Environmental Impact Statement 

for Combined Licenses (COLs)

for Turkey Point Nuclear Plant

Units 6 and 7

Final Report

Appendices A to K

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. 3

Environmental Impact Statement 

for Combined Licenses (COLs)

for Turkey Point Nuclear Plant

Units 6 and 7

Final Report

Appendices A to K

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. 3

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 

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

Selection Criteria within 50 mi of the St. Lucie Alternative Site .................................. 9-235 

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
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 A 

CONTRIBUTORS TO THE ENVIRONMENTAL IMPACT STATEMENT 

NUREG–2176 A-1 October 2016 

APPENDIX A 

CONTRIBUTORS TO THE ENVIRONMENTAL IMPACT STATEMENT 

The overall responsibility for the preparation of this environmental impact statement was 

assigned to the Office of New Reactors, U.S. Nuclear Regulatory Commission (NRC). The 

statement was prepared by members of the Offices of New Reactors with assistance from other 

NRC organizations, the U.S. Army Corps of Engineers, the National Park Service - Biscayne 

Bay and Everglades National Park, Pacific Northwest National Laboratory, and Information 

Systems Laboratories. 

Name Education/Expertise Contribution

Nuclear Regulatory Commission 

Alicia Williamson B.S. Biology and Chemistry; M.S. 

Environmental Science; 12 years relevant 

experience 

Environmental Project 

Manager 

Andrew Kugler B.S., Mechanical Engineering; M.S. 

Technical Management; 14 years relevant 

experience 

Alternatives, Environmental 

Project Manager 

Tomeka Terry M.S. Civil Engineering; 12 years relevant 

experience 

Assistant Project Manager 

Stacey Imboden B.S. Meteorology; M.S. Environmental 

Engineering and Science; 13 years relevant 

experience 

Meteorology , Air Quality, 

Climate Change 

Kevin Quinlan B.S. Meteorology; M.S. Atmospheric 

Science; 6 years relevant experience 

Meteorology, Air Quality 

Mohammad Haque M.S. Civil Engineering; 35 years relevant 

experience 

Surface Water Hydrology 

Daniel Barnhurst B.S. Environmental Geology; M.S. Geology 

11 years relevant experience 

Groundwater Hydrology, 

Geology 

Michael Masnik B.S. Conservation; M.S. and Ph.D. Zoology, 

42 years relevant experience 

Aquatic Ecology; Essential 

Fish Habitat 

Robert Schaaf B.S. Mechanical Engineering; 24 years 

relevant experience 

Fuel Cycle 

Peyton Doub B.S. Plant Sciences; M.S. Plant Physiology; 

Professional Wetland Scientist; 27 years 

relevant experience 

Terrestrial Ecology, Land Use, 

Transmission Lines 

Daniel Mussatti B.A. Economics; M.S. Natural Resource 

and Environmental Economics; 24 years 

relevant experience 

Socioeconomics, 

Environmental Justice, 

Benefit-Cost, Need for Power 

Jennifer Davis B.A. Historic Preservation and Classical 

Civilization; 14 years relevant NEPA and 

NHPA experience 

Historic and Cultural 

Resources 
Appendix A 

NUREG–2176 A-2 October 2016 

Name Education/Expertise Contribution

Jack Cushing B.S. Marine Engineering; 30 years relevant 

nuclear experience 

Historic and Cultural 

Resources, Nonradiological 

Health and Waste 

Donald Palmrose M.S. and Ph.D. Nuclear Engineering; 

30 years relevant experience 

Radioactive Waste 

Management, Health Physics, 

Decommissioning, Fuel Cycle, 

Postulated Accidents, 

Transportation 

Malcolm Patterson B.S. Systems Engineering; 39 years 

relevant experience 

Severe Accidents 

Seshagiri Tammara M.S. Chemical and Environmental 

Engineering; 40 years relevant experience 

Demography, Transportation, 

Postulated Accidents 

Charles Hinson M.S. Nuclear Engineering / Health Physics; 

40 years relevant experience 

Construction Worker Dose, 

Radioactive Waste 

Management 

Michelle Hart B.S. Physics; M.S. Nuclear Engineering; 18 

years relevant experience 

Postulated Accidents 

Zachary Gran B.S. Physics; M.S. Radiological Health 

Physics; 5 years relevant experience 

Radiological Health 

Stephen Giebel B.S. Health Physics; 31 years relevant 

experience 

Decommissioning 

U.S. Army Corps of Engineers 

Megan Clouser B.S. Marine Science and Biology; 18 years 

relevant experience 

Senior Project Manager 

David Pugh M.A. Historic Archaeology / History; 20 

years relevant experience 

Historic and Cultural 

Resources 

Jacob Hemingway B.S. Anthropology; M.S. Geography; 7 

years relevant experience 

Historic and Cultural 

Resources 

National Park Service 

Elsa Alvear M.S. Biology; 22 years relevant experience Natural Resources; 

Environmental Impact 

Analysis 

Sarah Bellmund B.S. Biochemistry; M.A. Marine Sciences; 

31 years relevant experience 

Natural Resources; 

Environmental Impact 

Analysis; Ecology; Hydrology 

Tylan Dean B.S. Fishery and Wildlife Management; 

M.S. Wildlife Ecology and Conservation; 21 

years relevant experience 

Natural Resources; Ecology 

Bryan Faehner B.S. Environmental Policy; M.S. 

Environmental Studies; 10 years relevant 

experience 

Natural Resources; 

Environmental Impact 

Analysis 

Vanessa McDonough Ph.D. Biology; 14 years relevant experience Ecology 

David Rudnick Ph.D. Oceanography; 30 years relevant 

experience 

Hydrology; Environmental 

Impact Analysis 
Appendix A 

October 2016 A-3 NUREG–2176 

Name Education/Expertise Contribution

Erik Stabenau B.A. Chemistry; Ph.D. Marine and 

Atmospheric Chemistry; 16 years relevant 

experience 

Climate Science 

Pacific Northwest National Laboratory(a)

Robert Bryce B.S. Geology; M.S. Hydrology/ 

Hydrogeology; 36 years relevant 

experience 

Task Leader 

Sandra McInturff B.S. Business; 35 years of relevant 

experience 

Deputy Task Leader 

Carmen Arimescu B.S. and M.S. Computer Science; 30 years 

relevant experience 

Comment Database 

Terri Miley B.S. and M.S. Mathematics; 27 years 

relevant experience 

Comment Database 

Tom Anderson B.S. Botany; 41 years relevant experience Alternatives 

Jeffrey Ward B.A. Zoology; M.S., Environmental 

Engineering; 25 years relevant experience 

Aquatic Ecology 

Ann Miracle B.A Biology, M.S. Population Genetics, 

Ph.D. Molecular Immunology; 17 years 

relevant experience. 

Aquatic Ecology 

Corey Duberstein B.S. Wildlife; M.S. Natural Resource 

Science; 20 years relevant experience 

Terrestrial Ecology 

Lara Aston B.S. and M.S. Environmental Science; 

15 years relevant experience 

Nonradiological Health; 

Terrestrial Ecology 

Michelle Niemeyer B.S. and M.S. Agricultural Economics; 

8 years relevant experience 

Need for Power, Benefit Cost 

Paul Thorne B.S. Chemistry/Math; M.S. Hydrology; 

34 years relevant experience 

Groundwater Use, Hydrology 

Steve Breithaupt B.S. Aquatic Biology; M.S. Environmental 

Science; Ph.D., Water Resource 

Engineering; 34 years relevant experience 

Surface Water Use, Hydrology 

Mart Oostrom Ph.D. Soil Physics and Engineering; 25 

years relevant experience 

Staff Scientist 

Lance Vail B.S. Environmental Systems Engineering; 

M.S. Civil Engineering; 35 years relevant 

experience 

Surface Water Use, Hydrology 

Nancy Kohn B.S. Freshwater Studies; 6 years relevant 

experience 

Site Layout and Plant 

Description 

Philip Daling B.S. Physical Metallurgy; 33 years relevant 

experience 

Transportation 

Susan Loper B.S. Biology; 13 years relevant experience Geographic Information 

Systems 

Susan Ennor B.A. Journalism; 35 years relevant 

experience 

Technical Editing and Text 

Processing 
Appendix A 

NUREG–2176 A-4 October 2016 

Name Education/Expertise Contribution

Cary Counts B.S. Ceramic Engineering; M.S. 

Environmental Systems Engineering; 42 

years relevant experience 

Technical Editing and Text 

Processing 

Mike Parker B.A. English; 16 years relevant experience Technical Editing and Text 

Processing 

Heather Culley B.S. Biology and Philosophy; M.A. Medical 

History and Ethics; 8 years relevant 

experience 

Technical Editing and Text 

Processing 

Christine Ross A.A. Microcomputer Management/ 

Multimedia Specialist; B.A., Social 

Sciences; 19 years relevant experience 

References, EARRTH 

Susan Gulley B.A. English/Library Science; 15 years 

relevant experience 

References 

Joanne Duncan B.A. Biology; 15 years relevant experience Reference Coordinator 

Information Systems Laboratories 

Ali Azarm, IESS Corp(b) B.S. Electrical Engineering; Ph.D. Nuclear 

Engineering; 15 years relevant experience 

Severe and Design Basis 

Accidents 

Alex Uriarte, ICF 

International(b)

M.S. Economics; PH.D. Development 

Studies; 15 years relevant experience 

Socioeconomics, 

Environmental Justice 

Ralph Grismala, ICF 

International(b)

M.S. Civil Engineering; 37 years relevant 

experience 

Nonradioactive Waste, Fuel 

Cycle 

Gregory Hofer, SC&A(b)

 M.S. Physics; M.S. Nuclear Engineering; 33 

years relevant experience 

Health Physics, Radioactive 

Waste Management 

Rose Gogliotti, SC&A(b)

 B.S. Radiological Health; 6 years relevant 

experience 

Health Physics 

Abe Zeitoun, SC&A(b)

 B.S. Chemistry and Zoology; M.S. 

Fisheries; Ph.D. Environmental Sciences; 

40 years relevant experience 

Radioactive Waste 

Management 

Sally Zeff, ICF 

International(b)

M.A. Urban Planning; 30 years relevant 

experience 

Land Use, Transmission Lines 

Edward Carr, ICF 

International(b)

M.S. Atmospheric Science; 33 years 

relevant experience 

Meteorology, Air Quality 

Michael Bever, ICF 

International(b)

Ph.D. Anthropology; 20 years relevant 

experience 

Historic and Cultural 

Resources 

U.S. Geological Survey 

Gary Patterson Hydrology 

Pacific Northwest National Laboratory is operated by Battelle for the U.S. Department of Energy. 

ICF International, Sandy Cohen & Associates (SC&A), and Innovative Engineering and Safety Solutions, LLC (IESS 

Corp) are subcontractors to Information Systems Laboratories (ISL). 
APPENDIX B 

ORGANIZATIONS CONTACTED 

October 2016 B-1 NUREG–2176

APPENDIX B 

ORGANIZATIONS CONTACTED 

The following Federal, State, regional, Tribal, and local organizations were contacted during the 

course of the U.S. Nuclear Regulatory Commission staff’s independent review of potential 

environmental impacts from the construction and operation of two new nuclear units, Turkey 

Point Units 6 and 7, at the Turkey Point site in Miami-Dade County, Florida: 

Organization Name, City, State 

Advisory Council on Historic Preservation, Washington, D.C. 

Archaeological and Historical Conservancy, Inc., Davie, Florida

Asian American Advisory Board 

Assistant Director, Community Redevelopment Agency, City of Homestead, Florida 

Centro Campesino, Florida City, Florida 

City of Florida City, Florida City, Florida 

City of Homestead, Homestead, Florida 

City of Miami, Office of the City Attorney, Miami, Florida 

City of South Miami, South Miami, Florida 

Department of Health, Bureau of Radiation Control, Tallahassee, Florida 

Director of Planning and Zoning, City of South Miami, Florida 

Fish and Wildlife Services, South Florida Ecological Services Office, Vero Beach, Florida 

Florida Department of Environmental Protection, Tallahassee, Florida 

Florida Department of Environmental Protection, West Palm Beach, Florida 

Florida International University, Miami, Florida 

Florida Keys Aqueduct Authority, Key West, Florida 

Florida State Historic Preservation Officer (SHPO), Tallahassee, Florida 

Florida State House of Representatives, Tallahassee, Florida 

Florida State Senate, Tallahassee, Florida 

Florida Wildlife and Fisheries Conservation Commission, South Region Office, West Palm 

Beach, Florida 

Historic Preservation Administrator, City of Coral Gables, Florida 

Historic Preservation Officer, City of Miami, Florida 

Homestead Housing Authority, Homestead, Florida 
Appendix B 

NUREG–2176 B-2 October 2016

Miami-Dade County Community Action Agency, Miami, Florida 

Miami-Dade County Department of Planning and Zoning, Miami, Florida 

Miami-Dade County Department of Regulatory and Economic Resources, formerly DERM, 

Miami, Florida 

Miami-Dade County Office of Historic and Archaeological Resources, Miami, Florida 

Miami-Dade County Permitting, Environment, and Regulatory Affairs, Miami, Florida 

Miami-Dade County Planning, Miami, Florida 

Miami-Dade County Public Schools, Miami, Florida 

Miami-Dade Office of Community Advocacy, Miami, Florida 

Miami-Dade Water and Sewer Department, Miami, Florida 

Miccosukee Tribe of Indians of Florida, Miami, Florida 

Monroe County, Key West, Florida 

Muscogee (Creek) Nation, Okmulgee, Oklahoma 

NGO Sembrando Flores, Homestead, Florida 

NMFS, Southeast Regional Office, Saint Petersburg, Florida 

South Florida Water Management District, Hydrogeology Section, Water Supply, Palm Beach, 

Florida 

Stephen P. Clark Center, Miami, Florida 

Town of Cutler Bay, Cutler Bay, Florida 

Tribal Historic Preservation Officer (THPO), Poarch Band of Creek Indians, Atmore, Alabama 

Tribal Historic Preservation Officer (THPO), Seminole Nation of Oklahoma, Wewoka, Oklahoma 

Tribal Historic Preservation Officer (THPO), Seminole Tribe of Florida, Clewiston, Florida 

U.S. Department of Homeland Security, Federal Emergency Management Agency, Region IV, 

Atlanta, Georgia 

U.S. Environmental Protection Agency, Region 4, Atlanta, Georgia 

U.S. Geological Survey, Fort Lauderdale, Florida 

U.S. House of Representatives, Washington, D.C. 

U.S. Interior Fish and Wildlife Services, South Florida Ecological Services Office, Vero Beach, 

Florida 

U.S. National Marine Fisheries Services, Southeast Regional Office, St. Petersburg, Florida 

U.S. National Park Service, Biscayne National Park, Homestead, Florida 

U.S. National Park Service, Everglades National Park, Homestead, Florida 

U.S. Senate, Washington, D.C. 

Village of Pinecrest, Pinecrest, Florida 
APPENDIX C 

NRC AND USACE ENVIRONMENTAL REVIEW CORRESPONDENCE 

October 2016 C-1 NUREG–2176 

APPENDIX C 

NRC AND USACE ENVIRONMENTAL REVIEW CORRESPONDENCE 

This appendix contains a chronological list of correspondence between the U.S. Nuclear 

Regulatory Commission (NRC) or the U.S. Army Corps of Engineers (USACE) and Florida 

Power & Light Company (FPL). Other correspondence related to the environmental review of 

FPL’s application for combined construction permits and operating licenses (COLs) and a 

USACE permit at the Turkey Point Nuclear site in Miami-Dade County, Florida, is also included. 

All documents, with the exception of those containing proprietary information, are available 

electronically from the Public Electronic Reading Room found on the Internet at the following 

web address: www.nrc.gov/reading-rm.html. From this website, the public can gain access to 

the NRC’s Agencywide Documents Access and Management System (ADAMS), which provides 

text and image files of NRC’s public documents. The ADAMS accession number or Federal 

Register citation for each document is included within the parenthesis following the reference. 

November 10, 2008 NRC trip report for readiness assessment (C-1) visit for a future combined 

license application at the Turkey Point site (ML082880307). 

April 15, 2009 NRC trip report for readiness assessment (C-2/C-3) visit for a future 

combined license application at Turkey Point site (ML090850294). 

May 15, 2009 NRC trip report for readiness assessment (C-2) visit for a future combined 

license application at Turkey Point site (ML091320137). 

June 4, 2009 NRC trip report for pre-application visit with regulatory agencies related to 

a future combined license application at the Turkey Point site 

(ML091470726). 

June 30, 2009 FPL letter submitting an application for a combined license for Units 6 and 

7 at the Turkey Point site (ML091830589). 

July 23, 2009 Letter from NRC to FPL acknowledging receipt of the COL application for 

Turkey Point Units 6 and 7 (ML091890130). 

August 3, 2009 Federal Register notice of receipt and availability of application for a 

combined license for Turkey Point (ML092590051). 

August 7, 2009 Letter from FPL to NRC providing meteorological information for the 

Turkey Point COL application (ML092250585). 

September 4, 2009 Letter from NRC to FPL accepting for docketing the COL application for 

Turkey Point Units 6 and 7 (ML092380248). 
Appendix C 

NUREG–2176 C-2 October 2016 

September 16, 2009 Letter from the County of Monroe, Florida, requesting NRC to keep it 

informed of activities related to the NRC staff’s review of the COL 

application for Turkey Point Units 6 and 7 (ML092750383). 

October 1, 2009 FPL letter to NRC providing schedule for response to NRC staff’s 

requests for additional information (ML092810318). 

October 7, 2009 Federal Register notice of acceptance for docketing of an application for a 

combined license for Turkey Point Units 6 and 7 (ML092860057). 

November 10, 2009 FPL letter to NRC withdrawing the request for a limited work authorization 

(ML093170513). 

November 25, 2009 Letter from NRC to Ms. Susan Grimsley, Assistant County Attorney, 

County of Monroe, Florida, Acknowledging Receipt of the Letter from 

County of Monroe Proposal (Accession No. ML092960671). 

November 25, 2009 Letter from NRC to Mr. David S. Hobbie, Chief Regulatory Division, U.S. 

Army Corps of Engineers, NRC’s Environmental Impact Statement for 

FPL Combined License Application for Turkey Point, units 6 and 7 

(ML092610207). 

December 10, 2009 Letter from Mr. Donald Kinard, Chief Regulatory Division, U.S. Army 

Corps of Engineers, agreeing to become a cooperating agency for the 

environmental impact statement for FPL combined license application for 

Turkey Point, Units 6 and 7 (ML093520690). 

January 4, 2010 Letter from NRC to Ms. Zelda Ryles, Manager, South Dade Regional 

Library, Regarding Maintenance of Document at the South Dade 

Regional Library Related to Combined License Application for Turkey 

Point, Units 6 and 7 (ML092610278). 

January 4, 2010 Letter from NRC to Ms. Pamela Hogue, Manager, Homestead Branch 

Library, Regarding Maintenance of Document at the Homestead Branch 

Library Related to Combined License Application for Turkey Point, Units 6 

and 7 (ML092610521). 

May 28, 2010 Letter from NRC to Mr. M. Nazar, FPL, Providing the Turkey Point Units 6 

and 7 Nuclear Power Plants Combined License Application Review 

Schedule (ML101310404). 

June 9, 2010 Letter from NRC to Mr. W. Maher, FPL, Notice of Intent to Prepare an 

Environmental Impact Statement and Conduct Scoping Related to a

Combined License Application for Turkey Point, Units 6 and 7 

(ML101580552). 
Appendix C 

October 2016 C-3 NUREG–2176 

June 14, 2010 Letter from NRC to Mr. M. Nazar, FPL, Florida Power & Light – 

Application for a Combined License for the Turkey Point Nuclear Power 

Plant Units 6 and 7; the Notice of Hearing, Opportunity to Petition for 

Leave to Intervene, and Associated Order (ML101400547). 

June 18, 2010 Federal Register Notice, Florida Power & Light Company, Combined 

License Application for the Turkey Point Units 6 and 7, Notice of Hearing, 

Opportunity to Petition for Leave to Intervene and Associated Order 

Imposing Procedures for Access to Sensitive Unclassified NonSafeguards Information and Safeguards Information for Contention 

Preparation (ML102370715). 

June 18, 2010 Letter from NRC to Ms. N. Linehan, Florida Wildlife and Fisheries 

Conservation Commission, Request for Participation in the Scoping 

Process and List of State Listed Protected Species for the Environmental 

Review for the Turkey Point Units 6 and 7 Combined License Application 

Review (ML101610556). 

June 23, 2010 Letter from NRC to Mr. R. Nelson, Advisory Council on Historic 

Preservation, Request for Participation in the Scoping Process for the 

Turkey Point Units 6 and 7 Combined License Application Review 

(ML101610537). 

June 23, 2010 Letter from NRC to Mr. P. Souza, U.S. Fish and Wildlife Service, 

Notification and Request for Consultation and Participation in the 

Environmental Scoping Process and a List of Protected Species within 

the Area Under Evaluation for the Turkey Point Units 6 and 7 Combined 

License Application Review (ML101610560). 

June 23, 2010 Letter from NRC to Dr. R. Crabtree, National Marine Fisheries Service, 

Notification and Request for Consultation and Participation in the 

Environmental Scoping Process and a List of Protected Species within 

the Area Under Evaluation for the Turkey Point Units 6 and 7 Combined 

License Application Review (ML101610565). 

June 24, 2010 Letter from NRC to Those on the Attached List, Request for Participation 

in the Scoping Process for the Turkey Point Units 6 and 7 Combined 

License Application Review (ML101610568). 

June 24, 2010 Letter from NRC to Mr. S. Terry, Miccosukee Tribe of Indians of Florida, 

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 (ML101690501). 
Appendix C 

NUREG–2176 C-4 October 2016 

June 24, 2010 Letter from NRC to Ms. J. Bear, Muscogee (Creek) Nation, 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 (ML101690496). 

June 24, 2010 Letter from NRC to Mr. R. Thrower, Poarch Band of Creek Indians, 

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 (ML101690503). 

June 24, 2010 Letter from NRC to Mr. W. Steele, Seminole Tribe of Florida, 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 (ML101690499). 

June 24, 2010 Letter from NRC to Ms. N. Deere, Seminole Nation of Oklahoma, 

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 (ML101690497). 

June 29, 2010 Letter from NRC to Ms. L. Kammerer, Florida Deputy State Historic 

Preservation Officer, Notification and Request for Consultation and 

Participation in the Environmental Scoping Process for the Environmental 

Review of the Turkey Point Units 6 and 7 Combined License Application 

(ML101690480). 

June 29, 2010 Notice of Public Scoping Meeting for the Turkey Point Units 6 and 7 

Combined License (ML101690484). 

July 1, 2010 Letter from NRC to Mr. R. Carr, Archaeological and Historical 

Conservancy, Inc., 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 

(ML101690462). 

July 1, 2010 Letter from NRC to Ms. K Kauffman, Miami-Dade Office of Historic & 

Archaeological Resources, 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 

(ML101690468). 

July 1, 2010 Letter from NRC to Ms. E. Uguccioni, Historic Preservation Officer, City of 

Miami, 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 (ML101690472). 
Appendix C 

October 2016 C-5 NUREG–2176 

July 1, 2010 Letter from NRC to Ms. S. Chin, Historic Preservation Administrator, City 

of Coral Gables, 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 

(ML101730494). 

July 1, 2010 Letter from NRC to Mr. D. Wick, Assistant Director of Community 

Redevelopment Agency, City of Homestead, 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 (ML101730511). 

July 1, 2010 Letter from NRC to Mr. S. Youkilis, Director of Planning and Zoning, City 

of South Miami, 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 

(ML101730515). 

July 1, 2010 Letter from NRC to Those on the Attached List, Invitation to a 

Government-to-Government Meeting for the Turkey Point Units 6 and 7 

Combined License Application Environmental Review (ML101800575). 

July 8, 2010 Letter from Ms. C. Hall, Advisory Council on Historic Preservation, to 

NRC, Regarding Florida Power and Light’s Application for Two New 

Nuclear Power Plants, Turkey Point Site, Homestead, Florida 

(ML101900325). 

July 28, 2010 Letter from Ms. L. Kammerer, Florida Division of Historical Resources, to 

NRC, Providing Scoping Comments Regarding Cultural Resources 

(ML102220345). 

August 5, 2010 Letter from Mr. M. Croom, National Marine Fisheries Service, to NRC, 

Providing Scoping Comments and Information Supporting Consultation 

Under the Endangered Species Act and the Magnuson-Stevens Act 

(ML102320025). 

August 12, 2010 Letter from Ms. K. Kauffman, Miami-Dade Office of Historic & 

Archaeological Resources, to NRC, Providing Scoping Comments and 

Accepting the NRC Invitation to Consult (ML102390102). 

August 16, 2010 Letter from Ms. M. Poole, Florida Fish and Wildlife Conservation 

Commission, to NRC, Providing Scoping Comments and a List of Species 

(ML102280488). 
Appendix C 

NUREG–2176 C-6 October 2016 

August 30, 2010 Memorandum, Summary of July 22, 2010, Category 1 Public 

Teleconference with the Florida Power and Light Company to Discuss 

Environmental Information Needs for the Turkey Point Units 6 and 7 

Combined License Application (ML102150618). 

August 31, 2010 Memorandum, Summary of July 15, 2010, Public Meetings to Support the 

Review of the Turkey Point Units 6 and 7 Combined License Application 

(ML102080607). 

August 31, 2010 Letter from NRC to Mr. W. Maher, FPL, Turkey Point Units 6 and 7 

Combined License Application Online Reference Portal (ML102320391). 

September 3, 2010 Letter from Mr. M. Nazar, FPL, to NRC, Submittal of Annual Update to the 

COL Application – Revision 1, and the Semiannual Update of the 

Departures Report (ML102570371). 

September 14, 2010 Letter from Ms. A. Mullins, Seminole Tribe of Florida, to NRC, 

Assessment of Effects for the Proposed Construction of Two Additional 

Nuclear Reactors at Turkey Point, Miami-Dade County, Florida 

(ML102660296). 

September 21, 2010 Memorandum, Summary of the Environmental Site Audit Related to the 

Review of the Combined License Application for Turkey Point Units 6 and 

7 (ML101880784). 

October 21, 2010 Memorandum, Summary of the Environmental Alternative Sites Audit 

Related to the Review of the Combined License Application for Turkey 

Point Units 6 and 7 (ML102660659). 

November 1, 2010 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, NRC June 2010 Environmental 

Audit, Supplemental Information Request Response 1 (ML103080837). 

November 1, 2010 Summary of September 29, 2010, Teleconference Between NRC and the 

Miami-Dade Water and Sewer Department Regarding Use of Treated 

Wastewater for Turkey point Units 6 and 7 (ML103490981). 

November 5, 2010 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Combined License Application 

Online Reference Portal (ML103130133). 

November 16, 2010 Memorandum, Summary of the November 2, 2010, Teleconference 

between NRC and EPA Regarding Emerging Pollutants of Concern in

Cooling Water (ML110050170). 

December 1, 2010 Memorandum, Scoping Summary Report Related to the Environmental 

Scoping Process for the Turkey Point Units 6 and 7 Combined License 

Application (ML103130609). 
Appendix C 

October 2016 C-7 NUREG–2176 

December 8, 2010 Summary of the October 20, 2010, Meeting between the Seminole Tribe 

of Florida, the U.S. Army Corps of Engineers, and the NRC to Discuss 

Issues Related to Cultural Resources (ML103420623). 

December 15, 2010 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, NRC June 2010 Environmental 

Audit, Supplemental Information Request Response 2, Part 1 

(ML103540248). 

December 15, 2010 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, NRC June 2010 Environmental 

Audit, Supplemental Information Request Response 2, Part 2 

(ML103560533). 

December 21, 2010 Letter from Mr. M. Nazar, FPL, to NRC, Early Submittal of Annual Update 

to the COL Application – Revision 2, and the Semiannual Update of the 

Departures Report (ML103630059). 

January 11, 2011 Memorandum, Summary of October 26, 2010, Teleconference with Dr. G. 

Rand, Florida International University, Regarding Reclaimed Water 

Quality and Toxicology Testing (ML110200187). 

February 1, 2011 Email Forwarding U.S. Army Corps of Engineers Request for Additional 

Information Related to Site Selection (ML110330126). 

February 28, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, NRC June 2010 Environmental 

Audit, Submittal of Groundwater Model Development and Analysis: Units 

6 and 7 Dewatering and Radial Collector Well Simulations, Revision 1 

(ML110610723). 

March 1, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1102231 Related to ESRP Section 2.7, 

Cultural Resources, for the Combined License Application Review for 

Turkey Point Units 6 and 7 (ML110601020). 

March 1, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1102232 Related to ESRP Section 9.3.1, 

Site Selection Process, for the Combined License Application Review for 

Turkey Point Units 6 and 7 (ML110601062). 

March 1, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1102233 Related to ESRP Section 3.1, 

External Appearance and Plant Layout, for the Combined License 

Application Review for Turkey Point Units 6 and 7 (ML110601071). 
Appendix C 

NUREG–2176 C-8 October 2016 

March 7, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1103071 Related to ESRP Section 5.7, 

Meteorological and Air Quality Impacts, for the Combined License 

Application Review for Turkey Point Units 6 and 7 (ML110660019). 

March 9, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1103091 Related to ESRP Section 5.3.4, 

Non-Radiological Health, for the Combined License Application Review 

for Turkey Point Units 6 and 7 (ML110680020). 

March 9, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1103092 Related to ESRP Section 3.4.4, 

Nonradioactive Waste Systems, for the Combined License Application 

Review for Turkey Point Units 6 and 7 (ML110680022). 

March 9, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1103093 Related to ESRP Section 2.2, Land 

Use, for the Combined License Application Review for Turkey Point Units 

6 and 7 (ML110680053). 

March 9, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1103094 Related to ESRP Section 9.3, 

Alternative Sites, for the Combined License Application Review for Turkey 

Point Units 6 and 7 (ML110680062). 

March 10, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1103101 Related to ESRP Section 2.4.1, 

Terrestrial and Wetlands Ecology, for the Combined License Application 

Review for Turkey Point Units 6 and 7 (ML110690002). 

March 10, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1103102 Related to ESRP Section 2.5, 

Socioeconomics, for the Combined License Application Review for

Turkey Point Units 6 and 7 (ML110690003). 

March 11, 2011 Letter from NRC to Mr. D. Vela, National park Service, Invitation to 

Become a Cooperating Agency for the U.S. Nuclear Regulatory 

Commission’s Environmental Impact Statement for the Florida Power and 

Light Company Combined License Application for Turkey Point Units 6 

and 7, Miami-Dade County, Florida (ML102030501). 

March 14, 2011 Memorandum, Summary of February 24, 2011, Category 3 Public 

Meeting with the Florida Power and Light Company to Discuss the

Revised Groundwater Model for the Turkey Point Units 6 and 7 Combined 

License Application (ML110620735). 
Appendix C 

October 2016 C-9 NUREG–2176 

March 14, 2011 Letter from NRC to Mr. M. Nazar FPL Environmental Request for 

Additional Information Letter 120316 Related to ESRP Section 9.3-US 

Army Corps of Engineers, For the Combined License Application Review 

for Turkey Point, Units 6 and 7 (ML12074A005). 

March 17, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information eRAI 5340, Revision 1, U.S. Army Corps of 

Engineers for Application Section 9.3 (ML110820044). 

March 17, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, NRC June 2010 Environmental 

Audit, Submittal of Groundwater Flow Model (MODFLOW) Calculation 

Revision 4 Input/Output Files (ML110830787). 

April 6, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1104071 Related to ESRP Section 9.3.1, 

Site Selection Process, for the Combined License Application Review for 

Turkey Point Units 6 and 7 (ML110960520). 

April 6, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103094 (RAI 5563), 

Environmental Standard Review Plan Section 9.3, Alternative Sites 

(ML110980612). 

April 12, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1104121 Related to ESRP Section 9.3, 

Alternative Sites, for the Combined License Application Review for Turkey 

Point Units 6 and 7 (ML111010357). 

April 15, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1102231 (RAI 5480), 

Environmental Standard Review Plan Section 2.7, Cultural Resources 

(ML111090274). 

April 15, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1102232 (RAI 5481), 

Environmental Standard Review Plan Section 9.3.1, Site Selection 

Process (ML111080761). 
Appendix C 

NUREG–2176 C-10 October 2016 

April 15, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1102233 (RAI 5482), 

Environmental Standard Review Plan Section 3.1, External Appearance 

and Plant Layout (ML11108A146). 

April 20, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103071 (RAI 5498), 

Environmental Standard Review Plan Section 5.7, Meteorological and Air 

Quality Impacts (ML111170331). 

April 21, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103092 (RAI 5595), 

Environmental Standard Review Plan Section 3.4.4, Non-Radioactive 

Waste Systems (ML11122A054). 

April 22, 2011 Letter from Mr. D. Vela, National Park Service, Southeast Regional 

Office, to Mr. S. Flanders, NRC, Accepting the NRC Invitation to Become 

a Cooperating Agency on the Turkey Point, Units 6 and 7, Environmental 

Impact Statement (ML111160378). 

April 25, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103093 (RAI 5561), 

Environmental Standard Review Plan Section 2.2, Land Use 

(ML11116A160). 

April 25, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103091 (RAI 5594), 

Environmental Standard Review Plan Section 5.3.4, Non-Radiological 

Health (ML11116A161). 

April 26, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103102 (RAI 5570), 

Environmental Standard Review Plan Section 2.5, Socioeconomics 

(ML11118A177). 

April 26, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103101 (RAI 5562), 

Environmental Standard Review Plan Section 2.4.1, Terrestrial and 

Wetlands Ecology (ML111180713). 
Appendix C 

October 2016 C-11 NUREG–2176 

April 27, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1104271 Related to ESRP Section 1.5, 

Compliance and Consultations, for the Combined License Application 

Review for Turkey Point Units 6 and 7 (ML111170533). 

May 4, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1105042 Related to ESRP Section 2.4.2, 

Aquatic Ecology, for the Combined License Application Review for Turkey 

Point Units 6 and 7 (ML111240011). 

May 4, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1105043 Related to ESRP Section 4.3.2, 

Aquatic Impacts, for the Combined License Application Review for Turkey 

Point Units 6 and 7 (ML111240013). 

May 4, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1105041 Related to ESRP Section 9.3, 

Alternative Sites, for the Combined License Application Review for Turkey 

Point Units 6 and 7 (ML111230733). 

May 5, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1105051 Related to ESRP Section 8.4, 

Assessment of Need for Power, for the Combined License Application 

Review for Turkey Point Units 6 and 7 (ML111240406). 

May 18, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Audit Data and Information Needs AQ-4, H-13, H-23, H-31, H-34, H-35, 

H-38, H-40, NR-6 (ML11143A090). 

May 23, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, First (Partial) Response to NRC 

Environmental Request for Additional Information Letter 1104071 (RAI 

5588), Environmental Standard Review Plan Section 9.3.1, Alternative 

Site Selection Process (ML11145A041). 

May 27, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, First (Partial) Response to NRC 

Environmental Request for Additional Information Letter 1104121 (RAI 

5589), Environmental Standard Review Plan Section 9.3.1, Alternative 

Site Selection Process (ML11151A198). 

June 3, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1104271 (RAI 5699), 

Environmental Standard Review Plan Section 1.5, Compliance and 

Consultations (ML11157A123). 
Appendix C 

NUREG–2176 C-12 October 2016 

June 10, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1105041 (RAI 5708), 

Environmental Standard Review Plan Section 9.3, Alternative Sites 

(ML11165A034). 

June 13, 2011 Email from NRC to Mr. W. Maher, FPL, Turkey Point Environmental – 

Final RAI EIS 9.4 (RAI No. 5770) – System Design Alternatives 

(ML11175A140). 

June 14, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 110614 Related to ESRP Section 3.2.2, 

Structures with a Major Environmental Interface, for the Combined 

License Application Review for Turkey Point Units 6 and 7 

(ML111650769). 

June 14, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 110614 Related to ESRP Section 2.3, 

Water, for the Combined License Application Review for Turkey Point 

Units 6 and 7 (ML111650597). 

June 14, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1105042 (RAI 5704), 

Environmental Standard Review Plan Section 2.4.2, Aquatic Ecology 

(ML11168A043). 

June 20, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1105043 (RAI 5707), 

Environmental Standard Review Plan Section 4.3.2, Aquatic Impacts 

(ML11172A285). 

June 20, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1105051 (RAI 5565), 

Environmental Standard Review Plan Section 8.4, Assessment of Need 

for Power (ML11178A015). 

July 7, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103101 (RAI 5562), 

Environmental Standard Review Plan Section 2.4.1, Terrestrial and 

Wetlands Ecology (ML11195A164). 
Appendix C 

October 2016 C-13 NUREG–2176 

July 7, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103093 (RAI 5561), 

Environmental Standard Review Plan Section 2.2, Land Use 

(ML11192A042). 

July 11, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Revised Schedule for Response to 

NRC Environmental Request for Additional Information Letter 1104071 

(RAI 5588), Environmental Standard Review Plan Section 9.3.1, 

Alternative Site Selection Process (ML11194A007). 

July 27, 2011 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 1107271 Related to ESRP Section 5.2, 

Water Related Impacts, for the Combined License Application Review for 

Turkey Point Units 6 and 7 (ML112081475). 

July 28, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 2011001 (RAI 5770), 

Environmental Standard Review Plan Section 9.4, System Design 

Alternatives (ML11213A095). 

July 29, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 110614 (RAI 5764), 

Environmental Standard Review Plan Section 3.2.2, Structures with a 

Major Environmental Interface (ML11214A031). 

July 29, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 110614 (RAI 5763), 

Environmental Standard Review Plan Section 2.3, Water 

(ML11214A032). 

August 8, 2011 Letter from Mr. P. Kruger, U.S. Army Corps of Engineers, to Ms. F. Braun, 

Florida Power & Light Company, Regarding an Alternative to the Western 

Transmission Line Corridor (ML112690006). 

August 17, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Revised Schedule for Response to 

NRC Environmental Request for Additional Information Letter 1104121 

(RAI 5589), Environmental Standard Review Plan Section 9.3, Alternative 

Sites (ML11231A239). 
Appendix C 

NUREG–2176 C-14 October 2016 

August 30, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 110614 (RAI 5763), 

Environmental Standard Review Plan Section 2.3, Water 

(ML11243A165). 

September 1, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1104071 (RAI 5588), 

Environmental Standard Review Plan Section 9.3.1, Alternative Site 

Selection Process (ML11250A130). 

September 2, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information RAI 5340 Revision 1 Standard Review Plan

Section: EIS USACE – U.S. Army Corps of Engineers for Application 

Section: 9.3 (ML11250A052). 

September 2, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1103094 (RAI 5563), 

Environmental Standard Review Plan Section 9.3 - Alternative Sites 

(ML11251A209). 

September 6, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 110614 (RAI 5763), 

Environmental Standard Review Plan Section 2.3, Water 

(ML11251A168). 

September 12, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1107271 (RAI 5767), Related to 

ESRP Section 5.2, Water Related Impacts (ML11257A133). 

September 13, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Revised Schedule for Response to 

NRC Environmental Request for Additional Information Letter 1104121 

(RAI 5589), Environmental Standard Review Plan Section 9.3, Alternative 

Sites (ML11258A158). 

September 13, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 110614 (RAI 5763), 

Environmental Standard Review Plan Section 2.3, Water 

(ML11258A156). 
Appendix C 

October 2016 C-15 NUREG–2176 

September 13, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1104071 (RAI 5588), 

Environmental Standard Review Plan Section 9.3.1, Alternative Site 

Selection Process (ML11258A155). 

September 30, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information Letter 1104121 (RAI 5589), 

Environmental Standard Review Plan Section 9.3, Alternative Sites 

(ML11276A099). 

October 27, 2011 Letter from NRC to Mr. M. Nazar, FPL, Issuance of a Revised Review 

Schedule for the Combined License Application Review for Turkey Point, 

Units 6 and 7 (ML111040122). 

November 10, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Environmental 

Request for Additional Information RAI 5340, Standard Review Plan 

Section: EIS USACE – US Army Corps of Engineers, Application Section 

9.3 (ML113190089). 

November 10, 2011 Letter from Mr. W. Maher, FPL, to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Revised Schedule for Response to 

NRC Environmental Request for Additional Information Letter 110614 

(RAI 5763) Environmental Standard Review Plan Section 2.3 - Water 

(ML11318A323). 

December 8, 2011 Letter from NRC to Mr. M. Nazar, FPL Environmental Request for 

Additional Information Letter 1112081 Related to ESRP Section 4.2. 

Water-Related Impacts, for the Combined License Application Review for 

Turkey Point, Units 6 and 7 (ML113420010). 

December 14, 2011 Letter from Mr. W. Maher, FPL to NRC eRAI Letter 1112081 Related to 

ESRP Section 4.2, Water-related Impacts, For the COL application review 

for Turkey Point, Units 6 and 7 (ML11350A197). 

January 23, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 1112082 (RAI 5769) Related to ESRP 

Section 9.3 – Alternative Sites (ML12025A266). 

January 23, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 1112081 (RAI 5765) Related to ESRP 

Section 4.2 – Water-Related Impacts (ML12025A263). 
Appendix C 

NUREG–2176 C-16 October 2016 

March 7, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 110614, ESRP Section 2.3, Water 

March 13, 2012 Letter from NRC, NRC to Mr. M.K. Nazar, FPL, Environmental Request 

for Additional Information Letter 120316 Related to ESRP Section 9.3 -US 

Army Corps of Engineers, for the Combined License Application Review 

for Turkey Point, Units 6 and 7 (ML12074A005). 

March 21, 2012 Letter from NRC to Mr. M.K. Nazar, FPL, Environmental Request for 

Additional Information Letter 122103 Related to ESRP Section 5.2, Water 

Related Impacts for Combined License Application Review for Turkey 

Point, Units 6 and 7 (ML12081A068). 

March 22, 2012 Letter from NRC to Mr. M.K. Nazar, FPL, Environmental Request for 

Additional Information Letter 122203 Related to Environmental Standard 

Review Plan Section 7.2, Water Use and Quality, for the Combined 

License Application Review for Turkey Point, Units 6 and 7 

(ML12081A238). 

April 3, 2012 Letter from NRC to Mr. M. K. Nazar, FPL, Environmental Request for 

Additional Information Letter 120329 Related to Environmental Standard 

Review Plan Section 2.3.1 Hydrology, for the Combined License 

Application Review for Turkey Point, Units 6 and 7 (ML12089A145). 

April 4, 2012 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 120403 Related to Environmental Standard 

Review Plan Section 5.8.1 Etiological Agents, for the Combined License 

Application Review for Turkey Point, Units 6 and 7 (ML1209A302). 

April 26. 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company, 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 120316 (RAI 6347 Rev.1) Related to ESRP 

Section 9.3- US Army Corps of Engineers (ML12121A365). 

May 4, 2012 Letter from NRC to Mr. M.K Nazar, FPL, Turkey Point Units 6 and 7 

Combined License Application Review Schedule (ML120740390). 

May 7, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response Schedule for NRC 

Request for Additional Information Letter 122103 (RAI 5766 Rev. 2) 

Related to ESRP Section 5.2 - Water Related Impacts (ML1213A166). 
Appendix C 

October 2016 C-17 NUREG–2176 

May 10, 2012 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 120510 Related to Environmental Standard 

Review Plan Section 5.2 Water Related Impacts for the Combined 

License Application Review for Turkey Point, Units 6 and 7 

(ML12122A886). 

May 11, 2012 Letter from Mr. M. Nazar, FPL, Florida Power & Light Company, 

Response to NRC COLA Review Schedule Letter dated May 4, 2012 

(ML12156A420). 

May 21, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 122103 (RAI 5766 Rev. 2) Related to ESRP 

Section 5.2 - Water Related Impacts (ML1214A357). 

May 21, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, 10 CFR 52.3 Response to NRC 

Request for Additional Information Letter 120403 (RAI 6350 Rev. 1) 

Related to ESRP Section 5.8.1 - Etiological Agents (ML12143A356). 

June 25, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, 10 CFR 52.3 Response to NRC 

Request for Additional Information Letter 120510 (RAI 6384 Rev. 1) 

Related to ESRP Section 5.2 - Water Related Impacts (ML12178A552).

June 25, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, NRC June 2010 Environmental 

Audit Revised Supplemental Information Request Response 2 Part 2

(ML12178A553). 

June 29, 2012 Letter from Mr. R. Braun, South Florida Water Management District to 

NRC, Florida Power and Light Combined License Application for Turkey 

Point Units 6 and 7 – Water Availability at Alternative Sites 

(ML12191A171). 

July 12, 2012 Notice of Forthcoming Public Teleconference to Discuss the 

Environmental Review Related to Florida Power and Light’s Turkey Point 

Units 6 and 7, Combined License Application (ML12194A143). 

July 18, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 120329, Related to ESRP Section 2.3.1- 

Hydrology (ML12202A068). 

July 30, 2012 Memorandum, Summary Meeting with South Florida Water Management 

District Related to the Alternative Sites for the Proposed Turkey Point 

Units 6 and 7 Environmental Review (ML12205A348). 
Appendix C 

NUREG–2176 C-18 October 2016 

August 18, 2012 Memorandum, Summary of Meeting with Florida Power and Light to 

Discuss the Environmental Review Related to Turkey Point Units 6 and 7 

Combined License Application – Socioeconomics (ML12221A192). 

August 20, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 120329, Related to ESRP Section 2.3.1- 

Hydrology (ML12234A549). 

August 30, 2012 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 120830 Related to Environmental Standard 

Review Plan Section 9.3.1 Alternative Site Selection, for the Combined 

License Application Review for Turkey Point, Units 6 and 7 

(ML12242A329). 

October 17, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Supplemental Response to NRC 

Request for Additional Information Letter 120329 Related to ESRP 

Section 2.3.1- Hydrology (ML12293A236). 

November 14, 2012 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 121114 Related to the Environmental 

Standard Review Plan Section 9.3.1 Alternative Site Selection, for the 

Combined License Application Review for Turkey Point, Units 6 and 7 

(ML12346A225). 

November 15, 2012 Notice of Forthcoming Public Meeting to Discuss Environmental Requests 

for Additional Information Draft Responses Relating to the Alternative 

Sites Selection Process for Florida Power and Light’s Turkey Point Units 

6 and 7 Combined License Application (ML12310A157). 

December 12, 2012 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 120830, Related to ESRP Section 9.3.1- 

Alternative Site Selection (ML12349A243). 

January 3, 2013 Memorandum, Summary of the Public Meeting to Discuss Environmental 

Requests for Additional Information Draft Responses Relating to the 

Alternative Site Selection Process For Florida Power and Light’s Turkey 

Point Units 6 and 7 Combined License Application (ML12352A203).

January 10, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 120830, eRAI 6353 Rev 2, Related to ESRP 

Section 9.3.1-Alternative Site Selection (ML13011A348). 
Appendix C 

October 2016 C-19 NUREG–2176 

January 17, 2013 Notice of Forthcoming Public Teleconference to Follow up on Action 

Items from the December 7, 2012, Public Meeting Relating to the

Alternative Sites Selection Process for Florida Power & Light’s Turkey 

Point Units 6 and 7 Combined License Application (ML13002A490).

February 6, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 120830, Related to ESRP Section 9.3.1- 

Alternative Site Selection (ML13039A018). 

February 12, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Status of Actions to Address NRC 

COLA Review Schedule Letter dated May 4, 2012 (ML13044A567). 

February 13, 2013 Letter from NRC to Mr. M. Nazar, FPL, Follow-up Questions to 

Environmental Requests for Additional Information 6353 Question 3 

Related to ESRP Section 9.3.1 Alternative Site Selection, for the 

Combined License Application Review for Turkey Point Units 6 and 7 

(ML13042A155). 

February 25, 2013 Memorandum, Summary of Public Teleconference to Discuss 

Environmental Requests for Additional Information Draft Responses 

Relating to the Alternative Site Selection Process for Florida Power and 

Light’s Turkey Point Units 6 and 7 Combined License Application

(ML13051A425). 

February 28, 2013 Letter from NRC to Mr. M.K Nazar, FPL, Turkey Point Units 6 and 7 

Combined License Application Review of Alternative Sites 

(ML13036A340). 

March 13, 2013 Letter from NRC to Mr. M. Nazar, FPL, Environmental Requests for 

Additional Information Letter 120316 Related to ESRP Section 9.3-US 

Army Corps of Engineers, for the Combined License Application Review 

for Turkey Point Units 6 and 7 (ML12074A005). 

March 26, 2013 Letter from Mr. R. Orthen, FPL to NRC Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Supplemental Response to NRC 

Request for Additional Information Letter 120329, Related to ESRP 

Section 2.3.1- Hydrology (ML13127A052). 

April 2, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Relocation Changes for the

Combined License Application, Part 3 Environmental Report, Subsection 

3.9, Preconstruction and Construction Activities (ML13093A409).
Appendix C 

NUREG–2176 C-20 October 2016 

April 18, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Supplemental Response to NRC 

Request for Additional Information Letter 120830, Related to ESRP 

Section 9.3.1- Alternative Site Selection Process (ML13109A431). 

May 10, 2013 Notice of Forthcoming Meeting to Discuss Environmental Requests for 

Additional Information Draft Responses Relating to the Alternative Sites 

Selection Process for Turkey Point Units 6 and 7 Combined License 

Application (ML13130A327). 

June 19, 2013 Memorandum, Summary of Public Meeting to Discuss the Environmental 

Review for Florida Power and Light’s Turkey Point Units 6 and 7

Combined License Application (ML13158A220). 

July 8, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and Supplemental Response to NRC 

Request for Additional Information Letter 120830, Related to ESRP 

Section 9.3.1- Alternative Site Selection (ML13196A063). 

July 8, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and Supplemental Response to NRC 

Request for Additional Information Letter 121114, Related to ESRP 

Section 9.3.1- Alternative Site Selection (ML13196A064). 

September 11, 2013 Letter from Mr. M. Raffenberg, FPL to US Army Corps of Engineers, 

Regarding Requests for Additional Information for a Department of the 

Army Permit, Assigned Number SAJ-2009-02417, Turkey Point Units 6 

and 7 Project (ML15037A237). 

October 9, 2013 Letter from NRC to Mr. M. Nazar, FPL, Environmental Request for 

Additional Information Letter 131009 Related to the Environmental 

Standard Review Plan Section 9.3.1 Alternative Site Selection, for the 

Combined License Application Review for Turkey Point, Units 6 and 7 

(ML13280A543). 

November 1, 2013 Notice of Forthcoming Public Meeting to Discuss the Alternative Sites 

Selection Analysis for Florida Power and Light’s Turkey Point Units 6 and 

7 Combined License Application (ML13301A630). 

November 25, 2013 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 131009, Related to ESRP Section 9.3- 

Alternative Site Selection Process (ML13330B668). 

December 13, 2013 Memorandum, Summary of Public Meeting Discussing the Alternative 

Sites Selection Process for Florida Power and Light’s Turkey Point Units 

6 and 7 Combined License Application (ML13343A323). 
Appendix C 

October 2016 C-21 NUREG–2176 

April 17, 2014 Letter from NRC to Mr. M.K Nazar, FPL, Turkey Point Units 6 and 7 

Combined License Application Environmental Review of Alternative Sites 

and Schedule Updates (ML14065A577). 

June 4, 2014 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Supplemental Response to NRC 

Request for Additional Information Letter No. 72, Liquid Waste 

Management Systems (ML14156A393). 

June 12, 2014 Notice of Forthcoming Public Teleconference to Discuss Potential 

Construction Noise Impacts to Aquatic Ecology Relating to the Florida 

Power and Light Turkey Point Units 6 and 7 Combine License Application 

(ML14163A426). 

June 18, 2014 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Supplemental Response to NRC 

Request for Additional Letter No .080, Related to SRP Section 20.01.03 

Population Density (ML14188C484). 

July 22, 2014 Memorandum, Summary of the June 23, 2014, Public Teleconference to 

Discuss Potential Aquatic Ecology Construction Impacts as a Result of 

the Florida Power and Light’s turkey Point Units 6 and 7 Combined 

License Application (ML14211A534). 

August 12, 2014 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Construction Noise and Vibration 

Aquatic Impacts Assessment Report for the Combined License 

Application Part 3, Environmental Report (ML14226A013). 

October 22, 2014 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Supplemental Response to NRC 

Request for Additional Information Letter No. 031, Standard Review Plan 

Section 12.03-12.04, Radiation Protection Design Features 

(ML14303A671). 

November 14, 2014 Memorandum, Supplemental Site Audit Summary Related to the 

Environmental Review of the Proposed Turkey Point Nuclear Power Plant 

Units 6 and 7 (ML14311A792). 

February 25, 2015 Letter from NRC to Mr. L. Williams, U.S. Fish and Wildlife Service, 

Request for Comments on the Draft Environmental Impact Statement 

and Biological Assessment for Turkey Point Nuclear Plant Units 6 and 7 

(ML15049A309). 
Appendix C 

NUREG–2176 C-22 October 2016 

February 25, 2015 Letter from NRC to Mr. R. Neslon, Advisory Council on Historic 

Preservation, Notification of the Issuance of the Draft Environmental 

Impact Statement for the Turkey Point Nuclear Plant Units 6 and 7 

(ML15049A317). 

February 25, 2015 Letter from NRC to Mr. M. Nazar, Florida Power & Light Company, Notice 

of Availability of the Draft Environmental Impact Statement for Turkey 

Point Nuclear Plant Units 6 and 7 (ML15049A302). 

February 25, 2015 Letter from NRC to Mr. M. Croom, U.S. National Marine Fisheries 

Services, Request for Comments on the Draft Environmental Impact 

Statement, Essential Fish Habitat, and Biological Assessment for the 

Turkey Point Nuclear Plant Units 6 and 7 (ML15049319). 

February 26, 2015 Letter from NRC to Mr. H. Mueller, U.S. Environmental Protection 

Agency, Notification of the Issuance of the Draft Environmental Impact 

Statement for the Turkey Point Nuclear Plant Units 6 and 7 

(ML15049A313). 

March 5, 2015 NRC Federal Register Notice, Florida Power and Light Company, 

Combined License Application for Turkey Point Nuclear Power Plant, 

Units 6 and 7 Draft Environmental Impact Statement Request for 

Comments (ML15049A320). 

March 6, 2015 Environmental Protection Agency (EPA) Federal Register Notice, Florida 

Power & Light Company, Combined License Application for Turkey Point 

Nuclear Power Plant, Units 6 and 7 Draft Environmental Impact 

Statement Request for Comments 80 FR 12173.

March 16, 2015 Letter from NRC to Dr. T. Parsons, Compliance and Review, Notification 

of the Issuance of the Draft Environmental Impact Statement for the 

Turkey Point Nuclear Plant Units 6 and 7 (ML15065A208). 

March 16, 2015 Letter from NRC to Mr. F. Dayhoff, Miccosukee Tribe of Indians of Florida 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15065A305).

March 16, 2015 Letter from NRC to Mr. E. Spain, Muscogee (Creek) Nation, Notification 

of the Issuance of the Draft Environmental Impact Statement for the 

Turkey Point Nuclear Plant Units 6 and 7 (ML15065A322). 

March 16, 2015 Letter from NRC to Mr. R. Thrower, Poarch Band of Creek Indians, 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15065A330).

March 16, 2015 Letter from NRC to Ms. N. Harjo, Seminole Nation of Oklahoma, 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15065A365).
Appendix C 

October 2016 C-23 NUREG–2176 

March 16, 2015 Letter from NRC to Dr. P. Backhouse, Seminole Tribe of Florida 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15065A366).

March 16, 2015 Letter from NRC to Mr. R. Carr, Archeological and Historical 

Conservancy, Inc., Notification of the Issuance of the Draft Environmental 

Impact Statement for the Turkey Point Nuclear Plant Units 6 and 7 

(ML15069A578). 

March 16, 2015 Letter from NRC to Mr. R. Bendus, State Historic Preservation Officer, 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15069A558).

March 16, 2015 Letter from NRC to Ms. M. Schmitt, Preservation Officer, City of Miami, 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15065A182).

March 16, 2015 Letter from NRC to Ms. K. Kauffman, Office of Historic Preservation, 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15065A261).

March 17, 2015 Letter from NRC to Mr. R. Ammirato, Homestead Community 

Redevelopment Agency, Notification of the Issuance of the Draft

Environmental Impact Statement for the Turkey Point Nuclear Plant Units 

6 and 7 (ML15076A291). 

March 17, 2015 Letter from NRC to Ms. D. Spain, Historic Preservation Administrator, 

Notification of the Issuance of the Draft Environmental Impact Statement 

for the Turkey Point Nuclear Plant Units 6 and 7 (ML15065A363).

March 17, 2015 Letter from NRC to Mr. C. Brimo, City of South Miami, Notification of the 

Issuance of the Draft Environmental Impact Statement for the Turkey 

Point Nuclear Plant Units 6 and 7 (ML15076A244). 

April 27, 2015 Email from Seminole Tribe of Florida to U.S. Army Corps of Engineers 

Regarding Seminole Tribe of Florida Request to Extend Turkey Point 

Comment Period on the Draft Environmental Impact Statement 

(ML15153A255). 

May 14, 2015 Email from National Park Service to NRC Requesting NRC to Extend 

Turkey Point Comment Period on the Draft Environmental Impact 

Statement (ML15153A234). 

May 14, 2015 Email from U.S. Environmental Protection Agency Requesting NRC to 

Extend Turkey Point Comment Period on the Draft Environmental Impact 

Statement (ML15153A227). 
Appendix C 

NUREG–2176 C-24 October 2016 

June 23, 2015 Summary of the June 23, 2015, U.S. Army Corps of Engineers, and the 

NRC Meeting with Seminole Tribe of Florida to Discuss Turkey Point 

National Historic Preservation Act Section 106 Consultation 

(ML16266A254). 

June 24, 2015 Summary of the June 24, 2015, U.S. Army Corps of Engineers, and the 

NRC Meeting with Miccosukee Tribe of Indians of Florida to Discuss 

Turkey Point National Historic Preservation Act Section 106 Consultation 

(ML16266A255). 

August 20, 2015 Memorandum, Summary of Public Meeting Conducted for the Draft 

Environmental Impact Statement for the Turkey Point Units 6 and 7 

Combined License Application (ML15219A261). 

October 5, 2015 Letter from Mr. B. M. Mueller, Seminole Tribe of Florida Tribal Historic 

Preservation Officer, to Ms. M. Clouser, U.S. Army Corps of Engineers, 

Related to Transmission Line Corridors for the Combined License

Application Review for Turkey Point, Units 6 and 7 (ML15289A368). 

November 2, 2015 Letter from NRC to Mr. M. Nazar, FPL Environmental Request for 

Additional Information Letter 150211 Related to Aquatic and Terrestrial 

Ecology and Hydrology/Groundwater, for the Combined License 

Application Review for Turkey Point, Units 6 and 7 (ML15307A160). 

December 17, 2015 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Partial Response to NRC Request 

for Additional Information Letter No. 150211, Related to 

Hydrology/Ground Water (ML15364A408). 

January 25, 2016 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Supplemental Response to NRC 

Request for Additional Information Letter No. 150211, Related to 

Hydrology/Ground Water (ML16028A121). 

February 3, 2016 Letter from NRC to Mr. M. Nazar, FPL Environmental Request for 

Additional Information Letter 160302 Related to Radioactive WasteManagement Systems and Meteorology and Air Quality, for the 

Combined License Application Review for Turkey Point, Units 6 and 7 

(ML16033A453). 

February 22, 2016 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 160302, Related to Radioactive Waste 

Management Systems (ML16061A223). 
Appendix C 

October 2016 C-25 NUREG–2176 

February 29, 2016 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Response to NRC Request for 

Additional Information Letter 160302, Related to Meteorology and Air 

Quality (ML16062A035). 

March 7, 2016 Letter from Mr. I. Gilbert, U.S. Army of Corps of Engineers to Mr. F. 

Dayhoff, Miccosukee Tribe of Indians of Florida Tribal Historic

Preservation Officer, Related to Consultation and Coordination for the 

Combined License Application Review for Turkey Point, Units 6 and 7 

(ML16172A120). 

March 7, 2016 Letter from Mr. W. Maher, FPL to NRC, Florida Power & Light Company 

Proposed Turkey Point Units 6 and 7, Partial Response to NRC Request 

for Additional Information Letter 150211, Related to Hydrology/Ground 

Water (ML16071A005). 

March 31. 2016 Letter from Mr. M. Raffenberg, FPL to Ms. M. Clouser, U.S. Army Corps 

of Engineers, Related to Transmission Line Corridors for the Combined 

License Application Review for Turkey Point, Units 6 and 7 

(ML16095A127). 

August 2, 2016 Letter from Mr. B. M. Mueller, Seminole Tribe of Florida Tribal Historic 

Preservation Officer, to Ms. M. Clouser, U.S. Army Corps of Engineers, 

Related to Cultural Resources for the Combined License Application 

Review for Turkey Point, Units 6 and 7 (ML16266A253). 

September 28, 2016 Letter from NRC to Mr. L. Williams, U.S. Fish and Wildlife Service, 

Response to Comments Received on the Biological Assessment for the 

Proposed Turkey Point Units 6 and 7 (ML16237A312). 

October 27, 2016 Supplemental Site Audit Trip Report Related to the Environmental Review 

of the Proposed Turkey Point Units 6 and 7 (ML16280A339). 

APPENDIX D 

SCOPING COMMENTS AND RESPONSES 

October 2016 D-1 NUREG–2176 

APPENDIX D 

SCOPING COMMENTS AND RESPONSES 

On June 15, 2010, the U.S. Nuclear Regulatory Commission (NRC) published a Notice of Intent 

to Prepare an Environmental Impact Statement and Conduct Scoping Process in the Federal 

Register (75 FR 33851) (TN511). The Notice of Intent notified the public of the staff’s intent to 

prepare an environmental impact statement (EIS) and conduct scoping for the applications for 

combined construction permits and operating licenses (COLs) received from Florida Power & 

Light Company (FPL) for two units, identified as Units 6 and 7, to be located at the Turkey Point 

site. The Turkey Point Nuclear Generating Station site is located approximately 4.5 mi east of 

Homestead Florida and approximately 25 mi south of the City of Miami, Florida. The NRC 

invited the applicant; Federal, Tribal, State, and local government agencies; local organizations; 

and individuals to participate in the scoping process by providing oral comments at the 

scheduled public meeting and/or submitting written suggestions and comments no later than 

August 16, 2010. 

D.1 Overview of the Scoping Process 

The scoping process provides an opportunity for public participants to identify issues to be 

addressed in the EIS and highlight public concerns and issues. The Notice of Intent identified 

the following objectives of the scoping process: 

 Define the proposed action that is to be the subject of the EIS. 

 Determine the scope of the EIS and identify significant issues to be analyzed in depth. 

 Identify and eliminate from detailed study those issues that are peripheral or that are not 

significant. 

 Identify any environmental assessments and other EISs that are being prepared or will be 

prepared that are related to, but not part of, the scope of the EIS being considered. 

 Identify other environmental review and consultation requirements related to the proposed 

action. 

 Identify parties consulting with the NRC under the National Historic Preservation Act, as set 

forth in Title 36 of the Code of Federal Regulations (CFR) 800.8(c)(1)(i) (TN513). 

 Indicate the relationship between the timing of the preparation of the environmental 

analyses and the Commission’s tentative planning and decision-making schedule. 

 Identify any cooperating agencies and, as appropriate, allocate assignments for preparation 

and schedules for completing the EIS to the NRC and any cooperating agencies. 

 Describe how the EIS will be prepared and include any contractor assistance to be used. 

Two public scoping meetings were held at the Homestead Young Men's Christian Association

facility located at 1034 Northeast 8th Street, Homestead, Florida, on July 15, 2010. 

Approximately 150 to 200 people attended each scoping meeting session. The scoping 
Appendix D 

NUREG–2176 D-2 October 2016 

meetings began with NRC staff members providing a brief overview of NRC’s review process for 

COL applications and the National Environmental Policy Act of 1969, as amended (NEPA) 

process (42 USC 4321 et seq.) (TN661). In addition, a representative of the U.S. Army Corps of 

Engineers (USACE) discussed the USACE regulatory role and authority and permitting 

decisions. After the NRC’s and USACE’s prepared statements, the meeting was opened for 

public comments. Forty six attendees provided either written statements or oral comments that 

were recorded and transcribed by a certified court reporter. In addition to the oral and written 

statements provided at the public scoping meetings, 10 letters and 32 emails were received 

during the scoping period. 

Transcripts for both the afternoon and evening scoping meetings can be found in the NRC 

Agencywide Documents Access and Management System (ADAMS) under accession numbers 

ML102150591 (NRC 2010-TN518) and ML102150597 (NRC 2010-TN519), respectively. 

ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html#webbased-adams (in the Public Electronic Reading Room; note: the URL is case-sensitive). 

Additional comments received later in letters or emails are also available. A meeting summary 

memorandum (ML102170529, NRC 2010-TN514) was issued August 31, 2010. 

At the conclusion of the scoping period, the NRC staff reviewed the scoping meeting transcripts 

and all written material received during the comment period and identified individual comments. 

These comments were organized according to topic within the proposed EIS or according to the 

general topic if they were outside the scope of the EIS. Once comments were grouped 

according to subject area, the staff determined the appropriate response for the comment. The 

staff made a determination on each comment that it was one of the following: 

 a comment that was actually a question and introduced no new information 

 a comment that was either related to support or opposition of combined licensing in general 

(or specifically the Turkey Point COL) or made a general statement about the COL process. 

In addition, it provided no new information and did not pertain to 10 CFR Part 52 (TN251). 

 a comment about an environmental issue that 

– provided new information that would require evaluation during the review 

– provided no new information. 

 a comment that was outside the scope of the COL, which included, but was not limited to 

– a comment about the safety record of the applicant. 

Preparation of the EIS has taken into account the relevant issues raised during the scoping 

process. The comments received on the draft EIS will be considered in the preparation of the 

final EIS. The final EIS, along with the staff’s Safety Evaluation Report (SER), will provide much 

of the basis for the NRC’s decision on whether to grant the Turkey Point COLs. 

The comments related to this environmental review are included in this appendix. They were 

extracted from the Turkey Point Nuclear Plant Combined License Scoping Summary Report 

(ML103130610 [NRC 2010-TN515] and ML103130612 [NRC 2010-TN516]) and are provided 

for the convenience of those interested specifically in the scoping comments applicable to this 
Appendix D 

October 2016 D-3 NUREG–2176 

environmental review. 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 operating plants 

 security and terrorism 

 support or opposition to the licensing action, licensing process, nuclear power, hearing 

process, or the applicant. 

More detail regarding the disposition of general or out-of-scope comments can be found in the 

Scoping Summary Report. To maintain consistency with the Scoping Summary Report, the 

comment source identification (ID) and comment number along with the name of the commenter 

used in that report are retained in this appendix. 

Table D-1 identifies, in alphabetical order, the individuals who provided comments during the 

scoping period, their affiliation (if given), and the ADAMS accession number that can be used to 

locate the correspondence. Although all commenters are listed, the comments presented in this 

appendix are limited to those within the scope of the environmental review. Table D-2 lists the 

comment categories in alphabetical order and commenter names and comment numbers for 

each category. Table D-3 lists the comment categories in the order they are presented in this 

appendix. The balance of this appendix presents the comments themselves with NRC staff 

responses organized by topic category. 

Table D-1. Individuals Providing Comments During the Scoping Comment Period 

Commenter Affiliation (if stated) 

Comment Source 

and ADAMS 

Accession # 

Correspondence 

ID 

Anonymous Letter (ML102100532) 0011 

Accursio, James Capri Restaurant, Inc. Meeting Transcript 

(ML102090730) 

0003-4 

Alexander, William Latin Chamber of Commerce Meeting Transcript 

(ML102150597) 

0002-10 

Amor, Valerie Meeting Transcript 

(ML102150591) 

0001-11 

Bass, Ken Email (ML102000006) 0005 

Burris, Jessica Email (ML102000003) 0007 

Cornick, Lance National Parks Conservation 

Association 

Meeting Transcript 

(ML102150591) 

0001-15 

Croom, Miles NOAA Email (ML102320025) 0033 

Daley, Dennis Self Meeting Transcript 

(ML102150591) 

0001-20 

De Villiers, Elena Self Letter (ML102370766) 0031 
Appendix D 

NUREG–2176 D-4 October 2016 

Table D-1. (contd) 

Commenter Affiliation (if stated) 

Comment Source 

and ADAMS 

Accession # 

Correspondence 

ID 

del Cid, Victor Self Meeting Transcript 

(ML102150597) 

0002-4 

Diggs, Bill Miami-Dade Chamber of 

Commerce 

Meeting Transcript 

(ML102150591) 

0001-17 

DiNuzzo, Laura Self Email (ML102310004) 0028 

Eney, Douglas Self Meeting Transcript 

(ML102150597) 

0002-17 

Espinosa, Carlos Department of Environmental 

Resources Management 

Letter (ML102370765) 0015 

Fessler, Greg Self Meeting Transcript 

(ML102150591) 

0001-28 

Finlan, Mary Great Homestead/Florida City 

Chamber of Commerce 

Meeting Transcript 

(ML102150597) 

0002-15 

Flinn, Eugene Village of Palmetto Bay Meeting Transcript 

(ML102150591) 

0001-22 

Garcia, Maria Self Meeting Transcript 

(ML102150591) 

0001-27 

Garcia, Preston Email (ML102000004) 0008 

Golden, James Self Letter (ML102370759) 0032 

Grosso, Richard Everglades Law Center Meeting Transcript 

(ML102150597) 

0002-6 

Guendelsberger, 

Debra 

Self Letter (ML102300037) 0029 

Gustave, Unito Board of County Commissioners, 

Miami-Dade County 

Meeting Transcript 

(ML102150591) 

0001-26 

Hamilton, Karen Self Email (ML102280577) 0019 

Hancock, Mandy Southern Alliance for Clean 

Energy 

Meeting Transcript 

(ML102150591) 

0001-14 

Hancock, Mandy Southern Alliance for Clean 

Energy 

Meeting Transcript 

(ML102150597) 

0002-18 

Harris, Walter South Miami Meeting Transcript 

(ML102150591) 

0001-2 

Harum-Alvarez, 

Albert 

Self Meeting Transcript 

(ML102150591) 

0001-24 

Hogsed, Daniel Email (ML102000002) 0009 

Horton, Richard Economic Development Council, 

South Miami-Dade 

Meeting Transcript 

(ML102150591) 

0001-25 

Jacobs, Jeanne Miami-Dade College Homestead Meeting Transcript 

(ML102150591) 

0001-4 

Johnson, Barry Greater Miami Chamber of 

Commerce 

Meeting Transcript 

(ML102150591) 

0001-5 
Appendix D 

October 2016 D-5 NUREG–2176 

Table D-1. (contd) 

Commenter Affiliation (if stated) 

Comment Source 

and ADAMS 

Accession # 

Correspondence 

ID 

Johnson, Michael Florida Carpenter's Regional 

Council 

Meeting Transcript 

(ML102150591) 

0001-8 

Kammerer, Laura Florida Division of Historical 

Resources 

Letter (ML102220345) 0013 

Kauffman, 

Kathleen 

Miami-Dade County Department of 

Planning and Zoning 

Email (ML102290548) 0026 

Kiley, Mike Turkey Point Meeting Transcript 

(ML102150591) 

0001-3 

Kiley, Mike Turkey Point Meeting Transcript 

(ML102150597) 

0002-5 

Kimball, Dan National Park Service Email (ML102290549) 0025 

Kipnis, Daniel Self Email (ML102320036) 0034 

LaFerrier, Marc Email (ML102290222) 0023 

Landeta, Hector Meeting Transcript 

(ML102150591) 

0001-18 

Lee, Nancy Email (ML102070008) 0010 

Lee, Nancy Urban Environment League Meeting Transcript 

(ML102150591) 

0001-12 

Lerner, Cindy Village of Pinecrest Meeting Transcript 

(ML102150591) 

0001-21 

Lewis, Mark National Park Service Email (ML102290549) 0025 

MacLaren, Kaitlin Tropical Audubon Society Meeting Transcript

(ML102150591) 

0001-7 

Marinelli, Francis J. Self Meeting Transcript 

(ML102150591) 

0001-10 

Martinelli, Tom Clean and Safe Energy Coalition Meeting Transcript 

(ML102150591) 

0001-9 

Martinelli, Tom Clean and Safe Energy Coalition Meeting Transcript 

(ML102150597) 

0002-9 

McHugh, John Self Meeting Transcript 

(ML102150597) 

0002-12 

Meerbott, Tim Cutler Bay Meeting Transcript 

(ML102150597) 

0002-2 

Miller, Lloyd Meeting Transcript 

(ML102150591) 

0001-6 

Moses, Dorothy Self Email (ML102300015) 0027 

Mueller, Heinz EPA Letter (ML102250207) 0014 

Mulkey, Cindy Self Email (ML102280580) 0020 

O'Katy, Jessica Self Meeting Transcript 

(ML102150597) 

0002-8 

Payne, Nkenga City of South Miami Letter (ML102160400) 0012 
Appendix D 

NUREG–2176 D-6 October 2016 

Table D-1. (contd) 

Commenter Affiliation (if stated) 

Comment Source 

and ADAMS 

Accession # 

Correspondence 

ID 

Poole, Mary Ann Florida Fish and Wildlife 

Conservation Commission 

Email (ML102280488) 0018 

Reynolds, Laura Self Email (ML102290221) 0022 

Roff, Rhonda Meeting Transcript 

(ML102150597) 

0002-11 

Ryan, Megan Self Meeting Transcript 

(ML102150591) 

0001-19 

Schwartz, Matthew Broward Group of the Sierra Club Meeting Transcript 

(ML102150597) 

0002-14 

Shlackman, Mara Self Meeting Transcript 

(ML102150597) 

0002-16 

Showen, Steve Citizens Alliance for Safe Energy Meeting Transcript 

(ML102150591) 

0001-16 

Simpson, Roce South Florida Building and 

Construction Trades and 

International Brotherhood of 

Electrical Workers, 

Meeting Transcript 

(ML102150597) 

0002-13 

Singer, Craig Email (ML102000005) 0004 

Smilan, Stan Self Meeting Transcript 

(ML102150591) 

0001-13 

Snelson, Richard Self Meeting Transcript 

(ML102150597) 

0002-7 

Sorenson, Katy Self Meeting Transcript 

(ML102150597) 

0002-1 

Troner, Susannah Self Email (ML102280487) 0017 

Vrooman, Paul Cutler Bay Meeting Transcript 

(ML102150591) 

0001-23 

Walker, Tom Florida Keys Aqueduct Authority Email (ML102290224) 0024 

Walker, Tom Florida Keys Aqueduct Authority Meeting Transcript 

(ML102150597) 

0002-3 

Wallace, Otis Florida City Meeting Transcript 

(ML102150591) 

0001-1 

Weins, Brian Email (ML102000007) 0006 

White, Barry Citizens Allied for Safe Energy, 

Inc. 

Email (ML102280490) 0016 

White, Barry Citizens Allied for Safe Energy, 

Inc. 

