Environmental Impact Statement 

for Combined Licenses (COLs)

for Turkey Point Nuclear Plant

Units 6 and 7

Final Report

Appendix E

U.S. Nuclear Regulatory Commission

Office of New Reactors 

Washington, DC 20555-0001

U.S. Army Corps of Engineers

Jacksonville District

Jacksonville, Florida 32232-0019

NUREG-2176, Vol. 4
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Environmental Impact Statement 

for Combined Licenses (COLs)

for Turkey Point Nuclear Plant

Units 6 and 7

Final Report

Appendix E

Manuscript Completed: October 2016

Date Published: October 2016

Division of New Reactor Licensing

Office of New Reactors

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Regulatory Division

Jacksonville District

U.S. Army Corps of Engineers

Jacksonville, Florida 32232-0019 

NUREG-2176, Vol. 4

October 2016 iii NUREG–2176 

Final Environmental Impact Statement for the Combined License (COL) 

FOR THE TURKEY POINT NUCLEAR PLANT 

Lead Agency: 

Cooperating Agency: 

Contact:

U.S. Nuclear Regulatory Commission 

U.S. Army Corps of Engineers, Jacksonville District 

Alicia Williamson, Environmental Project Manager 

Environmental Projects Branch 

Division of New Reactor Licensing 

Office of New Reactors 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Telephone: 301-415-1878 

e-mail: Alicia.Williamson@nrc.gov 

ABSTRACT 

This environmental impact statement (EIS) has been prepared in response to an application 

submitted to the U.S. Nuclear Regulatory Commission (NRC) by Florida Power & Light 

Company (FPL) for two combined construction permits and operating licenses (combined 

licenses or COLs). The proposed actions related to the FPL application are (1) NRC issuance 

of COLs for two new power reactor units (Units 6 and 7) at the Turkey Point Nuclear Power 

Plant site in Miami-Dade County, Florida, and (2) U.S. Army Corps of Engineers (USACE) 

decision to issue, deny, or issue with modifications a Department of the Army (DA) permit to 

perform certain dredge and fill activities in waters of the United States and to construct 

structures in navigable waters of the United States related to the project. The NRC, its 

contractors, and USACE make up the review team. The National Park Service (NPS) is also a 

cooperating agency on this EIS but does not now have a request to take any specific regulatory 

action before it. Due to this unique set of circumstances, impact determinations made in this 

EIS should only be attributed to the review team. This EIS documents the review team’s 

analysis, which considers and weighs the environmental impacts of constructing and operating 

two new nuclear units at the Turkey Point site and at alternative sites, including measures 

potentially available for reducing or avoiding adverse impacts. 

The EIS includes an evaluation of the impacts of construction and operation of Turkey Point 

Units 6 and 7 on waters of the United States pursuant to Section 404 of the Clean Water Act 

and on navigable waters of the United States pursuant to Section 10 of the Rivers and Harbors 

Act of 1899. The USACE will base its evaluation of FPL’s DA permit application, on the 

requirements of USACE regulations, the Clean Water Act Section 404(b)(1) Guidelines, and the 

USACE public interest review process. 

After considering the environmental aspects of the proposed action before the NRC, the NRC 

staff’s recommendation to the Commission is that the COLs be issued as proposed. This 

recommendation is based on (1) the application, including the Environmental Report (ER), 

submitted by FPL; (2) consultation with Federal, State, Tribal, and local agencies; (3) the review 

 
Abstract 

NUREG–2176 iv October 2016 

team’s independent review; (4) the consideration of public comments received on the 

environmental review; and (5) the assessments summarized in this EIS, including the potential 

mitigation measures identified in the ER and this EIS. 

NUREG-2176 has been reproduced 

from the best available copy. 
October 2016 v NUREG–2176 

CONTENTS 

ABSTRACT .................................................................................................................................. iii 

CONTENTS .................................................................................................................................. v

FIGURES .................................................................................................................................... xxi

TABLES..................................................................................................................................... xxv

EXECUTIVE SUMMARY .......................................................................................................... xxxi

ABBREVIATIONS/ACRONYMS ............................................................................................... xliii

1.0 INTRODUCTION .............................................................................................................. 1-1

1.1 Background .............................................................................................................. 1-2

1.1.1 Application and Review ................................................................................ 1-3

1.1.1.1 NRC COL Application Review ....................................................... 1-3

1.1.1.2 USACE Permit Application Review ................................................ 1-5

1.1.2 Preconstruction Activities ............................................................................. 1-6

1.1.3 Cooperating Agencies .................................................................................. 1-7

1.1.4 Concurrent NRC Reviews ............................................................................ 1-9

1.2 The Proposed Federal Actions ................................................................................. 1-9

1.3 The Purpose of and Need for the Proposed Actions .............................................. 1-10

1.4 Alternatives to the Proposed Actions ..................................................................... 1-11

1.5 Compliance and Consultations ............................................................................... 1-12

1.6 Report Contents ..................................................................................................... 1-12

2.0 AFFECTED ENVIRONMENT ........................................................................................... 2-1

2.1 Site Location ............................................................................................................. 2-1

2.2 Land Use .................................................................................................................. 2-4

2.2.1 The Site and Vicinity ..................................................................................... 2-4

2.2.1.1 Mineral Resources ......................................................................... 2-4

2.2.1.2 Nearby Population Centers, Schools, and Hospitals ..................... 2-5

2.2.1.3 Rail and Ports ................................................................................ 2-5

2.2.1.4 Comprehensive Plans and Zoning ................................................. 2-5

2.2.1.5 Site Access .................................................................................... 2-7

2.2.1.6 Existing Land Uses on the Turkey Point Site and in the 

Vicinity ........................................................................................... 2-7

2.2.2 Transmission Line Corridors and Offsite Areas .......................................... 2-12

2.2.2.1 Transmission Line Corridors ........................................................ 2-13

2.2.2.2 Transmission Substation Improvements ...................................... 2-17

2.2.2.3 Makeup and Potable Water System Pipelines ............................. 2-18

2.2.2.4 Fill Material Source Site ............................................................... 2-18

2.2.2.5 Emergency Operations Facility .................................................... 2-19

2.2.2.6 Roads and Highways ................................................................... 2-19
Contents 

NUREG–2176 vi October 2016 

2.2.3 The Region ................................................................................................. 2-21

2.2.3.1 Rail and Ports .............................................................................. 2-21

2.2.3.2 Regional Land Uses and Jurisdictions ......................................... 2-21

2.3 Water ...................................................................................................................... 2-24

2.3.1 Hydrology ................................................................................................... 2-25

2.3.1.1 Surface-Water Hydrology ............................................................ 2-25

2.3.1.2 Groundwater Hydrology ............................................................... 2-47

2.3.2 Water Use ................................................................................................... 2-58

2.3.2.1 Surface-Water Use ...................................................................... 2-59

2.3.2.2 Groundwater Use ......................................................................... 2-60

2.3.3 Water Quality .............................................................................................. 2-61

2.3.3.1 Surface-Water Quality ................................................................. 2-62

2.3.3.2 Groundwater Quality .................................................................... 2-68

2.3.4 Water Monitoring ........................................................................................ 2-71

2.3.4.1 Surface-Water Monitoring ............................................................ 2-71

2.3.4.2 Groundwater Monitoring .............................................................. 2-73

2.4 Ecology ................................................................................................................... 2-75

2.4.1 Terrestrial and Wetland Ecology ................................................................ 2-76

2.4.1.1 Terrestrial and Wetland Communities of the Site and Vicinity ..... 2-76

2.4.1.2 Terrestrial Resources – Associated Offsite Facilities ................... 2-80

2.4.1.3 Important Terrestrial Species and Habitats – Site and Vicinity .... 2-82

2.4.1.4 Important Terrestrial Species – Transmission Lines .................. 2-112

2.4.1.5 Important Terrestrial Species and Habitats – Other Offsite 

Facilities ..................................................................................... 2-117

2.4.1.6 Terrestrial Monitoring ................................................................. 2-118

2.4.1.7 Related Federal Projects and Consultation ............................... 2-118

2.4.2 Aquatic Ecology ........................................................................................ 2-119

2.4.2.1 Aquatic Resources – Site and Vicinity ....................................... 2-122

2.4.2.2 Aquatic Resources – Transmission Lines and Related 

Pipeline ...................................................................................... 2-134

2.4.2.3 Aquatic Species and Habitats .................................................... 2-136

2.4.2.4 Aquatic Monitoring ..................................................................... 2-159

2.5 Socioeconomics ................................................................................................... 2-162

2.5.1 Demographics .......................................................................................... 2-164

2.5.1.1 Resident Population ................................................................... 2-165

2.5.1.2 Transient Population .................................................................. 2-166

2.5.1.3 Migrant Labor ............................................................................. 2-167

2.5.2 Community Characteristics ....................................................................... 2-168

2.5.2.1 Economy .................................................................................... 2-168

2.5.2.2 Taxes ......................................................................................... 2-172

2.5.2.3 Transportation ............................................................................ 2-175

2.5.2.4 Aesthetics and Recreation ......................................................... 2-178

2.5.2.5 Housing ...................................................................................... 2-180
Contents 

October 2016 vii NUREG–2176 

2.5.2.6 Public Services .......................................................................... 2-181

2.6 Environmental Justice .......................................................................................... 2-187

2.6.1 Methodology ............................................................................................. 2-188

2.6.1.1 Minority Populations .................................................................. 2-189

2.6.1.2 Low-Income Populations ........................................................... 2-190

2.6.2 Analysis .................................................................................................... 2-196

2.6.3 Scoping and Outreach .............................................................................. 2-196

2.6.4 Migrant Populations .................................................................................. 2-196

2.6.5 Environmental Justice Summary .............................................................. 2-196

2.7 Historic and Cultural Resources ........................................................................... 2-197

2.7.1 Cultural Background ................................................................................. 2-197

2.7.2 Historic and Cultural Resources at the Site and in the Vicinity ................. 2-201

2.7.2.1 Archaeological Resources ......................................................... 2-202

2.7.2.2 Above-Ground Resources ......................................................... 2-202

2.7.2.3 Traditional Cultural Properties ................................................... 2-203

2.7.2.4 Historic and Cultural Resources in Transmission Line 

Corridors and Offsite Areas ....................................................... 2-203

2.7.3 Consultation .............................................................................................. 2-205

2.8 Geology ................................................................................................................ 2-208

2.9 Meteorology and Air Quality ................................................................................. 2-211

2.9.1 Climate ..................................................................................................... 2-211

2.9.1.1 Wind ........................................................................................... 2-212

2.9.1.2 Temperature .............................................................................. 2-213

2.9.1.3 Atmospheric Moisture ................................................................ 2-213

2.9.1.4 Severe Weather ......................................................................... 2-213

2.9.1.5 Atmospheric Stability ................................................................. 2-214

2.9.2 Air Quality ................................................................................................. 2-214

2.9.3 Atmospheric Dispersion ............................................................................ 2-215

2.9.3.1 Short-Term Dispersion Estimates .............................................. 2-215

2.9.3.2 Long-Term Dispersion Estimates............................................... 2-216

2.9.4 Meteorological Monitoring ........................................................................ 2-216

2.10 Nonradiological Health ......................................................................................... 2-217

2.10.1 Public and Occupational Health ............................................................... 2-217

2.10.1.1 Air Quality .................................................................................. 2-217

2.10.1.2 Occupational Injuries ................................................................. 2-220

2.10.1.3 Etiological Agents ...................................................................... 2-222

2.10.2 Noise ........................................................................................................ 2-224

2.10.3 Transportation .......................................................................................... 2-227

2.10.4 Electromagnetic Fields ............................................................................. 2-228

2.11 Radiological Environment ..................................................................................... 2-229
Contents 

NUREG–2176 viii October 2016 

2.12 Related Federal Projects and Consultation .......................................................... 2-231

3.0 SITE LAYOUT AND PLANT DESCRIPTION .................................................................. 3-1

3.1 External Appearance and Plant Layout .................................................................... 3-1

3.2 Proposed Plant Structures ....................................................................................... 3-4

3.2.1 Reactor Power-Conversion System ............................................................. 3-5

3.2.2 Structures with a Major Environmental Interface .......................................... 3-5

3.2.2.1 Landscape and Stormwater Drainage ........................................... 3-8

3.2.2.2 Cooling System .............................................................................. 3-8

3.2.2.3 Other Structures with a Permanent Environmental Interface ....... 3-14

3.2.2.4 Other Structures with a Temporary Environmental Interface ....... 3-19

3.2.3 Structures with a Minor Environmental Interface ........................................ 3-19

3.2.3.1 Nuclear Island and Other Reactor Buildings ................................ 3-19

3.2.3.2 Cranes and Footings ................................................................... 3-20

3.2.3.3 Pipelines ...................................................................................... 3-20

3.2.3.4 Support and Laydown Areas ....................................................... 3-21

3.2.3.5 Parking ......................................................................................... 3-21

3.2.3.6 Miscellaneous Buildings .............................................................. 3-21

3.3 Construction and Preconstruction Activities ........................................................... 3-21

3.3.1 Major Activity Areas .................................................................................... 3-23

3.3.1.1 Landscape and Stormwater Drainage ......................................... 3-23

3.3.1.2 Main Plant Area, Cooling Towers, and Makeup Water 

Reservoir ..................................................................................... 3-23

3.3.1.3 Reclaimed Makeup Water Reservoir and Cooling Towers .......... 3-24

3.3.1.4 Excavation Dewatering ................................................................ 3-25

3.3.1.5 Radial Collector Wells .................................................................. 3-25

3.3.1.6 Deep-Injection and Monitoring Wells ........................................... 3-25

3.3.1.7 Spoils Disposal ............................................................................ 3-25

3.3.1.8 Roads .......................................................................................... 3-26

3.3.1.9 Barge-Unloading Facility .............................................................. 3-26

3.3.1.10 Reclaimed Water-Treatment Facility ............................................ 3-26

3.3.1.11 Sanitary Waste-Treatment Plant .................................................. 3-26

3.3.1.12 Pipelines ...................................................................................... 3-26

3.3.1.13 Concrete Batch Plant ................................................................... 3-27

3.3.1.14 Construction-Support and Laydown Areas .................................. 3-27

3.3.1.15 Parking ......................................................................................... 3-27

3.3.1.16 Miscellaneous Buildings .............................................................. 3-27

3.3.1.17 Switchyard and Substation Expansions ....................................... 3-27

3.3.1.18 Transmission Lines ...................................................................... 3-27

3.3.1.19 Cranes and Crane Footings ......................................................... 3-28

3.3.2 Summary of Resource Parameters During Construction and 

Preconstruction ........................................................................................... 3-28

3.4 Operational Activities .............................................................................................. 3-29

3.4.1 Description of Operational Modes .............................................................. 3-29
Contents 

October 2016 ix NUREG–2176 

3.4.2 Plant-Environment Interfaces during Operation ......................................... 3-30

3.4.2.1 Stormwater-Management System ............................................... 3-30

3.4.2.2 Circulating-Water System ............................................................ 3-30

3.4.2.3 Injection Wells .............................................................................. 3-32

3.4.2.4 Other Environmental Interfaces during Operation ....................... 3-32

3.4.3 Radioactive Waste-Management System .................................................. 3-33

3.4.3.1 Liquid Radioactive Waste-Management System ......................... 3-34

3.4.3.2 Gaseous Radioactive Waste-Management System .................... 3-34

3.4.3.3 Solid Radioactive Waste-Management System ........................... 3-35

3.4.4 Nonradioactive Waste-Management Systems ........................................... 3-36

3.4.4.1 Solid-Waste Management............................................................ 3-36

3.4.4.2 Liquid-Waste Management .......................................................... 3-37

3.4.4.3 Gaseous Waste Management ..................................................... 3-39

3.4.4.4 Hazardous- and Mixed-Waste Management ............................... 3-40

3.4.5 Summary of Resource Parameters During Operation ................................ 3-40

4.0 CONSTRUCTION IMPACTS AT THE TURKEY POINT SITE ......................................... 4-1

4.1 Land-Use Impacts .................................................................................................... 4-4

4.1.1 The Turkey Point Site and Vicinity ................................................................ 4-4

4.1.1.1 Onsite Land-Use Impacts .............................................................. 4-4

4.1.1.2 Pipelines ........................................................................................ 4-8

4.1.1.3 Access Roadways ......................................................................... 4-9

4.1.1.4 Fill Material – Sources and Transportation .................................. 4-12

4.1.2 Transmission Line Corridors and Associated Offsite Areas ....................... 4-13

4.1.2.1 Transmission Line Corridors ........................................................ 4-13

4.1.2.2 Substations .................................................................................. 4-18

4.1.3 Summary of Land-Use Impacts .................................................................. 4-18

4.2 Water-Related Impacts ........................................................................................... 4-20

4.2.1 Hydrological Alterations .............................................................................. 4-21

4.2.1.1 Biscayne Bay ............................................................................... 4-21

4.2.1.2 Biscayne Aquifer .......................................................................... 4-23

4.2.1.3 Floridan Aquifers and Boulder Zone ............................................ 4-25

4.2.1.4 IWF (Cooling Canals) .................................................................. 4-26

4.2.1.5 Offsite/Adjacent Areas ................................................................. 4-29

4.2.2 Water-Use Impacts ..................................................................................... 4-30

4.2.2.1 Surface-Water-Use Impacts......................................................... 4-30

4.2.2.2 Groundwater-Use Impacts ........................................................... 4-30

4.2.3 Water-Quality Impacts ................................................................................ 4-31

4.2.3.1 Surface-Water-Quality Impacts .................................................... 4-31

4.2.3.2 Groundwater-Quality Impacts ...................................................... 4-33

4.2.4 Water Monitoring ........................................................................................ 4-34

4.2.4.1 Surface-Water Monitoring ............................................................ 4-34

4.2.4.2 Groundwater Monitoring .............................................................. 4-35
Contents 

NUREG–2176 x October 2016 

4.3 Ecological Impacts ................................................................................................. 4-35

4.3.1 Terrestrial and Wetland Impacts ................................................................. 4-35

4.3.1.1 Terrestrial Resources – Site and Vicinity ..................................... 4-35

4.3.1.2 Terrestrial Resources – Associated Offsite Facilities ................... 4-40

4.3.1.3 Impacts on Important Terrestrial Species and Habitats ............... 4-45

4.3.1.4 Impacts from Fill Acquisition ........................................................ 4-65

4.3.1.5 Terrestrial Monitoring ................................................................... 4-65

4.3.1.6 Potential Mitigation Measures for Terrestrial Impacts .................. 4-65

4.3.1.7 Summary of Impacts on Terrestrial Resources ............................ 4-70

4.3.2 Aquatic Impacts .......................................................................................... 4-74

4.3.2.1 Aquatic Resources − Site and Vicinity ......................................... 4-75

4.3.2.2 Aquatic Resources – Transmission Line and Pipeline 

Corridors ...................................................................................... 4-85

4.3.2.3 Aquatic Species and Habitats ...................................................... 4-86

4.3.2.4 Aquatic Monitoring ....................................................................... 4-96

4.3.2.5 Summary of Impacts on Aquatic Resources ................................ 4-97

4.4 Socioeconomic Impacts ......................................................................................... 4-98

4.4.1 Physical Impacts ......................................................................................... 4-98

4.4.1.1 Noise Impacts on Workers and the Local Public ......................... 4-98

4.4.1.2 Air-Quality Impacts on Workers and the Local Public .................. 4-99

4.4.1.3 Buildings ...................................................................................... 4-99

4.4.1.4 Roads ........................................................................................ 4-100

4.4.1.5 Waterways ................................................................................. 4-102

4.4.1.6 Aesthetics .................................................................................. 4-102

4.4.1.7 Summary of Physical Impacts .................................................... 4-103

4.4.2 Demography ............................................................................................. 4-103

4.4.3 Economic Impacts on the Community ...................................................... 4-105

4.4.3.1 Economy .................................................................................... 4-106

4.4.3.2 Taxes ......................................................................................... 4-108

4.4.3.3 Summary of Economic Impacts on the Community ................... 4-110

4.4.4 Infrastructure and Community Service Impacts ........................................ 4-110

4.4.4.1 Traffic ......................................................................................... 4-110

4.4.4.2 Recreation ................................................................................. 4-113

4.4.4.3 Housing ...................................................................................... 4-113

4.4.4.4 Public Services .......................................................................... 4-115

4.4.4.5 Education ................................................................................... 4-118

4.4.4.6 Summary of Infrastructure and Community Service Impacts ..... 4-119

4.4.5 Summary of Socioeconomic Impacts ....................................................... 4-119

4.5 Environmental Justice Impacts ............................................................................. 4-119

4.5.1 Physical and Socioeconomics Impacts .................................................... 4-120

4.5.1.1 Physical Impacts ........................................................................ 4-120

4.5.1.2 Socioeconomics ......................................................................... 4-121

4.5.2 Health Impacts .......................................................................................... 4-121
Contents 

October 2016 xi NUREG–2176 

4.5.3 Subsistence and Special Conditions ........................................................ 4-121

4.5.3.1 Subsistence and Unique Pathways of Exposure to 

Environmental Effects ................................................................ 4-122

4.5.3.2 High-Density Communities ........................................................ 4-122

4.5.4 Summary of Environmental Justice Impacts ............................................ 4-122

4.6 Historic and Cultural Resources Impacts ............................................................. 4-122

4.7 Meteorological and Air-Quality Impacts ................................................................ 4-125

4.7.1 Construction and Preconstruction Activities ............................................. 4-125

4.7.2 Transportation .......................................................................................... 4-127

4.7.3 Summary of Meteorological and Air-Quality Impacts ............................... 4-128

4.8 Nonradiological Health Impacts ............................................................................ 4-128

4.8.1 Public and Occupational Health ............................................................... 4-129

4.8.1.1 Public Health .............................................................................. 4-129

4.8.1.2 Construction Worker Health ....................................................... 4-130

4.8.1.3 Summary of Public and Construction Worker Health Impacts ... 4-131

4.8.2 Noise Impacts ........................................................................................... 4-131

4.8.3 Impacts of Transporting Construction Materials and Personnel to the 

Turkey Point Site ...................................................................................... 4-133

4.8.4 Summary of Nonradiological Health Impacts ........................................... 4-136

4.9 Radiation Exposure to Construction Workers ...................................................... 4-136

4.9.1 Direct Radiation Exposures ...................................................................... 4-136

4.9.2 Radiation Exposures from Gaseous Effluents .......................................... 4-137

4.9.3 Radiation Exposures from Liquid Effluents ............................................... 4-138

4.9.4 Total Dose to Construction Workers ......................................................... 4-138

4.9.5 Summary of Radiological Health Impacts ................................................. 4-138

4.10 Nonradioactive Waste Impacts ............................................................................. 4-138

4.10.1 Impacts on Land ....................................................................................... 4-139

4.10.2 Impacts on Water ..................................................................................... 4-140

4.10.3 Impacts on Air ........................................................................................... 4-141

4.10.4 Summary of Nonradioactive Waste Impacts ............................................ 4-142

4.11 Measures and Controls to Limit Adverse Impacts During Construction Activities 4-142

4.12 Summary of Construction and Preconstruction Impacts ...................................... 4-147

5.0 OPERATIONAL IMPACTS AT THE TURKEY POINT SITE............................................ 5-1

5.1 Land-Use Impacts .................................................................................................... 5-1

5.1.1 The Site and Vicinity ..................................................................................... 5-1

5.1.1.1 Onsite Land-Use Impacts .............................................................. 5-2

5.1.1.2 Pipelines ........................................................................................ 5-3

5.1.1.3 Access Roadways ......................................................................... 5-4

5.1.2 Transmission Line Corridors and Associated Offsite Areas ......................... 5-4
Contents 

NUREG–2176 xii October 2016 

5.1.2.1 Transmission Line Corridors .......................................................... 5-4

5.1.2.2 Substations .................................................................................... 5-5

5.1.3 Summary of Land-Use Impacts .................................................................... 5-5

5.2 Water-Related Impacts ............................................................................................. 5-5

5.2.1 Hydrological Alterations ................................................................................ 5-7

5.2.1.1 Biscayne Bay ................................................................................. 5-8

5.2.1.2 Biscayne Aquifer .......................................................................... 5-13

5.2.1.3 Boulder Zone ............................................................................... 5-20

5.2.1.4 Industrial Wastewater Facility (Cooling Canals) .......................... 5-29

5.2.1.5 Effect of Radial Collector Well Operation..................................... 5-33

5.2.1.6 Offsite/Adjacent Areas ................................................................. 5-33

5.2.2 Water-Use Impacts ..................................................................................... 5-34

5.2.2.1 Surface-Water-Use Impacts......................................................... 5-34

5.2.2.2 Groundwater-Use Impacts ........................................................... 5-34

5.2.3 Water-Quality Impacts ................................................................................ 5-37

5.2.3.1 Surface-Water-Quality Impacts .................................................... 5-37

5.2.3.2 Groundwater-Quality Impacts ...................................................... 5-38

5.2.4 Water Monitoring ........................................................................................ 5-42

5.2.4.1 Surface Water .............................................................................. 5-42

5.2.4.2 Groundwater ................................................................................ 5-42

5.3 Ecological Impacts ................................................................................................. 5-43

5.3.1 Terrestrial and Wetland Impacts Related to Operations ............................. 5-43

5.3.1.1 Terrestrial Resources – Site and Vicinity ..................................... 5-44

5.3.1.2 Terrestrial Resources – Associated Offsite Facilities ................... 5-51

5.3.1.3 Impacts on Important Terrestrial Species and Habitats ............... 5-54

5.3.1.4 Terrestrial Monitoring ................................................................... 5-65

5.3.1.5 Potential Mitigation Measures for Terrestrial Impacts .................. 5-65

5.3.1.6 Summary of Impacts on Terrestrial Resources ............................ 5-65

5.3.2 Aquatic Impacts Related to Operation ........................................................ 5-67

5.3.2.1 Aquatic Resources – Site and Vicinity ......................................... 5-67

5.3.2.2 Aquatic Resources – Transmission Line and Pipeline 

Corridors ...................................................................................... 5-70

5.3.2.3 Aquatic Species and Habitats ...................................................... 5-70

5.3.2.4 Aquatic Monitoring During Operation ........................................... 5-77

5.3.2.5 Summary of Operational Impacts on Aquatic Resources ............ 5-78

5.4 Socioeconomic Impacts ......................................................................................... 5-78

5.4.1 Physical Impacts ......................................................................................... 5-78

5.4.1.1 Noise Impacts on Workers and the Local Public ......................... 5-78

5.4.1.2 Air-Quality Impacts on Workers and the Local Public .................. 5-79

5.4.1.3 Buildings ...................................................................................... 5-79

5.4.1.4 Roads .......................................................................................... 5-79

5.4.1.5 Waterways ................................................................................... 5-80

5.4.1.6 Aesthetics .................................................................................... 5-80
Contents 

October 2016 xiii NUREG–2176 

5.4.1.7 Summary of Physical Impacts ...................................................... 5-81

5.4.2 Demography ............................................................................................... 5-81

5.4.3 Economic Impacts on the Community ........................................................ 5-82

5.4.3.1 Economy ...................................................................................... 5-82

5.4.3.2 Taxes ........................................................................................... 5-83

5.4.3.3 Summary of Economic Impacts on the Community ..................... 5-86

5.4.4 Infrastructure and Community Services ..................................................... 5-86

5.4.4.1 Traffic ........................................................................................... 5-86

5.4.4.2 Recreation ................................................................................... 5-87

5.4.4.3 Housing ........................................................................................ 5-88

5.4.4.4 Public Services ............................................................................ 5-89

5.4.4.5 Education ..................................................................................... 5-91

5.4.4.6 Summary of Infrastructure and Community Services .................. 5-92

5.4.4.7 Summary of Socioeconomic Impacts ........................................... 5-92

5.5 Environmental Justice ............................................................................................ 5-92

5.5.1 Physical and Socioeconomic Impacts ........................................................ 5-93

5.5.1.1 Soil-Related Impacts .................................................................... 5-93

5.5.1.2 Water-Related Impacts ................................................................ 5-93

5.5.1.3 Air-Related Impacts ..................................................................... 5-93

5.5.1.4 Noise Impacts .............................................................................. 5-94

5.5.1.5 Socioeconomic Impacts ............................................................... 5-94

5.5.2 Health Impacts ............................................................................................ 5-94

5.5.3 Subsistence and Special Conditions .......................................................... 5-94

5.5.3.1 Subsistence and Unique Pathways of Exposure to 

Environmental Effects .................................................................. 5-94

5.5.3.2 High-Density Communities .......................................................... 5-95

5.5.4 Summary of Environmental Justice Impacts .............................................. 5-95

5.6 Historic and Cultural Resources Impacts ............................................................... 5-95

5.7 Meteorological and Air-Quality Impacts .................................................................. 5-97

5.7.1 Air-Quality Impacts ..................................................................................... 5-97

5.7.1.1 Criteria Pollutants......................................................................... 5-97

5.7.1.2 Greenhouse Gases ...................................................................... 5-99

5.7.2 Cooling-System Impacts ............................................................................. 5-99

5.7.3 Transmission Line Impacts ....................................................................... 5-101

5.7.4 Summary of Meteorological and Air-Quality Impacts ............................... 5-101

5.8 Nonradiological Health Impacts ............................................................................ 5-102

5.8.1 Etiological and Chemical Agents .............................................................. 5-102

5.8.1.1 Operational Components ........................................................... 5-102

5.8.1.2 Potential Impacts ....................................................................... 5-103

5.8.2 Noise ........................................................................................................ 5-104

5.8.3 Acute Effects of Electromagnetic Fields ................................................... 5-106
Contents 

NUREG–2176 xiv October 2016 

5.8.4 Chronic Effects of Electromagnetic Fields ................................................ 5-107

5.8.5 Occupational Health ................................................................................. 5-108

5.8.6 Impacts of Transporting Operations Personnel to and from the Turkey 

Point Site .................................................................................................. 5-110

5.8.7 Summary of Nonradiological Health Impacts ........................................... 5-112

5.9 Radiological Impacts of Normal Operations ......................................................... 5-113

5.9.1 Exposure Pathways .................................................................................. 5-113

5.9.2 Radiation Doses to Members of the Public .............................................. 5-115

5.9.2.1 Liquid Effluent Pathway ............................................................. 5-115

5.9.2.2 Gaseous Effluent Pathway ........................................................ 5-118

5.9.3 Impacts on Members of the Public ........................................................... 5-119

5.9.3.1 Maximally Exposed Individual .................................................... 5-119

5.9.3.2 Population Dose ........................................................................ 5-122

5.9.3.3 Deep-Well Injection Scenarios – Postulated Doses ................... 5-123

5.9.3.4 Summary of Radiological Impacts on Members of the Public .... 5-124

5.9.4 Occupational Doses to Workers ............................................................... 5-124

5.9.5 Impacts on Non-Human Biota .................................................................. 5-125

5.9.5.1 Liquid Effluent Pathway ............................................................. 5-125

5.9.5.2 Gaseous Effluent Pathway ........................................................ 5-125

5.9.5.3 Summary of Impacts on Biota Other Than Humans .................. 5-126

5.9.6 Radiological Monitoring ............................................................................ 5-126

5.10 Nonradioactive Waste Impacts ............................................................................. 5-127

5.10.1 Impacts on Land ....................................................................................... 5-127

5.10.2 Impacts on Water ..................................................................................... 5-128

5.10.3 Impacts on Air ........................................................................................... 5-129

5.10.4 Summary of Nonradiological Waste Impacts ............................................ 5-130

5.11 Environmental Impacts of Postulated Accidents .................................................. 5-130

5.11.1 Design Basis Accidents ............................................................................ 5-134

5.11.2 Severe Accidents ...................................................................................... 5-136

5.11.2.1 Air Pathway ................................................................................ 5-138

5.11.2.2 Surface-Water Pathways ........................................................... 5-143

5.11.2.3 Groundwater Pathway ............................................................... 5-144

5.11.2.4 Externally Initiated Events ......................................................... 5-144

5.11.2.5 Summary of Severe Accident Impacts ....................................... 5-146

5.11.3 Severe Accident Mitigation Alternatives ................................................... 5-147

5.11.4 Summary of Postulated Accident Impacts ................................................ 5-151

5.12 Measures and Controls to Limit Adverse Impacts during Operation .................... 5-151

5.13 Summary of Operational Impacts ......................................................................... 5-154

6.0 FUEL CYCLE, TRANSPORTATION, AND DECOMMISSIONING .................................. 6-1

6.1 Fuel-Cycle Impacts and Solid Waste Management ................................................. 6-1
Contents 

October 2016 xv NUREG–2176 

6.1.1 Land Use ...................................................................................................... 6-7

6.1.2 Water Use ..................................................................................................... 6-8

6.1.3 Fossil-Fuel Impacts ...................................................................................... 6-8

6.1.4 Chemical Effluents ........................................................................................ 6-9

6.1.5 Radiological Effluents ................................................................................. 6-10

6.1.6 Radiological Wastes ................................................................................... 6-12

6.1.7 Occupational Dose ..................................................................................... 6-15

6.1.8 Transportation ............................................................................................ 6-16

6.1.9 Conclusions for Fuel Cycle and Solid Waste Management ........................ 6-16

6.2 Transportation Impacts ........................................................................................... 6-16

6.2.1 Transportation of Unirradiated Fuel ............................................................ 6-19

6.2.1.1 Normal Conditions ....................................................................... 6-19

6.2.1.2 Radiological Impacts of Transportation Accidents ....................... 6-25

6.2.1.3 Nonradiological Impacts of Transportation Accidents .................. 6-25

6.2.2 Transportation of Spent Fuel ...................................................................... 6-26

6.2.2.1 Normal Conditions ....................................................................... 6-27

6.2.2.2 Radiological Impacts of Transportation Accidents ....................... 6-33

6.2.2.3 Nonradiological Impact of Spent Fuel Shipments ........................ 6-36

6.2.3 Transportation of Radioactive Waste ......................................................... 6-37

6.2.4 Conclusions for Transportation ................................................................... 6-38

6.3 Decommissioning Impacts ..................................................................................... 6-39

7.0 CUMULATIVE IMPACTS ................................................................................................. 7-1

7.1 Land-Use Impacts .................................................................................................... 7-8

7.2 Water-Use and Water-Quality Impacts ................................................................... 7-11

7.2.1 Water-Use Impacts ..................................................................................... 7-11

7.2.1.1 Surface-Water–Use Impacts ........................................................ 7-12

7.2.1.2 Groundwater-Use Impacts ........................................................... 7-13

7.2.2 Water-Quality Impacts ................................................................................ 7-14

7.2.2.1 Surface-Water-Quality Impacts .................................................... 7-14

7.2.2.2 Groundwater-Quality Impacts ...................................................... 7-16

7.3 Ecological Impacts ................................................................................................. 7-18

7.3.1 Terrestrial Ecosystem Impacts ................................................................... 7-19

7.3.1.1 Past, Present, and Reasonably Foreseeable Future Actions 

Affecting Terrestrial Ecology ........................................................ 7-19

7.3.1.2 Summary of Terrestrial and Wetland Ecology Impacts ................ 7-23

7.3.2 Cumulative Effects for Aquatic Ecology ...................................................... 7-24

7.3.2.1 Description of Past, Present, and Reasonably Foreseeable 

Future Actions .............................................................................. 7-24

7.3.2.2 Summary of Aquatic Ecology Impacts ......................................... 7-29

7.4 Socioeconomic and Environmental Justice Impacts .............................................. 7-29
Contents 

NUREG–2176 xvi October 2016 

7.4.1 Socioeconomics ......................................................................................... 7-29

7.4.2 Environmental Justice ................................................................................ 7-31

7.5 Historic and Cultural Resources Impacts ............................................................... 7-31

7.6 Air-Quality Impacts ................................................................................................. 7-33

7.6.1 Criteria Pollutants ....................................................................................... 7-33

7.6.2 Greenhouse Gas Emissions ....................................................................... 7-35

7.6.3 Summary of Air-Quality Impacts ................................................................. 7-37

7.7 Nonradiological Health ........................................................................................... 7-37

7.8 Radiological Impacts of Normal Operations ........................................................... 7-39

7.9 Nonradioactive Waste Impacts ............................................................................... 7-40

7.10 Postulated Accidents .............................................................................................. 7-41

7.11 Fuel-Cycle, Transportation, and Decommissioning Impacts .................................. 7-42

7.11.1 Fuel Cycle ................................................................................................... 7-42

7.11.2 Transportation ............................................................................................ 7-43

7.11.3 Decommissioning ....................................................................................... 7-45

7.11.4 Summary of Cumulative Fuel Cycle, Transportation, and 

Decommissioning Impacts .......................................................................... 7-45

7.12 Summary of Cumulative Impacts ........................................................................... 7-46

8.0 NEED FOR POWER ........................................................................................................ 8-1

8.1 Description of the Power System ............................................................................. 8-1

8.1.1 Description of the FPL System ..................................................................... 8-2

8.1.2 Evaluation of the FPL Analytical Process ..................................................... 8-4

8.1.2.1 Systematic ..................................................................................... 8-4

8.1.2.2 Comprehensive .............................................................................. 8-4

8.1.2.3 Subject to Confirmation ................................................................. 8-5

8.1.2.4 Responsive to Forecasting Uncertainty ......................................... 8-5

8.2 Determination of Demand ........................................................................................ 8-5

8.2.1 Factors in the FPSC Determination of Need ................................................ 8-6

8.2.1.1 Growth in Demand ......................................................................... 8-6

8.2.1.2 Electric System Reliability .............................................................. 8-6

8.2.1.3 Fuel Diversity ................................................................................. 8-7

8.2.1.4 Baseload Capacity ......................................................................... 8-7

8.2.1.5 Adequate Electricity at a Reasonable Cost .................................... 8-7

8.2.1.6 Demand-Side Management and Renewable Energy Sources 

and Technologies .......................................................................... 8-8

8.2.1.7 Most Cost-Effective Source of Power ............................................ 8-8

8.2.2 FPL’s Demand for Electricity ........................................................................ 8-9

8.3 Determination of Supply ........................................................................................... 8-9

8.4 Conclusions ............................................................................................................ 8-12

9.0 ENVIRONMENTAL IMPACTS OF ALTERNATIVES ...................................................... 9-1
Contents 

October 2016 xvii NUREG–2176 

9.1 No-Action Alternative ................................................................................................ 9-2

9.2 Energy Alternatives .................................................................................................. 9-2

9.2.1 Alternatives Not Requiring New Generating Capacity .................................. 9-3

9.2.1.1 Purchased Power .......................................................................... 9-3

9.2.1.2 Reactivating Retired Power Plants or Extending Operating 

Life ................................................................................................. 9-4

9.2.1.3 Energy Efficiency and Demand-Side Management ....................... 9-5

9.2.1.4 Summary Statement Regarding Alternatives Not Requiring 

New Generating Capacity .............................................................. 9-5

9.2.2 Alternatives Requiring New Generating Capacity ........................................ 9-5

9.2.2.1 Coal-Fired Power Generation ........................................................ 9-6

9.2.2.2 Natural-Gas−Fired Power Generation ......................................... 9-16

9.2.3 Other Alternatives ....................................................................................... 9-22

9.2.3.1 Oil-Fired Power Generation ......................................................... 9-23

9.2.3.2 Wind Power ................................................................................. 9-23

9.2.3.3 Solar Power ................................................................................. 9-24

9.2.3.4 Hydropower ................................................................................. 9-25

9.2.3.5 Geothermal Energy ...................................................................... 9-26

9.2.3.6 Wood Waste ................................................................................ 9-26

9.2.3.7 Municipal Solid Waste ................................................................. 9-26

9.2.3.8 Other Biomass-Derived Fuels ...................................................... 9-27

9.2.3.9 Fuel Cells ..................................................................................... 9-28

9.2.4 Combination of Alternatives ........................................................................ 9-28

9.2.5 Summary Comparison of Alternatives ........................................................ 9-30

9.3 Alternative Sites ..................................................................................................... 9-33

9.3.1 Alternative Site-Selection Process ............................................................. 9-34

9.3.1.1 Selection of Region of Interest ..................................................... 9-35

9.3.1.2 Selection of Candidate Areas ...................................................... 9-35

9.3.1.3 Selection of Potential Sites .......................................................... 9-37

9.3.1.4 Selection of Candidate Sites ........................................................ 9-40

9.3.1.5 Selection of the Proposed Site .................................................... 9-40

9.3.1.6 Review Team Evaluation of FPL’s Site-Selection Process .......... 9-41

9.3.2 Glades Site ................................................................................................. 9-44

9.3.2.1 Land Use ..................................................................................... 9-53

9.3.2.2 Water Use and Quality ................................................................. 9-56

9.3.2.3 Terrestrial and Wetland Resources ............................................. 9-61

9.3.2.4 Aquatic Resources ....................................................................... 9-70

9.3.2.5 Socioeconomics ........................................................................... 9-75

9.3.2.6 Environmental Justice .................................................................. 9-82

9.3.2.7 Historic and Cultural Resources .................................................. 9-88

9.3.2.8 Air Quality .................................................................................... 9-91

9.3.2.9 Nonradiological Health Impacts ................................................... 9-93

9.3.2.10 Radiological Impacts of Normal Operations ................................. 9-94

9.3.2.11 Postulated Accidents ................................................................... 9-95
Contents 

NUREG–2176 xviii October 2016 

9.3.3 Martin Site .................................................................................................. 9-96

9.3.3.1 Land Use ................................................................................... 9-108

9.3.3.2 Water Use and Quality ............................................................... 9-111

9.3.3.3 Terrestrial and Wetland Resources ........................................... 9-116

9.3.3.4 Aquatic Resources ..................................................................... 9-125

9.3.3.5 Socioeconomics ......................................................................... 9-129

9.3.3.6 Environmental Justice ................................................................ 9-135

9.3.3.7 Historic and Cultural Resources ................................................ 9-141

9.3.3.8 Air-Quality Impacts .................................................................... 9-144

9.3.3.9 Nonradiological Health ............................................................... 9-145

9.3.3.10 Radiological Impacts of Normal Operations ............................... 9-147

9.3.3.11 Postulated Accidents ................................................................. 9-147

9.3.4 Okeechobee 2 Site ................................................................................... 9-148

9.3.4.1 Land Use ................................................................................... 9-157

9.3.4.2 Water Use and Quality ............................................................... 9-161

9.3.4.3 Terrestrial and Wetland Resources ........................................... 9-165

9.3.4.4 Aquatic Resources ..................................................................... 9-172

9.3.4.5 Socioeconomics ......................................................................... 9-175

9.3.4.6 Environmental Justice ................................................................ 9-182

9.3.4.7 Historic and Cultural Resources ................................................ 9-187

9.3.4.8 Air-Quality Impacts .................................................................... 9-190

9.3.4.9 Nonradiological Health ............................................................... 9-192

9.3.4.10 Radiological Impacts of Normal Operations ............................... 9-194

9.3.4.11 Postulated Accidents ................................................................. 9-194

9.3.5 St. Lucie Site ............................................................................................ 9-195

9.3.5.1 Land Use ................................................................................... 9-204

9.3.5.2 Water Use and Quality ............................................................... 9-207

9.3.5.3 Terrestrial and Wetland Resources ........................................... 9-211

9.3.5.4 Aquatic Resources ..................................................................... 9-219

9.3.5.5 Socioeconomics ......................................................................... 9-224

9.3.5.6 Environmental Justice ................................................................ 9-231

9.3.5.7 Historic and Cultural Resources ................................................ 9-236

9.3.5.8 Air Quality Impacts ..................................................................... 9-239

9.3.5.9 Nonradiological Health ............................................................... 9-240

9.3.5.10 Radiological Impacts of Normal Operations ............................... 9-243

9.3.5.11 Postulated Accidents ................................................................. 9-243

9.3.6 Comparison of the Impacts of the Proposed Action and the Alternative 

Sites .......................................................................................................... 9-244

9.3.6.1 Comparison of Cumulative Impacts at the Proposed and 

Alternative Sites ......................................................................... 9-245

9.3.6.2 Environmentally Preferable Sites ............................................... 9-247

9.3.6.3 Obviously Superior Sites............................................................ 9-249

9.4 System Design Alternatives ................................................................................. 9-250

9.4.1 Heat-Dissipation Systems ........................................................................ 9-250

9.4.1.1 Natural Draft Cooling Towers ..................................................... 9-250
Contents 

October 2016 xix NUREG–2176 

9.4.1.2 Fan-Assisted Natural Draft Cooling Towers ............................... 9-251

9.4.1.3 Once-Through Cooling .............................................................. 9-251

9.4.1.4 Cooling Pond ............................................................................. 9-252

9.4.1.5 Spray Ponds .............................................................................. 9-252

9.4.1.6 Dry Cooling Towers ................................................................... 9-252

9.4.1.7 Combination Wet/Dry Cooling-Tower System ........................... 9-253

9.4.1.8 Mechanical Draft Towers with Plume Abatement ...................... 9-253

9.4.2 Circulating-Water Systems ....................................................................... 9-253

9.4.2.1 Water Supplies .......................................................................... 9-254

9.4.2.2 Intake Alternatives ..................................................................... 9-256

9.4.2.3 Discharge Alternatives ............................................................... 9-257

9.4.2.4 Water Treatment ........................................................................ 9-258

9.4.3 Summary Statement ................................................................................. 9-258

9.5 U.S. Army Corps of Engineers Alternatives Evaluation ........................................ 9-258

10.0 CONCLUSIONS AND RECOMMENDATIONS .............................................................. 10-1

10.1 Impacts of the Proposed Action ............................................................................. 10-4

10.2 Unavoidable Adverse Environmental Impacts ........................................................ 10-5

10.2.1 Unavoidable Adverse Impacts during Construction and 

Preconstruction Activities ........................................................................... 10-5

10.2.2 Unavoidable Adverse Impacts during Operation ........................................ 10-9

10.3 Relationship between Short-Term Uses and Long-Term Productivity of the 

Human Environment ............................................................................................. 10-14

10.4 Irreversible and Irretrievable Commitments of Resources ................................... 10-15

10.4.1 Irreversible Commitments of Resources .................................................. 10-15

10.4.1.1 Land Use ................................................................................... 10-15

10.4.1.2 Water Use .................................................................................. 10-15

10.4.1.3 Ecological Resources ................................................................ 10-15

10.4.1.4 Socioeconomic Resources ........................................................ 10-15

10.4.1.5 Historical and Cultural Resources.............................................. 10-16

10.4.1.6 Air and Water ............................................................................. 10-16

10.4.2 Irretrievable Commitments of Resources ................................................. 10-16

10.5 Alternative to the Proposed Actions ..................................................................... 10-16

10.6 Benefit-Cost Balance ............................................................................................ 10-17

10.6.1 Benefits ..................................................................................................... 10-18

10.6.1.1 Societal Benefits ........................................................................ 10-18

10.6.1.2 Regional Benefits ....................................................................... 10-20

10.6.2 Costs ........................................................................................................ 10-21

10.6.2.1 Internal Costs ............................................................................. 10-24

10.6.2.2 External Costs ........................................................................... 10-26

10.6.3 Summary of Benefits and Costs ............................................................... 10-27

10.7 NRC Staff Recommendation ................................................................................ 10-28
Contents 

NUREG–2176 xx October 2016 

11.0 REFERENCES ............................................................................................................... 11-1

12.0 INDEX............................................................................................................................. 12-1

APPENDIX A – CONTRIBUTORS TO THE ENVIRONMENTAL IMPACT STATEMENT ..... A-1

APPENDIX B – ORGANIZATIONS CONTACTED ................................................................ B-1 

APPENDIX C – NRC AND USACE ENVIRONMENTAL 

REVIEW CORRESPONDENCE ................................................................... C-1 

APPENDIX D – SCOPING COMMENTS AND RESPONSES ............................................... D-1 

APPENDIX E – DRAFT ENVIRONMENTAL IMPACT STATEMENT COMMENTS AND 

RESPONSES ................................................................................................ E-1 

APPENDIX F – KEY CONSULTATION CORRESPONDENCE ............................................. F-1 

APPENDIX G – SUPPORTING DOCUMENTATION ............................................................. G-1 

APPENDIX H – AUTHORIZATIONS, PERMITS, AND CERTIFICATIONS ........................... H-1 

APPENDIX I – THE EFFECT OF CLIMATE CHANGE ON THE EVALUATION OF 

ENVIRONMENTAL IMPACTS........................................................................ I-1 

APPENDIX J – GREENHOUSE GAS FOOTPRINT ESTIMATES FOR A REFERENCE

1,000 MW(E) LIGHT-WATER REACTOR ..................................................... J-1 

APPENDIX K – POTENTIAL USACE ALTERNATIVE TRANSMISSION LINE ROUTES .... K-1 
October 2016 xxi NUREG–2176 

FIGURES 

ES-1 The Turkey Point Site and Affected Environment ....................................................... xxxiii 

ES-2 Location of Sites Considered as Alternatives to the Turkey Point Site ....................... xxxix 

2-1 Proposed Units 6 and 7 Plant Area and 50-Mile Region ................................................ 2-2

2-2 Proposed Units 6 and 7 Plant Area and 6-Mile Vicinity .................................................. 2-3

2-3 Oblique Aerial Photograph of the Proposed Units 6 and 7 Plant Area and 

Surrounding Area ........................................................................................................... 2-5

2-4 Principal Land Uses in the 6-Mile Vicinity of the Turkey Point Site ................................ 2-9

2-5 Locations of Proposed Transmission Line Corridors and Water Pipelines at the 

Turkey Point Site .......................................................................................................... 2-14

2-6 Map Showing Major Roads, Highways, and Rail Lines within the Turkey Point 

Site Vicinity ................................................................................................................... 2-20

2-7 Land Use within the 50-Mile Radius of the Turkey Point Site ...................................... 2-22

2-8 Physiographic Provinces in Southeast Florida ............................................................. 2-26

2-9 South Florida Canal System 1920 and 1990 ............................................................... 2-27

2-10 South Florida Typical Surface Hydrologic Flows Historic and Present ........................ 2-29

2-11 Comprehensive Everglades Restoration Plan Projects in Southeastern Florida 

that Are Planned through 2020 .................................................................................... 2-30

2-12 Regional Hydrologic System Showing the Canals, Glades, etc. .................................. 2-32

2-13 Biscayne Bay Bathymetry and Features ...................................................................... 2-34

2-14 Salinity Station Locations in Biscayne Bay .................................................................. 2-36

2-15 Salinity Time Series from 2005 through 2012 for the Four Stations near the 

Turkey Point Site .......................................................................................................... 2-37

2-16 Site Drainage Sub-Basins for the Existing Condition ................................................... 2-40

2-17 Temperature in Cooling Canals ................................................................................... 2-45

2-18 Salinity in Cooling Canals ............................................................................................ 2-45

2-19 Geologic Stratigraphy and Major Aquifers beneath the Turkey Point Site ................... 2-48

2-20 Specific Conductance Isopleths along a West-to-East Cross Section through the 

IWF ............................................................................................................................... 2-52

2-21 Monthly Water-Quality Measurements at Station BISC123 for the Period of 

Record Including the Monthly Averages for Each Constituent ..................................... 2-63

2-22 USGS Estimated Extent of Saltwater Intrusion from 1951 to 2008 .............................. 2-69

2-23 Landward Limit of the Saltwater Interface in 1996 and Canal Control Structures ........ 2-70

2-24 Locations of Surface-Water Monitoring Stations from SFWMD, the FPL Units 3 

and 4 Uprate Project, and NPS .................................................................................... 2-72

2-25 Locations of Groundwater Monitoring Well Clusters for the FPL Units 3 and 4 

Uprate Project .............................................................................................................. 2-74

2-26 USGS Groundwater Monitoring Locations within 6 Miles of the Proposed Plant 

Location ....................................................................................................................... 2-75

2-27 Habitat Classification at the Proposed Units 6 and 7 Plant Area ................................. 2-78

2-28 Turkey Point Site Location with Respect to Protected Areas ..................................... 2-120

2-29 Turkey Point Site Showing Onsite Aquatic Resources, Surface-Water Habitats 

and Canal Systems, and Nearshore Areas Adjacent to the Turkey Point 

Peninsula ................................................................................................................... 2-121
Figures 

NUREG–2176 xxii October 2016 

2-30 2009 Fish Sampling Locations on the Turkey Point Site ............................................ 2-124

2-31 Critical Habitat for the Florida Manatee near the Turkey Point Site ........................... 2-145

2-32 Critical Habitat for the American Crocodile near the Turkey Point Site ...................... 2-149

2-33 Locations of Crocodile Nests in the Turkey Point IWF, 1978−2010 ........................... 2-152

2-34 Location of Crocodile Nests in the Turkey Point IWF, 2011–2015 ............................. 2-153

2-35 Map of South Florida, Showing Counties Potentially Affected by Proposed Units 

6 and 7 ....................................................................................................................... 2-163

2-36 Transportation Infrastructure within the 50-Mile Radius of the Site ............................ 2-176

2-37 Highways, Streets, and Traffic Count Stations in the Vicinity of the Site ................... 2-177

2-38 Aggregate Minority Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria ............................................................................................ 2-192

2-39 Hispanic Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria ........................................................................................................ 2-193

2-40 African-American Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria ............................................................................................ 2-194

2-41 Aggregate Low-Income Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria ............................................................................................ 2-195

2-42 The Generalized Stratigraphy and Corresponding Hydrogeologic Units at the 

Turkey Point Site ........................................................................................................ 2-210

2-43 Nearest Actual and Potential Receptors .................................................................... 2-219

3-1 Location of Proposed Units 6 and 7 on the Turkey Point Site ........................................ 3-3

3-2 Conceptualization of Proposed Units 6 and 7 Superimposed on the Turkey Point 

Site ................................................................................................................................. 3-4

3-3 AP1000 Power-Conversion Diagram ............................................................................. 3-6

3-4 Site Layout for Proposed Turkey Point Units 6 and 7 and Associated Facilities ............ 3-7 

3-5 Plan View of a Typical Radial Collector Well System .................................................. 3-10 

3-6 Cross-Section View of a Typical Radial Collector Well System ................................... 3-11

3-7 Turkey Point Proposed Units 6 and 7 Layout Detail .................................................... 3-12

3-8 Cross-Section View of a Typical Injection Well Design ................................................ 3-13

4-1 Cooling-Canal Volumes Calculated by the Review Team Using Estimated 

Monthly Fluxes from the FPL Uprate Report 2012 ....................................................... 4-28

4-2 Concentrations of TKN Using Estimated Monthly Fluxes from the FPL Uprate 

Report 2012 ................................................................................................................. 4-28

4-3 Location of Muck Spoils Area within the IWF ............................................................... 4-79

4-4 Road Improvements to Maintain an Acceptable Level of Service .............................. 4-101

4-5 Total Workforce at Turkey Point Plant Units 6 and 7 ................................................. 4-105

5-1 Schematic of Hydrologic and Mass Exchange Processes Considered in 

Estimating the Effects of Drift Deposition on the IWF Cooling Canals, Model 

Lands, and Biscayne Bay ............................................................................................. 5-30

5-2 Concentrations of 1,4-Dichlorobenzene Based on Annual Average Drift Flux from 

the Cooling Towers over a 9-Year Period .................................................................... 5-31

5-3 Predicted Monthly Salt Deposition from Cooling-Tower Operation Using Makeup 

Water Only Supplied by the Radial Collector Wells. .................................................... 5-46

5-4 Exposure Pathways to Humans ................................................................................. 5-114

5-5 Exposure Pathway to Biota Other than Humans ........................................................ 5-116

5-6 Typical Injection Well for Turkey Point Units 6 and 7 ................................................. 5-117
Figures 

October 2016 xxiii NUREG–2176 

6-1 The Uranium Fuel Cycle: No-Recycle Option ................................................................ 6-5

6-2 Illustration of Truck Stop Model .................................................................................... 6-30

8-1 FPL Service Territory ..................................................................................................... 8-3

9-1 FPL Service Territory ................................................................................................... 9-36

9-2 Candidate Areas: Southern Service Territory .............................................................. 9-38

9-3 Candidate Areas: Northern Service Territory ............................................................... 9-38

9-4 Potential Site Locations ................................................................................................ 9-39

9-5 The Glades Site Region ............................................................................................... 9-45

9-6 Glades Site Footprint ................................................................................................... 9-46

9-7 Aggregate Minority Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the Glades Alternative Site .......................... 9-84

9-8 Hispanic Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the Glades Alternative Site ...................................... 9-85

9-9 African American Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the Glades Alternative Site .......................... 9-86

9-10 Low-Income Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the Glades Alternative Site ...................................... 9-87

9-11 Martin Site Region ........................................................................................................ 9-97

9-12 Martin Site Footprint ..................................................................................................... 9-98

9-13 Aggregate Minority Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the Martin Alternative Site .......................... 9-137

9-14 Hispanic Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the Martin Alternative Site ...................................... 9-138

9-15 African American Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the Martin Alternative Site .......................... 9-139

9-16 Low-Income Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the Martin Alternative Site ...................................... 9-140

9-17 Okeechobee 2 Site Region ........................................................................................ 9-149

9-18 Okeechobee 2 Site Footprint ..................................................................................... 9-150

9-19 Aggregate Minority Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the Okeechobee 2 Alternative Site ............ 9-184

9-20 Hispanic Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the Okeechobee 2 Alternative Site ........................ 9-185

9-21 African American Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the Okeechobee 2 Alternative Site ............ 9-186

9-22 Low-Income Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the Okeechobee 2 Alternative Site ........................ 9-187

9-23 St. Lucie Site Region .................................................................................................. 9-196

9-24 St. Lucie Site Footprint ............................................................................................... 9-197

9-25 Aggregate Minority Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the St. Lucie Alternative Site ...................... 9-232

9-26 Hispanic Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the St. Lucie Alternative Site .................................. 9-233 
Figures 

NUREG–2176 xxiv October 2016 

9-27 African American Populations in Block Groups that Meet the Environmental 

Justice Selection Criteria within 50 mi of the St. Lucie Alternative Site ...................... 9-234

9-28 Low-Income Populations in Block Groups that Meet the Environmental Justice 

Selection Criteria within 50 mi of the St. Lucie Alternative Site .................................. 9-235 
October 2016 xxv NUREG–2176 

TABLES 

ES-1 Environmental Impact Levels of the Proposed Turkey Point Units 6 and 7 ................. xxxv 

ES-2 Cumulative Impacts on Environmental Resources, Including the Impacts of 

Proposed Turkey Point Units 6 and 7 ......................................................................... xxxvi 

ES-3 Comparison of Cumulative Impacts at the Turkey Point and Alternative Sites .......... xxxvii 

ES-4 Summary of Environmental Impacts of Construction and Operation of New 

Nuclear, Coal-Fired, and Natural-Gas-Fired Generating Units and a Combination 

of Alternatives .................................................................................................................. xl 

2-1 Proposed Coordinates for the Units 6 and 7 Containment Buildings ............................. 2-4

2-2 Major Land-Use Acreages on the Turkey Point Site ....................................................... 2-8

2-3 Major Land-Use Acreages within the 6-Mile Vicinity ...................................................... 2-8

2-4 Existing and Proposed Transmission Line Corridors ................................................... 2-13

2-5 FLUCFCS Land-Cover Acreage within Proposed Transmission Line Corridors 

and Transmission Access Roads ................................................................................. 2-17

2-6 Regional Land Use ....................................................................................................... 2-21

2-7 Agriculture in the Region .............................................................................................. 2-23

2-8 Summary Statistics of Salinity at the Four Measurement Stations near the Turkey 

Point Site ...................................................................................................................... 2-38

2-9 The Review Team Estimates of Average and Maximum Annual Runoff under the 

Existing Condition from Sub-Basins on FPL Property at the Turkey Point Site ........... 2-41

2-10 Consumptive Use Surface-Water Permits in the Region around the Turkey Point 

Site ............................................................................................................................... 2-59

2-11 Acreage of Land-Cover Classes within the Proposed Units 6 and 7 Offsite 

Reclaimed Water Pipeline Corridor .............................................................................. 2-80

2-12 Federally Listed Species Known to Occur within Terrestrial Habitats of MiamiDade County or in the Vicinity of the Turkey Point Site................................................ 2-82

2-13 Number of Nests at Wood Stork Colonies Located near the Proposed West 

Transmission Corridors from 1992–2011 ..................................................................... 2-94

2-14 State-Listed Terrestrial or Wetland Plant Species Occurring in the Vicinity of the 

Turkey Point Site not Previously Discussed as a Federally Listed Species ................. 2-98

2-15 State-Listed Terrestrial or Wetland Animal Species Occurring in the Vicinity of the 

Turkey Point Site Not Previously Discussed as a Federally Listed Species .............. 2-104

2-16 Federally and State-Listed Terrestrial Wildlife Species Identified by the State of 

Florida as Occurring or Potentially Occurring within Transmission Line Corridors 

Associated with Proposed Units 6 and 7 .................................................................... 2-113

2-17 Federally and State-Listed Plant Species Observed within Transmission Line 

Corridors Associated with Proposed Units 6 and 7 .................................................... 2-116

2-18 Fish Species Present in Surface-Water Habitats Inclusive of the IWF on Turkey 

Point Site in Summer 2009 ........................................................................................ 2-125

2-19 Aquatic Species Documented in the Industrial Wastewater Facility........................... 2-125

2-20 Summary of Benthic Invertebrate Abundances near Turkey Point ............................ 2-127

2-21 Relative Abundance of Aquatic Species Commonly Found in Biscayne Bay for 

Given Salinity Ranges ................................................................................................ 2-130
Tables 

NUREG–2176 xxvi October 2016 

2-22 Fish Species Composing 90 Percent of the Total Catch in Card Sound during 

2008-2009 Sampling Events ...................................................................................... 2-132

2-23 Shellfish Species Composing 90 Percent of the Total Catch in Card Sound during 

2008-2009 Sampling Events ...................................................................................... 2-132

2-24 Fish Larvae Composing 90 Percent of the Total Collection in Card Sound during 

2008-2009 Sampling Events ...................................................................................... 2-133

2-25 Summary of Benthic Invertebrate Abundances near Card Sound ............................. 2-133

2-26 Fish Species that Could Occur in Open Water Habitats Associated with the 

Proposed Transmission Line Corridors in Dade County, Florida ............................... 2-135

2-27 Ecologically, Recreationally, and Commercially Important Aquatic Species Likely 

to Occur at or near the Turkey Point Site ................................................................... 2-137

2-28 Federally or State-Listed Species, Proposed Species, or Candidate Species 

Likely to Occur at or near the Turkey Point Site ......................................................... 2-143

2-29 American Crocodile Monitoring Results at the Turkey Point Site, 2000−2015 ........... 2-150

2-30 Federally or State-Listed Species of Concern Likely to Occur at or near the 

Turkey Point Site ........................................................................................................ 2-155

2-31 Designated Essential Fish Habitat Likely to Occur near the Turkey Point Site .......... 2-157

2-32 Population of Counties within 50 Miles of the Proposed Site ..................................... 2-162

2-33 Commuting Characteristics of Workers in the 50-Mile Region ................................... 2-164

2-34 Distribution of Turkey Point Plant Employees ............................................................ 2-164

2-35 Population Growth in Miami-Dade and Florida, 1970−2030 ...................................... 2-165

2-36 Resident Population in the 50-Mile Radius, Projected to 2030, by County ................ 2-166

2-37 Employment by Industry, Miami-Dade County, 2012 ................................................. 2-169

2-38 Construction and Extraction Occupation in the Miami-Miami Beach-Kendall 

Metropolitan Area, 2013 ............................................................................................. 2-170

2-39 Major Employers in Miami-Dade County, by Number of Employees, 2013 ............... 2-171

2-40 Employment and Unemployment Statistics for Miami-Dade County and Florida, 

Annual Averages ........................................................................................................ 2-171

2-41 Miami-Dade County Adopted Budget Revenues by Major Sources, 

FY 2011-2012, $Thousands ....................................................................................... 2-172

2-42 Florida Tax Revenues by Major Sources, FY 2010-2011 .......................................... 2-173

2-43 City of Homestead Adopted Budget, FY 2012 ........................................................... 2-174

2-44 Available Peak Hour Capacity at Traffic Count Stations, 2008 .................................. 2-177

2-45 Wildlife Management Areas, National Wildlife Refuges, Preserves, and State 

Parks within 50 Miles of the Turkey Point Site ........................................................... 2-179

2-46 Baseline Housing Information .................................................................................... 2-180

2-47 Major Public Water Suppliers in Miami-Dade County, 2007 ...................................... 2-181

2-48 Miami-Dade County Projected Water Demands, 2005−2025 .................................... 2-182

2-49 Wastewater-Treatment Systems in Miami-Dade County ........................................... 2-182

2-50 Law Enforcement and Fire Protection in Miami-Dade County and the Homestead 

and Florida City Area, 2010 ....................................................................................... 2-183

2-51 Medical Facilities and Personnel in Miami-Dade County, 2006 ................................. 2-185

2-52 Public School Statistics in Miami-Dade County and Homestead and Florida City ..... 2-187

2-53 Class Sizes in Miami-Dade County, 2010-2011 ......................................................... 2-187

2-54 Regional Minority and Low-Income Populations by Block Group Analysis Results ... 2-190
Tables 

October 2016 xxvii NUREG–2176 

2-55 Atmospheric Dispersion Factors for Proposed Units 6 and 7 Design Basis 

Accident Calculations ................................................................................................. 2-215

2-56 Maximum Annual Average Atmospheric Dispersion and Deposition Factors for 

Evaluation of Normal Effluents for Receptors of Interest ........................................... 2-216

2-57 Injuries and Illnesses by Industry and Area ............................................................... 2-220

2-58 Fatal Injuries by Industry in the United States ............................................................ 2-221

2-59 Waterborne Disease Outbreaks in Florida, 2002−2011 ............................................. 2-224

2-60 Construction Noise Sources and Attenuation with Distance ...................................... 2-227

3-1 Volume of Fill Needed for Turkey Point Units 6 and 7 and Associated Facilities ......... 3-16

3-2 Summary of New Transmission Lines for Proposed Turkey Point Units 6 and 7 ......... 3-18

3-3 Definitions and Examples of Activities Associated with Building Turkey Point 

Units 6 and 7 ................................................................................................................ 3-22

3-4 Summary of Parameters and Resource Commitments Associated with 

Construction and Preconstruction of Proposed Units 6 and 7 ..................................... 3-28

3-5 Expected Constituents and Concentrations Discharged to the Deep-Injection 

Wells ............................................................................................................................ 3-38

3-6 Resource Parameters Associated with Operation of Proposed Turkey Point Units 

6 and 7 ......................................................................................................................... 3-41

4-1 Summary of Proposed Disturbance on the FPL Turkey Point Site in Acres .................. 4-6

4-2 Major Land-Use Acreages along the Reclaimed Water Pipeline to the FPL 

Reclaimed Wastewater-Treatment Facility..................................................................... 4-9

4-3 Major Land-Use Acreages in Areas of the Access Road Improvement ....................... 4-10

4-4 Major Land-Use Acreages within the Proposed Transmission Line Corridors ............. 4-14

4-5 Major Land-Use Acreages within Transmission Line and Substation Access 

Corridors ...................................................................................................................... 4-16

4-6 Extent of Proposed Impacts on Cover Types at the Turkey Point Site ........................ 4-36

4-7 Permanent Habitat Loss on the FPL Turkey Point Property Attributed to Building 

Units 6 and 7 Facilities ................................................................................................. 4-37

4-8 Wetland Types that Would Be Permanently Lost During Building of Proposed 

Units 6 and 7 and the Associated Facilities on the Turkey Point Site .......................... 4-39

4-9 Summary of Undeveloped Uplands and Wetlands Found within Transmission 

Line Corridors ............................................................................................................... 4-41

4-10 Proposed Mitigation Efforts to Offset Loss of Wetland Function Related to the 

Preconstruction and Construction of Proposed Units 6 and 7 and the Building 

and Installation of Related Structures .......................................................................... 4-67

4-11 Level-of-Service Designations for Key Intersections during Peak Workforce after 

Road and Intersection Improvements ........................................................................ 4-111

4-12 Peak Workforce Traffic LOS Analysis for Truck Traffic beyond the Vicinity of the 

Site ............................................................................................................................. 4-112

4-13 Construction Impact on Police Protection in Miami-Dade County and the 

Homestead and Florida City Area .............................................................................. 4-117

4-14 Construction Impact on Fire Protection in Miami-Dade County and the 

Homestead and Florida City Area .............................................................................. 4-117

4-15 Anticipated Annual Average Atmospheric Emissions Associated with Site 

Preparation and Construction of Proposed Units 6 and 7 .......................................... 4-126
Tables 

NUREG–2176 xxviii October 2016 

4-16 Estimated Impacts of Transporting Workers and Materials to and from the Turkey 

Point Site for a Single Unit ......................................................................................... 4-136

4-17 Summary of Measures and Controls Proposed by FPL to Limit Adverse Impacts 

During Construction and Preconstruction of Proposed Units 6 and 7 ........................ 4-143

4-18 Summary of Impacts from Construction and Preconstruction of Proposed Turkey 

Point Units 6 and 7 ..................................................................................................... 4-147

5-1 Estimated Annual Average Deposition Rates from Cooling-Tower Drift ...................... 5-12

5-2 Estimated Contaminant Concentrations in the Cooling Canal from Drift 

Deposition .................................................................................................................... 5-31

5-3 Comparison of Predicted Concentrations of Chemicals from Cooling-Tower 

Deposition during Reclaimed Water Use to Analytical Method Detection Limits 

and Toxicological Criteria or Benchmarks .................................................................... 5-48

5-4 Level of Service of Key Intersections during Normal Operations of Turkey Point 

Units 6 and 7 with Selected Intersection Improvements .............................................. 5-87

5-5 Building Impact on Police Protection in Miami-Dade County and the Homestead 

and Florida City Area ................................................................................................... 5-90

5-6 Operations Impact on Fire Protection in Miami-Dade County and the Homestead 

and Florida City Area ................................................................................................... 5-91

5-7 Anticipated Atmospheric Emissions Associated with Operation of Proposed Units 

6 and 7 ......................................................................................................................... 5-98

5-8 Screening-Level Analysis of Inhalation of Selected Chemicals in Drift from 

Reclaimed Water Used for Cooling ............................................................................ 5-110

5-9 Nonradiological Estimated Impacts of Transporting Operations Workers to and 

from the Turkey Point Site and Alternative Sites ........................................................ 5-111

5-10 Gaseous Effluent Exposure Pathway Receptor Locations ......................................... 5-119

5-11 Annual Individual Doses to the MEI from Gaseous Effluents for One Unit ................ 5-120

5-12 Comparisons of the Dose Estimates from Liquid and Gaseous Effluents to 10 

CFR Part 50, Appendix I Design Objective at the Turkey Point Site Boundary ......... 5-121

5-13 Cumulative Turkey Point Site Dose to the MEI from Units 6 and 7 Combined with 

Units 3 and 4 .............................................................................................................. 5-121

5-14 FPL Estimate of Non-Human Biota Doses for Proposed Turkey Point Units 6 and 

7 for a Single Unit ....................................................................................................... 5-125

5-15 Comparison of the FPL Estimate of Biota Doses from the Proposed Turkey Point 

Units 6 and 7 to the IAEA/NRCP Guidelines for Biota Protection .............................. 5-126

5-16 Atmospheric Dispersion Factors for Turkey Point Site DBA Calculations .................. 5-135

5-17 Design Basis Accident Doses for an AP1000 Reactor for Proposed Turkey Point 

Units 6 and 7 .............................................................................................................. 5-136

5-18 Mean Environmental Risks from AP1000 Reactor Severe Accidents at the Turkey 

Point Site .................................................................................................................... 5-139

5-19 Comparison of Environmental Risks for an AP1000 Reactor at the Turkey Point 

Site with Risks for Current-Generation Reactors at Five Sites Evaluated in 

NUREG−1150 and the AP1000 at Four Early Site Permit Sites ................................ 5-140

5-20 Comparison of Environmental Risks from Severe Accidents Initiated by Internal 

Events for an AP1000 Reactor at the Turkey Point Site with Risks Initiated by 

Internal Events for Current Plants Undergoing Operating License Renewal 

Review and Environmental Risks of the AP1000 Reactor at Other Sites .................. 5-141
Tables 

October 2016 xxix NUREG–2176 

5-21 Comparison of the Turkey Point Site SAMDA Characteristics with Parameters 

Specified in Appendix 1B of the AP1000 DCD ........................................................... 5-149

5-22 Alternatives Considered for the SAMDA in the AP1000 DCD .................................... 5-149

5-23 Summary of Proposed Measures and Controls to Limit Adverse Impacts during 

Operation ................................................................................................................... 5-151

5-24 Summary of Operational Impacts for the Proposed Turkey Point Units 6 and 7 ........ 5-154

6-1 Table S–3 from 10 CFR 51.51(b), Table of Uranium Fuel-Cycle Environmental 

Data ................................................................................................................................ 6-2

6-2 Comparison of Annual Average Dose Received by an Individual from All Sources ..... 6-12

6-3 Number of Truck Shipments of Unirradiated Fuel for the Reference LWR and the 

AP1000 Reactor ........................................................................................................... 6-20

6-4 RADTRAN 5.6 Input Parameters for Unirradiated Fuel Shipments .............................. 6-21

6-5 Radiological Impacts under Normal Conditions of Transporting Unirradiated Fuel 

to the Turkey Point Site or the Alternative Sites ........................................................... 6-22

6-6 Nonradiological Impacts of Transporting Unirradiated Fuel to the Turkey Point 

Site and the Alternative Sites Normalized to Reference LWR ..................................... 6-26

6-7 Transportation Route Information for Shipments from the Turkey Point Site and 

the Alternative Sites to the Proposed Geologic Repository at Yucca Mountain, 

Nevada ......................................................................................................................... 6-28

6-8 RADTRAN 5.6 Normal Exposure Parameters ............................................................. 6-29

6-9 Normal Radiation Doses to Transport Workers and the Public from Shipping 

Spent Fuel from the Turkey Point Site and the Alternative Sites to the Proposed 

High-Level Waste Repository at Yucca Mountain ........................................................ 6-31

6-10 Radionuclide Inventories Used in Transportation Accident Risk Calculations for 

an AP1000 Reactor ...................................................................................................... 6-34

6-11 Annual Spent Fuel Transportation Accident Impacts for an AP1000 Reactor at 

the Turkey Point Site and the Alternative Sites, Normalized to Reference 1,100 

MW(e) LWR Net Electrical Generation ........................................................................ 6-36

6-12 Nonradiological Impacts of Transporting Spent Fuel from the Turkey Point Site 

and the Alternative Sites to Yucca Mountain, Normalized to Reference LWR ............. 6-36

6-13 Summary of Radioactive Waste Shipments from the Turkey Point Site and 

Alternative Sites ........................................................................................................... 6-37

6-14 Nonradiological Impacts of Radioactive Waste Shipments from the Turkey Point 

Site ............................................................................................................................... 6-38

7-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions 

Considered in the Cumulative Analysis in the Vicinity of the Turkey Point Site ............. 7-3

7-2 Comparison of Annual Carbon Dioxide Emission Rates .............................................. 7-36

7-3 Cumulative Impacts on Environmental Resources, Including the Impacts of 

Proposed Turkey Point Units 6 and 7 .......................................................................... 7-46

8-1 Shares of Electricity Sales by FPL Customer Class....................................................... 8-4

8-2 FPL Summer Reserve Margin Forecast by Case........................................................... 8-7

8-3 Forecasted Energy Consumption, Capacity, and Peak Demand ................................. 8-10

8-4 Forecasted Capacities and Reserve Margins during the Summer Peak Period .......... 8-11

9-1 Summary of Environmental Impacts of Coal-Fired Power Generation at the 

Turkey Point Site .......................................................................................................... 9-15

9-2 Summary of the Environmental Impacts of Natural-Gas−Fired Power Generation ...... 9-21
Tables 

NUREG–2176 xxx October 2016 

9-3 Summary of the Environmental Impacts of a Combination of Power Sources ............. 9-29

9-4 Summary of the Environmental Impacts of Construction and Operation of New 

Nuclear, Coal-Fired, and Natural-Gas–Fired Generating Units and a Combination 

of Alternatives .............................................................................................................. 9-31

9-5 Comparison of Carbon Dioxide Emissions for Energy Alternatives ............................. 9-32

9-6 Past, Present, and Reasonably Foreseeable Projects and Other Actions in the 

Vicinity of the Glades Alternative Site ........................................................................... 9-47

9-7 Glades Site Land-Use Impacts .................................................................................... 9-55

9-8 Federally Listed Terrestrial Species that May Occur on the Glades Site or within 

the Conceptual Transmission Line Corridor ................................................................. 9-62

9-9 Acreage within the Conceptual Footprint at the Glades Site ........................................ 9-64

9-10 Peak Workforce Traffic LOS Analysis for the Glades Site ........................................... 9-80

9-11 Past, Present, and Reasonably Foreseeable Projects and Other Actions in the 

Vicinity of Martin Site .................................................................................................... 9-99

9-12 Martin Alternative Site Land-Use Impacts .................................................................. 9-109

9-13 Federally Listed Terrestrial Species that May Occur on the Martin Site or within 

the Conceptual Transmission Line Corridor ............................................................... 9-117

9-14 Acreage within the Conceptual Footprint at the Martin Site ....................................... 9-119

9-15 Peak Workforce Traffic LOS Analysis for the Martin Site ........................................... 9-133

9-16 Past, Present, and Reasonably Foreseeable Projects and Other Actions in the 

Vicinity of the Okeechobee 2 Site .............................................................................. 9-151

9-17 Okeechobee 2 Alternative Site Land-Use Impacts .................................................... 9-159

9-18 Federally Listed Terrestrial Species that May Occur on the Okeechobee 2 Site or 

within the Conceptual Transmission Line Corridor ..................................................... 9-166

9-19 Acreage within the Conceptual Footprint at the Okeechobee 2 Site .......................... 9-167

9-20 Peak Workforce Traffic LOS Analysis for the Okeechobee 2 Site ............................. 9-180

9-21 Past, Present, and Reasonably Foreseeable Projects and Other Actions in the 

Vicinity of the St. Lucie Site ........................................................................................ 9-198

9-22 St. Lucie Alternative Site Land-Use Impacts .............................................................. 9-206

9-23 Federally Listed Terrestrial Species that May Occur on the St. Lucie Site or within 

the Conceptual Transmission Line Corridor ............................................................... 9-212

9-24 Acreage within the Conceptual Footprint at the St. Lucie Site ................................... 9-214

9-25 Essential Fish Habitat and Habitat Areas of Particular Concern Present near the 

St. Lucie Site .............................................................................................................. 9-221

9-26 Federally or State-Listed Species and Species of Concern Likely to Occur at or 

near the St. Lucie Site ................................................................................................ 9-222

9-27 Peak Workforce Traffic LOS Analysis for the St. Lucie Site ....................................... 9-229

9-28 Comparison of Cumulative Impacts at the Turkey Point and Alternative Sites .......... 9-246

10-1 Unavoidable Adverse Environmental Impacts from Construction and 

Preconstruction Activities ............................................................................................. 10-6

10-2 Unavoidable Adverse Environmental Impacts from Operation .................................. 10-10

10-3 Summary of the Benefits of the Proposed Action ...................................................... 10-19

10-4 Summary of the Costs of Preconstruction, Construction, and Operation ................... 10-21
October 2016 xxxi NUREG–2176 

EXECUTIVE SUMMARY 

This environmental impact statement (EIS) presents the results of a U.S. Nuclear Regulatory 

Commission (NRC) environmental review of an application for a combined construction permit 

and operating license (combined license or COL) for two new nuclear reactor units at a 

proposed Turkey Point site in Miami-Dade County, Florida. The U.S. Army Corps of Engineers 

(USACE) participated in the preparation of the EIS as a cooperating agency and as a member 

of the review team, which consisted of the NRC staff, its contractor staff, and the USACE staff. 

The National Park Service (NPS) participated in the environmental review as a cooperating 

agency by providing special expertise for the areas in and around the adjacent national parks 

(Biscayne and Everglades National Parks). The NPS does not have a request to take any 

specific regulatory actions related to the proposed COLs before it. Due to this unique set of 

circumstances, all impact determinations made in this EIS should not be attributed to NPS, but 

only to the NRC and USACE (also referred to as the review team). The NPS’s participation in 

connection with this EIS does not imply NPS concurrence. 

Background 

On June 30, 2009, the Florida Power & Light Company (FPL) submitted an application to the 

NRC for a combined construction permit and operating license (combined license or COL) for 

Turkey Point Units 6 and 7. 

Upon acceptance of FPL’s application, the NRC review team began the environmental review 

process by publishing a Notice of Intent to prepare an EIS and conduct scoping in the Federal 

Register on June 15, 2010. As part of this environmental review, the review team did the 

following: 

 conducted public scoping meetings on July 15, 2010 in Homestead, Florida 

 conducted a site visit of the proposed Units 6 and 7 plant area on the Turkey Point site in 

June 2010 

 conducted visits to alternative sites in July 2010 

 reviewed FPL’s Environmental Report (ER) 

 consulted with Tribal Nations and other agencies such as the U.S. Fish and Wildlife Service 

(FWS), Advisory Council on Historic Preservation, Florida Fish and Wildlife Conservation 

Commission, National Marine Fisheries Service, Miami-Dade Office of Historic and 

Archaeological Resources, and Florida Division of Historical Resources 

 conducted the review following guidance set forth in NUREG-1555: 

– “Standard Review Plans for Environmental Reviews for Nuclear Power Plants 

– Supplement 1: Operating License Renewal” 

 considered public comments received during the 60-day scoping process from June 15, 

2010 to August 16, 2010 
Executive Summary 

NUREG–2176 xxxii October 2016 

 conducted public meetings on the draft EIS on April 22, 2015, in Miami, Florida, and on April 

23, 2015, in Homestead, Florida 

 considered public comments received during the comment periods for the draft EIS, which 

extended from March 5 to May 22 and from May 28 to July 17, 2016. 

Proposed Action 

FPL initiated the proposed Federal action by submitting an application for Turkey Point Units 6 

and 7 to the NRC. The NRC’s Federal action is issuance of COLs for two Westinghouse 

AP1000 reactors at the Turkey Point site near Homestead, Florida. 

The USACE is a cooperating agency in preparation of this EIS. The USACE’s Federal action is 

its decision of whether to issue, deny, or issue with modifications a Department of Army (DA) 

permit pursuant to Section 404 of the Clean Water Act and Section 10 of the Rivers and 

Harbors Act of 1899 to authorize certain construction activities potentially affecting waters of the 

United States.(1) 

Purpose and Need for Action 

The purpose of the proposed NRC action, issuance of the COL, is to provide for additional 

baseload electric generating capacity for use in the FPL service territory. 

The USACE determines both a basic and an overall project purpose pursuant to the Clean 

Water Act Section 404(b)(1) Guidelines, 33 CFR § 230.10. The basic purpose is to meet the 

public’s need for electric energy. The overall purpose is to meet the public’s need for reliable 

increased electrical baseload generating capacity in FPL’s service territory. 

Affected Environment 

The Turkey Point site is located in southeast Miami-Dade County, Florida, near Homestead 

(Figure ES-1). Turkey Point Units 6 and 7 would be located on the same site as the existing 

Turkey Point site, which has five other power plants, including two nuclear power reactors. 

Turkey Point would be located 25 mi south of Miami and 4.5 and 8 mi east of Homestead and 

Florida City, respectively. The primary source of cooling water would be reclaimed wastewater 

and the alternative source would be saltwater supplied from radial collector wells beneath 

Biscayne Bay. The ultimate heat sink for Turkey Point Units 6 and 7 would be the atmosphere, 

using three mechanical draft cooling towers per reactor. 

 

(1) Waters of the United States” is used to include both “waters of the United States” as defined by 33 

CFR Part 328 (TN1683) defining the extent of USACE geographic jurisdiction pursuant to Section 404 

of the Clean Water Act and “navigable waters of the United States” as defined by 33 CFR Part 329 

(TN4770) defining the extent of USACE geographic jurisdiction pursuant to Section 10 of the Rivers 

and Harbors Act of 1899 (33 U.S.C. § 403) (TN4768). 
Executive Summary 

October 2016 xxxiii NUREG–2176 

Figure ES-1. The Turkey Point Site and Affected Environment
Executive Summary 

NUREG–2176 xxxiv October 2016 

Evaluation of Environmental Impacts 

This EIS evaluates the potential environmental impacts 

of the construction and operation of the two new nuclear 

plants proposed for the Turkey Point site related to the 

following resource areas: 

 land use 

 air quality 

 aquatic ecology 

 terrestrial ecology 

 surface and groundwater 

 waste (radiological and nonradiological) 

 human health (radiological and nonradiological) 

 socioeconomics 

 environmental justice 

 cultural resources 

 fuel cycle, decommissioning, and transportation 

The impacts are designated as SMALL, MODERATE, or LARGE. The incremental impacts 

related to the construction and operations activities requiring NRC authorization are described 

and characterized, as are the cumulative impacts resulting from the proposed action when the 

effects are added to, or interact with, other past, present, and reasonably foreseeable future 

effects on the same resources. A summary of the construction and operation impacts are 

outlined in Table ES-1. Table ES-2 summarizes the review team’s assessment of cumulative 

impacts. The review team’s detailed analysis which supports the impact assessment of the 

proposed new units can be found in Chapters 4, 5, and 7, respectively. 

SMALL: Environmental effects are 

not detectable or are so minor that 

they will neither destabilize nor 

noticeably alter any important 

attribute of the resource. 

MODERATE: Environmental 

effects are sufficient to alter 

noticeably, but not to destabilize, 

important attributes of the resource. 

LARGE: Environmental effects are 

clearly noticeable and are sufficient 

to destabilize important attributes of 

the resource. 
Executive Summary 

October 2016 xxxv NUREG–2176 

Table ES-1. Environmental Impact Levels of the Proposed Turkey Point Units 6 and 7 

Resource Category 

Preconstruction and 

Construction Operation 

Land Use MODERATE (NRC authorized 

construction impact level is 

SMALL) 

MODERATE 

Water-Related 

Water Use – Surface Water SMALL SMALL 

Water Use – Groundwater Use SMALL SMALL 

Water Quality – Surface Water SMALL SMALL 

Water Quality – Groundwater SMALL SMALL 

Ecology 

Terrestrial Ecosystems MODERATE (NRC authorized 

construction impact level is 

SMALL) 

MODERATE 

Aquatic Ecosystems SMALL to MODERATE SMALL 

Socioeconomic 

Physical Impacts SMALL (adverse) to 

MODERATE (beneficial) 

SMALL (adverse) to 

MODERATE (beneficial) 

Demography SMALL SMALL 

Economic Impacts on the Community SMALL SMALL and beneficial 

Infrastructure and Community Services SMALL to MODERATE SMALL to MODERATE 

Environmental Justice NONE(a) NONE(a)

Historic and Cultural Resources MODERATE (NRC authorized 

construction impact level is 

SMALL) 

SMALL 

Air Quality SMALL SMALL 

Nonradiological Health SMALL SMALL 

Nonradiological Waste SMALL SMALL 

Radiological Health SMALL SMALL 

Postulated Accidents n/a SMALL 

Fuel Cycle, Transportation, and 

Decommissioning 

n/a SMALL 

(a) A determination of “NONE” for Environmental Justice analyses does not mean there are no adverse impacts to 

minority or low-income populations from the proposed project. Instead, an indication of “NONE” means that 

while there are adverse impacts, those impacts do not affect minority or low-income populations in any 

disproportionate manner, relative to the general population. 
Executive Summary 

NUREG–2176 xxxvi October 2016 

Table ES-2. Cumulative Impacts on Environmental Resources, Including the Impacts of 

Proposed Turkey Point Units 6 and 7 

Resource Category Impact Level 

Land Use MODERATE 

Water-Related 

Water Use – Surface Water SMALL 

Water Use – Groundwater Use SMALL 

Water Quality – Surface Water MODERATE 

Water Quality – Groundwater SMALL 

Ecology 

Terrestrial Ecosystems MODERATE to LARGE 

Aquatic Ecosystems MODERATE 

Socioeconomic 

Physical Impacts SMALL adverse to MODERATE beneficial 

Demography SMALL 

Economic Impacts on the Community SMALL and beneficial 

Infrastructure and Community Services SMALL to MODERATE 

Environmental Justice NONE(a)

Historic and Cultural Resources MODERATE 

Air Quality SMALL to MODERATE for criteria pollutants and 

MODERATE for GHGs 

Nonradiological Health SMALL 

Nonradiological Waste SMALL 

Radiological Health SMALL 

Postulated Accidents SMALL 

Fuel Cycle, Transportation, and Decommissioning SMALL 

(a) A determination of “NONE” for Environmental Justice analyses does not mean there are no adverse impacts to 

minority or low-income populations from the proposed project. Instead, an indication of “NONE” means that while 

there are adverse impacts, those impacts do not affect minority or low-income populations in any 

disproportionate manner, relative to the general population.

Alternatives 

The review team considered the environmental impacts associated with alternatives to issuing a 

COL for the two new nuclear units proposed by FPL for the Turkey Point site. These 

alternatives included a no-action alternative (i.e., not issuing the COL) and alternative energy 

sources, siting locations, and system designs. 

The no-action alternative would result in the COL not being granted or the USACE not issuing 

its permit. Upon such a denial, construction and operation of new units at the Turkey Point site 

would not occur and the predicted environmental impacts would not take place. If no other 

facility would be built or strategy implemented to take its place, the benefits of the additional 

electrical capacity and electricity generation to be provided would also not occur and the need 

for baseload power would not be met. 

Based on the NRC staff’s review of energy alternatives, the NRC staff concluded that, from an 

environmental perspective, none of the viable alternatives is environmentally preferable to 

building a new baseload nuclear power generation plant at the Turkey Point site. The NRC staff 

eliminated several energy sources (e.g., wind, solar, geothermal, and biomass) from full 
Executive Summary 

October 2016 xxxvii NUREG–2176 

consideration because they are not currently capable of meeting the need of this project. None 

of the viable baseload alternatives (natural gas, coal, or a combination of alternatives) was 

environmentally preferable to the proposed Turkey Point units. 

After comparing the cumulative effects of a new nuclear power plant at the proposed site against 

those at the alternative sites, the NRC staff concluded that none of the alternative sites would be 

environmentally preferable to the proposed site for building and operating a new nuclear power 

plant (Table ES-3). The four alternatives sites selected were as follows (Figure ES-2): 

 Glades 

 Martin 

 Okeechobee 2 

 St. Lucie. 

Table ES-3. Comparison of Cumulative Impacts at the Turkey Point and Alternative Sites

Resource Category 

Turkey Point 

Site(a) Glades(b) Martin(b)

Okeechobee 

2(b) St. Lucie(b)

Land Use MODERATE MODERATE MODERATE MODERATE MODERATE 

Water-Related 

Surface-water use SMALL MODERATE MODERATE MODERATE SMALL 

Groundwater use SMALL SMALL SMALL SMALL SMALL 

Surface-water quality MODERATE MODERATE MODERATE MODERATE MODERATE 

Groundwater quality SMALL SMALL SMALL SMALL SMALL 

Ecology 

Terrestrial and 

wetland ecosystems 

MODERATE 

to LARGE 

MODERATE MODERATE MODERATE MODERATE 

Aquatic ecosystems MODERATE MODERATE MODERATE MODERATE SMALL to

MODERATE 

Socioeconomics 

Physical impacts SMALL 

adverse 

except for 

MODERATE 

beneficial 

impacts on 

road quality 

MODERATE 

adverse to 

SMALL 

beneficial 

impacts on 

road quality 

MODERATE 

adverse to 

MODERATE 

beneficial 

impacts on 

road quality 

MODERATE 

adverse to 

SMALL 

beneficial 

impacts on 

road quality 

LARGE adverse 

to MODERATE 

beneficial 

impacts on road 

quality 

Demography SMALL SMALL SMALL SMALL SMALL, except 

for LARGE 

residential 

displacement 

impacts 

Economic impacts on 

the community 

SMALL and 

beneficial 

SMALL and 

beneficial, 

except for 

LARGE and 

beneficial 

property tax 

revenues for 

Glades 

County and 

School District 

SMALL and 

beneficial, 

except for 

MODERATE 

and beneficial 

property tax 

revenues for 

Martin County 

and School 

District 

SMALL and 

beneficial, 

except for 

LARGE and 

beneficial 

property tax 

revenues for 

Okeechobee 

County and 

School District 

SMALL and 

beneficial 
Executive Summary 

NUREG–2176 xxxviii October 2016 

Table ES-3. (contd) 

Resource Category 

Turkey Point 

Site(a) Glades(b) Martin(b)

Okeechobee 

2(b) St. Lucie(b)

Infrastructure and 

community services 

SMALL except 

for 

MODERATE 

adverse 

impacts on 

traffic 

SMALL except 

for 

MODERATE 

adverse 

impacts on 

traffic 

SMALL except 

for 

MODERATE 

adverse 

impacts on 

traffic 

SMALL except 

for 

MODERATE 

adverse 

impacts on 

traffic 

SMALL except 

for 

MODERATE 

adverse 

impacts on 

traffic 

Environmental 

Justice 

None(c) None(c) None(c) None(c) None(c)

Historic and Cultural 

Resources 

MODERATE MODERATE SMALL MODERATE SMALL 

Air Quality 

Criteria pollutants SMALL to 

MODERATE 

SMALL SMALL to 

MODERATE 

SMALL to 

MODERATE 

SMALL to 

MODERATE 

Greenhouse gas 

emissions 

MODERATE MODERATE MODERATE MODERATE MODERATE 

Nonradiological 

Health 

SMALL SMALL SMALL SMALL SMALL 

Radiological Health SMALL SMALL SMALL SMALL SMALL 

Postulated 

Accidents 

SMALL SMALL SMALL SMALL SMALL 

(a) Cumulative impact determinations taken from EIS Table 7-3. 

(b) Cumulative impact determinations taken from EIS Table 9-28.

(c) A determination of “NONE” for Environmental Justice analyses does not mean there are no adverse impacts on 

minority or low-income populations from the proposed project. Instead, an indication of “NONE” means that 

while there are adverse impacts, those impacts do not affect minority or low-income populations in any 

disproportionate manner, relative to the general population. 

Table ES-3 provides a summary of the cumulative impacts for the proposed and alternative 

sites. The NRC staff concluded that all of the sites were generally comparable, and it would be 

difficult to state that one site is preferable to another from an environmental perspective. In 

such a case, the proposed site prevails because none of the alternatives is environmentally 

preferable to the proposed site. 

Table ES-4 provides a summary of the EIS-derived impacts for a new nuclear power plant in 

comparison with the energy alternatives. The NRC staff concluded that none of the viable 

energy alternatives is preferable to construction of a new baseload nuclear power-generating 

plant located within FPL’s region of interest. 

The NRC staff considered various alternative systems designs, including seven alternative heatdissipation systems and multiple alternative intake, discharge, and water-supply systems. The 

review team identified no alternatives that were environmentally preferable to the proposed 

Turkey Point Units 6 and 7 systems design. 
Executive Summary 

October 2016 xxxix NUREG–2176 

Figure ES-2. Location of Sites Considered as Alternatives to the Turkey Point Site 
Executive Summary 

NUREG–2176 xl October 2016 

Table ES-4. Summary of Environmental Impacts(a) of Construction and Operation of New 

Nuclear, Coal-Fired, and Natural-Gas–Fired Generating Units and a 

Combination of Alternatives 

Impact Category Nuclear Coal(b) Natural Gas(b)

Combination of 

Alternatives(b)

Land Use MODERATE MODERATE MODERATE MODERATE 

Air Quality SMALL MODERATE SMALL to 

MODERATE 

SMALL to 

MODERATE 

Water Use and Quality SMALL SMALL SMALL SMALL 

Ecology MODERATE MODERATE MODERATE MODERATE 

Waste Management SMALL MODERATE SMALL SMALL 

Socioeconomics MODERATE 

Beneficial to 

MODERATE 

Adverse 

MODERATE 

Beneficial to 

MODERATE 

Adverse 

MODERATE 

Beneficial to 

SMALL 

Adverse 

MODERATE 

Beneficial to 

MODERATE 

Adverse 

Human Health SMALL SMALL SMALL SMALL 

Historic and Cultural 

Resources 

MODERATE MODERATE MODERATE MODERATE 

Environmental Justice NONE(b) NONE(b) NONE(b) NONE(b)

(a) Impact levels for all alternatives are for construction and operation but do not reflect cumulative impacts. Thus, 

the nuclear impacts identified here may differ from those used to compare the proposed site to the alternative 

sites, which reflect cumulative impacts. 

(b) Impacts taken from EIS Table 9-4. These conclusions for energy alternatives should be compared to NRCauthorized activities reflected in Chapters 4, 5, and Sections 6.1, and 6.2. 

(c) A determination of “NONE” for Environmental Justice analyses does not mean there are no adverse impacts to 

minority or low-income populations from the proposed project. Instead, an indication of “NONE” means that while 

there are adverse impacts, those impacts do not affect minority or low-income populations in any 

disproportionate manner, relative to the general population.

Benefits and Costs 

The NRC staff compiled and compared the pertinent analytical conclusions reached in the EIS. 

It gathered all of the expected impacts from building and operating proposed Turkey Point Units 

6 and 7 and aggregated them into two final categories: (1) expected environmental costs and 

(2) expected benefits to be derived from approval of the proposed action. Although the analysis 

in Section 10.6 is conceptually similar to a purely economic benefit-cost analysis, which 

determines the net present dollar value of a given project, the purpose of the section is to 

identify potential societal benefits of the proposed activities and compare them to the potential 

internal (i.e., private) and external (i.e., societal) costs of the proposed activities. In general, the 

purpose is to inform the COL process by gathering and reviewing information that demonstrates 

the likelihood that the benefits of the proposed activities outweigh the aggregate costs. 

On the basis of the assessments in this EIS, the building and operation of proposed Turkey 

Point Units 6 and 7, with mitigation measures identified by the review team, would accrue 

benefits that most likely would outweigh the economic, environmental, and social costs. For the 

NRC-proposed action (i.e., NRC-authorized construction and operation), the accrued benefits 

would also outweigh the costs of preconstruction, construction, and operation of proposed 

Turkey Point Units 6 and 7. 
Executive Summary 

October 2016 xli NUREG–2176 

Public Involvement 

A 60-day scoping period was held from June 15, 2010, to August 16, 2010. On July 15, 2010, 

the NRC held two public scoping meetings in Homestead, Florida. The review team received 

many oral comments during the public meetings and 32 e-mails and 10 letters throughout the 

rest of the scoping period on numerous topics including energy alternatives, terrestrial ecology, 

ground and surface water, and socioeconomics. The review team’s response to the in-scope 

public comments can be found in Appendix D. The Scoping Summary Report (Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML103130609) contains 

all of the comments, even those considered out-of-scope (e.g., security, safety issues). 

During the initial 75-day comment period on the draft EIS, which began on March 6, 2015, the 

review team held public meetings in Miami, Florida, on April 22, 2015, and in Homestead, 

Florida, on April 23, 2015. During the course of the comment period, the NRC received 

requests from members of the public, a Tribal government, and Federal agencies to extend the 

comment period. In response to these requests, the NRC reopened the comment period on the 

draft EIS on May 28, 2015, until July 17, 2015, allowing additional time for public comments. In 

total, approximately 68 people provided oral comments at the public meetings held in April, and 

the NRC received approximately 11,300 pieces of correspondence during the original and 

reopened comment period. 

Recommendation 

The NRC’s recommendation to the Commission related to the environmental aspects of the 

proposed action is that the COL should be issued. 

This recommendation is based on the following: 

 the application, including the ER, submitted by FPL 

 consultation with Federal, State, Tribes, and local agencies 

 site audits and alternative sites audits 

 consideration of public comments received during the environmental review 

 the review team’s independent review and assessment summarized in this EIS. 

The NRC’s determination is independent of the USACE’s determination of whether to issue, 

deny, or issue with modifications the DA permit application for the Turkey Point Units 6 and 7. 

The USACE will conclude its Clean Water Act Section 404(b)(1) Guidelines and public interest 

analyses in its Record of Decision. 

October 2016 xliii NUREG–2176 

ABBREVIATIONS/ACRONYMS 

AADT annual average daily traffic 

ac acre(s) 

ACC averted cleanup and decontamination costs 

ac-ft acre (foot) feet 

ACHP Advisory Council on Historic Preservation 

ACS American Community Survey 

AD Anno Domini 

ADAMS Agencywide Documents Access and Management System 

AERMOD American Meteorological Society/U.S. Environmental Protection Agency 

(AMS/EPA) Regulatory Model 

AICUZ Air Installation Compatible Use Zone 

ALARA as low as reasonably achievable 

a.m. ante meridian 

AO Administrative Order 

AP-42 EPA’s Compilation of Air Pollutant Emission Factors document 

APE Area of Potential Effect 

APPZ Avon Park Permeable (or Producing) Zone 

AQCR Air Quality Control Region 

ARNI Aquatic Resources of National Importance 

ARRA American Recovery and Reinvestment Act of 2009 

ASE advanced safety evaluation 

ASR aquifer storage and recovery (system) 

ATC Atlantic Coastal Ridge 

BA Biological Assessment 

BACT Best Available Control Technologies 

BBCW Biscayne Bay Coastal Wetlands 

BC Before Christ 

BEBR University of Florida’s Bureau of Economic and Business Research 

BEA U.S. Bureau of Economic Analysis 

BEIR VII Biological Effects of Ionizing Radiation VII 

bgs below ground surface 

BISC Biscayne Bay 

BLS U.S. Bureau of Labor Statistics 

BMP Best Management Practice 

Btu British thermal unit 

°C degree(s) Celsius 

μCi microcurie(s) 
Abbreviations/Acronyms 

NUREG–2176 xliv October 2016 

μCi/mL microcuries per milliliter 

CA Consent Agreement 

CAA Clean Air Act 

CAIR Clean Air Interstate Rule 

CCD Colony Collapse Disorder 

CCR coal combustion residuals 

CCS cooling-canal system (also known as IWF) 

CDF core damage frequency 

CDMP Comprehensive Development Master Plan 

CDNFRM cost for decontamination of non-farmland 

CEC chemical/contaminant of emerging concern 

CEQ Council on Environmental Quality 

CERP Comprehensive Everglades Restoration Program (also Project, Plan) 

CFR Code of Federal Regulations

cfs cubic foot/feet per second 

cm centimeter(s) 

cm2 square centimeter(s) 

CO carbon monoxide 

CO2 carbon dioxide 

CO2e carbon dioxide equivalent 

COL combined construction permit and operating license 

CPI Consumer Price Index 

CPUE catch per unit effort 

CSAPR Cross-State Air Pollution Rule 

CTEMISS cooling-tower emissions processor 

CWA Clean Water Act (aka Federal Water Pollution Control Act) 

CWS circulating-water system 

CZMP Coastal Zone Management Plan 

d day(s) 

D Directional Distribution Factor 

DA Department of the Army 

dB decibel(s) 

dBA decibel(s) on the A-weighted scale 

DBA design basis accident 

DCD Design Control Document 

DEET N,N-Diethyl-meta-toluamide 

DEIS draft environmental impact statement 

DERM Miami-Dade County Department of Environmental Resources 

Management 

DHS Department of Homeland Security 
Abbreviations/Acronyms 

October 2016 xlv NUREG–2176 

DNL day-night average sound level 

DOE U.S. Department of Energy 

DOI U.S. Department of Interior 

DOT U.S. Department of Transportation 

DPS distinct population segment 

DSM demand-side management 

DZMW dual-zone monitoring well 

EAB exclusion area boundary 

EAI Ecological Associates, Inc. 

EC10 effective concentration required to induce a 10% effect 

EC50 effective concentration required to induce a 50% effect 

ECOTOX EPA Ecotoxicology 

EDR Florida Legislature’s Office of Economic and Demographic Research 

EEEA East Everglades Expansion Area 

EEL Environmentally Endangered Lands (Program) 

EFH essential fish habitat 

EIA Energy Information Administration 

EIS environmental impact statement 

EJ environmental justice 

ELF extremely low frequency 

ELF-EMF extremely low frequency-electromagnetic field 

EMB Everglades Mitigation Bank 

EMF electromagnetic field 

ENP Everglades National Park 

EPA U.S. Environmental Protection Agency 

EPOC emerging pollutant of concern 

EPRI Electric Power Research Institute 

ER Environmental Report 

ESA Endangered Species Act of 1973, as amended 

ESOC emerging substance of concern 

ESRP Environmental Standard Review Plan (NUREG-1555, Supplement 1, 

Operating License Renewal) 

EW exploratory well 

°F degree(s) Fahrenheit 

FAA Federal Aviation Administration 

FAC Florida Administrative Code or Fla. Admin. Code 

FDEP Florida Department of Environmental Protection 

FDHR Florida Division of Historic Resources 

FDOH Florida Department of Health 
Abbreviations/Acronyms 

NUREG–2176 xlvi October 2016 

FDOT Florida Department of Transportation 

FEC Florida East Coast (Railway) 

FEFP Florida Education Finance Program 

FEMA Federal Emergency Management Agency 

FERC Federal Energy Regulatory Commission 

FFWCC Florida Fish and Wildlife Conservation Commission 

FIRM Flood Insurance Rate Map 

FKNMS Florida Keys National Marine Sanctuary 

FLUCFCS Florida Land Use, Cover, and Forms Classification System 

FLUM Future Land Use Map 

FMNH Florida Museum of Natural History 

FMP fishery management plan 

FMSF Florida Master Site File (form) 

FNAI Florida Natural Areas Inventory 

FONSI Findings of No Significant Impact 

FPL Florida Power & Light Company 

fps foot (feet) per second 

FPSC Florida Public Service Commission 

FR Federal Register 

FRCC Florida Reliability Coordinating Council 

FSAR Final Safety Analysis Report 

FSER Final Safety Evaluation Report 

ft foot/feet 

ft2 square foot/feet 

ft/d foot (feet) per day 

ft2/d square foot (feet) per day 

ft3 cubic foot (feet) 

ft3/d cubic foot (feet) per day 

ft3/yr cubic foot (feet) per year 

FTE full-time equivalent 

FWPCA Federal Water Pollution Control Act (also known as the Clean Water Act 

of 1977) 

FWS U.S. Fish and Wildlife Service 

FY fiscal year 

μg microgram(s) 

μg/L microgram(s) per liter 

μGy microgray(s) 

g gram(s) or gravity of Earth (g-force) 

gal gallon(s) 

gal/yr gallon(s) per year 
Abbreviations/Acronyms 

October 2016 xlvii NUREG–2176 

GC gas centrifuge 

g/cm3 gram(s) per cubic centimeter 

GCRP U.S. Global Change Research Program 

GEIS Generic Environmental Impact Statement (for License Renewal of 

Nuclear Plants, NUREG-1437) 

GHG greenhouse gas 

GIS geographic information system 

gpd gallon per day 

gpm gallon per minute 

gpm/ft gallon(s) per minute per foot 

g/s gram(s) per second 

GU Interim District (zone) 

GW gigawatt(s) 

GWh gigawatt hour(s) 

ha hectare(s) 

HAP hazardous air pollutant 

HAPC habitat area of particular concern 

HBB health-based benchmark 

HDR HDR Engineering, Inc. 

HEC-RAS Hydrologic Engineering Centers River Analysis System 

hr hour 

HUD U.S. Department of Housing and Urban Development 

Hz hertz 

I Interstate 

IAEA International Atomic Energy Agency 

ICRP International Commission on Radiological Protection 

ID identification 

IGCC integrated gasification combined-cycle 

in. inch(es) 

IRWST in-containment refueling water storage tank 

ISFSI independent spent fuel storage installation 

IUCN World Conservation Union 

IWF industrial wastewater facility (also known as CCS) 

K Standard Peak Hour Factor 

kg kilogram(s) 

kg/d kilogram(s) per day 

kg/L kilogram(s) per liter 

kg/yr kilogram(s) per year 
Abbreviations/Acronyms 

NUREG–2176 xlviii October 2016 

kg/ha/mo kilogram(s)/hectare/month 

kHz kilohertz 

km kilometer(s) 

km2 square kilometer(s) 

km/hr kilometer(s) per hour 

kt knot(s) 

kV kilovolt(s) 

kV/m kilovolt(s) per meter 

kW kilowatt(s) 

kWh kilowatt-hour(s) 

L liter(s) 

lb pound(s) 

lb/yr pound(s) per year 

Ldn day-night average sound level 

LEDPA least environmentally damaging practicable alternative 

Leq noise level equivalent 

LFA Lower Floridan Aquifer 

LLC Limited Liability Company 

LLW low-level waste 

LOEC lowest-observed effect concentration 

LOS level of service 

LPZ low-population zone 

LST local standard time 

LWA Limited Work Authorization 

LWR light water reactor 

μmhos/cm micromhos per centimeter 

m meter(s) 

m/s meter(s) per second 

m2 square meter(s) 

m3 cubic meter(s) 

m3/d cubic meters per day 

m3/s cubic meter(s) per second 

mA milliampere(s) 

MACCS MELCOR Accident Consequence Code System 

MCU Middle Confining Unit 

MDC Miami-Dade County 

M-DCPS Miami-Dade County Public School District 

MDWASD Miami-Dade Water and Sewer Department 

MEI maximally exposed individual 
Abbreviations/Acronyms 

October 2016 xlix NUREG–2176 

mg milligram(s) 

mG milliGauss 

Mgd million gallon(s) per day 

Mgd/yr million gallon(s) per day per year 

Mgm million gallons per month 

Mg/L milligram(s) per liter 

Mg/m3 milligram(s) per cubic meter 

mg N/L milligrams of nitrate per liter 

mg P/L milligrams of phosphate per liter 

mGy milligray(s) 

mGy/d milligray(s) per day 

MFCMA Magnuson–Stevens Fishery Conservation and Management Act (or 

Magnuson–Stevens Act)

MHz megahertz 

mi mile(s) 

mi2 square mile(s) 

min minute(s) 

MIT Massachusetts Institute of Technology 

mL milliliter(s) 

MMBtu one million British thermal units 

MMBtu/hr one million British thermal units per hour 

MMBtu/yr one million British thermal units per year 

mo month(s) 

MOU Memorandum of Understanding 

mph mile(s) per hour 

mrad millirad 

mrem millirem 

msl or MSL mean sea level 

mSv millisievert(s) 

MSW municipal solid waste 

MT metric ton(nes) 

MTU metric ton uranium 

MW megawatt(s) 

MWd/MTU megawatt-days per metric ton of uranium 

MW(e) megawatt(s) electric 

MW(t) megawatt(s) thermal 

MWh megawatt hour(s) 

MWh/yr megawatt hour(s) per year 

N north or nitrogen 

NA not applicable 
Abbreviations/Acronyms 

NUREG–2176 l October 2016 

NAAQS National Ambient Air Quality Standard 

NAD83 North American Datum of 1983 

NARUC National Association of Regulatory Utility Commissioners 

NASCAR National Association for Stock Car Auto Racing 

NAVD88 North American Vertical Datum of 1988 

NCI National Cancer Institute 

NCRP National Council on Radiation Protection and Measurements 

NEPA National Environmental Policy Act of 1969, as amended 

NERC North American Electric Reliability Corporation 

NESC National Electrical Safety Code 

NFC Natural Forest Community 

NGCC natural-gas combined-cycle 

NGVD National Geodetic Vertical Datum 

NHPA National Historic Preservation Act 

NIEHS National Institute of Environmental Health Sciences 

NMFS National Marine Fisheries Service 

NNC Numerical Nutrient Criteria 

NO2 nitrogen dioxide 

NO3+NO2 nitrate+nitrite 

NOx nitrogen oxides 

NOAA National Oceanic and Atmospheric Administration 

NOEC no-observed effect concentration 

NPDES National Pollutant Discharge Elimination System 

NPS National Park Service 

NRC U.S. Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

NSR new source review 

NUREG U.S. Nuclear Regulatory Commission technical document 

NW northwest 

NWS National Weather Service 

O2 oxygen 

O3 ozone 

ODCM Offsite Dose Calculation Manual 

OFW Outstanding Florida Water 

OIG Office of the Inspector General 

ORV off-road vehicle 

OSHA Occupational Safety and Health Administration 

P phosphorus 

PAH polycyclic aromatic hydrocarbon 
Abbreviations/Acronyms 

October 2016 li NUREG–2176 

PC personal computer 

PCB polychlorinated biphenyl 

pCi/L picocurie(s) per Liter 

pH measure of acidity or basicity in solution 

PHU panther habitat units 

PHU panther habitat unit 

PFA Panther Focus Area 

P/L phosphorus per liter 

PIR Public Interest Review or Project Implementation Report 

PIRF Public Interest Review Factor 

PK-12 preschool through 12th grade 

p.m. post meridian 

PM particulate matter 

PM10 particulate matter with an aerodynamic diameter of 10 microns or less 

PM2.5 particulate matter with an aerodynamic diameter of 2.5 microns or less 

PPSA Power Plant Siting Act 

ppm part(s) per million 

ppt parts per thousand 

PRA probabilistic risk assessment 

PSA probabilistic safety assessment 

PSD Prevention of Significant Deterioration (Permit) 

psu practical salinity unit 

PWR pressurized water reactor 

rad radiation absorbed dose 

RAI Request for Additional Information 

RCRA Resource Conservation and Recovery Act of 1976, as amended

RCW radial collector well 

rem roentgen equivalent man 

REMP radiological environmental monitoring program 

RfC reference concentration 

RFI Request for Information 

RHA Rivers and Harbors Act of 1899 

RIMS II Regional Input-Output Modeling System 

RMS root mean square 

Rn-222 radon-222 

ROD Record of Decision 

ROI region of interest 

RPHP Radiation Public Health Project 

RRY reference reactor year 

RSICC (Oak Ridge) Radiation Safety Information Computational Center 
Abbreviations/Acronyms 

NUREG–2176 lii October 2016 

RV recreational vehicle 

RWTF reclaimed water-treatment facility 

Ryr reactor year 

s or sec second(s) 

SAFMC South Atlantic Fisheries Management Council 

SAMA severe accident mitigation alternative 

SAMDA severe accident mitigation design alternative 

SAV submerged aquatic vegetation 

SBO Station Blackout 

SCA Site Certification Application 

scf standard cubic feet 

SCR selective catalytic reduction 

SDWWTP South District Wastewater Treatment Plant 

sec second(s) 

SECA State Energy Conversion Alliance 

SER Safety Evaluation Report 

SFRPC South Florida Regional Planning Council 

SFWMD South Florida Water Management District 

SGWEA Southern Glades Wildlife Environmental Area 

SHA seismic hazard analysis 

SHPO State Historic Preservation Office (or Officer) 

s/m3 seconds per cubic meter 

SO2 sulfur dioxide 

SOx oxides of sulfur 

SOR Save Our Rivers (Program) 

SPCC Spill Prevention, Control, and Countermeasure (Plan) 

SR State Route 

SRP Standard Review Plan 

SSC Species of Concern 

SU Standard Unit(s) 

Sv sievert(s) 

SW southwest 

SWPPP stormwater pollution prevention plan 

SWS service-water system 

T ton(s) or tonne(s) 

T/B Tug/Barge 

TBq terrabequerel 

TCP traditional cultural property 

T&E threatened and endangered 
Abbreviations/Acronyms 

October 2016 liii NUREG–2176 

TDS total dissolved solids 

TEDE total effective dose equivalent 

THPO Tribal Historic Preservation Officer 

TIMDEC decontamination time 

TKN total Kjeldahl nitrogen 

TLD thermoluminescent dosimeter 

TLF Treasured Lands Foundation 

TN total nitrogen 

TOC total organic carbon 

TP total phosphorus 

TRC total reportable cases 

TVA Tennessee Valley Authority 

UDB urban development boundary 

UF6 uranium hexafluoride 

UIC underground injection control 

UMAM Uniform Mitigation Assessment Method 

UMTRI University of Michigan Transportation Research Institute 

UNESCO United National Educational, Scientific and Cultural Organization 

UO2 uranium dioxide 

US U.S. (State Highway) 

U.S. United States 

USACE U.S. Army Corps of Engineers 

U.S.C. United States Code 

USCB U.S. Census Bureau 

USCG U.S. Coast Guard 

USDA U.S. Department of Agriculture 

USDW underground source of drinking water 

USGS U.S. Geological Survey 

VOC volatile organic compound 

W west 

W.A.T.E.R. Wetland Assessment Technique for Environmental Review 

WCA water conservation area 

Westinghouse Westinghouse Electric Company, LLC 

WHO World Health Organization 

wk week(s) 

WOTUS waters of the United States 

WRDA Water Resources Development Act 

WTP water treatment plant 

WWTP wastewater treatment plant 
Abbreviations/Acronyms 

NUREG–2176 liv October 2016 

/Q atmospheric dispersion factor(s); annual average normalized air 

concentration value(s) 

yd3 cubic yards 

yr year(s) 
APPENDIX E 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

COMMENTS AND RESPONSES 

APPENDIX E 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

COMMENTS AND RESPONSES 

As part of the U.S. Nuclear Regulatory Commission (NRC) review of the Florida Power & Light 

Company (FPL) application for combined construction permits and operating licenses (COLs) 

for proposed Units 6 and 7 at the Turkey Point site, located in Miami-Dade County, Florida, the 

NRC and the U.S. Army Corps of Engineers (USACE) (together referred to as the “review 

team”) solicited comments from the public on the draft environmental impact statement (EIS). 

The draft EIS was issued on March 5, 2015. A 75-day comment period began on March 6, 

2015, when the U.S. Environmental Protection Agency (EPA) issued a Federal Register Notice 

of Availability (80 FR 12172) of the draft EIS to allow members of the public to comment on the 

results of the environmental review. The public comment period closed on May 22, 2015. On 

May 28, 2015, the NRC reopened the public comment period to allow more time for members of 

the public to develop and submit their comments (80 FR 30501-TN4614). The reopened 

comment period closed on July 17, 2015. 

As part of the process to solicit public comments on the draft EIS, the review team 

• placed a copy of the draft EIS at the Homestead Branch Library in Homestead, Florida and

the South Dade Regional Library in Miami, Florida;

• made the draft EIS available in the NRC’s Public Document Room in Rockville, Maryland;

• placed a copy of the draft EIS on the NRC website at http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr2176/.

• provided a copy of the draft EIS to the Turkey Point Nuclear Plant environmental review

mailing list and any member of the public who requested one;

• sent copies of the draft EIS to certain Federal, State, Tribal, and local agencies;

• published a request for comment on the draft EIS in the Federal Register on March 5, 2015

(80 FR 12043);

• filed the draft EIS with the U.S. Environmental Protection Agency; and

• held three public meetings, one on Wednesday, April 22, 2015 in Miami, Florida, and two on

Thursday, April 23, 2015 in Homestead, Florida. 

Approximately 182 people attended the public meetings in Miami, approximately 196 people 

attended the two meetings in Homestead, and numerous participants provided oral comments 

at each. A certified court reporter recorded these oral comments and prepared written 

transcripts of the meeting. The transcripts (NRC 2015-TN4553; NRC 2015-TN4554; NRC 2015-

TN4555) of the public meetings were published on August 25, 2015, as part of the public 

meeting summary. In addition to the comments received at the public meeting, the NRC 

received letters, e-mail messages, and posts to the regulations.gov site with comments 

concerning the proposed new units at the Turkey Point site. 

Appendix E October 2016 E-1 NUREG–2176
The comment letters, regulations.gov posts, e-mail messages, and transcripts of the public 

meetings are available in the NRC’s Agencywide Documents Access and Management System 

(ADAMS). ADAMS is accessible at http://www.nrc.gov/reading-rm.html. Persons who do not 

have access to ADAMS or who encounter problems in accessing the documents located in 

ADAMS should contact the NRC’s Public Document Room reference staff at 1-800-397-4209 or 

301-415-4737. The ADAMS accession numbers for the letters, regulations.gov posts, e-mail 

messages, and transcripts are provided in Table E-1. 

 Section E.1 – Disposition of Comments provides a list of commenter names and a unique 

identifier that is used throughout this appendix. 

 Section E.2 – Comments and Responses provides individual comments and the 

corresponding response by subject category. 

 Section E.3 – Form Letter Authors provides tables for each form letter received and includes 

commenter names and the ADAMS identifier. 

 Section E.4 – References provides the list of references used in this appendix. 

E.1 Disposition of Comments 

Each set of comments from a given commenter was given a unique correspondence identifier, 

allowing each set of comments from a commenter to be traced back to the transcript, letter, or 

e-mail in which the comments were submitted. After the comment period concluded, the review 

team considered and dispositioned all comments received. To identify each individual 

comment, the review team reviewed the transcripts of the public meetings and each piece of 

correspondence received related to the draft EIS. As part of the review, the review team 

identified statements that it believed were related to the proposed action and recorded the 

statements as comments. Each comment was assigned to a specific subject area, and similar 

comments were grouped together. Finally, responses were prepared for each comment or 

group of comments. 

Some comments addressed topics and issues that are not part of the environmental review for 

this proposed action. These comments included questions about NRC’s safety review, general 

statements of support or opposition to nuclear power, and comments on the NRC regulatory 

process in general. These comments are included, but detailed responses to such comments 

are not provided because they addressed issues that do not directly relate to the environmental 

effects of this proposed action and are, thus, outside the scope of the National Environmental 

Policy Act (NEPA) (42 U.S.C. § 4321 et seq.) (TN661) review of this proposed action. Many 

comments, however, specifically addressed the scope of the environmental review, analyses, 

and issues contained in the draft EIS. 

Table E-1 provides a list of commenters identified by name, affiliation (if given), comment 

number, and the source of the comment. 

Appendix E NUREG–2176 E-2 October 2016
Table E-1. Individuals Providing Comments During the Comment Period

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Abalos, Jessica reg.gov (ML15201A051) 0659 

Ackerman, Frank Email (ML15153A511) 0565 

Agler, Mindy Email (ML15141A397) 0152 

Aha, Chas reg.gov (ML15225A087) 0708 

Albers, Harold Email (ML15156A095) 0688 

Allen, Keith Email (ML15156A488) 0162 

Allen, Maureen Email (ML15141A653) 0154 

Allison, Noreen reg.gov (ML15211A039) 0549 

Almer, Anessa reg.gov (ML15225A093) 0712 

Almirola, Alejandro Email (ML15159A881) 0178 

Almirola, Alejandro Email (ML15159A948) 0178 

Almirola, Alejandro Meeting Transcript 

(ML15219A360) 

0721-31 

Alvarez, Chad reg.gov (ML15201A057) 0664 

Alvarez, Susana reg.gov (ML15104A339) 0025 

Andersen, Paul Email (ML15148B181) 0388 

Anderson, Glen Email (ML15156B027) 0321 

Anderson, Vaughn Email (ML15141A262) 0380 

Anderson, Vaughn Email (ML15162A942) 0608 

Anderson, Vaughn Email (ML15195A631) 0560 

Anonymous, Anonymous Email (ML15146A106) 0239 

Anonymous, Anonymous reg.gov (ML15096A471) 0327 

Anonymous, Anonymous reg.gov (ML15110A282) 0331 

Anonymous, Anonymous reg.gov (ML15110A284) 0333 

Anonymous, Anonymous reg.gov (ML15110A288) 0336 

Anonymous, Anonymous reg.gov (ML15128A081) 0346 

Anonymous, Anonymous reg.gov (ML15128A087) 0351 

Anonymous, Anonymous reg.gov (ML15128A091) 0354 

Anonymous, Anonymous reg.gov (ML15198A123) 0644 

Anonymous, Anonymous reg.gov (ML15198A124) 0645 

Anonymous, Anonymous reg.gov (ML15198A130) 0628 

Anonymous, Anonymous reg.gov (ML15211A041) 0551 

Anonymous, Anonymous reg.gov (ML15211A057) 0603 

Anonymous, Anonymous reg.gov (ML15225A084) 0705 

Anonymous, Anonymous reg.gov (ML15225A085) 0706 

Anonymous, Anonymous reg.gov (ML15225A092) 0711 

Anonymous, Anonymous reg.gov (ML15225A204) 0715 

Anonymous, Anonymous reg.gov (ML15225A208) 0719 

Anonymous, Charity reg.gov (ML15198A143) 0638 

Anonymous, Elena reg.gov (ML15201A055) 0662 

Anonymous, Judi reg.gov (ML15211A030) 0537 

Anonymous, Lynn Email (ML15146A153) 0161 

Aronson, Murray Email (ML15153B137) 0391 

Atler, Neal Email (ML15139A871) 0215 

Appendix E October 2016 E-3 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Austin, Stan National Park Service Email (ML15222A171) 0622 

Austin, Stan National Park Service Email (ML15272A460) 0623 

Avers, Pamela Dee Email (ML15139A692) 0090 

Bach, Lili Email (ML15139A722) 0128 

Bagwell, Wilson Knox Email (ML15156A862) 0306 

Bailey, Evelyn Email (ML15148B220) 0525 

Ball, Cheri Email (ML15190A270) 0472 

Balog, Nancy Email (ML15159B075) 0185 

Barczak, Sara Southern Alliance for Clean 

Energy 

Email (ML15146A145) 0112 

Barlow, Jeffrey Email (ML15139A974) 0218 

Barnes, Janice Email (ML15195A188) 0558 

Barnidge, Virginia reg.gov (ML15201A041) 0672 

Bastidas, Mauricio reg.gov (ML15225A115) 0720 

Batista, Carlos Letter (ML15128A183) 0685 

Baumwall, Douglas reg.gov (ML15104A332) 0329 

Bazzi, Noell Email (ML15139A609) 0047 

Bazzone, Barbara Email (ML15146A112) 0159 

Beattie, Jane Email (ML15154B523) 0417 

Beckman, Yvonne and 

Douglas 

Email (ML15139A633) 0060 

Beiriger, Mary Email (ML15162A919) 0287 

Bejarano, Antonio reg.gov (ML15104A328) 0019 

Bender, Kae Email (ML15154C263) 0441 

Bennett, Robbie Email (ML15148A890) 0265 

Benson, Mary Email (ML15139A685) 0081 

Benton-Janetta, Lori Email (ML15156B499) 0449 

Bereczki, Patricia Email (ML15153B232) 0393 

Berendsohn, Catherine Meeting Transcript 

(ML15219A410) 

0723-11 

Bernabei, Catharina Meeting Transcript 

(ML15219A360) 

0721-18 

Bernatis, Jenn Email (ML15142A340) 0520 

Berndgen, Michelle reg.gov (ML15128A451) 0361 

Bertelson, Bob Florida Power and Light Meeting Transcript 

(ML15219A410) 

0723-15 

Berzowski, Bill Meeting Transcript 

(ML15219A386) 

0722-18 

Bethune, David Meeting Transcript 

(ML15219A360) 

0721-23 

Bethune, David reg.gov (ML15128A454) 0615 

Betts, Cynthia Email (ML15155B927) 0280 

Birsh, Arthur and Joan Email (ML15139A684) 0083 

Black, Mary Beth Email (ML15141A499) 0107 

Blair, Dan Email (ML15154A284) 0485 

Blanck, Heidi Email (ML15155C231) 0397 

Bloom, Justin Suncoast Waterkeeper Email (ML15146A151) 0253 

Appendix E NUREG–2176 E-4 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Bodiford, Loretta Email (ML15156B342) 0444 

Bofill, Beatriz Email (ML15142A382) 0235 

Bofill, Beatriz Email (ML15211A034) 0235 

Boling, Steve Florida Power and Light Meeting Transcript 

(ML15219A410) 

0723-7 

Bonilla-Jones, Carmen 

Elisa 

Email (ML15142A324) 0231 

Boone, James Email (ML15155A604) 0533 

Boone, Jim Email (ML15154C045) 0436 

Borie, Edith Email (ML15156A016) 0629 

Boyce, Sheila Email (ML15139A693) 0091 

Brandariz, Anita Email (ML15148B306) 0529 

Bratcher, Suzanne Email (ML15155A332) 0498 

Bremen, Gary Email (ML15159B232) 0181 

Breslin, Tom Meeting Transcript 

(ML15219A360) 

0721-17 

Brexel, Sr., Charles Email (ML15197A051) 0592 

Brinn, Ira Email (ML15141A268) 0148 

Brito, Rosa South Dade Chamber of 

Commerce 

Meeting Transcript 

(ML15219A410) 

0723-10 

Bromage, Joan Email (ML15148B122) 0386 

Brown, Bradford reg.gov (ML15201A061) 0667 

Brown, Judith O. Email (ML15139A725) 0131 

Brown, Robert Email (ML15148B082) 0383 

Brstow, Mary Email (ML15156A021) 0497 

Brumleve, Charles Email (ML15155A420) 0502 

Bryan, David Email (ML15195A572) 0507 

Bubb, Ken Email (ML15148B039) 0462 

Buechler, Jerry reg.gov (ML15225A207) 0718 

Bump, Deborah Email (ML15148B317) 0535 

Bunker, Diane Email (ML15154B857) 0426 

Burge, Laura Email (ML15156A161) 0540 

Burns, Terry Email (ML15155B716) 0647 

Buyea, Thomas Email (ML15155A458) 0505 

Cafarelli, Cenie Email (ML15142A309) 0298 

Campbell, Cara Ecology Party of Florida Email (ML15146A151) 0253 

Campbell, Grant Email (ML15155A310) 0482 

Cardona, Alfredo reg.gov (ML15128A078) 0343 

Carlson, John Email (ML15142A378) 0158 

Carpenter, Rory Email (ML15155B705) 0694 

Casey, Sr., Robert J. Letter (ML15131A379) 0368 

Casper, Laurel Email (ML15159B553) 0202 

Castro, Alyssa Tomasi reg.gov (ML15201A059) 0665 

Caswell, Gail Email (ML15148A721) 0465 

Caswell, Susan Email (ML15154A305) 0487 

Cathey, Turner Email (ML15139A679) 0079 

Appendix E October 2016 E-5 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Causey, Charlie Florida Keys Environmental 

Fund 

Email (ML15146A151) 0253 

Cava, Daniella Levine Miami-Dade County 

Commissioner 

reg.gov (ML15155A563) 0172 

Cava, Daniella Levine Miami-Dade County 

Commissioner 

reg.gov (ML15198A121) 0172 

Cavros, George Southern Alliance for Clean 

Energy 

Email (ML15146A151) 0253 

Cavros, George Southern Alliance for Clean 

Energy 

Meeting Transcript 

(ML15219A360) 

0721-8 

Chatterton, Andrew North American Young 

Generation Nuclear 

Meeting Transcript 

(ML15219A386) 

0722-3 

Chenoweth, Mike Izaak Walton League of 

America 

Email (ML15146A151) 0253 

Chirillo, James Email (ML15155B963) 0261 

Chiszar, Benjamin J. Letter (ML15191A341) 0677 

Chrissos, H. L. Chris Email (ML15159A039) 0164 

Christie, Grazie reg.gov (ML15104A321) 0013 

Clapp, Linda Email (ML15159B286) 0028 

Clay, Cynthia Email (ML15139A986) 0219 

Cleland, Noel Letter (ML15160A314) 0207 

Cleland, Noel Sierra Club Miami Group Email (ML15175A152) 0288 

Cobb, Tanya Email (ML15153B269) 0413 

Coffey, Rotraud Email (ML15142A340) 0516 

Cohen, Howard Email (ML15155A936) 0567 

Colby, Helen Email (ML15139A717) 0124 

Colby, Helen Email (ML15146A126) 0242 

Colby, Helen Email (ML15156A120) 0733 

Colls, Ana Email (ML15139A719) 0125 

Colson, Clay G. Email (ML15162A913) 0602 

Commenters, Multiple Email (ML15139A604) 0044 

Commenters, Multiple Email (ML15139A651) 0067 

Commenters, Multiple Email (ML15139A668) 0073 

Commenters, Multiple Email (ML15139A729) 0103 

Commenters, Multiple Email (ML15140A000) 0102 

Commenters, Multiple Email (ML15140A141) 0104 

Commenters, Multiple Email (ML15141A259) 0379 

Commenters, Multiple Email (ML15146A110) 0240 

Compel, Jr., Joseph Email (ML15160A987) 0283 

Cook, Cherie Email (ML15156A492) 0163 

Cook, J. reg.gov (ML15211A051) 0577 

Cooper, Fran Letter (ML15160A311) 0204 

Cooper, Joe Email (ML15159A077) 0165 

Corda, Charles Meeting Transcript 

(ML15219A360) 

0721-25 

Corey, Sheffield Email (ML15154B767) 0424 

Cornely, Tina reg.gov (ML15198A136) 0633 

Appendix E NUREG–2176 E-6 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Corral, Oscar Email (ML15139A727) 0133 

Council, Barbara Email (ML15155A348) 0731 

Courliss, William Email (ML15153A991) 0604 

Critser, Jackie Email (ML15159A251) 0168 

Crystal, Chris reg.gov (ML15110A285) 0334 

Cullen, Sarah Email (ML15198A538) 0597 

Cummings, Frank reg.gov (ML15225A089) 0709 

Cunningham, Sue Email (ML15146A374) 0114 

Cusidor, Teresa Email (ML15139A721) 0127 

Dahlgren, Shelley Email (ML15154B983) 0434 

Daly, Meg Friends of the Underline Email (ML15139A674) 0076 

Daly, Meg Friends of the Underline Email (ML15146A151) 0253 

Daniels, Bonnie reg.gov (ML15128A076) 0341 

Darden, Colgate Email (ML15195A151) 0571 

Datz, Amy reg.gov (ML15211A046) 0621 

Dauerty, Barbara Email (ML15155C003) 0614 

Davidson, Penny Email (ML15154A414) 0493 

Davis, S. K. Email (ML15153B256) 0412 

de Armas, Maria Cristina Email (ML15139A676) 0077 

de Azevedo, Ricardo Email (ML15139A711) 0119 

Defoggi, Virginia Email (ML15148B204) 0266 

Degges, Frank Email (ML15156B481) 0447 

Delateur, Marc Email (ML15142A281) 0230 

Demaria, Karen Email (ML15155C181) 0262 

Demello, Christine Email (ML15155C024) 0180 

DeMent, David L. Email (ML15139A588) 0036 

Denninger, Frank reg.gov (ML15211A045) 0554 

Dent, William Email (ML15162A094) 0319 

Detrick, Mary Email (ML15161A649) 0317 

Deutsch, Steven reg.gov (ML15211A042) 0552 

Dickinson, Robert Email (ML15148B038) 0461 

Dietrich, Chris OMeara Email (ML15142A224) 0295 

Dimondstein, Carla Email (ML15153A491) 0564 

Dolben, Hollis reg.gov (ML15198A128) 0627 

Dorn, Kathryn Email (ML15155B897) 0693 

Dougherty, Kate Email (ML15154B076) 0394 

Douglas, Carolyn Email (ML15154A285) 0486 

Draper, Lonnie M. Email (ML15196A152) 0511 

Drevicky, John Email (ML15156A438) 0691 

Drew, Virginia Email (ML15154B284) 0399 

Dronsky, Rick Email (ML15141A234) 0142 

Dudley, Dwight Florida House of 

Representatives 

Email (ML15146A155) 0254 

Dulicai, Linda Email (ML15156A029) 0697 

Dunn, Elmo Email (ML15154B341) 0402 

DuPriest, William Robert Email (ML15139A695) 0093 

Appendix E October 2016 E-7 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Duquette, Bill Homestead Hospital Meeting Transcript 

(ML15219A386) 

0722-13 

Duran-Pinzon, Jaime Email (ML15146A131) 0243 

Durieux, P. Email (ML15158A046) 0451 

Dutton, Julene reg.gov (ML15198A145) 0640 

Dwyer, John P. Email (ML15147A217) 0264 

Dwyer, John P. reg.gov (ML15201A045) 0673 

Dwyer, Karen reg.gov (ML15141A398) 0674 

Dwyer, Karen reg.gov (ML15201A048) 0674 

Earnshaw, Shinann Email (ML15155C194) 0326 

Eastman, John Meeting Transcript 

(ML15219A360) 

0721-24 

Eckert, Brenda Email (ML15154B325) 0400 

Edmond, Gabriel South Miami Meeting Transcript 

(ML15219A360) 

0721-7 

Edwards, Suzi reg.gov (ML15211A056) 0600 

Egan, June Email (ML15156A312) 0690 

Ehrenfried, Jennifer reg.gov (ML15211A033) 0544 

Ehrmann, Nancy Email (ML15158A154) 0454 

Elton, Wallace Email (ML15160A802) 0229 

Enfield, David Email (ML15142A383) 0236 

Engelberg, Jodi reg.gov (ML15082A283) 0004 

England, Margaret Hendry-Glades Audubon Email (ML15146A151) 0253 

England, Peter Meeting Transcript 

(ML15219A386) 

0722-10 

Ercole, Steven Email (ML15159A445) 0170 

Ericson, Del Email (ML15142A256) 0320 

Erven, Marlene Email (ML15161A618) 0314 

F****SH, Peter reg.gov (ML15211A037) 0547 

Faber, Davenie reg.gov (ML15082A285) 0006 

Fairchild, David Email (ML15139A696) 0094 

Family, Manzi Email (ML15198A509) 0593 

Farnsworth, Stu Email (ML15148A586) 0464 

Fass, Amy Email (ML15160A803) 0278 

Fay, Virginia M. NOAA-Habitat Conservation 

Division 

Email (ML15272A530) 0724 

Fecteau, Lynn Email (ML15161A617) 0313 

Felinski, Julee reg.gov (ML15198A126) 0625 

Fernandez, Maria 

Cristina 

Email (ML15139A647) 0064 

Ferro, Colleen Email (ML15146A231) 0260 

Ferry, Lisa reg.gov (ML15198A129) 0704 

Field, Fran Email (ML15146A228) 0258 

Fielding, Ed Martin County Board of 

Commissioners 

Email (ML15142A379) 0232 

Finver, Jody Email (ML15085A500) 0008 

Fischer, Antoinette reg.gov (ML15128A513) 0365 

Appendix E NUREG–2176 E-8 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Fishman, Zelma Email (ML15154B087) 0395 

Fitzpatrick, Deirdre Email (ML15139A940) 0217 

Fitzpatrick, Deirdre Email (ML15148B206) 0389 

Forbes, J. Email (ML15159B307) 0189 

Foster, Beverly Email (ML15154B337) 0401 

Fox, Kristi Email (ML15195A187) 0506 

Franzmann, Paul Email (ML15156A298) 0384 

Fray, Antje Email (ML15155B775) 0648 

Frederickson, Kelly Email (ML15155B676) 0188 

Freel, Susan Email (ML15159A079) 0166 

Fuentes, Mariana Email (ML15195A156) 0574 

Fulks, Anna Louise Email (ML15146A141) 0250 

Fuller, Manley Florida Wildlife Federation Email (ML15146A151) 0253 

G., Ambriel reg.gov (ML15211A050) 0561 

Galbreath, Jerry Email (ML15146A368) 0489 

Galles, Camilla reg.gov (ML15198A125) 0624 

Garcia, Alda S. Email (ML15146A128) 0524 

Garcia, Javier Pipefitters, Local 725 Meeting Transcript 

(ML15219A360) 

0721-20 

Garcia, Ruslan Email (ML15139A705) 0116 

Garey, Jenne Email (ML15142A273) 0668 

Garmon, Toni Email (ML15154A221) 0477 

Gavel, Deborah Email (ML15139A700) 0098 

Geary, Craig W. Email (ML15139A699) 0097 

Geiger, Marcia Email (ML15156A978) 0312 

Ghosh, Susan Email (ML15198A526) 0595 

Gibson, David Email (ML15162A490) 0324 

Glass, Rachel Email (ML15159B572) 0222 

Glasshof, Wendy Email (ML15155B196) 0587 

Glynn, Simon Email (ML15146A143) 0111 

Goldberg, Laura Email (ML15155B050) 0568 

Goldman, Emanuel Email (ML15141A401) 0153 

Goldmeier, Barry reg.gov (ML15104A324) 0015 

Goldstein, Louis Email (ML15154B561) 0418 

Gomez, Albert Meeting Transcript 

(ML15219A360) 

0721-34 

Gomez, Christian Email (ML15154A757) 0269 

Gomez, Gustavo Email (ML15139A703) 0101 

Gomez, Lissett Email (ML15139A549) 0030 

Gomez, Toni Thoman Email (ML15155A442) 0504 

Gonzalez, Carlos reg.gov (ML15225A096) 0714 

Gonzalez, Javier Meeting Transcript 

(ML15219A386) 

0722-8 

Govindasamy, Rani Email (ML15146A137) 0247 

Graffagnino, Mary Ann 

and Frank 

Email (ML15154B434) 0403 

Appendix E October 2016 E-9 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Grant, Randy Email (ML15141A258) 0146 

Greenwald, Ken Email (ML15155C084) 0385 

Greer, Tom Email (ML15153B174) 0392 

Gregory, Gregory B. Email (ML15154A125) 0728 

Griffith, Ed and Harriet New Progressive Alliance reg.gov (ML15128A514) 0366 

Grill, Brock Email (ML15142A340) 0512 

Grill, Helen Email (ML15139A596) 0043 

Griswold, Dave reg.gov (ML15198A134) 0631 

Gross, Cheryl A. Email (ML15148A486) 0463 

Gross, Gary reg.gov (ML15104A326) 0017 

Guy, Sharon reg.gov (ML15201A043) 0654 

H., Pat reg.gov (ML15211A040) 0550 

Haber, Matthew S. City of Miami Email (ML15201A460) 0611 

Haber, Rochelle Email (ML15146A132) 0244 

Haffmans, Edmund reg.gov (ML15138A086) 0371 

Hall, Linnea M. Fronce 

Thomas 

Email (ML15160A853) 0279 

Halligan, Melody Email (ML15154A377) 0491 

Hamilton, Brent reg.gov (ML15082A281) 0002 

Hamilton, McHenry Letter (ML15160A312) 0205 

Hanna, Jane Email (ML15155B346) 0588 

Hansen, Yvonne Email (ML15154C148) 0439 

Harden, Ronald Email (ML15159B465) 0195 

Hardie, Daniel Email (ML15153A409) 0562 

Hardin, Lillian Email (ML15158A172) 0455 

Harper, Diane Email (ML15153A722) 0583 

Harris, Walter South Miami Meeting Transcript 

(ML15219A360) 

0721-6 

Harrison, J. M. M. Email (ML15195A715) 0508 

Harrison, Norma J. F. Email (ML15155B823) 0649 

Hart, Barbara Email (ML15162B091) 0196 

Hart, Barbara Email (ML15162B154) 0196 

Hartmann, Donald reg.gov (ML15201A049) 0657 

Haselhurst, Richard reg.gov (ML15198A144) 0639 

Hawkes, Holly Forrester Email (ML15139A552) 0031 

Hayes, Linda Email (ML15156A712) 0275 

Hazard, Evan Email (ML15153B288) 0415 

Headley, Linda reg.gov (ML15138A091) 0376 

Hefty, Lee N. Miami-Dade County Division of 

Environmental Resources 

Management 

Email (ML15146A118) 0110 

Heiney, Jamie reg.gov (ML15225A095) 0713 

Henry, Jim Meeting Transcript 

(ML15219A410) 

0723-12 

Herrera, Luis Vizcaya Road Association Meeting Transcript 

(ML15219A360) 

0721-33 

Hickey, Alan reg.gov (ML15201A042) 0653 

Appendix E NUREG–2176 E-10 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Hicklin, Mary Email (ML15154B949) 0431 

Hilderbrandt, Todd Email (ML15155B158) 0585 

Hill, Michael Email (ML15156B468) 0446 

Hodie, Jake Email (ML15159B366) 0191 

Hoegler, Jean Email (ML15154C117) 0438 

Hoffmeyer, Lisa reg.gov (ML15211A036) 0546 

Hogle, Dick Email (ML15142A185) 0293 

Holland, Karen reg.gov (ML15211A044) 0059 

Hollister, David Email (ML15162A494) 0325 

Horiwitz, Laura Email (ML15155A379) 0732 

Houghton, Francis Email (ML15159B565) 0735 

Howell, Carol Email (ML15142A216) 0294 

Hoyle, Lester and Judy Email (ML15154C229) 0440 

Hubbard, Stanley S. Email (ML15139A707) 0680 

Hubler, Gina Marie Email (ML15139A691) 0089 

Hubler, Gina Marie Email (ML15139A697) 0095 

Hudak, Jill Email (ML15139A591) 0038 

Hudak, Jill Meeting Transcript 

(ML15219A386) 

0722-19 

Hudson, Harold J. Email (ML15139A701) 0099 

Hughes, David reg.gov (ML15138A092) 0377 

Hull, Meagan reg.gov (ML15128A079) 0344 

Hunt, Jim Email (ML15160A978) 0311 

Hurley, Paula reg.gov (ML15128A452) 0362 

Hyams, Charles Email (ML15139A710) 0213 

Hyden, Brent A. Department of the Air Force Letter (ML15198A132) 0670 

Icaza, Alejo Email (ML15134A013) 0613 

Imbesi, Nan Email (ML15139A631) 0058 

Infante, Jose Renee Redland Market Village Meeting Transcript

(ML15219A386) 

0722-12 

Inguanzo, Maria Email (ML15154A756) 0268 

Jackalone, Frank National Sierra Club Email (ML15175A152) 0288 

Jackson, Donald L. Email (ML15162A859) 0286 

Jacobs, Lee Letter (ML15191A341) 0677 

Jacobs, Lee Letter (ML15191A341) 0679 

Jacobs, Leslye reg.gov (ML15198A137) 0634 

Jennings, Cara Email (ML15162A489) 0323 

Jens-Rochow, Steve reg.gov (ML15201A060) 0666 

Jezierski, Elisabeth Email (ML15156A651) 0302 

Jimenz, Lawrence Email (ML15156A646) 0301 

Joannou, Jr., Benjamin Email (ML15139A949) 0643 

Joannou, Jr., Benjamin reg.gov (ML15104A334) 0023 

Johannsen, Christian Email (ML15139A605) 0045 

Johnson, Diane Email (ML15196A475) 0590 

Johnson, Kay Email (ML15161A638) 0315 

Johnson, Nadine Email (ML15084A178) 0007 

Appendix E October 2016 E-11 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Johnson, Rheta Email (ML15148B048) 0696 

Johnson, Robert Email (ML15159B352) 0190 

Johnston, Judy Email (ML15156A529) 0734 

Jones, Diane Email (ML15139A724) 0130 

Jones, Gary Email (ML15156B302) 0443 

Jones, George L. Ocean Research and 

Conservation Association, Inc. 

Email (ML15146A151) 0253 

Jones, Joan and Robert Email (ML15141A267) 0147 

Jones, Michael E. Email (ML15139A682) 0082 

Juras, Randy Email (ML15154B691) 0419 

Jurczewski, Carol Email (ML15147A727) 0490 

Jurin, Richard Email (ML15141A538) 0108 

K., Jeff reg.gov (ML15110A286) 0335 

Kadis, Patricia Email (ML15146A138) 0248 

Karlow, Edwin Email (ML15160A657) 0226 

Karsten, Annetta Email (ML15158A072) 0452 

Kasenow, Lisa Email (ML15139A621) 0054 

Kasenow, Lisa Email (ML15159B532) 0200 

Kassel, Kerul reg.gov (ML15128A093) 0676 

Kaul, Devika University of Miami Meeting Transcript 

(ML15219A386) 

0722-14 

Kavanaugh, Daniel Letter (ML15124A025) 0338 

Kaye, Jackie Email (ML15162A588) 0407 

Keating, Tim reg.gov (ML15211A035) 0545 

Keaton, Rebecca Email (ML15155A438) 0503 

Keim, Mary Email (ML15142A340) 0517 

Keller, Alan Audoban of the Western 

Everglades 

Email (ML15146A151) 0253 

Kern, Madeleine Fisher Email (ML15153B247) 0411 

Khajeh-Noori, Jeri Email (ML15162A951) 0609 

Khajeh-Noori, Jeri Email (ML15196A128) 0381 

Kimball, Larry Email (ML15148B248) 0526 

Kipnis, Dan Email (ML15139A655) 0702 

Kipnis, Dan Email (ML15139A656) 0703 

Kipnis, Dan Email (ML15272A488) 0725 

Kipnis, Dan Email (ML15272A504) 0702 

Kipnis, Dan Meeting Transcript 

(ML15219A386) 

0722-2 

Kirschbaum, Saran Email (ML15148A753) 0466 

Klopfer, Carol Letter (ML15191A341) 0677 

Klopfer, Carol Letter (ML15191A341) 0678 

Knowles, Yvonne Homestead Main Street 

Program 

Meeting Transcript 

(ML15219A386) 

0722-11 

Koenigsberg, Linda Meeting Transcript 

(ML15219A360) 

0721-26 

Konczal, Eddie Email (ML15159A373) 0169 

Kowalski, Kathleen S. Email (ML15139A612) 0049 

Appendix E NUREG–2176 E-12 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Kristy, Joseph Email (ML15155B886) 0650 

Kuraza, Devon Florida Power and Light Meeting Transcript 

(ML15219A360) 

0721-15 

Lague, Victoria Email (ML15139A644) 0061 

Lamb, Deborah S. Email (ML15139A661) 0070 

Lane, N. Jo Email (ML15155B103) 0569 

Lange, Alexandra Email (ML15139A689) 0087 

Lange, Alexandra Email (ML15139A690) 0088 

Lange, Barbara Email (ML15197A046) 0591 

Langlieb Greer, Evelyn Email (ML15196A148) 0510 

Larrabee, Laura Email (ML15139A587) 0035 

Larsen, Paul reg.gov (ML15082A284) 0005 

Larsen, Shannon Email (ML15146A148) 0160 

Larsen, Shannon Email (ML15146A156) 0255 

Larsen, Shannon Email (ML15146A156) 0610 

Larsen, Shannon Email (ML15146A159) 0255 

Lawrence, Diane Email (ML15139A688) 0086 

Lawrence, Theresa reg.gov (ML15211A054) 0580 

Lawson, Ken Email (ML15160A577) 0225 

Le Cronier, Micki reg.gov (ML15201A039) 0652 

Lebatard, David Email (ML15159B388) 0192 

Ledbetter, Carolyn Email (ML15156B255) 0406 

Lee, Nancy reg.gov (ML15138A088) 0373 

Leibowitz, Arthuir Email (ML15154B449) 0404 

Lenz, Andrew Email (ML15154A104) 0470 

Leo, Carlos Email (ML15154B902) 0428 

Lerner, Cindy Village of Pinecrest Email (ML15141A257) 0145 

Lerner, Cindy Village of Pinecrest Email (ML15160A320) 0145 

Lerner, Cindy Village of Pinecrest Mayor Email (ML15146A155) 0254 

Lerner, Cindy Village of Pinecrest Mayor Meeting Transcript 

(ML15219A360) 

0721-3 

Lettieri, Tammy Email (ML15146A230) 0259 

Lettieri, Tammy Email (ML15195A570) 0559 

Levy, Morgan I. Email (ML15139A738) 0136 

Liesche, Ken Email (ML15154A338) 0488 

Lindsey, Jerrie Email (ML15146A133) 0245 

Lish, Christopher reg.gov (ML15211A047) 0555 

Livingston, C. J. Email (ML15154C069) 0437 

Livingston, Catherine reg.gov (ML15138A089) 0374 

LoBiondo, Roana and 

Michael 

reg.gov (ML15128A203) 0359 

Logan, Brian Email (ML15139A666) 0072 

Lopez, Jaclyn Center for Biological Diversity Email (ML15146A150) 0113 

Lopez, Josie Email (ML15162A389) 0284 

Lucas, Carmen Email (ML15141A232) 0141 

Lucero, Olga Email (ML15139A728) 0134 

Appendix E October 2016 E-13 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Lucero, Olga Email (ML15161A393) 0134 

Lucero, Olga Email (ML15162A855) 0134 

Lundholm, Mark Email (ML15156A896) 0309 

Macher, Nathan reg.gov (ML15139A021) 0378 

Macraith, Bonnie Email (ML15142A031) 0186 

Macy, Michelle Email (ML15156B180) 0405 

Maher, William Florida Power and Light Email (ML15202A054) 0619 

Mahoney, Robert S. reg.gov (ML15128A512) 0364 

Mahoney, Stephen Sierra Club Miami Group Email (ML15175A152) 0288 

Maida, Cecilia Email (ML15156B400) 0445 

Malefatto, Alfred Lewis, Longman and Walker Letter (ML15160A318) 0211 

Malone, Peggy Email (ML15156A131) 0539 

Malpass, Betsy Email (ML15154B739) 0421 

Malyon, Hilary Email (ML15155B974) 0669 

Manter, Larry Email (ML15155A026) 0471 

Manuel, Becky Randel Email (ML15139A739) 0137 

Martin, Allan University of Florida Meeting Transcript 

(ML15219A386) 

0722-6 

Martin, Drew reg.gov (ML15198A119) 0641 

Martin, Drew Loxahatchee Group of the 

Sierra Club 

Meeting Transcript 

(ML15219A360) 

0721-13 

Martin, Drew Sierra Club, Loxahatchee Group Email (ML15146A151) 0253 

Martin, Patrick Nuclear Matters Meeting Transcript 

(ML15219A360) 

0721-21 

Martinez, Orlando A. Email (ML15195A148) 0570 

Massa, Arturo reg.gov (ML15104A327) 0018 

Massey, Linda Email (ML15142A340) 0514 

Matheny, Kent Email (ML15158A087) 0453 

Matthews, Debbie Sierra Club Florida Email (ML15175A152) 0288 

Mauri, Tom Email (ML15139A726) 0132 

Mayer, Doug Email (ML15139A723) 0129 

Mayer, Karen Email (ML15155A110) 0475 

Mayotte, Monica Email (ML15159B458) 0194 

Mazzarella, Rebecca Email (ML15142A007) 0495 

Mazzuca, Rich Email (ML15153A798) 0584 

McCall, Eric Email (ML15139A624) 0056 

McCarthy, Dawn reg.gov (ML15104A338) 0330 

McColgan, Robert Meeting Transcript 

(ML15219A386) 

0722-15 

Mccroskey, Carol Email (ML15154A835) 0530 

McDaniel, Diana Email (ML15159B554) 0203 

McDuffie, Stephen Meeting Transcript 

(ML15219A410) 

0723-8 

Mcintyre, Frances Email 

(ML15195A152ML) 

0572 

Mckee, Sarah Email (ML15154A386) 0492 

McLaughlin, Caroline National Parks Conservation Email (ML15146A151) 0253 

Appendix E NUREG–2176 E-14 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Assocation 

McLaughlin, Caroline National Parks Conservation 

Assocation 

Meeting Transcript 

(ML15219A360) 

0721-9 

McLaughlin, Caroline National Parks Conservation 

Assocation 

Meeting Transcript 

(ML15219A410) 

0723-4 

McLaughlin, Caroline National Parks Conservation 

Association 

Email (ML15146A150) 0113 

McVicker, Micah Email (ML15159A875) 0177 

Melby, George M. Email (ML15154B109) 0396 

Mendelsohn, Alex Email (ML15158A082) 0277 

Mendez, Victoria Miami's Attorney's Office Meeting Transcript

(ML15219A360) 

0721-5 

Merino, Miriam Email (ML15139A694) 0092 

Merleaux, Derek reg.gov (ML15128A077) 0342 

Metje, Melodie Email (ML15153B020) 0606 

Meyer, Paul Email (ML15139A715) 0122 

Meyer-Steele, Shawn Email (ML15166A031) 0187 

Miami, City City of Miami Email (ML15146A122) 0456 

Mikan, Edward Email (ML15148B348) 0536 

Mikowski, George Email (ML15142A377) 0382 

Miller, Howard R. Email (ML15139A740) 0138 

Miller, Melissa Email (ML15162A670) 0285 

Miller, Nena Email (ML15156A282) 0689 

Miller, Nyana reg.gov (ML15198A127) 0626 

Mitzkewich, Yuri reg.gov (ML15211A029) 0523 

Moll, Wolfgang reg.gov (ML15198A135) 0632 

Monfort, Brooke Email (ML15154A183) 0476 

Montalvo, Stephanie reg.gov (ML15198A133) 0630 

Moo, Patrick University of Florida American 

Nuclear Society Student Section 

Meeting Transcript 

(ML15219A386) 

0722-4 

Moore, Linda Email (ML15159B529) 0199 

Morgan, Carol Email (ML15155C150) 0387 

Morgan, Karen Email (ML15141A687) 0155 

Morrisse, Christine Email (ML15148A138) 0483 

Morton, Sean Florida Keys National Marine 

Sanctuary 

Email (ML15245A496) 0618 

Mosca-Clark, Vivianne Email (ML15154C278) 0442 

Mosher, Paul Email (ML15146A139) 0249 

Mueller, Bradley M. Seminole Tribe of Florida Tribal 

Historic Preservation Office, AhTah-Thi-Ki Museum 

Email (ML15289A368) 0727 

Mueller, Heinz J. U.S. Environmental Protection 

Agency 

Email (ML15216A357) 0617 

Mulet, Tomas Email (ML15139A716) 0123 

Mundhenk, Norm Email (ML15153B015) 0605 

Murphy, Mike Meeting Transcript 

(ML15219A410) 

0723-6 

Appendix E October 2016 E-15 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Myers, B. J. Email (ML15156B026) 0256 

Nagel, Karen Email (ML15148B250) 0527 

Nappe, Judith Email (ML15155B785) 0695 

Neal, Kevin Email (ML15139A536) 0027 

Neff, Victoria Email (ML15155C228) 0682 

Nelson, Joyce E. Email (ML15141A269) 0149 

Nelson, Wendy Email (ML15154A040) 0468 

Neway, Roberta Email (ML15139A628) 0057 

Newman, Donna Email (ML15141A737) 0156 

Nickerson, Nancy Email (ML15155B708) 0692 

Nieto, Victor reg.gov (ML15225A206) 0717 

Norman, Ronald Letter (ML15128A197) 0358 

Nye, Janet Email (ML15160A887) 0281 

O'Brien, Lance Email (ML15139A548) 0029 

O'Donahoo, Gayle Email (ML15156A031) 0698 

O'Donahoo, Roger Email (ML15156A031) 0698 

O'Meara, Patrick Email (ML15195A644) 0700 

Odierna, Cynthia reg.gov (ML15211A031) 0542 

Oliva, Vivian reg.gov (ML15128A085) 0349 

Olson, Diane Email (ML15154B971) 0432 

Oria, Jordan Email (ML15159A531) 0171 

Oria, Jordan Email (ML15159A532) 0171 

Ortiz, Natalia reg.gov (ML15082A282) 0003 

Ortiz, Natalia reg.gov (ML15138A087) 0372 

Orzechowicz, Holly Email (ML15147A207) 0263 

Osborne, Martin Email (ML15139A939) 0216 

Otis, Martha Email (ML15141A274) 0150 

Otto, Peter Email (ML15196A089) 0509 

Padilla, Dora Email (ML15146A104) 0238 

Padron-Delgado, Blanca Email (ML15146A225) 0257 

Palmer, Majorie reg.gov (ML15128A450) 0360 

Pareto, Rolando and 

Marlene 

Email (ML15139A593) 0040 

Parker, Richard Email (ML15161A645) 0316 

Parsons, Timothy A. Florida Department of State Email (ML15139A741) 0139 

Passmore, Judith Email (ML15153B129) 0390 

Pattison, Janet Email (ML15155B629) 0646 

Pearce, J. B. Email (ML15155A219) 0479 

Perez, Danica Email (ML15159B073) 0184 

Peterman, Andy Email (ML15156A013) 0274 

Peters, Emily reg.gov (ML15128A453) 0363 

Petersen, John reg.gov (ML15128A083) 0347 

Peterson, Ted Email (ML15154B759) 0423 

Pew, Don Email (ML15154A680) 0500 

Pheil, Edward reg.gov (ML15225A086) 0707 

Philips, Sally B. reg.gov (ML15110A296) 0337 

Appendix E NUREG–2176 E-16 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Phillips, Monica D. Email (ML15139A686) 0084 

Pikus, Barbara Email (ML15156A935) 0303 

Pinto, Theresa Email (ML15195A041) 0499 

Piper, Cynthia Email (ML15159B028) 0183 

Platt, David Email (ML15141A604) 0109 

Platt, George Seth reg.gov (ML15225A091) 0710 

Poese, David Email (ML15156A861) 0305 

Polifroni, Josephine Email (ML15159A957) 0182 

Polk, J. D. reg.gov (ML15133A099) 0369 

Polk, James Email (ML15148B008) 0458 

Pontier, Christine Hughes Email (ML15139A720) 0126 

Poole, Diane Email (ML15148A951) 0457 

Poolos, Hazel Email (ML15153A938) 0726 

Portela, Ana C. Email (ML15188A202) 0409 

Porter, Jeff City of Homestead Meeting Transcript 

(ML15219A386) 

0722-1 

Portuondo, Pilar Email (ML15146A114) 0241 

Post, Patrick reg.gov (ML15198A146) 0671 

Provost, Allan reg.gov (ML15128A074) 0339 

Provost, Allan reg.gov (ML15198A118) 0339 

Prugue, Jorge and 

Paloma 

Email (ML15139A657) 0068 

Puchades, Mary Email (ML15181A349) 0616 

Punnett, Daniela reg.gov (ML15211A043) 0553 

Purcell, Douglas Email (ML15154B901) 0427 

Purdy, Shyam and 

Mohini 

Email (ML15142A380) 0233 

Quarles, Greyson Email (ML15139A687) 0085 

Quillen, Carter Email (ML15201A466) 0601 

Quinn, George Email (ML15148A881) 0410 

Raab, Frances Email (ML15154A991) 0532 

Rader, D.L. Email (ML15154B205) 0729 

Raits, Eric Email (ML15139A645) 0062 

Ramankutty, Vishnu reg.gov (ML15211A052) 0578 

Ramsey, Betty Email (ML15153A419) 0563 

Rapuano, Shannon Email (ML15198A522) 0594 

Rawlins, Steve reg.gov (ML15198A120) 0642 

Read, Alice Gray reg.gov (ML15104A333) 0022 

Reed, Jennifer Email (ML15154A658) 0496 

Regalado, Tomas City of Miami Mayor Email (ML15146A155) 0254 

Regalado, Tomas City of Miami Mayor Meeting Transcript 

(ML15219A360) 

0721-4 

Regalado, Tomas Mayor of the City of Miami Email (ML15146A122) 0515 

Regalado, Tomas Mayor of the City of Miami Email (ML15201A460) 0515 

Reid, Sarah Email (ML15159B539) 0201 

Reiter, Ben Email (ML15139A680) 0080 

Appendix E October 2016 E-17 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Rennie, Edwyna Email (ML15160A054) 0224 

Revord, Michael Email (ML15154B712) 0420 

Reyneri, Juan Email (ML15139A713) 0121 

Reynolds, Laura Tropical Audubon Society Email (ML15146A150) 0113 

Reynolds, Laura Tropical Audubon Society Email (ML15146A151) 0253 

Reynolds, Laura Tropical Audubon Society Meeting Transcript 

(ML15219A360) 

0721-10 

Rhodes, Karen Email (ML15140A049) 0140 

Riccio, Jim Greenpeace reg.gov (ML15225A205) 0716 

Richards, Margie Email (ML15156A134) 0450 

Richardson, Don Email (ML15142A227) 0296 

Rifkind, David Meeting Transcript 

(ML15219A360) 

0721-16 

Riley, Bill International Brotherhood of 

Electrical Workers, Local Union 

349 

Meeting Transcript 

(ML15219A360) 

0721-19 

Riley, Bill International Brotherhood of 

Electrical Workers, Local Union 

349 

Meeting Transcript 

(ML15219A386) 

0722-9 

Riley, Bill International Brotherhood of 

Electrical Workers, Local Union 

349 

Meeting Transcript 

(ML15219A410) 

0723-14 

Ritz, David Ocean Reef Community 

Association 

Email (ML15160A315) 0208 

Robbin, Valerie Email (ML15160A050) 0223 

Roberts, Kenneth Email (ML15195A161) 0575 

Roberts, Linda Email (ML15139A698) 0096 

Robertson, Alyce Email (ML15139A706) 0117 

Robinson, Angel Email (ML15155A118) 0474 

Rock, Andrew Email (ML15198A542) 0599 

Rodriguez, Barbara Email (ML15139A560) 0034 

Rodriguez, Jose Javier State of Florida Meeting Transcript 

(ML15219A360) 

0721-1 

Rodriguez, Jose Javier State of Florida reg.gov (ML15201A063) 0675 

Rodriguez, Manuel J. RoadTech Engineering Meeting Transcript 

(ML15219A360) 

0721-27 

Roedel, Kitty Email (ML15139A622) 0055 

Roehl, Richard Ralph Email (ML15142A340) 0513 

Roff, Rhonda Sierra Club Calusa Group Email (ML15175A152) 0288 

Roff, Rhonda Sierra Club Calusa Group Meeting Transcript 

(ML15219A360) 

0721-11 

Roos, Monica Email (ML15139A617) 0052 

Roque, Julio reg.gov (ML15096A472) 0328 

Roque, Julio reg.gov (ML15104A336) 0024 

Rose, Aaron Email (ML15156A887) 0307 

Rose, Simon Email (ML15085A501) 0009 

Roseberry, Bill Email (ML15159A882) 0179 

Appendix E NUREG–2176 E-18 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Rosenberry, Casara reg.gov (ML15128A515) 0367 

Rosenfeld, Alice Email (ML15155A909) 0566 

Ross, Robert and Teresa Email (ML15139A709) 0212 

Ross, Sherwood reg.gov (ML15110A283) 0332 

Rossin, A. David reg.gov (ML15128A080) 0345 

Rothstein, Debbie Email (ML15142A158) 0292 

Routh, Jeffrey Email (ML15142A340) 0522 

Rowe, James reg.gov (ML15104A318) 0011 

Royce, M. reg.gov (ML15128A090) 0353 

Rush, Charlene Email (ML15156B496) 0448 

Ryan, Jim reg.gov (ML15211A032) 0543 

Sachs, Jean Email (ML15155B254) 0686 

Salatino, Freda Email (ML15148B144) 0299 

Samole, Sharon Email (ML15142A381) 0234 

San Pedro, Patricia Email (ML15139A531) 0026 

Sanchez, Sergio and 

Irma 

reg.gov (ML15201A052) 0660 

Sanfilippo, Val reg.gov (ML15198A140) 0636 

Saporito, Thomas Saprodani Associates reg.gov (ML15096A473) 0010 

Sasiadek, Alfred Email (ML15139A620) 0053 

Scherr, Matthew Email (ML15128A183) 0684 

Schilling, Judy Email (ML15154B916) 0429 

Schlackman, Mara Meeting Transcript 

(ML15219A360) 

0721-32 

Schoene, William Email (ML15159B279) 0037 

Schwab, Roy reg.gov (ML15211A053) 0579 

Schwaller, Greg Email (ML15159A156) 0167 

Schwartz, Matthew South Florida Wetlands 

Association 

Email (ML15146A150) 0113 

Schwartz, Matthew South Florida Wetlands 

Association 

Meeting Transcript 

(ML15219A360) 

0721-22 

Schwartz, Matthew South Florida Wetlands 

Association 

Meeting Transcript 

(ML15219A410) 

0723-9 

Scott, John Sierra Club Calusa Group Email (ML15175A152) 0288 

Scott, Ruth reg.gov (ML15211A038) 0548 

Segal-Wright, Nicholas reg.gov (ML15201A054) 0661 

Segor, Joseph C. Meeting Transcript 

(ML15219A386) 

0722-16 

Seiman, Rhonda reg.gov (ML15198A138) 0635 

September, P. J. Email (ML15155B871) 0267 

Shahsavar, Mehran reg.gov (ML15104A319) 0012 

Shapiro, Eugene reg.gov (ML15128A095) 0357 

Shark, Jason Email (ML15139A712) 0120 

Sharp, Andrea Heuson Letter (ML15160A317) 0210 

Shasky, Mike reg.gov (ML15128A086) 0350 

Shelley, Cynthia reg.gov (ML15211A049) 0556 

Shepard, J. Email (ML15141A253) 0143 

Appendix E October 2016 E-19 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Shepherd, James Email (ML15155A092) 0473 

Sheridan, Michelle Email (ML15159A863) 0176 

Shifflett, Jr., James E. Email (ML15156A090) 0687 

Shipe, Kathleen Email (ML15159B428) 0193 

Shlackman, Jed reg.gov (ML15128A094) 0356 

Shlackman, Mara Email (ML15146A134) 0246 

Sifko, Basilio Email (ML15188A199) 0408 

Silva, Nicolas University of Florida Meeting Transcript 

(ML15219A386) 

0722-5 

Silver, William reg.gov (ML15104A330) 0021 

Silverstein, Rachel Miami Water Keeper Email (ML15146A150) 0113 

Silverstein, Rachel Miami Water Keeper Meeting Transcript 

(ML15219A386) 

0722-7 

Silverstein, Rachel Miami Waterkeeper Email (ML15146A151) 0253 

Simmerman, Scott Email (ML15158A216) 0480 

Simon, Gary P. Email (ML15139A613) 0050 

Simpson, Chris International Brotherhood of 

Electrical Workers 

Meeting Transcript 

(ML15219A410) 

0723-13 

Skove, Ellen H. Email (ML15139A681) 0081 

Slaton, Marina Email (ML15154A967) 0531 

Slonim, Roberta reg.gov (ML15104A325) 0016 

Smay, Betty Email (ML15139A646) 0063 

Smith, David W. Email (ML15139A616) 0051 

Smith, Leigh Emerson Email (ML15162A432) 0322 

Smith, Leigh Emerson reg.gov (ML15104A329) 0020 

Smith, Pamela Email (ML15155A184) 0730 

Smoller, Merry Sue reg.gov (ML15141A254) 0637 

Smoller, Merry Sue reg.gov (ML15198A142) 0637 

Smyke, Pete Email (ML15148B026) 0459 

Smythe, Ana Email (ML15155A878) 0557 

Socie, Robert Email (ML15142A340) 0521 

Sockloff, Judith Email (ML15162A906) 0175 

Sommers, Andrea Email (ML15154A758) 0270 

Sophia, Tristan Email (ML15142A063) 0221 

Sorenson, Katy Email (ML15198A528) 0596 

Southern, Tom reg.gov (ML15110A287) 0620 

Speno, Charlie Email (ML15148A180) 0484 

Spigel, Sue Email (ML15139B000) 0220 

Stamps, Gail Email (ML15155B183) 0586 

Standley, Ron Email (ML15153B272) 0414 

Stanko, Janet L. Sierra Club, Northeast Florida Email (ML15141A319) 0151 

Stanley, Gael Email (ML15139A664) 0071 

Stanley, Joyce U.S. Department of the Interior Email (ML15294A379) 0227 

Star, Priscilla Meeting Transcript 

(ML15219A410) 

0723-3 

Stevens, Lisa Email (ML15156A898) 0310 

Appendix E NUREG–2176 E-20 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Stewart, Berkeley Email (ML15155A990) 0273 

Stocker, Nancy Email (ML15162B105) 0699 

Stoddard, Philip K. City of South Miami Email (ML15141A255) 0106 

Stoddard, Philip K. City of South Miami Mayor Email (ML15146A155) 0254 

Stoddard, Philip K. City of South Miami Mayor Meeting Transcript 

(ML15219A360) 

0721-2 

Streit, Christopher V. Email (ML15139A672) 0075 

Streit, Didi Email (ML15139A669) 0074 

Strouble, Jackie Email (ML15156B019) 0297 

Suda, Maryska Email (ML15155A659) 0534 

Svensson, Bo Email (ML15154A242) 0478 

Swensen, Harry Email (ML15159A731) 0174 

Swenson, Cyndee Meeting Transcript 

(ML15219A386) 

0722-17 

Szabo, Liz Email (ML15155A298) 0481 

Szabo, Liz Email (ML15155B617) 0481 

Tacher, Ian Email (ML15082A132) 0001 

Tamargo, Jorge J. Email (ML15154A542) 0494 

Tamburr, C. reg.gov (ML15201A046) 0655 

Tambussi-Brechon, Linda Email (ML15139A595) 0042 

Taylor, Kirk Email (ML15155B906) 0276 

Teas, James reg.gov (ML15138A085) 0612 

Teas, Jim Sierra Club Miami Group Email (ML15175A152) 0288 

Teas, Jim Sierra Club Miami Group Meeting Transcript 

(ML15219A410) 

0723-5 

Teasley, Regi Email (ML15162A061) 0318 

Thiel, Markus Email (ML15139A737) 0135 

Thomas, Bill reg.gov (ML15128A092) 0355 

Thomas, Gina Email (ML15154A993) 0271 

Thompson, Muhammad Email (ML15156A270) 0683 

Timberlake, Ralph Email (ML15160A889) 0282 

Tingle, Peggy reg.gov (ML15128A089) 0352 

Togati, Joanne Email (ML15142A340) 0519 

Tokunaga, Barb Email (ML15156A445) 0198 

Tompkins, Constance Email (ML15139A683) 0081 

Tosney, Kathryn Email (ML15153A911) 0173 

Trauner, Keith Email (ML15195A153) 0573 

Trencher, Ruth Email (ML15139A704) 0115 

Trowbridge, Mark Coral Gables Chamber of 

Commerce 

Meeting Transcript 

(ML15219A410) 

0723-2 

Tucker, Lauren Email (ML15141A224) 0105 

Tulenko, James reg.gov (ML15138A090) 0375 

Turner, William P. reg.gov (ML15201A056) 0663 

Tweedy, Mary Email (ML15211A055) 0581 

Tweeton, Tanya reg.gov (ML15128A075) 0340 

Ullman, John Miami Group of the Sierra Club Meeting Transcript 0721-30 

Appendix E October 2016 E-21 NUREG–2176
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

(ML15219A360) 

Ullman, Jonathan National Sierra Club Email (ML15175A152) 0288 

Umpierre, Diana Email (ML15160A316) 0209 

Umpierre, Diana Email (ML15162A271) 0209 

Underwood, John Email (ML15154B521) 0416 

Van Leer, Sam Urban Paradise Guild Email (ML15146A147) 0252 

Van Pelt, Jason Email (ML15153A518) 0300 

Van Thienen, Mateo Email (ML15139A557) 0033 

Vance, Richard Email (ML15142A131) 0289 

Vayu, Satya reg.gov (ML15138A084) 0370 

Veijalainen, Pertti Email (ML15148A825) 0467 

Veit, Eberhard Email (ML15153B029) 0607 

Vermeulen, Mary Email (ML15154B979) 0433 

Vinciguerra, Anthony Email (ML15139A556) 0032 

Violich, Francesca Email (ML15139A592) 0039 

Vorachek, Mary Email (ML15142A152) 0291 

Wade, Pat Email (ML15153A704) 0582 

Wade, Thomas M. Email (ML15139A607) 0046 

Wallace, Otis Florida City Meeting Transcript 

(ML15219A410) 

0723-1 

Wallington, Victoria Email (ML15156A892) 0308 

Ward, Richard reg.gov (ML15128A084) 0348 

Warzalla, Jim Email (ML15155B847) 0144 

Wasilewski, Joe Natural Selections Meeting Transcript 

(ML15219A360) 

0721-14 

Watson, Fran Email (ML15148B273) 0528 

Weber, Gae Email (ML15142A006) 0157 

Weber, Zorina Email (ML15154A103) 0469 

Wegner, Geri Email (ML15139A611) 0048 

Weiss, Arwen Email (ML15142A340) 0518 

Welber, Michael Email (ML15142A385) 0237 

West, Eric Email (ML15154C041) 0435 

Westaway, Katharine reg.gov (ML15104A323) 0014 

White, Barry Citizens Allied for Safe Energy, 

Inc. 

Email (ML15139A702) 0100 

White, Barry J. CASE Email (ML15198A539) 0598 

White, Barry J. CASE Meeting Transcript 

(ML15219A360) 

0721-12 

White, Holly Letter (ML15160A313) 0206 

White, Paton Audubon Society of the 

Everglades 

Email (ML15146A151) 0253 

Whitehorn, C. Email (ML15154A318) 0681 

Whitfield, Isabelle Email (ML15146A146) 0251 

Whitlock, Catherine Email (ML15218A210) 0701 

Wicht, Dan Email (ML15156A578) 0197 

Wilansky, Laura Sue Email (ML15139A678) 0078 

Appendix E NUREG–2176 E-22 October 2016
Table E-1. (contd)

Commenter Affiliation (if stated)

Comment Source and 

ADAMS Accession #

Correspondence 

ID

Wilansky, Laura Sue Meeting Transcript 

(ML15219A360) 

0721-28 

Willett, Bett reg.gov (ML15201A050) 0658 

Willett, Greg Email (ML15148B363) 0538 

Williams, Elinor Loxahatchee National Wildlife 

Refuge 

Email (ML15146A151) 0253 

Williams, Paul Email (ML15139A594) 0041 

Williams, Paul Email (ML15139A659) 0069 

Williams, Penelope Email (ML15196A067) 0576 

Wilson, J. D. Bruce Email (ML15139A648) 0065 

Wingerd, Mala Email (ML15154B820) 0425 

Winters, Gracie Email (ML15154B133) 0398 

Wong, Christina Email (ML15139A649) 0066 

Wry, Ellen Email (ML15142A132) 0290 

Yarter, E. C. Email (ML15148B034) 0460 

Yeager, Jerry Email (ML15160A733) 0228 

Yost, Gaylord Email (ML15154B918) 0430 

Young, Kim Email (ML15155B916) 0651 

Yount, Madeline Email (ML15154B744) 0422 

Yovel, Ephrat Meeting Transcript 

(ML15219A360) 

0721-29 

Zakon, Allan Email (ML15139A708) 0118 

Zarsky, Terry Email (ML15153B098) 0541 

Zerulla, Tanja Email (ML15139A714) 0214 

Zhivelev, Leon reg.gov (ML15201A047) 0656 

Zimmermann, John Email (ML15154A715) 0501 

Zimmermann, John Email (ML15156A789) 0304 

Zook, Caryl Email (ML15196A256) 0589 

Zuniga, Family Email (ML15154B094) 0272 

Table E-2 provides an alphabetical index to the comment categories and lists the 

commentersand the specific comment identification number(s) that were included in each 

category 

Appendix E October 2016 E-23 NUREG–2176
Table E-2. Comment Categories 

Comment Category Commenter (Comment ID) 

Accidents-Severe  Allison, Noreen (0549-2)

 Almer, Anessa (0712-1)

 Almirola, Alejandro (0178-2)

 Anonymous, Anonymous (0331-2) (0333-4) (0551-3) (0603-7) (0644-2)

 Anonymous, Charity (0638-1)

 Bach, Lili (0128-2)

 Baumwall, Douglas (0329-3)

 Bazzone, Barbara (0159-4)

 Bender, Kae (0441-1)

 Benson, Mary (0081-2)

 Benton-Janetta, Lori (0449-1)

 Bethune, David (0615-2-17) (0615-2-26) (0615-3-8) (0721-23-5) (0721-23-

7) (0721-23-8)

 Betts, Cynthia (0280-1)

 Burge, Laura (0540-1)

 Burns, Terry (0647-1)

 Carpenter, Rory (0694-5)

 Caswell, Susan (0487-1)

 Chrissos, H. L. Chris (0164-1)

 Commenters, Multiple (0044-2) (0067-2) (0067-3) (0240-8)

 Corda, Charles (0721-25-1)

 Corral, Oscar (0133-4)

 Council, Barbara (0731-1)

 Denninger, Frank (0554-1)

 Draper, Lonnie M. (0511-4)

 DuPriest, William Robert (0093-2)

 Dwyer, John P. (0673-3)

 Enfield, David (0236-2)

 Felinski, Julee (0625-3)

 Finver, Jody (0008-6) (0008-10)

 Fulks, Anna Louise (0250-1) (0250-4)

 Geary, Craig W. (0097-3)

 Glass, Rachel (0222-1)

 Guy, Sharon (0654-4)

 Haber, Matthew S. (0611-14)

 Haffmans, Edmund (0371-2)

 Hall, Linnea M. Fronce Thomas (0279-1)

 Hardin, Lillian (0455-1)

 Haselhurst, Richard (0639-2)

 Hoyle, Lester and Judy (0440-2)

 Hull, Meagan (0344-2)

 Hyams, Charles (0213-2)

 Joannou, Jr., Benjamin (0643-1)

 Jones, Diane (0130-3)

 Jurin, Richard (0108-1)

 Kavanaugh, Daniel (0338-1)

 Koenigsberg, Linda (0721-26-2)

 Lague, Victoria (0061-2)

Appendix E NUREG–2176 E-24 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

Accidents-Severe 

(contd) 

 Lange, Alexandra (0087-3) 

 Lee, Nancy (0373-6) (0373-9) 

 Lettieri, Tammy (0259-1) 

 LoBiondo, Roana and Michael (0359-2) 

 Lucero, Olga (0134-1) 

 Maher, William (0619-1-4) 

 Mauri, Tom (0132-1) 

 Mayer, Doug (0129-1) 

 Mazzarella, Rebecca (0495-3) 

 McColgan, Robert (0722-15-2) 

 Mckee, Sarah (0492-3) 

 Mendez, Victoria (0721-5-1) 

 Merleaux, Derek (0342-2) 

 Meyer, Paul (0122-3) 

 Miami, City (0456-18) (0456-19) 

 Mikowski, George (0382-2) 

 Nappe, Judith (0695-3) 

 Nelson, Joyce E. (0149-8) 

 Neway, Roberta (0057-3) (0057-4) 

 Nickerson, Nancy (0692-1) 

 Norman, Ronald (0358-3) 

 Orzechowicz, Holly (0263-1) 

 Palmer, Majorie (0360-4) 

 Platt, David (0109-2) 

 Polk, James (0458-1) 

 Provost, Allan (0339-1) 

 Rader, D.L. (0729-1) 

 Read, Alice Gray (0022-2) 

 Reid, Sarah (0201-1) 

 Riccio, Jim (0716-9) (0716-10) 

 Rifkind, David (0721-16-1) 

 Roehl, Richard Ralph (0513-1) 

 Roff, Rhonda (0721-11-9) 

 Roque, Julio (0024-1) 

 Ross, Sherwood (0332-1) 

 Schwartz, Matthew (0721-22-10) 

 Scott, Ruth (0548-2) 

 Shlackman, Mara (0246-2) 

 Skove, Ellen H. (0081-2) 

 Smyke, Pete (0459-2) 

 Stanko, Janet L. (0151-1) 

 Stocker, Nancy (0699-1) 

 Swensen, Harry (0174-1) 

 Taylor, Kirk (0276-1) 

 Tompkins, Constance (0081-2) 

 Trauner, Keith (0573-2) 

 Trencher, Ruth (0115-7) 

 Tweeton, Tanya (0340-8) (0340-9) 

 Van Leer, Sam (0252-2) (0252-10) (0252-11) 

Appendix E October 2016 E-25 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Violich, Francesca (0039-2) 

 White, Holly (0206-2) 

 Wilansky, Laura Sue (0078-1) (0078-10) (0721-28-2) (0721-28-10) 

 Yarter, E. C. (0460-1) 

 Young, Kim (0651-4) 

 Zarsky, Terry (0541-2) 

Alternatives-Energy  Agler, Mindy (0152-1) 

 Almer, Anessa (0712-2) 

 Almirola, Alejandro (0178-5) (0721-31-5) (0721-31-10) (0721-31-12) 

(0721-31-14) 

 Anderson, Vaughn (0608-1) 

 Anonymous, Anonymous (0706-1) (0715-3) 

 Anonymous, Charity (0638-2) 

 Anonymous, Elena (0662-2) 

 Anonymous, Judi (0537-6) 

 Atler, Neal (0215-1) 

 Bach, Lili (0128-3) 

 Bailey, Evelyn (0525-1) 

 Ball, Cheri (0472-2) 

 Balog, Nancy (0185-2) 

 Barlow, Jeffrey (0218-1) 

 Barnes, Janice (0558-2) 

 Bastidas, Mauricio (0720-2) 

 Batista, Carlos (0685-1) 

 Baumwall, Douglas (0329-4) 

 Bazzone, Barbara (0159-6) 

 Bender, Kae (0441-2) 

 Bennett, Robbie (0265-2) 

 Bernabei, Catharina (0721-18-3) (0721-18-4) 

 Bethune, David (0615-1-3) (0615-1-14) 

 Bonilla-Jones, Carmen Elisa (0231-2) (0231-4) 

 Brexel, Sr., Charles (0592-2) (0592-3) (0592-5) (0592-6) (0592-7) 

 Brown, Judith O. (0131-2) 

 Buechler, Jerry (0718-2) 

 Cavros, George (0721-8-3) (0721-8-5) (0721-8-7) (0721-8-9) 

 Chiszar, Benjamin J. (0677-5) 

 Clay, Cynthia (0219-1) 

 Cleland, Noel (0207-3) (0288-10) (0288-13) (0288-16) 

 Colby, Helen (0124-2) (0242-1) 

 Colls, Ana (0125-2) 

 Colson, Clay G. (0602-2) 

 Commenters, Multiple (0044-8) (0073-2) (0104-3) (0240-13) (0379-5) 

 Compel, Jr., Joseph (0283-3) (0283-5) (0283-6) 

 Cornely, Tina (0633-3) 

 Crystal, Chris (0334-5) 

 Cunningham, Sue (0114-3) 

 Daly, Meg (0076-6) 

 Datz, Amy (0621-3) 

 de Armas, Maria Cristina (0077-2) 

Appendix E NUREG–2176 E-26 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 de Azevedo, Ricardo (0119-2) 

 DeMent, David L. (0036-1) 

 Detrick, Mary (0317-1) 

 Deutsch, Steven (0552-2) 

 Dimondstein, Carla (0564-3) 

 Dolben, Hollis (0627-1) 

 Duran-Pinzon, Jaime (0243-3) (0243-5) 

 Dwyer, John P. (0264-6) (0673-6) 

 Dwyer, Karen (0674-7) 

 Eckert, Brenda (0400-2) 

 Edmond, Gabriel (0721-7-7) 

 Edwards, Suzi (0600-2) 

 Ehrenfried, Jennifer (0544-2) 

 Engelberg, Jodi (0004-2) 

 Ercole, Steven (0170-2) 

 Fairchild, David (0094-2) (0094-6) 

 Family, Manzi (0593-1) 

 Fecteau, Lynn (0313-1) 

 Felinski, Julee (0625-4) 

 Ferro, Colleen (0260-1) 

 Ferry, Lisa (0704-2) 

 Finver, Jody (0008-13) 

 Fischer, Antoinette (0365-9) 

 Fulks, Anna Louise (0250-5) (0250-7) 

 Galles, Camilla (0624-4) 

 Garcia, Ruslan (0116-2) 

 Geary, Craig W. (0097-2) 

 Goldman, Emanuel (0153-4) 

 Goldmeier, Barry (0015-15) 

 Gomez, Albert (0721-34-2) (0721-34-5) 

 Gomez, Christian (0269-2) 

 Gomez, Gustavo (0101-2) 

 Grant, Randy (0146-5) (0146-6) 

 Grill, Helen (0043-2) 

 Gross, Cheryl A. (0463-8) 

 Haber, Matthew S. (0611-16) 

 Haffmans, Edmund (0371-5) 

 Hardin, Lillian (0455-3) 

 Hartmann, Donald (0657-1) 

 Haselhurst, Richard (0639-4) 

 Heiney, Jamie (0713-3) 

 Henry, Jim (0723-12-5) (0723-12-6) (0723-12-7) 

 Herrera, Luis (0721-33-4) 

 Hickey, Alan (0653-2) 

 Hill, Michael (0446-1) 

 Hollister, David (0325-1) 

 Howell, Carol (0294-1) 

 Hubler, Gina Marie (0089-2) 

 Hull, Meagan (0344-1) 

Appendix E October 2016 E-27 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Hunt, Jim (0311-1) 

 Hurley, Paula (0362-5) 

 Hyams, Charles (0213-4) 

 Icaza, Alejo (0613-2) 

 Imbesi, Nan (0058-2) 

 Inguanzo, Maria (0268-1) 

 Jackalone, Frank (0288-10) (0288-13) (0288-16) 

 Jacobs, Lee (0677-5) 

 Jennings, Cara (0323-4) 

 Jens-Rochow, Steve (0666-3) 

 Jezierski, Elisabeth (0302-1) 

 Joannou, Jr., Benjamin (0023-2) 

 Johnson, Diane (0590-1) 

 Johnson, Kay (0315-1) 

 Johnson, Robert (0190-1) 

 Kadis, Patricia (0248-1) 

 Keim, Mary (0517-1) 

 Khajeh-Noori, Jeri (0381-1) (0609-2) 

 Klopfer, Carol (0677-5) 

 Kristy, Joseph (0650-1) 

 Kuraza, Devon (0721-15-2) (0721-15-4) (0721-15-7) 

 Lamb, Deborah S. (0070-2) (0070-4) 

 Lange, Alexandra (0087-5) (0088-1) (0088-3) (0088-6) 

 Lange, Barbara (0591-1) 

 Lebatard, David (0192-3) 

 Lee, Nancy (0373-7) 

 Lettieri, Tammy (0259-5) 

 Levy, Morgan I. (0136-3) (0136-4) 

 LoBiondo, Roana and Michael (0359-4) 

 Lucas, Carmen (0141-2) 

 Macher, Nathan (0378-2) (0378-7) 

 Maher, William (0619-1-7) 

 Mahoney, Stephen (0288-10) (0288-13) (0288-16) 

 Maida, Cecilia (0445-1) 

 Martin, Drew (0641-9) 

 Massey, Linda (0514-1) 

 Matthews, Debbie (0288-10) (0288-13) (0288-16) 

 Mayer, Doug (0129-4) 

 Mayotte, Monica (0194-2) 

 Mazzarella, Rebecca (0495-2) 

 Merino, Miriam (0092-3) 

 Merleaux, Derek (0342-3) 

 Miami, City (0456-23) 

 Mitzkewich, Yuri (0523-2) 

 Moll, Wolfgang (0632-1) 

 Montalvo, Stephanie (0630-1) 

 Mosca-Clark, Vivianne (0442-2) 

 Mosher, Paul (0249-3) 

 Mueller, Heinz J. (0617-4-12) 

Appendix E NUREG–2176 E-28 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Myers, B. J. (0256-2) 

 Neal, Kevin (0027-1) 

 Nelson, Joyce E. (0149-6) 

 Neway, Roberta (0057-6) 

 O'Meara, Patrick (0700-1) 

 Ortiz, Natalia (0003-2) (0372-3) 

 Orzechowicz, Holly (0263-5) 

 Otis, Martha (0150-2) (0150-3) 

 Padilla, Dora (0238-2) 

 Passmore, Judith (0390-1) 

 Peters, Emily (0363-2) 

 Philips, Sally B. (0337-6) 

 Phillips, Monica D. (0084-2) 

 Piper, Cynthia (0183-2) 

 Platt, George Seth (0710-4) 

 Polk, J. D. (0369-2) 

 Portuondo, Pilar (0241-2) 

 Post, Patrick (0671-1-3) (0671-2-1) (0671-2-3) 

 Puchades, Mary (0616-2) 

 Quillen, Carter (0601-1) 

 Raab, Frances (0532-1) 

 Ramsey, Betty (0563-1) 

 Rapuano, Shannon (0594-5) 

 Rawlins, Steve (0642-3) 

 Read, Alice Gray (0022-1) (0022-6) 

 Regalado, Tomas (0515-4) 

 Reiter, Ben (0080-3) 

 Reyneri, Juan (0121-2) 

 Reynolds, Laura (0721-10-3) 

 Richards, Margie (0450-1) 

 Rifkind, David (0721-16-2) (0721-16-3) (0721-16-4) (0721-16-6)

 Roberts, Linda (0096-3) 

 Rodriguez, Barbara (0034-2) (0034-4) 

 Rodriguez, Jose Javier (0675-3) (0721-1-10) 

 Roedel, Kitty (0055-4) 

 Roff, Rhonda (0288-10) (0288-13) (0288-16) (0721-11-4) (0721-11-8) 

 Roos, Monica (0052-2) 

 Rose, Simon (0009-4) 

 Ross, Robert and Teresa (0212-4) 

 Ross, Sherwood (0332-2) 

 Ryan, Jim (0543-2) 

 San Pedro, Patricia (0026-1) 

 Sanchez, Sergio and Irma (0660-2) 

 Saporito, Thomas (0010-5) (0010-6) 

 Sasiadek, Alfred (0053-3) (0053-5) 

 Schlackman, Mara (0721-32-1) 

 Schoene, William (0037-2) 

 Schwab, Roy (0579-2) (0579-5) 

 Schwartz, Matthew (0721-22-18) (0723-9-2) (0723-9-3) (0723-9-5) (0723-

Appendix E October 2016 E-29 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

9-20) 

 Scott, John (0288-10) (0288-13) (0288-16) 

 Scott, Ruth (0548-3) 

 Segal-Wright, Nicholas (0661-2) 

 Seiman, Rhonda (0635-5) 

 Shahsavar, Mehran (0012-2) 

 Shapiro, Eugene (0357-2) 

 Shepherd, James (0473-1) 

 Shlackman, Jed (0356-4) (0356-16) 

 Silver, William (0021-2) 

 Smay, Betty (0063-2) 

 Smith, David W. (0051-3) 

 Smith, Leigh Emerson (0020-2) (0322-1) 

 Sorenson, Katy (0596-2) (0596-4) 

 Speno, Charlie (0484-2) 

 Star, Priscilla (0723-3-3) (0723-3-5) 

 Szabo, Liz (0481-3) 

 Teas, Jim (0288-10) (0288-13) (0288-16) (0723-5-4) 

 Thiel, Markus (0135-2) 

 Thomas, Bill (0355-2) 

 Trauner, Keith (0573-4) 

 Trencher, Ruth (0115-5) 

 Tweeton, Tanya (0340-7) 

 Ullman, John (0721-30-10) 

 Ullman, Jonathan (0288-10) (0288-13) (0288-16) 

 Van Leer, Sam (0252-12) (0252-14) (0252-15) (0252-16) (0252-18) 

 Van Thienen, Mateo (0033-2) 

 Vinciguerra, Anthony (0032-2) 

 Violich, Francesca (0039-4) 

 Ward, Richard (0348-2) 

 Wegner, Geri (0048-3) 

 Welber, Michael (0237-1) 

 Westaway, Katharine (0014-2) 

 Wilansky, Laura Sue (0078-11) (0078-13) (0721-28-11) (0721-28-12) 

 Wingerd, Mala (0425-1) 

 Zakon, Allan (0118-2) 

 Zerulla, Tanja (0214-7) 

 Zhivelev, Leon (0656-2) 

 Zimmermann, John (0501-1) 

 Zuniga, Family (0272-3) 

Alternatives-NoAction  Barczak, Sara (0112-3) 

 Brexel, Sr., Charles (0592-1) (0592-11) 

 Brinn, Ira (0148-2) 

 Cavros, George (0721-8-2) 

 Commenters, Multiple (0104-2) (0379-2) (0379-7) 

 Harrison, J. M. M. (0508-2) 

 Khajeh-Noori, Jeri (0609-3) 

 Lebatard, David (0192-2) 

 Maher, William (0619-2-17) 

Appendix E NUREG–2176 E-30 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

Alternatives-Sites  Allison, Noreen (0549-1) 

 Almer, Anessa (0712-4) 

 Anonymous, Anonymous (0711-1) 

 Anonymous, Judi (0537-2) (0537-7) 

 Balog, Nancy (0185-1) 

 Bazzone, Barbara (0159-2) 

 Bethune, David (0615-2-24) 

 Birsh, Arthur and Joan (0083-2) 

 Blair, Dan (0485-1) 

 Bloom, Justin (0253-2) 

 Bofill, Beatriz (0235-2) 

 Borie, Edith (0629-1) 

 Bremen, Gary (0181-2) 

 Brexel, Sr., Charles (0592-12) 

 Burge, Laura (0540-3) 

 Campbell, Cara (0253-2) 

 Causey, Charlie (0253-2) 

 Cava, Daniella Levine (0172-1) 

 Cavros, George (0253-2) 

 Chenoweth, Mike (0253-2) 

 Chirillo, James (0261-1) 

 Cobb, Tanya (0413-3) 

 Commenters, Multiple (0044-3) (0044-5) (0102-4) (0103-4) (0240-2) 

(0379-3) 

 Daly, Meg (0253-2) 

 Datz, Amy (0621-2) 

 Dietrich, Chris OMeara (0295-2) 

 Dorn, Kathryn (0693-4) 

 Douglas, Carolyn (0486-1) 

 Dudley, Dwight (0254-2) 

 Edmond, Gabriel (0721-7-1) (0721-7-5) 

 England, Margaret (0253-2) 

 Fass, Amy (0278-1) 

 Ferry, Lisa (0704-1) 

 Field, Fran (0258-5) 

 Finver, Jody (0008-9) 

 Fulks, Anna Louise (0250-2) 

 Fuller, Manley (0253-2) 

 Garey, Jenne (0668-1) 

 Glasshof, Wendy (0587-1) 

 Goldstein, Louis (0418-1) 

 Govindasamy, Rani (0247-1) 

 Greer, Tom (0392-2) 

 Griffith, Ed and Harriet (0366-2) (0366-6) 

 Grill, Brock (0512-1) 

 Guy, Sharon (0654-2) 

 Hanna, Jane (0588-2) (0588-3) (0588-4) 

 Headley, Linda (0376-1) 

 Jones, George L. (0253-2) 

Appendix E October 2016 E-31 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Karsten, Annetta (0452-1) 

 Kassel, Kerul (0676-4) (0676-9) 

 Keller, Alan (0253-2) 

 Kimball, Larry (0526-1) 

 Lague, Victoria (0061-3) 

 Lebatard, David (0192-5) 

 Lerner, Cindy (0145-13) (0254-2) (0721-3-4) 

 Lish, Christopher (0555-2) 

 Livingston, C. J. (0437-1) 

 LoBiondo, Roana and Michael (0359-1) 

 Lopez, Jaclyn (0113-1-3) 

 Macy, Michelle (0405-1) 

 Maher, William (0619-3-2) (0619-5-14) (0619-5-15) (0619-5-16) (0619-5-

18) 

 Malpass, Betsy (0421-1) 

 Manter, Larry (0471-1) 

 Martin, Drew (0253-2) (0641-11) (0721-13-3) 

 Mckee, Sarah (0492-2) 

 McLaughlin, Caroline (0113-1-3) (0253-2) (0721-9-2) (0721-9-3) (0723-4-

4) 

 Melby, George M. (0396-1) 

 Mendelsohn, Alex (0277-1) 

 Mendez, Victoria (0721-5-5) 

 Miami, City (0456-3) (0456-4) (0456-5) (0456-7) (0456-9) 

 Mueller, Heinz J. (0617-4-14) 

 Mundhenk, Norm (0605-1) 

 Neff, Victoria (0682-1) 

 Oliva, Vivian (0349-2) (0349-3) 

 Ortiz, Natalia (0372-4) 

 Orzechowicz, Holly (0263-3) 

 Palmer, Majorie (0360-1) 

 Pareto, Rolando and Marlene (0040-2) 

 Petersen, John (0347-1) 

 Poese, David (0305-1) 

 Rapuano, Shannon (0594-1) 

 Regalado, Tomas (0254-2) 

 Revord, Michael (0420-1) 

 Reynolds, Laura (0113-1-3) (0253-2) 

 Riccio, Jim (0716-8) 

 Ritz, David (0208-2) (0208-5) 

 Ross, Robert and Teresa (0212-3) 

 Routh, Jeffrey (0522-1) 

 Royce, M. (0353-2) (0353-6) 

 Sachs, Jean (0686-1) 

 Schlackman, Mara (0721-32-5) 

 Schwartz, Matthew (0113-1-3) (0721-22-17) 

 Sharp, Andrea Heuson (0210-2) 

 Sheridan, Michelle (0176-1) 

 Shlackman, Jed (0356-7) (0356-8) (0356-13) 

Appendix E NUREG–2176 E-32 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Silverstein, Rachel (0113-1-3) (0253-2) 

 Smoller, Merry Sue (0637-1) 

 Speno, Charlie (0484-1) 

 Spigel, Sue (0220-1) 

 Stoddard, Philip K. (0254-2) 

 Tingle, Peggy (0352-1) 

 Togati, Joanne (0519-1) 

 Tokunaga, Barb (0198-1) 

 Ullman, John (0721-30-7) 

 Van Leer, Sam (0252-7) 

 Van Pelt, Jason (0300-1) (0300-3) 

 Vayu, Satya (0370-6) (0370-12) 

 Violich, Francesca (0039-3) 

 White, Paton (0253-2) 

 Whitehorn, C. (0681-1) 

 Wilansky, Laura Sue (0078-8) (0721-28-8) 

 Willett, Greg (0538-1) 

 Williams, Elinor (0253-2) 

 Yeager, Jerry (0228-4) 

Alternatives-System 

Design  White, Barry J. (0721-12-12) 

Benefit-Cost Balance  Anonymous, Anonymous (0333-5) (0336-2) (0715-2) 

 Anonymous, Charity (0638-3) 

 Bastidas, Mauricio (0720-1) 

 Batista, Carlos (0685-6) (0685-11) 

 Bennett, Robbie (0265-1) 

 Bethune, David (0615-1-15) 

 Burns, Terry (0647-2) 

 Cavros, George (0721-8-6) (0721-8-11) 

 Chrissos, H. L. Chris (0164-4) 

 Cleland, Noel (0207-7) 

 Compel, Jr., Joseph (0283-2) 

 Dickinson, Robert (0461-1) 

 Dimondstein, Carla (0564-2) 

 Eastman, John (0721-24-2) 

 Gross, Cheryl A. (0463-2) 

 Harrison, Norma J. F. (0649-1) 

 Heiney, Jamie (0713-2) 

 Henry, Jim (0723-12-3) 

 Keating, Tim (0545-7) 

 Lane, N. Jo (0569-1) 

 Lange, Alexandra (0088-5) 

 Mayer, Doug (0129-2) 

 Miller, Nyana (0626-3) 

 Mosher, Paul (0249-2) 

 Nelson, Joyce E. (0149-10) (0149-13) 

 Platt, George Seth (0710-5) 

 Post, Patrick (0671-1-2) (0671-2-4) 

 Read, Alice Gray (0022-3) 

Appendix E October 2016 E-33 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Regalado, Tomas (0515-6) 

 Rock, Andrew (0599-1) 

 Rodriguez, Jose Javier (0721-1-1) (0721-1-2) (0721-1-4) 

 Roedel, Kitty (0055-5) 

 Roff, Rhonda (0721-11-3) 

 Stanley, Gael (0071-1) 

 Tamargo, Jorge J. (0494-1) 

 Vorachek, Mary (0291-2) 

 Wilansky, Laura Sue (0078-3) (0721-28-4) 

 Zerulla, Tanja (0214-2) 

Climate Change  Berendsohn, Catherine (0723-11-4) (0723-11-5) (0723-11-7) 

 Edmond, Gabriel (0721-7-2) (0721-7-4) 

 Haber, Matthew S. (0611-15) 

 Harris, Walter (0721-6-3) 

 Henry, Jim (0723-12-13) 

 Hubbard, Stanley S. (0680-2) 

 Lawrence, Diane (0086-3) 

 Martin, Drew (0721-13-4) 

 McLaughlin, Caroline (0721-9-7) (0723-4-2) (0723-4-8) (0723-4-9) 

 Mueller, Heinz J. (0617-4-16) 

 Roff, Rhonda (0721-11-2) 

 Rose, Simon (0009-2) 

Cumulative Impacts  Austin, Stan (0622-2-5) 

 Cava, Daniella Levine (0172-6) (0172-8) 

 Lerner, Cindy (0145-6) 

 Lopez, Jaclyn (0113-2-2) 

 McLaughlin, Caroline (0113-2-2) 

 Reynolds, Laura (0113-2-2) 

 Schwartz, Matthew (0113-2-2) 

 Silverstein, Rachel (0113-2-2) 

Decommissioning  Franzmann, Paul (0384-2) 

 Hyams, Charles (0213-5) 

 Jones, Diane (0130-4) 

Ecology-Aquatic  Anonymous, Judi (0537-5) 

 Austin, Stan (0622-1-7) (0622-1-9) (0622-1-26) (0622-2-3) (0622-2-11) 

 Benson, Mary (0081-3) 

 Bertelson, Bob (0723-15-2) 

 Brexel, Sr., Charles (0592-9) 

 Carpenter, Rory (0694-6) 

 Casey, Sr., Robert J. (0368-2) 

 Cleland, Noel (0288-2) 

 Cobb, Tanya (0413-2) 

 Commenters, Multiple (0102-3) (0103-3) 

 Courliss, William (0604-1) 

 Dietrich, Chris OMeara (0295-4) 

 Fay, Virginia M. (0724-1) (0724-2) (0724-3) (0724-5) (0724-8) (0724-9) 

(0724-10) (0724-11) (0724-12) (0724-13) (0724-14) 

 Field, Fran (0258-3) 

Appendix E NUREG–2176 E-34 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Finver, Jody (0008-5) 

 Goldmeier, Barry (0015-13) 

 Gregory, Gregory B. (0728-2) 

 Griffith, Ed and Harriet (0366-5) (0366-7) 

 Hazard, Evan (0415-1) 

 Hefty, Lee N. (0110-1-6) 

 Hodie, Jake (0191-1) 

 Hurley, Paula (0362-3) 

 Icaza, Alejo (0613-1) 

 Jackalone, Frank (0288-2) 

 Jones, Diane (0130-2) 

 Kassel, Kerul (0676-2) (0676-7) 

 Kaul, Devika (0722-14-4) 

 Lish, Christopher (0555-1) 

 Lopez, Jaclyn (0113-1-13) (0113-1-16) (0113-1-18) (0113-1-19) 

 Lopez, Josie (0284-3) (0284-5) 

 Maher, William (0619-1-12) (0619-1-16) (0619-2-29) (0619-3-12) (0619-3-

13) (0619-4-9) (0619-4-10) (0619-4-11) (0619-4-16) (0619-6-8) (0619-6-

12) (0619-6-14) (0619-7-3) (0619-7-4) (0619-7-6) (0619-7-7) (0619-7-8) 

(0619-7-9) (0619-7-10) (0619-7-11) 

 Mahoney, Stephen (0288-2) 

 Martin, Drew (0641-7) (0721-13-7) 

 Matthews, Debbie (0288-2) 

 McLaughlin, Caroline (0113-1-13) (0113-1-16) (0113-1-18) (0113-1-19) 

(0723-4-3) 

 Mendez, Victoria (0721-5-7) 

 Morton, Sean (0618-2) (0618-3) 

 Mueller, Heinz J. (0617-1-11) (0617-1-12) (0617-1-24) (0617-1-27) (0617-

1-31) (0617-1-32) (0617-1-33) (0617-4-7) (0617-4-8) 

 Pheil, Edward (0707-2) (0707-4) 

 Phillips, Monica D. (0084-1) 

 Post, Patrick (0671-1-1) 

 Raab, Frances (0532-2) 

 Regalado, Tomas (0515-3) 

 Reynolds, Laura (0113-1-13) (0113-1-16) (0113-1-18) (0113-1-19) 

 Ritz, David (0208-3) 

 Rodriguez, Jose Javier (0721-1-8) 

 Roff, Rhonda (0288-2) 

 Royce, M. (0353-5) 

 Salatino, Freda (0299-2) 

 Schwartz, Matthew (0113-1-13) (0113-1-16) (0113-1-18) (0113-1-19) 

(0721-22-13) (0721-22-15) (0721-22-16) 

 Scott, John (0288-2) 

 Sharp, Andrea Heuson (0210-4) 

 Shipe, Kathleen (0193-2) 

 Shlackman, Jed (0356-2) (0356-11) 

 Silverstein, Rachel (0113-1-13) (0113-1-16) (0113-1-18) (0113-1-19) 

 Skove, Ellen H. (0081-3) 

 Stanley, Joyce (0227-4) (0227-5) (0227-11) 

 Stoddard, Philip K. (0106-5) (0106-12) 

Appendix E October 2016 E-35 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Swenson, Cyndee (0722-17-4)

 Teas, Jim (0288-2)

 Tompkins, Constance (0081-3)

 Tweeton, Tanya (0340-2)

 Ullman, Jonathan (0288-2)

 Van Leer, Sam (0252-4)

 Vayu, Satya (0370-3) (0370-7) (0370-10)

 Wegner, Geri (0048-1)

 White, Barry J. (0721-12-4) (0721-12-10)

 Wilansky, Laura Sue (0078-7)

 Yeager, Jerry (0228-3)

 Zerulla, Tanja (0214-5)

Ecology-Terrestrial  Austin, Stan (0622-1-6) (0622-1-8) (0622-1-17) (0622-1-18) (0622-1-19)

(0622-1-20) (0622-1-21) (0622-1-22) (0622-1-23) (0622-1-24) (0622-1-25)

(0622-2-1) (0622-2-2) (0622-2-4) (0622-2-7) (0622-2-10) (0622-2-12)

(0622-2-13) (0622-2-15) (0623-9)

 Bazzone, Barbara (0159-3)

 Benton-Janetta, Lori (0449-2)

 Berendsohn, Catherine (0723-11-3)

 Bertelson, Bob (0723-15-3)

 Casper, Laurel (0202-1)

 Cleland, Noel (0288-7)

 Commenters, Multiple (0240-9)

 Cusidor, Teresa (0127-3)

 Dwyer, Karen (0674-6)

 Eastman, John (0721-24-4)

 Fay, Virginia M. (0724-4) (0724-15) (0724-16)

 Finver, Jody (0008-7)

 Jackalone, Frank (0288-7)

 Lee, Nancy (0373-2)

 Lindsey, Jerrie (0245-3)

 Lopez, Jaclyn (0113-1-6) (0113-1-9) (0113-1-10) (0113-2-8) (0113-2-9)

(0113-2-14) (0113-2-16) (0113-2-17)

 Maher, William (0619-1-2) (0619-1-9) (0619-1-19) (0619-1-20) (0619-2-2)

(0619-2-5) (0619-2-6) (0619-2-7) (0619-2-31) (0619-2-35) (0619-2-37)

(0619-2-38) (0619-2-39) (0619-3-7) (0619-3-8) (0619-3-9) (0619-3-10)

(0619-3-11) (0619-4-3) (0619-4-4) (0619-4-5) (0619-4-6) (0619-4-7)

(0619-4-8) (0619-4-17) (0619-4-18) (0619-5-9) (0619-6-1) (0619-6-2)

(0619-6-3) (0619-6-4) (0619-6-5) (0619-6-6) (0619-6-7) (0619-6-9) (0619-

6-10) (0619-6-11) (0619-6-13) (0619-6-15) (0619-6-16) (0619-6-17) (0619-

6-18) (0619-6-19) (0619-7-1) (0619-7-2) (0619-7-5)

 Mahoney, Stephen (0288-7)

 Matthews, Debbie (0288-7)

 McDuffie, Stephen (0723-8-4)

 McLaughlin, Caroline (0113-1-6) (0113-1-9) (0113-1-10) (0113-2-8) (0113-

2-9) (0113-2-14) (0113-2-16) (0113-2-17)

 Miller, Melissa (0285-2)

 Miller, Nena (0689-1)

 Mueller, Heinz J. (0617-1-6) (0617-1-9) (0617-1-10) (0617-1-13) (0617-1-

28) (0617-1-29) (0617-1-30)

Appendix E NUREG–2176 E-36 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Peters, Emily (0363-4) 

 Reynolds, Laura (0113-1-6) (0113-1-9) (0113-1-10) (0113-2-8) (0113-2-9) 

(0113-2-14) (0113-2-16) (0113-2-17) 

 Roff, Rhonda (0288-7) 

 Rose, Aaron (0307-1) 

 Schlackman, Mara (0721-32-9) 

 Schwartz, Matthew (0113-1-6) (0113-1-9) (0113-1-10) (0113-2-8) (0113-2-

9) (0113-2-14) (0113-2-16) (0113-2-17) (0721-22-4) (0721-22-7) (0723-9-

10) (0723-9-12) (0723-9-13) 

 Scott, John (0288-7) 

 Shlackman, Mara (0246-5) 

 Silverstein, Rachel (0113-1-6) (0113-1-9) (0113-1-10) (0113-2-8) (0113-2-

9) (0113-2-14) (0113-2-16) (0113-2-17) 

 Stanley, Joyce (0227-1) (0227-2) (0227-3) (0227-6) (0227-7) (0227-8) 

(0227-10) (0227-12) (0227-13) (0227-14) 

 Swenson, Cyndee (0722-17-1) 

 Teas, Jim (0288-7) 

 Ullman, Jonathan (0288-7) 

 Wallington, Victoria (0308-1) 

 White, Barry J. (0598-2) 

 Wong, Christina (0066-3) 

 Zerulla, Tanja (0214-4) (0214-6) 

Editorial Comments  Maher, William (0619-1-5) (0619-1-13) (0619-1-18) (0619-2-15) (0619-2-

16) (0619-2-28) (0619-5-7) (0619-5-11) 

Environmental 

Justice  Edmond, Gabriel (0721-7-6) 

 Mueller, Heinz J. (0617-3-2) (0617-3-3) 

 Stoddard, Philip K. (0721-2-15) 

Geology  Mueller, Heinz J. (0617-1-23) 

 White, Barry J. (0721-12-7) 

HealthNonradiological  Almirola, Alejandro (0721-31-8) 

 Batista, Carlos (0685-2) 

 Bethune, David (0615-2-19) 

 Commenters, Multiple (0073-5) (0240-4) 

 de Armas, Maria Cristina (0077-4) 

 Dwyer, Karen (0674-2) 

 Goldman, Emanuel (0153-2) 

 Griffith, Ed and Harriet (0366-4) 

 Haselhurst, Richard (0639-3) 

 Hurley, Paula (0362-2) 

 Kassel, Kerul (0676-6) 

 Koenigsberg, Linda (0721-26-1) 

 Lange, Alexandra (0088-7) 

 Maher, William (0619-2-26) (0619-2-32) (0619-2-33) (0619-4-12) (0619-4-

13) (0619-4-14) 

 Mueller, Heinz J. (0617-1-35) (0617-1-36) 

 Philips, Sally B. (0337-3) 

 Poolos, Hazel (0726-1) 

 Roff, Rhonda (0721-11-6) 

 Royce, M. (0353-4) 

Appendix E October 2016 E-37 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Schwartz, Matthew (0721-22-12) 

 Shlackman, Jed (0356-10) 

 Stoddard, Philip K. (0721-2-12) 

 Vayu, Satya (0370-9) 

 White, Barry J. (0721-12-3) 

 Wilansky, Laura Sue (0078-6) (0721-28-6) 

Health-Radiological  Anonymous, Anonymous (0603-2) (0603-3) (0603-4) (0603-5) (0628-2) 

(0644-3) 

 Bethune, David (0615-1-8) (0615-1-9) (0615-1-11) (0615-2-22) 

 Draper, Lonnie M. (0511-3) 

 DuPriest, William Robert (0093-4) 

 Dwyer, John P. (0264-4) 

 Galles, Camilla (0624-2) (0624-3) 

 Garcia, Alda S. (0524-1) 

 Maher, William (0619-1-3) (0619-2-27) (0619-2-30) (0619-2-36) (0619-4-

15) (0619-4-19) (0619-4-20) (0619-7-12) (0619-7-13) (0619-7-14) (0619-7-

15) (0619-7-16) 

 Schlackman, Mara (0721-32-3) 

 Wilansky, Laura Sue (0078-9) (0721-28-9) 

 Wilson, J. D. Bruce (0065-1) 

Historic and Cultural 

Resources  Maher, William (0619-1-10) (0619-2-10) (0619-2-13) (0619-3-14) (0619-3-

15) (0619-3-16) 

 Mueller, Bradley M. (0727-1) (0727-2) (0727-3) (0727-4) (0727-5) 

 Mueller, Heinz J. (0617-3-4) (0617-3-5) 

 Parsons, Timothy A. (0139-1) (0139-2) (0139-3) 

HydrologyGroundwater  Almirola, Alejandro (0721-31-3) 

 Austin, Stan (0622-1-2) (0623-2) (0623-6) (0623-8) 

 Barczak, Sara (0112-7) 

 Batista, Carlos (0685-14) 

 Berendsohn, Catherine (0723-11-2) 

 Bethune, David (0615-1-5) (0615-3-1) (0615-3-4) 

 Bloom, Justin (0253-3) 

 Breslin, Tom (0721-17-2) 

 Campbell, Cara (0253-3) 

 Causey, Charlie (0253-3) 

 Cavros, George (0253-3) 

 Chenoweth, Mike (0253-3) 

 Cleland, Noel (0288-8) 

 Cobb, Tanya (0413-5) 

 Commenters, Multiple (0102-6) (0103-6) (0240-12) 

 Daly, Meg (0253-3) 

 Daniels, Bonnie (0341-3) 

 de Armas, Maria Cristina (0077-1) 

 Dorn, Kathryn (0693-3) 

 Eastman, John (0721-24-3) 

 England, Margaret (0253-3) 

 Fay, Virginia M. (0724-6) (0724-7) 

 Finver, Jody (0008-8) 

 Fischer, Antoinette (0365-2) (0365-4) 

Appendix E NUREG–2176 E-38 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Fulks, Anna Louise (0250-8) 

 Fuller, Manley (0253-3) 

 Gomez, Christian (0269-1) 

 Gross, Cheryl A. (0463-1) 

 Haber, Matthew S. (0611-4) (0611-5) (0611-7) (0611-8) (0611-9) (0611-

10) 

 Hefty, Lee N. (0110-1-8) (0110-1-9) (0110-1-10) (0110-1-12) 

 Henry, Jim (0723-12-9) (0723-12-12) (0723-12-14) 

 Horiwitz, Laura (0732-1) 

 Hoyle, Lester and Judy (0440-6) 

 Jackalone, Frank (0288-8) 

 Jennings, Cara (0323-1) 

 Jones, George L. (0253-3) 

 Kaul, Devika (0722-14-2) 

 Keaton, Rebecca (0503-1) 

 Keller, Alan (0253-3) 

 Kuraza, Devon (0721-15-10) 

 Lange, Barbara (0591-2) 

 Lerner, Cindy (0145-2) (0145-3) (0145-5) (0145-8) (0145-10) (0721-3-2) 

 Lindsey, Jerrie (0245-5) 

 Livingston, C. J. (0437-2) 

 Lopez, Jaclyn (0113-1-4) (0113-1-15) (0113-1-17) (0113-2-1) (0113-2-3) 

(0113-2-4) (0113-2-5) (0113-2-7) (0113-2-10) 

 Maher, William (0619-2-20) (0619-4-2) (0619-5-8) (0619-7-17) (0619-7-18) 

(0619-7-19) (0619-7-20) (0619-7-21) (0619-7-22) 

 Mahoney, Stephen (0288-8) 

 Malefatto, Alfred (0211-1) 

 Martin, Drew (0253-3) 

 Matthews, Debbie (0288-8) 

 McDuffie, Stephen (0723-8-8) 

 McLaughlin, Caroline (0113-1-4) (0113-1-15) (0113-1-17) (0113-2-1) 

(0113-2-3) (0113-2-4) (0113-2-5) (0113-2-7) (0113-2-10) (0253-3) (0721-

9-6) (0723-4-6) (0723-4-7) 

 Meyer-Steele, Shawn (0187-3) 

 Miami, City (0456-10) (0456-12) (0456-21) 

 Mueller, Heinz J. (0617-1-7) (0617-1-15) (0617-1-17) (0617-1-22) (0617-1-

25) (0617-1-26) (0617-2-1) 

 Palmer, Majorie (0360-3) 

 Reynolds, Laura (0113-1-4) (0113-1-15) (0113-1-17) (0113-2-1) (0113-2-

3) (0113-2-4) (0113-2-5) (0113-2-7) (0113-2-10) (0253-3) 

 Ritz, David (0208-1) (0208-7) 

 Roff, Rhonda (0288-8) 

 Schwartz, Matthew (0113-1-4) (0113-1-15) (0113-1-17) (0113-2-1) (0113-

2-3) (0113-2-4) (0113-2-5) (0113-2-7) (0113-2-10) (0721-22-8) (0721-22-

14) (0723-9-16) (0723-9-18) 

 Scott, John (0288-8) 

 Silverstein, Rachel (0113-1-4) (0113-1-15) (0113-1-17) (0113-2-1) (0113-

2-3) (0113-2-4) (0113-2-5) (0113-2-7) (0113-2-10) (0253-3) (0722-7-5) 

 Stoddard, Philip K. (0106-4) (0721-2-2) (0721-2-3) (0721-2-4) 

 Streit, Didi (0074-2) 

Appendix E October 2016 E-39 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Teas, James (0612-1) (0612-2) (0612-3) (0612-4) (0612-5) (0612-6) 

 Teas, Jim (0288-8) (0723-5-6) 

 Tweeton, Tanya (0340-1) 

 Ullman, Jonathan (0288-8) 

 Van Leer, Sam (0252-5) 

 Vayu, Satya (0370-11) 

 White, Barry J. (0721-12-6) 

 White, Paton (0253-3) 

 Wilansky, Laura Sue (0078-9) (0721-28-7) 

 Williams, Elinor (0253-3) 

 Yeager, Jerry (0228-6) 

Hydrology-Surface 

Water  Albers, Harold (0688-1) 

 Almer, Anessa (0712-3) 

 Anonymous, Anonymous (0327-1) (0551-1) 

 Anonymous, Judi (0537-3) 

 Austin, Stan (0622-1-3) (0622-1-4) (0622-1-5) (0622-1-10) (0622-1-14) 

(0622-1-28) (0622-1-29) (0622-2-14) (0623-3) (0623-4) (0623-5) (0623-7) 

 Barczak, Sara (0112-2) (0112-5) (0112-6) 

 Beattie, Jane (0417-2) 

 Beckman, Yvonne and Douglas (0060-3) (0060-4) 

 Berndgen, Michelle (0361-2) 

 Bethune, David (0615-2-27) (0615-3-2) (0615-3-3) (0615-3-5) (0615-3-6) 

 Bloom, Justin (0253-4) 

 Boyce, Sheila (0091-2) 

 Bremen, Gary (0181-1) 

 Brexel, Sr., Charles (0592-8) 

 Brstow, Mary (0497-1) 

 Buechler, Jerry (0718-1) (0718-5) 

 Cafarelli, Cenie (0298-1) 

 Campbell, Cara (0253-4) 

 Carpenter, Rory (0694-3) 

 Casey, Sr., Robert J. (0368-1) 

 Cathey, Turner (0079-1) 

 Causey, Charlie (0253-4) 

 Cava, Daniella Levine (0172-2) (0172-3) (0172-4) (0172-5) 

 Cavros, George (0253-4) 

 Chenoweth, Mike (0253-4) 

 Chiszar, Benjamin J. (0677-3) 

 Cleland, Noel (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-14) 

 Cobb, Tanya (0413-4) 

 Coffey, Rotraud (0516-1) 

 Commenters, Multiple (0073-1) (0102-2) (0102-5) (0103-2) (0103-5) 

(0103-7) (0104-4) (0240-3) (0240-6) (0379-6) 

 Compel, Jr., Joseph (0283-4) 

 Cook, Cherie (0163-2) 

 Cornely, Tina (0633-2) 

 Corral, Oscar (0133-2) 

 Crystal, Chris (0334-3) (0334-4) 

 Cunningham, Sue (0114-2) (0114-4) 

Appendix E NUREG–2176 E-40 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Cusidor, Teresa (0127-2) (0127-4) 

 Daly, Meg (0253-4) 

 Darden, Colgate (0571-2) 

 Davidson, Penny (0493-1) 

 Demello, Christine (0180-1) 

 Dietrich, Chris OMeara (0295-3) 

 Dorn, Kathryn (0693-1) 

 Drevicky, John (0691-1) 

 Dudley, Dwight (0254-3) (0254-4) 

 Duquette, Bill (0722-13-7) 

 Dwyer, John P. (0264-3) (0673-4) (0673-8) 

 Dwyer, Karen (0674-4) 

 Eckert, Brenda (0400-1) 

 Enfield, David (0236-1) 

 England, Margaret (0253-4) 

 Ericson, Del (0320-1) 

 Fairchild, David (0094-1) (0094-3) (0094-5) 

 Field, Fran (0258-2) (0258-4) 

 Finver, Jody (0008-14) (0008-15) 

 Fischer, Antoinette (0365-3) (0365-5) (0365-6) (0365-7) 

 Foster, Beverly (0401-1) 

 Fuentes, Mariana (0574-2) 

 Fulks, Anna Louise (0250-6) 

 Fuller, Manley (0253-4) 

 Goldman, Emanuel (0153-1) 

 Gonzalez, Javier (0722-8-1) (0722-8-2) (0722-8-3) 

 Grant, Randy (0146-4) 

 Gregory, Gregory B. (0728-1) 

 Griffith, Ed and Harriet (0366-9) 

 Gross, Cheryl A. (0463-3) 

 Guy, Sharon (0654-3) 

 H., Pat (0550-1) (0550-4) 

 Haber, Matthew S. (0611-1) (0611-2) (0611-3) (0611-6) (0611-11) (0611-

12) (0611-13) (0611-18) (0611-19) 

 Haber, Rochelle (0244-2) 

 Hanna, Jane (0588-6) 

 Hefty, Lee N. (0110-1-7) 

 Hoyle, Lester and Judy (0440-3) (0440-4) 

 Hudak, Jill (0722-19-1) 

 Jackalone, Frank (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-14) 

 Jacobs, Lee (0677-3) 

 Johnson, Diane (0590-2) 

 Jones, Gary (0443-1) 

 Jones, George L. (0253-4) 

 Jones, Joan and Robert (0147-2) 

 Kasenow, Lisa (0054-1) (0200-1) 

 Kassel, Kerul (0676-5) (0676-8) 

 Kaul, Devika (0722-14-3) 

 Keating, Tim (0545-2) (0545-3) 

Appendix E October 2016 E-41 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Keller, Alan (0253-4) 

 Kipnis, Dan (0702-1) (0703-1) (0722-2-1) (0722-2-2) (0722-2-3) (0725-1) 

 Klopfer, Carol (0677-3) 

 Kowalski, Kathleen S. (0049-2) 

 Lange, Alexandra (0088-4) 

 Larsen, Paul (0005-1) 

 Lawrence, Diane (0086-2) 

 Lebatard, David (0192-4) 

 Lee, Nancy (0373-3) (0373-4) (0373-8) (0373-11) (0373-12) 

 Lenz, Andrew (0470-1) 

 Lerner, Cindy (0145-4) (0145-7) (0145-9) (0145-11) (0145-12) (0254-3) 

(0254-4) (0721-3-1) (0721-3-3) 

 Levy, Morgan I. (0136-1) (0136-2) 

 Liesche, Ken (0488-1) 

 Lindsey, Jerrie (0245-2) 

 Lopez, Jaclyn (0113-1-5) (0113-1-7) (0113-1-8) (0113-1-11) (0113-2-6) 

(0113-2-11) (0113-2-12) (0113-2-18) 

 Lopez, Josie (0284-2) 

 Maher, William (0619-1-8) (0619-1-15) (0619-2-9) (0619-2-12) (0619-2-14) 

(0619-2-19) (0619-5-17) 

 Mahoney, Robert S. (0364-2) 

 Mahoney, Stephen (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-

14) 

 Malefatto, Alfred (0211-2) 

 Martin, Drew (0253-4) (0641-2) (0641-3) (0641-4) (0641-12) (0721-13-2) 

(0721-13-6) (0721-13-8) 

 Martinez, Orlando A. (0570-3) (0570-4) 

 Matthews, Debbie (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-

14) 

 Mayotte, Monica (0194-1) 

 Mazzarella, Rebecca (0495-4) 

 Mazzuca, Rich (0584-1) 

 McLaughlin, Caroline (0113-1-5) (0113-1-7) (0113-1-8) (0113-1-11) (0113-

2-6) (0113-2-11) (0113-2-12) (0113-2-18) (0253-4) (0721-9-5) 

 Mendez, Victoria (0721-5-4) (0721-5-8) 

 Merleaux, Derek (0342-1) 

 Meyer, Paul (0122-2) 

 Meyer-Steele, Shawn (0187-4) 

 Miami, City (0456-6) (0456-8) (0456-11) (0456-13) (0456-14) (0456-15) 

(0456-16) (0456-17) (0456-20) (0456-27) (0456-28) 

 Monfort, Brooke (0476-1) 

 Montalvo, Stephanie (0630-2) 

 Morrisse, Christine (0483-1) 

 Morton, Sean (0618-1) 

 Mueller, Heinz J. (0617-1-2) (0617-1-3) (0617-1-4) (0617-1-8) (0617-1-14) 

(0617-1-16) (0617-1-18) (0617-1-19) (0617-1-20) (0617-1-21) (0617-4-1) 

(0617-4-2) (0617-4-3) (0617-4-4) (0617-4-5) (0617-4-6) (0617-4-10) 

(0617-4-13) 

 Murphy, Mike (0723-6-3) 

 Nappe, Judith (0695-2) 

Appendix E NUREG–2176 E-42 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Otto, Peter (0509-2) 

 Pareto, Rolando and Marlene (0040-4) 

 Peters, Emily (0363-3) 

 Philips, Sally B. (0337-4) 

 Platt, George Seth (0710-2) 

 Pontier, Christine Hughes (0126-3) 

 Rapuano, Shannon (0594-2) 

 Rawlins, Steve (0642-2) (0642-5) 

 Read, Alice Gray (0022-4) 

 Regalado, Tomas (0254-3) (0254-4) (0515-2) (0515-5) (0721-4-2) (0721-

4-3) 

 Reynolds, Laura (0113-1-5) (0113-1-7) (0113-1-8) (0113-1-11) (0113-2-6) 

(0113-2-11) (0113-2-12) (0113-2-18) (0253-4) (0721-10-2) (0721-10-4) 

 Rhodes, Karen (0140-3) 

 Riccio, Jim (0716-7) 

 Riley, Bill (0722-9-9) 

 Ritz, David (0208-6) (0208-8) (0208-9) 

 Robinson, Angel (0474-1) 

 Rock, Andrew (0599-2) 

 Rodriguez, Jose Javier (0675-2) (0675-6) (0721-1-5) (0721-1-6)

 Roedel, Kitty (0055-3) 

 Roff, Rhonda (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-14) 

(0721-11-5) 

 Rose, Simon (0009-3) 

 Ross, Robert and Teresa (0212-2) 

 Royce, M. (0353-3) 

 Salatino, Freda (0299-1) (0299-3) (0299-4) 

 Sasiadek, Alfred (0053-2) (0053-4) 

 Schlackman, Mara (0721-32-4) (0721-32-6) 

 Schwartz, Matthew (0113-1-5) (0113-1-7) (0113-1-8) (0113-1-11) (0113-2-

6) (0113-2-11) (0113-2-12) (0113-2-18) (0723-9-14) (0723-9-15) 

 Scott, John (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-14) 

 Segal-Wright, Nicholas (0661-3) 

 Segor, Joseph C. (0722-16-1) 

 Seiman, Rhonda (0635-3) 

 Sharp, Andrea Heuson (0210-3) (0210-5) 

 Shipe, Kathleen (0193-1) 

 Shlackman, Jed (0356-1) (0356-9) (0356-12) 

 Shlackman, Mara (0246-3) 

 Silverstein, Rachel (0113-1-5) (0113-1-7) (0113-1-8) (0113-1-11) (0113-2-

6) (0113-2-11) (0113-2-12) (0113-2-18) (0253-4) (0722-7-3) (0722-7-4) 

(0722-7-6) (0722-7-8) 

 Smyke, Pete (0459-1) 

 Standley, Ron (0414-1) 

 Stanley, Joyce (0227-9) 

 Stoddard, Philip K. (0106-2) (0106-6) (0106-7) (0106-8) (0106-9) (0106-

10) (0106-11) (0254-3) (0254-4) (0721-2-5) (0721-2-6) (0721-2-7) (0721-2-

8) (0721-2-9) (0721-2-10) 

 Strouble, Jackie (0297-2) 

 Swenson, Cyndee (0722-17-3) 

Appendix E October 2016 E-43 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Teas, James (0612-7) 

 Teas, Jim (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-14) (0723-

5-5) 

 Teasley, Regi (0318-1) 

 Thiel, Markus (0135-1) 

 Thomas, Bill (0355-1) 

 Tingle, Peggy (0352-2) 

 Trauner, Keith (0573-3) 

 Trencher, Ruth (0115-6) 

 Trowbridge, Mark (0723-2-6) 

 Ullman, John (0721-30-3) (0721-30-6) (0721-30-8) (0721-30-9) 

 Ullman, Jonathan (0288-3) (0288-4) (0288-5) (0288-9) (0288-12) (0288-

14) 

 Van Leer, Sam (0252-3) (0252-6) (0252-9) 

 Vayu, Satya (0370-2) (0370-8) 

 Wallace, Otis (0723-1-6) 

 West, Eric (0435-1) 

 White, Barry J. (0598-3) (0721-12-2) (0721-12-9) 

 White, Paton (0253-4) 

 Wicht, Dan (0197-1) 

 Wilansky, Laura Sue (0078-5) 

 Williams, Elinor (0253-4) 

 Yeager, Jerry (0228-2) (0228-5) (0228-7) 

 Yovel, Ephrat (0721-29-2) 

Land Use-Site and 

Vicinity  Austin, Stan (0622-2-8) 

 Gross, Cheryl A. (0463-5) 

 Hefty, Lee N. (0110-1-4) (0110-1-11) 

 Lindsey, Jerrie (0245-6) 

 Maher, William (0619-1-17) (0619-2-3) (0619-2-4) (0619-2-8) (0619-2-11) 

(0619-2-18) (0619-3-3) (0619-3-4) (0619-3-5) (0619-3-6) 

 Tweeton, Tanya (0340-4) 

Land UseTransmission Lines  Almirola, Alejandro (0721-31-6) (0721-31-7) 

 Austin, Stan (0622-1-12) (0622-1-15) (0622-1-16) (0622-1-27) (0622-2-9) 

(0623-12) 

 Batista, Carlos (0685-3) 

 Berendsohn, Catherine (0723-11-6) 

 Berndgen, Michelle (0361-3) 

 Brown, Judith O. (0131-1) 

 Commenters, Multiple (0044-7) (0073-3) (0073-4) (0073-6) (0240-10) 

(0240-11) 

 Corral, Oscar (0133-3) 

 Crystal, Chris (0334-2) 

 Daly, Meg (0076-1) (0076-3) 

 de Armas, Maria Cristina (0077-3) 

 Fairchild, David (0094-4) 

 Finver, Jody (0008-2) 

 Fulks, Anna Louise (0250-3) 

 Griffith, Ed and Harriet (0366-3) (0366-8) 

 H., Pat (0550-2) 

Appendix E NUREG–2176 E-44 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Haber, Matthew S. (0611-17) 

 Hamilton, McHenry (0205-1) 

 Hefty, Lee N. (0110-1-1) (0110-1-2) (0110-1-3) (0110-1-5) 

 Hughes, David (0377-1) (0377-2) 

 Hyden, Brent A. (0670-1) (0670-2) 

 Johnson, Nadine (0007-2) 

 Kassel, Kerul (0676-3) 

 Koenigsberg, Linda (0721-26-3) 

 Lange, Alexandra (0088-2) 

 Langlieb Greer, Evelyn (0510-1) 

 Maher, William (0619-2-1) (0619-2-34) (0619-4-1) 

 Martin, Drew (0641-10) 

 Martinez, Orlando A. (0570-2) 

 McCall, Eric (0056-2) 

 McLaughlin, Caroline (0721-9-4) (0723-4-5) 

 Merino, Miriam (0092-2) 

 Meyer-Steele, Shawn (0187-5) 

 Miami, City (0456-24) 

 Mueller, Heinz J. (0617-4-11) 

 Nelson, Joyce E. (0149-2) (0149-4) (0149-11) 

 Ortiz, Natalia (0372-1) 

 Palmer, Majorie (0360-2) 

 Perez, Danica (0184-1) 

 Provost, Allan (0339-2) 

 Puchades, Mary (0616-1) 

 Rawlins, Steve (0642-4) 

 Regalado, Tomas (0515-7) (0721-4-4) 

 Reiter, Ben (0080-2) 

 Robertson, Alyce (0117-2) 

 Rodriguez, Barbara (0034-3) 

 Rodriguez, Jose Javier (0675-5) (0721-1-7) 

 Roedel, Kitty (0055-6) 

 Roque, Julio (0024-2) (0328-1) 

 Schwab, Roy (0579-4) 

 Schwartz, Matthew (0721-22-3) (0721-22-5) (0723-9-9) (0723-9-11) 

 Shlackman, Jed (0356-3) 

 Sifko, Basilio (0408-1) (0408-2) (0408-3) (0408-4) (0408-6) (0408-8) 

 Stoddard, Philip K. (0721-2-14) 

 Trencher, Ruth (0115-8) 

 Trowbridge, Mark (0723-2-8) 

 Vayu, Satya (0370-4) 

 Wegner, Geri (0048-2) 

 Whitlock, Catherine (0701-2) 

Meteorology and Air 

Quality  Frederickson, Kelly (0188-1) 

 Harris, Walter (0721-6-2) 

 Maher, William (0619-2-22) 

 Mueller, Heinz J. (0617-2-3) (0617-4-9) 

 Platt, George Seth (0710-3) 

 Riley, Bill (0722-9-8) (0722-9-10) 

Appendix E October 2016 E-45 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Roff, Rhonda (0721-11-1) (0721-11-7) 

 Schwartz, Matthew (0721-22-9) (0723-9-17) 

 Stoddard, Philip K. (0721-2-11) 

 Trowbridge, Mark (0723-2-5) 

 Tweeton, Tanya (0340-3) 

Need for Power  Almirola, Alejandro (0721-31-4) 

 Barczak, Sara (0112-1) (0112-4) 

 Bethune, David (0615-1-4) (0615-1-13) 

 Breslin, Tom (0721-17-1) 

 Cavros, George (0721-8-1) (0721-8-4) (0721-8-8) (0721-8-10) 

 Commenters, Multiple (0379-4) 

 de Azevedo, Ricardo (0119-3) 

 England, Peter (0722-10-2) 

 Finver, Jody (0008-3) 

 Goldmeier, Barry (0015-1) (0015-8) (0015-12) 

 Henry, Jim (0723-12-1) (0723-12-4) 

 Hickey, Alan (0653-3) 

 Hubbard, Stanley S. (0680-4) 

 Keating, Tim (0545-6) 

 Larrabee, Laura (0035-3) 

 Maher, William (0619-5-12) (0619-5-13) 

 Martin, Drew (0641-8) (0721-13-5) 

 McDuffie, Stephen (0723-8-3) 

 Mendez, Victoria (0721-5-2) 

 Miami, City (0456-22) 

 Nelson, Joyce E. (0149-7) 

 Philips, Sally B. (0337-2) 

 Platt, George Seth (0710-6) (0710-7) 

 Porter, Jeff (0722-1-1) 

 Rapuano, Shannon (0594-4) 

 Read, Alice Gray (0022-5) 

 Riccio, Jim (0716-6) 

 Rodriguez, Jose Javier (0721-1-9) 

 Rodriguez, Manuel J. (0721-27-1) 

 Saporito, Thomas (0010-4) (0010-10) 

 Sifko, Basilio (0408-5) 

 Silva, Nicolas (0722-5-2) 

 Trencher, Ruth (0115-4) 

 Trowbridge, Mark (0723-2-2) 

 Wallace, Otis (0723-1-1) 

 Williams, Paul (0041-1) 

Opposition-Licensing 

Action  Ackerman, Frank (0565-1) 

 Allen, Maureen (0154-1) 

 Almirola, Alejandro (0178-1) (0178-4) (0721-31-1) (0721-31-11) (0721-31-

13) 

 Alvarez, Chad (0664-1) 

 Anderson, Glen (0321-1) 

 Anderson, Vaughn (0380-1) 

 Anonymous, Anonymous (0239-1) (0331-1) (0351-1) (0354-1) (0628-3) 

Appendix E NUREG–2176 E-46 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

(0644-1) (0644-5) 

 Anonymous, Charity (0638-4) 

 Anonymous, Elena (0662-1) 

 Anonymous, Judi (0537-1) (0537-4) 

 Anonymous, Lynn (0161-1) 

 Aronson, Murray (0391-1) 

 Avers, Pamela Dee (0090-1) 

 Bach, Lili (0128-1) 

 Bagwell, Wilson Knox (0306-1) 

 Ball, Cheri (0472-1) (0472-3) 

 Barczak, Sara (0112-10) 

 Barlow, Jeffrey (0218-2) 

 Barnidge, Virginia (0672-1) 

 Bastidas, Mauricio (0720-3) 

 Baumwall, Douglas (0329-1) 

 Bazzi, Noell (0047-1) 

 Bazzone, Barbara (0159-1) (0159-7) 

 Beattie, Jane (0417-1) 

 Beckman, Yvonne and Douglas (0060-1) (0060-2) 

 Beiriger, Mary (0287-1) (0287-2) 

 Bejarano, Antonio (0019-1) 

 Benson, Mary (0081-1) (0081-6) (0081-7) 

 Berendsohn, Catherine (0723-11-9) 

 Bernabei, Catharina (0721-18-5) 

 Bernatis, Jenn (0520-1) 

 Berndgen, Michelle (0361-1) (0361-4) 

 Bethune, David (0615-1-12) (0615-3-11) (0615-3-12) (0721-23-9)

 Birsh, Arthur and Joan (0083-1) 

 Blanck, Heidi (0397-1) 

 Bloom, Justin (0253-1) (0253-6) 

 Bodiford, Loretta (0444-1) 

 Boone, James (0533-2) 

 Boone, Jim (0436-1) 

 Boyce, Sheila (0091-1) (0091-4) 

 Bremen, Gary (0181-3) 

 Brinn, Ira (0148-1) (0148-3) 

 Bromage, Joan (0386-1) 

 Brown, Bradford (0667-1) 

 Bryan, David (0507-1) 

 Buechler, Jerry (0718-3) 

 Bump, Deborah (0535-1) 

 Bunker, Diane (0426-1) 

 Burge, Laura (0540-2) (0540-4) 

 Burns, Terry (0647-3) 

 Buyea, Thomas (0505-1) (0505-3) 

 Campbell, Cara (0253-1) (0253-6) 

 Cardona, Alfredo (0343-1) (0343-2) 

 Carlson, John (0158-3) 

 Casey, Sr., Robert J. (0368-3) 

Appendix E October 2016 E-47 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Castro, Alyssa Tomasi (0665-1) 

 Cathey, Turner (0079-2) 

 Causey, Charlie (0253-1) (0253-6) 

 Cavros, George (0253-1) (0253-6) 

 Chenoweth, Mike (0253-1) (0253-6) 

 Chiszar, Benjamin J. (0677-1) (0677-7) 

 Clapp, Linda (0028-1) (0028-2) 

 Cleland, Noel (0207-1) (0207-8) (0288-1) 

 Cobb, Tanya (0413-1) 

 Coffey, Rotraud (0516-2) 

 Cohen, Howard (0567-1) 

 Colby, Helen (0124-3) (0242-2) (0733-1) 

 Colls, Ana (0125-1) 

 Colson, Clay G. (0602-1) 

 Commenters, Multiple (0044-1) (0044-9) (0067-1) (0067-4) (0073-7) 

(0102-1) (0102-7) (0102-8) (0103-1) (0103-8) (0104-1) (0104-6) (0240-1) 

(0379-1) 

 Compel, Jr., Joseph (0283-1) 

 Cook, Cherie (0163-1) (0163-3) 

 Cooper, Fran (0204-1) 

 Cooper, Joe (0165-1) 

 Cornely, Tina (0633-1) 

 Corral, Oscar (0133-1) (0133-5) 

 Courliss, William (0604-2) 

 Crystal, Chris (0334-1) 

 Cullen, Sarah (0597-1) 

 Cummings, Frank (0709-1) (0709-3) 

 Cunningham, Sue (0114-1) 

 Cusidor, Teresa (0127-1) (0127-6) 

 Daly, Meg (0076-4) (0253-1) (0253-6) 

 Daniels, Bonnie (0341-1) (0341-4) 

 Darden, Colgate (0571-1) 

 Dauerty, Barbara (0614-1) 

 de Armas, Maria Cristina (0077-5) 

 de Azevedo, Ricardo (0119-1) (0119-4) 

 Defoggi, Virginia (0266-1) 

 Degges, Frank (0447-1) 

 Demaria, Karen (0262-1) 

 Dent, William (0319-1) 

 Deutsch, Steven (0552-1) 

 Dietrich, Chris OMeara (0295-1) (0295-5) 

 Dimondstein, Carla (0564-1) 

 Dorn, Kathryn (0693-2) (0693-5) 

 Dougherty, Kate (0394-1) 

 Douglas, Carolyn (0486-2) 

 Draper, Lonnie M. (0511-1) 

 Drew, Virginia (0399-1) 

 Dronsky, Rick (0142-1) 

 Dudley, Dwight (0254-1) (0254-7) 

Appendix E NUREG–2176 E-48 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Dunn, Elmo (0402-1) 

 DuPriest, William Robert (0093-1) 

 Duran-Pinzon, Jaime (0243-1) (0243-4) 

 Durieux, P. (0451-1) 

 Dutton, Julene (0640-1) 

 Dwyer, John P. (0264-8) (0673-9) 

 Dwyer, Karen (0674-1) (0674-8) (0674-9) 

 Earnshaw, Shinann (0326-2) 

 Edmond, Gabriel (0721-7-8) 

 Edwards, Suzi (0600-1) 

 Egan, June (0690-1) 

 Ehrenfried, Jennifer (0544-1) 

 Elton, Wallace (0229-1) (0229-2) 

 Engelberg, Jodi (0004-1) 

 England, Margaret (0253-1) (0253-6) 

 Erven, Marlene (0314-1) 

 F****SH, Peter (0547-1) 

 Faber, Davenie (0006-1) 

 Felinski, Julee (0625-1) (0625-5) 

 Fernandez, Maria Cristina (0064-1) 

 Field, Fran (0258-1) 

 Fielding, Ed (0232-1) 

 Finver, Jody (0008-1) (0008-12) 

 Fischer, Antoinette (0365-1) 

 Fishman, Zelma (0395-1) 

 Fitzpatrick, Deirdre (0217-1) 

 Fox, Kristi (0506-1) 

 Franzmann, Paul (0384-1) (0384-3) 

 Frederickson, Kelly (0188-2) 

 Freel, Susan (0166-1) 

 Fuentes, Mariana (0574-1) 

 Fuller, Manley (0253-1) (0253-6) 

 Galbreath, Jerry (0489-1) 

 Galles, Camilla (0624-1) 

 Garcia, Ruslan (0116-1) 

 Gavel, Deborah (0098-1) (0098-3) 

 Geary, Craig W. (0097-1) 

 Ghosh, Susan (0595-1) 

 Glass, Rachel (0222-2) 

 Goldberg, Laura (0568-2) 

 Goldman, Emanuel (0153-3) (0153-5) 

 Gomez, Albert (0721-34-3) 

 Gomez, Gustavo (0101-1) 

 Gomez, Lissett (0030-1) 

 Gomez, Toni Thoman (0504-1) 

 Gonzalez, Carlos (0714-1) 

 Graffagnino, Mary Ann and Frank (0403-1) 

 Grant, Randy (0146-1) 

 Greenwald, Ken (0385-1) 

Appendix E October 2016 E-49 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Greer, Tom (0392-1) (0392-3) 

 Griffith, Ed and Harriet (0366-1) (0366-12) 

 Grill, Helen (0043-1) 

 Griswold, Dave (0631-1) 

 Gross, Cheryl A. (0463-6) (0463-7) 

 Guy, Sharon (0654-1) 

 H., Pat (0550-5) 

 Haber, Rochelle (0244-1) (0244-3) 

 Haffmans, Edmund (0371-1) (0371-6) 

 Halligan, Melody (0491-1) 

 Hanna, Jane (0588-1) 

 Hansen, Yvonne (0439-1) 

 Harden, Ronald (0195-1) 

 Hardie, Daniel (0562-1) 

 Harris, Walter (0721-6-5) 

 Harrison, J. M. M. (0508-1) 

 Hart, Barbara (0196-1) 

 Haselhurst, Richard (0639-1) 

 Hawkes, Holly Forrester (0031-1) (0031-2) 

 Hayes, Linda (0275-1) 

 Heiney, Jamie (0713-1) (0713-4) 

 Herrera, Luis (0721-33-1) (0721-33-3) 

 Hickey, Alan (0653-1) 

 Hilderbrandt, Todd (0585-1) 

 Hoegler, Jean (0438-1) 

 Hoffmeyer, Lisa (0546-1) 

 Holland, Karen (0059-1) 

 Houghton, Francis (0735-1) 

 Hoyle, Lester and Judy (0440-1) (0440-5) 

 Hubler, Gina Marie (0089-1) (0089-3) (0095-1) 

 Hudson, Harold J. (0099-1) 

 Hurley, Paula (0362-1) (0362-6) 

 Hyams, Charles (0213-1) 

 Imbesi, Nan (0058-1) 

 Jackalone, Frank (0288-1) 

 Jacobs, Lee (0677-1) (0677-7) (0679-1) 

 Jacobs, Leslye (0634-1) 

 Jennings, Cara (0323-2) 

 Jens-Rochow, Steve (0666-1) 

 Jimenz, Lawrence (0301-1) 

 Joannou, Jr., Benjamin (0643-3) (0643-4) (0643-6) 

 Johannsen, Christian (0045-1) (0045-3) 

 Johnson, Nadine (0007-1) (0007-3) 

 Johnson, Rheta (0696-1) 

 Johnston, Judy (0734-1) 

 Jones, Diane (0130-1) 

 Jones, George L. (0253-1) (0253-6) 

 Jones, Joan and Robert (0147-1) (0147-3) 

 Jones, Michael E. (0082-1) 

Appendix E NUREG–2176 E-50 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Jurczewski, Carol (0490-1) 

 K., Jeff (0335-1) 

 Kadis, Patricia (0248-2) 

 Karlow, Edwin (0226-1) 

 Kassel, Kerul (0676-1) 

 Kaul, Devika (0722-14-1) (0722-14-6) 

 Kavanaugh, Daniel (0338-2) 

 Kaye, Jackie (0407-1) 

 Keating, Tim (0545-1) 

 Keller, Alan (0253-1) (0253-6) 

 Kern, Madeleine Fisher (0411-1) 

 Kirschbaum, Saran (0466-1) 

 Klopfer, Carol (0677-1) (0677-7) (0678-1) 

 Koenigsberg, Linda (0721-26-4) (0721-26-7) 

 Kowalski, Kathleen S. (0049-3) 

 Lague, Victoria (0061-1) (0061-4) 

 Lane, N. Jo (0569-2) 

 Lange, Alexandra (0087-1) (0087-2) (0087-4) (0088-8) 

 Langlieb Greer, Evelyn (0510-2) 

 Larsen, Shannon (0160-1) 

 Lawrence, Diane (0086-1) (0086-4) 

 Lawrence, Theresa (0580-1) (0580-3) 

 Lawson, Ken (0225-1) 

 Le Cronier, Micki (0652-1) 

 Lebatard, David (0192-1) (0192-7) 

 Lee, Nancy (0373-1) (0373-15) 

 Lenz, Andrew (0470-3) 

 Leo, Carlos (0428-1) 

 Lerner, Cindy (0254-1) (0254-7) 

 Lettieri, Tammy (0259-3) (0259-4) (0559-1) 

 Levy, Morgan I. (0136-5) 

 Lindsey, Jerrie (0245-1) (0245-7) 

 Lish, Christopher (0555-3) 

 Livingston, Catherine (0374-1) 

 LoBiondo, Roana and Michael (0359-3) 

 Lopez, Jaclyn (0113-1-14) (0113-2-15) 

 Lopez, Josie (0284-1) (0284-6) (0284-7) 

 Lucas, Carmen (0141-1) (0141-3) (0141-5) 

 Macraith, Bonnie (0186-1) 

 Mahoney, Robert S. (0364-1) 

 Mahoney, Stephen (0288-1) 

 Malone, Peggy (0539-1) (0539-2) 

 Malyon, Hilary (0669-1) 

 Manter, Larry (0471-2) 

 Manuel, Becky Randel (0137-1) 

 Martin, Drew (0253-1) (0253-6) (0641-1) 

 Martinez, Orlando A. (0570-1) (0570-5) 

 Matheny, Kent (0453-1) 

 Matthews, Debbie (0288-1) 

Appendix E October 2016 E-51 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Mauri, Tom (0132-3) 

 Mayer, Karen (0475-1) 

 Mazzarella, Rebecca (0495-1) 

 McCall, Eric (0056-1) (0056-4) (0056-5) 

 McCarthy, Dawn (0330-1) (0330-2) 

 Mcintyre, Frances (0572-1) 

 Mckee, Sarah (0492-1) (0492-4) 

 McLaughlin, Caroline (0113-1-14) (0113-2-15) (0253-1) (0253-6) (0721-9-

1) (0721-9-8) (0723-4-1) (0723-4-10) 

 McVicker, Micah (0177-1) 

 Merino, Miriam (0092-1) 

 Metje, Melodie (0606-1) 

 Meyer, Paul (0122-1) 

 Meyer-Steele, Shawn (0187-1) (0187-6) 

 Miami, City (0456-1) (0456-25) 

 Mikan, Edward (0536-1) 

 Miller, Howard R. (0138-1) 

 Miller, Melissa (0285-1) (0285-3) 

 Miller, Nyana (0626-1) (0626-4) 

 Mitzkewich, Yuri (0523-1) 

 Morgan, Karen (0155-1) 

 Mosher, Paul (0249-1) 

 Nagel, Karen (0527-1) 

 Nappe, Judith (0695-1) 

 Nelson, Joyce E. (0149-1) (0149-3) (0149-14) 

 Neway, Roberta (0057-1) (0057-5) 

 Newman, Donna (0156-1) 

 Nickerson, Nancy (0692-2) 

 Nieto, Victor (0717-1) 

 Norman, Ronald (0358-1) (0358-4) (0358-5) 

 Nye, Janet (0281-1) 

 O'Donahoo, Gayle (0698-1) 

 O'Donahoo, Roger (0698-1) 

 Odierna, Cynthia (0542-1) 

 Oliva, Vivian (0349-1) (0349-4) 

 Oria, Jordan (0171-2) 

 Ortiz, Natalia (0003-1) (0003-3) (0372-2) (0372-5) 

 Orzechowicz, Holly (0263-2) (0263-6) (0263-7) 

 Osborne, Martin (0216-1) 

 Otis, Martha (0150-1) (0150-4) 

 Otto, Peter (0509-3) 

 Padilla, Dora (0238-1) (0238-3) 

 Padron-Delgado, Blanca (0257-1) (0257-3) 

 Pareto, Rolando and Marlene (0040-1) (0040-5) 

 Parker, Richard (0316-1) 

 Pattison, Janet (0646-1) 

 Pearce, J. B. (0479-1) 

 Perez, Danica (0184-2) (0184-3) 

 Peterman, Andy (0274-1) (0274-2) 

Appendix E NUREG–2176 E-52 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Peters, Emily (0363-1) 

 Petersen, John (0347-2) 

 Peterson, Ted (0423-1) 

 Phillips, Monica D. (0084-3) 

 Pinto, Theresa (0499-1) 

 Piper, Cynthia (0183-1) 

 Platt, David (0109-1) (0109-3) 

 Platt, George Seth (0710-1) 

 Polifroni, Josephine (0182-1) 

 Pontier, Christine Hughes (0126-1) 

 Poole, Diane (0457-1) 

 Portela, Ana C. (0409-1) 

 Portuondo, Pilar (0241-1) (0241-3) 

 Post, Patrick (0671-2-2) 

 Provost, Allan (0339-5) 

 Prugue, Jorge and Paloma (0068-1) 

 Punnett, Daniela (0553-1) (0553-3) 

 Purcell, Douglas (0427-1) 

 Purdy, Shyam and Mohini (0233-1) 

 Quinn, George (0410-1) 

 Raits, Eric (0062-1) 

 Ramankutty, Vishnu (0578-1) 

 Rawlins, Steve (0642-1) (0642-6) 

 Regalado, Tomas (0254-1) (0254-7) (0515-8) 

 Reiter, Ben (0080-1) 

 Rennie, Edwyna (0224-1) 

 Reyneri, Juan (0121-1) 

 Reynolds, Laura (0113-1-14) (0113-2-15) (0253-1) (0253-6) (0721-10-5) 

 Rhodes, Karen (0140-4) 

 Richards, Margie (0450-2) 

 Rifkind, David (0721-16-7) 

 Robbin, Valerie (0223-1) 

 Roberts, Linda (0096-2) (0096-4) 

 Robertson, Alyce (0117-1) (0117-4) 

 Rodriguez, Barbara (0034-1) 

 Rodriguez, Jose Javier (0675-1) (0721-1-11) 

 Roedel, Kitty (0055-1) (0055-7) (0055-9) 

 Roff, Rhonda (0288-1) 

 Roos, Monica (0052-3) 

 Roque, Julio (0024-3) 

 Rose, Simon (0009-1) 

 Roseberry, Bill (0179-1) 

 Rosenfeld, Alice (0566-1) 

 Ross, Robert and Teresa (0212-1) 

 Rothstein, Debbie (0292-1) 

 Royce, M. (0353-7) 

 Ryan, Jim (0543-1) (0543-3) 

 Salatino, Freda (0299-5) 

 Sanchez, Sergio and Irma (0660-1) 

Appendix E October 2016 E-53 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Sanfilippo, Val (0636-1) 

 Saporito, Thomas (0010-1) (0010-2) 

 Sasiadek, Alfred (0053-1) 

 Scherr, Matthew (0684-1) 

 Schilling, Judy (0429-1) 

 Schlackman, Mara (0721-32-10) 

 Schwab, Roy (0579-1) (0579-6) 

 Schwartz, Matthew (0113-1-14) (0113-2-15) 

 Scott, John (0288-1) 

 Scott, Ruth (0548-1) 

 Segal-Wright, Nicholas (0661-1) 

 Seiman, Rhonda (0635-1) (0635-2) (0635-4) 

 September, P. J. (0267-1) 

 Shapiro, Eugene (0357-1) 

 Shark, Jason (0120-1) 

 Sharp, Andrea Heuson (0210-1) (0210-7) 

 Shasky, Mike (0350-1) 

 Shelley, Cynthia (0556-1) 

 Shepard, J. (0143-1) 

 Shipe, Kathleen (0193-3) 

 Shlackman, Jed (0356-15) (0356-17) 

 Shlackman, Mara (0246-1) (0246-7) 

 Silverstein, Rachel (0113-1-14) (0113-2-15) (0253-1) (0253-6) (0722-7-1) 

(0722-7-2) 

 Simmerman, Scott (0480-1) 

 Simon, Gary P. (0050-1) (0050-3) 

 Skove, Ellen H. (0081-1) (0081-6) (0081-7) 

 Slaton, Marina (0531-1) 

 Smay, Betty (0063-1) 

 Smith, David W. (0051-1) (0051-4) 

 Smith, Pamela (0730-1) 

 Smythe, Ana (0557-1) 

 Sockloff, Judith (0175-1) 

 Sommers, Andrea (0270-1) 

 Sophia, Tristan (0221-1) 

 Sorenson, Katy (0596-1) (0596-3) 

 Southern, Tom (0620-1) 

 Speno, Charlie (0484-3) 

 Stanley, Gael (0071-2) 

 Stevens, Lisa (0310-1) 

 Stoddard, Philip K. (0254-1) (0254-7) 

 Streit, Christopher V. (0075-2) 

 Streit, Didi (0074-1) 

 Strouble, Jackie (0297-1) (0297-3) 

 Suda, Maryska (0534-1) 

 Svensson, Bo (0478-1) 

 Tambussi-Brechon, Linda (0042-1) 

 Teas, Jim (0288-1) (0723-5-1) 

 Thiel, Markus (0135-3) 

Appendix E NUREG–2176 E-54 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Thomas, Bill (0355-3) 

 Thomas, Gina (0271-1) 

 Timberlake, Ralph (0282-1) 

 Tingle, Peggy (0352-3) 

 Tompkins, Constance (0081-1) (0081-6) (0081-7) 

 Trauner, Keith (0573-1) 

 Trencher, Ruth (0115-1) (0115-3) 

 Tucker, Lauren (0105-1) 

 Turner, William P. (0663-1) 

 Tweedy, Mary (0581-1) 

 Tweeton, Tanya (0340-6) 

 Ullman, John (0721-30-1) (0721-30-5) (0721-30-12) 

 Ullman, Jonathan (0288-1) 

 Umpierre, Diana (0209-1) 

 Underwood, John (0416-1) 

 Van Leer, Sam (0252-13) (0252-20) 

 Van Pelt, Jason (0300-4) 

 Van Thienen, Mateo (0033-1) 

 Vance, Richard (0289-1) 

 Vayu, Satya (0370-1) (0370-14) 

 Vermeulen, Mary (0433-1) 

 Vinciguerra, Anthony (0032-1) 

 Violich, Francesca (0039-1) (0039-5) 

 Wade, Pat (0582-1) 

 Wade, Thomas M. (0046-1) 

 Wallington, Victoria (0308-2) 

 Warzalla, Jim (0144-1) 

 Watson, Fran (0528-1) 

 Weber, Gae (0157-1) 

 Weber, Zorina (0469-2) 

 Wegner, Geri (0048-4) 

 Weiss, Arwen (0518-1) 

 West, Eric (0435-2) 

 White, Barry J. (0721-12-8) 

 White, Holly (0206-1) (0206-3) 

 White, Paton (0253-1) (0253-6) 

 Whitfield, Isabelle (0251-1) 

 Wilansky, Laura Sue (0078-4) (0078-14) (0721-28-5) (0721-28-12) 

 Willett, Bett (0658-1) 

 Williams, Elinor (0253-1) (0253-6) 

 Winters, Gracie (0398-1) 

 Wong, Christina (0066-1) (0066-2) (0066-4) 

 Wry, Ellen (0290-1) (0290-2) (0290-3) 

 Yeager, Jerry (0228-1) (0228-8) 

 Yost, Gaylord (0430-1) 

 Young, Kim (0651-1) (0651-2) (0651-3) (0651-5) 

 Yount, Madeline (0422-1) 

 Yovel, Ephrat (0721-29-1) (0721-29-3) 

 Zakon, Allan (0118-1) 

Appendix E October 2016 E-55 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Zarsky, Terry (0541-1) 

 Zerulla, Tanja (0214-3) (0214-8) 

 Zuniga, Family (0272-2) 

Opposition-Licensing 

Process  Bethune, David (0721-23-2) 

 Breslin, Tom (0721-17-3) 

 Edmond, Gabriel (0721-7-3) 

 Lee, Nancy (0373-14) 

 Lerner, Cindy (0721-3-5) 

 Schwartz, Matthew (0721-22-11) 

 Stoddard, Philip K. (0721-2-1) 

 White, Barry J. (0721-12-13) 

Opposition-Nuclear 

Power  Aha, Chas (0708-1) 

 Almirola, Alejandro (0178-3) 

 Alvarez, Chad (0664-2) 

 Alvarez, Susana (0025-1) 

 Andersen, Paul (0388-1) 

 Anderson, Vaughn (0380-2) 

 Anonymous, Anonymous (0327-2) (0336-1) (0336-4) (0346-1) (0603-1) 

(0628-1) (0645-1) (0705-1) (0715-1) (0719-1) (0719-2) 

 Bach, Lili (0128-4) 

 Barnes, Janice (0558-1) 

 Baumwall, Douglas (0329-2) 

 Bereczki, Patricia (0393-1) 

 Bernabei, Catharina (0721-18-1) (0721-18-2) 

 Bonilla-Jones, Carmen Elisa (0231-1) (0231-3) 

 Brandariz, Anita (0529-1) (0529-3) 

 Bratcher, Suzanne (0498-1) 

 Brexel, Sr., Charles (0592-4) 

 Bubb, Ken (0462-1) 

 Campbell, Grant (0482-1) 

 Chiszar, Benjamin J. (0677-2) (0677-4) (0677-8) (0677-9) 

 Chrissos, H. L. Chris (0164-2) 

 Cleland, Noel (0207-2) (0207-4) (0207-5) (0288-15) 

 Cohen, Howard (0567-2) 

 Colby, Helen (0124-1) 

 Compel, Jr., Joseph (0283-7) 

 Cook, J. (0577-1) 

 Corey, Sheffield (0424-1) 

 Cummings, Frank (0709-2) 

 Cusidor, Teresa (0127-5) 

 Davis, S. K. (0412-1) 

 Dolben, Hollis (0627-3) 

 Draper, Lonnie M. (0511-2) (0511-5) 

 Dulicai, Linda (0697-1) 

 DuPriest, William Robert (0093-3) 

 Duran-Pinzon, Jaime (0243-2) 

 Earnshaw, Shinann (0326-1) 

 Engelberg, Jodi (0004-3) 

 Ercole, Steven (0170-1) 

Appendix E NUREG–2176 E-56 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Faber, Davenie (0006-2) 

 Farnsworth, Stu (0464-1) 

 Forbes, J. (0189-1) 

 Fray, Antje (0648-1) 

 Fulks, Anna Louise (0250-9) 

 G., Ambriel (0561-1) (0561-4) 

 Gavel, Deborah (0098-2) 

 Gibson, David (0324-1) 

 Glasshof, Wendy (0587-2) 

 Goldberg, Laura (0568-1) 

 Gomez, Lissett (0030-2) 

 Grant, Randy (0146-2) 

 Griffith, Ed and Harriet (0366-10) 

 Gross, Gary (0017-1) 

 Haffmans, Edmund (0371-4) 

 Hardin, Lillian (0455-2) 

 Hartmann, Donald (0657-2) 

 Hicklin, Mary (0431-2) 

 Hogle, Dick (0293-1) 

 Jackalone, Frank (0288-15) 

 Jacobs, Lee (0677-2) (0677-4) (0677-8) (0677-9) 

 Jacobs, Leslye (0634-2) 

 Jens-Rochow, Steve (0666-2) 

 Jezierski, Elisabeth (0302-2) 

 Joannou, Jr., Benjamin (0023-1) (0643-2) 

 Juras, Randy (0419-1) 

 Khajeh-Noori, Jeri (0609-1) 

 Klopfer, Carol (0677-2) (0677-4) (0677-8) (0677-9) 

 Koenigsberg, Linda (0721-26-5) 

 Larsen, Shannon (0255-1) 

 Lettieri, Tammy (0259-2) 

 Lundholm, Mark (0309-1) 

 Mahoney, Stephen (0288-15) 

 Matthews, Debbie (0288-15) 

 Mccroskey, Carol (0530-1) 

 McDaniel, Diana (0203-1) 

 Miller, Nyana (0626-2) 

 Moll, Wolfgang (0632-3) 

 Moore, Linda (0199-1) 

 Morgan, Carol (0387-1) 

 Mosca-Clark, Vivianne (0442-1) 

 Mosher, Paul (0249-4) 

 Myers, B. J. (0256-1) 

 Neal, Kevin (0027-2) 

 Nelson, Wendy (0468-1) 

 O'Brien, Lance (0029-1) 

 Oliva, Vivian (0349-5) 

 Olson, Diane (0432-1) 

 Padron-Delgado, Blanca (0257-2) 

Appendix E October 2016 E-57 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Philips, Sally B. (0337-1)

 Pikus, Barbara (0303-1)

 Polk, J. D. (0369-1)

 Provost, Allan (0339-3)

 Punnett, Daniela (0553-2)

 Rapuano, Shannon (0594-3)

 Reed, Jennifer (0496-1)

 Reid, Sarah (0201-2) (0201-4)

 Rhodes, Karen (0140-1)

 Richardson, Don (0296-1)

 Rodriguez, Jose Javier (0721-1-3)

 Roehl, Richard Ralph (0513-2)

 Roff, Rhonda (0288-15)

 Roos, Monica (0052-1)

 Rosenberry, Casara (0367-1)

 Royce, M. (0353-1)

 Schwartz, Matthew (0723-9-6)

 Scott, John (0288-15)

 Shahsavar, Mehran (0012-1)

 Shlackman, Jed (0356-6)

 Silver, William (0021-1)

 Simmerman, Scott (0480-2)

 Smith, Leigh Emerson (0020-1) (0020-3)

 Socie, Robert (0521-1)

 Stamps, Gail (0586-1)

 Star, Priscilla (0723-3-4) (0723-3-6)

 Szabo, Liz (0481-1) (0481-2)

 Teas, Jim (0288-15) (0723-5-2) (0723-5-3)

 Thompson, Muhammad (0683-1)

 Ullman, John (0721-30-2) (0721-30-4)

 Ullman, Jonathan (0288-15)

 Van Leer, Sam (0252-1) (0252-19)

 Vayu, Satya (0370-5)

 Veit, Eberhard (0607-1)

 Vorachek, Mary (0291-1)

 Ward, Richard (0348-1)

 Westaway, Katharine (0014-1)

 White, Barry (0100-1)

 White, Barry J. (0598-4)

 Whitlock, Catherine (0701-1)

 Wilansky, Laura Sue (0078-2) (0721-28-3)

 Williams, Penelope (0576-1)

 Zerulla, Tanja (0214-1)

 Zhivelev, Leon (0656-1)

 Zimmermann, John (0304-1)

 Zook, Caryl (0589-1)

 Zuniga, Family (0272-1)

Opposition-Plant  Brown, Bradford (0667-2)

 Buechler, Jerry (0718-4)

Appendix E NUREG–2176 E-58 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Buyea, Thomas (0505-2) 

 Cava, Daniella Levine (0172-7) 

 Daniels, Bonnie (0341-2) 

 Gomez, Albert (0721-34-1) 

 Logan, Brian (0072-1) 

 Lopez, Josie (0284-4) 

 Nelson, Joyce E. (0149-5) 

 Neway, Roberta (0057-2) 

 Reynolds, Laura (0721-10-1) 

 Roberts, Linda (0096-1) 

 Roedel, Kitty (0055-2) 

 Sanchez, Sergio and Irma (0660-3) 

 Tamargo, Jorge J. (0494-2) 

 Trencher, Ruth (0115-2) (0115-9) 

 Van Leer, Sam (0252-17) 

 White, Barry J. (0721-12-1) 

Outside ScopeEmergency 

Preparedness 

 Anonymous, Anonymous (0336-3) 

 Berendsohn, Catherine (0723-11-8) 

 Bethune, David (0615-2-14) (0615-3-7) (0615-3-9) 

 Commenters, Multiple (0044-6) 

 Dwyer, John P. (0264-1) (0673-1) 

 Johannsen, Christian (0045-2) 

 Lee, Nancy (0373-5) (0373-13) 

 Lettieri, Tammy (0259-6) 

 Martin, Drew (0641-6) 

 McColgan, Robert (0722-15-3) (0722-15-4) 

 Meyer-Steele, Shawn (0187-2) 

 Mueller, Heinz J. (0617-4-15) 

 Orzechowicz, Holly (0263-4) 

 Pareto, Rolando and Marlene (0040-3) 

 Philips, Sally B. (0337-5) 

 Robbin, Valerie (0223-2) 

 Roedel, Kitty (0055-8) 

 Samole, Sharon (0234-1) 

 Van Leer, Sam (0252-8) 

Outside ScopeMiscellaneous  Abalos, Jessica (0659-1) 

 Almer, Anessa (0712-5) 

 Anderson, Vaughn (0560-1) 

 Anonymous, Anonymous (0645-3) 

 Batista, Carlos (0685-12) (0685-13) 

 Beckman, Yvonne and Douglas (0060-6) 

 Berendsohn, Catherine (0723-11-10) 

 Black, Mary Beth (0107-1) 

 Bofill, Beatriz (0235-1) 

 Boling, Steve (0723-7-2) 

 Brown, Robert (0383-1) 

 Brumleve, Charles (0502-1) 

 Caswell, Gail (0465-1) 

 Cusidor, Teresa (0127-7) 

Appendix E October 2016 E-59 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Daniels, Bonnie (0341-5) 

 Dwyer, John P. (0264-5) (0673-5) 

 Eastman, John (0721-24-5) 

 Ehrmann, Nancy (0454-1) 

 Family, Manzi (0593-2) 

 Finver, Jody (0008-11) 

 Fitzpatrick, Deirdre (0389-1) 

 G., Ambriel (0561-3) 

 Geiger, Marcia (0312-1) 

 Gomez, Albert (0721-34-4) (0721-34-6) 

 Harper, Diane (0583-1) 

 Harris, Walter (0721-6-4) 

 Harrison, J. M. M. (0508-3) 

 Henry, Jim (0723-12-10) (0723-12-11) 

 Jennings, Cara (0323-3) 

 Larsen, Shannon (0610-1) 

 Lenz, Andrew (0470-2) 

 Oria, Jordan (0171-1) 

 Pew, Don (0500-1) 

 Quarles, Greyson (0085-1) 

 Schlackman, Mara (0721-32-2) 

 Schwartz, Matthew (0723-9-4) 

 Shark, Jason (0120-2) 

 Shifflett, Jr., James E. (0687-1) 

 Timberlake, Ralph (0282-2) 

 Van Pelt, Jason (0300-2) 

 Wilansky, Laura Sue (0721-28-1) 

 Zhivelev, Leon (0656-3) 

Outside Scope-NRC 

Oversight  Batista, Carlos (0685-8) 

 Bethune, David (0615-3-10) 

 Boling, Steve (0723-7-3) 

 Garmon, Toni (0477-1) 

 Gomez, Albert (0721-34-7) (0721-34-8) (0721-34-9) 

 Schwartz, Matthew (0723-9-21) 

 Smith, David W. (0051-2) 

 Wallace, Otis (0723-1-4) 

Outside ScopeSafety  Anonymous, Anonymous (0333-1) (0333-2) 

 Bethune, David (0615-1-1) (0615-1-16) (0615-1-17) (0615-1-18) (0615-2-

1) (0615-2-2) (0615-2-3) (0615-2-4) (0615-2-5) (0615-2-6) (0615-2-8) 

(0615-2-9) (0615-2-10) (0615-2-11) (0615-2-12) (0615-2-13) (0615-2-15) 

(0615-2-16) (0615-2-18) (0615-2-20) (0615-2-21) (0615-2-23) (0615-2-28) 

(0721-23-1) (0721-23-3) (0721-23-4) (0721-23-6) (0721-23-10) 

 Cleland, Noel (0288-6) 

 Commenters, Multiple (0044-4) (0240-5) 

 Delateur, Marc (0230-1) 

 Dwyer, Karen (0674-3) 

 Finver, Jody (0008-4) 

 Hyams, Charles (0213-3) 

 Jackalone, Frank (0288-6) 

Appendix E NUREG–2176 E-60 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Keating, Tim (0545-4) 

 Lamb, Deborah S. (0070-3) 

 Lee, Nancy (0373-10) 

 Mahoney, Stephen (0288-6) 

 Martin, Drew (0641-5) (0721-13-1) 

 Matthews, Debbie (0288-6) 

 Mendez, Victoria (0721-5-3) (0721-5-6) 

 Mueller, Heinz J. (0617-2-2) 

 Nelson, Joyce E. (0149-12) 

 Orzechowicz, Holly (0263-8) 

 Pontier, Christine Hughes (0126-2) 

 Rhodes, Karen (0140-2) 

 Roff, Rhonda (0288-6) 

 Scott, John (0288-6) 

 Star, Priscilla (0723-3-2) 

 Swenson, Cyndee (0722-17-2) 

 Tacher, Ian (0001-1) 

 Tamburr, C. (0655-1) 

 Teas, Jim (0288-6) 

 Ullman, Jonathan (0288-6) 

Outside ScopeSecurity and 

Terrorism 

 Anonymous, Anonymous (0333-3) 

 Bethune, David (0615-2-7) (0615-2-25) 

 Keating, Tim (0545-5) 

 Koenigsberg, Linda (0721-26-6) 

 Mauri, Tom (0132-2) 

 Provost, Allan (0339-4) 

 Riccio, Jim (0716-11) 

 Shlackman, Jed (0356-5) 

Process-ESP-COL  Barczak, Sara (0112-9) 

 Bethune, David (0615-1-6) 

 Boone, James (0533-1) 

 Daly, Meg (0076-5) 

 Harris, Walter (0721-6-1) 

 Herrera, Luis (0721-33-2) 

 Keating, Tim (0545-8) 

 Kipnis, Dan (0722-2-4) 

 Lerner, Cindy (0145-1) 

 Lopez, Jaclyn (0113-1-1) 

 Maher, William (0619-1-1) 

 Malefatto, Alfred (0211-3) 

 McLaughlin, Caroline (0113-1-1) 

 Miami, City (0456-26) 

 Mueller, Heinz J. (0617-1-1) 

 Reynolds, Laura (0113-1-1) 

 Riccio, Jim (0716-4) (0716-5) (0716-13) 

 Ritz, David (0208-4) 

 Schwartz, Matthew (0113-1-1) (0721-22-2) (0721-22-19) (0723-9-22) 

 Silverstein, Rachel (0113-1-1) 

 Star, Priscilla (0723-3-1) 

Appendix E October 2016 E-61 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Stoddard, Philip K. (0106-1) (0721-2-16) 

 White, Barry J. (0598-1) 

Process-NEPA  Austin, Stan (0622-1-1) (0622-2-6) (0622-2-16) (0623-1) (0623-10) (0623-

11) (0623-13) 

 Ball, Cheri (0472-4) 

 Bethune, David (0615-1-2) (0615-1-7) 

 Hanna, Jane (0588-5) 

 Hull, Meagan (0344-3) 

 Lopez, Jaclyn (0113-1-2) (0113-2-13) 

 Maher, William (0619-3-1) 

 McLaughlin, Caroline (0113-1-2) (0113-2-13) 

 Mueller, Heinz J. (0617-1-5) (0617-1-34) 

 Regalado, Tomas (0515-1) (0721-4-1) 

 Reynolds, Laura (0113-1-2) (0113-2-13) 

 Riccio, Jim (0716-1) (0716-2) (0716-3) (0716-12) 

 Ritz, David (0208-10) 

 Saporito, Thomas (0010-3) (0010-7) (0010-8) 

 Schwartz, Matthew (0113-1-2) (0113-2-13) (0721-22-1) (0723-9-8) 

 Silverstein, Rachel (0113-1-2) (0113-2-13) 

Site Layout and 

Design  Kuraza, Devon (0721-15-12) 

 Maher, William (0619-1-14) (0619-2-23) (0619-3-17) (0619-3-18) (0619-3-

19) (0619-3-20) (0619-3-21) 

Socioeconomics  Almirola, Alejandro (0721-31-2) (0721-31-9) 

 Austin, Stan (0622-1-11) (0622-1-13) (0622-1-30) 

 Bazzone, Barbara (0159-5) 

 Beckman, Yvonne and Douglas (0060-5) 

 Benson, Mary (0081-4) (0081-5) 

 Boyce, Sheila (0091-3) 

 Brito, Rosa (0723-10-1) (0723-10-4) 

 Chiszar, Benjamin J. (0677-6) 

 Cleland, Noel (0207-6) (0288-11) 

 Daly, Meg (0076-2) 

 Dudley, Dwight (0254-6) 

 Duquette, Bill (0722-13-3) (0722-13-4) 

 Garcia, Javier (0721-20-2) 

 Goldmeier, Barry (0015-4) (0015-7) (0015-11) 

 Henry, Jim (0723-12-2) (0723-12-8) 

 Hubbard, Stanley S. (0680-3) 

 Hudak, Jill (0722-19-2) 

 Infante, Jose Renee (0722-12-1) 

 Jackalone, Frank (0288-11) 

 Jacobs, Lee (0677-6) 

 Kaul, Devika (0722-14-5) 

 Klopfer, Carol (0677-6) 

 Knowles, Yvonne (0722-11-1) 

 Kuraza, Devon (0721-15-9) 

 Lawrence, Theresa (0580-2) 

 Lerner, Cindy (0254-6) 

 Lopez, Jaclyn (0113-1-12) 

Appendix E NUREG–2176 E-62 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Macher, Nathan (0378-4) 

 Maher, William (0619-1-6) (0619-2-21) (0619-2-24) (0619-2-25) (0619-5-

19) 

 Mahoney, Stephen (0288-11) 

 Martin, Patrick (0721-21-2) 

 Matthews, Debbie (0288-11) 

 McCall, Eric (0056-3) 

 McDuffie, Stephen (0723-8-2) 

 McLaughlin, Caroline (0113-1-12) 

 Miami, City (0456-2) 

 Mueller, Heinz J. (0617-3-1) 

 Murphy, Mike (0723-6-2) 

 Nelson, Joyce E. (0149-9) 

 Norman, Ronald (0358-2) 

 Regalado, Tomas (0254-6) 

 Reynolds, Laura (0113-1-12) 

 Rifkind, David (0721-16-5) 

 Riley, Bill (0721-19-3) (0722-9-3) (0722-9-4) (0723-14-4) 

 Robertson, Alyce (0117-3) 

 Rodriguez, Jose Javier (0675-4) 

 Rodriguez, Manuel J. (0721-27-2) 

 Roedel, Kitty (0055-10) 

 Roff, Rhonda (0288-11) 

 Schwartz, Matthew (0113-1-12) (0721-22-6) (0723-9-7) (0723-9-19) 

 Scott, John (0288-11) 

 Shlackman, Mara (0246-6) 

 Sifko, Basilio (0408-7) 

 Silva, Nicolas (0722-5-1) 

 Silverstein, Rachel (0113-1-12) (0722-7-7) 

 Simon, Gary P. (0050-2) 

 Simpson, Chris (0723-13-2) 

 Skove, Ellen H. (0081-4) (0081-5) 

 Stanley, Joyce (0227-15) 

 Stoddard, Philip K. (0106-3) (0106-13) (0254-6) (0721-2-13) 

 Teas, Jim (0288-11) 

 Tompkins, Constance (0081-4) (0081-5) 

 Trowbridge, Mark (0723-2-7) (0723-2-9) 

 Ullman, John (0721-30-11) 

 Ullman, Jonathan (0288-11) 

 Wallace, Otis (0723-1-5) (0723-1-7) 

 White, Barry J. (0721-12-5) (0721-12-11) 

 Wilansky, Laura Sue (0078-12) (0721-28-13) 

Support-Licensing 

Action  Batista, Carlos (0685-4) (0685-7) (0685-9) (0685-10) 

 Boling, Steve (0723-7-5) 

 Brito, Rosa (0723-10-3) (0723-10-6) 

 Carpenter, Rory (0694-1) (0694-2) (0694-4) 

 Christie, Grazie (0013-2) 

 Duquette, Bill (0722-13-2) (0722-13-9) 

 England, Peter (0722-10-4) 

Appendix E October 2016 E-63 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Garcia, Javier (0721-20-1) 

 Goldmeier, Barry (0015-9) (0015-10) (0015-14) (0015-16) (0015-17) 

 Hamilton, Brent (0002-1) 

 Hubbard, Stanley S. (0680-1) 

 Hudak, Jill (0038-1) 

 Infante, Jose Renee (0722-12-2) 

 Jackson, Donald L. (0286-1) (0286-3) 

 Knowles, Yvonne (0722-11-2) 

 Kuraza, Devon (0721-15-14) 

 Lamb, Deborah S. (0070-1) 

 Larrabee, Laura (0035-1) 

 Macher, Nathan (0378-1) 

 Martin, Allan (0722-6-1) 

 Massa, Arturo (0018-1) 

 McDuffie, Stephen (0723-8-7) 

 Moo, Patrick (0722-4-1) 

 Pheil, Edward (0707-1) 

 Porter, Jeff (0722-1-3) 

 Riley, Bill (0721-19-1) (0721-19-4) (0722-9-1) (0722-9-5) (0722-9-7) 

(0722-9-12) (0723-14-1) (0723-14-5) 

 Roberts, Kenneth (0575-1) 

 Rodriguez, Manuel J. (0721-27-4) 

 Rossin, A. David (0345-1) 

 Rowe, James (0011-1) 

 Simpson, Chris (0723-13-1) (0723-13-3) 

 Slonim, Roberta (0016-1) 

 Tulenko, James (0375-1) (0375-2) 

 Wallace, Otis (0723-1-8) 

 Williams, Paul (0041-2) (0069-1) 

Support-Licensing 

Process  Berendsohn, Catherine (0723-11-1) 

 Chatterton, Andrew (0722-3-2) 

 Duquette, Bill (0722-13-1) 

 England, Peter (0722-10-1) 

 McDuffie, Stephen (0723-8-5) 

 Schwartz, Matthew (0723-9-1) 

Support-Nuclear 

Power  Brito, Rosa (0723-10-5) 

 Chatterton, Andrew (0722-3-1) 

 Christie, Grazie (0013-1) 

 Duquette, Bill (0722-13-6) 

 Glynn, Simon (0111-1) (0111-2) (0111-3) 

 Goldmeier, Barry (0015-3) (0015-6) 

 Jackson, Donald L. (0286-2) 

 Kuraza, Devon (0721-15-3) (0721-15-5) (0721-15-6) (0721-15-8) (0721-

15-11) 

 Macher, Nathan (0378-3) (0378-5) (0378-6) 

 Martin, Patrick (0721-21-1) (0721-21-3) 

 McDuffie, Stephen (0723-8-1) 

 Moo, Patrick (0722-4-2) (0722-4-3) 

 Mulet, Tomas (0123-1) 

Appendix E NUREG–2176 E-64 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Murphy, Mike (0723-6-1) 

 Pheil, Edward (0707-3) (0707-5) 

 Riley, Bill (0723-14-3) 

 Roberts, Kenneth (0575-2) 

 Rodriguez, Manuel J. (0721-27-3) 

 Silva, Nicolas (0722-5-3) 

 Streit, Christopher V. (0075-1) 

 Trowbridge, Mark (0723-2-3) 

 Wallace, Otis (0723-1-2) 

Support-Plant  Batista, Carlos (0685-5) 

 Bertelson, Bob (0723-15-1) (0723-15-4) 

 Berzowski, Bill (0722-18-1) 

 Boling, Steve (0723-7-1) (0723-7-4) 

 Brito, Rosa (0723-10-2) 

 Duquette, Bill (0722-13-5) (0722-13-8) 

 England, Peter (0722-10-3) 

 Goldmeier, Barry (0015-2) 

 Hamilton, Brent (0002-2) 

 Kuraza, Devon (0721-15-1) (0721-15-13) 

 Larrabee, Laura (0035-2) 

 McDuffie, Stephen (0723-8-6) 

 Murphy, Mike (0723-6-4) 

 Porter, Jeff (0722-1-2) 

 Riley, Bill (0721-19-2) (0722-9-2) (0722-9-6) (0722-9-11) (0723-14-2) 

 Trowbridge, Mark (0723-2-1) (0723-2-4) (0723-2-10) 

 Wallace, Otis (0723-1-3) 

 Wasilewski, Joe (0721-14-1) 

Transportation  Goldmeier, Barry (0015-5) 

 Maher, William (0619-1-11) (0619-5-2) (0619-5-3) (0619-5-4) (0619-5-5) 

(0619-5-6) (0619-5-10) 

Uranium Fuel Cycle  Anonymous, Anonymous (0551-2) (0603-6) (0644-4) (0645-2) 

 Barczak, Sara (0112-8) 

 Bethune, David (0615-1-10) 

 Bloom, Justin (0253-5) 

 Brandariz, Anita (0529-2) 

 Brexel, Sr., Charles (0592-10) 

 Brumleve, Charles (0502-2) 

 Campbell, Cara (0253-5) 

 Carlson, John (0158-1) (0158-2) 

 Causey, Charlie (0253-5) 

 Cavros, George (0253-5) 

 Chenoweth, Mike (0253-5) 

 Chrissos, H. L. Chris (0164-3) 

 Commenters, Multiple (0104-5) (0240-7) 

 Dahlgren, Shelley (0434-1) 

 Daly, Meg (0253-5) 

 Datz, Amy (0621-1) 

 Dolben, Hollis (0627-2) 

 Dudley, Dwight (0254-4) 

Appendix E October 2016 E-65 NUREG–2176
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Dwyer, John P. (0264-2) (0264-7) (0673-2) (0673-7) 

 Dwyer, Karen (0674-5) 

 Eastman, John (0721-24-1) 

 England, Margaret (0253-5) 

 Felinski, Julee (0625-2) 

 Fischer, Antoinette (0365-8) 

 Fuller, Manley (0253-5) 

 G., Ambriel (0561-2) 

 Grant, Randy (0146-3) 

 Griffith, Ed and Harriet (0366-11) 

 Gross, Cheryl A. (0463-4) 

 H., Pat (0550-3) 

 Haffmans, Edmund (0371-3) 

 Hartmann, Donald (0657-3) 

 Hicklin, Mary (0431-1) 

 Hurley, Paula (0362-4) 

 Joannou, Jr., Benjamin (0643-5) 

 Jones, George L. (0253-5) 

 Kassel, Kerul (0676-10) 

 Keller, Alan (0253-5) 

 Lebatard, David (0192-6) 

 Ledbetter, Carolyn (0406-1) 

 Leibowitz, Arthuir (0404-1) 

 Lerner, Cindy (0254-4) 

 Lindsey, Jerrie (0245-4) 

 Lucas, Carmen (0141-4) 

 Maher, William (0619-5-1) 

 Martin, Drew (0253-5) 

 Mayer, Doug (0129-3) 

 McColgan, Robert (0722-15-1) 

 McLaughlin, Caroline (0253-5) 

 Mikowski, George (0382-1) 

 Moll, Wolfgang (0632-2) 

 Otto, Peter (0509-1) 

 Regalado, Tomas (0254-4) 

 Reid, Sarah (0201-3) 

 Reynolds, Laura (0253-5) 

 Rush, Charlene (0448-1) 

 Saporito, Thomas (0010-9) 

 Schlackman, Mara (0721-32-7) (0721-32-8) 

 Schoene, William (0037-1) 

 Schwab, Roy (0579-3) 

 Shark, Jason (0120-3) 

 Sharp, Andrea Heuson (0210-6) 

 Shlackman, Jed (0356-14) 

 Shlackman, Mara (0246-4) 

 Silverstein, Rachel (0253-5) 

 Stewart, Berkeley (0273-1) 

 Stoddard, Philip K. (0254-4) 

Appendix E NUREG–2176 E-66 October 2016
Table E-2. (contd)

Comment Category Commenter (Comment ID)

 Tweeton, Tanya (0340-5) 

 Vayu, Satya (0370-13) 

 Veijalainen, Pertti (0467-1) 

 Weber, Zorina (0469-1) 

 White, Paton (0253-5) 

 Williams, Elinor (0253-5) 

E.2 Comments and Responses 

Table E-3 is a list of the comment categories included in this appendix in the order in which they 

appear. This section presents the comments and responses organized by topic category. 

When the comments resulted in a change in the text of the draft EIS, the corresponding 

response refers the reader to the appropriate section of the EIS where the change was made. 

Throughout the final EIS, with the exception of this new Appendix E, revisions to the text (other 

than editoral) from the draft EIS are indicated by vertical lines (change bars) in the margin 

beside the text. Additionally, for purposes of this review, DEIS and FEIS are abbreviations for 

draft EIS and final EIS. 

Table E-3. Comment Categories in Order of Presentation 

E.2.1 Comments Concerning Process - COL ..................................................................... E-70 

E.2.2 Comments Concerning Process - NEPA ................................................................... E-76 

E.2.3 Comments Concerning Site Layout and Design ........................................................ E-85 

E.2.4 Comments Concerning Land Use - Site and Vicinity ................................................. E-87 

E.2.5 Comments Concerning Land Use - Transmission Lines ........................................... E-92 

E.2.6 Comments Concerning Geology .............................................................................. E-111 

E.2.7 Comments Concerning Hydrology - Surface Water ................................................. E-117 

E.2.8 Comments Concerning Hydrology - Groundwater ................................................... E-182 

E.2.9 Comments Concerning Ecology - Terrestrial ........................................................... E-239 

E.2.10 Comments Concerning Ecology - Aquatic ............................................................... E-280 

E.2.11 Comments Concerning Socioeconomics ................................................................. E-306 

E.2.12 Comments Concerning Environmental Justice ........................................................ E-323 

E.2.13 Comments Concerning Historic and Cultural Resources ........................................ E-325 

E.2.14 Comments Concerning Meteorology and Air Quality ............................................... E-331 

E.2.15 Comments Concerning Health - Nonradiological ..................................................... E-335 

E.2.16 Comments Concerning Health - Radiological .......................................................... E-340 

E.2.17 Comments Concerning Accidents - Severe ............................................................. E-351 

E.2.18 Comments Concerning the Uranium Fuel Cycle ..................................................... E-370 

E.2.19 Comments Concerning Transportation .................................................................... E-379 

Appendix E October 2016 E-67 NUREG–2176
E.2.20 Comments Concerning Decommissioning ............................................................... E-381 

E.2.21 Comments Concerning Cumulative Impacts ........................................................... E-382 

E.2.22 Comments Concerning the Need for Power ............................................................ E-383 

E.2.23 Comments Concerning Alternatives - No-Action ..................................................... E-392 

E.2.24 Comments Concerning Alternatives - Energy .......................................................... E-393 

E.2.25 Comments Concerning Alternatives - System Design ............................................. E-429 

E.2.26 Comments Concerning Alternatives - Sites ............................................................. E-429 

E.2.27 Comments Concerning Benefit-Cost Balance ......................................................... E-446 

E.2.28 Comments Concerning Climate Change ................................................................. E-452 

E.2.29 General Comments in Support of the Licensing Action ........................................... E-454 

E.2.30 General Comments in Support of the Licensing Process ........................................ E-460 

E.2.31 General Comments in Support of Nuclear Power .................................................... E-461 

E.2.32 General Comments in Support of the Existing Plant or the Applicant ..................... E-465 

E.2.33 General Comments in Opposition to the Licensing Action ...................................... E-468 

E.2.34 General Comments in Opposition to the Licensing Process ................................... E-515 

E.2.35 General Comments in Opposition to Nuclear Power ............................................... E-516 

E.2.36 General Comments in Opposition to the Existing Plant or the Applicant ................. E-530 

E.2.37 Comments Concerning Issues Outside Scope - Emergency Preparedness ........... E-532 

E.2.38 Comments Concerning Issues Outside Scope - Miscellaneous .............................. E-535 

E.2.39 Comments Concerning Issues Outside Scope - NRC Oversight ............................. E-542 

E.2.40 Comments Concerning Issues Outside Scope - Safety ........................................... E-543 

E.2.41 Comments Concerning Issues Outside Scope - Security and Terrorism ................ E-554 

E.2.42 General Editorial Comments .................................................................................... E-555 

E.2.1 Comments Concerning Process - COL 

Comment: At the very least the United States Nuclear Regulatory Commission, the agency 

that will be licensing this project, should complete a supplementary environmental impact 

statement to more thoroughly review these matters and the portions of the project that are 

related to the reactor site, its backup cooling systems, and their adverse impacts on water 

quality. (0076-5 [Daly, Meg])

Comment: The Turkey Point 6 & 7 Draft EIS [DEIS] has serious omissions in analysis that 

make it impossible to determine the likely effects of plant operation on the environment. (0106-1

[Stoddard, Philip K.])