Meeting Transcript 

(ML102090730) 

0003-2 

Wilansky, Laura Self Email (ML102290220) 0021 

 
Appendix D 

October 2016 D-7 NUREG–2176 

Table D-2. Comment Categories with Associated Commenters and Comment IDs 

Comment 

Category Commenter (Comment ID) 

Accidents-Severe  Hancock, Mandy (0001-14-9) 

Alternatives-Energy  Amor, Valerie (0001-11-7) (0001-11-8) (0001-11-11) 

 Burris, Jessica (0007-7) 

 De Villiers, Elena (0031-6) 

 DiNuzzo, Laura (0028-3) (0028-4) (0028-6) 

 Finlan, Mary (0002-15-4) 

 Guendelsberger, Debra (0029-2) 

 Hancock, Mandy (0001-14-3) (0001-14-4) (0001-14-7) (0002-18-3)

 Harum-Alvarez, Albert (0001-24-4) 

 Hogsed, Daniel (0009-2) (0009-4) 

 Kiley, Mike (0001-3-3) 

 Lerner, Cindy (0001-21-5) 

 Mueller, Heinz (0014-16) 

 O'Katy, Jessica (0002-8-3) (0002-8-9) 

 Payne, Nkenga (0012-2) (0012-15) (0012-18) 

 Ryan, Megan (0001-19-4) 

 Schwartz, Matthew (0002-14-3) 

 Shlackman, Mara (0002-16-4) 

 Showen, Steve (0001-16-8) 

 Smilan, Stan (0001-13-8) 

 Sorenson, Katy (0002-1-4) 

 Troner, Susannah (0017-3) (0017-5) 

 Weins, Brian (0006-4) 

 White, Barry (0016-12) 

 Wilansky, Laura (0021-12) (0021-20) 

Alternatives-Sites  Cornick, Lance (0001-15-1) 

 Kimball, Dan (0025-1-6) (0025-1-7) (0025-1-8) (0025-1-9) (0025-1-10) 

 Lerner, Cindy (0001-21-6) 

 Lewis, Mark (0025-1-6) (0025-1-7) (0025-1-8) (0025-1-9) (0025-1-10) 

 Meerbott, Tim (0002-2-1) 

 Miller, Lloyd (0001-6-9) 

 Moses, Dorothy (0027-2) 

 Ryan, Megan (0001-19-3) 

 Sorenson, Katy (0002-1-1) 

Alternatives-System 

Design 

 Kimball, Dan (0025-2-12) (0025-3-22) (0025-3-47) 

 LaFerrier, Marc (0023-1-25) (0023-1-49) (0023-2-7) (0023-3-48) 

 Lewis, Mark (0025-2-12) (0025-3-22) (0025-3-47) 

 Poole, Mary Ann (0018-9) (0018-14) 
Appendix D 

NUREG–2176 D-8 October 2016 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID) 

Benefit-Cost 

Balance 

 De Villiers, Elena (0031-4) 

 Grosso, Richard (0002-6-8) 

 Hamilton, Karen (0019-8) (0019-11) 

 Hancock, Mandy (0001-14-2) 

 Harum-Alvarez, Albert (0001-24-1) (0001-24-3) 

 Payne, Nkenga (0012-14) 

 Reynolds, Laura (0022-2-10) (0022-3-16) 

 Ryan, Megan (0001-19-5) 

 Showen, Steve (0001-16-5) (0001-16-6) 

 Singer, Craig (0004-2) 

 Troner, Susannah (0017-1) 

 White, Barry (0003-2-2) (0016-7) 

 Wilansky, Laura (0021-15) (0021-18) 

Cumulative Impacts  Espinosa, Carlos (0015-5) 

 Golden, James (0032-28) 

 Hamilton, Karen (0019-3) 

 Harris, Walter (0001-2-3) 

 Kimball, Dan (0025-1-12) (0025-1-15) (0025-2-13) 

 Kipnis, Daniel (0034-1) (0034-2) (0034-3) (0034-4) (0034-5) 

 LaFerrier, Marc (0023-1-10) 

 Lerner, Cindy (0001-21-3) 

 Lewis, Mark (0025-1-12) (0025-1-15) (0025-2-13) 

 MacLaren, Kaitlin (0001-7-1) (0001-7-2) (0001-7-4) (0001-7-8) 

(0001-7-9) 

 Miller, Lloyd (0001-6-5) 

 Mueller, Heinz (0014-7) (0014-14) 

 Payne, Nkenga (0012-6) (0012-9) 

 Reynolds, Laura (0022-1-9) (0022-2-17) (0022-4-17) 

 Shlackman, Mara (0002-16-1) (0002-16-2) 

 Sorenson, Katy (0002-1-2) 

 White, Barry (0016-5) (0016-6) (0016-14) 

 Wilansky, Laura (0021-4) 

Decommissioning  Reynolds, Laura (0022-4-14) 

 Wilansky, Laura (0021-6) 

Ecology-Aquatic  Amor, Valerie (0001-11-10) 

 Croom, Miles (0033-1) (0033-2) (0033-3) (0033-4) (0033-7) (0033-9) 

(0033-10) 

 Golden, James (0032-9) 

 Grosso, Richard (0002-6-7) 

 Kimball, Dan (0025-1-11) (0025-1-14) (0025-3-17) (0025-3-18) 

(0025-3-19) (0025-3-29) (0025-3-30) 

 LaFerrier, Marc (0023-1-18) (0023-1-36) (0023-1-64) (0023-2-14) 

(0023-2-15) 
Appendix D 

October 2016 D-9 NUREG–2176 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID) 

 Lewis, Mark (0025-1-11) (0025-1-14) (0025-3-17) (0025-3-18) 

(0025-3-19) (0025-3-29) (0025-3-30) 

 Mulkey, Cindy (0020-2) 

 Poole, Mary Ann (0018-2) (0018-4) (0018-6) (0018-8) (0018-10) 

 Reynolds, Laura (0022-2-6) (0022-2-7) (0022-3-1) (0022-3-18) 

(0022-3-21) 

Ecology-Terrestrial  Amor, Valerie (0001-11-3) 

 Burris, Jessica (0007-1) (0007-3) 

 Croom, Miles (0033-11) 

 Espinosa, Carlos (0015-3) (0015-4) 

 Garcia, Preston (0008-2) 

 Golden, James (0032-12) (0032-14) (0032-16) (0032-17) (0032-19) 

(0032-25) (0032-27) (0032-35) (0032-36) 

 Grosso, Richard (0002-6-5) 

 Kimball, Dan (0025-2-6) (0025-2-11) (0025-2-18) (0025-3-31) 

(0025-3-32) (0025-3-33) (0025-3-34) (0025-3-43) 

 LaFerrier, Marc (0023-1-17) (0023-1-19) (0023-1-22) (0023-1-46) 

(0023-1-50) (0023-1-62) (0023-1-63) (0023-1-71) (0023-2-5) (0023-2-8) 

(0023-2-9) (0023-2-10) (0023-2-11) (0023-2-12) (0023-2-13) (0023-2-16) 

(0023-2-17) (0023-2-30) (0023-2-31) (0023-2-32) (0023-3-18) 

(0023-3-22) (0023-3-23) (0023-3-24) (0023-3-25) (0023-3-51) 

(0023-3-53) (0023-3-69) (0023-4-5) (0023-4-9) (0023-4-14) (0023-4-15) 

(0023-4-16) (0023-4-18) (0023-4-20) 

 Lewis, Mark (0025-2-6) (0025-2-11) (0025-2-18) (0025-3-31) 

(0025-3-32) (0025-3-33) (0025-3-34) (0025-3-43) 

 MacLaren, Kaitlin (0001-7-3) 

 Miller, Lloyd (0001-6-4) 

 Mueller, Heinz (0014-10) (0014-15) (0014-17) (0014-18) 

 Payne, Nkenga (0012-7) 

 Poole, Mary Ann (0018-3) (0018-5) (0018-16) 

 Reynolds, Laura (0022-1-16) (0022-1-17) (0022-1-19) (0022-2-3) 

(0022-2-21) 

 Schwartz, Matthew (0002-14-10) 

 Simpson, Roce (0002-13-7) 

Geology  Reynolds, Laura (0022-1-14) 

HealthNonradiological 

 Burris, Jessica (0007-4) 

 De Villiers, Elena (0031-3) 

 Hamilton, Karen (0019-6) 

 Kimball, Dan (0025-3-28) 

 LaFerrier, Marc (0023-1-11) (0023-3-35) 

 Lewis, Mark (0025-3-28) 

 O'Katy, Jessica (0002-8-6) 

 Reynolds, Laura (0022-1-15) (0022-1-18) (0022-1-20) (0022-2-2)

 Schwartz, Matthew (0002-14-7) 
Appendix D 

NUREG–2176 D-10 October 2016 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID) 

 White, Barry (0003-2-1) (0016-3) 

Health-Radiological  , Anonymous (0011-1) 

 Burris, Jessica (0007-5) 

 O'Katy, Jessica (0002-8-8) 

 Payne, Nkenga (0012-8) 

 Reynolds, Laura (0022-4-8) (0022-4-10) (0022-4-11) (0022-4-12) 

(0022-4-15) 

 Showen, Steve (0001-16-3) (0001-16-4) 

 Smilan, Stan (0001-13-6) 

 Walker, Tom (0002-3-7) (0024-4) 

 Wilansky, Laura (0021-9) (0021-14) (0021-19) 

Historic and Cultural 

Resources 

 Kammerer, Laura (0013-1) 

 Kauffman, Kathleen (0026-1) (0026-2) 

 Kimball, Dan (0025-3-41) 

 LaFerrier, Marc (0023-2-1) (0023-3-32) (0023-3-33) 

 Lewis, Mark (0025-3-41) 

HydrologyGroundwater 

 Croom, Miles (0033-5) (0033-6) (0033-8) 

 De Villiers, Elena (0031-7) 

 DiNuzzo, Laura (0028-2) 

 Espinosa, Carlos (0015-2) 

 Golden, James (0032-7) (0032-8) (0032-11) (0032-29) (0032-30) 

(0032-31) (0032-32) 

 Grosso, Richard (0002-6-9) 

 Kimball, Dan (0025-1-4) (0025-1-5) (0025-1-13) (0025-2-1) (0025-3-1) 

(0025-3-2) (0025-3-3) (0025-3-4) (0025-3-5) (0025-3-6) (0025-3-7) 

(0025-3-8) (0025-3-9) (0025-3-10) (0025-3-11) (0025-3-12) (0025-3-13) 

(0025-3-14) (0025-3-16) (0025-3-21) 

 LaFerrier, Marc (0023-1-1) (0023-1-2) (0023-1-3) (0023-1-4) (0023-1-7) 

(0023-1-9) (0023-1-14) (0023-1-15) (0023-1-29) (0023-1-31) (0023-1-32) 

(0023-1-33) (0023-1-34) (0023-1-35) (0023-1-37) (0023-1-38) 

(0023-1-39) (0023-1-40) (0023-1-41) (0023-1-42) (0023-1-44) 

(0023-1-47) (0023-1-66) (0023-1-67) (0023-1-68) (0023-1-70) 

(0023-3-13) (0023-3-38) (0023-3-40) (0023-3-47) (0023-4-10) 

 Lerner, Cindy (0001-21-2) 

 Lewis, Mark (0025-1-4) (0025-1-5) (0025-1-13) (0025-2-1) (0025-3-1) 

(0025-3-2) (0025-3-3) (0025-3-4) (0025-3-5) (0025-3-6) (0025-3-7) 

(0025-3-8) (0025-3-9) (0025-3-10) (0025-3-11) (0025-3-12) (0025-3-13) 

(0025-3-14) (0025-3-16) (0025-3-21) 

 MacLaren, Kaitlin (0001-7-10) 

 McHugh, John (0002-12-1) (0002-12-6) (0002-12-9) (0002-12-10) 

 Miller, Lloyd (0001-6-3) (0001-6-6) 

 Moses, Dorothy (0027-6) (0027-7) 

 Mueller, Heinz (0014-5) (0014-6) 

 Mulkey, Cindy (0020-1) 
Appendix D 

October 2016 D-11 NUREG–2176 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID) 

 O'Katy, Jessica (0002-8-4) 

 Poole, Mary Ann (0018-1) 

 Reynolds, Laura (0022-1-1) (0022-1-21) (0022-2-8) (0022-2-9) 

(0022-2-13) (0022-2-20) (0022-3-2) (0022-3-3) (0022-3-8) (0022-3-9) 

(0022-4-6) (0022-4-7) 

 Walker, Tom (0002-3-1) (0002-3-2) (0002-3-3) (0002-3-5) (0024-1) 

(0024-2) (0024-3) (0024-5) (0024-6) 

 White, Barry (0016-8) 

Hydrology-Surface 

Water 

 Burris, Jessica (0007-6) 

 Cornick, Lance (0001-15-2) (0001-15-3) 

 Croom, Miles (0033-12) (0033-13) 

 Eney, Douglas (0002-17-6) 

 Espinosa, Carlos (0015-6) 

 Golden, James (0032-2) (0032-3) (0032-4) (0032-5) (0032-6) (0032-10) 

(0032-13) (0032-23) (0032-26) (0032-34) 

 Grosso, Richard (0002-6-1) (0002-6-2) 

 Hancock, Mandy (0001-14-6) 

 Kimball, Dan (0025-2-4) (0025-2-15) (0025-2-17) (0025-3-15) 

(0025-3-35) (0025-3-36) 

 LaFerrier, Marc (0023-1-13) (0023-1-48) (0023-2-20) (0023-3-26) 

(0023-3-27) (0023-3-39) (0023-3-43) (0023-3-59) (0023-3-60) (0023-4-1) 

(0023-4-11) 

 Lewis, Mark (0025-2-4) (0025-2-15) (0025-2-17) (0025-3-15) 

(0025-3-35) (0025-3-36) 

 McHugh, John (0002-12-4) 

 Meerbott, Tim (0002-2-3) 

 Moses, Dorothy (0027-5) 

 O'Katy, Jessica (0002-8-5) 

 Payne, Nkenga (0012-10) 

 Poole, Mary Ann (0018-7) (0018-11) (0018-12) 

 Reynolds, Laura (0022-1-4) (0022-1-8) (0022-2-19) 

 Ryan, Megan (0001-19-2) 

 Schwartz, Matthew (0002-14-14) 

 Walker, Tom (0002-3-4) (0002-3-6) 

 White, Barry (0016-9) (0016-11) 

Land Use-Site and 

Vicinity 

 Burris, Jessica (0007-2) 

 Golden, James (0032-21) (0032-24) (0032-33) (0032-37) (0032-38) 

 Gustave, Unito (0001-26-3) 

 Hamilton, Karen (0019-4) (0019-12) (0019-13) 

 Kimball, Dan (0025-3-27) 

 LaFerrier, Marc (0023-1-30) (0023-3-2) (0023-3-54) 

 Lewis, Mark (0025-3-27) 

 Miller, Lloyd (0001-6-7) 

 Moses, Dorothy (0027-3) 
Appendix D 

NUREG–2176 D-12 October 2016 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID) 

 Mueller, Heinz (0014-12) 

Land UseTransmission Lines 

 Cornick, Lance (0001-15-4) 

 De Villiers, Elena (0031-2) 

 Flinn, Eugene (0001-22-1) (0001-22-2) (0001-22-3) (0001-22-4) 

 Garcia, Preston (0008-3) 

 Golden, James (0032-22) 

 Hamilton, Karen (0019-5) (0019-7) (0019-9) (0019-10) 

 Harum-Alvarez, Albert (0001-24-6) 

 Horton, Richard (0001-25-5) 

 Kimball, Dan (0025-2-5) (0025-2-7) (0025-2-8) (0025-2-9) (0025-2-10) 

(0025-3-37) 

 LaFerrier, Marc (0023-3-19) (0023-3-20) (0023-3-31) (0023-3-37) 

(0023-3-52) (0023-3-62) (0023-3-63) 

 Lerner, Cindy (0001-21-1) (0001-21-4) 

 Lewis, Mark (0025-2-5) (0025-2-7) (0025-2-8) (0025-2-9) (0025-2-10) 

(0025-3-37) 

 MacLaren, Kaitlin (0001-7-5) 

 Meerbott, Tim (0002-2-2) 

 Miller, Lloyd (0001-6-8) 

 Reynolds, Laura (0022-1-6) (0022-1-7) (0022-4-5) 

 Schwartz, Matthew (0002-14-9) 

 Sorenson, Katy (0002-1-5) 

 Vrooman, Paul (0001-23-1) (0001-23-2) (0001-23-3) 

 Wallace, Otis (0001-1-3) 

Meteorology and Air 

Quality 

 Kimball, Dan (0025-2-3) (0025-3-25) (0025-3-45) 

 LaFerrier, Marc (0023-1-16) (0023-1-26) (0023-1-28) (0023-3-16) 

(0023-4-7) (0023-4-8) 

 Lewis, Mark (0025-2-3) (0025-3-25) (0025-3-45) 

 MacLaren, Kaitlin (0001-7-7) 

 Mueller, Heinz (0014-21) 

 Reynolds, Laura (0022-2-1) (0022-2-16) (0022-2-18) (0022-4-2) 

(0022-4-3) (0022-4-4) 

 White, Barry (0016-2) 

 Wilansky, Laura (0021-11) 

Need for Power  Eney, Douglas (0002-17-2) 

 Hancock, Mandy (0001-14-5) 

 Horton, Richard (0001-25-2) 

 Johnson, Barry (0001-5-2) 

 Martinelli, Tom (0001-9-3) 

 O'Katy, Jessica (0002-8-1) 

 Reynolds, Laura (0022-1-5) (0022-3-4) (0022-3-5) (0022-3-6) 

(0022-4-24) 

 Schwartz, Matthew (0002-14-1) (0002-14-2) 
Appendix D 

October 2016 D-13 NUREG–2176 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID) 

 Snelson, Richard (0002-7-2) 

 Weins, Brian (0006-5) 

 Wilansky, Laura (0021-3) 

Nonradiological 

Waste 

 LaFerrier, Marc (0023-1-8) (0023-1-60) 

Process-ESP-COL  Kimball, Dan (0025-1-2) (0025-3-20) 

 LaFerrier, Marc (0023-1-59) (0023-3-42) (0023-3-50) (0023-3-64) 

(0023-3-66) (0023-4-21) 

 Lee, Nancy (0001-12-1) 

 Lewis, Mark (0025-1-2) (0025-3-20) 

 Miller, Lloyd (0001-6-10) 

 Mueller, Heinz (0014-3) (0014-4) 

 Ryan, Megan (0001-19-10) 

 Singer, Craig (0004-3) 

Process-NEPA  Kimball, Dan (0025-2-19) 

 Lewis, Mark (0025-2-19) 

Related Federal 

Projects 

 Golden, James (0032-1) (0032-15) (0032-18) (0032-20) 

 Grosso, Richard (0002-6-4) 

 Kimball, Dan (0025-1-1) (0025-2-14) (0025-2-16) (0025-3-42) 

(0025-3-44) 

 LaFerrier, Marc (0023-1-51) (0023-3-3) (0023-3-7) (0023-3-8) (0023-3-9) 

(0023-3-10) (0023-3-11) (0023-3-12) (0023-3-15) (0023-3-17) 

(0023-3-21) (0023-3-28) (0023-3-45) (0023-3-46) 

 Lewis, Mark (0025-1-1) (0025-2-14) (0025-2-16) (0025-3-42) 

(0025-3-44) 

 MacLaren, Kaitlin (0001-7-6) 

 Reynolds, Laura (0022-1-13) 

Site Layout and 

Design 

 Amor, Valerie (0001-11-4) 

 Kimball, Dan (0025-1-3) (0025-3-24) (0025-3-26) 

 LaFerrier, Marc (0023-1-20) (0023-1-21) (0023-1-23) (0023-1-24) 

(0023-1-27) (0023-1-43) (0023-1-52) (0023-1-54) (0023-1-55) 

(0023-1-56) (0023-1-61) (0023-1-65) (0023-1-69) (0023-2-6) (0023-2-18) 

(0023-2-19) (0023-2-21) (0023-2-22) (0023-2-33) (0023-2-34) 

(0023-2-35) (0023-2-36) (0023-2-37) (0023-2-38) (0023-2-39) 

(0023-2-40) (0023-2-41) (0023-3-4) (0023-3-5) (0023-3-6) (0023-3-14) 

(0023-3-29) (0023-3-30) (0023-3-41) (0023-3-44) (0023-3-57) 

(0023-3-65) (0023-3-67) (0023-4-2) (0023-4-3) (0023-4-6) (0023-4-12) 

(0023-4-13) (0023-4-19) 

 Lewis, Mark (0025-1-3) (0025-3-24) (0025-3-26) 

 Mueller, Heinz (0014-8) (0014-20) 

 Poole, Mary Ann (0018-13) (0018-15) 

 Reynolds, Laura (0022-2-4) (0022-2-5) (0022-2-11) (0022-2-12) 

(0022-2-14) (0022-2-15) (0022-3-7) (0022-3-10) (0022-3-11) (0022-3-12) 
Appendix D 

NUREG–2176 D-14 October 2016 

Table D-2. (contd) 

Comment 

Category Commenter (Comment ID) 

(0022-3-13) (0022-3-14) (0022-3-17) (0022-3-20) (0022-4-1) 

Socioeconomics  Accursio, James (0003-4-4) (0003-4-5) 

 Alexander, William (0002-10-1) (0002-10-3) (0002-10-4) 

 Daley, Dennis (0001-20-5) 

 Diggs, Bill (0001-17-1) (0001-17-2) 

 Grosso, Richard (0002-6-3) 

 Hamilton, Karen (0019-1) (0019-2) 

 Harum-Alvarez, Albert (0001-24-5) 

 Jacobs, Jeanne (0001-4-2) 

 Johnson, Barry (0001-5-3) (0001-5-4) 

 Johnson, Michael (0001-8-3) 

 Kiley, Mike (0001-3-1) (0002-5-4) 

 Kimball, Dan (0025-3-38) (0025-3-39) (0025-3-40) (0025-3-46) 

 LaFerrier, Marc (0023-1-53) (0023-2-2) (0023-2-3) (0023-2-4) 

(0023-2-23) (0023-2-24) (0023-2-25) (0023-2-26) (0023-2-27) 

(0023-2-28) (0023-2-29) (0023-3-1) (0023-3-34) (0023-3-36) 

 Landeta, Hector (0001-18-2) (0001-18-3) (0001-18-5) 

 Lerner, Cindy (0001-21-7) 

 Lewis, Mark (0025-3-38) (0025-3-39) (0025-3-40) (0025-3-46) 

 Marinelli, Francis J. (0001-10-2) 

 Martinelli, Tom (0001-9-2) (0002-9-3) 

 McHugh, John (0002-12-5) 

 Reynolds, Laura (0022-4-16) 

 Ryan, Megan (0001-19-7) (0001-19-8) 

 Schwartz, Matthew (0002-14-4) 

 Shlackman, Mara (0002-16-3) 

 Simpson, Roce (0002-13-3) (0002-13-4) (0002-13-5) 

 Snelson, Richard (0002-7-3) (0002-7-4) 

 Wallace, Otis (0001-1-5) 

Uranium Fuel Cycle  Amor, Valerie (0001-11-5) 

 Bass, Ken (0005-2) 

 DiNuzzo, Laura (0028-5) 

 Guendelsberger, Debra (0029-3) 

 Hancock, Mandy (0001-14-8) 

 Harris, Walter (0001-2-4) 

 Marinelli, Francis J. (0001-10-1) 

 O'Katy, Jessica (0002-8-2) (0002-8-7) 

 Payne, Nkenga (0012-13) 

 Reynolds, Laura (0022-4-13) 

 Schwartz, Matthew (0002-14-8) (0002-14-13) 

 Shlackman, Mara (0002-16-5) 

 Weins, Brian (0006-2) 

 Wilansky, Laura (0021-10) (0021-21) 
Appendix D 

October 2016 D-15 NUREG–2176 

Table D-3. Comment Categories in Order as Presented in this Report 

D.1.1 Comments Concerning Process – COL 

D.1.2 Comments Concerning Process – NEPA 

D.1.3 Comments Concerning Site Layout and Design 

D.1.4 Comments Concerning Land Use – Site and Vicinity 

D.1.5 Comments Concerning Land Use – Transmission Lines 

D.1.6 Comments Concerning Geology 

D.1.7 Comments Concerning Hydrology – Surface Water 

D.1.8 Comments Concerning Hydrology – Groundwater 

D.1.9 Comments Concerning Ecology – Terrestrial 

D.1.10 Comments Concerning Ecology – Aquatic 

D.1.11 Comments Concerning Socioeconomics 

D.1.12 Comments Concerning Historic and Cultural Resources 

D.1.13 Comments Concerning Meteorology and Air Quality 

D.1.14 Comments Concerning Health – Nonradiological 

D.1.15 Comments Concerning Health – Radiological 

D.1.16 Comments Concerning Nonradiological Waste 

D.1.17 Comments Concerning Accidents – Severe 

D.1.18 Comments Concerning the Uranium Fuel Cycle 

D.1.19 Comments Concerning Decommissioning 

D.1.20 Comments Concerning Related Federal Projects 

D.1.21 Comments Concerning Cumulative Impacts 

D.1.22 Comments Concerning the Need for Power 

D.1.23 Comments Concerning Alternatives – Energy 

D.1.24 Comments Concerning Alternatives – System Design 

D.1.25 Comments Concerning Alternatives – Sites 

D.1.26 Comments Concerning Benefit-Cost Balance 

D.1.1 Comments Concerning Process – COL 

Comment: Having these meetings out in one corner of the County is not fair to the rest of the 

County because this affects the entire County. All our commissioners vote on this and yet, you'll 

have it in one commission district. It's all our Bay. The water which you are going to bring in to 

cool the plants is all our water. The power lines are going throughout all our neighborhoods. 

This is not just a Homestead issue; it's not a local issue; it's a Countywide issue. And I would 

say it's a regional issue because I think Monroe County should be part of the plan, too. I think 

there should be meetings held all over the County. The scoping meeting out to Homestead, I 

had to drive an hour-and-a-half to get here and I'm just on the other side of the County. So the 

Urban Environment League calls for scoping meetings throughout the County because this 

empty room should tell you something. (0001-12-1 [Lee, Nancy])

Response: Public meetings are generally held in the community located geographically closest 

to the proposed project location. Interested parties that are unable to attend the public meetings 

in person are also afforded the opportunity to submit written comments. This comment 

expresses opposition to the NRC's scoping process, but provides no specific information on the 
Appendix D 

NUREG–2176 D-16 October 2016 

NRC's environmental review of the Turkey Point Units 6 and 7 COL application. Therefore, this 

comment will not be addressed in the environmental impact statement (EIS). 

Comment: I just want to make is that I that I think we should be evaluating environmental 

impacts and safety on the same plane and not rank safety above environmental. Because if 

you neglect the environmental impacts of building these reactors, you are putting the safety of 

my generation and the future generation at risk. (0001-19-10 [Ryan, Megan])

Comment: I have little faith in what might happen here. As you have heard, they have never 

and can't find any instance in which they have refused a nuclear power plant. They've always 

managed to find ways to accommodate it. (0001-6-10 [Miller, Lloyd])

Response: The NRC takes seriously its responsibility under the Atomic Energy Act to protect 

the health and safety of the public and the environment in regulating the U.S. nuclear power 

industry. More information about NRCs roles and responsibilities is available on the NRCs 

website at http://www.nrc.gov/about-nrc.html. NRC approval of an application for a COL is not a 

foregone conclusion. Environmental issues, as well as safety issues, will be evaluated before a 

decision on an application is reached. As described in the regulations, the NRC can deny an 

application based on the finding of its review. 

Comment: In my opinion there should be one universal standard design, agreed upon by a 

panel of experts, and built to exacting standards so it becomes cheaper and less time 

consuming. (0004-3 [Singer, Craig])

Response: This comment did not provide information related to the environmental effects of 

the proposed action and will not be addressed in the EIS. 

Comment: The Draft EIS should discuss the status and any issues/concerns associated with 

the following approvals: Approval of the application to the NRC for a COL; Approval of the 

application to the State of Florida for site certification; Approval of any required National 

Pollutant Discharge Elimination Permit(s) (NPDES) for water discharge; Approval of the 

Prevention of Significant Deterioration (PSD) air permit; Approval of a 316(b) demonstration for 

the proposed cooling water intake; Approval of the U.S. Army Corps of Engineers (USACE) 

Section 404 and Section 10 permits to construct structures in wetlands and regulated 

waterways; Approval of hazardous waste management and disposal plans; Approval of the 

"determination of consistency" under the requirements of the Coastal Zone Management Act to 

ensure the expanded plant is consistent with existing federal and state coastal zone 

management plans. (0014-4 [Mueller, Heinz])

Comment: Four (4) sixty thousand gallon above ground diesel fuel tanks, four (4) 1300 gallon 

diesel generator day tank, and two (2) diesel driven fire pumps are mentioned. No details and 

specification were provided to establish compliance with Chapter 24 and FAC 62-762 or obtain 

the necessary approval of the Director of DERM or his designee. (0023-1-59 [LaFerrier, Marc])

Comment: The expiration date on the copies of USFWS permits No. MB697722-0, 

MB697722-1 and MB1335540-0, included in Appendix 10.2.10 indicate that these permits 
Appendix D 

October 2016 D-17 NUREG–2176 

expired on March 31, 2009. The applicant shall provide copies of the current permits. 

(0023-3-64 [LaFerrier, Marc])

Comment: In Section 5.12, the application states that No variances from applicable regulatory 

standards are being sought for construction of the Project. In Section 4.5.5, however, the 

application states that a variance is needed. (0023-3-66 [LaFerrier, Marc])

Comment: The application states that FPL will prepare and submit an earthwork and materials 

disposal plan prior to the start of construction. (0023-4-21 [LaFerrier, Marc])

Comment: The COL application proposes the discharge of cooling tower blowdown from 

Units 6&7 to underground injection wells within the Boulder Zone of the Lower Floridan Aquifer. 

FPL makes the assumption that a Class I Underground Injection Control permit will be issued by 

FDEP. However, a FDEP permit has not been acquired for this action, to date. 

(0025-3-20 [Kimball, Dan] [Lewis, Mark])

Response: An appendix of the EIS will contain a list of environmental-related authorizations, 

permits, and certifications potentially required by FPL from Federal, State, regional, local, and 

affected Native American Tribal agencies related to the COLs for proposed Turkey Point Units 6 

and 7. 

Comment: DERM has determined that the proposed work or activity may result in adverse 

environmental impacts as defined in Section 24-5 of the Code of Miami-Dade County. The 

application does not contain sufficient information to evaluate the project's environmental 

impacts, benefits, and detriments with regard to assessment points numbers 1 thru 6 as 

defined in Section 24-5 of the Code of Miami-Dade County under Comprehensive 

Environmental Impact Statement. (0023-3-42 [LaFerrier, Marc])

Response: This comment refers specifically to the Site Certification Application (SCA) 

submitted to the State of Florida by FPL, but it indicates an interest in the potential impacts of 

the proposed plant on the environment. The potential impacts of building and operating the 

proposed plant on the environment will be addressed in Chapters 4, 5, and 7 of the EIS, based 

on the affected environment described in Chapter 2. 

Comment: Please clarify mitigation success criteria for the proposed mitigation plans. What 

are the projected goals? What will constitute success? Please include details of the routine 

monitoring and maintenance plans designed to achieve planned success levels that are 

required in order to evaluate the adequacy of the proposed mitigation. 

(0023-3-50 [LaFerrier, Marc])

Response: This comment refers to the SCA submitted to the State of Florida by FPL, but it 

indicates an interest in mitigation of the impacts of proposed Turkey Point Units 6 and 7 on 

wetlands. The potential impacts of building and operating the proposed plant on wetlands and 

potential mitigation of those impacts will be discussed in Chapters 4 and 5 of the EIS, based on 

the affected environment that will be described in Chapter 2. A wetland mitigation plan is 

included in the Clean Water Act (CWA) Section 404 permit application submitted to the 

U.S. Army Corps of Engineers (USACE or Corps). Monitoring plans during building and 

operating the proposed plant will be presented in Chapters 4 and 5. 
Appendix D 

NUREG–2176 D-18 October 2016 

Comment: The Draft EIS should discuss any plans by the applicant to seek a Limited Work 

Authorization (LWA). On similar projects an LWA was sought prior to certain environmental 

permits being obtained. EPA understands that an LWA could potentially authorize site 

development and deep/shallow foundation construction. (0014-3 [Mueller, Heinz])

Comment: The parks encourage the NRC to carefully analyze the activities which would be 

permitted as Preconstruction Activities and/or Limited Work Authorization Construction. This 

project is located in a highly sensitive, wetlands coastal environment, immediately adjacent to a 

national park, and components of the COL are proposed to run through or adjacent to a second 

national park. This permit evaluation will examine the environmental impacts of roads, bridges, 

facility location, transmission lines, cooling water pipelines (radial collector wells), and other 

issues. Although these non-safety related components may frequently be allowed as 

Preconstruction Activities and/or Limited Work Authorization Construction, the parks believe 

many of these activities present the potential for cumulative impacts to this sensitive 

ecosystem and require a greater amount of environmental review than the LW A process 

provides. (0025-1-2 [Kimball, Dan] [Lewis, Mark])

Response: Cumulative impacts are the impacts that result from the combination of the 

proposed action and past, present, and reasonably foreseeable actions, regardless of who 

takes the actions. The cumulative impacts associated with building and operating proposed 

Units 6 and 7, including those actions identified as preconstruction, will be evaluated for each 

affected resource. The results of cumulative impact analyses will be presented in Chapter 7 of 

the EIS. FPL withdrew its request for a limited work authorization (LWA) in a letter to the NRC 

dated November 10, 2009. 

D.1.2 Comments Concerning Process – NEPA 

Comment: NPS urges a comprehensive evaluation, additional documentation, and 

consultation with respect to potential impacts of the Turkey Point 6 & 7 Project and other power 

plant and transmission corridor site alternatives. NPS concerns should be addressed in the EIS 

process in order to avoid and minimize potential adverse impacts to the resources and values of 

Biscayne and Everglades National Parks and conflicts with CERP goals and projects. 

(0025-2-19 [Kimball, Dan] [Lewis, Mark])

Response: The potential impacts of building and operating the proposed units at the 

alternative sites will be discussed in Chapter 9 of the EIS. The alternative sites will be 

compared against the proposed site to determine whether any of the alternative sites are 

environmentally preferable to the proposed site. The environmental impacts of building and 

operating the proposed transmissions lines will be addressed in Chapters 4, 5 and 7. 

Alternative transmission corridors would not typically be considered within the context of an 

NRC EIS for a proposed nuclear power plant. However, the Corps of Engineers, and perhaps 

the National Park Service, will be cooperating with the NRC on the EIS. To the extent that a 

cooperating agency addresses such alternatives for its NEPA analysis, those alternatives would 

likely be included in this EIS in order to support the cooperating agency’s environmental review. 
Appendix D 

October 2016 D-19 NUREG–2176 

D.1.3 Comments Concerning Site Layout and Design 

Comment: We also know through many studies by scientists that the sea level waters are 

rising and that I have been told through a presentation through an environmental group that I'm 

a part of and on committees with different towns -- I'm on a lot of different groups -- that they're 

going to raise their plant, I thought it was 28 feet; Lloyd said 24. The reality is they know that it's 

a problem. (0001-11-4 [Amor, Valerie])

Comment: Please publish a map showing new and existing canals, pipelines, STAs, pump 

locations, and pump capacities associated with the water management feature(s). 

(0022-3-10 [Reynolds, Laura])

Comment: Please state the specific material that will be used to line the water management 

feature(s) and state the minimum thickness of the lining. (0022-3-11 [Reynolds, Laura])

Comment: Please state whether the lining of the water management feature(s) will be 

impervious to the flow of groundwater. (0022-3-12 [Reynolds, Laura])

Comment: Please state how the lining of the water management feature(s) will be stabilized 

knowing that groundwater continually flows through the Biscayne Aquifer. 

(0022-3-13 [Reynolds, Laura])

Comment: Please state the number of times the water management feature(s) can be drained 

and refilled while retaining its structural integrity. (0022-3-14 [Reynolds, Laura])

Comment: Please state how long the applicant plans to own and operate the water 

management feature(s). (0022-3-17 [Reynolds, Laura])

Comment: Please state the dimensions, capacities, and location(s) of the water management 

feature(s) resulting from excavations of the FPL-Owned fill source (rockmines). 

(0022-3-7 [Reynolds, Laura])

Comment: Provide a process flow with description of the proposed FPL reclaim treatment plant 

& plant effluent. (0023-1-27 [LaFerrier, Marc])

Comment: [P]lease provide a detailed map of all FPL land holdings within the Biscayne 

Coastal Wetlands and Model Lands Basins. Please identify on the map which areas are 

proposed for development and which are proposed for mitigation. (0023-4-3 [LaFerrier, Marc])

Comment: If the water reservoir for Units 6&7 is unlined, the seepage of wastewater 

constituents, including EPOCs, will occur to the Biscayne Aquifer and cause uptake to adjacent 

wetlands; migration of these contaminants will be transported subsequently to the bay. The 

ecological impacts associated with an unlined reservoir should be evaluated. 

(0025-3-26 [Kimball, Dan] [Lewis, Mark])

Response: A description of the FPL site layout, the reactor type, and the cooling-water 

systems for proposed Turkey Point Units 6 and 7 will be provided in Chapter 3 of the EIS. 

Offsite features associated with the proposed units will also be described in Chapter 3. 
Appendix D 

NUREG–2176 D-20 October 2016 

Comment: Please provide plans for the handling and disposal of the spoils generated from 

demucking of the Units 6 & 7 site. (0023-1-20 [LaFerrier, Marc])

Comment: Please submit evaluation criteria for non-acceptable vs. acceptable material that 

would be used for common or structural backfill and demonstrate how the criteria for material 

that would be used for common or structural backfill meet the clean fill requirements of 

Section 24-48, Miami-Dade Code. (0023-1-21 [LaFerrier, Marc])

Comment: Please identify temporary vs. permanent impacts expected to result from the 

proposed work within the barge unloading area, and provide a detailed description of these 

impacts. (0023-1-23 [LaFerrier, Marc])

Comment: The application did not provide sufficient information to fully evaluate work 

proposed in the barge area. Please submit detailed plans, including but not limited to applicable 

site surveys, site plan and cross sectional views with mean high water and mean low water 

lines, existing depth and proposed resulting depth of the turning basin, details of any proposed 

alteration of the existing shoreline inclusive of complete designs for creating any vessel notches 

or bays, as well as detailed stabilization methodology for any portion of the shoreline that is to 

be modified as a result of the proposed expansion of the Barge Turning Basin. 

(0023-1-24 [LaFerrier, Marc])

Comment: [I]nclude sufficient information for the radial collection wells, specifically the spacing 

between the well screen laterals and the maximum distance that the well screen laterals will 

extend under Biscayne Bay. Please .... show the boundaries of sovereign submerged lands and 

the extent to which the radial collection wells would be located within sovereign submerged 

lands. (0023-1-43 [LaFerrier, Marc])

Comment: Pipe installation and canal crossing details were not provided. 

(0023-1-54 [LaFerrier, Marc])

Comment: Table 4.5-1 (Stream Number 36) lists the reclaimed water volume to FPL as 

72.7 MGD (50,481 gpm) and Appendix 10.9, Section 2.0 states Turkey Point Units 6 & 7 will 

require 55.3 million gallons per day (MGD) if supplied from reclaimed water. The discrepancy in 

the reclaimed water volume is not addressed. (0023-1-65 [LaFerrier, Marc])

Comment: The quantity of fill needed for Unit 6&7 and associated facility construction, the 

quantity of fill to be extracted at this site, the dimensions of the rock pit. Commitment approved 

by MDC CAO that no fill will be sold. (0023-3-4 [LaFerrier, Marc])

Comment: Geologic cross section of the proposed excavation (including the amount of water 

storage above- and below-ground, detailed information on the depth of the area to be mined) 

(0023-3-6 [LaFerrier, Marc])

Comment: The application states that muck removed from several construction sites will be 

stored in the spoil disposal site. (0023-4-13 [LaFerrier, Marc])

Comment: Application does not provide information on demolition or renovation that may occur 

as part of this project. (0023-4-6 [LaFerrier, Marc])
Appendix D 

October 2016 D-21 NUREG–2176 

Response: These comments refer specifically to the SCA submitted to the State of Florida by 

FPL, but they indicate an interest in the activities that will occur to build proposed Turkey Point 

Units 6 and 7. Chapter 3 of the EIS will describe the activities that will be taken to build the 

proposed units. The review team will assess the potential impacts of building the proposed 

units in Chapter 4 of the EIS. 

Comment: Are there any roads, whether for plant access or associated with the transmission 

lines that are being proposed as temporary roads? If so, please identify them and provide a 

map of their locations. (0023-1-52 [LaFerrier, Marc])

Comment: No data is provided indicating which roads are temporary, which roads are to be left 

as-built, and which roads are to be reduced after construction of power generation units and 

supporting facilities. (0023-2-22 [LaFerrier, Marc])

Comment: The application does not adequately depict property ownership in areas 

surrounding proposed linear features such as access roads, including Miami-Dade County 

Environmentally Endangered Lands (EEL) Program projects that have been at least partially 

acquired. (0023-2-6 [LaFerrier, Marc])

Comment: Information including but not limited to depth, slope, deep cut lines, levee height, 

etc. for the water management feature and rock mining activities proposed for the FPL owned fill 

source are not provided in the application. (0023-3-14 [LaFerrier, Marc])

Comment: No sketches are provided clearly denoting if rights-of-way shown are FPL right-ofway, road right-of-way or other right-of-way. (0023-3-29 [LaFerrier, Marc])

Comment: No data is provided describing the existing available right-of-way and ownership 

thereof. Provide clear maps denoting the aforementioned. (0023-3-30 [LaFerrier, Marc])

Comment: The applicant shall provide detailed information on the elevation of all project 

features that is sufficient to determine whether this requirement has been met. 

(0023-3-44 [LaFerrier, Marc])

Comment: Detailed information on the proposed excavation including the exact proposed 

location not provided. (0023-3-5 [LaFerrier, Marc])

Comment: The application does not provide sufficient information to determine whether all 

construction operations involving earthwork, including disposal, are limited to clean fill. 

(0023-4-12 [LaFerrier, Marc])

Response: These comments refer specifically to the SCA submitted to the State of Florida by 

FPL, but they indicate an interest in the layout of the proposed plant. The layout of features 

associated with proposed Turkey Point Units 6 and 7 will be described in Chapter 3 of the EIS. 

The review team will assess the potential impacts of building the proposed units in Chapter 4. 

Comment: The project's draft PSD permit incorporates the use of reclaimed water as the 

primary source of cooling water for the cooling towers as well as the use of salt water from 

radial collector wells as a backup source or some combination of the two as necessary. As 
Appendix D 

NUREG–2176 D-22 October 2016 

presented in the PSD emissions calculations, particulate emissions are highly dependent on the 

source of the cooling water. The Draft EIS should discuss: impacts related to particulate 

emissions with respect to the-source of the cooling water; anticipated availability of reclaimed 

water to support the new units in addition to existing units; recordkeeping and monitoring plans 

to assess water flow rates and the ratio of reclaimed to salt water used; and any salinity 

changes outside of the range used for the emissions calculations. (0014-20 [Mueller, Heinz])

Comment: As mentioned previously, FPL apparently proposes that Units 6 and 7 will have 

their cooling water needs provided by cooling towers as opposed to the existing canal system. 

The Draft EIS should discuss the wastewater-to-reclaimed water process, including describing 

the processes to remove debris, sand, sediment, and other large solids. The Draft EIS should 

discuss use of any microorganisms to break down organic materials, proposed clarifiers to 

remove microorganisms and remaining solids, filtering processes, and what type of disinfection 

(chlorine?) will be used to kill microorganisms. The monitoring of the re-use facilities and 

processes should be discussed in order that only high-quality reclaimed water is distributed and 

that it is clear and free of pathogens. (0014-8 [Mueller, Heinz])

Comment: Please provide a schedule of radial collector well operation including initial 

operation and all planned subsequent events, as well as monitoring protocol for the abovementioned resources. (0018-15 [Poole, Mary Ann])

Comment: Please state the maximum pressure the deep well injection pumps will generate. 

Please state the maximum water temperatures of the wastes that will be deep well injected. 

(0022-2-11 [Reynolds, Laura])

Comment: Please state the affects of the geologic fracturing that will occur as a result of 

pressure, temperature, exotic chemicals, and oxygen from deep well injections. 

(0022-2-12 [Reynolds, Laura])

Comment: Please state the amount of heat that will be discharged into the atmosphere from 

units 6&7 and state the temperature differential between the discharged heat and the ambient 

temperature. Please state the amount of water vapor that will be discharged into the 

atmosphere from units 6&7 and state the moisture differential between the discharged water 

vapor and the ambient humidity. (0022-2-15 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

varieties and concentrations of pathogenic waste, toxic waste, EPOCs, chemical waste, and 

radioactive waste that will be disposed by deep well injection, please provide them. 

(0022-2-4 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the ultimate location(s) of the deep well injected wastes, please provide them. 

(0022-2-5 [Reynolds, Laura])
Appendix D 

October 2016 D-23 NUREG–2176 

Comment: Please state, specifically, which wastewater batches will be deep well injected and 

which wastewater batches will be released into the unlined cooling canal system for both 

construction activities and normal operation activities. (0022-3-20 [Reynolds, Laura])

Comment: Please state, specifically, all additives and all additive quantities, injected into the 

cooling water, such as solvents, detergents, biocides, corrosion inhibitors, lubricants, scale 

inhibitors, oxygen removing agents, foam removing agents, salts, and any other chemicals. 

(0022-4-1 [Reynolds, Laura])

Comment: Pretreatment of the wastewater reuse source water to include treatment of EPOCs 

should be evaluated, considering Biscayne National Park's status as an Outstanding Florida 

Water Body with a no degradation standard under Florida Statutes. (0025-3-24 [Kimball, Dan] 

[Lewis, Mark])

Response: The proposed design for Turkey Point Units 6 and 7, including cooling tower and 

injection well performance, will be addressed in Chapter 3 of the EIS. The review team will 

assess the potential impacts of operating the proposed plant in Chapter 5, based on the 

affected environment described in Chapter 2. The EIS will include citations for documents used 

in its preparation. 

Comment: Based on the review of the Environmental Report, Part 3, submitted as pat1 of the 

Nuclear Regulatory Commission (NRC) Combined Operating License (COL), several 

inconsistencies have been noted when compared to the State of Florida Site Certification 

Application (SCA). The COL and the State of Florida SCA should contain the same design 

specifications and construction elements. For example, the FPL-owned fill source (rock mine) 

has been removed from the State of Florida SCA and the Army Corps of Engineers permit 

application. Without the Florida and ACOE permit approvals, the excavation cannot proceed. 

(0025-1-3 [Kimball, Dan] [Lewis, Mark])

Response: The NRC process is to review the license application and prepare an EIS based on 

the actions proposed in that application. Information to be used during the review will include 

documents obtained from State and Federal agencies, including the SCA, to the extent 

necessary to characterize the Turkey Point site. The FPL-owned fill source remains in the COL 

application at this time and a review of the environmental impacts of obtaining fill material will be 

presented in Chapter 4 of the EIS. 

Comment: Not enough information provided to assess water supply alternatives. 

Appendix 10.9 is a summary of alternative water supply study conducted by FPL. MDWASD 

has not received the reports cited in the Appendix (Analysis of Baseline Water Source, 

HDR Dec. 2007; Task 1 Initial Water Source Alternative Screening, HDR March 2008; Task 2 

and 3 Water Source Alternative Characterization and Scope, HDR March 2008; Conceptual 

Engineering of Cooling Water supply and Disposal for Turkey Point Units 6 & 7, HDR, June 

2008; Cooling Water Supply and Disposal Conceptual Design Report, HDR, March 2009). 

(0023-1-56 [LaFerrier, Marc])

Comment: Condition 5 of Z-56-07 requires FPL to provide an alternative water source plan that 

will outline all sources of water not supplied by WASD through reuse. (0023-3-41 [LaFerrier, Marc])
Appendix D 

NUREG–2176 D-24 October 2016 

Comment: Please provide additional information on the quality, quantity, timing and reliability 

of the proposed reclaimed water for hydrologic improvements. (0023-4-2 [LaFerrier, Marc])

Response: These comments are directed at the applicant and refer specifically to the SCA 

submitted to the State of Florida by FPL, but they indicate an interest in the cooling water supply 

for the proposed units. The cooling-water source for proposed Turkey Point Units 6 and 7 will 

be described in Chapter 3 of the EIS. Alternative water supplies will be considered in 

Chapter 9. 

Comment: Most of the lands adjacent to the proposed roadway segment improvements occur 

within the boundaries of the Biscayne Bay Coastal Wetlands CERP Project, and several 

segments would be located where this CERP project proposes infrastructure for restoration of 

the surrounding wetlands and Biscayne Bay. These road improvements would directly interfere 

with CERP features associated with the Biscayne Bay Coastal Wetlands Project, including 

pumps and spreader canals. (0023-2-18 [LaFerrier, Marc])

Comment: Please address how the proposed roadway features would be constructed to be 

consistent with the proposed CERP features. (0023-2-19 [LaFerrier, Marc])

Comment: The applicant must provide a detailed map identifying areas where roads or road 

improvements would not be completely contained within the boundaries of either FPL-owned 

land or an existing public right-of-way. The applicant must also identify adjacent property 

owners whose land may need to be obtained to accommodate the road or road improvements, 

including but not limited to the Miami-Dade Environmentally Endangered Lands Program, and 

explain the process by which the additional property will be obtained. (0023-2-21 [LaFerrier, Marc])

Response: These comments refer specifically to the SCA submitted to the State of Florida by 

FPL, but they indicate an interest in the proposed road improvements associated with building 

and operating Turkey Point Units 6 and 7. The EIS will describe the proposed road 

improvements in Chapter 3 of the EIS. The impacts of these road improvements will be 

presented in Chapters 4 and 5. The cumulative impacts of road improvements and CERP 

actions will be presented in Chapter 7 of the EIS. 

Comment: Please state the locations and extents of permitted ASR wells sites within 25 miles 

of units 6&7. Please state the capacity of each of the permitted ASR well sites within 25 miles 

of units 6&7. (0022-2-14 [Reynolds, Laura])

Response: The cumulative impact of the operation of proposed Turkey Point Units 6 and 7 and 

existing facilities that impact groundwater, such as the aquifer storage and recovery wells 

located in the vicinity of the Turkey Point site, will be addressed in Chapter 7 of the EIS. 

Comment: Flow rate used to calculate water demands on Table 4.5-1 not provided. Not clear 

on how water demands for potable water use were calculated. (0023-1-55 [LaFerrier, Marc])

Comment: No information was provided to show that the facility will be in compliance with the 

Flood Plain Management requirements including flood proofing as may be required. Please 

explain why existing runoff from pre-development conditions results in more runoff volume than 
Appendix D 

October 2016 D-25 NUREG–2176 

post development conditions, despite the fact that the pre-development plant site is mostly 

undeveloped and should have no runoff volume to be pre-treated. (0023-1-61 [LaFerrier, Marc])

Comment: Details for road improvements list"...NHW Elevation to be provided by DERM. 

Please provide further explanation as to what is expected. (0023-1-69 [LaFerrier, Marc])

Comment: Pursuant to Condition 9 of Z-56-07, Planned restoration features such as, but not 

limited to, pump PU-M3 (BBCW proposed project feature] and downstream hydrologic 

restoration shall not be compromised or constrained by the roadway(s). The application does 

not contain sufficient information to determine whether the requirements of Condition 9 of 

Z-56-07 have been met. (0023-2-33 [LaFerrier, Marc])

Comment: Pursuant to Condition 9 of Z-56-07, Sheet flow shall be maintained across roadway 

alignments by elevating portions of the roadway and through the installation of culverts in other 

areas. The application does not contain sufficient information to determine whether the 

requirements of Condition 9 of Z-56-07 have been met. (0023-2-34 [LaFerrier, Marc])

Comment: Roads are to be constructed to comply with Flood Criteria requirements, at a 

minimum. Assess impact on a larger study area. (0023-2-35 [LaFerrier, Marc])

Comment: No data is provided describing the existing available right-of-way and ownership 

thereof. Provide clear maps denoting the aforementioned. Clearly denote which roadways are 

to be public and which are to be private. Provide clear maps denoting the aforementioned. All 

roads to be dedicated as public right-of-way (arterials-section lines and half-section lines) 

should include the following: dedication of the zoned right-of-way for future widening and no 

easements within said right-of-way. Any utilities within the right-of-way will be allowed to be 

installed by permit only. No sketches are provided clearly denoting if right-of-way shown are 

FPL right-of-way, road right-of-way or other right-of-way. (0023-2-36 [LaFerrier, Marc])

Comment: The traffic studies provided in Appendices 1 0.7.4.1 and 1 0.7.4.2 do not 

demonstrate the need for construction vehicle traffic access to the power plant site from SW 359 

Street. (0023-2-37 [LaFerrier, Marc])

Comment: [T]he traffic studies presented in Appendices 10.7.4.1 and 10.7.4.2 do not provide 

sufficient data to demonstrate the need for the proposed roadway improvements. 

(0023-2-38 [LaFerrier, Marc])

Comment: Assumptions: Substantiate the following assumptions: maximum work-force of 

3,650 construction workers and vehicle occupancy of 1.0 worker per vehicle. Study Area. 

Given the amount of vehicular traffic likely to be generated, the number of employees and the 

size of project, the study area to be analyzed shall include all roadway facilities where traffic 

generated by the proposed project is equal to or greater than five (5) percent of the maximum 

service volume at the adopted level of service standard applicable to the roadway facility. Trip 

Generation. Given the unique characteristics of the use proposed, the trip generation shall 

include the following information: average daily, AM peak hour and PM peak hour. Consider car 

pooling, van pooling or employer-based car pooling. Analysis Period. Consider three analysis 

periods: Short-term (Concurrency Analysis for 3 years; construction is estimated to begin in 
Appendix D 

NUREG–2176 D-26 October 2016 

2011); and long-term (Years 2016 and 2020). Peak construction employment for the project is 

estimated for 2016; Project construction is estimated to conclude in 2020. Trip Distribution. For 

the Concurrency Analysis use the Cardinal Directional Trip Distribution from Zone 1401 and 

Year 2015, and the computerized travel demand forecasting (FSUTMS) model, refined where 

needed, for Years 2016 and 2020. (0023-2-39 [LaFerrier, Marc])

Comment: Future Conditions Analyses. Perform an assessment of future conditions on the 

study area roadways for the long-term planning horizons without the impacts of the applicationgenerated traffic; perform other assessment of future conditions on study area roadway and 

intersections with the impacts of the application-generated traffic. Incorporate programmed and 

planned roadway improvements consistent with Adopted Plans and Programs above. Mitigation 

Analysis. If the application causes the study area roadways to fall below their adopted LOS 

standards, recommend mitigation through physical or operational improvements, travel demand 

management strategies, fair-share contributions, or a combination of these or other strategies. 

(0023-2-40 [LaFerrier, Marc])

Comment: Provide detailed supporting documents for trip generation of 3,650 construction 

peak period employees. Document all the growth rates and estimate growth factors values for 

different analysis years. Since there are different peak hours for construction (5:00 AM to 

6:00 AM) and regular employees arrival (6:00 AM to 7.00 AM), traffic volumes for these two 

hours should not be combined in the analysis. Future roadway improvements in TIP, LRTP and 

Comprehensive Plans of effected jurisdictions should be investigated and listed in the report. 

Potential improvements may include bike trails, greenways and roadways etc. Potential 

improvements such as bike trails, greenways and roadway improvements, etc. Provide detailed 

supporting documents for trip generation of 36 construction-related trucks per hour. The 

existing truck volumes should also be included in the traffic data collection. This data can 

provide more accurate operational analysis as well as pavement design. To ease the review 

process, please provide traffic counts in the form of maps. Provide detailed supporting 

documents for trip generation of 806 and 2000 employees in normal traffic operational analysis 

for Scenario 1 and 2, respectively. Presence of only 940 employees during data collection 

period while 1,467 employees work. Therefore, trips should be adjusted, or it should be 

documented that only 940 employees are usually present. Please note that traffic data should 

be adjusted for all types of seasonal variations. (0023-2-41 [LaFerrier, Marc])

Comment: Parking demand and supply analysis should be included in the report. Regional 

traffic impact analysis should also be conducted because of the anticipated high peak-hour 

volumes generated during peak periods. Different access routes should be explored to the site, 

such as through SW 328 Street. (0023-3-57 [LaFerrier, Marc])

Comment: Pursuant to Condition 21 of Z-56-07, FPL has agreed to allow water level increases 

on the project site on the order of one foot or more, pursuant to regional restoration projects, 

and will design the project to accommodate these water level increases at FPL's expense. 

Information in the application is not sufficient to determine whether the requirements of this 

condition have been met. (0023-3-65 [LaFerrier, Marc])
Appendix D 

October 2016 D-27 NUREG–2176 

Comment: Further elaboration is needed on item 49 on Table 4.5-1 and noted in Figure 4.5-1 

(Effluent from FPL Reclaimed TP to Future FPL Users = 9,739 gallons per minute). 

(0023-3-67 [LaFerrier, Marc])

Comment: Please submit the earthwork and materials disposal plan required under 

Condition 7 of Z-56-07. The plan should include, but not be limited to plans and sketches 

pertaining to the proposed Spoil Areas including elevation details and slope stabilization. The 

applicant should also provide the management plan for listed species required under 

Condition 2 of Z-56-07, which should include but not be limited to identifying the plans 

established to protect endangered or threatened species from impacts resulting from the 

proposed work. (0023-4-19 [LaFerrier, Marc])

Response: These comments are directed at the applicant and refer specifically to the SCA 

submitted to the State of Florida by FPL, but they indicate an interest in site layout and design. 

The review team will describe the layout of proposed Turkey Point Units 6 and 7 and support 

features in Chapter 3 of the EIS. The potential impacts of building the proposed units will be 

presented in Chapter 4, and the potential impacts of operating the proposed units in Chapter 5. 

Comment: Under what circumstances would the radial collector wells be required to be used 

and at what capacities? Under what specific anticipated circumstance would radial collector 

wells constitute 100% of water source composition? (0018-13 [Poole, Mary Ann])

Response: The proposed cooling-water source for proposed Turkey Point Units 6 and 7, 

including operational information provided by FPL, will be described in Chapter 3 of the EIS. 

D.1.4 Comments Concerning Land Use – Site and Vicinity 

Comment: The Miami-Dade Board of County Commissioners, where Dennis C. Moss sits as 

the Chairman, recently approved a land use change in order to accommodate the expansion 

plan, which is the subject of the request that is before you today. (0001-26-3 [Gustave, Unito])

Comment: The proposed expansion by Florida Power & Light involves the land use of 38,607 

acres composed of wetlands, agricultural land, barren land, and water. Less than 5% of the 

proposed expansion involves the use of pre-established urban or built up land [1]. 

(0007-2 [Burris, Jessica])

Comment: The project should be consistent with the Goal, Objectives, and Policies of the 

Miami-Dade County Master Development Comprehensive Plan and its corresponding land 

development regulations. It is important for the applicant to coordinate permits with all 

governments of jurisdiction. (0019-12 [Hamilton, Karen])

Comment: Council staff recommends that the Goals and Policies of the Strategic Regional 

Policy Plan for South Florida (SRPP) related to protecting and enhancing South Florida's natural 

resources should be observed (0019-13 [Hamilton, Karen])

Comment: Consider the full the impacts of construction of the plant, and related facilities as 

they relate to rights-of way issues, relocation of facilities and infrastructure, and provide the 

appropriate mitigation strategies. (0019-4 [Hamilton, Karen])
Appendix D 

NUREG–2176 D-28 October 2016 

Comment: The plant site is located in Environmental Protection Subarea F, and is consistent 

only if the use is deemed consistent with the goals, objectives and policies of the 

Comprehensive Development Master Plan (CDMP). (0023-1-30 [LaFerrier, Marc])

Comment: Potential viewshed impacts may increase over current levels in Biscayne National 

Park from the construction of Units 6&7 and non-transmission facilities. This will impact visitor 

use and experience within the park and should be evaluated. (0025-3-27 [Kimball, Dan] 

[Lewis, Mark])

Comment: The scope of this project (adding two new reactors) is extraordinarily large. It will 

more than double the size of the existing plant. It requires changes in land use designations, 

unbelievable amounts of fill, building heavy duty roads, modifying shorelines, destroying 

wetlands and hammocks, digging a very large hole in South Dade for fill, (not to be restored), 

digging radial and injection wells, installing a wastewater treatment plant, installing a water 

treatment plant, installing miles of transmission lines, installing miles of pipelines, changing the 

horizon, and in effect building a small industrial city, yet FPL insists in their license application 

that this project in its entirety will have small to no impact. Amazing. Of course there will be an 

environmental impact and a big one. (0027-3 [Moses, Dorothy])

Comment: Identify specific measures that will be adopted to protect the environmentally 

sensitive lands south of Palm Drive (S.W. 3 4 4th Street) from illegal access and activities such 

as dumping, use of all-terrain vehicles, and poaching. The new roadways proposed south of 

Palm Drive will increase opportunities for illegal access to environmentally sensitive lands, 

including those in the Model Lands Basin area. (0032-38 [Golden, James])

Response: Land-use impacts of building and operating proposed Turkey Point Units 6 and 7 

and associated offsite facilities and transmission lines will be presented in Chapters 4 and 5 of 

the EIS, and cumulative land-use impacts will be presented in Chapter 7. The analysis of landuse impacts will address the general consistency of the proposed new facilities with applicable 

zoning regulations and land-use plans. Many of the land-use issues raised in this set of 

comments overlap with ecological issues, which will also be addressed in Chapters 4, 5, and 7. 

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - The potential for adverse 

impacts to the SFWMD's L-30 and L-31N Canal levees, which are located within the West 

Preferred Corridor. FPL is proposing use the existing access roads on the canal levees for 

construction and maintenance purposes; however, portions of the levees have not been 

designed to accommodate the heavy equipment proposed to be used by FPL; therefore, the 

levees will need to be enhanced and widened. The SFWMD advised FPL that any proposed 

levee enhancements will need to meet USACE design specifications, compaction, and side 

slope stabilization (grass/sod) requirements. (0032-21 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - The potential for adverse 

impacts to wetlands that are part of northeastern Shark River Slough, within the boundaries of 

Everglades National Park, and wetlands within Water Conservation Area 3B, associated with 

the West Secondary Corridor. Both of these areas are part of the Everglades Protection Area 
Appendix D 

October 2016 D-29 NUREG–2176 

as defined in the Everglades Forever Act and are targets for restoration under CERP. FPL has 

not provided adequate information on potential impacts from the construction, operation, and 

maintenance of the proposed transmission lines and related access (fill) roads through these 

areas. Currently, there are no existing access roads in this area other than the L-30 and 

L-31 N levee roads. New road construction would result in long-term impacts to wetland habitat, 

disrupt existing hydrologic flows, and impact water quality. New road construction would 

potentially conflict with future CERP project restoration efforts related to the relocation of the 

S-356 pump station and the promotion of wetland sheet flow. Vehicles (other than airboats) 

moving over the wetlands (without roads) would also result in major disturbance to existing 

wetlands by compacting soils, disrupting existing hydrologic flows, and impacting habitat for 

listed species. (0032-24 [Golden, James])

Response: Environmental impacts associated with planned new transmission corridors, as well 

as potential impacts associated with upgrades to the existing lines, if required, will be addressed 

in Chapters 4, 5, and 7 of the EIS. The analysis will consider possible effects on canals, levees, 

and other existing facilities in the affected areas as well as planned future Everglades’ 

restoration projects. 

Comment: Then there's a plan to put those two nukes on a pile of dirt 24 feet high, about 

10 million cubic yards. The bulk of this would come from a piece of property that FPL owns 

back from the edge of the Bay. That will take a very large hole, very deep. 

(0001-6-7 [Miller, Lloyd])

Comment: The Draft EIS should discuss sources of limestone rock proposed for use in the 

construction of Units 6 and 7. Any impacts from required mining should be discussed, 

particularly the impacts on Biscayne National Park or U.S. Air Force lands. 

(0014-12 [Mueller, Heinz])

Comment: The allowance of rock mining in agricultural areas is subject to approval of an 

amendment to the Comprehensive Development Master Plan. FPL has filed an amendment; 

however no action will be taken by local government until October 2009. Approval of this 

amendment is subject to extensive informational requests which have not been provided 

through this application. Therefore land use/zoning consistency cannot be determined at this 

time. (0023-3-2 [LaFerrier, Marc])

Response: The impacts of the proposed offsite fill-source operation as a part of building 

proposed Turkey Point Units 6 and 7 will be considered in Chapters 4 and 7 of the EIS. The 

analysis of land-use impacts in Chapters 4 and 7 will address the general consistency of the 

proposed fill-source operation with applicable land use plans and regulations. 

Comment: Please verify whether all proposed road construction, including stabilization slopes, 

will fall within the road ROW's. How will proposed impacts, either direct or secondary, adjacent 

to private property and areas held under conservation easement be addressed? 

(0023-3-54 [LaFerrier, Marc])
Appendix D 

NUREG–2176 D-30 October 2016 

Response: Environmental impacts associated with planned new roadways, as well as potential 

impacts associated with upgrades to the existing roadways, if required, will be addressed in 

Chapters 4, 5, and 7 of the EIS. 

Comment: Indicate which roadway improvements will be temporary and which will be 

permanent and specify the time-frames when each temporary roadway improvement will be 

restored to its previous, or better, condition. Although the applicant, FPL, indicates that all of 

the roadway improvements will be temporary, the County's Supplement to the Initial 

Recommendations Report for Application 6 states, "The [Miami-Dade County Planning] 

Department favors the dedication of the proposed roadway improvements as permanent 

facilities". Without clear identification of temporary and permanent roadway improvements, the 

District cannot identify all potential impacts. (0032-33 [Golden, James])

Comment: Include the additional roadway improvements proposed under the Additional 

Access Option in the plan. The plan only addresses the roadway improvements proposed by 

FPL. It should be modified to include the additional roadway improvements under consideration 

that are referred to in the County's Supplement to the Initial Recommendations Report as the 

Additional Access Option. (0032-37 [Golden, James])

Response: Potential impacts associated with roadways will be addressed in Chapters 4, 5, and 

7 of the EIS. The analysis will distinguish temporary from permanent roadway improvements. 

The review team does not advise the applicant on alternative roadway improvement plans; 

these decisions are made by the applicant and State regulatory bodies. Therefore, the choice 

of roadway improvements will not be addressed in the EIS. 

D.1.5 Comments Concerning Land Use – Transmission Lines 

Comment: I'm mindful of the concern of many of my fellow cities north of us with the 

transmission line issue. Those issues do not pertain to the City of Florida City at all. However, I 

believe that it's good for us to understand, and I believe this is the fact, that with regard to 

transmission lines, it doesn't matter what kind of power source we eventually construct at the 

Turkey Point site. If we construct fossil fuel plants, a fossil fuel plant, that power will still have to 

be transmitted. Hence, the transmission lines will be necessary no matter the type of 

generation system we have there. So the transmission line issue is not a child of the nuclear 

reactor request. And I think we are going to have to figure out a way to take care of 

transmission regardless of the power source. (0001-1-3 [Wallace, Otis])

Comment: Lastly, the plan calls for nearly 90 miles of new transmission corridors. NPCA is 

particularly opposed to the western corridor proposal which calls for the construction of more 

than 50 miles of power lines either within or adjacent to Everglades National Park. FP&L hasn't 

given any alternative plans that are acceptable with respect to the placement of these power 

lines, which are bad for migratory birds, parklands, and wetlands alike. 

(0001-15-4 [Cornick, Lance])

Comment: The impact that we are most immediately dealing with is the Florida Power & Light's 

transmission line process that they have undertaken from -- as a result of the Florida statutory 

framework. We are participating within that administrative hearing. And as a result of the 
Appendix D 

October 2016 D-31 NUREG–2176 

environmental study indicating that you are also going to be looking at that as an indicator, we 

will be giving you some very specific information about the incompatibility and very adverse 

impact of the proposed alternate corridor along US-1. We have a process that we are a part of 

where we will be submitting an alternate corridor outside of the US-1 corridor for the siting of the 

transmission lines. (0001-21-1 [Lerner, Cindy])

Comment: In addition, the US-1 corridor, as I said, is our only commercial area. And we are 

working towards plans -- you'll hear from my colleagues about the plans they have already 

implemented for the ability to take the US-1 corridor, which is our major transit, transportation, 

and commercial corridor, and over the course, the vision for Miami-Dade County for the future of 

the US-1 corridor is to create the opportunity for in-fill by having mixed use development along 

that corridor, encouraging people to move along the corridor and use the transit that is there as 

opposed to going out and having the sprawl that we are all fighting against. And preserving the 

urban development boundaries would require that we focus on mixed use development along 

US-1. Placing the power lines along that US-1 corridor would absolutely not only inhibit, it 

would destroy any commercial interest or developer in coming along and complying with that. 

(0001-21-4 [Lerner, Cindy])

Comment: We're here to talk jobs. Just as the discussion is jobs in regards to the nuclear 

power plant such as with the siting lines, we're here to present a pro-business, a pro-job 

argument for why we need the least intrusive siting of these lines. Now, to a large degree we've 

been powerless in this regard because with the state statutes that govern siting, there's really 

no discretion that has been allowed within the different municipalities. In essence, we've been 

preempted and it's a state matter that will eventually go before the Cabinet if we get in front of 

the Administrative Law Judge. For the record, what I would like to bring and present to you on 

DVD's are the legislative actions that the various three municipalities have taken in regards to 

the US-1 Business District and the transmission sitings. And what these are are the resolutions 

as well as some of the charrette plans and the other actions that we've taken. Now, I would like 

to make that part of the record on behalf of the Village of Palmetto Bay, the town of Cutler Bay, 

and the Village of Pinecrest. (0001-22-1 [Flinn, Eugene])

Comment: Why that's important -- and Mayor Vrooman will discuss in more detail those 

charrettes that he's been involved in, that we've been involved in in regards through Chambers 

South, a very important community partner, and the different cities, is one of the first things the 

Village of Palmetto Bay did in incorporating in 2002, was to attempt to put a rudder on an 

otherwise local economic area that was adrift. And we are attempting to bring jobs; we are 

attempting to bring sustainable development. And we believe that the record evidence from an 

economist and from our engineers, who is going to show that these siting lines have a severe 

risk in actually forcing sprawl. Why is that? Because they're going to render commercially 

useless some areas where significant work was done. What I would like to show as our first 

board here, is this is the Franjo Triangle Commercial Island charrette. And it is a wonderful 

vision for the community. And I think if you will take a look at this, this is primarily an economic 

center. It is a mixed use; it does include residential. But you're going to have quite a few jobs, 

small businesses, which is a huge component of our Miami-Dade County economy here. These 

lands will be rendered, from some of the information we've received, will be severely impacted 

by the siting of these lines basically going through them. These lines are incompatible. From 

what we've seen, these lines are more appropriate what you would see driving down Krome 
Appendix D 

NUREG–2176 D-32 October 2016 

Avenue and those areas that weren't seen fit to put through the areas 30 years ago, they're less 

fit to put through here now. (0001-22-2 [Flinn, Eugene])

Comment: We are attempting to work with FP&L. It is an adversarial proceeding but we're 

attempting to work together. We have just passed resolutions, Pinecrest and Palmetto Bay, in 

regards to engaging an engineer to get us to the first section of this process and have our input. 

Because we believe there are better locations for these lines without adversely affecting the 

hard work that's been going on. You have three municipalities here that have done outstanding 

work since they're been incorporated. And Paul Vrooman, I don't -- maybe I should just yield 

the floor to you at this point. But our position at this time is that they are incompatible with the 

area. They could be rendered more compatible if we undergrounded them, which we 

understand the issues on that. But we're not sure we're getting the feedback or the recognition 

as to what our issues are. We do not want to render these plans obsolete. If you render these 

plans obsolete you are going to see no net gain in jobs for the South Dade area; you're going to 

see no net gain improvement; and the only thing you're going to see coming out of here is 

power for other areas. (0001-22-3 [Flinn, Eugene])

Comment: Now, we have an opportunity to properly site these areas but that's not the plan on 

the board here. We have two other boards here. These are not from Palmetto Bay, Pinecrest, 

or Cutler Bay. But just to show you the charrettes that the South Dade area have been involved 

in in trying to revision this area, the Leisure City Naranja Lake charrette area plan. And, Paul, if 

you could talk about the goals and come up with your plan and the South Dade, too. Because 

we're trying to put together a comprehensive vision for South Dade. This is not a single city 

issue; this is a regional issue that affects the entire county. And we need to work together to 

find the least intrusive solution to this problem. And right now we're in a position to where we 

have to take this head on and try to get a result in the best interest of South Dade. And that's 

why we're opposing this at this time. (0001-22-4 [Flinn, Eugene])

Comment: I'm proud to be here with my colleagues from Palmetto Bay and Pinecrest and to 

speak in opposition to the transmission line on US-1. I am not here to speak -- and my mind is 

not made up -- on the wisdom of the additional reactors. That is not the issue that I am 

authorized to bring here on behalf of my Town Council. However, I am authorized -- we do 

have a Resolution on our record that Mayor Flinn turned in that said that we do not feel that it is 

in the public interest to do transition -- transmission lines up US-1. (0001-23-1 [Vrooman, Paul])

Comment: And the reason why I want to discuss that is an environmental factor. What is 

environmental impact? Is it just the impact that happens on the site; is it what happens adjacent 

to the plant; is it the footprint of the plant; or is it broader policy? Well, we've had discussions in 

this community on a regional basis about suburban sprawl, and about sprawl going out into 

places like the Everglades; something that our country is spending billions of dollars to try to 

mitigate and try to repair. So, if we are creating policies or -- that respond to that as our in-fill 

policies and our smart growth policies have done on a regional basis to combat that, which 

essentially means adding mixed use, urban in-fill, transit-friendly development on the US-1 

corridor, and this plant results in a transmission line gutting that plan by running up US-1, then I 

see that as a very definite environmental impact. The impact of that transmission line won't 

be -- you won't be able to identify that on US-1 specifically. But I can tell you that when the next 

ring of homes and the next ring of development goes out into the Everglades because we have 
Appendix D 

October 2016 D-33 NUREG–2176 

not provided an alternative to that on US-1, that will be directly because of these decisions that 

are going to be made, vis-a-vis this application. (0001-23-2 [Vrooman, Paul])

Comment: I think that we've said that enough times but I do want to reflect that I do see this as 

an environmental issue. I do see this as effectively gutting the regional response from the 

county and all the municipalities up and down US-1 to come up with a response to suburban 

sprawl that is economic friendly. I think if you look at the boards around me, it's not hard to 

imagine the number of jobs that that will create that will come from that construction, that will 

come from the businesses that will be there, and it is much, much Greener, environmental 

friendly alternative growth patterns. And this will be very, very detrimental to our ability to make 

that come true. (0001-23-3 [Vrooman, Paul])

Comment: I want to agree with the mayors of Palmetto Bay, Cutler Bay, and Pinecrest. We've 

done some incredible things on walkable areas along US-1. We should protect those and I do 

believe that should be in the scope. (0001-24-6 [Harum-Alvarez, Albert])

Comment: Additional environmental destruction would involve their desire to put the 

transmission lines through Everglades National Park, because all the towns up US-1 don't want 

any more transmission lines. So where else do you put them? Well, you go tear up the 

Everglades and put them out there. (0001-6-8 [Miller, Lloyd])

Comment: FPL's proposed transmission corridor will impact upon lands within Everglades 

National Park and the footprint of BBCW and seek to fill more than 300 acres of wetlands. In 

addition, the other proposed sites for these transmission lines is along the US-1 corridor which 

is very important for nodal growth as this is an area where public transportation exists. And if 

we don't develop along these nodal corridors, then this encourages sprawl which will, of course, 

affect Everglades and other wetlands. (0001-7-5 [MacLaren, Kaitlin])

Comment: In closing, I also want to join the voices of the Mayors from Cutler Bay, Palmetto 

Bay, South Miami and Pinecrest, who object to the environmental impact of power lines along 

the US-1 corridor, which would destroy the plans of mixed use pedestrian and transit oriented 

development, compact urban form that holds the line on urban sprawl, and which in turn 

protects our Everglades and environmentally sensitive areas. (0002-1-5 [Sorenson, Katy])

Comment: Power lines through Everglades National Park. That's another part of this licensing 

thing. The land that was purchased by the people of the United States in a place called the 

East Everglades Expansion Area, was purchased for one particular reason; the protection and 

restoration of that section of the Everglades, the Shark River Slough, the heart of the 

Everglades ecosystem. Now FP&L is planning to put three power lines through that National 

Park, the iconic National Park in Florida; 150 feet tall, 500,000 kilovolts each. And they're 

demanding that the Park turn over the eastern edge to them so they can put this thing in there. 

How do they get away with that? I looked at the documents at the beginning when that 

expansion area first came through. NPS looked at that corridor that they owned. They said, 

well, we valued the land, we can give you 100, $200,000 for it. When could you turn it over? 

That was 20 years ago, and now they're on the verge -- National Park Service is on the verge of 

turning this corridor, on the eastern edge of our Park, over to them. Not only is it going to create 
Appendix D 

NUREG–2176 D-34 October 2016 

an industrial landscape for Everglades National Park, which will happen. 150 foot tall towers 

would be visible from Shark River Slough. (0002-14-9 [Schwartz, Matthew])

Comment: The transmission lines along the US-1 corridor is a direct contradiction of what we, 

the leaders of these cities, have envisioned for an improved US-1 corridor which will allow us to 

go ahead and develop our communities in smart ways rather than going further into the 

Everglades. (0002-2-2 [Meerbott, Tim])

Comment: Do not allow transmission lines to be run down US 1. This is a primary federal 

highway that runs directly through many south Florida cities. Please run these down our 

expressways and railway right of ways to prevent aesthetic loss of property values along our 

cities. (0008-3 [Garcia, Preston])

Comment: Consider the full the impacts of construction of the transmission lines and related 

facilities as they relate to rights-of way issues, relocation of facilities and infrastructure, and 

provide the appropriate mitigation strategies. (0019-5 [Hamilton, Karen])

Comment: Ensure the proposed transmission lines are compatible with existing and future 

uses in terms of mass, scale and height. (0019-7 [Hamilton, Karen])

Comment: Consider how the placement of transmission lines along the more urbanized areas 

of the two proposed corridors will affect future opportunities to provide new transit features, the 

South Miami-Dade Busway or Metrorail expansion, greenways and pedestrian features, 

redevelopment projects, and scheduled roadway improvements (0019-9 [Hamilton, Karen])

Comment: Provide contextual perspectives for both existing and proposed electric poles and 

supporting infrastructure to demonstrate that chosen technology and structures will be 

compatible with the surrounding land uses. (0023-3-31 [LaFerrier, Marc])

Comment: Please provide a detailed description of the construction methodology that will be 

used to limit secondary impacts, especially along the linear infrastructure features. 

(0023-3-52 [LaFerrier, Marc])

Comment: Potential impacts from the construction and operation of transmission lines and 

access roads in either the West Preferred or West Secondary Corridors include disruption of 

hydrologic flows; wildlife and habitat disruption; wetland plant community destruction; reduction 

of native plant species populations; adverse effects on threatened and endangered species and 

migratory birds; introduction of non-native, invasive species; air and water pollution; noise; 

impacts to cultural resources, adverse impacts to viewsheds and wilderness character; and 

degradation of park visitor experiences. A cultural resources survey should be performed to 

identify cultural resources in the two corridors and measures to avoid and minimize potential 

impacts. (0025-2-10 [Kimball, Dan] [Lewis, Mark])

Comment: The EIS should evaluate the direct, indirect and cumulative effects of the 

transmission lines and related facilities needed to connect Units 6 & 7 to FPL's electric 

transmission system. (0025-2-5 [Kimball, Dan] [Lewis, Mark])
Appendix D 

October 2016 D-35 NUREG–2176 

Comment: The Western Transmission Line Corridor includes two options, a West Preferred 

Corridor option and a West Secondary Corridor option. Either option would include the 

installation of two 500 kV transmission lines, one 230 kV transmission line and related towers, 

guy wires, ground wires, fill pads, and access roads. Both corridors are partially located within 

the boundaries of Everglades National Park Expansion Area as shown in Fig 9.4-13 of the 

COLA Environmental Report. (0025-2-7 [Kimball, Dan] [Lewis, Mark])

Comment: The NPS is conducting a wilderness study for the 109,500 acre ENP Expansion 

Area. This study evaluates lands for possible recommendation to Congress for inclusion in the 

national wilderness preservation system as required by the Wilderness Act of 1964. 

Construction of transmission structures and access roads in the West Secondary Corridor would 

result in 320 acres of lands not being eligible for wilderness designation. FPL's West Preferred 

Corridor runs through lands within the Expansion Area that may also be eligible for wilderness 

designation. The eligibility of lands adjacent to either corridor would be adversely affected by 

introducing visible man-made structures (such as transmission facilities), and introducing noise 

(from construction/operation/maintenance activities) that would adversely affect opportunities for 

solitude. (0025-3-37 [Kimball, Dan] [Lewis, Mark])

Comment: Kingston Square Condominium is located at 9300 -9430 SW 77th Avenue and our 

street is the preferred route for FPL to erect 80 -100 foot transmission lines of 230 volts. This is 

an outrage! Ours is a quiet residential street of homes, condominiums, a Baptist Church with 

orphanage, and small businesses. (0031-2 [De Villiers, Elena])

Response: Environmental impacts associated with the planned new transmission corridors and 

roadways will be addressed in Chapters 4, 5, and 7 of the EIS, as will potential impacts 

associated with upgrades to the existing lines if required. The land-use impact analyses 

sections in Chapters 4, 5, and 7 will consider the compatibility of the proposed transmission 

lines and other offsite facilities with existing and proposed land uses in the affected areas and 

with land-use plans under consideration by State and local governments. The analyses will also 

consider potential impacts from the transmission lines and other offsite facilities on Everglades 

National Park, Biscayne National Park, and other affected public lands. The impacts of power 

lines on human health will be addressed in Chapter 5. 

Comment: FPL owns, and has owned since the 1960's and early 1970's, approximately 

320 acres of undeveloped land within the Expansion Area (part of the West Secondary 

Corridor). Since the FPL Property is currently undeveloped and is needed for the restoration 

and enhancement of the ecosystem through improvement of natural hydrologic conditions, the 

NPS intends to acquire the FPL property and manage it as part of ENP and to maintain the FPL 

Property in its undeveloped natural condition. The NPS began negotiations with FPL in 1996 

but to date the federal government and FPL have been unable to reach an agreement on the 

direct acquisition of FPL's property by the United States. (0025-2-8 [Kimball, Dan] [Lewis, Mark])

Comment: As noted, in Section 9.4.3.1 of the COLA Environmental Report, the Omnibus 

Public Land Management Act of 2009 authorized the Secretary of the Interior to exchange 

260 acres of NPS property within and along the eastern edge of the Expansion Area (part of 

FPL's West Preferred Corridor) for FPL's 320-acre property within the Expansion Area (part of 

FPL's West Secondary Corridor). The NPS lands being considered for exchange were acquired 
Appendix D 

NUREG–2176 D-36 October 2016 

by the NPS for the purpose of restoring the hydrology and ecology of the park. The exchange 

decision is left to the Secretary's discretion subject to conditions necessary for protection of 

resources, equalization of land values and evaluation of potential environmental impacts 

pursuant to the National Environmental Policy Act (NEPA). The NPS is currently preparing an 

environmental assessment regarding the potential exchange. At the conclusion of the NEPA 

process, the NPS will decide whether to exchange lands with FPL or to acquire the FPL 

property by direct purchase/eminent domain. There are many uncertainties regarding the 

exchange, and it is not a foregone conclusion that the NPS will decide to exchange lands. An 

NPS decision to acquire FPL's property, rather than exchange lands, would result in neither 

corridor within the Park being available for placement of transmission lines. 

(0025-2-9 [Kimball, Dan] [Lewis, Mark])

Response: Potential land-use impacts of building and operating proposed Turkey Point Units 6 

and 7 on the Everglades National Park, Biscayne National Park, and other parks and preserves, 

including impacts on wetlands within those areas and on threatened or endangered species, will 

be evaluated in Chapters 4, 5, and 7 of the EIS. 

Comment: The applicant must provide details on what other parties are filing alternate 

transmission line corridors, along with an explanation of how the process for approving 

transmission line corridors differs, including but not limited to obligations of other parties to meet 

applicable Conditions in Z-56-07, when FPL is not the applicant. (0023-3-19 [LaFerrier, Marc])

Comment: The map series showing the transmission corridor locations do not differentiate 

between existing rights-of-way/easements and areas proposed. (0023-3-20 [LaFerrier, Marc])

Comment: Maps and narratives do not demonstrate existing rights-of-way or existing certified 

corridors along the proposed east and west transmission corridor alignments. 

(0023-3-37 [LaFerrier, Marc])

Comment: Location of greenways/trails are not shown in map series showing preferred 

corridors or secondary corridors although the criteria in Tables W 9.3.1-4 and E 9.3.1-4 

specifically state that the acquisition status of existing and proposed greenways was included in 

the Alternative Route Qualitative Evaluation Criteria. Please provide mapping of existing and 

proposed greenways. The Application does not address the Parks and Open Space System 

Master Plan prepared in compliance with Policy ROS-4 of the Recreation and Open Space 

Element of the CDMP and as approved by the Board of County Commissioners. 

(0023-3-62 [LaFerrier, Marc])

Comment: Materials provided are not sufficient to determine whether corridor alignments, 

construction techniques, and proposed pole designs will ensure protection of future inland 

wetlands, wellfield areas, and Natural Forest Communities from incompatible land use. 

(0023-3-63 [LaFerrier, Marc])

Response: These comments refer specifically to the SCA submitted to the State of Florida by 

FPL, but they indicate an interest in the potential impacts of the proposed transmission lines. 

The review team will assess the potential impacts of the proposed transmission lines in 

Chapters 4 and 5, based on the affected environment described in Chapter 2. 
Appendix D 

October 2016 D-37 NUREG–2176 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of the Turkey Point FPL power station and its transmission lines on the 

environment, including any cost-benefit analyses, please provide them. 

(0022-1-6 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of construction and operation of the proposed Eastern Transmission Corridor 

and the proposed Western Transmission Corridor, on the environment, including any costbenefit analysis, please provide them. (0022-1-7 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of construction or operation of the Clear Sky switchyard, the Davis substation, 

the Miami substation, the Pennsuco substation or the Levee substation in the future, including 

any cost-benefit analysis, please provide them. (0022-4-5 [Reynolds, Laura])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 and associated offsite facilities, including transmission lines, on the environment will be 

addressed in Chapters 4, 5, and 7 of the EIS, based on the affected environment described in 

Chapter 2. The EIS will include citations for documents used in its preparation. 

Comment: We are limited in what we can do with underground lines, or overhead poles, or all 

of the things that are needed to get the transmission of the power to all of our communities. 

(0001-25-5 [Horton, Richard])

Comment: Explore the alternatives of undergrounding and co-locating transmission lines with 

Metrorail. (0019-10 [Hamilton, Karen])

Response: The environmental impacts of building and operating the proposed transmission 

lines will be addressed in Chapters 4, 5, and 7 of the EIS. However, the review team does not 

advise the applicant on alternative designs of transmission facilities; these decisions are made 

by the applicant and State regulatory bodies. Therefore, issues related to possible underground 

transmission lines would ordinarily not be addressed in the EIS. However, the Corps of 

Engineers, and perhaps the National Park Service, will be cooperating with the NRC on the EIS. 

To the extent that a cooperating agency addresses such alternatives for its NEPA analysis, 

those alternatives would likely be included in this EIS in order to support the cooperating 

agency’s environmental review. 

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - The potential for the Preferred 

Corridors to adversely impact SFWMD-owned communications towers and radio matrix sites. In 

particular, the West Preferred Corridor is located very close to various SFWMD communications 

towers and radio matrix sites. Although FPL has indicated that they will work with the SFWMD 

to resolve any unlikely interference issues, they have not provided the SFWMD with adequate 

information to determine if or to what extent critical SFWMD-owned communications facilities 
Appendix D 

NUREG–2176 D-38 October 2016 

may be impacted by the proposed transmission line facilities. The SFWMD advised FPL that it 

is unacceptable to wait until impacts have occurred to identify, design, permit, construct, and 

implement solutions, since this could substantially impact the SFWMD's ability to use these 

facilities to meet SFWMD flood protection and other critical emergency management 

responsibilities. (0032-22 [Golden, James])

Response: The impacts of operating proposed Turkey Point Units 6 and 7, including the 

impacts of the associated transmission lines, on community services, will be addressed in 

Chapter 5 of the EIS. The potential impact of transmission lines on radio signals used by local 

and regional agencies to perform their missions will be considered in preparing that chapter. 

D.1.6 Comments Concerning Geology 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of operation of the rock mining associated with the Turkey Point FPL power 

station on the environment in the past, currently, and in the future, please provide them. 

(0022-1-14 [Reynolds, Laura])

Response: Available information about the fill source will be provided in Chapter 3 of the EIS. 

The potential impacts of obtaining fill material on water resources will be presented in Chapter 4 

of the EIS, based on baseline information on the affected environment described in Chapter 2. 

The cumulative impacts of the actions proposed by FPL to build and operate proposed Turkey 

Point Units 6 and 7 along with other past, present, and reasonably foreseeable future actions 

will be presented in Chapter 7. 

D.1.7 Comments Concerning Hydrology – Surface Water 

Comment: And the one last thing I keep wondering about is, the nuclear power plants generate 

hot water; correct? What about desalinization, especially in areas like South Florida, to take 

that hot water and use it as part of a desalinization solution? (0002-17-6 [Eney, Douglas])

Response: The impact of effluents discharged from proposed Turkey Point Units 6 and 7 on 

water resources and ecological resources will be discussed in Chapter 5 of the EIS. The NRC 

does not advise the applicant on alternative uses of waste heat from a power plant; these 

decisions are made by the applicant and State regulatory bodies. Therefore, the comment 

related to alternative use of waste heat will not be discussed in the EIS. 

Comment: We also continue to be concerned about the saltwater intrusion into the Biscayne 

Bay that is being facilitated by the current cooling canals. The effects of the increased salinity 

are negatively impacting Biscayne Bay restoration efforts. (0001-15-3 [Cornick, Lance])

Response: The review team will assess and discuss baseline water-quality conditions within 

the affected environment in Chapter 2 of the EIS. The team will assess the impacts of building 

and operating proposed Turkey Point Units 6 and 7 on water resources in Chapters 4 and 5, 

respectively. The cumulative impact of the proposed action and other past, present, and 

reasonably foreseeable actions that have the potential to affect water resources will be 

discussed in Chapter 7. 
Appendix D 

October 2016 D-39 NUREG–2176 

Comment: Water impact and the saltwater intrusion has been coming to Dade County -- I used 

to swim right there before the plant was built. I used to crab right there -- just south of there. I 

was a human bobber. My dad used to pull me behind the boat and used to go and dive and get 

crabs and all kind of fish. You don't see a lot of that now. But, is it the plant's fault? No. It's 

because Dade County has gone from 100,000 people to 1 million 9, or whatever our current is. 

And that impact is going to continue. It's not the plant that's causing the problem. Our water 

situation, with that mitigation of fresh water flowing out to the ocean, now you're going to have 

saltwater coming in; it's not the plant's fault. (0002-12-4 [McHugh, John])

Response: This comment refers to changes in baseline water quality and aquatic ecology in 

Biscayne Bay in the vicinity of the proposed units. The review team will present baseline waterquality conditions within the affected environment in Chapter 2 of the EIS. Predicated on this 

information, the team will assess the impacts of the proposed action on water resources in 

Chapters 4 and 5 for building and operating proposed Turkey Point Units 6 and 7, respectively. 

The cumulative impact of the proposed action and other past, present, and reasonably 

foreseeable actions that have the potential to affect water resources will be discussed in 

Chapter 7. 

Comment: Growing up in Florida I have seen firsthand our issue with water consumption and 

lack of water. Lately, reports of clean water becoming scarce is an issue being talked about by 

many world leaders. Half of the world's schools do not have access to clean water and 

1.5 billion people do not have access to clean water either. We're taking water, one of our most 

precious natural resources, for granted by consuming so much through nuclear energy. 

Conserving water and our incredible ecosystems in Florida should be a main priority and a main 

influence for FP&L decisions. Nuclear power is very water-intensive and we'll only have 

problems in the future. It is not efficient as other options that Florida should be considering, such 

as solar and wind. (0001-19-2 [Ryan, Megan])

Comment: But we also need to consider that the water they're going to be using, the 90 million 

gallons of water that they want to use to cool these plants, is about one-third of our grey water, 

and there are other alternatives that we could use for that. We could be using irrigation and 

other areas rather than just turning it over to FP&L. So I want them to consider the use of the 

water along with the impact it will have on the development of the US-1 quarter. 

(0002-2-3 [Meerbott, Tim])

Comment: As a result, we request that the scoping that you're providing in the EIS present a 

very high level of detail in the water resource mass balance of both the hydrology and the water 

chemistries that we have in South Dade County to prohibit any negative impacts. We already 

have enough negative impacts, and last year was a good example. We had a drought that 

brought the surface water of the Biscayne aquifer down to zero, and as you know we can't keep 

it at zero too long with the saltwater head pushing inland. So, we need to do everything we can 

to protect our water resources and our water supply for our citizens. (0002-3-4 [Walker, Tom])

Comment: What are the cumulative effects of radial collector wells on water conditions in 

Biscayne Bay, including salinity, flushing, clarity, water quality, localized temperatures, etc.? 

Further, what are the anticipated effects at increments of 25%, 50% and 100% of full 

implementation of this proposal? (0018-12 [Poole, Mary Ann])
Appendix D 

NUREG–2176 D-40 October 2016 

Comment: Radial Collector Wells: The application does not provide enough information on 

this technology and the current conditions at the locations of the radial collector wells for us to 

assess whether their construction or operation would have an impact on fish and wildlife 

resources. We wish to point out the highest priority for recovering the ecosystem health of 

Biscayne Bay is on addressing the negative impacts that water resource development and 

water management have had on the salinity regime of the Bay and its associated coastal 

wetlands, which provide important habitat for fish and wildlife resources. If radial collector wells, 

which are vertical wells that then discharge laterally via a series of pipes underground, would 

disrupt the groundwater system, which is closely tied to surface water (which in turn supports 

fish and wildlife resources) in this extremely porous karst area, this proposal would seem to be 

contrary to commitments made by the Governor's Office and U.S. Congress, which signed into 

law authorizations to restore Biscayne Bay (Water Resources Development Act of 2000 -see 

http://www.fws.gov/habitatconservation/omnibus/wrda2000. pdf). (0018-7 [Poole, Mary Ann])

Comment: Whether the extraction of water from the Biscayne Bay system will change or 

reduce the freshwater inflow to the bay and/or increase salinity at least seasonally shall be 

examined through additional modeling as part of the application. (0023-1-48 [LaFerrier, Marc])

Response: The review team will assess the impacts of building and operating proposed Turkey 

Point Units 6 and 7 on the water quantity and quality of both local and regional water resources 

and identify mitigation measures proposed by the applicant to reduce adverse impacts. This 

assessment will consider current and future conditions, including changes in water demands to 

serve the needs of the future population, and changes in water supply. The review team will 

present baseline water quality conditions in the environment around the proposed site in 

Chapter 2 of the EIS. The impacts of building and operating the proposed units on water 

resources will be presented in Chapters 4 and 5 of the EIS, respectively. Cumulative water-use 

impacts will be addressed in Chapter 7 and cooling-water alternatives in Chapter 9. 

Comment: Florida Power & Light refers to plans to fill at least 70 acres of existing wetlands in 

the Miami Dade region surrounding Turkey Point. This fill could have devastating impacts on 

the surrounding environment and economy, as it would eliminate 70 acres of existing flood 

water storage during intense rainfall or hurricane. Filled wetlands can cause both on-site and 

off-site flooding [2], damaging the plant itself on property owned by Florida Power & Light, and 

also causing possible devastating damage to the surrounding communities, even possible loss 

of life. (0007-6 [Burris, Jessica])

Response: The environmental impacts of building and operating proposed Turkey Point 

Units 6 and 7, including the infilling of wetlands, on local hydrology and terrestrial ecology will be 

evaluated in Chapters 4 and 5 of the EIS. Safety issues related to potential floods are outside 

the scope of the environmental review, but will be evaluated by the NRC staff in its SER. 

Comment: If the scientists are correct, and they keep moving that global warming -- not global 

warming, but global sea level change up more and more because the glaciers of Greenland, of 

Antarctica, are melting. They are melting. You don't have to believe it or not. Look at the 

photos and look at it, look at the measurements and look at it. (0002-14-14 [Schwartz, Matthew])
Appendix D 

October 2016 D-41 NUREG–2176 

Comment: Sea level rise is a real and ongoing interesting element that we haven't had to deal 

with before that is going to be causing major challenges to our infrastructure. We would hope 

that FPL's proposed facility do not add any unintended consequences by moving millions of 

tons of dirt and moving waters around that could increase the potential impacts as a result of the 

already impacting sea level rise. (0002-3-6 [Walker, Tom])

Comment: [L]ook ahead through the expected life of the new facilities, and should consider 

potential future conditions in the analysis, including a change in sea level. Sea level has been 

rising in this region since records were established, and could ultimately affect how the plant 

and associated facilities interact with the surrounding environment. Miami-Dade County 

recommends that the time period for projections of future conditions include the potential that 

the license would be renewable for a second operational period. This has been the case for the 

existing Units 3 and 4. Given FPL's operational record, there is no reason to assume otherwise 

for the proposed Units 6 and 7. (0015-6 [Espinosa, Carlos])

Comment: A further 2-foot sea level rise by the end of the century, as projected in the 2001 

IPCC report, would make life in south Florida very difficult for everyone. Spring high tides would 

be +4.5 to 5 feet above present mean sea level 3 q; storm surges would be higher; barrier 

islands, fill islands and low-lying mainland areas would be frequently flooded; salt water 

intrusion would restrict available freshwater resources; drainage would be more sluggish; 

Turkey Point would be an offshore island; and so on. (0016-9 [White, Barry])

Comment: Please state all the projections for sea level rise used by the NRC. 

(0022-1-4 [Reynolds, Laura])

Comment: No identification of sea level rise projections used to model the water management 

project provided. (0023-3-59 [LaFerrier, Marc])

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 5. Sea level rise. Please include information in the EIS that evaluates potential 

seal level rise scenarios and how the project is being designed to mitigate these effects. 

(0033-13 [Croom, Miles])

Response: The review team will assess the impacts of building and operating proposed Turkey 

Point Units 6 and 7 on local and regional water resources and aquatic and terrestrial ecology. 

This assessment will consider both current and future conditions that affect the environment 

including sea level rise and mitigation measures identified by the applicant that could reduce 

adverse impacts. Impacts on water and ecological resources from building and operating the 

units will be discussed in EIS Chapters 4 and 5, respectively. Cumulative impacts will be 

addressed in Chapter 7 and plant design alternatives in Chapter 9. The period of consideration 

for environmental impacts is over the 40-year license period; under the NRCs environmental 

protection regulations (Title 10 of the Code of Federal Regulations [CFR] Part 51), which 

implement Section 102(2) of the National Environmental Policy Act of 1969, as amended 

(NEPA), if renewal of the operating license is requested, preparation of an EIS would again be 

required. Because license renewal is not certain to occur (or even to be requested), to include 

that extended period for environmental impacts would be speculative and outside the bounds of 
Appendix D 

NUREG–2176 D-42 October 2016 

NEPA. Therefore, the assertion that the time period for projection of future considerations 

should include a second operational period is out of scope for this EIS. 

Comment: Please state the amount of disruption to sheetflow of wetlands that the construction 

of units 6 & 7 will make including the plant site, all support facilities, all structures, all borrow pits 

(including rockmines) all fencing, all roads, all berms, all pipelines, all transmission lines, all 

basins, all parking lots, and all vehicle usage. (0022-2-19 [Reynolds, Laura])

Comment: The application does not provide a description of the specific upgrades FPL 

proposes to satisfy this condition. A complete and detailed description shall be provided. In 

addition, FPL shall describe what sheet flow improvements, if any, are proposed within 

transmission corridors for which mitigation lift is being sought. (0023-3-26 [LaFerrier, Marc])

Comment: Please resolve the apparent conflict between this condition and the stated intent to 

install roads in the transmission line corridors where no impediments to sheetflow currently 

exist, such as the portion of the West transmission corridor in Section 31 T57S R39E. 

(0023-3-27 [LaFerrier, Marc])

Comment: The construction of proposed access roads to the new reactor facility will also 

impact the Biscayne Bay Coastal Wetlands Project by altering sheet flow that is important to the 

success of the Project. (0025-2-17 [Kimball, Dan] [Lewis, Mark])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - The potential for adverse 

impacts to existing wetland slough systems, located within the vicinity of U.S. Highway 1, from 

new and/or improved fill roads associated with the West Preferred Corridor. East of U.S. 1, 

under the CERP Biscayne Bay Coastal Wetlands Project, additional surface water flows are to 

be diverted southward, through existing wetland slough systems in this area, to hydrate 

wetlands to the south, including wetlands in the SFWMD's Model Lands Basin area, and 

possibly the SFWMD's Southern Glades Basin area. The SFWMD is a partner with the USACE 

in this project. Even if culverts are installed, they are very poor at maintaining low head flows 

(i.e., sheetflow). West of U.S. 1, the corridor crosses the SFWMD's Southern Glades Save Our 

Rivers Parcel GR701-025. (0032-23 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - Regarding Water 

Conservation Area 3B, there are potential impacts related to the construction, operation, and 

maintenance of the proposed transmission line with respect to the SFWMD's legally mandated 

responsibilities for managing its lands within Water Conservation Area 3B. These lands were 

specifically acquired for water management-related purposes (i.e., flood control, water supply, 

conservation, reclamation, and other allied purposes) and are managed by the SFWMD and 

other agencies, including the U.S. Fish and Wildlife Service and the Florida Fish and Wildlife 

Conservation Commission, through special agreements for those purposes. 

(0032-26 [Golden, James])

Response: The review team's assessment of the impacts of building proposed Turkey Point 

Units 6 and 7 on the environment, including impacts on sheetflow associated with building 
Appendix D 

October 2016 D-43 NUREG–2176 

roads, transmission lines, and other linear features, will be presented in Chapter 4 of the EIS. 

Cumulative impacts will be addressed in Chapter 7. The EIS will include citations for 

documents used in its preparation. 

Comment: Simulation should cover, at a minimum, the area bounded by SW 344th St in the 

north, Old Card Sound Road in the west, and the coastline in the south and east. The EPASWMM and XP-SWMM are recommended models to simulate the variety of structures within 

the area, in order to obtain hydrographs and pollutographs at selected points. The model 

should also simulate contaminant transport and dilution effect. Event simulations should be run 

to obtain the conditions before and after the proposed development, including the new inflow 

and loads from the proposed Administrative/Training Buildings, Parking area, and Reclaimed 

Water Treatment Facility. (0023-1-13 [LaFerrier, Marc])

Response: This comment refers specifically to the SCA submitted to the State of Florida by 

FPL, but it indicates an interest in the potential impacts of the building of the proposed units on 

local and regional water supply and water quality. Modeling data provided by the applicant will 

be reviewed and evaluated in the course of the development of the assessment. The 

assessment of the impacts on water resources from building proposed Turkey Point Units 6 and 

7 will be presented in Chapter 4 of the EIS, based on information describing the affected 

environment in Chapter 2. 

Comment: Please provide drainage plans and associated calculations for the proposed access 

roads. (0023-2-20 [LaFerrier, Marc])

Comment: The mitigation plan proposes to discharge wastewater into the Model Lands and to 

seek mitigation credit for this discharge. Since the area proposed for discharge is a sawgrass 

wetland, pollutant levels, including but not limited to nutrient levels, would need to be very low 

(e.g. less than 10 ppb phosphorous). The application, however, provides insufficient information 

on the treatment methodology, the resulting quality, volume, and timing of the discharge. The 

applicant shall provide complete and detailed water quality information for the proposed 

discharge water that is sufficient to determine whether the water quality of the proposed 

discharge water is sufficient to prevent degradation of the receiving wetlands. 

(0023-3-43 [LaFerrier, Marc])

Comment: In order to have hydrologic improvements, with the exception of reclaimed water, 

water must be captured or diverted from other areas. Please describe in detail how the 

redirection of water will affect those donor areas, such as Biscayne Bay. Is there a loss of 

function from some areas associated with the diversion of water for the proposed hydrologic 

improvements? (0023-4-1 [LaFerrier, Marc])

Comment: [T]he application does not provide sufficient information to evaluate the impact of 

these discharges on water quality of adjacent surface. (0023-4-11 [LaFerrier, Marc])

Response: These comments refer specifically to the SCA submitted to the State of Florida by 

FPL, but they indicate an interest in the potential impacts of the operation of proposed Turkey 

Point Units 6 and 7 on water availability, water quality, and terrestrial ecology. The review 

team’s assessment of impacts on local and regional water resources and terrestrial ecology 
Appendix D 

NUREG–2176 D-44 October 2016 

from building the proposed units will be presented in Chapter 4 of the EIS. Impacts from 

operation of the proposed units will be presented in Chapter 5. Cumulative impacts will be 

addressed in Chapter 7 and plant effluent discharge alternatives in Chapter 9. 

Comment: To the extent that you are aware of any documents or reports by any federal, 

state, local or regional government agency, FPL or any of its employees or contractors that 

relate to adverse impacts of utilizing reclaimed water as supplied by M-D County to the 

Turkey Point FPL power station in the future, including any cost-benefit analyses please 

provide them. (0022-1-8 [Reynolds, Laura])

Comment: [T]he COL proposes the use of tertiary treated wastewater as the primary cooling 

water supply source for Units 6&7.] Biscayne Bay is designated an Outstanding Florida Water 

and as such has a no degradation standard. The use of tertiary treated wastewater for cooling 

water would indirectly introduce PPCPs, surfactants, biocides, and EDCs into southern 

Biscayne Bay that were not present at the time of designation. (0025-2-4 [Kimball, Dan] 

[Lewis, Mark])

Response: These comments refer to the impacts of using treated wastewater as the primary 

cooling water supply for proposed Turkey Point Units 6 and 7. The impacts of the proposed 

units on local and regional water resources, including impacts related to using reclaimed water 

on water quality in Biscayne Bay, will be presented in Chapter 5 of the EIS, based on 

information describing the affected environment in Chapter 2 and plant design and operations 

discussed in Chapter 3. The EIS will include citations for documents used in its preparation. 

Comment: A lot has changed since this facility was originally sited here. You are about to 

undertake an analysis of a proposal to place two nuclear reactors on the shores of a bay that is 

the subject of a major Federal multi-billion dollar restoration project. The nature of the impacts 

that this project will have; water consumption, wetland loss that is sort of off the charts in terms 

of modern wetland permitting in Southeast Florida; habitat loss; impacts to hydrology in the way 

water moves, are the types of impacts that that multi-billion dollar Federal project is trying to 

reverse. And so the notion of coming in and bringing about water use impacts, that are unlike 

anything else known in South Florida, and wetland impacts that are kind of off the charts, just 

fundamentally is a major problem and doesn't really add up. The exacerbation of things that 

one arm of the Federal Government is trying to fix, doesn't make sense in the modern world. 

(0002-6-1 [Grosso, Richard])

Comment: Will this project potentially interfere with the goals of the Biscayne Bay Coastal 

Wetlands Project (BBCW)? Please indicate how the applicant is coordinating with the BBCW 

team to ensure that the use of the radial collector wells will not hinder the success of the BBCW 

project. (0018-11 [Poole, Mary Ann])

Comment: The application predicts the potential for additional salinization throughout the area 

as a result of the project by drawing salty water landward via the radial collector wells and from 

deposition of salts as a result of cooling tower operations. In contrast, the CERP BBCW project 

seeks to reduce salinity levels in and adjacent to Biscayne Bay to restore more natural estuarine 

conditions. No documentation is provided to examine the specific impacts to the area from 

additional salinization generally and for CERP consistency specifically. A study is needed that 
Appendix D 

October 2016 D-45 NUREG–2176 

includes a salt budget and an examination of the cumulative effects of existing and proposed 

operations at Turkey Point including but not limited to the existing chloride plume created by the 

cooling canal system and the additional salts that would be added to the area as a result of the 

proposed project. The study shall also be sufficient to determine the extent to which the radial 

collector wells would capture, redirect, or otherwise affect groundwater from the existing plume 

emanating from FPL's Cooling Canal System. (0023-3-39 [LaFerrier, Marc])

Comment: Narrative description of the timing and the approval process of the FPL water 

management project and the Alternative "O" CERP project, to ensure that both can and will 

likely be accomplished. Analysis by FPL, with cooperation from the SFWMD, on whether the 

incorporation of the water management project into the CERP process will alter or jeopardize 

the potential approval and funding of the CERP project not provided. (0023-3-60 [LaFerrier, Marc])

Comment: The groundwater modeling is currently insufficient to effectively simulate impacts to 

the bay, or even to determine the percentage of fresh water from the aquifer, which would be 

removed from the ecosystem by the RCWs. Until it can be satisfactorily determined that the 

RCW system will not remove aquifer water, this plan appears to conflict with the CERP 

Biscayne Bay Coastal Wetlands project. (0025-2-15 [Kimball, Dan] [Lewis, Mark])

Comment: Construction of infrastructure associated with transmission lines and access roads 

in either corridor would result in the permanent filling of over 100 acres of wetlands. Direct and 

indirect effects of filling need to be included in the evaluation of impacts resulting from this 

project. In particular, installation of additional access roads in either corridor would create new 

barriers to flow in a critical portion of northeast Shark River Slough. This area is a focal point of 

Modified Water Deliveries (MWD) and CERP restoration projects designed to restore natural 

flow to that area. In addition, modification of the existing L-31 N levee in the western preferred 

corridor to provide access to proposed transmission lines would create an impediment to the 

natural north to south flow of water in the area. Access roads, even if culverted, will result in 

reduction of surface water flow critical to maintenance of ENP wetlands. This is in direct conflict 

with one of the critical components of hydrological restoration under CERP. The impacts of this 

flow reduction on park wetland resources and on MWD and CERP restoration projects that are 

underway or planned needs to be evaluated. (0025-3-35 [Kimball, Dan] [Lewis, Mark])

Comment: Construction, maintenance and vegetation management in either transmission line 

corridor identified by FPL would result in impacts to ENP water quality through soil disturbance 

and/or the introduction of chemical pesticides. These impacts need to be evaluated. 

(0025-3-36 [Kimball, Dan] [Lewis, Mark])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Radial Wells and Construction Dewatering Withdrawals at 

Power Plant Site - The potential for the proposed withdrawals to adversely impact the CERP 

Biscayne Bay Coastal Wetlands project. (0032-10 [Golden, James])

Comment: Proposed Project may result in adverse impacts to: The Biscayne Bay Coastal 

Wetlands CERP Project -This project will replace lost overland fresh water flow and partially 

compensate for the reduction in groundwater seepage by redistributing, through a spreader 

system, available surface water entering the area from regional canals. The goal of this project 
Appendix D 

NUREG–2176 D-46 October 2016 

is to improve the ecological health of Biscayne Bay (including freshwater wetlands, tidal creeks 

and near-shore habitat) by adjusting the quantity, quality, timing, and distribution of freshwater 

entering Biscayne Bay and Biscayne National Park. Redistribution of freshwater flow and the 

expansion and restoration of wetlands will help to restore or enhance freshwater wetlands, tidal 

wetlands, and near shore bay habitat. The project, located in southeastern Miami-Dade County, 

includes pump stations, spreader swales, stormwater treatment areas, flowways, levees, 

culverts, and backfilled canals. The project covers 13,600 acres along the L-31 E Canal. The 

purpose of the project is to capture, treat, and redistribute freshwater runoff from the watershed 

going into Biscayne Bay, creating more natural water deliveries and expanding the spatial 

extent and connectivity of coastal wetlands and improving recreational opportunities. 

(0032-2 [Golden, James])

Comment: Proposed Project may result in adverse impacts to: The L31 N (L-30) Seepage 

Management Pilot CERP Project -This project, located along a portion of the L-30 levee north of 

U.S. Highway 41 in Miami-Dade County, will help resolve critical uncertainties associated with 

seepage management, including the characterization of the Biscayne aquifer hydrodynamics, 

constructability in south Florida geology, reliability of materials and technologies, feasibility of 

implementing a seasonally flexible operating system, appropriateness of monitoring to evaluate 

effects on seepage, and cost and time requirements necessary for implementation. The 

recommended plan will test two structural seepage reduction technologies (steel sheet pile and 

slurry wall), and will test the ability to seasonally manage seepage flows through pumping 

operations with the use of extraction and injection wells. Field tests, seepage reports, and 

historical data independently show that this is one of the most transmissive parts of the 

Biscayne aquifer. (0032-3 [Golden, James])

Comment: Provide assurance that the proposed roadway improvements will be designed to be 

compatible with CERP Biscayne Bay Coastal Wetlands Project Alternative "O". The 

amendment does not demonstrate how the proposed roadway improvements will be designed 

to be compatible with CERP Biscayne Bay Coastal Wetlands Project Alternative O. Under 

Alternative O, additional surface water flow :(sheetflow) is to be diverted southward, through 

existing wetland slough systems, into environmentally sensitive lands located south of Palm 

Drive (S.W. 344th Street), generally between the District's L-31E Canal and U.S. Highway 1. 

Under this amendment, several new roadway improvements are proposed that could interfere 

with the proposed sheetflow. Prior, to adoption, the amendment should be revised to include 

policies, strategies, and commitments to ensure that the appropriate engineering analyses are 

conducted and any proposed drainage features, including culverts, be designed, sized, and 

spaced to handle existing and proposed flows. (0032-34 [Golden, James])

Comment: Proposed Project may result in adverse impacts to: The South Dade C-111 Project 

and Modified Water Delivery Project to Everglades National Park (Modwaters) -This project will 

modify the existing water management infrastructure to improve water deliveries to Everglades 

National Park (ENP). Changes are being made to Water Conservation Area 3A/3B levees and 

canals to redirect water flow into Northeast Shark River Slough in and around the proposed new 

Florida Power & Light (FPL) Turkey Point Units 6 & 7 transmission line corridors. Current water 

management actions focus on re-establishing sheet flow into ENP by removing barriers such as 

the Tamiami Trail road and replacing it with a bridge. Future water management changes will 

increase the volume of water introduced and distributed into Northeast Shark River Slough. 
Appendix D 

October 2016 D-47 NUREG–2176 

Additional changes are being implemented along the Lower C-1 11 Canal to promote 

rehydration of Taylor Slough and northern Florida Bay in the southern limits of ENP. A series of 

detention areas are being constructed west of the L31N Canal to provide storm water detention 

and create a hydrologic barrier between the managed canal levels and the Everglades marsh. 

Water levels will be managed at higher levels within the detention areas to create a positive 

hydrologic head and reduce seepage from ENP. (0032-4 [Golden, James])

Comment: Proposed Project may result in adverse impacts to: Decompartmentalization of 

Water Conservation Area 3A/3B -This is a CERP project and a companion to the South Dade 

C-1 11/Modwaters Project promoting removal of existing levees and canals impacting sheet flow 

into ENP. Future changes include removal of existing canals, levees, and structures separating 

WCA 3A/3B and ENP, such as removal of the Miami Canal within WCA 3A, removal of the 

L-67A/C levee segments, and additional bridging of Tamiami Trail together with the removal of 

the L-29 containment levee. (0032-5 [Golden, James])

Comment: In addition to the potential for significant adverse impacts to specific restoration 

projects, the SFWMD is concerned about the potential for significant adverse impacts that relate 

to its overall mission to manage the water resources of the State located within the SFWMD's 

geographic boundaries. (0032-6 [Golden, James])

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 4. Biscayne Bay Coastal Wetlands (BBCW). Please describe any potential 

conflicts this project may have with the restoration goals of BBCW. Please indicate how FPL 

and NRC are working with the BBCW team to ensure that any expansion at Turkey Point will not 

hinder the success of the BBCW project. (0033-12 [Croom, Miles])

Response: These comments refer to interactions between the proposed action and regional 

projects, including CERP projects. The review team will assess the impact of proposed Turkey 

Point Units 6 and 7 on local and regional water resources and aquatic and terrestrial ecology. 

Assessment of the impacts of building and operating the proposed units on water quality and 

ecological resources will be presented in Chapters 4 and 5 of the EIS, respectively. Cumulative 

impacts, including interactions with CERP and other restoration efforts, will be addressed in 

Chapter 7. 

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Additional Construction Impacts at Power Plant Site - The 

potential for adverse impacts to Biscayne Bay associated with the proposed barge canal 

dredging. (0032-13 [Golden, James])

Response: The impacts of the proposed action on hydrology and water quality in Biscayne 

Bay, specifically the impacts related to dredging of the barge canal (barge-turning basin and 

barge-unloading area), will be presented in Chapter 4 of the EIS. The impact assessment in 

Chapter 4 will be based on information describing the affected environment in Chapter 2 and 

plant design and operations discussed in Chapter 3. 

Comment: The NRC needs to acknowledge that this area is an extremely sensitive 

hydrological environment. The history of the Everglades and the current costly restoration 
Appendix D 

NUREG–2176 D-48 October 2016 

projects illustrate the long-term shortsightedness that has scarred Florida's waterways. 

(0001-14-6 [Hancock, Mandy])

Comment: The new reactors will require more fresh water for cooling and there's already a 

shortage of water in the natural system. So, although the comprehensive Everglades 

Restoration Plan plans to provide reused water to help restore Biscayne Bay, the two new 

reactors would require additional water as well. This plan puts Florida Power & Light 

development in competition with Everglades Restoration and we think restoration has had 

enough competition already. (0001-15-2 [Cornick, Lance])

Comment: The water use is massive. Biscayne Bay restoration is all about fixing the problem 

that we don't get enough fresh water into the bay anymore. So the notion that you would add 

this type of fresh water consumptive use right there at that same location, is incredibly troubling. 

We haven't figured out how we're going to get the amount of fresh water back into the bay that 

we need to make it work again. This water demand could absolutely preclude ever getting that 

done. (0002-6-2 [Grosso, Richard])

Comment: Sixty billion gallons of water is the last statistic that I heard that would be needed 

per day. That's way too much water. And I also heard that it would be warmer after use, going 

into the cooling and going back into our water. And just a small degree change can definitely 

affect all of our wetlands and things here. (0002-8-5 [O'Katy, Jessica])

Comment: [T]he new nuclear power plants will require more than ninety million gallons of fresh 

water a day to cool the reactors, causing severe problems to the already water restricted 

Southeast Florida. (0012-10 [Payne, Nkenga]) 

Comment: THERE IS NOT ENOUGH WATER IN THE AREA TO SUPPORT TP 6&7! ( 

0016-11 [White, Barry])

Comment: The required amounts of water needed to operate the reactors is beyond the 

capability of the water supply in South Florida. I am presently restricted from certain water use. 

What will be my future if these reactors are allowed to be built? How much potable water will be 

needed to support the doubling of the plant without the reactors? (0027-5 [Moses, Dorothy])

Response: The impacts of building and operating proposed Turkey Point Units 6 and 7 on 

consumptive water use and cooling water discharge for both local and regional water resources 

will be presented in Chapters 4 and 5 of the EIS. Cumulative water-use impacts will be 

addressed in Chapter 7 and cooling water alternatives in Chapter 9. 

Comment: Table 4.6-1 states that occasional surface water overflow/run-off from deep well 

injection wells would be directed to the Cooling Canal System. This would cause infiltration of 

wastewater constituents, including EPOCs, to the Biscayne Aquifer and subsequently to 

Biscayne Bay via subsurface flow. Wastewater migration to the bay would negatively impact the 

flora and fauna of the nearshore habitat due to the release of nutrient and microconstituents 

(i.e., EPOCs), which requires further consideration. (0025-3-15 [Kimball, Dan] [Lewis, Mark])

Response: Table 4.6-1 indicates “The deep injection wells and the required monitoring wells 

would be installed in accordance with an FDEP injection well permit and any local permit 
Appendix D 

October 2016 D-49 NUREG–2176 

requirements. During the construction of the injection wells and associated equipment, any 

surface water runoff would be directed to the cooling canals of the industrial wastewater facility.” 

During construction, wastewater constituents will not be present at the well sites and so would 

not be discharged to the Cooling Canal System. The impacts of constructing the injection wells 

will be presented in Chapter 4 of the EIS. 

D.1.8 Comments Concerning Hydrology – Groundwater 

Comment: As Mayor of the Village of Pinecrest and a former legislator, when I did serve in the 

House of Representative in the Florida Legislature, I had an opportunity to learn about and 

really come to grips with some of the potential for contamination and impact on the Floridan 

aquifer and the Biscayne aquifer, and I've been very attentive to that ever since, the concept of 

placing deep well injection. And back in the year 2001, there was an effort by the State and the 

Legislature and the Water Management Districts, to inject untreated storm water into the 

aquifer, and that actually passed the Florida Senate. We had to go back and undo it and we 

killed that legislation. I have been very involved in supporting the sustainability and the 

comprehensive Everglades Restoration Project ever since. (0001-21-2 [Lerner, Cindy])

Comment: And what will 70 million gallons of hot water do each day that they will have to get 

rid of? Where do you put 70 million gallons of water each day? You can't pump it down into the 

same place you're getting your cooling water from. If they got their cooling water from the 

sewage treatment plant then they would want to dump the hot water down into the boulder 

zone. Nobody has any idea what that would mean. We know that with sewage we pump way 

down deep into there offshore is now coming back up in Biscayne Bay and elsewhere. Also, 

that hot water is slightly radioactive. (0001-6-6 [Miller, Lloyd])

Comment: FPL proposes to inject 40 million gallons a day of waste in the boulder zone, a layer 

of the lower Floridan aquifer. And we are -- as the previous speaker mentioned, we are really 

unclear what the effects of this might be. (0001-7-10 [MacLaren, Kaitlin])

Comment: Please state the amount of waste seepage, by volume, into drinking water aquifers 

from deep well injection for units 6&7. (0022-2-13 [Reynolds, Laura])

Comment: To the extent that you are aware of any of any consent decrees or administrative 

orders or settlements concerning underground injection control wells in Florida, please provide 

them. (0022-2-8 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of operation of underground injection control wells in the South Florida area, 

please provide them. (0022-2-9 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of the deep well injection of wastes exceeding the capacity of the wastes 

reservoir, please provide them. (0022-4-6 [Reynolds, Laura])
Appendix D 

NUREG–2176 D-50 October 2016 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the maximum geographical extent of the deep well injected waste reservoir for the duration of 

the operating license, please provide them. (0022-4-7 [Reynolds, Laura])

Comment: The application does not address any proposed treatment of biocide additive in the 

cooling waters, and how biocides are removed before reinjection into the proposed deep wells. 

(0023-1-15 [LaFerrier, Marc])

Comment: Given the high evaporation rate, the concentrations of the analytes leaving the 

cooling tower system will be significantly higher that the concentration of those analytes entering 

the system. Considering that the final discharge point of the cooling system blowdown water is 

proposed to be the boulder zone (via underground injection wells), projected water quality 

characteristics for the blowdown must be provided. (0023-1-7 [LaFerrier, Marc])

Comment: The application proposes the discharges of industrial wastes from several sources 

to injection wells. No information was provided to ascertain compliance with the applicable 

discharge standards. No information was provided to show that no treatment is necessary or 

that contamination will not result from such discharges. (0023-1-9 [LaFerrier, Marc])

Comment: The primary source of cooling water is supposedly reclaimed water from MiamiDade Water & Sewer Authority. The daily flow rate for cooling is supposedly 60mgd. The EIS 

should confirm that the cooling water concentrate from the reclaimed water source will be 

disposed of in the boulder zone through a class one deep injection well. Similarly, if the 

Floridian Aquifer water is used for cooling, concentrated brine reject should be disposed of in 

the deep well injection system in the boulder zone. (0024-6 [Walker, Tom])

Comment: Current hydrologic knowledge regarding underground injection into the Boulder 

Zone suggests that the porosity and permeability in the Floridan can vary greatly depending on 

the location and formation. A history of dual zone groundwater monitoring results from the 

Miami-Dade County South District Wastewater Treatment Plant shows evidence of wastewater 

contaminant migration into the Upper Floridan. Upon the submittal of the pending USGS 

groundwater underground injection investigation for this region, it may be soon proven that the 

geology of the injection zone is incapable of confining the volume of injected sewage. These 

same concerns seem applicable to this project and the very large amount of discharged fluids 

intended to be injected. The Upper Floridan supplies make-up cooling water for existing Unit 5. 

Based on the above discussion, a similar breach of the Boulder Zone is possible and would 

compromise the water supply quality of Unit 5. (0025-3-21 [Kimball, Dan] [Lewis, Mark])

Comment: An even more frightening scenario is FPL's intention of using injection wells for 

radioactive wastewater. I do not believe this has ever been done before. Can the NRC 

guarantee these waters will not percolate back up into our water supply or into our coral reefs or 

marine environments or national parks or my backyard? Does anyone know with complete 

certainty where this radioactive waste may end up? (0027-7 [Moses, Dorothy])

Response: The impacts on the Biscayne and Floridan Aquifers from deep well injection to the 

Boulder Zone will be assessed by the team and discussed in Chapter 5 of the EIS. The 
Appendix D 

October 2016 D-51 NUREG–2176 

cumulative impacts of the proposed injection and other past, present, and reasonably 

foreseeable actions will be presented in Chapter 7. 

Comment: Secretary of Interior, Stewart Udall, took the federal court -- took FPL to federal 

court and forced them to construct an enormous cooling canal system, closed circuit cooling 

canal system. It's so big it can be seen from space. And it now contains super saline water and 

it has now penetrated and started to move in toward the farmlands and the tree farms. 

(0001-6-3 [Miller, Lloyd])

Comment: The Draft EIS should disclose/summarize results from all recent hydrologic studies 

and on-going assessments of the existing cooling canal system being utilized by Florida Power 

& Light Company's (FPL) for Turkey Point. EPA has met with National Park Service (NPS) 

officials from the Biscayne National Park regarding their concerns with the existing cooling canal 

system and its contribution to salt water intrusion in the South Miami-Dade area. NPS is 

concerned that the planned increased electric output from the existing units and the construction 

of two new nuclear reactors may exacerbate the salt water intrusion. This has raised concerns 

about adversely affecting local potable water supplies and the on-going Everglades restoration 

efforts. (0014-5 [Mueller, Heinz])

Comment: The Draft EIS should address concerns by agencies that the canal system has 

created a very warm and "hypersaline" water that sinks and spreads into the Biscayne Aquifer 

below. (0014-6 [Mueller, Heinz])

Comment: Water quality data summarized in Table 3.3.4-2 is not sufficient to fully assess the 

hydrologic characteristics of the cooling canal system. Cooling canal system is complex 

hydrology and includes interaction with Bay and groundwater (Section 3.3.2.1), and as such 

may have temporal and spatial variability. (0023-1-67 [LaFerrier, Marc])

Comment: Data indicate that migration of the cooling canal system water is impacting 

adjoining surface and groundwater in the vicinity of the cooling canal system. 

(0023-4-10 [LaFerrier, Marc])

Comment: [The Florida Keys Aqueduct Authority has] concerns for any potential impacts to our 

water supply. As the proposed project is significant in size and nature, conducting a 

comprehensive EIS to address key concerns and impacts to the natural resources is a 

necessary part of the evaluation process. It is our understanding that FPL's existing cooling 

water canal system, located west and south of the power plant contains high salinity 

concentrations. This high salinity is derived from evaporation of natural sea water discharged 

within these cooling water canals. As the highly concentrated seawater enters the groundwater 

along the bottom and the sides of the canals, the receiving groundwater becomes more saline. 

Without adequately operating system controls, this hydrogeological process can continue with a 

resultant salt load into a fresher groundwater aquifer. The higher saline groundwater with a 

higher specific gravity can increase the rate and amount of salt water intrusion from east to west 

in the Biscayne Aquifer and toward the FKAA wellfield. (0024-1 [Walker, Tom])

Response: The impacts of the cooling canals of the existing Turkey Point units on groundwater 

near the plant are in general outside the scope of the current EIS, which will assess the impact 
Appendix D 

NUREG–2176 D-52 October 2016 

of building and operating proposed Turkey Point Units 6 and 7. To the extent that the building 

and operation of the proposed units interact with the cooling canals, the building impacts will be 

presented in Chapter 4 and the operations impacts will be presented in Chapter 5 of the EIS. 

The cumulative impacts of the proposed units and the existing units, to the extent that they 

impact the same resources, will be presented in Chapter 7. 

Comment: We have an impact for water, we have an impact for saltwater intrusion. But don't 

we have that naturally? (0002-12-1 [McHugh, John])

Comment: When I moved out to my house -- I live west of Krome Avenue -- I could drink the 

water right out of my well, and that was fine for over 20 years. And then about 10 years ago 

they decide -- I used to have 4 houses to my block, okay, about 1 square mile. Now I have 

about 50 or 60 houses to my block. My water supply is not the same now. The quality of water 

is not the same as it was 10 years ago before those houses were built. See? And it's not any 

difference except now there's 40 or 50 more people in the area drawing off that same aquifer 

that there was only 4 before. (0002-12-6 [McHugh, John])

Comment: The agriculture out there uses massive amounts of water. Okay. When I lived out 

there for 20 years agriculture used massive amounts of water. We didn't have bad quality of 

water. Okay. The water was there, it was used, reached right under the ground. 

(0002-12-9 [McHugh, John])

Response: The impacts of saltwater intrusion on baseline water quality in the vicinity of the 

proposed plant will be discussed in Chapter 2 of the EIS. The impacts of the proposed action 

on water resources will be discussed in Chapters 4 and 5 for building and operating the units, 

respectively. Projects that have the potential to interact cumulatively with the operations of the 

proposed units and affect water resources will be discussed in Chapter 7. 

Comment: The Florida Keys primary water supply comes from a well field that is within ten 

miles of the proposed project. That's the well field itself. The actual aquifer that draws water 

into the well field is all around where we are. It's a very open, porous, surficial aquifer that's very 

vulnerable, very sensitive to wants and needs and with water chemistry in and about the land 

uses in South Dade County. Not just our well fields, there's well fields for Florida City, 

Homestead, and many other private and public systems in South Dade County that are within 

this region, some closer, some further away than ours, to the proposed project. 

(0002-3-1 [Walker, Tom])

Comment: Saltwater intrusion is a real issue to the Biscayne aquifer. We've seen the saltwater 

front line move over time inland. We have a huge number of monitoring wells as sentinels to 

help keep an eye and monitor the chemistries in the Biscayne aquifer. We have seen the 

intrusion exacerbated by existing operation at the existing FPL facility. One of the prior 

speakers mentioned high density saline water from the cooling canals. And that's been studied 

to some degree, however, the transparency of seeing the data is not as good as we would like 

from the applicant. (0002-3-2 [Walker, Tom])

Comment: We understand also that the proposal included potentially huge amounts of borrow 

excavation in and around the facility. Also, a huge amount of reclaimed water to be used as 
Appendix D 

October 2016 D-53 NUREG–2176 

cooling. Both of these elements are going to change potentially the hydrology and the water 

chemistry in and around the area. (0002-3-3 [Walker, Tom])

Comment: And the final point I'll make is about saltwater impacts. One aspect of Everglades 

and Biscayne Bay restoration is about ecology. The other aspect is about South Florida's 

drinking water supply. We've had major drinking water crises. We've had development 

moratoriums because of a lack of drinking water. Saltwater intrusion is a major problem. 

Saltwater intrusion, if it contaminates drinking water is not just an environmental problem, but it's 

a sound growth into the future development problem for South Florida. It's not a risk that a 

place like South Florida that already has major droughts and already has major drinking water 

shortages can afford to take. So, that's an unacceptable risk. The unacceptability of that risk 

ought to be considered strongly. (0002-6-9 [Grosso, Richard])

Comment: I'd like to ask that you please look at the protection of our wetlands and our national 

parks, and be careful of saltwater intrusion in our aquifers. It doesn't seem like that when we're 

going to be drilling for more fresh water that we need here, as well as filling acres, what we have 

wetland restorations for now. (0002-8-4 [O'Katy, Jessica])

Comment: Water resources issues associated with this project include protection of water 

quality and the Biscayne Aquifer. The Biscayne Aquifer is a sole source aquifer providing high 

quality drinking water throughout Miami-Dade and Monroe Counties. Protection of this aquifer 

from contamination by chlorides and sodium from saline water sources is key to ensuring the 

continued ability to deliver safe drinking water from public well fields in Florida City and 

Homestead as well as from the Florida Keys Aqueduct Authority Navy Wells facility. The EIS 

should include an assessment of the potential impact of the project on water resources in this 

area. (0015-2 [Espinosa, Carlos])

Comment: There is already salt water intrusion into the area to the west of TP. Not only is this 

a threat to the rock in the area, you cannot use rock for building if it has salt water in it, but to 

the water supply. TP 3&4 have already increased the salinity in the area; the cooling canals are 

twice the density of sea water. Any operation of TP 6&7 which will increase salinity could force 

the need for desalinization to produce potable water. (0016-8 [White, Barry])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of the Turkey Point FPL power station on groundwater (quality or quantity), 

please provide them. (0022-1-1 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of operation of the Turkey Point FPL power station on the Biscayne Aquifer, in 

the past, currently, and in the future, please provide them. (0022-1-21 [Reynolds, Laura])

Comment: Please state the amount of disruption to groundwater flow and the salt front that the 

construction of units 6&7 will make including the plant site, all support facilities, all structures, all 

borrow pits (including rockmines,) all fencing, all roads, all berms, all pipelines, all transmission 

lines, all basins, all parking lots, and all vehicle usage. (0022-2-20 [Reynolds, Laura])
Appendix D 

NUREG–2176 D-54 October 2016 

Comment: Please state the worst case scenario and the worst timeline projection, as a result 

of hydrologic changes from units 6&7 for salt water intrusion affecting the municipal wellfields of 

Miami- Dade County, the City of Homestead, the City of Florida City, the Florida Keys Aqueduct 

Authority, and private well users. (0022-3-2 [Reynolds, Laura])

Comment: Please state what protective measures will be taken to prevent salt water intrusion, 

as a result of hydrologic changes from units 6&7, to the municipal wellfields of Miami-Dade 

County, the City of Homestead, the City of Florida City, the Florida Keys Aqueduct Authority, 

and private well users. (0022-3-3 [Reynolds, Laura])

Comment: [T]he effect that the proposed facility would have on surface and groundwater 

quality, and groundwater table elevation within the C111 Basin (Model Land Area). 

Furthermore, any model used for evaluation of this project should be able to predict changes, if 

any, in the contaminant concentrations; in the water table elevations; and in the salinity wedge 

movement under different scenarios (baseline and post-construction conditions, for a wet, dry, 

and average year, etc). Models should combine groundwater with surface water and 

contaminant transport, and shall include the effect of the difference in densities between salt 

and fresh water. In addition, the area in the model should be large enough to avoid any 

boundary-induced bias; boundary conditions could be taken from South Florida Water 

Management District regional models. EPA authorized models, such as MODFLOW, 

MODPATH, and FEMWATER should be considered for use in this study. Another possible 

model would be the FEFLOW, which combines the groundwater contaminant transport 

(MODFLOW and MODPATH capabilities) with the two density fluids wedge salinity difference 

(FEMWATER capability). (0023-1-14 [LaFerrier, Marc])

Comment: [A] DERM approved hydrologic study and its results shall be provided that 

evaluates all impacts to surface and groundwater. This study should include consideration of 

seasonal differences in groundwater flow cited in Section 3.3.3.2 and determine the extent to 

which these differences are due to current operations at Turkey Point. 

(0023-3-47 [LaFerrier, Marc])

Comment: The FKAA requests that additional ground water modeling and monitoring be 

presented at the current salt/fresh water interface of the Biscayne Aquifer. As you see in the 

attached ground water monitoring plan, a trend has been shown and interface presented in 

collaboration with the USGS and Miami-Dade County to demonstrate the current interface 

location and its movement. For the EIS, modeling of potential changes to the interface position 

of this salt/fresh interface resulting from the proposed impacts from the construction and 

operation of the facility is requested. (0024-3 [Walker, Tom])

Comment: A robust, peer-reviewed hydrologic modeling analysis is essential to fully 

incorporate regional and site specific conditions in the vicinity of Turkey Point. The Biscayne 

Aquifer has a unique lithology and consists of a karst substrate with very high transmissivity. 

This surficial aquifer is hydraulically connected to nearby man-made surface water bodies, 

which has a profound impact on model construction. FPL's current groundwater model fails to 

simulate actual or planned conditions that include: seasonal and temporal variability, 

hypersaline plume migration, Biscayne Aquifer heterogeneity, and CERP project 
Appendix D 

October 2016 D-55 NUREG–2176 

implementation. NPS does not believe the COL sufficiently analyzes or evaluates these 

hydrological and estuarine issues. (0025-2-1 [Kimball, Dan] [Lewis, Mark])

Comment: Given the sensitive designation of the adjacent surface water body, Biscayne 

National Park, a horizontal pilot test, including a tracer study, should be considered as a critical 

design feature and would be more representative of actual full-scale RCW operation than a 

limited scope vertical pump test. (0025-3-1 [Kimball, Dan] [Lewis, Mark])

Comment: The new hypersaline plume delineation and hydrogeologic data collected as part of 

the well drilling and logging for the Uprate Project for Turkey Point Units 3 & 4 should be 

incorporated in the groundwater modeling and planning for evaluation of the effects of the 

RCWs. (0025-3-10 [Kimball, Dan] [Lewis, Mark])

Comment: The groundwater model should reflect implementation of CERP project features. 

(0025-3-11 [Kimball, Dan] [Lewis, Mark])

Comment: The Biscayne Aquifer is an unconfined surficial aquifer that has a fragile karst 

macroporosity substrate. A comprehensive geological survey should be performed for the 

proposed locations of the RCWs (Turkey Point peninsula) to identify voids or cavities in the 

aquifer substrate. Soil borings that were performed as part of the 2009 pump test are not 

aerially sufficient to represent a known dual porosity karst limestone aquifer. 

(0025-3-12 [Kimball, Dan] [Lewis, Mark])

Comment: Contingency plans should be established should a karst fracture occur during the 

construction or operation of the RCWs. (0025-3-13 [Kimball, Dan] [Lewis, Mark])

Comment: Even based on the rather dubious groundwater modeling provided, FPL is 

proposing to remove 8% of the total withdrawal from the aquifer, which equals approximately 

10 million gallons of groundwater daily. Pursuant to the Resolution (No. Z-56-07, conditions 4 & 

5) of the Board of County Commissioners of Miami-Dade County, FPL shall not apply for any 

water withdrawals from the Biscayne Aquifer as a source of cooling water for the proposed 

facilities, and shall use reclaimed or reuse water to the maximum extent possible. This 

consumptive water use conflict must be resolved. (0025-3-14 [Kimball, Dan] [Lewis, Mark])

Comment: The effects of dewatering on the Biscayne Aquifer (e.g., hypersalinity plume 

migration, salt water intrusion, etc.) during plant construction were based on the dubious current 

model, and warrants further evaluation. (0025-3-16 [Kimball, Dan] [Lewis, Mark])

Comment: Drilling through karst limestone can cause a bay bottom collapse or a cavity could 

be encountered that would be significantly closer to the surface than anticipated. A structural 

collapse due to macroporosity features of the Biscayne Aquifer (i.e., dual porosity) or drilling 

through existing touching-vug preferential flow zones or large karst features would alter the 

potential velocity of flow through the RCW. Flow in this case would be substantially higher than 

anticipated. These types of macrokarst features have been found in drilling the wells for the 

Units 3 & 4 Uprate project, and should be reflected in the groundwater model. 

(0025-3-2 [Kimball, Dan] [Lewis, Mark])
Appendix D 

NUREG–2176 D-56 October 2016 

Comment: The groundwater model (FSAR Section 2.4-12 Appendix 2CC) utilizes a constant 

density groundwater model with a reference value of seawater. Average salinity values are not 

appropriate since Biscayne Bay is an estuarine environment with seasonal salinity variability, 

which is not equivalent to an ocean salinity pattern. In addition, shallow groundwater salinity 

observed during the 2009 pump test in MW-I SS (20 avg psu) is not representative of seawater. 

Also, the groundwater in the vicinity of the Industrial Waste Facility exhibits hypersaline 

concentrations (68 avg psu). A groundwater salinity range of 48 psu on average is not 

indicative of a constant density groundwater profile. The constant density assumption cannot 

adequately determine the effects of the hypersaline plume eastern migration and bay salinity 

impacts due to the operation of the RCWs and dewatering activities. (0025-3-3 [Kimball, Dan] 

[Lewis, Mark])

Comment: A coupled surface water and groundwater hydrologic model, including a separate 

solute transport module, is necessary to fully evaluate all the associated impacts to Biscayne 

Bay. (0025-3-4 [Kimball, Dan] [Lewis, Mark])

Comment: The model input parameters (e.g., hydraulic conductivity, boundary inflow values, 

etc.) should be based on site specific conditions and data, when available, and be consistent 

with the calibrated results. Please note that the model calibration results in Table 2CC-205 of 

the COL, FSAR, Part 2, do not correspond to the calibration results provided in the State of 

Florida SCA. This discrepancy between the two applications should be rectified. Furthermore, 

the hydraulic conductivities listed in Table 2CC-205 for the different stratigraphic units of the 

aquifer do not appear to correspond to site-specific hydraulic conductivity values obtained from 

on-site pump tests nor published values. This flaw seriously affects the results and validity of 

the groundwater model. (0025-3-5 [Kimball, Dan] [Lewis, Mark])

Comment: The margin of error associated with the groundwater model simulation results 

should be provided. This information is necessary to ascertain the value of the model and how 

realistic the model output is. 5. Seasonal variability (i.e., rainfall, water levels, surface water 

flow, salinity, etc.) is inherent to South Florida and cannot be sufficiently reflected in a steady 

state model. (0025-3-6 [Kimball, Dan] [Lewis, Mark])

Comment: There are significant temporal differences between the cooling canals, Biscayne 

Aquifer, and the bay that will affect the water source pathway for the RCWs, which cannot be 

evaluated with a constant density, steady state model. (0025-3-7 [Kimball, Dan] [Lewis, Mark])

Comment: An equivalent porous media value was utilized for the groundwater model, which 

does not reflect the Biscayne Aquifer. The Biscayne Aquifer is defined as a heterogeneous 

aquifer with documented dual porosity and preferential flow pathways. (0025-3-8 [Kimball, Dan] 

[Lewis, Mark])

Comment: Should a preferential subsurface flow pathway be encountered through an RCW 

lateral, the water source intake will originate from the flow pathway of least resistance. This 

scenario should be accounted for in the groundwater modeling. (0025-3-9 [Kimball, Dan] 

[Lewis, Mark])
Appendix D 

October 2016 D-57 NUREG–2176 

Comment: Salt water intrusion is already a problem on our aquifer, anymore rock mining and 

water usage will cause further degradation of our fresh water supply. (0027-6 [Moses, Dorothy])

Comment: Turkey Point is hastening saltwater intrusion into South Miami-Dade well fields that 

supply water to our nearby communities. (0031-7 [De Villiers, Elena])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Radial Wells and Construction Dewatering Withdrawals at 

Power Plant Site - The potential for adverse impacts to regional water resources, including 

public water supply wellfields, Biscayne National Park, the Biscayne Bay Aquatic Preserve, and 

the Florida Keys National Marine Sanctuary from induced seepage from the Turkey Point 

cooling canal system as a result of cumulative impacts, including additional loading from 

construction dewatering/wastewater discharges and runoff from stored muck, and reduced head 

in the vicinity of the power block construction dewatering withdrawals and the radial well 

withdrawals. The unlined cooling canal system contains hypersaline water overlying the highly 

permeable Biscayne Aquifer. The salinity of cooling canal system water is significantly greater 

than natural groundwater salinity in the area and the waters within adjacent Biscayne Bay; 

therefore, the presence of density driven seepage upgradient (to the west) and downgradient (to 

the east and south) is likely. Monitoring wells up to approximately three miles west of the 

cooling canal system have encountered groundwater with chemical constituents indicative of 

cooling canal system water, including hypersalinity and/or tritium. Constituents within the 

cooling canal system that have or may have the potential to degrade water resources include 

hypersaline water, radiological isotopes, nutrients, or other compounds that may be discharged 

into the cooling canal system from plant operations and/or muck storage adjacent to the cooling 

canal system. (0032-11 [Golden, James])

Comment: Ground Water Modeling Summary - Conceptualization and Configuration: The 

entire model domain is assumed to be constant density and saline. Both of these assumptions 

are inconsistent with other submitted documentation. The simulation bounds of the model are 

neither all saline nor are they of the same density. FPL has asserted that the assumption is 

valid for the type of analyses (pump induced drawdown of flux) conducted. While this may be 

possible in the narrowest interpretation, it is likely that impacts of density dependent flow or 

temperature induced buoyancy may dominate in some areas; however, the modeling provided 

does not afford the SFWMD or FPL the opportunity to examine these situations. Also, it is 

unusual for a system that is made up of fresh, brackish, salt and hyper-saline water to be 

generically represented as sea water. While we understand an equivalent fresh water head was 

used, the impacts of this representation on gradients, stage (heads), simulated drawdown, and 

flows, as well as conclusions derived from these, need to be further explored and justified. 

(0032-29 [Golden, James])

Comment: Ground Water Modeling Summary - Boundary Conditions: By utilizing a steady 

state simulation, the impact of selected boundary conditions will propagate over the entire 

model. By definition, a steady state is reached when all hydrologic drivers, including those 

specified at the boundaries, reach equilibrium. This assumption makes the specification of the 

model boundaries, such as head in the constant head cells that represent Biscayne Bay, very 

crucial. It is understood that for permitting purposes, non-exact simulations may be acceptable, 

if they are conservatively estimated; however, a non-conservative estimate (e.g., the water level 
Appendix D 

NUREG–2176 D-58 October 2016 

in Biscayne Bay) could result in under-estimation or over-estimation of pumping rate necessary 

to achieve necessary drawdown during dewatering. Similarly, a non-conservatively selected 

stage in Biscayne Bay could overestimate the contribution of this boundary (source) to the radial 

collection well system. It is typical in these scenarios for extensive sensitivity analyses to be 

performed to establish the sensitivity of the outcome or conclusions, to erroneous or nonconservatively specified boundary conditions. FPL has applied an average value to the 

boundary representing Biscayne Bay. This may mask tidal or seasonal trends and is unlikely to 

represent the critical condition for dewatering or assessing the impacts of dewatering. 

(0032-30 [Golden, James])

Comment: Ground Water Modeling Summary - Parameterization: In selecting model 

parameters and applying them to the model cells, FPL has used a homogeneous representation 

of aquifer parameters in a highly heterogeneous aquifer system. This representation is, along 

with some unusual layering in the model construct, suspect, and must be tested to ensure that it 

does not negate conclusions drawn from the model. Specific concerns include the 

representation of the vertical hydraulic conductivity of the top two layers in the model (1 to 

1 ratio for Kh to Kv), the representations of those layers in locations where canals and other 

surface features intersect the conceptual (or physical) tops of the model layers, as well as the 

representation of the vertical connectivity in layers that were split for predictive simulations 

following the calibration. It is important for FPL to demonstrate that the conclusions and 

determinations based on modeling remain unchanged, with more correct representation of 

model parameters. (0032-31 [Golden, James])

Comment: Ground Water Modeling Summary - Calibration: The model was calibrated to the 

results of on-site pump tests (quantitative) and to regional groundwater gradients and flow 

directions (qualitative). Both calibrations were based on steady state simulations. FPL justified 

these simulations by the rapid response of the system to the volumes extracted during the pump 

test. This was further justified by the intent to apply the tools also in steady state. While these 

justifications are understood, the calibration remains insufficient and does not represent 

stresses to the system similar in magnitude to the intended applications. In addition, the 

conditions used for calibration do not demonstrate the impact of the effect of boundary 

conditions on the simulation results. Lastly, the model does not include important on-site 

operations or features present during the pump test that could contribute to the observed data to 

which the model is calibrated. The foregoing notwithstanding, a review of the calibration results 

presented show a number of situations where multiple monitoring wells show exactly the same, 

response in the model while they vary in the measured data. This may be suggestive of 

impacts of a specified boundary or inadequately tuned model parameter. If the variability that is 

missing is important to the required outcome from the model, then the model may not be 

adequately calibrated for use. (0032-32 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: The adequacy of the ground water modeling submitted by 

FPL. (0032-7 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Radial Wells and Construction Dewatering Withdrawals at 

Power Plant Site - The potential for the proposed withdrawals to exacerbate saline water 
Appendix D 

October 2016 D-59 NUREG–2176 

intrusion and ground water contamination due to the existence of preferential flow paths within 

the Biscayne aquifer. (0032-8 [Golden, James])

Response: The impacts of the proposed action on water resources, specifically the potential 

impacts to water availability and water quality in the Biscayne Aquifer, will be assessed by the 

review team and presented in Chapters 4 and 5 of the EIS for building and operating proposed 

Turkey Point Units 6 and 7, respectively. Modeling data provided by the applicant will be 

reviewed and evaluated in the course of developing this assessment. Cumulative water-use 

and water-quality impacts will be addressed in Chapter 7. 

Comment: FPL, just last year, negotiated a new groundwater monitoring plan with the South 

Florida Water Management District. However, there were compliance questions from the initial 

groundwater monitoring plan that had been issued 20 years ago, and there was, I think, a lack 

of some transparency of looking at the groundwater data. So I would request that that data be 

sought and included in your evaluation in the scoping process. (0002-3-5 [Walker, Tom])

Comment: We understand that the FPL has negotiated a new ground water monitoring 

program with the South Florida Management District (SFWMD.) Unfortunately, the prior ground 

water monitoring plan has been questioned and from what we have understood, had 

compliance issues which were never quite resolved. Subsequently, a new monitoring plan was 

laid out and approved by the SFWMD; yet, much of the historic information may provide 

important trending information which would be helpful for the EIS to evaluate. We request that 

the NRC obtain the previous ground water monitoring information relative to these cooling 

canals and analyze their past and present impacts to the ground water in the adjacent aquifer. 

(0024-2 [Walker, Tom])

Response: The environmental monitoring data collected at the existing units for the current 

baseline water resources in the affected environment, including water quality and quantity, will 

be discussed in Chapter 2 of the EIS. Chapters 4 and 5 will include descriptions of 

environmental monitoring to be conducted at the units during building and operating, 

respectively. Cumulative impacts will be assessed in Chapter 7. The EIS will include citations 

for documents used in its preparation. 

Comment: Please state the distance between the water management feature(s) and the salt 

front at the land's surface and the distance between the water management feature(s) and the 

salt front at the base of the Biscayne Aquifer. (0022-3-8 [Reynolds, Laura])

Comment: Please publish a vertical profile of the land showing 1. the surface of the water 

management feature(s), 2. the depth of the water management feature(s), 3. the location of the 

current salt front at the land surface, and 4. the location of the current salt front at the base of 

the Biscayne Aquifer. (0022-3-9 [Reynolds, Laura])

Response: These comments refer to the distance between proposed Turkey Point Units 6 and 

7s water-management feature and the salinity intrusion front in the Biscayne Aquifer. A 

description of the affected environment, including local groundwater flow, water quality, and 

quantity, will be presented in Chapter 2 of the EIS. The plant layout, including the detailed 

locations of facilities and design specifications for the units, will be provided in Chapter 3. 
Appendix D 

NUREG–2176 D-60 October 2016 

Comment: Miami-Dade County has previously provided the U.S. Nuclear Regulatory 

Commission with a copy of our comments on the State of Florida Site Certification Application 

for the Turkey Point Power Plant. The County would like to point out one discrepancy between 

the state and federal applications, the Florida Power & Light owned fill source was removed 

from the state application but remains part of the federal application. The proposed fill source 

may adversely impact groundwater, destroy wetlands and advance salt water intrusion closer to 

wellfields. Additional details on these concerns are provided in the attached table summarizing 

our initial comments on the state application. This table, as well as, the documents previously 

submitted to the NRC should be considered as part of the record for the scoping process. 

(0023-1-1 [LaFerrier, Marc])

Response: The NRC process is to review the COL application and prepare an EIS based on 

the actions proposed in the application. Information to be used during the review will include 

documents obtained from State and Federal agencies, including the SCA to the extent 

necessary to characterize the Turkey Point site. The FPL-owned fill source remains in the COL 

at this time and a review of the environmental impacts of obtaining fill material will be presented 

in Chapter 4 of the EIS. 

Comment: The application proposes to dewater up to 26 MGD of groundwater by discharging 

it to the cooling canals. Pursuant to Condition No. 15 of the Unusual Use Approval Resolution 

Z-56-07, a DERM approved hydrologic study is required. The study results are required to 

evaluate all impacts to surface and groundwater, including but not limited to all dewatering 

activities. The hydrologic study should include, but not be limited to providing data and 

modeling to show how the existing groundwater plume under the Cooling Canal System would 

respond to the dewatering activities. (0023-1-2 [LaFerrier, Marc])

Comment: Sufficient information is not provided to make a determination of dewatering 

impacts. Please provide a description of all required dewatering activities and the techniques 

that will be used to ensure that all surface and groundwater quality standards will be met. 

(0023-1-3 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of the proposed units on water quality and 

hydrology from the discharge of dewatering flows to the cooling-canal system during plant 

construction. The review team will assess the impact of proposed Turkey Point Units 6 and 7s 

dewatering at the site on water resources. The dewatering effluent produced by the proposed 

units will be described in Chapter 3 of the EIS. The impacts of building the proposed units on 

water resources will be presented in Chapter 4. Cumulative impacts will be addressed in 

Chapter 7. Modeling data provided by the applicant will be technically evaluated in the course 

of developing the EIS. 

Comment: Disposal of the facility's wastewater is proposed via deep well injection into the 

boulder zone. The application does not include an evaluation of the technical feasibility for 

reuse of the wastewater discharge for the benefit of the Biscayne Bay Coastal Wetlands Project 

as required pursuant to Z-56-07. (0023-3-38 [LaFerrier, Marc])
Appendix D 

October 2016 D-61 NUREG–2176 

Response: This comment refers to the SCA submitted to the State of Florida by FPL, but it 

indicates an interest in alternative uses of blowdown water from the proposed units. 

Alternatives to deep-well injection for plant effluent discharges will be described in Chapter 9 of 

the EIS. 

Comment: [T]he application does not provide sufficient detail on what standard of reclaimed 

water quality is required. This information is necessary to evaluate the application 

(0023-1-29 [LaFerrier, Marc])

Response: This comment refers to the SCA submitted to the State of Florida by FPL, but it 

indicates an interest in the quality of reclaimed water to be used as cooling water at the 

proposed units. The water quality of the reclaimed water will be described in Chapter 3 of the 

EIS. 

Comment: Conditions outlined in Zoning Resolution Z-56-07 must be met to achieve land 

use/zoning consistency. This resolution stated that no water will be withdrawn from the 

Biscayne Aquifer (Condition 4) and that a hydrologic study (Condition 15) will be performed. 

The radial well component does not demonstrate consistency with these two conditions; 

therefore this component will be subject to a land use/zoning consistency determination. 

(0023-1-31 [LaFerrier, Marc])

Comment: Selection of potential locations, idealized designs, number of wells, and even the 

pipe sizes of the radial lines of the collector wells should be based on hydrogeologic data within 

the areas Biscayne Bay that the wells will tap. (0023-1-32 [LaFerrier, Marc])

Comment: Site specific aquifer characteristics have not been made available. 

(0023-1-33 [LaFerrier, Marc])

Comment: Lithologic descriptions are contradictory. The observations from the site subsurface 

investigation (Section 3.3.2.2) contradict expectations that almost all the water withdrawn by the 

radial collector wells would be recharged from the Bay (Section 3.3.4.1). Therefore additional 

information is necessary to evaluate this aspect of the proposal. (0023-1-34 [LaFerrier, Marc])

Comment: [D]etermine the impact of the radial collector well system on the fate and transport 

of the groundwater plume associated with the cooling canal system, the potential for and effect 

of the recharge of the radial collector well system through horizontal preferential flow zones in 

the aquifer, the impact of the radial collector well system on salt intrusion. 

(0023-1-35 [LaFerrier, Marc])

Comment: [N]o information was found in the application discussing potential effects of inducing 

ground water flow towards the proposed withdrawal wells. (0023-1-38 [LaFerrier, Marc])

Comment: Neither preferential vertical nor horizontal stratigraphic flow directions have been 

established. Vertical hydraulic conductivity data is not presented in the application, but it is 

needed to properly evaluate how the horizontal screens installed in the Fort Thompson 

Formation 30 to 35 feet below the shallow bay bottom are expected to preferentially draw water 

from the less transmissive Miami Limestone above instead of from the much more transmissive 

Fort Thompson. (0023-1-39 [LaFerrier, Marc])
Appendix D 

NUREG–2176 D-62 October 2016 

Comment: Cones of influence are not defined and aquifer pump-test data has not been 

presented to properly evaluate hydrologic conditions under which the collector wells would be 

operated. Neither has there been any data presented to indicate the potential cone of 

depression that pumping more than 120 million gallons a day from a wellfield located along the 

shoreline would have on the movement of the salt front line. (0023-1-40 [LaFerrier, Marc])

Comment: The applicant has not provided sufficient geologic, hydrologic and water quality 

data to evaluate the application. (0023-1-41 [LaFerrier, Marc])

Comment: The applicant has not provided sufficient information to evaluate the mixing 

chamber model that was used to project impacts from the radial collector wells. 

(0023-1-42 [LaFerrier, Marc])

Comment: Adequate hydrogeologic data have not been presented and the application does 

not include sufficient information to determine whether the proposed withdrawals from the radial 

collector wells would meet the requirements of Section 24-43.2 Miami-Dade County Code. 