Comment: We ask that you address these concerns and take the following into consideration 

for a sorely needed supplemental EIS[.] (0208-4 [Ritz, David])

Comment: It is clear from the actions of the NRC's poorly-informed staff that due diligence was 

not performed in researching and writing the draft EIS for Turkey Point 6 and 7. The NRC has 

Appendix E NUREG–2176 E-68 October 2016
failed to meet its obligation to protecting people and the environment by ignoring or failing to 

discover crucial information about the environmental and health impacts of siting two new 

nuclear plants alongside two existing plants and near to such a large, water-starved population. 

In addition to the comments I presented orally last night, I add my voice to the many others at 

the meeting who demand a revised and complete Environmental Impact Statement which 

address the issues outlined in this letter. (0615-1-6 [Bethune, David])

Comment: So that's ten different points in which I believe the Environmental Impact Statement 

Draft is incomplete and it may require a supplemental draft in order to address these points.

(0721-2-16 [Stoddard, Philip K.])

Comment: At any rate, we demand a supplemental EIS from this agency to cover all the 

unanswered questions that everybody is bringing up and we basically say this is the wrong 

project in the wrong location. Let's move on to something that's going to work. (0721-22-19

[Schwartz, Matthew])

Comment: They haven't done that. It's not in the Draft. And just at the outset I'm saying, I'm 

requesting the agency undertake a supplemental EIS to deal with many of the unanswered 

questions that have been brought up today and which will be brought up in further comments.

(0721-22-2 [Schwartz, Matthew])

Comment: I'm not against nuclear power, I'm against the EIS the way it's written here without 

taking this into consideration seriously. And I really hope that if we're going to spend $30 billion 

that we have to look at getting our money's worth for it. (0722-2-4 [Kipnis, Dan])

Comment: This application should be rejected. At the very least a supplemental EIS needs to 

be written to address all of these concerns that people are raising and do not rush into a project 

of this caliber. (0723-9-22 [Schwartz, Matthew])

Response: The comments state that the draft EIS is incomplete and request the NRC to 

supplement it. To the extent the commenters identify specific environmental topics as 

incompletely discussed in the DEIS in support of the request for supplementation, the NRC staff 

addresses such comments under the associated subject matter headings in this response 

document (Appendix E to the final EIS). To the extent the NRC staff agrees with the 

commenters’ specific comments, the staff has so indicated in its responses in the specific 

subject matter sections below; the staff has also indicated which of those comments warranted 

inclusion of additional or modified discussion in the final EIS. Comments not identifying specific 

information related to environmental topics did not provide any significant new information not 

considered by the review team in the draft EIS, and therefore did not identify any reason to 

supplement the DEIS. 

One of the purposes of circulating a draft EIS for public comment is to obtain additional insight 

into the environmental issues evaluated in the draft EIS and augment the EIS discussion as 

warranted. However, the mere fact that a final EIS includes additional or modified information 

as a result of public comments does not necessarily indicate that a draft EIS requires 

supplementation. 

Specifically, the NRC regulations outlined in 10 CFR 51.72 describe when the staff should 

produce a supplement to a draft EIS. According to 10 CFR 51.72, the NRC staff will issue a 

supplement to an EIS if: (1) there are substantial changes in the proposed action that are 

relevant to environmental concerns, or (2) there are significant new circumstances or 

Appendix E October 2016 E-69 NUREG–2176
information relevant to the environmental concerns and bearing on the proposed action or its 

impacts. For the Turkey Point COL draft EIS, the staff has determined there have been no 

substantial changes to the proposed action in the Florida Power & Light (FPL) COL relevant to 

environmental concerns or significant new information associated with environmental issues 

that would trigger a supplement. Accordingly, supplementation is not required, and the staff has 

determined not to issue a supplement to the draft EIS. 

Comment: Please do not reward, poorly thought out proposals because that is your job (at the 

NRC). (0545-8 [Keating, Tim])

Response: The staff has independently verified information in the applicant’s Environmental 

Report (ER; Part 3 of the Application dated October 29, 2014 (ML14311A715)), and has 

performed literature searches and field studies in doing so. The draft EIS reflects the staff 

independent evaluation of the environmental effects of the proposed action. The comment did 

not warrant any change to the final FEIS. 

Comment: On behalf of the National Parks Conservation Association, Center for Biological 

Diversity, Miami Waterkeeper, South Florida Wildlands Association, and Tropical Audubon 

Society, we thank you for the opportunity to comment on the Draft Environmental Impact 

Statement (DEIS) for Combined Licenses (COLs) for Turkey Point Units 6 & 7, released by the 

Nuclear Regulatory Commission (NRC) under Docket ID NRC-2009-0337 and as publicly 

noticed by the U.S. Army Corps of Engineers (Corps), 2009-02417 (SP-MLC). We are deeply 

concerned about the potential wide-ranging environmental impacts to regional water resources, 

national parks, wildlife, and sensitive wetlands resulting from the construction and operation of 

Units 6 & 7 and ancillary facilities. (0113-1-1 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] 

[Schwartz, Matthew] [Silverstein, Rachel])

Comment: ACI appreciates your consideration of the foregoing comments, and we look 

forward to the final EIS adequately addressing the issues raised. (0211-3 [Malefatto, Alfred])

Comment: I'm writing this letter because this issue is important to me. I hope it is to you as 

well. (0533-1 [Boone, James])

Comment: The DEIS provides useful information and covers a variety of complex 

environmental issues related to the COL process for the proposed new units. We appreciate 

your coordination and outreach to us to discuss the numerous technical issues and our 

environmental concerns regarding this project, and your response to our request for additional 

review time for this DEIS. We look forward to working with the NRC to reduce this project's 

impacts, and to provide environmental protection for future generations. We request that the 

FEIS address our concerns, which are detailed in the enclosed comments. (0617-1-1 [Mueller, 

Heinz J.])

Comment: FPL appreciates the opportunity to review and provide comments on the DEIS to 

assist the Commission and U. S. Army Corps of Engineers in disclosing an accurate and 

complete evaluation of potential impacts in the final EIS (FEIS). FPL recommends that the 

inconsistencies identified in the attached comments be reconciled in the FEIS. Many comments 

can be categorized as (1) significant overestimation of environmental impacts (such as the 

statement that FPL seeks approval to discharge fill into 1,000 acres of federal jurisdictional 

wetlands or describing impacts to the entirety of a pipeline or transmission corridor, when only a 

relatively narrow right-of-way would ultimately be affected), (2) minor discrepancies between 

values in the DEIS and the values in the cited references, and (3) overlooking updates to FPL's 

Appendix E NUREG–2176 E-70 October 2016
application documents, many of which result from binding Conditions of Certification recently 

imposed under the Florida Power Plant Siting Act process. Given the NRC's delayed comment 

closing deadline of July 17, FPL hopes sufficient, timely resources are engaged to address all 

comments and maintain the NRC's Phase 3 milestone of February 2016 for publication of the 

FEIS, since publication of the FEIS is a prerequisite for permitting activities required before FPL 

can proceed with the project. (0619-1-1 [Maher, William])

Response: These comments express support for the NEPA review process for eliciting and 

receiving comments on the draft EIS as implemented by the NRC. To the extent the comments 

identified specific information regarding the environmental impacts of the proposed action, that 

information is discussed in the comment responses on specific impacts below. No changes 

were made in response to these comments. 

Comment: We believe it is important to mention problems experienced with public accessibility 

and public notifications associated with the release of the DEIS and related public hearings. 

Initially there were discrepancies in the meeting times for the afternoon public meeting in 

Homestead, Florida on April 23, 2015 -- both on the NRC's website and in NRC public meeting 

notices. There were also different email and mailing addresses to submit public comments to 

the NRC as listed in separate NRC public notices that were also different than what was listed in 

the Federal Register Notice. There was also a problem with the DEIS itself in that hyperlinks 

included in the DEIS were not active, yet appeared to be resulting in the reader receiving an 

"Authentication Required" error message. In terms of the inactive hyperlinks, we were told that it 

was a publication problem that occurred during the printing process, that the links were 

supposed to be removed before printing and that this would be resolved when the FEIS is 

issued. All of this caused confusion among the public and SACE staff spent significant time 

researching and bringing this to the attention of NRC staff. Though NRC staff were cordial and 

prompt in responding to our concerns, these discrepancies should not have happened. We 

hope that in the future, a more thorough review process can occur before issuing such important 

public notices. (0112-9 [Barczak, Sara])

Comment: EVERY SINGLE FOOTNOTE IN THE DEIS IS HIDDEN BEHIND A FIREWALL! 

[FIGURE: Authentication Required; The server https://earrth.pnnl.gov:443 requires a 

username and password. User Name: Password: Log In Cancel] (0716-4 [Riccio, Jim])

Comment: NEPA requires agencies to ensure professional and scientific integrity by setting 

forth the methodologies used and making "explicit reference by footnote [to] the scientific and 

other sources relied upon for conclusions in the statement." (Earth Island Inst. v. U.S. Forest 

Serv., 442 F.3d 1147, 1160 (9th Cir. 2006), abrogated on other grounds by Winter v. Natural 

Res. Def Council, Inc., 555 U.S. 7 (2008). 

When the NRC staff was informed that every single citation in the DEIS was broken their reply 

was that it would be repaired in the final draft. OUTRAGEOUS! NRC has sought public 

comment on a two volume EIS totaling 1458 pages where every single citation is hidden behind 

a fire wall and the agency somehow thinks this is adequate? This pathetic inadequacy in citation 

wouldn't pass muster in a high school science class but somehow the NRC thinks it's 

appropriate for a DEIS to construct two nuclear reactors. (0716-5 [Riccio, Jim])

Response: The comment refers to administrative discrepancies associated with the Federal 

Register Notice, Public Meeting Notice, and draft EIS published in support of proposed Turkey 

Point Units 6 and 7. Each of these errors was quickly corrected as soon as the staff was 

notified. For instance, the NRC website and public meeting notice were updated to reflect the 

Appendix E October 2016 E-71 NUREG–2176
correct public meeting times. As for the different mailing addresses, each was within the NRC 

Administration Division therefore, all comments submitted were accounted for within the Turkey 

Point COL review process. Finally, hyperlinks or tracking numbers (e.g. TN3792) were 

inadvertently left active in the publicly distributed electronic copies of the draft EIS. This error 

occurred during the printing process but was corrected immediately in electronic copies in 

NRC’s ADAMS; and will be remedied in any future EIS publication. If active, these hyperlinks 

would not have provided access to information beyond that in draft EIS Chapter 11. Draft EIS 

Chapter 11, “References,” properly cited and included all the references that are not 

copyrighted. References in Chapter 11 include ADAMS accession numbers where available, 

allowing the reader to access these documents at http://www.nrc.gov/readingrm/adams.html. Web links are also included where available. The staff regrets any 

inconvenience or confusion these errors may have caused. 

Comment: Why at the next meeting they going to do? There's two meetings only. Why the next 

meeting this in Homestead? They no inviting in the news. All the people going there. And they 

going to find out some more against it. (0721-33-2 [Herrera, Luis])

Comment: I don't know what you've been listening to for the last several years. I've been to a 

lot of the NRC meetings. And when people ask questions, nobody answered any of them. When 

they asked what you thought of sea level rise, you actually just said -- you quoted the company, 

you didn't actually say what you thought. When they asked, what is the need for this, you said 

the -- a Public Service Commission had recommended it. (0721-6-1 [Harris, Walter])

Comment: I came here a little bit afraid that if I opposed this plan there would be people 

looking at me right now that might be angry with things that I'd say so I want to make sure that 

whatever I say I'm going to feel safe when I leave. So I'd like that assurity. (0723-3-1 [Star, 

Priscilla])

Response: It is NRC policy to involve the public in the Commission's decision-making process; 

therefore, it elects to conduct open public meetings to collect comments on the environmental 

aspects of a proposed project. The NRC generally holds meetings in locations accessible to the 

largest population that will experience the most direct environmental impact as a result of the 

proposed action. In the case of the draft EIS on the proposed Turkey Point Units 6 and 7, the 

NRC held three public meetings, one in Miami on April 22, 2014 and two in Homestead, Florida 

on April 23, 2014. The NRC held a meeting in Miami to make it more convenient for people 

from the nearby population center to participate in the meeting; the NRC held meetings in 

Homestead to make it more convenient for people from the communities closest to the site 

proposed for power plant construction to attend and comment. The NRC staff attends these 

meetings to listen to the comments to improve their understanding of the public concerns as 

part of its independent review. In some cases there is insufficient time available to respond to 

comments during a meeting. Nonetheless, the NRC responds to all comments on the draft EIS 

in Appendix E of the final EIS. 

Regarding the comment about the security of these public meetings, the NRC had security 

personnel present at all of the public meetings to ensure the safety of all participants. The NRC 

takes the safety of the meeting participants very seriously. 

No changes were made to the EIS as a result of these comments. 

Comment: To the extent that certain of these comments are determined to be outside the 

scope of the environmental review, the City requests that those comments be addressed 

Appendix E NUREG–2176 E-72 October 2016
through the safety review process or the review undertaken by the U.S. Army Corps of 

Engineers. (0456-26 [Miami, City])

Response: The NRC conducts a concurrent safety review of each COL application along with 

the environmental review; the results of the NRC's safety review of Turkey Point Units 6 and 7 

will be published in a Final Safety Evaluation Report, scheduled for publication in November 

2016. Further information on the safety review and how to members of the public can 

participate should be directed to the NRC Safety Project Manager, Manny Comer. Mr. Comar 

can be reached at Manny.Comar@nrc.gov. In addition, comments received by the public 

comment process are being reviewed by the U.S. Army Corps of Engineers under a 

Department of Army permit application, who is a cooperating agency on this EIS. No changes 

were made to the EIS as a result of this comment. 

Comment: As the Nuclear Regulatory Commission awaits the final NEPA required studies, 

including the Environmental Impact Statement (EIS) and the Final Safety Analysis Report, there 

are significant environmental impacts that have not been adequately addressed in the Draft EIS 

and on behalf of our residents, we register our concerns through these written comments to the 

draft statement issued. (0145-1 [Lerner, Cindy])

Response: The licensing process for combined construction permit and operating license 

(COL) applications is specified in Title 10 of the Code of Federal Regulations (CFR), Part 

52. The process includes a detailed review by the NRC of an applicant's COL application to 

determine the safety and environmental effects of construction and operation of a nuclear power 

facility. Public involvement and comments are invited and encouraged throughout the 

environmental review of major Federal actions; the NRC formally solicits both written and oral 

comments from members of the public at the beginning of the process during environmental 

scoping for the environmental impact statement (EIS) and when the draft EIS is issued. Specific 

information regarding the environmental impacts of the proposed action is discussed in the 

comment responses for specific impacts below. No changes were made in response to this 

comment. 

Comment: Even if the draft EIS weren't fatally flawed by the lack of functioning footnotes, the 

NRC has failed to meets its responsibilities under NEPA to address the impacts of the proposed 

federal action. (0716-13 [Riccio, Jim])

Response: The NRC implements NEPA according to its regulations in 10 CFR Part 51. The 

NRC uses these regulations as the basis for preparing EIS’s in support of NEPA. This comment 

is general in nature and provides no specific information related to the environmental 

review. No changes were made to the EIS as a result of this comment. The comment also 

refers to hyperlinks or tracking numbers (e.g. TN3792) that were inadvertently left active in the 

publicly distributed electronic copies of the draft EIS. This error occurred during the printing 

process but was corrected immediately in electronic copies in NRC’s Agencywide Documents 

Access and Management System (ADAMS); and will be remedied in any future EIS 

publication. If active, these hyperlinks would not have provided access to information beyond 

that in draft EIS Chapter 11. Draft EIS Chapter 11, “References,” properly cited and included all 

of the references that are not copyrighted. References in Chapter 11 include ADAMS accession 

numbers where available, allowing the reader to access these documents at 

http://www.nrc.gov/reading-rm/adams.html. Web links are also included where available. The 

staff regrets any inconvenience or confusion these errors may have caused. The NRC 

implements National Environmental Policy Act (NEPA) according to its regulations in 10 CFR 

Part 51. The NRC uses these regulations as the basis for preparing EIS’s in support of 

Appendix E October 2016 E-73 NUREG–2176
NEPA. This comment is general in nature and provides no specific information related to the 

environmental review. No changes were made to the EIS as a result of this comment. 

Comment: Please consider the relevant issues in the attached documents regarding the 

environmental impact of the operation of proposed reactors 6 & 7 at Turkey Point, FL by FPL.

(0598-1 [White, Barry J.])

Response: This comment is referring to a motion submitted by the Citizens Allied for Safe 

Energy, Inc. (CASE) in the ongoing Atomic Safety and Licensing Board (ASLB) proceeding on 

the Turkey Point Units 6 and 7 combined licenses, docket numbers 52-040 and 52-041 

COL. Information regarding the legal proceedings can be found on the electronic hearing 

docket at https://adams.nrc.gov/ehd/. This comment is legal in nature, has been addressed in 

the ASLB proceeding, and outside of the environmental review. No changes were made to the 

EIS in response to this comment. 

E.2.2 Comments Concerning Process - NEPA 

Comment: Potential Mitigation Measures Are Speculative, Inadequate, and Based on 

Incomplete Information. The U.S. Army Corps of Engineers has an independent responsibility 

under Section 404 of the Clean Water Act to determine if the project is consistent with the 

"public" interest and if impacts to the Waters of the United States have been adequately 

avoided, minimized, or mitigated. As a cooperating agency, the Corps will depend on 

information included in the EIS to comply with the requirements of NEPA in issuing a permit 

under the Clean Water Act. The Corps makes this determination through its own Record of 

Decision (ROD) and Department of Army (DA) permit. The potential mitigation measures 

proposed in the DEIS are speculative and inadequate and their effectiveness is not properly 

examined as required under NEPA. NEPA is "our basic national charter for protection of the 

environment," [Footnote 48: 40 C.F.R.§ 1500.1(a).] ensuring that federal agencies identify and 

analyze detailed information regarding significant environmental impacts of proposed projects 

and that such information is disseminated to a wide audience. Within an EIS, the EIS must 

describe the environmental impacts of the proposed action; "adverse environmental effects 

which cannot be avoided should the proposal be implemented;" alternatives to the action 

proposed; "the relationship between local short-term uses of man's environment and the 

maintenance and enhancement of long-term productivity;" and any "irreversible or irretrievable 

commitment of resources which would be involved in the proposed action should it be 

implemented." [Footnote 49: 42 U.S.C. §4332(2)(c).] The proposed project will impact 

approximately 1000 acres of tidal and freshwater wetlands in order to construct Units 6 & 7. 

[Footnote 50: Gattiana, J. L., United States Environmental Protection Agency Letter to Colonel 

Alan M. Dodd, U.S. Army Corps of Engineers, April 9, 2015, 1.] Portions of the project, as 

outlined in permit application number 2009-02417 (SP-MLC), include (1) new transmission lines, 

(2) Units 6 & 7 site, (3) pipelines for potable and reclaimed water, (4) equipment barge 

unloading area, (5) transmission line crossing under the Miami River, (6) access roads, (7) 

radial collector wells located under Biscayne Bay, and (8) pre-treatment building. Impacted 

wetlands include mangrove swamp, sawgrass marsh, seagrass, mixed wetland hardwoods, 

freshwater and saltwater marsh, and wetland shrub. [Footnote 51: Ibid. 1.] The project will 

directly impact approximately 300 acres of high quality mangrove wetlands, 40 acres of 

sawgrass marshes, and one acre of submerged aquatic vegetation, all of which are considered 

by the U.S. Environmental Protection Agency to be aquatic resources of national importance 

(ARNI). [Footnote 52: Ibid., 1-2.] (0113-2-13 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] 

[Schwartz, Matthew] [Silverstein, Rachel])

Appendix E NUREG–2176 E-74 October 2016
Response: The USACE will complete an independent evaluation of the proposed project after 

publication of the final EIS. The USACE's independent Record Of Decision (ROD) regarding 

the proposed permit will reference the analyses in the EIS and will also present any additional 

information required by the USACE to support its permit decision. This will include the USACE's 

determination on the Least Environmentally Damaging Practical Alternative (LEDPA), the 

consideration of impacts to the aquatic environment, Public Interest Review (PIR) factors, a 

consideration of all comments received, and compliance with applicable laws and 

regulations. Mitigation for the resource areas described in the comments are discussed in 

Sections 4.3.1 and 5.3.1 and support the NRC’s NEPA review, and includes information for the 

USACE’s permit decision. While the USACE will reference and tier off of the information in the 

EIS, the USACE final decision document is separate from the EIS and will not be completed 

until after the final EIS is published. The comments, however, provided no specific information 

not already discussed in the draft EIS, and did not warrant any change to the final EIS. No 

changes were made to the EIS as a result of these comments. 

Comment: According to the requirements of the National Environmental Policy Act (NEPA) and 

NRC regulations, the DEIS must present an analysis that examines and considers the 

environmental impacts, including direct, indirect, and cumulative impacts, of the proposed 

action; the environmental effects of alternatives to the proposed action; and mitigation 

alternatives that would reduce or avoid adverse environmental impacts. [Footnote 1: United 

States Regulatory Commission, Draft Environmental Impact Statement - Contents, 2014, 10 

C.F.R. 51.71(d). The DEIS fails to adequately discuss and analyze potential adverse 

environmental impacts and provides insufficient proposals for mitigation. Due to the deficiencies 

of the DEIS, as outlined in this letter, it would be premature and inappropriate to issue COLs for 

Turkey Point Units 6 and 7. (0113-1-2 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] 

[Schwartz, Matthew] [Silverstein, Rachel])

Comment: According to the requirements of the National Environmental Policy Act (NEPA) and 

NRC regulations, the DEIS must present an analysis that examines and considers the 

environmental impacts, including direct, indirect, and cumulative impacts, of the proposed 

action; the environmental effects of alternatives to the proposed action; and mitigation 

alternatives that would reduce or avoid adverse environmental impacts.1 [Footnote 1: United 

States Regulatory Commission, Draft Environmental Impact Statement-Contents, 2014, 10 

C.F.R. § 51.71(d)]. The DEIS fails to adequately discuss and analyze potential adverse 

environmental impacts and contains insufficient proposals for mitigation. Due to the deficiencies 

of the DEIS, as outlined in this letter, it would be premature and inappropriate to issue COLs for 

Turkey Point Units 6 & 7. (0208-10 [Ritz, David])

Comment: It is telling that no fewer than four local mayors and a state representative were in 

attendance to speak out against the draft EIS on behalf of their constituents. The meeting 

facilitator made a grievous error in trying to hurry the mayor of Miami off the podium as he 

continued to point out the appalling environmental impacts of the proposed plants, particularly 

on our drinking water supply. The fact that our elected representatives have no power over the 

NRC's licensing process other than to stand at the podium like their fellow citizens shows that 

the licensing process for nuclear power plants in this country is anything but democratic.

(0615-1-7 [Bethune, David])

Comment: The NRC has failed to produce an EIS for the proposed nuclear reactors at Turkey 

Point that is easily amenable to public review. Even if the draft EIS werent fatally flawed by the 

lack of functioning footnotes, the NRC has failed to meets its responsibilities under NEPA to 

address the impacts of the proposed federal action. (0716-1 [Riccio, Jim])

Appendix E October 2016 E-75 NUREG–2176
Comment: Since this a discussion on a Draft EIS that's been prepared under the auspices of 

NEPA, I'd like to talk -- just make one statement about NEPA that really wasn't made when we 

started this meeting, and it's important for people to understand what NEPA requires. And I took 

this from the Citizens Guide to NEPA, prepared by the Council on Environmental Quality. To 

implement these policies NEPA requires agencies -- in this case the NRC as the lead agency - -

to undertake an assessment of the environmental effects of their proposed actions prior to 

making decisions. In common language we call that the hard look. The agency is required to 

take a hard look at all of the environmental impacts and human impacts from this major Federal 

action before it takes place. (0721-22-1 [Schwartz, Matthew])

Comment: The purpose of NEPA is to evaluate the environmental impacts of a project before it 

is built, thoroughly. Take what's called a hard look. This EIS did not do that in any way, shape or 

form. (0723-9-8 [Schwartz, Matthew])

Response: The review team agrees that NEPA calls for a hard look at the environmental 

impacts of a major Federal action having a significant effect on the environment. The NRC 

licensing process for nuclear power plants includes a thorough review of the proposed plant's 

impacts on the environment in accordance with NRC regulations. The EIS analyses of the 

potential adverse environmental impacts from building the proposed units are described in 

Chapter 4 and the potential adverse environmental impacts from the operation of the proposed 

units are described in Chapter 5. Alternatives to the proposed action are analyzed in Chapter 

9. Mitigation proposed by the applicant and imposed on the applicant by local, state and 

Federal regulatory agencies other than the NRC during construction and operation are 

documented in Chapters 4 and 5, respectively. The draft DEIS summarizes the staff analyses 

of the impacts of the proposed action, which are based on extensive staff work that includes 

literature search, field work, modeling, and independent staff consideration of all pertinent 

information. To the extent the comments identified specific information regarding the 

environmental impacts of the proposed action, that information is discussed in the comment 

responses on specific impacts below. Otherwise, the comments provided no specific 

information not already discussed in the draft EIS, and did not warrant any change to the final 

EIS. 

In regard to public participation, Congress included in NEPA a requirement to circulate each 

draft EIS for public comment. The NRC implements that requirement in 10 CFR 51.73. In 

accordance with 10 CFR 51.74, the NRC staff distributed the draft EIS to appropriate State and 

local agencies authorized to develop and enforce relevant environmental standards. This 

ensures that local governments with authority to regulate the impacts of the proposed action 

have the opportunity to participate in the NEPA process and provide information to the NRC to 

inform the NRC staff analysis of the impacts. The NRC staff typically holds public meetings on 

draft EISs to elicit comments from the public. In that regard, the NRC staff process is designed 

to allow all of those who wish to speak that opportunity by allotting approximately equal 

speaking time to each speaker. Normally, elected officials are afforded the courtesy of speaking 

before members of the public at large. Every public meeting, however, is finite in length, and to 

ensure every member of the public who seeks to speak has the opportunity to do so, the NRC 

allots an approximately equal time to each speaker, given the available time and the number of 

speakers. One who speaks far beyond the time allotted—even an elected public official—will be 

informed that his or her time is up. Nonetheless, the public can submit comments (i.e. via 

electronic or U.S. postal mail), which compensates for the practical limits for receiving 

comments in the public meeting setting. 

No changes were made to the EIS as a result of these comments. 

Appendix E NUREG–2176 E-76 October 2016
Comment: Thank you for listening to logic and reason. (0344-3 [Hull, Meagan])

Comment: Thank you for listening to the wishes, promises, and concerns of this one voice in 

the large pool of Floridian voices. (0472-4 [Ball, Cheri])

Comment: Thank you for the opportunity to comment on the draft Environmental Impact 

Statement ("'DEIS") for Turkey Point Nuclear Plant Units 6 & 7. Attached to this letter, please 

find the City of Miami's comments prepared by the Office of the City Attorney. (0515-1 [Regalado, 

Tomas])

Comment: Thank you for considering my deeply felt and knowledgeable concerns. (0588-5

[Hanna, Jane])

Response: These comments express support for the NEPA review process for eliciting and 

receiving comments on the draft EIS as implemented by the NRC. To the extent the comments 

identified specific information regarding the environmental impacts of the proposed action, that 

information is discussed in the comment responses on specific impacts below. Otherwise, the 

comments provided no specific information not already discussed in the EIS, and did not 

warrant any changes to the EIS. 

Comment: Last night, I attended the NRC's public meeting on the draft Environmental Impact 

Statement for Turkey Point units 6 and 7. I must say the lack of preparedness and poor access 

to information demonstrated by the NRC staff at this meeting were most distressing. NRC staff 

were essentially unable to answer any public questions of significance. (0615-1-2 [Bethune, 

David])

Response: The purpose of the NRC's public meetings on the draft EIS was to provide an 

opportunity for members of the public to submit comments on the draft EIS for FPL's Turkey 

Point Units 6 and 7 COL application. The NRC staff were present primarily to assure that they 

heard and understood the comments. Because of the large number of people who signed up to 

provide comments there was little time for the NRC staff to respond. Responses to all 

comments on the draft EIS are provided in Appendix E of the final EIS. No changes were made 

to the EIS as a result of this comment. 

Comment: The NPS strongly encourages the NRC to consider the important anthropocentric 

value (i.e. enjoyment) of wildlife that is reflected in the NPS Organic Act and the enabling 

legislation that established both Biscayne and Everglades NPs. The Organic Act states that 

"wild life" must be conserved for the "enjoyment" of future generations. Biscayne NP's enabling 

legislation states the NPS must "preserve and protect ... for the enjoyment of present and future 

generations a rare combination of terrestrial, marine, and amphibious life. Lastly, Everglades NP 

was established as a "public park for the benefit of the people" that preserves the "ecological 

integrity of the unique flora and fauna." This statutory context, and the fact the NPS is a 

cooperating agency, makes the EIS for Units 6 and 7 unique among environmental reviews the 

NRC may have prepared in the past. It also elevates the value that should be given by the NRC 

to the human environment, which includes the relationship of people with the environment.

(0622-2-16 [Austin, Stan])

Comment: The construction and operation of Units 6 and 7 and related infrastructure has the 

potential to adversely affect NPS resources and potentially make more difficult ongoing federal, 

state, and county efforts to restore the broader everglades ecosystem via CERP and the BBCW 

Project. This section provides the NRC and USACE concepts for mitigation that would be 

necessary if Units 6 and 7 and supporting infrastructure were approved. Upon review, the NPS 

Appendix E October 2016 E-77 NUREG–2176
maintains that FPL's Turkey Point Units 6 & 7 Mitigation Plan Rev. 2, which was prepared in 

July 2011, is far from being sufficient to offset the potential for the impacts to NPS resources for 

which we have expressed concern. 

While the NPS understands that the NRC and USACE will be considering mitigation that 

complies with their own internal guidance, we encourage you to consider Secretarial Order 

Number 3330 Improving Mitigation Policies and Practices of the Department of the Interior 

(DOI). A central component of DOI's strategy is taking "a landscape-scale approach to identify 

and facilitate investment in key conservation priorities in a region." Another component 

encourages agencies to focus "on mitigation efforts that improve the resilience of our Nation's 

resources in the face of climate change." Because NPS lands and resources would be 

significantly impacted by this project, we assert that an innovative mitigation package that 

contains measures that take a landscape-scale approach and account for climate change would 

be essential if the project and associated infrastructure were to be approved. 

The NPS understands that it is difficult to compare this project to other projects elsewhere in the 

country that would similarly impact a national park, let alone two parks. Nonetheless, we 

encourage both agencies to consider the following two case studies as they may provide helpful 

context. 

Skagit River Project, Washington[.] In 1995, the Federal Energy Regulatory Commission 

(FERC) accepted several settlement agreements (SA) to mitigate various environmental, 

operational, and recreational issues relating to the relicensing of the Skagit River Hydroelectric 

Project (FERC Project No. 553), which is located within Ross Lake National Recreation Area 

and along the Skagit River in northwest Washington State. Under the SA, Seattle City Light 

(SCL), the licensee that operates the dams, helped fund the construction of the North Cascades 

Environmental Learning Center, which has become an internationally renowned center for 

environmental education and a source of pride for SCL. They also set aside $17 million for land 

acquisition to conserve wildlife habitat in the Skagit River watershed. Since relicensing, over 

eight thousand acres of high-value conservation lands have been acquired. The SA also 

included an additional $17 million to support recreation access along the river. According to 

Dean Shumway, the former Director of FERC's Office of Hydropower Licensing, the SA have 

been recognized by many as a national model and have been called "the most comprehensive 

set of Settlement Agreements for the public good ever submitted to FERC." 

Susquehanna to Roseland Transmission Line Upgrade, Pennsylvania. New York, and New 

Jersey[.] In 2012, the NPS approved construction of the 4.5 mile section of the proposed 146 

mile Susquehanna-Roseland Transmission Line across Delaware Water Gap National 

Recreation Area. Importantly, the new transmission line is located entirely along existing rightsof-way held by the companies for decades and that predate the parks' establishment. In an 

effort to minimize impacts to the park, the companies partnered with The Conservation Fund 

and contributed $56 million for the acquisition of critical lands within and near the park. An 

additional $10 million was provided to mitigate for visual impacts of the project to the 

Appalachian National Scenic Trail. Lastly, the applicants funded a number of NPS staff for five 

years for construction monitoring. (0622-2-6 [Austin, Stan])

Comment: After a thorough review of the DEIS, the NPS has identified a number of concerns 

regarding assumptions contained in the DEIS, the analysis of impacts, and the conclusions 

related to severity of impacts on resources managed by the NPS. The NPS remains concerned 

that federal actions associated with permitting and operating the proposed facility could result in 

adverse impacts to NPS resources and values including water quality and quantity, wetlands, 

Appendix E NUREG–2176 E-78 October 2016
wildlife and fisheries resources (including species listed under the Endangered Species Act), 

scenery, and the experience of park visitors that may affect our ability to manage these 

resources for their preservation for current and future generations. Although we recognize 

nuclear power as one of the means to achieve energy independence from fossil fuel, we also 

recognize the unique situation posed by the proposed expansion of the Turkey Point power 

plant immediately adjacent to two national parks. Both Biscayne and Everglades NPs are 

located within the greater Everglades ecosystem, which is not only one of the nation's most 

iconic landscapes, but also the focus of the largest intergovernmental watershed restoration 

program in the world. (0623-1 [Austin, Stan])

Comment: The NPS asserts that the DEIS impact analysis associated with construction and 

operation of proposed Units 6 and 7 does not sufficiently address issues related to the 

environmental impacts of the proposed action on resources managed by the NPS. Based on our 

review of the DEIS, we have strong concerns that impact analysis described in the DEIS does 

not:...provide for opportunities to eliminate or mitigate risks to NPS resources. (0623-10 [Austin, 

Stan])

Comment: It is for these reasons, we respectfully request that NRC and USACE revise the 

DEIS to address these issues. An update to the DEIS analysis should: 1) more fully evaluate 

potential impacts on NPS resources[.] (0623-11 [Austin, Stan])

Comment: It is for these reasons, we respectfully request that NRC and USACE revise the 

DEIS to address these issues. An update to the DEIS analysis should:...development of this 

additional information would better inform NRC licensing and USACE's permitting decisions. 

Specifically, additional analysis of the outstanding issues we have identified may assist USACE 

in determining the Least Environmentally Damaging Practicable Alternative and consideration of 

the public interest. Moreover, this information would better inform the public regarding the extent 

of potential impacts and the decision-making process. The NPS is ready to collaborate with the 

NRC and USACE on this effort. (0623-13 [Austin, Stan])

Response: The National Park Service (NPS) presents recommended mitigation measures for 

impacts to NPS resources resulting from project construction and operation. The ecological 

impacts of building and operating the proposed units are described in Sections 4.3 and 5.3, 

respectively. Visual and aesthetic impacts are addressed in Sections 4.4 and 5.4. The 

applicant, FPL, has proposed a series of specific wetland mitigation measures that are 

described in Section 4.3.1 of the EIS. Because the applicant develops mitigation measures in 

conjunction with State, local, and Federal agencies other than the NRC that have jurisdiction 

over such matters, the NRC only rarely imposes mitigation requirements on the applicant. The 

NRC staff nonetheless accounts for such mitigation matters, in its environmental 

evaluation. The USACE determines the adequacy of proposed compensatory mitigation for 

unavoidable impacts to aquatic resources pursuant to 33 CFR Part 332. Furthermore, the 

USACE determines whether mitigation is required in order for a proposed project not to be 

contrary to the public interest pursuant to 33 CFR § 320.4(r). 

The NRC staff responses to the specific NPS comments regarding the environmental impacts of 

the proposed action are set forth in the comment responses on specific subjects below. In 

regard to the specific subjects identified in the comment, other NPS comments provided more 

detailed information that is addressed in the responses below. The general or otherwise 

prefatory statements in the NPS comment do not provide the type of specific information set 

forth in the NPS-specific comments discussed in the subject matter sections below, and do not 

Appendix E October 2016 E-79 NUREG–2176
warrant any change to the EIS. No change was made to the EIS as a result of the general 

comments. 

Comment: The National Park Service provides the following detailed technical comments 

regarding the determinations reached in the DEIS. Based on our review of the DEIS, the NPS 

has identified updated information relevant to environmental concerns that were not included in 

the DEIS and need to be addressed to more fully incorporate environmental impacts of the 

proposed action into the decision-making process. (0622-1-1 [Austin, Stan])

Response: The NRC appreciates the NPS's continued participation in the development of the 

EIS as a cooperating agency. Information provided by the NPS throughout the entire 

environmental review was considered by the review team as the EIS was developed and 

included in the draft and final EIS, as appropriate. 

Comment: Today we must discuss a matter of vital importance to the future of our citizens and 

their children. Specifically, we must have an honest and critical discussion about FPL's plan to 

expand the nuclear plant at Turkey Point. When I say that we must have a 'discussion,' I mean it 

in the truest sense. We need our citizens and residents to be informed on the expansion and 

then speak up and make their voices heard to the Federal Regulators entrusted with our safety.

(0721-4-1 [Regalado, Tomas])

Response: The NRC prepared a draft EIS to assess the environmental impacts if the NRC 

grants FPL’s application to construct and operate two new nuclear power plants at the Turkey 

Point site. A 75-day comment period began on March 6, 2015 when the EPA published its 

Notice of Availability of the draft EIS to allow members of the public to comment on the results 

of the environmental review. During the public comment period, three public meetings were 

held, one in Miami on April 22, 2015 and two in Homestead, Florida on April 23, 

2015. Members of the review team described the results of the environmental review, provided 

members of the public with information to assist them in formulating comments on the EIS, and 

accepted comments on the EIS. Of those attending the public meetings, 68 provided oral 

comments. In addition to comments received at the public meetings, the NRC staff received 

approximately 11,300 additional pieces of correspondence. The review team considered the 

comments received at the public meetings and through correspondence as it developed the final 

EIS. Appendix E of the EIS outlines the comments received and responses to the comments on 

the draft EIS. No changes to the EIS were made as a result of this comment. 

Comment: The NRC's apparent failure to properly consider the harm to the environment that 

FPL's Turkey Point Nuclear Units 6 & 7 will cause is alarming and should be investigated by the 

NRC's Office of the Inspector General (OIG). To this extent -the NRC Staff is hereby requested 

to provide a copy of this document and all related NRC documents to the NRC's OIG -to enable 

that agency to make an informed decision as to whether the NRC Staff acted improperly in 

these circumstances to protect public health and safety and to protect the environment. 

(0010-3 [Saporito, Thomas])

Comment: To the extend that the NRC wholly relied on the FPSC's "NEED" determination - the 

agency failed to consider the benefits of these grid-tied solar power home energy systems in 

completing the agency's EIS determination in this matter. Accordingly - the NRC should reject 

and/or deny and/or revoke FPL's COL and the agency's EIS in their entirety as a matter of law. 

Moreover, to the extent that the NRC failed in its mission to protect public health and 

safety - and the environment as a whole in issuance of a "flawed" EIS in this matter - the 

NRC is requested to self-identify - to the NRC OIG accordingly. (0010-7 [Saporito, Thomas])

Appendix E NUREG–2176 E-80 October 2016
Comment: The NRC's EIS is flawed insofar as the EIS wholly relied upon the FPSC's "NEED" 

determination in authorizing FPL's COL and other licenses for the construction and operation of 

the proposed Turkey Point Nuclear Units 6 & 7 near Homestead, Florida. In so doing - the NRC 

jeopardized public health and safety and failed to protect the environment as a matter of law - 

and therein - violated the agency's mission statement. Thus, the NRC OIG must investigate the 

NRC in this instance as a matter of law accordingly. (0010-8 [Saporito, Thomas])

Comment: In conclusion, it is Greenpeace's view that the NRC's Environmental Impact 

Statement for Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7, Draft 

Report for Comment (NUREG-2176) should be pulled from public consideration unless and until 

the footnotes in the document actually work. I am amazed that the NRC even allowed the Draft 

EIS to see the light of day with every footnote hidden behind a fire wall. It is both a measure of 

the extent to which the NRC is captured and a measure of the disdain it has for the law and the 

public it supposedly serves. If NRC fails to withdraw and repair the document, I fail to see how 

the agency can conclude that the public has been given an adequate opportunity to comment. 

As the OIG Report reported, "NRC ought to break down the information 'in a common sense 

approach so the average person can do a quick read and learn how they may be impacted by 

the action." (http://pbadupws.nrc.gov/docs/ML1323/ML13232A192.pdf) The NRC has failed to 

produce an EIS for the proposed nuclear reactors at Turkey Point that is easily amenable to 

public review. (0716-12 [Riccio, Jim])

Comment: The U.S. Nuclear Regulatory Commission (NRC) has once again displayed its 

disdain for both the National Environmental Policy Act (NEPA) and the public it supposedly 

serves. The NRC's failure to comply with the terms of NEPA as well as own regulations in the 

preparation of environmental impact statements was the subject of a 2013 NRC Office of the 

Inspector General (OIG) Report. (http://pbadupws.nrc.gov/docs/ML1323/ML13232A192.pdf)

(0716-2 [Riccio, Jim])

Comment: The OIG report found that NRC's NEPA documentation "does not clearly present, in 

an accessible way, the proposed action, alternatives, and conclusions to stakeholders" and 

"undermines its extensive efforts to be clear, open, and transparent." OIG Report at 12. The 

OIG criticized NRC's EIS documents for being "lengthy and complex" and "overwhelming to the 

average person." OIG Report at 7, 10-15. 

(http://pbadupws.nrc.gov/docs/ML1323/ML13232A192.pdf) The OIG's criticisms were not meant 

as a road map for continued NRC malfeasance. (0716-3 [Riccio, Jim])

Response: The comments refer to a 2013 report of the NRC Office of the Inspector General 

(OIG), “Audit of NRC’s Compliance With 10 CFR Part 51 Relative to Environmental Impact 

Statements,” OIG-13-A-20, dated August 20, 2013 (NRC 2013-TN4804). The portions of the 

OIG report to which the comment refers focus on (1) the record of decision (ROD) (OIG Report 

at 7, 10-11) and (2) the model format for an EIS in 10 CFR Part 51, Appendix A (OIG Report at 

12-15). Neither the NRC nor the U.S. Army Corps of Engineers (USACE) has issued a ROD 

on the proposed action, and the NRC fully intends to comply with the NRC regulations that 

govern the issuance of RODs in 10 CFR 51.102 and 51.103. The NRC staff took the 

appropriate steps to address recommendations expressed in the report. Members of the public 

can review how the staff responded to the recommendations on the OIG website at 

http://www.nrc.gov/reading-rm/doc-collections/insp-gen/2013/. Any additional inquires and/or 

follow up regarding this case should be directed to the NRC’s OIG at 1-800-233-3497. No 

changes to the EIS were made as a result of this comment. 

Appendix E October 2016 E-81 NUREG–2176
Comment: CWA 404 Permit NEPA Documentation: EPA understands that the NRC is 

addressing impacts of the onsite facility, and that offsite facilities, such as the transmission lines 

and other related facilities, will not be considered in detail for the purposes of this EIS. The EPA 

also understands that the USACE intends to adopt the NRC's EIS for the purposes of their CWA 

Section 404 permit action. However, many of the associated and connected actions, such as 

construction of the transmission lines, are not considered in the NRC's EIS. For the purposes of 

permit issuance, the USACE should state how they plan to address associated NEPA 

documentation for these offsite facilities, as those impacts are directly related to this project. 

NEPA coverage for these permit actions should be included within NRC's FEIS. 

Recommendations: EPA recommends that the NRC document the USACE intentions for 

addressing their NEPA documentation and timing with NRC's FEIS and permit issuance. The 

FEIS should include a mitigation plan which details how the proposed mitigation is in 

compliance with the Federal Compensatory Mitigation Rule, dated April 2008. (0617-1-34

[Mueller, Heinz J.])

Response: The final EIS does provide a NEPA alternatives analysis for the transmission 

corridor alignment alternatives, see Appendix K. The USACE will conduct its Least 

Environmentally Damaging Practicable Alternative (LEDPA) analysis and public interest review 

(PIR) in its ROD and will potentially provide the draft LEDPA/PIR for public review and 

comment. The final EIS addresses mitigation measures, including avoiding, minimizing, 

rectifying, reducing, eliminating, and compensating for impacts to the extent required by the 

NEPA statute (42 U.S.C. Section 4321 et seq.), the Council on Environmental Quality (CEQ) 

regulations at 40 CFR Parts 1500-1508, and CEQ guidance (e.g., CEQ January 14, 2011 

Memorandum on the Appropriate Use of Mitigation and Monitoring and Clarifying the 

Appropriate Use of Mitigated Findings of No Significant Impact). These NEPA authorities and 

guidance do not require an action agency to detail how proposed mitigation is in compliance 

with 33 CFR Part 332 in the final EIS. The USACE will review the sufficiency of the proposed 

compensatory mitigation for unavoidable losses of aquatic resources at the appropriate point in 

the Clean Water Act Section 404(b)(1) Guidelines process, which is after avoidance and 

minimization. 33 CFR Section 332.1(c). The Corps will determine the LEDPA and determine 

the sufficiency of the proposed mitigation plan pursuant to 33 CFR Part 332 in its ROD. 

Comment: DEIS Section 1.3, Page 1-9, Lines 25-28: The DEIS states: "The purpose and need 

of the NRC proposed action—NRC authorization of the construction and operation of two 

AP1000 units at the Turkey Point site—is to provide additional baseload electrical generation 

capacity for use in the FPL service territory." ER Subsection 1.1.1, Purpose and Need, states: 

"FPL's purpose is to provide additional baseload generation to maintain system reliability, 

increase fuel diversity, and allow progress toward meaningful CO2 emissions reductions."

(0619-3-1 [Maher, William])

Response: The comment offers a more detailed purpose and need statement written in the 

applicant's ER for the proposed Turkey Point Units 6 and 7 (COL Application Part 3). While the 

comment does provide more detail regarding the overall purpose and need for the application, 

the staff thinks the purpose and need as stated in the EIS is sufficient. Furthermore, the NRC 

does not promote any particular form of energy generation, including nuclear. No changes were 

made to the EIS. 

Comment: The EPA has numerous concerns regarding the analyses, data and mitigation 

required for the CWA Section 404 permitting application. We noted a number of details and data 

that need to be clarified, with additional information provided to the EPA prior to the publication 

Appendix E NUREG–2176 E-82 October 2016
of the FEIS, in order for the FEIS to meet the needs of all the project's permitting requirements. 

The EPA reviewed the permit application number 2009-02417(SP-MLC) submitted to the U.S. 

Anny Corps of Engineers (USACE} by Florida Power & Light (FPL), and responded in writing on 

April 9, 2015 and May 4, 2015. EPA's letters state our CWA Section 404 concerns regarding the 

proposed project. These comments should be considered and responded to by the project 

team, with further information provided in the FEIS. (0617-1-5 [Mueller, Heinz J.])

Response: The Corps is in receipt of the EPA comments dated April 9, 2015 and May 4, 

2015. The Corps will review the sufficiency of the proposed compensatory mitigation for 

unavoidable losses of aquatic resources at the appropriate point in the Clean Water Act Section 

404(b)(1) Guidelines process, which is after avoidance and minimization. 33 C.F.R. Section 

332.1(c). The Corps will determine the Least Environmentally Damaging Practicable Alternative 

and determine the sufficiency of the proposed mitigation plan pursuant to 33 C.F.R. Part 332 in 

its Record of Decision. 

E.2.3 Comments Concerning Site Layout and Design 

Comment: There are instances in the DEIS where the reclaimed water pipeline is not correctly 

illustrated. Instances in the DEIS include: a. DEIS Subsection 2.2.2.1, Page 2-16, Figure 2-5: 

DEIS Figure 2-5 contains the following inconsistencies: i. A reclaimed water pipeline route is 

illustrated that does not take into account the width of the corridor for the northern section of the 

pipeline as it approaches the Miami-Dade County WASD. ER Figure 2.2-5 shows the pipeline 

corridor in this section to be 1 mile wide. ii. The reclaimed water pipeline route is illustrated 

following the transmission line corridor as it approaches the Turkey Point site. ER Figure 2.2-3 

shows the pipeline route following the L-31 E canal south until it enters the RWTF. b. DEIS 

Subsection 3.2.2, Page 3-7, Figure 3-4: DEIS Figure 3-4 has the reclaimed water pipeline 

exiting the Reclaimed Water Treatment Facility but also has a reclaimed water-pipeline along 

344th St. ER Figure 2.2-3 illustrates the current configuration of the reclaimed water pipeline 

route which does not include the routing along 344th Street. c. DEIS Appendix F-3, Section 

3.1.1, Page 3-4, Figure 3-3: Appendix F-3 Figure 3-3, illustrates the reclaimed water pipeline as 

it approaches the RWTF from the north and is not shown correctly. ER Figure 2.2-3 shows the 

pipeline following the L-31 E canal south until it enters the RWTF. (0619-1-14 [Maher, William])

Comment: DEIS Subsection 3.2.2.2, Page 3-10, Lines 13-14; Appendix F-3, Subsection 

3.1.1.1, Page 3-5, Lines 34-35; and Appendix F-4, Subsection 2.3.4, Pages 2-9/2-10, Lines 

40/1: DEIS (Subsection 3.2.2.2) states: "A typical injection well steel casing would be lined 

with...with grout in the annulus..." Similar descriptions occur in Appendix F-3 (Subsection 

3.1.1.1) and Appendix F-4 (Subsection 2.3.4). In contrast, in a letter dated April 22, 2014, FPL 

submitted a supplemental response to NRC Request for Additional Information Letter No. 72 

(eRAI 6985), ML14113A411, which states: "The annular space...will be filled with a nonhazardous corrosion inhibitor (e.g., one percent Baracor 100 solution)..." This supplemental 

response indicates that the annular space will be lined with a non-hazardous corrosion inhibitor. 

Additionally, ER Figure 3.4-3 illustrates that the annular space is filled with "1% Baracor 100 

solution". (emphasis added) (0619-3-18 [Maher, William])

Comment: DEIS Subsection 3.2.2.3, Page 3-16, Lines 23-25: The DEIS states: "FPL plans to 

build...It would be sized to serve the operational workforce of both units (approximately 500

workers)...workforce expected to be onsite during an outage (approximately 1,000 workers)." 

The operational workforce and outage workforce numbers should reflect the values indicated in 

the supporting documentation. ER Subsection 3.10.3 states: "... it is estimated that the onsite 

operations workforce would be 403 personnel for each unit, or 806 personnel..." Additionally, 

Appendix E October 2016 E-83 NUREG–2176
ER Subsection 5.8.2 states: "Refueling outages for each unit would occur every 18 months, last 

approximately 30 days, and require the addition of approximately 600-1000 temporary 

workers." (emphasis added) (0619-3-19 [Maher, William])

Comment: DEIS Subsection 3.4.4.2, Page 3-38/3-39, Table 3-5: DEIS Table 3-5 reflect 

constituents' concentrations (or stated value in the case of conductivity) that are not consistent 

with those reported in ER Table 3.6-3 for saltwater. These include: Nitrate as N; Total Organic 

Compounds, Total Dissolved Solids; Barium; Copper; Silica as SiO2; and conductivity. The 

listed sources for DEIS Table 3-5 are: FPL 2014-TN4058 (ER Revision 6) and FPL 2012-TN263 

(FPL response to RAI No. 4.2-2). The listed constituents' concentrations (or stated value in the 

case of conductivity) are consistent with DEIS reference FPL 2012-TN263. However, 

subsequent to the submission of RAI response 4.2-2, the values were revised as reflected in ER 

Revision 6. (0619-3-20 [Maher, William])

Comment: DEIS Subsection 3.4.4.3, Page 3-39, Lines 4-7: The DEIS states: "Based on four 

operating hours per month for each engine, the estimated annual emissions...and 24,004 lb of 

hydrocarbons and nitrogen oxides (FPL 2014-TN4058)." ER Table 3.6-4 lists 11.83 

tons/year which is equivalent to 23,660 lbs. (11.83 tons x 2000 lbs/tons = 23,660 lbs.). 

(emphasis added) (0619-3-21 [Maher, William])

Response: EIS Figures 2-5 and 3-4, Table 3-5, and text in Sections 3.2 and 3.4 were revised 

to incorporate the identified changes. Appendices F-3 and F-4 contain species and habitat 

consultation documents submitted to the National Marine Fisheries Service (NMFS) as part of 

Endangered Species Act (ESA) Section 7 consultation and Magnuson-Stevens Act Essential 

Fish Habitat (EFH) consultation. Once consultation documents are submitted to the regulatory 

agency they cannot be modified. No changes were made to the submitted consultation 

documents as a result of these comments. 

Comment: And we have extra barriers and defenses in place to make sure that that can't 

happen here. But that doesn't mean that we can't learn from it. And we did. And we've made 

further upgrades and further modifications, not just to our procedures but to our actual plant 

equipment. We've turned Turkey Point and the future designs into basically a plug-and-play type 

of design. So now we don't just look at, hey, what's the worst hypothetical thing that can 

happen. We try to not even look at the what-ifs. We just say, if it happens, how do we mitigate it. 

We've implemented new designs and new strategies, new approaches, to make sure that we 

have extra margin of safety. (0721-15-12 [Kuraza, Devon])

Response: This comment relates to how the site layout and design developed by FPL for the 

Turkey Point site would prevent the kind of accident that happened at Fukushima from 

happening at the Turkey Point site. Site layout and design are discussed in Chapter 3 of the 

EIS, but this comment relates to safe operation of the proposed units and, as such, is outside 

the scope of the environmental review. A safety assessment for the proposed licensing action 

was provided as part of the application. The NRC is developing a Safety Evaluation Report that 

will analyze all aspects of reactor and operational safety for the proposed units; this document is 

slated to be issued in November 2016 and can found on the NRC’s Turkey Point homepage 

(http://www.nrc.gov/reactors/new-reactors/col/turkey-point/documents.html#nrcDocuments). No 

changes were made in the EIS as a result of this comment. 

Comment: DEIS Subsection 3.2.2.1, Page 3-8, Lines 21-22 and DEIS Subsection 3.3.1.1, 

Page 3-23, Lines 19-20: The DEIS (Subsection 3.2.2.1) states: "The proposed stormwaterdischarge locations for the main plant area, laydown area, and administration/training/parking 

Appendix E NUREG–2176 E-84 October 2016
area are shown on Figure 3-4." Additionally, the DEIS (Subsection 3.3.1.1) states: "EIS Section 

3.2.2.1 provides a description of the drainage system and Figure 3-4 shows the stormwater 

outfall locations." The text indicates that stormwater discharge locations and stormwater outfall 

locations are shown on Figure 3-4. However, neither the stormwater discharge locations nor the 

stormwater outfall locations are shown on this figure. (0619-3-17 [Maher, William])

Response: The text in Sections 3.2 and 3.3 of the EIS were revised to delete the reference to 

Figure 3-4. 

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 3.2.2.3, Page 3-

18, Table 3-2: The total length of the "Clear Sky-Turkey Point" route for the East Corridor is 

listed as 0.4 miles. ER Subsection 3.7.2: In the first paragraph of ER Subsection 3.7.2, the 

length of the "Clear Sky-Turkey Point (230 kV)" transmission line is characterized as 0.5 miles.

(0619-2-23 [Maher, William])

Response: Table 3-2 has been revised to be consistent with Revision 6 of the ER. 

E.2.4 Comments Concerning Land Use - Site and Vicinity 

Comment: There are two national parks, an aquatic preserve, a wetland preserve and a 

national wildlife refuge within six miles of the proposed expansion site. Obviously an expansion 

of Turkey Point could jeopardize the area's habitat, endangering wildlife including a wide range 

of federally protected endangered species. The Nuclear Regulatory Commission's rules state 

that "sites adjacent to lands devoted to public use may be considered unsuitable," and 

unacceptable impacts are "most apt to arise in areas adjacent to natural-resource-oriented 

areas." The area certainly fits the accepted criteria for "unsuitable" and the plan for 

"unacceptable impacts". (0463-5 [Gross, Cheryl A.])

Response: The comment suggests that the ecological costs of the proposed action, in 

combination with the site's proximity to nearby public lands, are so high as to make the site 

unsuitable for nuclear power. The principal costs and benefits of the proposed action are 

summarized in Chapter 10 of the EIS. The summary is derived from careful assessment of 

ecological impacts across the terrestrial and aquatic environmental interfaces affected by the 

action during construction (Section 4.3) and during operations (Section 5.3). In addition, the 

cumulative terrestrial and aquatic ecologic impacts of the action are presented in Chapter 

7. These impact discussions frame the assessment of overall project benefits and costs that 

are within the staff's scope to assess. The NRC staff determined that the overall benefits of the 

proposed action outweigh the expected environmental costs. No changes to the EIS were 

made as a result of this comment. 

Comment: The impacts of additional roads and pads [is] unacceptable. (0245-6 [Lindsey, Jerrie])

Comment: It will be necessary to fill in our precious wetlands, build new roads, bridges, new 

electrical transmission line corridors etc. all which threaten to degrade the restoration efforts of 

recently carried out CERP projects and perhaps also threaten to damage the very fragile marine 

ecosystems of Biscayne National Park! (0340-4 [Tweeton, Tanya])

Response: These comments express opposition to the roads and transmission tower pads that 

are part of the proposed project. The impacts of building roads and transmission lines are 

described in Section 4.1 and 4.3.1. No changes were made to the EIS as a result of these 

comments. 

Appendix E October 2016 E-85 NUREG–2176
Comment: Miami-Dade County's Environmentally Endangered Lands (EEL)[.] The NPS 

supports the Miami-Dade County's request that certain FPL owned land be transferred and/or 

otherwise made available through easements to the County's Environmentally Endangered 

Lands (EEL) Program's South Dade Wetlands Project Area. This request was outlined in letter 

from George M. Burgess, County Manager, to FPL dated April 22, 2010. EEL was approved by 

Miami-Dade County voters in 1990 and was created to "acquire, preserve, enhance, restore, 

conserve, and maintain environmentally-endangered lands for the benefit of present and future 

generations." According to the County, over 19,500 acres of land has been conserved since the 

establishment of the EEL program in 1990. The letter also identified that FPL owns 3,388 acres 

of non-mitigation lands that are on the EEL list. FPL's proposed mitigation plan indicates that 

they would dedicate 812 acres of land outside of mitigation banks for conservation. Importantly, 

the County's EEL map identifies conservation priority lands west of the Biscayne NP contained 

within the Biscayne Bay Greenprint (shown in Figure 2 [Biscayne Bay Greenprint map showing 

BNP adjacent lands protection and overall conservation priorities]). We encourage close 

consideration of the County's request that FPL's entire 3,388 acres be given to EEL as a part of 

their mitigation package. Additionally, we encourage FPL to create a restoration fund to combat 

invasive species, reverse salt water intrusion, and restore the full ecological function of these 

lands. (0622-2-8 [Austin, Stan])

Response: The commenter presents specific recommended mitigation measures for wetland 

impacts resulting from building the proposed project. The applicant, FPL, has proposed a series 

of specific wetland mitigation measures which are described in Section 4.3.1.6 of the EIS. The 

review team does not itself impose natural resources mitigation requirements on the applicant, 

but in its assessment does account for the mitigation measures that the applicant develops in 

conjunction with other regulatory agencies. No change was made to the EIS as a result of this 

comment. 

Comment: There are instances in the DEIS where there are inconsistencies and/or 

discrepancies relating to authorizations, permitting and certifications. Instances in the DEIS 

include (emphasis added):...DEIS Subsection 5.1.1.1, Page 5-3, Lines 28-29: The DEIS states: 

"The applicant would be required to obtain a Coastal Zone Consistency Determination from the 

State of Florida prior to initiating work." As noted in the Conditions of Certification issued by the 

State of Florida Department of Environmental Protection, Section A, Subsection XXIII: "Pursuant 

to Sections 373.428 and 403.511, F.S., certification of the Certified Facilities constitutes the 

State's concurrence that the licensed activity or use is consistent with the federally approved 

program under the Florida Coastal Management Act." (0619-2-11 [Maher, William])

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Section 2.1, Page 2-1, Lines 

35-36 "The location for the proposed Units 6 and 7 is within portions of Sections 33 and 34 of 

Township 58S Range 40E (FPL 2014-TN4058)" ER Section 2.1 "The Units 6 & 7 plant area 

would be located in portions of Sections 33 and 34 of Township 57S, Range 40E." (0619-2-18

[Maher, William])

Comment: There are instances in the DEIS with respect to the presented land use values in 

their respective tables, which are inconsistent with the cited source or not current with the most 

recent documentation/reference. Instances in the DEIS include (emphasis added):...DEIS 

Subsection 4.1.1.1, Pages 4-5 and 4-6, Table 4-1: DEIS Table 4-1 reports the disturbed area 

acreage for the Turkey Point Site. The following acreage values do not reflect the values in ER 

Table 4.3-1 Revision 6, but rather reflects those of ER Table 4.3-1 Revision 4 prior to the 

relocation of the FPL Reclaimed Wastewater-Treatment Facility: i. The following "FPL 

Reclaimed Wastewater-Treatment Facility" FLUCFCS codes and associated acreages are 

Appendix E NUREG–2176 E-86 October 2016
reported (612B: 42.82 acres; 617: 0.78 acres; and 814: 0.31 acres). ER Table 4.3-1, Revision 6, 

reports the same facility with FLUCFCS codes and associated acreages as (437: 7.79 acres; 

510: 3.07 acres; 511: 0.30 acres: 612-B: 19.80 acres; 619: 0.61 acres; 619-AP: 0.16 acres; 

6411: 11.93 acres; and 814: 0.26 acres). ii. Additionally, FLUCFCS land-use codes and 

acreages are reported in DEIS Table 4-1 for disturbed areas for the "Treated Reclaimed 

Delivery Pipelines" category. Per note in ER Table 4.3-1, Revision 6: "The treated reclaimed 

water supply pipeline is now fully within the heavy haul road disturbed area and is not 

separately considered". g. DEIS Subsection 4.1.1.1, Page 4-7, Table 4-2: DEIS Table 4-2 

contains acreages for the project elements by major FLUCFCS codes. The following 

inconsistencies with the cited source, DEIS Table 4-1, and/or the corresponding source for 

DEIS Table 4-1, ER Table 4.3-1, are noted: i. The "Heavy Haul Roads" project element, under 

code 500, 0.30 acres is listed; and under code 700, 0.21 acres is listed. DEIS Table 4-1 and ER 

Table 4.3-1 both report 0.15 acres under code 500. The summed values for code 700 listed in 

both DEIS Table 4-1 and ER Table 4.3-1 is 0.22 acres for the same project element. ii. The 

"Equipment Barge-Unloading Area" project element, under code 600, 0.73 acres is listed. Both 

DEIS Table 4-1 and ER Table 4.3-1 reports this acreage under code 800 not 600. iii. The 

"Radial Collector Well Delivery Pipeline" project element does not have acreage listed under 

code 700, while both DEIS Table 4-1 and ER Table 4.3-1, report 9.21 acres under code 700 for 

the same project element. iv. The acreages for the "FPL Reclaimed Wastewater Treatment 

Facility" and "Treated Wastewater Delivery Pipelines" project elements do not reflect the revised 

location of the FPL Reclaimed Water Treatment Facility detailed in ER Table 4.3-1, Revision 6.

(0619-2-3 [Maher, William])

Comment: There are instances in the DEIS with respect to the presented land use values in 

their respective tables, which are inconsistent with the cited source or not current with the most 

recent documentation/reference. Instances in the DEIS include (emphasis added):...h. DEIS 

Subsection 4.1.1.3, Pages 4-10 and 4-11, Table 4-3: DEIS Table 4-3 contains acreage values 

by FLUCFCS codes for the reclaimed water and potable water pipelines. The following 

inconsistencies are noted with the source cited for DEIS Table 4-3, (FPL 2014-TN4058): i. The 

acreages for the "Reclaimed Wastewater Pipeline" do not reflect the revised location of the FPL 

Reclaimed Water Treatment Facility detailed in ER Table 4.3-1, Revision 6, but rather reflect 

those of the initial location with the acreages and percentages matching ER Table 4.3-1, 

Revision 4. ii. The acreages for the "Potable Water Pipeline" do not reflect the values in ER 

Table 4.3-1 Revision 6, but rather reflects those of ER Table 4.3-1 Revision 4. i. DEIS 

Subsection 4.1.1.3, Pages 4-12 and 4-13, Table 4-4: DEIS Table 4-4 reports acreage values by 

FLUCFCS codes for the access roads. The following inconsistency is noted with the source 

cited for DEIS Table 4-4, (FPL 2014-TN4058): i. For "SW 359th Ave. East", DEIS Table 4-4 

does not list FLUCFCS code 534 "Reservoirs Less Than 10 Acres (4 Hectares) Which Are 

Dominant Features" and its corresponding acreage and percent total. However, ER Revision 6 

Table 2.2-7, lists FLUCFCS code 534, under the "SW 359th Ave. East" area with a 

corresponding acreage and percent total of 0.06 and 0.13, respectively. j. DEIS Subsection 

4.1.2.1, Page 4-16 through 4-19, Table 4-5: DEIS Table 4-5 contains acreages for the 

transmission line routes by FLUCFCS codes. The following inconsistencies with the source 

cited in the text for DEIS Table 4-5, (FPL 2014-TN4058) are noted: i. DEIS Table 4-5 contains 

information listed as "Clear Sky to Levee 2nd Leg (Consensus Corridor)." From ER Table 2.2-3, 

these acreages are actually acreages from "Clear Sky to Levee 2nd Leg (Secondary Corridor)." 

The West Secondary Corridor was removed from consideration in 2013. [DEIS Reference (FPL 

2013-TN2941)]. Acreages should be provided for the West Consensus Corridor, which are 

found in DEIS reference (FPL2013-TN2941). ii. DEIS Table 4-5 lists the total acres for the 

proposed Clear Sky to Levee 1st Leg as 1378.9. ER Table 2.2-3 and DEIS Table 2-5 list the 

correct total acreage, 1365.43, for the same route. Seven of the values for the Clear Sky to 

Appendix E October 2016 E-87 NUREG–2176
Levee 1st Leg are inconsistent with the ER, which is cited as the reference. DEIS Table 4-5 for 

codes 437, 510, 511, 612-B, 619, 6411, and 814 lists 0.84, 219.01, 0.92, 73.16, 57.07, 11.47 

and 12.27 respectively, while the values listed on ER Table 2.2-3 for codes 437, 510, 511, 612-

B, 619, 6411, and 814 are 0.08, 218.11, 0.67, 63.96, 56.46, 9.97, and 12.03, respectively. 

(emphasis added) iii. DEIS Table 4-5 contains information listed as "Clear Sky to Levee 2nd Leg 

(Preferred Option). There is one category missing-category 619, Exotic Wetlands Hardwood, 

which should be listed with an acreage value of 74.62 acres.[ ER Table 2.2-3, DEIS reference 

(FPL2014-TN4058)]. iv. DEIS Table 4-5 does not contain acreages for the Clear Sky to Levee 

3rd Leg (Consensus Corridor) per DEIS Reference (FPL 2013-TN2941). (0619-2-4 [Maher, 

William])

Comment: There are instances in the DEIS where there are inconsistencies and/or 

discrepancies relating to authorizations, permitting and certifications. Instances in the DEIS 

include (emphasis added): a. DEIS Subsection 4.1.2.1, Page 4-20, Lines 5-7: The DEIS states: 

"The State certification review process also includes a determination of land-use consistency 

with local land-use plans and zoning ordinances (Fla. Stat. 29-403.50665-TN1470)." However, 

under the Power Plant Siting Act, land use consistency determination does not apply to 

transmission lines. The land use consistency determination made was for the site and 

associated facilities that constitute development under state law. Transmission lines are not 

"development" under Florida law and, therefore, local government land use and zoning 

ordinances are not applicable. See 403.50665 and 380.04 Fla. Stat. (0619-2-8 [Maher, William])

Comment: DEIS Subsection 2.2.1.6, Page 2-14, Lines 12-13: The DEIS states: "Agricultural 

land composes approximately 9 percent (3,500 ac) of land use within the 6 mi vicinity of the 

Turkey Point site (Figure 2-4; Table 2-2)." DEIS Subsection 2.2.1.6, page 2-8,Table 2-2 details 

the acreage related to the Turkey Point site, where no agricultural land use is designated, rather 

than the 6 mi vicinity. DEIS Subsection 2.2.1.6, page 2-8/2-10, Table 2-3, contains the 

agricultural land acreage within the 6 mi vicinity. However, the total land use acreage depicted 

in DEIS Table 2-3 and ER Table 2.2-1 is 62,941.15 acres; 9 percent of 62,941.15 acres is 

approximately 5,665 acres not 3,500 acres (3,500 acres is approximately 5.6 percent). From 

DEIS Table 2-3 and ER Table 2.2-1, agricultural land composes approximately 4.5 percent 

(2,850 ac). (emphasis added) (0619-3-3 [Maher, William])

Comment: DEIS Subsection 2.2.2.3, Page 2-20, Lines 25-27: The DEIS states: "Existing land 

uses in the area to be disturbed by the potable water pipelines would be approximately 20

percent agricultural land, 19 percent urban or built-up land, and approximately 30 percent marsh 

and wetland (FPL 2014-TN4058)." The cited reference in the DEIS text, (FPL 2014-TN4058), is 

FPL's ER Revision 6. Taking into consideration the acreages in DEIS Subsection 2.2.3, page 2-

20, Table 2-6 and ER Table 2.2-6, the percentages are approximately 21 percent for agricultural 

land; 6 percent for urban or build-up; and 49 percent for marsh and wetland. (emphasis added)

(0619-3-5 [Maher, William])

Comment: DEIS Subsection 2.2.3.2, Page 2-25, Lines 9-11: The DEIS states: "Most of this 

land is wetland...urban or built-up lands account for approximately 15 percent (FPL 2014-

TN4058)." Taking into consideration the acreages in DEIS Subsection 2.2.3, page 2-23, Table 

2-7 and ER Table 2.2-8, the percentage for urban or build-up is approximately 13 percent. 

(emphasis added) (0619-3-6 [Maher, William])

Response: The review team verified the suggested changes in these comments and revised 

the EIS accordingly. The conclusions of the EIS were not altered by this information. 

Appendix E NUREG–2176 E-88 October 2016
Comment: It does not appear that potential adverse impacts to CERP were adequately 

evaluated during the DEIS process. CERP was approved by the U.S. Congress and has 

required and will require significant funding in the future for the implementation of the BBCW 

project. Therefore, the EIS should re-evaluate the impacts of the construction and operation of 

the proposed RCW to evaluate the project consistency with CERP or a supplemental EIS 

should be performed. (0110-1-11 [Hefty, Lee N.])

Response: The EIS presents the impacts of the construction and operation of the project on 

sensitive wetlands and wildlife in Section 4.3 as part of the discussion of ecological impacts of 

preconstruction/construction and in Section 5.3 as part of the discussion of ecological impacts of 

operation. Interactions between actions planned under the Comprehensive Everglades 

Restoration Plan (CERP) and the actions proposed by FPL for Turkey Point Units 6 and 7 are 

discussed in Sections 7.2 (Water) and 7.3 (Ecology). 

The review team has expanded the discussion in the EIS regarding how the proposed action 

could potentially conflict with the CERP. The expanded discussion has not altered the 

conclusions regarding potential impacts on land use or terrestrial ecology in the EIS. 

Comment: Miami-Dade County notes that the discussion on MDC's CDMP in Section 2.2.1.4 

appears to be limited to selected policies within the Land Use Element; no references or 

summaries are provided for other CDMP elements. Miami-Dade County asks whether the NRC 

specifically considered the consistency of the proposed project with Land Use Element Policy 

LU-3A, which requires consistency with all elements of the CDMP, including Objectives CON-4, 

CON-7, and CON-9 of the Conservation, Aquifer Recharge and Drainage and Coastal 

Management Elements, as well as with all applicable environmental regulations; the referenced 

objectives and policies address protection of the aquatic environment and endangered and 

threatened species and consistency with the Comprehensive Everglades Restoration Program. 

If so, the NRC should provide citations from the DEIS where this information was presented. If 

the NRC did not consider the consistency of the proposed project with Land Use Element Policy 

LU-3A, including consistency with the referenced policies of the Conservation, Aquifer Recharge 

and Drainage Element, please provide an explanation for why this analysis was not performed. 

(0110-1-4 [Hefty, Lee N.])

Response: The land use reviewers on the review team considered the entirety of the MDC 

CDMP when arriving at the conclusions regarding land use conflicts in Sections 4.1 and 

5.1. The review team recognizes that the CDMP also includes issues that fall outside of 

traditional land use considerations. The EIS evaluates the impact of building and operating the 

proposed units on water resources in Sections 4.3 and 5.3 and on ecological resources 

including wetlands in Sections 4.4 and 5.4. No changes were made to the EIS in response to 

this comment. 

Comment: DEIS Subsection 2.2.2.3, Page 2-20, Lines 12-15: The DEIS states: "The reclaimed 

wastewater pipelines from the FPL RWTF would be routed south along the eastern side of the 

cooling canals to the makeup-water reservoir, traversing a mangrove forest..." The Turkey 

Point Units 6 & 7 Mitigation Plan, Revision 2, DEIS Reference (FPL 2011-TN1012), Section 

2.3.2 states: "The treated reclaimed water pipeline between the FPL reclaimed water treatment 

facility potential alternative location and the Site would be installed within construction 

access roadways, avoiding additional wetland impact." (emphasis added) (0619-3-4 [Maher, 

William])

Appendix E October 2016 E-89 NUREG–2176
Response: Data on acreages of terrestrial habitat affected by pipeline installation have been 

updated in Sections 4.1 and 4.3.1 of the EIS. Additionally, the review team has added 

information about in situ restoration activities planned for the reclaimed water pipeline to Section 

4.1 of the EIS to describe why some impacts from this pipeline can be considered 

temporary. However, the review team expects forested wetlands (i.e., mangroves) to be 

converted to herbaceous wetlands and to remain so for the operational life of the pipelines 

because standard practice dictates exclusion of woody vegetation from pipeline corridors due to 

root intrusion and subsequent maintenance issues. Although no net loss of wetlands would 

occur within the reclaimed water pipeline corridors, the conversion of forested wetlands to 

herbaceous wetlands within the corridors must be regarded as a permanent impact (at least for 

the operational life of the pipelines). The updated data do not alter any conclusions presented 

in the EIS. 

Comment: The DEIS text refers to the "9,640 ac Turkey Point site". The reference listed in the 

DEIS is FPL 2014-TN4058, FPL's ER. The ER text denotes this same area as the 

"approximately 9400-ac Turkey Point plant property". (emphasis added) Instances in the DEIS 

include: a. DEIS Section 1.0, Page 1-1, Line 12. b. DEIS Section 2.1, Page 2-1, Line 23. c. 

DEIS Section 3.1, Page 3-1, Line 30. d. DEIS Section 10.0, Page 10-1, Line 12. e. DEIS 

Appendix F-3, Section 1.0, Page 1-2, Line 10. References to the approximate 9400-ac Turkey 

Point plant property in the ER include (emphasis added): a. ER Subsection 1.1.2.2. b. ER 

Section 2.1. c. ER Subsection 2.2.1.1.1. d. ER Table 2.2-1 which lists 9459.94 acres as total 

land for Turkey Point Property. (0619-1-17 [Maher, William])

Response: The review team has reviewed all acreage figure information and updated acreage 

figures as appropriate in Chapters 1 and 3 and Sections 2.4, 4.3, and 5.3 of the EIS. The 

updated acreage figures did not alter the conclusions presented in the EIS. 

E.2.5 Comments Concerning Land Use - Transmission Lines 

Comment: I am opposed to above ground transmission line towers being installed along roads 

where citizens live. (0007-2 [Johnson, Nadine])

Comment: I was quite surprised this plan was going through given the public hearings and 

continued comments about...the overwhelming opposition to high voltage transmission lines 

running the US1 corridor right near residential neighborhoods. (0008-2 [Finver, Jody])

Comment: Second, the infrastructure necessary to support this project, including power cables 

traversing some of the best communities in South Florida, will lower property values and 

increase health concerns for our families. (0024-2 [Roque, Julio])

Comment: and the cities along US 1 where fp&l wants to put the huge transmission lines is 

being fought in court. (0055-6 [Roedel, Kitty])

Comment: There are other sites where high voltage poles can be placed that would cause less 

impact than placement so close to such a historically significant neighborhood as the Miami 

Roads neighborhood. The placement of these poles and lines are not even in sync with the 

presently existing criteria governing their building or placement. (0073-3 [Commenters, Multiple])

Comment: I am also concerned about the loss of value of our homes due the close proximity of 

these lines through our neighborhood. Should the lines be placed in the neighborhood, they 

Appendix E NUREG–2176 E-90 October 2016
should be buried underground to a level that will not pose a hazard to the neighborhood or 

those traversing the area. (0073-6 [Commenters, Multiple])

Comment: 3. Placing high voltage poles in a historically significant neighborhood such as the 

Miami Roads or South Miami Avenue Association is not the best of ideas. The placement of 

these poles in areas where they would cause less impact and where they would synchronize 

better with presently existing criteria governing their placement. 4. The hazards of 100 foot 

high electric poles within 50 feet of our homes where hurricanes or tornados could cause 

massive damage to both life and property by toppling onto roofs and causing fires. (0077-3 [de 

Armas, Maria Cristina])

Comment: Brickell Neighbors, I oppose the 10 Story Transmission Lines across Brickell 

Avenue. (0088-2 [Lange, Alexandra])

Comment: In addition to the underestimating the environmental impacts, FPL will degrade the 

quality of life of people in the pathway of the transmission lines. (0117-2 [Robertson, Alyce])

Comment: My townhouse is less than 250 feet from the 110 foot high transmission lines that 

will be built to carry the power from these new reactors. The effect upon my property value will 

not be positive, and FP&L will not reimburse us. (0205-1 [Hamilton, McHenry])

Comment: As a resident of Coconut Grove, I want to express my deep concerns over the 

power line plans routing over our neighborhood. Health concerns and property value issues 

should be a consideration when making routing plans. (0328-1 [Roque, Julio])

Comment: I am shocked to hear that FPL is planning to construct two (count them, two) new 

nuclear reactor units at Turkey Point. This ill-advised and high-risk project will engender miles of 

100-foot oversized poles with high-voltage lines throughout Miami-Dade county, including the 

historic and-at the moment-desirable neighborhood of The Roads. (0339-2 [Provost, Allan])

Comment: I live in Miami in an area called The Roads. We will be directly impacted by the FPL 

high voltage lines. (0372-1 [Ortiz, Natalia])

Comment: I oppose the expansion of the Turkey Point Nuclear Plant if it causes the placement 

of above ground power lines through any residential neighborhoods. (0377-1 [Hughes, David])

Comment: I oppose FPL's proposal to string a high-voltage, aboveground power line along US 

Hwy One. (0408-1 [Sifko, Basilio])

Comment: I worked amicably with FPL on many projects but must express deep and 

substantial opposition to the installation of high intensity power poles along US 1, a project 

which will impact the many diverse communities along this corridor and near Turkey Point in 

Miami-Dade County. (0510-1 [Langlieb Greer, Evelyn])

Comment: Should the lines be placed in the neighborhood, they should be buried underground 

to a level that will not pose a hazard to the neighborhood or those traversing the area. (0685-3

[Batista, Carlos])

Comment: Also costs to quality of life. I think some of the questions were about these 105 feet 

--5 foot transmission towers, which, as it happens, would cut my District in half, along 

commercial and residential corridors. (0721-1-7 [Rodriguez, Jose Javier])

Appendix E October 2016 E-91 NUREG–2176
Comment: I'm shocked to hear that FP&L is planning to construct two, count them, two, new 

nuclear reactor units at Turkey Point. This ill-advised and high-risk project will endanger miles 

with 100 foot oversized poles with high-voltage lines throughout Miami-Dade County, including 

the historic and at the moment desirable neighborhood of the Roads. Who know what will 

happen then. Are they going to buy our properties? Are they going to buy all of us out? I doubt 

it. (0721-26-3 [Koenigsberg, Linda])

Comment: Number three is that there are other sites where high voltage poles can be placed 

that would cause less impact then placement so close to such a historically significant 

neighborhood as the Miami Roads neighborhood. Now, the placement of these poles and lines 

aren't even in sync with the present of the existing criteria governing their building or placement.

(0721-31-6 [Almirola, Alejandro])

Response: These comments express concerns regarding the proposed assemblage and 

locations of transmission lines to distribute power into Miami-Dade County from proposed 

Turkey Point Units 6 and 7. The review team considered the environmental impacts of electrical 

transmission in EIS Section 4.1.2 and 5.1.2 for land use; 4.6 and 5.6 for historic and cultural 

impacts; 4.4 and 5.4 for socioeconomics impacts; and 5.8 for nonradiological health 

impacts. Electrical transmission, its siting and safety are outside the regulatory authority of the 

NRC and, in Florida, are regulated by the Florida Public Service Commission and appropriate 

state agencies. No changes were made to the EIS as a result of these comments. 

Comment: My biggest concern with this project is the proposed Power Lines that FPL is not 

willing to place underground, rather they're willing to place the lives of this community at risk by 

choosing the cheapest route. Erecting poles 150ft above ground is not only a eye sore but it's 

also poses a huge risk to the residents of this community during Hurricane Season. We've been 

fortunate thus far but in the event another Hurricane Andrew were to hit our community there is 

no guarantee that those poles could survive the devastating impact of high force winds. This 

poles should automatically be laid underground with FPL paying for the cost which is ultimately 

paid by the consumers of this community. Expecting municipalities to cover the cost of 8 million 

dollars per mile is absolutely ludicrous and doing so will most likely result in higher property 

taxes for the residents of the municipalities affected. (0034-3 [Rodriguez, Barbara])

Comment: Constructing the associated new 110' tall High Voltage Electrical Power Line 

Transmission towers, exempted from the high velocity hurricane zone requirements of the 

Florida Building Code, in a location that historically experiences Very High Velocity Hurricane 

force winds, at 200 foot intervals along the length of US One, the major north -south evacuation 

route for Dade County, poses unacceptable risks to the population of Dade County. Doing so is 

simply inviting catastrophe in the event of a natural or man-made disaster requiring evacuation.

(0044-7 [Commenters, Multiple])

Comment: In addition to the plants, FPL wants to erect more power lines along US 1. During a 

hurricane, exposed power lines are the first things to fall. Why are these not being place 

underground as other new power lines around the state? It is doable, a little more expensive at 

first to put in but we would have power during bad storms and there would be minimal repair 

costs, saving money in the long run. (0048-2 [Wegner, Geri])

Comment: Hurricane Andrew show me unrivaled destruction I couldn't have imagined nor can I 

forget if I live for a thousand years, I do seriously believe that if you construct 110 foot high 

carrier lines along US-1 on purpose, any decent hurricane will down those towers, and 

endanger millions of citizens[.] (0056-2 [McCall, Eric])

Appendix E NUREG–2176 E-92 October 2016
Comment: I am concerned about the hazards of 100 foot high electric poles that are within 50 

feet of our homes and, in a hurricane or tornado could cause massive damage, including 

toppling onto rooftops and causing fires. (0073-4 [Commenters, Multiple])

Comment: The Underline is an initiative to transform the land below Miami's Metrorail from the 

Brickell area to Dadeland South into a 10-mile linear park and urban trail. Miami is one of the 

country's most dangerous places to bike and walk in the country. The Underline will be Miami's 

first off-road mobility corridor providing a safe haven for bicyclists and pedestrians, greatly 

improving our city's bike and pedestrian infrastructure, safety and while also taking cars off our 

roads improving our traffic problems. What does this have to do with FPL? At the same time 

the vision for The Underline was ramping up, FPL was finalizing its preferred corridor for 

transmission line placement - right in the same place as the future Underline. (0076-1 [Daly, Meg])

Comment: The towers for the power line will be ten-stories tall (up to 105-feet), 4-feet wide, 

and placed every 200-400 feet. Moreover, they will not be built to Florida hurricane safety 

standards. This aspect of FPL's expansion project alone will make it more difficult to create 

beautiful, urban spaces, like the Underline, that improve public safety. (0076-3 [Daly, Meg])

Comment: Furthermore, 100 foot towers for transmission lines represents old technology and 

is dangerous. When we went through hurricane Wilma in 2006, only the city of Weston, with 

underground transmission lines, had power. (0080-2 [Reiter, Ben])

Comment: I sincerely hope you will withdraw your proposal to build additional nuclear plants 

and to install more giant size transmission poles in South Florida. I live in the City of West Miami 

and objected to the installation of the poles on SW 62nd avenue to no avail. Many countries in 

Europe have installed necessary transmission lines underground. What are we waiting for?

(0131-1 [Brown, Judith O.])

Comment: And the idea to route massive, unsightly power lines through a beautiful part of the 

city is just tone deaf to the residents of the area. Those power lines can snap when a hurricane 

hits because they aren't hurricane resistant strength. (0133-3 [Corral, Oscar])

Comment: If we have a hurricane and any of these poles fall, who is liable? If it falls on my 

house, will they fix my house? How long will it take to fix homes, roadways, buildings, etc? We 

need proof of liability. If placed underground, it should include a maintenance plan and who will 

pay for that? (0149-11 [Nelson, Joyce E.])

Comment: Why can't the lines be underground. They exist all over the world!!!! There are 

already plans to do a Green Link for biking and walking under the Metrorail from Dadeland to 

downtown Miami. The path would be directly next to these huge power poles. Check out the 

plan on greenlink.org. Has there been a coordinated plan with all projects for US1? Land use 

and zoning does not recommend this. Coral Gables, Pinecrest, and the City of Miami has filed a 

lawsuit and others will follow.! (0149-4 [Nelson, Joyce E.])

Comment: My street is favored as the "preferred alternative route" for the giant power 

transmission lines referenced below, which has been approved by Gov. Rick Scott and his 

entire cabinet. To construct such power lines on a residential street, which combines low-rise 

condominiums, a church and small businesses, is a complete travesty of justice that endangers 

our health, welfare and property values. (0184-1 [Perez, Danica])

Appendix E October 2016 E-93 NUREG–2176
Comment: The proposed towers will create a danger to all those living and working in close 

proximity to them, they will be an unnecessary eyesore running through some of Miami's nicest 

neighborhoods, and exponentially increase the traffic situation on US1 during the construction 

phase. (0187-5 [Meyer-Steele, Shawn])

Comment: Wires need to be underground. (0334-2 [Crystal, Chris])

Comment: Power lines must be underground near or through or neighborhoods! (0377-2

[Hughes, David])

Comment: It is wholly unjustifiable to place a high-voltage, aboveground power line along US 

Hwy 1. FPL has ample resources to place it belowground. The only justification for aboveground 

placement is to save a few dollars on one-time placement costs at the expense of our 

communities, which demonstrates FPL's utter contempt for residents who are also its 

customers. (0408-2 [Sifko, Basilio])

Comment: It is dangerous. Traffic accidents are not scripted...they happen. This is why they 

are called precisely those...accidents. Even reinforced concrete poles crack, break and fall 

when impacted by tractor-trailers and fuel-laden delivery vehicles traveling at 55 miles per hour, 

weighing several tons plus the weight of cargo or flammable liquid, namely, gasoline, to the 

Florida Keys. The assurances of FPL Counsel of absolute safety notwithstanding. (0408-3 [Sifko, 

Basilio])

Comment: It will negatively affect tourism. Along this same corridor, millions of tourists travel 

on their way to the world-known and widely visited ...Florida Keys. Imagine a tourist from any 

city flying into MIA, renting their car and traveling southbound on US Hwy 1. The welcome they 

would receive to the Florida Keys is a very visible, very unsightly and very dangerous highvoltage, aboveground power line strung for mile after mile. (0408-4 [Sifko, Basilio])

Comment: Homeowners and affected businesses along the proposed route will not watch 

passively and accept a situation in which a tiny handful of power company executives, who, by 

virtue of: vast power (by "power" I do not mean electricity); considerable influence at all 

government levels; and immense economic resources arbitrarily impose their will. We are 

actively organizing opposition. (0408-6 [Sifko, Basilio])

Comment: It would behoove counsel for FPL/NextERA to revisit a court case as old as me: 

Microwave Communications Inc. vs. (AKA MCI) American Telephone & Telegraph Company 

(AKA AT&T). The quarrel began in 1963 and the resolution was implemented January 1, 

1984. Careful examination strongly suggests similarities. MCI only asked for a license to 

provide two-way radio communications for truckers traveling Route 66 from Chicago to Joilet, 

Illinois. AT&T flexed its power, influence and economic resources in opposition. In the final 

analysis, Judge Harold Greene's decision ended the monopoly privilege enjoyed by AT&T. A 

monopoly privilege almost exactly as that enjoyed by FPL. I use the term "monopoly" because it 

is correct. There are substitutes but who among us uses candles to light our home? So we 

depend on FPL to generate and distribute power...safely. Some of us strongly believe some 

markets are what economists call "natural monopolies". Best served where the company can 

operate serving an "economy of scale". We do not seek to remove the privilege FPL enjoys 

under a monopoly pricing structure. We only ask FPL place its high-voltage power line 

belowground. FPL's latest Balance Sheet lists the account, "Goodwill & Intangibles", as an asset 

account with a zero balance. A protracted battle with the entities listed below and the inevitable 

media exposure will result in, "Goodwill & Intangibles", shifting to the Liabilities section and an 

Appendix E NUREG–2176 E-94 October 2016
account balance. How much of a balance is contingent upon FPL's intransigence and insistence 

at aboveground placement. There is a direct relationship between the two; the more FPL insists 

on aboveground placement, the more FPL's "brand" will suffer. The homeowners who would be 

adversely affected by this "quick-and-dirty" proposal are actively organizing to assure this 

proposal never becomes reality. We will do our best to make the proposal so public, and 

therefore so costly, the "fallout" will render it untenable. US Supreme Court Associate Justice 

Louis Brandeis was quoted as saying. "the best disinfectant is the sun". We agree and hoping 

(some of us praying) for bright sunny days until this issue is resolved to the satisfaction of the 

citizens of Miami-Dade and Monroe Counties. Nature supports our position ...for we are the 

Sunshine State. The NRC (Nuclear Regulatory Commission), the Florida Department of 

Tourism, The Florida Public Service Commission, environmentalist organizations, NGO's, 

affected municipalities and businesses will be contacted. Homeowners of record six city-blocks 

east and west and north and south will be culled from public records. Direct mail will be used to 

inform them how and why their property values will drop. Just as important are the residents and 

"mom-and-pop" businesses of Monroe County, specifically those in the Florida Keys whose 

primary source of income is tourism. It is they who will suffer the most economically. In the 

event moral suasion does not convince FPL to recognize right...as well as reality, available legal 

channels will be used; moratoriums and class-actions are possible eventualities. Preliminary 

research indicates legal fees alone could rival the marginal difference in underground placement 

We expect and are prepared for a protracted legal battle given the resources of FPL. Make no 

mistake there is a countervailing force to FP&L / NextERA's vast resources. It is called 

Democracy and we will exercise it. Lastly, we will see this ill-conceived, counterproductive and 

unsafe proposal never becomes reality. (0408-8 [Sifko, Basilio])

Comment: Expand Consideration of Transmission Line Impacts. ... the impacts of FPL's 

proposed transmission lines are not limited to construction-related disruptions. Comment 17: 

The final Environmental Impact Statement should disclose risks related to transmission 

lines not built to Florida hurricane safety standards. The transmission lines associated with 

this project will not be constructed to conform to Florida's Building Code, which specifically 

accounts for the high velocity hurricane zones common throughout South Florida. Instead, the 

transmission lines will be erected according to an industry-created minimum safety standard 

known as the National Electrical Safety Code (NESC). In short, structures built using NESC 

standards are significantly less hurricane resistant than structures built to Florida Building Code 

standards. The NESC is too large to attach to these comments. However, it is contained in the 

Site Certification Application that FPL submitted to the State of Florida. NESC Table 253-1 

shows the load factors for the highest velocity winds contemplated under that code. The table 

lists the relevant load factor as 1.00. Essentially, a load factor is a safety factor that accounts for 

construction error and establishes the amount of additional stress from wind, and related 

swaying, that the structure is able to withstand; designs using this standard will have 60% 

less loading, and less reliability, than required by building codes which account for high 

velocity hurricanes. This is a significant concern when many of the transmission poles proposed 

in the Turkey Point Nuclear Plant Units 6 & 7 application are over ten-stories tall. (0456-24

[Miami, City])

Comment: Moreover, the transmission line FPL plans to run through Miami will not be built to 

Florida hurricane safety standards. In a storm, the ten-story poles could collapse onto homes or 

the Metrorail. (0515-7 [Regalado, Tomas])

Comment: While transmission lines may be an eyesore, that is not the biggest issue with what 

is being proposed. The biggest issue IMO is that these transmission lines will not even be up to 

hurricane code (ie able to withstand hurricane force winds). As someone who has lived through 

Appendix E October 2016 E-95 NUREG–2176
several hurricanes in south florida, this is absolutely a NON-STARTER. I cannot build or 

remodel a home without it being to code, so FPL should NOT be allowed to construct these 

without ensuring that they can withstand hurricanes. (0570-2 [Martinez, Orlando A.])

Comment: Comment 18: The final Environmental Impact Statement should disclose risks 

related to transmission lines not built to Florida hurricane safety standards. The 

transmission lines associated with this project will not be constructed to conform to Florida's 

Building Code, which specifically accounts for the high velocity hurricane zones common 

throughout South Florida. Instead, the transmission lines will be erected according to an 

industry-created minimum safety standard known as the National Electrical Safety Code 

("NESC"). Structures built using NESC standards are significantly less hurricane resistant than 

structures built to Florida Building Code standards. The NESC is too large to attach to these 

comments. However, it is contained in the Site Certification Application that FPL submitted to 

the State of Florida. NESC Table 253-1 shows the load factors for the highest velocity winds 

contemplated under that code. The table lists the relevant load factor as 1.00. Essentially, a 

load factor is a safety factor that accounts for construction error and establishes the amount of 

additional stress from wind, and related swaying, that the structure is able to withstand; designs 

using this standard will have 60% less loading, and less reliability, than required by 

building codes which account for high velocity hurricanes. This is a significant concern when 

many of the transmission poles proposed in the Turkey Point Nuclear Plant Units 6 & 7 

application are over ten-stories tall. (0611-17 [Haber, Matthew S.])

Comment: The thought of FPL poles dotting US1 is unbearable. Haunting images in my head, 

I cannot understand how the poles would even be a consideration. We are the United States, 

one of the most advanced countries in the world. In other developed countries this issue is dealt 

by placing the cables underground. How is it possible that we, in the United States, would be 

taking a step forward with The Underline project and two steps back with how we deal with 

unsightly, antiquated, industrial-age ideas? (0616-1 [Puchades, Mary])

Comment: In addition the FPL plan requires the building of transmission lines through 

populous residential areas to downtown Miami. According to an editorial in the Miami Herald, 

these lines will not be built to Florida hurricane safety standards. Having lived through Hurricane 

Andrew in 1992, I am appalled by any such plan which would endanger the lives and property of 

thousands of our citizens. (0642-4 [Rawlins, Steve])

Comment: The proposed transmission lines will not be built to Florida hurricane safety 

standards. If a tower buckles during a storm, it could destroy the Metrorail and surrounding 

homes. (0675-5 [Rodriguez, Jose Javier])

Comment: Therefore, the solution proposed in #8 [burial of the transmission lines] is not an 

acceptable alternative to the plan. (0701-2 [Whitlock, Catherine])

Comment: And also, five, I'm concerned about the hazards of 100 foot high electric poles that 

are within 50 feet of our homes, and a hurricane or a tornado could cause massive damage, you 

know, toppling these things onto, you know, close by to my house. I live on 20th Road, you 

know, next to the Shell Gas Station on 20th and Coral Way, and I just think it's just a really bad 

idea that they're going to put those ugly things that nobody wants, and they're going to crash 

and ruin our neighborhood. Just terrible. (0721-31-7 [Almirola, Alejandro])

Appendix E NUREG–2176 E-96 October 2016
Comment: And the transmission line towers will be ten stories tall and will not be built to 

Florida Hurricane Safety Standards. If the NRC does not grant the licensing then the 

transmission lines also will not be built. (0721-4-4 [Regalado, Tomas])

Comment: And finally whereas transmission interconnection between the Turkey Point facility 

and the transmission system will be needed in order to support the electrical supply and 

reliability means of Miami Dade County customers. (0723-2-8 [Trowbridge, Mark])

Response: These comments express concerns regarding the proposed assemblage, 

capability, and placement of transmission lines to distribute power into Miami-Dade County from 

proposed Turkey Point Units 6 and 7. The review team considered the environmental impacts 

of electrical transmission in EIS Sections 4.1.2 and 5.1.2 for land use; 4.6 and 5.6 for historic 

and cultural impacts; 4.4 and 5.4 for socioeconomics impacts; and 5.8 for nonradiological health 

impacts. Electrical transmission, its siting and safety are outside the regulatory authority of the 

NRC and, in Florida, are regulated by the Florida Public Service Commission and appropriate 

state agencies. No changes were made to the EIS as a result of these comments. 

Comment: [I strongly oppose] the installation of the transmission lines through our 

neighborhoods or the everglades. (0092-2 [Merino, Miriam])

Comment: I recommend that you disapprove any further processing of their Turkey Point 

Nuclear Power plant expansion proposal for the reasons summarized below 4) The proposed 

project includes massive new transmission lines through Everglades National Park and the 

heart of Miami-Dade's densely populated commercial and residential areas on 105-foot tall steel 

towers. The towers would deface Dixie Highway and traverse residential neighborhoods in 

Pinecrest, South Miami, Coral Gables, Coconut Grove, and then go along Brickell Avenue on 

their way to downtown Miami. Apart from their appalling visual impacts, these lines would 

remove tens of millions annually from the county's tax base. Worse, FPL -- evidently to save 

costs -- proposes erecting those transmission towers without meeting Florida State hurricane 

safety standards. FPL did not adequately evaluate the risk of those towers buckling during the 

region's relatively frequent hurricane force storms. Their location would almost certainly risk 

those transmission lines and towers falling onto the adjacent MetroRail and surrounding homes. 

The costs in life and property, not to mention of disruption of transportation and electrical 

service during the aftermath of a storm would be catastrophic. This cost was not adequately 

assessed by FPL in their proposal. (0094-4 [Fairchild, David])

Comment: Does the DEIS consider that the area of proposed impact within ENP is a 

designated UNESCO World Heritage Site in Danger, a Ramsar Wetland of International 

Importance, a Specially Protected area under the Cartagena Convention and an Outstanding 

Florida Water and a Miami-Dade County designated Area of Critical Environmental Concern 

where the proposed roads are specifically prohibited in portions of the proposed corridor?

(0110-1-2 [Hefty, Lee N.])

Comment: Florida Power & Light plans to erect a series of huge concrete light poles each 

more than 100 feet tall, with a 35 square foot footprint. These concrete structures are intended 

to carry the energy created by the new reactors north so the energy can, for the near future at 

least, be sold. FPL would like to run its gigantic poles through our national park, the Everglades! 

This would have a huge impact on this national treasure and severely impact the plants and 

animals in the park., Local cities, as well as citizen groups, have protested the erection of these 

towers, asking instead that the lines be buried. FPL says it will consider burial only of the local 

communities provide the money. Although the power is not intended for the citizens in these 

Appendix E October 2016 E-97 NUREG–2176
cities and the towers provide no benefits to the community, they want us to pay to have the lines 

buried! Their plan is to run the power towers parallel to US 1, a major thoroughfare for our 

residents. First, it would run north on the west side of US 1, totally destroying the value of 

homes nearby.It would continue north, running by the Metrorail, our local mass transit system, a 

narrow strip of land currently a bicycle path and planned as an urban linear park. (0115-8

[Trencher, Ruth])

Comment: Florida, Power, and Light is planning to place 2 nuclear reactors and transmission 

lines of high voltage, approximately 80-105 feet tall and the size of a 10 story building, along 

US1 from the Homestead to Downtown Miami. If built, such transmission lines will impact my 

community. FPL will be contacting you and the cabinet for approval and we want you all to know 

our community along this route is outraged. Please defer this until all questions are answered, 

reviewed and the constituents are informed. (0149-2 [Nelson, Joyce E.])

Comment: [I] oppose the transport of energy across or through the fragile Everglades. Our 

river of grass which feeds into Florida Bay and supports and entire eco system has been 

devastated in the past by the effects of phosphorus and fertilizer from the sugar industry and 

has killed off the grasses in the bay where shrimp spawn. (0360-2 [Palmer, Majorie])

Comment: I also don't like that the power lines would run through the Shark River Slough. 

There are power lines running north along 27. Let there be areas that are just wild. (0361-3

[Berndgen, Michelle])

Comment: 7) Description of the Affected Environment, Especially Relating to the State of 

Florida Site Certification Process 

The DEIS does not provide accurate geographical descriptions, hydrology, and Western 

Corridor language pertaining to the Florida Site Certification Process and up-to-date information 

relating to the Western Corridor which represents the location for the transmission power lines 

that was approved in the Siting Order. Although the Final Siting Order has been appealed, the 

DEIS should be updated to include not only the Final Siting Order as it relates to the proposed 

expansion and the location of the powerlines, but also the Conditions of Certification for these 

features that are the subject of this DEIS as it provides the anticipated framework for the 

implementation of these features. (0622-1-15 [Austin, Stan])

Comment: 

Status of State of Florida Site Certification Process Pertaining to Western Corridors 

Introductory text on pages 1-1 to 1-2 regarding the State of Florida's May 2014 certification of 

the Turkey Point project is incomplete. As written, it suggests the certification process has 

concluded and FPL has all the State, regional and local permits needed for the project. We 

encourage a revision of this section to note that Miami-Dade County has appealed the 

certification of the West Preferred Corridor for transmission lines and three municipalities have 

appealed the location of transmission lines in the Eastern Corridor. Certification of the West 

Consensus Corridor was not appealed. The appeal process is anticipated to continue through 

the fall of 2015 or longer. Until there is a non-appealable Final Order, FPL does not have the 

State, regional, and local approvals needed to use the West Preferred Corridor as the backup 

location for its western transmission lines. 

Text on page 2-18 regarding the Site Certification Process is incomplete. We recommend 

adding the following text to describe the Final Order and the Siting Board's direction to 

Appendix E NUREG–2176 E-98 October 2016
maximize use of the West Consensus Corridor to avoid siting transmission lines in Everglades 

NP: 

["]On May 19th, 2014, Florida's Governor and Cabinet, sitting as the Siting Board, issued 

a Final Order (FO) of Certification that approved FPL 's application to construct and 

operate two new nuclear generating units at Turkey Point, approved the transmission 

lines to be located in the East Preferred Corridor, and approved the western transmission 

lines to be located in the West Consensus Corridor with the West Preferred Corridor as 

the backup location if a right-of-way in the West Consensus Corridor cannot be obtained 

in a timely manner and at a reasonable cost. The FO directs FPL, the affected rock 

mining companies, and the South Florida Water Management District to pursue the option 

of fully accommodating the western transmission right-of-way to the east of the L-31N 

canal to avoid siting any transmission lines in Everglades NP. In areas where FPL is 

unable to build and maintain its structures east of the L-3JN canal (outside of ENP), the 

FO directs that FPL shall only use the minimum amount of land west of the L-31N canal 

(inside the current boundaries of ENP) that is necessary to build and maintain the 

structures, and FPL shall return to installing structures to the east side of the L-31N canal 

at the first available and practicable location. The Siting Board's certification of the West 

Preferred Corridor and the East Corridor is currently under appeal. The timeline for a 

decision by the Appeals Court is anticipated to continue through the fall of 2015.["] 

Section 2.2.2.1 Western Corridors[.] We are concerned with the accuracy and completeness of 

information regarding the West transmission corridor on page 2-17. Text on lines 5-7 states FPL 

has "two options for the West corridor that differ primarily with respect to where the corridor 

would pass near Everglades NP (even though no part of the corridor would actually pass 

through the park)." The last half of this sentence is inaccurate. The West Preferred and West 

Consensus corridors overlap and traverse five to six miles of lands currently within the park 

boundary. 

Similarly, the West Preferred Corridor text (page 2-17, lines 13-24) states that the West 

Preferred Corridor runs just east of the park boundary. This is inaccurate at the present time. 

The West Preferred Corridor north of SW 120 St. and west of the L-31N canal includes 260 

acres of NPS land along 6.5 miles of the eastern park boundary. NPS is currently preparing an 

EIS that considers exchanging park lands in the West Preferred and West Consensus corridors 

for FPL lands farther west in the park. The Final NPS EIS and Record of Decision on the 

potential land exchange are anticipated to be complete in December 2015. Until the ROD is 

signed, the existing status of NPS lands in the West corridor should be described in the NRC's 

EIS. 

The West Consensus Corridor text (page 2-17, lines 25-31) states that portions of the 

Consensus Corridor "have been shifted to the east to avoid abutting the eastern perimeter of 

Everglades National Park." This is partially accurate but omits noting that the Consensus 

corridor overlaps the West Preferred corridor for 5 miles and includes approximately 200 acres 

within the current park boundary. It may be several years after a non-appealable Final Order of 

Certification is issued before FPL knows if it will be able to use any of the Consensus Corridor 

for the west transmission lines. The following text is recommended to be included in a revised 

DEIS to provide a more complete description of the corridor: 

["]The Consensus Corridor follows the West Preferred Corridor until it reaches a point 

approximately six miles south of Tamiami Trail. There, the Consensus Corridor expands the 

Appendix E October 2016 E-99 NUREG–2176
width of the corridor by 600 feet to the east of the West Preferred Corridor for a distance of 

about 5 miles until it reaches a point one mile south of Tamiami Trail. This segment includes 

approximately 200 acres of land within the current boundary of Everglades National Park and 

rock-mining lands on the east side of the L-31N canal. Then, the Consensus Corridor turns to 

the east for a distance of about 2.5 miles, turns northeast through the Bird Drive Basin and 

passes through the Pennsuco wetlands north of Tamiami Trail to intersect with the West 

Preferred Corridor. The Consensus Corridor differs from the West Preferred Corridor in that it is 

wide enough to potentially allow FPL to locate the full right-of-way on the east side of the L-31N 

Canal to avoid siting transmission lines within the current boundary of Everglades National Park. 

The alignment through the Bird Drive Basin and Pennsuco wetlands would locate transmission 

lines farther to the east of endangered Wood stork colonies in Everglades National Park and 

Water Conservation Area 3-B. This corridor still crosses a landscape consisting mostly of 

wetlands and disturbed wetlands, but FPL states that its use would reduce the potential for 

adverse impacts on multiple federally endangered species (FPL 2013-TN2941).["] (0622-1-16

[Austin, Stan])

Comment: It is for these reasons, we respectfully request that NRC and USACE revise the 

DEIS to address these issues. An update to the DEIS analysis should:...more fully address the 

current information related to the Florida Siting Board's Conditions of Site Certification that 

address features of the plant components that may affect the environment, including the RCWs 

and other associated infrastructure, including the construction of power lines. (0623-12 [Austin, 

Stan])

Comment: The heart of Everglades restoration, the reason we're doing Everglades restoration, 

now we're going to align it with three massive power lines and that's what hundreds of 

thousands of visitors are going to see when they come to Everglades National Park. The first 

thing they're going to see is these three 150-foot power lines going up over there...[and] the 

pads... (0723-9-11 [Schwartz, Matthew])

Response: These comments express concerns regarding the potential effects of the proposed 

transmission lines to support Turkey Point Units 6 and 7 on ecological resources including the 

Everglades National Park. Although electrical transmission and its safety and siting are outside 

the regulatory authority of the NRC, the review team considered the environmental impacts of 

electrical transmission, which are described in Sections 4.1.2 and 5.1.2 for land use; 4.3.1, 

4.3.2, 5.3.1, and 5.3.2 for terrestrial and aquatic resources including the Everglades National 

Park; and 4.4 and 5.4 for socioeconomics impacts. 

Regarding Everglades National Park, the NPS signed a ROD transferring 260 ac of land to FPL 

in exchange for 360 ac of FPL property within the East Everglades Expansion Area 

(EEEA)(NPS 2016-TN4532). The ROD incorporates the Conditions of Certification from the 

Final Order on Certification from the State of Florida Siting Board dated May 19, 2015 (State of 

Florida 2014-TN3637). As a result of this land exchange, no portion of any proposed power line 

corridor would fall within Everglades National Park. A description of the land exchange was 

added to Section 2.2. In addition, the designation of Everglades National Park as a Miami-Dade 

County designated area of critical environmental concern was added to Section 2.2. The status 

of the State of Florida site certification process was updated in Sections 1.0 and 2.2. 

Comment: The East Preferred Corridor for the transmission lines runs through the Homestead 

Air Reserve Base (HARB) Accident Potential Zone II (APZ II). APZ II is an area beyond the end 

of runway which possesses a measurably higher potential for aircraft accidents. This area is 

identified in the base Air Installation Compatible Use Zone (AICUZ) Study. Recommendations 

Appendix E NUREG–2176 E-100 October 2016
from the base's AICUZ should be a major consideration in any planning process. (0670-1

[Hyden, Brent A.])

Comment: The goal of the Department of Defense's (DoD) long standing AICUZ program is to 

promote public health, safety and general welfare while also protecting military airfields from 

encroachment that would in turn jeopardize the military mission. The land use guidelines for the 

Air Force AICUZ programs are outlined in DoD Instruction 4165.57, Change 1, 12 March 2015. 

The suggested land use compatibility guidelines for APZ II are located in the referenced DoD 

instruction, Appendix 2, Enclosure 3, Recommended Land Use Compatibility in APZs, which 

begins on page 16. Here you will find Table 1 which includes the Standard Land Use Coding 

Manual (SLUCM). Utilities are listed on page 17 of this Table. SLUCM 48 (Utilities) shows that 

while some utilities are allowed in APZ II, note 6 states: "No above ground passenger terminals 

and no above ground power transmission or distribution lines. Prohibited power lines include 

high-voltage transmission lines and distribution lines that provide power to cities, towns, or 

regional power for unincorporated areas". HARB recognizes the fact that FPL owns a right-ofway in this area. HARB also recognizes that transmission lines already exist. However, we feel 

that adding more transmission lines coupled with the fact that these new lines will also be 

positioned higher than the existing lines, will put our pilots and the public at increased risk. 

Should an aircraft impact these transmission lines, the consequences could be a loss of life, and 

a loss of electrical power to a large part of the county. As such, we recommend that the 

transmission lines be routed through either the West Preferred Corridor or the West Secondary 

Corridor. Both of these corridors would run the transmission lines through areas outside of the 

APZs and therefore not put at risk U.S. Air Force pilots or the community. (0670-2 [Hyden, Brent 

A.])

Response: The Air Installation Compatible Use Zone (AICUZ) was reviewed as a part of the 

analysis performed for the EIS, and is cited in Section 4.1 of the EIS. The new transmission line 

proposed in the East Corridor would be collocated with the existing transmission line as 

described in that section of the EIS, and as noted by the commenter. The portion of the 

transmission line that would traverse the Accident Potential Zone II (APZ II) alongside the 

existing transmission line between the Clear Sky and Davis substations would be a little less 

than a mile long at the end of the zone delineated in the AICUZ (Figure 3-1). The EIS has been 

revised to include this information. 

Comment: And we have modeled the same costs from the transmission lines infrastructure 

which turn out to be significantly greater than the temporary benefits. The permanent costs per 

year are greater than the temporary benefits that are going to end. (0721-2-14 [Stoddard, Philip 

K.])

Response: Section 10.6 of the EIS presents a benefit-cost balance performed by the review 

team for the Units 6 and 7 project, including associated new transmission line 

infrastructure. While Table 10-4 of the EIS acknowledges potentially MODERATE costs 

associated with the land use and terrestrial ecology impacts, the analysis in Section 10.6 

concludes that the benefits of the project likely outweigh the costs. Therefore, no changes to 

the EIS were made as a result of these comments. 

Comment: There are instances in the DEIS with respect to the presented land use values in 

their respective tables, which are inconsistent with the cited source or not current with the most 

recent documentation/reference. Instances in the DEIS include (emphasis added): a. DEIS 

Subsection 2.2.2.1, Page 2-15, Table 2-4: In DEIS Table 2-4 contains acreages for the existing 

and proposed transmission corridors. The following inconsistencies are noted with the cited 

Appendix E October 2016 E-101 NUREG–2176
source for DEIS Table 2-4, (FPL 2014-TN4058) (areas where the data is inconsistent with the 

most current reference are also indicated): i. Information for the West Secondary Corridor is 

included, while information for the West Consensus Corridor is not included. The West 

Secondary Corridor was removed from consideration in 2013 at the time the West Consensus 

Corridor was adopted. [DEIS Reference (FPL 2013-TN2941)]. ii. The acreage for the proposed 

"Clear Sky-Levee Leg 1"/ "Clear Sky-Pennsuco Leg 1" is listed as 1378.9. ER Table 2.2-3 and 

DEIS Table 2-5 lists the total acreage, 1365.43, for the same route. (Note the total acreages for 

mentioned corridors are accordingly inconsistent.) iii. The total length of the "Clear Sky-Levee" 

is listed as 44 miles. ER Subsection 2.2.2.2 lists the total length as 43 miles. iv. The 

intermediary lengths for the co-located legs of "Clear Sky-Levee" and "Clear Sky "Pennsuco" is 

listed as 27.5, 13, and 4.5 for Leg 1, Leg 2, and Leg 3, respectively, and gives the total of these 

three legs as 44. ER Subsection 2.2.2.2 lists the total length as 43 miles and no intermediary 

lengths are provided in the ER. b. DEIS Subsection 2.2.2.1, Page 2-18, Table 2-5: In DEIS 

Table 2-5 contains total acres of transmission line corridors and access roads by major 

FLUCFCS code. The following inconsistencies are noted with the cited sources for DEIS Table 

2-5, [(FPL 2014-TN4058) and (FPL 2013-TN2941)]: i. Listed under "West Consensus Access 

Roads" are 11 different segments. As stated in DEIS Section 2.2.2.1, Transmission-Line 

Corridors, and DEIS reference (FPL 2013-TN2941), only four proposed access road corridors 

for the West Consensus corridor have been designated: NW 12th Street, Tamiami Trail, L-31 

Canal and Levee, and SW 88th Street. ii. The acreage listed for FLUCFCS code 600 under 

"West Consensus Access Corridor", segment for the L-31 Canal is 4.2 ac. DEIS reference (FPL 

2013-TN2941) Table 1 lists this entry as 4.7 ac. ii. The presented summation of the acreage for 

FLUCFCS code 800 listed for both the "West Preferred Corridor" and "West Consensus 

Corridor", segments for the Levee to Pennsuco is 24.8 ac. ER Table 2.2-3 provides the 

individual acreage by FLUCS code subcategory. For code 800, under the Levee to Pennsuco 

route, the sum is 34.8 ac. c. DEIS Subsection 2.2.2.3, Page 2-20, Table 2-6: DEIS Table 2-6 

contains total acres of reclaimed water pipeline and the potable water pipeline by major 

FLUCFCS land-use categories. The following inconsistencies are noted with the source cited for 

DEIS Table 2-6, (FPL 2014-TN4058): i. Four of the values for the reclaimed water pipeline are 

inconsistent with the ER. DEIS Table 2-6 for codes 200, 500, 600, and 800 lists 496.64, 74.89, 

447.80, and 672.05, respectively, while the summation of the values listed on ER Table 2.2-6 for 

codes 200, 500, 600, and 800 are 496.65, 78.06, 457.75, and 669.29, respectively. ii. Four of 

the values for the potable water pipeline are inconsistent with the ER. DEIS Table 2-6 for codes 

400, 500, 600, and 800 lists 7.69, 24.75, 159.95, and 39.21, respectively, while the summation 

of the values listed on ER Table 2.2-6 for codes 400, 500, 600, and 800 are 7.65, 24.72,158.95, 

and 39.19, respectively. d. DEIS Subsection 2.2.3, Page 2-23, Table 2-7: DEIS Table 2-7 

reports the acres within the 50 mile region using FLUCFCS. The following inconsistency is 

noted with the source cited for DEIS Table 2-7 (FPL 2014-TN4058): i. Two of the values, for 

codes 600 and 800, listed as 1,409,912 and 42,570, respectively, are inconsistent with ER 

Table 2.2-8. The summation provided in ER Table 2.2-8 for codes 600 and 800, are 1,416,931 

and 42,588, respectively. (0619-2-1 [Maher, William])

Comment: Numerical value inconsistencies within the draft EIS: Subsection 4.1.2.2, Page 4-

23, Lines 7-10 "The affected land comprises... 1.81 ac of existing electric power facility land

(FLUCFCS Code 831)...plus...0.52 ac of adjoining land designated as exotic wetland 

hardwoods (FLUCFCS Code 619)." DEIS Subsection 4.3.1.2 Page 4-50, Lines 29-31 ER Table 

2.2-5 DEIS Section 4.3.1.2: "Approximately 1.81 ac...is classified as exotic wetland 

hardwoods, and the remaining 0.52 ac is existing electric power facilities (FPL 2014-

TN4058)." ER Table 2.2-5 lists the Levee Substation acreage for FLUCCS code 619, Exotic 

Wetland Hardwoods, as 1.81 ac, and for FLUCCS code 831, Electric Power Facilities as 

0.52 ac. (0619-2-34 [Maher, William])

Appendix E NUREG–2176 E-102 October 2016
Response: The review team updated acreage information in the EIS to be consistent with data 

provided in Revision 6 of the ER or more recent responses to Requests for Additional 

information (RAI). The conclusions in the EIS were not altered by these changes. 

Comment: If the Army Corps of Engineers will have to decide to issue, deny, or issue with 

modifications a Department of the Army (DA) permit for the portions of the West corridor that 

would be constructed within wetlands, shouldn't the DEIS provide all available information on 

what alternatives are potentially available? Miami-Dade County requests that the NRC explain 

why only the West Preferred and West Consensus transmission corridors were considered as 

West corridor alternatives in the DEIS, when several alternatives for the West corridor were 

presented to the State of Florida and "all of the western alternate corridors met the criteria for 

certification" (State of Florida, Division of Administrative Hearings, Application No. PA 03-45A3, 

Florida Power & Light Company Turkey Point Units 6 & 7 Power Plant Siting Case No. 09-

3575EPP, Recommended Order, Section III.C.2.d., paragraph 511). Miami-Dade County 

requests that the NRC explain why the DEIS does not provide information or analysis of all of 

the alternative corridors presented to the State of Florida, including the West Consensus and 

West Preferred corridors, that includes an assessment of which of these are practicable, which 

of the alternatives have less adverse impact on the aquatic environment, and which of the 

alternatives have other significant adverse environmental consequences. Miami-Dade County 

requests that the DEIS be revised or a supplemental EIS performed in order to evaluate and 

compare all of the possible western alternate corridors that met the criteria for certification under 

provisions of the State of Florida Transmission Line Siting Act, and at a minimum, evaluate 

which of these are practicable (including which of the alternatives meet local regulatory and land 

use requirements), which of the alternatives have less adverse impact on the aquatic 

environment, and which of the alternatives have other significant adverse environmental 

consequences that the Army Corps of Engineers should consider. It is Miami-Dade County's 

position that that the corridor submitted by the National Parks Conservation Association (NPCA) 

for certification by the State of Florida is the only proposed corridor other than the West 

Consensus corridor that could meet Miami-Dade County's strict environmental regulations for 

the East Everglades Area of Critical Environmental Concern. Miami-Dade County asserts that 

the NPCA corridor is a practicable alternative to the West Preferred corridor and has 

significantly less adverse impact on the aquatic environment because it does not require the 

construction of transmission lines and associate infrastructure within the current boundaries of 

Everglades National Park and because it avoids impacts to high quality wetlands in this area. 

This alternative therefore meets the requirements for the Section 404(b)(1) Guidelines that "no 

discharge of dredged or fill material into waters of the United States (including jurisdictional 

wetlands) shall be permitted if there is a practicable alternative that would have a less adverse 

impact on the aquatic environment, as long as the alternative does not have other significant 

adverse environmental consequences". (0110-1-3 [Hefty, Lee N.])

Response: The USACE will complete an independent evaluation of the proposed project after 

publication of the final EIS. The USACE's independent ROD regarding the proposed permit will 

reference the analyses in the EIS and will also present any additional information required by 

the USACE to support its permit decision. This will likely include the USACE's determination on 

the LEDPA, the consideration of impacts to the aquatic environment, PIR factors, consideration 

of all comments received, and compliance with applicable laws and regulations. The USACE's 

final decision document was not addressed in this EIS because the document is separate and 

independent and will not be completed until after the final EIS is issued. The siting of the 

electrical transmission lines is outside the regulatory authority of the NRC so the NRC does not 

propose alternatives to the routes included in the application submitted by FPL. However, the 

review team (which includes the USACE) considered the environmental impacts of electrical 

Appendix E October 2016 E-103 NUREG–2176
transmission, which are described in Sections 4.1.2 and 5.1.2 (land use); 4.3.1, 4.3.2, 5.3.1, and 

5.3.2 (ecological impacts); 4.6 and 5.6 (historic and cultural impacts); 5.7.3 (meteorological and 

air quality impacts); and 5.8 (nonradiological health impacts). No changes were made to the 

EIS as a result of this comment. 

Comment: The NPS suggests that revisions to the DEIS consider the specific purposes the 

Everglades NP Protection and Expansion Act of 1989, which expanded the boundaries of the 

park to include approximately 109,600 acres. This analysis is especially important for USACE 

as they consider their public interest review. The NPS's DEIS found that the construction and 

operation of powerlines in the West Preferred Corridor would have adverse impacts on park 

resources and values that would be inconsistent with the Expansion Act purposes. (See DEIS 

pp 54-55 Table 2, How Alternatives Meet Project Objectives.) (0622-1-27 [Austin, Stan])

Response: This comment references the NPS findings in its final EIS for acquisition of a parcel 

of land owned by FPL in the EEEA of Everglades National Park. Concerns regarding the 

location of transmission lines near Everglades National Park are noted in Section 4.1.2 of this 

EIS. Although the siting of the electrical transmission lines is outside the regulatory authority of 

the NRC, the review team (which includes the USACE) considered the land use impacts of 

electrical transmission, which are described in Sections 4.1.2 and 5.1.2. 

Comment: [Three new sets of power lines will cause] changes to the hydrology of the Shark 

River Slough (the "crown jewel" of Everglades restoration) due to tower pads and road 

construction[.] (0240-10 [Commenters, Multiple])

Comment: [A] new, unsightly, industrial landscape - visible for miles - for visitors to one of our 

country's most unique and popular wilderness areas. (0240-11 [Commenters, Multiple])

Comment: NRC is planning three new sets of power lines to run across and through the 

eastern section of Everglades National Park. (0250-3 [Fulks, Anna Louise])

Comment: In addition, power lines from the expanded plant could be run across the eastern 

side of Everglades National Park. (0356-3 [Shlackman, Jed])

Comment: There are also three sets of massive power lines going inside Everglades National 

Park at the heart of Everglades restoration. (0366-3 [Griffith, Ed and Harriet])

Comment: Power lines from the expanded plant could also be run across the eastern side of 

Everglades National Park. (0366-8 [Griffith, Ed and Harriet])

Comment: Power lines from the expanded plant would likely run across the eastern side of 

Everglades National Park, further impacting the natural treasures of this area. (0370-4 [Vayu, 

Satya])

Comment: In addition, the power lines through the Everglades, a World Heritage site and the 

location near the Biscayne NP, is reprehensible. (0550-2 [H., Pat])

Comment: Much of the energy that this expansion of Turkey Point produces will be directed to 

other areas of the state requiring massive power line towers that are dangerous to migrating 

birds and an eyesore for the hundreds of thousands of visitors to Everglades National Park.

(0579-4 [Schwab, Roy])

Appendix E NUREG–2176 E-104 October 2016
Comment: Transmission line impacts. We have concerns regarding the proposed transmission 

line corridor route potentially impacting the Everglades National Park. The second and third legs 

of the West Preferred Corridor would traverse a landscape just east of the Everglades National 

Park characterized by wetlands and disturbed wetlands; a portion of the second leg would be 

adjacent to the eastern perimeter of the park (page 2-17). EPA is concerned with the lack of 

information in the DEIS regarding the National Park Services' (NPS) DEIS (Acquisition of Florida 

Power & Light Company Land in the East Everglades Expansion Area Draft Environmental 

Impact Statement, January 2014). The NPS decision regarding the land exchange action will 

greatly influence which transmission corridor is viable. Recommendations: The FEIS should 

clarify the impacts to the Everglades (particularly to the Everglades National Park) associated 

with the Western Preferred Corridor, and better describe the NPS land exchange DEIS. Efforts 

should be made to avoid impacts to the extent feasible, and to effectively mitigate impacts 

where they are unavoidable. (0617-4-11 [Mueller, Heinz J.])

Comment: FPL's Eastern Corridor would include the addition of a 230 kV (up to 90 ft. tall) 

powerline. The Eastern Corridor crosses a portion of Biscayne NP along a FPL easement and 

crosses the road leading to the entrance to the park's visitor center. The conclusion that locating 

the Eastern Corridor along U.S. Highway One and the metro rail line would result in minimal 

visual impacts is unsubstantiated. FPL's West Preferred and West Consensus corridors cross 

lands located within and near the Everglades NP boundary. Either route would contain two 500 

kV transmission lines (up to 160 ft. tall) and one 230 kV (up to 90 ft. tall) powerline. Importantly, 

the NPS's Acquisition of FPL land in the East Everglades Expansion Area DEIS found that the 

construction and operation of three powerlines and associated fill pads and access roads in 

West Preferred Corridor would result in minor to major impacts on park visual resources. 

If powerlines are built in FPL's West Preferred Corridor, they would be located west of the L3lN 

levee road on roadless wetlands currently inside Everglades NP (not east of the canal on SW 

187th Ave). The NPS DEIS found that the introduction of three powerlines, fill pads, and access 

roads inside the current NPS boundary would result in minor to major adverse impacts on visual 

resources. The most severe impacts would be where the powerlines cross Tamiami Trail and 

from the L-31N canal levee road. See NPS DEIS pages 364-370, and photo simulations of 

powerlines looking west from the L-3lN Canal (Figure 59 on page 361) and looking northwest 

from the L-31N Canal (Figure 63 on page 369), and looking west on Tamiami Trail (Figure 61 on 

page 365). 

If powerlines are built in the West Consensus Corridor, east of L-31N canal along SW 187th 

alignment, the impacts to park visual resources could be less depending on how much of the 

Consensus Corridor is used. The NPS questions how a horizontal road would "attenuate" the 

visual contrast of a powerline, which has vertical structures and elevated horizontal conductors. 

Because the access road along the levee isn't substantially elevated and is generally 

unnoticeable from the park, we maintain this statement should be revised to indicate the 

expected level of contrast and visibility of the powerline. (0622-1-12 [Austin, Stan])

Comment: One of the requirements of this evaluation is to look at the impacts of this plant on 

the two national parks. These parks are situated next to the Turkey Point Power Plant. The 

building of two additional reactors will increase the need for power lines near or in Everglades 

National Park. These power lines will impact birds and affect the visual expansiveness of the 

park. They are an extreme negative to visitors in the area. The power lines are a direct effect of 

permitting the two new reactors. (0641-10 [Martin, Drew])

Appendix E October 2016 E-105 NUREG–2176
Comment: In addition, power lines from the expanded plant could be run across the eastern 

side of Everglades National Park. (0676-3 [Kassel, Kerul])

Comment: The power lines through Everglades National Park on the eastern side are part of 

this project. My organization has been fighting that for years. Many, many questions remain 

about those. What are the impacts from building a major power line corridor along the east side 

of Everglades National Park with access roads, pads for many, many towers that are standing 

there. (0721-22-3 [Schwartz, Matthew])

Comment: [You've got] changes to the hydrology of Shark River Slough. That place was 

added to Everglades National Park in 1989 for the restoration of the Shark River Slough, the 

crown jewel of Everglades's restoration. And now it's going to be lined with three major FP&L 

power lines from the Turkey Point plant that points north? (0721-22-5 [Schwartz, Matthew])

Comment: Furthermore, FP&L has proposed constructing power lines in Everglades National 

Park. These power lines would severely endanger the incredible viewsheds that really define 

the experience in Everglades National Park, and could threaten endangered Wood Stork 

habitat. (0721-9-4 [McLaughlin, Caroline])

Comment: But then I didn't even realize three power lines in the Everglades? (0723-11-6

[Berendsohn, Catherine])

Comment: Furthermore, FPL has proposed constructing power lines in Everglades National 

Park. This could severely affect and endanger wood stork habitat and some of the incredible 

views that really just define the visitor experience in the Everglades. (0723-4-5 [McLaughlin, 

Caroline])

Comment: First of all, this application includes three master power lines across Everglades 

National Park. (0723-9-9 [Schwartz, Matthew])

Response: Although electrical transmission is outside the regulatory authority of the NRC, the 

review team considered the potential impacts of transmission lines in Sections 4.1.2, 4.3.1.2, 

4.4.1.6, 5.1.2, 5.3.1.2, and 5.4.1.6. The text of the EIS has been revised to reference the 

findings of the NPS in its EIS on the NPS's acquisition of FPL land in the EEEA regarding visual 

impacts of construction and operation of a transmission line in or near the Everglades National 

Park. 

Comment: Considerations for Mitigating Impacts from Project Infrastructure[.] Below are 

suggestions for mitigating impacts to NPS resources from proposed project infrastructure. We 

have aligned each topic area according to USACE's public notice from March 13, 2015. 

New Transmission Lines[.] As discussed previously, FPL's two western corridors are adjacent to 

and within Everglades NP. It would contain two 500 kV powerlines (up to 150 ft. tall) and one 

230 kV (up to 105 ft. tall) powerline. FPL's eastern corridor would contain a single 230 kV (up to 

90 ft. tall) powerline that would be built alongside an existing FPL powerline corridor. The 

corridor crosses a section of Biscayne NP. For wetland impacts in the western corridor, we 

support FPL's proposal to conduct mitigation within the "Hole in the Donut," which is within 

Everglades NP. We also recommend preparation of a planning study to consider the 

effectiveness of transferring soil to Miami-Dade County to use in raising the elevation of certain 

levees and for agricultural use to potentially reduce impacts of flooding. To offset added visual 

and ecological impacts to Biscayne NP from the eastern corridor, we suggest consideration be 

Appendix E NUREG–2176 E-106 October 2016
given to the purchase of the Ragged Keys, which are located on the end of Elliot Key. Ragged 

Key 5 and 2 are priority lands for the park and are the only fee-simple lands within the park 

boundary not yet owned by the NPS. 

The NPS recommends that FPL work with NPS to identify and remove unnecessary 

transmission infrastructure within Everglades NP, such as that which remains in the Chekika 

area of the park. In addition, we recommend FPL work with Everglades NP and other 

Everglades restoration partners to relocate the powerline located along the Old Tamiami Trail 

within the park, south of the current U.S. Hwy 41 west of the L-67 canal. Converting this 

powerline to an underground transmission line along the current U.S. 41 alignment could 

improve reliability of electrical service to the Miccosukee Reservation, allow for removal of the 

Old Tamiami Trail to achieve restoration benefits, and reduce impacts to wildlife from the current 

aerial transmission line. 

Units 6 & 7 Site[.] The Nuclear Island, which includes Units 6 and 7 and other reactor buildings, 

would encompass approximately 300 acres, most of which are mud flat wetlands that provide 

important bird habitat. As discussed, nitrogen and phosphorus organics from the muck could 

further degrade the IWF. To offset ecological impacts related to the construction on Nuclear 

Island, the NPS encourages USACE to consider the NPS's ongoing efforts to eradicate invasive 

plants and restore three spoil islands and adjacent peninsulas within the Biscayne NP. These 

restoration projects involve stabilizing eroding shorelines, removing exotic vegetation, and 

planting native species. The resulting sites benefit submerged vegetation such as seagrass, 

improve water quality of coastal waters, and provide high quality native habitat for coastal birds 

and wildlife. Further, spoil island restoration offers the community opportunities to learn about 

the benefits of environmental restoration, to "get dirty" in an actual restoration project, and to 

observe birds and wildlife in their native habitat. (0622-2-9 [Austin, Stan])

Response: The commenter presents specific recommended mitigation measures intended to 

offset the loss of wetlands and other natural habitats, especially those within Biscayne National 

Park and Everglades National Park. The applicant, FPL, has proposed a series of specific 

natural resource mitigation measures that are described in Section 4.3.1.6 of the EIS. The NRC 

staff does not impose natural resources mitigation requirements on the applicant, but in its 

assessment does account for the mitigation measures that the applicant develops in conjunction 

with other regulatory agencies. No change was made to the EIS as a result of this comment. 

Comment: DEIS Subsection 4.1.2.1, Page 4-21, Table 4-6: DEIS Table 4-6 contains the 

header "L-31 Canal (West Consensus)". DEIS reference, (FPL2013-TN2941), refers to this 

transmission line access corridor as "L-31N Canal and Levee". (emphasis added) (0619-4-1

[Maher, William])

Response: In response to this comment and to various other comments received from the 

applicant (FPL), the review team has provided more precise details regarding the anticipated 

extent of impacts on terrestrial and wetland habitats from each proposed offsite transmission 

line. Tables 4-5 and 4-6 have been updated accordingly. 

Comment: Miami-Dade County requests that the NRC undertake a thorough review of the 

proposed project, and especially the West transmission corridor alternatives, for consistency 

with local land use objectives and policies and local environmental regulations prior to issuing 

the FEIS, and update the document conclusions accordingly. For example, how did the NRC 

evaluate the transmission lines for the proposed project with regards to the provisions of Land 

Use Element Policy LU-3A and Section 24-48.4 of the Miami-Dade County Code? This section 

Appendix E October 2016 E-107 NUREG–2176
of the Code provides for mitigation for projects that are otherwise acceptable under the 

evaluation factors provided in Section 24-48.3 of the Code, but that nevertheless result in 

adverse environmental impacts. Miami-Dade County notes that the mitigation methods 

elaborated in Section 24-48.4(1)-(4) of the Code must be considered in the priority order listed, 

and avoiding the impact altogether as provided in Section 24-48.4(1) is the first (and highest) 

priority, followed by minimizing impacts by limiting the degree or magnitude of the action or its 

implementation (Section 24-48.4(2)). Please explain how the NRC justified consistency of the 

West Preferred corridor with the adopted local comprehensive plan and applicable 

environmental regulations, given the existence of a transmission line alternative (NPCA corridor) 

that has been accepted by both FPL and the State of Florida as certifiable (State of Florida, 

Division of Administrative Hearings, Application No. PA 03-45A3, Florida Power & Light 

Company Turkey Point Units 6 & 7 Power Plant Siting Case No. 09-3575EPP, Recommended 

Order, Section III.C.2.d., paragraph 511), does not have any fatal flaws, according to testimony 

presented by FPL's witness during the administrative hearings (Proposed Recommended Order 

filed by the National Parks Conservation Association and Miami-Dade County, State of Florida, 

Division of Administrative Hearings, Application No. PA 03-45A3, Florida Power & Light 

Company Turkey Point Units 6 & 7 Power Plant Siting Case No. 09-3575EPP, Section 11(a), 

Paragraph 165, attached), and which is fully consistent with Land Use Element Policy LU-3A 

because it meets the requirements of the Conservation, Aquifer Recharge and Drainage 

Element and other applicable CDMP policies, as well as Section 24-48.4(1) of the Miami-Dade 

County Code. The NPCA corridor avoids and minimizes adverse environmental impacts to the 

highest quality wetlands in the region because it: does not require that transmission lines or 

associated infrastructure be built within the current boundary of Everglades National Park; does 

not require a land swap that will reduce the overall size of Everglades National Park; avoids 

impacts to feeding and nesting habitat for the federally endangered snail kite by avoiding the 

high quality wetlands west of L-31N where feeding and nesting habitat for snail kites have been 

documented; and avoids impacts to the federally endangered wood stork by avoiding the 1-mile 

buffer zone between wood stork rookeries and high tension power lines that is recommended by 

the USFWS wood stork management plan. In addition, the NPCA corridor does not require the 

construction of transmission lines and associated road infrastructure in areas within the East 

Everglades Area of Critical Environmental Concern where roads are not allowed, and otherwise 

meets the environmental standards of Chapter 33B, Miami-Dade County Code. (0110-1-5 [Hefty, 

Lee N.])

Response: Section 4.1.1 describes how FPL has worked to minimize land-use impacts from 

the transmission lines as part of its corridor selection process using Florida State criteria. The 

siting criteria include potential disruption to such areas as national, state, and county parks; 

wildlife refuges; estuarine sanctuaries; landmarks; and historical sites. Section 4.1.1 also 

describes how FPL would implement other mitigation measures for the transmission lines such 

as installing erosion-control devices, using matting and wide-track vehicles when working in 

wetlands, and restoring wetlands following temporary disturbances. Additionally, Section 

4.3.1.6 of the EIS summarizes the review team’s independent analysis of FPL’s proposed 

mitigation for terrestrial ecology impacts, including installing avian protective measures on 

transmission lines and conducting wetland enhancement measures that would benefit the wood 

stork. Finally, the USACE, a cooperating agency on the EIS, will identify the LEDPA for the 

Units 6 and 7 project prior to issuing a Department of the Army permit under Section 404 of the 

Clean Water Act. The LEDPA determination will include a consideration of various project 

alternatives possible, including alternative transmission line routes such as those noted in the 

comment. Appendix K of the EIS includes the USACE analysis of alternative transmission lines. 

Appendix E NUREG–2176 E-108 October 2016
Comment: Miami-Dade County asserts that the DEIS is inadequate with respect to the West 

transmission line corridor. It is our understanding that as a cooperating agency, the Army Corps 

of Engineers will use the EIS in their review and processing of the requisite regulatory permits 

for this proposed activity. However, the DEIS does not provide the Army Corps of Engineers 

with the information needed to support a "decision to issue, deny, or issue with modifications a 

Department of the Army (DA) permit to perform certain dredge and fill activities in waters of the 

United States and to construct structures in navigable waters of the United States related to the 

project" (DEIS Abstract, Lines 7-10). Specifically, the DEIS does not include an adequate 

alternatives analysis for the West transmission corridor. (0110-1-1 [Hefty, Lee N.])

Response: The USACE review of the project will continue after the publication of the final 

EIS. If additional information is needed during that review, the applicant will be required to 

submit the necessary information. Please note that as a result of this comment regarding an 

alternatives analysis for the West Transmission Corridor, Appendix K was added to the final 

EIS. 

E.2.6 Comments Concerning Geology 

Comment: Well, not exactly, according to Dr. Donald McNeill, a University of Miami Geologist. 

The DEIS contends that the confining layer is over 1,000 feet thick and will not let the newlyintroduced water percolate upward into the upper Floridan aquifer from which Hialeah, coral 

reef, the Keys, and other draw their water. However, Dr. McNeill found that at the Southern 

Miami-Dade Water Treatment Plant, about nine miles from Turkey Point, the presumed very 

thick, low permeability confining layer was only about 14 feet thick, just above the Boulder Zone 

at a depth of 2,456 to 1,443 feet. Ten of the 17 deep injection wells for the effluent came out 

above the low permeability zone. And this area of low permeability rises from the area of Turkey 

Point and continues to the northwest, the location of the treatment plant relative to Turkey Point. 

So the Boulder Zone at Turkey Point is not like Las Vegas. What is injected at Turkey Point will 

not stay at Turkey Point. It will migrate to the northwest where the natural fissures in the thin, 

confining layer will allow it to percolate upward. Like the DEIS reports, the Boulder Zone 

confining layer has may fissures and the DEIS reports the general westward movement of water 

in the Boulder Zone from Turkey Point. (0721-12-7 [White, Barry J.])

Response: As described in Section 2.3.1.2 of the draft EIS, upward migration of injected 

effluent out of the Boulder Zone has been observed at a minority of injections sites in 

Florida. The extent, causes and impacts of upwelling at these sites has been widely studied 

and these studies were evaluated as part of the EIS development to understand potential 

impacts of proposed injection at the Turkey Point site. 

As part of development of the final EIS, the staff reviewed two studies from Dr. McNeill, who is 

cited in the comment above, which evaluated the upwelling that has occurred at the Miami-Dade 

SDWWTP north of the Turkey Point site (McNeill 2000-TN4572; McNeill 2002-

TN4571). Together these studies identified an “important low-permeability interval” dolomite 

layer which “appears to act as a competent confining unit” between the Boulder Zone and 

MCU. The two studies indicated that 10 of 17 injection wells were drilled through this unit but 

were completed above it, leaving an open hole and upward pathway for injected effluent. In the 

2002 study, McNeill concluded that the dolomite confining unit appeared continuous throughout 

southeast Florida and provided “additional effective confinement of upwardly buoyant injected 

fluids.” McNeill (2002-TN4571) indicated that while there is local variability in the bottom depth 

of the “dolomite confining unit” which may cause buoyant injectate to flow westward at the 

SDWWTP site, the overall dip of the structure to the southwest would cause any migration 

Appendix E October 2016 E-109 NUREG–2176
within the Boulder Zone beyond the site to move northeast, away from areas of use in the upper 

aquifers. The review team concluded that this could also apply to injectate at the Turkey Point 

site. 

Maliva et al. (2007-TN1483) coupled an analysis of core plug vertical hydraulic conductivity 

data from the MCU at 29 South Florida injection well systems (including the SDWWTP) with 

variable density solute-transport modeling. Based on this, they observed that “matrix hydraulic 

conductivies of the limestone and dolostones that constitute the confining strata between the 

injection zone and the base of the USDW in South Florida are sufficiently low to retard 

significant vertical fluid movement” and that vertical migration would be limited by thin sections 

where vertical hydraulic conductivity was low (10-6 cm/sec or less), as is seen at the Turkey 

Point site. 

Based on a review of well logs and water chemistry data at the SDWWTP, Walsh and Price 

(2010-TN3656) determined that enhanced vertical flow pathways that allowed upwelling likely 

resulted from well installation issues identified by Dr. McNeill, because “no fracturing of the 

confining strata had been reported” and effluent appeared to bypass deeper monitored intervals 

before being detected higher. Walsh and Price found that upwelling did not extend into the 

upper portion of the MCU and the Upper Floridan aquifer and concluded that this may be 

because “rapid vertical pathways did not appear to extend up to the Upper Floridan aquiferA” 

and because once upwelling reached the APPZ of the MCU, “the transport mechanism 

appeared to be a horizontal flow with mixing of ambient waters” (Walsh and Price 2010-

TN3656). 

Cunningham (2012-TN4576; Cunningham 2013-TN4573; Cunningham 2014-TN4051; 

Cunningham 2015-TN4574) evaluated injection sites for natural vertical high conductivity 

features (such as karst collapse structures) using seismic-reflection data. In the absence of 

seismic data, Cunningham (2015-TN4574) suggests that, “other evidence for karst collapse 

includes borehole log signatures that indicate highly fractured rock” and that fractures would be 

indicated by “high travel times measured on borehole sonic log data.” Using sonic logs from 

injection sites in South Florida, Maliva et al (2007-TN1483) depicted log signatures and travel 

times for both fractured and unfractured rock. The NRC staff evaluated return velocities in sonic 

logs obtained at well EW-1 at the Turkey Point site and found large sections of the MCU to have 

log signatures and transit times consistent with unfractured rock. 

One study evaluating the human and ecological impacts of various methods of wastewater 

disposal in South Florida, concluded that the overall health risk for deep well injection was “low 

where there have been impacts to USDWs” and that “the risk would be further reduced when 

the injected wastewater is treated to reclaimed water standards” (EPA 2003-TN4759). The 

water proposed for injection at the Turkey Point site would be treated beyond the secondary 

treatment referred to here before it is sent to the Turkey Point site, where it would be further 

treated and diluted before injection. 

As a result of this information, staff determined it was reasonable to conclude that properly 

installed injection wells that are cased and cemented through the confining zone will provide 

adequate confinement of the injected wastewater. If upward leakage of wastewater through the 

confining layers did occur, it is not likely it would impact the Upper Floridan aquifer and could be 

detected onsite in the overlying monitoring wells and mitigated as required by the FDEP UIC 

program. Additional information has been added to Sections 2.3 and 5.2 of the EIS to reflect 

the discussion above. 

Appendix E NUREG–2176 E-110 October 2016
Comment: A petition was submitted to EPA on April 28, 2015, to designate the entire Floridan 

aquifer system as a Sole Source Aquifer (SSA) under 40 CFR Part 149. The area in the petition 

includes the Lower Floridan, which contains the Boulder Zone. Although the Boulder Zone is 

saline, it is hydraulically connected to fresh water zones lying above. If confinement of the 

overlying layer is not sufficient, the injection of effluent into the Boulder Zone could result in 

waste, including radionuclides, being emplaced into the lowermost USDW. EPA's review of the 

petition is in progress. The MDWSD installed Class I injection wells for discharging effluent from 

the South District wastewater treatment plant (WWTP) into the Boulder Zone; injection began in 

1983. This facility is located approximately 8 miles north of the Turkey Point facility. In 1994, 

MDWSD notified the Florida Department of Environmental Protection (FDEP) that ammonia and 

total kjeldahl nitrogen (TKN) had been found outside the injection zone in the freshwater aquifer 

protected by the Safe Drinking Water Act (SDWA) as a USDW. (EPA's well classification 

information: http://water.epa.gov/type/groundwater/uidwells.cfm) EPA issued consent order 4-

UICC-006-95 in 1995, which became effective in 1997. This order included testing to determine 

whether confinement existed, as required by federal and state regulations, for Class I wells. In 

February 2001, the report "Evaluation of Confining Layer Integrity Beneath the South District 

Wastewater Treatment Plant, Miami-Dade Water and Sewer Department, Dade County, 

Florida," by R.C. Starr, T.S. Green, and L.C. Hull was completed. The conclusions included the 

finding that the geologic data provided for review were not sufficient to demonstrate that the 

Middle Confining Unit is a competent, low hydraulic conductivity layer capable of preventing 

upward migrations of fluids from the Boulder Zone into the overlying underground source of 

drinking water. Also, the geochemical data showed that groundwater in the Upper Floridan 

aquifer is contaminated with treated wastewater. Based upon EPA's review of the available 

scientific information and data, there is no information to show that sufficient confinement exists 

to meet the Underground Injection Control (UIC) regulatory requirements for Class I wells. Class 

I wells must meet the "No-Migration Clause" of the UIC regulations at 40 CFR § 144.12(b). 

Recent USGS studies indicate that karst collapse features and possibly transmissive faults exist 

in the subsurface in the south Florida area, and modeling for the proposed Class I wells should 

determine whether the proposed wells would meet the criteria in order to comply with UIC Class 

I permit requirements. It is not clear whether the installation of a desalinization unit has been 

considered, in order to reduce or control the salinity of the water in the cooling canal system, 

and decrease the rate of migration of the hypersaline plume towards the water supply wells 

completed in the Biscayne sole source aquifer. Recommendations: The FEIS should include 

more information regarding the proposed deep injection wells to be used for wastewater 

disposal, including the status of the permitting process of the 12 deep injection wells that are 

proposed, the planned timeline for permitting of these wells, and planning for surface discharge 

of effluents in the event that delays occur in the permitting process. In addition, the FEIS should 

include information regarding subsurface karst delineation, aquifer testing and modeling that will 

be required to demonstrate that this project will be protective of the USDWs in the Upper 

Floridan. Also, the FEIS should evaluate the other alternatives that are being considered for 

effluent discharge. In addition, the FEIS should include details of a robust monitoring plan to 

ensure the protection of the Biscayne aquifer, the public drinking water supply, and prevention 

of migration of injectate into freshwater. The proposed injection wells are contingent upon future 

issuance of applicable UIC permits, for which substantial issues will need to be addressed. 

More data and modeling is needed to determine whether all requirements will be met in order to 

issue the required permits. Since the proposed planning for disposition of blowdown/effluent is 

contingent upon issuance of the required permits by FDEP, alternatives will need to be 

developed. (0617-1-23 [Mueller, Heinz J.])

Response: In keeping with its responsibility under NEPA, the NRC has developed the EIS to 

inform the decision of whether or not to grant FPL’s application for combined licenses for 

Appendix E October 2016 E-111 NUREG–2176
proposed Turkey Point Units 6 and 7. Information requested in the comment demonstrating 

protection of the underground sources of drinking water (USDWs) through monitoring and 

confinement by the Middle Confining Unit (MCU) is required by and would be described in the 

underground injection control (UIC) permit for the proposed injection wells, which is granted by 

the Florida Department of Environmental Protection (FDEP). The NRC regulates the release of 

radiological constituents and a conservative evaluation of the expected impacts of the 

radiological component of the injected effluent at Turkey Point is documented in Final Safety 

Evaluation Report (FSER) Section 11.2 and EIS Section 5.9. The NRC recognizes that 

responsibility for regulation of non-radiological pollutant discharges “rests by statute with the 

Environmental Protection Agency” (10 CFR 51.10(c)). 

NRC staff evaluated the expected impacts of deep well injection and documented this 

evaluation in updated Sections 2.3, 5.2, 7.2, and Appendix G of the final EIS. This evaluation 

includes an extensive literature review of many studies concerning the adequacy of the Boulder 

Zone to receive and the MCU to confine injected effluent. Specifically, the staff reviewed 

studies of; the local and regional hydrogeology of the Floridan aquifer system, the nature and 

competency of the MCU using geologic and geophysical investigation techniques, behavior of 

injected wastewater at current injection facilities and causes of documented upwelling, relative 

risk assessments of wastewater disposal methods including deep well injection, and ranges of 

hydrogeological parameters that inhibit upwelling. NRC staff also performed an independent 

conservative evaluation of injected effluent migration assuming a non-fractured MCU matrix as 

well as an evaluation of instantaneous migration to a hypothetical drinking water well at the site 

boundary, which assumes total, instantaneous failure of the MCU. Based on this evaluation the 

impacts were determined to be SMALL. 

The NRC would like to clarify several issues raised in the comment. The comment states that 

the Boulder Zone is “hydraulically connected to fresh water zones lying above.” The staff notes 

that the Upper Floridan aquifer is brackish in southeast Florida. Despite this, the Upper Floridan 

aquifer is mixed with fresher water and used municipally in the vicinity of the site (draft EIS 

Section 2.3.2.2). The overlying Biscayne Aquifer, which is a Sole Source Aquifer, has been 

impacted by saltwater intrusion up to 4 mi inland along the coast and also by infiltration of 

hypersaline waters from the cooling-canal system (CCS) in the vicinity of the Turkey Point 

site. However, the NRC staff understands that the UIC program requires protection of these 

resources from upward migration of effluent. 

The degree of hydraulic connection between the Upper Floridan aquifer and the Boulder Zone 

has been the subject of many studies. These studies have determined that, in general, the 

MCU provides confinement and that incidences of upwelling have been coincident with features 

that provide vertical pathways for upward migration. As for potential contamination of the 

Biscayne aquifer, the Biscayne aquifer is a near-surface aquifer that is separated from the 

Boulder Zone at the Turkey Point site by about 2,800 ft, a large portion of which is confining 

strata. As mentioned earlier, recent studies of the impacts of deep well injection in South 

Florida indicate that the Upper Floridan aquifer (UFA) has not been impacted by deep well 

injection. Therefore, impact to the Biscayne Aquifer is very unlikely. 

The comment also states that the Upper Floridan aquifer has been “contaminated with treated 

wastewater”, repeating a conclusion made by Starr et al. (2001-TN1251) and other reports 

published around the same time. More recent studies, such as those by Maliva et al. (2007-

TN1483) and Walsh and Price (2010-TN3656), have clarified that while migration has reached 

the USDW at some Class I injection facilities, no impact has been reported for the Upper 

Floridan aquifer in southeast Florida. This may be explained as follows: in some places, the 

Appendix E NUREG–2176 E-112 October 2016
USDW (total dissolved solids (TDS) concentrations exceed 10,000 mg/L) is below the Upper 

Floridan aquifer within the MCU. In this regard, more recent reviews of hydrostratigraphy, such 

as Reese and Richardson (2008-TN3436) have recognized that a permeable unit known as the 

Avon Park Permeable Zone (APPZ) occurs within the MCU and “...has been identified in 

previous studies as the...lower part of the Upper Floridan aquifer in...the southern part of 

southeastern Florida.” A comparison of the depth where impact has been detected relative to 

the revised stratigraphy indicates that upwelling has only impacted the APPZ and not the Upper 

Floridan aquifer. These clarifications are discussed in greater detail in the EIS and below. 

NRC staff previously reviewed the study identified in the comment, which the draft EIS refers to 

as Starr et al. (2001-TN1251). This study was an independent review of “existing information 

that describes geology, hydrogeology, and geochemistry at the SDWWTP [South District 

Wastewater Treatment Plant]...” which was conducted by the Idaho National Engineering 

Laboratory at the request of the EPA Region 4 to determine the ability of the MCU to prevent 

fluid upward migration. The NRC staff disagrees that this and other available studies should be 

interpreted to indicate that there is “no information to show that sufficient confinement exists” as 

stated in the comment above. Rather, the study expressed concern about the amount and type 

of data then available for evaluation. According to the Starr et al. (2001-TN1251) report, a few 

of the shortcomings of the data set include; “The review of the available geologic data set 

resulted in the conclusion that it is insufficient for performing this analysis..”, “it is not possible to 

perform an evaluation of the stratigraphy or physical attributes of the confining units without 

sonic and density logs”, “...the validity of the hydrographs is suspect...”, “the hydraulic head 

data available for review are inadequate to provide a useful understanding of head 

relationships...”, and “the hydraulic conductivity values reviewed may not reflect the effective 

vertical hydraulic conductivity of the confining units above the Boulder Zone.” Rather than 

indicating a lack of confinement by the MCU, the study concludes that “the MCU and/or upper 

portion of the Lower Floridan Aquifer is a better confining unit than indicated” by the data set 

that was reviewed. The study concluded that overall, the spatial distribution of contaminants 

“suggests that isolated conduits, such as inadequately sealed wells or natural features, provide 

pathways for contaminated water to migrate upward from the Boulder Zone, but contaminants 

are not migrating upward through the MCU across a broad area.” The study also recommended 

additional collection of specific types of data. This additional data collection as well as 

modeling, which has also been requested in this comment, has been performed in subsequent 

studies and further data are required and will be collected as part of the UIC permitting 

process. 

The conclusion reached by the Starr et al. study that upward migration at the SDWWTP 

resulted from flow along enhanced vertical flow pathways has been strengthened by findings 

from later studies, including those by McNeill (2002-TN4571), Maliva et al. (2007-TN1483), and 

Walsh and Price (2010-TN3656). 

In a 2002 study of upwelling at the SDWWTP (2002-TN4571), Dr. McNeill indicated that 10 of 

17 injection wells were drilled through an “important low-permeability interval” that “appears to 

act as a competent confining unit” between the Boulder Zone and MCU, but completed above it, 

leaving an open hole and upward pathway for injected effluent. 

Maliva et al. explored this subject by studying core plug vertical hydraulic conductivity data from 

the MCU at 29 South Florida injection well systems (including the SDWWTP) and variable 

density solute-transport modeling Maliva et al. (2007-TN1483). Maliva et al. observed that 

“matrix hydraulic conductivies of the limestone and dolostones that constitute the confining 

strata between the injection zone and the base of the USDW in South Florida are sufficiently low 

Appendix E October 2016 E-113 NUREG–2176
to retard significant vertical fluid movement.” Accordingly, the Maliva et al. study concluded that 

observed vertical fluid migration from injection zones likely occurred due to enhanced vertical 

flow pathways created by natural features (such as fractures) or improper well installation. 

Walsh and Price (2010-TN3656) evaluated well logs and water chemistry data at the SDWWTP 

and determined that enhanced vertical flow pathways that allowed upwelling likely resulted from 

well installation issues identified by Dr. McNeill, because “no fracturing of the confining strata 

had been reported”. Walsh and Price found that upwelling did not extend into the upper portion 

of the MCU and the Upper Floridan aquifer and concluded that this may be because “rapid 

vertical pathways did not appear to extend up to the upper Floridan aquifer” and because once 

upwelling reached the APPZ of the MCU, “the transport mechanism appeared to be a horizontal 

flow with mixing of ambient waters” (Walsh and Price 2010-TN3656). This conceptual model 

was also illustrated in a numerical modeling scenario by Maliva et al. (2007-TN1483). This 

indicates that, even where migration through the bottom portion of the MCU has occurred, 

impact to the upper MCU and the overlying Upper Floridan aquifer may not be possible. This 

could partially explain why recent studies have indicated that impact to the Upper Floridan 

aquifer has not occurred at injection sites. 

Cunningham ( 2012-TN4576; Cunningham 2013-TN4573; Cunningham 2014-TN4051; 

Cunningham 2015-TN4574) evaluated injection sites for natural vertical high conductivity 

features (such as karst collapse structures) using seismic-reflection data. Cunningham stated 

that “if present at or near wastewater injection utilities, these features represent a plausible 

physical system for the upward migration of effluent injected into the Boulder Zone to overlying 

EPA-designated USDW in the upper part of the Floridan aquifer system.” At a municipal 

wellfield for the City of Sunrise, where upwelling was coincident with a karst collapse feature, 

migration had not occurred above the Lower Floridan aquifer. 

While seismic data has been collected near the Turkey Point site, there is no deep seismic data 

at the site. In the absence of seismic data Cunningham (2015-TN4574) suggests that “other 

evidence for karst collapse includes borehole log signatures that indicate highly fractured rock” 

and that fractures would be indicated by “high travel times measured on borehole sonic log 

data.” Using sonic logs from injection sites in south Florida, Maliva et al. (2007-TN1483) 

depicted log signatures and travel times for both fractured and unfractured rock. The NRC staff 

evaluated return velocities in sonic logs obtained at well EW-1 at the Turkey Point site and 

found sections of the MCU to have log signatures and transit times consistent with unfractured 

rock. 

The draft EIS states that at the Turkey Point site "The bottom of the deepest underground 

source of drinking water (USDW) was determined to be between 1,430 and 1,505 ft below 

ground surface based on water samples collected during packer testing, and was estimated at 

1,450 ft based on specific conductance logging (FPL 2012-TN1577). The deepest USDW is 

within the Avon Park Formation, and is considered part of the Upper Floridan aquifer because of 

its relatively low salinity." The NRC staff revised the EIS to more clearly describe the status of 

the Avon Park Formation in general, and the APPZ in particular. The State of Florida granted a 

permit for FPL to use the exploratory well drilled at the Turkey Point site (EW-1) as an injection 

well under the Florida State UIC program. The permit rests, in part, on the status of the Upper 

Floridan aquifer, which is designated as a USDW. 

Based on the information presented above and discussed in updated text within the final EIS, 

the staff finds it reasonable to conclude that adequate confinement of injected wastewater would 

occur if injection wells are properly installed through the MCU. If upward leakage of wastewater 

Appendix E NUREG–2176 E-114 October 2016
through the confining layers did occur at the site, it would likely be detected in the overlying 

monitoring wells and mitigated as required by the FDEP UIC program. Modeling performed as 

part of the EIS analysis also indicates that the extent of migration of the injected effluent within 

the Boulder Zone would be limited over the life of the proposed plant. 

Even in the event that upward migration occurs, studies evaluating the human and ecological 

impacts of various methods of wastewater disposal in South Florida have concluded that the 

overall health risk for deep well injection was “low where there have been impacts to USDWs” 

and that “the risk would be further reduced when the injected wastewater is treated to reclaimed 

water standards” (EPA 2003-TN4759). The reclaimed wastewater would be treated beyond the 

secondary treatment referred to here before it is sent to the Turkey Point site. At the Turkey 

Point site, it would be further treated and diluted before injection at rates lower than those 

currently used at the SDWWTP. This study also reinforces the staff conclusion regarding the 

requirements of the UIC permit by stating that “the [FDEP UIC] permit process offers better 

opportunities to evaluate the suitability of specific well sites and injection zones. The permit 

process is also designed to anticipate and prevent potential problems related to well operation 

(and adverse impacts resulting from injection).” The construction and operation of proposed 

Turkey Points Units 6 and 7 would have only a negligible effect (through salt drift) on the salinity 

of the existing cooling canals associated with the operation of Turkey Point Units 3 and 4, and 

need not be discussed further in the EIS. Possible measures to address the salinity of the 

existing cooling canals are outside the scope of this EIS. The potential impact of upward 

leakage of wastewater injected in the Boulder Zone is assessed in Appendix G of the EIS and 

discussed in EIS Section 5.2.1.3. 

E.2.7 Comments Concerning Hydrology - Surface Water 

Comment: The concern related to expected sea level rise throughout the world which is 

anticipated to occur over the coming decades and measured in feet and it's possible impacts on 

any coastal development activity needs to be fully addressed. (0005-1 [Larsen, Paul])

Comment: I certainly don't want two reactors being built using outdated scientific sea rise 

models. (0008-14 [Finver, Jody])

Comment: The facts speak for themselves: the cooling ponds at Turkey Point were at 

dangerously high temperatures late last summer with no end in sight for increasing water 

temperatures in Biscayne Bay; even the more conservative estimates of sea level rise would 

cause cascading and catastrophic results to a nuclear reactor in the event of major storm 

coupled with storm surge at the plant site. (0009-3 [Rose, Simon])

Comment: FPL should be denied a license for Turkey Point expansion for many reasons:...4. 

Sea level rise will make Turkey Point an island (0022-4 [Read, Alice Gray])

Comment: Has anyone considered the raising of the ocean waters? How will that affect the 

nuclear reactors? This should be another concern. (0040-4 [Pareto, Rolando and Marlene])

Comment: Sea level rise makes Turkey Point a bad place for nuclear plants. The new 

transmission lines are tied to development of two new nuclear reactors at Turkey Point, situated 

between two national parks on a hurricane-swept coastline subject to storm surge and 

inundation from sea level rise. Just this past week reports came out naming our area as one of 

the worst regarding rising sea levels. (0049-2 [Kowalski, Kathleen S.])

Appendix E October 2016 E-115 NUREG–2176
Comment: Building any such plants on the shores of Florida, which will see the sea rise up to 

10 feet in 50 years, is lunacy. (0053-4 [Sasiadek, Alfred])

Comment: with global warming, Miami and Florida will be the first affected areas in the nation 

with sea level rise. so how can anyone, NRC, fp&l, propose adding two more nuclear reactors at 

turkey point in that scenario. (0055-3 [Roedel, Kitty])

Comment: As a related matter, we also do NOT need any more irresponsible, out of control, 

development in our tenuous environmental situation with the global warming and sea level 

rising. The latter is especially dire in our peninsula because we have water on three sides and, 

to date no ways the ameliorate the rapid continuation of this pending threat. (0060-4 [Beckman, 

Yvonne and Douglas])

Comment: These reactors would pose a danger not only in a hurricane, but the location 

doesn't take into account the reality of rising seas caused by climate change. (0086-2 [Lawrence, 

Diane])

Comment: I recommend that you disapprove any further processing of their Turkey Point 

Nuclear Power plant expansion proposal for the reasons summarized below. 1) The National 

Oceanic and Atmospheric Administration (NOAA) recommends that new power plants account 

for three feet to 6.6 feet of sea-level rise. FPL's application proposes to accommodate only one 

foot of sea-level rise over the proposed 60-year project life. (0094-1 [Fairchild, David])

Comment: I recommend that you disapprove any further processing of their Turkey Point 

Nuclear Power plant expansion proposal for the reasons summarized below 5)FPL's proposes 

operating the new reactors for 60 years, or at least until 2080. One foot of sea-level rise will 

certainly occur during that time frame, inundating the area surrounding Turkey Point and turning 

the power plant into an island, possibly flooding radioactive waste storage facilities and 

releasing radioactivity into the surrounding water during storm surges. The proposal fails to 

adequately assess that risk. The proposal fails to use the latest and most authoritative forecasts 

of sea-level rise at the site, nor the probability of storm surges releasing radioactive waste 

storage there. FPL's assertion that the new reactors will be safe from storm surges does not 

properly account for these and other impacts to the plant from expected sea level rise plus 

storm surges heights at the site. (0094-5 [Fairchild, David])

Comment: The site proposed for expansion is located directly on the shores of Biscayne 

National Park in an area that is extremely susceptible to sea level rise and the impacts of 

climate change. (0102-2 [Commenters, Multiple])

Comment: The proposed construction site is located directly on the shores of Biscayne 

National Park in an area that's extremely susceptible to sea-level rise and the storm surges that 

will come with climate change. (0103-2 [Commenters, Multiple])

Comment: [E]xpanding a nuclear power plant in an area that's ground zero for sea level rise 

puts South Florida at unacceptable risk. (0103-7 [Commenters, Multiple])

Comment: Clearly, South Florida is highly vulnerable to sea level rise and the impacts of 

climate change. This site was never an acceptable location for the Turkey Point facility there 

today and many decades later it has only become an even more unacceptable location. (0104-4

[Commenters, Multiple])

Appendix E NUREG–2176 E-116 October 2016
Comment: Comment 3. The DEIS fails to take NOAA's guidance of planning for the 

highest estimates of SLR, and likely underestimates SLR by using consensus global 

projections for future SLR that are below the ongoing local rates of SLR measured by 

regional experts at the University of Miami's Rosenstiel School of Marine and 

Atmospheric Science - Appendix I of the DEIS addresses climate change and sea level rise: 

"Sea level is projected to rise 1 to 4 ft globally by 2100." [DEIS, p. I-3] While several reports list 

project such global figures, scientists at the University of Miami's Rosenstiel School of Marine 

and Atmospheric Science (RSMAS) have actually measured SLR in the Miami region that 

indicates higher SLR rates are already happening locally: "...over the past 15 years, the average 

annual increase [in sea level] is roughly 0.27./year, but over just the past 5 years, it's about 

0.97./year." [McNoldy 2014] Existing SLR rates measured locally yield a range of 2 to 6.5 feet 

of rise over the life of the plant stated in DEIS Appendix I, but scientists agree the rate of rise is 

going to accelerate exponentially. The NOAA states: "The Highest Scenario [for SLR] should be 

considered in situations where there is little tolerance for risk (e.g. new infrastructure with a long 

anticipated life cycle such as a power plant)." [NOAA 2012] The final EIS must better estimate 

effects of sea level rise (SLR) by considering how measured local rates of SLR differ 

from projected global rates, and the effect of uncertainty in SLR on viability of the 

project. (0106-6 [Stoddard, Philip K.])

Comment: Comment 4. The DEIS is incomplete in failing to consider loss of the main 

cooling water supply through reduction of the wastewater stream resulting from reduced 

residential demand caused by forced water conservation - Sea level rise (SLR) will limit 

cooling water availability in ways that were not considered in the DEIS. One foot of sea level 

rise will overwhelm the saltwater exclusion dams in Miami-Dade County, and produce significant 

saltwater intrusion upon the wellfields. The freshwater supply will be supplemented, at 

considerable expense, with desalinated water from the Upper Floridan Aquifer, a process that 

has already begun in parts of Miami-Dade County. Since saltwater intrusion from SLR will 

impose staunch water conservation measures, either by regulation or by economics, the amount 

of water available from the Southern Waste Water Treatment Facility will undoubtedly decline 

over time. Thus the amount of water available today from the Southern Waste Water Treatment 

Facility will not be available for use as cooling water over the projected operational life of TPN 

6&7. The final EIS must consider loss of wastewater as cooling water source because of 

reduced residential demand from water conservation measures addressing SLR induced 

saltwater intrusion on freshwater supply. (0106-7 [Stoddard, Philip K.])

Comment: Comment 6. The DEIS is incomplete in failing to consider access restriction 

and ocean vulnerability caused by SLR that could eliminate treated wastewater as a 

source of cooling water for TPN 6&7 - SLR will complicate road access to the Southern 

Waste Water Treatment Facility, making plant operation difficult. Although a causeway could be 

built to keep the plant operational, the price could make operation uneconomical. Further, Elliot 

Key, which currently shields the region from open ocean effects, will be underwater. Ocean 

swell, east winds, storms, and tides will have greater effects on plant accessibility and 

operations. If Miami-Dade County finds operation of the plant has become uneconomical 

because of SRL, then TPN 6&7 could lose its primary source of cooling water. The final EIS 

must consider possible loss of treated wastewater as a cooling water source because 

SLR will impair site access and operability of the Southern Waste Water Treatment 

Facility. (0106-9 [Stoddard, Philip K.])

Comment: The direct, indirect, and cumulative impacts of sea level rise on the construction 

and operation of Units 6 & 7 and ancillary facilities are not adequately analyzed. (0113-1-8

[Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Appendix E October 2016 E-117 NUREG–2176
Comment: Failure to Adequately Analyze the Direct, Indirect, and Cumulative Impacts of 

Sea Level Rise on the Construction and Operation of Units 6 & 7 and Ancillary Facilities. 

Preparing for the impacts of impending sea level rise and ensuring that development, both 

existing and planned, takes into account these potential impacts is one of the most critical 

challenges facing South Florida. In considering such impacts, the DEIS fails to adequately 

address the direct, indirect, and cumulative impacts of sea level rise on the construction and 

operation of Units 6 & 7 and ancillary facilities. Turkey Point is located close to sea level, with an 

elevation of -2.4 feet to 0.8 feet. Over the last 100 years, sea level in the area of Turkey Point 

has risen approximately 9-12 inches. [Footnote 40: South Florida Water Management District, 

FPL Turkey Point Units 6 & 7, Site Certification Application, First Completeness Review, July 

30, 2009, 34-35.] According to the Miami-Dade Climate Change Task Force, by 2050, sea level 

rise could be between 1.5 and 5 feet. [Footnote 41: Ibid., 34-35.] With FPL seeking a COL valid 

for 40 years, Units 6 & 7 could still be operating when these predictions come to fruition. 

However, the DEIS fails to adequately analyze the potential impacts associated with this level of 

sea level rise. The DEIS acknowledges that global sea level is projected to rise by 1 to 4 feet by 

2100 and that the vulnerability of Turkey Point to sea level rise is "high" to "very high." [Footnote 

42: NRC, DEIS, I-3.] According to the U.S. Global Change Research Program, as cited in the 

DEIS, there is "an imminent threat of increased inland flooding during heavy rain events in lowlying coastal areas such as southeastern Florida" and sea level rise will "accelerate saltwater 

intrusion into freshwater supplies" [Footnote 43: Ibid. I-3.] Predictions for sea level rise globally 

and in specific regions can vary widely and the DEIS accounts for a very conservative estimate 

of sea level rise in its analysis. NOAA discourages decision makers from using only the most 

likely sea level rise scenarios when considering future impacts of sea level rise on development. 

Rather, in terms of the construction of power plants, NOAA recommends that a projection of 

over six feet of sea level rise by 2100 be used for planning purposes. [Footnote 44: Parris, A., P. 

Bromirski, V. Burkett, D. Cayan, M. Culver, J. Hall, R., Horton, K. Knuuti, R. Moss, J. 

Obejsekera, A. Sallenger, and J. Weiss. Global Sea Level Rise Scenarios for the US National 

Climate Assessment, NOAA Tech Memo OAR CPO-1, 2012, 2.] Under such recommendations, 

three feet of sea level rise by 2060 should be accounted for, which is within the lifetime of Units 

6 & 7. Despite the fact that new units would be constructed on elevated pads, transmission line 

facilities, reclaimed water pipelines, industrial wastewater facilities, access roads, and other 

facilities would be located at the current elevation of the plant. The DEIS omits an adequate 

discussion on how sea level rise could potentially impact these facilities and the operations of 

Units 6 & 7. Sea level rise could cut off road access to the Southern Waste Water Treatment 

Facility, impacting the plant's operations. Moreover, considering the porosity of the Biscayne 

Aquifer, increasing sea level rise could also increase groundwater levels in the region. [Footnote 

45: South Florida Water Management District, FPL Turkey Point Units 6 & 7, Site Certification 

Application, First Completeness Review, July 30, 2009, 34-35.] Impacts of sea level rise could 

affect the operations of the radial collector wells, particularly in regards to the percentage of 

water drawn from Biscayne Bay versus freshwater from the Biscayne Aquifer. The NRC should 

also look at the impacts of sea level rise beyond the 40 year lifetime of the plant, especially as 

nuclear waste will be stored onsite. In addition, the DEIS does not adequately discuss the 

increased vulnerability of Units 6 & 7 to storm surge as a result of sea level rise. While sea level 

rise occurs slowly, impacts from storm surge can be sudden and immediate. Turkey Point is 

located between Biscayne Bay to the east and low-lying wetlands to the west. As sea level 

rises, Florida Bay could also border the Turkey Point site. Therefore, when anticipating future 

scenarios, storm surge could potentially come at the plant from three directions. Elliott Key, 

which currently acts as a barrier to the impacts of storms, may be underwater, leaving the 

facility more vulnerable to storm surge, high tides, winds, and ocean swell. Given projections, it 

is extremely likely that water from Biscayne Bay will rise to or above levels of water within the 

cooling canal system at some point in the project's lifetime. During storm events, it is possible 

Appendix E NUREG–2176 E-118 October 2016
that water levels may breach the height of the berms surrounding the CCS, causing Bay water 

to mix with CCS water before the water returns to Biscayne Bay. [Footnote 46: West, B. United 

States Department of the Interior, National Park Service Letter to A. Williamson, U.S. Nuclear 

Regulatory Commission, November 25, 2014, SER PC, 9.] The end result would be the 

increased presence of cooling canal system water in the bay, which could lead to nutrient 

loading and potentially devastating algal blooms within the bay. [Footnote 47: Ibid., 9.] The DEIS 

must account for such future scenarios and direct, indirect, and cumulative impacts of sea level 

rise and storm surge in its analysis of project impacts. (0113-2-12 [Lopez, Jaclyn] [McLaughlin, 

Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: The current reactors and the proposed two new reactors are located along the 

south east Florida coast on low lying land. We are already actively seeing the effects of sea rise; 

the city of Miami Beach, some 10-15 miles from the plant, has been suffering from flooding 

during high tides, and is spending millions of dollars installing huge pumps to move the water 

back into the sea. Nuclear reactors should not be built on the coast, an location threatened by 

sea rise, an area mere feet above current sea level (Miami Dade County has a maximum height 

of 13.5 feet above sea level). (0115-6 [Trencher, Ruth])

Comment: Even one foot of sea-level rise will inundate the area surrounding Turkey Point and 

turn the power plant into a remote island. A difference of two feet of sea-level rise will 

dramatically affect the height of future storm surges. (0122-2 [Meyer, Paul])

Comment: I herewith want you to note my objection to FPL's planned new nuclear power 

plans - a dangerous and superfluous proposition, given our climate change[.] (0135-1 [Thiel, 

Markus])

Comment: I am writing today from my home to oppose the approval of FPL's two new nuclear 

power plant at Turkey Point for the following reasons: 1. This location is too vulnerable to storm 

surges in a hurricane prone location. Sea level rise is not a fantasy and will subject Turkey Point 

to serious damage as well as costly preventative measures. (0136-1 [Levy, Morgan I.])

Comment: The biggest risk in Florida would be from flooding, and that risk increases every 

year because of people like our idiot governor who deny climate change. (0140-3 [Rhodes, 

Karen])

Comment: Secondly, the draft Environmental Impact statement fails to thoroughly review and 

address the fact that the FPL proposed plan does not adequately take into account the plan for 

the sea level rise that is certain to come over the next 40 - 60 years, the lifespan of the two new 

reactors. The plan must be compliant with the NOAA Dec 6 2012 report, Global Sea Level Rise 

Scenarios for the United States National Climate Assessment. In that review, the report 

indicates that over Eight million people live in areas at risk of coastal flooding, and many of the 

nation's assets related to military readiness, energy, commerce and ecosystems are already 

located at or near the ocean. The report establishes a high confidence (greater than 9 in 10 

chances that global mean sea level will rise at least 8 inches, and no more than 6.6 feet by 

2100. The report indicates that the highest scenario should be considered in situations where 

there is little tolerance for risk, eg new infrastructure with a long anticipated life cycle, such as a 

power plant. The FPL plan only accounts for one foot of rise. The draft EIS utterly fails to 

address the commonly accepted levels of impact of projected sea level rise on the site, as well 

as the surrounding land, according to the US Global Change Research, which will all be several 

feet under water within the lifetime of the nuclear plants over 50 years. The NRC review study 

failed to rely on the US Global Change Research, which rates the Vulnerability of the Turkey 

Appendix E October 2016 E-119 NUREG–2176
point area to sea level rise as "high" to "very high" and notes an "imminent threat of increased 

inland flooding during heavy rain events in low lying coastal areas such as Southeastern 

Florida, where just inches of sea level rise will impair the capacity of Stormwater drainage 

systems to empty into the ocean." (0145-11 [Lerner, Cindy])

Comment: The access roads, and all accompanying infrastructure would make the Plant site 

eventually, during the projected life and operation of the plant inaccessible to maintain 

operation, and most importantly, crisis management would not be feasible. For example, the 

planned Miami Dade County reclaimed water pipeline will run 9 miles to the plant site, 

approximately 4-5 feet underground. By not accounting adequately for sea level rise, there 

would not be access to the pipeline along the 9 mile track, which would then be several feet 

underwater and therefore inaccessible to necessary repair. The Draft EIS fails to consider the 

impact of different weather events combined with scenarios of Sea Level Rise, which according 

to the NOAA report is crucial to developing hazard profiles for emergency planning and 

vulnerability impact and adaptation assessment, all of which are required to be done by the 

Global Change Research Act and in addition, the US Army Corp of Engineers Guidance for 

Coastal Decision Makers. (0145-12 [Lerner, Cindy])

Comment: The Florida climate is not safe for this reactor. Hurricane's, tropical storms, sea 

level changes, etc. According to scientific research, the area could be below sea level in less 

than 30 years. (0146-4 [Grant, Randy])

Comment: Sea rise is a major threat in and of itself; what it Will do to the present facility is 

deeply concerning.... But to a hugely expanded plant? Terrifying. (0163-2 [Cook, Cherie])

Comment: This location is exceedingly vulnerable to sea level rise from climate change.

(0172-2 [Cava, Daniella Levine])

Comment: And finally, expanding a nuclear power plant in an area that's ground zero for sea 

level rise, as well as hurricane threats, puts South Florida at unacceptable risk. (0180-1 [Demello, 

Christine])

Comment: Expanding Turkey Point power plant is a fool's errand in light of undeniable sea 

level rise. (0181-1 [Bremen, Gary])

Comment: South Florida has already experienced a sea level rise of almost 5" over the last 10 

years. Increasing the size and scope of a plant that will be susceptible to yearly hurricane 

events, ever powerful storm surge and rising sea levels is irresponsible and I am sure one day 

will be recognized as criminal. (0187-4 [Meyer-Steele, Shawn])

Comment: Clearly, South Florida is highly vulnerable to sea level rise and the impacts of 

climate change. (0192-4 [Lebatard, David])

Comment: Florida is subject to some rather alarming affects of global warming, including the 

influx of salt water due to the rising seas. Florida has beautiful natural resources that deserve 

protection. (0193-1 [Shipe, Kathleen])

Comment: The location of the Turkey Point power plant will begin (if it hasn't already) to feel 

the affects of climate change very soon. It will exponentially get worse as time passes. This is 

not the right location or timeframe to be adding new reactors to Turkey Point. (0194-1 [Mayotte, 

Monica])

Appendix E NUREG–2176 E-120 October 2016
Comment: The site proposed for expansion is located directly on the shores of Biscayne 

National Park in an area that is extremely susceptible to sea level rise and the impacts of 

environmental degradation. (0197-1 [Wicht, Dan])

Comment: The direct, indirect, and cumulative impacts of sea level rise on the construction 

and operation of Units 6 & 7 and ancillary facilities are not adequately analyzed. (0208-9 [Ritz, 

David])

Comment: Furthermore, South Florida is vulnerable to the impacts of climate change, including 

storm surge, sea level rise, and increased incidents of other types of flooding. (0210-5 [Sharp, 

Andrea Heuson])

Comment: In addition, proper reporting and evaluation of present and forecasted climatological 

changes and how they might affect the power plant operations is of critical importance. (0211-2

[Malefatto, Alfred])

Comment: In addition, the assumptions made about sea level rise are inaccurate. If they are, 

the plant will be an island before the units are taken out of service. (0212-2 [Ross, Robert and 

Teresa])

Comment: The site proposed for expansion is located directly on the shores of Biscayne 

National Park in an area that is extremely susceptible to sea level rise and the impacts of 

climate change. (0228-2 [Yeager, Jerry])

Comment: Furthermore, expanding a nuclear power plant in an area that is ground zero for 

sea level rise threatens the future of South Florida. (0228-7 [Yeager, Jerry])

Comment: I am especially worried that neither FPL nor the NRC have addressed the issue of 

sea level rise, which has the potential to reach up to six feet by the end of this century. (0236-1

[Enfield, David])

Comment: The low-lying wetlands which surround Turkey Point contain some of the lowest 

elevations in South Florida. Even a half foot of sea level rise will be enough to inundate the 

5,000 acres of canals used to cool the two reactors currently operating at this location. They are 

filled with hot and extremely salty water - as well as chemicals used to kill a recent algae 

outbreak in the canals. With scientists measuring ever-increasing sea level rise from the melting 

of our planet's remaining ice in addition to thermal expansion due to increased temperatures, 

those 6 inches of sea level rise are a virtual certainty. New nuclear reactors in this location will 

be sitting on islands in Biscayne Bay - quite possibly in the not so distant future. (0240-6

[Commenters, Multiple])

Comment: There are many concerns that have been brought but my biggest concern is that 

the Turkey Point site is not safe, because it is vulnerable like Fukushmia to sea level rise and 

because it has problems with cooling its existing units. Neither of these concerns are 

addressed in the application submitted to your agency. (0244-2 [Haber, Rochelle])

Comment: Expanding in this location that is so vulnerable to sea level rise and severe 

hurricanes is irresponsible. (0245-2 [Lindsey, Jerrie])

Comment: The aforementioned article from Climate Central pointed out the deficiencies in 

FPL's projections concerning sea level rise and storm surges for its application for Units 6 and 

7: [Commenter submitted the following two paragraphs from a website article regarding 

Appendix E October 2016 E-121 NUREG–2176
maximum storm surge] During its safety assessment for the new reactors' applications at Turkey 

Point, FPL has modeled a worst-case scenario, based on what they estimate to be the highest 

tide conditions paired with the worst potential hurricane to strike the area -- plus an additional 10 

percent for an extra margin of safety. Based on these estimates, FPL predicts the maximum 

storm surge at the location of the new Turkey Point reactors would likely be no higher than 24.8 

feet, which is 1.2 feet below the plant's safety facilities. In particular, these calculations of a 

likely maximum storm surge include an estimate that sea level could rise by between 0.78 and 1 

foot in Biscayne Bay during the next century. This rate of sea level rise was based on 

observations taken at a nearby NOAA tide gauge between the years 1931 and 1981 and then 

extrapolated forward. Scientists, however, have observed that in recent decades the rate of sea 

level rise has been accelerating. According to a Climate Central analysis of sea level rise in the 

same region, but based on readings for the most recent 30-year period, the rate of sea level rise 

around Turkey Point is already about 15 percent higher, or about 1.1 feet-per-century, than what 

FPL used in its assessment. Consequently, FPL's assessment that Turkey Point can withstand 

a worst-case scenario storm might fall short. There is already a growing consensus among 

scientists that the rate of sea level rise is higher than the IPCC estimated in their 2007 report. 

For example, a 2010 report from the National Academy of Sciences confirmed that the future 

rate of sea level rise may actually be higher than that projected by the 2007 IPCC assessment, 

because that report didn't take into account future ice losses from Greenland and Antarctica. 

Consequently, FPL has likely failed to account for how much sea level will rise at Turkey Point 

in the next 100 years. Because these rates of sea level rise are included in the calculations of 

how large storm surges could be at Turkey Point, FPL may also be underestimating their "worstcase scenario." (0246-3 [Shlackman, Mara])

Comment: I would also be so bold to suggest to you that you contact Dr. Harold R. Wanless, 

Professor and Chair, Department of Geological Sciences at the University of Miami regarding 

the increase sea level rise in our State. (0250-6 [Fulks, Anna Louise])

Comment: [E]xisting nuclear power reactors at Turkey Point have already exceeded the 

carrying capacity of the existing water resources, and have become dysfunctional. (0252-3 [Van 

Leer, Sam])

Comment: As Sea-Level Rise (SLR) progresses, these problems will only get worse. There will 

be more salt intrusion into the aquifer, more hypersaline water, more algae bloom, and more 

toxic chemicals. (0252-9 [Van Leer, Sam])

Comment: Furthermore, South Florida is vulnerable to the impacts of climate change, including 

storm surge, sea level rise, and increased incidents of other types of flooding. (0253-4 [Bloom, 

Justin] [Campbell, Cara] [Causey, Charlie] [Cavros, George] [Chenoweth, Mike] [Daly, Meg] [England, 

Margaret] [Fuller, Manley] [Jones, George L.] [Keller, Alan] [Martin, Drew] [McLaughlin, Caroline] 

[Reynolds, Laura] [Silverstein, Rachel] [White, Paton] [Williams, Elinor])

Comment: Furthermore, South Florida is extremely susceptible to the impacts of climate 

change, including sea level rise, storm surge, and increased incidents of other types of flooding.

(0254-4 [Dudley, Dwight] [Lerner, Cindy] [Regalado, Tomas] [Stoddard, Philip K.])

Comment: If expanded, Turkey Point would become one of the largest nuclear power facilities 

in the country, located in an area that is ground zero for sea level rise. (0258-2 [Field, Fran])

Comment: We surmise that a tsunami isn't necessary to poison the Atlantic; sea level rise 

alone will do it, assisting the Corexit and BP oil polluted Gulf Stream. The low-lying wetlands 

which surround Turkey Point contain some of the lowest elevations in South Florida. Even a half 

Appendix E NUREG–2176 E-122 October 2016
foot of sea level rise will be enough to inundate the 5,000 acres of canals used to cool the two 

reactors currently operating at this location. They are filled with hot and extremely salty water - 

as well as chemicals used to kill a recent algae outbreak in the canals. (0264-3 [Dwyer, John P.])

Comment: If expanded, Turkey Point would become one of the largest nuclear power facilities 

in the country, located in an area that is ground zero for sea level rise. (0284-2 [Lopez, Josie])

Comment: 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/thepress-office/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. (0288-14 [Cleland, Noel] [Jackalone, Frank] 

[Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: Florida and Power 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. (0288-4 [Cleland, Noel] [Jackalone, Frank] [Mahoney, 

Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: 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. (0288-5 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] 

[Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: 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. (0288-9 [Cleland, Noel] [Jackalone, 

Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, 

Jonathan])

Comment: The proposed expansion site is on the shores of Biscayne National Park in an area 

that is extremely susceptible to sea level rise and the impacts of climate change, making this a 

public safety issue. (0295-3 [Dietrich, Chris OMeara])

Comment: We need to be pulling back from coastal development, particularly in Florida which 

is extremely vulnerable to the effects of sea rise and other factors of our changing climate.

(0297-2 [Strouble, Jackie])

Comment: With climate change sea level will rise. A nuclear plant in Florida will be very 

vulnerable to this sea level rise. If we do not also consider the effects on sea level on this 

expansion of Turkey Hill, we will also be wasting money and putting Florida's citizens at risk.

(0298-1 [Cafarelli, Cenie])

Appendix E October 2016 E-123 NUREG–2176
Comment: The site proposed for expansion of the Turkey Point Power Plant, in Homestead, 

Florida, is located directly on the shores of Biscayne National Park in an area that is extremely 

susceptible to sea level rise and the impacts of climate change[.] (0299-1 [Salatino, Freda])

Comment: Finally, expanding a nuclear power plant in an area that is ground zero for sea level 

rise threatens the future of South Florida. (0299-4 [Salatino, Freda])

Comment: Expanding this facility in the face of sea level rise is profoundly irrational and 

dangerous, as you surely know. (0318-1 [Teasley, Regi])

Comment: The site proposed for expansion is located directly on the shores of Biscayne 

National Park in an area that is extremely susceptible to sea level rise, hurricanes and the 

impacts of climate change like large shifts of sand, changes in salinity of fresh water. (0320-1

[Ericson, Del])

Comment: if global warming hits the planet, fla will be under water (0327-1 [Anonymous, 

Anonymous])

Comment: It is fool-hardy to place such risky reactors at the very edge of a rising sea level. 

The eventual damage to people and the environment is too great for such a venture. (0337-4

[Philips, Sally B.])

Comment: I wish we could see more debate in public about the wisdom of siting two more 

reactors at a site that will be ground zero for sea level rise and extreme weather and that is 

upwind of a vast, densely-populated urban area. (0342-1 [Merleaux, Derek])

Comment: Putting nukes on Biscayne Bay has got to be one of the most senseless actions 

you could take. Are you paying no attention at all to what government scientists are saying 

about sea level rise? Are you planning to put these nukes on the equivalent of an offshore oil 

rig? (0355-1 [Thomas, Bill])

Comment: The consensus of the scientific community is that, within ten years, today's high 

temperatures will be tomorrow's lows. NASA scientists have also predicted a world wide 

drought. We see that drought has been ongoing in California (for four years with no relief in 

sight) and other States as well as other countries, worldwide. We have experienced droughts 

here in South Florida in the past, and we know that the possibility exists for more droughts.

(0365-6 [Fischer, Antoinette])

Comment: I would like you to meet with University of Miami Professor Harold Wanless.

(0373-11 [Lee, Nancy])

Comment: The tide is rising. We don't want two more nuclear power plants built on fill. (0373-3

[Lee, Nancy])

Comment: Until you talk to Harold Wanless Geologist about rising sea water this is really a 

stupid idea. I just don't think you are thinking straight. (0373-8 [Lee, Nancy])

Comment: If the sea levels were to rise to a level of contact with the reactors, the 

consequences would be devastating. (0400-1 [Eckert, Brenda])

Comment: Is this a new solution to the age-old problem of cooling a nuke reactor - by putting it 

under six feet of sea water?!? Wake UP and 'get more smarter'!! (0414-1 [Standley, Ron])

Appendix E NUREG–2176 E-124 October 2016
Comment: Expansion will take place in an area susceptible to sea level rise and the f climate 

change, with a sensitive ecological habitat and f limited freshwater resources. Please halt the 

widespread negative environmental and public health and safety impacts and the serious 

threats to Biscayne National Park. (0417-2 [Beattie, Jane])

Comment: How anyone could consider placing a nuclear power plant in Florida despite the 

projected sea level rise is dumbfounding. (0440-3 [Hoyle, Lester and Judy])

Comment: At this very moment, Miami is spending $400 million to build sea walls and pumps 

and raise sidewalks 2 feet to cope with current and projected conditions. Since we don't answer 

to Rick Scott here's some concepts you must learn: Global Warming, Climate Change, Sea 

Level Rise, Sustainability. (0440-4 [Hoyle, Lester and Judy])

Comment: Has anyone thought about the rising tides from climate change brought on by all 

that extra CO2? You know, as Fukashima showed, reactors don't work so well under water. Oh, 

I forgot; it's illegal to talk about that global warming thing in Florida. Forget it; just don't tell the 

NSA I brought it up. (0443-1 [Jones, Gary])

Comment: Comment 8: The final Environmental Impact Statement should incorporate 

higher sea-level rise projections and local measurements of sea-level rise rates into its 

analysis of the risks presented by the Turkey Point Nuclear Plant Units 6 & 7 project. The 

DEIS states that "[s]ea level is projected to rise 1 to 4 ft. globally by 2100." DEIS at I-3. This 

figure comes from the U.S. Global Change Research Program, which is the only source for sealevel rise projections cited in the DEIS. In contrast, the National Oceanic and Atmospheric 

Administration (NOAA) has stated that "[n]o widely accepted method is currently available for 

producing probabilistic projections of sea level rise at actionable scales (i.e. regional and local)." 

http://tinyurl.com/NOAA-SLR at 1. Furthermore, there is broad uncertainty regarding the specific 

effects that glacial melting and thermal expansion of the oceans will have on rising sea levels. i. 

at 2. "[O]ne of the functions of a NEPA statement is to indicate the extent to which 

environmental effects are essentially unknown . . . . Reasonable forecasting and speculation is 

thus implicit in NEPA, and we must reject any attempt by agencies to shirk their responsibilities 

under NEPA by labeling any and all discussion of future environmental effects as 'crystal ball 

inquiry.'" Scientists' Inst. for Pub. Info., Inc. v. Atomic Energy Comm'n, 481 F.2d 1079, 1092 

(D.C. Cir. 1973); see also N. Plains Res. Council, Inc. v. Surface Transp. Bd., 668 F.3d 1067, 

1079 (9th Cir. 2011) (same). Therefore, when data is incomplete or uncertain as with sea-level 

rise projections, "reasonably foreseeable" includes "impacts which have catastrophic 

consequences, even if their probability of occurrence is low, provided that the analysis of 

the impacts is supported by credible scientific evidence, is not based on pure conjecture, and is 

within the rule of reason." 40 CFR § 1502.22 (emphasis added). Based on the above, the final 

Environmental Impact Statement should account for multiple sea-level rise projections, including 

those with the highest projected sea-levels. In 2012, NOAA released four sea-level rise planning 

scenarios, the highest of which projected 6.6 feet of sea-level rise by 2100. Concerning these 

scenarios, NOAA recommended: The Highest Scenario should be considered in situations 

where there is little tolerance for risk (e.g. new infrastructure with a long anticipated life cycle 

such as a power plant). http://tinyurl.com/NOAA-SLR at 2 (emphasis added); see id. at 12 and 

15. Moreover, scientists at the University of Miami have measured sea-level rise locally, finding 

even higher rates than predicted: [O]ver the past 15 years, the average annual increase [in sea 

level] is roughly 0.27./year, but over just the past 5 years, it's about 0.97"/year. 

http://www.rsmas.miami.edu/blog/2014/10/03/sea-level-rise-in-miami/ (emphasis added). Using 

this information and modeling from the National Hurricane Center, the City of Miami and the 

Village of Pinecrest commissioned a sea-level rise assessment for the proposed site of the new 

Appendix E October 2016 E-125 NUREG–2176
reactors. That assessment is attached to these comments as COM -- D. It accounts for SLOSH 

MOM scenarios, the planned increases in elevation for the new facilities, and uses storm surge 

data for southern Biscayne Bay. The findings of this assessment demonstrate that even by the 

year 2030, storm surges could isolate the reactor site and inundate the industrial wastewater 

facility. It is important to note that this assessment displays information for mean tides only. The 

effects of a storm surge would be greater in a hurricane at high tide. Due to the uncertain nature 

of the data presented in the DEIS and the new reactors' low tolerance for risk, NEPA requires 

that the final Environmental Impact Statement consider greater potential sea levels based on 

existing credible scientific evidence. Additionally, the final Environmental Impact Statement 

should include existing, local measurements of rates of sea-level rise and account for more than 

static sea-level rise, which by itself does not reveal risks associated with more frequent and 

severe flooding. (0456-14 [Miami, City])

Comment: Comment 9: In addition to Appendix I, the final Environmental Impact 

Statement should integrate subsections related to sea-level rise throughout its review. 

Appendix I of the DEIS contains the majority of the discussion on climate change and sea-level 

rise. Sea-level rise was likely relegated to a single appendix for ease of reference and to 

consolidate discussion on a complicated problem. Nevertheless, it is not the kind of problem 

that should be acknowledged separately from the rest of the environmental review. Instead, the 

potential consequences of sea-level rise should be incorporated into, and analyzed at, every 

stage of the review process. For example, the section discussing the transportation of 

radiological materials would benefit from its own analysis of how rising sea-levels might affect 

this particular process. (0456-15 [Miami, City])

Comment: Comment 10: The final Environmental Impact Statement should examine how 

the Turkey Point Nuclear Plant Units 6 & 7 project's adverse environmental impacts are 

likely to undermine efforts at sea-level rise adaptation. The DEIS notes that, among other 

problems caused by climate change, "[s]ea-level rise will also push the freshwater-seawater 

interface further inland. This will put further stresses on freshwater resources inland." DEIS at I5. These problems are likely to occur due to sea-level rise regardless of future activities at the 

Turkey Point site. However, the U.S. Environmental Protection Agency (EPA) has stated, in its 

April 2015 letter to the U.S. Army Corps of Engineers (USACE), that FPL's project "may result in 

substantial and unacceptable impacts to mangrove wetlands, sawgrass marshes and 

[submerged aquatic vegetation], which we consider to be [aquatic resources of national 

importance]." Attached as COM -- B. These environmental resources are significant not only in 

the context of the Clean Water Act, but also to the discussion concerning sea-level rise impacts. 

The problem of saltwater intrusion cannot be separated from sea-level rise, storm surge, and 

other threats to the public's potable water supply. Even without extreme rises in sea-level, storm 

surges can exacerbate saltwater intrusion. In contrast, mangrove roots stabilize shorelines and 

enhance water clarity. Sawgrass marshes function as natural water filtration systems. Placing 

the new reactors at Turkey Point threatens 300 acres of mangrove wetlands and 40 acres of 

sawgrass marshes. Hence, Miami agrees with the EPA's requests for additional analysis and its 

conclusion that the project should not be approved as currently proposed. Moreover, as these 

environmental resources provide important benefits related to water quality, the final 

Environmental Impact Statement should examine how their loss will exacerbate the 

consequences of sea-level rise and limit efforts at successful adaption. Similarly, NRC RAI EIS 

7.2-3 (RAI No. 5768 Revision 2) requests from FPL a discussion of adaptions being considered 

to account for changes in environmental impacts due to sea-level rise up to the year 2050. This 

discussion should also be included in the final Environmental Impact Statement. (0456-16 [Miami, 

City])

Appendix E NUREG–2176 E-126 October 2016
Comment: Comment 11: The final Environmental Impact Statement's analysis should 

include worst case and plausible scenarios. The DEIS notes that: Climatological changes 

might affect the average environmental risks of severe accidents because of changes in either 

severe accident probabilities or associated consequences. While the potential severity of storms 

and other natural phenomena might increase, nuclear power plants must be designed to 

withstand all creditable natural events at the site of concern. Increases in the severity of 

hurricanes with associated storm surges could increase the chance that a challenged safety 

system may not function. However, the core damage frequencies (CDFs) for the Advanced 

Passive 1000 (AP1000) pressurized water reactor design are very low and climate change is 

unlikely to change the CDFs appreciably. Therefore, even if consequences change as a result 

of climate change, severe accident risk is likely to remain SMALL because CDFs are so low. 

DEIS at I-13. It further states that "as long as floodwaters did not rise to the level of the plant 

grade, there would be no contribution to CDF. More detail [sic] evaluation of external flooding at 

Turkey Point site also confirmed that the flood level at probable maximum precipitation will be 

below the plant grade." DEIS at 5-130. These statements in the DEIS raise three questions that 

should be addressed in the final Environmental Impact Statement: •What sea-level rise 

projection was used to generate the maximum probable storm-surge contemplated above? 

•What operational lifetime was projected for the new reactors? •Was the worst case scenario 

hurricane drawn from a proper sample of storms? The first question does not require additional 

explanation. Concerning the second question, the U.S. Nuclear Regulatory Commission's Office 

of Nuclear Regulatory Research has confirmed that it is investigating the possibility of licensing 

reactors to operate for a total of 80 years and that it expects the first applications for these 

licenses to be submitted in the next couple years. Currently, nuclear reactors may not be 

licensed beyond a total of 60 years. FPL's most recent filings before the Florida Public Service 

Commission show that it plans to delay operation of the new reactors to the late 2020s. If the 

new reactors were eventually approved for a total of 80 years, it would extend their operation up 

to the year 2100, when NOAA's projections contemplate 6.6 feet of sea-level rise. Therefore, 

the final Environmental Impact Statement should account for an 80 year operating life of the 

proposed reactors when analyzing the potential impacts of sea-level rise near Turkey Point. 

Concerning the third question, new research into deeper climate histories suggests that, due to 

natural variability, the storm hazard profile of the recent era could be lower than what might be 

experienced in the future. See Donnelly and Woodruff, attached to these comments as COM - 

C. In short, it is possible that the intensity of future storms is being underestimated. (0456-17

[Miami, City])

Comment: Comment 7: The final Environmental Impact Statement should examine and 

clarify how the operation of the Turkey Point Nuclear Plant Units 6 & 7 project, as 

currently proposed, might constrain attempts to adapt to climate change and to remedy 

the history of destabilizing uses and impacts the regional ecosystem has already 

suffered. The DEIS contemplates that demand for water by all users will increase significantly 

in Miami-Dade County before the new reactors begin operating. See DEIS at 2-176. Similarly, 

"[t]hermoelectric demand for power use is projected to increase from 2.1 Mgd (four-tenths of 

one percent of total demand) to 69.8 Mgd (about 10 percent of total demand) from 2005 to 

2025, respectively." Id. At the least, this information should be updated to include the water 

being diverted to the FPL industrial wastewater facility. Moreover, the DEIS concludes that the 

"[a]dditional extraction of groundwater by [Miami-Dade County] to meet plant requirements for 

potable and service water is negligible compared to the current demand. Therefore, the [DEIS] 

concludes that operational groundwater-use impacts would be SMALL, and mitigation beyond 

the FDEP final Conditions of Certification would not be warranted." DEIS at 5-26. The 

conclusion that groundwater-user impacts would be small stands in contrast to the projection 

that thermoelectric demand will grow to 10 percent of all water demand in Miami-Dade County. 

Appendix E October 2016 E-127 NUREG–2176
The relationship between these determinations should be explained more directly in the final 

Environmental Impact Statement. To the extent that an Environmental Impact Statement is a 

decision-making tool, it should also clarify the tradeoffs of pursuing the Turkey Point Nuclear 

Plant Units 6 & 7 project as currently proposed. As has been made clear, FPL facilities consume 

large volumes of water in a region that already has extremely limited freshwater resources. Any 

conflicts presented by the operation of the new reactors with investments in the Comprehensive 

Everglades Restoration Plan (CERP), protecting the Biscayne Aquifer from saltwater intrusion, 

or the consumption of potable water by the public should be made clear, not only in the body of 

the final Environmental Impact Statement, but also in the executive summary. As an additional 

matter, any decision based on the final Environmental Impact Statement would benefit from an 

examination of how the placement of the new reactors at Turkey Point might affect regional 

adaptation strategies. As sea levels rise, saltwater intrusion intensifies, and drinking water 

becomes more expensive, the South Florida region will be required to pursue a variety of 

adaptation strategies. The majority of these adaptations will be forced to occur during the 

operating life of the new reactors. The need for power identified in the DEIS is predicated on 

assumptions that may not be in line with these adaptive strategies and potential inconsistencies 

should be explored further. (0456-27 [Miami, City])

Comment: Expand Consideration of Sea-Level Rise Scenarios and Related Impacts 

Turkey Point is a low-lying peninsula bordered by a shallow bay to the east and the Everglades 

to the west. The proposed site of the new reactors is a mud island southwest of the current plant 

that is surrounded by the industrial wastewater facility and borders Biscayne Bay. DEIS at 3-2. 

The proposed site will be raised with fill to a finished grade elevation of 25.5 ft North American 

Vertical Datum 1988 (NAVD88). Id. As noted by the DEIS, the U.S. Global Change Research 

Program rates the vulnerability of the Turkey Point area to sea-level rise as "high" to "very high." 

DEIS at I-3. The DEIS further acknowledges that: Sea-level rise also is expected to 

"...accelerate saltwater intrusion into freshwater supplies from rivers, streams, and groundwater 

sources near the coast" and agricultural areas around Miami-Dade County "...are at risk of 

increased inundation and future loss of cropland with a projected loss of 37,500 acres in Florida 

with a 27-inch sea level rise." Water demand in southeastern Florida is projected to increase by 

more than 50 percent by 2060, relative to 2005, based on combined changes in population, 

socioeconomic conditions, and climate. Id. However, the DEIS merely acknowledges these 

issues as a matter distinct from the rest of its analysis. It does not incorporate the 

consequences of climate change into its broader review of the cumulative impacts that may be 

associated with the siting of new reactors at Turkey Point. (0456-28 [Miami, City])

Comment: Seriously? You all want to expand a nuke plant in a prime spot for sea level rise? Is 

there no end to the stupidity that can be permitted by the NRC? Beyond poor siting (next to 

Biscayne National Park), consider also what will happen when this site is inundated by sea 

water, either through ocean rise or major storms. (0459-1 [Smyke, Pete])

Comment: The proposed construction site is very susceptible to damage from storm surges 

and hurricanes. Both the facility and the required long-term radioactive waste storage would be 

at risk from such weather events and would also be susceptible over the long term to rises in 

sea level already being triggered by climate change. (0463-3 [Gross, Cheryl A.])

Comment: It would also be incredibly dumb to build a couple more nukes that close to sea 

level, even if the science denying governor refuses to notice sea level rise. (0470-1 [Lenz, 

Andrew])

Appendix E NUREG–2176 E-128 October 2016
Comment: With sea level rise, freshwater resources are in danger of sea contamination.

(0474-1 [Robinson, Angel])

Comment: No more nuclear plants in precarious and sensitive locations! Our nation needs to 

get real about the rising sea levels, an event we will witness in our lifetimes, and build our power 

grid accordingly, or we could pay for our folly with inestimable environmental damage. Florida is 

particularly vulnerable. (0476-1 [Monfort, Brooke])

Comment: Furthermore, expanding a nuclear power plant in an area that is ground zero for 

sea level rise threatens the future of South Florida, especially with the Antarctic ice sheets 

melting so swiftly. (0488-1 [Liesche, Ken])

Comment: The expansion of Turkey Point in Biscane National Park i s an irreplaceable 

national treasure in an area that is susceptible to sea level rise and the impacts of climate 

change. (0493-1 [Davidson, Penny])

Comment: And projected sea level rise could have an adverse effect on this project. (0497-1

[Brstow, Mary])

Comment: I am concerned for the future of my community. We are confronted by sea-level rise 

and a diminishing drinking water supply. FPL's project, as proposed, may needlessly endanger 

our sole source of freshwater by exacerbating saltwater intrusion. (0515-2 [Regalado, Tomas])

Comment: Isn't anyone noticing the constant flooding episodes in Miami already? Sea levels 

are rising, especially noticeable here in Florida. Why stick our heads in the sand, and make 

believe it is not happening? (0516-1 [Coffey, Rotraud])

Comment: The estimated sea level rise by the end of this century is from 1 to 2 meters(7 feet), 

maybe higher. While the proposed reactors and mechanical draft cooling towers may be 

sufficiently elevated and safe from day to day flooding. FPL's customer base will NOT have 

similar protections, hundreds of thousands, maybe more than a million South Florida's 

households will be risk of flooding during high tide & storm events. I.E. Demand for electricity 

will drop off as large portions of South Florida flood in a semi-permanent fashion. (0545-2

[Keating, Tim])

Comment: Sea level rise makes the location of these plants irresponsible. I have lived in 

Florida all of my rather long life and seen what hurricanes can do in coastal areas; this is 

especially true in South Florida. (0550-1 [H., Pat])

Comment: The low-lying wetlands which surround Turkey Point contain some of the lowest 

elevations in South Florida. Even a half foot of sea level rise will be enough to inundate the 

5,000 acres of canals used to cool the two reactors currently operating at this location. They are 

filled with hot and extremely salty water -as well as chemicals used to kill a recent algae 

outbreak in the canals. With scientists measuring ever-increasing sea level rise from the melting 

of our planet's remaining ice in addition to thermal expansion due to increased temperatures, 

those 6 inches of sea level rise are a virtual certainty. New nuclear reactors in this location will 

be sitting on islands in Biscayne Bay -quite possibly in the not so distant future. (0551-1

[Anonymous, Anonymous])

Comment: If expanded, Turkey Point would become one of the largest nuclear power facilities 

in the country, located in an area that is AT GROUND ZERO FOR SEA LEVEL RISE. (0584-1

[Mazzuca, Rich])

Appendix E October 2016 E-129 NUREG–2176
Comment: Not only is it too near a National Park, it is also an area of ;potential sea level rise in 

our increasingly warmer oceans. This would threaten the freshwater in the area. (0588-6 [Hanna, 

Jane])

Comment: This is 2015 and given the impact of climate change and the resulting sea level 

rise, one would think that intelligent forward thinking individuals would not consider an 

expensive, water intensive option like nuclear energy. (0590-2 [Johnson, Diane])

Comment: In addition, South Florida is highly vulnerable to continuing and worsening drought 

as climate change continues to worsen. New nuclear power requires extreme amounts of 

precious fresh water supplies. Solar and wind power do not require any use of precious fresh 

water supplies. Nuclear power plants in Alabama and Tennessee and other states have been 

shut down because of drought. More nuclear power plants will be shut down when drought 

continues to get worse because of worsening climate change. (0592-8 [Brexel, Sr., Charles])

Comment: The site is also vulnerable to the impacts of rising seas. Logically, it does not add 

up. (0594-2 [Rapuano, Shannon])

Comment: It would be extremely irresponsible to site a nuclear reactor in South Florida where 

rising sea levels will threaten a major nuclear accident. (0599-2 [Rock, Andrew])

Comment: Comment 9: The final Environmental Impact Statement should incorporate 

higher sea-level rise projections and local measurements of sea-level rise rates into its 

analysis of the risks presented by the Turkey Point Nuclear Plant Units 6 & 7 project. The 

DEIS states that "[s]ea level is projected to rise 1 to 4 ft. globally by 2100." DEIS at I-3. This 

figure comes from the U.S. Global Change Research Program, which is the only source for sealevel rise projections cited in the DEIS. In contrast, the National Oceanic and Atmospheric 

Administration ("NOAA") stated that "[n]o widely accepted method is currently available for 

producing probabilistic projections of sea level rise at actionable scales (i.e. regional and local)." 

http://tinyurl.com/NOAA-SLR at 1. Furthermore, there is broad uncertainty regarding the specific 

effects that glacial melting and thermal expansion of the oceans will have on rising sea levels. 

See id. at 2. "[O]ne of the functions of a NEPA statement is to indicate the extent to which 

environmental effects are essentially unknown . . . . Reasonable forecasting and speculation is 

thus implicit in NEPA, and we must reject any attempt by agencies to shirk their responsibilities 

under NEPA by labeling any and all discussion of future environmental effects as "crystal ball 

inquiry.'" Scientists' Inst. for Pub. Info., Inc. v. Atomic Energy Comm'n, 481 F.2d 1079, 1092 

(D.C. Cir. 1973); see also N. Plains Res. Council, Inc. v. Surface Transp. Bd., 668 F.3d 1067, 

1079 (9th Cir. 2011) (same). Therefore, when data is incomplete or uncertain as with sea-level 

rise projections, "reasonably foreseeable" includes "impacts which have catastrophic 

consequences, even if their probability of occurrence is low, provided that the analysis of 

the impacts is supported by credible scientific evidence, is not based on pure conjecture, and is 

within the rule of reason." 40 CFR § 1502.22 (emphasis added). Based on the above, the final 

Environmental Impact Statement should account for multiple sea-level rise projections, including 

those with the highest projected sea-levels. In 2012, NOAA released four sea-level rise planning 

scenarios, the highest of which projected 6.6 feet of sea-level rise by 2100. Concerning these 

scenarios, NOAA recommended: The Highest Scenario should be considered in situations 

where there is little tolerance for risk (e.g. new infrastructure with a long anticipated life cycle 

such as a power plant). http://tinyurl.com/NOAA-SLR at 2 (emphasis added); see id. at 12 and 

15; see also Horton, Radley, et al. "New York City Panel on Climate Change 2015 Report 

Chapter 2: Sea Level Rise and Coastal Storms." Annals of the New York Academy of Sciences 

1336.1 (2015): 36-44; Kopp, Robert E., et al. "Probabilistic 21st and 22nd century sea-level 

Appendix E NUREG–2176 E-130 October 2016
projections at a global network of tide-gauge sites." Earth's Future 2, no. 8 (2014): 383-406. 

Moreover, scientists at the University of Miami have measured sea-level rise locally, finding 

even higher rates than predicted: [O]ver the past 15 years, the average annual increase [in sea 

level] is roughly 0.27./year, but over just the past 5 years, it's about 0.97./year. 

http://www.rsmas.miami.edu/blog/2014/10/03/sea-level-rise-in-miami/ (emphasis added). The 

acceleration measured by the University of Miami may stem from natural variability. 

Nonetheless, natural variability could exacerbate climate change signals for periods spanning 

multiple decades. Using this information and modeling from the National Hurricane Center, the 

City of Miami and the Village of Pinecrest commissioned a sea-level rise assessment for the 

proposed site of the new reactors. That assessment is attached to these comments as COM - 

D. It accounts for SLOSH MOM scenarios, the planned increases in elevation for the new 

facilities, and uses storm surge data for southern Biscayne Bay. The findings of this assessment 

demonstrate that even by the year 2030, storm surges could isolate the reactor site and 

inundate the industrial wastewater facility. It is important to note that this assessment displays 

information for mean tides only. The effects of a storm surge would be greater in a hurricane at 

high tide. Likewise, climate models predict longer stretches of dry days between more intense 

rain events in the subtropics. The combination of these conditions increases the likelihood of 

more severe floods in the region. Climate Change and Water Management in South Florida: 

Interdepartmental Climate Change Group, SOUTH FLORIDA WATER MANAGEMENT 

DISTRICT (Nov. 2009). Further, weakening of the Gulf Stream implies additional sea-level rise, 

which is not accounted for in the DEIS. Due to the uncertain nature of the data presented in the 

DEIS and the new reactors' low tolerance for risk, NEPA requires that the final Environmental 

Impact Statement consider greater potential sea levels based on existing credible scientific 

evidence. Additionally, the final Environmental Impact Statement should include existing, local 

measurements of rates of sea-level rise and account for more than static sea-level rise, which 

by itself does not reveal risks associated with more frequent and severe flooding. See, e.g., 

Sweet, William V., and Joseph Park. "From the extreme to the mean: Acceleration and tipping 

points of coastal inundation from sea level rise." Earth's Future 2.12 (2014): 579-600. (0611-11

[Haber, Matthew S.])

Comment: Comment 10: In addition to Appendix I, the final Environmental Impact 

Statement should integrate subsections related to sea-level rise throughout its review. 

Appendix I of the DEIS contains the majority of the discussion on climate change and sea-level 

rise. Sea-level rise was likely relegated to a single appendix for ease of reference and to 

consolidate discussion on a complicated problem. Nevertheless, it is not the kind of problem 

that should be acknowledged only separately from the rest of the environmental review. Instead, 

the potential consequences of sea-level rise should be incorporated into, and analyzed at, every 

stage of the review process. For example, the section discussing the transportation of 

radiological materials would benefit from its own analysis of how rising sea-levels might affect 

this particular task. (0611-12 [Haber, Matthew S.])

Comment: Comment 11: The final Environmental Impact Statement should examine how 

the Turkey Point Nuclear Plant Units 6 & 7 project's adverse environmental impacts are 

likely to undermine efforts at sea-level rise adaptation. The DEIS notes that, among other 

problems caused by climate change, "[s]ea-level rise will also push the freshwater-seawater 

interface further inland. This will put further stresses on freshwater resources inland." DEIS at I5. These problems are likely to occur due to sea-level rise regardless of future activities at the 

Turkey Point site. However, the U.S. Environmental Protection Agency ("EPA") stated, in its 

April 2015 letter to the U.S. Army Corps of Engineers ("USACE"), that FPL's project "may result 

in substantial and unacceptable impacts to mangrove wetlands, sawgrass marshes and 

[submerged aquatic vegetation], which we consider to be [aquatic resources of national 

Appendix E October 2016 E-131 NUREG–2176
importance]." Attached as COM - B. These environmental resources are significant not only in 

the context of the Clean Water Act, but also to the discussion concerning sea-level rise impacts. 

The problem of saltwater intrusion cannot be separated from sea-level rise, storm surge, and 

other threats to the public's potable water supply. Even without extreme rises in sea-level, storm 

surges can exacerbate saltwater intrusion. In contrast, mangrove roots stabilize shorelines and 

enhance water clarity. Sawgrass marshes function as natural water filtration systems. Placing 

the new reactors at Turkey Point threatens 300 acres of mangrove wetlands and 40 acres of 

sawgrass marshes. Hence, Miami agrees with the EPA's requests for additional analysis and its 

conclusion that the project should not be approved as currently proposed. Moreover, as these 

environmental resources provide important benefits related to water quality, the final 

Environmental Impact Statement should examine how their loss will exacerbate the 

consequences of sea-level rise and limit efforts at successful adaption. Similarly, NRC RAI EIS 

7.2-3 (RAI No. 5768 Revision 2) requests from FPL a discussion of adaptions being considered 

to account for changes in environmental impacts due to sea-level rise up to the year 2050. This 

discussion should also be included in the final Environmental Impact Statement. (0611-13 [Haber, 

Matthew S.])

Comment: Comment 8: The final Environmental Impact Statement should examine and 

clarify how the operation of the Turkey Point Nuclear Plant Units 6 & 7 project, as 

currently proposed, might constrain attempts to adapt to climate change and to remedy 

the history of destabilizing uses and impacts the regional ecosystem has already 

suffered. The DEIS contemplates that demand for water by all users will increase significantly 

in Miami-Dade County before the new reactors begin operating. See DEIS at 2-176. Similarly, 

*[t]hermoelectric demand for power use is projected to increase from 2.1 Mgd (four-tenths of 

one percent of total demand) to 69.8 Mgd (about 10 percent of total demand) from 2005 to 

2025, respectively." Id. At the least, this information should be updated to include the water 

being diverted to the FPL industrial wastewater facility. Moreover, the DEIS concludes that the 

*[a]dditional extraction of groundwater by [Miami-Dade County] to meet plant requirements for 

potable and service water is negligible compared to the current demand. Therefore, the [DEIS] 

concludes that operational groundwater-use impacts would be SMALL, and mitigation beyond 

the FDEP final Conditions of Certification would not be warranted." DEIS at 5-26. The 

conclusion that groundwater-user impacts would be small contradicts the projection that 

thermoelectric demand will grow to 10 percent of all water demand in Miami-Dade County. The 

relationship between these determinations should be explained more directly in the final 

Environmental Impact Statement. To the extent that an Environmental Impact Statement is a 

decision-making tool, it should also clarify the tradeoffs of pursuing the Turkey Point Nuclear 

Plant Units 6 & 7 project as currently proposed. As has been made clear, FPL facilities consume 

large volumes of water in a region that already has extremely limited freshwater resources. 

Likely climate change scenarios for South Florida include a 3-11% and up to 20% reduction in 

rainfall that will further tax freshwater demand. See Vasubandhu et al., Climate Scenarios: A 

Florida-centric View, STATE UNIV. SYSTEM OF FLORIDA (Nov. 2011) (citing Enfield et al., 

Mid-Century Expectations for Tropical Cyclone Activity and Florida Rainfall); see also Climate 

Change and Water Management in South Florida: Interdepartmental Climate Change Group, 

SOUTH FLORIDA WATER MANAGEMENT DISTRICT (Nov. 2009). Any conflicts presented by 

the operation of the new reactors with investments in the Comprehensive Everglades 

Restoration Plan (*CERP"), protecting the Biscayne Aquifer from saltwater intrusion, or the 

consumption of potable water by the public should be made clear, not only in the body of the 

final Environmental Impact Statement, but also in the executive summary. As an additional 

matter, any decision based on the final Environmental Impact Statement would benefit from an 

examination of how the placement of the new reactors at Turkey Point might affect regional 

adaptation strategies. As sea levels rise, saltwater intrusion intensifies, and drinking water 

Appendix E NUREG–2176 E-132 October 2016
becomes more expensive, the South Florida region will be required to pursue a variety of 

adaptation strategies. The majority of these adaptations will be forced to occur during the 

operating life of the new reactors. The need for power identified in the DEIS is predicated on 

assumptions that may not be in line with these adaptive strategies and potential inconsistencies 

should be explored further. (0611-18 [Haber, Matthew S.])

Comment: Expand Consideration of Sea-Level Rise Scenarios and Related Impacts 

Turkey Point is a low-lying peninsula bordered by a shallow bay to the east and the Everglades 

to the west. The proposed site of the new reactors is a mud island southwest of the current plant 

that is surrounded by the industrial wastewater facility and borders Biscayne Bay. DEIS at 3-2. 

The proposed site will be raised with fill to a finished grade elevation of 25.5 ft North American 

Vertical Datum 1988 (*NAVD88"). Id. As noted by the DEIS, the U.S. Global Change Research 

Program rates the vulnerability of the Turkey Point area to sea-level rise as *high" to *very high." 

DEIS at I-3. The DEIS further acknowledges that: Sea-level rise also is expected to **accelerate 

saltwater intrusion into freshwater supplies from rivers, streams, and groundwater sources near 

the coast" and agricultural areas around Miami-Dade County **are at risk of increased 

inundation and future loss of cropland with a projected loss of 37,500 acres in Florida with a 27-

inch sea level rise." Water demand in southeastern Florida is projected to increase by more than 

50 percent by 2060, relative to 2005, based on combined changes in population, socioeconomic 

conditions, and climate. Id. However, the DEIS merely acknowledges these issues as a matter 

distinct from the rest of its analysis. It does not incorporate the consequences of climate change 

into its broader review of the cumulative impacts that may be associated with the siting of new 

reactors at Turkey Point, nor does it assess the probability of 27 inches of sea-level rise being 

exceeded at various points in time. (0611-19 [Haber, Matthew S.])

Comment: I understand that the Safety Evaluation Report is not subject to public hearing. 

Based on discussions with local experts on sea level rise, the USACE's projected one foot rise 

over the 35 year life of the project seems overly conservative. If FPL's nuclear unit 6 and 7 are 

approved and built, and they become islands within the next 1015 years due to one foot of SLR, 

the NRC will face review of its approval. (0612-7 [Teas, James])

Comment: Section 3.2.2.1, Landscape and Stormwater Drainage (pg. 3-8): The proposed 

nuclear reactor Units 6 and 7, including cooling towers, makeup water reservoir, new substation 

and associated facilities, would be built on a filled "218 acre island" enclosed by a stabilized 

earth wall to the north, east, and west. A reinforced concrete wall could be constructed to the 

south. The elevation within the fill island would range from 19 feet to 26 feet North American 

Vertical Datum of 1988. With the threat of sea level rise in the foreseeable future, the EPA has 

concerns on what effect this may have on the surrounding infrastructure to this created island; 

there are concerns that rising sea levels could potentially surround the island at some point in 

the future during the lifespan of this project. Please provide information in the FEIS which would 

support construction of the project, considering the fact that even though the power units will be 

constructed on this island, the surrounding landscape may be impacted by sea level rise or 

storm surges that may affect the feasibility of the project, given the project purpose. FPL has 

stated that they provided substantial scientific data and testimony regarding the effects of sea 

level rise during the State site certification proceedings, and that the Recommended Order, 

adopted in the Final Order on Certification states: "The plant design elevation accounts for more 

than maximum storm surge plus sea level rise. FPL has provided reasonable assurance that the 

project is not contrary to the public interest as it relates to the sea level rise." The FEIS should 

evaluate, document and clarify the effectiveness of proposed measures to protect the facility 

from storm surges and rising sea level. (0617-1-8 [Mueller, Heinz J.])

Appendix E October 2016 E-133 NUREG–2176
Comment: Climate Change and Sea Level Rise. The Turkey Point site is in a low-lying, floodprone, (Section 2.2.1.4, p. 2-6) coastal area at or near sea level. It is often flooded by tides or 

freshwater runoff (Section 2.4.1.1, p. 2-74). Additionally, it is bounded by Biscayne Bay to the 

east, Card Sound to the south, and wetlands to the west. Florida Power & Light proposes to 

build the proposed action on a filled "island" (Section 3.2.2.1, p. 3-8). This island would contain 

the proposed two new nuclear units' power blocks and most of the associated infrastructure: the 

mechanical draft cooling towers, makeup-water reservoir, substation, underground injection 

control wells, and various small associated buildings. This island would be constructed on a 

vacant 218-acre mudflat, known as "Mud Island" (Section 4.1.1. l, pp. (4-4) - (4-6)). This 218-

acre mudflat is to be excavated down to XX feet and then filled to a plant grade of 26 feet. This 

elevation is above the design basis flood elevation of 24.8 ft. (Section 5.11.2.4, p. 5-129). 

Additionally, this land island is to be enclosed by a stabilized earth perimeter wall on the north, 

east, and west sides and a reinforced concrete wall on the south side (Section 3.2.2.1, p. 3-8). 

This land island will also be surrounded by 4,370 acres (Section 2.3 .1, p. 2-42) or 5,900 acres 

(Section 2.2.1.6, p. 2-7) of existing man-made, unlined cooling canals of the industrial waste 

facility. It is unclear whether the land island will be 26 feet above these existing cooling canals. 

Climate Change Adaptation: NRC's analysis of climate-change effects (Appendix I) does not 

consider potential climate-change impacts to the proposed action, nor subsequent impacts to 

the surrounding environment. Instead it documents NRC's qualitative determination of the likely 

changes described in Chapter 5 (operational impacts) if the environment is altered in a manner 

consistent with current climate-change predictions (Appendix I, p. 1-1). Recommendations:

EPA recommends NRC discuss potential climate-change impacts to the facility, resulting 

impacts to the surrounding communities, ecosystems, infrastructure, land uses, etc., and 

mitigation opportunities. Additionally, EPA recommends NRC use available sea-level rise and 

storm-surge models to quantify impacts to the proposed action, which can facilitate identification 

of associated impacts to the affected environment. For example, the USACE's Sea Level Rise 

analysis where alternatives are evaluated using "low," "intermediate," and "high" rates of future 

sea level rise for both "with" and "without" project conditions. [Footnote 1: Incorporating Sea 

Level Change in Civil Works Programs (31 December 2013) Department of the Army, U.S. 

Army Corps of Engineers, ER 1100-2-8162, Regulation No. 1100-2-8162, available at 

http://www.publications.usace.army.mil/Portals/76/Publications/EngineerRegulations/ER_1100-

2-8162.pdf] (0617-4-1 [Mueller, Heinz J.])

Comment: Sea Level Rise and Regional Stormwater Management: As noted by NRC, land 

was drained by a series of canals to support urban and agricultural development (Section 

7.3.2.1, p. 7-22). The anticipated encroaching sea-level can reverse water transport by moving 

sea water into these canals. Thereby raising the water-surface level and decreasing stormwater 

storage potential within these canals. Moreover, the rising water-surface level within these 

canals reflects the saturation of the surrounding soils. Saturated soils are unable to store storm 

water. Additionally, sea level rise is expected to decrease the water elevation gradient along this 

canal-drainage system. Thereby reducing the capacity for gravity-driven drainage through the 

canal network. Recommendations: EPA recommends NRC consider the effects of sea level 

rise, storm surge, and extreme storm events upon the regional canal system and surrounding 

saturated soils and associated impacts to the proposed action. EPA recommends this analysis 

include the stability of the proposed 218-acre, 26-foot elevated, land island having a three-sided 

earthen berm. For example, FPL proposes to include the underground injection control wells 

within the elevated, 218-acre, land island (Section 4.1.1.1, p. 4-4). EPA recommends NRC 

discuss whether these canals, UIC wells, and the four proposed radial collector wells, will act as 

conduits to transport ground water under the influence of sea level rise into the proposed facility. 

As NRC has noted, the drainage canals also provide a conduit for seawater to flow inland at 

high tide (Section 2.3.3.2, p. 2-66). Additionally, the analysis should include the combined 

Appendix E NUREG–2176 E-134 October 2016
effects of sea level rise combined storm surge and a heavy precipitation event. As NRC noted 

(Appendix I), the U.S. Global Change Research Program rates the vulnerability of the Turkey 

Point area to sea-level rise as "high" to "very high," and notes an "imminent threat of increased 

inland flooding during heavy rain events in low-lying coastal areas such as southeastern Florida, 

where just inches of sea level rise will impair the capacity of stormwater drainage systems to 

empty into the ocean." (0617-4-4 [Mueller, Heinz J.])

Comment: Sea Level Rise and Land Subsidence: Prior work suggests that land subsidence 

rates in South Florida could be in the 0. 7 to 1.8 mm per year range, with Dade County at 1.1 

mm per year, which could add 7 to 18 cm (or more) to sea level rise estimates for this area 

through the year 2080. [Footnote 3: Climate Change in Coastal Areas in Florida: Sea Level Rise 

Estimation and Economic Analysis to Year 2080, Center for Economic Forecasting and Analysis 

(2008). Available at 

http://www.cefa.fsu.edu/content/download/472341327898]. Recommendations: EPA 

recommends NRC discuss the potential impacts of filling a 218-acre mudflat, and thereby 

raising it to the proposed 26-foot plant grade, upon the Turkey Point area's land subsidence rate 

and affected environment. Additionally, EPA recommends NRC discuss this impact in context of 

projected sea level rise, storm surge, and extreme precipitation events. As stated earlier, the 

U.S. Global Change Research Program predicts the occurrence of more category 4 and 5 

storms. (0617-4-5 [Mueller, Heinz J.])

Comment: Sea Level Rise and Shoreline erosion: The proposed action is to be located in a 

low lying coastal area subject to shoreline erosion. It will impact 591 coastal acres. This includes 

182 acres of mudflat, 32 acres of open water, and 89 acres of various mangrove types, 

sawgrass marsh, and mixed wetland hardwood (Section 4.3.1.1, pp. (4-40) - (4-42)). 

Additionally, the industrial wastewater facility covers another 5,600 acres along 5 miles of the 

Biscayne Bay shoreline (Section 2.3.1.1, p. 2-44). Moreover an existing barge-turning basin is to 

be enlarged by 4,356 ft2 to accommodate large barges (Section 4.2.1.1, p. 4-27). Approximately 

328 miles (40 percent) of Florida's sandy beaches are eroding enough to threaten existing 

developments and recreation areas. [Footnote 4: Saving Florida's VANISHING Shores, 

http://www.epa.gov/climatechange/Downloads/impacts-adaptation/saving_FL.pdf] According to 

the state Department of Environmental Protection, 485 miles of beaches (59%) already are 

experiencing erosion, with 387 miles experiencing "critical erosion. [Footnote 5: Florida's 

Resilient Coasts: A State Policy Framework for Adaptation to Climate Change, 

http://www.ces.fau.edu/files/projectslclimate_change/Fl_ResilientCoast.pdf]." Recommendatio

ns: EPA recommends NRC examine the potential for shoreline erosion impacts associated with 

rising sea levels, storm surges, and increasing occurrence of Category 4 and 5 storms on the 

proposed action and associated impacts upon the affected environment. (0617-4-6 [Mueller, Heinz 

J.])

Comment: 4) Evaluation of Sea-Level Rise, Future Hurricanes and Storms, and Climate 

Change Impacts 

The NPS is concerned that the DEIS does not include a sufficient analysis of how sea-level rise, 

hurricanes and storms, and climate change may impact the proposed project and NPS 

resources affected by these changing conditions. These potential environmental impacts should 

be included in the DEIS. The DEIS does not include an analysis of sea-level rise as it pertains to 

the proposed action or the present facility, and its conclusions do not contain information which 

would indicate the effect of sea-level rise, including hurricanes and storms, demonstrating the 

potential effect on park resources. As discussed earlier, the concerns related to the IWF include 

the transfer of IWF water into the bay as a result of storm surge, including hurricanes. 

Appendix E October 2016 E-135 NUREG–2176
As the NRC and USACE are aware, there is a broad range of sea-level rise projections for 

South Florida. While predicted sea-level for the life of the project varies, projections agree about 

one key feature - sea-level is rising and it will continue to rise at an increasing rate. Most 

importantly, sea-level rise at a particular site is not a smooth, steady rate of increase, but rather 

it will be varied and include pulses from climatic events (notably storm surge from hurricanes) 

that could connect, as noted earlier, the IWF with Biscayne Bay and release pollutants from the 

IWF and other facilities that are not elevated and strongly reinforced. The DEIS currently has no 

analysis or discussion of the impacts on movement of materials (especially toxic materials, 

nutrients, and turbidity) from the Units 6 and 7 to Biscayne NP and Biscayne Bay that may occur 

with hurricanes, storms, and storm surge on the site. The impact of these higher, more forceful 

storm surges must be evaluated. 

The rate of sea-level rise in the region of the IWF is currently 2.4 mm/year and increasing. 

Projections by the Intergovernmental Panel on Climate Change (IPCC Fifth Assessment, 13.5, 

2013) show coastal water levels gaining between 0.40 and 0.63 m by the end of the century, 

with related increases in coastal erosion and additive impacts on storm surge. Additionally, sealevel in Miami is directly affected by the flow rate of the Florida Current I Gulf Stream system. 

Reductions in flow rate and associated increases in sea-level along the East Coast of North 

America above the global sea-level rise rates are predicted for this system. At a minimum, a 

monitoring and adaptive management program that tracks local sea level, measures 

connectivity between the IWF and the Bay, and acts to minimize risk from IWF contaminants to 

Biscayne NP (by decreasing these contaminants and the connectivity between the IWF facility 

and Bay waters), should be in place. 

Although the DEIS generally acknowledges that there is a range of potential sea level rise of 1 

to 4 feet by the end of this century (the U.S. National Climate Estimate predicted up to 6.6 feet), 

there is no analysis of the impacts of even within this range of sea-level rise on the Turkey Point 

Facility, its infrastructure, IWF, or access roads. The DEIS contains no elevation comparisons 

with the estimated sea-level rise, showing how much of the site land would be lost under the 

estimated sea level rise scenarios. The analysis needs to consider how this land loss would 

affect plant operations. The NRC should analyze whether the plant will be able to operate under 

these various sea level scenarios and, if so, how environmental risks vary with differing 

operational and sea-level scenarios. Sea-level rise assessment should also include 

consideration of the South Miami-Dade Waste Water Treatment Plan, as this facility is proposed 

as the primary source of cooling water for the proposed Units 6 and 7. 

Draft climate change guidance from the Council for Environmental Quality (CEQ) on how to 

consider the effects of greenhouse gas emissions and climate change in the evaluation of 

federal actions, as well as, guidance related to sea level rise and siting infrastructure from 

National Oceanic and Atmospheric Agency (NOAA) are available. Further guidance on this 

subject is provided by USACE Engineering and Construction Bulletin No. 2014-10 "Guidance for 

Incorporating Climate Change Impacts to Inland Hydrology in Civil Works Studies, Designs, and 

Projects"; Regulation No 1100-2-8162 "Incorporating Sea Level Change in Civil Works 

Programs"; and ETL 1100-2-1 Technical Letter 1100-2-1 "Procedures to Evaluate Sea Level 

Change: Impacts, Responses, and Adaptation. " The NPS recommends that NRC review these 

documents and update the DEIS as appropriate to account for climate change/sea level rise. 

The DEIS should include assessment of how climate change and sea-level rise vulnerability 

changes risks associated with the proposed project and its long-term operations both in the 

analysis of alternatives as well as cumulative impacts. In this evaluation, climate change and 

sea-level rise related risks are dismissed as an criterion for risk assessment, with a statement 

Appendix E NUREG–2176 E-136 October 2016
(page 941) that equates the risk of all alternatives: "The inland alternative sites could 

experience fewer impacts from sea-level rise, but may also experience greater impacts from 

other climate change indicators, such as rising temperature." 

Because the NPS is required to manage parks for "future generations," we recommend that a 

revised DEIS provide more detail as to how radioactive waste would be stored before and after 

the forty-year license expire. Storing hazardous waste adjacent to Biscayne NP indefinitely 

poses great concern, especially because the region will face increased storm events and 

possibly more intense resulting from climate change and sea-level rise and it is unclear whether 

the storage facilities are capable of withstanding increased storm events resulting from climate 

change and sea-level rise. 

The NPS acknowledges that a storm related analysis may be contained in the NRC's Safety 

Report and will not receive a public review. To increase transparency with the public, this 

information should be clearly articulated in revisions to the DEIS. We recognize the NRC may 

be constrained by their regulations and guidance to include applicable environmental 

information in their DEIS. (0622-1-10 [Austin, Stan])

Comment: Climate Change and Sea-Level Rise[.] The NPS is concerned that the DEIS does 

not include a sufficient analysis of how sea-level rise, hurricanes and storms, and climate 

change may impact the proposed project and NPS resources affected by these changing 

conditions. As an example, the DEIS does not address how sea-level rise may impact plant 

operations or the availability of cooling water sourced from the South Miami-Dade Wastewater 

facility and a greater reliance on the RCWs. There is recent draft climate change guidance from 

the Council on Environmental Quality on how to consider the effects of greenhouse gas 

emissions and climate change in the evaluation of federal actions, as well as guidance related 

to sea level rise and siting infrastructure from National Oceanic and Atmospheric Administration. 

The NPS recommends that NRC review these or other related guidance documents and update 

the DEIS as appropriate to account for climate change/sea level rise. (0623-5 [Austin, Stan])

Comment: The NPS asserts that the DEIS impact analysis associated with construction and 

operation of proposed Units 6 and 7 does not sufficiently address issues related to the 

environmental impacts of the proposed action on resources managed by the NPS. Based on our 

review of the DEIS, we have strong concerns that impact analysis described in the DEIS does 

not: 1) sufficiently utilize the best science/data/information (e.g., current salinity data or sea-level 

rise projections for modeling) to analyze the environmental effects of the proposed action on the 

affected environment, including Biscayne and Everglades NPs[.] (0623-7 [Austin, Stan])

Comment: Green spaces and parks must be protected at all costs. It is now known by 

scientists that our country will be directly impacted from global warming due to arctic meltings. 

The Antarctic which scientist thought would be the glacier that would be the least impacted is 

melting at an accelerated rate both from the top and bottom (warm waters). The West side of 

the antarctic, ie the Amundson Sea, Larsen Band the Thwaites Ice Shelves will be gone in only 

a few years. The disappearance of the Amundson ice shelves will increase sea level by 15 feet! 

Miami and coastal communities need to act quickly to prevent and correct shoreline erosion. 

Our greenspaces, parks, green roofes, vertical/hanging gardens are key in prevent and 

reducing flooding. Dense communities have 55% runoff where green space communities only 

produce 10% runoff. (0633-2 [Cornely, Tina])

Comment: Not enough effort has been made to determine the risk from sea level rise. These 

two new reactors will be built in an area that could be under water in the future. Even if these 

Appendix E October 2016 E-137 NUREG–2176
reactors are being decommissioned at this time how easy will this be if sea level has risen in the 

surrounding area? It could also impact these reactors during their life time. The estimates of sea 

level rise continue to be debated. The numbers you are using could be low estimates. What if 

your estimates are incorrect? I recommend that you look at additional sources for sea level rise 

estimates. (0641-12 [Martin, Drew])

Comment: Climate change could increase salt water intrusion even further increasing this 

stress level. Why add on two new reactors to increase the competition for fresh water? (0641-3

[Martin, Drew])

Comment: Lastly, the current proposed plan has not accounted for the anticipated sea level 

rise in our coastal region. NOAA recommends that power plants account for a 3 to 6.6 feet sea 

level rise. The proposed FPL plan only accounts for a 1 foot rise. In a area where we are 

already experiencing problems with sea level rise, this type of irresponsible planning is 

unacceptable. (0642-5 [Rawlins, Steve])

Comment: We surmise that a tsunami isnt necessary to poison the Atlantic; sea level rise 

alone will do it, assisting the Corexit and BP oil polluted Gulf Stream. The low-lying wetlands 

surrounding Turkey Point contain some of the lowest elevations in South Florida. Even a half 

foot of sea level rise will be enough to inundate the 5,000 acres of canals used to cool the two 

reactors currently operating at this location: They are filled with hot and extremely salty water as 

well as chemicals. (0673-4 [Dwyer, John P.])

Comment: According to Professor Wanless, it's already too late. The oceans have already 

absorbed the critical amount of heat and are undermining the ice at the poles faster than 

anyone predicted. He says 75 years at best before the area south of Tampa/ Stewart is 

underwater--and notes that it will include Turkey Point's reactors and cooling pools containing 

45 years worth of uranium rods. Miami will be Fukushima for the Atlantic. (0673-8 [Dwyer, John 

P.])

Comment: Consider, too, that Biscayne Bay is at risk for sea-level rise. The low-lying wetlands 

that surround Turkey Point contain some of the lowest elevations in South Florida. Even a halffoot of sea level rise will be enough to inundate the 5,000 acres of canals used to cool the two 

reactors currently operating at this location. They are filled with hot and extremely salty water as 

well as chemicals used to kill a recent algae outbreak in the canals. With scientists measuring 

ever-increasing sea-level rise from the melting of our planet's remaining ice ill addition to 

thermal expansion due to increased temperatures, six inches of sea level rise are a certainty. 

New nuclear reactors in this location will be sitting on islands in Biscayne Bay quite possibly in 

the not so distant future. (0674-4 [Dwyer, Karen])

Comment: The original decision to build nuclear reactors at Turkey Point, on a hurricane-swept 

coastline vulnerable to storm surge, was made a half a century before we understood climate 

change and sea-level rise. FPLs new reactors would operate until 2080, during which, the 

National Oceanic and Atmospheric Administration (NOAA) recommends that power plants 

account for three feet to 6.6 feet of sea-level rise. FPLs application accounts for only one foot of 

sea-level rise for that period, clearly unrealistic given the five inches of sea-level rise measured 

locally in the past five years. Even one foot of sea-level rise will inundate the area surrounding 

Turkey Point and turn the power plant into a remote island. A difference of two feet of sea-level 

rise will dramatically affect the height of future storm surges. FPLs assertion that new reactors 

will be safe from a storm surge because they are 26-feet above sea level, overlooks the facts 

that FPLs sea level standard is 27 years old; and the project does not properly account for 

Appendix E NUREG–2176 E-138 October 2016
realistic storm surge projections. FPL ignores these facts to double down on a dangerous 

position based on yesterdays science. (0675-6 [Rodriguez, Jose Javier])

Comment: Please remember that as global warming continues, the water level in the bay will 

rise. We do not want a nuclear power plant surrounded by water. (0688-1 [Albers, Harold])

Comment: The risk in doing this project should be considered to be severely prohibitive, 

especially with Larsen-B ice shelf degradation continuing. (0691-1 [Drevicky, John])

Comment: Even if our governor is "not a scientist" and doesn't want Floridians to discuss 

climate change, I hope that the U.S. Nuclear Regulatory Commission and Army Corps of 

Engineers include scientists and people who are smart enough to know that we'll need to deal 

with rising sea levels if even we don't talk about them. (0693-1 [Dorn, Kathryn])

Comment: When the sea rises it would be inundated, that would be crazy wouldn't it? Do not 

risk the consequences Ms.'s Bladley and Megan Clouser. (0695-2 [Nappe, Judith])

Comment: I would like to add these PowerPoint slides to the public record for your review of 

the Turkey Point EIS. They are closeups of the Turkey Point showing .5-6 feet of sea level rise 

and were prepared by Dr. Peter Harlem of Florida Atlantic University. As you will see, sea level 

rise will have an immediate and ongoing effect on the plant site and it's surrounding 

environment [Commenter attached figure showing a map of the effects of 6 ft sea level rise].

(0702-1 [Kipnis, Dan])

Comment: Turkey Point EIS comments and slide #2 [Commenter attached figure showing a 

map of the effects of 6 ft sea level rise]. (0703-1 [Kipnis, Dan])

Comment: The low-lying wetlands which surround Turkey Point contain some of the lowest 

elevations in South Florida: Even a half foot of sea level rise will be enough to inundate the 

5,000 acres of canals used to cool the two reactors currently operating at this location. They are 

filled with hot and extremely salty water -as well as chemicals used to kill a recent algae 

outbreak in the canals. With scientists measuring ever-increasing sea level rise from the melting 

of our planet's remaining ice in addition to thermal expansion due to increased temperatures, 

those 6 inches of sea level rise are a virtual certainty. (0712-3 [Almer, Anessa])

Comment: NRC's Draft EIS is Flawed Because it Fails to Adequately Address the 

Impacts of Climate Change, Specifically, Sea Level Rise on the Turkey Point Site:

According to the NRC's Environmental Impact Statement for Combined Licenses (COLs) for 

Turkey Point Nuclear Plant Units 6 and 7, Draft Report for Comment (NUREG-2176) (Here in 

after DEIS): The impact of sea level rise on the safe operation of the proposed units is 

considered in the NRC's safety review and is not within the scope of environmental review. 

Results of the safety review can be found in the Safety Evaluation Report (SER). However, sea 

level rise will be considered as one of the contributing factors to the cumulative impact of the 

proposed action and other past, present, and reasonably foreseeable actions in Chapter 7 of the 

EIS. (I won't bother with citing the footnote in NRC's Draft EIS since it does function!) Sadly, the 

Huffington Post did a better job framing the issue of sea level rise at Turkey point in one graphic 

than the NRC did in nearly 1500 pages. [FIGURE: Turkey Point Nuclear Generating Station] 

(http://www.huffingtonpost.com/2014/05/19/maps-rising-seas-storms-threaten-flood-coasta1-

nuclear-power-plantsn5233306.html) Yet NRC's DEIS seemingly fails to address the fact that 

the Turkey Point site will be an island during a storm surge by the time the proposed reactors 

would be operation should FP&L ever commit to building them. (0716-7 [Riccio, Jim])

Appendix E October 2016 E-139 NUREG–2176
Comment: Why build here when the Army Corp of Engineers estimates that by 2030 (less than 

15 years from now) the projected sea level rise for this area is 3-7 inches. Already the existing 

plant is drawing so much water that it creates problems for the counties future water supply. 

What are the negative impacts of your allowed increase to 104 degrees and why is the lower 

level kept in place for all other nuclear power plants? (0718-1 [Buechler, Jerry])

Comment: Three, the costs that are related to safety. The information that I have is that NOAA 

has recommended power plants account for between 3 and 6 feet of sea level rise. And if this 

application is granted, basically the application is seeking approval for two new units on a low 

peninsula into a shallow bay that's already highly vulnerable to storm surge. That is a -- that is 

going to present costs that are hard to calculate. (0721-1-6 [Rodriguez, Jose Javier])

Comment: Now what happens if you get both entrainment and sea level rise taking out the 

reclaimed water supply? Where do you get your water from then? That's not in the 

Environmental Impact Statement, and we know darn well it's going to come out of the L-31-E, 

same as they're drawing right now for Turkey Point 3 and 4, and that's going to conflict 

massively with the Southeast Everglades restoration of Coastal Everglades. (0721-2-10

[Stoddard, Philip K.])

Comment: The third issue is an underestimation of sea level rise by a failure to consider how 

measured local rates of sea level rise differ from projected global rates and the effect of that 

uncertainty and viability of this project. 

So Appendix I of the Impact Statement addresses climate change and sea level rise. And here's 

a quote: "Sea level is projected to rise 1 to 4 feet globally by the Year 2100." We heard where 

that came from earlier. So several reports list figures similar to this. But scientists at RSMAS, 

Rosenstiel School of Marine and Atmospheric Science at University of Miami on Virginia Key, 

have actually measured sea level rise rates in the Miami region, and it indicates higher rates of 

sea level rise are already happening locally. In the past five years the average rate has been .97 

inches. That's almost an inch a year. So existing rates would yield a range of about 21 inches to 

about 78 inches, that's almost 2 feet to about 6-1/2 feet over the life of the plant. Now, that's just 

the current rate that we're seeing right now. And every scientific model indicates an exponential 

increase as we start seeing more of the ice melting at the poles. So the Draft Environmental 

Impact Statement likely underestimates sea level rise by using consensus global measures that 

don't match existing local rates of rise. (0721-2-5 [Stoddard, Philip K.])

Comment: There's a fourth issue, and that's failure to consider the loss of wastewater as a 

cooling source because of reduced residential demand from conservation measures resulting 

from sea level rise induced salt water intrusion on the fresh water supply. We know that one foot 

of sea level rise is going to render our salt water exclusion gates on our canals ineffective. The 

salt water intrusion is going to come in, it's going to become uncontrollable and we're going to 

lose our fresh water supply. Well, you can bet that we're going to put in stringent conservation 

measures at that point because we're going to be doing reverse osmosis and paying through 

the nose for our water. So there will be a lot less water going into the waste supply. And so the 

Draft Environmental Impact Statement is incomplete in failing to consider the reduction in 

wastewater stream from reduced residential demand and force water conservation. (0721-2-6

[Stoddard, Philip K.])

Comment: The fifth omission here is a failure to consider loss of wastewater as a cooling water 

source because of regional depopulation. Both the Miami-Dade Water Sewer Department and 

the Draft Environmental Impact Statement know that the people in Southeast Dade County are 

Appendix E NUREG–2176 E-140 October 2016
likely to leave as the sea level comes up. If you're not there, you're not using water. The water 

treatment plant, even if it remains operational, is going to get less water in, less water out, less 

water to Turkey Point. (0721-2-7 [Stoddard, Philip K.])

Comment: So, there's a failure to consider loss of wastewater as a cooling source because 

sea level rise impairs site access. (0721-2-8 [Stoddard, Philip K.])

Comment: They're going to have to build causeways. They can build a causeway. It will be an 

island. Awkward but possible. (0721-2-9 [Stoddard, Philip K.])

Comment: And, furthermore, South Florida not only being porous and porous area for water, it 

is also an incredibly unstable area for weather in the past. It's going to get even more unstable 

because of climate change, which is happening here. (0721-29-2 [Yovel, Ephrat])

Comment: The studies that we have all relied on for the past six years as a region bring 

together a lot of science, a lot of reports, and an understanding that we, as a region, have come 

to use as our baseline of knowledge. Unfortunately it does not appear that those who are 

studying this very critical area, are appreciating and respecting the baseline of scientific data 

that we have all come to realize we must incorporate in to our responsibilities. Especially the 

elected officials who must be stewards for the future of our communities to assure that our land 

use and our building codes and our decision making in every realm of creating resilient 

communities incorporates what science tells us, which is, we are looking at anywhere from two 

to six feet of sea level rise by 2100. And when FPL comes in and says they will only be relying 

on one foot, that is inadequate to the needs that we all understand have to be incorporated.

(0721-3-1 [Lerner, Cindy])

Comment: The Draft Statement fails to address a failure of the plan to adequately plan for the 

sea level rise that's certain to come. The plan must be compliant with the NOAA report of 2012, 

the global sea level rise scenario for national climate assessment. In that review the report 

indicates over 8 million people live in areas at risk of coastal flooding, and many of the nation's 

assets related to military readiness, energy, commerce and ecosystems, are already located at 

or near the ocean. We have all of those. The report establishes a high confidence greater than 

nine in ten chances that the global mean sea level will rise at least eight inches, no more than 

six feet by 2100. The report indicates the highest scenario should be considered in situations 

where there's little tolerance for risk. Two new nuclear power plants, there should be no 

tolerance for risk. The new infrastructure has a long anticipated life cycle with this power plant 

and the failure to include the planning for the --up to six foot sea level rise is a fatal flaw.

(0721-3-3 [Lerner, Cindy])

Comment: Certainly we have different circumstances. We have sea level rise, and that in the 

end is what this really is all about. (0721-30-6 [Ullman, John])

Comment: The analysis of sea level rise by the NRC and by FP&L is woefully inadequate.

(0721-30-8 [Ullman, John])

Comment: And I would suggest to you that the President's mandate is that all Federal 

agencies account for sea level rise. And this agency has failed to do so, and FP&L has failed to 

do so. And the President wants us to do that. (0721-30-9 [Ullman, John])

Comment: [These issues are dwarfed by] sea level rise and climate change impacts, and the 

list goes on as we've heard tonight. (0721-32-6 [Schlackman, Mara])

Appendix E October 2016 E-141 NUREG–2176
Comment: It does not realistically account for sea level rise, which is a safety concern as well.

(0721-4-3 [Regalado, Tomas])

Comment: FPL's application only accounts for one foot of sea level rise despite the fact that 

NOAA recommended to account for three to five feet of sea level rise. And because Turkey 

Point is located directly on the shoreline of Biscayne National Park it's already vulnerable to sea 

level rise, storm surge, flooding, hurricanes, et cetera, as some other people have said before. 

So we don't feel like this plant is safe. (0722-14-3 [Kaul, Devika])

Comment: And the concern I want to raise today is one that probably won't occur in my lifetime 

so it's for the people of the future that I would like to talk. It seems that the estimates for sea rise 

have been continually been being raised. We have recently learned that the west end arctic ice 

sheet is inevitably going to slide into the sea. If that should ever happen with the east end arctic 

ice sheet, all bets are off as to how high the ocean is going to go. And that is my concern. 

What I would suggest here is that a careful scientific analysis be made to determine at which 

point it would be prudent to say we now must close the plant if it is built. And if that point comes 

then there must be a plan already in place for the closing of the plant and the removal of all 

radioactive material from the coast to some safe place. And that safe place should be 

designated before the plant is built, not afterwards, and the method of removal should be 

designated before the plant is built and not afterwards. 

Those are my concerns. I'm willing to assume, as we lawyers say, but not admit all of the good 

stuff. But the scientific estimates of the rise of the sea have all been too conservative and I think 

that should be taken into very careful consideration before this plant is built. (0722-16-1 [Segor, 

Joseph C.])

Comment: After listening to everything about the ecological impacts, which I'm concerned 

about, but I feel that there is no real evidence of sea water rise. I've heard nobody say last year 

it rose all that much. All they say is within 30 years it rose. So if we stick with clean, nuclear 

power like other people have said, we will not impact the carbon footprint. And as far as it -- if it 

does rise, where are we all going to go? (0722-19-1 [Hudak, Jill])

Comment: But I sat on the Miami Dade County Climate Change Task Force and I work with 

the City of Miami Beach Sea Level Rise Task Force and unfortunately the Mayor of Homestead 

probably won't like to hear this but the slides I'm talking about are sea level rise and it's 

environmentally important to this project. All of South Florida is going to change in the very near 

future; it's doing it right now. 

I found it very interesting that the Army Corps of Engineers jurisdiction in the salt water is at the 

highest annual high tide. The Army Corps of Engineers under that scenario probably has 

jurisdiction over all of Miami Beach because we flood with saltwater at the highest tide of the 

year. That's what's going to happen in South Florida. 

My objection to the siting of this plant and to the EIS is that it doesn't take the new and updated 

sea level rise predictions into consideration. It is using an older version of it, in the beginning it 

used no version of it at all, at least the NRC said it was not an issue. It's becoming an issue. 

One foot of sea level rise on the southeast coast will put most of Homestead and South Florida 

and Florida City and Cutler Bay and Turkey Point underwater. Now that's at high tide -- that's 

not at high tide, that's just under the water all the time at mean tide, all right? 

Appendix E NUREG–2176 E-142 October 2016
At high tide you can add, if it's a three-foot tide or a four-foot tide, to that. My slides show this. 

It's very disturbing to see the amount of building going on down here and then a nuclear power 

plant knowing that this is going to happen. This is not "if," this is "when." And the latest 

observations by NOAA and even the Army Corps of Engineer talks about this, has a one-foot 

sea level rise sometime in the next 30 to 40 years. That means the plant would be finished and 

go into operation and it would be an island. (0722-2-1 [Kipnis, Dan])

Comment: Now I guess Miami Dade County would have to come in and raise the roads to be 

above high tide, so that's a three or four foot rise in the roads so the workers can get to work. Or 

additionally, as it's going up, we probably would have to raise roads just to get the equipment in 

there and the men that are building the plant there. (0722-2-2 [Kipnis, Dan])

Comment: Why build it when we know that environmentally it isn't going to help us there 

because we're going to run into problems that are not shown in that EIS because of sea level 

rise. 

Two feet -- well, Miami Beach goes two feet also, so I have to tell you that. Doral's going three 

feet. We have about 67 percent of the land surface in Miami Dade County inside the UDB left so 

we're looking at a customer base that's really going to shrink because people are not going to 

live in the water. They won't be able to. (0722-2-3 [Kipnis, Dan])

Comment: In addition, as Captain Dan Kipnis noted there is only one foot of sea level rising 

accounted for in this plan which is better than no sea level rise. But it is still not adequate to 

meet what NOAA has recommended which is to consider three to four feet of sea level rise to 

be more realistic to models and more conservative in planning. You know, this is really a 

question of how Miami wants to move into the future and whether or not we want to face this 

issue head-on and really prepare and plan for it or whether we want to be caught off-guard like 

some other places in the world have been when flooding and storm surge and storms in 

themselves have impacted critical infrastructure. And we don't want that to happen here in this 

really fragile and important area. And to affect a nuclear power plant that we all rely on as well. 

So to be more cautious here is really the best way to go, in my opinion. (0722-7-6 [Silverstein, 

Rachel])

Comment: What I cannot understand, and I'm a simple fellow, is that if the president of the 

most powerful, respected nation in the world and our Federal government acknowledges and 

accepts the climate change is playing a role in endangering our water and our air, how can FPL 

deny an increasing footprint and power output will not stress an endangered environment? They 

have already answered higher acceptable water temperature levels. They are already using 

water from our canals that were set aside for restoration. They were already using waters from 

our aquifers on an emergency basis. (0722-8-1 [Gonzalez, Javier])

Comment: As I mentioned earlier, I'm a simple fellow with no degree in law or science and I 

know that a lot of fancy language is being used but I do know that someone at the present is 

concerned about -- and said that climate change will have no bigger impact than in South 

Florida. And maybe, just maybe us simple and smart folk should revisit FPL's plan. And maybe 

we can conduct a supplemental EIS to review the water quality and climate change. (0722-8-2

[Gonzalez, Javier])

Comment: And one of our biggest concerns and one of our residents' biggest concerns is 

climate change. It is the future. I won't get into the specifics and all the numbers but I know that 

[for] every young kid out there, this is a topic. And if this is a concern that we should be worried 

Appendix E October 2016 E-143 NUREG–2176
about, truly FPL, you might want to take a look at this. This might not be the best idea. (0722-8-3

[Gonzalez, Javier])

Comment: I have two articles that I'd like to leave with you. I won't go into them too much other 

than to say one is in the..."Miami Herald," I believe it was, or the "Sun Sentinel" by Brower. And 

her comments were "numerous studies show that the effects of carbon pollution on the 

environment, the United Nations Interglobal Panel on Climate Energy and Climate Change 

shows that it is extremely likely that human activities and greater greenhouse gases are 

responsible for more than half of the observed rise in global temperatures and that the global 

sea level will rise another 26 to 98 centimeters by 2100." (0722-9-9 [Riley, Bill])

Comment: And even though I understand the Nuclear Regulatory Commission is not 

considering sea level rise as an important criteria in their Environmental Impact Statement, it's 

coming. It could be severe. We could be talking about a foot, worst case within ten, fifteen 

years. And we're talking about building nuclear power units on an island, basically, a future 

island. And I was here for Hurricane Andrew, as many of you were. I'm concerned about that.

(0723-5-5 [Teas, Jim])

Comment: The commenter provided a handout entitled "Turkey Point Immediate effect of SLR" 

prepared by Peter Harlem of Florida International University. The series of slides show 

extrapolated inundation maps for 0.5 ft to 6.0 ft of sea level rise at the Turkey Point 

plant. (0725-1 [Kipnis, Dan])

Comment: If expanded, Turkey Point would become one of the largest nuclear power facilities 

in the country, located in an area that is ground zero for sea level rise. (0728-1 [Gregory, Gregory 

B.])

Response: Appendix I of the EIS documents the review team’s consideration of the potential 

changes in impacts that may occur as a result of the changes in the environment resulting from 

global climate change including sea-level rise. The changes that were considered include 

potential changes in temperature, rainfall and the occurrence of severe weather events. As 

discussed in Appendix I, the review team considered the assessment presented in the most 

recent National Assessment. The 2014 National Assessment was conducted by a team of more 

than 300 experts guided by a 60-member Federal Advisory Committee and extensively 

reviewed by the public and experts, including Federal agencies and a panel of the National 

Academy of Sciences. The review team has also considered more recent estimates of sea level 

rise. The review team has added mention of research into a localize sea-level rise in South 

Florida associated with changes in regional ocean currents. 

The review team is aware that the sea-level rise of 1–4 ft by 2100 is not bounding. It is not 

implausible that sea level rise significantly in excess of 4 ft could occur by 2100. Such extreme 

sea-level rises would inundate much of South Florida making it uninhabitable. However, NEPA 

requires consideration of likely future scenarios not extreme future scenarios. However, the 

gradual increase in sea level and NRC's safety process protects the public health and safety. 

Appendix I has been updated based on these comments. 

Comment: I don't want what precious water we have used on this project. (0008-15 [Finver, 

Jody])

Comment: We need the water for drinking, not cooling. (0060-3 [Beckman, Yvonne and Douglas])

Appendix E NUREG–2176 E-144 October 2016
Comment: The new reactors will require 90 million gallons a day of Miami-Dade's treated 

wastewater for cooling. (0078-5 [Wilansky, Laura Sue])

Comment: FPL's expansion would consume additional large quantities of fresh water which is 

already in short supply. (0079-1 [Cathey, Turner])

Comment: These resources are vital for our well being and health. Please DON'T let FPLS to 

endanger our clean source of water. (0088-4 [Lange, Alexandra])

Comment: I recommend that you disapprove any further processing of their Turkey Point 

Nuclear Power plant expansion proposal for the reasons summarized below 3) Nuclear plants 

consume vast amounts of water to keep reactors cool. FPL claims the new primary cooling 

system will use reclaimed wastewater, but that water is sorely needed for other uses. The 

project will increase usage of all Miami-Dade's available water by ten times, from one to 10 

percent of supply, a massive impact for which there is no mitigation, in view of the projected 

skyrocketing forecast of water demand and declining water supply in the region. The project's 

assessment of its claim on fresh and salt water in the region is inadequate, failing to assess the 

loss it would cause to water needed for a rapidly growing population and severely threatened 

habitat in the coastal Everglades, Biscayne National Park, and South Dade County generally.

(0094-3 [Fairchild, David])

Comment: Operating two new reactors at Turkey Point could also have huge impacts on the 

quantity and quality of precious freshwater resources. (0102-5 [Commenters, Multiple])

Comment: As you know operating two new reactors at Turkey Point could also have huge 

impacts on the quantity and quality of the area's limited freshwater supplies. (0103-5

[Commenters, Multiple])

Comment: Comment 7. The DEIS is incomplete in failing to consider a third source of 

cooling water if the primary and secondary sources are compromised by SLR, or to 

consider the consequences of that outcome for residents and businesses of Miami-Dade 

County - The DEIS does not consider the possibility of losing both sources of cooling water, or 

the consequences. As detailed above, the treated wastewater eventually will be lost because of 

water conservation or regional depopulation, both caused by sea level rise. While the timeframe 

of SLR is uncertain at this date, the first loss scenario is almost certain to happen before the 

TPN 6&7 would be ready for decommissioning, and the second one could occur within that time 

frame as well. The proposed backup source of cooling water, the radial collector wells (RCWs) 

could become compromised by entrainment of hypersaline water from under the cooling canals 

(IWF). So what happens if the reactors at TPN 6&7 lose both sources of cooling water? The 

plant would be forced to compete directly with residential and businesses for the remaining 

sources of fresh water. Ironically the DEIS notes a projected increase in residential demand for 

freshwater over the same time period. The final EIS must consider the possibility and the 

consequence of losing both proposed cooling water sources. (0106-10 [Stoddard, Philip K.])

Comment: Most of the problems and uncertainties identified concern cooling water operations.

(0106-2 [Stoddard, Philip K.])

Comment: Comment 5. The DEIS is incomplete in failing to consider reduction of the 

wastewater stream from reduced number of residences and businesses producing 

wastewater - The Miami-Dade Water Sewer Dept. has noted that the residential service area of 

the Southern Waste Water Treatment Facility is low in elevation, and will likely depopulate in the 

Appendix E October 2016 E-145 NUREG–2176
face of SLR. The DEIS likewise notes: "Climate change could lead to changes in the distribution 

of land use in Miami-Dade County and sea-level rise could lead to the loss of some inhabitable 

land in the county." [DEIS I.3.1.1 Land-Use Summary, p. I-4.] Reduction in the number of 

customers in the southeast coastal regions of Miami-Dade County will reduce the amount of 

wastewater sent to the Southern Waste Water Treatment Facility, and thus the amount of 

treated wastewater water available for cooling TPN 6&7. The final EIS must consider 

eventual loss of wastewater as a cooling water source because of regional depopulation 

due to SLR. (0106-8 [Stoddard, Philip K.])

Comment: The region surrounding the Turkey Point nuclear plant is an extremely complex and 

sensitive hydrological environment that is only becoming more complicated as human 

populations increase and the effects of global climate change emerge, including sea level rise. 

The history of the Everglades and the current costly restoration projects illustrate the long-term 

shortsightedness that has scarred Florida's waterways. When comparing types of energy 

generation, nuclear power has higher rates of both water withdrawal and consumption than 

traditional coal and natural gas and far more than renewable energy sources, such as wind and 

solar. Additionally, energy efficiency has the added benefit of substantially reducing energy 

needs, while simultaneously reducing water consumption. As we see FPL's projected figures for 

water demand increase for thermoelectric power generation, the NRC needs to fully evaluate 

current information about less water intensive energy alternatives, efficiency and renewables, 

including using a combination of these energy options. The NRC also needs to better analyze 

the impacts such a drastic increase in water demand from the power sector could cause to this 

area. (0112-5 [Barczak, Sara])

Comment: The analysis of the impacts of the use and disposal of reclaimed wastewater is 

inadequate, particularly in terms of the characterization of constituents, the impacts of the 

construction of pipelines, and the impacts of wastewater reuse on CERP activities and goals.

(0113-1-5 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, 

Rachel])

Comment: The potential adverse impacts from use and reservation of reclaimed wastewater 

from the South District Water Treatment Plant to CERP and specifically, to BBCW, are not 

adequately discussed in the DEIS. BBCW, intended to restore freshwater flows in and around 

Biscayne Bay's littoral zone, is premised on the conveyance of freshwater that may include 

treated wastewater from Miami Dade County. The DEIS does not discuss the potential negative 

impacts to Everglades restoration efforts that may arise from the use of up to 90 MGD of 

reclaimed water to cool Units 6 & 7, water that may otherwise be used to supply freshwater to 

the BBCW project. (0113-2-18 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, 

Matthew] [Silverstein, Rachel])

Comment: The DEIS fails to analyze the potential for the operations of radial collector wells to 

negatively impact the implementation of CERP, specifically the Biscayne Bay Coastal Wetlands 

(BBCW) project. BBCW is intended to restore freshwater flow to Biscayne Bay and Biscayne 

National Park, recharging sources of fresh groundwater and addressing high salinity in 

nearshore environments. Using radial wells to collect cooling water for Units 6 & 7 could 

negatively impact CERP goals of restoring freshwater flow to Biscayne Bay. Radial wells 

located at a depth of 40 feet may withdraw freshwater from the aquifer, potentially offsetting 

attempts to deliver more freshwater to Biscayne Bay's littoral zone. [Footnote 29: Florida 

Department of Environmental Protection, Determination of Completeness, FPL Turkey Point 

Units 6 & 7, August 10, 2009, 2.] (0113-2-6 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] 

[Schwartz, Matthew] [Silverstein, Rachel])

Appendix E NUREG–2176 E-146 October 2016
Comment: The plant is already endangering the water supply[.] (0114-2 [Cunningham, Sue])

Comment: More reactors will need more cooling water....and that is not available. (0114-4

[Cunningham, Sue])

Comment: [The new reactors] is not a wise use of our fresh water, which will become a limited 

resource over the next several decades. (0126-3 [Pontier, Christine Hughes])

Comment: This expansion is said to enhance the economic value of the community, but it is 

not the economy I am worried about. I am worried about our water, it's amount, it's quality, and 

it's endangerment (0127-2 [Cusidor, Teresa])

Comment: I do not want FPL to have 10% of waters usage. (0127-4 [Cusidor, Teresa])

Comment: Not only does it jeopardize drinking water, it also makes the facility more vulnerable 

to rising sea levels and storm surge. (0133-2 [Corral, Oscar])

Comment: I am writing today from my home to oppose the approval of FPL's two nuclear 

power at Turkey Point for the following reasons....2. The present plant and the new proposed 

plant use millions of gallons of fresh water and water from Biscayne Bay, ignoring the damage 

that will occur to the Everglades, Biscayne National Park and South Dade well fields. (0136-2

[Levy, Morgan I.])

Comment: The draft EIS fails to account for the adverse and potentially deadly competition 

between a thirsty nuclear power plant and almost 4 million people, in one of the most highly 

populate areas of Florida. And water demand in southeast Florida, is projected to increase by 

more than 50% by 2060, relative to 2005, based on combined changes in population, 

socioeconomic conditions and climate. (0145-9 [Lerner, Cindy])

Comment: Additionally, the operation of the existing reactors interferes with the National 

objectives of Everglades Restoration and further development of this site should incorporate the 

Federal projects intended to flood the land where the Turkey Point plants are located in order to 

restore Biscayne National Park's shoreline to estuary conditions. (0172-3 [Cava, Daniella Levine])

Comment: Furthermore, we: are concerned that the operation of two new nuclear reactors 

could have significant impacts on the quantity and quality of our limited freshwater resources. 

Maintaining South Florida's water supply is critical to ensuring the future of our environment and 

our communities. (0210-3 [Sharp, Andrea Heuson])

Comment: Radial collector wells. The Department is concerned that the operation of the 

radial collector wells (CWs), installed to provide a backup source of cooling water for Units 6 

and 7,) has the potential to affect the salinity of Biscayne Bay (Bay). The lateral pipes 

associated with the CWs will be located 25 to 40 feet beneath the bottom of the Bay, but will 

draw water from the Bay itself. During operation of the CWs, the water withdrawn from the Bay 

will be replaced mostly by ocean water containing a typical ocean salinity of about 35 practical 

salinity units (psu). Consequently, operation of the CWs could negatively affect salinity 

(mesohaline; 5-18 psu) in this area of the Bay, and may undermine efforts of the 

Comprehensive Everglades Restoration Plan (CERP) in the region. Results from U.S. 

Geological Survey (USGS) salinity modeling of the effects of CWs, as provided in the DEIS, 

indicate that under the most conservative scenario (continuous pumping) the maximum salinity 

increase was .3 psu above the base condition in the immediate vicinity of the lateral pipes of the 

Appendix E October 2016 E-147 NUREG–2176
CWs. However, most of the time salinity was within psu of the baseline condition. If the 

modelling is correct, the magnitude of change in salinity is not likely be ecologically significant 

(i.e., the flora and fauna probably will not be affected). Salinity in the Bay is frequently falls 

outside of the Restoration Coordination and Verification (RECOVER) performance measures 

targets established by CERP. Therefore, we are concerned that any further increases in the 

Bay's salinity may have adverse effects to the flora and fauna in area including the American 

crocodile. We recommend that FPL develop a monitoring plan to ensure that salinity in the Bay 

is consistent with the predicted modeling and develop an adaptive management plan to address 

what steps will be taken if salinity level exceed the 1 psu. We are also concerned that the 

operation of the CWs may exacerbate the hypersaline plume of ground water underneath the 

existing cooling canal network. The USGS modeling indicates that some hypersaline water 

beneath the cooling canals will be drawn into the CWs during extended periods of pumping. The 

increased gradient during CW pumping will likely increase the flow velocity of hypersaline water 

eastward under the Bay and may change the area affected by the hypersaline plume. It is 

unclear how this might affect salinity in the Bay; however, as previously indicated increased 

salinity in the Bay would have undesirable ecological effects to the Bay's ecosystem. Finally, 

operation of the CWs has the potential to adversely affect the local biota within the Bay due to 

the increase in downward vertical flow of water in the Bay's water column. The calculated 

average velocity of 0.0003 ft/min or about 0.4 ft/day is probably insignificant. However, a worst 

case modelling scenario presented in the DEIS, using an ultra-conservative approach, resulted 

in a vertical velocity of 0.43 ft/minute. This velocity could entrap small, weak-swimming 

organisms. Based on the design of the CW system, impingement and entrapment of organisms 

due to the operation of the CWs is unlikely. However, it could occur in a limited manner if the 

limestone above the CW laterals fractures and increase downwelling. Animals susceptible to 

impingement and entrapment include the eggs and larval forms of several species of fish and 

invertebrates. Also, a downward vertical flow would also likely replace high-nutrient pore water 

with low nutrient Bay water, and result in adverse effects to seagrasses. Other species 

potentially influenced by changes in sediment pore-water characteristics include polychaetes, 

amphipods, mollusks, and other benthic macro-invertebrates present in near shore locations 

above the CW laterals. Based on the potential adverse effects of the operation of the CWs, we 

recommend that a rigorous water monitoring program be employed in the Bay in association 

with the project. The Department supports the monitoring described in Section B of the Florida 

Department of Environmental Protection's Certificate of Conditions issued in May 2014. (0227-9

[Stanley, Joyce])

Comment: Operating two new reactors at Turkey Point would also have huge impacts on the 

quantity and quality of precious freshwater resources. (0228-5 [Yeager, Jerry])

Comment: The operation of two new nuclear reactors at Turkey Point would also likely have 

significant impacts on the quantity and quality of our limited freshwater resources. Maintaining 

our water supply here in South Florida is critical to ensuring the future of our communities. We 

are concerned that withdrawing massive amounts of freshwater needed for the plant's 

operations could increase salinity levels within Biscayne National Park and hasten freshwater 

intrusion into our limited freshwater supplies. Avoiding these impacts will be a far less costly 

option than the cost associated with alternative water supply development. (0254-3 [Dudley, 

Dwight] [Lerner, Cindy] [Regalado, Tomas] [Stoddard, Philip K.])

Comment: Turkey Point's operations are already impacting Biscayne Bay's habitat, water 

quality, and salinity, which are vital for the health and productivity of the bay. The expansion of 

the power plant would only intensify and expand these negative impacts, posing significant 

threats to sensitive ecological areas and critical freshwater supplies. (0258-4 [Field, Fran])

Appendix E NUREG–2176 E-148 October 2016
Comment: 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. (0288-12 [Cleland, Noel] 

[Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] 

[Ullman, Jonathan])

Comment: 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. (0288-3 [Cleland, 

Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] 

[Ullman, Jonathan])

Comment: Moreover, operating two new reactors at Turkey Point could have huge impacts on 

the quantity and quality of precious freshwater resources. The withdrawal of massive amounts 

of water from under Biscayne Bay as back-up cooling water could increase salinity levels within 

the Bay and hasten saltwater intrusion into our limited freshwater supplies. (0299-3 [Salatino, 

Freda])

Comment: [T]hey have enough problems (and use enough water) with the 2 reactors they 

already have. Doubling that will double the problems and water consumption. (0334-3 [Crystal, 

Chris])

Comment: It wasn't that many years ago that we had drought problems. If FP&L needs all the 

water they do for cooling and dealing with algae bloom, what happens when we have a 

shortage of rain (like California) or we have in the past. (0334-4 [Crystal, Chris])

Comment: Power is useless without drinkable water for the consumers. (0352-2 [Tingle, Peggy])

Comment: The new reactors will require 90 million gallons a day of Miami-Dades treated 

wastewater for cooling. (0353-3 [Royce, M.])

Comment: Florida Power and Light is seeking permission to build two new nuclear reactors at 

its existing plant next to Biscayne National Park and other natural areas; the project would be 

highly water-intensive, likely threatening Biscayne Bay and the Biscayne Aquifer. (0356-1

[Shlackman, Jed])

Comment: If there is insufficient treated wastewater for cooling the reactors, the radial wells 

used for back-up cooling would become one of the largest well-fields in the Southeast and could 

lead to further saltwater intrusion into the Biscayne Aquifer, a major problem already impinging 

on South Floridas limited freshwater supply. (0356-12 [Shlackman, Jed])

Comment: The new reactors will require 90 million gallons a day of Miami-Dades treated 

wastewater for cooling. (0356-9 [Shlackman, Jed])

Comment: There is too much water being used to cool the reactors if there isn't enough treated 

wastewater available, which I also don't like. There are already too many interests competing for 

our limited water supply, and I'm not even taking about the ecosystem and wildlife that depend 

on water. (0361-2 [Berndgen, Michelle])

Comment: Wasting 90 million gallons of Miami-Dade's treated wastewater for cooling every 

day is not a good idea. (0363-3 [Peters, Emily])

Appendix E October 2016 E-149 NUREG–2176
Comment: Construction and operations of the proposed nuclear reactors threaten to degrade 

water quality and damage the marine ecosystems of Biscayne National Park. In addition, the 

water usage of the additional units (projected by FPL in 2025 to include a 35% increase for 

public and commercial needs and a 3000% increase for thermoelectric power generation) is a 

threat to our aquifers and public water. (0364-2 [Mahoney, Robert S.])

Comment: The amount of waste water 90 million gallons per day is inadequate for the cooling 

of the nuclear reactors. Although over 300 million gallons of waste water from Miami -Dade 

County Sewage Treatment Plant is pumped into Biscayne Bay on a daily basis, it is obviously 

impossible for that amount of water to be treated adequately for use at Turkey Point. The 

infrastructure simply does not exist. Miami-Dade County has made no progress whatsoever to 

begin the construction of a Sewage Processing Plant that will cleanse the water in a sustainable 

way, so that it would be reusable for Turkey Point or any other use. FPL has proposed building 

their own waste water treatment plant, and all parties need to take a good, hard look at that, as 

well. There remain many unanswered questions regarding the environmental impacts of such a 

plant, i.e. how and where would the resulting waste be disposed of? How many gallons of water 

per day could be cleansed properly for use at Turkey Point? (0365-3 [Fischer, Antoinette])

Comment: The balance of nature becomes ever more precarious as more and more water is 

needed because of unbridled development, and large corporate usage. The water in our aquifer 

will have to be used with great conservatism. (0365-7 [Fischer, Antoinette])

Comment: The two new reactors are a clear and present danger to the water supply. With two 

new reactors, Turkey Point would become one of the largest nuclear facilities in the country. 

They will require 90 million gallons a day of Miami-Dade's treated wastewater for cooling. The 

project would be highly water-intensive, potentially threatening both the Biscayne Bay and the 

Biscayne Aquifer. If there is insufficient treated wastewater for cooling the reactors, the radial 

wells used for back-up cooling would become one of the largest well-fields in the Southeast and 

could lead to further saltwater intrusion into the Biscayne Aquifer, already a major problem 

impinging on South Florida's limited freshwater supply. (0366-9 [Griffith, Ed and Harriet])

Comment: The project would be highly water-intensive, potentially threatening Biscayne Bay 

and the Biscayne Aquifer. (0370-2 [Vayu, Satya])

Comment: The new reactors will require 90 million gallons a day of Miami-Dades treated 

wastewater for cooling. (0370-8 [Vayu, Satya])

Comment: I would like you to not allocate anymore water to the plant. (0373-12 [Lee, Nancy])

Comment: NO WAY is this going to happen. Fresh water is running out all over the country 

because of our wrecklessness. This has become a matter of life and death. DO NOT destroy 

what's left of our fresh water. (0401-1 [Foster, Beverly])

Comment: Operating two new reactors at Turkey Point will also have huge impacts on the 

quantity and quality of precious freshwater resources. (0413-4 [Cobb, Tanya])

Comment: Comment 4: The final Environmental Impact Statement should include an 

analysis of alternatives to the radial collector well backup cooling system that are less 

likely to adversely impact the Biscayne Aquifer. The DEIS acknowledges that "[r]emoving 

relatively large volumes of water from the inland aquifer could lower the water table in the inland 

portion of the aquifer, affecting existing water-supply wells and increasing saltwater intrusion to 

Appendix E NUREG–2176 E-150 October 2016
the Biscayne aquifer." DEIS at 5-13. In addition, it states that "the volume of water that would be 

removed [by the radial collector wells] from the inland aquifer is difficult to predict with certainty 

because it depends on several hydrogeologic features and parameters that are incompletely 

quantified." DEIS at 5-14. According to the DEIS, the highest estimated "volume of groundwater 

that could be removed from the Biscayne aquifer is 4,500 gpm during [radial collector well] 

operation . . . ." DEIS at 5-15. This amounts to about 6.48 million gallons of water per day from 

the Biscayne Aquifer during radial collector wells operation and about 388,800,000 gallons 

annually. During the proposed project's lifetime, Miami will likely face dwindling supplies of 

potable water as well as further difficulties preventing flooding and saltwater intrusion during wet 

and dry seasons respectively. Considering these challenges, 388,800,000 gallons appears to be 

a relatively large withdrawal of water from the Biscayne Aquifer. FPL's most recent filings before 

Florida's Public Service Commission indicate that the new reactors are now planned to enter 

service closer to 2027. Around that time, Miami-Dade County's Water and Sewer Department 

projects that demand for water will be much closer to capacity. See SFWMD Individual Use 

Permit for MDWASD Permit Number 13-00017-W (Exhibits 8A, 9, and 23). Therefore, the 

increased demand placed on the Biscayne Aquifer reserves by the radial collector wells could 

adversely impact both supply and management of this scare resource in the coming decades. 

See DEIS at 2-176. Moreover, withdrawing water from the Biscayne Aquifer is not a necessary 

consequence of siting the new reactors at Turkey Point. The goal of the final Environmental 

Impact Statement is to balance the need to implement an action against its impacts on the 

surrounding environment. In this instance, that need is for additional baseload power, and not 

for any specific facility contemplated in FPL's application. For example, Work Order #2, Task 1, 

Initial Water Source Alternative Technical Review Report, Section 5.0 (pages 3-4) indicated that 

operating the radial collector wells for use as a backup cooling system ranked fourth in FPL's 

analysis of cooling options. In contrast, drawing cooling water from the "Boulder Zone" (a South 

Florida injection zone) ranked second in this report. FPL's response to NRC RAI Number EIS 

9.4-2 (RAI 5770) indicated that this option was not selected because the Boulder Zone is 

planned for use as an injection zone for wastewater. However, this does not address why the 

third ranked option was not selected or vetted further. Likewise, limiting the analysis in the DEIS 

to only the proposed radial collector wells as a backup cooling system is not the "hard look" 

required by the National Environmental Policy Act (NEPA). This backup cooling system is easily 

one of the most concerning parts of the Turkey Point Nuclear Plant Units 6 & 7 application. 

Since the final Environmental Impact Statement must independently assess the impacts of the 

Environmental Report submitted by FPL, it should also consider other approaches to providing 

cooling water to the reactors. The DEIS has already accomplished this task for some of the 

inland alternative sites by assessing potential cooling systems other than those proposed. The 

final Environmental Impact Statement must do the same for Turkey Point. (0456-11 [Miami, City])

Comment: Comment 13: The final Environmental Impact Statement should examine 

impacts related to the loss of the backup cooling system. The radial collector well system 

may be unable to operate for a variety of reasons. The environmental impacts of losing this 

system should be examined by the final Environmental Impact Statement to meet the "hard 

look" imposed by NEPA. For example, the radial collector wells are not able to operate with 

water that is more than 1.5 times the salinity of Biscayne Bay. As has been noted previously, 

there is already a plume of hypersaline water in the aquifer beneath FPL's industrial wastewater 

facility. Since, the radial collector wells will be drawing water from this groundwater source, the 

final Environmental Impact Statement should examine and disclose how entrainment of the 

hypersaline water by the radial collector wells will impact the surrounding aquifer and operation 

of the nuclear plant. Likewise, the final Environmental Impact Statement should examine and 

disclose what outcomes will result if the primary source of cooling water is still unavailable after 

Appendix E October 2016 E-151 NUREG–2176
FPL has exhausted the 60 days during which it is allowed to operate the radial collector well 

system. (0456-20 [Miami, City])

Comment: FPL has stated that using reclaimed water provided by Miami-Dade County as the 

primary source of cooling water is a beneficial feature. This may be a compelling reason to 

place the new reactors in Miami-Dade County; however, if that is the case it should be 

explained more directly and thoroughly. On this point in particular, it is worth noting that MiamiDade County has begun efforts to supplement its freshwater supply with desalinated water from 

the Upper Floridan Aquifer. Additional saltwater intrusion will only force local governments to 

impose stricter water conservation measures. Hence, the amount of reclaimed water available 

from Miami-Dade County will decline over time and will not be available for use as cooling water 

for much of the operating life of Turkey Point Nuclear Plant Units 6 & 7. (0456-8 [Miami, City])

Comment: In defense of water, please protect our natural resources. (0483-1 [Morrisse, 

Christine])

Comment: Fresh and clean water is essential to life. The two new reactors at Turkey Point 

could also have huge impacts on the quantity and quality of the area's limited freshwater 

supplies. (0495-4 [Mazzarella, Rebecca])

Comment: FPL already has problems cooling the existing facilities and is using millions of 

gallons of fresh water from the aquifer to ameliorate their existing cooling problem. To add more 

capacity, which will require yet more water to cool the site, is irresponsible. (0509-2 [Otto, Peter])

Comment: Given South Florida's limited sources of freshwater, FPL's project seems to be a 

shortsighted investment. (0515-5 [Regalado, Tomas])

Comment: Building additional reactors so near our own drinking water and natural reserves 

should NOT be allowed. I don't think I really have to get too deep into this argument, I simply 

have to link you to a wikipedia page: 

https://en.wikipedia.org/wiki/Fukushima_Daiichi_nuclear_disaster. We must not forget the 

actual costs associated with a natural disaster that literally washes over a nuclear facility. Sure, 

we may not have tsunamis here, but we do have hurricanes, which bring HUGE storm surges.

(0570-3 [Martinez, Orlando A.])

Comment: Fresh drinking water is a concern all over the United States, especially out West. 

We should NOT be blind to this and think we are different. The current FPL nuclear facility at 

Turkey Point already is begging for MORE fresh water to keep its reactors cool. The cooling 

canals are not doing their jobs; even with additional water the cooling canals are overheating. 

This is not being satisfactorily addressed at the moment, nor in the proposal to EXPAND the 

facility. (0570-4 [Martinez, Orlando A.])

Comment: No additional water draws should be allowed. Canal temperatures and salinity 

should be lowered. This environmental situation is incompatible with current operations much 

less expanded ones. (0571-2 [Darden, Colgate])

Comment: In addition, the demands on the limited fresh water reserves of south Florida would 

be highly significant. (0573-3 [Trauner, Keith])

Comment: we will have shortage of water, please don't allow this to happen (0574-2 [Fuentes, 

Mariana])

Appendix E NUREG–2176 E-152 October 2016
Comment: There is not enough freshwater in the area and any further demands on available 

freshwater or loss of it due to plant operation are irresponsible and selfish. (0598-3 [White, Barry 

J.])

Comment: FPL has stated that using reclaimed water provided by Miami-Dade County as the 

primary source of cooling water is a beneficial feature. This may be a compelling reason to 

place the new reactors in Miami-Dade County; however, if that is the case it should be 

explained more directly and thoroughly. On this point in particular, it is worth noting that MiamiDade County has begun efforts to supplement its freshwater supply with desalinated water from 

the Upper Floridan Aquifer. Additional saltwater intrusion will only force local governments to 

impose stricter water conservation measures. Likely climate change scenarios for the region 

indicate that reductions in rainfall will further tax the available freshwater supply. See 

Vasubandhu et al., Climate Scenarios: A Florida-centric View, STATE UNIV. SYSTEM OF 

FLORIDA (Nov. 2011) (citing Enfield et al., Mid-Century Expectations for Tropical Cyclone 

Activity and Florida Rainfall); see also Climate Change and Water Management in South 

Florida: Interdepartmental Climate Change Group, SOUTH FLORIDA WATER MANAGEMENT 

DISTRICT (Nov. 2009). Hence, the amount of reclaimed water available from Miami-Dade 

County will decline over time and will not be available for use as cooling water for much of the 

operating life of Turkey Point Nuclear Plant Units 6 & 7. Accordingly, the final Environmental 

Impact Statement must directly explain the rationale for approving Turkey Point as the site of 

the new reactors. (0611-1 [Haber, Matthew S.])

Comment: During the proposed project's lifetime, Miami will likely face dwindling supplies of 

potable water as well as further difficulties preventing flooding and saltwater intrusion. 

Considering these challenges, 388,800,000 gallons appears to be a relatively large withdrawal 

of water from the Biscayne Aquifer. FPL's most recent filings before Florida's Public Service 

Commission indicate that the new reactors are now planned to enter service closer to 2027. 

Around that time, Miami-Dade County's Water and Sewer Department projects that demand for 

water will be much closer to capacity. See SFWMD Individual Use Permit for MDWASD Permit 

Number 1300017-W (Exhibits 8A, 9, and 23). Therefore, the increased demand placed on the 

Biscayne Aquifer reserves by the radial collector wells could adversely impact both supply and 

management of this scare resource in the coming decades. See DEIS at 2-176. (0611-2 [Haber, 

Matthew S.])

Comment: Comment 6: The final Environmental Impact Statement should update its 

analysis, in groundwater modeling and elsewhere, to include the effects of flooding 

FPL's industrial wastewater facility/cooling canal system with additional water from the 

L-31E canal and other sources. After the completion of the DEIS, the South Florida Water 

Management District ("SFWMD") issued a permit authorizing FPL to divert 100 million gallons of 

water per day from the L-31E canal to the industrial wastewater facility. SFWMD Consumptive 

Use Permit No. 13-05856-W; see also SFWMD Order No. 2015-020-DAO-WU; SFWMD Order 

No. 2015-034DAO-WU. Florida's Department of Environmental Protection ("FDEP") has also 

begun a process that would entitle FPL to draw an additional 14 million gallons of water per day 

from the Floridan Aquifer into its industrial wastewater facility. See http://tinyurl.com/TP3-

5ConditionsDraftMod. Although both actions have been challenged, the former had been 

challenged by the City and the latter is currently being challenged by Miami-Dade County, the 

final Environmental Impact Statement should account for the presence of this additional water 

flow because its ostensible purpose is to flush hypersaline water out of FPL's facilities. As the 

SFWMD noted in late 2013, the consequences of flooding the FPL industrial wastewater facility 

are far from certain. See FPL Turkey Point Cooling Canal System Salinity Reduction Proposal 

Review, attached to these comments as COM - A. Likewise, the USGS model described by the 

Appendix E October 2016 E-153 NUREG–2176
DEIS in Appendix G would need to account for this additional water flow. In addition, "[b]ecause 

the [USGS] model conserves mass, withdrawal of groundwater results in water being drawn 

from other sources to replace it, and the freshening in this region could be due to predicted 

inflow from either freshwater or marine waters." DEIS at G-35. Hence, the assumption appears 

to be that there will be a recharge of freshwater. This assumption is problematic and likely 

inaccurate. The final Environmental Impact Statement should address this assumption more 

directly. (0611-6 [Haber, Matthew S.])

Comment: In addition to their waste water use, Turkey Point 6 and 7 would use vast quantities 

of drinking water, making it unavailable for people and agricultural uses. Florida already suffers 

from a lack of fresh water and the further encroachment upon our supply necessitated by the 

proposed plants would create a substantial and unjustifiable impingement upon the environment 

resulting in a hazard to human health. (0615-3-2 [Bethune, David])

Comment: Water is Florida's most important environmental asset. In failing to fully examine the 

impact of both its proposed use of fresh water and the plant's effluent injection and wastewater 

aerosols, the draft EIS proves to be fatally incomplete. (0615-3-6 [Bethune, David])

Comment: The estimated average rate of saltwater migration is between 525 feet per year in 

the northern part of the cooling canals, and 660 feet per year in the southern part, [FDEP AO 

OGC No. 14-0741.] Many municipal water supply systems to the west of the Turkey Point 

cooling water canals rely on the Biscayne aquifer, and if the hypersaline plume continues to 

migrate, these water supply systems could potentially need additional treatment, or alternative 

sources of water supply. We are concerned about the potential for additional and cumulative 

impacts to the sole source aquifer, in addition to the existing hypersaline impacts. Protecting the 

freshwater lens in southeast Miami-Dade County is also a critical priority, since this important 

resource supports critical marsh wetland communities, as well as irrigation and public water 

supply needs. This fresh water supply is needed to preserve and restore Biscayne National 

Park (BNP) and Biscayne Bay, and for supporting the Comprehensive Everglades Restoration 

Plan (CERP). We appreciate your efforts to minimize impacts from the proposed project by 

using reclaimed wastewater as cooling water. The DEIS also states that current alternative 

backup cooling water source plans call for saltwater supplied from horizontal radial collector 

wells installed in the Biscayne aquifer, between 25 and 40 feet beneath the bed of Biscayne Bay 

and adjacent to Biscayne National Park. The DEIS notes that the use of these wells as a 

backup source is limited to 60 days. However, there are concerns that FPL could eventually 

require more water from the radial collector wells than currently estimated, and that FPL may 

need to withdraw freshwater to supply the needs of the two new reactors, in the event that 

adverse circumstances arise and backup water sources fail to supply sufficient quantity. The 

FEIS should address contingency plans in detail. Concerns exist that future circumstances, 

such as draughts and/or temperature issues, may require freshwater withdrawals that could 

potentially impact water quantity and quality, and contribute to the risk of additional saltwater 

intrusion into groundwater supplies. Furthermore, there are concerns that water withdrawals 

from the radial collector wells could potentially contribute to increased hypersalinity. (0617-1-18

[Mueller, Heinz J.])

Comment: Concerns regarding fresh water needs for Biscayne National Park (BNP), the 

Everglades National Park (ENP), the Comprehensive Everglades Restoration Plan (CERP), in 

addition to other fresh water needs in the area, need to be clarified in the Final Environmental 

Impact Statement (FEIS). The EPA has concerns regarding the project's fresh water supply 

requirements, cumulatively added to the existing fresh water needed to supply the existing Units 

3 and 4, as well as for drinking water, agricultural and ecosystems in the region, in an 

Appendix E NUREG–2176 E-154 October 2016
environment already experiencing saltwater intrusion. The Biscayne aquifer underlying the area 

is prone to saltwater intrusion because this area has low land-surface altitude and a low 

topographic gradient, and is bordered by sources of saltwater in Biscayne Bay, and, further 

east, by the Atlantic Ocean. Page 2-66 states that the most important factors contributing to the 

regional intrusion of saltwater from the ocean into the aquifer are rerouting of sheet flow to 

drainage canals and groundwater pumping. (0617-1-3 [Mueller, Heinz J.])

Comment: 6) Analysis of Impacts to CERP Projects and the BBCW Project 

One of the goals of the CERP is to increase freshwater flow to Biscayne NP to achieve more 

natural hydrologic conditions within the park that has been negatively impacted by 

implementation of the regional water supply and flood control project. Given the lack of specific 

localized information regarding the effect of the RCWs on nearshore salinity levels, the NPS 

disagrees with NRC's conclusion that the proposed action would have minimal effect on CERP 

and Phase 1 of the BBCW project. NPS remains concerned that the cumulative impacts 

resulting from this project could potentially negate current or potentially future efforts to increase 

freshwater flows to rehydrate wetlands and reduce point source pollution discharge into 

Biscayne NP and Biscayne Bay. A second phase of the BBCW project remains to be planned 

and authorized, but is reflected in overall salinity restoration target goals for the park. Detailed 

review of modeling results from the DEIS analysis show a potential for impacts to groundwater 

sources for CERP, as well as movement of the groundwater masses related to RCW 

operations. The BBCW Project Phase 1, which is intended to redistribute existing freshwater 

flows to Biscayne NP, is now entering the construction phase with operation to shortly follow. 

This is an example where a model with finer spatial scale on the operation of the RCWs would 

provide information to determine whether the effects of the RCW operation negate or diminish 

efforts to rehydrate near shore coastal wetlands through the implementation of the BBCW 

Project, phase 1, authorized under the Water Resources Development Act of 2014. Generally 

the BBCW Project will divert an average of 59 percent of the annual coastal structure 

discharges from the S-123, S-21, S-21A and S-20F structures into Biscayne Bay. Anticipated 

environmental benefits include, among other things, improving the probability that the water 

within 500 meters from the shoreline will meet a desired salinity concentration of less than 20 

psu. The NPS recommends development of a model with additional data, better calibration, and 

a finer scale will better show the likely potential localized impacts. 

Although the BBCW Project is in the implementation phase, the CERP assumes a second 

phase for the project that would provide additional fresh water to Biscayne Bay. We recognize 

the difficulty in determining the environmental effects of the proposed action on a plan that is not 

yet planned or implemented with specificity including additional volumes of fresh water to be 

discharged, however, NPS believes it is important to acknowledge the future potential for this 

planned additional work to reintroduce more fresh water to the bay to benefit the various wildlife 

species that depend on the wetlands and on a healthy bay. 

Additional information on the progress of the CERP may be obtained in the National Academy 

of Sciences' report "Progress Toward Restoring the Everglades: The Fifth Biennial Review, 

2014." (0622-1-14 [Austin, Stan])

Comment: RCWs located below Biscayne Bay, offshore Turkey Point[.] Four radial collector 

well caissons located on the Turkey Point Peninsula would serve as a backup water supply. 

Each RCW caisson would be approximately 30 feet in diameter and extend beneath the surface 

of Biscayne Bay to a depth between -35 to -45 feet. The laterals would be extremely close to the 

Appendix E October 2016 E-155 NUREG–2176
marine boundary of Biscayne NP and be built in limestone terrain. Because FPL owns much of 

the land within the footprint for BBCW Phases 1 & 2, we once again encourage consideration of 

having this land transferred to EEL in preparation for the completion of both phases of BBCW 

project. We also strongly encourage the development of a comprehensive monitoring and 

adaptive management plan to ensure that any operational problems are judiciously addressed.

(0622-2-14 [Austin, Stan])

Comment: Water Quality Impacts and the Industrial Wastewater Facility (IWF)[.] The NPS 

is concerned that the DEIS does not fully analyze water quality impacts, which are derived from 

construction activities, associated cooling water drift, and the movement of IWF waters related 

to RCW operation, to NPS resources, especially cumulative impacts associated with the IWF. 

Recent developments relating to the operation of the IWF were not analyzed in the DEIS. The 

hyper-salinity and temperature in the IWF, including the use of regional system water under 

recent orders, must be evaluated as part of the past, present, and future cumulative impacts. 

Also, the IWF and its associated plume should be evaluated to better understand cumulative 

impacts from RCW operation on the hypersaline plume. Fundamentally, the NPS is concerned 

that the operation of the RCWs has the potential to affect the salinity of Biscayne Bay. The DEIS 

modeling demonstrated that RWC operations influenced salinity at a broad spatial scale. 

However, salinity variability at a scale finer than that addressed by modeling would provide 

more insight into localized potential ecological effects in southern Biscayne Bay. The NPS 

recommends more extensive analysis of the model output and some model modifications, 

including the consideration of more recent salinity data, to increase its spatial resolution to 

determine the extent to which RCW operations will adversely impact resources in Biscayne NP 

due to salinity changes. (0623-4 [Austin, Stan])

Comment: In addition to this problem with surface water two new nuclear reactors will need to 

increase the amount of ground water required to cool these new reactors. Ground water 

supplies are already under stress from salt water intrusion and additional development in this 

area. (0641-2 [Martin, Drew])

Comment: Water reuse may not provide adequate water supplies as a supplement to existing 

water supplies as we increase the needs of the community for reusable water. Some 

proponents suggest that water reuse can provide adequate water. This assumes that water 

reuse will not be needed for other needs. (0641-4 [Martin, Drew])

Comment: This action would reduce the availability of fresh water to our community. In a 

populous state such as Florida which already experiences a lack of fresh water (in Miami-Dade 

county we already have water restrictions limiting us to two days a week to water outside) I 

believe that using 7 billion gallons of water from Biscayne Bay and aquifer for a back up cooling 

system is totally irresponsible. (0642-2 [Rawlins, Steve])

Comment: In addition, it could harm our clean water supply. (0654-3 [Guy, Sharon])

Comment: It would further destroy Florida's wild and poison our water. It is a disaster waiting to 

happen! (0661-3 [Segal-Wright, Nicholas])

Comment: Nuclear plants consume vast amounts of water to keep reactors cool. FPL currently 

accounts for less than 1 percent of the water used in Miami-Dade County, but a nuclear 

expansion would raise that to 10 percent of water usage. In two decades, the demands on our 

limited water supply are already projected to skyrocket. FPL emphasizes that the primary 

cooling system will use reclaimed wastewater. But it ignores the inconvenient fact that its 

Appendix E NUREG–2176 E-156 October 2016
backup cooling system will also draw over 7 billion gallons of water a year from Biscayne Bay 

and the Biscayne Aquifer, our only source of drinking water, threatening the coastal Everglades, 

Biscayne National Park, and South Dade well fields. Given the anticipated demands on our 

shrinking water supply, FPLs water grab is an irresponsible use of resources. In addition, on 

May 19th, 2015, FPL had to obtain an emergency permit from the South Florida Water 

Management District to pump more water into the Turkey Point cooling canals as a result of a 

cooling problem with the existing nuclear reactors that FPL has been dealing with for over a 

year. (0675-2 [Rodriguez, Jose Javier])

Comment: The new reactors will require 90 million gallons a day of Miami-Dades treated 

wastewater for cooling. (0676-5 [Kassel, Kerul])

Comment: If there is insufficient treated wastewater for cooling the reactors, the radial wells 

used for back-up cooling would become one of the largest well-fields in the Southeast and could 

lead to further saltwater intrusion into the Biscayne Aquifer, a major problem already impinging 

on South Floridas limited freshwater supply. (0676-8 [Kassel, Kerul])

Comment: Additionally, the nuclear reactors use an enormous amount of fresh water for 

cooling that makes the Biscayne Aquifer more susceptible to salt water intrusion. 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. In 2008, nuclear power plants withdrew 8 times as much freshwater as natural gas 

plants per unit of energy produced, and up to 11 percent more than the average coal plant. Our 

water supply is a finite resource that we need to conserve in order to support our South Florida 

population. (0677-3 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: The Design and Operating two new reactors at Turkey Point should not have any 

effect on the quantity and quality of precious freshwater resources. The tech exist today to 

prevent any effect. (0694-3 [Carpenter, Rory])

Comment: Turkey Point continues to consume large amounts of fresh water needed by the 

population increases expected in South Florida. Additional reactors will exacerbate the 

problems. Current cooling ponds for Turkey Point are at excessive temperatures. (0710-2 [Platt, 

George Seth])

Comment: Number two is, some of the questions have alluded to the issues about water. 

Some of the information that's come to me is that if these new reactors are built, Turkey Point's 

use of our fresh water will go from 1 percent to 10 percent. Now, even if that's not accurate, 

somewhere in that range is. (0721-1-5 [Rodriguez, Jose Javier])

Comment: So here we are, we're looking at a site. Obviously it's not working, and this EIS, if 

it's going to consider anything, should consider the fact that the system's broken, it's not 

working, 3 and 4 is a disaster, the cooling canal system is loading salt into our aquifer, 

evaporating 40 million gallons a day, and pushing a plume of pollution underneath our national 

parks toward the Newton Well Fields in Dade County. It is a disaster. And the thing is, it's all 

underground. And if there's a loophole, FPL has found it, and they are taking advantage of it for 

corporate gain. And so what we need to do is really consider the issues on the ground, the 

water consumption. This is all about water. It's a big water grab, in my opinion. And if all of the 

proposals go forward, FPL will be the single largest user in the State of Florida. And that 

surpasses Dade County at about 30.5 million gallons a day of water. Think about how big that 

is. So we're talking about water. We're spending $20 billion on Everglades restoration to get the 

Appendix E October 2016 E-157 NUREG–2176
water right, to make sure that 8 million people have enough water to drink, to make sure we 

restore the Everglades. We have nowhere to store fresh water in South Florida. Yet, we're using 

an energy source that requires a lot of water. (0721-10-2 [Reynolds, Laura])

Comment: So nuclear, we have water demand, fresh and saline[.] (0721-11-5 [Roff, Rhonda])

Comment: It [building 6 and 7] will bring increased salinity and salt water intrusion and possibly 

over time, fouling the water supply for all of South Florida and the Keys[.] (0721-12-9 [White, Barry 

J.])

Comment: But I do think that if there [are] problems finding water to cool existing reactors, then 

it indicates that there would be a problem having additional water to cool two new reactors. So it 

makes sense to me that you would resolve these problems before you would authorize the 

building of two new reactors. (0721-13-2 [Martin, Drew])

Comment: So what have we learned from the President's speech today? We learned we need 

to save our water. We don't have enough. And this power plant is going to be a major water 

hog. No question about it. (0721-30-3 [Ullman, John])

Comment: Nonetheless these issues are dwarfed, as I've said, by the voracious water 

consumption of Turkey Point, both presently with the dysfunctional cooling canals and the future 

needs to two additional reactors, (0721-32-4 [Schlackman, Mara])

Comment: For the safety of our communities this plan must not be approved as proposed, and 

here is why: It will shrink the supply and quality of water and our fresh water sources. (0721-4-2

[Regalado, Tomas])

Comment: And, water usage does not take in to account what would happen -- the Draft EIS 

report does not take account water usage and what would happen if the reclaimed water system 

fails; where would the water usage go or how would that be addressed. (0721-5-8 [Mendez, 

Victoria])

Comment: The expansion of Turkey Point also has the potential to have huge impacts on our 

regional water resources. FP&L has proposed using millions of gallons of reclaimed wastewater 

as the primary source of cooling water for the new reactors. (0721-9-5 [McLaughlin, Caroline])

Comment: [O]ne of the neat things I think that they're doing, they're engineering this project, is 

they're reclaiming wastewater from Miami Dade County to about 60 million gallons a day which 

would otherwise go down into Biscayne Bay or the ocean or the deep wells that we have. That 

this will also be reclaimed and recycled for continuing cooling. (0722-13-7 [Duquette, Bill])

Comment: Our planet is bleeding and I think we have to make every effort to protect our planet 

and Biscayne Bay. We talk about water and how we're going to reuse water sewage. Miami 

Dade can't even get their pipes right. We're flooding Miami Dade, sewers backing up. They 

were supposed to replace pipes over the last 30 years, they did not do so and we're going to be 

counting on those pipes to provide water to this nuclear plant? What about the water that's not 

going to go to the Florida Keys because Turkey Point needs it? What's our water pressure going 

to be like in Turkey -- in Florida Keys? (0722-17-3 [Swenson, Cyndee])

Comment: The withdrawal of this water would increase salinity levels in Biscayne that have 

already been drastically and dramatically changed by the draining of the Everglades and this 

would increase the rate of saltwater intrusion into our limited freshwater supplies. There's also 

Appendix E NUREG–2176 E-158 October 2016
the potential for the contamination of our freshwater supplies by chemicals related to the nuclear 

power generation. (0722-7-4 [Silverstein, Rachel])

Comment: One thing that we all have in common here is that we all drink water. And access to 

clean water and clean freshwater is absolutely critical and is something that can be lost here in 

South Florida and should be really considered very seriously in this project. (0722-7-8

[Silverstein, Rachel])

Comment: I'm also impressed by the reuse factor with Miami Dade Water and Sewer Authority. 

This one project will meet 50 percent of the needs as far as reusing the effluent from the Water 

and Sewer Authority. That's significant. (0723-1-6 [Wallace, Otis])

Comment: And whereas FPL's design of the Turkey Point Units 6 and 7 to make use of 

reclaimed water for cooling purposes and will assist our county and meet the regulatory 

requirements for reusing" -- I'm sorry -- "for increasing use of reclaimed water. (0723-2-6

[Trowbridge, Mark])

Comment: From the environmental impact of -- I know recently the local papers talk about the 

wastewater discharge. We're one of the few counties, communities in Florida still discharging to 

the ocean or bay. So this project to control wastewater, treat wastewater and reuse it is going to 

happen one way or the other, appropriately. If Turkey Point 6 and 7 can use some of that water 

and help to use that for our cooling medium, that will help the environmental impact of all of us 

living in Dade County because we all make wastewater, to minimize that on our great area that 

we live. (0723-6-3 [Murphy, Mike])

Comment: Let's talk about one of the really rough parts of the project, the use of recycled 

sewage to cool it. What happens when you run recycled sewage through cooling towers? First 

of all, what do you think that recycle sewage is? Is it pure H2O? No, not at all. Hundreds if not 

thousands of chemicals are still in there. The drinking water in Homestead has hundreds of 

chemicals below what they call the safety limit, but this stuff is in there. Lead, cadmium, arsenic, 

et cetera. The wastewater has even more. Household chemicals, cleaning fluids, viruses, 

bacteria. (0723-9-14 [Schwartz, Matthew])

Response: Turkey Point Units 6 and 7 would rely primarily on treated wastewater for 

operation. Treated wastewater is not suitable for potable water or most restoration activities 

because of its water chemistry. NRC staff did not identify other current or likely future demands 

for treated wastewater that are likely to conflict with the volume of treated wastewater proposed 

to be used by Units 6 and 7. The treated wastewater, while “fresh” in terms of salinity, is still not 

suitable for most other uses including municipal, agricultural, and CERP wetland restoration 

because concentrations of other contaminants and nutrients are too high. If this treated 

wastewater is not used by the proposed plant it would likely be injected into the Boulder Zone, 

at which point it would be unavailable for any beneficial use. Accordingly, it would be inaccurate 

to characterize the treated wastewater as a percentage of fresh water available for drinking, 

agricultural use, or the like. 

The Miami-Dade Water and Sewer Department (MDWASD) SDWTP has a capacity of about 

300 MGD. The proposed plant would take about 73 MGD from the South District Plant. Under 

Florida law, MDC is required to end ocean discharge and, therefore, must substantially increase 

deep well disposal. Evaporation in the cooling towers of the proposed plant would consume 

some of the wastewater volume before the remainder is injected into the Boulder Zone. 

Appendix E October 2016 E-159 NUREG–2176
While the NRC staff determined that the wastewater supply is reliable for power generation 

operations, FPL proposed a radial collector well (RCW) system as a backup water supply. As 

discussed in Appendix G, while the water withdrawn from the RCWs would predominately come 

from the Biscayne Bay, the review team did evaluate the amount of water that may come from 

the Biscayne Aquifer under various possible current and future conditions. Far smaller amounts 

of water would enter the RCWs from the hypersaline plume beneath the IWF than from the 

Bay. The potentiometric depression caused by the operation or the RCWs could cause the 

limited lens of freshwater in the Biscayne Aquifer northwest of the IWF to move slightly closer to 

the IWF under certain conditions. However, the staff determined that this change was minor. 

In the unlikely situation that the reclaimed water supply would be unavailable and the FDEP 

restrictions on the duration of the RCWs would be met, and in the absence of the use of some 

other water source approved by the State of Florida, the plant would cease operation. 

Neither the reclaimed water nor the backup RCW water provide a safety function. Plant safety 

systems do not rely on either water source. These water sources are only necessary for 

continued electrical power generation. The proposed RCW water supply capability as a backup 

water source was an FPL decision to ensure generation reliability and is not a requirement for 

plant safety. 

Comment: The cooling canals at the current Turkey Point facility do not function properly for 

the existing site. Scarce water from the South Florida Acquifer must now be drawn to cool the 

reactors properly. The size of these canals are already a blight on our sensitive Florida 

landscape and the drawing down of water for cooling purposes endangers our drinking water 

supply. (0053-2 [Sasiadek, Alfred])

Comment: The integrity of drinking water for the south Florida area is at stake. The water that 

FP&L would use to cool its power plants would affect the level of saltwater intrusion into the 

Biscayne Aquifer, the main source of drinking water for this area. FP&L also plans to curtail its 

current monitoring program for this, which is totally unacceptable. (0073-1 [Commenters, Multiple])

Comment: FPL is already operating cooling based upon "emergency" draw down, so is using 

fresh water never anticipated in the original operating plan and that will only get worse. (0091-2

[Boyce, Sheila])

Comment: Miami-Dade County asserts that the DEIS is inadequate with respect to the 

proposed radial collector wellfield (RCW) that would be constructed under the tidal waters of 

Biscayne Bay. The Biscayne Model, discussed in Appendix G, does not accurately represent 

the current surface water salinity conditions of the CCS. Historic monitoring data indicate that 

the salinity of the surface waters of the CCS has been steadily increasing since the early 1970s 

and this modeling does not appear to take this fact into account. Furthermore, data from the 

more recently implemented Uprate monitoring indicates that the salinity of the CCS has 

increased even more rapidly after the uprate of the existing nuclear units (Units 3 & 4) was 

completed and both units returned operating back to full capacity (around May 27, 2013) 

reaching salinity levels that are nearly three (3) times that of seawater. The increased salinity of 

the CCS surface water has compromised the system's ability to reduce the water temperature 

so that it can be used for cooling of Units 3 & 4 and forced FPL to seek an NRC license 

amendment to increase the ultimate heat sink (UHS) water temperature limit for the plant's 

cooling canal system in July of 2014. In August of 2014, the NRC Staff approved the proposed 

license amendments increasing the temperature specification for the UHS from 100oF to 104oF. 

The increased salinity and temperature of the CCS have also forced FPL to seek alternative 

Appendix E NUREG–2176 E-160 October 2016
sources of water to discharge to the CCS in order to reduce the salinity and temperature of its 

surface waters in order to allow for the continued safe operation of the plant. The average post 

Uprate salinity at CCS surface water monitoring station TPSWCCS-1B between June 1, 2013 to 

April 30, 2015, is 76.35 PSU. Monitoring station TPSWCCS-1B is located in the vicinity of the 

NW corner of the CCS along canal 32, the station is equipped with water quality monitoring 

equipment that measures physical water parameters, including salinity, in one hour intervals. 

The CCS surface water salinity used for the model discussed in Appendix G was a constant 65 

PSU. The use of salinity averages that underestimate the actual salinity of the CCS and that 

incorrectly assume that the salinity will not continue to increase over time is not appropriate as it 

does not simulate existing conditions and because it can lead to an underestimation of the 

impacts associated with CCS related issues including but not limited to salinity of the CCS 

groundwater plume that is mobilized by the operations of the proposed RCW. (0110-1-7 [Hefty, 

Lee N.])

Comment: The NRC is aware that FPL has been experiencing significant problems related to 

cooling water and the cooling canal system (CCS) needed for their existing Turkey Point 3 and 

4 reactors. Further, on March 23, 2015 an Atomic Safety and Licensing Board panel admitted a 

modified contention, based on the October 14, 2014 petition of Citizens Allied for Safe Energy, 

Inc. (CASE) who successfully requested a hearing on license amendments issued to FPL's 

Turkey Point reactor Units 3 and 4, which increased the ultimate heat sink (UHS) water 

temperature limit for the plant's cooling canal system (CCS). Contention 1, which is still pending, 

states: "The NRC's environmental assessment, in support of its finding of no significant impact 

related to the 2014 Turkey Point Units 3 and 4 license amendments, does not adequately 

address the impact of increased temperature and salinity in the CCS on saltwater intrusion 

arising from (1) migration out of the CCS; and (2) the withdrawal of fresh water from surrounding 

aquifers to mitigate conditions within the CCS."5 [footnote 5: See March 23, 2015 ASLBP 

Memorandum and Order, http://pbadupws.nrc.gov/docs/ML1508/ML15082A197.pdf.] We 

believe there is new information regarding reactor Units 3 and 4 that affects the analysis and/or 

determinations in the DEIS for reactor Units 6 and 7. The NRC has a continuing obligation to 

update the Turkey Point 6 and 7 EIS with new and significant information and that information 

must be included and analyzed before an FEIS is issued. For instance, recent reports highlight 

an ever-worsening situation that could have implications for the proposed Turkey Point 6 and 7 

reactors, including the possibility of piping reclaimed water from the Miami Dade County's 

southern sewer treatment plant which was also proposed to cool the two proposed new 

reactors:6 [footnote 6: Jenny Staletovich, Miami Herald, "FPL needs more water to run Turkey 

Point," May 19, 2015. At 

http://www.miamiherald.com/news/local/environment/article21419787.html.] "The utility obtained 

an emergency permit Tuesday from the South Florida Water Management District to pump more 

water into the 5,900-acre loop used to cool the plant's two nuclear reactors. But Miami-Dade 

County Commissioners added a strict caveat: they agreed to provide a permit to pump the water 

across sensitive wetlands only for a year and only if the utility comes up with a long-term fix. ... 

The canals first began running hot last summer after the utility completed work to increase 

power coming from the plant on southern Biscayne Bay. The hotter and increasingly saltier 

canals triggered persistent algae blooms, threatened to shut down the reactors and forced the 

utility to scramble to find ways to better control the system. But finding a solution has proved 

tricky and set off debates over South Florida's fragile water supply, with the county, the city of 

Miami, Biscayne National Park, environmentalists and even rock miners raising objections. In 

addition to raising the risk of power outages, the canals have pushed an underground saltwater 

plume closer to drinking water supplies. Last summer, after the Nuclear Regulatory Commission 

agreed to allow operating temperatures to rise to 104 degrees, the hottest in the nation, FPL 

began looking for water to cool and freshen the canals. The company won temporary 

Appendix E October 2016 E-161 NUREG–2176
permission to pull water from the nearby L-31 canal -- between August and October, the utility 

pumped 1,135 million gallons or about four times what all of Miami-Dade County uses in a day. 

The utility hoped to find a more permanent solution by drilling six new wells to pump up to 14 

million gallons of water a day from the Floridan aquifer, a source deep beneath the shallow 

Biscayne Aquifer that supplies most of the county's drinking water. But local government 

officials and environmental groups have fought FPL's plans, filing appeals and arguing that 

diverting water to the plant could derail Everglades restoration efforts intended to revive 

Biscayne Bay, where increasing salinity threatens marine life. County staff also said adding 

freshwater could also worsen the movement of underground saltwater. ... Pulling water from the 

L-31, he explained, is intended to keep the canals working only until six wells can be drilled to 

pump water from the Floridan for long-term relief. FPL is also now talking with the county about 

piping reclaimed water from the county's southern sewer treatment plant -- water it also intends 

to use to cool two new reactors now being considered by the NRC. However, that water must be 

cleaned first and Scroggs said the utility has not yet determined the standards for its use."

(0112-6 [Barczak, Sara])

Comment: The expansion also threatens the goals of CERP through potential negative 

impacts to the benefits of BBCW. One of the primary objectives of BBCW is to rehydrate coastal 

wetlands located adjacent to Turkey Point and to restore overland and subsurface water flows. 

Plans to withdraw water from Biscayne Bay using radial collector wells as a backup cooling 

water supply for Units 6 & 7 will likely draw freshwater away from what is needed for restoration, 

as discussed in greater detail in Section II, and operations could detract from benefits realized 

as a result of restoration efforts. (0113-1-11 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] 

[Schwartz, Matthew] [Silverstein, Rachel])

Comment: The DEIS does not adequately address the cumulative impacts of constructing and 

operating Units 6 & 7 on salinity levels in groundwater, surface water, the Biscayne Aquifer, and 

Biscayne Bay. (0113-1-7 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] 

[Silverstein, Rachel])

Comment: According to NEPA, cumulative impacts are those that occur from the "incremental 

impact of the action when added to other past, present, and reasonably foreseeable future 

actions regardless of what agency (Federal or non-Federal) or person undertakes such other 

actions." [Footnote 37: 40 C.F.R. § 1508.7] Every year, the SFWMD conducts fall agricultural 

draw downs in Miami-Dade County in order to manipulate groundwater storage to support 

agricultural interests at the end of the wet season. The result of these actions include the rapid 

release of water at the end of the wet season and an artificially early start to the dry season. 

[Footnote 38: Kearns, E. J., A. Renshaw, and S. Bellmund. Environmental Impacts of the 

Annual Agricultural Drawdown in Southern Miami Dade County, Abstract, American 

Geophysical Union, 2008.] The dry season is therefore unnaturally dry, causing habitat loss, 

salinity issues and other negative ecological consequences. [Footnote 39: Ibid.] The DEIS fails 

to include a discussion of how these annual draw downs, when coupled with the existing 

hypersaline plume and proposed operations of Units 6 & 7, will cumulatively impact salinity 

levels within Biscayne Bay and the Biscayne Aquifer. (0113-2-11 [Lopez, Jaclyn] [McLaughlin, 

Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: We are currently being forced to share our drinking water source with FPL as a 

result of the failure of their Cooling Canal system to sufficiently cool the canals after the current 

nuclear plants had an "uprate" in 2014. The predictions that FPL relied on in 2008 when they 

first applied under the Florida Power Plant Siting Act to "uprate" the allowable amount of 

electricity generated by the two nuclear facilities at Turkey Point, Units 3 & 4 were wrong. In 

Appendix E NUREG–2176 E-162 October 2016
their application they represented that the uprate would cause only an insignificant temperature 

increase. As a result of their failed predictions, they sought emergency relief from the NRC, to 

increase the temperature cutoff to 104 degrees. Based on their failure to accurately predict or 

play out the consequences of various scenarios, the predicted increase in water temperature 

entering the cooling canals, and the predicted salinity were not in fact accurate, and as a result, 

a management plan was required, to avert a crisis scenario of water heated to over 104 

degrees. (0145-4 [Lerner, Cindy])

Comment: Further, failure to address the current crisis, the instability of Turkey Point and its 

entire cooling canal system as it functions today, under emergency permits, is a fatal flaw by 

ignoring a current crisis that may never be resolved. The Draft EIS report must take into account 

under what circumstances would FPL manage operations of cooling canals in a manner that 

does not impact surface waters of our aquifer, and how that would factor into the determination 

that this site could function with two new plants, if the proposed new Cooling towers failed, or 

the re use water failed, and its cumulative impact to maintaining both 3 & 4 and a proposed new 

6& 7. (0145-7 [Lerner, Cindy])

Comment: No less the warmer water from the cooling systems creating an algae bloom and 

the amount of water it would take to cool (0147-2 [Jones, Joan and Robert])

Comment: The Nuclear Regulatory Commission draft Environmental Impact Statement needs 

to incorporate recent data showing the negative impact caused by the "uprate" for Turkey Point 

nuclear power units 3 & 4 into the final analysis. Miami-Dade environmental regulators have 

opined that the NRC approved increase in energy output and increased temperature for the 

cooling canals and are causing an acceleration of hypersaline conditions which is accelerating 

saltwater intrusion into Miami-Dade's drinking water aquifer. (0172-4 [Cava, Daniella Levine])

Comment: Prior environmental impact statements conducted by the NRC indicated that the 

uprate project would have minimal environmental impact, yet just months after Florida Power 

and Light initiated the increased power output at the plants, the water temperature in the cooling 

canal system spiked to unacceptable levels. To mitigate the impact that the NRC had previously 

determined was not going to happen, FPL petitioned to draw up to 100 million gallons of water 

per day that would otherwise flow to Biscayne National Park in order to try to cool down the 

overheated canals. According to the Miami Herald, in just 7 months, over one billion gallons of 

water had been diverted to the power plant during that emergency period. FPL has requested to 

continue this emergency draw from the South Florida Water Management District for another 

two years in an attempt to control the excessive temperature that continues to plague the 

existing system. (0172-5 [Cava, Daniella Levine])

Comment: The DEIS fails to include an adequate analysis of the direct, indirect, and 

cumulative impacts of the proposed radial collector well system, including its impact on the 

available regional water supply. (0208-6 [Ritz, David])

Comment: The DEIS does not adequately address the cumulative impacts of constructing and 

operating Units 6 & 7 on salinity levels in groundwater, surface water, the Biscayne Aquifer, and 

Biscayne Bay. (0208-8 [Ritz, David])

Comment: Hypersaline water is being discharged into the waters and mangrove swamps of 

Biscayne National Park and and the Biscayne Bay Aquatic Preserve. (0252-6 [Van Leer, Sam])

Appendix E October 2016 E-163 NUREG–2176
Comment: This utility is victimizing Miami residents in the following ways:--starting to draw in 

2014 more fresh water from our aquifer supply because its cooling canals are no longer cooling 

discharged water fast enough. This endangers our drinking water supply by increasing salt 

water intrusion into the aquifer. (0283-4 [Compel, Jr., Joseph])

Comment: The issue of super heated water is another insurmountable problem. There is a 

history of this problem which has been chronicled by The Miami Herald. It is public knowledge 

that the hot water produced by the nuclear reactors does not cool down as it is expected to, and 

Turkey Point was threatened with a shutdown for this reason. We are experiencing record heat, 

and there is no way for the heated water to cool down as temperatures will continue to hit record 

highs year after year. (0365-5 [Fischer, Antoinette])

Comment: The salinity in the cooling canals is too much and the canals are too hot. You are 

using our precious water to cool the canals more. Israel uses all of its reuse water. In the future 

we will have to use all of ours as well. If you legislate the water for this plant we won't have it to 

use for our precious tropical plant agriculture. Did you know that in the continental US florida is 

the only place where tropical plants grow. (0373-4 [Lee, Nancy])

Comment: I am greatly concerned about the large impacts Turkey Point has already had on 

the quantity and quality of limited freshwater resources, a situation that will only worsen with 

more reactors. The withdrawal of massive amounts of water from under Biscayne Bay as backup cooling water could increase salinity levels within the Bay and hasten saltwater intrusion into 

limited freshwater supplies--the full impacts of which have not been thoroughly analyzed in the 

draft Environmental Impact Statement. (0379-6 [Commenters, Multiple])

Comment: Just remember, that the operators of Turkey Point, the way it is already, have so 

underdesigned the cooling systems that they had to get a waiver to degrade even more of the 

aquifer and Biscayne Bay by pumping even more water, and now, they want this exception that 

was granted to be permanent! (0435-1 [West, Eric])

Comment: Comment 6: The final Environmental Impact Statement should update its 

analysis, in the USGS model and elsewhere, to include the effects of flooding FPL's 

industrial wastewater facility/cooling canal system with additional water from the L-31E 

canal and other sources. After the completion of the DEIS, the South Florida Water 

Management District (SFWMD) issued an order authorizing FPL to divert 100 million gallons of 

water per day from the L-31E canal to the industrial wastewater facility. SFWMD Order No. 

2015-020-DAO-WU. Florida's Department of Environmental Protection (FDEP) has also begun 

a process that would entitle FPL to draw an additional 14 million gallons of water per day from 

the Floridan Aquifer into its industrial wastewater facility. See http://tinyurl.com/TP3-

5ConditionsDraftMod. Although both actions are being challenged, the former by the City and 

the latter by Miami-Dade County, the final Environmental Impact Statement should account for 

the presence of this additional water flow because its ostensible purpose is to flush hypersaline 

water out of FPL's facilities. As the SFWMD noted in late 2013, the consequences of flooding 

the FPL industrial wastewater facility are far from certain. See FPL Turkey Point Cooling Canal 

System Salinity Reduction Proposal Review, attached to these comments as COM - A. 

Likewise, the USGS model described by the DEIS in Appendix G would need to account for this 

additional water flow. In addition, "[b]ecause the [USGS] model conserves mass, withdrawal of 

groundwater results in water being drawn from other sources to replace it, and the freshening in 

this region could be due to predicted inflow from either freshwater or marine waters." DEIS at G35. Hence, the assumption appears to be that there will be a recharge of freshwater. The final

Environmental Impact Statement should address this assumption more directly. The final

Appendix E NUREG–2176 E-164 October 2016
Environmental Impact Statement should also update the USGS model to account for sea-level 

rise over the radial collector well system's operating life and address: The possibility that 

flushing the FPL industrial wastewater facility with additional water from the L-31E canal (in a 

manner that does not prevent evaporation or the resulting salinity increases) will push saltier 

water underground, The effect on the inland aquifer of seawater releases from the radial 

collector wells into the FPL industrial wastewater facility, and The potential for increased salinity 

levels in the inland aquifer resulting from future sea-level rise and storm surge hazards at the 

Turkey Point site, as well as the effects of this increased salinity on South Florida's freshwater 

resources. Moreover, the City echoes Miami-Dade County's concerns related to the area across 

which the USGS model predicts average salinities over Biscayne Bay. The model should 

include an analysis that more narrowly focuses on southern Biscayne Bay. The broad focus of 

the USGS model obscures the true potential impacts of operating the radial collector wells in a 

fragile aquatic ecosystem. The decision of the Nuclear Regulatory Commission, and 

cooperating agencies, of whether or not to approve the Turkey Point Nuclear Plant Units 6 & 7 

application will likely rely on the findings of this model. The final Environmental Impact 

Statement, or a Supplemental Environment Impact Statement, should address these issues by 

refining the USGS model. (0456-13 [Miami, City])

Comment: In addition: The existing power plant infrastructure has demonstrably impacted the 

Biscayne Aquifer already, The cooling canals' continuing problems with salinity, temperature 

increases, and algae blooms reveal the difficulties of operating a power plant at Turkey Point 

while minimizing environmental damage, and FPL's requests to divert large amounts of 

freshwater to Turkey Point come within the context of a region that currently lacks sufficient 

freshwater resources for Everglades restoration and faces a diminishing supply for public 

consumption. Since FPL has not stated that it intends to replace the existing reactors with the 

new reactors contemplated in this application, it is likely that placing additional reactors at the 

site will only constrain efforts to resolve these issues. (0456-6 [Miami, City])

Comment: During 2014 the NRC granted a FPL request to continue operating reactor units 3 & 

4 when cooling discharge temperatures exceeded 100 degrees Fahrenheit. This was a 

combination of newly increased up rating of power on reactor units 3 & 4 to 2644MWt each, and 

high ambient temperatures. Ambient air temperatures is a combination atmospheric conditions 

and the localized waste heat sources in the vicinity ~6.6GWt range. With the proposed addition 

of units 6 and 7, thermal waste dissipation on site will increase to ~11 GWt (peak) for a period of 

at least ten years until reactor units 3 and 4 are finally retired. This extra atmospheric thermal 

energy will further decrease the evaporation and the cooling ability of the 5,800 miles of cooling 

canals which support NG/Oil Units 1,2 and Reactor Units 3, 4. (0545-3 [Keating, Tim])

Comment: What dangerous pollutants will escape in the cooling water to the bay? (0550-4 [H., 

Pat])

Comment: Problems with cooling ponds at the existing Turkey Point 3 and 4 reactors have 

already led to unprecedented use of freshwater by those plants as they attempt to reverse the 

toxic salinity the plants already introduce into Biscayne Bay. The water cycle in South Florida 

simply cannot afford the demands of four nuclear plants and the NRC cannot permit their 

radioactive effluents to be released in such close proximity to local drinking water supplies as 

the Turkey Point siting would require. (0615-3-3 [Bethune, David])

Comment: The NRC acknowledges the hydraulic connection between the cooling canal 

system (CCS)/industrial wastewater facility (IWF) and the hydrologic complex, especially during 

the tidal cycle (page 2-46) and states, "Recently, the IWF has experienced algal blooms, 

Appendix E October 2016 E-165 NUREG–2176
increased water temperatures, and increases in concentrations in salinity and nutrients. The 

precise cause of this anomaly is not understood at this time." However, the FEIS should further 

evaluate whether the overheated water in the canal, with increased nutrients due to 

concentrations resulting from evaporation, contributed to the formation of the algal blooms. EPA 

is concerned regarding the interconnection of the IWF, Biscayne Aquifer and Biscayne Bay. 

NRC acknowledges this connection when it states, "Hydraulic heads in monitoring wells near 

Biscayne Bay fluctuated in response to tidal cycles indicating a potential for tide-induced flow 

between the bay, shallow groundwater and the cooling canals in this area of the IWF"." (page 2-

68.) On page 2-69, NRC also discusses a FPL study that examines the dynamic processes 

between the IWF, surface water and groundwater as it is related to water quality, but does not 

discuss the results of that study. NRC also discusses a required monitoring study of the IWF to 

evaluate the "horizontal and vertical hydrologic exchanges with the surrounding environment". 

EPA requests that the NRC better describe the existing condition of the current operations of 

Units 3 and 4, and related water quality impacts, in the FEIS. EPA also understands that the 

IWF is used for the existing nuclear reactors (Units 3 and 4), and that cooling water from the 

new units 6 and 7, will use reclaimed water from MDWSD, and the blowdown from the cooling 

tower will be discharged into the Boulder Zone via UIC wells. (0617-1-14 [Mueller, Heinz J.])

Comment: The DEIS discusses operational surface water quality impacts associated with the 

IWF {page 5-19, 5.2.1.4). The DEIS individually examines the surface water quality impacts 

associated with excavation dewatering, stormwater discharge, muck spoil runoff and drift 

deposition. However, the DEIS does not holistically and additively analyze these additional 

stresses to the IWF. Also, the NRC does not discuss these additional wastewater stresses to 

the IWF and potential impacts to the underlying groundwater. (0617-1-16 [Mueller, Heinz J.])

Comment: The DEIS states that FPL intends to place the construction dewatering water into 

the cooling canals. Other information indicates that dewatering water and other wastewaters 

generated during construction will be injected via a Class I injection well permitted by FDEP 

(page 4-30). This needs to be clarified in the FEIS. Estimated discharges from these waste 

streams would be 1200 gpm, or I.73 mgd, of discharge into the IWF for approximately 1 year 

(page 3-23). The DEIS does not discuss the composition of the constituents in the wastewater. 

FPL also intends to drain all of the new facilities' stormwater discharge into the IWF (pages 3-8 

and 3-27). On page 4-36 (4.2.3.1), NRC also states, "Because the transport of sediment in the 

stormwater runoff from the disturbed area would be minimized by the use of the BMPs, and 

controlled by a stormwater-retention basin, the effects of offsite water quality are expected to be 

minor." The DEIS discusses volumes and potential pollutants of stormwater and wastewater to 

be placed in the IWF (page 5-19); however, the document did not discuss the types of 

stormwater retention basins and other best management practices (BMPs). The FDEP permit 

does not include information regarding possible BMPs. Additionally, FPL intends to place 

dewatering wastewater in the IWF as well. The NRC considered impacts of the excavation 

dewatering activities (4.2.3.2, page 4-37), but in relationship to inflows caused by excavation 

dewatering, and relationship to outflows due to the cooling canals canal seepage (mass 

balance). (0617-1-19 [Mueller, Heinz J.])

Comment: We appreciate your efforts to minimize project impacts for the proposed Units 6 and 

7 by using reclaimed wastewater from the Miami-Dade Water and Sewer Department (MDWSD) 

treatment system as cooling water, with the alternative source being groundwater supplied from 

horizontal radial collector wells installed in the Biscayne Aquifer on the Turkey Point peninsula. 

The lateral collector wells would extend up to 900 feet from the central caisson beneath 

Biscayne Bay (page 3-25). We appreciate the plans to avoid releasing blowdown to surface 

water bodies. However, based on the EPA's review of the DEIS, there are a number of serious 

Appendix E NUREG–2176 E-166 October 2016
concerns regarding the direct, indirect and cumulative impacts of this project, and further 

information and clarification is needed. (0617-1-2 [Mueller, Heinz J.])

Comment: EPA also recommends that the NRC consider and evaluate the additive impacts of 

the additional wastewater discharges (excavation dewatering, stormwater runoff activities, muck 

spoil runoff and drift disposition) into the IWF as a result of constructing the new reactors (Units 

6 and 7), specifically as it relates to the hypersalinity plume and Biscayne aquifer and 

associated drinking water wells. (0617-1-21 [Mueller, Heinz J.])

Comment: Recommendations: Page 2-45 of the DEIS states that the cooling canal 

system/industrial wastewater facility " ... is a closed-cycle cooling system, but is not a closed 

hydrologic system." EPA notes that since this is not a closed cycle hydrologic system, and 

therefore the FEIS should include a more in-depth discussion relating to the cumulative impacts 

associated with the hydrologic complex. The FEIS should include a water balance calculation 

for the site that shows all the potential sources of water supplying the site, and discharges and 

other releases from the site under normal operating conditions. This balance should include 

seepages from the canal system and changes in evaporative losses (e.g., changes in thermal 

load due to projected completion of the conversion to synchronous condenser mode for Units 1 

and 2). Additionally, the FEIS should discuss the releases or seepages from the Industrial 

Waste Facility (IWF). Specifically, the FEIS should document the presence of any direct 

releases from the IWF to the surrounding surface waters via breaches in the berms. (0617-1-4

[Mueller, Heinz J.])

Comment: Indirect and Cumulative Impacts. Several potential cumulative and indirect project 

impacts are of particular concern at Turkey Point, particularly radionuclides in surface water and 

groundwater, along with hypersalinity. Also, issues related to all nuclear power plants, including 

spent nuclear fuel storage, transportation and disposition, and groundwater monitoring for 

radionuclides, will require continued monitoring as the project progresses. The existing unlined 

Industrial Waste Facility (IWF)/Cooling Canal System (CCS) for Units 3 and 4 has issues 

regarding radionuclides and hypersalinity releases to the aquifer complex. Increasing water 

withdrawals from the canals, combined with additional groundwater withdrawals, could result in 

changing the level of the groundwater complex in the area surrounding the open interval of the 

withdrawal wells, eventually resulting in surface water impacts. EPA is concerned regarding the 

proposed project's potential for cumulative impacts on the migration of the existing hypersaline 

plume, particularly since the quantity of water in the cooling water canals will increase as a 

result of this project. EPA is especially concerned with ensuring the protection of public drinking 

water wells located to the west. Therefore, as a result of the proposed changes, further 

migration of the hypersaline plume is expected, and there is likely to be an increase in the rate 

of westward migration, increasing the potential for contact with offsite wells. EPA has concerns 

regarding the adjacent Biscayne Bay and the surrounding terrestrial environment, particularly 

that operation of additional units could potentially contribute to existing issues, and thereby 

increase cumulative impacts and environmental stressors. EPA has concerns that historical 

operating conditions at the site, combined with future construction and operation of new units, 

could result in increased saltwater intrusion, increased levels of radionuclides in water, and 

proximity of a hypersaline plume and sole source aquifer impacts. Recommendations: The 

FEIS should evaluate the environmental stressors, in their entirety, on the ecosystem 

surrounding Turkey Point. The potential impacts of current operations, combined with future 

groundwater withdrawals needed for construction and operation of the facility, should be fully 

evaluated, and impacts should be avoided to the maximum extent feasible. The issue of impacts 

on water supply wells should be thoroughly evaluated and discussed in the FEIS. The westward 

movement of the plume as a result of continued use of the cooling water canals should be 

Appendix E October 2016 E-167 NUREG–2176
projected through predictive modeling extending through the expected operation of the project. 

The project team should explain what steps will be taken to monitor and protect drinking water 

supplies in the event that the hypersaline plume encounters a public water supply well.

(0617-4-10 [Mueller, Heinz J.])

Comment: Monitoring and Adaptive Management. EPA is concerned about the numerous 

environmental issues and sustainability related to the project, particularly the current operations 

of the IWF. The development of the hypersalinity plume, the recent uprate waiver for salinity and 

temperature, and pumping of water from the L31E canal and other sources to the IWF cause 

concern that the IWF may not be ecologically viable in the long term. EPA is concerned that the 

need to place additional water into the IWF in order for it to remain functional is not a long term 

solution, since the IWF is needed for the proposed project. EPA is particularly concerned 

regarding the drainage of Unit 6 and 7's construction and post-construction stormwater into the 

existing IWF, especially considering the numerous issues related to the current operations of 

the IWF. Given these uncertainties, as well as uncertainties related to climate change 

(especially increases in storms and sea level rise, operations of the RCW, and possible 

exacerbation of the hypersalinity plume), EPA believes that a monitoring and adaptive 

management plan is needed to prepare for any future, unforeseen environmental issues related 

to the construction and operation of Units 6 and 7. Therefore, EPA requests that NRC and 

USACE (with resource agency collaboration) develop a robust monitoring and adaptive 

management plan. Recommendations: EPA recommends that NRC and USACE develop a 

monitoring and adaptive management plan with collaboration from resource agencies, and other 

stakeholders, for inclusion in the FEIS. Further, EPA recommends NRC and USACE commit to 

the implementation of the monitoring and adaptive management plan in the Record of Decision 

(ROD). (0617-4-13 [Mueller, Heinz J.])

Comment: 2) Evaluation and Analysis of the Extended Operation of the RCW 

The NPS is concerned about the potential for adverse impacts to park resources from continued 

and extended operation of the RCWs, particularly operating scenarios involving either the 

combination of RCW water with the primary wastewater supply or using RCW water in place of 

reused wastewater for the primary source of cooling. It is reasonably foreseeable that future 

wastewater supplied for reuse by Miami-Dade County may have unforeseen limitations. For 

example, sea-level rise and saltwater intrusion could decrease the availability and raise the cost 

of this water supply - a risk that was not assessed in the DEIS. As stated in the DEIS (page 3-9, 

lines 1-9), FPL intends to use RCW water in combination with wastewater or as a replacement 

for wastewater should it become less available or unavailable in the future. More specifically, 

the NPS is concerned that the DEIS does not contain information to evaluate whether the 

operation of the RCW could draw the subterranean hypersaline plume further eastward into 

Biscayne NP. 

Although the model spatial resolution may be too coarse to describe local impacts, results 

indicate the potential for RCW operation to affect the regional hydrologic system within the 

boundaries of Biscayne NP and Biscayne Bay Coastal Wetlands (BBCW) restoration project. 

The model report shows that continuous pumping scenarios yielded year round effects on water 

stages and salinity, especially to the northwest of the RCW site. In addition, all USGS model 

scenarios of RCW effects assumed that waters within the IWF, also known as the cooling canal 

system, had a constant salinity of 65 psu. Recent IWF salinity, following implementation of the 

uprate of Units 3 and 4, has risen to 90 psu and FDEP recently ordered actions (water additions 

to the IWF) to decrease salinity to 35 psu. Such action will increase head pressure difference 

and decrease the salinity and density difference between IWF and Biscayne Bay waters, 

Appendix E NUREG–2176 E-168 October 2016
possibly increasing RCW operational influence on transporting water from the IWF waters 

toward the bay which in tum could affect resources of Biscayne Bay NP. 

The NPS recommends that additional scenarios that extend the period of RCW operation and 

that vary IWF stages and salinity should be assessed with an appropriately scaled model to 

quantify this uncertain risk to Biscayne NP. This analysis should include an adequate 

assessment of how these operations could affect freshwater availability for current and future 

BBCW restoration projects. (0622-1-3 [Austin, Stan])

Comment: Extended Operation of the RCWs[.] The NPS is concerned about the potential for 

adverse impacts to park resources from continued and extended operation of the RCWs, 

particularly operating scenarios involving either the combination of RCW water with the primary 

wastewater supply or using RCW water in place of reused wastewater for the primary source of 

cooling. More specifically, the NPS is concerned that the DEIS does not contain information to 

evaluate whether the operation of the RCW could draw the subterranean hypersaline plume 

further eastward into Biscayne NP. The NPS recommends that additional scenarios that extend 

the period of RCW operation and vary IWF stages and salinity should be assessed with an 

appropriately scaled model to quantify this uncertain risk to Biscayne NP. (0623-3 [Austin, Stan])

Comment: We must consider the cumulative impacts of the water use with what's happening 

on the ground with 3 and 4. And if that's not in an EIS then, unfortunately, you need to do a 

supplemental EIS. (0721-10-4 [Reynolds, Laura])

Comment: I want to talk briefly about fresh water. I think that the radial canals will not work 

properly. I think we need to look at the salt water plume that's underneath Biscayne Bay and in 

the area there[.] (0721-13-6 [Martin, Drew])

Comment: [We need to look at] the extreme salinity that's been caused, and I think these 

problems will continue. (0721-13-8 [Martin, Drew])

Comment: Already there's a algal bloom that's expanding uncontrolled from the cooling canal 

that's already existing at the Turkey Point site and the expansion of Turkey Point has the 

potential to further impact those regional water resources. The proposed radial collector wells 

which stretch underneath Biscayne Bay and would require as much as 7.4 billion gallons of 

water a year. To put that into perspective, the entire Florida Keys uses just over 6 billion gallons 

of water a year. That's over a billion gallons of water more than the entire Florida Keys.

(0722-7-3 [Silverstein, Rachel])

Response: The IWF (also called the cooling-canal system) is not a feature of the design of 

proposed Units 6 and 7. The IWF provides cooling for Units 3 and 4. The IWF also previously 

provided cooling for Units 1 and 2, both of which have been converted to function to stabilize the 

grid and no longer generate power. To the extent comments relate solely to the current state of 

the IWF and its operation in connection with the existing Turkey Point units, the comments fall 

outside the scope of the EIS, which is the environmental impacts of the proposed new 

units. Nonetheless, the IWF is a feature of the site on which Units 6 and 7 are proposed to be 

constructed and operated. In describing the environmental setting for the proposed action, the 

review team disclosed that construction and operation of the IWF has affected the quality of 

shallow groundwater and the Biscayne Bay. Nothing in recent events has significantly altered 

the review team’s understanding of the IWF. As discussed in the EIS, potential effects on the 

IWF from building and operating proposed Units 6 and 7 are very limited. These include effects 

resulting from: 1) discharge of groundwater from excavation dewatering and storm water to the 

Appendix E October 2016 E-169 NUREG–2176
IWF while building the plants, 2) runoff to the IWF from muck added to the berms, and 3) 

cooling tower drift deposition landing on the IWF. Analyses presented in the EIS show that 

these changes are expected to result in minor changes to the water levels or chemistry of the 

IWF. The EIS acknowledges that operation of the proposed RCWs installed beneath the 

Biscayne Bay could move hypersaline water from the IWF toward the RCWs. Any increase in 

volume and concentration of the seepage from the IWF to the underlying portion of the Biscayne 

aquifer is not expected to have a noticeable impact on the quality of groundwater in the areas of 

the Biscayne aquifer that meet USDW criteria for TDS. After publication of the draft EIS, 

because of potential changes in the future environmental baseline, the review team performed 

additional groundwater modeling of the interaction between the planned RCWs, the existing 

hypersaline plume, and the IWF using a two-dimensional cross section model and a limitedextent three-dimensional model. These simulations were performed to determine whether the 

postulated changes in the environmental baseline would alter the review team’s findings from 

the draft EIS regarding the effects of RCW pumping. The effects of climate related sea-level 

rise were also simulated. Model results were added to the Section 5.2 of EIS and details of the 

modeling and results are presented in EIS Appendix G. 

Comment: 3) Evaluation of Water Quality Impacts and Associated Cumulative Impacts 

from the IWF 

The NPS is concerned that the DEIS does not fully analyze water quality impacts to NPS 

resources, especially cumulative impacts associated with the IWF. Recent developments 

relating to the operation of the IWF and subsequent environmental concerns were not analyzed 

in the DEIS. The hyper-salinity and temperature in the IWF, including the use of regional system 

water under recent orders and actions now underway to address this issue, must be evaluated 

as part of the past, present and future cumulative impacts. These recent actions of increased 

withdrawals from the regional system have currently decreased the amount of freshwater going 

to Biscayne NP and Biscayne Bay. This information should be included in a revised DEIS along 

with appropriate adjustments to impact assessments that include this updated baseline 

condition. Additionally, the levees surrounding the IWF are relatively low in height. Therefore, 

the transport of high salinity and high temperature IWF water into Biscayne NP and Biscayne 

Bay with sea level rise and storm conditions should be considered in an updated analysis 

related to the effect of anticipated sea level rise. 

We are concerned that operation of the RCWs has the potential to affect the salinity of Biscayne 

Bay. Ecological responses to salinity depend upon both the magnitude and variability of salinity 

exposure. The CERP is attempting to restore both of these components by decreasing high 

salinity peaks in the dry season and changing the seasonal timing of low salinity (extending low 

salinity well into the dry season, and decreasing harmful rapid drops in salinity). For BBCW, 

there is particular focus on salinity in the near-shore zone within 500 meters of the shoreline, 

where hypersalinity and high variability occur. The modeling in the DEIS demonstrated that 

RWC operations influenced salinity at a broad spatial scale. However as described previously, 

modeling salinity variability at a finer scale would provide more insight into localized potential 

ecological effects in southern Biscayne Bay. For these reasons, the NPS recommends that 

additional modeling be conducted to include more recent salinity data, assumptions concerning 

redistributed freshwater flow into the park as a result of the BBCW Project, and at an 

appropriate scale to determine the extent to which RCW operations will effect salinity changes 

and have potential adverse impacts to resources in near-shore coastal waters of Biscayne NP. 

The DEIS concludes that changes in the hydrology and chemistry of the IWF caused by 

construction of Unit 6 and 7 will not impact Biscayne NP and Biscayne Bay. We have concerns 

Appendix E NUREG–2176 E-170 October 2016
regarding the methodology used to draw this conclusion and how pulses of nutrients and 

dissolved organic matter from dewatering and stored muck could potentially move toward the 

bay, thereby increasing the risk of near-shore algal blooms. Our concerns regarding the impact 

of Units 6 and 7 construction activities are now heightened by changes in IWF hydrologic 

management. These construction activities, when combined with planned freshwater or brackish 

water additions from canals and the Florida aquifer, intended to decrease IWF salinity, will raise 

water levels in the IWF. This will change both head and density differences among water 

parcels of the IWF, groundwater, and bay water, changing patterns of advection and dispersion 

and associated water quality risks. This scenario was not evaluated in the DEIS. The NPS is 

concerned that these changes in water levels, combined with nutrient and other material inputs 

from construction, will significantly increase the risk of industrial waste water and materials 

being transported or dispersed into adjacent Biscayne NP and Biscayne Bay, consequently 

increasing the risk of ecological impacts. (0622-1-4 [Austin, Stan])

Response: The review team demonstrated that the impacts of changes in water chemistry 

from dewatering and leaching of the muck piles is expected to be small and within the normal 

range of variability in the IWF. The review team also computed the impact of an unrealistically 

conservative bounding release of the nutrients to Card Sound and Biscayne Bay and also 

determined they were within the range of typical variability. 

Construction activities would require temporary dewatering of areas below the water 

table. Pumps would remove the water from these holes and discharge it into the IWF. To 

minimize the amount of water that needs to be pumped, barriers would be used around the 

holes. Because the IWF and Mud Island are hydraulically connected, there is no net change in 

water volume. Removal of muck to allow placement of fill material that would raise grade for the 

plant would result in saturated muck draining. Again this results in no net change in the water 

volume, but it could make nutrients and other chemicals that would drain into the IWF more 

available. Once the dewatered muck is piled on the berms, nutrients and chemicals can 

continue to be leached by rainfall and enter the IWF. Technologies implemented as Best 

Management Practice (BMPs) for managing dewatering and leaching problems are mature and 

reliable. FPL also has the unique option of possibly using the UIC system to dispose of nutrientladen dewatering drainage, and leachate at the Turkey Point site. The review team was 

advised by SFWMD that there was nothing about the Turkey Point site that would suggest that 

the existing suite of available BMPs would not be sufficient. 

The review team acknowledges that operation of the RCWs would decrease the piezometric 

head in the vicinity of the RCW and cause increased lateral movement to the east of the 

hypersaline plume underneath the IWF (assuming the remediation of the hypersaline plume 

under the Consent Agreement is unsuccessful). However, without an upward impelling force, 

the hypersaline plume would remain well below the bay floor. The review team has not been 

able to identify any credible upward impelling force that would offset the tendency of the denser 

hypersaline water to sink. 

Comment: The Turkey Point units 6 & 7 fails to address the toxicity of the drift from the cooling 

towers if chemical-laden municipal wastewater is used to cool the reactors. There is no analysis 

of the chemical reaction products and the chemical decomposition products that would form 

when the wastewater is heated. These unknown products would then be dispersed over the 

land and water via the cooling towers. There has been no environmental impact analysis of this 

random dispersal of completely unknown chemicals. (0054-1 [Kasenow, Lisa])

Appendix E October 2016 E-171 NUREG–2176
Comment: Comment 8. The DEIS is incomplete because it gives no context for 

evaluating the safety of the chemicals projected to be released. Nor does it show 

quantitative mapping of aerosol accumulation, though the data are probably available. 

Specifically, the DEIS does not list safe accumulation levels for the list of chemicals that 

will be released as aerosols, nor does it compare the projected levels to the safe 

accumulation levels - Cooling water will be evaporated in cooling towers with blowdown 

preventing escape of most aerosols. Nonetheless, some aerosols will escape the towers and 

blow out across Biscayne National Park and the coastal Everglades on the prevailing winds: 

"Small droplets of water (drift) and salt particles would be emitted from the cooling towers during 

operation. For the Turkey Point Units 6 and 7 combined drift rate from the circulating-water 

system and service-water system towers the expected maximum drift rate would be 

approximately 8 gpm (Table 3-6)." [DEIS p. 5-9] The DEIS projects 4,207,680 gal/year aerosol 

drift, and a 4 year accumulation cycle. Dispersion models predict a non-uniform distribution of 

aerosols across the region, with greater accumulation near the plant. Thus, use of reclaimed 

wastewater will introduce myriad waste chemicals into the nearby reaches of Biscayne Bay and 

the Southeast Coastal Everglades. The DEIS gives no context for evaluating safety of the 

chemicals to be released. It lists projected amounts, but does not provide other key information. 

Absent are diagrams showing how fallout varies over the area. Likewise absent are safety data 

to evaluate the possible effects of chemicals that accumulate. What are the safe accumulation 

levels? While soluble chemicals like chloride might reach saturation after 4 years time, the same 

is not true for hydrocarbons and metals that bioaccumulate. They may continue to concentrate 

in the ecosystem for longer, reaching greater concentrations over periods longer than four 

years. The final EIS must better estimate accumulation levels and better detail spatial 

distribution of listed wastewater chemicals released as aerosols and compare those 

levels to levels shown safe for aquatic organisms. (0106-11 [Stoddard, Philip K.])

Comment: Your choice of locating two nuclear reactors at Biscayne and Everglades National 

Parks are at risk for using 90 million gallons per day of recycled Miami-Dade County sewage 

and wastewater which will not be pure H2O and will be released over Biscayne Bay and 

surrounding wetlands along with steam in the planned cooling towers. (0153-1 [Goldman, 

Emanuel])

Comment: The EIS also fails to analyze impact of particulate drift from the nuclear cooling 

towers. The impact cannot be known at this time because the chemical content of the drift is 

unknown. (0200-1 [Kasenow, Lisa])

Comment: The powerful new reactors (1,117 MW each) are to be cooled primarily by 90 

million gallons per day of recycled Miami-Dade County sewage and wastewater. This water will 

not be pure H2O - and some will be released over Biscayne Bay and surrounding wetlands 

along with steam in the planned cooling towers. (0240-3 [Commenters, Multiple])

Comment: The draft EIS also omits any analysis of the chemical constituents of the 

aerosolized effluents as well as any modeling of the synergistic effects of adding two new plants 

a site which has already reached unacceptable levels of fresh water use. Furthermore, the draft 

EIS neglects any study of the impact of the radial collector wells on the salinity of the waters of 

Biscayne Bay National Park, an irreplaceable environmental resource. (0615-3-5 [Bethune, David])

Comment: References to the State of Florida Site Certification Process[.] The NPS 

recommends that the hydrology and ecology sections in the DEIS be strengthened by including 

references to important documents from the State of Florida Site Certification Process, 

especially as it relates to the cooling tower plume issue. We also encourage the NRC to draw 

Appendix E NUREG–2176 E-172 October 2016
from the extensive technical and scientific literature of the SFWMD who are the local sponsors 

of the C&SFP with the USACE and are the local experts on hydrology and water operations. 

They are also the primary water operations regulatory agency of the State of Florida. This 

extensive collection of materials is both peer reviewed and online and should be included in the 

DEIS. (0622-1-28 [Austin, Stan])

Comment: Release of Chemicals of Emerging Concern CCECs) 

The NPS has a number of questions/concerns relating to the release of CECs originating from 

reclaimed water and released via the operation of Units 6 and 7 onto the Turkey Point facility 

and into Biscayne NP and how they are analyzed in the DEIS: 

Page 5-10 

Lines 19-20: The DEIS states, "This conservative approach assumes no loss of contaminants 

via removal ..., biodegradation, or volatilization." Since biodegradation of some 

compounds (e.g., 4-nonylphenol, triclosan) can result in more toxic compounds than the parent 

compound, we suggest that more information be included along with additional discussion of 

how biodegradation of contaminants are affected by drift deposition. 

Lines 30-31: The DEIS states that "... the review team first performed a screening-level 

assessment to identify chemicals and constituents likely to occur at ecologically relevant 

concentrations in both reclaimed water and Biscayne Bay seawater obtained from the RCW 

system." NPS requests an explanation of how the review team determined which chemicals and 

constituents were likely to occur at ecologically relevant concentrations; how these 

concentrations were determined; and how the review team determined which species and which 

endpoints to use for these ecologically relevant concentrations. Revisions to the DEIS should 

include an outline of the screening-level assessment process in addition to the information 

regarding these questions. 

Lines 41-44: The DEIS states, "...were compared to existing EPA freshwater and marine waterquality criteria, which are readily available for many compounds and believed to be protective of 

aquatic life." Were freshwater water-quality criteria applied to marine species if marine waterquality criteria were not available? Lines 22-25 on p.5-53 highlight this possibility. If this was 

done, the screening-level assessment needs to be conducted again since the toxicity of 

compounds are greater in seawater and brackish waters than in freshwater. 

Page 5-11, Table 5-1 contains footnote (c) that indicates the contaminant with the lowest 

environmental effect concentration. However, there does not appear to be a contaminant (or 

concentration) annotated with a (c) in the table. (0622-1-5 [Austin, Stan])

Comment: You think they can get them all out? No. That's going through the cooling towers. 

You think it's pure H2O steam coming out of there? No. Volatile gases mixed in with it plus 

droplets called drift. That drift contains the wastewater. Those are little tiny droplets of 

wastewater spreading out over Biscayne Bay, spreading out over your community, your children 

are going to be breathing that in. (0723-9-15 [Schwartz, Matthew])

Response: In Section 5.2.1.1 of the EIS, the review team disclosed that the chemicals in the 

reclaimed water include contaminants of emerging concern (CECs) and the review team has 

provided a representative calculation of the amount of the CECs available in the drift. The 

review team determined that the drift rate would be small (8 gpm); chemicals in the water 

Appendix E October 2016 E-173 NUREG–2176
treatment process may degrade; there is some potential for volatilization of CECs in the cooling 

towers, so they would not be deposited locally as drift; mixing and dilution would occur as the 

chemicals combine with other surface water bodies; and given the ubiquitous presence of 

chemicals in the environment, the projected alterations to the water quality would likely be 

undetectable. The review team employed conservative estimates of wet deposition based on 

air quality models applied consistent with NRC guidance. 

The review team disclosed the existence of CECs in the EIS and performed a conservative 

analysis to demonstrate the small amount of material being released to fully advise the 

public. NEPA does not require an encyclopedic characterization of all the possible CECs that 

may be in the reclaimed wastewater and even natural water bodies. As with any other 

constituent, if EPA changes existing standards or adds new standards such as for CECs, 

changes may be necessary in the future. 

Comment: Further, if the expansion of Turkey Point does occur, it could have profound and 

unacceptable environmental impacts to regional water resources, Biscayne and Everglades 

National Parks, wildlife, wetlands and threaten public health and safety. There are more 

affordable, less water-intensive ways for FPL to meet energy demand1 [Footnote 1: See 

http://www.cleanenergy.org/wpcontent/uploads/F_SACE_CleanenergysolutionstoTurkeyPtreactors_040915.pdf.] while 

protecting the environment and addressing climate change. (0112-2 [Barczak, Sara])

Comment: In the description of the affected environment there is an extensive discussion of 

the locational environment around southeastern edge of Everglades NP, however there is no 

description of Biscayne NP's watershed which is contiguous to the plant which would include a 

discussion of the surface and groundwater flow to Biscayne NP as well as the surface water 

operations contiguous to the plant site that affect the near shore coastal environment. The 

watershed to the west and northwest of the plant is the Central & Southern Florida Project 

canals, Miami-Dade County canals and the groundwater made up of the Biscayne Aquifer an 

unconfined aquifer. Together these components control the water level and water flow of this 

area and are responsible for the ecological structure of Biscayne NP and its adjacent wetlands. 

In turn, these systems are operated to accommodate the dense population of Miami-Dade 

County. (0622-1-29 [Austin, Stan])

Response: Section 9.2 of the EIS describes the review team's assessment of water usage by 

alternative energy systems water. The review team identified some energy alternatives that use 

less water than the proposed plant (e.g. combined cycle, and solar). However, given that the 

plant is using treated wastewater that would otherwise be immediately disposed by deep well 

injection, the review team determined that water use is not relevant as a determinate in this 

case. 

Comment: Likewise, limiting the analysis in the DEIS to only the proposed radial collector wells 

as a backup cooling system is not the "hard look" required by the National Environmental Policy 

Act ("NEPA"). This backup cooling system is easily one of the most concerning parts of the 

Turkey Point Nuclear Plant Units 6 & 7 application. Since the final Environmental Impact 

Statement must independently assess the impacts of the Environmental Report submitted by 

FPL, it should also consider other approaches to providing cooling water to the reactors. The 

DEIS has already accomplished this task for some of the inland alternative sites by assessing 

potential cooling systems other than those proposed. The final Environmental Impact Statement 

must do the same for Turkey Point. (0611-3 [Haber, Matthew S.])

Appendix E NUREG–2176 E-174 October 2016
Response: Alternative water sources for Turkey Point are discussed in Section 9.4 of the 

EIS. Withdrawal of water from marine sources, including Biscayne Bay, Card Sound, and the 

Atlantic Ocean (including locations such as the barge-turning basin or Card Sound Canal) was 

considered. Other surface-water sources, including the IWF cooling canals and offsite sources 

such as a new freshwater reservoir, were also considered. The review team considered several 

groundwater sources, including the Biscayne aquifer, the Upper Floridan aquifer, and the zone 

of the Lower Floridan aquifer that is commonly referred to as the Boulder Zone. None of these 

alternatives were environmentally preferable to the proposed water sources. No changes to the 

EIS were made based on this comment. 

Comment: Stormwater Management Design Event: NRC states the stormwater management 

system for the new plant area will be designed to handle a 25-year, 72-hour design storm event 

(Section 3.4.2. l, p. 3-30). Recommendations: EPA recommends NRC provided some 

supporting environmental information justifying the sufficiency of a 25-year, 72-hour design 

storm event for this facility in this area. As noted by NRC, the U.S. Global Change Research 

Program has determined that extreme heavy precipitation events are expected to increase in 

frequency and intensity. For example, an event that now occurs once in 20 years is projected to 

occur 2 to 3 times as often by the end of the century. Heavy precipitation events are expected 

to have a 20-percent increase in the amount of precipitation falling. While the number of tropical 

storms occurring around the globe will decrease, those that occur will be stronger in force, 

yielding more Category 4 and 5 storms. Rainfall rates associated with tropical storms are 

expected to be greater, " ... with projected increases of about 20 percent averaged near the 

center of hurricanes" (GCRP 2014-TN3472). (Appendix I, p. 1-3) (0617-4-2 [Mueller, Heinz J.])

Comment: Stormwater Management Cooling Canals: NRC states the storm water runoff will be 

directed to the existing cooling canals of the existing industrial wastewater facility. 

Recommendations: EPA recommends NRC discuss the impacts of heavy precipitation events, 

sea level rise, and storm surge on the existing cooling canals and their stormwater-management 

effectiveness and associated impacts to the affected environment. For example during the 

hurricane season of 2004, Hurricanes Frances and Jeanne created high-water surges of over 

18 feet (Section 9.3.2.4, p. 9-70). Reportedly, storm surge can range up to 20 feet and last a 

day in known extreme cases. [Footnote 2: Miami-Dade Sea Level Rise Task Force Report and 

Recommendations, July 1, 2014, available at 

heep://www.miamidade.gov/planning/library/reportsfsea-level-rise-final-report.pdf] Moreover, 

NRC qualitatively presumes the unlined cooling canals' water-surface elevation will rise in 

response to sea level rise (Appendix I, p.1-5). EPA recommends that the cooling canals' water 

elevations be analyzed in context of sea-level rise projections and the resulting impacts 

assessed. (0617-4-3 [Mueller, Heinz J.])

Response: Appendix I includes a discussion of stormwater management as related to climate 

change. Stormwater management is regulated by the EPA, and while the NRC discloses the 

impacts of storm water management in NRC EISs, the NRC does not intrude on the EPA’s 

decisions regarding nonradiological pollutant discharges into receiving waters. Additional 

information is available in Section E.2.32, in which the NRC responds to comments regarding 

climate change, and Appendix I, which includes the NRC analysis of climate change issues 

associated with the proposed action. The storm surge of 18 ft that was mentioned in one 

comment refers to the storm surge on the confined Lake Okeechobee and is not related to 

coastal storm surge at the proposed site.

Appendix E October 2016 E-175 NUREG–2176
Comment: The DEIS individually views the surface water quality impacts associated with 

excavation dewatering, stormwater discharge, muck spoil run off and drift disposition, but does 

not holistically and additively analyze these additional stresses to the IWF. Also, the DEIS does 

not discuss these additional wastewater stresses to the IWF, and potential impacts to the 

underlying groundwater. The DEIS notes that the impacts would be minor; however, it does not 

discuss possible impacts related to the hypersalinity plume. The EPA is concerned that these 

additional wastewater activities would further stress the IWF and potentially worsen the 

hypersalinity plume, cumulatively and adversely impacting the Biscayne Aquifer. We note that 

additional waters will be added to the IWF to address the heating and hypersalinity issues, 

however, the extent to which the additional waters will alleviate the hypersalinity levels in the 

plume is unclear. Recommendations: The FEIS should clarify whether remediation measures 

are planned to remedy the serious issues that exist with hypersalinity migration. Also, the FEIS 

should provide more detail regarding the dewatering and stormwater activities (including types 

of pollutants, volumes, types of BMPs and stormwater-retention basins). (0617-1-20 [Mueller, 

Heinz J.])

Response: The review team is aware that regulatory actions by state and county agencies 

have been undertaken to mitigate the inland migration of the hypersaline plume. The staff has 

updated the EIS to include a discussion of these in Section 2.3. The review team also included 

discussion in Sections 5.2, 7.2, and Appendix G to explain modeling performed to confirm that 

the review team's conclusions in the draft EIS would not be changed as a result of these new 

actions. 

Comment: There are instances in the DEIS where the DEIS characterizes the stormwater 

would be "discharged" into the industrial wastewater facility (IWF). FPL's ER uses the terms 

"routed" or "released" due to FPL's National Pollutant Discharge Elimination Permit. For 

example ER Subsection 3.6.3.2 states: "Stormwater would be routed to the industrial 

wastewater facility." Additionally, ER Subsection 4.2.1.1.3 states, "During construction, surface 

water runoff would be released to the industrial wastewater facility. Instances in the DEIS 

include (emphasis added): a. Appendix F-2, Section 2.1, Page 2-2, Lines 1-2: Appendix F-2: 

"Eventually, stormwater would be discharged into nearby canals of the existing industrial 

wastewater facility (IWF)." b. DEIS Appendix F-3, Section 2.0, Page 2-1, Line 23: Appendix F-3 

states: "Stormwater would then be collected and discharged into nearby cooling canals of the 

existing industrial wastewater facility (IWF)." c. DEIS Appendix F-3, Subsection 4.1.1.2, Page 4-

3, Lines 7-8: Appendix F-3 states "Water or effluent associated with RCW construction would be 

discharged into the IWF and not directly released into nearshore areas." d. DEIS Appendix F-3, 

Subsection 4.1.1.2, Page 4-3, Lines 14-15: NFMS BA states, "This water, and other effluents or 

stormwater associated with construction activities, would be discharged into the IWF."

(0619-1-15 [Maher, William])

Response: The review team understands that the term “discharge” has a specific meaning 

under the Federal Water Pollution Control Act, commonly referred to as the Clean Water 

Act. The review team revised the use of term discharge to avoid confusion with National 

Pollutant Discharge Elimination System (NPDES) permit process designations under the Clean 

Water Act. 

Comment: To enlarge the plant and contaminate the bay waters would be wrong! (0368-1

[Casey, Sr., Robert J.])

Comment: Some of the water that cools the reactors could be released over Biscayne Bay and 

surrounding wetlands along with steam in the planned cooling towers. (0537-3 [Anonymous, Judi])

Appendix E NUREG–2176 E-176 October 2016
Comment: [F]ind other ways of recycling sewage and wastewater. Releasing sewage and 

wastewater over Biscayne Bay will destory the welands and also the reason people come to 

visit, clean water and beaches. DON'T MAKE THIS AREA A GIANT CESSPOOL! (0630-2

[Montalvo, Stephanie])

Comment: The hot water that will be released as a result of cooling, the nuclear waste that we 

have no way of safely dealing with, the electrical lines that will kill birds and mar the beauty of 

the landscape make it an unacceptable plan. (0635-3 [Seiman, Rhonda])

Response: The majority of the treated wastewater would be evaporated in the cooling towers, 

and the residual (blowdown) would be injected into the deep Boulder Zone, as is common for 

wastewater in South Florida. The only pathway for wastewater to enter the landscape would be 

from drift from the cooling towers. The review team assessed this in Section 5.2 of the EIS and 

determined the changes from the cooling towers would be undetectable. No changes to the EIS 

were made based on this comment. 

Comment: According to the Draft Environmental Impact Statement, the cooling towers for 

proposed Reactors 6 and 7 will deposit an average of 50 million gallons a day of radioactive salt 

water as aerosol for 60 days a year[.] (0721-12-2 [White, Barry J.])

Response: The only radioactive material in the drift would be that already in the treated 

wastewater. The design of the reactor does not transfer radiation to the water that can become 

drift. The daily drift rate would be 11,520 gpd not the 50,000,000 gpd the commenter 

states. No changes were made to the EIS based on this comment. 

Comment: This [renewable energy] would save the people money on future electric bills and 

begin to mitigate climate change and the rising sea levels that already are impacting Key West 

and Miami Beach (both of which flood during King high tide and full moon events). I have been 

called several times as a Miami Beach firefighter to pump out and squeegee peoples homes 

during these events. (0718-5 [Buechler, Jerry])

Response: Climate change and sea-level rise are discussed in Appendix I and alternative 

energy systems are discussed in Section 9.2. No changes were made to the EIS based on this 

comment. 

Comment: The most dangerous scenario for Turkey Point is also the most likely to occur, an 

extended station blackout combined with extensive site flooding due to a hurricane. Although 

extended station blackout and storm surge flooding have taken place at Turkey Point already 

and are expected to continue or even increase in the future as a result of climate change, the 

draft EIS fails to examine any aspect of this site-specific scenario. (0615-2-27 [Bethune, David])

Comment: Point is 25 feet above sea level. Access roads are at approximately 14 feet. The 

rest of Miami-Dade County is at pretty much sea level. Any storm surge of just 2 or 3 feet would 

not allow access to the plant. No access to the cooling canals or the plants could cause a 

potential meltdown. (0721-5-4 [Mendez, Victoria])

Response: The NRC staff documents their review of the applicant's safety assessment in the 

Safety Evaluation Report. This review considers discussion of storm surge and sea-level rise in 

Section 2.4. Also, the proposed units do not rely on the cooling canals for any safety function; 

rather, in the event normal cooling is lost, the AP1000 design provides safety-related cooling 

through passive means, including water stored in tanks onsite. These tanks need not be refilled 

Appendix E October 2016 E-177 NUREG–2176
for 72 hours from the time normal cooling is lost. No changes were made to the EIS based on 

this comment. 

Comment: The project components most relevant to FKNMS include the filling of 1,000 acres 

of wetlands for construction of the Units 6 and 7 and related infrastructure, the location and 

materials placed in Spoils Area B, and the impacts of building and operating radial collector 

wells. Impacts from these project components may include sediment and nutrient run-off and 

hypersaline and hyperthermal water quality conditions. These adverse impacts will most directly 

affect the aquatic resources and water quality of Biscayne Bay, Card Sound and vicinity; 

however, there could be downstream impact on FKNMS resources. FKNMS regulations (15 

CFR 922.163(a)(4)(ii)) prohibit discharging or depositing, from beyond the boundary of the 

Sanctuary, any material or other matter that subsequently enters the Sanctuary and injures a 

Sanctuary resource or quality. Therefore, FKNMS recommends reviewing these project 

components to ensure that impacts to aquatic resources and water quality are adequately 

addressed. (0618-1 [Morton, Sean])

Response: The topics discussed in this comment regarding the Florida Keys National Marine 

Sanctuary (FKNMS) were addressed in Sections 4.2 and 5.2 of the EIS. Based on information 

that became available after publication of the draft EIS, the review team has also updated and 

expanded the discussions in Sections 2.3, 4.2, 5.2, and Appendix G. 

Comment: In early 2015, FPL announced the change of the commercial operation dates 

(CODs) for Units 6 & 7 from 2022 and 2023 to 2027 and 2028, respectively. A new and 

significant information review was conducted by FPL where it was concluded that there would 

not be an impact to any significance level or conclusion drawn in the ER with respect to the 

change in CODs. There are instances in the DEIS, however, where references to CODs differ 

from the newly announced CODs. Instances in the DEIS include:...DEIS Appendix I, Section I.2, 

Page I-2, Lines 32-42: In DEIS Appendix I.2, the DEIS states: "Florida Power and Light 

Company (FPL) has indicated that, if the COLs are granted, it expects to initiate commercial 

operations in the third quarter of 2022 and third quarter of 2023 for Units 6 and 7, respectively 

(FPL 2014-TN4058)... The review team considers use of GCRP impacts report projections for 

the 2071-2099 period under a continued increasing emissions scenario to be a conservative 

proxy for likely future conditions encompassing the licensing action, and for assessing the 

effects of climate change on the resource area impact levels presented in this EIS." (0619-1-8

[Maher, William])

Comment: There are instances in the DEIS where there are inconsistencies and/or 

discrepancies relating to authorizations, permitting and certifications. Instances in the DEIS 

include (emphasis added):...DEIS Subsection 5.2.3.1, Page 5-26, Lines 19-20: The DEIS states: 

"Wastewater from the sanitary and potable water systems would be discharged to the 

municipal sewer system." However, wastewater from these facilities will be discharged to the 

Boulder Zone via deep injection wells as described in ER Section 3.3: "This water would also be 

the source for potable water, the demineralized water system, fire protection, and miscellaneous 

water users. Effluents would be discharged to the Boulder Zone via deep injection wells 

permitted by the Florida Department of Environmental Protection (FDEP) underground injection 

control program." (0619-2-12 [Maher, William])

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 2.3.2.1, Page 2-

58, Lines 4-8 "For the local area, 32 permitted surface-water users...include landscaping, 

agriculture, industrial, and "(a golf course) (FPL 2014-TN4058). Landscape...largest number 

Appendix E NUREG–2176 E-178 October 2016
(31) of permitted users..." ER Table 2.3-25 ER Table 2.3-25 lists 34 surface water permits (31 

landscape, 1 agriculture, 1 industrial, 1 golf course). (0619-2-19 [Maher, William])

Comment: There are instances in the DEIS where there are inconsistencies and/or 

discrepancies relating to authorizations, permitting and certifications. Instances in the DEIS 

include (emphasis added):...DEIS Section 4.2, Page 4-25, Lines 39-40 and DEIS Section 5.2, 

Page 5-6, Lines 38-39: In both instances, the DEIS states: "Consumptive use of surface water 

and groundwater would require a permit from the FDEP or the water-management district." The 

consumptive use authorizations are part of the Conditions of Certification. (0619-2-9 [Maher, 

William])

Response: The review team has confirmed the information in these comments and corrected 

the EIS accordingly. 

Comment: There are instances in the DEIS where there are inconsistencies and/or 

discrepancies relating to authorizations, permitting and certifications. Instances in the DEIS 

include (emphasis added):...DEIS Appendix F-2, Section 1.0, Page 1-1, Lines 19-20 and DEIS 

Appendix F-3, Section 1.0, Page 1-1, Line 27-28: Appendix F-2 states: "The SCA process 

provides a certification that encompasses all licenses needed for appropriate Florida State, 

regional, and local agencies." (Nearly identical language is found in Appendix F-3 as cited). ER 

Section 1.2 states: "*Pursuant to the Florida Electrical Power Plant Siting Act (PPSA) all state, 

regional and local permits, except for certain local land use and zoning approvals and 

certain state issued licenses required under federally delegated or approved permit 

programs, are covered under a single "Certification"." h. DEIS Appendix F-3, Subsection 

3.1.1.1, Page 3-5, Line 24 and DEIS Appendix F-4, Subsection 2.3.4, Page 2-10, Lines 13-14: 

Appendix F-3 states: "FPL has proposed that RCW use would be limited to 60 days per year 

(FPL 2012-TN2688)." (Nearly identical language is found in Appendix F-4 as cited). Condition of 

Certification, Section B. VI. C.2.b.i.(3) states, "Licensee shall be authorized to operate the 

RCW system up to sixty (60) days and withdraw a maximum volume of 7,465 MG in any 

consecutive twelve (12) month period [equivalent to sixty (60) days at full capacity of 124.416 

MGD]." i. DEIS Appendix H, Table H-1: Appendix H, Table H-1 does not include the USACE 

Section 408 permit. However, ER Table 1.2-1 lists the USACE Section 408 permit (3rd item in 

the ER Table 1.2-1). j. DEIS Appendix H, Page H-5 to H-8, Table H-1: Appendix H, Table H-1: 

Federal, State and Local Environmental Permits and Authorizations, under "Description of 

Requirement" states the following were issued May 19, 2014 under Final Conditions of 

Certification: i. NPDES storm water operations permit for industrial activities ii. Exploratory well 

construction permit iii. UIC well construction permit (allows for the construction and operational 

testing of additional injection and dual zone monitoring wells). iv. Class I well operation permit 

v. Prevention of significant deterioration construction permit vi. Modification of Industrial 

Wastewater Treatment Facility permit vii. NPDES construction stormwater permit viii. Operation 

of Class V, Group 3 domestic wastewater injection (gravity flow) well ix. Title V Operations 

Permit - 0250003-010-AV x. Title V Operations Permit - 0250003-21-AV xi. Well Construction 

Permit ER Table 1.2-1, Authorizations for Turkey Point Units 6 & 7, states: "*Pursuant to the 

Florida Electrical Power Plant Siting Act (PPSA) all state, regional and local permits, except for 

certain local land use and zoning approvals and certain state issued licenses required 

under federally delegated or approved permit programs, are covered under a single 

"Certification". Because the Certification is the sole license of the state and any agency required 

for construction and operation of the proposed electrical power plant, it is not necessary to apply 

for permits individually." These permits are not issued as part of the Site Certification.

(0619-2-14 [Maher, William])

Appendix E October 2016 E-179 NUREG–2176
Response: Table H-1 in Appendix H has been modified to show the permit status provided by 

FPL in the ER. The documents in Appendix F are consultation documents submitted to the 

U.S. Fish and Wildlife Service (FWS) as part of ESA Section 7 consultation between the NRC, 

the USACE, and the FWS, and were not edited. 

Comment: DEIS Subsection 9.3.1.7, Pages 9-40 through 9-43, general comment: The DEIS 

discusses the alternative water supply scenarios analyzed by FPL for the three inland sites. 

Among the water supply features considered were a 3,000 acre reservoir to retain excess flow 

from the Kissimmee River/Lake Okeechobee system and a reverse osmosis groundwater 

treatment system to reduce cooling tower drift salinity to protect sensitive plant and animal 

communities from salt drift. On page 9-42, the DEIS states that the review team was "unable to 

confirm" (based solely on drift rates provided for the Units 6 & 7 cooling towers) that salt 

deposition would be sufficiently adverse to preclude the use of groundwater without reverse 

osmosis. This is inconsistent with FPL's analysis of salt drift impacts presented in the Turkey 

Point Units 6 & 7 Section 404(b)(1) Alternatives Analysis (DEIS Reference FPL 2011-TN1374 at 

63-64), particularly the differences in susceptibility of plant species in coastal compared to 

inland areas. Additionally, the DEIS review team assumed that increased groundwater use 

"could reduce or eliminate the requirement for a surface-water reservoir" and thus performed a 

water supply analysis configured without a surface-water reservoir or a reverse osmosis 

groundwater treatment system, and concluded the inland sites are not environmentally 

preferable to Turkey Point. FPL maintains, based on its consultation with the South Florida 

Water Management District (SFWMD) and its experience with the practicability of siting, 

permitting, and operating power plants in Florida, that these features would be required for 

these sites. FPL nonetheless recognizes that the DEIS analysis is conservative for the purpose 

of NEPA alternative sites analysis because its assumptions tend to underestimate the 

environmental impacts of the inland alternatives compared to the Turkey Point site. The DEIS 

also recognizes that the NEPA analysis performed by the NRC is "necessarily imprecise" and 

that any evaluation of a particular alternative site "must have a wide range of uncertainty" (page 

9-243). Therefore, FPL does not object to the DEIS excluding the reverse osmosis groundwater 

treatment facility and reservoir water supply impact assumptions. However, as the DEIS 

explains on page 9-43, there is significant uncertainty regarding whether a power plant could be 

sited at one of these three sites without surface water supply features. In light of other 

independent regulatory actions, the EIS should clarify that the assumptions regarding reverse 

osmosis groundwater treatment and onsite reservoirs are based on a reconnaissance-level 

NEPA review and do not represent a regulatory determination on their practicability. (0619-5-17

[Maher, William])

Response: As stated in the EIS, the staff acknowledges that there is considerable uncertainty 

regarding how the cooling system might actually be implemented if the plant were to be built at 

one of the inland alternative sites. The staff modified the text in Section 9.3.1.6 to further clarify 

that were such a plant to be built, State regulatory agencies may require actions to mitigate 

cooling system impacts, such as building a reservoir to store water or implementing reverse 

osmosis to reduce the impacts from cooling-tower drift. 

E.2.8 Comments Concerning Hydrology - Groundwater 

Comment: DEIS Appendix G, Section G.3.1, Page G-22, Paragraph 2: The DEIS states: "FPL 

completed the pumped well on the Turkey Point peninsula as an open borehole from 22 to 46 ft 

below ground surface and with cemented casing above that depth. They also completed five 

observation wells with the top of the open interval at a depth of 22 ft in each well, and the 

bottom of the open interval at depths varying between 41 and 46 ft." This discussion of the 

Appendix E NUREG–2176 E-180 October 2016
monitoring wells used in the aquifer pumping test is inconsistent with the description in the ER 

Subsection 2.3.1.2.2.3, page 2.3-30 and the cited reference (FPL 2009-TN1263). ER 2.3.1.2.2.3 

states 7 observation wells at distances of 925 ft to 2704 ft away from the pumped well.

(0619-7-17 [Maher, William])

Response: Although seven observation wells were completed, these were at five unique 

locations. Only four wells were used in the FPL analysis because no response was observed at 

the most distant well. To clarify, the text in Appendix G was reworded. 

Comment: DEIS Appendix G, Subsection G.3.2.1, Page G-28: Subsection "Model ResultsRadial Collector Wells": There are instances in this subsection where the values, which describe 

the results presented in the FSAR Table 2CC-211, are consistent with an earlier revision of 

FPL's FSAR Table 2CC-211 but are inconsistent with FPL's FSAR Table 2CC-211 Revision. 

These instances include (emphasis added): a. The DEIS states: "Only 0.3 percent of the water 

produced was predicted by the base case model..." The FSAR reports base case percentage as 

0.2 percent. b. The DEIS states: "This "worst-case" analysis predicted that 1.5 percent...from 

the Biscayne aquifer." The FSAR reports worst case percentage as 1.4 percent. c. The DEIS 

states: "The base case model predicted that 1.9 percent...A "worst" case of 3.3 percent of the 

extracted water coming from the industrial wastewater facility..." The FSAR reports base case 

percentage as 2.0 percent and the worst percentage is 3.2 percent. (0619-7-18 [Maher, William])

Comment: Appendix G, Subsection G.3.2.1, Page G-29: Subsection "Assessment - Radial 

Collector Wells": Page G-29, 2nd to last paragraph, first line: The DEIS states: "FPL's base case 

model predicted that 1.9 percent of the water extracted by the RCW would come from the 

industrial wastewater facility." FSAR Table 2CC-211 reports the percentage as of RCW flow 

originating from the industrial waste facility as 2.0 percent. (emphasis added) (0619-7-19 [Maher, 

William])

Comment: Appendix G, Subsection G.3.2.1, Page G-30: Subsection "Model Results-Inflow to 

Power Block Excavations": The DEIS states: "The FPL model predicted that pumping rates of 

140 and 136 gpm would be necessary for dewatering the excavations at Units 6 and 7, 

respectively." These values have been updated. Revision 6 of the ER, Subsection 4.2.1.1.1, 

and FSAR Appendix 2CC Section 9.0, states the excavation dewatering pumping rates as 96 

gpm for each of the two units. (emphasis added) (0619-7-20 [Maher, William])

Response: The values in the EIS were updated to be consistent with those presented in 

Revision 6 of the FSAR. 

Comment: Appendix G, Subsection G.3.2.2, Page G-33: Subsection "Numerical Modeling": 

The DEIS states (last paragraph of page G-33): "...the total RCW pumping rate was set to 

470,965 cubic meters per day (m3/d) (86,400 gpm)..." However, according to cited reference, 

USGS document "Estimated Effects of Proposed Radial Collector Well Pumpage Near Turkey 

Point Nuclear Facility, Miami-Dade County, Florida. (NRC 2014-TN3078, page 9): "The total 

rate of pumping...is 490,536 m3/d or approximately 90,000 gallons per minute (gal/min)." 

These values should be reconciled for consistency. (emphasis added) (0619-7-21 [Maher, 

William])

Response: The RCW pumping rate used in the USGS model was corrected in Appendix G to 

"490,536 m3/d or approximately 90,000 gallons per minute (gal/min)" as stated in the USGS 

report titled "Estimated Effects of Proposed Radial Collector Well Pumpage Near Turkey Point 

Nuclear Facility, Miami-Dade County, Florida" (NRC 2014-TN3078). 

Appendix E October 2016 E-181 NUREG–2176
Comment: Appendix G, Subsection G.3.3.2, Page G-49, Lines 6-7: The DEIS states: "...using 

the maximum MCU hydraulic conductivity from the range of values shown in Table G-25..." 

Table G-25 only shows one value for hydraulic conductivity. Table G-24 contains hydraulic 

conductivity values for the MCU. (0619-7-22 [Maher, William])

Response: The text was changed to refer to the correct table listing core sample analyses 

(currently Table G-24). 

Comment: [T]here's no guarantee that it [the reactor] won't affect the aquifer. (0008-8 [Finver, 

Jody])

Comment: 1. The integrity of the drinking water for South Florida will be affected as FPL 

would use this same water to cool its power plants thereby affecting the level of salt intrusion 

into the Biscayne Aquifer, the main source of drinking water for this area. I find it totally 

unacceptable that FPL also plans to curtail its current monitoring program for this. (0077-1 [de 

Armas, Maria Cristina])

Comment: If there is insufficient treated wastewater for cooling the reactors, the wells used for 

back-up cooling would become one of the largest well-fields in the Southeast, and could lead to 

further saltwater intrusion into the Biscayne Aquifer, a huge problem already impinging on South 

Florida's limited freshwater resources. (0078-9 [Wilansky, Laura Sue])

Comment: The withdrawal of massive amounts of water from under Biscayne Bay as back-up 

cooling water could increase salinity levels within the Bay and hasten saltwater intrusion into our 

limited freshwater supplies. (0102-6 [Commenters, Multiple])

Comment: The withdrawal of massive amounts of water from under Biscayne National Park as 

backup cooling water could increase salinity levels within the bay and hasten saltwater intrusion 

into the aquifer. (0103-6 [Commenters, Multiple])

Comment: Furthermore, as noted in the DEIS, removing large volumes of water from the 

aquifer could impact water-supply levels and ultimately increase saltwater intrusion into the 

Biscayne Aquifer. [Footnote 18: NRC, DEIS, 5-13.] South Florida's water supply is already 

extremely vulnerable to the impacts of salt water intrusion and an acceleration of the 

degradation of our water supply as a result of this project is unacceptable. Such potential 

impacts must be fully analyzed in the DEIS to comply with NRC regulations that require a 

complete discussion of the potential negative impacts of a project. [Footnote 19: 10 C.F.R. § 

51.45(b).] (0113-1-17 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] 

[Silverstein, Rachel])

Comment: The existing two 693 MW Westinghouse units (Unite 3 & 4) are already consuming 

a huge amount of water from the Floridian aquifer 14 MGD, which is already exhibiting signs of 

being over pumped. Even with the present pumping the cooling water temperature in the canals 

has increased from 100 to 104 degrees and FPL has received permission to use more water.

(0187-3 [Meyer-Steele, Shawn])

Comment: We are deeply concerned about our close proximity to the plant and how this EIS 

has not at all taken into account the current failing operations of the Cooling Canal System 

(CCS) and the lack of regional water supply in the area. It has come to our attention that FPL 

has been applying for every available water source in the region. This concerns us not only 

because it will impact restoration efforts we as taxpayers spend billions on, but because it 

Appendix E NUREG–2176 E-182 October 2016
threatens our ability to continue using the Floridian Aquifer as our primary water source. (0208-1

[Ritz, David])

Comment: Withdrawing massive amounts of water from under Biscayne Bay as back-up 

cooling water would increase salinity levels within the Bay and speed-up saltwater intrusion into 

our limited freshwater supplies. (0228-6 [Yeager, Jerry])

Comment: [A] clue would also be the Biscayne Aquifer with its surrounding limestone which is 

important to our drinking water. (0250-8 [Fulks, Anna Louise])

Comment: The cooling canals have led to salt intrusion into our aquifer - our fresh water 

supply. (0252-5 [Van Leer, Sam])

Comment: Furthermore, we are concerned that the operation of two new nuclear reactors 

could have significant impacts on the quantity and quality of our limited freshwater resources. 

Maintaining South Florida's water supply is critical to ensuring the future of our environment and 

our communities. We are concerned that withdrawing massive amounts of freshwater from 

underneath Biscayne Bay could increase salinity levels within Biscayne National Park and 

hasten saltwater intrusion into freshwater resources. (0253-3 [Bloom, Justin] [Campbell, Cara] 

[Causey, Charlie] [Cavros, George] [Chenoweth, Mike] [Daly, Meg] [England, Margaret] [Fuller, Manley] 

[Jones, George L.] [Keller, Alan] [Martin, Drew] [McLaughlin, Caroline] [Reynolds, Laura] [Silverstein, 

Rachel] [White, Paton] [Williams, Elinor])

Comment: I don't want FPL to build these 2 nuclear reactors because it is not environmentally 

responsible through the huge amount of fresh water consumption. This is unsustainable and 

irresponsible. (0269-1 [Gomez, Christian])

Comment: We are also concerned about the new radial wells and their impact on groundwater 

supplies and salinity levels. (0288-8 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, 

Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: Our aquifers and fresh water resources should not be further depleted by water 

hogging nuclear energy. We need to protect the Bay and the greater drinking water needs of 

South Florida--not hasten salt water intrusion. (0323-1 [Jennings, Cara])

Comment: Nuclear power is not clean. The reactors threaten to degrade our water quality 

which is of tremendous concern with a very large increase in thermoelectric power generation, 

according to the studies done on this project. It is a real potential threat to our aquifers and our 

public drinking water. (0340-1 [Tweeton, Tanya])

Comment: [T]he increasing salinity of the water in those canals and the in-land advance of salt 

water intrusion and its effect on our aquifer are already at alarming levels. (0341-3 [Daniels, 

Bonnie])

Comment: The aquifers that we depend on for drinking water, would be impacted. (0360-3

[Palmer, Majorie])

Comment: The amount of water needed to cool these nuclear reactors on a daily basis is 

simply not available without depleting the Biscayne Bay aquifer so rapidly that salt water 

intrusion will completely destroy our fresh water supply. The educated community is already 

aware that there is a certain amount of salt water intrusion due to the current operation of 

Turkey Point. There should be absolutely no water taken from the aquifer for use by FPL under 

Appendix E October 2016 E-183 NUREG–2176
any circumstances. This can only mean that there can be no more nuclear reactors. (0365-2

[Fischer, Antoinette])

Comment: If FPL sees this as a solution, then why do they also need to draw on the Biscayne 

Bay aquifer. Apparently, the 90 million gallons of waste water that they would produce would be 

inadequate since FPL is also asking for an unknown quantity of water from the aquifer. This 

would guarantee a huge, and unsustainable drain off of the aquifer. (0365-4 [Fischer, Antoinette])

Comment: If there is insufficient treated wastewater for cooling the reactors, the radial wells 

used for back-up cooling would become one of the largest well-fields in the Southeast and could 

lead to further saltwater intrusion into the Biscayne Aquifer, a major problem already impinging 

on South Floridas limited freshwater supply. (0370-11 [Vayu, Satya])

Comment: The withdrawal of massive amounts of water from under Biscayne Bay as back-up 

cooling water will increase salinity levels within the Bay and hasten saltwater intrusion into our 

limited freshwater supplies. (0413-5 [Cobb, Tanya])

Comment: Saltwater intrusion into the areas fresh waters will affect the land, the wildlife, and 

the company's use of fresh water for backup cooling. This shows a definite lack of foresight in 

planning. (0437-2 [Livingston, C. J.])

Comment: Prioritize Avoiding Potential for Impacts to the Biscayne Aquifer and National 

Parks. Radial collector wells located on the Turkey Point peninsula are planned to supply 

backup cooling water for the proposed reactors. The installation of this backup system "would 

involve drilling of lateral collector wells in the Biscayne aquifer beneath Biscayne Bay." DEIS at 

4-28. According to its state license, FPL is authorized to operate the radial collector wells for 60 

days each year and withdraw a maximum volume of over 7 billion gallons of water during that 

time, the equivalent of 124 million gallons per day. If constructed, the radial collector wells would 

likely become the largest wells in Florida by daily permitted volume when pumping. The majority 

of pumped water is projected to come from Biscayne Bay rather than the Biscayne Aquifer itself. 

Even so, the radial collector wells may put the City at risk because the "Biscayne aquifer is the 

sole source of potable water in Miami-Dade County, Florida." ML14287A481. However, the 

determination that the backup radial collector well system will have "minor impacts on 

groundwater users is based on the reliability of the [primary cooling] water supply," and not the 

prudence of drilling radial collector well laterals into a sole source aquifer. DEIS at 7-12.

(0456-10 [Miami, City])

Comment: Comment 5: The final Environmental Impact Statement should give greater 

weight to the potential for adverse impacts to environmentally significant resources in its 

risk analysis. Operation of the radial collector wells would remove water from Biscayne Bay, 

the FPL industrial wastewater facility (also referred to as cooling canals), and the Biscayne 

Aquifer in an area adjacent to Biscayne National Park. DEIS at 2-27. It is also worth noting that 

there is a plume of hypersaline water in the portion of the Biscayne Aquifer underneath the FPL 

industrial wastewater facility. The DEIS acknowledges this fact and predicts that some of the 

hypersaline water would be drawn into the radial collector well system, which "may change the 

area affected by the hypersaline plume." DEIS at 5-15. Therefore, the most direct risk of 

operating the radial collector wells would be an increase in the amount of saltwater intrusion 

caused by removing groundwater from the inland portion of the Biscayne Aquifer. DEIS at 5-27. 

Similarly, the intermittent usage of the backup cooling system "could result in an increase of 

hypersaline flow into the aquifer beneath the bay that could migrate into the bay when the [radial 

collector well system] is not operating." DEIS at G-29. The introduction of this hypersaline water 

Appendix E NUREG–2176 E-184 October 2016
into Biscayne Bay may irreparably damage or destroy local seagrass beds, a critical habitat for 

several endangered species. A similar pattern occurred in the fall of 1987, causing an abrupt 

and widespread mortality event in the Florida Bay seagrass community. See

http://tinyurl.com/SeagrassHabitatRestoration2013 at 11-12, 14-15. Seagrass mortality 

continued due to hypersaline conditions in Florida Bay through 1995 and had negative 

consequences for a variety of marine life. Id. The DEIS also notes that there is the potential for 

adverse effects on threatened species, including American crocodile, that inhabit the FPL 

industrial wastewater facility due salt drift and deposition from cooling-tower operation while the 

radial collector wells are being used. DEIS at 5-54. Furthermore, there is the potential for the 

entrainment of microscopic organisms and larvae. Due to the myriad risks presented by the 

radial collector wells and the vulnerable nature of the surrounding ecosystem, the final 

Environmental Impact Statement should place additional emphasis on avoiding the potential for 

adverse impacts to, and place additional weight on protecting, environmentally significant 

resources. (0456-12 [Miami, City])

Comment: Florida's water resources are already under severe strain. The plant will require 90 

million gallons a day of Miami-Dade's wastewater for cooling, with wells tapping the aquifer to 

meet any additional needs. Such withdrawals could increase salinity levels within Biscayne Bay 

and hasten further saltwater contamination of the aquifer. Additionally, even treated wastewater 

contains numerous contaminants which may be emitted into the air in vented steam, potentially 

impacting air and water quality, human health and aquatic and terrestrial wildlife. (0463-1 [Gross, 

Cheryl A.])

Comment: Florida's aquifer is so critical, and so close to the ground it is critical not to do 

anything to violate its integrity! (0503-1 [Keaton, Rebecca])

Comment: This area is also extremely vulnerable to the withdrawal of massive amounts of 

water from under Biscayne Bay as back-up cooling water. (0591-2 [Lange, Barbara])

Comment: Therefore, the most direct risk to the surrounding environment of operating the 

radial collector wells would be an increase in the amount of saltwater intrusion caused by 

removing groundwater from the inland portion of the Biscayne Aquifer. DEIS at 5-27. (0611-4

[Haber, Matthew S.])

Comment: Due to the myriad risks presented by the radial collector wells and the vulnerable 

nature of the surrounding ecosystem, the final Environmental Impact Statement should place 

additional emphasis on avoiding the potential for adverse impacts to, and place additional 

weight on protecting, environmentally significant resources. As noted in Comment 4, this may 

come in the form of an alternate backup cooling system proposed by the review team staff.

(0611-5 [Haber, Matthew S.])

Comment: The senior NRC staff member presiding over the event demonstrated a total 

ignorance of hydrological conditions in South Florida and around the Turkey Point site when she 

announced that staff had determined the impact to local water supplies would be "small." The 

assembled public spent the rest of the evening learning just how many critical environmental 

facts draft EIS had failed to uncover. (0615-1-5 [Bethune, David])

Comment: The withdrawal of massive amounts of water from under Biscayne National Park as 

backup cooling water could increase salinity levels within the bay and hasten saltwater intrusion 

into the aquifer, which is already likely to increase as the sea level rises. (0693-3 [Dorn, Kathryn])

Appendix E October 2016 E-185 NUREG–2176
Comment: The first one is, you know, the integrity of the drinking water for the South Florida 

area is at risk. The water that FP&L would use to cool its power plants would affect the level of 

salt water intrusion into the Biscayne aquifer, the main source of drinking water for this 

area. FP&L also plans to curtail its current monitoring program for this, which is totally 

unacceptable. (0721-31-3 [Almirola, Alejandro])

Comment: First of all, this project can cause contamination of our groundwater. The proposed 

radial collector wells would remove billions of gallons of water each year from the bay which 

could increase salinity levels and increase the rate also of hot water intrusion into our limited 

freshwater supply. (0722-14-2 [Kaul, Devika])

Comment: There's a lot of issues about nuclear power that we need to worry about with 

respect to safety. But you know, I think the major point is that the water supply here, (0723-12-12

[Henry, Jim])

Comment: ...we have to look very carefully at the assumptions they've been making about 

water. (0723-12-9 [Henry, Jim])

Comment: Furthermore, the backup cooling system for the new reactors can become one of 

the largest well fields in terms of water consumption in the entire southeast region of this 

country. Proposed radial collector wells will stretch out underneath Biscayne Bay removing as 

much as 7.4 billion gallons of water per year. To put that number into perspective, the entire 

Florida Keys uses just over 6 billion gallons of water per year. The withdrawal of this water will 

increase salinity in Biscayne Bay and could increase the rate of saltwater intrusion into our 

limited freshwater resources. (0723-4-7 [McLaughlin, Caroline])

Comment: [I]t needs to be done in a safe and secure manner so that way we don't have any 

intrusions into the aquifers or into the Biscayne. (0723-8-8 [McDuffie, Stephen])

Response: The comments primarily focus on two issues raised in connection with operation of 

the RCWs, namely, the possibility for saltwater intrusion into the Biscayne aquifer, and the 

possibility for increasing the salinity of the water in Biscayne Bay. To the extent the comments 

also raise other issues, such as the continued availability of reclaimed wastewater for cooling, 

those issues are addressed in separate responses. Using reclaimed wastewater as the primary 

source of cooling water for the proposed reactors would not result in removal of water from 

Biscayne aquifer or Biscayne Bay, and would not increase the salinity of the aquifer or the Bay. 

In regard to the Biscayne aquifer, saltwater from the sea has already intruded into the 

groundwater in the Biscayne aquifer in the vicinity of the Turkey Point site, which has resulted in 

elevated salinity in that groundwater. This saltwater intrusion from the sea is unrelated to 

operations at Turkey Point. Because of its elevated salinity, groundwater from the Biscayne 

aquifer in the vicinity of the Turkey Point site cannot be used as a drinking water source without 

treatment. Seepage of saline water from the IWF cooling canals associated with the existing 

Turkey Point Units 3 and 4 has also resulted in locally higher groundwater salinity near the 

cooling canals. Analyses from the USGS groundwater-surface water model presented in the 

EIS show that in the absence of remediation of the IWF hypersaline plume, increases in 

groundwater salinity may occur inland from Turkey Point because of movement of the existing 

hypersaline plume. This would occur regardless of whether or not the proposed units are built 

and operated. The model-predicted increase in groundwater salinity is not caused by RCW 

pumping or other activities related to the proposed units. The model-predicted increase in 

groundwater salinity also does not reach the location of drinking water wells. 

Appendix E NUREG–2176 E-186 October 2016
Analyses presented in the EIS predict that the RCW system would draw water primarily from the 

overlying Biscayne Bay with only a small portion coming from inland portions of the Biscayne 

aquifer. Nonetheless, the review team revised the text in Sections 2.3, 5.2, and G.3.2 of the EIS 

to expand and clarify the process and findings of the analysis of the potential alteration of the 

hypersaline plume caused by the operation of the RCW system. In additional to the review 

team’s conceptual understanding of the processes that would occur with RCW operation, the 

review team considered three independent modeling studies that are all consistent in projecting 

that RCW operation would result in only insignificant alterations to both the Biscayne Bay and 

the surficial aquifer. The review team considered a wide range of baseline environmental 

conditions to reflect the uncertainty in the baseline environment associated with various 

proposed actions associated with the IWF, climate change, and geohydrologic parameter 

uncertainty. While the environmental baseline may change significantly, the incremental 

alteration to the hypersaline plume associated with operation of the RCWs remains minor. 

The review team has responded to similar comments in Section E.2.7, regarding surface water. 

Comment: The results of the groundwater modeling discussed in Appendix G appear to 

indicate that the operation of the RCW would impact salinity in Biscayne Bay by capturing 

freshwater canal discharges to the bay. Specifically the last paragraph of page 35 of Appendix 

G concludes that "... When the proximal canals are discharging fresh water into the bay and 

pumping is occurring, the pumping may capture this fresher water, preventing it from 

contributing to overall dilution of the bay." Regarding water quality impacts of the RCW, It is 

stated on page 5 to 26, lines 35 to 38 of the DEIS that "Operation of the RCWs, if and when 

needed during operation of Units 6 and 7 would not result in discharges to Biscayne Bay 

because they are used only to withdraw saltwater. Therefore, the staff determined that the 

impact of any potential changes in surface-water chemistry as a result of the use of the RCWs 

on Biscayne Bay water quality would be minor." Based on this last statement it does not appear 

that DEIS evaluated the potential adverse impacts of operating the RCW resulting from its 

consumption of freshwater discharges to the bay on restoration projects aimed at reducing the 

salinity of Biscayne Bay through the rehydration of coastal wetlands to reestablish fresh water 

sheet flow patterns to the bay. One such restoration project includes the Comprehensive 

Everglades Restoration Plan (CERP) Biscayne Bay Coastal Wetlands project (BBCW).

(0110-1-10 [Hefty, Lee N.])

Response: The EIS discusses USGS conducted modeling of potential impacts of the radial 

collector wells (RCWs) on surface water and the Biscayne aquifer using a linked surface watergroundwater model. The results showed that some of the water going to the RCWs would come 

from the regional canals. The model examined interactions near the mouth of the Mowry Canal 

and found that pumping of the RCWs results in an increase of downward leakage of surface 

water, including canal water, into the aquifer. However, the modeling showed that the overall 

effect on groundwater/surface-water fluxes in the Mowry Canal Basin are small; the reduction in 

base flow to the bay could be less than 10 percent of the base flow with no RCWs 

pumping. The modeling also showed that capture of canal water by the RCWs occurs primarily 

during the wet season, when the canals are discharging freshwater to the bay. Additional 

discussion has been added to the EIS to clarify the use of model results and expected 

monitoring requirements for Biscayne Bay and the Biscayne aquifer. 

Comment: The Boulder Zone deep aquifier that is going to be used with an injection system to 

absorb the treated liquid (which will most likely be radioactive) is literally scary! (0074-2 [Streit, 

Didi])

Appendix E October 2016 E-187 NUREG–2176
Comment: However the discharge of this waste water will have an adverse impact on our 

ground water, which will contaminate our drinking water source. Turkey Point has now begun to 

compete with the people of these two counties for consumptive use of our freshwater source, to 

cool the current canals, and the FPL proposal for the two new plants would also rely on the 

Biscayne Aquifer by the use of radial collector wells which would also draw water from the same 

source, the Biscayne Aquifer. (0145-8 [Lerner, Cindy])

Comment: The analysis of the impacts of the use and disposal of reclaimed wastewater is 

inadequate. We are concerned that the proposal to store the waste in the boulder zone will fail 

and impact the Floridian Aquifer and impact our drinking water. (0208-7 [Ritz, David])

Comment: Clarify Uncertainties Related to the Deep Injection of Wastewater. The 

application plans for disposal of waste by use of deep injection wells. The purpose of this 

system is to diffuse waste water with aquifer water over the long term by sending it beneath the 

"Boulder Zone" (a South Florida injection zone). At present, the formation of this injection zone 

is not fully understood by geologists and little data exists on its lateral flow capabilities. 

Moreover, the proposed discharge method for the disposal of treated liquid radioactive waste is 

not practiced by any other power plant in the U.S. Comment 14: The final Environmental 

Impact Statement should disclose uncertainties related to the deep injection of 

wastewater and the probable final disposition of the waste. The final Environmental Impact 

Statement should "indicate the extent to which environmental effects are essentially unknown . . 

. ." Scientists' Inst. for Pub. Info., Inc. v. Atomic Energy Comm'n, 481 F.2d 1079, 1092 (D.C. Cir. 

1973). Hence, to the extent that such information is known, the final Environmental Impact 

Statement should disclose where effluent from the nuclear plant might migrate. Similarly, 

although the east-west tidal forces on groundwater are not well understood, the final 

Environmental Impact Statement should discuss the probability that the north-south shallower 

slope of the dolomite in the Boulder Zone will push the wastewater north of the injection site.

(0456-21 [Miami, City])

Comment: Possible effect of long-term injection of wastewater into Boulder Zone. The 

maximum injection rate appears to be between 84 and 85 Mgd. Have calculations been made to 

determine if the Lower Floridan Aquifer can accommodate between 30.066 and 31.205 Ggy for 

the expected 35 year life of the two proposed nuclear units 6 and 7? (0612-3 [Teas, James])

Comment: Possible upward migration of wastewater due to underestimate in injection rates. At 

higher injection rates, upward migration of wastewater has previously been seen: "Upward 

migration of treated municipal wastewater injected into the Boulder Zone has been observed 12 

mi north of the proposed Turkey Point site at the Miami-Dade SDWWTP, where injection rates 

are around 97 Mgd. (2-55). Is it possible that the estimated maximum 84-85 Mgd might be 

exceeded by 14% and lead to 97 Mgd injection rates, which could migrate upwardly? (0612-4

[Teas, James])

Comment: Possibility of migration of wastewater into Atlantic Ocean over 35 year life of 

project. "It is thought that the Boulder Zone connects to the Atlantic Ocean at a depth of about 

2,500 ft about 25 mi off the coast of Miami." (2-53). Is it possible that wastewater from the deep 

injection wells could end up in the Atlantic Ocean over the expected life of units 6 and 7? (0612-5

[Teas, James])

Comment: The radioactive portion of the waste water is proposed to be diverted to 

underground wells located near important aquifers and fresh water supplies, exposing the 

residents, animals, and plants in the surrounding areas to water laced with tritium and other 

Appendix E NUREG–2176 E-188 October 2016
dangerous radioactive isotopes. Two nearby municipal water supplies have already filed 

comments with the NRC objecting to the proposed injection of chemically and radioactive 

contaminated wastewater so near to their communities' drinking water supplies. (0615-3-1

[Bethune, David])

Comment: The draft EIS is incomplete because it fails to examine the migration paths of 

effluent water from the proposed plant's deep injection wells and the resulting threat to the water 

supply of 4 million people. (0615-3-4 [Bethune, David])

Comment: Underground injection of effluents. The DEIS states that blowdown water from the 

cooling towers, and other plant discharge effluents from proposed Units 6 and 7, would be 

collected in a sump and injected into the Boulder Zone, a cavernous, high-permeability South 

Florida geologic horizon within the Lower Floridan aquifer system. The surrounding surface 

water bodies would neither be directly used for the primary water supply, nor for the heat sink 

for the proposed Units 6 and 7. However, we have concerns regarding the potential for vertical 

migration of the injectate, as no adequate confining zone has been shown to exist between the 

injection zone and lowermost underground source of drinking water (USDW). Several 

investigations by the United States Geological Survey (USGS) in southeast Florida (the latest is 

USGS Scientific Investigations Report 2015-5013) have shown that the limited confinement 

which may exist between the Lower Floridan and Upper Floridan has been reduced or 

eliminated by karst features and faulting. FPL has not produced any documentation to delineate 

karst features or faults in the Floridan which may significantly alter hydraulics of the injectate at 

this facility. Further, additional data, including conducting more comprehensive aquifer testing 

and incorporation of karst features and fault delineation, as well as results of aquifer testing into 

predictive modeling, are needed to assess potential injectate impacts on USDWs. In addition to 

injection in the Boulder Zone creating upward gradients, the Upper Floridan is proposed to be 

used as a source of cooling water, also creating upward gradients from the Lower Floridan, with 

the potential to impact the USDWs in the area. (0617-1-22 [Mueller, Heinz J.])

Comment: Let's look at some of the other impacts from this plant. The injectate. Somebody 

was talking about putting it down earlier during the presentation, 3,000 feet below ground. Out 

of sight, out of mind; really? That's called the Boulder Zone. Everything goes into the Boulder 

Zone. When we flush our toilets most of it goes into the Boulder Zone. The drillers out in the 

western Everglades, I had a discussion with them at the Raccoon Point drilling sites in the Big 

Cypress National Preserve. They talked about lowering pipes, 50 foot sections of pipes down 

into their wells, which are about 2 miles below ground. They hit the Boulder Zone and a 50-foot 

pipe hit the bottom and turned sideways. It's a cavern. It's a deep undersea cavern in this area 

where they're planning on dumping the injectate from this well. Where does it go? It goes out to 

the Atlantic. Sewage, wastewater, oil drilling fluids, and now the injectate from this new Turkey 

Point 6 and 7. What are the consequences of that to the Atlantic Ocean? Doesn't disappear. 

There's no such thing as a free lunch, there's no way. (0721-22-8 [Schwartz, Matthew])

Comment: Deep well injection of either raw sewage or anything I think is problematic and a 

bad idea in South Florida where that stuff moves around underground. You never know where 

it's going to pop up, and it does move. So let's not kid ourselves thinking that, you know, hey, 

let's put it down 3,000 feet, the problem will go away. That's not going to happen. Eventually it's 

going to resurface somewhere. I would highly recommend we also get on our State Reps about 

banning all deep well injection, no matter what it is. It's a bad idea. (0721-24-3 [Eastman, John])

Appendix E October 2016 E-189 NUREG–2176
Comment: [Wastewater will be] injected into the earth. That can't be controlled. We've heard 

about the problems with the radial wells that would be used for backup cooling, the salt water 

intrusion into the aquifer, which is already a huge problem. (0721-28-7 [Wilansky, Laura Sue])

Comment: FPL has proposed using millions of [gallons of] reclaimed wastewater as the 

primary source of cooling water for the proposed new reactors and this wastewater would then, 

after use, to back into our groundwater where it would be adding chemical contaminants to our 

groundwater supplies. We have very, very vulnerable groundwater to contamination. 

A study was done a few years ago where some dyes were put near a wellhead and it was 

expected that they would take a few days to weeks to be detected by special detectors. And 

they put in the red dye and within a few hours, people's laundry were turning pink in their 

washing machines. We have very vulnerable, vulnerable water supply to contamination so it has 

to be really taken very seriously and considered very carefully which I feel that the EIS has not 

done adequately. (0722-7-5 [Silverstein, Rachel])

Comment: Even this idea of shooting the water deep into the ground, these kinds of concepts 

may work when you have a different kind of stone or granite to receive them. (0723-11-2

[Berendsohn, Catherine])

Comment: The expansion of Turkey Point also has the potential to have huge impacts on 

regional water resources. FPL is proposing using millions of gallons of reclaimed wastewater as 

the primary source of cooling water for the new reactors. After used, some of this wastewater 

will be discharged directly underground. The possible impacts of adding chemical contaminants 

into our groundwater supplies have not been adequately analyzed by this EIS. (0723-4-6

[McLaughlin, Caroline])

Comment: All of our prescriptions go down, we're using deep well injection -- I've got to 

mention that, too. 

Deep well injection. Out of sight, out of mind? The boulder zone 3,000 feet deep. Run that 

boulder zone east, what happens? You reach the continental shelf. It can't keep going. The 

continental shelf is lower. The boulder zone empties out into the Atlantic. So that wastewater, 

that hot wastewater ends up in the Atlantic. Is that in the DEIS? I know they're not going to 

answer that. That's where the boulder zone empties out into. (0723-9-18 [Schwartz, Matthew])

Response: As described in Section 5.2 of the EIS, cooling tower blowdown water and other 

liquid waste streams would be injected into the highly permeable Boulder Zone, which is 

approximately 2,900 to 3,500 ft below ground in the Lower Floridan aquifer. This aquifer 

contains water that has approximately the same salinity as seawater and is used for injection of 

treated municipal wastewater throughout South Florida. As discussed in the EIS, there is a 

1,465 ft thick sequence of mostly low-permeability rock strata called the MCU (Middle Confining 

Unit) between the Boulder Zone and the overlying Upper Floridan Aquifer. The Upper Floridan 

aquifer is classified as an USDW (Underground Source of Drinking Water) where the TDS 

concentration is 10,000 mg/L or less. The depth of the USDW was confirmed by sampling of 

the monitoring intervals within the FDEP permitted dual-zone monitoring well that was 

constructed at the Turkey Point site after the construction of the exploratory/injection well. The 

monitoring intervals are at 1,450-1,490 ft and 1,860-1,905 ft below ground surface. These 

comments express concern about the proposed injection of effluent from the Turkey Point site, 

the nature of the geologic zones that would be used for injection and confinement, and the 

Appendix E NUREG–2176 E-190 October 2016
impact on water resources, especially the Upper Floridan aquifer and the Biscayne aquifer, if 

injected fluid were to migrate out of the Boulder Zone. 

To evaluate the potential impacts of deep well injection of effluent at the Turkey Point site the 

review team took a number of steps, which are discussed in greater detail in the revised 

sections of the final EIS. The staff 1) reviewed regional and site specific studies that evaluated 

the confining ability of the MCU, the causes and extent of upwelling at other deep well injection 

sites, the extent of injection plume migration, and risk to human health and the environment of 

deep well injection; 2) compared hydrogeological conditions and parameters from these sites to 

conditions and parameters at the proposed site; 3) evaluated numerical modeling of the flow of 

injected wastewater presented by the applicant and performed confirmatory calculations; and 4) 

considered the injection well testing and groundwater monitoring requirements of the FDEP UIC 

program. 

Based on this evaluation, the review team concluded that, in general, the matrix of the MCU 

would confine injected effluent and that incidences of upwelling at other sites have been 

coincident with features that provide vertical pathways for upward migration. As documented in 

Sections 2.3.1.2 and 5.2.1.3 of the EIS, the review team is aware of recent research showing 

that “karst-collapse structures” exist in some places in South Florida and may provide a pathway 

for injectate to move upward through some thickness of the expected confining layers. At a 

location beneath Biscayne Bay, deformation associated with collapse structures has been found 

to extend from the MCU to above the Upper Floridan aquifer (Cunningham 2015-TN4574). A 

collapse structure was implicated in the observed migration of injected wastewater from the 

Boulder Zone to the uppermost permeable zone within the Lower Floridan aquifer at an injection 

well operated by the City of Sunrise in Broward County (Cunningham 2014-TN4051). Migration 

of contaminants above the Lower Floridan aquifer was not observed at this site and significant 

migration to the Upper Floridan aquifer due to natural features has not been definitively 

identified at any site. Substantial fracturing of the confining layers is not evident at the Turkey 

Point site. 

The EIS discusses several studies that have attributed upwelling at deep well injection sites to 

vertical pathways created by improper well construction or casing failure. The studies indicated 

that wells were either drilled through but completed above the most significant confining portions 

of the MCU or that completed wells deviated from previously drilled pilot holes. These issues 

are not expected at the Turkey Point site because its hydrogeology is better understood. Also, 

pilot holes would be cemented and injection wells would have multiple concentric casings that 

terminate in and seal each confining zone. The FDEP UIC Permit also requires testing of 

confinement and monitoring for upwelling at each injection well. However, studies of other 

injection sites indicate that if rapid vertical migration occurs along preferential pathways created 

by well construction issues or natural features it is not likely to reach the Upper Floridan 

Aquifer. This is discussed in greater detail in Sections 2.3.1.2, 3.2.2.2, and 5.2.1.3 of the 

updated EIS. As discussed in Section 5.2.1.3 and Appendix G of the EIS, only a minimal 

pressure buildup in the injection zone is expected during injection based on calculations that 

considered the expected rate of injection and buoyancy of the reclaimed makeup water used for 

cooling. One comment expressed concern that the Turkey Point site might also experience 

upward migration if injection rates exceeded that of the SDWWTP, where upwelling has 

occurred. Reclaimed water from the SDWWTP would be the primary source of makeup water 

at Turkey Point, however injection rates would be significantly less at the Turkey Point site (20 

Mgd vs 97 Mgd). Injection rates at Turkey Point may temporarily be as high as 90 Mgd when 

saltwater from the RCWs is used. Despite higher injection rates, the potential for upward 

migration of this saltier water would be less than reclaimed water because the saltwater used for 

Appendix E October 2016 E-191 NUREG–2176
cooling would be denser and less buoyant, causing it to sink to the base of the Boulder Zone. In 

addition, multiple studies have indicated that upwelling at the SDWWTP may be primarily a 

result of improperly constructed injection wells (Walsh and Price 2010-TN3656; McNeill 2002-

TN4571). 

Calculations and modeling discussed in EIS Section 5.2.1.3 also indicate that horizontal flow of 

the plume within the Boulder Zone would be limited and would not extend to beneath the 

locations of the nearest offsite water-supply well in the overlying Upper Floridan aquifer (7.7 mi) 

or flow to surface water bodies, such as the Atlantic Ocean. Modeling indicates that dilution 

would significantly reduce the concentrations of cooling water chemical constituents within the 

injected plume, which are already very low at the point of injection due to advanced treatment 

now required at the SDWWTP, where the cooling water would primarily be sourced. 

As for potential contamination of the Biscayne aquifer, the Biscayne aquifer is a near-surface 

aquifer which is separated from the Boulder Zone at the Turkey Point site by about 2800 ft, a 

large portion of which is confining strata. Therefore, impact to the Biscayne Aquifer is so 

unlikely as to be speculative. 

Additionally, the review team recognize that the UIC permitting process required by the FDEP 

will address uncertainty through further characterization and testing of the ability of the MCU to 

confine and the Boulder Zone to receive injected effluent. This additional characterization and 

testing are required before each of the injection wells are permitted at the Turkey Point site and 

these wells would be frequently monitored during operation for the evidence of upwelling of 

injected effluent. Finally, EIS Sections 5.2.1.3 and 5.2.3.2 discuss risk assessments of 

wastewater disposal methods in southeast Florida, which indicate that risk from deep well 

injection to human health is low and decreases dramatically as distance from the injection well 

to potential receptors increases, even when upwelling has reached drinking water aquifers. 

As discussed in several comments, the injected water would include radionuclides, however 

these radiological constituents would be mixed and diluted to concentrations below regulatory 

limits before being injected. The review team performed a conservative evaluation and 

determined that radiological dose limits to the public would not be exceeded. This is 

documented in EIS Sections 5.2.1.3, 5.9, and in Appendix G. 

Another comment indicated that the geology and hydrogeology of the Boulder Zone is not well 

understood. As discussed in Sections 2.3.1.2, 5.2.1.3, and Appendix G of the final EIS, 

because of the deep and isolated location of the Boulder Zone and its subsequent widespread 

use as a wastewater injection zone in South Florida, testing and a number of regional and site 

specific studies have been conducted to characterize this zone. This information addresses 

flow direction and rates of water within the Boulder Zone, the capacity to receive injected 

wastewater, and the effect of overlying confining units on flow direction. The review team used 

this information to evaluate the potential for impacts from deep well injection at the Turkey Point 

site. 

For the reasons discussed above, the review team determined that impacts of deep well 

injection at the Turkey Point site on water resources would be SMALL. Detailed documentation 

of these studies and the review team’s evaluation is provided in updated sections 2.3, 5.2, 7.2, 

and Appendix G of the final EIS. 

Comment: Comment 1. The DEIS is incomplete in that it makes no analysis of the effects 

of entrainment of the hypersaline plume, and the likely resulting consequences for 

Appendix E NUREG–2176 E-192 October 2016
demand on water from other sources, i.e., fresh water from the Coastal Everglades or bay 

water from Biscayne National Park, if the RCW system is tainted by the hypersaline 

plume- Radial collector wells (RCWs) under the site will draw water from beneath the plant 

when water is unavailable from the wastewater treatment plant. The DEIS attempts to model 

how water will flow underground into the RCWs, yet the DEIS admits that the models used to 

project underground flow of ground water were insufficient to determine how water of different 

density (i.e., from salinity differences) will move through the ground: "The steady-state nature of 

the FPL model and the assumption of constant density fluids make the model inadequate for 

modeling this potential scenario." [DEIS p. G-29]; How water of differing densities moves is 

critically important because of the hypersaline plume underneath the existing cooling canals (the 

so-called "Industrial Waste Facility" or IWF). According to the DEIS [p. 3-30], the cooling system 

cannot operate if the cooling water becomes more than 1.5x the saline concentration of bay 

water. However, the hypersaline plume is already approximately twice the salinity of water in 

Biscayne Bay prior to entering the cooling system, and it could get worse: continued operation 

of TPN 3 & 4 has the capacity to further expand or relocate the hypersaline plume, either by 

continued concentration of water through heating and evaporation, or by displacement with 

water pumped in. Entrainment of the underground hypersaline plume into the RCWs could halt 

operation of the plant. Specifically, if the water entering the RCWs included 70% or more of 

water with the salinity of the hypersaline plume, the plant could not operate. Failure of the 

RCWs to provide water of sufficiently low salinity would place the cooling demand squarely on 

aboveground sources, either the L31E canal or Biscayne Bay itself. The final EIS must 

consider possible loss of usable cooling water caused by RCW entrainment of 

hypersaline plume under the IWF. (0106-4 [Stoddard, Philip K.])

Comment: Given the complexity of the current issues associated with the Cooling Canal 

System (CCS) and the uncertainty about its adverse hydrologic and other impacts, MDC 

believes that the recommendation for more detailed modeling is more than warranted for the 

EIS evaluation of the proposed RCW. The RCW in-and-of-themselves can potentially have 

significant hydrologic and other impacts which can likely exacerbate the existing CCS impacts. 

Did the NRC EIS reviewers conclude that the aforementioned recommendation for more 

detailed modeling was not warranted? MDC therefore recommends that a model capable of 

providing a more detailed understanding of how the proposed RCW can influence the CCS 

hypersaline plume now and how it will influence it in the future when Units 3 & 4 are 

decommissioned and the CCS circulating pumps are either not operated at all or operated at a 

much reduced rate. This model needs a much higher resolution and needs to be able to identify 

source waters through particle tracking. Most importantly, any analysis that relies primarily on 

model output that predicts average salinities of Biscayne Bay across large areas as a surrogate 

for impacts is totally inadequate to examine hydrologic impacts to the aquifer and surface 

waters. In addition, if the model cannot determine whether water quality standards with 

Biscayne Bay would be violated by operation of the radial collector well field, then additional 

study would be warranted prior to approval either as part of this EIS or through a supplemental 

EIS. (0110-1-12 [Hefty, Lee N.])

Comment: The DEIS fails to include an adequate analysis of the direct, indirect, and 

cumulative impacts of proposed radial collector well system, including cumulative impacts 

associated with the cooling canal system (CCS) industrial wastewater facility (IWF) and CERP.

(0113-1-4 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, 

Rachel])

Comment: The DEIS does not adequately discuss potential cumulative impacts caused by the 

existing underground hypersaline plume produced by the current operations of the CCS. The 

Appendix E October 2016 E-193 NUREG–2176
findings of the uprate monitoring program for Units 3 & 4 identified the presence of CCS water in 

shallow groundwater (approximately 25' to 30') in wetlands adjacent to Biscayne Bay. [Footnote 

23: West, B. United States Department of the Interior, National Park Service Letter to A. 

Williamson, U.S. Nuclear Regulatory Commission, November 25, 2014, SER PC, 6.] Radial 

wells will be constructed at approximately the same depth. According to FPL's groundwater 

modeling, the RCWs would draw approximately 2% of its water from the Industrial Wastewater 

Facility (IWF) cooling canal system. [Footnote 24: NRC, DEIS, 5-14] The DEIS acknowledges 

that the operations of the radial collector wells could impact the movements of the hypersaline 

plume, likely increasing the flow velocity of hypersaline water eastward under Biscayne and 

changing the area impacted by the plume. [Footnote 25: Ibid., 5-16.] The DEIS states that 

"intermittent operation [of the radial collector wells] could result in an increase of hypersaline 

flow into the aquifer beneath the bay that could migrate into the bay when the RCW is not 

operating." [Footnote 26: Ibid., G-29.] Despite admitting the potential for interactions, the DEIS 

fails to adequately analyze the adverse environmental impacts that could result if CCS water 

were to appear in the bay due to the operations of the radial collector wells. (0113-2-3 [Lopez, 

Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: In discussing such interactions, the DEIS admits that, "the steady-state nature of 

the FPL model and the assumption of constant density fluids make the model inadequate for 

modeling this potential scenario," [Footnote 28: Ibid., G-29.] in effect admitting uncertainty as to 

the interactions between the radial collector wells and hypersaline water from the plume. 

Despite the fact that the proposed system of radial collector wells would be located within or 

adjacent to the plume and will impact the movement and location of the plume, the DEIS fails to 

provide an adequate discussion of the ways in which the movement and composition of the 

plume may be affected by radial collector well withdrawals. There is an insufficient analysis of 

how the wells may capture or affect water from the plume and inadequate information regarding 

the possible impacts associated with causing plume water to flow towards the radial wells.

(0113-2-5 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, 

Rachel])

Comment: Our principal concern is the ongoing westward migration of hypersaline 

groundwater through the aquifer in the vicinity of the Turkey Point facility. FPL should implement 

a plan to address the saline groundwater contamination emanating from its Cooling Canal 

System ("CCS") at Turkey Point. Groundwater modelling can be very subjective due to 

uncertainty caused by limited model assumptions and characterization data. It is very important 

that the results from both the USGS and the FPL groundwater models be carefully analyzed to 

address the impacts of migration of hypersaline groundwater from the Turkey Point CCS. 2. 

There is need for further hydrological studies to show how the increase in temperature from the 

Turkey Point facility will affect the plant's cooling system, as well as the adjacent surface and 

groundwater. (0211-1 [Malefatto, Alfred])

Comment: Most of the problems and uncertainties identified concerning cooling water 

operations. The first of these is the failure to consider loss of useable cooling water caused by 

the radial collector wells entrainment sucking in the hypersaline plume underneath the cooling 

canals, which is known as the industrial waste facility. It's what they think of our southeast 

Everglades. Radial collector wells under the site will draw water from beneath the plant when 

water is unavailable from the wastewater treatment plant. The Impact Statement attempts to 

model how water will flow underground to the radial collector wells. But, the Impact Statement 

admits that the models used to project underground flow of groundwater were not sufficient to 

determine how water of different densities, such as from differences in salinity, will move 

through the ground. You have to recognize, there's a hypersaline plume underneath Turkey 

Appendix E NUREG–2176 E-194 October 2016
Point. And I'll keep referring to it. It's dense water about twice the salinity of the surrounding bay 

water. And the Draft EIS says, "The steady state nature of the FP&L model and the assumption 

of constant density fluids makes the model inadequate for modeling this potential scenario." 

That's from the Impact Statement, page G-29. So this uncertainty is critically important because 

of the hypersaline plume underneath the existing cooling canals. So according to the Impact 

Statement the cooling system cannot operate with more than -- at more than one-and-a-half 

times the salinity of bay water. But the hypersaline plume is twice the salinity of bay water. So if 

they entrain 70 percent or more of the plume, the radial collector well system cannot work for 

cooling the plant. (0721-2-2 [Stoddard, Philip K.])

Response: In regard to the Biscayne aquifer, saltwater from the sea has already intruded into 

the groundwater in the Biscayne aquifer in the vicinity of the Turkey Point site, which has 

resulted in elevated salinity in that groundwater. This saltwater intrusion from the sea is 

unrelated to operations at Turkey Point. Because of its elevated salinity, groundwater from the 

Biscayne aquifer in the vicinity of Turkey Point site cannot be used as a drinking water source 

without treatment. Seepage of saline water from the cooling canals associated with existing 

Turkey Point Units 3 and 4 has also resulted in locally higher groundwater salinity near the IWF 

cooling canals. Cumulative impacts of the proposed RCW pumping on the existing hypersaline 

plume were considered in the EIS. 

Analyses from the USGS groundwater-surface water model presented in the EIS show that in 

the absence of remediation of the IWF hypersaline plume, increases in groundwater salinity 

may occur inland from Turkey Point because of movement of the existing hypersaline plume, 

regardless of whether or not the proposed units are built and operated. The model-predicted 

increase in ground water salinity is not caused by RCW pumping or other activities related to the 

proposed units. The model-predicted increase in groundwater salinity also does not reach the 

location of drinking water wells. The NRC review team acknowledges that the distribution of 

contaminants from the cooling canals in groundwater beneath Biscayne Bay could be affected 

to by pumping of the planned RCWs beneath Biscayne Bay. Several comments indicate that 

the FPL groundwater model provides limited insight into groundwater behavior because it does 

not consider density differences. The review team evaluation documented in the draft EIS 

made the same point, and this is why the review team commissioned the USGS to perform 

additional groundwater modeling that is also documented in the EIS and which accounts for 

density differences. 

Nonetheless, after publication of the draft EIS, the review team performed additional 

groundwater modeling of the interaction between the planned RCWs, the existing hypersaline 

plume, and the cooling canals using a two-dimensional cross section model and a limited-extent 

three-dimensional model that accounts for variable fluid density. The review team also 

evaluated the combined impacts from proposed remediation of the hypersaline groundwater 

plume and sea level rise. Additional discussion has been added to the EIS to clarify (1) the use 

of model results, 2) the conceptual understanding of the hydrologic system, and 3) aquifer 

monitoring requirements. The review team considered this additional information in determining 

the impact of building and operating the proposed plants on groundwater in the Biscayne 

aquifer. 

In short, results of analyses presented in the EIS show that activities related to building and 

operating the proposed units would have minor effects on the salinity of the Biscayne aquifer or 

Biscayne Bay and would also not negatively impact efforts to remediate the existing hypersaline 

plume associated with Units 3 and 4. Inputs to the IWF related to building the new units would 

be limited to adding muck to the IWF berms and discharge of water from excavation dewatering 

Appendix E October 2016 E-195 NUREG–2176
for a limited time at a maximum rate that is approximately 0.06 percent of the recirculating flow 

rate water of the IWF. The water quality of the dewatering discharge would be similar to the 

aquifer water quality. 

Comment: MISSLEADING STATEMENT [terminating the current monitoring program for the 

Turkey Point power plant cooling canals that may very well affect the level of saltwater intrusion 

into the Biscayne Aquifer, the main source of drinking water for South Florida]. (0685-14 [Batista, 

Carlos])

Response: State and local agencies currently require monitoring of the cooling canals and 

nearby groundwater and Biscayne Bay, and the NRC review team is not aware of any plan or 

proposal to discontinue that monitoring. No changes were made to the EIS in response to this 

comment. 

Comment: MDC strongly emphasizes that the state certification for the Units 6 & 7 project, 

issued on May 19, 2013, was issued at a time when the impacts of the implementation of the 

Units 3 & 4 Uprate were not yet evident because some of the water quality monitoring data were 

either not yet available or had not yet been reviewed and analyzed. The most noteworthy issue 

to point out as it relates to the evaluation of the Units 6 & 7 project proposed RCW is the 

significant increase in the tritium concentration at the deep well of monitoring well cluster 

TPGW10, which is located on Biscayne Bay slightly north and east of the Turkey Point Plant 

and within the cone of influence of the proposed RCW, see Figure 1. (0110-1-8 [Hefty, Lee N.])

Response: The comment correctly states that there has been an increase in the concentration 

of tritium in groundwater near the Turkey Point site. Information in the EIS shows that this 

tritium and other constituents originating from the seepage of cooling-canal water have migrated 

into the groundwater in the vicinity of Turkey Point. The concentrations of tritium found in the 

aquifer, at less than 25 percent of the drinking water standard, are much lower than 

concentrations considered a health concern. The distribution of tritium and the other 

constituents in the aquifer could be affected to some degree by pumping of the planned RCWs 

beneath Biscayne Bay as a backup supply of cooling water. However, there is a very large 

volume of treated municipal wastewater available for this purpose, but the treated wastewater is 

not suitable for normal uses of freshwater, such as for drinking or agriculture. Accordingly, the 

treated municipal wastewater can be used for cooling proposed Turkey Point Units 6 and 7 

without affecting the ability to meet demands for freshwater. MDWASD is required to direct 60 

percent of the wastewater flows to reuse by 2025 and to cease using ocean outfalls by 2025 

under the Florida State Ocean Outfall Legislation Compliance Plan, Chapter 2008-232 Laws of 

Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. Therefore, the NRC staff concluded that the reclaimed-water supply 

is reliable and the RCWs would likely be used infrequently and for short durations. The review 

team nonetheless considered the potential impacts from migration of groundwater constituents 

including tritium in the review team evaluation of potential effects of operating the RCWs, which 

is set forth in Section 5.2.1.2 of the EIS. After publication of the draft EIS, the review team 

performed additional groundwater modeling of the interaction between the planned RCWs, the 

existing hypersaline plume, and the cooling canals using a two-dimensional cross-section model 

and a limited-extent three-dimensional model that accounted for fluid density effects caused by 

salinity and temperature. The results showed that changes in the concentration of salinity and 

other constituents in the aquifer near the site and beneath Biscayne Bay would be minor and 

would not have significant effects on drinking water wells or the water in Biscayne Bay. 

Appendix E NUREG–2176 E-196 October 2016
Comment: In September of 2012, tritium was identified by DEP, the SFWMD and MDC as the 

tracer to delineate vertical and horizontal extent of the CCS hypersaline plume. The increase in 

tritium concentration at TPGW-10D first became evident in the quarterly monitoring results for 

the June 2012 sampling, which coincides with the time that Unit 3 was being uprated and not all 

circulating pumps were operating, see Figure 2 attached. MDC believes that this is a significant 

finding because it appears to suggest that mobilization of the CCS hypersaline plume under the 

bay towards the area where the RCW are proposed to be installed may have been facilitated by 

the reduction in operation of the CCS circulating pumps. It is important to note the results of the 

aquifer performance test that FPL provided in support of the proposed radial collector wells. 

Although FPL did not provide the types of data that MDC requested, the limited data that was 

provided should be carefully reviewed. Most noteworthy are the extremely high levels of sulfate 

detected in the monitoring wells during the test in addition to the elevated sulfate levels in the 

surface waters of Biscayne Bay. These data suggest that the highly contaminated water 

beneath the cooling canals was drawn into the surface waters of Biscayne Bay, albeit with a 

much lower pumping volume during the test than would be realized when the radial collector 

wells are in operation. Determining whether operation of the radial collector wells, which would 

be the largest well field in Miami-Dade County in terms of daily pumped volumes, would result in 

violations of applicable water quality standards in the tidal waters of Biscayne Bay including 

Biscayne National Park is necessary. (0110-1-9 [Hefty, Lee N.])

Response: The NRC review team did review data from the pumping test on the Turkey Point 

peninsula, including the elevated sulfate concentrations. In addition to the review team’s 

conceptual understanding of the processes that would occur with RCW operation, the review 

team considered three independent modeling studies that are all consistent in projecting only 

insignificant alterations to both the Biscayne Bay and the surficial aquifer, even in view of the 

observed elevated sulfate concentrations . The review team considered a wide range of 

baseline environmental conditions to reflect the uncertainty in the baseline environment 

associated with various proposed actions associated with the IWF, climate change, and 

geohydrologic parameter uncertainty. While the environmental baseline may change 

significantly, the incremental alteration to the hypersaline plume associated with operation of the 

RCWs remains minor. In view of the above, the review team revised the text in Sections 2.3, 

5.2, and G.3.2 of the EIS to expand and clarify the process and findings of the analysis of the 

potential alteration of the hypersaline plume caused by the operation of the RCW system. 

Comment: Section 2.3, Water (pg. 2-26): The DEIS states that the alternate cooling water 

source supplied by the radial collector wells would be limited to a maximum of 60 days per year 

by the Florida State Conditions of Certification. The DEIS is not clear regarding what 

contingency plans will be implemented should the 60 day limitation be exhausted and the 

reclaim water supply is not available. FPL has stated that the Conditions of Certification 

addresses the contingency plan for emergency water allocation. Please clarify this issue with a 

detailed explanation of contingency plans in the FEIS. (0617-1-7 [Mueller, Heinz J.])

Response: Cooling the main condenser is not a safety function in the AP1000 

design. Accordingly, there is no NRC requirement for a contingency plan to supply backup 

cooling water to the main condenser if reclaimed water is not available and the 60-day limitation 

on RCW pumping is exhausted. The plant can be safely shut down if water is not available from 

either source. Safety-related cooling water is stored onsite, and can be replenished from 

multiple sources. While the EIS analysis assumes that the RCWs would not operate more than 

60 days per year, the primary source of cooling water—reclaimed wastewater from the 

MDWASD—should be highly reliable, and therefore the availability of backup cooling water 

supplies need not be evaluated. Further, the review team also considered alternative sources 

Appendix E October 2016 E-197 NUREG–2176
of cooling water in EIS Section 9.4.2, none of which are environmentally preferable to the 

proposed sources of cooling water. In view of the high reliability of the reclaimed wastewater 

source and the availability of the RCW system as a backup, there is no need to consider 

additional backup sources of cooling water. 

Comment: However, the IWF will be accepting wastewater from the new reactors (Units 6 and 

7), and these additional wastewater streams include excavation dewatering, stormwater run-off, 

muck spoil run off and drift deposition. There is a potential for these additional wastewater 

streams to increase nutrient loading, including nitrate, for which EPA has set a drinking water 

maximum contaminant level (MCL), to the underlying Biscayne Aquifer, (an Underground 

Source of Drinking Water under the SOWA), given the existing hydrologic connection between 

the IWF and groundwater. (0617-1-15 [Mueller, Heinz J.])

Response: As discussed in the EIS, the combined impacts of the planned discharge of 

groundwater from excavation dewatering and stormwater to the CCS while building the plants, 

and the chemical inputs to the CCS from muck spoils runoff and cooling-tower drift are expected 

to cause minor changes in the water levels and chemistry of the CCS. Potential changes in 

nitrate concentration from muck runoff are presented in the EIS. Water from the CCS does 

currently seep into the Biscayne aquifer below the CCS beneath the site. However, the EIS 

analysis shows that the effects of the expected volume and concentration of any seepage 

resulting from discharges to the CCS during plant construction would be minor and 

temporary. Any increase in volume and concentration of the seepage from the CCS to the 

underlying portion of the Biscayne aquifer due to construction of proposed Units 6 and 7 is not 

expected to have a noticeable impact on the quality of groundwater in the areas of the Biscayne 

aquifer that meet USDW criteria for TDS. The review team also responded to similar comments 

in E.2.7, “Comments concerning hydrology - surface water.” 

Comment: The EPA has several serious concerns related to groundwater, with the paramount 

concern being the condition of the Biscayne Aquifer, an EPA-designated sole source aquifer 

serving as a drinking water resource in the south Florida area. The Biscayne aquifer has already 

suffered significant and unacceptable hypersalinity impacts, and the EPA is concerned that the 

proposed project may result in further migration of the hypersaline plume. (0617-1-17 [Mueller, 

Heinz J.])

Response: After publication of the draft EIS, the review team used a third model, called the 

RTF (Review Team Focused) model, to performed additional groundwater modeling of the 

interaction between the planned RCWs, the existing hypersaline plume, and the cooling 

canals. This third model included using a two-dimensional cross-section model and a limitedextent three-dimensional model. Simulations were performed to better understand how the 

existing hypersaline plume may be affected by RCW pumping combined with remediation 

actions recently stipulated in a consent agreement between FPL and Miami-Dade County. 

The RTF model was useful in showing salinity changes that occur in the aquifer near the RCWs 

when the wells are operated. The results showed that when the wells are not operating, 

hypersaline water from the cooling canals is present in the high permeability zone where the 

well laterals are installed. This saline water is drawn into the wells during the first few days of 

RCW pumping, resulting in increasing, then decreasing salinity at the well. The RTF model 

predicts that the salinity of the water produced by the operating RCW would eventually drop to 

about the concentration of the bay water. Water flowing down through the bed of the bay and 

into the RCWs is therefore expected to have about the same salinity as bay water. When RCW 

pumping ceases, water in the high permeability zone again increases in salinity because of the 

Appendix E NUREG–2176 E-198 October 2016
migration of water from the hypersaline plume. This migration of hypersaline water into the high 

permeability zone would occur regardless of the presence of the RCWs. 

Predicted future change in sea level and its effect on interactions between the RCWs and the 

hypersaline plume were also simulated. The additional modeling confirmed that pumping of the 

RCWs would move hypersaline water toward the RCWs and would remove some groundwater 

captured by the RCWs from the hypersaline plume region of the Biscayne aquifer. The model 

also indicated that RCW pumping is not likely to reduce the effectiveness of hypersaline plume 

remediation actions specified in the consent agreement. Additional discussion of the potential 

impacts of the proposed new units on groundwater in the Biscayne aquifer has been added to 

the EIS to reflect these results. 

Comment: These are just some of the more obvious impacts from this expansion. When the 

first two nuclear reactors and fossil fuel plants were completed at Turkey Point, regulators failed 

to consider the impacts of dumping hot water (used for cooling the generators) directly into 

Biscayne Bay. When the 5,000 acres of cooling canals - likely the largest radiator on the planet 

(and clearly visible from space) - were carved out of natural mangrove habitat to correct the 

problem, regulators again failed to consider that the extremely hot salty water would drop 

through the surrounding limestone and degrade the underlying Biscayne Aquifer. The known 

risks from this project are bad enough - very hard to plan for the unknown and unconsidered 

risks as well as inevitable human error. (0240-12 [Commenters, Multiple])

Comment: The EPA has several serious concerns related to groundwater, with the paramount 

concern being the condition of the Biscayne Aquifer, an EPA-designated sole source aquifer 

serving as a drinking water resource in the south Florida area. The Biscayne aquifer has already 

suffered significant and unacceptable hypersalinity impacts, and the EPA is concerned that the 

proposed project may result in further migration of the hypersaline plume. (0617-1-17 [Mueller, 

Heinz J.])

Response: The salinity and total dissolved solids TDS in the water in the Biscayne aquifer in 

the vicinity of Turkey Point exceed USDW standards because of saltwater intrusion from the sea 

and intrusion of the CCS hypersaline plume. As a result, the Biscayne aquifer near the site 

cannot be used as a drinking water source without treatment. In south Florida, the amount of 

saltwater intrusion has increased over the past several decades for reasons unrelated to 

operations at Turkey Point, including the drainage of wetlands and groundwater pumping in 

inland areas. Seepage of hypersaline water from the CCS (cooling canal system) associated 

with the existing Turkey Point Units 3 and 4 has also resulted in areas of groundwater salinity 

higher than seawater near the CCS. 

As discussed in the EIS, only the RCWs (radial collector wells), which are planned as a back-up 

cooling water source for Units 6 and 7, and limited inputs to the CCS while building the plants 

are expected to have any potential impact on the salinity of groundwater in the Biscayne 

aquifer. As discussed in the EIS, the combined impacts of the planned discharge of 

groundwater from excavation dewatering and stormwater to the CCS while building the plants, 

and the chemical inputs to the CCS from muck spoils runoff and cooling tower drift during plant 

operations are expected to cause minor changes in the water levels, salinity, or other chemical 

concentrations of the CCS. As stated in the EIS, saline water drawn from the RCWs beneath 

Biscayne Bay would only be used when reclaimed treated wastewater is not available in 

sufficient quantity or quality, and for a maximum of 60 days per year as permitted under the 

Florida State COCs. The potential effects of operating the RCWs are described in Section 

5.2.1.2 of the EIS. During the limited periods of RCW pumping, some water would be removed 

Appendix E October 2016 E-199 NUREG–2176
from the Biscayne Aquifer, which would potentially cause hypersaline water to move under 

Biscayne Bay toward the RCWs. The review team evaluated information about the reliability of 

the components of the reclaimed-water system and determined that the RCW supply system 

would be likely be called into use infrequently and for durations much shorter than 60 days. The 

review team determined that proposed use of the RCWs as a backup supply of cooling water for 

short periods of time is likely to have small impacts on groundwater users or on the extent of 

saltwater intrusion based on the FPL model analysis, USGS modeling analysis, the NRC review 

team's modeling of the CCS-RCW interaction, and the knowledge that environmental monitoring 

and potential mitigation measures are required under the COCs imposed by Florida State. The 

review team responded to similar comments in Section E.2.7, “Comments concerning hydrology 

– surface water.” 

Comment: Comprehensive Everglades Restoration Plan (CERP). The EPA is concerned with 

the project's potential impacts to CERP. The CERP is a 30 year, $10-12 billion ecosystem 

project designed to restore the greater Everglades ecosystem. CERP is the largest ecosystem 

restoration project in the US, and although the Corps and the South Florida Water Management 

District (SFWMD) are the primary cost share partners, several other local, state, Federal 

agencies (including EPA), and NGOs are active partners in CERP. A primary goal of CERP is to 

restore flows to the greater Everglades and Everglades National Park (ENP). One of the CERP 

projects is the Biscayne Bay Coastal Wetlands (BBCW) project. EPA is concerned that the 

proposed project will impact BBCW. In particular, L-31E canal is an important part of BBCW. 

The DEIS states: "Groundwater flow in the Biscayne aquifer is also affected by an interceptor 

ditch adjacent to the west side of the cooling canals and east of the L-31E Canal. Water is 

pumped from the interceptor ditch into the IWF cooling canals when needed to maintain a water 

level in the ditch that is lower than the water level in the L-31E Canal. This is designed to keep 

groundwater from moving westward from the interceptor ditch toward the L-31E Canal and keep 

cooling canal water from affecting groundwater quality to the west (FPL 2014-TN4069). 

However, because deeper permeable layers within the Biscayne aquifer may be isolated from 

hydraulic head in the ditch by lower permeability layers, it is possible that some water from the 

cooling canals could move to the west. As discussed in Section 2.2.3 below, monitoring by FPL 

indicates that hypersaline water from the cooling canals has moved west of the L31-E Canal in 

the deeper part of the Biscayne aquifer." Also, when discussing project components of the 

BBCW, the DEIS states, "L-31 East Flow Way -isolation of the L-31E Canal from the major 

discharge canals and allowing freshwater flow through the L-31E Levee into saltwater marsh. 

Pump stations and culverts are to be added to facilitate freshwater discharges." The FEIS 

should clarify whether the NRC anticipates that the proposed project will continue to use water 

from L-31E to augment waters for the IWF, and if so, what the impacts would be to the L31N 

canal. Also, impacts to the Biscayne Aquifer and further movement of the saline water into 

Biscayne Bay should be further defined and detailed. The SFWMD permitted FPL to continue 

pumping water from L31E canal into the IWF for 2 years, but there is no discussion regarding 

this subject in the DEIS. EPA is concerned that continued use of the L31E canal as a source of 

water for the cooling canal system could impact the success of the BBCW and possibly 

exacerbate movement of salinity through the Biscayne Aquifer. (0617-1-25 [Mueller, Heinz J.])

Response: There is no plan for the proposed Units 6 and 7 to use any water from the L-31E 

Canal or any other freshwater canals. The addition of water to the IWF from the L-31E Canal 

and any other sources is unrelated to planned Units 6 and 7, which would not use the IWF for 

cooling. In addition to the review team’s conceptual understanding of the processes that would 

occur with RCW operation, the review team considered three independent modeling studies that 

are all consistent in projecting that RCW operation would result in only insignificant alterations to 

both the Biscayne Bay and the surficial aquifer. The review team considered a wide range of 

Appendix E NUREG–2176 E-200 October 2016
baseline environmental conditions to reflect the uncertainty in the baseline environment 

associated with various proposed actions associated with the IWF, climate change and 

geohydrologic parameter uncertainty. While the environmental baseline may change 

significantly, the incremental alteration to the hypersaline plume associated with operation of the 

RCWs remains minor. The review team revised the text in Sections 2.3, 5.2, and G.3.2 of the 

EIS to expand and clarify the process and findings of the analysis of the potential alteration of 

the hypersaline plume caused by the operation of the RCW system. 

Comment: Recommendations: The EPA recommends that the FEIS better describe the 

interaction between the FPL's use of L31E canals for the IWF in the existing facility, and 

proposed project and potential impacts to the BBCW and Biscayne Aquifer. The EPA also 

recommends that the FEIS discuss the 2-year SFWMD permit to pump water from the L31E 

canal into the IWF, and resulting impacts to BBCW and Biscayne Aquifer. EPA also notes that, 

effective July 14, 2014, SFWMD updated consumptive use permitting (CUP) criteria as part of a 

statewide effort headed by the FDEP, and joined by all five water management districts. The 

FEIS should document any changes to existing or future permitting actions relative to this 

criteria. (0617-1-26 [Mueller, Heinz J.])

Response: The building and operation of the proposed plants has no significant nexus with the 

SFWMD permitting of FPL’s request to pump water from the L-31E Canal into the IWF or with 

the consumptive use permitting criteria mentioned in the comment. In addition to the review 

team’s conceptual understanding of the processes that would occur with RCW operation, the 

review team considered three independent modeling studies that are all consistent in projecting 

only insignificant alterations to both the Biscayne Bay and the surficial aquifer. The review team 

considered a wide range of baseline environmental conditions to reflect the uncertainty in the 

baseline environment associated with various proposed actions associated with the IWF, 

climate change, and geohydrologic parameter uncertainty. While the environmental baseline 

may change significantly, the incremental alteration to the hypersaline plume associated with 

operation of the RCWs remains minor. The review team revised the text in Sections 2.3, 5.2, 

and G.3.2 of the EIS to expand and clarify the process and findings of the analysis of the 

potential alteration of the hypersaline plume caused by the operation of the RCW system. 

Comment: Radionuclides. Existing and historic operations at Turkey Point have resulted in 

radionuclides (tritium) migrating into the hydrologic complex. The DEIS discusses deep-well 

injection scenarios and postulated doses in Section 5.9.3.3. One of these scenarios includes 

postulated maximum radionuclide concentrations of tritium, strontium and cesium (page 5-108). 

Although the DEIS states that there would be no observable health impacts on the public from 

normal operation of the proposed units (page 5-109), EPA has concerns regarding potential 

environmental pathways and cumulative impacts related to radionuclides. Recommendations:

The FEIS should provide updated information regarding the progress with defining the extent of 

the tritium contamination. Updated sampling data should be included or referenced in the FEIS, 

with modeling information included regarding potential cumulative impacts. (0617-2-1 [Mueller, 

Heinz J.])

Response: Information about the distribution of tritium in the Biscayne aquifer that resulted 

from the seepage of water from the IWF cooling canals is provided in Chapter 2 of the draft 

EIS. This information was collected by the Units 3 and 4 Uprate Monitoring Project. FPL is also 

undertaking a groundwater monitoring program as delineated in the SFWMD's "FPL Turkey 

Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan" (SFWMD 

2009-TN149). In this plan, FPL commits to monitoring tritium as a "tracer suite" for tracking the 

movement of the CCS plume. This plan also states: "The Agencies and FPL recognize that the 

Appendix E October 2016 E-201 NUREG–2176
concentrations of tritium from the CCS water are expected to fall below the regulatory standard 

used to identify the potential for human health concerns. Accordingly it is mutually understood 

tritium is being monitored only as a potential tracer for identifying contributions of CCS water as 

a source." 

Comment: ...hot water leaching through porous limestone [is unacceptable]. (0245-5 [Lindsey, 

Jerrie])

Comment: Possibility of excess thermal discharge into Boulder Zone. In the event that the 

cooling towers, designed to dissipate a heat load of 22 7.63 x 109 Btu/hr (1.53 x 1010 Btu/hr for 

both units) (3-25) are unable to discharge this amount of thermal energy, then heated 

wastewater would likely enter the deep injection well. Has any research been done to calculate 

the impact of the additional BTUs on the water in the Lower Floridan Aquifer? (0612-1 [Teas, 

James])

Comment: Possibility of upward migration occurring at lower than 85 Mgd maximum injection 

rate due to increased wastewater buoyancy. "An EPA study of 93 deep-well injection facilities in 

South Florida also indicates that fluid movement underground is influenced by buoyancy 

created by temperature and density differences between native and injected waters." (2-56). Is it 

possible that heated wastewater, which would affect it temperature and therefore, its buoyancy, 

could exhibit upward migration at lower injection rates? (0612-2 [Teas, James])

Comment: The proposal is to take the waste hot heated water from the nuclear reactors and 

pump it underground, deep injection. My question is, for the NRC, has this been done, and what 

-- has anyone done any research? Are there any impacts on pumping heated effluent down into 

deep well injection, not just injecting effluent? (0723-5-6 [Teas, Jim])

Response: As discussed in the EIS, an overall upward hydraulic gradient is expected to 

develop in the Boulder Zone because of the warmth and relatively low salinity of the injected 

reclaimed water after it has gone through the cooling towers. 

After passing through the cooling system, the injected effluent would be warmer than the native 

water in the Boulder Zone. In addition, reclaimed water would be less saline that native water in 

the Boulder Zone. As a result, the injected effluent from reclaimed water would be more 

buoyant. The higher buoyancy of the wastewater does increase the upward driving force. In 

general, salinity differences contribute more to buoyancy than thermal differences. However, 

both the thermal and salinity components of buoyancy were evaluated as part of the analysis of 

the impacts of deep well injection in the EIS. Thermal impacts on the fate and transport of 

injected effluent were evaluated in numerical modeling performed by FPL and described in 

Section 5.2.1.3 of the EIS. Information provided in the EIS was summarized from an FPL report 

describing this modeling effort in greater detail (FPL2013-TN3931). While the actual maximum 

expected temperature differential between injected and native Boulder Zone waters is expected 

to be 14oF, FPL used an extreme temperature differential of 50oF in modeling to determine the 

impacts on vertical migration. Based on this, FPL determined that effluent injected into the 

Boulder Zone at the decreased rate (relative to current SDWWTP injection rates) would migrate 

approximately 300 ft into the base of the 1,450 ft thick MCU at the end of the 100-year 

simulation. This estimate of vertical migration was confirmed by the review team through 

independent calculations, as described in Section 5.2.1.3 and Appendix G of the EIS. 

This indicates that upward migration is expected to be limited by low-permeability confining 

units. Additional information has been added to the EIS to better describe the confining nature 

Appendix E NUREG–2176 E-202 October 2016
of low-permeability units within the MCU, the causes of vertical migration where it has been 

observed at other injection sites, and the expected fate and transport of injected effluent at the 

Turkey Point site. Results from regional and site-specific modeling, studies of deep well 

injection, and characterization of geology at the site support the review team conclusion that 

significant upwelling out of the Boulder Zone is not expected to occur and that, if upwelling does 

occur, it would not likely impact the Upper Floridan aquifer. Additionally, the construction, 

testing and monitoring requirements of the FDEP UIC program are designed to provide more 

characterization of the nature of geology at the injection site and detect and mitigate any 

upwelling that may occur. This is discussed in greater detail in the updated sections of the EIS 

mentioned above. 

Comment: In addition, due to substrata, Florida is a well-known hotspot for sinkholes. (0440-6

[Hoyle, Lester and Judy])

Response: Extensive geological and geophysical studies were performed by the applicant to 

make sure that there were no caverns beneath the proposed plant structures that could collapse 

and create a sinkhole. The potential for sinkholes to affect plant structures is primarily a safety 

concern and is addressed in the applicant's Final Safety Analysis Report and the NRC's Safety 

Evaluation Report. An environmental impact might result from contaminated water entering the 

shallow aquifer by draining into a sinkhole if one were to develop during construction of facilities 

such as pipelines or power lines. FPL has committed to following BMPs designed to stop such 

contamination of both surface water and groundwater. Therefore, the staff determined that 

environmental impacts from potential sinkhole formation associated with building and operating 

proposed Units 6 and 7 would be negligible. No changes were made to the EIS based on this 

comment. 

Comment: I note that tritiated water, due to wastewater passing through the nuclear reactors, 

cannot be separated out: "Liquid radioactive effluent would be discharged to the deep-injection 

wells" (3-34). Should there be upward migration of wastewater from the Booulder Zone, it will 

come with its own built-in tracer. (0612-6 [Teas, James])

Response: As described in the EIS, tritium and other radionuclides would be injected to the 

Boulder Zone and could be used as a tracer of water movement. No changes were made to the 

EIS in response to this comment. 

Comment: And the second question is, given the limited capacity of the Biscayne Bay aquifer, 

has the Draft, the reviewers who drew up the Draft, looked at the whole aquifer and all the 

various impacts that it suffers now? The draw-downs for example, or the effects, rather, of the 

proposed enlargement of rock mining in northwest Dade County, which would affect both the 

Everglades and the aquifer itself. And factor that into a model which projects forward the future 

of the aquifer. Or has the study been so narrow that it's artificial and has no relationship to the 

life of the whole aquifer and the needs of the population dependent on it? (0721-17-2 [Breslin, 

Tom])

Response: Chapter 7 of the EIS analyzes the cumulative impacts of the proposed Turkey Point 

Units 6 and 7, and other past, present, and reasonably foreseeable projects, on water use and 

water quality. This analysis includes cumulative impacts from the mining of fill needed to build 

the proposed plants and other rock mining activities. There is also information in the water 

sections of the EIS, including newly added information to reflect additional review team 

modeling, concerning the potential effects of the proposed units on the Biscayne aquifer. No 

changes were made to the EIS in response to this comment. 

Appendix E October 2016 E-203 NUREG–2176
Comment: After use some of this wastewater would be discharged underground. The possible 

impacts of adding chemical contaminants into our groundwater has not been adequately 

analyzed in this EIS. Furthermore, the backup cooling system for the new reactors could 

become one of the largest well fields in terms of water consumption in the entire Southeast 

region of the United States. Proposed radial collector wells would stretch out underneath 

Biscayne Bay, removing as much as 7.4 billion gallons of water per year. Just in comparison, 

the entire Florida Keys uses just over 6 billion gallons of water per year. The withdrawal of this 

water could increase salinity in Biscayne Bay and increase the rate of salt water intrusion into 

our very limited fresh water resources. (0721-9-6 [McLaughlin, Caroline])

Comment: We risk poisoning our water sources at our grave peril. (0732-1 [Horiwitz, Laura])

Response: After cooling the plant, the reclaimed water would be injected into the saline 

Boulder Zone aquifer. As described in the draft EIS, upward migration from the Boulder zone to 

shallower aquifers used for drinking water is expected to be limited by low permeability confining 

units. If upward leakage of wastewater through the confining layers did occur, it would likely be 

detected in the overlying monitoring wells and mitigated as required by the FDEP UIC 

program. The potential impact of upward leakage is assessed in Appendix G of the EIS and 

discussed in EIS Section 5.2.1.3. 

In regard to the Biscayne aquifer, saltwater from the sea has already intruded into the 

groundwater in the Biscayne aquifer in the vicinity of the Turkey Point site, which has resulted in 

elevated salinity in that groundwater. This saltwater intrusion from the sea is unrelated to 

operations at Turkey Point. Because of its elevated salinity, groundwater from the Biscayne 

aquifer in the vicinity of the Turkey Point site cannot be used as a drinking water source without 

treatment. Seepage of saline water from the cooling canals associated with the existing Turkey 

Point Units 3 and 4 has also resulted in locally higher groundwater salinity near the IWF cooling 

canals. Cumulative impacts of the proposed RCW pumping on the existing hypersaline plume 

were considered in the EIS. 

Analyses from the USGS groundwater-surface water model presented in the EIS show that in 

the absence of remediation of the IWF hypersaline plume, increases in groundwater salinity 

may occur inland from Turkey Point because of movement of the existing hypersaline plume, 

regardless of whether or not the proposed units are built and operated. The model-predicted 

increase in groundwater salinity is not caused by RCW pumping or other activities related to the 

proposed units. The model-predicted increase in groundwater salinity also does not reach the 

location of existing drinking water wells. 

As stated in the draft EIS, saline water from the RCWs beneath Biscayne Bay would only be 

used when reclaimed treated wastewater is not available in sufficient quantity or quality, and for 

a maximum of 60 days per year that is permitted under the Florida State COCs. The potential 

effects of operating the RCWs are described in Section 5.2.1.2 of the draft EIS. During the 

limited periods of RCW pumping, some water would be removed from the Biscayne Aquifer, 

which would potentially cause hypersaline water to move under Biscayne Bay toward the 

RCWs. The review team evaluated information about the reliability of the components of the 

reclaimed-water system and determined that the RCW supply system would likely be called into 

use infrequently and for durations much shorter than 60 days. The review team determined that 

proposed use of the RCWs as a backup supply of cooling water for short periods of time is likely 

to have small impacts on groundwater users or on the extent of saltwater intrusion based on the 

FPL model analysis, modeling analysis performed by the USGS, the NRC staff's modeling of the 

Appendix E NUREG–2176 E-204 October 2016
CCS-RCW interaction, and the knowledge that environmental monitoring and potential 

mitigation measures are required under the COCs imposed by Florida State imposed. 

Comment: Although the proposal by FPL for Turkey Point 6 and 7 indicates they will rely on 

Cooling towers and reclaimed water, as opposed to the current cooling canals system used for 

TP 3&4, the draft statement fails to account for the several potential scenarios of a failure of, or 

destruction of the cooling towers, or failure of a sufficient amount of the predicted required reuse 

water from Miami Dade County water and sewer. If either system fails, the backup plan would 

have to rely on the upper Floridan aquifer, thereby perpetually competing with the sole source of 

drinking water for four million plus residents in South Florida. (0145-3 [Lerner, Cindy])

Response: The review team considers the failure or destruction of the cooling towers to be 

very unlikely. There is no plan to use the Upper Floridan aquifer for cooling water. Reclaimed 

wastewater would be the primary source of cooling water for the proposed reactors. Saline 

water from the RCWs beneath Biscayne Bay would only be used when reclaimed treated 

wastewater is not available in sufficient quantity or quality, and for a maximum of 60 days per 

year that is permitted under the Florida State COCs. There is a very large volume of treated 

municipal wastewater that can be used without affecting the ability to meet demands for fresh 

water. MDWASD is required to direct 60 percent of the wastewater flows to reuse by 2025 and 

to cease using ocean outfalls by 2025 under the Florida State Ocean Outfall Legislation 

Compliance Plan Chapter 2008-232 Laws of Florida Wastewater Disposal/Ocean Outfalls 

[Section 403.086 (9), Florida Statutes and Amendment CS/SB 444]. 

Comment: The first concern is that the Draft EIS fails to adequately account for the significant 

and substantial cumulative adverse impact that the proposed two new nuclear power plants will 

have on our water supply, the Biscayne Aquifer fed by the Upper Floridan Aquifer as a result of 

the current crisis conditions and management plan operating for Turkey Point 3&4. While there 

was a finding that the Biscayne Aquifer is both vulnerable to the significant water usage needs 

of the Turkey Point Plant and critical to the continual supply of fresh water to Miami Dade and 

Broward Counties, the Draft EIS has admittedly not addressed the current crisis conditions 

under which Turkey Point 3& 4 operate. This is a fatal flaw. (0145-2 [Lerner, Cindy])

Response: Chapter 7 of the draft EIS analyzes the cumulative impacts of proposed Turkey 

Point Units 6 and 7, and other past, present, and reasonably foreseeable projects on water use 

and water quality. Information in the water sections of the EIS, including newly added 

information, acknowledges the existing site conditions related to Units 3 and 4. Water in the 

Biscayne aquifer in the vicinity of Turkey Point has elevated salinity and TDS above USDW 

standards because of saltwater intrusion from the sea and it cannot be used as a drinking water 

source without treatment. In South Florida, the amount of saltwater intrusion has increased 

over the past several decades because of the drainage of wetlands and groundwater pumping 

in inland areas that is unrelated to operations at Turkey Point. Seepage of hypersaline water 

from the CCS (cooling canal system) associated with the existing Turkey Point Units 3 and 4 

has also resulted in areas of groundwater salinity higher than seawater near the CCS. As 

discussed in the draft EIS, only the RCWs (radial collector wells), planned as a back-up cooling 

water source, and limited inputs to the CCS while building the plants are expected to have any 

potential impact on the salinity of groundwater in the Biscayne aquifer. As discussed in the draft 

EIS, the combined impacts of the planned discharge of groundwater from excavation 

dewatering and storm water to the CCS while building the plants, and the chemical inputs to the 

CCS from muck spoils runoff and cooling tower drift are expected to cause minor changes in the 

water levels, salinity, or other chemical concentrations of the CCS. As stated in the draft EIS, 

saline water from the RCWs beneath Biscayne Bay would only be used when reclaimed treated 

Appendix E October 2016 E-205 NUREG–2176
wastewater is not available in sufficient quantity or quality, and for a maximum of 60 days per 

year that is permitted under the Florida State Conditions of Certification (COCs). The potential 

effects of operating the RCWs are described in Section 5.2.1.2 of the draft EIS. During the 

limited periods of RCW pumping, some water would be removed from the Biscayne Aquifer, 

which would potentially cause hypersaline water to move under Biscayne Bay toward the 

RCWs. The review team evaluated information about the reliability of the components of the 

reclaimed-water system and determined that the RCW supply system would likely be called into 

use infrequently and for durations much shorter than 60 days. The review team determined that 

proposed use of the RCWs as a backup supply of cooling water for short periods of time is likely 

to have small impacts on groundwater users or on the extent of saltwater intrusion based on the 

FPL model analysis, modeling analysis performed by the USGS, the NRC review team's 

modeling of the CCS-RCW interaction, and the knowledge that environmental monitoring and 

potential mitigation measures are required under the COCs imposed by Florida State. 

Comment: FPL now consumes vast amounts of our precious water and continues to plan for 

future use, by drilling six Upper Floridan production wells, and the pumping of 14 million gallons 

per day from those wells into the Cooling canal system. The permitted temperature of 100 

degrees can not be sustained, in fact it had heated to as high as 104 degrees, without the 

additional draw of waters from the canal and or the aquifer, This necessitated that FPL seek a 

permit to utilize up to 100 million gallons a day of water from the L-31 canal, a canal which is a 

critical component of the health of Biscayne Bay. FPL has also sought permission from the 

State of. Florida to pump 14 million gallons per day of water from the Upper Floridan Aquifer into 

the Cooling Canal system and they have received approval to draw 1 million gallons a day for a 

temporary period of time. However, FPL is now seeking a permit to extend access to these 

water resources for the next two years, hoping that they will solve the problem in that time 

period. At present time FPL does not have a long term solution. (0145-5 [Lerner, Cindy])

Response: There is no plan for the proposed units 6 and 7 to use any water from the L-31E 

Canal or any other freshwater canals. The addition of water to the IWF from the L-31E Canal, 

the upper Floridan aquifer, or other sources is unrelated to building or operating planned Units 6 

and 7, which would not use the IWF (industrial wastewater facility) for cooling. Water in the 

Biscayne aquifer in the vicinity of Turkey Point has elevated salinity because of saltwater 

intrusion from the sea and cannot be used as a drinking water source without treatment. In 

South Florida, the amount of saltwater intrusion has increased over the past several decades 

because of the drainage of wetlands and groundwater pumping in inland areas that is unrelated 

to operations at Turkey Point. However, seepage of saline water from the cooling canals 

associated with the existing Turkey Point Units 3 and 4 has also resulted in locally higher 

groundwater salinity near the cooling canals. Water in the cooling canals has a higher salinity 

than seawater. Although the water in the cooling canals is not directly connected to Biscayne 

Bay or Card Sound, there is groundwater flow back and forth between the cooling canals and 

the Biscayne Aquifer beneath Biscayne Bay. This exchange of water would occur regardless of 

whether proposed Units 6 and 7 are built or operated. 

However, the construction and operation of Units 6 and 7 would affect the Biscayne aquifer in 

some ways that are described in the draft EIS. Some groundwater would be removed from the 

aquifer during plant construction by dewatering of the proposed plant excavations. Some 

groundwater would also be removed during plant operation by pumping from the proposed 

RCWs (radial collector wells) as a backup source of makeup water for reactor cooling. Saline 

water from the RCWs beneath Biscayne Bay would only be used when reclaimed treated 

wastewater is not available in sufficient quantity or quality, and for a maximum of 60 days per 

year that is permitted under the Florida State COCs (Conditions of Certification). These limited 

Appendix E NUREG–2176 E-206 October 2016
periods of pumping of the RCWs would reduce the hydraulic head in the aquifer beneath 

Biscayne Bay near the wells and, therefore, would remove some water from the 

aquifer. However, the proportion of water flowing into the RCWs from the aquifer is expected to 

be small, and more than 95 percent of the water would flow into the RCWs from the overlying 

Biscayne Bay. This estimate is supported by separate groundwater modeling efforts performed 

by FPL and by the USGS. The models indicated that pumping the RCWs for less than 60 days 

per year is unlikely to cause a noticeable change in the existing extent of salt water intrusion or 

to noticeably lower groundwater levels so as to affect other users of the Biscayne aquifer. 

The review team recognizes that complete knowledge of the hydrologic system associated with 

the RCWs is not now available, and that uncertainties therefore remain in the impact 

analysis. Further, future operational and environmental conditions are not known with 

certainty. A vast number of future scenarios are plausible. The sources of uncertainty in the 

RCW analysis include: heterogeneity in subsurface parameters, lack of experience with RCW 

systems in carbonate strata, and uncertainty in the potential need for using the backup water 

supply. Uncertainties in the future site environment include: freshening of the IWF cooling 

canals, remediation of the subsurface hypersaline plume, and the magnitude and rate of future 

sea-level rise. 

Determinations in this EIS related to groundwater are based on the FPL numerical model 

analysis, the USGS model analysis, the review team’s independent numerical modeling 

analysis, and the review team’s knowledge and expertise. The conceptual models that served 

as the basis for the numerical models are based on available characterization information for 

the Turkey Point site and surrounding region. Uncertainties in the information and conceptual 

model were addressed in some cases by performing multiple model runs while varying key 

parameters in the model and in other cases by using conservative parameter values. However, 

uncertainties remain that do not allow the review team to assert that no other conceptual models 

that may result in more adverse impacts from RCW operation are plausible. Heterogeneity in 

subsurface parameters, lack of experience with RCW systems in carbonate strata, and 

uncertainty in the future site environment (e.g., freshening of IWF, remediation of subsurface 

hypersaline plume, sea-level rise) all warrant the review team to exercise care to avoid relying 

on numerical models alone. Because of this, the review team does not rely solely on the output 

of any numerical model. 

Numerical models are numerical representations of complex processes occurring in three 

dimensions over time. The appropriate role of a numerical model is to test assumptions of the 

behavior of complex systems. While running a numerical model numerous times with different 

parameters cannot compensate for all uncertainties, the models employed here have been 

tested and benchmarked within the conditions that limit their application. In this assessment the 

review team used models to test possible consequences of changes in the affected environment 

and uncertainty in some subsurface parameters within the capability of the models 

employed. This information was combined with the geography of the RCW field (such as the 

relatively short distance from the laterals to the bottom of Biscayne Bay relative to the distance 

from the laterals to the Homestead well fields) and the COC requirement of a monitoring 

program with mitigation options. The review team determined that the proposed monitoring of 

RCW construction and operation that is included is sufficient to detect unexpected behavior in a 

timely manner. While all possible mitigation measures have not yet been spelled out, in 

accordance with the COCs, the review team considers the ultimate mitigation of ceasing 

operation of the RCWs as ensuring prevention of any impacts in a timely manner. “When harm 

occurs, or is imminent, SFWMD will require Licensee to modify withdrawal rates or mitigate the 

harm” (FDEP 2014-TN4371). 

Appendix E October 2016 E-207 NUREG–2176
Comment: II. The Analysis of Direct, Indirect, and Cumulative Impacts of Proposed 

Radial Collector Wells is Inadequate. Some of our principal concerns regarding the potential 

adverse environmental impacts of this project are centered on the operation of the radial 

collector wells and their impacts on surrounding ecological areas. In order to dissipate waste 

heat generated by Units 6 & 7, two sources of water are identified for use in the DEIS. Up to 90 

million gallons of water per day (MGD) of reclaimed wastewater from Miami Dade County will be 

used as the primary source of cooling water. However, when this water source is unavailable or 

insufficient in supply, radial collector wells will draw water from under Biscayne Bay as a backup 

water supply. The DEIS proposes the construction of four radial collector wells, which according 

to FPL, will withdraw saltwater from the Biscayne Aquifer. Radial wells would extend 900 feet 

horizontally beneath Biscayne Bay and would be installed approximately 25 to 40 feet below 

sediment surface. [Footnote 9: United States Nuclear Regulatory Commission, Environmental 

Impact Statement for Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7, 

February 2015, NUREG-2176, 3-9.] Operation of the radial collector wells is to be limited to 60 

days per year, with a maximum of volume of 7.5 billion gallons of water that may be pumped 

during that period. [Footnote 10: NRC, DEIS, 5-13.] It is important to note that radial collector 

well structures would be located under navigable Waters of the United States, as regulated 

under the Clean Water Act. [Footnote 11: 40 C.F.R. § 230.3.] Radial collector wells such as 

those described in the DEIS have never before been constructed in an estuarine environment 

anywhere else in the world. [Footnote 12: West, B. United States Department of the Interior, 

National Park Service Letter to A. Williamson, U.S. Nuclear Regulatory Commission, November 

25, 2014, SER PC, 6.] A huge degree of uncertainty comes into play when predicting the 

impacts of the construction and operations of these wells on the surrounding environment, 

including the resources of Biscayne National Park, which are within the cone of influence of the 

radial collector wells. Despite the fact that radial wells will be located in the underlying aquifer, 

the primary source of intake water will be water from Biscayne Bay. According to the DEIS, "if 

the radial collector wells are used, the water would be pumped directly from the Biscayne 

aquifer beneath the bay and most of this water would be drawn downward from Biscayne Bay in 

an area adjacent to Biscayne National Park." [Footnote 13: NRC, DEIS, 2-27.] The DEIS fails to 

include an adequate analysis of these potential adverse impacts that could be caused by the 

installation and operation of radial collector wells. The DEIS does not adequately analyze the 

potential for radial collector wells to impact salinity levels in Biscayne Bay and associated 

potential impacts on benthic flora and fauna. The DEIS acknowledges that 98% of water draw 

via the radial collector wells would come from Biscayne Bay, noting the hydrological 

connections between the aquifer and the bay. [Footnote 14: Ibid., 498.] However, it is possible 

that, due to these connections, pumping operations will draw down the freshwater lens found in 

the bay, impacting the flora, fauna and salinity of Biscayne Bay. According to the Florida 

Department of Environmental Protection (FDEP), radial wells located at a depth of 40 feet may 

ultimately withdraw freshwater from the aquifer, resulting in potential impacts to the seabed and 

salinity within the Bay. [Footnote 15: Florida Department of Environmental Protection, 

Determination of Completeness, FPL Turkey Point Units 6 & 7, August 10, 2009, 2.] Neither 

Biscayne Bay nor Biscayne Aquifer is characterized by a constant salinity. Rather, both the bay 

and the aquifer are subject to spatial and temporal variations in salinity. [Footnote 16: MiamiDade County, Third Completeness Comments for Plant and Non-Transmission Line Portions of 

the FPL Site Certification Application - Turkey Point Units 6 & 7, May 28, 2010, 25.] The salinity 

model upon which the impacts analysis is based is inadequate and was not developed for the 

true scale at which the wells will operate. The DEIS admits that models used to predict the 

underground flow of water into the radial collector wells are insufficient to identify how water of 

different density (caused by differences in salinity) will move through the ground. [Footnote 17: 

NRC, DEIS, G-29.] (0113-1-15 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, 

Matthew] [Silverstein, Rachel])

Appendix E NUREG–2176 E-208 October 2016
Response: Reclaimed wastewater would be the primary source of cooling water for the 

proposed reactors. Saline water from the RCWs (radial collector wells) beneath Biscayne Bay 

would only be used when reclaimed treated wastewater is not available in sufficient quantity or 

quality, and for a maximum of 60 days per year that is permitted under the Florida State COCs 

(Conditions of Certification). The NRC review team used modeling performed by the USGS and 

documented in Appendix G of the draft EIS to evaluate potential adverse impacts to Biscayne 

Bay that could be caused by operation of RCWs. This included predictions of salinity time 

series based on continuous year-round pumping of the RCWs at locations in Biscayne Bay, 

including locations that were close to and north of the Turkey Point site. As stated in the draft 

EIS, the review team selected two different dates during the simulation period that showed 

either a relatively large positive salinity difference, or a relatively large negative salinity 

difference between the continuous pumping scenario and the base case (60 day per year 

pumping). The model results indicated that the salinity difference between the continuous 

pumping scenario and the base case (no pumping) was mostly within ±1 psu, with only transient 

increases to near 2 psu. 

The review team examined the spatial distribution results on the dates when simulated salinity 

differences were relatively large and found that the largest increases were less than about +2.3 

psu. Also, the salinity increases greater than +1 psu occurred in a relatively small area (14.4 

km2 [5.57 mi2]) located north of the Turkey Point site (Appendix G, Figure G-8); the maximum 

salinity within this area was about 30.8 psu. The review team examined the spatial distribution 

results on a date when large salinity decreases of less than 1 psu occurred in an area that was 

24.2 km2 (9.33 mi2) in size located north of Turkey Point (Appendix G, Figure G-10); the 

maximum salinity within this area was about 31.8 psu. Overall, these simulation results show 

that the temporal and spatial variation of salinity with continuous RCW pumping are expected to 

be minimal. The review team notes that the actual duration of pumping would not be 

continuous. As required by the FDEP COCs, operation of the RCWs is limited to 60 days per 

year. This short duration of pumping would reduce alterations of salinity within Biscayne 

Bay. Therefore, the effect on Biscayne Bay salinity of any permitted pumping would be much 

reduced from the already minimal salinity change calculated by the USGS modeling of a 

continuous pumping scenario. Sections 4.3.2 and 5.3.2 of the EIS have been revised to include 

experimental results to support assessment of RCW effects on seagrass and other aquatic 

resources. State of Florida required monitoring and surveys for seagrass and marine organisms 

are also included in Sections 4.3.2 and 5.3.2. The additional information does not change the 

impact determination that the effects to aquatic resources in these locations from dredging and 

RCW installation and operation are minor. 

The review team recognizes that complete knowledge of the hydrologic system associated with 

the RCWs is not now available, and that uncertainties therefore remain in the impact 

analysis. A vast number of future scenarios are plausible. The sources of uncertainty in the 

RCW analysis include heterogeneity in subsurface parameters, lack of experience with RCW 

systems in carbonate strata, and uncertainty in the potential need for using the backup water 

supply. Uncertainties in the future site environment include: freshening of IWF cooling canals, 

remediation of the subsurface hypersaline plume, and the magnitude and rate of future sealevel rise. 

Determinations in this EIS related to groundwater are based on the FPL numerical model 

analysis, the USGS model analysis, the review team’s independent numerical modeling 

analysis, and the review team’s knowledge and expertise. The conceptual models that served 

as the basis for the numerical models are based on available characterization information for 

the Turkey Point site and surrounding region. Uncertainties in the information and conceptual 

Appendix E October 2016 E-209 NUREG–2176
model were addressed in some cases by performing multiple model runs while varying key 

parameters in the model and in other cases by using conservative parameter values. However, 

uncertainties remain that do not allow the review team to assert that no other conceptual models 

that may result in more adverse impacts from RCW operation are plausible. Heterogeneity in 

subsurface parameters, lack of experience with RCW systems in carbonate strata, and 

uncertainty in the future site environment (e.g., freshening of IWF, remediation of subsurface 

hypersaline plume, sea-level rise) all warrant the review team to exercise care to avoid relying 

on numerical models alone. Because of this, the review team does not rely solely on the output 

of any numerical model. 

Numerical models are numerical representations of complex processes occurring in three 

dimensions over time. The appropriate role of a numerical model is to test assumptions of the 

behavior of complex systems. While even running a numerical model numerous times with 

different parameters cannot compensate for all uncertainties, the models employed here have 

been tested and benchmarked within the conditions that limit their application. In this 

assessment the review team used models to test possible consequences of changes in the 

affected environment and uncertainty in some subsurface parameters within the capability of the 

models employed. This information was combined with the geography of the RCW field (such 

as the relatively short distance from the laterals to the bottom of Biscayne Bay relative to the 

distance from the laterals to the Homestead well fields) and the COC requirement of a 

monitoring program with mitigation options. The review team determined that the proposed 

monitoring of RCW construction and operation that is included is sufficient to detect unexpected 

behavior in a timely manner. While all possible mitigation measures have not yet been spelled 

out, in accordance with the COC, the review team considers the ultimate mitigation of ceasing 

operation of the RCWs as ensuring prevention of any impacts in a timely manner. “When harm 

occurs, or is imminent, SFWMD will require Licensee to modify withdrawal rates or mitigate the 

harm” (FDEP 2014-TN4371). 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply for emergency backup cooling water to 

the main condenser if reclaimed water is not available and the 60-day limitation on RCW 

pumping is exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the NRC staff also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Comment: There are already a host of serious groundwater concerns given the complicated 

hydrology and hydrogeology in the surrounding area, which will be further exacerbated by 

increased demand for freshwater resources and the effects of climate change, particularly sea 

level rise. However, we would like to bring attention to the August 17, 2010 contention that 

SACE and other joint intervenors submitted, which was accepted in part by the Atomic Safety 

and Licensing Board Panel on February 28, 20117 [Footnote 7: See 

http://pbadupws.nrc.gov/docs/ML1105/ML110591003.pdf.] and is still pending today.8 [Footnote 

8: See a discussion of the 2.1 contention in the Joint Intervenors' Request for Leave to Respond 

to NRC Staff's Answers to FPL's Motion for Summary Disposition and Alternatively, Joint 

Appendix E NUREG–2176 E-210 October 2016
Intervenors' Conditional Motion to Admit Second Amended Contention NEPA 2.1, August 20, 

2012. At http://pbadupws.nrc.gov/docs/ML1223/ML12233A743.pdf.] Contention 2.1 as modified 

states, "The ER is deficient in concluding that the environmental impacts from FPL's proposed 

deep injection wells will be "small" because the chemical concentrations in ER Rev. 3 Table 3.6-

2 for ethylbenzene, heptachlor, tetrachloroethylene, and toluene may be inaccurate and 

unreliable. Accurate and reliable calculations of the concentrations of those chemicals in the 

wastewater are necessary so it might reasonably be concluded that those chemicals will not 

adversely impact the groundwater should they migrate from the Boulder Zone to the Upper 

Floridan Aquifer." (0112-7 [Barczak, Sara])

Comment: The primary source of cooling water for the operations of Unit 6 & 7 would be 

reclaimed water from the Miami-Dade Water and Sewer Department (MDWSD). This water 

would be discharged into the Boulder Zone of the Lower Floridan Aquifer using twelve 

underground injection wells. The DEIS does not include an adequate analysis of the impacts 

that may arise from the disposal of this, wastewater -which contains ethylbenzene, heltachlor, 

tetrachloroethylene, and toluene- into the Boulder Zone using these wells. Moreover, the 

impacts of these contaminants migrating upward and into the Upper Floridan Aquifer are not 

adequately addressed. The DEIS also does not include an adequate discussion and evaluation 

of the impacts associated with the construction of pipelines needed to convey reclaimed 

wastewater to the plant's wastewater treatment facility. (0113-2-7 [Lopez, Jaclyn] [McLaughlin, 

Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Response: When the NRC issued the draft EIS in February 2015, a contention regarding the 

environmental impact of four chemical constituents in the wastewater—ethylbenzene, 

heptachlor, tetrachloroethylene, and toluene—was pending in litigation before an Atomic Safety 

and Licensing Board (Board). See Florida Power & Light Co. (Turkey Point Units 6 and 7), 

LBP-16-3, 83 NRC 169, 172 (2016) (LBP-16-3). In December 2015, FPL filed a Motion for 

Summary Disposition (Motion) of the pending contention, relying, in part on additional 

measurements of the concentrations of the four chemical constituents, which the Board granted, 

in part (LBP-16-3, 83 NRC at 177-79). The Board did not dismiss the contention, but 

reformulated it to read: “The DEIS is deficient in concluding that the environmental impacts from 

FPL’s proposed deep injection wells will be ‘small.’ The chemicals ethylbenzene, heptachlor, 

tetrachloroethylene, and toluene in the wastewater injections at concentrations listed in DEIS 

Table 3-5 may adversely impact the groundwater should they migrate from the Boulder Zone to 

the Upper Floridan Aquifer.” LBP-16-3, 83 NRC at 186. 

The concentrations of constituents present in reclaimed water listed in Table 3-5 are calculated 

to represent the water quality expected at the point of injection at the Turkey Point site. The 

concentrations of the four constituents included in the contention and listed in EIS Table 3-5 are 

all below the EPA maximum contaminant levels (or MCLs) allowed for drinking water. As 

mentioned above, eight additional samples were collected at the SDWWTP from 2013 to 2014 

to better understand seasonal variation of the concentrations of the four constituents listed in 

the contention. Concentrations for these constituents collected through this additional sampling 

were below both EPA MCLs and laboratory method detection limits, as indicated in the 

footnotes to Table 3-5. These results also could illustrate the effect of advanced treatment 

which had recently been implemented at SDWWTP in order to provide additional protection to 

USDWs (NRC 2015-TN4773). This additional treatment was required by FDEP and has been 

described as being, “as effective as confinement of fluids in protecting USDWs from 

contaminants in wastewater” (EPA 2005-TN4766). The more recent results represent the future 

reclaimed water that would be received by Turkey Point and do not reflect the additional 

Appendix E October 2016 E-211 NUREG–2176
reduction that would occur due to treatment, volatilization, and dilution at the Turkey Point site 

before injection. 

The review team has revised Sections 2.3 and 5.2 of the final EIS regarding the evaluation of 

the impact of deep well injection of effluent at the Turkey Point site. The final EIS includes more 

recent studies related to regional and site geology, causes and extent of upwelling where it has 

occurred, modeling of fate and transport of injected wastewater, risk assessments of the 

impacts of deep well injection in South Florida, and a more complete discussion of the review 

team evaluation. 

As described in the EIS, the review team took a number of steps to evaluate the potential 

impacts of deep well injection of effluent at the Turkey Point site. The staff 1) reviewed regional 

and site specific studies that evaluated the confining ability of the MCU, the causes and extent 

of upwelling at other deep well injection sites, the extent of injection plume migration, and risk to 

human health and the environment of deep well injection; 2) compared hydrogeological 

conditions and parameters from these sites to conditions and parameters at the proposed site; 

3) evaluated numerical modeling of the flow of injected wastewater presented by the applicant 

and performed confirmatory calculations; and 4) considered the injection well testing and 

groundwater monitoring requirements of the FDEP UIC program. 

Based on this evaluation, the review team concluded that, in general, the matrix of the MCU 

would confine injected effluent and that incidences of upwelling at other sites have been 

coincident with features that provide vertical pathways for upward migration such as fractures or 

improperly completed wells. Site data indicate that substantial fracturing of the confining layers 

is not evident at the Turkey Point site and well construction-related issues are not expected to 

create potential for upwelling at the Turkey Point site because of improved understanding of the 

confining zones within the MCU and improved construction techniques. However, studies of 

other injection sites indicate that if rapid vertical migration occurs, it is not likely to reach the 

Upper Floridan aquifer. This is discussed in greater detail in Sections 2.3.1.2, 3.2.2.2, and 

5.2.1.3 of the updated EIS. 

Calculations and modeling discussed in EIS Section 5.2.1.3 also indicate that horizontal flow of 

the plume within the Boulder Zone would be limited and is not expected to extend to beneath 

the locations of the nearest offsite water-supply well in the overlying Upper Floridan aquifer (7.7 

mi) or flow to surface water bodies, such as the Atlantic Ocean. Modeling indicates that dilution 

along the flowpath could significantly reduce (by as much as 95 percent) the already low or 

undetectable concentrations of constituents within the injected effluent. As a result, it is not 

reasonable that concentrations would be detectable in offsite areas. 

The review team also recognizes that the UIC permitting process required by the FDEP would 

require further characterization and testing of the ability of the MCU to confine and the Boulder 

Zone to receive injected effluent. The additional characterization and testing are required 

before each of the additional injection wells are permitted at the Turkey Point site. In addition, 

these wells would be frequently monitored during operation for the evidence of upwelling of 

injected effluent. 

Finally, EIS Sections 5.2.1.3 and 5.2.3.2 discuss risk assessments of wastewater disposal 

methods in southeast Florida. The risk assessments included modeling of conservative 

transport scenarios that evaluated expected concentrations of a number of representative 

constituents in injected wastewater at locations that included the USDW, the Upper Floridan 

aquifer, and the Biscayne aquifer. One risk analysis specifically evaluated the expected 

Appendix E NUREG–2176 E-212 October 2016
concentration of tetrachloroethylene at the USDW and a well within the Upper Floridan aquifer 

in Dade County resulting from both matrix flow and rapid preferential flow through the MCU 

(EPA 2003-TN4759). In these scenarios, the initial injected concentration of tetrachloroethylene 

was slightly lower than the MCL and higher than the concentration expected for injected effluent 

at Turkey Point (Table 3-5). The initial concentrations were calculated to be reduced by 95 

percent to 100 percent when they reached the USDW and the well within the Upper Floridan 

aquifer. The studies indicate that human health risk decreases as distance from the injection 

well to potential receptors increases. As a result, the assessments conclude that risk from deep 

well injection to human health is low even when upwelling has reached drinking water 

aquifers. If the concentrations expected for Turkey Point effluent were used as the initial 

concentration in this analysis, the expected final concentrations expected at the USDW or 

Upper Floridan aquifer well would also be so low as to be undetectable. However, the Boulder 

Zone is not used as a groundwater source, wastewater is not expected to migrate upward into 

the Upper Floridan aquifer, and the Upper Floridan aquifer, which is brackish, is not used as a 

source of groundwater within the expected migration extent of the injected cooling water from 

the Turkey Point site. 

For the reasons discussed above, the review team determined that impacts of deep well 

injection at the Turkey Point site on water resources would be SMALL. Detailed documentation 

of these studies and the review team’s updated evaluation is provided in updated Sections 2.3, 

5.2, 7.2, and Appendix G of the final EIS. 

Comment: The impacts analysis included in the DEIS regarding the impacts of the radial 

collector wells, already inadequate, is premised on the assumption that sufficient water supply 

will be available from reclaimed wastewater throughout the lifespan of this project. The 

determination that the operations of the radial collector wells would have minor impacts on 

groundwater is dependent on the reliability of reclaimed water. [Footnote 21: NRC, DEIS, 7-12.] 

Due to inherent uncertainties and risk regarding the continued future availability and supply of 

treated wastewater as cooling water, the impacts from the potential increased usage of radial 

collector wells beyond the 60 days identified in the DEIS must be analyzed. Such discussion 

should include possible adverse impacts to Biscayne National Park, benthic habitats and 

organisms, saltwater intrusion, migration of the hypersaline plume, and water levels at 

freshwater supply wells. (0113-2-1 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, 

Matthew] [Silverstein, Rachel])

Comment: The reactor cooling water that does not evaporate from the cooling towers will be 

injected 3,000 feet into the lower Florida aquifer, called the Boulder Zone. Because, according 

to the DEIS, it will stay there forever; out of sight, out of mind. But most of those billions of 

gallons of water will actually be fresh water. Only 3 percent of the water on the planet is fresh 

water and only 1 percent of that is available. So to produce electricity for Florida, Georgia, and 

the rest of the nation, FPL will take reclaimed fresh water out of the South Florida water system, 

now laden with residual chemicals and reactor descaling agents, and send it into the earth 

never to be seen again. (0721-12-6 [White, Barry J.])

Response: Reclaimed wastewater would be the primary source of cooling water for the 

proposed reactors. Saline water from the RCWs beneath Biscayne Bay would only be used 

when reclaimed treated wastewater is not available in sufficient quantity or quality, and for a 

maximum of 60 days per year that is permitted under the Florida State COCs. A very large 

volume of treated municipal wastewater is available for this purpose, but the treated wastewater 

is not suitable for normal uses of fresh water, such as for drinking or agriculture. Accordingly, 

the treated municipal wastewater can be used for cooling proposed Turkey Point Units 6 and 7 

Appendix E October 2016 E-213 NUREG–2176
without affecting the ability to meet demands for fresh water. MDWASD is required to direct 60 

percent of the wastewater flows to reuse by 2025 and to cease using ocean outfalls by 2025 

under the Florida State Ocean Outfall Legislation Compliance Plan Chapter 2008-232 Laws of 

Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. Therefore, the NRC staff concluded that the reclaimed water supply 

is reliable. The review team determined that proposed use of the RCWs as a backup supply of 

cooling water for short periods of time is likely to have small impacts on groundwater users or 

on the extent of saltwater intrusion based on the FPL model analysis, USGS modeling analysis, 

the NRC review team's modeling of the CCS-RCW interaction, and the knowledge that 

environmental monitoring and potential mitigation measures are required under the COCs 

imposed by Florida State imposed. 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply for emergency backup cooling water to 

the main condenser if reclaimed water is not available and the 60-day limitation on RCW 

pumping is exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite, and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the NRC staff also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Comment: Comment 7: The final Environmental Impact Statement must not rely on the 

FPL or USGS groundwater models. The City echoes Miami-Dade County's concerns related 

to the area across which the USGS model predicts average salinities over Biscayne Bay. The 

model should include an analysis that more narrowly focuses on southern Biscayne Bay. The 

USGS model is too coarse: The broad focus of the USGS model obscures the true potential 

impacts of operating the radial collector wells in a fragile aquatic ecosystem. The USGS model 

has inadequate spatial resolution and is inadequately formulated to predict the salinity 

redistribution at the Turkey Point site that will result from the operation of the radial collector 

wells. The USGS model is not a new model that was developed to address the response of the 

Turkey Point site to the operation of the radial collector wells. Rather, the USGS model is a 

minimally modified previous model (Lohmann et al., 2012) that was originally developed to 

predict regional groundwater conditions at the county scale and associated Biscayne Bay 

salinity during 1996-2004. The individual cell sizes in the USGS model are too coarse to 

adequately resolve the groundwater response to the operation of the radial collector wells on 

the Turkey Point site. The horizontal dimensions of each cell are 500 m x 500 m (about 0.3 mi x 

0.3 mi). Any changes in groundwater conditions on these scales are simply averaged out. 

Groundwater and salinity variations over these scales cannot be resolved at all, drawdowns 

near the radial collector wells (expected to be on the order of meters) cannot be determined 

accurately, the distribution of flow along the radial collector wells cannot be modeled at all, and 

individual cooling canals cannot be separated. The USGS model does not properly represent 

the cooling canals: Further, the USGS model does not adequately represent the presence of 

the cooling canals, which are major hydrologic features at the Turkey Point site. In reality, the 

water surface elevations in the cooling canals will fluctuate in tandem with the groundwater 

elevations at the site, and the groundwater elevations will respond to the operation of the radial 

collector wells. In contrast to this reality, the USGS model represents the water surface 

Appendix E NUREG–2176 E-214 October 2016
elevations in the cooling canals as having a pre-specified elevation regardless of pumping from 

the radial collector wells. This approach precludes the model from determining actual water 

surface elevations in the cooling canals and actual groundwater elevations that will occur on the 

site in response to operation of the radial collector wells. A review of the USGS model results for 

the baseline conditions shows that the volume of water withdrawn from the cooling canals is 

approximately 28% of the volume pumped from the radial collector wells. Although not all of the 

water leaking from the cooling canals ends up being pumped by the radial collector wells, the 

upper limit of 28% of the pumpage volume gives further support to the significant influence that 

the cooling canals have on the geohydrology and underline the need to accurately represent 

both the cooling canals and the radial collector wells in the model. (0611-7 [Haber, Matthew S.])

Response: The USGS modeled potential impacts of the RCWs on surface water and the 

Biscayne aquifer using a linked surface water-groundwater model. The key issues related to 

the grid size employed in the USGS model are whether (1) Biscayne Bay can be treated as 

well-mixed, (2) the effects of fresh water capture by the RCWs are adequately modeled, and (3) 

the RCW and IWF are adequately modeled. As described in Appendix G of the draft EIS, the 

USGS analysis had relatively large grid cells and assumed the surface water (notably Biscayne 

Bay) to be vertically mixed. The review team determined that because of the shallow depths of 

Biscayne Bay, particularly near Turkey Point, the vertical mixing assumption was not 

unreasonable for the examination of potential RCW impacts on salinity in Biscayne Bay. While 

localized areas of salinity stratification may develop, wind mixing is expected to keep Biscayne 

Bay well mixed. The analysis used two-dimensional circulation, which is driven in response to 

wind forcing and tidal elevation boundary conditions. Because of the relatively rapid mixing of 

Biscayne Bay, the 500 m cell size is also not expected to have a significant effect on the bay 

salinities predicted by the model. 

In regard to freshwater discharge to the Biscayne Bay, the USGS model was applied to assess 

the potential capture of relatively fresh water from the inland aquifer and the regional 

canals. The large cell size of the model would tend to conservatively overestimate these 

effects. As for the RCWs and IWF, the RCWs were represented by four cells in the model, 

which is adequate to calculate drawdown at the wells and provide volumetric estimates of the 

sources of water captured by the RCWs. The existing cooling canals associated with Units 3 

and 4 were represented as a head boundary in the USGS model with 70 individual cells for the 

entire extent of the cooling canals. Grid resolution of the USGS model is also adequate to 

represent the IWF as such a boundary condition. As described in the USGS model report 

referenced in the draft EIS, the cooling canal head boundary varied over time and was 

estimated using water-level data collected in the cooling canals and the interceptor ditch during 

2008–2009. 

The NRC staff determined that the impact of the limited RCW operations on Biscayne Bay 

salinity would be minor because the effect on salinity of water in the bay would likely be less 

than the natural observed variation in salinity of the bay. However, uncertainties in the model 

parameters and configuration, as well as uncertainty in future conditions, such as RCW usage 

and the magnitude and rate of future sea-level rise, lead to uncertainty in the determination of 

potential impacts on the salinity of Biscayne Bay. Because of this, the review team did not rely 

solely on the output of the FPL or USGS models. The review team determined that the 

proposed monitoring of RCW operations that is included in the COCs is sufficient to detect 

unexpected impacts on the bay in a timely manner. While all possible mitigation measures are 

not detailed at this time, in accordance with the COCs, the review team considers the ultimate 

mitigation of ceasing operation of the RCWs as ensuring prevention of any impacts in a timely 

Appendix E October 2016 E-215 NUREG–2176
manner. “When harm occurs, or is imminent, SFWMD will require Licensee to modify 

withdrawal rates or mitigate the harm” (FDEP 2014-TN4371). 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply emergency backup cooling water to the 

main condenser if reclaimed water is not available and the 60-day limitation on RCW pumping is 

exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite, and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate for more than 60 days 

per year, the primary source of cooling water—reclaimed wastewater from the MDWASD—

should be highly reliable, and therefore the availability of backup cooling-water supplies need 

not be evaluated. Further, the review team also considered alternative sources of cooling water 

in EIS Section 9.4.2, none of which are environmentally preferable to the proposed sources of 

cooling water. In view of the high reliability of the reclaimed wastewater source and the 

availability of the RCW system as a backup, there is no need to consider additional backup 

sources of cooling water. 

Comment: The USGS model baseline is not representative: The USGS model uses as 

baseline conditions those that occurred in the period 1996-2004, and assesses the impact of the 

operation of the radial collector wells relative to conditions that existed in this 9-year time period. 

However, the USGS model report does not demonstrate that the 9-year time period used in the 

model is representative of more recent hydrologic conditions. Such an analysis is essential to 

validate applying the model results to the future hydrologic environment in which the radial 

collectors will likely be operating. This validation could have been done by showing that 

groundwater levels in a more recent 9-year time period is statistically indistinguishable from the 

1996-2004 period. Statistical analyses performed on groundwater elevations near the site, at 

wells G-1183 and G-3356 using the t-test for population differences, show that wet-season and 

annual groundwater fluctuations in the 9-year period of 2005-2013 are statistically different at 

the 90% confidence level from the fluctuations in the 1996-2004 baseline period. Chin, D.A., 

2013, Water Quality Engineering in Natural Systems, Second Edition, Wiley, Hoboken, New 

Jersey. Hence, the validity of using 1996-2004 conditions as a baseline for assessing the impact 

of the radial collector wells at the Turkey Point site is questionable. In addition, the USGS report 

does not compare the more recent salinity fluctuations (e.g., 2005-2013) to the 1996-2004 

salinity fluctuations to establish that the assumed baseline salinities are representative of 

current or future baseline conditions. Further, the USGS model shows that the 19962004 

discharges from the Mowry Canal can significantly affect the salinities in the area of Biscayne 

Bay that recharges the radial collector wells, yet there is no demonstration that the quantity and 

timing of the Mowry Canal discharges used in the model are representative of later (e.g., 2005-

2013) or even future conditions. This particular issue is important because, as reported by 

USGS, the radial collector wells could withdraw sufficient fresh canal-discharge water so as to 

lead to significantly increased salinities in Biscayne Bay, which would otherwise be the recipient 

of this fresh water. (0611-8 [Haber, Matthew S.])

Comment: Limitations of the USGS model: Aside from the aforementioned flaws with the 

USGS model, there are several other model limitations each of which could negatively impact 

the accuracy of the model. These limitations include: (1) The use of the 1-year (20082009) 

correlation between water levels in the L-31E canal and the cooling canals to establish the 

elevations in the cooling canals without demonstrating that that this correlation does not vary 

temporally or even recognizing that this correlation will almost certainly be different when the 

radial collector wells are in operation; (2) artificially limiting the leakage rates from the cooling 

canals; (3) assigning the same salinity to all cooling canals and setting the salinity based on 

Appendix E NUREG–2176 E-216 October 2016
data available before 2011; and (4) adding cooling canals to the model without recalibrating the 

model, especially at the Turkey Point site, to account for the presence of the cooling canals. 

Given the strong influence of the cooling canals on the salinity of the underlying groundwater 

the Turkey Point site, it is particularly important that the cooling canals be modeled accurately. 

Key model limitations explicitly self-reported by USGS (Lohmann, 2014) are: (1) the 

discretization of the model may be too coarse to accurately represent characteristics of interest 

for potential groundwater pumping in the Turkey Point area; (2) the model simulates the surface 

water as a single layer with a single salinity value, effectively representing it as completely 

mixed column water, which is not realistic in the coastal zone, (3) the size of the model cells, 

500 m by 500 m, is too large to accurately represent the individual cooling canals (4) spatial 

averaging may result in more subdued effects than would be simulated at a finer scale, (5) to 

estimate and evaluate the water sources for the radial collector wells more fully, finer spatial 

discretization and additional evaluation tools, such as particle tracking, are needed, (6) the 

model period represents a recent 9-yr period with limited variability of hydrologic conditions, and 

(7) in order to fully represent the effects of the radial collector wells on the system, additional 

simulations of extreme dry periods, wet periods, sea-level rises, and effects from regional 

restoration efforts would need to be evaluated. Given all of the aforementioned limitations of the 

USGS model, it is apparent that the salinity of the cooling canals at the FPL industrial 

wastewater facility will exert a significant influence on the salinity distribution and groundwater 

flow that will occur in response to the operation of the radial collector wells. Further, since the 

USGS model is not able to accurately resolve the spatial variations in salinity and groundwater 

flows at the Turkey Point site, and the USGS model does not demonstrate that 1996-2004 

baseline conditions adequately represents the conditions under which the radial collector wells 

are likely to operate (and noting that groundwater levels in 2005-2013 were significantly different 

than in 1996-2004) it must be concluded that the salinity effects of the cooling canals in the 

Turkey Point site are not adequately represented in the USGS model. (0611-9 [Haber, Matthew 

S.])

Response: The purpose of the USGS model calculations was to predict the approximate 

magnitude of changes in hydraulic head and salinity in the shallow aquifer, and predict changes 

in the distribution of bay salinity that are likely to be caused by building and operating the 

proposed plants. The baseline of the USGS model based on conditions from 1996 to 2004 has 

changed, and the baseline would also change in the several years between 2015 and the time 

plant operation could begin. However, the purpose of the USGS model analyses is to 

understand changes that would occur because of building and operation the proposed 

plants. These changes from the baseline caused by the proposed units are not expected to be 

significantly altered because of different baselines that are caused by external factors such as 

weather or ongoing seepage from the IWF. Discharges from the Mowry Canal also change 

based on weather patterns and canal management practices and these variations could affect 

the salinity distributions in Biscayne Bay. However, these potential changes in baseline are not 

expected to result in significant changes in the impacts from excavation dewatering during plant 

construction or from limited operation of the RCWs (radial collector wells) as a backup water 

supply. 

Based on the expected reliability of the primary reclaimed water source, the RCWs would likely 

operate less than the 60 days per year permitted under the Florida State COCs (Conditions of 

Certification). The NRC staff determined that the impact of the limited RCW operations on the 

Biscayne Bay salinity would be minor because the effect on the salinity of water in the bay 

would likely be less than the natural observed variation in the salinity of the bay. However, 

uncertainties in the model parameters and configuration, as well as uncertainty in future 

conditions, such as RCW usage and the magnitude and rate of future sea level rise, lead to 

Appendix E October 2016 E-217 NUREG–2176
uncertainty in the determination of potential impacts on the salinity of Biscayne Bay. Because of 

these uncertainties, the review team did not rely solely on the output of the FPL or USGS 

models. The review team determined that the proposed monitoring of RCW operations that is 

included in the COCs is sufficient to detect unexpected impacts on the bay in a timely 

manner. While all possible mitigation measures are not detailed at this time, in accordance with 

the COCs, the review team considers the ultimate mitigation of ceasing operation of the RCWs 

as ensuring prevention of any impacts in a timely manner. “When harm occurs, or is imminent, 

SFWMD will require Licensee to modify withdrawal rates or mitigate the harm” (FDEP 2014-

TN4371). 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply emergency backup cooling water to the 

main condenser if reclaimed water is not available and the 60-day limitation on RCW pumping is 

exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the review team also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Comment: The USGS model inaccurately represents the water pumped by the radial 

collector wells: Ultimately, the USGS model is not capable of determining what percentage of 

the water pumped from the radial collector wells is derived from the FPL industrial wastewater 

facility. This percentage is relevant because the industrial wastewater facility is the primary 

source of hypersaline water to the Biscayne Aquifer. Therefore, it has the potential to 

significantly affect the distribution of salinity in the groundwater that will result from the operation 

of the radial collector wells. The final Environmental Impact Statement should include an 

updated groundwater model to account for sea-level rise over the radial collector well system's 

operating life and address: •The possibility that flushing the FPL industrial wastewater facility 

with additional water from the L-31E canal (in a manner that does not prevent evaporation or the 

resulting salinity increases) will push saltier water underground, •The effect on the inland aquifer 

of seawater releases from the radial collector wells into the FPL industrial wastewater facility, 

and •The potential for increased salinity levels in the inland aquifer resulting from future sealevel rise and storm surge hazards at the Turkey Point site, as well as the effects of this 

increased salinity on South Florida's freshwater resources. The decision of the Nuclear 

Regulatory Commission, and cooperating agencies, of whether or not to approve the Turkey 

Point Nuclear Plant Units 6 & 7 application will likely rely on the findings of the USGS 

groundwater model. Due to the limitations of this model and the availability of more accurate 

data, NEPA requires that the final Environmental Impact Statement, or a Supplemental 

Environment Impact Statement, provide a more careful representation of the effects of the radial 

collector well system on the surrounding environment. (0611-10 [Haber, Matthew S.])

Response: The purpose of modeling presented in the draft EIS is to understand changes in the 

environment that would occur because of construction and operation of the proposed 

plants. The cooling canals and associated hypersaline plume are part of the expected 

background environment of the proposed plants. There is no plan for “releases from the radial 

collector wells into the FPL industrial wastewater facility” that is mentioned in the 

Appendix E NUREG–2176 E-218 October 2016
comment. Rather, the water from the RCWs would be used to cool the plant only when the 

primary reclaimed water source is not available, and the water remaining after that function is 

accomplished would be injected into the Boulder Zone. 

After publication of the draft EIS, the review team performed additional groundwater modeling of 

the interaction between the planned RCWs, the existing hypersaline plume, and the cooling 

canals using a two-dimensional cross section model and a limited-extent three-dimensional 

model that accounted for variable density fluids. These simulations were performed to better 

understand the effects of RCW pumping on the existing hypersaline plume from the Units 3 and 

4 cooling canals and resulting impacts to the salinity of the Biscayne aquifer. Planned 

remediation of the hypersaline and predicted sea level rise were also simulated. The results of 

this additional modeling have been added to the EIS. The addition of “freshening water” to the 

IWF from L-31E Canal or other sources is not related to the building or operation of the 

proposed plants, but is a potential change in the environmental baseline conditions. However, 

the review team determined that the very small head increases in the IWF caused by 

“freshening” combined with the resulting dilution of constituents in the IWF would result in minor 

changes in the amount of salt or other constituents seeping into the aquifer from the IWF. 

Comment: 1) Water Modeling 

Numerous DEIS assessments rely upon coarse-scale hydrologic models, whose scale and 

extent were too large to adequately determine localized environmental effects of the proposed 

action on NPS resources. Although the models utilized by the NRC answered some questions 

related to the effect of the proposed action on the regional hydro logic system, the scale of the 

model used by the NRC in conducting its impact assessment is not fine enough to effectively 

evaluate impacts to NPS resources located with portions of Biscayne NP from the removal or 

moderation of freshwater along the shoreline of the park, the removal of water within the park 

through groundwater withdrawal at the RCWs, and the potential for direct adverse impacts at 

the site of withdrawal on seagrass beds and seagrass faunal and benthic communities. The 

DEIS recognizes that each of the models used to evaluate the effects of the Unit 6 and 7 

construction and operation (especially RCW operation) has shortcomings that result in 

significant uncertainty in the modeling results. In part, this limitation stems from model 

calibration, with crucial data being derived from a single, seven-day Aquifer Performance Test. 

During this non-replicated, short-term test, pumping rates were less than 10% of that proposed 

for the RCW and some monitoring equipment failures occurred. Given the variability of 

watershed and marine hydrologic conditions, additional tests were needed in order to better 

calibrate models and produce sufficiently accurate simulations.

The DEIS was informed by two hydrologic models developed by Florida Power and Light (FPL) 

and the U.S. Geological Survey (USGS): 

FPL Model 

The FPL model is a local (fine) scale, constant density groundwater model. Given the wide 

range of water body densities in the region (including low density freshwater, mesohalinemarine bay water, and hypersaline Industrial Wastewater Facility (IWF) water), this model could 

not simulate the effect of proposed Unit 6 and 7 construction and operations on saltwater 

movement in the Biscayne Aquifer, salinity in Biscayne Bay, and regional surface-water and 

groundwater levels. Consequently, the NRC commissioned additional modeling by the USGS. 

USGS Model 

Appendix E October 2016 E-219 NUREG–2176
The USGS model is a regional model, with a model grid too coarse to accurately simulate 

conditions within and under the IWF or adjacent to the RCWs. The model's accompanying 

report identified limitations that included: 1) the sizing of the model cells in 500 x 500 grids; 2) 

simulating surface water as a single layer with a single salinity value; and 3) an inability of the 

model to track the ultimate sources of water that flow to the RCWs. The report recommended 

that finer spatial discretization and additional evaluation tools, such as particle tracking, were 

needed to estimate and evaluate RCW water sources, and that additional simulations of 

extreme dry periods, wet periods, and effects from regional restoration efforts were needed in 

order to fully represent RCW effects on the system. 

This model utilized calibration data from 1997-2004; however, newer groundwater data is 

available that would improve model calibration and validation. This data includes: - Salinity, 

temperature, and depth data collected at 15-minute intervals as part of the NPS salinity 

monitoring network. - Data from South Florida Water Management District (SFWMD) 

Comprehensive Everglades Restoration Plan (CERP) wells in the area. - Conductivity, 

temperature, and depth data collected hourly as part of the Turkey Point Units 3 and 4 Uprate 

Monitoring efforts. 

These data show that average values do not represent the conditions that most affect biota in 

Biscayne Bay, which is better represented by finer scale hourly to daily salinity and temperature 

values. The modeling used to evaluate impacts from the RCWs would be improved to the 

appropriate scale for the necessary applications by calibrating with the available 15 minute 

salinity data from the Bay. The groundwater model would be improved if it used data for 

calibration and validation from groundwater wells installed as part of the Turkey Point Units 3 & 

4 Uprate Monitoring which would improve the ability of the model to more accurately predict the 

effects of the proposed action on adjacent natural resources. These wells are located at shallow 

medium and deep locations in the Biscayne Aquifer. They are numbered 1-15 and are located 

through the model domain from just west of US highway 1 to three clusters located in Biscayne 

Bay (10, 14, 15). They provide hourly data for conductivity temperature and depth. Empirical 

findings from past work, such as the distribution and trends of tritium concentrations, have 

established that IWF waters are found in near-surface shallow groundwater (25 to 30 ft. deep) in 

wetlands adjacent to Biscayne Bay (Figure 1 [Tritium concentration time series in IWF well 

monitoring clusters showing increasing trends]). The NPS is concerned that since this is the 

same depth at which RCW intake pipes are expected to be located, that it is possible for IWF 

water to impact resources within Biscayne National Park (NP). 

The NPS recommends that the NRC utilize improved model extent, model scale, and model 

calibration to accurately evaluate the appropriate spatial extent of these potential impacts to 

better characterize operations of the RCWs and the relative localized impacts of resulting 

movement of the hypersaline plume on surface waters and ground waters in the park and under 

the IWF, as well as the relative effects of sea-level rise on operations of the RCW system. This 

improved analysis will provide better information as to the effect of the proposed action in terms 

of changes in salinity and other impacts to near shore resources that occur within Biscayne NP 

in the vicinity of the RCWs. (0622-1-2 [Austin, Stan])

Comment: Hydrologic Modeling[.] The NPS is concerned that numerous assessments in the 

DEIS rely upon hydrologic models, whose scale and extent were too large to adequately 

determine localized environmental effects of the proposed action on NPS resources. Although 

the model utilized by the NRC answered some questions related to the effect of the proposed 

action on the regional hydrologic system, the scale of the model used by the NRC in conducting 

its impact assessment is not fine enough to effectively evaluate impacts to NPS resources 

Appendix E NUREG–2176 E-220 October 2016
located with portions of Biscayne NP from the removal or moderation of freshwater along the 

shoreline of the park, the removal of water within the park through groundwater withdrawal at 

the RCW s, and the potential for direct adverse impacts at the site of withdrawal on seagrass 

beds and seagrass faunal and benthic communities. The NRC should utilize newer data 

available from NPS and the South Florida Water Management District to improve the extent, 

scale, and calibration of the models to accurately evaluate the appropriate spatial extent of 

these potential impacts on park resources. Furthermore, the model should better characterize 

operations of the RCWs and the relative localized impacts of the resulting movement of the 

hypersaline plume that presently exists from the operation of the Industrial Wastewater Facility 

(IWF or cooling canals) used to cool the existing facility on surface and ground waters, as well 

as the relative effects of sea-level rise on operations of the RCW system. (0623-2 [Austin, Stan])

Comment: The NPS asserts that the DEIS impact analysis associated with construction and 

operation of proposed Units 6 and 7 does not sufficiently address issues related to the 

environmental impacts of the proposed action on resources managed by the NPS. Based on our 

review of the DEIS, we have strong concerns that impact analysis described in the DEIS does 

not:...acknowledge scientific uncertainty associated with the effects of certain elements of the 

proposed action, including the use of groundwater collected from the RCWs on the resources of 

Biscayne NP[.] (0623-8 [Austin, Stan])

Response: The purpose of the modeling presented in the draft EIS is to understand potential 

changes in the environment that could occur because of construction and operation of proposed 

Units 6 and 7. The cooling canals and associated hypersaline plume are part of the background 

environment of the proposed plants. Three different groundwater models were used to evaluate 

different aspects of the RCW (radial collector well) pumping effects. FPL’s groundwater model, 

documented in the Final Safety Analysis Report (FSAR), had a sufficiently small cell size to 

simulate the local effects of the RCW pumping on the aquifer and identify the likely sources of 

water that would be captured by the RCWs. This model provided valuable information about the 

sources of water captured by the RCWs and about the hydraulic head changes (drawdown) that 

could be expected. However, the FPL model did not account for the effects of variable density 

fluids that are caused by salinity and temperature differences. 

The USGS modeling was performed to evaluate the effects of variable density fluids on the 

model results. Although the USGS model cells were too large to simulate conditions at a small 

scale, this model provided valuable information about larger-scale groundwater salinity changes 

expected in areas affected by the hypersaline plume and areas farther inland. It also was useful 

in predicting the potential for RCW capture of water from the drainage canals, which reduces 

the amount of fresh water entering the bay from the canals. The review team is aware of 

Biscayne Bay salinity and temperature data available from the NPS salinity monitoring network 

and data available from the SFWMD and the Turkey Point Units 3 and 4 Uprate 

Monitoring. These data sets were used in the draft EIS descriptions of the site surface water 

and groundwater. 

After publication of the draft EIS, the review team used a third model—the RTF (Review Team 

Focused model)—to perform additional groundwater modeling of the interaction between the 

planned RCWs, the existing hypersaline plume, and the cooling canals. This third model 

included a two-dimensional cross-section model and a limited-extent three-dimensional 

model. The review team used the RTF model to perform simulations to better understand how 

the existing hypersaline plume may be affected by RCW pumping combined with remediation 

actions recently stipulated in a consent agreement between FPL and Miami Dade County. The 

RTF model was useful in showing salinity changes that occur in the aquifer near the RCWs 

Appendix E October 2016 E-221 NUREG–2176
when the wells are operated. The results showed that when the wells are not operating, 

hypersaline water from the cooling canals is present in the high-permeability zone where the 

well laterals are installed. This saline water is drawn into the wells during the first few days of 

RCW pumping, resulting in increasing, then decreasing salinity at the well. The RTF model 

predicts that the salinity of the water produced by the operating RCW eventually drops to about 

the concentration of the bay water. Water flowing down through the bed of the bay and into the 

RCWs is therefore expected to have about the same salinity as bay water. When RCW 

pumping ceases, water in the high-permeability zone again increases in salinity because of the 

migration of water from the hypersaline plume. This migration of hypersaline water into the 

high-permeability zone would occur regardless of the presence of the RCWs. 

Predicted future change is sea level and its effect on interactions between the RCWs and the 

hypersaline plume were also simulated. The additional modeling confirmed that pumping of the 

RCWs would move hypersaline water toward the RCWs and would remove some groundwater 

captured by the RCWs from the hypersaline plume region of the Biscayne aquifer. The model 

also indicated that RCWs pumping is not likely to reduce the effectiveness of hypersaline plume 

remediation actions specified in the consent agreement. 

Reclaimed wastewater would be the primary source of cooling water for the proposed 

reactors. Saline water from the RCWs beneath Biscayne Bay would only be used when 

reclaimed treated wastewater is not available in sufficient quantity or quality, and for a maximum 

of 60 days per year that is permitted under the Florida State COCs. A very large volume of 

treated municipal wastewater is available for this purpose, but the treated wastewater is not 

suitable for normal uses of freshwater, such as for drinking or agriculture. Accordingly, the 

treated municipal wastewater can be used for cooling proposed Turkey Point Units 6 and 7 

without affecting the ability to meet demands for fresh water. Miami Dade Water and Sewer 

Department is required to direct 60 percent of the wastewater flows to reuse by 2025 and to 

cease using ocean outfalls by 2025 under the Florida State Ocean Outfall Legislation 

Compliance Plan Chapter 2008-232 Laws of Florida Wastewater Disposal/Ocean Outfalls 

[Section 403.086 (9), Florida Statutes and Amendment CS/SB 444]. Therefore, it is likely that 

the RCWs would be used less than the 60 days per year permitted under the COCs. Based on 

the modeling efforts described in the draft EIS, more than 90 percent of the water pumped when 

the RCWs are operating is expected to come from Biscayne Bay, and small amounts would 

come from the hypersaline plume beneath the cooling canals, the inland part of the Biscayne 

aquifer, and the drainage canals. The models described above predicted that limited pumping 

of the RCWs as a backup water supply for less than 60 days per year would not result in a 

significant change in the extent of salt water intrusion or to reduce the flow of relatively fresh 

water into Biscayne Bay compared to the variability that occurs under current conditions. 

The review team recognizes that complete knowledge of the hydrologic system associated with 

the RCWs is not now available, and that uncertainties therefore remain in the impact 

analysis. A vast number of future scenarios are plausible. The sources of uncertainty in the 

RCW analysis include: heterogeneity in subsurface parameters, lack of experience with RCW 

systems in carbonate strata, and uncertainty in the potential need for using the backup water 

supply. The aquifer performance test used a pumping rate designed to create enough stress in 

the aquifer for measurable drawdown at the observation wells and estimate aquifer flow 

parameters. Repeating the test would not have produced significantly different 

results. Uncertainties in the future site environment include: freshening of IWF cooling canals, 

remediation of the subsurface hypersaline plume, and the magnitude and rate of future sealevel rise. 

Appendix E NUREG–2176 E-222 October 2016
The determinations in this EIS related to groundwater are based on the FPL numerical model 

analysis, the USGS model analysis, the review team’s independent numerical modeling 

analysis, and the review team’s knowledge and expertise. The conceptual models that served 

as the basis for the numerical models are based on available characterization information for 

the Turkey Point site and surrounding region. Uncertainties in the information and conceptual 

model were addressed in some cases by performing multiple model runs while varying key 

parameters in the model and in other cases by using conservative parameter values. However, 

uncertainties remain that do not allow the review team to assert that no other conceptual models 

that may result in more adverse impacts from RCW operation are plausible. Heterogeneity in 

subsurface parameters, lack of experience with RCW systems in carbonate strata, and 

uncertainty in the future site environment (e.g., freshening of IWF, remediation of subsurface 

hypersaline plume, sea-level rise) all warrant the review team to exercise care to avoid relying 

on numerical models alone. Because of this, the review team does not rely solely on the output 

of any numerical model. 

Numerical models are numerical representations of complex processes occurring in three 

dimensions over time. The appropriate role of a numerical model is to test assumptions of the 

behavior of complex systems. While even running a numerical model numerous times with 

different parameters cannot compensate for all uncertainties, the models employed here have 

been tested and benchmarked within the conditions that limit their application. In this 

assessment, the review team used models to test possible consequences of changes in the 

affected environment and uncertainty in some subsurface parameters within the capability of the 

models employed. This information was combined with the geography of the RCW field (such 

as the relatively short distance from the laterals to the bottom of Biscayne Bay relative to the 

distance from the laterals to the Homestead well fields) and the COC requirement of a 

monitoring program with mitigation options. The review team determined that the proposed 

monitoring of RCW construction and operation that is included is sufficient to detect unexpected 

behavior in a timely manner. While all possible mitigation measures have not yet been spelled 

out, in accordance with the COC, the review team considers the ultimate mitigation of ceasing 

operation of the RCWs as ensuring prevention of any impacts in a timely manner. “When harm 

occurs, or is imminent, SFWMD will require Licensee to modify withdrawal rates or mitigate the 

harm” (FDEP 2014-TN4371). 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply emergency backup cooling water to the 

main condenser if reclaimed water is not available and the 60-day limitation on RCW pumping is 

exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the review team also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Comment: Analysis of Impacts to Comprehensive Everglades Restoration Plan (CERP) 

Projects and the Biscayne Bay Coastal Wetlands (BBCW) Project[.] One of the goals of the 

CERP is to increase freshwater flow to Biscayne NP to achieve more natural hydrologic 

conditions within the park that has been negatively impacted by implementation of the regional 

Appendix E October 2016 E-223 NUREG–2176
water supply and flood control project. Given the lack of specific localized information regarding 

the effect of the RCW s on nearshore salinity levels, the NPS disagrees with NRC's conclusion 

that the proposed action would have minimal effect on CERP and Phase 1 of the BBCW project. 

NPS remains concerned that the cumulative impacts resulting from this project could potentially 

negate current or potentially future efforts to increase freshwater flows to rehydrate wetlands 

and reduce point source pollution discharge into Biscayne NP and Biscayne Bay. A second 

phase of the BBCW project remains to be planned and authorized, but is reflected in overall 

salinity restoration target goals for the park. Detailed review of modeling results from the DEIS 

analysis show a potential for impacts to groundwater sources for CERP, as well as movement of 

the groundwater masses related to RCW operations. The BBCW Project Phase 1, which is 

intended to redistribute existing freshwater flows to Biscayne NP, is now entering the 

construction phase with operation to shortly follow. (0623-6 [Austin, Stan])

Response: In Section 7.1, the draft EIS states “The primary surface-water use plan that could 

potentially be affected by Turkey Point Units 6 and 7 is the CERP (Comprehensive Everglades 

Restoration Program) (USACE 2010-TN113) and its component Biscayne Bay Wetlands 

Restoration Project (USACE/SFWMD 2011-TN1038).” The review team acknowledges that 

some freshwater entering Biscayne Bay, including additional water inputs facilitated by CERP 

projects could be captured by the RCWs when they are operating. However, a very large 

volume of treated municipal wastewater is available for this purpose, but the treated wastewater 

is not suitable for normal uses of freshwater, such as for drinking or agriculture. Accordingly, 

the treated municipal wastewater can be used for cooling proposed Turkey Point Units 6 and 7 

without affecting the ability to meet demands for freshwater. MDWASD is required to direct 60 

percent of the wastewater flows to reuse by 2025 and to cease using ocean outfalls by 2025 

under the Florida State Ocean Outfall Legislation Compliance Plan Chapter 2008-232 Laws of 

Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. The RCWs are likely to be used less than the 60 days per year 

permitted under the Florida State COCs. The review team also relies on the COC requirement 

for a monitoring program with mitigation options. The review team determined that the 

proposed monitoring of RCW construction and operation that is included is sufficient to detect 

unexpected behavior in a timely manner. While all possible mitigation measures are not 

detailed at this time, in accordance with the COC, the review team considers the ultimate 

mitigation of ceasing operation of the RCWs as ensuring prevention of any impacts in a timely 

manner. “When harm occurs, or is imminent, SFWMD will require Licensee to modify 

withdrawal rates or mitigate the harm” (FDEP 2014-TN4371) 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply emergency backup cooling water to the 

main condenser if reclaimed water is not available and the 60-day limitation on RCW pumping is 

exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the review team also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Appendix E NUREG–2176 E-224 October 2016
Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 2.3.4.2, Page 2-

71, Lines 10-12 "Each pair included a well completed in the Miami Limestone/Key Largo 

Limestone at depths...from 14 to 28 ft and a well completed in the Fort Thompson Formation at 

depths...from 85 to 110 ft..." ER Subsection 2.3.1.2.1.4 "Ten observation well pairs...completed 

to depths...from 24 to 110 feet bgs...installed in the Miami Limestone/Key Largo Limestone and 

the Fort Thompson Formation." (0619-2-20 [Maher, William])

Response: According to ER Table 2.3-14 the open interval range for the shallow wells is 14–

28 ft bgs and the open interval range for the lower wells is 85–110 ft bgs. Accordingly, the draft 

EIS and ER appear consistent, and the review team made no changes to the EIS. 

Comment: So the continued operation of Turkey Point 3 and 4 has the capacity to further 

relocate the hypersaline plume. So I think the Impact Statement is incomplete in that it makes 

no analyses of the effects of possible entrainment of the hypersaline plume and the likely 

resulting consequence for the demand on water from other sources --such as fresh water from 

the L-31-E canal -- if the radial collector well system is tainted with hypersaline plume. (0721-2-3

[Stoddard, Philip K.])

Response: As described in the draft EIS, seepage of hypersaline water from the CCS (coolingcanal system) associated with the existing Turkey Point Units 3 and 4 has resulted in areas of 

groundwater salinity higher than seawater near the CCS. This is part of the existing 

environment for the proposed Units 6 and 7. After publication of the draft EIS, the review team 

performed additional groundwater modeling of the interaction between the planned RCWs 

(radial collector wells), the existing hypersaline plume, and the cooling canals using a twodimensional cross section model and a limited-extent three-dimensional model called the 

Review Team Focused (RTF) model. 

These simulations were performed to better understand the effects of RCW pumping on salinity 

in the aquifer beneath the bay combined with the existing hypersaline plume from the Unit 3 and 

4 cooling canals and planned remediation actions. This model was useful in showing salinity 

changes that occur in the aquifer near the RCWs when the wells are operated. The results 

showed that when the wells are not operating, hypersaline water from the cooling canals is 

present in the high permeability zone where the well laterals are installed. This saline water is 

drawn into the wells during the first few days of RCW pumping, resulting in increasing, then 

decreasing salinity at the well. The RTF model predicts that the salinity of the water produced 

by the operating RCW eventually drops to about the concentration of the bay water. Water 

flowing down through the bed of the bay and into the RCWs is therefore expected to have about 

the same salinity as bay water. When RCW pumping ceases, water in the high permeability 

zone again increases in salinity because of the migration of water from the hypersaline 

plume. This migration of hypersaline water into the high-permeability zone would occur 

regardless of the presence of the RCWs. 

Predicted future change in sea level and its effect on interactions between the RCWs and the 

hypersaline plume were also simulated. The additional modeling confirmed that pumping of the 

RCWs would move hypersaline water toward the RCWs and would remove some groundwater 

captured by the RCWs from the hypersaline plume region of the Biscayne aquifer. The model 

also indicated that RCWs pumping is not likely to reduce the effectiveness of hypersaline plume 

remediation actions specified in the consent order between FPL and Miami Dade 

County. Reclaimed wastewater would be the primary source of cooling water for the proposed 

reactors. Saline water from the RCWs beneath Biscayne Bay would only be used when 

reclaimed treated wastewater is not available in sufficient quantity or quality, and for a maximum 

Appendix E October 2016 E-225 NUREG–2176
of 60 days per year that is permitted under the Florida State COCs. There is a very large 

volume of treated municipal wastewater available for this purpose, but the treated wastewater is 

not suitable for normal uses of fresh water, such as for drinking or agriculture. Accordingly, the 

treated municipal wastewater can be used for cooling for proposed Turkey Point Units 6 and 7 

without affecting the ability to meet demands for fresh water. MDWASD is required to direct 60 

percent of the wastewater flows to reuse by 2025 and to cease using ocean outfalls by 2025 

under the Florida State Ocean Outfall Legislation Compliance Plan, Chapter 2008-232 Laws of 

Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. Therefore, the NRC staff concluded that the reclaimed water supply 

is reliable and use of the RCWs for short periods of time is likely to have small impacts on 

groundwater users or on the extent of saltwater intrusion based on the FPL model analysis, 

USGS modeling analysis, the NRC review team's modeling of the CCS-RCW interaction, and 

the knowledge that environmental monitoring and potential mitigation measures are required 

under the COCs imposed by Florida State. Therefore, it is likely that the RCWs would be used 

less than the 60 days per year permitted under the COCs. Based on the review teams analysis, 

there is no reason to expect that building and operating the proposed plants would increase the 

impacts of the existing hypersaline plume or lead to additional demand for water from the L-31E 

Canal. 

Comment: The current determination that there would not be an environmental problem with 

the proposed radial collector wells as long as they were not used more than 60 days per year. 

The current emergency use of Aquifer water has certainly gone far beyond any length of time 

imagined, and in fact is proposed to be used for at another two year, drawing 100 million gallons 

of water every single day. Thus the draft statement fails to comprehensively address the long 

term viability of providing fresh water to the plant as a backup to the reuse water. The potable 

drinking water resource for 2.5 million residents of Miami Dade County will be in competition for 

water drawn from the aquifer for the voraciously thirsty nuclear plants. (0145-10 [Lerner, Cindy])

Response: Reclaimed wastewater would be the primary source of cooling water for the 

proposed reactors. Saline water from the RCWs beneath Biscayne Bay would only be used 

when reclaimed treated wastewater is not available in sufficient quantity or quality, and for a 

maximum of 60 days per year that is permitted under the Florida State COCs. A very large 

volume of treated municipal wastewater is available for this purpose, but the treated wastewater 

is not suitable for normal uses of freshwater, such as for drinking or agriculture. Accordingly, 

the treated municipal wastewater can be used for cooling proposed Turkey Point Units 6 and 7 

without affecting the ability to meet demands for freshwater. The MDWASD is required to direct 

60 percent of the wastewater flows to reuse by 2025 and to cease using ocean outfalls by 2025 

under the Florida State Ocean Outfall Legislation Compliance Plan, Chapter 2008-232 Laws of 

Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. Therefore, the NRC staff concluded that the reclaimed-water supply 

is reliable and use of the RCWs for short periods of time is likely to have small impacts on 

groundwater users or on the extent of saltwater intrusion based on the FPL model analysis, 

USGS modeling analysis, the NRC review team's modeling of the CCS-RCW interaction, and 

the knowledge that environmental monitoring and potential mitigation measures are required 

under the COCs imposed by Florida State 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply emergency backup cooling water to the 

main condenser if reclaimed water is not available and the 60-day limitation on RCW pumping is 

exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite and can be replenished from multiple 

Appendix E NUREG–2176 E-226 October 2016
sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the NRC staff also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Comment: The potential for interactions between the operations of the radial collector wells 

and the hypersaline plume leads to inherent risks and potential environmental impacts that are 

not adequately addressed in the DEIS. The construction and operation of Units 6 & 7 will likely 

increase the input of materials into the CCS, altering the concentrations of dissolved 

contaminants. Interactions between radial collector wells and CCS waters could result in the 

transport of contaminants and nutrients into underground waters that are connected with the 

waters of Biscayne Bay, potentially causing algal blooms and indirect threats to its ecological 

health and sustainability. [Footnote 27: West, B. United States Department of the Interior, 

National Park Service Letter to A. Williamson, U.S. Nuclear Regulatory Commission, November 

25, 2014, SER PC, 6-8. ]The DEIS must analyze and review monitoring information regarding 

contaminants of environmental concern, such as salinity, nutrients, metals, and sulfate.

(0113-2-4 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, 

Rachel])

Response: As discussed in the draft EIS, the combined impacts of the planned discharge of 

groundwater from excavation dewatering and stormwater to the CCS while building the plants, 

and the chemical inputs to the Units 3 and 4 cooling canal system (CCS) from muck spoils 

runoff and cooling-tower drift are expected to cause minor changes in the water levels or 

chemistry of the CCS. Potential changes in nitrate concentration from muck runoff are 

presented in the draft EIS. Water from the CCS does seep into the Biscayne aquifer below the 

CCS beneath the site, as it has for decades. However, this seepage is not a result of planned 

Units 6 and 7, and the draft EIS analysis shows that the effects of the expected volume and 

concentration of the seepage would be minor and temporary. Any increase in volume and 

concentration of the seepage from the CCS to the underlying portion of the Biscayne aquifer is 

not expected to have a noticeable impact on the quality of groundwater in the areas of the 

Biscayne aquifer that meet USDW criteria for TDS. 

After publication of the draft EIS, the review team performed additional groundwater modeling of 

the interaction between the planned RCWs, the existing hypersaline plume, and the cooling 

canals using a two-dimensional cross-section model and a limited-extent three-dimensional 

model. The review team used the RTF (Review Team Focused) model, to perform simulations 

to better understand the effects of RCW pumping on salinity in the aquifer beneath the bay 

combined with the existing hypersaline plume from the Units 3 and 4 cooling canals and 

planned remediation actions. 

The RTF model was useful in showing salinity changes that occur in the aquifer near the RCWs 

when the wells are operated. The results showed that when the wells are not operating 

hypersaline water from the cooling canals is present in the high-permeability zone where the 

well laterals are installed. This saline water is drawn into the wells during the first few days of 

RCW pumping, resulting in increasing, then decreasing, salinity at the well. The RTF model 

predicts that the salinity of the water produced by the operating RCW eventually drops to about 

the concentration of the bay water. Water flowing down through the bed of the bay and into the 

Appendix E October 2016 E-227 NUREG–2176
RCWs is therefore expected to have about the same salinity as bay water. When RCW 

pumping ceases, water in the high-permeability zone again increases in salinity because of the 

migration of water from the hypersaline plume. This migration of hypersaline water into the 

high-permeability zone would occur regardless of the presence of the RCWs. Predicted future 

change is sea level and its effect on interactions between the RCWs and the hypersaline plume 

were also simulated. The additional modeling confirmed that pumping of the RCWs would 

move hypersaline water toward the RCWs and would remove some groundwater captured by 

the RCWs from the hypersaline plume region of the Biscayne aquifer. The model also indicated 

that RCWs pumping is not likely to reduce the effectiveness of hypersaline plume remediation 

actions specified in the consent order between FPL and Miami Dade County. Migration of 

metals and of nutrients from the cooling canals toward Biscayne Bay could occur when the 

RCWs are operated and then turned off. The constituents would tend to be removed from the 

aquifer and captured by the RCWs while they are operating. The concentration change of these 

constituents in the aquifer beneath the bay are expected to be proportional to salinity changes 

that were simulated in the additional limited 3D modeling. As described in the EIS, the salinity 

changes are small and would be further diluted and dispersed by water in the bay. It is unlikely 

that the very small mass of nutrients moving into the bay by this mechanism would contribute to 

algal blooms or increase concentration of metals by a noticeable degree. 

Reclaimed wastewater would be the primary source of cooling water for the proposed 

reactors. Saline water from the RCWs beneath Biscayne Bay would only be used when 

reclaimed treated wastewater is not available in sufficient quantity or quality, and for a maximum 

of 60 days per year that is permitted under the Florida State COCs. A very large volume of 

treated municipal wastewater is available for this purpose, but the treated wastewater is not 

suitable for normal uses of freshwater, such as for drinking or agriculture. Accordingly, the 

treated municipal wastewater can be used as cooling water for proposed Turkey Point Units 6 

and 7 without affecting the ability to meet demands for freshwater. MDWASD is required to 

direct 60 percent of the wastewater flows to reuse by 2025 and to cease using ocean outfalls by 

2025 under the Florida State Ocean Outfall Legislation Compliance Plan, Chapter 2008-232 

Laws of Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. Therefore, the NRC staff concluded that the reclaimed-water supply 

is reliable and use of the RCWs for short periods of time would be likely to have small impacts 

on groundwater users or on the extent of saltwater intrusion based on the FPL model analysis, 

USGS modeling analysis, the NRC review team's modeling of the CCS-RCW interaction, and 

the knowledge that environmental monitoring and potential mitigation measures are required 

under the COCs imposed by Florida State. Therefore, it is likely that the RCWs would be used 

less than the 60 days per year permitted under the COCs. 

Based on the modeling efforts described in the draft EIS, more than 90 percent of the water 

pumped when the RCWs are operating is expected to come from Biscayne Bay and small 

amounts would come from the hypersaline plume beneath the cooling canals, the inland part of 

the Biscayne aquifer, and the drainage canals. The models described above provided evidence 

that limited pumping of the RCWs as a backup water supply (less than 60 days per year) is 

unlikely to cause a noticeable change in the existing extent of saltwater intrusion or to reduce 

the flow of relatively freshwater into Biscayne Bay compared to the variability that occurs under 

current conditions. Dissolved nutrients and metals that may migrate from the CCS to the 

Biscayne aquifer would be approximately proportional to the modeled salinity movement and 

would not result in significant changes in the bay. 

The review team recognizes that complete knowledge of the hydrologic system associated with 

the RCWs is not now available, and that uncertainties therefore remain in the impact 

Appendix E NUREG–2176 E-228 October 2016
analysis. A vast number of future scenarios are plausible. The sources of uncertainty in the 

RCW analysis include heterogeneity in subsurface parameters, lack of experience with RCW 

systems in carbonate strata, and uncertainty in the potential need for using the backup water 

supply. Uncertainties in the future site environment include freshening of IWF cooling canals, 

remediation of the subsurface hypersaline plume, and the magnitude and rate of future sealevel rise. 

The determinations in this EIS related to groundwater are based on the FPL numerical model 

analysis, the USGS model analysis, the review team’s independent numerical modeling 

analysis, and the review team’s knowledge and expertise. The conceptual models that served 

as the basis for the numerical models are based on available characterization information for 

the Turkey Point site and surrounding region. Uncertainties in the information and conceptual 

model were addressed in some cases by performing multiple model runs while varying key 

parameters in the model and in other cases by using conservative parameter values. However, 

uncertainties remain that do not allow the review team to assert that no other conceptual models 

that may result in more adverse impacts from RCW operation are plausible. Heterogeneity in 

subsurface parameters, lack of experience with RCW systems in carbonate strata, and 

uncertainty in the future site environment (e.g., freshening of IWF, remediation of subsurface 

hypersaline plume, sea-level rise) all warrant the review team to exercise care to avoid relying 

on numerical models alone. Because of this, the review team does not rely solely on the output 

of any numerical model. 

Numerical models are numerical representations of complex processes occurring in three 

dimensions over time. The appropriate role of a numerical model is to test the assumptions of 

the behavior of complex systems. While even running a numerical model numerous times with 

different parameters cannot compensate for all uncertainties, the models employed here have 

been tested and benchmarked within the conditions that limit their application. In this 

assessment the review team analysts used models to test possible consequences of changes in 

the affected environment and uncertainty in some subsurface parameters within the capability of 

the models employed. This information was combined with the geography of the RCW field 

(such as the relatively short distance from the laterals to the bottom of Biscayne Bay relative to 

the distance from the laterals to the Homestead well fields) and the COC requirement of a 

monitoring program with mitigation options. The review team determined that the proposed 

monitoring of RCW construction and operation that is included is sufficient to detect unexpected 

behavior in a timely manner. While all possible mitigation measures have not yet been spelled 

out at this time, in accordance with the COC, the review team considers the ultimate mitigation 

of ceasing operation of the RCWs as ensuring prevention of any impacts in a timely 

manner. “When harm occurs, or is imminent, SFWMD would require Licensee to modify 

withdrawal rates or mitigate the harm” (FDEP 2014-TN4371). 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply for emergency backup cooling water to 

the main condenser if reclaimed water is not available and the 60-day limitation on RCW 

pumping is exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the review team also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

Appendix E October 2016 E-229 NUREG–2176
the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Comment: As the NRC awaits the NEPA required studies, including this Draft EIS Statement 

and the final safety analysis, we have found that there are still significant environmental impacts 

that must be addressed. In reviewing the EIS on behalf of our residents --not only our residents 

but all of Southeast Florida we have several major concerns. The first of which is the major 

impact these plants will have on our water supply in the Biscayne aquifer. FPL's proposing 

using millions of gallons of reclaimed wastewater as the primary source of cooling for the two 

nuclear reactors. However, the discharge of the wastewater will still have an adverse impact on 

our groundwater. We've seen that the theory that went into the use of the cooling canals has 

fallen to pieces because it is completely dysfunctional. They are now requesting up to 100 

million gallons a day for the next two years. When we questioned this morning, at the 

Government to Government session with the individuals conducting the study, whether they 

were incorporating the current crisis we see we are facing because we are now in competition 

with a very voraciously thirsty nuclear power plant for our source of drinking water. That issue is 

not being considered in the current EIS because these problems came to the forefront as they 

were concluding this EIS. So when we asked, will there be a supplemental Environmental 

Impact Statement where you do address what we are currently experiencing and have no way 

of knowing how long this could go on, it could go on indefinitely? We didn't get a clear answer, 

that there will be a supplement Environmental Impact Statement. And when we asked, how do 

you make a cumulative and thorough analysis without relying on the current crisis, we did not 

get a sufficient answer. (0721-3-2 [Lerner, Cindy])

Response: Water in the Biscayne aquifer in the vicinity of Turkey Point has elevated salinity 

and TDS above USDW standards because of saltwater intrusion from the sea and cannot be 

used as a drinking water source without treatment. In South Florida, the amount of saltwater 

intrusion has increased over the past several decades because of the drainage of wetlands and 

groundwater pumping in inland areas, which is unrelated to operations at Turkey 

Point. Seepage of hypersaline water from the CCS (cooling-canal system) associated with 

existing Turkey Point Units 3 and 4 has also resulted in areas of groundwater salinity higher 

than seawater near the CCS. 

As discussed in the draft EIS, only the RCWs (radial collector wells), planned as a backup 

cooling-water source, and limited inputs to the CCS while building the plants are expected to 

have any potential impact on the salinity of groundwater in the Biscayne aquifer. As discussed 

in the draft EIS, the combined impacts of the planned discharge of groundwater from excavation 

dewatering and stormwater to the CCS while building the plants, and the chemical inputs to the 

CCS from muck spoils runoff and cooling-tower drift, are expected to cause minor changes in 

the water levels, salinity, or other chemical concentrations of the CCS. As stated in the draft 

EIS, saline water from the RCWs beneath Biscayne Bay would only be used when reclaimed 

treated wastewater is not available in sufficient quantity or quality, and for a maximum of 60 

days per year that is permitted under the Florida State COCs. 

A very large volume of treated municipal wastewater is available for this purpose, but the 

treated wastewater is not suitable for normal uses of freshwater, such as for drinking or 

agriculture. Accordingly, the treated municipal wastewater can be used for cooling proposed 

Turkey Point Units 6 and 7 without affecting the ability to meet demands for 

freshwater. MDWASD is required to direct 60 percent of the wastewater flows to reuse by 2025 

and to cease using ocean outfalls by 2025 under the Florida State Ocean Outfall Legislation 

Compliance Plan, Chapter 2008-232 Laws of Florida Wastewater Disposal/Ocean Outfalls 

Appendix E NUREG–2176 E-230 October 2016
[Section 403.086 (9), Florida Statutes and Amendment CS/SB 444]. Therefore, the NRC staff 

concluded that the reclaimed-water supply is reliable and use of the RCWs for short periods of 

time is likely to have small impacts on groundwater users or on the extent of saltwater intrusion 

based on the FPL model analysis, USGS modeling analysis, the NRC review team's modeling 

of the CCS-RCW interaction, and the knowledge that environmental monitoring and potential 

mitigation measures are required under the COCs imposed by Florida State. If reclaimed water 

is not available and the 60-day limitation on RCW pumping is exhausted, the plant can be safely 

shut down. 

Cooling the main condenser is not a safety function in the AP1000 design. Accordingly, there is 

no NRC requirement for a contingency plan to supply emergency backup cooling water to the 

main condenser if reclaimed water is not available and the 60-day limitation on RCW pumping is 

exhausted. The plant can be safely shut down if water is not available from either 

source. Safety-related cooling water is stored onsite and can be replenished from multiple 

sources. The EIS analysis assumes that the RCWs would not operate more than 60 days per 

year, the primary source of cooling water—reclaimed wastewater from the MDWASD—should 

be highly reliable, and therefore the availability of backup cooling-water supplies need not be 

evaluated. Further, the review team also considered alternative sources of cooling water in EIS 

Section 9.4.2, none of which are environmentally preferable to the proposed sources of cooling 

water. In view of the high reliability of the reclaimed wastewater source and the availability of 

the RCW system as a backup, there is no need to consider additional backup sources of cooling 

water. 

Comment: The second omission is a failure to note a possible harm to Biscayne Bay National 

Park's eco system if the hypersaline plume is relocated into Biscayne Bay. The Draft Impact 

Statement indicates that intermittent pumping, which is what's proposed, could displace the 

hypersaline plume into the path of fresh water flowing eastward. Here's a quote: "Intermittent 

operation could result in an increase of hypersaline flow into the aquifer beneath the bay that 

could migrate into the bay when the radial collector wells are not operating." G-29. So 

emergence of the hypersaline water into Biscayne Bay could result in a localized hypersalinity 

that would kill sea grass beds in Biscayne National Park, which is what happened during a 

period of hypersalinity in Florida Bay in Everglades National Park in the early 1990's, and those 

areas of Everglades National Park remain dead zones to this day. So the Draft Impact 

Statement is incomplete because it doesn't evaluate the possible harm to the ecosystem of 

Biscayne Bay, Biscayne National Park if the hypersaline plume under the cooling canals is 

forced in to the Bay by pumping from the radial collector wells. (0721-2-4 [Stoddard, Philip K.])

Response: The review team acknowledges that the distribution of contaminants from the 

cooling canals in groundwater beneath Biscayne Bay could be affected to some degree by 

pumping of the planned RCWs beneath Biscayne Bay. After publication of the draft EIS, the 

NRC staff performed additional groundwater modeling of the interaction between the planned 

RCWs, the existing hypersaline plume, and the cooling canals using a two-dimensional crosssection model and a limited-extent three-dimensional model. The review team used the RTF 

(Review Team Focused) model, to perform simulations to better understand how the existing 

hypersaline plume may be affected by RCW pumping combined with remediation actions 

recently stipulated in the recent consent order between FPL and Miami-Dade County. 

This model was useful in showing salinity changes that occur in the aquifer near the RCWs 

when the wells are operated. The results showed that when the wells are not operating 

hypersaline water from the cooling canals is present in the high-permeability zone where the 

well laterals are installed. This saline water is drawn into the wells during the first few days of 

Appendix E October 2016 E-231 NUREG–2176
RCW pumping, resulting in increasing, then decreasing, salinity at the well. The RTF model 

predicts that the salinity of the water produced by the operating RCW eventually drops to about 

the concentration of the bay water. Water flowing down through the bed of the bay and into the 

RCWs is therefore expected to have about the same salinity as bay water. When RCW 

pumping ceases, water in the high-permeability zone again increases in salinity because of the 

migration of water from the hypersaline plume. This migration of hypersaline water into the 

high-permeability zone would occur regardless of the presence of the RCWs. 

Predicted future change in sea level and its effect on interactions between the RCWs and the 

hypersaline plume were also simulated. The additional modeling confirmed that pumping of the 

RCWs would move hypersaline water toward the RCWs and would remove some groundwater 

captured by the RCWs from the hypersaline plume region of the Biscayne aquifer. The model 

also indicated that RCWs pumping is not likely to reduce the effectiveness of hypersaline plume 

remediation actions specified in the consent order. 

Reclaimed wastewater would be the primary source of cooling water for the proposed 

reactors. Saline water from the RCWs beneath Biscayne Bay would only be used when 

reclaimed treated wastewater is not available in sufficient quantity or quality, and for a maximum 

of 60 days per year that is permitted under the Florida State COCs. A very large volume of 

treated municipal wastewater is available for this purpose, but the treated wastewater is not 

suitable for normal uses of fresh water, such as for drinking or agriculture. Accordingly, the 

treated municipal wastewater can be used for cooling proposed Turkey Point Units 6 and 7 

without affecting the ability to meet demands for fresh water. MDWASD is required to direct 60 

percent of the wastewater flows to reuse by 2025 and to cease using ocean outfalls by 2025 

under the Florida State Ocean Outfall Legislation Compliance Plan, Chapter 2008-232 Laws of 

Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. Therefore, the NRC staff concluded that the reclaimed water supply 

is reliable, and it is likely that the RCWs would be used less than the 60 days per year permitted 

under the COCs. The modeling described above provided evidence that limited pumping of the 

RCWs as a backup water supply less than 60 days per year is unlikely to cause a significant 

increase in salinity within the bed of Biscayne Bay or within the bay itself compared to the 

variability that occurs under current conditions. 

The review team recognizes that complete knowledge of the hydrologic system associated with 

the RCWs is not now available, and that uncertainties therefore remain in the impact 

analysis. A vast number of future scenarios are plausible. The sources of uncertainty in the 

RCW analysis include: heterogeneity in subsurface parameters, lack of experience with RCW 

systems in carbonate strata, and uncertainty in the potential need for using the backup water 

supply. Uncertainties in the future site environment include: freshening of IWF cooling canals, 

remediation of the subsurface hypersaline plume, and the magnitude and rate of future sealevel rise. 

The determinations in this EIS related to groundwater are based on the FPL numerical model 

analysis, the USGS model analysis, the review team’s independent numerical modeling 

analysis, and the review team’s knowledge and expertise. The conceptual models that served 

as the basis for the numerical models are based on available characterization information for 

the Turkey Point site and surrounding region. Uncertainties in the information and conceptual 

model were addressed in some cases by performing multiple model runs while varying key 

parameters in the model and in other cases by using conservative parameter values. However, 

uncertainties remain that do not allow the review team to assert that no other conceptual models 

that may result in more adverse impacts from RCW operation are plausible. Heterogeneity in 

Appendix E NUREG–2176 E-232 October 2016
subsurface parameters, lack of experience with RCW systems in carbonate strata, and 

uncertainty in the future site environment (e.g., freshening of IWF, remediation of subsurface 

hypersaline plume, sea-level rise) all warrant the review team to exercise care to avoid relying 

on numerical models alone. Because of this, the review team does not rely solely on the output 

of any numerical model. 

Numerical models are numerical representations of complex processes occurring in three 

dimensions over time. The appropriate role of a numerical model is to test the assumptions of 

the behavior of complex systems. While even running a numerical model numerous times with 

different parameters cannot compensate for all uncertainties, the models employed here have 

been tested and benchmarked within the conditions that limit their application. In this 

assessment the review team analysts used models to test possible consequences of changes in 

the affected environment and uncertainty in some subsurface parameters within the capability of 

the models employed. This information was combined with the geography of the RCW field 

(such as the relatively short distance from the laterals to the bottom of Biscayne Bay relative to 

the distance from the laterals to the Homestead well fields) and the COC requirement of a 

monitoring program with mitigation options. The review team determined that the proposed 

monitoring of RCW construction and operation that is included is sufficient to detect unexpected 

behavior in a timely manner. While all possible mitigation measures have not yet been spelled 

out, in accordance with the COC, the review team considers the ultimate mitigation of ceasing 

operation of the RCWs as ensuring prevention of any impacts in a timely manner. “When harm 

occurs, or is imminent, SFWMD will require Licensee to modify withdrawal rates or mitigate the 

harm” (FDEP 2014-TN4371). 

If reclaimed water is not available and the 60 day limitation on RCW pumping is exhausted, the 

plant can be safely shut down. Cooling the main condenser is not a safety function in the 

AP1000 design. Accordingly, there is no NRC requirement for a contingency plan to supply for 

emergency backup cooling water to the main condenser if reclaimed water is not available and 

the 60-day limitation on RCW pumping is exhausted. The plant can be safely shut down if water 

is not available from either source. Safety-related cooling water is stored onsite and can be 

replenished from multiple sources. The EIS analysis assumes that the RCWs would not 

operate more than 60 days per year, the primary source of cooling water—reclaimed 

wastewater from the MDWASD—should be highly reliable, and therefore the availability of 

backup cooling-water supplies need not be evaluated. Further, the NRC staff also considered 

alternative sources of cooling water in EIS Section 9.4.2, none of which are environmentally 

preferable to the proposed sources of cooling water. In view of the high reliability of the 

reclaimed wastewater source and the availability of the RCW system as a backup, there is no 

need to consider additional backup sources of cooling water. 

Comment: Failure to Adequately Address the Cumulative Impacts of Constructing and 

Operating Units 6 & 7 on Salinity Levels in Groundwater, Surface Water, the Biscayne 

Aquifer, and Biscayne Bay

The DEIS fails to adequately address the cumulative impacts of constructing and operating 

Units 6 & 7 on salinity levels in groundwater, surface water, the Biscayne Aquifer, and Biscayne 

Bay. One of the most significant environmental impacts of the proposed action is the potential 

for greatly increased salinity levels in an ecosystem that is already stressed by high salinity. The 

construction and operation of Units 6 & 7 could lead to the expansion and continued migration 

of the underground hypersaline plume that is currently threatening groundwater supplies. 

Construction activities would likely add an increased amount of nutrients and dissolved organic 

materials into the CCS. Adverse environmental impacts could occur if these contaminants reach 

Appendix E October 2016 E-233 NUREG–2176
the waters of Biscayne Bay. Increased salinities in the project area could result as cumulative 

impacts when combined with the use of radial wells that withdraw freshwater from Biscayne Bay 

and the Biscayne Aquifer (increasing salinity levels in the Bay); the reservation of municipal 

wastewater that might otherwise be used to provide freshwater to Biscayne Bay's littoral zone 

through BBCW; the failure of FPL to elevate the entire project area and its facilities to protect 

against saltwater intrusion from sea level rise and storm surge; and the use of injection wells 

that could increase salinities in the Floridan Aquifer. (0113-2-10 [Lopez, Jaclyn] [McLaughlin, 

Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Response: In addition to the review team’s conceptual understanding of the processes that 

would occur with RCW operation, the review team considered three independent modeling 

studies that are all consistent in projecting only insignificant alterations to both the Biscayne Bay 

and the surficial aquifer. The review team considered a wide range of baseline environmental 

conditions to reflect the uncertainty in the baseline environment associated with various 

proposed actions associated with the industrial wastewater facility (IWF), climate change, and 

geohydrologic parameter uncertainty. While the environmental baseline may change 

significantly, the incremental alteration to the hypersaline plume associated with operation of the 

RCWs remains minor. All of these modeling studies are cumulative analyses. The review team 

considered both the impact of the proposed plant and a range of other future activities that may 

also change the environment at the same time. Regarding the potential use of reclaimed 

wastewater that could be used to “refresh” the Bay under the BBCW, or CERP based on the 

limited need for freshening water with impaired water quality, the range of available water 

sources, and the limitations on the timing of water withdrawals, NRC staff have not identified 

any noticeable effect on the surface water resources used to support CERP. Therefore, the 

NRC staff considered this practice to have minimal impacts. Moreover, reclaimed wastewater 

could not be used to “refresh” the Bay without additional treatment. The NRC staff revised the 

text in Sections 2.3, 5.2, and G.3.2 of the EIS to expand and clarify the process and findings of 

the analysis of the potential alteration of the hypersaline plume caused by the operation of the 

radial collector well (RCW) system. 

Comment: What are the impacts of this [drift] on the aquifer? (0721-22-14 [Schwartz, Matthew])

Response: As discussed in Section 5.3.1 of the EIS, cooling-tower drift would be deposited on 

the ground surface in the vicinity of the proposed Turkey Point Unit 6 and 7 mechanical draft 

cooling towers and the surface of the existing Units 3 and 4 cooling canals and the Biscayne 

Bay. Most of this drift would fall on Biscayne Bay and the existing cooling canals. As described 

in Chapter 3 of the EIS, drift of cooling water from the proposed plants cooling towers would 

total about 8 gpm. The effects of drift on the Bay and the existing cooling canals would be small 

because the amount of salt and other chemical constituents in the drift is negligible compared to 

the volume of the Bay and the cooling canals. In regard to the underlying Biscayne aquifer, the 

impact of salt and other chemical constituents in the drift would be expected to be negligible 

because the salinity of water in the aquifer in this area is already elevated by saltwater intrusion 

from the bay and by the hypersaline groundwater plume from the cooling canals. 

Comment: That's what the EIS is supposed to look at, what exactly is in that wastewater going 

in? (0723-9-16 [Schwartz, Matthew])

Response: Table 3-5 lists the constituents of the reclaimed wastewater and their 

concentrations at the point of injection. Table 5-2 lists those that would be released in coolingtower drift (water droplets emitted from the cooling towers). Some of these constituents are 

volatile and would evaporate in the cooling towers, and some would be injected by deep wells 

Appendix E NUREG–2176 E-234 October 2016
into the Boulder Zone along with the remaining used cooling water. Sections 5.2 and 5.3 of the 

EIS include detailed descriptions of the constituents predicted to be present in cooling-tower 

drift, the rates and patterns of drift deposition, and the potential environmental impacts of the 

drift. No changes were made to the EIS in response to this comment. 

Comment: Neither the draft EIS nor the EFH assessment describe another type of frac-out 

associated with horizontal directional drilling (HDD), the construction method for the RCWs. 

During HDD, drilling mud can escape into the environment through fractures in the rock 

potentially degrading EFH. The Southeast Florida Coral Reef Initiative's Best Management 

Practices (BMPs) for Construction, Dredge and Fill and Other Activities Adjacent to Coral Reefs1

[footnote 1: 1 Available at: 

www.floridadep.org/coastal/programs/coral/reports/MICCI/MICCI_6_BMP_Manual.pdf] notes 

the risk of frac-outs occurring can be reduced through proper geotechnical assessment 

practices and prudent drill planning and execution. The BMPs also describe how the extent of 

damage from a frac-out can be limited by carefully monitoring the hydraulic pressure and having 

the appropriate response equipment and contingency plans ready in the event that a frac-out 

occurs. While these measures and BMPs are useful in reducing and limiting the occurrence of 

frac-outs, direct measures of borehole pressure may be necessary for the agencies to have 

reasonable assurance that damage from frac-outs would be minimal. Stauber et al. (2003) 

presents a method for predicting borehole pressure by means of a demand-capacity analysis. 

With a calculated maximum allowable borehole pressure curve for a given HDD bore profile, 

specifications could require borehole pressure be maintained below the maximum allowable 

value or to maintain rheological properties within specified limits. (0724-6 [Fay, Virginia M.])

Response: The Florida State Conditions of Certification require following submission and 

approval of a drilling plan for construction of the radial collector wells and contingency plans for 

natural or man-made uncontrolled release of excavated material (State of Florida 2014-

TN3637). These plans will include “Best Management Practices” such as those mentioned in 

the comment. FPL has also provided a plan stating that the laterals would be drilled using a 

reverse circulation method with water from the formation as the drilling fluid and cuttings being 

circulated from the drill bit back to the central radial caisson, where the fluid and cuttings would 

be collected. No drilling mud would be used. Accordingly, a “frac-out” that would result in flow 

of any material into the bay, is not a possibility. 

Comment: The NMFS requests the NRC update final EIS and EFH assessment to describe 

plans to perform close monitoring along the RCW lateral pipelines during construction to ensure 

frac-outs are identified and remediated immediately and, if necessary, compensatory mitigation 

implemented. To assist with developing this monitoring plan for the Turkey Point RCWs, the 

NMFS will send separate from this letter monitoring plans used by the NMFS, USACE, and 

Florida Department of Environmental Protection (FDEP) for similar projects. (0724-7 [Fay, Virginia 

M.])

Response: Best Management Practices (BMPs) would be used during the construction of the 

RCW caissons and laterals. These BMPs would involve monitoring along the laterals, as 

mentioned in the comment. Monitoring and contingency plans would also be required by the 

Florida State COCs and would limit the potential impacts on Biscayne Bay that might result from 

the release of material such as drill cuttings through natural or induced fractures. The review 

team understands further that the RCW laterals would be drilled using a reverse circulation 

method with water from the formation serving as the drilling fluid and cuttings being circulated 

from the drill bit back to the central radial caisson, where the fluid and cuttings would be 

Appendix E October 2016 E-235 NUREG–2176
collected. No drilling mud would be used. No changes were made to the EIS in response to 

this comment. 

Comment: DEIS Subsection 4.2.1: There are inconsistencies in the DEIS regarding the 

duration of dewatering activities: a. DEIS Subsection 4.2.1.1, Page 4-27, Lines 37-41: The DEIS 

states: "...the expected dewatering flow rate into the IWF would be 1,000 gpm for 13 weeks, 

followed by 1,200 gpm for 13 weeks, followed by an extended period at 200 gpm. However, 

taking a conservative approach, FPL assumed that the maximum dewatering flows would be 

1,200 gpm for 1 year followed by 200 gpm for a period of about 24 months." b. DEIS 

Subsection 4.2.1.2, Page 4-29, Lines 26-29: The DEIS states: "FPL (2014-TN4058) estimated 

that a maximum of 1,000 gpm of groundwater would be pumped for up to 13 weeks at each of 

the two deep excavation pits during the initial excavation and grouting phase, followed by a 24-

month period of pumping at up to 200 gpm."; c. DEIS Subsection 4.2.1.4, Page 4-33, Lines 17-

19: The DEIS states: "The 1,200 gpm (1.7 Mgd) discharge that could occur over the course of a 

year..." The following explanation can be used to reconcile each of these inconsistencies: 

Because the start of the plant excavation would be staggered, the expected total maximum 

dewatering flow rate into the IWF would be 1,000 gpm for 6 months, followed by 1,200 gpm for 

6 months, followed by 400 gpm for 18 months and then 200 gpm for 6 months. However, taking 

a conservative approach, FPL assumed that the maximum dewatering flows would be 1,200 

gpm for 1 year followed by 400 gpm for a period of about 24 months. (0619-4-2 [Maher, William])

Response: The EIS was modified to clarify the expected flow rates from the excavations and 

the more conservative flow rates applied in the FPL analysis. 

Comment: DEIS Subsection 7.2.2.2, Page 7-15, Lines 17-19: The DEIS states: "FPL 

determined that adding the requested 2,000 gpm of brackish water would increase the water 

level of the canals by 0.25 ft (Tetra Tech 2014-TN4126) and eventually reduce salinity to 

approximately that of Biscayne Bay." The reference states: "The first model configuration, called 

the unconstrained model, predicted water levels in the CCS considering the addition of 14 mgd 

of Floridan water. This model was used to determine the increase in canal stage that would 

likely result from the added inflow: an average of 0.25 ft due to the Floridan-based inflow". The 

14 mgd stated in the reference is equivalent to 9722 gpm, which is inconsistent with the 2000 

gpm stated in the DEIS. (emphasis added) (0619-5-8 [Maher, William])

Response: The expected flow of water for IWF freshening was corrected to 14 Mgd. 

Comment: The other point that I heard brought up is the water re-injection into the wells. 

Currently that is the process that Miami-Dade uses with their wastewater, they re-inject into the 

wells -- into the groundwater. The only difference we're doing is we're taking that water, treating 

it, using it to cool our reactor and then re-injecting it. So the process is actually cleaner than the 

current process that Miami-Dade has for disposing of wastewater. (0721-15-10 [Kuraza, Devon])

Response: The EIS discusses changes to the reclaimed water, including higher water 

temperature, increase salinity, and the addition of other waste streams that include 

radionuclides, caused by its use in cooling the proposed reactors. However, the review team 

agrees that there is a benefit in using reclaimed water. MDWASD is required to direct 60 

percent of its wastewater flows to reuse by 2025 and to cease using ocean outfalls by 2025 

under the Florida State Ocean Outfall Legislation Compliance Plan (Miami-Dade County 2013-

TN4786). 

Appendix E NUREG–2176 E-236 October 2016
Comment: We also have to look at the assumptions that you're making about the water supply, 

the radial well collectors and how well they'll operate under super-salinity conditions. And the 

wastewater supply which is drying up in South Florida. This plant is going to assume that you're 

going to consumer 50 million gallons a day of water, and that's huge. This is just for 6 and 7, 

incremental demand. (0723-12-14 [Henry, Jim])

Response: Higher salinity of cooling water resulting from capture of some hypersaline plume 

water by the RCWs would not have a significant effect on the plant cooling system. The NRC 

review team determined that the RCWs are likely to be used infrequently and for short 

durations. There is a very large volume of treated municipal wastewater that can be used for 

cooling the proposed plants without affecting the ability to meet demands for 

freshwater. MDWASD is required to direct 60 percent of the wastewater flows to reuse by 2025 

and to cease using ocean outfalls by 2025 under the Florida State Ocean Outfall Legislation 

Compliance Plan Chapter 2008-232 Laws of Florida Wastewater Disposal/Ocean Outfalls 

[Section 403.086 (9), Florida Statutes and Amendment CS/SB 444]. 

E.2.9 Comments Concerning Ecology - Terrestrial 

Comment: It's [the reactor] going to destroy wetlands[.] (0008-7 [Finver, Jody])

Response: The EIS acknowledges that building the new reactors and associated facilities 

would unavoidably result in the loss of wetland acreage and functions. Impacts on wetlands are 

described in Sections 4.3.1 and 5.3.1 of the EIS. Section 4.3.1.6 outlines the applicant’s 

proposed wetland mitigation measures and how those mitigation measures would offset wetland 

functions lost. No changes were made to the EIS as a result of this comment. 

Comment: Potential mitigation measures are speculative, inadequate, and based on 

incomplete information. (0113-1-9 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, 

Matthew] [Silverstein, Rachel])

Comment: The DEIS fails to comply with NEPA because its determinations of the project's 

environmental impacts, dismissal of other alternatives, and recommendation to issue the COL 

are based on speculative mitigation measures that have not been adequately analyzed. NEPA 

requires an analysis and discussion of the extent to which adverse effects can be avoided. 

[Footnote 53: Roberston v. Methow Valley Citizens Council, 490 U.S. 332, 315-352, 1989, 352.] 

Therefore, the DEIS is insufficient in satisfying the requirements of NEPA because it merely lists 

"possible" and "potential" mitigation measures for terrestrial impacts of the project. [Footnote 54: 

Neighbors of Cuddy Mountain v. U.S. Forest Service, 137F.3d 1372, 1380, 9th Cir.1, 1998.] It 

fails to adequately analyze the effectiveness of the proposed measures in mitigating project 

impacts, [Footnote 55: NRC, DEIS, 4-3, 4-69, 4-72.] despite the fact that an "essential 

component of a reasonably complete mitigation discussion is an assessment of whether the 

proposed mitigation measures can be effective." [Footnote 56: S. Fork Band Council of W. 

Shoshone of Nevada v. U.S. Department of Interior, 588F.3d 718, 727, 9th Cir., 2009.] 

Notwithstanding the failure of the DEIS to adequately analyze the efficacy of "proposed" or 

"possible" mitigation activities, the DEIS gives an impact category to wetland and terrestrial 

impacts and recommends that the COL be issued based on potential mitigation measures 

described in the Environmental Report and DEIS. [Footnote 57: NRC, DEIS, 10-28.] The 

determination of an impact level category for each resource area is based on the assumption 

the mitigation activities are implemented. "Proposed mitigation efforts" are listed and include an 

in-lieu fee program, mitigation banks, or permittee responsible mitigation. [Footnote 58: Ibid., 

106.] It is unclear as to which combination of mitigation measures will actually be implemented, 

Appendix E October 2016 E-237 NUREG–2176
considering that some possible mitigation options, including the NPS Hole-in-the Donut 

Mitigation Bank, are not federally approved and that some programs are not approved by the 

U.S. Army Corps of Engineers. [Footnote 59: Ibid., 4-71.] Furthermore, the DEIS does not 

describe why and how mitigation measures will sufficiently offset the loss of wetlands 

anticipated as a result of this project. In order to comply with NEPA, a more thorough analysis of 

concrete and actionable mitigation measures must be included in an EIS. The NRC repeatedly 

states that the U.S. Army Corps of Engineers has not evaluated the proposed mitigation 

measures because the applicant has not demonstrated that wetland impacts have been avoided 

or minimized according to Clean Water Act section 404(b)(1) guidelines. [Footnote 60: Ibid., 4-

69, 4-70, 4-73.] An evaluation of proposed mitigation measures by the Corps is expected as part 

of the Corps' Record of Decision, which will not be made until after the Final EIS is issued. 

Furthermore, the DEIS indicates that further mitigation for wetland and listed species impacts 

may be required. [Footnote 61: Ibid., 4-72.] It is premature for the NRC to issue a DEIS, assign 

impact analyses to affected resources, dismiss other alternatives, and issue a preliminary 

recommendation to issue a COL prior to any substantive analysis of the effectiveness of 

mitigation measures. The information requirement to make such a determination must be 

included in the DEIS, rather than any future decision-making process. After reviewing the 

proposed mitigation for the project, the EPA determined that a permit for the project should not 

be issued because of "substantial and unacceptable impacts to mangrove wetlands, sawgrass 

marshes, and submerged aquatic vegetation." [Footnote 62: Gattiana, J. L., United States 

Environmental Protection Agency Letter to Colonel Alan M. Dodd, U.S. Army Corps of 

Engineers, April 9, 2015, 4.] Pursuant to the Clean Water Act 404(b)(1) Guidelines [Footnote 63: 

40 C.F.R. § 230.91(c).] and a February 6, 1990 Memorandum of Agreement between the Corps 

and the EPA regarding the Determination of Mitigation under the Clean Water Act 404(b)(1), "an 

applicant must demonstrate avoidance and minimization of wetland impacts before 

compensatory mitigation can be considered." [Footnote 64: Gattiana, J. L., United States 

Environmental Protection Agency Letter to Colonel Alan M. Dodd, U.S. Army Corps of 

Engineers, April 9, 2015, 3.] The DEIS must therefore include a more substantial discussion and 

analysis of mitigation measures, rather than a mere identification of "possible" or "potential" 

mitigation activities, and a sufficient discussion of how mitigation activities would effectively 

offset the impacts of the proposed projects. In consideration of the fact that the proposed project 

will have significant negative impacts to the ecology and health of Biscayne Bay, Biscayne 

National Park, and adjacent sensitive ecological areas, any consideration of adequate mitigation 

must include mitigation activities that offset these negative impacts by improving the health of 

these important ecological areas. The BBCW project aims to improve the health of nearshore 

and wetland areas of Biscayne Bay and Biscayne National Park by rehydrating coastal 

wetlands. In order to achieve the goals of this project, significant water storage and delivery 

must be developed in the area adjacent to Turkey Point Power Plant. Much of the lands needed 

for public ownership to proceed with the project are currently owned and managed by FPL. 

Transferring such land into public ownership for the purposes of BBCW as originally envisioned 

by CERP would go a long way towards achieving Everglades restoration goals and the 

restoration of critical wetland habitat and function in Biscayne Bay. Thus, mitigation measures 

should include the transfer of FPL land within the footprint of the original and complete BBCW 

project to public ownership. (0113-2-14 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] 

[Schwartz, Matthew] [Silverstein, Rachel])

Response: The EIS discusses the applicant’s conceptual approach for mitigating impacts on 

wetlands and other terrestrial ecology resources in Section 4.3.1.6 of the EIS. Although the EIS 

discussed mitigation at a conceptual level, the discussion is not speculative. The applicant has 

indicated that each of the mitigation measures discussed in the EIS would be implemented once 

the project proceeds. Most would be required under one or more Federal or State regulation(s) 

Appendix E NUREG–2176 E-238 October 2016
protecting wetlands or other sensitive ecological resources, such as Section 404 of the Clean 

Water Act, the ESA (Endangered Species Act), or the Florida Power Plant Siting Act. The 

discussions are based on recommendations and requirements from the local, State, and 

Federal regulatory agencies that regulate impacts on wetlands and habitat. No changes were 

made to the EIS specifically as a result of this comment, although the mitigation discussions, 

primarily addressed in Section 4.3.1.6, have been updated to reflect the latest information 

available from the applicant. 

Comment: The loss of valuable habitat to expand is also unacceptable. We need to protect 

what is left. (0066-3 [Wong, Christina])

Comment: Access Roads[.] According to the DEIS, "approximately 3 .3 miles of existing paved 

roads would be improved, and approximately 7 miles of unpaved roads would be paved to 

provide access to the site." Additionally, "a heavy-haul road would be created between the 

barge-unloading facility and the building site, which would disturb approximately 5 acres. The 

heavy-haul road would be 2 miles long and 24 ft. wide, and would include new heavy-haul 

bridges across the existing discharge and return cooling canals." A patchwork of new roads 

would further fragment important habitat for Florida Panthers and other wildlife, and create 

impediments for restoring hydrological flows. The NPS encourages land protection and 

restoration efforts, such as those under EEL, to offset these impacts. (0622-2-13 [Austin, Stan])

Response: Section 4.3.1 of the EIS acknowledges habitat losses and fragmentation caused by 

building the proposed facilities. Mitigation proposed by the applicant to address terrestrial 

ecology impacts from building the proposed new facilities in compliance with local and State 

regulatory requirements is presented in Section 4.3.1.6. No changes were made to the EIS as a 

result of these comments. 

Comment: The DEIS fails to provide an adequate analysis of the direct, indirect, and 

cumulative impacts of the construction and operation of transmission lines and access roads on 

sensitive wetlands, wildlife, and CERP activities. (0113-1-6 [Lopez, Jaclyn] [McLaughlin, Caroline] 

[Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Response: The NRC staff discusses in detail impacts of the construction and operation of 

transmission lines and access roads on sensitive wetlands and wildlife in Sections 4.3.1 and 

5.3.1 of the EIS. Cumulative impacts on wetlands, wildlife, and CERP activities are addressed 

in Section 7.3. The review team has added additional detail to the impact discussions based on 

new information available subsequent to publication of the draft EIS, but made no changes to 

the EIS specifically as a result of this comment. 

Comment: Pipelines (potable and reclaimed water)[.] Pipelines would be installed between the 

MDWASD South District Wastewater Treatment Plant and the reclaimed water-treatment facility 

at the Turkey Point site. The potable water line would include approximately 10 miles of new 

pipeline, most of it along existing roads or corridors. Approximately 2.5 miles of pipeline 

construction would involve new land disturbance, and the pipeline would affect 326 acres, 

including 184 acres of wetlands. The reclaimed water pipeline would include approximately 9 

miles of new pipeline, approximately 2.5 miles of which would be in a new pipeline corridor. 

According to the DEIS, approximately 1,886 ac of upland, forested, and wetland habitats would 

be affected as well as mangrove swamp, mixed wetland hardwoods, shrub and brushland, 

wetland shrubs, freshwater marsh, mixed rangeland, and herbaceous prairie. The NPS 

encourages land protection and restoration efforts, such as those under EEL (described above), 

to offset the pipeline-related impacts. (0622-2-10 [Austin, Stan])

Appendix E October 2016 E-239 NUREG–2176
Comment: Transmission line crossing under the Miami River[.] According to USACE's public 

notice, "A short section of the proposed Davis-Miami 230-kV transmission line, at the crossing of 

the Miami River adjacent to the existing FPL Miami substation, is proposed to be constructed as 

an underground extruded dielectric cable system using cross-linked polyethylene insulating 

cables." The NPS encourages that consideration be given to restoring the Key Hole and Elliot 

Key Spoils area within Biscayne NP. The area has high natural value but needs to be cut and 

filled for restoration. (0622-2-12 [Austin, Stan])

Response: The comment provides recommendations for specific mitigation measures 

addressing impacts on sensitive natural habitats. The review team appreciates suggestions 

regarding possible mitigation measures but only considers mitigation proposed by the applicant 

or required by agencies specifically authorized to enforce the mitigation. No change was made 

to the EIS as a result of this comment. 

Comment: As detailed throughout our comments, the proposed project could have numerous 

adverse environmental impacts to our national parks and the treasured natural resources they 

were designated to protect. Specifically, threatened wildlife and wetland habitat in Everglades 

National Park could be harmed by the construction and operation of transmission line corridors 

in and adjacent to the park. (0113-1-10 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] 

[Schwartz, Matthew] [Silverstein, Rachel])

Response: Potential impacts on threatened and endangered species as well as wetlands as a 

result of transmission line construction are discussed in Sections 4.3.1.2 and 5.3.1.2 of the 

EIS. Although the analyses contained in both sections consider the unique setting of the 

proposed site and offsite rights-of-way in close proximity to Everglades National Park and 

Biscayne National Park, additional discussion was added to Section 4.3.1.3 about wildlife 

expected to regularly enter and leave National Park boundaries that could be affected by the 

proposed actions. Mitigation for impacts on wetlands and other terrestrial ecological resources 

from building the proposed facilities, including the transmission lines, is discussed in Section 

4.3.1.6. 

Comment: In order to connect Units 6 & 7 to the power grid, FPL seeks to construct two new 

transmission line corridors. The proposed transmission line sites for the Western corridor are of 

primary concern due to their potential impacts on areas in and around Everglades National 

Park. The DEIS fails to adequately analyze the direct, indirect, and cumulative impacts of the 

construction and operation of transmission lines on wetlands, wildlife, and CERP. In its 

discussion of potential Western transmission line corridors, the DEIS limits its discussion to 

West Preferred and West Consensus corridors. The construction and operation of transmission 

lines and access roads in either of these corridors could cause an array of adverse 

environmental impacts, including impacts to wildlife, habitat, and wetland resources, such as 

freshwater marshes, wetland hardwoods, and wet prairies; the disruption of hydrologic flows; air 

and water pollution; viewshed impacts; and impacts to national park visitor experiences. 

[Footnote 32: Florida Department of Environmental Protection, Second Determination of 

Completeness, Transmission Lines, September 17, 2009, 1.] The project could harm waterdependent birds, such as migratory birds and federally listed wood storks and snail kites. 

Woods storks are listed as a federally threatened species due to habitat loss, fragmentation, 

and degradation. Wading birds such as the wood stork are at risk of collision with powerlines 

because of their large size and inability to navigate obstacles while flying. In a scientific 

evaluation of wood stork mortality, collisions with powerlines were listed as the most significant 

cause of death. [Footnote 33: Forrester, D.J. and Spalding, M.G., “Ibises, Spoonbills, 

Flamingos, and Storks: Trauma,” Parasites and Diseases of Wild Birds in Florida, 2003, 

Appendix E NUREG–2176 E-240 October 2016
University Press of Florida, Gainesville, 227-228.] It is reasonable to anticipate that, given the 

high collision risk of wood storks and wading birds, the construction of powerlines in critical 

wood stork habitat will lead to a sustained level of mortality for these threatened species 

throughout the life of the project. The construction and operation of transmission lines could also 

lead to the degradation and fragmentation of critical wetland areas, disturbing birds during the 

construction process and creating a permanent risk of bird collisions and injuries from 

transmission lines and associated structures. (0113-2-8 [Lopez, Jaclyn] [McLaughlin, Caroline] 

[Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Response: Impacts on terrestrial resources from the proposed transmission lines are 

described in Sections 4.3.1.2 and 5.3.1.2 of the EIS and include consideration of direct, indirect, 

and cumulative impacts from building and operating those lines on wetlands and 

wildlife. Mitigation of the impacts on wetlands and other terrestrial ecological resources from 

building the proposed facilities, including the transmission lines, is discussed in Section 

4.3.1.6. No changes to the EIS were made as a result of this comment. 

Comment: Impacts associated with the construction and operation of access roads associated 

with Units 6 & 7 on wetlands and wildlife are not adequately discussed and analyzed within the 

DEIS. Access roads will be constructed in and adjacent to wetlands and conservation lands, 

including on lands that are part of the Miami-Dade County Environmentally Endangered Lands 

Program. [Footnote 34: Miami-Dade County, Third Completeness Comments for Plant and NonTransmission Line Portions of the FPL Site Certification Application- Turkey Point Units 6 & 7, 

May 28, 2010, 39.] The construction and operation of such roads could have a number of 

negative impacts, such as the disruption of ecological corridors and sheet flow and the 

degradation of conservation lands. [Footnote 35: Ibid., 39.] The DEIS lacks sufficient information 

regarding the possible overlap of access roads and wildlife corridors. The discussion of such 

impacts is cursory and as such fails to comply with the requirements of section 102(2) of NEPA. 

[Footnote 36: National Environmental Policy Act of 1969 §102(2) 42 U.S.C. § 4332.] (0113-2-9

[Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Response: Impacts on terrestrial resources from building and using the proposed temporary 

construction access roads are included in the scope of analysis of proposed onsite activities in 

Section 4.3.1.1. However, to provide increased clarity regarding the effects of the access roads, 

a separate header was added to Section 4.3.1.3 of the EIS to address the access road impact 

on Miami-Dade County Environmentally Endangered Lands. 

Comment: I am worried for animals that have been labeled "units of economy"instead of 

beings with active consciousnesses. (0127-3 [Cusidor, Teresa])

Response: Impacts on wildlife have been described in Sections 4.3.1, 5.3.1, and 7.3.1 of EIS 

using standardized and accepted ecological terminology, methodologies, and criteria as 

prescribed by State and Federal regulatory agencies. No changes were made to the EIS as a 

result of this comment. 

Comment: There will be negative impacts on the environment for both humans and other 

animals. (0159-3 [Bazzone, Barbara])

Response: Impacts on wildlife and their habitats are described in Sections 4.3.1, 4.3.2, 5.3.1, 

5.3.2, 7.3.1, and 7.3.2 of the EIS. Impacts on and potential conflicts with human land uses are 

addressed in Sections 4.1, 5.1, and 7.1. Various other issues related to the quality of the 

Appendix E October 2016 E-241 NUREG–2176
environment on humans, e.g., aesthetics and air quality, are addressed in various other 

sections. No changes were made to the EIS as a result of this comment. 