Selection of potential locations, idealized designs, number of wells, and even the pipe sizes of 

the radial lines of the collector wells should be based on hydrogeologic data within the areas 

under Biscayne Bay that the wells would tap. (0023-1-44 [LaFerrier, Marc])

Comment: Please provide adequate analysis in support of the conclusion made that the 

Biscayne Aquifer is not affected by the Radial Collector wells. A fully three dimensional 

mathematical model should be used to determine the boundary conditions (influence cones) of 

the proposed radial collector well. (0023-1-47 [LaFerrier, Marc])

Comment: Application does not adequately demonstrate that the proposed radial collector 

wells do not violate Condition 4 of Z-56-07 which prohibits withdrawal from the Biscayne 

Aquifer. (0023-1-66 [LaFerrier, Marc])

Comment: Data presented for Groundwater Impact assessment is not sufficient. Visual 

MODFLOW data files are not provided for assessment. Not enough data provided to assess 

statement that radial collector wells are substratum collectors of saltwater that will recharge from 

below Biscayne Bay. The applicant states that almost all the water withdrawn by the proposed 

radial collectors will be recharged from the Bay; however, no data to support this statement is 

provided in the application. The applicant shall provide all relevant data relating to recharge of 

the Biscayne Aquifer that would be induced by operation of the radial collectors. Pursuant to 

Condition No. 4 of the Unusual Use approved but he BCC through resolution Z-56-07, FPL shall 

not apply for any withdrawals from the Biscayne Aquifer as a source of cooling water for the 

proposed facilities. (0023-1-68 [LaFerrier, Marc])

Comment: The radial wells are located so as to draw from the easterly groundwater flow. 

Please resolve the apparent conflict between the location of the wells and the water from which 

they are drawing and Condition 4 of Z-56-07, which prohibits withdrawal from the Biscayne 

Aquifer. (0023-1-70 [LaFerrier, Marc])

Comment: Condition 5 of Z-56-07 requires FPL to analyze the potential use of marine water as 

a secondary source of cooling water. Under this scenario, a directional bore would be used to 
Appendix D 

October 2016 D-63 NUREG–2176 

construct a pipeline under the Florida Keys National Marine Sanctuary or under Biscayne 

National Park in order to obtain salt water from the ocean with limited or no permanent impacts 

to benthic resources. Provide a detailed analysis that documents the reasons why this potential 

secondary source of cooling water was not selected. (0023-3-40 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in impacts on the Biscayne Aquifer below Biscayne Bay from the 

withdrawal of cooling water using radial collector wells (RCW) at proposed Turkey Point Units 6 

and 7. The impacts of these units consumptive use of water on local and regional water 

resources, including the Biscayne Aquifer, will be presented in Chapters 4 and 5 of the EIS for 

building and operating, respectively. Cumulative water-use impacts will be addressed in 

Chapter 7 and cooling-water alternatives in Chapter 9. 

Comment: The application does not provide information on how the water management project 

would operate, the water source for the feature, any related infrastructure, projected water 

quality of the completed feature, or information on best technology regarding a liner or other 

hydrologic isolation from surrounding ground and surface waters, the hydrologic impact of the 

feature on adjoining areas. (0023-3-13 [LaFerrier, Marc])

Response: Available information about the water-management feature will be provided in 

Chapter 3 of the EIS. The impacts of the water-management feature on water resources will be 

presented in Chapters 4 and 5 for building and operation, respectively, based on information 

about the affected environment provided in Chapter 2. Cumulative impacts will be presented in 

Chapter 7. 

Comment: And that's what they're trying to do on a couple of the different designs, is to pump 

the water back down into the ground. There have got to be some options. We have too much 

knowledge and too much in our industry to overcome these minor problems. 

(0002-12-10 [McHugh, John])

Response: The comment refers to the discharge of effluent from the plant, specifically the 

effluent sourced from reclaimed water to be used as cooling water at proposed Turkey Point 

Units 6 and 7. The proposed units effluent discharge locations, quantity, and quality will be 

described in Chapter 3 of the EIS. Alternative discharge locations will be discussed in 

Chapter 9. 

Comment: FPL recently proposed a restriction on using the RCWs to 90 days per year; this 

proposed restriction is not mentioned in the COLA. Such inconsistencies between the two 

separate applications should be resolved and the State of Florida SCA and NRC COL 

applications should be fairly uniform. (0025-1-5 [Kimball, Dan] [Lewis, Mark])

Response: The NRC process is to review the COL application, including revisions provided by 

the applicant, and prepare an EIS based on the actions proposed in the application. Information 

to be used during the review will include documents obtained from State and Federal agencies, 

including the SCA, to the extent necessary to characterize the Turkey Point site. A review of the 

environmental impacts of using RCWs to obtain cooling water will be presented in Chapter 5 of 

the EIS. 
Appendix D 

NUREG–2176 D-64 October 2016 

Comment: To add insult to injury, these 2 dangerous nuclear plants are proposed to be 

over/around the only natural aquifer we have that provides clean water to millions of people! 

(0028-2 [DiNuzzo, Laura])

Response: The impacts of building and operating proposed Turkey Point Units 6 and 7 on the 

sustainability of local and regional water resources will be presented in Chapters 4 and 5 of the 

EIS, respectively. Cumulative water-use impacts will be addressed in Chapter 7. 

Comment: The CEIS should include, at minimum, an analysis of the water quality for the 

source water for each dewatering project, including radionuclides such as tritium. 

(0023-1-4 [LaFerrier, Marc])

Response: The CWA designated the Environmental Protection Agency (EPA) as the Federal 

agency with general responsibility for effluent discharges to the nation’s waters. In Florida, the 

EPA has delegated this responsibility to the Florida Department of Environmental Protection 

(FDEP). Therefore, in Florida, the FDEP is the primary regulatory authority over water quality. 

While the NRC only regulates radiological effluents, the NRC does have the responsibility under 

NEPA to assess and disclose the expected impacts of the proposed action on water quality. 

The assessment of the radiological and nonradiological impacts on water quality from the 

operation of proposed Turkey Point Units 6 and 7 will be presented in Chapter 5 of the EIS. 

Comment: The proposed radial collector wells would be located within or adjacent to a 

groundwater plume emanating from FPL's Cooling Canal System, which contains high levels of 

chlorides. It also contains tritium, which may be used as a tracer. In addition, portions of this 

plume contain heated water, although underground directional travel of the heated water has 

not been established. No information regarding the delineation of this plume is contained within 

the application and the extent to which this plume would be affected by the proposed 

groundwater withdrawals is not documented. (0023-1-37 [LaFerrier, Marc])

Response: The impacts of the RCWs with respect to building and operating proposed Turkey 

Point Units 6 and 7 on Biscayne Bay and adjacent lands are part of the overall EIS analysis. 

The results of the analysis of impacts of proposed Turkey Point Units 6 and 7 operations on 

water quality, ecology, and aesthetics will be presented in Chapter 5 of the EIS, and the results 

of cumulative impact analyses will be presented in Chapter 7. 

Comment: The proposed project requires a significant amount of borrow material to build the 

platform for the new reactors. Such volumes of borrow in high quantities requires significant 

movement of material in and around the aquifers in such low lying areas as South Miami-Dade 

County. Such excavation can disturb the water resources. The EIS should do a quantification 

of the amount of material required and its potential impact to see if in fact such borrow material 

can be moved or can be excavated in the vicinity of the existing power plant and the FKAA well 

field. If not, material must be obtained elsewhere where such impacts are not detrimental to 

local well fields. (0024-5 [Walker, Tom])

Response: Available information about the fill source will be provided in Chapter 3 of the EIS. 

The impacts of obtaining fill material will be presented in Chapter 4; and the cumulative impacts 

of the proposed action by FPL to build and operate proposed Turkey Point Units 6 and 7, along 
Appendix D 

October 2016 D-65 NUREG–2176 

with other past, present, and reasonably foreseeable future actions by other agencies, will be 

presented in Chapter 7. 

Comment: A major area of interest is whether operation of the radial collector wells would 

cause the karst Biscayne Aquifer to fracture (frac out), thereby altering the salinity of the 

Biscayne Bay and affecting the area's fish and wildlife resources. Staff from Florida Power & 

Light (FPL) believes that these radial collection wells will not be used for a substantial part of the 

time that the plant would be in operation, and consequently taken a conservative approach by 

modeling a scenario during which the radial collector wells would inject water laterally 

constantly. Other agencies participating in the review and whose staff has the expertise to test 

the model are doing so, and we are waiting for the results in order to determine the extent to 

which we may be concerned about the possibility of frac out actually occurring. 

(0018-1 [Poole, Mary Ann])

Comment: Concerns still remain regarding unknowns related to the Radial Collector Well 

(RCW) System including, but not limited to: possible impacts to the Bay including benthic flora 

and fauna; salinity; and possible impacts of the radial collector wells on the freshwater input to 

the bay, flora and fauna. These issues and concerns will require further review and discussion. 

(0020-1 [Mulkey, Cindy])

Comment: The operation of the RCWs would result in hydrologic impacts, including ... surface 

water, on Biscayne Bay due to geological disturbances, resulting in water volume and quality 

alterations ... [A] large portion of the nearly 124 million gallons of Biscayne Bay water will 

originate from within Biscayne National Park boundaries, which is a protected water body. 

(0025-1-13 [Kimball, Dan] [Lewis, Mark])

Comment: The Florida Department of Environmental Protection (FDEP) is requiring a revised 

groundwater model due to many deficiencies, including the inability to effectively simulate 

impacts to Biscayne Bay; as a result, the SCA remains incomplete to date. Thus, a revised 

groundwater model is pending submittal to the State of Florida for the SCA process. The 

revised SCA groundwater model should be consistent with the groundwater model submitted as 

part of the COLA. A model that represents the Biscayne Aquifer and site specific hydrologic 

features is necessary to fully evaluate the impacts of the operation of the radial collector wells 

(RCWs) on the Biscayne Bay nearshore ecosystem function (see Attachment 1.B.). Therefore, 

the COLA groundwater model results that claim 92 to 100 percent of the intake water for the 

RCWs comes from the bay has not been substantiated. (0025-1-4 [Kimball, Dan] [Lewis, Mark])

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 1.a Radial wells. Impacts to EFH associated with radial well construction and 

operation within Biscayne Bay should be fully evaluated. The evaluations should include 

detailed HDD routes and examinations of the potential for frac-outs. Monitoring and mitigation 

measures for frac-out detection and clean-up will also be needed. (0033-5 [Croom, Miles])

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 1.b Radial wells. Impacts to EFH associated with radial well construction and 

operation within Biscayne Bay should be fully evaluated. The evaluations should include 
Appendix D 

NUREG–2176 D-66 October 2016 

detailed explanations of the circumstances under which radial wells would be required and at 

what capacities. (0033-6 [Croom, Miles])

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 1.d Radial wells. Impacts to EFH associated with radial well construction and 

operation within Biscayne Bay should be fully evaluated. The evaluations should include a 

more clear explanation of how use of the radial wells will affect salinity, including identification of 

the geographic area that would be affected and how that area would change seasonally and 

under various environmental conditions (such as tides and prevailing wind conditions). This 

analysis of effects on water quality also should include pH and temperature. 

(0033-8 [Croom, Miles])

Response: These comments indicate an interest in impacts on the Biscayne Aquifer below 

Biscayne Bay and on the Bay itself from the withdrawal of cooling water using RCW at the 

proposed units. The impacts of the plant's consumptive use of water on local and regional 

water resources, including the Biscayne Aquifer, will be presented in Chapters 4 and 5 of the 

EIS for building and operating, respectively. Cumulative water-use impacts will be addressed in 

Chapter 7 and cooling water alternatives in Chapter 9. 

D.1.9 Comments Concerning Ecology – Terrestrial 

Comment: I was very disappointed to hear that the U.S. Army Corps of Engineers so casually 

referred to that almost all nuclear power plants are placed near wetlands. That, alone, to me is 

a concern. This one, too, would be the same. (0001-11-3 [Amor, Valerie])

Comment: They [FPL] may need 90 million gallons of cooling water a day for these two new 

units. One plan would take that from a big sewage treatment plant to be built 25 miles up the 

road. How would they get 90 million gallons of water a day down here? That takes a big pipe 

and maybe some pumping stations. They're not going to get permission to run that down 

through Biscayne Bay so they'll have to put it in the wetlands, and there go the wetlands next to 

the Bay. (0001-6-4 [Miller, Lloyd])

Comment: Besides fresh water loss the loss of wetlands is the other major thing we're trying to 

fix there. The numbers of wetland loss here are just astronomical, and they're not something 

that we really ought to be considering in modern 2010 times anymore. 

(0002-6-5 [Grosso, Richard])

Comment: The planned expansion of Units 6&7 of Turkey Point requires the permanent 

destruction of untouched wetlands just off of the Biscayne Bay national park regions. 

(0007-1 [Burris, Jessica])

Comment: In the West Preferred Corridor, additional access pads (approximately 79-170 ft 

long) are proposed east of the power line poled structures that would provide access from the 

structure pads to the existing L-31 North Levee Road (Figures 5A-5B). Additional wetland filling 

would be required to construct the proposed pads beneath the power line poled structures. 

Construction of the access roads/pad would require filling of more than 100 acres of wetlands 

within the West Preferred Corridor (that is currently within Everglades National Park) per the 

COLA/SCA. A perpetual 90 ft vegetation easement is proposed to extend from the westernmost 
Appendix D 

October 2016 D-67 NUREG–2176 

portion of the West Preferred Corridor into ENP to allow FPL to manage non-native vegetation. 

(0025-3-31 [Kimball, Dan] [Lewis, Mark])

Comment: Vegetation in the ENP portion of both transmission line corridors identified by FPL 

consists primarily of high quality, long and short hydroperiod native marsh and prairie 

communities. Direct impacts of the construction and maintenance of power line infrastructure 

on the natural abundance and distribution of these native plant communities need to be 

evaluated. 2. Limited information on the presence of state listed threatened and endangered 

plant species exists for either corridor identified by FPL. Nonetheless, preliminary surveys of 

the Western Preferred Corridor resulted in the identification of at least one state listed 

endangered plant species within the boundary of the corridor. Additional survey work is needed 

and the results of that survey work should be used to evaluate impacts on threatened and 

endangered plant species in both corridors. 3. The proposed exotic vegetation management 

easement associated with the Western Preferred Corridor will result in the modification and/or of 

native plant species by mechanical or chemical means within boundaries of ENP. The impacts 

of these actions on individual species native plant community composition need to be 

considered in this evaluation. 4. Soil disturbance and modification of natural elevations in 

either corridor identified by FPL has the potential to introduce new invasive plant species or 

exacerbate existing invasive plant species populations. These impacts need to be evaluated. 

(0025-3-34 [Kimball, Dan] [Lewis, Mark])

Response: The impacts on wetlands from building proposed Turkey Point Units 6 and 7, 

including water supply pipelines and transmission corridors, will be addressed in Chapter 4 of 

the EIS and the impacts of plant operation will be addressed in Chapter 5. 

Comment: I had fished, hunted and camped exactly where the power plants are before they 

were built. I could tell you, beyond a doubt right now, there's probably, in most instances, as 

many fish, deer, and other types of wildlife in that area now as there were when I was a kid. 

That hasn't been impacted all that greatly. (0002-13-7 [Simpson, Roce])

Response: The impacts of building and operating proposed Turkey Point Units 6 and 7 on fish 

and wildlife will be evaluated in Chapters 4 and 5 of the EIS, respectively. 

Comment: The second area of concern, of course, is Everglades impact. The expansion will 

impact hundreds of acres of wetlands which is contradictory to our very expensive and very 

important effort to restore the Everglades right now. (0001-7-3 [MacLaren, Kaitlin])

Comment: It [the new transmission lines] also will create a corridor for invasive species; it will 

disrupt the water flow; birds run into power lines all the time, electrocutions, collisions. 

(0002-14-10 [Schwartz, Matthew])

Comment: The largest percentage of this land, 61% of the 38,607 acres evaluated for this 

project are composed of wetlands bordering Biscayne National Park, Biscayne Bay Aquatic 

Preserve, Homestead Bayfront Park, the Model Lands Basin, and the Everglades Mitigation 

Bank as openly noted in the NRC environmental report concerning this expansion. The 

destruction of wetlands in the surrounding areas of national reserves has possible drastic 

results on the reserved area. In addition to destroying the ecological foundation for wildlife in the 
Appendix D 

NUREG–2176 D-68 October 2016 

affected region itself, the permanent destruction of everglade wetlands surrounding the reserve 

equally affects the ecology of areas designated to remain untouched by U.S National Park 

service and the U.S department of the interior. (0007-3 [Burris, Jessica])

Comment: The Draft EIS needs to fully address the alternative transmission line corridors and 

the environmental effects it may have on Everglades National Park. (0014-15 [Mueller, Heinz])

Comment: The Turkey Point facility is located within the southeastern saline Everglades, which 

is a large, contiguous wetland system that consists of both freshwater and coastal wetlands. 

This area is strategically located in the watershed for the Florida Keys National Marine 

Sanctuary, Biscayne National Park, the Crocodile Lake National Wildlife Refuge, and the State 

of Florida's Card Sound Aquatic Preserve. In addition, the proposed transmission line corridor 

bisects this wetland system and continues westward into Everglades National Park, as well. 

This region provides habitat for many plant and animal species that are protected at the county, 

state and/or federal level, including the wood stork, Everglades snail kite, American crocodile, 

Florida panther, and Eastern indigo snake, among others. It is a known stop-over for migratory 

songbirds and waterfowl, and the proposed plant site provides significant shorebird habitat, as 

well. The EIS should also include an assessment of the impacts of the project on wetlands 

habitat and habitat for rare threatened and endangered species. (0015-3 [Espinosa, Carlos])

Comment: Although the NRC does not directly regulate transmission lines, Miami-Dade 

County understands that the Army Corps of Engineers (ACOE) will be a cooperating agency for 

this EIS. Since the Army Corps will be using the EIS as the basis for their Section 404 permit 

decision as it relates to the wetland impacts that would be necessary to construct the proposed 

plant and associated facilities, including the transmission lines, we strongly recommend the 

NRC include a comprehensive impacts analysis of all features that will or could potentially 

impact environmental resources, including wildlife and jurisdictional wetlands to be affected by 

the proposed transmission corridors. (0015-4 [Espinosa, Carlos])

Comment: Construction of roads and tower pads would likely result in soil disturbance and the 

colonization of exotic vegetation like Brazilian pepper if unchecked. The potential land 

exchange property is frequently used for exotic vegetation management and monitoring of 

wetlands in the project area. NPS staff would be required to monitor the impacts of FPL's exotic 

vegetation management practices on native vegetation in the vegetation management 

easement granted to FPL and adjacent natural vegetative communities within the park. 

(0025-3-43 [Kimball, Dan] [Lewis, Mark])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 on Everglades National Park, Biscayne National Park, and other parks and preserves, 

especially on wetlands within those areas, will be evaluated in Chapters 4 and 5 of the EIS, 

respectively. The cumulative impacts on wetlands and other ecological resources in these 

areas will be evaluated in Chapter 7. 

Comment: [A]ny environmental mitigation should include purchasing large tracts of land south 

of the plant between Florida City and Key Largo and adding this acreage to Everglades National 

Park or Crocodile Lake National Preserve. Several endangered panthers have been hit by cars 

in this area, crocodiles and manatees use Turkey Point's warm water as mating and winter 
Appendix D 

October 2016 D-69 NUREG–2176 

weather locations. The area south of the Nuclear plant is not a good location for homes or 

businesses due to proximity to the plant both for safety and security as well as environmentally 

sensitive lands. This land should be protected as part of the environmental mitigation and 

permitting. (0008-2 [Garcia, Preston])

Response: The potential mitigation for wetland impacts and impacts on Federally and Statelisted threatened or endangered species will be discussed in Chapters 4, 5, and 7 of the EIS. 

Evaluation of the impacts of building and operating proposed Turkey Point Units 6 and 7 on 

regional land use will also be included in those chapters. 

Comment: [T]he planned use of SW 359 Street as a service road through wetlands for Turkey 

Point 6 & 7 will compromise a $135 Million CERP/Comprehensive Everglades Restoration 

Project. (0012-7 [Payne, Nkenga])

Comment: Road construction will also cause direct wetland loss and fragmentation. 

(0025-2-18 [Kimball, Dan] [Lewis, Mark])

Response: The potential impacts of proposed Turkey Point Units 6 and 7 transmission line and 

access road construction and operation on regional wetlands, including those involved in the 

CERP, as well as potential mitigation actions, will be evaluated in Chapters 4, 5, and 7 of the 

EIS. 

Comment: The Draft EIS should discuss how the construction of Units 6 and 7 would impact 

sensitive coastal. wetlands and any mangrove protected areas along Biscayne Bay and 

adjacent to Biscayne National Park. The Draft EIS should also address any issues related to 

the Florida Everglades Mitigation Bank. (0014-10 [Mueller, Heinz])

Response: The impacts of building proposed Turkey Point Units 6 and 7 on coastal wetlands 

and mangrove-protected areas along Biscayne Bay will be evaluated in Chapter 4 of the EIS. 

The possible role of the Florida Everglades Mitigation Bank, and other wetland mitigation banks 

in the region, in the mitigation of wetland losses will also be evaluated in Chapter 4. 

Comment: The Draft EIS needs to provide information on measures that have been taken to 

avoid and minimize wetland impacts. According to the Clean Water Act (CWA) 

Section 404(b)(1) Guidelines, an applicant must demonstrate avoidance and minimization of 

wetland impacts before compensatory mitigation can be considered. Specifically, no discharge 

of dredged or fill material shall be permitted if there is a practicable alternative to the proposed 

discharge which would have less adverse impact on the aquatic ecosystem. Practicable 

alternatives include activities which do not involve the discharge of dredged or fill material into 

waters of the United States. (0014-17 [Mueller, Heinz])

Response: Wetland mitigation measures, as applicable to CWA Section 404 compliance, 

including avoidance and minimization efforts, will be discussed in Chapter 4 of the EIS. 

Comment: List of potentially occurring State-listed fish and wildlife species 

 Common name Scientific name State-listing status 

 Atlantic sturgeon Acipenser oxyrinchus Species of special concern 
Appendix D 

NUREG–2176 D-70 October 2016 

 American alligator Alligator mississippiensis Species of special concern 

 American crocodile Crocodylus acutus Endangered 

 Eastern indigo snake Drymarchon corais couperi Threatened 

 Least tern Sterna antillarum Threatened 

 Limpkin Aramus guarauna Species of special concern 

 Snail kite Rostrhamus sociabilis plumbeus Endangered 

 Everglades mink Mustela vison evergladensis Threatened 

 Florida manatee Trichechnus manatus latirostris Endangered 

(0018-3 [Poole, Mary Ann]) 

Comment: The site has nesting habitat for the least tern. Least terns are listed as threatened 

by the FWC and may potentially be nesting on the cleared gravel upland portions of the site. 

Please provide least tern nesting surveys and address the loss of potential nesting habitat. 

(0018-5 [Poole, Mary Ann])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of airborne pathogens from the Turkey Point FPL power station on state or 

federal endangered or threatened species, as a result of using reclaimed wastewater for cooling 

purposes, please provide them. (0022-1-16 [Reynolds, Laura])

Comment: Please state the amount of disruption to listed species that the construction of 

units 6&7 will make including the plant site, all support facilities, all structures, all borrow pits 

(including rockmines) all fencing, all roads, all berms, all pipelines, all transmission lines, all 

basins, all parking lots, and all vehicle usage. (0022-2-21 [Reynolds, Laura])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 and associated facilities on Federally and State-listed threatened or endangered species will 

be addressed in Chapters 4 and 5 of the EIS, based on the affected environment described in 

Chapter 2. The analysis will consider possible impacts resulting from airborne pathogens. The 

EIS will include citations for documents used in its preparation. 

Comment: To the extent that you are aware of any documents or reports by any federal, 

state, local or regional government agency, FPL or any of its employees or contractors that 

relate to adverse impacts on farm crops, wetlands, wildlife, and marine areas from airborne 

pathogens, as a result of using reclaimed wastewater for cooling purposes, please 

provide them. (0022-1-17 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts from airborne toxic matter on farm crops, wetlands, and marine areas, as a 

result of using reclaimed water for cooling purposes, please provide them. 

(0022-1-19 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts from airborne EPOCs on farm crops, wetlands, wildlife, and marine areas, as a 
Appendix D 

October 2016 D-71 NUREG–2176 

result of using reclaimed water for cooling purposes, please provide them. 

(0022-2-3 [Reynolds, Laura])

Response: The potential impacts of building proposed Turkey Point Units 6 and 7 on 

ecological resources, including the impacts of airborne releases, will be addressed in 

Chapters 4, 5, and 7 of the EIS, based on the affected environment described in Chapter 2. 

The analysis will consider possible impacts to species and habitats resulting from airborne 

pathogens and contaminants. The EIS will include citations for documents used in its 

preparation. 

Comment: The applicant should also provide the management plan for listed species required 

under Condition 2 of Z-56-07, which should include but not be limited to identifying the plans 

established to protect endangered or threatened species from impacts resulting from the 

proposed work. (0023-1-19 [LaFerrier, Marc])

Comment: The application states, "Due to the limited amount of upland habitat, mammalian 

wildlife species are relatively uncommon in the vicinity of the Site" and fails to acknowledge that 

there is a possibility for Florida panther in the vicinity. It should be noted that there have been 

three documented vehicle strikes of Florida Panthers in this region, including two road kills in 

the recent past. In addition, there have been recent agency reports of additional animals in the 

area, including a panther/cub pair. The application does not provide sufficient information to 

evaluate potential impacts to ecological resources including but not limited to rare threatened 

and endangered species resulting from the installation and use of the proposed access roads. 

[Same statement for T-Lines] (0023-2-13 [LaFerrier, Marc])

Comment: The application notes that the Eastern indigo snake has been observed both within 

and adjacent to the boundaries of the site. Please provide a Comprehensive Environmental 

Impact Statement that includes, but is not limited to, the potential effects of the construction and 

operation of the plant and its associated non-linear and linear features on the Eastern indigo 

snake. [Same statement for T-Lines] (0023-2-16 [LaFerrier, Marc])

Comment: Please provide documentation that demonstrates that critical habitat for threatened 

and endangered species will not be degraded and/or destroyed, as required pursuant to the 

Miami-Dade County CDMP. (0023-4-9 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of the proposed units on Federally and Statelisted threatened or endangered species. The potential impacts of building and operating 

proposed Turkey Point Units 6 and 7 on Federally and State-listed threatened or endangered 

species will be discussed in Chapters 4, 5, and 7 of the EIS, based on the affected environment 

described in Chapter 2. 

Comment: High quality coastal wetlands exist on the shoreline along the proposed area of 

work. (0023-1-46 [LaFerrier, Marc])
Appendix D 

NUREG–2176 D-72 October 2016 

Comment: Pursuant to Condition 1 of Z-56-07, the applicant shall submit a wetlands mitigation 

plan for the Units 6 and 7 Site. .... Pursuant to Condition 1 of Z-56-07, the plan shall identify the 

specific mitigation that is for the Units 6 and 7 Site. (0023-1-62 [LaFerrier, Marc])

Comment: It is unclear from the application whether the proposed rock mines will impact 

existing wetland restoration areas associated with previous unauthorized impact to wetlands on 

FPL property in this location. (0023-3-18 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of proposed Turkey Point Units 6 and 7 on 

wetlands. The potential impacts of building and operating the proposed units on wetlands will 

be discussed in Chapters 4, 5, and 7 of the EIS, based on the affected environment described in 

Chapter 2. 

Comment: The CEIS should include, at a minimum, a comprehensive species survey that 

utilizes professionally-accepted sampling standards to survey plants and animals at multiple 

locations in the mudflat at least quarterly for a minimum of one year. Sampling should include, 

but not be limited to algae, vascular plants, insects, birds, reptiles, amphibians, fish, aquatic 

invertebrates, and mammals. (0023-1-22 [LaFerrier, Marc])

Comment: The application does not address biological, hydrological, and ecological impacts 

resulting from road construction and operation. Impacts that shall be addressed include but are 

not limited to disruption of ecological corridors, altered hydrology in surrounding wetlands (e.g. 

via barriers to sheetflow), increased invasion rate of non-native species, increased road-kill, 

impacts to listed species and their habitat, including but not limited to Florida panthers and 

Eastern indigo snakes, and increased access that may facilitate illegal dumping, ATV riding, 

poaching, and other activities that may directly or indirectly impact surrounding wetlands. 

(0023-1-50 [LaFerrier, Marc])

Comment: [P]lease provide locations, details and descriptions of all wildlife protection features, 

including but not limited to wildlife fencing and panther underpasses. (0023-2-17 [LaFerrier, Marc])

Comment: Application is incomplete and includes incorrect characterization of the vegetation 

adjacent to the site. Corrected and missing information is needed to determine the potential 

impacts of the application, especially on state and federally protected species. Vegetation 

adjacent to the site and located along the transmission line corridors includes freshwater 

communities, and the coastal vegetation communities are more diverse than characterized. 

Please provide a complete vegetation survey for all transmission line corridors, including but not 

limited to complete species lists for each community type and identification and location of state 

and federally protected species. Please also provide a complete analysis of utilization of these 

vegetation communities by fauna, including but not limited to insects, birds, fish, aquatic 

invertebrates, reptiles, amphibians, and mammals, and including but not limited to season of 

use, use by state or federally protected species, and nature of use. (0023-3-22 [LaFerrier, Marc])

Comment: The application provides insufficient information on the potential effects of the 

transmission line corridors on state and federally protected species, designated EEL sites, 

Natural Forest Communities, and tree resources protected. (0023-3-23 [LaFerrier, Marc])
Appendix D 

October 2016 D-73 NUREG–2176 

Comment: The application states that new rights-of-way will need to be obtained for the east 

transmission line corridor. Please provide details on where new rights of way will be obtained, 

and whether there are state or federally protected plant or animal species, designated EEL 

sites, Natural Forest Communities, or tree resources that could be impacted by the work within 

these proposed new rights-of-way. (0023-3-24 [LaFerrier, Marc])

Comment: Any improvements to the transmission corridors, including but not limited to the 

installation of power poles and lines must avoid/minimize impacts to Natural Forest 

Communities. A survey of all Natural Forest Communities, within and adjacent to the 

transmission corridors, is required and all proposed impacts to Natural Forest Communities 

must be identified. (0023-3-25 [LaFerrier, Marc])

Comment: Please submit plans for the protection of Endangered and Threatened Species both 

during construction and for the temporary and long term use of the proposed roads and 

facilities. (0023-3-51 [LaFerrier, Marc])

Comment: [T]he referenced location will be permanent or temporary, final slopes and 

elevations for the piles, what measures will be taken to address stormwater runoff from the spoil 

piles, characterization of the material including but not limited to contamination levels, potential 

impacts to threatened and endangered species including but not limited to potential impacts to 

critical habitat, and potential impacts to surrounding coastal wetlands. 

(0023-4-14 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of proposed Turkey Point Units 6 and 7 on 

Federally and State-listed threatened or endangered species, wetlands, and other terrestrial 

resources. The potential impacts of building and operating the proposed units on terrestrial 

ecological resources will be discussed in Chapters 4, 5, and 7 of the EIS, based on the affected 

environment described in Chapter 2. 

Comment: Construction and use of new access or improved access roads will provide a 

conduit for introduction of invasive exotic species on adjacent lands, including but not limited to, 

EEL conservation lands. (0023-2-5 [LaFerrier, Marc])

Comment: Chapter 24 and the Landscape Code of Miami-Dade County require that all 

invasive/exotic plant species be removed prior to site development, even outside of mitigation 

areas. Please address exotic plant management for all parcels where impacts will occur. 

(0023-3-53 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of the proposed units and transmission lines on 

habitat quality on adjacent lands. The potential impacts of building and operating proposed 

Turkey Point Units 6 and 7 and transmission corridors on terrestrial ecological resources will be 

addressed in Chapters 4, 5, and 7 of the EIS, based on the affected environment described in 

Chapter 2. The analysis will consider the potential impacts from invasive and exotic plant 

species. 
Appendix D 

NUREG–2176 D-74 October 2016 

Comment: Please provide in the Draft EIS a proposed mitigation plan to offset unavoidable 

wetland impacts. The mitigation plan should be in compliance with Federal Compensatory 

Mitigation Rule, dated April 10, 2008. (0014-18 [Mueller, Heinz])

Comment: [T]he applicant shall submit a wetlands mitigation plan for the areas impacted by 

the construction of the access roads. (0023-2-10 [LaFerrier, Marc])

Comment: A substantial proportion of the access road network passes through and, if 

approved, will impact the South Dade Wetlands and South Dade Wetlands Addition, both of 

which are projects designated for acquisition by Miami-Dade County's Environmentally 

Endangered Lands (EEL) Program. The applicant must provide information on the ultimate 

disposition of all proposed access roads that occur within the boundaries of these EEL 

projects, including but not limited to identifying roads that will be downgraded or removed, 

and which rights of way or road corridors could potentially be transferred or dedicated to the 

EEL program at the completion of the construction phase of the project after road remediation 

has been completed. (0023-2-11 [LaFerrier, Marc])

Comment: Please submit information demonstrating that impacts to wetlands within and 

adjacent to the proposed roadway expansion area have been avoided and minimized to the 

maximum extent possible. (0023-2-12 [LaFerrier, Marc])

Comment: Environmentally Endangered Lands (EEL) owned and/or managed conservation 

lands exist along proposed access roads. The application has not detailed the potential impacts 

to EEL land from any work related to the roads. The application should provide information on 

which roads are proposed as temporary, the ultimate disposition of the access road network, 

and an analysis of options for remediation of temporary roads after the project has been 

completed, including but not limited to road removal, restoration of impacted natural areas, and 

dedication of the restored land to the EEL Program. (0023-2-8 [LaFerrier, Marc])

Comment: The EEL Program owns additional land in other areas in which project features 

occur, so changes to roads and rights-of-way may impact publicly-held and managed lands 

beyond the proposed project areas. (0023-2-9 [LaFerrier, Marc])

Comment: Please provide additional documentation to describe the time associated with the 

proposed functional gain, especially in areas where the ecology, including change in the floral 

and faunal composition, is projected to recover based on relatively minor changes in 

hydroperiod and/or hydropattern. (0023-4-5 [LaFerrier, Marc])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Wetland Mitigation Proposals - The potential benefits and/or 

adverse impacts related to FPL's wetland mitigation proposals. Limited information has been 

provided to date by FPL regarding potential wetland mitigation options. (0032-27 [Golden, James])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of the proposed units and ancillary linear 

corridors on wetlands and other environmentally sensitive lands. The potential impacts of 

building and operating proposed Turkey Point Units 6 and 7 and ancillary corridors on wetlands 
Appendix D 

October 2016 D-75 NUREG–2176 

and other sensitive areas and potential mitigation of those impacts will be discussed in 

Chapters 4, 5, and 7 of the EIS, based on the affected environment described in Chapter 2. 

FPL will be required to submit a wetland mitigation plan as part of the CWA Section 404 permit 

application submitted to the USACE. 

Comment: The NPS is particularly concerned about the potential harm to water-dependent 

birds, including endangered wood storks, snail kites and a host of migratory bird species that 

nest, forage and feed within or near the West Preferred and West Secondary corridors. 

Potential effects include degradation or fragmentation of valuable wetlands habitat, disturbance 

of birds during construction, and the permanent risk of avian injuries and death from 

electrocution or collisions with the transmission lines, towers, and guy wires. This area is the 

focus of a number of important ecosystem restoration projects that specifically seek to increase 

the wetland function in these areas and provide improved habitat suitability for a variety of 

wetland-dependent species, particularly water-dependent birds. The construction of a large 

complex of transmission lines in this area creates a perpetual risk to birds that is inconsistent 

with the goals of Everglades restoration projects. The ElS should assess the impacts of the 

proposed transmission infrastructure on all avian species known to use the area with particular 

emphasis on state- and Federally-listed threatened and endangered and migratory bird species. 

A risk assessment should be performed that outlines specific methods that will be employed to 

avoid and minimize impacts to avian species. (0025-2-11 [Kimball, Dan] [Lewis, Mark])

Comment: The Eastern Preferred Transmission Line Corridor should be evaluated for impacts 

to migratory, roosting, and nesting birds. State-listed wading birds (e.g., white ibis) have nightly 

roosts in islands of Biscayne National Park, and they fly to the mainland daily crossing over 

proposed Eastern transmission lines. In addition, bald eagles, ospreys, and State-listed wading 

birds also have active nests within Biscayne National Park boundaries. A risk assessment 

should be performed that outlines specific methods that will be employed to minimize impacts to 

roosting and nesting birds. (0025-2-6 [Kimball, Dan] [Lewis, Mark])

Comment: The proposed corridors are located adjacent to multiple wading bird colonies 

containing federal and state-listed species including the wood stork (Mycteria americana),

snowy egret (Egretta thula), little blue heron (Egretta caerulea), tricolored heron (Egretta 

tricolor), and white ibis (Eudocimus albus). More than 30 other avian species of concern 

(federal and/or state listed) are known to, or have the potential to, occur in the corridors and 

habitats. 2. The endangered Everglade snail kite (Rostrhamus sociabilis plumbeus) forages 

and nests directly within the footprint of the proposed West Preferred Corridor. 3. Listed avian 

species are at risk of injury/mortality from collisions and electrocutions with the proposed power 

lines. Both corridors cross known flight pathways of the endangered wood stork and the 

Everglade snail kite. The West Preferred Corridor crosses flight pathways of other protected 

migratory species, such as waterfowl, that use the Atlantic Flyway during seasonal migrations. 

4. Based on their sheer abundance, including juveniles within the area, proximity to the power 

line, frequent flights across the West Preferred Corridor, and morphology, listed wading birds 

meet many of the risk factors known to affect avian mortality rates caused by transmission 

power lines. 5. The endangered wood stork may be at highest risk of injury/mortality from the 

proposed powerlines of all avian species due to its limited population size, body form, nocturnal 

foraging behavior, flight patterns, and abundance of juveniles in the area. 6. Implementation of 

the proposed transmission lines would result in filling of over 100 acres of habitat within 
Appendix D 

NUREG–2176 D-76 October 2016 

Everglades National Park that includes wood stork and Everglade snail kite foraging habitat as 

well as Everglade snail kite nesting habitat. 7. Florida panthers have been documented in and 

around both corridors within ENP. Suitable panther habitat within the park would be reduced by 

over 100 acres as wetlands are filled for tower pads and access roads. Potential effects to 

panthers would include temporary disturbance during construction. (0025-3-32 [Kimball, Dan] 

[Lewis, Mark])

Comment: More than 200 avian species are at risk of increased injury/mortality resulting from 

potential electrocutions and collisions with the proposed power lines. Species known to 

produce streamers, such as raptors, vultures, and herons, are at risk of injury/mortality from 

electrocution with the proposed power lines. 2. Besides the previously mentioned listed and 

special status species, other non-listed avian species that nest within colonies adjacent to the 

proposed corridors include great egrets (Ardea alba), great blue herons (Ardea herodias), cattle 

egrets (Bub ulcus ibis), anhingas (Anhinga anhinga), black-crowned night herons (Nycticorax 

nycticorax), and yellow-crowned night herons (Nyctanassa violacea). 3. More than 40 bird 

species that are not threatened, endangered, or special status species are anticipated to nest 

within the proposed corridors or adjacent habitats. 4. Implementation of the proposed 

transmission lines would result in filling of over 100 acres of habitat used by more than 

200 avian species. (0025-3-33 [Kimball, Dan] [Lewis, Mark])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - Another area of concern is 

specific to tree islands, which are commonly used as bird rookeries. Islands in or adjacent to 

this corridor have been Wood Stork rookeries in recent years. Given that Wood Storks are an 

endangered species and that restoration of the Wood Stork population, along with other 

Everglades wading bird populations, is a primary CERP target, the construction and presence of 

electrical transmission lines that could impact these tree islands and their fauna should be 

avoided. Please note that there may also be potential adverse impacts to the Wood Stork 

population and other Everglades wading bird populations from the West Preferred Corridor. 

(0032-25 [Golden, James])

Response: The potential impacts of building and operating the proposed new transmission 

lines on migratory, roosting, and nesting birds, including those that are Federally or State-listed 

as threatened or endangered will be addressed in Chapters 4, 5, and 7 of the EIS, based on the 

affected environment described in Chapter 2. 

Comment: Eliminate or reduce the direct and secondary wetland impacts and impacts to 

wetland-dependent listed species. The amendment does not demonstrate elimination or 

reduction of direct and secondary wetland impacts and impacts to wetland-dependent listed 

species. Please provide alternative analyses to document elimination or reduction of direct and 

secondary wetland impacts for all potential roadway corridors. Potential secondary impacts 

include habitat fragmentation, other induced development, and habitat alteration related to 

opportunistic undesirable (or exotic) vegetation. (0032-35 [Golden, James])

Comment: Revise the habitat assessment to better reflect the actual habitat values. Provide 

mitigation adequate to offset the proposed wetland impacts. (0032-36 [Golden, James])
Appendix D 

October 2016 D-77 NUREG–2176 

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of the proposed units and ancillary facilities on 

wetlands and habitat degradation. The potential impacts of building and operating proposed 

Turkey Point Units 6 and 7 and ancillary facilities and corridors on wetlands and habitat 

degradation will be discussed in Chapters 4, 5, and 7 of the EIS, based on the affected 

environment described in Chapter 2. 

Comment: These sections characterize the plant site as sparsely-vegetated hypersaline mud 

flats which provide limited habitat for aquatic biota due to fluctuations in water levels and salinity 

associated with the cooling canal system, DERM staff observations of the plant site during site 

visits, however, indicated that the site was heavily vegetated during the early wet season 2009, 

A Comprehensive Environmental Impact statement is needed pursuant to Chapter 24 of the 

Miami-Dade Code that addresses this and other issues. CEIS should include, at a minimum, a 

complete seasonally-based biological surveys for the proposed facility site that includes, but is 

not limited to birds, insects, fish, reptiles and amphibians, mammals, and aquatic invertebrates. 

(0023-1-17 [LaFerrier, Marc])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Radial Wells and Construction Dewatering Withdrawals at 

Power Plant Site - The potential for adverse impacts to wetlands and listed species. 

(0032-12 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Additional Construction Impacts at Power Plant Site - The 

potential for adverse impacts to wetlands and listed species. (0032-14 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Temporary Roadway Improvements for Construction of 

Units 6 & 7 - The potential for adverse impacts to environmentally sensitive lands within the 

Model Land Basin. (0032-16 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Reclaimed Water Pipeline - The potential for adverse impacts 

to wetlands and listed species. (0032-17 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - The potential for adverse 

impacts to wetlands and listed species. (0032-19 [Golden, James])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 and ancillary facilities and corridors on wetlands, Federally and State-listed species, and other 

terrestrial important resources will be addressed in Chapters 4, 5, and 7 of the EIS, based on 

the affected environment described in Chapter 2. 

Comment: The application does not include the listed species management plan, as required 

under Condition 2 of Z-56-07. Please provide the required plan. (0023-1-63 [LaFerrier, Marc])
Appendix D 

NUREG–2176 D-78 October 2016 

Comment: A plan is needed for in-kind, in-situ mitigation for impacts to existing wetlands 

related to the Radial Collection Well Area and Radial Collector Well Delivery Pipeline. Please 

include planting scheme, success criteria, monitoring and maintenance schedules. High quality 

coastal wetlands exist on the shoreline along the proposed area of work. 

(0023-1-71 [LaFerrier, Marc])

Comment: The application does not provide a complete and detailed exotic vegetation 

management plan as required by Condition 12 of Z-56-07. (0023-2-30 [LaFerrier, Marc])

Comment: The application fails to provide sufficient information to determine whether it is in 

compliance with the tree protection provisions of Section 24-49 of the Miami-Dade Code. 

(0023-2-31 [LaFerrier, Marc])

Comment: The application does not include the management plan for all federal and state 

listed threatened and endangered species documented within the proposed access area, as 

required under Condition 11 of Z-56-07. (0023-2-32 [LaFerrier, Marc])

Comment: Please submit a proposed schedule for long term monitoring, maintenance and 

financial assurances for all proposed mitigation areas. Please submit more detailed information 

about the location and types of anticipated impacts associated with the secondary Impacts. 

Please submit a detailed assessment of the time lag and risk associated with the restoration of 

the temporary impacts. (0023-3-69 [LaFerrier, Marc])

Comment: It was stated that the Basis of Review and ratios were used to determine the 

mitigation credits necessary in the HID. According to the Basis of Review, the ratios should be 

1.5/1 to 4/1. How was the proposed 1/1 determined and how is it consistent with the Basis of 

Review and the agency decisions used for other wetland impacts in the area? 

(0023-4-15 [LaFerrier, Marc])

Comment: The HID Mitigation Bank has a finite amount of mitigation that they can perform 

annually and receives funding from other impact associated with private development. Please 

provide evidence that the large amount of mitigation, as proposed, can be accomplished in the 

projected time frame. (0023-4-16 [LaFerrier, Marc]) 

Comment: The application does not provide the planting plan required under Condition 13 of 

Z-56-07 for material that will not be planted at the proposed plant site. 

(0023-4-18 [LaFerrier, Marc])

Comment: The application does not include the listed species management plan, as required 

under Condition 2 of Z-56-07. Please provide the required plan. Pursuant to Condition 2 of 

Z-56-07, the plan shall include but not be limited to identification, location, and description of 

features such as permanent physical barriers, visual buffers, and the establishment of 

development setbacks necessary to prevent both direct and indirect impacts to adjacent critical 

habitat and disruption of sensitive behaviors such as breeding, nesting and foraging within the 

adjacent critical habitat. (0023-4-20 [LaFerrier, Marc])

Response: These comments are directed at the applicant and refer specifically to the SCA 

submitted to the State of Florida by FPL, but they indicate an interest in the impacts of building 
Appendix D 

October 2016 D-79 NUREG–2176 

and operating proposed Turkey Point Units 6 and 7 on terrestrial resources. The potential 

terrestrial impacts of building the units will be presented in Chapter 4 of the EIS and the 

potential terrestrial impacts of operating the units will be presented in Chapter 5. Cumulative 

terrestrial impacts will be presented in Chapter 7. 

Comment: What impact will salt deposition from the cooling towers have on freshwater 

wetlands in the area? What are the cumulative impacts of salt deposition from Units 3 and 4 in 

addition to those from the proposed Units 6 and 7? (0018-16 [Poole, Mary Ann])

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 3. Cooling towers. Please evaluate potential impacts to wetlands from salt 

deposition from the cooling towers. (0033-11 [Croom, Miles])

Response: The potential impacts of operating proposed Turkey Point Units 6 and 7 on 

terrestrial ecological resources, including the impact of salt deposition from drift, will be 

discussed in Chapters 5 and 7 of the EIS, based on the affected environment described in 

Chapter 2. 

D.1.10 Comments Concerning Ecology – Aquatic 

Comment: The reason they want to stay in that spot is because they're going to use the ocean 

water to cool the reactors. That hot water goes somewhere. It has been shown over and over 

again it produces algae blooms; it affects the pH around there; it kills the fish; it changes it. We 

have a fragile coral reef that runs along us. We are in a fragile environmental area. It is an 

environmental impact. (0001-11-10 [Amor, Valerie])

Response: The potential impacts from cooling water, including the use of reclaimed water from 

Miami-Dade County, use of water obtained from RCWs located at Turkey Point, and discharge 

of heated water to the Boulder Zone, will be discussed in Chapter 5 of the EIS. 

Comment: I haven't even begun to talk about fish and wildlife, road impacts, exotic species, 

and all of that. But there's a lot of information out there from the State Siting Act process that 

you should look at. (0002-6-7 [Grosso, Richard])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of the biological forms that will be affected by deep well injected wastes, 

please provide them. (0022-2-6 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the geographical extent of the biological forms that will be affected by the deep well injected 

wastes, please provide them. (0022-2-7 [Reynolds, Laura])

Response: A variety of sources of information will be used during the development of the EIS, 

including information associated with the Florida SCA. The EIS will include citations for 

documents used in its preparation. 
Appendix D 

NUREG–2176 D-80 October 2016 

Comment: List of potentially occurring State-listed fish and wildlife species 

 Common name Scientific name State-listing status 

 Atlantic sturgeon Acipenser oxyrinchus Species of special concern 

 American alligator Alligator mississippiensis Species of special concern 

 American crocodile Crocodylus acutus Endangered 

 Eastern indigo snake Drymarchon corais couperi Threatened 

 Least tern Sterna antillarum Threatened 

 Limpkin Aramus guarauna Species of special concern 

 Snail kite Rostrhamus sociabilis plumbeus Endangered 

 Everglades mink Mustela vison evergladensis Threatened 

 Florida manatee Trichechnus manatus latirostris Endangered 

(0018-2 [Poole, Mary Ann])

Response: The potential impacts on Federally and State-listed threatened and endangered 

species, including those listed in the comment, from building and operating proposed Turkey 

Point Units 6 and 7 will be discussed in Chapters 4 and 5 of the EIS. 

Comment: Please state the amount of disruption to the biota of Biscayne National Park and 

adjacent bodies of Outstanding Florida Waters that the construction of units 6&7 will make 

including the plant site, all support facilities, all structures, all borrow pits (including rockmines,) 

all fencing, all roads, all berms, all pipelines, all transmission lines, all basins, all parking lots, 

and all vehicle usage. (0022-3-1 [Reynolds, Laura])

Response: The EIS will discuss the aquatic resources in the vicinity of Turkey Point in 

Chapter 2 of the EIS and will consider potential impacts from building proposed Turkey Point 

Units 6 and 7 in Chapter 4. Chapter 7 will evaluate cumulative aquatic impacts. 

Comment: Please show the barge routes and state the number of barge trips for each route for 

units 6&7 that traverse the waters of Biscayne National Park and other protected waters. 

Please state the sizes and drafts of the barges. Please state the average speed and maximum 

speed of the barge trips. Please state the increased damage to the benthic communities due to 

physical contact, turbidity, silt deposition, and wake disruptions. Please state the amounts of 

cumulative damage to the benthic communities resulting from historic barge trips and the 

increased barge trips due to units 6&7. Please state the plan for preventing barge collisions 

with manatees, turtles, and other protected species. Please state the plan for minimizing the 

number of barge trips for units 6&7. Please state the mitigation for damage to the benthic 

communities of Biscayne National Park and other protected waters. (0022-3-18 [Reynolds, Laura])

Comment: The application does not provide sufficient information to demonstrate how 

manatees will be protected during construction of the barge slip improvements. 

(0023-1-64 [LaFerrier, Marc])

Comment: Potential impacts to other key resources in Biscayne National Park - 4. FPL should 

clarify how they would transport construction supplies and equipment to the worksite, including 

via marine pathways, and evaluate any additional impacts on the marine environment. 

(0025-3-30 [Kimball, Dan] [Lewis, Mark])
Appendix D 

October 2016 D-81 NUREG–2176 

Response: The potential impacts of increased barge traffic associated with building proposed 

Turkey Point Units 6 and 7 and the potential impacts of altering the barge slip will be discussed 

in Chapter 4 of the EIS. 

Comment: Surveys: Detailed surveys of all fish and wildlife resources in the vicinity of each 

proposed component of this project, to include laydown areas for construction equipment; areas 

that will be temporarily disturbed by excavations; and areas that may potentially be affected by 

changes in salinity, turbidity and sedimentation due to the operations of project. Please include, 

but do not limit to: benthic species and habitats (seagrasses, hardbottom, reefs, and associated 

reef resources), plankton, mangroves, and protected species (both Federally and State-listed). 

The design of all survey methodologies should be coordinated with the FWC. Provide a map of 

delineated habitat types (including mangroves and submerged habitats such as seagrasses and 

hardbottoms) with an overlay of the project component footprints. (0018-4 [Poole, Mary Ann])

Comment: Surveys: For the 60-foot x 100-foot x 9-foot deep barge unloading area expansion, 

please provide fish and wildlife resource surveys and sea grass surveys. With regard to the 

potential for manatees to occur in the barge unloading expansion area during construction, the 

applicant should provide information detailing how observers will be selected, whether they 

have any previous experience observing for manatees, how many observers will be assigned to 

the construction areas, and how many hours per day each observer will be assigned to work. 

(0018-6 [Poole, Mary Ann])

Comment: Please state the plan for protecting benthic communities for all alterations to the 

plant site affecting the marine environment. Please state the plan for protecting manatees, 

turtles, dolphins, sawfish, and other protected species from non-explosive dredging activities. 

Please state the plan for protecting manatees, turtles, dolphins, sawfish, and other protected 

species from explosive activities. (0022-3-21 [Reynolds, Laura])

Comment: The application proposes several wildlife underpasses to facilitate movement of 

crocodiles under construction roads within the plant boundary. Please provide a detailed 

analysis of how the specified locations were selected and how crocodiles that may occur 

outside the plant near linear features (such as the transmission lines, access roads and spoil 

disposal routes) will also be protected from disturbance. [Same statement for T-Lines] 

(0023-2-15 [LaFerrier, Marc])

Comment: Seasonal patterns of behavior of threatened and endangered species occupying 

Biscayne National Park, such as West Indian Manatees and American crocodiles, may occur if 

water salinity, temperature or quality changes as a result of construction or operation of 

Units 6&7 and non-transmission facilities. These impacts should be evaluated. 

(0025-3-29 [Kimball, Dan] [Lewis, Mark])

Response: The EIS will discuss the aquatic resources in the vicinity of Turkey Point in 

Chapter 2 and will consider potential impacts to benthic communities, fish, manatees, and sea 

turtles in Biscayne Bay and American crocodiles from building and operating proposed Turkey 

Point Units 6 and 7 (and planned mitigation) in Chapters 4 and 5. 
Appendix D 

NUREG–2176 D-82 October 2016 

Comment: lmpacts to submerged aquatic vegetation: Please submit a description of expected 

short term and long term anticipated impacts resulting from the proposed scope of work. 

(0023-1-18 [LaFerrier, Marc])

Response: The nature and extent of submerged aquatic vegetation will be discussed in 

Chapter 2 of the EIS. Potential impacts to submerged vegetation of building and operating 

proposed Turkey Point Units 6 and 7 will be discussed in Chapters 4 and 5, respectively. 

Cumulative impacts of operating the proposed units and other past, present, and reasonably 

foreseeable future actions that impact the same resources will be discussed in Chapter 7. 

Comment: Please provide documentation in support of this statement, including but not limited 

to a copy of the cited report with current data on nesting activity, nest success, hatchling sex 

ratios and survivorship, and survivorship to adulthood of juveniles hatched at Turkey Point over 

the period of record during which crocodile monitoring has been occurring at the Turkey Point 

power plant. [Same statement for T-Lines] (0023-2-14 [LaFerrier, Marc])

Response: The past and current populations of the American crocodile will be characterized 

and a description of the recent monitoring program for this species will be provided in Chapter 2 

of the EIS. 

Comment: The cumulative effects of the proposed Units 6&7 plants and non-transmission 

facilities will place considerable stress on an already vulnerable ecosystem and potentially 

cause harm to Biscayne Bay and adjacent coastal wetlands. Disturbances to estuarine, marine, 

and terrestrial habitats are likely to result from proposed Units 6&7 construction and operation. 

(0025-1-11 [Kimball, Dan] [Lewis, Mark])

Response: The potential impacts associated with building and operating proposed Turkey 

Point Units 6 and 7 will be discussed in Chapters 4 and 5 of the EIS, respectively. A discussion 

of the cumulative impacts associated with the proposed units will appear in Chapter 7. 

Comment: The operation of the RCWs would result in ... water volume and quality alterations 

posing a threat to ecosystem function of the nearshore habitats of Biscayne Bay. 

(0025-1-14 [Kimball, Dan] [Lewis, Mark])

Comment: The operation of the RCWs could potentially change sediment oxidation-reduction 

potential in seagrass beds and benthic communities, which should be considered an ecological 

impact. (0025-3-17 [Kimball, Dan] [Lewis, Mark])

Comment: The net reduction in positive groundwater flux to the benthic ecosystem will occur 

due to the operation of the RCW. Groundwater is an important source of freshwater for benthic 

communities and any reduction should evaluated for its associated impact. 

(0025-3-18 [Kimball, Dan] [Lewis, Mark])

Comment: Although the radial collector wells will be physically placed in the underlying aquifer 

and the laterals are not expected to extend into park boundaries, the primary source intake 

water is Biscayne Bay. Based on the design feature of horizontal production wells and 

preliminary hydrologic modeling, the cone of influence includes Biscayne National Park waters. 

The application design is for up to 124 million gallons per day to be withdrawn from these 
Appendix D 

October 2016 D-83 NUREG–2176 

surface waters. The groundwater modeling which predicts minimal impacts to the benthic 

organisms of the bay appears to consider the subsurface as a singular uniform, non-karst 

feature, which is not accurate. The groundwater modeling does not provide the degree of detail 

needed to determine impacts to the benthic organisms of the bay and Biscayne National Park, 

when the RCW system is operated. (0025-3-19 [Kimball, Dan] [Lewis, Mark])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Radial Wells and Construction Dewatering Withdrawals at 

Power Plant Site - The potential for the proposed withdrawals to adversely impact the ecology of 

Biscayne Bay. (0032-9 [Golden, James])

Response: The potential impacts of RCW operations will be discussed in Chapter 5 of the EIS. 

Comment: Essential Fish Habitat within the Project Area - Mangrove: The South Atlantic 

Fishery Management Council (SAFMC) designates mangroves as EFH for juvenile gray 

snapper (Lutjanus griseus), dog snapper (L. jocu), bluestriped grunt (Haemulon sciurus), spiny 

lobster (Panulirus argus), and pink shrimp (Farfantepenaeus duorarum). Mangrove habitats are 

ecologically important coastal ecosystems (Lugo and Snedaker 1974). At a recent meeting, 

FPL suggested that the mangrove habitat that would be impacted by the water treatment facility 

(approximately 50 acres) is composed of dwarf red mangroves (Rhizophora mangle) with 

hypersaline conditions and lack of direct connection to other wetlands or water bodies. These 

types of mangrove wetlands still provide ecological services including as a buffer against storm 

surges, they reduce shoreline erosion and turbidity, and absorb and transform nutrients. While 

this mangrove system may not be inhabited to a large degree by various life stages of federally 

managed fisheries, they may contribute dissolved and particulate organic detritus to estuarine 

food webs. They help shape local geomorphic processes and are important in the 

heterogeneity of landforms which provide shelter, foraging grounds and nursery areas for 

terrestrial organisms (e.g., through bird use as a rookery and feeding on fish). The root system 

binds sediments thereby contributing to sedimentation and sediment stabilization. 

(0033-1 [Croom, Miles])

Comment: Seagrass and Unconsolidated Bottom: SAFMC also designates seagrass as EFH. 

Species associated with seagrass include pink shrimp, spiny lobster, and estuarine life stages of 

various species within the snapper/grouper complex including adult white grunt (Haemulon 

plumieri); juvenile and adult gray snapper (Lutjanus griseus); juvenile mutton snapper (Lutjanus 

analis). Any bottom-disturbing activities within areas that are seagrass habitat must include 

best management practices to avoid impacting this habitat. SAFMC also designates soft bottom 

habitat as EFH because it plays an important role in the ecological function of coastal 

ecosystems by controlling fluxes of nutrients between the sediment and the water column. 

Shallow water, unconsolidated bottom also provides EFH by serving as nursery grounds for 

early life stages of benthic-oriented, estuarine-dependent species; refuges and feeding grounds 

for forage species and juvenile fishes (SAFMC 2009) and feeding grounds for specialized 

predators, including adult white grunts (Potts and Manooch 2001). (0033-2 [Croom, Miles])

Comment: Habitat Area of Particular Concern within the Project Area - SAFMC also identifies 

mangroves and seagrass as a Habitat Area of Particular Concern (HAPC) for several species 

within the snapper/grouper complex. HAPCs are subsets of EFH that are either rare, 
Appendix D 

NUREG–2176 D-84 October 2016 

particularly susceptible to human-induced degradation, especially important ecologically, or 

located in an environmentally stressed area. Federal actions with potential adversely impacts 

HAPCs will be more carefully scrutinized during the consultation process and subject to more 

stringent conservation recommendations. In addition, Biscayne Bay is an EFH-HAPC for spiny 

lobster. Biscayne Bay and the Biscayne National Park are also an EFH-HAPC for coral, coral 

reefs, and hardbottoms (SAFMC 1998). (0033-3 [Croom, Miles])

Comment: Essential Fish Habitat Consultation Requirements - The Magnuson-Stevens Act 

directs federal agencies to consult with NMFS when the agency’s activities may have an 

adverse affect on EFH. We recommend that the NRC coordinate closely with the NMFS Habitat 

Conservation Division to ensure the EFH assessment and NEPA documents contain sufficient 

detail, 50 CFR 600.10 to 600.920 describes the content required of an EFH assessment. 

Specifically, the components of an EFH assessment can be found at 50 CFR 600.920(e)(3) and 

(4) and are listed below (additional comments are provided in parentheses). The EFH 

assessment can be incorporated into the EIS or provided to NMFS under separate cover. 

Components of an EFH Assessment: 

1. Description of the action. (This section can reference relevant portions of the EIS.) 

2. Analysis of the potential adverse effects of the action on EFH and the managed species. 

3. Federal agency’s conclusions regarding the effects of the action on EFH. 

4. Proposed mitigation. (Unavoidable direct and indirect impacts to EFH will require 

compensatory mitigation.) 

5. Results of an on-site inspection to evaluate the habitat and the site-specific effects of the 

project. 

6. Views of recognized experts on the habitat or species that may be affected. 

7. Review of pertinent literature and related information. 

8. An analysis of alternatives to the proposed action. (This section can reference relevant 

portions of the EIS alternatives analysis.) 

(0033-4 [Croom, Miles])

Response: Essential fish habitat (EFH) and mangrove habitats near Turkey Point will be 

described in Chapter 2 of the EIS. The review team will also assess potential impacts on EFH, 

including mangrove resources, from building and operating proposed Turkey Point Units 6 and 7 

in an EFH assessment that will be forwarded to the National Marine Fisheries Service (NMFS) 

for review. The EFH assessment will be included in an Appendix of the EIS. 

Comment: [Determine] the impact on wetlands and nearshore surface and groundwater water 

quality in Biscayne Bay, including as it relates to CERP efforts to promote estuarine conditions 

in nearshore areas. (0023-1-36 [LaFerrier, Marc])

Response: The impacts of building and operating proposed Turkey Point Units 6 and 7 on 

wetlands and nearshore surface-water and groundwater quality will be discussed in Chapters 4 

and 5 of the EIS. Chapter 7 of the EIS will evaluate cumulative impacts, and include a 

discussion of how the proposed action might affect current or planned restoration activities in 

the vicinity of Turkey Point. 
Appendix D 

October 2016 D-85 NUREG–2176 

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 1.c Radial wells. Impacts to EFH associated with radial well construction and 

operation within Biscayne Bay should be fully evaluated. The evaluations should include an 

evaluation of impacts associated with extended use of the radial well system to include an 

evaluation of impacts to groundwater that is closely tied to surface water in this porous karst 

area and thereby supports fish and wildlife resources. (0033-7 [Croom, Miles])

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 1.e Radial wells. Impacts to EFH associated with radial well construction and 

operation within Biscayne Bay should be fully evaluated. The evaluations should include a 

survey and monitoring plan that would enable FPL to determine impacts from radial wells to 

localized habitats and the fish and wildlife that depend on them. (0033-9 [Croom, Miles])

Response: The potential impact of building and operating radial wells on aquatic resources will 

be discussed in Chapters 4 and 5 of the EIS, respectively. The review team will also assess 

potential impacts on EFH in an EFH assessment that will be forwarded to the NMFS for review. 

The EFH assessment will be included in an Appendix of the EIS. FPL's proposed monitoring 

program will be discussed in Chapters 2, 4, and 5. 

Comment: Other specific issues NMFS recommends for evaluation in the EIS or EFH 

assessment: 2. Deep-well injection. Please provide an evaluation of effects to fish and wildlife

resources from proposed deep-well injection activities. The evaluation should describe the fate 

(location and concentration over time), of any nuclides injected into the well. 

(0033-10 [Croom, Miles])

Response: The potential ecological impacts associated with deep-well injection of cooling 

tower blowdown will be discussed in Chapter 5 of the EIS. 

Comment: We would like to see a baseline survey and monitoring information for the radial 

collector wells, caissons, and lateral arms, with preferably a minimum of two years of data. This 

data should include sampling prior to, during, and at least one month after all radial collector 

well events. Identify and commit to modeling environmental responses such as water quality 

and fish and wildlife species that depend on seagrass and hard-bottom habitats. FWC staff can 

work with the applicant to identify species of interest. How will noise from well/pump operation 

affect fish and wildlife resources (particularly listed species) in the area of the lateral arms and 

the well caissons? Our staff is concerned that there might be a delayed impact on fish and 

wildlife resources if phenomena such as "frac-out" or subsidence of the bay bottom should 

impact on the radial collector wells and their associated lateral arms. Is this a possibility? If so, 

how will this possibility be avoided, and what contingencies will be in place if "frac-out" or 

subsidence does occur? Also, since radial collector wells have not yet been used in a 

saltwater environment, we suggest that FPL anticipate the potential for indirect impacts on 

fish and wildlife resource needs in the case where there might be a potential failure of the 

wells due to corrosion. (0018-10 [Poole, Mary Ann])

Comment: How will fish and wildlife resources over the lateral arms of the radial collector wells 

be affected by the construction of the wells? How will the lateral arms be "advanced from the 

caissons"? We would like to see a survey and monitoring program that specifically enables FPL 
Appendix D 

NUREG–2176 D-86 October 2016 

to determine the contribution of this part of the proposal to any impacts on the surrounding 

ecosystem, localized habitats and the fish and wildlife that depend on them. 

(0018-8 [Poole, Mary Ann])

Comment: FPL's response [to FDEP's SCA review] does not adequately address how benthic 

resources in the footprint of the RCWs and adjacent areas will not be significantly affected given 

the fact that at least 3% of the water will come from the Biscayne Aquifer, a source of freshwater 

inputs to the bay bottom, helping to support the benthic community. (0020-2 [Mulkey, Cindy])

Response: These comments refer to the Florida SCA, but express a concern that there is the 

potential for impact to benthic organisms in the vicinity of the RCWs. The potential impact of 

building and operating the RCWs on benthic resources will be discussed in Chapters 4 and 5 of 

the EIS, respectively. 

D.1.11 Comments Concerning Socioeconomics 

Comment: Additionally, as Mayor of Florida City, I'm concerned about our economy. And the 

building of these two power plants in our area will be an immensely beneficial operation as far 

as spurring our economy. Safety first along with environmental protection; those are the first 

issue. Even with the economic benefit, if we can't guarantee safety and protection of the 

environment, we'll have to get jobs elsewhere. But once those two criteria are met, then the job 

creation becomes immensely important to me. People with jobs don't care about that aspects of 

it; but people without jobs simply do. (0001-1-5 [Wallace, Otis])

Comment: Also, the gentleman that spoke before from the Chamber of Commerce, which I 

was a member of, stated that 4,000 jobs would be available for five years. And the gentleman 

who was just here before me said that 800 permanent jobs would be established. I would like 

to recall 1970 when Aerojet promised Florida City and Homestead that jobs would be created 

in the development of the Aerojet canal. Contractors were brought in from out of State and 

they got the jobs; nothing was done for the benefit of Florida City or Homestead, as you can 

see. I don't want to see this happen again if they decide to go ahead and approve nuclear 

plant 6 and 7. (0001-10-2 [Marinelli, Francis J.])

Comment: When I look at this opportunity for growth and expansion in an area that truly needs 

it, I, because of not just what someone has told me or what someone has talked about, but it is 

something that I've lived, I see the benefits of it. I see kids being able to get jobs and come 

back home to a community that they're so very proud of. I see adults being able to take care of 

their elderly family members because of the amount of revenue and commerce that is being 

sparked. So with some of you I agree and others I vehemently disagree. And I say that this is 

about jobs, but it is about lifestyle, it's about living, and it's about opportunity. (0001-17-1 [Diggs, 

Bill])

Comment: We are at a difficult time in our history in this country. Jobs are hard to come by; 

college kids that you've spent your life savings to send to school are having difficult time finding 

opportunities. I submit to you this: They'll either find it here or somewhere else. But at the end 

of the day this is our community. And I stand, if nothing else, but an example of what can 
Appendix D 

October 2016 D-87 NUREG–2176 

happen when community and business works together, because it's not just about jobs. It's 

about lifestyle; it's about faith; it's about hope. (0001-17-2 [Diggs, Bill])

Comment: Data shows that the nuclear power plants contribute significantly to local 

economies. These are averages. The creation of a nuclear power plant will result in a creation 

of 1400 to 1800 jobs during the construction, with peak employment at 2400. As we can see in 

the back, FP&L has 3600, so the numbers are better. Operating a nuclear power plant 

generates from 400 to 700 permanent jobs and these jobs pay 36 percent more than average 

salaries in the local area. Again, FP&L has 800 permanent jobs. These permanent jobs create 

an equivalent number of additional jobs in the local area and provide goods and services 

necessary to support the nuclear workforce such as grocery stores, dry cleaners, et cetera. 

We're looking forward to that. (0001-18-2 [Landeta, Hector])

Comment: Each year an average nuclear plant generates approximately 430 million in sales, 

goods, and services in the local community and nearly 40 million in total labor income. Again, 

they have better numbers. They see -- they have 6 billion -- 6 billion in economic benefits to 

local economy over the next decade. (0001-18-3 [Landeta, Hector])

Comment: We need jobs. My generation is coming into this hard economic times and we need 

jobs. You're promising 800 full-time jobs for South Florida for these two reactors. I graduated in 

a class of 935 students in Palm Beach County. That doesn't cover those people. That's about 

135 less jobs than there are people who graduated in my class. There are 23 high schools in 

Palm Beach County; there are 32 high schools in Miami-Dade. Do you think 800 jobs is going 

to make a dent in the number of young people looking to enter the work force in South Florida? 

(0001-19-7 [Ryan, Megan])

Comment: [T]here are 800 full-time employees at the site and approximately an equivalent 

number of contractors of the site. Now, those 1600 people, they're members of the community; 

they buy their gas in the gas stations; they go to the supermarkets; their children go to the 

schools. (0001-3-1 [Kiley, Mike])

Comment: We have to look at jobs. We have to build our economy back, a new economy that 

relies on growth. And the good news is that from this project it's anticipated that as many as 

4,000 or more jobs will be added through the construction phase which will last five to seven 

years. That would be a rich addition to the workforce in South Florida, which will benefit all of us 

in so many, many ways, but most importantly for those people who are out of work and looking 

for jobs. And we have so many people in the construction industry who have been hit hard by 

the downturn in the economy. (0001-5-3 [Johnson, Barry])

Comment: When the project is completed it will include 800 jobs -- 800 more jobs in South 

Dade; 800 more families in South Dade contributing to the growth of our community. And these 

are high-skilled well-paying jobs that our community needs. Those are the jobs that will build 

our future. (0001-5-4 [Johnson, Barry])

Comment: As the previous speakers have said, 4,000 jobs can be created by having Units 6 

and 7 built, and 800 permanent jobs -- not just any regular jobs, but high-paying engineering 

jobs and the like, can be provided by having 6 and 7 built. (0001-9-2 [Martinelli, Tom])
Appendix D 

NUREG–2176 D-88 October 2016 

Comment: We are here because of the proposed plans to build two atomic plants that will 

afford us the opportunity, after they are built at Turkey Point, to have a flourishing economy in 

the area. (0002-10-1 [Alexander, William])

Comment: The Chamber also sees with sympathy all the efforts surrounding the industry, the 

generating industry, and the production of electricity and energy. We also see that it will provide 

around 3,000 jobs, which is very, very important to us. We also are considering not just those 

3,000 temporary jobs, but also the 800 permanent jobs that would be left here in this region that 

sorely needs it right now. (0002-10-4 [Alexander, William])

Comment: What these jobs will do -- there's a long-term effect from these two plants. Not only 

are they going to provide thousands of jobs as they're being built here locally, these jobs are 

jobs that give a sufficient rate of pay, a living wage. And in addition to that, most of the workers 

that work on these projects will either receive some type of pension benefits or health and 

welfare. (0002-13-3 [Simpson, Roce])

Comment: One of the things you'll also notice when you come to the site is that there's 

800 full-time employees, and there's an additional 800 contractors that work at the site and call 

this community their home. They buy their gas in town, they go food shopping in this town, they 

use the local restaurants, their children go to the schools. (0002-5-4 [Kiley, Mike])

Comment: And you have to understand the economic impact and the economic value of a 

restored Biscayne Bay to the industries that are populated by a lot of folks who probably 

aren't here tonight; fisherman, recreational users, people that make their money off of that 

Bay. Those are jobs too, and those have major implications for what happens here in 

the future. (0002-6-3 [Grosso, Richard])

Comment: We need these new power plants. It provides jobs for honest people. You look at 

it. A lot of people -- to get in at a nuclear power plant you got to take a 500 question site 

[psych?] test, plus pass a background check. You are attracting a good crowd of people in this 

area, which is good economically, not to mention -- I believe there's one other nuclear power 

plant being built right now, which is Plant Vogtle, I believe in Georgia. And we can lead the way 

to supplying our power demands. (0002-7-3 [Snelson, Richard])

Comment: You look at it as far as local impact; the people, the training programs and stuff like 

that, it's going to provide a lot of permanent jobs for people. You look at all the foreclosures and 

the people that have lost their jobs. I think it's a win-win situation. (0002-7-4 [Snelson, Richard])

Comment: Nuclear energy is also a smart economic choice. Constructing plants has the ability 

to employ about 4,000 people at its highest rate of construction, and then it employs about 

500 specialized jobs, like Victor's, who came to the Pipeline Program at Miami-Dade. 

(0002-9-3 [Martinelli, Tom])

Comment: Another great reason to consider building two new reactors would be to imagine 

just how many jobs it would create. In a downed economy such as this, jobs are a hard thing to 

come by; but upon the unveiling of two nuclear reactors, a significant job growth is to be 

expected -good jobs to boot, not just a medley of entry level positions. This will in turn spike the 
Appendix D 

October 2016 D-89 NUREG–2176 

cash flow in the South Florida area and analogously pass on to corporate and private 

businesses alike. (0003-4-4 [Accursio, James])

Comment: In addition to jobs, it will also stimulate the economy by commencing the required 

construction spending to the county which thusly stimulates millions of dollars in property tax. 

These taxes are passed on to schools, colleges, educational institutions, economic growth 

firms, and many other governmental organizations; giving them the financial injection they need 

in these hectic times. (0003-4-5 [Accursio, James])

Comment: Ensure the full scope of the proposed project's fiscal impacts is calculated. The 

location of the plant; transmission lines and associated facilities; the rate increase, which is 

proposed to precede the actual construction phase of the project; and additional direct costs 

that will be incurred by Miami-Dade County and its municipalities (including but not limited to 

fire, police; etc) over the life of the project should be taken into account and be incorporated into 

economic and fiscal analyses. (0019-1 [Hamilton, Karen])

Comment: Ensure the economic benefits of the proposed expansion project, such as 

employment and capital expenditures, are realized by the residents of South Florida. 

(0019-2 [Hamilton, Karen])

Response: The expected socioeconomic impact of building and operating proposed Turkey 

Point Units 6 and 7, including impacts on local employment and earnings, local tax revenues, 

in-migration, local infrastructure, and public services will be presented in Chapters 4 and 5 of 

the EIS. The cumulative impacts of the proposed action and other past, present, and 

reasonably foreseeable actions will be presented in Chapter 7. 

Comment: So what that means is, that we're not going to have massive amounts of people, 

like we do now, going to Jackson Hospital and other community hospitals that have no health 

insurance, putting the burden back on the taxpayers to be able to furnish health insurance for 

these people. There is an endless line of people who are retired that have no income, waiting 

on Section 8 housing and other types of housing that they can get into and live in the twilight of 

their years. This will, in a lot of cases, prevent that from happening. (0002-13-4 [Simpson, Roce])

Response: The expected impact of building and operating proposed Turkey Point Units 6 and 

7 on the capacity use of local medical services will be evaluated in Chapters 4, 5, and 7 of the 

EIS. 

Comment: To be more specific to the lodging industry, which I'm part right now, this power 

plant would produce a stabilizing effect on the local economy. It will compliment the tourism 

industry. And as maybe you know this, especially people from FP&L, refueling takes place 

every 18 to 24 months for each reactor and brings several hundred workers from outside the 

local area who stay in the hotels, motel, and eat in our local restaurants. Each reactor 

alternates its refueling schedule, usually resulting in at least one refueling or significant 

equipment installation per year, typically for us during a slack part of the tourist season. 

(0001-18-5 [Landeta, Hector])
Appendix D 

NUREG–2176 D-90 October 2016 

Response: The impacts on the economy and infrastructure, including recreation and housing, 

will be addressed in Chapters 4, 5, and 7 of the EIS. 

Comment: You say that tourism is going to be affected because people coming to work here 

are going to need hotels and restaurants. But I thought you said that you wanted to create jobs 

for people who already live here, so we should not be talking about tourism because it's already 

affected enough by the Gulf oil spill. (0001-19-8 [Ryan, Megan])

Response: The impacts of building and operating proposed Turkey Point Units 6 and 7 on both 

local and in-migrating labor and indirect impacts of job creation on the local economy will be 

addressed in Chapters 4, 5, and 7 of the EIS. 

Comment: Regarding the ability to have jobs and provide jobs for the area. Right now MiamiDade College offers an internship program in nuclear power and practice. And interns right now 

from Miami-Dade College working at the FP&L Plant at Turkey Point are making $19 to $20 an 

hour as an intern before they even set foot on the property as a full-time licensed person. So, 

you know, what I think is marvelous is that they are a good partner; they run a very safe, very 

secure practice. And the expansion I think only solidifies our future as a great, great place to 

live, that being Homestead/Florida City down here. (0001-20-5 [Daley, Dennis])

Comment: Turkey Point has had a growing demand for highly-skilled workers, and we 

understand that they could soon experience workforce shortages, largely due to retirements. As 

a result we, together, developed an Associate in Science Degree program in electrical power 

technology. And I would be here to tell you this today, that that program has been extremely 

successful. It was targeted for a very diverse population of incumbent workers at Florida Power 

& Light Turkey Point and our college students. Graduates from this program meet the 

qualifications to work in positions in nuclear and non-nuclear facilities. To date we have had 

63 students to graduate from the program. And I might add that the program began in 2006. Of 

those 63 graduates, 36 are currently working at Turkey Point and 20 are in the process of being 

hired. This has truly been a success story for Florida Power & Light and Miami-Dade College. 