Comment: Please do not expand into this valuable habitat. (0202-1 [Casper, Laurel])

Response: Impacts on wildlife and their habitats are described in Sections 4.3.1, 4.3.2, 5.3.1, 

and 5.3.2 of the EIS. As is evident from the information contained in Section 4.3.1.1, much of 

the habitat encompassed by the proposed expansion has a history of previous disturbance or is 

in close proximity to existing disturbed areas. As is evident from the information contained in 

Section 4.3.1.2, much of the habitat encompassed by the expanded offsite facilities involved 

areas within or adjacent to existing utility corridors. No changes were made to the EIS as a 

result of this comment. 

Comment: Furthermore, nuclear reactors are known to impact wildlife in the region. (0214-4

[Zerulla, Tanja])

Response: Impacts on wildlife and their habitats are described in Sections 4.3.1, 4.3.2, 5.3.1, 

and 5.3.2 of the EIS. The discussion in these sections includes consideration of mitigation. The 

cumulative effects of the existing and new reactors on wildlife are addressed in Sections 7.3.1 

and 7.3.2. No changes were made to the EIS as a result of this comment. 

Comment: Metals leach from the reactors into the environment, contaminating air, water, 

ground, plants, and other wildlife. (0214-6 [Zerulla, Tanja])

Response: All pathways for potential environmental impacts were considered in the 

EIS. Potential releases of pollutants to the air during operation of the reactors is addressed in 

Section 5.7. Potential release of pollutants to water during operation of the reactors is 

addressed in Section 5.2. The effects of potential releases of radiological pollutants on plants, 

wildlife, and other non-human biota are addressed as part of Section 5.9. Text has been added 

to Sections 5.3.1 and 5.3.2 specifically to address the potential for adverse effects on terrestrial 

and aquatic biota from releases of nonradiological pollutants. 

Comment: Everglade snail kite - If the Preferred corridor segment of the west transmission line 

in chosen as the preferred alternative, it will result in habitat loss for the snail kite and 

significantly increase the likelihood that snail kites are injured and killed due to collisions with 

transmission lines. Please indicate how FPL intends to minimize the adverse effects of the 

preferred segment of the west transmission line corridor to the snail kite. The Department notes 

that we have had discussions with FPL regarding moving the northern segment of west 

transmission line [i.e., the currently proposed Preferred and Consensus corridors) much farther 

to the east, away from the Everglades National Park (ENP) and adjacent to existing 

development]. We believe that movement of this segment of the west transmission corridor as 

described will reduce potential adverse effects to the snail kite. We urge FPL to adopt this new 

corridor. If adoption of the new corridor does not occur, we recommend that FPL consider 

protecting currently unprotected wetlands habitat for the snail kite to minimize the adverse 

effects from the project. (0227-1 [Stanley, Joyce])

Response: Section 2.4.1.3 of the EIS describes the overlap of snail kite management areas 

and range with proposed facility construction locations. Sections 4.3.1.3 and 5.3.1.3 discuss 

potential impacts on the snail kite during installation and operation of transmission lines, and 

includes an evaluation of displacement, permanent habitat loss, and transmission line collision 

risks. Although not specific for snail kites, perch discouragers and flight diverters installed near 

Appendix E NUREG–2176 E-242 October 2016
stork colonies should reduce operational impacts on snail kites because their occurrence 

generally coincides with proximity to stork colonies. The review team concluded that the 

potential impact on the Everglade snail kite from the proposed actions could be noticeable at a 

population level. The FFWCC requires snail kite surveys in all suitable habitat as defined in the 

State of Florida COCs. If snail kites are observed, FPL is required to meet with the FFWCC and 

develop a detailed mitigation plan containing corrective action alternatives to be approved by 

the FFWCC. Additional mitigation may be required by the FWS as part of their ESA 

consultation process. No changes were made to the EIS as a result of this comment. 

Comment: Florida bonneted bat - The project will result in the loss of potential suitable roosting 

habitat for the FBB within the Department's focus area for the species. To better ascertain the 

status of the FBB on the project site, we request that a pedestrian survey of all suitable roosting 

habitat for the FBB be conducted within the entire project footprint, including the footprint of the 

proposed transmission lines. The results of the survey should be provided to the Department for 

our review. We also recommend that FPL include a survey of potential roosting habitat prior (no 

earlier than a month prior) to any clearing activities to ensure no FBB have recently begun 

roosting in the clearance areas. (0227-2 [Stanley, Joyce])

Response: Although the Florida Fish and Wildlife Conservation Commission (FFWCC) did not 

require any species specific measures for the Florida bonneted bat within the State of Florida 

COCs issued on 5/19/14, they included this species with other Federally and State-listed 

species likely to occur within the area of the transmission line corridor and associated 

facilities. As such, FFWCC requires coordination for an assessment of all listed species 

including the Florida bonneted bat prior to clearing or preconstruction activities within the 

transmission line corridors. Additional surveys and assessments could be required by the FWS 

as part of their ESA consultation process. Section 2.4.1.3 of the EIS was expanded to include a 

discussion of the overlap of the proposed project sites with the FWS Florida Bonneted Bat 

Focus Area. 

Comment: Florida panther - The Biological Assessment states that the project will result in the 

loss of 69 acres of panther habitat located within the project footprint. This habitat is located in 

the Department's primary and secondary zones for the panther. FPL's consultant has applied 

the Department's panther habitat methodology (PHM) to the habitat types affected by the 

project and calculated that the 69 acres of panther habitat lost due to the project provide 412 

Panther Habitat Units (PHUs). Based on the PHM, a total of 1,030 PHUs of panther habitat will 

need to be provided to offset the loss of panther habitat due to the project. We request a 

detailed habitat compensation plan indicating how FPL intends to provide 1,030 PHUs of 

panther habitat to offset the loss of panther habitat due to the project. (0227-3 [Stanley, Joyce])

Response: The State of Florida COCs issued by the Siting Board on 5/19/14 state that 

development of roads and pipeline corridors would affect 69 ac of Florida panther habitat within 

the FWS Panther Focus Area, with a value of 297 Panther Habitat Units. Although FPL's ER 

(Rev 6) states "Construction of new corridors, modification of existing corridors, and 

construction/modification of access roads will result in the alteration of panther habitat within the 

primary and secondary Panther Focus Area zones rather than a loss of habitat," the EIS states 

that the review team disagrees with this statement because habitat fragmentation has been 

identified in the FWS Florida Panther Recovery Plan (3rd revision dated 1 November, 2008) as 

a threat to panther survival. FPL-proposed mitigation activities for the Florida panther, 

addressed in Section 4.3.1.6, are designed to minimize threats of increased traffic and do not 

address habitat. Additional habitat mitigation could be required by the FWS as part of their EIS 

consultation. The discussion of potential impacts on the Florida panther in Section 4.3.1.3 of 

Appendix E October 2016 E-243 NUREG–2176
the EIS has been expanded to include more quantitative detail about panther habitat mitigation 

from the COCs and to present more detail drawn from the FWS Florida Panther Recovery Plan. 

Comment: Wood Stork. The proposed west transmission line corridor for the project occurs 

within the core foraging areas (i.e., all lands within 18.6 miles) of five active nesting colonies of 

the wood stork. As currently proposed the Preferred Corridor segment of west corridor 

transmission line occurs within about 1 mile or less of an active wood stork nest colony. 

Consequently, if this alternative is selected, it will likely result in injuries and deaths of wood 

storks and other bird species due to collisions with the transmission wires or towers during flight. 

If the transmission line cannot be re-sighted, we recommend considering additional 

compensation for impacts to wood stork above those currently being considered for wetland 

impacts. In addition, a wetlands mitigation plan that adequately compensates for the loss of 

wood stork foraging habitat due to the project should be developed. This should include a 

functional analysis of the loss of wood stork foraging habitat within the project footprint 

(including the transmission lines) through the application of the Fish and Wildlife Service's 

(FWS) Wood Stork Foraging Habitat Methodology (FWS, 2012). Please be aware that we 

consider all wetland types as suitable for wood stork foraging, and all wetland types lost due to 

the project should be included in the analysis. (0227-6 [Stanley, Joyce])

Response: Although impacts on the wood stork would be decreased if the West Consensus 

corridor were developed rather than the West Preferred corridor, impacts would still not be 

eliminated. Section 4.3.1.3 includes an assessment of potential impacts from both corridor 

options on the wood stork and acknowledges their proximity to wood stork nesting 

colonies. That discussion has been expanded to provide more detail about wood stork impacts 

and how the proposed wetland mitigation and other mitigation proposed by the applicant would 

help reduce adverse impacts on the wood stork. 

Comment: Additional Species. The Department requests species surveys be conducted (in 

appropriate habitat) for the Bartram's scrub-hairstreak butterfly and Florida leafwing butterfly. 

Botanical surveys should be conducted for crenulate lead-plant, deltoid spurge, Florida brickellbush, Small's milkpea, tiny polygala, and Garber's spurge. (0227-7 [Stanley, Joyce])

Response: Sections 4.3.1.4 and 5.3.1.3 of the EIS discuss potential impacts on each of these 

species and acknowledges the possible adverse impacts on each. Coordination with FFWCC 

for an assessment of all Federally and State-listed species likely to occur within the 

transmission line corridor and associated facilities prior to clearing or preconstruction activities is 

required by the State of Florida COCs issued on 5/19/14. Additional surveys and assessment 

could be required by the FWS as part of their ESA consultation process. No changes were 

made to the EIS as a result of this comment. 

Comment: Endangering delicate, one-of-a-kind species is not a good idea. (0363-4 [Peters, 

Emily])

Response: This comment pertains to species rare enough to be Federally and/or State-listed 

as threatened or endangered. The EIS includes a thorough assessment of potential impacts 

from the project on Federal and State-threatened and endangered species and habitats in 

Sections 4.3.1 and 5.3.1 (for terrestrial species) and Sections 4.3.2.3 and 5.3.2.3 (for aquatic 

species). These sections also address mitigation proposed regarding impacts on threatened or 

endangered species. No changes were made to the EIS specifically as a result of this 

comment, although expanded information about threatened and endangered species has been 

added to the sections noted above in response to other comments. 

Appendix E NUREG–2176 E-244 October 2016
Comment: Section 4.3.1.6, Wetland Mitigation Plan (pg.4-70): The DEIS states that FPL 

instituted measures during project planning to avoid and minimize impacts on wetlands to the 

greatest extent practicable. Proposed avoidance and minimization measures include 

maximizing the previously disturbed areas, while minimizing use of areas with high-quality intact 

wetlands. The corridor selection for the reclaimed water pipeline, portable water pipeline, and 

transmission facilities maximized co-location with other existing or proposed infrastructure, to 

limit land disturbance. The Public Notice published by the USACE on March 13, 2015 stated 

that the project proposes impacts to 1000 acres of tidal and freshwater wetlands. FPL stated in 

their letter of May 14, 2015, addressed to USACE, that the correct number for the direct wetland 

impacts for the project is 710 acres, with temporary impacts to 50 acres. These include impacts 

to high quality, tidal mangrove wetlands. Mangrove wetlands located within south Florida form a 

vital component of the estuarine and marine environment, providing a major organic detrital 

base to the aquatic food chains, significant habitat for arboreal, intertidal and subtidal 

organisms, nesting sites, cover and foraging grounds for birds, and habitat for reptiles and 

mammals. Mangroves also provide protected nursery area for fishes, crustaceans, and shellfish. 

Mangroves are one of the most biologically productive ecosystems in the world, also serving as 

storm buffers by functioning as wind breaks, and through prop root baffling of wave action. 

Mangrove roots stabilize shorelines and fine substrates, reducing turbidity, and enhancing water 

clarity. Mangroves improve water quality and clarity by filtering upland runoff, and trapping 

waterborne sediments and debris. The cumulative loss of this habitat has reduced overall water 

quality and fisheries production within the south Florida ecosystem. For these reasons, the EPA 

considers these mangrove wetlands to be aquatic resources of national importance (ARNI). In 

addition, the proposed project would impact sawgrass marshes, which provide principal 

environmental values related to water quality and quantity. They serve as filter systems for 

water, and protect natural bodies of water from eutrophication. Numerous birds can be found in 

this community year-round, or for over-wintering. They also provide habitat for frogs, snails, and 

crayfish, which serve as food sources for larger protected animals that are found in this region. 

Protected animals that can be found in and around sawgrass marsh systems include the 

Everglades mink (Mustela vison evergladensis), Florida panther (Felis concolor coryi), snail kite 

(Rostrlzamus sociabilis), wood stork (Mycteria americana), and American alligator (Alligator 

mississippiensis). Therefore, the EPA considers sawgrass marshes to be ARNI. (0617-1-28

[Mueller, Heinz J.])

Response: The description of affected wetlands in Section 2.4.1.3 of the EIS has been 

expanded to indicate the status of mangrove wetlands and sawgrass marshes as aquatic 

resources of national importance ARNI (Aquatic Resources of National Importance), and the 

assessments of impacts on those wetlands have been expanded in Section 4.3.1.1 of the EIS to 

account for the ARNI status. The wetland mitigation measures discussed in Section 4.3.1.6 

have been developed based on quantification of estimated losses and offsetting gains of 

wetland functions and values, including those provided by the presence of mangroves. 

Comment: Pipelines to transport reclaimed wastewater from the South Dade Water Treatment 

Plant to Turkey Point will be constructed in an area currently home to expansive wetlands using 

a corridor approximately nine miles long. [Footnote 30: NRC, DEIS, 3-20.]The DEIS must 

discuss how the construction and operation of these pipelines will impact wetlands, how FPL will 

properly avoid or mitigate impacts to wetlands, and whether reasonable alternatives exist to 

constructing pipelines in sensitive wetland areas. (0113-2-16 [Lopez, Jaclyn] [McLaughlin, Caroline] 

[Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: The DEIS on Pages 1-2 and 10-2 states that the "applicant proposes to discharge 

fill material into approximately 1,000 acres of jurisdictional wetlands to construct the proposed 

Appendix E October 2016 E-245 NUREG–2176
project." The correct number for the direct wetland impacts for the project is 710 acres. This 

corrected information was supplied to the Corps in FPL's May 7, 2010 letter to Paul Kruger 

modifying the federal dredge and fill permit application (FPLNNP-10-0151), as well as the July 

2011 Turkey Point Units 6 & 7 Mitigation Plan Rev.2 and August 2012 Mitigation Plan Rev. 2 

(USACE Supplement). As specified in the Table 1-1 of the Mitigation Plan Rev. 2 (USACE 

Supplement), the generating units and non-transmission facilities impact 402 wetland acres, 

while either of the transmission corridors is estimated to have no more than 308 acres of 

potential wetland impact thus totaling 710 acres of direct wetland impact. (0619-1-2 [Maher, 

William])

Response: The acreages of affected wetlands presented in the EIS have been updated to 

reflect the most recent information provided. Most notably, the wetland acreage noted in 

Section 4.3.1 as being permanently altered by development of the offsite transmission lines and 

pipelines has been substantially reduced to reflect more precise disturbance widths provided for 

the corridors by the applicant subsequent to publication of the draft EIS. Text in Chapters 1 and 

10 was also modified to reflect the revised acreage of wetland impact. 

Comment: On December 11, 2014, the U.S. Fish and Wildlife Service published a final rule 

classifying the rufa subspecies of the red knot as threatened. A new and significant information 

review was conducted by FPL where it was concluded that there would not be an impact to any 

significance level or conclusion drawn in the ER with respect to the change in status of the rufa 

subspecies of the red knot. With respect to this change of designation, there remain instances in 

the DEIS where it states that the red knot is proposed as a Federally threatened/ endangered 

species (emphasis added): a. DEIS Subsection 2.4.1.3, Page 2-89, Lines 3-4: The DEIS states: 

"Red Knot (Calidris canutus rufa). The red knot is proposed as a Federally threatened 

species (78 FR 60024) (TN3199)." b. DEIS Subsection 2.4.1.3, Page 2-80, Table 2-13: DEIS 

Table 2-13 lists the "Rufa red knot" as "PT" (Federally proposed threatened). c. DEIS 

Subsection 9.3.2.3, Page 9-60, Table 9-8: DEIS Table 9-8 lists the "Federal Status" for the "Red 

knot" as "Proposed Threatened". d. DEIS Subsection 9.3.3.3, Page 9-115, Table 9-13: DEIS 

Table 9-13 lists the "Federal Status" for the "Red knot" as "Proposed Threatened". e. DEIS 

Subsection 9.3.4.3, Page 9-165, Table 9-18: DEIS Table 9-18 lists the "Federal Status" for the 

"Red knot" as "Proposed Threatened". f. DEIS Subsection 9.3.5.3, Page 9-211, Table 9-23: 

DEIS Table 9-23 lists the "Federal Status" for the "Red knot" as "Proposed 

Endangered". There are, however, two instances in the DEIS that list the rufa red knot as 

threatened (emphasis added): a. DEIS Subsection 4.3.1.3, Page 4-55, Line 19: The DEIS 

states: "Red Knot (Calidris canutus rufa) - Threatened." b. DEIS Subsection 7.3.1.1, Page 7-20, 

Lines 10-13: The DEIS states: "Listed wildlife that could likely be affected by building proposed 

Units 6 and 7 facilities include the eastern indigo snake (threatened; Drymarchon corais 

couperi),...red knot (threatened; Calidris canutus),..." Additionally, in two instances of the DEIS, 

the red knot is characterized as "not known to occur on the Turkey Point Property (emphasis 

added): a. DEIS Subsection 2.4.1.3, Page 2-89, Lines 4-18: The DEIS states: "As of 2008, the 

rufa subspecies is thought to have three biogeographically distinct populations, one of which 

winters in the Southeast United States including Georgia, South Carolina, and Florida (FWS 

2013-TN3202)" red knots have not been observed and are not known to occur on the 

Turkey Point property or along the Atlantic Coast of Miami-Dade County."b. DEIS Subsection 

4.3.1.3, Page 4-55, Lines 21-23: The DEIS states: "... No record of red knots occurring on 

the Turkey Point site has been found. However, suitable habitat exists on the site that would 

be affected by the proposed action..." However, ER Table 2.4-1 lists the "Red knot" as being 

observed during the late winter 2009 avian surveys—one Red knot was observed. The DEIS 

supports FPL's conclusion that there would not be an impact to any significance level or 

conclusion drawn in the ER. Specifically, in DEIS Subsection 4.3.1.3, pages 4-55 (lines 30-31), 

Appendix E NUREG–2176 E-246 October 2016
and 4-65 (lines 18-19), and in DEIS Subsection 5.3.1.3, page 5-41 (lines 16-20), the NRC 

discusses its impact evaluation—in each instance the review team "expects that impacts would 

be minimal" in relation to the potential that the Red knot "could be expected to occasionally 

occur in small numbers at the Turkey Point site". (0619-1-9 [Maher, William])

Response: The comment identifies updated information about the status and occurrence of a 

listed species. Discussion of the rufa red knot in Sections 2.4.1.3, 4.3.1.3, and 5.3.1.3 has been 

updated based on information in this comment as well as updated information provided by the 

applicant regarding mitigation for impacts on habitat for migratory birds. 

Comment: There are instances in the DEIS where the impacts are characterized as affecting 

an entire transmission or pipeline corridor, when in reality, only a small percentage of the 

corridor will be impacted. Instances in the DEIS include (emphasis added): ...DEIS Subsection 

7.3.1.1, Page 7-19, Lines 31-33: The DEIS states: "An additional 2,203 ac of terrestrial habitats 

would be affected by the installation of potable and reclaimed water-supply systems..." FPL's 

response to NRC RAI Letter No. 1103093 (eRAI 5561), ML11192A042, dated July 7, 2011 

states: "The land disturbance for each type of vicinity and region linear feature -transmission, 

pipeline, road -represents a corridor in which each feature will be located. The actual land 

disturbance for each feature are expected to be less, based on the requirements of that 

feature... Additionally, the pipeline disturbances are considered temporary. That is, the land 

disturbance will be restored to its original land use upon completion of construction/installation 

activities." h. DEIS Appendix F-2, Subsection 3.1.2, Page 3-6, Lines 3-4 and DEIS Appendix F2, Subsection 3.1.2, Page 3-6, Lines 11-12: Appendix F-2 (lines 3-4) states: "Development of 

the East corridor would disturb approximately 1,635 ac of land." Appendix F-2 (lines 11-12) also 

states: "The route referred to as the "West Preferred corridor" occupies approximately 3,280 ac 

of land." This information does not take into account that the acreage listed is for a corridor, not 

the final right of way. The corridor will not be developed; the ROW within the corridor will be 

developed (ER Subsection 4.3.2.4). In addition in some locations the new facilities will be colocated with existing facilities (ER Subsection 2.2.2.2). ER Subsection 4.3.2.4 states: "The 

western and eastern transmission corridors represent the maximum extent of land presented for 

certification as part of the Site Certification Application (SCA) state process. The actual required 

right-of-ways will be determined post-certification, as will the location and amount of actual land 

requirements/disturbances necessary for transmission line construction. Therefore, the end-use 

land cover for these transmission corridors cannot be determined at this time." ER Subsection 

2.2.2.2 states: "The Clear Sky-Davis portion of the East Preferred Corridor would use an 

existing, 19-mile-long, multicircuit FPL transmission line right-of-way. This right-of-way has the 

ability to accommodate the proposed single-circuit 230 kV line without the need for additional 

right-of-way. However, for a portion of the Davis to Miami corridor, new rights-of-way would be 

required, but much of the proposed corridor includes existing transportation rights-of-way (e.g., 

U.S. Route 1, Metrorail)" and "In some portions of the proposed Davis-Miami transmission line 

section, it would be collocated with other transmission lines on the existing right-of-way." i. DEIS 

Appendix F-2, Subsection 3.1.4, Page 3-6/3-7, Lines 40/2: Appendix F-2 states, with regard to 

the potable pipeline corridor: "...for the purposes of this BA, it is assumed the entire corridor 

would be disturbed. More than 184 ac of wetlands would be disturbed." The DEIS is presenting 

all acreage within the corridor as impact area, when only a small percentage of the corridor 

would be affected. COLA Rev 6 section 4.1.2.4 states, "Because of the commonality of the 

(potable) pipeline route with previous disturbance and/or new disturbance already expected to 

occur resulting from construction of other Units 6 & 7 project facilities (e.g., roadway 

improvements), construction of the underground pipelines would have minimal additional 

environmental impacts." In addition, the language does not state that these are temporary 

impacts. ER Subsection 4.1.2.4 states: "As described in Section 4.3,...and, upon completion, 

Appendix E October 2016 E-247 NUREG–2176
the disturbed portions of the corridor would be graded to the contours of the 

surrounding landscape and revegetated or returned to previous land uses." j. DEIS 

Appendix F-2, Section 5.1, Page 5-1, Lines 5-8: Appendix F-2 states: "Development of lands 

within the Turkey Point site, including...would result in the removal of more than 1,300 trees, 

including almost 550 trees of various palm species (FPL 2011-TN1471)." Condition of 

Certification, Section B "Specific Conditions - Power Plant and Associated Facilities (Excluding 

Transmission Lines)", Subsection VII "Miami-Dade County", Item O. 13, page 89 states: "Prior 

to commencement of work within each segment of linear facilities (roads or pipelines), FPL shall 

revise the tree survey previously submitted in response to MDC completeness question 5-MDCD-11 (July 2011). The revised tree survey will show all upland trees proposed to be removed, as 

well as a tree planting plan to mitigate for the tree canopy to be removed as required by Section 

24-49 of Miami-Dade County Code." The tree survey was a baseline conducted to identify 

existing trees per MDC requirements. It does not indicate what trees would be removed.

(0619-1-20 [Maher, William])

Response: This comment provides updated information about the quantification of impacts to 

terrestrial ecology resources. Using information available to the review team prior to preparing 

the draft EIS, the draft EIS conservatively bounded its assessment of terrestrial habitat impacts 

from building the proposed transmission lines and pipelines by assuming that all habitat within 

the designated corridors would be permanently altered. The review team subsequently sought 

and received from the applicant more precise information about the projected footprint of 

disturbance within the corridors. In general, the applicant was able to narrow the width of 

projected facility disturbance footprints, thereby allowing the review team to present a more 

precise and less broadly conservative assessment. The review team independently reviewed 

the updated information and following its verification used the information to reduce the 

projected extent of terrestrial habitat impacts accordingly in Section 4.3 of the EIS. 

Comment: There are instances in the DEIS with respect to the presented land use values in 

their respective tables, which are inconsistent with the cited source or not current with the most 

recent documentation/reference. Instances in the DEIS include (emphasis added):...DEIS 

Subsection 2.4.1.2, Page 2-78, Table 2-12: DEIS Table 2-12 contains the land use coverage 

acreages for the pipeline corridors by classification. The following inconsistencies are noted with 

the source cited for DEIS Table 2-12, (FPL 2014-TN4058, Table 2.2-6) (areas where the data is 

inconsistent with the most current reference are also indicated): i. The "Potable Water Pipeline 

Corridor" acreages for the "Forest (ac)", "Open Water (ac)", "Wetlands (ac)", and "Infrastructure 

(ac)" classifications are consistent with an earlier revision of FPL's ER but are inconsistent with 

FPL's ER Revision 6. The acreages listed in DEIS Table 2-12 for the "Forest (ac)", "Open Water 

(ac)", "Wetlands (ac)", and "Infrastructure (ac)" classifications are 7.69, 24.75, 159.95, and 

39.21, respectively. In contrast, the summation of the acreages in ER Table 2.2-6, Revision 6, 

for the same major classifications are 7.65, 24.72, 158.95, and 39.19, respectively. ii. The 

"Reclaimed Water Pipeline Corridor" acreages for the "Uplands (ac)" and "Wetlands (ac)" 

classifications are inconsistent with ER Revision 6. The acreages listed in DEIS Table 2-12 for 

the "Uplands (ac)" and "Wetlands (ac)" classifications are 101.34 and 457.8, respectively. In 

contrast, the summation of the acreages in ER Table 2.2-6, Revision 6, for the same major 

classifications are 99.28 and 457.75, respectively. iii. For both the "Potable Water Pipeline 

Corridor" and "Reclaimed Water Pipeline Corridor" the acreage for the "Developed (ac)" 

classification is not consistent with ER Revision 6. The acreages listed in DEIS Table 2-12 for 

the "Developed (ac)" classification are 58.9 and 720.7 for the "Potable Water Pipeline Corridor" 

and "Reclaimed Water Pipeline Corridor", respectively. In contrast, the summation of the 

acreages in ER Table 2.2-6, Revision 6, for the "Developed (ac)" classification are 51.36 and 

19.67 for the "Potable Water Pipeline Corridor" and "Reclaimed Water Pipeline Corridor", 

Appendix E NUREG–2176 E-248 October 2016
respectively. iv. For both the "Potable Water Pipeline Corridor" and "Reclaimed Water Pipeline 

Corridor" the summation of the acreages do not equate to the values listed under the "Total 

Acres" in DEIS Table 2-12. Additionally, for the "Potable Water Pipeline Corridor", the value 

listed for the "Total Acres" is not consistent with ER Revision 6. (0619-2-2 [Maher, William])

Comment: Numerical value inconsistencies within the draft EIS: Subsection 2.4.1.1, Page 2-

74, Lines 28-31 "Terrestrial land cover on the Turkey Point site is presented in Table 2-2. Land 

on the Turkey Point site is used primarily for electric power facilities, and facilities for existing 

Turkey Point Units 1-5 occupy approximately 5,672 ac, composing almost half of the Turkey 

Point site" DEIS Table 2-2 ER Table 2.2-1 The referenced table, DEIS Table 2-2, indicates that 

land use characterized as electric power, FLUCFCS code 831, totals 5,682.84 ac. ER Table 

2.2-1 also indicates land use characterized as electric power, FLUCFCS code 831, as 5,682.84 

ac. (0619-2-31 [Maher, William])

Comment: Numerical value inconsistencies within the draft EIS: DEIS Subsection 4.3.1.3, 

Page 4-58, Lines 38-39 "Limpkin. More than 100 ac of mangrove habitat would be 

permanently lost, although only 28 ac of the affected areas are high-quality mangrove habitat." 

DEIS Table 4-7 DEIS Table 4-9 ER Table 4.3-1 DEIS Table 4-7 presents this acreage as 77.4 

ac, and DEIS Table 4-9 presents this acreage as 80.8 ac. ER Table 4.3-1 presents this acreage 

as 77.39 ac[.] (0619-2-35 [Maher, William])

Comment: There are instances in the DEIS with respect to the presented land use values in 

their respective tables, which are inconsistent with the cited source or not current with the most 

recent documentation/reference. Instances in the DEIS include (emphasis added):...DEIS 

Subsection 4.3.1.1, Page 4-43: DEIS Table 4-8, "Permanent Habitat Loss on the FPL Turkey 

Point Property Attributed to Building Units 6 and 7 Facilities", contains total acreage and 

wetland acreage values attributed to constructing Units 6 & 7. The following inconsistencies with 

the source (adapted) cited for DEIS Table 4-8, (FPL 2014-TN4058, Table 4.3-1 of Revision 6) 

are noted: i. The following acreage values do not reflect the values in ER Table 4.3-1, Revision 

6, but rather reflects those of ER Table 4.3-1, Revision 4, prior to the relocation of the FPL 

Reclaimed Wastewater-Treatment Facility: the acreages for the "FPL Reclaimed WaterTreatment Facility (alternate location)", "Spoils Area B", and "Spoils Area C". ii. The wetland 

acreage value for the "FPL Reclaimed Water-Treatment Facility (alternate location)" include 

FLUCFCS code 437 Australian Pine; however, footnote b for DEIS Table 4-8 indicates that "all 

500 and 600 series FLUCFCS codes and 743W are considered in this analysis to be wetlands". 

iii. Acreages are included for the "Treated Reclaimed Water Delivery Pipelines"; however, as 

noted in the table note for ER Table 4.3-1, Revision 6, "The treated reclaimed water supply 

pipeline is now fully within the heavy haul road disturbed area and is not separately considered". 

iv. the "Nuclear Administration Parking" should be titled "Nuclear Administration Building" as 

described in ER Table 4.3-1, Revision 6. v. DEIS Table 4-8 reports the total wetland acreage as 

328.12 ac. A summation of reconciled acreage values indicates that this number should be 

316.16 ac. Also note, there are locations in the DEIS text that will require reconciliation. For 

example, DEIS Subsection 7.3.1.1, page 7-19, Lines 28-31. (0619-2-6 [Maher, William])

Comment: DEIS Appendix F-2, Subsection 3.1.3, Page 3-6, Lines 35-37: USFWS BA states, 

"Although the exact location of the pipeline has not been determined within the corridor, burying 

the reclaimed water pipeline is expected to temporarily disturb approximately 327 ac of the 

1,876 ac corridor." The area of temporary disturbance associated with installation of the 

reclaimed water pipeline is approximately 75 feet wide by 9 miles long (see comment 89, 

above), equaling approximately 82 acres. ER Subsection 4.1.2.4 states: "The current land use 

of the 1886 acres within this corridor, some smaller portion of which could be impacted with the 

Appendix E October 2016 E-249 NUREG–2176
construction of the pipelines and right-of-way." DEIS Subsection 4.3.1.2, page 4-45, line 15 

states: "Approximately 1,886 ac of upland, forested, and wetland habitats as well as previously

developed or disturbed lands would be affected by installation of the reclaimed water pipeline 

(Table 4-3)." (emphasis added) (0619-6-10 [Maher, William])

Response: The review team has reviewed all acreage figure information and updated acreage 

figures as appropriate in the Sections 2.4, 4.3, and 5.3 of the EIS. The updated acreage figures 

did not substantially alter the conclusions presented in the EIS. 

Comment: The NPS continues to be concerned that the construction of new powerlines, roads, 

and other infrastructure relating to the licensing of Turkey Point Units 6 and 7 would impact a 

great many federally threatened and endangered species. (0622-2-1 [Austin, Stan])

Response: The review team has met with representatives of the FWS on multiple occasions to 

discuss possible impacts on Federally listed species, including but not limited to, the American 

crocodile, Florida panther, wood stork, Everglade snail kite, manatee, and various species 

endemic to South Florida. The review team prepared a BA (Biological Assessment) evaluating 

each Federally listed species and included it in Appendix F of the draft EIS. The BA included 

the review team's professional opinion regarding the severity of possible effects on each 

Federally listed species as of its preparation in 2015. The team continued to work closely with 

the applicant and FWS to obtain and review updated information about possible effects on these 

species and the applicant's proposed mitigation. The proposed mitigation was developed by the 

applicant. Following continued coordination with the FWS, the review team prepared an 

updated table presenting updated effects conclusions about each listed species, including 

species newly listed or proposed for listing subsequent to publication of the draft EIS and initial 

BA (e.g., Miami tiger beetle). The review team provided that table to the FWS in August 

2016. The final EIS discusses the review team's continued coordination with the FWS since the 

initial BA and updates the status of the review team's formal consultation efforts with FWS under 

ESA Section 7. 

Comment: The wood stork was originally listed as endangered, primarily due to loss, 

fragmentation, and degradation of the wetland habitats on which they depend. Since listing, the 

wood stork population has shown signs of improvement, and the range has been expanding 

northward. In June 2014, the U.S. Fish and Wildlife Service downlisted the wood stork from 

endangered to threatened in recognition of the expansion of the stork's population. Range-wide, 

the stork population reached the recovery criterion for downlisting of a 3-year running average 

of more than 6,000 nesting pairs. However, wood stork nesting falls well below the recovery 

criterion of more than 10,000 nesting pairs. In addition, the 5-year average stork nesting in the 

Everglades and Big Cypress Systems remains below the 2,500 nesting pairs that is another 

benchmark for delisting, as nesting in south Florida remains variable. While there have been 

improvements in wood stork nesting in the Everglades region, the majority of increases in wood 

stork nesting have occurred further north, outside of the species' historic range in the 

southeastern U.S. In the Everglades, nesting success tends to be irregular, with occasional 

"big" nesting years interspersed with several poor years, and in the big years, the success of the 

South Florida colonies is significant. In 2001, the Tamiami West colony supported approximately 

25 percent of all wood stork nesting in the U.S. [Footnote 2: NPS. 2011. Everglades National 

Park Colonial Wading Bird Nesting Monitoring Data. 2011. South Florida Natural Resources 

Center at Everglades National Park. Footnote 3: U.S. Fish and Wildlife Service. 2012. 

Endangered and Threatened Wildlife and Plants; Reclassification of the Continental U.S. 

Breeding Population of the Wood Stork From Endangered to Threatened. Federal Register 

77(247): 75947-75966.] As a result, increases in risk, particularly to adult storks, may 

Appendix E NUREG–2176 E-250 October 2016
substantially reduce the productivity and nesting that currently occurs. Because of the 

reproductive strategy of wood storks, in which adults do not fledge young in every year, losses 

of breeding adults may have population-level consequences. Thus, we encourage the NRC to 

reconsider language in DEIS section 5.3.1 relating to the impact of FPL's proposed powerlines 

on wood storks and the role of FWS. While Section 7 consultation addresses projects that have 

the potential to "jeopardize" the existence of a species, this project could change the trajectory 

of the stork population and still not rise to a level of jeopardy. In the DEIS for the Acquisition of 

FPL Land in the East Everglades Expansion Area, the NPS concluded that impacts could be 

major for some species such as the threatened wood stork. This conclusion was reached due to 

the close proximity of the proposed powerlines to Everglades NP. For instance, the proposed 

powerlines pass within five miles of several wading bird colonies (species highly susceptible to 

collision) in an area where there are no existing powerlines. The proposed route travels within 

one mile of one of the largest and most consistent wading bird colonies in South Florida, which 

can support around ten thousand pairs of wading birds of several species. Taking into account 

site-specific detail, "minimal" may not adequately describe impacts to avian resources. The NPS 

maintains that since wetlands are recognized as areas where birds congregate - the large 

amount of wetlands in the corridor (and proximity to the Everglades) makes risk much higher 

than "normal." Some species, such as wood stork, may be more susceptible to collisions, 

especially with guy wires, leading to potentially high mortality and population-level changes.

(0622-1-20 [Austin, Stan])

Response: Sections 4.3.1.3 and 5.3.1.3 include discussions of potential impacts of building 

and operating the project on the wood stork. These discussions are in addition to and 

consistent with the review team’s evaluation of impacts on the wood stork in the BA developed 

for formal consultation under ESA Section 7. The wetland mitigation discussed in Section 

4.3.1.6 of the EIS specifically accounts for impacts on wetlands in designated “core foraging 

areas” for the wood stork and calls for establishing offsetting wood stork habitat in areas used 

for the proposed wetland mitigation. The indicated EIS sections have been updated to address 

the latest information available on wood stork impacts and associated mitigation proposed by 

the applicant. 

Comment: The NPS recommends that NRC provide additional information and data related to 

species and habitat use, especially for habitats that will be used for construction such as the 

mudflat. (0622-1-19 [Austin, Stan])

Response: Section 4.3.1.1 of the EIS discusses in detail the impacts on wetlands and other 

terrestrial habitats from building the proposed facilities in the 218 ac plant area that includes the 

mudflat, and the remainder of Section 4.3.1.1 and Section 4.3.1.2 address impacts from building 

project facilities on other onsite and offsite terrestrial habitat. Regarding the mudflat, Section 

4.3.1 has been updated where appropriate to discuss input from FWS about the loss of 

shorebird habitat provided by the mudflat and the establishment of compensatory shorebird 

habitat in the applicant’s proposed wetland mitigation. 

Comment: Additionally, the DEIS did not analyze the effects of the proposed action upon the 

federally listed Red Knot. (0622-1-18 [Austin, Stan])

Response: Section 4.3.1.3 of the EIS contains analyses of the effects of the proposed 

preconstruction and construction activities on the rufa subspecies of red knot onsite and 

offsite. Section 5.3.1.3 considered operational impacts on the red knot. Without specific fauna 

surveys, the EIS conservatively assumes that all wildlife known to occur in the region would 

occur within all reasonably suitable habitats. Because the red knot is known to use mud flat and 

Appendix E October 2016 E-251 NUREG–2176
mangrove habitats, the loss of mudflat and mangrove habitat was assumed to affect this 

species. However, the review team concluded habitat loss due to building the new facilities was 

not substantial and operations would have minimal impact on this species. No changes were 

made to the EIS specifically in response to this comment. 

Comment: DEIS Subsection 4.3.1.1, Page 4-42, Lines 11-16: The DEIS states "Loss of 

mangrove stands...This extent of permanent mangrove cover loss...is a noticeable impact. 

However, some of the lost mangrove cover is from remnant stands in tidal creeks that have 

been isolated from Biscayne Bay by cooling canals." ER Subsection 2.2.1.1.2, states: 

"Mangrove heads, remnants of the original tidal creeks, contain...The connection between 

these creeks and Biscayne Bay were severed during construction of the industrial 

wastewater facility." All of the mangrove areas proposed for permanent impact are isolated

from Biscayne Bay by cooling canals, roads, and other existing plant-related development. 

(emphasis added) (0619-4-3 [Maher, William])

Response: The review team agrees that certain mangrove forest areas that would be lost to 

build the new facilities are spatially separated from Biscayne Bay by berms or other surface 

features. However, the review team disagrees that these areas are fully separated 

hydrologically or ecologically from Biscayne Bay. Additionally, approximately 3.98 ac of 

mangrove swamp lies within the path of the RCW delivery pipelines. This mangrove acreage is 

not separated in any way from Biscayne Bay. Section 4.3 of the EIS has been edited to discuss 

the degree of separation between the affected mangrove cover and Biscayne Bay. The edits 

did not substantially alter the overall conclusions presented in the EIS regarding impacts on 

wetlands and other terrestrial ecosystems. 

Comment: DEIS Subsection 2.4.1.4, Page 2-108, Lines 36-40: The DEIS states: "The eastern 

indigo snake is a...threatened species (FWS 2012-TN117; FNAI 2014-TN3668)... None were 

observed during recent surveys of the transmission line corridors (FPL 2014-TN4058)." The 

cited reference in the DEIS text, (FPL 2014-TN4058), is FPL's ER Revision 6. ER Subsection 

2.4.1.2 states: "Indigo snakes have been observed...and at two locations in the Eastern 

Preferred transmission line corridor (in 2011)." (emphasis added) (0619-3-11 [Maher, William])

Response: Section 2.4.1 of the EIS was revised to indicate that the eastern indigo snake was 

observed at two locations in the proposed corridor for the eastern transmission line. This 

change did not substantially alter the conclusions regarding the eastern indigo snake in the EIS 

or BA. 

Comment: DEIS Subsection 2.4.1.1, Page 2-76, Lines 8-12: The DEIS states: "The raised fill 

areas contain maintained grasses as well as...and melaleuca (Melaleuca quinquinervia) (FPL 

2014-TN4058)." The cited reference in the DEIS text, (FPL 2014-TN4058), is FPL's ER Revision 

6. ER Section 2.4 includes a similar discussion of vegetation in these areas but does not include 

melaleuca (Melaleuca quinquinervia) (emphasis added) (0619-3-9 [Maher, William])

Response: Section 2.4 of the EIS has been revised to remove the mention of melaleuca in the 

subject area. This change did not substantially alter the conclusions presented in the EIS. 

Comment: DEIS Subsection 2.4.1.1, Page 2-76, Lines 3-6: DEIS Section 2.4.1.1 states: 

"Wetland spoil areas totaling about 9 ac occur adjacent to remnant canals...(FPL 2014-

TN4058)." The cited reference in the DEIS text, (FPL 2014-TN4058) is FPL's ER Revision 6. ER 

Section 2.4 states: "Wetland habitats within the Units 6 & 7 plant area and adjacent laydown 

area include...and wetland spoil areas (10 acres). (emphasis added) (0619-3-8 [Maher, William])

Appendix E NUREG–2176 E-252 October 2016
Response: Table 4.3-1 of the Turkey Point Units 6 & 7 COL Application Part 3 – Environmental 

Report Revision 6 indicates 9.05 ac of wetland spoils (FLUCFCS [Florida Land Use, Cover, and 

Forms Classification System] class 743-WET) are present within the Turkey Point Units 6 and 7 

plant area. No changes were made to the EIS as a result of this comment. 

Comment: DEIS Subsection 2.4.1.1, Page 2-74, Line 35-38: The DEIS states: "Most of the 

plant area comprises mudflats that are inundated annually for 3 to 4 months and are sparsely 

vegetated with saltwort (Batis maritime)...(FPL 2014-TN4058)." The cited reference in the DEIS 

text, (FPL 2014-TN4058), is FPL's ER Revision 6. The timeframe, 3 to 4 months, is consistent 

with an earlier revision of FPL's ER but does not reflect the timeframe given in FPL's ER 

Revision 6. ER, Revision 6, Section 2.4 states: "...the sparsely vegetated mudflats are typically 

inundated by water 7 to 8 months out of the year and a few hardy plant species that can 

tolerate these conditions persist, including saltwort (Batis maritima)..." (emphasis added)

(0619-3-7 [Maher, William])

Response: The commenter provides incorrect information. Page 2.2-4 in Section 2.4 of 

Revision 6 of the Turkey Point Units 6 and 7 COL Application Part 3 – Environmental Report 

actually states "...the sparsely vegetated mudflats are typically inundated by water 3 to 4 

months out of the year and a few hardy plant species that can tolerate these conditions persist, 

including saltwort...". (emphasis added) No changes were made to the EIS as a result of this 

comment. 

Comment: There are instances in the DEIS with respect to the presented land use values in 

their respective tables, which are inconsistent with the cited source or not current with the most 

recent documentation/reference. Instances in the DEIS include (emphasis added):...DEIS 

Subsection 4.3.1, Page 4-44, Table 4-9: DEIS Table 4-9 contains acreage values for the Turkey 

Point Site by wetland FLUCFCS code. The following inconsistencies with the source (adapted) 

cited for DEIS Table 4-9, (FPL 2014-TN4058, Table 4.3-1 of Revision 6) are noted: i. The 

acreage listed under code 612-B is 40.4 ac. The summation provided in ER Table 4.3-1 for 

code 612-B is 36.98 ac. ii. The acreage listed under code 510 is 12.9 ac. The summation 

provided in ER Table 4.3-1 for code 510 is 12.45 ac. Additionally, in DEIS Table 4-7, the 

acreage listed under code 510 is 12.5 ac. iii. DEIS Table 4-9 lists FLUCFCS code 617 "Mixed 

Wetland Hardwoods" with a permanent impact acreage value of 0.4. However, ER Table 4.3-1, 

does not list FLUCFCS code 617 or a corresponding acreage. iv. There are no numerical 

FLUCFCS codes listed for the corresponding FLUCFCS code descriptions: "Sawgrass Marsh", 

"Australian Pine", "Exotic Wetland Hardwoods", "Exotic Wetland Hardwoods-Australian Pine", 

and "Disturbed Land". v. The acreage in this table is characterized as permanent acreage but 

the table includes areas of temporary wetland impact. (0619-2-7 [Maher, William])

Response: The review team has reviewed and updated as appropriate the acreage data 

provided in the EIS. The updated acreage data did not substantially alter the conclusions 

presented in the EIS. 

Comment: The construction footprint for the Unit 6 and 7 reactors and associated 

infrastructure (i.e., cooling towers, make-up water reservoir, ancillary buildings etc.) is currently 

comprised largely of occasionally flooded mudflats that provide important habitat for shorebirds 

and wading birds. These trust resources are protected under the Migratory Bird Treaty Act 

(MBTA), 16 U.S.C. 703. According to the DEIS, the project will result in the loss of 182.05 acres 

of mud flats (listed as non-vegetated in Table 4-1) that provide habitat for shore birds and 

wading birds. To minimize the impacts of the project to migratory birds, the Department has 

requested that FPL compensate for the loss of mud flats (migratory bird habitat) that will be lost 

Appendix E October 2016 E-253 NUREG–2176
from project construction. In past discussions with the Department, FPL has indicated that they 

may be able to create and maintain the same acreage of mud flat habitat in perpetuity on FPLowned lands north of the project site. These lands are currently being leased for agricultural 

purposes. We request that FPL provide the Department with a detailed plan on how they intend 

to minimize and compensate for the loss of the migratory bird habitat. We further request that 

the NRC and U.S. Army Corps of Engineers include this plan, once approved by the 

Department, as a condition of any permit or authorization to offset the loss of habitat for 

shorebirds and wading birds. (0227-8 [Stanley, Joyce])

Response: The State of Florida COCs issued on 5/19/14 state that FPL must mitigate for loss 

of shorebird habitat in consultation with the FFWCC (Florida Fish and Wildlife Conservation 

Commission). FPL is also required to restore or preserve 170 ac of mudflat habitat within the 

Everglades Mitigation Bank as part of their wetlands mitigation plan, of which 5 credits shall be 

applied to offset loss of shorebird habitat instead of wetlands. Additional mitigation may be 

negotiated with FPL by the FWS as part of the ESA consultation process. Section 4.3.1.6 of the 

EIS has been updated to describe this required mitigation. 

Comment: Included in the project application are three new sets of powerlines (two of them will 

be 15 stories tall) to be run across and through the eastern section of what is currently 

Everglades National Park. Expected impacts include: increased electrocutions and collisions for 

birds (three federally threatened wood stork colonies are known to roost in the vicinity of the 

proposed lines); the spread of invasive plant species along a new, drivable access corridor[.]

(0240-9 [Commenters, Multiple])

Response: Sections 5.3.1.2 and 5.3.1.3 of the EIS discuss avian mortality caused by the 

proposed new transmission lines, including electrocutions and collisions by wood storks, 

Everglade snail kites, and other large birds. FPL is required to install flight diverters on those 

wires identified by the FFWCC as being the most likely to cause avian collision mortality. FPL is 

also required to fund a mitigation effectiveness study that includes mortality monitoring and 

observations of flight behavior of any birds crossing transmission lines. Study results are to be 

provided to the FFWCC for discussion and evaluation, which could include additional mitigation 

or monitoring. Sections 4.3.1.3 and 5.3.1.2 of the EIS provide discussion of potential 

introduction of invasive plants both onsite and offsite as an environmental impact of the 

proposed actions. No changes were made to the EIS as a result of this comment. 

Comment: Constructing high tension power lines in the migratory pathways of birds is just one 

more unconscionable negative impact. (0245-3 [Lindsey, Jerrie])

Response: As stated in Section 4.3.1.3 of the EIS, migratory bird habitat would be altered and 

lost during installation of the proposed transmission lines. Section 5.3.1.3 of the EIS describes 

impacts of transmission operation on migratory birds, including collision and electrocution risk 

and measures required by the State of Florida to reduce and assess these risks. Additional 

mitigation may also be required by the FWS. No changes were made to the EIS as a result of 

this comment. 

Comment: A more immediate impact on wildlife that will result from construction of Units 6 and 

7 arises from the powerlines that will be built through Everglades National Park to transmit the 

power from the reactors. I have observed one of the wood stork colonies in Everglades National 

Park that is in close proximity to the location where the powerlines and their supporting towers 

will be installed-there are three federally threatened wood stork colonies known to roost in the 

vicinity. The powerlines will increase electrocutions and collisions for wood storks and other 

Appendix E NUREG–2176 E-254 October 2016
birds. It is well known that the wading bird population in the Everglades has already declined 

90% over several decades; this loss should not be compounded with powerline 

infrastructure. (0246-5 [Shlackman, Mara])

Response: Section 2.4.1.3 and 2.4.1.4 of the EIS discuss known wood stork colony locations, 

management zones, and core foraging areas near the proposed transmission corridors. The 

discussion of wading bird population trends in the Biological Indicators portion of Section 2.4.1.3 

of the EIS indicates that populations are significantly lower than historical levels, consistent with 

the comment. However, the subject EIS text also states that almost all wading bird species 

have recently increased in number and their populations are significantly greater than 10 

percent of historical levels, and the wood stork population is also recovering as evidenced by 

the June, 2014 reclassification from endangered to threatened. Nonetheless, collision and 

electrocution mortality of wood storks and other wading birds were identified as a potential 

impact of the proposed actions in Sections 4.3.1.3 and 5.3.1.3 of the EIS. Mitigation of these 

risks to wood storks and monitoring to assess mitigation effectiveness as required by the State 

of Florida COCs were also discussed in Section 5.3.1.3 of the EIS. Information about recent 

wood stork population trends was added to the EIS as a result of this comment. The added 

information did not alter the review team’s conclusions regarding impacts on the wood stork or 

on terrestrial ecology in general. 

Comment: Since other animals do not belong to humans at all, the least we can do is 

assiduously try to protect them as much as possible, after all the harm people have inflicted on 

them. (0285-2 [Miller, Melissa])

Response: Wildlife mitigation and protection measures are discussed in Sections 4.3.1.3 and 

5.3.1.3 of the EIS. No changes were made to the EIS as a result of this comment. 

Comment: The planned expansion of Turkey Point is environmentally dangerous and 

unacceptable at a time when we are aware of the hazards of intruding on sensitive habitats. 

(0307-1 [Rose, Aaron])

Response: A description of sensitive habitats potentially affected by the proposed action was 

included in Section 2.4.1.3 of the EIS. Impacts on those habitats caused by project 

encroachment are provided in Sections 4.3.1.1 and 5.3.1.1 of the EIS. No changes were made 

to the EIS as a result of this comment. 

Comment: I worked at the Turkey Point Plant some years ago and witnessed the changes 

made in the surrounding ecosystems. (0308-1 [Wallington, Victoria])

Response: Changes in the South Florida terrestrial ecosystem, including ecological impacts 

from past actions, are described in Section 7.3.1.1 of the EIS and changes in the aquatic 

ecosystem are described in Section 7.3.2.1. The assessments of cumulative terrestrial and 

aquatic ecological impacts in Chapter 7 of the EIS were considered in the context of this history 

of rapid and substantial change from past actions. No changes were made to the EIS as a 

result of this comment. 

Comment: We are having salt water intrusion into the everglades. Salt Water plants are 

growing there. If there, then everywhere. (0373-2 [Lee, Nancy])

Response: Intrusion of saltwater into surface water and wetlands was not an issue of concern 

identified during consultation with Federal, State, and local environmental agencies. Therefore, 

Appendix E October 2016 E-255 NUREG–2176
this issue was not considered by the review team. Potential ecological effects of sea-level rise 

caused by global climate change are discussed in Appendix I of the EIS. No changes were 

made to the EIS as a result of this comment. 

Comment: IN FOLLOWING THE NRC'S OWN GUIDELINES, THE EXPANSION OF TURKEY 

POINT COULD HAVE UNACCEPTABLE AND IRREVERSIBLE IMPACTS ON THESE

TREASURED SITES. (0449-2 [Benton-Janetta, Lori])

Response: Impacts on terrestrial resources, including the wetlands and wildlife habitat referred 

to in the comment as "treasured sites", are discussed in Sections 4.3.1.1 and 5.3.1.1 of the 

EIS. No changes were made to the EIS as a result of this comment. 

Comment: That fragile piece of land has already been pushed beyond its limits endangering 

and destroying rare wetlands and wildlife. (0598-2 [White, Barry J.])

Response: The fragile piece of land referred to by the commenter is assumed to be the Turkey 

Point Site. Past development of the Turkey Point site is discussed in Sections 2.2.1.6 and 

2.4.1.1 of the EIS. Ecological effects from past actions are discussed in Sections 7.3.1.1 of the 

EIS. Impacts from the proposed development of Units 6 and 7 to terrestrial resources, including 

wetlands and wildlife habitat, are described in Sections 4.3.1.1 and 5.3.1.1 of the EIS. No 

changes were made to the EIS as a result of this comment. 

Comment: Section 2.2.2.3, Makeup and Potable Water Systems (pg. 2-20): Table 2-6 lists 

447.80 acres of wetlands within the reclaimed water pipeline corridor, and 159.95 acres within 

the potable water pipeline corridor. It also states (pg.4-9) that FPL proposes to grade the 

disturbed portions of the corridor to the contours of the surrounding landscape and re-vegetate 

or return these areas to previous land uses. The EPA appreciates the effort to minimize wetland 

impacts by this action. The EPA is still unclear on the total extent and type of permanent 

impacts which will occur due to this activity. Please clarify. (0617-1-6 [Mueller, Heinz J.])

Response: The EPA's appreciation of the applicant's effort to minimize wetland impacts is 

noted. In response to various comments on the EIS by the applicant (FPL), the review team 

has provided more precise details regarding the anticipated extent and permanence of impact 

from pipeline installation on the overlying terrestrial and wetland habitats in Section 4.3 of the 

EIS. This updated information has not changed the conclusions drawn in the EIS concerning 

potential impacts on wetlands and terrestrial habitats. 

Comment: Section 3.2.3.4, Support and Laydown Areas (pg. 3-20): The EPA requests that the 

FEIS provide additional avoidance and minimization efforts by restoring wetlands associated 

with support and laydown areas after construction is completed. Section 4.1.l .2, Pipelines (pg. 

4-9) Table 4-3: Outlines major land use acreages for the pipelines but is not clear on the specific 

acres of wetlands to be impacted. Please provide more detail about wetland impacts for this 

activity, to be consistent with the format illustrated in Table 4-1 of the DEIS for the Turkey Point 

site. Section 4.1.1.3, Access Roadways (pg. 4-9) Table 4-4: Outlines major land use acreages 

for access road improvement but is not clear on the specific acres of wetlands to be impacted. 

Please provide more detail about wetland impacts for this activity, to be consistent with the 

format illustrated in Table 4-1 of the DEIS for the Turkey Point site. (0617-1-9 [Mueller, Heinz J.])

Response: In response to these comments and to various other comments received from the 

applicant (FPL), the review team has provided more precise details in the text and tables 

regarding the anticipated extent of impacts on terrestrial and wetland habitats from various 

Appendix E NUREG–2176 E-256 October 2016
project elements. Table 4-8 of the EIS states that 32.17 ac of wetlands lie within the Western 

Laydown Areas. FPL has stated that laydown areas would become permanent above-grade 

facilities and would not be restored as wetlands. This information was added to Section 4.3.1 of 

the EIS. The review team has also expanded the discussion in Section 4.3.1.6 of FPL's 

proposed Wetland Mitigation Plan, which does not include laydown areas within the Turkey 

Point site because these areas would be permanently filled. This updated information has not 

changed the conclusions drawn in the EIS concerning potential impacts on wetlands and 

terrestrial habitats. 

Comment: Section 4.1.2, Transmission-Line Corridors and Associated Areas (pg. 4-15) Tables 

4-5 and 4-6: Outlines major land use acreages for transmission-line corridors and associated 

areas, but is not clear on the specific acres of wetlands to be impacted. Please provide more 

detail regarding wetland impacts for this activity, to be consistent with the format illustrated in 

Table 4-1 of the DEIS for the Turkey Point site. (0617-1-10 [Mueller, Heinz J.])

Response: In response to this comment and to various other comments received from the 

applicant (FPL), the review team has provided more precise details regarding the anticipated 

extent of impacts on terrestrial and wetland habitats from each proposed offsite transmission 

line. Tables 4-5 and 4-6 have been updated accordingly. However, specific acreages for 

various land cover classifications are not available for proposed offsite corridors because the 

siting of transmission infrastructure has not been finalized. Although all lands within the 

corridors would not be developed, the review team conservatively concluded that all land area 

within proposed corridors could be developed and based conclusions on this approach. This 

updated information has not changed the conclusions drawn in the EIS concerning potential 

impacts on wetlands and terrestrial habitats. Wetland acreage figures within proposed 

transmission corridors are summarized in Table 4-10 of the EIS. The review team believes the 

format of the various tables of terrestrial habitat impact are sufficiently consistent and therefore 

has not altered the format of any of the subject tables. 

Comment: The EPA requests that the FEIS address additional measures that can be taken to 

avoid and minimize onsite tidal and freshwater wetland impacts. As stated previously, the Public 

Notice published by the USACE stated that the project proposes impacts to 1000 acres of tidal 

and freshwater wetlands, and FPL stated in their response to USACE that the correct number 

for the direct wetland impacts for the project is 710 acres, with temporary impacts to 50 acres. 

Project impacts will include impacts to ARNI. The FEIS should clarify the acreage that would be 

impacted. (0617-1-29 [Mueller, Heinz J.])

Response: In response to this comment and to comments from the applicant (FPL), the review 

team has provided more precise details in Section 4.3.1 of the EIS regarding the anticipated 

extent of impacts on terrestrial and wetland habitats from various project elements. Sections 

2.4.1.1 and 4.3.1.1 of the EIS also now provide information about which of the affected wetlands 

are Aquatic Resources of National Importance (ARNI). This updated information, while 

providing a clearer picture of the total extent of anticipated impacts, has not changed the 

conclusions drawn in the EIS concerning potential impacts on wetlands and terrestrial habitats. 

Comment: There are instances in the DEIS where the impacts are characterized as affecting 

an entire transmission or pipeline corridor, when in reality, only a small percentage of the 

corridor will be impacted. Instances in the DEIS include (emphasis added): a. DEIS Subsection 

2.4.1.2, Page 2-79, Lines 10-13: The DEIS states: "Access near the L-31 Canal would occur 

over or through dikes, levees, and canals as well as 5 ac of wetlands. An access road near 

NW 88th Street would occupy...." Acreages presented in the ER, along with the corresponding 

Appendix E October 2016 E-257 NUREG–2176
documents, are on a corridor basis; the actual area disturbed will be less than the total within 

the corridor. b. DEIS Subsection 4.3.1.2, Page 4-45, Lines 3-4: The DEIS states: "Land cover 

that would be affected by installation of the pipeline totals approximately 326 ac (Table 4-3)..." 

All acreage within potable water pipeline corridor is identified as "affected area", when actually 

only a small percentage of the corridor will be used to install the pipeline. c. DEIS Subsection 

4.3.1.2, Page 4-45, Lines 15-17: The DEIS states: "Approximately 1,886 ac of upland, forested, 

and wetland habitats... would be affected by installation of the reclaimed water pipeline (Table 

4-3)." Only a small percentage of total will actually be temporarily impacted during pipeline 

installation. d. DEIS Subsection 4.3.1.2, Page 4-50, Lines 7-16: The DEIS states: "Combined, 

the two new access roads for the West Preferred corridor would affect 365 ac (Table 4-6). The 

Krome Avenue access road would result in habitat loss or alteration...The four access roads 

necessary for the West Consensus corridor would affect a combined 110 ac...A variety 

of wetlands would be lost..." Corridors are wider than necessary to allow for impact avoidance 

during final roadway alignment design. Only a small percentage of habitats within the corridor 

would be affected. e. DEIS Subsection 4.3.1.3, Page 4-68, Lines 21-23: The DEIS states: "The 

proposed reclaimed water pipeline would affect almost 450 ac of wetlands, including..." The 

DEIS is presenting all acreage within a corridor (from DEIS Table 4-3) as impact area, when 

only a small percentage of the corridor would be affected. For comparison, from DEIS reference 

(FPL2011-TN1012)—Turkey Point Units 6 & 7 Mitigation Plan, the total acreage of temporary 

wetland impact associated with reclaimed water pipeline is 43.6 ac. f. DEIS Subsection 4.3.1.7, 

Page 4-72, Lines 29-31: The DEIS states: "Pipelines that would be built...would affect an 

additional area of approximately 2,211 ac..." Corridors are wider than necessary to allow for 

impact avoidance during final design. Only a small percentage of habitats within the corridor 

would be affected. (0619-1-19 [Maher, William])

Response: The review team understands corridors were designated to be wider than what 

would be necessary to contain a linear feature (road, pipeline, transmission line) for planning 

purposes. Lacking more precise design data, the review team had originally conservatively 

assumed that all acreage contained within a corridor could be affected by the proposed 

action. Use of newer more precise data allows the review team to present a less conservative, 

more realistic evaluation in the final EIS. The review team has verified the information 

contained in the comment and expanded Section 4.3.1 of the EIS accordingly. This updated 

information has not changed the conclusions drawn in the EIS concerning potential impacts on 

wetlands and terrestrial habitats. 

Comment: There are instances in the DEIS with respect to the presented land use values in 

their respective tables, which are inconsistent with the cited source or not current with the most 

recent documentation/reference. Instances in the DEIS include (emphasis added):...DEIS 

Subsection 4.3.1.1, Page 4-40, Table 4-7: DEIS Table 4-7 contains acreage values for the 

Turkey Point Site by cover types and FLUCFCS code. The following inconsistencies with the 

source cited for DEIS Table 4-7, (FPL 2014-TN4058) are noted: i. DEIS Table 4-7 lists 

FLUCFCS code 617 "Mixed Wetland Hardwoods" with a permanent impact acreage of 1.2. 

However, ER Table 4.3-1 does not list FLUCFCS code 617 or a corresponding acreage and 

percent total but rather list FLUCFCS code 619 "Exotic Hardwoods" with a corresponding 

disturbed acreage of 0.61. ii. DEIS Table 4-7 characterizes all of the disturbed acreage as 

"permanent". (0619-2-5 [Maher, William])

Response: The review team used the most current design data available to them. The review 

team has revised EIS Sections 4.1 and 4.3.1 so that the analyses in the final EIS account for 

design information received subsequent to publication of the draft EIS. The review team has 

independently verified the information contained in the comment and expanded the EIS 

Appendix E NUREG–2176 E-258 October 2016
accordingly. This updated information has not changed the conclusions drawn in the EIS 

concerning potential impacts on wetlands and terrestrial habitats. 

Comment: DEIS Subsection 4.3.1.1, Page 4-43/4-44, Lines 21/5: The DEIS states: "FPL has 

accounted for secondary impacts on wetlands at all proposed wetland fill locations associated 

with temporary road improvement for construction access as well as other non-linear facilities by 

calculating the acreage of a 25 ft buffer of those proposed fill locations. Secondary impacts on 

wetlands would also be mitigated per State of Florida regulations (State of Florida 2014-

TN3637), but FPL has proposed to do so at a reduced level equal to 60 percent of direct 

impacts (FPL 2011-TN1012)." There is no specific FDEP guidance on mitigation for secondary 

impacts, which are potential impacts to wetlands adjacent to where the facilities will be located 

(direct impacts). FPL has proposed a very conservative mitigation approach by providing 60 

percent of the mitigation required had the wetlands impacts been direct impacts. This is 

consistent with the mitigation approach approved by FDEP for previous FPL projects. (emphasis 

added) (0619-4-4 [Maher, William])

Response: The statement "Secondary impacts on wetlands would also be mitigated per State 

of Florida regulations (State of Florida 2014-TN3637)" has been removed from the 

EIS. Removal of this statement does not alter the overall assessment of wetland impacts in the 

EIS. 

Comment: DEIS Subsection 4.3.1.1, Page 4-44, Lines 21-23: The DEIS states: "Spoils would 

be deposited mostly on previously filled areas but would also fill in additional canal acreage 

classed as streams and waterways." ER Section 2.4 states: "Spoils from the Units 6 & 7 plant 

area, FPL reclaimed water treatment facility, and other construction locations would be 

deposited on three areas (total approximately 211 acres) within the industrial wastewater facility. 

Two of these areas would be located on wide berms on either side of Grand Canal, the primary 

north-south canal in the center of the facility. The third would be along a strip of land below the 

southern end of the industrial wastewater facility. All three areas have been used historically 

for spoil deposition and contain scattered patches of early succession vegetation (grasses, 

low shrubs, etc.)." (emphasis added) (0619-4-5 [Maher, William])

Response: Table 4.3-1 in FPL's ER entitled Turkey Point Property Disturbed Area FLUCFCS 

Summary states that Spoils Area A contains 1.06 ac of land classified as FLUCFCS Level 3 

code 510 – Streams and Waterways/Canals, Spoils Area B has less than 0.01 ac of FLUCFCS 

Level 3 code 510 – Streams and Waterways/Canals, and Spoils Area C has 4.39 ac of 

FLUCFCS Level 3 code 510 Streams and Waterways/Canals. ER Section 4.3.1.1 states the 

three spoils areas would lie along designated sections of banks within the IWF. Therefore, the 

review team concluded that approximately 5.45 ac of streams and waterways along banks of 

the IWF would be filled during spoil deposition. No changes were made to the EIS as a result of 

this comment. 

Comment: DEIS Subsection 4.3.1.2, Page 4-49, Lines 14-15: The DEIS states: "Adjacent 

wetlands would also be affected by siltation and runoff." FPL has committed to utilizing BMPs 

to prevent erosion/sedimentation impacts. (emphasis added) (0619-4-6 [Maher, William])

Response: FPL’s ER Revision 6 (on pg 4.2-2) states that BMPs would be employed "to 

minimize" discharge of pollutants during storm events during construction as part of an NPDES 

(National Pollutant Discharge Elimination System) permit. The ER also states that the NPDES 

permit (and its protections) is subject to a Notice of Termination following construction and 

stabilization of disturbed areas. The review team therefore concluded that minimization of 

Appendix E October 2016 E-259 NUREG–2176
runoff as part of an NPDES permit does not equate to complete prevention of erosion or 

sedimentation along transmission line access roads for the life of the project. No changes were 

made to the EIS as a result of this comment. 

Comment: DEIS Subsection 4.3.1.6, Page 4-70, Lines 17-21: The DEIS states: "FPL proposes 

to remove or control exotic vegetation...FPL also proposes to maintain and monitor vegetation

for 3 years after mitigation activities..." The DEIS reference, (FPL 2011-TN1012), "Turkey 

Point Units 6 & 7 Mitigation Plan", states: "Success criteria, to be negotiated in consultation with 

the FDEP, USACE, and DERM, will likely...include 5% or less cover by exotic species...for a 

period of at least 3 years following initiation of mitigation activities." (emphasis added)

(0619-4-7 [Maher, William])

Response: Section 4.3.1.6 of the EIS has been expanded to provide more detail on proposed 

mitigation for terrestrial ecology impacts, including clarifying mitigation success criteria. 

Comment: DEIS Subsection 4.3.1.6, Page 4-71, Table 4-11: DEIS Table 4-11 contains the 

following inconsistencies with DEIS reference, (FPL 2011-TN1012), "Turkey Point Units 6 & 7 

Mitigation Plan": a. In the "W.A.T.E.R. Debits" category, the "Reclaimed Water-Treatment 

Facility (W.A.T.E.R.)" site should list the currently proposed values rather than the originally 

proposed. The current proposed values are as follows: "Impact (ac)" = 39.5, and "Wetland 

Functional Change (Mitigation Units)" = -33 b. The "West Preferred Transmission Line" site 

should be included under "UMAM Debits", not "W.A.T.E.R. Debits". c. In the "UMAM Debits" 

category, the "Reclaimed Water Pipeline (UMAM)" site is referencing values associated with the 

Treated Reclaimed Water Pipeline from the originally-proposed location. The revised values for 

the "Reclaimed Water Pipeline (UMAM)" are as follows: "Impact (ac)" = 43.6 ac, and "Wetland 

Functional Change (Mitigation Units)" = -4.8 Mitigation Units. d. In the "UMAM Debits" category, 

the "Construction Access Road (UMAM)" "Impact (ac)" should be 81.6 ac., not 45.0 ac. e. After 

reconciliation, the "Subtotals" should be revised as follows: "W.A.T.E.R. Debits"; "Impact (ac)" = 

315.86, "Wetland Functional Change (Mitigation Units)" = 201.35; "UMAM Debits"; "Impact (ac)" 

= 433.4, "Wetland Functional Change (Mitigation Units)" = 326.24; and "UMAM Credits"; 

"Wetland Functional Change (Mitigation Units)" = 333.5. f. After reconciliation, the "Net 

difference in Wetland Function (Credits)" = 7.21. g. The "Overall Net Mitigation Ratio (credit 

basis)" should be presented on an acreage basis rather than credit basis. h. Temporary wetland 

impacts (pipelines) should be separated from permanent wetland impacts. (0619-4-8 [Maher, 

William])

Response: This comment provides edits to update design information used in the wetland 

mitigation discussion in Section 4.3.1.6 of the EIS. The review team has independently verified 

the supplied information and updated Section 4.3.1.6 where appropriate. The updated 

information about that facility's proposed location has not changed the conclusions drawn in the 

EIS concerning potential impacts on wetlands and terrestrial habitats. 

Comment: DEIS Subsection 5.3.1.1, Page 5-36, Lines 38-39: The DEIS states: "The extent of 

the effects of road improvement on wildlife is contingent upon the decision to restore roads 

to the preexisting condition and traffic levels." FPL has committed to remove construction 

access roads within 2 years following construction of Units 6 & 7 as documented in the 

Conditions of Certification issued by the State of Florida Department of Environmental 

Protection, Section B, Subsection VII-B-2-a and condition number 4 of the "Standard 

Amendments to the Comprehensive Development Master Plan for Miami-Dade County" issued 

by the Board of County Commissioners on April 28, 2010, which states "Within 2 years following 

the construction of Turkey Point Units 6 & 7 (a) all temporary roadway improvements on publicly 

Appendix E NUREG–2176 E-260 October 2016
owned rights-of-way will be returned to the status of the roadway(s) prior to the commencement 

of construction of the temporary roadways and roadway improvements, and, (b) any privately 

owned roadway will be returned to the minimum roadway width required to provide maintenance 

to FPL facilities and shall not be more than two lanes;" (emphasis added) (0619-4-17 [Maher, 

William])

Response: This comment contains suggested edits provided by the applicant to update text in 

Section 5.3.1 of the EIS regarding their commitment to remove access roads once they are no 

longer needed. The review team used the most current design data available to them, including 

the data for the access roads. The review team has revised the EIS so that the analyses in the 

final EIS account for design information received subsequent to publication of the draft 

EIS. The review team has independently verified the information contained in the comment and 

expanded the EIS accordingly. This updated information has not changed the conclusions 

drawn in the EIS concerning potential impacts on wetlands and terrestrial habitats. 

Comment: DEIS Subsection 5.3.1.4, Page 5-50, Lines 17-20: The DEIS states: "FPL would 

monitor for the possible loss of wood stork foraging habitat within the designated wood stork 

core foraging areas in accordance with a methodology approved by the FWS (FPL 2011-

TN1283)." No monitoring of wood stork foraging habitat is proposed in the cited reference (FPL 

2011-TN1283), but the possible loss will be quantified and mitigated in accordance with 

USFWS guidelines. (emphasis added) (0619-4-18 [Maher, William])

Response: The statement about monitoring for lost wood stork foraging habitat was removed 

from the EIS. The review team did however add more information to Sections 4.3 and 5.3 of the 

EIS discussing mitigation of impacts on the wood stork. 

Comment: DEIS Appendix F-2, Section 2.2, Page 2-7, Lines 6-9: USFWS BA states: "Field 

reconnaissance surveys for threatened or endangered wildlife within existing and proposed new 

transmission-line corridors as well as a proposed reclaimed water pipeline corridor consisted of 

a single vehicular driving survey during 2008 along the corridors (FPL 2011-TN94)." ER 

Table 2.4-1 lists results of wildlife surveys and observations along the proposed transmission 

corridors from 1972 to 2011. (emphasis added) (0619-6-4 [Maher, William])

Response: This comment consists of the applicant's suggested text edits to the BA. The 

indicated edits are too minor to influence the accuracy of the BA. The edits will not be made to 

the BA, because they are minor edits that would not affect the accuracy of the information 

provided in the BA and would have no material effect on the findings FWS must make. 

Comment: DEIS Appendix F-2, Subsection 3.1.3, Pages 3-6, Line 30: USFWS BA states, "The 

reclaimed water pipeline corridor would be 75 ft wide by 9 mi long." DEIS reference 

(FPL2012-TN1618), "Turkey Point Units 6 & 7 Federal Biological Assessment for Six Listed 

Species", Section 2.3 states, "Pipeline installation will require temporary disturbance of an 

approximately 75-ft-wide right-of-way within of the pipeline corridor to facilitate trench 

excavation. Areas of temporary impact will be restored following pipeline construction." (0619-6-9

[Maher, William])

Response: This comment provides edits reflecting the design of pipeline elements under the 

project. Data on acreages of terrestrial habitat affected by pipeline installation have been 

updated throughout the EIS, except in distributed correspondence to FWS in Appendix F2. Additionally, the review team has added information about in situ restoration activities 

planned for the reclaimed-water pipeline to Section 4.3 of the EIS to describe why some impacts 

Appendix E October 2016 E-261 NUREG–2176
from this pipeline can be considered temporary. However, the review team expects forested 

wetlands (i.e., mangroves) to be converted to herbaceous wetlands and remain so for the 

operational life of the pipelines because standard practice dictates exclusion of woody 

vegetation from pipeline corridors due to root intrusion and subsequent maintenance 

issues. Although no net loss of wetlands would occur within the reclaimed-water pipeline 

corridors, the conversion of forested wetlands to herbaceous wetlands within the corridors must 

be regarded as a permanent impact (at least for the operational life of the pipelines). The 

updated data do not alter any conclusions presented in the EIS. 

Comment: Page 5-51, Section 5.3.1.6, Summary of Impacts to Terrestrial Resources 

Lines 2-5: The DEIS states, "Salinity within the IWF or other area wetlands would not change 

enough to alter prey populations consumed by wading birds. Deposition of emerging pollutants 

... would also be below levels expected to affect the terrestrial ecosystem." There is insufficient 

information provided in the DEIS to be able to make such a conclusion. While salinity may not 

have an effect on prey populations consumed by wading birds such as the Wood Stork, 

reclaimed water put back into the IWF, as well as the addition from the drift, may have an effect. 

Some of these contaminants are endocrine disruptors, which cause effects such as immune 

suppression and developmental and reproductive effects at very low concentrations. The DEIS 

should include additional discussion about contaminants in the reclaimed water that not only 

exceed toxicological benchmarks and EPA water quality criteria, but also those that 

bioaccumulate. These contaminants have the potential to not only impact the wood stork and 

crocodile, but other species foraging in the project area as well. (0622-1-6 [Austin, Stan])

Response: The commenter is concerned about the potential for adverse effects on terrestrial 

and aquatic resources from the presence of CECs (chemicals of emerging concern) that may be 

present in the cooling-tower drift. Sections 5.2.1 and 5.3.2 of the EIS provide an assessment of 

the region of potential effect for CECs, and Section 5.3.1 provides an overview pertaining to the 

terrestrial ecosystem. Section 5.3.2 of the EIS has an extensive discussion of the EPA criteria 

used to assess the potential toxicity or adverse effects of CECs on aquatic species known to be 

sensitive to chemical compounds and at critical life stages. Because it is not possible to assess 

every potential chemical or chemical byproduct that may be present in the reclaimed-water 

source, the representative and most abundant chemical compounds were provided for different 

functional chemical classes, including endocrine disrupting compounds. The use of no 

observed effects concentrations (NOECs) for assessing toxicity thresholds is a widely used 

criterion in aquatic toxicology, and represents the highest concentration threshold acceptable in 

these toxicity tests for the correlated exposures. Section 5.3.1 of the EIS has been expanded to 

include discussion of recent environmental conditions within the IWF and actions taken and 

proposed to address these conditions that would also affect the transport of CECs from coolingtower drift through the food chain to terrestrial organisms. 

Comment: Page 5-136, Table 5-23 (under the Terrestrial Ecosystems) states, "Herbicide use 

would be in accordance with manufacturer specifications and carried out by licensed 

applicators." Additionally under the Aquatic Ecosystems heading, the DEIS states "... 

procedures would include adherence to strict guidelines established by Federal, State, and local 

resource agencies regarding the use of herbicides." However, the document does not identify 

which herbicides would be used, when would they be used, how often would they be used, how 

they would be applied, if more than one herbicide would be used at a time or in conjunction with 

other chemicals, or whether any of the herbicides proposed for use have aquatic labels and will 

be applied over water, including any wetland. Revisions to the DEIS should address these 

Appendix E NUREG–2176 E-262 October 2016
questions and discuss known potential interactive effects of these chemicals. (0622-1-8 [Austin, 

Stan])

Response: Sections 5.3.1 and 5.3.2 of the EIS address possible ecological impacts resulting 

from herbicide use. Because herbicide use would adhere to manufacturer specifications and 

Federal/State/local guidelines, for appropriate use, the review team concludes that the risk to 

terrestrial and aquatic ecosystems would be minimized to the extent practicable. As long as the 

herbicides are used in accordance with their labels and Federal and State regulations, the 

impacts of herbicide use on terrestrial ecology would be minimal. No changes were made to the 

EIS as a result of this comment. 

Comment: The DEIS provides only limited information related to potential impacts of 

construction of Units 6 and 7, associated power lines, and other related infrastructure on avian 

populations and other fauna. (0622-1-17 [Austin, Stan])

Response: Possible impacts on birds and other wildlife from all elements of the Units 6 and 7 

project, including building and operating transmission lines, have been analyzed in detail and 

included in Sections 4.3.1 and 5.3.1 of the EIS. No change was made to the EIS as a result of 

this comment. 

Comment: The NPS recommends that the EIS also consider impacts on the piping plover and 

red knot. Both species would be expected to use the project site and vicinity for migratory 

habitat. (0622-1-22 [Austin, Stan])

Response: Potential impacts on the piping plover and rufa red knot have been considered and 

are individually discussed in Sections 4.3.1.3 and 5.3.1.3 of the EIS. Mitigation measures 

addressing shorebirds such as the rufa red knot are provided in Section 4.3.1.6. Cumulative 

impacts on wildlife habitats, including those used by the piping plover and rufa red knot, are 

discussed in Section 7.3.1.1. No change was made to the EIS as a result of this comment. 

Comment: Although birds from a wide range of taxa and feeding guilds are exposed to these 

direct risks, wading birds (such as herons, egrets, storks, and cranes) are of particular concern 

because they make up such a large and important component of the birds found in Everglades 

region of South Florida. Wading birds are behaviorally predisposed to collision due to their large 

size, which makes it difficult for them to take evasive action when confronted with flight 

obstacles. Collision with powerlines was identified as the most significant source of wood stork 

mortality in an evaluation of causes of death. [Footnote 4: Forrester, D.J. and Spalding, M.G. 

2003. Ibises, Spoonbills, Flamingos, and Storks: Trauma. Pp. 227-228 In: Parasites and 

diseases of wild birds in Florida. Univ. Press of Florida, Gainesville. 1132 pp.] During nesting 

season when foraging conditions are good east of Everglades NP, the thousands of pairs of 

these nesting wading birds will fly past the powerlines, often two or more times daily, for periods 

of weeks to months. Use of flight diverters and line markers may reduce, but not eliminate, 

collision mortality for wading birds. The resulting expectation is that considering the elevated 

collision risk of wood storks and wading birds, the fact that thousands of these species are 

nesting within the normal foraging distances of these wading birds, the presence of powerlines 

will cause a sustained level of mortality for these species for the life of the powerlines. This 

sustained mortality may be punctuated by more significant mortality events when weather 

conditions or other factors cause increased risk of collision. Over time, this mortality may result 

in measurable population declines. (0622-1-23 [Austin, Stan])

Appendix E October 2016 E-263 NUREG–2176
Response: The review team has identified wading birds as a biological indicator of the South 

Florida ecosystem in Section 2.4.1.3 of the EIS, and many wading bird species are noted in 

Table 2-15, State-Listed Wildlife in the Turkey Point Vicinity. Impacts on wading birds, including 

the wood stork, are discussed in Section 4.3.1.3. Avian Mortality Impacts from Power 

Transmission is a subheading within Section 5.3.1.3 that contains a discussion of strike and 

electrocution mortality of wood storks and other wading birds. Mitigation measures addressing 

wood storks are discussed in Sections 4.3.1.6 and 5.3.1.5. Cumulative impacts on wildlife 

habitats, including those used by the wood stork and wading birds, are discussed in Section 

7.3.1.1. The State of Florida COCs require pre- and post-construction ground surveys of all 

wading bird colonies that occur within a half mile of any new transmission line. No change was 

made to the EIS as a result of this comment. 

Comment: In the NPS DEIS regarding land exchange and the subsequent construction of 

powerlines within the west preferred corridor, the impacts of powerlines on wildlife and wood 

storks was determined to be moderate to major. (0622-1-24 [Austin, Stan])

Response: Consistent with the referenced NPS conclusion regarding impacts to wood storks 

from transmission lines in this area, the EIS acknowledges the potential for adverse impacts on 

wood storks and other wildlife from transmission lines built in the Western Preferred and 

Western Consensus transmission corridors. However, the review team also acknowledges that 

differences are possible among subjectively determined impact levels such as those used in its 

EIS and the referenced NPS EIS. No change was made to the EIS as a result of this comment. 

Comment: The NPS is also concerned that bird surveys conducted at the mud flats where 

Units 6 and 7 would be built are inadequate. Avian surveys referenced in the DEIS were 

conducted over a two-day span during June 2009. The use of this limited period of time for 

avian surveys is wholly inadequate to analyze annual or migratory use and the potential for 

avian impacts due to the plant construction or operations. This limited review did not include 

spring migration, fall migration, or wintering use birds. June is traditionally the least likely month 

to observe the diversity of birds in south Florida, and a mere two days could have been heavily 

impacted by weather and light conditions. Spring, fall, and winter surveys should be performed, 

not just on the proposed site for Units 6 and 7 itself, but also in the pipeline corridors, the 

transmission line corridors, the road areas, the fill source location, as well as other impacted 

sites. In an analysis of the potential for avian impacts, the more broadly available data for 

migration and winter or summer habitat use is available from the NPS, Tropical Audubon 

Society, or university researchers and should be consulted. (0622-1-25 [Austin, Stan])

Response: The review team acknowledges that comprehensive bird surveys were not 

conducted in all seasons at all proposed project locations. However, the baseline data 

underlying the wildlife impact analyses and subsequent conclusions within the EIS did not 

depend solely on the results of faunal surveys specifically conducted on the project 

site. Potentially affected fauna lists were generated using information from Federal, State, and 

local agencies, published literature, and online sources in addition to the limited onsite field 

survey data. To be conservative, the review team assumed that any bird or wildlife species 

potentially occurring in South Florida was present in all potentially suitable habitats. The 

discussion of baseline wildlife conditions on the Turkey Point site in Section 2.4.1.1 of the EIS 

was expanded to provide increased specificity and to more clearly identify the data sources 

used. 

Comment: The Florida panther utilizes habitat in the project area, illustrated by sightings, 

mortality, and behavior of radio-collared animals. Although there may be no confirmed 

Appendix E NUREG–2176 E-264 October 2016
observations on FPL land, the panthers have been seen on nearby lands and FPL lands can 

reasonably be considered natural and active range for panthers. Lack of sightings does not 

necessarily indicate a lack of use of habitat. Increased road traffic and construction activity can 

reasonably be considered to affect current use of the area by this highly endangered species. 

Furthermore, access can increase threats to the endangered cats from poachers. For instance, 

a 5-year-old male panther was shot to death and found discovered alongside Immokalee Road 

in the Naples area on March 22, 2015. Lastly, new research relating to how wildlife see and are 

impacted by ultra-violet flashes emitted from powerlines should be analyzed as it is pertinent to 

the discussion on the Florida panther, as well as other wildlife and avian species. (0622-2-2

[Austin, Stan])

Response: Florida panthers were observed near the Turkey Point site within the west 

transmission corridors (SFWMD 2013-TN2917), and the review team assumes that Florida 

panthers are present throughout the region. Impacts on the Florida panther are addressed in 

Sections 4.3.1.3, 5.3.1.3, and 7.3.1.1 of the EIS. These discussions have been expanded to 

consider in greater detail how increased human access could affect the movement and behavior 

of Florida panthers in the region. The expanded discussions include consideration of the 

possible effects from ultraviolet flash. They do not alter the review team’s general conclusions 

regarding impacts on the Florida panther. 

Comment: The NPS continues to be concerned with potential impacts to the Eastern indigo 

snake. Increased traffic during construction and operation of Units 6 and 7 would almost 

certainly impact Eastern indigo snake vehicle-related mortality near and on the site. 

Furthermore, power block construction and muck disposal, which could bury snakes, could 

affect eastern indigo snake populations as well. Short hydration periods for wetlands on site 

could also play an important role. Out of concern that increased traffic would lead to more 

vehicle-related wildlife mortality, the NPS has previously recommended to the State of Florida 

that herpetological surveys be conducted along the public roads leading to the site for at least a 

year prior to and during construction activities. These surveys would inform the placement of 

snake and reptile underpasses, as appropriate. (0622-2-4 [Austin, Stan])

Response: Impacts on the eastern indigo snake are discussed in Sections 4.3.1.3 and 5.3.1.3 

of the EIS. Increased vehicle strike mortality is identified as a potential impact. The discussion 

addressing the potential for live burial during earth-moving activities has been expanded. FPL 

is required by the State of Florida to conduct pre-clearing surveys for listed species, including 

the eastern indigo snake in accordance with the State of Florida COCs issued by the Siting 

Board on 5/19/14. The expanded discussion includes information about this requirement and 

how the data ultimately collected could be used to reduce impacts. The expanded discussion 

does not alter the review team’s general conclusions regarding impacts on the eastern indigo 

snake. 

Comment: Pre-treatment building - associated with the reclaimed and potable water 

pipelines[.] Location of the reclaimed water treatment facility is on 43 acres of wetlands. The 

DEIS states that there would be 328.12 acres of wetlands (not verified by the USACE as 

jurisdictional wetlands) that would be filled to prepare the site. A proposed restoration project 

would be to scrape down the Florida City Canal. Eradicating invasive species and restoring 

mangrove would benefit the ecological value of the area. (0622-2-15 [Austin, Stan])

Response: FPL's wetlands mitigation plan included in the State of Florida COCs issued on 

5/19/14 would mitigate for all functional loss of wetlands through regional wetland restoration, 

enhancement, and preservation combined with purchase of credits from regional mitigation 

Appendix E October 2016 E-265 NUREG–2176
banks. The discussion of the Wetland Mitigation Plan in Section 4.3.1.6 of the EIS has been 

expanded to better explain how the proposed mitigation would offset the unavoidable losses 

and degradation of specific wetland habitats, including the coastal mangrove forests. Although 

the review team considers the possible benefits of the applicant’s proposed wetland mitigation 

in its assessment of terrestrial and wetland impacts in the EIS, the details of the plan are 

developed by the applicant and approved by the Federal and State agencies that have 

regulatory oversight. 

Comment: The NPS asserts that the DEIS impact analysis associated with construction and 

operation of proposed Units 6 and 7 does not sufficiently address issues related to the 

environmental impacts of the proposed action on resources managed by the NPS. Based on our 

review of the DEIS, we have strong concerns that impact analysis described in the DEIS does 

not:...describe the importance of the fragile and threatened nature of Biscayne and Everglades 

NPs, Biscayne Bay, and the broader Everglades ecosystem in the context of ongoing federal 

and state efforts to restore the Everglades; and, as a result[.] (0623-9 [Austin, Stan])

Comment: Included in the project application are three new sets of power lines, some 15 

stories tall, that will cut across the Everglades National Park. Expected impacts include: 

increased electrocutions and collisions for birds; the spread of invasive plant species along a 

new, drivable access corridor; changes to the hydrology of the Shark River Slough due to tower 

pads and road construction; and a new, unsightly, industrial landscape, visible for miles, in the 

heart of the Everglades, one of Floridas most profitable and popular wilderness areas. (0674-6

[Dwyer, Karen])

Comment: I believe it will bring some benefits but we also have to make sure that we have the 

-- have a greater discussion about how it will impact the national parks because it's right there 

on the bay and it's right there near the Everglades. (0723-8-4 [McDuffie, Stephen])

Response: The review team has added an expanded discussion to Sections 4.3.1 and 5.3.1 of 

the potential effects of the project on the terrestrial and wetland resources of the South Florida 

ecosystem as they pertain to both Biscayne and Everglades National Parks and the experience 

of visiting these parks. This expanded discussion integrates the direct and indirect effects on 

specific resources in the parks and addresses how those effects could influence the resource 

management objectives for each park and the broader Everglades ecosystem, including the 

objectives of the CERP. The assessment of potential cumulative impacts on the unique 

terrestrial and wetland resources of both parks and the Everglades ecosystem has likewise 

been expanded. The expanded discussion does not alter the NRC staff’s general conclusions 

regarding impacts on terrestrial ecology resources. 

Comment: We have to start to look more completely at possible long term consequences 

involving the expansion of Power plants. There are so many creatures and plants that call this 

area home. (0689-1 [Miller, Nena])

Response: Cumulative impacts on terrestrial plants and animals, discussed in Section 7.3.1 of 

the draft EIS, are considered for the proposed life of the project and include the actions that 

would occur in the reasonably foreseeable future. No changes were made to the EIS as a result 

of this comment. 

Comment: You've got the spread of invasive plant species into the area[.] (0721-22-4 [Schwartz, 

Matthew])

Appendix E NUREG–2176 E-266 October 2016
Comment: It's going to spread invasive plant species throughout the east Everglades 

expansion area. (0723-9-10 [Schwartz, Matthew])

Comment: Invasive plant species throughout the access road, the pads, changes in the 

hydrology. (0723-9-12 [Schwartz, Matthew])

Response: The possible inadvertent introduction of terrestrial plant and animal invasive 

species is discussed under the Disease Vector and Pest Species heading of Sections 2.4.1.2 

and 2.4.1.3 of the EIS. Non-indigenous fish are discussed in Section 2.4.2.3 and listed in Table 

2.26. The impacts of additional inadvertent introduction of non-native species by the proposed 

actions are included in appropriate sections of Chapters 4, 5, and 7. 

Comment: The National Parks Service did an avian and bird study. Lots of impacts, lots of 

collisions, lots of electrocutions. Three colonies have now threatened Wood Storks in the area. 

They're going to be impacted. We need to look at those. (0721-22-7 [Schwartz, Matthew])

Comment: Electrocutions, National Park Service already evaluated it. Electrocutions and 

collisions with birds. Three colonies of threatened wood storks in the area. (0723-9-13 [Schwartz, 

Matthew])

Response: Collision and electrocution mortality as well as other impacts on wading birds, 

including the wood stork, are discussed in Sections 4.3.1.3 and 5.3.1.3 of the EIS, and 

associated mitigation measures are discussed in Sections 4.3.1.6 and 5.3.1.5. No changes 

were made to the EIS as a result of this comment. 

Comment: And what will happen then to the wildlife that remains? They can't leave. (0721-32-9

[Schlackman, Mara])

Response: Impacts on wildlife are discussed in Sections 4.3.1.1 and 5.3.1.1. The assessment 

of possible impacts on wildlife considers the relative mobility of various species. 

Comment: I also have read your impact, your ecological impact that clearly says, when 

required, permanent disturbance to approximately 573 acres of habitat. It would affect wetlands, 

it would create mud. It will create a lot of killing of lifestyle, of life, of wildlife in our areas. You 

clearly say some habitat will be permanently lost, some wildlife will be killed and other wildlife 

will be temporarily displaced. And you consider this small to moderate? 

We talked about the butterflies, we talk about the bobcats, we talk about the marsh rabbits. We 

talk about the tarpin, we talk about the porpoises. We're talking about -- I'm looking at my notes 

because I really haven't prepared anything. We're talking about the voice of the water, the voice 

of the environment, the voice of the wildlife. (0722-17-1 [Swenson, Cyndee])

Response: The terrestrial and aquatic ecology sections of Chapters 4 and 5 of the EIS 

(Sections 4.3.1 and 5.3.1 for terrestrial and Sections 4.3.2 and 5.3.2 for aquatic) acknowledge 

that impacts from the proposed units on terrestrial ecological resources, including wetlands, 

would be MODERATE. MODERATE impact is defined by the NRC as being sufficient to 

noticeably alter, but not destabilize important attributes of the resource. The EIS provides 

specific details about the acreage of specific terrestrial habitats affected by the project and an 

in-depth evaluation of the adverse effects on wildlife using those habitats and adjoining 

areas. The review team used a conservative approach when analyzing impacts, leaning on the 

side of caution when considering terrestrial resources and wetlands resources. 

Appendix E October 2016 E-267 NUREG–2176
Comment: ...the significance of these rare and disappearing birds and animals. (0723-11-3

[Berendsohn, Catherine])

Response: Impacts on birds and other terrestrial wildlife are discussed in Sections 4.3.1.1 and 

5.3.1.1. Impacts on specific rare species that are Federally or State-listed as threatened or 

endangered are presented individually in Sections 4.3.1.3 and 5.3.1.3. 

Comment: The FEIS should include a wetland jurisdictional determination, so that a complete 

review of wetland impacts can be determined. During the wetland jurisdictional determination 

review, the EPA is willing to participate with that review, prior to publishing in the FEIS. Also, the 

FEIS should include Uniform Mitigation Assessment Method scores (Parts 1 and 2), for the 

proposed impact and mitigation sites. Technical rationale for each score should also be 

included. 

Overall, the FEIS should include updated information regarding the CWA Section 404 permitting 

process, and include information responsive to the concerns stated in EPA's letters to the 

USACE, as well as the specific concerns listed here. Impacts should be avoided to the 

maximum extent feasible, and unavoidable impacts should be effectively mitigated. (0617-1-30

[Mueller, Heinz J.])

Comment: Sequential Mitigation of Impacts to Essential Fish Habitat[.] Under the Clean 

Water Act, its implementing regulations, and EPA guidelines, wetland impact avoidance and 

minimization are the first two steps in sequential mitigation, and the third step is compensatory 

mitigation for unavoidable impacts. The public notice does not describe any measures to avoid 

or minimize impacts to mangroves or seagrass from the project. Based on the drawings 

provided with the notice, it appears 100 percent of the wetlands on the site are proposed for 

impact. The public notice states the applicant submitted a mitigation plan that includes debiting 

of mitigation credits from the FPL Everglades Mitigation Bank, purchasing of mitigation credits 

from the Hole-in-the-Donut in-lieu-fee program, and constructing permittee-responsible 

mitigation. The public notice, draft EIS, and EFH assessment neither describe the permitteeresponsible mitigation, how well the credits from these mitigation banks match the impacts, nor 

the number of credits required. In letters to the USACE dated April 9, 2015, and May 4, 2015, 

the EPA provides additional detail on concerns about how the sequential mitigation process has 

been implemented for this project. (0724-15 [Fay, Virginia M.])

Comment: Wetland Fill[.] In order to construct Units 6 and 7 and related infrastructure, 

including pipelines and the RCWs, the NRC and FPL propose to fill approximately 1,000 acres 

of wetlands. The public notice does not identify the impacts to mangroves from this work; 

however, the draft EIS indicates approximately 105 acres of mangroves would be filled, 

permanently or temporarily to facilitate construction (Table 2). The NRC expects about half of 

the mangrove impacts to be construction related and temporary. Project plans in the final EIS 

and EFH assessment should reflect all practicable avoidance and minimization of impacts to 

mangroves. In addition, a compensatory mitigation plan should be provided demonstrating, 

through a functional assessment comparing impact and mitigation areas, that sufficient 

mitigation is proposed. The mitigation plan should describe how mangrove temporary impact 

areas would be re-graded to appropriate elevations and monitored to ensure mangrove 

vegetation returns to the impacted sites at locally appropriate densities. Performance measures, 

monitoring criteria, schedule, and frequency should also be identified in the plan (see the 

Federal Compensatory Mitigation Rule dated April 2008). 

[Table 2 included in original correspondence] 

Appendix E NUREG–2176 E-268 October 2016
Table 2: FPL proposed land disturbance on the Turkey Point site and Florida land use, cover, 

and forms classification system (FLUCFCS) summary for the different categories of mangrove 

impacts (modified from Table 4-1 in the draft EIS) (0724-4 [Fay, Virginia M.])

Response: Section 4.3.1.6 of the EIS discusses FPL’s proposed Wetland Mitigation Plan that 

was adopted within the State of Florida COCs. Regarding the wetland jurisdictional 

determination, FPL would have to obtain a jurisdictional determination from the USACE prior to 

receiving its Section 404 permit authorizing impacts on wetlands and other waters of the United 

States. The mitigation discussion addresses opportunities for avoidance or minimization of 

wetland impacts, and it outlines concepts for compensatory mitigation. Table 4-10 of the EIS 

summarizes wetland functional loss debits and mitigation credits, using the Uniform Mitigation

Assessment Method. As required by the USACE Mitigation Rule dated April 2008, the Wetland 

Mitigation Plan is based on estimating the functional credits that must be provided in the 

compensatory wetland mitigation needed to offset the losses of functional values in wetlands

affected by the project. The review team has updated the text of Section 4.3.1.6 to reflect new 

information about wetland mitigation available since the draft EIS. The review team has also 

updated Table 4-10 to reflect the latest mitigation information available from the applicant and 

interactions between the applicant and the USACE and FWS subsequent to the draft EIS. The 

expanded text in Section 4.3.1.6 provides more information about specific elements of the 

applicant’s proposed wetland mitigation and how each element of that mitigation addresses 

wetland impacts from individual parts of the Units 6 and 7 project. 

Comment: DEIS Subsection 7.3.1.1, Page 7-19, Lines 10-12: The DEIS states: "The West 

Preferred Corridor within the eastern boundary of Everglades National Park could be 

counterproductive to future CERP goals..." ER Subsection 2.2.2.2 states that the West 

Preferred Corridor (preferred option) "runs along" the eastern boundary of Everglades 

National Park, while the West Secondary Corridor (secondary option) runs through the Park. 

Further, ER Figure 2.2-5 shows both routes in relation to the Park boundary. Therefore, the 

West Preferred Corridor/preferred option does not present a barrier to surficial flow to eastern 

Everglades National Park as it is associated with the eastern boundary of the Park. (emphasis 

added) (0619-5-9 [Maher, William])

Response: The location of the West Preferred transmission corridor was corrected in Section 

7.3.1.1 of the EIS, and its potential effects on the CERP was also edited accordingly. These 

changes did not alter the conclusions presented in the EIS.

Comment: DEIS Appendix F-2, Section 2.1, Page 2-4, Lines 3-4: USFWS BA states: "Each 

unit would have a mechanical draft cooling tower for the circulating-water system..." ER 

Subsection 3.1.2 states: "For each unit, the closed-cycle circulating water system (CWS) would

consist of three mechanical draft cooling towers..." (emphasis added) (0619-6-1 [Maher, 

William])

Comment: DEIS Appendix F-2, Subsection 3.2.1, Page 3-8, Lines 5-6: USFWS BA states: 

"The circulating-water system flow and heat rejection rates compared to the service-water 

system would be about 44 times larger respectively." ER Table 3.4-1 lists the service water 

flow rate for normal operation as 10,500 gpm and the heat transferred as 103 x 106 Btu/hr. ER 

Subsection 3.4.1.1.1 lists the circulating water pumps flow rate at 660,100 gpm and the heat 

load as 7628 x 106 BTU/hr. Using these values, the circulating-water system flow and heat 

rejection rates compared to the service-water system are 62.9 and 74.1, respectively. (Note all 

the values listed are on a per unit basis.) (0619-6-11 [Maher, William])

Appendix E October 2016 E-269 NUREG–2176
Comment: DEIS Appendix F-2, Section 4.18, Page 4-15, Lines 27-29: USFWS BA states: 

"Pineland habitat a the Gold Coast Railroad Museum Park that borders the proposed East 

transmission-line corridor for approximately 700 m is also designated critical habitat for the 

Florida brickell-bush." The East Corridor does not border the Gold Coast Railroad Museum 

Park. The location of the Gulf Coast railroad Museum is adjacent to Zoo Miami on the north 

side. The address is 12450 SW 152nd St, Miami, FL 33177, http://www.gcrm.org/ (emphasis 

added) (0619-6-15 [Maher, William])

Comment: DEIS Appendix F-2, Section 5.2, Page 5-2, Lines 10-12: USFWS BA states: 

"Mitigation has also been proposed for 1,030 habitat units after applying the FWS mitigation 

ratio of 2.5:1 for panther habitat." The reference provided in the USFWS BA is (FPL 2011-

TN1283). However, Attachment D of this document "Estimated Impacts to Florida Panther 

Habitats (BDA, 2009)", Page 3 states: "The number of PHUs that the USFWS may require for 

mitigation for the direct and temporary losses of panther habitat due to improvements to roads 

accessing the Site was estimated. FPL will work with the USFWS, ACOE, and other 

appropriate agencies to determine mitigation recommendations for the loss of panther habitats 

after a final design for project features has been achieved consistent with the conditions of site 

certification." (0619-6-16 [Maher, William])

Comment: DEIS Appendix F-2, Section 5.7, Page 5-5: This section refers to FPL 2011-

TN1283 "FPL Turkey Point Units 6 & 7 Threatened and Endangered Species Evaluation and 

Management Plan, Rev 1" when describing several wood stork requirements imposed by 

FFWCC on FPL. The correct reference is (FPL2014-TN3637), "Final Order on Certification, In 

Re: Florida Power and Light Company Turkey Point Units 6 & 7 Power Plant Siting Application 

No. PA 03-45A3," which contains the FFWCC Conditions of Certification. The Threatened and 

Endangered Species Plan does not include Conditions of Certification. (0619-6-17 [Maher, 

William])

Comment: DEIS Appendix F-2, Section 5.7, Page 5-5, Lines 8-11: USFWS BA states: "Offsite 

activities would also affect storks, because the installation of a portion of the proposed 

transmission lines would occur within 1 mi of two active wood stork colonies and within 3 mi 

of two other colonies. The transmission lines would also bisect the 18.6 mi CFA of nine wood 

stork colonies." The language is correct for the West Preferred Corridor; however, it does not 

reflect the location of the West Consensus Corridor (MDLPA 2 Corridor) which is located 

outside the recommended management zones. DEIS reference, (FPL2013-TN2941), Section 

"Threatened and Endangered Species", page 9 states: "However, use of the MDLPA 2 Corridor 

reduces the probability of potential impacts to the federally endangered wood stork (Mycteria 

americana) and Everglade snail kite (Rostrhamus sociabilis plumbeus). The wood stork is 

known to nest in four colonies both south and north of Tamiami Trail and west of the West 

Preferred Corridor. These colonies have been well documented for years and are known as the 

Tamiami East 1 and 2, Tamiami West, and 3B Mud East colonies [South Florida Water 

Management District (SFWMD), 2013]. The MDLPA 2 Corridor is located east of all these 

known colonies, and the closest colony (Tamiami East 1) is 0.86 mile away. This distance 

falls outside the recommended primary (500-1500') and secondary (2500') management 

zones..." (emphasis added) (0619-6-18 [Maher, William])

Comment: DEIS Appendix F-2, Section 5.7, Page 5-5, Lines 14-16: USFWS BA states: "The 

FFWCC requires FPL to conduct flight surveys of the two known wood stork nesting colonies to 

determine the flight corridors of fledging wood storks before and after transmission-line 

installation (FPL 2011-TN1283)." The reference is incorrect in this section. FPL 2011-TN1283

references the "FPL Turkey Point Units 6 & 7 Threatened and Endangered Species Evaluation 

Appendix E NUREG–2176 E-270 October 2016
and Management Plan". The correct reference is the Conditions of Certification (State of 

Florida 2014-TN3637). (emphasis added) (0619-6-19 [Maher, William])

Comment: DEIS Appendix F-2, Section 2.2, Page 2-6, Lines 21-24: USFWS BA states: 

"Freshwater marsh is the predominant natural land cover on the site; it occupies almost 18 

percent of the entire property and almost 40 percent of the undeveloped land area. An 

additional 9 percent is mixed wetland hardwoods." The following language can be used for 

clarification: "An additional 9 percent of the undeveloped land is mixed wetland hardwoods." 

(emphasis added) (0619-6-3 [Maher, William])

Comment: DEIS Appendix F-2, Section 2.2, Page 2-7, Lines 12-13: USFWS BA states, "Avian 

surveys were also conducted at selected locations on the Turkey Point site over a 2-day span 

during June 2009." In addition to the survey conducted on June 23-24, 2009, another survey 

was conducted on March 24-25, 2009. The survey report is included in the DEIS reference 

(FPL2009-TN1334), however, it is not referred to in the USFWS BA. (emphasis added) (0619-6-5

[Maher, William])

Comment: DEIS Appendix F-2, Subsection 3.1.1, Page 3-3, Lines 5-10: USFWS BA states: 

"Land clearing, grubbing, grading, and placement of fill would occur on approximately 591 ac of 

the Turkey Point site (FPL 2014-TN4058). Excluding cover classes supporting existing 

development, approximately 577 ac of intact terrestrial habitat would be lost. Approximately 328 

ac of wetlands on the Turkey Point site would be permanently altered by filling and grading, 

clearing of vegetation, dewatering, erosion, sedimentation, and other alterations of the existing 

hydrology such as road construction and culvert installation." The cited source in the text is 

FPL's ER Revision 6. ER Table 4.3-1, Revision 6, includes revised acreage values that will 

result in different acreage values—this includes the removal of the treated reclaimed water 

supply line as this line is now fully within the heavy haul road disturbed area and is no longer 

separately considered. Additionally, the 577 ac value number includes the spoils area and, as 

described in ER Section 2.4, the spoils area is not "intact terrestrial habitat." ER Section 2.4 

states: "All three areas have been used historically for spoil deposition and contain 

scattered patches of early succession vegetation (grasses, low shrubs, etc.)." (emphasis added)

(0619-6-6 [Maher, William])

Comment: DEIS Appendix F-2, Subsection 3.1.1, Page 3-3, Lines 23-25: USFWS BA states: 

"Almost 40 percent of the affected land area has been filled during previous land-development 

activities. Another 30 percent of the affected land, including the entire Units 6 and 7 plant area, 

is classified as non-vegetated wetland (FPL 2014-TN4058)." ER Section 2.4: Total property 

acreage is approximately 9400 ac; cooling canals acreage = 5900 ac (open water = 4400 ac); 

and Units 1-5 = 340 ac. Total filled areas is [(5900 ac-4400 ac) + 340 ac] =1840 ac or 20%. 

(emphasis added) (0619-6-7 [Maher, William])

Comment: DEIS Appendix F-2, Section 5.7, Page 5-5, Lines 14 -25: USFWS BA states, "The 

FFWCC requires FPL to conduct flight surveys of the two known wood stork nesting colonies to 

determine the flight corridors of fledging wood storks before and after transmission-line 

installation (FPL 2011-TN1283)." Line 23 states: "FPL would also have to conduct post-building 

monitoring during the breeding season after transmission-line installation near wood stork 

colonies." FFWCC Conditions of Certification states: "The FFWCC requires FPL to conduct 

flight surveys of the two known wood stork nesting colonies to determine the flight corridors of 

fledging wood storks before transmission-line installation. For the West Preferred Corridor, 

FFWCC also requires FPL to conduct flight surveys of the two known wood stork nesting 

colonies after transmission-line installation." In addition, "FPL would also have to conduct postAppendix E October 2016 E-271 NUREG–2176
building monitoring during the breeding season after transmission-line installation within 0.5 mi 

of wood stork colonies. (FPL 2011-TN1283)." (emphasis added) (0619-7-1 [Maher, William])

Comment: DEIS Appendix F-2, Section 5.14, Page 5-13, Lines 23-25: USFWS BA states: 

"Almost 62 ac of land were classified as Brazilian pepper within the second leg of the preferred 

route of the West transmission-line corridor that would span between the Clear Sky and Levee 

substations." For consistency in this section, also include the Brazilian pepper acreage in the 

2nd leg of Clear Sky to levee for the West Consensus Corridor. From the Proposed Turkey 

Point, Units 6 & 7 "Supplemental Transmission Corridor Information for the Combined License 

Application Part 3 - Environmental Report", DEIS reference (FPL2013-TN2941), Section "Land 

Use", Table 2 "Major Land Use Acreages Along the Entire West Consensus Corridor", page 6 

shows: 44.82 acres (approximately 45 acres). (emphasis added) (0619-7-2 [Maher, William])

Comment: DEIS Appendix F-2, Section 6.1, Page 6-2, Lines 40-41: USFWS BA states: "Unit 5 

also uses freshwater mechanical draft cooling towers to dissipate heat." ER Rev. 6, Subsection 

2.3.1.2.2.4 "Hydrogeochemical Characteristics", page 2.3-35 states: "Although the Upper 

Floridan aquifer is a major source of potable groundwater in much of Florida, water withdrawn 

from the unit in southeastern Florida, including Miami-Dade County, is brackish and variable 

with chloride and dissolved solid concentrations greater than 1000 mg/L. Groundwater 

samples from the Upper Floridan aquifer production wells at Unit 5 (Table 2.3-22) show an 

average chloride concentration of 2900 mg/L." (emphasis added) (0619-7-5 [Maher, William])

Response: These comments offer specific suggested edits based on new information available 

since publication of the draft EIS. They are specifically directed to the BA submitted to the FWS 

as part of ESA Section 7 consultation between the NRC, the USACE, and the FWS. Since the 

draft EIS, the review team has held multiple discussions with the FWS, resulting in a table of 

updated analysis of project effects on Federally listed species. The review team has not, 

however, updated the text of the BA. The FWS did not request the review team to update the 

BA text beyond simply providing the updated table. EIS Sections 4.3.1 and 5.3.1 were revised 

to reflect the updated consultation status. 

Comment: DEIS Subsection 2.4.1.1, Page 2-77, Lines 6-14: The DEIS states: "During April 

2009, surveys were also conducted to determine...reptile presence and relative 

abundance...(FPL 2009-TN1444)...Reptiles were observed, including the American alligator 

(Alligator mississippiensis)..." The cited DEIS reference, (FPL 2009-TN1444), is the 

"Mammal Trapping and Herpetology Report Turkey Point Property Associated with Units 6 & 7, 

April 13-16, 2009". The referenced report does not indicate that the American alligator was 

observed during April 2009 surveys. Nor is this species listed in ER Table 2.4-2 which presents 

results of April 2009 (and earlier) surveys. (emphasis added) (0619-3-10 [Maher, William])

Response: The American alligator was removed from the list of reptiles noted as having been 

observed during the April, 2009 surveys in Section 2.4.1.1 of the EIS. 

Comment: Reclaimed water treatment facility. The project will require the construction of a 

facility to treat reclaimed water used in cooling of Units 6 and 7. The proposed site for the facility 

is located immediately north of the northern border of the cooling canal system and west of the 

test canal system. The proposed treatment facility will result in the loss of 42.82 acres of dwarf 

mangroves and 0.78 acres of mixed wetland hardwoods. Wetlands provide important habitat for 

fish and wildlife, aid in flood control, and perform a number of other vital ecosystem functions. 

Consequently, the location of the water treatment facility, as proposed, will result in a significant 

loss of valuable wetland resources. To minimize the loss of wetlands resulting from the project, 

Appendix E NUREG–2176 E-272 October 2016
we recommend that FPL relocate the reclaimed water treatment facility to a site with minimal or 

no impacts to wetlands or to a disturbed uplands closer to the Miami-Dade Water and Sewer 

Department's South District Wastewater Treatment Plant. We understand that FPL has stated 

security concerns as a reason to site this facility in its current location. However, the Department 

asserts that those concerns can be addressed with adequate fencing and other safeguards, and 

that these concerns do not warrant the destruction of wetlands within the current preferred site. 

We recommend that the NRC require the reclaimed water treatment facility to be moved from 

the currently proposed location. (0227-12 [Stanley, Joyce])

Response: This comment relates to how the site layout and design for Units 6 and 7 

developed by FPL would result in impacts on terrestrial ecology. The site layout and design 

proposed by FPL is discussed in Chapter 3 of the EIS. It is outside of the review team's 

regulatory authority to require FPL to change the planned layout of the site. The impact on 

terrestrial ecology resulting from construction of the proposed units is described in Section 

4.3.1. No changes were made to the EIS in response to this comment. 

Comment: Transmission lines. Moreover, active nesting colonies of the wood stork are 

located near both the Preferred Corridor and the Consensus Corridor. Locating new 

transmission lines near these colonies will increase the potential for injuries and deaths of wood 

storks from collisions with power lines and transmission towers. The Department has had 

discussions with FPL about moving this segment of the west corridor eastward in order to abut 

existing development to the greatest extent practicable. FPL may be amenable to this approach. 

We recommend that the NRC require the location of the west corridor to be relocated eastward 

along existing developed areas. Information provided in the Biological Assessment and DEIS 

indicate that parcels of the rare pine-rockland habitat type are located within or near the west 

corridor. Pine rocklands are a globally imperiled ecosystem, which has been reduced by 95 

percent of its historical range in Miami-Dade County, and is home to sixteen candidate and 

listed species. We recommend that these habitat parcels be avoided when siting the west 

corridor transmission line. The transmission towers and wires of the proposed transmission lines 

will be greatly elevated above the ground (80 to 150 feet). Consequently, they represent a 

hazard to migratory birds flying through the area, especially at night. Migratory birds may have 

difficulty avoiding these structures, and may be injured or killed due to collisions with these 

structures. These trust resources are protected under the MBTA. Therefore, FPL should 

develop a Department approved avian protection plan to avoid, minimize impacts to bird species 

and compensate for the loss of their habitat. (0227-13 [Stanley, Joyce])

Response: Transmission corridors and specific routes evaluated in the EIS include those 

proposed by FPL. Expected impacts are discussed in numerous subsections in Sections 4.3.1 

and 5.3.1 of the EIS. FPL's Avian Protection Plan is briefly discussed and referenced in Section 

4.3.1.6 of the EIS. Requiring FPL to use any particular transmission corridor or route or to 

obtain approval from the FWS of its Avian Protection Plan is outside the scope of the review 

team's authority. No changes were made to the EIS in response to this comment. 

Comment: Western laydown area. A storage or laydown area for the stockpiling of 

construction materials and equipment will be established just east of the northeast portion of the 

cooling canal system and immediately east of the footprint for Units 6 and 7. This area is largely 

disturbed but is located immediately east of canal and berm habitat inhabited by the crocodile in 

the cooling canal system. To reduce the likelihood that crocodiles and other wildlife are hit by 

motor vehicles or crushed during movement and storage of materials, we recommend FPL 

install continuous barrier fencing along both sides of SW 359 Street where it borders the 

reclaimed water treatment facility, cooling canal system, and test canal system. The continuous 

Appendix E October 2016 E-273 NUREG–2176
fencing should also extend southward along the western edge of the heavy haul road and along 

the western boundary of the laydown area to a point about 500 feet south of the land utilization 

building. The fence should be constructed of at least 6-foot tall galvanized chain-link type 

material (or a similar material that will exclude crocodiles). If needed, a barrier material of some 

type should be installed along the bottom two to three feet of the fence to prevent small 

crocodiles and other small species of wildlife from passing through the fence. The proposed 

fence will connect with the barrier fencing the FPL has agreed to install along both sides of SW 

359th Street from SW 137th Avenue/Tallahassee Road to the L-31E Canal, SW 137th Avenue 

from SW 344th Street/Palm Drive to SW 359th Street, and SW 117th Avenue from SW 344th 

Street/Palm Drive to SW 359th Street to protect wildlife in the area. (0227-14 [Stanley, Joyce])

Response: Impacts on the American crocodile are discussed as part of Sections 4.3.2.3 and 

5.3.2.3. A Biological Assessment (BA) was submitted to the FWS to address effects on 

protected species, such as the American crocodile, through consultation under ESA Section 

7. The FWS may determine, as part of their ongoing formal consultation with the review team 

under ESA Section 7, that additional fencing requirements are necessary for crocodile 

protection. No changes were made to the BA as a result of this comment. Updates to ESA 

Section 7 consultation were made to Sections 4.3.1, 4.3.2, 5.3.1, and 5.3.2 of the EIS. 

Comment: 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. (0288-7 [Cleland, 

Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] 

[Ullman, Jonathan])

Response: Although FPL had discussed acquiring fill material from an FPL-owned fill source 

for the construction of Turkey Point Units 6 and 7 in their ER, FPL subsequently stated in a 

letter to the NRC that they removed the FPL-owned fill source from the application. As noted in 

Section 4.3.1.4 of the EIS, FPL would acquire all of the fill from regional commercial 

mines. None of the available commercial mines are located near Biscayne National Park or 

directly on the coast, and all of them are permitted by the USACE to operate as such. Impacts 

on wetlands from the operation of commercial mines is regulated as a separate action under the 

existing permits held by the mine owners. No changes were made to the EIS as a result of this 

comment. 

Comment: According to the CWA Section 404(b)(l) Guidelines, 40 CFR § 230.91(c), and the 

February 6, 1990, Memorandum of Agreement between the U.S. Anny Corps of Engineers and 

the EPA regarding the Determination of Mitigation under the Clean Water Act Section 404{b)(l) 

Guidelines, an applicant must demonstrate avoidance and minimization of wetland impacts 

before compensatory mitigation can be considered. Subpart H of the CWA Section 404(b)(1) 

Guidelines describes several (but not all) means of minimizing impacts of an activity. Section 

4.3.1.6, Wetland Mitigation Plan (pg.70): The DEIS states that, as part of the compensatory 

mitigation offset projects impacts, FPL proposes to restore two parcels totaling 812 acres.

(0617-1-13 [Mueller, Heinz J.])

Response: The commenter identified an issue related to the Clean Water Act Section 404 

permitting process. This comment is acknowledged. The USACE has not concluded its review 

and permitting process for wetlands impacts. Mitigation that would address impact avoidance 

and minimization is discussed in Section 4.3.1.6. Section 4.3.1.6 has been updated to reflect 

progress in the Section 404 permit review process and the development of wetland mitigation. 

Appendix E NUREG–2176 E-274 October 2016
Comment: The proposed powerlines could also harm snail kites, which forage by flying over 

suitable marsh habitat at an elevation of 10-16 feet above vegetation. Like wood storks, they 

may be vulnerable to collisions with guy wires. Forage flights at this elevation would occur well 

below the expected transmission-line heights of 80-90 feet (230 kV) and 140-160 feet (500 kV). 

Because the snail kite population is severely depressed, even the loss of a few individuals may 

have population-level impacts. We suggest the NRC include a discussion in section 5.3.1 

regarding the value of not using guy wires for portions of the western corridor near sensitive bird 

habitat, which could significantly limit collision risks for wood storks and snail kites. (0622-1-21

[Austin, Stan])

Response: The comment suggests that the use of non-guyed transmission poles near 

sensitive areas could decrease environmental impacts from the proposed action. The 

discussion in Section 5.3.1 of the EIS identifies collision with guy wires as a risk to snail 

kites. Although no information exists that would quantify this risk, the review team 

acknowledges that use of non-guyed transmission poles near snail kite nests and foraging 

areas would likely reduce risk to snail kites. Although the review team added a discussion to 

Section 5.3.1 about the possible benefits of reducing the number of transmission line guy wires, 

the review team cannot require the applicant to change its design unless it falls within its 

regulatory jurisdiction. 

Comment: Biscayne Bay Coastal Wetlands Projects -Phase 1 and Phase 2[.] As set forth 

above, implementation of the BBCW Project is crucial to realizing the suite of direct restoration 

benefits provided by the project. Although Phase 1 of this project has been previously 

described, Phase 2 includes the critical component of locating and providing a source of much 

needed additional freshwater to Biscayne NP and Biscayne Bay. To implement BBCW Phase 2, 

additional lands will be needed, as well as planning, design, and construction funding. Some 

project lands needed to complete Phase 2 are in FPL ownership. The NPS urges the action 

agencies to consider requiring mitigation that would move Phase 2 of this crucial project 

forward. Mitigation could be donation of project lands or funding components of the project. The 

NPS wishes to begin a dialogue with the action agencies regarding these mitigation possibilities.

(0622-2-7 [Austin, Stan])

Response: This comment contains a specific suggestion regarding possible mitigation for 

wetland impacts resulting from the project. The review team appreciates suggestions regarding 

possible mitigation measures but can only consider mitigation proposed by the applicant or 

required by agencies specifically authorized to enforce the mitigation. No changes were made 

to the EIS as a result of this comment. 

Comment: Numerical value inconsistencies within the draft EIS: Appendix F-2, Section 2.1, 

Page 2-4, Lines 40-43 "Two potential routes were proposed for the West corridor--the preferred 

and consensus routes. Each route would eventually be about 89 mi long..." (Reference for 

statement was corrupt.) DEIS Table 2-4 ER Subsection 3.7.2 DEIS Table 2-4 indicates that this 

length is 52 miles. In the first paragraph of ER Subsection 3.7.2, the length of the West corridor 

"Clear Sky -- Pennsuco (230 kV)" is characterized as 52 miles. (0619-2-37 [Maher, William])

Comment: Numerical value inconsistencies within the draft EIS: Appendix F-2, Section 2.3.2, 

Page 2-9, Lines 16-18 "Approximately 89 mi of corridors are being proposed; approximately 52 

mi of the corridor would be associated with either of the two West corridor routes, and 

approximately 36 mi would be associated with the East corridor." DEIS Table 2-4 ER 

Subsection 3.7.2 DEIS Table 2-4 indicates that this length is 37 miles. In the first paragraph of 

Appendix E October 2016 E-275 NUREG–2176
ER Subsection 3.7.2, the length of the East Corridor comprised of Clear Sky to Davis (19 miles) 

plus Davis to Miami (18 miles) results in a total of 37 miles. (0619-2-38 [Maher, William])

Comment: Numerical value inconsistencies within the draft EIS: Appendix F-2, Section 5.6, 

Page 5-4, Lines 35-36 "The construction of Units 6 and 7 could permanently eliminate 182 ac of 

mudflat suitable as piping plover (Charadrius melodus) wintering habitat." DEIS Subsection 

4.3.2.1, Page 4-77, Lines 33-35 DEIS Appendix F-2, Subsection 3.1.1, Page 3-3, Lines 14-17 

ER Section 2.4 "As described in ER Revision 6 (FPL 2014-TN4058) wetland and aquatic 

habitats within the proposed Units 6 and 7 plant area and adjacent laydown areas include the 

following: *187.5 ac of mudflats..." Similarly, Appendix F-2: "Wetland and aquatic habitats within 

the proposed Units 6 and 7 plant area and adjacent laydown areas total approximately 270 ac 

and include the following land-cover classes: * 187.5 ac of mudflats..." ER Section 2.4: "Wetland 

habitats within the Units 6 & 7 plant area and the adjacent laydown area include mudflats (187.5 

acres)..." (0619-2-39 [Maher, William])

Comment: DEIS Appendix F-2, Subsection 3.2.1.1, Pages 3-13/3-14, Lines 18-26/1-2: USFWS 

BA states: "NRC EIS, NUREG-2176 Section 3.2.2.1 discusses stormwater drainage for the plant 

area...According to Table 2-10 of the NRC EIS, NUREG-2176, the average annual runoff for the 

plant area prior to building for the period from 2000 to 2010 is...annual average precipitation 

depth of 56.10 in...The annual average runoff after building decreases largely due to the 

removal of the makeup-water reservoir as a contributing area. The maximum annual 

precipitation during the period was 71.53 in. during 2005, which produces 1,428 ac-ft of runoff 

after building compared to 1,646 ac-ft (NRC EIS, NUREG-2176 Table 2-10) prior to building." 

There are some inconsistencies with the DEIS (emphasis added): a. DEIS Subsection 2.3.1.1 

states "The review team estimated an average annual precipitation of 57.10 in. and maximum 

annual precipitation of 71.53 in. during the period from 2001 through 2010." b. DEIS Table 2-10 

reports the maximum total annual runoff for the plant area prior to building for the period from 

2000 to 2010 (2001 to 2010) as 1,715 ac-ft. (0619-6-13 [Maher, William])

Comment: DEIS Appendix F-2, Section 2.1, Page 2-4, Lines 34-36 and DEIS Appendix F-2 

Subsection 3.1.1, Page 3-4, Lines 6-8: USFWS BA (Section 2.1) states: "The review staff 

assumes water contained in the muck would drain primarily into the IWF; the spoil pile at the 

southern end of the site may dewater into Card Sound." Similarly the USFWS BA 

(Subsection 3.1.1) states: "There is also concern that the disturbance and relocation of the 

muck from the plant site to the cooling-canal berms may adversely affect the water quality of 

the IWF and possibly Card Sound as the muck dewaters." Condition of Certification, Section 

B "Specific Conditions - Power Plant and Associated Facilities (Excluding Transmission Lines)", 

Subsection VII "Miami-Dade County", Item C.2, page 78 states: "To the greatest extent 

practicable FPL shall use proposed Spoil Areas A and C, located along the east and west 

berms of the Grand Canal. If spoils are placed on Area B, FPL shall implement Best 

Management Practices to limit to the extent practicable, runoff from the spoils entering the 

wetlands areas to the south of the Industrial Wastewater Facility." (emphasis added)

(0619-6-2 [Maher, William])

Response: These comments contain specific suggested edits to the text of the BA that the 

review team submitted to FWS as part of its consultation under ESA Section 7. The BA was a 

final product of the FWS formal consultation process and hence has not been edited. The 

information is acknowledged. The information does not alter the conclusions in the BA or 

substantially alter the presentation of information in the BA. If the information did substantially 

alter the content of the BA, the NRC would have notified the FWS. 

Appendix E NUREG–2176 E-276 October 2016
Comment: Synergistic effects of aerosols. I'm a bee farmer. You combine certain pesticides 

you have bee colony collapse. If we're killing bees, humans are not going to be around much 

longer either. So these things need to be looked at. (0721-24-4 [Eastman, John])

Response: Colony Collapse Disorder (CCD) is a recognized phenomenon affecting honey 

bees worldwide. Extensive research indicates no single causative agent. Although pesticides 

have not been ruled out as a contributing factor, insecticides and possibly fungicides currently 

appear to be the group of pesticides that may contribute to CCD. Pesticides likely used by FPL 

related to the construction and operation of Units 6 and 7 would be herbicides to control 

invasive plant species (discussed in Section 5.3.1.2). Herbicides have not been implicated as a 

causative agent of CCD. Specific herbicides used to control vegetation have not been identified 

by FPL, but as noted in Section 5.3.1.2, any herbicide or pesticide use would be conducted in 

compliance with applicable Federal, state, and local laws, regulations, and permit 

requirements. No changes were made to the EIS as a result of this comment. 

Comment: The NMFS believes the proposed mangrove fill is not consistent with EPA' s 

Guidelines for Specification of Disposal Sites for Dredged or Fill Material. The fundamental 

precept stated in 40 CFR 230.1(c) that *dredged or fill material should not be discharged into 

the aquatic ecosystem unless it can be demonstrated that such a discharge will not have an 

unacceptable adverse impact either individually or in combination with known and/or probable 

impacts of other activities affecting the ecosystems of concern" would not be met by this project. 

The basic purpose of the project, as stated in the public notice is to meet the public's need for 

electric energy. Based on guidance provided by 40 CFR 230.10(a)(3), energy development 

does not require access or proximity to or siting within wetlands to achieve the basic purpose 

(i.e., energy production is not water dependent). In discussing the water dependency 

requirement, the guidelines state that for non-water dependent projects, practicable alternatives 

that do not involve special aquatic sites (e.g., wetlands adjacent to and within the Biscayne Bay 

Aquatic Preserve) are presumed to be available. (0724-16 [Fay, Virginia M.])

Response: Placement of fill material within waterways of the U.S. would be regulated by the 

USACE under a Department of the Army permit. As part of its review of FPL’s application for a 

Department of the Army permit to perform work in waters of the United States, the USACE 

would determine whether the proposed action was the LEDPA (least environmentally damaging 

practicable alternative) in accordance with the Section 404(b)(1) guidelines (40 CFR 230). No 

changes were made to the EIS as a result of this comment. 

Comment: [W]e also handle and capture and monitor the indigo snakes where their habitat is 

threatened. And we monitor their population and their growth. We also monitor terns, the 

nesting terns. They love our berms to nest on, and the wading birds that are populating our 

canals. But not just the native species but also there are a mix of exotics. We now have permits 

to eradicate the pythons. So we're giving back to the community in so many different ways and 

these are small examples of our environmental stewardship. (0723-15-3 [Bertelson, Bob])

Response: The comment expresses support for environmental stewardship at the Turkey Point 

site. The comment does not provide specific information related to the environmental effects of 

the proposed action, and no changes were made to the EIS. 

Comment: Finally, the South Florida Water Management District plans to construct culverts on 

the east side of the L-31 E right-of-way for the BBCW project. FPL is also considering using the 

same right-of-way to accommodate the reclaimed water pipeline. The DEIS does not adequately 

discuss this potential conflict and how plans for reclaimed wastewater pipelines may negatively 

Appendix E October 2016 E-277 NUREG–2176
impact plans to proceed with Everglades restoration. [Footnote 31: South Florida Water 

Management District, Third Completeness Comments, FPL Turkey Point Units 6 & 7, Site 

Certification Application Power Plant & Associated Facilities, June 4, 2010, 14.] Considering the 

extensive loss of ecologically valuable wetlands in and around Turkey Point and Biscayne Bay 

that has already occurred and the commitment of the federal government and the state of 

Florida to restore and replenish wetland resources in these areas, the DEIS must include an 

adequate discussion of how the construction and operation of around nine miles of pipeline will 

further impact wetland resources and if reasonable alternatives exist. (0113-2-17 [Lopez, Jaclyn] 

[McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Response: Impacts on terrestrial resources from the proposed reclaimed-water pipeline are 

described in Sections 4.3.1 and 5.3.1 of the EIS and include consideration of direct, indirect, 

and cumulative impacts from building and operating those pipelines on wetlands and 

wildlife. No changes to the EIS were made as a result of this comment. 

Comment: New paved roads. The project will result in the construction of new paved 

roadways to provide the main construction access to the project site and allow the delivery of fill, 

equipment, and construction materials. New paved roadways will be constructed within the 

footprint of existing dirt roadway at: SW 137th Avenue from SW 344th Street/Palm Drive to SW 

359th Street (three lanes); SW 117th Avenue from SW 344th Street/Palm Drive to SW 359th 

Street (three lanes); and SW 359th Street from SW 137th Avenue/Tallahassee Road to the 

Turkey Point Power Plant site (three lanes from SW 137th Avenue to SW 117th Avenue and 

four lanes from SW 117th Avenue to the Turkey Point Power Point site, including a new bridge 

over the L-31E Canal). Consequently, the project will introduce significant motor vehicle traffic 

(consisting largely of trucks) within an area that seldom experiences motor vehicle traffic and 

increase the likelihood of injuries and deaths to the panther and other wildlife resulting from 

collisions with vehicles. We note the proposed paved roadways described above will result in a 

significant loss of wetlands and fish and wildlife habitat and the impacts to the environment will 

be great. We recommend that the NRC require FPL to use a less environmentally damaging 

route to access the project site, such as the use of Palm Drive. We understand that this will 

increase motor vehicle traffic on this roadway but we believe that this problem could be 

overcome through road widening, the use of a shuttle bus system for FPL employees, and the 

judicious construction of new access roads near the project site. In the event that the proposed 

new paved roadways are implemented. FPL has agreed to several protective measures to 

reduce the potential for vehicle collisions, including installing continuous barrier fencing on both 

sides of the new roadways (i.e., SW 137th Avenue from SW 344th Street/Palm Drive to SW 

359th Street, SW 117th Avenue from SW 344th Street/Palm Drive to SW 359th Street, and SW 

359th Street from SW 137th Avenue/Tallahassee Road to the Turkey Point Power Plant site), 

and installation of a large underpass structure and several smaller culvert structures along SW 

359th Street that will allow Florida panthers and other wildlife to pass safely under the roadway. 

In addition, FPL has agreed to remove these paved roadways following construction and return 

the area to its original condition (i.e., lime dirt road and wetlands). (0227-10 [Stanley, Joyce])

Response: The review team appreciates suggestions such as this that could reduce impacts to 

terrestrial ecology resources, but the NRC does not have the regulatory authority to require FPL 

build its roads or other project facilities in specific locations. No changes were made to the EIS 

specifically as a result of this comment. 

E.2.10 Comments Concerning Ecology - Aquatic 

Comment: The algae bloom was never controlled. (0008-5 [Finver, Jody])

Appendix E NUREG–2176 E-278 October 2016
Comment: When power output was increased, algae bloom followed. Now FPL is pumping 

toxins in to control it. (0252-4 [Van Leer, Sam])

Comment: 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. (0288-2 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, 

Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Response: The commenters are concerned about the algae bloom in the IWF cooling 

canals. These cooling canals are used for the operation of Turkey Point Units 3 and 4, and 

would not be used for cooling Units 6 and 7. These comments offer no new information relative 

to the construction and operation of Units 6 and 7. However, a more detailed description of the 

changes in the cooling canals since 2013 has been added to Sections 2.3.1 and 2.4.2. 

Comment: Please do NOT approve additional Nuclear reactors at Turkey Point in South 

Florida. There are already problems with the water surrounding the current reactor, too warm 

for the sea life and causing unnecessary algae to bloom. More reactors will mean more warm 

water flowing into the canals that feed into Biscayne Bay. This is disastrous for the sea life of all 

types. (0048-1 [Wegner, Geri])

Comment: Regarding the FPL request to enlarge Turkey Point, I am sure you are aware that it 

is located on the border of Biscayne National Park. The existing cooling canals drain into the 

Card Sound National Lobster Sanctuary. Our marine life has been severely compromised over 

the last few decades with the population explosion that has happened in and around the Miami 

area. I have been here since 1966 and have personally experienced the decline of our natural 

habitat and marine life. The heated water that already runs into this precious area along with 

sewage infiltration from Miami Dade County has resulted in a marked decline of our local wildlife 

since my arrival. The stress that this project will have on what natural splendor we still have left 

will be devastating. As you know, even a slight increase in water temperature can be fatal to 

living corals and sea grass. (0081-3 [Benson, Mary] [Skove, Ellen H.] [Tompkins, Constance])

Comment: It is a serious matter to chance raising the water temperature and negatively 

affecting the wildlife of the Florida Keys. (0084-1 [Phillips, Monica D.])

Comment: Discharged hot water from cooling systems is known to affect fish reproduction and 

development. (0214-5 [Zerulla, Tanja])

Comment: The water is not deep enough in the area and it would cause it to heat up, thus 

killing all the fish etc. (0368-2 [Casey, Sr., Robert J.])

Comment: Please consider the impacts of dumping additional hot water directly into Biscayne 

Bay. (0537-5 [Anonymous, Judi])

Comment: Once those towers are built we can't go back. If the temperature in our water in 

Biscayne Bay rises and we continue to get algae blooms and we continue to get fish killing 

because of the rise in salt, salinity and we have rise in temperatures we are doomed. We need 

to also represent the voice of the ocean, the water and the wildlife. (0722-17-4 [Swenson, Cyndee])

Appendix E October 2016 E-279 NUREG–2176
Response: The commenters are concerned about the potential for warm water discharge from 

proposed Units 6 and 7 to the IWF cooling canals and Biscayne Bay, and the potential for algae 

blooms and adverse effects on marine organisms. As described in Section 5.3.2, the operation 

of two new reactors would result in discharge of station blowdown from Units 6 and 7 to deep 

injection wells. There would be no thermally enriched water discharges to surface waters, 

including Biscayne Bay or the IWF, from operation of units 6 and 7. There would be no surface 

water discharge of treated or untreated reclaimed water to any surface waters. No changes 

were made to the EIS as a result of these comments. 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...If the additional reactors generate more water 

water then more Manatees can benefit from that further increasing their numbers. The addition 

of the 2 reactors thus can point to positive environmental benefits to a threatened species.

(0015-13 [Goldmeier, Barry])

Response: The commenter supports the construction and operation of two new nuclear units 

for the possible benefit additional warm water might provide to endangered manatees. The 

effects of operation on protected aquatic species is described in Section 5.3.2, and in the staff’s 

BA for the FWS mentioned in Appendix F2 of this final EIS. Due to the proposed deep-well 

injection of blowdown water, no warm water would be discharged to the nearshore waters of 

Biscayne Bay. No changes were made to the EIS as a result of this comment. 

Comment: [The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the county's wastewater. Even in small amounts, these can 

affect] terrestrial and marine environments like mangroves, seagrass beds and coral reefs. The 

aerosol mist can be dispersed widely by wind and water. (0078-7 [Wilansky, Laura Sue])

Comment: The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacterial and viruses that end up in the countys wastewater. Even in small amounts these can 

effect] terrestrial and marine environments like mangroves, seagrass beds and coral reefs. The 

aerosol mist can be dispersed widely by wind and water currents. Did I mention this is a 

hurricane prone state? (0353-5 [Royce, M.])

Comment: [The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the county's wastewater. Even in small amounts, these can 

affect] terrestrial and marine environments like mangroves, seagrass beds and coral reefs. The 

aerosol mist can be dispersed widely by wind and water currents. (0356-11 [Shlackman, Jed])

Comment: [The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacterial and viruses that end up in the countys wastewater. Even in small amounts these can 

effect] terrestrial and marine environments like mangroves, seagrass beds and coral reefs. I do 

NOT want to CHANCE that the aerosol mist may be (likely) dispersed widely by wind and water 

currents. (0362-3 [Hurley, Paula])

Comment: [The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacterial and viruses that end up in the county's wastewater. Even in small amounts these can 

effect] terrestrial and marine environments like mangroves, seagrass beds and coral reefs. The 

aerosol mist can be dispersed widely by wind and water currents. (0366-5 [Griffith, Ed and Harriet])

Appendix E NUREG–2176 E-280 October 2016
Comment: Even in small amounts, these can affect human health and terrestrial and marine 

environments like mangroves, seagrass beds and coral reefs. The aerosol mist can be 

dispersed widely by wind and water currents. (0370-10 [Vayu, Satya])

Comment: [The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the county's wastewater. Even in small amounts, these can 

affect] terrestrial and marine environments like mangroves, seagrass beds and coral reefs. The 

aerosol mist can be dispersed widely by wind and water currents. (0676-7 [Kassel, Kerul])

Comment: When it comes out as gaseous H2O, as water vapor, there's gases mixed in with it 

that contain some of these chemicals. When the water droplets, where people call "drift," come 

out, those little tiny particles, they contain the exact same constituents of the wastewater, 

drifting over Biscayne Bay, over the terrestrial ecosystem. (0721-22-13 [Schwartz, Matthew])

Comment: [What are the impacts of drift] on the terrestrial landscape, on Biscayne Bay, on 

mangroves, on sea grass beds, on coral reefs? (0721-22-15 [Schwartz, Matthew])

Comment: How many places in the United States, Continental United States have a coral 

reef? We're blessed with a coral reef in South Florida. We're going to build a nuclear power 

plant right next to them, throw the wastewater up into the air as vapor and droplets and disburse 

it over this entire area. (0721-22-16 [Schwartz, Matthew])

Response: The commenters are concerned that aerosolized components from the cooling 

towers would be harmful to human and ecological resources. Sections 5.3.1 and 5.3.2 discuss 

the relative deposition of a number of contaminants of concern that may be present in reclaimed 

wastewater and concluded that the expected trace amounts would have negligible effects due to 

the extremely low concentration and dilution in receiving water bodies. No changes were made 

to the EIS as a result of these comments. 

Comment: The expansion of Turkey Point could have serious environmental impacts on 

sensitive ecological habitat and the health and sustainability of limited freshwater resources.

(0102-3 [Commenters, Multiple])

Comment: And an expansion of Turkey Point could jeopardize the area's limited freshwater 

resources as well as sensitive habitat for a wide range of federally protected endangered 

species. (0103-3 [Commenters, Multiple])

Comment: Furthermore, changes to the salinity, quality and temperature of water in Biscayne 

may result in impacts to the seasonal behaviors of threatened and endangered species, such as 

the West Indian manatee and American crocodile. [Footnote 7: Lewis, M. and D. B. Kimball, 

United States Department of Interior, National Park Service Letter to U. S. Nuclear Regulatory 

Commission, April 16, 2010, L 67, 16.] (0113-1-13 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, 

Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: As fresh water is withdrawn from either the aquifer and/or the bay, there may be 

less freshwater to replenish the system, affecting salinity levels within Biscayne Bay. The 

withdrawal of freshwater from either of these sources has the potential to permanently disrupt 

the system's saltwater regime and could have substantial impacts to local ecosystems, which 

are extremely sensitive to changes in salinity. Disruption in nearshore habitats and overall 

ecological stability may occur as a result of hydrologic impacts that change water quality and 

Appendix E October 2016 E-281 NUREG–2176
volume with the bay. (0113-1-16 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, 

Matthew] [Silverstein, Rachel])

Comment: Given the sensitivity of our coastal waters, including the only living coral reef in the 

US, I am shocked that we are considering the addition to the environmental burden. (0130-2

[Jones, Diane])

Comment: So many of our waters have already been ruined by development, drilling, pollution, 

and humans. Enough is enough! Our waters are supposed to be a place of peace and quiet for 

us, and the fish and wildlife which live in them! The animals are running out of places to live and 

be safe. Our fish and wildlife are under threat from so many angles. They desperately need to 

be protected, mainly from humans. Life is hard enough for people, let alone the animals. Can't 

we please offer them some much needed help?! PLEASE save the waters Biscayne National 

Park for all future generations before they are permanently ruined. Some damage cannot be 

undone! (0191-1 [Hodie, Jake])

Comment: Expanding this nuclear plant would endanger the precious coral reefs. (0193-2

[Shipe, Kathleen])

Comment: We are concerned that withdrawing massive amounts of freshwater from 

underneath Biscayne Bay could increase salinity levels within Biscayne National Park and 

hasten saltwater intrusion into freshwater resources. (0210-4 [Sharp, Andrea Heuson])

Comment: Expanding Turkey Point would have serious environmental impacts on sensitive 

ecological habitat and the health and sustainability of limited freshwater resources. (0228-3

[Yeager, Jerry])

Comment: The waters of Biscayne Bay are also home to incredible coral reef habitat and 

numerous threatened and endangered animals, including the West Indian manatee, American 

crocodile, and five species of sea turtles. (0258-3 [Field, Fran])

Comment: The waters of Biscayne Bay are also home to incredible coral reef habitat and 

numerous threatened and endangered animals, including the West Indian manatee, American 

crocodile, and five species of sea turtles. (0284-3 [Lopez, Josie])

Comment: The expansion of the power plant would only intensify and expand these negative 

impacts, posing significant threats to sensitive ecological areas and critical freshwater supplies. 

(0284-5 [Lopez, Josie])

Comment: In addition, the expansion could have serious environmental impacts on sensitive 

ecological habitat and the health and sustainability of limited freshwater resources. (0295-4

[Dietrich, Chris OMeara])

Comment: The expansion of Turkey Point could have serious environmental impacts on 

sensitive ecological habitat and the health and sustainability of limited freshwater resources.

(0299-2 [Salatino, Freda])

Comment: It would threaten other sensitive marine resources, including dozens of federally 

protected species such as the American crocodile, Florida manatee and five species of sea 

turtle. (0356-2 [Shlackman, Jed])

Appendix E NUREG–2176 E-282 October 2016
Comment: These two new nuclear plants would also threaten other sensitive marine resources 

such as dozens of federally protected species to include the American crocodile, Florida 

manatee and five species of sea turtle. (0366-7 [Griffith, Ed and Harriet])

Comment: It would threaten other sensitive marine resources, including dozens of federally 

protected species such as the American crocodile, Florida manatee and five species of sea 

turtle. (0370-3 [Vayu, Satya])

Comment: Important natural resources would be in serious jeopardy. (0370-7 [Vayu, Satya])

Comment: The expansion of Turkey Point will have serious environmental impacts on sensitive 

ecological habitat and the health and sustainability of limited freshwater resources. (0413-2

[Cobb, Tanya])

Comment: Expansion of Turkey Point could have serious environmental impacts on sensitive 

ecological habitat and the health and sustainability of limited freshwater resources. (0415-1

[Hazard, Evan])

Comment: If approved, the project will also destroy mangrove and seagrass populations that 

perform vital ecosystem services, including maintaining our water quality and protecting our 

shoreline. (0515-3 [Regalado, Tomas])

Comment: The expansion of Turkey Point could have serious environmental impacts on 

sensitive ecological habitat and the health and sustainability of limited freshwater resources. 

"Our duty to the whole, including to the unborn generations, bids us to restrain an unprincipled 

present-day minority from wasting the heritage of these unborn generations. The movement for 

the conservation of wildlife and the larger movement for the conservation of all our natural 

resources are essentially democratic in spirit, purpose and method." --Theodore Roosevelt

(0555-1 [Lish, Christopher])

Comment: Other than the disposition of nuclear waste, the use of water by the plant that is 

located in a fragile ecological area, is something that should take priority in considering the 

licensing of the plant. (0613-1 [Icaza, Alejo])

Comment: FP&L has stated that their two proposed nuclear reactors will use 90 million gallons 

of water daily for cooling. This will naturally have a negative impact on the plants, animals, birds, 

and marine life in the Everglades, Biscayne National Park, and the Atlantic Ocean which border 

the nuclear facility. (0671-1-1 [Post, Patrick])

Comment: It would threaten other sensitive marine resources, including dozens of federally 

protected species such as the American crocodile, Florida manatee and five species of sea 

turtle. (0676-2 [Kassel, Kerul])

Comment: The design (engineering tech exist today) must not effect/should not have any 

serious environmental impacts on sensitive ecological habitat and the health and sustainability 

of limited freshwater resources. (0694-6 [Carpenter, Rory])

Comment: [Building 6 and 7 will foul the water supply], threatening the sea life and aquatic 

sanctuaries in the area. (0721-12-10 [White, Barry J.])

Appendix E October 2016 E-283 NUREG–2176
Comment: Increased salinity will reduce fresh water which hatchling and juvenile sea life in 

Biscayne National Park and Biscayne Bay Aquatic Preserve, next door to Turkey Point, need to 

survive. (0721-12-4 [White, Barry J.])

Comment: Also Biscayne National Park is the country's largest marine park and is home to 

incredible life diversity, important habitats, watersheds and ecosystems. The expansion of 

Turkey Point puts these natural resources at risk. (0722-14-4 [Kaul, Devika])

Response: The commenters express general concern about the potential for adverse effects 

on ecological resources, protected species, and freshwater supplies as a result of the 

construction and operation of Units 6 and 7. The effects of construction and site preparation on 

the water use and quality of surface water and groundwater resources are described in Section 

4.2, and the effects of operation in Section 5.2, and were determined to be SMALL. The effects 

of construction and site preparation on terrestrial and aquatic ecological resources and 

protected species are described in Sections 4.3.1 and 4.3.2, respectively, and were found to be 

MODERATE for Terrestrial resources and SMALL for Aquatic resources except to the American 

crocodile, which would sustain a MODERATE impact. Operational effects on terrestrial 

ecological resources (including wetlands and listed species) and aquatic resources and 

protected species were found to be MODERATE and are described in Section 

5.3.1. Operational effects on Aquatic resources were found to be SMALL and are described in 

Section 5.3.2. Because the new units would use reclaimed water as a source of cooling water 

with RCWs as a backup water source, employ closed-cycle cooling, and dispose of station 

blowdown through deep-well injection, adverse effects on aquatic resources would be 

avoided. No changes were made to the EIS as a result of these comments. 

Comment: Our residents enjoy recreating in this very area and have already seen a decrease 

in fish and bird populations that local experts tell us is related to the hypersalinity in the area.

(0208-3 [Ritz, David])

Comment: Stop disrupting already traumatized bio-systems, National Parks, endangered 

species by disregarding what The People want. (0532-2 [Raab, Frances])

Comment: This power plant has been sited in the past for environmental damages such as 

pumping too WARM of water out in to the Gulf thereby destroying coral and changing the entire 

marine life in that area. (0604-1 [Courliss, William])

Comment: Costs to the ecosystem, which I think was the last question that came up. (0721-1-8

[Rodriguez, Jose Javier])

Comment: [We need to look at the salt water plume], the impact it's had on crocodiles[.]

(0721-13-7 [Martin, Drew])

Comment: Biscayne National Park is one of our country's largest marine national parks and it's 

home to important marine biodiversity and wetland and marine habitats and countless 

opportunity for education and recreation. (0723-4-3 [McLaughlin, Caroline])

Comment: The waters of Biscayne Bay are also home to incredible coral reef habitat and 

numerous threatened and endangered animals, including the West Indian manatee, American 

crocodile, and five species of sea turtles. Turkey Point's operations are already impacting 

Biscayne Bay's habitat, water quality, and salinity, which are vital for the health and productivity 

of the bay. The expansion of the power plant would only intensify and expand these negative 

Appendix E NUREG–2176 E-284 October 2016
impacts, posing significant threats to sensitive ecological areas and critical freshwater supplies.

(0728-2 [Gregory, Gregory B.])

Response: The commenters express general concern about the current status of ecological 

resources in the area. The staff agree that Biscayne National Park is an important resource for 

marine biodiversity. However, the staff is unaware of any studies showing destruction of corals 

or significant changes to marine life in Biscayne Bay as a result of current Turkey Point 

operations. Except for site runoff, there would be no discharges to surface waters from 

operation of Units 6 and 7. No new information is provided, therefore, no changes were made 

to the EIS as a result of these comments. 

Comment: When nuclear plants draw water from natural water sources, fish and other wildlife 

get caught in the cooling system water intake structures. A study done in California investigated 

impacts from 11 coastal power plants and estimated that a single nuclear plant can kill millions 

of fish! (0340-2 [Tweeton, Tanya])

Comment: The proposed new nuclear reactors would also imperil fish larvae and other forms 

of aquatic life, which are strained from the water as it travels through thousands of metal tubes 

to become steam that turns the turbines to make electricity. A 2005 study found that one coastal 

power plant in Southern California destroyed nearly 3-and-a-half million fish in just one year. 

(0592-9 [Brexel, Sr., Charles])

Response: The commenters express general concern about the current status of ecological 

resources in the area as well as the current water quality of Biscayne Bay. The staff agree that 

Biscayne National Park is an important resource for marine biodiversity. However, the staff is 

unaware of any studies showing destruction of corals or significant changes to marine life in 

Biscayne Bay as a result of current Turkey Point operations. Except for site runoff, there would 

be no discharges to surface waters from operation of Units 6 and 7. There would be no heated 

discharge to Biscayne Bay from the construction and operation of Units 6 and 7 and no 

degradation of water quality. No new information is provided; therefore, no changes were made 

to the EIS as a result of these comments. 

Comment: DEIS Subsection 2.4.2.1, Page 2-119, Lines 2-4 and DEIS Subsection 2.4.2.1, 

Page 2-121, Table 2-18: The DEIS (Page 2-119) states: "onsite surface-water habitats 

exclusive of the IWF include hypersaline mudflats, remnant canals...and areas of open water". 

The onsite surface-water habitats listed are inclusive of the IWF. Further, the sentences that 

follow describe data taken from sampling locations that are located within the permitted IWF. 

Similarly, DEIS Table 2-18, "Fish Species Present in Surface-Water Habitats Exclusive of the 

IWF on Turkey Point Site in Summer 2009", includes observations from locations within the 

permitted IWF; all listed observation points in this table are located within the IWF as described 

in DEIS reference FPL 2009-TN201. The statement and Title of Table 2-18 should reflect that 

the onsite surface-water habitats and surface water sampling are "inclusive of the IWF". 

(emphasis added) (0619-3-12 [Maher, William])

Comment: DEIS Subsection 2.4.2.4, Page 2-154, Lines 38-40: The DEIS states: "Because 

modifications to the existing equipment barge-unloading area were expected...a survey of 

seagrass presence in that area was conducted during the summer of 2008 (EAI 2009-TN153)." 

The correct reference for the seagrass survey of the equipment barge unloading area is: (FPL 

2010-TN272).) (emphasis added) (0619-3-13 [Maher, William])

Appendix E October 2016 E-285 NUREG–2176
Comment: DEIS Subsection 4.3.2.1, Page 4-78, Lines 31-32: The DEIS states: "The RWTF 

would be built on approximately 44 ac of land immediately north and east of the IWF near SW 

360th Streets (Figure 3-1)." The RWTF is located north and west, as illustrated on DEIS Figure 

3-1. (emphasis added) (0619-4-9 [Maher, William])

Response: The commenter is correct. Text and references in Sections 2.4.2 and 4.3.2 were 

revised to reflect these clarifying comments describing the location of the reclaimed water 

treatment facility. 

Comment: Their construction will improve the environment and ensure the future of the 

manatee habitat, this helping preserve the manatees. (0707-2 [Pheil, Edward])

Comment: They reduce C02 emmissions reducing ocean acidification damage to the ocean 

environment. (0707-4 [Pheil, Edward])

Response: These comments express general support for the construction and operation of 

Units 6 and 7 at the Turkey Point site. No changes were made to the EIS as a result of these 

comments. 

Comment: Climate Change and Drought impacts: As noted by NRC, climate-related changes 

include increased frequency and intensity of extreme weather, e.g., heavy downpours, floods, 

and droughts (Section 2.9.2, p. 2-208). For example, the drought of 2006 lowered the level of 

Lake Okeechobee to an all-time record of 8.82 foot mean sea level (Section 9.3.2.4, p. 9-70). 

Droughts and water shortages have the potential to increase in severity and frequency as the 

water demand increases in south Florida, independent of climate change effects. A minimum of 

one severe drought every decade can be expected. [Footnote 6: Droughts and Water Shortages 

in Central and South Florida (September 2001) SFWMD Technical Paper EMA #396 available 

at http://www.sfwmd.gov/portal/page/portal/pg_grp_tech__pubs/portlet_tech__pubs/ema396.pdf]. Ninety percent of South Florida has been designated as a water resource caution 

area. [Footnote 7: Florida Water Management and Adaptation in the Face of Climate Change: A 

White Paper On Climate Change And Florida's Water Resources November 2011, available at 

http://floridaclimate.org/docslwater_managment.pdf] These are areas that have critical water 

supply problems, or are projected to have these problems in the next 20 years. Chapter 62-40, 

F.A.C. requires reuse within these designated areas. Florida currently uses more reclaimed 

water (43 percent of wastewater) than any other state. Recommendations: EPA has concerns 

regarding estuary and habitat impacts related to lengthy periods of droughts. In particular, the 

potential for increased salinity in existing brackish water habitats should be evaluated. Due to 

the proximity of saline, hypersaline and seawater in the area, measures to prevent increasing 

salinity should be addressed; in particular, brackish water species and habitat protection 

measures should be fully evaluated with regard to the project's impacts and potential future 

climate conditions. (0617-4-7 [Mueller, Heinz J.])

Response: The commenter expresses concern regarding the effects of climate change and the 

potential for subsequent effects on aquatic species and habitats in the context of these changes 

during operation of Units 6 and 7. Appendix I of the EIS describes the potential for climate 

changes, to include drought, sea-level rise, temperature increases, and changes in precipitation 

intensity and frequency. Section I.3.2 in Appendix I assesses the potential for adverse effects to 

water quality and on other water uses in the area during operation from climate 

changes. Section I.3.4 in Appendix I assesses the potential for adverse effects to aquatic 

species and habitats during operation from climate change. The staff found that operation of 

Appendix E NUREG–2176 E-286 October 2016
Units 6 and 7 would have a minimal influence on the effects of climate change on Biscayne 

Bay. No changes were made to the EIS as a result of this comment. 

Comment: Threatened and Endangered Species. The DEIS summarizes the NRC's 

coordination with the U.S. Fish and Wildlife Service (FWS) and state wildlife agencies in Florida. 

Mitigation measures include protocols and requirements for protecting the American crocodile, 

Smalltooth Sawfish, Nassau Grouper, manatees and sea turtles. However, unavoidable adverse 

impacts would include permanent loss of some onsite aquatic environments, and some 

disturbance of aquatic environments and potential disturbance of species. Also, there would be 

habitat loss and land adversely affected for resident American crocodiles (page 2-122 and Table 

4-10). Recommendations: The EPA defers to the FWS and the State wildlife agencies on 

these issues and agrees that the FEIS should provide updated information. Impacts should be 

avoided to the maximum extent feasible, and unavoidable impacts should be mitigated.

(0617-1-27 [Mueller, Heinz J.])

Comment: This plant will have negative impacts on endangered species. A number of 

endangered species live near the Turkey Point Nuclear Power Plant. These include a number of 

endangered wading birds, the American Alligator and the American Crocodile. The surrounding 

canals have been found to be overheated and on one occasion an American Crocodile was 

found dead. (0641-7 [Martin, Drew])

Response: The staff agree that impacts on threatened and endangered species should be 

avoided or minimized to the maximum extent feasible, and unavoidable impacts should be 

mitigated. Evaluation of effects on protected species such as the Smalltooth Sawfish, Nassau 

Grouper, and sea turtles are presented in a BA as part of ESA Section 7 consultation with the 

NMFS, and with the FWS for the American crocodile, birds, and manatees. Updated 

information about the status of the consultations, anticipated impacts, and mitigation related to 

the results of consultation is presented in Sections 4.3.2 and 5.3.2 of the EIS. 

Comment: Risks to Threatened and Endangered Species in Biscayne Bay[.] An additional area 

of concern is how project-related changes to water quality might affect threatened and 

endangered species that are found within Biscayne NP. Because there is much uncertainty 

about exactly what environmental changes could occur as a result of the proposed project, 

further investigation is needed to better elucidate potential negative impacts to imperiled 

species. For example, it is currently unknown if the proposed expansion will result in substantial 

changes to the water quality and/or temperature of water in Biscayne Bay in the vicinity of the 

cooling canals. It is possible that alterations to water quality and/or temperature could affect the 

relative incident and prevalence of Fibropapillomatosis (FP), a tumor-forming disease linked to a 

herpesvirus that is often lethal for juvenile sea turtles, particularly green sea turtles (Chelonia 

mydas). Eutrophication and increased temperatures have been implicated in triggering the 

emergence of FP tumors. Similarly, the endangered smalltooth sawfish (Pristis pecinata) is a 

benthic-dwelling species that could feasibly be affected by groundwater seepage from the plant. 

Comparable concerns also exist for manatees (Trichechus manatus), which are known to 

populate the southwest part of the bay (southeast cooling canals and associated external 

canals) during the winter. The potential impacts of activities at the plant need to be considered 

as part of a bigger picture, as there is concern that project-related effects could exacerbate the 

effects of other stressors present in the system and not related to Turkey Point. (0622-1-26

[Austin, Stan])

Response: Water quality effects on protected sea turtles, Smalltooth Sawfish, and manatees, 

including known diseases such as fibropapillomatosis, from construction and operation were 

Appendix E October 2016 E-287 NUREG–2176
assessed in a BA as part of ESA Section 7 consultation with the NMFS and FWS. Updated 

information about the result of consultation is presented in Sections 4.3.2 and 5.3.2 of the 

EIS. Section 7.3.2 of the EIS describes the cumulative effects of stressors on aquatic resources 

within the described region. In Sections 4.2 and 5.2, the staff has determined that construction 

and operation of Units 6 and 7 at Turkey Point would not noticeably alter water quality or 

temperature in Biscayne Bay, and therefore the staff determined that no adverse effects on 

protected aquatic species would occur due to changes in water quality and temperature. No 

changes were made to the EIS with regard to cumulative effects as a result of this comment. 

Comment: Draft EIS also does not take in to account the Miami-Dade County Manatee 

Protection Plan and it could very well be in conflict. (0721-5-7 [Mendez, Victoria])

Response: Sections 4.3.2 and 5.3.2 of the EIS describe the applicant's manatee protection 

plan, which is consistent with FFWCC requirements. The effects of construction and operation 

on the Florida manatee were assessed in a BA as part of ESA Section 7 consultation with the 

FWS. Updated information about the result of consultation is presented in Sections 4.3.3 and 

5.3.2 of the EIS, which includes conditions for monitoring manatees under FDEP manatee 

conditions for in-water work. 

Comment: In Revision 1 of the "FPL Turkey Point Units 6 & 7 Threatened and Endangered 

Species Evaluation and Management Plan", DEIS reference, (FPL 2011-TN1283), FPL updated 

the plan to incorporate the final location of the Reclaimed Wastewater-Treatment Facility 

(RWTF), revising the number of wildlife underpasses from 4 to 3. There remain instances in 

the DEIS where the wildlife underpasses were not updated. Instances in the DEIS include 

(emphasis added): a. DEIS Subsection 4.3.2.1, Page 4-82, Lines 17-22: The DEIS states: "To 

mitigate the hazards associated with the increased traffic...FPL is proposing to install a system 

of wildlife underpasses to allow crocodiles to move safely under the primary access road...and 

associated freshwater ponds on the berms to the north, including the area known as the moat." 

As illustrated in DEIS Section 3.1, page 3-3, Figure 3-1, the moat is the location of the RWTF, 

underpasses are no longer proposed at that location. b. DEIS Subsection 4.3.2.3, Page 4-94, 

Lines 13-16 and DEIS Subsection 4.3.2.5, Page 4-98, Lines 23-26: The DEIS (Subsection 

4.3.2.3) states: "As described in its 2009 Threatened and Endangered Species Evaluation and 

Management Plan, FPL has proposed to install three wildlife underpasses on the road 

between the northern end of the IWF and test canals to the west of the IWF to mitigate 

collision hazards (FPL 2010-TN170)." Similarly, the DEIS states (4.3.2.5): "To mitigate hazards 

related to vehicle collision, FPL...proposed a series of wildlife underpasses on the road between 

the northern end of the IWF and test canals to the west of the IWF (FPL 2014-TN4058; FPL 

2010-TN170)." Additionally, with respect to the location of the test canals, ER Subsection 

4.3.1.1.4 states: "The FPL reclaimed water treatment facility would be built on a parcel by the 

test canals...(immediately north of the industrial wastewater facility)." (0619-1-16 [Maher, 

William])

Comment: DEIS Subsection 4.3.2.3, Page 4-93, Lines 39-41: The DEIS states: "The 

American crocodile is currently listed as Federally endangered and State threatened..." As 

of 2007, the American crocodile is Federally threatened. As of 2010, all Federally listed 

species that occur in Florida are now included on Florida's list as Federally-designated 

Endangered or Federally-designated Threatened species. (emphasis added) (0619-4-10 [Maher, 

William])

Comment: DEIS Subsection 4.3.2.3, Page 4-95, Lines 5-7 and DEIS Subsection 4.3.2.5, Page 

4-98, Lines 16-17: The DEIS (Subsection 4.3.2.3) states: "As shown in Figures 2-30 and 2-31, 

Appendix E NUREG–2176 E-288 October 2016
surveys conducted by FPL from 1978 to 2013 have shown that only a few nests have been 

observed in areas where muck disposal would occur." Additionally, the DEIS (Subsection 

4.3.2.5) states: "Nests have also been documented along the IWF Grand Canal where muck 

disposal is planned." Reference should be to DEIS Figure 2-31, "Locations of Crocodile Nests 

in the Turkey Point IWF, 1978-2010", and DEIS Figure 2-31, "Locations of Crocodile Nests in 

the Turkey Point IWF, 2011-2013." Additionally, neither figure shows nests located upon the 

spoils disposal areas. (emphasis added) (0619-4-11 [Maher, William])

Response: The commenters suggested changes are correct. Text in Section 4.3.2 was 

revised to reflect these comments. The new and corrected information does not alter the staff’s 

conclusions of impact. 

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Appendix F-4, Section 2.0, 

Page 2-1, Lines 30-33 "FPL's application states that preconstruction activities, which include 

activities the USACE denotes as "construction," are expected to occur for 60 months and 

construction activities, as defined by the NRC...to occur for 66 months (FPL 2014-TN4058)." ER 

Subsection 1.1.2.7 ER Section 3.9 ER Table 3.9-1 "No site preparation activities would 

occur...and the required U.S. Army Corps of Engineers permits are obtained. The project 

schedule assumes a 69-month duration for preconstruction activities." (ER Section 3.9 and 

Table 3.9-1 also indicate a 69-month duration for preconstruction activities.) (0619-2-29 [Maher, 

William])

Comment: DEIS Appendix F-2, Subsection 3.2.1, Page 3-11, Table 3-1 and Appendix F-3, 

Subsection 4.2.1, Page 4-7, Table 4-1: The following inconsistencies were identified in 

comparing USFWS BA Table 3-1 and DEIS Table 5-1 on page 5-11. a. The listed concentration 

for "Triclosan" in USFWS BA Table 3-1 and NMFS BA Table 4-1 differs from the concentration 

for the same chemical; in the referenced DEIS Subsection 5.2.1.1, Table 5-1, page 5-11. b. 

"Ciprofloxacin" in USFWS BA Table 3-1 and NMFS BA Table 4-1 is not listed in the referenced 

DEIS table, Subsection 5.2.1.1, Table 5-1, page 5-11. c. The header for the values reads 

"Annual Average Drift - Deposition Rates"; however, the units are shown as (g/m2-month) in 

USFWS BA Table 3-1 and NMFS BA Table 4-1. (emphasis added) d. Estimated values in 

USFWS BA Table 3-1 and NMFS BA Table 4-1 for "HHCB" and "Phenanthrene" differs from the 

values in the referenced DEIS Subsection 5.2.1.1, Table 5-1, page 5-11. (0619-6-12 [Maher, 

William])

Comment: DEIS Appendix F-2, Section 4.10, Pages 4-9 through 4-12, Lines 17-20 (for text 

inconsistencies): USFWS BA states: "Recent crocodile monitoring data provided by FPL from 

2000 to 2012 are summarized in Table 4-1. The number of successful nests observed from 

2000 to 2012 has ranged from a low of 14 in 2001 to a high of 28 in 2008; the number of 

hatchlings captured has ranged from 134 in 2004 to 548 in 2009." Table 4-1 also includes 2013

data. Also, Figure 4-4 is entitled "Crocodile Nests Observed in 2011 and 2012: The nests shown 

in this figure do not match the nests shown for the same time period in the FPL Annual 

American Crocodile Report for 2011 and for 2012. Figure 4-4 also includes 2013 data. USFWS 

BA Figure 4.4 is consistent with the DEIS Figure 2-32. (emphasis added) (0619-6-14 [Maher, 

William])

Comment: DEIS Appendix F-4, Subsection 2.3.1, Page 2-8, Lines 28-29 and Appendix F-4, 

Subsection 5.1.1, Page 5-2, Line 15-16: NMFS EFH (Subsection 2.3.1) states, "The RWTF 

would be located west of the proposed units..." Similar language is found in Appendix F-4 

(Subsection 5.1.1). However, NMFS EFH Figure 2-2 shows the RWTF will be located 

northwest of the proposed units. (emphasis added) (0619-7-10 [Maher, William])

Appendix E October 2016 E-289 NUREG–2176
Comment: DEIS Appendix F-4, Subsection 2.3.2, Page 2-9, Line 5: NMFS EFH states, "The 

maximum saltwater makeup-water rate under normal operating conditions would be 

approximately 43,200 gpm, assuming 1.5 cycles of concentration in the cooling towers." ER 

Subsection 3.4.1.1.1 states, "The maximum saltwater makeup rate to the circulating water 

system would be approximately 43,200 gpm per unit." (emphasis added) (0619-7-11 [Maher, 

William])

Comment: DEIS Appendix F-2, Section 6.1, Page 6-2, Lines 20-22: USFWS BA states: "As 

previously noted, this sanctuary would be located south and west of the existing IWF in an 

area adjacent to the Sea Dade Canal (FPL 2012-TN1618)." Turkey Point Units 6 & 7, 

Transmittal of Federal Biological Assessment for Six Listed Species dated November 2012, 

DEIS reference (FPL 2012-TN1618), Subsection 6.2.1.5 "Units 6 & 7 Crocodile Conservation 

and Monitoring Plan", page 77 states: "...and construction of an additional crocodile nesting and 

foraging sanctuary (Sea Dade Canal Crocodile Sanctuary) south of the industrial wastewater 

facility within the EMB." (emphasis added) (0619-7-3 [Maher, William])

Comment: DEIS Appendix F-2, Section 6.1, Page 6-2, Lines 26-28, 31: USFWS BA states: 

"FPL predicted that the increase in capacity derived from the NRC-approved uprate of Units 3 

and 4 (77 FR 20059) (TN1001) would increase water temperatures within the cooling canals by 

2°F and increase salinity by 2-3 ppt (FPL 2014-TN4058)." ER Section 5.11.2.1, states: "The 

uprated Units 3 & 4 would have an increased thermal discharge into the cooling canals of a 

maximum of 2.5°F and would increase salinity by 6 percent." Two different temperatures are 

referred to—one within the cooling canals and one for the discharge into the cooling canals. 

(emphasis added) (0619-7-4 [Maher, William])

Comment: DEIS Appendix F-3, Subsection 3.1.1.2, Page 3-6, Line 14-16: NMFS BA states, 

"These pipelines would be routed from the Turkey Point peninsula along the existing berm east 

of the plant area, and be situated above ground (Figure 3-3)." ER Subsection 3.9.1.7 states: 

"The pipelines from the radial collector wells would require excavation on the Turkey Point 

peninsula and the existing berm east of the plant area, but would be above ground on the 

plant area." (emphasis added) (0619-7-6 [Maher, William])

Comment: DEIS Appendix F-3, Subsection 4.1.2.2, Page 4-4, Lines 15-19 and Appendix F-4, 

Section 5.3, Page 5-6, Lines 24-26: NFMS BA states, "the current deliveries will likely decrease 

significantly, but during the 6-year construction period, approximately 80 additional deliveries 

of construction equipment and modules would occur (FPL 2014-TN4058)." Similar 

language is found in Appendix F-4. ER Subsection 4.3.2.2.1 states: "The number of weekly 

shipments of fuel oil would not be expected to change; however, during the 6-year construction 

period, there would be approximately 80 additional barge trips for delivery of construction 

equipment and modules per unit." (emphasis added) (0619-7-7 [Maher, William])

Comment: DEIS Appendix F-3, Subsection 4.2.1, Page 4-6, Lines 31-33: NMFS BA states 

"With the exception of TDS, calculated depositional rates were very low, ranging from 7.5 x 10-10

to 2 x 10-7 g/m2-month." NMFS BA calculated depositional rates in Table 4-1 range from 3.5 x 

10-10 to 8.4 x 10-7 g/m2-month. (emphasis added) (0619-7-8 [Maher, William])

Comment: There are instances in DEIS Appendix F-3 that describe the possible impacts to 

aquatic species through impingement and entrainment if flow pathways occur through fracturing. 

For example DEIS Appendix F-3, Page 4-87, Line 5 states: "Operation of the RCW system to 

supply cooling water to proposed Units 6 and 7 could affect aquatic T&E species or their prey 

through impingement or entrainment if preferential flow pathways through the limestone above 

Appendix E NUREG–2176 E-290 October 2016
the well lateral occur through fracturing (i.e., frac-out)..." However, Conditions of Certification 

require a reverse-flow scenario that will maintain control of the drilling water within the 

drill bore and within the caisson minimizing the potential for frac-outs. "Should fracturing 

occur...FPL shall mitigate for adverse impacts to Biscayne Bay Aquatic Preserve and its aquatic 

resources that have been caused by the fracturing event." (emphasis added) Instances in the 

DEIS include: a. DEIS Appendix F-3, Subsection 4.2.2, Page 4-7, Lines 5-9 b. DEIS Appendix 

F-3, Subsection 4.2.2, Page 4-8, Lines 17-20 c. DEIS Appendix F-3, Subsection 4.2.2, Page 4-

9, Lines 29-32 (0619-7-9 [Maher, William])

Response: The commenter is correct; the described inaccuracies occur in the BAs submitted 

to the FWS and NMFS as part of ESA Section 7 consultation and the EFH assessment 

submitted to NMFS as part of ESA consultation between the NRC, USACE, and the FWS and 

NMFS. No changes were made to submitted consultation as result of these 

comments. Discussions and correspondence with the services since issuance of the BAs have 

kept them informed of changes, new analyses, and inaccuracies associated with the 

consultations. The new and corrected information does not alter the staff’s conclusions of 

impact. Sections 4.3.2 and 5.3.2 were revised to reflect updated consultation status. 

Comment: The current status of American Crocodiles within Biscayne Bay and nearby areas of 

South Florida is well below restoration targets set by CERP. The overall crocodilian indicator 

status for American crocodiles within Biscayne Bay dropped from "yellow" in 2012 to "red" in 

2014. Given recent information on the declining trends of crocodilians within Biscayne Bay and 

other areas of South Florida (see Brandt et al. 2014), potential impacts to American crocodiles 

of the proposed project need to be better assessed, and NPS recommends that local 

populations be monitored either through establishment of a new program or through funding 

continuation of existing work. Potential impacts of the proposed activity on population sizes, 

growth rates, hatchling survival rates, and body condition for American crocodiles within 

Biscayne Bay must be better understood. [Footnote 5: Brandt, L.A., J. Beauchamp, M. Cherkiss, 

A. Clark, R.F. Doren, P. Frederick, E. Gaiser, D. Gawlik, S. Geiger, L. Glenn, E. Hardy, A. 

Huebner, R. Johnson, K. Hart, C. Kelble, S. Kelly, K. Kotun, J. Lorenz, C. Madden, F. J. 

Mazzotti, L. Rodgers, A. Rodusky, D. Rudnick, B. Sharfstein, R. Sobszak, J. Trexler, A. Volety, 

2014. System-wide Indicators for Everglades Restoration. 2014 Report. Unpublished Technical 

Report.] 

The NPS encourages the NRC to clarify in revisions to the DEIS that crocodiles utilize Biscayne 

Bay and thus move in and out of Biscayne NP. Section 5.3.2 discusses variations in salinity 

from the pumping of the RCW and mentions there was a transient increase near two practical 

salinity units (psu). The EIS should clarify whether those areas included critical habitat for the 

American crocodile. Additionally, the 2014 report for the System-wide Ecological Indicators for 

Everglades Restoration states that Biscayne Bay has moved into the red (highest concern) 

ranking (down from yellow in previous years), and system-wide survival of hatchlings beyond 6 

months old is less than 3%. This downward trend is disturbing and should be considered when 

analyzing direct and cumulative impacts on crocodiles from this project. (0622-2-3 [Austin, Stan])

Response: The NRC Staff acknowledges the concern about habitat requirements for the 

protected American crocodile. Direct and cumulative effects from construction and operation of 

new Units 6 and 7 on the American crocodile were assessed in a BA as part of ESA Section 7 

consultation with the FWS. Updated information regarding anticipated impacts and mitigation 

related to protected species was communicated with the Services and is presented in Sections 

4.3.2 and 5.3.2 of the EIS. Updated information about the status of consultations is presented 

in Sections 4.3.2, 5.3.2, and 7.3.2 of the EIS. 

Appendix E October 2016 E-291 NUREG–2176
Comment: AMERICAN CROCODILES AND DESIGNATED CRITICAL HABITAT. Appendix F 

Section 5.10 describes 270 acres of permanent loss of federally designated critical habitat for 

the American crocodile as a result of wetlands and surface waters that would be directly 

destroyed by the project and 211 acres of additional critical habitat that would be adversely 

affected for resident crocodiles. These impacts are being characterized in the DEIS as 

"unavoidable". In addition, at least one crocodile has already been killed by the project during 

construction of the first deep injection well for the Units 6 and 7 project according to the DEIS. 

Please clarify whether the USFWS has considered the cumulative impacts of this project in 

addition to the continuing degradation of adjacent critical habitat in and adjacent to the cooling 

canal system as temperatures and pollutant loads increase due to operation of Units 3 and 4. 

Please be advised that MDC has issued land use approvals (Z-56-07) for this project that 

include consultation conditions between FPL, the USFWS and Miami-Dade County for this issue 

and this informal consultation was initiated. At the time, FPL agreed to the establishment of 

development setbacks to prevent both direct and indirect impacts to crocodile habitat and these 

requirements are included within the land use approval. Has the NRC's analysis indicated any 

development setbacks that could reduce the acreage of impact to designated critical habitat for 

the crocodile? Have any other mitigation measures (beyond that proposed by the applicant) 

been identified through this review process, either by the NRC or USFWS to reduce these 

"unavoidable impacts"? An analysis of the cumulative impacts of the proposed project combined 

with the continuing degradation of adjacent critical habitat in and adjacent to the cooling canal 

system as temperatures and pollutant loads increase due to Units 3 and 4 is needed as part of 

this effort. MDC also requests information and clarification on the following issues: As part of the 

review for the American crocodile, have the cumulative impacts to areas adjacent to the cooling 

canals been considered including the continuing degradation of water quality throughout the 

cooling canals? For example, we understand that the USFWS has concurred with FPL that the 

water quality in the CCS surface water has become inappropriate for release of crocodile 

hatchlings due to increased salinity and temperature, and therefore all hatchlings last year were 

relocated to areas outside the cooling canals. Please confirm if our understanding is correct. 

Has the ongoing monitoring data on the adult crocodiles within this area been examined to 

determine whether there is any indication that the overall health of the adults may be decreasing 

or if their numbers are decreasing? Has the NRC or FWS considered the indirect as well as 

cumulative impacts to the crocodile mitigation area that was required by the Army Corps for the 

unit 5 project? Should the degradation or loss of this habitat require mitigation since it was 

previously required as a regulatory action? Pursuant to Condition 2 of Z-56-07, Miami-Dade 

County's Unusual Use Zoning approval for this project, MDC requests continued coordination 

with USFWS on the issue of the American crocodile and any required management actions or 

mitigation that may be required prior to finalization of the EIS. (0110-1-6 [Hefty, Lee N.])

Response: An assessment of the cumulative effects of building and operating Turkey Point 

Units 6 and 7 and all other past, present, and reasonably foreseeable future projects on aquatic 

resources, including the American crocodile, is discussed in Section 7.3.2 of the EIS. Sections 

2.3.1 and 2.4.2 of the EIS have been revised to discuss the changes in the cooling canal system 

that have affected American crocodile habitat. The review was performed in consultation with 

the FWS as described in the BA and in accordance with Section 7 consultation requirements. If 

the FWS determines that environmental setbacks are necessary to reduce the permanent loss 

of designated critical habitat, they could be required as part of Section 7 consultation and be 

incorporated in the terms and conditions of a Biological Opinion. Such requirements would be 

determined by the FWS and are not determined by the NRC. FPL continues to work with the 

FWS on surface water quality in the cooling canals that are necessary for Turkey Point Units 3 

and 4. Improved water quality in the IWF would be beneficial to the resident crocodile 

population. Section 7.3.2 of the EIS has been updated to reflect the 2015 status of crocodile 

Appendix E NUREG–2176 E-292 October 2016
populations near the cooling canals and coordination between FWS and FPL with regard to 

water quality. The information in the comment does not alter the staff’s conclusion of impact. 

Comment: Recommendations: The FEIS should specifically and holistically describe impacts 

to the ENP, BNP and BBAP. Because these are vitally important national and regional 

resources, the NRC should individually and robustly address potential impacts, both 

construction and operational, to these public lands. 

These specific impacts for the ENP, BNP and BBAP should be separately described in the 

Affected Environment (Chapter 2), Construction Impacts at the Turkey Point Site (Chapter 4), 

Operational Impacts at the Turkey Point Site (Chapter 5), and Cumulative Impacts (Chapter 7), 

sections of the FEIS. (0617-1-32 [Mueller, Heinz J.])

Response: The commenter is concerned that impacts on Everglades National Park, Biscayne 

National Park, and the Biscayne Bay Aquatic Preserve are not described in specific subsections 

for all affected resources. The direct and indirect effects of construction and operation of Units 

6 and 7 on the National Parks and the Preserve are described in the context of the affected 

resources in Sections 4.2.2, 4.2.3, 4.3.1, 4.3.2, 5.2.2, 5.2.3, 5.3.1, 5.3.2, 7.2.1, 7.2.2, 7.3.1, and 

7.3.2 of the EIS. No changes were made to the EIS as a result of this comment. 

Comment: EPA recommends NRC and USACE develop a robust monitoring and adaptive 

management plan (in collaboration with resource agencies) to address any unforeseen future 

impacts to ENP, BNP and BBAP especially related to the potential operational impacts 

associated with the RCW. EPA recommends these commitments be reflected in the ROD.

(0617-1-33 [Mueller, Heinz J.])

Comment: FKNMS concurs with National Marine Fisheries Service comments (submitted May 

22, 2015) requesting development of a biological monitoring and adaptive management plan to 

assess ecological impacts of the project at construction, implementation, and operation phase to 

continue throughout the life of the project. FKNMS welcomes the opportunity to contribute to 

development of this plan and requests that results and outputs from any biological monitoring be 

shared with FKNMS. (0618-2 [Morton, Sean])

Comment: FKNMS conducts water quality monitoring and special studies through its longstanding Water Quality Protection Program (WQPP). Administered by the Florida Department of 

Environmental Protection and U.S. Environmental Protection Agency, the WQPP is a 

collaborative effort dedicated to protecting and improving water quality, coral reefs, seagrasses, 

fisheries and recreational opportunities within the FKNMS. The WQPP has supported and 

funded long-term research and monitoring programs that track water quality, coral reef and 

seagrass communities; results from monitoring and research studies have been instrumental in 

decision-making and in determining what actions are needed to sustain a healthy ecosystem. 

As such the WQPP could help inform the design of a water quality and biological monitoring 

program for this project that includes potential impacts to downstream aquatic ecosystems.

(0618-3 [Morton, Sean])

Comment: Need for a Biological Monitoring and Adaptive Management Plan[.] A 

biological monitoring and adaptive management plan based on ecologically relevant impacts 

should be developed, and the NMFS offers to assist development of the plan. The plan should 

be developed to measure impacts predicted from a reliable impact assessment that considers 

ecologically relevant water quality conditions and interactions between the cooling canals and 

Biscayne Bay waters. The plan should be implemented in perpetuity for the life of the RCWs 

Appendix E October 2016 E-293 NUREG–2176
and include no less than three years of baseline monitoring (pre-operation) during dry years to 

characterize the ambient conditions at the site. (0724-11 [Fay, Virginia M.])

Comment: Seagrass monitoring should also be a component of this plan. The NMFS reviewed 

the FDEP Certificate of Conditions (May 2014) containing recommendations for monitoring 

changes to the seagrass communities near the Turkey Point Nuclear Plant resulting from RCW 

operation. The NMFS believes the monitoring effort would be more efficient by incorporating 

relatively new approaches, for example using geo-spatial video-based survey techniques 

described in Lirman et al. (2008). The monitoring plan should demonstrate capability in 

detecting the level of biological change that constitutes an adverse effect to seagrass and 

fishery resources in Biscayne Bay. The sampling plan should be supported by a power analysis 

to demonstrate the sampling proposed is sufficient to detect the expected impacts. (0724-13

[Fay, Virginia M.])

Comment: One way to efficiently accomplish developing the biological monitoring and adaptive 

management plan would be to establish and interagency team to contribute to the development 

of the plan. Ideally, the team should be composed of staff from the NMFS, NPS, NRC, USACE, 

U.S. Environmental Protection Agency (EPA), U.S. Fish and Wildlife Service, FDEP, Florida 

Fish and Wildlife Commission, Miami-Dade Department of Environmental Resources 

Management, South Florida Water Management District, and FPL. The final plan implemented 

should reflect substantial input from this team. The NMFS, National Park Service, and others 

are currently planning to meet May 29, 2015, in Homestead to discuss this monitoring need 

(please contact Jocelyn Karazsia for additional information about this meeting, her contact 

information is at the end of this letter) (0724-14 [Fay, Virginia M.])

Response: The commenters are requesting a biological monitoring and adaptive management 

plan for aquatic resources that may be affected by construction and operation of Units 6 and 

7. The staff agree that an interagency team would be valuable to coordinate monitoring efforts 

and share data. The FDEP provides detailed monitoring requirements for assessing potential 

adverse effects on ecological resources and water quality during the construction and operation 

of the RCW system, which include a 2-year period of pre-construction monitoring (State of 

Florida 2014-TN3637). The USACE would also provide special conditions regarding any 

monitoring and mitigation for USACE authorized activities in accordance with 33 CFR 320.4 for 

compliance with Federal and state wildlife provisions and for water quality standards under the 

Clean Water Act if Department of the Army permit is issued. Additional clarifying text has been 

added to Sections 4.3.2 and 5.3.2 of the EIS to provide more detail concerning surface water 

and biological monitoring and mitigation requirements as provided in the FDEP COCs. 

Comment: The DEIS also fails to provide sufficient information about current species diversity, 

abundance, and habitat utilization in the vicinity of proposed radial collector wells and therefore 

fails to complete a full and adequate analysis of the impacts of the wells to the Biscayne Bay 

ecosystem. This data is necessary to determine the ways in which disruptions to the salinity 

regime caused by the radial collector wells will impact Biscayne National Park, wildlife species, 

and their habitats. The DEIS does not contain comprehensive biological studies on wildlife 

utilization, plant cover, and species in the area adjacent to the radial collector wells. (0113-1-18

[Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: Furthermore, a baseline survey of benthic fauna and seagrass cover has not been 

conducted near the location of the radial collector wells. Seagrasses can be particularly 

sensitive to changes in salinity and water quality and benthic habitat could be impacted by the 

radial collector wells. [Footnote 20: South Florida Water Management District, Second 

Appendix E NUREG–2176 E-294 October 2016
Completeness Review, FPL Turkey Point Units 6 & 7, Site Certification Application, Power Plant 

& Associated Facilities, January 2, 2010, 3.] The DEIS cannot fully consider the potential 

impacts of the wells on wildlife resulting from the disruption of salinity regimes without providing 

comprehensive surveys and studies of the flora and fauna within the bay, particularly in areas 

near the radial collector wells. Without providing this data, the DEIS fails to establish an 

environmental baseline by which to evaluate impacts and alternatives. (0113-1-19 [Lopez, Jaclyn] 

[McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: Barge unloading facility. To support construction activities, the equipment barge 

unloading area, located at the northeastern portion of the Turkey Point Power Plant site, will be 

enlarged by 0.75 acres. This activity will require the dredging of approximately 0.1 acre of 

marine bottoms in the turning basin, and the installation of sheet piling to support building 

activities. Surveys conducted in 2008 indicate that at least some seagrasses occur in the area 

to be affected. We recommend that FPL resurvey the area to be affected to determine the 

extent of seagrasses and provide mitigation for the loss of these valuable marine resources.

(0227-11 [Stanley, Joyce])

Comment: Further, the proposed project would impact submerged aquatic vegetation (SAV), 

which includes Ruppia maritima, Thalassia testudinum, and Halodule wrightii. Fin and shell fish 

commonly associated with this species include Florida crawfish, stone crab, blue crab, penaeid 

shrimp, sea trout, gray snapper, red drum, pinfish, mullet, and flounder. Moreover, SAV 

provides attachment sites for periphyton which in turn increases food value for the base of 

marine and estuarine food webs. SAV aids in stabilizing the shallow water submerged land 

which promotes water quality. SAV also performs important nutrient uptake functions, which 

assist in the maintenance of water quality. For these reasons, the EPA also considers SAV to 

be ARNI. (0617-1-11 [Mueller, Heinz J.])

Comment: EPA understands that a benthic survey has not been completed at the FPL Turkey 

Point site for some years. In order to evaluate the proposed project, the FEIS should include a 

colored copy benthic survey of the boat basin, radial collector well locations, and the Units 6 & 7 

site. The benthic survey should extend a radius of 50 feet around submerged lands of these 

locations. The benthic survey should include a description of the protocol used to complete the 

survey, sampling dates, and a map that illustrates the density and location of each SAV found at 

the site. The seagrass survey should be conducted between the months of June and September 

to ensure the survey is conducted during the active growing season. The benthic survey is 

necessary for the EPA to determine extent of SAV impacts that will occur by the proposed 

project. (0617-1-12 [Mueller, Heinz J.])

Comment: Equipment Barge Unloading Area[.] The existing barge-unloading facility would be 

enlarged to accommodate the larger barges used to deliver components for the proposed units. 

According to the DEIS, "approximately 90 ft. by 150 ft. would be excavated on the northwest 

edge of the existing barge-turning basin resulting in a total disturbed area of 130 ft. by 250 ft. or 

0.75 ac ... The expansion of the barge-unloading facility would require dredging a 4,356 ft2 (0.1 

ac) area in the turning basin." A survey from 2008 indicated that some seagrasses are found in 

the project area. The NPS recommends that the area be resurveyed to enable more accurate 

estimation of potential impacts to submerged aquatic vegetation. The NPS suggests that 

USACE consider supporting NPS restoration of "orphan" vessel grounding injuries in Biscayne 

NP sea grass habitat to offset dredging impacts. Some progress has been made, but much 

more work remains. We contend that orphan site restoration will help support the integrity of the 

seagrass ecosystem, which in tum supports manatees, sea turtles, critical habitat, economically 

important fisheries, and other marine life. (0622-2-11 [Austin, Stan])

Appendix E October 2016 E-295 NUREG–2176
Comment: Equipment Barge Canal Expansion 

The equipment-barge uploading area at the northeastern portion of the Turkey Point Nuclear 

Facility would be expanded by dredging 0.75 acres of estuarine bottom, including 0.10 acres of 

seagrass habitat, to support construction activities. The NRC and FPL propose use of turbidity 

curtains to limit water quality degradation caused by dredging. The EFH assessment states the 

basin contains sparse growth of seagrass and macroalgae. The NMFS requests the final EIS 

and EFH assessment include a more detailed habitat characterization and compensatory 

mitigation to offset the seagrass impacts. (0724-3 [Fay, Virginia M.])

Response: The commenters are requesting additional ecological characterization of nearshore 

aquatic resources associated with the barge unloading and the RCW areas. Section 2.4.2 of 

the EIS has been modified to provide additional ecological baseline information for the barge 

unloading area and the nearshore area surrounding the RCW location, and include seagrass 

locations and density. Sections 4.3.2 and 5.3.2 of the EIS have been revised to provide 

additional context for the construction and operation impacts at the barge unloading area, and 

include experimental results to support assessment of RCW effects on seagrass and other 

aquatic resources. State of Florida required monitoring and surveys for seagrass and marine 

organisms are also included in Sections 4.3.2 and 5.3.2. The additional information does not 

change the impact determination that the effects to aquatic resources in these locations from 

dredging and RCW installation and operation are minor. 

Comment: Comment 2. The DEIS is incomplete because it does not evaluate possible 

harm to the ecosystem of Biscayne Bay if the hypersaline plume under the cooling 

canals is forced into the bay by pumping from the radial collector wells - The DEIS 

indicates that intermittent pumping, as proposed in the DEIS, could displace the hypersaline 

plume into the path of fresh water flowing eastward: "Intermittent operation could result in an 

increase of hypersaline flow into the aquifer beneath the bay that could migrate into the bay 

when the RCW is not operating." [DEIS p. G-29] Emergence of hypersaline water into Biscayne 

Bay could result in localized hypersalinity that would kill sea grass beds in Biscayne National 

Park, as happened during periods of hypersalinity in Florida Bay in the early 1990s (e.g., 

Zieman et al. 1999); those areas of Everglades National Park have not fully recovered. The 

final EIS must note possible harm to Biscayne National Park ecosystem if hypersaline 

plume is relocated into Biscayne Bay. (0106-5 [Stoddard, Philip K.])

Comment: Everglades National Park. Biscayne National Park and Biscayne Bav Aquatic 

Preserve. The EPA is concerned about the proposed project's potential impacts to the 

Everglades National Park (ENP), Biscayne National Park (BNP) and Biscayne Bay Aquatic 

Preserve (BBAP). Turkey Point is in close proximity to both the BNP and BBAP. In the Affected 

Environment section of the DEIS (pages 2-10 -2-13), the NRC recognizes the unique 

characteristics of the ENP, BNP and BBAP, and that many of these waters are listed as 

Outstanding Florida Waters. Although the DEIS generally addresses some of the issues facing 

these national and state protected lands, the DEIS does not specifically address potential 

impacts facing these fragile and vital resources. EPA is concerned that the radial collector wells 

(RCWs) could impact the hydrology of BNP, and potentially impact tidal cycles and inflow of 

freshwater towards the national parks and the aquatic preserve. The FEIS should clarify 

whether there will be pre and/or post construction monitoring to ensure that the RCWs are not 

impacting the ENP, BNP and BBAP. EPA is concerned that the proposed projects' additional 

wastewater discharges to the IWF could contribute to increased salinity in the underlying 

Biscayne Aquifer, and increase the salinity and nutrient loading to BNP and BBAP. (0617-1-24

[Mueller, Heinz J.])

Appendix E NUREG–2176 E-296 October 2016
Comment: If the proposed action needed to rely on the radial wells as the primary source of 

cooling water for extended periods during the project's projected life, the impacts to the near 

shore aquatic ecosystems should be assessed. Impacts of concern include how the volume of 

water required for cooling purposes and drawn from Biscayne Bay may potentially affect the 

salinity levels of the near shore Biscayne Bay, and the associated aquatic ecosystem. (0617-4-8

[Mueller, Heinz J.])

Comment: Overall, the NRC provided an initial determination that construction and operation 

of the RCWs, 105 acres of mangrove impact, and 0.10 acres of seagrass impact, located within 

or adjacent to the Biscayne Bay Aquatic Preserve and designated Habitat Areas of Particular 

Concern (HAPCs) by the South Atlantic Fishery Management Council, would not result in an 

adverse impact on EFH or federally managed fishery species. The NRC provides individual 

determinations on the effects of six actions or activities on mangrove, seagrass, and 

unconsolidated bottom habitats in the EFH assessment (Table 1). As described further below, 

the NMFS disagrees with these determinations and concludes the proposed dredging and 

operation of the RCWs would result in adverse impacts to seagrass or mangroves. In particular, 

the RCW operation could alter nearshore water quality resulting in hypersalinity and 

hyperthermal conditions impacting additional seagrass and fishery resources in the Biscayne 

Bay Aquatic Preserve. Due to the potential severity of these impacts, a biological monitoring 

and adaptive management plan is recommended to evaluate the predicted impacts of RCW 

operation relative to the actual impacts and to implement corrective actions or mitigation 

measures if environmental thresholds are reached. (0724-1 [Fay, Virginia M.])

Comment: FPL and the National Park Service, Biscayne National Park (NPS), are currently 

conducting water quality monitoring, and the NMFS recommends installing an additional four or 

five continuous water quality monitoring sites with similar equipment to assess the frequency 

duration, and intensity of hyperthermal and hypersaline events. The NMFS can assist in 

determining the location of the sites (spatially with respect to other sites and the work proposed 

and location in the water column). The water quality monitoring component of the plan should 

clearly identify the environmental thresholds requiring adaptive management and options to 

manage the operation. Because this type of monitoring generates a lot of data, an efficient plan 

to manage, analyze, and share data is also recommended. (0724-12 [Fay, Virginia M.])

Comment: Operation of the RCWs would result in hypersaline conditions and thermal events 

within estuarine habitats in Biscayne Bay known to support federally managed species. The 

severity of these effects would depend on annual rainfall levels (i.e., more severe effects are 

expected during dry years than wet years). This is of concern because hypersaline conditions 

and thermal events can be bio-energetically expensive and reduce capacity for reproduction or 

growth. Impacts to seagrass habitats and fishery resources from the RCW operation are not 

quantified in the public notice. However, the draft EIS attempts to quantify these effects based 

the modelling FPL has completed to predict the influence RCWs will have on local salinity 

regimes in Biscayne Bay (provided in the draft EIS Appendix G). The draft EIS also briefly 

describes how the recent upgrades of Turkey Point Units 3 and 4 have led to increased 

discharge temperatures within the cooling canals contributing to an extensive algal bloom (draft 

EIS, Section 7.2.2.1). Based on maps provided with the public notice, it appears the RCWs 

would collect water in the vicinity of elevated temperature discharge plumes from the cooling 

canals. (0724-9 [Fay, Virginia M.])

Response: Section 5.2.1 and Appendix G were revised to provide an updated assessment of 

groundwater and surface water connectivity and salinity changes caused by RCW 

operation. Additional information about the RCW inflow volume under State of Florida permitted 

Appendix E October 2016 E-297 NUREG–2176
conditions compared to the total tidal volume of Biscayne Bay is provided in Section 5.3.2 of the 

EIS. Additional information has been included in Section 5.3.2 of the EIS to clarify the predicted 

changes in salinity to nearshore areas and Biscayne Bay (Biscayne National Park and Biscayne 

Bay Aquatic Preserve) based on modeling from RCW operation, and support the NRC Staff's 

conclusion that no adverse effects on aquatic resources are anticipated from RCW 

operation. The State of Florida COCs require water quality and biological pre-construction 

monitoring for 2 years prior to RCW installation activities, monitoring during construction, and at 

least 2 years of operational monitoring to include the first two RCW operational events, which 

are limited by the State of Florida to not exceed 60 days per year. Monitoring would take place 

in Biscayne Bay waters surrounding the RCW location and at reference sites in accordance with 

an FDEP approved RCW System Monitoring Plan. 

Comment: American crocodile. The proposed project will result in the loss of approximately 

270 acres of designated critical habitat for the crocodile associated with the construction of 

Units 6 and 7. The project also has the potential to affect water quality in the cooling canal 

system at the Turkey Point site. The cooling canal system provides important habitat to 

crocodiles. Drift from the cooling towers from the use of reclaimed water is expected to deposit 

a small amount of chemical contaminants (e.g., 1,4-dichlorobenzene, phenanthrene, copper 

etc.) into waters of the cooling canal system, although information provided in the DEIS indicate 

that the deposition rates of these contaminants is extremely low. Additional water quality testing 

in the canal system should be considered to address these contaminants. (0227-4 [Stanley, 

Joyce])

Response: Section 5.3.2 discusses operational effects from cooling-tower drift including those 

on nearby water bodies and effects on aquatic species. A BA was submitted to the FWS to 

address effects to protected species, such as the American crocodile, through ESA Section 7 

consultation. The NRC staff agrees that additional water quality testing in the canal system 

should be considered by the State of Florida, the applicant, and FWS. No changes to the EIS 

were made as a result of this comment. 

Comment: FPL intends to store the muck removed from the project footprint on the berms 

within the cooling canal system. This practice has the potential to introduce organic matter and 

nutrients (e.g., nitrogen, phosphorus etc.), and decrease the quality of the water in the cooling 

canal system. This will undoubtedly further exacerbate the poor water quality currently 

experienced in the cooling canal system and further adversely affect the crocodile that inhabit 

the system. (0227-5 [Stanley, Joyce])

Response: Section 5.3.2 discusses the applicant’s plan to place the muck on the cooling canal 

berms. The staff does not expect the placement of muck on the canal berms to significantly 

affect water quality in the IWF or Biscayne Bay. See Section 3.2.2.3 and 4.3.2.1 for a detailed 

explanation of muck disposal. Additional information has been added to Section 5.3.2 regarding 

the placement of muck on these cooling canal berms and the potential for its effects on aquatic 

species, including the American crocodile. The information in the comment does not alter the 

staff’s conclusion of impact. 

Comment: Comment 9. The DEIS is incomplete (a) in failing to consider a complete list 

of bioactive chemicals found in the wastewater stream, (b) in failing to identify the 

bioactivity class of all chemicals listed, and (c) in failing to address additive and 

synergistic effects of those chemicals on aquatic organisms in the adjacent Biscayne 

National Park - Ecotoxicology studies show that some pollutants act in tandem to produce 

greater effects than any single chemical does at is particular concentration. Compound action 

Appendix E NUREG–2176 E-298 October 2016
can be additive or synergistic (Crews et al. 2000). Chemicals in the same class of bioactivity 

often act in an additive manner, with effects proportional to the sum of the concentrations of 

multiple chemicals (Kortenkamp 2007). For other bioactive waste products, especially chemicals 

acting on different endocrine or biochemical pathways, the combined activity of multiple 

chemicals can be synergistic, with actions greater than the sum of the constituents (e.g., Vonier 

et al. 1996; Arukwe et al. 2001). Because of additive and synergistic effects, environmental 

consequences of exposure can only be estimated by knowing the entire constituency of 

chemicals released in treated wastewater, upon what body systems they act, and how they 

interact in the organism. The DEIS does not consider or present an exhaustive list of bioactive 

chemicals in the local wastewater stream, only those quantified by one prior study (Lietz and 

Meyer 2006). One example of a chemical missing from the DEIS is triclocarban (TCC), a 

chemical common to personal hygiene products, and likewise common in municipal wastewater 

(Lozanoa et al. 2013). While TCC has no endocrine action on its own, it acts synergistically to 

enhance action of androgens (Chen et al. 2008). Projected levels of TCC are not stated in 

DEIS. Triclosan is listed in the DEIS, but methyltriclosan, also common in wastewater, is 

omitted. Since triclosan and methyltriclosan will have additive effects, the omission of one of 

these necessarily results in underestimation of the likely effects of that chemical class on 

aquatic organisms. Lietz and Meyer (2006) did not pretend to be exhaustive in their analysis of 

wastewater chemicals, however the EIS must be exhaustive in order to give us an accurate 

picture of the possible hazards to the sensitive ecosystem surrounding the nuclear plant. The 

final EIS must consider additive and synergistic bioactivity of toxins and endocrine 

disrupters released as aerosols. (0106-12 [Stoddard, Philip K.])

Comment: EPA is concerned that drift deposition could impact ENP, BNP and BBAP. The 

NRC should provide additional details regarding these impacts, and any other project impacts to 

ENP, BNP and BBAP. (0617-1-31 [Mueller, Heinz J.])

Comment: Page 5-60

Lines 14-18: The DEIS states, "When toxicological benchmarks were used, no-observed effect 

concentration (NOEC) levels were chosen for sensitive, representative aquatic species to 

provide a conservative assessment." How is sensitive defined here and how were the most 

representative aquatic species determined? For what endpoints (e.g., growth, reproductive 

success, mortality, etc.) were the NOECs selected and for what period of time (e.g., 96-h, 7d, 

etc.)? Depending on the answers to these questions, the NOECs selected may NOT provide the 

most conservative assessment. Revisions to the DEIS should include a discussion regarding 

this topic. 

Lines 21-24: The DEIS states, "For chemicals without established water-quality criteria, 

including most CECs, those present at >1/10 of a toxicological benchmark chosen by the review 

team to be protective of aquatic resources were included in the fate and effects evaluations 

(Table 5-1)." How were these toxicological benchmarks selected and what criteria were they 

based on? How were selected benchmarks determined to be protective of aquatic resources? 

Specifically, what aquatic resources were included in the above benchmark selection process? 

Revisions to the DEIS should include a discussion regarding this topic. 

This section does not discuss the impacts of contaminants on species present in the mangrove 

wetlands. This type of habitat is known to be a nursery for a multitude of fish species and two, if 

not three, of the contaminants mentioned in Table 5-1 are endocrine disruptors (EDCs). Only 

very small concentrations of EDCs are needed to cause developmental effects and potentially 

reproductive effects. (0622-1-7 [Austin, Stan])

Appendix E October 2016 E-299 NUREG–2176
Comment: Page 5-140, Table 5-24 (under Aquatic Ecosystems) states, "The use of reclaimed 

water from Miami-Dade County to operate the cooling system would not result in noticeable 

impacts on onsite and offsite aquatic resources." How was this determined? The revised DEIS 

should discuss known potential interactive effects of these chemicals not only with other 

pesticides, but also with other chemicals expected to be present from drift or other means. (See 

comments above regarding EDCs and their effects.) Revisions should include a discussion of 

the contaminants present in the reclaimed water, their environmental fate and transport and 

their potential environmental effects. (0622-1-9 [Austin, Stan])

Response: The commenters are concerned about the potential for adverse effects on aquatic 

resources from the presence of chemicals of emerging concern (CECs) that may be present in 

the cooling-tower drift. Sections 5.2.1 and 5.3.2 of the EIS provides an assessment of the 

region of potential effect for CECs. Section 5.3.2 of the EIS has an extensive discussion of the 

EPA criteria used to assess the potential toxicity or adverse effects of CECs on aquatic species 

known to be sensitive to chemical compounds and at critical life stages. Because it is not 

possible to assess every potential chemical or chemical byproduct that may be present in the 

reclaimed water source, representative and most abundant chemical compounds were provided 

for different functional chemical classes, including endocrine disrupting compounds. The use of 

No Observed Effects Concentrations (NOEC) for assessing toxicity thresholds is a widely used 

criterion in aquatic toxicology, and represents the highest concentration threshold acceptable in 

these toxicity tests for the correlated exposures. Section 5.3.2 has been expanded to 

demonstrate the overall sensitivity differences between freshwater and marine or estuarine 

species to further validate the described endpoints and species used in the assessment. One 

commenter suggests further analysis of synergistic interactions between compounds. The NRC 

staff agrees that synergistic or additive interactions may occur, but antagonist interactions are 

just as likely to occur and are supported by as many studies. Section 5.3.2 has been expanded 

to discuss environmentally relevant complex mixture interactions. The proposed high level 

disinfection and filtration of reclaimed water to be provided to the FPL water treatment plant is 

consistent with State of Florida regulations and water reuse management practices (FAC 62-

610.688). FPL would further treat the reclaimed water prior to cooling water system use, which 

would further reduce any CECs in the water, and represents additional water treatment not 

provided for other reclaimed water uses such as direct irrigation for food crops and pastures for 

livestock, recharge of groundwater, and restoration enhancement efforts. Section 5.3.2 has 

been expanded to provide context for reclaimed water use in Florida. 

Comment: Construction and Operation of RCWs[.] Construction of RCW: The draft EIS and 

EFH assessment note frac-outs may occur during the drilling needed for the RCWs; however, 

the discussion focuses only on one aspect of what constitutes a frac-out. The NRC describes a 

frac-out as one or more significant fractures of the limestone above the RCW lateral pipelines 

altering fine-scale water flows during RCW system operation potentially resulting in 

impingement or entrainment of early life stages of fishery species. It is not clear to the NMFS 

how the NRC views this impact. While the NRC notes monitoring and detecting this type of fracout and its impacts would be difficult, it goes on to conclude no adverse impacts would result 

from the entrainment or impingement of aquatic resources but later states there would be small, 

localized adverse effects. The NMFS requests the final EIS and EFH assessment clarify this 

issue. (0724-5 [Fay, Virginia M.])

Response: The commenter is concerned about the potential for adverse effects from 

installation and operation of the RCWs. Sections 4.3.2 and 5.3.2 of the EIS have been revised 

to include additional context and clarity concerning the potential for adverse effects on aquatic 

resources during installation and operation of the RCWs; the RCWs include specific installation 

Appendix E NUREG–2176 E-300 October 2016
requirements of the State of Florida (2014-TN3637) and do not use high-pressure water 

injection, thus negating any potential for a pressure induced frac-out. The information in the 

comment does not alter the staff’s conclusion of impact. 

Comment: You know, we did accidentally unearth a nest in 1977 with a backhoe, and part of 

our environmental stewardship we adopted a conservation effort from the University of Florida 

folks, Dr. Mozzotti in the International Park, and never took any money, he did it all in-house to 

monitor the crocodile population. And it steadily increased year after year. We did some 

evolving with the animals and the civil engineer and the biologists. You know, the canal system 

is an engineered supporting system for a fossil/nuclear plant. Sometimes those berms got to be 

cleared off. But also the biologists, we need to have the mangroves, we need to have some 

preservation for these to hatch some babies. And the ideas came together where we created a 

habitat. We dug out freshwater ponds when the babies were hatching so now the females, the 

nesting females won't take those babies to freshwater refugia away from these sanctuaries 

which, then, they became impregnated. So many predators, raptors, terrapins, raccoons, 

snakes, you couldn't count them. Now they're staying in the same place. And the best news 

about that, from '96 to 2006, that ten-year swath, the population went up tenfold in ten years. 

And then the State, U.S. Fish and Wildlife looked at that information and in 2007 the State of 

Florida downlisted the species from endangered to threatened. And all of us at Turkey Point 

take great pride in that accomplishment. It is the crocodiles. (0723-15-2 [Bertelson, Bob])

Response: The commenter expresses general support for the enhancement of crocodile 

habitat on FPL property. No changes were made to the EIS as a result of this comment. 

Comment: There are instances in the DEIS where, due to the timing of events with respect to 

drafting the DEIS, specified dates, or future actions, indicated in the DEIS have passed. 

Instances in the DEIS include (emphasis added):...DEIS Appendix F-2, Section 1.0, Page 1-1, 

Lines 22-25: Appendix F-2 states: "A proposed Conditions of Certification dated May 24, 2013, 

was issued to FPL authorizing construction, operation, and maintenance of Turkey Point Units 

6 and 7 and associated facilities subject to the requirements listed (FDEP 2013-TN2629)." On 

May 19, 2014, the Governor and Cabinet issued the Site Certification Order with the final

Conditions of Certification (State of Florida 2014-TN3637). d. DEIS Appendix F-2, Section 2.1, 

Page 2-4, Lines 11-12 and DEIS Appendix F-2 Subsection 3.1.3, Page 3-6, Lines 26-30: 

Appendix F-2 (Section 2.1) states: "FPL has proposed an original location and an 

alternative location for the RWTF and both are on the Turkey Point site." Similarly, USFWS 

(Section 3.1.3) states: "Land cover at the alternate location is mostly Australian pine 

established on upland spoil, canals, and ditches with some sawgrass marsh, dwarf mangroves, 

and Australian pine wetlands (FPL 2014-TN4058)." ER Section 3.9 "Preconstruction and 

Construction Activities", Figure 3.9-1 "Construction Utilization Plan", does not include the 

original location, only what used to be the called the "alternate" location. e. DEIS Appendix F-2, 

Subsection 3.1.1, Page 3-4, Lines 29-31: Appendix F-2 states with regards to dredging in the 

turning basin for the equipment barge unloading area improvement: "FPL would submit an 

application to USACE for a permit to dredge under the CWA, Section 404(b)(1) "Guidelines 

for Specification of Disposal Sites for Dredged or Fill Material" (40 CFR 230) (TN427), as 

described in ER Revision 6 (FPL 2014-TN4058)." The 404 permit application submitted to 

ACOE on June 30, 2009 includes dredging in the turning basin. f. DEIS Appendix F-2, 

Section 6.1, Page 6-2, Lines 10-11: Appendix F-2 states: "Conversion of Units 1 and 2 to 

synchronous condenser mode would reduce onsite vehicular traffic attributable to these two 

existing units." Unit 2 already operates in synchronous condenser mode as stated on Page 6-1, 

lines 19-20 of this document, which states: "In January 2013, Unit 2 was converted to operate 

in synchronous condenser mode..." (0619-1-12 [Maher, William])

Appendix E October 2016 E-301 NUREG–2176
Response: The commenter describes updates to referenced documents and processes 

described in the BA submitted to the FWS as part of ESA Section 7 consultation between the 

NRC, the USACE, and the FWS. No changes were made to submitted consultation as result of 

this comment. 

Comment: The USACE did not make an initial determination in its public notice on whether the 

impacts to 1,000 acres of wetlands, including over 100 acres of mangroves, would result in an 

adverse impact on EFH or federally managed fishery species noting the NRC is the lead federal 

agency for the EIS and is responsible for the EFH consultation. (0724-2 [Fay, Virginia M.])

Response: The commenter is correct that NRC is the lead federal agency responsible for EFH 

consultation, but the USACE is a cooperating agency. Sections 4.3.1 and 4.3.2 of the EIS have 

been revised to further describe the type of wetlands and mangroves that would be adversely 

affected by installation activities. Section 4.3.2 of the EIS has been further revised to describe 

the potential for adverse effects on aquatic habitats and species, including EFH and federally 

managed species from impacts on mangrove habitats. This additional information does not 

change the assessment of an overall SMALL impact to aquatic resources from installation 

activities. 

Comment: DEIS Section 4.11, Page 4-146, Table 4-18: In DEIS Table 4-18, in the "Aquatic 

Ecosystems" impact category, the DEIS states: "FPL would follow the guidance provided by the 

National Marine Fisheries Service (NMFS) to protect sea turtles and Smalltooth Sawfish during 

nearshore construction activities." The reference is a December 19, 2006 letter from Shelley 

Norton (NMFS) to Harriet Nash (NRC). The "Reasonable and Prudent Measures" outlined by 

NMFS represent a significant commitment for FPL. Among the documents reviewed (ER, SCA, 

RAIs), there is no record that FPL has committed to these actions. In-water work is limited to 0.1 

acres of dredging within the existing turning basin; this area will be isolated from adjacent 

waters and manatee observers will be utilized in accordance with the FWC Standard Manatee 

Conditions for In-Water Work. These protective measures would also minimize the potential for 

impact to smalltooth sawfish or sea turtles if they were to occur within the project area.

(0619-4-16 [Maher, William])

Response: The commenter is correct. Text in Table 4-17 was revised to reflect this comment. 

Comment: There are instances in DEIS Appendix F-2 that describe potential impacts to the 

American crocodile due to the location of the spoils piles. For example, the USFWS BA 

(Subsection 3.1.1) states: "Potential impacts on American crocodile include the permanent loss 

of approximately 270 ac of designated critical habitat to accommodate proposed Units 6 and 7 

and the associated infrastructure, and adverse effects to approximately 211 ac of habitat 

related to the relocation of material not suitable for reuse..." Whereas, DEIS reference, 

(FPL2012-TN1618), Section 5.1, page 5-2 states: "Areas designated for placement of spoil 

materials excavated from the Units 6 & 7 Site were specifically selected due to their lack of 

suitable nesting substrate for the American crocodile and lack of recorded crocodile nesting in 

these areas." Also, DEIS reference (FPL2011-TN1283), Section 7.2.1 "American Crocodile", 

page 59 states: "These spoils areas do not contain suitable nesting habitat, nor do they contain 

any freshwater refugia for juvenile crocodiles; therefore, no adverse impacts to the breeding 

population are anticipated." (emphasis added) Instances in the DEIS Appendix F-2 include: a. 

DEIS Appendix F-2, Subsection 3.1.1, Page 3-4, Lines 1-6. b. DEIS Appendix F-2, Section 5.10, 

Page 5-6, Lines 29-32. c. DEIS Appendix F-2, Subsection 5.10.2, Page 5-7, Lines 42-43. d. 

DEIS Appendix F-2, Section 6.6, Page 6-7, Lines 20-23. e. DEIS Appendix F-2, Section 7.0, 

Page 7-1 Lines 15-17. (0619-6-8 [Maher, William])

Appendix E NUREG–2176 E-302 October 2016
Response: The NRC Staff acknowledges the analysis prepared by FPL for habitat effects for 

the protected American crocodile. The NRC Staff did an independent analysis of the FPL 

references, other scientific literature, and discussions with crocodile researchers and prepared a 

BA as part of ESA Section 7 consultation with the FWS. The effect of spoils pile placement did 

not only consider direct effects associated with reproduction, but indirect effects on crocodile 

habitats and individuals, such as changes in water quality and restriction of migration across the 

IWF. Updated information about the result of consultation is presented in Sections 4.3.2, 5.3.2, 

and 7.3.2 of the EIS. 

Comment: The NMFS believes applying the results of the modelling conducted by FPL to 

predict impacts to seagrass and federally managed species is problematic because it focuses 

on mean conditions as opposed to ecologically relevant conditions. In addition, the modelling 

performed was based on an inaccurate assumption that the cooling canals are a closed system 

(i.e., no exchange between the canals and Biscayne Bay). A more reliable way to analyze the 

impacts would be to examine ecologically relevant scenarios, such as the frequency, duration, 

and intensity of the salinity and temperature disturbance (i.e., extreme) events. In addition, the 

impact analysis should be updated to characterize and quantify the level of exchange between 

the cooling canals and Biscayne Bay and then incorporate that working understanding of the 

level of exchange into the analysis of impacts and the development of monitoring to verify those 

impacts. (0724-10 [Fay, Virginia M.])

Response: The review team performed additional groundwater modeling of the interaction 

between the planned RCWs, the existing hypersaline plume, and the cooling canals using a 

two-dimensional cross-section model and a limited-extent three-dimensional model. These 

simulations were performed to better understand the effects of RCW pumping on salinity in the 

aquifer beneath the bay combined with the existing hypersaline plume from the Units 3 and 4 

cooling canals and planned remediation actions, and the analysis has been added to Appendix 

G. This model was useful in showing salinity changes that occur in the aquifer near the RCWs 

when the wells are operated. The results showed that when the wells are not operating 

hypersaline water from the cooling canals is present in the high permeability zone where the 

well laterals are installed. This saline water is drawn into the wells during the first few days of 

RCW pumping, resulting in increasing, then decreasing, salinity at the well. The salinity of the 

water produced by the operating RCW eventually dropped to about the concentration of the bay 

water. Water flowing down through the bed of the bay and into the RCWs is therefore expected 

to have about the same salinity as bay water. When RCW pumping ceases, water in the high 

permeability zone again increases in salinity because of the migration of water from the 

hypersaline plume. This migration of hypersaline water into the high permeability zone would 

occur regardless of the presence of the RCWs. Predicted future change in sea level and its 

effect on interactions between the RCWs and the hypersaline plume were also simulated. The 

additional modeling confirmed that pumping of the RCWs would move hypersaline water toward 

the RCWs and would remove some groundwater captured by the RCWs from the hypersaline 

plume region of the Biscayne aquifer. The model also indicated that RCWs operation is not 

likely to reduce the effectiveness of hypersaline plume remediation actions specified in the 

consent order between FPL and Miami Dade County. Reclaimed wastewater would be the 

primary source of cooling water for the proposed reactors. Saline water from the RCWs 

beneath Biscayne Bay would only be used when reclaimed treated wastewater is not available 

in sufficient quantity or quality, and for a maximum of 60 days per year that is permitted under 

the Florida State COCs. The review team determined that the primary reclaimed water source 

is reliable because of the need for Miami-Dade County to dispose of large volumes of treated 

wastewater that now go to the ocean. Therefore, it is likely that the RCWs would be used less 

than the 60 days per year permitted under the COCs. Sections 5.2.1 and 5.3.2 were revised to 

Appendix E October 2016 E-303 NUREG–2176
include the results of the additional modeling and effects to aquatic resources in Biscayne Bay 

such as seagrass and aquatic species, however the new information did not change the SMALL 

effect characterization on aquatic resources for operation of Units 6 and 7. 

Comment: Operation of RCWs: The primary source of cooling water for the proposed Turkey 

Point Units 6 and 7 would be reclaimed wastewater from the Miami-Dade Wastewater and 

Sewer Department. Because the availability of the reclaimed wastewater supply will vary, FPL 

plans to install four RCWs on the Turkey Point peninsula to provide a secondary source of 

cooling water. Each RCW would consist of a central reinforced concrete caisson with 8 to 12 

lateral pipelines (horizontal collector lines) extending out from the caisson. The horizontal extent 

of the RCW lateral pipelines would be up to 900 feet beneath Biscayne Bay and would be 

approximately 25 to 40 feet below the bay bottom. In order to maintain the RCW system, the 

RCWs would be used up to 60 days per year with a maximum saltwater makeup-water rate 

under normal operating conditions being 43,200 gpm. The EFH assessment does not address 

use of the RCW system outside this maintenance; i.e., when it becomes the main water supply 

when the primary supply is inadequate. The NMFS recommends the final EIS and EFH 

assessment analyze the effects of operating the RCW as the main water supply when the 

reclaimed wastewater becomes unavailable for longer periods than expected. Alternatively, the 

NRC or the USACE may need to reinitiate EFH consultation prior use of RCWs for time periods 

exceeding those evaluated in the draft EIS and EFH assessment. (0724-8 [Fay, Virginia M.])

Response: Reclaimed wastewater would be the primary source of cooling water for the 

proposed reactors. Saline water from the RCWs beneath Biscayne Bay would only be used 

when reclaimed treated wastewater is not available in sufficient quantity or quality, and for a 

maximum of 60 days per year that is permitted under the Florida State COCs. The review team 

determined that there is a very large volume of treated municipal wastewater that can be used 

for cooling the proposed plants without impacting other demands for fresh water. MDWASD 

staff have stated that they must find ways to dispose of large volumes of treated wastewater 

that currently go into the ocean. Therefore, the review team concluded that the reclaimed water 

supply is reliable. Therefore, it is likely that the RCWs would be used less than the 60 days per 

year permitted under the COCs. The commenter is incorrect that the 60 day RCW annual 

maximum operation is required for maintenance. 

E.2.11 Comments Concerning Socioeconomics 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...I see the potential of economies of scale 

boosting FLP's ability to provide safety and efficiency over what it is today. (0015-4 [Goldmeier, 

Barry])

Response: The NRC acknowledges the commenter's support for new nuclear 

power. Economies of scale to the applicant are not part of the scope of the socioeconomics 

analysis. No change was made to the EIS as a result of this comment. 

Comment: Plus putting such large ugly power poles along a roadway which goes thru many 

residential and low rise commercial establishments and neighborhoods of high end homes are 

unacceptable choices. Just because you can build it does not mean it should be built. The 

human needs and emotional needs are great in this area, and we should all be very cautious 

when locating such extreme projects in this Miami area. (0050-2 [Simon, Gary P.])

Appendix E NUREG–2176 E-304 October 2016
Comment: Tourists and residents do not come to National Parks to see huge power lines.

(0159-5 [Bazzone, Barbara])

Comment: Electricity produced by the proposed Units 6 and 7 will be distributed to the existing 

power grid through two new transmission line corridors: the east corridor and the west corridor. 

The northern segment of west corridor will be located either in the Preferred Corridor or the 

Consensus Corridor. The Department notes that the Preferred Corridor will be located 

immediately adjacent to the (ENP). As such the installation of this new transmission line will 

adversely affect the aesthetic experience of visitors to the ENP. (0227-15 [Stanley, Joyce])

Response: The comments express opposition to the visual impact of the transmission lines to 

serve FPL's proposed Turkey Point Units 6 and 7. Although electrical transmission is outside 

the regulatory authority of the NRC, the review team considered the visual impacts of 

transmission lines in Sections 4.4.1.6 and 5.4.1.6 (aesthetics) and the cumulative impacts of 

transmission lines with past, present, and foreseeable future actions in Chapter 7, 

Cumulative Impacts. No new information was provided by these comments that was not 

already considered in the analysis. No changes were made to the EIS as a result of these 

comments. 

Comment: I encourage you all to rethink this "let's make quick money and let the next 

generation deal" mentality and discontinue support for this dangerous and frankly lazy attempt 

on FP&L's part to keep up with the market or grow their business a par 15% per annum or 

whatever is motivating this plan to expand the Turkey Point facility rather than pursue what they 

already have in the can, ready to go, the motivation is obviously not hospitable or even aware 

that there is a population south of spaghetti junction as long as they keep paying the bills.

(0056-3 [McCall, Eric])

Comment: Investing in dirty, dangerous nuclear plants that may never even be built is very 

profitable for FPL and its shareholders. That's why they want to do it. But it' a financial and 

environmental disaster for our local area, our state and all who live here. (0078-12 [Wilansky, 

Laura Sue])

Comment: Investing in dirty, dangerous nuclear plants that many never even be built, is very 

profitable for FPL and its shareholders. That's why they want to do it. But it's a financial and 

environmental disaster for our local area, our State, and all who live here. (0721-28-13 [Wilansky, 

Laura Sue])

Response: Environmental and socioeconomic impacts from construction and operation of the 

proposed nuclear reactors are analyzed in Chapters 4 and 5 of the EIS. Financial 

considerations are outside the scope of the EIS. The comment did not provide new information 

relevant to this EIS and will not be evaluated further. No change was made to the EIS as a 

result of this comment. 

Comment: The State should be for people and wildlife. Tourism is a very sustainable industry 

but will fall by the wayside if our environment is wantonly destroyed. (0060-5 [Beckman, Yvonne 

and Douglas])

Comment: I am told that expansion of the power plant will result in 800 new jobs. Any 

destruction to Biscayne National Park, will negatively impact the hundred of thousands visitors 

that we have annually to our area and the businesses that rely on them. I am also greatly 

concerned that any environmental change could potentially effect the only living coral reef we 

have in United States waters, The John Pennekamp National Coral Preserve. These resources 

Appendix E October 2016 E-305 NUREG–2176
are far to unique, valuable and delicate to jeopardize. Undoubtedly, the negative economic 

impact of lost eco visitors will far out weigh the positive economics of the Turkey Point project 

for south Florida. (0081-4 [Benson, Mary] [Skove, Ellen H.] [Tompkins, Constance])

Comment: 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 notake 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. (0288-11

[Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] 

[Teas, Jim] [Ullman, Jonathan])

Comment: We also feel that Miami's economy relies heavily on its tourism industry and it's in 

the best interest of the tourism economy to keep Biscayne National Park pristine, safe and clean 

for the people who come here to see its beauty every year. (0722-14-5 [Kaul, Devika])

Comment: Because you guys, you own those national parks, people come here from all over 

the world to see them. It's a huge part of our economy. Everybody wants to see Everglades 

National Park and thousands and hundreds of thousands want to see Biscayne National Park. 

(0723-9-7 [Schwartz, Matthew])

Response: These comments express concern about impacts on tourism through impacts on 

the environment. The review team analyzed environmental impacts from construction and 

preconstruction (Chapter 4) and from operations (Chapter 5) of the proposed nuclear 

reactors. Summaries of these impacts can be found in Section 4.12 (Summary of Construction 

and Preconstruction Impacts) and Section 5.12 (Summary of Operational Impacts). Because 

the site is already heavily industrialized and there is no indication industrialization has 

significantly affected current tourism the review team determined an incremental addition to the 

site should not have a noticeable effect. Impacts on recreational infrastructure are discussed in 

Sections 4.4.4.2 and 5.4.4.2 (recreation). No changes were made to the EIS in response to 

these comments. 

Comment: As a South Florida resident I am deeply concerned about the potential 

environmental impacts of the proposed Turkey Point expansion (reactor units 6&7). But as the 

founder of the future Underline, it will be tragic to erect massive powerlines along a park and 

trail that is will bring so much good and much-needed alternative transportation infrastructure to 

our community. (0076-2 [Daly, Meg])

Response: The commenter expresses opposition to the transmission lines to serve FPL's 

proposed Turkey Point Units 6 and 7, because of their location along a proposed park and 

trail. Although electrical transmission is outside the regulatory authority of the NRC, the review 

team considered the visual impacts of transmission lines in Sections 4.4.1.6 and 5.4.1.6 

(aesthetics) and the cumulative impacts of transmission lines with past, present, and 

foreseeable future actions in Chapter 7, Cumulative Impacts. The potential for adverse 

cumulative impacts along the proposed transmission line routes with proposed land uses is 

discussed in Section 7.1 (Land-Use Impacts), which recognizes potential moderate and adverse 

impacts. No changes were made to the EIS as a result of this comment. 

Appendix E NUREG–2176 E-306 October 2016
Comment: The Biscayne National Park has been trying for years to put new management 

regulations into place that will hopefully give what little marine life we have left a chance to 

regenerate. I am shocked that they are not pursuing every legal avenue available to prevent the 

FPL expansion from occurring. Over the next decade, millions of people will visit this area. That 

is unless, god forbid, an accident happens. Then, the resource could be lost forever and the 

visitors simply won't come. (0081-5 [Benson, Mary] [Skove, Ellen H.] [Tompkins, Constance])

Comment: I am a Florida native; growing up in Miami, I have seen the unfortunate change to 

this unique subtropical environment as it is. This proposal subjects our delicate environs to the 

horrable and - INEVITABLE - hurricane impact that would be devastating on many levels; not 

the least of which is to Floridas' survival as a tourist destination. Our beautiful beaches are an 

intricate part of our survival as a state. This will devistate our fishing,our swimming, our 

Everglades, the intrinsic beauty, life style and safety of our unique and beloved state. (0580-2

[Lawrence, Theresa])

Response: The comments express concern about impacts on tourism if the environment is 

destroyed due to a natural disaster. The review team assessed the potential for environmental 

impacts from postulated accidents (design basis accidents and severe accidents) in Section 

5.11 (Environmental Impacts of Postulated Accidents). The review team found the potential 

environmental impacts (risks) to be small. No changes were made to the EIS as a result of 

these comments. 

Comment: The proposed expansion of Turkey Point could also have significant impacts on the 

diverse ecosystems and valuable recreational experiences protected by our national parks. 

Biscayne National Park is particularly vulnerable to the impacts of the proposed project due to 

its location directly adjacent to Turkey Point. The park visitor center and entrance are located 

only two miles north of the site proposed for Units 6 & 7 and water areas of the park are just 

2000 feet east of the proposed new units. Viewsheds from the waters of Biscayne will be 

significantly impacted above current levels due to the construction and presence of the new 

units and ancillary facilities, impacting visitor use and experience. (0113-1-12 [Lopez, Jaclyn] 

[McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: This infrastructure will also mar the view for visitors who come from all over the 

world to this UNESCO World Heritage site. (0246-6 [Shlackman, Mara])

Comment: It's going to create an industrial landscape for the hundreds of thousands of people 

who go visiting that area on airboats, on canoes and kayaks, people who paddle to Shark River 

Slough. And you know that observation tower up there when you get up to the top of it; you're 

going to see power lines. That's a human impact. (0721-22-6 [Schwartz, Matthew])

Response: These comments express concern about impacts on recreational experiences or 

tourism via visual impacts in the vicinity of the proposed nuclear reactors. The review team 

considered the visual impacts of construction and operation of the proposed nuclear reactors in 

Sections 4.4.1.6 and 5.4.1.6 (aesthetics). The analysis conducted in those sections concludes 

that there would be minor or temporary aesthetic impacts from building and operating the 

proposed new units. The comment does not introduce any new information not already 

considered in the analysis. No changes were made to the EIS as a result of these comments. 

Comment: People come from all corners of the world to visit South Florida. They don't come to 

visit FPL or nuclear power plants. They come to swim in the ocean, enjoy the clean air, soak up 

Appendix E October 2016 E-307 NUREG–2176
some sunshine, visit the Everglades, and a host of other activities that give them reasons to 

come back. I invite you to come and enjoy our beautiful peninsula. (0207-6 [Cleland, Noel])

Comment: People come from all corners of the world to visit South Florida. They don't come to 

visit FPL or nuclear power plants. They come to swim in the ocean, enjoy the clean air, soak up 

some sunshine, visit the Everglades, the Keys, Biscayne National Park, and a host of other 

activities that give them reasons to come back. (0677-6 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, 

Carol])

Response: These comments express general opposition to new power plants and appreciation 

for environment-based tourism. No new information was provided regarding the environmental 

or socioeconomic impacts of the proposed plants. Therefore, no changes were made to the EIS 

as a result of these comments. 

Comment: Also, removing the negative externalities of pollution will free up investment. 

Businesses will invest more when the oft-hidden costs of pollution are removed. More 

investment means more jobs. Lastly, new ventures and industries that are too energy-intensive 

under our nuclear-deficient energy system--venture like indoor vertical farming--will be possible 

with increased nuclear energy generation. (0378-4 [Macher, Nathan])

Response: The NRC acknowledges the commenter's support for new nuclear power. The 

impacts of the proposed nuclear reactors relative to alternative energy sources is discussed in 

Section 9.2 (Energy Alternatives). No change was made to the EIS as a result of this comment. 

Comment: Socioeconomics. We note the distinction in the DEIS between temporary 

construction impacts and longer-term operation impacts. However, since the facility's 

construction is likely to be underway for seven years, these impacts may be considered 

significant for the local communities. Issues regarding traffic congestion, socioeconomic 

impacts, Environmental Justice, and other issues that directly concern the local communities, as 

well as operational impacts related to these matters, should be fully clarified in the FEIS, 

pursuant to our comments. We understand that the NRC cannot include mitigation measures in 

the licenses that do not pertain to safety and security. However, the EPA encourages the project 

team and the applicant to continue coordinating with the communities that will be impacted by 

the proposed project, and to continue a comprehensive public outreach strategy to inform 

residents of the risks and impacts as a result of the proposed project. In particular, potential 

traffic impacts and emergency preparedness measures should be coordinated with local 

communities. Recommendations: The EPA encourages a comprehensive public outreach 

strategy. This should include, but is not limited to, targeted outreach campaigns to neighbors, 

informational literature, and updated websites. Traffic impacts and emergency preparedness 

measures are particular topics that should be addressed and coordinated with local 

communities. (0617-3-1 [Mueller, Heinz J.])

Response: This comment recommends a comprehensive public outreach strategy to address 

traffic impacts, emergency preparedness measures, and other impacts in coordination with local 

communities. These actions are outside the scope of NRC's NEPA requirements and outside 

the scope of NRC's Atomic Energy Act mission. No change was made to the EIS as a result of 

this comment. 

Comment: Having said that, Cyndee, please relax. "Gigantic 26 foot high cooling towers" are 

not going to drive tourists away from Florida. As a matter of fact, nothing they are going to do at 

Appendix E NUREG–2176 E-308 October 2016
Turkey Point is going to drive anybody away from Florida. No, we have no problem looking at 

the Turkey Point Plant. (0680-3 [Hubbard, Stanley S.])

Response: The NRC acknowledges the commenter's view that the proposed nuclear reactors 

would have no impact on tourism. The comment does not raise any new information not already 

considered in the analysis. No changes were made to the EIS as a result of this comment. 

Comment: And that is the breeding ground for the entire Florida Keys, so salinity there 

threatens the $7.6 billion fishing and tourist industries. (0721-12-5 [White, Barry J.])

Comment: [past and current Boulder Zone discharges to the Atlantic] It's destroying our 

fishing. Everybody who fishes in Biscayne Bay knows what happened to the fishing. It's not 

even worth doing it anymore for most people. (0723-9-19 [Schwartz, Matthew])

Response: Impacts on aquatic resources from operations are assessed in Section 5.3.2 

(Aquatic Impacts Related to Operation). The review team concluded that impacts would be 

small. No changes were made to the EIS as a result of these comments. 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[w]hy sould Miami-Dade residents pay of power 

generated as far away as Canada when we can be employing local people to whom our 

payments go who in turn support the economy. (0015-11 [Goldmeier, Barry])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[t]he relatively high paid construction and 

ongoing jobs in operation will serve as an economic boost for Homestead...FPL has been 

collecting the funds for this expansion for years. from Miami-Dade County. It should be 

reinvested here. (0015-7 [Goldmeier, Barry])

Comment: This construction is going to generate 800 permanent jobs, highly technical 

permanent jobs, and an additional 3,500 job just for the construction, not to mention the added 

benefits that the local economy is going to see just from the large influx of money. (0721-15-9

[Kuraza, Devon])

Comment: Reports indicate that Turkey Point Units 6 and 7 will create 3,500 jobs over a 

multitude of year's construction period, and 800 good paying --good paying, jobs once the 

facility is completed and becomes operational. The construction of these units will represent one 

of the largest projects in this State's history, and the jobs it creates will benefit thousands, 

thousands of South Florida families while protecting all environmental issues. In addition to the 

construction of the project these units will need to be maintained and refueled on a reoccurring 

basis, just like the current units require. These periods are also known as outages, resulting in 

hundreds of temporary jobs for area workers, which help local businesses keep the customers 

that they already have and generate a large ripple effect throughout the economy. (0721-19-3

[Riley, Bill])

Comment: The south Florida community has benefited immensely from the FPL's investments 

for the last 40 years. The Turkey Point Plant, not only has generated clean energy, but also has 

helped our local economy. The reports indicate that Turkey Point Units 6&7 will generate 3,500 

jobs that will last for many years, in addition to more than 800 maintenance jobs once the plant 

starts functioning. The construction of these units will be one of the largest projects in the history 

of the state of Florida, and will generate jobs that will benefit thousands of families in south 

Appendix E October 2016 E-309 NUREG–2176
Florida. Furthermore, the new units will require maintenance work. The maintenance work 

known as "Outages" will result in the creation of hundreds of additional jobs in the area, which in 

turn will benefit local business. We are convinced that this important project will be positive and 

beneficial for the entire state. (0721-20-2 [Garcia, Javier])

Comment: Additionally, the nuclear energy facilities in Florida are heavyweights when it comes 

to economic growth in the State, as you've heard from several others here today. These 

facilities employ more than 2,270 highly skilled workers with an annual payroll of $191 million. 

They also pay more than $32 million in State and local taxes. This support of local communities 

through jobs and tax revenue is tangible and would be sorely missed if a plant were to be taken 

offline. (0721-21-2 [Martin, Patrick])

Comment: The Hurricane Andrew wiped out Homestead, pretty much all the businesses 

dropped, our population dropped dramatically and we're rebuilding now but we're not there yet. 

Unlike other cities north of us who have rebounded economically, Homestead is still struggling. 

We are coming around the corner, we're making some major progress but we definitely need 

more jobs and we're looking at a potential of greater jobs and higher paying jobs with this 

expansion. So we really --I can't speak to the science, I'm not a scientist, there's much smarter 

people in this room than I. But I do know that the impact of our downtown and the partnerships 

we've had over the last few years with FPL has greatly helped us[.] (0722-11-1 [Knowles, Yvonne])

Comment: We [Redland Market Village] are in full support of this application and the reason 

that we have, the main reason is that we are part of a very low-income persons that are part of 

our business. And every penny counts. (0722-12-1 [Infante, Jose Renee])

Comment: There will be a huge -- as many other people have mentioned earlier -- huge 

economic, continued economic impact to deep South Dade and not only deep South Dade but 

the communities going up the north and south U.S. 1 corridor as well. (0722-13-3 [Duquette, Bill])

Comment: [T]here's 700 employees at Turkey Point with an additional industry of indirect jobs 

related to that which brings in, it nets us $500 million annually toward local economies. So for 

every dollar spent at Turkey Point the local economies produce about 43 which is a huge 

impact. 

And as Yvonne did mention, post Hurricane Andrew, we're finally getting back to the previous 

level we were so this would be a huge boom to our local community. 

The additional units will, of course, provide additional -- a number of additional jobs. After all is 

said and done comparatively, plus construction of about ten years, that will be an additional 800 

full-time higher paying jobs not only again in deep South Dade, Homestead and Florida City and 

up the road. (0722-13-4 [Duquette, Bill])

Comment: We have to be realistic. I say with the impact of jobs, of good growth community, I 

think we need the reactors. (0722-19-2 [Hudak, Jill])

Comment: [T]he building of these Units 6 and 7 presents us with employment opportunity. And 

to be more specific on that, it's going to produce about 3,500 jobs during construction and 800 

stable jobs upon completion. And these are jobs that I can take as well as many other students, 

many of my other colleagues. 

Appendix E NUREG–2176 E-310 October 2016
It's important to note that these jobs will be available not just to myself but generations to come 

due to the longevity and reliability that comes from running nuclear reactors. (0722-5-1 [Silva, 

Nicolas])

Comment: Reports indicate that Turkey Point Units 6 and 7 will create 3,500 jobs during the 

course of construction and 800 permanent, good-quality paying jobs for our local residents once 

the plant has become operational. The construction of these units will represent one of the 

largest projects in the State's history and the jobs it creates will benefit thousands of South 

Florida families while protecting the environmental issues. (0722-9-3 [Riley, Bill])

Comment: In addition to the construction projects these units will need maintenance and 

refueling on a regular basis just like the existing nuclear units. These periods are known as 

outages resulting in hundreds of additional temporary jobs for area workers which helps local 

businesses keep their customers that they already have and generate a large ripple effect 

through the economy. (0722-9-4 [Riley, Bill])

Comment: a supporter of the environment. I want my kids to have fresh air, clean water, 

abundant wildlife, flora and fauna. But you know, as we are the city, there's another element to 

our environment that sometimes gets overlooked. It's the working men and women of our 

community. They're part of the environment, too. A project like this, the building construction 

stage will generate 3,500 construction jobs followed by approximately 800 permanent jobs. 

These are not retail jobs, these are real, real important substantial salaries that people will make 

and then reuse in the community. So when you talk about the environment, never forget people, 

that they're part of it, too. And I've seen that happen too many times in presentations where that 

element of need is often left out. (0723-1-5 [Wallace, Otis])

Comment: As a mayor, got to talk taxes as a reality. This project will generate $100 million in 

taxes for our community. Rich folks don't care about stuff like that, or they whine about paying 

taxes. They do whine more than anybody else. But when it comes to making money, I think it's 

important that people be allowed living wages to make money, but the 100 million in taxes 

generated would be significant running our community, a community within Dade County. 

(0723-1-7 [Wallace, Otis])

Comment: ...we do see that study shows benefits on day-to-day operations when we see the 

huge economic impact in our community. (0723-10-1 [Brito, Rosa])

Comment: We see Turkey Point supports over $540 million of annual economic activity locally 

which is really important for small businesses in our area which are dependent on plant 

business and employees spending to stay afloat. For every dollar FPL's Turkey Point plant 

spends locally the economy produces $1.43. When you do the math, this is a huge amount of 

money for a small town of 60,000 citizens. (0723-10-4 [Brito, Rosa])

Comment: We also heard some folks talk about the actual monitoring of the project after it's 

built and some of the experience that goes in, and the knowledge that goes into doing that. But 

also in the construction of this we have skilled trades people that are going to be working on 

these projects. It's going to develop just good jobs. Not just jobs but good jobs, good paying 

jobs for professional people. (0723-13-2 [Simpson, Chris])

Comment: But just to move along here real quick, reports indicate that Turkey Point Units 6 

and 7 would create 3,500 jobs, as you've heard tonight, over a multitude of years of construction 

period, and 800 good, qualified paying jobs for multiple local residents once the plant has 

Appendix E October 2016 E-311 NUREG–2176
become operational. The construction of these units will represent one of the largest projects in 

the State of Florida's history and the jobs it creates will benefit thousands of South Florida 

families while protecting environmental issues. In addition to the construction projects, these 

units will need maintenance and refueling on a recurring basis just like the existing nuclear unit 

are now at Turkey Point. These periodic shut-downs are known as outages, the results of 

hundreds, hundreds of additional temporary jobs for area workers, area workers in Homestead, 

Miami, Broward, Conyer County, Naples, wherever. There are hundreds of jobs on each one of 

these shutdowns. It keeps the customers they have and businesses active and also generates a 

large ripple effect throughout the economy when they shut down. People, local people and a lot 

of other people participate in those activities. (0723-14-4 [Riley, Bill])

Comment: And whereas the project, during its construction and completion will bring economic 

stimulus via jobs both during construction and permanent as well as high technology 

employment to Miami Dade County. (0723-2-7 [Trowbridge, Mark])

Comment: I do consider the fact that this proposed plants, the two separate sites, 6 and 7 will 

bring to -- in jobs... (0723-8-2 [McDuffie, Stephen])

Response: These comments express support for the proposed nuclear reactors due to their 

impacts on the economy and specific aspects of it such as jobs, earning, output, and fiscal 

impacts but do not introduce any new information to inform the assessment of impacts. The 

NRC acknowledges these comments. Impacts on employment, earnings and fiscal 

revenues are assessed in Sections 4.4.3 and 5.4.3 (Economic Impacts on the Community). No 

changes were made to the EIS as a result of these comments. 

Comment: And then the last thing I would mention too, is, that I just want to speak directly to 

my Union brothers and sisters here in the audience, the ones who are working for FPL. I 

understand that you all -- that this is your livelihood, and I know what it's like. Believe me. I know 

what it's like to be in a situation where I have to advocate on behalf of my employer. But I would 

mention, too, that before I taught here at FIU, before I was a member of the United Faculty of 

Florida, I was a member of the United Auto Workers, and I was a very proud Union member, 

except for the point where my Union, I thought, sold us all out by going before Congress and 

advocating against the CAFÉ standards, the minimum standards for fuel efficiency on 

automobiles. They went to Washington arguing the same thing that the automakers were 

arguing, was that the CAFÉ standards were going to cost jobs. They said it was an economic 

argument, much like the one that you guys are making now. And I can you tell you, they were 

wrong. It didn't keep American -- it didn't keep auto working jobs here in America. It did nothing 

to help the Union, and the Union suffered. We all suffered. Don't let FPL, which is beholding not 

to you, but to its shareholders, try to make an artificial argument between economic growth in 

your jobs versus, I don't know what the other alternative is, that we all live in darkness. It's a 

false choice. (0721-16-5 [Rifkind, David])

Comment: Now, I want everybody in this room to understand, there will be jobs. There will be a 

future, there will be power. (0721-30-11 [Ullman, John])

Response: These comments express opposition to the proposed nuclear reactors suggesting 

that claims of forgone jobs under the No Action Alternative are overstated. Impacts on 

employment, earnings and fiscal revenues are assessed in Sections 4.4.3 and 5.4.3 (Economic 

Impacts on the Community). These comments do not provide new information to inform the 

assessment of impacts. No changes were made to the EIS as a result of these comments. 

Appendix E NUREG–2176 E-312 October 2016
Comment: I am a realtor and I strongly believe that all the property value in Miami is at 

extreme risk with turkey point. (0055-10 [Roedel, Kitty])

Comment: More nuclear electric generating plants would not only be a danger, but will also 

severely impact billions of dollars in value of the business, homes, and infrastructure of MiamiDade county and beyond. (0091-3 [Boyce, Sheila])

Comment: And 6 and 7 would cost every FPL homeowner about $5,200 or 2 percent of the 

value of their own home. (0721-12-11 [White, Barry J.])

Response: These comments suggest that construction of the proposed nuclear reactors would 

have a negative effect on property values. In response to these comments, the review team 

assessed the current literature on the effects of nuclear reactors on property values. The review 

team concluded that the current literature is inconclusive and that any potential adverse or 

beneficial impacts would be expected to be small. Section 4.4.4.3 (Housing) was edited to 

include this review. 

Comment: Comment 10. The DEIS is incomplete in that its analysis of alternate sites did 

not consider the economic impacts of transmission infrastructure necessitated by a new 

nuclear plant and it did not consider the disparate economic impact of that infrastructure 

on a county with a disproportionately minority and low income population - Miami-Dade 

County has a predominantly minority population and a higher number of people living in poverty 

(25.6%) than the statewide average (20.8%) (U.S. Census & American Community Survey). 

Economic effects of the entire TPN 6&7 project include not just the plant itself, but also the 

attendant infrastructure, including new transmission lines. All components that can affect the 

County's tax base must be taken into economic consideration within the DEIS because they will 

affect the ability of the County to provide needed services countywide. The DEIS does consider 

the economic benefits to the County during construction, but not the countywide costs caused 

by infrastructure necessitated by the plant. Most of the economic benefits reported in the DEIS 

will accrue only during construction, but the economic costs will be permanent and recurring. 

Economic analysis by Dr. Richard Weisskoff, Chairman of the Economics Dept. at the University 

of Miami (2011) has projected that the transmission line infrastructure will cost the county's tax 

base by $35 million annually (adjusted for change in real estate values since the study was 

done in 2010). FPL's analysis shows approximately 6500 temporary jobs will be added 

countywide during construction. However, Dr. Weisskoff's analysis, not mentioned in the DEIS, 

shows that 4000-8000 permanent jobs will be lost by routing supporting infrastructure 

(transmission lines) through areas of high economic activity. It should be noted that FPL 

engaged the property appraiser from Leon County, Florida to critique Dr. Weisskoff's analysis. 

That individual concluded that Dr. Weisskoff's valuation data were erroneous, however it 

appears the property appraiser did not understand that the Miami-Dade County Property 

Appraiser's valuation listings treat condominiums differently than other property types, 

combining values of land and structure in a single column of numbers rather than breaking them 

out separately. Thus the valuation discrepancy reported by the Leon County property appraiser 

appears to stem from his own misunderstanding of local property appraiser listings and not from 

any error in Dr. Weisskoff's data collection or analysis. The final EIS must evaluate disparate 

countywide impacts of site selection and attendant infrastructure on minorities and lowincome residents of Miami-Dade County. (0106-13 [Stoddard, Philip K.])

Comment: In addition we find likely adverse consequences for the Miami-Dade County 

economy as a whole that are overlooked in the DEIS. (0106-3 [Stoddard, Philip K.])

Appendix E October 2016 E-313 NUREG–2176
Comment: The lines traverse well-populated areas with unsightly towers, impacting property 

values. (0117-3 [Robertson, Alyce])

Comment: We will lose property value due to these poles and we are in the prime real-estate 

area in South Florida. (0149-9 [Nelson, Joyce E.])

Comment: As for the residents on both sides of US Hwy 1: Coral Gables, Cutler Bay, Florida 

City, Homestead, Miami, Palmetto Bay, Pinecrest, Princeton and un-incorporated Miami Dade 

property values will see an immediate, tangible drop upon completion of FPL's would-be power 

line. A rudimentary economic-impact study will bear out this fact. This, in turn, will lower tax 

revenues for all municipalities and taxing units; further impoverishing the public sector so private 

interests may benefit. (0408-7 [Sifko, Basilio])

Comment: And also, another thing also is that, you know, what someone else mentioned 

earlier about the lady from Roads saying, oh, it's going to reduce the property values to the 

Roads neighborhood. And, yeah, that's true. I mean, who wants to live next to those ugly power 

lines that nobody wants. (0721-31-9 [Almirola, Alejandro])

Response: These comments refer to potential adverse effects on property values of the 

construction of transmission lines associated with the proposed project. The review 

team assessed the current literature on the effects of nuclear reactors and transmission lines on 

property values and concluded that the current literature is inconclusive and that any potential 

adverse or beneficial impacts would be expected to be small. Section 4.4.4.3 (Housing) was 

edited to include this review. 

Comment: Overall, the expansion of Turkey Point will end up costing our communities jobs 

and our taxpayers, money. Despite the addition of temporary jobs during construction, research 

from the University of Miami indicates that more jobs will be lost due to the routing of 

transmission lines through areas of high economic activity. Furthermore, Florida Power & Light 

customers have been footing the bill for the expansion up front, regardless of whether the new 

reactors are ever built. The expansion of Turkey Point does not make economic sense for the 

people of South Florida. (0254-6 [Dudley, Dwight] [Lerner, Cindy] [Regalado, Tomas] [Stoddard, Philip 

K.])

Response: This comment expresses opposition to the proposed nuclear reactors because of 

potential adverse effects on local economies, as well as the cost to electricity consumers. The 

economic impacts of construction and operations of the proposed project are discussed 

sections 4.4.3 and 5.4.3, respectively. Changes in the cost of electricity are outside the scope 

of the NRC's authority and were not addressed in the EIS. 

Comment: [The Turkey Point Nuclear Plant Units 6 & 7 application should be viewed in context 

of a region facing the enormous water quality and land use related challenges imposed by 

climate change.] Therefore, the final Environmental Impact Statement ought to consider not 

only the direct impact of this project to a region currently under threat, but also how the project's 

operations will constrain investments made to manage future challenges and correct a history of 

destabilizing influences. In sum, the region is confronted with a deteriorating baseline and will 

need to adapt. (0456-2 [Miami, City])

Response: Section 2.3 (Water) describes the current water use in the affected area. Appendix 

I of the EIS documents the review team’s consideration of the potential changes in impacts that 

may occur as a result of the changes to the environment resulting from global climate change, 

Appendix E NUREG–2176 E-314 October 2016
including sea-level rise. The changes that were considered include potential changes in 

temperature, rainfall, and the occurrence of severe weather events. The effects of sea-level rise 

were also considered. No changes were made to the EIS in response to this comment. 

Comment: In early 2015, FPL announced the change of the commercial operation dates 

(CODs) for Units 6 & 7 from 2022 and 2023 to 2027 and 2028, respectively. A new and 

significant information review was conducted by FPL where it was concluded that there would 

not be an impact to any significance level or conclusion drawn in the ER with respect to the 

change in CODs. There are instances in the DEIS, however, where references to CODs differ 

from the newly announced CODs. Instances in the DEIS include: a. DEIS Subsection 4.4.3.1, 

Page 4-107, Lines 2-5: In DEIS Subsection 4.4.3.1, the commercial operations dates are 

mentioned in relation to economic analysis: "The impacts of building the proposed units on the 

local and regional economy ...For this analysis, FPL assumed site preparation activities would 

begin in 2016 and commercial operation dates would be 2025 for Unit 6 and 2026 for Unit 7." b. 

DEIS Subsection 5.4.2, Page 5-66, Line 22: In DEIS Subsection 5.4.2, the commercial 

operations dates are mentioned in relation to demographic analysis: "For analytical purposes, 

Unit 6 is scheduled to start operation by 2025 and Unit 7 by 2026." (0619-1-6 [Maher, William])

Response: The NRC includes clarification in Sections 4.4 and 5.4 regarding FPLs modification 

of the expected commercial operation dates. 

Comment: DEIS Subsection 9.3.6.2, Page 9-247, Lines 12-19: The DEIS states, "The impacts 

of traffic at the Martin site are MODERATE to LARGE (depending on the timing of other 

projects in the area), while the impacts at the Turkey Point site are MODERATE because of 

visual impacts along the eastern corridor, while the impacts at the Martin site are SMALL 

because the new transmission lines are expected to follow the path of existing lines. Finally, 

impacts on cultural and historic resources at the Turkey Point site are MODERATE because 

of visual impacts along the eastern corridor, while the impacts at the Martin site are SMALL 

because the new transmission lines are expected to follow the path of existing lines." These 

sentences appear to conflate the discussion of traffic, transmission, visual, and cultural/historic 

impacts. (emphasis added) (0619-5-19 [Maher, William])

Response: Section 9.3.6 (Comparison of the Impacts of the Proposed Action and the 

Alternative Sites) offers socioeconomic assessments of four different sites, each of which has 

different characteristics of importance. These differences are the source of the concerns in the 

comment. After review of each analysis, the staff determined the analyses are not incorrect. No 

changes were made to the EIS in response to this comment. 

Comment: There were some comments by the Mayor about people paying taxes. None of us 

like paying all of our electric bill, right? But it's basically a fixed cost that we all have to do. And 

anything that we can do to help drive that cost down helps all of us in the long run. (0723-6-2

[Murphy, Mike])

Response: The comment suggests the proposed nuclear reactors could help decrease 

electrical bills. The impact of the proposed nuclear reactors on electricity prices is beyond the 

scope of this EIS. No changes were made to the EIS in response to this comment. 

Comment: ...our Chamber hereby supports the proposed Turkey Point Units 6 and 7 which will 

result in the creation of additional jobs, reliability and significant infrastructure improvements. 

(0723-2-9 [Trowbridge, Mark])

Appendix E October 2016 E-315 NUREG–2176
Response: This comment expresses support for the proposed nuclear reactors due to their 

impacts on the economy and infrastructure, but does not introduce any new information to 

inform the assessment of impacts. Impacts on the economy are assessed in Sections 4.4.3 and 

5.4.3 (Economic Impacts on the Community) and impacts on the infrastructure are assessed in 

Sections 4.4.1 and 5.4.1 (Physical Impacts). No changes were made to the EIS as a result of 

this comment. 

Comment: So if you want to give FPL credit for employing people you ought to also on the 

other hand look at all the jobs they've been destroying. (0723-12-8 [Henry, Jim])

Response: This comment refers to jobs that would be created if solar power were developed 

instead of the proposed nuclear reactors. The consideration of jobs created by alternative 

generating technologies is outside the scope of the EIS. No changes were made in the EIS in 

response to this comment. 

Comment: They pay very little tax in the way of after-tax profits, their actual corporate tax rate 

in 2005 to 2009 averaged 1.3 percent. They're one of the lowest taxpayers in the United States 

because they take advantage of unaccelerated appreciation and being able to write off a lot of 

that expenditure. (0723-12-2 [Henry, Jim])

Response: The tax impacts of the proposed nuclear reactors area assessed in Sections 4.4.3 

and 5.4.3 of this EIS. The taxes paid by a licensee are outside the scope of the NRC's 

authority. No information is provided in the comment that would alter the analysis done in those 

sections. No change was made in the EIS in response to this comment. 

Comment: And I want to echo the sentiments of the lady from the Roads neighborhood who's 

against this plan as well, because I personally will be affected. I'm a lifelong resident of the 

Roads neighborhood and I echo the sentiments of the City Attorney and the City, in saying it's a 

bad idea to make our neighborhood look ugly with those ugly power lines that nobody wants. 

Nobody from the Roads wants those power lines. And so it's going to be the ugly thing to see on 

top of those banyan trees on Coral Way, and it's just going to kill the historic value of the, you 

know, the historic nature of the neighborhood. (0721-31-2 [Almirola, Alejandro])

Response: The commenter expresses opposition to the visual impact of the transmission lines 

to serve FPL's proposed Turkey Point Units 6 and 7, as well as the impact of transmission lines 

on the historic character of the neighborhood. Although electrical transmission is outside the 

regulatory authority of the NRC, the review team considered the visual impacts of transmission 

lines in Sections 4.4.1.6 and 5.4.1.6 (aesthetics), and concluded the aesthetic impacts of 

transmission lines would be minor. Historic and cultural impacts are assessed in Sections 4.6 

and 5.6. No new information was provided by the commenter that was not already considered 

in the analysis. No changes were made to the EIS as a result of this comment. 

Comment: The construction industry is the second larger employer in Miami-Dade County. 

And there have been talk before about the minorities on this project, the impact of this project on 

the minorities. The majority of the workers in the construction industry are minority, members of 

the minority community, and we need -- we need the additional power in order to keep this 

construction boom going. (0721-27-2 [Rodriguez, Manuel J.])

Response: Impacts on minority and low-income populations are discussed in Sections 4.5 and 

5.5. No new information was provided in the comment that was not already considered in the 

analysis. No changes were made to the EIS in response to this comment. 

Appendix E NUREG–2176 E-316 October 2016
Comment: Finally, there's an economic issue. The Impact Statement talks about benefits to the 

County, economic benefits. It was modeled by FPL. They talk about creating jobs. They talk 

about other benefits to the economy. But those are temporary jobs that are created. Those are 

temporary benefits during construction only. (0721-2-13 [Stoddard, Philip K.])

Response: The EIS discussed both temporary and long-term impacts of the proposed nuclear 

reactors during construction and operations. This analysis was included in Sections 4.4 and 5.4 

of the EIS. No changes in the EIS were made in response to this comment. 

Comment: 5) Analysis of Visual, Lighting, and Noise Impacts 

The DEIS does not sufficiently analyze impacts to NPS scenery, night skies, nocturnal habitat, 

acoustic environment and wildlife health to determine impacts to these resources and values. 

Effects to these resources are of particular importance to the NPS because they affect wildlife 

movement and habitat use, and the visitor experience within both NPs. NPS recommends NRC 

update its analysis of impacts to these resources and values, as well as, develop photo 

simulations. 

As discussed, the DEIS virtually dismisses the visual impacts of the plant construction, plant 

profile, powerline corridor and other powerline infrastructure on Biscayne and Everglades NPs. 

Moreover, we contend that the computer illustration of the facility found in the DEIS is 

inadequate and that a full visual analysis that include photo simulations is warranted. As a 

result, the NPS and the public have not been able to assess how this major energy project will 

impact the viewscape at Biscayne and Everglades NPs. Photo simulations are routinely 

completed for environmental reviews relating to energy infrastructure and are a critical 

component that informs the NEPA process as to the relationship of people with the natural and 

physical environment. [Footnote 1: 40 CFR part 1508.14] The NPS requests that a visual 

analysis be included in a revised DEIS that includes development of photo simulations of the 

proposed project and examines the visibility of project components and the level of change in 

the existing landscape. 

The NPS is happy to collaborate with the NRC to identify important vantage points from within 

Biscayne and Everglades NPs for these simulations. Based on our experience working with 

other agencies, we can also share with you our suggested guidelines on site photography, 

simulations, and output. Furthermore, the NRC can utilize photo simulations included in the 

NPS's Acquisition of FPL land in the East Everglades Expansion Area DEIS. (0622-1-11 [Austin, 

Stan])

Comment: The NPS also encourages the NRC to further analyze potential increases in light 

pollution and resultant impacts related to construction and operation of Turkey Point Units 6 and 

7. As construction would likely be ongoing throughout the night, construction lighting under 

standard practices can adversely affect night sky quality by contributing to glare and 

atmospheric scattering (light domes). Glare can directly affect nearby wildlife and visitors while 

light domes can affect wildlife habitat quality, overall photic environmental conditions, and 

scenic and scientific views of the night sky. The reflective nature of water can exacerbate the 

scattering of construction lighting more so than an equivalent project on land. Impact from 

artificial light can be reduced by limiting where lighting will occur, limiting hours of operation, 

limiting nighttime operation during seasonally sensitive periods (e.g., bird migration), limiting 

total lumen output of artificial lighting (either per fixture or by calculating lumens per acre), and 

directing lighting downward and shielding the fixtures. 

Appendix E October 2016 E-317 NUREG–2176
In addition to the lighting design criteria discussed in section 5.3.1, the NRC should consider 

other lighting areas and lighting color. Warmer lighting colors typically have less ecological 

impact and adequate lighting can be achieved with less amount of lighting than is often used. 

We also encourage the NRC to consider whether illumination of Units 6 and 7, which would be 

sited within a key area within the Atlantic Flyway, would impact migratory birds. This evaluation 

should address whether new lighting may also increase illumination of existing structures, 

thereby increasing risk to migratory birds. The NPS requests that lighting plans, analysis of 

lighting impacts, and mitigation techniques be included in revisions to the DEIS. 

NPS recommends that section 5.3.1 be updated to include information related to the effects of 

noise on NPS resources and acoustic environment in Biscayne NP. Currently, only a day-care 

facility and Homestead Bayfront Park are categorized as "sensitive receptors," however we 

maintain that NPS resources should also be considered sensitive to noise. Changes in overall 

decibel levels, maximum decibel levels, and audibility can have effects on the acoustic 

environment, wildlife interactions, and park visitors. The DEIS does not appear to analyze noise 

impacts on Biscayne NP. We encourage the NRC to consider the relationship between 

increased noise generated at the facility compared with the natural ambient baseline sound 

levels for Biscayne NP. The NPS recommends that further documentation and environmental 

analysis include: 

Determination of the natural ambient acoustic condition that exists in Biscayne NP; 

Assessment of the cumulative noise output of all noise sources on site during construction and 

under full operating conditions; 

Determination of the distance at which noise will attenuate to natural ambient levels. The 

inclusion of a noise map with contours would be helpful; 

Calculation of noise levels at the park boundary and comparison with natural ambient levels; 

Assessment of the effects that these increased noise levels would have on park wildlife and 

visitors; and 

The use of an analytical framework for evaluating impacts that is appropriate for a national park 

setting (e.g., not a community noise framework). 

The NPS's "Baseline Ambient Sound Levels in Biscayne National Park" report from November 

2011, which has already been shared with the NRC, should prove helpful in gathering this 

information. (0622-1-13 [Austin, Stan])

Response: These comments suggest that further analysis is needed regarding the impacts of 

light and noise at the Turkey Point site. As explained in Sections 4.4.1 and 5.4.1, the review 

team assessed the potential impacts from construction- and operations-related light at the 

Turkey Point site and concluded that the visual impact of the building of proposed Units 6 and 7 

would be noticeable but temporary and the visual impacts of operations would be minor. Noise 

impacts on the general public would be minimal given the use of the mitigation actions included 

in applicable regulations and because noise attenuates rapidly with distance, intervening 

vegetation, and variations in topography. NEPA guidance states the depth and detail of an 

analysis must be proportional to the expected severity of the impacts. Because the staff 

determined small impacts from light and noise, no changes were made in the EIS in response to 

these comments. 

Appendix E NUREG–2176 E-318 October 2016
Comment: Contrary to the assertion of the NRC (EIS) that the "socioeconomic "effects of 

building and operating the proposed reactors #6 and #7, are "small and beneficial" I believe the 

actual risk to the population of South Florida is astronomical and potentially devastating. (0358-2

[Norman, Ronald])

Response: This comment expresses the view that the risks to the population of South Florida 

are very high. The review team analyzed impacts on people from construction and 

preconstruction (Chapter 4) and from operations (Chapter 5) of the proposed nuclear 

reactors. Summaries of these impacts can be found in Section 4.12 (Summary of Construction 

and Preconstruction Impacts) and Section 5.12 (Summary of Operational Impacts). The 

analysis does not support the view that the "risk to the population of South Florida is 

astronomical and potentially devastating," and the comment does not introduce any new 

information not already considered in the analysis. No changes were made to the EIS in 

response to this comment. 

Comment: Florida law allows FPL to charge its customers for the licensing and construction 

costs for this project. In the past three years, FPL has charged us $209 million. Even if FPL 

never completes the new reactors, it keeps our money. These charges include new 

transmission lines in Everglades National Park and the heart of Miami-Dades dense commercial 

and residential neighborhoods. Massive 105-foot tall towers along Dixie Highway would cut 

through Pinecrest, South Miami, Coral Gables, Coconut Grove, and then Brickell, on their way 

into downtown Miami, carving tens of millions annually from the countys tax base and killing 

thousands of jobs in the process. (0675-4 [Rodriguez, Jose Javier])

Response: This comment expresses opposition to the proposed nuclear reactors because of 

adverse effects on consumer rates as well as the adverse effects of the associated transmission 

lines on the county’s tax base and jobs. The NRC does not assess impacts on electricity rates 

and electrical transmission is outside the regulatory authority of the NRC. In addition, the 

comment did not provide evidence to support the claim that transmission lines would have an 

adverse impact on the tax base and jobs. Although the review team recognizes the potential for 

land use conflicts in Chapter 7, Cumulative Impacts, the impact of the transmission line on 

property values (and consequences for the tax base) is not possible to determine based on the 

existing literature (see Section 4.4.4.3 for a discussion). No change was made to this EIS as a 

result of this comment. 

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 2.5.2.6, Page 2-

179, Lines 27-29 "There are 35 colleges or universities that are accredited.... that offer 

professional and paraprofessional training (FPL 2014-TN4058)." ER Subsection 2.5.2.8.3 ER 

Table 2.5-43 "There are 12 colleges or universities that are accredited...that offer professional 

and paraprofessional training within 50 miles..." ER Table 2.5-43 also identifies 12.colleges.

(0619-2-21 [Maher, William])

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 4.4.2, Page 4-

104, Lines 8-11 Subsection 4.4.2, Page 4-105, Lines 37-38 On page 4-104: "...assessment of 

population impacts is based on FPL's estimated peak project workforce analysis (FPL 2014-

TN4058). The proposed project schedule assumes 10 years-- 36 months for preconstruction 

activities and 84 months for NRC-authorized construction--to build both units....." On page 4-

105: "Also shown is the 36 months of preconstruction activities." ER Subsection 3.10.1.1 ER 

Table 3.9-1 ER Table 3.10-2 DEIS Figure 4-6 ER Figure 3.10-1 ER Figure 3.10-3 "As described 

in Section 3.9, preconstruction activities could occur 39 months (start of 2nd quarter 2013 

through end of 2nd quarter 2016)... before the start of safety-related construction for Units 6 & 

Appendix E October 2016 E-319 NUREG–2176
7." ER Tables 3.9-1 and 3.10-2 project 39 months for preconstruction activities prior to safety 

related construction. (Note DEIS Figure 4-6 and ER Figures 3.10-1 and 3.10-3 also illustrate 39 

months for preconstruction activities.) (0619-2-24 [Maher, William])

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 4.4.4.5 Page 4-

118 through 4-119 Lines 39 through 3 Subsection 5.4.4.5, Page 5-77, Lines 9-10 On page 4-

118 and 4-119: "...15.4 percent of students in Miami-Dade County...attend private schools (FPL 

2014-TN4058)...Fifteen point four percent of in-migrating students..." Similarly, on page 5-77 

"...15.4 percent of students County...attend private schools (FPL 2014-TN4058)." ER 

Subsection 4.4.2.2.8.3 ER Subsection 5.8.2.2.8.3 "...assumption...percentage of inmigrating...private school... (15 percent)...The assumption...percentage of in-migrating...private 

schools...attending private schools in Miami-Dade County (15 percent). (This percentage, 15 

percent, is also consistent with ER Subsection 5.8.2.2.8.3) (0619-2-25 [Maher, William])

Response: The text in Sections 2.5, 4.4, and 5.4 was revised to be consistent with Revision 6 

of the ER. 

Comment: In some portions of the document, there are descriptions of the area within the 50 

mile radius as highly developed, densely populated, with some of the highest incomes in the 

county. However, language in other sections of the document identifies the proposed plant site 

location as if it were located within a completely undeveloped area. Turkey Point lies within 12 

miles from the Cities of Homestead and Florida City, within 8 miles from the developed area 

Ocean Reef on North Key Largo, 16 miles from the city of South Miami, and 20 miles from 

downtown Miami. The 50 mile radius, the Gateway to both National Parks, includes Miami-Dade 

County with the highest and densest (by land area) population in the State of Florida. That 

population is in large part concentrated along the coast and along U.S. Highway One north of 

the parks. The DEIS does not sufficiently evaluate this population and its location particularly 

with respect to use and economic contribution of their travel to the NPs (0622-1-30 [Austin, Stan])

Response: The EIS acknowledges both the significant population centers near Turkey Point 

and the large areas of undeveloped land in the vicinity included in the nearby National Parks, 

aquatic preserves, and mitigation banks. Section 2.5 of the EIS addresses the Socioeconomic 

setting of the Turkey Point site and describes the population and significant communities in the 

counties surrounding the site. Section 2.2 describes the various land uses in the surrounding 

region. The impacts of building and operating the proposed new units at Turkey Point on local 

populations and on undeveloped regions are described in Chapters 4 and 5 of the EIS. No 

changes were made to the EIS as a result of this comment. 

Comment: There are over a dozen threatened and endangered species in Biscayne Bay and 

nearly half a million visitors visited Biscayne National Park in 2013. And there are -- there's an 

active community of fishermen, boaters, divers, snorklers and recreational and commercial 

fishing area that is important. And you know, those jobs and those livelihoods and that culture 

and heritage should be considered in this process as well. Even if you've never visited the 

Coral Reef you're never going to catch lobster, you're never going to go fishing for permit.

(0722-7-7 [Silverstein, Rachel])

Response: The comment expresses concerns about the potential impacts to tourism, 

recreation, and ecological impacts to the nearby Biscayne Bay including the Biscayne National 

Park. The review teams agree that Biscayne National Park is an important resource for marine 

biodiversity and has added an expanded discussion to Sections 4.3.1 and 5.3.1 of the potential 

effects of the project on ecological resources of the South Florida ecosystem as they pertain to 

Appendix E NUREG–2176 E-320 October 2016
both Biscayne and Everglades National Parks and the experience of visiting these 

parks. Furthermore, Sections 4.4 and 5.4. provide the review teams analysis of the potential 

socioeconomic impacts from construction and operation of the proposed Turkey Point Units 6 

and 7. 

E.2.12 Comments Concerning Environmental Justice 

Comment: Environmental Justice (EJ). Pursuant to Executive Order 12898, the DEIS (Section 

2.6) includes demographic and impact data, including minority and low-income populations. The 

project team assessed the potential for disproportionately high and adverse health and 

environmental impacts, and concluded that there are no environmental pathways where the 

identified EJ populations in the 50-mile region would be likely to suffer disproportionately high 

and adverse environmental or health impacts as a result of the proposed project (page 10-7). 

Communities may experience both benefits and burdens associated with this project, and 

should be involved in meaningful discussions with the project team throughout the decisionmaking process. We encourage the project team to continue coordinating with the communities 

that will be impacted by the licensing and permitting actions. Community involvement and 

discussion of project issues should take place throughout project planning. In particular, local 

communities have voiced their concerns regarding transmission line routing and potential 

economic impacts resulting from the location of these lines. Demographics: The NRC includes 

demographic information related to minority and low income populations. The project area 

contains minority and low-income populations within the 50 mile project area that includes 

Miami-Dade County and portions of Broward, Collier, and Monroe Counties. U.S. Census data 

from the American Community Survey was used to evaluate minority and low-income 

populations prior to the identification of disproportionate impacts. Thresholds that include the 

50% Criterion and the Meaningfully Greater Criterion were used to compare race and income 

data from the block group level to the reference population at the State. The use of these 

thresholds are consistent with the Council for Environmental Quality EJ Guidance. Analyses: 

Based on our review, EPA has concerns regarding how the Meaningfully Greater Criteria was 

applied. The DEIS used a 20% threshold, however, the manner in which it is applied or 

calculated can mean that minority or low-income populations may not be appropriately 

identified. In the DEIS, 20% is simply added to the reference population (i.e., 20% threshold 

+42.2% minority population = 62.2% minority threshold). However, the way the threshold should 

be used to yield consistent benchmarks involves taking 20% of 42.2% minority population, 

which is 8.44, and adding that to 42.2, resulting in a benchmark of 50.64%. Using this 

mathematical calculation will yield consistent benchmarks that will be 20% higher than the 

reference population, regardless of the initial percent population value. Meaningful engagement: 

Communication with minority and low-income populations and other interested individuals, 

community, community and organizations should consider (as appropriate) encompassing 

adaptive and innovative approaches to both public outreach, (i.e. disseminating relevant 

information),and participation (receiving community input), since minority populations and lowincome population often experience barriers to engagement. NRC indicates that there was 

active phone and field consultations with various organizations and study of applicant's 

Environmental Report (ER) to identify affected populations and unique exposure pathways. 

Recommendations: The FEIS EJ sections should include information about the outreach and 

participation methods to minority and low-income populations that may have limited English 

proficiency, particularly since migrant workers that are primarily Hispanic are located 

approximately 3 miles from the proposed site. In addition, the FEIS should also include a 

summary of any EJ comments or concerns, and the NRC's response to those comments.

(0617-3-2 [Mueller, Heinz J.])

Appendix E October 2016 E-321 NUREG–2176
Response: Application of the meaningfully greater criteria is consistent with NRC 

regulations. Information about the outreach and participation methods, including comments 

received and responses, is provided in Appendices B through F of this EIS. No modifications to 

the document were made in response to this comment. 

Comment: EJ Impacts: The NRC's EJ analysis includes a summary of noise, air quality, water 

resource and traffic impacts on affected minority and low-income populations, including Native 

American tribes and populations that are dependent on subsistence resources. According to the 

DEIS, there are no disproportionate high and adverse impact to EJ populations. 

Recommendations: Based on our review of the EJ section of the DEIS, it was difficult to 

identify the impacts to minority and low-income populations. Most of the impacts are 

marginalized for various reasons, including proximity. While the DEIS summarizes the impacts 

associated with the construction of the reactors and traffic, it is unclear whether there are other 

impacts that should be considered, such as impacts associated with transmission lines 

constructed through minority and low-income communities. The FEIS should clarify whether 

these and other impacts will primarily be borne by EJ communities. 

Local residents should be involved in meaningful discussions with the project team throughout 

the decision-making process. Efforts should be made to meaningfully involve and outreach to 

residents near the site and with increased visibility to the facility's structures and its emissions. 

The project team should take community concerns regarding transmission line routing and 

impacts into consideration, and these concerns should be fully addressed to the extent feasible. 

Dialog between the project team and the communities should continue. (0617-3-3 [Mueller, Heinz 

J.])

Response: Section 2.6.1 (Methodology) explains the NRC's approach to the environmental 

justice (EJ) analysis. The review team investigated special pathways by which EJ populations 

of interest could be disproportionally affected by adverse impacts. No impacts considered small 

could lead to disproportionately high and adverse human health or environmental effects without 

special pathways through which EJ populations of interest could be disproportionately 

affected. Sections 4.5 and 5.5 summarize the results of the analysis. No special pathways 

were identified through which EJ populations of interest could be disproportionately affected by 

adverse impacts. Although electrical transmission is outside the regulatory authority of the 

NRC, the analysis includes the potential impacts of transmission lines associated with the 

proposed nuclear reactors. Recommendations for meaningful outreach and involvement of the 

local communities is outside the NRC's NEPA and Executive Order 12898 requirements. No 

changes were made to the EIS in response to this comment. 

Comment: Let me make a mention in terms of environmental justice. Under Federal guidelines 

it's critical that Federal agencies review environmental justice impacts. Miami-Dade County is a 

very diverse county, as many as 80 to 85 percent minority. I think I've not seen a proper 

analysis in terms of that. The impact of this on low income people, on minorities, and I think that 

needs to be reviewed as well. (0721-7-6 [Edmond, Gabriel])

Response: The comment suggests no proper EJ analysis was done but no supporting details 

are provided in the comment. The review team followed its guidance under NUREG-1555, the 

Environmental Standard Review Plan, in its assessment of EJ impacts. The EJ analysis is 

presented in Sections 4.5 and 5.5. No changes were made to the EIS in response to this 

comment. 

Appendix E NUREG–2176 E-322 October 2016
Comment: And Miami-Dade County, as everybody around here knows, is -- has a 

disproportionally high population of minority members and poor. And so the damage to the 

County's economy and the tax base and the job loss is going to be greater in this 

disproportionally poor and minority community than elsewhere. And I think that's a flaw in the 

site selection process that needs to be addressed. (0721-2-15 [Stoddard, Philip K.])

Response: The comment requests that impacts on disproportionally poor and minority 

communities be addressed. Sections 4.5 and 5.5 address impacts on minority and low-income 

populations in the study area. No changes were made to the EIS in response to this comment. 

E.2.13 Comments Concerning Historic and Cultural Resources 

Comment: I agree with the DEIS review team's conclusion that the impacts from the 

construction and preconstruction activities of Units 6 and 7 will be small (and therefore unlikely 

to impact cultural resources listed on or eligible for listing on the National Register of Historic 

Places, or NRHP). I also agree that the impacts from the construction and preconstruction 

activities for the proposed transmission lines and other offsite activities have the potential to 

adversely affect eligible NRHP resources. (0139-2 [Parsons, Timothy A.])

Response: The comment from the Florida SHPO express agreement with the findings of the 

historic and cultural resources analysis in the draft EIS. No changes were made to the EIS as a 

result of the comment. 

Comment: In a letter to the Corps' Miami Permits Section dated April 2, 2015 (DHR #: 2015-

1221), our office requested that all previously unsurveyed portions of the offsite APE be 

subjected to professional archaeological survey and that the resultant report be submitted to us 

in order to facilitate Section 106 review. I look forward to continuing Section 106 consultation 

with the Corps of Engineers to assess effects to the resources within the area of potential 

effects, and to consult on any necessary avoidance, minimization, or mitigation strategies that 

might be necessary. (0139-3 [Parsons, Timothy A.])

Response: The comment from the Florida SHPO states that future Section 106 procedures will 

be required of the USACE. These procedures include professional surveys of previously 

unsurveyed portions of the offsite APE (primarily along the transmission line corridors), and 

submission of the resulting report to the SHPO. These requirements are described in the 

EIS. No changes were made to the EIS as a result of these comments. 

Comment: Tribal Coordination. Consultation. The EPA encourages government to 

government consultation with the Seminole Tribe of Florida and Miccosukee Tribe of Indians of 

Florida at all levels of decision-making. The EPA works closely with both Tribes on Evergladesrelated matters, and is committed to working with other federal partners to prioritize the Tribes' 

water quality and water management concerns. (0617-3-4 [Mueller, Heinz J.])

Response: The NRC and the USACE have engaged in government-to-government 

consultation with the Seminole Tribe of Florida and Miccosukee Tribe of Indians of Florida as 

described in Section 2.7 of the EIS. The NRC appreciates that the EPA also works closely with 

both Tribes. No changes were made to the EIS as a result of this comment. 

Comment: National Historic Preservation Act (NHPA). Historic Preservation. NRC's 

evaluation anticipates that indirect visual impacts on National Register-eligible buildings will 

occur in the transmission line corridor. Specific impacts are to be determined based on USACE 

Appendix E October 2016 E-323 NUREG–2176
impact evaluation related to transmission lines on cultural resources. FPL agreed to develop a 

work plan for additional cultural resources studies related to requirements for the transmission 

line corridors and offsite facilities. The DEIS (Section 2.7) describes the project team's 

coordination with the Florida State Historic Preservation Office (SHPO) and tribes. The 

document concludes that the potential impact of license renewal on cultural and historic 

resources is minimal. The USACE is the lead federal agency for Section 106 of the National 

Historic Preservation Act (NHPA), and the consultation for this project is in progress. 

Recommendations: Compliance with Section 106 of the National Historic Preservation Act 

(NHP A) should be documented as the project progresses. The FEIS should include an update 

regarding the mitigation measures developed in consultation with the Florida State Historic 

Preservation Officer (SHPO). The FEIS should also include an update of coordination activities 

with the SHPOs and tribes, along with the finalized decision documents pursuant to Section 106 

of the NHPA, if available. The EPA defers to the SHPOs and tribes on these issues. EPA 

encourages government-to-government consultation with the Seminole Tribe of Florida and 

Miccosukee Tribe of Indians of Florida at all levels of decision-making. (0617-3-5 [Mueller, Heinz 

J.])

Response: The NRC and the USACE agree with the EPA recommendations. Section 2.7 was 

modified to include government-to-government consultation meetings with the Tribes that took 

place subsequent to the publication of the draft EIS. Section 106 consultation between the 

USACE, the Seminole Tribe of Florida, and Miccosukee Tribe of Indians of Florida is 

ongoing. Section 2.7 of the EIS was updated to include the current status of National Historic 

Preservation Act (NHPA) Section 106 consultation. Special conditions that the USACE typically 

uses for permitting actions dictate that all work and ground-disturbing activities shall halt within a 

100-meter radius of any unanticipated discovery of cultural materials or human remains, and 

that the USACE shall notify the Florida State Historic Preservation Office(r) (SHPO) and 

appropriate Tribal Historic Preservation Officers (THPOs) of the finds. Sections 4.6 and 5.6 of 

the EIS were modified to clarify the USACE's special conditions regarding work stoppage. 

Comment: There are instances in the DEIS where, due to the timing of events with respect to 

drafting the DEIS, specified dates, or future actions, indicated in the DEIS have passed. 

Instances in the DEIS include (emphasis added): a. DEIS Section 4.6, Page 4-124, Lines 31-33 

and DEIS Section 5.6, Page 5-82, Lines 2-3: The DEIS (Section 4.6) states: "(3) if consultation 

with the Florida SHPO concluded with a finding of no historic properties affected... (FDHR 2010-

TN1455; FPL 2014-TN4058, Appendix 2.5A)..." Similarly, The DEIS (Section 5.6) states: "(4) if 

consultation with the Florida SHPO concluded with a finding of no historic properties 

affected..." However, as indicated in DEIS Section 4.6, ER Subsection 4.1.3.1, and ER 

Subsection 5.1.3, the work plan was submitted and Florida SHPO concurred. DEIS Section 4.6, 

page 4-123, lines 34-36 states: "The Florida SHPO concurred with FPL's informal determination 

of "no historic properties affected" (Appendix 2.5A in FPL 2014-TN4058)." ER Subsection 

4.1.3.1, states: "The survey identified no newly or previously recorded archaeological sites or 

historic resources...The Work Plan was submitted to SHPO and concurrence with the 

recommendation was received by FPL (FDOS Jul. 2009a)." And, ER Subsection 5.1.3, states: 

"Based on the findings contained in these two reports...no further surveys or investigations are 

warranted at the plant or associated non-linear facilities due to the lack of any cultural resources 

in these areas. The SHPO has concurred with these recommendations (FDOS Jul 2009a)."

(0619-1-10 [Maher, William])

Response: This comment pertains to a discrepancy in the draft EIS where similar wording in 

Sections 4.6 and 5.6, describing a SHPO finding of no historic properties affected for the Units 6 

and 7 onsite APE, conflicts with subsequent wording in the same sections. The NRC agrees 

Appendix E NUREG–2176 E-324 October 2016
with the comment. Sections 4.6 and 5.6 were revised to clarify that consultation with the Florida 

SHPO did reach a finding of no historic properties affected for the Units 6 and 7 onsite APE. 

Comment: There are instances in the DEIS where there are inconsistencies and/or 

discrepancies relating to authorizations, permitting and certifications. Instances in the DEIS 

include (emphasis added):...DEIS Section 4.6, Page 4-124, Lines 12-16: The DEIS states: "In 

addition, the USACE, the Florida SHPO (FPL 2014-TN4058, Appendix 2.5A), and the MiamiDade County Office of Historic and Archaeological Resources (NRC 2010-TN1458) have 

required FPL to conduct surveys and other studies of offsite areas and, if practicable, 

avoid National Register-eligible sites or mitigate effects in an acceptable manner, as determined 

through consultation with these agencies." The USACE permit has not been issued and there 

are no USACE requirements in the Conditions of Certification. (0619-2-10 [Maher, William])

Response: This comment pertains to a statement in the draft EIS where the wording implies 

that USACE has already issued requirements concerning archaeological survey and other 

required studies of the offsite APE. The commenter correctly notes that the USACE has not yet 

issued any specific conditions concerning these requirements. The NRC agrees with the 

comment. Section 4.6 was modified to remove reference to the USACE in the State-level 

review. 

Comment: There are instances in the DEIS where there are inconsistencies and/or 

discrepancies relating to authorizations, permitting and certifications. Instances in the DEIS 

include (emphasis added):...DEIS Section 5.6, Page 5-81, Lines 33-40: The DEIS states: "All 

work within a 100-meter radius would be halted while the appropriate specialist consults with 

the Florida SHPO and USACE Project Manager, per the Special Conditions of the DA 

permit, if one is issued...Any ground-disturbing activity that impacts a historic property that is 

potentially eligible, eligible to the NRHP, or contains human remains, all ground disturbing 

activities shall halt within 100-meter radius buffer of the site, and the USACE Project 

Manager and SHPO notified. Work shall not commence without written notice from both the 

USACE and SHPO." FPL has not included nor has SHPO required a specific "work halting 

radius" in the work plans. (0619-2-13 [Maher, William])

Response: This comment pertains to statements in the draft EIS that describe a 100-meter 

radius within which work would halt should there be an unanticipated discovery of a cultural 

resource during operations. The special conditions that the USACE typically uses for permitting 

actions dictate that all work and ground-disturbing activities shall halt within a 100-meter radius 

of any unanticipated discovery of cultural materials or human remains, and that the USACE 

shall notify the Florida SHPO and appropriate THPOs of the finds. Sections 4.6 and 5.6 of the 

EIS were modified to clarify the USACE’s special conditions regarding work stoppage. 

Comment: DEIS Subsection 2.7.3, Page 2-198, Lines 30-36: The DEIS states, "The indirecteffects APE...has been set at 500 ft on either side of the centerline of the alignment...(FPL 

2009-TN1513; FPL 2009-TN1515; FPL 2011-TN95; FPL 2013-TN2941)." One of the cited 

references, (FPL 2009-TN1515), "Cultural Resource Assessment Survey Work Plan for the 

Turkey Point Units 6 & 7 Associated Linear Facilities", states: "For the purposes of this 

preliminary analysis, Janus Research defined the areas of potential effects (APE) as 100 feet 

from each side of the East Preferred Corridor ...In addition, a review of previously recorded 

historic resources within 500 feet of each side of corridors, pipelines, roads, and bridges was 

conducted." The final APE will be established in consultation with the Florida Department of 

State, Division of Historical Resources and State Historic Preservation Office (DHR/SHPO)." 

(emphasis added) (0619-3-15 [Maher, William])

Appendix E October 2016 E-325 NUREG–2176
Response: This comment concerns the definition of the Area of Potential Effect (APE) for 

Section 106 of the NHPA, which, as stated in the comment, will be defined by the USACE in 

consultation with the SHPO. The EIS text in Section 2.7 was modified to clarify that, for 

purposes of the review team's analysis, a preliminary APE of 500 ft on either side of the 

centerline for linear facilities was used to guide the data collection. This preliminary APE may or 

may not correspond to the final APE adopted by the USACE and SHPO because consultation is 

not completed for the transmission line route. 

Comment: DEIS Subsection 2.7.3, Page 2-199, Lines 25-28: The DEIS states: "In addition to 

the desktop research for the transmission line APE, FPL also conducted a search of the 

National Register and Florida SHPO site files for a distance of 1.2 mi from the eastern and 

western transmission line corridors. The research for the offsite linear facilities identified 359 

resources and 16 resource groups located with 1.2 mi of these facilities." The cited reference 

(FPL 2009-TN1513) "Cultural Resource Assessment Survey Work Plan for the Turkey Point 

Units 6 & 7 Site and Associated Non-Linear Facilities" did not contain information regarding a 

search of the National Register and Florida SHPO site files for a distance of 1.2 mi., nor did FPL 

conduct a search of the National Register and Florida SHPO site files for a distance of 1.2 mi 

from the eastern and western transmission line corridors. (0619-3-16 [Maher, William])

Response: This comment refers to a statement in the EIS that refers to a background records 

search conducted by FPL of the area encompassing 1.2 mi around the offsite linear facilities, 

including transmission lines. The comment indicates that the cited reference in the draft EIS, 

prepared by FPL's consultant, does not report on this records search, and also states that FPL 

did not conduct a search of the National Register of Historic Places and Florida SHPO site 

files. The NRC agrees that FPL's consultant did not conduct the records search, and that the 

draft EIS should not have cited the consultant's report (FPL 2009-TN1513). Rather, reference 

should have been made to the Turkey Point Nuclear Plant COL ER (FPL 2014-TN4058), which 

does contain the information. The NRC therefore disagrees with the comment that FPL has not 

conducted a records search within 1.2 mi of the transmission line corridors. As stated in the 

COL ER in Section 2.5.3.6 (FPL 2014-TN40). "A search of records maintained by the National 

Park Service, Florida Division of Historical Resources, Miami-Dade County, and city of 

Homestead was conducted to identify significant cultural resources located within 1.2 miles of 

the transmission lines, substations, and reclaimed water pipelines." Section 2.7 was revised to 

include the correct citation and to clarify the source of the information for the records search. 

Comment: A large number of archaeological sites have been recorded throughout southeast 

Florida and as noted in the draft EIS, numerous sites are known to occur near the proposed 

transmission line corridors. We are concerned with the possible impacts of any undertaking on 

cultural resources which may be present within the area of potential effect. Since it does not 

appear that either of the possible transmission line corridors have been subjected to a 

systematic Phase I cultural resources assessment survey, we request that such a survey be 

conducted at the appropriate time and that the results of such survey be provided to the STOFTHPO for review and comments. If any preliminary or desktop/archival investigations have 

already been completed we would like to be provided copies of those reports. (0727-1 [Mueller, 

Bradley M.])

Response: Preliminary desktop surveys have been completed for the proposed transmission 

line corridors and are summarized in Section 2.7 of the EIS. The USACE would provide the 

Seminole Tribe of Florida with these reports and any other reports as they are 

developed. Phase I cultural resources surveys would be conducted at the appropriate time and 

the results of such surveys would be provided to the Seminole Tribe of Florida through 

Appendix E NUREG–2176 E-326 October 2016
continued consultation between the USACE and the Seminole Tribe of Florida. No changes 

were made to the EIS as a result of this comment. 

Comment: Our experience has shown that archaeological sites in the Everglades have a high 

likelihood of containing burial resources (human skeletal remains, etc.). This is especially 

relevant with regards to the West Consensus Corridor. It is the Tribes position that the remains 

of ancestors should be left undisturbed and every effort should be made to identify sites in 

advance of any ground disturbance, and those sites avoided whenever feasible. We also 

request that at the appropriate time, prior to any ground disturbing activities, the USACE, the 

STOF-THPO, and other appropriate parties develop protocols to follow in the event of the 

unanticipated discovery of human remains during any phase of the proposed undertaking.

(0727-2 [Mueller, Bradley M.])

Response: These comments from the Seminole Tribe of Florida provide information about the 

likely presence of sensitive cultural resources, including those containing human remains, within 

the transmission line corridors, and especially the western corridors, and that the Tribe's 

preferred treatment for human remains is preservation in place. They also state that efforts 

should be made to identify such resources prior to disturbance, and that appropriate procedures 

for unanticipated finds should be in place prior to construction. The EIS in Section 2.7 indicates 

that both pre-construction surveys and unanticipated finds procedures would be required by the 

USACE and other agencies prior to construction. Regarding unanticipated finds procedures, 

the special conditions that the USACE typically uses for permitting actions dictate that all work 

and ground-disturbing activities shall halt within a 100-meter radius of any unanticipated 

discovery of cultural materials or human remains, and that the USACE shall notify the Florida 

SHPO and appropriate THPOs of the finds. Work cannot resume until an appropriate treatment 

has been determined. In response, Sections 2.7, 4.6, and 5.6 of the EIS have been modified to 

include information about sensitive cultural resources provided by the Tribe. 

Comment: At least one area considered sacred to the Seminole, a natural spring, is located 

near a portion of the East Preferred Corridor. We are concerned with the possible effects of 

transmission line construction on the hydrology of that area and request that sufficient technical 

analysis be conducted to assess if water flowing to the spring would be interrupted or adversely 

affected. We would also ask that the USACE make available an appropriate, knowledgeable 

individual to discuss the results of such investigations with members of the Tribal community if 

needed. (0727-3 [Mueller, Bradley M.])