It has enriched our community. (0001-4-2 [Jacobs, Jeanne])

Comment: Briefly I would like to discuss training with you. For this undertaking of the 

construction of Units 6 and 7, we're looking at jobs for over 4,000 building tradesmen. Building 

tradesmen within the State of Florida who are either licensed by their trade and/or have the 

training that is necessary to go out and build this facility correctly, on budget, and on time. I can 

speak on behalf of the Florida Carpenters, that we do not send a single person out to that plant 

for any piece of operation that is not properly credentialed and trained. And I can also tell you 

that the rest of the building trades, that's their same philosophy. (0001-8-3 [Johnson, Michael])

Comment: Along with the fact that we're going to be able to provide these jobs for working 

men and women during the time of construction, a lot of young people will go out there on those 

particular projects and be trained with a skill in a technical high-level industry and be able to 

take those skills back out into the community and be able to work on other projects and sustain 

their families for the rest of their lives. And in addition to that, for those of you that don't realize 

it, once these plants are built that's not the end of it. People will go back on a regular basis to 
Appendix D 

October 2016 D-91 NUREG–2176 

maintain, update, and upgrade these plants. It's a system that is good for the community, good 

for the workers. (0002-13-5 [Simpson, Roce])

Response: Impacts on local employment will be addressed in Chapters 4, 5, and 7 of the EIS. 

Comment: I do want to say that I think the whole discussion of the jobs that might be brought 

to this community, it is and should be irrelevant to an environmental study. I know that there is 

a socioeconomic aspect of it, and we're going to be addressing the socioeconomic, again very 

adverse impacts if the transmission lines were to go along the U.S. 1 corridor. 

(0001-21-7 [Lerner, Cindy])

Comment: I can understand that folks in Florida City and Homestead may be interested in 

grabbing that relatively small amount of jobs that could come from an investment that's focused 

down here. But speaking regionally, of course, that's money that's taken out of the hides of 

everyone in the rate base. If it came right down to trying to make more jobs, well, with this 

amount of money I figure we could build about 50 new sports arenas for billionaire ball teams 

and the Heat, I think they deserve a new arena by now. That other one is getting old and 

they've got these three new players. It's not just about jobs. And I think in reality that should 

pretty much be out of scope for our discussion. (0001-24-5 [Harum-Alvarez, Albert])

Response: The Council on Environmental Quality guidance for implementing NEPA includes a 

discussion of economic or social effects when these are interrelated with natural or physical 

environmental effects. NRC guidance for implementing NEPA includes the analysis of 

employment impacts from construction and operation activities (including transmission lines) 

among the socioeconomic impacts to be analyzed in environmental reviews of nuclear power 

plants. The socioeconomic impacts of construction and operation of proposed Turkey Point 

Units 6 and 7 will be assessed in Chapters 4, 5, and 7 of the EIS. 

Comment: And, by the way, all the folks that are up here talking about jobs. I took a job about 

a month ago with a solar company installing solar installation panels on a ranger station in 

Biscayne National Park. That is as blue collar a job as any blue collar work I've ever done; it's 

construction work; it's electrical work; it's roofing; it's tiling. It's blue collar work, it produces lots 

of jobs. People sometimes think solar is people going up to a rooftop and meditating on the sun 

or something like that. It's nothing to do with that. It's the construction trades installing solar 

panels which are existing right now. The jobs that this plant will create are located in 

Homestead. If we did solar on rooftops throughout the service area of FP&L, we would be 

creating jobs throughout their entire service area. That's a big consideration. 

(0002-14-4 [Schwartz, Matthew])

Response: Alternative energy sources, including solar power, will be discussed in Chapter 9 of 

the EIS. 

Comment: People come to South Dade to go to Everglades National Park or Biscayne 

National Park. Business in the area benefit from that tourism and provide services to people 

who are going to visit those parks. So people will be affected and the locals in that way as well. 

(0002-16-3 [Shlackman, Mara])
Appendix D 

NUREG–2176 D-92 October 2016 

Comment: Construction of transmission towers and access roads in either corridor could 

impact visitor experiences. Heavy equipment including dump trucks, bulldozers, excavators and 

cranes would be used for construction of transmission lines. Qualities of the existing visitor 

experience such as primitiveness and solitude may be impacted. (0025-3-38 [Kimball, Dan] 

[Lewis, Mark])

Comment: Natural vistas provide park visitors with an immediate and lasting sensory 

experience that strongly conveys the character of a national park. The proposed transmission 

lines, towers and associated roads could adversely affect the visitor's appreciation of the visual 

viewshed over large areas. The transmission lines and structures would be visible within the 

park for many miles away. Because of the flat topography and the broad unobstructed vistas, 

visitors on the Tamiami Trail, and to a lesser extent, visitors to Shark Valley and the Chekika 

areas, as well as visitors on airboat tours, would be able to see the transmission lines and 

structures. The transmission facilities would be an intrusion on the natural scenery of the 

Everglades and detract from the visitors' ability to appreciate the park. For visitors near the 

L 31-N canal, the towers and transmission lines would dominate the viewshed. These impacts 

would be permanent. A separate viewshed analysis should be prepared for scenic and visual 

impacts on the visitor experience. (0025-3-39 [Kimball, Dan] [Lewis, Mark])

Comment: Similar impacts to viewsheds could occur elsewhere in the Western Transmission 

Corridor in Water Conservation Area 3B, north of the park, the Southern Glades Management 

Area, east of the park and in the Model Lands between U.S. 1 and the Turkey Point site. 

(0025-3-40 [Kimball, Dan] [Lewis, Mark])

Comment: Short-term impacts would be expected from construction and maintenance 

activities and transmission line monitoring overflights. A corona effect from the proposed new 

lines (audible noise) may increase in the long-term. (0025-3-46 [Kimball, Dan] [Lewis, Mark])

Response: The expected impact of building and operating proposed Turkey Point Units 6 and 

7 on local recreational areas, including Everglades National Park and Biscayne National Park, 

will be assessed in Chapters 4, 5, and 7 of the EIS. 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of the creation of construction jobs, temporary jobs, and permanent jobs, 

please provide them. (0022-4-16 [Reynolds, Laura])

Response: This potential impacts of building and operating proposed Turkey Point Units 6 and 

7 on employment and the effects of job creation on the local infrastructure and public services 

will be discussed in Chapters 4, 5, and 7, based on the affected environment described in 

Chapter 2. The EIS will include citations for documents used in its preparation. 

Comment: Transportation Subsection indicates that the Homestead Extension of Florida's 

Turnpike (SR 821) and South Dixie Highway (US 1/SR 5) are the major transportation corridors 

for north-south movement in Miami-Dade County. The traffic impact data and analyses 

presented in Appendices 10.7.4.1 (Traffic Study Peak Construction) and 10.7.4.2 (Traffic Study 
Appendix D 

October 2016 D-93 NUREG–2176 

Operations Analysis) does not consider the impact of the construction and operation of Units 6 

and 7 on these two regional corridors. (0023-2-23 [LaFerrier, Marc])

Comment: The assertion that the proposed access road from the Turkey Point Units 6 and 7 

site to theoretical SW 137 Avenue along theoretical SW 359 Street will be improved within the 

transmission line right-of-way is premature. The traffic studies contained in 

Appendices 10.7.4.1 and 10.7.4.2 do not consider other alternative roadways such as 

SW 344 Street and transportation demand management strategies. (0023-2-24 [LaFerrier, Marc])

Comment: [Miami-Dade County Planning and Zoning] staff have the following concerns 

regarding the traffic study: the assumptions; the methodology; the impact study area; the lack of 

consideration of alternative roadways including SW 328 Street and SW 344 Street; and the lack 

of consideration of transportation demand management programs to reduce the overall traffic 

demand and use of single occupant vehicles. (0023-2-25 [LaFerrier, Marc])

Comment: The consultant should identify the programmed transportation projects located 

within the Study Area for roadways and intersections listed in the 2010 Transportation 

Improvement Program (TIP); and identify the planned transportation projects located within the 

Study Area listed in Priority I, II and III of the 2030 Long Range Transportation Plan. 

(0023-2-26 [LaFerrier, Marc])

Comment: The expected increase in non-development traffic and traffic from other previously 

approved and unbuilt development should be accounted for in the future years. 

(0023-2-27 [LaFerrier, Marc])

Comment: Prior to the assumption of new roadway construction (SW 359 Street), traffic impact 

analyses with the existing and improved existing roadways for concurrency year (usually 

3 years in the future), construction opening year (2011), construction peak year (2016) and 

normal operational year (2020) should be provided. (0023-2-28 [LaFerrier, Marc])

Comment: Please note that LOS standards for roadways outside UDB are different than within 

UDB (0023-2-29 [LaFerrier, Marc])

Comment: Include bicycle facilities as part of the road construction. (0023-2-4 [LaFerrier, Marc])

Comment: Options for shuttle service should be explored. (0023-3-1 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the potential impacts of the proposed plant on transportation. The 

potential impacts of building and operating proposed Turkey Point Units 6 and 7 on 

transportation will be discussed in Chapters 4, 5, and 7, based on the affected environment 

described in Chapter 2. 

Comment: Application does not supply sufficient design and placement information on Eastern 

corridor and location-specific pole placement to determine whether this activity is well designed 

and conducive to both pedestrian and transit use, and architecturally attractive. 

(0023-3-34 [LaFerrier, Marc])
Appendix D 

NUREG–2176 D-94 October 2016 

Response: This comment refers to the SCA submitted to the State of Florida by FPL, but it 

indicates an interest in the potential impacts of the proposed transmission lines on land use, 

transportation, and aesthetics. The potential impacts of building and operating the transmission 

lines on land use, transportation, and aesthetics will be discussed in Chapters 4, 5, and 7, 

based on the affected environment described in Chapter 2. 

Comment: The proposed access roads are outside the existing site of the FPL power plant and 

are therefore subject to land use/zoning consistency determinations. Such access roadways will 

be subject to amendments to the Comprehensive Development Master Plan (CDMP). 

(0023-1-53 [LaFerrier, Marc])

Comment: Application fails to consider the County's Greenway Plans and Parks and Open 

Space System Master Plan. The County's Preferred Corridor for the proposed Biscayne Trail 

Segment D and a portion of the southern route of the Biscayne-Everglades Greenway is located 

along the north side of SW 328 St. (North Canal Dr.). (0023-2-2 [LaFerrier, Marc])

Comment: The County's Preferred Corridor for the Biscayne Trail north-south leg is located 

along SW 137 Av. from SW 328 Av. to Card Sound Rd. The County's Preferred Corridor for the 

southeastern leg of the Biscayne Trail also extends southeast along the L-31 E canal from 

SW 328 St. to Card Sound Rd. (0023-2-3 [LaFerrier, Marc])

Comment: Information is not provided on how activities will impact approved Urban Centers 

and their respective Regulating Plans and will be in compliance with the County's Urban Design 

Manual. (0023-3-36 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL, but 

they indicate an interest in the consistency of proposed Turkey Point Units 6 and 7 with existing 

zoning and land use plans. The general consistency of building and operating the proposed 

units with existing zoning and land-use plans will be discussed in Chapters 4, 5, and 7. 

Comment: [A]pparently this would represent for the economy, after the 40 years of the building 

when the two plants are finally working, savings in energy costs for about $90 million. So, we 

believe this is very important. We have analyzed the project and realize that when the two 

plants that will be built here at Turkey Point are finally constructed, this will afford us the things 

that we need in order to have a better future. We, thus, once again, applaud FPL for its vision 

and for the time that it has invested in providing us with a better opportunity for our future. 

(0002-10-3 [Alexander, William])

Response: This comment refers to savings in fuel costs projected for the life of the proposed 

project as part of the State of Florida's Determination of Need. Need for power will be 

addressed in Chapter 8 of the EIS. The expected socioeconomic impact of building and 

operating proposed Turkey Point Units 6 and 7, including impacts on local employment and 

earnings, local tax revenues, in-migration, local infrastructure, and public services, will be 

discussed in Chapters 4, 5, and 7. 

Comment: The plant is there. Fortunately we've had the plant. It's the Government's idea of 

trying to provide South Florida power has made us where we've grown to this point, where we 
Appendix D 

October 2016 D-95 NUREG–2176 

have this power, where we have the development that we have. Okay. We have to keep going. 

It's not going to stop unless we put doors up there on the county line that says, we can't move 

anybody else in here. I don't see any difference between a plant down there and using the 

water, okay, or another 40,000 people moving into Dade County every two years. 

(0002-12-5 [McHugh, John])

Response: This comment suggests impacts on resources such as water would occur 

independently of the units. Impacts on water and other resources will be discussed in 

Chapters 4, 5, and 7 of the EIS. 

D.1.12 Comments Concerning Historic and Cultural Resources 

Comment: This office reviewed the referenced project for possible impact to historic 

properties listed, or eligible for listing, in the National Register of Historic Places. The review 

was conducted in accordance with Section 106 of the National Historic Preservation Act of 

1966, as amended, 36 CFR Part 800: Protection of Historic Properties and the National 

Environmental Policy Act of 1969, as amended. In October 2008, December 2008, March, 2009, 

and April 2009, Janus Research conducted an archaeological and historical Phase I survey of 

the proposed Turkey Point Units 6 & 7 site, associated non-linear facilities, and spoils areas on 

plat property on behalf of the Florida Power & Light Company. Janus Research identified no 

cultural resources within the project area during the investigation. Our office found the 

submitted report complete and sufficient in accordance With Chapter 1 A-46, Florida 

Administrative Code. Based on the information provided, it is the opinion of this office that the 

proposed development will have no effect on historic properties. However, we also concur with 

Janus Research that, prior to construction, an unanticipated finds plan should be developed to 

outline the procedures and identify personnel to be contacted if significant archaeological 

material or human remains are encountered during construction. In 2009, Janus Research 

conducted background research to identify previously recorded archaeological resources 

within 100 feet and historic cultural resources within 500 feet of the associated linear facilities, 

and to identify areas of high, medium, and low probability for the presence of unrecorded 

cultural resources. (0013-1 [Kammerer, Laura])

Comment: Of particular concern would be design compatibility related to shadows, traffic, 

height, bulk and scale of architectural elements and how pole placement and design will 

address these standards. (0023-3-32 [LaFerrier, Marc])

Comment: Design details, including proposed materials, visual buffering, complementary 

vegetation, and fencing must be addressed to determine consistency with LU-4D for each 

proposed new pole and corridor alignments generally. (0023-3-33 [LaFerrier, Marc])

Comment: Archeological surveys of the entire West Transmission Corridor will be needed. An 

archeological survey conducted in 2009 in FPL's West Preferred Corridor within ENP found no 

evidence of prehistoric humans. (0025-3-41 [Kimball, Dan] [Lewis, Mark])

Comment: Our utmost concern will be to ensure that areas of archaeological importance will 

be indentified and protected from any ground disturbing activities, and that all designated 

historic sites and structures, as well as those eligible for designation, will be identified, 
Appendix D 

NUREG–2176 D-96 October 2016 

documented and protected from any new construction or view shed obstruction associated with 

both the new on-site structures and the transmission line corridors and related structures. 

(0026-1 [Kauffman, Kathleen])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 on historic and cultural resources will be discussed in Chapters 4, 5, and 7, based on the 

affected environment as described in Chapter 2. The EIS will include citations for documents 

used in its preparation. As stated in the application, an unanticipated-finds plan will be 

developed. 

Comment: The application states that the Florida Master Site File forms (FMSF) maintained by 

the Bureau of Historic Preservation, Division of Historical Resources were reviewed to 

determine whether any historic or archaeological sites were in the areas of potential effects. 

However, the County's Office of Historic and Archaeological Resources was not given the 

opportunity to determine whether these areas impacted locally designated sites or sites which 

have been determined as eligible for designation. In addition, the application makes the 

assumption that the probability of impacts on undiscovered sites is considered extremely low. 

This conclusion is not supported without coordination with the Office of Historic and 

Archaeological Resources. Sites that the County has surveyed and identified, but may have not 

yet designated, would not necessarily be recorded in FMSF forms. (0023-2-1 [LaFerrier, Marc])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 on historic and cultural resources will be discussed in Chapters 4, 5, and 7, based on the 

affected environment described in Chapter 2. The information sources from the Miami-Dade 

County Office of Historic and Archaeological Resources will be considered in this assessment. 

The EIS will include citations for documents used in its preparation. 

Comment: We are aware that the Department of State's Division of all Historical Resources 

has already made recommendations. We concur with those recommendations and also offer the 

following: 

1. For all areas that have not been previously surveyed, our staff shall be notified once 

surveying has commenced. The County archaeologist will have the opportunity to comment 

on any new visual surveys performed to determine areas of high archaeological probability. 

2. We concur with the development of an unanticipated finds plan, and request that the Office 

of Historic and Archaeological Resources be added to the contact list, should a find occur. 

3. View sheds and view corridors shall be considered during the identification of the Area of 

Potential Effect as part of the surveys for potential impacts to historic sites and structures. 

4. Copies of all new FMSF forms, created as a result of historic or archaeological resource 

surveys, shall be provided to our office. 

5. The Office of Historic and Archaeological Resources shall have the opportunity to review 

and comment on any survey findings related to historic resources or eligible resources that 

are found within or in close proximity to the transmission line corridors. 

6. The Office or Historic and Archaeological Resources shall be included in determining the 

Area of Potential Effect (APE) and shall be permitted to review and comment on any 

additional reconnaissance level historic resource surveys conducted in such areas. 

(0026-2 [Kauffman, Kathleen])
Appendix D 

October 2016 D-97 NUREG–2176 

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 on historic and cultural resources will be discussed in Chapters 4, 5, and 7, based on the 

affected environment described in Chapter 2. The EIS will include citations for documents used 

in its preparation. The Florida State Historic Preservation Office and Miami-Dade County will be 

consulted in accordance with the National Historic Preservation Act. 

D.1.13 Comments Concerning Meteorology and Air Quality 

Comment: In addition, we would like you to consider in the environmental impact statement, 

the impacts that 30 million gallons a day of steam being released into the atmosphere could 

have on wildlife, Biscayne Bay, and, of course, agriculture (0001-7-7 [MacLaren, Kaitlin])

Comment: According to FPL information, the six cooling towers for TP 6&7 will evaporate 

41.5 MGD of water which will be .0005% particulates. That is 20,750 gallons of particulates 

24/7. The FPL model diagram shows the dispersion of that vapor in a neat pattern around the 

plant assuming average wind conditions. However, the average does not fully reflect the many 

days down here when the wind blows from the SE at 15 to 25 MPH for hours on end. That 

would carry the now condensed and concentrated residue of TP over the people and the crops 

to the west and northwest. (0016-2 [White, Barry])

Comment: [T]he effect of aerial dispersal of biocides from the cooling towers on surrounding 

areas, including surface and groundwater. (0023-1-16 [LaFerrier, Marc])

Comment: The atmospheric deposition from the cooling towers is projected to extend into the 

surface waters of Biscayne National Park. Atmospheric deposition rates and for EPOCs from 

the proposed cooling towers should be quantified and include incremental projections over the 

life span of Units 6&7. (0025-3-25 [Kimball, Dan] [Lewis, Mark])

Response: The reactor cooling system including the water treatment, its operation and steam 

released to the atmosphere, and associated salt drift and other potential impacts of the coolingsystem operation will be discussed in Chapter 5 of the EIS. 

Comment: Construction related emissions and other temporary or secondary emissions are 

not included in the PSD emissions analysis. The impacts from these activities on air quality 

should be discussed qualitatively in the Draft EIS. Air emissions of criteria and toxic pollutants 

should be addressed. A discussion of the designation status of the area in which the units will 

be built should also be included in the document. Finally, the Draft EIS should discuss any 

issues or concerns regarding obtaining the required Title V operating permit once the units are 

operational. (0014-21 [Mueller, Heinz])

Comment: Please state the cumulative emissions of construction activities for each of the 

greenhouse gases including water vapor, carbon dioxide, methane, nitrous oxide, and ozone. 

(0022-4-3 [Reynolds, Laura])

Comment: Please state the cumulative emissions of operation activities for each of the 

greenhouse gases including water vapor, carbon dioxide, methane, nitrous oxide, and ozone. 

(0022-4-4 [Reynolds, Laura])
Appendix D 

NUREG–2176 D-98 October 2016 

Response: Environmental impacts associated with building and operating nuclear plants, 

including greenhouse gas emissions, will be addressed in EIS Chapters 4, 5, and 7, 

respectively. Greenhouse gas emissions associated with the fuel cycle will be presented in 

Chapter 6. A discussion of the status of air quality in the area will be presented in Chapter 2. 

Comment: Nuclear plants also do not operate well in hot conditions, as evidenced by recent 

instances in the US and France where nuclear plants shut themselves down, due to high 

temperatures in the environment. (0021-11 [Wilansky, Laura])

Response: The reactor cooling system, including the water-source treatment and heat 

dissipation during operation, will be discussed in Chapter 3 of the EIS. The potential impacts of 

the cooling-system operation will be addressed in Chapter 5 of the EIS. The existing 

climatological conditions and projected change in temperature over the licensing period will be 

discussed in Chapter 2. 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the varieties and concentrations of airborne "emerging pollutants of concern" (EPOCs) as a 

result of using reclaimed wastewater for cooling purposes, please provide them. 

(0022-2-1 [Reynolds, Laura])

Comment: Please state, specifically, all additives and all additive quantities that will be 

released to the atmosphere in gaseous, particulate, or droplet form, from the cooling towers and 

cooling water (0022-4-2 [Reynolds, Laura])

Comment: There is concern that constituents in the cooling water will be emitted in the 

aerosol/drift exhaust from the cooling towers.... (0023-1-26 [LaFerrier, Marc])

Comment: Provide technical discussion and analysis of the effect that the cooling tower (heat 

transfer) process has on the reclaim water constituents and the facility's air emissions (both 

criteria and hazardous air pollutants). Source water analysis constituents to be addressed 

include: total dissolved solids, total suspended solids, salinity, organics, metals, and 'EPOCs' 

(emerging pollutants of concern) addressed in USGS 2006 Report identifying organic 

wastewater compounds, pharmaceutical compounds, antibiotic compounds, and hormones 

detected in effluent from the South District WW Treatment Plant). In addition to PM and PM10, 

provide emissions calculations for other criteria pollutants and hazardous air pollutants. 

(0023-1-28 [LaFerrier, Marc])

Comment: The COL proposes the use of tertiary treated wastewater as the primary cooling 

water supply source for Units 6&7. The environmental risk associated with the aerial dispersal 

and possible subsurface release of micro-constituents, sometimes referred to as Environmental 

Pollutants of Concern (EPOCs), commonly associated with treated waste water requires further 

evaluation. Treated wastewater from municipal sewage commonly includes pharmaceuticals 

and personal care products (PPCPs), as well as various endocrine disrupter compounds 

(EDCs), and frequently heavy metals and other contaminates not normally removed in tertiary 

treatment. (0025-2-3 [Kimball, Dan] [Lewis, Mark])
Appendix D 

October 2016 D-99 NUREG–2176 

Response: Potential impacts to the aquatic and terrestrial ecology environment, via the air 

pathway impacts associated with cooling tower “drift” as a result of using reclaimed water in the 

cooling towers, will be discussed in Chapters 5 and 7 of the EIS, based on the affected 

environment as described in Chapter 2. 

Comment: Please state the amount of heat that will be discharged into the atmosphere from 

units 6&7 and state the temperature differential between the discharged heat and the 

atmosphere. Please state the amount of water vapor that will be discharged into the 

atmosphere from units 6&7 and state the moisture differential between the discharged water 

vapor and the atmosphere. (0022-2-16 [Reynolds, Laura])

Response: The reactor cooling system, including the water-source treatment and heat 

dissipation, will be discussed in Chapter 3 of the EIS. The potential impacts of the coolingsystem operation on the frequency of plume visibility will be addressed in Chapter 5 under 

meteorology and air quality. The affected atmospheric environment, including temperature and 

moisture, will be discussed in Chapter 2. 

Comment: Please state the amount of change units 6&7 will make to local weather conditions. 

Please state the amount of change units 6&7 will make to hurricane formation, intensity, and 

longevity. Please state the amount of change units 6&7 will make to tornado formation, 

intensity, and longevity. (0022-2-18 [Reynolds, Laura])

Response: The impacts of operating proposed Turkey Point Units 6 and 7 on local 

meteorology will be presented in Chapter 5 of the EIS. The staff will consider in its evaluation 

whether more remote potential meteorological impacts from the plant are likely. However, past 

experience with large power stations would indicate that there would be no impact to the 

formation, intensity, or longevity of tornados and hurricanes. 

Comment: The application does not provide sufficient information to determine facility 

emissions for the limestone mining operations and grading & fill activities. 

(0023-3-16 [LaFerrier, Marc])

Response: Environmental impacts associated with building proposed Turkey Point Units 6 and 

7 will be addressed in Chapter 4 of the EIS. The impacts of building-related air emissions, 

including those from activities at FPL-owned fill sources and from grading and fill activities, will 

be estimated. 

Comment: Applicant needs to provide information sufficient to determine whether open burning 

operations would be consistent with the requirements of Chapter 24. (0023-4-7 [LaFerrier, Marc])

Response: Environmental impacts associated with building proposed Turkey Point Units 6 and 

7 will be addressed in Chapter 4 of the EIS. The building-related air emissions and related 

impacts on air quality, as well as the emissions from any open burning of vegetation, will be 

estimated. 
Appendix D 

NUREG–2176 D-100 October 2016 

Comment: The application provided insufficient details related to the General Purpose Diesel 

Engines on what equipment the engines are to service or what fuel tanks and day tanks will be 

associated with the engines. (0023-4-8 [LaFerrier, Marc])

Comment: Construction and maintenance activities would impact air quality. 

(0025-3-45 [Kimball, Dan] [Lewis, Mark])

Response: Environmental impacts associated with building and operating proposed Turkey 

Point Units 6 and 7 will be addressed in EIS Chapters 4 and 5, respectively. Emissions 

associated with diesel fueled engines will also be discussed in Chapters 4 and 5. 

D.1.14 Comments Concerning Health – Nonradiological 

Comment: These two gigantic, enormous 1,000 megawatt each nuclear generators are going 

to be cooled with recycled sewage. Let's say that, recycled sewage. That's what's going into 

these cooling towers. There's no way to get all the pharmaceuticals, all the chemicals that we 

flush down our toilets, out of that water that's going to be going through these plants. When that 

water goes through the cooling towers they're going to be released to steam, droplets are 

coming out with that water vapor, and lots of stuff is going to be in those droplets. Lots and lots 

of those chemicals are going to be in those droplets. And that's going to be sprayed out over 

Biscayne National Park, Biscayne Bay, and the City of Homestead, which already has extremely 

dubious air and water to begin with for many of the reasons people have talked about. 

(0002-14-7 [Schwartz, Matthew])

Comment: And what about the workers at the plant who will have to breath that stuff 8 hours a 

day? What would OSHA say about that? And the particulates will be a concentration of every 

carcinogen known to man, having come originally from waste water. What TP 6&7 really is is 

the best still in the world for concentrating the highest amount of pollutants and efficiently 

distributing it over the land. (0016-3 [White, Barry])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts on humans and/or the environment of airborne pathogens from the Turkey 

Point FPL power station as a result of using reclaimed wastewater for cooling purposes, please 

provide them. (0022-1-15 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the number of fatal and non-fatal diseases from airborne toxic matter as a result of using 

reclaimed wastewater for cooling purposes, please provide them. (0022-1-18 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the varieties and concentrations of known airborne toxic matter as a result of using reclaimed 

wastewater for cooling purposes, please provide them. (0022-1-20 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 
Appendix D 

October 2016 D-101 NUREG–2176 

the number of fatal and non-fatal diseases from airborne EPOCs as a result of using reclaimed 

wastewater for cooling purposes, please provide them. (0022-2-2 [Reynolds, Laura])

Response: These comments concern the impacts of chemicals in the cooling tower drift from 

proposed Turkey Point Units 6 and 7 on the public and workers. The planned reactor-cooling 

system, including the use of reclaimed water and saltwater, along with water treatment, the 

expected vapor and droplet release to the atmosphere and associated “drift,” and associated 

potential impacts, will be discussed in Chapter 5 of the EIS. These impacts will be assessed 

within the context of the affected environment described in Chapter 2. Cumulative impacts from 

past, present, or reasonably foreseeable future actions will be discussed in Chapter 7, and 

alternatives to the proposed cooling system will be discussed in Chapter 9. The EIS will include 

citations for documents used in its preparation. 

Comment: I've also heard that transmission lines would buzz, cause radiation problems that 

may cause cancer, especially breast cancer, in a lot of people, as well as that it might go 

through our Everglades as well as down US-1. (0002-8-6 [O'Katy, Jessica])

Comment: [CASE submitted an article titled, "Recent Biomedical Literature on Health Risks of 

Power Transmission Lines" by Philip Stoddard, Dept Biological Sciences, Florida International 

University. The article expressed concern about exposure to magnetic fields.] 

(0003-2-1 [White, Barry])

Comment: Information on the potential degradation of health, safety, tranquility, character, and 

overall welfare of residential neighborhood conditions with respect to transmission line corridors 

has not been provided. Information should include recent academic studies regarding EMFs and 

high kV electrical transmissions. (0023-3-35 [LaFerrier, Marc])

Comment: The health of our children and families will be in grave danger! Peer reviewed 

medical literature shows Alzheimer's and senile dementia rates are doubled in people living 

near power lines. (0031-3 [De Villiers, Elena])

Response: These comments concern the impacts of living near transmission line corridors. 

Health and/or other impacts from noise, electromagnetic fields, and/or land use associated 

with the planned upgrade and construction of transmission lines will be addressed in 

Chapters 4 and 5 of the EIS, based on the affected environment described in Chapter 2. 

Cumulative effects will be addressed in Chapter 7. 

Comment: Areas surrounding the Turkey Point nuclear power plant are at high risk for 

exposed pollutants, including asbestos, mercury, and 174 detected carcinogens including 

tritium which was found to be leaking from over a quarter of all nuclear plants in the 

United States. Expanding the ground that Turkey Point inhabits would bring these pollutants 

closer to the National Park reserve areas, bringing endangered and rehabilitated marine life 

and ecology into severe danger. (0007-4 [Burris, Jessica])

Response: This comment concerns the potential impacts on biota of pollutants released from 

proposed Turkey Point Units 6 and 7. The ecological health impacts of radiological and nonradiological releases from nuclear power plants during building and operating the proposed 
Appendix D 

NUREG–2176 D-102 October 2016 

units will be discussed in Chapters 4 and 5 of the EIS, respectively, within the context of the 

affected environment described in Chapter 2. The cumulative impacts from the proposed action 

when added to those of past, present, or reasonably foreseeable future actions will be 

discussed in Chapter 7. 

Comment: Consider the full the impacts of noise and light pollution concerns to people, 

animals, native plants and wetlands, environmentally endangered lands, and provide the 

appropriate mitigation strategies. (0019-6 [Hamilton, Karen])

Comment: Potential soundscape impacts may increase over current levels in Biscayne 

National Park from construction, operation and security (additional overflights by military jets). 

These impacts should be assessed and quantified. (0025-3-28 [Kimball, Dan] [Lewis, Mark])

Response: These comments concern the potential impacts of noise and light in the environs of 

proposed Turkey Point Units 6 and 7. The potential impacts of noise and light pollution on the 

public and the environment during the building and operating of the proposed units will be 

addressed in Chapters 4 and 5 of the EIS, respectively, within the context of the affected 

environment described in Chapter 2. Cumulative impacts from the proposed action when added 

to those of past, present, or reasonably foreseeable future actions will be discussed in 

Chapter 7. 

Comment: The generation of hazardous wastes (as defined in Section 24-5) and other 

regulated non-hazardous wastes is mentioned throughout the application. The size of tanks or 

containers is not specified nor their locations, nor details of the release detection methods or 

pollution prevention measures to be implemented. (0023-1-11 [LaFerrier, Marc])

Response: This comment concerns the management of hazardous and non-hazardous wastes 

for proposed Turkey Point Units 6 and 7. The impacts from the generation, handling, and 

disposal of hazardous and non-hazardous waste material from building and operating the 

proposed units will be addressed in Chapters 4 and 5 of the EIS, respectively, within the context 

of the affected environment described in Chapter 2. Cumulative impacts from the proposed 

action when added to those of past, present, or reasonably foreseeable future actions will be 

discussed in Chapter 7. 

D.1.15 Comments Concerning Health – Radiological 

Comment: The NRC knows full well that in 1988 and 1990, Congress passed the Radiation 

Exposed Veterans Compensation Act and stipulated that 21 categories of cancer are 

attributable either as a causative or contributory factor to the exposure to ionizing radiation from 

radioactive fallout. The NRC knows full well that induced genetic damage and genetic 

mutations are precursors from manifesting over 21 categories of cancer as stipulated by the 

Congress. The NRC knows full well that cancer is a genetic process and that ionizing radiation 

causes genetic damage and that genetic damage and cancer are inextricably intertwined. You 

cannot separate the two. However, the NRC disingenuously avoided mention in its 

supplemental environmental impact statement of August 2007, in a Diablo Canyon license 

proceeding, that small children -- they omitted this -- that small children, pregnant women, 

women of childbearing age, and the elderly are seriously impacted and vulnerable to acquiring 
Appendix D 

October 2016 D-103 NUREG–2176 

induced genetic damage from exposure to ionizing radiation of a magnitude as little as 5 rems. 

Now, because of the concerns linking ionizing radiation to genetic damage, the Atomic Energy 

Commission provided the initial funding for the Human Genome Project. Most people don't 

know that. That Project today is jointly funded by your parent organization, the Department of 

Energy, and the National Institutes of Health. (0001-13-6 [Smilan, Stan])

Comment: The health effects on communities has not been adequately studied, and the 

presence of childhood leukemia clusters in the vicinity of nuke plants raises serious questions 

about the possible connections. It is to these curious questions about the environmental 

impacts on public health that I request that the NRC add to its scope of inquiry. (0001-16-4

[Showen, Steve])

Comment: Public health is ultimately what you affect most in your decision-making. We can't 

go back to FPL, or the M. Dade Com. College Homestead, or your members in our Capitol in 

10 years and say please cleanse out our circulatory systems of our bodies and replace them. 

Vulnerable people depend on your wisdom now in history to choose the safest path for the 

citizens. (0011-1 [, Anonymous])

Comment: We should not create the GUARANTEED RISK of radiation, toxic waste, birth 

defects, cancers, fish kills, and all the other consequences which can and will result from 

building Turkey Point 6 and 7. (0021-14 [Wilansky, Laura])

Comment: I ask you to include the true costs of nuclear plants throughout their entire life cycle 

in your environmental calculations, including the reality of enormous risks to health and life. 

(0021-19 [Wilansky, Laura])

Response: These comments concern possible health effects from radiation exposure. 

Chapter 5 of the EIS will address the potential radiation doses and the associated health effects 

from operation of proposed Turkey Point Units 6 and 7. 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. These radiation standards reflect extensive scientific study by national 

and international standard setting 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. 

Comment: In addition, the public is largely unaware that radioactive emissions are permitted 

legally in normal operations of nuclear plants. Also, a number of nuke plants have leaked 

radioactive effluent into underground drinking aquifers. (0001-16-3 [Showen, Steve])

Comment: I was looking at some of the documents you left in the back of the room. And in 

terms of tritium your own periodical says, nuclear power plants have reported abnormal 

releases of water containing tritium resulting in groundwater contamination. This is spooky stuff. 

And we would hope that any such releases would not go anywhere outside the boundary if such 

releases actually occur, and that information, if it's out there, would be immediately released to 

agencies that deal with water resources so we can deal with the potential implications as a 

result of such potential contamination. (0002-3-7 [Walker, Tom])
Appendix D 

NUREG–2176 D-104 October 2016 

Comment: One function of wetlands is to filter water as it runs through its natural ecosystem 

before reaching primary waterways where it is likely to be ingested. In addition to adding 

pollutants to the Biscayne area outside of Turkey Point with this proposed expansion the 

reduction of wetlands in the area will cause further harm by the natural reduction of water 

filtration before entering the surrounding communities. This includes the reduction of a filtration 

system for radioactive leakage present in groundwater leakage that is normally released from all 

U.S nuclear power plants. The NRC permits up to 400 gallons per day of low level leakage to 

be deposited into the environment surrounding nuclear power plants. Without wetlands to filter 

this pollution, residents of the surrounding area are directly vulnerable to this waste. 

(0007-5 [Burris, Jessica])

Response: These comments concern the potential release of radioactive material to the 

environment by proposed Turkey Point Units 6 and 7. Chapter 5 of the EIS will address the 

expected releases of radioactive material in liquid and gaseous effluents, the impacts of those 

releases on humans and biota other than humans, and the applicant's effluent and 

environmental radiological monitoring systems. The results of a licensees radiological effluent 

and environmental monitoring systems are publicly available in the ADAMS Public Electronic 

Reading Room and are accessible at http://www.nrc.gov/reading-rm/adams.html. 

Comment: [A]lso just got my water report reading from Miami-Dade. And I found it interesting 

that not only was there uranium, which we don't have here in our water, but that the levels of it 

were much higher closer to Turkey Point than they were in Northern Miami. I thought that was 

very interesting. And when I read the reason for uranium being in the water, it said that it was 

from natural sources. So I found that to be extremely worrisome. (0002-8-8 [O’Katy, Jessica])

Comment: Tritium and Strontium 90 are present in the area and research is currently being 

done to establish their levels and concentrations (0012-8 [Payne, Nkenga])

Response: These comments concern the presence of radioactive materials in the environment 

near proposed Turkey Point Units 6 and 7. Chapter 2 of the EIS will address the current 

radiological environment at the proposed site for the proposed units. 

Comment: Two new, unnecessary plants are guaranteed to bring more leaks and more 

radioactive waste to South Florida, and will endanger us that much more. 

(0021-9 [Wilansky, Laura])

Comment: At the NRC scoping meeting held in July, a handout (USNRC BACKGROUNDER, 

February 2010) was available which stated that Nuclear power plants have reported abnormal 

releases of water containing Tritium, resulting in groundwater contamination. This is also 

discussed on your website under operating reactors. Obviously, the potential leakage of Tritium 

from the Turkey Point nuclear power plant is a concern to be analyzed. With this in mind, FKAA 

request that any Tritium test results from the existing cooling water canals and the aquifer 

system adjacent to these canals be released for review. If there has been leakage above the 

background levels in the existing system, continued rate of analysis should be required at more 

stations, and the source and remedy be found. Also, whether or not there is Tritium above 

background levels in the existing system, the EIS should include the requirement for continued 
Appendix D 

October 2016 D-105 NUREG–2176 

measurements of Tritium at the interface of the reactors including water canals, strategic 

monitoring points, and downstream monitoring locations. (0024-4 [Walker, Tom])

Response: These comments concern potential groundwater contamination by inadvertent 

leaks of liquids containing tritium from the Turkey Point site. Chapter 2 of the EIS will address 

the current radiological environment at the proposed site for proposed Turkey Point Units 6 and 

7. Chapter 5 of the EIS will discuss the applicant's effluent and environmental radiological 

monitoring systems for the proposed units. 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of deep well injection of radioactive wastes including annual expected amounts 

and the expected cumulative amount of each isotope for the duration of the requested operating 

license, please provide them. (0022-4-10 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of airborne radioactive releases to the atmosphere including best practices, 

precautions, the cumulative number of expected non-lethal cancers, and the cumulative number 

of expected lethal cancers for the duration of the requested operating license, please provide 

them. (0022-4-11 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse radiological impacts of units 6 & 7 as a result of a sea level rise of 10 meters, please 

provide them. (0022-4-12 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of leaking buried pipes, please provide them. (0022-4-15 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of securing the storage of low-level solid radioactive wastes, including 

locations, structures, containers, damage from missiles, airborne solid wastes, water ingress 

and egress, fires, and cleanup, in the event of a tornado watch or warning is issued for the 

Turkey Point area, please provide them. (0022-4-8 [Reynolds, Laura])

Response: These comments concern the radiological impacts of operation of proposed Turkey 

Point Units 6 and 7, including storage of low-level wastes, release of liquid and gaseous 

effluents; and inadvertent pipe leaks. These impacts will be addressed in Chapter 5 of the EIS. 

The EIS will include citations for documents used in its preparation. 

D.1.16 Comments Concerning Nonradiological Waste 

Comment: The use of hazardous materials (e.g. treatment chemicals, solvents, paints, 

lubricants, etc.) is mentioned throughout the application for maintenance operations, water and 
Appendix D 

NUREG–2176 D-106 October 2016 

wastewater (influent and effluent) treatment systems. The size of tanks or containers is not 

specified nor are their locations identified. In addition, no details of the release detection 

methods or pollution prevention measures to be implemented are provided. 

(0023-1-60 [LaFerrier, Marc])

Comment: Liquid waste other than domestic sewage will be generated, used, and handled at 

the proposed facility which is not connected to sanitary sewer. The application did not provide 

sufficient information to evaluate the project with regard to requirements of Section 24-43.1 of 

the code of Miami-Dade County. (0023-1-8 [LaFerrier, Marc])

Response: The generation, management, and treatment or disposal of nonradiological waste 

will be discussed in Chapters 4 and 5 of the EIS. 

D.1.17 Comments Concerning Accidents – Severe 

Comment: Miami-Dade is an extremely population dense area with 1158 people per square 

mile. Although FP&L and Westinghouse state that the probability of a severe accident is very 

low for the AP1000, this reactor design has never been built or operated anywhere in the world. 

(0001-14-9 [Hancock, Mandy])

Response: This comment concerns the potential for severe accidents at proposed Turkey 

Point Units 6 and 7. The impacts of postulated accidents including severe accidents will be 

addressed in Chapter 5 of the EIS. 

D.1.18 Comments Concerning the Uranium Fuel Cycle 

Comment: With the addition of the nuclear power plant 6 and 7, it will be doubling the waste 

that's being stored out at Turkey Point. I ask the Nuclear Regulatory Commission, what is being 

done nationally for the storage of nuclear power plant waste? I don't see enough being done 

nationally for the storage and safety of this nuclear waste. (0001-10-1 [Marinelli, Francis J.])

Comment: Waste is contained and moved, a potential problem. It is moved to Yucca Mountain 

that's sitting on a fault line. We are saying it's safe for now but the safety has not been proven. 

(0001-11-5 [Amor, Valerie])

Comment: As the NRC is aware, FPL already operates three reactors here in Florida and is 

proposing to build two more. FPL also proposes to build an onsite storage facility to deal with 

the high level radioactive waste already overflowing in the spent fuel pools. This amount of 

radioactivity clustered in such a population-dense, hurricane-prone area could create significant 

safety and health concerns for Floridians. The NRC must address these cumulative impacts. 

(0001-14-8 [Hancock, Mandy])

Comment: Tons and tons of nuclear waste are already stockpiled at this plant right now. They 

were cited. They were fined recently by the Nuclear Regulatory Commission for failure to take 

care of that waste. There's no place to put it; by the way, there's no place to move it. 

(0002-14-13 [Schwartz, Matthew])
Appendix D 

October 2016 D-107 NUREG–2176 

Comment: I'd also like to say that from what I've learned at school, that uranium transportation 

and storage is very dangerous and not something that we should be risking people and the 

environment's well-being for. (0002-8-2 [O'Katy, Jessica])

Comment: I am not a nuclear scientist, but my understanding at this time is that the main 

concern regarding nuclear energy is how to safely store the waste material. If there is a 

scientific answer to this problem that is safe, I think America would be wise to pursue increasing 

our use of nuclear energy. (0005-2 [Bass, Ken])

Comment: [T]he economic and ecological risks associated with the entire nuclear power fuel 

cycle, are vast, including the long term of safeguarding nuclear waste produced at Turkey Point. 

(0012-13 [Payne, Nkenga])

Comment: It is unacceptable to even think of disposing highly toxic and radioactive substances 

anywhere on or in our beautiful Earth as we do not know the consequences - and there is 

nothing to stopgap or in place in case these substances have a dire reaction on the earth. 

(0028-5 [DiNuzzo, Laura])

Comment: On the surface, the "greener" than dirty coal theme sounds good. Given there are 

positives and negatives to most situations, this green theme would be the positive. However, all 

of us involved, including FP&L, would be remiss if we did not consider the negative. In this 

case, the negative is the stored, on site radioactive waste generated by the Turkey Point plant, 

and more reactors mean more radioactive waste. This negative must be factored into the 

greener theme to reflect the true cost of the nuclear facility. Has FP&L factored in this critical 

cost of how to dispose of radioactive nuclear waste, or will they just continue to store it on site 

(in a hurricane prone, sea level environment)? Will FP&L send it to an undetermined repository 

(if one is ever mandated) and at what cost? While the front end looks green, the back end looks 

dirty. Objectively, the big picture must be duly considered. Decisions that are narrow, shortsighted and reactionary lead to a vulnerable position that can escalate into insurmountable 

problems (think BP oil, Chernobyl, 3 Mile). Until the above mentioned negatives are resolved, 

expansion magnifies potential problems. (0029-3 [Guendelsberger, Debra])

Response: These comments concern the transportation and disposal of high-level radioactive 

waste, such as spent fuel. The impact of the uranium fuel cycle, including disposal of high-level 

radioactive waste and spent fuel, will be addressed in Chapter 6 of the EIS. 

Comment: That's just the tip of the iceberg. There are so many different aspects to a building 

of these two additional nuclear power plants at Turkey Point. When they built them in 1972 they 

had never heard of anything such as global warming, such as rising sea levels. Out of their 

consciousness. Presently, five miles from here is over 2 million pounds of nuclear waste. Five 

miles from here. As soon as the sea level covers all that up, God knows what's going to 

happen. (0001-2-4 [Harris, Walter])

Comment: When sea level rises, what's that going to do to a nuclear plant built in the middle of 

Biscayne Bay, with storage -- with nuclear waste that cannot be moved because there's 

nowhere to put it. So this is an extreme danger to our community. 

(0002-14-8 [Schwartz, Matthew])
Appendix D 

NUREG–2176 D-108 October 2016 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse radiological impacts of spent fuel storage as a result of a sea level rise of 10 meter. 

(0022-4-13 [Reynolds, Laura])

Response: The environmental impacts of operating and decommissioning proposed Turkey 

Point Units 6 and 7, including potential impacts associated with sea level rise, will be considered 

in Chapters 5, 6, and 7 of the EIS. 

Comment: One thing we should consider is, this is not an energy source that gives so-called 

energy independence. The great bulk of the uranium comes from outside the United States, 

and there are greenhouse gas emissions in the process of the extraction and processing of that 

uranium. (0002-16-5 [Shlackman, Mara])

Comment: In the big environmental picture, companies like FPL that want to build nuclear 

plants are trying to sell the idea that nuclear energy is a solution to global warming. In fact, the 

opposite is true. Nuclear energy is neither carbon-free nor emission-free throughout its entire 

life cycle, which includes a variety of wastes produced by mining uranium and making nuclear 

fuel, in addition to the aforementioned unsolved problem with spent fuel and other nuclear 

waste. This waste includes the plants themselves, which operate for a few decades, and then 

take, at a minimum, hundreds of years to be decommissioned. (0021-10 [Wilansky, Laura])

Response: These comments concern the greenhouse gas emissions of the entire fuel cycle 

and the operation of proposed Turkey Point Units 6 and 7. The impacts of greenhouse gas 

emissions from the life-cycle of fuel production, construction, operation, and decommissioning of 

the units will be presented in Chapters 4, 5, and 6 and an appendix of the EIS. 

Comment: We now have the technology to recycle spent nuclear rods. Look to France as a 

prime example as nuclear energy as a viable energy resource. (0006-2 [Weins, Brian])

Response: This comment concerns the potential for recycling spent nuclear fuel. The potential 

environmental impacts of the fuel cycle from recycling only the uranium from spent nuclear fuel 

will be addressed in Chapter 6 of the EIS. Recycling uranium and plutonium from spent nuclear 

fuel will not be addressed in the EIS. While Federal policy no longer prohibits recycling, 

additional research and development is needed before commercial recycling of spent fuel from 

U.S. nuclear power reactors would occur. 

Comment: I feel that uranium is not a long-term answer and so that expansion of Turkey Point 

would not start until a long term after we need it, and that it wouldn't last for that long because 

we do not have uranium here and we don't have enough of it. (0002-8-7 [O'Katy, Jessica])

Response: This comment concerns the availability of uranium to fuel proposed Turkey Point 

Units 6 and 7. The irretrievable and irreversible commitment of resources, such as uranium, will 

be addressed in the context of the resources availability in Chapter 10 of the EIS. 

Comment: I ask you to include the true costs of nuclear plants throughout their entire life cycle 

in your environmental calculations, including the cost of hundreds of years of plant 
Appendix D 

October 2016 D-109 NUREG–2176 

decommissioning; and the cost of nuclear waste storage for thousands of years to come. 

(0021-21 [Wilansky, Laura])

Response: This comment concerns the cost of the entire fuel cycle including decommissioning 

and waste disposal. The costs of proposed Turkey Point Units 6 and 7 throughout their entire 

life cycle, including the costs of decommissioning and nuclear waste storage, will be discussed 

in Chapter 10 of the EIS.

D.1.19 Comments Concerning Decommissioning 

Comment: This site will also be under SEVERAL FEET of water if global warming continues as 

it has, or worsens, as scientists predict. If you think killing an oil well is difficult underwater, try 

decommissioning a nuclear plant! (0021-6 [Wilansky, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse radiological impacts of decommissioning units 6&7 as a result of a sea level rise of 

10 meters. (0022-4-14 [Reynolds, Laura])

Response: The potential environmental impacts of decommissioning proposed Turkey Point 

Units 6 and 7 will be addressed in Chapter 6 of the EIS. The EIS will include citations for 

documents used in its preparation. 

D.1.20 Comments Concerning Related Federal Projects 

Comment: The Comprehensive Everglades Restoration Project is a major priority for the 

Federal and State Government. (0002-6-4 [Grosso, Richard])

Comment: Models and study explaining how preliminary design of the water management 

project will tie to the CERP Environmental Restoration Project (Alternative O) missing. 

(0023-3-9 [LaFerrier, Marc])

Comment: [The National Park Service has] identified a number of concerns regarding 

potential adverse impacts of the proposed facilities to the resources and values of Biscayne 

and Everglades National Parks, to regional water resources and to the Biscayne Bay 

Coastal Wetlands project, a component of the Comprehensive Everglades Restoration Plan 

(CERP). (0025-1-1 [Kimball, Dan] [Lewis, Mark])

Comment: The CERP Biscayne Bay Coastal Wetlands preferred plan, Alternative 0, includes 

plans to rehydrate wetlands in the vicinity of the proposed Turkey Point power plant site and 

poses a conflict with the COL application proposal to extract up to 124 million gallons per day 

from Biscayne Bay. The restoration project objective is to re-establish both overland freshwater 

flow and subsurface flow, which is intended to improve ecosystem function by stabilizing 

seasonal salinity patterns. Therefore, it appears likely that the withdrawal of Biscayne Bay 

water for cooling water supply is incompatible with the restoration goals, since it will intercept a 

percentage of the freshwater intended for restoration. (0025-2-14 [Kimball, Dan] [Lewis, Mark])
Appendix D 

NUREG–2176 D-110 October 2016 

Comment: The SFWMD is currently reviewing a Site Certification Application (SCA) for this 

project, pursuant to the State of Florida's Power Plant and Electrical Transmission Line Siting 

Act (Sections 403.501-403.539, Florida Statutes). During the SCA review process, the SFWMD 

has identified a number of issues that have the potential to result in significant adverse regional 

water resource-related impacts, including potential impacts to specific CERP projects and 

related restoration initiatives. (0032-1 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Reclaimed Water Pipeline - The potential for adverse impacts 

to the CERP Biscayne Bay Coastal Wetlands Project. (0032-18 [Golden, James])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Electrical Transmission Lines - The potential for adverse 

impacts to the construction schedule for the U.S. Army Corps of Engineers (USACE) Seepage 

Management Pilot Project, which is a component of the CERP Project. The work on the 

USACE project will take place within the western levees of the SFWMD's L-30 and 

L-31N Canals, which are located within the West Preferred Corridor. The SFWMD is a 

participating partner with the USACE in this project. Work is scheduled to begin soon and may 

still be ongoing when FPL commences construction of the proposed transmission lines. 

(0032-20 [Golden, James])

Response: The review team has been consulting with, and will continue to consult with, State 

and Federal agencies in preparing the EIS. The USACE is a cooperating agency on the 

development of the EIS and is a key agency in the implementation of the CERP. The 

cumulative impact of the proposed action when added to the impacts of other past, present, and 

reasonably foreseeable projects, including the CERP and proposed Turkey Point Units 6 and 7, 

will be considered in Chapter 7 of the EIS. 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of operation of the Turkey Point FPL power station on Biscayne National Park, 

in the past, currently, and in the future, please provide them. To the extent that you are aware 

of any documents or reports by any federal, state, local or regional government agency, FPL or 

any of its employees or contractors that relate to adverse impacts of operation of the Turkey 

Point FPL power station on Everglades National Park, in the past, currently, and in the future, 

please provide them. To the extent that you are aware of any documents or reports by any 

federal, state, local or regional government agency, FPL or any of its employees or contractors 

that relate to adverse impacts of operation of the Turkey Point FPL power station on 

Comprehensive Everglades Restoration Plan (CERP) Projects and CERP related projects, in 

the past, currently, and in the future, please provide them. To the extent that you are aware of 

any documents or reports by any federal, state, local or regional government agency, FPL or 

any of its employees or contractors that relate to adverse impacts of operation of the Turkey 

Point FPL power station on the Everglades Mitigation Bank, in the past, currently, and in the 

future, please provide them. (0022-1-13 [Reynolds, Laura])

Comment: Construction and operation of transmission lines, pads and access roads in either 

corridor within ENP is likely to adversely affect park operations such as fire management, exotic 
Appendix D 

October 2016 D-111 NUREG–2176 

vegetation management and law enforcement. 2. Specific adverse effects to fire management 

would include increased fire activity due to the inherent threat of uncontrolled ignitions from 

transmission lines, limited accessibility to areas to engage in fire suppression activities due to 

gates and security issues on FPL land, and an increase in staffing levels based on fire danger 

rating. Transmission lines in either corridor would limit the park's ability to use aircraft for fire 

suppression in the area, especially along the eastern boundary. (0025-3-42 [Kimball, Dan] 

[Lewis, Mark])

Comment: Inappropriate use of park lands could become an issue. Construction of access 

roads would introduce new areas for unauthorized all terrain vehicle use, dumping and other 

unforeseen uses which would result in adverse impacts to park law enforcement operations and 

sensitive natural resources. (0025-3-44 [Kimball, Dan] [Lewis, Mark])

Response: The potential impacts of building and operating the proposed units on nearby 

parks, the CERP, and the Everglades Mitigation Bank will be discussed in Chapters 4 and 5 of 

the EIS, respectively. The cumulative impacts of the proposed action when added to the 

impacts of other past, present, and reasonably foreseeable actions including those identified in 

this comment will be presented in Chapter 7. The EIS will include citations for documents used 

in its preparation. 

Comment: In addition the proposed rock mining project, which is planned within the Biscayne 

Bay Coastal Wetlands footprint, violates Miami-Dade County's comprehensive development 

master plan and interferes with the planned restoration project and could worsen saltwater 

intrusion and chloride contamination in Biscayne aquifer which is, of course, South Florida's 

primary drinking water supply. (0001-7-6 [MacLaren, Kaitlin])

Comment: No data provided to assess groundwater Impact as a result of the fill extraction and 

construction of the water management feature. (0023-3-11 [LaFerrier, Marc])

Comment: No mitigation plan found for possible salt front advancement as a result of rock pit 

mining. Planned fill source lies approximately 4 miles to the northeast of MDWASD Newton 

Wellfield. (0023-3-12 [LaFerrier, Marc])

Comment: The application does not contain sufficient water quality and geotechnical 

information needed in order to evaluate the proposed FPL fill source. Given that the salt front 

exists at the proposed rockmining site, FPL must provide data including modeling under normal 

and drought conditions. (0023-3-15 [LaFerrier, Marc])

Comment: The application does not provide sufficient information to determine that the 

proposed excavation will not extend into groundwater containing 250 mg/L or greater chloride. 

(0023-3-17 [LaFerrier, Marc])

Comment: Application does not provide the following data/information related to the FPL-filed 

CDMP amendment application for rock mining in Agriculturally designated land: 1. Plan and 

data for the design of the leave-behind water management project, including technologies to be 

used during and after excavation to ensure that the project's waters are isolated from any 

present or future salt intruded groundwater. (0023-3-3 [LaFerrier, Marc])
Appendix D 

NUREG–2176 D-112 October 2016 

Comment: Sufficient water quality data for the site not provided. (0023-3-7 [LaFerrier, Marc])

Comment: No studies provided to assess project's impact to surrounding agricultural wells or 

public wellfields under worst case conditions. (0023-3-8 [LaFerrier, Marc])

Comment: The COLA proposes the excavation of fill material for the construction of the 

Units 6&7 Plant from a nearby FPL owned site behind the Homestead Air Force Base (HAFB) 

and adjacent to Biscayne National Park, although the FPL fill-source is no longer part of the 

State of Florida SCA. FPL intends to excavate a large amount of rock fill (approximately 

300 acres) to elevate the proposed reactor construction site from approximately 1 foot above 

mean sea level to 26.5 feet above mean sea level. These activities will result in a large manmade lake, as a by-product of rock mining operations. The presence of this new lake would 

conflict with CERP design features planned for the Biscayne Bay Coastal Wetlands project 

because the lake would inhibit groundwater flow to the southeast and possibly exacerbate salt 

water intrusion inland. (0025-2-16 [Kimball, Dan] [Lewis, Mark])

Response: Available information about the fill source will be provided in Chapter 3 of the EIS. 

The impacts of obtaining fill material will be presented in Chapter 4; and the cumulative impacts 

of the proposed action by FPL to build and operate proposed Turkey Point Units 6 and 7, along 

with other past, present, and reasonably foreseeable future actions by other agencies, will be 

presented in Chapter 7, including the impacts associated with the CERP. 

Comment: Location and design approval from the Homestead Air Reserve Base for the 

project's conformance with AICUZ recommendations regarding bird strikes and other potential 

navigational hazards has not been provided. (0023-3-10 [LaFerrier, Marc])

Response: This comment refers to the SCA submitted to the State of Florida by FPL, but it 

indicates an interest in FPL's proposed plant design. A description of the site layout, the reactor 

type, and the cooling-water systems will be described in Chapter 3 of the EIS. 

Comment: The applicant shall also address how road construction and operation would 

compromise the ability of the EEL Program and other agencies to appropriately manage public 

lands. (0023-1-51 [LaFerrier, Marc])

Comment: Please provide amended maps showing EEL projects, along with a complete 

analysis of the effects of linear feature construction and operation on nearby EEL Projects. 

(0023-3-21 [LaFerrier, Marc])

Comment: Environmentally Endangered Lands (EEL) owned and/or managed preserves exist 

along proposed corridors. Please provide an analysis of the potential impacts to EEL Preserves 

from any work related to the transmission lines, including but not limited to development of 

corridors, acquisition to corridors, acquisition of additional easements, etc. 

(0023-3-28 [LaFerrier, Marc])

Comment: Maps in the site certification application fail to depict conservation lands held and/or 

managed by the Environmentally Endangered Lands (EEL) Program. For example, the maps 

depicting jurisdictions fail to include MDC EEL holdings. Direct, indirect and cumulative impacts 
Appendix D 

October 2016 D-113 NUREG–2176 

to these lands associated with any of the proposed work or changes in hydrology is not 

addressed and needs to be detailed. (0023-3-45 [LaFerrier, Marc])

Comment: Permitted land use within EEL acquisition project areas must be compatible with 

the environment and objectives of the Comprehensive Everglades Restoration Plan (CERP) and 

shall not adversely affect the long-term viability, form or function of these ecosystems. Any land 

use or site alteration should be carefully evaluated on a case by case basis by federal, state, 

regional and county agencies for conformity with all prevailing environmental regulations and 

compatibility with the objectives of CERP. Land Use Element LU-3B states that all significant 

natural resources and systems shall be protected from incompatible land use. Conservation 

Objective CON-4 and Policy CON-4A of the CDMP recognize the importance of these wetlands 

for their aquifer recharge and storage capacity and states these values shall be maintained, 

enhanced or restored. Objective CON-7 and related policies state that Miami-Dade County shall 

protect and preserve the biologic and hydrologic functions of the Future Wetlands identified in 

the Land Use Element. (The Future Wetlands includes all of the South Dade Wetlands area). 

Some of the proposed features are within Environmental Protection Sub Areas E and F of the 

CDMP which both require that the approval of any use and access roads or easements should 

be conditioned on demonstrated consistency of that use with the adopted goals, objective and 

policies of the CDMP and conformity with all prevailing environmental regulations. 

(0023-3-46 [LaFerrier, Marc])

Response: These comments refer to the SCA submitted to the State of Florida by FPL but they 

indicate an interest in how activities associated with building and operating proposed Turkey 

Point Units 6 and 7 would affect efforts being taken under the Environmentally Endangered 

Lands (EEL) Program. The EIS will address the cumulative impacts from the combination of the 

proposed action and past, present, and reasonably foreseeable actions, regardless of who 

takes the actions. The cumulative impacts associated with building and operating the proposed 

units will be evaluated for each affected resource. 

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Temporary Roadway Improvements for Construction of 

Units 6 & 7 - The potential for adverse impacts to the CERP Biscayne Bay Coastal Wetlands 

Project. (0032-15 [Golden, James])

Response: The EIS will address the cumulative impacts from the combination of the proposed 

action and past, present, and reasonably foreseeable actions, regardless of who takes the 

actions. The cumulative impacts associated with building and operating the proposed units will 

be evaluated for each affected resource. 

D.1.21 Comments Concerning Cumulative Impacts 

Comment: In addition to the ongoing problems from the existing facility, the combination of 

losing wetlands and worsening saltwater intrusion could significantly impact the habitats, water 

quality, surface flow, projected restoration of water levels, and groundwater hydrology functions 

that are the object of the Everglades restoration. Construction of the plant itself, as well as the 

operation of the facility, will have adverse impacts on water quality, ecology, and aesthetics of 
Appendix D 

NUREG–2176 D-114 October 2016 

the Biscayne National Park. It will negatively impact the areas' protected species, wetlands, 

and much-needed fresh groundwater input into Biscayne Bay. (0001-2-3 [Harris, Walter])

Comment: A final comment is that the -- the current -- the existing, in Units 4 and 5, as the 

previous speaker mentioned, are impacting our groundwater supply. And it is suspected that 

they are contributing to saltwater intrusion. And so we would like you to consider the cumulative 

effects of existing plants and then consider what additional impact a new plant will have. 

(0001-7-8 [MacLaren, Kaitlin])

Comment: One of the most important things that the NRC can do as a function of the 

environmental review of this application is to evaluate the cumulative environmental impacts 

from all of these plants. After all, the reactors are called 6 and 7, not 1 and 2. Just evaluating 

this application as if the proposed plants exist in a vacuum, as the State is doing through their 

permitting process, would be a disservice to the community and to our environment. The NRC 

needs to evaluate the impacts of the two new reactors. Direct impacts like wetland losses, 

dredge fill pads, permanent onsite nuclear waste storage and temporary 20-year roads through 

an Everglades Restoration Project, in the context of the impact already caused by the existing 

power plant complex. (0002-1-2 [Sorenson, Katy])

Comment: The Draft EIS should discuss the cumulative impacts to the environment associated 

with FPL's past, present, and future expansion in the south Florida region. 

(0014-14 [Mueller, Heinz])

Comment: FPL has reportedly received all of the necessary approvals from FDEP to proceed 

with the uprate project. Construction activities for this project will occur primarily during two 

scheduled outages per unit, with each outage lasting approximately 50 days. Construction 

activities for Unit 3 and 4 are anticipated to conclude in the fall of 2011 and 2012, respectively. 

After completion, the cooling water flow rate will remain unchanged, although the temperature 

rise across the condensers is anticipated to increase by 2.5F. FPL proposes that Units 6 and 7 

will have their cooling water needs provided by cooling towers as opposed to the existing canal 

system. Make-up for the towers is to be provided by reclaimed water. The Draft EIS should 

assess the cumulative effects of the uprated Units 3 and 4 combined with construction of new 

Units 6 and 7. Also, any increased removal of water from area basins as a result of operations 

of the interceptor ditch pumps should be discussed. (0014-7 [Mueller, Heinz])

Response: Cumulative impacts result from the combined effects of the proposed action and 

past, present, and reasonably foreseeable actions, regardless of who takes the actions. The 

appropriate geographic area and time period for considering cumulative impacts depend on the 

resource being affected and will be determined for each resource as part of the review team's 

evaluation. The impacts of building and operating proposed Turkey Point Units 6 and 7 on 

Biscayne Bay and adjacent lands will be added to other known or reasonably foreseeable 

actions and stressors within the defined geographic area of interest, including known or planned 

upgrades of other units on the Turkey Point site, if appropriate. The results of the analysis of 

impacts of the proposed units operations on water quality, ecology, and aesthetics will be 

presented in Chapter 5 of the EIS. The results of cumulative impact analyses will be presented 

in Chapter 7. 
Appendix D 

October 2016 D-115 NUREG–2176 

Comment: What we are now finding in our communities is that there are significant risks to 

those of us who still have residents on well water. We have 1,000 homeowners, just in the 

Village of Pinecrest, still on well water. And we risk, with those residents on well water, the 

specter of saltwater intrusion at any time and the balance of what may happen as a result of the 

continued impositions of construction and what the nuclear plants would do, likely due to the 

balance and the risk that that would place. That all of our homes that are still on well water may 

be contaminated through saltwater intrusion is a very serious issue that we -- none of us have 

the financial wherewithal, nor does our county, who is facing a $400 million deficit, nor does the 

State of Florida which is facing an additional -- I think it is 3 to $6 billion deficit in the coming 

year, have any resources to come in and help put the infrastructure in place for those homes 

that are on -- continue to be on well water. (0001-21-3 [Lerner, Cindy])

Comment: Another suggestion would be that they take the cooling water from deep within the 

bottom of Biscayne Bay and Card Sound, what they call the boulder zone. No one has the 

foggiest notion what that would do to the surface water. Would it create a cone of water? And if 

it did, how would that affect the inshore current that existed for thousands of years? 

(0001-6-5 [Miller, Lloyd])

Comment: Our first major concern has to do with water impact. FPL proposes to place radial 

collector wells 40 feet below Biscayne Bay Aquatic Preserve in the upper levels of the Biscayne 

aquifer. And this step -- we hope you will consider whether this step may be within the take 

zone of the Biscayne aquifer. (0001-7-1 [MacLaren, Kaitlin])

Comment: The Turkey Point expansion would require either 90 million gallons a day of 

reclaimed water, 124 million gallons a day from radial wells, or a combination of both. This is a 

huge amount of water and, as I'm going to discuss later, there are other better uses for this 

water. (0001-7-2 [MacLaren, Kaitlin])

Comment: At least 3 percent of the water to be used in the radial collector wells will come from 

the Biscayne aquifer. This will result in a reduction of more than 3 million gallons a day of 

groundwater flow needed to support the flora and fauna of Biscayne Bay. 

(0001-7-4 [MacLaren, Kaitlin])

Comment: This proposed expansion is in direct conflict with Biscayne Bay Coastal Wetland 

Project, which is part of the Everglades restoration. The availability of reused water to meet 

both the projected needs of FPL to operate the new plant and the needs of Everglades 

restoration is questionable. There was water, reused water earmarked for Biscayne Bay 

Coastal Wetlands Project that could be used for this project. (0001-7-9 [MacLaren, Kaitlin])

Comment: Some of the other speakers have already talked about water. Nuclear plants 

consume more water and withdraw more water than coal plants, natural gas plants, and 

certainly far more so than wind or solar as forms of energy. As other speakers have alluded to, 

we already have water shortage issues with drinking water. (0002-16-1 [Shlackman, Mara])

Comment: And we have to consider the socioeconomic impacts of this. The Redlands and 

Homestead are still an area that have agricultural businesses. There's been an effort to 

cultivate agritourism with such things as the Schnebly Winery, the Fruit and Spice Park, 
Appendix D 

NUREG–2176 D-116 October 2016 

Paradise Farms. And if we have all of this water being withdrawn for the nuclear plant, these 

agricultural businesses will suffer that much more. (0002-16-2 [Shlackman, Mara])

Comment: Miami-Dade County is on permanent water rationing; we are only permitted to 

water our lawns twice a week. In the winter, winter that can go down to zero. We do not flush 

our toilets after every use; if it's yellow, let in mellow, if it's brown, flush it down. 

3,000,000 people in Miami-Dade County live like this and you are going to build a power plant 

here that uses 125,000,000 gallons of water per day????!!!!. (0016-14 [White, Barry])

Comment: The drawdown of water will be a threat to our water supply, creating salt water 

intrusion, increased salinity, and challenge our continued existence on this endangered land not 

to mention the impact on the nearby national parks, their flora and fauna. (0016-5 [White, Barry])

Comment: The proposed use of radial wells to draw water from 40 feet under Biscayne Bay is 

a major threat to the water supply of the area. There is lateral movement of water in the aquifer 

so that the water will be drawn from all of the surrounding area including the aquifer to the west, 

the source of the Florida Keys water. (0016-6 [White, Barry])

Comment: We in Florida, where water is already scarce, and rationed many months of the 

year, cannot afford to give up the additional millions of gallons of water required for these new 

nuclear plants' operation. The existing plants at Turkey Point have already contaminated our 

groundwater, like nuclear plants have all over our country, and caused saltwater intrusion into 

our freshwater wetlands and drinking water sources. Please do not further risk our irreplaceable 

Florida water resources by allowing these new plants to be built. (0021-4 [Wilansky, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of utilizing water from Radial Wells to the Turkey Point FPL power station in 

the future, including any cost-benefit analyses please provide them. (0022-1-9 [Reynolds, Laura])

Comment: The operation of the RCWs would result in hydrologic impacts, including ground... 

water, on Biscayne Bay due to geological disturbances, resulting in water volume and quality 

alterations... The cone of influence during the operation of the RCWs extends into Biscayne 

National Park boundaries. Therefore, a large portion of the nearly 124 million gallons of 

Biscayne Bay water will originate from within Biscayne National Park boundaries, which is a 

protected water body. (0025-1-12 [Kimball, Dan] [Lewis, Mark])

Response: The impact of consumptive water use on both the local and regional water 

resources associated with building and operating proposed Turkey Point Units 6 and 7 will be 

presented in Chapters 4 and 5 of the EIS. Both current and future conditions, including changes 

in water demands to serve the needs of the future population and changes in water supply, will 

be considered. Cumulative impacts will be addressed in Chapter 7; and system design 

alternatives, including cooling water system designs and alternative cooling water sources will 

be presented in Chapter 9. 

Comment: Turkey Point is situated between two national parks and over the water supply for 

the entire Florida Keys and much on southern Miami-Dade County; and salt water intrusion and 
Appendix D 

October 2016 D-117 NUREG–2176 

increased levels of water salinity from the operation of Turkey Point Reactors 3 & 4 are already 

major concerns in the area. (0012-6 [Payne, Nkenga])

Comment: [T]he construction of the additional nuclear power plants, as well as the operation of 

the existing facilities, will have adverse impacts on water quality, ecology, farm lands, cause salt 

water intrusion, as well as adversely impact the habitat of protected species, wetlands and 

much needed fresh groundwater input to Biscayne Bay. (0012-9 [Payne, Nkenga])

Response: The impacts on water quality, including the effects of saltwater intrusion during 

building and operation of the proposed units will be discussed in Chapters 4 and 5 of the EIS. 

The impacts of the proposed actions on the local ecology and nearby farm land will also be 

addressed in Chapters 4 and 5. Saltwater intrusion resulting from the combined effects of the 

proposed action and past, present, and reasonably foreseeable actions will be addressed in 

Chapter 7. 

Comment: Ensure an analysis of the possible impacts of sea level rise on the proposed project 

with all of its associated facilities, consistent with the range of potential increases adopted by 

the Miami-Dade County Climate Change Advisory Task Force. FPL's assessment is based 

historical information on sea level rise in Miami-Dade County. Current discussions of sea level 

rise suggest that a much more significant rise could occur during the useful life of the proposed 

project, initially from 2020 to 2060, with a possible extension of 20 years, taking us out as far as 

2080. (0019-3 [Hamilton, Karen])

Comment: The impacts of sea level rise due to climate change should be addressed as they 

pertain to the operation and maintenance of the RCWs and the hydrologic modeling, which is 

being used to forecast the percentage of water derived from Biscayne Bay versus freshwater 

from the Biscayne Aquifer. The effects of climate change should also address major storm 

events and cooling canal functionality over the projected lifespan of Units 6&7. Peer reviewed 

and governmental references should be part of this analysis, including the [PCC Fourth 

Assessment Report: Climate Change 2007; the Miami-Dade Climate Change report; and the 

Army Corps of Engineers, engineering circular - sea level rise 1165-2-211. 

(0025-2-13 [Kimball, Dan] [Lewis, Mark])

Comment: The SFWMD recommends that the following issues be addressed in the 

Environmental Impact Statement: Hurricanes/Climate Change/Sea Level Rise - The potential for 

adverse impacts related to the siting and design of the proposed plant and associated facilities 

directly on the coast in an area subject to the direct effects of hurricane tidal surge, climate 

change, and sea level rise. (0032-28 [Golden, James])

Comment: The sighting of the proposed Florida Power & Light (FPL) nuclear reactors 6 and 7 

adjacent to FPL’s existing power plants on the sight abutting Biscayne Bay approximately 

25 miles south of the city of Miami, is ill conceived and short sighted. According to the latest 

United Nations Intergovernmental Panel on Climate Change (IPCC) estimates, a sea level rise 

between 18 and 59 cm (7.1 to 23.2 inches) can be expected before the turn of the century. 

Unfortunately the IPCC did not factor in global land ice melt into this equation. The new IPCC 

report, due to be released in 2014, will include land ice melt sea level rise forcings. 

(0034-1 [Kipnis, Daniel])
Appendix D 

NUREG–2176 D-118 October 2016 

Comment: This scenario may not be the reality of the situation. Dr. Stefan Rahmstorf, a 

leading and respected authority on the subject notes that, “land ice (glacial melt) has, in fact, 

contributed 80 per cent of the observed sea level rise over the past five years”, and, “if twothirds of glacier ice were lost, this would add 40 centimeters to the global sea level”, then, “The 

big ice sheets would then need to contribute only about 50 centimeters (19.7 inches) — 

corresponding to less than one per cent of their mass — to bring sea level rise up to 114 

centimeters (44.9 inches)”. This does not include any thermal expansion of ocean water which 

the IPCC admits will increase due to rising global temperatures. The only debate among 

climate scientists is not if, but when these changes will occur. Additionally and closer to home, 

the Science Committee of the Miami Dade County Climate Change Advisory Task Force 

(CCATF), Co-chaired by Dr. Hal Wanless, Chairman of the University of Miami’s Geology 

Department and Dr. Stephen Leatherman, Director of the International Hurricane Center at 

Florida International University, have predicted that sea level rise will be between 91.4 cm and 

152.4 cm (3 to 5 Feet) by the end of the century and possibly as early as 2070. 

(0034-2 [Kipnis, Daniel])

Comment: It should be plain to see, especially when sighting a 23 billion dollar facility with a 

useful working life of up to 100 years, that the proposed site presents inherent risks that place 

not only the financial investment of FPL’s rate payers but also their safety in extreme jeopardy. 

A sea level rise of just one foot would inundate 17% of Miami Dade County’s land mass, most of 

which would be in south Dade, including the area around Turkey Point and the access road to 

the facility. A two foot rise covers 28% of Miami Dade County’s land mass. Turkey Point 

generating facility effectively becomes an island. The current cooling canals for the existing 

nuclear generating facility become unusable as they are breached by rising bay waters. 

(0034-3 [Kipnis, Daniel])

Comment: At the full predicted 5 foot range of sea level rise, occurring sometime between 

2070 and the turn of the century, only 54% of Miami Dade County remains high and dry. FPL’s 

proposed power lines running down the western side of the County’s Urban Development 

Boundary (UDB) are miles from dry land as that part of the Everglades is flooded with both fresh 

water, used to hold back the rising sea, and salt water which is fast encroaching. The coastal 

ridge is now divided by tidal channels into a series of independent islands displacing a million or 

more county residents. The effect of any hurricane storm surge will force an additional million or 

more residents to leave the county for higher ground as they have already had to do on the 

barrier islands of Miami Beach and Key Biscayne. Even as bad as this scenario seems, it will 

get worse. Sea levels are expected to continue to rise for centuries to come and if they reach 

historic levels of past melts, could exceed 20 meters (66.61 feet). This may happen faster than 

expected due to accelerated climate forcings as countries have not only failed to reduce 

greenhouse gas emissions, but actually have accelerated them. (0034-4 [Kipnis, Daniel])

Comment: The bottom line, the Nuclear Regulatory Commission and the Army Corps of 

Engineers should withhold permitting for FPL’s proposed generating facilities 6 and 7 due to 

concerns that: (1) Predicted sea level rise would first, isolate the facility on an island, then 

(2) Cause the access road to be undermined and overrun by sea water causing it to become 

unstable and unusable, then (3) Overrun and alter the current cooling canals and possibly 

cause the proposed cooling-water radial wells to function differently than now proposed and 

possibly cease to function as planned, then (4) Increase the effects of storm surges from 
Appendix D 

October 2016 D-119 NUREG–2176 

hurricanes and other tropical events on the facilities and access roads, then (5) Place 

maintenance constraints on power transmission lines that now will be water bound, then 

(6) Unfairly burden rate payers in funding a project that will not reach its projected life span, then 

(7) Have an insufficient client base to support the facilities operations when much of south 

Florida’s population is forced to relocate due to sea level rise, tidal surge events, pollution 

concerns, altered wet and dry seasons, increased chance of tropical diseases and all the other 

predicted effects of climate change. (0034-5 [Kipnis, Daniel])

Response: 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. 

Comment: The application proposed the discharges of potentially contaminated industrial 

waste from the maintenance of boiler, equipment closed cooling water system maintenance, 

and other areas to cooling canals. Although the use of oil-water separators is mentioned, no 

information was provided to allow for evaluation of potential impacts to sensitive ecological 

receptors, and surface and groundwater quality. No information was provided to show that no 

contamination will result from such discharges. (0023-1-10 [LaFerrier, Marc])

Response: This comment refers to the SCA submitted to the State of Florida by FPL, but it 

indicates an interest in the potential impacts of the proposed plant on Federally and State-listed 

endangered or threatened species and surface water and groundwater quality. The potential 

impacts of building and operating proposed Turkey Point Units 6 and 7 on Federally and Statelisted endangered or threatened species and surface water and groundwater quality will be 

discussed in Chapters 4 and 5 of the EIS, based on the affected environment described in 

Chapter 2. The cumulative impacts of the proposed action and other past, present, and 

reasonably foreseeable future actions will be assessed in Chapter 7. 

Comment: The Summary of Measures and Controls to limit Adverse Impacts during 

Construction (Table 4.6-1, COL, Environmental Report, Part 3, Ch. 4) assesses the cumulative 

impacts to land use, hydrology, water use, subsurface flow, ecology, and socioeconomics, as a 

result of the construction of the entire Unit 6&7 plant (pre and post construction). FPL lists most 

impacts as small in this analysis, compared to moderate or large. Small is defined by FPL as 

Environmental effects are not detectable or are so minor that they will neither destabilize nor 

noticeably alter any important attribute or resource. A striking aspect of this analysis is the 

incorporation of CERP features as either a contributable negative or positive impact to 

Units 6&7 construction. FPL appears to use benefits from the proposed Biscayne Bay Coastal 

Wetlands/CERP project to mitigate the environmental impacts of the Units 6&7 construction. 

This appears highly inappropriate in the determination of total impacts from the FPL project. 

Therefore, the NPS requests that this analysis be carefully evaluated to consider the impacts 

Unit 6&7 combined construction will have on Biscayne Bay Coastal Wetlands/CERP 

implementation, as well as, all other associated impacts to the environment. 

(0025-1-15 [Kimball, Dan] [Lewis, Mark])
Appendix D 

NUREG–2176 D-120 October 2016 

Response: Cumulative impacts result from the combined effects of the proposed action and 

past, present, and reasonably foreseeable actions, regardless of who takes the actions. The 

results of cumulative impact analyses will be presented in Chapter 7 of the EIS; and in that 

analysis the contribution of proposed Turkey Point Units 6 and 7 to the cumulative impact will be 

identified. In addition, the respective impacts of building and operating the proposed units will 

be presented in Chapters 4 and 5. 

Comment: Please state the amount of greenhouse gases units 6&7 will contribute to the 

atmosphere. Please state the amount of climate change units 6&7 will make to the environment. 

(0022-2-17 [Reynolds, Laura])

Response: The potential impacts of the airborne emissions from building and operating 

proposed Turkey Point Units 6 and 7 will be discussed in EIS Chapters 4 and 5, respectively. 

The potential cumulative impacts of the proposed nuclear power generation on climate change 

will be addressed in Chapter 7. 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

adverse impacts of climate change as a result of direct heating of the atmosphere, please 

provide them. (0022-4-17 [Reynolds, Laura])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 on climate change will be discussed in Chapters 4, 5, and 7 of the EIS, based on the affected 

environment described in Chapter 2. The EIS will include citations for documents used in its 

preparation. 

Comment: The proposed plant and associated facilities are located within project areas for the 

Comprehensive Everglades Restoration Plan (CERP), which proposes to restore regional 

wetland functions in the region, including functions that provide direct benefits to Miami-Dade 

County's population through protection of surface and groundwater resources. The EIS should 

examine the compatibility of the plant and associated facilities, including transmission lines, with 

CERP and CERP restoration goals for this area. (0015-5 [Espinosa, Carlos])

Response: The cumulative impacts associated with building and operating proposed Turkey 

Point Units 6 and 7 will be evaluated for each affected resource. Past, present, and reasonably 

foreseeable actions taken under the CERP will be considered in the cumulative impact analyses 

presented in Chapter 7 of the EIS. 

D.1.22 Comments Concerning the Need for Power 

Comment: Like the previous speakers of the Greater Miami Chamber, the Mayor of the Florida 

City, Mr. Bill Diggs, efficient supply of power is essential to sustain economic growth and 

sustainability in South Florida. Business and industries is what we are predominantly, as an 

economic development council, concerned with. People that come to our community need to 

know that there is power provided by Florida Power & Light that is second to none, along with 

the infrastructure of roads, education, and other things that are climbing at an enormous rate in 

our community. Just the expansion of roads alone in the last two years is astronomical. Why? 
Appendix D 

October 2016 D-121 NUREG–2176 

Because there's a need. There's a lot of people coming into our communities. We need to 

keep up with that capacity, and that's what this is all about. As well, Barry Johnson, with the 

Greater Miami Chamber, talked about the fact that we've been accustomed to a quality of life, 

which is true. That quality dictates the need for additional infrastructure and utilities, power, all 

those things that we depend on in our daily lives. (0001-25-2 [Horton, Richard])

Comment: The addition of the two new reactors to Turkey Point provide the energy which we 

will need in South Florida as our community continues to grow; 5, 6, 7 million people projected 

in the not too distant future. We've got to provide the kind of services that everyone expects 

and demands (0001-5-2 [Johnson, Barry])

Comment: According to the Waxman-Markey Bill, we would probably need about 45 new 

nuclear reactors to meet the expectation, and I think 6 and 7 is the start of that. 

(0001-9-3 [Martinelli, Tom])

Comment: I believe our electrical energy use is going to continue to grow in South Florida. I 

was walking the Hollywood Broadwalk this morning, and there were two large cranes I saw right 

at Sheridan Street and A1A. And what I found out they were doing is they were installing a new 

cellular tower on the top of the condominium building for wireless 4G/3G for the new 

smartphones. And we're more and more, as consumers, using electric. And to be competitive 

in this world we're not going to cut back on our electric use. However, there were some good 

points that were brought up, and it kind of ties into what I think is very important. 

(0002-17-2 [Eney, Douglas])

Comment: If you look across the country, a lot of your nuclear power plants have reached the 

end of their life expectancy. Over the last, say, 10 years, America has been rebuilding, 

revamping them, making them capable of going on another 20, 30 years. You have a lot of coal 

fired power plants that have reached their life expectancy. As far as America as an industrial 

nation, we need this power to power our factories. Look at it. You go throughout the 

United States -- when you go to stores you don't see hardly anything made in America anymore. 

So if you look at it from an economic standpoint, if you see that these power plants have 

reached the end of their life expectancies, big industry is looking at this. 

(0002-7-2 [Snelson, Richard])

Response: These comments express agreement with the FPL application's assertion that the 

area needs additional power. The need-for-power analysis will be addressed in Chapter 8 of 

the EIS. 

Comment: FPL and Florida should be the leader in renewable and nuclear energy. So much 

that supply is greater than demand and we can sell it to other states. (0006-5 [Weins, Brian])

Comment: Please state the "Need for Power" where units 6&7 is at the distant end of the 

electrical grid and is unable to send excess power to the east, the south, or the west. 

(0022-3-6 [Reynolds, Laura])

Response: The need-for-power evaluation will be presented in Chapter 8 of the EIS. 
Appendix D 

NUREG–2176 D-122 October 2016 

Comment: If you Google FP&L, PSC -- Public Services Commission -- you'll find a lot of data, 

you'll find a lot of interesting articles. And I would direct you primarily to a writer for the Sun 

Sentinel in Fort Lauderdale called Julie Patel, for whom FP&L is her beat. And look at the long 

history of the relationship between PSC and FP&L. Why do I mention PSC at the beginning? 

Because they're the ones who did the needs analysis. Remember, this project starts with a 

needs analysis, where the PSC determined that there was a need for this power plant. Is there a 

need for this power plant? (0002-14-1 [Schwartz, Matthew])

Response: The need-for-power evaluation will be presented in Chapter 8 of the EIS. The 

determination of the need for power within a given area is not under the NRC's regulatory 

purview. However, for the purpose of its NEPA analysis, where another regulatory body has 

made a need-for-power determination, the NRC staff reviews the applicable regulators need-forpower analysis to determine if it is (1) systematic, (2) comprehensive, (3) subject to 

confirmation, and (4) responsive to forecasting uncertainty. If the need-for-power evaluation is 

found to be acceptable under these criteria, no additional independent review by the NRC is 

needed. 

Comment: Is the Florida population growing? Are we getting to the -- what was it, 15 million 

people we're going to have living in South Florida? Nowhere near there. In fact, population is 

not growing, it's static. There's a reason for that, there's a reason why the population isn't 

growing. But at any rate, this project does not take that into consideration. 

(0002-14-2 [Schwartz, Matthew])

Comment: I'd first like to say that I know that we're saying there's a new need for energy. The 

last I've heard there's been a population decrease in this area. (0002-8-1 [O'Katy, Jessica])

Comment: Please state the "Need for Power" in Florida in light of a population decrease of 

58,294 from April 1, 2008 to April 1, 2009. (0022-3-4 [Reynolds, Laura])

Response: The need for power in light of population growth and electrical demand in the FPL 

service area will be analyzed and addressed in Chapter 8 of the EIS. 

Comment: The alternative analysis is based on an archaic assumption that base load power is 

needed. Last April, Federal Energy Regulatory Commission Chief Jon Wellington told the 

U.S. Energy Association that saying we need base load energy is like saying we need 

mainframe computers. The technology currently exists for distributed energy systems that 

negate the need for base load power. Further, the NRC must use updated information to 

reevaluate FPL's 2008 analysis for the new reactors in terms of the need for power given -- for 

the need for power, given the economic downturn and significant reduction in demand. 

(0001-14-5 [Hancock, Mandy])

Comment: The electricity generated is not even needed in South Florida where the plants are 

proposed to be built, endangering all of us in this area for something we will neither use nor 

need. And the electricity these proposed plants could generate is not needed, period - this 

amount of energy and more could easily be saved by simply increasing conservation and 

efficiency, at a saving of billions of dollars to consumers, with NO risk to the environment 

whatsoever. (0021-3 [Wilansky, Laura])
Appendix D 

October 2016 D-123 NUREG–2176 

Response: Decisions regarding which generation sources and alternatives to deploy are made 

by the applicant and regulatory bodies such as the public utility commission. The impacts of 

energy efficiency and demand-side management on the need for power and load forecasts will 

be addressed in Chapter 8 of the EIS. Alternative actions such as the no-action alternative, new 

generation alternatives, purchased electrical power, energy efficiency, alternative technologies 

(including renewable energy such as wind and solar), and the combination of alternatives will be 

considered in Chapter 9. The determination for the need for power is not under NRC's 

regulatory purview. However, for the purpose of its NEPA analysis, where another regulatory 

body has made a need-for-power determination, the NRC staff will review the applicable 

regulators need for power and determine if it is (1) systematic, (2) comprehensive, (3) subject to 

confirmation, and (4) responsive to forecasting uncertainty. If the need-for-power evaluation is 

found to be acceptable under these criteria, no additional independent NRC review is needed. 

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the "50-year electrical demand projections for the FPL service area" considering various climate 

change and sea level rise scenarios, please provide them. (0022-1-5 [Reynolds, Laura])

Comment: Please state the "Need for Power" in the light of sole source municipal wellfields 

being contaminated with salt water by a sea level rise of 1 foot or less. Please state the "Need 

for Power" in the light of large areas of infrastructure, residential and commercial real estate 

being flooded by a sea level rise of 1 foot or less. (0022-3-5 [Reynolds, Laura])

Comment: To the extent that you are aware of any documents or reports by any federal, state, 

local or regional government agency, FPL or any of its employees or contractors that relate to 

the permanent closure of solid fueled electrical generating plants as a result of units 6 & 7 

becoming operational, please provide. (0022-4-24 [Reynolds, Laura])

Response: The determination for the need for power within a given area is not under the 

NRC's regulatory purview. However, for the purpose of its NEPA analysis, where another 

regulatory body has made a need-for-power determination, the NRC staff reviews the applicable 

regulators need-for-power analysis to determine if it is (1) systematic, (2) comprehensive, 

(3) subject to confirmation, and (4) responsive to forecasting uncertainty. If the need-for-power 

evaluation is found to be acceptable under these criteria, no additional independent review by 

the NRC is needed. The need-for-power discussion will be included in Chapter 8 of the EIS. 

Chapter 8 will include a discussion of planned retirements of other generating facilities within the 

FPL service territory. The potential cumulative impacts associated with sea level rise will be 

discussed in Chapter 7. 

Comment: There is growing evidence that the thousands of acres of cooling canals designed 

for Turkey Point 3 and 4 are exacerbating saltwater intrusion in the area, and is believed to be 

impeding the flow of groundwater to Biscayne National Park. If no solutions to these impacts 

are addressed in this application review, then you will have contributed to the degradation of our 

national parks and our quality of life in Miami-Dade. (0002-1-3 [Sorenson, Katy])

Response: The purpose of the EIS is to disclose the environmental impacts of proposed 

Turkey Point Units 6 and 7. This comment addresses the impact of the existing power plants on 
Appendix D 

NUREG–2176 D-124 October 2016 

the Turkey Point site which is outside the scope of the environmental review. The cumulative 

impact of the proposed action when added to the impact of past, present, and reasonably 

foreseeable future actions discussed in Chapter 7 of the EIS will consider the impact of the 

existing units on resources affected by the proposed units. 

D.1.23 Comments Concerning Alternatives – Energy 

Comment: It is not okay to build a nuclear power plant. If Germany can take and stop with all 

their nuclear power plants, planned by the year 2020 because they have found solar to be that 

efficient, and they get 50 percent less sunlight per year than we do, then certainly we can come 

up and do the same thing. (0001-11-11 [Amor, Valerie])

Comment: This is the Sunshine State. We should be using sunshine as our source of energy. 

This is almost Neanderthal that we're still considering building more nuclear power as a way to 

solve our energy crisis. We have not gone beyond this point and it's very disappointing. There 

have been studies done by Broward County, a targeted industry study that said, solar is to be 

the next industry. (0001-11-7 [Amor, Valerie])

Comment: There are more affordable ways for FPL to meet energy demand while protecting 

the environment and tackling global warming. As SACE and the NRDC testified to the PSC in 

2009, simply increasing energy efficiency goals by 1 percent could save enough energy to 

estimate the need -- to eliminate the need for new reactors, while saving ratepayers money. 

Additionally, investing more resources in solar and clean bio-energy, instead of costly new 

reactors, would benefit FPL and offer economic development opportunities for Florida, without 

draining our water resources or pocketbooks. The NRC must evaluate updated information 

using a combination of these sustainable energy choices, including energy efficiency, before 

allowing FP&L to commit billions of dollars, billions of gallons of water, and nearly an entire 

decade to building these reactors when that time and money could be better spent on less risky 

options. (0001-14-3 [Hancock, Mandy])

Comment: Energy efficiency measures preserve our water resources, save customers money, 

and also pose no health or safety risks to the public. Florida utilities have significant resources 

to tap in these areas as outlined in a recent extensive report, Energy Efficiency in the South, by 

Georgia Tech and Duke University, and our report, Yes We Can: Southern Solutions for a 

National Renewable Standard. Renewable energy technologies, such as solar and wind, do not 

require extreme manipulation of our precious water resources. The environmental report 

overlooks the potential for FPL to pursue a combination of wind and solar resources within its 

service territory and states there is no renewable technology alternative that could mitigate the 

need for nuclear power (0001-14-4 [Hancock, Mandy])

Comment: It's imperative that the U.S. invest in a safe, sustainable energy paradigm for the 

21st Century that can also help revitalize our economy and create vastly more jobs than Turkey 

Point could ever dream of. The nuclear industry claims that it is a necessary piece of that 

energy future. On the contrary, studies indicate that the energy mix will not require a nuclear 

component. In the ten years it takes to bring a new plant online, we could've been developing a 

new truly Green energy technologies. Because the nuke industry cannot compete on its own 
Appendix D 

October 2016 D-125 NUREG–2176 

without massive government subsidies, it threatens our bright Green future by drawing public 

investment away from it. (0001-16-8 [Showen, Steve])

Comment: As Florida Power & Light staff was helping us build this house and advising us, my 

wife and I would say: Why are they helping you not pay them so much money? It doesn't quite 

make sense. So we asked them one time and the gentleman I asked said, Albert, you don't 

understand. If everyone built like this we would never need to build another nuclear power 

plant. (0001-24-4 [Harum-Alvarez, Albert])

Comment: I know it isn't the Nuclear Regulatory Commission's place to determine need, but I 

do believe that there is a deep reservoir of available energy if we would only embrace energy 

efficiency. A recent report by Duke University and Georgia Tech concluded that the southern 

states could meet our future energy demand through aggressive energy conservation programs. 

There are a lot more jobs to be had putting people to work now, not 5, 10, or 15 years from now 

retrofitting homes and business throughout our community, and we don't have to pay for these 

jobs and reduced energy bills through an early cost recovery fee. (0002-1-4 [Sorenson, Katy])

Comment: This project, from what I can see, it's about a $20 billion project. What's the 

problem with that? Because we are in an era where renewable, true renewable resources are 

now available to us; ocean power, solar, wind. Insolation is the measurement of how much sun 

reaches a given area of the earth. Florida is the Sunshine State for a reason. Look at insolation 

maps of the United States. South Florida is equivalent to parts of the Southwest; Arizona, 

New Mexico. We have the energy here, we are not using any of it. We are not making use of 

the solar. (0002-14-3 [Schwartz, Matthew])

Comment: I think we keep looking at fossil fuel and I don't think we really understand how 

dependent we are on it and what a nasty thing it can be. And, yes, it would be wonderful and -- 

really wonderful. I don't think it's pie in the sky. I don't think that solar power is a magical thing. 

I think it's a coming thing, and I do think FP&L uses. I know they do. They use wind power. 

(0002-15-4 [Finlan, Mary])

Comment: But solar installations on rooftops would create green jobs that would provide a 

viable alternative for the community. (0002-16-4 [Shlackman, Mara])

Comment: Looking at reports that have been done in the name of efficiency, and we've heard 

a lot of about efficiency and renewables, there were a couple -- the Southern Alliance for Clean 

Energy and the Natural Resource Defense Council both testified to the Public Service 

Commission last year that simply increasing energy efficiency goals by 1 percent could negate 

the need for any nuclear power reactors. I think the NRC should really look at this option while 

they're doing the consideration of the scoping process. Obviously, renewables in conjunction 

with that would even further negate the need for new nuclear reactors. The NRC must evaluate 

updated information using a combination of this sustainable energy choices, including energy 

efficiency, before allowing FP&L to commit billions of dollars, billions of gallons of water, and 

nearly an entire decade to building these reactors when that time and money could be better 

spent on less risky options. (0002-18-3 [Hancock, Mandy])
Appendix D 

NUREG–2176 D-126 October 2016 

Comment: I, instead, would like to propose that we focus on truly renewable energy and clean 

energy answers as well as efficiency in Miami. (0002-8-3 [O'Katy, Jessica])

Comment: So, I'd like to ask that we focus on truly clean and renewable energy sources like 

solar or wind, and most of all efficiency, and definitely take into consideration all of the 

environmental impacts that we can when making this decision. (0002-8-9 [O'Katy, Jessica])

Comment: FPL should be exploring wind farms off the coast of Florida not oil drilling. Every 

new structure built should be required to use a minimum of 25% solar energy. 

(0006-4 [Weins, Brian])

Comment: Opting to pursue energy resources that would not involve such irreversible damage 

to the surrounding environment is necessary to ensure the safety of the surrounding community. 

Renewable energy resources such as wind and solar power are a much wiser alternative for the 

State of Florida. (0007-7 [Burris, Jessica])

Comment: Solar power is growing and Florida is known as the sunshine state. If we charged 

each homeowner for the installation and maintenance of the solar panels on their homes, then 

we could probably power the whole state. Also solar power does not emit green house gases or 

any other harmful side effects either. (0009-2 [Hogsed, Daniel])

Comment: If we installed solar panels on every home in Florida we could generate more jobs 

than the nuclear power plant expansion would and inspire other countries to follow our lead. 

(0009-4 [Hogsed, Daniel])

Comment: The City of South Miami supports energy policies based on investment in the rapid 

development of solar and wind energy, and all other proven renewable energy solutions, 

combined with a comprehensive program promoting energy efficiency and conservation. 

(0012-18 [Payne, Nkenga])

Comment: South Miami supports energy policies based on investment in the rapid 

development of solar and wind energy, and all other proven renewable energy solutions, 

combined with a comprehensive program promoting energy efficiency and conservation. 

(0012-2 [Payne, Nkenga])

Comment: The Draft EIS should discuss other alternative sources of energy that may available 

to serve the project purpose that would have less impact on sensitive wetland resources. 

(0014-16 [Mueller, Heinz])

Comment: We can do better through major investments in energy efficiency, conservation, and 

renewables. No health risks involved if a solar panel breaks. (0017-3 [Troner, Susannah])

Comment: I am fairly certain that FPL has done less than any other utility to try to curb 

electrical usage in our community through demand side management. They have no true 

incentive to do so. (0017-5 [Troner, Susannah])

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 
Appendix D 

October 2016 D-127 NUREG–2176 

drain much-needed resources from full development of better, safer technologies. Florida in 

particular has abundant solar energy that is not being used. (0021-12 [Wilansky, Laura])

Comment: Please STOP THIS DISASTEROUS AND GREEDY EXPANSION OF ELECTRIC 

COMPANIES AND OTHER BIG BUSINESSES SET ON 21ST CENTURY ABUSE OF OUR 

PLANET. Our government must not turn its back - and should immediately go in the green 

direction - so that Americans, and especially our children, can look back with pride on the 

governmental leaders with this kind of foresight that protected the earth for future generations 

instead of allowing greed to continue its destructive pattern. (0028-6 [DiNuzzo, Laura])

Comment: What about solar and wind power as safe alternatives? (0031-6 [De Villiers, Elena])

Response: The EIS will be prepared in accordance with 10 CFR 51.75(c). Alternative energy 

sources, including energy conservation and renewable energy sources, will be considered in 

Chapter 9 of the EIS. 

Comment: I could say the same thing that's been said for this nuclear power plant: I can bring 

you 4,000 new jobs and I can build a solar power plant. Would you all still be so happy? And I 

hope you would because if there is a problem with a solar plant, millions of people will not die; 

or the water will not be contaminated; the air will not be jeopardized; we would not worry about 

our aquifers. (0001-11-8 [Amor, Valerie])

Comment: Now, aside from saddling the taxpayers with extraordinary risks, the nuclear power 

will crowd out dramatically energy-efficient competition from decentralized co-generation such 

as the 21 megawatt plant that provides the entire campus at Massachusetts Institute of 

Technology with electricity, heating, and cooling by extracting twice as much useful energy and 

using half as much fuel as a conventional power plant. (0001-13-8 [Smilan, Stan])

Comment: In light of the recent Gulf oil spill, which upsets me very much, do you think it's a 

good idea of taking more risks with new technologies? I don't and that's why I'm here today. 

Why risk so much when there is other, better technologies such as solar? Energy efficiency and 

clean renewable energy should be our main focus right now. It will save money in the long term 

so that future generations have a chance. (0001-19-4 [Ryan, Megan])

Response: The evaluation of potential health impacts of operating additional nuclear plants on 

the Turkey Point site will presented in Chapter 5 of the EIS. In addition, the applicants safety 

assessment for the proposed licensing action was provided as part of the application. The NRC 

is in the process of developing an 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. In addition, energy efficiency and renewable energy alternatives to the 

proposed action will be evaluated in Chapter 9 of the EIS. 

Comment: When comparing energy types -- when comparing types of energy generation, 

nuclear power has higher rates of both water withdrawal and consumption than coal and natural 

gas and far more than renewable energy sources, such as wind and solar. The 2010 report I 
Appendix D 

NUREG–2176 D-128 October 2016 

mentioned earlier by Georgia Tech and Duke University examined the energy efficiency in the 

South and it illustrated ways to substantially reduce energy needs, while simultaneously 

reducing water consumption. According to the report: In the North American Electric Reliability 

Council regions in the South, 8.6 billion gallons of freshwater could be conserved in 2020, which 

is 56 percent of the projected growth in cooling needs. And in 2030 this could grow to 

20.1 billion gallons of conserved water, which is 45 percent of projected growth. Instead, we 

see FP&L projected figures for water demand in 2025 to include a 35 percent increase for public 

and commercial needs and a whopping 3,224 percent increase for thermoelectric power 

generation. The NRC needs to fully evaluate less water- intensive energy alternatives -- 

efficiency and renewables -- including using a combination of these energy sources. The NRC 

also needs to analyze the impacts such a drastic increase in water demand from the power 

sector could cause to this area. (0001-14-7 [Hancock, Mandy])

Comment: As a mayor who has signed on the U.S. Conference of Mayors Climate Protection 

Agreement, I am committed to, as we all are -- we have major sustainable and clean energy 

initiatives that we are going forward with. But we don't see the cost benefit analysis that you are 

to do as one that could in any way sustain or support an additional nuclear power infrastructure 

being placed. We would love to see, as other speakers have said, additional solar 

manufacturing. We've got the land throughout South Florida to do the manufacturing of the 

solar panels, to see Florida Power & Light do what they've done in Arcadia, and put in more 

solar fields. But the adverse impact of the potential for bringing in additional nuclear power 

plants would interfere with residential, and commercial, and environmental interest to a 

significant degree. (0001-21-5 [Lerner, Cindy])

Comment: Wouldn't any energy technology create jobs? Developing solar and wind energy 

systems would involve construction and permanent jobs. FP&L's job creation theme is an 

emotional ploy at best. Is enticement of jobs in trying economic times a good enough reason for 

expansion? We need direction from something much smarter and more thoughtful. That takes 

us to "greener" than coal fired plants. (0029-2 [Guendelsberger, Debra])

Response: Alternative energy sources, including coal, natural gas, energy conservation, and 

renewable-energy sources, will be considered in Chapter 9 of the EIS. The impact of 

consumptive water losses on the sustainability of both the local and regional water resources 

will be presented in Chapters 4, 5, and 7 for building and operation, respectively. 

Comment: I ask you to include the true costs of nuclear plants throughout their entire life cycle 

in your environmental calculations, including the diversion of resources from the desperatelyneeded development of truly safe and sustainable energy technologies. 

(0021-20 [Wilansky, Laura])

Response: The assumptions of reactor life span and costs used in this analysis will be 

provided in Section 10 of the EIS. Costs for all phases of reactor building and maintenance will 

be discussed. The license period for a combined license is 40 years. A licensee can request 

renewal for an additional 20 years. The benefit-cost analysis is done for the license period of 

40 years. It would not be appropriate to assume additional cost or benefit for an additional 

20 years of license renewal when that action has not been requested or approved. 
Appendix D 

October 2016 D-129 NUREG–2176 

Comment: As was said, we're referring to Units 6 and 7, because there are five operating units 

at the site. There are three fossil units and there's two nuclear units. So FPL has a well 

balance of fuel diversity but it's important that we increase, from a diversity standpoint, our 

reliance on nuclear energy and renewables. FPL currently is the largest generator of electricity 

from wind in the United States, and we have the largest solar power facility in the country. 

We're the third largest generator of electricity from nuclear in the United States currently today, 

without the addition of Units 6 and 7. (0001-3-3 [Kiley, Mike])

Response: This comment expresses support for the applicant's COL application. It does not 

provide specific information relating to the environmental effects of the proposed action and will 

not be evaluated in the EIS. It is listed to compile a complete record of comments received. 

Comment: [T]he estimated cost of thirty billion dollars or more which the public is expected to 

prepay, would be much better spent on creating and/or subsidizing an alternative energy 

industry. This industry will create many thousands of permanent jobs, as opposed to the 

relatively few which would be created by establishing new nuclear power plants. 

(0012-15 [Payne, Nkenga])

Comment: The article [in the "Free Press"] mentioned that the nuclear plants rely almost 50% 

on natural gas - my question to you, Mayor, is why not go in the more "green" direction of 

"natural gas" for all future energy needs - which is abundant and cheap - I believe we are not 

even considering other alternatives because of the following: Big Business, FPL, and its welltrodden path of making the American people more and more electricity-, dependent (prices 

never going down or stabilizing to benefit the American people, even though FPL grows bigger 

and bigger every year) - and then - influencing our government by threatening loss of jobs = two 

ways coercing the American people/government into "feeding" this greedy monster AND IS 

NOT THE WAY TO GO IN THE 21ST CENTURY. (0028-3 [DiNuzzo, Laura])

Comment: Regarding the coercing of the American people and our government by suggesting 

that thousands of jobs would be lost if the nuclear plants were not constructed, I propose the 

following green outlook: If, for instance, your office, Mayor, turned its back on FPL and our 

government refused to allow this typical example of Big Business 20th Century greed and 

inconsideration for the American people, and decided that America needs to be more selfsufficient and its individual homes more self-efficient - I can promise you with millions of homes 

proceeding in this Green Direction, thousands if no millions of jobs would be created by: 

Independent American-home generators, Independent American-home solar panels, 

Independent American-home, cistern-like water supplies. Thereby creating endless jobs in 

manufacturing, sales, installations, maintenances, repairs, and so many other job-related 

ramifications therewith - making Americans more dependent upon each other rather than big 

business and the world for our needs, and more importantly, moving in the right green direction 

to protect this planet from any further exploitation by big business. As far as fossil fuels are 

concerned: It is not the fossil fuels that have caused so many problems, it is Big Business 

Greed that has gotten out of control and must be stopped in the 21st Century. 

(0028-4 [DiNuzzo, Laura])

Response: The NRC does not establish public policy regarding electric power supply 

alternatives nor does it promote the use of nuclear power as a preferred energy alternative. 
Appendix D 

NUREG–2176 D-130 October 2016 

Decisions regarding which generation sources and alternatives to generation to deploy are 

made by the applicant through least-cost planning and integrated resource plans. Additional 

regulatory purview is provided by bodies such as State energy planning agencies and 

commissions. However, the discussion of various alternatives to the proposed project is 

pertinent to the extent that an energy alternative must reasonably be expected to replace the 

base load energy supplied by the proposed project, whether individually or in combination. The 

alternatives must be technically viable, feasible, and competitive. Chapter 9 of the EIS will 

include the no-action alternative (energy efficiency and demand-side management), new 

generation alternatives, purchased electrical power, alternative energy technologies (including 

renewable energy such as wind and solar), and the combination of alternatives. For acceptable 

alternatives, the potential for environmental and economic impacts will be assessed against the 

proposed project. If one of the potentially viable alternatives is environmentally preferable to the 

proposed action, economic impacts will also be compared. 

Comment: YOU HAVE THE OPTIONS OF DECIDING TO PUT TP 6&7 SOMEWHERE ELSE 

AND/OR TO SUGGEST THE USE OF ALTERNATIVE (AND DECENTRALIZED) ENERGY 

SOURCES AND PRODUCTION. FOR THE SAKE OF OUR GRANDCHILDREN, CHOOSE 

ONE OF THOSE OPTIONS. (0016-12 [White, Barry])

Response: The NRC staff carefully reviews each application it receives by using an 

acceptance review process to ensure all required components are provided by the applicant. 

Each application then receives additional scrutiny during the safety and environmental review 

processes. Examining alternative energy sources and alternative sites is a function of the 

environmental review process and these topics will be discussed in Chapter 9 of the EIS. 

D.1.24 Comments Concerning Alternatives – System Design 

Comment: Application fails to provide an alternatives analysis for routing of the proposed 

reuse pipeline. Please provide an alternatives analysis that considers and compares the 

benefits and impacts of all feasible alternative routes for this pipeline, including but not limited to 

wetland impacts, impacts to state and federally protected species, impacts to existing water 

management features. Alternatives evaluated should include but not be limited to options that 

minimize wetland impacts. (0023-1-25 [LaFerrier, Marc])

Comment: Application fails to provide an alternatives analysis for the proposed access road 

network, both for construction access to the plant and access to the transmission line corridors, 

and to adequately demonstrate that impacts to resources are minimized and avoided. Please 

provide an analysis of alternatives for the access roads that considers and compares the 

benefits and impacts of all feasible alternative routes for ingress-egress, and demonstrates 

minimization and avoidance of impacts including but not limited to wetlands, impacts to state 

and federally protected species, impacts to existing water management features, impacts to 

Environmentally Endangered Lands projects, Natural Forest Communities, and tree resources 

protected by Chapter 24, Miami-Dade Code. Alternatives evaluated for ingress-egress to 

Turkey Point should include but not be limited to utilization of the existing Palm Drive 

(SW 344 Street) corridor with and without shift change modifications, and alternative 

construction entrances including but not limited to utilizing the existing plant entrance with shift 

change modifications or making improvements to the L-31 East levee for use as a temporary 
Appendix D 

October 2016 D-131 NUREG–2176 

construction entrance by backfilling a section of the L-31 E borrow canal. 

(0023-2-7 [LaFerrier, Marc])

Comment: Should the NPS decided to acquire FPL's property within ENP and not exchange 

lands, it is assumed that FPL would not abandon its objective to obtain a western route from 

Turkey Point to the Levee substation. FPL would, therefore, likely resume investigation of 

alternate route(s). These new route(s) could affect the local socioeconomic environment 

including people, property values, employment, and construction-related expenditures in MiamiDade County. These impacts should be evaluated in the EIS. (0025-3-47 [Kimball, Dan] 

[Lewis, Mark])

Response: The potential impacts of building and operating proposed Turkey Point Units 6 and 

7 and ancillary facilities and corridors on wetlands, Federally and State-listed species, and other 

terrestrially important resources will be discussed in Chapters 4 and 5 of the EIS, based on the 

affected environment described in Chapter 2. However, alternatives to the roads, pipelines, and 

transmission corridors proposed by FPL will not be considered in the NRC staffs analysis in the 

EIS because they are not alternatives to the proposed action (issuance of combined licenses) 

before the NRC. However, the Corps of Engineers, and perhaps the National Park Service, will 

be cooperating with the NRC on the EIS. To the extent that a cooperating agency addresses 

such alternatives for its NEPA analysis, those alternatives would likely be included in this EIS in 

order to support the cooperating agency’s environmental review. 

Comment: Given the value of utilizing the treated reclaimed water as a part of the cooling 

process, it seems beneficial to store or reroute this by-passed water for beneficial use rather 

than disposal. Where possible, recycling/reuse efforts should be utilized to maximize the use of 

the reclaimed waters to supplement operations that have traditionally utilized other surface 

water or groundwater as sources for cooling and/or for environmental enhancement. 

(0023-3-48 [LaFerrier, Marc])

Comment: Hence, underground injection is not a proven, reliable method of wastewater 

disposal in southern Miami-Dade County, most likely due to differences in regional geology. 

Therefore, FPL should investigate alternative methods of cooling water blowdown and 

wastewater disposal. What is FPL's contingency should FDEP not approve a Class I 

underground injection control permit for Units 6&7 operation? A feasibility analysis of treating 

wastewater for the benefit of the Biscayne Bay Coastal Wetlands/CERP project should be 

performed. (0025-3-22 [Kimball, Dan] [Lewis, Mark])

Response: A description of the site layout, the reactor type, and the cooling-water systems will 

be included in Chapter 3 of the EIS. Alternatives to the proposed method of disposal of 

wastewater will be presented in Chapter 9. 

Comment: [T]he foregoing discussion, the NPS recommends that the ElS identify and evaluate 

alternative Western Transmission Corridors outside the existing boundary of Everglades 

National Park and connecting wetland habitats. The National Environmental Policy Act 

mandates that reasonable alternatives to a proposed action be evaluated. Consistent with this 

requirement, the EIS should evaluate other corridors that could be considered as reasonable 

alternatives to the segments of the West Preferred and West Secondary Corridors that run 
Appendix D 

NUREG–2176 D-132 October 2016 

through Everglades National Park (and Water Conservation Area 3B). The NPS recommends 

this analysis focus on the zone between Krome Avenue and the Miami-Dade County Urban 

Development Boundary in order to identify potential corridors that would avoid and minimize 

adverse impacts to people, wildlife in the Everglades ecosystem, special status species and 

other natural and cultural resources. (0025-2-12 [Kimball, Dan] [Lewis, Mark])

Response: The potential impacts from building and operating transmission lines associated 

with proposed Turkey Point Units 6 and 7 will be addressed in the Chapters 4, 5, and 7 of the 

EIS. However, alternatives to the roads, pipelines, and transmission corridors proposed by FPL 

will not be considered in the NRC staffs analysis in the EIS because they are not alternatives to 

the proposed action (issuance of combined licenses) before the NRC. However, the Corps of 

Engineers, and perhaps the National Park Service, will be cooperating with the NRC on the EIS. 

To the extent that a cooperating agency addresses such alternatives for its NEPA analysis, 

those alternatives would likely be included in this EIS in order to support the cooperating 

agency’s environmental review. 

Comment: What alternatives are being investigated to avoid use of radial collector wells, even 

as a backup system? In particular, we recommend that the applicant address the ability of the 

project to use reclaimed water technology either in part or in full. (0018-14 [Poole, Mary Ann])

Comment: What contingency plans are considered for alternative water sources if fish and 

wildlife resources demonstrate negative responses to this technology? We would expect FPL to 

provide for a contingency plan in their Conditions-of-Certification, should monitoring indicate that 

this technology is counter-productive to the recovery of Biscayne Bay. (0018-9 [Poole, Mary Ann])

Comment: Please provide a more detailed justification (including all supporting data and 

assumptions) in selecting the Biscayne Aquifer Radial Collector Well alternative instead of the 

Floridan Aquifer and offshore (marine surface) water alternatives as secondary. 

(0023-1-49 [LaFerrier, Marc])

Response: These comments are directed at the applicant and refer specifically to the SCA 

submitted to the State of Florida by FPL, but they indicate an interest in the cooling-water supply 

for proposed Turkey Point Units 6 and 7. The cooling-water source for the proposed units will 

be described in Chapter 3 of the EIS. Alternative water supplies will be considered in 

Chapter 9. 

D.1.25 Comments Concerning Alternatives – Sites 

Comment: We are not opposed to nuclear energy but we don't support additional reactors next 

to the national parks that we're trying to restore and preserve. (0001-15-1 [Cornick, Lance])

Comment: My next concern is the risk of building nuclear reactors so close to Miami and the 

Everglades. (0001-19-3 [Ryan, Megan])

Comment: I understand there are alternate locations that are being looked at and considered. 

So I would implore the Regulatory Commission to come back with a recommendation that an 

alternate site that doesn't have the fragile environmental community that Turkey Point is faced 

with and all of the adverse impacts, take it somewhere else. (0001-21-6 [Lerner, Cindy])
Appendix D 

October 2016 D-133 NUREG–2176 

Comment: If they're sending this power north -- and somebody said we need this power here 

in Florida City. My God, we don't need two nuclear plants worth of power in Florida City. And if 

the power lines are going north, why don't they just leave them go up there and build a power 

plant up north instead of putting it down here? (0001-6-9 [Miller, Lloyd])

Comment: Turkey Point is probably the most environmentally unlikely nuclear installation in the 

nation. If we had to do it all over again, would we really put a massive power plant complex on 

the border of a national park in the middle of sensitive wetlands and then convert thousands of 

acres of coastal mangroves into a giant radiator for two nuclear reactors? We may not have the 

chance to do it over, but we can certainly think better about making things worse. The 

environmental review of an expanding nuclear facility abutting a national park, in the middle of 

wetlands, that the Federal, State, and local governments have spent millions working to restore 

and protect, deserves extra scrutiny. (0002-1-1 [Sorenson, Katy])

Comment: The EIS should include a comprehensive evaluation of the potential impacts of 

constructing and operating two nuclear power plants and related facilities at the four alternate 

sites located in Glades, Martin, Okeechobee and St. Lucie Counties. This analysis will enable 

the applicant, stakeholders, decisionmakers and the general public to identify the 

environmentally preferable alternative and if there is an obviously superior site for the 

construction and operation of the proposed facilities. (0025-1-10 [Kimball, Dan] [Lewis, Mark])

Comment: A review of the Florida Power & Light Company Project Bluegrass Nuclear Power 

Plant Site Selection Study Report (summarized in COL Environmental Report, Section 9.3), 

leads the National Park Service (NPS) to question the adequacy of the site selection study. 

Please note that only excerpts from the site selection study report referenced above were 

included as pat1 of Section 9.3 of the COL Environmental Report. For instance, the Cooling 

Water Supply Criterion, PI, is based on an ocean intake water source (to avoid Biscayne Bay) 

approximately seven miles offshore as a back-up water supply source (Pages B-3, B-4, C- 93, 

and C-99). Therefore, it appears that the RCWs, proposed for use as a water source in the 

COL, may not have been evaluated as part of the site selection process. (0025-1-6 [Kimball, Dan] 

[Lewis, Mark])

Comment: [T]he land use rating issued to Turkey Point was the highest (most favorable) 

among the eight site locations evaluated even though ecologically sensitive habitats were 

identified. The Report simply assumed that the Biscayne National Park would not be affected 

by the plant since land is owned by FPL and existing power plants/nuclear units are located 

there now (Page C-95). However, the RCW operation and use of the area for the CERP 

Biscayne Bay Coastal Wetlands project was not considered during that analysis. Furthermore, 

the Turkey Point location was issued the highest possible index score for possible risk of 

groundwater contamination, compared to the other locations evaluated (Page C-51). The 

Ecology/Federal RTE Species Criterion, P5, identified Turkey Point as having the highest 

number of threatened and endangered (T&E) species (Page B-19). The evaluation of disruption 

to important species was based on the Federally protected species list (22 aquatic and 

terrestrial species); this review did not consider State of Florida T&E species. If the NPS is to 

be a cooperating agency on the EIS, then impacts to state-listed and locally-listed species 

would need to be evaluated in this document as well (NPS Management Policies 2006 

sec. 4.4.2.3). Moreover, the Wetlands Criterion, P6, did not include estuarine, marine, riverine, 
Appendix D 

NUREG–2176 D-134 October 2016 

or freshwater pond wetland acreage in the evaluation (page B-21), all of which are required to 

be considered due to the potential impacts associated with the RCW operation. 

(0025-1-7 [Kimball, Dan] [Lewis, Mark])

Comment: Of particular concern is the fact that the Turkey Point location received an average 

score during the initial screening site selection evaluation (Page 16), yet that score was 

changed to the highest favorable score in the final general criteria evaluation (Page 23). The 

reason for the increase in favorability is unclear. It appears that the Turkey Point location was 

given additional weight based on non-quantified socioeconomic factors. (0025-1-8 [Kimball, Dan] 

[Lewis, Mark])

Comment: [T]he NPS recommends that the site selection process be re-evaluated, reflect the 

actual proposed features of the COL application, and consist of a more detailed and accurate 

comprehensive analysis that accounts for the RCW operation, state and federal T &E listed 

species and their habitats, conflicts with CERP Biscayne Bay Coastal Wetlands projects, and a 

quantifiable socioeconomic analysis. It is important that these factors be carefully considered in 

the process because they could significantly affect the results. (0025-1-9 [Kimball, Dan] 

[Lewis, Mark])

Comment: It's location and proximity to Everglades National Park, Biscayne National Park, 

John Pennekamp Coral Reef State Park, and the Florida Keys National Marine Sanctuary 

makes it an eyesore on the coastline and a drain on the environment, not to mention the 

potentially catastrophic damage that would occur if there should be a radioactive release. 

(0027-2 [Moses, Dorothy])

Response: The alternative site-selection process will be reviewed to determine whether it is 

systematic, employs reasonable selection criteria, and constitutes an acceptable number of 

reasonable sites for consideration. The alternative sites will be compared against the proposed 

site to determine whether any of the alternative sites are environmentally preferable to the 

proposed site. The process and results will be provided in Chapter 9 of the EIS. 

Comment: The Mayors from our surrounding cities gathered and together put forth information 

about their concerns on the environmental impact, not just the site of the reactors, but also the 

transmission lines. I'm here this evening just so I can add my voice to their concerns. 

(0002-2-1 [Meerbott, Tim]) 

Response: The impacts of building proposed Turkey Point Units 6 and 7 and transmission 

lines will be considered in Chapter 4 of the EIS, and the impacts of operating the units and 

transmission lines will be considered in Chapter 5. 

D.1.26 Comments Concerning Benefit-Cost Balance 

Comment: The NRC should be aware that FPL's ratepayers aren't happy about the tens of 

millions they have already been forced to pay in advance given the pre-payment scheme in 

place to finance new reactors in Florida. And FP&L is asking again the troubled Florida Public 

Service Commission for tens of millions more with hearings set for the end of August. 

(0001-14-2 [Hancock, Mandy])
Appendix D 

October 2016 D-135 NUREG–2176 

Comment: The FP&L has garnered several hundred millions from its ratepayers at this early 

stage through the Florida's Early Cost Recovery Program awarded by the Public Service 

Commission. Under the program, FP&L could conceivably recoup the cost of -- the entire cost 

of the plant, estimated to be between 14 and 30 billion, and may not actually be required to ever 

build that plant. (0001-16-6 [Showen, Steve])

Comment: Determine how public investment costs will be equitably shared by all FPL rate 

holders, no matter what delivery system is ultimately constructed. (0019-11 [Hamilton, Karen])

Comment: Outrageous monetary costs to rate payers. FPL is now collecting $18 billion from its 

4.5 million customers to provide nuclear electricity for 750,000 homes. (0031-4 [De Villiers, Elena])

Response: The costs of power generation are passed on to customers. The NRC's 

responsibility is to regulate the nuclear industry to protect the public health and safety within 

existing policy. The NRC is not involved in establishing the rates paid by customers; therefore, 

these comments are outside the scope of the NRC's authority and will not be evaluated further. 

Comment: This should be our choice, the ratepayers. Me, my family, my neighbors, we have 

already seen an increase in our bills to start paying for these reactors. These risky projects 

have a history of going over budget and taking longer than promised. (0001-19-5 [Ryan, Megan])

Comment: Are you aware that Wall Street will not finance nuclear power plants? TP will cost 

around $35,000,000,000. Divided by 4.4 million homes, that is $8,000 per home, and then FPL 

will own them and we will pay 10.5% annually on FPL's free asset until they are depreciated. 

No wonder they want to build them, on the public's money. It will more than triple their market 

cap. And before I will do that, I will put in solar and go off the grid and reduce my FPL bill to 

about $40 per month, and if enough people do that, who will pay for those carbuncles on the 

bay? Power companies have gone bankrupt. Or would Uncle Sam have to bail them out too? 

(0016-7 [White, Barry])

Response: Issues related to costs associated with previous projects are outside the scope of 

the proposed action and will not be addressed in the EIS. The estimated overall costs and 

environmental impacts of the proposed project will be addressed in Chapter 10 of the EIS. The 

benefit-cost balance for the project will rely on the best available estimate of project timing and 

duration, while noting possible uncertainties that may affect those estimates. 

Comment: In reality, nuclear energy is a dinosaur that would be extinct if left to market forces 

except for its resuscitation by huge infusions of public cash. Wall Street considers nuke power 

too risky to invest in and nuclear energy is the most expensive form of energy. It can't make it 

on its own. Hence, we see the political influence of the industry in the halls of government. 

(0001-16-5 [Showen, Steve])

Comment: If nuclear energy was truly sustainable, cost-effective and truly a profitable 

business, the companies trying to build new nuclear plants would not have to keep going back 

to Congress for loan guarantees, liability insurance and tax breaks. The fact that this industry 

cannot obtain operating insurance by any means other than Congressional action is extremely 
Appendix D 

NUREG–2176 D-136 October 2016 

telling! Nuclear plants are uninsurable!!!! Does that sound like an environmentally safe, 

economically sound business to you?! It surely doesn't to me! (0021-15 [Wilansky, Laura])

Response: 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. Determining whether nuclear power should be subsidized is outside of the NRCs 

mission and authority and will not be addressed in the EIS. 

Comment: I ask you to include the true costs of nuclear plants throughout their entire life cycle 

in your environmental calculations, including the guaranteed damage to Florida's environment. 

(0021-18 [Wilansky, Laura])

Response: The benefit-cost balance for proposed Turkey Point Units 6 and 7 will rely on the 

best available estimate of project timing and duration, with uncertainties noted. The estimated 

overall costs and environmental impacts of the proposed project during both building and the 

40-year operations period will be discussed in Chapter 10 of the EIS. 

Comment: I am disheartened to see that a new facility can cost 10's of billions of dollars to 

build but we have sat around for the past 30 years so we must do something. 

(0004-2 [Singer, Craig])

Response: The costs and benefits of building and operating proposed Turkey Point Units 6 

and 7 will be addressed in Chapter 10 of the EIS. 

Comment: I would like to first address the issue of jobs. If, in fact, the 15 to $30 billion that 

Steve mentioned were manna from heaven that we would only get if we built these power 

plants, then I think it's worthwhile to consider, in isolation, the construction jobs and the 800 jobs 

that would be ongoing. If not -- and of course it's not manna from heaven -- we have to compare 

what 15 to $30 billion could do spent in other ways. So I suggest that it's very much in scope to 

consider a cost benefit analysis that compares other ways of spending that money. 

(0001-24-1 [Harum-Alvarez, Albert])

Comment: And so I would like to propose that the NRC include a cost benefit analysis that 

compares this proposed expansion of Turkey Point to distributed generation because, of course, 

that would get around the whole issue of transmission lines completely, including distribution of 

small nukes; building efficiency, which would create the largest number of jobs across the 

region; and finally, a no-build option which I suggest should always be in your comparisons 

because, of course, if we got to keep the 15 to $30 billion ourselves, we would find some way to 

spend it or invest it, and that would have an economic impact as well. Could very well give us 

our own efficiency by having us work on our houses individually. 

(0001-24-3 [Harum-Alvarez, Albert])

Response: Job creation during the building and operation of proposed Turkey Point Units 6 

and 7 will be discussed in the socioeconomic sections of Chapters 4 and 5 of the EIS. The 

benefit-cost balance for the project will rely on the best available estimate of project timing and 

duration, while noting possible uncertainties that may affect those estimates. The NRC benefitcost analysis in Chapter 10 is confined to an analysis of the as-proposed facilities at the 

proposed location. Alternatives will be considered in Chapter 9. 
Appendix D 

October 2016 D-137 NUREG–2176 

Comment: The new reactors are too costly and will require too much water. 

(0017-1 [Troner, Susannah])

Response: This comment expresses opposition to the cost of the project. An evaluation of the 

benefit-cost balance of building proposed Turkey Point Units 6 and 7 will be discussed in 

Chapter 10 of the EIS. Water usage will be discussed in the hydrology sections of Chapters 4 

and 5. 

Comment: [CASE submitted an article titled, "Proposed Turkey Point Nuclear Reactor Units 6 

& 7 -Financially Prudent?" by George Cavros, Esq. The article expressed concerns about the 

benefit/cost balance of building nuclear reactors.] (0003-2-2 [White, Barry])

Comment: The applicant should consider both monetary and societal costs when making 

decisions about infrastructure location and technology. Special attention should be given to 

limiting environmental, health, economic and social impacts to the surrounding communities. 

(0019-8 [Hamilton, Karen])

Response: The benefit-cost balance will be discussed in Chapter 10 of the EIS and will include 

environmental, health, social, and monetary costs along with benefits. 

Comment: [T]he two additional nuclear power plants: will take ten to fifteen years to become 

operational, which will make them technologically obsolete before completion. 

(0012-14 [Payne, Nkenga])

Response: The long-term benefits associated with the cost of building proposed Turkey Point 

Units 6 and 7 will be presented in Chapter 10 of the EIS. 

Comment: Please state the life-cycle costs of the water management feature(s). 

(0022-3-16 [Reynolds, Laura])

Response: Hydrology will be discussed in Chapters 4 and 5 of the EIS. The costs and benefits 

of building and operating proposed Turkey Point Units 6 and 7 will be addressed in Chapter 10. 

Comment: Please state the costs and benefits of constructing and operating Class I UIC wells 

for units 6&7. Please state the costs and benefits of constructing and operating Class V UIC 

wells for units 6&7 (0022-2-10 [Reynolds, Laura])

Response: Class I injection wells are used to inject wastewater below the lowermost 

underground source of drinking water and have been proposed for disposal of cooling-system 

blowdown water by FPL. The proposed system will be presented in Chapter 3 of the EIS. 

Alternatives for wastewater disposal will be presented in Chapter 9. Benefit-cost analysis for 

the proposed units will be presented in Chapter 10. 

Comment: Everglades Restoration, Biscayne Bay Restoration, is about restoring that area for 

its economic value, for its environmental value, and that has to be considered. This is two 

National Parks. Two National Parks that could be impacted by this. Biscayne Bay, and for the 

transmission siting aspect of it, Everglades National Park. Again, not one, but two National 

Parks that we're spending billions of dollars to restore because of their economic value, and the 
Appendix D 

NUREG–2176 D-138 October 2016 

economic value of restoring them. So, again, that negative economic cost has to be considered 

in your analysis. (0002-6-8 [Grosso, Richard])

Response: Impacts on Biscayne National Park and Everglades National Park from building 

and operating proposed Turkey Point Units 6 and 7 will be discussed in Chapters 4, 5, and 7 of 

the EIS. The costs and benefits of the proposed project will be presented in Chapter 10. 

D.2 References 

10 CFR Part 52. 2012. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 

Certifications, and Approvals for Nuclear Power Plants." Washington, D.C. TN251. 

36 CFR Part 800. 2012. Code of Federal Regulations, Title 36, Parks, Forests, and Public 

Property, Part 800, "Protection of Historic Properties." Washington, D.C. TN513. 

75 FR 33851. June 15, 2010. “Florida Power & Light Company; Turkey Point, Units 6 and 7; 

Combined License Application, Notice of Intent To Prepare an Environmental Impact Statement 

and Conduct Scoping Process.” Federal Register, Nuclear Regulatory Commission, 

Washington, D.C. TN511. 

42 USC 4321 et seq. National Environmental Policy Act (NEPA) of 1969, as amended. TN661. 

NRC (U.S. Nuclear Regulatory Commission). 2010. Staff Memorandum from T. Terry to R. 

Whited dated August 31, 2010, regarding “Summary of Public Meetings to Support the Review 

of the Turkey Point, Units 6 and 7, Combined License Application.” Washington, D.C. 

Accession No. ML102170529. TN514. 

NRC (U.S. Nuclear Regulatory Commission). 2010. Staff Memorandum from A.J. Kugler to R. 

Whited, dated December 1, 2010, regarding “Scoping Summary Report Related to the 

Environmental Scoping Process for the Turkey Point Units 6 and 7 Combined License 

Application.” Washington, D.C. Accession No. ML103130610. TN515. 

NRC (U.S. Nuclear Regulatory Commission). 2010. Environmental Impact Statement Scoping 

Process Summary Report Turkey Point Units 6 and 7 Combined Licenses Miami-Dade County, 

Florida. Rockville, Maryland. Accession No. ML103130612. TN516. 

NRC (U.S. Nuclear Regulatory Commission). 2010. Official Transcript of Proceedings for 

Turkey Point Site License Public Meeting: Afternoon Session. Neal R. Gross and Co., Inc., 

Washington, D.C. Accession No. ML102150591. TN518. 

NRC (U.S. Nuclear Regulatory Commission). 2010. Official Transcript of Proceedings for 

Turkey Point Site License Public Meeting: Evening Session. Neal R. Gross and Co., Inc., 

Washington, D.C. Accession No. ML102150597. TN519. 
APPENDIX E 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

COMMENTS AND RESPONSES 

October 2016 NUREG–2176 

APPENDIX E 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

COMMENTS AND RESPONSES 

Note: Appendix E, Draft Environmental Impact Statement Comments and Responses can be 

found in Volume 4 of NUREG-2176, Environmental Impact Statement for Combined Licenses 

(COLs) for Turkey Point Nuclear Plant Units 6 and 7. 

APPENDIX F 

KEY CONSULTATION CORRESPONDENCE 

October 2016 F-1 NUREG–2176 

APPENDIX F 

KEY CONSULTATION CORRESPONDENCE 

Table F-1 identifies correspondence received during the evaluation process for the combined 

construction permits and operating licenses (COLs) application for the siting of two new nuclear 

units, Turkey Point Nuclear Plant Units 6 and 7, in Miami-Dade County, Florida. The initial 

biological assessment for the U.S. Fish and Wildlife Service is provided in Appendix F-2; the initial 

biological assessment for the National Marine Fisheries Service is provided in Appendix F-3; the 

essential fish habitat assessment submitted to National Marine Fisheries Service is provided in 

Appendix F-4. Follow on correspondence with the agencies is listed in Table F-1. The 

correspondence documents can be found in the Agencywide Documents Access and 

Management System (ADAMS) electronic public reading room accessible at 

http://www.nrc.gov/readingrm/adams.html, using the accession numbers listed under Date of 

Document. If you encounter issues accessing ADAMS, call the U.S Nuclear Regulatory 

Commission at 1800-397-4209 or 301-415-4737, or send an e-mail to pdr.resource@nrc.gov. 

Table F-1. Key Combined License Consultation Correspondence 

Source Recipient Date of Letter

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Advisory Council on Historic 

Preservation (Mr. Reid Nelson) 

June 23, 2010 

(ML101610537) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Muscogee (Creek) Nation (Ms. Joyce 

Bear) 

June 24, 2010 

(ML101690496) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Poarch Band of Creek Indians (Mr. 

Robert Thrower, Tribal Historic 

Preservation Officer) 

June 24, 2010 

(ML101690503) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Seminole Nation of Oklahoma (Ms. 

Natalie Deere, Tribal Historic 

Preservation Officer) 

June 24, 2010 

(ML101690497) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Seminole Tribe of Florida (Mr. W.S. 

Steele) 

June 24, 2010 

(ML101690499) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Florida Deputy State Historic 

Preservation Officer (Ms. Laura 

Kammerer) 

June 29, 2010 

(ML101690480) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Archaeological and Historical 

Conservancy, Inc. (Mr. Robert Carr) 

July 1, 2010 

(ML101690462) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

City of Coral Gables, Historic 

Preservation Administrator (Ms. Simone 

Chin) 

July 1, 2010 

(ML101730494) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

City of Homestead Community 

Redevelopment Agency (Mr. Dan Wick) 

July 1, 2010 

(ML101730511) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

City of Miami Historic Preservation 

Officer (Ms. Ellen Uguccioni) 

July 1, 2010 

(ML101690472) 
Appendix F 

NUREG–2176 F-2 October 2016 

Table F-1. Key Combined License Consultation Correspondence

Source Recipient Date of Letter

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

City of South Miami (Mr. Sanford 

Youkilis) 

July 1, 2010 

(ML101730515) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

Florida Office of Historic & 

Archaeological Resources (Ms. 

Kathleen Kauffman) 

July 1, 2010 

(ML101690468) 

Advisory Council on Historic 

Preservation (Ms. Caroline Hall) 

U.S. Nuclear Regulatory Commission 

(Ms. Laurel Bauer) 

July 8, 2010 

(ML101900325) 

Florida Deputy State Historic 

Preservation Officer (Ms. Laura 

Kammerer) 

U. S. Nuclear Regulatory Commission July 28, 2010 

(ML102220345) 

Miami-Dade County Historic 

Preservation Chief (Ms. Kathleen 

Kauffman) 

U. S. Nuclear Regulatory Commission August 12, 2010 

(ML102390102) 

Seminole Tribe of Florida (Mr. Willard 

Steele) 

U.S. Nuclear Regulatory Commission 

(Mr. Andrew Kugler) 

September 14, 2010 

(ML102660296) 

U.S. Nuclear Regulatory Commission 

(Mr. Andrew Kugler) 

U.S. Nuclear Regulatory Commission 

(Mr. Ryan Whited) 

September 21, 2010 

(ML101880786) 

U.S. Nuclear Regulatory Commission 

(Mr. Andrew Kugler) 

Seminole Tribe of Florida (Mr. W.S. 

Steele) 

December 8, 2010 

(ML103420623) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

Advisory Council on Historic 

Preservation (Mr. Reid Nelson) 

October 23, 2014 

(ML14269A049) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

Archaeological and Historical 

Conservancy, Inc. (Mr. Robert Carr) 

October 23, 2014 

(ML14269A067) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

City of Coral Gables (Ms. Dona Spain) October 23, 2014 

(ML14283A127) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

City of Homestead Community 

Redevelopment Agency (Mr. Rick 

Ammirato) 

October 23, 2014 

(ML14281A316) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

City of Miami Preservation Officer (Ms. 

Megan Cross Schmitt) 

October 23, 2014 

(ML14283A175) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

City of South Miami Planning Director 

(Mr. Christopher Brimo) 

October 23, 2014 

(ML14283A124) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

Cultural and Historical Programs 

Compliance Review Supervisor (Dr. 

Tim Parsons) 

October 23, 2014 

(ML14296A592) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

Florida Division of Historical Resources 

(Mr. Robert F. Bendus) 

October 23, 2014 

(ML14269A082) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

Florida Office of Historic & 

Archaeological Resources (Ms. 

Kathleen Kauffman) 

October 23, 2014 

(ML14281A278) 
Appendix F 

October 2016 F-3 NUREG–2176 

Table F-1. Key Combined License Consultation Correspondence

Source Recipient Date of Letter

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

Muscogee (Creek) Nation Tribal 

Historic Preservation Officer (Mr. 

Emman Spain) 

October 23, 2014 

(ML14283A151) 

U.S. Nuclear Regulatory Commission 

(Ms. Jennifer Dixon-Herrity) 

Seminole Tribe of Florida Tribal Historic 

Preservation Officer (Dr. Paul 

Backhouse) 

October 23, 2014 

(ML14283A141) 

U.S. Nuclear Regulatory Commission Seminole Tribe of Florida Tribal Historic 

Preservation Office 

June 23, 2015 

(ML16266A254) 

U.S. Nuclear Regulatory Commission Miccosukee Tribe of Indians of Florida 

Tribal Historic Preservation Office 

June 24, 2015 

(ML16266A255) 

Department of Army, Jacksonville 

District Corps of Engineers (Ms.

Megan Clouser) 

Seminole Tribe of Florida Tribal Historic 

Preservation Officer (Mr. Bradley M. 

Mueller) 

October 5, 2015 

(ML15289A368) 

Department of Army, Jacksonville 

District Corps of Engineers (Ms. Ingrid 

Gilbert) 

Miccosukee Tribe of Indians of Florida 

Tribal Historic Preservation Officer (Mr. 

Fred Dayhoff) 

March 7, 2016 

(ML16172A120) 

Florida Power & Light (Mr. Matthew J. 

Raffenberg) 

Department of Army, Jacksonville 

District Corps of Engineers (Ms. Megan 

Clouser) 

March 31, 2016 

(ML16095A127) 

Department of Army, Jacksonville 

District Corps of Engineers (Mr. Jacob 

Hemingway) 

Seminole Tribe of Florida Tribal Historic 

Preservation Officer (Mr. Bradley M. 

Mueller) 

August 2, 2016 

(ML16266A253) 

U.S. Nuclear Regulatory Commission 

(Dr. Allen Fetter) 

U.S. Fish and Wildlife Service (Mr. 

Larry Williams) 

September 28, 2016 

(ML16237A212, 

ML16237A213, 

ML16237A214) 

Appendix F-2 

The U.S. Nuclear Regulatory Commission (NRC) has not reproduced the “Biological 

Assessment for the U.S. Fish and Wildlife Service” in the paper reproduction of the 

Environmental Impact Statement for Combined Licenses (COLs) for Turkey Point Units 6 and 7. 

This document can be found in the Agencywide Documents Access and Management System 

(ADAMS) electronic public reading room accessible at http://www.nrc.gov/readingrm/adams.html, using accession number ML15028A372. If you encounter issues accessing 

ADAMS, call the NRC at 1800-397-4209 or 301-415-4737, or send an e-mail to 

pdr.resource@nrc.gov. 
Appendix F 

NUREG–2176 F-4 October 2016 

Appendix F-3 

The U.S. Nuclear Regulatory Commission (NRC) has not reproduced the “Biological 

Assessment for the National Marine Fisheries Service” in the paper reproduction of the 

Environmental Impact Statement for Combined Licenses (COLs) for Turkey Point Units 6 and 7. 

This document can be found in the Agencywide Documents Access and Management System 

(ADAMS) electronic public reading room accessible at http://www.nrc.gov/readingrm/adams.html, using accession number ML15028A378. If you encounter issues accessing 

ADAMS, call the NRC at 1800-397-4209 or 301-415-4737, or send an e-mail to 

pdr.resource@nrc.gov. 

Appendix F-4 

The U.S. Nuclear Regulatory Commission (NRC) has not reproduced the “Comment Draft 

Essential Fish Habitat Assessment for the National Marine Fisheries Service” in the paper 

reproduction of the Environmental Impact Statement for Combined Licenses (COLs) for Turkey 

Point Units 6 and 7. This document can be found in the Agencywide Documents Access and 

Management System (ADAMS) electronic public reading room accessible at 

http://www.nrc.gov/reading-rm/adams.html, using accession number ML15028A395. If you 

encounter issues accessing ADAMS, call the NRC at 1800-397-4209 or 301-415-4737, or send 

an e-mail to pdr.resource@nrc.gov. 
APPENDIX G 

SUPPORTING DOCUMENTATION 

October 2016 G-1 NUREG–2176 

APPENDIX G 

SUPPORTING DOCUMENTATION 

G.1 Supporting Socioeconomic Documentation 

Workforce estimates reflect direct labor estimated by the applicant to be employed in 

preconstruction, construction, and operations of the Turkey Point Nuclear Power Plant 

(Turkey Point) Units 6 and 7. In Table G-1, months are numbered starting from the beginning of 

the construction phase, with negative numbers indicating preconstruction, and the peak 

workforce is expected to occur in month 42. 

Table G-1. Estimated Workforce by Month During Preconstruction, Construction, and 

Operation of Proposed Turkey Point Units 6 and 7 (FPL 2014-TN4058) 

Month 

Number of Employees 

Construction 

Operations 

Unit 6 Unit 7 Total Total 

Preconstruction Activities 

-39 40 - - - 40 

-38 45 45 

-37 55 55 

-36 60 - - - 60 

-35 70 - - - 70 

-34 75 - - - 75 

-33 90 - - - 90 

-32 100 - - - 100 

-31 110 - - - 110 

-30 130 - - - 130 

-29 150 - - - 150 

-28 180 - - - 180 

-27 230 - - - 230 

-26 280 - - - 280 

-25 320 - - - 320 

-24 390 - - - 390 

-23 465 - - - 465 

-22 540 - - - 540 

-21 575 - - - 575 

-20 650 - - - 650 

-19 740 - - - 740 

-18 825 - - - 825 

-17 900 - - - 900 

-16 1,000 - - - 1,000 

-15 1,020 - - - 1,020 

-14 1,090 - - - 1,090 
Appendix G 

NUREG–2176 G-2 October 2016 

Table G-1. (contd)

Month 

Number of Employees 

Construction 

Operations 

Unit 6 Unit 7 Total Total 

-13 1,180 - - - 1,180 

-12 1,200 - - - 1,200 

-11 1,220 - - - 1,220 

-10 1,240 - - - 1,240 

-9 1,300 - - - 1,300 

-8 1,320 - - - 1,320 

-7 1,340 - - - 1,340 

-6 1,350 - - - 1,350 

-5 1,375 - - - 1,375 

-4 1,400 - - - 1,400 

-3 1,425 - - - 1,425 

-2 1,450 - - - 1,450 

-1 1,475 - - - 1,475 

Unit 6 Construction Begins 

1 1,500 - - - 1,500 

2 1,525 - - - 1,525 

3 1,550 - - - 1,550 

4 1,600 - - - 1,600 

5 1,625 - - - 1,625 

6 1,650 - - - 1,650 

7 1,675 - - - 1,675 

8 1,700 - - - 1,700 

9 1,725 - - - 1,725 

10 1,750 - - - 1,750 

11 1,775 - - - 1,775 

12 1,800 - - - 1,800 

Unit 7 Construction Begins 

13 1,825 - - - 1,825 

14 1,850 - - - 1,850 

15 1,900 - - - 1,900 

16 1,950 - - - 1,950 

17 2,000 - - - 2,000 

18 2,100 - - - 2,100 

19 2,250 - - - 2,250 

20 2,350 - - - 2,350 

21 2,450 - - - 2,450 

22 2,600 - - - 2,600 

23 2,750 - - - 2,750 

24 2,900 - - - 2,900 

25 3,050 - - - 3,050 

26 3,200 - - - 3,200 

27 3,350 - - - 3,350 

28 3,500 - - - 3,500 

29 3,650 - - - 3,650 

30 3,850 - - - 3,850 
Appendix G 

October 2016 G-3 NUREG–2176 

Table G-1. (contd)

Month 

Number of Employees 

Construction 

Operations 

Unit 6 Unit 7 Total Total 

31 3,950 - - - 3,950 

32 3,950 - - - 3,950 

33 3,950 - - - 3,950 

34 3,950 - - - 3,950 

35 3,950 - - - 3,950 

36 3,950 - - - 3,950 

37 3,950 - - - 3,950 

38 3,950 - - - 3,950 

39 3,950 - - - 3,950 

40 3,950 - - - 3,950 

41 3,950 16 - 16 3,966 

42 3,950 33 - 33 3,983 

43 3,925 49 - 49 3,974 

44 3,900 66 - 66 3,966 

45 3,870 82 - 82 3,952 

46 3,850 99 - 99 3,949 

47 3,825 115 - 115 3,940 

48 3,800 132 - 132 3,932 

49 3,775 148 - 148 3,923 

50 3,750 164 - 164 3,914 

51 3,725 181 - 181 3,906 

52 3,700 197 - 197 3,897 

53 3,675 214 16 230 3,905 

54 3,650 230 33 263 3,913 

55 3,625 247 49 296 3,921 

56 3,600 263 66 329 3,929 

57 3,575 280 82 362 3,937 

58 3,550 296 99 395 3,945 

59 3,525 313 115 428 3,953 

60 3,500 329 132 461 3,961 

61 3,450 345 148 493 3,943 

62 3,400 362 164 526 3,926 

63 3,300 378 181 559 3,859 

64 3,200 395 197 592 3,792 

65 3,100 403 214 617 3,717 

66 3,000 403 230 633 3,633 

67 2,900 403 247 650 3,550 

68 2,800 403 263 666 3,466 

69 2,700 403 280 683 3,383 

70 2,600 403 296 699 3,299 

71 2,500 403 313 716 3,216 

72 2,400 403 329 732 3,132 

73 2,300 403 345 748 3,048 

74 2,200 403 362 765 2,965 

75 2,100 403 378 781 2,881 
Appendix G 

NUREG–2176 G-4 October 2016 

Table G-1. (contd)

Month 

Number of Employees 

Construction 

Operations 

Unit 6 Unit 7 Total Total 

76 1,900 403 395 798 2,698 

77 1,700 403 403 806 2,506 

78 1,500 403 403 806 2,306 

79 1,300 403 403 806 2,106 

80 1,100 403 403 806 1,906 

81 800 403 403 806 1,606 

82 550 403 403 806 1,356 

83 450 403 403 806 1,256 

84 375 403 403 806 1,181 

Source: (FPL 2014-TN4058) 

G.2 Supporting Radiological Dose Assessment 

The U.S. Nuclear Regulatory Commission (NRC) staff performed an independent dose 

assessment of the radiological impacts resulting from normal operation of the proposed nuclear 

Units 6 and 7 at the Florida Power & Light Company (FPL) Turkey Point site. The results of that 

assessment are presented in this section in comparison to the results of the FPL Environmental 

Report (ER) Section 5.9 (FPL 2014-TN4058). This section is divided into five sections: (1) 

dose estimates from the deep-well injection exposure scenario, (2) dose estimates to the public 

from gaseous effluents, (3) cumulative dose estimates, (4) dose estimates to construction 

workers from Units 3, 4, and 6 during construction of Unit 7, and (5) dose estimates to biota 

other than humans. 

G.2.1 Dose Estimates from the Deep-Well Injection Exposure Scenario 

Hydrologic alterations affecting the Boulder Zone of the Lower Floridan aquifer would result from 

the deep-well injection of blowdown water and other liquid waste streams from the proposed 

Turkey Point Units 6 and 7. The injected water would include effluent from the sanitary wastetreatment plant, wastewater-retention basin, and liquid radioactive-waste-treatment system. 

The Boulder Zone is isolated from the Upper Floridan aquifer which can be used as an 

underground source of drinking water (USDW). However, although a normal operation 

exposure pathway is not expected, because of the unique nature of the radioactive effluent 

discharge and in response to NRC requests for additional information (NRC 2013-TN3937), FPL 

evaluated three potential dose scenarios in Final Safety Analysis Report (FSAR) Section 

11.2.3.5 (FPL 2015-TN4502) and ER Section 5.4.1.1 (FPL 2014-TN4058) based on potential 

groundwater flow pathways of the injected radioactive liquid effluent that could result in 

inadvertent radioactive exposure to the general public. Therefore, FPL included an analysis of 

the potential liquid effluent pathways for radiological impacts from this waste disposal method 

(FPL 2014-TN4058), which was reviewed by the NRC staff for this environmental impact 

statement. The NRC staff reviewed and evaluated FPL’s deep-well injection of radioactive 

liquid effluent and determined that the applicant’s analyses met the regulatory requirements for 

such releases. The detailed results of the NRC staff’s review are provided in Chapter 11, 

Radiological Waste Management, of the Advanced Safety Evaluation Report (NRC 2016-

TN4776). 
Appendix G 

October 2016 G-5 NUREG–2176 

This discussion is concerned with the dose estimates of the scenarios, not with the hydrology 

model of the injectate transport. The hydrology model is discussed in Section G.3. 

The results of the evaluation are summarized in the following sections. 

G.2.1.1 Scope 

As discussed in Sections 5.9.2.1 and 5.9.3.3, three exposure scenarios were postulated. 

However, does analysis was not performed for one scenario, the Ocean Reef Club scenario 

(located approximately 7.7 mi south-southeast of the deep-well injection analysis centerpoint), 

because the injectate plume never reached that far. Therefore, the only scenarios for which 

dose analysis was performed were the so-called “child” and “driller” scenarios located at a 

private parcel of land (located approximately 2.2 mi north-northwest of the deep-well injection 

analysis centerpoint). 

G.2.1.2 Resources Used 

The NRC staff calculated the postulated liquid pathway doses from the so-called child and driller 

conceptual scenario using a personal computer (PC) version of the LADTAP II code—

NRCDose, Version 2.3.20 (ORNL 2012-TN4556)—obtained through the Oak Ridge Radiation 

Safety Information Computational Center (RSICC). 

G.2.1.3 Input Parameters 

Table G-2G-2 provides a list of the major parameters used in calculating dose to certain 

members of the public from liquid effluent releases into the Boulder Zone for retained scenarios 

during normal operation. Appendix G, Section G.3.3, discusses the hydrology groundwater 

confirmatory calculations of the potential for upward migration of injectate from the Boulder 

Zone of the lower Floridan aquifer, which forms the technical basis for the radiological source 

term input parameters. 

G.2.1.4 Comparison of Results 

The results documented by FPL in its ER (FPL 2014-TN4058) and the FSAR (FPL 2015-

TN4502) for doses from accessing groundwater with infiltration from the Boulder Zone are 

compared in Table G-3 with the results calculated by the NRC staff. The largest dose to a 

member of the public calculated for this scenario was from an inadvertent intrusion by a 

subsistence driller. The doses calculated by the NRC staff are uniformly two-thirds of the doses 

calculated by FPL. 

Table G-2. Parameters Used in Calculating Dose for Retained Scenarios 

Parameter NRC Values Comments

Intrusion well source term (Ci/yr) H-3 2.76 × 101

Sr-90 4.99 × 10-7

Cs-134 6.86 × 10-6

Cs-137 6.78 × 10-4

Scenario-specific values based on FSAR 

Section 11.2.3.5 (FPL 2015-TN4502) and 

ER Section 5.4.1.1 (FPL 2014-TN4058). 
Appendix G 

NUREG–2176 G-6 October 2016 

Table G-2G-2. (contd) 

Parameter NRC Values Comments

Discharge flow rate (ft3/s) 1.0 Scenario-specific values based on FSAR 

Section 11.2.3.5 (FPL 2015-TN4502) and 

ER Section 5.4.1.1 (FPL 2014-TN4058). 

Source term multiplier 1 Source term already accounts for two units 

discharging into the deep-well injection 

Site type Fresh water Discharge is to surface freshwater sources 

Reconcentration model Fully Mixed Scenario-specific 

Total 50-mi population 1 Scenario-specific to one individual. 

Dilution factors for aquatic 

food and boating, shoreline 

and swimming, and drinking 

water 

1 LADTAP II code default values (NRC 

1977; Strenge et al. 1986) 

Transit time (hr) 0 (all uses) Scenario-specific values 

Consumption and usage 

factors for adults, teens, 

children, and infants 

Shoreline usage (hr/yr) 

 12 (adult) 

 67 (teen) 

 14 (child) 

 0 (infant) 

Water usage (L/yr) 

 730 (adult) 

 510 (teen) 

 510 (child) 

 330 (infant) 

Fish consumption (kg/yr) 

 21 (adult) 

 16 (teen) 

 6.9 (child) 

 0 (infant) 

LADTAP II code default values (NRC 

1977; Strenge et al. 1986). 

Irrigation rate (L/m2/month) 38.7 Scenario-specific values based on FSAR 

Section 11.2.3.5 (FPL 2015-TN4502) and 

ER Section 5.4.1.1 (FPL 2014-TN4058). 