Response: Regarding the sacred area near the eastern transmission line corridor, Sections 

2.7, 4.6, and 5.6 of the EIS have been modified to include information about cultural resources 

provided by the tribe. Regarding the effects of transmission line construction on the hydrology 

of the spring, FPL's ER indicates that local dewatering might be required at some of the 

transmission tower bases. This would result in a temporary drop in the groundwater levels near 

the excavation of that particular transmission tower, but the groundwater levels are expected to 

return to normal after the tower base is in place and backfilled. BMP's and requirements of the 

construction permits would assure no introduction of contaminants that could affect the quality 

of the groundwater that may eventually reach springs or wells near the transmission tower 

construction site. If necessary, the USACE would perform analyses to determine the effects of 

transmission line construction on water flowing to the spring, and can provide an appropriate 

knowledgeable individual to discuss the results of the investigation with members of the tribal 

community. 

Appendix E October 2016 E-327 NUREG–2176
Comment: [I]n the USACE's April 4th, 2015 public notice announcing the release and 

availability of the Turkey Point draft EIS, it is stated that a short section of the transmission line, 

presumably the East Preferred Corridor, will cross beneath the Miami River as an underground 

cable system. The area proposed for this crossing, east of Interstate I-95, is rich in aboriginal 

archaeological sites including sites that have been shown to contain numerous burials. We 

caution that any ground disturbing activities in these areas has a heightened potential for 

encountering cultural and/or burial resources and we would like to be consulted further when 

details of such a river crossing are being developed. We again recommend that protocols be 

developed in consultation with the STOF-THPO to deal with the unanticipated discovery of 

human remains. (0727-4 [Mueller, Bradley M.])

Response: This comment from the Seminole Tribe of Florida provides information about the 

likely presence of subsurface cultural resources, including those containing burials within the 

Miami River crossing for the eastern transmission corridor. The tribe requests that they be 

consulted as details of the crossing are developed. Sections 2.7, 4.6 and 5.6 of the EIS have 

been modified to include information about cultural resources provided by the tribe. Details of 

the crossing would be discussed during ongoing consultation between the USACE and the 

Seminole Tribe of Florida. Ongoing consultation would also ensure that the Seminole Tribe of 

Florida is involved in the development of treatment protocols for the unanticipated discovery of 

human remains. 

Comment: Please continue to consult with us on this project since it is occurring within an area 

that is especially important to the Tribe. (0727-5 [Mueller, Bradley M.])

Response: This comment from the Seminole Tribe of Florida reiterates the request for further 

government-to-government consultation regarding the project. In response, Section 2.7 of the 

EIS has been modified to include meetings held among the NRC, USACE, and the Tribe in June 

2015, and to clarify that consultation with the Tribe is ongoing. 

Comment: Thank you for providing the Florida State Historic Preservation Officer with the 

opportunity to comment on the Draft Environmental Impact Statement (DEIS) for the Turkey 

Point Units 6 and 7 combined license application. Pursuant to a letter from NRC dated October 

23, 2014, I note that the U.S. Army Corps of Engineers is now the lead federal agency for 

compliance with Section 106 of the National Historic Preservation Act of 1966, and that the 

Section 106 process will not be completed through the completion of this NEPA document.

(0139-1 [Parsons, Timothy A.])

Response: This comment acknowledges that the USACE would serve as the lead Federal 

agency for NHPA Section 106, and that the Section 106 process would not be completed 

through the NEPA document. These decisions are described in Section 2.7 of the EIS and no 

changes were made as a result of this comment. 

Comment: DEIS Subsection 2.7.1, Page 2-195, Lines 1-2: The DEIS states: "Lake 

Okeechobee and Everglades regions, and Fort Davis...became a base of operations." The 

name should be Fort Dallas as indicated in Cultural Resource Assessment Survey for the 

Turkey Point Units 6 & 7 Site, Associated Non-Linear Facilities, and Spoils Areas on Plant 

Property [Enclosure 1 of FPL's response to NRC RAI No. 2.7-1 (eRAI 5480), DEIS reference 

(FPL2011-TN1512)]. (emphasis added) (0619-3-14 [Maher, William])

Response: Section 2.7 was revised to read Fort Dallas. 

Appendix E NUREG–2176 E-328 October 2016
E.2.14 Comments Concerning Meteorology and Air Quality 

Comment: Greenhouse Gases (GHGs). EPA appreciates the thorough GHG analysis in the 

DEIS, which evaluated the carbon dioxide (CO2) equivalent emissions of the proposed two new 

nuclear power plants in context of building, operating, and decommissioning (Sections 4.7, 

5.7.1, 6.1.3, and 6.3). NRC made conservative GHG-emission estimates by basing them on the 

most GHG-emission intensive nuclear technology (i.e., the uranium fuel cycle). Consequently, 

NRC estimated the total nuclear power plant lifecycle footprint to be 10,500,000 MT CO2e, with 

a 7-year preconstruction and construction phase, 40 years of operation, and 10 years of 

decommissioning. NRC concluded the cumulative impacts from other past, present, and 

reasonably foreseeable future actions on air quality resources in the geographic areas of 

interest would be moderate for GHGs. Additionally, NRC concluded the fossil fuel impacts, 

including GHG emissions, from the direct and indirect consumption of electric energy for fuelcycle operations would be small (page 6-9). Recommendations: EPA recommends that the 

NRC address the following in its FEIS: •The GHG emissions analysis used a 40-year (Section 

7.6.2, p. 7-33) operation period while the Climate Change Effect analysis (Appendix J) 

incorporated the license renewal which could extend operation of the two reactors another 20 

years. EPA recommends NRC's GHG emissions analysis use the 60-year operation period 

similar to that used in Appendix J. •Clarify what the uranium fuel cycle is, i.e., identify the 

activities associated with the production of electricity from nuclear reactions. This could be done 

effectively with a simple diagram. • Whether the GHG emissions analysis in the DEIS addresses 

the GHG emissions associated with decommissioning the existing 2 nuclear power plants (Units 

3 and 4), in addition to the new ones (Units 6 and 7). EPA recommends the decommissioning of 

units 3 and 4 also be included as part of the GHG cumulative-effects analysis. (0617-4-9 [Mueller, 

Heinz J.])

Response: The greenhouse gas (GHG) appendix and the climate change appendix both used 

a 40-year period for the proposed action. The EIS has been revised to delete the sentence "If 

applied for and if granted, license renewal could extend operation of the reactors until 2082 and 

2083" (draft EIS pages I-2, lines 37-38), because it could be interpreted as including a license 

renewal period in the analysis. The uranium fuel cycle is defined in Section 6.1, and a diagram 

of the fuel cycle appears in Figure 6-1. The GHG appendix does not include the emissions from 

decommissioning of the existing Units 3 and 4. As stated in EIS Section 1.2, the proposed NRC 

Federal action is issuance, under the provisions of 10 CFR Part 52, of COLs for authorizing the 

construction and operation of two new Westinghouse AP1000 reactors at the Turkey Point site 

while the proposed USACE Federal action is the decision about whether to issue, issue with 

modification, or deny a Department of the Army permit pursuant to the requirements in Clean 

Water Act Section 404 (40 CFR 230) and Section 10 of the Rivers and Harbors Act of 1899 (33 

U.S.C. 403 et seq.) to authorize certain activities potentially affecting Waters of the United 

States. Decommissioning of existing Units 3 and 4 is not part of the proposed Federal 

actions. Additionally, the decommissioning of power facilities is subject to a separate 

environmental review that must be conducted prior to the start of decommissioning activities in 

order to satisfy the requirements of 10 CFR 50.82(a)(6)(ii), which states that a licensee must not 

perform any decommissioning activity that causes significant environmental impacts not 

previously reviewed. Assessment of GHG emissions associated with decommissioning existing 

Units 3 and 4 will be addressed in the decommissioning environmental review, which will be 

conducted by the NRC when FPL decides to terminate their NRC license for Units 3 and 

4. Additional information about the NRC’s decommissioning environmental review process can 

be found on the NRC’s website at: 

http://www.nrc.gov/waste/decommissioning/process.html#rea. 

Appendix E October 2016 E-329 NUREG–2176
Comment: All the endangered wildlife and sea mammals help us so much in our lives without 

us, the people, really knowing it. This breaks my heart that you people are willing to just destroy 

their lives and our lives by putting toxins into our air that we breath from. (0188-1 [Frederickson, 

Kelly])

Response: The comment concerns the release of air pollutants into the environment. Airquality impacts from operation of the power plant are discussed in Section 5.7.1 and Section 

5.7.2 addresses the cooling-tower impacts. Emissions from the cooling towers would be the 

largest source of air emissions and the air pollutant of most concern. The cooling-tower 

emissions would be required to adhere to the New Source Performance Standards (40 CFR 

60.40Da) and the applicant would need to demonstrate compliance with national ambient airquality standards by acquiring a Prevention of Significant Deterioration (PSD) Permit before 

operating. In Section 5.7.2 it was concluded that air-quality impacts from operating the cooling 

towers would have minimal impacts. No change was made to the EIS as a result of this 

comment. 

Comment: The reactors also threaten to degrade our air quality with excessive chlorides and 

industrial contaminants, creating more health problems for our population. (0340-3 [Tweeton, 

Tanya])

Response: Section 5.7.2 discusses the potential impacts from the cooling-tower salt-drift 

deposition when using saltwater in the cooling system. Impacts were examined both within the 

Turkey Point site and in maximum impact locations near the site. No significant increases were 

found in the salinity levels in the canals or in the nearby environment. Section 5.2.1.3 discuss 

the potential impacts to the environment from the cooling-tower salt-drift deposition when using 

treated reclaimed water in the cooling system. The review team considered Florida 

requirements for reclaimed wastewater and concluded that compliance with Florida 

requirements for the treatment and use of reclaimed wastewater by FPL would be protective of 

public health. No change was made to the EIS as a result of this comment. 

Comment: Turkey Point is located on a coastline in an area that is susceptible to hurricanes, 

flooding, storm surges, and even the possibility of a tsunami. (0710-3 [Platt, George Seth])

Comment: Hurricane Andrew. This agency, the Nuclear Regulatory Commission, did a 

complete study on the impacts of Hurricane Andrew, which basically it was a direct impact, 

August 1992, Cat. 4 hurricane hit, Hurricane Andrew. This is what they identified happened: 

Loss of all offsite power for more than five days. No offsite power. The plant ran off the 

generators. Complete loss of communications systems. Closure of the access road. One access 

road was closed. The high water tank collapsed onto the fire water system rendering the fire 

protection system inoperable. This is the NRC's report. The potential collapse of the damaged 

Unit 1 chimney onto the diesel generator buildings. (0721-22-9 [Schwartz, Matthew])

Comment: What we have here is a problem that really needs to be recognized for what it is. 

We are on the verge of a possible calamity. Had Hurricane Andrew been ten miles further to the 

south we wouldn't even be sitting here. They would've had a 17 foot tidal surge instead of just a 

5 foot one because of the rotation. (0721-6-2 [Harris, Walter])

Response: EIS Section 2.9.1.4 discusses the potential for severe weather events, including 

hurricanes, at the Turkey Point site. The historical record observed that three hurricanes make 

landfall per decade within 100 mi of the Turkey Point site. As part of the NRC's site safety 

review, the staff will consider whether the site is suitable based on the potential for flooding, 

Appendix E NUREG–2176 E-330 October 2016
storm surge, and the potential for tsunami. The results of this review will be found in the site 

Safety Evaluation Report. This issue is not within the scope of the environmental review. No 

change was made to the EIS as a result of these comments. 

Comment: Now, this brings me to the subject of the aerosols. So the new technology brings 

down most of the aerosols back into the towers, but there is still going to be about 4.2 million 

gallons a year of this stuff strewn out across the site. We don't know the spatial distribution. The 

modelers do know; they didn't put it in the Impact Statement. (0721-2-11 [Stoddard, Philip K.])

Response: Section 5.7.2 of the EIS discusses the spatial distribution of the salt-deposition 

analysis from cooling-tower drift using saltwater from the RCWs as the primary cooling-water 

source. Maximum deposition rates as high as 105 kg/ha/mo were found near the makeup-water 

reservoir, decreasing to 1 to 70 kg/ha/mo in the cooling canals. Salt-deposition rates greater 

than 10 kg/ha/mo were generally confined to the Turkey Point site except for areas adjacent to 

the southeastern portion of the site. No change was made to the EIS as a result of this 

comment. 

Comment: What's going to be coming out of those cooling towers? What are people going to 

be breathing in, (0723-9-17 [Schwartz, Matthew])

Response: In Section 5.2.1.3, the NRC discusses what is emitted from the cooling 

towers. Small droplets of water (drift) and salt particles would be emitted from the cooling 

towers during operation of the power plant. As a result, salt along with any potential 

contaminants in the cooling water would be deposited on the area surrounding the cooling 

towers. When using treated reclaimed wastewater for makeup water in addition to salt, priority 

pollutants (metals and organic compounds) and emerging pollutants of concern (EPOCs) could 

be contained in the drift. No changes was made to the EIS as a result of this comment. 

Comment: And then she goes on to say, "regarding nuclear energy it is especially important as 

provided about 12 percent of the State's electricity but accounts for a full 98 percent of the 

emissions-free electricity." So emission-free electricity. (0722-9-10 [Riley, Bill])

Comment: I have two articles that I'd like to leave with you. I won't go into them too much other 

than to say one is in the -- one was in the "Sun Sentinel" by the ex-governor of New Jersey. And 

just a quick comment quote, "moreover, nuclear energy provides 98 percent of Florida's carbonfree electricity. Because nuclear plants produce no greenhouse gases, Florida has -- reactors 

have effectively offset 15 billion tons of carbon emissions each year. That equivalence of 

removing three million cars from the roadways." And that was by Christine Whitman. (0722-9-8

[Riley, Bill])

Comment: And whereas additional nuclear power generation will provide reliable and cost 

effective electricity to maintain our standard of living and economic vitality without additional gas 

emissions. (0723-2-5 [Trowbridge, Mark])

Response: These comments provide general information in support of nuclear power. They do 

not provide any specific information related to the environmental effects of the proposed 

action. No changes were made to the EIS as a result of this comment. 

Comment: And then I see that it says here that: Additional plan treatment of the reclaimed 

wastewater prior to use also is expected. Therefore, the actual concentration of these 

constituents in drift could be either higher or lower. (0721-11-7 [Roff, Rhonda])

Appendix E October 2016 E-331 NUREG–2176
Response: This statement is in regard to the inhalation screening risk in drift from reclaimed 

water discussed in Section 5.8.5, Footnote (a) in Table 5-8, indicating "higher or lower" has 

been revised to indicate "lower" concentration only. Treatment of the reclaimed water should 

only lower concentration and the conservative estimates used in the air-dispersion modeling 

(Section 5.2.1.3) also support the conclusion that the estimated concentrations in Table 5-8 

are maximum concentrations. Table 5-8 has been revised in response to this comment. 

Comment: My background is as an environmental chemist, so I stress out a lot about things 

that Mayor Stoddard was talking about, about the aerosol drift and the accumulation. And it is 

kind of surprising to look at the uncertainties in the EIS regarding that. (0721-11-1 [Roff, Rhonda])

Response: Section 5.3.1.1 discusses the impacts of accumulation from aerosol drift. The 

section broadly discusses the possible impact from salt deposition onto leaves, surface 

water, and accumulation in soil on vegetation found within and near the facility as well as 

possible impacts on fish and other wildlife. No changes were made to the EIS as a result of this 

comment. 

Comment: Air Quality. Air Quality Criteria Pollutants. Section 5.7.1 discusses the potential 

impacts of criteria pollutants associated with operation of Units 6 and 7. The analysis indicates 

that the principal emissions associated with the new units are emissions of particulate matter 

with an aerodynamic diameter of 10 microns or less (PM10). Table 5-7 includes estimates of 

anticipated emissions of criteria pollutants associated with the operation of proposed units 6 and 

7. Emission factors from PM10 are cited for the maximum mechanical drift from all six cooling 

towers. However, it is unclear what assumptions were used to estimate emissions of PM2.5. 

Section 7.6. l discusses the cumulative impacts of criteria air pollutants and indicates that the 

operation of Units 6 and 7 cooling towers would result in plumes and salt deposition, including 

"significant salt deposits" when using make-up water, with the highest concentrations occurring 

within the Turkey Point site, specifically including deposition on the current industrial cooling 

canals. Hence, the impacts of salinity of the cooling canals cannot be separated from impacts of 

the new units. Potential impacts related to interactions of the Unit 6 and 7 cooling towers with 

the emissions from the stack of the combined-cycle generating Unit 5 were not discussed in the 

impacts or cumulative impacts sections. The analysis indicates that CALPUFF modelling was 

performed to determine the impact area, however, this analysis was not included in the 

appendices. Hence, it is not possible to determine if interactions between these stacks may 

occur. Of particular concern is the formation of PM2.5 from nitrates, ammonium, or other salts. 

Table 5-1, which addresses the constituent salts, does not address whether ammonium salts 

are present. It is not clear from the discussion whether ammonia was not present in samples 

from the reclaimed water facility, or whether no tests were conducted for this constituent. 

Recommendations: EPA recommends that a report documenting the findings of the plume 

modelling be included in the FEIS appendices, including information on stack height and 

interaction between the emissions plumes from Units 5, 6, and 7. In addition, EPA recommends 

clarification of Tables 5-1 and 5-7 or related text to include assumptions used to estimate 

emissions of PM2.5 from the cooling towers, and the presence of ammonia or ammonium salts 

related to the use of reclaimed water from the sewage treatment facility. (0617-2-3 [Mueller, Heinz 

J.])

Response: In Section 5.7, Table 5-7 reports particulate matter with an aerodynamic diameter 

of 10 microns or less (PM-10) and particulate matter with an aerodynamic diameter of 2.5 

microns or less (PM-2.5) emission rates from cooling towers. The basis for the PM10 and the 

PM2.5 emissions for the escape of the dissolved salts that could be emitted from cooling-tower 

outflow as drift is the peak in PM10 and PM2.5 emission rate, which occurs at 4,000 ppm total 

Appendix E NUREG–2176 E-332 October 2016
dissolved salts for PM10 and 5,000 ppm for PM2.5 based on the methodology of Reisman and 

Frisbie (2002-TN1022). The staff identified from the FPL Response to NRC RAI No. 4.2-2 (RAI 

5765; FPL 2012-TN263) that based on measurements in reclaimed water ammonia (as N) 

concentrations ranged from 19.1 to 29.0 mg/L from 5 yearly samples. The maximum ammonia 

found in the reclaimed water along with the ammonia emissions from Unit 5 was then used as 

input to the CALPUFF dispersion model to determine the maximum ammonia concentrations in 

the ambient air that would be available to interact with Unit 5’s emissions of oxides of sulfur 

(SOx) and nitrogen oxides (NOx). The maximum 24-hour and annual average ammonia 

concentrations were 14.7 and 0.60 ppb, respectively. A background concentration of 0.35 ppb 

was added to these modeled concentrations to estimate maximum ammonia concentration 

levels. The background concentrations were based on monitoring data for a suburban Florida 

location (Saylor et al. 2015-TN4605). These ammonia concentrations were then used as the 

background ammonia level in the CALPUFF model. The conservative MESOPUFF II chemical 

scheme option in the model was applied to predict nitrate and sulfate particulate matter 

concentrations. In response to RAI 8508 FPL provided the location of the Unit 5 exhaust 

stacks, ammonia, SOx and NOx emission rates for the annual average and maximum short-term 

period (FPL 2016-TN4501). These emissions were then modeled with CALPUFF to determine 

the maximum annual average and 24-hour sulfate and nitrate aerosol concentration. Results 

from these simulations showed that the maximum increase in total particulate matter 

concentration (sulfate plus nitrate) for 24-hour average was less than 0.05 μg/m3 and long-term 

was less than 0.0003 μg/m3. These changes would be difficult to measure and are less than 0.2 

percent of the national ambient air quality standard. On this basis, the review team concludes 

that the impacts of Unit 5 operating concurrently with the cooling towers of Units 6 and 7 on air 

quality would be SMALL and warrant no further mitigation. 

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 2.9.4, Page 2-

210, Lines 8-9 "... backup meteorological tower is located about 0.4 mi northwest of...proposed 

Units 6 and 7." ER Subsection 6.4.2.2 "...the LU tower is currently approximately 0.30 miles 

northwest of Units 6 & 7...." (0619-2-22 [Maher, William])

Response: The text in Section 2.9 was revised to be consistent with Revision 6 of the ER. 

E.2.15 Comments Concerning Health - Nonradiological 

Comment: I am concerned as well about the health and well being of individuals, including 

children who live close to the lines as I believe that there is the potential of cancer from these 

high voltage power lines. Whether you believe that there is or is not such danger, it has not yet 

been sufficiently negated by any study that l have read, and you should err towards caution as 

opposed to err towards risk. Also, the people who traverse the area regularly (as there is a bike 

path/walking path adjacent to SW 151 Avenue) would also be placed at risk. (0073-5

[Commenters, Multiple])

Comment: 5. The health and well being of individuals, as well as the people who traverse the 

area regularly on bikes or on foot, including children who live close to these proposed lines, is a 

real cancer concern. Whether or not you choose to acknowledge this danger, keep in mind that 

such has not been negated by any study I have read and it is always better to err towards 

caution. Should these lines be placed in the neighborhood, they should be buried underground 

to a level that will not pies a threat to those traversing the area or to the neighborhood. (0077-4

[de Armas, Maria Cristina])

Appendix E October 2016 E-333 NUREG–2176
Comment: We all know that High voltage transmission towers produce an unhealthy 

environment even making sick to people who live under these towers. (0088-7 [Lange, Alexandra])

Comment: The lines that will carry this high voltage for miles to its ultimate use will be going 

through populated areas that cannot be protected adequately from the electro-magnetic 

radiation. (0337-3 [Philips, Sally B.])

Comment: I am concerned as well about the health and well being of individuals, including 

children who live close to the lines. Whether you believe that there is or is not such danger, it 

has not yet been sufficiently negated by any study that I have read, and you should err towards 

caution as opposed to err towards risk. Also, the people who traverse the area regularly (as 

there is a bike path/walking path adjacent to SW I st A venue) would also be placed at risk. (?)

(0685-2 [Batista, Carlos])

Comment: [W]e're going to have hundred plus lines on poles running down on street on First 

Avenue from U.S. 1, through our neighborhood, I'd say 150 feet from my home. Homes around 

me, including homes where kids are, there are babies, there are toddlers, they are teenagers, 

and there are us, and we don't want it. I don't care whether you believe in that radiation or not. 

Wouldn't you want to err on the side of caution? (0721-26-1 [Koenigsberg, Linda])

Comment: Also, I mean, you know, I'm concerned for the health and safety of everyone in the 

Roads. My neighbors and myself included, especially children who live close to the lines that 

because, you know, there could be cancer risks with those high voltage lines right there to 

everyone. And so, you know, I don't know why we need to put ourselves at risk of cancer and 

other problems with those things there that nobody wants. (0721-31-8 [Almirola, Alejandro])

Response: These comments relate to the impacts of the electromagnetic fields (EMFs) 

associated with the transmission lines and the applicable regulatory standards. As discussed in 

Sections 3.2.2.3 and 5.8.3 of the EIS, all transmission lines would comply with National Electric 

Safety Code (NESC) provisions, which are protective of human health. No change was made in 

the EIS as a result of these comments. 

Comment: DEIS Section 4.8, Page 4-129, Lines 14-16: The DEIS states: "Extrapolating from 

data in the ER (FPL 2014-TN4058), in 2010 approximately 87,000 people lived within 10 mi of 

the site and approximately 50,000 others are estimated to have worked or visited within this 

radius..." The DEIS references the ER for this data; however, ER Table 2.5-1 and FSAR 

Subsection 2.1.3.1 show 192,594 combined residents and transients within 10 miles of 

Turkey Point. FSAR Subsection 2.1.3.3 indicates that 53,547 of these people are transients. 

Subtracting yields 139,047 residents, not 87,000. (emphasis added) (0619-4-13 [Maher, William])

Response: The text in EIS Section 4.8, Nonradiological Human Health, regarding population 

numbers within 10 mi of the site was updated to be consistent with data provided in the FSAR 

(Final Safety Analysis Report), Subsection 2.1.3.3. 

Comment: Numerical value inconsistencies within the draft EIS: Subsection 2.10.1.2, Page 2-

212, Lines 36-39 "As seen in Table 2-57, rates of injuries and illnesses per 100 full-time workers 

for years 2003-2010 in the heavy and civil engineering construction sector-- an important 

sector baseline for assessing building impacts (Chapter 4) -- ranged from 3.8 to 5.9 for the 

United States and 2.4 to 7.0 for Florida." DEIS Subsection 4.8.1.2, Page 4-130, Lines 21-23 

DEIS Table 2-57 "As noted in Section 2.10, the total recordable cases rate published by the 

BLS for 2010 for heavy and civil engineering construction was 3.8 per 100 full-time workers 

Appendix E NUREG–2176 E-334 October 2016
in the United States overall and 3.4 per 100 full-time workers in Florida." DEIS Table 2-57 

indicates, for the heavy and civil engineering construction sector for Florida, the range is 3.4 to 

7.0 per 100 full-time workers in Florida. (0619-2-32 [Maher, William])

Comment: Numerical value inconsistencies within the draft EIS: Subsection 2.10.1.2, Page 2-

214, Lines 15-16 "As seen in Table 2-58, fatal injury rates for utility operations ranged from 3.6 

to 6.1 per 100,000 workers." DEIS Table 2-58 DEIS Table 2-58 indicates the range is 3.6 to 6.3.

(0619-2-33 [Maher, William])

Comment: DEIS Subsection 4.8.2, Page 4-132, Lines 21-32: The DEIS states: "Similarly, the 

nearest residences at Homestead Bayfront Park (2.7 mi from the proposed units)...which would 

be close to the measured background noise levels of 49.4 dBA for the daytime and 47.3 dBA 

for the nighttime...The day-care facility (2 mi from the proposed units), would experience a 

maximum noise level during the site preparation and construction phase of about 49.6 dBA 

during the daytime and 51.1 dBA during the nighttime..." The data in this paragraph 

references the noise study in the Site Certification Application (SCA). However, Table 5.7.4-3 

(and Table 5.7.4-5) of the SCA reports the background nighttime sound pressure level for site 

S7 (Homestead Bayfront Park) value to be 47.2 dBA. Additionally, the maximum sound 

pressure level for site S6 (day-care facility) during pre-construction and construction as reported 

from the noise study in the Site Certification Application (SCA), Table 5.7.4-4 of the SCA, are 

50.2 dBA for daytime and 50.4 dBA for nighttime for preconstruction. And, Table 5.7.4-6 on 

construction reports 49.2 dBA for daytime and 49.5 dBA for nighttime. The DEIS is reporting 

values for site S5 (the northern FPL boundary). (emphasis added) (0619-4-14 [Maher, William])

Response: The text in the Nonradiological Human Health Sections 2.10 and 4.8 of the EIS was 

revised to be consistent with the referenced material. 

Comment: The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the county's wastewater. Even in small amounts, these can 

affect human health[.] (0078-6 [Wilansky, Laura Sue])

Comment: Aerosol droplets known as "drift" can travel far and contain pharmaceuticals, 

cleaners, and detergents and other household chemicals as well as bacteria which can grow 

inside the cooling towers themselves as bacterial slime. This all impacts the human environment 

as well as dozens of threatened species in the vicinity. (0153-2 [Goldman, Emanuel])

Comment: Aerosol droplets known as "drift" can travel far and contain pharmaceuticals, 

cleaners, detergents and other household chemicals, as well as viruses and bacteria (which can 

grow inside the cooling towers themselves as bacterial slime). Impacts on the human 

environment as well as on dozens of endangered and threatened species in the vicinity are 

largely unknown. (0240-4 [Commenters, Multiple])

Comment: The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the countys wastewater. Even in small amounts, these can 

affect human health. (0353-4 [Royce, M.])

Comment: The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the countys wastewater. Even in small amounts, these can 

affect human health[.] (0356-10 [Shlackman, Jed])

Appendix E October 2016 E-335 NUREG–2176
Comment: I do NOT want a CHANCE of the vented hot steam which likely contains household 

chemicals, pharmaceuticals, bacteria and viruses ending up in the countys wastewater. Even in 

small amounts, these can affect human health. (0362-2 [Hurley, Paula])

Comment: The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the county's wastewater. Even in small amounts, these can 

affect human health[.] (0366-4 [Griffith, Ed and Harriet])

Comment: The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the countys wastewater. (0370-9 [Vayu, Satya])

Comment: The primary source of cooling water for the proposed Turkey Point 6 and 7 reactors 

is waste water from Miami. Some of this water will be turned into steam and released into the 

surrounding environment, along with its constituent pesticides, inorganic solvents, industrial 

wastes, household chemicals, and dissolved pharmaceuticals. This waste water turned into 

steam will spread out into clouds over the entire population of Miami-Dade and Broward 

counties and rain down on the population with its chemical, waste, and pharmaceutical 

components, creating polluted air vapors and polluted rainfall. (0615-2-19 [Bethune, David])

Comment: It seems that the ingredients for a 'Perfect Storm' are being assembled as I read 

that you will also be adding 'wastewater' to the mix with its intendant biohazards. (0639-3

[Haselhurst, Richard])

Comment: There is nothing safe about two new 1,117 megawatt nuclear reactors being built 

on Floridas east coast, especially because they will be cooled by 90 million gallon per day of 

recycled Miami-Dade County sewage and wastewater. This water will not be pure water and 

some will be released over Biscayne Bay and surrounding wetlands along with steam in the 

planned cooling towers. Aerosol droplets known as "drift" can travel far and contain 

pharmaceuticals, cleaners, detergents and other household chemicals, as well as viruses and 

bacteria (which can grow inside the cooling towers themselves as bacterial slime). Impacts on 

the human environment as well as on dozens of endangered and threatened species in the 

vicinity are largely unknown. (0674-2 [Dwyer, Karen])

Comment: The vented hot steam will likely contain household chemicals, pharmaceuticals, 

bacteria and viruses that end up in the countys wastewater. Even in small amounts, these can 

affect human health[.] (0676-6 [Kassel, Kerul])

Comment: [W]e have all kinds of contaminants through drift; we have waste products to 

manage. I look at the list of chemicals including the metals, including the anti-scaling, including 

the things that we know are toxic, including the things that are considered endocrine disruptors. 

We don't know what safe level they are. We don't know their synergistic effects. (0721-11-6 [Roff, 

Rhonda])

Comment: [F]or the rest of the year chemically laden reclaimed water with descaling chemicals 

added to the water by FPL will fall within a 1 mile radius. This will fall on workers there, and on 

already salinity challenged cooling canals for Turkey Point 3 and 4. (0721-12-3 [White, Barry J.])

Comment: There's a whole panoply of chemicals that are listed, many of them are endocrine 

disruptors. The amounts are small, but endocrine disruptors work in small amounts. There is 

nothing in the Environmental Impact Statement that lets a scientist, such as myself, determine 

what safe levels actually are relative to the levels that are going to be produced. Furthermore, at 

Appendix E NUREG–2176 E-336 October 2016
the National Pesticide Forum this weekend, everybody was talking about synergistic effects, all 

the major eco-toxicologists who study endocrine disruptors, talk about synergistic effects. 

There's no indicator of synergistic effects in the Environmental Impact Statement. (0721-2-12

[Stoddard, Philip K.])

Comment: Let's look at the cooling towers a little bit and these 90 million gallons a day of 

wastewater that they're going to be putting in there. What's in that wastewater? I want to know 

everything that's in that wastewater. We, as people, need to know what's going into --excuse 

me, we just had a meltdown --what's going in to this wastewater that they're pouring through this 

nuclear power plant? Is it going to be pure H2O? No. I started reading the research from people 

who deal with wastewater experts, engineers. It ain't pure. There's thousands --think of 

everything you buy at a CVS. Think about all the things we put down our toilet bowls; the 

cleaning fluids, the pharmaceuticals, the bacteria, the viruses. All of that's going into that 

wastewater. How clean could they get it? It ain't pure. (0721-22-12 [Schwartz, Matthew])

Comment: We've heard about the 90 million gallons of wastewater, the chemicals and the 

pollutants that would be in that water, how that water is going to be disbursed, aerosolized[.]

(0721-28-6 [Wilansky, Laura Sue])

Response: These comments express concern that the use of reclaimed wastewater for cooling 

of Turkey Point Units 6 and 7 could result in the release of additional etiological and chemical 

agents in the cooling-tower drift. Sections 5.3.1 and 5.3.2 discuss the relative deposition of a 

number of contaminants of concern that may be present in reclaimed wastewater and 

concluded that the expected trace amounts would have negligible effects due to the extremely 

low concentration and dilution in receiving water bodies. The review team considered Florida 

requirements for reclaimed wastewater and concluded that compliance with Florida 

requirements for the treatment and use of reclaimed wastewater by FPL would be protective of 

public health. No changes were made to the EIS as a result of these comments. 

Comment: Nuclear expansion is not going to be good for public health or environment at 

Biscayne National Park. Why don't you really admit this? One more dollar profit is really not 

everything to you, is it? (0726-1 [Poolos, Hazel])

Response: The EIS was developed to disclose the environmental and health impacts of 

building and operating the proposed Turkey Point Units 6 and 7. The impacts of building the 

units are described in Chapter 4 and the impacts of operating the units are described in Chapter 

5. Nonradiological health impacts are described in Sections 4.8 and 5.8 of the EIS. Section 5.9

of the EIS describes the radiological impacts of operating the proposed units. No changes were

made to the EIS in response to this comment.

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 4.8.1.2, Page 4-

130, Lines 31-33 "The resulting estimates are an annual average of 89 (based on U.S. data) 

and 96 (based on Florida data) recordable cases and a peak 12-month amount (months 34 to 

45) of 162 (U.S.) and 174 (Florida) recordable cases." ER Table 4.8-1 ER Table 4.8-1 indicates:

the Incidence at US Rate annual average as 86; TRC Incidence at FL Rate annual average as

93; TRC Incidence at US Rate Peak 12-month period as 161; and TRC Incidence at FL Rate

12-month period as 173. (DEIS values are consistent with an earlier revision for the source.)

(0619-2-26 [Maher, William])

Comment: DEIS Section 4.8, Page 4-129, Lines 12-13: The DEIS states: "The area south and 

southwest of the site consists primarily of marshland and glades, and contains no resident 

Appendix E October 2016 E-337 NUREG–2176
human population." However, ER Table 2.5-1 shows 2,249 people living to the south (ranging 

from 5 to 30 miles) and 15 people living to the southwest (ranging from 40 to 50 miles).

(0619-4-12 [Maher, William])

Response: The text in Section 4.8 was revised to be consistent with Revision 6 of the ER. 

Comment: The FEIS should include detailed information regarding impacts associated with 

potential exceedances of the NNC. The Florida Department of Environmental Protection (FDEP) 

approved NNC water quality standards for estuaries including Biscayne Bay. However, there is 

no discussion in the DEIS regarding the project's potential impacts regarding the NNC and 

Biscayne Bay. (0617-1-35 [Mueller, Heinz J.])

Comment: EPA acknowledges that there are no current exceedances of the NNC. However, 

the DEIS should evaluate the future project in the context of potential NNC impacts and possible 

related algal blooms beyond the IWF. EPA requests that the NRC better describe the existing 

condition of the current operations of Units 3 and 4 and related water quality impacts in the FEIS 

and, if available, disclose the results of the FPL studies discussed in the DEIS. The EPA is 

concerned that the combined and additional wastewater discharges into the IWF could 

potentially lead to exceedances of the NNC. 

Recommendations: The EPA is concerned that the proposed project could cause NNC

exceedances within Biscayne Bay, and requests that more detailed information be provided in 

the FEIS. Specifically, EPA requests that the NRC consider the additive effects of all the 

wastewater being placed into the IWF. The FEIS should describe how the additional wastewater 

discharges to the IWF could potentially impact the Biscayne Aquifer, potentially increase NNC 

levels within Biscayne Bay and the potential for the algal bloom to expand beyond the IWF.

(0617-1-36 [Mueller, Heinz J.])

Response: Compliance with Numerical Nutrient Criteria (NNC) is a regulatory responsibility of 

the FDEP, not the NRC or USACE. The NNC is only of interest in this review inasmuch as it 

helps inform the aquatic ecologists about the thresholds of potential impacts to the aquatic 

ecosystems. Nonetheless, the review team did consider the incremental increase in nutrients in 

Biscayne Bay from drift, which is the only new source of nutrients associated with the proposed 

units. The staff also considered drainage and leakage from muck as a source of nutrients to the 

canals. While these nutrients are not new to the local environment, they would likely become 

more mobile and available for movement outside the boundaries of the IWF. The review team 

has acknowledged the subsurface migration of hypersaline water, but as discussed in Appendix 

G, determined that upward migration into the affected environment would be minor. Therefore, 

the minor incremental increase in nutrient concentration and minor potential for entering the 

surface of the Bay itself would be minor impact. No changes to the EIS were made based on 

these comments. 

E.2.16 Comments Concerning Health - Radiological 

Comment: ESE breezes prevail, any mishap and where do you think that takes the 

contamination, directly over the largest concentration of human beings south of. Hello is 

anybody thinking?? (0065-1 [Wilson, J. D. Bruce])

Comment: As previously mentioned, there is no way to guarantee that some, or many of these 

substances will not find their way into the local environment. Some of these substances have a 

Appendix E NUREG–2176 E-338 October 2016
halflife of 80 million to over 700 million years! Can FPL, or the NRC guarantee they will be 

contained for all of that time? None of us know how to do that. (0078-9 [Wilansky, Laura Sue])

Comment: Nuclear advocates frequently state that both xenon and krypton decay and 

disappear in a matter of seconds or minutes. What they don't tell us is that these isotopes decay 

into daughter isotopes that are extremely deadly emitters. Many credible physicians, scientists 

and other nuclear experts -- free of the self-interests of nuclear profits, academic sponsorship or 

career advancement -- have outlined the absence of epidemiological studies of certain 

radionuclides emitted or flushed at nuclear reactors. Dr. Helen Caldicott has elaborated the 

detrimental health effects of the noble gases xenon (Xe) and krypton (Kr), and she notes that 

these have appearance hundreds of miles from reactors believed to have emitted them. --

Xenon 137, with a half-life of 3.9 minutes, converts almost immediately to the notoriously 

dangerous cesium 137 with a half-life of thirty years. --Krypton 90, half-life of 33 seconds, 

decays to rubidium 90, half-life of 2.9 minutes, then to the medically toxic strontium 90, half-life 

of twenty-eight years. --Xenon 135 decays to cesium 135 with an incredibly long half-life of 3 

million years. --Large amounts of xenon 133 are released at operating reactors, and although it 

has a relatively short half-life of 5.3 days, it remains radioactive for 106 days. --Krypton 85, 

which has a half-life of 10.4 years, is a powerful gamma radiation emitter. --Argon 39 has a 265-

year half-life (0264-4 [Dwyer, John P.])

Comment: All reactors as part of normal operations regularly emit radioactive material into 

both the air and the cooling water used [to] manage the heat produced by the reactors. 

Radioactivity generated by the mining of uranium, the ore refining and enriching facilities, the 

fission process in reactors and the toxic radioactive waste all pose a danger to human life. 

Radioactive emissions that are a necessary product of nuclear power generation are linked to 

cancer, birth defects, developmental delays in children, reproductive problems and other chronic 

health issues such as heart disease. (0511-3 [Draper, Lonnie M.])

Comment: This is simply very dangerous to our health! (0524-1 [Garcia, Alda S.])

Comment: The NRC cannot persist in a shell game that pretends radiation isn't both a safety 

and environmental concern. (0615-1-11 [Bethune, David])

Comment: The most serious shortcomings in the draft EIS relate to radiation releases and 

accident mitigation. Although the staff present at last night's meeting tried to shift questions 

about radiation off to a closed-door safety review which does not allow public participation, the 

truth of the matter is that safety and environmental impact cannot be separated when it comes 

to the manufacture and release of fission products, whether intentional or unintended. Every 

radioactive isotope created at the proposed plants is both a safety hazard and an environmental 

hazard. (0615-1-8 [Bethune, David])

Comment: Even precluding their release, the mere creation of radioactive isotopes such as 

plutonium with its 24,000 year half life poses unavoidable risks to health and the environment.

(0615-1-9 [Bethune, David])

Comment: I have family in Florida,and am very aware of the high radiation levels they are 

being exposed to daily! Miami has had rad levels above 450 counts per minute almost daily! 

anything above 50 cpm is shelter in place! (0624-2 [Galles, Camilla])

Appendix E October 2016 E-339 NUREG–2176
Comment: People need to check netc.com to know what we are all being poisoned with at 

present, and go to enenews.com to find out just what is coming your way from the nuclear 

power plants already spreading their poison every time they refuel! (0624-3 [Galles, Camilla])

Comment: There is no safe dose and we're risking the human genome. It's madness. It's cruel 

to the people in the area and everyone downwind, not to mention downstream. To extend this is 

random premeditated murder in my opinion. It is a crime against humanity and our unborn 

children as well. (0644-3 [Anonymous, Anonymous])

Comment: As previously mentioned, there's no way to guarantee that some or many of these 

substances will not find their way into the local environment. Some of them have a half-life of 80 

million to over 700 million years. Can FP&L or the NRC or any of us guarantee that they'll be 

contained for all that time? We can't do that. (0721-28-9 [Wilansky, Laura Sue])

Response: The NRC's primary mission is to license and regulate the Nation's civilian use of 

radioactive materials to protect public health and safety, promote the common defense and 

security, and protect the environment. The NRC's regulatory limits for radiological protection 

are set to protect workers and the public from the harmful health effects of ionizing radiation on 

humans. The limits are based on the recommendations of standards-setting organizations. The 

NRC radiation standards reflect extensive scientific study by national and international 

organizations and incorporate conservative assumptions and models to account for differences 

in gender and age so as to ensure that workers and all members of the public are adequately 

protected from radiation. 

The NRC disagrees with the comments that “[t]here is no safe dose“ or that the existing 

population in the area of the Turkey Point site is exposed to high levels of radiation. The dose 

standards are set conservatively by NRC based on the conclusions and recommendations of 

numerous national and international expert panels in part to account for the potential 

uncertainties. These dose standards are based on the linear, no-threshold dose-response 

model described in the Biological Effects of Ionizing Radiation (BEIR) VII report. The report 

states “Lower doses would produce proportionally lower risks.” It does continue to support the 

conclusion that there is some amount of cancer risk associated with any amount of radiation 

exposure and the risk increases with exposure and exposure rate. It also concludes that the 

risk of cancer induction at the dose levels in the NRC’s and EPA’s radiation standards is very 

small. 

As reported to the Commission in SECY-05-0202 (Staff Review of the National Academies 

Study of the Health Risks From Exposure to Low Levels of Ionizing Radiation (BEIR VII) - 

October 29, 2005), the staff stated “that the findings presented in the National Academies BEIR 

VII report contribute to our understanding of the health risks from exposure to ionizing 

radiation. The major conclusion is that current scientific evidence is consistent with the 

hypothesis that there is a linear, no-threshold dose response relationship between exposure to 

ionizing radiation and the development of cancer in humans. This conclusion is consistent with 

the system of radiological protection that the NRC uses to develop its regulations. Therefore, 

the NRC regulations continue to be adequately protective of the public health and safety and the 

environment." 

As discussed in Sections 2.11 and 5.9.6 of this EIS, the amount of radioactive material released 

from nuclear power facilities is well measured, well monitored, and known to be very small. The 

doses of radiation received by members of the public as a result of exposure due to nuclear 

power facilities are very low (i.e., less than a few millirem). To put this in perspective, the 

Appendix E NUREG–2176 E-340 October 2016
average dose per individual in this country is approximately 360 millirems from natural sources 

of radiation (NRCP Report # 160 (NRCP 2009-TN420)). Radiation from natural and man-made 

sources is not different in its properties or effects. To ensure that the nuclear power plants are 

operated safely within radiation protection requirements, the NRC licenses the plants to operate, 

licenses the plant operators, and establishes license conditions for the safe operation of each 

plant. The NRC provides continual oversight of plants through its Reactor Oversight Process to 

verify that they are being operated in accordance with NRC rules and regulations. 

The comments do not provide any information that was not already considered in the evaluation 

in the draft EIS, and no changes were made to the EIS as a result of these comments. 

Comment: The municipalities of Homestead and Florida City have allowed extensive 

residential development east of U.S. and within a few miles of the Turkey Point plant. Moreover, 

most of the most populous areas of Miami-Dade County are downwind of the plant and within a 

few dozen miles of it. Please note the following: The RPHP "Tooth Fairy Project-" grew out of 

the work of Dr. Jay Gould, Director of the Radiation and Public Health Project (RPHP) and 

author of The Enemy Within: The High Cost of Living Near Nuclear Reactors. By analyzing 50 

years of US National Cancer Institute data, Dr. Gould proved that......of the 3,000-odd counties 

in the United States, women living in about 1,300 nuclear counties (located within 100 miles of a 

reactor) are at the greatest risk of dying of breast cancer. Dr. Gould found even higher risks for 

prostate cancer among men living in nuclear counties. (0093-4 [DuPriest, William Robert])

Response: As presented in the public summary introduction of the BEIR VII report (National 

Research Council 2006-TN296), the health risks from exposure to radiation are related to the 

dose one receives: 

“Specifically, substantial evidence exists that exposure to high levels of ionizing radiation can 

cause illness or death. Further, scientists have long known that in addition to cancer, ionizing 

radiation at high doses causes mental retardation in the children of mothers exposed to 

radiation during pregnancy. Recently, data from atomic bomb survivors suggest that high doses 

are also connected to other health effects such as heart disease and stroke.” 

And, 

“This report, BEIR VII, focuses on the health effects of low levels of low linear energy transfer 

(LET) ionizing radiation. Low-LET radiation deposits less energy in the cell along the radiation 

path and is considered less destructive per radiation track than high-LET radiation. Examples of 

low-LET radiation, the subject of this report, include X-rays and γ-rays (gamma rays). Health 

effects of concern include cancer, hereditary diseases, and other effects, such as heart 

disease." 

The occurrence of cancers is known to be related to a number of factors, including age, sex, 

time, and ethnicity, as well as exposure to environmental agents such as ionizing 

radiation. Understanding the role of exposure in the occurrence of cancer in the presence of 

modifying effects is a difficult problem. Contributing to the difficulty are the stochastic nature of 

cancer occurrence, both background and exposure related, and the fact that radiogenic cancers 

are indistinguishable from nonradiogenic cancers. Therefore, the BEIR committees have 

judged that the linear no-threshold model (LNT) provided the most reasonable description of the 

relation between low-dose exposures to ionizing radiation and the incidence of solid cancers 

that are induced by ionizing radiation.. Simply stated, the NRC currently assumes that any 

increase in dose, no matter how small, results in an incremental increase in health risk. 

Appendix E October 2016 E-341 NUREG–2176
The NRC accepts this theory as a conservative model for estimating health risks from radiation 

exposure and recognizes that the model probably overestimates those risks. On the basis of 

this theory, the NRC conservatively establishes limits for radioactive effluents and radiation 

exposures for workers and members of the public, as found in 10 CFR Part 20. 

As discussed in Sections 2.11 and 5.9, the amount of radioactive material released from Turkey 

Point Units 3 and 4 is well measured, well monitored, and known to be very small. Based on 

this operational experience and the new facility design, the NRC believes that the amount of 

radioactive material to be released from the Turkey Point, Units 6 and 7 would also be well 

measured and well monitored, and the NRC also believes the release would be very small. The 

total whole body dose from both ingested radionuclides due to liquid and gaseous releases and 

direct radiation from the Turkey Point site is and would be negligible compared with the public’s 

exposure from natural background radiation alone (approximately 360 mrem per year), and 620 

millirem per year from the combination of natural background, medical irradiation, and radiation 

from consumer products (NRCP 2009-TN420). 

Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have 

been conducted, there are no studies to date that are accepted by the scientific community that 

show a correlation between radiation dose from nuclear power facilities and cancer incidence in 

the general public. Specific studies accepted as scientifically valid include: 

 In 1990, at the request of Congress, the National Cancer Institute conducted a study of

cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities. The

study covered the period from 1950 to 1984 and evaluated the change in mortality rates

before and during facility operations. The study concluded that there was no evidence that

nuclear facilities may be linked causally with excess deaths from leukemia or from other

cancers in populations living nearby.

 In June 2000, investigators from the University of Pittsburgh found no link between radiation

released during the 1979 accident at the Three Mile Island power plant and cancer deaths

among nearby residents. Their study followed 32,000 people who lived within 5 mi of the

plant at the time of the accident.

 In January 2001, the Connecticut Academy of Sciences and Engineering issued a report on

a study around the Haddam Neck nuclear power plant in Connecticut and concluded that

radiation emissions were so low as to be negligible.

 The American Cancer Society (ACS) in 2001 concluded that although reports about cancer

clusters in some communities have raised public concern, studies show that clusters do not

occur more often near nuclear plants than they do by chance elsewhere in the population.

Likewise, the ACS report found no evidence that links strontium-90 with increases in breast 

cancer, prostate cancer, or childhood cancer rates. The ACS also found that radiation 

emissions from nuclear power plants are closely controlled and involve negligible levels of 

exposure for nearby communities. 

Also in 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there are 

striking increases in cancer rates in southeastern Florida counties caused by increased 

radiation exposures from nuclear power plants. Using the same data to reconstruct the 

calculations on which the claims were based, Florida officials were not able to identify unusually 

Appendix E NUREG–2176 E-342 October 2016
high rates of cancers in these counties compared with the rest of the state of Florida and the 

nation. 

 In 2000, the Illinois Public Health Department compared childhood cancer statistics for 

counties with nuclear power plants to similar counties without nuclear plants and found no 

statistically significant difference. 

The NRC has reviewed a number of studies by the Radiation Public Health Project (RPHP) that 

assert that levels of radioactive strontium-90 are rising in the environment and that these 

increased levels are responsible for increases in cancers, particularly cancers in children, and 

infant mortality. The group claims that radioactive effluents from nuclear power plants are 

directly responsible for the increases in strontium-90. In one study, researchers reported that 

strontium-90 concentrations in baby teeth are higher in areas around nuclear power plants than 

in other areas. This has sometimes been referred to as "The Tooth Fairy Project." However, 

as discussed in a background paper prepared by the NRC, (http://www.nrc.gov/reading-rm/doccollections/fact-sheets/tooth-fairy.pdf), numerous peer-reviewed, scientific studies do not 

substantiate the RPHP claims, and the NRC finds that there is little or no credibility in the 

RPHP's studies. 

As presented in the above NRC backgrounder, approximately 99 percent of strontium-90 in the 

environment came from atmospheric testing of nuclear weapons. The second largest source of 

strontium-90 in the environment was the Chernobyl accident. The amount of strontium-90 from 

all commercial nuclear power plants is a tiny fraction of the amount from Chernobyl. The 

estimated radiation dose from all sources of strontium-90 in the environment is approximately 

0.3 percent of the dose that the average person in the United States receives from natural 

background radiation. These dose levels are well below the levels that are known to cause any 

health effects. The NRC requires nuclear power plant licensees to monitor the releases of 

radioactivity from their facilities to the environment and to annually report these releases to the 

NRC. Additionally, these licensees are required to monitor the environment around their 

facilities and report results annually to the NRC. The NRC routinely inspects these aspects of 

nuclear power plant licensee performance. 

Due to the concern about the issues regarding the increased cancer rates raised by the RPHP, 

the Florida Department of Health (FDOH) chose to also look at the cancer rates using the same 

data used by RPHP. Staff from the Bureau of Environmental Epidemiology interviewed the 

RPHP staff to determine the source of data and then performed their own calculations and 

graphed the results (FDOH 2001-TN4744). Overall the FDOH could not identify any unusually 

high rates of cancers in the area. While some county rates appear higher than state and 

national trends and some appear lower, this variation is within the expected, statistical variation, 

meaning the variation would be expected to occur by chance. These rates fluctuate from year 

to year and in some situations large fluctuations occur with a small number of cases in small 

underlying county populations. Therefore, the claim by the RPHP that there are elevated rates 

of cancer in the vicinity of the plant are unsubstantiated and refuted by the State of Florida 

study. 

No changes were made to the EIS as a result of these comments. 

Comment: Don't you know that the radiation monitors in Florida for EPA have been long since 

TURNED OFF to conceal form the people of Florida how they are already impacted from the 

wind currents coming in from Fukushima? (0628-2 [Anonymous, Anonymous])

Appendix E October 2016 E-343 NUREG–2176
Response: Given the great distances between Fukushima Dai-ichi and the United States and 

the large amount of dilution and dispersion that would occur over this distance, only a trace 

amount of radioactivity was detected in the United States from this event. Based on the 

environmental measurements made to date by government agencies and non-government 

organizations, the Fukushima Dai-ichi accident has had no detectable impact on human health 

in the United States. In particular, the EPA’s air monitoring data have not shown any 

radioactive elements associated with the damaged Japanese reactors since late 2011, and 

even then, the levels found were very low—always well below any level of public health concern 

(EPA 2015-TN4217). 

No changes were made in the EIS as a result of this comment. 

Comment: Nuclear power plants also release dangerous radiation into the air and water during 

their daily operations. This radiation is linked to all kinds of cancers, heart disease, diabetes, 

birth defects, miscarriages, thyroid problems, leukemia, the list goes on and on. (0603-2

[Anonymous, Anonymous])

Comment: During refueling, nuclear power plants can release up to 1,000X the amount of 

radiation and Dr. Ian Fairlie believes this is what causes the increases in childhood leukemias 

around nuclear power plants. (0603-3 [Anonymous, Anonymous])

Comment: Let's discuss the childhood leukemias and cancer deaths that researchers say 

arecaused by nuclear energy: 

Quote from Dr. Ernest Sternglass ---> The official measurements carried out by the Office 

ofRadiological Health, and by the government, and the Public HealthService, they measured the 

radiation doses around the first bigreactors in Dresden near Chicago, and they found that 

indeed therewere doses almost as high as half of the normal background, andaccording to Dr. 

Stewarts finding, that would mean an increaseof 40-50% in childhood cancers and leukemias 

around the fence ofevery nuclear plant. SOURCE: youtube /watch?v=hN7rcjSnxZs. (0603-4

[Anonymous, Anonymous])

Comment: Let's also not forget Dr. John Gofman's research which states that approximately 

1,600 CANCER DEATHS PER YEARcan becaused by EACHnuclear power plant. (0603-5

[Anonymous, Anonymous])

Comment: While the potential public health effects are much less significant than some of the 

other issues everyone has talked about tonight, I think they do bear mention. At least one study 

found increased thyroid problems in areas near nuclear plants in the Northeast, and there have 

been studies from the U.S. and abroad correlating some forms of leukemia with proximity to 

nuclear plants. Despite no family history of leukemia, I lost a parent to leukemia a couple years 

ago. (0721-32-3 [Schlackman, Mara])

Response: The NRC’s primary mission is to protect the public health and safety and the 

environment from the effects of radiation from nuclear reactors, materials, and waste 

facilities. The NRC's regulatory limits for radiological protection are set to protect workers and 

the public from the harmful health effects of radiation on humans and can be found in 10 CFR 

Part 20 (Standards for Protection Against Radiation). The limits are based on the 

recommendations of standards-setting organizations. Radiation standards reflect extensive 

scientific study by national and international organizations (International Commission on 

Radiological Protection [ICRP], National Council on Radiation Protection and Measurements 

Appendix E NUREG–2176 E-344 October 2016
[NCRP], United Nations Scientific Committee on the Effects of Atomic Radiation [UNSCEAR], 

and the National Academy of Sciences [NAS]) and are conservative to ensure that the public 

and workers at nuclear power plants are protected. 

Health effects from exposure to radiation are dose-dependent. At low doses, radiation can be 

responsible for inducing cancers such as leukemia, breast cancer, and lung cancer. At very 

high doses (several hundred rem or higher) and dose rates, radiation has been known to cause 

prompt (or early, also called acute) effects, such as vomiting and diarrhea, skin burns, cataracts, 

and even death. 

Currently, there are no scientifically conclusive data that unequivocally establish the occurrence 

of cancer following exposure to low doses, below about 0.1 Sv (10 rem). However, radiation 

protection experts conservatively assume that any amount of radiation may pose some risk of 

causing cancer and that the risk is higher for higher radiation exposures. Therefore, a linear, 

no-threshold dose response relationship is used to describe the relationship between radiation 

dose and cancer induction. Simply stated, any increase in dose, no matter how small, results in 

an incremental increase in health risk. The NRC accepts this theory as a conservative model 

for estimating health risks from radiation exposure and recognizes that the model probably 

overestimates those risks. On the basis of this theory, the NRC conservatively establishes 

limits for radioactive effluents and radiation exposures for workers and members of the public, 

as found in 10 CFR Part 20. 

The amount of radioactive material released from Turkey Point Units 3 and 4 is well measured, 

well monitored, and known to be very small. Based on this operational experience and the new 

facility design, the NRC believes that the amount of radioactive material to be released from the 

Turkey Point Units 6 and 7 would also be well measured and well monitored, and the NRC also 

believes the release would be very small. The total whole body dose from both ingested 

radionuclides due to liquid and gaseous releases and direct radiation from the Turkey Point site 

is and would be negligible compared with the public’s exposure from natural background 

radiation, medical irradiation, and radiation from consumer products of more than 300 millirem 

per year. 

Although a number of studies of cancer incidence in the vicinity of nuclear power facilities have 

been conducted, there are no studies to date that are accepted by the scientific community that 

show a correlation between radiation dose from nuclear power facilities and cancer incidence in 

the general public. Specific studies that have been conducted include: 

 In 1990, at the request of Congress, the National Cancer Institute conducted a study of 

cancer mortality rates around 52 nuclear power plants and 10 other nuclear facilities. The 

study covered the period from 1950 to 1984 and evaluated the change in mortality rates 

before and during facility operations. The study concluded that there was no evidence that 

nuclear facilities may be linked causally with excess deaths from leukemia or from other 

cancers in populations living nearby. 

 In June 2000, investigators from the University of Pittsburgh found no link between radiation 

released during the 1979 accident at the Three Mile Island power plant and cancer deaths 

among nearby residents. Their study followed 32,000 people who lived within 5 miles of the 

plant at the time of the accident. 

 In January 2001, the Connecticut Academy of Sciences and Engineering issued a report on 

a study around the Haddam Neck nuclear power plant in Connecticut and concluded that 

radiation emissions were so low as to be negligible. 

Appendix E October 2016 E-345 NUREG–2176
 The American Cancer Society in 2001 concluded that although reports about cancer 

clusters in some communities have raised public concern, studies show that clusters do not 

occur more often near nuclear plants than they do by chance elsewhere in the 

population. Likewise, there is no evidence that links strontium-90 with increases in breast 

cancer, prostate cancer, or childhood cancer rates. Radiation emissions from nuclear power 

plants are closely controlled and involve negligible levels of exposure for nearby 

communities. 

 Also in 2001, the Florida Bureau of Environmental Epidemiology reviewed claims that there 

are striking increases in cancer rates in southeastern Florida counties caused by increased 

radiation exposures from nuclear power plants. Using the same data to reconstruct the 

calculations on which the claims were based, Florida officials were not able to identify 

unusually high rates of cancers in these counties compared with the rest of the state of 

Florida and the nation. 

 In 2000, the Illinois Public Health Department compared childhood cancer statistics for 

counties with nuclear power plants to similar counties without nuclear plants and found no 

statistically significant difference. No changes were made to the EIS as a result of these 

comments. 

Comment: DEIS Subsection 4.9.1, Page 4-137, Lines 18-20 and Appendix G, Section G.2.4.4, 

Page G-16, Line 27: The DEIS (Subsection 4.9.1) states: "...FPL calculated an annual dose to 

the construction worker of 0.009 mrem (FPL 2014-TN4058)" and references the ER. Similar 

language appears in Appendix G (Subsection G.2.4.4). The ISFSI dose was subsequently 

revised to 0.013 mrem in the response to RAI 12.4.1.9.3-1 (eRAI 5430), L-2014-322, dated 

October 22, 2014, ML14297A026. (emphasis added) (0619-4-15 [Maher, William])

Response: The typographical error was noted after publication of the draft EIS. The 0.009 

mrem (mrem/yr) has been changed to 0.013 mrem (mrem/yr) in Sections 4.9.1 and G.2.4.3 in 

the final EIS. 

Comment: DEIS Subsection 5.9.1, Page 5-98, Lines 23-26: The DEIS states: "For the gaseous 

effluent release pathway, FPL considered the following exposure pathways in evaluating the 

dose to the maximally exposed individual (MEI): ...ingestion of goat milk..." ER Subsection 

5.4.1.2 states: "The input parameters for the gaseous effluent exposure pathway are presented 

in Table 5.4-5", and Table 5.4-5 includes "Milk cows" and does not include "goat milk". 

(emphasis added) (0619-4-19 [Maher, William])

Response: This comment indicates that cow milk was a parameter for the population dose 

assessment and that goat milk was not considered as a parameter for the population dose 

assessment. Therefore, in Section 5.9.1, the phrase "ingestion of goat milk," has been deleted 

from the final EIS. 

Comment: DEIS Subsection 5.9.1, Page 5-98, Lines 27-28: The DEIS states: "For population 

doses from the gaseous effluents, FPL used the same exposure pathways as those used for the 

individual dose assessment." The FPL analysis included cow milk in population doses but not in 

MEI doses. (0619-4-20 [Maher, William])

Response: The sentence in Section 5.9.1 was amended in the final EIS to reads as 

follows: "For population doses from the gaseous effluents, FPL used the same exposure 

Appendix E NUREG–2176 E-346 October 2016
pathways as those used for the individual dose assessment, with the addition of a pathway for 

the ingestion of cow milk." 

Comment: DEIS Appendix G, Subsection G.2.1.4, Page G-7, Table G-3: DEIS Appendix G 

Table G-3 incorrectly states that the driller doses in ER Table 5.4-3 are for an adult. They are 

for a child, as indicated in the last paragraph of ER Subsection 5.4.1.1. The lower doses 

calculated by the Staff are for an adult, leading to the differences noted in Table G-3.(emphasis 

added) (0619-7-12 [Maher, William])

Response: ER Table 5.4-3 (FSAR Table 11.2-209) gives no indication that the subsistence 

driller dose is based on a child rather than an adult for conservatism. This is only discussed in 

the last paragraph on ER page 5.4-5 (third paragraph on FSAR page 11.2-29). 

In Table G-3, the following changes were made in the final EIS for clarification: 

In the FPL column, "(adult)" was changed to "(child)" and "(liver)" was changed to "(child's liver)" 

In the NRC column, "(liver)" was changed to "(adult's liver)" 

Note "a" now includes the following additional sentence: "ER Table 5.4-3 (FPL 2014-TN4058) 

and FSAR Table 11.2-209 (FPL 2015-TN4502). For conservatism, FPL used the parameters of 

a child for the driller's dose based on the radiological liquid effluent releases from two AP1000 

units." 

Comment: DEIS Appendix G, Subsection G.2.2.6, Page G-14, Table G-11: DEIS Table G-11, 

"Calculated Doses to the Population Within 50 mi of the Turkey Point Site from Gaseous and 

Liquid Pathways (Two AP1000 Units)", contains calculated whole body doses by various 

pathways and reports the "FPL Estimate" for each cited pathway. The "FPL Estimate" contains 

a footnote which cites (FPL 2014-TN4058), FPL's ER Revision 6. However, the listed doses by 

pathway in Table G-11 that are attributed to the ER do not appear in the ER. (0619-7-14 [Maher, 

William])

Response: Section G.2.2.6 and Table G-11 along with their references have been revised as 

appropriate. 

Comment: DEIS Appendix G, Subsection G.2.4.4, Page G-17, Table G-15: DEIS Table G-15, 

"Comparison of FPL and NRC Staff Estimated Gaseous Effluent Doses to Unit 7 Construction 

Workers," compares annual dose values by source. There are instances where the doses 

attributed to FPL are inconsistent with ER Table 4.5-4: a. For the "Units 3 and 4" source, the 

"Skin Dose" reported for FPL is 0.0022 mrem/yr. ER Table 4.5-4 reports this same dose as 

0.0031 mrem/yr. b. For the "Units 3 and 4" source, the "TEDE" reported for FPL is 0.0022 

mrem/yr. ER Table 4.5-4 reports this same dose as 0.0023 mrem/yr. (0619-7-15 [Maher, William])

Response: In the final EIS, Section G.2.4.4, Page G-17, Table G-15 dose values have been 

changed to the following FPL dose values: 

For row "Units 3 and 4" the FPL Skin Dose has been changed from 0.0022 To 0.0031. 

For row "Units 3 and 4" the FPL TEDE Dose has been changed from 0.0022 To 0.0023. 

Appendix E October 2016 E-347 NUREG–2176
Comment: DEIS Appendix G, Subsection G.2.5.3, Page G-19, Table G-18: DEIS Table G-18, 

"NRC Staff Estimate of Non-Human Biota Doses for Proposed Turkey Point Units 6 and 7 for 

One Unit", presents estimates of non-human biota doses expressed as annual absorbed dose. 

For consistency with DEIS Table G-19, these doses should be expressed as daily absorbed 

dose. (0619-7-16 [Maher, William])

Response: The dose values in Table G-18 are in mrad/yr because the GASPAR output is in 

annual doses. However, in Table G-19, the doses are being compared to International Atomic 

Energy Agency/NCRP guidelines, which necessitates providing doses in mrad/d. No changes 

to the EIS were made as a result of this comment. 

Comment: DEIS Appendix G, Subsection G.2.2.4, Tables G-8 and G-9, Page G-12: DEIS 

Table G-8 lists values for the "FPL and NRC Staff Skin Dose (mrem/yr)" for Inhalation, 

Vegetable, and Meat. ER Table 5.4-7 reports "0" for each of the corresponding doses. 

Additionally, the "Total MEI Dose" via the Skin pathway by Inhalation reported in the DEIS for an 

adult is 0.0622 mrem/year and is 0 mrem/year in ER Table 5.4-7. This discrepancy also 

appears in DEIS Table G-9 in the 5th row. DEIS Table G-9 reports a Skin dose of 0.04 

mrem/year for a child via the Inhalation pathway, whereas the ER reports 0 mrem/year for a 

child. (0619-7-13 [Maher, William])

Response: In the final EIS, for clarification, for each value in question in Tables G-8 and G-9, 

the following format is now used: [FPL]/[NRC] (where [FPL] is the FPL value and [NRC] is the 

NRC value). A note has been added to each table to discuss the revised format. 

Comment: There are a few instances in the DEIS text where the DEIS either states that 

Revision 6 of Florida Power & Light's (FPL) Environmental Report (ER) (FPL 2014-TN4058) 

incorporated Revision 19 of the Westinghouse AP1000 Design Control Document (DCD) or that 

the FPL application refers to Revision 17 of the AP1000 reactor certified design. Revision 19 of 

the AP1000 DCD was incorporated as early as Revision 3 of the Units 6 & 7 COLA, DEIS 

reference (FPL 2011-TN127). Instances in the DEIS include: a. DEIS Section 5.9, Page 5-97, 

Lines 36-41. (0619-1-3 [Maher, William])

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 4.9.2, Page 4-

138, Lines 5-7 "FPL estimated a total body dose from Unit 6 of...5.5 mrem/yr based on a 

worker occupancy...2,080 hours annually (FPL 2014-TN4058)." ER Table 4.5-4 ER Table 4.5-4 

shows the total body dose of 5.2 mrem from Unit 6 and the total effective dose equivalent 

(TEDE) of 5.5 mrem from Unit 6. (0619-2-27 [Maher, William])

Response: The text in Sections 4.9 and 5.9 was revised to be consistent with Revision 6 of 

the ER. 

Comment: Numerical value inconsistencies within the draft EIS: Subsection 5.9.3.2, Page 5-

107, Lines 22-25 "...the estimated collective whole body dose to the population living within 50 

mi of the Turkey Point Units 6 and 7 is 9.4 person-rem/yr..." Subsection 5.9.3.2 Page 5-10 

Lines 10-12 ER Table 5.4-10 DEIS Subsection 5.9.3.2: "In ER Table 5.4-10 (FPL 2014-

TN4058), FPL estimated...collective total body dose within a 50 mi radius...8.0 personrem/yr..." ER Table 5.4-10 reports 8.0 person-rem/yr as the collective dose for Turkey Point 

Units 6 and 7. (0619-2-36 [Maher, William])

Response: Section 5.9 of the EIS was updated to correct the inconsistency related to whole 

body dose. 

Appendix E NUREG–2176 E-348 October 2016
Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Appendix G Subsection 

G.2.4.3, Page G-16, Line 33-35 "For dose calculation purposes, the average location of the Unit 

7 worker was assumed to be at the center of Unit 7 reactor. Table 3.10-2 from the ER (FPL 

2014-TN4058) estimates the maximum workforce for Unit 7 during any month to be 3,950 

people." ER Table 3.10-2 ER Subsection 4.5.3.3 DEIS Table G-16. ER Table 3.10-2 reports the 

maximum construction workforce as 3,950 people. (The maximum construction workforce after 

fuel load is 2800 people.) Table G-16 defines footnote '(c)' and refers to a maximum Unit 7 

worker population of 2800 people (0619-2-30 [Maher, William])

Response: Table G-16 has been changed to be consistent with the expected workforce 

numbers reported in Revision 6 of the ER. 

Comment: The potential economic impacts of radioactively contaminating these ports and 

waterways is staggering. The draft EIS for Turkey Point 6 and 7 is incomplete because it fails to 

take into account the site's location alongside economically and biologically critical waterways of 

the United States. (0615-2-22 [Bethune, David])

Response: The EIS takes into account the areas around Turkey Point Units 6 and 7. The NRC 

reviews and assesses the impacts (both radiological and non-radiological) on land and water 

features, and includes (but not just limited to) biological, human, and economic impacts of the 

construction, operation, and decommissioning of Turkey Point Units 6 and 7. 

The NRC review and assessment looks at normal, off-normal, and postulated accident releases 

to the environment. As a result of this review and assessment, the NRC determined that the 

release of gaseous radioactive effluents enveloped the postulated releases from Units 6 and 7. 

As presented in EIS Section 5.9, due to the applicant meeting the regulations of 10 CFR Part 20 

for gaseous radioactive effluent releases, the health effects to members of the public and nonhuman biota from all radioactive effluent releases are SMALL. This includes nearby ports and 

waterways. 

No change was made to the EIS as a result of this comment. 

E.2.17 Comments Concerning Accidents - Severe 

Comment: I don't want another Fukushima. (0008-10 [Finver, Jody])

Comment: FPL should be denied a license for Turkey Point expansion for many reasons:...2. 

Too dangerous. We don't want Fukushima here in Miami. (0022-2 [Read, Alice Gray])

Comment: I was born in the 1950's, and have been living with the threat of nuclear energy for 

my whole life, as long as I can remember. Although the dropping of atomic bombs on Hiroshima 

and Nagasaki was unspeakable, I believe the ongoing nuclear catastrophe at Fukushima poses 

the greatest threat to the future of life on Earth that we have ever seen. The people of Japan 

trusted the TEPCO power plant owners and developers who pooh-poohed the dangers of 

building multiple nuclear plants in that beautiful spot by the ocean. Their trust has proven to be 

woefully misplaced. (Added while speaking) So to Devin Caraza, the gentleman from FPL who 

spoke, you'll forgive me if I just can't take your word for it when you tell us everything is safe 

now. After Fukushima, it's clear that nuclear energy is way too dangerous, and it's impossible to 

either prevent or clean up nuclear accidents. (0078-1 [Wilansky, Laura Sue])

Appendix E October 2016 E-349 NUREG–2176
Comment: HAVE WE NOT LEARNED FROM THE JAPAN DISASTER THAT PUTTING A 

NUCLEAR PLANT BY A WATER SOURCE IS STUPID!!!!! (0108-1 [Jurin, Richard])

Comment: It is a bad place to build a nuclear plant as it is too close to the water as was 

Fukashima. (0122-3 [Meyer, Paul])

Comment: We are totally opposed to the expansion of nuclear generated energy at Turkey 

Point - for the following reasons: 1) Too dangerous (as in the Fukushima disaster in Japan)

(0129-1 [Mayer, Doug])

Comment: Of course, beyond the daily addition of heated waters and waste, the potential 

disaster related to weather or other operational failure looms large. We might think we've 

engineered the plant properly, but as Fukishima showed us, Mother Nature has a way of 

overwhelming man made systems. (0130-3 [Jones, Diane])

Comment: Often the NIMBY attitude is applied to perfectly reasonable plans. This is not one of 

those cases. By approving this proposal, and putting South Florida at Fukushima-like risk, the 

NRC could have blood on its hands in the future. (0133-4 [Corral, Oscar])

Comment: Another disaster waiting to happen like in Japan. (0149-8 [Nelson, Joyce E.])

Comment: BUT A MUCH LARGER DANGER LOOMS. ALL ONE HAS TO DO IS REMEMBER 

THE DEVASTATION THAT OCCURRED IN JAPAN NOT VERY LONG AGO TO KNOW THAT 

MOTHER NATURE WILL REEK HAVOC AT WILL IN SPITE OF ANY AND ALL HUMAN 

PRECAUTIONS. CLOSE PROXIMITY TO OPEN WATER AND RISING SEA LEVELS IS A 

DISASTER WAITING TO HAPPEN. (0164-1 [Chrissos, H. L. Chris])

Comment: We should learn and apply some important lessons from the Fukushima Daiichi 

disaster. (0174-1 [Swensen, Harry])

Comment: The tragedy of Fukushima should have been the last word on building nuclear 

plants in vulnerable coastal locations like this one. (0240-8 [Commenters, Multiple])

Comment: Proponents of FPL's new nukes claim that expansion is safe, and that every 

eventuality has been considered and planned for. I must point out that the TEPCO must have 

made the same claims while seeking approval of Fukushima. (0252-11 [Van Leer, Sam])

Comment: We could rethink this after Fukushima is no longer threatening to destroy the 

planet? (0276-1 [Taylor, Kirk])

Comment: Look what has happened at Chernobyl and Fukushima. The risk is way too high[.]

(0329-3 [Baumwall, Douglas])

Comment: The ongoing disaster at Fukushima, Japan is precisely the sort of thing that might 

happen at Turkey Point. None of the experts can actually say for certain how high the dikes 

need to be in every possible event. (0342-2 [Merleaux, Derek])

Comment: No more Fukishima's. (0344-2 [Hull, Meagan])

Comment: Did we learn nothing from what happened in Japan? (0359-2 [LoBiondo, Roana and 

Michael])

Appendix E NUREG–2176 E-350 October 2016
Comment: The era of nuclear power ended with the Fukushima melt down. (0440-2 [Hoyle, 

Lester and Judy])

Comment: After Fukushima, we know that nuclear power plants are NOT safe, and we should 

never be expanding or building new ones. (0441-1 [Bender, Kae])

Comment: ... and-as the world has seen from the Fukushima power plant debacle-a profound 

potential for incalculable damage to everything, people included, should the unthinkable happen 

and a disaster strike. (0449-1 [Benton-Janetta, Lori])

Comment: The ongoing disaster at Fukushima should has shown convincingly that nuclear 

power is a dead-end, quite literally. (0458-1 [Polk, James])

Comment: If you all need a hint look at how the Fukushima nuclear plant is faring. How many 

more of these time bombs are you all willing to place in our country? (0459-2 [Smyke, Pete])

Comment: After Fukashima and the continuing radiation disaster, Are you Crazy????? (0487-1

[Caswell, Susan])

Comment: You might remember Fukushima, as well. (0492-3 [Mckee, Sarah])

Comment: We don't need to be reminded of the horror the Japanese suffered when their 

power plant was hit by a big wave. (0495-3 [Mazzarella, Rebecca])

Comment: Do you want another Fukushima??? (0540-1 [Burge, Laura])

Comment: We do not plan to have a catastrophe but it has happened with Japan's nuclear 

plants as well as oil spills that had disastrous results for the local areas and widespread areas in 

Japan. (0541-2 [Zarsky, Terry])

Comment: There are so many reasons why this is a BAD decision. We can't afford to have a 

FUKUSHIMA incident off the South East Coast of Florida. It will be a matter of time before a 

hurricane will hit this area again. (0548-2 [Scott, Ruth])

Comment: Look what happened in Japan you think that won't happen here? (0549-2 [Allison, 

Noreen])

Comment: The tragedy of Fukushima should have been the last word on building nuclear 

plants in vulnerable coastal locations like this one. (0551-3 [Anonymous, Anonymous])

Comment: Although I am not opposed to nuclear power generally (so long as waste can be 

properly dealt with), I believe this application is misguided. Clearly, the experience of Fukushima 

in Japan should be causing all regulators to seriously question the wisdom of siting ANY 

additional nuclear facilities adjacent to low-lying shorelines, nature preserves, and significant 

population centers. (0573-2 [Trauner, Keith])

Comment: Hurricane damage to the fuel pool building or its cooling water supply equipment is 

of particular concern at Turkey Point, as without a constant supply of water, a meltdown of the 

fuel rods is assured. (0615-2-26 [Bethune, David])

Comment: The tragedy of Fukushima should have been the last word on building nuclear 

plants in vulnerable coastal locations like this one. (0625-3 [Felinski, Julee])

Appendix E October 2016 E-351 NUREG–2176
Comment: I will sum it up with one word Fukishama! (0638-1 [Anonymous, Charity])

Comment: Think Fukushima!!! (0651-4 [Young, Kim])

Comment: We have seen what can happen when nuclear plants are located near large bodies 

of water-witness Japan. (0692-1 [Nickerson, Nancy])

Comment: We still have to deal with Fukushima, you know. (0695-3 [Nappe, Judith])

Comment: Do we really want to set ourselves up for the problems Japan experienced with 

their nuclear reactors recently? (0699-1 [Stocker, Nancy])

Comment: The tragedy of Fukushima should have been the last word on building nuclear 

plants in vulnerable coastal locations like this one. No amount of "profit" will ever replace the 

destruction and loss of life from having a nuclear fallout or leak from a facility such as this.

(0712-1 [Almer, Anessa])

Comment: One of the big lessons we learned from Fukushima is that when you lose the ability 

to run cooling water through the core reactor, through the thousands of pounds of waste nuclear 

material, that sits right now on the shores of Biscayne Bay, it melts down. It did melt down in 

Fukushima. It almost could have happened at Turkey Point. That was -- we dodged the bullet 

there. All these things happened. All these things happened. And this is safe? (0721-22-10

[Schwartz, Matthew])

Comment: Another big concern of mine that's been raised here by some other people is the 

spent fuel storage. This is exactly the same setup as Fukushima, and this plant uses the same 

type of fuel. They use a zirconium coated fuel pellets. The zirconium interacts with steam and 

water, in the case of a meltdown, to produce hydrogen, and that hydrogen is explosive. It's 

exactly what exploded in Fukushima. (0721-23-5 [Bethune, David])

Comment: So we're creating, if we license this plant here, another potential Fukushima 

situation with two fuel pools that are exposed and open to the air essentially, and in largely 

unprotected buildings. If those fuel pools lose water we will have a meltdown. And not only will 

we have a meltdown, but the site will be unapproachable to human beings until the end of 

time. Once that fuel pool is uncovered and there is no water in there, no human beings can go 

back to that site to perform any kind of work at all. So these design basis accidents, about it's all 

-- it's going to be over in three days and we'll just go back and make things right, are completely 

unrealistic. We already saw that with our own eyes that that's not what happens in a fuel pool 

meltdown situation. (0721-23-7 [Bethune, David])

Comment: The last thing I want to bring up is the fact that we're creating another Fukushima 

situation here with multiple plants on the same site. (0721-23-8 [Bethune, David])

Comment: So if you had an accident at one of the nuclear plants, whether it be here or 

anyplace else, we'd probably not be -- not the roof blowing off like in the Ukraine which can 

produce like 10 or 12,000 Roentgens blowing in the air. But you would have no problem here 

but you may have a problem if somebody accidentally or otherwise took the water out where the 

spent rods storage is. It would release probably 1,000, 1,500 Roentgens if that was released. 

So that would be the only thing. (0722-15-2 [McColgan, Robert])

Appendix E NUREG–2176 E-352 October 2016
Comment: It perhaps borders on insanity to begin to even consider another one or two power 

plants, after seeing what has happened with Chernobyl, and Fukashima. (0731-1 [Council, 

Barbara])

Response: The first several pages of Section 5.11 of the EIS discusses the actions taken by 

NRC to enhance the safety of U.S. reactors based on specific lessons learned from the event 

at Japan’s Fukushima Dai-ichi Nuclear Power Plant. On March 12, 2012, the Commission 

issued three Orders and a Request for Information (RFI) under 10 CFR 50.54(f) to holders of 

U.S. commercial nuclear reactor licenses and construction permits. The first Order (EA-12-

049) requires a three-phase approach for mitigating beyond design-basis external events that 

employs installed structures, systems, and components (phase 1), onsite portable equipment 

(phase 2), and offsite support (phase 3). For the AP1000 passive design, passive means 

assure the cooling for the core, spent fuel pool, and containment are assured in the first 72 

hours after an accident or external event. The AP1000 design includes ancillary diesel 

generators and features to provide make-up water after 72 hours and up to 7 days to the 

passive systems, such as the passive containment cooling water ancillary storage tank, and 

ancillary diesel generators. This equipment is protected from external hazards including the 

safe-shutdown earthquake (SSE). The third Order (EA-12-051) requires reliable spent fuel pool 

level instrumentation (77 FR 16082) (TN1424). The AP1000 containment design differs from 

those identified in the second Order; therefore, the actions addressed in the second Order are 

not applicable to Turkey Point Units 6 and 7. The NRC staff, with the Commission’s approval, 

implemented a plan to address the requirements in the Orders and the RFI for pending COL 

applications. 

In regard to the Turkey Point COL application, the NRC staff issued RAIs to FPL requesting 

information to address the requirements of the first Order on mitigation strategies for beyond 

design basis accidents and the third Order on spent fuel pool instrumentation, respectively, and 

information sought in the first RFI for a seismic reevaluation and the fifth RFI in regard to 

emergency preparedness (NRC 2012-TN3239). FPL addressed the first and third Orders along 

with the fifth RFI by proposing license conditions that would require action before initial fuel 

loading for proposed Units 6 and 7 (FPL 2014-TN4058; FPL 2014-TN4103). The NRC’s 

evaluation of FPL’s responses are addressed in the NRC’s advanced safety evaluation 

(ASE). In particular, ASE Section 2.4 documents the staff evaluation of the potential effects of 

hurricanes on the proposed new units (NRC 2016-TN4775), and ASE Section 9.1 documents 

the staff evaluation of the spent fuel pool design (NRC 2016-4803). As discussed in Section 

5.11.2.4 of the EIS, the AP1000 reactor vendor considered extratropical cyclones, hurricanes up 

to Category 5 on the Saffir-Simpson scale, and tornadoes up to EF5 on the enhanced Fujita 

scale in the AP1000 design. The total contribution of high winds to core damage frequency 

(CDF) was reported to be 1.38 × 10-8 per year by the AP1000 reactor vendor (Westinghouse 

2011-TN261), assuming that only safety systems are available. The more detailed analysis in 

the FSAR (FPL 2014-TN4069) specifically for Turkey Point site also estimated CDF probability 

from high wind on the order of 1.0 × 10-8 per year. The safety design features of the AP1000, 

lead warning time before the arrival of hurricane force winds, and NRC’s oversight policies are 

all considered in the NRC evaluation of plant safety in case of hurricane events. The common 

concern raised by the comments is already considered in Section 5.11 of the EIS; therefore, 

there were no changes made to this EIS. 

Comment: The lessons of Chernoble and the nuclear disaster at Fukushima Daiichi after the 

Earthquake & Tsunami of March, 2011 teach me that the balance of risk versus reward has not 

been properly considered with this proposal. Planning & Construction fail to be designed to 

meet the extremes of the unexpected. The unexpected occurs frequently enough that the 

Appendix E October 2016 E-353 NUREG–2176
consequences need be considered. One consequence of the Fukushima nuclear disaster was 

the evacuation of everyone within a fifty-mile radius of those plants. A fifty-mile radius 

evacuation here, because of a possible disaster at Turkey Point, would extend from Islamorada 

in the Florida Keys all the way to Hollywood, Florida. See this link: 

http://www.nytimes.com/interactive/2011/03/16/world/asia/japan-nuclear-evaculation-zone.html.

(0213-2 [Hyams, Charles])

Comment: Haven't we learned anything from the devastation that resulted from the reckless 

planning that went into not only building the Nuclear plant in Fukushima but the clean up 

process for a accident/meltdown as well? As I type a steady flow of radioactive toxic water is 

released into the Pacific ocean and the world stands by helpless! We can build the best bombs 

and weapons in the world but we can NOT contain nor sufficiently clean up from a nuclear 

accident or a deep water well blow out! (0259-1 [Lettieri, Tammy])

Comment: The idea that a nuclear plant will never have an accident that endangers the public 

health and safety defies both history and logic. All industries experience accidents of one kind or 

another sooner or later and the latest example in Japan shows how the manufacture of energy 

using nuclear power can result in a killing calamity that takes human life and destroys property.

(0332-1 [Ross, Sherwood])

Comment: You would think that Three Mile Island, Chernobyl, and Japan's Fukushima 

disasters would tell us all we need to know about the sudden, unexpected and long, long term 

dangers of nuclear energy. (0339-1 [Provost, Allan])

Comment: History has shown that unanticipated "incidents" can occur at Nuclear Power 

generating facilities. History has also shown that the results of such an incident can be 

catastrophic and long lasting. (0358-3 [Norman, Ronald])

Comment: No matter how safe those who profit say they are, a Fukushima type accident or 

terrorist attack could render most of South Florida uninhabitable. (0371-2 [Haffmans, Edmund])

Comment: And I have been reading about Japan. They are finding radiation pretty far from the 

plants. (0373-6 [Lee, Nancy])

Comment: I realize that the risk of a nuclear accident is very low. But the consequences are 

astronomical. Can you image a Fukushima-type accident here in Florida? Can you imaging 

evacuating everyone from the Palm Beaches to Key West? Do you want to be responsible for 

such a disaster? (0643-1 [Joannou, Jr., Benjamin])

Comment: Until there is technology to cean up a meltdown, like in Fukushima and Chernobyl 

and God only knows what else. I say absolutely not. (0644-2 [Anonymous, Anonymous])

Comment: I believe that the ongoing nuclear catastrophe at Fukushima poses the greatest 

threat to the future of life on earth that we've ever seen. The people of Japan trusted the 

TEPCO power plant owners and developers who poo-poo'd the dangers of building multiple 

nuclear plants in that beautiful spot by the ocean. Their trust has proven to be woefully 

misplaced, and I'm sorry, but I just can't take the assurances of Devon and the folks from FPL 

that they've got everything handled. I don't believe that. After Fukushima it's clear that nuclear 

energy is way too dangerous and it's impossible to either prevent or clean up nuclear accidents.

(0721-28-2 [Wilansky, Laura Sue])

Appendix E NUREG–2176 E-354 October 2016
Response: The Great Tohoku earthquake of March 11, 2011, and the subsequent resulting 

tsunami produced widespread devastation across northeastern Japan, resulting in 

approximately 25,000 people dead or missing, displacing many tens of thousands of people, 

and significantly affecting the infrastructure and industry in the northeastern coastal areas of 

Japan. Nonetheless, the damage to the Fukushima Dai-ichi nuclear power plant from the 

tsunami, including the loss of ac power and almost all safety systems, has not resulted in any 

radiation exposure-related fatalities (UNSCEAR 2014-TN4762; UNSCEAR 2015-TN4763). The 

comments correctly refer to the evacuation of the population residing near the reactor site and 

the need for decontamination near the site. Evacuation and land decontamination are part of 

the input to the MACCS code for the severe accident analysis as described in Section 5.11.2 of 

this EIS. In the event of an actual accident, emergency response management authorities 

would consider whether evacuation is warranted, depending on the circumstances. 

The Turkey Point severe accident risk analyses in Table 5-18 of EIS Section 5.11 includes 

population dose risk, risks of fatalities, and costs associated with evacuation, resettlement, land 

decontamination, interdiction, and condemnation. Table 5-21 of the EIS provides the calculated 

costs of all severe accidents. These costs are part of the evaluation process for implementation 

of severe accident mitigation alternatives as discussed in Section 5.11.3 of the EIS. The 

comments do not provide any information that was not already considered in the evaluation in 

the draft EIS, and no changes were made to the EIS as a result of these comments. 

Comment: Radiation from Fukushima is hitting US shores. Where do you think radiation and 

chemicals from Turkey Point will end up? (0078-10 [Wilansky, Laura Sue])

Comment: BUILDING A NUCLEAR FACILITY NEAR A SENSITIVE ECOSYSTEM IS 

FOOLISH. JUST LOOK AT THE CONTINUING DAMAGE FROM THE FUKUSHIMA NUCLEAR 

DISASTER, WITH RADIATION POURING INTO THE PACIFIC OCEAN AND WAFTING OVER 

THE PACIFIC TO THE WESTERN U.S.A. RADIATION COUNTS NEAR OUR WESTERN 

COAST WERE STOPPED LONG AGO BECAUSE PEOPLE WERE UNWILLING TO REVEAL 

THE REAL THREAT TO THE AMERICAN & CANADIAN PUBLIC. (0201-1 [Reid, Sarah])

Comment: Locating two new nuclear reactors at Turkey Point would seem to invite disaster if 

a severe weather event were to occur, similar to the one that devastated the nuclear plant in 

Japan. Radioactive waste from that disaster has spread by water across the seas to countries 

thousands of miles away. (0280-1 [Betts, Cynthia])

Comment: The ongoing radioactive contaminatio horror emanating from the nuclear fission 

time-bomb plants in Fukushima will be poisoning the Northern Pacific Ocean for countless 

centuries. Fukushima is an extinction level event! (0513-1 [Roehl, Richard Ralph])

Comment: We know that Fukushima has poisoned the whole Pacific. (0673-3 [Dwyer, John P.])

Comment: Radiation from Fukushima is hitting U.S. shores. Where do you think radiation and 

chemicals from Turkey Point will end up? (0721-28-10 [Wilansky, Laura Sue])

Response: Only a trace amount of radioactivity has been detected in the United States from 

this event from airborne or waterborne pathways (Kratchman et al. 2015-TN4737). Based on 

these measurements, the Fukushima Dai-ichi accident resulted in no or negligible impact on 

human health in the United States. This result is unsurprising, since the great distances 

between Fukushima and the United States would result in large amounts of dilution and 

dispersion over those distances, which, in turn, would result in negligible doses in the United 

Appendix E October 2016 E-355 NUREG–2176
States from the Fukushima accident. The comments do not provide any information that was 

not already considered in the evaluation in the draft EIS, and no changes were made to the EIS 

as a result of these comments. 

Comment: It's [the reactor] a prime target in the event of a hurricane. (0008-6 [Finver, Jody])

Comment: I would like to express my concerns and opposition to this projects on 

environmental and quality-of-live grounds. First, we only need to look at the Fukushima incident 

in Japan, a country I lived for over 5 years, to understand the catastrophic potential of this 

project in Hurricane prone Florida. (0024-1 [Roque, Julio])

Comment: I also, have great concerns about the condition of the existing facility. I remember 

that during Hurricane Andrew significant damage occurred at Turkey Point. I can't even imagine 

what will happen to this area if something like that happens again if a facility the size of what is 

proposed becomes reality. (0081-2 [Benson, Mary] [Skove, Ellen H.] [Tompkins, Constance])

Comment: My understanding is that their proposal involves antiquated technology and would 

be highly vulnerable to modest storm surges. (0093-2 [DuPriest, William Robert])

Comment: Nuclear power should not be placed in locations with high hurricane or tsunami 

risk. Fukushima is a lesson we should never forget. (0109-2 [Platt, David])

Comment: The area is also very susceptible to the threats of hurricanes. Hurricane Andrew, 

which hit two decades ago, was a small intense storm. Its full force did not effect Turkey point. 

Its 200+ mph winds totally destroyed the area a few miles to the north. Had it hit Turkey Point 

directly, the consequences could have been devastating and irreversible to our entire 

community. (0115-7 [Trencher, Ruth])

Comment: With Florida being proned to Hurricanes this could be detrimental to our 

communities and our environment. Don't you remember what happened to Japan in 2011?

(0128-2 [Bach, Lili])

Comment: Hurricanes may severely damage them and cause untold damage as was done in 

Japan. (0159-4 [Bazzone, Barbara])

Comment: I need not remind you of the 1992 nuclear reactors at Turkey Point which took a 

direct hit from Hurricane Andrew. . . READ THE DATA. (0250-4 [Fulks, Anna Louise])

Comment: Building the reactors in a hurricane flood zone was unsafe, and just plain stupid in 

the first place. This common sense has been confirmed by the NRC's own findings after 

Hurricane Andrew, which knocked out all or part of its safety, power, access, security and firefighting capacities... for 5 days. (0252-2 [Van Leer, Sam])

Comment: DIDN'T WE LEARN ANYTHING FROM JAPAN'S DISASTER? WHAT HAPPENS 

IF IT GETS HIT WITH A HURRICANE????? (0279-1 [Hall, Linnea M. Fronce Thomas])

Comment: Current safety approaches have been found to be inadequate for preventing melt 

down accidents according to the authors of a report submitted by a very prominent panel of 

scientists, physicists, and engineers, recently convened by Congress. (the best safety efforts 

were used by the Fukashima reactors,but the accident happened anyway, so what will happen 

during a potential huge future hurricane event ?) (0340-9 [Tweeton, Tanya])

Appendix E NUREG–2176 E-356 October 2016
Comment: A strong hurricane would devastate South Florida. (0360-4 [Palmer, Majorie])

Comment: These plants are especially vulnerable to hurricane impacts also. (0647-1 [Burns, 

Terry])

Comment: If there is a hurricane nearby, it will be a huge disaster. (0654-4 [Guy, Sharon])

Comment: 

NRC's Draft EIS is Deficient Because it Mischaracterizes the Impact of Hurricane Andrew 

on the Turkey Point Site: Not only has NRC's DEIS failed to address the potential impacts 

upon the Turkey Point site of climate change but when NRC did address Hurricane Andrews 

impact on the site NRC mischaracterized and downplayed the risk posed by severe weather 

events. According to NRC's DEIS: 

Hurricane Andrew was historic because it was the first time that a hurricane significantly 

affected a commercial nuclear power plant. The eye of the storm, featuring sustained 

winds of up to 145 mph and gusts of 175 mph, passed over the Turkey Point site and 

caused extensive onsite and offsite damage. However, there was no damage to the 

safety-related systems of Units 3 and 4 except for minor water intrusion and some 

damage to insulation and paint (NRC 1993-TN542). 

This is a significant mischaracterization of the impact of Hurricane Andrew on Turkey Point. In 

fact Hurricane Andrew resulted in a loss of offsite power at Turkey Point that lasted six and a 

half days according to the joint NRC/INPO review: 

A high priority was placed on restoring offsite power to Turkey Point. The Davis 1 line to 

the Turkey Point switchyard was energized 4V2 days after the storm, but suffered 

intermittent losses for several hours. Six and one-half days after the storm, the startup 

transformers for Units 3 and 4 were energized, and the EDGs were shut down. A second 

offsite line became available about a day later (see Appendix K for details). 25 Section 3 

When offsite power was not available, the four EDGs ran continuously to supply plant safetyrelated loads. An EDG tripped on two instances during this period. Seven hours after the storm 

had passed, the "A" EDG for Unit 4 tripped during efforts to troubleshoot and isolate a ground 

on the dc control power supply. The crew immediately recognized that the troubleshooting 

procedure in use applied when the bus is energized from offsite power but not when the EDG is 

supplying loads. The EDG was restarted again after a few minutes, and the procedure revised. 

The "A" EDG for Unit 3 tripped 3!/? days after the storm. Troubleshooting to locate the cause of 

the trip was unsuccessful, and the EDG was successfully restarted in 2/4 hours. No further 

problems were encountered. (Effects of Hurricane Andrew on the Turkey Point Nuclear 

Generating Station from August 20-30, 1992, Jointly sponsored by Institute of Nuclear Power 

Operations and the U.S. Nuclear Regulatory Commission, March 1993, section 3, p. 25. 

(http://www.osti.gov/scitech/servlets/purl/10158520/) 

The NRC seems to have merely cut and paste the Information Notice on Hurricane Andrew into 

its EIS but for some reason NRC decided to edit the following which contradict the blithe 

assurances in the DEIS. The NRC's Information Notice on the impact of the Category 5 

hurricane on the site states that, "(t)he onsite damage included loss of all offsite power for more 

than 5 days, complete loss of communication systems, closing of the access road, and damage 

Appendix E October 2016 E-357 NUREG–2176
to the fire protection and security systems and warehouse facilities. (http://www.nrc.gov/readingrm/doc-collections/gen-comm/infonotices/1993/in93053.html) 

Damage at the Turkey Point Site was not limited to the electrical infrastructure. As the Union of 

Concern Scientists has pointed out FPL, Turkey point and the people of Florida got lucky: 

"The fire protection system at the plant was disabled when winds knocked a high tower 

tank onto a 500,000 gallon tank containing water for the fire protection system .... If the 

damaged stack had fallen, it could have landed on the building housing the emergency 

diesel generators for the nuclear units. Considering that the diesel generators were the 

only source of ac power at the plant for several days, it was extremely fortunate that the 

leaning stack of Turkey Point did not fall." (http://allthingsnuclear.org/fission-stories-48-

hurricane-andrew-vs-turkey-point/) [FIGURES-Water tower and Chimneys] 

The extent to which NRC mischaracterized the impact of Hurricane Andrew in the DEIS is 

demonstrated by the fact that NRC's own risk analysts found the hurricane to be an important 

accident precursor. NRC's risk analysts counted both units as accident precursors and 

attributed a risk of 1.6E-4 or 1 in 10,000. (U.S. Nuclear Regulatory Commission, Precursors to 

Potential Severe Core Damage Accidents: 1992 A Status Report, NUREG/CR--4674 

ORNL/NOAC-232 Vol. 17, December 1993, p. 31. 

(http://www.osti.gov/scitech/servlets/purl/10125322/) (0716-9 [Riccio, Jim])

Response: The NRC disagrees with the comments concerning Hurricane Andrew effects on 

Turkey Point Units 3 and 4. The NRC has years of experience with hurricanes and other severe 

storms. Nuclear facilities were affected by Hurricane Andrew in Florida in 1992, by Katrina in 

Louisiana in 2005, and by Sandy along the East Coast in 2012, among others. Lessons learned 

from each hurricane are examined and enhancements to safety are made if deemed 

necessary. Since hurricanes have long lead warning times (on the order of days), plant 

shutdowns are commenced long before a hurricane arrives along with other protective 

measures and actions. In response to lessons learned from previous weather events, 

emergency planning and evacuation notification systems have been enhanced (e.g., see NRC 

Information notices 93-53 and 97-05 for Hurricane Andrew). Additionally, as part of the NRC’s 

Fukushima lessons learned actions and orders, Turkey Point Units 3 and 4 have undergone 

additional analyses, including for hurricane events (NRC 2014-TN4738). The site is also part of 

the industry’s FLEX initiative to address mitigation strategies for beyond design basis external 

events. 

The comments cite the estimated risk of CDF calculated using probabilistic risk assessment 

(PRA) techniques for existing Turkey Point Units 3 and 4. The estimated risk for the existing 

units, however, does not apply to the proposed new units, nor do those numbers reflect how the 

Units 3 and 4 in fact performed in the face of Hurricane Andrew, which is discussed further 

below. As discussed in Section 5.11.2.4 of the EIS, the AP1000 reactor vendor considered 

extratropical cyclones, hurricanes up to Category 5 on the Saffir-Simpson scale, and tornadoes 

up to EF5 on the enhanced Fujita scale in the AP1000 design proposed for Turkey Point Units 6 

and 7. In regard to the estimated risk for proposed Turkey Point Units 6 and 7, calculated with 

PRA techniques, the total contribution of high winds to CDF was reported to be 1.38 × 10-8 per 

year by the AP1000 reactor vendor (Westinghouse 2011-TN261), assuming that only safety 

systems are available. The more detailed analysis in the FSAR (FPL 2014-TN4069) specifically 

for Turkey Point site also estimated CDF probability from high wind on the order of 1.0 × 10-8

per year. The safety design features of AP1000, lead warning time before the arrival of 

Appendix E NUREG–2176 E-358 October 2016
hurricane force winds, and NRC’s oversight policies are all considered when assuring plant 

safety in case of hurricane events. 

The comments provided no new information or challenges to the proposed new reactors not 

considered in the draft EIS; therefore, no changes were made to the EIS in response to these 

comments. 

Comment: It's not cost effective for us and it poses a mayor catastrophic risk in the event a big 

hurricane hits us or with the rise in sea levels. (0087-3 [Lange, Alexandra])

Comment: While I am normally not opposed to nuclear energy generation, I would like to know 

how the project's design engineers have addressed the concern of susceptibility to storm surge 

from a hurricane, so as to learn from and further prevent the existential threat posed by a repeat 

of the Fukushima Daiwa plant in our own back yard. (0132-1 [Mauri, Tom])

Comment: I believe the purpose of these lines to maintain a fully depreciated facility ignores 

the risk of an outdated & highly dangerous technology (i.e. Japan's Fukushima disaster) in an 

area prone to powerful hurricanes, storm surge, and increasing sea levels which heightens the 

risk of water contamination & damage to the reactor or its cooling system. (0134-1 [Lucero, Olga])

Comment: This area is subject to sea level rise and tropical storm impacts. It is inconceivable 

that this location could be used for a nuclear power plant. It is not possible to guarantee the 

safety of the operation. (0151-1 [Stanko, Janet L.])

Comment: Tsunamis may not be as frequent as in the Pacific but they are possible in the 

Atlantic and storm surges can be as bad as many tsunamis. By not accounting for sea level rise 

along with tsunamis and storm surges we are risking another Fukushima on our own doorstep.

(0236-2 [Enfield, David])

Comment: This is an unsafe place for a nuclear plant being barely above sea level, in a 

hurricane zone & next to an ocean. (0729-1 [Rader, D.L.])

Response: As discussed in Section 5.11 of this EIS the AP1000 reactor vendor considered 

extratropical cyclones, hurricanes up to Category 5 on the Saffir-Simpson scale, and tornadoes 

up to EF5 on the enhanced Fujita scale. The total contribution of high winds to CDF was 

reported to be 1.38 × 10-8 per year by the AP1000 reactor vendor (Westinghouse 2011-TN261), 

assuming that only safety systems are available. The more detailed analysis in the FSAR (FPL 

2014-TN4069) specifically for Turkey Point site also estimated CDF probability from high wind 

on the order of 1.0 × 10-8 per year. The safety design features of the AP1000, lead warning 

time before the arrival of hurricane force winds, and NRC’s oversight policies are all considered 

when assuring plant safety in case of hurricane events. 

Similarly, for possible severe accidents due to external flooding, the EIS in Section 5.11 states 

that each new reactor application evaluates the natural phenomena that are pertinent to the site 

for the proposed reactor design by applying present-day regulatory guidance and 

methodologies. This includes a determination of the characteristics of flooding at the site. The 

plant design elevation accounts for high tides in Biscayne Bay, which, in combination with 

maximum storm surge plus sea-level rise, are controlling for external floods. ASE Section 2.4 

assesses the maximum external flood as being within the design basis of the site (NRC 2016-

TN4775). The associated severe accident risk due to external flooding is discussed in Section 

5.11.2.4 of the EIS and also shown to be small. 

Appendix E October 2016 E-359 NUREG–2176
The comments did not provide any information in addition to that already considered in the draft 

EIS. Therefore, no changes were made to the EIS as a result of these comments. 

Comment: FPL has failed to adequately account for the intersecting impacts of sea level rise 

and storm surge. A study by John Perkins and Natalie Kopytko published in the journal Energy 

Policy in January 2011 concerning 9 coastal nuclear reactors in the US found that while 

currently operating nuclear plants were built high enough to withstand sea level rise alone for 

the next 50 years, which is beyond the operating lifetime of those plants, storm surges from 

Category 4 and 5 hurricanes will completely inundate those plants within their lifetimes--see 

http://www.climatecentral.org/news/sea-level-rise-brings-added-risks-to-coastal-nuclear-plants.

(0246-2 [Shlackman, Mara])

Comment: Some people consider Hurricane Andrew to be a Category 6 for its power (the 

conventional scale tops out at Cat 5). It spawned many tornadoes, with wind-speeds that were 

in addition to the Hurricane's. Many climate scientists to be growing in strength, and perhaps in 

frequency. Numerous records have been broken in the past decade. Hurricane Storm-Surge will 

be boosted to higher levels by SLR with each passing year. (0252-10 [Van Leer, Sam])

Comment: Deeper Examination of Foreseeable Emergencies. As noted in the previous 

section, the DEIS acknowledges the potential that "[c]limatological changes might affect the 

average environmental risks of severe accidents," however it concludes that the core damage 

frequencies of the relevant reactor design are low enough that this is an unlikely problem. DEIS 

at I-13. This does not appear to be a thorough analysis. Simply stating, without further 

discussion or support, that the reactor design standards are sufficient to protect from future 

climate harm, does not satisfy NEPA. (0456-18 [Miami, City])

Comment: Comment 12: The final Environmental Impact Statement should incorporate a 

full analysis of the potential for severe accidents related to climate change or cite to 

relevant research. Although the DEIS does acknowledge that there is the potential for a severe 

accident resulting from climatological changes, it does not discuss specific scenarios or 

estimated probabilities. The final Environmental Impact Statement should include a full analysis 

to better demonstrate the nature and likelihood of the risks acknowledged in the DEIS. (0456-19

[Miami, City])

Comment: Comment 13: The final Environmental Impact Statement should incorporate a 

full analysis of the potential for severe accidents related to climate change or cite to 

relevant research. Although the DEIS does acknowledge that there is the potential for a severe 

accident resulting from climatological changes, it does not discuss specific scenarios or 

estimated probabilities. The final Environmental Impact Statement should include a full analysis 

to better demonstrate the nature and likelihood of the risks acknowledged in the DEIS. (0611-14

[Haber, Matthew S.])

Comment: However, due to rising sea-levels and hurricanes the potential for this plant to 

become another Fukushima in its lifetime is very real. (0639-2 [Haselhurst, Richard])

Comment: The site proposed for expansion is located directly on the shores of Biscayne 

National Park. If designed correctly there would be no concerns like Japan plant flooding do to 

weather related wind/huricane potential sea level rise. (0694-5 [Carpenter, Rory])

Response: As discussed in Section 5.11, the AP1000 reactor vendor considered extratropical 

cyclones, hurricanes up to Category 5 on the Saffir-Simpson scale, and tornadoes up to EF5 on 

Appendix E NUREG–2176 E-360 October 2016
the enhanced Fujita scale. The total contribution of high winds to CDF was reported to be 1.38 

× 10-8 per year by the AP1000 reactor vendor (Westinghouse 2011-TN261), assuming that only 

safety systems are available. The more detailed analysis in the FSAR (FPL 2014-TN4069) 

specifically for Turkey Point site also estimated CDF probability from high winds on the order of 

1.0 × 10-8 per year. The safety design features of the AP1000, lead warning time before the 

arrival of hurricane force winds, and NRC’s oversight policies are all considered when assuring 

plant safety in case of hurricane events. 

EIS Appendix I indicates that nuclear power plants must be designed to withstand natural 

events. General Design Criteria 2 of 10 CFR Part 50 Appendix A requires nuclear power plants 

to be designed to withstand the effects of natural phenomena without loss of capability to 

perform their safety functions. A plant’s design must reflect appropriate consideration of the 

most severe natural phenomena events that have occurred at or near the proposed site, with 

margin to account for uncertainty. In addition, the EIS does recognize that the safety review 

assesses the plant’s capability to withstand external flooding, which is part of the design basis 

for proposed Turkey Point Units 6 and 7. As discussed in the staff’s ASE Section 2.4 (NRC 

2016-TN4775), the plant design elevation accounts for high tides in Biscayne Bay, which, in 

combination with maximum storm surge plus sea-level rise, are controlling for external 

floods. Therefore, with the information in Section 5.11.2.4 of this EIS and the safety finding that 

the plant at this site would meet all necessary regulatory requirements, the associated severe 

accident risk due to external flooding is small. 

Climate change in general and rising sea level are expected to be gradual. Under 10 CFR 

50.54(f), the NRC could determine whether or not a license should be modified based on a 

review of the impact of climate change on plant operation and adaptation, emergency 

preparedness, and the availability of nearby structures used for plant operation and safety. If 

the NRC determines that additional safety enhancements are necessary based on information 

obtained in accordance with 10 CFR 50.54(f), the NRC can require that such enhancements be 

implemented in a timely manner to assure adequate protection of the public within the current 

NRC regulatory process. 

In conclusion, the NRC staff published an Advanced Safety Evaluation that analyzes all aspects 

of reactor and operational safety including hurricane and flooding events. The primary purpose 

of the EIS is to evaluate the environmental impacts resulting from the construction and 

operation of the proposed plant. The comments express concern about the possibility of an 

event that might damage the proposed units, but do not raise any issue in regard to the 

substance of the severe accident evaluation in EIS Section 5.11. The staff clarified in Appendix 

I of the EIS the NRC process for ensuring plant safety over the licensing period with respect to 

sea level rise as a result of these comments. 

Comment: History has shown that the potential exists for unplanned "incidents" to occur at or 

within Nuclear Power Plants. Fukushima, Three Mile Island and Chernobyl are just 3 examples 

of when the best intentions can go terribly wrong. The results of such an unplanned "incident" 

can be catastrophic and long lasting. (0039-2 [Violich, Francesca])

Comment: Very recent history has demonstrated that the potential exists for unanticipated 

"incidents" to occur at or within Nuclear Power facilities. Fukushima, Three Mile Island and 

Chernobyl are just three examples of how the very best intentions can go terribly wrong. The 

results of these actual unanticipated "incidents" have proven both catastrophic and long-lasting. 

FP&l's recent problems with the reactor cooling water temperatures only reinforces the fact that 

Appendix E October 2016 E-361 NUREG–2176
unanticipated problems and "incidents" remain a distinct possibility at Turkey Point. (0044-2

[Commenters, Multiple])

Comment: History (Fukushima, Three Mile Island, and Chernobyl) provides solid evidence that 

nuclear incidents devastate large areas and destroy lives. (0057-3 [Neway, Roberta])

Comment: I do not want to have the next "Fukushima" or "Chernobyl" on my doorsteps! As I 

stated in last month's NRC meeting in Miami at FIU, it's just a bad idea waiting to happen. 

(0178-2 [Almirola, Alejandro])

Comment: Attached is a list of Nuclear power station accidents and incidents with the IAEA 

description for your information and before any approval is given for two new nuclear reactors.

(0250-1 [Fulks, Anna Louise])

Comment: Fukushima, Three Mile Island and Chernobyl are just three examples of how the 

very best intentions can go terribly wrong. The results of these actual unanticipated "incidents" 

have proven both catastrophic and long-lasting. FP&l's recent problems with the reactor cooling 

water temperatures only reinforces the fact that unanticipated problems and "incidents" remain 

a distinct possibility at Turkey Point. (0263-1 [Orzechowicz, Holly])

Comment: An MIT team has estimated that give the expected growth of nurlear power over the 

50 year span from 2005 to 2055, at least 4 serious nuclear accidents would be expected.

(0333-4 [Anonymous, Anonymous])

Comment: I remember 3 mile island. Learn from your mistakes. (0373-9 [Lee, Nancy])

Comment: We should have learned from the errors of Chernobyl, Three Mile Island, and the 

ongoing disaster that is Fukashima that nuclear power is the wrong choice for our energy future.

(0382-2 [Mikowski, George])

Comment: Really think this doesn't need to happen especially since there have been nuclear 

reactors disasters already. (0455-1 [Hardin, Lillian])

Comment: Let's not have another 3 mile island or Fukushima in the United States! (0460-1

[Yarter, E. C.])

Comment: When the regular occurrence of nuclear accidents and meltdowns such as occurred 

at Chernobyl, Three Mile Island and the Fukushima disaster are factored in, the health risks of 

nuclear power rise exponentially and make this form of power generation totally unacceptable.

(0511-4 [Draper, Lonnie M.])

Comment: I wanted to mention, though, that before I came to South Florida I grew up in 

Philadelphia, which is 90 miles downwind from Three Mile Island, and I can tell you firsthand 

what it's like to live in a metropolis of 2 million people undergoing -- or in the midst of a nuclear 

reactor meltdown. And I know that you can reassure us that the same thing can't happen here. 

But remember, too, that NASA assured us that there was no way that a second shuttle could 

fail, right? And so things happen. (0721-16-1 [Rifkind, David])

Comment: I want to talk to the Union guys for a second. When I was a young guy I was a 

Union member, Local 23, Mason Tenders Union. I worked real hard. We had a building in New 

York we were building that we were real proud of, the World Trade Center. We looked at those 

buildings go up, carried lumber, did concrete work. My best friend was Tom Consadine, an 

Appendix E NUREG–2176 E-362 October 2016
electrician. We were so proud to be involved in that project. There was no way on this earth 

those buildings could go down. Nobody ever thought of that. Tommy's still my friend. You know 

what he did the last few years? He's been building the new World Trade Center. I'm going to 

leave everybody with one fact from this meeting they're never going to forget. April 26, 1986, a 

crew of workers goes in to Reactor Number 4 to do a safety check, and they botched it. Nothing 

was wrong with the reactor. They botched the safety check. Well, it's 29 years later and a 

thousand square miles -- this is no exaggeration -- over a thousand square miles around the 

Chernobyl Nuclear Plant are inhabitable from a safety check. So anybody in this room who 

believes it can't happen here, you're kidding yourself. That's all I have to say. (0721-25-1 [Corda, 

Charles])

Comment: "You would think that Three Mile Island, Chernobyl, and Japan's Fukushima 

disasters would tell us all we need to know about the sudden, unexpected and long-term 

dangers of the nuclear energy. But apparently not. At least not when some large corporation like 

FP&L stands to make greater profits by putting Americans in danger and destroying the beauty 

and safety of Florida neighborhoods. (0721-26-2 [Koenigsberg, Linda])

Response: These comments indicate that severe reactor accidents such as those that 

occurred at Three-Mile Island Unit 2 (TMI-2), Chernobyl, and Fukushima Dai-ichi, and their 

consequences are unavoidable. The design of nuclear power plants in accordance with NRC 

requirements affords protection to public health and safety in two basic ways: (1) prevention of 

core damage events such that the likelihood of events that lead to core damage is very low, and 

(2) mitigation of consequences in the event of an accident. The NRC has determined that the 

combination of these two aspects of protection of public health and safety results in an 

acceptably low risk. In addition, enhancements to safety have been made based on the lessons 

learned from previous accidents to further reduce the acceptably low risk from severe 

accidents. The TMI-2 accident brought about regulatory changes for nuclear power plants and 

heightened oversight by NRC, as did the Fukushima accident. The Chernobyl accident did not 

result in regulatory changes for enhancing safety because the design, construction, and 

operation of U.S. reactors is fundamentally different than the Chernobyl reactor. As described 

above in this comment response section, the NRC has taken several actions regarding the 

lessons learned from the Fukushima accident specifically for the Turkey Point Units 6 and 7 

COL application. Additionally, the AP1000 is a passive design and it provides core, 

containment, and spent fuel pool cooling for 72 hours with no operator action needed. These 

cooling functions can be sustained for an extended period beyond 72 hours during which the 

only operator actions are to refill the tank that is the source of water for the passive safety 

systems and distribute the water when needed. The enhanced safety of the AP1000 due to 

these passive features is clearly illustrated in Table 5-20 of the EIS, which compares the health 

risks from severe accidents for an AP1000 reactor at the Turkey Point site with the risks for 

current-generation reactors at various sites. The comments do not provide information other 

than what the review team has already considered in the EIS. Accordingly, no changes were 

made to the EIS as a result of these comments. 

Comment: Turkey Point is adjacent to fragile natural resources and a "stone's throw" from the 

densely populated areas of Miami-Dade County. Any "major" incident would destroy our 

ecosystem and wreck havoc on the lives of more than two million people. (0057-4 [Neway, 

Roberta])

Comment: This area is highly populated. Any problem that arises would affect hundreds of 

thousands of people, not to mention multiple millions of dollars in property. It is clear from Three 

Appendix E October 2016 E-363 NUREG–2176
Mile Island, and other "accidents" around the world, that nuclear plants and city and towns 

should not be mixed. (0061-2 [Lague, Victoria])

Comment: Contrary to the assertion of the NRC (EIS) that the "socioeconomic" effects of 

building and operating the proposed reactors #6 and #7, are "small and beneficial" I believe the 

actual risk to the population of South Florida is astronomical and potentially devastating. History 

has shown that unanticipated "incidents" can occur at Nuclear Power generating facilities. 

History has also shown that the results of such an incident can be catastrophic and long lasting.

(0067-2 [Commenters, Multiple])

Comment: Locating a Nuclear Power Generating Facility in close proximity to a densely 

populated metropolitan area of more than 2,500,000 people, is an ill conceived notion at best. 

Although this decision may be a means to enrich the shareholders of FP&L, it places the entire 

population of South Florida in extreme jeopardy. (0067-3 [Commenters, Multiple])

Comment: The expansion is a direct threat to our drinking water. An accident, a la Chernobyl 

or Fukushima would destroy one of the most beautiful places in America. (0097-3 [Geary, Craig 

W.])

Comment: Contrary to the assertion of the NRC (EIS) that the "socioeconomic' effects of 

building and operating the proposed reactors# 6 and# 7, are "small and beneficial" I believe the 

actual risk to the population of South Florida can be devastating. History has shown that 

unanticipated "incidents" can occur at Nuclear Power generating facilities. History has also 

shown that the results of such an incident can be catastrophic and long-lasting. (0206-2 [White, 

Holly])

Comment: There is no question if an accident will happen but when, maybe not in our lifetime 

but it WILL happen and the consequences for the earth and people leaving near there will be 

devastating! (0222-1 [Glass, Rachel])

Comment: Obviously you have not considered the possible danger to the residents of South 

Florida. (0331-2 [Anonymous, Anonymous])

Comment: We live in the the historic and beautiful Coconut Grove section of Miami, a short 

distance due north of Turkey Point. A southerly breeze would bring the tragic effects of a 

nuclear disaster at Turkey Point straight to our homes and our lives in Coconut Grove, adding 

our community to the names Fukushima, Three Mile Island, and Chernobyl. (0338-1 [Kavanaugh, 

Daniel])

Comment: There are real safety concerns with this proposal for more reactors to be built so 

close to a huge metropolitan area. (0340-8 [Tweeton, Tanya])

Comment: Please make sure any expansion of Turkey Point's reactors is accomplished in a 

manner that will assure that there is Zero possibility of any harm coming to South Florida's 

people or environment as a result of any expansion of the facilities. (0554-1 [Denninger, Frank])

Comment: The cost of a nuclear meltdown is astronomical. One TRILLION dollars and 

counting for Fukushima and Chernobyl. (0603-7 [Anonymous, Anonymous])

Comment: Operators of PWR reactors like the AP1000 often store the full core inventory in the 

spent fuel pool during maintenance operations, alongside the older fuel kept in long-term 

storage there. The larger the number of rods in the fuel pool at one time, the greater the risk of 

Appendix E NUREG–2176 E-364 October 2016
criticality accidents, meltdown, hydrogen explosion, and the release of fission products. An 

extended station blackout, terrorist attack, or aircraft accident taking place when the fuel pool 

was full or nearly full presents a risk to human health and the environment of unprecedented 

proportions. Fission releases from fuel pool meltdowns at Fukushima were one of the principal 

sources of land and water contamination and human exposure to radiation. Spent fuel pools at 

Japanese reactors typically have far fewer fuel rods than their US counterparts owing to that 

country's use of spent fuel reprocessing. In the four years since the events at Fukushima, the 

NRC has allowed the start of construction of AP1000 plants in Georgia and South Carolina with 

spent fuel pools that are no different from pre-Fukushima designs. Those plants are situated at 

inland, rural locations. Turkey Point is located on the Atlantic Ocean near a major metropolitan 

area. A fuel pool accident or hydrogen explosion at Turkey Point 6 or 7 presents an unjustifiable 

risk to the large human population, Florida Everglades National Park, and to the marine 

environment along the coast including Biscayne Bay National Park. Fuel pool meltdowns were 

and continue to be the cause of the largest releases of radioactivity from Fukushima, where the 

surrounding land has become uninhabitable and the plant continues to pour dangerously 

radioactive water into the sea every day as the utility company attempts to prevent further 

criticalities. A catastrophic release of radiation into the waters around Turkey Point would have 

devastating consequences for tourism and shipping industries as the plant sits alongside one of 

the most heavily trafficked waterways of the United States and just south of important sea ports 

at Miami and Fort Lauderdale. (0615-2-17 [Bethune, David])

Comment: Allowing a total of four nuclear reactors to Turkey Point would mean paradoxically 

siting of one of the country's largest nuclear reactor installations alongside an urban population 

of 4 million people. Siting at this location presents an extreme hazard to public health and safety 

in the event of an evacuation due to catastrophic environmental release of radiation. South 

Florida is laid out along the coast of the Atlantic Ocean and lacks evacuation routes to the west.

(0615-3-8 [Bethune, David])

Comment: And, of course, there's always accident scenarios. We don't even want to talk about 

an accident. We've seen them. I lived through --I'm old enough to have been through Three Mile 

Island and we - our jaws are still dropped open from Fukushima. I know it's not the same kind of 

power plant, but accidents can happen. So all bets are off. All those estimates about 

environmental impacts changes dramatically, in the event of a release in an accident scenario.

(0721-11-9 [Roff, Rhonda])

Comment: First, the population data right now is inaccurate. The models are not looking at this 

project effecting as many as 4 million people, all the way up to Fort Lauderdale, and they're not 

even taking into account the 2 million in Miami-Dade County. Right now the models are really 

looking at about 150,000 people that could be affected if there is a problem with the plant.

(0721-5-1 [Mendez, Victoria])

Response: As discussed in Section 5.11 of the EIS, the severe accident risks listed in Table 5-

18 include the population dose risk values. Specifically, the risk values include the risk to 

human health in terms of calculated cumulative doses to the general public residing within 50 mi 

of the site and estimated early fatalities and latent cancer fatalities in the exposed population; 

total economic costs from evacuation, rehabilitation, and land interdiction, condemnation and 

decontamination; estimated areas of surrounding farm lands requiring decontamination; and 

from water ingestion. The staff review applied the latest available census data of 2010, and 

accounted for the increasing population trend, and the property values for independently 

assessing the applicant's results as presented in the EIS. Thus, the staff considered the most 

recent information in evaluating severe accident risk for the proposed new reactors. 

Appendix E October 2016 E-365 NUREG–2176
As discussed in Section 5.11.2 of the EIS, the environmental risks from various classes of 

severe accidents for the Turkey Point site were considered for the purpose of severe accident 

analysis Site-specific information appears in Table 5-18 as population dose risk (personrem/Ryr), offsite economic costs ($/Ryr), and population dose risk from water ingestion (personrem/Ryr). The AP1000 design has several passive safety features to reduce the risk from 

severe accidents. For example, as described in the AP1000 DCD Appendix 19B, one of the key 

AP1000 severe accident design features is the capability to retain the core debris within the 

reactor vessel for a large number of severe accident sequences by flooding the reactor cavity 

and submerging the outer surface of the reactor vessel. The heat removal capability of the 

water on the external surface of the reactor vessel prevents the reactor vessel wall from 

reaching temperatures at which failure of the reactor vessel could occur. This has been termed 

in-vessel retention (IVR). The primary benefit of in-vessel retention of the core is that ex-vessel 

severe accident phenomena associated with relocation of core debris to the containment, which 

can be a dominant containment failure mechanism, are physically prevented. Thus, retention of 

the core within the reactor vessel results in a significant reduction in the potential for large 

fission product releases to the environment for core damage accidents. 

In accordance with the Commission policy statement on severe reactor accidents (50 FR 

32138) (TN4519), the severe accident risks of the proposed new reactors are presented in 

Table 5-18 of Section 5.11.2 of this EIS in terms of risk values per reactor-year, which are the 

product of the probability of a severe accident and its consequences. The NRC considers these 

risk values to represent the most meaningful way to place the risk in context and inform the 

environmental assessment process. 

The NRC carries out its mission to protect public health and safety by specifying licensing and 

operational requirements that nuclear power plants must meet and by inspecting and enforcing 

compliance with these requirements. The NRC staff does not claim that the risk from a severe 

accident is zero or that a severe accident “cannot happen here,” or that there would not be 

impacts to tourism or other economic activities. Rather, the NRC staff estimates the risk from a 

severe accident as described above and uses the estimates in the environmental analysis. The 

risk values include selected measures that are used for comparative analyses of societal risks 

and benefits. Specifically, the population dose and economic costs are used for assessing 

viable severe accident mitigation alternatives, or design alternatives, as explained in Section 

5.11.3 of the EIS. The average individual fatality risk for the Turkey Point site, as shown in 

Table 5-19 and discussed in Section 5.11.2.1, are well below the Commission’s safety goals (51 

FR 30028) (TN594). The comments provided no information in addition to that considered in 

the draft EIS analysis, and no changes were made to the EIS as a result of these comments. 

Comment: There are a few instances in the DEIS text where the DEIS either states that 

Revision 6 of Florida Power & Light's (FPL) Environmental Report (ER) (FPL 2014-TN4058) 

incorporated Revision 19 of the Westinghouse AP1000 Design Control Document (DCD) or that 

the FPL application refers to Revision 17 of the AP1000 reactor certified design. Revision 19 of 

the AP1000 DCD was incorporated as early as Revision 3 of the Units 6 & 7 COLA, DEIS 

reference (FPL 2011-TN127). Instances in the DEIS include:...DEIS Section 5.11, Page 5-131, 

Lines 10-11. (0619-1-4 [Maher, William])

Response: The text in Section 5.11 was revised to reflect FPL's application and Appendix D of 

10 CFR Part 52 reference Revision 19 of the AP1000 Design Control Document. 

Comment: NRC's Draft EIS is Flawed Because it Fails to Adequately Address the 

Impacts of Severe Accidents From Multiple Units and or Spent Fuel Pools. According to 

Appendix E NUREG–2176 E-366 October 2016
the NRC's DEIS: The NRC staff evaluated the environmental impacts from DBAs and severe 

accidents for an AP1000 at the Turkey Point site. Based on the information provided by FPL 

and NRC's own independent review, the NRC staff concludes that the potential environmental 

impacts (risks) from a postulated accident from the operation of the proposed Turkey Point Units 

6 and 7 would be SMALL, and no further mitigation would be warranted. (See Appendix D, p. D3. http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2176/) NEPA provides for a 

detailed statement of, "the environmental impact of the proposed action, (and) any adverse 

environmental effects which cannot be avoided should the proposal be implemented." 42 

U.S.C. § 4332(2)(C). However, the NRC characterizes impacts as "Small," "Moderate," or 

"Large." NRC's characterization of the postulated impacts as "small" is not supported by facts 

and instead relies upon claims of low probability of severe accidents. However as former 

Chairman MacFarlane acknowledged in one of her votes after Fukushima: While postulated 

frequencies of accidents at nuclear power facilities inte h U.S. are often expressed anywhere 

from one in 1,000 years to one in 1,000,000 years, it's important to recognize that the world has 

seen three severe accidents at nuclear facilities in the last 33 years -or essentiallyone every ten 

years, on average. Even though the circumstances, regulatory requirements, and plant designs 

differed from one accident to the next, these distinctions do not reassure most members of the 

public. To the contrary, this recurrence rate feeds much of the concern the public expresses 

about the safety of nuclear power. (U.S. Nuclear Regulatory Commission, Commission Voting 

Record, SECY-12-0157, Consideration of Additional Requirements for Containment Venting 

Systems for Boiling Water Reactors with Mark I and Mark II Containments, March 19, 2003, p. 

3, http://www.nrc.gov/reading-rm/doc-collections/commission/cvr/2012/2012-0157vtr.pdf) Not 

only does NRC characterization of accidents as "small" violate NEPA but also the DC Circuits 

decision in New York v NRC, which found that, "(o)nly if the harm in question is so 'remote and 

speculative' as to reduce the effective probability to zero may the agency dispense with the 

consequences portion of the (NEPA) analysis." (New York v NRC, 68 F.3d 471, 482. (DC Cir. 

2012) Given the commercial nuclear industry's track record of a meltdown per decade and the 

2011 triple melt down of General Electric designed reactors in Japan, a severe nuclear accident 

at a U.S. nuclear plant involving multiple units is anything but speculative. (0716-10 [Riccio, Jim])

Response: The staff recognizes and appreciates the concern the public has about the safety of 

nuclear power. In recognition of this concern, the staff assesses the environmental impacts 

from postulated accidents in Section 5.11 of the EIS in accordance with Commission policy 

statements, the regulations of 10 CFR Part 51, and the guidance in Sections 7.2 and 7.3 of 

NUREG-1555. Nonetheless, the NRC disagrees with the comment that the draft EIS is flawed 

concerning the risks from severe accidents and that the NRC violates NEPA by assigning an 

environmental impact finding of “SMALL” to severe accidents. 

As for the comment’s citation to the decision in New York v NRC, 681 F.3d 471, 

482. (D.C. Cir. 2012), the Court of Appeals for the District of Columbia Circuit decision there 

invalidated an NRC rule. In that case, the NRC had not prepared an environmental impact 

statement, and the D.C. Circuit held that the challenged rule was not supported by an 

environmental assessment finding of no significant impact. The rule challenged in the New York 

v. NRC case differs from the application for COLs for Turkey Point Units 6 and 7 under 

consideration here because the NRC has prepared an EIS in connection with requested COLs, 

and the NRC staff has considered the plant-specific facts, including those raised in the 

comment.” 

Specifically, the NRC staff did consider severe accidents affecting more than one unit. As the 

EIS states in Section 5.11.2.4, “[t]he consequences of a severe accident would be the same 

regardless of whether one or two reactors were built at the site. If two reactors were built, the 

Appendix E October 2016 E-367 NUREG–2176
risks would apply to each reactor, and the total risk for the site would be approximately double 

the risk for a single reactor.” In the evaluation of severe accidents presented in Section 5.11.2 of 

the EIS, the staff has shown that the combination of probability and harm is sufficiently minimal 

in terms of the expected risks of a severe accident for the AP1000 reactor design to reach an 

environmental finding of SMALL. 

Specifically regarding the Fukushima accident, the staff discusses in Section 5.11 the actions 

that have been taken during the safety review to address this concern and addresses the design 

features of the AP1000 that are specifically designed to counter the type of severe accidents 

that could affect multiple reactor units. Therefore, the staff concludes in Section 5.11 of the EIS 

that “none of the information the staff has identified about the Fukushima accident or the steps 

taken by the NRC to date to implement the task force recommendations suggests that the 

seismic and flooding hazards or the available mitigation capability assumed in the Turkey Point 

Units 6 and 7 EIS analysis of severe accidents would be affected. For these reasons, the 

NRC’s analysis of the environmental impacts of design-basis and severe accidents presented 

herein remains valid.” Additional information concerning the actions taken by the applicant to 

address actions for the mitigation of beyond-design-basis external events are presented in 

Chapter 20 of the ASE, Requirements from Fukushima Task Force Recommendations (NRC 

2016-TN4806). For example, ASE Chapter 20 notes how passive cooling of the spent fuel is 

achieved using the water inventory of the SFP and safety-related makeup, and does not rely on 

active components or ac power (NRC 2016-TN4806). 

The staff provided further clarification on the consideration of external events in Section 5.11.2.4 

of the EIS in response to this comment. 

E.2.18 Comments Concerning the Uranium Fuel Cycle 

Comment: Finally, the high-level nuclear waste generated by Turkey Point Nuclear Units 6 &7 

will end up and harm the environment for tens of thousands of years to come! (0010-9 [Saporito, 

Thomas])

Comment: None of the chronic problems of nuclear power have been permanently solved. 

High-level nuclear waste continues to accumulate at reactor sites all across the U.S. We should 

not be building more reactors that create this deadly stuff, until we have a permanent repository 

for nuclear waste. (0037-1 [Schoene, William])

Comment: Complicating all of this is that with no solution in sight for the long-term 

management of highly radioactive nuclear waste, there is no reason to support the licensing of 

these proposed reactors. (0104-5 [Commenters, Multiple])

Comment: We are totally opposed to the expansion of nuclear generated energy at Turkey 

Point -- for the following reasons.....3) No long term solution for waste disposal (0129-3 [Mayer, 

Doug])

Comment: Complicating all of this is that with no solution in sight for the long-term 

management of highly radioactive nuclear waste (0141-4 [Lucas, Carmen])

Comment: We are still dealing with disposal issues. This waste lasts for centuries. Where will it 

be stored? (0146-3 [Grant, Randy])

Appendix E NUREG–2176 E-368 October 2016
Comment: Thousands of pounds of spent fuel rods (nuclear waste) have already piled up on 

the shores of Biscayne Bay. There is no long term safe storage on the horizon. (0158-1 [Carlson, 

John])

Comment: WE STILL DO NOT HAVE CONSENSUS ON THE DISPOSAL OF WASTE. IT IS 

WRONG OF US TO LEAVE THIS PROBLEM TO OUR DESCENDANTS TO LIVE OR DEAL 

WITH. (0164-3 [Chrissos, H. L. Chris])

Comment: Complicating all of this is that with no solution in sight for the long-term 

management of highly radioactive nuclear waste, there is no reason to support the licensing of 

these proposed reactors. (0192-6 [Lebatard, David])

Comment: AND, HOW TO SAFELY STORE SPENT FUEL??? (0201-3 [Reid, Sarah])

Comment: Spent fuel storage [is unacceptable]. (0245-4 [Lindsey, Jerrie])

Comment: One item that was heatedly argued by the commissioners present was the "safe" 

disposal of "spent" nuclear fuel rods which, some commissioners insisted could be converted 

into "glass logs" and thus neutralized. Depleted uranium doesn't deplete very much. Plutonium239 only lasts 24,100 years. And Plutonium 244 only lasts 80 million years. (0264-2 [Dwyer, John 

P.])

Comment: US spent-fuel storage sites are packed with no place to go. This is 

EXTRAORDINARILY RISKY AND DANGEROUS. Taxpayers are paying for storage for some 

utilities that have run out of storage space, and some have even sued the federal government 

for breach of contrac, because it failed to keep the 1998 deadline to establish long-term storage.

(0273-1 [Stewart, Berkeley])

Comment: And then there is the problem of nuclear waste disposal. We dont have a good long 

term solution for it and as we speak, it is being stored on site, too close for comfort! (0340-5

[Tweeton, Tanya])

Comment: Another environmental issue that has not even been addressed by FPL or any 

government agencies is the huge accumulation of nuclear waste, with no place to dispose of it. 

The plan was to send it to Yucca Mountain, and now it has been determined that there are 

environmental problems with disposal at Yucca. What will be the environmental impact of 

keeping nuclear waste with no place for an environmentally safe place for disposal? (0365-8

[Fischer, Antoinette])

Comment: The U.S. still has not settled upon a place to store radioactive waste materials. The 

Yucca Mountain reserve has proven to have to many problems for storage of dangerous 

materials for 50,000+ years. (0382-1 [Mikowski, George])

Comment: If you cannot create a SAFE way to dispose, reverse, or eliminate nuclear waste in 

that the piles/deposits, etc. do not last thousands of years, THEN DON'T BUILD ANY MORE 

NUCLEAR PLANTS!!!!! DO YOU UNDERSTAND THIS BASIC FACT????? (0406-1 [Ledbetter, 

Carolyn])

Comment: Furthermore, we have never devised a way to deal with nuclear waste, and at this 

point it seems unlikely we ever will. The kitty litter disaster at the WIPP is just one example of 

the insanity that plagues the nuclear waste industry. Here in California we're storing vast 

quantities of nuclear waste from the San Onofre plant (which had to be decommissioned 

Appendix E October 2016 E-369 NUREG–2176
because the owners tried to skirt regulations and made "upgrades" which effectively destroyed 

it) right on active earthquake faults. What could possibly go wrong? (0431-1 [Hicklin, Mary])

Comment: Where do you plan to store the nuclear waste? SDD (0434-1 [Dahlgren, Shelley])

Comment: AND, where goes the waste, in whose backyard? (0448-1 [Rush, Charlene])

Comment: And nobody has answers to the final question: What to do with spent fuel? Is this 

left for our children to take care of? (0467-1 [Veijalainen, Pertti])

Comment: No one knows what to do with nuclear waste. It will be there forever. (0469-1 [Weber, 

Zorina])

Comment: 2) after 30 years, the waste still has nowhere to go. Before expansions can be 

considered, the mounting spent nuclear waste problem has to be addressed. Suggest giving 

NASA a new mission - get the Nuc waste off the planet - shoot it into the sun or whatever.

(0502-2 [Brumleve, Charles])

Comment: To collect additional Nuclear waste material at that site, without a method of 

disposal, is irresponsible. (0509-1 [Otto, Peter])

Comment: The waste created by these plants are a hazard to the planet and all like on it.

(0529-2 [Brandariz, Anita])

Comment: Uranium 238 is permanent since and has a half-life of 4.5 billion years, making 

contaminated areas uninhabitable for eternity. And where are you guys going to bury the 

nuclear waste? You have already run out of places to bury it. (0561-2 [G., Ambriel])

Comment: Nuclear power has lethal by products, nuclear waste, that will be around for 

hundreds of years. Has FPL developed a viable plan to deal with this waste? I doubt it. I think 

they are being irresponsible and not protecting the public welfare if there is no workable plan to 

safely dispose of these highly toxic wastes. (0579-3 [Schwab, Roy])

Comment: The proposed additional, new nuclear reactors at FPL's Turkey Point would 

produce even more radioactive waste that would not decay for the next 250,000 years or more. 

Solar and wind power do not produce any radioactive pollution. (0592-10 [Brexel, Sr., Charles])

Comment: NO ONE has figured out how to make radioactive waste safe. (0627-2 [Dolben, 

Hollis])

Comment: Nuclear power will ultimately destroy humanity-just think of the waste problem.

(0632-2 [Moll, Wolfgang])

Comment: And what about nuclear waster? No one has any idea what to do with the growing 

mountains of nuclear waster. (0643-5 [Joannou, Jr., Benjamin])

Comment: Where are they going to store the waste?WIPP, in the open air, by the great lakes, 

in the ocean, on mars? (0644-4 [Anonymous, Anonymous])

Comment: Our technology surpasses our ability to control, maintain, service, and dispose of 

wastes from nuclear plants, but we proceed, just as we continue to bum fossil fuels. (0657-3

[Hartmann, Donald])

Appendix E NUREG–2176 E-370 October 2016
Comment: One item that was heatedly argued by the commissioners present was the safe 

disposal of spent nuclear fuel rods which, some commissioners insisted could be converted into 

glass logs and thus neutralized. Depleted uranium doesn't deplete very much. Plutonium-239 

lasts 24,100 years. And Plutonium 244 lasts 80 million years. (0673-2 [Dwyer, John P.])

Comment: But probably the number one thing that stuck out at me was the United States' 

approach to storing this hazmat and the nuclear waste, not only from power plants but from 

military. They come up with the Yucca Flats idea, initially it sounded great. Let's put all this stuff 

in one spot, put it underground, we can seal it off forever. And really, that's what we need as far 

as the long-term storage of these products is forever because some of the harmful effects can 

affect humans for 300,000 years, so that's basically forever. The country needs to come up with 

a national storage facility and get rid of all these onsite storage locations. It's just too hazardous 

having this stuff parked all over the country. Let's get it in one spot and not have any more 

nuclear plants put online until we have that policy in effect. And I think that this needs to be 

done, it needs to be a national priority and we all need to be letting our elected representatives 

know that we need a national plan for dealing with this waste. Until then there is no such thing 

as safe nuclear power. (0721-24-1 [Eastman, John])

Comment: Will there be anyone here to oversee storage of these substances, keeping them 

from leaching into the environment? (0721-32-8 [Schlackman, Mara])

Comment: So to get down to the point, Monroe County has a safety plan in case of a spill, and 

spill could see -- okay, they say our core of reactors may produce 10,000 Roetgens. You're 

loading up the Westinghouse, the rods to say three and a half percent uranium. When you get 

finished with them you bring down about one and a half percent uranium, it's called spent rods. 

Unfortunately we do not have a good repository in the United States to store them so they're 

stored onsite. (0722-15-1 [McColgan, Robert])

Response: These comments are concerned with Continued Storage and long term disposal of 

high-level waste. While a repository for final disposal of spent nuclear fuel has yet to be 

constructed, the Commission has, through rulemaking, considered the environmental impacts of 

spent fuel disposal in light of the current national policy regarding spent fuel. Specifically, on 

August 26, 2014, the Commission issued a revised rule at 10 CFR 51.23 and an associated 

Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel 

(NUREG-2157). Continued Storage is defined as the storage of spent fuel after the end of the 

licensed life for operations of a nuclear reactor and before final disposal in a permanent 

repository. The revised rule adopts the generic impact determinations made in NUREG-2157 

and codifies the NRC's generic determinations regarding the environmental impacts of 

continued storage of spent nuclear fuel beyond a reactor's operating license. As directed by 10 

CFR 51.23(b), the impacts assessed in NUREG-2157 are deemed incorporated into this EIS in 

Section 6.1.6. Section 6.1.6 also explains that current national policy mandates that high-level 

and transuranic wastes are to be buried at deep geologic repositories and that no release to the 

environment is expected to be associated with deep geologic disposal. The comments provided 

no information in addition to that considered in the draft EIS analysis and NUREG2157. Accordingly, no change was made to the EIS as a result of these comments. 

Comment: More operating nuclear reactors at Turkey Point will produce more long-lived, highly 

radioactive nuclear waste in the form of spent nuclear fuel for which no safe storage and longterm management yet exists. Coupled with the high vulnerability of this area to sea level rise 

and severe storm surges from extreme weather events, which will increase from the effects of 

global climate change, the DEIS is deficient in assessing the impacts to the environment and 

Appendix E October 2016 E-371 NUREG–2176
public health and safety of indefinite on-site, long-term, potentially permanent, storage of this 

nuclear waste. Having such a large amount of radioactivity clustered in a population-dense, 

hurricane-prone area could create significant safety and health concerns for Floridians. The 

NRC must address these cumulative impacts. (0112-8 [Barczak, Sara])

Comment: With the two new reactors having a much larger power capacity than the existing 

ones, increasing amounts of spent nuclear fuel containing uranium-235, plutonium, and other 

dangerous radioactive materials will be accumulating in a flood and hurricane prone location for 

many years to come. (0158-2 [Carlson, John])

Comment: Expanding a nuclear power plant in an area that is ground zero for sea level rise 

threatens our communities and the environment, especially if large amounts of spent nuclear 

fuel are stored on---site. (0210-6 [Sharp, Andrea Heuson])

Comment: In addition to the highly dangerous nuclear fuel in the reactor cores - thousands of 

pounds of spent fuel rods (nuclear waste) have already piled up on the shores of Biscayne Bay. 

There is no long term safe storage on the horizon. With the two new reactors having a much 

larger power capacity than the existing ones, increasing amounts of spent nuclear fuel 

containing uranium-235, plutonium, and other dangerous radioactive materials will be 

accumulating in a flood and hurricane prone location for many years to come. (0240-7

[Commenters, Multiple])

Comment: There are already thousands of pounds of spent nuclear fuel rods accumulating 

onsite at Turkey Point, and that accumulation will be compounded by the addition of two reactor 

units. Given the half-lives of Uranium 235 and plutonium, this waste will remain radioactive for 

thousands of years, and yet it is accumulating in a location vulnerable to sea level rise and 

storm surges, whose impacts FPL has underestimated. The spent fuel rods greatly multiply the 

risks from adding two reactors at this location, to the human population and even more so the 

wildlife in the nearby national parks. (0246-4 [Shlackman, Mara])

Comment: Expanding a nuclear power plant in an area that is ground zero for sea level rise 

threatens our communities and the environment, especially if large amounts of spent nuclear 

fuel are stored on-site. (0253-5 [Bloom, Justin] [Campbell, Cara] [Causey, Charlie] [Cavros, George] 

[Chenoweth, Mike] [Daly, Meg] [England, Margaret] [Fuller, Manley] [Jones, George L.] [Keller, Alan] 

[Martin, Drew] [McLaughlin, Caroline] [Reynolds, Laura] [Silverstein, Rachel] [White, Paton] [Williams, 

Elinor])

Comment: Expanding a nuclear power plant in an area that is ground zero for sea level rise 

poses a multitude of threats to our communities, especially if large amounts of spent nuclear 

fuel are stored on-site. (0254-4 [Dudley, Dwight] [Lerner, Cindy] [Regalado, Tomas] [Stoddard, Philip 

K.])

Comment: The half-life of the main fuel, U-235, is 703.8 million years. Plutonium is also 

routinely created in the process of running a nuclear plant. It is highly toxic and its various 

isotopes have half-lives ranging from about 25,000 to 80 million years. These extremely 

dangerous substances will require secure storage and protection for a very long period of time 

in an area likely to be hard hit by increasing sea-level rise, storm surges and hurricanes.

(0356-14 [Shlackman, Jed])

Comment: The half-life of the main fuel, U-235, is 703.8 million years! Taking a CHANCE on 

the natural resources we HAVE REMAINING NOW is not a game. Plutonium often created in 

the process is highly toxic and its various isotopes have half-lives ranging from about 25,000 to 

Appendix E NUREG–2176 E-372 October 2016
80 million years! Our wildlife and the eco-SYSTEMS that interacts dynamically have delicate 

balances, just like the human body. Securing storage and protection of dangerous substances I 

for a very long period of time in an area likely to be hard hit by increasing sea-level rise, storm 

surges and hurricanes does not seem logical. Once a resource is gone, it's not coming back! 

Risking throwing anything off in the slightest way can have effects that scientists haven't studied 

and I would like our next generation to be able to enjoy nature, just as I have today. (0362-4

[Hurley, Paula])

Comment: The half-life of the main fuel, U-235, is 703.8 million years. Plutonium is also 

routinely created in the process of running a nuclear plant. It is highly toxic and its various 

isotopes have half-lives ranging from about 25,000 to 80 million years. These extremely 

dangerous substances will require secure storage and protection for a very long period of time 

and we do not have an agreed upon place to store or agreed way to transport nuclear waste. 

This is especially a problem for these two nuclear plants because they are in an area likely to be 

hard hit by increasing sea-level rise, storm surges and hurricanes. (0366-11 [Griffith, Ed and 

Harriet])

Comment: The half-life of the main fuel, U-235, is 703.8 million years. Plutonium is also 

routinely created in the process of running a nuclear plant. It is highly toxic and its various 

isotopes have half-lives ranging from about 25,000 to 80 million years. These extremely 

dangerous substances will require secure storage and protection for a very long period of time 

in an area likely to be hard hit by increasing sea-level rise, storm surges and hurricanes.

(0370-13 [Vayu, Satya])

Comment: In addition to the highly dangerous nuclear fuel in the reactor cores -thousands of 

pounds of spent fuel rods (nuclear waste) have already piled up on the shores of Biscayne Bay. 

There is no long term safe storage on the horizon. With the two new reactors having a much 

larger power capacity than the existing ones, increasing amounts of spent nuclear fuel 

containing uranium-235, plutonium, and other dangerous radioactive materials will be 

accumulating in a flood and hurricane prone location for many years to come. (0551-2

[Anonymous, Anonymous])

Comment: No New Nukes until you figure out how to dispose of the waste. Letting it pile up for 

decades in a hurricane potential area is not what the public wants. (0621-1 [Datz, Amy])

Comment: With the two new reactors having a much larger power capacity than the existing 

ones, increasing amounts of spent nuclear fuel containing uranium-235, plutonium, and other 

dangerous radioactive materials will be accumulating in a flood and hurricane prone location for 

many years to come. (0625-2 [Felinski, Julee])

Comment: In addition to the highly dangerous nuclear fuel in the reactor cores, Im also deeply 

concerned about the thousands of pounds of spent radioactive fuel rods being stored on the 

shores of Biscayne Bay. There is no long term safe storage on the horizon. Two new reactors 

mean that increasing amounts of spent nuclear fuel rods containing uranium-235, plutonium, 

and other dangerous radioactive materials will be accumulating in a known hurricane lane as 

well as a flood zone for decades to come. The tragedy of Fukushima should have been the last 

word on building nuclear plants in vulnerable coastal locations like this one. (0674-5 [Dwyer, 

Karen])

Comment: The half-life of the main fuel, U-235, is 703.8 million years. Plutonium is also 

routinely created in the process of running a nuclear plant. It is highly toxic and its various 

isotopes have half-lives ranging from about 25,000 to 80 million years. These extremely 

Appendix E October 2016 E-373 NUREG–2176
dangerous substances will require secure storage and protection for a very long period of time 

in an area likely to be hard hit by increasing sea-level rise, storm surges and hurricanes.

(0676-10 [Kassel, Kerul])

Comment: I'd like to conclude with some thoughts regarding the highly toxic radioactive 

substances involved in nuclear plant operations. The main fuel is Uranium 235 with a half-life of 

700 million years. Plutonium which is created in the process of running a nuclear plant has 

isotopes with half-lives of 25,000 years to 80 million years. These half-lives have to be looked at 

in conjunction with the depopulation of South Florida as sea level rise occurs. (0721-32-7

[Schlackman, Mara])

Response: These comments are concerned with Continued Storage, long-term disposal of 

spent fuel, and how climate change may affect spent fuel storage at the Turkey Point 

site. While a repository for final disposal of spent nuclear fuel has yet to be constructed, the 

Commission has, through rulemaking, considered the environmental impacts of spent fuel 

disposal in light of the current national policy regarding spent fuel. Specifically, on August 26, 

2014, the Commission issued a revised rule at 10 CFR 51.23 and an associated Generic 

Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NUREG2157). Continued Storage is defined as the storage of spent fuel after the end of the licensed 

life for operations of a nuclear reactor and before final disposal in a permanent repository. The 

revised rule adopts the generic impact determinations made in NUREG-2157 and codifies the 

NRC's generic determinations regarding the environmental impacts of continued storage of 

spent nuclear fuel beyond a reactor's operating license. As directed by 10 CFR 51.23(b), the 

impacts assessed in NUREG-2157 are deemed incorporated into this EIS in Section 

6.1.6. Section 6.1.6 also explains that current national policy mandates that high-level and 

transuranic wastes are to be buried at deep geologic repositories and that no release to the 

environment is expected to be associated with deep geologic disposal. In particular, NUREG2157, Section 4.17 and Appendix E, describes the effect of long-lived isotopes including those 

mentioned in the comments. 

Climate change, including future sea-level rise, is addressed in Chapter 2, Chapter 7, and 

Appendix I of the EIS. NRC-licensed spent fuel storage facilities are evaluated to ensure that 

the performance of their safety systems, structures, and components is maintained during 

flooding events, and they are monitored when in use. The NRC safety oversight process 

includes collection and analysis of information regarding changes in the severity or frequency of 

natural hazards, such as flooding from storm surge and sea level rise, as discussed in SECY15-0137 (TN4731). When warranted, the NRC can request licensee study and analysis of 

changing natural hazards, and can impose additional design or operation requirements to 

address those changing hazards. The comments provided no information in addition to that 

considered in the draft EIS analysis and NUREG-2157. Accordingly, no change was made to 

the EIS as a result of these comments. 

Comment: DEIS Section 6.1, Page 6-2, Table 6-1: In DEIS Table 6-1, "Table S-3 from 10 CFR 

51.51(b), Table of Uranium Fuel-Cycle Environmental Data", portions of Table S-3 have been 

omitted. The complete table is found in Table S-3 of 10 CFR 51.51 and ER Table 5.7-1. The 

omissions in Table 6-1 occur under the subheading "Effluents - Chemical (MT)" following the 

entry for "Particulates" at the bottom of page 6-2. Following "Particulates", there are 

omissions for "Other Gases," F and HCl, and the associated notes regarding those 

emissions. The "Other Gases" entries should be followed by the subheading "Liquids" and 

entries for SO4-, NO3-, and Fluoride. Notes from Table S-3 in 10 CFR 51.51(b) documenting 

various assumptions about how the reference reactor values were derived and regarding the 

Appendix E NUREG–2176 E-374 October 2016
likely dilution requirements for liquid chemical constituents have also been omitted. (emphasis 

added) (0619-5-1 [Maher, William])

Response: The missing information from Table S-3 from 10 CFR 51.51(b) has been restored 

to Table 6-1. 

Comment: The nuclear fuel cycle utilizes large quantities of fossil fuel at all of its stages--the 

mining and milling of uranium, the construction of the nuclear reactor and cooling towers, robotic 

decommissioning of the intensely radioactive reactor at the end of its 20 to 40-year operating 

lifetime, and transportation and long-term storage of massive quantities of radioactive waste, all 

are risking our environment and our lives. (0264-7 [Dwyer, John P.])

Comment: Nuclear power is touted as a greenhouse solution, but the ancillary inputs to the 

nuclear fuel cycle such as mining, milling, reactor vessel construction, dealing with the waste 

that remains radioactive for millions of years, etc. negates any greenhouse mitigation. (0371-3

[Haffmans, Edmund])

Comment: They are also not carbon free. It takes many carbon producing steps to prepare the 

fuel. (0645-2 [Anonymous, Anonymous])

Comment: The nuclear fuel cycle utilizes large quantities of fossil fuel at all of its stages--the 

mining and milling of uranium, the construction of the nuclear reactor and cooling towers, robotic 

decommissioning of the intensely radioactive reactor at the end of its 20 to 40-year operating 

lifetime, and transportation and long-term storage of massive quantities of radioactive waste, all 

are risking our environment and our lives. (0673-7 [Dwyer, John P.])

Response: These comments relate to fossil fuel use and the carbon footprint of the uranium 

fuel-cycle activities. The NRC staff evaluated the carbon footprint impacts from the life-cycle of 

uranium fuel production, construction, operation, and decommissioning of the Turkey Point 

Nuclear Plant Units 6 and 7. These impacts are discussed in Chapters 4, 5, 6, and 7 of the 

EIS. The generic impacts of the uranium fuel cycle are codified in 10 CFR 51.51(b), Table S-3, 

Table of Uranium Fuel Cycle Environmental Data. In accordance with 10 CFR 51.51, the staff 

relied on Table S-3 as a basis for the impacts of uranium fuel-cycle impacts (including fossil fuel 

emissions). The staff used the coal and natural gas values in Table S-3 to estimate the 

greenhouse gas emissions from the fuel cycle. The review team compared the carbon dioxide 

(CO2) footprints of nuclear power and reasonable baseload energy alternatives, and this 

evaluation is presented in EIS Section 9.2.5. Appendix J of the EIS presents a detailed 

breakout of the CO2 footprint of a nuclear power plant. The comments provided no information 

in addition to that considered in the draft EIS analysis and Table S-3. Accordingly, no changes 

were made to the EIS as a result of these comments. 

Comment: I hope the you & your colleagues are un-biased & have enough integrity & complete 

enough with your science to come to the stronger conclusions against FPL wanting 6 & 7 

Nuclear Reactors, because you have also factored in, along with Global Warming flooding 

where Turkey Point resulting in even greater damage to people's health & tourism, that:....The 

very source of nuclear power has to be dug out of the ground, through huge mines & has to be 

transported over states to the nuclear power plants. As I believe PFL representatives said, not 

just the one time they start a new nuclear reactor or/and a nuclear power plant, but regularly to 

replace the spent source. Plus, since the nuclear waste that is created cannot be safety stored, 

the transporting & attempting to safely store the nuclear waste has a huge cost in terms of 

global warming & our world's environment. (0120-3 [Shark, Jason])

Appendix E October 2016 E-375 NUREG–2176
Response: This comment is concerned with Continued Storage, long-term disposal of spent 

fuel, transportation of radioactive material, and climate change impacts. While a repository for 

final disposal of spent nuclear fuel has yet to be constructed, the Commission has, through 

rulemaking, considered the environmental impacts of spent fuel disposal in light of the current 

national policy regarding spent fuel. Specifically, on August 26, 2014, the Commission issued a 

revised rule at 10 CFR 51.23 and an associated Generic Environmental Impact Statement for 

Continued Storage of Spent Nuclear Fuel (NUREG-2157). Continued Storage is defined as the 

storage of spent fuel after the end of the licensed life for operations of a nuclear reactor and 

before final disposal in a permanent repository. The revised rule adopts the generic impact 

determinations made in NUREG-2157 and codifies the NRC's generic determinations regarding 

the environmental impacts of continued storage of spent nuclear fuel beyond a reactor's 

operating license. As directed by 10 CFR 51.23(b), the impacts assessed in NUREG-2157 are 

deemed incorporated into this EIS in Section 6.1.6. Section 6.1.6 also explains that current 

national policy mandates that high-level and transuranic wastes are to be buried at deep 

geologic repositories and that impacts to the environment would not be significant as associated 

with deep geologic disposal. Section 6.1.8 discusses the transportation impacts of the uranium 

fuel cycle and Section 6.2 discusses the impacts under normal operating and accident 

conditions of the transportation of nuclear fuel and radioactive waste, in accordance with 10 

CFR 51.52 and Table S-4, Environmental Impact of Transportation of Fuel and Waste To and 

From One Light-Water-Cooled Nuclear Power Reactor. Climate change, including future sealevel rise, is addressed in Chapter 2, Chapter 7, and Appendix I. The impacts of climate change 

on the storage of spent fuel are included in NUREG-2157. Climate change impacts on the safe 

operation of Units 6 and 7, including sea-level rise, flooding, hurricanes, and storm surge, will be 

addressed in the staff’s Safety Evaluation Report. 

The comments provided no information in addition to that considered in the draft EIS analysis, 

NUREG-2157, and Tables S-3 and S-4. Accordingly, no change was made to the EIS as a 

result of this comment. 

Comment: Storage of radioactive waste in such an area can hardly be described as secure; 

transport of such waste would be extremely hazardous and presently no long term central 

storage facility exists. (0463-4 [Gross, Cheryl A.])

Comment: Where will the spent rods be disposed of and how will they be transported? (0550-3

[H., Pat])

Response: These comments are concerned with Continued Storage, long-term disposal of 

spent fuel, and transportation of radioactive material. While a repository for final disposal of 

spent nuclear fuel has yet to be constructed, the Commission has, through rulemaking, 

considered the environmental impacts of spent fuel disposal in light of the current national policy 

regarding spent fuel. Specifically, on August 26, 2014, the Commission issued a revised rule at 

10 CFR 51.23 and an associated Generic Environmental Impact Statement for Continued 

Storage of Spent Nuclear Fuel (NUREG-2157). Continued Storage is defined as the storage of 

spent fuel after the end of the licensed life for operations of a nuclear reactor and before final 

disposal in a permanent repository. The revised rule adopts the generic impact determinations 

made in NUREG-2157 and codifies the NRC's generic determinations regarding the 

environmental impacts of continued storage of spent nuclear fuel beyond a reactor's operating 

license. As directed by 10 CFR 51.23(b), the impacts assessed in NUREG-2157 are deemed 

incorporated into this EIS in Section 6.1.6. Section 6.1.6 also explains that current national 

policy mandates that high-level and transuranic wastes are to be buried at deep geologic 

repositories and that no release to the environment is expected to be associated with deep 

Appendix E NUREG–2176 E-376 October 2016
geologic disposal. Section 6.1.8 discusses the transportation impacts of the uranium fuel cycle 

and Section 6.2 discusses the impacts under normal operating and accident conditions of the 

transportation of nuclear fuel and radioactive waste, based on 10 CFR 51.52, Table S-4. The 

environmental effects of transportation of fuel and waste are codified in 10 CFR 51.52, Table S4, Environmental Impact of Transportation of Fuel and Waste To and From One Light-WaterCooled Nuclear Power Reactor. 

The comments provided no information in addition to that considered in the draft EIS analysis, 

NUREG-2157, and Table S-4. Accordingly, no change was made to the EIS as a result of these 

comments. 

Comment: Storing these elements in spent fuel pools such as FPL proposes for Turkey Point 6 

and 7 creates a serious environmental threat to the people, land, air, and water of this 

community. (0615-1-10 [Bethune, David])

Response: Section 6.1.6 discusses the onsite storage of spent fuel during the licensed lifetime 

of reactor operations. Environmental impacts from onsite spent fuel storage have been studied 

extensively and are well understood. Further, effects of normal operation are addressed in EIS 

Sections 5.9 and 6.1.6 (radiological health), Section 5.1 (land use), Section 5.3.1 (terrestrial 

ecology), and Section 5.3.2 (aquatic ecology). The overall conclusion is that the environmental 

impacts of radiation exposure would be small. The comments provided no information in 

addition to that considered in the draft EIS analysis. Accordingly, no change was made to the 

EIS as a result of this comment. 

Comment: The nuclear industry and especially any new construction should pay for the cost of 

nuclear waste disposal. This should be a cost of nuclear power and not a cost paid for by the 

government. (0404-1 [Leibowitz, Arthuir])

Comment: Nuclear waste is the largest form of LONG-TERM DEBT that any country with 

nuclear energy will ever have. The cost to store nuclear waste for 250,000 years could bankrupt 

a country as the cost is INFINITE. (0603-6 [Anonymous, Anonymous])

Response: Licensees, and ultimately their electricity consumers, pay for the storage and 

ultimate disposal of spent fuel. Under the Nuclear Waste Policy Act, licensees are required to 

pay a fee into the nuclear waste fund, which is to be used to fund permanent disposal of spent 

fuel; DOE recently suspended collection of the fee in response to the decision in NARUC 

v. DOE. In addition, under 10 CFR 50.54(bb) and 10 CFR 72.22(e), licensees are required to 

provide funding for spent fuel storage costs whether the storage occurs onsite or at an 

independent spent fuel storage installation. As discussed in Section B.3.4 of NUREG-2157, the 

NRC acknowledges that, because of delays in the siting and licensing of a repository, the 

Federal government bears an increasing financial responsibility for spent fuel storage costs, and 

may become responsible for paying all the costs associated with spent fuel storage at some 

time in the future. The comments provided no information in addition to that considered in the 

draft EIS analysis and NUREG-2157. Accordingly, no change was made to the EIS as a result 

of these comments. 

E.2.19 Comments Concerning Transportation 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[b]y increasing the capacity to generate power 

from nuclear the dependence on various non-renewable fuels will diminish decreasing the need 

Appendix E October 2016 E-377 NUREG–2176
for transportation of oil and liquefied natural gas over rail tracks which are becoming 

overcrowded with new passenger and commuter services to the east, trains plus increased 

freight demand from the port expansion etc...As development continues to expand fewer people 

will be exposed to the dangers of train accidents which are even more threatening to people and 

the environment if the train carried oil or gas...The decrease in train transportation of fuel for the 

generation of electricity will have a very substantial positive environmental effect and result in a 

decrease in greenhouse gas emissions from the transportation alone. (0015-5 [Goldmeier, Barry])

Response: The review team agrees with the comment. Fewer rail shipments are needed to 

support operation of a commercial nuclear power plant than would be needed to achieve the 

same electrical generating capacity at coal- or oil-fired power plants. No changes were made to 

the EIS as a result of this comment. 

Comment: There are instances in the DEIS where, due to the timing of events with respect to 

drafting the DEIS, specified dates, or future actions, indicated in the DEIS have passed. 

Instances in the DEIS include (emphasis added):...DEIS Subsection 7.11.2, Page 7-41, Lines 

23-26: The DEIS states: "The Tunnel Access Improvement project is located about 26 mi 

northeast of the Turkey Point site, but it is unlikely construction of the two projects would overlap 

because the tunnel improvement project is scheduled to be complete in 2014..." This project 

was completed in 2014. (0619-1-11 [Maher, William])

Response: Section 7.11.2 of the EIS was revised to remove the reference to the Tunnel 

Project. 

Comment: DEIS Subsection 6.2.1.1, Page 6-21, Table 6-4: In DEIS Table 6-4, the parameter, 

"Dose rate at 1 m from vehicle, mrem/hr", is reported as 0.1. In ER Table 5.7-6, the same 

parameter, with a different unit, "Dose rate at 1 meter from vehicle, person-rem per hour" is 

reported as 0.1.? (emphasis added) (0619-5-2 [Maher, William])

Response: There appears to be a typographical error in the ER. The correct unit for the dose 

rate emitted from a shipment is mrem/hr. Person-rem refers to collective radiation doses to 

groups of persons or populations, and not dose rate. No changes to the EIS were necessary as 

a result of this comment. 

Comment: DEIS Subsection 6.2.1.1, Page 6-23, Lines 20-21 and Subsection 6.2.1.1, Page 6-

23, Lines 27-29: The DEIS (Subsection 6.2.1.1, Lines 20-21) states: "The following discussion 

applies to unirradiated fuel shipments..." Additionally, the DEIS (Subsection 6.2.1.1, Lines 

27-29) states: "In all cases in this EIS, the NRC staff assumed that the dose rate from the 

shipping containers would be 10 mrem/hr at a distance 2 m (6.6 ft) from the side of the transport 

vehicle." This transport dose rate assumption (equivalent to 14 mrem/hr at 1 m) greatly exceeds 

that presented in DEIS Table 6-4 (0.1 mrem/hr at 1 m for unirradiated fuel shipments). 

Recommend replacing "In all cases in this EIS..." with "In all irradiated fuel cases in this EIS..." 

(emphasis added) (0619-5-3 [Maher, William])

Response: The staff agrees with the comment that the 10 mrem/hr dose rate does not apply to 

all cases in the EIS. The NRC staff revised the EIS to indicate that the 10 mrem/hr dose rate 

applies to the analysis of radiation doses to maximally exposed individuals from transportation 

of irradiated fuel. The radiation dose rates used for calculating incident-free and accident 

impacts from transportation of irradiated fuel on populations are specified in the EIS Tables 6-6 

and 6-8. 

Appendix E NUREG–2176 E-378 October 2016
Comment: DEIS Subsection 6.2.2.2, Page 6-34, Table 6-10: In DEIS Table 6-10 footnote (a) 

indicates the radionuclide inventory in DEIS Table 6-10 was obtained from ER Table 7.4-3. ER 

Table 7.4-1 contains the radionuclide inventories found in DEIS Table 6-10 with the exception of 

Kr-85—this exception should be noted in the DEIS Table 6-10. (0619-5-4 [Maher, William])

Response: The comment is correct. The Kr-85 source term was taken from an Idaho National 

Engineering and Environmental Laboratory document (INEEL 2003) and has been included in 

previous EISs for AP1000 reactors. The NRC staff revised EIS Table 6-10 to reflect this 

comment. 

Comment: DEIS Subsection 6.2.2.2, Page 6-36, Table 6-11: In DEIS Table 6-11 includes an 

incorrect footnote (a). Values in the table are reported in person-rem/year, not person-Sv/yr. 

Footnote (a) should provide the conversion from person-rem to person-Sv as in DEIS 

Subsection 6.2.1.1, page 6-22, Table 6-5 and DEIS Subsection 6.2.2.1, page 6-31, Table 6-9.

(0619-5-5 [Maher, William])

Response: The footnote in the EIS Table 6-11 is correct, but the review team agrees with the 

comment to the extent that the conversion should be from units of person-rem reported in the 

Table to person-Sv. The review team revised EIS Table 6-11 to reflect this change. 

Comment: DEIS Subsection 6.2.2.2, Page 6-36, Lines 8-10: The DEIS states: "This risk is very 

small compared to the 4.5 x 10-5 person-rem/yr that the same population would incur 

annually...Turkey Point site to Yucca Mountain from exposure to natural sources of radiation." 

The DEIS Subsection 6.2.2.1, Page 6-33, Lines 10-12 correctly states: "This dose is very small 

compared to the estimated 4.5 x 105

 person-rem that the same population...Turkey Point site to 

Yucca Mountain would incur annually from exposure to natural sources of radiation." (emphasis 

added) (0619-5-6 [Maher, William])

Response: The comment correctly identifies a typographical error in Section 6.2.2.2. The 

review team revised the statement in the EIS Section 6.2.2.2 to correctly reflect the 4.5x105

person-rem/yr exposures to natural background radiation. 

Comment: DEIS Subsection 7.11.2, Page 7-43, Lines 3-7 and Subsection 7.11.2, Page 7-43, 

Lines 10-12: The DEIS (Subsection 7.11.2, Lines 3-7) states: "...the NRC staff considers to be 

acceptable for the 1,000 MW(e) reference reactor." Similarly, lines 10-12 refer to a 1,000 MW(e) 

reference reactor. Impacts presented in Table S-4 are based on an 1100 MWe reference 

reactor evaluated in the reference WASH-1238. (emphasis added) (0619-5-10 [Maher, William])

Response: The statement in Section 7.11.2 of the EIS was revised to correct this typographical 

error. 

E.2.20 Comments Concerning Decommissioning 

Comment: As a resident of Key Largo, I am hopeful that you will reconsider the proposed 

expansion and begin thinking about decommissioning the plant as it's useful life reaches its 

limits. (0130-4 [Jones, Diane])

Comment: As the Turkey Point reactors age, they should be dismantled. (0213-5 [Hyams, 

Charles])

Comment: My god, you should be planning its dismantling even as we speak! (0384-2

[Franzmann, Paul])

Appendix E October 2016 E-379 NUREG–2176
Response: At the end of the operating life of a nuclear power reactor, NRC regulations require 

that the facility be decommissioned. Decommissioning is discussed in Section 6.3 of the 

EIS. The environmental impact from decommissioning a permanently shut-down commercial 

nuclear power reactor is also discussed in Supplement 1 to NUREG-0586, Generic 

Environmental Impact Statement on Decommissioning of Nuclear Facilities, which was 

published in 2002. In Supplement 1, NRC staff found that for most environmental issues, the 

impact from decommissioning activities is considered small. 

No changes were made to the EIS in response to these comments. 

E.2.21 Comments Concerning Cumulative Impacts 

Comment: According to NRC and NEPA requirements, the DEIS must discuss and analyze the 

environmental impacts of the proposed Turkey Point expansion, including the direct, indirect 

and cumulative impacts. Current operations of Turkey Point already pose risks to the ecological 

integrity of surrounding environments, particularly to Biscayne Bay and Biscayne National Park. 

Specifically, water from the cooling canal system (CCS), a designated industrial wastewater 

facility (IWF) used to cool waters from the operation of Units 3 & 4, is seeping into groundwater, 

creating a hypersaline plume emanating out in all directions. [Footnote 22: Lewis, M. United 

States Department of the Interior, National Park Service Letter to M. Harris, Florida Department 

of Environmental Protection, November 13, 2009, L76, 1.] Despite being described as a "closed 

system" by FPL, the CCS is an unlined system with direct connections to groundwater. (0113-2-2

[Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: This failure to address the current crisis of the cooling canals, the fact that there 

has not been presented any proposed long term solution in the Draft EIS is a fatal flaw in the 

Draft statement, and can only be addressed by studying these current emergency conditions, 

and the cumulative effect of this new and likely long-term scenario, the impact of the uprate on 

the cooling canal system, the significant impact on our water sources, and the CUMULATIVE 

EFFECT of current conditions when planning for the future, then factoring it into the scenario for 

the two proposed new plants. The failure to address current conditions and to establish the 

potential scenario fails to provide a comprehensive evaluation as recommended by the USGC 

Global Sea Level Rise Scenarios for the US national Climate Assessment. (0145-6 [Lerner, 

Cindy])

Comment: The NRC review should not separate the new reactor impacts from the persistent 

damage being caused by the existing reactor operations. The continued damage to Biscayne 

National Park must not be allowed to continue as it runs counter to the National Parks mission 

and the Nation's promise to its citizens that the Park and its biological resources be protected 

for current and future generations. (0172-6 [Cava, Daniella Levine])

Comment: Not effectively addressing the ongoing environmental degradation as part of the 

NRC's environmental review of the proposed additional nuclear power plants would be a 

disservice to the residents of Miami-Dade County, the rate-payers of the State of Florida, and 

Nation. Please ensure that the environmental review for Turkey Point 6 & 7 evaluates the 

cumulative impact and use this opportunity to correct the problems as they exist now. (0172-8

[Cava, Daniella Levine])

Comment: The DEIS does not adequately describe the cumulative impacts of constructing and 

operating Units 6 and 7. Information should be included related to impacts from other ongoing 

actions as we have indicated herein, federal or non-federal, that are likely, when added to the 

Appendix E NUREG–2176 E-380 October 2016
incremental effects of the proposed action, to have an impact on the affected environment. This 

view is consistent with the CEQ regulations for implementing NEPA which defines cumulative 

impacts as, "The impact on the environment which results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future actions regardless 

of what agency (federal or non-federal) or person undertakes such other actions." Most notably, 

the analysis does not fully consider the following impacts: effects of sea level rise and storm 

surge, and impacts from the IWF hypersaline plume, freshwater utilized to alleviate IWF 

emergencies, operation of the RCWs on NPS resources, impacts on surface water and 

groundwater, and effects on imperiled flora and fauna and aquatic resources. The NRC should 

update its cumulative impacts analysis in revisions to the DEIS. Many of the specific cumulative 

impact concerns are described in previous comments on specific topics such as sea-level rise 

and climate change, water quantity and quality. (0622-2-5 [Austin, Stan])

Response: The NRC is aware of the 1997 guidance from the Council on Environmental Quality 

(CEQ) regarding cumulative impacts. The NRC's process for assessing cumulative impacts is 

described in the introduction to Chapter 7. In performing its cumulative impacts analysis, the 

NRC follows the requirements of NEPA, the NRC's regulations, and the guidance provided in 

NUREG-1555, the Environmental Standard Review Plan (NRC 2000). This analysis considers 

the current environmental conditions at the Turkey Point site and in the surrounding region as 

described in Chapter 2 of the EIS. Chapter 2 includes a description of the existing units at the 

site and the environmental conditions associated with their operation. The analysis considers 

the impacts associated with construction and operation of Turkey Point Units 6 and 7 described 

in Chapters 4 and 5 to be those that are also important to consider in a cumulative impact 

context. Chapter 7 provides a list of other important projects within the general 50-mi region 

surrounding Turkey Point that could contribute to cumulative impacts. For each resource area 

considered, the EIS further describes the geographical area of interest and provides a technical 

justification for its extent. These geographical areas of interest encompass the areas in which 

direct, indirect, and cumulative impacts would be expected to occur for each resource 

area. The EIS has been updated to reflect data collected since the publication of the draft EIS. 

E.2.22 Comments Concerning the Need for Power 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons: 1-The area needs a dependable long term source 

of electric power to accommodate future growth[.] (0015-1 [Goldmeier, Barry])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...I would imagine that more nuclear generation 

capacity from new plants will take the strain off the older facilities allowing them to be upgraded 

and have their safety mechanisms improved. (0015-12 [Goldmeier, Barry])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...In the event of a disruption in the power grid 

because of terrorism, accidents or weather having a Miami-Dade generated source of electric 

power would proved to be a tremendous advantage for our County and boost our stability.

(0015-8 [Goldmeier, Barry])

Comment: I also am aware that FP&L has decommissioned several power plants in Florida 

and the requirements for extra power, especially with the huge influx of immigrants and others 

from our northern states, is critical. (0035-3 [Larrabee, Laura])

Appendix E October 2016 E-381 NUREG–2176
Comment: South Florida is growing and more Electrical Power is needed. (0041-1 [Williams, 

Paul])

Comment: There have been some questions about the need for this project, and to us in the 

construction industry there is no question about the need for this project. All it takes is you drive 

down Downtown Miami, the Biscayne corridor, Brickell, the Design District and you see cranes 

everywhere and you see high-rises going up everywhere. And that construction growth, that 

boom in construction that we're experiencing right now, needs additional power capacity. Each 

high-rise consumes on the average from 2 to 3,000 kva's of load. And that is the reason why 

this project is necessary, the need for additional power capacity to maintain this growth.

(0721-27-1 [Rodriguez, Manuel J.])

Comment: In essence we have taken the position as a city the need for additional power as we 

grow our city. As you all well know our community is growing really fast and we don't have the 

capacity to generate enough of our own so we do purchase a lot from Florida Power and Light. 

They are an extremely good partner, they've been with -- you know, we've been partners for a 

long time. Actually, we're the sister city so of record. (0722-1-1 [Porter, Jeff])

Comment: I've lived here, as I said, for 30 years which means I lived through Hurricane 

Andrew. Can I see a show of hands? How many of you here in the room lived through Hurricane 

Andrew? You know, that is indicative of what happens when you no longer have a reliable 

supply of electricity. And that is what my concern is and that is what brought me here today. 

Turkey Point 6 and 7 represent what I believe to be a necessary element of additional power to 

this community. We operate, we live at the end of the power grid. All of our energy with the 

exception of what's coming out of Turkey Point is basically imported from the north which makes 

us highly vulnerable in the case of storms and other potential natural interruptions. (0722-10-2

[England, Peter])

Comment: And then aside from that there's the concern that South Florida needs energy.

(0722-5-2 [Silva, Nicolas])

Comment: [W]as the additional power needed? Second, was it safe and cost efficient? Over 

the years as I've become more informed. I've been convinced that we need -- we will need 

additional power. (0723-1-1 [Wallace, Otis])

Comment: ...whereas FPL has plans to expand electrical generation at its Turkey Point facility 

meeting the electrical needs of its customers and service area in Miami Dade County. (0723-2-2

[Trowbridge, Mark])

Comment: [A]nd kilowatt hours, that it will bring to extra capacity for Miami Dade County.

(0723-8-3 [McDuffie, Stephen])

Response: These comments express support for nuclear power because of the growth of the 

area and the concomitant increase in the need for power. No changes were made to the EIS as 

a result of these comments. 

Comment: FPL has cancelled its renewable programs for ratepayers, is engaged in anti 

rooftop solar astroturf campaigns and disinformation propaganda to limit competition from 

rooftop solar that would make the need for new reactors unnecessary. This is poor coporate 

social responsibility that should not be rewarded. (0710-6 [Platt, George Seth])

Appendix E NUREG–2176 E-382 October 2016
Comment: And I think the last cost that I think is really hard to quantify is the long-terms cost of 

business and our economy by doubling down on nuclear at a time when we are not in crisis. No 

one is predicting brown-outs in the near future. Instead, we're at a time of opportunity. We don't 

know what our future will be in terms of energy, but we'd be doubling down for 50 to 80 years on 

nuclear, when we're at a time where on the ballot in 2016 is a measure that would allow us -- 

allow voters to consider whether they want competition and diversification on how power is 

generated and distributed. (0721-1-9 [Rodriguez, Jose Javier])

Comment: Lastly, it's no surprise that FPL argues that there's a need for a $20 billion nuclear 

reactor project to meet the demand 12 years from now. They have gutted their energy efficiency 

programs for customers and they don't assign any capacity avoidance value to solar power, so 

they've cleared the deck of all clean energy options. (0721-8-10 [Cavros, George])

Response: These comments express general opposition to the environmental costs of power 

plant construction or raise societal issues that are not within the purview of NRC or USACE to 

address as part of the environmental review process. They did not provide new information 

related to the environmental effects of the proposed action. Therefore, no changes were made 

to the EIS as a result of these comments. 

Comment: Overall: The overall project purpose is to meet the public's need for reliable 

increased electrical baseload generating capacity in Florida Power & Light's service 

territory. My question is: Is this public need for the entire state or specifically for Miami?

(0008-3 [Finver, Jody])

Comment: The NRC wholly relied on the Florida Public Service Commission (FPSC) need 

determination as stated above [commenter pasted text from EIS Section 8.2.1 and its 

subsections into their correspondence] - and failed to properly make an "independent" "NEED" 

determination in this matter. (0010-4 [Saporito, Thomas])

Comment: FPL should be denied a license for Turkey Point expansion for many reasons:...5. 

No need. Miami's demand for electricity is falling, not rising. (0022-5 [Read, Alice Gray])

Comment: We continue to have serious concerns about FPL's proposal to potentially build two 

new Toshiba-Westinghouse AP1000 reactors at their existing Turkey Point site in Miami-Dade 

County. The uncertainties of this more than $20 billion, decade-delayed project continue to 

escalate, putting utility ratepayers and the environment at increasing risk. Fundamentally, there 

is no purpose and need for the two reactors. (0112-1 [Barczak, Sara])

Comment: The power lines would be sold upstate, Orlando and Tampa, and out of state. It is 

not for local use. So who does it serve? (0149-7 [Nelson, Joyce E.])

Comment: The power that will be generated at these reactors is not for the local area. (0337-2

[Philips, Sally B.])

Comment: Another reason to support the "No Action" alternative is that there is no need for the 

proposed ~$20 billion reactors--the fact that they have been delayed several times and the inservice date pushed back at least ten years is just one indication. The fact that FPL will not 

commit to actually completing the project is clearly another. Further, the NRC's reliance on 

Florida Public Service Commission orders and the state's utility resource planning process is 

badly misplaced. The alleged need for the new reactors is the product of a disjointed state utility 

planning process that the NRC should not rely on. (0379-4 [Commenters, Multiple])

Appendix E October 2016 E-383 NUREG–2176
Comment: It is quite possible that the plants will never be built, if FPL decides, for example 

that their use would be uneconomical. (0615-1-13 [Bethune, David])

Comment: When asked to justify the electrical demand for a new plant, another staff member 

simply reported that the state Public Utilities Commission had deemed it necessary. (0615-1-4

[Bethune, David])

Comment: Even though you rely upon the state of Florida for the electric needs assessment 

and determination of need it is important to point out that these two new reactors may not be 

needed. Florida is moving to an economy based upon new electric sources of power. (0641-8

[Martin, Drew])

Comment: Florida needs to strengthen and secure its grid through diversity of electricity 

generation, not create large reactors at the tip of the State that feed energy elsewhere. (0710-7

[Platt, George Seth])

Comment: And so as I look at this synopsis of the Draft Environmental Impact Statement, I 

have to wonder about the age of some of the statistical basis that have been invoked by FP&L 

and by other parts, the Public Utilities Commission, for example, as a basis for making the claim 

for the need for these two units. So, that's one question that I have, and I want to raise for our 

visitors. (0721-17-1 [Breslin, Tom])

Comment: Second one is, our area may need more electricity, but there is no present 

foreseeable crisis that exists. (0721-31-4 [Almirola, Alejandro])

Comment: The determination of need right now is based on antiquated data that was done in 

2008. The NRC review based on a seven-year-old determination of need that was done before 

the market crashed and the real estate crash is not adequate information to base this plant 

expansion on. It seems to be a desktop review and not appropriate with such large threshold 

questions. (0721-5-2 [Mendez, Victoria])

Comment: FPL's proposed Turkey Point reactors are neither low cost nor low risk. While there 

are a host of environmental and safety impacts, from the extremely water intensive proposed 

reactors, I'm going to limit my comments to the need for power. And with all due respect, Dan 

and Alicia, there is no need for the proposed reactors. The fact that they have been delayed 

several times and the in-service dates have been pushed back at least ten years, is but one 

indication. The fact that FP&L will not commit to actually completing the projects is another clue.

(0721-8-1 [Cavros, George])

Comment: But let me circle back to the DEIS, because, you know, why is this important in that 

context? Because the alleged need for the power plant is the product of a disjointed State utility 

planning process upon which the NRC relies. To reach this determination that the need is there 

the NRC concludes that Florida's utility planning process is systematic, comprehensive, subject 

to confirmation, and responsive to forecasting uncertainty. (0721-8-8 [Cavros, George])

Comment: The reason I asked the question earlier about the demand forecast is I don't think 

you can trust even an honest and well-managed utility with the lowest power cost in the nation, 

like FPL, to make these projections for the demand for power, baseload power. They have a 

bias in the system. Basically they get a guaranteed return on every dollar they spend. (0723-12-1

[Henry, Jim])

Appendix E NUREG–2176 E-384 October 2016
Comment: We have to think of some alternatives to the demand forecasts that they have laid 

out here, which are -- you know, if they're -- I mean, they're directly relevant to the DEIS. 

Because if the demand forecast isn't right then we have to go back to square one. (0723-12-4

[Henry, Jim])

Response: These comments generally suggest that NRC's reliance upon the State's 

Determination of Need process implemented by the Florida Public Service Commission (FPSC) 

is invalid, unfounded, or that the need for Units 6 and 7 has not been clearly established. In 

2008, the State granted the applicant a Determination of Need for Units 6 and 7. Chapter 8 of 

the EIS provides the review team's analysis of the findings of the FPSC process in support of 

granting FPL's Determination of Need. The Chapter 8 discussion includes analysis of the most 

recent annual update to FPL's feasibility assessment approved by the FPSC in October, 

2015. As indicated in Section 8.4 of NRC's Environmental Standard Review Plan (NUREG1555), when a State agency has regulatory authority over determining a need for power, NRC 

defers to that agency's decision. Chapter 8 of the EIS has been updated to reflect any relevant 

new information provided by FPL or the FPSC regarding the need for proposed Units 6 and 

7. In addition, it discusses FPSC's condition in its granting of FPL's Determination of Need - 

that FPL regularly update its long-term forecasting to regularly reassess the need for the 

project. 

Comment: DEIS Subsection 8.1.1, Pages 8-3/8-4, Lines 4/5: The DEIS states: "FPL relies on 

two measures of reliability in its resource planning..." However, in FPL's 2014 Ten Year 

Power Plant Site Plan (DEIS reference [(FPL2014-TN3360)], FPL introduced a third criterion: 

"Therefore, FPL is implementing a new reliability criterion of a 10% GRM in its resource 

planning work to complement its other two reliability criteria: a 20% total reserve margin criterion 

for Summer and Winter, and an annual 0.1 day/year loss-of-load-probability (LOLP) criterion." 

(emphasis added) (0619-5-12 [Maher, William])

Comment: DEIS Subsection 8.1.1, Page 8-4, Table 8-1: DEIS Table 8-1 cites (FPL 2014-

TN3360), "Ten Year Power Plant Site Plan 2014-2023", as the reference. However, only the 

Industrial values can be verified per Schedules 2.1 and 2.2 (pages 37-38) from the Ten Year 

Power Plant Site Plan 2014-2023. (0619-5-13 [Maher, William])

Response: These comments identify inconsistencies or point out reliance on outdated sources 

in Chapter 8 of the EIS. Changes to Chapter 8 have been made to reflect updated sources of 

information and to correct any inconsistencies in the text. 

Comment: These "grid-tied" solar systems not only "decrease" FPL's "NEED" for more 

generating base load capacity - they actually "decrease" FPL's base load requirements. To 

the exent that the FPSC failed to properly consider these types of grid-tied home solar 

systems in making their "NEED" determination - the NRC's reliance on FPSC's 

determination is flawed in kind. One of the major and leading home solar system providers - 

Solar City - offers a leasing option for Florida home owners with NO upfront costs as shown 

here and below: http://www.solarcity.com/residential/how-much-do-solar-panels-cost [ad placed 

here - refer to PDF file] As can be seen here - a customer of FPL can simply lease a complete 

home solar power generating system for their home without making any upfront payments. As 

previously stated - these grid-tied systems generate excess power back to FPL's electric grid. 

Thus, FPL's base load demand is reduced in two ways - (1) reduced customer demand for 

electric power from the FPL grid since these solar power systems can generate 100% of a 

home owner's energy needs; and (2) the solar systems generate electric power back to FPL's 

grid. (0010-10 [Saporito, Thomas])

Appendix E October 2016 E-385 NUREG–2176
Comment: The NRC's reliance on the Florida need determination process is misplaced. The 

foundation for the need for power, which is a foundational consideration in the DEIS, is based 

on a 2008 state need determination order by the Florida Public Service Commission (PSC), 

whose underlying assumptions have been not stood the test of time. In fact, the load forecast 

assumptions made in 2008 regarding the need for the reactors to meet demand bear no 

resemblance to today's load forecast realities. Moreover, the NRC analysis of the need 

determination order is cursory and not weighed against current forecast realities to determine if 

the process meets the NRC's own requirements (NUREG-1455) for responsiveness to 

forecasting uncertainty. Instead, the NRC offers a conclusory opinion with mere references to 

the order that are not independently verified by FPL's own subsequent filings with the Florida 

PSC. Therefore, the NRC should take a "hard look" at the underlying need for power by 

conducting an analysis of Florida regulations and the load forecasts, as they exist today, in 

rendering a decision on the need determination's responsiveness to load forecasting 

uncertainty. If it does so in a through manner, it can only conclude that the process that 

determined need for the plant is obsolete, not remotely responsive to load forecast uncertainty, 

and does not support the need for power upon which the DEIS is based. The NRC relies 

exclusively on the PSC's Order No. 08-0237-FOF-EI in concluding that there is a need for 

power. (DEIS 8-4 -- 8-12). Yet, the load projections, and the related assumption for the need for 

the reactors in the 2008 need determination were flat wrong. The order states, in part that 

"FPL's peak load is expected to increase by over 6,000 MW by the year 2020." (PSC Order 08-

0237-FOF-EI p.10). In fact, the increase in peak load demand projected from the Company's 

2015 Ten Year Site Plan shows that the increased peak load from 2008 to 2014 and projected 

peak load out to 2020 only amounts to a 3,847 MW increase in peak demand. (FPL 2015 Ten 

Year Site Plan, p. 42). The order upon which the NRC relies, goes on to state the following: [I]if 

load forecasts were to dramatically drop or the amount of DSM or renewable generation 

available were to substantially increase, the likely result would be the deferral or avoidance of 

some natural gas-fired power plants which have not been certified to date, rather than the 

deferral or avoidance of new nuclear base-load generation.(emphasis added). (PSC Order 08-

0237-FOF-EI p.10). Truth is, with the dramatic drop in demand, it is the proposed reactors that 

have been pushed back, not new natural gas plants. The in-service dates for Turkey Point 6 and 

7 have been delayed several times. It was most recently announced that the new projected inservice dates for the reactors is 2027/2028.3 [Footnote 3: FPL Press Release, January 26, 

2015. At http://newsroom.fpl.com/2015-01-26-FPL-announces-plans-to-install-more-than-1-

million-solar-panels-at-three-additional-solar-power-plants-as-part-of-continued-strategy-ofadvancing-affordable-clean-energy-in-Florida. And FPL testimony from Richard O. Brown filed 

on May 1, 2015 with the Florida Public Service Commission, Docket No. 150009, p. 17, states: 

"...the in-service dates of Turkey Point 6 & 7 utilized in the 2015 feasibility analyses are changed 

from 2022 and 2023 to 2027 and 2028. These dates represent the earliest practical deployment 

date for Turkey Point 6 & 7." At http://www.psc.state.fl.us/library/FILINGS/15/02473-15/02473-

15.pdf.] The determination of need never contemplated an in-service date pushed back almost a 

decade. (PSC Order 08-0237-FOF-EI p.1). In the absence of the proposed reactors, the 

Company has continued to repower existing natural gas plants and intends to return to the PSC 

for another determination of need for a natural gas combined cycle plant this year with a 

projected in-service date of 2019. (FPL 2015 Ten Year Site Plan, p. 9). There is no discussion 

of this new dynamic in the DEIS. The DEIS continues to be riddled with inaccuracies. It states 

that FPL is expected to fall below the 20 percent summer reserve margin requirement in 2016 

by 824 MW. By 2022, the projected year referenced in the DEIS during which Unit 6 might 

become operational, the reserve margin would be 5.4 percent. (DEIS 8-9). This is simply 

incorrect and not consistent with FPL's 2015 Ten Year Site Plan and further indicates the NRC's 

careless analysis of PSC Order 08-0237-FOF-EI against the realities that exist in Florida today. 

Moreover, the NRC inexplicably shifts its focus from the 2018/2020 timeframe (in service dates 

Appendix E NUREG–2176 E-386 October 2016
used in the need determination) to a 2022 timeframe without any explanation of how it 

transitioned to that year nor why it failed to incorporate the most recent projected operation 

dates of 2027/28. (DEIS 8-9). The DEIS must analyze its conclusion that there is a need for 

power in the context of the FPL's current resource planning scenario as identified in its 2015 

Ten Year Site Plan. The DEIS does not directly address the fact that FPL has currently missed 

the projected in service dates by almost a decade, nor does it address the issue that the utility 

continues to not commit to actually construct the proposed reactors4 [Footnote 4: Florida Public 

Service Commission, Docket No. 130009, Hearing Transcript Volume 3, p. 617.] and simply 

continues to seek determinations of need for natural gas combined cycle facilities that were not 

contemplated in the very PSC order on which the NRC places its reliance. Not only have the 

facts today proven that the Turkey Point 6 and 7 need determination is not responsive to 

forecast uncertainty, as a matter of law, once the order is issued, it cannot be revisited -- 

rendering any decision related to need unresponsive to load forecast uncertainty. The Florida 

PSC is the sole forum for a determination of need as plainly stated in Florida statute. In making 

its determination on a proposed electrical power plant using nuclear materials or synthesis gas 

produced by integrated gasification combined cycle power plant as fuel, the commission shall 

hold a hearing within 90 days after the filing of the petition to determine need and shall issue an 

order granting or denying the petition within 135 days after the date of the filing of the petition. 

The commission shall be the sole forum for the determination of this matter and the issues 

addressed in the petition, which accordingly shall not be reviewed in any other forum, or in the 

review of proceedings in such other forum. (emphasis added). (§403.519 (3), Fla. Stat.) Hence, 

pursuant to the need determination process, the need for the Turkey Point reactors cannot be 

challenged or revisited once the order has been issued. Therefore, if the PSC grants a 

determination of need based on economic conditions which are no longer relevant, and the 

need determination cannot be revisited, it begs the question: how can the NRC reach its tersely 

explained conclusion that the need determination process is responsive to load forecast 

uncertainty, when it is in-fact not? The NRC's reliance on the state process is misplaced. The 

agency must take a hard look at the need for power. (0112-4 [Barczak, Sara])

Comment: Clarify Analysis of Need for Power and Population Projections. NEPA requires 

that a final Environmental Impact Statement discuss the purpose of and need for the action "to 

which the agency is responding in proposing the alternatives including the proposed action." 40 

CFR § 1502.13. In particular, Chapter 8 of the Nuclear Regulatory Commission's Environmental 

Standard Review Plan provides a review and analysis of the "need for power". Through this 

section, the Nuclear Regulatory Commission may weigh the benefits of the power plant against 

the environmental impacts of construction and operation of a nuclear power reactor. Comment 

15: The final Environmental Impact Statement should assess and explain projections of 

future demand for electricity in South Florida. The Florida Bureau of Economic and 

Business Research (BEBR) at the University of Florida released a Florida Detailed Population 

Projection for the years 2015-2040 in 2014. http://tinyurl.com/BEBR2015-2040. This study 

projects that the rate of population growth in Miami-Dade County will continue to rise until 2020. 

At that point, the rate of population growth will begin to decrease and level off. The DEIS 

acknowledges this projection and states that "high rates of population growth are anticipated 

from 2014 until 2018 and then level off after 2018." DEIS at 8-6. Moreover, BEBR produced a 

Florida Estimates of Population analysis in 2014. See http://tinyurl.com/BEBR2014. This 

analysis shows that the rate of population growth has decreased from 16.3% to 4.7% in MiamiDade County from 1990 to 2014. See id. at Table 3. The previous study suggests that this rate 

will continue to decline to 3.1% by the year 2040. Similarly, the SFWMD decreased water 

allocation from the Biscayne Aquifer in a 2015 water use permit for Miami-Dade County's Water 

and Sewer Department "due to water conservation measures and updated population 

projections showing a lower population growth rate through 2033." See SFWMD Individual Use 

Appendix E October 2016 E-387 NUREG–2176
Permit for MDWASD Permit Number 13-00017-W (Description 4-5). Thus, Miami-Dade County 

has updated its future demand projections with the availability of new population data, thereby 

reducing the total amount of water required to meet the needs of Miami-Dade County. 

Accordingly, the demand for power will likely decrease as the rate of population growth in 

Miami-Dade continues to decrease and then stabilizes over the coming decades. Therefore, the 

final Environmental Impact Statement should include a discussion of whether or not a decrease 

in the rate of population growth in Miami-Dade County will affects the projected demand for 

electricity. (0456-22 [Miami, City])

Comment: FPL's overall electrical energy demand· has stabilized and is very slowly 

increasing. With more focus on energy efficient appliances. LED/LCD tv's, Even cable/sat boxes 

are now being investigated, more efficient A/C, more thermal installation, etc. As electronics 

reduce chip feature size, power consumption decreases, modem tablets and cell phones 

consume a fraction of the energy of the devices they replaced. Air conditioners are now more 

efficient SEER 14 (Jan 1, 2015) minimum by law. Based on FPSC data for the period 2003 to 

2012, FPL's overall electricity sales increased 2.7% for that ten year period. Yet for the period 

2013 to 2022 FPL projects a 16% net sales growth! I would say FPL's projections are more than 

overly optimistic! Ref: Review Of The 2013 Ten-Year Site Plans For Floridas Electric Utilities, 

FPSC October 2013. Item 6 (loss of net metering) is omitted due to limited space. Complete 

version of letter attached in .pdf format. (0545-6 [Keating, Tim])

Comment: Also, as residential and commercial properties continue to generate excess daily 

power by solar energy systems, the utilities in the state will have less of a customer base to bill 

back as unique charges on their statements for overhead costs (power lines, etc.) resulting in 

significant increases to their customers over and above the costs of units 6 & 7. (0653-3 [Hickey, 

Alan])

Comment: I want to talk briefly about what George Cavros said about conservation. I've been 

able to conserve a lot. And I think when we talk about the need for these two power plants and 

the reliance on the PSC we -- that is pretty much a biased organization. I've been able to reduce 

my power usage significantly. I don't use any outdoor lighting. I turned off my hot water heater. 

People don't realize this, but most of South Florida originally did not use electric or gas water 

heaters, they used direct sunlight to heat their water. I currently use direct sunlight and it works 

very well. And when you talk about building these additional plants and you're talking about the 

need for this, you are ignoring --and you're ignoring how people can reduce their energy use, 

then the need assessment does not ring true. And I think that's very important. (0721-13-5

[Martin, Drew])

Comment: Each year the need for more capacity is deferred. It allows FP&L to choose to build 

lower cost, more modular resources such as solar power if efficiency cannot meet the entire 

load in over a decade. Unfortunately, FP&L forthcoming efforts over the next ten years, to help 

customers reduce energy use and save money on their bills through energy efficiency 

programs, is simply a national embarrassment. The [Florida Public Service Commission] PSC 

recently approved the company's request to gut its conservation goals. Now FP&L will meet only 

3/100ths of 1 percent of annual demand through energy savings. To put that in perspective. If 

FP&L were a state it would rank among the bottom, behind Alabama and Mississippi in energy 

savings for customers. And I have an illustrative chart which I can leave with you. (0721-8-4

[Cavros, George])

Response: The review team followed its Need for Power guidance found in NUREG-1555, the 

Environmental Standard Review Plan. Some of these comments generally suggest that the 

Appendix E NUREG–2176 E-388 October 2016
State's Determination of Need process implemented by the FPSC, upon which NRC relies 

pursuant to Section 8.4 of NRC's Environmental Standard Review Plan (NUREG-1555), is 

flawed, outdated, or relies upon faulty logic or assumptions. The FPSC process requires FPL to 

provide an annual update to its feasibility assessment of Units 6 and 7. The FPSC has 

approved the FPL process through its 2015 independent review of FPL's planning assumptions, 

cost estimates, feasibility analysis, and other considerations, which FPL must annually report to 

FPSC. New information regarding the planning assumptions and feasibility of Units 6 and 7 was 

made public through this process and updates have been made to Chapter 8 and Section 10.6 

of the EIS to reflect this new information. The FPSC's 2015 approval of Docket 15009 EI 

reaffirms the State's 2008 determination that Units 6 and 7 are needed and remain viable 

(FPSC 2015-TN4521). The review team reviewed the most recent FPSC proceedings in this 

regard and finds that the process for annually updating the feasibility and associated analyses 

was (1) systematic, (2) comprehensive, (3) subject to confirmation, and (4) responsive to 

forecasting uncertainty. Other comments in this set challenge the need for the two new nuclear 

units in favor of other sources of electricity, primarily conservation and solar power 

generation. These alternatives are discussed in detail in Sections 9.1 (No-Action Alternative), 

9.2.1 (Alternatives Not Requiring New Generating Capacity), and 9.2.3 (Other Alternatives). No 

changes were made to the EIS because of these comments. 

Comment: To make matters worse, FPL has not even committed to actually completing the 

project if approved! Why should Floridians support such a project? (0594-4 [Rapuano, Shannon])

Comment: Since, according to the Miami Herald, Florida Power & Light has not formally 

committed to building the two new reactors, I strongly recommend that NRC withdraw the 

current document, repair the citations, and reopen the public comment period. 

(http://www.miamiherald.com/news/local/community/miami-dade/article18627960.html) (0716-6

[Riccio, Jim])

Response: The decision about whether or not to build and operate a new nuclear units is 

made by the applicant in conjunction with State and local public regulators, not the NRC. The 

NRC’s responsibilities are to review the application according to its regulations outlined in 10 

CFR Part 52 and 51. No changes were made to the EIS as a result of this comment. 

Comment: As I understand it, FPL does not need these reactors for current use, but is 

planning for the future. Currently, I believe, they are intending to sell the excess power to more 

northerly climes. (0115-4 [Trencher, Ruth])

Comment: If there is going to be a monopoly in our electrical system, then it must be forced to 

adopt the policies which benefit the most people (taking externalities into account). If not, open 

up the market and allow for PPAs, the absence of which is squashing solar power in the 

"Sunshine State". (0119-3 [de Azevedo, Ricardo])

Comment: This high-voltage, aboveground power line proposes to distribute power to 

customers outside Miami-Dade County as well. Residents in the affected area are asked to 

accept the degradation of their communities so FPL can save a few, none-recurring dollars on 

placement. We pay FPL handsomely for the power they deliver. Now, we are asked to 

compromise safety, beauty and despoliation of the public landscape with tourism suffering 

permanent economic damage to aggrandize FPL's Retained Earnings. Moreover, who is willing 

to negate FPL intends to sell excess capacity to Georgia Power & Light via this aboveground, 

high-voltage power line? "Profit" is not a gritty word; however, it is a grimy word when spillovercosts are safety and permanent degradation of our communities. (0408-5 [Sifko, Basilio])

Appendix E October 2016 E-389 NUREG–2176
Response: These comments express concern about the dispatch of the nuclear power 

from proposed Units 6 and 7 to areas outside the Miami-Dade area. The allocation of the 

electricity generated to other markets is beyond the scope of the NRC's Need for Power process 

under NUREG-1555, Environmental Standard Review Plan. No changes were made to the EIS 

as a result of these comments. 

Comment: Cyndee, it is abundant electricity that makes our society the wonderful place that it 

is. It is unfortunate, because of the global warming scare, that underprivileged people around 

the world are not getting the opportunity to enjoy our level of abundance. (0680-4 [Hubbard, 

Stanley S.])

Response: This comment expresses support for nuclear power because of the standard of 

living it provides. No changes were made to the EIS as a result of these comments. 

E.2.23 Comments Concerning Alternatives - No-Action 

Comment: I request that both agencies support the "No Action" alternative in reference to 

Docket ID: NRC-2009-0337. (0104-2 [Commenters, Multiple])

Comment: SACE believes that the DEIS fails to adequately discuss and analyze these 

potentially adverse impacts and insufficient proposals for mitigation. As such, we recommend 

that the NRC and USACE support the "No Action" alternative. (0112-3 [Barczak, Sara])

Comment: I request that the Nuclear Regulatory Commission and U.S. Army Corps of 

Engineers support the "No Action" alternative. (0148-2 [Brinn, Ira])

Comment: I request that both agencies support the "No Action" alternative in reference to 

Docket ID: NRC-2009-0337. (0192-2 [Lebatard, David])

Comment: I request that the Nuclear Regulatory Commission and U.S. Army Corps of 

Engineers support the "No Action" alternative. (0379-2 [Commenters, Multiple])

Comment: I support the "No Action" alternative given the project's potentially widespread 

negative environmental and public health and safety impacts. (0379-7 [Commenters, Multiple])

Comment: I request that the Nuclear Regulatory Commission and U.S. Army Corps of 

Engineers support the "No Action" alternative. (0508-2 [Harrison, J. M. M.])

Comment: Along with probably more than 225 million Americans (i.e. 9 out of 10 Americans in 

recent surveys) who want more solar and wind power installed rather than more nuclear power 

and more than 20.236 million members and supporters of the supporting organizations listed 

below and more supporting organizations, I very strongly urge both agencies to please, right 

now, support the "No Action" alternative in reference to Docket ID: NRC-2009-0337. (0592-1

[Brexel, Sr., Charles])

Comment: We strongly oppose the expansion of Turkey Point and strongly urge both agencies 

to please, right now, support the "No Action" alternative in reference to Docket ID: NRC-2009-

0337. (0592-11 [Brexel, Sr., Charles])

Comment: NO ACTION! (0609-3 [Khajeh-Noori, Jeri])

Appendix E NUREG–2176 E-390 October 2016
Comment: Moreover, the NRC's reliance on the Florida Public Service Commission and its 

Orders and the State's Utility Resource Planning Process is badly misplaced. As such, we 

believe that the no-action alternative should be the Agency's preferred choice. (0721-8-2 [Cavros, 

George])

Response: The impacts of a no-action alternative are discussed in Section 9.1 of the 

EIS. Selecting the no-action alternative would mean a license would not be issued for the 

proposed reactor and impacts from its construction and operation would not occur. Such a 

decision would also mean, however, that the purpose and need of the proposed action (to 

provide additional baseload electrical generation capacity for use in the FPL service territory) 

would have to be satisfied by other means. The environmental impacts of meeting the need for 

power by these other means are discussed in Section 9.2, and the review team concluded that 

none of the feasible alternatives was environmentally preferable to the proposed action. The 

comments did not provide any information that would change the review team’s 

conclusions. Therefore, no changes to the EIS were made as a result of these comments. 

Comment: Executive Summary, Page xl, Table ES-4: In DEIS Table ES-4, "Summary of 

Environmental Impacts of Construction and Operation of New Nuclear, Coal-Fired, and NaturalGas-Fired Generating Units and a Combination of Alternatives", for the Socioeconomics impact 

category, the environmental impact levels for coal, natural gas, and combination of alternatives 

are inconsistent with their corresponding impact levels in DEIS Subsection 9.2.2.1, page 9-15, 

Table 9-1; Subsection 9.2.2.2, page 9-21, Table 9-2; Subsection 9.2.4, page 9-29, Table 9-3; 

and Subsection 9.2.5, Page 9-30, Table 9-4. In the case of natural gas, the impact level is listed 

as "MODERATE (beneficial)" in DEIS Table 9-2 and "SMALL (beneficial)" in DEIS Table ES-4. 

For the combination of alternatives, the impact levels for beneficial and adverse are reversed. 

For coal, both beneficial and adverse are MODERATE in DEIS Table 9-1; however, in DEIS 

Table ES-4, the impact level for beneficial is listed as "SMALL (beneficial)". (0619-2-17 [Maher, 

William])

Response: The tables in the Executive Summary and Section 9.2 were edited to correct the 

inconsistencies noted in the comment. 

E.2.24 Comments Concerning Alternatives - Energy 

Comment: We are very susceptible to hurricanes, the last thing we need is 2 more nuclear 

reactors near us. Why can't FPL invest in solar energy to help them meet the demand of energy 

that is needed? It comes down to greed. They think about the money and not about the lives 

they are putting at risk. (0003-2 [Ortiz, Natalia])

Comment: I urge you to instead invest the money in more environmentally sustainable, 

renewable energies. (0004-2 [Engelberg, Jodi])

Comment: Put up wind farms, require all new construction to incorporate solar like France is 

doing. Get a bunch of catfish to eat up the algae bloom and tell people to stop blasting their AC 

24/7 and opening retail store doors to cool the sidewalk. (0008-13 [Finver, Jody])

Comment: A determination of FPL's application should be done in as sober a manner as 

possible by weighing the facts. The Greater Miami area has a population of some six million 

people from Miami to Palm Beach. The prime consideration behind any decision should be the 

safety and welfare of all of these people. With the abundance of sunshine that South Florida 

has, it seems clear that clean, safe renewable energy should be pursued rather than a 

Appendix E October 2016 E-391 NUREG–2176
technology that has a history of catastrophic accidents (Three Mile Island, Chenobyl, 

Fukushima, to name a few). (0009-4 [Rose, Simon])

Comment: The NRC Failed to Consider Solar Power Energy Alternatives: The solar power 

industry is extensive in the United States and the associated installation costs have dramatically 

decreased over the years. Moreover, the efficiency of solar power generating systems have 

dramatically increased over that same time period. Moreover, a customer of FPL can "lease" an 

entire home solar energy system without paying any upfront costs or maintenance costs. These 

solar energy systems can power an entire home and supply FPL's grid with excess power not 

consumed by the customer. (0010-6 [Saporito, Thomas])

Comment: We need more renewable environmentally safe power and educate power 

consumers to use more efficient electrical devices. (0012-2 [Shahsavar, Mehran])

Comment: Now is the time to invest in solar, wind, and wave energy. (0014-2 [Westaway, 

Katharine])

Comment: The multi 100M-dollar corporation that is FPL, absolutely MUST be employing solar 

and wind energy. Conservation, solar & wind are the only way to succeed in living in harmony 

with nature. Nature -upon which ALL life depends. (0020-2 [Smith, Leigh Emerson])

Comment: Non Nuclear generation of power by solar, tidal current, wind or geothermal 

methods have no such dangers.or consequences to our life on Earth, which should be a primary 

consideration in these decision making times. Even natural gas is less expensive and available 

to accomplish the same goals with less adverse consequences. Florida is blessed with sun and 

wind as well as the constant Gulf Stream current. Let us take advantage of what we have to our 

greatest advantage and create the least damage with all our renewal resources. (0021-2 [Silver, 

William])

Comment: FPL should be denied a license for Turkey Point expansion for many reasons: 1. 

Too expensive. Nuclear power is much more expensive than solar (0022-1 [Read, Alice Gray])

Comment: FPL should be denied a license for Turkey Point expansion for many reasons:...6. 

Conservation first. Miami could conserve much more than it does. Most important: Distributed 

rooftop solar should be top priority for electricity generation. It's cheap, clean, safe, efficient, 

reliable, and resilient in disasters. No excuse not to make the sunshine state generate all it's 

power from the sun. All that's needed is efficient energy storage. (0022-6 [Read, Alice Gray])

Comment: In fact, we need to build renewable energy power plants such as wind, solar, etc. so 

that we can dismantle every single one of our nuclear reactors before they destroy our 

civilization. (0023-2 [Joannou, Jr., Benjamin])

Comment: In the face of climate change, what we really need is clean, safe, and affordable 

renewable energy along with energy efficiency and conservation that will not endanger our 

health, environment, or future. We do NOT need more nuclear plants. Invest in renwables.We 

live in the Sunshine state...solar...solar...solar. (0026-1 [San Pedro, Patricia])

Comment: I would prefer FPL focus their efforts and money on true clean energy, like solar 

and wind. (0027-1 [Neal, Kevin])

Appendix E NUREG–2176 E-392 October 2016
Comment: Our community needs to consider electricity savings, and sustainable energy 

sources such as wind and tide, rather than relying on nuclear sources. (0032-2 [Vinciguerra, 

Anthony])

Comment: The Sunshine State and the Government of the United States should invest in solar 

energy rather than on obsolete and dangerous nuclear plants. Nuclear energy plants pose a 

threat to the environment and to the population that resides near the plant. History proves the 

dangers of nuclear energy production with examples such as Chernobyl and Fukushima. 

Catastrophe can be prevented by investing in solar energy. (0033-2 [Van Thienen, Mateo])

Comment: Although, I understand that population growth in South Florida has gone up year 

after year but I don't believe that all other alternative power sources have properly 

been explored and should be prior to this application being approved. (0034-2 [Rodriguez, 

Barbara])

Comment: I know this is a difficult decision to make but looking at all the alternative 

possibilities as to how to supply our community with power for years to come is definitely 

needed. (0034-4 [Rodriguez, Barbara])

Comment: We live about six miles from Turkey Point.. I don't go to bed at night wondering if 

the system will go bad but I do think about the possibilities once in a while. I did know TP was 

there when I bought my second house in this area and I am not opposed to this kind of 

energy. However, I am strongly opposed to the stand that Florida's big energy firms have taken 

on solar energy. Florida is the sunshine state, it says everywhere we go.. Yet we are behind 

many northern states in encouraging solar as a serious power source and I feel that is mostly 

due to FPL and Duke doing everything they can to keep solar out of this state. Some companies 

are offering to lease panels to homeowners which is being opposed by our energy firms in this 

state. If there is a cleaner, cheaper way to produce electricity I have not heard of it.. It should be 

everywhere in this state. We should set the pace for the entire country. (0036-1 [DeMent, David 

L.])

Comment: And why, with solar and wind power already economically competitive, should we 

be building any new power plants that have so many problems when wind and solar do not?

(0037-2 [Schoene, William])

Comment: Given the advent of viable, lower cost, and benign alternative power generating 

technologies such as wind and solar, the risks associated with the expansion of Nuclear Power 

in South Florida far outweigh any possible benefits that may be derived. As the world moves 

toward ecologically sound and renewable alternative power technologies, I believe it is 

contingent upon FP&L to do likewise. FP&L should not resist change, but embrace it. It is in the 

interests of FP&L's shareholders, customers and a healthier, safer world to do so. (0039-4

[Violich, Francesca])

Comment: Given the advent of viable, lower cost, and benign alternative power generating 

technologies such as wind and solar, the risks associated with the expansion of nuclear power 

in South Florida far outweigh any possible benefits that may be derived. (0043-2 [Grill, Helen])

Comment: With the advent of viable, lower cost, and benign alternative power generating 

technologies such as wind and solar, the risks associated with the expansion of Nuclear Power 

in South Florida far outweigh any possible benefits that may be derived from the proposed 

Nuclear Power Plants at Turkey Point. As the world moves toward ecologically sound and 

renewable alternative power technologies, I believe it is essential that FP&L follow such 

Appendix E October 2016 E-393 NUREG–2176
established examples of viable and safe utility scale energy production. Times have changed 

and technologies have advanced since the inception of the Turkey Point facility. The changes 

and advancements in viable power generating technologies have been even more dramatic 

within the 9 years that FP&L has pursued this goal of expanding the nuclear facilities at Turkey 

Point. FP&L should not resist change, but embrace it. It is in the interest of FP&L's 

shareholders, customers, the residents of Miami-Dade County, the residents of the State of 

Florida, and a healthier, safer world, to do so. (0044-8 [Commenters, Multiple])

Comment: Why aren't solar farms being considered rather than nuclear power? FPL has done 

more than any other company in the state to prevent the growth of solar power energy. This is a 

much safer way to meet the growing demand for more energy. (0048-3 [Wegner, Geri])

Comment: Worse yet, the cost of the proposed expansions will never be realized by 

production, as already better, safer, and cheaper modes of energy production abound and the 

technological increases during just the construction phases of this project will make it obsolete.

(0051-3 [Smith, David W.])

Comment: We should be moving away from nuclear energy and toward more environmentally 

friendly sources like sun (hello, this is FLORIDA!), wind and ocean current. (0052-2 [Roos, 

Monica])

Comment: Let's talk cost. Before billions are spent to build new reactors way far south of the 

points of use and the transmission lines to carry that power north, we must demand that Florida 

Power and Light investigate solar panels on all large flat roofs in the urban areas to produce 

power at the point of use and negate the need for both the reactors and transmission lines to 

get the power where it is needed. I contend the cost will be levels of magnitude LESS than two 

nuclear reactors. (0053-3 [Sasiadek, Alfred])

Comment: Florida is the "Sunshine State". We need to use the resources that nature provides 

us here to save money and save our environment at the same time. I ask you to consider the 

consequences and alternative to any decision. (0053-5 [Sasiadek, Alfred])

Comment: Encourage Florida Power and Light to invest in renewable safe energy sources for 

the good of all. (0057-6 [Neway, Roberta])

Comment: It is time we switched to renewable, environmentally responsible energy production 

in the Sunshine State! (0058-2 [Imbesi, Nan])

Comment: We need more solar and wind. (0063-2 [Smay, Betty])

Comment: And last, I would suggest that you ask FPL to allow homeowners to sell their solar 

generated power back to the grid so that, over time, we can use our sunshine to our advantage. 

This is a long term goal that many people are arguing now as the solution to nuclear power. But 

I do not want to spend my retirement years sitting in darkness waiting while the solar and wind 

industries mature to the point that they can provide the electricity necessary to power 3 million 

people's needs. (0070-4 [Lamb, Deborah S.])

Comment: FPL is developing solar power too, but they are doing a teeny tiny fraction of what 

they could be doing. While 95% or more of their advertising and PR is devoted to promoting 

how much solar development they're doing, they are actually generating less than 1/10 of 1% 

(that's 0.01%) of their electricity through solar power. I know, I'm a customer and I read the 

Appendix E NUREG–2176 E-394 October 2016
brochures that come with my bills each month, and see the commercials on TV! Look at the 

graphs in their brochures and it's obvious! I brought the brochure that came with my February 

2015 bill (see below) if you want to see it in their own words, in black and white - or rather green 

and white. But printing the info in green doesn't make what FPL is doing green - unless the 

green you're talking about is cash. (0078-11 [Wilansky, Laura Sue])

Comment: With so many truly clean, safe, renewable and sustainable technologies now 

available and in development, there is no reason to build new nuclear plants, which will only 

drain much-needed resources from full development of better, safer technologies. We will get 

much better value and results from investing in these technologies. This is THE SUNSHINE 

STATE! We should be leading the nation, heck, the world in solar development! Instead we rank 

13th in total installed solar, and 20th in solar installed in 2014. It' time to end the use of all 

nuclear power, and put ALL - ALL! of our resources into truly safe, clean and sustainable 

technologies like conservation, solar, wind, geothermal and others, which absolutely can, and 

will supply all the energy the state, and the world needs, without destroying the world in the 

process. (0078-13 [Wilansky, Laura Sue])

Comment: Finally, in the "Sunshine State" it is unforgivable that we are discouraging solar 

energy utilization. FPL is against this solely for financial reasons! Please consider the 

responsible future for Florida power!! (0080-3 [Reiter, Ben])

Comment: FPL should be looking to better renewable resources of energy instead of investing 

OUR money into an antiquated, dirty and very risky system. (0087-5 [Lange, Alexandra])

Comment: I would like to see our local government to explore other sources of energy. Eolic, 

Solar, even in very underdeveloped countries are using these technologies today. (0088-3

[Lange, Alexandra])

Comment: Given the falling prices of solar power and new batteries, we question the wisdom 

of committing customers to $20 billion worth of last century's technology, while closing the door 

on cheaper, safer and more environmentally responsible options. (0088-6 [Lange, Alexandra])

Comment: WHY ARE WE NOT GOING TOWARDS SOLAR POWER, particularly in 

FLORIDA??? (0089-2 [Hubler, Gina Marie])

Comment: FPL should be looking to better renewable resources of energy instead of investing 

OUR money into an antiquated, dirty and very risky system. (0092-3 [Merino, Miriam])

Comment: I recommend that you disapprove any further processing of their Turkey Point 

Nuclear Power plant expansion proposal for the reasons summarized below2)The proposal is 

not the most environmentally acceptable alternative. FPL has not adequately evaluated other, 

more cost-effective alternatives to produce electrical energy which do not add the risk of nuclear 

waste storage at a highly flood and wind prone site. Alternatives for new energy production 

abound, but were not evaluated based on the falling prices of solar power due to the 

introduction of new battery technology. Furthermore, FPL has not evaluated other alternatives 

including energy conservation and efficiency, at one-fifth the cost of new nuclear power 

generation, thereby concealing how those alternatives, with conservation included, would cost 

less and have far less public health and hurricane damage risk than this proposal. This $20 

billion project you could only approve by ignoring or deliberately hiding the fact that better, 

cheaper, safer and more environmentally acceptable alternatives to new power production are 

available now or in the near future for Southern Florida. (0094-2 [Fairchild, David])

Appendix E October 2016 E-395 NUREG–2176
Comment: I recommend that you disapprove any further processing of their Turkey Point 

Nuclear Power plant expansion proposal for the reasons summarized below6)Finally, the 

proposal assumes that future growth in demand for electricity must be supplied from the grid. 

Rapid evolution in the technology needed to locally generate power from solar, wind and wave 

sources, together with scalable on-site battery storage make that assumption obsolete. The 

basic justification for this project is a dubious need for large amounts of grid delivered power. 

That justification must now be reassessed in light of current or soon available new technologies 

enabling local, non-grid based power generation. (0094-6 [Fairchild, David])

Comment: FPL has the opportunity to use wind or solar energy because it a perfect way to 

generate power without negatively impacting the National Parks, Preserves and Sanctuaries in 

our eco-sensitive area. (0096-3 [Roberts, Linda])

Comment: FP&L has bribed the Florida Legislature to block the expansion of solar here in the 

Sunshine State by blocking net metering. Nuclear is unprofitable, existing only with rate payer 

and tax payer subsidies. (0097-2 [Geary, Craig W.])

Comment: Please consider other sources of renewable energy instead of a nuclear plant. Our 

environment is not the best suited for these type of project. (0101-2 [Gomez, Gustavo])

Comment: There are other energy choices that don't pose such risks, which are not properly 

studied in the draft Environmental Impact Statement. Solar power has dropped in price and 

improved in quality whereas new nuclear reactors continue to increase in cost and have yet to 

actually be built. Energy efficiency is the lowest cost resource in meeting electricity demand--

many times less expensive than these reactors that are approaching $20 billion. Yet, FPL is 

doing almost nothing to expand energy efficiency or renewables, which are viable alternatives, 

nor is the Florida Public Service Commission making decisions that will expand these safer, 

more affordable options. Y our agencies should not rely on their flawed utility planning process.

(0104-3 [Commenters, Multiple])

Comment: I would much rather see them invest in solar power rather than anymore nuclear.

(0114-3 [Cunningham, Sue])

Comment: They have invested very little into solar energy or other renewable sources of 

energy, sources that do not have the potential problems of a nuclear facility; storage of waste, 

leakage, breakdown of various elements of the system. (FPL does not encourage the use of 

solar power on homes and businesses, and, together with Duke Energy, has convinced the 

Florida legislature to make it illegal to sell excess power created through solar collectors.

(0115-5 [Trencher, Ruth])

Comment: Our community (other than those who have FPL stock) is concerned and would like 

responsible, alternative sources of energy (e.g., SOLAR) to be implemented. (0116-2 [Garcia, 

Ruslan])

Comment: By the time construction is complete alternative energy will have become much 

cheaper and safer than nuclear (0118-2 [Zakon, Allan])

Comment: They should invest in solar energy. FPL's parent company produces way more 

solar energy in other states, so it has the capability, knowledge and expertise to do expand 

solar energy in Florida. It chooses not to because of Florida's weak laws on solar energy. 

(0121-2 [Reyneri, Juan])

Appendix E NUREG–2176 E-396 October 2016
Comment: We need solar and wind, sustainable solutions. (0124-2 [Colby, Helen])

Comment: This expansion would cause a lot of harm in our community. I support alternative 

forms of energy that are less harmful to the environment. (0125-2 [Colls, Ana])

Comment: Why can't FPL consider championing solar (we are the "sunshine state"), wind or 

hydro energy? (0128-3 [Bach, Lili])

Comment: We are totally opposed to the expansion of nuclear generated energy at Turkey 

Point -- for the following reasons.....4) I would rather FPL spend the money on solar and wind 

generation. (0129-4 [Mayer, Doug])

Comment: [C]ould you find a better location for more solar and wind power than South Florida. 

Wake up please! Save what is left of our environment.! (0131-2 [Brown, Judith O.])

Comment: I herewith want you to note my objection to FPL's planned new nuclear power 

plans - a dangerous and superfluous proposition, given....the fact that we have plenty of solar 

energy opportunities in Florida! (0135-2 [Thiel, Markus])

Comment: I am writing today from my home to oppose the approval of FPL's two nuclear 

power at Turkey Point for the following reasons....3. Conservation is by far less costly and 

productive as is being demonstrated by South Dade Farmers in water conservation with the use 

of drop irrigation and the use of compost and mulch that hold water and require less irrigation. 

All energy conservation measures must be implemented now, not more costly nuclear power. 

Utilize and subsidize more solar power that is making great strides towards becoming more 

affordable every year. We advertise on our license plates that Florida Is The Sunshine State yet 

present laws restrict the use if our ever-present Sun to be used for power. We must not commit 

ourselves to this new nuclear power for 60 years when clean solar energy is being wasted as it 

is showered over us every day. (0136-3 [Levy, Morgan I.])

Comment: I am writing today from my home to oppose the approval of FPL's two nuclear 

power at Turkey Point for the following reasons....4. My family has stock in FPL and we are 

against spending the $20 million on old technology that will be paid for by its customers. As a 

stock holder, we would prefer that FPL use whatever financial resources are necessary to get 

our lawmakers in Tallahassee to make solar energy available to every household and 

commercial building with the latest technology in batteries that can make solar power available 

24 hours a day. (0136-4 [Levy, Morgan I.])

Comment: There are other energy choices that don't pose such risks, which are not properly 

studied in the draft Environmental Impact Statement. Solar power has dropped in price and 

improved in quality whereas new nuclear reactors continue to increase in cost and have yet to 

actually be built. Energy efficiency is the lowest cost resource in meeting electricity demandmany times less expensive than these reactors that are approaching $20 billion. Yet, FPL is 

doing almost nothing to expand energy efficiency or renewables, which are viable alternatives, 

nor is the Florida Public Service Commission making decisions that will expand these safer, 

more affordable options. Your agencies should not rely on their flawed utility planning process.

(0141-2 [Lucas, Carmen])

Comment: With an abundance of sunshine, our first and best alternative for energy production 

should be solar. It's time the public be given a chance to install affordable, dependable solar 

Appendix E October 2016 E-397 NUREG–2176
equipment. Allow tax credits to everyone who can help lower our usage of depleting the worlds 

reserves. Stop acting in the best interests of what is good for business. (0146-5 [Grant, Randy])

Comment: This would approve old technology. We need new progressive forms of energy like 

wind and solar. This is the Sunshine State!! Why spend money on old technology? (0149-6

[Nelson, Joyce E.])

Comment: It will devastate our already weak political will in Florida for more sustainable 

energy policy. (0150-2 [Otis, Martha])

Comment: The nuclear expansion at this particular juncture, at this particular location, puts 

Everglades restoration in jeopardy; it consistutes a costly and short-sighted energy policy, 

especially considering the viability in Florida of alternatives such as solar and wind--both 

cheaper options. (0150-3 [Otis, Martha])

Comment: Let's put our money and resources in sustainable energy--we live in the Sunshine 

State! We should be the leader in solar energy development and use. The technology is here--

use the money proposed for Turkey Point expansion to give subsidies to residents and 

businesses for solar energy and we won't need more nuclear power! (0152-1 [Agler, Mindy])

Comment: This investment of more than 20 billion dollars of the rate-payers money makes no 

logical sense. FPL should drop this risky project and instead embrace a solar alternative that the 

company knows its customers want. Solar contains virtually none of the risk of the proposed 

projects and will contribute to both the ecological ans economic sustainability of our region for 

years to come. (0153-4 [Goldman, Emanuel])

Comment: What happened to Solar Power? We are the Sunshine State. (0159-6 [Bazzone, 

Barbara])

Comment: It's time to exercise environmental responsibility and fast track development of 

Solar, Wind, and Water powered energy as well as electric and solar powered automobiles!

(0170-2 [Ercole, Steven])

Comment: Instead, we really need to practice more energy conservation and embrace 

renewable forms of energy especially solar energy in the Sunshine State. (0178-5 [Almirola, 

Alejandro])

Comment: The future is in renewable energy, not in foolhardy archaic nuclear technology that 

is environmentally hazardous for thousands of years. (0183-2 [Piper, Cynthia])

Comment: We need to more actively provide safe energy, not expand the dangerous, 

destructive use of nuclear power! (0185-2 [Balog, Nancy])

Comment: No need for more nuclear energy, we need solar panels in Florida. (0190-1 [Johnson, 

Robert])

Comment: There are other energy choices that don't pose such risks, which are not properly 

studied in the draft Environmental Impact Statement. Solar power has dropped in price and 

improved in quality whereas new nuclear reactors continue to increase in cost and have yet to 

actually be built. Energy efficiency is the lowest cost resource in meeting electricity demandmany times less expensive than these reactors that are approaching $20 billion. Yet, FPL is 

doing almost nothing to expand energy efficiency or renewables, which are viable alternatives, 

Appendix E NUREG–2176 E-398 October 2016
nor is the Florida Public Service Commission making decisions that will expand these safer, 

more affordable options. Your agencies should not rely on their flawed utility planning process.

(0192-3 [Lebatard, David])

Comment: Renewable energy alternatives such as solar and wind power, should be the only 

types of energy production to be built starting now. (0194-2 [Mayotte, Monica])

Comment: However, the risks associated with nuclear power are completely avoidable 

because alternatives are available. From improving energy efficiency to increase use of 

renewable energy sources, we don't need to invest $20 billion into a technology that no one 

wants in their backyard. (0207-3 [Cleland, Noel])

Comment: Being in South Florida, we feel that solar power would be a much better choice.

(0212-4 [Ross, Robert and Teresa])

Comment: I suggest that instead of allowing a company to charge me more for electricity and 

the building of nuclear reactors that I don't even want, the government seriously reconsiders 

policies on energy to keep up on the times. Models can be found all around the world, including 

Germany which currently subsidizes cleaner energy initiatives, allowing them to become the 

forerunners of innovation and manufacturing in cleaner energy. When these antiquated energy 

sources run out, they'll be selling us the equipment to change our state. Why can't Florida 

become the centre of clean energy technologies? Why do we have to pander to a for-profit 

company? (0214-7 [Zerulla, Tanja])

Comment: Also, at a time of tremendous clean energy and battery advancement, to make a 

long term, huge financial commitment doesn't make sense. (0215-1 [Atler, Neal])

Comment: I am an FPL customer, and this proposal is idiotic. There's plenty of solar power 

potential in south florida! (0218-1 [Barlow, Jeffrey])

Comment: Instead, the state of Florida should be encouraged to go solar. (0219-1 [Clay, 

Cynthia])

Comment: Let's invest our money in renewables instead of something that will eventually 

destroy us. (0231-2 [Bonilla-Jones, Carmen Elisa])

Comment: You need to approve solar and wind power plants not nuclear. (0231-4 [BonillaJones, Carmen Elisa])

Comment: We live in the "Sunshine State" but FPL's commitment to renewable energy has 

been very weak. FPL under-performs on solar power, generating less than 1/10 of 1% (0.01%) 

of its electricity through solar power. Given that solar power helps meet peak demand, and 

power plants are built meet peak demand, meaningful investment in solar would be a step in the 

correct direction and defer the need for the proposed Turkey Point nuclear reactors, which are 

very expensive, take a very long time to construct, increase greenhouse gases during 

construction and are very detrimental to ratepayers. (0237-1 [Welber, Michael])

Comment: What you need is to switch to solar power, please!!!. (0238-2 [Padilla, Dora])

Comment: On a final note - this investment of more than 20 billion dollars of the rate-payers 

money makes no logical sense. Solar power was not considered a viable alternative by the NRC 

reviewers - even though no state in the eastern half of the U.S. has the solar potential of Florida 

Appendix E October 2016 E-399 NUREG–2176
- also known as the Sunshine State. And in spite of all the advertising they do on the topic - 

FPL's actual solar production of less than 1/10th of 1 percent of its "energy portfolio" leaves 

much to be desired. With initiatives like third party rooftop solar coming online soon (and more 

about the "Floridians for Solar Choice" project in a future email), FPL should drop this risky 

project and instead embrace a solar alternative that the company knows its customers want. 

Solar contains virtually none of the risk of its proposed Turkey Point expansion and will 

contribute to both the ecological and economic sustainability of our region. (0240-13

[Commenters, Multiple])

Comment: That money can empower so many Florida homes with solar power as well as 

businesses public buildings etc. (0241-2 [Portuondo, Pilar])

Comment: I am opposed to granting FPL permission to build two new reactors at Turkey Point. 

Now is the time to look at sustainable energy, not to endanger or future. (0242-1 [Colby, Helen])

Comment: There are other choices for clean, safe energy, without dangerous toxic waste that 

will be present for years. (0243-3 [Duran-Pinzon, Jaime])

Comment: Say yes to solar energy. (0243-5 [Duran-Pinzon, Jaime])

Comment: Say no to expansion into nuclear energy...look to solar expansion for the sunshine 

state (0248-1 [Kadis, Patricia])

Comment: I would suggest to you that Florida, the Sunshine State, follow the lead of Spain 

and Germany whose solar energy is world renown and they are not located in a subtropical 

country where there is an abundance of sunshine. (0250-5 [Fulks, Anna Louise])

Comment: Solar roofs would feed residential and commercial needs, with peak power 

occurring with peak demand, when the heat of the day increases air conditioning loads. Current 

generators could be installed off Miami Beach, providing for the demands of resorts, hotels and 

restaurants. The party never stops? No problem, the Gulf Stream flows 24/7. Why are these 

solutions not being implemented? FPL has virtually blocked residential rooftop solar by 

manipulating regulatory mechanisms of government. (0252-16 [Van Leer, Sam])

Comment: This public money will be used to expand Turkey Point. Instead, the money should 

be either refunded to the people who paid it, or used by others to research or install alternative 

energy. (0252-18 [Van Leer, Sam])

Comment: We have wind and solar power that are environmentally safe and will not kill 

people. (0256-2 [Myers, B. J.])

Comment: And it is shocking that the powers that be never even considered alternative energy 

such as Solar! It is long past time to make he Sunshine State the Solar Power State! (0259-5

[Lettieri, Tammy])

Comment: Solar power should be first considered as a viable alternative by the NRC 

reviewers. Solar contains virtually none of the risk of the proposed Turkey Point expansion and 

solar will contribute to both the ecological and economic sustainability of our region for years to 

come. Florida has huge solar potential - known as the Sunshine State. FPL's actual solar 

production of less than 1/10th of 1 percent of its energy portfolio & leaves much to be desired. 

Appendix E NUREG–2176 E-400 October 2016
With initiatives like third party rooftop solar, FPL should drop this risky project and instead 

embrace a solar alternative that the company knows its customers want. (0260-1 [Ferro, Colleen])

Comment: With the advent of viable, lower cost, and benign alternative power generating 

technologies such as wind and solar, the risks associated with the expansion of Nuclear Power 

in South Florida far outweigh any possible benefits that may be derived from the proposed 

Nuclear Power Plants at Turkey Point. As the world moves toward ecologically sound and 

renewable alternative power technologies, I believe it is essential that FP&L follow such 

established examples of viable and safe utility scale energy production. Times have changed 

and technologies have advanced since the inception of the Turkey Point facility. The changes 

and advancements in viable power generating technologies have been even more dramatic 

within the 9 years that FP&L has pursued this goal of expanding the nuclear facilities at Turkey 

Point. FP&L should not resist change, but embrace it. It is in the interest of FP&L's 

shareholders, customers, the residents of Miami-Dade County, the residents of the State of 

Florida, and a healthier, safer world, to do so. (0263-5 [Orzechowicz, Holly])

Comment: Solar power was not considered a viable alternative by the NRC reviewers - even 

though no state in the eastern half of the U.S. has the solar potential of Florida - also known as 

the Sunshine State. And in spite of all the advertising they do on the topic - FPL's actual solar 

production of less than 1/10th of 1 percent of its "energy portfolio" leaves much to be desired. 

With initiatives like third party rooftop solar coming online soon (and more about the "Floridians 

for Solar Choice" project in a future email), FPL should drop this risky project and instead 

embrace a solar alternative that the company knows its customers want. Solar contains virtually 

none of the risk of its proposed Turkey Point expansion and will contribute to both the ecological 

and economic sustainability of our region for years to come. (0264-6 [Dwyer, John P.])

Comment: Have you checked out solar? Prices are way down. Using solar during the day time 

peak-use periods would absorb enough load to make the existing facilities more than adequate. 

Battery storage is getting cheaper, too, although not cheap enough to go 100% solar this year. 

(Maybe in five to ten years...) The maintenance expenses for solar are minimal, the safety factor 

is high, and decommissioning a solar plant, should that happen, is not dangerous or expensive.

(0265-2 [Bennett, Robbie])

Comment: It is beyond me how it is obvious that our best source of power is solar. SUNSHINE 

STATE. It is a no brainier that investing in solar power technologies would take us into the future 

and the forefront of implementing the use of solar power in our state. I am sure FPL can 

absolutely afford to take this on and spend the $ on this totally renewable and clean energy 

resource.I support use of Solar Power. (0268-1 [Inguanzo, Maria])

Comment: Other methods of energy generation need to be explored and developed as well as 

more energy conservation awareness and education. (0269-2 [Gomez, Christian])

Comment: CLEAN ENERGY production options for South Florida such as SOLAR ENERGY 

should take priority over more risky options. We appreciate the attention given to our citizen's 

concerns about energy producing options. (0272-3 [Zuniga, Family])

Comment: This utility is victimizing Miami residents in the following ways:--blocking attempts 

by entrepreneurs to produce cost effective solar power. (0283-3 [Compel, Jr., Joseph])

Appendix E October 2016 E-401 NUREG–2176
Comment: It is ridiculous that one of the sunniest states in the United States is far behind 

states with less solar availability in the development of renewable solar energy. (0283-5 [Compel, 

Jr., Joseph])

Comment: If Florida Power & Light Company is as technically proficient as it advertises, it 

should be required to develop more solar energy[.] (0283-6 [Compel, Jr., Joseph])

Comment: 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. (0288-10 [Cleland, Noel] [Jackalone, 

Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, 

Jonathan])

Comment: 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) (0288-13 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] 

[Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: 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.

(0288-16 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, Rhonda] 

[Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: We need a focus on green energy, not high risk nuclear energy. (0294-1 [Howell, 

Carol])

Comment: WE NEED TO GO TO WIND, SOLAR, GEOTHERMAL and other RENEWABLE 

sources of energy (0302-1 [Jezierski, Elisabeth])

Comment: I wish to express my concern over the expansion of the Turkey Point Nuclear 

Power Station. I don't agree with the reasons for the expansion and I feel we should begin 

moving in a more positive direction with solar, wind and water generated renewable energy 

sources. (0313-1 [Fecteau, Lynn])

Comment: Now is the time move toward green energy! Invest your exspnsion in solar!! Novel 

idea?? This is 2015! Move forward!!! (0315-1 [Johnson, Kay])

Comment: Inexplicabley, our state legislature and our governor have been creating obstacles 

to solar power instead of encouraging its use. (0317-1 [Detrick, Mary])

Comment: The sunshine state is burgeoning with solar and wind energy!!! (0322-1 [Smith, Leigh 

Emerson])

Comment: Please look more closely at energy efficiency and renewables to meet the projected 

need for our state. The Sunshine state can, and must, do better than expanding risky, water 

intensive, expensive nuclear energy. (0323-4 [Jennings, Cara])

Appendix E NUREG–2176 E-402 October 2016
Comment: Go wind and solar!!!!!!!!! (0325-1 [Hollister, David])

Comment: [T]here are other safer options available for generating power. (0329-4 [Baumwall, 

Douglas])

Comment: The owners and operators of Turkey Point have no right whatever to hold the 

million people of this metropolitan area hostage and to cause them to live in a state of perpetual 

fear for the owners' business profit, particularly as there are a number of perfectly safe 

alternatives to nuclear. I believe a referendum is in order that asks the question, "Would you 

prefer to decommission the Turkey Point nuclear plant and replace it with a plant that utilizes a 

non-nuclear power source?" (0332-2 [Ross, Sherwood])

Comment: We need alternatives ... and the Nuclear option shouldn't be one of them: especially 

not with the issues they are having today with only two (and the poor way in which they are 

dealing with it.) (0334-5 [Crystal, Chris])

Comment: Solar or wind is the only way to in this future and FPL should be concentrating 

heavily on offering the public real options to this renewable energy in our SUNSHINE state. 

(0340-7 [Tweeton, Tanya])

Comment: I find it even more troubling that the same utility company that is hoping to expand 

the size and extend the life of this aging nuclear power plant, FPL is behind lobbying efforts to 

keep domestic rooftop solar power from competing in Florida. We should examine this entire 

picture and think carefully about the consequences. (0342-3 [Merleaux, Derek])

Comment: I live and work full-time in the Florida Keys. The irony of this controversial nuclear 

initiative is that we live in 'The Sunshine State.' We are being out-flanked by many other nations 

in sustainable energy production. This is wrong and is not permissable in a civilized world. 

Choose wisely and don't make us shut you down. Switch to solar and your company will have a 

future in our fast-growing green economy. Otherwise, Turkey Point, you will be left 

behind. (0344-1 [Hull, Meagan])

Comment: We have to much solar to use and never ends. (0348-2 [Ward, Richard])

Comment: Aside from the absolutely unacceptable, (and I would say immoral) risks to human 

and natural ecosystem health, nuclear plants are not competitive with alternate forms of energy, 

including renewable ones. (0355-2 [Thomas, Bill])

Comment: Safe home energy generation via technologies such as those developed by the 

Tesla Corp. will reduce the need for power generation from utility company plants. (0356-16

[Shlackman, Jed])

Comment: With rapid advances in technology and possible release of previously suppressed 

methods of clean energy generation, adding additional nuclear facilities seems foolish and 

shortsighted. (0356-4 [Shlackman, Jed])

Comment: We have lots of sunlight going unused. (0357-2 [Shapiro, Eugene])

Comment: This is the Sunshine State. -focus on developing solar energy. (0359-4 [LoBiondo, 

Roana and Michael])

Appendix E October 2016 E-403 NUREG–2176
Comment: By TAKING and USING more and more without considering sustainability of our 

planet we will inevitably run out of resources to take. Being responsible for our actions by 

treating nature and our precious resources that sustain us with respect will allow ecosystems to 

react and recover to development which has ALREADY encroached the area. (0362-5 [Hurley, 

Paula])

Comment: There are so many methods of renewable energy production that are clean, 

environmentally friendly, and affordable for our infrastructure. (0363-2 [Peters, Emily])

Comment: FPL should be focusing on solar energy, rather than more nuclear reactors. We live 

in The Sunshine State, and yet our State is behind Georgia in the implementation of solar 

energy. (0365-9 [Fischer, Antoinette])

Comment: [Commenter included Attachment: The 1st Millennium Renewable and Sustainable 

World Energy Prognosis - supporting TurboGreenTM Energy and Advanced Technology 

Industries Inc.- several pages supporting alternative energy] (0369-2 [Polk, J. D.])

Comment: We need to be developing Solar and other forms of renewable energy. (0371-5

[Haffmans, Edmund])

Comment: When are we going to start putting what's right in front of what's financially more 

lucrative? FPL could invest more in solar energy if it really wanted to, but it's not as lucrative.

(0372-3 [Ortiz, Natalia])

Comment: FPL does not take solar power seriously. I would like panels on my house. I am 

sure lots of others would too. (0373-7 [Lee, Nancy])

Comment: [T]he NRC must look more closely at energy efficiency and renewables to meet the 

projected need. (0379-5 [Commenters, Multiple])

Comment: Whatever happened to solar and wind power? You can't make enough money on 

that? (0390-1 [Passmore, Judith])

Comment: With the recent developments in wind and solar energy, additional nuclear reactors 

are unnecessary. (0400-2 [Eckert, Brenda])

Comment: We, the U.S., should be promoting cleaner, renewable forms of energy! We should 

be global leaders. We have the technology, but lack the insight and support to make it happen 

in a timely manner. We should no longer be using dirty and dangerous fossil fuels and/or nukes. 

No form of energy use is perfect, but there are certain forms that are much less damaging. If the 

govt had supported these forms as they have funded fossil fuels and nukes for the past one or 

two decades, we would be in a much better position on Earth today! No one cried for wagon 

makers when the car replaced wagons. The economy will right itself--we need to give it that 

chance! (0425-1 [Wingerd, Mala])

Comment: Instead, we should be wroking on converting our energy production to sustainable, 

environmentally safe GREEN energy solutions. (0441-2 [Bender, Kae])

Comment: Stop any kind of energy production that isn't from renewable resources. (0442-2

[Mosca-Clark, Vivianne])

Appendix E NUREG–2176 E-404 October 2016
Comment: As an American I am watching as destructive policies like these destroy our 

environment. Spend the money on renewable solar? Jeez! (0445-1 [Maida, Cecilia])

Comment: Nuclear is out. Solar, wind and thermal are in. Don't waste money on this 

dangerous form of energy. (0446-1 [Hill, Michael])

Comment: It is time to move on to more solar energy --European countries can show us the 

way. (0450-1 [Richards, Margie])

Comment: ... need to look into other source of energy that wouldn't be so unstable. (0455-3

[Hardin, Lillian])

Comment: It is time for The Sunshine State's utility companies to join the 21st century and 

focus on producing energy from clean, sustainable sources such as solar. (0463-8 [Gross, Cheryl 

A.])

Comment: You have a variety of expert testimony, some in favor, some opposed, I'll make my 

reasons simple. As custodians of this earth and energy users, most desire and are prepared for 

the responsibility of better alternatives than nuclear. We are ready for solar exploration 

explosion and ready to put our dollars to this initiative. There are additional energy alternatives 

but as a Floridian this is particularly attractive as a clean and safe alternative. I and thousands 

of fellow citizens are willing to put the billions that FPL would spend on nuclear into solar, wind 

and additional options for energy needs. Our federal EPA does not agree with the current 

proposal, the costs have skyrocketed from $13.7 billion to $20 billion, and the support of your 

residents is not behind a massive nuclear addition to the energy challenge. (0472-2 [Ball, Cheri])

Comment: We need SOLAR, not nukes. (0473-1 [Shepherd, James])

Comment: [I]n lieu [of nuclear power] establish natural renewable energy sources that are safe 

such as solar, wind and water power. (0481-3 [Szabo, Liz])

Comment: Or alternative energy development, which the world is begging for. (0484-2 [Speno, 

Charlie])

Comment: Many of us live close enough to this power plant to be frustrated that it is not 

winding down, but that some people want to expand it. Our homes, our lives, our parks are 

endangered unnecessarily, since solar power is easily available, cheaper, and safer. (0495-2

[Mazzarella, Rebecca])

Comment: Nuclear power is the dirty past, we don't need to promote it any more, we need to 

move into clean renewables. (0501-1 [Zimmermann, John])

Comment: We should put this money and effort into solar and wind production of energy.

(0514-1 [Massey, Linda])

Comment: There are ways to generate electricity, some of which are explored in the DEIS, that 

do not create these problems. (0515-4 [Regalado, Tomas])

Comment: Living in the Sunshine State, we should be moving toward solar energy. (0517-1

[Keim, Mary])

Appendix E October 2016 E-405 NUREG–2176
Comment: Florida being an excellent location for alternative energy sources such as solar 

power, FPL needs to drop this project and focus instead on safer and more sustainable planning 

for the future of this beautiful area we all share for our home. (0523-2 [Mitzkewich, Yuri])

Comment: Please! The insanity must stop somewhere! All the phenomenal amounts of money 

spent by large corporations to secure permission to operate against all logic or public 

preference would be far better spent developing safe, clean, and sustainable energy sources. 

Solar and wind come to mind. (0525-1 [Bailey, Evelyn])

Comment: The People shouldn't have to keep telling you corporate bullies the same thing over 

and over....find other solutions to the energy problem. (0532-1 [Raab, Frances])

Comment: I'd like to know why solar power, in the sunshine state, is not being considered as 

an alternative. (0537-6 [Anonymous, Judi])

Comment: Solar is a far better solution and it creates jobs! (0543-2 [Ryan, Jim])

Comment: FPL needs to invest heavily and seriously in safer forms of energy such as wind 

and solar; not double down on dangerous or dirty methods in a heavily populated area 

encompassing and adjacent to delicate ecosystems that are supposed to be being restored not 

further endangered. (0544-2 [Ehrenfried, Jennifer])

Comment: Florida should be focusing its efforts towards alternative clean energy. Solar Energy 

is the ONLY choice for the future of Florida. (0548-3 [Scott, Ruth])

Comment: Please consider investing in sustainable power such as solar and providing 

financial incentives to homeowners and businesses to become more enegy efficient. (0552-2

[Deutsch, Steven])

Comment: We should be using clean, renewable energy. (0558-2 [Barnes, Janice])

Comment: We should be moving toward more renewable resources, not building more power 

plants that can harm the environment. (0563-1 [Ramsey, Betty])

Comment: SO MANY ALTERNATIVES EXIST (0564-3 [Dimondstein, Carla])

Comment: Florida - the Sunshine State - offers no incentives whatsoever for conservation or 

solar power - largely due to the influence of FP&L and its desire to expand its nuclear facilities 

and have them forced into the rate base without a proper discussion of alternatives. 

Respectfully, adding new nuclear facilities in such a place at such a time is not the right way to 

go. Please force a consideration of alternatives. (0573-4 [Trauner, Keith])

Comment: Instead of expanding a plant that is vulnerable to hurricanes and is presently 

situated in Biscayne National Park, a pristine natural area, Florida Power and Light (FPL), 

should be expanding its solar energy capabilities. We are the "Sunshine State", but you wouldn't 

know that by FPL's poor record of involvement and commitment to solar energy. (0579-2

[Schwab, Roy])

Comment: I say expand solar energy[.] (0579-5 [Schwab, Roy])

Comment: It is ironic that Florida's license plates proclaim us as the sunshine state and yet 

solar energy development is an major underused resource. (0590-1 [Johnson, Diane])

Appendix E NUREG–2176 E-406 October 2016
Comment: FPL has a once a year solar grant program for FPL customers. The grants are all 

taken in the first few minutes customers are allowed to sign into the site and fill out the 

application. I have been trying to get a solar grant for two year and I can never fill out the form in 

time to submit. It is my understanding that literally 10,000's of customers try for these grants. 

Wouldn't it be smarter to expand that program than to spend billions on a two more nuclear 

reactors. Why not give solar a chance in the sunshine state? (0591-1 [Lange, Barbara])

Comment: 9 out of 10 Americans, including Republicans, Democrats and Independents, want 

more solar and wind power installed rather than using natural gas, coal, oil and nuclear power. 

According to a comprehensive 12-year Harvard survey as of 1/1/15, 90% of all Americans, 

including Republicans, Democrats and Independents, said that they wanted solar and wind 

energy to increase and 80% of all Americans said that they wanted solar and wind energy to 

"increase a lot". It is at http://www.forbes.com/sites/jeffmcmahon/2015/01/01/americans-wantamerica-to-run-on-solar-and-wind/. The Harvard study found that all Americans overwhelmingly 

prefer solar and wind power, rather than natural gas, coal, oil and nuclear power, because solar 

and wind power provide the least local pollution and health risk. (0592-2 [Brexel, Sr., Charles])

Comment: In addition, the market price evidence is overwhelmingly clear and compelling--

nuclear power is an extremely more expensive energy solution. The US energy market 

continues to move, faster and faster, toward an extremely better value energy future, reliant on 

solar and wind, not extremely expensive and risky nuclear power. (0592-3 [Brexel, Sr., Charles])

Comment: Solar and wind power are clearly the most innovative and newest technologies. 

Solar and wind power are, overwhelmingly, the energies of the present and future. Solar and 

wind power are where the overwhelming innovations and development are rapidly occurring.

(0592-5 [Brexel, Sr., Charles])

Comment: As of 5/29/15, for the year so far, 84.1% of all new power installations at utility 

companies were solar power, wind power and other renewables. Natural gas power supplied 

the rest of the new power installations. It is at http://safeenergy.org/2015/05/29/checking-in-onthe-energy-transition/. Germany and Sweden continue to very rapidly decommission all of their 

nuclear power plants and to very rapidly transition to solar and wind power. France is also 

rapidly cutting down its amount of nuclear power and is also rapidly transitioning to solar and 

wind power. California has only one, very old nuclear power plant left in operation and California 

is continuing to very rapidly transition to solar and wind power. On 1/7/15, Governor Brown of 

CA called for increasing the state renewable portfolio standard (RPS) to 50% by 2030, reducing 

petroleum use in cars and trucks in California by 50%, and doubling building energy efficiency, 

all by 2030. Legislative bills will be decided on later in 2015. It is at 

http://www.lawofrenewableenergy.com/2015/04/articles/renewable/governor-brown-announcesnew-2030-greenhouse-gas-reduction-target-for-california/. Since 2014 and earlier, Southern 

California Edison, Arizona Public Service, Tucson Electric Power, HECO, NRG Energy, Duke 

Energy, Southern Company, Georgia Power, and many other US electric power utility 

companies have all been quickly and massively ramping up their installations of zero carbon 

emission, clean energy such as solar and wind power. It is at 

http://www.utilitydive.com/news/grid-edge-live-2015-the-trends-behind-the-explosion-indistributed-resourc/401417/. As of 6/11/15, Vermont has a law for electric utilities to be at 75% 

renewables by 2032 and at 55% renewables by 2017. It is at 

http://www.utilitydive.com/news/new-vermont-law-mandates-75-renewables-by-2032-targetsresidential-emissi/400777/ and http://www.eia.gov/todayinenergy/detail.cfm?id=21852. As of 

6/29/15, Governor Cuomo of NY presented an energy plan under NY's REV plan to be at 50% 

renewable energy by 2030. The Assembly has already passed a bill for the plan and the Senate 

Appendix E October 2016 E-407 NUREG–2176
bill is awaiting a vote. It is at http://www.governorswindenergycoalition.org/?p=13551 and 

file:///C:/Users/Charles/Downloads/2015-overview.pdf and 

http://energyplan.ny.gov/Plans/2014.aspx. Effective 7/1/15, it is the law in Hawaii that 100% of 

its electricity come from renewables by 2045, with 30% by 2020, 40% by 2030 and 70% by 

2040 as interim targets. It is at http://www.utilitydive.com/news/100-renewables-by-2045-is-nowthe-law-in-hawaii/400495/ and http://www.eia.gov/todayinenergy/detail.cfm?id=21852. Nuclear 

power is clearly in rapid decline in use in the US and throughout the world, while solar and wind 

power are clearly and compellingly experiencing exponential growth for the next 25 years and 

longer. It will be even harder and even more expensive to get parts, operation, maintenance, 

support and engineering services for nuclear power as the decline in the use of nuclear power 

plants continues to accelerate over the next couple of decades. As of 7/5/15, it has already 

been costing our manufacturing industry, our businesses and our homeowners much less to buy 

solar power than natural gas, coal, oil, timber, biomass or nuclear power. And, it is expected to 

continue to cost them typically another 20% less per year for, at the least, the next few years. It 

is at http://www.usatoday.com/story/money/markets/2015/07/05/motley-fool-solarenergy/29583021/. As of 7/5/15, all bids for selling power from solar power utility-scale projects 

are now in the 4 cents to 5 cents per kWh range -- this is much less than what it costs you to 

build a natural gas, coal, oil, timber, biomass or nuclear power plant. It is at 

http://www.usatoday.com/story/money/markets/2015/07/05/motley-fool-solar-energy/29583021/. 

As of 7/9/15, two bids for selling power from solar power utility-scale projects have now come in 

below 4 cents per kWh, with one bid coming in below 3.9 cents per kWh -- this is much less 

than what it costs you to build a natural gas, coal, oil, timber, biomass or nuclear power plant. It 

is at http://www.utilitydive.com/news/nv-energy-buys-utility-scale-solar-at-record-low-priceunder-4-centskwh/401989/. As of 6/23/15, the price of wholesale solar power has been 

forecasted by independent analysts at Bloomberg New Energy Finance to continue to decrease, 

at the least, for the next 25 years. It is at http://www.bloomberg.com/news/articles/2015-06-

23/renewables-to-beat-fossil-fuels-with-3-7-trillion-solar-boom. As of 7/5/15, according to GTM 

Research, the cost of utility-scale solar projects has fallen 67% in the past five years, and is 

expected to fall another 44% in the next couple of years. As of 7/5/15, "Since solar costs are 

beating those of competing energy sources, there are expectations of a boom in demand--and 

it's going to be a global solar boom. GTM Research predicts that solar installations will triple to 

135 GW annually by 2020." On 7/5/15, financial analyst Travis Hoium of The Motley Fool said: 

"We're past the point of no return --solar energy will be the biggest new energy source in the 

future." (0592-6 [Brexel, Sr., Charles])

Comment: As of 8/22/14, US wind power hit an all-time national average low purchase price of 

2.5 cents per kWh -- this is much less than what it costs you to build a natural gas, coal, oil, 

timber, biomass or nuclear power plant. It is at http://www.theenergycollective.com/ericwesoff/468266/price-us-wind-power-all-time-low-25-cents-kilowatt-hour. As of 5/31/15, lawyers 

for Wal-Mart, a hospital group and a coalition of other ratepayers found that Florida utilities were 

buying Oklahoma wind power for just 2 cents per kilowatt hour: "Henry and the lawyers for 

OG&E's corporate customers formed a kind of tag team, taking turns blasting the company for 

refusing to even study new wind power. They repeatedly pointed out that in-state competitors as 

well as Florida and New Mexico utilities were buying Oklahoma wind for just 2 cents per kilowatt 

hour, even cheaper than coal without pollution controls, while OG&E hadn't purchased new 

wind in four years--even though its ads boasted about its commitment to wind. When its 

witnesses claimed their transmission lines were too congested to add new wind, Henry 

produced internal documents suggesting the congestion could be fixed for about 3 percent of 

the cost of the new coal scrubbers." http://www.politico.com/agenda/story/2015/05/inside-waron-coal-000002. As of 3/12/15, the price of wholesale wind power will continue to decrease, at 

the least, for the next 10 years according to a Department of Energy report. It is at 

Appendix E NUREG–2176 E-408 October 2016
http://www.bloomberg.com/news/articles/2015-03-12/wind-energy-without-subsidy-will-becheaper-than-gas-in-a-decade. On 8/8/14, Amory Lovins, a physicist and chief scientist at the 

Rocky Mountain Institute, found that "Wind and solar become the most economical options 

while gas and nuclear become the least economical". It is at 

http://www.theenergycollective.com/eric-wesoff/468266/price-us-wind-power-all-time-low-25-

cents-kilowatt-hour. Further, FPL's proposed power from new nuclear reactors can more costeffectively be met with demand side management programs. In meeting demand, energy 

efficiency measures meet demand at less than 3 cents per kilowatt hour (kWh)1, while the 

proposed Turkey Point nuclear reactors will meet demand at a cost of more than 15 cents per 

kWh. (0592-7 [Brexel, Sr., Charles])

Comment: Why you don't come to terms with solar? And wind power using the tubed fans? 

Those resources are all free. You can still kickback your investors also. (0593-1 [Family, Manzi])

Comment: Florida should be investing in more renewable forms of energy that don't have such 

negative impacts on the environment. I just returned from Hawaii where solar installations are 

increasing for home and business use. Florida is sadly lagging behind. (0594-5 [Rapuano, 

Shannon])

Comment: FPL has done nothing but discourage solar power on individuals' rooftops, while 

saying they are working on solar throughout the state. Their small solar initiative pales in 

comparison to what could be done by individual homeowners and businesses. But they wouldn't 

make any money that way. (0596-2 [Sorenson, Katy])

Comment: We need to be concentrating on conservation and renewables – not more nuclear 

power. (0596-4 [Sorenson, Katy])

Comment: Why is solar power so unused in a state with more sun than most! (0600-2 [Edwards, 

Suzi])

Comment: Shame on you if you allow this boondoggle on Florida ratepayers and the 

environment. There are many better alternatives for Florida's energy supply that are cheaper 

with less environmental impact and you know it. Pleas do the the right thing instead of the most 

"PROFITABLE" thing. (0601-1 [Quillen, Carter])

Comment: In the face of global climate change, we need resilient solutions today. Clean, safe, 

and affordable renewable energy along with energy efficiency and conservation will preserve 

our health, environment, and future (0602-2 [Colson, Clay G.])

Comment: Turkey Point is the PAST -- lets put the future of 'GREEN" energy on the front 

burner. (0608-1 [Anderson, Vaughn])

Comment: SOLAR AND WIND ENERGY ARE CHEAP, RENEWABLE AND HARMLESS TO 

THE ENVIRONMENT. (0609-2 [Khajeh-Noori, Jeri])

Comment: Living in the 'sunshine state' would it not make more sense to invest a fraction of 

the cost of a nuclear plant to develop solar power and other renewable sources? Costa Rica, a 

very small country but also with fewer economic resources than the U.S, just enjoyed one 

month without the need of power generated by fossil fuels. They are experimenting with 

renewable sources. Is there a lesson for us to learn? (0613-2 [Icaza, Alejo])

Appendix E October 2016 E-409 NUREG–2176
Comment: Another way these plants could be abandoned is by the advance of solar and 

battery technology. The Gemasol solar plant in Spain already operates 24 hours a day thanks to 

molten salt energy storage and has done so since 2013. Just this week, the New York Times 

carried a story about Tesla's deployment of 400 home solar storage batteries which allow their 

owners to run solar electricity at night, including installations at Wal-Mart stores. The company 

announced that its next solar storage product will be a utility grade battery. With 2417 solar 

generation and home solar energy storage by batteries already a reality, it is inconceivable that 

Florida would need baseload nuclear energy at the time of the plant's projected opening 15 

years from the start of construction. In fact, it's more likely that Florida would suffer from a glut 

of electricity produced off the grid, causing FPL to move away from their costly investments in 

nuclear and fossil fuel plants. (0615-1-14 [Bethune, David])

Comment: The agency's alternative energy "expert" said that solar wasn't viable because the 

sun went away at night, an appalling revelation of the agency's ignorance of modern salt 

storage and battery technologies for solar. The NRC staff member was unaware of the 24/7 

baseload solar power plant in Spain and was totally ignorant of Florida efforts at rooftop solar, 

off-the-grid local power generation, and home battery storage. The extent of his understanding 

of current US progress in solar energy was revealed when he said that he "thought there might 

be some research [about solar] in California." (0615-1-3 [Bethune, David])

Comment: Please stop! Look at the big picture. I am certain you will find an alternative 

solution. Thank you. (0616-2 [Puchades, Mary])

Comment: Shift the funding for these plants to solar infrastructure development. (0621-3 [Datz, 

Amy])

Comment: No to more cancer machines,let's go solar from now on! (0624-4 [Galles, Camilla])

Comment: FPL should be investing in solar power, rather than nuclear power, where the risk 

and payoff make far more sense. (0625-4 [Felinski, Julee])

Comment: We should be moving completely to renewable energy, wind and solar. (0627-1

[Dolben, Hollis])

Comment: We don't need to install new reactors, we need to use those funds to start installing 

solar, wind[.] (0630-1 [Montalvo, Stephanie])

Comment: There is no need for more nuclear plants if we would finally understand that 

photovoltaic systems on 50 % of all the roofs in Florida and connected to the grid -same as in so 

many parts of this country, even far more north, where they have only half the sunny hours 

compared to "The Sunshine State". (0632-1 [Moll, Wolfgang])

Comment: I suggest that we build our use of solar energy which is safer, cleaner, and does not 

detract from the land. (0635-5 [Seiman, Rhonda])

Comment: Let us learn from the mistakes we as a human race have made. This fragile one of 

a kind Eco system is irreplaceable. It is time to transform to ways that are in harmony with earth. 

Why can we not choose to build a solar plant or a solution in alignment that would be much less 

harmful when a disaster occurs. (0638-2 [Anonymous, Charity])

Appendix E NUREG–2176 E-410 October 2016
Comment: Now is the time to turn this turkey around and plant solar panels instead of nuclear 

plants. (0639-4 [Haselhurst, Richard])

Comment: At this time we should be looking for alternative sources of energy such as solar 

and wind power. In the state of SUNNY Florida we really should not have a great problem 

generating power with the use of solar energy. (0642-3 [Rawlins, Steve])

Comment: We need to do more for alternative energy production. I have a design for a device 

that will use solar and/or wind to produce electrical power. I have even started a company--

Pernetic Generator Group LLC to promote my design and bring it to market. (0650-1 [Kristy, 

Joseph])

Comment: We must go to renewal energyLike solar and wind (0660-2 [Sanchez, Sergio and 

Irma])

Comment: I'm for eliminating fossil and nuclear energy sources and transition to solar and 

wind energy sources in Florida, where we have plenty of both. (0662-2 [Anonymous, Elena])

Comment: Instead I would support taking the construction money and building more 

renewable energy facilities; solar and wind. (0666-3 [Jens-Rochow, Steve])

Comment: The alternative is renewable energy. If we installed small renewable energy 

systems at all of the 65,000 new homes and buildings that are constructed in Florida every year 

and each system generated $20 a month in power x 12 months= $240 annually, this would 

create $15.6 million annually in free electricity. This free power would increase by an additional 

$15.6 million each year when 65,000 new homes and building are constructed in Florida 

annually. Another important benefit promoting this concept is that the manufacturing and 

installation businesses in Florida will always know how many renewable energy systems will be 

purchased and installed every year. The U.S. spends $2.5 billion annually in solar energy 

rebates for 250,000 existing structures and the cost to install one million renewable energy 

systems at all of the new homes and buildings constructed in the U.S. annually at $2500 each 

would be $2.5 billion. This is also the same amount of money FP&L intends to spend every year 

in building the two nuclear reactors with money raised by increasing utility rates. The average 

amount of free power generated at one million new homes and buildings would be $20 a month 

x 12 months= $240 x 1,000,000 =$240 million. This will increase by an additional $240 million 

each year as one million new structures are built annually. After ten years, the systems will 

collectively generate $2.4 billion each year in free power which is 200% more power produced 

annually than the two reactors that FP&L wants to build near Miami. These systems will start 

producing power as soon as they are installed and nuclear plants will not generate power for at 

least ten years. Investing $1 in renewable energy at homes and buildings will create $2-$4 in 

free power for consumers and every $1 invested in nuclear power will require consumers to 

spend $5-$6 more to purchase the power, maintain the plants, disassemble them in the future, 

and dispose of the nuclear waste. We can expect that within ten years the renewable energy 

systems will become 100% more efficient and their costs will decline by 50%. At this time we 

can begin installing ten million systems each year in existing homes and buildings. We should 

start in low income neighborhoods and train local unemployed workers to install the systems.

(0671-1-3 [Post, Patrick])

Comment: If renewable energy is developed properly, it can help save the world by eliminating 

all use of nuclear power. This is a major goal of our project! (0671-2-1 [Post, Patrick])

Appendix E October 2016 E-411 NUREG–2176
Comment: We have a proposal for FP&L if they want to help the citizens of South Florida to 

have access to stable, inexpensive, and environmentally friendly electricity. They should use all 

of the money that they have collected to construct the two new $25 billion nuclear power 

reactors and instead use the funds to begin installing solar and renewable energy equipment on 

all of the 4.5 million homes and buildings that are FP&L utility customers. This effort would be 

an infinitely better use of our money which FP&L is collecting by raising utility rates. All of the 

power would be free, clean, and unlimited because it will come from the sun and wind. FP&L 

could start first with new homes and buildings and we would welcome the opportunity to discuss 

our proposals with them at any time. (0671-2-3 [Post, Patrick])

Comment: This proposed investment of more than 20 billion dollars for each of the reactors (of 

the rate-payers' money) makes no logical sense to anyone except business marketers. Solar 

power was not considered a viable alternative by the NRC reviewers, even though no state in 

the eastern half of the U.S. has the solar potential of Florida. And in spite of all the advertising 

they do on the topic, FPL's actual solar production of less than 1/10th of 1 percent of its energy 

portfolio is wholly inadequate. Solar contains none of the risk of its proposed Turkey Point 

expansion and will contribute to both the ecological and economic sustainability of our region for 

years to come. (0673-6 [Dwyer, John P.])

Comment: On a final note, this investment of more than 20 billion dollars of the rate-payers 

money makes no logical sense. Solar power was not considered a viable alternative by the NRC 

reviewers -even though no state in the eastern half of the U.S. has the solar potential of Florida. 

FPL should drop this risky project and instead embrace a solar alternative that the company 

knows its customers want. Solar contains virtually none of the risk of its proposed Turkey Point 

expansion and will contribute to both the ecological and economic sustainability of our region for 

years to come. (0674-7 [Dwyer, Karen])

Comment: FPLs project commits us to expensive nuclear power for the next 60 years without 

fairly evaluating more cost-effective energy that does not require local storage of radioactive 

waste. The cheapest, cleanest and safest way to meet our energy needs is through energy 

conservation and efficiency. Conservation is one-fifth the cost of nuclear generation, yet FPL 

opposes conservation standards and presses for nuclear, the most expensive and risky 

investment available. (0675-3 [Rodriguez, Jose Javier])

Comment: I really do not understand Florida's love affair with nuclear energy. We have so 

many roof tops that would be prime real estate for solar collectors. either it is a stupid decision 

or a decision based on greed not to use our greatest resource. (0700-1 [O'Meara, Patrick])

Comment: We need to put funding into developing more renewable resources -not spending $ 

on trying to clean up disasters which are inevitable in situations like this. (0704-2 [Ferry, Lisa])

Comment: Florida is known as the SUNSHINE state. Florida, of all places, should be powered 

with Renewable Energy. Go to www.thesolutionsproject.org to see how every state can be 

powered ENTIRELY with Renewable Energy. (0706-1 [Anonymous, Anonymous])

Comment: We are the Sunshine State and should use the sun and other clean sources of 

energy for our beautiful state and lead the rest of the nation by example. (0712-2 [Almer, Anessa])

Comment: Instead of building large power plants, the Florida government should focus on 

harnessing solar energy. Unlike this nuclear power plant, solar panels do not require any 

Appendix E NUREG–2176 E-412 October 2016
valuable water or expensive infrastructure. They also do not create waste product and do not 

require the electricity to be transported. (0713-3 [Heiney, Jamie])

Comment: [S]unshine state should go all solar and built electric storage, not cancerous 

reactors. (0715-3 [Anonymous, Anonymous])

Comment: This seems like a foolish expenditure when FPL could help put solar on every roof, 

fund LED lighting everywhere, start talks about turning off downtown highrise office lights which 

are left on all night. foam spray the rafters of every home and building in Miami Dade county.

(0718-2 [Buechler, Jerry])

Comment: Solar power was not even considered a viable alternative by the NRC reviewers -

even though no state in the eastern half of the U.S. has the solar potential of Florida -also 

known as the Sunshine State. And in spite of all the advertising FPL do on the topic -FPL's 

actual solar production of less than 1/10th of 1 percent of its "energy portfolio" leaves much to 

be desired. With initiatives like third party rooftop solar coming online soon (and "Floridians for 

Solar Choice" project), FPL should drop this risky project and instead embrace a solar 

alternative that the company knows its customers want and it's a no brainer when it comes to 

humanity and real care of the environment we actually live in. Solar contains virtually none of 

the risk of its proposed Turkey Point expansion and will contribute to both the ecological 

and economic sustainability of our region for years to come. (0720-2 [Bastidas, Mauricio])

Comment: And I think what's really interesting to me is that the parent company of FP&L 

acquired Hawaii Electric Industries, who has had a lot of success in taking a very different route 

to generation and distribution, a lot of which has to do with solar. And so I sort of take that as a 

tacit acknowledgment that there is another future for us possibly in energy that we are exploring. 

We don't know what that answer is, but why cut it off before we're there. (0721-1-10 [Rodriguez, 

Jose Javier])

Comment: So one of the things I wanted to share, and I do have copies to leave with you, is 

that the Everglades Coalition 2015 Legislative priorities included, and this is representing 6 

million environmental members of the Everglades Coalition. Collectively our 57 organizations 

make up that many people. And our priorities talk about minimizing fresh water waste, salt water 

intrusion, and flooding through expanded use of renewable and smart energy sources. So what 

does that mean? That means we have to move toward energy sources that do not use water. 

Nuclear isn't right for Florida because we don't have the fresh water resources. (0721-10-3

[Reynolds, Laura])

Comment: We have --our solar panels don't demand any water. Of course this is all postconstruction, I admit. The nuclear power plant is constructed, it takes energy, it takes water, it 

takes whatever. So solar panels are manufactured, but we call it even when they're built. Once 

they're in operation I'm not using any water, I'm not releasing any toxins, I'm not transporting 

fuel or waste products anywhere, I don't have to store anything. (0721-11-8 [Roff, Rhonda])

Comment: Talking about FPL and -- I'm sorry -talking about solar power. We were talking 

about France's -- or China just had it about the same capacity as France's capacity in solar. To 

clear up that number, China added about 5 gigawatts of solar power. France has about 5 

gigawatts of solar power. France's total output is about 50 gigawatts, 45 gigawatts of which is 

about -- is produced from nuclear power. And consistently France ranks amongst one of the top 

countries for air quality. (0721-15-2 [Kuraza, Devon])

Appendix E October 2016 E-413 NUREG–2176
Comment: So let's talk about nuclear power and let's talk about wind and solar. Show of 

hands, how many of you are in favor of wind and solar as a source of power generation? Okay. 

And how many of you are against nuclear power? Show of hands. Okay. (0721-15-4 [Kuraza, 

Devon])

Comment: So I wanted to mention also to my friends from FPL that there are alternatives in 

nuclear power. (0721-16-2 [Rifkind, David])

Comment: So, for instance, when I built my house three years ago I installed a 5 kilowatt array 

on the roof, and I installed it for $3.00 a watt. So as I understand it, even if we were able to build 

-- if FPL was able to build these two reactors, and it would be the first time in human history that 

reactors would actually be built on budget, it would still cost about $9.00 a watt, and as I 

understand, that's three times what I paid for my rooftop solar array, so I'm kind of wondering, 

have you really thought about the economics of what it costs to build a nuclear reactor.

(0721-16-3 [Rifkind, David])

Comment: And the other thing that I wanted to mention too, is that, again it's come up, and I 

know that the NRC has its rules. But I would say that as far as the rule regarding the need to 

constantly generate power, keep in mind that you guys have all got telephones in your pocket, 

they've all got batteries. The technology for storing electricity, when the sun's not shining, is not 

magical, and these are things that can be overcome. The other thing I would mention too is, that 

even if FPL was able to be the first utility in America to ever build a nuclear reactor on time, it 

would still be 12 years before these units come online, and in that time we could easily install 

the 22,000 megawatts of capacity, or the equivalent of that, using solar and other renewable 

energy sources that don't require -well, don't require any use of water for cooling, don't require 

any kind of mitigation for radiation and so on. (0721-16-4 [Rifkind, David])

Comment: So I would just say, again, my own experience from powering my house with solar 

panels, it shows me that we can do it so much more efficiently, so much more economically, so 

much more rapidly, and so much more safely, than resorting to nuclear power. (0721-16-6

[Rifkind, David])

Comment: Solar is right. You can feel that in your gut. Wind energy is right. And there's 

research. (0721-18-3 [Bernabei, Catharina])

Comment: People of FPL, if you were to have solar panels, half of Miami, half of South Florida, 

you have enough. But maybe if it becomes more affordable. My daughter and her husband will 

pay off in seven years, and they have a child, and that will be her college fund; that it's paid off 

and then they hardly have to pay any electricity. We collect it through the grid. It goes back to 

FPL, the excess of sun, of solar energy, will benefit FPL. What are you thinking? You will benefit 

from all those homes when you see an air -- when you look out of the plane and look at Miami, 

wow, couldn't you imagine, solar panels here and here, everywhere. It will be sufficient.

(0721-18-4 [Bernabei, Catharina])

Comment: We need solar. Florida, South Florida especially has more solar potential than any 

place in the continental United States. The EIS looked at solar and they compared this plant to a 

solar farm. We need rooftop solar. We have millions of acres in Florida of rooftops that are not 

being used. FP&L --just coming here somebody mentioned that. I heard one of their solar 

commercials. In terms of their portfolio, 0.06 percent. Not even 1/10th of 1 percent of their 

portfolio is produced by solar. One way they can do it, don't compare it to solar farms, compare 

it to rooftop solar and use the model that DishTV came up with. You don't have to create your 

Appendix E NUREG–2176 E-414 October 2016
own satellite in space. Let FP&L put the solar panels on people's houses. Let them own it, the 

same way as Dish. You want solar, you call up, they come out, they put the panels. 24 hour, 

they say we can't do it because it's not 24 hour. That's nonsense. Peak electricity is during the 

day. That's when we're burning the electricity. We can go to other forms of electricity when we're 

not using solar. Let FP&L get into that business, installing solar panels on people's houses so 

people don't have to shell out $20,000, $30,000. That's what the solar initiative coming up right 

now is all about, getting competition in there. FP&L I don't think is in favor of that. (0721-22-18

[Schwartz, Matthew])

Comment: With so many truly clean, safe, renewable and sustainable technologies now 

available and in development, there is no reason to build new nuclear plants. This will only drain 

much-needed resources from full development of better, safer, technologies. This is the 

Sunshine State. We should be leading the nation, the world, in solar development. Instead, we 

rank 13th in total installed solar in the country and 20th in solar installed in 2014. It's time to end 

the use of all nuclear power and put all, all of our resources into truly safe, clean, and 

sustainable technologies, like conservation, solar, wind, geothermal and others which absolutely 

can and will supply all the energy the State and the world needs without destroying the world in 

the process. (0721-28-11 [Wilansky, Laura Sue])

Comment: FP&L is developing solar power too, but they're doing a teeny, tiny fraction of what 

they could be doing. While 95 percent or more of their advertising and PR is devoted to 

promoting how much solar development they're doing, they're actually generating less than 

1/10th of 1 percent, as has been mentioned, .01 percent of their electricity through solar power. 

I'm a customer, I know, I get the brochures every month in my bills. I brought the brochure that 

came with my February 2015 bill, if you want to see it in their own words in black and white, .01 

percent solar. In black and white, or rather, green and white. But printing the information in 

green doesn't make what FP&L is doing, green, unless the green you're talking about is cash.

(0721-28-12 [Wilansky, Laura Sue])

Comment: The answer is solar. FP&L knows this, and at .01 percent we are woefully low for 

the Sunshine State. (0721-30-10 [Ullman, John])

Comment: And I just want to emphasize the whole point is that why not invest in solar energy. I 

mean that's just a much more cleaner, safer form of energy. I mean other countries, even 

Germany, which has less sunshine than us, has 20 percent of energy from solar energy. So I 

don't know why Florida, being the Sunshine States doesn't, you know, really, you know, live by 

its own nickname or name, whatever, and try to embrace that and try to have, you know, solar 

panels at everyone's house. And so instead of doing the FP&L, oh, pay now and get screwed 

over plan, how about we give the money to us and just we'll put in our own solar panels and 

save everyone money. We can give the electricity back to FP&L. I think that makes way more 

sense than, oh, let's give lots of money now, rip me off now, and then, you know, not even come 

through with a promise. (0721-31-10 [Almirola, Alejandro])

Comment: It's just, you know, I think we could be smarter and actually pick something that 

works for everyone. (0721-31-14 [Almirola, Alejandro])

Comment: By now Florida and the United States should've transitioned to solar and other 

renewable resources rather than this inherently dangerous power source. (0721-32-1

[Schlackman, Mara])

Appendix E October 2016 E-415 NUREG–2176
Comment: Try it and use solar panel. And why the Florida Power and Light they no make the 

solar panel and sell it to everybody at good price. And they got a lot of jobs right there to work in 

the solar panel, to sell it out. Only he looking for money. Money and money. They don't care 

about the life of the people. So, to me it's the best way, make a solar farm. (0721-33-4 [Herrera, 

Luis])

Comment: So when I step away and say I'm an advocate, yeah, I'm an advocate, and yeah, 

I'm conflicted. But I look at this now and say, you guys from FPL to everybody, I supply Solar 

City. You guys want to do some special work with Solar City? I'll work with you guys on creating 

a rack system; cash on hand. You know, we'll put money in front. We'll make this worth your 

while, whatever you -- let's get creative. (0721-34-2 [Gomez, Albert])

Comment: I think there's a better way. A gentleman earlier referred to it in terms of renewable 

energy. The same way if we built this reactor, which I think we should to do. By the time we built 

this we'd have new renewable energy sources, which would be cheaper and more efficient.

(0721-7-7 [Edmond, Gabriel])

Comment: Additionally, FP&L generates less than 1/10th of 1 percent of its electricity from 

solar power. Given that solar helps meet peak demand and power plants are built to meet peak 

demand, meaningful investment in solar could help defer the need for the proposed reactors. 

Yet, FP&L assigns solar power a zero value in avoiding capacity additions in its resource 

planning process. And if you make a plug for the ballot petition, if you want to see rooftop solar 

increased in Florida, please sign the Floridian For Solar Choice ballot petition. (0721-8-7 [Cavros, 

George])

Comment: I can tell you after working many years in front of the Public Service Commission on 

behalf of Clean Energy Advocates, that description simply does not fit the planning process in 

Florida. There are three disjointed components; the State planning process in Florida, a tenyear site plan, and new determination in conservation goal setting. A ten year site plan is simply 

a summary planning document that PSC cannot require the utility to change it. The power 

company cannot change it --or can change it, rather, at any time on its own accord, and there is 

no open stakeholder process that provides meaningful participation in the utility's long-term 

planning process. Moreover, energy efficiency and renewable energy are never placed on a 

level playing field in the Florida planning process, nor considered comprehensively, and we will 

provide more detailed written comments on the State's disjointed planning process. Suffice to 

say that the NRC should not rely on it and must take a hard look at energy efficiency and 

renewables to meet the projected need. (0721-8-9 [Cavros, George])

Comment: Well, I'd suggest that there's alternatives that they haven't considered because they 

are biased in the direction of heavy capital investment, continuing the same game they've been 

playing. You know, they have right now .06 percent of all the mega-wattage that they want in the 

State of Florida is solar. I think that's an embarrassment. This is the Sunshine State. (0723-12-5

[Henry, Jim])

Comment: ...but the idea that less than one percent of your installed base is generated by 

solar energy is just -- I mean, I think it's hard to explain. (0723-12-6 [Henry, Jim])

Comment: You really need to think about that very long and very hard before you put this 

puppy to bed. This is a very important time to think about that. And if you need jobs down here it 

should be in solar. (0723-3-3 [Star, Priscilla])

Comment: [Y]ou all deserve jobs provided by FPL in solar. (0723-3-5 [Star, Priscilla])

Appendix E NUREG–2176 E-416 October 2016
Comment: In general, we also feel that the needs, future needs of the State of Florida for 

electrical power could be met by alternative energy sources and conservation. (0723-5-4 [Teas, 

Jim])

Comment: NEPA requires an evaluation of a reasonable range of alternatives as part of the 

keystone to it. The alternative that I mentioned which is distributed solar on rooftops providing 

the baseload during the day, peak time, when we're using the energy, the air conditioners, that's 

when we're using most of it, combined with traditional fossil fuel in the evening. That's a 

combination that apparently was not evaluated. It's missing from the EIS. It's got to go in there. 

The technology is there, it was not evaluated. It's missing. Solar economy. This is things we 

want to add a little bit because we are in Homestead, and this is kind of a company town.

(0723-9-2 [Schwartz, Matthew])

Comment: There's so much out there for solar technology. (0723-9-3 [Schwartz, Matthew])

Comment: I understand this gentleman is running the nuclear plant but you folks could let -- 

your children could also learn to run solar, not plants, but distributed solar on every house, 

every building, every store. FPL is always advertising their new solar technology. Look at their 

numbers, though. Google FPL energy portfolio, 0.06 percent. Not even one-tenth of one percent 

solar. So the technology is there. (0723-9-5 [Schwartz, Matthew])

Response: The NRC does not promote any particular form of energy generation, including 

nuclear. However, the NRC does examine energy alternatives as part of its NEPA 

responsibilities. The staff’s evaluation of renewable alternative energy sources, including wind, 

solar, geothermal, fuel cells, and biomass, in Section 9.2 of the EIS describes potential impacts 

from these sources in comparison with the proposed action. In Section 9.2 the review team 

determined that none of these renewable energy sources could, by themselves, meet the 

purpose and need of the proposed action; to provide a target of 2200 MW(e) of baseload 

power. Alternatives not requiring new generating capacity, including conservation and 

demandside management, are discussed in Section 9.2.1 of the EIS. The staff concluded in the 

EIS that these technologies also did not represent reasonable alternatives to a large baseload 

power plant located at the Turkey Point site because they could not meet the purpose and need 

of the project. The staff concluded in Section 9.2 of the EIS that none of the feasible alternative 

energy options were environmentally preferable to the proposed action. The cost of energy 

alternatives was not considered in the EIS because the options were either not capable of 

meeting the purpose and need, or were not environmentally preferable. No change was made 

to the EIS as a result of these comments. 

Comment: The NRC Failed to Consider Natural Gas Energy Alternatives: As a matter of 

public record -the cost of natural gas is at an all time low due to vast amounts of natural gas 

production (harvesting) from numerous sources. Clearly, FPL customers would benefit 

economically from a natural gas fired power plant -rather than a extensively more costly nuclear 

power plant. Notably, the regulatory cost of constructing and operating a nuclear power plant far 

exceeds a comparable natural gas fired power plant. Indeed, even after a nuclear power plant is 

decommissioned -there remain very extensive costs related to that activity which are passed on 

to the customers. (0010-5 [Saporito, Thomas])

Comment: We are NOT in favor of any gas plants or the fracking that goes with them. I know 

that, at this time, gas would be less expensive, but I see it harming our environment at a much 

greater cost. (0070-2 [Lamb, Deborah S.])

Appendix E October 2016 E-417 NUREG–2176
Comment: Given the operating cost vs that of a gas fired powerplant this just seems like 

someone's nuclear wet dream. (0249-3 [Mosher, Paul])

Response: In Section 9.2.2, the staff concluded that natural gas was a feasible alternative to 

the proposed action. However, in Section 9.2.5 the staff concluded that natural gas was not 

environmentally preferable to the proposed action, and the air-quality impacts from the natural 

gas plant emissions, including greenhouse gas emissions, are a key difference. The cost of 

natural gas was not considered in the EIS because it was not environmentally preferable. No 

change was made to the EIS as a result of these comments. 

Comment: the winds have shifted in energy supplies and natural gas is much more affordable 

and doesnt have to be built along the coast. also, solar and wind and thermal have now become 

competitive to nuclear, in fact, cheaper than nuclear (considering nuclear plants have a federal 

subsidy) (0055-4 [Roedel, Kitty])

Comment: Our area may need more electricity, but there is no present or foreseeable crisis 

that exists. Therefore, a better thought out and ecologically sensitive plan for electricity should 

be on the drawing boards for our area including, but not limited to: solar, wind, water currents, 

etc. (0073-2 [Commenters, Multiple])

Comment: We know that we have growing demands for electricity. But our land and our 

drinking water are limited resources. It's time we look to more sustainable, less environmentally 

impactful energy solutions to fulfill our growing community. (0076-6 [Daly, Meg])

Comment: 2. While I can see that our area may in the future need more electricity, right now 

there is no current or foreseeable crisis that exists. A better thought out and ecologically 

sensitive plan to obtain more electricity should be planned to include but not be limited to solar, 

wind, water currents, etc. (0077-2 [de Armas, Maria Cristina])

Comment: As a Florida resident I beg of you to find a more suitable way or place to increase 

electricity production here in our beautiful state. (0084-2 [Phillips, Monica D.])

Comment: Don't give FPL green light to build more nuclear towers, please explore other 

source of energy. (0088-1 [Lange, Alexandra])

Comment: Smaller, more numerous natural-gas fired facilities could decentralize electric 

power production here. The consequence would be that smaller transmission lines could be 

used to distribute the energy so produced, and networks properly designed, could cover a loss 

of one or two in any natural disaster. Our nation has such plentiful natural-gas supplies that we 

are exporting it already. Let's use the resources we have here for our own safety and economy. 

Also, the use of SOLAR power in this Sunshine State has barely begun here as well, and should 

be exploited fully before resorting to the construction of added nuclear facilities. (0213-4 [Hyams, 

Charles])

Comment: The NRC. . . including Florida Power and Light. . . need to return to the draft board 

to come up with a better solution for Florida's energy needs. (0250-7 [Fulks, Anna Louise])

Comment: I will like to conclude by praising the positive aspects of renewable technologies 

(surprising from the tone of the article, I know). Renewable technologies coupled with battery 

storage have great potential to make our grid more stable. Having small distributed powerstorage stations that are powered with wind and solar would be a great way to deal with 

Appendix E NUREG–2176 E-418 October 2016
localized energy-demand spikes, which would replace the need for gas-fired peaking stations. 

Renewables could literally outshine and outperform fossil fuels in providing peaking power when 

it is built upon nuclear baseload power. However, if we do not allow the construction of nuclear 

units at Turkey Point 6&7--and at other locations--the use of fossil fuels will continue unabated 

to supply the necessary amount of energy to put food on our tables and power our economy. It 

is critical to approve Turkey Point 6&7 because without these units we will miss not only on the 

benefits of nuclear power, but also the benefits of renewables. (0378-7 [Macher, Nathan])

Response: The NRC does not promote any particular form of energy generation, including 

nuclear. However, the NRC does examine energy alternatives as part of its NEPA 

responsibilities. In Section 9.2.2 the staff concluded that natural gas was a feasible alternative 

to the proposed action. However, in Section 9.2.5 the staff concluded that natural gas was not 

environmentally preferable to the proposed action, and the air-quality impacts from the natural 

gas plant emissions, including greenhouse gas emissions, are a key difference. The staff’s 

evaluation of renewable alternative energy sources, including wind, solar, geothermal, fuel cells, 

and biomass, in Section 9.2 of the EIS describes potential impacts from these sources in 

comparison with the proposed action. In Section 9.2 the review team determined that none of 

these renewable energy sources could, by themselves, meet the purpose and need of the 

proposed action; to provide a large baseload power source. Alternatives not requiring new 

generating capacity, including conservation and demandside management, are discussed in 

Section 9.2.1 of the EIS. The staff concluded in the EIS that these technologies did not 

represent reasonable alternatives to meet the need for 2200 MW(e) of baseload power in the 

FPL service territory because they are incapable of generating baseload power, or (for 

alternatives such as biomass) 2200 MW(e) of baseload power. The staff concluded in Section 

9.2 of the EIS that none of the feasible alternative energy options were environmentally 

preferable to the proposed action because the environmental impacts of the alternatives were 

either similar to, or worse than, those of the proposed action. The cost of energy alternatives 

was not considered in the EIS because the options were either not feasible, or were not 

environmentally preferable. No change was made to the EIS as a result of these comments. 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[s]olar and wind although options are very costly 

and not as efficient as nuclear so those options cant be relied on. (0015-15 [Goldmeier, Barry])

Comment: Nuclear fission is a technology that we have today and doesn't require the 

development of another technology, like battery storage; A technology that has not yet reached 

mass commercial viability. If the world is lucky enough to develop commercial battery storage, 

then nuclear power will work even better. In contrast, renewable energies merely depend 

completely on the development of battery storage. Instead of straining our economy with 

renewables by stretching the technology just to get back to the "volume" of electricity generated 

today with fossil fuels, we can revamp and transform our economy with abundant nuclear 

energy. (0378-2 [Macher, Nathan])

Response: The NRC acknowledges the commenter's support for new nuclear power. The 

NRC does not promote any particular form of energy generation, including nuclear. However, 

the NRC does examine energy alternatives as part of its responsibilities under the National 

Environmental Policy Act (NEPA). The staff concluded in Section 9.2.5 of the EIS that none of 

the feasible alternative energy options were environmentally preferable to the proposed action 

because the environmental impacts of the alternatives were either similar to, or worse than, 

those of the proposed action. The cost of energy alternatives was not considered in the EIS 

Appendix E October 2016 E-419 NUREG–2176
because the options were either not feasible, or were not environmentally preferable. No 

change was made to the EIS as a result of these comments. 

Comment: We should also be harnessing the ocean currents for hydro electric power. Burning 

fossil fuels, and creating nuclear waste have been proven to be detrimental to our "mother 

earth". It's time we use our ingenuity as mankind to create sustainable and safe energy 

production. We only have one earth, one planet. It has to last for many generations to come.

(0146-6 [Grant, Randy])

Comment: If only there was a viable alternative to nuclear power... Oh, that's right, there are 

many alternatives. Now, we must also consider the alternatives that exist, and FPL's role in 

preventing their implementation. We are the sunshine state, and Solar infrastructure gets 

cheaper every year, yet we have minimal Solar PV Power (cloudy Germany is shutting down 

coal and nuclear plants). We have the Gulf Stream right off shore, yet we're only beginning to 

"study" current and wave power generation (while Brazil, Holland and Australia have installed 

operational power plants). We have no shortage of wind (and wind farms are sprouting up in 

many parts of the USA). (0252-14 [Van Leer, Sam])

Comment: It is also my very strong opinion, that Florida Power and Light cares more about 

generating money than it does about the people who rely on its services. For all its glossy, warm 

and fuzzy flyers about how it is generating environmentally safe and economic power, there is 

inadequate proof that these claims are true. If they were, all the money we have been charged 

for "future development" would be showing up in wind, sun, and tide generated power -NOT 

additional hazardous nuclear plants on the edge of a rising ocean. (0337-6 [Philips, Sally B.])

Comment: We want clean, renewable energy sources -solar, wind, water. These energy 

sources are CHEAP and SAFE. Nuclear is neither! (0381-1 [Khajeh-Noori, Jeri])

Comment: I beg you to go back to the drawing board. We have free and abundant energy 

sources like water, sun and wind. This is where we need to be headed. (0633-3 [Cornely, Tina])

Comment: Additionally, the community would be better served by using the projected $20 

Billion in cost by exploring power generation of electricity by solar, wind, or wave means. (0653-2

[Hickey, Alan])

Comment: LETS INVEST IN WATER TURBINE AND SOLAR ENERGY. (0656-2 [Zhivelev, 

Leon])

Comment: There are so many ways to produce energy. From the sun, wind, tides, hydrogen, 

etc. but we have not invested in them. Rather we elect to make energy the old ways with the 

accompanying horrible ecological consequences. We don't correct our mistakes since how we 

make energy now is expedient, corporatized, and highly profitable. (0657-1 [Hartmann, Donald])

Comment: If we were making better use of renewable energy (solar, wind, tide, etc.) at the 

neighborhood level, we could start to envision a state that doesn't need nuclear plants and their 

associated nuclear waste. Other nations around the world are already working on a new 

paradigm, so we need to focus our efforts on catching up to leading edge technology instead of 

continuing with an obsolete model. (0677-5 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: Our area may need more electricity, but there is no present or foreseeable crisis 

that exists. Also a good thought out and ecologically sensitive plan for electricity should be on 

Appendix E NUREG–2176 E-420 October 2016
the drawing boards for our area including, but not limited to: solar, wind, water currents, etc.

(0685-1 [Batista, Carlos])

Comment: There exists alternative means to generate electricity in a cheaper moire 

sustainable manner in South Florida through solar, tidal, and other alternative energy sources. 

Florida should exhaust all other alternatives before building more reactors. (0710-4 [Platt, George 

Seth])

Comment: So it's much better putting solar energy in. We can do the solar panels, put solar 

farms and combination. I don't see why we can't do that and put wind energy, you know, put 

windmills on our house. I don't care. I mean, add a new addition or whatever. Maybe even a 

Gulfstream current, we can put maybe geothermal energy there or somehow harness the 

energy of the Gulfstream. (0721-31-12 [Almirola, Alejandro])

Comment: Therefore, a better thought out and ecologically sensitive plan for electricity should 

be on the drawing boards for an area including but not limited to solar, wind, water currents, et 

cetera. (0721-31-5 [Almirola, Alejandro])

Response: The NRC does not promote any particular form of energy generation, including 

nuclear. However, the NRC does examine energy alternatives as part of its responsibilities 

under the National Environmental Policy Act (NEPA). The staff’s evaluation of renewable 

alternative energy sources, including wind, solar, water-driven, geothermal, fuel cells, and 

biomass, in Section 9.2 of the EIS describes potential impacts from these sources in 

comparison with the proposed action. In Section 9.2 the review team determined that none of 

these renewable energy sources could, by themselves, meet the purpose and need of the 

proposed action; to provide a target of 2,200 MW(e) of baseload power because they are 

incapable of generating baseload power, or (for alternatives such as biomass) 2,200 MW(e) of 

baseload power. Alternatives not requiring new generating capacity, including conservation and 

demandside management, are discussed in Section 9.2.1 of the EIS. The staff concluded in the 

EIS that these technologies did not represent reasonable alternatives because they also could 

not meet the need for 2,200 MW(e) of baseload power in the FPL service territory. The staff 

concluded in Section 9.2 of the EIS that none of the feasible alternative energy options were 

environmentally preferable to the proposed action because the environmental impacts of the 

alternatives were either similar to, or worse than, those of the proposed action. The cost of 

energy alternatives was not considered in the EIS because the options were either not feasible, 

or were not environmentally preferable. 

Ocean and tidal technologies were evaluated in Section 9.2.3.4 and the NRC staff noted that 

both are being developed but are in their infancy and have not been used at utility 

scale. Therefore, the staff concluded that these technologies are not feasible alternatives within 

the FPL region of interest to the construction of a new nuclear power-generation facility that can 

generate 2,200 MW(e) of baseload power at the proposed site. 

The comments did not provide any information that would change the review team's 

conclusions. Therefore, no changes to the EIS were made as a result of these comments. 

Comment: If any nuclear power generation of electricity is approved, then please approve 

breeder reactors for their small waste footprint, and require the use of closed steam systems, 

like a USN nuc sub, where no steam is wasted, steam is cooled and recycled. If land nuc plants 

did that then less water would be wasted for cooling. And for fossil fuel burning plants with 

Appendix E October 2016 E-421 NUREG–2176
recycled steam, no Mercury or nox, sox, or COx would be contributing to poor air quality, health 

and global environmental health of the climate. (0311-1 [Hunt, Jim])

Response: There are not any current plans in the United States to build breeder 

reactors. There are no breeder reactor designs submitted to the NRC for review. Regarding 

Navy submarine cooling systems, they use an open-cycle cooling system, heating the water 

they draw in and then discharging the hotter water back into the ocean. Under current EPA 

regulations, it is unlikely such a system could be approved for a land-based nuclear power 

plant. Finally, the comment regarding emissions from fossil-fueled plants is unclear. All such 

plants emit numerous pollutants that affect air quality. No changes were made to the EIS as a 

result of this comment. 

Comment: Comment 16: The final Environmental Impact Statement should include 

distributive models of energy generation in its review. FPL has stated that "without the 

proposed action, nuclear power generation would decline to 16% of its portfolio by 2021 and 

cause FPL to rely on natural gas power generation for up to 75% of its power generation." DEIS 

at 8-7. This statement assumes that natural gas, or even centralized energy generation, is the 

only alternative to a nuclear power plant. In contrast, the final Environmental Impact Statement 

should assess distributive, or "rooftop," solar power generation options. Although the DEIS 

assess solar farms, it does not include an assessment of distributive options. With this in mind, 

the City of Miami used data from the Florida Solar Energy Center at the University of Central 

Florida to compare the output of a limited distributive generation scenario with nuclear power. 

For simplicity's sake, the City focused only on solar water heaters. Solar water heaters use solar 

energy to heat water and hold that hot water in reserve for consumer use. This brief analysis 

showed that the same energy needs can be met more efficiently with less power output. Not 

only is solar hot water heating a reasonable renewable energy option, it is also more efficient 

than traditional electricity generation for the purposes of heating water. Other economic 

considerations must be incorporated in this analysis, however, the City of Miami believes that if 

a simple change such as adopting widespread use of solar hot water heaters can result in such 

an impact in energy demand, this type of scenario should be considered in the final 

Environmental Impact Statement's analysis of the determination of need for Turkey Point 

Nuclear Plant Units 6 & 7. Equations, Variables, & Givens. Pkw = Ekwh ÷ thr; P = Power in 

kilowatts; E = Energy in kilowatt hours; t = Time in hours; Hours in a year = 8, 765.81 hours. For 

a family of four, typical hot water usage is 25,550 gal/yr at 3,990 kwh/yr to heat electrically. 

Solar hot water heaters save between 50 - 85% of energy expenditure. For the purposes of a 

conservative analysis, the City assumed that solar hot water heaters use 1,995 kwh/yr (or, 50% 

of 3,990 kwh/yr). FPL has 4.7 million customers. Of these, the average number of rural and 

residential customers is 4,230,063. See FPL 10 year site plan. Comparison Point A: 

Calculating Yearly Power from One Solar Hot Water Heater. Pkw = 1,995 kwh ÷ 8, 765.81 

hours = .227 kw; .227 kw = 227 w; 227 w/hr × 24 hours/day = 5,448 w/day; 5,448 w/day × 365 

days/yr = 1,988,520 w/yr; 1,988,520 w/yr × (1.0 × 10-6) MW/w = 1.98852 MW/yr; 1.98852 

MW/yr = power from one solar hot water heater. Comparison Point B: Calculating Yearly 

Power from Turkey Point Nuclear Plant Units 6 & 7. FPL's Target Capacity for Proposed 

Units 6 & 7 = 2,200 MW/hr; 2,200 MW/hr × 24 hr/day = 52,800 MW/day; 52,800 MW/day × 365 

days/yr = 19,272,000 MW/yr; 19,272,000 MW/yr = total projected power generated from Units 6 

& 7. Conclusion Based on a Limited Population of Adopting Ratepayers: Amount of 

Power Produced from Solar Hot Water Heaters from FPL Rural and Residential 

Customers. If one solar water heater produces 1.98852 MW/yr of power, then: 1.98852 MW/yr 

× 4,230,063 rural and residential customers = 8,411,565.88 MW/yr; 8,411,565.88 MW/yr = 

Amount of power produced in one year if FPL rural and residential customers were required to 

have a solar hot water heater. Conclusion Based on Adopting by All Ratepayers: Amount 

Appendix E NUREG–2176 E-422 October 2016
of Power Produced from Solar Hot Water Heaters from all FPL customers. If one solar 

water heater produces 1.98852 MW/yr of power, then: 1.98852 MW/yr × 4,700,000 total 

customers = 9,346,044 MW/yr; 9,346,044 MW/yr = Amount of power produced in one year if all 

of FPL customers were required to have a solar hot water heater. Based on this scenario, the 

City found that almost half of the projected power output of the new reactors can be generated 

using a distributive power generation model even under conservative circumstances. Moreover, 

the final Environmental Impact Statement should assess whether the energy needs anticipated 

by FPL can be met more efficiently with less power output. (0456-23 [Miami, City])

Comment: Comment 17: The final Environmental Impact Statement should include 

distributive models of energy generation in its review. FPL has stated that "without the 

proposed action, nuclear power generation would decline to 16% of its portfolio by 2021 and 

cause FPL to rely on natural gas power generation for up to 75% of its power generation." DEIS 

at 8-7. This statement assumes that natural gas, or even centralized energy generation, is the 

only alternative to a nuclear power plant. In contrast, the final Environmental Impact Statement 

should assess distributive power generation options such as "rooftop" solar. Although the DEIS 

considers solar farms, it does not include an assessment of distributive options. With this in 

mind, the City of Miami used data from the Florida Solar Energy Center at the University of 

Central Florida to compare the efficacy of a limited distributive generation scenario against 

nuclear power. For simplicity's sake, the City focused only on solar water heaters. Solar water 

heaters use solar energy to heat water and hold that hot water in reserve for consumer use. 

This brief analysis showed that the same energy needs can be met more efficiently with less 

power output. Not only is solar hot water heating a reasonable renewable energy option, it is 

also more efficient than traditional electricity generation for the purposes of heating water. Other 

economic considerations must be incorporated in this analysis, however, the City of Miami 

believes that if a simple change such as adopting widespread use of solar hot water heaters can 

result in such an impact in energy demand, this type of scenario should be considered in the 

final Environmental Impact Statement's analysis of the determination of need for Turkey Point 

Nuclear Plant Units 6 & 7. Equations, Variables, & Givens. Pkw = Ekwh ÷ thr P = Power in 

kilowatts, E = Energy in kilowatt hours, t = Time in hours. The reactors will operate at 93% 

capacity; each one generating 8,148 hours/yr (8,760 hours in a year x .93 = 8,148). See DEIS at 

5-69. 8,148 hours ÷ 24 hrs/day = approx. 340 days. For a family of four, typical hot water usage 

is 25,550 gal/yr at 3,990 kwh/yr to heat electrically. Solar hot water heaters save between 50 - 

85% of energy expenditure. For the purposes of a conservative analysis, the City assumed that 

solar hot water heaters use 1,995 kwh/yr (or 50% of 3,990 kwh/yr). FPL has 4.7 million 

customers. Of these, the average number of rural and residential customers is 4,230,063. See 

FPL 10 year site plan. Comparison Point A: Calculating Yearly Power from One Solar Hot Water 

Heater Pkw = 1,995 kwh ÷ 8, 760 hours = .227 kw; .227 kw = 227 w; 227 w/hr × 24 hours/day = 

5,448 w/day; 5,448 w/day × 365 days/yr = 1,988,520 w/yr; 1,988,520 w/yr × (1.0 × 10-6) MW/w 

= 1.98852 MW/yr; 1.98852 MW/yr = power from one solar hot water heater. Comparison Point 

B: Calculating Yearly Power from Turkey Point Nuclear Plant Units 6 & 7, FPL's Target Capacity 

for Proposed Units 6 & 7 = 2,200 MW(e), 2,200 MW/hr × 24 hr/day = 52,800 MW/day, 52,800 

MW/day × 340 days/yr = 17,952,000 MW/yr, 17,952,000 MW/yr = total projected power 

generated from Units 6 & 7. Conclusion Based on a Limited Population of Adopting Ratepayers: 

Amount of Power Produced from Solar Hot Water Heaters from FPL Rural and Residential 

Customers. If one solar water heater produces 1.98852 MW/yr of power, then: 1.98852 MW/yr × 

4,230,063 rural and residential customers = 8,411,565.88 MW/yr, 8,411,565.88 MW/yr = 

Amount of power produced in one year if FPL rural and residential customers were required to 

have a solar hot water heater. 

Appendix E October 2016 E-423 NUREG–2176
Conclusion Based on Adopting by All Ratepayers: Amount of Power Produced from Solar Hot 

Water Heaters from all FPL customers. If one solar water heater produces 1.98852 MW/yr of 

power, then: 1.98852 MW/yr × 4,700,000 total customers = 9,346,044 MW/yr, 9,346,044 MW/yr 

= Amount of power produced in one year if all of FPL customers were required to have a solar 

hot water heater. Based on this scenario, almost half of the projected output of the new reactors 

can be generated using a distributive generation model even under conservative circumstances. 

Florida electric capacity from distributive methods has increased about 33% since 2014. 

http://tinyurl.com/FPSCrenewables. The final Environmental Impact Statement cannot meet the 

"hard look" standard required by NEPA without analyzing distributive energy generation models. 

Expand Consideration of Transmission Line Impacts. The DEIS notes that "[t]ransmissionline construction would fragment habitat and permanently affect pine rocklands that are 

designated as critical habitat for listed species." DEIS at 10-5. However, the impacts of FPL's 

proposed transmission lines are not limited to construction-related disruptions. (0611-16 [Haber, 

Matthew S.])

Comment: There is an attempt to greatly increase solar power in the state of Florida. In the 

past solar water heaters were common. Florida could return to the days of using more solar 

power. Energy efficiency could be increased. Florida has not made a significant effort to 

improve energy efficiency. It ranks behind many states on energy efficiency and does not even 

have a state policy on increasing renewable energy. (0641-9 [Martin, Drew])

Comment: So I know personally it is possible to do distributed generation instead of central 

power plants to do distributed generation. And I think about it all the time. I think about -- and I 

love my solar panels and I love my solar hot water heater, and the solar hot water heater has 

paid for itself many times over already. The solar panels, not quite, and it will take a while to do 

that. But when a hurricane comes and the grid is down, I'm up, I'm running. We have batteries. I 

listened to a Tesla Board of Directors conference call the other day. Tesla, that makes that car, 

the electric car. They have a proposal to build a new whole house battery. How exciting. A 

whole house battery that can keep the house up and running when the sun is not shining or the 

wind is not blowing. (0721-11-4 [Roff, Rhonda])

Comment: So we've got existing technology that will not have any of these impacts I'm talking 

about. The company has not evaluated that reasonable alternative. (0723-9-20 [Schwartz, 

Matthew])

Response: Any alternative energy source must be able to meet the purpose and need of the 

action (i.e., production of 2,200 MW(e) of baseload power to supply the future needs of FPL's 

service territory). In Section 9.2.1 of the EIS, the review team discussed conservation and 

demand site management (DSM) programs (under which residential solar water haters would 

likely fall). The review team pointed out that the FPSC had already approved those 

conservation and DSM programs that it found to be cost-effective. In addition, the FPSC stated 

that there are no additional conservation measures that could effectively mitigate the need for 

the addition of the proposed FPL Units 6 and 7 (FPSC 2008-TN735). Thus, implementation of 

conservation and DSM programs, including domestic solar water heating, is not a reasonable 

alternative for providing baseload power-generating capacity. The review team considered 

solar photovoltaic (PV) power as an alternative in Section 9.2.3.3 of the EIS. The review team 

concluded that the capacity factor of solar PV is too low to be used as a baseload power 

generation source and that it was not a reasonable alternative to the proposed 

action. Considering the relative capacity factors of nuclear and solar PV, to obtain the same 

annual output as nuclear would require almost 10,000 MW of solar panels and energy storage 

on a scale that has not been contemplated in any State. The review team also included solar 

Appendix E NUREG–2176 E-424 October 2016
PV and conservation and DSM as components of the combination of energy alternatives in 

Section 9.2.4. However, the review team concluded in Section 9.2.5 that the combination of 

energy alternatives was not environmentally preferable to the proposed action because the 

environmental impacts of this alternative were similar to those of the proposed action. No 

changes were made to the EIS in response to these comments. 

Comment: The Executive Summary (pg. xxxvi) states that the NRC staff eliminated several 

energy sources (e.g., wind, solar, geothermal, and biomass) from full consideration because 

they are not capable of meeting the need of the project. The EPA would prefer that the NRC 

evaluation consider the combining of renewable energy sources, such as wind and solar, as an 

alternative to meet the needs of the project. (0617-4-12 [Mueller, Heinz J.])

Comment: I think we all share a common goal, more than we want to admit, and that is the 

elimination of CO2 gasses, or at least a drastic reduction. And a combined mixture of wind, 

solar and nuclear is definitely the way to go. Reliable base power and reliable solar and wind, 

especially in the Sunshine State. I've heard the discussion about rooftop solar and solar 

powered -- solar water heaters, and, yes, those are viable options. (0721-15-7 [Kuraza, Devon])

Response: The review team evaluated wind and solar energy as alternatives to the proposed 

reactors in Sections 9.2.3.2 and 9.2.3.3 of the EIS, respectively, and found neither to be a 

feasible discrete alternative to the proposed reactor. The review team identified a combination 

alternative involving natural gas-fired combined-cycle turbines, energy efficiency, and 

contributions from wind and solar as a technically feasible alternative to the proposed FPL Units 

6 and 7. The review team evaluated the environmental and socioeconomic impacts of such a 

combination alternative, summarizing the projected impacts in Table 9-5. In Table 9-6, the 

review team compared the projected impacts of the proposed reactor with all of the alternatives 

that the team found to be technically feasible. The review team applied objective criteria in its 

evaluation of all the options that were considered to be technically feasible and practically 

available alternatives to the proposed reactor for satisfaction of the stated purpose and need to 

provide 2200 MW(e) of baseload power in the FPL service territory, and concluded that the 

combination of energy alternatives was not environmentally preferable to the proposed action 

because the environmental impacts of this alternative were similar to those of the proposed 

action. The comments did not provide any information that would change the review team’s 

conclusions. Therefore, no changes to the EIS were made as a result of these comments. 

Comment: In early 2015, FPL announced the change of the commercial operation dates 

(CODs) for Units 6 & 7 from 2022 and 2023 to 2027 and 2028, respectively. A new and 

significant information review was conducted by FPL where it was concluded that there would 

not be an impact to any significance level or conclusion drawn in the ER with respect to the 

change in CODs. There are instances in the DEIS, however, where references to CODs differ 

from the newly announced CODs. Instances in the DEIS include:...DEIS Section 9.2, Page 9-3, 

Lines 4-12: In DEIS Section 9.2, the in-service dates, along with the impact of extending those 

dates, are mentioned: "The review team's analysis is based on an in-service date for Unit 6 of 

2022 and Unit 7 of 2023 based on FPL's 2014 Ten-Year Plan (FPL 2014-TN3360). Even if the 

actual in-service date were to slip by a few years, the NRC staff would not expect such a 

change to affect the overall conclusions regarding energy alternatives for two reasons. First, the 

projections by FPL and by the U.S. Department of Energy, Energy Information Administration 

(DOE/EIA) that the NRC staff has used in its analyses do not change appreciably in the later 

years and are generally consistent with the data used for 2023. Second, the environmental 

impacts of the feasible alternatives are not likely to change appreciably, so the NRC staff's 

Appendix E October 2016 E-425 NUREG–2176
conclusions regarding environmental preferability are unlikely to change." (0619-1-7 [Maher, 

William])

Response: The EIS text in the Alternative Energy subsection of Section 9.2 was corrected to 

reflect the noted inconsistency with the referenced material. 

Comment: By building massive power plants at one spot, FPL must then distribute that power. 

They want to build massive transmission lines through the Everglades, and along Miami's iconic 

South Dixie Highway. As I understand it, the towers for these lines are not capable of surviving 

a Cat 5, much less the tornadoes that we might also expect. If the power plants are being put in 

to serve public, yet transmission is unsafe, who does this really serve? (0252-12 [Van Leer, Sam])

Comment: By having power generation distributed near points of demand, massive 

transmission lines are not needed. (0252-15 [Van Leer, Sam])

Comment: Start to take stake in the distributed grid reality, take stake in it, get value from it 

and own your customers. Because if there's another utility that pops up via some co-op or 

something that's going to take your client business away, you had those clients because you set 

them up. (0721-34-5 [Gomez, Albert])

Comment: But the elephant in the hallway is the utility company that says, we won't buy your 

power or we won't take it off-grid. We will not allow independent power generators, they're not 

allowed in the State of Florida. You've got a monopoly here. And you know that's what holding 

up the jobs. (0723-12-7 [Henry, Jim])

Response: These comments argue for distributed power generation, an approach that would 

rely on the types of energy alternatives that the review team considered in Section 9.2 of the 

EIS. The alternative energy resources considered in the EIS must be able to meet the purpose 

and need of the action (i.e., production of 2,000 MW(e) of baseload power to supply the future 

needs of FPL's service territory), in order to be considered feasible. While the use of renewable 

energy resources for distributed power generation is growing rapidly in some parts of the United 

States, in Section 9.2 the review team determined that none of these renewable energy sources 

could, by themselves, meet the purpose and need of the proposed action; to provide a large 

baseload power source. No changes were made to the EIS in response to this comment. 

Comment: FPL is pushing for this expansion because it will benefit their bottom line and rate 

payers are stuck with the bill. There are cheaper ways to increase our generation capacity and 

reduce our electrical consumption with energy efficiency upgrades which have been opposed by 

FPL because it would obviously take away from the kWh charged to customers. (0119-2 [de 

Azevedo, Ricardo])

Comment: This project is a waste of taxpayer dollars, which would be more efficiently (and 

safely!) spent on energy efficiency projects. (0661-2 [Segal-Wright, Nicholas])

Comment: Look, it's been well established that energy efficiency is the lowest cost resource in 

meeting electricity demand. It can meet demand with an investment of less than 3 cents per 

kilowatt hour, a fraction of the levelized cost of the proposed reactors which is over 15 cents per 

kilowatt hour. Yet, FPL's past efforts in helping customers reduce energy use and save money 

on their bills through energy efficiency programs, quite frankly, has been abysmal, capturing a 

mere 2/10ths of 1 percent of annual energy sales through energy efficiency programs. However, 

even at these very low levels, had FP&L continued the conservation programs that it had in 

Appendix E NUREG–2176 E-426 October 2016
place in 2013, it would capture over 1,520 megawatts of capacity, about 70 percent of what it 

needs in the 2027/2028, the time frame for the proposed reactors. (0721-8-3 [Cavros, George])

Comment: [U]nfortunately, the people that are hardest hit by these almost non-existent energy 

efficiency programs are folks on fixed incomes and customers like the working poor that may 

not have information or the resources to make their homes more energy efficient. (0721-8-5

[Cavros, George])

Response: Neither the NRC or the USACE establish public policy regarding electric power 

supply alternatives, nor do they promote the use of nuclear power as a preferred energy 

alternative. Decisions regarding which generation sources and alternatives (including energy 

efficiency, conservation, and DSM portfolios) to deploy are made by the applicant and have to 

be confirmed by regulatory bodies such as the FPSC. Energy efficiency and DSM programs 

were reviewed by the FPSC as part of the hearing record, as discussed in Chapter 8 of the 

EIS. In Section 9.2.1 of the EIS, the review team discussed conservation and DSM 

programs. The review team pointed out that the FPSC had already approved those 

conservation and DSM programs that it found to be cost-effective. In addition, the FPSC stated 

that there are no additional conservation measures that could effectively mitigate the need for 

the addition of the proposed FPL Units 6 and 7 (FPSC 2008-TN735). Thus, implementation of 

conservation and DSM programs is not a reasonable alternative for providing baseload powergenerating capacity. 

Chapter 9 of the EIS included discussion of energy efficiency and DSM as part of the no-action 

alternative, and the combination of alternatives. No changes were made to the EIS as a result 

of these comments. 

E.2.25 Comments Concerning Alternatives - System Design 

Comment: They said in the EIS they considered all alternatives, but you might be surprised to 

learn that 40 percent of the nuclear plants on the planet and 20 percent in the United States use 

once-through sea water to cool their reactors. Some will say there's a problem of entrainment 

with that. If you check you will see that their technology has reduced that to a manageable level. 

All of the reactors in Britain, I think in South Korea, and a few other cities, use once-through sea 

water, and just think of the problems that that eliminates. You put pipes out as far as you have 

to, into the Gulfstream if you have to. You bring in water, it goes through the reactor once, [and] 

it goes back out into the Gulfstream; done, finished. All these problems we're talking about go 

away. (0721-12-12 [White, Barry J.])

Response: Alternative heat dissipation systems are addressed in Section 9.4.1 of this EIS, 

which includes consideration of the type of cooling system described in the comment. None of 

the systems and/or designs that were evaluated were found to be environmentally preferable to 

the system design that is proposed for the Turkey Point site. Because this comment did not 

offer any new or significant information about environmental impacts, it did not result in any 

changes to the EIS. 

E.2.26 Comments Concerning Alternatives - Sites 

Comment: Can this not be erected/expanded in Central or Northern Florida? There are 

municipalities going completely off grid and Costa Rica has been running on Hydropower for 

more than a month. Yet Florida is adding on to a run-down nuclear reactor? (0008-9 [Finver, 

Jody])

Appendix E October 2016 E-427 NUREG–2176
Comment: We can not believe that there is not a remote place (still many in Florida) to build 

these things. (0040-2 [Pareto, Rolando and Marlene])

Comment: I am not against nuclear power per se. I just think it should be located away from 

populated areas. When I first moved to South Florida from Rhode Island, I was not aware that 

such a plant would be essentially in my backyard. (0061-3 [Lague, Victoria])

Comment: There are significantly large, low population sites on the eastern Florida shoreline 

that could be used for a modern nuclear facility. It is simply irresponsible to increase the already 

inflicted damage and the threat to our vulnerable area. (0083-2 [Birsh, Arthur and Joan])

Comment: FPL has petitioned NRC to expand the nuclear power plant at Turkey Point. This 

location was chosen because of the existence of multiple power plants at the same site, 

including two currently operating nuclear reactors. The convenience and logistical advantages 

for this site are counterbalanced by the detrimental effect the existing plants are having on the 

ecology and water supply for Miami-Dade. (0172-1 [Cava, Daniella Levine])

Comment: We are not against nuclear power, but feel that rural North Florida would be a better 

location since fewer people would be affected in the event of a system problem. (0212-3 [Ross, 

Robert and Teresa])

Comment: Isn't there a more acceptable place for a nuclear reactor besides next to TWO 

national parks? (0220-1 [Spigel, Sue])

Comment: I was shocked to learn that the reactor had been allowed in the first place. The 

Nuclear Regulatory Commission's regulations state, "sites adjacent to lands devoted to public 

use may be considered unsuitable," and unacceptable impacts are "most apt to arise in areas 

adjacent to natural-resource-oriented areas." Within six miles of the proposed expansion site 

there are two national parks, an aquatic preserve, a national wildlife refuge, and a wetland 

habitat preserve. (0295-2 [Dietrich, Chris OMeara])

Comment: There are better locations for this. (0305-1 [Poese, David])

Comment: That's not the smartest choice to place nuclear reactors. (0347-1 [Petersen, John])

Comment: I question the thinking behind this without much thought or regard for the location it 

is in. (0349-2 [Oliva, Vivian])

Comment: It is dangerous to have nuclear plants in populated, hurricane-prone areas. (0359-1

[LoBiondo, Roana and Michael])

Comment: Follow your own regulations and say NO Expandtion. Case Closed, find a new 

loaction Turkey Point.. (0392-2 [Greer, Tom])

Comment: There must certainly be better sites to build this power plant. Why not inland on the 

east coast of FL? This is where there is more demand. (0452-1 [Karsten, Annetta])

Comment: I ask. Where is the conscience of those proposing this project. It's likely true that no 

one wants this stuff in their back yard. But, there must be a better place than this for the 

monstrosity[.] (0484-1 [Speno, Charlie])

Appendix E NUREG–2176 E-428 October 2016
Comment: I have visited friends who lived a few blocks from Tampa Bay and thought it an 

extremely risky place to be. (0492-2 [Mckee, Sarah])

Comment: It would seem to an intelligent person that your regulations would forbid you from 

undertaking an expansion in this area. (0526-1 [Kimball, Larry])

Comment: Get real and build these energy plants somewhere else. (0538-1 [Willett, Greg])

Comment: The draft EIS completely omits these important considerations of the proposed 

siting and the resulting hazards they present to the environment and public health. (0615-2-24

[Bethune, David])

Comment: Please don't build the plants in Homestead. (0686-1 [Sachs, Jean])

Comment: What this really is all about is, is this the place that you want to put a nuclear power 

plant, and the answer is resoundingly no. (0721-30-7 [Ullman, John])

Response: FPL conducted a site-selection study and chose the proposed site at Turkey Point 

based on that study. Included in the FPL study was a site-by-site comparison of alternative 

sites with the Turkey Point site. The NRC staff evaluated the FPL process in Section 9.3.1 of 

the EIS and concluded that it was reasonable and consistent with the NRC guidance for site 

selection (e.g., NUREG-1555). For example, as discussed in Section 9.3.1.1, FPL used its 

service territory as the region of interest, consistent with NUREG-1555. In addition, the NRC 

staff independently compared the alternative sites to the proposed site to determine if any of the 

alternative sites were environmentally preferable to the proposed site. In Section 9.3.6 of the 

EIS, the NRC staff concluded that none of the alternative sites was environmentally preferable 

to the proposed Turkey Point site. In addition, the NRC staff would determine whether building 

and operating the proposed units at the Turkey Point site would meet all of the safety 

requirements in the NRC regulations. The results of this review will be documented in a safety 

evaluation report and those results, along with the EIS, will be considered in the NRC’s decision 

about whether or not to issue the COLs for proposed Units 6 and 7. No change was made to 

the EIS as a result of these comments. 

Comment: Given the proximity of Turkey Point to the major population centers of South 

Florida, its location close to the environmentally sensitive, irreplaceable, Florida Everglades, 

Everglades National Park and Biscayne National Park, the Turkey Point Nuclear Power Plant 

exposes the population and environment of South Florida to unintended, but nevertheless, 

extraordinary risk. (0039-3 [Violich, Francesca])

Comment: Given the proximity of Turkey Point to the major population centers of South 

Florida, its location immediately contiguous to the environmentally sensitive, fragile and 

irreplaceable, Florida Everglades, Everglades National Park, Biscayne National Park, and the 

Florida Keys Marine Sanctuary, the Turkey Point Nuclear Power Plant exposes the population 

and natural environment of South Florida to unintended, but nevertheless, extraordinary 

risk. The conditions that were present when The Turkey Point facility was originally sited and 

constructed in the early 1970s are not the same conditions that exist today. Those original 

conditions and considerations that may have made Turkey Point a viable location for a Nuclear 

Power Generating Plant have changed dramatically in the ensuing years. (0044-3 [Commenters, 

Multiple])

Appendix E October 2016 E-429 NUREG–2176
Comment: The two fold increase in the population density of Miami-Dade County over the last 

40 years to approximately 2,500,000.people, coupled with the growing recognition of the value 

and need for preservation and protection of the fragile and irreplaceable natural resources that 

surround the plant, require serious reconsideration of this location for Nuclear Power 

generation. (0044-5 [Commenters, Multiple])

Comment: Turkey Point's neighborhood includes Biscayne National Park, and four other parks, 

wildlife and nature preserves, habitats and refuges. This is an extremely sensitive, 

irreplaceable and biodiverse area which could be devastated by even small amounts of the 

Uranium 235 fuel, Plutonium and other deadly toxic substances used in and generated by 

nuclear plants. (0078-8 [Wilansky, Laura Sue])

Comment: Like so many Americans, I am committed to protecting the National Park System, 

which preserves our country's incredible array of landscapes, waters, wildlife, and opportunities 

for exploration. Biscayne National Park is an irreplaceable national treasure that safeguards 

precious natural resources and recreational opportunities. According to the Nuclear Regulatory 

Commission's own regulations, "sites adjacent to lands devoted to public use may be 

considered unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to 

natural-resource-oriented areas." Within six miles of the proposed expansion site, there are two 

national parks, an aquatic preserve, a national wildlife refuge, and a wetland habitat preserve. In 

following the NRC's own guidelines, the expansion of Turkey Point could have unacceptable 

and irreversible impacts on these treasured sites. (0102-4 [Commenters, Multiple])

Comment: Like so many Americans, I love our national parks, which preserve our country's 

incredible landscapes and waters, wildlife and opportunities for exploration. Biscayne National 

Park is one of these irreplaceable national treasures. According to the Nuclear Regulatory 

Commission's own rules, "sites adjacent to lands devoted to public use may be considered 

unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to naturalresource-oriented areas." How then can this project proceed when there are two national parks, 

an aquatic preserve, a wetland preserve and a national wildlife refuge within six miles of the 

proposed expansion site? (0103-4 [Commenters, Multiple])

Comment: The proposed action threatens nearby Biscayne and Everglades National Parks 

and the goals and activities of the Comprehensive Everglades Restoration Plan (CERP).

(0113-1-3 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, 

Rachel])

Comment: Finally, the draft EIS fails to properly and fully consider the superior rated alternate 

sites for the placement of the two new plants, sites which are located in areas significantly less 

vulnerable to sea level rise, storm surge and a location of Turkey Point with highly dense urban 

populations that would compete for water. It is clear that the site selection process was overly 

biased in favor of building on an existing FPL power plant site, and completely ignored the over 

stressed current conditions under which Turkey Point is currently operating on a temporary 

management plan to avert a crisis shut down. It is not clear, or substantiated, how that would 

factor into the determination that the Turkey Point site could possibly remain the superior site for 

two new plants rather than the proposed alternate sites that do not currently operate under crisis 

conditions. The determination of alternate sites is highly subjective, and the statement fails to 

adequately provide fact specific comparative analysis on the rationale for excluding the alternate 

sites as environmentally preferable. Neither of those sites are located on as vulnerable a coastal 

location, neither are located in the middle of two National parks, and neither would impact the 

sole drinking source for more than four million Floridians. (0145-13 [Lerner, Cindy])

Appendix E NUREG–2176 E-430 October 2016
Comment: The Biscayne and Everglades National Parks are should not be stressed by this ill 

conceived project. They will be forever changed by this in ways we cannot even begin to 

imagine. (0159-2 [Bazzone, Barbara])

Comment: We have a duty to protect our National Parks and if this situation doesn't warrant 

protecting I don't know what is. (0176-1 [Sheridan, Michelle])

Comment: The fact that the existing plant is on the shore of the largest marine park in the 

National Park System makes it doubly foolish. (0181-2 [Bremen, Gary])

Comment: This is an area I lived near for many years. It is indeed treasured for its wildlife and 

beauty. What a shame to jeopardize all this. (0185-1 [Balog, Nancy])

Comment: This site was never an acceptable location for the Turkey Point facility there today 

and many decades later it has only become an even more unacceptable location[.] (0192-5

[Lebatard, David])

Comment: Our national parks protect some of our nation's most treasured natural and 

historical sites. The protection of these parks and their wildlife should be a priority in order that 

they may remain as they are for future generations. (0198-1 [Tokunaga, Barb])

Comment: Further, we are concerned by the wide-ranging environmental impacts to Biscayne 

National Park, wildlife, and adjacent wetlands. (0208-2 [Ritz, David])

Comment: The proposed action threatens nearby Biscayne National Parks and the goals of 

the Comprehensive Everglades Restoration Plan (CERP). (0208-5 [Ritz, David])

Comment: 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 a UNESCO World Heritage Site and 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. These natural areas offer critical 

protection to sensitive ecological areas, wildlife, and unique habitat and support the local 

economy through recreational opportunities, tourism and the provision of ecological goods and 

services. Biscayne and Everglades National Parks alone generate nearly $137 million in local 

revenue from 1.6 million annual visitors. According to the standards of the Nuclear Regulatory 

Commission ("NRC"), "sites adjacent to lands devoted to public use may be considered 

unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to natural---

resource---oriented areas."1 According the NRC's own standards, Turkey Point should not be 

expanded due to the potential for unacceptable impacts to the ecological health and economic 

viability of surrounding protected areas. (0210-2 [Sharp, Andrea Heuson])

Comment: Like so many Americans, I am committed to protecting the National Park System, 

which preserves our country's incredible array of landscapes, waters, wildlife, and opportunities 

for exploration. Biscayne National Park is an irreplaceable national treasure that safeguards 

precious natural resources and recreational opportunities. According to the Nuclear Regulatory 

Commission's own regulations, "sites adjacent to lands devoted to public use may be 

considered unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to 

natural-resource-oriented areas." Within six miles of the proposed expansion site, there are two 

national parks, an aquatic preserve, a national wildlife refuge, and a wetland habitat preserve. In 

Appendix E October 2016 E-431 NUREG–2176
following the NRC's own guidelines, Turkey Point's expansion would have unacceptable and 

irreversible impacts on these treasured sites. (0228-4 [Yeager, Jerry])

Comment: It [nuclear energy] should also not be located at such low sea level and next to two 

National Parks. Let's make intelligent choices. How many millions are we investing to restore 

the Everglades? Let's plan with vision and make sound decisions! (0235-2 [Bofill, Beatriz])

Comment: Two of South Florida's most important public lands and wildlife habitats - Biscayne 

and Everglades National Parks - will be put at risk and be forever changed by a project of this 

scale. Wherever you happen to live - South Florida or not - these special places (hotspots for 

our planet's biodiversity) are a part of your natural heritage. (0240-2 [Commenters, Multiple])

Comment: Please have some deep thoughts to safeguard the wildlife and also the livelihood of 

ALL living beings in Biscayne & Everglades National Park. Your project will forever be harmful 

to the environment. Our Nation Heritage must be well looked after. Wise people like you know 

that this project is harmful. So Please, Please have a serious thought before it is too late. A 

project like this should be carried out at a different location. (0247-1 [Govindasamy, Rani])

Comment: Comes now the NRC drafting two new reactors located off Biscayne and 

Everglades National Parks. . . what are they thinking? (0250-2 [Fulks, Anna Louise])

Comment: Everglades National Park is just a few miles away. (0252-7 [Van Leer, Sam])

Comment: 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 a UNESCO World Heritage Site and 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. These natural areas offer critical 

protection to sensitive ecosystems, wildlife, and unique habitat and support the local economy 

through recreational opportunities, tourism and the provision of ecological goods and 

services. Biscayne and Everglades National Parks alone generate nearly $200 million of 

economic output from 1.6 million annual visitors. According to the standards of the Nuclear 

Regulatory Commission ("NRC"), "sites adjacent to lands devoted to public use may be 

considered unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to 

natural resource-oriented areas."1 [Footnote 1: U.S. Nuclear Regulatory Commission, 

Regulatory Guide 4.7- General Site Suitability Criteria for Nuclear Power Stations, Revision 2, 

1998, Section C.] According the NRC's own standards, Turkey Point should not be expanded 

due to the potential for unacceptable impacts to the ecological health and economic viability of 

surrounding protected areas. (0253-2 [Bloom, Justin] [Campbell, Cara] [Causey, Charlie] [Cavros, 

George] [Chenoweth, Mike] [Daly, Meg] [England, Margaret] [Fuller, Manley] [Jones, George L.] [Keller, 

Alan] [Martin, Drew] [McLaughlin, Caroline] [Reynolds, Laura] [Silverstein, Rachel] [White, Paton] 

[Williams, Elinor])

Comment: Turkey Point is located directly on the shores of Biscayne National Park, one of our 

country's largest marine national parks, and home to incredible biodiversity and important 

marine and wetland habitat. The plant is located within six miles of two national parks, a state 

aquatic preserve, a national wildlife refuge, and a wetland habitat preserve. Biscayne and 

Everglades National Parks alone generate close to $137 million in local revenue due to 1.6 

million visitors per year, as of 2014. According to the standards of the Nuclear Regulatory 

Commission (NRC), "sites adjacent to lands devoted to public use may be considered 

Appendix E NUREG–2176 E-432 October 2016
unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to naturalresource-oriented areas."1 [Footnote1 Text: U.S. Nuclear Regulatory Commission, Regulatory 

Guide 4.7- General Site Suitability Criteria for Nuclear Power Stations, Revision 2, 1998, 

Section C.] In following the NRC's own standards, we advise against moving forward with the 

project as proposed due to the potential for unacceptable impacts on the ecological integrity and 

economic viability of the surrounding protected natural areas. (0254-2 [Dudley, Dwight] [Lerner, 

Cindy] [Regalado, Tomas] [Stoddard, Philip K.])

Comment: Please choose to protect Biscayne National Park's incredible wetland and marine 

habitats from the threat of nuclear expansion. Expanding a nuclear power plant directly on the 

shores of Biscayne National Park--in an area vulnerable to sea level rise--will have serious 

environmental consequences! The NRC and the Corps must ensure that future plans for Turkey 

Point protect our national parks, water supply, and public health. (0258-5 [Field, Fran])

Comment: THE PROPOSED EXPANSION IS NOT JUST IMPRUDENT FOR THE PARK AND 

HENCE THE PEOPLE OF THE COUNTRY AS A WHOLE, IT IS SIMPLY ANOTHER GREEDINSPIRED ATTEMPT AT DEVELOPING AN AREA WHICH IS CRUCIAL TO THE SURVIVAL 

OF MANY ENDANGERED SPECIES. (0261-1 [Chirillo, James])

Comment: The two fold increase in the population density of Miami-Dade County over the last 

40 years to approximately 2,500,000. people, coupled with the growing recognition of the value 

and need for preservation and protection of the fragile and irreplaceable natural resources that 

surround the plant, require serious reconsideration of this location for Nuclear Power 

generation. (0263-3 [Orzechowicz, Holly])

Comment: According to the Nuclear Regulatory Commission's own regulations, "sites adjacent 

to lands devoted to public use may be considered unsuitable," and unacceptable impacts are 

"most apt to arise in areas adjacent to natural-resource-oriented areas." Within six miles of the 

proposed expansion site, there are two national parks, an aquatic preserve, a national wildlife 

refuge, and a wetland habitat preserve. In following the NRC's own guidelines, the expansion of 

Turkey Point could have unacceptable and irreversible impacts on these treasured sites. (0277-1

[Mendelsohn, Alex])

Comment: This is the exact definition of being "adjacent to lands devoted to public use," 

making the site unsuitable, and "adjacent to natural-resource-oriented areas," making the 

impacts of the expansion of Turkey Point, which could well be irreversible, unacceptable.

(0278-1 [Fass, Amy])

Comment: Perhaps nuclear power plants should be taken elsewhere away from our U.S. 

National Parks. An idea for relocation is Antarctica or the Arctic Circle. (0300-1 [Van Pelt, Jason])

Comment: Nuclear expansion can and should be viewed positively as something we can 

harness for the good of humankind. Nonetheless anything nuclear must be kept far away from 

National Parks of The United States of America. (0300-3 [Van Pelt, Jason])

Comment: This goes far beyond the discussion of whether nuclear power is the right or wrong 

choice at this point in time, said Matthew Schwartz, executive director at South Florida 

Wildlands Association. Biodiversity in the ecosystem surrounding the existing Turkey Point plant 

is second to none. This is absolutely the wrong location for a massive new engineering project 

of this scale. (0349-3 [Oliva, Vivian])

Appendix E October 2016 E-433 NUREG–2176
Comment: The Everglades and Biscayne Bay are one of only one place like this all over the 

world. Though I realize the importance of the power needed I do think the Commission needs to 

look at the overall picture. (0352-1 [Tingle, Peggy])

Comment: why would FPL need to expand a nuclear plant at all in such a sensitive marine 

park and eco zone? There is a state-managed aquatic preserve, expansive wetland habitat 

preserve, two national parks and a national wildlife refuge all within six miles of the proposed 

site. (0353-2 [Royce, M.])

Comment: Marine parks and huge nuclear plants simply dont go together. Important natural 

resources would be in serious jeopardy. I'll let the experts explain further the dangers to wildlife 

and the population, as well as ecotourism. (0353-6 [Royce, M.])

Comment: There are a state-managed aquatic preserve, expansive wetland habitat preserve, 

two national parks and a national wildlife refuge all within six miles of the proposed site. (0356-13

[Shlackman, Jed])

Comment: This goes far beyond the discussion of whether nuclear power is the right or wrong 

choice at this point in time, said Matthew Schwartz, executive director at South Florida 

Wildlands Association. Biodiversity in the ecosystem surrounding the existing Turkey Point plant 

is second to none. This is absolutely the wrong location for a massive new engineering project 

of this scale. (0356-7 [Shlackman, Jed])

Comment: Turkey Point is on the shoreline and adjacent to Biscayne National Park, one of the 

nations largest marine parks famous as an ecotourism destination and teeming with wildlife, 

said Jaclyn Lopez, Florida director at the Center for Biological Diversity. But with two new 

reactors, Turkey Point would become one of the largest nuclear facilities in the country. Marine 

parks and huge nuclear plants simply dont go together. Important natural resources would be in 

serious jeopardy. (0356-8 [Shlackman, Jed])

Comment: I strongly oppose the building of any new nuclear reactors in or near Biscayne Bay.

(0360-1 [Palmer, Majorie])

Comment: The two nuclear plants are poorly placed because the massive new reactors are 

adjacent to Biscayne National Park-one of the nation's largest marine parks. (0366-2 [Griffith, Ed 

and Harriet])

Comment: Within just six miles of the proposed site there are a state-managed aquatic 

preserve, expansive wetland habitat preserve, two national parks and a national wildlife refuge.

(0366-6 [Griffith, Ed and Harriet])

Comment: There are a state-managed aquatic preserve, expansive wetland habitat preserve, 

two national parks and a national wildlife refuge all within six miles of the proposed site. (0370-12

[Vayu, Satya])

Comment: But building reactors in a place like this is even more outrageous. Biodiversity in the 

ecosystem surrounding the existing Turkey Point plant is second to none. This is absolutely the 

wrong location for any massive new engineering project of this scale. Turkey Point is on the 

shoreline and adjacent to Biscayne National Park, one of the nations largest marine parks 

famous as an ecotourism destination and teeming with wildlife. Marine parks and huge nuclear 

plants simply dont go together. (0370-6 [Vayu, Satya])

Appendix E NUREG–2176 E-434 October 2016
Comment: So what do they suggest instead-let's do more environmental harm to south Florida 

& the Everglades, because Tallahassee says we can. Miami-Dade, Coral Gables & Pinecrest 

governments all disapprove of this, the residents disapprove of this, and somehow that doesn't 

matter. (0372-4 [Ortiz, Natalia])

Comment: I have just read my email about the proposed Nuclear site near Biscayne Bay and 

Florida Everglades. I am not sure where the decision making is, but that is totally the wrong site. 

We in Florida have been fighting the preservation of both our National Parks here in South 

Florida for years. I am asking you to please choose another site, This operation will totally ruin 

those Parks . Both Parks are a lifeline for our coastal and freshwater birds and animals, which 

certainly will suffer as will our tourism. Florida has been fighting for years to save our "River of 

Grass" Please reconsider your choice. (0376-1 [Headley, Linda])

Comment: Within six miles of the proposed expansion site, there are two national parks, the 

Everglades and Biscayne, an aquatic preserve, a national wildlife refuge, and a wetland habitat 

preserve. This area is also extremely vulnerable to sea level rise and the impacts of climate 

change. Turkey Point was never a "good" site to develop an expansive power plant; decades 

later it is only more clear that this is a wholly unacceptable location. (0379-3 [Commenters, 

Multiple])

Comment: ABSOLUTELY NO NUCLEAR PLANTS, OLD OR NEW, NEAR NATIONAL PARKS 

IN USA!!! (0396-1 [Melby, George M.])

Comment: I am astonished and appalled that a nuclear plant would be put in a National Park. 

This is an OUTRAGE and is UNacceptable!! (0405-1 [Macy, Michelle])

Comment: Within six miles of the proposed expansion site, there are two national parks, an 

aquatic preserve, a national wildlife refuge, and a wetland habitat preserve. In following the 

NRC's own guidelines, the expansion of Turkey Point will have unacceptable and irreversible 

impacts on these treasured sites. (0413-3 [Cobb, Tanya])

Comment: I am all for building more nuclear power plants, but not in this location due both to 

its proximity to the Biscayne National Park and susceptibility to rising water and flooding. (0418-1

[Goldstein, Louis])

Comment: When are people going to realize that public lands are not meant for private for 

profit companies, especially at the cost of the environment. (0420-1 [Revord, Michael])

Comment: I also approve of the use of clean renewable energy resources and have nothing 

against Nuclean Power per se; however, additional nuclear power plants in the sensitive area of 

Turkey Point is not a good idea. It may even be a very dangerous idea. Think about this. (0421-1

[Malpass, Betsy])

Comment: According to the Nuclear Regulatory Commission's own regulations, "sites adjacent 

to lands devoted to public use may be considered unsuitable," and unacceptable impacts are 

"most apt to arise in areas adjacent to natural-resource-oriented areas." Which part of these 

regulations are considered unimportant? Why are they unimportant? (0437-1 [Livingston, C. J.])

Comment: Clarify Rationale for Selecting Turkey Point as the New Reactor Site. The 

DEIS outlines the legal framework for the alternative site selection process and describes some 

of the criteria used in selecting the final site for the new reactors. The site selection criteria 

included: •Avoidance of high-population areas, •Avoidance of ecologically sensitive and special 

Appendix E October 2016 E-435 NUREG–2176
designation areas, •Avoidance of special dedicated land uses (e.g., national parks), •Proximity 

to target transmission/load centers, •A minimum size of 5,000 acres, etc. At first glance, the 

Turkey Point site does not rate highly on these measures. The site itself is within 25 miles of 

Miami, the densest population center in Florida and the second most populous city in the state. 

Likewise, the site is sandwiched between two national parks and sits atop the Biscayne Aquifer, 

the sole source of drinking water for most of Miami-Dade and Broward Counties. Instead, the 

text of the DEIS suggests that Turkey Point was chosen as the site for the new reactors 

primarily to satisfy the company's business objectives. The DEIS states: Of the original 21 

potential sites FPL selected the top 8 ranked sites, and even though they ranked below these 

8 sites, FPL also retained the Turkey Point and St. Lucie sites "based on the fact that they are 

existing, operating nuclear power plant sites within the ROI," and FPL's determination that the 

sites fall within "the special case (described above) for licensed nuclear power plant sites." DEIS 

at 9-39. The DEIS goes on to conclude that "FPL selected the Turkey Point site as its proposed 

site based on this ranking and its determination that the site was the preferred site for meeting 

FPL's overall business objectives." DEIS at 9-40. (0456-3 [Miami, City])

Comment: Comment 1: The final Environmental Impact Statement should clarify the 

Nuclear Regulatory Commission's assessment of the site selection analysis conducted 

by FPL. Tables 9.3-5 and 9.3-6 of FPL's Environmental Report compare Turkey Point with the 

alternate sites across a range of criteria. As noted above, the DEIS describes some of these 

criteria. Within Table 9.3-6, entitled "Candidate Site Rankings," the Technical Analysis 

Composite Rating/Score for each candidate site is compared against several categories, all of 

which appear to be given equal weight. These categories included land acquisition, site layout, 

public acceptance, and political considerations. However, the score that matters most within this 

framework, the reliability of electrical generation, is also the metric on which Turkey Point 

scored the lowest compared to all alternative sites. Generating additional and reliable baseload 

power is the primary motivation for constructing the additional reactors. Hence, the final 

Environmental Impact Statement, as a decision-making tool, should clarify the rationale for 

proceeding with the Turkey Point site despite the low score on reliability of electrical generation.

(0456-4 [Miami, City])

Comment: Comment 2: The final Environmental Impact Statement should expand its 

discussion of the criteria that make Turkey Point a suitable site in comparison to the 

alternatives considered by FPL. As noted above, the Turkey Point site does not appear to 

rate highly on many of the site selection criteria specifically mentioned in the DEIS. From the 

City's perspective, Turkey Point is a poor site for the placement of two nuclear reactors that will 

presumably operate for the majority of the 21st Century. Turkey Point's proximity to large 

population centers, two national parks, the comparably few evacuation routes available to 

nearby residents, its location atop a single source aquifer, and the site's vulnerability to extreme 

storm surges are only the most obvious reasons to question FPL's choice. (0456-5 [Miami, City])

Comment: In contrast, the Glades alternative site is: Located further from major population 

centers, Would experience fewer impacts from sea-level rise or extreme storm surge, Near only 

a small portion of Big Cypress National Preserve, Could draw its cooling water from a 

groundwater source that is generally not used for other purposes due to the salinity of that 

water. DEIS at 9-57. The primary drawbacks to placing the reactors at this site appear to be that 

it would impact unique farmland and it would require a variance from the local comprehensive 

plan. DEIS at 9-53 and 9-55. Compared to the problems presented by operating additional 

reactors near the critical and protected ecosystems at Turkey Point, these issues seem 

minor. Therefore, the final Environmental Impact Statement would benefit from an expanded 

Appendix E NUREG–2176 E-436 October 2016
discussion of the criteria that led to Turkey Point's selection as the final site for the new reactors.

(0456-7 [Miami, City])

Comment: Comment 3: The final Environmental Impact Statement should expand the 

site selection scoring criteria to include sea-level rise resilience. Extreme storm surges 

made possible by sea-level rise and intense storms can affect saltwater intrusion into 

groundwater resources, thereby affecting the regional availability of freshwater. There are 

obvious safety implications for storm surges near the reactor site as well. For these reasons, 

resilience against problems associated with sea-level rise should be incorporated into the site 

selection scoring criteria. (0456-9 [Miami, City])

Comment: All questions of whether or not we should have more nuclear power aside, why by 

Biscayne National Park. Just tell them no. (0471-1 [Manter, Larry])

Comment: As retirees, Jan and I travel frequently, and our interest centers on national parks 

and historic sites. The site proposed for expansion is located directly on the shores of Biscayne 

National Park in an area that is extremely susceptible to sea level rise and the impacts of 

climate change. (0485-1 [Blair, Dan])

Comment: Certainly there is a better place to put this (or not put it anywhere) where precious 

wildlife, the environment and humans won't be affected. (0486-1 [Douglas, Carolyn])

Comment: I am not against nuclear power. However, construction of nuclear power plants next 

to National Parks is not good policy. (0512-1 [Grill, Brock])

Comment: I live across the street from the Everglades National park and moved here for the 

beauty and naturalness of this place. I grow organic like many of my neighbors and do not 

support nuclear power in a place like this for obvious reasons. Whether I live here or not, I care 

about the earth, and you should too! Waters, wildlife and opportunities for exploration. (0519-1

[Togati, Joanne])

Comment: I frequent and enjoy our national parks; they preserve our country's incredible 

landscapes and waters, wildlife and opportunities for exploration. (0522-1 [Routh, Jeffrey])

Comment: Two of South Florida's most important public lands and wildlife habitats -Biscayne 

and Everglades National Parks -will be put at risk and be forever changed by a project of this 

scale. (0537-2 [Anonymous, Judi])

Comment: We need to stop and think about the consequences of our actions on our delicate 

environment here in South Florida. (0537-7 [Anonymous, Judi])

Comment: Like so many Americans, I am committed to protecting the National Park System, 

which preserves our country's incredible array of landscapes, waters, wildlife, and opportunities 

for exploration. Biscayne National Park is an irreplaceable national treasure that safeguards 

precious natural resources and recreational opportunities. According to the Nuclear Regulatory 

Commission's own regulations, "sites adjacent to lands devoted to public use may be 

considered unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to 

natural-resource-oriented areas." Within six miles of the proposed expansion site, there are two 

national parks, an aquatic preserve, a national wildlife refuge, and a wetland habitat preserve. In 

following the NRC's own guidelines, the expansion of Turkey Point could have unacceptable 

Appendix E October 2016 E-437 NUREG–2176
and irreversible impacts on these treasured sites. ***Take note of your own regulations and 

adhere to them Now!!! (0540-3 [Burge, Laura])

Comment: I am against building a nuclear plant in Biscayne Bay! I think it could destroy habitat 

and fish and wildlife and maybe people. I understand FPL is trying to update but let's not kill my 

favorite park! (0549-1 [Allison, Noreen])

Comment: Like so many Americans, I am committed to protecting the National Park System, 

which preserves our country's incredible array of landscapes, waters, wildlife, and opportunities 

for exploration. Biscayne National Park is an irreplaceable national treasure that safeguards 

precious natural resources and recreational opportunities. According to the Nuclear Regulatory 

Commission's own regulations, "sites adjacent to lands devoted to public use may be 

considered unsuitable," and unacceptable impacts are "most apt to arise in areas adjacent to 

natural-resource-oriented areas." Within six miles of the proposed expansion site, there are two 

national parks, an aquatic preserve, a national wildlife refuge, and a wetland habitat preserve. In 

following the Nuclear Regulatory Commission's own guidelines, the expansion of Turkey Point 

could have unacceptable and irreversible impacts on these treasured sites. "Every man who 

appreciates the majesty and beauty of the wilderness and of wild life, should strike hands with 

the farsighted men who wish to preserve our material resources, in the effort to keep our forests 

and our game beasts, game-birds, and game-fish--indeed, all the living creatures of prairie and 

woodland and seashore--from wanton destruction. Above all, we should realize that the effort 

toward this end is essentially a democratic movement." --Theodore Roosevelt (0555-2 [Lish, 

Christopher])

Comment: Save the parks. (0587-1 [Glasshof, Wendy])

Comment: Because the site designated for this expansion is on the shores of Biscayne 

National Park, this seems an unwise location for a nuclear operation. (0588-2 [Hanna, Jane])

Comment: I treasure our National Parks and am grateful for the wisdom of past leaders who 

insured these special areas would be here for generations to come. The very suggestion that 

the Biscayne National Park would be put at risk by the expansion of Turkey Point doesn't make 

any sense. We must not continue to supply our power by nuclear means and certainly not in 

ecologically sensitive and incredibly special ecological areas. (0588-3 [Hanna, Jane])

Comment: In adjacent areas are other sites that need protection, another res;possible reason 

that the Turkey Point site be closed rather than expanded. For far too numerous reasons this 

plan would threaten many environmentally sensitive areas, this expansion must be prevented. I 

urge your support for my concerns. Once an area is destroyed, it cannot be resurrected. (0588-4

[Hanna, Jane])

Comment: We have serious concerns that the proposed expansion of FPL's Turkey Point 

could significantly impact and degrade the health of our national parks, sensitive ecological 

areas including extensive wetlands, federally listed threatened and endangered wildlife, and the 

quality and quantity of limited fresh water resources. We request that both agencies support the 

"No Action" alternative in reference to Docket ID: NRC-2009-0337. (0592-12 [Brexel, Sr., Charles])

Comment: There are many reasons why Turkey Point is a terrible location. There are sensitive 

national parks (Everglades and Biscayne), a wildlife refuge and sensitive wetland habitats very 

close to the site. (0594-1 [Rapuano, Shannon])

Appendix E NUREG–2176 E-438 October 2016
Comment: It is of course rather unusual to have a nuclear power plant right on the border of a 

national park. But as I understand it, the plant was there first, and it was necessary to work with 

the existing situation when establishing Biscayne National Park. Because of this, there is no 

justification in using the existing plant as a justification for adding more nuclear plants. (0605-1

[Mundhenk, Norm])

Comment: Glades, Martin, Okeechobee, and St. Lucie were evaluated as alternative sites for 

nuclear stations. The NRC staff concluded that all of these alternative sites were generally 

comparable, and that it would be difficult to state that one site is preferable to another, from an 

environmental perspective. The DEIS then concludes that the Turkey Point site prevailed 

because "none of the alternatives is environmentally preferable to the proposed site, " (page 

xxxvii). We also note that the proposed islands for Units 6 and 7 would be elevated 20-25 feet, 

in order to decrease the risk of flooding from hurricanes and other weather events that are 

prone to occur in this area. Recommendations: Given the environmental concerns at the 

Turkey Point site, particularly regarding the Biscayne sole source aquifer, public drinking water 

supply well concerns, hypersalinity and radionuclide migration issues, proximity of two national 

parks, Biscayne Bay Aquatic Preserve, and the issues described in EPA's Section 404 CWA 

comment letters in addition to the other issues detailed above, the reason for the environmental 

preference for the Turkey Point site is unclear. The FEIS states that the alternative locations 

are generally comparable. Therefore, it is unclear why the Turkey Point site is preferred. The 

FEIS should further clarify and document the rationale that was used, particularly regarding 

evaluation of viewshed issues and operational analyses. (0617-4-14 [Mueller, Heinz J.])

Comment: Our legislators delegate hundreds of millions of dollars to help recover the 

Everglades. This project of adding new nukes could set the recovery effort back substantially. 

Floridians don't want more pollution for the Everglades and Biscayne Bay area. (0621-2 [Datz, 

Amy])

Comment: Future plans for Turkey Point must protect our national parks, water supply, and 

public health. (0629-1 [Borie, Edith])

Comment: Two of South Florida's most important public lands and wildlife habitats are 

Biscayne and Everglades National Parks. i urge you not to allow this project in this particular 

location to go forward. (0637-1 [Smoller, Merry Sue])

Comment: An increase of these two reactors will negatively impact these two national parks. 

Siting of these two new reactors violates the requirement that National Park proximity be taken 

into account during this evaluation. (0641-11 [Martin, Drew])

Comment: This project is too close to Biscayne Bay and Biscayne National Park. It is also too 

close to the Everglades, another incredibly unique place that is a national treasure. (0654-2 [Guy, 

Sharon])

Comment: Please review your plans and ensure the future of this area as a natural as mother 

nature can provide. (0668-1 [Garey, Jenne])

Comment: This goes far beyond the discussion of whether nuclear power is the right or wrong 

choice at this point in time, said Matthew Schwartz, executive director at South Florida 

Wildlands Association. Biodiversity in the ecosystem surrounding the existing Turkey Point plant 

is second to none. This is absolutely the wrong location for a massive new engineering project 

of this scale. Turkey Point is on the shoreline and adjacent to Biscayne National Park, one of 

Appendix E October 2016 E-439 NUREG–2176
the nations largest marine parks famous as an ecotourism destination and teeming with wildlife, 

said Jaclyn Lopez, Florida director at the Center for Biological Diversity. But with two new 

reactors, Turkey Point would become one of the largest nuclear facilities in the country. Marine 

parks and huge nuclear plants simply dont go together. Important natural resources would be in 

serious jeopardy. (0676-4 [Kassel, Kerul])

Comment: There are a state-managed aquatic preserve, expansive wetland habitat preserve, 

two national parks and a national wildlife refuge all within six miles of the proposed site. (0676-9

[Kassel, Kerul])

Comment: Nuclear power plants do not belong adjacent to ANY Natioonal Park! (0681-1

[Whitehorn, C.])

Comment: Please, let's have some areas that are wild and safe from human destruction. Let's 

not put toxic nasty stuff near our national parks. (0682-1 [Neff, Victoria])

Comment: Florida does need to cut its dependence on fossil fuels, but nuclear power plants 

are not the correct alternative for us, particularly not in such proximity to natural parks and the 

relatively wild land and wildlife they shelter. (0693-4 [Dorn, Kathryn])

Comment: This project is slated for one of the most environmentally delicate areas in FL.

(0704-1 [Ferry, Lisa])

Comment: No additional reactor next to Biscayne Bay! One is enough!! (0711-1 [Anonymous, 

Anonymous])

Comment: Two of South Florida's most important public lands and wildlife habitats -Biscayne 

and Everglades National Parks -will be put at risk and be forever changed by a project of this 

scale. (0712-4 [Almer, Anessa])

Comment: One must really question the wisdom of a corporation, a federal agency or a 

process that would allow for the construction of two nuclear reactors here: [FIGURE - Turkey 

Point aerial] (0716-8 [Riccio, Jim])

Comment: I want to agree with Caroline McLaughlin of the MPCA, in which she said about the 

location. Although I'm not anxious to see it move to a different location, I do think that part of the 

requirement of the EIS is to look at the location as the two national parks. So I do think that that 

needs to be considered. (0721-13-3 [Martin, Drew])

Comment: One of the elected officials spoke earlier said, this is just the wrong place. This is 

not the place to be building this type of a way of generating electricity. (0721-22-17 [Schwartz, 

Matthew])

Comment: Turkey Point's neighborhood includes the Biscayne National Park, and four other 

parks, wildlife, and nature preserves, habitats and refuges. This is an extremely sensitive, 

irreplaceable, and bio-diverse area which could be devastated by even tiny amounts of Uranium 

235 fuel, Plutonium, and other deadly toxic substances used in and generated by nuclear 

plants. (0721-28-8 [Wilansky, Laura Sue])

Comment: Finally, the EIS fails to seriously consider the superior rated alternate sites for the 

placement of the two new plants. Sites which were located in areas significantly less vulnerable 

to sea level rise, storm surge, as the location of Turkey Point is, and with nowhere near the 

Appendix E NUREG–2176 E-440 October 2016
dense urban population. In fact, they are mostly rural areas. There would be no competition for 

the water as we are currently facing it. The determination of the alternate sites appears to be 

highly subjective. The Statement fails to adequately provide facts specific comparative analysis 

on the rationale for excluding the alternate sites as environmentally preferable. Neither of those 

sites are located in the vulnerable coastal location. Neither are located in the middle of two 

national parks, and neither would impact a sole drinking source for more than 4 million 

Floridians. (0721-3-4 [Lerner, Cindy])

Comment: [These issues are dwarfed by] placement between two national parks and in 

proximity to other vital public lands and aquatic areas[.] (0721-32-5 [Schlackman, Mara])

Comment: Upgrades in other nuclear plant locations would jive better next to interior lakes 

than next to the ocean or the Bay, like in Turkey Point. Serious consideration really needs to be 

given to alternate sites based on location alone. (0721-5-5 [Mendez, Victoria])

Comment: First of all, I think my major message here is, I believe this is the wrong location for 

this. It's the wrong location. Number one, environmental concerns. This is going to be located 

between Biscayne National Park and Everglades National Park. These are two jewels in our 

National Park Service. If somebody thought about placing a nuclear reactor next to the Statue of 

Liberty or Lincoln Memorial, people would all say, put it somewhere else, this is not where you 

want to put it. Well, in terms of National Parks, the Everglades and Biscayne National Parks are 

the same thing. It's the wrong location. We shouldn't even be discussing this. It's just not the 

place to put this. (0721-7-1 [Edmond, Gabriel])

Comment: And, again, this is the wrong place to put this reactor. It's not the right place to put 

this. (0721-7-5 [Edmond, Gabriel])

Comment: [It's] located in one of the nation's most vulnerable areas to sea level rise, on the 

shores of Biscayne National Park. Biscayne is our nation's largest marine park and a home to 

incredible bio-diversity, important wetland and marine habitats, and countless opportunities for 

recreational and educational opportunities. (0721-9-2 [McLaughlin, Caroline])

Comment: According to the NRC's own regulations, locating a nuclear power plant next to 

public lands designed to protect valuable wildlife and habitat can have unacceptable impacts. 

There is a State aquatic preserve, two national parks, a wetland habitat preserve and one 

national wildlife refuge, located within six miles of the proposed site. One would be hard pressed 

to find a worse location to build two new nuclear units, especially considering that the 

construction and the operation of the proposed reactors could have serious impacts on these 

sensitive ecological areas. (0721-9-3 [McLaughlin, Caroline])

Comment: According to the NRC's own regulations, locating a nuclear power plant next to 

public lands that are designed to protect valuable wildlife habitat can have unacceptable 

impacts. There is a State aquatic preserve, two national parks, a wetland habitat preserve and 

one national wildlife refuge located within six miles of the proposed site. We would be hard 

pressed to find a worse place to build two nuclear units, especially considering the severe 

potential impacts that this could have on these fragile ecological areas. (0723-4-4 [McLaughlin, 

Caroline])

Response: Regarding the proposed site's proximity to National Parks and other public use 

features, commenters noted language from NRCs Site Suitability guidelines "Sites adjacent to 

lands devoted to public use may be considered unsuitable...{emphasis added}”. The NRC’s 

Appendix E October 2016 E-441 NUREG–2176
regulations applicable to an applicant’s site screening process, 10 CFR Part 100, “Reactor Site 

Criteria,” do not require that such a consideration be applied as an exclusionary screening 

criterion. Regulatory Guide 4.7 also notes that the context for evaluating impacts must be 

considered. However, the acceptability of sites for nuclear power stations at some future time in 

these areas would depend on the existing impacts from industrial, commercial, and other 

developments. 

The NRC’s consideration of Everglades and Biscayne National Parks, National Wildlife 

Refuges, aquatic preserves, and their associated ecosystems, and recreational users involved 

two basic steps. Using guidance in the Environmental Standard Review Plan (NUREG-1555), 

Section 9.3, the NRC first independently evaluated FPL’s screening process to determine 

whether the screening process adequately implemented the site suitability requirements for 

nuclear power stations as defined in 10 CFR Part 100, “Reactor Site Criteria”. Next the NRC 

considered the cumulative impacts that would occur at the Turkey Point site and compared 

those cumulative impacts to those that would result from construction and operation of two 

nuclear units at the alternative sites. 

In its screening process from the region of interest to candidate areas, FPL excluded from 

consideration areas within (1) the boundaries of critical habitats for endangered species, (2) 

dedicated lands such as National Parks and Recreation Areas, (3) census block groups with 

population density > 300 persons per square mile, and (4) areas too distant from available 

cooling water. In subsequent screening steps, FPL applied additional environmental, 

population, and engineering criteria to its site selection process to narrow the range of 

alternatives sites to a suite of sites that were representative of the licensable alternatives within 

FPL’s service territory. As documented in Section 9.3.1.7 of the EIS, the NRC staff evaluated 

the methodology used by FPL and concluded that the process was reasonable and consistent 

with the applicable regulations and guidelines. FPL conducted an adequate site selection study 

and chose Turkey Point as its proposed site. The review team found that the systematic 

alternative siting analysis demonstrated a logical selection process and application of screening 

and exclusionary siting criteria. The analysis enabled the evaluation of the likely environmental 

impacts associated with the respective sites, including the evaluation of suitability criteria, 

identified reasonable alternative sites, and clearly provided the mechanism for selection of the 

final proposed site. 

Following its review of this site screening determination, the NRC -- in its independent review, 

as documented in Section 9.3 of this EIS – first assessed the cumulative impacts that would 

occur at each of the alternative sites. The cumulative impact analyses combine the impacts of a 

proposed action with those that have already occurred in the past and present, or may occur in 

the foreseeable future. As discussed in Section 9.3, these cumulative impact analyses 

considered impacts such as, but not limited to, land use, surface and ground-water, terrestrial 

and aquatic ecology, threatened or endangered species and their associated critical habitats, 

wetlands, recreational, visual, historic and cultural resources, and social and economic 

impacts. 

As a part of the evaluation of cumulative impacts, Appendix I of the EIS documents the review 

team’s consideration of the potential changes in impacts that may occur as a result of the 

changes in the environment resulting from global climate change including sea-level rise. The 

changes that were considered include potential changes in temperature, rainfall, and 

occurrence of severe weather events. The effects of sea-level rise were also considered in this 

analysis. The potential effects of climate change on resource areas including water and ecology 

are presented in the appropriate sections of Chapter 5 and the cumulative impacts in Chapter 

Appendix E NUREG–2176 E-442 October 2016
7. In addition, in its evaluation of alternative sites, the NRC staff would only consider sites that 

appear to be licensable; i.e., sites for which it appears to be reasonable to expect that the 

applicant could obtain the necessary licenses and permits from the NRC and other 

agencies. The safety of the proposed site (including consideration of sea-level rise, storm 

surge, etc.) will be addressed in the staff’s safety evaluation report. The site would not be 

licensed by the NRC unless the staff determines that it meets the NRC’s safety requirements. 

As documented in Section 9.3.6, and in Table 9-28, the NRC then undertook a site-by-site 

comparison of the cumulative impacts at the alternative sites with the cumulative impacts at the 

Turkey Point site to determine if any of the alternative sites were environmentally preferable to 

the proposed site. The NRC's review process used reconnaissance-level information to 

determine whether there were environmentally preferable sites among the alternative sites; 

however, none of the alternative sites proved to be environmentally preferable to the proposed 

Turkey Point site. No change was made to the EIS as a result of these comments. 

Comment: DEIS Subsection 9.3.1.3, Page 9-37, Lines 2-3: The DEIS states: "...an internal 

FPL team was canvassed to identify known available sites within the 16 candidate areas." ER 

Subsection 9.3.2.3.1 states: "Functionally, the canvassing was conducted at an August 2006 

meeting...The committee was polled to identify the full spectrum of known existing and available 

sites "within or near the FPL service territory." (emphasis added) (0619-5-14 [Maher, William])

Comment: DEIS Subsection 9.3.1.5, Page 9-39, Lines 18-28: The DEIS section title is 

"Selection of Alternative Sites". Further, the DEIS states: "The resulting five alternative sites 

proposed by FPL..." In both instances, the term "Alternative Sites" should be changed to 

"Candidate Sites" consistent with ER Subsection 9.3.2.5, Identification of Candidate Sites, and 

terminology in NUREG-1555 where candidate sites include the proposed and alternative sites. 

(emphasis added) (0619-5-16 [Maher, William])

Comment: DEIS Subsection 9.3.4.5, Page 9-179, Lines 5-7: The DEIS states, "... after 

widening of SR-710." "SR-710" should be changed to "SR 70" consistent with ER Subsection 

9.3.3.3.6.5 which states: "To facilitate the additional traffic, a portion of SR 70 could be widened 

to a four-lane highway..." (emphasis added) (0619-5-18 [Maher, William])

Response: The text in the Alternative Sites subsection of Section 9.3 was corrected to reflect 

the noted inconsistency with the referenced material. 

Comment: DEIS Subsection 9.3.1.4, Page 9-38, Line 3 and DEIS Subsection 9.3.1.4, Page 9-

39, Lines 6-7: On page 9-38 of the DEIS, the DEIS section title is "Selection of Candidate Sites". 

On page 9-39, the DEIS states: "The resulting 10 candidate sites were: ..." In both instances, 

the term "Candidate Sites" should be changed to "Primary Sites" consistent with ER 

Subsection 9.3.2.4, Identification of Primary Sites. (emphasis added) (0619-5-15 [Maher, William])

Response: The text was revised to be consistent with the terminology as defined in 

Regulatory Guide 4.2. 

Comment: DEIS Section 1.4, Page 1-10, Lines 27-28: The DEIS states: "Using this process, 

FPL reviewed multiple sites and identified 23 candidate sites...from which the alternative sites 

were selected." This is not consistent with page 9-37 of the DEIS, Subsection 9.3.1.3, Selection 

of Potential Sites, which states: "Through this process, FPL identified 6 additional greenfield 

sites to consider as potential sites for a total of 21 potential sites as identified on Figure 9-4." In 

both instances, the DEIS cites FPL 2014-TN4058, FPL's ER. The evaluation in FPL's ER is 

Appendix E October 2016 E-443 NUREG–2176
based on the reference: Florida Power & Light Company Turkey Point 6 & 7, New Nuclear 

Power Generation (Formerly Project Bluegrass) Augmented Site Selection Study Report, 

August 2011. Section 4.0, Identification of Potential Sites, of this reference, states: 

"Cumulatively, a total of 21 potential sites were identified". (emphasis added) (0619-3-2 [Maher, 

William])

Response: The text in the Alternative Sites subsection of Section 1.4 was corrected to reflect 

the noted inconsistency with the referenced material. 

E.2.27 Comments Concerning Benefit-Cost Balance 

Comment: FPL should be denied a license for Turkey Point expansion for many reasons:...3. 

Bad Deal. Nuclear Cost Recovery law makes ratepayers bear the cost and risk while FPL reaps 

profit (0022-3 [Read, Alice Gray])

Comment: Is this a matter of jeopardizing the public's safety due to economic savings on FPL 

part? If so, pass it on to the customers. (0333-5 [Anonymous, Anonymous])

Comment: The estimated cost to build the two reactors is $25 billion. That comes out to $5500 

for each FP&L utility customer, which will be paid by raising utility rates. In 2014, the State of 

Florida approved FP&L to begin charging utility customers for the reactors which are in the 

design stage. They also passed legislation saying if the reactors are not finished FP&L doesn't 

have to pay back the money. FP&L has said they can construct the nuclear reactors and start 

generating power in ten years. After the plants begin producing electricity, FP&L will charge an 

average of $1.25 billion each year to their 4.5 million utility customers. This amount factors in 

shut downs for maintenance and refueling every 18-24 months. The $1.25 billion annual 

charges will continue for 40 years which is the average lifespan of the reactors, equaling $50 

billion. That comes out to an additional $11,000 for each FP&L customer. This of course does 

not include the future costs for disassembling the equipment and disposing of the nuclear waste 

once the reactors are too old to be repaired. (0671-1-2 [Post, Patrick])

Comment: The economics are too costly and the burden will fall on ratepayers to foot the bill 

with increased rates. (0710-5 [Platt, George Seth])

Comment: Now, the proposed nuclear reactors are already raising monthly customer utility 

rates by virtue of a State law passed in 2006 that Representative Rodriguez alluded to. That law 

essentially shifts a financial risk of constructing the plants from the company's shareholders to 

the company's customers, and the customers are paying in advance for this project. It should 

also be noted that the net cumulative fuel savings of the project, extolled by FP&L as the prime 

benefit for this project, will not be realized by customers until 25 to 36 years from today, 

assuming the project is built at all. So this practically means that a 70-year old FPL customer 

today may not break even on the project, if at all, until the customer is 106 years old. (0721-8-6

[Cavros, George])

Response: The purpose of the EIS is to disclose the potential environmental impacts of 

constructing and operating the proposed Units 6 and 7, and the associated costs and benefits 

related to those impacts. Setting retail power rates is outside the NRC's regulatory purview; 

those determinations are the responsibility of the FPSC. The EIS was not modified as a result 

of these comments. 

Appendix E NUREG–2176 E-444 October 2016
Comment: fp&l does its customers and more importantly its shareholders a disservice by 

proposing such an expensive proposition. (0055-5 [Roedel, Kitty])

Comment: When the Turkey Point expansion was first proposed, the projected cost was about 

$7 billion. The latest projections are $20 billion. Nuclear expansion might make sense for FPL's 

shareholders but it doesn't for us. That's right. (0088-5 [Lange, Alexandra])

Comment: We are totally opposed to the expansion of nuclear generated energy at Turkey 

Point -- for the following reasons.....2) Too expensive (0129-2 [Mayer, Doug])

Comment: We do not know how much money has been collected already and how much more 

is needed. Who will pay for this? Miami, Miami-Dade County, some cities, the State? What will 

it cost? What is the construction timetable? 2 years or more? US1 is a MAJOR thoroughfare 

with many businesses on it. Who benefits? What is the benefit to us? Who does it serve? Who 

is going to make money on this? In what other cities in Florida, the United States, the world is 

this existing? What did it cost? Who paid for it? Has research been done and if so share it.!

(0149-10 [Nelson, Joyce E.])

Comment: The extra expenses associated with nuclear safety and waste handling are making 

this option less practical, even if it wasn't risking "nuking" the local environment, so to speak.

(0265-1 [Bennett, Robbie])

Comment: Stop pushing dangerous nuclear energy solutions that cost billions of dollars and 

are a catastrophe waiting to happen. (0291-2 [Vorachek, Mary])

Comment: It will also be a tremendous economic cost to FPL's ratepayers, who must bear the 

cost in the form of advance payments (since the capital markets will not finance new nuclear 

reactors) with little or no benefits (example: the Crystal River nuclear plant fiasco). (0599-1 [Rock, 

Andrew])

Comment: Thanks to Florida law, FPL is already charging ratepayers for planning and 

licensing Turkey Point 6 and 7 and the company will continue to do so up until the moment 

construction is abandoned, at which point FPL keeps any remaining funds they've collected and 

passes them to their shareholders. For the United States Nuclear Regulatory Commission to 

participate in such a con job, or even appear to be associated with it, is unconscionable.

(0615-1-15 [Bethune, David])

Comment: I realize that South Florida has an ever-increasing appetite for energy and that 

nuclear may seem like an immediate solution to the problem, but we need to take a broader 

view of the costs involved. (0626-3 [Miller, Nyana])

Comment: Nuclear energy is NOT carbon free, requiring huge amounts of fossil fuels for 

mining, processing, construction, transportation, and disposal. Nuclear energy is far more costly 

than any other energy source, and would not be considered even, without massive federal 

subsidies. (0647-2 [Burns, Terry])

Comment: Why is profit more important than our environment and our very lives? This 

investment of more than 20 billion dollars of the rate-payers money makes no logical sense and 

it's far from being mindful of our future. (0720-1 [Bastidas, Mauricio])

Appendix E October 2016 E-445 NUREG–2176
Comment: I'm here tonight standing with many of my constituents and my Mayors in opposition 

to the current plan and the application that was submitted. In terms of why, and the reason it just 

being it's just way too costly for us. (0721-1-1 [Rodriguez, Jose Javier])

Response: These comments reflect concern about the potentially high costs of plant 

construction or nuclear power plants in general. The costs and benefits of construction and 

operation of the proposed Units 6 and 7 are summarized in Chapter 10 of the EIS using the best 

information available to the review team. In Chapter 9, the EIS provides an analysis of the 

potential for alternative non-nuclear technologies to provide the electricity that could be 

generated by the proposed plant and the environmental impacts of those alternatives. Neither 

the NRC nor the USACE has the authority or responsibility by law or regulation to ensure that 

the proposed plant is the least costly alternative for providing energy services under any 

particular set of assumptions concerning future circumstances. The NRC is not involved in 

establishing energy policy. Rather, it regulates the nuclear industry to protect the public health 

and safety and the environment within existing policy. Therefore, comments regarding the 

potential effect of a particular nuclear power investment on the future development and 

implementation of alternative technologies, subsidies for nuclear power, and characterization of 

financial risks associated with such projects are not within the scope of this environmental 

review. No changes were made to the EIS as a result of these comments. 

Comment: When is big business more important than a community? (0149-13 [Nelson, Joyce E.])

Comment: HERE IN CONNECTICUT WE WERE SOLD NUCLEAR POWER AS A WAY TO 

REDUCE OUR ENERGY COSTS WITH CLEAN ENERGY. MAY i REMIND YOU THAT 

CONNECTICUT CONTINUES TO HAVE ONE OF THE HIGHEST ENERGY RATES IN THE 

COUNTRY. WE WERE SOLD A BILL OF GOODS SO THAT THE NUCLEAR 

CORPORATIONS COULD MAKE MONEY. IN RESPONSE TO THE CLAIM THAT THE 

INDUSTRY MAKES THAT NUCLEAR POWER IS SAFE, I WOULD ASK WHY THE INDUSTRY 

DOESN'T SHARE MORE OF THE FINANCIAL RISK IN THE EVENT OF A DISASTER. IT IS 

THE AMERICAN TAXPAYER WHO IS BURDENED WITH THE MAJORITY OF THE RISK.

(0164-4 [Chrissos, H. L. Chris])

Comment: Our investments should be enacted with long-term vision of the future and not 

based on a project manager's timeline for getting their annual bonus. (0207-7 [Cleland, Noel])

Comment: Also the cost of the plant the regulations that must be met will ensure that this plant 

will not come on line for decades. (0249-2 [Mosher, Paul])

Comment: How many of these plants actually make money? Probably none. The money is in 

the cleanup after a shutdown or accident (see info on Vermont Yankee). (0336-2 [Anonymous, 

Anonymous])

Comment: I believe that this expansion of the reactors at turkey point are a waste of customers 

dollars[.] (0494-1 [Tamargo, Jorge J.])

Comment: Ultimately, I fear that Miami residents will be left to shoulder the costs of this project 

and its long-term consequences. Securing new supplies of drinking water and protecting coastal 

lands will be an expensive and difficult task. (0515-6 [Regalado, Tomas])

Comment: In summary, FPL's allowed profits are based upon a percentage return on total 

assets(ROI). This still applies even when rate payers pay for those assets upfront(proposed TP 

Appendix E NUREG–2176 E-446 October 2016
units 6 and 7), Florida statute 366.93. Turkey Points units 6 and 7 are designed to be overpriced 

white elephants, designed to extract maximum funds from the ratepayers and nothing else. FPL 

has every incentive to build overpriced capacity, and to discourage outside investment in 

alternative renewable energy sources. (0545-7 [Keating, Tim])

Comment: PLEASE DO NOT EVISCERATE ANOTHER SACRED PLACE AND ALL ITS 

INHABITANTS FOR THE SAKE OF PROFIT AND PERPETUATING A DENIAL SO

DELUSIONAL IT'S STUNNING. NUCLEAR POWER MUST NOT BE A WELFARE RECIPIENT, 

SUBSIDIZED BY MY TAXES, WILLING TO PUT US ALL IN HARM'S WAY. (0564-2

[Dimondstein, Carla])

Comment: I realize corporations have their bottom line to consider and often have no idea or 

perhaps money is more important than damaging our country, our natural resources and 

peoples lives. Projects are always written to protect them from damages caused by their 

projects and American citizens, e.g.. taxpayers are left with the damages both in physical and 

monetary terms. (0569-1 [Lane, N. Jo])

Comment: It appears that a few will be able to profit off this project at the demise of far more 

people, animals and plant life. Now does that seem like a logical balanced decision. The way it 

appears it does not really seem to matter what the majority of people or animals that call this 

amazing place home seem to think, feel or want in this matter. (0638-3 [Anonymous, Charity])

Comment: THESE ARE STRICTLY PROFIT-MAKING attempts. They have nothing to do with 

benefiting us. (0649-1 [Harrison, Norma J. F.])

Comment: WHAT DO THEY SAY? [concerning reopening Nuclear Cost Recovery docket 

150009 that governs the amount of money FPL may recover before it constructs the 2 nuclear 

reactor units and transmission lines] (0685-11 [Batista, Carlos])

Comment: Selfish. People want the benefits, but let someone else carry the burden. (0685-6

[Batista, Carlos])

Comment: This is not a worthwhile investment for the people of Florida. If the public was 

properly informed about the construction they would be against it. (0713-2 [Heiney, Jamie])

Comment: Let a bank -invester bank roll the reactor, if it is a good investment, get real 

insurance for it, not taxpayer bailouts. (0715-2 [Anonymous, Anonymous])

Comment: So I'm talking about the advanced nuclear cost recovery statute. So since 2006 

ratepayers bear the cost of siting, licensing, design, construction, or operation of nuclear power 

plants. So to summarize, basically the costs that FP&L has in pursuing this license, we pay for 

it. So this year it's going to be over 14 million, last year over 43 million, and in 2013 it was over 

$151 million that ratepayers paid toward this. And the irony is that everyone here who is 

objecting to this application in some form or another, if you're in the FP&L rate paying region, 

which I guarantee you are, businesses, organizations, people, you are paying for the cost of 

FP&L to pursue this license, and that is a deep irony. And some of us in the Legislature have 

been fighting for a while to try to get that statute repealed. Just yesterday, along with some of 

my colleagues in the Tampa Bay area, I led an effort to try to force a vote. We got a vote on the 

House floor on this issue. We weren't successful, but we have been making progress on getting 

support for removing this perverse incentive. And I just want to say that, you know, in terms of 

the comments that you're going to hear, in terms of why these -- why I say the costs are so high. 

Appendix E October 2016 E-447 NUREG–2176
You know, one is that from the information that I have it's not just that nuclear is the most capital 

intensive and expensive way to generate, but since the '70s we've learned that it's even more 

expensive than we imagined. (0721-1-4 [Rodriguez, Jose Javier])

Response: These comments express general opposition to the costs of power plant 

construction or raise societal issues that are not within the purview of NRC or USACE to 

address as part of the environmental review process. They did not provide new information 

related to the environmental effects of the proposed action. Therefore, no changes were made 

to the EIS as a result of these comments. 

Comment: FP&L believes locating TWO NEW Nuclear Power Plants here at Turkey Point is in 

the best interests of FP&L and its shareholders.. a business decision, pure and simple. FP&L 

will not compensate you for any losses you may incur due to their business decisions. Your 

Insurance Company does not cover your home or businesses in the event of a Nuclear 

"incident". Your insurance company will not compensate you for any losses you may incur. That 

is a business decision pure and simple. You will still be obligated to pay your Mortgage even if 

you must abandon your home. The Banks will not forgive your loans. The Government, whether 

local or Federal, will not compensate you either. SO....If a nuclear "incident" forces me to 

abandon my home, my property becomes worthless overnight and I lose almost 

everything I have. How much money will YOU lose if the value of your home drops to $0 

overnight? How much money will YOU lose if the value of your business drops to $0 

overnight? How much money will YOU lose if your job disappears overnight? How much 

money will YOU lose if you can NEVER reclaim your property or reopen your business? 

How and where will you live without assets, without income without ......anything? In the 

blink of an eye, Nuclear Power Generation at Turkey Point has the potential to wipe out every 

penny of value and income in South Florida. Nuclear Power at Turkey Point has the potential to 

destroy, in a virtual instant, everything you have spent your life working for. Are you willing to 

take this financial risk? Are you willing to let FP&L gamble with your money and your 

life? (0071-1 [Stanley, Gael])

Comment: If the commercial nuclear industry can't support itself after 50 years - and it can't - 

US taxpayers and ratepayers should not be required to support it with our tax dollars and 

massive CWIP (Construction Work In Progress) rate increases for plants that may never even 

be built or completed. (0078-3 [Wilansky, Laura Sue])

Comment: Instead of promoting more environmentally-friendly energy sources, the 

government seems to be pandering to a company that's main goal is to make money - a goal 

which does not include caring about the people or environment of Florida. Why, then, are we 

allowing them so much power in the decision of our energy future? Since Florida is the 

"Sunshine State," I was shocked when I came to Miami and hardly any houses had been 

outfitted with solar panels. In fact, FPL is actively campaigning against solar power because 

they know that it provides cleaner and cheaper energy to the consumer. (0214-2 [Zerulla, Tanja])

Comment: This utility is victimizing Miami residents in the following ways: --charging in 

advance for nuclear facilities it may never build. (0283-2 [Compel, Jr., Joseph])

Comment: Without federal insurance guarantees no necular plant could be insured or build in 

a cost effective way. Other sources such as wind turbines require less investment. (0461-1

[Dickinson, Robert])

Appendix E NUREG–2176 E-448 October 2016
Comment: Additional treatment of wastewater and/or provision of best available technology 

emission controls would add prohibitively to the already extremely high costs of nuclear plant 

construction. If history serves correctly, estimated project costs will suffer severe over-runs, 

making it likely that taxpayer and ratepayer dollars will be required to pay for the excessive 

costs of a project most financial institutions are too wise to fund. (0463-2 [Gross, Cheryl A.])

Comment: The best way to stop nuclear power construction in Florida and throughout the U.S. 

is to require the electric utility companies to pay 100% of all costs for building the plants. These 

companies and their shareholders will never accept these terms because it is not cost-effective 

for them to be financially involved in these immense long-term nuclear projects. It is only costeffective for them if their utility customers and U.S. taxpayers pay all of the costs. The question 

is why do we allow for-profit utilities and their stockholders such as FP&L to retain 100% 

ownership of the nuclear reactors, giving them a $25 billion asset, when FP&L is not paying any 

of the costs to build them? (0671-2-4 [Post, Patrick])

Comment: And I'm going to limit my remarks to the question of why. Why is it that FP&L is 

pursuing this application so vigorously? And the reason for that is, you know, I'm not a technical 

expert. I'm sure you'll hear from a lot of technical experts, but I just wanted to kind of offer the 

indication of giving significant scrutiny to the information that you are getting from the utility in 

this process. And the reason why, and the way that I believe that I come to the answer of why 

it's being pursued so much, it's because of the nuclear fee that we have here in the State of 

Florida that I think distorts FP&L's incentives significantly. (0721-1-2 [Rodriguez, Jose Javier])

Comment: But it makes economic sense for Florida Power and Light to propose things, even if 

they never build it. And I hope everybody understands that. That even if a nuclear power plant is 

not built they still get to recoup the costs that they incur on an annual basis in advance, and they 

don't have to return it if they decide to change their mind. That's the really sort of simplistic 

overview of it. But the ratepayers pay it and the shareholders profit and the company profits. So 

that's why we're here. That's what we're talking about. (0721-11-3 [Roff, Rhonda])

Comment: I have a problem with Florida Power and Light as far as shareholders versus 

ratepayers who's on the hook for this. Capital projects need to be done by shareholders and 

stockholders. That's what stock's for. If you want to build something you sell stock. People take 

risk. If it works out, great. If it doesn't, you're on the hook, not the ratepayers. Florida Public 

Service Commission. Our State Reps need to come up with a different way of appointing these 

folks. The Commission is broken. It too favors the power plants. They've got some big issues 

with Duke Energy up in the Northwest part of the State. So we need to get on our elected reps 

to change the way that these PSC people are appointed. I don't know publicly elect them is the 

way to go, but there needs to be discussion on it because the current PSC is broken and I feel 

it's corrupt. The process doesn't come out in our favor. We always seem to come out on the 

short end. (0721-24-2 [Eastman, John])

Comment: If the commercial nuclear industry can't support itself after 50 years, and it can't, 

U.S. taxpayers and ratepayers should not be required to support it with our taxes dollars and 

massive construction work in progress, rate increases, for plants that may never even be built or 

completed. (0721-28-4 [Wilansky, Laura Sue])

Comment: Moreover, FPL shareholders will earn a 10-1/2 percent rate of return on the money 

invested in the nuclear plant while FPL customers shoulder all the financial risk. It's a sweet 

deal for FPL shareholders but not so much for customers. (0721-8-11 [Cavros, George])

Appendix E October 2016 E-449 NUREG–2176
Comment: And furthermore, they're allowed since 2006 to bill customers in advance of any of 

these costs for the full cost of what they spend, even before they decide, as they haven't yet 

decided, to build. So it's going into the rate base. Consumers like me who are paying electrical 

bills in Juno are already paying for the cost of the planning process and, you know, I think that's 

biasing FPL toward wanting to make these projections. (0723-12-3 [Henry, Jim])

Response: These comments express concerns about cost-related issues outside the scope of 

NRC and USACE purview, including perceptions about energy policies, tax burdens, or industry 

subsidies. The principal costs and benefits of the proposed action are summarized in Section 

10.6 of the EIS. The summary is derived from careful assessment of impacts across the 

principal environmental interfaces affected by the action during construction (Chapter 4) and 

during operations (Chapter 5). In addition, the cumulative environmental impacts of the action 

are presented in Chapter 7. These impact discussions frame the assessment of overall project 

benefits and costs that are within the Review Team's scope to assess. The comments did not 

present any new or relevant information. No changes to the EIS were made as a result of these 

comments. 

E.2.28 Comments Concerning Climate Change 

Comment: Given the overwhelming research and consensus of scientific opinion on climate 

change, South Florida should not be considered for such a project. Just because there is a 

minority of climate change deniers with politically driven motives does nothing to mitigate the 

risks of building more reactors at this location. (0009-2 [Rose, Simon])

Comment: We are in the 21st Century and this proposed expansion was planned before the 

reality of climate change was confirmed by scientists. (0086-3 [Lawrence, Diane])

Comment: For example, extreme flooding due to climate change will significantly affect the 

regional water management system. This system was initially designed to protect 2 million 

people and now serves a population of more than 7.5 million. If flooding were to reach new 

extremes, the water management system currently in place may not be adequate to provide the 

necessary levels of flood protection. See Climate Change and Water Management in South 

Florida: Interdepartmental Climate Change Group, SOUTH FLORIDA WATER MANAGEMENT 

DISTRICT (Nov. 2009). The water management structures' lack of capacity makes flooding 

more likely and may compromise access to the plant site. Similarly, the final Environmental 

Impact Statement should include a discussion of the level of flooding that will impact plant safety 

and the corresponding rainfall return period. (0611-15 [Haber, Matthew S.])

Comment: EPA recommends that this impact analysis also consider extended periods of 

drought, characteristic of the southeast U.S. (0617-4-16 [Mueller, Heinz J.])

Comment: You mentioned climate change. Having looked at a great deal of research and 

having heard from both sides of the issue, Karen, my family and I are convinced that there is no 

such thing as climate change or global warming. As the great professor, Richard Lindzen of MIT 

said, "Global warming is the biggest hoax in the history of science." (0680-2 [Hubbard, Stanley S.])

Comment: I would like to echo George Cavros' comments regarding -- and some of the others' 

comments regarding what we're doing here, why we are even talking about a nuclear power 

plant in this location or really in any location in Florida, given that the entire peninsula of Florida 

is Ground Zero for the impacts of climate change. So we have to worry about increasing 

severity of droughts, storms, lack of water, water for restoration, water for agriculture, water for 

Appendix E NUREG–2176 E-450 October 2016
people. We have a lot of people in Florida and supposedly it's growing. People are moving to 

Florida like crazy. So we really don't have that kind of water to feed these power plants.

(0721-11-2 [Roff, Rhonda])

Comment: I think that sea level rise needs to be looked at in more detail. I don't think the 

current estimates are adequate. I think that sea level rise will be greater. I think we need to look 

at that and factor in storm surge, because when we talk about the level of sea level, when we 

talk about storm surge, that will be on top of the existing sea level rise. So if sea level rise were 

to be greater, and since this plan -- the life of this plan is in 60 years, and we don't know what's 

going to happen, that's a particular concern. (0721-13-4 [Martin, Drew])

Comment: The reality is, we are at the very beginning of a very serious rise in sea level.

(0721-6-3 [Harris, Walter])

Comment: As some of my colleagues have mentioned, in terms of sea level rise. This is a 

major issue in terms of sea level rise, and as we look at the models the sea level is rising 

quicker than the models have even shown. (0721-7-2 [Edmond, Gabriel])

Comment: South Florida, Miami-Dade County is Ground Zero in the world in terms of sea level 

rise. We already see Miami Beach flooding. (0721-7-4 [Edmond, Gabriel])

Comment: Finally, Biscayne Bay and South Florida are extremely susceptible to climate 

change, and Turkey Point in particular is vulnerable to sea level rise, storm surge, and other 

types of flooding. FP&L's application only accounts for a 1 foot rise in sea levels during the 

reactor's lifetime. In contrast, NOAA recommends the power plant's account for between 3 to 5 

feet of sea level rise during that same time period. By the Federal Government's own 

recommendations the plan to expand Turkey Point should not be considered safe. Today the 

President of the United States came to Everglades National Park to discuss the need to prepare 

South Florida and the nation for the impacts of climate change. I suggest we follow his 

leadership here and work together towards a more resilient, sustainable and adaptive South 

Florida. (0721-9-7 [McLaughlin, Caroline])

Comment: But something else that just was part of the museum was just showing how the 

shape of Florida naturally changed. Forget climate change and how everyone gets too sensitive 

about whether we're even doing it or not. Because even if we aren't, the reality is the earth is not 

so stable. We are in the most unique period in the earth's history of stability and we've gotten 

used to it. But you know what, 40 years is nothing. (0723-11-4 [Berendsohn, Catherine])

Comment: ...it was on the second story of the historic house where I had my office, we had a 

marker of the sixteen and a half foot tall storm surge that went up to the second floor. It was 

even always still flood there, and I am -- I didn't even realize that your plan only accounts for 

one foot of water change? That's not even the case when I was four years old. That's the most 

disturbing thing I've heard in a long time. (0723-11-5 [Berendsohn, Catherine])

Comment: We -- the Everglades is the only Everglades the world has ever had and it may 

never be able to return once Florida floods. (0723-11-7 [Berendsohn, Catherine])

Comment: ...the sea level rise projection of one foot and everybody, including the latest 

projections in, you know, the scientific community are talking, in the University of Miami, about 

three to five feet through this time period. We have to look more carefully at those projections. 

(0723-12-13 [Henry, Jim])

Appendix E October 2016 E-451 NUREG–2176
Comment: If expanded, Turkey Point will become one of the largest nuclear generating 

facilities in the entire country located in one of the nation's most vulnerable areas to sea level 

rise and directly on the shores of Biscayne National Park. (0723-4-2 [McLaughlin, Caroline])

Comment: Finally, Biscayne Bay and South Florida are extremely susceptible to the effects of 

climate change. At Turkey Point in particular is susceptible to sea level rise, storm surge and 

other types of flooding. FPL's application only accounts for a one-foot rise in sea levels during 

the reactors' lifetime. In contrast, NOAA recommends that the power plants account for between 

three and five feet of sea level rise over the same period. By the Federal government's own 

recommendation, the expansion at Turkey Point should not be considered safe. (0723-4-8

[McLaughlin, Caroline])

Comment: The President of the United States came to the Everglades yesterday on Earth Day 

to discuss the need to prepare this nation for the effects of climate change, particularly here in 

South Florida. (0723-4-9 [McLaughlin, Caroline])

Response: These comments are related to climate change and sea level rise. The review 

team's evaluation of climate change and sea level rise is discussed in Appendix I. Based on 

these comments, Appendix I was modified to: clarify the role of the NRC safety review; describe 

the conformance of Appendix I to CEQ guidance; mention groundwater modeling analysis 

discussed in Appendix G; describe several reasonably foreseeable adaptations to sea level rise; 

and mention localized sea level rise changes. 

E.2.29 General Comments in Support of the Licensing Action 

Comment: I believe that that COLs should be issued for Turkey Point Units 6 & 7. The site is 

adjacent to FPL's existing reactors, so it should not impact the environment in any additionally 

detrimental ways. In fact the NRC's environmental review found no environmentally preferable 

or superior sites. (0002-1 [Hamilton, Brent])

Comment: Good for them. I think it is great idea especially as growth in South Florida is 

uncontrolled. (0011-1 [Rowe, James])

Comment: Please approve the project quickly. (0013-2 [Christie, Grazie])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[a]s for those who are opposed to nuclear power 

for philosophical reasons, that closed minded fearful thinking has to be weighed against people 

like myself who for philosophical reasons are opposed to importing foreign oil which supports 

the despots that use the income from oil sales to oppress people and because they have the 

revenue from oil sales make the world a more dangerous place to live. (0015-10 [Goldmeier, 

Barry])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[f]rom a geopolitical point of view, why would the 

US assist Iran in building a "safe civilian" nuclear program which could turn into something else 

while not doing so on US soil. FPL is not Iran by any stretch of the imagination. (0015-14

[Goldmeier, Barry])

Comment: I AM IN FAVOUR OF BUILDING TWO OTHER NUCLEAR PLANTS THEY ARE 

MORE EFFICIRNT, AND WE NEED TO BE READY FOR THE INCREASE IN POPULATION IN 

SOUTH FLORIDA. (0016-1 [Slonim, Roberta])

Appendix E NUREG–2176 E-452 October 2016
Comment: I am in favor of the Turkey Point expansion of two nuclear units. (0035-1 [Larrabee, 

Laura])

Comment: Doubt if we can attend hearings but definitely feel the advantages to our area far 

exceed the risks. (0038-1 [Hudak, Jill])

Comment: I would like to put my two cents in on the future expansion of Turkey Point's two 

new nuke plants. Myself and my husband are native Miamians and have had our roots in this 

area for three generations now. We were here before FPL built their first two nuclear reactors in 

the 70s and remember all that went into building them. It took some time before FPL could flip 

the switch on those two. It will take time to build these as well and I am just hoping that the two 

existing reactors can handle the load until then, since our "esteemed" local politicians don't 

seem to know how to say "no" to any development, regardless of the crowding or stresses it 

puts on our infrastructure and resources. We are STRONGLY IN FAVOR of FPL building the 

two new nuclear plants. (0070-1 [Lamb, Deborah S.])

Comment: I support the expansion of Turkey Point and oppose the "No Action" alternative.

(0286-1 [Jackson, Donald L.])

Comment: I support the proposed expansion of FPL's Turkey Point. (0286-3 [Jackson, Donald 

L.])

Comment: To the NRC under Docket ID NRC-2009-0337 Activists are telling people to voice 

their concerns about proposed nuclear power plants Turkey Point 6&7. Their supporters are 

urged to say they want clean, safe, and affordable renewable energy. 

Taking these demands apart: 

Clean: Nuclear power has a cleaner record than natural gas, which is the only alternative that 

could make up for more than a fraction of the energy that the proposed units would generate. 

Safe: American nuclear power plants undergo the most stringent regulatory review of any 

sources of electric power. 

No civilian injury, or radiation sickness has ever been found to be associated with operation of 

the plants that have supplied 20% of our nations electricity for the past several decades. The 

same goes for plant workers. 

Nuclear plant and laboratory workers have been studied and their excellent health has been 

explained in medical literature by a healthy worker effect. 

Three Mile Island: Total number of civilian or worker health effects: ZERO. 

From handling and disposal of radioactive wastes: ZERO. 

In Japan, due to the tsunami disaster at the Fukushima nuclear power plants: Radiation cancers 

detected or predicted in the future: ZERO. (Predicted by real qualified medical experts rather 

than discredited activists like Helen Caldicott.) Dead and missing from the tsunami, 17,000 to 

20,000 persons. 

Affordable: Once built, power from nuclear plants has consistently been the higher economic 

choice on utility systems. 

Appendix E October 2016 E-453 NUREG–2176
Plant construction costs are high, demonstrably higher than they should have been had not 

regulatory delays and demands of activists not been allowed to delay and interfere with 

construction plans. On utility systems, nuclear and coal plants provide the base load 24-7 power 

alongside of which solar and wind contributions can be successfully utilized. The NRC must 

remind activists who attend the Turkey Point public meetings that NRC decisions must be based 

on factual scientific evidence and not on slogans of people who do not study the scientific 

evidence or learn to understand the importance of adequate, dependable electric energy to the 

people of Florida, the United States and the rest of the worlds populations. Every nuclear power 

plant in the U. S. is licensed, which required a complete Environment Impact Statement in 

addition to its detailed Safety Analysis Report. Licensing proceedings were held in public in the 

most transparent and extensive process of any and all energy sources. Claims like those of 

SACE were all debated and dismissed hundreds of times. Those of us who took part in these 

processes are appalled to see the same kind of opportunistic groups demand a rehash of 

proven evidence. It takes time to write this statement, which obviously has become lengthy. 

SACE can tell its supporters to send bales of meaningless words to take up your reading time, 

with no more effort than just hitting the CUT and PASTE keys. It is up to you to make your 

findings based on facts. (0345-1 [Rossin, A. David])

Comment: Florida has had a long and very successful history with nuclear energy and the 

plans for new plants in the state (Turkey Point Units # 6 and 7) are based on that history of 

successful and safe nuclear operation by Florida Power and Light. (0375-1 [Tulenko, James])

Comment: The State of Florida ranks 6th in carbon dioxide (CO2) emissions among the 50 

states. More carbon free energy sources are badly needed. The two new units will provide 

2,200 Megawatts of clean, reliable power, which is enough to power more than 1 million homes. 

This energy output avoids approximately 418 million tons of carbon dioxide emissions over 60 

years (equivalent to removing 88 million cars from the road) and will create approximately 3,500 

jobs during construction and 800 permanent high-paying jobs in operation. Certainly these 

plants carbon free output along with FP&L operating experience provides the positive 

environmental impact needed for approval. (0375-2 [Tulenko, James])

Comment: In the face of climate change, we need real solutions now. Clean, safe, and 

affordable nuclear power will put us on the path of obtaining improved public health, a better 

conserved, protected natural environment, and a more vibrant, creative economy. Approving the 

application for Turkey Point 6&7 will simply lead to a better future. (0378-1 [Macher, Nathan])

Comment: This email is to voice my support for the two additional units at the Turkey Point 

power generation station. (0575-1 [Roberts, Kenneth])

Comment: I am sorry that you are upset about the proposed expansion of the Turkey Point 

Nuclear Plant. I'm sorry that Karen and I don't share your concern. (0680-1 [Hubbard, Stanley S.])

Comment: THE TIME TO OBJECT AND VOICE YOUR SUPPORT FOR THIS IS NOW 

BEFORE IT IS TOO LATE. (0685-10 [Batista, Carlos])

Comment: Please do confirm FP&L's request to build new nuclear reactors and certainly 

do allow placement of these huge high voltage lines in the Miami Roads neighborhood (in or 

adjacent to any other residential neighborhood). (0685-4 [Batista, Carlos])

Comment: 2. This flyer doesn't represent what the majority thinks. 3. Info here is incomplete 

and misleading. (0685-7 [Batista, Carlos])

Appendix E NUREG–2176 E-454 October 2016
Comment: WE DON'T OBJECT! (0685-9 [Batista, Carlos])

Comment: I am writing in reference to Docket ID: NRC-2009-0337 to express my support to 

the proposed expansion of Turkey Point Power Plant, located in Homestead, Florida. (0694-1

[Carpenter, Rory])

Comment: I support the expansion of Turkey Point providing proper designs are in place.

(0694-4 [Carpenter, Rory])

Comment: PLEASE APPROVE the Turkey Point license for two new nuclear plants! (0707-1

[Pheil, Edward])

Comment: On behalf of our 18,000 members we are requesting that you adopt the 

recommendations of the final order of certification to certify Turkey Point Units 6 and 7.

(0721-19-1 [Riley, Bill])

Comment: We are convinced that this is an important project which has a strong positive 

benefit for our entire State, with a very strong environmental partnership with Florida Power and 

Light, and we urge you to approve this project. (0721-19-4 [Riley, Bill])

Comment: I represent the Pipefitters Local [Union] 725 of Miami. I am one of 18,000 members 

of the South Florida Traders Council. As a representative of the 18,000 members I ask that you 

adopt and recommend the final certification of Turkey Point Units 6&7. (0721-20-1 [Garcia, Javier])

Comment: I'm here tonight to support the construction of Turkey Point Nuclear Units 6 and 7.

(0721-27-4 [Rodriguez, Manuel J.])

Comment: We're pleased with that and would encourage the NRC and the appropriate 

governing bodies to allow the nuclear units to be built. (0722-1-3 [Porter, Jeff])

Comment: To our friend Captain Dan who spoke earlier, as a shareholder, you must have 

some idea of what the degree of difficulty would be in trying to site a new nuclear facility. 

(Recording briefly inaudible.) 

-- requires additional electric capacity, it requires it here in Miami Dade County and it requires it 

at Turkey Point. And we urge the NRC to proceed with the application. (0722-10-4 [England, 

Peter])

Comment: [W]e really strongly need and encourage this expansion for the jobs and the 

economic revitalization of our community. (0722-11-2 [Knowles, Yvonne])

Comment: [W]e [Redland Market Village] need safe, clean, affordable energy. So that's the 

reason we are supporting, and please approve the 6 and 7. (0722-12-2 [Infante, Jose Renee])

Comment: I'd like to speak strongly in support of adding the two nuclear units at Turkey Point.

(0722-13-2 [Duquette, Bill])

Comment: Anyway, so I would like to just lend you our support. (0722-13-9 [Duquette, Bill])

Comment: This is a position I took on to promote nuclear science and technology and I, along 

with my fellow students, understand the importance of energy security in our State as much as 

Appendix E October 2016 E-455 NUREG–2176
anyone. This is why we're here today to support the development of Turkey Point 6 and 7.

(0722-4-1 [Moo, Patrick])

Comment: And after reading through a portion of the EIS we have no qualms about any of the 

recommendations made by the NRC or the Army Corps of Engineers. The statements made in 

their assessment fully fulfills our understanding of the Units 6 and 7 and the impact it would 

have on the surrounding areas. So we recommend that they move forward and go Gator's, go 

nuclear. (0722-6-1 [Martin, Allan])

Comment: On behalf of 1,800 of our members we would like to request that you adopt the 

recommended final order of certificate and certify the Turkey Point Units 6 and 7. (0722-9-1

[Riley, Bill])

Comment: [W]e hope very much that you will support this application. (0722-9-12 [Riley, Bill])

Comment: We are convinced that the --this important project will be a strong positive benefit 

for our entire State in South Florida. (0722-9-5 [Riley, Bill])

Comment: [W]e strongly urge you to approve this project. (0722-9-7 [Riley, Bill])

Comment: So I'm not afraid to have this facility in my back yard. I think it's -- any time change 

comes about there are some necessary elements of it. And I think that the United States has 

always shown an ability to meet the needs of its community with oversight and the cost -- well, 

not always cost efficient, I'm not going to tell that lie. (Laughter.) But in a safe way. So after a 

lot of review, my community supports this project, my council supports this project with the 

proper oversight, with the proper safety mechanisms in place. And again, when we think about 

our environment, think about the whole environment. That includes, you, me too. (0723-1-8

[Wallace, Otis])

Comment: In addition we, as the Chamber of Commerce, looked at the report when we went to 

the last meeting and are confident that everyone here that has specific knowledge and 

education has taken sufficient caution and measures to look at all the data, do your analysis, 

and you are making a report that I think we, as the population of people that live in this area 

should feel confident that we know, I guess, that you're not lying. You are giving us scientific 

fact, you've analyzed, so again we thank you for that. (0723-10-3 [Brito, Rosa])

Comment: We're looking forward to another 40 years of the two new plants. (0723-10-6 [Brito, 

Rosa])

Comment: And what I'm concerned about the most is that this project won't be developed. I'm 

in total favor for the development of this project. This is something that's important to the city, it's 

important to us as residents for power supply. There's just so many benefits that go along with 

this project. (0723-13-1 [Simpson, Chris])

Comment: So as a resident, I just want to express that I fully support the development of this 

project. (0723-13-3 [Simpson, Chris])

Comment: On behalf of our 18,000 members we are requesting that you adopt the 

recommended final order of certification and certify Turkey Point's Units 6 and 7 project.

(0723-14-1 [Riley, Bill])

Appendix E NUREG–2176 E-456 October 2016
Comment: We strongly recommend that you approve and adopt this project. (0723-14-5 [Riley, 

Bill])

Comment: And one more thing I wanted to say, there is a word, acronym called NIMBY. And I 

think that "not in my back yard" attitude has probably done more damage than has helped in this 

country. I think it's important to realize that having the attitude that we want to have power 

plants but we don't want to have them in our back yard just displaces the convenience, if that 

makes sense, for people who just want to see something go away and go somewhere else.

(0723-7-5 [Boling, Steve])

Comment: I do approve of the sites being constructed, (0723-8-7 [McDuffie, Stephen])

Response: These comments express support for the addition of new nuclear units at the 

Turkey Point Nuclear Power Plant site. They do not provide any specific information related to 

the environmental effects of the proposed action. No change was made to the EIS as a result of 

these comments. 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...Turnkey Pint along with its infrastructure is 

already there so it is far better and less intrusive to expand it than locating new generating 

capacity in Turkey Point than siting any type of power generation facility anywhere else.

(0015-17 [Goldmeier, Barry])

Comment: Like so many Americans, I am committed to protecting the National Park System, 

which preserves our country's incredible array of landscapes, waters, wildlife, and opportunities 

for exploration. Biscayne National Park is an irreplaceable national treasure that safeguards 

precious natural resources and recreational opportunities. I am told that there are, within six 

miles of the proposed expansion site, there are two national parks, an aquatic preserve, a 

national wildlife refuge, and a wetland habitat preserve. Sufficient data should exist today to 

provide design direction and upgrade from existing two reactors. (0694-2 [Carpenter, Rory])

Response: The NRC acknowledges the commenter's support for new nuclear power. The 

review team independently compared the alternative sites to the proposed site to determine if 

any of the alternative sites were environmentally preferable to the proposed site in Section 

9.3. The review team concluded that none of the alternative sites was environmentally 

preferable to the proposed Turkey Point site in Section 9.3. In addition, the NRC staff will 

determine whether building and operating the proposed units at the Turkey Point site will meet 

all of the safety requirements in the NRC regulations. The results of this review will be 

documented in a safety evaluation report and those results, along with the EIS, will be 

considered in the NRC’s decision about whether to issue the COLs for proposed Units 6 and 

7. No change was made to the EIS as a result of these comments. 

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[t]he lessons from past accidents and knowledge 

of sea level rise will be incorporated into the design making the planned facility more 

dependable in the long term than even the facilities FPL has in place. (0015-16 [Goldmeier, Barry])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[m]odern science has learned a great deal in the 

past 50 years since the existing nuclear facility at Turkey Point was built. Since there has been 

no major issues with the Miami-dade or Hutchinson Island facilities FPL has run safely for 

Appendix E October 2016 E-457 NUREG–2176
decades I see no real risk from expanding the existing nuclear capacity of Turkey Point. (0015-9

[Goldmeier, Barry])

Comment: Provided that the two new reactors are of the latest generation, and hence are 

much safer than the old ones, I am convinced that this is a great way to generate electricity with 

very low environmental impact. (0018-1 [Massa, Arturo])

Comment: I believe that the proposed plants would be a great boost to the economy here and 

provide economical electricity for business and residential. The latest designs are much more 

safer than those 50 year old designs of current use. (0041-2 [Williams, Paul])

Comment: Please accept my support for the proposed new Nuclear Power units at Turkey 

Point. As Florida population continues to grow, we will need reasonably priced electricity to 

support that growth. The design of the new generation of nuclear power plants are a great 

improvement over the old design. (0069-1 [Williams, Paul])

Comment: So I hope, I really wish, or I hope that I can convince you that the nuclear option is 

definitely the best option for us right now. It's the best option that we can bring together to the 

table to going forward into the future to eliminate our dependence on any type of fuel source 

that produces CO2 emissions. And I hope there's no doubt about that. 6 and 7 is the right 

choice. Build Unit 6 and 7. (0721-15-14 [Kuraza, Devon])

Response: The comments express support for the proposed units at the Turkey Point 

site. They do not provide any specific information related to the environmental effects of the 

proposed action. No changes were made to the EIS as a result of these comments. 

E.2.30 General Comments in Support of the Licensing Process 

Comment: I'd like to thank the NRC for holding these hearings. I'd like to thank all of you for 

coming out and showing your interest because this is an extremely important subject. (0722-10-1

[England, Peter])

Comment: [T]hank you for giving us the opportunity to address the Commission today.

(0722-13-1 [Duquette, Bill])

Comment: I appreciate the forum to come out and speak to you guys today. I just want to 

express my gratitude to you guys, having you come out and speak today. Appreciate your 

time[.] (0722-3-2 [Chatterton, Andrew])

Comment: There is something I am proud of as an American citizen and something that I think 

stood out was the idea of the system of checks and balances here. (0723-11-1 [Berendsohn, 

Catherine])

Comment: But I do appreciate that the NRC is giving this as public. (0723-8-5 [McDuffie, 

Stephen])

Comment: I like the way that this project was done or the way this evaluation was done.

(0723-9-1 [Schwartz, Matthew])

Response: This comment provides general information in support of the NRC COL 

process. Because it did not provide any specific information related to the environmental effects 

of the proposed action, no changes were made to the EIS as a result of this comment. 

Appendix E NUREG–2176 E-458 October 2016
E.2.31 General Comments in Support of Nuclear Power 

Comment: Nuclear Power is safe and environmentally friendly. And cost effective. (0013-1

[Christie, Grazie])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[t]here already is a nuclear reactor there so 

anyone who is opposed to that source of power should have no argument[.] (0015-3 [Goldmeier, 

Barry])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...[n]uclear generates fewer environmental 

greenhouse gasses than does gas or oil as a source of electric power[.] (0015-6 [Goldmeier, 

Barry])

Comment: Nuclear energy is good and I believe it is an important our past and future energy 

needs in America. In fact at Merrill Lynch in the early 1970's I help raise the original capital to 

build Turkey Point. (0075-1 [Streit, Christopher V.])

Comment: The commenter submitted an article on radiological health effects that states that 

support for the nuclear energy industry has been largely predicated upon three fallacies: 1. 

That there is a safe level of exposure to radiation, below which it does no harm. (0111-1 [Glynn, 

Simon])

Comment: The commenter submitted an article on radiological health effects that states that 

support for the nuclear energy industry has been largely predicated upon three fallacies: 2. 

That in any event the radiation emanating from nuclear power production is only a small 

proportion of the total level of radiation, from all sources, to which we are exposed, and thus 

produces a similarly small proportion of the health effects resulting therefrom. (0111-2 [Glynn, 

Simon])

Comment: The commenter submitted an article on radiological health effects that states that 

support for the nuclear energy industry has been largely predicated upon three fallacies: 3. 

That so long as we monitor radiation levels to insure they do not exceed permitted maximums, 

expansion of the industry may proceed without producing intolerable health costs. (0111-3

[Glynn, Simon])

Comment: Solar power is expensive and produces little energy. Expansion of nuclear power 

plants is the best option. (0123-1 [Mulet, Tomas])

Comment: Nuclear energy continues to be safer, cheaper, and cleaner than fossil fuel 

alternatives. (0286-2 [Jackson, Donald L.])

Comment: Nuclear power will transform our economy because generating electricity through 

nuclear power can be done at a more inexpensive price point than coal. (0378-3 [Macher, Nathan])

Comment: A nuclear powered economy will improve public health and help protect the 

environment. Ventures like indoor vertical farming will put fresh food on tables nationwide. This 

fresh food will be produced without pesticides or even dirt. Think of all the forests we can save if 

forests don't have to be cleared for farmland. (0378-5 [Macher, Nathan])

Appendix E October 2016 E-459 NUREG–2176
Comment: Also, nuclear power can scale up to completely displace fossil fuels: France 

generates 80% of its electricity with nuclear power. Replacing fossil fuels would remove from 

the environment air pollutants that today kill thousands--if not tens of thousands--of people 

every decade in North America. In some situations, the intermittent nature of renewables leads 

to more fossil fuels being burned, which creates more air pollution. As someone who has a 

couple of family members with asthma, I can tell you that depending on renewables to generate 

more power than the technology is capable of does not help my family members breathe any 

easier. (0378-6 [Macher, Nathan])

Comment: America needs the energy and nuclear energy is the friendliest form to the planet.

(0575-2 [Roberts, Kenneth])

Comment: They will also improve the human habitat and reduce center deaths and health 

costs caused by air pollution from the alternative fossil fuels. (0707-3 [Pheil, Edward])

Comment: Nuclear has a proven BEST safety record both for any energy production method 

already, and new plants will further improve the safety record, while also saving people money 

by reduced electricity and Healthcare costs. (0707-5 [Pheil, Edward])

Comment: I know there's a lot of -- there's a negative cloud over nuclear power, particularly in 

the wake of the Fukushima accident, I understand that. And I think the only way that we can try 

to reassure the public that we are looking out for their best interest is basically to talk about it 

and talk about what we did and what we learned from those events. (0721-15-11 [Kuraza, Devon])

Comment: Another point that was brought up that I wanted to address. Oh, I heard a number 

about 10 to 15 cents a kilowatt for current nuclear power generation. Closest numbers I could 

find online about 2.7 cents per kilowatt is the current cost of power generation from a nuclear 

source. (0721-15-3 [Kuraza, Devon])

Comment: There's a lot of misconceptions about nuclear power and about what we do and 

how we do it, and I always say that those in the industry have nobody else to blame but 

ourselves for not coming out and trying to educate the public about what we do and how we do 

it. (0721-15-5 [Kuraza, Devon])

Comment: A lot of people think that because we are pro-nuclear we are somehow against 

other forms of power generation. That's simply not true. I think the most hard-line advocate in 

here for nuclear power would tell you that we need a diverse fuel mixture and that includes 

wind, solar, and of course nuclear. (0721-15-6 [Kuraza, Devon])

Comment: I, myself, live in an apartment building. I don't have that option, so I need the next 

best thing, something that is both clean, good for the environment[.] (0721-15-8 [Kuraza, Devon])

Comment: I want to underscore the significant value the nuclear plants bring to the State of 

Florida in the form of carbon free energy, jobs, and reliability. Florida's four operating nuclear 

reactors currently generate 12 percent of the State's electricity while emitting no greenhouse 

gases, accounting for a full 98 percent of the State's emission free electricity. If the power from 

even one nuclear reactor were to be taken offline, it would significantly affect the State's 

emission free energy supply. So it's important to recognize that nuclear power is a critical asset, 

especially when thinking about standards such as the EPA's Clean Power Plant. (0721-21-1

[Martin, Patrick])

Appendix E NUREG–2176 E-460 October 2016
Comment: Nuclear plants are also unmatched in their reliability. The facilities of Florida 

operate around the clock, even at times of extreme temperatures and weather to generate 12 

percent of the State's total energy mix. They can be counted on the keep the lights on for 

Florida's businesses and for Florida's residents. I am pleased and honored to be able to offer 

these supportive comments on behalf of Nuclear Matters and I very much appreciate your time 

this evening. (0721-21-3 [Martin, Patrick])

Comment: We work out there, we take pride in where we work and we want our surrounding 

communities to have the support and the opportunity to understand the growth of the new plants 

being built are going to be, and that's what we're trying to do with our community outreach. So 

we want more people that want to come to work at nuclear power plants and we want them to 

be excited to come and work there and not scared. 

So back to my final thing and that's, we're the stewards of this industry and it's my job as a 

member of the staff out there to make sure that the community and the surrounding 

neighborhoods understand that it is clean, it is safe, you know. It's Captain Dan's points, the 

rising sea levels, you know, I appreciate that, I love the water. But we're also the cleanest and 

the least impactful on the environment that have anything to do with that. (0722-3-1 [Chatterton, 

Andrew])

Comment: [W]ith nuclear power you get clean, emission-free energy that's reliable and stable 

and runs virtually 24/7, so you always have power when you need it. On top of that, the energy 

that's being produced is also very economic. It will provide many customer savings. And to, you 

know, be specific, it's also -- within the first year of operations customers will save about $644 

million from fossil fuel costs and then projected to 40 years you'll be saving about $64 billion. 

And for the course of 60 years you'll be saving $173 billion on fossil fuels. I think that these units 

are economically practical and provide a lot of future support for many generations to come in 

South Florida. (0722-5-3 [Silva, Nicolas])

Comment: The question of whether the nuclear option was the best option, I've come to 

believe it's the most cost efficient and sensible way to approach the problem. (0723-1-2 [Wallace, 

Otis])

Comment: Because of the relatively low production cost, nuclear power operations helps us 

maintain the lowest bills in our State. This is also very important for small businesses who have 

to account for spending on healthcare, taxes and their utilities. (0723-10-5 [Brito, Rosa])

Comment: I'd just like to mention a couple articles that was in the paper and I went through 

them briefly this afternoon. The "Miami Herald" of -- let's see, February 17th, it was written by -- 

let's see here, Whitman. She used to be the Chairman of the board of H&P, Hewlett and 

Packard. But she wrote a nice article that covered a lot of the facts about nuclear power and 

how it was. But a couple of things, it was really motivating, I thought. It was "moreover, nuclear 

energy provides 98 percent of Florida's carbon-free electricity. Because nuclear plants 

production process emits no greenhouse gases, Florida reactors have officially offset 15 million 

of carbon emissions each year, equivalent of removing three million cars from our roadways." 

And then there was another article that was written by the ex-governor of New Jersey. The -- it 

was the "Sun Sentinel." "Florida's nuclear energy is exceptionally important as it provides about 

12 percent of the State's electric but it accounts for a full 98 percent of our emission-free 

electricity for Florida." And I think those two statements are very -- are very, very important.

(0723-14-3 [Riley, Bill])

Appendix E October 2016 E-461 NUREG–2176
Comment: And whereas nuclear power has been meeting the needs of our citizens of Miami 

Dade County for nearly 40 years, (0723-2-3 [Trowbridge, Mark])

Comment: They'll talk about fuel diversity. For myself I was always -- it didn't quite make sense 

to me, I've only worked in nuclear power. But fuel diversity, right, is where do you get your 

electricity from? What's the source of your electricity? That is one of those things, having that 

fuel diversity helps us control the cost of our electric bills. And every single one of us in this 

room get an electric bill every month. None of us like paying it but we all get it and we have to 

pay it, right? So you have fuel diversity that helps drive the cost down because natural gas 

prices move around a lot over the course of a year or five years, ten years. And adding 

additional nuclear power helps maintain that cost down as long as possible. And that pays for 

everyone, right. (0723-6-1 [Murphy, Mike])

Comment: I do know that my family worked at Plant Hatch and how nuclear power has 

benefited it. But I also do know some of the downsides to nuclear. There's not many that I know 

of with the nuclear regulations that we have in today's society. (0723-8-1 [McDuffie, Stephen])

Response: These comments express support for nuclear power in general. These comments 

do not provide any specific information related to the environmental effects of the proposed 

action. No changes were made to the EIS as a result of these comments. 

Comment: Nuclear power is clean, it's carbon free, and therefore it doesn't contribute to 

climate change. It's safe, it has a very safe record. They talk about Three Mile Island, everything 

that could go wrong went wrong and nothing happened, so it's a safe industry with a proven 

track record. It reduces our dependence on foreign oil. It's a win-win for everybody[.] (0721-27-3

[Rodriguez, Manuel J.])

Comment: [T]he cleanliness of the nuclear energy, the lack of emissions and the carbon 

footprint that is not being produced because of nuclear energy. I have a new grandson, I look 

forward to him and his children and his grandchildren having affordable, clean energy for their 

generations to come, for them and their generations to come. (0722-13-6 [Duquette, Bill])

Comment: Nuclear power plants typically operate at capacity factors above 90 percent making 

them the highest among all forms of energy. Nuclear power is also the only emission-free 

baseload energy for grids, large grids like those in South Florida. This is critical to Florida since 

we are a State that relies on clean air and beautiful beaches. (0722-4-2 [Moo, Patrick])

Comment: Turkey Point 6 and 7 would avoid more than 265 million tons of CO2 emissions in 

the first 40 years of operation. This is an amount that's equal to the annual equivalent of 

removing 56 million cars from the road. By providing clean and affordable energy that these 

plants would produce we would help ensure that Florida remains one of the best states to visit 

and reside in. (0722-4-3 [Moo, Patrick])

Response: These comments express support for nuclear power based on avoidance of CO2

emissions. The calculation of the expected greenhouse gas emissions for a reference reactor is 

given in Appendix J. The effects of climate change on the environment are discussed in 

Appendix I. No changes were made to the EIS as a result of these comments. 

Appendix E NUREG–2176 E-462 October 2016
E.2.32 General Comments in Support of the Existing Plant or the Applicant 

Comment: Taken with FPL's history of stewardship of the environment and their technical 

expertise in operating world class nuclear plants, I can see no reason for any objections to this 

project. (0002-2 [Hamilton, Brent])

Comment: I am strongly in favor of the addition of 2 more nuclear reactors to the current 

Turkey Point facility for the following reasons:...To date Turkey Point has been well run and 

dependable which add up to safety and dependability[.] (0015-2 [Goldmeier, Barry])

Comment: I have worked with FP&L at both the Point Beach NP in Two Rivers, WI, and the 

Turkey Point NP in Florida City, FL with Bechtel in the Safety Departments and have full 

confidence in the team to manage these plants safely. (0035-2 [Larrabee, Laura])

Comment: IN SUPPORT OF FPL. (0685-5 [Batista, Carlos])

Comment: I've worked on and off for Turkey Point, for Florida Power and Light at Turkey Point 

since 1988 as biologist that specializes in crocodiles. Over that time we have marked --I have 

marked over 5,000 hatchling crocodiles and from 500 nests. The cooling canal system is super 

saline, however, what a lot of people don't realize is within that super saline system are fresh 

water ponds and less saline ponds which, back in the '80s -- by the way there was only 220 

American Crocodiles in South Florida, plus or minus 78. So let's just say 150 to 300. As a result 

of this cooling canal being built -- and I know they didn't build it for crocodiles. Anyway, as a 

result of that the numbers of crocodiles have increased to a point where in April of 2007 the U.S. 

Fish and Wildlife Service down-listed American Crocodiles from Federally Endangered animal to 

a threatened species. So, again, a lot of that has to do with the management of Florida Power 

and Light. And I'm talking from my heart and I'm talking from what I see firsthand, and what I've 

seen for 25 years. Florida Power and Light is a steward for the environment, not only with the 

crocodiles but with a number of other wildlife species I see out there. What I've learned in 

working in all of these underprivileged countries that I work, and here in the United States, is 

that because of the state of the world today, it being Earth Day, the way the population is 

increasing, the need for power, the need for all of these amenities that we want, that industry 

and the environment can coexist. And somehow there has to be negotiations throughout all of 

this, and I just feel good about the job FPL is doing with the Crocodile Program and other 

wildlife species. (0721-14-1 [Wasilewski, Joe])

Comment: I heard someone talking about the once-through design for the cooling of the canals 

using sea water to go through the reactor, through the condensers for cooling, and back out to 

the sea. The initial design of Turkey Point was something similar to that, or basically a oncethrough design. Once we started realizing the impacts of the hotter water coming out of the 

condensers on the local ecosystem we went to the closed canal system. This closed canal 

system, of course, ended up attracting a lot of the wildlife Joe talked about, American Crocodile 

in particular. And that success story is now history. It's a great success story, and I think Joe put 

it best. It's a great way where the environment and a corporation can exist. (0721-15-1 [Kuraza, 

Devon])

Comment: And one last point I forgot to talk about as far as the canal water. I know some 

people talked about the elevated salinity and the algae bloom. The algae bloom was a recent 

event that occurred. We have been taking corrective actions and we've used an approach that 

has been tried and proven in the industry. So it's -- it wasn't FPL just going outside of their 

Appendix E October 2016 E-463 NUREG–2176
normal operation, it was something that we've seen in the industry, we talked about it and then 

we implemented it. (0721-15-13 [Kuraza, Devon])

Comment: The South Florida community has benefitted tremendously from Florida Power and 

Light's investment in nuclear energy and nuclear power for the past 40 years. We built that plant 

40 years ago with the Building Trades Council and the Building Trades members. The Turkey 

Point plant has not only benefit providing Florida Power and Light customers with clean -- clean, 

reliable energy, but has also been very supportive of our local environment, economy, in 

creating jobs in the process. (0721-19-2 [Riley, Bill])

Comment: Economic impact on our city is a very large key to the success of Homestead and 

from the perspective of the City Council we've been very comfortable with their track record as 

far as safety is concerned, their ability to respond appropriately to whatever may happen.

(0722-1-2 [Porter, Jeff])

Comment: The plant is operated well, it's operated safely for over 40 years. (0722-10-3

[England, Peter])

Comment: FPL is --and I should mention that FPL will provide and continues to provide 

significant tax, property tax revenues not only to Miami Dade County but also helping the school 

board. FPL is a great corporate citizen, the employees and the administration of Turkey Point 

are active in many, many events in our community. They provide a lot of money to United Way, 

for everything. We have Relay for Life at the hospital campus this weekend, they'll be out there. 

They're very into community activities and being good community citizens. (0722-13-5 [Duquette, 

Bill])

Comment: FPL, Turkey Point has been a great environmental advocate. The cooling canals, I 

don't know if you guys have been over there, I welcome you to -- I would suggest you go over 

there. They've done a lot environmentally to make sure that all the species and everything is 

maintained. Plus they have a unit onsite to look at environmental issues. (0722-13-8 [Duquette, 

Bill])

Comment: I was offered an opportunity to move to Alabama, very lucrative opportunity, and 

FPL kept me here. They're very good to work with, I see no evidence of environmental impact, 

and I support the expansion. (0722-18-1 [Berzowski, Bill])

Comment: So I think Florida Power and Light is doing a great job. I think that they are without 

a doubt as much concerned about the environment as anybody in this room[.] (0722-9-11 [Riley, 

Bill])

Comment: The South Florida community has benefited tremendously from Florida Power and 

Light's investment in nuclear power over the last 40 years. Turkey Point has not only been 

providing Florida Power and Light customers with clean, very clean, reliable energy but has also 

been very supportive of our local environmental issues along with the South Florida economy 

while creating jobs in the process. (0722-9-2 [Riley, Bill])

Comment: Along with a very strong environmental partner like Florida Power and Light we do 

and think that we can even do better, create random things for the communities and for the 

environment. (0722-9-6 [Riley, Bill])

Appendix E NUREG–2176 E-464 October 2016
Comment: But the most important issue of all for me was safety for obvious reasons. Florida 

City is very close to the proposed expansion area and again, given FPL's efforts in the area of 

safety being the vanguard of best practices for our safety[.] (0723-1-3 [Wallace, Otis])

Comment: Also I had the opportunity to visit Turkey Point and see the site, and I'm confident 

that everyone there takes all the necessary cautions to run a safe operation. (0723-10-2 [Brito, 

Rosa])

Comment: The Turkey Point plant has not only been providing Florida Power and Light 

customers with clean -- and I think the word "clean" here has been mentioned several times 

tonight -- it's clean, very clean, reliable energy. It has also been very supportive of our local 

environmental issues along with the South Florida economy which creates good paying jobs. 

(0723-14-2 [Riley, Bill])

Comment: And so I'm here to talk a little bit about FPL Turkey Point's environmental 

stewardship. You know, many people don't realize but back in the '60's our then president, 

McGregor Smith had a vision. It wasn't only just fossil fuel and nuclear fuel providing all the 

energy needs for humanity but also an interactive communal station for the community to come 

out and enjoy. We had Boy and Girl Scout camps, we had the deer and duck pond. We had, 

you know, canoeing and all kinds of activities for the community to go to. And as a child, you got 

to experience that. (0723-15-1 [Bertelson, Bob])

Comment: But getting back to, you know, what the original focus, the communal effort, the 

interactive community coming to us, well that really isn't possible because of 9-11. That affected 

all of us. However, we don't necessarily have -- I do have a group coming out to us tomorrow for 

education about our stewardship but we also go out to the community. We reach out. We travel 

to the Deering Estates. We travel to schools all around to spread the good word of what we do. 

So it's been rewarding for me, I can tell you. If somebody had said, 35 years from now what 

would you be doing, I wouldn't have come close to this. And I really thank FPL for that and I also 

thank you for listening to me. (0723-15-4 [Bertelson, Bob])

Comment: Whereas, the Coral Gables Chamber of Commerce, one of the community's leading 

business development organizations recognizes the critical role that Florida Power and Light 

Company plays in providing electrical generation in our community while serving as a 

tremendously generous corporate citizen, (0723-2-1 [Trowbridge, Mark])

Comment: [W]e just want to reiterate our support and let you know that we are very pleased 

with the corporate support that FPL provides in communities as great citizens, and the things 

that they do to bring jobs to our community. (0723-2-10 [Trowbridge, Mark])

Comment: ...clean, safe and reliable generation at the Turkey Point facility. (0723-2-4

[Trowbridge, Mark])

Comment: The last thing I want to say is, you know, there's a lot of talk about safety and I 

would say information that maybe is given to us from the NRC or from Florida Power and Light 

or what have you. Just remember that everyone works out at Turkey Point. Everyone who is 

involved with the nuclear industry, we all have families. We all have kids. We all have kids and 

wives and husbands who all live in this area. So we all take the responsibility that we have for 

running a nuclear reactor with absolute seriousness because we do understand the impact it 

can have and we do understand what we have -- the safeguards we have to have in place so 

accidents do not happen. We take it very seriously. There's a large number of guys from work 

Appendix E October 2016 E-465 NUREG–2176
and -- guys and gals from work here. You can ask any one of them, we take it very seriously 

because we understand the impact it could have. (0723-6-4 [Murphy, Mike])

Comment: FPL I can say from experience, it's a trustworthy company. And integrity is our most 

highly prized value, we talk about it a lot, take it seriously. And we have a way of talking about 

doing things where we say that we leave things better than we found them, down to the kitchen 

at work, the coffeepot, the stairwell. Leave it better than you found it. And we have that as kind 

of a motto of operating in our lives and in our work. And that seems to work out well in nuclear 

power especially. And so I have also as a matter of appreciation for FPL. (0723-7-1 [Boling, 

Steve])

Comment: And all those things somehow work together to create what I believe to be the 

safest industry in the United States. And I think I could prove that if I had any opportunity and 

needed to. I don't think I need to. (0723-7-4 [Boling, Steve])

Comment: And to all the workers that work out at Turkey Point, we do appreciate everything 

you do for us. (0723-8-6 [McDuffie, Stephen])

Response: These comments express support either for the Applicant or the existing reactor 

units at the Turkey Point site. They do not provide any specific information related to the 

environmental effects of the proposed action. No changes were made to the EIS as a result of 

these comments. 

E.2.33 General Comments in Opposition to the Licensing Action 

Comment: As a homeowner in the area, I want to express that I do not feel that any more 

reactors be built in the Miami area. (0006-1 [Faber, Davenie])

Comment: I am opposed to the building of two new nuclear power plants at Turkey Point in 

Homestead, Florida. (0007-1 [Johnson, Nadine])

Comment: I oppose the expansion. (0008-12 [Finver, Jody])

Comment: I am writing to express my firm opposition to FPL's request for permission to 

construct two new nuclear reactors at Turkey Point. (0009-1 [Rose, Simon])

Comment: Saprodani Associates herein submits the following comments regarding the EIS 

and urges the NRC and the NRC Commission to deny FPL's construction license and/or 

operational licenses accordingly. To the extent that the NRC has already granted the 

aforementioned license(s) - Saprodani Associates requests that the NRC and/or the NRC 

Commission revoke said licenses accordingly. (0010-1 [Saporito, Thomas])

Comment: Saprodani Associates has reviewed the NRC EIS extensively and has determined 

that the NRC has made unreliable conclusions related to the harm to the environment that 

will result from the construction and operation of FPL's Turkey Point Nuclear Units 6 & 7. 

Notably, the NRC appears to have made unsupported assumptions with respect to the 

environmental harm -and compensated said environment harm and impact -by offsetting -the 

same -with economic considerations for the licensee FPL. (0010-2 [Saporito, Thomas])

Comment: I am writing in reference to Docket ID: NRC-2009-0337 to express my opposition to 

the proposed expansion of Turkey Point Power Plant, located in Homestead, Florida. (0028-1

[Clapp, Linda])

Appendix E NUREG–2176 E-466 October 2016
Comment: I am not in favor of the nuclear reactors to be set in place a turkey point. (0030-1

[Gomez, Lissett])

Comment: My husband and I, tax paying residents of Miami, are strongly opposed to the 

expansion of the Turkey Point Nuclear Power Plant. (0031-1 [Hawkes, Holly Forrester])

Comment: As with many residents of Miami, I would like to express my strong opposition to 

expanding Turkey Point. (0032-1 [Vinciguerra, Anthony])

Comment: Members as a resident of the City of Miami I am deeply concerned about the 

proposal to add two (2) additional reactors in Turkey Point. (0034-1 [Rodriguez, Barbara])

Comment: This note is to inform you of my opposition to the construction of the Two New 

Nuclear Power Reactors- 6 & 7- at Florida Power and Light's Turkey Point facility. (0039-1

[Violich, Francesca])

Comment: I urge the NRC, and FP&L, to reconsider this ill conceived plan. (0039-5 [Violich, 

Francesca])

Comment: My husband and I are totally opposed to FP&L's plans to build TWO NEW 

NUCLEAR REACTORS at Turkey Point. (0040-5 [Pareto, Rolando and Marlene])

Comment: This letter is to inform you of my opposition to the construction of the two proposed 

Nuclear Power Reactors - 6 & 7- at Florida Power and Light's Turkey Point facility. (0044-1

[Commenters, Multiple])

Comment: Please be advised by this e-mail that I am strongly opposed to the construction of 

the two proposed Nuclear Power Reactors, 6 & 7 at Florida Power and Light's Turkey Point 

facility. (0045-1 [Johannsen, Christian])

Comment: There are quite a few other reasons why these reactors are a bad idea but I hope 

the ones I listed will be enough to help you make a decision that is in the best interests of the 

citizens of South Florida. (0048-4 [Wegner, Geri])

Comment: Please consider my dissent and that of so many other South Floridians who say NO 

to more nuclear reactors at Turkey Point. (0052-3 [Roos, Monica])

Comment: i am appalled that the NRC would even consider expanding Turkey Point at all, 

much less adding two new reactors! (0055-1 [Roedel, Kitty])

Comment: the NRC needs to do the right thing here. (0055-7 [Roedel, Kitty])

Comment: pls deny the addition of the two additional nuclear reactors at turkey point. it is a 

poorly conveived boondoggle by fp&l that the NRC should not entertain in this day and age!

(0055-9 [Roedel, Kitty])

Comment: As a Miami native I protest this expansion of nuclear power at Turkey point reactor,

(0056-1 [McCall, Eric])

Comment: I strongly oppose the construction of the two proposed Nuclear Power Reactors - 6 

& 7 - at Florida Power and Light's Turkey Point facility[.] (0057-1 [Neway, Roberta])

Appendix E October 2016 E-467 NUREG–2176
Comment: In short, please do not approve these reactors. Consider history, current conditions 

at Turkey Point, and the lives of the people of Miami-Dade County and the health of our 

ecosystem. (0057-5 [Neway, Roberta])

Comment: The NRC and FPL must NOT expand nuclear power generation at Turkey Point.

(0058-1 [Imbesi, Nan])

Comment: This letter is to inform you that my husband and I share the opposition to the 

construction of the two proposed Nuclear Power Reactors - 6 & 7 - at Florida Power and Light's 

Turkey Point facility. (0060-1 [Beckman, Yvonne and Douglas])

Comment: As a Homestead, FL, resident and a concerned citizen, I am completely against any 

expansion at Turkey Point Nuclear Power Plant. (0061-1 [Lague, Victoria])

Comment: As a resident, living a few miles from Turkey Point, I'm opposed to any expansion of 

the nuclear facility. (0062-1 [Raits, Eric])

Comment: Please stop more reactors at turkey point. (0063-1 [Smay, Betty])

Comment: I am greatly opposed to the nuclear expansion of Turkey Point. (0066-1 [Wong, 

Christina])

Comment: My childhood home is within the danger zone if something catastrophic were to 

occur. I grew up with that very real fear, which is still a reality. (0066-2 [Wong, Christina])

Comment: I am greatly opposed to this expansion. (0066-4 [Wong, Christina])

Comment: I object to Florida Power and Light's plan to expand Nuclear Power Generation at 

Turkey Point. (0067-1 [Commenters, Multiple])

Comment: I strongly recommend that Turkey Point 6&7 nuclear reactors be reconsidered.

(0076-4 [Daly, Meg])

Comment: Please say NO to the two new nuclear plants at Turkey Point! (0078-14 [Wilansky, 

Laura Sue])

Comment: I beg you to deny the FPL request for the expansion of the Turkey Point Nuclear 

Power Plant expansion. (0081-7 [Benson, Mary] [Skove, Ellen H.] [Tompkins, Constance])

Comment: As a voter I will be unable to support anyone sponsoring this proposal. (0084-3

[Phillips, Monica D.])

Comment: I am writing to object to the building of more nuclear reactors at Turkey Point and 

their attendant transmission lines. (0086-1 [Lawrence, Diane])

Comment: Please do not approve the building of these reactors and the transmission lines.

(0086-4 [Lawrence, Diane])

Comment: It is with grave concern that i write to you in reference to Florida Power and Light 

request for approval into adding 2 new Nuclear Reactors to their plant in Turkey Point Florida. 

(0087-1 [Lange, Alexandra])

Appendix E NUREG–2176 E-468 October 2016
Comment: I have read the plan in detail and i am astonished to see that they are still moving 

forward with a plan that Floridians and Miamians do not want. Their plan fails to guarantee any 

type of safety to our citizens (0087-2 [Lange, Alexandra])

Comment: If granted, I for one would move my manufacturing and marketing facilities out of 

south Florida. (0091-4 [Boyce, Sheila])

Comment: I would like to strenuously oppose Florida Power & Light's proposed expansion of 

nuclear facilities at Turkey Point. (0093-1 [DuPriest, William Robert])

Comment: Turkey Point Nuclear Not a good alternative!!!!!! (0095-1 [Hubler, Gina Marie])

Comment: Please deny the application for the expansion of Turkey Point Nuclear Power Plant. 

(0096-4 [Roberts, Linda])

Comment: I oppose the expansion of nuclear power at Turkey point. (0097-1 [Geary, Craig W.])

Comment: I am writing to express my concern and oppose to this project being approved.

(0101-1 [Gomez, Gustavo])

Comment: I am writing in reference to Docket ID: NRC-2009-0337 to express my opposition to 

the proposed expansion of Turkey Point Power Plant, located in Homestead, Florida. (0102-1

[Commenters, Multiple])

Comment: I am writing in opposition to the proposed expansion of Turkey Point Power Plant in 

Homestead, Florida. (0103-1 [Commenters, Multiple])

Comment: I urge you to deny the proposed expansion at Turkey Point and protect the region's 

people and unparalleled natural resources. (0103-8 [Commenters, Multiple])

Comment: I strongly oppose the expansion of Turkey Point and support the "No Action" 

alternative. (0104-6 [Commenters, Multiple])

Comment: I am writing in reference to Docket ID: NRC-2009-0337 to express my opposition to 

the proposed expansion of Turkey Point Power Plant. (0109-1 [Platt, David])

Comment: Please do not expand the Turkey Point Power Plant. (0109-3 [Platt, David])

Comment: We firmly believe that, due to the deficiencies in the information and analysis 

provided in the DEIS and the multitude of negative environmental impacts on the surrounding 

environment, the NRC should not issue COLs for Turkey Point Units 6 & 7. (0113-2-15 [Lopez, 

Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, Matthew] [Silverstein, Rachel])

Comment: I object to Turkey Point power plant's request to build new reactors. (0114-1

[Cunningham, Sue])

Comment: I am very much opposed to this action, as is the majority of the populace in South 

Florida! (0115-1 [Trencher, Ruth])

Comment: Please send FPL back to the drawing board to come up with a solution that serves 

the community not its shareholders. (0117-4 [Robertson, Alyce])

Appendix E October 2016 E-469 NUREG–2176
Comment: This is a bad idea. ... No (0118-1 [Zakon, Allan])

Comment: I am an electrical engineering graduate student at FIU and I want to express my 

disapproval of the expansion of Turkey Point's Nuclear Generation. (0119-1 [de Azevedo, Ricardo])

Comment: Do NOT approve FPL's request to build two new reactors. (0121-1 [Reyneri, Juan])

Comment: I am against the expansion of the Turkey Point nuclear power plant. (0122-1 [Meyer, 

Paul])

Comment: Please do not approve FPL's application for new nuclear facilities at Turkey Point.

(0124-3 [Colby, Helen])

Comment: I am completely opposed to the expansion of FPL's Turkey Point expansion project.

(0125-1 [Colls, Ana])

Comment: This is my testimony against FPL's plan of expansion. I feel FPL does not 

understand the extent of their actions, and they will be too late in realizing their mistakes.

(0127-1 [Cusidor, Teresa])

Comment: I wholeheartedly protest this expansion and every plan associated with it. FPL is an 

energy company monopoly. It's presence is already cancerous enough, do not make fasten our 

termination anymore. (0127-6 [Cusidor, Teresa])

Comment: I am adamantly against having FPL's nuclear power plant. (0128-1 [Bach, Lili])

Comment: Based on what I've read and heard about the environmental impact of the proposed 

new reactors (and the impact of the existing reactors), I am 100% opposed to the project.

(0130-1 [Jones, Diane])

Comment: I am concerned that expansion may not be the solution. (0132-3 [Mauri, Tom])

Comment: As a resident of Coral Gables, Florida, I find it disturbing that the NRC would even 

consider approving such an irresponsible and short sighted proposal as the one being put forth 

by Florida Power and Light for expansion of the nuclear facility at Turkey Point. (0133-1 [Corral, 

Oscar])

Comment: Please listen to the people and decline the FPL proposal for Turkey Point. (0133-5

[Corral, Oscar])

Comment: Please do not let this happen, (0135-3 [Thiel, Markus])

Comment: I respectfully request that the US Nuclear Regulatory Commission deny FPL's 

request for two new nuclear reactors at Turkey Point. (0136-5 [Levy, Morgan I.])

Comment: I urge you to reject this FP&L proposal and as a 45 year resident and taxpayer, I 

vehemently object to FPL's project as proposed. Many thanks for your support regarding this 

vital decision! (0138-1 [Miller, Howard R.])

Comment: You also need NOT to approve this disastrous plan. (0140-4 [Rhodes, Karen])

Appendix E NUREG–2176 E-470 October 2016
Comment: there is no reason to support the licensing of these proposed reactors. I strongly 

oppose the expansion of Turkey Point and support the "No Action" alternative. (0141-5 [Lucas, 

Carmen])

Comment: I would like to voice my complete opposition to this project. (0146-1 [Grant, Randy])

Comment: We are against any change to Turkey Point. (0147-1 [Jones, Joan and Robert])

Comment: I oppose FPL's proposal to build two more nuclear reactors at their Turkey Point 

site in South Florida. (0148-1 [Brinn, Ira])

Comment: I am writing to oppose the proposed 2 new nuclear reactors at Turkey Point. I 

attended the April 22, 2015 meeting at FIU to educate myself on this project. There were over 

200 people there to oppose it. I heard nothing to change my opinion only to make this project 

seem more ridiculous than ever. The U.S. Environmental Protection Agency (EPA) has stated 

that "the permit for the project should not be approved as currently proposed, because it may 

result in substantial and unacceptable impacts" to the local environment. (0149-1 [Nelson, Joyce 

E.])

Comment: 'PROGRESS ONLY FOR PROFIT' IS NOT WISE. THIS IS NOT SAFE. STOP

(0154-1 [Allen, Maureen])

Comment: I am against this project and it should not be allowed to go forward. (0159-1

[Bazzone, Barbara])

Comment: Please reject this expansion. It is in the wrong place, wrong time, wrong idea!

(0163-3 [Cook, Cherie])

Comment: I believe the proposed FPL expansion should be rejected as it brings along a 

plethora of both seen and unpredictable consequences. I hope that the Nuclear Regulatory 

Commission values safety over profit. (0171-2 [Oria, Jordan])

Comment: I live near Turkey Point and am not happy about this. (0175-1 [Sockloff, Judith])

Comment: Thus, I vehemently implore you to unequivocally deny this expansion. (0177-1

[McVicker, Micah])

Comment: As a lifelong resident of Miami and the Roads Neighborhood, only 25 miles north of 

Turkey Point, I vehemently oppose the construction and further expansion of this nuclear plant 

with two more reactors. (0178-1 [Almirola, Alejandro])

Comment: Please deny this request...plIn and simple. (0181-3 [Bremen, Gary])

Comment: I am strongly in agreement with the arguments stated below [opposing the 

proposed action]. (0184-2 [Perez, Danica])

Comment: Please do the right thing and do not allow this project to proceed. (0187-6 [MeyerSteele, Shawn])

Comment: I strongly oppose the expansion of Turkey Point and support the "No Action" 

alternative. (0192-7 [Lebatard, David])

Appendix E October 2016 E-471 NUREG–2176
Comment: Please do not allow this project. It isn't good for Florida's environment. (0193-3

[Shipe, Kathleen])

Comment: MUST WE ALWAYS PUT PROFIT FRIST. IN THIS CASE PEOPLE MUST COME 

FRIST!!! (0196-1 [Hart, Barbara])

Comment: I believe this project is not in the best interest of the citizens of Miami Dade. I 

believe the future is better served by using solar energy and energy conservation and efficiency. 

As the articles states, FPL's plan is regressive and harmful. I hearby state my OBJECTION to 

this project. We need to protect the environment for future generations. We need to be wise!

(0204-1 [Cooper, Fran])

Comment: Although this decision may be a means to enrich the shareholders of Florida Power 

and Light, it places the entire population of South Florida in jeopardy. I hearby request that you 

deny the construction and operating license for the proposed facilities at Turkey Point. (0206-3

[White, Holly])

Comment: My children and grand-children live in South Florida, and I want to preserve for 

them the beauty and natural wonder that I grew up with. (0207-8 [Cleland, Noel])

Comment: I'm a South Florida resident and I am expressing my opposition to expanding the 

Turkey Point nuclear plant any further. This project is the wrong project for this location and the 

permit to add more nuclear reactors should be denied. (0209-1 [Umpierre, Diana])

Comment: A Sick Dream. That is what adding reactors at Turkey Point is. How do you even 

consider such madness? (0216-1 [Osborne, Martin])

Comment: Please look to our children and their future and not to those who try to influence you 

to ignore what is best for the environment. (0217-1 [Fitzpatrick, Deirdre])

Comment: I am writing in reference to Docket ID: NRC-2009-0337 to express my opposition to 

the proposed expansion of Turkey Point Power Plant, located in Homestead, Florida. (0221-1

[Sophia, Tristan])

Comment: This is a terrible idea--don't do it! (0222-2 [Glass, Rachel])

Comment: I attended the evening public comment session at FIU. Although, I did not write this 

letter. It says everything that I would have said and I'm very concerned about each of the 

issues. (0223-1 [Robbin, Valerie])

Comment: I oppose the proposed expansion of Turkey Point Power, (0228-1 [Yeager, Jerry])

Comment: As voters, taxpayers, business owners and grandparents in Fort Lauderdale, we 

ask you to please prevent the nuclear expansion at Turkey Point. We don't need to list the many 

reasons why this ill-advised project should be stopped -- you have already heard them -- but 

please add our names to those who strongly oppose this project. (0233-1 [Purdy, Shyam and 

Mohini])

Comment: Not everything in this world is just about money, or getting it by making horrendous 

and greedy choices which will affect all of us. Please make a difference in this world, doing the 

right thing!!! I know YOU CAN. (0238-3 [Padilla, Dora])

Appendix E NUREG–2176 E-472 October 2016
Comment: Please do not do this! I don't see how you can collect money from your customers 

without them knowing where its all going. Not to mention the dangers of this. Is this really 

necessary? What is wrong with the nuclear power plants we already have? I do not want my 

money going to this. (0239-1 [Anonymous, Anonymous])

Comment: As a resident in South Florida I am opposed to the plans for two new nuclear plants 

at Turkey Point[.] (0240-1 [Commenters, Multiple])

Comment: No more power plants please. (0241-3 [Portuondo, Pilar])

Comment: Terrible idea. Do what is right! (0242-2 [Colby, Helen])

Comment: Their is no logical reason for building these two nuclear reactors. (0243-1 [DuranPinzon, Jaime])

Comment: Do not allow this travesty. Say no to the new nuclear reactors. (0243-4 [DuranPinzon, Jaime])

Comment: Please do not approve the expansion of the nuclear power plant at Turkey Point.

(0244-1 [Haber, Rochelle])

Comment: I believe you should do the right thing and not approve the Turkey Point plant 

expansion. (0244-3 [Haber, Rochelle])

Comment: I am writing to express my opposition to the proposed expansion. (0245-1 [Lindsey, 

Jerrie])

Comment: Do NOT approve this expansion! (0245-7 [Lindsey, Jerrie])

Comment: The impacts mentioned above are by no means the only adverse impacts from the 

addition of two new nuclear reactor units. I hope the NRC will take my comments into 

consideration and reject FPL's application. (0246-7 [Shlackman, Mara])

Comment: I live too close to Miami to allow this to happen (0248-2 [Kadis, Patricia])

Comment: This is a totally irresponsible idea given the potential environmental impact. (0249-1

[Mosher, Paul])

Comment: I strongly agree with the views expressed by the Mayors of Pinecrest, Palmetto 

Bay, & South Miami that the expansion of the nuclear facility at Turkey Point by FPL should 

NOT BE ALLOWED under any circumstances. (0251-1 [Whitfield, Isabelle])

Comment: As a taxpayer I want the NRC not to approve FPLs proposal for two new reactors.

(0257-1 [Padron-Delgado, Blanca])

Comment: Your recent decision to give tentative approval for two new reactors along the 

shores of Biscayne Bay via their Draft Environmental Impact Statement is Reprehensible!

(0259-3 [Lettieri, Tammy])

Comment: I urge the NRC, and FP&L, to abandon this ill-conceived plan to expand nuclear 

power generation at Turkey Point. (0263-6 [Orzechowicz, Holly])

Appendix E October 2016 E-473 NUREG–2176
Comment: In reference to Docket ID: NRC-2009-0337 the proposed expansion of Turkey Point 

Power Plant, located in Homestead, Florida NONO NO NO NO NO NO NONO NO NONONOT 

NO NO N O N O NO NO NO (0266-1 [Defoggi, Virginia])

Comment: This is insane! (0267-1 [September, P. J.])

Comment: Turkey Point Nuclear Reactor Plant is all ready ENOUGH A TREAT for us in the 

vescinity. Me and my Family STRONGLY OPPOSE to permitting of new developments of 

NUCLEAR POWER PLANT projects in this area we have called home for over 5 decades. 

Please take our concern to the highest level of descition making management for such 

unwanted projects. (0272-2 [Zuniga, Family])

Comment: It is illogical and inconceivable to me hat you'd be striving to expand Turkey Point 

Power Plant in Homestead, Florida. Just a few years ago we were forced to mobilize against 

development of an international airport at Homestead AFB which would have severely impaired 

Biscayne and Everglades National Parks. (0274-1 [Peterman, Andy])

Comment: Do you think we can ever get a grip on what makes sense for our region and 

country so the few citizens that are awake don't have to keep resisting these noxious proposals 

? (0274-2 [Peterman, Andy])

Comment: Please follow your own guidelines in this matter and deny this request for 

expansion. (0275-1 [Hayes, Linda])

Comment: As a lifelong Dade County resident, I oppose Florida Power & Light Company's 

attempt to build additional nuclear generators at its Turkey Point facility. (0283-1 [Compel, Jr., 

Joseph])

Comment: I am writing in opposition to the proposed expansion of Turkey Point Power Plant in 

Homestead, Florida. (0285-1 [Miller, Melissa])

Comment: We do not want you to approve construction of 2 new nuclear power plants at 

Turkey Point. (0287-1 [Beiriger, Mary])

Comment: The undersigned urge you to reject the application and choose the No Action 

alternative. (0288-1 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, 

Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: So here is my message to you: JUST SAY NO!! (0290-1 [Wry, Ellen])

Comment: This is not the place for another power plant. (0290-2 [Wry, Ellen])

Comment: Our eco system is so sensitive, how can this even be considered? (0292-1

[Rothstein, Debbie])

Comment: In reference to Docket ID: NRC-2009-0337, I stand strongly opposed to the 

proposed expansion of Turkey Point Power Plant, located in Homestead, Florida. (0295-1

[Dietrich, Chris OMeara])

Comment: I strongly oppose the expansion of Turkey Point as proposed in Docket NRC-2009-

0337. (0299-5 [Salatino, Freda])

Appendix E NUREG–2176 E-474 October 2016
Comment: I Oppose the Proposed Expansion of Turkey Point, Docket ID: NRC-2009-0337.

(0300-4 [Van Pelt, Jason])

Comment: The only real pressure You will feel is in not protecting your fellow citizens and the 

environment in which they live. Please do not knuckle under to the Fear of Politics and 

pressure. You are the one that looks into that mirror every morning. (0301-1 [Jimenz, Lawrence])

Comment: Although FP&L does a good job in managing as much as possible, expansion 

would tip the scales too strongly. (0308-2 [Wallington, Victoria])

Comment: The following paragraphs tell me and I would think would also tell you why it should 

not be permitted. (0319-1 [Dent, William])

Comment: To expand upon on already ill-placed power plant is a horrible idea. (0323-2

[Jennings, Cara])

Comment: Stop this now before there are horrendous repercussions. (0326-2 [Earnshaw, 

Shinann])

Comment: The application should be denied. (0329-1 [Baumwall, Douglas])

Comment: I, as a resident of Palmetto Bay, FL, do not want another nuclear reactor built at the 

Turkey Point faculty. (0330-1 [McCarthy, Dawn])

Comment: I live in and my children attend school in Palmetto Bay, and I already feel a 

constant threat of a nuclear accident. The last thing I want is for further endangerment of our 

community. (0330-2 [McCarthy, Dawn])

Comment: Don't let FP&L do it! (0334-1 [Crystal, Chris])

Comment: I am against any additional nuclear power generation in Florida. (0335-1 [K., Jeff])

Comment: Accordingly, we respectfully request that you reject the application for additional 

nuclear facilities at Turkey Point. (0338-2 [Kavanaugh, Daniel])

Comment: We cannot urge you strongly enough to deny this license. The dangers to the 

environment, as well as to human life, inherent in such a project are beyond doubt. (0341-1

[Daniels, Bonnie])

Comment: The disastrous effects of a potential weather event - a hurricane being a highly 

likely risk in this area - are undeniably real and have been well illustrated by Fukushima. We 

lived through Hurricane Andrew, and our home is only a few miles from Turkey Point; we do not 

want, nor see the need for, the risks this project entails in our own backyard. (0341-4 [Daniels, 

Bonnie])

Comment: With reference to the upcoming meetings concerning the approvals for a nuclear 

facility at Turkey point, please note I DO NOT think the project is necessary. (0343-1 [Cardona, 

Alfredo])

Comment: Quite to the contrary, I feel that its proximity to a major urban area and its location 

in a place subject to hurricanes suggests that the permits should be DENIED. (0343-2 [Cardona, 

Alfredo])

Appendix E October 2016 E-475 NUREG–2176
Comment: I do not approve. (0347-2 [Petersen, John])

Comment: Please reconsider this project. (0349-4 [Oliva, Vivian])

Comment: Though I am sure your researchers truly believe the plants will not harm anything I 

think in the overall picture from generations to come, even they don't have all the 

answers. Please consider the impacts carefully and make a choice that is right for people and 

the environment and not for power companies and profits (0352-3 [Tingle, Peggy])

Comment: This is a terrible idea and I am thoroughly against it. (0354-1 [Anonymous, 

Anonymous])

Comment: Please scratch this idea once and for all. (0355-3 [Thomas, Bill])

Comment: It's time for FPL to face the future rather than fight it, and for public officials to 

promote the public interest rather than short term corporate financial interests. (0356-17

[Shlackman, Jed])

Comment: I object to Florida Power and Light's plan to expand Nuclear Power Generation at 

Turkey Point. (0358-1 [Norman, Ronald])

Comment: I simply am not willing to take the necessary personal and financial risk to further 

FP&L's business objectives. I hereby request that you deny the construction and operating 

license for the proposed facilities at Turkey Point. (0358-5 [Norman, Ronald])

Comment: I oppose this plan. (0361-1 [Berndgen, Michelle])

Comment: Please don't approve this short sighted plan. (0361-4 [Berndgen, Michelle])

Comment: I urge you to not build and expand Turkey Point Nuclear Plant. (0362-1 [Hurley, 

Paula])

Comment: I urge you to consider the ENORMOUS effect of the HIGH risks of expanding 

Turkey Point power plant. Have you ever relaxed and recharged in nature? Please think of your 

children, grandchildren or others only being able to hear I stories of what beauty was and not 

being able to experience it themselves. (0362-6 [Hurley, Paula])

Comment: I am speaking out against the expansion of the Nuclear power plant at Turkey 

Point. I don't believe it is in South Florida's best interest, nor in the best interest of the world.

(0363-1 [Peters, Emily])

Comment: There is very serious cause for concern regarding the negative environmental 

impacts of Turkey Point Nuclear Power Plant. The addition of 2 more nuclear reactors will 

exacerbate the existing problems to a crisis level. (0365-1 [Fischer, Antoinette])

Comment: Am strongly opposed to granting the licenses for Turkey Point. (0368-3 [Casey, Sr., 

Robert J.])

Comment: Building two new nuclear reactors at Turkey Point, an incredibly sensitive natural 

ecosystem, is a truly terrible idea. (0370-1 [Vayu, Satya])

Appendix E NUREG–2176 E-476 October 2016
Comment: Please do not allow new nuclear reactors to be built at Turkey Point. (0370-14 [Vayu, 

Satya])

Comment: Building additional reactor units at Turkey point is a really bad idea. (0371-1

[Haffmans, Edmund])

Comment: Please say NO to Turkey Point 6 & 7. (0371-6 [Haffmans, Edmund])

Comment: I've lived in this area for over 30 years. I have 2 young kids. As a parent I'm trying 

to teach my kids about the importance of recycling and respecting our environment. I am sad, 

disappointed and scared that FPL was able to get this far in the process. When are we, as 

adults, going to start practicing what we preach to our kids? (0372-2 [Ortiz, Natalia])

Comment: None of this makes any sense. I hope and pray that you will do what's right. That 

you will object to this and show FPL and Tallahassee that money doesn't trump safety. (0372-5

[Ortiz, Natalia])

Comment: Do not License this application, no way, no how. (0373-1 [Lee, Nancy])

Comment: In reference to Docket ID: NRC-2009-0337, I oppose FPL's proposal to build two 

more nuclear reactors at their Turkey Point site in South Florida. (0379-1 [Commenters, Multiple])

Comment: The Turkey Point 6 & 7 Expansion only adds to a BAD situation. (0380-1 [Anderson, 

Vaughn])

Comment: Seriously, some chucklehead must lose his payday over this and it's not a bad idea 

to lose his/her supervision, as well. Whatever were you thinking? (0384-3 [Franzmann, Paul])

Comment: THIS IS EXTREMELY IMPORTANT! LIFE DEPENDS ON THIS! (0385-1 [Greenwald, 

Ken])

Comment: To think that the expandtion in the area, turns my stomack. What is the 

management thinking. It seems that theydon't think anything about our ecology. We are 

poisoning our water and killing fist by the thhousands is some parts of the world. (0392-1 [Greer, 

Tom])

Comment: My personal feeling is that this is a Very Bad Idea. Weather, potential water levels 

and other factors make this facility not worth the risk. (0395-1 [Fishman, Zelma])

Comment: As a Georgia resident, we spend quite a bit of time in Florida. As a mom, I ensure 

that my children understand the necessity of our role as humans to protect land and 

water. Therefore, I am writing in reference to Docket ID: NRC-2009-0337 to express my 

opposition to the proposed expansion of Turkey Point Power Plant, located in Homestead, 

Florida. (0397-1 [Blanck, Heidi])

Comment: The expansion would be a huge mistake from any perspective for South Florida.

(0402-1 [Dunn, Elmo])

Comment: PLEASE TAKE THE RIGHT, FAIR, JUST, HUMANE AND HEALTHY ACTION AND 

OPPOSE THE PROPOSED EXPANSION OF TURKEY POINT. (0403-1 [Graffagnino, Mary Ann 

and Frank])

Appendix E October 2016 E-477 NUREG–2176
Comment: A family tradition for 25 years has been "head to Florida to recover from winter and 

enjoy parks, beach, water and baseball". Homestead is an important location for access to 

those goals! (0407-1 [Kaye, Jackie])

Comment: I propose you have enough grid feeds in Florida to supply everybody. If ya need 

more juice then build another unit at St. Lucie County. I don't live near Miami but I do know what 

the Biscayne park is as I ride my bicycle there with my bike club...NO is the answer. (0410-1

[Quinn, George])

Comment: With or without, we face a barren world without animal life and soon without human 

life and so I am writing in reference to Docket ID: NRC-2009-0337 to express my opposition to 

the proposed expansion of Turkey Point Power Plant, located in Homestead, Florida. (0411-1

[Kern, Madeleine Fisher])

Comment: In reference to Docket ID: NRC-2009-0337, I oppose the proposed expansion of 

Turkey Point Power Plant located in Homestead, Florida. (0413-1 [Cobb, Tanya])

Comment: Quit destroying the environment----we only have one. (0416-1 [Underwood, John])

Comment: Please oppose expansion of Turkey Point Power Plant. (0417-1 [Beattie, Jane])

Comment: Surely you cannot be considering this! (0422-1 [Yount, Madeline])

Comment: I am a supporter of nuclear power, and believe that it should be a key component of 

any future energy plan as we transition to an era of less dependance of fossil fuel. However, the 

expansion of the Turkey Point Power Plant is unacceptable. (0423-1 [Peterson, Ted])

Comment: Please, this is extremely important not just for our area, or for the entire State of 

Florida, but for our nation. I am writing in reference to Docket ID: NRC-2009-0337 to express my 

opposition to the proposed expansion of Turkey Point Power Plant, located in Homestead, 

Florida. (0428-1 [Leo, Carlos])

Comment: Biven the points made above, the proposed expansion would be the wrong thing to 

do. (0433-1 [Vermeulen, Mary])

Comment: This place should be closed, not expanded. (0435-2 [West, Eric])

Comment: There is time and place for everything, but this is neither the time or place. (0436-1

[Boone, Jim])

Comment: We are APPALLED AND OUTRAGED that our own government would propose the 

expansion of Turkey Point Power Plant, located in Homestead, Florida. (0440-1 [Hoyle, Lester and 

Judy])

Comment: The site proposed for expansion is located RIGHT NEXT TO MIAMI[.] (0440-5

[Hoyle, Lester and Judy])

Comment: SIMPLY ANOTHER ATTEMPT BY CORPORATE ENTITIES TO EXPAND THEIR 

PROFITS WITH NO REGARD FOR PUBLIC AND PLANETARY HEALTH!!! WE HAVE HAD 

FAR, FAR TOO MUCH OF THIS CRAP!!! PLEASE DO THE RIGHT THING: SAY 

ABSOLUTELY NOT!!!!!!!!! (0444-1 [Bodiford, Loretta])

Appendix E NUREG–2176 E-478 October 2016
Comment: Having lived within "blowing up" distance of Indian Point, NY and read about their 

current problems, we really don't need more expansion, particularly near a national park that is 

near sea level. (0450-2 [Richards, Margie])

Comment: As the voting constituents of your administration, we strongly oppose the expansion 

of nuclear power generating facilities, specially at Turkey Point. (0451-1 [Durieux, P.])

Comment: In conclusion, the City reiterates its belief that the Turkey Point Nuclear Plant Units 

6 & 7 application should not be approved as currently proposed. (0456-25 [Miami, City])

Comment: Actions that were considered safe during the 1900s, are no longer. The dangers 

are too great because actions to repair are never enough. (0466-1 [Kirschbaum, Saran])

Comment: It is not the way to go. (0469-2 [Weber, Zorina])

Comment: It is a terribly bad idea, a fools' errand. (0470-3 [Lenz, Andrew])

Comment: This is a bad plan anyway. Even the existing structure poses a potential threat. 

Why make it even worse? Bucks for someone and other people are just collateral damage?

(0471-2 [Manter, Larry])

Comment: As a resident of Florida, I get a voice in the discussion about the proposed new 

nuclear reactors at Turkey Point and I say NO to the proposed project. (0472-1 [Ball, Cheri])

Comment: Please do NOT move forward with the proposed nuclear initiative as FPL has 

proposed. (0472-3 [Ball, Cheri])

Comment: NO to Nuclear Expansion! (0475-1 [Mayer, Karen])

Comment: Please come to your senses. Help your children and grandchildren inherit a world 

that's worth living in !!! Show them our generation's concern for the rest of the world doesn't end 

at the tip of our noses !!! (0478-1 [Svensson, Bo])

Comment: Couldn't believe what I was reading when I saw this. As a former Miamian, and 

someone who has witnessed the savging of Florida's once-rich resources, this proposal at first 

seemed like a fundraising ploy - or a bad joke. Even without the inevitable rise in ocean levels, it 

is a demented and dangerous idea. (0479-1 [Pearce, J. B.])

Comment: No. Simply NO. (0480-1 [Simmerman, Scott])

Comment: Send them back to the drawing board. And PLEASE, do not succumb to the 

probable greedy interests behind this approach to problem solving. (0484-3 [Speno, Charlie])

Comment: Someone's corporate greed and profits are probably at stake here but they will live 

without this. (0486-2 [Douglas, Carolyn])

Comment: Too close for comfort! This is not a smart move! (0489-1 [Galbreath, Jerry])

Comment: EXPANDING THE NUCLEAR FACILITY WILL DO HARM TO THE 

ENVIRONMENT. PLEASE DO NOT APPROVE THIS PROJECT. THANK YOU! (0490-1

[Jurczewski, Carol])

Appendix E October 2016 E-479 NUREG–2176
Comment: Saving this beautiful place forever should be a priority. It is very important to 

sustaining the clean water supply for Florida as well as environment for the wildlife. Please do 

not destroy anymore habitat at this location. (0504-1 [Gomez, Toni Thoman])

Comment: This is true information and I think the fact that they kept this out of the news may 

be good ammunition for you to use to Stop enlarging Turkey Point Nuclear Reactor Now ?? !!

(0505-3 [Buyea, Thomas])

Comment: In reference to Docket ID: NRC-2009-0337, I oppose FPL's proposal to build two 

more nuclear reactors at their Turkey Point site in South Florida. (0508-1 [Harrison, J. M. M.])

Comment: The location is vulnerable to Hurricanes, sea level rise and terrorist attack. By all 

measures this proposal should be rejected. (0509-3 [Otto, Peter])

Comment: The concerns and objections to this project were succinctly expressed in the 

following article: http://www.miamiherald.com/opinion/op-ed/article20380647.html. Please add 

my objection to this enormously impactful and dangerous project. (0510-2 [Langlieb Greer, Evelyn])

Comment: Please accept and review my letter in opposition to nuclear reactors at Turkey 

Point. (0511-1 [Draper, Lonnie M.])

Comment: I am asking you to do everything in your power to protect Miami from these risks.

(0515-8 [Regalado, Tomas])

Comment: Please deny permits for the proposed expansion of the Turkey Point Power Plant in 

Homestead, Florida. (0518-1 [Weiss, Arwen])

Comment: IF people were truly smart they would recognize the basic concept of carrying 

capacity and realize the solution is fewer people. So please stop empowering stupidity and help 

make people be responsible for their actions. Please do not support this project. (0520-1

[Bernatis, Jenn])

Comment: As a South Florida resident and a citizen concerned about the protection of our 

local nature, wildlife, and the future risks to everyone who resides near to this project, it is my 

duty to tell you that i believe strongly the risks inherent in this expansion outweigh the benefits 

of constructing extra nuclear capacity. (0523-1 [Mitzkewich, Yuri])

Comment: Thank you for considering my request. According to the NRC's own guidelines this 

expansion is prohibited! Why is it even being suggested? Tell them "NO!" and be done with it!

(0531-1 [Slaton, Marina])

Comment: This proposal is in violation of the NRC's own guidelines. Why is it under 

consideration? (0535-1 [Bump, Deborah])

Comment: NO EXPANSION OF NUCLEAR PLANT AT TURKEY POINT!!!! (0536-1 [Mikan, 

Edward])

Comment: It surely doesn't seem that expanding Turtle Point is a good idea. (0539-2 [Malone, 

Peggy])

Comment: It is essential that you stop it now, no new plans for Turkey Point!!! (0540-4 [Burge, 

Laura])

Appendix E NUREG–2176 E-480 October 2016
Comment: I am very opposed to more reactors at Turkey Point. This is wrong for a large 

variety of reasons: Environmental, safety, visual (tourist and locals viewing the power lines), 

impedes Everglades restoration, financial (nuclear has been an expensive boondoggle). I can 

go on at length. As a taxpayer and user of electricity from FPL I object to having to pay for this.

(0543-1 [Ryan, Jim])

Comment: This is a ridiculous waste and FPL and the NRC are on the wrong side of history. 

Wake up! (0543-3 [Ryan, Jim])

Comment: Expanding a nuclear power plant in ths area makes no sense to me. It is in 

Hurricane Alley, it's at ground zero for sea level rise in the US, it is a beautiful tourist attraction, 

it is a delicate ecosystem, and the area is already suffering from salt water intrusion that will 

presumably only be excerbated by these new units. (0544-1 [Ehrenfried, Jennifer])

Comment: I request that you deny FPL's request to spend in excess of 18 Billion dollars in 

order to construct two new AP-1000 reactors at Turkey point and operate them mid 2020's 

onwards to 2090's. (0545-1 [Keating, Tim])

Comment: I am against the proposed new reactors at Turkey Point and agree with the 

comments made by the South Florida Wildlands Assn. (0546-1 [Hoffmeyer, Lisa])

Comment: I am against any nuclear power plants operating in areas that are prone to natural 

disasters which could cause long-term power outages, flooding, wildfires, or seismic activity. 

Look at what has happened and continues to happen at Fukushima. Can you fathom the 

situation if that type of accident were to occur in a deensly populated area in the US? (0547-1

[F****SH, Peter])

Comment: Please stop the madness! (0550-5 [H., Pat])

Comment: Please do not approve this project, there are way too many health and 

environmental risks involved. (0553-1 [Punnett, Daniela])

Comment: I am leaving Miami if this project goes through, in order to protect my family and two 

children. It is outrageous that this is even being considered. (0553-3 [Punnett, Daniela])

Comment: Having spent 31 years in the USMC and travelling the world I clearly understand 

both perspectives. However, the take away for me is once we destroy what nature has provided, 

there is no going back! Look at the lessons the world has learned, but can't undo, don't make 

this another mistake we, and more importantly our children live to regret! (0557-1 [Smythe, Ana])

Comment: In reference to Docket ID: NRC-2009-0337, our right to clean water, land and air, 

essential to life liberty and the pursuit of happiness, trumps their right to build a plant and pollute 

our environment with radioactive waste and discharge, and a possible meltdown, especially in 

the path of major hurricanes. Have we learned anything from the Fukushima Disaster? Why isnt 

there a major effort to make the Sunshine State the Solar Powered State? Hence, I vehemently 

oppose FPL's proposal to build two more nuclear reactors at their Turkey Point site in South 

Florida. (0559-1 [Lettieri, Tammy])

Comment: As a retired Bechtel employee involved in nuclear power plants, I am very familiar 

with plant design and its impacts. (0562-1 [Hardie, Daniel])

Appendix E October 2016 E-481 NUREG–2176
Comment: OUTRAGE AND OPPOSITION TO THE PROPOSED INSANITY OF EXPANDING 

TURKEY POINT POWER PLANT (0564-1 [Dimondstein, Carla])

Comment: This is comparable to the Indian Point Nuclear Facility in NY which is now 

threatening residents in a very wide circle!!!!! (0566-1 [Rosenfeld, Alice])

Comment: I am writing as a citizen and a physicist in reference to Docket ID: NRC-2009-0337 

to express my opposition to the proposed expansion of Turkey Point Power Plant, located in 

Homestead, Florida. (0567-1 [Cohen, Howard])

Comment: I am writing in reference to Docket ID: NRC-2009-0337 to express my opposition to 

the proposed expansion of Turkey Point Power Plant, located in Homestead, Florida. (0568-2

[Goldberg, Laura])

Comment: As a citizen of Miami-Dade county for my entire life, I am deeply concerned by the 

actions FPL is trying to take with regard to nuclear expansion. While I understand that our cities 

and counties have growing needs for energy, I do not believe this is the right route to take.

(0570-1 [Martinez, Orlando A.])

Comment: For these reasons, and others highlighted here: 

http://www.miamiherald.com/opinion/op-ed/article20380647.html I ask that you NOT grant FPL 

permission to move forward with it's proposal. (0570-5 [Martinez, Orlando A.])

Comment: This proposed expansion is a real turkey! It poses danger to our lives, nothing less. 

Please do not allow expansion. (0572-1 [Mcintyre, Frances])

Comment: As a member of the local community (living in unincorporated Miami-Dade County 

only a few miles from Turkey Point), I urge the commission NOT to approve the FPL application.

(0573-1 [Trauner, Keith])

Comment: I'm against this project, this doesn't benefit the HEALTH or ENVIRONMENT.

(0574-1 [Fuentes, Mariana])

Comment: I am opposed to the expansion of the Turkey Point nuclear power plant. (0579-1

[Schwab, Roy])

Comment: [Do] not allow this expansion to go through. (0579-6 [Schwab, Roy])

Comment: Are you people crazy??? This scheam is deviant and devoid of any rational thought 

! DO NOT DO THIS!!! (0580-1 [Lawrence, Theresa])

Comment: Think! This is a hideous idea; STOP THIS !!! (0580-3 [Lawrence, Theresa])

Comment: In my estimation it is time pull the plug on this ill thought out endeavor. (0585-1

[Hilderbrandt, Todd])

Comment: Having learned about the proposed expansion of the Turkey Point Power Plant that 

is in Homestead, Florida, I write to urge that this not be approved. (0588-1 [Hanna, Jane])

Comment: I am an ordinary citizen of Florida and a concerned citizen of the United States. It is 

so common for we humans to put off until tomorrow what we can do today. With regard to the 

environment and to clean energy we have put off action so long we really have to STOP doing 

Appendix E NUREG–2176 E-482 October 2016
business as usual now. Please do not approve FPL's request to build two additional nuclear 

reactors at Turkey point. (0595-1 [Ghosh, Susan])

Comment: I object to the new reactors. (0596-1 [Sorenson, Katy])

Comment: Bad idea! Think that more creativity is needed to solve energy needs without 

endangering, plant, animal and human life. (0600-1 [Edwards, Suzi])

Comment: The Point Is: they can't be trusted to do the right thing as only PROFIT drives 

them!! (0604-2 [Courliss, William])

Comment: This is irresponsible. (0606-1 [Metje, Melodie])

Comment: As a SCUBA diver, I can appreciate further environmental issues from nuclear 

expansion. (0614-1 [Dauerty, Barbara])

Comment: To put it succinctly, there is no way that the NRC can claim to meet its legal 

obligations to public health and environmental safety in licensing the construction of these 

plants in South Florida. The combination of the AP1000's new and untested "passive safety" 

features and the particular meteorological, hydrological, and population density characteristics 

of the area preclude the legal licensing of Turkey Point 6 and 7. (0615-1-12 [Bethune, David])

Comment: Given now the incontrovertible evidence that the applicant's COL for Turkey Point 6 

and 7 presents unacceptable risks to human health and the environment, I demand that the 

NRC swiftly and conclusively terminate these licensing proceedings. (0615-3-12 [Bethune, David])

Comment: The two new proposed nuclear reactors at Turkey Point are not only dangerous for 

the environment, but dangerous for the community in a fragile location. (0625-1 [Felinski, Julee])

Comment: Stop this development at Turkey Point, before it's too late! (0625-5 [Felinski, Julee])

Comment: Shame on you for even considering this. You're a public menace and this needs to 

STOP! Oh, but what YOU are doing will be "safe"? Get real! Stop these plans right now!! (0628-3

[Anonymous, Anonymous])

Comment: Please do not approve this expansion at Turkey Point. (0631-1 [Griswold, Dave])

Comment: Please reconsider these projects. (0633-1 [Cornely, Tina])

Comment: The habitat for wildlife cannot-be replaced if there is an accident and I believe the 

risks are too great to warrant going forward with the Nuclear Power Plant. (0635-2 [Seiman, 

Rhonda])

Comment: Please deny the application for more nuclear plants in south Florida. (0635-4

[Seiman, Rhonda])

Comment: I am writing in opposition to FPL's request for two new nuclear reactors at their 

Turkey Point location. (0642-1 [Rawlins, Steve])

Comment: I urge the Nuclear Regulatory Commission to deny approval to the Florida Power 

and Light company to build two more reactors. Let us start to behave in a way that is safe and 

environmentally sound. (0642-6 [Rawlins, Steve])

Appendix E October 2016 E-483 NUREG–2176
Comment: But at a minimum, please don't add to the problem! (0643-4 [Joannou, Jr., Benjamin])

Comment: Please don't add any new nuclear reactors! (0643-6 [Joannou, Jr., Benjamin])

Comment: I say no. No, no No! (0644-1 [Anonymous, Anonymous])

Comment: This is absolutely irrational unless you have a vested interest. And you are a 

sociopath and are devoid of empathy of any kind. (0644-5 [Anonymous, Anonymous])

Comment: The Homestead/Miami area is also at a high statistical risk for hurricane hits. We all 

know that Homestead was devastated in August, 1992 by hurricane Andrew. We should take 

this risk seriously, and admit, that for this reason alone, expansion at Turkey Point Power Plant 

is a very poor idea. (0646-1 [Pattison, Janet])

Comment: As a matter of fact I strongly feel it would be absolutely stupid and absurd to 

expand this plant. (0651-1 [Young, Kim])

Comment: This expansion should ABSOLUTELY NEVER HAPPEN!!!!!!!! (0651-3 [Young, Kim])

Comment: PLEASE DO NOT ALLOW THIS TO HAPPEN, WE DO NOT NEED A BIGGER 

PLANT!!! (0651-5 [Young, Kim])

Comment: I do not support the construction and subsequent operation of Units 6 & 7 at Turkey 

Point. I believe the potential negative environmental impact creates too much additional risk for 

the area. (0653-1 [Hickey, Alan])

Comment: I am one hundred percent opposed to building/expanding Turkey Point Nuclear 

Plant. (0662-1 [Anonymous, Elena])

Comment: bad idea.. (0664-1 [Alvarez, Chad])

Comment: I vehemently oppose the proposed expansion of nuclear reactors at turkey point. 

Please, for once, think of the health of the citizens of Miami and their families. Not to mention 

the environmental impacts could be catastrophic. Please don't let this plan pass, it is a mistake 

and a tragedy. Miami is vulnerable enough to climate change, let's make a good example of 

Miami as a leader in environmental protection and human health--oppose these reactors!!!

(0665-1 [Castro, Alyssa Tomasi])

Comment: I am opposed to the building of two additional nuclear reactors at Turkey Point. If 

they were built the damage to the environment would be huge. (0666-1 [Jens-Rochow, Steve])

Comment: The building of these reactors is an abomination (0667-1 [Brown, Bradford])

Comment: No to the two planned nuclear reactors. PLEASE! (0672-1 [Barnidge, Virginia])

Comment: I urge you to deny the permit for building reactors #6 and #7. (0674-8 [Dwyer, Karen])

Comment: Don't put our beautiful peninsula in jeopardy by approving more nuclear reactors.

(0677-7 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: Don't commit our children to this fiasco! It's good for FPL, not the public! (0679-1

[Jacobs, Lee])

Appendix E NUREG–2176 E-484 October 2016
Comment: Please treat our neighborhood as if you were living here. (0684-1 [Scherr, Matthew])

Comment: How else can the government screw up our natural resources, it goes on and on, 

and we seem helpless to stop it!!!! (0690-1 [Egan, June])

Comment: We do NOT need to expand this facility, especially in such a vulnerable area. 

(0692-2 [Nickerson, Nancy])

Comment: This project is just a really bad idea. (0693-2 [Dorn, Kathryn])

Comment: We simply do not need any more nuclear facilities. (0696-1 [Johnson, Rheta])

Comment: Please, please, please listen. This issue is vitally important to each and every one 

of us--worldwide. We are writing in reference to Docket ID: NRC-2009-0337 to express our 

opposition to the proposed expansion of Turkey Point Power Plant, located in Homestead, 

Florida. (0698-1 [O'Donahoo, Gayle] [O'Donahoo, Roger])

Comment: The risk of nuclear contamination in this delicate environment is far too great. If we 

allow this project to move forward we will never be able to turn back again. (0709-1 [Cummings, 

Frank])

Comment: The construction of a new power plant is a very bad investment for the people of 

Florida and should not be carried out. (0713-4 [Heiney, Jamie])

Comment: Have we gone insane, suicidal or are we just stupid!? (0718-3 [Buechler, Jerry])

Comment: Please be mindful and recognize this is a choice that comes from greed. We are all 

one and we are the environment. By taking care of our present, we take care of our future. 

Please don't let this happen ... It's time for change. (0720-3 [Bastidas, Mauricio])

Comment: So I'll just conclude it by just saying that, again, I'm not a technical expert, but from 

my vantage point working in State policy, just asking you to understand that the artificial 

incentive to pursue this application on the part of our electric utility is because we're being 

forced to pay for it by State law. And that's the reason why I believe that in their application and 

in their zeal they can ignore the cost on our economy, they can ignore the cost on our 

community, on safety, and our environment, and on behalf of my constituents, I ask that you not 

do the same. (0721-1-11 [Rodriguez, Jose Javier])

Comment: So what would the environmental impact of building 6 and 7 be? It will compound 

the disaster which has already occurred at Turkey Point, possibly the worst place to produce 

energy on the planet. (0721-12-8 [White, Barry J.])

Comment: So for all of these reasons I encourage all of you to go research some of these 

things and write in and let's oppose this and stop this plant from being built here. (0721-23-9

[Bethune, David])

Comment: The many objections from residents like me are outlined in the form letter sent to 

you. (0721-26-4 [Koenigsberg, Linda])

Comment: I would suspect that the executives of FP&L, the architects of these reactors, the 

stockholders who will profit from their construction, and many other amoral participants who will 

benefit from this insane project, are full of optimism about how safe it is, how environmental, 

Appendix E October 2016 E-485 NUREG–2176
how necessary. Except that it is none of those things. It is a time bomb being placed in our 

State, our neighborhood, where the residents are being forced to give up their peace of mind, 

future safety and property values to satisfy the greed of FP&L and all those who support this 

highly dangerous endeavor. There were other locations that assumed there was no problem like 

this. Three Mile Island, Chernobyl, Fukushima. But unlike Chernobyl we're not a remote 

community that can be isolated in the event of a disaster. We are a major American city and 

placing us in even the most unlikely danger is a terrible, terrible idea. (0721-26-7 [Koenigsberg, 

Linda])

Comment: Please say no to the two new nuclear plants at Turkey Point. (0721-28-12 [Wilansky, 

Laura Sue])

Comment: There is just no way that I think anybody can justify expanding nuclear energy in 

South Florida. (0721-29-3 [Yovel, Ephrat])

Comment: First of all I just want to say that the Sierra Club opposes the expansion of FP&L 

Turkey Point at 6 and 7. (0721-30-1 [Ullman, John])

Comment: This plant is in the wrong place. Just because we had the plant, this plant was -- the 

first two plants, nuclear reactors were built starting in 1967, that doesn't mean we should 

continue to build two new reactors there today. (0721-30-5 [Ullman, John])

Comment: I think in the -- when I was an attorney in the legal world we call what FP&L's 

proposing, or what the ratepayers are screwed under a statute under, as an illusory promise. 

What does that mean? It is a promise that doesn't have to be kept. It's like, oh yeah, oh, I can 

do that. But there's no obligation for them to do that. So, yeah, sure, they can make all the 

promises they want but they're not bound by it. So you can give them the money now, they 

charge -- can jack up their rates. And then, oh, midway through a project, no, we don't need to 

finish it but we'll keep the money. So it just seems like a really bad idea, just, you know, out of 

common sense that we should never support such a bad idea. (0721-31-11 [Almirola, Alejandro])

Comment: I ask that the NRC reject this application. (0721-32-10 [Schlackman, Mara])

Comment: Now, you can see right here how many seat do they have. Florida Power and Light 

he mention problematic. One of you mention problematic. It's everybody. They no put it in the 

news. Why they not put it in the news? This room ain't going to be full. So he wants on the 

people only they can be in favor of the plan. I'm against it. (0721-33-1 [Herrera, Luis])

Comment: And I think everybody they got to be against this. (0721-33-3 [Herrera, Luis])

Comment: But to just say that -- I see this and from a quality management perspective there's 

too many flaws in this. And this is from me being involved for 25 years in manufacturing, and 

being a supplier to you. I'm telling you right now, this is not the best course of action. There are 

other ways to make money. (0721-34-3 [Gomez, Albert])

Comment: I'm the Vice-Mayor of South Miami, and I assure you, everybody in that City is 

against the additional nuclear reactors. And I would say everybody throughout most of Dade 

County who is aware of this, is against it. (0721-6-5 [Harris, Walter])

Comment: I hope the Commission does not build this. (0721-7-8 [Edmond, Gabriel])

Appendix E NUREG–2176 E-486 October 2016
Comment: I'm here to express our serious concerns regarding this project. FP&L has proposed 

installing two new nuclear reactors at Turkey Point. If expanded, Turkey Point will become one 

of the largest nuclear generating facilities in the country. (0721-9-1 [McLaughlin, Caroline])

Comment: I'm representing a large number of students at UM who oppose the expansion of 

the Turkey Point Power Plant for a couple of reasons. There are many potential risks to public 

health associated with this project as well as stress to the environment. (0722-14-1 [Kaul, Devika])

Comment: I just wanted to say we do not support the expansion of Turkey Point. (0722-14-6

[Kaul, Devika])

Comment: I want jobs, too, but I want to survive and I don't want to lose my heritage which I'm 

watching disappear. Even my own mother's house, I realize this is -- the trees, I didn't think I 

would ever have to become such a tree hugger but I'm seeing them all disappear. (0723-11-9

[Berendsohn, Catherine])

Comment: I'm here tonight on behalf of our nearly one million members and supporters 

nationwide including over 18,500 members here in Florida alone to express our serious 

concerns around this project. (0723-4-1 [McLaughlin, Caroline])

Comment: PROTECT OUR NATIONAL TREASURES...NO NUCLEAR EXPANSION! (0730-1

[Smith, Pamela])

Comment: This plan is absolutely unacceptable. (0733-1 [Colby, Helen])

Comment: Are you kidding? The proposed expansion of Turkey Point Power Plant is a disaster 

waiting to happen! (0734-1 [Johnston, Judy])

Comment: As a former resident of Miami where two of my children were born I am completely 

opposed to any further expansion of the Power Plant with future concerns for unborn children in 

the future. (0735-1 [Houghton, Francis])

Response: These comments express opposition to the licensing of new nuclear reactors at the 

Turkey Point site. The NRC carefully reviewed the application against its regulations that are 

intended to protect public health and safety and the environment. These comments do not 

provide specific information related to the environmental effects of the proposed action, and no 

changes were made to the EIS as a result of these comments. 

Comment: We live in Miami and are opposed to this. This is an opportunity for us to invest in 

energy that isn't going to be more harmful to the environment as well as the residents in Miami. 

Please think about the long term impact. (0003-1 [Ortiz, Natalia])

Comment: Please, as a parent, as a Miami resident, I beg you to do what's right and vote 

against this. Put yourself in our shoes, would you want this project in your backyard? We want 

to teach our kids about saving our planet and be green, but as adults we continue to make 

decisions that go against what we teach. (0003-3 [Ortiz, Natalia])

Comment: This project is unsafe for the environment and it is unsafe for the citizens who will 

be impacted by it! (0007-3 [Johnson, Nadine])

Comment: We have sufficient risk and power. We do not need any additional of any. 

Especially RISK. (0019-1 [Bejarano, Antonio])

Appendix E October 2016 E-487 NUREG–2176
Comment: Please, either reject this project or require FPL to propose a better proposal to 

safeguard our health and quality of live. (0024-3 [Roque, Julio])

Comment: I urge both the Commission and the State of Florida to prevent the expansion of the 

Turkey Point nuclear plant in Homestead, FL and invest in renewable energy instead. (0033-1

[Van Thienen, Mateo])

Comment: With all due respect to all involved in the decision making for the Turkey Point 

Nuclear Expansion, why do you have to put two more reactors in such close proximity to 

neighborhoods, schools, hospitals etc? (0040-1 [Pareto, Rolando and Marlene])

Comment: I understand that FPL and Turkey Point wants to build an additional (2) nuclear 

reactors at the site.......I live about 5 miles from Turkey Point and I am totally against the 

proposed plan.......First of all, you will be subjecting us to possible inherent risks in building 

these 2 nuclear reactors.......We live in an environmentally sensitive location where one mistake 

could be catastrophic to South Florida.......and to everyone that lives anywhere near this plant. 

I, for one, do not want these nuclear reactors built, we have seen other catastrophe's that have 

happened around the world when something goes wrong at these reactor sites.......It would 

change So. Florida forever. Quite sure you can find some other alternative plan to harness 

electricity....... (0042-1 [Tambussi-Brechon, Linda])

Comment: I am opposed to the building of any more nuclear reactors at Turkey Point, in 

South Florida, and elsewhere within the State of Florida. As I am sure you are aware history has 

shown that the potential exists for unplanned "incidents" to occur at or within nuclear power 

plants. The most recent of these, of course, was Fukushima. The best of intentions can go 

wrong and do go wrong. As we have seen, the results of such an unplanned "incident" can be 

catastrophic and long lasting. We are still experiencing "fall out" from Fukushima; in the Pacific 

Ocean, in sea life, in the lives of the people of Japan and the wasteland surrounding 

Fukushima. They are still having difficulty containing the radiated material from the reactor 

"incident." Given the proximity of Turkey Point to the major population centers of South Florida, 

its close location to the unique and environmentally sensitive Everglades and its coastal location 

potentially exposing it to the effects of rising sea levels, the Turkey Point Nuclear Power Plant 

exposes the population and natural environment of South Florida to unintended, but 

nevertheless, extraordinary risk. One serious nuclear power plant "incident" and South Florida 

would be forever changed. Large numbers of citizens, as well as animal and sea life, could be 

sickened by such an "incident". The fact that the Power Plant is located right on the coastline, 

would also impact the Atlantic Ocean not just in South Florida but, via the jet stream, the 

coastline of the eastern United States and coastlines of our European neighbors. It is my 

understanding that the new nuclear reactors would be providing power for northern Florida as 

well as the lower south eastern States. At what expense to humankind? (0043-1 [Grill, Helen])

Comment: I urge the NRC, and FP&L, to abandon this ill-conceived plan to expand nuclear 

power generation at Turkey Point. (0044-9 [Commenters, Multiple])

Comment: I had been notified about those dangerous 2 plants that FPL is planning in building 

in Turkey point FL. I urge not to approve this plan because it is a threat to the public and the all 

living creatures around. (0047-1 [Bazzi, Noell])

Comment: Given the advent of viable, lower cost, and benign alternative power generating 

technologies such as wind and solar, the risks associated with the expansion of Nuclear Power 

Appendix E NUREG–2176 E-488 October 2016
in South Florida far outweigh any possible benefits that may be derived. (0049-3 [Kowalski, 

Kathleen S.])

Comment: I am very much against the expansion of 2 additional nuclear power plants as part 

of the Turkey Point FPL power system. I am also against the 80 ft tall power poles planned for 

going along US1 in Miami-Dade County. The risks to the area by having such additional power 

plants from rising sea levels and the probability of a risk from more power plants are 

unacceptable. The Greater Miami area is one of the few economic power houses in this part of 

Florida and it would come to a complete standstill if there were a mishap. (0050-1 [Simon, Gary 

P.])

Comment: Simply stated, approve this plan at our peril on the basis of one corporations greed, 

or follow science, reason, and your duty as a public servant, and deny any expansion of Turkey 

Point. Please do not let a handful of billionaires give my family radiation poisoning, so that they 

can make a little more money. (0051-4 [Smith, David W.])

Comment: This letter is to inform you of my opposition to the construction of the two proposed 

Nuclear Power Reactors - 6 & 7- at Florida Power and Light's Turkey Point facility. I will not 

bore you with tales about the dangers of nuclear accidents. Those are already well known.

(0053-1 [Sasiadek, Alfred])

Comment: Well please protect my family, friends and neighbors Please employ some decency, 

dignity and integrity (that's where you do the right thing when nobody is looking) It matters a 

great deal. Let this plan be set in motion and it will reduce the entire population of South Florida 

to just something else they'll give odds on in Las Vegas. below is the standard protest letter but 

I wanted you to know I love my home and I hope you read this and plays to you as sincere,

(0056-4 [McCall, Eric])

Comment: I urge the NRC, and FP&L, to abandon this ill-conceived plan to expand nuclear 

power generation at Turkey Point. I sincerely agree with this estimation of probability, (0056-5

[McCall, Eric])

Comment: The question of whether nuclear power is good or bad is not the main issue here. 

Rather, the issue is whether this project in this particular location should be allowed to go 

forward. South Florida Wildlands thinks it should not, and so do I! I will not support this 

endeavor. (0059-1 [Holland, Karen])

Comment: Numerous respectable South Floridians have provided valid and scientific back -up 

to confirm that these nuclear plants should not be build down here. (0060-2 [Beckman, Yvonne and 

Douglas])

Comment: This letter is to express my negative to the construction of a nuclear central in 

Turkey Point. We have the right and the duty of take care of our lives and our security. I say 

NOT to this project because is dangerous. (0064-1 [Fernandez, Maria Cristina])

Comment: I simply am not willing to take the necessary personal and financial risk to further 

FP&L's business objectives. I hereby request that you deny and the construction and operating 

license for the proposed facilites at Turkey Point. (0067-4 [Commenters, Multiple])

Comment: I am not. This is a pure and simple business decision. NUCLEAR POWER IS 

BAD BUSINESS. BAD FOR ME, BAD FOR YOU BAD FOR EVERYONE IN SOUTH 

Appendix E October 2016 E-489 NUREG–2176
FLORIDA PLEASE SEND A LETTER TO THE NRC BEFORE MAY 22, expressing your 

opposition to the nuclear expansion of Turkey Point. (0071-2 [Stanley, Gael])

Comment: I am very much against any plans for adding 2 nuclear towers to the Turkey Pt. 

Power Plant. I am a resident of the Ocean Reef Club in Key Largo, FL. We understand the 

impact that this could and probably will have not only on our waters but also the protected 

wildlife plus hundreds of species of birds that migrate through this area.... To add insult to injury 

- this is energy being sold to Georgia!! This is our precious environment that we must take care 

of for the sake of all of our children and their children...It is my hope and prayer that this project 

is dropped. (0074-1 [Streit, Didi])

Comment: Now FPL want to build two more nuclear plants at Turkey Point. The plants that 

already exist, and the new ones proposed, as well as ALL that nuclear waste at Turkey Point, 

WILL be underwater in the foreseeable future. To me, that one fact is sufficient reason not to 

build these new plants. Game over! But if that's not reason enough for you, there are plenty of 

other compelling reasons. (0078-4 [Wilansky, Laura Sue])

Comment: It [FPL's expansion] would spend billions of dollars that could be better spent on 

power conservation and alternative energy projects. Its design does not take into consideration 

the reality of climate change; in fact it puts Florida's power grid at risk. This expansion plan is 

poorly conceived, inadequately designed, and environmentally harmful. As a resident of MiamiDade County, Florida, I urge you NOT to approve two new nuclear reactors at Turkey Point.

(0079-2 [Cathey, Turner])

Comment: This is a political and financial dark and ugly play. Take an afternoon and ask your 

six year old child, grandchild, or neighbor what is important. All we really need to know we 

learned in kindergarden. LISTEN, LEARN and LOVE. (0089-3 [Hubler, Gina Marie])

Comment: It is with grave concern that i write to you in reference to Florida Power and Light 

request for approval into adding 2 new Nuclear Reactors to their plant in Turkey Point Florida. I 

have read the plan in detail and i am dumbfounded to see that they are still moving forward with 

a plan that Floridians and Miamians do not want. Their plan fails to guarantee any type of safety 

to our citizens. It's not cost effective for us and it poses a mayor catastrophic risk in the event a 

big hurricane hits us or with the rise in sea levels. I can go on stating many other reasons, but I 

will refrain due to the lack of time you have. I want this letter to be clear and strong statement 

that I strongly oppose the expansion of Turkey Point with this new reactors. (0092-1 [Merino, 

Miriam])

Comment: I am writing in opposition to the proposed expansion of Turkey Point Power Plant in 

Homestead, Florida. I know that nuclear plants aren't always that dangerous, but national parks 

are created to protect species. Doesn't that counterproductive? (0105-1 [Tucker, Lauren])

Comment: I hope the you & your colleagues are un-biased & have enough integrity & complete 

enough with your science to come to the stronger conclusions against FPL wanting 6 & 7 

Nuclear Reactors, because you have also factored in, along with Global Warming flooding 

where Turkey Point resulting in even greater damage to people's health & tourism, that: When 

FPL (& the nuclear power industry) claims they are either 'Green' or Carbon Free or Low 

Carbon Foot Print they are lying, (0120-1 [Shark, Jason])

Comment: As a lifelong resident of S. Florida (I was born in Miami in 1961 and have lived here 

ever since) I am asking that we NOT build any more nuclear power plants in South Florida. The 

Appendix E NUREG–2176 E-490 October 2016
risks are just too great. Our potential for solar energy has hardly been tapped. Please heed the 

warning of Fukushima, and don't build any more nuclear power plants on coastal sites, so 

vulnerable to hurricanes, rising sea levels, and more. Thanks for your consideration. (0142-1

[Dronsky, Rick])

Comment: NO NUKE EXPANSION. (0144-1 [Warzalla, Jim])

Comment: The risks are entirely too great for this to take place. Please reconsider. (0147-3

[Jones, Joan and Robert])

Comment: The Miami-Dade County area is highly populated and functioning nuclear reactors 

within the county would represent a constant threat to the lives of the residents. (0148-3 [Brinn, 

Ira])

Comment: Nuclear might have its place--but not in Southern Florida. (0150-4 [Otis, Martha])

Comment: Please vote NO on any expansion. Have you not heard of Fukushima? (0158-3

[Carlson, John])

Comment: Will our children, grandchildren and other future generations some day ask us, 

"Why did you do it? Were we not worth saving our environment?" (0159-7 [Bazzone, Barbara])

Comment: I am shocked to learn of this project that is clearly out of the question. It is totally 

unacceptable in this fragile coastal area with incredible biodiversity of plants, fish, birds, and 

animals. It is frightening to think of all the destruction, and damage you will cause if you are 

allowed to go through with this project. You are putting humans, wildlife and an irreplaceable 

landscape and habitat at risk. How dare you even consider such a project that puts us all, not 

just humans, but all of God's Creations in danger. What you are doing will have far reaching 

consequences that must not happen. None of us wants to see Florida having to deal with an 

experience the horrors Japan endured, and that is exactly what you are bringing upon all of us, 

and I do not think you have the right to sacrifice us for your greed. We do not need or want your 

Nuclear Reactors, that have the potential to take away the Future Generations and cause pain 

and suffering, and destroy our Waters. I could go on, and on, speaking about the water you will 

use for your cooling systems, nuclear waste, spent fuels rods, and all the other science based 

problems, but I know many have already done this, to obviously blind and deaf individuals who 

are suppose to care about our well-being and safety. Florida will hold all of you responsible for 

even the slightest accident! Do not destroy us. Do not do this project. The risks are tod great.

(0160-1 [Larsen, Shannon])

Comment: No more nuclear in Florida PLEASE enough already (0161-1 [Anonymous, Lynn])

Comment: The recent fire and explosion at the Indian Point Nuclear reactor outside New York 

City on the Hudson River is a further example of the potential danger of such plants. The Turkey 

Point nuclear expansion is "an accident waiting to happen." The NRC should use it's powers to 

prevent such accidents from happening. (0184-3 [Perez, Danica])

Comment: Please think twice before destroying innocent lives. (0188-2 [Frederickson, Kelly])

Comment: The proposed expansion of the Turkey Point Nuclear Power Plant has the potential 

to destroy, in an instant, everything I have spent my life working for. With this fact in mind I 

would like to object to the plan to expand the Nuclear Power Generators at Turkey Point. (0206-1

[White, Holly])

Appendix E October 2016 E-491 NUREG–2176
Comment: I am extremely concerned about the proposal to add more nuclear reactors to the 

FP&L Turkey Point Site. I consider this option to be extremely irresponsible to the people who 

live in South Florida and to the rest of the planet for that matter. (0207-1 [Cleland, Noel])

Comment: How the expansion of this Nuclear Power Plant can be under consideration is 

inconceivable! Have we not learned enough from recent history that shows the danger and 

potential for catastrophic loss of life and damage to the ecosystem! The time to shut down any 

plans for more nuclear power generation is now! (0225-1 [Lawson, Ken])

Comment: Please think about the future of your and our families and every living creature. We 

don't need another threat around us. We all deserve to live in peace and to be safe. (0238-1

[Padilla, Dora])

Comment: Please invest your dollars in safe energy, public and environmentally responsible 

energy resources, not two new nuclear power plants. Why are you putting us at risk. I'd rather 

light a candle. (0241-1 [Portuondo, Pilar])

Comment: In the final analysis: Expanding the Turkey Point Nukes serves only FPL's 

corporate shareholders. It exposes the surrounding communities to a mind-numbing level of 

risk. We are literally paying the price to endanger our whole future. Please don't approve 

expansion. (0252-20 [Van Leer, Sam])

Comment: I hope you have the courage to do the right thing for the people and our planet.

(0257-3 [Padron-Delgado, Blanca])

Comment: I do not support nuclear power, and I certainly do not support expanding a facility! 

Why don't you all move to Fukushima and call it quits... (0271-1 [Thomas, Gina])

Comment: Haven't you learned enough of a lesson seeing the tragedies that have taken place 

in the world with nuclear power plants? Please deny this project. (0287-2 [Beiriger, Mary])

Comment: I grew up near the Turkey Point Nuclear power plant and could see it on the horizon 

from my neighborhood. I lived in fear of a disaster every time a hurricane approached South 

Florida. Please do not expand this facility--we should be creating renewable power facilities in 

this country-not nuclear facilities. (0316-1 [Parker, Richard])

Comment: Many countries are closing down their Nuclear Power plants, one by one. It is 

inexcusable for you to consider expanding operations at Turkey Point. (0331-1 [Anonymous, 

Anonymous])

Comment: There were other locations that assumed there was no problem with projects like 

this: Three Mile Island, Chernobyl, and Fukushima. But unlike Chernobyl, we are not a remote 

community that can be isolated in the event of a disaster. We are a major American city, and 

placing us in even the most unlikely danger is a terrible, terrible idea. (0339-5 [Provost, Allan])

Comment: For all the above identified concerns, I absolutely oppose more nuclear reactors to 

be built in our back yards. (0340-6 [Tweeton, Tanya])

Comment: As a citizen and current resident of South Florida, I am totally opposed to any 

expansion of nuclear plants, particularly at Turkey Point. (0353-7 [Royce, M.])

Appendix E NUREG–2176 E-492 October 2016
Comment: Please do NOT allow further nuclear development in South Florida! It is unsafe 

(remember Fukishima!) and unnecessary. (0357-1 [Shapiro, Eugene])

Comment: Locating a Nuclear Power Generating Facility in close proximity to a densely 

populated metropolitan area of more than 2,500,000 people, is an ill conceived notion at best. 

Although this decision may be a means to enrich the shareholders of FP&L, it places the entire 

population of South Florida in extreme jeopardy. (0358-4 [Norman, Ronald])

Comment: Florida Power and Light Company is applying to obtain site certifications and 

operating licenses to construct and operate two nuclear reactors of 1,117-MWe each at its 

Turkey Point nuclear power generating facility on Biscayne Bay. Although nuclear power 

produces less CO2 than fossil alternatives, nuclear power is not affordable, or clean with 

currently available technology, and there are safety concerns with the new plants being on the 

coast, and within 10 miles of large population centers. (0364-1 [Mahoney, Robert S.])

Comment: Let's make it easy for you: No Water, Sea Level Rise, Stupid Idea, Old Technology, 

Too Much Salinity, Too many people. JAPAN. (0373-15 [Lee, Nancy])

Comment: Approval should NOT be granted for this project, an expansion of the Turkey Point 

reactor. the public should be encouraged ... even compelled ... to reduce its overuse of power, 

especially via nuclear power plants. Stop FPL from further filling its coffers with public money to 

produce these unwanted plants. (0374-1 [Livingston, Catherine])

Comment: Do not do evil. Do not do 'dumb'. Our nation is more valuable than to make such an 

out-of-date decision. (0439-1 [Hansen, Yvonne])

Comment: I urge you to deny the proposed expansion at Turkey Point and protect the area's 

people, natural resources, environment and national treasures from this inappropriate plan and 

dangerous, incredibly expensive and outmoded type of energy system. (0463-6 [Gross, Cheryl A.])

Comment: The expansion of Turkey Point could have serious environmental impacts on 

sensitive ecological habitat and the health and sustainability of limited freshwater resources. 

Just think of what happened this past week at Indian Point. Did New York City narrowly escape 

nuclear disaster? (0492-1 [Mckee, Sarah])

Comment: Florida has so much sunshine! Do we really need to continue to expand nuclear 

power plants? Please veto the proposed expansion of Turkey Point Power Plant in Homestead, 

Florida. (0495-1 [Mazzarella, Rebecca])

Comment: I am writing to publicly comment on the plans for new nuclear reactors in Turkey 

Point. My family and I live in Miami, and we have several properties in the area. I am also an 

Environmental Scientist. After reading about the plans, I am completely against any new nuclear 

power in south Florida and hope the NRC will prevent FPL from going through with their plans. 

(0499-1 [Pinto, Theresa])

Comment: Please do not expand the nuclear power facilities here in south Florida. Currently 

the nuclear reactors are located in an environmentally sensitive area directly adjacent to an 

amazing National Park. They are just above sea level, use more water that is available and 

there is a huge issue with cooling ponds as it stands today. There is amble opportunities to 

create power from the sun here in Florida and it is a huge short sighted mistake to try to 

continue with nuclear at the present location. (0507-1 [Bryan, David])

Appendix E October 2016 E-493 NUREG–2176
Comment: Unlike some, I am not opposed to nuclear power--precisely because I care so much 

about the threats posed by global warming and ocean acidification. But it is an energy source 

that must be handled with the greatest of care, and the proposed expansion of Turkey Point 

illustrates how NOT to do it. Hasn't anybody learned from the horrible example of Fukushima? 

(0534-1 [Suda, Maryska])

Comment: We are in a hurricane prone location which can easily damage a nuclear reactor 

and in an area which will most likely see rising sea levels in the not too distant future. After what 

happened at Fukushima, I can't believe that we are considering adding nuclear power plants at 

this location. (0537-4 [Anonymous, Judi])

Comment: NO to two new proposed nuclear power plants on Biscayne Bay. We barely 

survived Turkey Point taking a direct hit from Hurricane Andrew. (0542-1 [Odierna, Cynthia])

Comment: NO, NO, NO .. stop expanding.!!! Dismantle and find alternatives for energy. I'll do 

my part, I'll use less lights, less air cond. Less everything that requires FPL energy.PLEASE 

stop. (0556-1 [Shelley, Cynthia])

Comment: Put the plant somewhere safer or use a renewable source of energy. We are killing 

ourselves with this. (0578-1 [Ramankutty, Vishnu])

Comment: The NRC's slogan points out that the sole purpose of the Nuclear Regulatory 

Commission is "protecting people and the environment." Licensing of the AP1000 design at 

Turkey Point would represent a catastrophic failing on the agency's part on both counts. It would 

shatter what little public confidence in the agency might exist and, should an accident ensue, 

would mean the end of nuclear power in the United States forever. As the agency charged with 

protecting the people of this community, you must reject these unsafe reactors as if you and 

your loved ones lived nearby, for I and 5 million other people do just that. (0615-3-11 [Bethune, 

David])

Comment: No more poison machines! (0624-1 [Galles, Camilla])

Comment: As a South Dade resident, I am alarmed at the prospect of having a nuclear plant 

near such a densely populated area in a hurricane zone. (0626-1 [Miller, Nyana])

Comment: The safety of my family and my community is not worth sacrificing at the alter of a 

quick fix. I urge you to deny this proposal and seek safer forms of energy. (0626-4 [Miller, Nyana])

Comment: The truth is we do not want this close to our homes or in our environment period! 

It's toxic and deadly to life! We want to live healthy while we are here on this beautiful planet. 

Please honor life and the planet give back with sustainable non toxic solutions to the 

environment and all living beings. (0638-4 [Anonymous, Charity])

Comment: Please deny the license application. I am a full-time resident of Florida and I am 

opposed to any additional nuclear reactors in Florida. (0654-1 [Guy, Sharon])

Comment: I guess you forgot that this is FLORIDA! Nuclear plants and hurricanes DO NOT 

MIX. No matter what they tell you about how safe they are, they are NOT. VOTE NO! (0658-1

[Willett, Bett])

Comment: No absolute NO. We don't need 2 more Nuclear Plants on Byscaine Bay. It will be a 

danger to South Florida. (0660-1 [Sanchez, Sergio and Irma])

Appendix E NUREG–2176 E-494 October 2016
Comment: ALL OF THE CURRENT NUCLEAR REACTORS ARE LEAKING AND 

CONTAMINATING THE SURROUNDING SOILS AND WATER: WHY WOULD ANY 

REASONABLE PERSON CONSIDER ADDING TO THESE ENVIRONMENTAL AND HEALTH 

DISASTERS? (0669-1 [Malyon, Hilary])

Comment: Florida Power & Light argues that its new nuclear project is environmentally 

friendly, that it will benefit us economically, and that its future plans at Turkey Point are safe. 

Unfortunately, none of these claims are accurate. FPLs project would reduce the availability of 

fresh water for our communities, it would commit South Florida to antiquated and expensive 

nuclear technology from the last century, and it would render our electric system vulnerable to 

storm surges from rising seas. (0675-1 [Rodriguez, Jose Javier])

Comment: I am extremely concerned about the proposal to add more nuclear reactors to the 

FP&L Turkey Point Site. There are much less risky solutions for meeting the energy needs of 

the area. (0677-1 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: I am extremely concerned about the proposal to add more nuclear reactors to the 

FP&L Turkey Point Site. My main personal concerns are: (1) need to focus on sustainable 

energy sources such as solar and (2) insufficient evacuation zones and other security issues.

(0678-1 [Klopfer, Carol])

Comment: I am totally opposed to any nuclear plant constructed anywhere in our beautiful 

state of Florida. (0709-3 [Cummings, Frank])

Comment: New Reactors at Turkey Point should be turned down for a variety of reasons. The 

current reactors have had many functional and operational issues in the last few years with little 

public oversight or accountability. (0710-1 [Platt, George Seth])

Comment: I am opposed to building a new reactor at Turkey Point since it will require a vast 

amount of water which is a very valuable resources. It will also be very expensive to construct 

and could be dangerous in the case of a hurricane. (0713-1 [Heiney, Jamie])

Comment: Do not allow the building of 2 additional units to the Turkey Point Nuclear Plant. 

They represent a threat to the lives of a massive number of residents of this country. It is a 

threat to that we can live without. If you allow this; there will be an extremely high political price 

to pay for all those involved in the decision. (0717-1 [Nieto, Victor])

Comment: And until those issues are fixed and corporate responsibility is maintained and it's 

cleaned up, then two more nuclear reactors cannot be on the table. It's wrong for Florida.

(0721-10-5 [Reynolds, Laura])

Comment: I do want to say that not only are we living in one of the global bio-diversity --the 

most important bio-diversity areas in the world, this is also an incredibly urban area. And 

building one of the largest nuclear facilities in an area where FPL has not proven to be a good 

manager of their existing facilities is reckless and dangerous. (0721-29-1 [Yovel, Ephrat])

Comment: I echo the sentiments of everyone who's against this proposed nuclear bomb or 

factory or plant. It's just a bad idea waiting to happen. I mean it's just another -- Turkey Point's 

going to be a new Fukushima or any other disaster you want to put in the blank, and it's a bad 

idea waiting to happen. (0721-31-1 [Almirola, Alejandro])

Appendix E October 2016 E-495 NUREG–2176
Comment: I think that would be you know, make more sense than putting another, you know, 

nuclear reactor, creating two nuclear bombs and having a Homer Simpson-like character 

blowing it up, you know, because of negligence or any other foreseeable disaster. I just think 

that it's a bad idea. (0721-31-13 [Almirola, Alejandro])

Comment: Sierra Club opposes licensing, construction and operation of new nuclear power 

reactors utilizing the fission process... (0723-5-1 [Teas, Jim])

Response: These comments provide general information in opposition to the proposed Turkey 

Point Units 6 and 7 based on opposition to nuclear power. They do not provide any specific 

information related to the environmental effects of the proposed action. No changes were made 

to the EIS as a result of these comments. 

Comment: The location of Turkey Point Nuclear Plant is too sensitive to expand it. (0004-1

[Engelberg, Jodi])

Comment: When Turkey Point was originally developed in the early 1970s, the conditions that 

existed then are NOT the same as they are today. Those original conditions have changed 

dramatically in the ensuing years, making Turkey Point a totally unsuitable location for 

continued operation, much less expansion. Locating a new facility in close proximity to a 

densely populated metropolitan area, contiguous to natural resources, within a historically 

proven High Velocity (Wind)-Hurricane Zone, and defenseless against terrorism threats by not 

only water but air, seems at best to be an ill-conceived plan. (0045-3 [Johannsen, Christian])

Comment: As Florida residents, we are very concerned about the ecological and social 

damage from the proposed expansion at TurkeyPoint. We are opposed to this expansion and 

ask the commission to look for alternatives. (0068-1 [Prugue, Jorge and Paloma])

Comment: [W]hat has been proposed for the expansion of the existing Turkey Point Facility is 

an egregious mistake. Card Sound is a small and shallow body of water in a warm environment. 

An expansion of the existing plant, which is already taxing our fragile environment would be 

devastating in the long term. The only advantage would be to the shareholders and 

management by selling electricity to other parts of North America for profit at the expense of our 

local environment. If this expansion is approved I will sell all my FLP shares and encourage all 

those intuitions who hold shares to do the same. Please reconsider. (0075-2 [Streit, Christopher 

V.])

Comment: I am writing today because you are about to make judgement on a request in my 

area that will potentially have terrible irreparable ecological consequences if it goes forward. As 

you know, FPL is attempting to gain approval on a major expansion to the Turkey Point nuclear 

plant in South Dade Florida. While I am not an opponent of nuclear energy, I believe it is your 

responsibility to protect our National Parks when a selection process is initiated. (0081-1 [Benson, 

Mary] [Skove, Ellen H.] [Tompkins, Constance])

Comment: I feel that extensive study should be performed before any approval of this project 

be granted in order to guarantee that our National Parks and surrounding habitats will not be 

harmed. I have seen no evidence that any such studies have been performed. All I see is the 

plan to clear thousands of acres of natural bay front habitat bordering our National Park and the 

creation of a facility that will fit the business plan and line the pockets of a major corporation.

(0081-6 [Benson, Mary] [Skove, Ellen H.] [Tompkins, Constance])

Appendix E NUREG–2176 E-496 October 2016
Comment: Based on what I've read and heard about the environmental impact of the proposed 

new reactors (and the impact of the existing reactors), I am 100% opposed to the project. Given 

the sensitivity of our coastal waters, including the only living coral reef in the US, I am shocked 

that we are considering the addition to the environmental burden. Of course, beyond the daily 

addition of heated waters and waste, the potential disaster related to weather or other 

operational failure looms large. We might think we've engineered the plant properly, but as 

Fukishima showed us, Mother Nature has a way of overwhelming man made systems. As a 

resident of Key Largo, I am hopeful that you will reconsider the proposed expansion and begin 

thinking about decommissioning the plant as it's useful life reaches its limits. (0082-1 [Jones, 

Michael E.])

Comment: We support necessary nuclear energy but certainly not expanding the initial error of 

placing such a facility in a location exposed to violent storms and surrounded by irreplaceable, 

fragile National Parks. (0083-1 [Birsh, Arthur and Joan])

Comment: Please listen to the people who live here in Miami, Florida. We want a healthier 

environment for our kids and families. (0088-8 [Lange, Alexandra])

Comment: This article was published in the Miami Herald today, reflecting our elected officials 

perspective on the nuclear facility being considered. It seems that we are in a time of our 

planet's future which every decision which is being made for infrastructure and environmental 

use needs to be monitored and proceeded with an open heart, and mind. This would require 

ALL to consider the ramifications which we are flirting with in a very serious light. I would 

implore you and those with whom you work with to look at the situation we are in, not from 

merely a financial standpoint but also a ecological and humanitarian. (0089-1 [Hubler, Gina Marie])

Comment: I have no doubt that you will consider FPL's application carefully and can only hope 

that you come to the same conclusion as myself and countless others who feel that the building 

of two new reactors would be folly and ultimately harmful to all living things here in South 

Florida. The damage done to our water supply, our parks and most importantly, the Everglades 

is immeasurable. Please cast your vote to decline this application. (0090-1 [Avers, Pamela Dee])

Comment: Increasing the size of the power plant does not make sense as it already impacts 

the habitat of the area. (0096-2 [Roberts, Linda])

Comment: I find today's Miami Herald Op-Ed by Mayor Tomas Regalado, Mayor Cindy Lerner 

and Mayor Philip Stoddard along with State Representative Jose Javier Rodriguez to be most 

informative about plans for expansion of a Florida energy source. This news is disturbing on 

many levels. I feel the information that it will reduce safe drinking water and disruptive the 

tender ecology of the area to be a huge negative for placing nuclear reactors in Miami-Dade 

County. "FPL's project would reduce the availability of fresh water for our communities, it would 

commit South Florida to antiquated and expensive nuclear technology from last century, and it 

would render our electric system vulnerable to storm surges from rising seas. FPL ignores these 

difficult facts." (0098-1 [Gavel, Deborah])

Comment: Please consider the harm done to the environment and the shared habitat to sea 

life and land animals, to the birds as well as the human life forms on this planet. FPL's nuclearpower plan regressive, harmful[.] (0098-3 [Gavel, Deborah])

Comment: I am a long time proponent of nuclear power and I have never considered myself to 

be particularly an environmentalist, but I strongly urge the denial of FPL's expansion of the 

Appendix E October 2016 E-497 NUREG–2176
Turkey Point facility. Having spent time trying to understand the pros and cons of the planned 

expansion, it seems clear to me that the extensive environmental damage significantly 

outweighs the gains from the expansion. I have come to this conclusion in spite of being an 

investor in public utilities and generally having a bias toward FPL. (0099-1 [Hudson, Harold J.])

Comment: I strongly oppose the expansion of Turkey Point as proposed due to the project's 

potentially widespread negative environmental and public health and safety impacts and the 

serious threats it poses to Biscayne National Park. (0102-8 [Commenters, Multiple])

Comment: I have serious concerns that the proposed expansion of FPL's Turkey Point could 

significantly impact and degrade the health of our national parks, sensitive ecological areas 

including extensive wetlands, federally listed threatened and endangered wildlife, and the 

quality and quantity of limited fresh water resources. (0104-1 [Commenters, Multiple])

Comment: Our comments demonstrate that there are more affordable, less water-intensive 

ways for FPL to meet energy demand while protecting the environment and addressing global 

climate change. As such, there is no purpose and need for the two reactors. If pursued by FPL, 

the expansion of Turkey Point could have profound and unacceptable environmental impacts to 

regional water resources, Biscayne and Everglades National Parks, wildlife, wetlands and 

threaten public health and safety. SACE believes that the DEIS fails to adequately discuss and 

analyze these potentially adverse impacts and includes insufficient proposals for mitigation. We 

do not support the issuance of COLs for Turkey Point reactor Units 6 and 7. Instead, we 

recommend that the NRC and USACE support the "No Action" alternative. (0112-10 [Barczak, 

Sara])

Comment: According to the standards of the Nuclear Regulatory Commission (NRC), "sites 

adjacent to lands devoted to public use may be considered unsuitable," and unacceptable 

impacts are "most apt to arise in areas adjacent to natural-resource-oriented areas." [Footnote 

8: United States Nuclear Regulatory Commission, Regulatory Guide 4.7-General Site Suitability 

Criteria for Nuclear Power Stations, Revision 2, 1998, Section C.] In following the NRC's own 

standards, we advise against moving forward with the project as proposed due to the potential 

for unacceptable impacts on the ecological integrity and economic viability of the surrounding 

national parks. (0113-1-14 [Lopez, Jaclyn] [McLaughlin, Caroline] [Reynolds, Laura] [Schwartz, 

Matthew] [Silverstein, Rachel])

Comment: Please do not increase the drain on our limited water supply by allowing FPL to 

create two new reactors. (0115-3 [Trencher, Ruth])

Comment: I am alarmed by the nuclear expansion plans that FPL proposes for South Florida, 

especially considering our vulnerable water supply. (0116-1 [Garcia, Ruslan])

Comment: When Turkey Point was first built in 1972, Earth Day was 2 years old and Biscayne 

National Park didn't exist, and there was no wellfield protection ordinance, you can excuse the 

environmental degradation it caused because we didn't understand then what we do now. We 

know what fresh water releases do to Biscayne Bay. We know that sea level rise is happening. 

We know that there are nuclear accidents like, Three Mile Island, Chernobyl, and Fukushima 

Daiichi happen. To expand Turkey Point in an environmentally sensitive and flood prone area, 

claim more water from the Biscayne Aquifer, expand a industrial use at the edge of a national 

park, is just dumb. (0117-1 [Robertson, Alyce])

Appendix E NUREG–2176 E-498 October 2016
Comment: Regarding FPL's proposed nuclear energy plan, What is there to say other than we, 

as a state, are currently ignoring just about every warning we've received from every scientist in 

the world telling us that in a matter of years, we will run out of fresh drinking water. We will be 

flooded. We will die. This is not an over dramatization, it's simply true. And yet, the only thing 

worse than doing NOTHING about our current problems is doing something that makes them 

HORRIBLY WORSE. Teach us how to be better. Save our state. Don't allow corporations to 

place money over humanity. (0137-1 [Manuel, Becky Randel])

Comment: I have serious concerns that the proposed expansion of FPL's Turkey Point could 

significantly impact and degrade the health of our national parks, sensitive ecological areas 

including extensive wetlands, federally listed threatened and endangered wildlife, and the 

quality and quantity of limited fresh water resources. I request that both agencies support the 

"No Action" alternative in reference to Docket ID: NRC-2009-0337. (0141-1 [Lucas, Carmen])

Comment: Clearly, South Florida is highly vulnerable to sea level rise and the impacts of 

climate change. This site was never an acceptable location for the Turkey Point facility there 

today and many decades later it has only become an even more unacceptable location. (0141-3

[Lucas, Carmen])

Comment: If you drive away wild life and fry our way of living, there really is no need to expand 

production. Pay some attention to the Aztec civilization and in more modern times the "streets" 

of Venice. There is a time when life is more precious than the dollar. (0143-1 [Shepard, J.])

Comment: Please stop this project for the safety of the environment, wildlife, our 2 National 

Parks, the economy in South Florida, and do what is right. (0149-14 [Nelson, Joyce E.])

Comment: I am writing to express my grave concerns regarding the expansion of Turkey Point 

nuclear facility, and any such project bordering the delicate wetlands and fragile aquifers in 

Southern Florida. This expansion will negatively affect water quality, species survival, wildlife 

habitat health (including our coral reefs, arguably the reason for an entire state's tourist 

economy), human health and safety, and even state finances for decades and more in the 

future[.] (0150-1 [Otis, Martha])

Comment: Please consider these facts before locating the nuclear reactors in the Biscayne 

and Everglades National Parks. (0153-3 [Goldman, Emanuel])

Comment: I am a conerned citizen of Florida and am pleading with you to reconsider your 

plans for the proposed nuclear reactors for the shores of Biscayne Bay and Everglades National 

Parks. (0153-5 [Goldman, Emanuel])

Comment: Turkey Point should never have had a power plant in the first place. Do not further 

damage the environment and Florida's fresh waters by expanding it now! (0156-1 [Newman, 

Donna])

Comment: This asinine proposal is one driven by greed and if not ignorance, at least 

environmental apathy. Expanding this already marginal operation would only further 

compromise the area, it's waters both fresh and salt, it's creatures, air, health threats to all, on 

and on. For someone's profit. Inevitably, to the park's and sentient beings' detriment, it can only 

cause problems that are impossible to correct. (0163-1 [Cook, Cherie])

Appendix E October 2016 E-499 NUREG–2176
Comment: This statement, written by members of the National Parks Conservation 

Association, reflects my opinions and beliefs. NPCA speaks for me, and many others concerned 

with the future of our planet. (0165-1 [Cooper, Joe])

Comment: This park does not belong to the energy producers, it belongs to citizens of the 

United States. keep your killing of animals and plants with reactor water away from the places 

that are sanctuaries for them. (0166-1 [Freel, Susan])

Comment: Also, it's ludicrous to expand this power plant with such ecologically sensitive 

ecosystems nearby plus the huge drain on our water supply that would inevitably result from the 

expansion. (0178-4 [Almirola, Alejandro])

Comment: It is against any and all sense to place this plant in a dangerous and unstable area. 

(0182-1 [Polifroni, Josephine])

Comment: Please do not expand this already ill-conceived location to include any expansion.

(0183-1 [Piper, Cynthia])

Comment: Please protect freshwater and other natural treasures of Biscayne National Park 

which are threatened by nuclear expansion. (0186-1 [Macraith, Bonnie])

Comment: I have serious concerns that the proposed expansion of FPL's Turkey Point could 

significantly impact and degrade the health of our national parks, sensitive ecological areas 

including extensive wetlands, federally listed threatened and endangered wildlife, and the 

quality and quantity of limited fresh water resources. (0192-1 [Lebatard, David])

Comment: Our nation's significant environmental heritage sites should not be sacrificed to 

industrial planning. (0195-1 [Harden, Ronald])

Comment: On behalf of the undersigned environmental organization representing hundreds of 

thousands of citizens throughout the country, we submit these comments in opposition to the 

proposed Turkey Point Power Plant expansion. Our groups and members are deeply committed 

to protecting the environmental health of South Florida and our precious freshwater supply. We 

have serious concerns that the proposed expansion of Turkey Point could significantly impact 

the health of our national parks, sensitive ecological areas, federally listed threatened and 

endangered wildlife, and the quality and quantity of our water resources. (0210-1 [Sharp, Andrea 

Heuson])

Comment: In the interest of protecting the health and integrity of our valuable natural 

resources and limited water supplies we strongly recommend that you do not permit the 

proposed Turkey Point Power Plant expansion. (0210-7 [Sharp, Andrea Heuson])

Comment: As residents of Key Largo, we oppose the expansion of the Turkey Point nuclear 

plant. We are within 15 miles of the facility, but we oppose the expansion for other reasons. The 

existing cooling canals exceeded the 100 degree limit many times last summer. We do not feel 

that the plan to accommodate 2 additional reactors is adequate and environmental damage is 

inevitable. (0212-1 [Ross, Robert and Teresa])

Comment: For all these reasons, I urge you to deny the proposed expansion at Turkey Point 

and protect the region's people and unparalleled natural resources. (0218-2 [Barlow, Jeffrey])

Appendix E NUREG–2176 E-500 October 2016
Comment: I grew up in Miami Beach and remember how unspoiled Biscayne Bay was even 

then. It must remain that way--it's a paradise! (0224-1 [Rennie, Edwyna])

Comment: Although I am a supporter of developing nuclear energy in the United States, I 

strongly oppose the expansion of Turkey Point as proposed due to the project's potentially 

widespread negative environmental and public health and safety impacts and the serious 

threats it poses to Biscayne National Park. (0226-1 [Karlow, Edwin])

Comment: I strongly oppose the expansion of Turkey Point as proposed due to the project's 

potentially widespread negative environmental and public health and safety impacts and the 

serious threats it poses to Biscayne National Park. (0228-8 [Yeager, Jerry])

Comment: As one who has visited most of our national parks, I believe such parks are the 

jewels of our natural heritage. Therefore, I am writing to express my opposition to the proposed 

expansion of Turkey Point Power Plant, located in Homestead, Florida. (0229-1 [Elton, Wallace])

Comment: Therefore, I oppose the expansion of Turkey Point as proposed due to the project's 

potentially widespread negative environmental and public health and safety impacts and the 

serious threats it poses to Biscayne National Park. Please reject this proposal. (0229-2 [Elton, 

Wallace])

Comment: The question of whether nuclear power is good or bad is not the main issue here. 

Rather, the issue is whether this project in this particular location should be allowed to go 

forward. Many citizens concerned about achieving restoration of the Everglades think it should 

not. (0232-1 [Fielding, Ed])

Comment: I oppose the application for Units 6 and 7 at Turkey Point. While it was an illadvised decision over 40 years ago to locate two nuclear reactors between two national parks, 

Everglades National Park and Biscayne National Park, which are unique biodiversity hotspots, 

that decision should not be compounded by adding two additional reactors to the site. (0246-1

[Shlackman, Mara])

Comment: On behalf of the undersigned environmental organizations representing hundreds 

of thousands of citizens throughout the country, we submit these comments in opposition to the 

proposed Turkey Point Power Plant expansion. Our groups and members are deeply committed 

to protecting the environmental health of South Florida and our precious freshwater supply. We 

have serious concerns that the proposed expansion of Turkey Point could significantly impact 

the health of our national parks, sensitive ecological areas, federally listed threatened and 

endangered wildlife, and the quality and quantity of our water resources. (0253-1 [Bloom, Justin] 

[Campbell, Cara] [Causey, Charlie] [Cavros, George] [Chenoweth, Mike] [Daly, Meg] [England, Margaret] 

[Fuller, Manley] [Jones, George L.] [Keller, Alan] [Martin, Drew] [McLaughlin, Caroline] [Reynolds, Laura] 

[Silverstein, Rachel] [White, Paton] [Williams, Elinor])

Comment: In the interest of protecting the health and integrity of our valuable natural 

resources and limited water supplies we strongly recommend that you do not permit the 

proposed Turkey Point Power Plant expansion. (0253-6 [Bloom, Justin] [Campbell, Cara] [Causey, 

Charlie] [Cavros, George] [Chenoweth, Mike] [Daly, Meg] [England, Margaret] [Fuller, Manley] [Jones, 

George L.] [Keller, Alan] [Martin, Drew] [McLaughlin, Caroline] [Reynolds, Laura] [Silverstein, Rachel] 

[White, Paton] [Williams, Elinor])

Comment: We, the undersigned elected representatives of the citizens of Florida, write to you 

united in our opposition to the proposed plan to expand Turkey Point Power Plant, located in 

Appendix E October 2016 E-501 NUREG–2176
Homestead, Florida. We are dedicated to ensuring the health of South Florida's environment 

and the integrity of our precious freshwater supply. We are concerned that the expansion of 

Turkey Point, as proposed, could have serious impacts on our national parks, sensitive 

ecological areas and the quality and quantity of our water resources, and critical economic 

drivers that support our communities. (0254-1 [Dudley, Dwight] [Lerner, Cindy] [Regalado, Tomas] 

[Stoddard, Philip K.])

Comment: We recommend that, in the interest of protecting the integrity of our valuable natural 

resources, limited water supplies and a healthy local economy, plans to expand Turkey Point 

Power Plant do not proceed as proposed. (0254-7 [Dudley, Dwight] [Lerner, Cindy] [Regalado, 

Tomas] [Stoddard, Philip K.])

Comment: Turkey Point Power Plant is a nuclear power facility located directly on the shores 

of Biscayne National Park, one of our country's largest marine national parks. A for-profit utility 

wants to expand Turkey Point by constructing two new nuclear reactors. Expanding a nuclear 

power plant in the sensitive ecosystem surrounding Biscayne National Park is unacceptable!

(0258-1 [Field, Fran])

Comment: It is unconscionable for you to waste our hard earned taxpayer dollars on toxic 

nuclear next to not just a precious ecosystem, Biscayne Bay and the Everglades, but an urban 

area where millions reside in an area prone to catastrophic damage from monstrous hurricanes!

(0259-4 [Lettieri, Tammy])

Comment: I am writing in reference to Docket ID: NRC-2009-0337. I am opposed to the 

expansion of Turkey Point Power located in Homestead, Florida. The site is right on the shores 

of Biscayne National Park and very susceptible to climate changes. Turkey Point will surely 

have negative impact on the environment. (0262-1 [Demaria, Karen])

Comment: Given the proximity of Turkey Point to the major population centers of South 

Florida, its location immediately contiguous to the environmentally sensitive, fragile and 

irreplaceable, Florida Everglades, Everglades National Park, Biscayne National Park, and the 

Florida Keys Marine Sanctuary, the Turkey Point Nuclear Power Plant exposes the population 

and natural environment of South Florida to unintended, but nevertheless, extraordinary risk.

(0263-2 [Orzechowicz, Holly])

Comment: The conditions that were present when The Turkey Point facility was originally sited 

and constructed in the early 1970s are not the same conditions that exist today. Those original 

conditions and considerations that may have made Turkey Point a viable location for a Nuclear 

Power Generating Plant have changed dramatically in the ensuing years. (0263-7 [Orzechowicz, 

Holly])

Comment: Biscayne National Park is a treasure in south Florida and expanding this facility with 

impacts on this ecosystem is unacceptable to me. (0281-1 [Nye, Janet])

Comment: I strongly oppose the expansion of Turkey Point as proposed due to the project's 

potentially widespread negative environmental and public health and safety impacts and the 

serious threats it poses to Biscayne National Park. (0282-1 [Timberlake, Ralph])

Comment: Expanding a nuclear power plant in the sensitive ecosystem surrounding Biscayne 

National Park is unacceptable! (0284-1 [Lopez, Josie])

Appendix E NUREG–2176 E-502 October 2016
Comment: Please choose to protect Biscayne National Park's incredible wetland and marine 

habitats from the threat of nuclear expansion. (0284-6 [Lopez, Josie])

Comment: Expanding a nuclear power plant directly on the shores of Biscayne National Park--

in an area vulnerable to sea level rise--will have serious environmental consequences! The 

NRC and the Corps must ensure that future plans for Turkey Point protect our national parks, 

water supply, and public health. (0284-7 [Lopez, Josie])

Comment: I urge you to deny the proposed expansion at Turkey Point and protect the region's 

people and unparalleled natural resources. (0285-3 [Miller, Melissa])

Comment: The ocean level is rising and the coral reef nearby is dying. You have the power to 

prevent the destruction of this beautiful area. Biscayne National Park is an irreplaceable national 

treasure that safeguards precious natural resources and recreational opportunities. (0290-3 [Wry, 

Ellen])

Comment: I strongly oppose the expansion of Turkey Point because of the project's potentially 

widespread negative environmental and public health and safety impacts as well as the serious 

threats it poses to Biscayne National Park. (0295-5 [Dietrich, Chris OMeara])

Comment: Why would you allow expansion of a nuclear plant in such a vulnerable area? 

These decisions affect us far, far into the future and that future is uncertain. (0297-1 [Strouble, 

Jackie])

Comment: The current administration in that state seems determined to ignore the warnings, 

but that doesn't mean you have to. Biscayne Bay is also an environmentally sensitive area 

where further construction is not warranted nor desirable. I urge you to turn down expansion 

plans in Biscayne Bay! (0297-3 [Strouble, Jackie])

Comment: Know what we ALL know now...these past reactors would HAVE NEVER been built 

where they are......WE CAN now MOST CERTAINLY PREVENT any MORE reactors being built 

there. (0306-1 [Bagwell, Wilson Knox])

Comment: The plan to expand nuclear facilities at a location that was not the best idea in the 

first place, is even stupider. Not just because of the Biscayne National Park, but that is certainly 

a major reason to deny permission for the expansion but really, when are we going to stop 

polluting the wetlands and when are we going to face the fact that Florida's coastline is subject 

to flooding due to climate change (not to mention storms)? (0310-1 [Stevens, Lisa])

Comment: YOUR AGENCY SHOULD BE PROTECTING NATIONAL PARKS, SO YOU 

SHOULD VIGOROUSLY OPPOSE THE ENVIRONMENTALLY STUPID PROPOSAL. (0321-1

[Anderson, Glen])

Comment: I see no benefit to the expansion of the existing Turkey Point plant for the health of 

South Florida's Biscayne National park and for my family's health. (0349-1 [Oliva, Vivian])

Comment: I am opposed to any expansion of nuclear power in Florida, especially in the 

Biscayne Bay area. Further expansion would only increase serious risks to our health and the 

environment. (0350-1 [Shasky, Mike])

Appendix E October 2016 E-503 NUREG–2176
Comment: I am opposed to any expansion of nuclear power in Florida, especially in the 

Biscayne Bay area. Further expansion would only increase serious risks to our health and the 

environment. (0351-1 [Anonymous, Anonymous])

Comment: We vote AGAINST the proposed new nuclear reactors in Biscayne National Park.

(0359-3 [LoBiondo, Roana and Michael])

Comment: The New Progressive Alliance at http://newprogs.org/ urges you to reject Florida 

Power and Light's plan to build two new nuclear reactors on the shores of Biscayne Bay. The 

two nuclear plants are poorly placed, are a clear and present danger to the water supply, and 

are a bad risk in light of over 50 years of history on the use of nuclear power. (0366-1 [Griffith, Ed 

and Harriet])

Comment: We at the New Progressive Alliance ask you to do the right thing because these 

two nuclear plants are poorly placed, are a clear and present danger to the water supply, and 

are a bad risk in light of over 50 years of history on the use of nuclear power. (0366-12 [Griffith, 

Ed and Harriet])

Comment: We hope to visit Biscayne National Park someday and do not want to find it 

compromised by an expanded Turkey Point Power Plant! (0386-1 [Bromage, Joan])

Comment: I have not yet been to Biscayne National Park, but I do hope to visit that and others 

to complete my goal of experiencing all the NPS units. I am sure that Biscayne National Park is 

a wonderful place. The manatees, flamingos, corals, and sponges do not need an expanded 

nuclear power plant in or near their habitat. Please protect Biscayne National Park vigorously.

(0391-1 [Aronson, Murray])

Comment: Please vote on the side of the parks and all the goods things it will distroy in time. 

Vote No for the parks, people, nature and most of all for that is best for the country. (0392-3

[Greer, Tom])

Comment: Please do not allow any expansion! (0394-1 [Dougherty, Kate])

Comment: Do not expand this plant on the shores of Biscayne National Park. Foolish idea and 

could be very destructive. (0398-1 [Winters, Gracie])

Comment: Please heed our advice and save our National Parks from ruination. (0399-1 [Drew, 

Virginia])

Comment: Please don't let this happen. I'm a scuba diver and have enjoyed diving in Florida. 

Don't ruin this area of the ocean, not just for me but others to not be able to enjoy in the future.

(0426-1 [Bunker, Diane])

Comment: This area is already showing signs of environmental stress. (0427-1 [Purcell, 

Douglas])

Comment: Please consider how many ways this could become a disaster-from freshwater 

resources, to plant and animal life, to the very likely saltwater intrusion. Please do the right thing 

& don't try to expand here! (0429-1 [Schilling, Judy])

Comment: Why do American citizens have to continually fight to keep the World's Greatest 

Park System in tact??? (0430-1 [Yost, Gaylord])

Appendix E NUREG–2176 E-504 October 2016
Comment: In April, 1991, I visited Biscayne National Park. I enjoyed that trip and would NOT 

want Turkey Point Power Plant to expand into any of the Park. (0447-1 [Degges, Frank])

Comment: I hope the proposed addition to the Turkey Point Power plant is rejected so there is 

no further degrading of Biscayne Bay waters or rising sea levels flooding the existing plant plus 

the addition. (0453-1 [Matheny, Kent])

Comment: I PERSONALLY HAVE BEEN TO THE BISCAYNE NATIONAL PARK MANY 

TIMES AS I HAD RELATIVES WHO LIVED ON KEY BISCAYNE AND IT IS A BEAUTIFUL 

PARK, SO PLEASE DO NOT LET THIS AREA BE DESTROYED & RUINED BY THIS 

EXPANSION!!! I DO STRONGLY OPPOSE IT & I PRAY THAT YOU THINK OF THE 

ENVIRONMENT FIRST!!! IT WILL CAUSE WAY TOO MUCH DAMAGE!!! AGAIN PLEASE DO 

NOT ALLOW THIS TO HAPPEN!!! (0457-1 [Poole, Diane])

Comment: Expanding a nuclear power plant in the sensitive ecosystem surrounding Biscayne 

National Park is unacceptable! (0491-1 [Halligan, Melody])

Comment: The proposed Turkey Point expansion's potentially widespread negative 

environmental and public health and safety impacts, and the serious threats it poses to 

Biscayne National Park, mandate its denial. (0492-4 [Mckee, Sarah])

Comment: Please oppose the plan to add two nuclear reactors to Florida Power and Light's 

Turkey Point operation. The reactors would be located between two national parks on fragile 

wetlands stressed by cooling canals and threatened by rising sea levels. This land is too fragile 

to support one nuclear reactor - let alone two. (0506-1 [Fox, Kristi])

Comment: Please do not destroy our delicate environment any further! (0516-2 [Coffey, 

Rotraud])

Comment: Some places should be left untouched by industry and this is a perfect example of 

one of those places. (0527-1 [Nagel, Karen])

Comment: I am writing to tell you to stop destroying our parks! (0528-1 [Watson, Fran])

Comment: I strongly oppose the expansion of Turkey Point as proposed due to the project's 

potentially widespread negative environmental and public health and safety impacts and the 

serious threats it poses to Biscayne National Park. (0533-2 [Boone, James])

Comment: I am writing to say that I am against placing additional nuclear reactors at Biscayne 

Bay. (0537-1 [Anonymous, Judi])

Comment: I grew up in Kendall, Florida. As a youth, I enjoyed diving in Biscayne National Park 

and canoing in the Everglades. I am shocked at the short sighted propasal to expand the 

nuclear facilities at Turkey Point. (0552-1 [Deutsch, Steven])

Comment: I strongly oppose the expansion of Turkey Point as proposed due to the project's 

potentially widespread negative environmental and public health and safety impacts and the 

serious threats it poses to Biscayne National Park. "A thing is right when it tends to preserve the 

integrity, stability, and beauty of the biotic community. It is wrong when it tends otherwise."

(0555-3 [Lish, Christopher])

Appendix E October 2016 E-505 NUREG–2176
Comment: Please do not allow this project to happen and protect our National Parks. (0569-2

[Lane, N. Jo])

Comment: With all of the environmental impact of fresh water draws and overheated cooling 

canals, not to mention potential hurricane impact on the facility, it seems unconscionable that 

FPL would be allowed to add additional reactors to its Turkey Point facility. The existing is 

already pushing the limits of sustainability. (0571-1 [Darden, Colgate])

Comment: Please do not approve FPL proposal for two new nuclear reactors. The danger to 

South Florida's most important public lands and wildlife habitats - Biscayne and Everglades 

National Parks - will be put at risk and be forever changed if this is approved. (0581-1 [Tweedy, 

Mary])

Comment: Please oppose the proposed expansion of Turkey Point Power Plant, located in 

Homestead, Florida near Biscayne National Park. It is close enough to the Gulf of Mexico to be 

even more fragile. (0582-1 [Wade, Pat])

Comment: I strongly oppose the EIS for FPL's application to build 2 new nuclear reactors at 

Turkey Point. They will negatively impact the surrounding community and Everglades and 

Biscayne National Park and threaten local water and land resources, as well as be a health risk.

(0597-1 [Cullen, Sarah])

Comment: This project that, if built, will impact surrounding communities and sensitive 

ecological areas such as the Everglades and Biscayne National Park, threaten local water and 

land resources and increase FPL customers' utility bills. (0602-1 [Colson, Clay G.])

Comment: It is very disappointing that you would think of building reactors on Biscayne Bay or 

anywhere for that matter. This action along with many approved building on endangered lands 

here in South Florida that impact our ability to breath and many endangered plants and species 

ability to survive have negative consequences .. with no preservation and over development 

here in South Florida -both our LAND AND SEA must be protected to "survive and thrive" for 

future generations .... and actions like these are not good. (0634-1 [Jacobs, Leslye])

Comment: I am writing to protest the application for the Turkey Point Nuclear Plant. I am a 

resident of Boca Raton and have frequently enjoyed the Everglades National Park and Biscayne 

Bay. The area is too fragile, beautiful and important to risk a an action that might jeopardize the 

natural environment. (0635-1 [Seiman, Rhonda])

Comment: STOP NUCLEAR EXPOSIONS ON BISCAYNE BAY, FLORIDA, THANK YOU.

(0636-1 [Sanfilippo, Val])

Comment: I am very concerned about the environmental ramifications of the proposed nuclear 

reactors in Biscayne Bay, not to speak also of the industrial ugliness that would be introduced to 

the landscape. Please do not allow this! (0640-1 [Dutton, Julene])

Comment: I oppose the licencing of two new nuclear reactors at Turkey Point Nuclear Power 

Plant. This plant is located next to two National Parks. It is negatively impacting Biscayne Bay 

National Park by drawing surface water from the Biscayne Bay where salinity levels are too high 

during dry periods. The park area was originally surrounded by natural areas that permitted 

sheet flow of fresh water into Biscayne Bay. The addition of two new nuclear reactors will 

increase an already stressed environment. (0641-1 [Martin, Drew])

Appendix E NUREG–2176 E-506 October 2016
Comment: Who even considers putting such a potentially destructive plant within range of an 

INTERNATIONAL treasure like the Everglades? Reconsider!!! For the sake of this generation 

and those to come! (0652-1 [Le Cronier, Micki])

Comment: No nuclear reactor at Biscayne Bay! (0661-1 [Segal-Wright, Nicholas])

Comment: I move that the Combined License application for Turkey Point Nuclear Plant, Unit 

Nos. 6 and 7 be denied. Because of the ecological sensitivity of the proposed area and the high 

human, animal and fish life usage of the waters and land areas of Biscayne Bay and the nearby 

Everglades Park and aquifer, the proposed nuclear reactors and generators would produce 

prohibitive amounts of contamination of the waters and land. Therefore, the approval and 

funding of this proposal needs to be denied due to the Chemical and environmental impacts on 

life and health within the proposed project areas. (0663-1 [Turner, William P.])

Comment: Please do not approve the application for two new nuclear reactors, Unit Nos. 6 and 

7, at the Turkey Point Nuclear Power Plant. This project should not be allowed to move forward, 

in part, because it will irrevocably change and put at risk two of Floridas most important public 

lands and wildlife habitats the Biscayne National Park and the Everglades National Park. (0674-1

[Dwyer, Karen])

Comment: Florida Power and Light is seeking permission to build two new nuclear reactors at 

its existing plant next to Biscayne National Park and other natural areas; the project would be 

highly water-intensive, potentially threatening Biscayne Bay and the Biscayne Aquifer. (0676-1

[Kassel, Kerul])

Comment: Please don't let this proposed power plant expansion hasten the death of South 

Florida's remaining wildlife habitats. (0693-5 [Dorn, Kathryn])

Comment: But the era of nuclear energy off of Biscayne National Park is coming to an end and 

we need to prepare for that because it's coming. (0721-30-12 [Ullman, John])

Comment: In the interest of protecting our national parks and maintaining the quality and 

quantity of South Florida's fresh water supply, the expansion of Turkey Point, as currently 

proposed, should not move forward. (0721-9-8 [McLaughlin, Caroline])

Comment: If this Turkey Point expansion is undertaken Turkey Point will become one of the 

largest nuclear generating facilities in the country which, in and of itself, is not at all a bad thing. 

But considering its location, in one of the most --the areas most vulnerable to sea level rise 

directly adjacent to a national park, a State preserve and some really critical habitat on Biscayne 

Bay, that does pose a problem. This is a really ecologically and economically important 

environment. (0722-7-1 [Silverstein, Rachel])

Comment: And the three major reasons that I'm going to talk about today that this expansion is 

not appropriate at this location is, potential contamination of our water supply, excessive 

withdrawals of water related to this project, the vulnerability of the facility to sea level rise and 

the inadequate incorporation of that aspect into the Environmental Impact Statement as well as 

the ecological fragility of the surrounding area. It's already been impacted by the existing 

nuclear power plant and excessive water withdrawals and the cooling canal issues that are 

already existing. (0722-7-2 [Silverstein, Rachel])

Appendix E October 2016 E-507 NUREG–2176
Comment: I suggest that we follow his leadership and work towards a more resilient 

sustainable South Florida. In the interest of protecting our national parks and maintaining the 

quality and quantity of South Florida's freshwater supply, the expansion at Turkey Point as 

proposed should not move forward. (0723-4-10 [McLaughlin, Caroline])

Response: These comments identify general concerns about the ecology surrounding the 

proposed Turkey Point Units 6 and 7. They do not provide any specific information related to 

the environmental effects of the proposed action. Ecological impacts of building and operating 

the proposed units are described in Sections 4.3 and 5.3 respectively. No changes were made 

to the EIS as a result of these comments. 

Comment: I was quite surprised this plan was going through given the public hearings and 

continued comments about the facility using outdated data regarding sea level change, the 

algae bloom issue[.] (0008-1 [Finver, Jody])

Comment: Are you people totally out of touch with whats happening with a warming climate 

and a rising sea. Stop this foolishness[.] (0028-2 [Clapp, Linda])

Comment: It seems insane to do this in the state the most endangered by climate change 

through rising sea water, and with our hurricanes. There are other, safer ways to provide the 

country's energy needs. (0031-2 [Hawkes, Holly Forrester])

Comment: It is simply unthinkable that the NRC would consider approval of any changes to 

Turkey Point Nuclear Power Plant aside from a plan to shut it down. There is no question as to if 

it will suffer problems, the only questions are when to what degree of severity. The combination 

of sea level rise, which no legitimate scientist denies, and the regularity with which severe 

storms, becoming more so each year, strike the Florida coastline, make the site untenable.

(0051-1 [Smith, David W.])

Comment: Now that I know, I would not like to see the current plant, especially with sea levels 

on the rise, located so close to any city. (0061-4 [Lague, Victoria])

Comment: I urge you strongly, as a Florida residence, to deny the nuclear power plant option 

for FPL. This is irresponsible in light of our local climate and future water shortages. (0080-1

[Reiter, Ben])

Comment: Given the dangers of hurricanes, sea level rise, and the demands on South Florida 

fresh water needed to cool the existing plant, any expansion is not only foolhardy but a danger 

and detrimental the the health and welfare of the South Florida human and marine population.

(0091-1 [Boyce, Sheila])

Comment: Furthermore, expanding a nuclear power plant in an area that is ground zero for 

sea level rise threatens the future of South Florida. (0102-7 [Commenters, Multiple])

Comment: This is without even mentioning the environmental effects such an upgrade will do 

specifically concerning water supply and the danger of sea level rise. (0119-4 [de Azevedo, 

Ricardo])

Comment: I am not opposed to all nuclear power. However, the site proposed for expansion is 

located directly on the shores of Biscayne National Park in an area that is extremely susceptible 

to sea level rise and the impacts of climate change. (0155-1 [Morgan, Karen])

Appendix E NUREG–2176 E-508 October 2016
Comment: THIS IS A TERRIBLE, TERRIBLE IDEA: TOO EXPENSIVE, DANGEROUS TO 

THE GLADES, SHORTSIGHTED IN VIEW OF RISING SEA LEVELS, AND YET ANOTHER 

POTENTIAL WATER HOG. (0157-1 [Weber, Gae])

Comment: This is an ill-conceived, poorly thought out decision and must not move forward. 

Even in a state that denies the reality of sea level change, like Florida, reality will hit home. and 

then what will you do with this facility? It's time to give life a chance because money and profit 

aren't cutting it. (0179-1 [Roseberry, Bill])

Comment: Florida is one of the only places in the world where you can see climate change in 

effect. Why, then, are we building nuclear reactors in an environmentally sensitive location? I 

haven't forgotten the tsunami that destroyed Fukushima. Recently, a robot sent into that nuclear 

reactor was destroyed in 10 minutes. Since Florida is an epicentre of hurricanes, tropical 

storms, and sea level rise, it seems absolutely ridiculous to even consider putting a nuclear 

reactor here - especially given FPL's outdated and misguided plans. I only foresee disaster 

within the time that it is here. (0214-3 [Zerulla, Tanja])

Comment: In summary, I believe that the proposed installation of nuclear reactors at Turkey 

Point has not considered current climate change science, alternative energy sources for Florida, 

and proper safety precautions. (0214-8 [Zerulla, Tanja])

Comment: If we have learned anything in Miami from Andrew, we have learned this: Don't 

plan for the good days, when everything is perfect. Don't plan for the bad days, when the 

excrement hits the fan and you get a little splattered. Plan for hell on earth, because worst-case 

scenarios happen, and they are worse than you expect. The reality is that by building nuclear 

reactors in "Hurricane Alley", under conditions of Sea-Level Rise exposes both the reactors and 

the surrounding residents to risks that can not be fully anticipated. FPL is essentially playing 

Russian Roulette with our community's very existence. (0252-13 [Van Leer, Sam])

Comment: Please do not approve the expansion of the nuclear power plant at Turkey Point. 

My biggest concern is that Turkey point, like Fukushima, could be affected by sea level rise. In 

addition, the existing Turkey point units already have problems with cooling its units. FPL will 

need to use Florida's natural aquifer to cool its units, should it run out of treated waste water. 

Neither of these concerns are addressed in the application submitted to your agency. I believe 

you should do the right thing and not approve the Turkey Point plant expansion. (0270-1

[Sommers, Andrea])

Comment: I am an engineer. USF '73. And a rocket scientist. But it doesn't take a rocket 

scientist to see rising seas by a nuclear reactor by an eco park to know a turkey when we see 

one. $$$ is not the measuring stick. Leaving a better place than we found is. (0289-1 [Vance, 

Richard])

Comment: You jest, surely. As sea levels inexorably rise and in a place like Homestead at only 

8' above sea level, you want to expand a nuclear power plant. (0384-1 [Franzmann, Paul])

Comment: Already seacoast cities are experiencing periodic flooding and saltwater has 

already found its way into their water supplies. Use common sense and deny this expansion at 

Turkey Point. (0438-1 [Hoegler, Jean])

Comment: The City believes that the license for the project should not be approved as 

currently proposed. The Turkey Point Nuclear Plant Units 6 & 7 application should be viewed in 

Appendix E October 2016 E-509 NUREG–2176
context of a region facing the enormous water quality and land use related challenges imposed 

by climate change. (0456-1 [Miami, City])

Comment: Environmental impacts are too great to allow the expansion, not to mention that the 

site is one where sea level rise and climate change could have terrible effects. (0539-1 [Malone, 

Peggy])

Comment: I am all for nuclear power if they are located where they will not have an negative 

impact on the environment they are located in. With sea levels and eco systems being an issue 

here I would not allow expansion in this location. (0541-1 [Zarsky, Terry])

Comment: This seems really stupid since sea level rise will wipe it out. (0565-1 [Ackerman, 

Frank])

Comment: I would just end by begging you guys and the NRC, please, you are our only hope. 

You've seen what the State Regulators, the so-called Regulators are like. They're really not 

regulators. I mean I'm a State employee. I'm not even sure if I can use the words "climate" and 

"change" in the same sentence legally. You know what we're dealing with here and you know 

that we're dealing with a utility that -- look, they're just doing their jobs. But they get paid 

whether or not they build this reactor. Unfortunately, we're the ones paying them. You may be 

the only people who can save us from this fate. So I'm just asking you to do everything in your 

power to save us from Units 6 and 7. (0721-16-7 [Rifkind, David])

Comment: So now FP&L wants to build two more nuclear plants at Turkey Point. The plants 

that already exist and the new ones proposed, as well as all that nuclear waste at Turkey Point 

will be under water in the foreseeable future. To me, that one fact is sufficient reason not to 

build these new plants. Game over. But, if that's not enough reason for you there are plenty 

compelling reasons and we've got a lot of them. (0721-28-5 [Wilansky, Laura Sue])

Response: These comments express opposition to the licensing of new nuclear reactors at the 

Turkey Point site due to concerns about global climate change and rising sea levels. Appendix I 

of the EIS documents the review team's consideration of the potential changes in impacts that 

may occur as a result of the changes to the environment resulting from global climate change 

including sea-level rise. The changes that were considered include potential changes in 

temperature, rainfall, and occurrence of severe weather events. The effects of sea-level rise 

were also considered in this analysis. No changes were made to the EIS in response to these 

comments. 

Comment: I would like to register my opposition to the expansion of the Turkey Point Nuclear 

facility by Florida Power and Light. The location, near dense population centers, adjacent to 

valuable natural areas, on the edge of ever-increasing sea levels all create too high a level of 

risk. There are better ways to supply energy to Florida citizens than this. Added to the safety 

issue is the total disrespect FPL shows to the communities it serves with the stated intent to 

install huge power poles through the middle of Coral Gables, South Miami and Miami. Please 

deny FPL permission to build the new reactors. (0046-1 [Wade, Thomas M.])

Comment: Please do not license these 2 additional power plants and do not allow the huge 

power poles to be located along US 1. (0050-3 [Simon, Gary P.])

Appendix E NUREG–2176 E-510 October 2016
Comment: Please do not confirm FP&L's request to build new nuclear reactors and certainly 

do not allow placement of these huge high voltage lines in the Miami Roads neighborhood (nor 

in or adjacent to any other residential neighborhood). (0073-7 [Commenters, Multiple])

Comment: 6. Home values will be definitely affected with the close proximity of these 

proposed lines. For these reasons, I respectfully ask that you consider not confirming FPL's 

request to build new nuclear reactors and certainly not to allow the placement of high voltage 

lines in the Miami Roads Neighborhood. (0077-5 [de Armas, Maria Cristina])

Comment: I want this letter to be a clear and strong statement that I strongly oppose the 

expansion of Turkey Point with this new reactors as well as the installation of the transmission 

lines through our neighborhoods and or the Everglades. (0087-4 [Lange, Alexandra])

Comment: I strongly oppose Florida Power & Light's (FPL) plan to build two new nuclear 

reactors and miles of transmission lines through residential and downtown Miami. (0126-1

[Pontier, Christine Hughes])

Comment: US1 is the gateway to one of the most beautiful areas in the State so why make it 

look like an industrial city. It is historic, the neighborhoods are historic, this is where Miami was 

first settled, it will destroy our future, and make us an industrial wasteland. (0149-3 [Nelson, Joyce 

E.])

Comment: I am writing to state my very strong opposition to both the expansion of nuclear 

power generating capacity at Turkey Point and the installation of the proposed towers along 

US1. (0187-1 [Meyer-Steele, Shawn])

Comment: I wish to express that I AM TOTALLY AGAINST new nuclear reactor units at Turkey 

Point as well as miles of oversized transmission lines going down US 1. (0314-1 [Erven, Marlene])

Comment: I am writing to express my opposition to the expansion of the Turkey Point 

expansion plans and to the placing of lines up and down highway U.S.1. (0409-1 [Portela, Ana C.])

Comment: There are issues of sea level rise, salt water intrusion, the potential raiding of 

freshwater supplies needed for our growing population, nuclear waste, damage to the bay's 

coral reefs and estuaries and the prospect of dangerous and unsightly poles along US1 and in 

the Everglades. (0596-3 [Sorenson, Katy])

Comment: I oppose the expansion of Turkey Point nuclear power plant, as well as the new 

power lines adjacent to Everglades National Park. My reasoning is the same as that put forth by 

the Miami Group Sierra Club. (0620-1 [Southern, Tom])

Comment: Even if this new plant were to operate for its entire lifetime with a 100% safety 

record, the impact of building and operating such a plant and transmission lines will be 

catastrophic. (0639-1 [Haselhurst, Richard])

Comment: In the cities near FP&L's nuclear facility south of Miami, there is intense opposition 

to the building of the two nuclear reactors from mayors, business leaders, and citizens. One part 

of the opposition comes from the negative impact these reactors will have for decades on the 

fragile environment of the Everglades, Biscayne National Park, and the Atlantic Ocean which 

border this nuclear facility. Another part comes from the $25 billion cost and the intrusive 

construction and traffic problems the plants will cause for years to the thousands of businesses 

Appendix E October 2016 E-511 NUREG–2176
and residences in the area. The third part comes from the installation of 100 foot high x 5 feet 

thick concrete power poles that will be used to transmit the power to Miami and other cities. 

These massive concrete poles will be placed along major highways and streets and they will be 

visible for miles. In many cases they will be the tallest and most noticeable structures in the 

historic neighborhoods along coastal Highway U.S. 1. (0671-2-2 [Post, Patrick])

Response: The comments express opposition to the proposed units at the Turkey Point 

site. They do not provide any specific information related to the environmental effects of the 

proposed action. No changes were made to the EIS as a result of these comments. 

Comment: As a 45 year resident of Coral Gables, FL I want to express my opposition to the 

construction of additional nuclear power plants in South Florida. Rather, the existing nuclear 

plants at Turkey Point should be phased out and shut down. (0213-1 [Hyams, Charles])

Comment: It wholly benighted to even think of building unit # 6 and #7. What should be 

thought about is permanently decommissioning Turkey Point. (0264-8 [Dwyer, John P.])

Comment: FPL has spent years developing their PR and campaigns to influence the public 

and public officials to enable their plan to go forward (often giving false or misleading 

information to silence safety and environmental concerns), rather than accepting the validity of 

objections and developing a more progressive and environmentally friendly plan for the future of 

energy in Florida. (0356-15 [Shlackman, Jed])

Comment: Rather than expanding Turkey Point, we should be preparing to close it down.

(0463-7 [Gross, Cheryl A.])

Comment: Hello Some information that may help Stop Turkey Point Nuclear Plant from being 

enlarged ? ! I had heard that they want to enlarge Turkey Point ! Which I think is already past 

it's time of usefulness maximum time use design already ? I was 14 years old when it came on 

line and I am 68 years old now. And of course just like Fukoshima it is just waiting for a tsunami 

sitting rite on the Atlantic Ocean ! (0505-1 [Buyea, Thomas])

Comment: In truth, my preference would be to shut down Turkey Point, and you are wanting to 

add more reactors!!! (0540-2 [Burge, Laura])

Comment: We need to be shutting Turkey Point down safely NOT expanding nuclear energy.

(0548-1 [Scott, Ruth])

Comment: Then we can work on dismantling the existing nuclear reactors, which is really what 

we should be doing. (0643-3 [Joannou, Jr., Benjamin])

Comment: It is time to shut down, not expand nuclear plants across the country. (0647-3 [Burns, 

Terry])

Comment: Also I strongly feel that this existing plant should be shut down and dismantled as 

soon as possible!!! (0651-2 [Young, Kim])

Comment: It wholly benighted to even think of building unit# 6 and #7. What should be thought 

about is permanently decommissioning Turkey Point. (0673-9 [Dwyer, John P.])

Comment: Furthermore, please consider decommissioning Turkey point and transporting the 

spent fuel rods to a safe storage site. (0674-9 [Dwyer, Karen])

Appendix E NUREG–2176 E-512 October 2016
Comment: My common sense is telling me that this nuclear power plant should not be 

enlarged, it should be decommissioned. (0695-1 [Nappe, Judith])

Comment: Given sea level rise and that there is no way of disposing nuclear waste from this 

site at this time, what we should be discussing is decommissioning this entire plant and coming 

up with plans for removing all waste from an area that will be underwater within decades.

(0714-1 [Gonzalez, Carlos])

Comment: You do not need any more power plant. Shut down the plant. (0721-18-5 [Bernabei, 

Catharina])

Response: These comments express opposition to both the existing units and additional units 

at the Turkey Point site. They do not provide information related to the environmental review for 

the proposed action. No changes were made to the EIS as a result of these comments. 

E.2.34 General Comments in Opposition to the Licensing Process 

Comment: You should not require regular people to read technical 25 megabyte files that take 

so long to load and are 717 pages long. You could have made this much shorter. (0373-14 [Lee, 

Nancy])

Comment: The report fails to explain the fact that they have obviously ignored their own 

criteria; that they've avoided locating a project near a national park. Although that was a 

significant criteria, they are ignoring it and placing it between two very fragile national parks, 

both of which have habitual and fragile wildlife, particularly vulnerable to the long term adverse 

impact of the hydrology, the quality and the quantity of the salt water source. There's one other 

particular species at highest risk of having to compete with the nuclear plants for water, and that 

is the 4 million human beings who inhabit South Florida. (0721-3-5 [Lerner, Cindy])

Response: The NRC licensing process for nuclear power plants includes a thorough review of 

the proposed plants' impacts on the environment in accordance with NRC 

regulations. Documenting the thorough review and the NRC's conclusions results in the large 

document you describe. In addition to making the document available for download, the NRC 

provided copies of the document to reading rooms and libraries near the Turkey Point site to 

facilitate review of the EIS. The EIS is also summarized in a Reader's Guide that is available on 

the NRC website. No changes were made to EIS as a result of this comment. 

Comment: I'm going to say what a lot of us are thinking. The Draft EIS is cursory, perfunctory, 

and biased in favor of the applicant. (0721-12-13 [White, Barry J.])

Comment: I am concerned about the probity, the adequacy of the research base that went into 

this Draft proposal. (0721-17-3 [Breslin, Tom])

Comment: So the Turkey Point 6 and 7 Draft Environmental Impact Statement has serious 

omissions in the analysis that make it impossible to determine the likely effects of plant 

operations on the environment. (0721-2-1 [Stoddard, Philip K.])

Comment: So the one question is, what are the chances of another Hurricane Andrew 

happening again at this same site? That's for them to answer. That's what the EIS is supposed 

to look at. That's the hard look. (0721-22-11 [Schwartz, Matthew])

Appendix E October 2016 E-513 NUREG–2176
Comment: Which brings up a big absurdity here. We keep trying to separate -- the NRC tries 

to separate safety and environmental concerns. We're talking about radiation. They're the same 

thing. A radiation release is a safety problem and an environmental problem. So to try to 

separate those out and say that's a different meeting and the public can't attend the safety 

meeting -- there is no public comment group like this for the safety meeting, is unconscionable. 

And it indicates that there is a safety problem that we need to be aware of. (0721-23-2 [Bethune, 

David])

Comment: In looking at the Environmental Impact Statement, I don't think they did a good job 

in terms of projecting what the future will look like. In order to do this properly we have to see 

what will happen in 50, 60, 70 years, and I think the models that they use are inaccurate.

(0721-7-3 [Edmond, Gabriel])

Response: These comments express concern about the NRC's licensing process. Because 

these comments did not provide new information, no changes were made to the EIS. 

E.2.35 General Comments in Opposition to Nuclear Power 

Comment: There is no one on earth building new nuclear plants. They are too risky and 

expensive. No. No. No! (0004-3 [Engelberg, Jodi])

Comment: No NUCLEAR POWER in the Sunshine State. (0012-1 [Shahsavar, Mehran])

Comment: I Do Not think it's time to invest in nuclear energy. (0014-1 [Westaway, Katharine])

Comment: We are opposed to any expansion of nuclear energy. (0020-1 [Smith, Leigh Emerson])

Comment: Nothing good has come with the endless tinkering, rape and pillage of the natural 

world. Nuclear energy is the most dangerous energy created. NO technology will reduce the 

impact of the fossil fuels that we are using to selfishly serve a dangerously high human 

population - especially the US population which generates the most pollution and waste 

proportional to our population. (0020-3 [Smith, Leigh Emerson])

Comment: When you look at the Fukushima disaster in Japan, and you look at the land area 

that was exposed to radiation, let's assume that would encompass an area from the Palm 

Beaches to Key West. Can you imagine evacuating that many people from such an area? And 

can you imagine the decline in property values that would result even if some of those people 

were convinced that they could return? That kind of thought is abhorrent to me. It is really 

unimaginable. Yet this is the risk that we take with nuclear power. In my opinion, even though 

the risks of a disaster are low, the consequences are so high that we really should not be taking 

the risk at all. We really should be planning for the abandonment of all nuclear reactors. They 

have the potential to end our civilization. For example, if there were a Coronal Mass Ejection in 

our Sun, of the magnitude that occurred in the late 1800s, that could cause a global electrical 

blackout. And in today's society, unlike in the late 1800s, that would be a major event. But the 

bigger problem would be that all of the control rooms of every nuclear reactor around the world 

would be rendered inoperable. So we wouldn't even be able to shut down our nuclear reactors. 

Within a few days, every single nuclear reactor would melt down. I believe the meltdown of 

every nuclear reactor in the United States would effectively mean the end of our nation. So I 

hope you see that I firmly believe that we should not be adding to our inventory of nuclear 

reactors. (0023-1 [Joannou, Jr., Benjamin])

Appendix E NUREG–2176 E-514 October 2016
Comment: I fear what could happen with more nuclear power nearby, ex explosions, terrorist 

attacks, and magnitude of damage to nearby population. Would not want to put human life in 

danger for sake of production, prosperity, or economic gain, not for me or future generations. I 

do not trust decisions of those who do not have same concerns or values. I say look to another 

way putting welfare of people first. May God guide your final decision. (0025-1 [Alvarez, Susana])

Comment: My opinion would be to turn the contaminating Nuclear plant and it horrible by 

product into something that we can live with for future generations. (0027-2 [Neal, Kevin])

Comment: I am asking you to be selfish, think of yourself, think of your family the future of kids 

or your kids kids, does their future look good, bright? It does!! I know it does. So I ask whats the 

POINT in Turkey Point to add more reactors? What is the real point? Is it an addicition? I ask 

this because to me its like smoking cigarettes. You trick yourself into thinking its good. Where is 

the good when now is fine until later in life you realize you're dying because you thought it was 

ALL good. Teach the lesson that you learned to your kids and their kids by saying NO to not 

only more nuclear reactors, say NO to ALL nuclear reactors. We're all dying from cancer, we 

cant eat fish from the Pacific Coast because of Fukushima. How they doing now? Ask them if 

theyre happy with their nuclear reactors. Its not if theres going to be a problem its a matter of 

WHEN. So WHEN are you going to realize that what YOU are doing affects YOU too & your 

kids. NOw is the time to make the right choice, not when youre dying from the effects. We have 

control of our fate here. Use this time to tackle the other issues we need to battle. If you need 

help there just ask, I WILL gladly assist. I am taking care of my kids by writing you because its 

ALL I can do so I am going back to LOVING & PLAYING..... what are you REALLY doing

(0029-1 [O'Brien, Lance])

Comment: I recently became a mother and I do not want my son's generation or the rest of 

mine to have to deal with the endless amounts of radiation the will affect us and the planet 

haven't we caused enough damage as it? (0030-2 [Gomez, Lissett])

Comment: As a native resident of south Miami-Dade County with young children and many 

relatives and friends in this area, I am deeply concerned about the prospect of new nuclear 

reactors being built at FPL's Turkey Point facility. Turkey Point already makes residents nervous 

due to its relative proximity to residential areas. (0052-1 [Roos, Monica])

Comment: The very future of life on Earth is threatened by use of this form of energy! One 

accident, equipment malfunction, operator error, or terrorist attack at a nuclear plant could 

literally mean the end of life on Earth. If Fukushima didn't convince you, and you still think a 

disaster like can't happen at Turkey Point, just think about that little O-Ring on the Challenger. 

Here in Florida we can never forget that. There is no way to guarantee 100% safety when using 

this technology, and when it comes to materials that remain deadly dangerous for tens of 

thousands of years, longer than all of human history, anything less than 100% safety cannot be 

considered safe. We humans are not infallible, and neither is anything we produce. Nor can we 

control - or predict - the forces of nature, as much as we might pretend we can. This means that 

nuclear plants cannot, simply cannot be guaranteed to be safe. And when it comes to nuclear 

materials, anything less than 100% safety is just not good enough. Nuclear plants are so 

dangerous even Wall Street won't invest in them, and they'll invest in almost anything, no matter 

how risky! (0078-2 [Wilansky, Laura Sue])

Comment: There are so many reasons to develop a forward thinking plan and reduce waste of 

our precious water. Nuclear is not the way forward. We need a vision that is not harmful to the 

Appendix E October 2016 E-515 NUREG–2176
environment and uses sound thinking and heartfelt discion making to find our way forward.

(0098-2 [Gavel, Deborah])

Comment: Says it all. Barry [commenter submitted a graphic/picture in original 

correspondence] (0100-1 [White, Barry])

Comment: I am unequivocably opposed to any new nuclear power facilities. We keep looking 

at wrong-headed solutions that are absolutely fraught with potential danger. The massive use of 

water is not acceptable and we do not want another Chernobyl or Fukushima. (0124-1 [Colby, 

Helen])

Comment: [T]he idea of a nuclear power plant terrifies me, and I strongly disagree with this 

plan on all fronts. (0128-4 [Bach, Lili])

Comment: Nuclear power has been shown, at Three Mile Island and at Chernobyl, to be 

unsafe, unreliable, and unpredicatble. (0140-1 [Rhodes, Karen])

Comment: This type of energy production should be outlawed. (0146-2 [Grant, Randy])

Comment: INSTEAD OF INCREASING THE FACILITY AT TURKEY POINT, I WOULD HAVE 

YOU CLOSE THE PLANT ENTIRELY. NUCLEAR POWER IS NOT CLEAN POWER 

REGARDLESS OF HOW IT IS SOLD. (0164-2 [Chrissos, H. L. Chris])

Comment: End this dangerous 20th century technology. (0170-1 [Ercole, Steven])

Comment: Finally, I think it's plainly stupid for FP&L and the US NRC to even be thinking about 

this since we shouldn't be further investing in a "dying" industry that's simply outdated and too 

expensive to fund with only government subsidies making it somewhat viable. (0178-3 [Almirola, 

Alejandro])

Comment: Nuclear energy puts ALL OF US AT RISK! Nuclear is OUTDATED & 

DANGEROUS! There are SAFE slternatives! (0199-1 [Moore, Linda])

Comment: NUCLEAR POWER HAS YET TO CONVINCE US THAT IT IS SAFE (0201-2 [Reid, 

Sarah])

Comment: PLEASE FOLLOW THE EXAMPLE OF SANE GERMANY, A LEADER FOR A 

NUCLEAR FREE WORLD. NO MORE NUCLEAR POWER PLANTS !!!!! (0201-4 [Reid, Sarah])

Comment: Germany has shuttered all of their nuclear plants. I don't want another Trenoble.

(0203-1 [McDaniel, Diana])

Comment: I have lived in Miami my whole life and I consider this area a piece of paradise. So 

do the millions of tourists that come to visit. As with any place on our fragile planet, there are 

unforeseen events that could occur that could decimate our area. Some risks, such as 

hurricanes or sea level rise, are unavoidable. (0207-2 [Cleland, Noel])

Comment: Regardless of how hard we try, we cannot make the risk of nuclear catastrophe to 

be 0%, because we cannot anticipate every possible contingency for failure modes that no one 

has considered before. So why take an unnecessary risk when we don't have to, even if it 

seems small. (0207-4 [Cleland, Noel])

Appendix E NUREG–2176 E-516 October 2016
Comment: I was deeply saddened to learn that Florida still relies on antiquated energy 

solutions. (0214-1 [Zerulla, Tanja])

Comment: Every time I think it cannot get worse it does! Nuclear power is not the solution to 

any of the energy problems of this nation or the world for that matter, especially considering the 

problem of disposing of the uranium, which will be radioactive and pose a threat for at least 

10,000 years! Have you no conscious? Do you even care about the children of tomorrow?

(0231-1 [Bonilla-Jones, Carmen Elisa])

Comment: How can you even consider adding more pollution and danger to this nation, which 

you have sworn to, defend? Is the "Corruption" so ingrained that the very lives of not only all 

the Country but also your own families mean absolutely nothing? (0231-3 [Bonilla-Jones, Carmen 

Elisa])

Comment: Just look at the recent nuclear reactor disaster in Japan. Another in a series of 

nuclear disasters without end, the consequences of which are still being felt, still 

happening. Now is the time to think about the damage that is caused with this type of energy 

and the impact it will have on future generations. Will Miami become the next Fukushima? Will 

south Florida become a radioactive wasteland? To allow this to happen is a disaster, the risk is 

criminal. (0243-2 [Duran-Pinzon, Jaime])

Comment: Please stop being soooo stupid. Until the technology of fusion is practicable nuclear 

is just a boondoogle waiting to happen. (0249-4 [Mosher, Paul])

Comment: Nuclear reactors are not the answer especially when there is a liability as noted by 

the International Atomic Energy Authority Data Summary listed below. (0250-9 [Fulks, Anna 

Louise])

Comment: Instead of considering expansion of this dysfunctional and dangerous facility, we 

should be considering how soon the existing reactors can be dismantled. (0252-1 [Van Leer, 

Sam])

Comment: I have spoken to many in the community, and can say that only one out of 

hundreds is in favor of more Nukes. In conversations with elected officials, they are unanimous 

in their opposition. (0252-19 [Van Leer, Sam])

Comment: After the disaster in Japan, I strongly oppose any further expansion of and addition 

to nuclear energy facilities in this country. (0256-1 [Myers, B. J.])

Comment: It is time we stop using nuclear energy now. We have already caused irreversible 

damage to our environment and we must protect the people. You must serve the people and not 

huge corporations. (0257-2 [Padron-Delgado, Blanca])

Comment: Your agency exhibits a blatant disregard for the sanctity of millions of lives and the 

survival of the planet at large! (0259-2 [Lettieri, Tammy])

Comment: it is a matter of GREAT CONCERN to see the further development of extensive 

Nuclear Power production plants within our home living radius in South Florida. (0272-1 [Zuniga, 

Family])

Appendix E October 2016 E-517 NUREG–2176
Comment: If Florida Power & Light Company is as technically proficient as it advertises ... and 

not submit its victims to the excessive cost and more inherent safety risks of additional nuclear 

capacity. (0283-7 [Compel, Jr., Joseph])

Comment: We are opposed to all nuclear power expansion in Florida, as it is unsafe and nonrenewable, taxes limited water supplies. It is unworkable, especially in the age of climate 

change. (0288-15 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] [Matthews, Debbie] [Roff, 

Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Comment: Nuclear is a waste of space. (0291-1 [Vorachek, Mary])

Comment: Too beautiful and delicate a place to screw around with nuclear crap. (0293-1 [Hogle, 

Dick])

Comment: GET REAL! NUKES ARE DEAD, EXPENSIVE AND DANGEROUS, HAVE 

ALREADY IRRADIATED THE EARTH FOREVER, AND HAVE BEEN SUPPLANTED BY 

RENEWABLES. READ THE NEWSPAPERS! (0296-1 [Richardson, Don])

Comment: TOTALLY PHASE OUT NUCLEAR PLANTS, NOT BUILD NEW ONES. (0302-2

[Jezierski, Elisabeth])

Comment: Nuclear power is a technology of the Past, please move on. (0304-1 [Zimmermann, 

John])

Comment: I concur with the above statement and wish to add that as a oat resident of Long 

Island during the debate regarding the nuclear power plants at Shorham and as a NYC resident 

living not too far from Indian point that nuclear power is always a bad idea.... it was then, it is 

now, for so many reasons, among them the entire nuclear waste issue, the whole issue of the 

potential danger of even small accidents and the simple fact that, with the advances in 

renewable energy technology, these albatrosses of the energy industry are no longer needed. 

(0324-1 [Gibson, David])

Comment: Nuclear energy use should be slowed down and eventually eliminated--not 

increased, especially in a sensitive area next to a national park. (0326-1 [Earnshaw, Shinann])

Comment: nukes are bad idea anywhere just look at fukushima (0327-2 [Anonymous, 

Anonymous])

Comment: I don't want any more nuclear energy. Nuclear energy is not safe and it's right in our 

back yard. (0329-2 [Baumwall, Douglas])

Comment: No, we don't need any more nuclear power plants. They use too much water and 

pollute the atmosphere and environment. The long chain of events to provide the fuel pollutes 

and emits C02 (mining, etc) Cleanup after an accident is paid by taxpayers(what a business 

plan). (0336-1 [Anonymous, Anonymous])

Comment: The NRC cannot be trusted, they do what the money masters tell them. It's all 

about the money, and a lot of it comes from taxpayers. Result -"electricity too cheap to meter"? 

No, it was another lie. Higher electricity bills will be the norm, along with more doses of radiation 

to the kids and grand-kids. (0336-4 [Anonymous, Anonymous])

Appendix E NUREG–2176 E-518 October 2016
Comment: It is my opinion that these planned nuclear reactors are dangerous. (0337-1 [Philips, 

Sally B.])

Comment: I will say that nuclear power should not be used anywhere in the United States. And 

certainly not in Florida, a state that has had more than its share of severe hurricanes. (0339-3

[Provost, Allan])

Comment: Not in my backyard thank you. (0346-1 [Anonymous, Anonymous])

Comment: No more nuclear plants. (0348-1 [Ward, Richard])

Comment: Not in my backyard. (0349-5 [Oliva, Vivian])

Comment: This is such a bad idea on so many levels. First of all, a nuclear power plant is an 

accident waiting to happen and when it does you can't fix it. Ask the folks in Fukushima -oh 

that's right, there aren't any folks in Fukushima because the nuclear accident made the town 

and surrounding areas unsafe to live.That should be enough for anyone with common sense, 

but greed is blind. (0353-1 [Royce, M.])

Comment: South Florida is a beautiful place that is envied and visited by many around the 

world. Placing it at increased risk of environmental harm and nuclear disaster is a travesty, and 

being in denial and telling ourselves a disaster can't happen here is not wise and not necessary.

(0356-6 [Shlackman, Jed])

Comment: The two nuclear plants are a bad risk in light of over 50 years of history on the use 

of nuclear power. Over half a century of experience throughout the world indicates nuclear 

energy is not the answer. It is the most expensive, the most delayed, and dangerous. No 

nuclear plant has yet been built that is not over budget and behind schedule. It is also carbon 

intensive in uranium mining, uranium processing where fracking is used just as for natural gas, 

building the nuclear plant, and transportation of uranium to and used radioactive waste away 

from the nuclear plant. (0366-10 [Griffith, Ed and Harriet])

Comment: No No NO absolutely not...don't you dare add more water destroying elements to 

this ridiculous Grid ... we need to dismantle to begin with ...We must stop the stupid Idea of 

Giant Generation and pushing down wires for miles and miles to get to end user and demand 

you spend the exact same BILLIONS OF DOLLARS on Distributed Generation @ point of use 

like Edison envisioned to begin with.... (0369-1 [Polk, J. D.])

Comment: Nuclear is an outmoded power source that would be economically non viable 

without massive subsidies. (0371-4 [Haffmans, Edmund])

Comment: We should be talking about a planned phase out of all nuclear power reactors NOT 

expansion. (0380-2 [Anderson, Vaughn])

Comment: Where does it stop? When does it stop? Stop and think, where and when, does it 

STOP. Does it really have to be when nothing is left? STAND UP. (0387-1 [Morgan, Carol])

Comment: PS before you take this disastrous course of action given the information above, 

read up on the consequences of nuclear energy gone sour at San Onofre, California. This site is 

even more vulnerable ! (0388-1 [Andersen, Paul])

Comment: No expanding nuclear power!!!!!!!!!!!! (0393-1 [Bereczki, Patricia])

Appendix E October 2016 E-519 NUREG–2176
Comment: WHEN WE FIGURE OUT HOW TO SAFELY DISPOSE / DEACTIVATE NUCLEAR 

MATERIAL SO THAT IT DOESN'T REMAIN TOXIC FOR THOUSANDS OF YEARS, MAYBE 

THEN NUCLEAR POWER WILL MAKE SENSE. UNTIL THEN--NOTHING! NO NUCLEAR 

POWER PLANT SHOULD BE COMMISSIONED OR ALLOWED TO CONTINUE TO 

OPERATE. ANYWHERE IN THE WORLD, LET ALONE THE USA! (0412-1 [Davis, S. K.])