Fraction of animal feed and 

water not contaminated 

1.0 Scenario-specific values based on FSAR 

Section 11.2.3.5 (FPL 2015-TN4502) and 

ER Section 5.4.1.1 (FPL 2014-TN4058). 

Total production within 50 

miles (kg/yr) 

1000.0 Scenario-specific values based on FSAR 

Section 11.2.3.5 (FPL 2015-TN4502) and 

ER Section 5.4.1.1 (FPL 2014-TN4058). 

Irrigated growing period 

(days) 

60 Scenario-specific values based on FSAR 

Section 11.2.3.5 (FPL 2015-TN4502) and 

ER Section 5.4.1.1 (FPL 2014-TN4058). 

Crop yield (kg/yr) 2.0 Scenario-specific values based on FSAR 

Section 11.2.3.5 (FPL 2015-TN4502) and 

ER Section 5.4.1.1 (FPL 2014-TN4058). 

(a) Only radionuclides included in Regulatory Guide 1.109 are considered (NRC 1977). 

Table G-3. Comparison of Doses to the Public from Intrusion Well Above Boulder Zone 

Type of Dose FPL ER or FSAR(a) NRC Staff Calculation Percent Difference

Total body (mrem/yr) 5.6 (child) 3.63 (adult) 35 

Other organ (mrem/yr) 7.8 (child’s liver) 5.15 (adult’s liver) 34 

(a) 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. 
Appendix G 

October 2016 G-7 NUREG–2176 

G.2.2 Dose Estimates to the Public from Gaseous Effluents 

The NRC staff used the dose-assessment approach specified in Regulatory Guide 1.109 

(NRC 1977-TN90) and the GASPAR II computer code (Strenge et al. 1987-TN83) to estimate 

doses to the maximally exposed individual (MEI) from the gaseous effluent pathway and to the 

population within the 50 mi radius of the Turkey Point site from the gaseous effluent pathway as 

recommended by NUREG-1555 (NRC 2000-TN614) for proposed Units 6 and 7. 

G.2.2.1 Scope 

The NRC staff and FPL independently calculated the maximum gamma air dose, beta air dose, 

total body dose, maximum organ dose, thyroid dose, and skin dose to receptors located at the 

maximum exposure point for each pathway discussed in Section 5.9. The maximum 

atmospheric dispersion factor and the maximum ground deposition occur in the north direction. 

In ER Section 5.4, the MEI is assumed to be located at 2.69 mi N (FPL 2014-TN4058). Dose to 

the MEI was calculated for the following exposure pathways: plume immersion, direct shine 

from deposited radionuclides, inhalation, ingestion of local farm or garden vegetables, and 

ingestion of locally produced beef, chicken, and cow’s milk. 

The NRC staff reviewed the input parameters and values used by FPL for appropriateness, 

including references made to AP1000 pressurized water reactor Design Control Document 

(DCD) Revision 19 (Westinghouse 2011-TN261). When site-specific input parameters were not 

available, default values from Regulatory Guide 1.109 (NRC 1977-TN90) were used. The NRC 

staff verified that FPL used reasonable exposure pathways, DCD input parameters (including 

source term), and recommended RG 1.109 input parameter values, and used those pathways 

and parameters in its independent calculation using GASPARII as summarized below. 

Joint frequency-distribution data of wind speed and wind direction by atmospheric-stability class 

for the Turkey Point site (FPL 2014-TN4058) were used as input to the XOQDOQ code 

(Sagendorf et al. 1982-TN280) to calculate long-term average atmospheric dispersion factor 

(/Q) and atmospheric deposition factor (D/Q) values for routine releases. Based on 2 years of 

meteorological data, the NRC staff’s independent results are similar to those reported by FPL in 

ER Tables 2.7-16 through and 2.7-18 (FPL 2014-TN4058). The NRC staff calculated population 

doses for all types of releases (i.e., noble gases, iodines, particulates, tritium, and carbon-14) 

for the applicable exposure pathways (i.e., plume immersion, direct shine from deposited 

radionuclides, ingestion of meat, vegetables, and goat milk) using the GASPAR II code. 

G.2.2.2 Resources Used 

The NRC staff calculated doses to the public from gaseous effluents using a PC version of the 

XOQDOQ and GASPAR II codes—NRCDose Version 2.3.20 (ORNL 2012-TN4556)—obtained 

through the Oak Ridge RSICC. 

G.2.2.3 Input Parameters 

Table G-4G-4, Table G-5G-5, and Table G-6G-6 list the major parameters used in calculating 

dose to the public from gaseous effluent releases during normal operation. For population dose 

assessment, FPL used the population projection for the year 2090. These population 

projections are presented in ER Table 2.5-1 (FPL 2014-TN4058). However, Section 5.4.1 of the 
Appendix G 

NUREG–2176 G-8 October 2016 

NRC’s Environmental Standard Review Plan (ESRP) (NRC 2000-TN614) recommends 

“projected population for 5 years from the time of the licensing action under consideration.” 

Assuming the combined construction permit and operating license action occurs in year 2018, 

adding 5 years yields year 2023. Because the population is increasing, the year 2030 was 

selected as being more conservative than recommended by the ESRP and has been used 

herein. In addition, staff also applied the population doses in the year 2090, selected by FPL as 

the likely end of operation. 

Table G-4. Gaseous Effluent Source Term 

Parameter Staff Value Comments 

New unit gaseous effluent 

source term (Ci/yr) 

Ar-41 

Kr-85m 

Kr-85 

Kr-87 

Kr-88 

Xe-131m 

Xe-133m 

Xe-133 

Xe-135m 

Xe-135 

Xe-138 

I-131 

I-133 

H-3 

C-14 

Cr-51 

Mn-54 

Co-57 

Co-58 

Co-60 

Fe-59 

Sr-89 

Sr-90 

Zr-95 

Nb-95 

Ru-103 

Ru-106 

Sb-125 

Cs-134 

Cs-136 

Cs-137 

Ba-140 

Ce-141 

3.4 × 101

3.6 × 101

4.1 × 103

1.5 × 101

4.6 × 101

1.8 × 103

8.7 × 101

4.6 × 103

7.0 × 100

3.3 × 102

6.0 × 100

1.2 × 10-1

4.0 × 10-1

3.5 × 102

7.3 × 100

6.1 × 10-4

4.3 × 10-4

8.2 × 10-6

2.3 × 10-2

8.7 × 10-3

7.9 × 10-5

3.0 × 10-3

1.2 × 10-3

1.0 × 10-3

2.54 × 10-3

8.0 × 10-5

7.8 × 10-5

6.1 × 10-5

2.3 × 10-3

8.5 × 10-5

3.6 × 10-3

4.2 × 10-4

4.2 × 10-4

Values from Westinghouse AP1000 DCD 

Table 11.3-3 , Rev 19 

(Westinghouse 2011-TN261). 
Appendix G 

October 2016 G-9 NUREG–2176 

Table G-5. NRC Staff GASPAR Parameters and Selected Inputs 

GASPAR Code Entry, Site Specifics 

Input 

Value Reference 

Source Term: annual average gaseous 

release 

Table G-3 Westinghouse AP1000 DCD Table 11.3-3, Rev 19 

(Westinghouse 2011-TN261) 

Source multiplication factor 1.0 

Distance from site to NE corner of the 

United States 

1,800 mi Estimate 

50 mi milk production(a) 1.70 × 

105

 L/yr 

Milk cows in the four counties within 50 mi represent 

approximately 0.0154 percent of the State total 

(USDA 2012-TN4523). The annual production of 

milk in the State (FDACS 2015-TN4526) was 

multiplied by 0.0154 percent to estimate the 

production within 50 mi as 1.70 × 105

 L/yr. 

50 mi meat production(a) 2.81 × 

105 kg/yr 

Cows and broilers sold in the four counties within 

50 mi represent approximately 0.53 percent and 

0.00012 percent, respectively, of the State totals 

(USDA 2012-TN4523). The annual productions of 

red meat (USDA 2013-TN4525) and broiler 

(FDACS 2015-TN4526) in the State were multiplied 

by these percentages and summed to estimate the 

total meat production within 50 mi as 2.81 × 105

kg/yr. 

50 mi vegetable production(a) 2.52 × 

108

 kg/yr 

The harvested vegetable land area in the four 

counties within 50 mi represents approximately 14.6 

percent of the State total (USDA 2012-TN4523). 

The annual production of vegetables in the State 

(USDA 2014-TN4524) was multiplied by 14.6 

percent to estimate the production within 50 mi as 

2.52 × 108

 kg/yr. 

Fraction of leafy vegetables grown 1 This is the most conservative value. 

Fraction of year milk cows on pasture 1 This is the most conservative value. 

Fraction of maximum individual’s 

vegetable intake from own garden 

0.76 This is the default value in GASPAR II. 

Fraction of milk-cow feed from pasture 1 This is the most conservative value. 

Average absolute humidity for growing 

season 

8 g/m3 This is the default value in GASPAR II. 

Fraction of year goats on the pasture 1 This is the most conservative value. 

Fraction of goat feed from pasture 1 This is the most conservative value. 

Fraction of year beef cattle at pasture 1 This is the most conservative value. 

Fraction of beef cattle feed from pasture 1 This is the most conservative value. 

(a) These values differ from the FPL ER input selections put into GASPAR II. This is discussed in detail in 

Section G.2.2.3. 
Appendix G 

NUREG–2176 G-10 October 2016 

Table G-6. Gaseous Effluent Exposure Pathway Receptor Locations 

Nearest Receptor(a) Direction Distance (mi)

Site boundary SSE 0.35 

Residence N 2.7 

Vegetable garden NW 4.8 

Meat N 2.7 

Biota SSE 0.25 

(a) There are no milk animals within 5 mi of Turkey Point Units 6 and 7. 

The NRC review guidance from the ESRP (NRC 2000-TN614) also states that present-day 

annual milk, meat, and vegetable consumption should be used. To model 2030 dose the NRC 

staff used the agricultural production estimates specified in Table G-5G-5. In its ER (FPL 2014-

TN4058), FPL provided estimates for dose at the projected end of plant life—2090. FPL’s 

estimates are derived from agricultural data from the years 2004 through 2008 (USDA 2004-

TN1390; USDA 2007-TN1391; USDA 2008-TN1393). FPL’s ER also projects food production 

to increase linearly with population growth, so production estimates were multiplied by 1.81. 

The NRC staff was able to replicate FPL’s GASPAR II dose results using the assumptions 

stated in the ER, but the staff applied data based on current agricultural production statistics 

specified in Table G-5G-5. The staff used current production estimates to model dose in the 

year 2030 and multiplied these values by 1.81 to estimate production in 2090. 

Population dose projections by FPL and the NRC staff differ due to differences in population 

and agricultural production assumptions. 

G.2.2.4 Comparison of Doses to the Public from Gaseous Effluent Releases 

Table G-7G-7, Table G-8G-8, and Table G-9G-9 present dose estimates to the MEI for each 

gaseous pathway as calculated by FPL and the NRC staff. Table G-7G-7 shows that the 

maximum doses from each unit occur at the Turkey Point site boundary and that most of the 

dose is derived from the external pathways. The maximum total body dose per unit is 3.9 

mrem/yr to the adult and the teen, while the maximum organ doses per unit are 14 mrem/yr to 

the skin and 7.5 mrem/yr to the thyroid of the child based on conservative assumptions. In ER 

Table 5.4-5 (FPL 2014-TN4058), FPL provided comparable doses from the operation of Units 3 

and 4 showing that the doses are less than 0.01 mrem/yr, based on the bounding values in 5 

years of annual effluent reports, and thus are considered negligible. The doses provided by 

FPL in its ER and those calculated by the NRC staff were identical. 
Appendix G 

October 2016 G-11 NUREG–2176 

Table G-7. Gaseous Pathway Doses for Maximally Exposed Individuals for One Unit 

Pathway 

Dose (mrem/year) per Unit 

Total Body GI-Tract Bone Liver Kidney Thyroid Lung Skin 

Site Boundary 

External 

Plume 2.6 2.6 2.6 2.6 2.6 2.6 2.7 13 

Ground 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.2 

Total 3.6 3.6 3.6 3.6 3.6 3.6 3.8 14 

Inhalation 

Adult 0.28 0.28 0.046 0.29 0.29 2.7 0.37 0 

Teen 0.28 0.29 0.055 0.29 0.30 3.3 0.42 0 

Child 0.25 0.25 0.067 0.26 0.27 3.9 0.36 0 

Infant 0.15 0.14 0.034 0.16 0.16 3.5 0.22 0 

Total 

Adult 3.9 3.9 3.6 3.9 3.9 6.3 4.1 14 

Teen 3.9 3.9 3.7 3.9 3.9 6.9 4.2 14 

Child 3.9 3.8 3.7 3.9 3.9 7.5 4.1 14 

Infant 3.7 3.7 3.6 3.8 3.8 7.1 4.0 14 

Residence 

External 

Plume 0.0067 0.0067 0.0067 0.0067 0.0067 0.0067 0.0074 0.046 

Ground 0.0066 0.0066 0.0066 0.0066 0.0066 0.0066 0.0066 0.0077 

Total 0.013 0.013 0.013 0.013 0.013 0.013 0.014 0.053 

Inhalation 

Adult 0.0012 0.0012 0.00016 0.0012 0.0012 0.0096 0.0015 0 

Teen 0.0012 0.0012 0.00019 0.0012 0.0012 0.012 0.0016 0 

Child 0.0010 0.0010 0.00023 0.0011 0.0011 0.014 0.0014 0 

Infant 0.00059 0.00058 0.00012 0.00063 0.00063 0.012 0.00087 0 

Vegetable 

Adult 0.0064 0.0065 0.033 0.0064 0.0061 0.086 0.0055 0 

Teen 0.0092 0.0093 0.050 0.0096 0.0091 0.11 0.0083 0 

Child 0.020 0.019 0.11 0.021 0.020 0.21 0.018 0 

Meat 

Adult 0.0026 0.0036 0.011 0.0027 0.0026 0.0094 0.0025 0 

Teen 0.0021 0.0027 0.0095 0.0022 0.0021 0.0070 0.0020 0 

Child 0.0038 0.0040 0.018 0.0039 0.0038 0.011 0.0037 0 

Total MEI Dose(a)

Adult 0.023 0.025 0.058 0.023 0.023 0.12 0.023 0.053 

Teen 0.026 0.026 0.073 0.026 0.026 0.14 0.026 0.053 

Child 0.038 0.037 0.15 0.039 0.038 0.24 0.037 0.053 

Infant 0.014 0.014 0.013 0.014 0.014 0.025 0.015 0.053 

FPL Source: ER Table 5.4-7 (FPL 2014-TN4058) 

(a) Total MEI dose per unit is the sum of the residence, vegetable, and meat pathways. 
Appendix G 

NUREG–2176 G-12 October 2016 

Table G-8. FPL and NRC Staff Results Annual Individual Doses to the Maximally 

Exposed Individual from Gaseous Effluents for One Unit 

Pathway Location 

Age 

Group 

FPL and 

NRC Staff 

Total Body 

Dose 

(mrem/yr) 

FPL and NRC 

Staff Max 

Organ Dose 

(mrem/yr) 

FPL and NRC 

Staff Skin Dose 

(mrem/yr) 

FPL and NRC 

Staff Thyroid 

Dose 

(mrem/yr) 

Plume Residence All 0.00671 0.00738 (lung) 0.0455 0.00671 

Ground Residence All 0.00655 0.00655 (lung) 0.00770 0.00655 

Inhalation Residence Adult 0.00115 0.00145 (lung) 0.0/0.00112(b) 0.00956 

 Teen 0.00116 0.00163 (lung) 0.0/0.00113(b) 0.0119 

 Child 0.00103 0.00142 (lung) 0.0/0.000994(b) 0.0137 

 Infant 0.0592 0.000865 (lung) 0.0/0.000572(b) 0.0122 

Vegetable Vegetable Adult 0.00638 0.0329 (bone) 0.0/0.00541(b) 0.0855 

 garden Teen 0.00916 0.0499 (bone) 0.0/0.00811(b) 0.108 

 Child 0.0197 0.114 (bone) 0.0/0.0182(b) 0.206 

Meat Residence Adult 0.00264 0.0114 (bone) 0.0/0.00247(b) 0.00938 

 Teen 0.00211 0.00954 (bone) 0.0/0.00201(b) 0.00702 

 Child 0.00377 0.0179 (bone) 0.0/0.00367(b) 0.0112 

Total MEI 

Dose(a)

 Adult 0.0234 0.0577 (bone) 0.0/0.0622(b) 0.118 

 Teen 0.0257 0.0729 (bone) 0.0645 0.140 

 Child 0.0378 0.145 (bone) 0.0761 0.244 

 Infant 0.0139 0.0134 (bone) 0.0538 0.0255 

FPL Source: ER Table 5.4-7 (FPL 2014-TN4058) 

(a) Total MEI dose is a sum of the residence, vegetable, and meat pathways. 

 There are no milk cows/goats within 5 mi of the Turkey Point site. 

 Assumes the MEI’s food comes from nearest meat and vegetable sources to the Turkey Point site. 

(b) The first value is the FPL-calculated dose and the second value is the NRC staff-calculated dose.

Table G-9. Dose to the Nearest Resident (2.69 mi N) Assuming the Resident Began 

Producing and Consuming Milk, Meat, and Vegetables(a) for One Unit 

Pathway 

Age 

Group 

FPL and NRC 

Staff Total Body 

Dose (mrem/yr) 

FPL and NRC Staff 

Max Organ Dose(b) 

(mrem/yr) 

FPL and NRC 

Staff Skin Dose 

(mrem/yr) 

FPL and NRC 

Staff Thyroid 

Dose (mrem/yr) 

Plume All 0.0067 0.0074 (lung) 0.046 0.0067 

Ground All 0.006 0.006 (lung) 0.0077 0.0066 

Inhalation Adult 0.0012 0.00145 (lung) 0.0 0.0096 

Teen 0.0012 0.0016 (lung) 0.0 0.012 

Child 0.0010 0.0014 (lung) 0.0/0.04(c) 0.014 

 Infant 0.00059 0.00087 (lung) 0.0 0.012 

Vegetable Adult 0.0064 0.033 (bone) 0.0 0.086 

 Teen 0.0092 0.050 (bone) 0.0 0.11 

 Child 0.00 0.114 (bone) 0.0 0.21 
Appendix G 

October 2016 G-13 NUREG–2176 

Table G-9G-9. (contd) 

Pathway 

Age 

Group 

FPL and NRC 

Staff Total Body 

Dose (mrem/yr) 

FPL and NRC Staff 

Max Organ Dose(b) 

(mrem/yr) 

FPL and NRC 

Staff Skin Dose 

(mrem/yr) 

FPL and NRC 

Staff Thyroid 

Dose (mrem/yr) 

Meat Adult 0.0026 0.011 (bone) 0.0 0.0094 

Teen 0.0021 0.0095 (bone) 0.0 0.0070 

Child 0.0038 0.018 (bone) 0.0 0.011 

Milk Adult 0.00438 0.0144 (bone) 0.00306 0.198 

(cow)(d) Teen 0.00680 0.0262 (bone) 0.00527 0.313 

Child 0.0140 0.0634 (bone) 0.0122 0.623 

Infant 0.0274 0.120 (bone) 0.0247 1.51 

Milk Adult 0.00705 0.0176 (bone) 0.00377 0.237 

(goat) (d) Teen 0.00966 0.0314 (bone) 0.00619 0.376 

Child 0.0171 0.0751 (bone) 0.0136 0.746 

Infant 0.0313 0.137 (bone) 0.0269 1.81 

FPL Source: ER Table 5.4-7 (FPL 2014-TN4058) 

(a) Hypothetical dose estimates to worst-case scenario if current parameters were to change. 

(b) Maximum organ dose excludes skin and thyroid because they are subsequently listed. 

(c) The first value is the FPL-calculated dose and the second value is the NRC staff-calculated dose. 

(d) Doses for milk animal pathways are from FPL’s GASPAR II output file (FPL 2010-TN4151). 

G.2.2.5 Comparison of Liquid and Gaseous Doses with 10 CFR Part 50, Appendix I 

Table G-10G-10 presents noble gas, radioiodine, and particulate matter dose estimates at the 

Turkey Point site boundary, as calculated by both FPL and the NRC staff, which are compared 

with dose design objectives from 10 CFR Part 50 (TN249), Appendix I. All gaseous doses were 

less than the 10 CFR Part 50 Appendix I design objectives. 

Table G-10. 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 

Radionuclide Releases/Dose 

(from site boundary) 

FPL and NRC Staff 

Calculations(a)

Appendix I Design 

Objectives 

Gaseous Effluents 

Beta air dose 18 mrad 20 mrad 

Gamma air dose 4.2 mrad 10 mrad 

External whole body dose 3.6 mrem 5 mrem 

Skin dose 14 mrem 15 mrem 

Liquid Effluents 

Total body dose from all pathways 0 rem(b) 3 mrem

Critical organ dose from all pathways 0 rem(b) 10 mrem 

(a) This is the dose for a single unit (i.e., either Unit 6 or Unit 7) from FPL 2014-TN4058. 

(b) There are no exposure pathways for liquid effluents to reach a population under normal operating conditions as 

discussed above in Section G.2.1. Under the calculated theoretical release scenario, Appendix I criteria were 

met and are considered bounding. 

G.2.2.6 Comparison of Population Dose from Liquid and Gaseous Exposures 

Table G-11G-11 presents the population dose estimates to individuals living within the 50 mi 

radius of the Turkey Point site. FPL estimated the population dose based on an extrapolated 
Appendix G 

NUREG–2176 G-14 October 2016 

population estimate for the year 2090. The NRC staff evaluated the population dose based on 

the estimated population for the year 2030 and the year 2090. 

The NRC population dose estimates as presented in Table G-11G-11 also presents person-rem 

dose estimates to individuals living within the 50 mi radius of the Turkey Point site, applying the 

assumptions specified by FPL in its ER (FPL 2014-TN4058) with updated agricultural production 

values as specified in Table G-5G-5. FPL’s agricultural production estimates were based on 

U.S. Department of Agriculture data from 2004 through 2008 (USDA 2004-TN1390; USDA 

2007-TN1391; USDA 2008-TN1393). FPL and staff production estimates were multiplied by 

1.81 to reflect linear production increases to be in line with population increases out to the year 

2090. As discussed in Section G.2.2.3, the NRC estimate of population total body dose 

estimates for vegetable, cow milk, and meat consumption for the year 2090 differs from the FPL 

estimate because the staff estimate is based on a greater amount of agricultural production. 

Table G-11. Calculated Doses to the Population Within 50 mi of the Turkey Point Site 

from Gaseous and Liquid Pathways (Two AP1000 Units) 

Pathway 

Total Body Dose (person-rem/yr) 

FPL Estimate(a) 

for 2090 

NRC Staff 

Estimate for 

2090 

NRC Staff 

Estimate for 

2030 

Gaseous 

Plume 4.28 4.28 2.64 

Ground 2.44 2.44 1.49 

Inhalation 0.872 0.872 0.542 

Vegetable 0.572 2.40 1.32 

Cow Milk 2.78 × 10-4 1.34 × 10-3 5.98 × 10-4

Meat 6.64 × 10-4 2.80 × 10-3 1.54 × 10-3

Liquid Effluents 0 0 0 

(a) Single AP1000 values from FPL 2016-TN4511 multiplied by 2.

Population doses resulting from natural background radiation to individuals living within the 

50 mi radius of Turkey Point site are presented in Table G-12G-12. Table G-12G-12 shows that 

the calculated person-rem/yr exposure from Turkey Point Units 6 and 7 would be much less 

than the estimated person-rem/yr exposure from natural radiation. 

Table G-12. Natural Background – Estimated Whole Body Dose to the Population Within 

50 mi of the Turkey Point Site 

Source 

Annual Individual Dose 

(mrem/yr) 

Annual population Dose 

(person-rem/yr) 

FPL Estimates 300(a) 2.5 × 106(a,c) 

NRC Staff Estimates 311(b) 1.3 × 106 (d)

(a) Taken from FPL ER Table 5.4-10 (FPL 2014-TN4058) based on NCRP 1987-TN2258. 

(b) NCRP 2009-TN420. 

(c) 2090 population estimate from FPL ER Table 2.5-1 (FPL 2014-TN4058). 

(d) Annual Population Dose based on projected residential population of 4,012,989 in the year 2030 from FPL ER 

Table 2.5-1) (FPL 2014-TN4058).
Appendix G 

October 2016 G-15 NUREG–2176 

G.2.3 Cumulative Dose Estimates 

Table G-13G-13 presents the comparison of doses for Turkey Point Units 6 and 7 with the dose 

standards of 40 CFR Part 190 (TN739). The table shows the NRC staff’s assessment of total 

doses to the MEI from FPL liquid and gaseous effluents. The assessment shows that the 

40 CFR Part 190 (TN739) standards would be met. 

Table G-13. Cumulative Site Dose to MEI from FPL Units 6 and 7 Combined with Units 3 

and 4 

Type of Dose 

(mrem/yr) 

FPL Units 

3 and 4(a)

FPL Units 6 

and 7 Liquid 

Dose (child)(b)

FPL Units 6 

and 7 

Gaseous 

Dose (child)(c)

Combined 

Maximum 

Individual Dose 

40 CFR 190 

Dose 

Standards 

Total Body 0.0029 0 7.8 7.8 25 

Thyroid 0.0059 0 15.0 15.0 75 

Other Organ (Bone) 0.0059 0 8.4 8.4 25 

(a) Bounding values from 5 years of effluent reports; theoretical values (thyroid, bone, and skin dose assumed to be 

the same). 

(b) Under normal operating conditions expected to be zero. 

(c) Values from table representing dose from both AP1000 units.

G.2.4 Dose Estimates During Construction 

The NRC staff used the dose-assessment approach specified in Regulatory Guide 1.109 

(NRC 1977-TN90) and the GASPAR II computer code (Strenge et al. 1987-TN83) to estimate 

doses to construction workers. Construction workers would be exposed to several potential 

sources of radiation. Workers would receive dose during the construction of Units 6 and 7 from 

the operation of Units 3 and 4. Unit 6 is planned to be operational 1 year prior to Unit 7. During 

that year, Unit 7 construction workers would be exposed to radiation from Units 3, 4, and 6. 

Gaseous effluent and direct radiation were considered as possible routes of exposure. Liquid 

effluents were not considered a likely route of exposure because drinking water to Units 6 and 7 

workers is to be supplied from the Miami-Dade Water and Sewer Department and liquid 

effluents from Units 3 and 4 are expected to be managed to ensure dose is negligible. 

G.2.4.1 Scope 

The NRC staff and FPL independently calculated the dose to construction workers working on 

Units 6 and 7 from Units 3 and 4, and dose to Unit 7 workers while Units 3, 4, and 6 are in 

operation. The NRC staff and FPL independently calculated the maximum gamma air dose, 

beta air dose, total body dose, maximum organ dose, and thyroid dose and skin dose to 

receptors located at the construction site. Dose to construction workers was calculated for the 

following exposure pathways: plume immersion, direct shine from deposited radionuclides, and 

inhalation. 

The NRC staff reviewed the assumed exposure pathways and input parameters and values 

used by FPL in ER Section 4.5 (FPL 2014-TN4058) for appropriateness, including references 

made to AP1000 DCD Revision 19 (Westinghouse 2011-TN261). Default parameters from 

Regulatory Guide 1.109 (NRC 1977-TN90) were used when site-specific input values were not 
Appendix G 

NUREG–2176 G-16 October 2016 

available. As a result of this independent review, the NRC staff verified that the assumed 

exposure pathways by FPL were reasonable and that the Turkey Point Units 3 and 4 source 

term input parameters and RG1.109 values used by FPL were appropriate. NRC staff used 

these exposure pathways and input parameters in its independent calculation using GASPARII 

as summarized below. 

Joint frequency-distribution data of wind speed and wind direction by atmospheric-stability class 

for the Turkey Point site (FPL 2014-TN4058) were used as input to the XOQDOQ code 

(Sagendorf et al. 1982-TN280) to calculate long-term average χ/Q and D/Q values for routine 

releases. Based on 2 years of meteorological data, the NRC staff’s independent results are 

similar to those reported by FPL in ER Tables 2.7-16 through 2.7-18 (FPL 2014-TN4058). 

G.2.4.2 Resources Used 

The NRC calculated doses to the public from gaseous effluents using a PC version of the 

XOQDOQ and GASPAR II codes—NRC Dose Version 2.3.20 (ORNL 2012-TN4556)—obtained 

through the Oak Ridge RSICC. 

G.2.4.3 Input Parameters 

Table G-4G-4 and Table G-5G-5 list the major parameters used in calculating dose to the 

construction workers from gaseous effluent releases during normal operations at the site. Units 

3 and 4 radiological releases are summarized in the annual reports entitled Turkey Point, Units 

3 and 4, Annual Radioactive Effluent Release Report and Turkey Point, Units 3 and 4, Annual 

Radiological Environmental Operating Report. The limits for all radiological releases are 

specified in the Turkey Point Offsite Dose Calculation Manual (ODCM), and these limits are 

designed to meet Federal standards and requirements. The radiological environmental 

monitoring program (REMP) includes monitoring of the aquatic environment (fish, invertebrates, 

and shoreline sediment), atmospheric environment (airborne radioiodine, gross beta, and 

gamma), and terrestrial environment (vegetation) and direct radiation. The NRC staff reviewed 

these annual reports for calendar years 2002 through 2015 (the references for these reports can 

be found in Section 2.11). The maximum annual release was assumed to be 35 Ci (FPL 2014-

TN4058). Unit 6 effluent releases were estimated for an AP1000 unit in DCD Table 11.3-3 

(Westinghouse 2011-TN261). As discussed in DCD Section 12.4.2.1 (Westinghouse 2011-

TN261), direct radiation exposure from Unit 6 is expected to be shielded such that the direct 

dose rate would be negligible.

The calculated annual dose rate, 0.013 mrem/yr, from a fully loaded independent spent fuel 

storage installation is negligible. To be conservative, the dose rate for the Unit 7 construction 

area from Units 3 and 4 is assumed to be 1 mrem. Construction workers were assumed to be 

at the construction site for 40 hours per week and 52 weeks per year. This constitutes an 

exposure time of 2,080 hours per year. Adjusted for 2,080-hour occupancy time per year, the 

direct radiation dose from Units 3 and 4 is not significant at 0.47 mrem/yr. 

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. This size workforce is 

expected to last less than a year. To be conservative, the maximum size was assumed to last 
Appendix G 

October 2016 G-17 NUREG–2176 

the entire year for calculating the maximum annual workforce dose. Total effective dose 

equivalent (TEDE) was calculated by multiplying the thyroid dose by 0.03 and adding it to the 

total body dose. 

G.2.4.4 Comparison of Doses to Construction Workers 

Table G-14G-14 and Table G-15G-15 present dose estimates to the construction workers for 

each gaseous pathway as calculated by FPL and the NRC staff. Prior to Unit 6 operation, only 

gaseous effluents and direct radiation from Units 3 and 4 would be expected. Table G-16G-16 

presents dose estimates to construction workers from direct exposure and effluent releases. 

The doses provided by FPL in its ER and those calculated by NRC are nearly identical. 

Table G-14. Comparison of FPL and NRC Staff Estimated Dose Rates in Construction 

Area from Unit 6 Gaseous Effluents 

Pathway 

Construction Area Dose Rates (mrem/yr) 

Total Body Thyroid Skin 

FPL Staff FPL Staff FPL Staff 

Plume 12 12.0 12 12.0 60 60.3 

Ground 8.7 8.74 8.7 8.74 10 10.3 

Inhalation 1.3 1.32 13 12.5 1.3 1.28 

Total 22 22.06 33 33.24 72 71.88 

Table G-15. Comparison of FPL and NRC Staff Estimated Gaseous Effluent Doses to 

Unit 7 Construction Workers 

Source 

Annual Dose (mrem) 

Total Body Dose Thyroid Dose Skin Dose TEDE(c)

FPL Staff FPL Staff FPL Staff FPL Staff 

Units 3 and 4(a) 0.0022 0.0022 0.0022 0.0022 0.0031 0.0022 0.0023 0.0022 

Unit 6(b) 5.2 5.24 7.9 7.89 17 17.07 5.5 5.47 

Total 5.2 5.24 7.9 7.89 17 17.07 5.5 5.48 

(a) Based on annual effluent reports from 2002 through 2015 (the references for these reports can be found in 

Section 2.11) and adjusted for 2,080 hr/yr occupancy. 

(b) Adjusted from Table G-14G-14 values to account for 2,080 hr/yr occupancy. 

(c) Calculated by multiplying the thyroid dose by 0.03 and adding it to the total body dose.

Table G-16. Estimated Total Dose to Unit 7 Construction Workers 

Pathway 

Annual Worker Dose (mrem) 

Total Body Dose Thyroid Dose Skin Dose TEDE 

FPL Staff FPL Staff FPL Staff FPL Staff 

Direct Radiation(a) 0.47 0.47 0.47 0.47 0 0 0.47 0.47 

Gaseous Effluents(b) 5.2 5.24 7.9 7.89 17 17.07 5.5 5.5 

Total 5.7 5.71 8.4 8.36 17 17.07 6 5.95 

Annual Workforce Dose (person-rem) 

Total(c) 23 22.55 33 33.02 67 67.43 24 23.50 

(a) Staff calculated values from Section G.2.4. 

(b) Total gaseous effluent calculated in Table G-15G-15 

(c) Calculated by multiplying the total annual worker dose by the maximum expected number of workers 

(i.e., 3,950 people).
Appendix G 

NUREG–2176 G-18 October 2016 

G.2.4.5 Comparison of Construction Workers Dose Estimates to 10 CFR 20 

Table G-17G-17 presents estimated construction worker dose as calculated by both FPL and 

the NRC staff along with the dose criteria for members of the public as stipulated in 

10 CFR 20.1301 (TN283). 

Table G-17. Comparison of Construction Worker Doses with 10 CFR 20.1301 Criteria for 

Members of the Public 

Criteria Worker Limit 

Annual Dose (TEDE mrem) 6 100 

Unrestricted area dose rate (mrem/h) 0.0029 2 

G.2.5 Dose Assessments to Biota Other Than Humans 

To estimate doses to the biota from the liquid and gaseous effluent pathways, the NRC staff 

used the LADTAP II code (Strenge et al. 1986-TN82), the GASPAR II code (Strenge et al. 1987-

TN83), and input parameters supplied by FPL in its ER (FPL 2014-TN4058). 

G.2.5.1 Scope 

The dose assessments discussed herein are for the operation of Turkey Point Units 6 and 7 and 

from the combined operation of Turkey Point Units 3, 4, 6, and 7 (i.e., cumulative site dose). 

Due to the deep-well injection of Units 6 and 7 radioactive liquid effluent, only gaseous effluent 

is considered from these units. When considering the cumulative site dose, the gaseous and 

liquid effluents from Units 3 and 4 are also considered. 

Liquid effluent doses to both terrestrial and aquatic biota were calculated using the LADTAP II 

code. Aquatic biota include fish, algae, and invertebrate species. Terrestrial biota include 

muskrats, raccoons, herons, and ducks. The LADTAP II code calculates an internal dose 

component and an external dose component and sums them for a total body dose. Terrestrial 

biota could also be exposed via the gaseous effluent pathway. These values would be based 

on the MEI calculations using the GASPAR II code. 

G.2.5.2 Resources Used 

To calculate the doses to biota, the NRC staff used PC versions of the LADTAP II and GASPAR 

II computer codes—NRCDose, Version 2.3.20 (ORNL 2012-TN4556). These codes were 

obtained through the Oak Ridge RSICC. 

G.2.5.3 Input Parameters 

Gaseous effluents would contribute to the total body dose of the terrestrial surrogate species 

(i.e., muskrat, raccoon, heron, and duck). The exposure pathways include inhalation of airborne 

radionuclides, external exposure because of immersion in gaseous effluent plumes, and surface 

exposure from deposition of iodine and particulates from gaseous effluents. The dose 

calculated to the MEI from gaseous effluent releases in Section 5.9.3 would also be applicable 

to terrestrial surrogate species with two modifications. One modification defined in ER 

Section 5.4.4 (FPL 2014-TN4058) was increasing the ground-deposition factors by a factor of 
Appendix G 

October 2016 G-19 NUREG–2176 

two because terrestrial animals would be closer to the ground than a member of the public. The 

second modification was to use the biota location delineated in ER Table 5.4-6 (FPL 2014-

TN4058). The gaseous effluent releases used in estimating dose are discussed in ER Section 

3.5.2 (FPL 2014-TN4058). 

In addition to the modifications applied by FPL for modeling biota, the NRC staff elected to 

make adjustments based on the diet of the organism. For example, because the muskrat is an 

herbivore, the meat ingestion pathway was omitted from the dose calculation for the species. In 

addition, the NRC staff chose to consider potential dose to the American crocodile, which is 

found in the canals surrounding the plant and is a Federally threatened species and on the 

Florida threatened species list. Because of the size of the American crocodile, a surrogate 

species model cannot be applied. The American crocodile can be up to approximately 2,006 lb 

(910 kg) and about 15 ft (4.6 m) long (National Geographic 2012-TN2577). Internal dose was 

adjusted to account for the size differential and a modification factor of 4 was applied to the 

ground-deposition factor. In captivity, an 11.5 ft (350 cm) crocodile eats 500 g per day (FAO 

2012-TN2580). It was not possible to find the food consumption rate for a crocodile in the wild, 

but it is likely less for a wild crocodile that has to hunt for food. Since the American crocodile

can be up to 15 ft long, a consumption rate of 3 times larger was assumed (1.5 kg/d) to be 

bounding. Therefore, in the calculations, the meat ingestion pathway was modified to assume 

1,213 lb/yr (550 kg/yr), and assumed to be terrestrial rather than aquatic or riparian. Total body 

dose estimates to the surrogate species and the American crocodile from the gaseous pathway 

for either Unit 6 or Unit 7 are listed in Table G-18G-18. 

Table G-18. NRC Staff Estimate of Non-Human Biota Doses for Proposed Turkey Point 

Units 6 and 7 for One Unit 

Surrogate Species 

of Non-Human Biota 

Doses from Gaseous Effluents 

Internal Dose 

(mrad/yr)(a)

External Dose 

(mrad/yr)(a)

Saltwater Fish 0.0 0.0 

Invertebrate 0.0 0.0 

Algae 0.0 0.0 

Muskrat 13.9 11.8 

Raccoon 15.6 11.8 

American Crocodile 155.7 19.0 

Heron 2.2 11.8 

Duck 15.6 11.8 

(a) Radiological doses to non-human biota are expressed in units 

of absorbed dose (rad). 

The NRC staff has done an estimate of the cumulative dose to biota from the proposed 

operation of Turkey Point Units 3, 4, 6, and 7. For the gaseous effluent doses, the gaseous 

effluent assumptions discussed above were still used. With respect to the American crocodile 

gaseous effluent dose, it was assumed that the crocodile spends 100 percent of the time on the 

shoreline. For the liquid effluent doses from Units 3 and 4, it was assumed that the American 

crocodile spends 50 percent of the time on the shoreline and 50 percent of the time swimming. 

There is no definitive information available on the makeup of the American crocodile’s diet. It is 
Appendix G 

NUREG–2176 G-20 October 2016 

known that they will eat mammals that come to the shoreline (even deer) and that they also eat 

fish, snails, and crustaceans (Mazzotti 2003-TN1499), but not in what proportions. A study of 

American alligators (Fogarty and Albury 1967-TN2581) provided more definitive diet 

information; however, this was for alligators not crocodiles, which have different feeding habits. 

Based on the above information, the assumption was made, when modeling dose from the Units 

3 and 4 liquid effluents, that 12 percent of the crocodile’s diet is fish and the remaining 88 

percent is invertebrates. These adjustments bound the potential effluent exposure to the 

American crocodile because they only consider food sources that were in the water (which 

would thus have a higher concentration of radionuclides) and that the majority of the diet was 

from invertebrates (whose bottom-feeding habits would further concentrate radionuclides). By 

using different assumptions for the American crocodile behavior and diet the with respect to the 

gaseous versus liquid effluents, the resulting cumulative dose estimates provide a conservative 

upper bound. 

G.2.5.4 Comparison of Results 

Operation of Turkey Point Units 6 and 7 

Total body dose estimates to the surrogate species and the American crocodile from the 

gaseous pathway for one unit are shown in Table G-18G-18. 

Cumulative Dose from Turkey Point Units 3, 4, 6, and 7 

The results of the cumulative dose estimates are provided in Table G-19G-19. Based on these 

dose estimates, the NRC staff concludes that the cumulative radiological impact on biota would 

not be significant. 
October 2016 G-21 NUREG

–2176 

Appendix G 

Table G-19. NRC Staff Estimate of the Cumulative Biota Doses from the Proposed Operation of Turkey Point Units 3, 4, 6, 

and 7 Compared to the IAEA/NRCP Guidelines for Biota Protection

Liquid Effluent Dose 

(mrad/d)(a)

Gaseous Effluent Dose 

(mrad/d)(a

Total Dose 

from 

Gaseous 

and Liquid 

Effluent 

(mrad/d)(a)

IAEA/NCRP 

Guidelines for 

Protection of 

Biota 

Populations 

(mrad/d)(a)(b) Biota

Unit 

3

Unit 

4

Units 

6 & 7 Total

Unit 

3

Unit 

4

Units 

6 & 7 Total

Saltwater Fish 0.0337 0.0337 — 0.0674 — — — — 0.0674 1,000 Invertebrate 0.0337 0.0337 — 0.0674 — — — — 0.0674 1,000 Algae 0.00507 0.00507 — 0.0101 — — — — 0.01517 1,000 Muskrat 0.00729 0.00729 — 0.01458 0.0302 0.0239 0.141 0.1951 0.20968 100 

Raccoon 0.00323 0.00323 — 0.00646 0.0343 0.0275 0.150 0.2118 0.21826 100 

American Crocodile 0.0322 0.0322 — 0.0644 0.365 0.319 0.957 1.641 1.7054 100 

Heron 0.00948 0.00948 — 0.01896 0.00412 0.00368 0.0768 0.08460 0.10356 100 

Duck 0.00808 0.00808 — 0.01616 0.0343 0.0275 0.150 0.2118 0.22796 100 

Source: IAEA 1992-TN712; NCRP 1991-TN729 (a) Radiological doses to non-human biota are expressed in units of absorbed dose (rad). (b) Guidelines in NCRP and IAEA reports expressed in Gy/d (1 mGy/d equals 100 mrad/d). 
Appendix G 

NUREG–2176 G-22 October 2016 

G.3 Supporting Hydrologic Documentation 

G.3.1 Review of FPL’s Aquifer Performance Test of the Biscayne Aquifer on the 

Turkey Point Peninsula 

FPL performed and analyzed a relatively large-scale aquifer performance test (APT) to 

determine hydraulic properties of the Biscayne aquifer in the vicinity of the proposed radial 

collector wells (RCWs). The RCWs are proposed as a backup source of cooling water for 

proposed Units 6 and 7 and would be constructed horizontally between 25 and 40 ft beneath the 

bed of Biscayne Bay adjacent to the Turkey Point peninsula. Hydraulic property estimates for 

the Biscayne aquifer were needed to support modeling which was performed to estimate the 

potential effects of pumping the proposed RCWs on the aquifer and on the hydraulically 

connected Biscayne Bay. The design, performance, and analyses of the test are described in 

FPL 2009-TN1263. 

FPL completed the pumped well (PW-1) 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 

constructed a dual-zone monitoring well (MW-1) with two vertically isolated monitoring zones at 

depth intervals of 24 to 60 ft (WM1-DZ-PI) and 65 to 70 ft (WM1-DZ-Deep) below ground 

surface. Four additional observation wells (MW-2, MW-3, MW-4, and MW-5) were completed 

with open intervals in the production zone interval, as follows: the top of the open interval was 

at a depth of 22 ft in each of the four wells, and the bottom of the open interval was at depths 

varying between 41 and 46 ft. The production interval observation wells were at distances 

ranging from 80 to 2,700 ft away from the pumped well. However, FPL did not detect a 

measurable response at the most distant observation well, MW-5. The APT was performed by 

pumping at a rate of 7,100 gpm for 7 days. Measured observation-well data were corrected for 

influence of both ocean tides and earth tides. 

G.3.1.1 Hantush-Jacob Solution 

Response at the observation wells indicated an aquifer separated from a constant-head water 

source by a thin (low storage capacity) semi-confining layer that allows some water to leak 

through the semi-confining layer and recharge the pumped aquifer. This recharge caused water 

level drawdowns (s) measured by FPL in the observation wells to stabilize within 2 to 10 min 

from the start of the APT, depending on radial distance (r) from the production well (Figure G-1). 

The method used to evaluate the test results and determine aquifer parameters is dependent on 

the response of the water levels in the wells to pumping. FPL (2009-TN1263) appropriately 

determined that the drawdown response from APT in the observation wells indicates that the 

Hantush and Jacob (1955-TN4094) “leaky-aquifer” analysis method should be used to estimate 

the hydraulic properties transmissivity (T) and storativity (S) of the Biscayne aquifer. The leakyaquifer analysis method relies on matching the observation-well drawdown data to type curves 

based on the dimensionless leaky-aquifer well function defined by: 

W(u,r/B) = 4Ts/Q 

and plotted vs. 4Tt/r2S, where t is elapsed pumping time. Different leaky aquifer type-curves 

were created by plotting the well function using different values of the dimensionless parameter, 
Appendix G 

October 2016 G-23 NUREG–2176 

r/B (where u is fixed). B is defined as the square root of Tb′/K′, where b′ and K′ are the 

thickness and hydraulic conductivity, respectively, of the semi-confining layer separating the 

aquifer from the overlying water source. Q is defined as the pumping rate. Therefore, the 

shape of the generated type-curves vary depending on thickness and hydraulic conductivity of 

the semi-confining layer 

The NRC staff found that precise analysis of the data was challenging because the period 

between the start of the pumping test and the start of the period of steady drawdown is very 

short, and is possibly affected by early-time variations in pumping rate. This resulted in a 

situation where data from any of the four observation wells could be equally well matched to any 

of several of the r/B-type curves from Hantush and Jacob (1955-TN4094). The shape of the 

drawdown curves is very similar after drawdown in the wells reaches a near steady value. 

However, when data are available from wells at different distances, an additional constraint 

Figure G-1. Composite Graph of Drawdown Data vs. Time for the Turkey Point Aquifer 

Test. Graph shows match to data for well MW4, but listed values are for 

data for well MW-1 (FPL 2009-TN1263).

may be added that allows the drawdown data from wells with different r values to match type 

curves which have proportional r/B values. To illustrate, the observation wells, their distance 
Appendix G 

NUREG–2176 G-24 October 2016 

from the production well, and the steady drawdowns interpreted by the staff for each well are 

listed in Table G-20. The flat portions of the data curves for wells MW1, MW2, MW3, and MW4 

should match different type curves where the ratio of the r/B values are 0.4, 0.52, 0.94, and 1.0, 

respectively, compared to the r/B value calculated for MW4. The staff tested this approach by 

plotting straight lines representing the drawdowns for each well listed in Table G-20 on log-log 

paper at the same scale as the leaky-aquifer-type curves provided by Lohman (1972-TN4095). 

The staff found that using r/B = 1 to match the data for the nearest observation well (MW4) 

provided matches of data for the other wells to type curves having r/B values that are close to 

the expected r/B ratios. Using this approach the staff calculated relatively consistent values of 

K′/b′ with an average value of 0.265 (Table G-20) and estimated a vertical hydraulic conductivity 

of approximately 0.5 ft/d for the confining layer based on a thickness (b’) of 2 ft. 

Table G-20. Well Data Used in and Results from the Test Reinterpretation 

Well Name r (ft) r/r MW4 s (ft) saq (ft) r/B B (ft) K′/b′ (day-1)

MW1 80 0.039 0.75 0.715 0.04 2,000 0.25 

MW2 925 0.45 0.20 0.188 0.52 1,780 0.31 

MW3 1,810 0.88 0.10 0.083 0.94 1,930 0.27 

MW4 2,065 1.0 0.09 0.079 1.0 2,065 0.23 

All Wells Average 1,940 0.265 

The staff’s results differ substantially from those presented in FPL 2009-TN1263 Table 5.2, 

which, based on the listed K′ values, resulted from matching drawdown data from each of the 

observation wells to the r/B = 1 type curve. These matches resulted in low estimates of T and 

very high estimates of K′/b′ for the close-in wells. FPL noted this discrepancy in FPL 2009-

TN1263, which summarizes: 

Calculated transmissivity (T) values ... range from approximately 368,000 

feet2/day to 1,000,000 feet2/day ... The lowest T value was calculated at MW-1 

DZ PI near the pumping well, and the higher T values were calculated at far-field 

wells MW-3 and MW-4 ... The noted increase in hydraulic conductivity with scale 

is likely a natural consequence of the aquifer heterogeneity.... (FPL 2009-

TN1263) 

The hypothesized scale effect instead arises because drawdown data from the wells at different 

distances from the production well should match proportional r/B curve values, as described 

above. 

G.3.1.2 K0(r/B) Distance-Drawdown Solution 

FPL (2009-TN1263) also performed a distance-drawdown an analysis using the AqtesolvTM 

software package (HydroSOLVE, Inc. 2007-TN4091) This approach helps to avoid the problem 

of selecting the appropriate r/B curve, which are discussed in the preceding sub-section. The 

AqtesolvTM solution provides an estimate of T of 8E5 ft2/d and a K′/b′ value of 0.5 day-1. The 

K′/b′ value is about twice the values determined from the composite plot analysis (discussed in 

the sub-section above), prompting a separate distance-drawdown analysis for this review. This 

analysis is based on the theory of de Glee (1930, not referenced), as summarized by Ferris et 
Appendix G 

October 2016 G-25 NUREG–2176 

al. (1962-TN4092), and involves use of a log-log-type curve of the steady-state, leaky-aquifer 

well function, K0(r/B) = 2Ts/Q, plotted vs. r/B. K0(x) is the modified Bessel function of second 

order and zero kind. NRC staff plotted the steady-state drawdowns listed in Table G-20 as x’s, 

and a match was obtained, as shown in Figure G-2. For type curve parameters K0(r/B) and r/B 

= 1, the type-curve match provided values of s = 0.25 ft and r = 1,700 ft (Table G-21). These 

values result in a T of 870,000 ft2/d and a K′/b′ of 0.3/d. Results for this analysis are closer to 

those determined from the time-drawdown analysis than the Aqtesolv distance-drawdown 

solution. To further test that solution, staff interpolated drawdown values from the AqtesolvTM 

graph, listed as saq in Table G-20 and plotted these values as *’s, and shifted to match the type 

curve (Figure G-2). The same value of r = 1,700 ft at r/B = 1 was obtained, but the value of 

s determined from the type-curve match was 0.23 ft, resulting in T = 950,000 ft2/d and K′/b′ = 

0.33/d. Thus, uncertainties of a few hundredths of a foot in estimated steady drawdown can 

result in 10 percent or larger variations in estimated hydraulic properties. 

Figure G-2. Match of Drawdowns at Four Different Observation Wells to the Steady-State 

Distance vs. Drawdown Curve 

Table G-21. Summary of Distance-Drawdown Solutions, Compared to Average of 

Hantush-Jacob Solution 

Solution T (ft2/d) B (ft) K′/b′ (day-1)

AqtesolvTM 8.0E-05 1,230 0.53 

K0(r/B), s 8.7E-05 1,700 0.30 

K0(r/B), saq 9.5E-05 1,700 0.33 

Hantush-Jacob (ave) 1.0E-06 1,940 0.265 

Source: Hantush and Jacob 1955-TN4094 
Appendix G 

NUREG–2176 G-26 October 2016 

G.3.1.3 Summary 

The Biscayne aquifer transmissivity (T) and the vertical hydraulic conductivity (kv) of the 

confining zone above the Biscayne aquifer are important because they control the rates at 

which water will flow into the RCWs from the aquifer and the bay and impact the amount that is 

drawn from each potential source. The NRC staff’s analyses resulted in K′/b′ values that vary 

from 0.23 to 0.53 d-1, and average about 0.3 d-1. If all the vertical resistance to flow is imposed 

by the muck layer, which averages in thickness (b’) of 2 ft, then its vertical hydraulic conductivity 

is about 0.6 ft/d. This value is close to that determined by FPL (2009-TN1263). 

The NRC staff found that values of T between about 800,000 and 1,000,000 ft2/d are obtained 

from time-drawdown analysis of the APT using consistent r/B values, or from distancedrawdown analysis. Differences in the calculated T values arise because of uncertainty in 

steady-state drawdowns of only a few hundredths of a foot. Values from the staff’s analysis are 

comparable with values determined by FPL (2009-TN1263), which states “The mean for the 

calculated T values using drawdown data is approximately 700,000 feet2/day.” Also, “The 

calculated T value using a distance-drawdown method is 800,000 ft2/d.” Thus, in spite of some 

inconsistency in analysis methods, results from the analysis prepared by FPL are similar to 

those determined in the NRC staff review.

G.3.2 Description of Groundwater Modeling Performed to Help Evaluate Effects of 

Excavation Dewatering and Radial Collector Well Operation on the Biscayne 

Aquifer 

This appendix describes three separate modeling efforts performed to estimate the effects of 

radial collector well (RCW) pumping on the Biscayne aquifer, Biscayne Bay, and other portions 

of the hydrologic environment including nearby drainage canals and the cooling canals of the 

industrial wastewater facility (IWF). Two of these modeling efforts were performed before the 

NRC issued the draft environmental impact statement (EIS) in 2015, while the third was 

performed afterwards. The staff also used the two earlier studies to simulate the effects of 

dewatering the Units 6 and 7 plant excavations. To further confirm their understanding of the 

groundwater hydrodynamics and to consider whether certain actions proposed after the two 

earlier modeling studies were completed would alter the earlier conclusions documented in the 

draft EIS (EIS, NRC 2015-TN4444), the review team performed a third modeling analysis 

(Oostrom and Vail 2016-TN4739). 

FPL conducted modeling (FPL 2014-TN4069) using a local-scale groundwater model of the 

Biscayne aquifer including the portion of the aquifer underlying Biscayne Bay near the Turkey 

Point site. The NRC commissioned the U.S. Geological Survey (USGS), to conduct additional 

modeling to help identify the potential effects of RCW pumping (NRC 2014-TN3078). As 

indicated above, after the Draft EIS was issued, the review team itself performed a third 

modeling analysis. 

Each of these hydrologic models provides an estimation of the effects of building and operating 

the proposed plants, however these estimations are imperfect due to a number of uncertainties. 

Uncertainty in groundwater models has been described as arising from 1) uncertainty in model 

parameters, and 2) uncertainty in the definition of the conceptual model framework including the 
Appendix G 

October 2016 G-27 NUREG–2176 

spatial and temporal variation in hydrologic variables (Neuman and Wierenga 2003-TN4090). 

Therefore, examining the results of the three modeling efforts provides a better understanding of 

the possible range of effects of building and operating Units 6 and 7. 

The model used by the USGS model is a submodel of an existing regional-scale (Miami-Dade 

County) coupled surface-water/groundwater model originally created to evaluate then-recent 

hypersalinity events in Biscayne Bay, at the county scale, during 1996−2004 (NRC 2014-

TN3078). The USGS model domain encompassed Biscayne Bay and included freshwater flows 

into Biscayne Bay through the offsite drainage canal system, exchange of groundwater between 

Biscayne aquifer and surface waterbodies including the Biscayne Bay, drainage canals, and the 

cooling canals of the IWF. It also included precipitation input to the bay, precipitation recharge 

to the Biscayne aquifer, evapotranspiration (ET) effects on bay salinity, and the effects of ET on 

recharge to the Biscayne aquifer. The USGS modified their existing model to include the 

cooling canals of the IWF, the proposed excavation dewatering wells, and four proposed RCW 

locations. 

Both of the modeling efforts are approximations of the real physical system, and each has 

shortcomings that result in uncertainty in the modeling results. The FPL model assumes 

constant density fluid and does not represent the differences in density between fresh and 

saline water that can result in “density-driven” groundwater flow. The FPL model was strictly a 

groundwater model with surface-water features represented as boundary conditions. The FPL 

model area is much smaller than the USGS model and does not include as many offsite canals. 

However, the USGS model has much lower spatial resolution with 500 × 500 m cell size 

compared to FPL’s model which is variable and is refined to a 5 ft spacing in the area around 

the radial collector wells (FPL 2014-TN4069). Therefore, the USGS model’s representation of 

smaller-scale features is not as accurate as FPL’s model. 

G.3.2.1 Summary of FPL Modeling 

FPL performed groundwater modeling in support of its application for building and operating 

Units 6 and 7 at the Turkey Point site. The model was created using Visual MODFLOW, a 

commercial implementation of the USGS-developed MODFLOW 2000, and was a steady-state 

three-dimensional model that assumes constant density of the fluid being modeled. Measured 

heads applied in the model for non-seawater waterbodies (e.g., freshwater canals and 

hypersaline cooling canals) were corrected to equivalent seawater heads based on the fluid 

density ratio. The model and results are described in detail in Appendix CC of the FSAR 

(FPL 2014-TN4069). Therefore, only a brief summary and assessment are provided here. 

The objectives of the model were to evaluate groundwater impacts of activities related to the 

building and operation of two new nuclear units by simulating groundwater flow in the Biscayne 

aquifer. The primary issues evaluated with the model were the following: 

 expected rates of groundwater infiltration into excavations for the new reactor buildings 

 origin of water pumped from the RCW, and 

 sea water approach velocities to the bay floor during RCW pumping. 

FPL calibrated the model by matching the groundwater level response to aquifer pumping tests 

performed at two wells (PW-7L and PW-7U) near the proposed plant locations and a well (PW-
Appendix G 

NUREG–2176 G-28 October 2016 

1) near the proposed RCW on the Turkey Point peninsula. An additional aquifer test near the 

proposed plant locations (PW-6U) was simulated by the model as a "validation run." 

FPL used the calibration process to estimate a variety of parameters which were included in 

their model. These included the horizontal hydraulic conductivity (Kh) and anisotropy (Kv/Kh; 

ratio of vertical (Kv) to horizontal (Kh) hydraulic conductivity) values for each of the 10 

hydrogeologic units included in the model and the conductance values applied to headdependent boundary conditions (cooling canals, regional canals, Biscayne Bay and model 

sides). The calibration parameters were varied manually until a model result was obtained that 

showed satisfactory agreement between simulated and observed pumping test drawdowns at 

monitored observation wells, as well as a reasonable match to understood directions and 

amounts of regional groundwater flow. 

Model Results – Radial Collector Wells 

Determining the environmental impacts of operating the proposed RCWs is the ultimate focus of 

the FPL groundwater model. The base case model results indicated that approximately 98 

percent of water extracted from the RCWs originates in Biscayne Bay with most of the 

remainder coming from the cooling canals (industrial wastewater facility). Only 0.2 percent of 

the water produced was predicted by the base case model to come from the freshwater portion 

of the Biscayne aquifer. This is the water entering the model domain from head-dependent 

boundaries along the northwest corner of the model. With an assumed RCW continuous 

withdrawal of 120 Mgd, the predicted volume of water removed from the inland Biscayne aquifer 

was 0.36 Mgd or 250 gpm according to the base case FPL model. The worst-case sensitivity 

analysis conducted by FPL regarding extraction of water from the Biscayne aquifer was based 

on assuming values of vertical conductivity that were 50 percent of the values applied in the 

base case for all the model layers. This “worst-case” analysis predicted that 1.4 percent or 

1,250 gpm would be continuously extracted from the Biscayne aquifer. 

The model results indicated that the velocity of water moving downward from Biscayne Bay into 

the seabed is very low at less than 0.001 cm/s for all sensitivity cases. 

The base case model predicted that 2.0 percent of the water extracted by the RCW would come 

from the industrial wastewater facility. A "worst" case of 3.2 percent of the extracted water 

coming from the industrial wastewater facility was predicted by cutting the vertical conductivity 

of all layers in half. 

Assessment – Radial Collector Wells 

The FPL model provides a reasonable, although uncertain, prediction of the impact of the 

RCWs on the Biscayne Bay and freshwater resources within the Biscayne aquifer. Parameter 

uncertainty in the FPL model prediction for the RCW water source is caused by several factors 

including the following: 

 limited area of the pumping test observations used for calibration compared to the extent of 

the model 

 large number of model parameters compared to the limited amount of calibration data 
Appendix G 

October 2016 G-29 NUREG–2176 

 limited data on the site-specific hydraulic properties of hydrogeologic units except at the 

pump test locations used in calibration 

 lack of data on the hydraulic conductivity of the sediment at the bottom of Biscayne Bay. 

Incomplete knowledge of the hydrogeologic system being modeled, the impacts of assuming 

constant density fluid, the assumption of a steady-state flow system, and problems related to 

discretization of the model into a cellular grid also cause conceptual model and structural 

uncertainty in the FPL model results. 

One of the most significant uncertainties in the model is the hydraulic conductivity assigned to 

the sediment at the bottom of Biscayne Bay. The bay bottom was characterized as either 

"offshore sediment" or exposed "Miami limestone." Water entering the RCW from the bay must 

pass through one of these materials to enter the higher conductivity "upper high flow zone 

(UHFZ)" where the RCW are placed. 

The NRC staff identified the following issues of potential concern with the FPL model setup: 

 Specified heads for the "general head boundary conditions" at the northwest and southwest 

corners of the model were inconsistent. For the calibration simulations, the western 

boundary ends at the northwest corner with a specified head of 0.85 ft, while the northern 

boundary ends at that corner with a value of 0.65 ft. The western boundary ends at the 

southwest corner with a specified head of -0.2 ft, while the southern boundary ends at that 

corner with a value of -0.95 ft. 

 The non-uniform lateral model discretization (row and column widths) exhibits moderately 

larger changes than the commonly accepted practice for finite-difference models. The 

accepted standard practice is for an increase in width between adjacent rows (or columns) 

to be 50 percent (width ratio of 1.5) or less, whereas the FPL model has increases of 100 

percent. 

 While the layer elevations mostly vary in a smooth fashion, there are places where adjacent 

cells of the same layer are offset vertically with no overlap, which differs from the accepted 

standard practice of 50 percent overlap. The lack of overlap is a result of the magnitude in 

elevation change over distance combined with the thinness of the layer. 

However, the NRC staff expects that the impact of these issues is relatively minor in comparison 

to the uncertainty in the model parameter calibration. 

FPL’s base case model predicted that 2.0 percent of the water extracted by the RCW would 

come from the industrial wastewater facility. This prediction is also regarded as uncertain 

because of the parameter calibration uncertainty mentioned above and because of the potential 

effects of variable density fluid on the migration of the hypersaline plume. If the RCWs are 

operated continuously, then it is likely that the hypersaline water flow induced by the RCW from 

the industrial wastewater facility would be captured by the RCW. However, 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. The steady-state nature of the FPL 

model and the assumption of constant density fluids make the model inadequate for modeling 

this potential scenario. 
Appendix G 

NUREG–2176 G-30 October 2016 

The NRC staff performed limited runs of the FPL model to verify performance and check some 

additional sensitivity cases of interest. The main item of interest was the volume of water 

captured from the inland portion of the Biscayne aquifer along the northwestern corner of the 

model. A sensitivity case of 10X the base case offshore bay sediment hydraulic conductivity 

combined with 10X the base case Miami limestone sediment hydraulic conductivity and 10X 

lower general head boundary conductance was performed. The results showed that 

approximately 15 percent more water would be captured through the general head boundary 

along the northwestern corner of the model under these conditions. 

Model Results – Inflow to the Power Block Excavations 

The FPL model predicted that pumping rates of 96 gpm would be necessary for dewatering 

each of the excavations at Units 6 and 7. This is based on installation of essentially 

impermeable grout curtains at the sides of the excavations and grouting of the rock at the base 

of the excavation. 

Assessment– Inflow to the Power Block Excavations 

The model results for the dewatering calculations are also affected by model uncertainties 

discussed above. However, the NRC staff expects the impact of model uncertainty on these 

calculations to be less significant because of the smaller scale of the focus area. The 

permeability of the grouted base rock and side walls for the excavation are the primary 

parameters controlling inflow, and are easier to estimate than the large-scale hydrogeologic 

parameters that control the source of water captured by the RCW. Engineering controls are 

also feasible for mitigation of any adverse conditions that are encountered during the excavation 

activities. 

Conclusions 

The environmental impact of operating the proposed RCW system is the most important issue 

addressed by the groundwater model. The FPL model results indicate that continuous 

operation of the RCW results in extraction of a relatively small volume of water from the inland 

portion of the Biscayne aquifer and that the velocity of water moving downward from Biscayne 

Bay into the seabed is very low at less than 0.001 cm/s. The NRC staff’s largest concern with 

the model is caused by uncertainty in the model parameters, especially in light of the limited 

area of calibration data and the large number of parameters that must be estimated. This may 

have a significant impact on the predicted volumes of water that would be extracted from the 

inland potion of Biscayne aquifer along the northwest corner of the model area and the amount 

captured from the industrial wastewater system. The NRC staff regards model estimates of 

inflow to the proposed excavations as more accurate than estimates of RCW captured water 

sources because of the knowledge of hydraulic parameters in that immediate area of the 

planned excavations. 

G.3.2.2 Summary of USGS Modeling 

The NRC commissioned the USGS to perform a numerical modeling study of the effects of the 

operation of a proposed RCW system at the Turkey Point site on surface and groundwater 
Appendix G 

October 2016 G-31 NUREG–2176 

salinity. The resulting report (NRC 2014-TN3078) represents part of the review team’s technical 

basis in its impact determination in this environmental impact statement (EIS). 

Purpose of the Study 

FPL proposes installing the RCWs at the Turkey Point site for use as a backup source of 

cooling water for proposed Units 6 and 7 in case of the loss of the normal water supply 

(reclaimed water from Miami-Dade County waste water treatment system). Neither the 

reclaimed water nor the water from the RCW system provides a safety-related function. The 

design of the RCW system and the flow from it are described in Chapter 3 of this EIS. Because 

of the potential during operation of the RCWs to alter the salinity of two sensitive and significant 

local water resources—the Biscayne Bay and the Biscayne aquifer—the review team 

commissioned the USGS independent modeling study. Salinity in Biscayne Bay is a concern 

because of the ongoing actions under the Comprehensive Everglades Restoration Plan (CERP) 

to restore freshwater flows to Biscayne Bay National Park (USACE/SFWMD 2011-TN1038). 

The Biscayne aquifer has been designated a sole-source aquifer by the U.S. Environmental 

Protection Agency and is critical to the region’s freshwater supply. 

Unique from other numerical modeling studies included in the review team’s assessment, the 

USGS model explicitly considered density effects on the flow within and between the 

groundwater and the surface-water systems. The spatial and temporal patterns of salinity are 

primarily controlled by the flow of water. Therefore, an understanding of various processes 

resulting in flow is required for the review team to understand the plausible impacts of the RCW 

operation. 

The commissioned study discussed herein relied on a numerical model developed and applied 

previously to this domain by USGS (NRC 2014-TN3078). This numerical model was used to 

simulate specific conditions that are understood to exist at the Turkey Point site and under 

boundary conditions consistent with the operation of the RCW system. The site conceptual 

model and the numerical model are discussed below. 

Conceptual Model 

The conceptual model of the region is consistent with a coastal freshwater-saltwater interface. 

Freshwater results from precipitation that infiltrates into the groundwater system and flows down 

gradient toward the ocean. As it approaches the seawater, the less dense freshwater tends to 

flow over the more dense seawater forming a saltwater wedge. The location of this saltwater 

wedge can move in response to increases and decreases in groundwater recharge from 

precipitation and also in response to groundwater pumping. Excess precipitation that does not 

enter the groundwater system through recharge can enter the ocean via sheet flow and channel 

flow. Several canals discharge freshwater during the wet season (summer to fall). However, 

along a portion of the area to the south of Turkey Point, the cooling canals prevent sheet flow 

from discharging to Card Sound and Biscayne Bay directly east of the cooling canals. The 

warm, hypersaline water in the unlined cooling canals also creates a plume of dense 

hypersaline groundwater under the cooling canals. Therefore, the site conceptual model 

reflects these conditions unique to the Turkey Point site. Further discussion of the hydrologic 

environment including the cooling canals can be found in Section 2.3 of this EIS. 
Appendix G 

NUREG–2176 G-32 October 2016 

The analysis considered the surface water (notably Biscayne Bay) to be vertically mixed 

(NRC 2014-TN3078). The review team considered this assumption and determined that 

because of the shallow depths of Biscayne Bay, particularly near Turkey Point, this 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 (NRC 2014-TN3078). The 

analysis also assumed that the tidal boundary had a typical seawater salinity of 35 practical 

salinity units (psu). 

Given that one of the motivations for this study was to consider density-driven flow within the 

groundwater system, the conceptual model explicitly allows for multiple layers and for both 

vertical variations in hydrogeologic flow-related parameters and for salinity variations. The 

boundary conditions for the groundwater portion of the model are the freshwater piezometric 

heads at the boundary of the domain and the areal recharge rates over the extent of the land 

surface of the domain, which vary seasonally. 

The conceptual model explicitly considers the surface-water/groundwater interface with 

exchange allowed in both directions depending on pressure gradients from upgradient 

freshwater inflows to groundwater, water-surface elevation differences along canals, well 

pumping, seepage of cooling canal waters to groundwater, and tidal head variation (NRC 2014-

TN3078). For instance, marine waters of Biscayne Bay water can percolate into the bed, enter 

the groundwater system, and enter the RCWs, and freshwater can enter the Bay through 

groundwater discharge. 

Evaporation of seawater results in increases of salinity. Poorly mixed shallow marine areas 

without sufficient freshwater inflow are likely to become hypersaline as a result of evaporation. 

The study included the effect of evaporation on salinity (NRC 2014-TN3078). 

As described in Section 2.3 of this EIS, the groundwater underneath Biscayne Bay has salinity 

levels similar to the marine surface waters. Below the freshwater layer landward of Biscayne 

Bay, there is a wedge of saline water that intrudes inland. The freshwater underlying the land 

has a somewhat higher piezometric head than the groundwater underlying Biscayne Bay; 

hence, there is a flux of freshwater eastward toward Biscayne Bay. Seasonal rainfall patterns 

also influence the flux of freshwater with increased runoff and surface-water discharge to 

Biscayne Bay and increased infiltration into the surface layers of the groundwater. Additional 

components of the surface-water/groundwater system that exist at present include water-supply 

pumping around population centers, drainage ditches that intercept shallow groundwater, and 

the cooling canals at Turkey Point. Inland water-supply pumping withdraws freshwater from the 

groundwater, thereby reducing the piezometric head that drives the salinity wedge seaward. 

Drainage ditches intercept shallow groundwater and transport it for discharge to Biscayne Bay. 

These processes are included in the conceptual model. 

Numerical Model 

The USGS model is based on a previously developed regional-scale model (Lohmann et 

al. 2012-TN1429) that integrated surface-water and groundwater processes to study flows into 

and out of Biscayne Bay (Figure G-3). The original model’s intent was to examine regionalscale processes that influence Biscayne Bay salinity. 
Appendix G 

October 2016 G-33 NUREG–2176 

Figure G-3. USGS Model Domain and Grid Used for Salinity Analysis of RCW Pumping 

at Turkey Point. An inset of the grid in the vicinity of Turkey Point is 

included. (Taken from NRC 2014-TN3078, Figure 2)

Both model studies (Lohmann et al. 2012-TN1429; NRC 2014-TN3078) covered the period 

January 1996 through December 2004, a duration of 9 years. This simulation period was 

chosen because the Lohmann et al. model was calibrated for this period. The canal inflows, 

precipitation, and meteorology applied in the NRC-commissioned study are the same as those 

used by Lohmann et al. (2012-TN1429). For the regional-scale analysis, the model used a 500 

m by 500 m grid spacing to define the physical features of the model domain. The model uses 

20 vertical layers that represent the whole aquifer, with one of those layers representing 

Biscayne Bay. The surface layer is 4 m thick, the second layer is 1.5 m thick, and the remaining 

layers are 2.75 m thick. The NRC commissioned study (NRC 2014-TN3078) updated the 

previously developed model to include (1) the cooling canals and (2) the representation of two 

temporary dewatering wells during the construction period at the proposed site for the Unit 6 

and 7 reactors for the scenarios. Pumping from the dewatering wells was only included in the 

base case. The cooling canals were represented in the model by 70 cells for which the watersurface elevations were specified and the salinity was set to a constant 65 psu. The two 

dewatering wells were represented in the model in one cell and were set to pump for a 6-month 

period (June 2001 through December 2001). The inclusion of these two updates into the 

Lohmann et al. (2012-TN1429) model constituted the base case of the analysis. 

For the evaluation of RCW pumping, the entire RCW system was represented in the model by 

four grid cells. When active, the total RCW pumping rate was set to 490,536 cubic meters per 
Appendix G 

NUREG–2176 G-34 October 2016 

day (m3/d) (90,000 gpm). Model inputs that were varied in the commissioned study were (1) the 

RCW withdrawal layer (layer 3 or layer 5) in the scenarios, (2) the distribution of RCW well 

intakes in model, (3) the RCW pumping period, and (4) vertical hydraulic conductivities and 

leakage of the subsurface layers (NRC 2014-TN3078). The commissioned report did not 

present results for all combinations of the varied inputs because the modeling results of some 

scenarios were not significantly different from the ones that were included in the report. The 

analyses ultimately included were for RCW groundwater extraction from layer 3 and for the well 

intakes distributed along the RCW intake pipes (NRC 2014-TN3078). 

In regard to the RCW pumping periods, the commissioned study examined (1) continuous 

pumping (the most conservative pumping option), (2) 90-day pumping during the annual dry 

period, and (3) alternating periods of 30 days pumping and 90 days no pumping (NRC 2014-

TN3078). Each of these pumping periods is longer than the 60 days mentioned in Section 

5.2.1.2 of this EIS as the limit currently proposed by FDEP as the permit condition for operating 

the wells. Consequently, each pumping period analyzed by the commissioned study 

(NRC 2014-TN3078) is more conservative than the FDEP conditions would actually permit. 

Ultimately, the review team included only the continuous-pumping and 90-day-pumping 

scenarios, because they were the most conservative of the three pumping scenarios examined 

by USGS. Continuous pumping does not allow any time for system recovery as would occur 

with the alternating pumping and no-pumping scenarios. 

In regard to vertical conductivities, the NRC (2014-TN3078) study examined (1) the values used 

in the previous study (Lohmann et al. 2012-TN1429), which were used in the base case, (2) 

decreased vertical conductivity in the subsurface layers plus decreased leakage between 

surface-water and groundwater layers, and (3) decreased vertical conductivity in all subsurface 

layers except layers 3, 4, and 5 (RCW extraction layers). The review team only included the 

first of these realizations because it was based on the calibrated model of the Biscayne Bay and 

aquifer system. Also, the review team expects that any reduction of vertical conductivity would 

decrease the effect of RCW pumping on Biscayne Bay salinity. 

The commissioned study specified that initial conditions used to start the scenario analyses be 

the same as the final state of the base case in order to provide each of the scenarios with a 

common starting point. The specified initial conditions include heads, water levels, and salinity. 

Results 

The alterations on the salinity in the groundwater and in Biscayne Bay predicted by the USGS 

model are discussed in the following sections. 

RCW Pumping Effects on Groundwater Salinity 

At the end of the base case run, the predicted potentiometric surface showed a slight 

depression along the coast near Turkey Point that is the result of pumping the RCWs in the area 

that is included in the model (Figure G-4; NRC 2014-TN3078). Layers 2 and 3 were selected 

for plotting because they are just below Biscayne Bay and any canals, so that any groundwater 

effects from RCW pumping on Biscayne Bay will be transmitted through these two layers. For 

the continuous-RCW-pumping scenario, the USGS model predicted a cone of depression that 

surrounded the RCWs and extended laterally for several hundred meters (NRC 2014-TN3078). 
Appendix G 

October 2016 G-35 NUREG–2176 

The model predicted that the cone of depression for the continuous-pumping case would be 

present at the end of the simulation because there was no opportunity for recovery. For the 

90-day-pumping case, the model predicted that the cone of depression would not be evident at 

the end of the simulation because the system would have fully recovered after 275 days of no 

pumping. 

The effect on regional groundwater potentiometric head to the northwest and west of the RCWs 

and Turkey Point site was predicted to be minimal. Sensitivity tests with vertical conductivity 

predicted there could be slightly larger changes in potentiometric head, which were attributed to 

a slightly landward movement of higher density (higher salinity) groundwater (NRC 2014-

TN3078). The review team notes that these ranges of potentiometric head were within the 

range of uncertainty and predictive error of the model. 

The salinity results at the end of the simulations for layers 2 and 3 within the groundwater 

system are shown in Figure G-5 (NRC 2014-TN3078). The blue regions landward of the coast 

represent freshwater. The green regions are where the marine water was predicted to infiltrate 

into the first two groundwater layers. The red zones are the hypersaline (high density) plume 

originating from the cooling canals. 

For the area north of the hypersaline plume Figure G-5 the model predicts that in the 

continuous-pumping case, salinity would decrease landward of Turkey Point in comparison with 

the base case, while in the 90-day-pumping case, there would be a smaller decrease in salinity. 

For the continuous-pumping case the model predicts an increase in salinity in layer 3 

(Figure G-5) directly under Turkey Point (essentially in a single grid cell), and a decrease in 

salinity north of the hypersaline plume. For the 90-day-pumping scenario, a decrease in salinity 

north of the hypersaline plume was also predicted, though the decrease was smaller than for 

continuous pumping. The smaller change results from the 9 months of recovery per year that is 

modeled in the 90-day-pumping scenario. 