Comment: At this point in time, we should be looking at shuttering nuclear power plants, not 

expanding them. Right here in Illinois, we are seeing Exelon looking for massive bailouts just to 

keep nuclear energy power plants profitable. Yet they, Exelon, has no clue what to do with our 

tremendous spent fuel rod stockpile. (0419-1 [Juras, Randy])

Comment: Nuclear power has never been safe. How many examples do we need? Chernobyl 

is a continuing train wreck in progress; TMI was a disaster; and words fail me to describe the 

horror of Fukushima. If you think that disaster is over, then you most definitely need to do a little 

research. For humanity's sake don't enlarge the Turkey Point plant, shut it down! (0431-2 [Hicklin, 

Mary])

Comment: I DON'T THINK WE NEED TO BE EXPANDING NUCLEAR POWER PLANTS 

ANYWHERE. WE SHOULD BE CLOSING DOWN THE ONES WE HAVE. THEY ARE VERY 

DANGEROUS AND THERE IS NO GOOD SOLUTION WHAT TO DO WITH THE NUCLEAR 

WASTE WHEN THEY ARE NO LONGER IN USE. (0432-1 [Olson, Diane])

Comment: No to any more nuclear anything. We are not having a good time with this 'cool' 

energy product called nuclear energy. It causes death. It causes pollution that an last for over a 

quarter of a million years. That is a pipe dream that needs to wake up. (0442-1 [Mosca-Clark, 

Vivianne])

Comment: Please don't put them here & perhaps no where is really good; (0455-2 [Hardin, 

Lillian])

Comment: Our country does not need any more nuclear expansions. We have enough to 

worry about. No more! No more! (0462-1 [Bubb, Ken])

Comment: WHY would anyone want to expand nuke power after the Man Made Disaster at 

Fukushima..?? It is time to stop the nuke power and get to safe alternatives!!! (0464-1

[Farnsworth, Stu])

Comment: Nuclear power is outdated, why would we want to expand ? (0468-1 [Nelson, Wendy])

Comment: Let's push to other sources and conservation. Nuclear power CANNOT be 

managed for 50 more years, we have no storage now. And the idea that we need another 

nuclear plant is illogical. (0480-2 [Simmerman, Scott])

Comment: According to science; anything radioactive is NO GOOD. According to science; 

anything radioactive is harmful to everything-be it human, animal, vegetation and even the soil, 

water and air. There is nothing good about anything radioactive; not even all the profits the few 

who profit from it. (0481-1 [Szabo, Liz])

Comment: Please do not let any further plants be built that will add radioactive harm to the 

planet. Instead work at phasing out plants that deal with radioactivity[.] (0481-2 [Szabo, Liz])

Appendix E NUREG–2176 E-520 October 2016
Comment: Nuclear energy is not a sustainable resource as one day we will run out of raw 

materials, and it cannot be considered clean energy until a safe disposal method for nuclear 

waste is implemented. (0482-1 [Campbell, Grant])

Comment: Are we really supposed to forget Fukushima? Are we supposed to pretend the 

ongoing disaster that is Hanford? I'm sorry, but heads in the sand is not acceptable. (0496-1

[Reed, Jennifer])

Comment: We have ample evidence of the danger of nuclear reactors from the disaster in 

Japan a few years ago. That reactor is still pumping nuclear waste into the ocean. Nuclear 

power needs to be phased out, not ramped up. In particular, nuclear power reactors need to be 

kept away from land Americans own in common--our national parks. (0498-1 [Bratcher, Suzanne])

Comment: No additional nuclear reactors should be built at Turkey Point and plans should be 

made to close existing nuclear power generating facilities in order to protect surrounding 

populations and their progeny. (0511-2 [Draper, Lonnie M.])

Comment: There is no safe way to manage nuclear power generation and therefore we must 

not build more reactors and must dismantle our existing facilities in favor of safe, renewable 

forms of power production. (0511-5 [Draper, Lonnie M.])

Comment: Those that promote and endorse nuclear fission time-bomb plants are misanthropic 

psychopaths. Nuclear fission technology is more than insane. It is pure raw evil. It is violation 

that even Satan would not do. (0513-2 [Roehl, Richard Ralph])

Comment: Stop this ! Nuclear power is proven to be more of a liability than ever thought. 

Disagree ? Then make them buy private insurance NOT underwritten by Uncle Sugar Daddy.

(0521-1 [Socie, Robert])

Comment: We do not need more nuclear power period. (0530-1 [Mccroskey, Carol])

Comment: Nuclear power is not the way towards a sustainable future. (0553-2 [Punnett, 

Daniela])

Comment: I strongly oppose of the use of nuclear energy due to the inability to dispose of 

waste. (0558-1 [Barnes, Janice])

Comment: NUCLEAR POWER IS POISON and cannot co-exist in the same space with life on 

earth. (0561-1 [G., Ambriel])

Comment: A total of 17,155,535 people live within 19 miles of a nuclear plant. I guess that's 

still not enough for you nuclear madmen to reduce earth's population. Documentaries: Into 

Eternity (A Nuclear Waste World)"Documentary on the idiocy of the Atomic Age and the long 

term ramifications of storing nuclear waste. 

https://www.youtube.com/watch?v=SBrMzwSdSI. The Biggest Nuclear Operators In The United 

States: http://www.investopedia.com/stockanalysis/2011/the-biggest-nuclear-operators-in-theunited-states-duk-pgn-so-exc-etr-dnee0328.aspx. The Truth about Nuclear Waste Disposal 

(Full Documentary) https://www.youtube.com/watch?v=5mthzaOyiEO. (0561-4 [G., Ambriel])

Comment: [N]uclear power is too expensive relative to renewable energy sources, and 

generates wastes that remain lethal for tens of thousands of years and which we have no 

means of permanent and safe disposal. With these considerations, NO nuclear plant anywhere 

Appendix E October 2016 E-521 NUREG–2176
makes any sense, beyond the obvious problems with the current site in question. (0567-2

[Cohen, Howard])

Comment: After the Fukishima disaster it quite apparent that ALL nuclear power plants should 

be immediately terminated. Florida is so vulnerable to extreme weather threats. Radiation is 

increasing day by day on our planet. Alternative forms of power are available and so there is no 

excuse for not supporting them except the greed of the powers that profit from nuclear power.

(0576-1 [Williams, Penelope])

Comment: I agree with the general message. I especially don't want another nuclear power 

plant in this country. they can be very dangerous. (0586-1 [Stamps, Gail])

Comment: Save humanity. (0587-2 [Glasshof, Wendy])

Comment: NO NUKES! The risks are unacceptable and unnecessary. (0589-1 [Zook, Caryl])

Comment: On 9/19/14, a UBS report called nuclear power plants the "the DINOSAUR of the 

future energy system" and Amory Lovins, a physicist and chief scientist at the Rocky Mountain 

Institute, said that nuclear power was an "OBSOLETE technology": "Banking giant UBS calls 

the big, slow, lumpy, expensive coal and nuclear plants "the dinosaur of the future energy 

system: Too big, too inflexible, not even relevant for backup power in the long run." Such 

obsolete technologies are less at risk from regulatory mandates than from market defeat by a 

swarm of agile competitors that their promoters don't even recognize." It is at 

http://www.forbes.com/sites/amorylovins/2014/09/19/micropowers-quiet-takeover/2/. Nuclear 

power is clearly an obsolete and old technology. Nuclear power is clearly an energy of the past. 

Nuclear power is not where the overwhelming innovation in new energy technology is occurring.

(0592-4 [Brexel, Sr., Charles])

Comment: Aside from the possible impact to sensitive parks and refuges, I don't think more 

nuclear reactors is the right solution. (0594-3 [Rapuano, Shannon])

Comment: Nuclear energy is NOT carbon-emission-free.Nuclear power plants release 90 140 

g of C02 per kwh AND, each nuclear power plant releases massive amounts of Carbon-14 

which is CONVERTED TO C02 in the atmosphere! Nuclear energy = Carbon14 = C02 = 

Climate Change. (0603-1 [Anonymous, Anonymous])

Comment: This said, we should not build any nuclear reactors anywhere ever again. Whoever 

wants to build more of them should be required to live next to a nuclear waste processing facility 

and final waste disposal site for the next 250,000 years. (0607-1 [Veit, Eberhard])

Comment: NO MORE NUCLEAR POWER PLANTS! (0609-1 [Khajeh-Noori, Jeri])

Comment: No one has figured out how to make nuclear plants REALLY safe. We don't need 

them! (0627-3 [Dolben, Hollis])

Comment: You are INSANE to build more nuclear power plants!! (0628-1 [Anonymous, 

Anonymous])

Comment: We don't need atomic bombs - nuclear plants will do the job slowly and effectively.

(0632-3 [Moll, Wolfgang])

Appendix E NUREG–2176 E-522 October 2016
Comment: If you care about our earth and this comer of the world and co-creating a 

safe/healthy future for our children you will reconsider this and say no to building nuclear 

reactors. (0634-2 [Jacobs, Leslye])

Comment: You have the opportunity to at least stop the growth of nuclear power. Please, no 

more nuclear reactors. (0643-2 [Joannou, Jr., Benjamin])

Comment: No more nuclear power plants. They do harm to the environment and people while 

being propped up monetarily by taxpayers. It is a big money scam. Nobody benefits except the 

big money players. And why pass on billions of dollars in cleanup/waste management costs to 

our grandchildren and great-grandchildren and great-great grandchildren. (0645-1 [Anonymous, 

Anonymous])

Comment: Nuclear power is DANGEROUS. (0656-1 [Zhivelev, Leon])

Comment: Nuclear energy is incredibly dangerous to our planet. (0657-2 [Hartmann, Donald])

Comment: nuclear is dangerous, plus too much nature near by.. (0664-2 [Alvarez, Chad])

Comment: The building of the reactors would leave a huge carbon footprint. (0666-2 [JensRochow, Steve])

Comment: Nuclear power comes with a dangerous byproduct, as well as the dangers of 

operating a nuclear facility. Although the risks have been mitigated with many safety features, 

the reality is there are still possibilities of a reactor failure due to human error, natural disasters, 

or even terrorism. (0677-2 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: The $20 billion investment in two new reactors would be better spent developing a 

decentralized energy network that would be less prone to the failures associated with nuclear 

energy generation. (0677-4 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: Not in our backyard[.] (0677-8 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: [N]ot in anyone's backyard! (0677-9 [Chiszar, Benjamin J.] [Jacobs, Lee] [Klopfer, Carol])

Comment: Use of Nuclear energy is foolish, worse than fossil fuel. We still have no safe way of 

disposing of the toxic radioactive waste. It is insane to even consider expanding it. (0683-1

[Thompson, Muhammad])

Comment: Any more nuclear facilities in the world are too many. Nuclear reactors should be 

de-commissioned, not added to. How many more uninhabitable areas of the world must be 

created before the insanity stops? Nuclear never was nor can it ever be environmentally neutral 

nor safe. (0697-1 [Dulicai, Linda])

Comment: South Florida needs a non-nuclear source that does not pose grave health risks.

(0701-1 [Whitlock, Catherine])

Comment: Regarding "manmade" "artificial" "nuclear radiation"--A great man once said --

>"there is no amount of radiation so small that it has no ill effects at all on anybody. There is 

actually no such thing as a minimum permissible dose. Perhaps we are talking about only a very 

small number of individual tragedies the number of atomic age children with cancer, the new 

victims of leukemia, the damage to skin tissues here and reproductive systems there perhaps 

Appendix E October 2016 E-523 NUREG–2176
these are too small to measure with statistics. But they nevertheless loom very large indeed in 

human and moral terms. 

Radiation, in its simplest terms figuratively, literally and chemically is poison. Nuclear explosions 

in the atmosphere are slowly but progressively poisoning our air, our earth, our water and our 

food. And it falls, let us remember, on both sides of the Iron Curtain, on all peoples of all lands, 

regardless of their political ideology, their way of life, their religion or the color of their skin. 

Beneath this bombardment of radiation which man has created, all men are indeed equal." 

~John F. Kennedy, 2 April 1960, Wisconsin. (0705-1 [Anonymous, Anonymous])

Comment: Ongoing TRIPLE MELTDOWNS and the continuous FALLOUT from Fukushima, (4 

plus years), should be reason enough to STOP this technology dead in it's tracks before it 

damages any more of our planet Building more Nuclear Plants is a BAD idea. The overall RISK 

to all living things is just too great. It's proven, containment is a fallacy. [Commenter followed 

with a quotation by E.F Schumacher, 1973] (0708-1 [Aha, Chas])

Comment: No more nukes they are dirty, making the fuel is dirty, and the is no safe storing the 

deadly waste. (0715-1 [Anonymous, Anonymous])

Comment: Nuclear energy is global warming, should not be in the future. (Nuclear Energy As 

A Direct Cause Of Global Warming, Acid Rain, Acid Oceans, Extreme Weather, And Super 

Storms http://agreenroad.blogspot.com/2013/12/nuclear-energy-as-direct-cause-of.html) (0719-1

[Anonymous, Anonymous])

Comment: Nuclear energy is expensive, dirty, dangerous and toxic (Nuclear Power; 

EXPENSIVE, Dirty, Dangerous And Toxic; via@AGreenRoad 

http://agreenroad.blogspot.com/2012/1Ofnuclear-power-expensive-dirty-dangerous.html)

(0719-2 [Anonymous, Anonymous])

Comment: Not nuclear. (0721-1-3 [Rodriguez, Jose Javier])

Comment: I have probably another 30 years to live and I think a lot about things going on on 

our planet. I am an American citizen since 2000 and I'm very proud to be an American citizen. 

My county originally was Belgium, and I go back every year to visit my mom, my brothers and 

sisters. In Belgium we closed all the coal plants 20 years ago. Coal, we all agree, I hope, has to 

go. We all have morally a carbon footprint. We are stewards for our planet and we are 

responsible for generations to come. We cannot think about greed and money. In Belgium we 

don't have as much sun as here. Nuclear power plants are to go. We have to think about the 

future. We are closing all our power plants. There is only one left near Antwerp, it's going to 

close. We have solar mushrooming where my brother just told me, he gets money back from his 

electric company, from his FPL. Not that we request that. (0721-18-1 [Bernabei, Catharina])

Comment: What I would like FPL to do, jobs will be there if you really think morally. You know 

how as a human being we have a gut feeling. Animals have that. We are on the top of the 

species list. My gut feeling is this is wrong. Nuclear power plants are wrong, all over the world. 

There's something tremendously wrong. Fukushima is an example, but it's wrong. (0721-18-2

[Bernabei, Catharina])

Comment: At the risk of reiterating some of our complaints, I will say that nuclear power should 

not be used anywhere in the United States and certainly not in Florida, a State that has more 

than its share of severe hurricanes. (0721-26-5 [Koenigsberg, Linda])

Appendix E NUREG–2176 E-524 October 2016
Comment: One accident, equipment malfunction, operator error, or terrorist attack at a nuclear 

plant could literally mean the end of life on earth. And if Fukushima didn't convince you, you still 

think that a disaster couldn't happen at Turkey Point, think about the little o-ring on the 

Challenger. We can never forget that here in Florida. There's no way to guarantee 100 percent 

safety when using this technology. And when it comes to materials that remain deadly 

dangerous for tens of thousands of years, longer than all of human history, anything less than 

100 percent safety cannot be considered safe. We humans are not infallible and neither is 

anything we produce. See? That proves it. Nor can we control or predict the forces of nature, as 

much as we might pretend that we can. This means that nuclear plants cannot --simply cannot 

be guaranteed to be safe. And when it comes to nuclear materials, anything less than 100 

percent safety is not good enough. Nuclear plants are so dangerous that even Wall Street won't 

invest in them, and they'll in invest in anything, no matter how risky. (0721-28-3 [Wilansky, Laura 

Sue])

Comment: We are opposed to nuclear power because it is neither clean nor renewable.

(0721-30-2 [Ullman, John])

Comment: We also learned that while we want to reduce carbon, and some are claiming that 

nuclear is the way to do that, falsely. (0721-30-4 [Ullman, John])

Comment: I think the nuclear industry is a Neanderthal industry, it's done with. The economy 

doesn't prove it's the right thing to do at this point. (0723-3-4 [Star, Priscilla])

Comment: You have enough nuclear now. I mean, you've got this dog. It's deadly, it's not 

clean, it's not safe, it's harming the environment. And if you're told otherwise you're being fed 

lies. (0723-3-6 [Star, Priscilla])

Comment: [D]evelopment of adequate national and global policies to curb energy overuse and 

unnecessary economic growth. A resolution of significant safety issues inherent in reactor 

operation, disposal of spent fuels and possible diversion of nuclear materials capable of use in 

weapons manufacture and establishment of adequate regulatory machinery to guarantee 

adherence before drawing conclusions. (0723-5-2 [Teas, Jim])

Comment: Furthermore, the Sierra Club supports the systemic reduction of society's 

dependence on nuclear fission as a source of electric power and recommends a phased closure 

and decommissioning of operating commercial nuclear fission electric power reactors. (0723-5-3

[Teas, Jim])

Comment: You think nuclear is something new? The nuclear technology that these guys are 

going to install and they're running is exactly the same that was designed at the University of 

Chicago in the 1940s to build an atomic bomb. It's exactly the same. Take U235, split it, you get 

krypton, barium, cesium, ruthenium, it throws off neutrons. It's a small bomb running off in slow 

motion. I'm not saying it's going to become an atomic bomb but that's the technology. That's 

what nuclear is, splitting U235. (0723-9-6 [Schwartz, Matthew])

Response: These comments provide general information in opposition to nuclear power. They 

do not provide any specific information related to the environmental effects of the proposed 

action. No changes were made to the EIS as a result of these comments. 

Appendix E October 2016 E-525 NUREG–2176
Comment: Already there are issues keeping the reactors cool and until the technology makes 

these safer for the environment and those that live around the plant, I strongly oppose any more 

nuclear plant additions. (0006-2 [Faber, Davenie])

Comment: I am against any new development of nuclear plants in South Florida. With the new 

technologies being developed by Tesla, GE and others there is no need to increase the dangers 

associated with radiation (ie. Chernobyl and Fukushima, Japan). Also our proximity to Cuba with 

their ties to Venezuela and Russia make this a verrrry bad choice. Please think of our 

Grandchildren and not corporate profits. How ever much the lobbyists offer you, it can't be worth 

your reputation. (0017-1 [Gross, Gary])

Comment: Nuclear power plants around the world have caused serious loss of life and 

permanent injury to millions of people from Chernoble to Fukashima. The waste from these and 

other nuclear plants is still alive and decaying at a rate to disappear perhaps in a few thousand 

years or escape into the atmosphere. We must learn our lessons from history. (0021-1 [Silver, 

William])

Comment: I do not want South Florida to have "antiquated and expensive nuclear technology 

from last century..". (0127-5 [Cusidor, Teresa])

Comment: Just because nuclear power is "clean" doesn't mean it's safe, it's dangerous. Think: 

Fukushima. (0189-1 [Forbes, J.])

Comment: I think we need to take a lesson from the Fukushima disaster and opt for safer 

forms of energy. (0626-2 [Miller, Nyana])

Comment: With nuclear contamination in Japan as one example of ever cleaning up the mess 

a nuclear power plant has made. We must look to natural resources for our planet to survive.

(0709-2 [Cummings, Frank])

Response: These comments and the attached statement provide general information in 

opposition to nuclear power. Some comments cite the Fukushima accidents as evidence that 

nuclear power is unsafe. They do not provide any specific information related to the 

environmental effects of the proposed Turkey Point Units 6 and 7. Issues related to safety are 

beyond the scope of the environmental review and will be evaluated in the NRC staff's safety 

evaluation report for the proposed units which is tentatively scheduled for publication November 

2016. 

Comment: Alternative power sources, such a solar, wind and waves, are being successfully 

used elsewhere. We do not want more nuclear facilities adjacent to our growing urban area.

(0093-3 [DuPriest, William Robert])

Comment: We need to be investing in decentralized power. This would provide a much greater 

level of redundancy, and meet the local power needs. If we were making better use of 

renewable energy (solar, wind, tide, etc.) at the neighborhood level, we could start to envision a 

state that doesn't need nuclear plants and their associated nuclear waste (have we found a 

place to permanently put the waste yet?). Other nations around the world are already working 

on a new paradigm, so we need to focus our efforts on catching up to leading edge technology 

instead of continuing with an obsolete model. (0207-5 [Cleland, Noel])

Comment: NUCLEAR POWER PLANTS' IMMORTAL WASTES ARE CAUSING HUGE 

STORAGE PROBLEMS ALREADY. IT'S INSANE TO BUILD MORE. INSURANCE 

Appendix E NUREG–2176 E-526 October 2016
COMPANIES WON'T INSURE THESE MONSTROSITIES BECAUSE THEY KNOW THE 

RISKS. FRESH WATER IS ALREADY AT RISK, SPECIES ARE AT RISK AND THIS POWER 

PLANT IS IN AN IRREPLACEABLE LOCATION. NOW IS THE TIME TO DEVELOP GREEN 

ENERGY, NOT PROVIDE ANOTHER OPPORTUNITY FOR A PRIVATE POLLUTING

INDUSTRY TO FORGE AHEAD. (0303-1 [Pikus, Barbara])

Comment: The time for nuclear power expansion is over. We should no longer permit building 

of any additional nuclear plants and instead transition to solar and wind and other sustainable 

systems. (0309-1 [Lundholm, Mark])

Comment: There are plenty of other alternative ways to create energy that are way less risk of 

severely damaging or completely destroying the environment around it. Please really look into 

the aspects to keep something like a nuclear plant up and running compared to any alternative 

energy method & the risk if something catastrophic were to happen, with irreplaceable damage 

to the environment and the people/inhabitants that will suffer. (0367-1 [Rosenberry, Casara])

Comment: Creating more nuclear power reactors is a bad idea anyway since we don't know 

how to safely manage radioactive waste, don't know where or how to adequately store it, it 

creates incredibly dangerous risks from accidents, and we don't need it since efficiency, wind, 

and solar can meet our energy needs if investment is redirected toward those sensible options.

(0370-5 [Vayu, Satya])

Comment: I suggest that we may want to consider renewable wind or solar energy before we 

head down the path of more dangerous nuclear power plants. (0424-1 [Corey, Sheffield])

Comment: Why are we not phasing out nuclear energy and going green? Nuclear is no longer 

an energy option and must be closed down. (0529-1 [Brandariz, Anita])

Comment: Stop dragging your feet and move to energy that is safer. (0529-3 [Brandariz, Anita])

Comment: We do NOT need more nuclear reactors. We need CLEAN GREEN ENERGY!!!!!

(0568-1 [Goldberg, Laura])

Comment: No more nuclear plants - close down existing plants and develop solar and wind 

instead. (0577-1 [Cook, J.])

Comment: There are other ways and places to produce energy. Consider carefully what you 

are doing and do not impose 6 & 7 and its consequences on this and future generations. (0598-4

[White, Barry J.])

Comment: Personally, I would not even want to live near ONE, let alone TWO, nuclear 

reactors. This is hazardous and LETHAL material to ALL LIFE. Power should be provided by 

natural, RENEWABLE and, especially, SAFE sources. THIS is what power companies SHOULD 

be working on, NOT toxic power that will further pollute our Earth. (0648-1 [Fray, Antje])

Response: These comments identify general concerns about alternative energies being used 

instead of the proposed Turkey Point Units 6 and 7. They do not provide any specific 

information related to the environmental effects of the proposed action. Alternative energies 

including wind and solar were evaluated and are described in Section 9.2 (Energy Alternatives) 

of the EIS. No changes were made to the EIS as a result of these comments. 

Appendix E October 2016 E-527 NUREG–2176
Comment: Attached is a response to the new Turkey Point Nuclear Reactors [Commenter 

attached a file authored by the Indigenous Elders and Medicine Peoples Council, a statement 

on Fukushima with file titled "COUNCIL_FUKUSHIMA_STATEMENT_OCT_2013[1].pdf"].

(0255-1 [Larsen, Shannon])

Response: This comment and the attached statement provide general information in 

opposition to nuclear power. Some comments cite the Fukushima accident as evidence that 

nuclear power is unsafe. They do not provide any specific information related to the 

environmental effects of the proposed Turkey Point Units 6 and 7. Issues related to safety are 

beyond the scope of the environmental review and will be evaluated in the NRC staff's FSER for 

the proposed units which is tentatively scheduled for publication in November 2016. 

E.2.36 General Comments in Opposition to the Existing Plant or the Applicant 

Comment: the NRC made a big mistake in allowing FPL to expand its capacity and to allow it 

to continue in operation after its original design period expired. this has proven to already be 

catastrophic: the cooling canals now do not work at this increased capacity. and s. Florida will 

be faced with either 1) black outs in peak demand summer months 2) or letting FP&L use our 

scarcest resource, more water to cool the expanded facility. already this year, one of the 

reactors was taken off line for some mysterious reason. (0055-2 [Roedel, Kitty])

Comment: I was at a meeting at audubon house years ago when you told us that if you put gas 

turbines into turkey point that you would not do any further nuclear. You are liars, something we 

all knew but now it is plainly obvious. (0072-1 [Logan, Brian])

Comment: As a resident of North Key Largo for 27 years, I am living under the threat of an 

accident at Turkey Point, whether it be from a hurricane, operating accident or age related. Just 

the operation of the existing facility has stressed the fresh water supply. The heated water has 

made a marked affect on marine life. (0096-1 [Roberts, Linda])

Comment: The existing reactors at Turkey Point are aging, and have been questionably 

managed and maintained. Time and time again, they have bent and outright broken regulations 

and have put the local community at risk! Their cooling mechanism, a series of manmade 

waterways, is overgrown with algae or similar organism, causing significant overheating of the 

water. They have demanded a new ongoing source of water from our local aquifer to reduce the 

temperature. We are, as the result of their actions, facing a huge plume of salt water intruding 

into the fresh water supply, contaminating many wells used by other entities for other purposes. 

We are already facing problems created by the existing nuclear reactors. (0115-2 [Trencher, 

Ruth])

Comment: Florida Power & Light is a monopoly, but is intended to serve the public. FPL has 

not been responsive to the needs and concerns of our community, instead, has chosen to 

bulldoze their way through our community in their effort to maximize their profits at our expense.

(0115-9 [Trencher, Ruth])

Comment: Why does FPL dictate all energy power. (0149-5 [Nelson, Joyce E.])

Comment: This monopoly has bullied us all. Their only concern is profit, so they buy the 

influence that guarantees their revenue. FPL and other power monopolies have exerted 

massive force, using $millions to ensure that the Public Service Commission (PSC) and other 

levels of government are populated by those who put corporate profits first, and public safety 

Appendix E NUREG–2176 E-528 October 2016
and benefit last. FPL has been granted authority by the PSC to impose fees for Nuclear Power 

on every user account. (0252-17 [Van Leer, Sam])

Comment: I believe that this expansion of the reactors at turkey point.....will increase the risk 

we all ready have we a plant that has been cited various times every year for the last 10 years 

for oversight and for defective equipment. (0494-2 [Tamargo, Jorge J.])

Comment: I had a friend who worked for FPL and about 25 years ago told me it once almost 

melted down. They have two large control rooms like we saw in the China Syndrome movie and 

a third smaller control room, They were doing some work in the room in the radioactive section 

of the reactor and a crane dropped something heavy on a pipe that had all the wires from the 

three control rooms to the reactor and shorted out all the wires so they had no control over the 

reactors and the only thing that saved it from meltdown was a system inside the reactor that 

when certain things melted it automatically flooded it or something turning it off, But it came very 

very close to melt down ! But they managed to keep it out of the news completely !! They 

advertised and hired a lot of one time employees I think they call them jumpers ? Who went into 

the hot section for only the maximum allowed time of a couple hours wearing radiation suits and 

did repairs! (0505-2 [Buyea, Thomas])

Comment: No to FPL. (0660-3 [Sanchez, Sergio and Irma])

Comment: But I do want to say corporate responsibility. This EIS, if you're not considering the 

current issues on the ground then what are we talking about? (0721-10-1 [Reynolds, Laura])

Comment: And what I've seen here is that the operational excellence or the operational reality 

of FPL has not been brought into the EIS. And that's a serious problem. The operational reality 

is why you want up-rating. And now you're reducing monitoring standards for that because of 

their operational a/k/a excellence or the reality that they've met the protocols listed out in the 

2009 agreement. Implementing an EIS before that and not realizing that there's been quality 

control issues in the time of the EIS initiation that would have weighted a quality control 

document in any other industry, whether it be medical -- you know, I've had FDA letters coming 

out of the ears of customers because they didn't have a voice basket in the right place. And 

here we are having steam leaks, value fractures, shutdowns. Serious issues here. And those 

weren't even weighted in the EIS? While they're having an up-rating processing of reducing 

monitoring standards for GMP, you know, good manufacturing practices. It starts to fall apart in 

my mind, and I'm looking at it from just a manufacturing quality management standpoint.

(0721-34-1 [Gomez, Albert])

Response: These comments express opposition to the existing units at the Turkey Point site or 

to the applicant. They do not provide information related to the environmental review for the 

proposed action. No changes were made to the EIS as a result of these comments. 

Comment: Anyone reading the local paper here in Miami knows that FPL's recent problems 

concerning reactor cooling water temperatures do not bode well for the future of the existing 

plant and serve as a strong warning against future nuclear construction in this area. (0057-2

[Neway, Roberta])

Comment: The NRC should, through the EIS process, identify opportunities to limit or remove 

environmental damage already being caused by the presence of Turkey Point 3 & 4. Clearly the 

1960's "technology" of thousands of miles of cooling canals is no longer a pragmatic or 

functional solution to the demands of the existing power plants and has been shown to have 

Appendix E October 2016 E-529 NUREG–2176
significant deleterious impacts on the immediate environment and is damaging the ecological 

health of Biscayne National Park. Even if two years of water diverted from the National Park 

temporarily cools the Turkey Point canal system, it is evident that the hyper-saline conditions 

were present before the recent uprate and are largely responsible for accelerating salt water 

intrusion into the Biscayne Aquifer -Miami-Dade's only drinking water source. That same water 

source that is being impacted by Turkey Point 3 & 4 is the planned "backup" water for Units 6 & 

7, further impacting the availability of fresh water flows to the National Park. (0172-7 [Cava, 

Daniella Levine])

Comment: Turkey Point's operations are already impacting Biscayne Bay's habitat, water 

quality, and salinity, which are vital for the health and productivity of the bay. (0284-4 [Lopez, 

Josie])

Comment: FPL has already failed to maintain sufficient cooling capacity in the canals it 

maintains to service the plant it has. now[.] (0341-2 [Daniels, Bonnie])

Comment: The ones already built are damaging the Bay and need to be better managed 

before there are any more proposed. (0667-2 [Brown, Bradford])

Comment: Please include the below Miami Herald article just published 3 days ago and read 

the whole article referenced in the last line. [Commenter attached a copyrighted Miami Herald 

newspaper article] (0718-4 [Buechler, Jerry])

Comment: Before Unit 1 was built at Turkey Point, in the eastern part of the Everglades, the 

salinity of water there was the same as the rest of Everglades is today, about 400 practical 

salinity units, PSU; 400. Under 500 is fresh water. Today, after 55 years of producing energy for 

Florida, Georgia and the rest of the nation the salinity at Turkey Point is 35,000 PSU, the same 

as sea water. That's from 400 to 35,000. And in the cooling canals it reached 95,000 PSU in 

2014. Salt water, which used to begin a few miles offshore at Turkey Point, has now intruded 

inland four miles due to the now hypersalinity, due to the energy production on the site.

(0721-12-1 [White, Barry J.])

Response: These comments express opposition to the existing units at the Turkey Point site or 

to the applicant. They do not provide information related to the environmental review for the 

proposed action. The proposed units will not use the cooling canals. No changes were made to 

the EIS as a result of these comments. 

E.2.37 Comments Concerning Issues Outside Scope - Emergency Preparedness 

Comment: Also we wonder how the Citizens Safety and Protection agency feels about this and 

what would happen if they were contacted by all of us who will be affected if, God forbid, 

anything were to happen at Turkey Point. (0040-3 [Pareto, Rolando and Marlene])

Comment: The question of whether or not Miami Dade County will ever experience another 

Hurricane Andrew or similar natural disaster is not a question of "if" but "when". Clear, 

unobstructed and safe evacuation routes are paramount to the safety of the residents of MiamiDade County. (0044-6 [Commenters, Multiple])

Comment: I live approximately 7 miles from Turkey Point and I have for years wondered what I 

would do in the event of a "melt down". Unfortunately, given my proximity, there really is nothing 

I CAN do. (0045-2 [Johannsen, Christian])

Appendix E NUREG–2176 E-530 October 2016
Comment: south florida has no feasible alternatives to mass exodus in case of a nuclear 

accident at the aged turkey point. yhe population explosion in 40 years has left all of us 

vulnerable to this accident waiting to happen. (0055-8 [Roedel, Kitty])

Comment: The Turkey Point plant is already the largest generating station in Florida, in close 

proximity to a relatively large population and no feasible evacuation plan in an emergency. 

Through most of the day, the main artery (US-1) is already bumper to bumper. Further 

concentrating the risk in that area is irresponsible and increases the danger to the surrounding 

cities and towns. (0187-2 [Meyer-Steele, Shawn])

Comment: I wonder if our cities have any type of plan in place if there is a leak,terrorist 

attack,or damage from a Hurricane. (0223-2 [Robbin, Valerie])

Comment: FPL mailed us all a book in Palmetto Bay called be prepared. It shows evacuations 

routes by FPL if sirens sound in Palmetto Bay. When I call Miami Dade they have no idea of my 

assigned shelter. I called Palmetto Bay they said take old Cutler and go North to South Miami. 

We are to listen to radio and turn off air and stay sealed in house for how long? We are NOT 

ready for units we have now. (0234-1 [Samole, Sharon])

Comment: Had an additional threat emerged, we could have had a Fukushima-level event in a 

densely populated American city. With the whole community reeling from massive infrastructure, 

transportation and communication damage from the Hurricane, rapid evacuation would have 

been impossible. I was here, I know what South Dade was like, and it was worse than a war 

zone. (0252-8 [Van Leer, Sam])

Comment: [O]ur history with hurricanes has proven how difficult it is too evacuate such a 

heavily populated area during hurricane season when we are for the most part prepared, let 

alone the chaos that would ensue on the limited escape routes headed north in the event of a 

nuclear meltdown. (0259-6 [Lettieri, Tammy])

Comment: The question of whether or not Miami Dade County will ever experience another 

Hurricane Andrew or similar natural disaster is not a question of "if" but "when". Clear, 

unobstructed and safe evacuation routes are paramount to the safety of the residents of MiamiDade County. Constructing the associated new 110' tall High Voltage Electrical Power Line 

Transmission towers, exempted from the high velocity hurricane zone requirements of the 

Florida Building Code, in a location that historically experiences Very High Velocity Hurricane 

force winds, at 200 foot intervals along the length of US One, the major north - south evacuation 

route for Dade County, poses unacceptable risks to the population of Dade County. Doing so is 

simply inviting catastrophe in the event of a natural or man-made disaster requiring evacuation.

(0263-4 [Orzechowicz, Holly])

Comment: One item that was incontrovertible was the impossibility of evacuating South Florida 

to save us from a nuclear disaster. Mere hurricane evacuation makes our evacuation routes by 

land, sea and air impassable and effective communication impossible. (0264-1 [Dwyer, John P.])

Comment: If something serious happens, the public might not be warned to take precautions, 

like the Three Mile Island meltdown which wasn't made public for 9 years. Who made that 

decision? (0336-3 [Anonymous, Anonymous])

Comment: As it is, there is inadequate means for evacuation in the event of a nuclear 

accident. (0337-5 [Philips, Sally B.])

Appendix E October 2016 E-531 NUREG–2176
Comment: I don't have a working Thyroid. A lot of good iodide will do me. Although I would like 

to try the cherry flavored syrup to see how it tastes (if kids will actually drink it). (0373-13 [Lee, 

Nancy])

Comment: I know I am not supposed to address this but god guys, how are you going to get 

people in the keys evacuated. There is only one way to go past the plant. There are almost 4 

million people in a 50 mile radius. I have yet to hear the evacuation plan. (0373-5 [Lee, Nancy])

Comment: They also increase the difficulties of emergency preparedness and evacuations.

(0615-2-14 [Bethune, David])

Comment: Any accident at Turkey Point serious enough to create widespread environmental 

contamination by fallout will also necessitate evacuation of large numbers of the resident 

population, making evacuation a factor in environmental impact planning. (0615-3-7 [Bethune, 

David])

Comment: Traffic flow to and from the Florida Keys is entirely constrained by a single road 

and, in essence, most South Florida traffic is constrained to three roads: US 1, Highway 95, and 

the Florida Turnpike. Bounded by the Everglades to the west, Florida simply does not have the 

east-west transportation infrastructure to make evacuation from Turkey Point viable. In the 

event of an emergency, all traffic flow would be constrained to the same north-south evacuation 

routes along the coast. By virtue of the road system ending in the Florida Keys, evacuation 

southward is also an impossibility, leaving northward travel by three roadways as the only 

evacuation option in case of a nuclear accident at any of the four reactors which would 

constitute the Turkey Point site if units 6 and 7 were completed and fueled. On a typical 

weekday, Miami and Fort Lauderdale experience considerable delays in trying to use these 

north-south roadways. During holidays, the corridor between Homestead and Key West is 

known to be particularly impassible. Hurricane evacuations from the Keys take 3-4 times as long 

as a trip during any other time, and none of these is a mass catastrophe on the order of a 

severe accident at Turkey Point. South Florida simply does not the geography or the road 

system to handle a mass evacuation such as would be necessitated by a serious nuclear 

accident at Turkey Point today and adding two more reactors to the site would only compound 

the problem. The draft EIS for Turkey Point 6 and 7 is incomplete because it fails to take into 

account the problems of evacuating the large population surrounding the plant when only a few 

northbound travel options exist and these are already constrained. Lacking a clear and workable 

evacuation plan, any significant radiation release (not just a meltdown) would present a 

considerable and unjustifiable hazard to human health and the environment. The resulting 

attempt by the public to evacuate a nuclear accident despite the lack of viable roadways could 

lead to violence, car crashes, and other hazards to people. The draft EIS is incomplete because 

it did not compare evacuation problems and options with other proposed sites. (0615-3-9

[Bethune, David])

Comment: Also, the evacuation scenarios of the Florida Keys should be evaluated as part of 

the siting issues, and compared with the evacuation scenarios of the alternative sites. The 

Florida Keys communities are offshore, and therefore have different evacuation routes than 

other potential sites that do not involve offshore communities with evacuation concerns. The 

evacuation of offshore communities in the event of an emergency should be thoroughly 

considered, and should also take into account the possible impacts of hurricanes occurring in 

conjunction with a nuclear plant emergency. (0617-4-15 [Mueller, Heinz J.])

Appendix E NUREG–2176 E-532 October 2016
Comment: The proximity of this plant to a large population that does not have adequate 

escape routes due to being on a peninsula increases the safety risk. (0641-6 [Martin, Drew])

Comment: One item that was incontrovertible was the impossibility of evacuating South Florida 

to save us from a nuclear disaster; Mere hurricane evacuation makes our evacuation routes by 

land, sea and air impassable and effective communication impossible. (0673-1 [Dwyer, John P.])

Comment: So my only point, in conclusion, there is an excellent plan for Dade County and an 

excellent plan for Monroe County on how to handle not just a nuclear waste or nuclear air 

quality or nuclear -- or how to get the cars out of town. It's all good, it's all tied in together, it's 

two separate studies. One's been in existence for a long time. Well done. (0722-15-3 [McColgan, 

Robert])

Comment: My only complaint --that's what I come down here for -- Broward County has no 

safety plan. I did call a Broward County Emergency Management a few months ago and I asked 

them for their Turkey Point nuclear plan in case something happened. And plan like similar to 

Dade or Monroe. And I asked, can I have a copy of your plan? And they looked and looked and 

couldn't find it. Then they called me back 15 minutes later and they said, oh, it's not required. So 

therefore, I'm coming back to the source, the one who requires it. Also a high-level person, a 

friend of mine who's environment health administrator with the Broward County, the Division of 

Health for the State, I asked him to help on this and he come back a week or so later, he had a 

funny look on his face. I know, it's not required. He said, you know, it's not required, that's why 

it's not done....So therefore, everybody means well. There's -- if it's from NRC is the one who 

requires it or doesn't or coordinates, why can't NRC have, okay, we've got Dade County here, 

Monroe County here, why can't Broward County be tied in? Why does it have to have these 

boundaries like ten miles or fifty miles? Why can't we change that? Why can't we have some 

sort of plan for Broward County even if it showed people how to get out of town or what to do?

(0722-15-4 [McColgan, Robert])

Comment: But I really, in the back of my mind, have to make a plan of leaving. And right near 

the front of my door I have the Turkey Point exit plan which, how will it work if you have 15 

minutes to get out? And we can't even move, I can't even get to my school in 15 minutes and I 

have to get out of this giant cone of influence? (0723-11-8 [Berendsohn, Catherine])

Response: These comments relate to the adequacy of emergency plans, which is a safety 

issue that is outside the scope of the NRC staff’s environmental review. As part of its safety 

review, the NRC staff will determine, after consultation with the U.S. Department of Homeland 

Security (DHS) and the Federal Emergency Management Agency (FEMA), whether the 

emergency plans submitted by the applicant are acceptable. The currently operating units have 

an emergency plan in place that has been reviewed and approved by both the NRC and 

DHS/FEMA. No changes were made to the EIS in response to these comments. 

E.2.38 Comments Concerning Issues Outside Scope - Miscellaneous

Comment: Nuclear advocates frequently state that both xenon and krypton decay and 

disappear in a matter of seconds or minutes. What they don't tell us is that these isotopes decay 

into daughter isotopes that are extremely deadly emitters. The corporate proponents of nuclear 

power have used all kinds of disinformation and tactics to protect the industry--compelling the 

nuclear complex to arm guards to 'protect' these secrets and to 'protect' civilian reactors. It is not 

only 'terrorists' that the nuclear establishment seeks to protect us from: the armed guards and 

classified documents are to prevent the public from learning the truth about the destruction of 

Appendix E October 2016 E-533 NUREG–2176
documents, the disappearing of evidence, the falsification of reports and records, the calculated 

fudging of risk and safety assessments. (0673-5 [Dwyer, John P.])

Response: The comment did not provide information relevant to the environmental effects of 

the proposed action. No changes were made to the EIS as a result of this comment. 

Comment: It turns out that nuclear power plants don't just consume uranium. By the way, 

yesterday's article in the "New York Times" said that 80 percent of the world's uranium supply is 

now controlled by President Putin. With his help of some deft contributions to the Clinton 

Foundation and the -- you know, some Canadian investors, we have the Russians basically 

who, over time, they have acquired a lynchpin control over the uranium supply for the world. 

(0723-12-10 [Henry, Jim])

Comment: But for the uranium supplies in the future, we want to turn to Russia? I mean, that's 

a technology risk that I don't want to make. It may not be within the scope of this DEIS. In the 

timeframe that we are considering, we should be thinking about that security issue. (0723-12-11

[Henry, Jim])

Response: These comments discuss the available uranium-ore supply and associated 

potential impact on the viability of the nuclear industry, which are outside the scope of the 

environmental review. No change was made in the EIS as a result of these comments. 

Comment: You people are only in it for money and greed. You'll kill everyone eventually after 

you've killed everything that living creatures, including us, depend on. Hope I'm already dead! 

(0107-1 [Black, Mary Beth])

Comment: I hope the you & your colleagues are un-biased & have enough integrity & complete 

enough with your science to come to the stronger conclusions against FPL wanting 6 & 7 

Nuclear Reactors, because you have also factored in, along with Global Warming flooding 

where Turkey Point resulting in even greater damage to people's health & tourism, that: ... 

Germany (The Western European country with the most cloud cover) that gets so much of the 

power from solar energy that they are decommissioning nuclear power plants, with the aim of 

having none. The information out there that Germany uses more International Corporations' 

Coal than they are using solar power (making the only way their program of providing mortgage 

type loans for all their home owners to have the chance to own & use solar panels is able to 

work) is also a lie. I have read & heard from sources (I trust) that the only reason they use nonsolar power & wind energy is because they & The EU already had established trade deals, with 

other countries. (0120-2 [Shark, Jason])

Comment: I am fearful of the monopolistic and lobbying power FPL has managed to obtain in 

our city. (0171-1 [Oria, Jordan])

Comment: The corporate proponents of nuclear power have used all kinds of disinformation 

and tactics to protect the industry -- compelling the nuclear complex to arm guards to 'protect' 

these secrets and to 'protect' civilian reactors. It is not only 'terrorists' that the nuclear 

establishment seeks to protect us from: the armed guards and classified documents are to 

prevent the public from learning the truth about the destruction of documents, the disappearing 

of evidence, the falsification of reports and records, the calculated fudging of risk and safety 

assessments. (0264-5 [Dwyer, John P.])

Appendix E NUREG–2176 E-534 October 2016
Comment: Nuclear power is something very powerful that we as fellow equal human beings 

are still developing and still learning about. We know better than to use nuclear weapons 

against one another as United Nations. I believe there is a responsible and sensible use for 

nuclear technology. Maybe nuclear development will come in handy one day when the people of 

Earth are ready to explore deep into outer space. (0300-2 [Van Pelt, Jason])

Comment: I don't know why these agencies even consider going through with allowing this, I 

still get amazed at the lack of foresight and stupidity. I continue to hope that intelligence will 

prevail.. (0312-1 [Geiger, Marcia])

Comment: The state process is flawed and NRC should not rely on a bad state utility planning 

process that could have a tremendous negative impact on myself and all residents in the region.

(0323-3 [Jennings, Cara])

Comment: But you're not looking at the big picture, and I want you to deal with it. (0723-11-10

[Berendsohn, Catherine])

Response: These comments did not provide information relevant to the environmental effects 

of the proposed action. No changes were made to the EIS as a result of these comments. 

Comment: On a final note-If any nuclear energy is to be pursued in this country there is no 

intelligent alternative besides Thorium. China is developing LFTR from technology the USA 

pioneered. (0235-1 [Bofill, Beatriz])

Comment: 1) the reactors need to be removed from the biosphere that we live in - meaning get 

the reactors a couple thousand feet underground (or in space); the steam generators and all 

other facilities can be on the surface, (0502-1 [Brumleve, Charles])

Response: The COL applicant is responsible for selecting the reactor design it prefers to have 

reviewed by the NRC during the licensing process. The NRC then reviews the application in 

accordance with its regulations and its licensing procedures. By separate action, the NRC has 

certified certain reactor designs as conforming to its safety standards, including the design 

selected by the applicant for Turkey Point Units 6 and 7. At this time there is no design for a 

liquid fluoride thorium reactor or for a reactor that operates outside the biosphere certified for 

use by the NRC. No change was made to the EIS as a result of these comments. 

Comment: Nuclear power is something very powerful that we as fellow equal human beings 

are still developing and still learning about. We know better than to use nuclear weapons 

against one another as United Nations. I believe there is a responsible and sensible use for 

nuclear technology. Maybe nuclear development will come in handy one day when the people of 

Earth are ready to explore deep into outer space. (0300-2 [Van Pelt, Jason])

Response: The NRC has carefully reviewed the application against its regulations that are 

intended to protect public health and safety and the environment. More information about the 

NRC's roles and responsibilities is available on the NRC's website at http://www.nrc.gov/aboutnrc/regulatory.html. No changes were made to the EIS in response to this comment. 

Comment: I don't want to continue to see the utility company belittle the efficacy of solar 

power. I don't want to expand a reactor because Sarasota doesn't want one. I certainly hope it 

doesn't come down to Legislators and a Governor that not only don't believe in climate change 

but gag-order all state EPA employees from even acknowledging 8th-grade science. (0008-11

[Finver, Jody])

Appendix E October 2016 E-535 NUREG–2176
Comment: You just flunked fifth grade grammar. Your readers deserve better. (0085-1 [Quarles, 

Greyson])

Comment: This power company has already acted cynically and irresponsibly to inhibit the 

development of solar energy (in the "Sunshine State"!) to enhance its bottom line. It has also 

profitted handsomely from future 'cost recovery' tariffs imposed on its customers. Enough is 

enough! (0341-5 [Daniels, Bonnie])

Comment: Your uniqueness, your monopoly reality that you have been able to cultivate over 

the years, it's not always going to be there. And the reality is, is if you have a chance to 

decentralize your client base as well as your production, therefore qualifying your distribution. 

Because the reality is that message of the distribution, somebody has to take care of the lines 

and somebody has to -- so centralized versus distribution, that doesn't make sense. (0721-34-4

[Gomez, Albert])

Comment: So, there's an opportunity space here. And there's someone in a management 

perspective -- it's old management thinking, it's not creative, it's not lateral, and I'm really 

depressed to know that I am supplying a company that has started to rest on their laurels, they 

have lost their innovation edge, and they are resting on the fact that they own the market. And it 

always happens, when anyone owns the market they're the biggest target. So I would just have 

you think from Board perspective that your stakeholders should demand more innovation, 

should demand more, and they're from a local citizen and from a subject matter expert in the 

manufacturing field, and being immersed in quality management on a day-to-day basis.

(0721-34-6 [Gomez, Albert])

Comment: I think FPL has set up a nuclear tech program here at the local college. Why not a 

solar tech project? (0723-9-4 [Schwartz, Matthew])

Response: These comments are directed to the applicant, therefore no changes were made to 

the EIS as a result of these comments. 

Comment: Ms. Bladley, another matter that I hope you can appreciate is the fact that we have 

politicians down here (I think by now that is a known infamous and shameful issue, from 

governor Scott to Tallahassee legislators to local politicians down) who are denying 

environmental changes and are scrupulously gaming the energy issues. A South Miami mayor 

really snowed the residents by fighting huge power lines along a route from Turkey point North a 

few years ago. His re-election campaign was mostly financed by special interests and people 

who opposed the power lines. At those hearings the citizens were lulled in believing that the 

"reactors will never happen". South Miami spent lots of money on legal fees and promptly lost 

the powerline fight against FPL and the mayor was re-elected. The same mayor proceeded to 

forge a 30 year franchise fee agreement with FPL where alternative options were presented and 

available. And now, its election time again, the same mayor is a poster boy against the nuclear 

plants, and I am afraid that history will repeat itself. Said clever mayor was incomprehensibly 

chosen to be with president Obama in the Everglades on Earth day. Except for photo-voltaic 

panels on his own roof there is no evidence in his leadership that tells us he is truly an 

environmentalist. All I want to ask you is to listen to the people and not just align with a 

list of elected officials to make the decisions. Florida just passed a referendum where 75% 

of the Florida Population voted to preserve and protect environmentally sensitive land and 

water. The Turkey point site belongs in that category and guess what: Politicians are already 

trying to game that issues because of the huge sums of taxpayer money involved. (0060-6

[Beckman, Yvonne and Douglas])

Appendix E NUREG–2176 E-536 October 2016
Comment: In following the NRC's own guidelines, the expansion of Turkey Point could have 

unacceptable and irreversible impacts ... even if the governor does not believe they exist.

(0470-2 [Lenz, Andrew])

Comment: And we're in a State with a Governor who doesn't even recognize that or won't even 

talk about it, and that's where the Public Service Commission comes from, and if somebody on 

the Public Service Commission who doesn't agree with the overall attitude of, let's not worry 

about it, they're replaced. (0721-6-4 [Harris, Walter])

Response: The comments did not provide information relevant to the environmental effects of 

the proposed action. No changes were made to the EIS as a result of these comments. 

Comment: I am worried about the mountain tops that we are blowing up to supply more than 

20% of South Florida's electricity. (0127-7 [Cusidor, Teresa])

Response: This comment relates to the environmental impacts of mining uranium for use as 

fuel in a nuclear power plant. The NRC staff evaluated the impacts from the life-cycle of fuel 

production, construction, operation, and decommissioning of the Turkey Point Nuclear Plant 

Units 6 and 7. The results of this analysis are presented in Chapters 4, 5, and 6 of the 

EIS. The generic impacts of the fuel cycle are codified in 10 CFR 51.51(b), Table S-3, Table of 

Uranium Fuel Cycle Environmental Data. In accordance with the guidance in 10 CFR 51.51, the 

staff relied on Table S-3 as a basis for the impacts of uranium fuel-cycle impacts. No changes 

were made to the EIS as a result of this comment 

Comment: Please due the right thing for future generations. (0383-1 [Brown, Robert])

Comment: Please take the time to think of our future, more importantly the future of our 

children, of our planet. (0389-1 [Fitzpatrick, Deirdre])

Comment: We must do all we can to protect Biscayne National Park (0454-1 [Ehrmann, Nancy])

Comment: Please help save this precious park and its wildlife! (0465-1 [Caswell, Gail])

Comment: In following the NRC's own guidelines, the expansion of Turkey Point could have 

unacceptable and irreversible impacts on these treasured sites. Poo-for-brains is ownly good for 

watching fox news. (0500-1 [Pew, Don])

Comment: I have been actively involved in working to protect our environment since 1970. 

President Theodore Roosevelt begin the National Park System by designating Yellowstone as 

our nation's first National Park. (0583-1 [Harper, Diane])

Comment: We need to take a lesson from California and not risk ruining our state for both 

visitors and our residents! (0659-1 [Abalos, Jessica])

Comment: Thank you very much to everyone for being here. It's good to be here on Earth Day 

with the President right around the corner celebrating the Everglades. I helped organize the very 

first Earth Day celebration in Syracuse in 1970 and I've been working to protect the environment 

since long before that, and that's what I'm doing here today. (0721-28-1 [Wilansky, Laura Sue])

Appendix E October 2016 E-537 NUREG–2176
Response: These comments express a general concern about the impact of Turkey Point 

Units 6 and 7 on the region. No specific information is provided in these comments and no 

changes were made to the EIS as a result of these comments. 

Comment: I would say this, on the more the technical side but on the understanding of what it 

means to have a nuclear power station in your town. You can talk about Chernobyl in Russia 

where it did not have a free press, it did not have a diversity of opinion, and where one did not 

have any checks and balances, one could operate with impunity regardless of what others 

believed or would like to know. Or you can operate like Japan did where there has been an 

understanding if there existed a free press and checks and balances, but was there really? 

(0723-7-2 [Boling, Steve])

Response: This comment indicates that the free press in the United States creates a climate of 

extensive oversight for the operation of nuclear power plants. It provides no information 

relevant to the environmental review. No changes were made to the EIS as a result of this 

comment. 

Comment: I would be able to do more if the United States Postal Service's officials was legal 

compelled to afford victims of their adverse actions due process, access to the information 

employed to indict their customers rights and privileges, and granting of a requested impartial 

hearing. Ralph Timberlake of 2117 Atkins Drive, Huntsville, Alabama 35810 mail is encumbered 

for his aforementioned address and his mailing is being encumbered. (0282-2 [Timberlake, Ralph])

Comment: In the 1950's I was an enginer assigned by the Air Force to study the radiation 

fallout effects of atomic weapon explosions during the Nevada Weapons Test Program. 

Conditions have changed extensively but the basic problem of understanding the radiation 

phenomenon still remains and demands full current understanding regardless of the radiation 

source. EPA needs to give this subject complete overview and action, especially the complete 

disposal of ALL nuclear weapons around the world. (0560-1 [Anderson, Vaughn])

Comment: Further, your Thorium-based nuclear systems are still too dangerous and will last a 

few hundred years instead of 10,000 or more years from uranium waste. I believe it was Dana 

Durnford, the Nuclear Proctologist who said "Thorium is more expensive than uranium because 

it can't sustain a reaction by itself and must be bombarded with neutrons." (0561-3 [G., Ambriel])

Comment: And this Fracking thing? Causing major pollution of our underground springs-for a 

bit of oil? (0593-2 [Family, Manzi])

Comment: [Commenter attached a file entitled: Addendum To Indigenous Elders and 

Medicine Peoples Council Statement Fukushima, Beyond Climate Change to Survival on 

Sacred Mother EARRTH. United Nations - September 21, 2014] (0610-1 [Larsen, Shannon])

Comment: The "atoms for peace" program was a cover for producing bomb materials in 

civilian reactors. In other words, it is a lie. Typical for the government. (0645-3 [Anonymous, 

Anonymous])

Comment: WHY KILL OUR ENVIRONMENT OR RISK A DISASTER? TEPCO IS EVIL (0656-3

[Zhivelev, Leon])

Comment: PITIFUL ARGUMENT [City of Miami]. (0685-12 [Batista, Carlos])

Appendix E NUREG–2176 E-538 October 2016
Comment: WHAT DOES THIS [terminating the current monitoring program for the Turkey 

Point power plant cooling canals] REALLY MEAN? (0685-13 [Batista, Carlos])

Comment: The devastation of habitat makes it very difficult for some rare species to survive. 

Many natural medicines, materials, foods, etc disappear with deforestation. I would not mind if 

companies drilled wells or dug up coal, if they actually cleaned up their mess afterwards. 

However, companies never take responsibility for their actions as they should under a free 

enterprise system. Companies NEVER clean up their mess and should not be allowed to pollute 

other countries and the US should condemn other countries' companies who do. Pollution IS 

terrorism!!!!!!!!!!!!!!! It harms everyone on the planet. (0687-1 [Shifflett, Jr., James E.])

Comment: If "profit" is what you're after, then why not follow Colorado's example and make 

Cannabis legal and see how much the sales of it will add to the State's bottom line making any 

type of technology for our citizens affordable! (0712-5 [Almer, Anessa])

Comment: Another big issue is being a native down here. I've seen our Dade County master 

plan. There is no master plan. You know, they come up with a plan, we're going to build here 

and not allow it further, then it goes more, more, more. This X amount of density, oh, no, we'll 

change that. So we need to have a master plan and stick to it and we need to limit further 

construction and the endless inflow of people down here, because people need electricity. And 

if you don't want to have to build nuclear power plants and produce mega power, which people 

need to live, then we need to start limiting the inflow of population through endless construction 

and increasing our density with vertical construction. (0721-24-5 [Eastman, John])

Response: These comments are outside the scope of this review and do not provide specific 

information related to the environmental effects of the proposed action; therefore they will not be 

evaluated further. No changes were made to the EIS in response to these comments. 

Comment: Quit supporting the most bailed out industry in US history, the nuclear power 

industry, since it's beginning. repeal Price-Anderson. (0508-3 [Harrison, J. M. M.])

Comment: And someone mentioned about Wall Street won't pay for this. Well, also insurance 

companies will not insure nuclear risks. There's a Federal law that provides for coverage for 

that. I think it's called the Price Anderson Act. So insurance companies will not insure this, it's 

such a horrible risk. (0721-32-2 [Schlackman, Mara])

Response: The NRC is not involved in establishing energy policy; rather, it regulates the 

nuclear industry to protect public health and safety within existing policy. Thus, matters related 

to the Price-Anderson Act of 1957 are outside the scope of this review and will not be included 

in the EIS. However, the EIS includes an evaluation of potential health impacts of operating a 

nuclear plant on the Turkey Point site in Chapter 5. In addition, the safety assessment for the 

proposed licensing action was provided as part of the application. The NRC is in the process of 

developing a SER that analyzes all aspects of construction and operational safety. The NRC 

will only issue a license if it can conclude that there is reasonable assurance that: (1) the 

activities authorized by the license can be conducted without endangering public health and 

safety, and (2) such activities will be conducted in compliance with the rules and regulations of 

the NRC. 

Appendix E October 2016 E-539 NUREG–2176
E.2.39 Comments Concerning Issues Outside Scope - NRC Oversight

Comment: Your failure to protect my family and the families of others who reside in South 

Florida will result in protracted litigation, of this I can assure you. (0051-2 [Smith, David W.])

Comment: YOU PEOPLE HAVE LOST YOUR MINDS !!!! YOU NEED TO RESIGN....YOU 

ARE NOT WORTHY OF YOUR OFFICE !!! (0477-1 [Garmon, Toni])

Comment: At the time of its creation, the NRC was charged with serving as the public's 

guardian over the activities of civilian nuclear power plants such as those at Turkey Point. The 

law which formed the NRC did so with the purpose of separating the function of protecting the 

public from the task of promoting nuclear energy. The NRC is to have no role in aiding the 

nuclear industry or in promoting the development of its products or agenda. It is not the 

agency's job to justify, rationalize, or encourage the industry's attempts to spread nuclear 

power. Yet faced with overwhelming public support for true clean energy options, particularly 

the solar option in South Florida, the NRC finds itself continually defending the nuclear 

industry's sales pitch. The lighthearted, promotional tone of the summary EIS materials 

presented at the April 22nd public meeting was shocking and reprehensible. As an informed and 

concerned citizen, I urge the agency to clean up its act. If the people of the United States 

decide that there is no future in nuclear power, as the people of Australia, Belgium, Germany, 

Italy, Japan, the Philippines, Sweden, and Switzerland have already decided, then the NRC will 

simply have to accept that fact and "go out of business," as one commenter on regulations.gov 

recommended. (0615-3-10 [Bethune, David])

Comment: Good oversight is a plus. (0685-8 [Batista, Carlos])

Comment: There's a lot of holes here, both in the EIS. You have to be lateral and connective 

to all the different inputs and I don't see that. There's a lot of compartmentalization going on and 

I think that it's time for you guys to start open kimono on this thing and really get into it, because 

from a Nuclear Regulatory Commission this is your legacy. This is your watch. You're here now. 

So you need to shake it up and start to realize that it's your role. (0721-34-7 [Gomez, Albert])

Comment: There is a collusive reality in the fact that the Commission -- you know, I remember, 

I've read your history from the '60s all the way up, how it developed and the whole thing, and 

reality is, it's tough, it's a tough reality that you're in, because you need to promote it, in the 

sense that you have to see it forward, it's an operating entity. You have to promote the entity as 

it operates. You're not obstructive to the entity, you want to make sure that the nuclear power 

plants doesn't shut down. (0721-34-8 [Gomez, Albert])

Comment: But I would like to see you guys take charge here, at least with regards to being 

more open, more holistic, and really look at the quality control issues that are occurring now that 

would affect the EIS. And this meeting is about the EIS. (0721-34-9 [Gomez, Albert])

Comment: [T]he NRC's oversight of the nuclear industry has provided the United States with 

the best, most cost efficient nuclear power in the world. So I'm a lot more comfortable now than I 

was maybe five years ago as we looked into the matter. (0723-1-4 [Wallace, Otis])

Comment: This country and this industry that we operate, that we work in, we truly have a 

system of checks and balances that's rigorous. Plus we have intense government oversight and 

regulation, appropriately. We have an unfettered free press, we have diversity of opinion where 

people can come in, because of freedom of speech they can come in, they can contest what our 

Appendix E NUREG–2176 E-540 October 2016
company wants to do, they can do it freely, openly and because FPL is not able to just do 

whatever we want whenever we want, we have standards we're held to and we have 

regulations. (0723-7-3 [Boling, Steve])

Comment: We've got this extremely risky project going on and the Draft EIS says, eh, it's 

minor, go ahead and do it. They erred and they did not follow something called a precautionary 

principle which means when the outcome of a project is not known, don't do it. Err on the side of 

caution. They didn't show that caution. (0723-9-21 [Schwartz, Matthew])

Response: The comments did not provide information relevant to the environmental effects of 

the proposed action. No changes were made to the EIS as a result of these comments. 

E.2.40 Comments Concerning Issues Outside Scope - Safety 

Comment: I understand nuclear energy is safe, I'm also concerned about human error. I've 

been a pharmacist for 30 years. I've had FPL workers come in to me stressed out because 

there was a leak in the reactor and they had to shut down. It was an immediate issue and I can't 

disclose because have a HIPAA requirement that I can't talk about a patient's stress. But there 

is human error at any job site, I don't care how safe a nuclear reactor or nuclear power plant is.

(0722-17-2 [Swenson, Cyndee])

Comment: It takes courage to oppose what you're all doing because you want jobs and you 

want to stimulate your economy. But this is America, it's just not the Everglades and Key 

Biscayne and FPL and NRC. It's a country. We cannot afford a meltdown here. We cannot 

afford human error to make a mistake for all the jobs this is going to create. And that's what 

created the meltdown in Japan, human error. So as many jobs as you're going to create, think 

of the lives if there's a mistake made, with two more nuclear power plants in the State of Florida 

abutting two national parks. (0723-3-2 [Star, Priscilla])

Response: The issues raised in the comments are outside the scope of the environmental 

review and are not addressed in the EIS. That said, the following are examples of how the NRC 

addresses operational safety issues. The NRC maintains resident inspectors at each reactor 

site. These inspectors monitor the day-to-day operations of the plant and perform inspections to 

ensure compliance with NRC requirements. In addition, the NRC has an operational experience 

program that ensures that the safety issues found at one plant are properly addressed at the 

others, as appropriate. Finally, the design of any new reactors will have already benefited from 

lessons learned at existing reactors and incorporate new safety features that would be 

impracticable to backfit onto existing plants. The NRC will only issue a license or permit if it can 

conclude that there is reasonable assurance that (1) the activities authorized by the license or 

permit can be conducted without endangering the health and safety of the public, and (2) such 

activities will be conducted in compliance with the rules and regulations of the Commission. 

Comment: Locating a new, untested, and questionable Nuclear Power Plant design with 

reduced safety features and possible susceptibility to "flying projectiles," in close proximity to a 

densely populated metropolitan area, contiguous to extremely fragile natural resources and 

within a historically proven State of Florida defined High Velocity (Wind)-Hurricane Zone, seems 

at best to be an ill conceived notion based upon faulty logic and outdated information. (0044-4

[Commenters, Multiple])

Comment: It has also been shown by the tidal wave event in Japan to be highly vulnerable to 

natural disasters. (0140-2 [Rhodes, Karen])

Appendix E October 2016 E-541 NUREG–2176
Comment: In 1992, the two existing nuclear reactors at Turkey Point took a direct hit from 

Hurricane Andrew. According to the NRC's own report: "The onsite damage included loss of all 

offsite power for more than 5 days, complete loss of communication systems, closing of the 

access road, and damage to the fire protection and security systems and warehouse 

facilities...the high water tank collapsed onto the fire water system, rendering the fire protection 

system inoperable. In addition, the storm threatened safety-related equipment (e.g., potential 

collapse of the damaged Unit 1 chimney onto the diesel generator building)." In other words - 

South Florida dodged a very big bullet in 1992. There is no need to build more risk in this 

hurricane-prone location. (0240-5 [Commenters, Multiple])

Comment: Locating a new, untested, and questionable Nuclear Power Plant design with 

reduced safety features and possible susceptibility to "flying projectiles," in close proximity to a 

densely populated metropolitan area, contiguous to extremely fragile natural resources and 

within a historically proven State of Florida defined High Velocity (Wind)-Hurricane Zone, seems 

at best to be an ill conceived notion based upon faulty logic and outdated information. (0263-8

[Orzechowicz, Holly])

Comment: Although the nuclear power industry has probably improved the performance and 

safety of reactors, and has proposed new safer reactor designs, but have they been tested? 

Generally, they have been untested. There is no guarantee to the general public that the 

reactors will be built and operated correctly. (0333-1 [Anonymous, Anonymous])

Comment: Since mistakes do occur and the reactors designers at Fukushima in Japan did not 

anticipate that a tsunami would disable the backup systems that were supposed to stabilize the 

reactor after the earthquake. This has cast doubt on whether even an advanced economy like 

Japan can master nuclear safety. (0333-2 [Anonymous, Anonymous])

Comment: As a person residing inside the 50 mile radius around the Turkey Point nuclear 

plant and already subjected to its dangers, I distressingly find myself a party to the ongoing 

licensing process for two unsafe, untested AP1000 reactors which FPL wants to add to the site.

(0615-1-1 [Bethune, David])

Comment: In lieu of the traditional "defense in depth" safety features found in conventional 

nuclear power plants, the AP1000 design proposes a set of unproven "passive safety" features 

which are assumed to prevent or contain a meltdown accident without human intervention. The 

proposed plants share a number of design problems with the reactors and fuel pools at 

Fukushima Daiichi, problems compounded by the removal of traditional safety features as a 

cost-saving measure. (0615-1-16 [Bethune, David])

Comment: The most important safety function of any nuclear power plant, emergency cooling, 

is the most severely compromised in the AP1000 design. Its predominant feature is a water 

supply tank located on top of the reactor building which offers only a 3 day supply of cooling 

water. If a plant emergency lasts more than 3 days, humans are expected to come refill the 

tank. In a meltdown situation, radiation at the site would severely limit human access, making 

further cooling difficult or impossible. With life threatening radiation levels surrounding the fuel 

pools there, workers at Fukushima were not able to physically approach the plant to assist in 

cooling and they would not be able to approach Turkey Point 6 or 7, either. Storm surge levels 

at the Turkey Point site can also preclude access by personnel. The draft EIS fails to consider 

the environmental impacts of the anticipated fission product releases from a station blackout 

condition lasting more than 3 days and completely the evidence of historical and predicted 

storm surge height at the site. (0615-1-17 [Bethune, David])

Appendix E NUREG–2176 E-542 October 2016
Comment: It cannot be reasonably assumed that the AP1000 design will do a better job of 

preventing a meltdown by having only a single large cooling tank on top instead of a series of 

backup pumps and water supplies. The cooling design itself is dubious, involving dripping water 

around the outside of the containment building rather than over the fuel rods themselves. 

Placed in direct sunlight on the roof as it is, the cooling tank's water is subjected to solar 

heating, which further reduces its potential cooling effect. (0615-2-1 [Bethune, David])

Comment: Lacking the multiple backups of traditional emergency core cooling systems, the 

AP1000 design relies on the environment to provide its cooling functions. There is no proof that 

this emergency core cooling function will work in the year-round warm temperatures at Turkey 

Point and, if it fails, the ensuing core meltdown would present a catastrophic and unacceptable 

risk to the people and the environment of Miami-Dade, Broward, and Monroe counties, as well 

as to the surrounding waterways of the United States. The draft EIS offers no evidence that the 

proposed in-core cooling system, which relies strictly on air circulation around the outside of the 

containment vessel for heat removal, will work as designed in the meteorological environment 

found at the site. (0615-2-10 [Bethune, David])

Comment: An essential part of the AP1000's emergency cooling is the chimney design in 

which the containment vessel sits. The chimney draws in air from the side and spews it out the 

top, unfiltered. Should any leak or breach of the containment vessel ever occur, the ensuing 

fission products would be immediately carried up the chimney and out into the environment. The 

design is reminiscent of the Windscale reactor in England which sprayed its radioactive leaks 

into the atmosphere, resulting in widespread exposure to fallout and contamination of land, 

water, farm animals, and crops. The narrow gap in between the containment vessel and the 

composite shell prevents simple inspections, making it easy for containment leaks to go 

unnoticed while they pour fission products into the sky. The design is full of small, moist spaces 

that will make it easy for corrosion, and therefore leaks, to develop around the containment 

vessel, and these will be immediately swept up and outside. If the air inlets at the sides of the 

reactor building are blocked for any reason the crucial air circulation function will be lost. 

Lacking the traditional array of redundant core cooling methods, this chimney design represents 

a single point of failure for the AP1000's emergency cooling. Both the water tank mounted on 

top and the pool to be dumped inside rely on the chimney air interface to actually remove heat. 

At Fukushima, we saw how a hydrogen explosion at an older reactor could launch debris that 

damaged a spent fuel pool at a different reactor. The Turkey Point siting of two AP1000's next 

to two older reactors would present a nearly identical situation. (0615-2-11 [Bethune, David])

Comment: The draft EIS for Turkey Point 6 and 7 also fails consider how the corrosive sea air 

at the site will affect its containment integrity, ignoring the NRC's own documentation of 

containment leaks at other US nuclear facilities. The combination of the containment vessel and 

chimney design add a new and unnecessary risk to people and to the environment, especially 

given the large population in the affected area and the massive fission product release that 

could result from a prolonged loss of cooling. (0615-2-13 [Bethune, David])

Comment: The AP 1000 design stores spent fuel in a what is essentially an indoor swimming 

pool inside a simple building constructed of the same brittle, untested material as the reactor 

housing. If the water in this pool were to drain to a level where the fuel rods were exposed, 

radiation from the fuel rods would be so intense that the spent fuel building would no longer be 

accessible by human beings. Westinghouse design documents show that, depending on water 

level and the amount and age of the fuel rods in the pool, spent fuel can melt down in a period 

of hours to days. Although Westinghouse claims that the fuel pool can be kept cool for 7 days in 

an emergency, some battery-backed parts of the system will only function for 24 hours. It is not 

Appendix E October 2016 E-543 NUREG–2176
only conceivable, it is highly likely that a hurricane affecting Turkey Point would prevent human 

access to the site for more than 24 hours or even 72 hours. The proposed on-site batteries, 

themselves of little duration, could be easily wiped out by storm surge as they were at 

Fukushima. Being at sea level, the entire area can become inaccessible during severe storm 

surge flooding. The NRC's own assessment of the events of Hurricane Andrew reported that 

workers were not able to reach the Turkey Point site for 5 days after the storm due to flooding. If 

humans cannot reach and attend to the fuel pool and reactor cooling functions, a meltdown is 

assured. A fuel pool meltdown is particularly dangerous since the spent fuel rods sit in an open 

pool of water, rather than inside a shielded reactor. The AP1000 fuel pellets are coated in a zinc 

alloy, like those at Fukushima, which reacts with water and steam during an accident to produce 

explosive hydrogen. A hydrogen explosion in the AP1000 fuel handling building would result in a 

massive and catastrophic release of fission products, contaminating all of the Miami area as 

well as the surrounding waterways and making the area unlivable for thousands of years. Less 

severe accidents have also taken place in fuel pools of this design, each requiring a huge and 

expensive cleanup. In many ways, an open spent fuel pool is a nuclear weapon which is already 

deployed but is waiting to be activated. (0615-2-16 [Bethune, David])

Comment: Hydrogen explosions in two spent fuel pools at Fukushima allowed the fission 

products from self-sustaining fuel rod fires to be released into the environment with catastrophic 

results. The hydrogen results from the zinc alloy coating on the fuel pellets reacting with the 

water and steam inside a melting pile of fuel rods. Although the AP1000's containment vessel 

contains hydrogen igniters which claim to be able to explode the hydrogen before the hydrogen 

explodes the building, these are unproven systems which only work in computer models. The 

most vulnerable part of the plant, the spent fuel pool, has no hydrogen igniters at all. When 

hydrogen ignited above the spent fuel pools at Fukushima it blew off part of the roof of the 

building. This wasn't hard to do, as the fuel pools were located outside of the containment 

structure. Despite what transpired at Fukushima, the proposed reactors at Turkey Point 6 and 7 

present an identical risk to people and the environment by virtue of using zinc alloy coated fuel 

pellets and racking them in the same type of unprotected pool. The draft EIS for Turkey Point 6 

and 7 fails to demonstrate how hydrogen explosions will be avoided during a core or fuel pool 

meltdown scenario, despite the agency's own Fukushima task force recommendations on this 

subject. The most dangerous scenario for Turkey Point is also the most likely to occur, an 

extended station blackout combined with extensive site flooding due to a hurricane. Although 

extended station blackout and storm surge flooding have taken place at Turkey Point already 

and are expected to continue or even increase in the future as a result of climate change, the 

draft EIS fails to examine any aspect of this site-specific scenario. A hydrogen explosion which 

opened the reactor core or the top of the fuel processing building would result in a widespread 

release of fission products, potentially making the entire Miami metropolitan area uninhabitable 

for thousands of years. (0615-2-18 [Bethune, David])

Comment: The top-heavy nature of the tank's location makes the reactor building particularly 

susceptible to hurricane damage and therefore especially unsuited for South Florida. (0615-2-2

[Bethune, David])

Comment: The proposed plant's fuel pool design is dangerous in its similarities to Fukushima, 

a danger compounded by the use of new and unproven building materials. (0615-2-23 [Bethune, 

David])

Comment: A hydrogen explosion which opened the reactor core or the top of the fuel 

processing building would result in a widespread release of fission products, potentially making 

Appendix E NUREG–2176 E-544 October 2016
the entire Miami metropolitan area uninhabitable for thousands of years. (0615-2-28 [Bethune, 

David])

Comment: Unlike traditional reactors with two containment structures, the AP1000 design 

offers only one. In a setup Westinghouse calls "passive cooling," this containment building 

would be directly exposed to the moist, salty, and corrosive air found at the Turkey Point site. 

The chimney-style design takes in the warm, wet air outside the building, heats it further, and 

sends it out the top. Nearly the entire outer surface of the containment vessel is exposed to the 

moist, corrosive sea air at the proposed site. Incidents of severe corrosion, including complete 

holes through containment vessels, have been discovered at other nuclear plants in the United 

States located in far less harsh environments. (0615-2-4 [Bethune, David])

Comment: The draft EIS for Turkey Point 6 and 7 fails to examine how the building design and 

materials would affect the plant's structural integrity during hurricane winds or impact from a 

hurricane-launched object. Should the reactor building or fuel processing building be damaged 

in a storm, the resulting release of fission products would present a serious environmental and 

health impact which remains unexamined. The emergency cooling support structure, being the 

reactor building itself, presents a new and unjustifiably risky design, while the open fuel pool in 

an unreinforced building at ground level simply repeats the problems found at Fukushima. The 

draft EIS is incomplete because it lacks a model for hurricane damage to crucial plant structures 

around the reactor and fuel pool and the potential for ensuing fission product release. (0615-2-5

[Bethune, David])

Comment: The outer building, which offers no containment function, is made of a new steel 

and concrete composite deemed proprietary by Westinghouse. No buildings have ever been 

built of this material in the United States and Westinghouse refuses to disclose its composition, 

preventing independent testing. The NRC's own lead structural engineer famously described the 

brittle nature of this composite when he said that it could "shatter like a glass cup" upon impact. 

After pointing out to Westinghouse that the proposed material wouldn't meet standard nuclear 

building codes for reinforced structures, the NRC accepted the company's reply that computer 

models were equivalent. When the primary part of the reactor building, called Module #2, failed 

in a Westinghouse test, the company claimed the test results were proprietary and couldn't be 

released to the public. The irregular physical design of the proposed reactor buildings and 

support structures, combined with the use of a new, unproven material, make it impossible to 

model the plant's structural behavior using any existing computer code. In a hurricane, the 

reactor building, rooftop cooling pool, or fuel storage pool could be damaged in unpredictable 

ways, posing an exceptional and unjustifiable risk to public safety and the environment.

(0615-2-6 [Bethune, David])

Comment: The draft EIS for Turkey Point 6 and 7 fails to consider that the containment vessel 

could be compromised by the highly corrosive environment at the site or to compare the 

corrosion rates of such a vessel in South Florida's climate with those of the locations where 

reactor containment perforations have already occurred. A leak in the containment vessel of any 

size is an event which presents a substantial risk to human health and the environment. It is a 

risk which can only increase over the proposed plant lifetime of 60 years as the vessel 

continues to be attacked by moisture and minerals from the outside and radiation from the 

inside. The draft EIS omits any study of the long term effects of corrosion from the outside of the 

containment vessel under the lifetime aging conditions of the plant, including aging of materials 

due to nuclear stresses. (0615-2-8 [Bethune, David])

Appendix E October 2016 E-545 NUREG–2176
Comment: In lieu of redundant cooling systems and water supplies in the reactor core, the 

AP1000 design relies on a completely new and untested method of in-core emergency cooling. 

It purports to circulate water from a single pool without pumps using only convection and 

condensation. The NRC has questioned the legitimacy of such a cooling method, which is likely 

to be just as impossible as it sounds. In an emergency, the contents of a single pool of water will 

be dumped into the bottom of the reactor containment vessel. The water is expected to 

evaporate or boil, rising to the top of the vessel where it is collected as steam, condensed, and 

returned to the bottom. The actual emergency removal of heat from the system is expected to 

be accomplished not with multiple sources of water as in a traditional PWR reactor, by merely 

by the containment vessel's air interface as described previously. Westinghouse refers to this 

strategy as "the atmosphere is the ultimate heat sink." A better description might be that it's the 

only heat sink. It is a single point of failure in all core cooling scenarios in the AP1000 design. 

Without pumps, this in-core cooling system is claimed to be able to remove enough heat to 

prevent core meltdown -- but only for 72 hours. After 3 days, human intervention is again 

required, and the entire system will only function if there is no damage to any of its many parts, 

especially the screens designed to keep out debris which would clog the condensation return 

path. When challenged on how the system could prevent the screens themselves from 

becoming clogged, Westinghouse again retreated to a proprietary claim and refused to disclose 

the screen's makeup. (0615-2-9 [Bethune, David])

Comment: There is no need to build more risk in this hurricane-prone location. In 1992, the two 

existing nuclear reactors at Turkey Point took a direct hit from Hurricane Andrew. According to 

the NRC's report: "The onsite damage included loss of all offsite power for more than 5 days, 

complete loss of communication systems, closing of the access road, and damage to the fire 

protection and security systems and warehouse facilities ... the high water tank collapsed onto 

the fire water system, rendering the fire protection system inoperable. In addition, the storm 

threatened safety-related equipment (e.g., potential collapse of the damaged Unit 1 chimney 

onto the diesel generator building)." In other words -South Florida dodged a very big bullet in 

1992. (0655-1 [Tamburr, C.])

Comment: The second thing that really disturbs me about AP-1000 is that it has a very thin 

containment structure. Only one containment building, not two like a traditional reactor. And that 

containment structure is exposed to the environment. It's actually exposed by design. It has air 

baffles on the side that bring air in around the sides of the containment vessel and sends it out a 

chimney in the top. Now, if that sounds like a good containment design to you, maybe you 

haven't lived in South Florida very long, because it's a very corrosive environment where we 

have hot, moist air full of salt water and other minerals. When the steel containment vessel is 

exposed to this air 24 hours a day because of this convection design around the side that's built 

into the plant, we're exposing ourselves to corrosion risks. We've already seen through hole 

corrosion in other in other nuclear reactors in the United States, and it's perfectly plausible for a 

hole to develop in this reactor and nobody even notice. These places are tight and tiny and 

radioactive and it can't be easily inspected. So the entire containment design is really 

unsuitable. It presents an enormous environmental risk. (0721-23-3 [Bethune, David])

Comment: The fuel processing and storage building in AP-1000 doesn't have any special 

protection to prevent that kind of explosion. It doesn't even have the hydrogen ignitors that are 

in the core, where FPL and Westinghouse know that a potential hydrogen explosion is possible.

(0721-23-6 [Bethune, David])

Response: The NRC conducts a concurrent safety review of each COL application along with 

the environmental review; the results of the NRC's safety review of Turkey Point Units 6 and 7 

Appendix E NUREG–2176 E-546 October 2016
will be published in a Final Safety Evaluation Report, which is scheduled for publication in 

November 2016. Regarding concerns about the viability of the AP1000 reactor design, approval 

of new reactor designs is contingent on the rigorous safety review of the design control 

document (DCD). New reactor construction is verified by inspections, tests, analyses, and 

acceptance criteria prior to initial startup testing and plant operation. The AP1000 reactor 

design underwent a lengthy and thorough safety review, resulting in issuance of the AP1000 

Design Certification (DC) Final Rule in December 2011. The AP1000 DC website 

(http://www.nrc.gov/reactors/new-reactors/design-cert/ap1000.html) provides links to 

Westinghouse's license amendment application and the NRC's safety evaluation report. 

Comment: It is not beyond all likelihood that a coastal facility in Florida could be subjected to 

extremes of weather or the vagaries of our planet's infra-structure. An earthquake in the Canary 

Islands eg could send a Tsunami here too. (0213-3 [Hyams, Charles])

Comment: The Westinghouse AP-1000 reactor design has a number of tradeoffs, fewer active 

emergency cooling systems, significantly reduced concrete content, larger secondary 

containment volume with passive cooling, etc. Normally these would be considered 

improvements, except these enhancements have also added a new risk factor, buoyancy. If a 

tsunami, 60-80ft or higher impacts these relatively lightweight/high cubic volume secondary 

containment structure, it will achieve buoyancy. Ref: Canary islands volcano subsidence has 

been modeled (Ward and Day. Cumbre Vieja Volcano --Potential collapse and tsunami at La 

Palma, Canary Islands) estimated Florida beaches would be impacted by a 20-25 meter 

Tsunami, flooding several kilometers inland. Once the secondary containment achieves 

buoyancy the main steam pipes and control connections to the turbine and control buildings 

would be highly stressed, and very likely rupture. Such a major mechanical disruption would 

likely compromise the connected steam generators and the primary coolant loop. Once the 

flooding event is over, the containment structure itself might end up flopped on it's side, thus 

defeating AP-1000's passive emergency cooling system. The Atlantic seaboard would be 

devastated. But like we've seen at Fukushima, the subsequent meltdown and semi-permanent 

radioactive contamination of surrounding area and the Atlantic ocean would make things far 

worse for survivors. (0545-4 [Keating, Tim])

Comment: Increased seismic activity in the Caribbean is something also that is not addressed 

in the Draft EIS Statement. (0721-5-3 [Mendez, Victoria])

Response: The tsunami hazard for Turkey Point site is a part of the safety review and it is 

discussed in Chapter 2 of the Safety Evaluation Report. A somewhat exaggerated account of 

possible scenarios that could cause large magnitude tsunamis impacting the east coast of 

United States was published in paper by Ward and Day (2001). Since then additional studies 

performed by government agencies (i.e., National Oceanic and Atmospheric Administration and 

USGS) and academic organizations, and published in peer-reviewed journals, have repudiated 

and questioned the validity of the scenarios described in this paper. This subject is considered 

out of scope for environmental review. No changes were made to the EIS as a result of these 

comments. 

Comment: 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. (0288-6 [Cleland, Noel] [Jackalone, Frank] [Mahoney, Stephen] 

[Matthews, Debbie] [Roff, Rhonda] [Scott, John] [Teas, Jim] [Ullman, Jonathan])

Appendix E October 2016 E-547 NUREG–2176
Comment: You are putting entirely too many plants in one place. What do you think we are 

Japan? (0373-10 [Lee, Nancy])

Comment: Not only would Turkey Point 6 and 7's fuel pool buildings be susceptible to damage 

from an accident at the older Turkey Point 3 and 4, so would the AP1000's chimneys which are 

essential for every emergency core cooling scenario. Debris from any kind of accident or 

hurricane could block part of this air circulation system, such as the filters at the air intake or the 

narrow annulus that separates the containment vessel from the shell building, threatening the 

entire setup and potentially leading to meltdown and massive release of fission products. A 

hydrogen explosion or turbine accident at one of Turkey Point's other two, older nuclear plants 

could clog these crucial air paths and prevent emergency cooling of one or both of the AP1000. 

The draft EIS for Turkey Point 6 and 7 fails to take into account how the single point of failure 

represented by the the AP1000's atmospheric cooling design could be further compromised by 

the older reactors at the site or by hurricane damage. (0615-2-12 [Bethune, David])

Comment: The draft EIS for Turkey Point 6 and 7 ignores the the NRC's own 

recommendations from its Fukushima task force by looking at the two new reactors in isolation 

and failing to take into account that placing a total of four reactors at the same site, differing in 

age and design, will affect the plant's environmental impact during an accident. (0615-2-15

[Bethune, David])

Comment: The draft EIS also completely ignores the very serious issue of siting the plant next 

to two existing, aging nuclear reactors. The NRC's own task force on Fukushima found that sites 

with multiple nuclear plants present special concerns in the face of extended station blackouts.

(0615-2-21 [Bethune, David])

Comment: Two new reactors increase the risk of an accident. Adding two new reactors could 

increase the risk of a nuclear accident. This plant is very close to the ocean. Storm surge or a 

tidal wave could cause damage to the plant and create a radiation leak. (0641-5 [Martin, Drew])

Response: The issues raised in the comments are outside the scope of the environmental 

review and are not addressed in the EIS. Multi-unit effects are considered in the Safety 

Evaluation Review of the COL. No changes were made to the EIS as a result of these 

comments. 

Comment: The draft EIS fails to consider the environmental impacts of the anticipated fission 

product releases from a station blackout condition lasting more than 3 days and completely the 

evidence of historical and predicted storm surge height at the site. (0615-1-18 [Bethune, David])

Comment: The draft EIS for Turkey Point 6 and 7 fails to examine the environmental impacts 

of a meltdown event resulting from the a failure of the in-core cooling system or its atmospheric 

heats ink, especially during a hurricane when station blackout may last longer than 3 days and 

storm surge may prevent worker access to the facility. The in-core cooling system relies on the 

circulation of condensation and outdoor air cooling and the efficacy of these approaches has not 

been tested under South Florida weather conditions. (0615-2-20 [Bethune, David])

Comment: In its mission to protect public safety and health, the NRC must err on the side of 

caution and presume that a beyond design basis accident will resemble what took place at 

Fukushima and, given the particular conditions at the Turkey Point site, also involve an 

extended station blackout lasting longer than 3 days combined with site inaccessibility due to 

storm surge or flooding. Given the hard evidence that an accident involving a similar 

Appendix E NUREG–2176 E-548 October 2016
arrangement of multiple units, the loss of on-site power, and high radioactivity due to meltdown 

has already occurred, the draft EIS for Turkey Point 6 and 7 is substantially incomplete as it 

assumes on human access to prevent catastrophic environmental releases when it may not be 

possible for humans to reach Turkey Point during or following a hurricane. The draft EIS omits 

any discussion of the environmental impact of a station blackout lasting longer than 3 days or 

one involving long-term site inaccessibility due to storm surge, even though both of those events 

are anticipated to occur at the site. (0615-2-3 [Bethune, David])

Comment: Consider, too, that Biscayne Bay is ground zero for the landfall of hurricanes. In 

1992 Turkey Point sustained a direct hit from Hurricane Andrew. According to the NRC's own 

report: "The onsite damage included loss of all offsite power for more than 5 days, complete 

loss of communication systems, closing of the access road, and damage to the fire protection 

and security systems and warehouse facilities...the high water tank collapsed onto the fire water 

system, rendering the fire protection system inoperable. In addition, the storm threatened 

safety-related equipment (e.g., potential collapse of the damaged Unit 1 chimney onto the diesel 

generator building)." In other words, South Florida dodged a very big bullet in 1992. There is no 

need to build more risk in this hurricane-prone location. (0674-3 [Dwyer, Karen])

Comment: When we build a nuclear plant here we increase our potential risks of a radiation 

based accident like we saw in Fukushima. And this particular plant design, as I've been finding 

out, has some really serious concerns. It combines a lot of the problems of the Fukushima 

plants and it also has some new, untested technologies that we're relying on to keep us safe. I 

don't think that we can really rely on those. So I want to point out a few of them to you so that 

you can do your own research and make some public comments to the NRC afterwards about 

what you find, because this is what I found out. The main source of emergency cooling in this 

plant is a water tank on top. The supply will only last three days. We've just heard a gentleman 

explain that we already had a hurricane at that location where the power was out for five days. 

So we're basically asking for, with this design, a meltdown. We are creating a situation in which 

there is no backup water supply to cool the reactor after three days. Human beings would have 

to go there and refill the water tank on the top of this reactor, which is completely insane. We 

saw people battling the radiation at Fukushima for weeks and months, not for days. And we 

already know that Florida can lose power for days and weeks at a time. So building a new 

design that's lacking in basic safety features, because they want to save money, and leaves us 

with basically a three-day outage period is completely unacceptable. It provides -- it presents 

not only an environmental risk but also a safety risk. (0721-23-1 [Bethune, David])

Comment: I don't see any discussion in the EIS about accident mitigation at all. Basically we're 

assuming that the design basis accident, the three day accident is the only one that could ever 

happen, and that's ridiculous. (0721-23-4 [Bethune, David])

Response: The issues raised in the comments are outside the scope of the environmental 

review. No changes were made to the EIS as a result of these comments. 

Comment: From what I can see the only lessons that were learned after the Hurricane Andrew 

impact on the Turkey Point facility dealt with wind damage. Given the serious impact that 

flooding had on the Fukushima Daiichi nuclear plant in Japan what precautions have been taken 

by FPL after the Fukushima incident? Hurricanes can produce severe storm surges and may 

create a similar flooding event as was experienced in the Fukushima incident. I would request 

that FPL detail the actions they have taken to prevent a meltdown due to flooding from a storm 

surge. In particular what preventative measures they have already taken to protect the two 

current reactors and the assumptions that underly those measures. It would seem prudent to 

Appendix E October 2016 E-549 NUREG–2176
me to have an understanding of how rigorous the current preventative measures are, so we as 

citizens can have an idea of what to expect from the company with regard to the new units. In 

the unlikely event that no action was taken after the Fukushima incident, I would very much like 

to understand the current measures in place to protect against a storm surge and have a copy 

of the review that must have been conducted after the Fukushima event. (0001-1 [Tacher, Ian])

Comment: The reactor itself it old and run down. (0008-4 [Finver, Jody])

Comment: I also know that I would much rather prefer new, state of the art, reactors rather 

than continually relying on the original two that are already past their original useful life and 

have needed improvements to increase their outputs. This pushing the original operational 

envelope is much more concerning to me than providing newer, safer units. I understand the 

concern that people have with nuclear safety, especially since the accident in Japan, but 

wonder how many realize that FPL reactors are not configured and will not operate the same 

way. (0070-3 [Lamb, Deborah S.])

Comment: It relies on outdated data (some decades old) when estimating its safety. (0126-2

[Pontier, Christine Hughes])

Comment: I am aware that nuclear power plant technology has come a long way over the 

years. We now have the ability to run plants that can reuse their nuclear fuel much longer, 

resulting in a much more stable radioactive waste when the fuel is finally retired. I am unaware if 

this new, more eco-friendly plant has been implemented on this site. My suggestion would be to 

deny the creation of any new reactors before the likely old style reactors at this plant are 

replaced with the new, safer, cleaner models. Go one further and suggest they undertake this 

task not only at this location, but all locations where this company owns nuclear power plants. If 

they are so eager to spend money, let them do so and help the environment at the same time. 

Win-win, in my book. In the process, they build company loyalty, as you've suddenly made 

plants that are far safer for the workers who maintain and operate them. They build community 

relationships because the people who live in the vicinity of this power plant can sleep a little bit 

easier, knowing they have the most current, safest, and most environmentally-friendly nuclear 

power plants in existence. Before they know it, they are a leader in the nuclear power industry 

based on this tiny change in their mission statement. (0230-1 [Delateur, Marc])

Comment: My concerns, along with what Laura Reynolds said on the fact that there are 

current problems with the maintenance and operation of 3 and 4. I understand, from what 

you've told me, you're not going to look at that. (0721-13-1 [Martin, Drew])

Comment: The older plants are '70s vintage designs, they have their own problems. Any kind 

of accident, including a turbine break at one of the older plants, 3 and 4, could cause flying 

debris that can damage the AP-1000, including clogging these important cooling vents on the 

side and preventing emergency cooling. It could also land in the spent fuel pool and cause 

damage to the fuel pool or the pumping and equipment that's used to move that water between 

the reactor and the fuel pool. So just creating an additional plant at the same site where we 

already have old plants exponentially increases our risk. Those old plants become a risk factor 

for the new plants. (0721-23-10 [Bethune, David])

Comment: The opportunity to replace units 3 and 4 by units 5 and 6 is not really reviewed, 

even though the NRC will claim that all they could do is approve or recommend this project. 

Serious consideration should be looked at replacing aging nuclear reactors rather than adding 

to the project. (0721-5-6 [Mendez, Victoria])

Appendix E NUREG–2176 E-550 October 2016
Response: NRC staff can only review the proposed application for Turkey Point Units 6 and 

7. The decision about whether or not to decommission the existing Units 3 and 4 is a decision 

made by the applicant, FPL. Also, safety matters related to aging of the existing units at Turkey 

Point are outside the scope of the environmental review of the proposed Units 6 and 7. No 

changes were made to the EIS as a result of these comments. 

Comment: Liquid, gaseous, and solid radioactive waste management systems would collect 

and treat the radioactive byproducts of operating the proposed Turkey Point Units 6 and 7, and 

these byproducts would be handled separately from the byproducts of existing Units 3 and 4. 

Spent nuclear fuel will require continued on-site storage. Due to the uncertainty regarding 

future availability of a geologic repository or other away-from-reactor storage facility, on-site 

storage may be required for many decades, until a permanent repository is established. The 

DEIS notes that each nuclear island would consist of a containment building, shield building, 

and auxiliary building; the radwaste building would be separate from the island, approximately 

36 feet above grade (page 3-19). Recommendations: The FEIS should clarify plans regarding 

how the storage of spent nuclear fuel will be handled in order to prevent contamination, in the 

event of flooding at the site. We note that the proposed Units 6 and 7 will be elevated to provide 

safety from potential flooding, however, the low sea level in this area combined with the area's 

history of hurricanes requires that measures to address potential flooding be thoroughly 

evaluated and documented. (0617-2-2 [Mueller, Heinz J.])

Response: On August 26, 2014, the Commission issued a revised rule at 10 CFR 51.23 and 

an associated Generic Environmental Impact Statement for Continued Storage of Spent Nuclear 

Fuel (NUREG-2157). Continued Storage applies to the storage of spent fuel after the end of the 

licensed life for operations of a nuclear reactor and before final disposal in a permanent 

repository. The revised rule adopts the generic impact determinations made in NUREG-2157 

and codifies the NRC's generic determinations regarding the environmental impacts of 

continued storage of spent nuclear fuel beyond a reactor's operating license. As directed by 10 

CFR 51.23(b), the impacts assessed in NUREG-2157 are deemed incorporated into this EIS in 

Section 6.1.6. Section 6.1.6 also explains that current national policy mandates that high-level 

and transuranic wastes are to be buried at deep geologic repositories and that no release to the 

environment is expected to be associated with deep geologic disposal. 

The radwaste building is at plant grade within the power block. Section 5.11.2.4 explains that 

the design basis flood elevation (24.8 ft) is below the design plant grade (26.0 ft), and no further 

evaluation of accidents resulting from external floods is required. Climate change, including 

future sea-level rise, is addressed in Chapter 2, Chapter 7, and Appendix I. The impacts of 

climate change on the storage of spent fuel is included in NUREG-2157. Climate change 

impacts on the safe operation of Units 6 and 7, including sea-level rise, flooding, hurricanes, 

and storm surge, will be addressed in the staff's Safety Evaluation Report. 

No change was made to the EIS as a result of this comment. 

Comment: Does FPL have the infrastructure to maintain this project?! (0149-12 [Nelson, Joyce 

E.])

Response: The NRC’s principal responsibility is to protect the health and safety of the public 

when authorizing the use of radioactive material. The regulations governing the environmental 

review are set forth in 10 CFR Part 51, Environmental Protection Regulations for Domestic 

Licensing and Related Regulatory Functions, and the regulations covering the safety review are 

in 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, and other 

Appendix E October 2016 E-551 NUREG–2176
regulations referenced therein. The NRC will only issue a license or permit if it can conclude 

that there is reasonable assurance (1) that the activities authorized by the license or permit can 

be conducted without endangering the health and safety of the public and (2) that such activities 

will be conducted in compliance with the rules and regulations of the Commission. Applicants 

must demonstrate they can meet the NRC established requirements before a license is 

issued. No changes were made to the EIS as a result of this comment. 

E.2.41 Comments Concerning Issues Outside Scope - Security and Terrorism 

Comment: I would also like to know how security concerns of a potential terrorist attack are 

being addressed in the expansion project plans as well as the current power plants in operation 

today. (0132-2 [Mauri, Tom])

Comment: Catastropic scenarios involving terrorist attacks are also conceivable. (0333-3

[Anonymous, Anonymous])

Comment: Also, at a time when there is so much terrorist activity, I cannot think of a better 

target for attack than a nuclear plant in the City of Miami-the very model of America's most 

desirable lifestyle--staffed by at least a few Homer Simpsons. (0339-4 [Provost, Allan])

Comment: It also represents a national security threat, with nuclear facilities a target for any 

nation or group seeking to inflict harm by triggering a nuclear disaster through attack or 

sabotage. (0356-5 [Shlackman, Jed])

Comment: Seaside nuclear power plants are vulnerable targets with a large multiplier factors 

(5,000 to 50,000x verses tactical n-weapon) for radioactive fallout and contamination. In a world 

that seams to becoming more unstable as time progresses, it's just a matter time before one 

these facilities are targeted. (0545-5 [Keating, Tim])

Comment: A terrorist attack on the poorly-protected fuel handling building, especially by air, is 

a notable risk. (0615-2-25 [Bethune, David])

Comment: The nearby location of Miami International Airport and the even closer Homestead 

Air Reserve Base add another level of danger as any accident or terrorist incident involving the 

considerable low-altitude air traffic in the vicinity could damage the reactor buildings. The 

primary emergency cooling tank, the highest point above ground level, presents a particular risk, 

as does the spent fuel storage pool its poorly protected location. (0615-2-7 [Bethune, David])

Comment: NRC 's Draft EIS is Flawed Because it Fails to Adequately Address the Threat 

of Terrorism and the Potential Consequences of a Meltdown in Multiple Units. The NRC's 

NRC's Environmental Impact Statement for Combined Licenses (COLs) for Turkey Point 

Nuclear Plant Units 6 and 7, Draft Report for Comment (NUREG-2176) fails to address the 

threat of terrorism to the Turkey Pont site. Since 9-11 it has come to light that U.S. nuclear 

reactors have viewed as targets by the like of Al Qaeda. In fact the FBI has arrested and 

convicted terrorist suspects in the US who referred to U.S. nuclear reactors as "nice targets" 

(http://articles.latimes.com/2012/nov/13/nation/la-na-nn-saudi-student-texas-terrorism20121113). 

But according to NRC's DEIS: The comments that are outside the scope of the environmental 

review for the proposed Turkey Point site are not included in this appendix. These include 

comments related to the following: safety, emergency preparedness, NRC oversight for 

Appendix E NUREG–2176 E-552 October 2016
operating plants, security and terrorism, support or opposition to the licensing action, licensing 

process, nuclear power, hearing process, or the applicant. (See Appendix D.) However, almost 

decade ago, the U.S. Court of Appeals for the Ninth Circuit required that the NRC account for 

the environmental impacts of terrorism under the National Environmental Policy Act's 

Environmental Impact Statement (EIS) provision. (San Luis Obispo Mothers for Peace v. 

Nuclear Regulatory Commission, 449 F.3d 1016, 1035 (91h Cir. 2006). The 9th circuit 

determined that the possibility of a terrorist attack was not so "remote and highly speculative" 

and that the NRC should not exclude it from consideration under NEPA Furthermore, the court 

found NRC position to be "inconsistent with the government's efforts and expenditures to 

combat this type of terrorist attack at nuclear facilities." (Id.) The Court determined that NEPA 

requires that the NRC take a 'hard look' at the consequences of a terrorist attack upon a nuclear 

power plant. Mother for Peace was not asking the agency to engage in speculation or 

conjecture but to adequately address the range of environmental impacts if an attack took place. 

(Id.) The NRC's DEIS ignores this decision. Although it remains an open question in Florida due 

to a split between the 9th and 6th circuits, sound regulation and a federal agency cognizant of 

and responsive to public concerns would have long ago adjusted its process to account for 

terrorism during the preparation of an EIS on known terrorist targets. 

(http://www.pillsburylaw.com/siteFiles/Publications/839E98B17AA3C8E45DOAD74928D1108.p

df) (0716-11 [Riccio, Jim])

Comment: Also at a time when there is so much terrorist activity, I cannot think of a better 

target for attack than a nuclear plant in the City of Miami, the very model of America's most 

desirable lifestyle, staffed at least by a few Homer Simpson's. (0721-26-6 [Koenigsberg, Linda])

Response: Comments related to security and terrorism are safety issues that are not within the 

scope of the staff's environmental review. No changes were made to the EIS in response to 

these comments. 

E.2.42 General Editorial Comments 

Comment: There are a few instances where the references to DEIS Appendix I (The Effect of 

Climate Change on the Evaluation of Environmental Impacts) and DEIS Appendix J 

(Greenhouse Gas Footprint Estimates for a Reference 1,000 MW(E) Light-Water Reactor) 

appear to be reversed. Instances in the DEIS include: a. DEIS Subsection 6.1.3, Page 6-8, 

Lines 20-21. b. DEIS Section 6.3, Page 6-39, Lines 40-41. Additionally, the title of Appendix J, 

"Carbon Dioxide Footprint Estimates for a 1,000 MW(e) Reference Reactor", listed in DEIS 

Subsection 1.6, page 1-12, line 27, is not consistent with the Table of Contents or Appendix J, 

"Greenhouse Gas Footprint Estimates for a Reference 1,000 MW(E) Light-Water Reactor"

(0619-1-13 [Maher, William])

Comment: There are instances in the DEIS where a reference is either incorrectly cited, 

corrupt in ADAMS, or not consistent with the information referenced. Instances in the DEIS 

include: a. DEIS Subsection 2.6.1.2, Page 2-186, Table 2-54: DEIS Table 2-54 lists the source 

as (USCB 2009-TN1462). The file in ADAMS, Accession No. ML14287A731, for the DEIS 

reference (USCB 2009-TN1462) is corrupt. b. DEIS Subsection 6.2.2, Page 6-27, Lines 15-16: 

The DEIS references Addendum 1 to NUREG-1437 as the 2013 Revision 1 of the GEIS (NRC 

2013-TN2654). The correct reference for Addendum 1 of the GEIS is DEIS reference (NRC 

1999-TN289). c. DEIS Subsection 8.1.1, Page 8-2, Line 37: The DEIS cites "(TenYrPlan2014)" 

as the reference. The reference should be cited as (FPL 2014-TN3360). d. DEIS Subsection 

10.6.1.2, Page 10-20, Line 31: The DEIS references Section 5.4.3.1 for additional information 

about the economic impacts of constructing and operating Units 6 & 7. DEIS Section 5.4.3.1 

Appendix E October 2016 E-553 NUREG–2176
references FPL 2011-TN435 which is "Personal Communications with Miccosukee Tribe of 

Indians of Florida, Metro Miami Action Plan Trust and Miami-Dade Office of Community 

Advocacy." The reference should be a U.S. Bureau of Economic Analysis reference: BEA 2012-

TN1569; BEA 2012-TN4074; or BEA 2014-TN4075. e. DEIS Subsection 11.0, Page 11-43, 

Lines 36-37: The DEIS reference cited, (FPL 2011-TN303), refers to FPL's "Stormwater 

Management Plan and Calculations" with an Accession No. ML12192A226. This Accession No. 

is linked to a SANDIA National Laboratories document, "RADCAT 2.3 User Guide" in ADAMS. f. 

DEIS Appendix F-2, Section 2.1, Page 2-4/2-5, Line 43/2: Appendix F-2 states: "A new 

substation...would also be necessary (Error! Reference source not found. Figure 2-3)." g. 

DEIS Appendix F-2, Section 4.10, Page 4-7, Lines 27-28: Appendix F-2 states: "As discussed in 

FPL's Ten-Year Power Plant Site Plan (FPL 2013-TN2630), population estimates...1,000 to 

2,000 individuals." The reference cited, (FPL 2013-TN2630), is FPL's Ten Year Power Plant 

Site Plan 2013-2022. This document does not provide information about crocodile populations. 

The correct reference is the FPL Threatened & Endangered Species Management Plan, Rev 1 

(FPL 2011-TN1283). Page 12, paragraph 3, which states, "Ogden (1978a) estimated that 

between 1,000 and 2,000 American crocodiles existed in south Florida in the early 20th 

century..." h. DEIS Appendix F-2, Subsection 5.10.5, Page 5-9, Lines 31-34: Appendix F-2 

states: "The 2014 death involved an adult crocodile...not attributed to plant operations (NRC 

2014-TN3718)." The reference listed could not be verified. The DEIS reference cited (NRC 

2014-TN3718) refers to NRC's Event Notification Report: Offsite Notification due to Deceased 

American Crocodile, July 25, 2014 with an accession No. ML14338A556. This Accession No. is 

linked to the Appendix F-2 . (emphasis added) (0619-1-18 [Maher, William])

Comment: The DEIS identifies FPL as "Florida Power and Light Company" and the ER 

identifies FPL as "Florida Power & Light Company". The correct legal name is "Florida Power & 

Light Company". (0619-2-15 [Maher, William])

Comment: Executive Summary, Page xxxv, Table ES-1: In DEIS Table ES-1, the DEIS 

indicates: a. For the "Land Use" Resource Category, that the operation environmental impact

level is "MODERATE (NRC authorized construction impact level is SMALL.)" (emphasis 

added). b. For the "Socioeconomic Physical Impacts" Category, that the construction 

environmental impact level is "SMALL." This is not consistent with DEIS Section 4.12, page 4-

148, Table 4-19 and DEIS Subsection 10.2.1, page 10-7, Table 10-1, where this impact level is 

listed as "SMALL (adverse) to MODERATE (beneficial) (NRC authorized construction impact 

level is SMALL)." (0619-2-16 [Maher, William])

Comment: Inconsistencies identified in draft EIS and ER, Rev 6: Subsection 10.4.2, Page 10-

15, Lines 28-33 "FPL states in Table 10.2-1 of its ER that construction of the...two new units at 

Turkey Point would involve... 22,000 tons of rebar.... (FPL 2014-TN4058). Construction would 

also use large quantities of aluminum, copper... and quarry materials (nuclear and construction 

grade fill material, aggregate, sand, etc.)." ER Table 10.2-1 ER Table 10.2-1 lists 20,000 tons 

of rebar and states, "Small quantities" related to aluminum, boron, titanium, tungsten, and 

other natural resources. (0619-2-28 [Maher, William])

Comment: DEIS Subsection 8.1.1, Page 8-2, Lines 35-36: The DEIS states: "FPL is 

interconnected with 21 municipal and rural electric cooperative systems (FPL 2014-TN4058)." 

ER Revision 6 indicates 19 external connections as illustrated in ER Figure 8.1-3. (emphasis 

added) (0619-5-11 [Maher, William])

Comment: DEIS Section 7.0, Page 7-3, Table 7-1: In DEIS Table 7.1 under the subheading 

"Energy Projects" the first project listed is "Turkey Point Units1-4". This should be changed to 

Appendix E NUREG–2176 E-554 October 2016
"Turkey Point Units 1-5" as stated in DEIS Section 7.1, Page 7-9, Line 5. (0619-5-7 [Maher, 

William])

Response: These comments are editorial in nature. Hyperlinks to documents within internal 

systems were inadvertently left in the electronic version of the draft document and led to the 

"corrupt and Error" messages for external readers. The hyperlinks will be removed in electronic 

version of the final EIS. Changes were made to reflect the correct legal term for Florida Power 

& Light. Additional changes were made to text in Sections 4, 7, 8, 10, Appendix I, and 

Executive Summary to reflect these comments. 

Comment: In a letter dated March 17, 2014, DEIS reference (FPL 2014-TN3569), FPL 

removed the FPL-owned fill source from the application; however, there remain instances in the 

DEIS where the FPL-owned fill source is referenced. Instances in the DEIS include: a. DEIS 

Subsection 2.7.2, Page 2-197, Line 11. b. DEIS Subsection 4.3.1.3, Page 4-60, Line 22. c. DEIS 

Subsection 4.5.1.1, Page 4-120, Line 30. d. DEIS Subsection 4.8.1.1, Page 4-129, Lines 34-

35. e. DEIS Appendix F-2, Section 4.7, Page 4-6, Lines 3-4. f. DEIS Appendix F-2, Section 4.8, 

Page 4-6, Lines 31-32. g. DEIS Appendix F-3, Section 2.0, Page 2-1, Line 28. h. DEIS Appendix 

F-3, Subsection 3.1.2, Page 3-7, Line 31. (0619-1-5 [Maher, William])

Response: The text in EIS Sections 4.3.1, 4.5, and 4.8 was revised to remove references to 

the FPL-owned fill source. Revision 6 of the ER includes the FPL-owned fill source in the 

description of the Area of Potential Effect (Section 2.5.3.3.1). To maintain consistency with the 

application, the fill source will be included in the features described in Section 2.7.2 of the 

EIS. Appendix F-2 and F-3 contain the BAs submitted to the FWS and NMFS as part of ESA 

Section 7 consultation. No changes were made to submitted consultation documents as result 

of this comment. 

E.3 Form Letter Authors 

Approximately 10,618 of the written submissions were form letters. The U.S. Nuclear 

Regulatory Commission (NRC) identified 9 form letter templates (see Table E-4). Table E-4 

includes a reference for the first piece of correspondence recived by the NRC for each of the 

nine form letters. The majority of the form letters were sponsored by the National Parks 

Conservation Association (Multiple Authors 2015-TN4716). Identical comments contained in 

form letters were captured only once; however, any additional comments contained in form 

letters were treated as unique comments. Authors and ADAMS accession numbers for form 

letter submissions are identified in Tables E-5 through E-13, one table per form letter. 

Table E-4. Form Letter Identification Numbers 

Correspondence 

Identifier 

ADAMS Accession 

No. 

Table of 

Author Names 

Reference 

TURK-COL6&7-DR-00044 ML15139A604 Table E-5 Multiple Authors 2015-TN4723 

TURK-COL6&7-DR-00067 ML15139A651 Table E-6 Multiple Authors 2015-TN4722 

TURK-COL6&7-DR-00073 ML15139A668 Table E-7 Multiple Authors 2015-TN4724 

TURK-COL6&7-DR-00102 ML15140A000 Table E-8 Multiple Authors 2015-TN4716 

TURK-COL6&7-DR-00103 ML15139A729 Table E-9 Multiple Authors 2015-TN4721 

TURK-COL6&7-DR-00104 ML15140A141 Table E-10 Multiple Authors 2015-TN4720 

TURK-COL6&7-DR-00379 ML15141A259 Table E-11 Multiple Authors 2015-TN4719 

TURK-COL6&7-DR-00240 ML15146A110 Table E-12 Multiple Authors 2015-TN4718 

TURK-COL6&7-DR-00679 ML15191A341 Table E-13 Multiple Authors 2015-TN4717 

Appendix E October 2016 E-555 NUREG–2176
Table E-5. Individuals Submitting the Form Sponsored by Brickell Unites with 

Correspondence ID TURK-COL6&7-DR-00044 and Representative ADAMS

Accession No. ML15139A604 (Multiple Authors 2015-TN4723)

Commenter 

ADAMS 

Accession # 

Arostegui, Al ML15139A606 

Baldwin, Brandi ML15139A636 

Billings, Marc ML15139A625 

Corda, Charles R. ML15139A610 

Curry, Carolyn ML15139A626 

Curry, Richard E. ML15147A201 

Echeverria, Diego ML15139A614 

Ehrlich, Jr., Peter R. ML15139A608 

Fernandez, Jackeline ML15139A665 

Fernandez, Susie P. ML15139A642 

Font, Lauri ML15139A639 

Grill, Helen ML15139A596 

Horowitz, Ira ML15139A643 

Hubler, Gina Marie ML15139A604 

Imbesi, Nan ML15139A631 

Ismail, Noreen ML15139A671 

Johannsen, Christian ML15139A605 

Commenter 

ADAMS 

Accession # 

Kavanaugh, Brigitte ML15139A623 

Lanoff, Robert and Andrea ML15139A619 

Logan, Scott ML15139A629 

Logan, Scott ML15139A637 

McCall, Eric ML15139A624 

Rocha, Bea ML15139A627 

Romero, Alejandro ML15139A618 

Segor, Joseph ML15139A630 

Shlachtman, Barbara ML15139A658 

Soto, Angela ML15139A638 

Ubieda, Yailky ML15139A615 

Valente, Free N. ML15139A670 

Vinciguerra, Anthony ML15139A635 

Violich, Francesca ML15139A592 

Wellins, Debra ML15139A650 

Williams, Lashawnda ML15139A640 

Wyman, Vicki ML15139A641 

Table E-6. Individuals Submitting the Form Sponsored Brickell Unites with 

Correspondence ID TURK-COL6&7-DR-00067 and Representative ADAMS

Accession No. ML15139A651 (Multiple Authors 2015-TN4722)

Commenter 

ADAMS 

Accession # 

Becerra, Francisco ML15139A654 

De Villiers, Elena ML15139A675 

Diaz, Mayra ML15139A660 

Echeverria, Diego ML15139A651 

Hamilton, McHenry ML15160A312 

Hawkes, Tim ML15139A673 

Commenter 

ADAMS 

Accession # 

Hecht, Deborah ML15139A652 

Hubler, Gina Marie ML15139A653 

Maurer-Guy, Lourdes Lina ML15139A662 

McCabe, Mead ML15139A663 

Stanley, Gael ML15139A664 

Wilder, Jo ML15139A632 

Appendix E NUREG–2176 E-556 October 2016
Table E-7. Individuals Submitting the Form with Subject “Objection to FP&L’s Plan to 

Place Huge High Voltage Lines on Poles on or Near SW 1st Avenue in the 

‘Miami Roads’ Area” with Correspondence ID TURK-COL6&7-DR-00073 and 

Representative ADAMS Accession No. ML15139A668 (Multiple Authors 2015-

TN4724)

Commenter 

ADAMS 

Accession # 

Alvarez, Rosa ML15128A183 

Arias, Vivian G. ML15161A393 

Arias, Vivian G. ML15146A128 

Ayerdis, Wenddy ML15218A210 

Batista, Carlos ML15128A183 

Cavlineau, Carmen ML15128A183 

Cavlineau, Nicolas ML15128A183 

Crousillont, Patrick ML15218A210 

de Armas, Maria Cristina ML15139A676 

Dean, Glenn M. ML15128A183 

DeSalle, Edward ML15128A183 

Dogan, Zynel Oleay ML15218A210 

Echevarria, M. Paz ML15161A393 

Elguaras, Carlos L. ML15218A210 

Febles, Ignacio ML15161A393 

Febles, Maria V. ML15161A393 

Fifer, Brian ML15128A183 

Fifer, Mark ML15128A183 

Fifer, Richard Glen ML15128A183 

Frade, Silvia ML15218A210 

Frade-Eguares, Silvia ML15218A210 

Garcia, Aida S. ML15146A128 

Garcia, Aida S. ML15161A393 

Garcia, Armando ML15128A183 

Garcia, Caridad R. ML15128A183 

Garcia, Enrique J. ML15161A393 

Garcia, Enrique J. ML15146A128 

Garcia, Enrique J. ML15146A128 

Glass, Bonita ML15148A482 

Gonzalez, Juan and 

Jaqueline ML15161A393 

Guirola, Chavela Maria 

Isabel ML15218A210 

Hernandez, Dagin ML15218A210 

Hughes, David ML15138A092 

Commenter 

ADAMS 

Accession # 

Hughes, David ML15161A393 

Hughes, David ML15139A718 

Koenigsberg, Linda ML15128A183 

Lappen, Jennifer ML15139A677 

Lucero, Olga ML15161A393 

Lucero, Olga ML15139A728 

Lucero, Olga ML15162A855 

Malcolm, Kelley ML15218A210 

Martinez, Serafin ML15218A210 

Mathia, Judith L. ML15128A183 

Menendez, Mike ML15128A183 

Milan, Craig ML15128A183 

Murillo, Maria M. ML15218A210 

Pajor, Claudia ML15218A210 

Provost, Allan ML15198A118 

Provost, Allan ML15128A074 

Reyes, Graciela ML15161A393 

Reyes, Graciela ML15146A128 

Scherr, Matthew ML15128A183 

Scudierc, Veronica ML15146A128 

Scudieri, Veronica ML15161A393 

Stoerger, Alexandra ML15218A210 

Stoerger, Stephen ML15218A210 

Stoerger, Zarda ML15218A210 

Suquet, Guillermo ML15161A393 

Valladores, Debra A. ML15139A668 

Vazquez, Cristina M. ML15161A393 

Vinuela, Maximilian ML15218A210 

Warren, Robert H. ML15128A183 

Whitlock, Catherine ML15218A210 

Zapata R., Martha C. ML15146A128 

Zapato R., Martha C. ML15161A393 

Zarazun, Nikki ML15218A210 

Appendix E October 2016 E-557 NUREG–2176
Table E-8. Individuals Submitting the Form Sponsored by National Parks Conservation 

Association with Correspondence ID TURK-COL6&7-DR-00102 and 

Representative ADAMS Accession No. ML15140A000 (Multiple Authors 2015-

TN4716)

Commenter 

ADAMS 

Accession # 

Aaron, Allysa ML15159B080 

Aaron, Emory ML15156B135 

Abadia, Betty ML15160A935 

Abare, Jeff ML15159B475 

Abbasparker, Ibn‐Umar ML15161A696 

Abbott, Shaun ML15156A528 

A'Becket, Suzanne ML15153A963 

Abel, Jerian ML15162A431 

Abraham, Mirla ML15156A590 

Abrams, Michael ML15154C261 

Abrams, Saliha ML15153A966 

Abrantes, Elizabeth ML15148A897 

Abreu, Sayuri ML15162A422 

Abshire, James ML15155C078 

Ackerman, Frank ML15153A511 

Ackerman, Laura ML15155B717 

Ackerman, Lynn ML15154A811 

Ackerson, David ML15155A949 

Ackroff, Karen ML15148B212 

Acosta, Angel ML15148B241 

Acuna, Carina ML15161A629 

Adam, Dawne ML15141A755 

Adam, Jackie ML15156B197 

Adams, Brett ML15154C240 

Adams, Carol ML15154C286 

Adams, Charlotte ML15147A720 

Adams, Cindy ML15159B537 

Adams, Jean ML15156A981 

Adams, Kim ML15148A893 

Adams, Lynn ML15154B988 

Adams, Robert ML15142A271 

Adams, Ruth ML15154B962 

Adams, Sandra ML15156A936 

Adams, Victoria ML15161A697 

Adan, Elizabeth ML15148A175 

Addis, Linda ML15159A472 

Adelman, Saul ML15153A684 

Aderhold, Steven ML15159A041 

Adler, Ken ML15155A304 

Adobajor, Alisa ML15142A298 

Adobajor, Alisa ML15154A411 

Adsit, Roy ML15162A542 

Aenlle, Willy ML15141A757 

Affolter, Angie ML15154B697 

Aflatooni, Mark ML15154C001 

Agostinho, Elizabeth ML15156A589 

Aguirre, Robert ML15155A785 

Commenter 

ADAMS 

Accession # 

Ahlstrand, Heidi Lynn ML15156A828 

Aiken, Edwin ML15154A739 

Ailill, Dane ML15148B227 

Ainsley, Brian ML15156A255 

Alamprese, Laura ML15148B441 

Albanese, Dawn ML15154C267 

Albar, Mike ML15159B417 

Albers, Harold ML15156A095 

Albert, Cheryl ML15159B558 

Albert, Laura ML15142A264 

Albertson, Pat ML15156A748 

Albonni, Adam ML15159B512 

Albrandt, Patti ML15155A367 

Albrecht, Lonnie ML15148B442 

Alden, Rory ML15159A963 

Alejandro, Patricia ML15155A018 

Alexander, Charles ML15160A923 

Alexander, Mark ML15158A111 

Alexander, Mary ML15156A110 

Alexander, Mary ML15156A882 

Alexander, Thomas ML15154B714 

Alfano, Joseph ML15142A327 

Alfaro, Elaine ML15154B280 

Alfonso, Nadine ML15156A211 

Alford, Linda ML15154B343 

Alguacil, Oscar Revilla ML15159B240 

Alippe, Lorraine ML15158A174 

Alisau, Patricia ML15155A370 

Allbee, Dwight ML15148B342 

Allbright, Galloway ML15148B390 

Allen, D. Patrick ML15159A317 

Allen, Dennis ML15154A391 

Allen, Elise ML15160A975 

Allen, J. ML15141A228 

Allen, Jerre ML15156A318 

Allen, Juanita ML15162A584 

Allen, Judy ML15155B023 

Allen, Keith ML15156A488 

Allen, Kenneth ML15162A573 

Allen, Linda ML15159A237 

Allen, Llowell ML15154A086 

Allen, Mary ML15142A026 

Allen, Maureen ML15141A653 

Allen, Melissa ML15156A667 

Allen, Monique ML15154A024 

Allen, Ron ML15154B637 

Allen, Rosamond ML15141A644 

Appendix E NUREG–2176 E-558 October 2016
Commenter 

ADAMS 

Accession # 

Allen, Suzanne ML15154A137 

Allen, Tracey ML15156A932 

Allen, Travis ML15156A179 

Allenby, Coral ML15154B885 

Alleyne-Chin, Donna ML15154B797 

Allgood, Jean ML15159A554 

Allphin, Toby ML15155A751 

Allred, Shelley ML15155C029 

Almeida, Gabriela ML15154A270 

Almendarez, Mary ML15148A615 

Almirola, Alejandro ML15159A881 

Almirola, Alejandro ML15159A948 

Alovis, Elly ML15155A126 

Altman, Jeff ML15155A043 

Altman, Penny ML15155A046 

Alvare, Michelle ML15158A224 

Alvarez, David ML15159A414 

Alzuro, Nick ML15141A493 

Amador, Nicole ML15141A783 

Amalfitano, Gloriamarie ML15141A460 

Aman, Michael ML15155A515 

Amaro, Hector R. ML15148B225 

Amato, Julie ML15155A814 

Amato, Nicole ML15153A992 

Amato, Sarina ML15158A135 

Ambler, Lana ML15162A140 

Ambrosio, Antoinette ML15159B027 

Ameen, Arshad ML15154A729 

Amell, June ML15158A100 

Ames, Karin ML15155B697 

Ames-Curtis, Juli ML15142A241 

Amick, Tom ML15154C007 

Ammon, Cara ML15160A787 

Ammon, Clifford ML15156A955 

Anderholm, Jon ML15159A005 

Andersen, Kirsten ML15156B436 

Andersen, Paul ML15148B181 

Anderson, Angela ML15159A528 

Anderson, Anthony ML15156B506 

Anderson, Arlete ML15156A966 

Anderson, Barry ML15142A041 

Anderson, Christine ML15156B256 

Anderson, Clifford ML15142A265 

Anderson, David ML15154A741 

Anderson, Diana ML15154B686 

Anderson, Dina ML15148A238 

Anderson, Edna ML15154A360 

Anderson, Glen ML15156B027 

Anderson, Joel ML15155B710 

Anderson, Judith ML15142A226 

Anderson, Julie ML15153B303 

Anderson, Julius ML15155B991 

Anderson, Karen ML15148B092 

Anderson, Karen ML15154B938 

Commenter 

ADAMS 

Accession # 

Anderson, Katrina ML15155C215 

Anderson, Kevin ML15154B969 

Anderson, Larry ML15140A155 

Anderson, Margaret ML15156B318 

Anderson, Mary ML15153A317 

Anderson, Matthew ML15154B235 

Anderson, Mike ML15154C197 

Anderson, Patricia ML15155C196 

Anderson, Robert ML15156B210 

Anderson, Sandy ML15153A831 

Anderson, Shel ML15148A879 

Anderson, William ML15154A331 

Andersson, Joan ML15155A166 

Andrade, Stacy ML15160A871 

Andre, Javier ML15155B061 

Andregg, S. ML15148A198 

Andresen, Bette ML15148A231 

Andreula, Ann ML15156A050 

Andrews, Becky ML15160A790 

Andrews, Becky ML15160A792 

Andrews, Susan ML15156A539 

Andrews, Terry ML15154B975 

Anduskey, Susan ML15158A226 

Angel, John ML15154A031 

Angell, J. ML15155A839 

Angelovich, Nancy ML15162B089 

Angelovich, Nancy ML15162B137 

Angotti, Kathleen ML15155B752 

Angus, Billy ML15154B512 

Ankli, Gene ML15155A011 

Anner-Bolieu, Lynn ML15148B208 

Ansari, Fariba ML15142A274 

Ansarifar, Vafa ML15155A668 

Ansay, Gabriele ML15160A786 

Anthis, L. ML15155A242 

Anthony, Art ML15159B472 

Anthony, Bahuaud ML15159B403 

Anthony, Judy ML15153B245 

Anton, Michael ML15160A976 

Antosiak, Carol ML15156A126 

Apfel, Sarah ML15155A385 

Appelbaum, Anita Brooks ML15155A056 

Appell, Stephen ML15154B531 

Appenzeller, Cary ML15154B864 

Apperson, Mariko ML15140A026 

Appleman, Luisa ML15154B108 

Araluce, Tiffany ML15154B945 

Arana, Josefa ML15156A447 

Aranita, Rosita ML15162B091 

Aranita, Rosita ML15162B146 

Arapoudis, Sandra ML15159A717 

Arbolaez, Fidel ML15148B100 

Arbour, Carole ML15154B886 

Archambault, Caitlin ML15160A830 

Appendix E October 2016 E-559 NUREG–2176
Commenter 

ADAMS 

Accession # 

Archbold, Edwin ML15155B654 

Archer, Linda ML15147A752 

Archuleta, Patricia ML15156B494 

Arcure, Barbara ML15140A178 

Arens, Donnis ML15155A798 

Arent, Raymond ML15162A605 

Arfin, Danielle ML15141A637 

Argenzio, Diane ML15158A029 

Armato, Frank ML15154C085 

Armbrust, Deborah ML15153B004 

Armenteros, Clara ML15159A122 

Armentrout, Harley ML15148B237 

Armer, Joan ML15154B826 

Armillas, Mercedes ML15148A710 

Armitage, Chris ML15142A247 

Armour, Kelly ML15141A528 

Armstead, Betty ML15141A629 

Armstead, Leroi ML15153B265 

Armstrong, Jennifer ML15155B945 

Armstrong, Marsha ML15148A713 

Arndt, Dolores ML15155C037 

Arneson, Andrew ML15161A626 

Arnett, Catherine ML15158A127 

Arney, Kevin ML15155A632 

Arney, Tracey ML15155A800 

Arnold, Arthur ML15159A342 

Arnold, Ben ML15158A102 

Arnold, Marge ML15159A033 

Aronson, Murray ML15153B137 

Aronson, Sylvia ML15153A910 

Arosarena, Oneida ML15159A622 

Arrington, Aubrey ML15155A140 

Arsiaga, Rosa ML15142A276 

Artigas, Josep ML15153A458 

Arumugham, Vinu ML15155A285 

Arveson, Michael ML15158A215 

Asbury, Craig Lee ML15155B912 

Ascenzo, Carey ML15153A900 

Aschenbrenner, Eva ML15155C139 

Ashcraft, Hugh ML15154B923 

Ashcraft, James ML15154C106 

Ashley, Cathy ML15154A578 

Ashmore, Sandra ML15154A716 

Ashton, Elyse ML15142A102 

Ashton, Linda ML15156B399 

Askew, Georgena ML15148A998 

Askins, Ed ML15140A171 

Astalos, Andrew ML15155B188 

Asteinza, Josef ML15155B417 

Atcheson, Sandra ML15148B109 

Atchison, Dorian ML15155B241 

Atkins, Ilene ML15156B268 

Atkinson, Paul ML15159A852 

Atmore, Wendy ML15147A722 

Commenter 

ADAMS 

Accession # 

Atwell, J. ML15155C067 

Audette, Jarryd ML15148B041 

Augenstern, Joy ML15142A288 

Aughey, Arlene ML15153B183 

Augusto, Keith ML15160A865 

Aulgur, John ML15148A765 

Aulgur, John ML15154B624 

Aungst, Judith ML15154B904 

Aurigemma, Kaye ML15154B529 

Ausenbaugh, Jean ML15148A730 

Ausman, Emma ML15154B257 

Austin, Genevieve ML15159A366 

Austin, Gregory ML15154C192 

Austin, Joyce ML15154C019 

Austin, Laird ML15148A162 

Aversa, Amy ML15159A102 

Avery, Patricia ML15156A028 

Avery, Sara ML15155A771 

Avetikyan, Jose ML15154A296 

Avidor, Roberta ML15162A107 

Avrutick, Alice ML15155A283 

Ayala, Joe ML15162B044 

Ayala, Joe ML15162B099 

Ayers, Frank ML15155A543 

Ayers, Mark ML15154B128 

Aylor, Anne ML15154B756 

Aylward, Diana ML15162A649 

Azcona, Gon ML15162A101 

Azzarello, Joe ML15154A465 

B., Angelene ML15140A157 

B., Angelene ML15156B456 

B., Christine ML15154B687 

B., Enzo ML15154A077 

B., J. ML15142A351 

B., Shary ML15146A370 

B., Susan ML15154B349 

Babb, Winifred ML15155C142 

Bachman, Jerald ML15140A114 

Bacic, E. ML15154A480 

Backstrom, Karin ML15154B833 

Badders, Christine ML15154A341 

Bader, Jessica ML15162B089 

Bader, Jessica ML15162B134 

Bader, Sandra ML15155A305 

Bader, William ML15153A345 

Badus, Theresa ML15156A092 

Badyrka, Jill ML15155A516 

Bagby, Janet ML15160A867 

Bagnoli, Connie ML15155A035 

Bagwell, Wilson Knox ML15156A862 

Bahn, Ted ML15154A871 

Bahris, Angie ML15155B924 

Baier, Carol ML15140A202 

Baier-Barnes, DeAnna ML15156A279 

Appendix E NUREG–2176 E-560 October 2016
Commenter 

ADAMS 

Accession # 

Bailey, Chrissy ML15160A808 

Bailey, Evelyn ML15148B220 

Bailey, Larry ML15154A766 

Bailey, Mary ML15154B729 

Bailey, Stephen ML15142A123 

Bailie, Janae ML15156A532 

Bailiff, Elliott ML15153B202 

Bailiff, Elliott ML15154C259 

Bails, Jean ML15155B729 

Bainbridge, Kathryn ML15154A420 

Bainbridge, Tamara ML15155A050 

Baird, Barbara ML15156A014 

Baird, Larry ML15155B589 

Bak, Patrick ML15155B603 

Baker, Frank ML15159A078 

Baker, Helene ML15141A671 

Baker, Joy ML15154B107 

Baker, Karen ML15155C155 

Baker, Kristina ML15148A212 

Baker, Leslie ML15142A035 

Baker, Louis ML15154B725 

Baker, Mary Sue ML15159A808 

Baker, Richard ML15156A003 

Baker, Sara ML15155A084 

Baker, Sasha ML15155A068 

Baker, Sharon ML15154B892 

Baker, Vickey ML15155B935 

Baker-Smith, Gerritt and 

Elizabeth ML15154B181 

Bakr, Rania ML15156A065 

Balaska, Konstantina ML15159B274 

Baldino, Vincenza ML15155A007 

Baldock, Jason ML15156A302 

Baldwin, Jeff ML15142A280 

Baldwin, Tanya ML15160A726 

Baley, Patricia Mcrae ML15162B042 

Baley, Patricia Mcrae ML15162B097 

Balfour, Joan ML15154A738 

Balke, Bruce ML15159A953 

Ball, Evelyn ML15158A284 

Ball, Tim ML15159B508 

Balles, Katherin ML15159A710 

Balog, Nancy ML15159B075 

Balosie, Dean ML15154A683 

Balzan, Darlene ML15154C044 

Balzer, Johanna ML15142A094 

Bamberger, Wayne ML15141A725 

Bamford, Robert ML15153A604 

Bamford, Stephen ML15154C048 

Banach, Darlene ML15161A664 

Banever, C. ML15142A289 

Banever, Robert ML15153A904 

Banfield, David ML15158A235 

Bangham, Jerry ML15140A005 

Commenter 

ADAMS 

Accession # 

Banken, Ella ML15154A440 

Banks, Janice ML15156A170 

Banks, Michele ML15160A805 

Bannon, Kevin ML15155A258 

Baouche, Karen ML15159A767 

Barber, Marilyn ML15154A657 

Barberi, Lillyam ML15153A501 

Barbuto, Paul D. ML15160A711 

Barclay, Daniel ML15153B116 

Barcomb, Wendy ML15141A620 

Barcott, Nick ML15158A139 

Barger, John ML15148A865 

Barile, Kathryn ML15146A371 

Barker, Anne ML15154A091 

Barker, Chris ML15155C187 

Barker, Donald ML15154B127 

Barker, Mary Clare ML15141A788 

Barker, Monica ML15159A722 

Barker, Scott ML15142A105 

Barkley, Dan ML15154C175 

Barlow, Scott ML15154C141 

Barmeyer, Sarah ML15155A148 

Barnard, Michele ML15155C190 

Barnes, Linda ML15155B896 

Barnes, Richard ML15158A086 

Barnett, Barbara ML15159B078 

Barnett, Lynn ML15154B465 

Barnett, Peter ML15156B299 

Barnett, Renee ML15155A012 

Barnett, Sandra ML15155A872 

Barney, Martin ML15160A596 

Barnhart, Katherine ML15154A394 

Barns, Suzanne ML15159A791 

Barr, Alwyn ML15160A925 

Barr, Ellen ML15162A624 

Barr, Ford ML15156A873 

Barr, Jay ML15154B698 

Barr, Nancy L. ML15158A117 

Barragan, Rosa ML15148B242 

Barreras, Terri ML15153A749 

Barrett, Donna ML15159A219 

Barrett, Elizabeth ML15154B452 

Barrett, Janet ML15159B231 

Barrett, Lisa ML15156A800 

Barrett, Martha ML15156A185 

Barrington, Tim ML15155A701 

Barron, Mikail ML15155B004 

Barrows, Steven ML15159B583 

Barrrons, Susan ML15159A109 

Barry, John ML15141A552 

Barry, Lynda ML15154B014 

Barry, Marion ML15155B826 

Barshter, Rebecca ML15148A955 

Bartholomew, Alice ML15155A241 

Appendix E October 2016 E-561 NUREG–2176
Commenter 

ADAMS 

Accession # 

Bartkowicz, Richard ML15159B216 

Bartleman, Mark ML15160A730 

Barton, Alyssa ML15159B147 

Barton, Gary ML15142A140 

Barton, Janelle ML15154B474 

Basile, C. ML15155A270 

Basman, Melis ML15160A071 

Bass, Lanny ML15140A267 

Bass, Wanda ML15141A469 

Bassett, Christine ML15154C303 

Bassett, Jan ML15156B032 

Bassett, Susan ML15154C232 

Basso, Jeremy ML15156A726 

Bastron, Diana Kukule ML15154C250 

Basye, Mae ML15154B277 

Bates, Abigail ML15148B178 

Bates, Shivaun ML15155A396 

Bathrick, Patricia ML15156A037 

Battaly, Gertrude ML15160A644 

Baucco, Matthew ML15159A817 

Bauder, William ML15142A086 

Bauer, Cynthia ML15154C282 

Bauer, Linda ML15155A797 

Bauer, Mary ML15155A054 

Bauer, Philip ML15153B250 

Bauer, Terri ML15161A644 

Baumann, Scott ML15153A410 

Baures, Timothy ML15155A182 

Baxter, Lou ML15155B966 

Bayer, Judith ML15156B431 

Be, Nancy ML15153B076 

Beach, Muriel ML15148B385 

Beale, Jr., Howard K. ML15159B509 

Beam, Stephanie ML15159A458 

Beaman, Deena ML15154A297 

Beans, Sheree ML15159A960 

Bearden, Jim ML15154A552 

Beardsley, Rebecca ML15159B434 

Beatini, Tom ML15155B272 

Beattie, Jane ML15154B523 

Beatty, Lorne ML15155A261 

Beavers, John ML15159B123 

Beavers, Nancy ML15155C197 

Bechtoldt, Lenore ML15159A520 

Becker, Elaine ML15160A693 

Beckman, Linda ML15155A499 

Bedat, Suzanne ML15155A369 

Bedell, Stephen ML15156B265 

Beebee, Kara ML15155C064 

Beecher, Christina ML15148B133 

Beeghly, Charles ML15155B880 

Beeler, James ML15148B329 

Beerheide, Erna ML15160A862 

Beery, Richard ML15154B993 

Commenter 

ADAMS 

Accession # 

Begley, Christina ML15162A576 

Begley, Matt ML15154B552 

Begrisch, Mary ML15141A634 

Begum, Khani ML15148B157 

Behan, Darren ML15148B328 

Behl, Daniel Max ML15161A624 

Bein, Ann ML15153A885 

Bejgrowicz, Thomas ML15140A024 

Belanger-Iott, Nancy ML15155B202 

Belcastro, Frank ML15155A464 

Beldin, Joan ML15148B060 

Belfer, Morgan ML15160A723 

Bell, David ML15159B330 

Bell, Denise ML15140A196 

Bell, Gary ML15160A968 

Bell, Jennifer ML15154B852 

Bell, Jim ML15153B108 

Bell, Lesli ML15158A199 

Bell, Linda ML15154A218 

Bell, Randall ML15148B247 

Bellas, Brian ML15148B359 

Bellefeuille, Barbee & 

Ronald ML15158A241 

Bellini, Cynthia ML15155B339 

Bellomo, Stephen ML15155C050 

Belloso-Curiel, Jorge ML15155B833 

Beltran, Olivia ML15148A878 

Beltz, Judith ML15162B044 

Beltz, Judith ML15162B112 

Benco, Mike and Andrea ML15156A070 

Bender, Kae ML15154C263 

Bender, Nancy ML15148B028 

Bender-Muir, Marie ML15159A662 

Benedetto, Mona 

Stephanie ML15155A611 

Benet, Marjorie ML15142A082 

Bengel, Anna ML15161A653 

Bengston, Lynn ML15148B139 

Bening, Allison ML15155A342 

Benito, Alejandra ML15155A062 

Benjamin, Alex ML15148A850 

Benjamin, Andrew ML15148B349 

Benjamin, Elaine ML15142A188 

Benjamin, Emily ML15162A043 

Benkert, Cynthia ML15141A670 

Bennett Jr., Frank Z. ML15155B932 

Bennett, Astrid ML15148B330 

Bennett, Bryan ML15155A003 

Bennett, Jesse ML15154A233 

Bennett, Maris ML15154B232 

Bennett, Michael V. L: ML15155A030 

Bennett, Robbie ML15148A890 

Bennett, Robert ML15154A307 

Bennett, Virginia ML15147A710 

Appendix E NUREG–2176 E-562 October 2016
Commenter 

ADAMS 

Accession # 

Benning, Sheryl ML15159B337 

Benoit, Marguerite ML15154B352 

Bensberg, Wilhelm ML15148B094 

Benson, William ML15159B344 

Bentley, Kathy ML15140A016 

Benton, Stan ML15153B179 

Benton‐Janetta, Lori ML15156B499 

Bentz-Letts, Alan ML15155A421 

Beqaj, Oliver ML15154B579 

Berard, Carol ML15156A078 

Berchem, Marie-Ange ML15141A439 

Berecz, Illya ML15140A240 

Bereczki, Patricia ML15153B232 

Berens, Bruce ML15153A889 

Berezansky, Nick ML15155A647 

Berg, Elaine ML15155B338 

Berg, Jon ML15156A523 

Bergen, Jaye ML15153A678 

Bergen, Peggy ML15148A827 

Berger, Keith ML15155A159 

Berger, Melissa ML15140A159 

Berger, Sally ML15155A165 

Bergeron, B. ML15141A657 

Bergey, Don ML15155A415 

Bergey, Nancy ML15153A881 

Bergman, Don ML15154C190 

Bergmann, Amy ML15162A115 

Bergstedt, Charlie ML15155C091 

Beringer, Laurie ML15154B912 

Berisford, Daniel ML15161A646 

Berkshire, David ML15140A043 

Berliner, Alice ML15154A219 

Berliner, Diane ML15158A071 

Berliner, Jill ML15155A487 

Berman, John ML15160A642 

Berman, Pearl ML15155B519 

Berman, Steven ML15141A672 

Berna, Patricia ML15155A634 

Bernache, Marie ML15141A616 

Bernard, Christina ML15162A087 

Bernard, James ML15148B343 

Bernardo, Kathleen ML15154A826 

Berner, Kris ML15142A163 

Berner, William ML15155A413 

Bernstein, Laura Ann K. ML15155A817 

Bernstein, Marcy ML15148B356 

Bernstein, Roslyn ML15154A488 

Berowski, Kim ML15155A001 

Berowski, Kim ML15156A820 

Berry, Bethany ML15162A718 

Berry, Kenneth ML15148B337 

Berry, Marla ML15158A158 

Berry, Paula ML15153B184 

Berry, Victoria ML15156A908 

Commenter 

ADAMS 

Accession # 

Bersell, Barbara ML15154A665 

Bertol, Alina ML15159A367 

Berzins, Ieva ML15159B531 

Betti, Mark ML15155A615 

Betts, Cynthia ML15155B927 

Bettum, Gary ML15159B278 

Betz, Brian ML15159A244 

Beuscher, Will ML15156B022 

Bever, Emily ML15148A653 

Beveren, Chantal ML15159A486 

Beverly, J. ML15154B778 

Beverly, Robert ML15155C137 

Beyerle, Brittany ML15154A951 

Bhence, Blaze ML15154A620 

Bianchi, Melanie ML15148B265 

Biccum, Susan ML15158A068 

Bickel, Michael ML15153B117 

Bicking, Ann ML15153B107 

Bicknell, Mary ML15154A014 

Biddle, Maxine ML15154B237 

Bidney, Martin ML15141A746 

Bidwell, Troy ML15159B400 

Biedermann, Martin ML15155A642 

Bielaus, Edward ML15140A013 

Bielawski, Richard ML15154A535 

Bielke, Patricia ML15159A357 

Biere, Debbie ML15154A311 

Bieszk, John ML15148A858 

Biffl, Betsy ML15154A385 

Biggs, Amy ML15154B877 

Biglia, Monique ML15153A928 

Bilenko, Stephanie ML15154B187 

Bill, Alma ML15160A847 

Billey, Catharine ML15154A170 

Bindas, Janet ML15156B305 

Binder, Caroline ML15162A671 

Binder, Gene ML15155A128 

Birch, Beatrice ML15162A076 

Bird, Richard ML15154B149 

Birkeland, Celeste ML15148A967 

Birnbaum, Dara ML15159A000 

Bishop, Cori ML15159A607 

Bishop, Norman ML15159A814 

Bishop, Shirley ML15156A257 

Bisser, John ML15153B143 

Bissett, Tina ML15162A510 

Bissram, Nyla ML15153A577 

Bitter, Josh ML15154C033 

Bjornbak, Kris ML15153A500 

Black, David ML15159A146 

Black, Karina ML15154A203 

Black, Mary Ann ML15155A402 

Black, Mary Beth ML15141A499 

Black, Pauline ML15154B012 

Appendix E October 2016 E-563 NUREG–2176
Commenter 

ADAMS 

Accession # 

Blackwood, Jean ML15148B076 

Blaesing-Thompson, 

Shawn ML15148A254 

Blair, Dan ML15154A284 

Blaire, Jan ML15154A474 

Blaisdell, Jill ML15153A743 

Blake, Frank ML15155A706 

Blake, Jocelyn ML15153A474 

Blake, Richard ML15160A630 

Blakemore, Richard ML15148A662 

Blanchard, Ann ML15160A067 

Blanchard, Rob ML15159A287 

Blanchette, Laura ML15140A040 

Blanck, Heidi ML15155C231 

Blandford, Tom ML15148B088 

Blanding, David ML15155A000 

Blaney, Carol ML15160A583 

Blank, Charles ML15159A376 

Blankenship, E. ML15153B289 

Blanton, Robin ML15156B014 

Blaschke, Lawrence ML15154B007 

Blau, P. ML15142A272 

Blay, Nora ML15140A039 

Bleby-Lewis, Joyce ML15155B817 

Bleecker, Skip ML15153A832 

Blesi, Donald ML15155B736 

Bley, Ann ML15160A073 

Blinder, Linda ML15154B230 

Blinder, Linda ML15156A046 

Bliss, Richard ML15154A708 

Block, Gary ML15155A392 

Block, Julie ML15162A702 

Bloedow, MaryAnn ML15154C063 

Blond, Olivia ML15153B072 

Bloom, Gary ML15156B257 

Bloom, Martin ML15155A824 

Bloomquist, Kristofor ML15140A182 

Blossom, Laurel ML15155A411 

Blount, Susan ML15158A074 

Blumert, Joel ML15155B038 

Blurton, Joan ML15159A143 

Bobb, Mary ML15156B165 

Bobb, Mary ML15160A732 

Bobroff, Alexander ML15153A739 

Boccagna, Emilia ML15155C080 

Bockino, Alida ML15155A274 

Boden, Jeff ML15148A243 

Bodiford, Loretta ML15156B342 

Bodleaender, Peter ML15147A721 

Boeckermann, Jesse ML15159B357 

Boehler, Karen ML15154A012 

Boerner, Gary ML15161A657 

Bogan, Susan ML15153A709 

Boggs, George ML15155B856 

Commenter 

ADAMS 

Accession # 

Bogin, Ronald ML15153B282 

Bohac, Stephen ML15162A206 

Bohanan, Crickett ML15156A143 

Bohl, Calleen ML15155A277 

Bohlen, Curt ML15159B211 

Böhm, Birgitt ML15160A632 

Bohn, David ML15156B367 

Boise, Gretchen ML15156B247 

Boka, Erika ML15155A386 

Bolcon, W. ML15147A745 

Bolen, D. K. ML15155A520 

Boliver, Emily ML15154B580 

Bollini, Margaret ML15148B063 

Bolman, David ML15155A419 

Bolsky, Debbie ML15153A747 

Bombar, Timothy ML15156A938 

Bon, Eric ML15155B419 

Bonaceto, Helen ML15158A116 

Bondy, Mamie ML15159A512 

Boner, Karen ML15162B064 

Boner, Karen ML15162B110 

Bonetti, Donna ML15148A988 

Bonfanti, Fran ML15142A295 

Bonfield, Barbara ML15155A391 

Boniface, Kathryn ML15154A108 

Bonilla-Jones, Carmen 

Elisa ML15142A324 

Bonini, L. ML15160A046 

Bonitatibus, Amber ML15159B397 

Bonk, Denise ML15154B039 

Bonnell, Christine ML15162A117 

Bonner, Tracey ML15154B497 

Bonnett, Andrea ML15148B233 

Bonney, Patty ML15155A185 

Bookheimer, Donna ML15148A165 

Bookwalter, Eleanor ML15153A951 

Boone, Foster ML15154A165 

Boone, James ML15155A604 

Boone, Jim ML15154C045 

Boone, Merrill ML15148B395 

Boone, Michael ML15154A301 

Booth, Erik ML15155A627 

Booth, Fay ML15156A151 

Booth, John ML15140A165 

Booth, Nancy ML15254A396 

Booth, Nancy ML15162B091 

Booth, Nancy ML15162B144 

Booth, Richard ML15155A033 

Borame, Joan ML15153A578 

Borbon, Maria ML15155B690 

Borchardt, Jerrold ML15156B354 

Borcherding, Paul ML15154A106 

Bordegaray, Dana ML15154B370 

Bordelon, Tika ML15154B689 

Appendix E NUREG–2176 E-564 October 2016
Commenter 

ADAMS 

Accession # 

Borges, Gretchen ML15154B787 

Borich, Marilyn ML15154B760 

Borie, Edith ML15156A016 

Borland, Matthew ML15155A008 

Born, Steven ML15155C055 

Boroshok, Ruth ML15155A434 

Borske, Cindy ML15158A256 

Bortoletto, Federico ML15156B514 

Boshears, Michael ML15155B818 

Boshell, Willis ML15155A523 

Bosque, Edgar Chico ML15155A896 

Bossard, Eudell ML15159A217 

Bostelmann, Allan ML15155B686 

Bostic, Byron ML15148B340 

Bosworth, Carol ML15155A851 

Both, Bill ML15153B100 

Bottesch, Marla ML15153A962 

Bougie, Ronald ML15156A157 

Boulan, Cassidy ML15159A597 

Bourlotos, George ML15154A068 

Bouse, Ari ML15155B246 

Bousman, Thomas ML15155A758 

Bovee, Emily ML15154A215 

Bowden, Joan ML15156A054 

Bowen, Mary Ellen ML15154C238 

Bower, Mike ML15153A612 

Bowers, Gary ML15148A916 

Bowie, Mary ML15153B258 

Bowles, Sherry ML15141A709 

Bowley, Kat ML15158A110 

Bowman, Alix ML15154B564 

Bowman, Candy ML15155A325 

Bowman, Jennifer ML15159B018 

Bowman, Kenneth ML15158A134 

Bowman, Robin ML15155A733 

Boyce, Richard ML15153A913 

Boyd, Erin ML15154B858 

Boydston, Charlene ML15155A051 

Boyens, Marguerite ML15155A115 

Boyer, David ML15155B206 

Boynton, Robin ML15155C112 

Boza, Mario ML15148B073 

Brabson, Thomas ML15159A942 

Bracken, Fay ML15155A692 

Bracken, Kyle ML15154B144 

Bradbury, Margaret ML15159A154 

Bradford, Leslie ML15159A377 

Bradford, Mishelle ML15154B666 

Bradley, Al ML15154A401 

Bradley, Alan ML15153B048 

Bradley, Kathy ML15154C147 

Bradley, Mark ML15142A127 

Bradshaw, Barbara ML15156A581 

Bradshaw, Beverly ML15156A334 

Commenter 

ADAMS 

Accession # 

Bradshaw, John ML15154A743 

Bradshaw, Mary ML15162A563 

Bradshaw, Susan ML15154B209 

Brady, Cheri ML15153A981 

Brady, Daren ML15155B732 

Brady, Sarah ML15154B909 

Bragg, Emma ML15154B034 

Braithwaite, Georgia ML15142A084 

Bramblett, Sharon ML15153B036 

Bramlette, Jenny ML15155A195 

Branagan, Jackie ML15155B698 

Branch, Clair ML15162B089 

Branch, Clair ML15162B141 

Brandariz, Anita ML15148B306 

Brandes, Susan ML15159A427 

Brandon, Annette ML15154A214 

Brandon, Janet ML15154B779 

Brandon, Jennifer ML15154A931 

Brandow, Shanna ML15154B799 

Brandreth, Zena ML15159B306 

Brandstetter, Charles ML15148A139 

Brandt, Emily ML15154B185 

Brandt, V. ML15154A953 

Branfman, Judy ML15153A750 

Braoudakis, Spyros ML15155B439 

Bratcher, Deborah ML15159A139 

Bratcher, Suzanne ML15155A332 

Bratvold, Gretchen ML15148A872 

Braunlich, Julie ML15160A696 

Braus, Joseph ML15155A744 

Braverman, Tobi ML15156A593 

Brawley, Elizabeth ML15148A253 

Braxton, Angelika ML15162A554 

Brayfield, David ML15153A696 

Brazis, Christine ML15159A166 

Breakfield, Sandra ML15154B847 

Breakstone, Enid ML15154A182 

Brebner, Linda ML15154B139 

Breckinridge, Lynn ML15153A825 

Bredow, Cindy ML15159B070 

Breeden, Paul ML15156B016 

Brehm, Anita ML15154A140 

Breiding, Joan ML15160A057 

Breiling, Ellen ML15156A286 

Breitkreuz, Paul ML15140A132 

Brelsford, Susanna ML15154A343 

Bremen, Gary ML15159B232 

Bremmer, Faith ML15142A354 

Bremner, Deborah ML15159B214 

Brenner, Jared ML15153A658 

Brenner, Thomas ML15148B121 

Brents, Julie ML15154B696 

Brenza, Tina ML15155B034 

Bresnahan, Rose ML15155A522 

Appendix E October 2016 E-565 NUREG–2176
Commenter 

ADAMS 

Accession # 

Brewer, Jak ML15153A731 

Brewer, Jill ML15154A451 

Brewer, John ML15154B340 

Brewer, Laurel ML15158A123 

Brewer, Matt ML15154A424 

Brewer, Suzanne ML15159B295 

Breyman, Steve ML15162A058 

Bricic, Jasmina ML15148A170 

Bricker, Linda ML15159A843 

Brickner, Marvin ML15153A922 

Briddick, Gary ML15159A815 

Bridges, Linda ML15156A644 

Brief, Allan ML15156A032 

Brien, Ray ML15154B105 

Brier, Jonathan ML15148B146 

Briery, Georgia ML15156A007 

Brigger, Kathy ML15148A974 

Briggs, Janice ML15142A260 

Briggs, William C. ML15158A248 

Brigner, Liberty ML15159A536 

Brill, Elizabeth ML15154A723 

Brillet, Matthieu ML15155C058 

Brimm, Martha ML15156B221 

Brincka, Frank ML15156A797 

Brink, Tom ML15154B792 

Brinkman, John ML15154B028 

Britton, Joanne ML15162A304 

Broadwater, David ML15156A448 

Brobst, Robert ML15158A143 

Brocious, Pamela ML15140A239 

Brod, Natalie ML15160A779 

Broderick, Kathleen ML15142A075 

Brody, Alice ML15153B126 

Broer-Leroux, David ML15148B189 

Bromage, Joan ML15148B122 

Bronik, Darlene ML15156A451 

Bronner, Dennis ML15159A020 

Bronner, Eric ML15160A908 

Brooker, Eric ML15142A061 

Brooker, Gary ML15161A701 

Brooks, Olivia ML15154A122 

Brooks, Patricia ML15154B344 

Brooks, Sandy ML15155C235 

Brophy, Tracy ML15155A483 

Bros, Sam ML15154B386 

Brose, Janice ML15155A095 

Bross, Carol ML15160A770 

Brothers, Jill ML15156B426 

Broughton, Beatrice ML15156A321 

Browder, Erin ML15142A346 

Browder, Susan ML15154A157 

Brower, Cristina ML15154A418 

Brown, Gina ML15155A279 

Brown, Alan ML15159A655 

Commenter 

ADAMS 

Accession # 

Brown, Brandye ML15141A751 

Brown, Brian ML15154B804 

Brown, Craig ML15148A939 

Brown, Damon ML15159B093 

Brown, Daniel ML15162A044 

Brown, David ML15154B316 

Brown, Dorothy ML15153A675 

Brown, Duncan ML15158A010 

Brown, Elizabeth C. ML15142A189 

Brown, Greg ML15154B881 

Brown, Jeannine ML15148A782 

Brown, Jennifer ML15147A726 

Brown, Jessica ML15148B394 

Brown, Jim ML15154A034 

Brown, Joseph ML15156A505 

Brown, Kathleen ML15153A829 

Brown, Kiley ML15142A169 

Brown, Laura ML15141A461 

Brown, Lauren ML15154A327 

Brown, Leo ML15154A431 

Brown, Margot ML15142A363 

Brown, Mary ML15154A719 

Brown, Michael ML15141A471 

Brown, Myrna ML15155B803 

Brown, Nancy ML15153A509 

Brown, Neil ML15155C217 

Brown, Pat ML15159A642 

Brown, Robert ML15148B082 

Brown, Sally ML15154A760 

Brown, Stevan ML15141A729 

Brown, Susan ML15142A292 

Brown, Susan ML15142A297 

Brown, Terrence George ML15154A711 

Brown, Tina ML15140A135 

Browne, M. Lou ML15148A911 

Browne, R. J. ML15154B062 

Browne, Tina ML15158A126 

Brownell, Deirdre ML15154C132 

Brownell, Deirdre ML15155C026 

Browning, Cassandra ML15156B428 

Browning, Craig ML15155A190 

Brownlee, Cathy ML15142A263 

Brown‐Nesbit, Parker ML15156A776 

Brstow, Mary ML15156A021 

Bruck, Jonathan ML15153B228 

Brucker, Bob ML15148A841 

Bruegge, Debra ML15160A834 

Brumby, Val ML15153A546 

Brumleve, Charles ML15155A420 

Brummette, Carrie ML15156A454 

Brunelli, Anne ML15154A907 

Bruner, Edward ML15156A890 

Bruner, Linda ML15160A595 

Brunick, Cathy ML15154B101 

Appendix E NUREG–2176 E-566 October 2016
Commenter 

ADAMS 

Accession # 

Bruno, A. B. ML15142A058 

Brunson, Jane and John ML15162A506 

Brunson, Pat ML15147A707 

Brunswick, Susan ML15155A220 

Brunton, James ML15154A412 

Brushaber, Marcie ML15155B791 

Bruton, Babette ML15160A921 

Bryan, Ellen ML15159A480 

Bryan, Judith ML15154B514 

Bryant, Anita ML15141A736 

Bryant, Cade ML15159A240 

Bryant, Judith ML15159A055 

Bryer, Gladys ML15155B873 

Bubb, Ken ML15148B039 

Bucciere, Janet ML15154A340 

Buch, Anthony ML15155A993 

Buch, Sophia ML15140A280 

Buchan, Martha ML15154B338 

Buchanan, Ellen ML15159B405 

Buchsbaum, Judy ML15148B403 

Buck, Mary Lou ML15155B646 

Buckley, Nan ML15154A288 

Bucklin, Lucia ML15159A490 

Bucolo, James ML15153A688 

Budde, Sharon ML15155B658 

Budnik, Bradley ML15154C198 

Buenrostro, Marta Rico ML15155A260 

Buensuceso, Antonio ML15154B614 

Buerger, Michelle ML15162A070 

Buergermeister, Sabine ML15142A045 

Bugbee, Michael ML15142A055 

Buhowsky, Joseph ML15159A754 

Buil, Beyssa ML15156A449 

Bulatova, Nuriya ML15162A112 

Bull, Michael ML15159A245 

Bullock, Debbie ML15159B276 

Bump, Deborah ML15148B317 

Bunchongruksa, Sudarat ML15154A737 

Bunker, Diane ML15154B857 

Bunker, Greg ML15156B200 

Buonaiuto, John ML15156A072 

Buono, Carmen Dello ML15154B250 

Burch, Maryann ML15155C122 

Burdick, Rebecca ML15154C211 

Burgard, D. J. ML15155B567 

Burge, Ken ML15142A197 

Burge, Laura ML15156A161 

Burger, Elizabeth ML15142A107 

Burger, Nancy ML15155C219 

Burger, Scott ML15159B530 

Burgess, Anthony ML15148B311 

Burgess, Ryan ML15154C302 

Burk, Robert ML15148A164 

Burkart, Marie ML15140A227 

Commenter 

ADAMS 

Accession # 

Burke, Bonnie Margay ML15141A662 

Burke, Emily ML15159B413 

Burke, Gerald ML15155A504 

Burke, Maureen ML15154B668 

Burke, Patricia ML15156B108 

Burkhart, Don ML15154A605 

Burkhart, Imogene ML15147A737 

Burks, Connie ML15154A625 

Burks, James ML15156A718 

Burks, Paul ML15154A275 

Burlew, Jessica ML15154B954 

Burnash, George ML15159A124 

Burnell, Nathan ML15155A293 

Burns, Bruce ML15148B136 

Burns, Catherine ML15153A519 

Burns, Catherine ML15154B568 

Burns, Dan ML15154A154 

Burns, Laurel ML15158A171 

Burns, Lyn ML15160A076 

Burns, Rebecca ML15148B305 

Burns, Terry ML15155B716 

Burns, Vikki ML15160A708 

Burr, Marcia ML15156A608 

Burress, Edward ML15148B118 

Burstein, Mimi ML15159B233 

Burt, John ML15155A894 

Burtch, Robert ML15142A028 

Burton, Christina ML15158A225 

Burton, Matthew ML15158A232 

Burwasser, David ML15153A890 

Burwell, Carol ML15156A670 

Busacco, Jeanne ML15155B822 

Busani, Elena ML15155B364 

Bush, Nancy ML15159B494 

Bush, Victoria ML15159A575 

Buslot, Chantal ML15148B174 

Busnach, Nadine ML15155B661 

Bustamante, Desiree ML15162A285 

Buster, Katey ML15154A434 

Bustos, Ray ML15148A131 

Butenko, Melody ML15162A699 

Butkiewicz, Mike ML15155B447 

Butkus, Joann ML15159A162 

Butler, Amber ML15148B066 

Butler, Donna ML15156A009 

Butler, Linda ML15156B053 

Butterfield, Colleen ML15154B376 

Butterfield, Doris ML15155C193 

Butterworth, John ML15141A498 

Butterworth, Leslie ML15148A941 

Buttles, Kathryn ML15153A797 

Button, Pat ML15156B243 

Button, Reyna ML15154C309 

Butts, Judith ML15156B077 

Appendix E October 2016 E-567 NUREG–2176
Commenter 

ADAMS 

Accession # 

Buu, Hieu ML15140A170 

Buxman, Ryan ML15154A705 

Buyea, Thomas ML15155A458 

Byland, John ML15159A897 

Byrd, Darlene ML15154A044 

Byrer, Dianne ML15154B519 

Byrne, Carolyn ML15156A145 

Byrne, Rosemary ML15140A167 

Byrnes, Leslie ML15155A153 

Byrnes, Richard ML15155C158 

C., Erin ML15158A291 

C., Lynne ML15155B201 

C., Max ML15155A135 

C., Michael ML15154A220 

C., Mike ML15148B445 

C., Shaz ML15155B189 

C., Sylvie ML15142A349 

C., T. ML15154A821 

Caballero, Luis ML15162A050 

Cabrera, Luis ML15155B805 

Cachopo, Patricia ML15153A681 

Cadot, Andrew ML15154B373 

Cadwallader, Terry ML15154C101 

Cafarelli, Cenie ML15142A309 

Caflisch, Kathie ML15156B150 

Cahillane, Leila ML15159A057 

Caillouette, Brook ML15155B314 

Cain, Lisa ML15156B519 

Calambro, Leslie ML15160A789 

Calcagno, Philip ML15154A740 

Caldwell, Dotty ML15158A064 

Caldwell, Ellen ML15154A467 

Caldwell, Kathleen ML15159A626 

Caldwell, Myron ML15156B295 

Caldwell, Robert ML15153A973 

Callahan, Loretta ML15155A607 

Callard, Diane ML15148A716 

Callow, Wayne ML15148A714 

Calvert, Mary Ann ML15158A160 

Calvert, Rick ML15148A715 

Camerman, Virginia ML15148B290 

Cameron, Cami ML15154B099 

Cameron, Jean ML15156A883 

Camp, David ML15159A901 

Camp, Timothy ML15159A296 

Campbell, Allan ML15159A645 

Campbell, Grant ML15155A310 

Campbell, Karolyn ML15156A069 

Campbell, Susan ML15160A890 

Campbell, Theresa ML15154B616 

Canale, Susan ML15158A236 

Candela, Macyle ML15153A820 

Candelaria, Tiffany ML15155A052 

Candlin, Celia ML15154C184 

Commenter 

ADAMS 

Accession # 

Canepa, John ML15147A724 

Canning, Christine ML15156A063 

Canning, John ML15154B679 

Canning, Rick ML15155A740 

Canning, Tom ML15155A881 

Cannon, Elizabeth ML15154C164 

Cannon, John ML15162A552 

Cannon, Maxine ML15162A550 

Cannon, Thomas ML15156A004 

Canny, Carlyn ML15159A112 

Cantu, Eva ML15155B971 

Cantu, Roel ML15155C214 

Caolo, Rosemary ML15154A124 

Capezzuto, Raymond ML15154B462 

Capone, Shantell ML15159A002 

Capotorto, Jeanette ML15156A313 

Cappa, Karen ML15156A643 

Cappuccio, Sharon ML15160A650 

Capstick, Hilary ML15154C102 

Capurro, Lyn ML15159A735 

Carden, E. ML15154B264 

Cardoso, Toby ML15154A138 

Cardwell, Paul ML15156A791 

Carey, Susan ML15156A795 

Cargman, Jered ML15156B497 

Cargulia, Guy ML15155A675 

Carideo, Ida ML15156B049 

Carideo, Ida ML15159B373 

Carl, Jeannie ML15155A917 

Carley, James ML15159B470 

Carlin, Catherine L. ML15154B267 

Carlin, Catherine L. ML15154C025 

Carlin, Catherine L. ML15154C151 

Carlino, Thomas ML15140A194 

Carlisle, Shelley ML15154A834 

Carlisle, Thomas ML15155A407 

Carlson, Carol ML15158A257 

Carlson, Sandy ML15162A274 

Carlton, Thomas ML15140A176 

Carman, Heather ML15154B532 

Carman, Iris ML15159B406 

Carmean, Roxann ML15159A338 

Carne, Carol ML15156B076 

Carney, Cheryl ML15141A676 

Carney, KC ML15153A435 

Caro, Steve ML15162B089 

Caro, Steve ML15162B138 

Carollo-Zeuner, Christine ML15141A635 

Carpenter, Dale ML15162B079 

Carpenter, Dale ML15162B127 

Carpenter, Gary ML15155A741 

Carpenter, Matthew ML15155A228 

Carpenter, Rory ML15155B705 

Carpenter, Steven ML15155A999 

Appendix E NUREG–2176 E-568 October 2016
Commenter 

ADAMS 

Accession # 

Carpenter, Victoria ML15148A694 

Carper, Robert ML15154C140 

Carr, Brittany ML15159A620 

Carr, D. ML15154C081 

Carr, Gaile ML15155B796 

Carrell, James ML15154B821 

Carrier, Cornelia ML15154B941 

Carrier, Paula ML15159A475 

Carriere, Richard ML15156A949 

Carringer, Nancy ML15160A768 

Carrington, Martha ML15153B214 

Carroll, Donna ML15159B466 

Carroll, John ML15154A798 

Carroll, Mary A. ML15155A384 

Carroll, Niall ML15155B928 

Carson, Debbie ML15159B369 

Carswell, Brandon ML15159A361 

Carter, Carl ML15148A630 

Carter, Gary ML15153B169 

Carter, Jackie ML15156A022 

Carter, Jacqueline ML15154B366 

Carter, Michelle ML15160A629 

Carter, Natalie A. ML15159A871 

Cartwright, Jennifer ML15154B951 

Carvajal, Mauricio ML15154C114 

Case, Alex ML15158A107 

Caseau, Sheri ML15155A176 

Casey, Jill ML15141A562 

Cashman, Sharon ML15155A874 

Caskey, Mark ML15154B356 

Caskey, Sally ML15154B863 

Caskey, Sally ML15156A190 

Caspar, Julia ML15148A926 

Casper, Laurel ML15159B553 

Cassar, Kristine ML15154B365 

Cassasdy, Marsh ML15141A579 

Cassel, Candice ML15155C233 

Cassidy, David ML15154C242 

Castaneda‐Mendez, Kicab ML15153B286 

Castellon, Leigh Anne ML15155B039 

Casten, Liane ML15155A333 

Castillo, Anthony ML15154C189 

Castillo, Esther ML15159B085 

Castner, Rebecca ML15155B819 

Castri, Serenella ML15160A044 

Caswell, Gail ML15148A721 

Caswell, Susan ML15154A305 

Cathcart, Melissa ML15156A690 

Catlin, Linda ML15160A971 

Catskill, Clover ML15154B442 

Caudill, John ML15158A138 

Caudill, Lori ML15162A653 

Cavalier, Andre ML15155A417 

Cavan, Noz ML15148B264 

Commenter 

ADAMS 

Accession # 

Cavasian, Edward ML15154B732 

Cayton, Chris ML15156A554 

Cease, Jane ML15155A416 

Cenc, John ML15155A021 

Cerny, Jayne ML15153B060 

Cerrella, Joseph ML15156A084 

Cerretti, Robert ML15148A848 

Cervene, Amy ML15154C307 

Cervene, Shirley ML15141A748 

Cesnik, Michael ML15153A724 

Ch, Lv ML15154A558 

Chacich, Elizabeth ML15153B142 

Chadwick, Carina ML15159A123 

Chaffee, Shon ML15140A138 

Chalfen, Karen ML15142A134 

Chalker, Mikki ML15154B952 

Challenger, Brett ML15156B410 

Challinor, Suzanne ML15154B061 

Chambers, Nola ML15161A703 

Chambers, Patricia ML15148A923 

Chambers, Robert ML15156B478 

Chan, Nancy ML15159A451 

Chandler, Randy ML15155A076 

Chandler, Vickie ML15148B429 

Chaney, David ML15156B249 

Chang, Bryna ML15155C015 

Chang, Patricia ML15155B760 

Changus, Carol ML15155B688 

Chanon, Renee ML15155A380 

Chapdelaine, Perry ML15156A549 

Chapin, Robert ML15162B044 

Chapin, Robert ML15162B118 

Chapman, Antony ML15158A166 

Chapman, Charles ML15148A190 

Chappell, Carol ML15154A164 

Char, Elizabeth ML15156B515 

Charest, Karry ML15160A962 

Charleston, Robert ML15159A510 

Charnas, Kelley ML15160A081 

Charnas, Kevin ML15142A254 

Charter, Donna ML15158A168 

Chase, Cheryl ML15154C080 

Chase, Felicia ML15162B089 

Chase, Felicia ML15162B133 

Chase, Janet ML15156A141 

Chase, Linda ML15154A189 

Chasin, Barbara ML15156A079 

Chasteen, Don ML15154B888 

Cheffi, Gisele ML15154C177 

Chelland, Ron ML15153A472 

Chelmecki, Patricia ML15140A271 

Chemai, Beverly ML15159B519 

Chen, Alicia ML15155B861 

Chen, Allan ML15159A647 

Appendix E October 2016 E-569 NUREG–2176
Commenter 

ADAMS 

Accession # 

Chen, Grace ML15159A242 

Chen, Te-Fen ML15154B928 

Chenoweth, Karen ML15156B250 

Cheo, Dorothy ML15142A157 

Chernysheva, Elena ML15159A931 

Cherubin, Elizabeth ML15148B068 

Chesire, Chris ML15159B437 

Cheslock, Michael ML15153A649 

Chianis, Antonia & Andrew ML15158A290 

Chiappa, Russell ML15160A911 

Child, Katrina ML15141A691 

Chirillo, James ML15155B963 

Chisari, Andrea ML15154B995 

Chisholm, Angell ML15141A667 

Cho, T. ML15155A259 

Choi, Ali ML15142A116 

Chopyak, Anne ML15148B223 

Chorba, Louis ML15158A012 

Choy, Duane ML15154B248 

Chrissos, H. L. Chris ML15159A039 

Christ, Mlou ML15154B752 

Christ, Ronald ML15153A875 

Christeller, Lois ML15156B416 

Christensen, Deb ML15154B706 

Christensen, Roger ML15156A601 

Christenson, Amy ML15155B605 

Christiansen, Sue ML15155B995 

Christianson, Chris ML15160A961 

Christie, Roxanne ML15159B371 

Christine, Dena ML15159A411 

Christman, Mary ML15153B109 

Christoff, Stephanie ML15154B129 

Christopoulos, James ML15155A361 

Christy, Alice ML15153A767 

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Christy, Mary ML15159B141 

Chung, Winnie ML15141A753 

Chuplis, Cindy ML15162A402 

Church, Mary Lou ML15155A430 

Churchill, Rhonda ML15159A513 

Churchman, Pat ML15148B196 

Chynoweth, Iris ML15140A189 

Cianciotti, Frank ML15156A326 

Cifuentes, Simone ML15159A908 

Cignoli, Karen ML15159A286 

Ciliberti, Ava ML15154A208 

Cisna, Todd ML15148B117 

Citron, Alan ML15155B965 

Civitate, Gregory ML15162A589 

Clagett, Kathleen ML15156A909 

Claiborn, William ML15160A535 

Clair, Kate ML15155A328 

Clapp, Jonathan ML15160A858 

Clapp, Linda ML15159B286 

Commenter 

ADAMS 

Accession # 

Clark, Alexander ML15155A297 

Clark, Carol ML15154A396 

Clark, Colleen ML15148A960 

Clark, Diane ML15153A944 

Clark, Diane ML15154A168 

Clark, Elaine ML15148A970 

Clark, Geoffrey ML15153A997 

Clark, Greg ML15158A084 

Clark, Jamie ML15148B384 

Clark, Jean ML15159A904 

Clark, Jenny ML15155A308 

Clark, Joe ML15156A026 

Clark, Jr., James A. ML15156A115 

Clark, Judy ML15142A142 

Clark, Kathleen ML15159A461 

Clark, Kenneth ML15156B130 

Clark, Leigh ML15158A031 

Clark, Maxine ML15153A763 

Clark, Morgan ML15153A793 

Clark, Rebecca ML15162A509 

Clark, Roger ML15154C272 

Clark, Ruth ML15156B149 

Clark, Stephanie ML15154B908 

Clark, Susan ML15156A607 

Clark, Todd ML15147A758 

Clark, Toni ML15148A141 

Clarke, Bob ML15154B879 

Clarke, Darrell ML15142A056 

Clarke, Tom ML15159B015 

Clasemann, Joel ML15159A423 

Clason, Susanna ML15141A779 

Claus, Carol ML15154B245 

Clausen, Nina ML15153B225 

Clausing, Melinda ML15154A038 

Clayton, David ML15156A319 

Clayton, David ML15159A703 

Cleaver, Melissa ML15142A083 

Clegg, Ann ML15160A905 

Clem, Jessica ML15156B074 

Clemens, Beatrice ML15156A094 

Clemens, Robert ML15156A436 

Clemens, Scott ML15154B784 

Clements, Scott ML15147A715 

Cleve, Della ML15162A103 

Clewett, Barbara ML15159A036 

Clifford, Rosemary ML15154B994 

Clifton, Robert ML15155A899 

Clipka, Mike ML15155C172 

Cloud, Michael ML15155A395 

Clough, Cyndi ML15155A529 

Clough, Steve ML15141A762 

Clower, Kimberly ML15154A794 

Coahran, Scott ML15154A037 

Coakley, Michele ML15154C157 

Appendix E NUREG–2176 E-570 October 2016
Commenter 

ADAMS 

Accession # 

Coates, Mark ML15156A332 

Cobb, Priscilla ML15155B096 

Cobb, Robert ML15156A959 

Cobb, Sandra ML15156A557 

Cobb, Tanya ML15153B269 

Cobb-Adams, Diane ML15159A508 

Coburn, Donald ML15156B460 

Cocco, Brian ML15160A936 

Cochran, Harold ML15142A290 

Cochran, John ML15155C061 

Cocke, Sandra ML15154A152 

Cocks, Verna Bloom ML15160A051 

Codina, Edward ML15153A927 

Coe, Michael ML15159B087 

Coeburn, Jeanette ML15155A605 

Coffey, Margery ML15154B368 

Coffin, Doug ML15155A017 

Cogar, Nicki ML15161A695 

Cogelja, Izabela ML15162A137 

Cohen, Bernard ML15148B440 

Cohen, Bernard ML15153A760 

Cohen, Bruce ML15140A066 

Cohen, C. ML15156A456 

Cohen, Elaine ML15156A205 

Cohen, Fritzi` ML15153A849 

Cohen, Harriet ML15154A854 

Cohen, Howard ML15155A936 

Cohen, Howard ML15153A585 

Cohen, Howard ML15156A274 

Cohen, Judith ML15155B968 

Cohen, Judy Ann ML15158A025 

Cohen, Patricia ML15148B080 

Cohen, Paula ML15154A849 

Cohen, Wendi ML15159B410 

Cohn, Robert ML15156B140 

Colborn, Sheree ML15159A081 

Coldwell, Sherilyn ML15155B583 

Cole, Brian ML15155A731 

Cole, Elizabeth ML15154A076 

Cole, Elizabeth ML15155A664 

Cole, Joan ML15156A209 

Cole, Merrill ML15142A284 

Cole, Patricia ML15156A331 

Cole, Tracy ML15140A106 

Coleman, Nina ML15140A143 

Coleman, Richard ML15156A080 

Colerich, Edward ML15148B131 

Coley, Linda ML15154B549 

Collar, Michelle ML15153B180 

Collas, Judith ML15148A637 

Collecchia, Geri ML15158A292 

Collimore, Robert ML15156A036 

Collins, Carol ML15154A446 

Collins, Jeffrey ML15156B106 

Commenter 

ADAMS 

Accession # 

Collins, Kathy ML15153B175 

Collins, Megan ML15153A787 

Collins, Teresa ML15154C145 

Collinsworth, Van ML15156A294 

Collison, Chelsea ML15140A248 

Colllins, Greg ML15141A648 

Colombini, Denise ML15153A761 

Colombo, Kathleen ML15142A270 

Colson, Lynn ML15156A609 

Colter, Alfred ML15153B030 

Colvin, Felicia ML15154A537 

Combs, Adele ML15148B142 

Combs, Cris ML15155A248 

Combs, Debi ML15159B071 

Combs, William ML15148B374 

Commander, Wanda ML15148B323 

Commons, Judy ML15140A007 

Como, Marianna ML15155A830 

Compher, Margaret ML15162A712 

Comrack, Janine ML15142A048 

Comstock, Ginger ML15148A267 

Conant, Deborah ML15155A790 

Conelley, B. ML15148B362 

Confer, John ML15160A549 

Conklin, Joyce ML15155A345 

Conklin, Lindsay ML15160A966 

Conlan, Mike ML15156B398 

Connell, Brendan ML15159A705 

Connelly, Walter ML15155C236 

Conner, Art ML15153A320 

Conner, Steve ML15155A355 

Connick, Cherie ML15141A697 

Connolly, James ML15154B670 

Connolly, Joe ML15148A135 

Connolly, Makenna ML15162A567 

Connor, Arthur ML15156B327 

Connor, David ML15148B391 

Connor, Elizabeth ML15154A363 

Connors, Joe ML15159B219 

Conrad, Lori ML15154B728 

Conroy, Beverly Ann ML15155A956 

Conroy, Eleanor ML15148B143 

Conroy, James ML15155A466 

Conroy, Laurie ML15156A267 

Conroy, Peggy ML15156A064 

Conroy, Thomas R. ML15142A038 

Constance, Bianca ML15155A700 

Conti, Sandra ML15154B645 

Contreras, Cristian ML15154A416 

Conway, Clayton ML15155A371 

Conway, Julianne ML15155B879 

Cook, Bruce ML15155B931 

Cook, Cherie ML15156A492 

Cook, Gary ML15154A190 

Appendix E October 2016 E-571 NUREG–2176
Commenter 

ADAMS 

Accession # 

Cook, Gary ML15154B930 

Cook, Geoffrey ML15155B542 

Cook, Patty ML15155A710 

Cooke, Douglas ML15154B720 

Cooksey, Marti ML15148A723 

Cooley, Marian ML15155A048 

Cooley, Richard E. ML15155B955 

Coons, Christine ML15154A366 

Cooper, Charlene ML15155A142 

Cooper, Edith ML15154C038 

Cooper, Gwendalle ML15155B613 

Cooper, Isabella ML15156A073 

Cooper, Joe ML15159A077 

Cooper, Michael ML15154A350 

Cooperman, Allan ML15155C107 

Cooperman, Sima ML15155B234 

Copanos, Beth ML15148B119 

Cope, Peggy ML15158A140 

Cope, William ML15156B356 

Copeland, Jeanette ML15156A558 

Copeland, Sue ML15155A196 

Coplan, Rosemary ML15153A540 

Coppotelli, Heide 

Catherina ML15155A047 

Copulsky, Steve ML15155A275 

Corby, Kathleen ML15155B252 

Corcacas, Phyllis ML15142A287 

Cordero, Carole-Anne ML15162B091 

Cordero, Carole-Anne ML15162B153 

Corey, Sheffield ML15154B767 

Corkey, Peter ML15148A184 

Corkran, Thomas ML15156A129 

Cormier, Jerry ML15156A146 

Cormier, Joyce ML15148A824 

Cornelia, Jared ML15141A618 

Cornell, Denice ML15158A153 

Cornelsen, Christy ML15153A906 

Cornett, Nina ML15154A365 

Cornetta, Eric ML15142A244 

Cornish, Christopher ML15155B655 

Corr, F. ML15158A164 

Corradini, Pamela ML15155A468 

Corredoira, Carmen ML15159B224 

Corriere, Caryn ML15154B223 

Corriere, Jim ML15148A907 

Corrigan, Jim ML15153A493 

Corrigan, Sean ML15155C054 

Corrigan, Theresa ML15159A249 

Corry, Ronit ML15156A649 

Cortez, Loyd ML15142A144 

Corwin, Diana ML15148B236 

Coscione, Brian ML15156B433 

Cosgrove, Pamela ML15153B001 

Costa, Lynn ML15155B236 

Commenter 

ADAMS 

Accession # 

Costa, Sandra ML15156A697 

Costanzo, Linda ML15147A777 

Costello, Anthony ML15162A582 

Costello, Sheri ML15162A583 

Costigan, Andrew ML15154B049 

Cotham, Keith ML15159B430 

Cotrell, Katharine ML15158A246 

Cotta, Mary ML15160A665 

Cottrell, David ML15148A946 

Cottrell, David ML15154A330 

Cottrell, David ML15154A473 

Cottrell, David ML15154B967 

Cottrell, David ML15155A155 

Cotturo, Mary L. ML15159A067 

Couch, Jaime ML15156B328 

Couch, Jayda ML15153B046 

Couch, Mike ML15154B900 

Couch, Sandra ML15156B213 

Coughlin, John ML15156A668 

Coulaz, Yolanda ML15159A911 

Coulson, Sue ML15154B835 

Council, Barbara ML15155A348 

Countryman, Carol ML15154C134 

Countryman-Mills, Gayle ML15148B338 

Courliss, William ML15153A991 

Courtney, Donald ML15148B135 

Cousino, Joyce ML15154A904 

Cousins, Vera ML15155A198 

Cousins, Virginia ML15153A488 

Coval, Deirdre ML15154B854 

Covell, Sandi ML15162A079 

Covington, Diana ML15158A282 

Covington, Lainie ML15159B347 

Covington, Laurel ML15154A052 

Covney, Chris ML15160A605 

Covney, Chris ML15162A069 

Cowan, Donald ML15159A053 

Cowie, Virginia ML15154A127 

Cowin, Caryn ML15159A635 

Cowles, Traver ML15155A029 

Cox, Chris ML15148B126 

Cox, David ML15154A557 

Cox, John ML15148A908 

Cox, Lanie ML15155B926 

Cox, Mary ML15148B145 

Cox, Sharon ML15154B609 

Cox, Sharon ML15155A319 

Coyle, N. ML15153A926 

Coyne, Ellis Heyer ML15155A682 

Coz, Ann ML15159B132 

Cozzi, Steven ML15156A868 

Cracchiolo, Anthony ML15140A224 

Craft, Robin ML15155A063 

Craig, Susan ML15161A682 

Appendix E NUREG–2176 E-572 October 2016
Commenter 

ADAMS 

Accession # 

Crandall‐Bear, Joanne ML15154A863 

Crane, Jeff ML15154A576 

Crane, Marcella ML15159A042 

Cranmer, Pat ML15155A841 

Crannell, Raymond ML15158A155 

Cranston, Jr., Andrew ML15156A201 

Cranston, Thomas ML15153B077 

Crase, Kirsten ML15161A671 

Crase, Steve ML15155C069 

Cratty, Bruce ML15156A177 

Crawford, Donald ML15155A676 

Crawford, Jason ML15154C049 

Crawford, Licia ML15159B525 

Crawford, P. E. ML15159A233 

Creagh, Donna ML15155A215 

Cresseveur, Jessica ML15154A249 

Crickenberger, Ray ML15162A233 

Crider, Erika ML15159A961 

Crim, Noel ML15155B062 

Crispin, Kim ML15159B490 

Crist, Michael ML15141A658 

Criswell, Gary ML15155A273 

Critser, Jackie ML15159A251 

Crittenden, Kathleen ML15156A457 

Crittenton, Cynthia ML15148A983 

Crockett, Shirley ML15148A894 

Croft, Samuel ML15141A421 

Crommett, Jennifer ML15153B244 

Cronin, Donald ML15154A174 

Cronin, Gary ML15154A941 

Croom, Carolyn ML15155B674 

Crosby, Donald ML15156A550 

Crosiglia, Nella ML15155C165 

Cross, Dave and Rita ML15154B925 

Cross, Heather ML15154A952 

Cross, Russ ML15147A716 

Crotwell, Kd ML15155A865 

Crowden, Michael ML15154A381 

Crowe, Edith ML15153B226 

Crowe, Nancy ML15148B235 

Crowley, Jeanne ML15155B802 

Crowley, Lori Ann ML15159A613 

Crozier, John ML15154C246 

Crozier, Mary ML15154C036 

Cruger, Kurt ML15155A446 

Cruickshank, Lynda ML15154B873 

Cruikshank, Anna ML15156A041 

Crumpacker, Barb ML15141A625 

Crupi, Kevin ML15159A151 

Cruz, Marian ML15154A306 

Cruz, Marian ML15154A868 

Csaszar, John ML15147A782 

Csenge, Debra ML15162A400 

Csenge, Rich ML15160A900 

Commenter 

ADAMS 

Accession # 

Csicsery-Ronay, Elizabeth ML15155C199 

Cuadrado, Lola ML15147A718 

Cucchiara, Philip ML15142A110 

Cuff, Kermit ML15155A213 

Culbert, Laurette ML15155B079 

Cull, David ML15159B016 

Cullinan, Sarabeth ML15162A065 

Culp, Philip ML15148A965 

Culver, Bruce ML15156A931 

Cummings, Connie ML15161A639 

Cummings, George ML15154A432 

Cummings, Kady ML15155C168 

Cundiff, William ML15148B370 

Cunha, Carlos ML15160A977 

Cunningham, Alan ML15155A657 

Cunningham, Cynthia ML15153A586 

Cunningham, Helen ML15154B056 

Cunningham, Jennifer ML15155A320 

Cunningham, Khari ML15155B070 

Cunnius, Cheryl ML15141A785 

Cuolahan, Sylvia ML15154B335 

Cupp, Stephanie ML15154A222 

Curia, Peter ML15154C285 

Curley, Frank ML15141A764 

Curow, Jerry ML15156A699 

Currey, Wally ML15159B043 

Currey, Wally ML15159B051 

Curry, Donna ML15155B790 

Curtis, Candy ML15153A892 

Curtis, Colleen ML15156A976 

Curtis, Frank ML15153A481 

Curtis, Kevin ML15141A706 

Curtis, Marie ML15156A452 

Curtler, III, Hugh ML15148A720 

Cuticka, Sheri ML15142A353 

Cutler, Annalisa ML15161A681 

Cutright, Sheri ML15154A232 

Cutting, Kimberly ML15155A424 

Cutting‐Brady, Joanna ML15154A160 

D., Susan ML15155B929 

Dabanian, Kathylynn ML15159A356 

Dabrowski, Linda ML15153A955 

Dace, Letitia ML15153B016 

Dahl, Kevin ML15155A868 

Dahlberg, Nancy ML15153B222 

Dahlgren, Shelley ML15154B983 

Dahoda, Jeff ML15142A039 

Dail, Michelle ML15154A110 

Dailey, Christa ML15155B381 

Daily, G. Allen ML15155A880 

Daiss, Becky ML15148B322 

Dakouzlian, Md ML15154A501 

Dal Cais, Sandra ML15153A856 

Dalal, Namita ML15140A105 

Appendix E October 2016 E-573 NUREG–2176
Commenter 

ADAMS 

Accession # 

Dale, Byron ML15156A259 

Dale, Felicia ML15156B373 

D'Alessandro, Jenette ML15142A365 

D'Alessandro, Keith ML15142A318 

Dalition, Mitch ML15155A129 

Dalnekoff, Cecilia ML15154A928 

D'Amato, Susan ML15156A323 

Dame, Laura ML15156A160 

Dameron, Susan ML15148B230 

Dammert, Colleen ML15154B735 

Damon, Rhea ML15162A626 

Dander, Katherine ML15148B081 

Danehy, Cecile ML15155C198 

Danek, Richard ML15154B629 

Daniell, David ML15148A910 

Daniels, Elizabeth ML15153A783 

Daniels, Joan ML15154B254 

Daniels, Michael ML15154B667 

Daniels, Patricia ML15156B520 

Daniels, Stacey ML15160A869 

D'Anna, Tina ML15154B897 

Dannelley‐Mccree, Sylvia ML15153B301 

Dannhardt, Beth ML15153A712 

Danos, Teri ML15156A059 

Dantonio, Lisa ML15155A900 

Darby, Sara ML15156B251 

D'Arco, Donna ML15147A739 

Darcy, Kevin ML15162A642 

Dare, Cheryl ML15142A122 

Darilek, Marilyn ML15162A703 

Daskal, Sharon ML15154C037 

Dater, Suzanne ML15153A326 

Dauerty, Barbara ML15155C003 

Daugherty, Amy ML15153A587 

Daugherty, Bret ML15141A458 

Dauphin, Jill ML15159B505 

Davee, Heidi ML15159B489 

Davenport, Cheryl ML15161A658 

Davenport, Jeanne ML15148A933 

Davenport, L. B. ML15153A510 

Davenport, Susan ML15155B348 

Davenport, Susan ML15156B005 

Davidson, Amber ML15158A024 

Davidson, Bruce ML15154A430 

Davidson, David ML15159A341 

Davidson, Kathryn ML15159A170 

Davidson, Penny ML15154A414 

Davidson, Sharon ML15154A349 

Davidson, Sharon ML15154A532 

Davies, Charlene ML15153A791 

Davies, Gyllian ML15148B298 

Davine, Jill ML15153A921 

Davis, Clark ML15158A194 

Davis, Cynthia ML15155B586 

Commenter 

ADAMS 

Accession # 

Davis, Donna ML15156B177 

Davis, Eleanor‐Ann ML15154A615 

Davis, Ellie ML15140A004 

Davis, Irene ML15158A190 

Davis, Jacqueline ML15159A818 

Davis, Janice ML15156B509 

Davis, John P. ML15155A907 

Davis, Jolynn ML15155A117 

Davis, Kathleen ML15140A009 

Davis, Kevin ML15155B778 

Davis, Lynn ML15159B518 

Davis, Marilyn ML15153A596 

Davis, Mary ML15156B451 

Davis, Michelle ML15156A942 

Davis, Randy ML15154B511 

Davis, Roger ML15154B225 

Davis, S. K. ML15153B256 

Davis, Sarah ML15159B356 

Davis, Sharon ML15155A531 

Davis, Shirley ML15156B162 

Davis, Shonna ML15154B958 

Davis, Susan ML15147A769 

Davis, WIlliam ML15154C054 

Dawdy, Kenneth ML15160A089 

Dawdy, Sandra ML15141A589 

Dawes, Steven ML15155A039 

Dawson, Elizabeth ML15154C012 

Dawson, Kathyrn ML15154B674 

Day, Charlie ML15155A028 

Day, Christopher ML15140A236 

Day, Cris ML15156A183 

De Baca, Sylvia ML15160A722 

de Bruyn Kops, Julianna ML15154A195 

De Castro, Brian ML15155A991 

De Feo, Joseph ML15154B819 

De Gregorio, Ermanno ML15153A876 

de la Rosa, Marco ML15148B358 

De La Rosa‐Young, Maria ML15148A186 

De Laval, Jerry ML15148B402 

De Leon, Lori ML15141A621 

De Lima, Carol ML15159A116 

De Lu, Dirk ML15148A839 

De Mars, Matthew ML15162A511 

De Raat, Maia ML15154B773 

De Saglietto, Eve ML15159A481 

De Vlaming, Victor ML15159A819 

De Vos, Paul ML15154B081 

Deal, Brandie ML15148B006 

Deal, Jeff ML15154C191 

Dean, June ML15155B094 

Dean, Sue ML15156B392 

Deane, Tricia ML15156B207 

Debing, Therese ML15153A347 

Deboer, Elisa ML15155A825 

Appendix E NUREG–2176 E-574 October 2016
Commenter 

ADAMS 

Accession # 

Decarlo, Anthony ML15156A459 

Deciccio, Robyn ML15148A760 

Deck, Avis ML15148B042 

Decker, Eleanor ML15155A085 

Deddy, John ML15156A779 

Dee, Diana ML15155C012 

Defauw, Rachel ML15159A332 

Defazio, Richard ML15148A906 

Defilippo, Terri ML15153A679 

Defoggi, Virginia ML15148B204 

Degges, Frank ML15156B481 

Dehn, Dennis ML15142A205 

Deist, Barry ML15153B167 

DeJong, Joan ML15156A584 

Dekalb, Sue ML15155B412 

Del Gado, Tanya ML15154A925 

Del Valle, Javier ML15155A346 

Delaney, Elisha ML15155A232 

Delaney, Janet ML15155B910 

Delateur, Marc ML15142A281 

Deleone, Barb ML15148B434 

Delgado, Crystal ML15158A141 

Delgado, Sasha ML15160A655 

Dell ' Italia, Patrick ML15159A734 

Dellera, Jayne ML15140A046 

Dellinger, Robert ML15156A103 

Deloff, D. ML15156A852 

Delorenzo, Pete ML15156B339 

Deluna, Marie Claire ML15155A457 

Demarais, Jackie ML15158A218 

Demarest, Kandie ML15141A679 

Demarest, Russ ML15147A763 

Demaria, Karen ML15155C181 

Demers, Melanie ML15156A594 

Demin, Vladimir ML15162A737 

Demott, Lisa ML15160A652 

Demott, Margaret ML15154A173 

Dempsey, Sheila ML15153A754 

Dempsey, Stephen ML15154B313 

Denberg, Judy ML15160A872 

Denison, James ML15153A833 

Denison, Lou Anna ML15159B567 

Denn, Gina ML15141A650 

Denninger, Sandra ML15154A806 

Dennis, Gudrun ML15154A903 

Dennison, Brett ML15155C018 

Denny, Rachael ML15158A073 

Densing, Lindsey ML15155A168 

Densmore, Paul ML15154B734 

Dent, Resi ML15162A119 

Dent, William ML15162A094 

DePante, Michael ML15159A248 

Depew, Robert ML15158A266 

Deppong, Genevieve ML15159A140 

Commenter 

ADAMS 

Accession # 

Depue, David ML15155C189 

Der, Don ML15155C140 

Derasary, Lara ML15159A549 

Derbick-Johnson, Mary ML15155A482 

Derbort, Wendy ML15148A272 

Derfner, Phyllis ML15156A606 

Dermody, Cathy ML15141A696 

Deroche, Russel ML15155B075 

Derrickson, Ray ML15154B915 

D'Errico, Didi ML15153A358 

Dervin, John ML15154A631 

DeSanctis, Joseph ML15148B176 

Desarbe, Michael Lauren ML15156A260 

Deschenes, Paul ML15156A081 

Desecki, Nancy ML15154B458 

Destrooper, Chantal ML15154A339 

Detert, Judith ML15154A133 

Detrick, Mary ML15159A164 

Dettmann, Barbara ML15156A123 

DeVine, Kelly ML15154A013 

Devinney, Claudia ML15148B336 

Devlaeminck, Michelle ML15159A774 

Devlin, III, Neil ML15159B473 

DeWitt, Joel ML15148A609 

Dewitt, Pam ML15153A884 

Dial, Pamela ML15155A447 

Diamante, Nina ML15156B008 

Diamond, Ann ML15156A002 

Diamond, Nicholas ML15148A264 

Diamond, Nichole ML15155A418 

Diana, Patty ML15155A486 

Diaz, Herman ML15141A760 

Diaz, Jose ML15153B283 

Diaz, Lorenzo ML15148A647 

Diaz, Sharyn ML15148A625 

Diaz, Tony ML15156A159 

Dicarlo, Leigh Ann ML15148A632 

Dick, Ruth ML15154C306 

Dickel, Geraldine ML15159A793 

Dickens, Marcay ML15156A515 

Dickey, Helen ML15159A129 

Dickey, Kim ML15155A404 

Dickey, Laura ML15156B507 

Dickinson, Richard ML15148B373 

Dickinson, Robert ML15148B038 

Dickinson, Vicki ML15154A714 

Dickinson‐Adams, Emily ML15156A989 

Dicks, Carol ML15159A027 

Dicks, Rodger ML15155B657 

Dickstein, Stephen ML15162A106 

DiDonato, Toni ML15154B783 

Diedrich, Martin ML15154A111 

Diener, B. Thomas ML15158A063 

Diener, B. Thomas ML15158A070 

Appendix E October 2016 E-575 NUREG–2176
Commenter 

ADAMS 

Accession # 

Diephouse, Roberta ML15153A555 

Dietrich, Chris OMeara ML15142A224 

Dietrich, Janet ML15155A756 

Digiannantoni, Theresa ML15154A069 

Digiovanni Jr., Robert ML15155C006 

Dillard, Gavin ML15148B064 

Dillman, Michael ML15158A040 

Dillon, Errol ML15155B301 

Dimitri, Lindsay ML15153A988 

Dimock, Donald ML15154A300 

Dimondstein, Carla ML15153A491 

Dingeman, Christine ML15155A977 

Dingman, Amy ML15153A851 

Dipaola, Marisa ML15156A133 

Dippre, Dawn ML15158A169 

Dire, Tonette ML15154B499 

Dirrenberger, Jonathan ML15148A193 

Disbro, Jonathan ML15140A003 

Dishion, Diane ML15155A742 

Dishman, Patricia ML15155A359 

Dispenza, Salvatore ML15162A256 

Divens, Alicia ML15155A903 

Dixon, Joyce ML15154A283 

Dixon, Matthew ML15153A459 

Dixon, Nicole ML15159B391 

Dixon, Vernon ML15154A616 

Dixson, Cynthia ML15147A754 

Doane, Anne ML15154A354 

Dobbelaere, Susan ML15159A459 

Dobronski, Irene ML15154B266 

Dobson, Bruce ML15156B326 

Dobson, Melissa ML15148B319 

Dobson, Michael ML15148B114 

Dockter, Richard ML15154B500 

Dodge, Dana ML15154C088 

Dodge, Joan ML15148A205 

Dodge, Morris ML15159A892 

Dodson, Sara ML15161A690 

Doerring, Beth Ann ML15154A379 

Doesserich, Diane ML15156A686 

Doherty, Helen ML15162A593 

Doherty, Jeanne ML15156A840 

Dokos, Kara ML15155A893 

Dolbear, Robin ML15148A614 

Doles, Robert ML15156A679 

Dolgin, Gary W. ML15155A053 

Dolin, Joy ML15161A672 

Dollar, Ellen ML15162A464 

Dollar, Robert ML15154C256 

Domb, Doreen ML15155A225 

Domingos, Lori ML15159B263 

Domingue, Christine ML15162A412 

Dominguez, Laura ML15155B261 

Domke, Ellen ML15154B615 

Commenter 

ADAMS 

Accession # 

Domowicz, Artur ML15155A151 

Donaghy, Rita ML15155A752 

Donahue, Mary ML15154A207 

Donald, Cooke ML15162A519 

Donaldson, Karen ML15153B128 

Donaldson, Patrick ML15154A781 

Donnell, Bruce ML15162B079 

Donnell, Bruce ML15162B120 

Donnelly, Debbie ML15159A606 

Donnelly, Debbie ML15161A686 

Donnelly, Russell ML15154A061 

Donnelly, Stephen ML15156A030 

Donnelly, Thos ML15155B360 

Donovan, Elaine ML15153A539 

Dooley, Maryann ML15154A159 

Dormont, Mitchell ML15155B340 

Dorn, Valerie ML15159A924 

Dorraugh, Tami ML15148A127 

Dorsey, James ML15153A853 

Dorsey, Jill ML15142A097 

Dortch, Pam ML15154B260 

Dosky, Pat ML15155B001 

Dostalek, Patricia ML15156B369 

Doster, Patty ML15159B461 

Dotson, Mike ML15154C105 

Doty, Carol ML15153A727 

Doty, David ML15156B228 

Doty, Jimmy ML15153A487 

Doucet, Barbara ML15154C068 

Dougher, Marilyn ML15155B884 

Dougherty, Janet ML15155C005 

Dougherty, Kate ML15154B076 

Douglas, Carolyn ML15154A285 

Douglas, Diana ML15155A314 

Douglas, Dianne ML15161A640 

Douglas, Donna ML15155B699 

Doust, Jim ML15156B223 

Dowd, Therese ML15154A462 

Dowell, Joanne ML15162A397 

Dowling, Deborah ML15141A606 

Dowling, Jay ML15155B232 

Downum, Monte L. ML15159A757 

Dowty, Amy ML15162A710 

Dragavon, Linda ML15155C111 

Dragavon, Linda ML15155C117 

Drager, Luranne ML15156B338 

Dragona, Danielle ML15148A711 

Drahos, Ronald ML15153B003 

Drake, Mercy ML15159B511 

Drake, Tracy ML15148B258 

Dratch, Sam ML15154A538 

Drevicky, John ML15156A438 

Drew, Craig ML15147A778 

Drew, Janet ML15155A705 

Appendix E NUREG–2176 E-576 October 2016
Commenter 

ADAMS 

Accession # 

Drew, Virginia ML15154B284 

Dreyer, Sharyn ML15148B153 

Driessen, Lynn ML15153B066 

Driggers, Judy ML15159A560 

Driscoll, Marie ML15154A224 

Driskell, Shelley ML15155A064 

Drissell, Eric ML15159A832 

Drivas, Linda ML15153B031 

Drobny, Edith ML15159A825 

Droll, Francesca ML15159A844 

Drullard, Claire ML15158A217 

Drumright, Chris ML15147A706 

Dryden, Marlie ML15156A254 

Du Rivage, Robert ML15159B249 

Dubasik, Valentina ML15160A518 

DuCharme, Christy ML15162A684 

Duckson, Robert ML15156A076 

Duckwall, Karen ML15156B103 

Duckworth, Ronald ML15154A209 

Dudley, Gregory ML15159A431 

Dudley, Gwen ML15155A477 

Dufel, Laura ML15153A332 

Dufel, Laura ML15154A265 

Dugaw, Anne ML15154A206 

Duggan, Bill ML15141A633 

Dukes, Aaron ML15155A282 

Dulas, Scott ML15159B222 

Dulicai, Linda ML15156A029 

Duman, Bonnie ML15140A031 

Dumford, Karen ML15141A551 

Dummerauf, Carla‐Maria ML15154A021 

Dunaway, Susan ML15142A089 

Dunbar, Betty ML15148B313 

Duncan, Bruce and 

Wendla ML15159A222 

Duncan, Bryan ML15158A274 

Duncan, Kim ML15141A784 

Duncan, Renee ML15160A949 

Duncan, Sylvia ML15154A764 

Dunham, Janet ML15154A797 

Dunham, Kathryn ML15159A836 

Dunham, Moneca ML15154A651 

Dunham, Moneca ML15155C237 

Dunlap, Anne ML15154C075 

Dunlop, Jean ML15154B104 

Dunn, Charles and June ML15156B420 

Dunn, Elmo ML15154B341 

Dunn, Linda ML15161A670 

Dunn, Sara ML15159A280 

Dunn, Sherry ML15156A478 

Dunn, Timothy ML15154C258 

Dunne, Linda ML15148B019 

Duppstadt, Eileen ML15159A636 

Dupree, Donna ML15158A106 

Commenter 

ADAMS 

Accession # 

DuPree, M. ML15159B153 

Duran, Wesley ML15153A967 

Durden, Lynda ML15156B127 

Durfee, Evelyn ML15162A060 

Durham, Desiree ML15158A133 

Durham, Eric ML15141A775 

Durieux, P. ML15158A046 

Durkin, Samuel ML15155A804 

Dust, Michelle ML15158A095 

Dutka, Cindy ML15156B152 

Dutschke, Stephen ML15156A996 

Dyakon, Douglas ML15154C016 

Dybel, Donald ML15154A944 

Dybel, Sandra ML15142A352 

Dycus, Terry ML15156A102 

Dyer, Paul ML15156A441 

Dygas, Dorothy ML15156A881 

Dym, Harvey ML15154A080 

Dzikowski, David ML15148B344 

Dzubak, Cheryl ML15154B875 

E., Sherry ML15155B066 

Eagle, Chief Grey ML15154A531 

Earle, Susan ML15154A066 

Earle, Susan ML15154A428 

Earnshaw, Shinann ML15155C194 

East, Jen ML15154B740 

East, Lawrence ML15148B396 

Easterday, Roger ML15153A871 

Easterling, Anne ML15155B485 

Easterling, Kermit ML15158A008 

Eastlake, Linda ML15159A872 

Eastlake, Linda ML15159A878 

Eaton, Alexandra ML15154A608 

Eaton, James ML15154A278 

Eaton, Sandy ML15156A124 

Eberg, Nancy ML15156A182 

Eberhardt, Steven ML15155A208 

Eberle, Melvin ML15153B231 

Ebersole, Jan ML15155B228 

Eck, Jj ML15154B117 

Eckard, Roberta ML15159B528 

Eckardt, Gerhard ML15155C124 

Ecker, Christopher ML15155B637 

Eckerline, Mckenna ML15142A096 

Eckert, Angela ML15155C203 

Eckert, Brenda ML15154B325 

Eckler, John ML15160A909 

Eckles, Sabrina ML15154A942 

Ecklund, John ML15154B929 

Eckstein, Susan ML15159A160 

Edell, Elaine ML15154B795 

Edelman, Ellen ML15156B485 

Edens, Teresa ML15148A733 

Edfast, Roy ML15148A636 

Appendix E October 2016 E-577 NUREG–2176
Commenter 

ADAMS 

Accession # 

Edgar, Lynn ML15154B064 

Edmondson, Nancy ML15153A418 

Edmonston, Pandora ML15155A317 

Edridge, Michael ML15156A967 

Edson, Patricia ML15148B170 

Edwards, B. ML15148B288 

Edwards, Bita ML15162B044 

Edwards, Bita ML15162B117 

Edwards, Carlene ML15159A765 

Edwards, Cynthia ML15154C031 

Edwards, Eric ML15154A470 

Edwards, Jane ML15155A169 

Edwards, Joe ML15162A608 

Edwards, Mary ML15148A938 

Edwards, Monique ML15154A359 

Edwards, William ML15153B138 

Edwards, Willie ML15141A714 

Eeds, Bill ML15148A868 

Eells, Margaret ML15155A864 

Efron, Deborah ML15155A809 

Efstration, George ML15162A540 

Egan, June ML15156A312 

Eggan, Emily ML15148B282 

Egger, Kathleen ML15159B209 

Eggers, Michael ML15154B279 

Egolf, Nancy ML15148A935 

Ehmke, Jessica ML15153A905 

Ehren, Aviva ML15154B647 

Ehrlich, Annette ML15154A771 

Ehrlich, Marion ML15154B288 

Ehrmann, Nancy ML15158A154 

Ei, Jen ML15155B933 

Eichler, Nancy ML15154C015 

Eicholtz, Dennis ML15159B551 

Eielson, Olivia ML15159B096 

Eiffler, Jeff ML15141A593 

Eikenbary, Susan ML15154B939 

Eisenberg, Howard ML15159B150 

Eisenberg, Michael ML15154B876 

Eisenberg, Paul ML15148B263 

Eisenberg, Roberta ML15155B190 

Eisenberg, Sarah ML15160A864 

Eisenberg, Sarah ML15160A864 

Eitelman, Andrea ML15159B463 

Eklund, Steve ML15155A915 

Elamon, Heather ML15148B369 

Elder, Dave ML15155A595 

Elder, Shonti ML15156B035 

Eldridge, Robyn ML15156A707 

Eley, Janet ML15154C217 

Elias, Ralph ML15159A627 

Elisberg, Cynthia ML15148B287 

Elkin, Susan ML15153A912 

Elkins, Judy ML15159B582 

Commenter 

ADAMS 

Accession # 

Ell, Christopher ML15155A229 

Ellefson, Colin ML15155A866 

Ellenberger, Charles ML15156B143 

Elliott, Allen ML15155B953 

Elliott, Judith ML15154C266 

Elliott, Lynn ML15160A914 

Elliott, Terry ML15155B784 

Ellis, Susan ML15153A946 

Ellison, David ML15156A307 

Ellison, Richard ML15158A114 

Elllis, Michael ML15140A109 

Elly, Karen ML15147A719 

Elm, Carole ML15155C070 

Elman, Mark ML15148B334 

Elness, Barbara ML15154C111 

Elson, Adam ML15155B017 

Elton, Wallace ML15160A802 

Elwell, Herbert ML15158A002 

Emmanuele, Kurt ML15148A742 

Emmerik, Christina ML15160A532 

Emond, Lise ML15159A268 

Emrick, Carol ML15142A301 

Encomenderos, Gayle ML15154B836 

Enderlein, Andreas ML15147A759 

Endress, Daphne ML15155A300 

Eng, Koney ML15155A500 

Engel, Sabrina ML15153A846 

Engelhart, Marylee ML15140A263 

Engels, Angelika ML15159A890 

Enger, Carolyn ML15159A094 

England, Roy ML15141A428 

Engle, I. ML15148B154 

Engler, Pam ML15159B272 

Englerth, Charlene ML15153A479 

Ennor, Kenneth ML15148A236 

Epstein, Barbara ML15159A096 

Epstein, Kelly ML15142A225 

Epstein, Sarah ML15159B513 

Erbs, Lori ML15155A329 

Ercole, Steven ML15159A445 

Ergueta, Taia ML15153A815 

Erickson, Charles ML15154A033 

Ericson, Del ML15142A256 

Ericson, Gretchen ML15153A432 

Erikson, Anne ML15141A527 

Erlander, Daniel ML15154B577 

Ernst, Cathie ML15159B155 

Ernst, Cathie ML15160A598 

Ernst, Kathleen ML15155A204 

Erpel, Julia ML15153B188 

Erskine, Mark ML15142A040 

Erskine, Michael ML15161A676 

Ervin, Heather ML15159A958 

Erwin, Lee ML15155C222 

Appendix E NUREG–2176 E-578 October 2016
Commenter 

ADAMS 

Accession # 

Escobales, Lauren ML15153A792 

Escobar, Victor ML15153A838 

Eskew, Eve ML15153B068 

Espinaco, Esmeralda ML15154A225 

Espinoza, Yaraly ML15154B594 

Esposito, Amanda ML15155B136 

Esposito, Dan ML15141A614 

Essenmacher, Barbara ML15155C129 

Estes, Donna ML15154C043 

Estes, John ML15154C099 

Estes, Julia ML15154B033 

Estrella, Andrea ML15156A673 

Ethridge, Diane ML15154B355 

Etris, Caveman ML15156B365 

Eudy, Elaine ML15153A978 

Eurs, Albert ML15153A766 

Evans, Bronwen ML15154C159 

Evans, Chad ML15155A697 

Evans, Debbie ML15148A928 

Evans, Geoffrey ML15153A939 

Evans, John ML15154A875 

Evans, Pamela ML15154A475 

Evert, Herb ML15154B758 

Evilsizer, Susan ML15142A250 

Ewert, Henry ML15160A967 

Ewing, Tracy ML15153A697 

Eyclesheimer, Susan ML15154B233 

Ezerman, Elizabeth ML15162A692 

F., Amy ML15162A054 

F., Jennifer ML15155B814 

Faber, Megan ML15156A642 

Facey, Laurel ML15154B013 

Faegre, Dirk ML15159A043 

Fahlstrom, Marylee ML15153A827 

Fahy, Kevin ML15148A963 

Fain, R. ML15155A211 

Fairchild‐Ehm, Audrey ML15160A970 

Faircloth, Diane ML15156B167 

Fairfield, Richard ML15154A777 

Fairless, Judy ML15153A609 

Fairley, Peter ML15162A263 

Fairlie, Mary ML15159A514 

Fait, Lawrence ML15156A595 

Falcone, Janet ML15154B887 

Falink, Norma ML15155A382 

Fallon, Ellen ML15154A282 

Falsken, James ML15154A290 

Fanelli, Mary ML15154B372 

Farenkopf, Nathan ML15141A599 

Faris, Dan ML15155B315 

Farkas, Midge ML15154C205 

Farley, Chanda ML15155C085 

Farlow, Joy ML15140A035 

Farmer, Bonnie ML15156A654 

Commenter 

ADAMS 

Accession # 

Farmer, Bonnie ML15156A600 

Farmoon, William ML15141A582 

Farneth, Sara ML15154C059 

Farnham, Charlene ML15154B831 

Farnor, Shane ML15140A018 

Farnsworth, Stu ML15148A586 

Farrell, Bob ML15154A146 

Farrington, Raymond ML15153A336 

Farris, Nancy ML15148B216 

Fary, Jim ML15155B640 

Fass, Amy ML15160A803 

Fassman, Dennis ML15154B657 

Fast, Wendy ML15154B172 

Fast, Yvonne ML15156B355 

Fastuca, Joy ML15148A275 

Fastuca, Meagan ML15159B291 

Fath, Vernon ML15161A691 

Faucett, Carol ML15156A724 

Faucett, Carol ML15156A775 

Faucett, Steven ML15154A746 

Faucher, Selma ML15156B394 

Faust, Malcolm and Carol ML15155A114 

Fayollat, Gloria ML15155B854 

Fear, Patricia ML15155C247 

Fecko, Albert ML15156B308 

Fedele, Lori ML15154C064 

Feder, Howard ML15155B753 

Feder, Melanie ML15140A123 

Federico, Kellie ML15159A470 

Fegan, Mike ML15148A171 

Fehr, Angelique ML15148A885 

Fehr, Richard ML15153B254 

Fehr, Stephen ML15142A178 

Fehrmann, Gail ML15154B515 

Feichtinger, Dennis ML15155A770 

Feider, John ML15153B022 

Feissel, John ML15153B008 

Felch, Shelley ML15156A857 

Feld, Ellin ML15155A097 

Feldman, Dee ML15154C227 

Feldman, Paul ML15158A252 

Feldmann, Grace ML15142A248 

Feldmann, Heike ML15155C195 

Feldmann, Michaela ML15162A129 

Fell, Cynthia ML15162A243 

Fellabaum, Wayne ML15148B400 

Feller, Penney ML15155A199 

Fellion, Karyn ML15142A090 

Feltham, Bette ML15154A858 

Felton, John ML15162A715 

Fenley, Bette-Burr ML15154B201 

Fenster, Fraidell ML15158A187 

Fenster, Steven ML15159A276 

Feran, Michael ML15140A045 

Appendix E October 2016 E-579 NUREG–2176
Commenter 

ADAMS 

Accession # 

Fergot, Michael ML15156A107 

Ferguson, Charlene ML15160A740 

Ferguson, J. ML15155C251 

Ferguson, Mike ML15148B211 

Ferland, Linda ML15141A542 

Ferland, Linda ML15141A602 

Ferman, Pam ML15154A869 

Fernandes, Ana-Paula ML15159A874 

Fernandez, Daniel ML15153B213 

Fernandez, Sandra ML15154A713 

Fernandez‐Reyes, Ynez ML15154A112 

Ferrar, Kristen ML15140A186 

Ferrara, Dawn ML15142A217 

Ferraro, Mary ML15160A833 

Ferrera, Ernesto ML15154A064 

Ferri, Vincent ML15159B364 

Ferro, Frank ML15153B097 

Ferron, Chadd ML15161A688 

Fers, Alda ML15148A633 

Fetch, Elena Marie ML15156A207 

Fetchko, Kathleen ML15156B370 

Fetter, Sharon ML15159B026 

Fetting, Joanne ML15141A464 

Feuchter, Robert H. ML15142A186 

Feuille, Leslie ML15155A406 

Fiallos, Rebecca ML15156B477 

Fickling, Karl ML15154A442 

Fidler, Vicki ML15142A050 

Fiedler, Patricia ML15153A933 

Field, Fran ML15146A228 

Field, Michael ML15154A071 

Fielder, Aixa ML15154A410 

Fielder, Aixa ML15154A610 

Fielder, Linda ML15155B049 

Fieno, Debbie ML15155A393 

Fifer, Nancy ML15159A326 

Figge, Donald ML15155A502 

Figman, Janice ML15160A540 

Figueroa, Alfredo ML15155C133 

Figueroa, Daphne ML15162A581 

Files, Heather ML15153A543 

Finamore, Scott ML15159A072 

Findley, Gail ML15156A986 

Findley, Helen ML15156A289 

Fine, Cindy ML15154A728 

Fine, Michael ML15155C101 

Fine, Michael ML15159B088 

Fingerhut, Ronnie ML15160A688 

Fingerman, Robert ML15156A139 

Fink, Brian ML15155A212 

Fink, Brian ML15162A456 

Finkbeiner, Theresa ML15159A091 

Finkel, Allyson ML15160A974 

Finley, Joel ML15155A364 

Commenter 

ADAMS 

Accession # 

Finley, Sharon ML15154A406 

Finn, Linda ML15141A704 

Finnegan, Pam ML15158A097 

Finnerty, Kathleen ML15156A517 

Finney, Pam ML15156A214 

Fiore, Janet ML15155A373 

Fiorentino, Doris ML15155B063 

Firman, Douglas ML15154A697 

First, Mary Beth ML15159A212 

Firth, Shawn ML15148B084 

Fisch, Greg ML15154C129 

Fischer, Quentin ML15161A652 

Fischman, Lawrence ML15160A810 

Fischoff, Robert ML15142A034 

Fish, David ML15159B398 

Fish, Margaret ML15154B811 

Fish, Richard ML15159B440 

Fisher, Cheryl ML15155B747 

Fisher, Chuck ML15153A580 

Fisher, Karen ML15154C135 

Fisher, Myrna ML15154B291 

Fisher, Sarah ML15156B012 

Fisher, Sharon ML15162A553 

Fisher, Yvonne ML15160A953 

Fishman, Ted ML15148B191 

Fishman, Zelma ML15154B087 

Fisk, Todd ML15153A340 

Fiske, Constance ML15148A256 

Fissinger, Julie ML15154A348 

Fite, Austin ML15158A176 

Fite, Barbara ML15155A130 

Fite, Emily ML15155A802 

Fithian, Joel ML15155C000 

Fittipaldi, Silvio ML15153A334 

Fitzpatrick, Deirdre ML15148B206 

Fix, M. ML15158A267 

Flagg, Yvonne ML15156B518 

Flanagan, John ML15154B042 

Flannery, Marcia ML15156A835 

Fleener, Teresa ML15154C293 

Fleetwood, Patricia ML15154C003 

Fleming, Laura ML15148B303 

Fleming, Tami ML15141A601 

Fleming, Tami ML15141A712 

Fletcher, Bonnie ML15158A271 

Fletcher, Carol ML15156A046 

Fletcher, Jeanne ML15156A118 

Fletcher, Karen ML15159B538 

Flick, Pamela ML15156A020 

Floersch, Elizabeth ML15155A339 

Florell, Tina ML15148B308 

Florio, Dawn ML15154B021 

Florio, Kathryn ML15154A514 

Floyd, Debra ML15155B009 

Appendix E NUREG–2176 E-580 October 2016
Commenter 

ADAMS 

Accession # 

Floyd, Randall ML15158A214 

Fluker, Richard ML15154C237 

Fly, Carol ML15142A230 

Fogel, Byron ML15156A174 

Foley, Catherine ML15155B223 

Foley, Jane ML15159A320 

Foley, Jr., Robert ML15153B095 

Folger, Jessica ML15155C097 

Fonda, Thomas ML15154C265 

Fong, Melissa ML15148B160 

Fontaine, Anna Louise ML15155B724 

Fontana, Mike ML15155B909 

Fontana, Sandy ML15155B905 

Fonte, Jeri ML15158A137 

Foote, Thomas ML15159A665 

Foran, Rochelle ML15159B420 

Forbes, J. ML15159B307 

Forbes, Reese ML15154A105 

Ford, Michael ML15159A447 

Ford, Peggy ML15155A671 

Forgacs, Nora ML15154C181 

Forgues, David ML15153B298 

Forkish, Jo ML15155A281 

Fornari, Arthur ML15155A910 

Forney, Kathy ML15155A606 

Forrest, Mariah ML15155B868 

Forschner, Jillian ML15156A853 

Forte, Robert ML15156A491 

Fortgang, Mindye ML15140A044 

Forwand, Arlene ML15155C164 

Fosburgh, Eric ML15155B104 

Foscherari, Dolores ML15142A052 

Foskett, Maryanna ML15155A201 

Foss, Maryann ML15155A644 

Foster, Beverly ML15154B337 

Foster, Delaina ML15159B066 

Foster, Frances ML15159A163 

Foster, Jacqui ML15156B492 

Foster, Leah ML15160A791 

Foster, Patricia ML15148A144 

Foster, Robin ML15155B011 

Foster, Stephanie ML15159B273 

Foster, Tracy ML15156B385 

Fotos, Janet ML15159A267 

Fouche, David ML15148B376 

Foulk, Jennifer ML15142A221 

Fouts, Shannon ML15156B447 

Fowler, Elizabeth ML15148A912 

Fowler, Kim ML15159A044 

Fowler, Rachel ML15141A568 

Fowlkes, Richard ML15153A999 

Fox, Carole ML15156B262 

Fox, Delphia ML15153A949 

Fox, H. ML15154C231 

Commenter 

ADAMS 

Accession # 

Fox, Kathleen ML15159A467 

Fox, Larry ML15148A990 

Fox, R. ML15156A934 

Foxworth, George ML15154B069 

Frale, Darren ML15155C180 

France, Catherine ML15155B672 

Franceil, Sondra ML15159A986 

Franchi, Irena ML15158A163 

Francis, Lorri ML15140A015 

Francis-Swayze, Carole ML15141A713 

Franck, Irene ML15142A114 

Franck, Matthew ML15148B281 

Franco, Diana ML15148B408 

Frangakis, Nicholas ML15155A137 

Frank, Andrea ML15154A668 

Frank, Patti ML15154B690 

Frank, Robert ML15148A802 

Frank, Sharon ML15153A642 

Frankenfield, Pat ML15153B092 

Franklin, Courtney ML15154B910 

Franklyn, Rex ML15156A990 

Franks, Scott ML15154C297 

Franz, Sandra ML15154A093 

Franzmann, Paul ML15156A298 

Fraser, Evelyn ML15154B282 

Fraser, Mark ML15141A770 

Fraser, Suzy ML15156A556 

Frasieur, Forest ML15155A254 

Fray, Antje ML15155B775 

Frazee, Cary ML15158A145 

Frazier, Madelynn ML15153A480 

Frazier, Shelley ML15160A585 

Fredenburg, Frank ML15153A708 

Frederick, Anne ML15154B741 

Fredrickson, Karen ML15148A610 

Freed, Hannah ML15159A135 

Freedman, Peter ML15153B215 

Freel, Susan ML15159A079 

Freeman, Amy ML15154B956 

Freeman, Carolyn ML15154B509 

Freeman, Myrna ML15155A010 

Freeman, Tyler ML15159A224 

Freestone, Mack ML15148B355 

Frega, Doreen ML15142A347 

Fregin, N. J. ML15148A140 

Freiler, Kyle ML15162A656 

Freitas, Frank ML15155C007 

French, A. ML15156A859 

French, Larry ML15159A092 

French, Nina ML15148A271 

French, Stephen ML15155A099 

Frerker, Ronald ML15159A821 

Freson, Neil ML15153B154 

Frey, Adrienne ML15148B159 

Appendix E October 2016 E-581 NUREG–2176
Commenter 

ADAMS 

Accession # 

Frey, John ML15162A113 

Frey, Lisa ML15154B968 

Frey, Patricia ML15154A357 

Friar, Beth ML15160A955 

Frick, Dean ML15153A957 

Frick, Patricia ML15154A147 

Frickel, Scott ML15155B739 

Fried, Marc ML15158A035 

Friederichsen, Jacqueline ML15141A436 

Friedland, Monique ML15159B255 

Friedman, Alan ML15153A644 

Friedman, Cherryl ML15159A771 

Friedman, Fredrica ML15148A213 

Friedman, Terry ML15160A933 

Friedman, Valerie ML15160A784 

Fries, Jeb ML15155C148 

Fritzler, Cyndi ML15158A277 

Froehle, Virginia ML15153A775 

Fromberg, Jeff ML15154B845 

Frost, Keith ML15159A424 

Fruchter, Rosalie ML15141A717 

Fruchter, Rosalie ML15148A235 

Fruge, Aaron ML15155B116 

Frush, Mary ML15155A887 

Frusteri, Biagio ML15155B600 

Frye, Donna ML15158A129 

Frymoyer, Allison ML15156A043 

Fues, Lisa ML15153B293 

Fuessel, Chere ML15153A819 

Fugate, Karl ML15156A230 

Fugit, Sherri ML15155A377 

Fukuman, Thomas ML15156A863 

Fuller, Astrid ML15148B309 

Fuller, Dustian ML15153A325 

Fuller, Lisa ML15153A818 

Fuller, Roy ML15148A904 

Fullerton, Richard ML15154C283 

Fumarola, Aaron ML15140A030 

Fundby, Lone ML15153A460 

Funk, Ilse ML15156A281 

Fura, David ML15155B632 

Furberg, Sven ML15159B449 

Furlan, Sophia ML15155A363 

Furlong, John ML15155C163 

Furr, Carolyn ML15156A226 

Fusco, Carol ML15159A644 

Fuss, Joanne ML15148A725 

Futrell, Sherrill ML15158A144 

Futrovsky, Rosemary ML15159B340 

G., G . ML15148B016 

G., Jan ML15153B235 

G., K. ML15140A120 

G., Steven ML15160A052 

Gaal, Tiffany ML15148A755 

Commenter 

ADAMS 

Accession # 

Gabbert, Tim ML15161A700 

Gabel, Eileen ML15159A228 

Gable, Derrelle ML15159A616 

Gabriel, Candace ML15154B775 

Gabriel, Robert ML15153B296 

Gaddy, Lisa ML15153A376 

Gage, Karen ML15160A695 

Gainer, Beverly ML15148A789 

Galante, Nicholas ML15156A592 

Galbreath, Jerry ML15146A368 

Gall, Gary ML15156B349 

Gall, Ronald ML15153A996 

Gallagher, E. ML15154C120 

Gallagher, Glenn ML15154B333 

Gallagher, Jim ML15148A787 

Gallagher, Julie ML15158A201 

Gallegos, Mark ML15154A454 

Gallo, Patricia ML15159A962 

Galloway, Adele ML15155A876 

Galst, Liz ML15154A054 

Gambriel, John ML15154A935 

Gandhi, Dipal ML15154A694 

Gandolfo, Laura ML15153A934 

Gangi, Melanie ML15155A410 

Ganter, Steven ML15154C079 

Garber, Lisa ML15156B378 

Garcia, Armando A. ML15156A547 

Garcia, Dena ML15159B097 

Garcia, Erik ML15155B799 

Garcia, Erin ML15155B590 

Garcia, Evette ML15154C276 

Garcia, Jeffery ML15156B088 

Garcia, Luis ML15155B990 

Garcia, Manny ML15161A654 

Garcia, Mark ML15154A010 

Garcia, Olaya ML15153A701 

Garcia, Susan ML15160A829 

Garcialuna, Edgar ML15156B418 

Gardner, Chris ML15148A624 

Gardner, Chris ML15154B115 

Gardner, Kent ML15155C125 

Gardner, Thomas ML15154A199 

Garescher, Marie ML15154A403 

Garetz, Diane ML15148B188 

Garey, Jenne ML15142A273 

Garfield, Andrea ML15142A109 

Garfinkel, Nina ML15156A640 

Garland, Carole ML15154A742 

Garland, Robert ML15154B869 

Garlit, Donald ML15148B371 

Garmon, Toni ML15154A221 

Garnant, Gregory ML15153B162 

Garoutte, Claudia ML15153A788 

Garoutte, Debra ML15159A654 

Appendix E NUREG–2176 E-582 October 2016
Commenter 

ADAMS 

Accession # 

Garratt, Liz ML15141A668 

Garrecht, Jamila ML15154B542 

Garrett, Benjamin ML15154A543 

Garrett, John ML15154B286 

Garrett, Larry ML15153B297 

Garrett, Lory ML15153A541 

Garrett, Mary ML15162A089 

Garrett, Robert ML15154B972 

Garrison, Ron ML15154A236 

Garrison, Susan ML15158A188 

Garritson, David ML15140A113 

Garside, Kim ML15160A709 

Garvey, Lydia ML15154A733 

Garvy, Vanessa ML15154B202 

Gasal, David ML15154B704 

Gasco, Christine ML15155A244 

Gaspar, Stephanie ML15155A256 

Gasperino, Maria ML15159A697 

Gasperoni, John ML15147A744 

Gast, Richard ML15159B390 

Gaster, Valerie ML15155A147 

Gately, Daniel ML15154A099 

Gates, Nancy ML15156A197 

Gathing, Nancy ML15148A664 

Gatling, Gayla ML15161A656 

Gaudin, Gerard F. ML15154B943 

Gault, Carol ML15159A883 

Gause, Jackie ML15154A693 

Gauthier, Lorraine ML15153A843 

Gawron, Katarzyna ML15153B118 

Gawryszewski, Nancy ML15154A550 

Gay, Larry ML15148B380 

Gayken, Aaron ML15148B231 

Gaylin, Rita ML15155B231 

Gaylor, Linda ML15154B757 

Gazzola, Linda ML15161A621 

Geary, Jonny ML15155A132 

Gebhard, Eric ML15155C252 

Gebhart, Leroy ML15153B198 

Gee, Lisa ML15142A313 

Geer, Matt ML15156A930 

Gehrig, Judy ML15148A706 

Geiger, Marcia ML15156A978 

Geiges, Marion ML15156A217 

Geiler, Janet ML15155A272 

Gelfand, Carol ML15148A749 

Gellar, Michael ML15160A956 

Geller, Phyliss ML15142A359 

Gemmill, Robert ML15159B236 

Genasci, Elaine ML15154B932 

Gendvil, Derek ML15153A643 

Gennarelli, Michael ML15159A468 

Gensler, Donna ML15155A251 

Gentili-Lloyd, Mika ML15159A051 

Commenter 

ADAMS 

Accession # 

George, Catherine ML15141A792 

George, Kim Sanders ML15154A954 

George, Mark ML15159A903 

Gerber, Eric ML15156A972 

Gerbitz, Gordon ML15154A675 

Gergely, Katrina ML15159B124 

Gerhard, Dan ML15153A874 

Gerke, David ML15155B160 

Germain, Mary ML15162A643 

German, Bonnie ML15158A105 

Germann, Lawrence ML15158A015 

Gertig, Kt ML15160A868 

Gertler, Edward ML15155A451 

Gerwens, Shana ML15155A023 

Gesland, Genelle ML15159A621 

Ghannadi, Nazlee ML15140A180 

Gherardi, Lisa ML15153A891 

Ghiggia, Michelle ML15155B972 

Gianikos, Cathy ML15159A539 

Gibbs, Donna ML15148A239 

Gibbs, Susan ML15158A245 

Giblin, Thomas ML15148B214 

Gibson, Irene ML15153B115 

Gibson, John ML15153B196 

Gibson, Raymond ML15142A285 

Gibson, Scott ML15154A378 

Gibson, Susan ML15155C242 

Gicela, Raymond ML15159A324 

Giddings, Ron ML15154A115 

Gideon, Barbara ML15159A111 

Gierlachowski, Alexandra ML15159A921 

Giese-Zimmer, Astrid ML15155C074 

Gifford, Teresa ML15155A071 

Gilardi, Gary ML15154C173 

Gilbert, Camille ML15153B267 

Gilbert, Jo Ann ML15154A302 

Gilbert, Pat ML15148B046 

Gilbert, Tracy ML15141A674 

Gilbreath, J. Michael ML15155C176 

Gilchrist, Amber ML15155B316 

Gilchrist, Cheryl ML15140A006 

Giles, Warren ML15154A308 

Gill, Juliana ML15155B702 

Gill, Raymond ML15155A146 

Gill, Stephanie ML15153B177 

Gillard, Charles ML15159A652 

Gillespie, Thomas ML15155A284 

Gillespy, Nicole ML15161A667 

Gillette, Shereen ML15155B735 

Gilliland, Charles ML15156A473 

Gilliland, Patricia ML15154A246 

Gillono, Mark ML15155A596 

Gilmore, Joyce ML15155C201 

Gilmore, Naomi ML15158A244 

Appendix E October 2016 E-583 NUREG–2176
Commenter 

ADAMS 

Accession # 

Gindele, Abigail ML15156A830 

Gingeresky, Joan ML15148B255 

Gingery, Suze ML15154C139 

Ginn, Kenneth ML15142A315 

Gioia, Linda ML15154B984 

Gioielli, Lawrence ML15155A323 

Girvin, Darrylin ML15156A850 

Gitto, Ruth ML15156A470 

Givens, Roger ML15154A006 

Glancy, Joann ML15156B404 

Glandon, Clarice ML15154A252 

Glaser, Helene ML15159B029 

Glaser, Patsy ML15154A690 

Glass, Jordan ML15141A611 

Glass, Malcolm ML15141A544 

Glass, Rachel ML15159B572 

Glasscock, Rita ML15159A869 

Glasser, Karen ML15141A722 

Glasser, Mark ML15153A854 

Glasser, Mark ML15153B182 

Glasser, Tanya ML15154A466 

Glasshof, Wendy ML15155B196 

Glazer, Gertrude ML15154A783 

Gleason, Barbara Lafaver ML15148B377 

Gleason, Debra ML15153B061 

Gleason, Melinda ML15153A428 

Glenn, Alice Ann ML15148B098 

Gley, Debra ML15153A931 

Glick, Art ML15140A265 

Glick, Edward ML15159A785 

Glier, Ingeborg ML15155A397 

Gliva, Stephen ML15148B280 

Gloe, Janice ML15148A962 

Glover, Tim ML15155A655 

Glover, Robert ML15155B359 

Gluchman, Matt ML15148A634 

Gmaz, Mary ML15154A049 

Gobely, Michelle ML15159A103 

Godbee, Allycia ML15154A356 

Godbey, Stella ML15159A155 

Goddard, Simon ML15156A567 

Goden, Gay Marie ML15155A815 

Goding, Larry ML15153A902 

Goebel, Fred ML15155A078 

Goecke, Linda ML15162A569 

Goeckermann, John ML15154B770 

Goehring, Dan ML15153A847 

Goetinck, Jean ML15155C185 

Goff, Karyn ML15155C239 

Goff, Thomas ML15156A961 

Golata, Grace ML15156A494 

Gold, Carol ML15153A794 

Gold, Ellen ML15153A414 

Gold, Jeff ML15153A566 

Commenter 

ADAMS 

Accession # 

Gold, Warren ML15153A699 

Goldberg, Anne ML15148A651 

Goldberg, Laura ML15155B050 

Goldberg, Rosalyn ML15154B700 

Goldberg, Susan ML15153A451 

Golden, Tim ML15154C067 

Goldin, Martha ML15156B396 

Golding, John ML15154B189 

Goldman, Linda ML15154A268 

Goldmark, Leila ML15159B552 

Goldstein, Carol Ann ML15155C077 

Goldstein, Helen ML15160A530 

Goldstein, Louis ML15154B561 

Goldwater, Glenda ML15156A252 

Golembeski, Michael ML15153A954 

Gollobin-Basta, Ruth ML15148B087 

Gomez, Chris ML15154B221 

Gomez, Toni Thoman ML15155A442 

Gomez, Unai Fuente ML15159A383 

Gondos, Nina ML15155C175 

Gonzales, Bernie ML15154C225 

Gonzales, Daniel ML15159B012 

Gonzalez, Daniel ML15159B065 

Gonzalez, Jose Luis ML15156B192 

Gonzalez, Raul ML15155C174 

Gonzalez, Veronica ML15156B425 

Gooden, Anne ML15141A781 

Goodin, Dale ML15156B266 

Goodman, Ellen ML15153A530 

Goodman, Margaret ML15153A554 

Goodrich, Darcy ML15156B092 

Goodrich, Rebecca ML15159A221 

Goodspeed, Helen ML15155B171 

Goodwin, Jill ML15154A245 

Gorden, Gay ML15158A159 

Gordon, Alexandra ML15142A060 

Gordon, Carol ML15153A683 

Gordon, J. B. ML15148A143 

Gordon, Janet ML15159A063 

Gordon, Michael ML15148B201 

Gore, Jesse ML15148B137 

Gorecki, Carole ML15159A522 

Gorina, Maya ML15153B266 

Gorlicki, Coralyn ML15142A074 

Gorn, Scott ML15141A759 

Gorra, Brian ML15142A304 

Gorsetman, Mark ML15156B133 

Gorton, Michelle ML15159B301 

Gosnell, Lisa ML15155B709 

Gossett, Gene ML15153A919 

Gotesky, Stephen ML15140A292 

Gotlib, Eva ML15148A768 

Gotlib, Eva ML15154B183 

Goto, Matthew ML15159B467 

Appendix E NUREG–2176 E-584 October 2016
Commenter 

ADAMS 

Accession # 

Gottfried, Susan ML15154B433 

Gottschalk, Pat ML15155A350 

Gotvald, Mark ML15148A179 

Gould, Catherine ML15153B281 

Gould, Ed ML15153B024 

Gould, Julianne ML15158A118 

Goulet, Christine ML15142A125 

Gover, Pat ML15156B020 

Gowani, Nancy ML15155B970 

Gowens, Edward ML15162B079 

Gowens, Edward ML15162B121 

Grace, Joel ML15148B150 

Grady, Pat ML15147A731 

Graffagnino, Mary Ann 

and Frank ML15154B434 

Graffell, Jess ML15140A256 

Graham, Dan ML15156A195 

Graham, Danielle ML15160A848 

Graham, Guy ML15162A081 

Graham, Lynn ML15155A519 

Graham, Sidney ML15148A989 

Grames, Patricia ML15154B808 

Gramza, Amy ML15153A515 

Granchi, Donald ML15158A259 

Granias, Susan ML15148A661 

Granofsky, Gabrielle ML15154A736 

Grant, Nancy ML15140A163 

Grasso, J. ML15159A015 

Graube, Davids ML15159A446 

Graul, Kara ML15161A622 

Gravelle, Willis ML15154A098 

Graver, Chuck ML15153B279 

Graves, Caryn ML15141A744 

Gray, Alison ML15156A154 

Gray, Debra ML15155A902 

Gray, Jennifer ML15155A103 

Gray, Joe ML15153A738 

Gray, Marissa ML15155B730 

Gray, Sylvia ML15154A192 

Gray, Tony ML15159A633 

Greaves, Leeann ML15158A077 

Green, Alice ML15142A054 

Green, Carol ML15154A702 

Green, Jamie ML15156A937 

Green, Jesse ML15148B351 

Green, July ML15155C095 

Green, June ML15156A290 

Green, Ken ML15154A337 

Green, Kerstin ML15156B406 

Green, Kristin ML15153A616 

Green, Martha ML15142A151 

Green, Mary Catherine ML15156A974 

Green, Meredith ML15155C245 

Green, Natasha ML15155B615 

Commenter 

ADAMS 

Accession # 

Green, Pamela ML15148A913 

Greenberg, Jason ML15154A029 

Greenberg, Joshua ML15159B499 

Greene, Carole ML15156B438 

Greenhalgh, Diana ML15153A502 

Greenhalgh, Karen ML15154A304 

Greenwald, Evelyn ML15154B292 

Greenwald, Ken ML15155C084 

Greenway, Lumina ML15148B202 

Greer, Amy ML15147A747 

Greer, Helen ML15155A425 

Greer, Tom ML15153B174 

Greger, Sabine ML15155B821 

Gregersen, David ML15155A716 

Gregoire, Andre ML15156B261 

Gregory, Gregory B. ML15154A125 

Gregory, Maria ML15154A383 

Gregson, Wright ML15154B216 

Greig, Joan ML15142A200 

Greig, Joe ML15148B316 

Greil, Judith ML15155B501 

Greinke, Pamylle ML15148B278 

Gribosky, Philip ML15154C178 

Grice, Royce ML15159A380 

Griesi, Linda ML15154B856 

Grieves, Kathy ML15154A145 

Griffin, Ann ML15159A046 

Griffin, Anne ML15159A114 

Griffin, Charles ML15154B229 

Griffin, Denise ML15153A952 

Griffin, Homer Ellis ML15154A456 

Griffin, Mike ML15140A279 

Griffin, Pam ML15155B828 

Griffin, Robert ML15155A266 

Griffith, Carolynn ML15154B866 

Griffith, Julie ML15159A993 

Griffith, Michael ML15160A689 

Griffith, Nancy R. ML15154A223 

Griffy, Kathleen ML15155A941 

Grillo, John ML15154A176 

Grillot, Charlotte ML15159B568 

Grimes, Tara ML15159A471 

Grimley, Chris ML15159A334 

Grimsgaard, Morten ML15160A777 

Grindle, Russell ML15160A763 

Griswold, Dave ML15155A020 

Griswold, Tracy ML15154B470 

Grizzell, Cs ML15142A269 

Groh, Paul ML15148B116 

Grohman, Carolyn ML15148B025 

Grone, Alexis ML15154A390 

Gronemann, Barbara ML15148B017 

Gronemeyer, Kimberly ML15162A616 

Gross, Anne ML15155A381 

Appendix E October 2016 E-585 NUREG–2176
Commenter 

ADAMS 

Accession # 

Gross, Barbara ML15142A042 

Gross, Jim ML15160A938 

Gross, Kurt ML15153A369 

Gross, Linda ML15148A886 

Gross, Sister James Marie ML15156A256 

Grossman, Bonnie ML15141A669 

Grossman, Kathleen ML15148B187 

Grossman, Kathleen ML15156B407 

Grotzke, Mark ML15154C294 

Grounds, Shari ML15148B090 

Grove, Earl ML15156A010 

Grove, Paul ML15156B298 

Grove, Stephen ML15154B936 

Grovenstein, Elizabeth ML15160A924 

Grover, Justin ML15148B301 

Groves, Linda ML15154A698 

Grubb, Harold ML15159A009 

Grubbs, Lisa ML15153A710 

Grubbs, Victoria ML15158A030 

Gruenau, Douglas ML15147A764 

Grush, Melissa ML15156B476 

Gruver, Chere ML15155A044 

Gualario, Lascinda ML15155B186 

Guallar, Santi ML15147A749 

Gualtieri, Kate ML15159B008 

Gucciardo, Kaye ML15159A230 

Guh, H. ML15147A717 

Guier, Richard ML15159B083 

Guilbault, Aubrey ML15159B395 

Guilliams, Karen ML15156B415 

Guinnup, David ML15154B810 

Guise, Elizabeth ML15148B180 

Gulla, Audrey ML15148A705 

Gullerud, Lois ML15153A741 

Gullo, Paula ML15159B459 

Gumpert, Michael ML15159A696 

Gunn, Amy ML15155B937 

Gunter, Karlene ML15159A082 

Gunther, Peter ML15147A771 

Gupta, Dave ML15147A781 

Guram, Monjit ML15141A771 

Gurdin, J. Barry ML15153B227 

Gurley, Marianne ML15153B051 

Gurvey, Jenna ML15153B238 

Guss, Elisabeth ML15155A494 

Gustafson, Heidi ML15158A260 

Gustafson, Marcy ML15156B007 

Gustafson, Owen ML15154B942 

Gustafson, Susan ML15155A280 

Guthrie, Amber ML15154B604 

Guthrie, Elizabeth ML15159B074 

Gutierrez, Emmylou ML15155C008 

Gutierrez, Nancy ML15154B453 

Gutierrez, Oscar ML15155B226 

Commenter 

ADAMS 

Accession # 

Gutman, Ruth ML15154A323 

Guttridge, Laura ML15153A475 

Guyon, Pamela ML15148B163 

Guyot, Jack ML15156A742 

Guyot, Jack ML15156A777 

Gwinn, Carol ML15148B399 

H., Jen ML15154A212 

H., Littlewolf ML15155C205 

Haage, L. ML15141A452 

Haas, Evelyn ML15153A463 

Habegger, Sue ML15154B339 

Habick, William ML15154A186 

Hacker, Sue ML15153B284 

Hackney, Stephen ML15156A178 

Hade, Michaeline ML15148A200 

Hadley, Shela ML15153A538 

Hadlock, Kevin ML15154B478 

Haegele, William ML15153A676 

Haertel, Melissa ML15153B145 

Hafer, Sarah ML15153A960 

Haffner, Barbara ML15161A637 

Haga, Martha ML15159B507 

Hagen, Cleo ML15155A439 

Hager, Jon ML15156A785 

Hagood, Hap ML15153A765 

Haig, Brenda ML15154A369 

Haine, R. ML15155C057 

Haines, Thomas ML15141A623 

Hair, Karla ML15154B950 

Hait, Gordon ML15155A537 

Hajduk, Kelly ML15156A299 

Hajek, Jim ML15148A274 

Hakkinen, Kari ML15155B097 

Hale, Sharon ML15154B121 

Hale, Susan ML15160A599 

Halem, Robert ML15141A705 

Hall, Dennis ML15160A828 

Hall, Emily ML15154B381 

Hall, George ML15141A743 

Hall, Heather ML15155A501 

Hall, Jan ML15153A768 

Hall, Janice ML15148B320 

Hall, Jennifer ML15142A117 

Hall, Keith ML15155B923 

Hall, Linnea M. Fronce 

Thomas ML15160A853 

Hall, Marian ML15160A880 

Hall, Shawn ML15148B368 

Hall, Silvia ML15156A527 

Hallett, Mark ML15142A196 

Halligan, Melody ML15154A377 

Halligan, Sue ML15154B204 

Hallman, Hollie ML15159A421 

Hallman, Janice ML15156B511 

Appendix E NUREG–2176 E-586 October 2016
Commenter 

ADAMS 

Accession # 

Hallmark, Jena ML15155A321 

Halpern, Carol ML15155B680 

Halpern, Harvey ML15154A172 

Halsell, Claudia ML15156A242 

Halsey, Jane ML15148B398 

Haltom, D. ML15159A025 

Halvorson, Heather ML15155A334 

Hamann, Susan ML15148B285 

Hamilton, Cheryl ML15160A759 

Hamilton, Colleen ML15148A792 

Hamilton, Janet ML15156A722 

Hamilton, Judy ML15155A108 

Hamilton, Pamela ML15155A079 

Hamilton, Ted ML15156A324 

Hamm, Bill ML15155B595 

Hammer, Dorothy ML15154A864 

Hammer, F. ML15159A239 

Hammer, Lisa ML15156B455 

Hammer, Randy ML15153B144 

Hammer, Randy ML15160A707 

Hammerly, Jimi ML15160A856 

Hammond, Bob ML15155B770 

Hammond, Robert ML15160A983 

Hammond, Todd ML15154A102 

Han, Richard ML15156A703 

Hance, Judith ML15156A638 

Hancock, Lynne ML15160A990 

Hancock, Rebecca ML15147A773 

Handford, Janet ML15154A042 

Handwerker, Steven ML15154C032 

Hanff, Jean ML15154B507 

Hanisee, Mark ML15159B010 

Hanks, Douglas ML15154A109 

Hanley, Lindsay ML15158A033 

Hanlon, Jessica ML15162B108 

Hanlon, Jessica ML15162B064 

Hanly, Heather ML15153A464 

Hanna, Jeff ML15148B062 

Hannan, Susan ML15162A055 

Hansen, Alan ML15155B914 

Hansen, Anna ML15153B070 

Hansen, Arthur ML15158A175 

Hansen, Claudia ML15155A002 

Hansen, James ML15155C017 

Hansen, Jan ML15154A968 

Hansen, Kathy-Jo ML15156A229 

Hansen, Marc ML15156B040 

Hansen, Neil ML15159B574 

Hansen, Yvonne ML15154C148 

Hanson, Craig ML15154A023 

Hanson, Delene ML15154A295 

Hanson, Kristin ML15155C094 

Hanson, Naomi ML15155B509 

Hanson, Richard ML15155B894 

Commenter 

ADAMS 

Accession # 

Hanson, Richard ML15156A912 

Happer, Marty ML15153A737 

Haraoui, Samira ML15148B032 

Harbison, G. B. ML15148B127 

Harden, Ronald ML15159B465 

Hardie, Daniel ML15153A409 

Hardin, Judith ML15140A139 

Hardin, Lillian ML15158A172 

Harding, Janilyn ML15153A752 

Hardt, Jerry ML15155C243 

Hardt, Vincent ML15153B216 

Hardy, Linda ML15154A267 

Hardyman, Leslie ML15155C103 

Harish, Anavai ML15154A786 

Harl, Melissa ML15159A985 

Harlan, Ann ML15142A020 

Harlan, Melissa ML15155B612 

Harland, Donald ML15159A594 

Harmon, Terry ML15154C298 

Harper, Alan ML15153B262 

Harper, Diane ML15153A722 

Harper, K. ML15156B419 

Harper, Leslie ML15154C084 

Harper, Marilynn ML15148A603 

Harper, Rebecca ML15159B523 

Harper, Thomas ML15142A167 

Harper, Tom ML15155B198 

Harrell, Marlene ML15155A662 

Harrington, Lonnie ML15159A339 

Harrington, Michelle ML15159A382 

Harrington, Sue ML15153A569 

Harris, Rosemary ML15148A975 

Harris, Susan ML15148B030 

Harris, Brooke ML15142A220 

Harris, Christine ML15141A517 

Harris, Harry ML15156A652 

Harris, J. ML15154A134 

Harris, Jamie ML15159B103 

Harris, Jan ML15148B089 

Harris, Julie ML15154C133 

Harris, Kymberlee ML15153A850 

Harrison, Catherine ML15154A320 

Harrison, Colleen ML15154A287 

Harrison, David ML15159B127 

Harrison, Edward ML15147A756 

Harrison, Jeane ML15155B940 

Harrison, Marie ML15160A884 

Harrison, Norma J. F. ML15155B823 

Harrison, T. Hamboyan ML15153A381 

Harris-Richardson, 

Annette ML15159B359 

Harrod, Dawn ML15153B136 

Harsin, Linda ML15156A171 

Hart, Barbara ML15162B154 

Appendix E October 2016 E-587 NUREG–2176
Commenter 

ADAMS 

Accession # 

Hart, Barbara ML15162B091 

Hart, Cynthia ML15158A042 

Hart, Jamie ML15159A949 

Hart, Jessica ML15155B125 

Hart, Kathy ML15153A989 

Hart, Ruth ML15155B788 

Hart, Sara ML15154B262 

Hart, Tricia ML15153A490 

Hartel, Gale ML15142A320 

Hartenstine, Dennis ML15148A915 

Hartfeld, Ronen ML15160A812 

Hartleb, Carole ML15148B158 

Hartleben, Christian ML15154B891 

Hartley, James ML15141A567 

Hartman, Jenny ML15154B548 

Hartman, Nancy ML15158A089 

Hartman, Nancy Kosnar ML15140A200 

Hartman, Richard ML15156A283 

Hartman, Sue ML15154C176 

Hartman, Todd ML15154A298 

Hartshorne, Annette ML15155B247 

Hartz, Liz ML15154B903 

Harvey, Kathy ML15153A550 

Harvey, Shea ML15155A784 

Harvey, Terry Greene ML15148B168 

Harwell, Janet ML15155B825 

Harwell, Mary Ann ML15159A646 

Hasbach, Corinna ML15156B386 

Haseltine, Amber ML15142A316 

Haskell, Michael ML15142A266 

Hasselbrink, Robert ML15142A095 

Hassig, William ML15154C100 

Hastings, Melissa ML15159A781 

Hastings, William ML15153B278 

Hatch, Gari ML15141A607 

Hatch, Susan ML15155A665 

Hatfield, Eugene ML15154A280 

Hathaway, Christsopher ML15156A765 

Hathaway, Susan ML15155A867 

Hatlem, Cherie ML15155A764 

Hattendorf, Ethan ML15148A695 

Hauber, Barclay ML15148B007 

Hauenstein, Cathleen ML15159A422 

Haugen, Bob ML15162A255 

Haugen, Bob ML15162A633 

Haupt, Carolyn ML15140A111 

Haussner, Norman ML15154A181 

Havens, Judith ML15155A512 

Haverkamp, Kathy ML15154A335 

Hawkins, Denise ML15159B346 

Hawkins, Patricia ML15159A238 

Hayasaka, Kiyo ML15153A574 

Hayes, Christine ML15154B188 

Hayes, Linda ML15156A712 

Commenter 

ADAMS 

Accession # 

Hayes, Mary ML15142A345 

Hayes-Budgen, Shawndra ML15153A702 

Haymans, Deanna ML15156A482 

Hayne, Jan ML15153A476 

Haynes, Michelle ML15160A894 

Haynes, Monica ML15154A101 

Hays, Helen Logan ML15156A666 

Hayward, Michelle ML15155C081 

Hayward, Susan ML15154A315 

Hazard, Evan ML15153B288 

Hazelleaf, Tom ML15159A073 

Hazelton, Judith ML15162A082 

Hazen, Alona ML15155B794 

Hazlett, Rob ML15156B142 

Hazynski, Chris ML15155C053 

Head, Ashley ML15141A715 

Head, Kris ML15158A272 

Headley, Kimberley ML15155B207 

Headley, Linda ML15162B091 

Headley, Linda ML15162B149 

Heagy-Len, Linda ML15159B230 

Heald, Mark ML15154A015 

Heaning, Richard ML15140A188 

Hearthstone, Bonnie ML15159B036 

Heartsong, Judith ML15160A814 

Heath, Mary ML15155A645 

Hebberger, Jo Anna ML15154A294 

Hedges, Ken ML15159B304 

Heffron, Joshua ML15141A677 

Hegarty, Elizabeth ML15154A256 

Hegedus, Barbara ML15159B564 

Heide, Andra ML15156B334 

Heiden, Patricia ML15156A296 

Heiden, Wendy ML15159B544 

Heiks, Kristina ML15155A769 

Heininger, Joseph ML15154B911 

Heinle, Janet ML15148A142 

Heinly, Bridgett ML15153A802 

Heinrich, Hans-Peter ML15141A656 

Heinrich, Hans-Peter ML15155A621 

Heist, Roberta ML15154C255 

Heithaus, Melissa ML15159B476 

Helaudais, Jamie ML15162A665 

Helenchild, Liz ML15148B086 

Helget, Linda ML15156A278 

Helmer, Kathleen ML15153A607 

Helmholz, Sharron ML15154C071 

Helsel, Daniel ML15159B415 

Hemberger, Jade ML15160A062 

Hemingway-Proia, 

Georgeann ML15153A961 

Hemming, Michele ML15154B839 

Hendershot, Tamara ML15148A655 

Henderson, David ML15156B183 

Appendix E NUREG–2176 E-588 October 2016
Commenter 

ADAMS 

Accession # 

Henderson, Douglas ML15155C068 

Henderson, Mae Ann ML15162A067 

Henderson, Maria ML15153A879 

Henderson, Rachelle ML15140A259 

Henderson, Sherry ML15155A238 

Henderson, Steven ML15155A808 

Henderson, Suzy ML15159B370 

Hendler, Carol ML15154A083 

Hendricks, Richard ML15156B025 

Hendrix, Alice ML15158A223 

Hendrix, Dana ML15158A037 

Hendry, Dawn ML15159A052 

Hennemann, W. W. ML15141A750 

Henning, Linda ML15154B703 

Henninger, Melissa ML15156B175 

Henriksen, Deb ML15160A088 

Henriksen, James ML15154A051 

Henry, Anne ML15148B024 

Henry, Harold ML15142A223 

Henry, Martha ML15155B908 

Henry, Robert ML15153A972 

Henry, Sheri ML15153A615 

Hensel, Charles ML15153B147 

Hensgen, Eric ML15140A237 

Hensley, Kim ML15154B222 

Henson, Joey ML15154C304 

Henson, Theresa ML15155C179 

Henzel, William ML15148B047 

Hepburn, Elizabeth ML15155A488 

Herbert, Annabelle ML15153B270 

Herbert, Wendy ML15154B506 

Herbruck, Janet ML15154B063 

Herbst, Daniel ML15141A716 

Herda, Frank ML15154B454 

Herlihy, Peggy ML15155A542 

Herman, Lon ML15156A035 

Hermann, Birgit ML15155A443 

Hermanson, Kristina ML15161A698 

Hernandez, Maria ML15154B192 

Hernandez, Noemi ML15159A012 

Hernandez, Robin ML15148A197 

Hernandez, Steven ML15156B446 

Herndobler, Beth ML15142A027 

Heron, Robert ML15154C226 

Herr, Richard and Marietta ML15140A223 

Herr, Richard and Marietta ML15141A553 

Herrera, Bill ML15141A485 

Herrera, Bill ML15148B432 

Herring, Kathleen ML15155A131 

Herron, Andria ML15153B125 

Herschler, Faith ML15153B121 

Hershey, June ML15154C062 

Herten, Margaret ML15148B113 

Hertz, Albert and Marcia ML15155B154 

Commenter 

ADAMS 

Accession # 

Herwig, Gary ML15140A067 

Herwig, Karen ML15155A158 

Herzog, Elaine ML15159B001 

Hess, Carolyn ML15154A274 

Hess, John ML15154B060 

Hess, Joseph ML15148B291 

Hess, Karin ML15156B452 

Hess, Paul ML15155A088 

Hesse, Susanne ML15148A737 

Hester, Sally ML15142A078 

Hesterberg, William ML15142A302 

Heuman, Chris ML15155A072 

Heuman, Rachel ML15154A575 

Heuman, Tachel ML15155A221 

Hewelt, Karen ML15148B195 

Hewes, WIlliam ML15154C022 

Hewett, Rosemary ML15156A842 

Hewgley, Joseph ML15154B085 

Hewitt, Anne-Marie ML15155C224 

Hewitt, Cheryl ML15156A155 

Hewitt, Sheri ML15141A794 

Hey, Lisa ML15154B976 

Heydemann, Paul ML15142A076 

Heyden, Neil ML15155A109 

Heyneman, Amy ML15155B786 

Hi, Jacki ML15153A338 

Hibbard, Jeff ML15148A247 

Hibben, Tresa ML15155B860 

Hibben, Walker ML15155C100 

Hicklin, Mary ML15154B949 

Hickox, Ann ML15155B846 

Hicks, Robert ML15155B243 

Hidde, John ML15154B273 

Hiestand, Nancy ML15140A268 

Higbee, Susan ML15142A137 

Higgins, Barbara ML15156A248 

Higgins, Susi ML15155A006 

Hightower, Keith ML15159B416 

Hilbert, Pamela ML15155C229 

Hildebrand, James ML15153A753 

Hildebrand, Valerie ML15158A278 

Hildebrandt, Todd ML15155B158 

Hildner, Ellen ML15155A124 

Hill, Bobbi ML15148B272 

Hill, Carol ML15156A950 

Hill, Frank ML15159A214 

Hill, Ginger ML15154B331 

Hill, Jennifer ML15155A532 

Hill, Jessica ML15142A147 

Hill, Joy ML15162A544 

Hill, Lois ML15162A705 

Hill, Michael ML15156B468 

Hill, Nastassia ML15162A226 

Hill, Sally ML15140A119 

Appendix E October 2016 E-589 NUREG–2176
Commenter 

ADAMS 

Accession # 

Hill, Steven ML15162B042 

Hill, Steven ML15162B100 

Hillard, Dale ML15156A692 

Hilliard, Donald ML15156B146 

Hilliard, Jenn ML15162A498 

Hills, Sally ML15156A330 

Hillstrom, Cindee ML15159A236 

Hilpman, Dwight ML15159A772 

Hiltz, Dan ML15155B859 

Himmelman, Carol ML15159A688 

Hinds, Elenita ML15159A031 

Hinerman, Michele ML15153A333 

Hines, Allison ML15154C284 

Hines, Lanier ML15155A257 

Hines, Nancy ML15155B737 

Hinson, Kathy ML15153B027 

Hinton, Eugene C. ML15142A300 

Hinze, Willie ML15153A740 

Hipp, James ML15155B743 

Hipsher, Linda ML15156A192 

Hirano, Kim ML15154C182 

Hird, Lindsey ML15159B399 

Hirsch, Catherine ML15155B508 

Hirsch, Harriet ML15140A032 

Hirsh, Ethan ML15154B737 

Hiseley, Michelle ML15155A940 

Hitchcock, Erik ML15156A717 

Hitchins, John ML15148B335 

Hite, Richard ML15154C128 

Hittle, Mike ML15159A749 

Hix, Hildegard ML15153A835 

Hix, Katherine ML15155B209 

Hlat, Mike ML15160A918 

Hlodnicki, Bruce ML15162B064 

Hlodnicki, Bruce ML15162B131 

Hoaglin, Dianne ML15154C097 

Hoats, John ML15141A583 

Hobbs, Joan ML15162A667 

Hobson, Kelvin ML15154A184 

Hochendoner, Bernard ML15155A507 

Hodge, Sonya ML15155B584 

Hodges, Andrea ML15154C216 

Hodges, Christina ML15142A310 

Hodie, Jake ML15159B366 

Hodovan, Francine ML15156A116 

Hodson, Sally ML15156A101 

Hoegler, Jean ML15154C117 

Hoernig, Paul ML15155B379 

Hoesel, Walter ML15155A661 

Hoess, Joseph ML15155B253 

Hofacker, Keith ML15141A702 

Hoff, Mary ML15156A083 

Hoff, Michelle ML15159B578 

Hoffman, Brenda ML15155C043 

Commenter 

ADAMS 

Accession # 

Hoffman, Lisa ML15153A937 

Hoffman, Marc ML15148A958 

Hoffman, Nancy ML15162A294 

Hoffman, Tom ML15154B761 

Hoffmann, James ML15156A484 

Hofheins, Paul ML15155A712 

Hofing, Amy ML15156A653 

Hogan, Cynthia ML15154A722 

Hogan, Jack ML15154B086 

Hogan, Michael ML15154A171 

Hogan, Randolph ML15155B863 

Hogle, Dick ML15142A185 

Hogue, Kelly ML15154B682 

Hohenshelt, Felicity ML15154A539 

Hojda, Debora ML15160A087 

Holden, Grace ML15158A220 

Holguin, George ML15156A804 

Holland, Brett ML15159B246 

Holland, Fern ML15154B905 

Holland, Lovice ML15154A248 

Hollenbeck, Margaret ML15148A222 

Hollenbeck, Pamela ML15159A137 

Holliday, T. ML15148B074 

Hollington, Jason ML15155A106 

Hollinrake, Mark ML15154B987 

Hollis, Bonnie ML15142A153 

Hollis, Kathleen ML15153A745 

Hollis, Nancy ML15148B347 

Hollis-Franklyn, Candace ML15155B516 

Hollister, David ML15156A186 

Hollon, Leanna ML15159B433 

Holloway, Elizabeth ML15148A744 

Holm, Samantha ML15140A269 

Holman, Clarisse ML15162A362 

Holmdahl, K. ML15155C092 

Holmes, Andre ML15155B622 

Holmes, Beate ML15159B054 

Holmes, Brad ML15159A992 

Holmes, Debbie ML15141A735 

Holmes, Phyllis ML15156A243 

Holmgren, Jeanette ML15159A449 

Holoduek, John ML15156B085 

Holsten-Coleman, Karen ML15156A246 

Holt, Amy ML15154A752 

Holt, Bill ML15148A901 

Holt, Kendra ML15154B937 

Holt, Mary ML15142A367 

Holt, Rhonda ML15158A195 

Holthaus, Tracy ML15158A253 

Holtrop, Holly ML15159A358 

Holtzclaw, John ML15142A286 

Holtzman, Dorothy ML15154B319 

Holtzman, Jed ML15154B001 

Holtzman, Lawrence ML15140A125 

Appendix E NUREG–2176 E-590 October 2016
Commenter 

ADAMS 

Accession # 

Holzbach, Windy ML15155C079 

Holzer, Rebecca ML15156A977 

Holzle, Cheryl ML15154A096 

Hon, Don ML15155A295 

Hong, Celeste ML15155B181 

Honigsblum, Alexander ML15155B093 

Honore, Stephanie ML15159A839 

Hoobing, Stan ML15153A974 

Hood, Janet ML15159B007 

Hood, Nick ML15155A916 

Hoodwin, Marcia ML15154C109 

Hook, Holly ML15148B161 

Hooks, David ML15160A903 

Hooley, Merle ML15154C202 

Hooson, Clare ML15141A447 

Hooven, Betty ML15155B797 

Hoover, Linda ML15156A588 

Hope, Holly ML15154A364 

Hope, Katherine ML15156A204 

Hopkins, Blair ML15141A424 

Hopkins, James ML15148A137 

Hopkins, Jeff ML15155B602 

Hopkins, Kathy ML15148A240 

Hoppenfeld, Cynthia ML15148A133 

Horan, Debbie ML15162B079 

Horan, Debbie ML15162B126 

Horiwitz, Laura ML15155A379 

Horn, Roger ML15156A311 

Hornak, Joann ML15142A238 

Horne, Mike ML15155A149 

Horne, Paul ML15153A925 

Horstman, Kara ML15159A344 

Horton, Christine ML15154B556 

Horwath, Pamela ML15158A229 

Horwitz, Martin ML15153B062 

Hosea, Marilyn ML15148B271 

Hosek, Ruth ML15156A988 

Hotchkiss, Jay ML15153A969 

Hottenstein, Tara ML15142A299 

Houchin, John F. ML15155A005 

Hough, Susan ML15148A601 

Houghton, Francis ML15159B565 

Houghton, Melissa ML15154B789 

House, Robert ML15154C006 

Houseworth, Bradley ML15160A891 

Houston, Annie ML15153A694 

Houston, Meghan ML15159A440 

Hovekamp, Larry ML15142A362 

Hovey, Roseanne ML15154B044 

Howard, Bryan ML15159A738 

Howard, Jim ML15154C010 

Howard, Lucy ML15154B748 

Howard, Nancy ML15156A240 

Howard, Sarah ML15155B343 

Commenter 

ADAMS 

Accession # 

Howard, Toni ML15158A124 

Howden, John ML15154A050 

Howe, Jill ML15155A306 

Howell, Carol ML15142A216 

Howell, Crystal ML15154C070 

Howell, Julia ML15155A449 

Howell, Lisa ML15153A786 

Howell, Lisa ML15154A084 

Hower, Alvin ML15155A388 

Howes, Abigail ML15156A234 

Howes, Elaine ML15141A694 

Howie, Linda ML15158A109 

Howlett, Ariel ML15156A474 

Howry, Marita ML15155A139 

Hoyle, Lester and Judy ML15154C229 

Hriljac, Donna ML15154B203 

Hubbard, Dan ML15154A352 

Hubbell, Sharon ML15153B218 

Huber, Anne ML15155B904 

Huckaba‐Paiz, Sharol ML15162A236 

Hudak, Lesley ML15159A277 

Huddleston, Heather ML15154C260 

Hudgins, Jerry ML15154C213 

Hudson, Harry ML15155B471 

Huerta, John ML15155A905 

Huerta, Juan ML15154A060 

Huffman, Russell ML15162A078 

Hufnagel, Glenn ML15154C116 

Hufnagel, Martha ML15155A885 

Huggins, Barbara ML15153B168 

Hughes, Angela ML15148B315 

Hughes, Barbara ML15153B302 

Hughes, Curtis ML15155C052 

Hughes, Diane ML15154B275 

Hughes, Jennifer ML15160A915 

Hughes, Jessica ML15162A586 

Hughes, Karan ML15155C169 

Hughes, Kathryn ML15155A343 

Hughes, Kevin ML15156A297 

Hughes, Laurel ML15156B345 

Hughes, Lisa ML15142A278 

Hughes, Richard ML15153A877 

Hui, Sng ML15159A517 

Hulbert, Susi ML15154C119 

Hull, Cynthia ML15159A034 

Hull, Gary ML15153A790 

Hull, Juanita ML15156B038 

Hull, Lise ML15148B437 

Hull, Ronald ML15153B287 

Humane Society 

South Brevar ML15159A037 

Hummell, Annette ML15159A401 

Humphrey, Carol ML15158A112 

Humphrey, Thomas ML15148A266 

Appendix E October 2016 E-591 NUREG–2176
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Accession # 

Humphries, Roberta ML15142A237 

Humrich, Gilia ML15153A372 

Hung, Patricia ML15148A134 

Hunrichs, Paul ML15156B301 

Hunt, Jill ML15162A064 

Hunter, Jan ML15153A887 

Hunter, Susan ML15153B261 

Hunter, Suzanne ML15140A190 

Huntington, Stephanie ML15142A218 

Huntley, Cheryl ML15142A364 

Huntley, Heather ML15159A147 

Huntley, William ML15154B652 

Hurley, Brady ML15155A233 

Hurley, Mark ML15155A538 

Hurst, June ML15154C153 

Hurtt, Kimberly ML15159A956 

Hurwitz, Jeffrey ML15141A592 

Husby, Jason ML15155C059 

Hutchens, Jr., John ML15148A620 

Hutchings, William ML15153B007 

Hutchins, David ML15153B094 

Hutchins, Katherine ML15153A805 

Hutchins, Leslie ML15155B043 

Hutchinson, Jerry ML15159B338 

Hutchison, Dwight ML15141A491 

Huth, Graciela ML15155A436 

Huttinger, Roberta ML15156B129 

Huttner, Elodie ML15153A430 

Hutton, Craig ML15154B114 

Hvozda, Tammi ML15154A361 

Hwad, Monoe ML15148A640 

Hyche, Kenneth ML15155A360 

Hyde, Lynda ML15160A531 

Hynd, J. ML15155A399 

Ibbotson, David ML15154A072 

Idone, Carol ML15147A709 

Iffland, Lisa ML15148A747 

Ihne, Merle ML15142A360 

Ihrig, Janis ML15158A285 

Ii, Keith Rick ML15148B213 

Ii, Riley Canada ML15159B342 

Ilowiecki, John ML15142A037 

Iltis, Michael ML15153A447 

Iltzsche, William ML15155A517 

Iluna, Mana ML15142A121 

Imada, F. ML15154A449 

Imberton, Marie‐France ML15156B409 

Imel, Arjuna ML15159B500 

Imker, Susan ML15148A650 

Immasche, Sonia ML15156A865 

Immel, Amy ML15156A265 

Indrelie, Kenneth ML15160A745 

Infante, Neil ML15141A723 

Ingraham, E. ML15155A113 

Commenter 

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Accession # 

Ingram, Taylor ML15155A027 

Insurriaga, Aurora ML15155B721 

Ionina, Kate ML15162A352 

Ireland, Victoria ML15159B090 

Irvine, Gael ML15155B059 

Isaac, David ML15153A723 

Iseri, Martin ML15148B379 

Ishii‐Kiefer, Takako ML15141A758 

Ismail, Hildy ML15154A193 

Israel, Miriam ML15154A813 

Israil, S. ML15148B050 

Ivankovic, Anthony ML15154A139 

Iversen, Sheryl ML15154B307 

Iverson, Steve ML15155B268 

Iverson, Susan ML15160A920 

Ivey, Cheryl ML15154A229 

Ivy, Rebecca ML15148A257 

Iwankiw, Pilar ML15156A469 

Izzo, Martha ML15154A624 

Izzo, Martha ML15154A946 

Jaakola, Julia ML15156B093 

Jablonski, Margaret ML15154C055 

Jacinto, Paloma ML15162A722 

Jackimiak, Jim ML15141A685 

Jackson, Carol ML15141A642 

Jackson, David ML15156B131 

Jackson, Ginny ML15154C096 

Jackson, James ML15154A634 

Jackson, Judy ML15155A089 

Jackson, Lael ML15154A089 

Jackson, Phyllis ML15148A225 

Jackson, Richard ML15154A198 

Jackson, Sasha ML15141A718 

Jackson, Warren ML15148B055 

Jacob, Sheena ML15159A158 

Jacobs, John ML15154C214 

Jacobs, Judy ML15159A142 

Jacobs, qJohn ML15155A324 

Jacobsen, Kathleen ML15153B081 

Jacobson, Lawrence ML15153B205 

Jacobson, Martin ML15153A914 

Jacobson, Paul ML15155A672 

Jacobs‐Pollez, Rebecca ML15162A171 

Jacque, Carol ML15154A277 

Jacques, David ML15153A982 

Jacques, Karen ML15153B006 

Jacques, Sally ML15148A971 

Jadczak, Andrew ML15148B085 

Jaeger, Pam ML15141A789 

Jaegers, Martha ML15154A231 

Jahos, Ellen ML15142A308 

Jakubowska‐Cook, Ewa ML15156B346 

Jalbert, Diane ML15155A074 

Jamal, Kate ML15141A665 

Appendix E NUREG–2176 E-592 October 2016
Commenter 

ADAMS 

Accession # 

James, Damian ML15154A191 

James, Ilona ML15142A242 

James, Kristine ML15155A015 

James, Nancy ML15141A584 

James, R. Dean ML15153B234 

James, Robert ML15158A049 

James, Russell ML15154C204 

Jamison, L. ML15148A942 

Jamison, Sara ML15154A153 

Jamsheed, Ghazale ML15155B947 

Jamvolds, Shunko ML15159B270 

Janczuk, Stan ML15154A520 

Jandourek, Alexia ML15158A197 

Janowsky, Margaret ML15155A193 

Jarvis, J. R. ML15155A722 

Jastromb, Virginia ML15154B855 

Jatinen, Jane ML15154A082 

Jaye, Abigail ML15142A283 

Jean, Patrick ML15160A815 

Jeavons, John ML15156B041 

Jenisio, Kurt ML15141A546 

Jenkin, Rob ML15155A094 

Jenkins, Cheryl ML15156A787 

Jenkins, Eugenie ML15148B209 

Jenkins, Janell ML15155B090 

Jenkins, Lynn ML15154A374 

Jenks, Robert ML15159A269 

Jenne, Karen ML15155A939 

Jennings, Erin Stuart ML15148B350 

Jennings, Linda ML15155A432 

Jennings, Scott ML15155B843 

Jennings, Sid ML15156B199 

Jensen, Brett ML15159A054 

Jensen, Catherine ML15153A896 

Jensen, Cornelia ML15156A720 

Jensen, Donna ML15155A586 

Jensen, Jan ML15148B002 

Jensen, S. ML15153B078 

Jensen, Victoria ML15142A355 

Jernquist, Harriet ML15155A875 

Jeschke, Herbert ML15142A047 

Jessee, Judy ML15153B221 

Jessop, D. ML15142A059 

Jessup, Nicole ML15141A763 

Jeude, Shirley ML15148A917 

Jeude, Shirley ML15148A924 

Jezierski, Elisabeth ML15156A651 

Ji, J. ML15158A081 

Jimenez, Lawrence ML15156A646 

Jishi, Mazen ML15154B198 

Joas, Chris ML15154A824 

Jobe, Laura ML15159A001 

John, Oda ML15155B334 

Johnsen, Harold ML15153B032 

Commenter 

ADAMS 

Accession # 

Johnson, Gordon ML15159A148 

Johnson, Arnold ML15156B469 

Johnson, Beverly ML15155B734 

Johnson, Carol ML15148B221 

Johnson, Chad ML15154B894 

Johnson, Don ML15158A206 

Johnson, Edward ML15156A664 

Johnson, Esther ML15153A842 

Johnson, Gregg ML15162A603 

Johnson, Janice ML15153B150 

Johnson, Jim ML15159A496 

Johnson, Joel ML15161A625 

Johnson, Jona ML15154B242 

Johnson, Julie ML15155A145 

Johnson, Kay ML15161A638 

Johnson, Larry ML15159A022 

Johnson, Laura ML15154A326 

Johnson, Leslie Austin ML15156A744 

Johnson, Lorraine ML15154B765 

Johnson, Martha ML15148B405 

Johnson, Mary ML15148B439 

Johnson, Maxwell ML15154B907 

Johnson, Michael ML15148A644 

Johnson, Michael ML15153A687 

Johnson, Michael ML15159A325 

Johnson, Michele ML15154B256 

Johnson, Michele ML15154B750 

Johnson, Nancy ML15153B292 

Johnson, Nita ML15148A867 

Johnson, Pat ML15159A047 

Johnson, Paula ML15155B407 

Johnson, Rheta ML15148B048 

Johnson, Richard ML15141A632 

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Johnson, Soeren ML15142A118 

Johnson, Susan ML15141A612 

Johnson, Suzy ML15159B435 

Johnson, Thomas ML15158A019 

Johnson, Tracy ML15148B093 

Johnson, Vicki ML15153A746 

Johnson-Hamerman, Lois ML15154B518 

Johnson‐Hamerman, Lois ML15158A108 

Johnston, Allan ML15156A085 

Johnston, James ML15148B014 

Johnston, Judy ML15156A529 

Johnston, Susan ML15140A028 

Johnstone, Lizette ML15159A211 

Joines, Aileen ML15155B014 

Jolly, John ML15154B676 

Joly, Frederique ML15159B000 

Jonaitis, Charles ML15155A024 

Joncus, Andrew ML15159B411 

Jones, Alice ML15155C191 

Appendix E October 2016 E-593 NUREG–2176
Commenter 

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Accession # 

Jones, Andrea ML15156A991 

Jones, Angie Grosland ML15153A470 

Jones, Avianna ML15154A828 

Jones, Carol ML15159B375 

Jones, Charles ML15160A065 

Jones, Dylan ML15155B960 

Jones, Gary ML15156B302 

Jones, Ingrid ML15159A509 

Jones, Joshua ML15154B095 

Jones, Leah ML15159A473 

Jones, Libby ML15155A727 

Jones, Marie ML15141A680 

Jones, Ronald ML15154A647 

Jones, Roslyn ML15154A782 

Jones, V. and B. ML15155A730 

Jordan, Archer ML15154A097 

Jordan, Lois ML15162B111 

Jordan, Lois ML15162B064 

Jordan, Mark ML15154B899 

Jordan, Scharley ML15155A715 

Jorgensen, Alena ML15155A087 

Jorgenson, Linda ML15140A276 

Jorz, Martha ML15153A387 

Joseph, Ann ML15153A811 

Josselyn, Susan ML15160A551 

Jourdenais, Richard ML15154A866 

Joy, Deborah ML15156B107 

Joy, Krista ML15154A376 

Joyce, Joy ML15155C166 

Joym, Kat ML15162A568 

Joyner, Jerry ML15154A780 

Joyner, Marjorie ML15156B380 

Juba, Anne ML15156A548 

Judge, Patrick ML15153B153 

Juelich, Clarence ML15155A456 

Juhl, Esther ML15159A333 

Julian, Alexis ML15154A380 

Jumet, Pamela ML15159B077 

Jumonville, J. ML15141A786 

June, Doris S. ML15155A390 

June, Taylor ML15156A196 

Jungers, Linda ML15148B447 

Jun‐Morris, Mary Anna ML15156A798 

Juras, Randy ML15154B691 

Jurczewski, Carol ML15147A727 

Jurgela, Elena ML15148B433 

Jurgensen, Catherine ML15155A167 

Jurin, Richard ML15141A538 

Juskowich, Nancy ML15160A957 

Justice, Kimberly ML15159B098 

Jyleen, Ron ML15156A191 

K., C. ML15155A352 

K., J. ML15155B648 

Kabisch, Mary Ethel ML15155B874 

Commenter 

ADAMS 

Accession # 

Kaehler, Linda ML15155B681 

Kaffer, Kathryn ML15155A765 

Kagl, Katharin ML15156A999 

Kahigian, Peter ML15159A915 

Kahnemundt, Martin ML15156A119 

Kain, Jennifer ML15141A561 

Kainz, Carlos ML15153B054 

Kaiser, Kathleen ML15154A621 

Kaiser, Mark ML15153A469 

Kaitis, Kathleen ML15148B194 

Kalbac, Mariette ML15155B781 

Kaler, Jason ML15148A793 

Kalinowski, Catherine ML15155A641 

Kalinski, Ray ML15154C094 

Kalka, Paul ML15156A761 

Kalvesmaki, Andrea ML15153B104 

Kameon, Kitty ML15153B014 

Kaminski, Marcia ML15155B696 

Kampa, Jan ML15154B859 

Kamrath, Henry ML15148A221 

Kane, Brooke ML15148A920 

Kane, Jolyne ML15154B278 

Kane, Linda ML15155A378 

Kane, Nina ML15156B449 

Kanee, Shirley ML15153A517 

Kanzer, Michaelain ML15156B176 

Kaplan, Kay ML15148A767 

Kapphahn, Gregory ML15154B963 

Kapustka, Franklin ML15155A189 

Karanjawala, Eric and 

Armin ML15148A252 

Karlow, Edwin ML15160A657 

Karls, Kristi ML15159A860 

Karlson, Fred ML15156A919 

Karpel, Janice ML15156B510 

Karpel, Ruth ML15155A041 

Karst, Richard ML15154C165 

Karsten, Annetta ML15158A072 

Kasey, C. ML15154B678 

Kask, Pat ML15159B363 

Kasper, Sandy ML15156A994 

Kast, Kathy ML15140A037 

Kast, Kenneth ML15154A464 

Kastner, Margean ML15155B915 

Katerinsky, Bess ML15142A172 

Kates, Barbara ML15158A021 

Katterson, Melissa ML15155B720 

Katz, Alissa ML15155C106 

Katz, David ML15155B762 

Katz, Ronald ML15154A368 

Katz, Sondra ML15155C110 

Kaufman, Mike ML15154B393 

Kause, Theresa ML15155A968 

Kautz, Katherine ML15154B695 

Appendix E NUREG–2176 E-594 October 2016
Commenter 

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Accession # 

Kavanaugh, Michael ML15160A068 

Kaye, Barb ML15155A592 

Kaye, Jackie ML15162A588 

Kea, Ruth ML15154A485 

Keast, Alix ML15153A845 

Keats, James ML15156A535 

Keegan, Helen ML15159B451 

Keener, Arlene ML15156B172 

Keeton, Hank ML15155A096 

Kegelman, Julia ML15154C065 

Kegler, Carol ML15155B424 

Kehl, David ML15154A670 

Keim, Steve ML15155B491 

Keiner, Kathryn ML15153B306 

Keiser, John ML15147A751 

Keiser, Peter ML15155A296 

Keiter, Nancy ML15156A979 

Keitz, Jennifer ML15155A687 

Keller, Brandon ML15155A243 

Kellermann, Thomasin ML15140A197 

Kelley, Marci ML15156B379 

Kelley, Pat ML15148B097 

Kelley, Ruth ML15160A524 

Kellndorfer, Emily ML15140A291 

Kelly, Bev ML15142A023 

Kelly, Brian ML15160A651 

Kelly, Gordon ML15153B259 

Kelly, Joe ML15148B357 

Kelly, Kevin ML15142A358 

Kelly, Kevin ML15154C112 

Kelly, Lisa Ann ML15154C013 

Kelly, Lisa Ann ML15155A269 

Kelly, Lucy ML15159A906 

Kelly, Stephen ML15148B378 

Kelly, Theresa ML15153B105 

Kelly, Theresa ML15154A814 

Kelman, Barry ML15154C243 

Kelsheimer, Elise ML15155A527 

Kelso, Carolyn ML15156B196 

Kemnitzer, David ML15155A736 

Kempf, William ML15162A732 

Kemple, Jason ML15153A521 

Kenagy, David ML15155B399 

Kendall, Donna ML15154A180 

Kendy, Arthur ML15155A383 

Kenion, Lisa ML15155B831 

Kennedy, Katya ML15141A727 

Kennedy, Sara ML15155B193 

Kennedy, Sarah ML15142A194 

Kenney, Pat ML15156A455 

Kennington, Janet ML15155A813 

Kenny, Bonnie ML15156B453 

Kenny, Paula ML15155C213 

Keough, Maurene ML15159A144 

Commenter 

ADAMS 

Accession # 

Kepley, Janna ML15159A119 

Kerman, Paul ML15156A732 

Kern, Carol ML15142A246 

Kern, Cynthia ML15153A613 

Kern, Madeleine Fisher ML15153B247 

Kern, Mark ML15154B653 

Kerns, Loretta ML15154A328 

Kerr, Heather ML15160A989 

Kersey, Donna ML15153B291 

Kersting, Pamela ML15155B675 

Keskitalo, Candace ML15155B867 

Kestell, Kathleen ML15156A212 

Keup, Astrid ML15156A564 

Keylin, Margaret ML15156B464 

Keys, Tom ML15162A216 

Keyser, Donald ML15141A730 

Khan, Zohal ML15140A150 

Khoury, Donna ML15153B273 

Khoury, Valentina ML15160A561 

Kibbe, Carolyn ML15153B059 

Kibbel, Kathi ML15140A122 

Kiel, G. Kendall ML15155A760 

Kielman, Laura ML15140A185 

Kienzle, Sandy ML15156A714 

Killion-Mottola, Brittani ML15142A187 

Kimatian, III, George ML15156A285 

Kimball, Larry ML15148B248 

Kimmel, Gailmarie ML15155A336 

Kincaid, Karen ML15162B089 

Kincaid, Karen ML15162B136 

Kindel, Karen ML15158A279 

King, Alex ML15155C108 

King, Barbara ML15140A002 

King, Ben ML15156B337 

King, Carol ML15142A046 

King, Christine ML15161A630 

King, Judith ML15155A648 

King, Justine ML15158A062 

King, Kathleen ML15155B205 

King, Kim ML15154A645 

King, Ryan ML15153A514 

King, Terry ML15154B130 

King, Tiffany ML15155A081 

King, Travis ML15159B495 

Kinkaid, David ML15142A162 

Kinney, Douglas ML15159A235 

Kinzer, Thelma ML15155A476 

Kirby, Yvonne ML15154A613 

Kirchner, John ML15154C300 

Kirk, Brian ML15153A504 

Kirk, Dorothy ML15142A135 

Kirk-Leach, Cheryl ML15156A042 

Kirkpatrick, Jim ML15148B224 

Kirschbaum, Saran ML15148A753 

Appendix E October 2016 E-595 NUREG–2176
Commenter 

ADAMS 

Accession # 

Kirshbaum, Adrienne ML15155C032 

Kirsling, Mary Ann ML15148B128 

Kish, Betty ML15140A107 

Kisinger, Ed ML15154C072 

Kisner, Al ML15159A708 

Kiss, Suzanne ML15141A659 

Kisselburg, Desiree ML15148B021 

Kistler, Andrew ML15156A715 

Kite, Richard ML15154B878 

Kittle, Pat ML15140A014 

Kitzinger, Jana ML15159B522 

Kiva, Jo Ann ML15159A223 

Kiver, Eugene ML15154A022 

Klasey, Janet ML15154B091 

Klausing, Michael ML15141A710 

Klauss, Mike ML15159B254 

Klebl, Susan ML15142A143 

Kleckler, Jan ML15160A832 

Klefbeck, Randal ML15155B693 

Klein, Chuck ML15148A991 

Klein, Daniel ML15155B964 

Klein, J. ML15141A790 

Klein, Linda ML15160A831 

Klein, M. ML15147A723 

Klein, M. ML15153A331 

Klein, Reinhard ML15148B386 

Klein, Robert ML15155C002 

Klein, William ML15153A734 

Klemm, Marcine ML15155A326 

Klemm, Marcine ML15155B263 

Klemm, Marcine ML15159B121 

Klempin, Serena ML15155B406 

Klepek, Lisa ML15140A232 

Klerer, Leona ML15148A167 

Klessig, Young ML15158A028 

Kliche, Diana ML15148A961 

Kliche, Diana ML15154A804 

Klimovitz, Joseph ML15154B671 

Kline, Danny ML15154C277 

Klingston, Karen ML15156A677 

Klinkovskaya, Irina ML15148A994 

Klipfel, George ML15156B332 

Klock, William ML15153A751 

Klohck, George and 

Margaret ML15155A514 

Klubek, Vic ML15155B325 

Klugiewicz, Mark ML15155B748 

Kluhsman, Holly ML15155B573 

Klump, Ted ML15162A658 

Knapton, Alex ML15154B102 

Kneedler, William ML15155B726 

Kneeland, Leslie ML15156A602 

Kneibert, Walter ML15155A711 

Kniffin, Margaret ML15154B656 

Commenter 

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Accession # 

Knight, Bobbie ML15148B365 

Knight, David ML15155B005 

Knight, E. M. ML15155C042 

Knight, Haven ML15156B459 

Knight, Julia ML15142A268 

Knight, Tina ML15155B469 

Knights, Lindsay ML15154B790 

Kniola, Marjorie ML15153B086 

Knoblock, Glenn ML15140A247 

Knodel, Henry ML15154B931 

Knoll, Carolyn ML15155A670 

Knoll, Julie ML15155B072 

Knorr, Carl ML15142A198 

Knuteson, Mary ML15155A401 

Knutson, Dana ML15156A695 

Kobayashi, Hugo ML15154C155 

Kobayashi, Hugo ML15161A665 

Kobayashi, Kate ML15155A795 

Kobylarz, Denise ML15153B170 

Kocer, John ML15154C162 

Koch, Aaron ML15155A372 

Koch, Joann ML15148A918 

Koch, John ML15140A154 

Koch, Peter ML15160A075 

Koch, Veronica R. ML15162A708 

Koeller, David ML15154A130 

Koenig, Georgia ML15154A706 

Koeninger, Laura ML15155C087 

Koessel, Karl ML15153A812 

Kofler, Michelle ML15156A051 

Kogan, Richelle ML15153A795 

Kohlenburg, Lindsey ML15159B409 

Kohlet, Robin ML15155A316 

Kohn, Carolyn ML15156B489 

Kohn, Laura ML15154C158 

Koiv, Ulle ML15142A312 

Koivisto, Ellen ML15155B494 

Kokaly, Atheer ML15148A269 

Kokett, Kim ML15153A756 

Kokkonen, Donald ML15155B068 

Kolakosky, Linda ML15156B248 

Kolassa, Michael F. ML15153A769 

Kolbe, Ken ML15154B832 

Kolbe, Tiffany ML15155B064 

Kolek, Brian ML15159B520 

Koles, Barbara ML15154A909 

Kolessar, Joan ML15154B683 

Kollasch, Michelle ML15154B926 

Kolodji, Yelena ML15153A796 

Kolodziejczyk, Dorota ML15159B543 

Kolter, Art ML15154C113 

Komar, Delores ML15154B096 

Komin, Tatyana ML15148B252 

Konczal, Eddie ML15159A373 

Appendix E NUREG–2176 E-596 October 2016
Commenter 

ADAMS 

Accession # 

Konrad, Martin ML15140A246 

Koo, Rebecca ML15155B986 

Koopman, Patricia ML15154A939 

Kopp, Isabel ML15162A546 

Kordes, Maria ML15159B498 

Kormann, Carollina ML15153A573 

Korn, Sandra ML15148B185 

Kornet, Christine ML15154A196 

Kosak, Donald ML15156A232 

Kosar, Rebecca ML15159A400 

Koschmeder, Teresa ML15155B936 

Kosec, Dawn ML15159B067 

Kosmark, Mary ML15148B366 

Koss, Joyce ML15142A124 

Koster, Philip ML15154C027 

Kostis, Steven ML15156A011 

Kotch, Brant ML15154A901 

Kotsis, Eleni ML15162A088 

Kouba, Nadine ML15160A520 

Kouzel, Lynn ML15155B943 

Kovac, Charles ML15155A472 

Kovacs, Jacqueline ML15148A195 

Kovacs, Natalie ML15158A085 

Koven, Thomas ML15160A086 

Kovich, Jenni ML15142A064 

Kowalewski, Douglas ML15159A167 

Krajewski, Barbara ML15159A059 

Kral, Suzanne ML15142A317 

Kramer, Andrew ML15155B362 

Kramer, Dorine ML15155B950 

Kramer, Gavin ML15142A092 

Kramer, Kelly ML15153A424 

Kramer, Lauren ML15155C238 

Kramer‐Smith, Lara ML15153B210 

Krasnoff, Joshua ML15148A776 

Krause, Al ML15148B120 

Krause, Doug ML15154B311 

Krause, Karen ML15155A102 

Krause, Susan ML15142A032 

Krause, Susan ML15158A173 

Krause, William ML15155B608 

Kreitz, Cynthia ML15153B209 

Krenz, Donna ML15155A898 

Kreutzjans, Viv ML15154A601 

Krewson, Caroline ML15160A741 

Krider, Sherry ML15153B187 

Kring, Juli ML15156A538 

Krinsky, William ML15160A798 

Kriss, Evan Jane ML15153A714 

Kristy, Joseph ML15155B886 

Kroeger‐Mappes, Joy ML15158A131 

Krouchick, Jennifer ML15159B496 

Krouse, Mike ML15153A834 

Krueger, David ML15160A582 

Commenter 

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Accession # 

Krueger, Marjorie ML15155C075 

Krueger-Cunningham, 

Cosima ML15155C065 

Kruggel, Thomas ML15162A133 

Krupinski, K. ML15154B861 

Kruppa, Muriel ML15155B324 

Kruszynski, Yasiu ML15155B256 

Krygowski, Richard ML15141A508 

Kryshak, Walter ML15141A756 

Ku, Michelle ML15154A491 

Kubik, Jerry ML15155A286 

Kubik, Jerry ML15156A872 

Kubzdela, Kashka ML15148B388 

Kucewicz, Leo ML15159A541 

Kuchera, Steve ML15160A898 

Kuckel, Charles ML15148A996 

Kucynski, Ron ML15155A025 

Kuczynski, Kathleen ML15155B920 

Kuestner, William ML15142A165 

Kugler, Terri ML15154C046 

Kugler, Terri ML15154C050 

Kuhlman, Lewis ML15155A818 

Kuhn, Gerald ML15153A390 

Kuhn, Kerry ML15155A626 

Kuhn, Marty ML15159A132 

Kuhnel, Kathie ML15148B179 

Kuhns, Doris ML15158A050 

Kukkonen, Holly ML15153B176 

Kuncl, Janet ML15155B065 

Kundrot, Kenneth ML15154B566 

Kunkler, Scott ML15153A433 

Kunz, Darleen ML15148B389 

Kunz, James ML15162A104 

Kunz, Ray ML15141A532 

Kuppler, Curtis ML15159B283 

Kuri, Joseph ML15155A349 

Kurowski, Lois ML15153B074 

Kurtz, Christy ML15141A627 

Kurtz, Kevin ML15160A838 

Kurtz, Maya ML15162B042 

Kurtz, Maya ML15162B096 

Kurucz, Laszlo ML15162A429 

Kurz, Richard ML15159A064 

Kurzweil, Andrew ML15155A255 

Kusick, Paul ML15153B276 

Kuykendall, Ron ML15148A649 

Kuznier, Janys ML15154B990 

Kwitt, Michael ML15154B747 

Kyse, Barbara ML15154C219 

L., Candace ML15142A024 

La Fleur, Gloria ML15154A121 

La Forgia, Tony ML15159A555 

La Lone, Darrell ML15153A870 

La Mont, Sandra ML15159A557 

Appendix E October 2016 E-597 NUREG–2176
Commenter 

ADAMS 

Accession # 

La Paglia, Claudia ML15160A056 

La Pointe, Drena ML15154B802 

La Pointe, Keith ML15155A589 

La Rocca, Isabella ML15142A322 

La Serra, Stephen ML15148B332 

Lab, Michael ML15159A463 

Labb, Deborah ML15153A729 

Labrie, Michele ML15141A615 

Lacas, Turner ML15154B677 

Lacey, Pamela ML15155B836 

Laclair, Gary ML15154A055 

Lacognata, Dale ML15154B110 

Lacroix, Catherine ML15148B307 

Ladd, Karen ML15154B270 

Ladouceur, Alain ML15155C056 

Lafleur, Steven ML15159A851 

Lafond, David J. ML15156B191 

Lafrance, Roberta ML15156B246 

LaGasse, Jeffrey Paul ML15154B980 

Lagerberg, Rose ML15154B848 

Lagrone, Amy ML15141A711 

Laieski, Caleb ML15198A122 

Laieski, Caleb ML15162A099 

Laik, Judith ML15155B080 

Laine, Alexis ML15156A202 

Laird, Jim ML15156A899 

Laitinen, Carol ML15158A032 

Lake, Daphne ML15156A843 

Lakebrink, Joan ML15154B749 

Lakin, Charles ML15155B579 

Lakosil, Joanne ML15154B135 

Laliberte, Kevin ML15155A820 

Lam, Ofelia ML15141A733 

Lamadrid, Irina Golda ML15148A612 

Lamaster, Gary ML15155B988 

Lamb, Diane ML15141A511 

Lamb, Leslie ML15148A981 

Lambert, John ML15159A348 

Lambert, Leanna ML15154C122 

Lambert, Mark ML15154A533 

Lambert, Rene ML15154B476 

Lambert, Rob ML15140A115 

Lamerton, Cathleen ML15159B349 

Lammers, Jon ML15155B864 

Lamond, Camas ML15160A593 

Lamont, Juliet ML15141A490 

Lampkin, Olga ML15158A038 

Lamson, Gary ML15148A937 

Lanagan, Pamela ML15154A250 

Lancia, Debra ML15153A496 

Lancia, Debra ML15153A496 

Land, David ML15154B813 

Land, Martha ML15154C206 

Landau, Douglas ML15156A044 

Commenter 

ADAMS 

Accession # 

Landau, Larry ML15156A015 

Landeo, Eva ML15155B707 

Landess, Michael ML15142A161 

Landgrebe, Gary ML15155C049 

Landi, Barbara ML15155B159 

Landry, Connie ML15159A314 

Landskron, David ML15156A531 

Lane, N. Jo ML15155B103 

Lane, Patricia ML15156A678 

Lanehart, Rheta ML15148B238 

LaNew, Maryann ML15155A181 

Lang, Lynn C. ML15162A639 

Lange, Charles ML15160A877 

Lange, Eva ML15155A793 

Langelan, M. ML15154C030 

Langenau, Douglas ML15159A075 

Langford, Lora ML15154C251 

Langmacher, Linda ML15161A699 

Langston, Michele ML15159A849 

Lanni, Phil ML15155A234 

Lanus, Howard ML15156A945 

Lanzl, Catherine ML15153B133 

LaPorte, Candace ML15155A882 

Large, Daniel ML15148B401 

Large, Kenneth ML15159A668 

Larkin, Timothy ML15141A560 

Larmee, Kimberly ML15155A693 

Larrabee, Bill ML15160A809 

Larrick, Margaret ML15160A959 

Larrison, Elizabeth ML15155A827 

Larsen, Karen ML15155A481 

Larson, Fran ML15159A813 

Larson, Al ML15156A017 

Larson, Brian ML15140A148 

Larson, Dan ML15142A053 

Larson, Dene ML15142A146 

Larson, Marguerite ML15156B269 

Larson, R. A. ML15153A486 

Larson, Wendy ML15155B170 

Lash, Cal ML15141A768 

Lashinski, Amy ML15141A686 

Laskas, Carol ML15155A059 

Lasley, Barbara ML15141A726 

Lasorsa, Maria ML15156A237 

Lastra, Irene ML15148A891 

Latch, Steve ML15155B792 

Lattanzia, Patricia ML15153B102 

Lau, E. ML15162A386 

Laube, Susan ML15154A141 

Laubert, Jon ML15155B769 

Lauer, Marcy ML15155B180 

Laughlin, Dawn ML15154A048 

Laughon, Char ML15154A291 

Laurent, Thouvenin ML15155C089 

Appendix E NUREG–2176 E-598 October 2016
Commenter 

ADAMS 

Accession # 

Lauritsen, Maryann ML15162A622 

Lauritsen, Nancy ML15159B055 

Lausz, Emilia ML15159A032 

Lavancher, John ML15148A884 

Laves-Mearini, Courtney ML15148B312 

Lavin, Chris ML15159A076 

Lawler, John ML15154A546 

Lawler, Karen ML15154C262 

Lawler, Ruth ML15156A198 

Lawrence, Andrew ML15158A101 

Lawrence, Betty ML15156A481 

Lawrence, David A. ML15141A507 

Lawrence, Geoffrey ML15141A708 

Lawrence, Rhett ML15159A920 

Lawrence, Robert ML15154B870 

Lawrence, Vinnedge ML15154B596 

Lawson, Ken ML15160A577 

Lawyer, Julie ML15141A766 

Laxier, Scott ML15153A583 

Layfield, Elizabeth ML15162A725 

Layman, William ML15154B295 

Lazio, Rochelle ML15154C163 

Leach, Brandi ML15155B745 

Leach, Jason ML15154B807 

Leahy, Susan ML15148B205 

Leake, Barbara ML15155B682 

Leatto, Renne ML15142A126 

Lebaron, Pat ML15162A636 

Lebert, Mary ML15154B978 

LeBlanc, Candy ML15155C114 

Leclair, Peg ML15162A268 

Ledbetter, Carolyn ML15156B255 

Ledden, Dennis ML15156A156 

Ledder, Janet ML15154B625 

Lederman, Jessica ML15159B563 

Lee, Aldora ML15154C051 

Lee, Audrey ML15154A448 

Lee, Barb ML15159A837 

Lee, Brenda ML15153B260 

Lee, Christopher ML15154C130 

Lee, Cynthia ML15156B441 

Lee, David ML15156A866 

Lee, E. R. ML15156A264 

Lee, Jerry ML15154C160 

Lee, Madeleine ML15142A376 

Lee, Richard ML15148A278 

Lee, Robert ML15154B582 

Lee, Virginia ML15154A346 

Leeman, Cavin ML15154B348 

Leeuw, Lyn ML15159A127 

Leff, Michele ML15142A057 

Leffler, Scott ML15154C026 

Lefler, Susan ML15153B192 

Legaroff, Kyra ML15153B044 

Commenter 

ADAMS 

Accession # 

Legault, Robert ML15159A375 

Leggett, Robert ML15160A806 

Lehman, Loretta ML15154C296 

Lehr, Doris ML15156B208 

Leibowitz, Arthuir ML15154B449 

Leidi, Angelo ML15156B070 

Leidig, Charles ML15156A158 

Leighton, Rona ML15148A857 

Leihy, Susan ML15159A864 

Leinbaugh, Tracy ML15156A841 

Leising, Norma ML15153A773 

Leiva, Miranda ML15155A120 

Leland, Lora ML15156B484 

Lemire, Mary ML15155A448 

Lemkuil, Rita ML15142A259 

Lemmie, Charmaine ML15156A038 

Lemoine, Kathryn ML15141A585 

Lenchner, Nicholas ML15153B299 

Lenhart, Beth ML15148A199 

Lennick, Brendalee ML15154A409 

Lensenmayer, Kathleen ML15148B058 

Lensi, Philip ML15159A720 

Lent, Kelli ML15141A626 

Lentini, Tony ML15148A905 

Lenz, Andrew ML15154A104 

Lenz, Carolyn ML15155B098 

Lenzen, Pat ML15156A780 

Lenzen, Pat ML15156A802 

Leo, Carlos ML15154B902 

Leod, Lea Mac ML15158A193 

Leon, Elizabeth ML15160A783 

Leonard, Cami ML15159B368 

Leonard, Esther ML15156A951 

Leonard, Fred ML15156B482 

Leonard, Joan ML15154B774 

Leonardo, Sherry ML15154A213 

LePere, Renee ML15148A952 

Leppo, Bob ML15156A498 

Lepre, Brenda ML15159B238 

Lerner, Pauline ML15155C083 

Lesem, Ken ML15159A315 

Leske, Jim ML15141A720 

Leslie, J. Allen ML15158A043 

Leslie, Jane ML15140A117 

Leslie-Dennis, Donna ML15154C028 

Lester, Lisa ML15153B300 

Leszczynski, M. ML15160A045 

Leto, Bogdana ML15156B187 

Leton, Sharon ML15154B688 

Leton, Sharon ML15154B693 

Letsche, Debbie ML15154A161 

Leva, Dana ML15159B133 

Levant, Mary ML15159A460 

Levecchia, Naomi ML15153A968 

Appendix E October 2016 E-599 NUREG–2176
Commenter 

ADAMS 

Accession # 

Levi, Louis ML15140A103 

Levie, Debra ML15155A493 

Levin, Shaun Marie ML15162B089 

Levin, Shaun Marie ML15162B135 

Levin, Susanna ML15159A117 

Levine, Adam ML15155B998 

Levine, Beth ML15154B317 

Levine, Christy ML15158A177 

Levine, Lynn ML15154C271 

Levine, Rhoda ML15158A013 

Levine, Sandy ML15154A413 

Levine, Susan ML15153A774 

Levinzon, Paulina ML15159A021 

Levy, Robert Brian ML15148B218 

Levy, Stephen ML15160A873 

Lewandoski, Nancy ML15155A122 

Lewandowski, Michael ML15156A907 

Lewis, Andrea ML15156B397 

Lewis, Brenda ML15155B302 

Lewis, Daniel ML15154A436 

Lewis, Deborah ML15155B911 

Lewis, Debra ML15148B321 

Lewis, George ML15141A639 

Lewis, Jan ML15140A175 

Lewis, Joan ML15155A337 

Lewis, Jordan ML15153B028 

Lewis, Kathleen ML15148A233 

Lewis, Larry ML15155A040 

Lewis, Marvin ML15155B835 

Lewis, Melia ML15159A347 

Lewis, Paul ML15156A135 

Lewis, Pravin ML15154A324 

Lewis, Pravin ML15159A792 

Lewis, S. ML15142A211 

Lewis, Shawn ML15155A037 

Lewis, Sherman ML15153A958 

Lewis, Sherry ML15155B351 

Lewis, Verlene ML15155B809 

Leyendecker, Billie ML15154B041 

Lezotte, Eric ML15155A625 

Libansky, Dada ML15156A060 

Libbares, Georgia ML15155A757 

Libby, Dominic ML15154C107 

Libengood, Patricia ML15156B457 

Libson, Aaron ML15155C088 

Lichtenberg, Don ML15153B122 

Lidicker, Naomi ML15154B643 

Liebermann, Jerry ML15159A048 

Liebowitz, Virginia ML15156A096 

Liedike, Robert ML15153B123 

Lieme, Patricia ML15162A543 

Liesche, Ken ML15154A338 

Liesemer, Kirk ML15154A789 

Liess, L. M. ML15148A648 

Commenter 

ADAMS 

Accession # 

Liggio, Eleanor ML15142A150 

Light, Madeline ML15154A461 

Lightbody, Kristen ML15153B237 

Lightfoot, Paul ML15162A591 

Lighthall, Tim ML15155B432 

Likens, Jessica ML15158A222 

Liles, Ben ML15141A761 

Lilienkamp, Bryan ML15140A187 

Lillard, Cecelia ML15153B058 

Lilli, Joseph ML15154A938 

Lillian, Michael ML15141A700 

Lilvingston‐Dunn, Connie ML15154A210 

Lim, Yee Yean ML15162A363 

Limpert, Rosanna ML15158A287 

Linarez, Kj ML15156B094 

Lincoln, Deb ML15156A792 

Lincoln, Deb ML15156B421 

Lincoln, Sarah ML15154B906 

Lind, Gordon ML15148B040 

Linden, Steven ML15158A273 

Linden, Susan ML15154A878 

Linden, Susanne ML15148A860 

Lindenbacher, Dany ML15155B281 

Lindenberger, Stewart ML15154A353 

Lindhard, Peter ML15154A387 

Lindhorst, Gerald ML15154B210 

Lindquist, Erin ML15155B841 

Linell, Tom ML15159A742 

Lines, Nancy ML15155B410 

Linhart, June ML15162A734 

Lininger, Betty ML15155B392 

Linsky, Richard ML15155B540 

Linzmeier, Robert ML15141A512 

Lipari, Philip ML15154A695 

Lipcsey, Todd ML15154B862 

Lipman, Elizabeth ML15155B673 

Lippert, Amy ML15160A882 

Lippert, Tim ML15140A118 

Lippmann, Becky ML15156A734 

Lippold, Earl ML15141A698 

Lipscomb, Emmett ML15153A725 

Lipsky, Carol ML15155B430 

Lira, Stefon ML15154B731 

Lis, Vera ML15159A220 

Lish, Christopher ML15211A047 

Liss, Mary ML15147A772 

Liszak, Jerry ML15155A455 

Liszeo, Barbara ML15153A970 

Litteken, Sister Clare Ann ML15159B302 

Little, Judith ML15148A169 

Little, Robyn ML15155C045 

Liu, Mini ML15155A265 

Lively, Nancy Zeilig ML15154A549 

Livesey‐Fassel, Elaine ML15154A397 

Appendix E NUREG–2176 E-600 October 2016
Commenter 

ADAMS 

Accession # 

Livingston, C. J. ML15154C069 

Livingston, Deborah ML15148A870 

Livingston, Elaine ML15154A392 

Livingston, Michelle ML15154B029 

Lizer, Deja ML15156A875 

Lloyd, B. ML15155A303 

Lloyd, Janet ML15153A711 

Lochner, Kathy ML15154C269 

Locicero, Jessica ML15154C024 

Lockett, Jennifer ML15155B815 

Lockwood, Brian ML15156A218 

Lockwood, Michael ML15153A655 

Lockwood, Ronald ML15148B324 

Loe, Steve ML15156A175 

Loeber, Charles ML15148A837 

Loeblich, Elizabeth ML15156A671 

Loewy, Cynthia ML15155A387 

Loftin, Nancy ML15156A018 

Lofton, Saab ML15159B014 

Lofurno, Susan ML15153B124 

Lohman, James ML15148B096 

Lohr, Krista ML15155A136 

Loizides, Thomas ML15156B324 

Lombardi, R. ML15155B642 

Long, Deborah ML15154B123 

Long, Jared ML15153A986 

Long, Jennie ML15153B240 

Long, Laura ML15159B383 

Long, Leland ML15162B079 

Long, Leland ML15162B129 

Long, Nancy ML15156A845 

Long, Robert ML15148B056 

Loomis, Adam ML15154C052 

Loomis, Gregry ML15153A899 

Loomis, Margaret ML15154C123 

Loomis, Rea Ann ML15156B017 

Loomis, Virpi ML15155A069 

Looney, Ernie ML15140A038 

Looney, Hannah ML15155B978 

Loosli, Edward ML15155A810 

Lopez, Josie ML15162A389 

Lopez, Laura ML15148A700 

Lopez, Maria Sune ML15155A598 

Lopez, Ralph ML15153B257 

Lopez, Randy ML15140A104 

Lopez, Vince ML15162A092 

Lopez‐Hagan, Nicole ML15154A427 

Loquvam, Mary ML15148A727 

Lorber, Deadre ML15159A113 

Lorenz, Gerald ML15153A836 

Lorenz, Philip ML15153A647 

Lorenzo, Anne ML15162B101 

Lorenzo, Anne ML15141A701 

Lorenzo, Anne ML15162B042 

Commenter 

ADAMS 

Accession # 

Lotito, Mark ML15158A020 

Lottes, Ilsa ML15153B065 

Lotz, Elizabeth ML15156A874 

Loughlin, Mary ML15141A724 

Louis, Jamie ML15155B271 

Lovely, Michael ML15155C011 

Lovitch, Derek ML15154B890 

Low, Sammy ML15154C215 

Lowans, Jennifer ML15155B695 

Lowden, Barbara ML15155C063 

Lowe, David ML15155A093 

Lowe, Jacklyn ML15159A518 

Lowe, James ML15148B404 

Lowe, Margot ML15160A816 

Lowe, Rob ML15159B382 

Lowell, Meryl ML15155B774 

Lowenthal, Steven ML15155C096 

Lowery, Candice ML15159A006 

Lowery, Chuck ML15148B078 

Lowery, Joanne ML15154B713 

Lowes, Jane ML15156A689 

Lowney, Kathleen ML15148B124 

Lowther, Joni ML15156A960 

Lowther, Larry ML15156A706 

Luban, Holly ML15148B140 

Lubin, Stephen ML15153A720 

Lubonovich, D. J. ML15154A117 

Luca, Joe ML15161A687 

Lucas, Adeline ML15154B516 

Lucas, Janie ML15154A309 

Luck, Patricia ML15156A460 

Luckett, Rosemary ML15153A779 

Ludington, Byron ML15154B003 

Ludwick, Russ ML15155A594 

Lueck, Donna ML15159B239 

Lukas, James ML15156A136 

Lulias, Eva ML15156A740 

Lunceford, Diana ML15154B432 

Lund, Deva ML15159A761 

Lundgren, Mike ML15159B348 

Lundgren, Roger ML15155A541 

Lundholm, Mark ML15156A896 

Lundin, Anne ML15148A992 

Lundin, Annmari ML15141A622 

Lupenko, Andy ML15160A680 

Lupo, Jack ML15160A537 

Lupori, Stacy ML15159A650 

Lusch, Mark ML15154C131 

Lustgarten, Annette ML15155B239 

Lutes, Stephen ML15159B581 

Lutman, Jeri ML15155A427 

Luttmann, Rick ML15154C185 

Lydy, Theresa ML15154B214 

Lyles, Lori ML15154A426 

Appendix E October 2016 E-601 NUREG–2176
Commenter 

ADAMS 

Accession # 

Lyman, Mike ML15154A724 

Lynch, Athena ML15154A732 

Lynch, Charles ML15154A622 

Lynch, Lisa ML15160A588 

Lynch, Tifni ML15154A447 

Lynch, W. ML15148B069 

Lynn, Andy ML15154B650 

Lynn, Pamela ML15159A448 

Lynn, Sandra ML15154B220 

Lynne, Sandra ML15155A341 

Lyon, Angela ML15155A083 

Lyon, Marsha ML15153B241 

Lyons, Pamela ML15155A768 

Lyons, Tracy ML15142A222 

Lyson, Valerie ML15162A515 

Lytle, Denise ML15162A674 

M., Ann ML15154A662 

M., N. ML15155A914 

Maar, Sandra ML15156B502 

Mac Cormick, Margarida ML15142A128 

Macarthur, Jacquelyn ML15155A597 

Macbride, David ML15153A917 

Macconaugha-Snyder, 

Morgan ML15162B064 

Macconaugha-Snyder, 

Morgan ML15162B109 

Macdonald, Angus M. ML15156A605 

Macdonald, David ML15153A953 

Macdonald, Ethel ML15158A270 

Macdonald, John ML15156A109 

MacDonald, John ML15159A807 

Macdonald, Leo ML15160A738 

MacGregor, Mary ML15154A047 

Mack, Joanne ML15155B058 

Mackelvie, Elizabeth ML15156A206 

Mackenzie, Michelle ML15156A921 

Mackie, Judie ML15155B459 

Mackin, Richard ML15147A712 

Mackison, George ML15156B391 

Mackrell, Chris ML15154B707 

Maclaren, Malcolm ML15154A703 

Macleman, Linda ML15154A400 

Macomber, Jessica ML15156A435 

Macomber, Paul ML15155A060 

Macquarrie, Robert ML15154B326 

Macraith, Bonnie ML15142A031 

Macy, Michelle ML15156B180 

Macy, Rene ML15154A062 

Maddlone, Claire ML15162A100 

Maddox, Eva ML15155A726 

Maddux, Daniel ML15154B874 

Madeco‐Smith, Mary ML15158A275 

Madera, Christina ML15155C178 

Madero, Mario ML15160A074 

Commenter 

ADAMS 

Accession # 

Madole, Richard ML15153B197 

Madoshi, Diana ML15148B219 

Madrid, Jade ML15161A633 

Madruga, Philip ML15148B072 

Madson, Erin ML15159B084 

Maestro, Betsy ML15148A945 

Magalas, Marie Christina ML15155B357 

Magallon, Katie ML15154B305 

Magallon, Katie ML15159A515 

Magana, Maria ML15155B203 

Magann, Gale ML15154A090 

Magdalene, Lilithe ML15153A621 

Magee, Dan ML15153A584 

Maghakian, Michael ML15154B738 

Magill, Bob ML15141A769 

Magliola, Lawrence ML15159B422 

Mahaux, Sylviane ML15154A004 

Maher, Timothy ML15159A110 

Maher, Jane ML15159A853 

Maher, Therese ML15141A434 

Mahnken, Jody ML15160A743 

Mahoney, Mary ML15153A382 

Mahoney, Rita ML15159B506 

Mahoney, Robert S. ML15155A210 

Mahood-Jose, Eileen ML15159A310 

Maida, Cecilia ML15156B400 

Maier, Patricia ML15154B961 

Maijala, Ann ML15159A984 

Maitre, Florian ML15154A322 

Maitre, Florian ML15154A329 

Makowski, Jane ML15154C011 

Malcher, Luiz ML15156A077 

Malcolm, Karen Kravcov ML15156B503 

Maldonado, Emily ML15159B535 

Maldonado, Jackie ML15159A816 

Maleckaite, Vaida ML15155C031 

Malerman, Rina ML15153B067 

Maley, Michael ML15148A931 

Malinauskas, Helen ML15155B114 

Malka, Ben ML15154A721 

Mallatt, Paul ML15148B279 

Malone, Peggy ML15156A131 

Malpass, Betsy ML15154B739 

Malsheimer, Fran ML15148A587 

Malyon, Hilary ML15155B974 

Mamoyac, Joy ML15155B076 

Man, Cave ML15140A000 

Manchester, Austin ML15155A409 

Mancini, Jayme ML15159B419 

Mancuso, Erica ML15159B294 

Mandeville, Helen ML15154A471 

Mangan, Lori ML15158A281 

Mangrum, Deborah ML15155A224 

Mangus, Tracey ML15154A626 

Appendix E NUREG–2176 E-602 October 2016
Commenter 

ADAMS 

Accession # 

Manion, Michaelene ML15140A022 

Manley, Marjorie ML15154B844 

Mann, C. ML15155B930 

Mann, Paul ML15153A494 

Mann, Renee ML15148B049 

Manning, Jennifer ML15156A924 

Manning, Patsey ML15141A643 

Manning, Robert ML15153A848 

Mannsfeld, Bjoern ML15154A816 

Manroe, Beverly ML15156B072 

Manscill, Kitty ML15148A909 

Mansfield, Lynn ML15142A091 

Manter, Larry ML15155A026 

Manyak, Rebecca ML15141A707 

Manzini, Dulce ML15159B329 

Maraldo, Mario ML15155A100 

Marancik, David ML15153B049 

Marbach, Terry ML15159B039 

Marburger, Craig ML15155A707 

March, Mark ML15155C102 

Marchand, Babs ML15154A081 

Marchand, Ginette ML15141A446 

Marchello, Linda ML15159B365 

Marchessault, Michael ML15156A880 

Marckini, David ML15153A942 

Marco, Stephanie ML15159B421 

Marcus, Janice ML15147A730 

Marcus, Martin ML15159A152 

Marcus, Mel ML15142A267 

Marczak, Holly ML15142A311 

Margeson, Don ML15154A067 

Margulies, Lee ML15147A779 

Margulis, Kathleen ML15155B499 

Marivn, Cindy ML15154A333 

Marjoncu, Daniel ML15155A453 

Mark, Bernard ML15148B182 

Markgraf, Steven ML15155B012 

Markham, Gary ML15154B992 

Markham, John ML15154A211 

Markham, John ML15155B838 

Markillie, Paul ML15141A793 

Markowitz, John ML15140A225 

Marks, Luan ML15155B002 

Marks, Richard ML15154A094 

Markson, Craig ML15160A645 

Marlowe, Denise ML15160A079 

Maron-Friend, Judie ML15142A184 

Marotta, Tracy ML15148B364 

Marquis, Luke ML15142A030 

Marr, Betty ML15148A797 

Marrone, Vito ML15141A745 

Marsden, Jim ML15155A121 

Marsh, Dorothy ML15159A596 

Marsh, Susan ML15159A755 

Commenter 

ADAMS 

Accession # 

Marsh, Heather ML15153A505 

Marsh, William ML15154C212 

Marshak, Judy ML15154B883 

Marshall, Ann ML15148B167 

Marshall, Cynthia ML15153A549 

Marshall, Edna ML15153A622 

Marshall, Laurie ML15159A425 

Marshall, LaVern ML15155C121 

Marshall, Lisa ML15159A225 

Marshall, Rich ML15154C201 

Marshall, Sally ML15159A168 

Martens, Bill ML15154A188 

Martin, Barbara ML15154A829 

Martin, Ben ML15162A659 

Martin, Candice ML15156B351 

Martin, Drew ML15154C257 

Martin, Elisabeth ML15142A243 

Martin, Emilie ML15153A789 

Martin, Gerry ML15155B890 

Martin, Gregory ML15154B805 

Martin, Helen ML15155B626 

Martin, Jeanne ML15153B201 

Martin, Julie ML15141A502 

Martin, Linda ML15153A759 

Martin, Marsha ML15155C161 

Martin, Melissa ML15155C046 

Martin, Melodie ML15140A250 

Martin, Patrick ML15156B347 

Martin, Raymomd ML15154A235 

Martin, Sherri ML15160A586 

Martin, Sue ML15141A603 

Martine, Gurinet ML15159A838 

Martinez, Claudia ML15153A915 

Martinez, Janie ML15159B217 

Martinez, Keiko ML15159B290 

Martinez, Lorraine ML15158A242 

Martinez, Michele ML15155A365 

Martinez, Priscilla ML15155B975 

Martini, Carol ML15159A811 

Martini, Denise ML15155C038 

Martinotti, Silvia ML15160A846 

Martinson, Patsy ML15154B973 

Marton, Dennis ML15162A623 

Maryanski, Joseph ML15155A709 

Mascarin, Paula ML15159B303 

Maseduca, Heidi ML15148A594 

Maselli, June ML15154A793 

Masi, Janie ML15155A958 

Maslanek, Michael ML15154A540 

Mason, Elliot ML15155A855 

Mason, Jackie ML15156B508 

Massa, Alison ML15140A235 

Massar, Marc ML15153A728 

Massar, Marc ML15153B242 

Appendix E October 2016 E-603 NUREG–2176
Commenter 

ADAMS 

Accession # 

Masse, Kierstin ML15155B685 

Massey, Carolyn ML15154B701 

Massey, Carolyn ML15155B609 

Massey, Linda ML15154B882 

Massman, John ML15159A010 

Masters, Stanley ML15155A287 

Mastri, Francis ML15155C218 

Masurat, Gerry ML15154A433 

Matheny, Kent ML15158A087 

Matheny, Vicki ML15153B236 

Mather, Elizabeth ML15148B217 

Mather, Natalie ML15148A864 

Matheson, Jen ML15153A348 

Mathews, Holger ML15142A239 

Mathews, L. ML15159A628 

Mathews, Mary ML15159A877 

Mathews, Peter ML15154B917 

Mathews, William ML15153A936 

Mathis, Barbara ML15142A262 

Mathis, Rebecca ML15162A108 

Matlock, Kevin ML15142A229 

Matos, Milagros ML15158A157 

Matso, Margo ML15159A355 

Matson, Leila ML15153A758 

Matsui, Vicky ML15154A818 

Mattes, Dale ML15156B154 

Matteucci, Gina ML15153B149 

Matthews, Larissa ML15159B396 

Matthews, Marilyn ML15154A484 

Matthews, Phillip ML15156A335 

Mattingly, Georgia ML15141A462 

Mattingly, Gloria ML15154A169 

Mattis, Albert ML15155A503 

Mattson, Sandra ML15148B207 

Mattson, Virginia ML15159B545 

Matwichuk, Gail ML15160A752 

Matwiejko, Anton ML15153A945 

Matych, Teresa ML15154B200 

Matyus, Marika ML15154B754 

Maughan, Eloise ML15158A149 

Maurelia, Kristin ML15154B586 

Maurer, Dorothy ML15160A934 

Maurer, Timothy ML15159A866 

Mawhorter, Jerry ML15156A122 

Maxwell, Steven ML15159A413 

May, Hildy ML15160A694 

May, Jim ML15148B003 

May, Julie ML15153B230 

May, Sarah ML15156A534 

Mayer, Karen ML15155A110 

Mayer, Chanelle ML15159B117 

Maynard, Linda ML15153B233 

Mazhnyy, Mark ML15148A748 

Mazuca, Frank ML15148B253 

Commenter 

ADAMS 

Accession # 

Mazuji, Nasrin ML15153B134 

Mazza, Penelope ML15159A671 

Mazzola, Lisa ML15156A227 

Mazzotta, Gaetano ML15154B023 

Mazzuca, Dale ML15142A319 

Mazzuca, Rich ML15153A798 

Mc Allister, Jean ML15155B624 

Mc Dermott, Ethna ML15156A125 

Mc Intyre, Nancy ML15154A123 

Mc Neill, Norma ML15156B517 

Mcafee, Al ML15159B333 

Mcalister, Suzann ML15155B858 

Mcarrell, Bianca ML15159B533 

McBride, Timothy ML15153A355 

Mccabe, Elaine ML15147A725 

Mccabe, Kathleen ML15154B040 

Mccalister, Janet ML15154B136 

Mccall, Ann ML15159A083 

Mccall, Charles ML15153B271 

Mccall, Donovan ML15153A565 

Mccall, Kaye ML15154B058 

Mccann, Donald ML15158A156 

Mccann, Peter ML15156A055 

Mccard, Jennifer ML15154B796 

Mccarren, Stephanie ML15158A055 

Mccart, Dale ML15148B246 

Mccarthy, Carolyn ML15155A467 

Mccarthy, Debbie ML15159B225 

Mccarthy, Maureen ML15153B148 

Mccartin, Mike ML15154C103 

McCarty, Chris ML15159A873 

Mccauley, Brandi ML15155B115 

Mccauley, Dianne ML15155C170 

Mcclain, Jerry ML15156A005 

Mccleary, Harriet C. ML15160A811 

McClendon, Linda ML15155A850 

Mcclendon, Michelle ML15154B934 

Mccloskey, Michelle ML15156A244 

Mccloskey, William ML15158A203 

Mcclung, Judy ML15148B392 

Mcclure, Kate ML15155B069 

Mcclure, Kim ML15159B292 

McClure, Sandy ML15154A036 

Mcclurg, Daviann ML15153B111 

McCollim, Jeffrey ML15159A525 

McComb, Sandy ML15155B233 

Mccomb, Tf ML15159A712 

Mccombs, Robert ML15162A297 

Mcconnaughey, Sarah ML15160A080 

Mccormack, Elizabeth ML15155A394 

Mccormick, David ML15148B283 

Mccormick, Douglas ML15155A471 

Mccorry, Eileen ML15148B353 

Mccoubrie, Elise ML15160A721 

Appendix E NUREG–2176 E-604 October 2016
Commenter 

ADAMS 

Accession # 

Mccoy, Bill ML15162A075 

Mccoy, Catherine ML15154B314 

Mccrate, Mary Rose ML15155C225 

McCray, Toni ML15162A663 

Mccreadie, Jane ML15156A957 

Mccready, Tamara ML15148A936 

Mccreary, Jan ML15154A144 

Mccredie, Gail ML15153A553 

Mccroskey, Carol ML15154A835 

Mcculloch, Samuel ML15162A111 

Mccullough, Justin ML15159A543 

McCullough, Justin ML15160A785 

Mccullough, Maureen ML15154A779 

Mccumber, Peter ML15156B238 

Mccurdy, Dassi ML15154C000 

Mccurdy, Prescott ML15154A026 

McDaniel, Diana ML15159B554 

Mcdermott, Jeff ML15155B983 

Mcdonald, A. ML15156A568 

Mcdonald, Joyce ML15140A286 

McDonald, Norma ML15155C134 

Mcdonald, Patricia ML15148A618 

Mcdonell, Alexander ML15154A417 

Mcdonnell, Hope ML15142A175 

Mcdonnell, Jameson ML15156B217 

Mcdonough, Brenda ML15154A079 

Mcdonough, Kimberly ML15142A232 

McEachron-Taylor, Linda ML15153B050 

McElhaney, Thomas ML15159B334 

Mcelhone, Mary ML15159B339 

McElwain, Judith ML15154B585 

McFadden, Arlene ML15156A086 

Mcfarland, Brian ML15154C110 

Mcfarland, Jackie ML15159A153 

McFarland, John ML15162A585 

Mcgaha, Patricia ML15158A167 

McGarvie-Munn, Iain ML15159A294 

Mcgil, Kent ML15148A604 

McGill, Ann C. ML15155B003 

McGill, Linda R. ML15154A395 

Mcgilvery, Eva ML15155B977 

Mcginnis, Dan ML15148B199 

Mcglashan, Maria ML15161A636 

Mcglone, Colleen ML15148A669 

Mcgoldrick, Carole ML15154B996 

Mcgough, Alice ML15155B811 

Mcgowan, Richard ML15154B324 

Mcgrath, Barbara ML15159A701 

Mcgrath, Mark ML15153A841 

Mcgratty, Chris ML15160A053 

Mcguire, Jessica ML15156A149 

Mcguire, Matthew ML15162A731 

Mchugh, Margaret C. ML15155A179 

Mcintyre, Misty ML15140A169 

Commenter 

ADAMS 

Accession # 

Mckee, Eileen ML15148B043 

Mckee, Sarah ML15154A386 

Mckeever, Mary ML15153A994 

Mckelvey, Gerald ML15148A722 

Mckelvie, Kevin ML15154A388 

Mckelvie, Patricia ML15148A929 

Mckenna, Colleen ML15156A250 

Mckenney, Christopher ML15140A116 

Mckenzie, Ernie ML15156A167 

Mckinley, Patti ML15154B067 

Mckinnie, Robert ML15142A325 

Mckinnon, Moira ML15141A526 

Mckye, Christina ML15154A423 

Mclaughlin, Bruce ML15148A778 

Mclaughlin, Joe ML15153A948 

Mclaughlin, Timothy ML15154A450 

Mclaurin, Phillip ML15162A558 

Mcleod, Daniel ML15156B500 

M'Closkey, Karen ML15140A010 

Mcmahan, Alexa ML15159A418 

Mcmahan, Barbara ML15153B294 

Mcmahan, Michael ML15159A669 

Mcmahon, Nicholas ML15156A273 

Mcmillan, Reba ML15156A012 

Mcmullen, Colleen ML15159B556 

Mcmurray, Kendel ML15160A948 

Mcmurray, Phillip ML15154A817 

Mcnamara, Catherine ML15141A693 

Mcnaught, Anna ML15154A483 

Mcneil, Kerry ML15154A994 

Mcneil, Sherry ML15156A306 

Mcneill, Katherine ML15154A092 

Mcnitt, Doris ML15154A827 

Mcpherson, Tracy ML15154B977 

Mcqueen, Neil ML15159A876 

McQuown, Michael ML15155C001 

Mcrill, Susan ML15153B275 

Mcvey, Earl ML15154A074 

Mcvey, Harry ML15158A007 

Mcvey, Kelly ML15155B921 

McVicker, Micah ML15159A875 

Mcwhirter, Carol ML15156B408 

Mead, Kathleen ML15153A335 

Mead, Melody ML15159A336 

Means, Jessica ML15147A735 

Meaux, Andre ML15160A907 

Mechanick, Jarred ML15160A643 

Mecke, Ernst ML15154A441 

Medeiros, Linda ML15155B037 

Medina, Daniel ML15154A945 

Medina, Kathleen ML15159B479 

Medlin, Barry ML15156A952 

Medlin, Nellie ML15156A900 

Medlin, Tony ML15156B465 

Appendix E October 2016 E-605 NUREG–2176
Commenter 

ADAMS 

Accession # 

Medlock, Linda ML15159B006 

Meehan, Carol and Barry ML15155B277 

Meek, Roxanne ML15148B115 

Meeks, Donnie ML15154C137 

Meier, D. ML15156B118 

Meier, Ron ML15156B344 

Meigs, Karen ML15155C119 

Mejia, Esperanza ML15162A590 

Mejia, Marianna ML15153A462 

Mejides, Andres ML15155A489 

Melby, George M. ML15154B109 

Meldahl, Deborah ML15153A443 

Mele, Frank ML15159B289 

Melius, Bruce ML15158A265 

Mellen, Linda ML15155A231 

Mello, Dawn ML15142A136 

Meltzer, Iris ML15160A084 

Menard, Rose Marie ML15158A150 

Menasian, Helen ML15155A311 

Mendel, Chris ML15154A534 

Mendelsohn, Alex ML15158A082 

Mendelson, Robert ML15140A206 

Mendez, Tatiana ML15148A174 

Mendez, Virginia ML15148A761 

Mendez‐Alvarez, Javier ML15154A554 

Mendousa, Anthony ML15155A042 

Mendoza, Redelisa ML15160A969 

Mennel‐Bell, Mari ML15153B085 

Mensforth, Elizabeth ML15156A733 

Mensing, Max ML15154B913 

Menyuk, Paula ML15154A070 

Mercer, Michele ML15162A208 

Mercer, Rory ML15160A712 

Mercure, Joan ML15156A067 

Merino, Aimee ML15159A105 

Merino, Margaret ML15155B876 

Merkel, Jane ML15142A361 

Merkel, Karynn ML15148A834 

Merl, Steve ML15153A544 

Merle, Lynn ML15153A883 

Merljak, Julija ML15159A241 

Merritt, Courtney ML15154B083 

Merritt, Jean ML15156A995 

Merz, Robert ML15156A560 

Meslar, Gerald ML15155B758 

Mesler, Corey ML15155C232 

Messling, Gordon ML15142A174 

Metas, Nicole ML15159A381 

Metcalf, A. ML15160A634 

Methven, Bernadette ML15154A709 

Metje, Melodie ML15153B020 

Mettler, Joan ML15162B079 

Mettler, Joan ML15162B130 

Metz, Nancy ML15153B141 

Commenter 

ADAMS 

Accession # 

Metzger, Harvey ML15155A082 

Meyer, Christina ML15156A725 

Meyer, Emily ML15155B000 

Meyer, Eric ML15140A183 

Meyer, Harold ML15155A077 

Meyer, Joan ML15159B205 

Meyer, Joe ML15155A913 

Meyer, Marita ML15155A239 

Meyer, Scott ML15156B501 

Meyer, Stephan ML15155A739 

Meyer, Tanya ML15153B207 

Meyer, Twyla ML15148A899 

Meyers, Sarah ML15147A713 

Meyers, Sue ML15159A695 

Meza, Joel ML15155A583 

Mican, Frances ML15162A142 

Michael, Joe ML15155B754 

Michael, Mary ML15155A016 

Michael-Dahlmann, Tina ML15159A118 

Michaels, Traven ML15162A080 

Michaud, Noreen ML15153A893 

Michener, Jr., Robert ML15153B110 

Middleditch, Ellen ML15156A885 

Midkiff, Michael ML15140A161 

Mietzner, Natalie ML15156B203 

Migliore, Eleanor ML15142A138 

Mikan, Edward ML15148B348 

Miksys, Matt ML15160A859 

Mikulin, Kathleen ML15142A204 

Milam, Tim ML15159A099 

Milano, Barbara ML15142A192 

Milanowski, Tanya ML15153B290 

Miles, Joseph ML15154A025 

Milford, Joan ML15159A692 

Milhaupt, Shannon ML15153A404 

Milione, Regina ML15155A340 

Milkowski, George ML15142A377 

Millensifer, Aimee ML15156A228 

Miller, Alexis Wray Negele ML15148B438 

Miller, Betty ML15156A752 

Miller, Bob ML15148A228 

Miller, Bobbi ML15155B662 

Miller, Brad ML15158A023 

Miller, Carole ML15159A138 

Miller, Charles ML15155B925 

Miller, D. Rex ML15142A062 

Miller, Danielle ML15148B352 

Miller, Dennis ML15154B553 

Miller, Diana ML15148A842 

Miller, Diana ML15155B700 

Miller, Donna ML15142A258 

Miller, Genevieve ML15158A132 

Miller, J. ML15154B846 

Miller, Janet ML15154B097 

Appendix E NUREG–2176 E-606 October 2016
Commenter 

ADAMS 

Accession # 

Miller, Jennifer ML15160A545 

Miller, Jerry ML15148A192 

Miller, Joan ML15155A111 

Miller, K. N. ML15156A106 

Miller, Karen ML15155A070 

Miller, Kenneth ML15155C009 

Miller, Lesley ML15160A980 

Miller, Lester ML15154A260 

Miller, Libba ML15155A301 

Miller, Madge ML15155A105 

Miller, Mary ML15148B027 

Miller, Nancy ML15148B274 

Miller, Nena ML15156A282 

Miller, Patricia ML15156B029 

Miller, Robert ML15153A940 

Miller, Robert R. ML15156B037 

Miller, Sandi ML15156A676 

Miller, Sara ML15155B352 

Miller, Tia ML15159A298 

Miller, Timothy ML15153A824 

Miller, Tracey ML15154B920 

Miller, Valerie ML15159A040 

Miller, Victoria ML15148B383 

Miller, William ML15154A579 

Millhoff, Faythe ML15155A826 

Milligan, Keith ML15156A939 

Milligan, Rosanne ML15148A927 

Milliken, Elizabeth ML15154B621 

Millman, Mia ML15153A648 

Mills, Krista ML15155A714 

Mills, Marianne ML15156A263 

Milonas, Nikolaos ML15148B228 

Milkowski, George ML15142A377 

Milster, Amanda ML15158A090 

Mims, Pat ML15156A973 

Minacheili, Susanna ML15160A578 

Mindar, Richard ML15154B927 

Mineck, Stephen ML15153B246 

Miner, Dan ML15155B078 

Miner, Rev Curt ML15154B673 

Minglis, Erica ML15155A335 

Minich, Chris ML15154C290 

Minicucci, Dianne ML15154A163 

Minor, Shannon ML15153A839 

Minto, Arthur ML15153A903 

Mintz, Phillip ML15154C295 

Mirabella, Judith ML15155C183 

Misero, Jamie ML15159B322 

Misero, Jamie ML15159B326 

Misra, Praveen ML15148A210 

Mistretta, Jill ML15154A375 

Misurelli, Jude ML15162A679 

Mitchell, Crystal ML15156B021 

Mitchell, Elizabeth ML15155A440 

Commenter 

ADAMS 

Accession # 

Mitchell, Katherine ML15155A699 

Mitchell, Kenneth ML15141A774 

Mitchell, Laura ML15155A065 

Mitchell, Melissa S. ML15161A666 

Mitchell, Ogden ML15155B229 

Mitchell, Robin ML15154B919 

Mitchell, Ruby ML15148B156 

Mitsuda, Michael ML15162A071 

Mitsuka, Joan ML15141A649 

Mittig, William ML15155A724 

Mitts, Karen ML15159B577 

Mitts, Yolanda ML15156A241 

Mixon, Phillip ML15161A692 

Mizell, Michael ML15154A194 

Mizhir, Tina ML15160A714 

Mock, Tim ML15155C113 

Moczarney, Cindy ML15141A534 

Moder, Timothy ML15148A234 

Moderacki, Deidre ML15154B038 

Moe, Helen ML15156A805 

Moenk, Jeanne ML15148A702 

Moglowsky, Myra ML15155B623 

Mohanty, Lopamudra ML15154B320 

Moignard, Andrew ML15154B722 

Moland, Janice ML15156A784 

Molder, Michael ML15155A351 

Moldoveanu, Carol ML15160A563 

Molessa, Leslie ML15155A767 

Molgora, Bianca ML15148B268 

Molina, Julimar Castro ML15156A575 

Molinero, Cynthia ML15148B023 

Moller, Richard ML15153A413 

Möllersten, Björn ML15158A142 

Mollo, Elizabeth ML15158A196 

Monaco, Carol ML15142A077 

Monaghan, Dina ML15142A251 

Moncure, Janet ML15155B938 

Mondazze, Gina ML15155B870 

Mondo, John ML15154B675 

Monfort, Brooke ML15154A183 

Monroe, Donna ML15160A794 

Monroe, Jim ML15141A795 

Monson, Christie ML15148B360 

Monson, Todd ML15155B728 

Monte, Bonnie J. ML15158A080 

Montero, Deborah ML15159B474 

Mont-Eton, Elaine ML15156A305 

Montford, Lawrence ML15156B480 

Montgomery, Elizabeth ML15154A255 

Montgomery, John ML15154B239 

Montgomery, Nancy ML15154B721 

Montgomery, Richard ML15155A045 

Montoro, Ernest ML15155A141 

Montreuil, Laura ML15154B119 

Appendix E October 2016 E-607 NUREG–2176
Commenter 

ADAMS 

Accession # 

Montti, Rina ML15154B379 

Moody, Janeane ML15148B266 

Moody, Peggy ML15156B513 

Moody, Richard ML15148A241 

Moody, Stan ML15154A065 

Mooha, Megan ML15155A695 

Mooney, Marianne ML15156A087 

Mooney, Sean ML15142A344 

Moore, Barbara ML15154B440 

Moore, Carol ML15159A899 

Moore, Charlotte ML15155A536 

Moore, Claudia ML15154C149 

Moore, Deb ML15158A276 

Moore, Hugh ML15153A516 

Moore, Judy ML15142A234 

Moore, Kerry ML15155C040 

Moore, Linda ML15159B529 

Moore, Lorraine ML15154B113 

Moore, Nancy ML15148B430 

Moore, Pauline ML15148B057 

Moore, Richard ML15156A152 

Moore, Robert ML15158A211 

Moore, Tammy ML15156A058 

Moore, Thomas ML15140A228 

Moore, Thomas ML15154C274 

Moore, Toni ML15140A253 

Moore, Trois ML15159A605 

Moore, Valerie ML15140A252 

Mora, Lauren ML15153A353 

Mora, Sharon ML15159A305 

Morales, Margaret ML15155A947 

Morales, Marisa ML15159A758 

Moran, Judy ML15153B195 

Moreira, J. ML15162A085 

Moreira, Rui ML15142A173 

Morel, Will ML15148A229 

Moreland, Tom ML15159B526 

Morell, Dario ML15153A561 

Morello, Phyl ML15160A690 

Moreno-Davis, Phaedra ML15159B212 

Morey, Kathy ML15154A843 

Morgan, Alexa Joy ML15159A802 

Morgan, Carol ML15155C150 

Morgan, Claire ML15155A405 

Morgan, Courtney ML15142A112 

Morgan, James ML15159A812 

Morgan, Joanna ML15154A402 

Morgan, Karen ML15141A687 

Morgan, Kathleen ML15154B539 

Morgan, Kitty ML15142A348 

Morgan, Linda ML15154A205 

Morgan, Paula ML15159A209 

Morgan-Kinsell, Judy ML15153A782 

Moriarty, Theodora ML15159A095 

Commenter 

ADAMS 

Accession # 

Moricca, Joan ML15154B829 

Morin, Carla ML15155B337 

Morley, Barbara ML15141A776 

Morley, Julaine ML15153A405 

Morris, Claire ML15159B542 

Morris, Florence ML15155A534 

Morris, Kathleen ML15159B555 

Morris, Lynn ML15148B166 

Morris, Penny ML15155A207 

Morris, Rebecca ML15153A918 

Morris, Roland ML15154B853 

Morris, Steven ML15154C245 

Morrison, Larry ML15155A214 

Morrison, N. ML15155B052. 

Morrison, Scott ML15153A361 

Morrissey, Christine ML15148A138 

Morrissey, Stephen ML15159B527 

Morrone, Marina ML15154C174 

Morrow, Lynn ML15154C127 

Morrow, Myrna ML15153A689 

Morsberger, Grace ML15158A079 

Morsey, Paul ML15142A294 

Mortensen, Leni ML15159A618 

Mortensen, Susanne ML15153B140 

Mortimer, Claire ML15156B470 

Morton, Robert ML15155A375 

Mosca-Clark, Vivianne ML15154C278 

Moscoso, Mary Ann ML15156B133 

Mosley, Michelle ML15155C128 

Mostov, Elizabeth ML15154B717 

Mothershead, Eileen ML15155B771 

Mott, Evelyn ML15159A506 

Motter, H. ML15153B166 

Mottl, Robb ML15147A767 

Motz, Mary ML15153A857 

Moukas, Patty ML15148B044 

Moulton, Rodney ML15155B944 

Mount, Cheryl ML15153B052 

Mourant, Wanda ML15154A345 

Mouzourakis, Kathy ML15142A296 

Mouzourakis, Nicholas ML15160A913 

Mowbray, Robert ML15153B019 

Mower, Amy ML15162A618 

Mowry, Vickie ML15155A473 

Moy, Carolyn ML15159A295 

Moyer, Ken ML15160A942 

Mramor, Andrew ML15158A294 

Mueller, Johanna ML15155B245 

Mueller, Marilyn ML15156A709 

Mueser, Karen ML15156A985 

Mugglestone, Lindsay ML15153A983 

Mulas, Enzo ML15159B514 

Mulcahy, Susan ML15156A963 

Mulder, James ML15155B425 

Appendix E NUREG–2176 E-608 October 2016
Commenter 

ADAMS 

Accession # 

Mulder, Mark ML15153B011 

Mullan, Kate ML15148A659 

Mullane, Marilyn ML15156A637 

Mullen, Charles ML15160A720 

Mullen, Timothy ML15154C239 

Muller, Deborah ML15159A045 

Mulligan, Margaret ML15159B462 

Mulligan, Margi ML15160A710 

Mullins, James ML15154B017 

Mullins, Lynette ML15154A262 

Mulloy, Crleen ML15159A126 

Mulshine, Peter ML15154C002 

Mulshine, Peter ML15155A253 

Mulvey, Lori ML15153A342 

Mumford, Andrew ML15155A313 

Mumma, Harlan ML15155A492 

Munar, Dwayne ML15154C207 

Munday, Sherrie ML15153A909 

Mundhenk, Norm ML15153B015 

Mundy, James ML15156A911 

Mundy, Jaye Anna ML15159A003 

Munger, Anthony ML15155B889 

Munn, J. ML15148A245 

Munoz, Alejandro ML15154A271 

Munoz, Alma ML15158A219 

Munoz, Angela ML15147A734 

Munro, Karen ML15141A580 

Munroe, Gary ML15154A926 

Munroe, Mj ML15154A126 

Murdock, Lauren ML15155A203 

Murin, Assiren ML15156B516 

Murnane, Susan ML15148A898 

Murphy, Amanda ML15159A465 

Murphy, Brian ML15155A859 

Murphy, Donald ML15159A820 

Murphy, Eileen ML15154B763 

Murphy, Garrett ML15155A683 

Murphy, Jane ML15141A489 

Murphy, Janelle ML15156B491 

Murphy, Joe ML15154B769 

Murphy, Michael ML15154A370 

Murphy, Tim ML15154A131 

Murray, Edward ML15155A435 

Murray, James ML15155A890 

Murray, Mark ML15148B011 

Murray, Sandra ML15153A558 

Murray, Sandra ML15154A107 

Muse, Dyan ML15155B057 

Musgrove, Tracy ML15154C098 

Musialowski, Monique ML15156A164 

Music, Barbra ML15142A314 

Mutchler, Ruth ML15154A351 

Muther, Wilhelmina ML15154A776 

Myers, B. J. ML15156B026 

Commenter 

ADAMS 

Accession # 

Myers, David ML15141A692 

Myers, Glenn ML15156B487 

Myers, Kristy ML15160A944 

Myers, Linda ML15154B146 

Myers, Rob ML15158A178 

Myers, Sonya ML15155B862 

Mylott, Sharon ML15159B353 

N., J. ML15154C092 

Nachtsheijm, Henry ML15154C077 

Nagel, Dennis ML15154C210 

Nagel, Karen ML15148B250 

Nagy, Diana ML15160A879 

Nagy, Mary Jo ML15158A249 

Nagyfy, Desi ML15155C120 

Nahay, Paul ML15156A922 

Nahill, Brad ML15160A807 

Naidich, Sandra ML15154B924 

Nakos, Judith ML15155C149 

Nall, James ML15159A304 

Napoleon, Alexandra ML15155A376 

Nappe, Judith ML15155B785 

Nardell, Jason ML15155A331 

Nardella, Nancy ML15153A454 

Narva, Adele ML15148A997 

Nash, Charlene ML15155C230 

Nasuti, Paul ML15155C135 

Nathan, Janice ML15158A189 

Nathan, Jessica ML15162A083 

Nau, Eric ML15155C027 

Naue, Judi ML15156A933 

Naujokas, Deborah ML15154A934 

Navarro, Eleanor ML15153B043 

Naversen, Ronald ML15154B672 

Navidad, Susan ML15159B243 

Naylor, Alan ML15161A694 

Naylor, Brent ML15142A129 

Naylor, John ML15155B993 

Nazzaro, Patricia ML15154A717 

Nearing, Sue ML15156A541 

Necas, Al ML15160A818 

Nedeau, E. James ML15155C033 

Needham, Christina ML15148B257 

Neff, Miriam ML15159B003 

Neff, Victoria ML15155C228 

Negri, Angela ML15142A182 

Neiberger, David ML15162A617 

Neihart, Janet ML15156A329 

Neihart, Joanne ML15159B478 

Neil, Carol ML15156A184 

Neiman, E. ML15159A629 

Neimark, D. ML15142A018 

Neis, Derek ML15162A651 

Nelmes, Beverly ML15159A631 

Nelson, Brenda ML15160A904 

Appendix E October 2016 E-609 NUREG–2176
Commenter 

ADAMS 

Accession # 

Nelson, Carol ML15159A794 

Nelson, Cyndi ML15154A100 

Nelson, David ML15156B292 

Nelson, David ML15156A520 

Nelson, Donna ML15159B287 

Nelson, Helen ML15148B346 

Nelson, J. ML15154B726 

Nelson, Jonathan ML15154B780 

Nelson, Joseph ML15155A422 

Nelson, Joy ML15155B250 

Nelson, Kristine ML15156B253 

Nelson, L. B. ML15141A778 

Nelson, M. Janet ML15158A162 

Nelson, Marianne ML15156A597 

Nelson, Nanci ML15160A697 

Nelson, Paul ML15153A888 

Nelson, Wendy ML15154A040 

Nemeth, Stevin ML15155A013 

Neral, David ML15155C076 

Nerwick, Randall ML15153A920 

Nesline, Rebecca ML15156A439 

Nesmith, Robert ML15153A771 

Neste, George ML15162B044 

Neste, George ML15162B098 

Nettesheim, Catherine ML15154B871 

Netusil, Paul ML15154B502 

Neubert, Lisa ML15154B849 

Neuenschwander, Betty ML15141A429 

Neuhauser, Alice ML15142A036 

Neuman, Margaret ML15148A600 

Neumann, Nancy ML15159A351 

Neumeister, John ML15154B346 

Neus, Marleen ML15162A652 

Neville, Janice ML15155A475 

Neville, Paula ML15156A701 

Nevins, Laura ML15156A948 

Newbeck, Phyl ML15153A529 

Newbegin, Gisela ML15156A097 

Newberg, Rosalie ML15159A484 

Newell, Barrie ML15148A226 

Newfield, Madeleine ML15155B763 

Newman, Anita ML15147A761 

Newman, Donna ML15141A737 

Newman, Kathy ML15154A445 

Newman, Ricki ML15155B092 

Newman, Ricki ML15155B597 

Newman, Suzanne ML15159B536 

Newton, Ann ML15154B709 

Newton, Carol ML15153A703 

Newton, Elizabeth ML15148B018 

Newton, Scurry Judy ML15140A273 

Ng, Carol ML15160A837 

Nghe, Keefe ML15154B818 

Nguyen, Tu-Quyen ML15159B285 

Commenter 

ADAMS 

Accession # 

Niatum, Duane ML15155A344 

Niccolini, Dianora ML15155B387 

Nichols, Anna ML15154B817 

Nichols, Bill ML15159A759 

Nichols, Carmen ML15148A756 

Nichols, Carmen ML15148A759 

Nichols, David S. ML15153A591 

Nichols, Laurie ML15154A257 

Nichols, Nick ML15153A895 

Nicholson, Kaitlyn ML15159A916 

Nicholson, Lisa ML15140A128 

Nickerson, Albert ML15154A439 

Nickerson, Nancy ML15155B708 

Nicodemus, Sharon ML15148A882 

Nicol, Tiffany ML15153B099 

Nicolini, Elizabeth ML15155A997 

Nicoud, John ML15155C086 

Nielsen, Don-Martin ML15154B140 

Nielsen, Ruth ML15154A767 

Nielson, Greg ML15154B315 

Nienaber, Rachel ML15156A238 

Nieters, Lenore ML15154B212 

Nietzold, William ML15155A819 

Nieves, Maria ML15155B636 

Nieves, Robert ML15154A429 

Night, Melody ML15153A780 

Niksic, Joyce ML15142A120 

Nilsen, Jeffrey ML15159B002 

Nix, Debra ML15148A244 

Nix, John ML15142A019 

Nix, John ML15148A209 

Nix, Kathy ML15159B468 

Noack, Michael ML15162A398 

Nobile, Stefania ML15153B127 

Noble, Katherine ML15156A253 

Noble, Vida ML15155B678 

Noble, W. F. ML15155B044 

Nobrega, Robert ML15159B460 

Noellert, Sunnie ML15148B260 

Noga, Kathie ML15142A170 

Nohava, Charles ML15148A589 

Nohava, Charles ML15153A322 

Nolan, Dennis ML15162A727 

Nolan, Nancy ML15153A670 

Nolan, Stephen ML15140A142 

Nolan, Timothy ML15154B889 

Nolan, Tracy ML15162A059 

Noll, Frederick ML15154A769 

Noordyk, James ML15142A029 

Nord, Randall ML15148A984 

Norden, Michael ML15156A272 

Nordenskiold, Mette ML15154A063 

Nordhof, Pamela ML15148A859 

Norkus, Edward ML15156A262 

Appendix E NUREG–2176 E-610 October 2016
Commenter 

ADAMS 

Accession # 

Norman, Jane ML15154C009 

Norris, Brenda ML15141A703 

Norris, James ML15142A106 

Norton, Jennifer ML15162A611 

Norton, Kathey ML15159A686 

Novack, Aaron ML15148A919 

Novak, Paul ML15153A852 

Novak, Trina ML15154A922 

Novkov, Russell ML15155B166 

Novkov, Russell ML15155B456 

Novotne, Holly ML15155A374 

Novstrup, Ginger ML15155C047 

Nowack, James ML15148A595 

Nowak, Diane ML15154A228 

Nowak, Joseph ML15162A596 

Nowicki, Ann ML15148A249 

Nowicki, Judith ML15159A649 

Noyes, Carol ML15153A964 

Nuesch, Raymond ML15142A282 

Nuesch, Raymond ML15148B138 

Nulty, Tom ML15141A655 

Nunez, Carlos ML15155A703 

Nutini, Michael ML15155A073 

Nutter, Mary ML15162A691 

Nye, Janet ML15160A887 

Nylen, E. ML15154A143 

Oba, Peggy Seo ML15155A194 

O'Bara, Carina ML15153A872 

Obeid, Robert ML15154A770 

Oberdorf, Robert ML15155A423 

Oberline, Beverly ML15155A811 

Obershaw, Lynda ML15155C130 

Obert, Leonard ML15154C288 

Obr, Brooks ML15140A029 

O'Brien, Beth ML15153A661 

Obrien, Cecille ML15154A073 

O'Brien, Dennis ML15153A719 

O'Brien, Kathy ML15154B766 

Obrien, Lauren ML15160A836 

O'Brien, Sara ML15154C136 

Ocean, Chris ML15155C115 

Och, Evelyn ML15158A146 

Ochoa, Chemen ML15153B035 

Ockenden, Lynn ML15153B025 

Oconnell, Kate ML15155C182 

O'Connell, Kathleen ML15155A585 

O'Connell, Michael ML15159A887 

O'Connor, John ML15148B331 

Ocskai, Barbara ML15154A030 

Oda, Christine ML15155B701 

Odear, Elizabeth ML15156A142 

O'Donahoo, Roger & 

Gayle ML15156A031 

O'Donnell, Dawn ML15156A148 

Commenter 

ADAMS 

Accession # 

O'Donnell, Deanne ML15159A330 

Oerke, Jr., Carl ML15154B236 

Oetter, Rae ML15159B107 

Ogella, Edith ML15156A831 

Ogle, Emily ML15159B569 

O'Grady, Darlene ML15154C018 

Ogren, Linda ML15140A210 

O'Hara, Kathy ML15148B341 

O'Hara, Kathy ML15154A517 

Ohlanda, Andreas ML15148B037 

Ohlendorf, Carol ML15153A420 

Ohlson, Ken ML15142A085 

Ohlsson, Aase ML15155C105 

O'Keefe, Tammie ML15142A206 

O'Kelley, Celia ML15159B022 

Okulewicz, Katherine ML15142A108 

O'Laughlin, Kay ML15158A258 

Oldani, Julie ML15162A621 

Oldfather, Jeremiah ML15156B483 

O'Leary, Daniel ML15140A027 

O'Leary-Chen, Jennifer ML15148A973 

Olenjack, Michael ML15154A438 

Olivares, Yvonne ML15158A147 

Oliver, Nancy ML15140A008 

Oliver, Niles ML15155A218 

Oliver, Niles ML15155A347 

Oliver, Niles ML15155B553 

Olmstead, Michaelan ML15156A869 

Olmsted, Charles ML15148B295 

Olsen, Charles ML15155B829 

Olsen, Kathy ML15159A545 

Olson, Beth ML15156A495 

Olson, Bruce ML15154A321 

Olson, Diane ML15154B971 

Olson, Francis ML15154A544 

Olson, Jane ML15159A868 

Olson, Linda ML15155A034 

Olson, Mary ML15156B383 

Olson, Steve ML15156B486 

Oman, Barbara ML15159A797 

O'Nan, Kathleen ML15153A389 

O'Neal, Nancy ML15156A104 

Oneil, Julie ML15148A230 

O'Neill, Cynthia ML15159A429 

Oneill, Den ML15156B462 

O'Neill, Frances ML15155C246 

Onesti, Frances ML15155A356 

Onorato, Stephanie ML15155A725 

Onufer, Mary ML15153A984 

Oothoudt, Sylvia ML15153B012 

Oppenheim, Benjamin ML15154B466 

Oppenhuizen, Kathy ML15155B671 

O'Rafferty, Eric ML15155A262 

Orcholski, Gerald ML15153A860 

Appendix E October 2016 E-611 NUREG–2176
Commenter 

ADAMS 

Accession # 

Orem, Jennifer ML15155A217 

Orfanos, Marc ML15154B840 

Orlich, Mary ML15155B666 

Orlinski, Patricia ML15154A216 

Orlowski, Eva ML15162A499 

Orndorff, Robert ML15154B605 

Ornee, Mary ML15148B045 

Ornelas, Karen ML15148B001 

Orons, Nancy ML15154B884 

O'Rourke, Dawn ML15148B302 

O'Rourke, Jake ML15154A398 

Orozco, Angela ML15160A550 

Orr, Barbara ML15154A648 

Orsetti, Rosa ML15162A688 

Ortega, Dalyn ML15155A852 

Ortega, Victor ML15158A280 

Ortiz, Frank ML15153B083 

Ortiz, Kathy ML15156B042 

Ortiz, Keren ML15155B827 

Ortiz, Nina ML15154B745 

Osada, Susan ML15162A733 

Osborn, Carole ML15156A895 

Osborn, Thomas ML15159A896 

Osborne, Amanda ML15147A736 

Osborne, Colin ML15155C025 

Osborne, Deborah ML15162A049 

Osborne, Denise ML15154C146 

Osborne, Pamela ML15156A100 

Osgood, Pamela ML15154B008 

Oshiro, Alex ML15153B112 

Oskamp, Stuart ML15162A102 

Osmond, Ronlyn ML15155A495 

Osnes, Linda ML15159A161 

Ossipov, Simone ML15154B005 

Ostapow, Judith ML15160A835 

Ostlie, Susan ML15159B033 

Ostoich, Julie ML15155B877 

Ostopoff, Christine ML15156A057 

Ostrander, Jr., William P. ML15154A317 

Ostrow, Hillary ML15153B152 

O'Sullivan, Joseph ML15156A665 

O'Sullivan, Katherine ML15148B289 

Oswald, Keith ML15155A469 

Oswald, Timothy ML15155A832 

Ott, Michael ML15156B096 

Otter, J. Den ML15159B541 

Otto, Brian ML15142A253 

Otzel, Margaret ML15159B378 

Ouai, Dalila ML15141A673 

Ouellette, Tracy ML15156B241 

Overdier, Ruth ML15156A061 

Overlock, Trina ML15156A261 

Overmann, Laura ML15148A902 

Overstreet, Romy ML15159A417 

Commenter 

ADAMS 

Accession # 

Owen, Stephen ML15159B336 

Oxley, Rhonda ML15153B190 

Ozkan, Dogan ML15155B225 

P., C. ML15155C240 

P., Jaz ML15154C308 

P., W. ML15156A522 

Pace, Ann ML15153A380 

Pace, Lisa ML15154B308 

Packman, Zola ML15154A238 

Padalino, Gail ML15154A924 

Padelford, Grace ML15141A749 

Paden, Donna ML15153B073 

Padilla, Melania ML15159B057 

Padilla, Sergio ML15160A991 

Padmanabhan, Urmila ML15153A713 

Paganuzzi, Cinzia ML15154B827 

Pagni, Jean ML15153A840 

Painter, Joanne ML15160A906 

Pairan, Josh ML15160A543 

Palacky, Tami ML15142A159 

Palazzini, Louis ML15148B449 

Palder, Evelyn ML15154A556 

Paley, Leon ML15141A752 

Paling, Scott ML15154A795 

Palladine, Michelle ML15155A177 

Pallanes, Beatriz ML15154A035 

Palmer, Marilyn ML15156B297 

Palmquist, Wendy ML15159B557 

Palo, Jason ML15154A355 

Paluck, Ilene ML15160A827 

Pandit, Sudhir ML15159B418 

Pandolfi, Sara ML15156B463 

Panei, Maryann ML15148A743 

Pankhurst, Heather ML15155A227 

Pannaman, Stanley ML15155C013 

Pannell, Destiny ML15141A631 

Panter, Lisanne ML15155A426 

Panza, Mike ML15155B779 

Papandrea, John ML15142A160 

Pappas, Carole ML15153B157 

Pappas, Melissa ML15156A039 

Papscun, Alan ML15153A950 

Parcell, Ruth ML15142A155 

Parcells, Julie ML15155A603 

Parcou, Julien Kaven ML15154B793 

Pardi, Marco ML15142A133 

Pardington, Akura ML15158A221 

Parent, Amy ML15158A227 

Parigi, Robin ML15156A430 

Park, Gregory ML15156A579 

Park, Laura ML15153B178 

Park, Phyllis ML15154B294 

Parker, Ashley ML15141A605 

Parker, Corey ML15162B091 

Appendix E NUREG–2176 E-612 October 2016
Commenter 

ADAMS 

Accession # 

Parker, Corey ML15162B150 

Parker, Janice ML15158A240 

Parker, Jin Adams ML15156A433 

Parker, Joannie ML15153A402 

Parker, Louise ML15148A892 

Parker, Patricia ML15142A193 

Parker, Richard ML15161A645 

Parker, Robert ML15156A001 

Parker, Sarah ML15156A062 

Parker, Sheri Dotson ML15160A947 

Parkhurst, Terrence ML15142A183 

Parkins, Janet ML15160A519 

Parks, Joan ML15156A194 

Parlee, Rodney ML15158A003 

Parmenter, Annmarie ML15153A916 

Parolini, Maura ML15141A613 

Parrish, Cynthia ML15141A689 

Parrish, Jessica ML15156A093 

Parrone, Cindy ML15148A980 

Parrott, Pamela ML15154A059 

Parsons, Michael ML15148B354 

Partsch, Michael ML15154B991 

Parzick, Anne ML15154A303 

Pascale, Alice ML15155B628 

Pascoe, Susan ML15141A475 

Pascual, Pat ML15154B965 

Pash, Eric ML15156A980 

Pasholk, Robin ML15162B102 

Pasholk, Robin ML15162B042 

Pasichnyk, Richard ML15148A903 

Pasqua, John ML15155A485 

Pasqueal, Adam ML15155B917 

Passmore, Judith ML15153B129 

Passoff, Dave ML15156A056 

Patel, Kaushik ML15159A595 

Patel, Sarosh ML15148A863 

Paterno, Ellen ML15160A528 

Patoray, Arlene ML15153A564 

Patrick, Jane ML15159A104 

Patrick, Dale ML15148B292 

Patrick, Duane ML15154B503 

Patrick, Leslie ML15154B473 

Patrizzi, Lee ML15154C220 

Patterson, Carol Joan ML15162A735 

Patterson, Dixie ML15156A829 

Patterson, Katherine ML15154B224 

Patterson, Kevin ML15154B791 

Patterson, Pam ML15161A660 

Patterson, Robin ML15140A217 

Pattison, Janet ML15155B629 

Patton, Lesley ML15155B892 

Patton, Todd ML15155B664 

Patty, Shannon ML15153B203 

Paul, Adrian ML15142A252 

Commenter 

ADAMS 

Accession # 

Pauley, Marcia ML15148A605 

Pauline, Jean ML15155C030 

Pauls, Terry ML15158A198 

Paulson, Melony ML15159A666 

Pavcovich, Michelle ML15159A159 

Paverman, Adriana ML15159A289 

Pavlova, Karina ML15159A796 

Paxson, Michele ML15159A278 

Paxton, Greg ML15159A743 

Paxton, Bobbie ML15155A837 

Payne, Geneine ML15159A552 

Payne, Grace ML15154B261 

Payne, Heather ML15153A777 

Peale, Mike ML15154C154 

Pearce, Harold ML15159A524 

Pearce, J. B. ML15155A219 

Pearson, B. ML15158A255 

Pearson, Kiesha ML15156A731 

Pearson, Tia ML15154B825 

Pearthree, Pippa ML15158A034 

Pecararo, Dawn ML15148A801 

Pech, Jim ML15141A638 

Pecha, III, Anton F. ML15159B143 

Peck, M. ML15162A375 

Peck, Sarah ML15154B025 

Peckham, Theresa ML15154B269 

Pedersen, Ashley ML15156B293 

Pedler, Stephanie ML15154B141 

Peeples, Ruth ML15154B443 

Peerman, Dean ML15153A512 

Pelausa, Enrico ML15159A511 

Pelleg, Josh ML15155B902 

Pelletier, Joel ML15153A646 

Pellett, Ocean ML15155B619 

Pelosi, Carol ML15154A276 

Peloza, Amy ML15159A857 

Peltan, Mark ML15156B445 

Pelzer, Ann ML15155A970 

Pena, Deanna ML15154C228 

Pena, Suzanne ML15154B290 

Penchoen, Gregory ML15154B940 

Pender, Jacqueline ML15160A896 

Pendergast, Betsy ML15156B099 

Penn, Gigi ML15162B079 

Penn, Gigi ML15162B124 

Pennell, Joyce ML15155A412 

Pennell, Sherry ML15154B022 

Pepitone, Michelle ML15154A243 

Pepper, Mark ML15154A701 

Perales, Tarasa Masia ML15141A719 

Percy, Patrick ML15158A204 

Perednik, Daniela ML15141A641 

Pereira, Sheila ML15158A170 

Perenich, Theresa ML15153A907 

Appendix E October 2016 E-613 NUREG–2176
Commenter 

ADAMS 

Accession # 

Perenne, Luise ML15155A080 

Perinchief, Jana ML15153B005 

Perkins, Ana ML15159A891 

Perkins, Christophe ML15156A068 

Perkins, David ML15155C048 

Perkins, E. ML15148A957 

Perkins, Guy ML15140A001 

Perkins, Jean ML15159B019 

Perkins, Karen ML15148A208 

Perkins, Kathy ML15155B197 

Perkins, Sandra ML15154C179 

Perkins, V. ML15154A458 

Perkowski, Richard ML15154A313 

Perlmutter, Martha ML15154B347 

Pero, Elva ML15155B801 

Perren, William ML15141A796 

Perrett, Jody ML15154B680 

Perricelli, Claire ML15153A721 

Perrin, Amy ML15158A076 

Perron, Patricia ML15154A237 

Perruccio, Frank J. ML15155C116 

Perry, Ed ML15156B151 

Perry, Frank ML15159B432 

Perryman, Toddy ML15154A691 

Persinger, Elizabeth ML15155B363 

Persky, Jerry ML15155C044 

Petel, Amanda ML15155B918 

Peter, Judith ML15154B228 

Peterman, Andy ML15156A013 

Peters, Emily ML15148A995 

Peters, Jeff ML15156A033 

Peters, Kevin ML15141A608 

Peters, Ray ML15155A290 

Peters, Ray ML15155B330 

Peters, Robert ML15154A992 

Peters, Robert ML15155B279 

Petersen, Sandra ML15141A666 

Petersman, Mary Jo ML15159B343 

Peterson, Dale ML15154C270 

Peterson, Elizabeth ML15148B033 

Peterson, Georgie ML15153A748 

Peterson, Kim ML15155B526 

Peterson, Kristina ML15154C108 

Peterson, Linda ML15161A631 

Peterson, Mary ML15154B036 

Peterson, Nancy ML15155B667 

Peterson, Robin ML15154B914 

Peterson, Tarina ML15162A448 

Peterson, Ted ML15154B759 

Peterson, Trayce ML15153B161 

Petitpas, Bethanie ML15155A738 

Petkiewicz, Margaret ML15148A836 

Petrisko, George ML15142A033 

Petrova, Dobrinka ML15159B450 

Commenter 

ADAMS 

Accession # 

Petry, Gabor ML15155B706 

Petsco, John ML15159A700 

Pettis, Carolyn ML15159A847 

Pettway, Beverly ML15159A862 

Petty, Mark ML15156B004 

Pew, Don ML15154A680 

Pfeifer, Nezka ML15155A156 

Pfeiffer, Steven ML15159A995 

Pfitzner, James ML15154A128 

Pflug, Carl ML15156A544 

Phelps, Amy ML15159A947 

Phelps, Tami ML15155C010 

Phenicie, Deb ML15142A164 

Philips, Nancy ML15159B056 

Phillips, Bob ML15156B382 

Phillips, Charles ML15162B104 

Phillips, Charles ML15162B042 

Phillips, Christopher ML15153B185 

Phillips, E. Lehuanani ML15155B834 

Phillips, George ML15148B387 

Phillips, Janice ML15154B974 

Phillips, Jean ML15154B238 

Phillips, Jeffrey ML15156A113 

Phillips, Nancy ML15159A523 

Phillips, Richard ML15148A875 

Phillis, Ashley ML15156A944 

Piazza, Joseph ML15155C241 

Piazza, Kerri ML15159B296 

Picchetti, Gloria ML15155A673 

Picchioni, George ML15148B035 

Picciani, Laureen ML15154A619 

Piccione, Maryann ML15140A110 

Pick, Thomas ML15155A187 

Pickering, Lori ML15147A714 

Pickworth-Campbell, 

Carole ML15148B155 

Picot, John Brian ML15162A740 

Pielke, Janet ML15154B824 

Pier, Mollie ML15154B296 

Pierce, Betty ML15159A065 

Pierce, Brian ML15154C058 

Pierce, Ernest ML15153B274 

Pierson, James ML15154A699 

Pietri, William ML15141A595 

Pikaart, Philip ML15155A533 

Pikala, Christine ML15154C035 

Pike, Evette ML15154C125 

Pikus, Barbara ML15156A935 

Pileggi, Peter ML15155A247 

Pilz, Mila ML15156B505 

Pinder, Paige ML15148A950 

Pinneau, Janet ML15155B725 

Pinneo, Guy ML15154B966 

Pinneo, Janet ML15154B627 

Appendix E NUREG–2176 E-614 October 2016
Commenter 

ADAMS 

Accession # 

Pinque, Meryl ML15156A144 

Pintagro, Thomas ML15154B762 

Piper, Cynthia ML15159B028 

Piper, Janna ML15154C115 

Pirrone, Annette ML15154A088 

Piser, Corey ML15155A246 

Pistor, Christiane ML15153B251 

Pitt, Jon ML15153A859 

Pixley, Elizabeth ML15156A315 

Pizarro, Vanesaa ML15154A310 

Pizzo, Sherrie ML15159A130 

Place, Robert and Mary ML15155A480 

Plaehn, Dave ML15154B933 

Plagge, Angela ML15142A261 

Plant, Eleanor ML15154A187 

Platt, David ML15141A604 

Plaza, Minette ML15148B099 

Plecko, Emil ML15154C042 

Plemons, Viktoria ML15154A730 

Pliner, Elliot ML15147A741 

Plitt, Kathryn ML15148A668 

Ploenzke, Laura ML15148A703 

Plonski, Heidi ML15159B118 

Plubell, Susan ML15141A501 

Poe, Susan ML15156B360 

Poese, David ML15156A861 

Poessel, Sharon ML15153A956 

Pogell, Sarah ML15142A303 

Poist, Ellen ML15148B005 

Poland, Dianne ML15148B314 

Polczynski, Eric ML15154A906 

Polesky, Alice ML15148B427 

Polidori, Marguerite ML15159B245 

Polifroni, Josephine ML15159A957 

Polis, Rose ML15156A277 

Polito, Gene ML15156A308 

Politzer, Andrew ML15154B768 

Polk, James ML15148B008 

Polk, Linda ML15158A165 

Polk, Nora ML15154C301 

Pollack, Gary ML15159A050 

Pollak, Jeannie ML15155A484 

Pollina, Ron ML15159B566 

Pollock, Jeri ML15154B782 

Pollock, Renee ML15148A258 

Polsky, Mark ML15148A183 

Poock, Patty ML15156A503 

Pool, Ed ML15155B259 

Pool, Roxann ML15141A645 

Poole, Diane ML15148A951 

Poole, Jai ML15155A846 

Poole, Marcia ML15154C254 

Poole, Richard ML15153B255 

Pooler, Carole ML15154B681 

Commenter 

ADAMS 

Accession # 

Poolos, Hazel ML15153A938 

Pope, Angela ML15159A227 

Popoff, Dave ML15161A693 

Popp, Joseph P. ML15141A747 

Poppe, Dorothy ML15154B998 

Porcelli, Maureen ML15148B071 

Porcher, Janeene ML15148B382 

Porreca, Audrey ML15155A144 

Porrello, Christine ML15159A301 

Porsch, Angela ML15154A536 

Porter, Barbara ML15154B030 

Porter, Betsey ML15141A690 

Porter, Jan ML15156B259 

Porter, Thomas ML15141A423 

Porter-Keisner, Cheri ML15155B750 

Poskiene, Lina ML15155C220 

Post, Mike ML15155C202 

Postel, Rus ML15155A444 

Poston, Cindy ML15155A450 

Potter, Doris ML15159B024 

Potter, Eric ML15148A959 

Potter, Meredith ML15148A796 

Potter, Penny ML15154C235 

Pottinger, Catherine ML15153A698 

Poulsen, Barbara ML15153A929 

Poulsen, Sabrina ML15159B013 

Povill, Jon ML15155B511 

Powell, Jessie ML15156A071 

Powell, Michael ML15141A738 

Powell, Peggy ML15154C183 

Powell, Shirley ML15159A038 

Power, Philip W. ML15153A732 

Powers, Jeri ML15154B947 

Powers, Paula ML15154A775 

Powers, Sheila ML15154A553 

Pratt, David ML15148B297 

Pratt, Frederick ML15156B193 

Pratt, Ted ML15155B973 

Preece, Kelly ML15159B020 

Presetti, Joan ML15154B935 

Preston, Dee ML15155A870 

Preston, J. ML15159B423 

Pribanic, Carl ML15155B746 

Price, Carolyn ML15160A603 

Price, Elisabeth ML15155B757 

Price, Joyce ML15155C151 

Price, Joyce ML15155C186 

Price, Joyce ML15158A261 

Price, Mary ML15156A266 

Price, Nicole ML15141A588 

Price, Tyler ML15158A103 

Priest, Dave ML15141A533 

Priest, Donald ML15155C146 

Priest, Ruth Ann ML15148B261 

Appendix E October 2016 E-615 NUREG–2176
Commenter 

ADAMS 

Accession # 

Primrose, John ML15155B999 

Prince, Noelle ML15154C089 

Priskich, Fiona ML15155B258 

Pritchard, Jennifer ML15142A195 

Pritchett, William ML15161A647 

Prochazka, Penelope ML15155A994 

Proctor, M. ML15154B699 

Profant, Michelle ML15159A861 

Proietta, Susan ML15154B597 

Proteau, Mary ML15158A231 

Prouty, Leslie ML15156A008 

Provost, Clifford ML15156B316 

Pruet, Mary ML15160A826 

Prunko, Thomas ML15154A437 

Prystauk, William D. ML15153A781 

Psaras, Brenda ML15154A453 

Public, Jean ML15156A953 

Puca, Laurie ML15161A673 

Puchalski, Holly ML15156A303 

Puchli, Robert ML15154B822 

Puckett, Peggy Smith ML15156A576 

Puddy, Michelle ML15160A085 

Puentes, Felena ML15154A734 

Puerta, Jeanne ML15158A047 

Pullen, Sher ML15148B203 

Punneo, Sheryll ML15159B218 

Purbrick‐Illek, Sally ML15154A468 

Purcell, Douglas ML15154B901 

Purdy, Patty ML15154B089 

Purnell, Til ML15155A786 

Purucker, Susanna ML15155B507 

Purvis, Barbara ML15159B262 

Puscheck, Susan/Robert ML15154A148 

Pusey, John ML15154A018 

Putman, Eileen ML15156A585 

Putnam, Elizabeth ML15148B197 

Putnam, Gary ML15153A975 

Putnam, Lynn ML15155C028 

Puza, A. ML15158A200 

Pyle, Cathy ML15159A999 

Pysher, Paul ML15154B723 

Quaggan, Nancy ML15154A057 

Quaintance, Joel ML15154B640 

Quasha, George ML15156B173 

Quezada, Marin ML15148A149 

Quigley, Jennifer ML15162A428 

Quillian, P. ML15153A392 

Quillin, Michael ML15156A542 

Quimby, Michal ML15156A099 

Quinlan, Lola ML15154A185 

Quinlan, Lola ML15154A986 

Quinn, Anne ML15155B731 

Quinn, George ML15148A881 

Quinn, Patrick ML15160A534 

Commenter 

ADAMS 

Accession # 

Quinn, Zoe ML15160A857 

Quota, Ann Bainchi ML15148B009 

R., Leslie ML15159B034 

Raab, Frances ML15154A991 

Raabe, Karen ML15156A325 

Rabenold, Paul ML15154A629 

Rabin, Pat ML15158A048 

Rabinowitz, Rebecca ML15140A108 

Raby, Elizabeth ML15158A052 

Raby, Kevin ML15156A293 

Raccio, Karen ML15154B815 

Rachal, Terese ML15154A316 

Racine, Robert ML15162A680 

Raczka, Alan ML15155B251 

Radcliffe, Steve ML15154C223 

Radecki, Jennifer ML15156A997 

Rader, D. L. ML15154B205 

Radke, William ML15154A455 

Radko, Danuta ML15154B777 

Radov, Lisa ML15153A327 

Rae, B. ML15153A770 

Rae, Brad ML15159A061 

Raftery, Rita ML15154B441 

Ragan, Kate ML15162A566 

Raggio, Wendy ML15148A597 

Ragsdale, Kelly ML15160A912 

Rahav, Maritte (Mara) ML15155C226 

Raite, Sarah ML15154B957 

Ralph, Cecil ML15156B136 

Ramirez, David ML15155A289 

Ramlow, Bob ML15156A675 

Rammel, Vicki ML15154B164 

Ramo, Carol ML15141A505 

Ramos, Joann ML15156B393 

Ramos, Paul ML15148B036 

Ramos, Reyna Garcia ML15154B800 

Ramos, Sigrid ML15153A865 

Ramos, Tatianna ML15155B249 

Ramsey, Betty ML15153A419 

Ramsey, Elizabeth ML15141A660 

Ramsey, Kerry and Beth ML15154A419 

Ramsey, Philip ML15155C035 

Ramsey, Sylvia ML15155C221 

Ramstrom, Eric G. ML15153B013 

Rand, Mary ML15159A261 

Randall, Michael ML15158A228 

Randall, Victoria ML15153A785 

Randalll, Kay ML15155A680 

Randolph, Peter ML15154A880 

Raney, Gary ML15154B312 

Rankin, Jennifer ML15140A284 

Ranly, Don ML15159A098 

Ranney, Myrne ML15156A832 

Ransom, Judy ML15154A833 

Appendix E NUREG–2176 E-616 October 2016
Commenter 

ADAMS 

Accession # 

Rantala, Mervi ML15160A047 

Ranz, Lauren ML15142A093 

Rapp, Julia ML15142A044 

Rapp, Kathy ML15148B183 

Rapp, Lauren ML15160A767 

Rappaport, Alexandra ML15153A814 

Rappaport, Ann ML15153A733 

Rappe, Leonard ML15154B786 

Rarick, Karen ML15148B192 

Rascati, Barbara ML15153A882 

Rasche, Sandra ML15155A971 

Rasmussen, David ML15153B208 

Rasmussen, Nancy ML15156A249 

Rater, Virginia ML15148B141 

Rattman, Joseph ML15159B145 

Ratzlaff, Karen ML15155A719 

Raub, Ann ML15154A342 

Raupp, Christopher ML15148B200 

Rauscher, Janet ML15153B114 

Ray, Billie ML15148A887 

Ray, Glynda ML15154B359 

Ray, Glynda ML15155A743 

Ray, Kristy ML15155A049 

Ray, Leslie ML15159A430 

Raychaudhuri, Sumana ML15159A066 

Rayhill, Ashley ML15155B498 

Rayle, Steven ML15153A930 

Raymond, P. J. ML15147A762 

Raynis, Beth ML15159A058 

Rea, Corde ML15156A580 

Rea, Linda ML15155B575 

Read, Seth ML15156B219 

Reader, Charlene ML15153B075 

Ream, Donna ML15156A231 

Reback, Mark ML15160A554 

Reckers, Pamela ML15154B226 

Rector, Crystal ML15141A772 

Rector, Teresa ML15148A966 

Redding, Carmen ML15156A075 

Redish, Maryellen ML15159A895 

Redman, Sandi ML15156B194 

Redwine, Laura ML15155A154 

Redwing, Liz ML15154B809 

Reed, Avis ML15154A001 

Reed, Jason ML15154B024 

Reed, Jennifer ML15154A658 

Reed, Lucia ML15158A186 

Reed, Mary ML15159A426 

Reed, Michael B. ML15153A677 

Reed, Michele ML15148B059 

Reed, Pamela ML15154C029 

Reed, Patrick ML15162A246 

Reed, Robert ML15155A588 

Reed, Rodger ML15154A179 

Commenter 

ADAMS 

Accession # 

Reel, Joseph ML15140A203 

Rees, Judy ML15155B962 

Rees, Les ML15156A108 

Rees, Michael ML15155A403 

Reese, Elizabeth ML15155A250 

Reese, Sarah ML15153A582 

Reeves, Diana ML15153A686 

Reeves, Ella ML15159A842 

Reeves, Lenore ML15155A901 

Reeves, Linda ML15148A237 

Reeves, Sheila ML15154A838 

Regan, Evelyn ML15148B102 

Regan, Marilyn ML15155B008 

Regan, Nora ML15153B106 

Reichel, Tom ML15141A787 

Reichter, Susan ML15148A871 

Reid, Nina ML15156A052 

Reid, Patricia ML15156B024 

Reid, Ruth ML15160A919 

Reid, Sarah ML15159B539 

Reid, Susan ML15153A627 

Reiff, Mary ML15148A889 

Reifke, Kathleen ML15154C083 

Reiher, Linda ML15156A327 

Reilly, Marnee ML15159A778 

Reilly, Michael ML15155C173 

Reiman, Lynn ML15154A478 

Reinfried, Kay ML15147A784 

Reinhart, Robin ML15154B781 

Reinik, Bruce ML15159B048 

Reisenbichler, Reg ML15158A044 

Reisman, Emil ML15148B010 

Reiter, Doris ML15154B960 

Reiter, Doris ML15154C209 

Remkus, Ann ML15159A783 

Remy, Deborah ML15154C073 

Rendon, Renate ML15154C253 

Renee, Locks ML15153A807 

Rennacker, Ann ML15154C078 

Rennie, Edwyna ML15160A054 

Renno, Gerd ML15142A212 

Renno, Kathy ML15156A507 

Renton, Kristen ML15155A886 

Repiquet, Sandra ML15153B080 

Resh, Brian ML15155A779 

Resseguie, William ML15155C126 

Rettig, William ML15155C132 

Revesz, Bruce ML15154C196 

Revord, Michael ML15154B712 

Rexrode, Earl ML15148A831 

Reyes, Kimberly ML15155A807 

Reynolds, Alan ML15159A088 

Reynolds, Britain ML15154A039 

Reynolds, Daniel ML15154B078 

Appendix E October 2016 E-617 NUREG–2176
Commenter 

ADAMS 

Accession # 

Reynolds, Jeff ML15154A314 

Reynolds, K. ML15156A176 

Reynolds, Lloyd ML15156B432 

Reynolds, Michele ML15155C162 

Reynolds, Renee ML15155B722 

Reynolds, Ruth ML15140A034 

Reynolds, Thomas ML15155B073 

Rhein, Herman ML15154B646 

Rhoades, John ML15155A216 

Rhoads, Donald ML15156A138 

Rhode, Christina ML15159A830 

Rhodes, Ira ML15160A698 

Rhodes, Janet ML15156B422 

Rhodes, Marilyn ML15154B052 

Rhodes, Michael ML15148A956 

Rhodes, Steven ML15159B372 

Rhymer, Joseph ML15154B841 

Rials, Jennifer ML15154A273 

Ricci, Gail ML15156A893 

Ricci, Scott ML15148B149 

Ricciardi, Anthony ML15140A068 

Rice, Everett ML15154A175 

Rice, Gina ML15154B610 

Rice, Jima ML15160A817 

Rice, Kyra ML15155A123 

Rice, Michael ML15148A985 

Rich, Laura ML15154C150 

Richard, Laree ML15156B472 

Richards, Leslie ML15142A236 

Richards, John ML15156A856 

Richards, Margie ML15156A134 

Richards, Sarah ML15147A770 

Richards, William ML15148A643 

Richardson, Aleda ML15156A864 

Richardson, Danielle ML15162A048 

Richardson, Dianne ML15148B148 

Richardson, Don ML15142A227 

Richardson, Gail ML15155A652 

Richardson, K. ML15158A036 

Richardson, Katherine ML15153A471 

Richcreek, Geoff ML15155A119 

Richey, Paul ML15148A629 

Richey, Sharon ML15153B252 

Richie, Lauren ML15154A281 

Richmond, Lonna ML15148B333 

Richmond, Michael ML15155A721 

Richter, Caleb ML15153A735 

Richter, Marthie ML15159B448 

Rickenbach, Deborah ML15155A267 

Riddell, Brian ML15159A293 

Ridder, Lynette ML15140A023 

Riddle, Carolyn ML15155A508 

Rider, Dara ML15154B736 

Ridgeway, William ML15153A373 

Commenter 

ADAMS 

Accession # 

Ridgley, Patricia ML15159B510 

Ridgway, K. ML15153A923 

Riehart, Dale ML15140A278 

Rietzel, Marilyn ML15155B969 

Riff, Christopher ML15156A461 

Riggins, Thomas ML15154C221 

Riggs, Richard ML15154A266 

Rigney, J. ML15158A207 

Rigney, Jane ML15158A208 

Riley, Diane ML15155A223 

Riley, Kathleen ML15162B044 

Riley, Kathleen ML15162B116 

Riley, Kelly ML15155A055 

Riley, Michael ML15140A069 

Rinaldi, Debbie ML15155C144 

Rincon, Tanya ML15156A027 

Rindler, Joseph ML15153A483 

Ringgaard, Line ML15141A454 

Ringler, Thomasin ML15154A796 

Ringquist, Rodd ML15153B160 

Rinner, Timothy ML15155A608 

Rios, Jen ML15159A131 

Rios, Susan ML15154A202 

Ripley, John ML15141A732 

Ripple, Martha Jane ML15158A254 

Ripplinger, George ML15158A053 

Rise, William ML15155A497 

Ritola, Donna ML15148B106 

Rittenhouse, Calvin ML15147A755 

Rittenhouse, Nancy ML15153A499 

Rivard, Kris ML15148A803 

Rivas, Cecilia ML15159B429 

Rivenburg, Russell ML15155B323 

Rivera, C. ML15156A300 

Rivera, Javier ML15154B463 

Rivera, Sergio ML15154B850 

Rizzo, Barbara ML15153A391 

Rizzo, Paul ML15154C040 

Rizzuto, Angela M. ML15156A163 

Roach, Edward ML15154A299 

Robbins, Elizabeth ML15155C188 

Robbins, Eloise ML15140A198 

Robbins, Mary ML15148A934 

Roberson, Steven ML15162A723 

Roberto, Robert ML15154A577 

Roberts, Rodney ML15142A257 

Roberts, Amy ML15148B240 

Roberts, Blake ML15153A808 

Roberts, Brock ML15154A773 

Roberts, Chuck ML15153A441 

Roberts, Fiona ML15156B424 

Roberts, Judith ML15154C004 

Roberts, Julie ML15162A711 

Roberts, Laney ML15154B227 

Appendix E NUREG–2176 E-618 October 2016
Commenter 

ADAMS 

Accession # 

Roberts, Phyllis ML15148A261 

Roberts, Sally ML15154A654 

Robertshaw, K. K. ML15155A530 

Robertson, Destine ML15160A893 

Robertson, Kathryn ML15142A235 

Robey, Eddy ML15154C275 

Robideau, Elizabeth ML15142A219 

Robin, Etta ML15153B173 

Robinson, Angel ML15155A118 

Robinson, Dameta ML15156B050 

Robinson, James ML15148A130 

Robinson, Janet ML15154B651 

Robinson, Jeanne ML15160A796 

Robinson, Julianna ML15158A125 

Robinson, Juneko ML15154C057 

Robinson, Khristine ML15155A761 

Robinson, Lee ML15148B110 

Robinson, Patricia ML15153A993 

Robinson, Rory ML15154A686 

Robinson, Saliane ML15153B163 

Robson, Eric ML15141A550 

Rocco, Evelyn ML15159A285 

Rocco, Y. ML15156A023 

Rocco, Y. ML15156B358 

Rocha, Nidia ML15160A660 

Roche, Chris ML15158A128 

Roche, Peter ML15140A047 

Rocheleau, Jessica ML15147A733 

Rocke, Janice ML15154B764 

Rockers, Kay ML15155C019 

Rodack, Soretta ML15156A783 

Rodgers, Ron ML15155B182 

Rodman, Shirley ML15159A495 

Rodoff, Lennie ML15156B181 

Rodrigue, Gracinda ML15155A353 

Rodriguez, Angela ML15148B270 

Rodriguez, Betsy ML15155A749 

Rodriguez, Ste Ven ML15156A716 

Rodriguez, Sylvia ML15154C034 

Roe, Christina ML15154A017 

Roegner, Debby ML15156A140 

Rogers, Belinda ML15141A497 

Rogers, Dave ML15159A250 

Rogers, David ML15154A405 

Rogers, Dennis ML15154A056 

Rogers, Jennifer ML15142A021 

Rogers, Susan ML15148A840 

Rogers, William ML15158A151 

Rohloff, Rosalyn ML15155A188 

Rohm, Lisa ML15159A023 

Rohr, Michaela ML15155B813 

Rol, Anna Natalie ML15154A158 

Roland, Jelica ML15156B161 

Rolbeck, Kathi ML15154B482 

Commenter 

ADAMS 

Accession # 

Roll, Greg ML15156A288 

Rolland, Lane ML15154B989 

Rollings, Rusty ML15154A293 

Rollo, P. ML15162A417 

Rolston, Patricia ML15153A810 

Roma, Michele ML15154B710 

Romani, Gwen ML15156A940 

Rome, Abigail ML15154B921 

Romesburg, Denise ML15161A635 

Romine, Janet ML15156A301 

Romine, Janet Holly ML15153A867 

Rominger, Nancy ML15159B464 

Ronco, Philip ML15154A710 

Rooney, Diane ML15153B268 

Root, Charlene ML15154C023 

Root, Sharon ML15154A521 

Rosa-Re, Samantha ML15154B964 

Rosasco, Stephen ML15155A643 

Roscher, Miles ML15162A144 

Rose, Aaron ML15156A887 

Rose, Amanda ML15148B435 

Rose, B. ML15158A247 

Rose, Jay ML15148B448 

Rose, Shannon ML15158A250 

Rose, Timothy ML15160A684 

Roseberry, Bill ML15159A882 

Rosen, Susan ML15155B025 

Rosen, Helene ML15148A930 

Rosen, Natalie ML15159A810 

Rosen, Paul ML15154A009 

Rosenblood, Jamie ML15153A718 

Rosenblum, Stephen ML15148B326 

Rosencrans, Matt ML15158A182 

Rosenfeld, Alice ML15155A909 

Rosengrant, Deb ML15159A831 

Rosenkrantz, Bruce ML15159A850 

Rosenthal, Rima ML15154A822 

Rosier, Amy ML15153A730 

Roske, Adam ML15142A293 

Ross, Audrey ML15155B502 

Ross, Barry ML15140A162 

Ross, Carolyn ML15155A276 

Ross, Elliot ML15153A363 

Ross, J. ML15148B443 

Ross, Jean ML15148A751 

Ross, Kay ML15148B296 

Ross, Patricia ML15154A058 

Rossetti, Pamela ML15154A027 

Rossi, Daniela ML15159B247 

Rossi, Ray ML15155B919 

Rossini, J. ML15141A569 

Rosso, Brit ML15156A904 

Rosson, Rebecca ML15154B258 

Roth, Augustine ML15156B498 

Appendix E October 2016 E-619 NUREG–2176
Commenter 

ADAMS 

Accession # 

Roth, Ed ML15153B155 

Roth, Gaby ML15153A508 

Roth, Jerome ML15148A667 

Roth, Lu ML15153A880 

Roth, Steve ML15154A606 

Rothauser, S. ML15159A651 

Rothman, Emily ML15154B092 

Rothschild, Blake ML15160A825 

Rothschild, Eileen ML15155A019 

Rothstein, Debbie ML15142A158 

Roulston-Doty, Suzanne ML15141A441 

Rouse, Framk ML15159A483 

Rousseau, Claudia ML15156B307 

Rousseau, Nicole ML15154B472 

Rove, Frances ML15156A295 

Rovnak, William ML15154A718 

Rowden, Tanya ML15162A259 

Rowe, Jeannette ML15154A792 

Rowell, Edward ML15155B327 

Rowinski, Wojciech ML15159A288 

Rowles, Trina ML15160A981 

Rowlingson, John ML15154B742 

Rowlingson, John ML15160A958 

Roy, Joe ML15156A112 

Roy, Randy ML15156B244 

Royer, Alice ML15154A332 

Royer, Alice ML15155A157 

Royer, Allen ML15155A496 

Ru, De ML15156A180 

Ru, Stephanie ML15154C241 

Ruben, Martha ML15154A150 

Rubesch, Erick ML15154A404 

Rubin, Bill ML15159A604 

Rubino, Karen ML15147A750 

Rubio, Maria ML15156A258 

Ruby, Jacki ML15154C060 

Ruby, Theresa ML15155B572 

Rudd, Vickie ML15147A732 

Rudisill, Amanda Sue ML15156A591 

Rudolph, Linda ML15148A794 

Ruggiero, Linda ML15155C159 

Ruiz, Antonio ML15154C086 

Ruiz, Arnold ML15159A216 

Ruiz, Arnold ML15159A218 

Ruiz, Nelida ML15159B571 

Ruiz, Osiel ML15156A485 

Ruiz, Susan ML15153B063 

Rule, Juliann ML15154A201 

Rullmann, Gale ML15153A822 

Rumiantseva, Elena ML15148B198 

Rummel, Thomas ML15148A168 

Rusell, Jessica ML15142A213 

Rush, Charlene ML15156B496 

Rushing, Dora ML15153A837 

Commenter 

ADAMS 

Accession # 

Rushlau, Mary Anne ML15156A566 

Rusian, Andrzej ML15155C204 

Rusiniak, Karen ML15155B633 

Russell, Claire ML15148A869 

Russell, Katherine Blum ML15156B071 

Russell, Lela ML15154A900 

Russell, Nathan ML15160A536 

Russell, Nathaniel ML15153B264 

Russell, Rick ML15154B207 

Russo, Bob ML15159A482 

Russo, Carl ML15156A506 

Rutherford, Helen ML15155A150 

Rutkowski, Robert ML15148A947 

Ryan, Mary ML15154B724 

Ryan, Terrance ML15156B028 

Ryan, Thomas ML15154B743 

Ryan, Thomas ML15154B982 

Rycheck, Kevin ML15153B079 

Ryder, Gigi ML15154A399 

Rysavy, Robin ML15155C062 

S., D. ML15155B683 

S., Jennifer ML15155B596 

S., R. ML15159A505 

Saavedra, Yvonne ML15159A955 

Sabatini, Kathy ML15155B812 

Sachs, Jean ML15155B254 

Sacirbey, Susan ML15156A570 

Sacks, Cindy ML15161A663 

Saddler, Robert ML15159A762 

Sadkovsky, Vera ML15153B243 

Saeger, Judy ML15148B065 

Saez, Denisa ML15155A498 

Safranek, Walter ML15154B893 

Sagatelian, Nancy ML15155B610 

Sager, Mary Jane ML15148A977 

Sailer, Randy ML15154C180 

Saja, Jean ML15153A813 

Sak, Myrna ML15156A858 

Salatino, Freda ML15148B144 

Salazar, Joe ML15155B881 

Salgado, Jane ML15155A877 

Salgado, Natasha ML15141A740 

Sall, Frederick ML15153A356 

Sallah, Maggie ML15147A774 

Salt, Max ML15159B452 

Salter, Andrew ML15141A557 

Saltzman, Barry ML15154C193 

Saltzman, Susan ML15154A240 

Salvat, Melanie ML15160A082 

Salvner, Amanda ML15162A476 

Salyer, Allen ML15159A128 

Salyer, June ML15160A564 

Salz, Michael ML15154B116 

Samartano, Jennifer ML15153A659 

Appendix E NUREG–2176 E-620 October 2016
Commenter 

ADAMS 

Accession # 

Sammons, Marilyn ML15148B294 

Sampson, Debbie ML15156B018 

Samuelson, Georgeanne ML15156B403 

San Cartier, Terry ML15155A327 

San Socie, Robert Glenn ML15159A888 

Sanchez, Luz ML15155B741 

Sanchez, Luz ML15155B765 

Sanchez, Paul ML15156B479 

Sanchez, Ralph ML15155B414 

Sanchez, Saul ML15155B869 

Sand, Margaret ML15148B372 

Sandel, P. ML15155B585 

Sanders, Carrie ML15155A330 

Sanders, Melanie ML15155A209 

Sanderson, Sandy ML15154A116 

Sandgrund, Robert ML15156A559 

Sandoval, Lily ML15155A763 

Sandow, Chris ML15148B259 

Sandritter, Ann ML15141A721 

Sanford, Ken ML15162A105 

Sanford, Timothy ML15148A976 

Santangelo, Elaine ML15154B439 

Santiago, Jr., Raymond ML15159A384 

Santonas, Gina ML15140A036 

Santopietro, Michael ML15154A425 

Santora, Mark ML15155A038 

Santos, Betty ML15154B868 

Santos, Eloy ML15159B328 

Santos, Hamerling ML15162B119 

Santos, Hammerling ML15162B079 

Santos, Saskia ML15158A054 

Santto, Aldana ML15159B154 

Sapiro, Claire ML15153A744 

Sarkisian, George ML15156A165 

Sarraille, Marijeanne ML15153A932 

Sarramia, Christian ML15154A408 

Sasaoka, Julie ML15153B305 

Sather, Alice ML15154C061 

Satijn, Pascalle ML15155C098 

Saucedo, Angelina ML15160A932 

Sauer, Marlene ML15153A436 

Saunders, Britton ML15154A966 

Saunders, Diana ML15153A772 

Savadove, Lydia ML15155A526 

Savage-Wright, Kathleen ML15153A799 

Savino, Heather ML15140A290 

Savitch, Steve ML15153A935 

Savla, Dinmani ML15162A485 

Sawicki, Barbara ML15142A180 

Sawyer, Caryl ML15148A665 

Sawyer, Jerry ML15140A042 

Saxon, Diana ML15154A258 

Sayers, Marrick ML15155B176 

Sayre, Jean ML15156A111 

Commenter 

ADAMS 

Accession # 

Sazonov-Robinson, 

Mauria ML15148B111 

Scalzo, Robert ML15154A407 

Scanzillo, Frank ML15155A358 

Scarborough, Lee and Sue ML15148B361 

Scarbrough, Shirley ML15154A263 

Scarci, Kris ML15155A734 

Scarlata, Rachel ML15155B922 

Scarlett, Steve ML15156A066 

Scarr, Carolyn ML15148A826 

Scarry, Patrick ML15159B331 

Scavezze, Barbara ML15155B393 

Schaack, Jerome ML15156A929 

Schabauer, Jacinda ML15148B029 

Schacht, Timothy ML15153B088 

Schack, Sara ML15154A151 

Schaefer, George ML15148A277 

Schaefer, Sandra ML15155C099 

Schaefer, Sarah ML15141A619 

Schaefer, Stacey ML15162B107 

Schaefer, Stacey ML15162B064 

Schaeffer, Kathy ML15159A643 

Schaem, Suzanne ML15148B184 

Schafer, Dale ML15141A742 

Schafer, Helen ML15154B798 

Schafer, Maggie ML15148A943 

Schafer, Peter ML15154B837 

Schall, James ML15159A093 

Schally, Erin ML15154C222 

Schamel, Raymond ML15147A780 

Schaming, Carol ML15155B652 

Scharaldi, Dan ML15159B300 

Schary, Joy ML15154A755 

Schas, Bill ML15156A269 

Schatz, Vivian ML15155A650 

Schatzle, Kathy ML15148A626 

Schecter, Jennifer ML15154B794 

Schehl, Ed ML15156A851 

Scheller, Emil ML15153B224 

Scherzer, Teresa ML15154A810 

Schetzer, Kathryn ML15162A577 

Scheyer, Marguerite ML15153A976 

Schick, Laurie ML15154A482 

Schierman, Mollie ML15154C252 

Schiffelbian, Alexander ML15158A237 

Schildwachter, Steve ML15159A945 

Schilling, Christy ML15142A168 

Schilling, Judy ML15154B916 

Schindler, Maury ML15148B101 

Schira, Jane ML15159A290 

Schlatter, Jeanne ML15160A758 

Schlein, Elizabeth ML15155B649 

Schlemel, Pierre ML15142A305 

Schlesinger, Ronald ML15162A047 

Appendix E October 2016 E-621 NUREG–2176
Commenter 

ADAMS 

Accession # 

Schlesinger, Sybil ML15153A513 

Schlitz, Barbara ML15154A279 

Schloss-Birkholz, Gisela ML15148B151 

Schlupp, Deo ML15154C143 

Schmalzer, Paul ML15156A000 

Schmatjen, Sheryl ML15154A747 

Schmeichel, Nicollette ML15156A153 

Schmidt, Frederick ML15155C036 

Schmidt, Jan ML15153A823 

Schmidt, Kimberly ML15155A107 

Schmidt, Laurie ML15155B839 

Schmidt, Roger ML15154C188 

Schmidt, Susan ML15158A039 

Schminke, Molly ML15158A293 

Schmitt, Donna ML15156A681 

Schmitt, Tim ML15162A714 

Schmittauer, John ML15147A768 

Schmitt-Debonis, Michelle ML15154B626 

Schmitz, Marsha ML15156A309 

Schmotzer, Mary ML15160A901 

Schnebel, Sherry ML15161A651 

Schnee, Jane ML15141A675 

Schneewind, Jon ML15159A014 

Schneider, Annette ML15155B344 

Schneider, Barbara ML15156B461 

Schneider, Caitlin ML15154B323 

Schneider, Daniel ML15153B119 

Schneider, Edward ML15156A236 

Schneider, George ML15155C066 

Schneider, Terri ML15154A261 

Schneider, Wanda ML15154A555 

Schnell, Gail ML15155B192 

Schneller, Douglas ML15154B705 

Schochet, Gordon ML15156A691 

Schoech, Dick ML15159A599 

Schoedler, Randolph ML15154A672 

Schoene, William ML15159B279 

Schoenfield, Rick ML15160A960 

Schoenhofer, Robert ML15141A537 

Schoenwetter, Ruth ML15154A516 

Scholl, Barbara ML15155B047 

Scholz, Denise ML15156A024 

Schonberger, Jennifer ML15148B229 

Schorey, Carmen ML15148B232 

Schramm, Marilyn ML15148B249 

Schramm, Peggy ML15160A899 

Schreckengost, J. ML15148A608 

Schreiber, John ML15159A030 

Schreiber, Linda ML15155B616 

Schreier, Marguerite ML15154B685 

Schreiner, Amy ML15154A053 

Schroeder, Andrew ML15162A612 

Schuchard, Susan ML15156A276 

Schuetz, Ralf ML15153A467 

Commenter 

ADAMS 

Accession # 

Schuhrke, Nancy ML15156B267 

Schultz, Cindy ML15148B239 

Schultz, Monica ML15159B351 

Schultz, Stephanie ML15160A795 

Schultz, Walter ML15155A829 

Schultz, Wm ML15156B402 

Schultze, Patti ML15159A086 

Schumacher, Amy ML15159B360 

Schurr, Arthur ML15153B285 

Schusterman, Jennifer ML15148A972 

Schwab, Judith ML15148A623 

Schwaller, Greg ML15159A156 

Schwandes, Shaytu ML15154B814 

Schwartz, Angela ML15155A061 

Schwartz, Donald ML15155A524 

Schwartz, Jake ML15148B193 

Schwartz, Judy ML15153B277 

Schwartz, Randy ML15155B842 

Schwartz, Robert ML15160A546 

Schwartz, Tamar ML15142A080 

Schwartzberg, Lora ML15161A659 

Schwarz, Don ML15159B037 

Schwarzauer, Dennis ML15156B304 

Schwegmann, Annette ML15159A343 

Schweiss, Kraig and 

Valerie ML15155B766 

Schwinberg, Jean ML15148B286 

Scibetta, Kimberly ML15154A600 

Sciochetti, Chris ML15148B345 

Sciolto, Maureen ML15140A199 

Scorzelli, Susan ML15153A705 

Scott, Brian ML15155B941 

Scott, Edward ML15148A949 

Scott, Emily ML15159A991 

Scott, J. David ML15147A711 

Scott, Jennifer ML15162A077 

Scott, K. ML15154C082 

Scott, Kari Lorraine ML15155B598 

Scott, Nolen ML15148B107 

Scott, Peter ML15159B058 

Scott, Raeann ML15154A687 

Scott, Wenona ML15154A016 

Scotti, O. Bisogno ML15156B437 

Scouras, Robert ML15154B357 

Scoville, Pam ML15141A459 

Scribner, Denee ML15159A169 

Scribner, Jason ML15148B061 

Scroggs, Tammy ML15155B019 

Scuder, Andrea ML15159B062 

Scully, Patricia ML15156A434 

Seaman, Gerda ML15148B277 

Seamans, Kurt ML15142A215 

Searle, M. ML15148A849 

Searles, Dave ML15159A798 

Appendix E NUREG–2176 E-622 October 2016
Commenter 

ADAMS 

Accession # 

Sears, Kim ML15160A886 

Sears, Nicole ML15153B018 

Seaton, Chris ML15159A856 

Seaver, LaRoy and Mary ML15153A362 

Seavey, Arthur ML15162A239 

Sebastian, Scott J. ML15153A503 

Sebastian-Lewis, Harley ML15142A328 

Seckel, John ML15159B242 

Seckman, Sally ML15156A913 

Sederquest, Evan ML15156B031 

Sedy, Alice ML15156B098 

Seeburger, John ML15155B663 

Seeman, Paul ML15159B584 

Seff, Joshua ML15154A673 

Segal, Gussie ML15156A215 

Selby, Lisa ML15142A025 

Selig, Ronald ML15158A283 

Sellers, Jennifer ML15155A998 

Sellers, Robert ML15155C234 

Sells, Greg ML15159A846 

Seltzer, Elizabeth ML15155A505 

Seltzer, Rob ML15153B056 

Seltzer, Rob ML15148B020 

Semienko, Brenda ML15154A367 

Sendrowitz, Mitchell ML15155A863 

Sennello, Patrick ML15155B849 

Sennert, Gloria ML15156A091 

Sennett, Frank ML15156A713 

September, P. J. ML15155B871 

Sepulveda, Christine ML15155B913 

Sepulveda, Christine ML15155B939 

Sera, Sally ML15153A680 

Serazio, Sandra ML15156A650 

Sercombe, Sarah ML15154B375 

Serletic, Cathie ML15154A974 

Sesack, Brian ML15160A063 

Seufert, Sarah ML15148A611 

Severino, Susan ML15160A931 

Sewick, Karen ML15141A765 

Sexton, John ML15140A112 

Seymour, Linda ML15154A805 

Shaaban, Marian ML15155B446 

Shaak, Susan ML15154C289 

Shackeldord, Patti ML15154C224 

Shade, Lynne ML15159B021 

Shade, Patricia ML15159B063 

Shadle, Linda ML15154A567 

Shafchuk, Patsy ML15148A204 

Shaffer, Susan ML15160A950 

Shalat, Harriet ML15155B687 

Shaller, Virginia ML15141A739 

Shallman, Elsy ML15140A121 

Shanahan, Pat ML15159A060 

Shanahan, Timothy ML15154A149 

Commenter 

ADAMS 

Accession # 

Shandruk, Maria ML15141A581 

Shane, Nancy ML15153B057 

Shank, Ronald ML15155B081 

Shankel, Georgia ML15153A595 

Shanker, Adrian ML15159B069 

Shanley, Karen ML15148B051 

Shanley, Susan ML15153B026 

Shapira, Susan ML15155B773 

Shapiro, Claudia ML15156A172 

Shapiro, Irving ML15154A696 

Sharee, Donna ML15155A782 

Sharif-Coon, Dawn ML15148A874 

Sharkey, Virginia ML15142A279 

Sharlock, Leslie ML15155A309 

Sharp, Kathryn ML15155A389 

Sharpnack, Sherry ML15148A876 

Shaum‐Amberg, Shel ML15154A095 

Shauver, Charles ML15159A933 

Shaver, Tammy ML15158A122 

Shaw, Janice ML15154C152 

Shaw, Mary ML15154A217 

Shea, Mary ML15155C216 

Shealy, Richard ML15156A025 

Shear, Julie ML15155B618 

Sheehy, Linda ML15153B021 

Sheehy, Steve ML15159B280 

Sheets, Aida ML15154A227 

Sheets, Gabriel ML15162B079 

Sheets, Gabriel ML15162B125 

Sheffer, Jeanne ML15154B298 

Sheffield, Michael ML15147A748 

Sheldan, Vijay ML15141A426 

Shelton, Kacie ML15155A066 

Shematek, Judith ML15154A334 

Shemo, Mary-Alice ML15159B288 

Shepherd, James ML15155A092 

Shepherd, Marilyn ML15156A509 

Shepler, Larry ML15155A806 

Sheppard, S. ML15160A866 

Sheridan, Ian ML15155B396 

Sheridan, Michelle ML15159A863 

Sherman, Stephanie ML15140A234 

Sherman, Trisha ML15159A013 

Shermock, Margaret ML15160A742 

Sherrard, Kathryn ML15154A167 

Sherwin, Boyce ML15155A264 

Sherwood, Kate ML15155B055 

Shields, Juli ML15159B281 

Shiels, Theresa ML15153B087 

Shifflett, Jr., James E. ML15148B367 

Shimaoka, Earl ML15147A766 

Shimasaki, Ewa ML15154B895 

Shinn, Michon ML15153A965 

Shipe, Kathleen ML15159B428 

Appendix E October 2016 E-623 NUREG–2176
Commenter 

ADAMS 

Accession # 

Shipley, Doraine ML15155A735 

Shipley, Renee ML15154B772 

Shippee, Robert ML15142A104 

Shirey, Elizabeth ML15155B067 

Shirey, William ML15154A292 

Shively, Judy ML15154A712 

Shivers, Dennis ML15155A801 

Shocair, Abla ML15159A134 

Shoffner, Elizabeth ML15142A154 

Shoham, Amit ML15155A540 

Shook, James ML15148A248 

Shook, Philip ML15153A924 

Short, John ML15162B145 

Short, John ML15162B091 

Short, Kimberly ML15155A513 

Shotwell, Andreia ML15148B267 

Shoup, Wendy ML15154B551 

Showell, Sada ML15141A734 

Shreve, Rick ML15153B172 

Shuben, Jeffrey ML15155A263 

Shubert, Stephen ML15153B219 

Shuler, Margaret ML15142A149 

Shult, Donald ML15154B285 

Shultz, Betty Jane ML15148B190 

Shultz, Jamie ML15154A857 

Shultz, Linda ML15158A104 

Shumaker, H. Dennis ML15155A717 

Shurtleff, Blair ML15159A784 

Shuster, Marguerite ML15155A792 

Shutkin, Sara ML15155A075 

Shutt, John ML15155A127 

Siano, Christiaan ML15141A780 

Sibelman, Grae ML15155A366 

Siddiqi, Marilyn ML15156A839 

Siddique, Omar ML15154B271 

Siddiqui, Saad ML15154C200 

Sidofsky, Carol ML15158A288 

Siebe, Martha ML15159A923 

Siebert, Simone ML15155B041 

Sieck, Joanne ML15159A318 

Siegel, Christa ML15154A032 

Siegel, Richard ML15148B103 

Siegner, Sandra ML15159A795 

Siegwald, Joan ML15159A024 

Sigler, Teri ML15160A058 

Sihmund, Bob ML15148A781 

Sihmund, Bob ML15148A888 

Sihmund, Bob ML15154A666 

Sikand, Vikram ML15158A027 

Silan, Sheila ML15154B669 

Sill, Marjorie ML15153A507 

Silodor, Steven ML15155B985 

Silva, Stephanie ML15154A791 

Silvano, Liliana ML15161A648 

Commenter 

ADAMS 

Accession # 

Silverman, Goldie ML15147A729 

Silvers, Margaret ML15153B211 

Silversmith, Linda ML15156B237 

Silvestre, Béatrice ML15153A692 

Silvey, Kevin ML15154B016 

Simioni, Marco ML15159B436 

Simmerman, Scott ML15158A216 

Simmons, Amber ML15154B694 

Simmons, Chris ML15154A129 

Simon, Elaine ML15147A765 

Simon, Philip ML15159A870 

Simon, Richard ML15147A740 

Simonds, Barbara ML15154B953 

Simonds, Linda ML15159A258 

Simone, Louise ML15158A083 

Simone, Louise Pisano ML15159A292 

Simonich, Claire ML15153B096 

Simpson, Eric ML15148A701 

Simpson, Gary ML15154C017 

Simpson, Malcolm ML15154B274 

Simpson, Rusty ML15159B488 

Simpson, Sally ML15156A268 

Sims, Amber ML15159A902 

Sims, Cindra ML15156A878 

Sims, Mary ML15148B070 

Simson, Jo Anne ML15140A207 

Singer, Barbara ML15153A736 

Singleton, Jon ML15156A876 

Siniard, Susan ML15140A288 

Sininger, Kathy ML15148B152 

Sink, Randle ML15156B374 

Sircar, Subrata ML15154B896 

Sirias, Christine ML15160A788 

Sisk, Sidney ML15148B147 

Sisson, Valerie Chipman ML15148B172 

Sisti, Susan ML15159A049 

Sitnick, Joan ML15140A243 

Sitton, Mary ML15148B276 

Sivley, Steve ML15154B304 

Sixtus, Michael ML15155A133 

Sjoberg, Jon ML15159B570 

Skeele, Michele ML15160A727 

Skerry, Priscilla ML15155A183 

Skews, Geoff ML15155A884 

Skinner, Richard ML15148B177 

Skinner, Russell ML15159A360 

Skipworth, Carl ML15142A088 

Skirvin, Katherine ML15162B079 

Skirvin, Katherine ML15162B123 

Skirvin, Laurence ML15158A041 

Sklute, Stacey ML15148B375 

Skoczek, Christianna ML15159A028 

Skolnick, Kate ML15153A357 

Skotnes, Darren ML15153B193 

Appendix E NUREG–2176 E-624 October 2016
Commenter 

ADAMS 

Accession # 

Skouge, Gloria ML15153B248 

Skowronski, Audrey ML15148A739 

Skowronski, Edmund ML15154A415 

Skowronski, Joan ML15154A336 

Skutches, Gregory ML15141A754 

Slack, Debbie ML15148B083 

Slack, Esward ML15148B052 

Slade, Colette ML15156A916 

Slater, Ruth ML15141A586 

Slaton, Marina ML15154A967 

Slawinski, Katherine ML15159A352 

Sleeth, Janet ML15158A185 

Slemenda, Joseph ML15154C292 

Sletten, Greg ML15158A006 

Sleva, Cathy ML15154C039 

Slisher, Rebecca ML15155B054 

Sloane, Kenneth ML15159A416 

Slote, Karen ML15148B123 

Slote, Karen ML15154B253 

Small, Sharon ML15162A664 

Smallwood, Tracey ML15148A940 

Smarr, Todd ML15155A754 

Smereck, Amy ML15156B046 

Smestad, Gloria ML15153B239 

Smit, Marilyn ML15159B439 

Smith and Hill, Lynn and 

EdwRd ML15154B342 

Smith, Adrian ML15159A419 

Smith, Angela ML15148A835 

Smith, Anita ML15154B719 

Smith, Barbara ML15156A728 

Smith, Beverly ML15140A231 

Smith, Bradley ML15154A264 

Smith, Brooke ML15153A570 

Smith, Cambria ML15155A630 

Smith, Christopher ML15158A234 

Smith, Cynthia ML15154B184 

Smith, David ML15153B034 

Smith, David L. ML15155B679 

Smith, Dea ML15153B156 

Smith, Diana ML15156A543 

Smith, Dylan ML15154B751 

Smith, Earl ML15148B275 

Smith, Elizabeth ML15155B767 

Smith, Indira ML15155C138 

Smith, J. T. ML15153B047 

Smith, James ML15142A209 

Smith, James ML15142A357 

Smith, Janet ML15156B013 

Smith, Janice ML15159B361 

Smith, Jean ML15154A607 

Smith, Jeannie ML15156A920 

Smith, Jeff ML15141A617 

Smith, Jennifer ML15142A323 

Commenter 

ADAMS 

Accession # 

Smith, John ML15155A678 

Smith, Julie ML15142A326 

Smith, Karen ML15148B300 

Smith, Keelan ML15148B169 

Smith, Kellie ML15156B120 

Smith, Kenneth ML15153B249 

Smith, Kevin ML15156A918 

Smith, Kristin ML15148A788 

Smith, Leslye ML15159A141 

Smith, Lisa ML15153B191 

Smith, Lloyd ML15156A216 

Smith, Lori ML15141A600 

Smith, Lynette ML15142A277 

Smith, Madeline ML15160A963 

Smith, Marilyn ML15155A134 

Smith, Mary Ann ML15153A412 

Smith, Mary Ann ML15154B322 

Smith, Maureen ML15159A062 

Smith, Neill ML15159B381 

Smith, Pamela ML15155A184 

Smith, Ray ML15148B013 

Smith, Raya ML15162A158 

Smith, Sandra ML15159A133 

Smith, Sarah ML15161A619 

Smith, Steven ML15155A783 

Smith, Stevew ML15155C248 

Smith, Stevew ML15156B052 

Smith, Suzanne ML15160A061 

Smith, Valerie ML15154B865 

Smith, Vernon ML15147A743 

Smith, Walter ML15156A987 

Smith, William ML15140A041 

Smith, Yvonne ML15154A007 

Smithberger, Dana ML15154B644 

Smock, Amanda ML15160A556 

Smoker, Art ML15154A948 

Smolarski, Ronald ML15155A268 

Smukler, Marguerite ML15156B252 

Smyke, Pete ML15148B026 

Smythe, Ana ML15155A878 

Smythe, Richard ML15155A202 

Smythe, Stewart ML15156A964 

Sneiderman, Arthur ML15159A719 

Snell, Karen ML15154C218 

Snider, Darleene ML15155B866 

Snider, Jay ML15153A431 

Snook, Richard ML15154C047 

Snow, Patricia ML15155A271 

Snowdon, Hilton ML15159B350 

Snyder, Joanne ML15154A230 

Snyder, John ML15141A688 

Snyder, Kristina ML15161A668 

Snyder, Laura ML15153A816 

Snyder, Lynn ML15156B242 

Appendix E October 2016 E-625 NUREG–2176
Commenter 

ADAMS 

Accession # 

Snyder, Nancy ML15159A867 

Snyder, Robert ML15155B659 

Snyder, Sheri ML15159A323 

Snyder, Ted ML15156B044 

Snyder, Warren ML15159A951 

Soar, Anita ML15155A138 

Sobanski, Sandra ML15156A019 

Sobel, Michael ML15156A188 

Sobel, Scott ML15142A255 

Soddy, Diane ML15155B007 

Soddy, Diane ML15155B782 

Soenksen, Mark ML15142A166 

Sogorka, Amber ML15153B204 

Sohl, Erica ML15159A746 

Sokolove, Harold ML15155B810 

Solano, Nicole ML15142A356 

Solaris, Laila ML15153A908 

Soler, Sandra ML15142A103 

Solesby, Eli ML15155B320 

Solomon, Karen ML15153B165 

Solum, Mary ML15154A463 

Somers, Mary ML15155A178 

Sommer, Kenna ML15154A819 

Sommie, Lee ML15153B186 

Sondgerath, Bob ML15158A192 

Sonker, Jennifer ML15153A439 

Sonnenblick, Rachel ML15155A803 

Sons, Lisa ML15159B358 

Sorano, Jessica ML15159A535 

Sorensen, Anna ML15159B559 

Sorensen, Barbara ML15155A470 

Sorensen, Elaine ML15155A843 

Sorensen, Gary ML15162A713 

Sorenson-Banavathu, Tina ML15162B089 

Sorenson-Banavathu, Tina ML15162B139 

Sorlucco, Lucy ML15154B100 

Sortland, Joyce ML15155C082 

Sosa, Gabriela ML15141A678 

Sosa, Madeline ML15154A373 

Soto, Edy G. ML15141A695 

Sotomayor, Nora ML15156A162 

Soucek, Paul ML15159A011 

Southwick, Christine ML15148A969 

Souza, Julie ML15158A078 

Sowards, Michael ML15156A132 

Sozio, Jeanne ML15156A117 

Spachidakis, Theodore ML15160A874 

Spada, Victor ML15156A983 

Spadoni, Michael ML15153A869 

Spady, William ML15155B345 

Spain, Steve ML15155B317 

Spak, Margaret ML15162A287 

Spalding, Jann ML15142A101 

Spangler, Steve ML15154A045 

Commenter 

ADAMS 

Accession # 

Spann, Bridget ML15154A155 

Spanogle, Vicki ML15154A704 

Sparks, Dana ML15142A307 

Sparlin, Shauna ML15156A128 

Spaulding, Stephen ML15148B105 

Spears, Harvey ML15154C124 

Speciale, Samuel ML15153A610 

Species, Scott ML15155A462 

Speed, Janice ML15159A553 

Speer, Cheryl ML15155A357 

Speicher, Sandra ML15156A432 

Speidel, Kurt ML15155A441 

Spencer, Carole ML15155A249 

Spencer, Jeremy ML15148B222 

Spencer, Kathleen ML15156A954 

Spencer, Martha ML15160A876 

Spencer, Sheila ML15153A360 

Spengler, Jennifer ML15162A657 

Speno, Charlie ML15148A180 

Spera, Kathy ML15154A881 

Spevak, Edward ML15142A099 

Spiegel, Edwyna ML15154A226 

Spiegel, Kimberly ML15159B041 

Spielmann, Edda ML15148B407 

Spillman, Aileen ML15142A343 

Spitzer, Laura ML15154B860 

Spivack, Susan ML15161A634 

Spohn, Dena ML15156A781 

Spokony, Irving ML15142A176 

Spong, Timothy ML15156A846 

Spradlin, Karen ML15153B093 

Spragins, John ML15148A800 

Sprague, Jeanne ML15159B151 

Sprano, Barbara ML15162B147 

Spreitzer, Francis ML15153A495 

Springer, Cynthia ML15154A011 

Springer, Steven ML15153A809 

Spry, Tom ML15156A582 

Squires, Emma ML15153B042 

St. Angelo, R. ML15154C287 

St. Clair, Sharyn ML15154A244 

St. Germaine, Gerald ML15155B566 

Staats, Jean ML15155A521 

Stabler, Jessica ML15155A307 

Stachnik, Holly ML15156A053 

Stadler, Debra ML15155B187 

Staff, George ML15159B524 

Stall, John ML15156A847 

Stallings, Kenneth ML15142A181 

Stalter, Marlene ML15153A377 

Stamer, Lou ML15155B848 

Stamm, Karen ML15142A275 

Stamm, Nancy ML15148A136 

Stamps, Gail ML15155B183 

Appendix E NUREG–2176 E-626 October 2016
Commenter 

ADAMS 

Accession # 

Stan, Talila ML15148B243 

Stanberry, Beth ML15159A074 

Standley, Dawn ML15153A947 

Standley, Ron ML15153B272 

Stanley, Norm ML15154C279 

Stanley, Richard ML15155B694 

Stansbury, Angelica ML15156B189 

Stansfield, Jack ML15155B056 

Stansill, Sally ML15155B437 

Stantial, Linda ML15154B872 

Stanton, Liana ML15154B898 

Stanton, Lisa ML15156A526 

Stapelfeldt, Horst ML15155C071 

Stapler, Carl ML15155B554 

Stapp, Laci ML15155C123 

Star, Star ML15158A184 

Starbuck, Stanley ML15148B446 

Stark, Katharine ML15153A466 

Stark, William ML15153A568 

Starling, Richard ML15158A088 

Starr, David ML15140A012 

Starr, Joan ML15156B089 

Starrett, Nancy ML15142A081 

Starz, Mary ML15147A783 

Stasey, Joseph ML15154B843 

Stassinopoulas, George ML15154A234 

Staton, Janiece ML15154B031 

Statts, Jeffrey ML15162A661 

Stauber, Michael ML15153B164 

Stavis, Alex ML15155A862 

Stawinoga, Greg ML15148B444 

Stay, Chris ML15162B079 

Stay, Chris ML15162B128 

Steadmon, Jason ML15154C021 

Stearney, Fern ML15159A529 

Stedman, Matt ML15148A993 

Steele, Cheryle ML15155B604 

Steele, Mary ML15162A225 

Steele, William ML15148A638 

Steers, Sandra ML15153A653 

Steets, Diane ML15156A130 

Steeves, Charleen ML15156A914 

Stefacek, Laura ML15154A876 

Stefanich, Rosalie ML15154C005 

Stefano, Courtney ML15155B512 

Steffen, Heidi ML15142A228 

Steffen, Melanie ML15161A641 

Stehle, Alice ML15154B246 

Steiger, Bonnie ML15162B106 

Steiger, Bonnie ML15162B064 

Steil, Ashleigh ML15159B345 

Stein, Dennis ML15153B064 

Stein, Herbert ML15156A778 

Stein, Renee ML15155C127 

Commenter 

ADAMS 

Accession # 

Steinauer, Kay ML15154B173 

Steinberg, Jack ML15154C203 

Steinberg, Tara ML15142A022 

Steinbrecher, Klaus ML15155C136 

Steinbrink, Nancy ML15153A941 

Steiner, A. L. ML15154A254 

Steinfeld, Naomi ML15158A066 

Steinhardt, Helene ML15153B023 

Steinhart, Carol ML15142A115 

Steininger, Lorenz ML15148B054 

Steininger, Robert ML15159A823 

Steinle, Sandra ML15154A735 

Steinmetz, Cindy ML15154C264 

Stellato, Pat ML15155C160 

Stenflo, Jahnavi ML15154B289 

Stenseth, Carolyn ML15155A828 

Stephan, Elise ML15148A953 

Stephens, Chandra ML15155B989 

Stephens, John ML15153A359 

Stephens, Robert ML15154A867 

Steppan, Linda ML15160A922 

Sterling, Keir ML15154B842 

Stern, Les ML15155A291 

Stern, Richard ML15141A654 

Sternberg, Karin ML15142A043 

Sterner, Jim ML15154C268 

Sterzing, H. Keith 

Mephodie ML15155B635 

Stetser, Ann ML15155A004 

Steva, Megan ML15155A091 

Stevens, Dennis ML15154A929 

Stevens, Earl ML15148A986 

Stevens, Earl ML15154A778 

Stevens, Eugenia ML15160A885 

Stevens, Gavi ML15158A065 

Stevens, Lisa ML15156A898 

Stevens, M. ML15158A213 

Stevens, Wendy ML15156A477 

Stevenson, Kenneth ML15155A414 

Stevenson, Nadine ML15140A144 

Stevenson, Timothy ML15162A730 

Stewart, Berkeley ML15155A990 

Stewart, Betty ML15156A006 

Stewart, Jack ML15155A236 

Stewart, Margie ML15156A513 

Stewart, Michael ML15159B389 

Stewart, Rebecca ML15159A937 

Stewart, Ruth ML15155B015 

Stewart, Sharron ML15154B125 

Stewart, Shelli ML15146A369 

Stewart, Stephanie ML15154B622 

Stickel, Ann ML15153A651 

Stickney, John ML15155A057 

Stickney, Karen ML15154B559 

Appendix E October 2016 E-627 NUREG–2176
Commenter 

ADAMS 

Accession # 

Stieber, Frank ML15148B134 

Stieglitz, Joseph ML15159B546 

Stiehl, Joanna ML15159A664 

Stierlen, Lorelei ML15155B398 

Stierli, Edward ML15148A232 

Stiff, Gina ML15148A921 

Stiff, Gina ML15154B243 

Stiles, Sarah ML15156B003 

Stime, Denise ML15159B407 

Stimmer, Sonja ML15153A695 

Stimpson, Lisa ML15142A231 

Sting, Gloria ML15156B034 

Stinson, Georgia ML15156A962 

Stinson, Loree ML15154A679 

Stiteler, Ellin ML15141A443 

Stocker, Nancy ML15162B105 

Stocker, Nancy ML15162B042 

Stocker, Thomas J. ML15155B580 

Stockman, Sharon ML15160A946 

Stocks, Lawrence ML15158A262 

Stoddard, Eric ML15155C145 

Stoddard, Wade ML15141A577 

Stoffel, Patrick ML15156B263 

Stokes, Bettina ML15154A118 

Stoltenberg, John ML15154A114 

Stone, James ML15148A627 

Stone, Jane ML15154B771 

Stone, Kelly ML15159A782 

Stone, Lisa ML15141A539 

Stone, Mary ML15159A282 

Stone, William ML15153B101 

Stoneback, Sharon ML15159A345 

Stoneburner, Barb ML15148A196 

Stonehawk, Mikerra ML15148A925 

Stoner, Dorothy ML15162A224 

Stonier, Polly ML15155B980 

Stonington, Louise ML15140A238 

Stoops, William ML15159A841 

Story, Shirley ML15156B427 

Story, Tiffany ML15155B178 

Story, Tiffany ML15158A136 

Stout, Karen ML15155C104 

Stout, Keri ML15154C074 

Stout, Kristen ML15156A137 

Stowers, Carol ML15148B079 

Strack, Daniel ML15155B669 

Strahan, Estha ML15155A112 

Strailey, Faith ML15148A718 

Strain, Darren ML15156A199 

Strand, Emmorette ML15154A325 

Stransky, Charles ML15155B795 

Strate, Kris ML15158A113 

Strauss, John ML15162A426 

Strauss, Nancy ML15155A911 

Commenter 

ADAMS 

Accession # 

Strawn, Mike ML15159B298 

Strayer, Rosa ML15148A822 

Strear, Nancy ML15154B072 

Street, Diena ML15142A100 

Street, Patty ML15159A374 

Strehlow, Jennifer ML15160A897 

Streur, Devin ML15154B329 

Stricker, Robert ML15155A667 

Strickland, Carolyn ML15159A087 

Strickland, Jennifer ML15141A728 

Stril, Jean ML15156A317 

Stringer, David Allen ML15159A300 

Strom, Theresa ML15156A239 

Stromberg, Patricia ML15155B384 

Stromfeld, Andrew ML15155C156 

Strong, Ann ML15155A474 

Strong, Daniel ML15156B209 

Strong, Grace ML15154A078 

Strouble, Jackie ML15156B019 

Stroupe, Kerri ML15154C273 

Strowd, Carl ML15156A310 

Strowd, Richard ML15154B090 

Strum, Cathy ML15154B334 

Strzesak, Jacqueline ML15159A029 

Stuart, Connie ML15155A036 

Stuart, Michael ML15155B621 

Stucker, Melinda ML15148A780 

Stuckey, Richard ML15142A179 

Stuebben, Angela ML15156A316 

Stulb, Jeanne ML15141A741 

Stulman, Esther ML15154B191 

Stumpf, Lawrence ML15155B436 

Sturek, Doshia ML15155B266 

Sturm, Sabine ML15153B090 

Stutes, Earl ML15160A600 

Stutz, Susan ML15155A787 

Styles, Ronda ML15159A455 

Su, Donna ML15153A784 

Suarez, Moraima ML15155B704 

Suchenicz, Carolyn ML15159A272 

Suda, Maryska ML15155A659 

Suess, Gillian ML15155A116 

Suggs, Magdaline ML15160A731 

Suit, Karen ML15155A368 

Sullenberger, Nathan ML15155A908 

Sullivan, Barbara ML15155A299 

Sullivan, Carol ML15156B335 

Sullivan, Denise ML15155A978 

Sullivan, Diane ML15156A793 

Sullivan, Molly ML15160A055 

Sullivan, Tad ML15153B304 

Sullivan, Teresa ML15153A329 

Sullivan, Tom ML15156A639 

Sumida, Kaytee ML15141A798 

Appendix E NUREG–2176 E-628 October 2016
Commenter 

ADAMS 

Accession # 

Summers, Lela ML15141A540 

Sumners, Robyn ML15153A844 

Sunada, Kristin ML15156B030 

Sunada, Kristin ML15154B385 

Sundarajan, Aditi ML15154B851 

Sunderland, Melissa ML15155A032 

Sunderland, Violet ML15154A119 

Sundquist, W. ML15153B033 

Sutherland, John ML15158A210 

Sutkowski, John ML15154B297 

Sutliff, Leslie ML15148B108 

Sutphin, Madelaine ML15156A838 

Suyehara, Erin ML15155B855 

Svare, Marlys ML15153A821 

Svec, Bonnie ML15154B218 

Svensson, Bo ML15154A242 

Swaim, Lauren ML15155B138 

Swaim, Lenore ML15141A767 

Swain, Aimee ML15147A753 

Swain, Robert and Mary ML15159B128 

Swall, Don ML15156A210 

Swan, Cate ML15159A035 

Swan, Susan ML15160A878 

Swaney, Sharon ML15155A186 

Swank, Carrie ML15141A518 

Swank, Phyllis ML15148B186 

Swanson, Lesllie ML15140A255 

Swanson, Lorraine ML15156A647 

Swanson, Michael ML15142A306 

Swanson, Ricki ML15159B220 

Swanson, S. ML15140A033 

Sweazea, Alan ML15155B085 

Sweeney, John Gideon ML15154B477 

Sweeney, Wesa‐Asgaya ML15156A511 

Sweet, Kirsten ML15155A969 

Sweet, Timothy ML15160A881 

Sweetland, Daisy ML15154B252 

Sweetling, William ML15154A087 

Sweeton, Margaret ML15154A763 

Swem, Earl Gregg ML15159B130 

Swendrowski, Mike ML15154B353 

Swensen, Harry ML15159A731 

Swenson, Keith ML15155B490 

Swenson-Zakula, Kimberly ML15159A619 

Swick, Chelsea ML15155B656 

Swiencicki, John ML15154B823 

Swimsaway, Crow ML15153A485 

Swindell, Elak ML15154B054 

Swindle, Terri ML15156B230 

Swinehart, Lorin ML15148A593 

Swoffer, Tom ML15153A864 

Sydor, Oleh ML15153A762 

Syed, Mushtaq ML15155A431 

Symcox, Geoffrey & Linda ML15156B033 

Commenter 

ADAMS 

Accession # 

Symonds, Allen ML15154C142 

Symonds, Russell ML15162B079 

Symonds, Russell ML15162B122 

Sytzko, Victor ML15153A863 

Syverson, Janelle ML15154B163 

Szabo, Joseph ML15160A845 

Szabo, Liz ML15155A298 

Szabo, Liz ML15155B617 

Szumal, Raymond ML15156A105 

Szymanowski, Paul ML15156B341 

Szymczak, Nancy ML15153A898 

Szymczyk, Mary ML15154A444 

Szyszka, Lawrence ML15159A586 

T., C. ML15155B832 

T., Randy ML15153A943 

Taber, Gloria ML15162A097 

Tabor, Kris ML15154B880 

Taffany, Laura ML15155C184 

Taft, Robert ML15155A979 

Tagawa, Ann ML15158A286 

Taggart, Carol ML15155B522 

Tait, Ann ML15148A214 

Takatsch, Julie ML15153A804 

Talbot, James ML15142A087 

Taliano, Ronald ML15155A192 

Talkington, Wendy ML15148A645 

Tallant, Deenie ML15156A074 

Talleagle, David ML15155B887 

Tamargo, Jorge J. ML15154A542 

Tamulen, Karin ML15153A858 

Tangen, Beverly ML15154A003 

Taniwaki, Marge ML15162A726 

Tankersley, Janice ML15141A797 

Tann, Rosemary ML15159A004 

Tann, Rosemary ML15159A071 

Tanner, Marjorie ML15155B638 

Tanner, Phillip ML15148A182 

Tansey, Paulette ML15154A156 

Tapiero, Abel ML15142A049 

Taplin, Helen ML15155A853 

Tapp, Elizabeth ML15162A241 

Tappen, Amy ML15154B981 

Tarallo, Mary ML15154C095 

Tarantino, Ethel ML15156B010 

Tarkington, Victoria ML15154B300 

Tarkowski, Brenda ML15160A667 

Taroli, Garry ML15141A510 

Tarpley, Matthew ML15153B091 

Tasker, David ML15153A551 

Tassell, Bruce Van ML15154A200 

Tate, Nancy ML15148A982 

Tatom, Andy ML15159A097 

Tatum, Elizabeth ML15141A630 

Tatum, Elizabeth ML15154B639 

Appendix E October 2016 E-629 NUREG–2176
Commenter 

ADAMS 

Accession # 

Tauriainen, Michael ML15159A498 

Taylor, Audrey ML15156A208 

Taylor, Barbara ML15155A226 

Taylor, Jackie ML15153B223 

Taylor, Kelly ML15159B308 

Taylor, Kirk ML15155B906 

Taylor, Nancy ML15159B431 

Taylor, Robyn ML15160A860 

Taylor, Stephen ML15155C141 

Taylor, Tim ML15160A793 

Tays, Shawn ML15153B181 

Teasley, Regi ML15162A061 

Teason, Christine ML15159A806 

Tedesco, Frances ML15155B631 

Tedesco, Terry ML15155B601 

Tedesco, Terry ML15159B076 

Tedesco-Kerrick, Terry ML15159B402 

Teel, Shannon ML15148B173 

Teeter, Keith ML15154B838 

Teevan, John ML15154C126 

Tefertiller, Staci ML15153B253 

Tegtmeier, Diane ML15153A757 

Tehan, Patricia ML15158A098 

Teibloom, Joel ML15155A737 

Telfair, II, Ray C. ML15148B299 

Teli, Ann Marie ML15153A971 

Telleen, Melany ML15153B217 

Tempelman, Steven ML15158A004 

Temple, Michele ML15148A763 

Templeton, Todd ML15153A990 

Tenaglia, Carol ML15156A757 

Tenerelli, Brenda ML15142A141 

Tennant, Allie ML15153A416 

Tennen, Laura ML15153A817 

Tennen, Sylvia ML15153A855 

Tennen, Sylvia ML15155A778 

Tenney, Joanne ML15155A633 

Teresi, Fran ML15154B430 

Tergesen, Ron ML15155A713 

Terleski, Margaret ML15155A362 

Terriault, Michelle ML15154A660 

Terrock, Jennifer ML15141A652 

Terry, Clifford ML15148A657 

Terry, Michael ML15155B124 

Tesch, Charlie ML15156B001 

Tetarenko, Pamela ML15154A479 

Tetro, Barbara ML15155A823 

Teunissen, Christina ML15147A708 

Tevelow, Carla ML15155C143 

Tevis, Eleanora ML15156B310 

Thackrey, Gale ML15153B103 

Tharp, Reynold ML15154C087 

Thayer, Mostyn ML15155B844 

The U. Family, ML15156A245 

Commenter 

ADAMS 

Accession # 

The U. Family, ML15156A251 

Theard, Lauren Pacheco ML15148A968 

Theroux, Rosemary ML15159A614 

Therrien, Theresa ML15154B118 

Thibault, Gail ML15140A226 

Thiel, Mary Martha ML15154B354 

Thiess, Fred ML15159A115 

Thing, Susan ML15155B027 

Thomas, John ML15154B785 

Thomas, Bev ML15153A873 

Thomas, Caren Crronk ML15148A666 

Thomas, Denise ML15159A858 

Thomas, Eva ML15154A873 

Thomas, Gina ML15154A993 

Thomas, Helen ML15158A022 

Thomas, James ML15148A708 

Thomas, Jeffrey ML15148B077 

Thomas, Kimberly ML15156A322 

Thomas, Lisa ML15161A620 

Thomas, P. ML15155A318 

Thomas, Patte ML15154B944 

Thomas, Robert ML15154C195 

Thomas, Rochelle ML15155B404 

Thomas, Toni ML15156B195 

Thomas-Hill, Pam ML15155A237 

Thomason, Anita ML15154B776 

Thomason, Sharon ML15159A349 

Thomas-Virnig, Christina ML15155A086 

Thompson, Beverly ML15160A525 

Thompson, Dave ML15162A237 

Thompson, Douglas ML15153A690 

Thompson, Jackie ML15148B428 

Thompson, Jeremy ML15161A674 

Thompson, Keith ML15148A769 

Thompson, Mark ML15162A423 

Thompson, Muhammad ML15156A270 

Thompson, Robert ML15154B255 

Thompson, Roberta ML15154C194 

Thompson, Sally ML15154A312 

Thompson, Susan ML15156A723 

Thomsen, Donna ML15148B012 

Thorington, Helen ML15153A536 

Thornburg, Merrie ML15156A127 

Thorne, Eugene ML15155A338 

Thornell, Nigel ML15155A511 

Thornsbury, Jean ML15141A624 

Thornton, Laura ML15142A245 

Thornton, Robyn ML15159B550 

Thorsen, Einar ML15154A460 

Thrailkill, Jim ML15154C199 

Thrower, Michelle ML15155A180 

Thrush, J. ML15155A245 

Thurman, Anna ML15156B504 

Thurn, Clement ML15161A702 

Appendix E NUREG–2176 E-630 October 2016
Commenter 

ADAMS 

Accession # 

Tiarks, Daniel ML15148B104 

Tiaven, Marilyn ML15154A135 

Tibbets, Linda ML15153A866 

Tice, Janet ML15158A183 

Tichman, Nadya ML15154A830 

Tidwell, Marion ML15155A312 

Tieso, Jovita ML15162A244 

Tiessen, Grace ML15156A771 

Tildes, Katherine ML15156B429 

Till, Mary Ann ML15154C244 

Tilley, Justine ML15148A709 

Tillinghast, Audrey ML15156A599 

Timberlake, Ralph ML15160A889 

Timm, Jill ML15155A098 

Timm, Richard ML15155B109 

Timmerman, Don ML15159B521 

Tindol, Lolly ML15155C060 

Tine', Tina ML15156A169 

Tingle, Brian ML15142A321 

Tinsley, Brenna ML15159A766 

Tisdell, Jennifer ML15153B151 

Tizard, Thomas ML15154A043 

Tobias, Alice ML15159A371 

Tobias, Christopher ML15155C200 

Tobin, Ralph ML15155A230 

Tobolski, Kelly ML15159B332 

Todaro, Tom ML15153B010 

Todd, Miranda ML15158A148 

Todd, Nic ML15154B834 

Todd, Victoria ML15155B457 

Todisco, Michael ML15156A304 

Toelle, Sherry ML15155A160 

Toft, Carolyn ML15156B125 

Toigo, Joe ML15155B627 

Tokunaga, Barb ML15156A445 

Toledo, Justin ML15155B982 

Tolerico, Joseph ML15154B753 

Tollefson/Conard, Margot ML15154A251 

Tolley, Mark ML15154B959 

Tomaselli, Susan ML15156B231 

Tomasello, Pela ML15155C093 

Tomlinson, Michael ML15153B120 

Tompetrini, Phil ML15159B113 

Tompkins, Greg ML15159B573 

Toms, Gary ML15156A546 

Tonkin, Gary ML15156A189 

Tonsing, Richard ML15154B306 

Toobert, Michael ML15155B113 

Toone, James ML15153A742 

Tootell, Joan ML15158A051 

Torchenot, Ferold ML15141A773 

Torchenot, Ferold ML15147A760 

Torres, Andrea ML15148A873 

Torres, Joe ML15141A782 

Commenter 

ADAMS 

Accession # 

Torres, Susan ML15148B067 

Torres‐Ortiz, Ramon ML15156B095 

Torrette, Ron ML15159A108 

Torsander, Camilla ML15160A760 

Torsander, Camilla ML15160A760 

Toscani, Maureen ML15162A575 

Tosney, Kathryn ML15153A911 

Toth, James ML15154B946 

Tousley, Kay ML15156B454 

Tovar, John ML15158A152 

Towers, Gloria ML15154A142 

Towner, Erline ML15146A237 

Townsend, Carlos ML15159A932 

Townsend, Darlene ML15153A700 

Townsend, Darlene ML15153A830 

Townsend, Peter ML15153B146 

Townshend, Elisa ML15141A647 

Toy, James ML15156B475 

Toy, Mary Ann ML15156A698 

Tozzi, Sharon ML15141A594 

Tracy, Anne ML15155B222 

Tracy, Steven ML15155C167 

Tracz, Gordon ML15154A457 

Trafficante, Michelle ML15148B284 

Tran, Danielle ML15159A845 

Tran, Kim ML15155B961 

Tran, Sheila ML15154A019 

Trask, David ML15162B079 

Trask, David ML15162B143 

Tratolatis, Denise ML15159B250 

Trauth, Beti ML15159A859 

Traveler, Calum ML15140A281 

Travis, Judi ML15153A321 

Travis-Morgan, Donna 

Mae ML15154B997 

Trawitzki, Tony ML15153A901 

Treadwell, Phyllis ML15153B053 

Tredinnick, Catherine ML15153B158 

Tregidgo, Richard ML15154B617 

Trela, Christine ML15154B730 

Tremmel, Leonard ML15142A350 

Trevillian, Linda ML15153A959 

Trevillion‐Hill, Mary Ann ML15153B194 

Triana, Antonio ML15155A090 

Trice, Tina ML15155C157 

Trico, Sher ML15159A925 

Trilles, Tangi ML15159A824 

Trimm, James ML15156A114 

Trinque, Eric ML15155B016 

Trotta, Anthony ML15162A600 

Trotta, Kevin ML15141A663 

Troy, Gail ML15154A602 

Truax, Wayne ML15155C227 

Trudeau, Christine ML15154A382 

Appendix E October 2016 E-631 NUREG–2176
Commenter 

ADAMS 

Accession # 

Trudeau, Christine ML15154B922 

True, Mary ML15159A085 

Truland, David ML15154B948 

Trumann, C. ML15158A230 

Trumbull, Ramon ML15155B200 

Trybus, Marilyn ML15155C147 

Tryggeseth, Jackie ML15155A861 

Trykowski, Denay ML15154B702 

Trykowski, Lonni ML15155B997 

Tsung, Dia ML15155B840 

Tuch, Christopher ML15155B185 

Tucker, Arlen ML15160A751 

Tucker, Jessica ML15156A098 

Tucker, Kathleen ML15154B716 

Tucker, Lynn ML15156B319 

Tucker, Robert ML15154C090 

Tuckerman, Peter ML15155C177 

Tuckett, Natasha ML15159A994 

Tudor, Doina ML15154B816 

Tugwell, Thomas ML15153B071 

Tulloch, Mary ML15155A058 

Tuman, Susan ML15159A714 

Tuomey, Joseph ML15154C186 

Turbeville, Pam ML15154C056 

Turbush, Heather ML15160A797 

Turetsky, Sami ML15156B168 

Turnbull, Karen ML15162A351 

Turner, Christy ML15160A066 

Turner, Jeffrey ML15159B477 

Turner, Kathleen ML15159B493 

Turner, Phyllis ML15155A601 

Turner, Thomas ML15148B244 

Tutihasi, R-Laurraine ML15159A120 

Tuxen, Ardelle ML15159A089 

Twickler, Carrie ML15155A398 

Twist, Shannon ML15155B006 

Twombly, Glen A. ML15155A191 

Tyler, Steve ML15155B793 

Tyler, Theresa ML15142A214 

Tyler, Wesley ML15160A902 

Tyre, Michael ML15154B213 

Tyrrell, Larry ML15154A582 

Tzelil, Canan ML15159B253 

Uchno, Lisa ML15158A264 

Ucko, Aaron ML15155A104 

Udelson, Donald ML15154B182 

Uecker, Robert ML15159B414 

Ulness, James ML15141A628 

Umbricht, Annie ML15148B164 

Underwood, Dennis ML15154A628 

Underwood, John ML15154B521 

Underwood, John ML15154B521 

Ungar, Luci ML15154A855 

Unger, David ML15141A731 

Commenter 

ADAMS 

Accession # 

Unger, Jennifer ML15154C248 

Unger, Pamela ML15155A688 

Unger, Steven ML15148A132 

Unruh, Jerry ML15156A168 

Urban, Richard ML15155C192 

Urbanek, Gail ML15155A278 

Urik, J. Alan ML15155B703 

Utigaard, Nina ML15155B852 

Utt, Charles ML15159A171 

Utterback, Pamela ML15154B265 

Uyenishi, Steve ML15158A289 

Uzsak, Adrienn ML15159B576 

V., Barbara ML15153A645 

Vachon, Adelia ML15155A780 

Vail, Cameron ML15155A840 

Vairo, Gina ML15153A588 

Valencia, Rio ML15154B134 

Valencour, Sandy ML15160A945 

Valenti, Scott ML15153A985 

Valentic, Nerma ML15156A034 

Valentine, J. ML15162B113 

Valentine, J. ML15162B044 

Valentine, Karen ML15159A997 

Valentine, Leslie ML15160A852 

Valentine, Sarah ML15162A218 

Valerie, Stiff ML15155B071 

Valiga, Susan ML15155A788 

Valle, Jacqueline ML15154B801 

Valluzzi, Jim ML15154B581 

Valney, Shirley ML15159A534 

Van Bergen, Jo Ann ML15148A160 

Van Burg, Chera ML15154B733 

Van Buskirk, Richard ML15155A860 

Van Dam, Chad ML15153A352 

Van Den Blink, Kieren ML15140A283 

Van Hise, James ML15158A251 

Van Huijkelom, Hans ML15154B599 

Van Lear, Tom ML15148B397 

Van Leekwijck, Natalie ML15154A609 

Van Leuven, Phyllis ML15155B992 

Van Ormer, Diana ML15155B244 

Van Pelt, Jason ML15153A518 

Van Petten, Melani ML15155A955 

Van Riper, Michael ML15154C066 

Van Velson, Nathan ML15156A333 

Vanbuskirk, Paula ML15142A079 

Vance, Christoper ML15155C152 

Vance, Eric ML15141A419 

Vance, Richard ML15142A131 

Vance, Samuel L. ML15155B994 

Vander Stoep, Dorothea ML15154A120 

Vandergrift, Debra ML15154B999 

Vanderhill, Margo ML15154A749 

Vandermark, Barbara ML15155B405 

Appendix E NUREG–2176 E-632 October 2016
Commenter 

ADAMS 

Accession # 

Vandersloot, Joyce ML15153A669 

Vanderveer, Angel ML15156A682 

Vandeventer, John ML15155C034 

Vandivere, Stephen ML15155B031 

Vanetten, Margot ML15159A399 

Vanhoy, Rick ML15153A633 

Vaniman, Jill ML15159A657 

Vanino, Susan ML15154B002 

Vankampen, Art ML15148B293 

Vanness, Barbara ML15142A145 

Vanruff‐Howden, Susann ML15141A791 

Vantilborgh, Tony ML15162A716 

Varanitsa, Oleg ML15156B211 

Varcoe, Donna D. ML15154A041 

Vargas, Christopher ML15148B226 

Varner, Miles ML15153B206 

Varney, Karen ML15154C208 

Vartenuk, Cynthia ML15148B256 

Vasily, Karen ML15147A742 

Vatter, Sherry ML15153B055 

Vaughan, Carolyn ML15154A166 

Vaughan, Lisa ML15156B091 

Vaught, Kevin ML15148B339 

Vaulx‐Smith, Wilford ML15154A820 

Vayda, Karen Ziomek ML15154B558 

Vazquez, Sonia ML15158A099 

Vearling, June ML15154A630 

Vecchiotti, Dorothea ML15156B147 

Vedvik, Gary ML15154A596 

Vee, Ordell ML15148A852 

Vegan, Rift ML15155B653 

Veijalainen, Pertti ML15148A825 

Veillette, Elizabeth ML15162A673 

Veirs, Mary ML15159A840 

Veirs, Mary ML15159A538 

Veit, Eberhard ML15153B029 

Velez, Francisco ML15160A973 

Velez, Jorge ML15147A738 

Velez, Sue ML15154C053 

Velloo, Samara Hanson ML15155B644 

Veltkamp, Robert ML15160A559 

Vena, Skip ML15156A200 

Venable, Sylvia ML15154B010 

Venezia, Sherri ML15148A740 

Veraldi, Anne ML15154A589 

Veraldi, Anne ML15154A604 

Veralli, Robert ML15141A444 

Verbridge, Tara ML15154A289 

Verhagen, Marianne ML15154C121 

Vermeer, Shellie ML15155A762 

Vermeulen, Mary ML15154B979 

Verna, Diane ML15159B362 

Verna, Diane ML15162A738 

Verrier, Theresa ML15154A008 

Commenter 

ADAMS 

Accession # 

Verzosa, Paul ML15158A096 

Vesely, Sakura ML15158A075 

Vest, Martha ML15153A886 

Vest, Nelda ML15159A084 

Veyhl, Stanley ML15154A178 

Viacrucis, John ML15154C230 

Vice, Daniel ML15148B165 

Vician, Doris ML15153A482 

Vickers, Margaret ML15154C014 

Viergutz, Julie ML15156A150 

Vignet, Stephen ML15155A031 

Viljoen, Christina ML15153A979 

Villanova, Carolyn ML15155A400 

Villanueva, Roberto ML15154B112 

Villarroel, Erick ML15154C091 

Villars, Julia ML15156A871 

Villodas, Abigail ML15155A354 

Vincent, Judith ML15159A954 

Vineski, Patricia ML15156B359 

Viney, Mary Anne ML15154C236 

Vion, Helene ML15154A389 

Vitek, Sandi ML15155B883 

Vivian, David ML15141A646 

VL, Judie ML15148A999 

Vlah, M. ML15154B828 

Vlasiadis, Andreas ML15159B284 

Voeltner, Carole ML15156A514 

Vogel, Nathan ML15154B037 

Vogel, Steven ML15148A964 

Voigtschild, Meg ML15154C281 

Volin, Judy ML15154A655 

Volk, Suzanne M. ML15156B376 

Vollmer, Alexander ML15154B310 

Volpatti, Dan ML15153A803 

Volpe, Joe ML15154C020 

Volquarts, Heinz ML15155A240 

Von Abele, Melitta ML15155A525 

von Sacher-Masoch, 

Michael ML15159A165 

Vorachek, Mary ML15142A152 

Vorhees, Miranda ML15158A045 

Voronov, Mikhail ML15153A370 

Vorse, Stephanie ML15155B984 

Voss, Barbara ML15159B585 

Vulic, Davor ML15147A775 

Vyatchanin, Evgenia ML15158A205 

W., Kevin ML15148B436 

Wachowiak, B. ML15162A607 

Wackowski, J. ML15159A364 

Wade, Gf ML15160A813 

Wade, Julia ML15154A751 

Wade, Pat ML15153A704 

Wadford, Soney ML15155C016 

Wadland, Sue ML15159A912 

Appendix E October 2016 E-633 NUREG–2176
Commenter 

ADAMS 

Accession # 

Wadsworth, Andrew ML15159B540 

Wagber, Herman ML15156A082 

Waggener, Michael ML15159A069 

Wagner, Florence ML15155B967 

Wagner, Inge ML15154B562 

Wagner, Joanne ML15161A627 

Wagner, Sandra ML15153B000 

Wagner, Vickie ML15141A480 

Wagner-Westbrook, 

Bonnie ML15156A233 

Wagoner, Donna ML15155C051 

Wagoner, Douglas ML15159A213 

Wahosi, Mare ML15162A683 

Wait, Cheryl ML15153B135 

Waite, Libby ML15154B727 

Walch, Mark ML15159A634 

Wales, Melissa ML15159B293 

Waleski, Melanie ML15155A708 

Walishko, Mary ML15155C109 

Walker, Christine ML15159B256 

Walker, David ML15155A732 

Walker, Donald and 

Charlotte ML15156B166 

Walker, Herman ML15154A005 

Walker, Jason ML15160A048 

Walker, Joan ML15158A014 

Walker, John ML15154C144 

Walker, Kathryn ML15160A916 

Walker, Kathy ML15153A417 

Walker, Leo ML15154A000 

Walker, Lynn ML15140A011 

Walker, Madonna ML15154A808 

Walker, Margret ML15155A590 

Walker, Matt ML15154B788 

Walker, Nora ML15155A518 

Walker, Sylvia ML15153B009 

Walker, Verla D. ML15140A245 

Walker, Verla D. ML15141A576 

Walker, Verla D. ML15162B080 

Walker, Verla D. ML15162B142 

Walker-Dale, Heather ML15140A244 

Wall, Nancy ML15156A837 

Wallace, Linda ML15141A430 

Wallace, Pamela ML15156B240 

Wallach, Larna ML15154B684 

Waller, Emory ML15140A257 

Waller, Kelley ML15159B234 

Waller, Kyle ML15148A877 

Waller, Russell ML15159B237 

Wallin, Willaim ML15153A868 

Wallington, Victoria ML15156A892 

Walrod, Brad ML15156B039 

Walsh, Arthur ML15159A056 

Walsh, Dorothy ML15154A319 

Commenter 

ADAMS 

Accession # 

Walsh, Frank ML15142A139 

Walsh, Kristin ML15154A259 

Walsh, Nancy ML15142A130 

Walsh, Susan ML15155B415 

Walsh, Tom ML15153B082 

Waltasti, Marilyn ML15153A388 

Walter, Ernest ML15156B440 

Walter, Gail ML15154A347 

Walter, Kenneth ML15155A454 

Walter, Lloyd ML15153A455 

Walters, Elizabeth ML15159A462 

Walters, Kenneth ML15154C093 

Walters, Lindsey ML15154A649 

Walters, Robyn ML15159B031 

Walters, Sandra ML15154A988 

Walters, Sherrie ML15159A368 

Walters, Wendy ML15162B089 

Walters, Wendy ML15162B140 

Waltman, Martha ML15158A212 

Walton, John ML15155A747 

Walton, Mark ML15159B401 

Ward, Aurelie ML15162A433 

Ward, Denise ML15155C014 

Ward, Eddie ML15141A563 

Ward, Joan ML15155A197 

Ward, Ken ML15155B857 

Ward, Lonnie ML15153B220 

Ward, Marvin J. ML15148B318 

Ward, Nancy ML15159A453 

Ward, Ralph ML15154B618 

Ward, Sheila ML15154B249 

Ward, Stacey A. ML15154A511 

Ward, Terrence ML15140A025 

Ward, Whitney ML15156A320 

Warfle, Jamee ML15155A452 

Warkoczewski, Marlene ML15155A429 

Warner, Teresa ML15148B125 

Warner, Thomas ML15153A457 

Warner, Thomas ML15156A946 

Warren, Barbara ML15148A189 

Warren, Jan ML15153A862 

Warren, Mobi ML15148A932 

Warzalla, Jim ML15155B847 

Wasgatt, Ann ML15154B479 

Washburn, Ted ML15159A026 

Washburn, Wadetta ML15154A384 

Wasielewski, Alison ML15148B129 

Watanabe, Hiroe ML15159A090 

Watene, Veronica ML15160A681 

Waterhouse, Ann Marie ML15159B438 

Waterman, Glenna ML15153B159 

Waters, Anje' ML15153A778 

Waterworth, Pamela ML15156A166 

Watkinson, Carolyn ML15155A684 

Appendix E NUREG–2176 E-634 October 2016
Commenter 

ADAMS 

Accession # 

Watson, Carrie ML15155B358 

Watson, Chris ML15159A834 

Watson, Claire ML15155B107 

Watson, Donna ML15154A344 

Watson, Fran ML15148B273 

Watson, Harold ML15155B981 

Watson, John ML15154B986 

Watson, Kim ML15159B515 

Watson, Suzanne ML15155A842 

Watters, Whitney ML15156B137 

Waugh, Wendy ML15156B490 

Waygren, Ed ML15155A491 

Wayne, Vicki ML15153A764 

Wear, Dennis ML15155C039 

Weatherwax, Nancy ML15162A395 

Weaver, Andrea ML15156A975 

Weaver, Carol ML15155B517 

Weaver, Esther ML15153B069 

Weaver, Gary ML15155B804 

Weaver, Joan S. ML15142A177 

Weaver, Judy ML15153A995 

Weaver, Mike ML15159B497 

Weaver, Wes ML15154C234 

Webb, Jane ML15156B325 

Webb, Kimberly ML15153A977 

Webb, Michelle ML15148B130 

Webb, Shannon ML15148A914 

Webber, Gary ML15155B521 

Weber, Marsita ML15153A552 

Weber, Zorina ML15154A103 

Weberg, Melanie ML15154A801 

Webster, Ellen ML15148A617 

Wecker, Judith ML15160A070 

Wedoff, Margaret ML15140A129 

Wedow, Nancy ML15148A220 

Weeks, Chris ML15154A204 

Weigel, Alice ML15155B336 

Weikert, J. ML15156A287 

Weil-Martin, Carla ML15155A696 

Weiman, C. David ML15154B302 

Weinberg, Henry ML15153A556 

Weiner, Linda ML15154A002 

Weinrich, John ML15155B220 

Weinstein, Diane ML15155B214 

Weinstein, Elyette ML15159A100 

Weisel, Jef ML15148B095 

Weissman, Warren ML15160A705 

Weisz, Russell ML15159A145 

Weitz, Stephen ML15148B091 

Weitzman, Anna ML15154A930 

Weitzman, Marilyn J. ML15142A191 

Welch, Joanna ML15154A393 

Welde, Logan ML15160A594 

Weldon, Wendy ML15148B310 

Commenter 

ADAMS 

Accession # 

Welkowitz, William ML15148B262 

Welling, John ML15159A274 

Wells, Janette ML15154A253 

Wells, Michael ML15155A528 

Wells, Michael ML15160A526 

Wells, Susan ML15141A684 

Welton, John ML15156A314 

Wemer, Kimberly ML15155A206 

Wendt, Rosamund ML15159B030 

Wene, M. Ghost Dancer ML15142A017 

Wenning, Judy ML15158A161 

Wentz, Shari ML15159A125 

Weprin, Andrew ML15153A411 

Werner, Katherine ML15142A098 

Werner, Ryvonne ML15154B970 

Wersinger, Sara ML15159B126 

Wertz, Jennifer ML15153A685 

Wessman, Eric ML15159A630 

West, John ML15155A222 

West, Reiven ML15155B032 

West, Diane ML15159B534 

West, Eric ML15154C041 

West, Kenneth ML15154B711 

West, Meredith ML15148B112 

Westergaard, Barbara ML15156A902 

Westfall, Rob ML15155A152 

Westmoreland, Henry H. ML15155B563 

Westra, Jennifer ML15155A938 

Wettersten, Jill ML15155A252 

Wetzler, Richard ML15162B115 

Wetzler, Richard ML15162B044 

Weyandt, Debbie ML15159A835 

Weyer, Diane ML15154A956 

Whalen, Patricia ML15159B148 

Wharton, Becky ML15154A689 

Wheeler, Al ML15160A937 

Wheeler, Ken ML15155A848 

Wheeler, Mark ML15160A072 

Wheeler, Maureen ML15158A091 

Whelan, V. ML15156A193 

Wheller, Noreen ML15155A143 

Whetsell, Frank ML15148B175 

Whetstine, Linda ML15153A998 

Whipple, Dave ML15154A921 

Whipple, Wyman ML15154A028 

Whitaker, Howard ML15162B044 

Whitaker, Howard ML15162B114 

White, Bruce ML15155A794 

White, Charmaine ML15159A444 

White, Claudia ML15154A241 

White, Diane ML15159A737 

White, Gisele ML15148B171 

White, Howard ML15154A486 

White, Janet ML15154A286 

Appendix E October 2016 E-635 NUREG–2176
Commenter 

ADAMS 

Accession # 

White, John ML15159B469 

White, Joseph ML15155B820 

White, Kathy ML15156A524 

White, L. ML15153B280 

White, Linda Michel ML15154A599 

White, Liz ML15155A302 

White, Maria ML15156B467 

White, Marianne ML15162A697 

White, Mark ML15160A703 

White, Mary ML15160A542 

White, Mindi ML15155B800 

White, Ronda ML15155B670 

White, Scott ML15162A295 

White, Terri ML15142A208 

White, William P. ML15153B171 

Whitehead, Lissette ML15154A136 

Whitehorn, C. ML15154A318 

Whitener, Shari ML15159A008 

Whiteside, Catherine ML15153B017 

Whitford, Kirstina ML15162A110 

Whiting, Carolyn ML15155A235 

Whitman, Rick ML15159A988 

Whitson, Helene ML15154A247 

Whitten, Robin ML15158A067 

Whybrew, Michael ML15154A685 

Wiant, Jean ML15154A872 

Wichar, Den Mark ML15154A269 

Wicht, Dan ML15156A578 

Wick, Jodi ML15147A776 

Widell, Janet ML15156A450 

Widera, Debra ML15154B272 

Wiebenson, Sarah ML15159B213 

Wiedemann, Janna ML15160A892 

Wiedemann, Janna ML15160A941 

Wieder, Anna ML15156A235 

Wiederhold, Joe ML15155A322 

Wiegand, Suzanne ML15155C244 

Wiegert, Hans ML15148B254 

Wieland, Chuck ML15148A596 

Wienert, John ML15154B455 

Wiesner, Joseph ML15153A878 

Wiesner, Mary Ann ML15147A746 

Wightman, Richard ML15142A148 

Wikette, Michelle ML15154A541 

Wilberding, Ron ML15159A884 

Wilbur, Lynn ML15141A664 

Wilby, Margaret ML15159A537 

Wilcox, C. ML15142A051 

Wilcox, Robert ML15158A026 

Wilde, Deena ML15154A239 

Wilde, Kathy ML15141A591 

Wildman, Teena ML15148A591 

Wiles, Kristin ML15159A266 

Wiley, Kimberly ML15162A599 

Commenter 

ADAMS 

Accession # 

Wiley, Patricia ML15155B153 

Wilgus, Kathleen ML15154B367 

Wilke, Gail ML15159B038 

Wilke, Wendy ML15156B258 

Wilken, Sara ML15148B004 

Wilkes, James ML15154A046 

Wilkin, Sue ML15154B018 

Wilkins, Pat ML15162B091 

Wilkins, Pat ML15162B132 

Wilkinson, Art ML15153A715 

Wilkinson, Diana ML15148B393 

Wilkinson, Dorothy ML15162A248 

Wilkinson, Maryann ML15155A022 

Wilks, Debra ML15148A173 

Will, Leona ML15153A693 

Willard, D. ML15154A272 

Willer, Benjamin ML15148A880 

Willett, Greg ML15148B363 

Williams, Adam ML15154C299 

Williams, Billie ML15148B304 

Williams, Carrie ML15156B006 

Williams, Cheryl ML15159B094 

Williams, David ML15162A415 

Williams, Donald ML15159B392 

Williams, Donald ML15159B393 

Williams, Elizabeth ML15158A061 

Williams, Glen ML15156B215 

Williams, Helen Jo ML15159B394 

Williams, Kathleen ML15153B084 

Williams, Linda ML15155B165 

Williams, Marjorie ML15155A691 

Williams, Marni ML15140A145 

Williams, Marty ML15155A014 

Williams, Nicholas ML15154C008 

Williams, Paul ML15148B132 

Williams, R. ML15148B234 

Williams, R. ML15148B381 

Williams, R. J. ML15156A181 

Williams, Rita ML15162A724 

Williams, Sara ML15158A202 

Williams, Susan ML15154A443 

Williams, Terrie ML15156A693 

Williams, Vicki ML15159A661 

Williamson, Bruce ML15158A233 

Williamson, Gay ML15155C171 

Willis, Ed ML15153B113 

Willison-Perry, Francine ML15153A806 

Willliamson, Shawn ML15159B146 

Willoh, J. ML15155A844 

Willour, Judith ML15154B263 

Wills, Susan ML15159A768 

Wilscam, Linda ML15155C041 

Wilschke, Carole ML15159B471 

Wilsey, Frank ML15154C118 

Appendix E NUREG–2176 E-636 October 2016
Commenter 

ADAMS 

Accession # 

Wilson, Angela ML15158A130 

Wilson, Antonia ML15156A213 

Wilson, Crystal ML15156B212 

Wilson, David ML15141A559 

Wilson, David ML15155A690 

Wilson, Donald ML15154A452 

Wilson, James ML15148A602 

Wilson, Kerri ML15154C233 

Wilson, M. ML15142A199 

Wilson, Margaret ML15142A190 

Wilson, Molly ML15155A490 

Wilson, Polly ML15154B009 

Wilson, Rick ML15142A291 

Wilson, Rose Marie ML15155B891 

Wilson, Steve ML15142A240 

Wilson, Susan ML15142A341 

Wilson, Thomas ML15156B159 

Wilson-Hopkins, Lori ML15154B584 

Windham, Dallas ML15158A263 

Windus, Jared ML15161A623 

Wine, Jordann ML15154B755 

Wines, R. ML15154A860 

Winfrey, Bobbiejo ML15153A894 

Wingerd, Mala ML15154B820 

Winick, Dorothy ML15162B091 

Winick, Dorothy ML15162B151 

Winkelmayer, Patricia ML15154A936 

Winkle, Annetta ML15155A009 

Winn, Laraine ML15155A125 

Winn, Priscilla ML15154A358 

Winne, Patricia ML15154A972 

Winner, Angelika ML15142A156 

Winnicki, Kristine ML15142A119 

Winograd, Deborah ML15160A579 

Winstead, A. ML15154B467 

Winston, Leslie ML15156A510 

Winston, Yvette ML15162B103 

Winston, Yvette ML15141A640 

Winston, Yvette ML15162B042 

Winter, Kathleen ML15155A640 

Winter, Ken ML15154A772 

Winter-Lisbeth, Merissa ML15155A445 

Winters, Gracie ML15154B133 

Winters, Valerie ML15154B469 

Wirth, Mark ML15156B512 

Wisboro, Judith ML15153A897 

Wisch, Anita ML15154B537 

Wise, Carol ML15153B189 

Wise, David ML15155B723 

Wisniewski, Georg ML15162A602 

Witham, Lisa ML15148A895 

Withington, Julia ML15154A802 

Withrow, Ferah ML15148A194 

Witmer, Tiffany ML15156A040 

Commenter 

ADAMS 

Accession # 

Witt, Kelly ML15153A726 

Wittenberg, Sara ML15159A670 

Wittkopp, Serena ML15155C118 

Wittner, Judith ML15158A011 

Woelbing, Keith ML15162A257 

Woersching, Marc ML15155B029 

Woessner, Paul ML15148A599 

Wohlberg, Robert ML15155A888 

Wolf, A. ML15155B783 

Wolf, Crystal ML15155A816 

Wolf, Wesley ML15153B002 

Wolfe, Charlotte ML15155C212 

Wolfe, Claire ML15154C104 

Wolfe, Gerald ML15156B488 

Wolfe, Jessica ML15148A922 

Wolfe, Kathleen ML15148A954 

Wolfgang, Mara ML15141A699 

Wolfson, Brett ML15155B777 

Wolinsky, Susan ML15141A496 

Wolkowitz, Rhea ML15159A080 

Wollard, Carla ML15148B431 

Wolle, Heather ML15148B031 

Wollner, William ML15159A007 

Wolongevicz, Patricia ML15142A233 

Wolslegel, Thomas ML15158A069 

Wolther, Mary ML15159B575 

Womble, Jeffrey ML15159A521 

Wong, Barbara ML15155C020 

Wong, Kimberly ML15156A328 

Wong, Timothy ML15158A005 

Wood, Barbara ML15154A113 

Wood, Barbara L. ML15154A372 

Wood, Dianna ML15156A173 

Wood, Gordon ML15154C156 

Wood, Heidi ML15153B139 

Wood, Homer ML15153B200 

Wood, Joyce ML15146A367 

Wood, Joyce ML15160A982 

Wood, Judy ML15159A733 

Wood, Megan ML15155B562 

Wood, Nancee ML15156A501 

Wood, Peter ML15154C305 

Wood, Sara ML15154B287 

Wood, Shelva ML15159A950 

Wood, Stacey ML15148A944 

Wood, Virginia ML15154A744 

Woodall, Sandra ML15154A987 

Woodard, Bennie ML15155B347 

Woodbury, Ellen ML15156A688 

Woodman, Renee ML15148B215 

Woodruff, Jenny ML15159A663 

Woodruff, Joanne ML15148B269 

Woods, Rocquelle ML15147A728 

Woods, Roth ML15159B061 

Appendix E October 2016 E-637 NUREG–2176
Commenter 

ADAMS 

Accession # 

Woodward, Melody ML15155A746 

Woolsey, David A. ML15159A365 

Worcester, Chris ML15160A064 

Worch, Cheryl ML15148B075 

Wordlaw, Christine ML15162A631 

Workman, Mary ML15153A473 

Worley, Irene ML15148B210 

Worley, Joseph ML15142A366 

Worley, Joseph ML15154A371 

Worrell, Jennifer ML15148A979 

Worrell, William ML15156B377 

Wotton, Bernard ML15154C280 

Wozniak, Rachel ML15156B495 

Wozniak, Rhonda ML15155B110 

Wright, Abigail ML15154B985 

Wright, Carolyne ML15155B851 

Wright, Carrie ML15162A614 

Wright, Charles ML15155A437 

Wright, Gay ML15153B045 

Wright, Glenn ML15155A428 

Wright, Marilyn ML15155A101 

Wright, Michael ML15141A777 

Wright, Michelle ML15148B162 

Wright, Nancy ML15156A867 

Wright, Sandra ML15159B374 

Wright, Shannon ML15159A905 

Wright, Susan ML15153A801 

Wright, Sydney ML15159A121 

Wright, Tammy ML15154A075 

Writz, Gina ML15159A485 

Wry, Ellen ML15142A132 

Wulf, Laurie ML15156A187 

Wulf, Maureen ML15159A281 

Wurtz, Jacob ML15160A069 

Wushensky, Sharon ML15155B354 

Wyatt, Aimee ML15161A632 

Wyatt, Cathy ML15156A440 

Wyatt, John ML15153B229 

Wyckoff, Dana ML15148A830 

Wyman, Elizabeth ML15155A288 

Wyman, Tom ML15158A009 

Wyse, Margo ML15153B199 

Wyse, Sheila ML15148B000 

Wyss, Jon ML15153B295 

Xavier, Marjorie ML15159B517 

Xhilone, Lynne ML15156A905 

Xiberras, Paula ML15155C223 

Y., Nancy ML15159A101 

Yaffee, Steve ML15141A610 

Yancey, Robert ML15154A177 

Yanke, Brian ML15154A197 

Yantselovskiy, Alexandr ML15154A669 

Yarger, Andrea ML15155B979 

Yarter, E. C. ML15148B034 

Commenter 

ADAMS 

Accession # 

Yazbek, Daniel ML15141A525 

Yazell, Jeremy ML15154B867 

Yeager, Jerry ML15160A733 

Yelenick, Lisa ML15159A353 

Yellis, Stefanie ML15148B325 

Yerena, Jr., Julian ML15159A909 

Yoder, Amanda ML15154B171 

Yokoyama, Holly ML15156B123 

Yost, Carol ML15155B483 

Yost, Gaylord ML15154B918 

You, Sam ML15154C076 

Youd, Mark ML15162B091 

Youd, Mark ML15162B152 

Young, Allan ML15159B491 

Young, Anne ML15148A900 

Young, Cecilia ML15156B412 

Young, Cheryl ML15154A435 

Young, Doug ML15154A472 

Young, Douglas ML15160A527 

Young, Jo Ellen ML15154A085 

Young, Karen ML15159B125 

Young, Katherine ML15160A548 

Young, Katie ML15160A581 

Young, Kim ML15155B916 

Young, Leslie ML15155A935 

Young, Nancy ML15154B281 

Young, Patricia ML15142A329 

Young, Philip ML15153A691 

Young, Rachel ML15155A408 

Young, Raymond ML15141A549 

Young, Rosanne ML15159A363 

Young, Sheila ML15156A271 

Young, Spencer ML15153A572 

Yount, Madeline ML15154B744 

Yovella, Debra ML15159A260 

Yun, Allen ML15148B022 

Yurchuck, Ruth ML15154A469 

Zachritz, Todd ML15153A477 

Zack, Mary ML15148A978 

Zagaris, Michael ML15153A980 

Zagone, Michael ML15154C138 

Zalesak, Margie ML15158A115 

Zambie, Dave ML15159B140 

Zammarano, Vittorio 

Tedesco ML15154A132 

Zampini, Cassandra ML15142A249 

Zand, June ML15162A051 

Zanders, Marya ML15153A861 

Zarek, Elizabeth ML15153A717 

Zarkhosh, Helia ML15159A068 

Zarsky, Terry ML15153B098 

Zatz-Diaz, Ivan ML15148A948 

Zavaro, Mario ML15156B411 

Zawada, Dave ML15160A765 

Appendix E NUREG–2176 E-638 October 2016
Commenter 

ADAMS 

Accession # 

Zawadzki, C. ML15159A070 

Zawaski, Joan ML15140A017 

Zebracki, Nancy ML15156A489 

Zegledi, Dawn ML15154C249 

Zehm, Carmen ML15156A203 

Zeilenga, Jack ML15141A476 

Zeilenga, Jack ML15141A609 

Zelazny, Bernie ML15156A788 

Zelinski, Dawn ML15160A725 

Zeller, Jennifer Kim ML15148A987 

Zellmer, Kevin ML15154B955 

Zelmanovich, Silvana ML15155A205 

Zeman, James ML15148B406 

Zendzian, Paul ML15159A983 

Zepeda, Robert ML15158A060 

Zerr, Laura ML15154B648 

Zetley, Herb ML15156A536 

Ziama, Kristin ML15159A275 

Zibordi, Barbara ML15140A261 

Zibordi, Barbara ML15153B089 

Ziegler, David ML15159A546 

Ziegler, Herbert ML15154A422 

Ziegler, Russ ML15153B041 

Ziegler, Russell ML15141A651 

Ziehler-Martin, Paige ML15155B957 

Zielke, David ML15148B327 

Ziencina, Terra ML15154A688 

Zierikzee, R. ML15148B053 

Commenter 

ADAMS 

Accession # 

Zillhardt, Matt ML15155A067 

Zimanova, Emilia ML15148A188 

Zimbelmann, Merrilyn ML15155B438 

Zimmer, Louise ML15153A440 

Zimmer, Susan ML15155A200 

Zimmerer, Mary Beth ML15159B492 

Zimmerman, Craig ML15156A965 

Zimmerman, Marcus ML15148B015 

Zimmermann, John ML15156A789 

Zimmermann, John ML15154A715 

Zimny, Gloria ML15148A757 

Zinn, Andrea ML15159B380 

Zinn, Cari ML15155B242 

Zinn, Robert ML15142A111 

Zinn, William ML15148A862 

Zirasri, Ran ML15147A757 

Zissu, Thoams ML15156A284 

Zoldak, Loretta ML15153A429 

Zoro, Piero ML15148B245 

Zschaler, Clara ML15154A989 

Zuber, Margaret ML15142A342 

Zuber, Margaret ML15154A020 

Zuckerman, Michael ML15154C161 

Zudell, Keith ML15156A280 

Zukoski, Katie ML15159A434 

Zwick, Larry ML15154A618 

Zywan, Katherine Barrett ML15155A796 

Zyzda, Marilyn ML15156B434 

Table E-9. Individuals Submitting the Form with Subject “No New Reactors at Turkey 

Point” with Correspondence ID TURK-COL6&7-DR-00103 and Representative 

ADAMS Accession No. ML15139A729 (Multiple Authors 2015-TN4721)

Commenter ADAMS Accession # 

Abal, Ramiro ML15142A340 

Abbondante, Jim ML15156A663 

Abraham, D. L. ML15142A340 

Abraham, Karin ML15140A051 

Abraham, Karin ML15140A052 

Acquino, Mary ML15139A936 

Adams, Chardae ML15156B364 

Aghayan, Veronic ML15156A291 

Ahuja, Neha ML15162A484 

Alabiso, Marie ML15159A354 

Albani, R. ML15139A829 

Alden, Susan ML15162A802 

Alexander, Larry ML15162A682 

Alexander, Natalie ML15162A382 

Alexander, Tiffany ML15142A013 

Alfimow, Beverly ML15148B423 

Alfimow, Beverly ML15153A662 

Commenter ADAMS Accession # 

Ali, Rozina ML15142A340 

Allan, Larry ML15139A944 

Allan, Linda ML15156B388 

Alverson, David ML15161A689 

Amann, Marianne ML15142A340 

Ammon, Cara ML15162A788 

Andersen, Peggu ML15162A148 

Anderson, Valda ML15158A059 

Anderton, Phillip ML15142A340 

Andrade, Abigail ML15162A041 

Andreacchio, Tonya ML15139A964 

Andrews, Laquitta ML15162A564 

Andrews, Renee ML15142A340 

Andrews, Thomas ML15142A340 

Angelo, Marjorie ML15139A845 

Ankiel, Summer ML15142A340 

Apple, Karla ML15142A340 

Appendix E October 2016 E-639 NUREG–2176
Commenter ADAMS Accession # 

Apple, Karla ML15162A186 

Arana, Josefa ML15159A369 

Arana, Josefa ML15159A369 

Arana, Josefa ML15162A773 

Araskog, Julie ML15139A860 

Arfin, Danielle ML15142A340 

Armm, Edward ML15142A340 

Armstrong, Brooks ML15155C210 

Artigas, Jose ML15142A340 

Arvidsson, Rikard ML15142A340 

Atkinson, Deborah ML15142A340 

Atkinson, Joan ML15139A819 

Atler, Neil ML15139A871 

Auld, Denise ML15139A848 

Auster, Evan ML15160A895 

B., Donna ML15142A340 

B., V. ML15142A340 

B., V. ML15162A238 

Bahos, Miguel ML15139A909 

Bailar, Tami ML15156A222 

Bailey, Marcia ML15139A779 

Baker, Mary Sue ML15159A826 

Balfour, Michele ML15160A929 

Balkan‐Litowitz, Donna ML15139A951 

Balogh, Daniel R. ML15142A371 

Bangerter, Jim ML15142A340 

Banks, Janice ML15142A340 

Bannon, Richard ML15139A858 

Baracca, Marco ML15142A340 

Barhoum, Tawfik ML15139A804 

Baridon, Flavia ML15142A340 

Barlow, Jeffrey ML15139A974 

Barmann, Adriene ML15155A833 

Barron, Marie ML15139A826 

Barroso, Mario ML15158A094 

Barry, Mina ML15155C207 

Bartlett, Ellen ML15139A773 

Bassett, Roy ML15158A268 

Bastian, Mark ML15142A340 

Batchelder, Jan ML15142A340 

Bate, Jo Ellen ML15162A744 

Bateman, Cheryl ML15142A340 

Bauer, Lynda ML15162A772 

Beam, Stephanie ML15142A340 

Beattie, Gordon ML15139A867 

Beauchamp, Beryl ML15142A340 

Beaupre, R. ML15142A340 

Bechmann, Elisabeth ML15142A340 

Bechmann, Elisabeth ML15161A683 

Bechtel, William ML15139A945 

Becker, Lauren ML15161A643 

Bedat, Suzanne ML15154B412 

Begley, Kathleen ML15162A190 

Behl-Whiting, Kathy ML15155C153 

Bekkers, Anne ML15142A340 

Commenter ADAMS Accession # 

Bekkers, Anne ML15162A827 

Bell, Lindsey ML15155C211 

Bellamy, Ray ML15139A803 

Belt, Dana ML15162A842 

Bendure, Ellie ML15139A796 

Benito, Alejandra ML15142A071 

Benkert, Cynthia ML15139A990 

Bentsur, Eyal ML15155C021 

Berger, Barbara ML15160A591 

Berger, Keith ML15142A340 

Bergman, Ingrid ML15142A340 

Bernabei, Kaatje ML15159A848 

Bernatis, Jenn ML15142A340 

Best, Rudy ML15162A790 

Bielski, Michele ML15159A640 

Biemuller, Eric ML15142A340 

Biermaier, Jennifer ML15159A477 

Bigas, Michelle ML15155C208 

Bilek, Heidrun ML15142A340 

Bischoff, Carol ML15142A340 

Bitnar, Patricia ML15159A464 

Bittner, Jill ML15142A340 

Bittner, Jill ML15162A594 

Bittner, Michael ML15142A340 

Black, Meaghan ML15162A812 

Blair, Libby ML15161A685 

Blais, Sonia ML15142A340 

Blake, Dale ML15142A340 

Blakestad, Nancy ML15162A819 

Blanton, Cricket ML15159A577 

Blauer, Sara ML15148A805 

Blessing, Anna ML15139A800 

Blue, Julie ML15148B424 

Boczkowski, Diane ML15142A340 

Bodine, Frank ML15142A340 

Boeckman, Evelyn ML15162A848 

Boehl, Ingrid ML15162A063 

Bogle, Tim ML15142A340 

Bolen, D. K. ML15155A173 

Booras, Cyndee ML15139A806 

Bornejko, Trina ML15142A340 

Bouilland, Stacy ML15142A340 

Bousquet, Bob ML15142A340 

Bow, Leslie ML15162A219 

Bowers, Mary ML15142A340 

Boyce, Sheila ML15139A781 

Boyce, Thomas ML15142A340 

Boylston, Sandra ML15142A340 

Bracciotti, Federica ML15162A793 

Brachman, Phyllis ML15142A340 

Bracken, Fay ML15142A340 

Bradley‐Johnson, 

Carol ML15139A835 

Brady, Carl ML15142A339 

Branch, Pat ML15142A340 

Appendix E NUREG–2176 E-640 October 2016
Commenter ADAMS Accession # 

Brand, Barbara ML15142A340 

Braswell, A. ML15142A340 

Bredda, Marina ML15142A340 

Brewer, Kelly ML15142A340 

Brien, Ray ML15142A340 

Brienza, Zachary ML15139A920 

Briggle, Ryan ML15139A895 

Briggs, Lois ML15156B235 

Brigner, Liberty ML15142A340 

Brimer, Richard ML15160A716 

Britz, Barbara ML15162A719 

Broad, Elisa ML15162A114 

Broughton, Alyssa ML15148A804 

Brower, Amanda ML15156A571 

Brown, Arlene ML15142A009 

Brown, Deborah ML15153B038 

Brown, Howard ML15142A340 

Brown, Ilean ML15162A209 

Brown, Judith ML15162A281 

Brown, Lillian ML15142A340 

Brown, Taylor ML15154A529 

Browne, Judy ML15139A973 

Browning, Tina ML15139A866 

Browning, Tina ML15139A930 

Brubaker, Dawn ML15139A975 

Brush, Johnnie ML15140A062 

Bruton, Babette ML15160A926 

Bruton, Darlene ML15160A927 

Bryer, Loree ML15159A252 

Buchwald, Marla ML15139A731 

Buchwald, Marla ML15142A340 

Buck, Michelle ML15156B202 

Bugbee, Michael ML15142A340 

Bullock, Elizabeth ML15142A340 

Burdine, Laura ML15142A171 

Burns, Georgina ML15142A340 

Burton, Martha ML15142A340 

Bush, Sandra ML15162A168 

Bushway, Cindy ML15148B419 

Butler, Amber ML15139A883 

Butterfield, Doris ML15162A350 

Byrne, Matthew ML15139A840 

Byrnes, Richard ML15139A934 

Byron, Lee ML15142A340 

C., N. ML15159B282 

Cabala, John ML15142A340 

Cadieux, Monique ML15142A340 

Caisse, C. ML15154A530 

Call, Cynthia ML15142A070 

Calo, Joan ML15142A340 

Campbell, Anne ML15139A880 

Campbell, Jacqueline ML15142A340 

Campbell, Jacqueline ML15162A728 

Campbell, John ML15159A641 

Campbell, Sean ML15153B037 

Commenter ADAMS Accession # 

Canas, Yisel ML15155C250 

Capasso, Celeste ML15142A340 

Capstick, Hilary ML15142A340 

Caracci, Gina ML15139A901 

Carbia, Vanessa ML15162A630 

Card, Kevin ML15142A340 

Cardoso, Toby ML15142A340 

Cardoso, Toby ML15162A762 

Carr, Marcus ML15142A068 

Carroll, Donna ML15142A340 

Carter, Cindy ML15142A340 

Carvajal, Mauricio ML15142A340 

Caserrta, Kimberly ML15142A340 

Caskey, Sally ML15142A340 

Cassens, Susie ML15142A340 

Caton, Elizabeth ML15142A340 

Cecil, Jon ML15162A251 

Celandine, Anna ML15162A800 

Cellette, Richard ML15156A247 

Chapman, Kevin ML15159A855 

Chi, AniMae ML15142A340 

Chin, Trevor ML15142A340 

Chirino, Miguel ML15142A369 

Chisari, Andrea ML15155C023 

Christoff, Stephanie ML15142A340 

Christoplos, Florence ML15162A786 

Chu, Sandra ML15162A536 

Chulock, Jan ML15156B321 

Chynoweth, Iris ML15142A340 

Ciardello, Elaine ML15142A340 

Ciesielski, J. ML15139A770 

Ciftci, Oscar ML15139A900 

Claiborn, William ML15139A836 

Clark, Jeff ML15139A812 

Clark‐Alexander, 

Barbara ML15139A935 

Claudine, Bos ML15142A340 

Clay, Cynthia ML15139A986 

Clement, Kevin ML15162A811 

Cleveland, Joel ML15159A370 

Clifford, Susan ML15156A089 

Clutter, Marcie ML15139A948 

Clutter, Marcie ML15139A970 

Coffey, Rotraud ML15142A340 

Colby, Helen ML15156A120 

Cole, 3rd, Lincoln P. ML15139A863 

Coleman, Laura ML15156A224 

Collins, Kathy ML15139A853 

Collins, Larry ML15142A340 

Collins, Larry ML15139A733 

Collins, Trevor ML15139A969 

Combes, Steven ML15139A764 

Comella, John ML15142A340 

Connelly, Sally ML15142A340 

Connolly, Makenna ML15162A572 

Appendix E October 2016 E-641 NUREG–2176
Commenter ADAMS Accession # 

Contreras, Constance ML15162A619 

Cook, Debra ML15142A340 

Cook, Steven ML15162A660 

Copeland, Damon ML15162A750 

Corby, Kathleen ML15142A340 

Corby, Kathleen ML15162A288 

Cortes, Juan ML15159B502 

Corzo, Cara ML15156B320 

Corzo, Hector ML15156B361 

Cosentino, Debra ML15142A340 

Cotz, Elina ML15142A340 

Cotz, Elina ML15139A734 

Courtney, Susan ML15142A012 

Coyle, N. ML15142A340 

Crabtree, Summer ML15142A340 

Craciun, George ML15139A742 

Craft, Katie ML15142A340 

Cranford, Connie ML15159A658 

Creech, Jeff ML15142A340 

Crowley, Joyce ML15162A200 

Crum, Bill ML15162A250 

Csanyi, Cheryl ML15139A785 

D., L. ML15162A839 

Daab, Antoinette ML15139A926 

Dace, Letitia ML15153A664 

Dace, Letitia ML15162A116 

Daen, L. ML15142A340 

Dahl, Thomas ML15142A340 

Daly, Erik ML15162A805 

D'amour, Roland ML15162A074 

Danios, Tea ML15156A049 

D'Annunzio, Patrick ML15142A340 

D'Antonio, Lisa ML15155A479 

Dascotte, Melinda ML15142A331 

Davis, Joan ML15142A340 

Davis, John ML15160A951 

Davis, Liora ML15139B006 

Davis, Liora ML15139B007 

Davis, Robin ML15139A915 

Day, C. ML15142A340 

Day, Edward ML15142A340 

de Buzon, Sylvie ML15142A340 

De Voy, Christy ML15139A954 

Deacy, Bob ML15142A340 

Deane, Triciat ML15139A813 

DeBias, Anita ML15154B399 

DeFauw, Rachel ML15139B001 

Dehler, Patricia ML15148B421 

Delgado, Alejandro 

Ceruelo ML15162A121 

Delgado, Barbara ML15160A863 

DeLia, Tony ML15139A922 

DeLuca, Patricia ML15142A340 

Demello, Christine ML15155C024 

Demers, Ralph ML15159A744 

Commenter ADAMS Accession # 

Deneault, Donna ML15162A610 

Dengel, Pat ML15162A487 

Densmore, Teresa ML15159B443 

DePante, Michael ML15139A783 

Desharnais, Jodi ML15142A340 

Destefano, Robert ML15154B403 

Detrick, Mary ML15159A157 

Devine, Lauren ML15142A340 

Devine, Lauren ML15139A730 

Diaz, Mayra ML15142A340 

Diaz, Mayra ML15139A755 

Diaz, Yelina ML15140A021 

DiFilippo, Robert ML15142A340 

Dillon, Sheila ML15162A779 

Dillon, Sheila ML15142A340 

DiVicino, Roseann ML15159B486 

DiVicino, Roseann ML15159B487 

Dobereiner, Trish ML15139A907 

Dobos, Robert ML15159A215 

Dodd, Belinda ML15162A273 

Dolly, William ML15159A500 

Domino, Michael ML15142A340 

Donis, Bea ML15139B009 

Donovan, Patrick M. ML15142A340 

Dorchin, Susan R. ML15142A340 

Dorn, Kathryn ML15155B897 

Dorsey, Tara ML15154B404 

Downey, Noel ML15139A757 

Dresser, Connie ML15139A828 

Driver, Monica ML15162A629 

Drummond, Willa ML15162A131 

du Brin, Jane ML15154C168 

Dührkopf, Manja ML15142A340 

Dunbar, Laura ML15162A062 

Duncan, Jane ML15139A997 

Duncan, Renee ML15160A952 

Duncan, Sue ML15155A174 

Dungee, Adrienne ML15159A150 

Dunn, Melissa ML15142A340 

Dunn, Timothy ML15162A202 

Durrer, Mary ML15142A340 

Düsterwald, Manuela ML15142A340 

Dutton, Matthew ML15161A669 

DuVerger, Roy ML15159B299 

Dyck, Cheryl ML15154B424 

E., Cheryl ML15162A595 

Easter, Jeff ML15142A340 

Easter, Tara ML15162A803 

Eaton, Rick ML15142A340 

Eckert, Jacqueline ML15139B008 

Edelman-Tolchin, 

Gayle ML15159A019 

Edelman‐Tolchin, 

Gayle ML15160A734 

Edmonds, Steven ML15142A340 

Appendix E NUREG–2176 E-642 October 2016
Commenter ADAMS Accession # 

Edmonson, Michele ML15139A771 

Egan, Marilyn ML15142A340 

Ehrenberger, Jennifer ML15142A340 

Eiser, Tina ML15142A340 

Elbirt, Diana ML15162A825 

Elferdink, Luann ML15162A743 

Eller, Dennis & Martha ML15142A340 

Eller, Dennis & Martha ML15139A748 

Eller, Dennis & Martha ML15139A751 

Eller, Dennis & Martha ML15139A756 

Eller, Dennis & Martha ML15139A761 

Ellicott, Barbara ML15142A340 

Elliott, Jan ML15162A296 

Elliott, Jan ML15162A299 

Elliott, Judith ML15154B408 

Enfield, Martie ML15139A887 

England, II, Roy ML15139A894 

Epstein, Philip ML15160A627 

Escobar, Hector ML15155A164 

Escobar, Melissa ML15142A340 

Esterly, A. ML15139A978 

Estrin, Mildred ML15142A340 

Eubank, Marana ML15142A340 

Evans, Janet ML15159A136 

Eyclesheimer, Susan ML15142A340 

Faison, Sandy ML15139A775 

Farrell, Roberta ML15162A774 

Faulkner-Uriarte, Elisa ML15142A340 

Faulks, Lea ML15162A783 

Fazio, Kristina ML15142A340 

Feder, Melanie ML15162A752 

Feder, Melanie ML15142A340 

Feeney, John ML15142A340 

Feeney, John ML15162A801 

Feldman, Dee ML15139A897 

Felicione, Felicia ML15155B808 

Fell, Cynthia ML15162A215 

Fell, Cynthia ML15162A548 

Fell, Cynthia ML15162A741 

Fera, Kristen ML15162A747 

Ferguson, Anisa ML15162A625 

Ferguson, Heather ML15161A661 

Fernandez, Beth ML15142A340 

Fielder, Linda ML15142A340 

Fige, Patti ML15154B401 

Finamore, Scott ML15158A243 

Firth, Walter ML15142A340 

Fischer, Quentin ML15162A781 

Fisher, Jack ML15139A837 

Fisher, Sarah ML15139A888 

Fisler, Mill ML15139A911 

Fitzgerald, Gerry ML15159A149 

Fitzke, Marion ML15142A340 

Fitzpatrick, Deirdre ML15139A940 

Fitzpatrick, Louis and ML15154A527 

Commenter ADAMS Accession # 

Patricia 

Flaherty, Jill ML15142A340 

Flanders, Gail ML15142A340 

Fletcher, Louise ML15159A284 

Flint, Vally ML15156A661 

Floersch, Elizabeth ML15162A792 

Floyd, Melanie ML15142A340 

Foley, Patricia ML15142A005 

Foster, Debbie ML15162A837 

Fowler, Luci ML15148B422 

Fox, Joyce ML15142A340 

Fox, Justin ML15142A340 

Fragela, Elizabeth ML15139A972 

Frank, Andrew ML15159B501 

Frederickson, Kelly 

Elizabeth ML15155B676 

Frelli, Gianfranco ML15142A340 

French, Lee Ann ML15156A660 

Friedman, Donna ML15160A940 

Fuchsman, Douglas ML15159A880 

Fullmer, Mark ML15158A056 

Fulwiler, Fran ML15142A337 

Fulwiler, Fran ML15142A340 

Fundby, Lone ML15142A340 

Futch, Patrick ML15142A340 

Gaal, Stephanie ML15142A340 

Gaarlandt, Jonathan ML15139A767 

Gaff, Mal ML15142A340 

Gaff, Mal ML15161A678 

Gagliardi, Michael ML15139A896 

Gallegos, Mark ML15142A340 

Galloway, Nancy ML15162A813 

Galvina, Inguna ML15162A093 

Garcia, Haydee ML15142A340 

Garcia, Joanna ML15142A340 

Garcia, Maria ML15162A231 

Garcia, Mary ML15142A340 

Garsson, Jane ML15162A820 

Gasco, Christine ML15155A161 

Gaskins, Melissa ML15142A335 

Gasser-Sanz, Eva ML15159B053 

Gaudry, Rita ML15142A340 

Geisheim, Roswitha ML15139A917 

Genn, Oliver ML15142A340 

Gentry, Kahla ML15139A865 

Gerosa, Robert ML15142A340 

Gerosa, Robert ML15162A748 

Gerwens, Shana ML15142A069 

Gestro, Patrizia ML15154A525 

Gibb, Bianca ML15139A869 

Gibson, Raymond ML15139A904 

Gibson, Sara ML15162A253 

Gideon, Barbara ML15158A269 

Gifford, Deborah ML15160A979 

Gilmore, Susanna ML15140A057 

Appendix E October 2016 E-643 NUREG–2176
Commenter ADAMS Accession # 

Giraldo, Gladys ML15142A340 

Glenn, Julie ML15161A677 

Glidewell, Marie ML15139A809 

Glorioso, Ellinor ML15162A414 

Gloyd, Susan ML15139A818 

Goetz, Janet ML15142A340 

Goldman, Eve ML15139A847 

Gonzalez, Iara ML15139A906 

Goodman, Ellen ML15162A794 

Goodman, Margaret ML15159A210 

Gordon, Alexandra ML15139A872 

Gordon, Amanda ML15156A225 

Gordon, Megan ML15142A340 

Gorges, Nadine ML15142A340 

Gould, Catherine ML15162A780 

Grage, Janina ML15142A340 

Graham, Guy ML15142A340 

Graham, Guy ML15162A073 

Graniello, Domenico ML15142A340 

Graniello, Domenico ML15162A512 

Graniello, Luciano ML15142A340 

Grasmugg, Franziska ML15142A340 

Grassi, Catherine ML15162A266 

Grassi, Catherine ML15162A266 

Gravuer, Elizabeth ML15139A884 

Grawunder, Marc ML15142A340 

Greene, Vaughan ML15142A340 

Grguric, Jackie ML15142A340 

Gries, Sylvia ML15142A340 

Griffin, Jr., Henry W. ML15142A340 

Griffin, Vivian ML15142A340 

Griffith, Randy ML15142A340 

Grill, Brock ML15142A340 

Grimes, Tara ML15139A814 

Grobler, Mariette ML15142A340 

Groh, Paul ML15142A008 

Gronemeyer, Kimberly ML15162A615 

Grossenbacher, John ML15139A921 

Grushko, Olga ML15162A291 

Guennar, K. ML15154C291 

Guggino, Monique ML15142A340 

Guzman, Tessi ML15142A340 

H., Manuel ML15142A340 

Habben, Nicholas ML15142A004 

Hager, Beverly ML15162A775 

Hague, Joy ML15160A917 

Haguel, Jane ML15155C131 

Haile, Randall ML15162A201 

Halkewycz, Ryan ML15155C154 

Hall, Dennis ML15139A732 

Hall, Dennis ML15142A340 

Hamilton, Dianna ML15142A340 

Hammock, Richard ML15142A340 

Hammond, Todd ML15159A502 

Hampton, S. ML15142A001 

Commenter ADAMS Accession # 

Hancock, Karen ML15142A340 

Handy, Erin ML15139A977 

Hankins, Judith ML15162A650 

Hanrahan, Mary ML15162A810 

Hansen, Bev ML15140A059 

Hanson, Laura ML15159A879 

Happenny, Peter ML15139A984 

Harker, Kathy ML15142A340 

Harney, Kathy ML15139A955 

Harper, Jim ML15142A340 

Harper, Rebecca ML15162A381 

Harris, Freya ML15142A340 

Hart, Terry ML15139A868 

Hartley, Cynthia ML15142A370 

Harvey, Geraldine ML15154B406 

Havener, Alice ML15140A048 

Havlik, Charles ML15154B395 

Havlik, Hugh ML15148B420 

Hawks, Whitney ML15162A632 

Hawlik, John ML15139A929 

Hay, Peter ML15139A765 

Hays, P. ML15156B157 

Hays, P. ML15156B444 

Hays, P. ML15159B091 

Hazen, Gail ML15142A340 

Headley, Linda ML15142A340 

Heinlein, Richard ML15142A340 

Hellmold, Harr ML15161A679 

Henao, Adela ML15139A931 

Hendershot, Tamara ML15148A810 

Hendry, Dawn ML15142A340 

Henize, Tina ML15142A340 

Hensgen, Eric ML15140A055 

Hermida, Daniela ML15140A054 

Hernandez, Amanda ML15156A219 

Hernandez, Dannette ML15139A794 

Herrera, Briseida ML15139A810 

Hickman, James ML15139A995 

Hicks, Barbara ML15155A294 

Hicks, Barbara ML15155A460 

Hicks, Connie ML15162A797 

Hill, Michael ML15159A804 

Hoang, Xuandai ML15139A992 

Hoeksema, Bruce ML15158A180 

Hoffman, Sue ML15142A011 

Hogan, Dennise ML15159A926 

Hogan, Dennise ML15159A929 

Hogan, Jack ML15148B410 

Hoin, Brigitte ML15142A340 

Holliday, Tricia ML15142A340 

Hollier, Fiona ML15142A340 

Hollon, Hollie ML15148A483 

Holmquist, Laurel ML15154C187 

Holton, John ML15142A340 

Holtzman, Lawrence ML15142A340 

Appendix E NUREG–2176 E-644 October 2016
Commenter ADAMS Accession # 

Holy, Kate ML15159B549 

Honore, Stephanie ML15162A640 

Hoodwin, Marcia ML15156B114 

Hope, Jane ML15142A340 

Hornaday, Sherral ML15142A340 

Horne, Paul ML15142A340 

Horvath, Elizabeth ML15142A340 

Horwath, Pamela ML15142A340 

Houde, Cathy ML15139A937 

House, Mark ML15142A340 

Houston, Meghan ML15159A395 

Hris, Angie ML15142A340 

Hubbard, Robin ML15156A048 

Hubbard, Ron L. ML15142A340 

Huey, Patrick ML15142A340 

Hughes, Karen ML15162A720 

Hughes, William ML15142A340 

Humphrey, Bente ML15160A964 

Hundemer, Sarah ML15142A333 

Hunkler, Lisa ML15139A821 

Hunt, Evan ML15142A375 

Hurley, Fredrika ML15142A340 

Hyland, Lillian ML15159A828 

Hylton, Marion W. ML15139A778 

Ibarra, Isabel ML15159A639 

Idesawa, Naoko ML15142A340 

Ierubino, Mary ML15142A340 

Inman, Linda ML15142A340 

Itzoe, Francis ML15139A842 

Jacobs, Celia ML15139B004 

Jacobs, Jenny ML15156B083 

Jacobs, Renee ML15162A678 

Jacobson, Ann ML15139A947 

Jakubzik, Petra ML15142A340 

James, Brenda ML15142A340 

James, Sarada ML15142A340 

Jankowski, Corinne ML15139A833 

Jannicelli, Barbara ML15153A668 

Janota, Linda ML15156A220 

Jaques, Diana ML15162A199 

Jarrett, Vera ML15142A340 

Jarvis, Michele ML15142A340 

Jennings, Jan ML15142A340 

Jensen, Norman ML15148B409 

Jett, Rachel ML15160A870 

Joannou, Jr., Benjamin ML15139A949 

Johansen, Matt ML15142A340 

Johnson, Darlene ML15155B850 

Johnson, Esther ML15153A987 

Johnson, Jacqueline ML15162A279 

Johnson, Libia ML15139A786 

Johnson, Richard ML15139A881 

Johnson, Shannan ML15148B413 

Johnson, Terry ML15148B426 

Jones, Christopher ML15140A065 

Commenter ADAMS Accession # 

Jones, Janice ML15162A549 

Jones, Jason ML15142A067 

Jones, Jeff ML15139A839 

Jordan-Vilanova, 

Hettie ML15142A340 

Juges, Jonathan ML15156A121 

Jungers, Carolann ML15160A850 

Kain, Laura ML15154B563 

Kalinová, Markéta ML15162A742 

Karkruff, Lee ML15142A340 

Karrmann, Dave ML15154A526 

Kawa, Sandra ML15159A283 

Kayser, Joan ML15162A401 

Kayyali, Susanne ML15142A202 

Keaney, John B. ML15139A938 

Keaton, Rebecca ML15155A438 

Keim, Mary ML15142A340 

Keisling, George ML15139A807 

Keller, Diann ML15142A340 

Kelley, Jeannette ML15158A121 

Kelly, Jean ML15142A340 

Kelly‐Banks, Patricia ML15139A913 

Kemp, Tasha ML15142A340 

Kemperle, Esther ML15142A340 

Kendall, Donna ML15148B414 

Kennedy, Tania ML15139A923 

Kerr, Anne ML15162A799 

Key, Laurence ML15142A340 

Khan, Rani ML15155A162 

Kibbe, Carolyn ML15162A768 

Kidd, Lori Beth ML15159A478 

Kiedis, Denise ML15139A893 

Killay, Sharon ML15139A864 

King, Charles ML15139A769 

King, Eileen ML15158A181 

King, Eileen ML15160A649 

King, John ML15142A340 

King, Marsha ML15139A859 

King, Roy I. ML15142A340 

Kirchner, Brooke ML15139A772 

Kirn, Steven ML15142A340 

Kiss, Carolyn ML15139A824 

Klayman, Joel ML15142A340 

Klien, Gabriele ML15142A340 

Knappman, Tanya ML15139A899 

Knight, Tina ML15154B397 

Knowles, Jerell ML15142A340 

Koch, Robin ML15142A336 

Kolbe, Daniela ML15142A340 

Kom, Willem ML15142A340 

Komin, Dmitriy ML15162A404 

Konigsberger, Kathryn ML15148B412 

Kovacs, Robert ML15139A942 

Kraut, Arthur ML15142A201 

Kraut, Michelle ML15139A797 

Appendix E October 2016 E-645 NUREG–2176
Commenter ADAMS Accession # 

Krawiecki, Susan ML15155C209 

Kreiner, Dennis ML15155A175 

Krieger, Barbara ML15142A340 

Krolick, Brian ML15139A952 

Kronholm, Linda ML15142A340 

Kropf, Keith ML15139A957 

Krygowski, Richard ML15140A019 

Kumar, Rahul ML15162A539 

Kuzina, Maria ML15153A667 

Kwetian, John ML15142A340 

LaBow, Charles ML15139A994 

LaChatte, Savanna ML15142A340 

Lagasca, Jeana ML15162A826 

Laieski, Caleb ML15162A675 

Lampka, Joseph ML15142A340 

Lanehart, Rheta ML15139A762 

Langdon, John ML15148A484 

Langford, Bob ML15139A885 

Laprade, Kenneth ML15139A908 

Lario, Rocio ML15139A991 

Larson, Cynthia ML15142A340 

Larson, June ML15162A189 

Lasahn, J. ML15162A392 

Laslie, Mary Lou ML15142A340 

Latham, Cathy ML15142A340 

Lawler, Ruth E. ML15142A340 

Lawrence, Clifford ML15154C171 

Lawrence, Diane ML15155C249 

Lazzarino, Carol ML15139A795 

Learch, Lynn ML15156B389 

Leavitt, Meaghan ML15142A340 

Leclerc, Marc ML15162A698 

LeDent, Jamie ML15142A340 

Lee, Jean ML15139A993 

Lefkowitz, Jill ML15139A749 

Leisey, Tamara ML15159A107 

Lemoine, Lizzie ML15162A769 

Lepikkö, Tanja ML15142A340 

Levi, Anna‐Lina ML15142A015 

Levitt, Michael ML15142A340 

Levitt, Michael ML15162A254 

Levy, B. ML15142A340 

Lewis, JoAnn ML15156B442 

Lewis, Larry ML15142A340 

Lewis, Mary ML15142A340 

Lewis, Nita ML15139A855 

Lewis, Norman ML15142A340 

Lieberman, Marah ML15156A047 

Lieurance, Cynthia ML15139A793 

Lillich, Anthony ML15155A171 

Lillywhite, Harvey ML15142A340 

Lindner, Diane ML15142A340 

Lindsay, David ML15142A340 

Lindsay, Marion ML15142A340 

Lindsay, Marion ML15162A191 

Commenter ADAMS Accession # 

Link, Diana ML15162A042 

Lintner, Lawrence ML15142A340 

Linton, Brandy ML15142A000 

Lippincott, John ML15162A838 

Lippner, Linda ML15148B418 

Livingston, Nancy ML15159A827 

Lockard, Donald ML15142A340 

Loftus, William ML15139A918 

Lomascolo, Suzanne ML15154B417 

Long, Jacquelyn ML15142A340 

Lopes, Ana ML15142A340 

Lopez, Yahaira ML15158A179 

Lorenzo, Carlos ML15159B579 

Love, Dee ML15139A890 

Lovett, Kirsten ML15156A088 

Lowell, Jen ML15139A870 

Lucas, Addie ML15154B414 

Lucas, Mark ML15155A172 

Lucido, Angela ML15159A397 

Lujan, Crystal ML15142A340 

Lunde, Lauren ML15142A340 

Lympius, Frauke ML15142A340 

Lynley, Lauren ML15142A340 

Lynn, Pam ML15159A396 

M., Lynda ML15140A058 

M., Pino ML15142A340 

MacFarlane, Adrienne ML15156A657 

MacFarlane, Shari ML15139A823 

MacInnes, Brenda ML15155C072 

Mack, Jean ML15159A263 

Maddock, June ML15142A340 

Maene, Sylvia ML15142A340 

Magaña, Kenneth ML15162A745 

Maher, M. ML15139A953 

Maji, Rosanne ML15142A340 

Malagon, Leticia ML15158A238 

Malott, Randy ML15142A340 

Maltbie, Anne Marie ML15142A340 

Manes, Regina ML15142A340 

Maness, Barbara ML15142A210 

Marie, Shari ML15156A467 

Marinelli, Antonella ML15142A340 

Marinelli, Antonella ML15162A486 

Marques, Jorge ML15142A340 

Marsh, Sherry ML15162A164 

Marsh, Suzanne ML15139A777 

Marshall, David ML15142A072 

Martin, Ashley ML15148B416 

Martin, Gayle ML15142A340 

Martin, Robin ML15142A340 

Martin, Samuel ML15142A340 

Martin, Timothy ML15139A841 

Martinez, Fay ML15158A120 

Martins, Claudia ML15139A956 

Masarati, Piero ML15142A340 

Appendix E NUREG–2176 E-646 October 2016
Commenter ADAMS Accession # 

Massar, Marc ML15139A831 

Massar, Marc ML15139A832 

Masse, Kierstin ML15142A340 

Massetti, J. ML15162A349 

Massey, Linda ML15142A340 

Mastrototaro, 

Domenico ML15162A293 

Mathews, Mary ML15162A830 

Matthews, Wade and 

Betty ML15159A578 

Mattison, Stephen ML15139A820 

Mayer, Ramona ML15139A802 

Mays, Constance ML15139A882 

Mazzarella, Rebecca ML15142A007 

Mc vay, Margaret ML15162A161 

Mcalister, Suzann ML15139A850 

McAlpine, Tracy ML15160A718 

Mccallin, Marissa ML15142A340 

McCarthy, Louise ML15160A965 

McCarty, Valerie ML15139A844 

McClasky, Stephen ML15159A667 

McCray, Toni ML15162A672 

Mcdow, Derek ML15142A340 

McGinn, Keven ML15162A038 

McGinty, Jacquelyn ML15162A174 

Mcgovern, L. ML15142A002 

McKenna, Sarah ML15142A340 

McMillan, Douglas ML15159A585 

McMillan, Joanne ML15139A941 

McMillan, Katherine ML15142A340 

McNeil, Kerry ML15139A736 

McNeil, Kerry ML15142A340 

McNicol, Lottie ML15159B484 

McPherson, Andrew ML15142A340 

Mcquade, Linda ML15156A221 

Medders, Melissa ML15160A855 

Meegan, Colleen ML15142A340 

Melegari, David ML15139A768 

Mercer, John & 

Saundra ML15162A157 

Merino, Aimee ML15162A160 

Merrick, Thomas ML15162A204 

Mes, Ferry ML15142A340 

Metzger, Harvey ML15160A851 

Meyer, Dawn ML15148A485 

Michel, Paul ML15154B394 

Mick, Rick ML15142A340 

Mickler, Walt ML15139A745 

Milian, Yosniel ML15158A058 

Miller, Ann ML15142A340 

Miller, Caroline ML15158A209 

Miller, Christopher ML15142A340 

Miller, Diane ML15139A849 

Miller, Dianne ML15159A331 

Miller, J. ML15139A902 

Commenter ADAMS Accession # 

Miller, Mary ML15142A340 

Miller, Meghan ML15139A854 

Miller, Robin ML15139A862 

Miller, Stacie ML15161A675 

Millett, Cheryl ML15154C169 

Minacheili, Susanna ML15142A340 

Minor, Shannon ML15139A792 

Mira, Mark ML15142A340 

Misicka, Ed ML15139A789 

Mitchell, Marilynn ML15142A340 

Mitts, Karen ML15159B562 

Mizrachi, Robyn ML15142A340 

Moats, Paula ML15162A090 

Mohseni, Leila ML15162A758 

Mollberg, W. ML15142A340 

Monroe, Katrina ML15139A782 

Moore, Mercedes ML15142A340 

Morais, Bonnie ML15162A162 

Morgan, Paula ML15139A966 

Morgan, Paula ML15142A340 

Moriarty, Karen ML15159A253 

Morrison, Barb ML15139A747 

Morse, Kathryn ML15142A340 

Moser, Prairie ML15162A579 

Moss, Vickie ML15162A096 

Mothley, Drucilla ML15139A928 

Moyers, Michele ML15154B405 

Mulcare, James S. ML15142A340 

Mumaw, John ML15154C247 

Munn, Enid ML15162A677 

Munoz, Alejandro ML15142A340 

Murphy-Larronde, 

Suzanne ML15142A340 

Myers, David Russell ML15142A373 

Myers, Michelle ML15142A340 

Nafarrate, Nancy ML15142A340 

Natali, Nts ML15142A340 

Navarro, Matilde ML15162A561 

Nece, Melissa ML15161A655 

Neckes, Shannon ML15154B398 

Neimark, Debbie ML15140A137 

Nelson, Emily ML15142A340 

Nelson, Jeena ML15156A466 

Nelson, Peggy ML15139A791 

Nersesian, Colleen ML15162A502 

Ness, Chris ML15162A046 

Neste, Lisa ML15142A340 

Newsom, Glenda ML15139A776 

Nguyen, Michelle ML15162A270 

Nicklas, Andrea ML15142A338 

Nierenberg, Susan ML15162A709 

Nixon, Peter ML15159A583 

Noble, Amanda ML15139A861 

Norsworthy, Julie ML15159A264 

Nualchawee, ML15142A340 

Appendix E October 2016 E-647 NUREG–2176
Commenter ADAMS Accession # 

Rungruedee 

Nyerick, Gary ML15139A774 

Obenchain, Helen ML15148A821 

Oberdorf, Robert ML15139A933 

O'Brien, Shannon ML15142A340 

Oelman, Robert ML15142A340 

Ohland, Andreas ML15142A003 

O'Laughlin, Elizabeth ML15162A700 

O'Leary, Suzanne ML15142A340 

Oliver Smith, Jennifer ML15139A927 

Olivia, Ana ML15159B341 

Olmstead, Daniel ML15162A823 

Oppenhuizen, Kathy ML15142A340 

Ornee, Mary ML15139B002 

Ornee, Mary ML15162A846 

Osborne, Diana ML15139A846 

Osborne, Martin ML15139A939 

Osorno, Juan ML15153B040 

Osterhoudt, Bettie ML15160A736 

Oswald, Allan ML15139A784 

Ott, Michael ML15142A340 

Ott, Michael ML15139A735 

P., T. ML15142A340 

P., Victoria ML15142A340 

Pachina, Maria ML15162A378 

Pachios, Darlene ML15142A340 

Palladine, Michelle ML15162A669 

Pallatino, Mary ML15162A503 

Pallatino, Mary ML15162A505 

Papaioannou, Kostis ML15162A761 

Papworth, Carol ML15156B113 

Parker, Julianne ML15142A340 

Parkinaon, Robert ML15139A743 

Parra, Dolores ML15142A203 

Patch, Frances ML15158A239 

Paul, John ML15139A910 

Paul, Laura ML15142A340 

Paulet, Virginia ML15156A656 

Pe, Dani ML15139A805 

Pearlman, Marie ML15154C166 

Pearlmutter, Nancy ML15154C167 

Pecha, Richard ML15162A372 

Peranio-Paz, Giana ML15142A340 

Percy, Leo ML15139A808 

Perry, Marian ML15156A821 

Peter, Judith ML15142A340 

Peterson, Patricia ML15156A823 

Petlack, Howard ML15142A340 

Petrus, Veronica ML15156A292 

Petty, Kevin ML15142A340 

Phelps, Ellen ML15139B003 

Phillips, Jennifer ML15159A247 

Phillips, Jim ML15162A127 

Pickard, Alexandria ML15159A966 

Pierce, Tanya ML15139A878 

Commenter ADAMS Accession # 

Pike, Evette ML15142A010 

Piner, George ML15142A340 

Piper, Janna ML15161A650 

Pirotte, Danielle ML15142A340 

Pirotte, Danielle ML15162A601 

Pitchford, Victoria ML15142A340 

Pittea, Chetna ML15162A556 

Plisko, Vladimir ML15156B111 

Poiani, Maria ML15139A889 

Poindexter, Tawnee' ML15159A270 

Pomeroy, Linda ML15155C206 

Pond, Christopher ML15142A340 

Pond, Christopher ML15162A537 

Pope, Alexine ML15140A020 

Pope, Donna ML15160A988 

Porcelli, Angela ML15156A572 

Porter, Donald J. ML15139A780 

Porter, Mark ML15162A132 

Posch, Robert ML15142A340 

Posner, Jessica Jean ML15162A185 

Prada, Francesca ML15161A662 

Pratt, Fred ML15139A980 

Preston, Apryl ML15139A968 

Preston, Apryl ML15139A985 

Preston, Dee ML15142A340 

Preston, Robin ML15142A340 

Printz, Jackie ML15139A801 

Pritchett, Ellouise ML15140A063 

Pritchett, William ML15139A892 

Proulx, Michelle ML15142A340 

Provchy, Gregory ML15162A232 

Prunhuber, Carol ML15142A368 

Pullaro, Barbara ML15139A788 

Pusek, Jasminka ML15142A340 

Quaintance, Charles ML15142A340 

Quaritius, Karen ML15142A340 

Quillen, River ML15159A499 

Raab, Elizabeth ML15142A340 

Rabin, Patr ML15142A340 

Rader, Kyle ML15142A340 

Raganato, Alessandro ML15162A689 

Rainey, Ann ML15156A464 

Ralph, Kathy ML15159B560 

Ramage, Jennifer ML15140A146 

Ramirez, Sally ML15162A796 

Ramon, Laura ML15159A501 

Ramos, Jaime ML15142A340 

Randler, John ML15142A340 

Rapp, Daniel ML15159A106 

Rausher, Hilary ML15139A950 

Ravine, Devon ML15156A223 

Rayburn, Tammie ML15153B039 

Reed, Alaina ML15139A967 

Reeves, Diana ML15148B415 

Rego, Sonia ML15156B078 

Appendix E NUREG–2176 E-648 October 2016
Commenter ADAMS Accession # 

Reichert, Robyn ML15159A503 

Reilly, Mary ML15141A484 

Reilly, Mary ML15162A203 

Reining, Francis ML15148A808 

Remington, L. ML15161A628 

Reynolds, Helen ML15153A665 

Rhein, Brenton ML15142A340 

Ribokas, Robert ML15162A782 

Rich, Laura ML15142A340 

Richardson, K. ML15158A016 

Richmond, Michael ML15142A340 

Ridgway, Kathi ML15162A751 

Rindler, Joseph ML15142A340 

Ripple, Jeff ML15159A271 

Rivera, Ed ML15142A340 

Rivera, Emma ML15162A756 

Rivera, Hilda ML15139A754 

Rivera, Hilda ML15142A340 

Roberts, Phil ML15139A790 

Robinett, Margaret 

Christine ML15162A156 

Robins, Michael ML15142A340 

Robinson, Darlene ML15140A053 

Robinson, Janet ML15142A340 

Robledo, Olga ML15139A838 

Roderigues, Mr. & Mrs. 

Dennis ML15142A340 

Rodrigues, Snndra ML15139A919 

Rodriguez, L. ML15142A340 

Roehl, Richard Ralph ML15142A340 

Roffe, Jessica ML15139A903 

Rogers, Carrie ML15160A854 

Rogers, Dirk ML15142A340 

Rollings, Rusty ML15142A372 

Roman, Christina ML15142A065 

Romero, Cristy ML15162A508 

Rosa, Sam ML15139A873 

Rosado, Val ML15142A340 

Rose, Lawrence ML15140A060 

Rose, Mary ML15139A999 

Ross, Kathy ML15142A340 

Ross, Rachel ML15162A685 

Rothman, Mitzi ML15142A340 

Rothstein, Richard ML15155B899 

Routh, Jeffrey ML15142A340 

Routh, Jeffrey ML15139A750 

Rowell, Edward ML15139A965 

Rozo, Carolina ML15142A340 

Rubin, Joan ML15139A976 

Rudner, Patricia ML15162A380 

Rudolph, John ML15139A996 

Ruhl, Geri ML15142A340 

Rusinko, Stephen ML15139A787 

Russo, Andy ML15139A759 

Russo, M. R. ML15142A340 

Commenter ADAMS Accession # 

Ryan, Allan ML15148B417 

Ryan, Marian ML15139A746 

Sabol, Barbara ML15139A958 

Sadiq, Tracey ML15139A827 

Sadura, Judith ML15142A340 

Sagovac, Emily ML15140A050 

Salgado, Natasha ML15142A340 

Saluja, Virginia ML15139A932 

Salyers, Helen ML15162A666 

San Socie, Robert ML15142A340 

Sander, Susan ML15162A784 

Sandulovic, Desanka ML15142A340 

Santiago, Rebeca ML15142A340 

Satiro, Cathy ML15142A340 

Savopoulos, Paskalini ML15162A303 

Scarbeck, Christopher ML15162A785 

Schaaf, William ML15142A340 

Schackney, Stephanie ML15142A340 

Scheffley, Helen ML15159B425 

Schildwachter, Steve ML15142A340 

Schloss, Morley ML15142A340 

Schnabel, Arthur ML15142A340 

Schnee, Jane ML15142A340 

Schneider, Cheryl ML15162A153 

Scholl, Linda ML15162A809 

Schollhorn, Maria 

Teresa ML15142A340 

Schultes, Yolanda ML15142A340 

Schultze, Patti ML15142A340 

Schwarz, Robin ML15142A340 

Scott, Joan ML15162A707 

Scott, Judith E. ML15142A340 

Scott, Lorrie ML15142A340 

Scott, Robin ML15142A340 

Scott, Wenona ML15142A340 

Scott, Wenona ML15162A560 

Scully, Rosemary ML15142A340 

Sebesta, Doyle ML15142A340 

Semmelhaack, Carl ML15162A052 

Sequeira, Kathleen ML15142A014 

Serne, S. ML15154C170 

Serra, Ruth ML15142A340 

Serrano, Tahimi ML15140A064 

Severino, Susan ML15160A928 

Shamis, Elliot ML15139A912 

Shank, Nancy ML15139A857 

Sharbaugh, Thomas ML15139A763 

Sharkeu, Bradley ML15142A340 

Sharrer, Brian ML15139A875 

Sheard, Sue ML15162A832 

Sheets, Aida ML15139A752 

Sheets, Aida ML15142A340 

Shero, Dale ML15155B022 

Shifflett, Jr., James E. ML15156A090 

Shultis, Bob ML15142A340 

Appendix E October 2016 E-649 NUREG–2176
Commenter ADAMS Accession # 

Siano, Kelly ML15161A680 

Siegel, Ruth ML15162A354 

Sierchio, Debbie ML15142A340 

Sierra, Juan Carlos ML15139A960 

Sill, K. ML15139A987 

Simkins, Dave ML15139A959 

Simmons, Haley ML15142A340 

Simontacchi, Alexis ML15162A835 

Sims, Nancy ML15142A340 

Sinclair, David ML15139A961 

Skelton, Laura ML15142A340 

Slowey‐Thomas, 

Dianna ML15162A276 

Smith, A. ML15139A811 

Smith, Angela ML15155B020 

Smith, Betsy D. ML15162A125 

Smith, Donna ML15159B335 

Smith, Greg ML15142A340 

Smith, Janet ML15162A721 

Smith, Jr., William M. ML15142A340 

Smith, Karen ML15139A891 

Smith, Karen ML15139A914 

Smith, Kenneth ML15142A340 

Smith, Linda ML15139A817 

Smith, Melissa ML15162A841 

Smith, Wendy ML15142A340 

Smyth, Teri ML15142A340 

Snowe, Sandy ML15139A851 

Snyder, Lynn ML15139A798 

Soden, Mary ML15139A989 

Sokol, Abbey ML15155B900 

Solomon, Laura ML15142A340 

Sophie, Grosbois ML15139A766 

Soteropoulos, Patricia ML15142A340 

Sotomayor, Nora ML15162A149 

Sowden, Bruce ML15162A439 

Spencer, Susan ML15162A648 

Spigel, Sue ML15139B000 

Spotts, Richard ML15142A340 

Sprano, Barbara ML15162B091 

Sprecher, Cindy ML15142A340 

Sprecher, Cindy ML15162A145 

Sprecher, Cindy ML15162A746 

Squire, Julie ML15162A764 

Srivastava, Suneet ML15142A340 

Stafford, Heather ML15142A334 

Stahl, James and Kay ML15139A852 

Standing, Barbara ML15162A228 

Stapelfeldt, Horst ML15155C073 

Stapleton, Judy ML15142A340 

Starr, Lawrence ML15139A916 

Stefanova, Silviya ML15162A220 

Steffen, Shirley ML15142A340 

Steigerwaldt, 

Samantha ML15154B416 

Commenter ADAMS Accession # 

Stevens, Patricia ML15142A340 

Stevens, Robert ML15142A340 

Stevenson, Richard ML15139A962 

Stevenson, Richard ML15139A963 

Stewart, Jacqueline ML15162B091 

Stewart, Jacqueline ML15162B148 

Stewart, Marlin ML15139A856 

Stickel, Gary ML15159A492 

Stickel, Gary ML15159A494 

Stone, James ML15139A830 

Stone, Susan ML15158A119 

Strack, Daniel ML15155B807 

Strader, Helen ML15142A340 

Strobel, Sabine ML15139A760 

Struck, Caroline ML15142A340 

Suchy, Robin ML15142A340 

Sullivan, Gretchen ML15162A829 

Sullivan, Susan ML15142A340 

Sulprizio, Karen ML15142A340 

Summers, Janine ML15139A825 

Summers, Sandi ML15142A340 

Sunde, Lill‐Jeanette ML15162A771 

Sunderland, Felicia ML15156B390 

Sunfire, Michael ML15148A812 

Sweeten, Brittany ML15160A939 

Swoboda, Lois ML15139A729 

Swoboda, Lois ML15142A340 

Swystun, Lydia ML15139A753 

Swystun, Lydia ML15142A340 

T., Mandi ML15142A340 

Tainio, Coe ML15140A056 

Tairova, Olga ML15159A231 

Tamborello, Isidoro ML15142A340 

Tardif, Mark ML15142A340 

Tarpinian, Karina ML15142A340 

Tatgenhorst, Joy N. ML15159A246 

Taylor, Kay ML15148B425 

Taylor, Walter ML15158A017 

Temple, Laurel ML15162A192 

Tempone, Antonio ML15142A340 

Tenhouten, Warren ML15162A194 

Terrier, Bernard ML15162A770 

Thayer, Mostyn ML15139A843 

The U. family, ML15139A925 

The U. family, ML15161A684 

The U. family, ML15162A394 

The U. family, ML15162A399 

The U. family, ML15162A844 

The U. family, ML15162A845 

Thollaug, Julia ML15139A946 

Thomas, Carrie ML15142A340 

Thompson, Brenda ML15162A787 

Thompson, Kate ML15162A368 

Thuline, James ML15139A799 

Tirado, Luis ML15156A826 

Appendix E NUREG–2176 E-650 October 2016
Commenter ADAMS Accession # 

Titilah, Jennifer ML15162A789 

Togati, Joanne ML15142A340 

Tomkins, Cassandra ML15159A479 

Tompetrini, Phil ML15139A905 

Torquato, Bruno ML15139A924 

Torres, Marcos ML15159A965 

Totan, Dan ML15142A340 

Tran, Dat ML15162A135 

Traub, Susan ML15142A340 

Travers, L. J. ML15162A834 

Travis, Michael ML15154A522 

Tremblay, Nancy ML15142A340 

Trent, Sharon ML15142A340 

Triana, Jennifer ML15156B443 

Triff, Asdur ML15142A374 

Trudeau, Stephanie ML15142A332 

Tucker, Barbara ML15155A478 

Tudorache, Lynette ML15162A367 

Turner, Ted ML15154B413 

Turney, Lynda ML15156B387 

Tutko, Jackie ML15142A340 

Tweedy, Mary ML15211A055 

Updike, Carl ML15142A340 

Urbanek, Adele ML15142A340 

Valencia, Suzanne ML15159A016 

Valencia, Suzanne ML15159A017 

Valencia, Suzanne ML15159A018 

Valero, Maudie ML15162A039 

Vallender, Andrew ML15142A340 

Van Vleet, Rodney ML15142A340 

Vandal, Lise ML15142A340 

Varanitsa, Oleg ML15156B474 

Vargo, Gabriel ML15139A898 

Vartanian, Carol ML15142A340 

Vaughn, Matt ML15139A822 

Veach, Deb ML15142A066 

Veltkamp, Robert ML15142A330 

Vennett, Sean ML15139A982 

Vessicchio, Susan P. ML15162A755 

Vieira, Barbara ML15142A340 

Vieira, Ed ML15142A340 

Villanueva, Vivian ML15154C172 

Villar, Michelle ML15139A971 

Villarnovo, Victoria ML15162A057 

Villaverde, Kristina ML15158A057 

Vines, Jimmy ML15139B005 

Vivero, Daniel ML15156A468 

Voris, Stephanie ML15142A340 

Voss, Skyler ML15162A265 

Vries, M. ML15142A340 

Vuotto, Karla ML15142A340 

W., C. ML15162A514 

Wachowiak, Mark ML15156A658 

Wade, Karen ML15159A519 

Walker, John ML15142A340 

Commenter ADAMS Accession # 

Walker, Leanne ML15159A255 

Walker, Leanne ML15159A257 

Walker, Lynne ML15162A547 

Walker, Terry ML15158A093 

Walker, William ML15139A758 

Wall, James ML15155A836 

Wall, Regina ML15142A340 

Wallace, Larry ML15139A815 

Wallace, Steve ML15156B322 

Walper-Taylor, James ML15142A340 

Walsh, Ellen ML15158A092 

Walters, Kenneth ML15142A340 

Walters, M. ML15142A073 

Walters, Sandra ML15142A340 

Waltrip, Laura ML15142A340 

Ward, Diana ML15139A983 

Warrington, Thomas ML15139A879 

Wasko, Tara ML15139A874 

Watson, Chris ML15162A760 

Watts, Cynthia ML15139A876 

Watts, Cynthia ML15139A877 

Way, Karen ML15162A808 

Weaver, George ML15140A173 

Weber, Gae ML15142A006 

Weber, Steve ML15142A340 

Weckering, Daniel ML15142A340 

Weinkle, Gary ML15139A816 

Weisberg, Edmund ML15162A766 

Weisman, Milt ML15142A340 

Weiss, Arwen ML15142A340 

Weisser-Lee, Melinda ML15148A806 

Welles, Diane ML15160A648 

Wentz, Pat ML15142A340 

Wenzel, Tom ML15162A850 

Wheeler, Cynthia ML15159B561 

Widdowson, John ML15139A886 

Wiechec, Christina ML15162A822 

Wiehemeijer, Robert ML15142A340 

Wieland, Martin ML15155C022 

Wildner, Andrea ML15142A340 

Wilkinson, Ian ML15155A753 

Williams, Alek ML15155C090 

Williams, Brigida ML15162A694 

Williams, Caroline ML15159A172 

Williams, Celia ML15156A659 

Williams, Dodie ML15142A340 

Williams, Freddie ML15142A340 

Williams, Linda ML15142A340 

Williams, Marjorie J. ML15142A340 

Williams, Stephen L. ML15142A340 

Williamson, Judith ML15142A340 

Willis, Jennifer ML15142A340 

Wilson, Kerri ML15142A340 

Wilson, L. ML15139A998 

Wilson, Winn ML15142A340 

Appendix E October 2016 E-651 NUREG–2176
Commenter ADAMS Accession # 

Wilson, Winn ML15162A687 

Windle, A. ML15142A340 

Winick, Dorothy ML15139A834 

Winicki, Anne ML15142A340 

Winters, Margueritta ML15142A340 

Wolf, Chantal ML15142A340 

Wolf, Darlene ML15139A979 

Wolf, Davis ML15139A981 

Wolle, Heather ML15142A340 

Wolter, Manuela ML15142A340 

Woo, Regina ML15154B407 

Wood, Ruby ML15142A340 

Woodard, Bennie ML15142A340 

Woodlief, Ann ML15162A815 

Woods, Sherry ML15142A340 

Woods, Teresa ML15154A807 

Workman, Mary ML15142A340 

Workman, Wickard ML15142A340 

Wortham, Michael ML15142A340 

Worthington, Nathalie ML15142A340 

Commenter ADAMS Accession # 

Wu, Miki ML15142A340 

Yaffee, Steve ML15162A817 

Yanez, Mario ML15156A462 

Yantselovskiy, 

Alexandr ML15142A340 

Yashirin, Nick ML15139A744 

Yazdi, T. ML15162A184 

Yoo, Sunnah ML15148B411 

Youd, Mark ML15139A988 

Young, Karen ML15156B080 

Young, Mary ML15156B158 

Zagar, Virginia ML15155A170 

Zarzycka, Alexandra ML15162A424 

Zebracki, Nancy ML15142A340 

Zella, Donna ML15139A943 

Zimmermann, Karin ML15142A340 

Zintel, Angelika ML15142A340 

Ziring, Sidney ML15156B117 

Zuckerman, Arlene ML15142A340 

Zuckerman, Barry ML15140A061 

Table E-10. Individuals Submitting with Subject “Support the ‘No Action’ Alternative” 

with Correspondence ID TURK-COL6&7-DR-00104 and Representative 

ADAMS Accession No. ML15140A141 (Multiple Authors 2015-TN4720)

Commenter 

ADAMS 

Accession # 

achtung@znaut.com ML15162A926 

Aghayan, Veronic ML15196A484 

Albrecht, Lonnie ML15196A072 

Anderson, Kelley ML15195A030 

Anderson, Vaughn ML15141A262 

Anderson, Vaughn ML15195A631 

Anderson, Vaughn ML15162A942 

Anderson, William ML15160A702 

Aponte, Jonathan ML15201A468 

Ayers, Randall ML15196A496 

Baird, Melissa ML15195A630 

Balfour, Joan ML15195A046 

Balfour, Joan ML15195A589 

Barnes, Janice ML15195A188 

Battin, John ML15198A547 

Bell, Angela ML15162A923 

Bellamy, Ray ML15198A545 

Bolen, D. K. ML15162A924 

Bolen, D. K. ML15195A170 

Bordonaro, Jo ML15195A597 

Born, Deborah L. ML15159B483 

Bowden, Deanna ML15162A405 

Bowman, Kenneth ML15195A611 

Bowman, Kenneth ML15196A060 

Brady, Meaghan ML15195A638 

Braley, Brian ML15197A044 

Commenter 

ADAMS 

Accession # 

Brexel, Sr., Charles ML15197A051 

Bromley, Gary ML15201A470 

Broughton, Janet ML15162A418 

Brown, Allie ML15198A533 

Bucolo, James ML15195A159 

Burgess, Candice ML15162A496 

Burns, Mary ML15196A467 

Byars, Rain ML15162A917 

Campbell, Grant ML15160A078 

Campbell, Linda ML15198A517 

Campbell, Susan ML15195A562 

Carver, Pat ML15198A503 

Catalina, Janet ML15196A071 

Colby, Helen ML15196A154 

Collins, Denise ML15201A471 

Constantino‐Martin, Patti ML15160A521 

Cook, Kevin ML15201A465 

Corbin, Randy ML15160A538 

Craciun, George ML15196A054 

Curci, James ML15195A646 

De Nolf, Susan ML15195A717 

de Sart, Marci ML15198A515 

Debus, John ML15198A532 

Deddy, John ML15195A650 

Detrick, Mary ML15161A649 

Detrick, Mary ML15195A033 

Appendix E NUREG–2176 E-652 October 2016
Commenter 

ADAMS 

Accession # 

dsinclair2013@hotmail.com ML15196A477 

Dunn, Elmo ML15195A652 

Dunn, Wendy ML15195A640 

Dunn, Wendy ML15196A075 

Duval, Ruthann ML15196A124 

Easter, Jeffrey ML15195A591 

Enfield, David ML15142A383 

Family, Manzi ML15198A509 

Fernandez, Maria ML15160A553 

Foster, Winnie ML15159B548 

Frederick, Diana ML15141A264 

Friedman, Donna ML15198A506 

Frotscher, H. David ML15160A668 

Frotscher, H. David ML15160A679 

Fults, Jason ML15140A141 

Fults, Jason ML15196A165 

Gibson, David ML15162A490 

Gifford, Bonnie ML15162A409 

Glenn, Martha ML15195A627 

Glickman, Susan ML15198A530 

Gutierrez, Kim ML15159B503 

Hall, Dennis ML15195A567 

Hallman, Janice ML15196A052 

Hamilton, Dianna ML15196A055 

Harsin, Linda ML15195A124 

Haun, Pamela ML15162A493 

Headley, Linda ML15162A928 

Henderson, Maria ML15159B516 

Henderson, Maria ML15162A856 

Henderson, Maria ML15195A137 

Hendrix, Kia ML15160A049 

Hensgen, Eric ML15160A701 

Hensgen, Eric ML15196A253 

Hollister, David ML15162A494 

Hollister, David ML15197A050 

Hoodwin, Marcia ML15198A571 

Howard, Karen ML15196A085 

Hung, Shiu ML15195A621 

Jennings, Cara ML15162A489 

Jennings, Sid ML15195A709 

Johnson, Diane ML15196A475 

Jones, Susan ML15159B456 

Kahn, Nancy ML15198A546 

Kapp, Bill ML15195A584 

Kasenow, Lisa ML15159B532 

Keeley, Robert ML15195A636 

Kerkhoff, Joyce ML15162A497 

Kerkhoff, Joyce ML15162A889 

Kerkhoff, Joyce ML15196A092 

Kerr, Earl ML15162A862 

Khajeh-Noori, Jeri ML15196A128 

Khajeh‐Noori, Jeri ML15162A951 

King, Michele ML15196A497 

Kluson, Forrest ML15160A589 

Commenter 

ADAMS 

Accession # 

Knight, David ML15195A174 

Kollbach, Anja ML15197A048 

Kramer, Richard ML15196A255 

Kwo, Ken ML15160A735 

Levin, Monnie ML15195A579 

Lightfoot, Martha ML15201A469 

Linden, Susan ML15160A059 

Luke, Keth ML15195A564 

Marchand, Babs ML15196A086 

Marder, Karen ML15196A471 

Margeson, Don ML15195A120 

Maricque, Mitchell ML15196A252 

Mariotte, Michael ML15196A095 

Marold, Doran ML15195A144 

Marold, Doran ML15195A614 

Martin, Drew ML15160A719 

Martinez, Judith ML15195A707 

Massar, Marc ML15195A573 

Mawhinney, John ML15195A625 

Mayotte, Monica ML15159B458 

Mazuca, Frank ML15196A074 

McClasky, Stephen ML15197A041 

McGlone, Colleen ML15160A692 

McGlone, Colleen ML15195A574 

Mejides, Andres ML15197A045 

Meyer, Colonel ML15195A172 

Meyer, Colonel ML15195A590 

Meyer, Colonel ML15195A653 

Michel, Paul ML15195A639 

Miller, Michele ML15198A524 

Milne, Martha ML15196A134 

Minniss, Regina ML15162A501 

Montesi, Toni ML15159B453 

Moore, Jeannine ML15159B547 

Moore, Jeannine ML15162A935 

Moore, Jeannine ML15195A713 

Moss, Eric ML15162A940 

Mumaw, John ML15196A468 

Nelson, Toni ML15162A419 

Nicholson, Carol ML15195A705 

Novotny, Jan ML15196A076 

O'Brien, Robert ML15196A485 

Oster, Teresa ML15160A552 

Paleias, Linda ML15162A910 

Paleias, Linda ML15196A499 

Patten, Elaine ML15162A425 

Pattison, Janet ML15195A578 

Pellegrini, Robert ML15196A149 

Peter, Judith ML15195A063 

Plockelman, Cynthia ML15160A077 

Porretto, Nick ML15162A915 

Pratt, Richard ML15162A907 

Prexl, Esther ML15195A647 

Price, Sue ML15196A166 

Appendix E October 2016 E-653 NUREG–2176
Commenter 

ADAMS 

Accession # 

Riley, Russell ML15195A184 

Rilling, Fred ML15162A943 

Rilling, Fred ML15195A601 

Rilling, Fred ML15198A525 

Robbin, Valerie ML15160A050 

Roberts, J. P. ML15196A155 

Rock, Andrew ML15198A542 

Rogers, Maureen ML15195A629 

Rowell, Edward ML15196A146 

Rowell, Edward ML15196A147 

S., C. ML15195A603 

S., J. ML15196A465 

Sabol, Barbara ML15162A899 

Saunders, Suzanne ML15195A582 

Scionti, Cynthia ML15197A052 

Scott, Jennifer ML15204A734 

Scott, Jennifer ML15162A072 

Scott, Jennifer ML15195A561 

Sechrist, Linda ML15195A167 

Shafchuk, Patsy ML15195A571 

Shaw, Donald ML15195A047 

Shetler, Terry ML15195A587 

Smith, Brenda ML15162A903 

Smith, Jody ML15189A035 

Smith, Leigh Emerson ML15162A432 

Sockloff, Judith ML15162A906 

Commenter 

ADAMS 

Accession # 

Southern, Tom ML15198A513 

Stallworth, Alicia ML15198A572 

Stansbery, Mark ML15195A605 

Stokes, Bill ML15162A893 

Stoll, Maria ML15195A181 

Stone, James ML15196A073 

Storino, Michael ML15195A642 

Stuchly, Ryan ML15196A103 

Tatum, James ML15198A518 

Thomas, John ML15162A941 

Tiano, Michael ML15160A060 

Tomi, Joseph ML15159B454 

Truesdell, Terrence L. ML15159B480 

Upchurch, Sandra ML15159B482 

Upchurch, Sandra ML15162A950 

Usinger, Gary ML15159B580 

Usinger, Gary ML15195A166 

Vennett, Sean ML15196A131 

Ward, Diana ML15195A022 

Ward, Diana ML15196A091 

Whetstone, Joe ML15195A641 

Williams, Alek ML15198A541 

Yll, Judy ML15196A068 

Zambrano, Ota ML15160A522 

Zook, Caryl ML15196A256 

Table E-11. Individuals Submitting with Subject “Support the ‘No Action’ Alternative” 

with Correspondence ID TURK-COL6&7-DR-00379 and Representative 

ADAMS Accession No. ML15141A259 (Multiple Authors 2015-TN4719)

Commenter ADAMS Accession # 

Albrecht, Lonnie ML15196A139 

Andreacchio, Tonya ML15195A635 

Arthur, Barbara ML15196A474 

Axelrod, Andrea ML15198A516 

Benjamin, Christopher ML15195A157 

Benjamin, Christopher ML15196A478 

Bernabei, Kaatje ML15196A156 

Bills, Kathleen ML15196A126 

Boda, Andrew ML15195A710 

Brenner, Barbara ML15198A520 

Breslin, Gail ML15195A044 

Brizard, Irene ML15195A711 

Brunke, Richard ML15195A704 

Cabral, Edgar ML15162A921 

Cameron, Erin ML15198A531 

Cammardella, Neil ML15196A498 

Campbell, Frank ML15197A042 

Campbell, Grant ML15198A504 

Cargille, Frances ML15196A466 

Carroll, Glenn ML15196A121 

Cherubin, Elizabeth ML15195A020 

Commenter ADAMS Accession # 

Claiborn, William ML15162A857 

Claiborn, William ML15195A721 

Clever, Sonnett ML15162A495 

Colon, Yamarie ML15159B387 

Colson, Clay G. ML15162A913 

Colson, Clay G. ML15195A566 

Covington, Laurel ML15196A062 

Cox, Lesley ML15162A390 

Craciun, George ML15198A523 

Cummins, Lynne ML15195A593 

Datz, Amy ML15198A512 

Davidson, Maggie ML15162A895 

Davidson, Maggie ML15196A144 

De Nolf, Susan ML15195A176 

De Parny, Sylvie ML15195A712 

Debus, John ML15198A505 

Delson, Dave ML15196A058 

Detrick, Mary ML15196A251 

Dietz, Noella ML15198A537 

Doenmez, Sarah ML15196A247 

Doyle, Brian ML15195A720 

Appendix E NUREG–2176 E-654 October 2016
Commenter ADAMS Accession # 

Duffey, Michael ML15195A568 

Dunn, Elmo ML15195A576 

Dunn, Marybeth ML15198A540 

Duval, Ruthann ML15195A143 

Eberly, Kenneth ML15195A703 

Edmondson, John ML15159B426 

Elizey, Georgia ML15159B485 

Elizey, Georgia ML15162A949 

Evelyn, Patty ML15195A177 

Fahrenkopf, Gladys ML15195A608 

Felice, Kathleen R. ML15196A481 

Felice, Kathleen R. ML15196A483 

Frotscher, H. David ML15195A622 

G., J. ML15159B404 

Gale, Michelle ML15196A161 

Gerster, Edward ML15159B455 

Gibbs, Covelo ML15196A094 

Glenn, Martha ML15195A031 

Glover, Tim ML15196A487 

Gould, Mark ML15196A493 

Grannon, Salima ML15196A463 

Guay, Mary ML15159B445 

Guidry, Ashley ML15162A365 

Gulden, Dale ML15162A562 

Gulden, Dale ML15162A890 

Gulden, Dale ML15195A722 

Hall, Dennis ML15196A168 

Hamilton, Dianna ML15195A606 

Hamilton, Kathleen ML15195A613 

Hancock, Guy ML15198A534 

Harrison, J. M. M. ML15195A715 

Hauck, Barbara ML15195A141 

Haun, Pamela ML15162A853 

Headley, Linda ML15195A594 

Hendrix, Kia ML15162A912 

Hendrix, Kia ML15196A480 

Hensgen, Eric ML15162A939 

Hertzman, Ron ML15196A164 

Hill, Ann ML15195A587 

Hill, Catherine ML15196A261 

Hoffman, Ace ML15198A536 

Hohenshelt, Felicity ML15196A057 

Hohenshelt, Felicity ML15196A158 

Howard, Barbara ML15195A719 

Hudon, Karen ML15198A511 

Hughes, Barbara ML15159B442 

Hughes, Curtis ML15159B441 

Hunt, Jim ML15160A978 

Jennings, Sid ML15196A064 

Kerr, Earl ML15195A612 

Kimbrough, Mecca ML15162A952 

King, Michele ML15195A168 

Kirkland, Kathy ML15162A151 

Kramer, Richard ML15195A563 

Kwo, Ken ML15195A714 

Commenter ADAMS Accession # 

Landau, Doug ML15195A127 

Landau, Doug ML15196A492 

Lange, Barbara ML15197A046 

Laxon, Barbara ML15196A122 

Leary, James ML15195A610 

Leavengood, Dena 

Gross ML15195A565 

Leone, Pakita ML15198A510 

Lettieri, Tammy ML15195A570 

Lewis, John ML15162A393 

Linden, Susan ML15195A045 

Linden, Susan ML15195A648 

Losen, Willy Karl the ML15195A624 

Lux, Sharon ML15198A548 

Mack, Heathe ML15195A596 

Marra, Tony ML15198A521 

Marra, Tony ML15195A633 

Martinez, Natalie ML15159B481 

McDonald, Patricia ML15195A165 

McGrath, Marcela ML15196A259 

Mercado, Monica ML15166A030 

Merritt, Mandy ML15159B384 

Merritt, Mandy ML15159B385 

Mesches, Arnold ML15195A164 

Miller, Lynn ML15198A514 

Milne, Martha ML15196A059 

Minniss, Regina ML15162A500 

Montesi, Toni ML15162A884 

Mora, Christian ML15162A492 

Morrison, Marc ML15162A897 

Natilson, Nancy ML15196A473 

Navarra, Rudi ML15198A543 

Nayer, Cyndy ML15198A519 

Nayer, Stuart ML15198A570 

Newton, Michael D. ML15197A047 

Novotny, Jan ML15196A153 

O'Brien, Robert ML15159B424 

Olson, Mary ML15188A201 

O'Meara, Patrick ML15195A644 

Osborne, Martin ML15198A544 

Owen, Cheryl ML15161A642 

Paleias, Linda ML15141A261 

Pannaman, Stanley ML15141A259 

Pannaman, Stanley ML15196A157 

Paradise, Brian ML15162A902 

Paul, Stephen ML15159B457 

Perez, Jose ML15195A131 

Perez, Letty ML15195A135 

Peter, Judith ML15195A651 

Pontones, Steven ML15195A604 

Pottinger, Brandon ML15141A266 

Pritchard, Alvera ML15195A716 

Quillen, Carter ML15195A706 

Raby, Joyce ML15195A162 

Rapuano, Shannon ML15198A522 

Appendix E October 2016 E-655 NUREG–2176
Commenter ADAMS Accession # 

Rehbit, La ML15196A143 

Rilling, Fred ML15159B446 

Rilling, Fred ML15159B447 

Rinaldi, Elaine ML15196A490 

Roderigues, Abel ML15195A599 

Rose, Pat ML15195A042 

Rowell, Edward ML15195A037 

San Pedro, Patricia ML15159B354 

San Pedro, Patricia ML15198A529 

Satori, Linda Sartori ML15196A097 

Schlumpf, Sebastian ML15196A133 

Scott, Jennifer ML15162A909 

Scott, Jennifer ML15195A602 

Sharifi, Yasamin ML15201A464 

Shetler, Terry ML15196A084 

Silvey, Kevin ML15195A708 

Sisco, D. ML15198A527 

Smith, Brenda ML15159B386 

Spencer, Patrick ML15196A127 

St. Martin, Darlene ML15196A491 

Stephan, Carole ML15162A410 

Commenter ADAMS Accession # 

Stephenson, James ML15195A138 

Stone, James ML15195A718 

Sullivan, Viola ML15162A407 

Tann, Rosemary ML15195A146 

Thomas, John ML15159B444 

Tirey, Sheila ML15159B504 

Torres, Victor ML15198A535 

Treuer, Galen ML15190A271 

Truesdale, John ML15196A069 

Tweeton, Tanya ML15162A955 

Vennett, Sean ML15195A580 

Waitkevicz, H. Joan ML15195A160 

Wallace, Christine ML15162A223 

Washburn, Thomas ML15196A088 

Whetstone, Joe ML15159B427 

Whetstone, Joe ML15162A888 

Whitfield, Isabelle ML15162A953 

Williams, Penelope ML15196A067 

Williamson, Barbara ML15196A486 

Wright, Edmund ML15195A038 

Yambor, Arthur ML15196A145 

Table E-12. Individuals Submitting the Form with Subject “Reject permits to build new 

nuclear reactors at Turkey Point” with Correspondence ID TURK-COL6&7-

DR-00240 and Representative ADAMS Accession No. ML15146A110 (Multiple 

Authors 2015-TN4718)

Commenter ADAMS Accession # 

Agler, Mindy ML15141A397 

Anonymous, 

Anonymous ML15211A041 

Anonymous, 

Anonymous ML15201A044 

Anonymous, 

Anonymous ML15211A058 

Anonymous, 

Anonymous ML15146A232 

Barnidge, Virginia ML15201A041 

Bofill, Beatriz ML15211A034 

Bofill, Beatriz ML15142A382 

Colby, Helen ML15146A126 

Dwyer, John P. ML15201A045 

Dwyer, Karen ML15201A048 

Dwyer, Karen ML15141A398 

Ferro, Colleen ML15146A231 

Fielding, Ed ML15142A379 

Commenter ADAMS Accession # 

Gallart, Frank ML15198A141 

Greene, Lisa ML15225A088 

Griswold, Dave ML15198A134 

Hoffmeyer, Lisa ML15211A036 

Holland, Karen ML15211A044 

James, Denise ML15141A321 

Key, Laurence W. ML15198A131 

Mahoney, Robert S. ML15201A062 

Montalvo, Stephanie ML15198A133 

Paleias, Linda ML15201A040 

Siegel, Ellen ML15201A053 

Smoller, Merry Sue ML15198A142 

Smoller, Merry Sue ML15141A254 

Sweetay, Lynn ML15201A058 

Umpierre, Diana ML15160A316 

Umpierre, Diana ML15162A271 

Younger, Sarah ML15146A110 

Appendix E NUREG–2176 E-656 October 2016
Table E-13. Individuals Submitting the Form with Subject “Re: NRC-2009-0337 Turkey 

Point Expansion” with Correspondence ID TURK-COL6&7-DR-00679 and 

Representative ADAMS Accession No. ML15191A341 (Multiple Authors 2015-

TN4717

Commenter ADAMS Accession # 

??, unnreadable ML15191A341 

??, unnreadable ML15191A341 

??, unreadable ML15191A341 

??, unreadable ML15191A341 

??, Corey Lopez ML15191A341 

Bara, Sharon ML15191A341 

Benson, Linda ML15191A341 

Bonnell, Elizabeth ML15191A341 

Chiszar, Benjamin J. ML15191A341 

Cleland, Noel ML15160A314 

Garcia, Dany ML15191A341 

Jacobs, Lee ML15191A341 

Kerr, Karen ML15191A341 

Klopfer, Carol ML15191A341 

Appendix E October 2016 E-657 NUREG–2176
E.4 References 

40 CFR Part 230. Code of Federal Regulations, Title 40, Protection of Environment, Part 230, 

"Section 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill Material." 

Washington, D.C. TN427. 

50 FR 32138. August 8, 1985. "Policy Statements on Severe Reactor Accidents Regarding 

Future Designs and Existing Plants." Federal Register, Nuclear Regulatory Agency, 

Washington, D.C. TN4519. 

51 FR 30028. August 21, 1986. "Safety Goals for the Operation of Nuclear Power Plants; 

Policy Statement; Correction and Republication." Federal Register, Nuclear Regulatory 

Commission, Washington, D.C. TN594. 

77 FR 16082. March 19, 2012. "In the Matter of All Power Reactor Licensees and Holders of 

Construction Permits in Active or Deferred Status: Order Modifying Licenses with Regard to 

Reliable Spent Fuel Pool Instrumentation (Effective Immediately)." Federal Register, Nuclear 

Regulatory Commission, Washington, D.C. TN1424. 

77 FR 20059. April 3, 2012. "License Amendment To Increase the Maximum Reactor Power 

Level, Florida Power & Light Company, Turkey Point, Units 3 and 4." Federal Register, Nuclear 

Regulatory Commission, Washington, D.C. TN1001. 

78 FR 60024. September 30, 2013. "Endangered and Threatened Wildlife and Plants; 

Proposed Threatened Status for the Rufa Red Knot (Calidris canutus rufa)." Federal Register, 

Fish and Wildlife Service, Washington, D.C. TN3199. 

BEA (U.S. Bureau of Economic Analysis). 2012. RIMS II—An Essential Tool for Regional 

Developers and Planners. Washington, D.C. Accession No. ML14309A040. TN1569. 

BEA (U.S. Bureau of Economic Analysis). 2012. "Total Full-Time and Part-Time Employment 

by NAICS Industry—Florida and Miami-Dade County." CA25N, Washington, D.C. Accession 

No. ML14338A460. TN4074. 

BEA (U.S. Bureau of Economic Analysis). 2014. "Bearfacts: Miami-Dade County, Florida 

Personal Income." Washington, D.C. Accession No. ML14338A461. TN4075. 

Cunningham, K.J. 2013. Integrating Seismic-Reflection and Sequence-Stratigraphic Methods 

to Characterize the Hydrogeology of the Floridan Aquifer System in Southeast Florida. U.S. 

Geological Survey Open File Report 2013-1181, Reston, Virginia. Accession No. 

ML16172A124. TN4573. 

Cunningham, K.J. 2014. Integration of Seismic-Reflection and Well Data to Assess the 

Potential Impact of Stratigraphic and Structural Features on Sustainable Water Supply from the 

Floridan Aquifer System. Open-File Report 2014–1136, U.S. Geological Survey, Davie, Florida. 

Accession No. ML14342A048. TN4051. 

Appendix E NUREG–2176 E-658 October 2016
Cunningham, K.J. 2015. Seismic-Sequence Stratigraphy and Geologic Structure of the 

Floridan Aquifer System Near "Boulder Zone" Deep Wells in Miami-Dade County, Florida. U.S. 

Geological Survey Scientific Investigations Report 2015-5013, Reston, Virginia. Accession No. 

ML16172A125. TN4574. 

Cunningham, K.J., C. Walker, and R.L. Westcott. 2012. "Near-Surface, Marine SeismicReflection Data Define Potential Hydrogeologic Confinement Bypass in the Carbonate Floridan 

Aquifer System, Southeastern Florida." In SEG Technical Program Expanded Abstracts 2012, 

Society of Exploration Physicists, Tulsa, Oklahoma. Available at 

http://library.seg.org/doi/abs/10.1190/segam2012-0638.1. TN4576. 

EAI (Ecological Associates, Inc.). 2009. Turkey Point Peninsula Seagrass Survey. Jensen 

Beach, Florida. Accession No. ML12240A279. TN153. 

EPA (U.S. Environmental Protection Agency). 2003. Relative Risk Assessment of 

Management Options for Treated Wastewater in South Florida. EPA-816-R-03-010, 

Washington, D.C. Accession No. ML16266A248. TN4759. 

EPA (U.S. Environmental Protection Agency). 2005. Fact Sheet: "EPA Provides a Regulatory 

Alternative for Class I Municipal Disposal Wells in Specific Counties in Florida." EPA 815-F-05-

033, Atlanta, Georgia. Accession No. ML16266A249. TN4766. 

EPA (U.S. Environmental Protection Agency). 2014. "Where Can I Find the Most Current 

Information about Fukushima and Radiation Levels in the Environment?" Washington, D.C. 

Accession No. ML15239A600. TN4217. 

FDEP (Florida Department of Environmental Protection). 2013. "Siting Coordination." 

Tallahassee, Florida. Available at http://www.dep.state.fl.us/siting/default.htm. TN2629. 

FDEP (Florida Department of Environmental Protection). 2014. Conditions of Certification, 

Florida Power & Light Company, Turkey Point Plant Units 6 & 7. PA 03-45A3, Tallahassee, 

Florida. Available at 

http://publicfiles.dep.state.fl.us/Siting/Outgoing/Web/Certification/pa03_45_2014_units6_7.pdf. 

TN4371. 

FDHR (Florida Division of Historical Resources). 2010. Letter from L.A. Kimmerer to NRC, 

dated July 28, 2010, regarding "Florida Power & Light Company—Notification and Request for 

Consultation and Participation in the Scoping Process for the Environmental Review of the 

Turkey Point, Units 6 and 7 Combined License Application." DHR Project File Number 2010–

3097, Tallahassee, Florida. Accession No. ML102220345. TN1455. 

FDOH (Florida Department of Health). 2001. Report Concerning Cancer Rates in 

Southeastern Florida. Bureau of Environmental Epidemiology, Tallahassee, Florida. Accession 

No. ML16266A250. TN4744. 

Fla. Stat. 29-403.50665. 2011. "Land Use Consistency." Florida Statutes, Tallahassee, 

Florida. TN1470. 

Appendix E October 2016 E-659 NUREG–2176
FNAI (Florida Natural Areas Inventory). 2014. "FNAI Tracking List: Miami-Dade County." 

Tallahassee, Florida. Available at http://fnai.org/trackinglist.cfm. TN3668. 

FPL (Florida Power & Light Company). 2009. Final Fish Surveys of the Turkey Point Property 

Associated with Units 6 & 7, June 23–24, 2009. L-2011-218, Homestead, Florida. Accession 

No. ML11168A043. TN201. 

FPL (Florida Power & Light Company). 2009. Turkey Point Exploratory Drilling and Aquifer 

Performance Test Program. HDR Engineering, Inc., West Palm Beach, Florida. Accession No. 

ML110820053. TN1263. 

FPL (Florida Power & Light Company). 2009. Avian Surveys of the Turkey Point Property 

Associated with Units 6 & 7, June 23–24, 2009. L-2011-163, Tetra Tech NUS, Inc., Aiken, 

South Carolina. Accession Nos. ML11118A175, ML111180713. TN1334. 

FPL (Florida Power & Light Company). 2009. Mammal Trapping and Herpetology Report 

Turkey Point Property Associated with Units 6 & 7, April 13–16, 2009. L-2011-163, Tetra Tech 

NUS, Inc., Aiken, South Carolina. Accession Nos. ML11118A175, ML111180713. TN1444. 

FPL (Florida Power & Light Company). 2009. Cultural Resource Assessment Survey Work 

Plan for the Turkey Point Units 6 & 7 Site and Associated Non-Linear Facilities. L-2011-095, 

Janus Research, Tampa, Florida. Accession No. ML11109A021. TN1513. 

FPL (Florida Power & Light Company). 2009. Cultural Resource Assessment Survey Work 

Plan for the Turkey Point Units 6 & 7 Associated Linear Facilities [Redacted]. L-2011-095, 

Janus Research, Tampa, Florida. Accession No. ML11109A022. TN1515. 

FPL (Florida Power & Light Company). 2010. FPL Turkey Point Units 6 & 7 Threatened and 

Endangered Species Evaluation and Management Plan. Revision 1, Homestead, Florida. 

Accession No. ML12240A282. TN170. 

FPL (Florida Power & Light Company). 2010. Site Certification Application Turkey Point Units 6 

& 7, Amendment, Revision 1. 0938-7652/230, Juno Beach, Florida. Accession No. 

ML14336A332. TN272. 

FPL (Florida Power & Light Company). 2011. Letter from W. Maher to NRC, dated September 

30, 2011, regarding "Response to NRC Environmental Request for Additional Information Letter 

1104121 (RAI 5589) Environmental Standard Review Plan Section 9.3—Alternative Sites." L2011-395, Juno Beach, Florida. Accession No. ML11277A003. TN40. 

FPL (Florida Power & Light Company). 2011. Letter from W. Maher to NRC, dated April 26, 

2011, regarding "Response to NRC Environmental Request for Additional Information Letter 

1103101 (RAI 5562) Environmental Standard Review Plan Section 2.4.1—Terrestrial and 

Wetlands Ecology." L-2011-163, Juno Beach, Florida. Accession No. ML111180713. TN94. 

Appendix E NUREG–2176 E-660 October 2016
FPL (Florida Power & Light Company). 2011. Letter from W. Maher to NRC, dated April 15, 

2011, regarding "Response to NRC Request for Additional Information Letter 1102231 (eRAI 

5480) Environmental Standard Review Plan Section 2.7—Cultural Resources." L-2011-095, 

Juno Beach, Florida. Accession No. ML111090274. TN95. 

FPL (Florida Power & Light Company). 2011. Letter from M.K. Nazar to NRC, dated December 

16, 2011, regarding "Combined License Application Submittal 9, Submittal of the Annual Update 

of the COL Application—Revision 3 and the Semi-Annual Update of the Departures Report." L2011-529, Juno Beach, Florida. Accession No. ML11361A102. TN127. 

FPL (Florida Power & Light Company). 2011. Stormwater Management Plan and Calculations. 

Golder Associates, Jacksonville, Florida. Accession No. ML12192A238. TN303. 

FPL (Florida Power & Light Company). 2011. Personal Communications with Miccosukee 

Tribe of Indians of Florida, Metro Miami Action Plan Trust and Miami-Dade Office of Community 

Advocacy. L-2011-162, Juno Beach, Florida. Accession No. ML11118A177. TN435. 

FPL (Florida Power & Light Company). 2011. Turkey Point Units 6 & 7 Mitigation Plan. 

Revision 2, 093-87652, Juno Beach, Florida. Accession No. ML12269A222. TN1012. 

FPL (Florida Power & Light Company). 2011. FPL Turkey Point Units 6 & 7 Threatened and 

Endangered Species Evaluation and Management Plan. Revision 1, Homestead, Florida. 

Accession No. ML14217A138. TN1283. 

FPL (Florida Power & Light Company). 2011. Turkey Point Units 6 and 7 Section 404(b)(1) 

Alternatives Analysis. L-2011-477, 093-87652, Juno Beach, Florida. Accession No. 

ML11319A035. TN1374. 

FPL (Florida Power & Light Company). 2011. "Table 4-MDC-D-11: Tree Survey." Golder 

Associates, Inc., Jacksonville, Florida. Accession No. ML14287A752. TN1471. 

FPL (Florida Power & Light Company). 2011. Cultural Resource Assessment Survey for the 

Turkey Point Units 6 & 7 Site, Associated Non-Linear Facilities, and Spoils Areas on Plant 

Property. L-2011-095, Janus Research, Tampa, Florida. Accession Nos. ML11109A019, 

ML11109A017. TN1512. 

FPL (Florida Power & Light Company). 2012. Letter from W. Maher to NRC, dated March 7, 

2012, regarding "Response to NRC Request for Additional Information Letter 1112081 (RAI 

5765) ESRP Section 4.2—Water-Related Impacts." L-2012-101, Juno Beach, Florida. 

Accession No. ML12074A041. TN263. 

FPL (Florida Power & Light Company). 2012. Report on the Construction and Testing of Class 

V Exploratory Well EW-1 at the Florida Power & Light Company Turkey Point Units 6 & 7. 

McNabb Hydrogeologic Consulting, Inc., Jupiter, Florida. Accession No. ML14336A337. 

TN1577. 

Appendix E October 2016 E-661 NUREG–2176
FPL (Florida Power & Light Company). 2012. Turkey Point Units 6 & 7 Federal Biological 

Assessment for Six Listed Species. L-2012-432, Juno Beach, Florida. Accession No. 

ML123390437. TN1618. 

FPL (Florida Power & Light Company). 2012. Letter from W. Maher to NRC, dated October 17, 

2012, regarding "Response to NRC Request for Additional Information Letter 120329, (eRAI 

6354 Rev 0) Related to ESRP Section 2.3.1—Hydrology." L-2012-337, Juno Beach, Florida. 

Accession No. ML12293A236. TN2688. 

FPL (Florida Power & Light Company). 2013. Ten Year Power Plant Site Plan 2013–2022. 

Miami, Florida. Accession No. ML14336A344. TN2630. 

FPL (Florida Power & Light Company). 2013. Letter from W. Maher to NRC, dated November 

5, 2013, regarding "Florida Power & Light Company Proposed Turkey Point Units 6 and 7, 

Docket Nos. 52-040 and 52-041, Supplemental Transmission Corridor Information for the 

Combined License Application Part 3—Environmental Report." L-2013-311, Juno Beach, 

Florida. Accession No. ML13311A105. TN2941. 

FPL (Florida Power & Light Company). 2013. Letter from W. Maher to NRC, dated August 9, 

2013, regarding "Response to NRC Request for Additional Information Letter No. 072 (eRAI 

6985)—SRP Section 11.02—Liquid Waste Management Systems." L-2013-216, Juno Beach, 

Florida. Accession No. ML13225A029. TN3931. 

FPL (Florida Power & Light Company). 2014. Ten Year Power Plant Site Plan 2014–2023. 

Miami, Florida. Accession No. ML14336A345. TN3360. 

FPL (Florida Power & Light Company). 2014. Letter from W. Maher to NRC, dated March 17, 

2014, regarding "Florida Power & Light Company Proposed Turkey Point Units 6 and 7, Docket 

Nos. 52-040 and 52-041, Removal of the FPL-Owned Fill Source from the Combined License 

Application Part 3—Environmental Report." L-2014-076, Juno Beach, Florida. Accession No. 

ML14078A052. TN3569. 

FPL (Florida Power & Light Company). 2014. "About St. Lucie." Juno Beach, Florida. 

Available at http://www.fpl.com/environment/nuclear/about_st_lucie.shtml. TN3792. 

FPL (Florida Power & Light Company). 2014. Turkey Point Plant, Units 6 and 7 COL 

Application, Part 3—Environmental Report. Revision 6, Juno Beach, Florida. Accession No. 

ML14342A011. TN4058. 

FPL (Florida Power & Light Company). 2014. Turkey Point Plant, Units 6 and 7 COL 

Application, Part 2—Final Safety Analysis Report. Revision 6, Juno Beach, Florida. Accession 

No. ML14311A247. TN4069. 

FPL (Florida Power & Light Company). 2014. Turkey Point Plant, Units 6 & 7 COL Application, 

Part 1—General and Financial Information. Revision 6, Juno Beach, Florida. Accession No. 

ML14311A173. TN4103. 

Appendix E NUREG–2176 E-662 October 2016
FPL (Florida Power & Light Company). 2015. Turkey Point Plant Units 6 and 7 COL 

Application, Part 2—Final Safety Analysis Report. Revision 7, Juno Beach, Florida. Accession 

No. ML15301A339. TN4502. 

FPL (Florida Power & Light Company). 2016. Letter from W. Maher to NRC, dated February 

29, 2016, regarding "Response to NRC Environmental Request for Additional Information Letter 

160302 (eRAI 8508) Related to Meteorology and Air Quality." L-2016-032, Juno Beach, Florida. 

Accession No. ML16062A035. TN4501. 

FPSC (Florida Public Service Commission). 2008. Final Order Granting Petition for 

Determination of Need for Proposed Power Plants. Docket No. 070650-EI, Order No. PSC-08-

0237-FOF-EI, Tallahassee, Florida. Available at 

http://www.psc.state.fl.us/dockets/orders/SingleDisplay.aspx?OrderNumber=PSC-08-

0237&Method=ByNumber. TN735. 

FWS (U.S. Fish and Wildlife Service). 2012. Natural Resources of Concern Miami-Dade, 

Florida. South Florida Ecological Services, Vero Beach, Florida. Accession No. ML12193A319. 

TN117. 

FWS (U.S. Fish and Wildlife Service). 2013. Rufa Red Knot Ecology and Abundance. 

Supplement to Endangered and Threatened Wildlife and Plants; Proposed Threatened Status 

for the Rufa Red Knot (Calidris canutus rufa). Docket No. FWS-R5-ES-2013-0097, Washington 

D.C. Accession No. ML14309A077. TN3202. 

GCRP (U.S. Global Change Research Program). 2014. Climate Change Impacts in the United 

States: The Third National Climate Assessment. J.M. Melillo, T.C. Richmond, and G.W. Yohe 

(editors). U.S. Government Printing Office, Washington, D.C. Accession No. ML14129A233. 

TN3472. 

Kratchman, C. Norton, and R. Bernado. 2015. Fukushima Water Contamination—Impacts on 

the U.S. West Coast. U.S. Nuclear Regulatory Commission, Washington, D.C. Accession No. 

ML15021A530. TN4737. 

Maliva, R.G., W. Guo, and T. Missimer. 2007. "Vertical Migration of Municipal Wastewater in 

Deep Injection Well Systems, South Florida, USA." Hydrogeology Journal 15:1387–1396, New 

York, New York. TN1483. 

McNeill, D.F. 2000. A Review of Upward Migration of Effluent Related to Subsurface Injection 

at Miami-Dade Water and Sewer South District Plant. Final Report, Coral Gables, Florida. 

TN4572. 

McNeill, D.F. 2002. A Geological Review of the Confining Capability of a Regional Dolomite 

Unit: Application to the MDWAS South District WWTP. Coral Gables, Florida. TN4571. 

Appendix E October 2016 E-663 NUREG–2176
Miami Dade County. 2013. Ocean Outfall Legislation Compliance Plan, Chapter 2008-232 

Laws of Florida Wastewater Disposal/Ocean Outfalls [Section 403.086 (9), Florida Statutes and 

Amendment CS/SB 444]. Miami Florida. Accessed September 22, 2016, at 

https://www.miamidade.gov/water/library/reports/ocean-outfall-legislation.pdf. Accession No. 

ML16278A748. TN4786. 

National Research Council. 2006. Health Risks from Exposure to Low Levels of Ionizing 

Radiation BEIR VII Phase 2. National Academies Press, Washington, D.C. Available at 

http://www.nap.edu/openbook.php?record_id=11340&page=1. TN296.

NCRP (National Council on Radiation Protection and Measurements). 2009. Ionizing Radiation 

Exposure of the Population of the United States. NCRP Report No. 160, Bethesda, Maryland. 

Available at http://app.knovel.com/web/toc.v/cid:kpIREPUS05. TN420. 

NPS (National Park Service). 2016. Record of Decision: Acquisition of Florida Power & Light 

Company Land in the East Everglades Expansion Area Environmental Impact Statement, 

Everglades National Park, Florida. Homestead, Florida. Accession No. ML16167A522. 

TN4532. 

NRC (U.S. Nuclear Regulatory Commission). 1993. Effect of Hurricane Andrew on Turkey 

Point Nuclear Generating Station and Lessons Learned. NRC Information Notice 93-53, 

Washington, D.C. Accession No. ML031070364. TN542. 

NRC (U.S. Nuclear Regulatory Commission). 1999. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants Addendum to Main Report. NUREG–1437, Volume 1, 

Addendum 1, Washington, D.C. Accession No. ML040690720. TN289. 

NRC (U.S. Nuclear Regulatory Commission). 2010. Letter from L. Bauer to K. Kauffman, dated 

July 1, 2010, regarding "Notification and Request for Consultation and Participation in the 

Scoping Process for the Environmental Review of the Turkey Point, Units 6 and 7 Combined 

License Application." Washington, D.C. Accession No. ML101690468. TN1458. 

NRC (U.S. Nuclear Regulatory Commission). 2012. Email from M. Comar to M. Nazar, dated 

May 1, 2012, regarding "Request for Additional Information Letter No. 58 Concerning 

Implementation of Fukushima Near-Term Task Force Recommendations for the Turkey Point 

Units 6 and 7 Combined License Application." Washington, D.C. Accession No. 

ML12122A973. TN3239. 

NRC (U.S. Nuclear Regulatory Commission). 2013. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants [GEIS]. NUREG–1437, Revision 1, Washington, D.C. 

Accession No. ML13107A023. TN2654. 

NRC (U.S. Nuclear Regulatory Commission). 2013. Memorandum from S.D. Dingbaum to 

R.W. Borchardt, dated August 20, 2013, regarding "Audit of NRC’s Compliance With 10 CFR 

Part 51 Relative to Environmental Impact Statements." OIG-13-A-20, Washington, D.C. 

Accession No. ML13232A192. TN4804. 

Appendix E NUREG–2176 E-664 October 2016
NRC (U.S. Nuclear Regulatory Commission). 2014. Estimated Effects of Proposed Radial 

Collector Well Pumpage Near Turkey Point Nuclear Facility, Miami-Dade County, Florida. In 

conjunction with the U.S. Geological Survey, Reston, Virginia. Accession No. ML14345A290. 

TN3078. 

NRC (U.S. Nuclear Regulatory Commission). 2014. "Event Notification Report: Offsite 

Notification due to Deceased American Crocodile." July 25, 2014, Number 50306, Washington, 

D.C. Accession No. ML14338A557. TN3718. 

NRC (U.S. Nuclear Regulatory Commission). 2014. Letter from R.F. Kuntz to M. Nazar, dated 

December 4, 2014, regarding "Turkey Point Nuclear Generating, Unit Nos. 3 and 4—Staff 

Assessment of Response to 10 CFR 50.54(f) Information Request—Flood-Causing Mechanism 

Reevaluation (TAC Nos. MF1114 and MF1115)." Washington, D.C. Accession No. 

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Fukushima Tier 2 and 3 Recommendations. SECY-15-0137, Washington, D.C. Accession No. 

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NRC (U.S. Nuclear Regulatory Commission). 2015. In the Matter of Florida Power & Light 

Company Turkey Point Units 6 & 7 (Combined License Application), "Florida Power & Light 

Company's Motion for Summary Disposition of Joint Intervenor’s Amended Contention 2.1." 

Submitted December 15, 2015 before the Atomic Safety and Licensing Board, Docket Nos. 52-

040-COL and 52-050-041, ASLBP No. 10-903-02-COL. Washington, D.C. Accession No. 

ML15349A986. TN4773. 

NRC (U.S. Nuclear Regulatory Commission). 2016. Advanced Safety Evaluation for Turkey 

Point Units 6 and 7 Combined License Application, Chapter 2: "Site Characteristics." 

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NRC (U.S. Nuclear Regulatory Commission). 2016. Memorandum from F.A. Akstulewicz to 

A.V. Valentin, dated May 17, 2016, regarding "Turkey Point Units 6 and 7, Combined License 

Application - Advanced Safety Evaluation with No Open Items for Chapter 20, "Requirements 

Resulting from Fukushima Near-Term Task Force Recommendations.” Washington, D.C. 

Accession No. ML16062A211. TN4806. 

Reese, R.S. and E. Richardson. 2008. Synthesis of the Hydrogeologic Framework of the 

Floridan Aquifer System and Delineation of a Major Avon Park Permeable Zone in Central and 

Southern Florida. U.S. Geological Survey Scientific Investigations Report 2007–5207, Reston, 

Virginia. Accession No. ML14342A007. TN3436. 

Reisman, J. and G. Frisbie. 2002. Calculating Realistic PM10 Emissions from Cooling Towers. 

Greystone Environmental Consultants, Inc., Sacramento, California. Available at 

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onse/Air%20Quality/Attachment%204-1.pdf. TN1022. 

Appendix E October 2016 E-665 NUREG–2176
Saylor, R., L. Myles, D. Sibble, J. Caldwell, and J. Xing. 2015. "Recent Trends in Gas-Phase 

Ammonia and PM2.5 Ammonium in the Southeast United States." Journal of the Air & Waste 

Management Association 65(3):347–357, Philadelphia, Pennsylvania. TN4605. 

SFWMD (South Florida Water Management District). 2009. FPL Turkey Point Power Plant 

Groundwater, Surface Water, and Ecological Monitoring Plan. West Palm Beach, Florida. 

Accession No. ML12193A539. TN149. 

SFWMD (South Florida Water Management District). 2013. South Florida Water Management 

District Patrol Summary, Model Lands October 18–31, 2013. West Palm Beach, Florida. 

Accession No. ML14328A521. TN2917. 

Starr, R.C., T.S. Green, and L.C. Hull. 2001. Evaluation of Confining Layer Integrity Beneath 

the South District Wastewater Treatment Plant, Miami-Dade Water and Sewer Department, 

Dade County, Florida. INEEL/EXT-01-00046, Idaho National Engineering and Environmental 

Laboratory, Idaho Falls, Idaho. Accession No. ML14216A601. TN1251. 

State of Florida. 2014. "Final Order on Certification, In Re: Florida Power & Light Company 

Turkey Point Units 6 & 7 Power Plant Siting Application No. PA 03–45A3." State of Florida 

Siting Board, OGC Case No. 09–3107, Division of Administrative Hearings, Case No. 09–

03575–EPP, Tallahassee, Florida. Accession No. ML14345A291. TN3637. 

Tetra Tech. 2014. Technical Memorandum from P.F. Andersen and J.L. Ross to FPL, dated 

May 9, 2014, regarding "Evaluation of Required Floridan Water for Salinity Reduction in the 

Cooling Canal System." Pasadena, California. Accession No. ML14279A555. TN4126. 

UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation). 2014. 

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and Effects of Radiation Exposure Due to the Nuclear Accident after the 2011 Great East-Japan 

Earthquake and Tsunami. New York, New York. Available at 

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UNSCEAR (United Nations Scientific Committee on the Effects of Atomic Radiation). 2015. 

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Exposure due to the Nuclear Accident Following the Great East-Japan Earthquake and 

Tsunami. New York, New York. Available at 

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Central and Southern Florida Project 2010 Report to Congress. Washington, D.C. Accession 

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USACE (U.S. Army Corps of Engineers) and SFMWD (South Florida Water Management 

District). 2011. Central and Southern Florida Project, Comprehensive Everglades Restoration 

Plan, Biscayne Bay Coastal Wetlands Phase 1 Final Integrated Project Implementation Report 

and Environmental Impact Statement Volume 1—Main Report. Jacksonville District, 

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Appendix E NUREG–2176 E-666 October 2016
USCB (U.S. Census Bureau). 2009. "2005–2009 American Community Survey 5–Year 

Estimates Demographics 50–Mile Area." Washington, D.C. Accession No. ML14287A731. 

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Walsh, V.M. and R.M. Price. 2010. "Determination of Vertical and Horizontal Pathways of 

Injected Fresh Wastewater into a Deep Saline Aquifer (Florida, USA) using Natural Chemical 

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Westinghouse (Westinghouse Electric Company LLC). 2011. AP1000 Design Control 

Document. APP-GW-GL-700, Revision 19, Pittsburgh, Pennsylvania. Accession No. 

ML11171A500. TN261. 

Appendix E October 2016 E-667 NUREG–2176



NUREG-2176, Vol. 4

Final

Environmental Impact Statement for Combined Licenses (COLs) for

Turkey Point Nuclear Plant Units 6 and 7