The change in groundwater salinity predicted by the model was assessed by finding the 

greatest differences for each grid cell between a scenario and the base case (NRC 2014-

TN3078). The results at the end of the simulations of the greatest salinity differences for the 

continuous-pumping and 90-day-pumping scenarios are shown in Figure G-6. Note that the 

maximum predicted salinity differences for each model grid cell would not necessarily occur in 

the same layer, but this analysis provided an overall trend of salinity change. The predicted 

penetration into the groundwater system of the hypersaline plume from the cooling canals 

produced the ring of high positive change that surrounds the Turkey Point facilities. The model 

predicted greater freshening of the groundwater under the continuous-pumping scenario than 

under the 90-day-pumping scenario. The freshening is shown by a negative change in salinity 

centered northwest of Turkey Point. The predicted change, with the inclusion of RCW pumping, 

likely results from the withdrawal of a portion of the hypersaline plume from the groundwater 

system. Because the 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. 

Examination of the total volumetric exchange between surface waters and groundwater showed 

that for the base case the model predicted a tendency toward discharge from the aquifer to 

Biscayne Bay (Figure G-7), though the base case rates were small (<500 m3/d). Landward of 
NUREG

–2176 G-36 October 2016 

Appendix G 

Figure G-4. Potentiometric Surfaces for Base Case and Continuous-Pumping and 90 d/yr Pumping Scenarios at the End of 

the 9-Year Simulations. Units are meters of elevation (NAVD88). (Taken from NRC 2014-TN3078, Figure 5, Figure 6A, and Figure 7) 
October 2016 G-37 NUREG

–2176 

Appendix G Figure G-5. Salinities for Base Case, Continuous-Pumping, and 90 d/yr Pumping Scenarios at the End of the 9-Year Simulations. Units were practical salinity units. (Taken from NRC 2014-TN3078, Figure 17, Figure 18A, and Figure 19)
NUREG

–2176 G-38 October 2016 

Appendix G 

Figure G-6. Differences between Maximum Salinities between the Continuous RCW-Pumping Case and the Base Case and 

between the 90 d/yr Pumping Case and the Base Case (Taken from NRC 2014-TN3078, Figure 16b) 
October 2016 G-39 NUREG

–2176 

Appendix G 

Figure G-7. Total Leakage (m3/d) at the End of the Simulation for the Base Case, Continuous RCW-Pumping, and 90 d/yr 

Pumping. (Taken from NRC 2014-TN3078, Figure 26 and Figure 27) 
Appendix G 

NUREG–2176 G-40 October 2016 

Biscayne Bay, the total volumetric exchange predicted for the base case tended toward 

recharge, as expected with the occurrence of precipitation and infiltration into the land. For the 

continuous-pumping case, the model predicted a tendency for high recharge (inflow) from 

Biscayne Bay into the aquifer, as expected with RCW pumping, with rates locally around 5,000 

m3/d. For the 90-day-pumping scenario, the results tended toward recharge but without the 

higher localized recharge rate predicted with continuous pumping. 

RCW Pumping Effects on Biscayne Bay Salinity 

To investigate the salinity response in Biscayne Bay to RCW pumping, the review team 

examined model output results at locations near Turkey Point (NRC 2014-TN3078) 

corresponding to the measurement stations reported in this EIS Table 2-9, as well as three 

additional stations further north and close to Turkey Point (Figure G-8). Only the 

continuous-pumping scenario was included in the examination of Biscayne Bay salinity because 

the USGS model predicted the largest effects on groundwater for this scenario and it provided 

an upper bound of salinity variation of all potential RCW-pumping scenarios. 

Time series of salinity results and salinity differences for the seven stations are shown in 

Figure G-9. Generally, the model predicted that salinity would exhibit seasonal variation due to 

freshwater inflows from drainage canals into Biscayne Bay, while increases in salinity would 

result from evaporative losses. For both the base and continuous-pumping cases, the largest 

seasonal variations were predicted at the northernmost locations (station A and B), with the 

smallest seasonal variations around Turkey Point (station C). Model results for locations closest 

to the measurement stations exhibited an intermediate range of seasonal variation. The 

north-south differences in seasonal salinity variation was likely caused by the northern portion of 

the region receiving relatively larger inputs of freshwater inflows from canals during the wet 

season. 

The review staff computed the summary statistics (Table G-22) for salinity time series for the 

stations shown in Figure G-9. As suggested by the variation seen in the time-series plots, the 

standard deviations were largest for the northernmost stations examined. The minimum and 

maximum salinities also varied by location, with the largest maximum and smallest minimum 

predicted for the northernmost stations. For the tidal boundary, the primary source of water for 

Biscayne Bay, the model had the salinity set to 35 psu (Lohmann et al. 2012-TN1429). In 

comparison with the measured stations (EIS Table 2-9), the maximum salinities from the NRC 

commissioned study were smaller than observed at the measured stations (NRC 2014-

TN3078). However, the periods from which the data were available were not the same between 

the measured data (2005 onward) and model results (2004 and earlier), so that direct 

comparisons are not possible. 

The review team finds that the salinity differences between the continuous-pumping and base 

cases varied between +2 psu to -2 psu, but with most variations between +1 psu and -1 psu 

(Figure G-9). The model predicted an anomalous increase within the first year (1996) because 

of the onset of pumping, but this was wiped out by the start of 1997. Variations beyond +2 psu 

and -2 psu were predicted to be of very short duration. 
Appendix G 

October 2016 G-41 NUREG–2176 

Figure G-8. Locations Where Salinity Time Series from USGS Model Were Examined 
Appendix G 

NUREG–2176 G-42 October 2016 

Figure G-9. Salinity and Salinity Differences (psu) from USGS Model at Locations 

Indicated in Table G-22. The dashed lines indicate the times for which 

spatial variations were examined (see Figure G-10 and Figure G-11).
Appendix G 

October 2016 G-43 NUREG–2176 

Table G-22. Summary of Predicted Salinity for the Period January 1, 1997 through 

December 31, 2004 near the Turkey Point Site at Stations Shown in Figure G-9 

Station 

Number of 

Time 

Intervals 

Mean 

(psu) 

Standard 

Deviation 

(psu) 

Minimum 

(psu) 

Median 

(psu) 

Maximum 

(psu) 

Base Case 

A 2,922 29.62 5.08 10.48 30.18 37.35 

B 2,922 31.24 4.21 13.81 31.84 37.24 

BBCW10 2,922 31.66 3.62 14.36 32.02 37.05 

BISC18 2,922 33.56 2.34 20.92 33.98 36.91 

BISCA6 2,922 34.41 1.48 24.75 34.62 36.97 

C 2,922 34.67 1.14 28.26 34.81 36.90 

BISC12 2,922 34.76 0.94 29.27 34.86 36.65 

Continuous-Pumping Case 

A 2,922 29.58 5.09 11.19 30.13 37.32 

B 2,922 31.22 4.20 14.02 31.81 37.24 

BBCW10 2,922 31.65 3.60 14.68 31.95 37.06 

BISC18 2,922 33.55 2.32 21.03 33.97 36.93 

BISCA6 2,922 34.41 1.46 25.20 34.62 36.99 

C 2,922 34.67 1.13 28.26 34.81 36.92 

BISC12 2,922 34.76 0.94 29.24 34.86 36.70 

psu = practical salinity units 

Source: NRC 2014-TN3078 

To investigate the spatial distribution of salinity and salinity differences, the review team 

examined salinity at two different characteristic periods. One was selected that had positive 

salinity differences as shown in Figure G-9, and another was selected that had negative salinity 

differences as shown in Figure G-9. During both of these periods, the salinities along the 

nearshore north of Turkey Point were lower than those typically found for marine waters, being 

on the order of 20 psu compared to 35 psu specified at the model’s tidal boundary with the 

Atlantic Ocean (Figure G-10 and Figure G-11). Examination of the salinity differences from the 

October 3, 2003 results showed a small increase in salinity in southern Biscayne Bay 

(Figure G-10), with only a small patch of nearshore water predicted to have a salinity increase 

on the order of +2 psu. In contrast, the results for the October 25, 2003 period showed a small 

decrease in salinity (Figure G-11), with a small patch of nearshore water predicted to have a 

salinity decrease on the order of -1.5 psu. 
Appendix G 

NUREG–2176 G-44 October 2016 

Figure G-10. Surface-Water Salinities at the Time with the Largest Difference North of 

Turkey Point between the Base Case and Continuous-Pumping Scenario on 

October 3, 2003. Units are psu (practical salinity units).
Appendix G 

October 2016 G-45 NUREG–2176 

Figure G-11. Surface-Water Salinities at the Time with Largest Decreases North of 

Turkey Point between the Base Case and Continuous-Pumping Scenario 

on October 25, 2004. Units are psu (practical salinity units). 
Appendix G 

NUREG–2176 G-46 October 2016 

G.3.2.3 Summary of Review Team Focused Modeling 

To further confirm the review team’s understanding of the groundwater hydrodynamics and to 

consider whether certain actions proposed after the two earlier modeling studies were 

completed would alter the earlier conclusions documented by the review team in their draft 

environmental impact statement (EIS, NRC 2015-TN4444), the review team performed a third 

modeling analysis. This third modeling analysis is discussed in this section and presented in 

detail by Oostrom and Vail (2016-TN4739). 

The review team used the water-salt-energy mode of the STOMP (Subsurface Transport Over 

Multiple Phases) simulator to perform the simulations (White and Oostrom 2006-TN4808). The 

applicable governing equations are the component mass-conservation equation for water and 

salt and the energy conservation equation. The simulator allows for the consideration of 

density-driven flow and temperature effects caused by the seepage of warm hypersaline water 

from the unlined cooling-canal system (CCS) into the saline Biscayne aquifer. The review team 

based the model configuration on an earlier cross-sectional model published by Hughes et 

al. (2010-TN1545). The two-dimensional (2D) model is 46 km long and extends 35 m vertically. 

To facilitate simulation of the effects of radial collector well operation, the review team also 

developed a three-dimensional (3D) model, which represents a 2 km wide extension of the 2D 

model. 

The review team performed a steady-state simulation with a Biscayne Bay hydraulic head of 0.2 

m and a west boundary head of 1.05 m to obtain the initial conditions for both the 2D and 3D 

simulations. The long-term (10,000-year) simulations yielded a typical salt intrusion front, which 

extends below the CCS. For the subsequent hypersaline water infiltration simulations, the 

review team used the same boundary conditions as those proposed by Hughes et al. (2010-

TN1545) for hydraulic heads and temperature. 

The 2D simulations predict several main observations, as follows: 

 CCS operation with warm 70 g/L hypersaline water leads to the development of a large 

subsurface plume. 

 Reducing the CCS salt concentration leads to a stable displacement of hypersaline water 

from the CCS subsurface. 

 Increasing the hydraulic head in the L-31E Canal limits westward migration of the 

hypersaline plume. 

 Increasing the west boundary hydraulic head (indicative of increased recharge) results in a 

compression of the hypersaline plume at the west side of the CCS. 

 Decreasing the west boundary hydraulic head (indicative of reduced recharge) has the 

opposite effect, and leads to additional migration of the hypersaline plume in the western 

direction. 

 During sea-level rise, infiltrating saltwater from the Biscayne Bay pushes the hypersaline 

water toward the CCS subsurface. Over time, the interface between hypersaline water 

originating from the CCS and seawater becomes more sharply defined and more vertical. 
Appendix G 

October 2016 G-47 NUREG–2176 

The 3D simulations predict several main observations, as follows: 

 Periodic extraction using the RCW system leads to fluctuating salt concentrations in the 

radial collector wells. 

 During pumping, the salt concentrations initially increase because of advective transport of 

hypersaline water through the Upper Higher Flow Zone; the salt concentrations then 

decrease because of the influence of extracted Biscayne Bay saltwater. 

 During intervals between periods of pump operation, salt concentrations slightly increase 

due to diffusion of hypersaline water eastward; the radial collector well salt concentrations 

do not change significantly from year to year. 

 RCW pumping increases the concentration gradients between the hypersaline plume below 

the CCS and Biscayne Bay saltwater in the upper parts of the aquifer and removes some of 

the hypersaline water from the Fort Thompson formation; the extracted volumes originate 

largely from Biscayne Bay (>95 percent); pumping rate reduction (up to 10 percent of 

maximum) and duration reduction (50 percent) do not considerably influence collector well 

salt concentrations. This result indicates that the proposed RCW operation with a 86,400 

gal/min withdrawal rate over 60 days per year would completely dominate flow and transport 

adjacent to the RCWs, because reasonable variations in the rate and duration do not 

considerably influence collector well salt concentrations. 

 Boundary condition modifications (i.e., L-31E Canal head and west boundary head 

increases) applied to the west of the CCS do not influence RCW extraction behavior. 

 Seawater rise in Biscayne Bay leads to decreasing RCW saltwater concentration over time 

because the increasing Biscayne Bay hydraulic head displaces hypersaline water toward 

the CCS subsurface. 

 Operation of remediation wells in the Lower Higher Flow Zone below the Interceptor Ditch 

does not influence extracted RCW salt concentrations. 

 Salt concentrations in the remediation wells are predicted to increase to CCS salt levels 

within a year of remediation pumping. 

 Freshening of the CCS surface water results in reduced RCW salt concentrations with 

relatively minor (<1 g/L) fluctuations. 

Without doubt, some perturbations of the baseline boundary conditions result in significantly 

altered environmental baselines. However, while the operation of the RCWs would change the 

incremental impacts of the RCWs on the salinity distribution of the Biscayne aquifer, the 

alterations would remain at levels that may only be detectable within the immediate vicinity of 

the RCWs. While the numerical model analysis predicts a slight westward movement of some 

hypersaline water as a result of the operation of the RCWs, there is no plausible upward 

impelling force above the RCWs that would result in hypersalinity moving into the Bay as a 

result of RCW operation. As the review team acknowledged in the EIS Section 2.3.1, when the 

water-surface elevation in the cooling canals exceeds that in the Bay, the water will follow the 

gradient of the impelling force into the Bay and may contribute to salinity in the Bay. Both of the 

above effects also apply for other dissolved constituents in the hypersaline plume, including 

nutrients and tritium. 
Appendix G 

NUREG–2176 G-48 October 2016 

Although the primary focus of the modeling reported here is on the incremental effects of the 

RCWs on the Biscayne Bay, the review team also acknowledges the cumulative impacts of 

other changes, including those from sea-level rise and possible future regulatory actions. While 

the scenarios considered in this analysis were designed to be bounding for sea-level rise and 

possible regulatory actions, they also provide a basis for assessing the cumulative impacts. 

NRC lacks authority to impose additional mitigation measures regarding surface water 

conditions subject to State regulation. However, additional mitigation actions proposed by state 

and county agencies would presumably improve the baseline environment. Because the 

modeling results predict that the incremental effect of the operation of the RCWs remains minor, 

the cumulative effects would also remain minor. 

The review team’s modeling predicts minor localized alterations in salinity distribution due to 

RCW operation, and these results suggest that the operation of the RCWs is unlikely to interfere 

with any of the mitigation measures proposed to address the conditions in the cooling canals or 

the underlying Biscayne aquifer. 

G.3.3 Confirmatory Calculations of Potential Upward Migration of Injectate from the 

Boulder Zone of the Lower Floridan Aquifer 

As described in Chapter 5 of the EIS, blowdown and other liquid wastes from the proposed 

plants would be injected into the Boulder Zone of the Lower Floridan aquifer. Use of reclaimed 

water as a makeup water source would result in injectate that is buoyant because of its lower 

density compared to the saline water in the Boulder Zone. FPL conducted performance 

assessment modeling of potential upward migration of injectate based on the reclaimed water 

source (FPL 2014-TN4069) in support of the safety and environmental analysis of the proposed 

plants. The analyses consisted of two main scenarios that were considered feasible: 

 Normal Operation Scenario: Upward migration of contaminants through a competent middle 

confining unit (MCU) under expected hydrogeologic conditions. The normal operation 

scenario assumes that no system failures occur, e.g., no injection well failure or subsurface 

loss of confinement beyond the FPL property area. 

 Off-Normal Operation and Inadvertent Intrusion Scenario: Bypass of the MCU at a location 

2.2 mi from the wastewater injection site through a hypothetical high-conductivity channel or 

failed well (conduit), where a water-supply well is withdrawing water from the upper Floridan 

aquifer directly above the MCU conduit. The hypothetical water-supply well provides direct 

access to the upper Floridan aquifer, bypassing the intermediate confining unit and the 

Biscayne aquifer. 

The FPL analyses were focused on the fate and transport of radionuclides in the injectate, but 

also demonstrate the potential movement of chemical species in the injectate. The FPL analyses 

were based on conservative assumptions that would tend to maximize the migration of effluent. 

The off-normal and inadvertent intrusion scenario “bounded” some other feasible scenarios such 

as bypass of the MCU at the injection site because it resulted in shorter travel times. 

The review team performed a separate confirmatory analysis of these scenarios, which resulted 

in concentrations of radionuclides at receptor locations similar to those calculated by FPL. The 

confirmatory analyses were performed through spreadsheet calculations as described below. 
Appendix G 

October 2016 G-49 NUREG–2176 

G.3.3.1 Normal Operations: Upward Migration through a Competent MCU Layer Scenario 

The confirmatory calculation was based on transport equations described by Post et al. (2007-

TN4145) and used the parameters shown in Table G-23. The effective vertical hydraulic 

conductivity of the MCU was based on the harmonic mean of the values determined from 

testing of core samples from the MCU at the EW-1 exploratory well (FPL 2012-TN1577). The 

harmonic mean is the most appropriate hydraulic conductivity value for fluid flow perpendicular 

to a layered system (Freeze and Cherry 1979-TN3275). Lower porosity decreases travel time in 

the calculations, so a conservatively low porosity value of 0.2 was used. The core analysis 

results from EW-1 are shown in Table G-24. 

Table G-23. Parameters and Results for the Confirmatory Analysis of Upward Migration 

through a Competent MCU Layer 

Parameter Value Description 

z1(a) -2,900 ft top of injection zone (referenced to sea level [positive upward]) 

z2(b) -1,400 ft bottom of USDW aquifer (referenced to sea level [positive 

upward]) 

ρ1(c) 62.230 lbm/ft3 water density at top of injection zone 

ρ2(d) 62.792 lbm/ft3 water density at bottom of USDW aquifer 

h1(e) 328.1 ft piezometer head elevation at top of injection zone 

h2(f) 188.6 ft piezometer head elevation at bottom of USDW aquifer 

Keff(g) 1.82E-07 ft/s effective hydraulic conductivity 

ρa 62.5 lbm/ft3 calculated average density over the migration interval 

hf1 328.1 ft fresh water head at top of injection zone 

hf2 203.0 ft fresh water head at bottom of USDW aquifer 

Δhf -125.1 ft calculated freshwater head difference 

Δz 1,500 ft calculated elevation difference 

Δhf/Δz -0.0834 calculated fresh water gradient 

(ρa-ρf)/ρf 0.0045 calculated density gradient 

qz 1.24E-3 ft/d calculated groundwater flux (positive upward) 

Θeff(h) 0.2 effective porosity along flow path 

tt 663 yr calculated travel time from z1 to z2 

Distance in 100 yr 226 ft calculated vertical migration distance in 100 yr 

Linear Velocity 0.00619 ft/d calculated 

C1 1 unit concentration of injectate at top of injection zone 

t-half 12.3 yr tritium half-life 

C2 5.92E-17 calculated fraction of unit tritium concentration after 663 yr 

Note: flux calculated based on Post et al. (2007-TN4145) 

(a) FSAR Fig. 2.4.12-245 

(b) FSAR Fig. 2.4.12-246 

(c) minimum FSAR value assumed to be freshwater density = 62.2 lbm/ft3

(d) 10,000 mg/l TDS @ 20°C 

(e) Starr et al. (2001-TN1251), Injection Zone High Value 

(f) Starr et al. (2001-TN1251), Upper Monitoring Low Value (wells being purged were not considered) 

(g) Approximate maximum MCU Property Estimate 

(h) Minimum value from Reese (1994-TN1439) 

Source: FPL 2014-TN4069 unless otherwise noted 
Appendix G 

NUREG–2176 G-50 October 2016 

Results of the “normal operations” scenario confirmed the FPL result that the injectate would 

move less than 300 ft upward into the MCU over a 100 yr period. The calculations also resulted 

in radionuclide concentrations at receptor locations similar to those calculated by FPL (2014-

TN4069). 

Table G-24. Core Analyses from the EW-1 Exploratory Well 

Sample Depth 

(ft bpl) 

Vertical Hydraulic 

Conductivity 

(cm/sec) 

Horizontal Hydraulic 

Conductivity 

(cm/sec) 

Specific 

Gravity 

Total 

Porosity 

(%) 

2026.4-2027.0 3.30E-06 3.20E-06 2.71 27.4 

2027.0-2027.5 3.70E-04 7.80E-04 2.70 35.0 

2029.4-2030.4 1.00E-05 2.80E-05 2.71 33.6 

2030.4-2031.3 3.00E-05 1.30E-04 2.71 36.6 

2036.2-2036.7 7.60E-05 1.10E-04 2.72 35.5 

2036.7-2037.9 NA NA NA NA 

2295.2-2296.0 1.90E-04 1.00E-04 2.74 39.5 

2296.0-2296.75 8.40E-05 5.90E-04 2.72 37.9 

2296.75-2297.5 1.00E-04 1.00E-04 2.72 38.5 

2399.9-2400.9 5.40E-04 5.40E-04 2.70 38.7 

2576.0-2577.0 1.90E-04 2.50E-04 2.71 41.4 

2639.3-2639.7 1.60E-06 8.40E-05 2.69 33.7 

2639.7-2640.2 NA NA NA NA 

2645.1-2645.5 1.40E-05 6.20E-06 2.70 36.9 

2645.5-2646.5 NA NA NA NA 

2652.0-2652.8 2.80E-06 4.60E-06 2.71 34.5 

2652.8-2653.5 2.30E-06 2.50E-05 2.71 33.2 

2675.1-2675.6 2.70E-04 2.90E-04 2.71 39.5 

2675.6-2676.1 NA NA NA NA 

2676.1-2677.0 1.10E-06 5.30E-04 2.72 43.4 

Arith. Mean 1.18E-04 

Geom. Mean 2.86E-05 

Harmonic Mean 5.54E-06 

Source: FPL 2012-TN1577 

G.3.3.2 Off-Normal Operation and Inadvertent Intrusion Scenario: 

FPL’s safety analysis (FPL 2014-TN4069) also considered a case with a hypothetical watersupply well being drilled into the upper Floridan (USDW) aquifer and a simultaneous 

bypass/failure of the MCU at the same location 2.2 mi from the wastewater injection site. The 

2.2 mi distance is based on the nearest privately owned parcel. This scenario makes the offnormal operation assumption that there is a high-permeability connection through the MCU 

between the injection zone and the upper Floridan aquifer located 2.2 mi from Turkey Point 

wastewater injection site. This is combined with an inadvertent intrusion scenario that places a 

water-supply well in the upper Floridan aquifer directly above the conduit through the MCU. The 

FPL analysis showed that the transit time through the Boulder Zone from the Turkey Point 
Appendix G 

October 2016 G-51 NUREG–2176 

injection wells to the offsite location 2.2 mi away would be 21 years (FPL 2014-TN4069). The 

staff’s confirmatory calculation showed that at the expected injection rate of 12,460 gpm, and a 

conservatively low porosity of 0.2, the injectate plume would reach the hypothetical offsite 

location in 23.5 years. 

The safety analysis was conservative in that it did not account for transit time through the MCU 

and it did not account for dilution of contaminants within the Upper Floridan aquifer. It assumed 

that 100 percent of the water pumped by the water-supply well would be from the Boulder Zone 

with no dilution in the APPZ or the Upper Floridan aquifer. 

The staff performed a calculation of expected flux through the MCU and dilution in the Upper 

Floridan aquifer using the maximum MCU hydraulic conductivity from the range of values shown 

in Table G-24 for the area of the enhanced vertical flow pathway. This calculation assumed a 

pathway size of 0.3 m2 to match the approximate size of a failed borehole seal. The results of 

the leakage calculations for this scenario were an upward velocity of 1,245 m/yr and eventual 

discharge of 54 gpd of injectate into the Upper Floridan aquifer. It was assumed that this 

volume of injectate would mix over a width of 10 m and 1 percent of the Upper Floridan aquifer 

depth before being brought to the surface through a water-supply well. This was based on an 

Upper Floridan aquifer transmissivity equal to the minimum of the range of values, which would 

minimize the calculated dilution factor. This very conservative mixing scenario results in a 

dilution factor of 0.93, meaning that 93 percent of the water from the well would be injectate. 

This calculation represents a conservative case in multiple ways, including the assumption that 

a water-supply well would be placed such that it would exclusively be pumping water from the 

assumed mixing zone directly above a high-conductivity conduit from the injection zone. An 

upward velocity of 262 ft/yr was estimated by Maliva et al. (2007-TN1483) for an enhanced 

vertical flow feature at an injection site in Palm Beach County compared to the 1,245 ft/yr 

upward velocity from this analysis. 

Table G-25. Parameters and Results for the Confirmatory Analysis of Upward Migration 

Through a Conduit in the MCU and into the Upper Floridan Aquifer 

Parameter Value Description 

z1(a) -2,900 ft top of injection zone (referenced to sea level [positive upward]) 

z2(b) -1,400 ft bottom of USDW aquifer (referenced to sea level [positive 

upward]) 

ρ1(c) 62.230 lbm/ft3 water density at top of injection zone 

ρ2(d) 62.792 lbm/ft3 water density at bottom of USDW aquifer 

h1(e) 328.1 ft piezometer head elevation at top of injection zone 

h2(f) 188.6 ft piezometer head elevation at bottom of USDW aquifer 

Keff(g) 3.28E-04 ft/s effective hydraulic conductivity 

ρa 62.5 lbm/ft3 calculated average density over the migration interval 

hf1 328.1 ft fresh water head at top of injection zone 

hf2 203.0 ft fresh water head at bottom of USDW aquifer 

Δhf -125.1 ft calculated freshwater head difference 

Δz 1,500 ft calculated elevation difference 

Δhf/Δz -0.0834 calculated fresh water gradient 
Appendix G 

NUREG–2176 G-52 October 2016 

Table G-25. (contd) 

Parameter Value Description 

(ρa-ρf)/ρf 0.0045 calculated density gradient 

qz 2.24 ft/d calculated groundwater flux (positive upward) 

Θeff(h) 0.2 effective porosity along flow path 

tt 134.2 d calculated travel time from z1 to z2 

Linear Velocity 11.18 ft/d calculated 

C1 1 unit concentration of injectate at top of injection zone 

t-half 12.3 yr tritium half-life 

C2 0.980 calculated fraction of unit tritium concentration at discharge to 

USDW aquifer after decay 

Discharge Area 0.98 ft2 assumed failed well (leakage) area through MCU 

Discharge Rate 0.67 ft2/d (54 gal/d) volumetric discharge rate of injectate through failed well 

UFA Mixing Width 32.81 ft width of UFA over which MCU discharge is mixed 

UFA Discharge 4.97 ft3/d horizontal volumetric discharge over depth of UFA based on 

minimum UFA transmissivity and gradient 

Mixing Fraction 0.010 assumed fraction of UFA over which MCU discharge is mixed 

Dilution Factor 0.931 MCU discharge/(MCU discharge + Mixing Fraction*UFA 

discharge)

Note: flux calculated based on Post et al. (2007-TN4145) 

(a) FSAR Fig. 2.4.12-245 

(b) FSAR Fig. 2.4.12-246 

(c) minimum FSAR value assumed to be freshwater density = 62.2 lbm/ft3

(d) 10,000 mg/L TDS @ 20°C 

(e) Starr et al. (2001-TN1251), Injection Zone High Value 

(f) Starr et al. (2001-TN1251), Upper Monitoring Low Value (wells being purged were not considered) 

(g) Approximate maximum MCU Property Estimate 

(h) Minimum value from Reese (1994-TN1439) 

Source: FPL 2014-TN4069 unless otherwise noted. 

G.4 SAMDA Sensitivity Evaluation and Supporting Documentation 

G.4.1 Introduction 

FPL performed a SAMDA evaluation and determined that none of the severe accident design 

alternatives (SAMDAs) can be justified to further reduce the risk of severe accidents. NRC’s 

review of the FPL submittal is detailed in Section 5.11.3. The SAMDA evaluation by FPL and 

the confirmatory evaluation by NRC identified the self-actuating containment isolation valves 

design alternative as the only design alternative with a value comparable to the maximum 

attainable benefit for the Turkey Point site. The results of the FPL analysis indicate that the 

maximum attainable benefit if the total risk for the AP1000 at the Turkey Point site were reduced 

to zero would have a value of about $55,513. The cost of implementing the self-actuating 

containment isolation valves design alternative is estimated to be $33,000. Thus, this SAMDA 

would be potentially cost-beneficial. To evaluate the maximum benefit of implementing the selfactuating containment isolation for the risk that this SAMDA would actually affect the 

Containment Isolation severe accident release category of Table 5-18 would be eliminated by 

this SAMDA and its contribution would be added to the Intact Containment release category. 

This would result in a benefit associated with this SAMDA of approximately $994. As was 
Appendix G 

October 2016 G-53 NUREG–2176 

applied for the NRC staff confirmatory calculations, the NRC staff used the population and the 

property value estimates from the latest census data of 2010 and the results of case runs made 

by using the latest version of SECPOP 2010 software (NRC 2003-TN3152; Bixler et al. 2003-

TN3636). This information was consistent with the estimated population and property values 

used in the FPL evaluation. 

With the Commission’s ruling regarding two MELCOR Accident Consequence Code System 

(MACCS) decontamination input parameter values as presented in the severe accident 

mitigation alternative (SAMA) ruling of CLI-16-07 (NRC 2016-TN4631), the staff determined that 

a sensitivity study would be appropriate for the Turkey Point Units 6 and 7 COL SAMDA 

assessments. Two of the MACCS input parameters are related to decontamination cost and 

duration. The basis, results, and conclusions for this SAMDA sensitivity analyses are 

documented here. 

G.4.2 Basis for Sensitivity Analysis 

The two parameters that are considered for the sensitivity analysis are the decontamination time 

(TIMDEC) and the cost for decontamination of non-farmland (CDNFRM), as discussed in CLI16-07. CDNFRM input values are usually taken from NUREG-1150 (NRC 1990-TN525) and 

adjusted for their present values using the Consumer Price Index (CPI) from 1986. The 

TIMDEC input value defines the time required to complete decontamination to a specified 

degree or level. The longer the TIMDEC value, the greater the dose that would be received by 

decontamination workers, and the longer duration that residents would be away from their 

homes. Both of these outcomes would entail higher costs to be assessed in the SAMDA 

analysis. TIMDEC input values and the associated decontamination levels are also taken from 

NUREG-1150. 

The Commission in CLI-16-07 concluded that these two MACCS input parameters for 

decontamination are not fully vetted and could be uncertain; therefore, sensitivity analyses 

should to be performed to ensure that the conclusion of a SAMA evaluation would not be 

affected by any such uncertainties. CLI 16-07 provides a detailed account of the technical basis 

and specifies the reasonably high values for these two parameters for the purpose of sensitivity 

evaluation. With the Commission’s ruling regarding this matter, the NRC staff used the same 

basis as CLI-16-07, to perform SAMDA sensitivity analysis and compare the results to those 

reported in FPL’s ER (FPL 2014-TN4058). 

G.4.3 Sensitivity Analysis and the Results 

Two decontamination levels are considered for evaluating the risks of the postulated accidents. 

An effectiveness factor (effective dose reduction factor) is associated with each 

decontamination level. For example, a dose reduction factor of 3 means that the resulting 

population dose at that location would be reduced to one-third of what it would be without 

decontamination. The two values for decontamination effectiveness (DF) were left unchanged 

at 3 and 15. The variable TIMDEC, which defines the time required for completion of each of 

the DF levels, was changed to 3.15E+07 seconds (i.e., the maximum allowable duration of 1 

year in MACCS input) for both DF levels. 
Appendix G 

NUREG–2176 G-54 October 2016 

The CDNFRM input parameter defines the cost (on a per person basis) of decontaminating nonfarmland to a specified level. To obtain the cost of decontaminating non-farmland areas, the 

code multiplies the specified CDNFRM parameter by the population residing in the areas (“grid 

elements”) that require decontamination. In footnote 122 of CLI 16-07, the intervenor asserts 

that the input values for CDNFRM range from $15,422 to $23,952 per person for light 

decontamination (level 3), and from $71,255 to $112,856 per person for heavy decontamination 

(level 15). Based on this information and the Commission’s recommendation, the sensitivity 

analysis was performed using CDNFRM values of $24,000 and $100,000 for decontamination 

levels of 3 and 15, respectively. 

The results of the sensitivity analysis in comparison to the base case runs are shown in 

Table G-26 for the undiscounted offsite cost, which includes the increase decontamination cost. 

The results in Table G-26 show the effect of the TIMDEC and CDNFRM sensitivity analysis. 

The table shows that for the sensitivity case, the undiscounted offsite cost can increase by a 

factor of about 2. Table G-27 shows the maximum attainable benefit and the benefit associated 

with implementing the self-actuating containment isolation valves design alternative for two 

cases of 7% and 3% annual discount rate. This table shows the benefit of implementing the 

self-actuating containment isolation valves design alternative can increase by a factor of about 2 

for the sensitivity analysis at both the 3% and 7% annual discount rates. 

Table G-26. Undiscounted Offsite Cost for the Base Case and the Sensitivity Cases 

Undiscounted Offsite Cost Present Dollar Value 

Base Case as reported in ER 1346.2(a) 

Sensitivity (TIMDEC of one year and CDNFRM of $24000 

for $100,000 for Decontamination Levels 3 and 15) 

2890.27 

(a) ER value of $636 was multiplied by the ratio of the total CDF from both external and 

internal hazards over CDF of internal hazards only 

Table G-27. Maximum Attainable Benefit and the Benefit of Implementing the Most Cost 

Beneficial SAMDA for the Base and Sensitivity Cases 

Case Studies 

Maximum Attainable Benefit 

Benefit of Implementing 

Self-Actuating Containment Isolation 

Valves SAMDA 

7% Discount Rate 3% Discount Rate 7% Discount Rate 3% Discount Rate 

Base Case FPL-ER $ 55,513 $ 123,602 $ 994 $ 1,965(a) 

Sensitivity Case $ 77,588 $ 167,220 $ 1,965 $ 3,896 

(a) This value was estimated based on information from FPL’s MACCS calculation (FPL 2014-TN3660) but it is not 

specifically reported in the ER. 

G.4.4 Conclusion 

The cost of implementing the self-actuating containment isolation valves design alternative for 

the AP1000 reactor design is estimated to be $33,000 (see Table 5-22). A sensitivity analysis 

was performed using conservative values for two MACCS decontamination input parameter 

values (i.e., TIMDEC and CDNFRM). This analysis showed that the maximum benefit from 

implementing this particular SAMDA is less than $3,896, which is below the $33,000 cost of this 
Appendix G 

October 2016 G-55 NUREG–2176 

particular SAMDA. This reconfirms the staff’s conclusion that no cost–beneficial SAMDAs 

remains valid for the AP1000 reactor design located at the Turkey Point site. 

G.5 References 

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for 

Protection Against Radiation." Washington, D.C. TN283. 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 

Production and Utilization Facilities." Washington, D.C. TN249. 

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 

"Environmental Radiation Protection Standards for Nuclear Power Operations." Washington, 

D.C. TN739. 

Bixler, N.E., S.A. Shannon, C.W. Morrow, B.E. Meloche, and J.N. Ridgely. 2003. 

SECPOP2000: Sector Population, Land Fraction, and Economic Estimation Program. 

NUREG/CR–6525, Revision 1, Sandia National Laboratories, Albuquerque, New Mexico. 

Accession No. ML032310279. TN3636. 

FAO (Food and Agriculture Organization of the United Nations). 2012. "Feeding and Growth of 

Juvenile Crocodiles." Chapter 9 in The Management of Crocodiles in Captivity (Bolton). Rome, 

Italy. Available at http://www.fao.org/docrep/006/T0226E/t0226e10.htm. TN2580. 

FDACS (Florida Department of Agriculture and Consumer Services). 2015. 2014 Florida 

Livestock, Dairy, and Poultry Summary. Tallahassee, Florida. Available at 

http://www.nass.usda.gov/Statistics_by_State/Florida/Publications/Livestock_and_Poultry/ldpsu

m14/ldp14All.pdf. TN4526. 

Ferris, J.G., D.B. Knowles, R.H. Brown, and R.W. Stallman. 1962. Theory of Aquifer Tests, 

Ground Water Hydraulics. U.S. Geological Survey Water-Supply Paper 1536E, Washington,

D.C. Accession No. ML14345B002. TN4092. 

Fogarty, M.J. and J.D. Albury. 1967. "Late Summer Foods of Young Alligators in Florida." In 

Proceedings of the 21st Annual Conference of the Southeastern Association of Game and Fish 

Commissioners, 1967. Columbia, South Carolina. TN2581. 

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). 2010. "GASPAR Output Files for Turkey Point Units 6 

and 7." Washington, D.C. Accession No. ML15026A472. TN4151. 

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 G 

NUREG–2176 G-56 October 2016 

FPL (Florida Power & Light Company). 2014. Letter from S. Franzone to NRC, dated February 

24, 2014, regarding "Florida Power & Light Company Proposed Turkey Point Units 6 and 7, 

Docket Nos. 52-040 and 52-041, Updated MACCS2 Input/Output Files." L-2014-058, Juno 

Beach, Florida. Accession No. ML14063A251. TN3660. 

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). 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 

22, 2016, regarding "Response to NRC Environmental Request for Additional Information Letter 

160302 (eRAI 8506) Related to Radioactive Waste Management Systems.” L-2016-028, Juno 

Beach, Florida. Accession No. ML16061A223. TN4511. 

Freeze, R.A. and J.A. Cherry. 1979. Groundwater. Prentice-Hall, Inc., Upper Saddle River, 

New Jersey. TN3275. 

Hantush, M.S. and C.E. Jacob. 1955. "Non-Steady Radial Flow in an Infinite Leaky Aquifer." 

Transactions American Geophysical Union, 36(1):95–100, Washington, D.C. TN4094. 

Hughes, J.D., C.D. Langevin, and L. Brakefield-Goswami. 2010. "Effect of Hypersaline Cooling 

Canals on Aquifer Salinization." Hydrogeology Journal 18(1):25–38, New York, New York. 

TN1545. 

HydroSOLVE, Inc. 2007. "AQTESOLVTM for Windows Version 4.5." Reston, Virginia. 

Available at http://www.aqtesolv.com/. TN4091. 

IAEA (International Atomic Energy Agency). 1992. Effects of Ionizing Radiation on Plants and 

Animals at Levels Implied by Current Radiation Protection Standards. Technical Report Series 

332, Vienna, Austria. TN712. 

Lohman, S.W. 1972. Ground-Water Hydraulics. U.S. Geological Survey Professional Paper 

708, Washington, D.C. Accession No. ML14342A004. TN4095. 

Lohmann, M.A., E.D. Swain, J.D. Wang, and J. Dixon. 2012. Evaluation of Effects of Changes 

in Canal Management and Precipitation Patterns on Salinity in Biscayne Bay, Florida, Using an 

Integrated Surface-Water/Groundwater Model. Scientific Investigations Report 2012–5099, 

U.S. Geological Survey, Reston, Virginia. Accession No. ML14287A448. TN1429. 

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. 
Appendix G 

October 2016 G-57 NUREG–2176 

Mazzotti, F.J. 2003. "American Crocodiles (Crocodylus acutus) in Florida." WEC 38, 

University of Florida Institute of Food and Agricultural Sciences Extension, Gainesville, Florida. 

Available at http://edis.ifas.ufl.edu/uw157. TN1499. 

National Geographic. 2012. American Crocodile. Washington, D.C. Available at 

http://animals.nationalgeographic.com/animals/reptiles/american-crocodile/. TN2577. 

NCRP (National Council on Radiation Protection and Measurements). 1987. "Exposure of the 

Population in the United States and Canada from Natural Background Radiation." NCRP 

Report No. 94, Bethesda, Maryland. TN2258. 

NCRP (National Council on Radiation Protection and Measurements). 1991. Effects of Ionizing 

Radiation on Aquatic Organisms. NCRP Report No. 109, Bethesda, Maryland. TN729. 

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. 

Neuman, S.P. and P.J. Wierenga. 2003. A Comprehensive Strategy of Hydrogeology Modeling 

and Uncertainty Analysis for Nuclear Facilities and Sites. NUREG/CR–6805, U.S. Nuclear 

Regulatory Commission, Washington, D.C. Accession No. ML032470827. TN4090. 

NRC (U.S. Nuclear Regulatory Commission). 1977. Calculation of Annual Doses to Man from 

Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 

Part 50, Appendix I. Regulatory Guide 1.109, Revision 1, Washington, D.C. Accession No. 

ML003740384. TN90. 

NRC (U.S. Nuclear Regulatory Commission). 1990. Severe Accident Risks: An Assessment 

for Five U.S. Nuclear Power Plants. NUREG–1150, Washington, D.C. Accession No. 

ML040140729. TN525. 

NRC (U.S. Nuclear Regulatory Commission). 2000. Environmental Standard Review Plan—

Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG–1555, 

Main Report and 2007 Revisions, Washington, D.C. Available at http://www.nrc.gov/readingrm/doc-collections/nuregs/staff/sr1555/toc/. TN614. 

NRC (U.S. Nuclear Regulatory Commission). 2003. Generic Environmental Impact Statement 

for License Renewal of Nuclear Plants Supplement 11 Regarding St. Lucie Units 1 and 2. 

NUREG-1437, Final Report, Washington, D.C. Accession No. ML031360705. TN3152. 

NRC (U.S. Nuclear Regulatory Commission). 2013. Email from M. Comar to Florida Power & 

Light, dated February 20, 2013, regarding "Request for Additional Information Letter No. 072 

Related to SRP Section 11.02 Liquid Waste Management Systems for the Turkey Point Units 6 

and 7 Combined License Application." Washington, D.C. Accession No. ML13051A779. 

TN3937. 
Appendix G 

NUREG–2176 G-58 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). 2015. Draft Environmental Impact Statement for 

Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7. NUREG-2176, 

Washington, D.C. Accession No. ML15055A103, ML15055A109. TN4444. 

NRC (U.S. Nuclear Regulatory Commission). 2016. "Memorandum and Order in the Matter of 

Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3)." CLI-16-07, 

Rockville, Maryland. Accession No. ML16125A150. TN4631. 

NRC (U.S. Nuclear Regulatory Commission). 2016. Advanced Safety Evaluation for Turkey 

Point Units 6 and 7 Combined License Application, Chapter 11: "Radioactive Waste 

Management." Washington, D.C. Accession No. ML15096A457. TN4776. 

Oostrom, M. and L. Vail. 2016. Review Team Focused Modeling Analysis of Radial Collector 

Well Operation on the Hypersaline Groundwater Plume beneath the Turkey Point Site near 

Homestead, Florida. PNNL-25755, Pacific Northwest National Laboratory, Richland,

Washington. Accession No. ML16278A742. TN4739. 

ORNL (Oak Ridge National Laboratory). 2012. "NRCDOSE 2.3.20 Computer Code System for 

Evaluating Routine Radioactive Effluents from Nuclear Power Plants with Windows Interface." 

CCC–684, Radiation Safety Information Computational Center, Oak Ridge, Tennessee. 

Accessed April 1, 2016, at https://rsicc.ornl.gov/PackageDetail.aspx?p=NRCDOSE 

2.3.20&id=C00684&cpu=PC586&v=14&t=Code System for Evaluating Routine Radioactive 

Effluents from Nuclear Power Plants with Windows Interface. TN4556. 

Post, V., H. Kooi, and C. Simmons. 2007. "Using Hydraulic Head Measurements in VariableDensity Ground Water Flow Analyses." Groundwater 45:664–71, Malden, Massachusetts. 

TN4145. 

Reese, R.S. 1994. Hydrogeology and the Distribution and Origin of Salinity in the Floridan 

Aquifer System, Southeastern Florida. U.S. Geological Survey Water-Resources Investigations 

Report 94–4010, Tallahassee, Florida. Accession No. ML14287A476. TN1439. 

Sagendorf, J.F., J.T. Goll, and W.F. Sandusky. 1982. XOQDOQ: Computer Program for the 

Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations. 

NUREG/CR–2919, Pacific Northwest Laboratory, Richland, Washington. Accession No. 

ML081360412. TN280. 

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. 
Appendix G 

October 2016 G-59 NUREG–2176 

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User Guide. NUREG/CR–4013, Pacific Northwest Laboratory, Richland, Washington. 

Accession No. ML14098A069. TN82. 

Strenge, D.L., T.J. Bander, and J.K. Soldat. 1987. GASPAR II—Technical Reference and User 

Guide. NUREG/CR–4653, Pacific Northwest Laboratory, Richland, Washington. Accession No. 

ML14098A066. TN83. 

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, 

Jacksonville, Florida. Accession No. ML12270A058. TN1038. 

USDA (U.S. Department of Agriculture). 2004. 2002 Census of Agriculture, Florida State and 

County Data. Volume 1, Geographic Area Series, Part 9, AC-02-A-9, Washington, D.C. 

Accession No. ML14280A612. TN1390. 

USDA (U.S. Department of Agriculture). 2007. Commercial Red Meat: Production by State 

and U.S. National Agriculture Statistics Service, Washington, D.C. Accession No. 

ML14280A613. TN1391. 

USDA (U.S. Department of Agriculture). 2008. 2007 Field Crops Highlights, Florida. National 

Agricultural Statistics Service, Washington, D.C. Accession No. ML14282A858. TN1392. 

USDA (U.S. Department of Agriculture). 2008. 2007 Livestock Highlights, Florida. National 

Agricultural Statistics Service, Washington, D.C. Accession No. ML14282A862. TN1393. 

USDA (U.S. Department of Agriculture). 2014. 2012 Census of Agriculture, Florida State and 

County Data. Volume 1, Geographic Area Series, Part 9, AC-12-A-9, Washington, D.C. 

Accession No. ML16167A507. TN4523. 

USDA (U.S. Department of Agriculture). 2013. "Commercial Red Meat: Production, by State 

and U.S." Table in 2013 Iowa Agricultural Statistics, Statistical Bulletin Number 2049, National 

Agricultural Statistics Services, Washington, D.C. Accession No. ML16167A508. TN4525. 

USDA (U.S. Department of Agriculture). 2014. Vegetables, Final Estimates 2008-2012. 

Statistical Bulletin Number 1033, National Agricultural Statistics Service, Washington, D.C. 

Accession No. ML16216A203. TN4524. 

Westinghouse (Westinghouse Electric Company LLC). 2011. AP1000 Design Control 

Document. APP-GW-GL-700, Revision 19, Pittsburgh, Pennsylvania. Accession No. 

ML11171A500. TN261. 

White, M.D. and M. Oostrom. 2006. STOMP Subsurface Transport Over Multiple Phases, 

Version 4.0, User's Guide. PNNL-15782, Pacific Northwest National Laboratory, Richland, WA. 

Accession No. ML16278A741. TN4808. 

APPENDIX H 

AUTHORIZATIONS, PERMITS, AND CERTIFICATIONS 

October 2016 H-1 NUREG–2176 

APPENDIX H 

AUTHORIZATIONS, PERMITS, AND CERTIFICATIONS 

This appendix contains a list of environmental-related authorizations, permits, and certifications 

potentially required by Florida Power and Light Company (FPL) from Federal, State, regional, 

and local agencies related to the combined construction permits and operating licenses 

(combined licenses or COLs) for proposed Turkey Point Units 6 and 7 in Miami-Dade County, 

Florida. Table H-1 is based on Table 1.2-1 of the Environmental Report (ER), Revision 6 

(FPL 2014-TN4058), submitted on October 29, 2014 by FPL to the U.S. Nuclear Regulatory 

Commission (NRC). 
NUREG

–2176 H-2 October 2016 

Appendix H Table H-1. Federal, State, and Local Environmental Permits and Authorizations Jurisdictional Agency Authority, Law, or Regulation Description of Requirement License/Permit and/or Applicability(a) Date of Application and/or Date Issued Activity Covered 

Federal NRC 10 CFR Part 30 By-product license (3) Application submitted

06/30/2009 

Possession of by-product material. 

NRC 10 CFR Part 40 Source material license (3) Application submitted 

06/30/2009 

Possession of source material. 

NRC 10 CFR Part 50 Licensing of nuclear power plant (3) Application submitted 

06/30/2009 

Approval for construction and/or operation of nuclear power plant. 

NRC 10 CFR Part 51, 

10 CFR Part 52 

NRC approval of an environmental report 

(2) Application submitted 

06/30/2009 

Evaluation of environmental impacts from construction and operation of a nuclear power plant.

NRC 10 CFR Part 52 COL (3) Application submitted 

06/30/2009 

Safety review of the nuclear power plant site. 

NRC 10 CFR Part 61 Licensing requirements for land 

disposal of radioactive wastes 

(2) Application submitted 

06/30/2009 

Land disposal of radioactive waste that contains by-product source and special nuclear material. 

NRC 10 CFR Part 70 Special nuclear material license (3) Application submitted 

06/30/2009 

Possession of special nuclear material. 

NRC 10 CFR Part 71 Packaging and transportation of 

radioactive material 

(3) Application submitted 

06/30/2009 

Packaging and transportation of licensed radioactive material. 

NRC 10 CFR 72 General License for Storage of 

Spent Fuel at Power Reactor Sites 

(3) Authorized if Combined 

License Issued 

Storage of power reactor spent fuel and other associated radioactive materials in an independent spent fuel storage installation 
October 2016 H-3 NUREG–2176 

Appendix H 

Table H-1. (contd) 

Jurisdictional 

Agency 

Authority, Law, or 

Regulation 

Description of 

Requirement 

License/Permit 

and/or 

Applicability(a) 

Date of Application 

and/or Date Issued Activity Covered 

Federal DOE Nuclear Waste Policy 

Act (42 U.S.C. 10101 et seq.) and 10 CFR Part 961 

Spent fuel contract No. DE-CR01-

09RW9012 (Unit 6) 

No. DE-CR01-

09RW09013 (Unit 7) 

(3) 

11/14/2008 11/14/2008 

Disposal of spent nuclear fuel. 

USACE Clean Water Act of 1976 

33 U.S.C. section 1344 

Section 404 Permit (1) 06/30/2009, modified 

05/07/2010 

Discharge of dredge and fill materials into waters of the United States. 

USACE (request is made through SFWMD) 

Rivers and Harbors Act of 1899/33 U.S.C. section 14 

Section 408 Permit (1) Application date to 

be determined 

Public works alteration request for facilities that are proposed on, over, under, or adjacent to a canal or levee constructed by the USACE and operated and maintained by SFWMD. 

USACE Rivers and Harbors 

Appropriations Act of 1899 (33 U.S.C. section 401 et seq.) 

Section 10 — Rivers and Harbors Act Permit 

(1) Application submitted 

06/30/2009 

Excavation or filling within navigable waters of the United States. 

USACE Secretary of the Army Modified water 

deliveries to Everglades National Park 

DACW-17-3-08-0006 

Amendment No.1 

Amendment No. 2 Amendment No. 3 Amendment No. 4 

(each Amendment 

extended the license 

agreement for an 

additional year, 

currently expires 

6/20/2013) 

06/20/2008 06/20/2009 06/20/2010 06/20/2011 06/27/2012 

Renewal application 

submittal date to be 

determined 

Use of Government-owned lands for the purpose of onsite investigations in support of a Phase 1 ESA, Wetland delineation, preparation of legal description and soil borings. 
NUREG–2176 H-4 October 2016 

Appendix H Table H-1. (contd) Jurisdictional Agency Authority, Law, or Regulation Description of Requirement License/Permit and/or Applicability(a) Date of Application and/or Date Issued Activity Covered 

Federal Aviation Agency. 

14 CFR Part 77 - Safe, Efficient Use, and Preservation of Navigable Airspace 

FAA Obstruction Permit for Unit 6 Containment Building 

2012-ASO-7115-OE 08/24/2012 FAA Obstruction 

Permit for Unit 6 Containment Building. 

Federal Aviation Agency 

14 CFR Part 77 - Safe, Efficient Use, and Preservation of Navigable Airspace 

FAA Obstruction Permit for Unit 7 Containment Building 

2012-ASO-7116-OE 08/24/2012 FAA Obstruction 

Permit for Unit 7 Containment Building. 

Department of the Interior 

RE-DO-53 Temporary 

Construction Easement 

EVER SUP 08-38 07/28/2008 Provide access to 

delineate wetland boundaries within the proposed utility line ROW relocation in Everglades National Park. 

Department of the Interior 

RE-DO-53 Temporary 

Construction Easement 

EVER SUP 08-39 07/28/2008 Provide access to 

conduct visual and pedestrian surveys for Phase I environmental assessment within the proposed utility line ROW relocation in Everglades National Park. 

FWS 16 U.S.C. 1539(a)(1)(A); 

50 CFR Parts 13, 17 

Endangered species permit to take American crocodile during monitoring 

TE092945-2 

(1) 

01/29/2010 Provides 

authorization to take (capture, examine, weigh, sex, collect tissue samples, mark, radio-tag, radio-track, relocate, release) endangered American crocodile individuals during population monitoring. 
October 2016 H-5 NUREG

–2176 

Appendix H 

Table H-1. (contd) 

Jurisdictional 

Agency 

Authority, Law, or 

Regulation 

Description of 

Requirement 

License/Permit 

and/or 

Applicability(a) 

Date of Application 

and/or Date Issued Activity Covered 

FWS 16 U.S.C. 703-712 Special purpose 

salvage permit, migratory birds 

MB697722-0 

Amendment 

(1) 

04/01/2012 Provides 

authorization to: salvage dead migratory birds, abandoned nests, and addled eggs after nesting season; dead bald or golden eagles; and possess live migratory birds for transport to permitted rehabilitator. 

State of Florida Authorizations FDEP, Siting Board 

FS 403.501-.518 Power plant site 

certification(b)

(2) 06/30/2009, 

Amendment 

submittals 05/07/2010 

11/12/2012 12/21/2012 

Errata submitted 

03/22/2013 

Final Conditions of 

Certification issued 

5/19/2014 

Remanded to FSB(b)

4/20/2016 

Construction and operation of a power plant with more than 75 MW of steam generated power and associated facilities. 

FDEP, USEPA Region IV review 

FAC 62-621 NPDES storm water 

operations permit for industrial activities 

(3) 06/30/2009 Operation of an 

industrial facility. 

FDEP Chapter 403 FS Exploratory well 

construction permit 

0293962-001-UC 

(1) 

05/05/2010 Allows for the 

construction of the exploratory well and dual-zone monitor well. 
NUREG–2176 H-6 October 2016 

Appendix H Table H-1. (contd) Jurisdictional Agency Authority, Law, or Regulation Description of Requirement License/Permit and/or Applicability(a) Date of Application and/or Date Issued Activity Covered 

FDEP Chapter 403 FS UIC well construction 

permit 

(1) 07/29/2013. 

Final Conditions of 

Certification issued 

May 19, 2014 

Allows for the conversion of the exploratory well to an injection well and perform operational testing for up to 2 years. 

FDEP Chapter 403 FS UIC well construction 

permit 

(1) Application date to be 

determined. A 

decision to move 

forward and submit 

the permit application 

will be made at a later 

date. 

Allows for the construction and operational testing of additional injection and dual zone monitoring wells. 

FDEP Chapter 403 FS Class I well operation 

permit 

(3) Application date to be 

determined. A 

decision to move 

forward and submit 

the permit application 

will be made at a later 

date. 

Allows for the operation of the injection wells. This permit must be renewed every 5 years. 

FDEP, USEPA Region IV review 

FAC 62-212 Prevention of significant 

deterioration construction permit 

PSD-FL-409 

(1) 

05/28/2010. final

Conditions of 

Certification issued 

May 19, 2014 

Construction and operation of facilities that generate air emissions. 

FDEP, USEPA Region IV review 

403.0885 FS Modification of 

Industrial Wastewater Treatment Facility permit 

FL0001562 

(2) 

06/30/2009. Final

Conditions of 

Certification issued 

May 19, 2014 

Construction of Units 6 and 7 within the industrial wastewater facility. 

FDEP/USEPA FAC 62-25, 62-40 NPDES construction 

storm water permit 

(1) To be submitted 2 

days prior to 

beginning construction 

Final Conditions of 

Certification issued 

May 19, 2014 

Construction of any facility that disturbs 1 acre or more. 
October 2016 H-7 NUREG–2176 

Appendix H 

Table H-1. (contd) 

Jurisdictional 

Agency 

Authority, Law, or 

Regulation 

Description of 

Requirement 

License/Permit 

and/or 

Applicability(a) 

Date of Application 

and/or Date Issued Activity Covered 

FDEP 403.087, FS and FAC 

62-4, 62-520, 62-522, 62-528, 62-550, 62-600, 62-601 

Operation of Class V, Group 3 domestic wastewater injection (gravity flow) well 

0127512-006-UO 

(3) 

08/14/2012. Final 

Conditions of 

Certification issued 

May 19, 2014 

Operation of IW-1. 

FDEP 403, FS and FAC 62-

600, 62-601, 62-602, 62-620, 62-640, 62-699 

Operation of domestic wastewater treatment facility 

FLA013612- 003-

DW3P 

(3) 

09/28/2010. Final 

Conditions of 

Certification issued 

May 19, 2014 

Operation of Turkey Point Power Plant wastewater treatment facility. 

FDEP FAC 62-213 Title V Operations 

Permit 

0250003-010-AV 

(3) 

01/01/2009. Final

Conditions of 

Certification issued 

May 19, 2014 

Operation of facilities that generate air emissions. 

FDEP FAC 62-213 Title V Operations 

Permit 

0250003-021-AV 

(3) 

Effective 01/01/2014.

Final Conditions of 

Certification issued 

May 19, 2014 

Operation of facilities that generate air emissions. 

FDEP 403 FS Nuclear Replacement 

of Emergency Diesel Engines 

0250003-020-AC 04/02/2013 Replacement of 

diesel engines. 

FDEP, South Florida Water Management District 

FAC 40B-3 Well Construction 

Permit 

13-59-3795 to 13-59-

3814 

(2) 

01/14/2008. Final

Conditions of 

Certification issued 

May 19, 2014 

Construct, repair, modify, or abandon a well.

South Florida Water Management District 

FAC 40E-3 Well Abandonment 

Permit 

#SF092308E, 

#SF092308F, 

#SF092308G, 

#SF092308H 

(2) 

05/05/2009 

Cancelled 

Well abandonment permits. 

State of Florida FAC 40E-3 Well Abandonment 

Permit 

13-59-2241 through 

13-59-2259 

(2) 

02/19/2008 Application to 

construct, repair, modify, or abandon well. 

FWCC FAC 68A-9.002, 68A27.005 Removal of nests and ospreys LSNR-1100026 (1) 02/02/2011 Removal and replacement of 

inactive nests of ospreys and other migratory birds. 
NUREG–2176 H-8 October 2016 

Appendix H Table H-1. (contd) Jurisdictional Agency Authority, Law, or Regulation Description of Requirement License/Permit and/or Applicability(a) Date of Application and/or Date Issued Activity Covered 

FWCC FAC 68A-9.002, 68A9.025, 68A-27 Carcass Salvage Permit LSSC-11-00021 (1) 02/02/2011 Salvage, mount, and display wildlife 

carcasses upon encounter for educational and scientific purposes. 

Florida Division of Historical Resources (SHPO) 

National Historic Preservation Act (54 U.S.C. 300101 et seq.) and 36 CFR 800 

Cultural Resources Review and Consultation 

(1), (2), and (3) 07/28/2010. Final

Conditions of 

Certification issued 

May 19, 2014 

Identification, description, and evaluations of cultural resources on and in the site vicinity with the potential to be impacted by construction and operations. 

Other States AuthorizationsUtah Department of Environmental Quality Division of Radiation Control 

R313-26 of the Utah Radiation Control Rules 

Revision of existing general site access permit 

(3) Annual authorization Transport of 

radioactive materials into the State of Utah. 

Tennessee Department of Environment and Conservation Division of Radiological Health 

TDEC Rule 1200-2-10.32 

Revision of existing Tennessee radioactive waste license-fordelivery 

(3) Annual authorization Transport of 

radioactive waste into the State of Tennessee.
October 2016 H-9 NUREG–2176 

Appendix H 

Table H-1. (contd) 

Jurisdictional 

Agency 

Authority, Law, or 

Regulation 

Description of 

Requirement 

License/Permit 

and/or 

Applicability(a) 

Date of Application 

and/or Date Issued Activity Covered 

Local AuthorizationsMiami-Dade County 

Chapter 163 FS; MiamiDade County Comprehensive Plan and adopted regulations and Miami-Dade County Ordinances, Chapter 33 

Land use and zoning approval (unusual use approval) 

Miami-Dade County 

Board of County 

Commissioners 

Resolution Z-56-07 

(1) 

12/24/2007 Unusual use 

(zoning approval) to permit a nuclear power plant (atomic reactors) and ancillary structures and equipment. 

Miami-Dade County 

Chapter 163 FS; MiamiDade County Comprehensive Plan and adopted regulations and Miami-Dade County Ordinances, Chapter 33 

Land use and zoning approval (unusual use approval) 

Miami-Dade County 

Board of County 

Commissioners 

Resolution Z-1-13 

(1) 

01/13/2013 Unusual use 

(zoning approval) to permit a reclaimed water treatment facility, radial collector wells, and a parking area associated with Turkey Point Units 6 and 7. 

Miami-Dade County 

Chapter 163 FS; MiamiDade County Comprehensive Development Master Plan and adopted regulations 

Comprehensive Development Master Plan text amendment 

(1) Application submitted 

10/31/2008; 

withdrawn 03/05/2010 

Excavation for fill source. 

Miami-Dade County 

Chapter 163 FS; MiamiDade County Comprehensive Development Master Plan and adopted regulations 

Comprehensive Development Master Plan text amendment 

(1) 04/30/2009 Temporary access 

roads. 

Miami-Dade County 

Miami-Dade County Ordinances 

IW6 permit (industrial well field) for site investigation 

Permit Numbers: 

13-59-2241 through 

13-59-2259 

(1) 

02/19/2008 Land use — 

nonresidential, within major well field protection areas not served by sanitary sewers. 
NUREG–2176 H-10 October 2016 

Appendix H Table H-1. (contd) Jurisdictional Agency Authority, Law, or Regulation Description of Requirement License/Permit and/or Applicability(a) Date of Application and/or Date Issued Activity Covered 

Miami-Dade County Health Department 

Chapter 373 FS Water well construction 

permits 

13-59-2241 to 13-59-

2259 

13-59-3795 to 13-59-

3814 

(1) 

02/19/2008 01/14/2008 

Well installation for hydrologic investigation. 

Miami-Dade County 

Miami-Dade County Code Chapter 24 

Domestic wastewater annual operating permit 

DWO-000010-20130-

2014 

(2) 

04/15/2013 Stabilization 

treatment facility. 

Miami-Dade County 

Miami-Dade County Code Chapter 24 

Operation of pollution control facility permit 

IW5-006229-2012-

2013 

(2) 

05/01/2013 Operation of fleet 

vehicle maintenance facility that generates waste oil, coolant, and used batteries with a solvent wash tank and served by septic tank. 

State of Florida Department of 

Agriculture 

Burn Permit 1373498 

(2) 

01/24/2011 Onsite combustion 

of construction debris. Annual permit issued. 

Miami-Dade County 

Miami-Dade County Ordinances, Section 24-35 

IW5 Permit (or waiver) IW-000016-

2012/2013 

06/01/2013 Hazardous 

materials or hazardous wastelarge user or generator. Hazardous waste permit issued 10/01/2008. 

Miami-Dade County 

Miami-Dade County Code Chapter 24 

Stratospheric Ozone Protection Annual Operations Permit 

APCF-001747-2012-

2013 

(1) 

07/01/2012 Use of refrigerants 

R-12, R-22, R-502 for Robinair Recovery Units, Models 25200, 25200A, 25200B. 
October 2016 H-11 NUREG–2176 

Appendix H 

Table H-1. (contd) 

Jurisdictional 

Agency 

Authority, Law, or 

Regulation 

Description of 

Requirement 

License/Permit 

and/or 

Applicability(a) 

Date of Application 

and/or Date Issued Activity Covered 

Miami-Dade County 

Miami-Dade County Code Chapter 24 

Industrial Waste Annual Operations Permit 

IW-000003-2013-

2014 

(2) 

06/01/2013 Onsite disposal of 

Class III industrial solid waste consisting of earth and earth-like products, concrete, rock, bricks, and land clearing debris. 

Miami-Dade County 

Miami-Dade County Ordinance 89-104 

Marine Facilities Annual Operations Permit 

MOP-000072-

2013/2013 

(2) 

10/01/2012 Operation of 1 wet 

slip, 1 dry slip, 2 commercial vessels. 

Miami-Dade County 

Miami-Dade County Ordinances, Chapter 8 

Turkey Point Units 6 and 7 Site InvestigationConstruction trailers 

2008-026502 01/29/2008 Construction 

Trailers. 

Miami-Dade County 

Miami-Dade County Ordinances, Chapter 8 

Turkey Point Units 6 and 7 Exploratory WellElectrical permits 

2011-028574 2011-031469 

03/28/2011 04/13/2011 

Exploratory well electrical permit. 

State of Florida; MiamiDade County 

Miami-Dade County Ordinances, Chapter 8; FAC 64E-6 

Turkey Point Units 6 and 7 Exploratory WellConstruction Trailer permits 

2011-031471 2011-031529 2011-031532 

13-SC-1307746 

2011-031470 2011-031530 2011-031531 

13-SC-1307751 

04/13/2011 04/13/2011 04/13/2011 03/18/2011 04/13/2011 04/13/2011 04/13/2011 03/18/2011 

Exploratory well construction trailer permit. 

State of Florida FAC 40D-3 Turkey Point Units 6 

and 7 Exploratory Well and Dual Zone Monitoring Well-Pad monitor well permits 

13-59-6664-71 04/14/2011 Exploratory well pad 

monitor well permits. 

South Florida Water Management District 

FAC 40D-3 Turkey Point Units 6 

and 7 Exploratory and Dual Zone Monitoring Well-Pad monitoring well abandonment 

13-59-8020 to 8027 07/24/2012 Pad monitor wells 

abandonment permit. 
NUREG–2176 H-12 October 2016 

Appendix H Table H-1. (contd) Jurisdictional Agency Authority, Law, or Regulation Description of Requirement License/Permit and/or Applicability(a) Date of Application and/or Date Issued Activity Covered 

Miami-Dade County 

Miami-Dade County Ordinances, Chapter 33 

Unusual Use Resolution 

Resolution Z-56-07 12/24/2007 Unusual use 

resolution. 

Miami-Dade County 

Not available Fencing permit around 

EW-1 and DZMW-1 

2012059049 09/06/2012 

South Florida Water Management District 

Chapter 373 FS Water well construction 

permits 

SF092308ASF092308D SF123008ASF123008E 

9/23/2008 

12/23/2008 

Pump test for test wells.

(a) Applicability of the license or permit to the project activity type, i.e., (1) activities not requiring a COL, (2) construction activities requiring a COL, and (3) plant 

operation activities. 

(b) Pursuant to the Florida Electrical Power Plant Siting Act 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. On June 30, 2009, FPL submitted a Site Certification Application (SCA) to the State of Florida Department of Environmental Protection for the proposed Turkey Point Units 6 and 7 and ancillary facilities (FPL 2010-TN1231). The SCA process provides a Certification that encompasses all licenses and permits needed for affected Florida State, regional, and local agencies. It also includes any regulatory activity that would be 

applicable under these agencies’ regulations for proposed Turkey Point Units 6 and 7 (FDEP 2013-TN2629). On May 19, 2014, the State of Florida issued 

final Conditions of Certification to FPL authorizing construction, operation, and maintenance of proposed Turkey Point Units 6 and 7 and associated facilities 

(State of Florida 2014-TN3637). The final Conditions of Certification issued are binding and subject to the requirements listed in State of Florida 2014(TN3637). The NRC staff is aware that on April 20, 2016, a Florida court issued an opinion in which it ruled that the Florida Siting Board should have considered whether to require FPL to bury a portion of the transmission lines, and that the record was inadequate to support certain mitigation measures associated with transmission lines in the East Everglades. [State of Florida 2016-TN4781] Although the opinion remands the Conditions of 

Certification to the Florida Siting Board for consideration of the possibility of burying a portion of the transmission lines and reconsideration of the specified mitigation measures, the NRC staff understands that the court’s opinion is not yet final as of this writing (October 3, 2016). Accordingly, for the purposes of 

the FEIS evaluation of impacts, the NRC staff considers the transmission line route and conditions reviewed and approved by the Florida Siting Board as the 

most current information regarding the transmission line and associated potential mitigation measures. Even if the Conditions of Certification are revisited, 

the NRC staff considers it reasonable to expect that Conditions of Certification similar to or no less effective than those originally issued will be in place before construction and operation of the proposed units begins.

CFR = Code of Federal Regulations. 

DOE = U.S. Department of Energy. ESA = Endangered Species Act of 1973, as amended. FAC = Florida Administrative Code. FS = Florida Statute. FAA = Federal Aviation Administration. FDEP = Florida Department of Environmental Protection. FWCC = Florida Fish and Wildlife Conservation Commission. FWS = U.S. Fish and Wildlife Service. IW = Industrial Well or Industrial Waste MW = Megawatt. NPDES = National Pollutant Discharge Elimination System. NRC = U.S. Nuclear Regulatory Commission. ROW = Right of Way TDEC = Tennessee Department of Environment and Conservation. 
October 2016 H-13 NUREG

–2176 

Appendix H 

Table H-1. (contd) 

Jurisdictional 

Agency 

Authority, Law, or 

Regulation 

Description of 

Requirement 

License/Permit 

and/or 

Applicability(a) 

Date of Application 

and/or Date Issued Activity Covered 

TP = Turkey Point. UIC = Underground Injection Control. USACE = U.S. Army Corps of Engineers. U.S.C. = United States Code. USEPA = U.S. Environmental Protection Agency. 

APPENDIX I 

THE EFFECT OF CLIMATE CHANGE ON THE 

EVALUATION OF ENVIRONMENTAL IMPACTS 

October 2016 I-1 NUREG–2176 

APPENDIX I 

THE EFFECT OF CLIMATE CHANGE ON THE 

EVALUATION OF ENVIRONMENTAL IMPACTS 

The review team has determined that it is reasonably foreseeable that climate change may 

substantially alter the affected environment described in Chapter 2 of this environmental impact 

statement (EIS). Climate change is a global phenomenon that the construction and operation of 

the proposed two-unit plant will not appreciably alter. However, climate change will provide a 

new environment that the operation of the proposed units will affect. 

The objective of this appendix is to document the review team’s consideration of the potential 

changes in impacts that may occur as a result of the new future environment. This appendix is 

not intended to be a comprehensive climate change assessment for the affected region. It 

documents the review team’s qualitative determination of the likely changes in the impacts 

described in Chapter 5, if the environment is altered in a manner consistent with the predictions 

in current climate change literature. 

The Nuclear Regulatory Commission staff documents the review of the safety of the plant in the 

Safety Evaluation Report (SER) expected to be published in November 2016 (NRC 2016-

TN4619). If the NRC grants the FPL COL application, the staff will inspect and otherwise 

moniter plant construction and operation. This 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 SECY-15-0137 (NRC 2015-

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. 

In this appendix, the review team assessed the potential effects of climate change on its 

evaluation of the environmental impacts of the proposed action. The results of this assessment 

are presented below in three sections: (1) description of the assessment process, (2) potential 

climate change impacts in the region, and (3) assessment summary. The appendix also 

discusses the USACE’s consideration of climate change in the context of the USACE Public 

Interest Review. 

I.1 Description of the Assessment Process 

As part of its National Environmental Policy Act (42 U.S.C. 4321 et seq.) (TN661) review, the 

U.S. Nuclear Regulatory Commission (NRC) staff analyzes greenhouse gas emissions and the 

potential effects of climate change for all resource areas in all new reactor licensing 

proceedings. In guidance dated August 1, 2016 on greenhouse gas emissions and climate 

change, the Council on Environmental Quality (CEQ) states “action agencies need not 

undertake new research or analysis of potential climate change impacts in the proposed action 

area, but may instead summarize and incorporate by reference the relevant scientific literature.” 
Appendix I 

NUREG–2176 I-2 October 2016 

In this regard, this EIS incorporates by reference the U.S. Global Change Research Program 

report (GCRP 2014-TN3472; CEQ 2016-TN4732).” 

In the first step of the NRC staff’s process a master table was created identifying plausible 

nexuses between nuclear power station resource area issues related to operation and likely 

climate change impacts as identified in the most recent climate change impacts report issued by 

the GCRP (2014-TN3472). The interagency GCRP was established under the Global Change 

Research Act of 1990 (P.L. 101-606) (15 U.S.C. § 2921 et seq.) (TN3330) “to understand, 

assess, predict, and respond to human-induced and natural processes of global change” and is 

the authoritative U.S. government source on likely climate change impacts in the United States. 

The master table was used to develop a list of questions for each resource area to assist the 

NRC staff in addressing whether GCRP-identified climate change impacts were likely to 

increase, decrease, or leave unchanged the assessed impact of a proposed facility on the 

environment, or to identify areas where scientific uncertainty precludes a definitive assessment. 

The comprehensive master table and question list can be found in the NRC’s Agencywide 

Documents Access and Management System (ADAMS), which is accessible from the NRC 

website at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room) under the 

following accession number ML5026A470 (NRC 2014-TN4149). A table, termed the sitespecific resource table, and list of questions specific to the proposed site of Turkey Point Units 6 

and 7 were then generated by removing non-relevant GCRP climate impacts and NRC resource 

area issues, and by using specific Southeast regional predictions identified by the GCRP. For 

example, the review team determined GCRP-identified direct impacts related to declining ice 

volume and extent were not relevant to the Turkey Point environment. The review team used 

the site-specific resource table and question list (NRC 2014-TN4150) in its assessment of the 

effects of climate change on relevant resource areas given in Section I.3. A combined 

construction permit and operating license (COL) is valid for 40 years (10 CFR 52.103) (TN251). 

In conducting its assessment, the NRC staff noted that if COLs are granted to the proposed 

facilities, baseline changes are more likely to be noticeable during operation (Chapter 5) than 

during preconstruction and construction (Chapter 4). The review team’s efforts thus focused on 

assessing the potential effects of climate change on the resource area impact levels assigned in 

Chapter 5. While general scientific consensus exists that climate change is occurring and will 

continue to occur for the foreseeable future, significant uncertainty remains about the magnitude 

of the changes for specific regions and the precise magnitude and form of the impacts on the 

environment from climate change. The review team acknowledges this situation, explicitly 

noting in this appendix where uncertainty in future climate predictions and uncertainty in impacts 

may make it impossible at this time to conclude qualitatively the influence of climate change on 

a specific resource area or issue. The review team also acknowledges that the Southeast 

Florida Regional Climate Change Compact, which includes Miami-Dade County, has 

established a Regional Climate Action Plan that discusses goals to reduce greenhouse gas 

emissions and adapt to regional and local impacts of a changing climate. Some of the climate 

change impacts discussed in this appendix could be further reduced with the efforts of this 

Regional Compact. 

I.2 Potential Climate Change Impacts in the Region 

Climate change is a subject of national and international interest. The recent compilation of the 

state of knowledge in this area—GCRP’s climate change impacts report (GCRP 2014-
Appendix I 

October 2016 I-3 NUREG–2176 

TN3472)—has been considered in the preparation of this EIS. Most GCRP projections are 

expressed as a change expected for the later part of the 21st century (2071−2099) relative to 

average conditions existing in the later part of the 20th century (1970−1999). Projected 

changes are also dependent on future emissions of heat-trapping gases. The GCRP’s climate 

change impacts report includes projections for wide-ranging scenarios where such emissions 

are rapidly reduced and where they continue to increase. 

Florida Power & Light Company (FPL) has indicated that, if the COLs are granted, it expects to 

initiate commercial operations in the second quarter of 2027 and second quarter of 2028 for 

Units 6 and 7, respectively (FPL 2015-TN4502). The Atomic Energy Act (42 U.S.C. § 2011 et 

seq.) (TN663) and NRC regulations (10 CFR 52.103) (TN251) limit commercial power reactor 

licenses to an initial 40 years. If granted, under FPL’s proposed schedule the COLs would be 

valid until 2067 and 2068. The NRC staff 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. Unless 

otherwise stated, projected climate changes discussed in this section are taken from the 

impacts report (GCRP 2014-TN3472) and refer to changes for the 2071−2099 period relative to 

the 1970−1999 period under an increasing emissions scenario. 

Projected changes in the climate for southeastern Florida include an increase in average 

surface air temperature of 5°F to 6°F. The number of days with maximum temperatures above 

95°F is expected to increase, rising by 50 or more days per year for the 2041−2070 period 

relative to 1971−2000. The hottest and coldest days expected in a 20-year period at the end of 

this century (2081−2100) are both projected to be 6°F to 7°F warmer than those experienced at 

the turn of the last century (1986−2005); in other words, both the hottest and the coldest days 

will be warmer. Southeastern Florida is projected to experience no days with temperatures 

below 32°F during the 2070−2099 period; currently, the low-temperature extreme for the 

proposed Turkey Point site is 25°F (Section 2.9.1.2). Projected precipitation changes in 

southeastern Florida vary seasonally, increasing by 0 percent−10 percent in winter, decreasing 

by 0 percent−10 percent in spring, decreasing by 20 percent−30 percent in summer, and 

increasing by 10 percent−20 percent in fall. Extreme heavy precipitation events are expected to 

increase in both frequency and intensity; 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. The climate 

change impacts report indicates that the number of tropical storms occurring around the globe 

will decrease, but 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). 

Sea level is projected to rise 1 to 4 ft globally by 2100 (GCRP 2014-TN3472). However, the 

review team acknowledges that, at the extreme high end, global sea level is predicted to rise by 

8.2 ft by 2100 relative to 2000. Should this extreme high range of sea level rise occur, much of 

South Florida would be uninhabitable and millions of people would likely be displaced. Sea 

level rise, however, occurs gradually, so that adaptation is possible. As explained in the 
Appendix I 

NUREG–2176 I-4 October 2016 

impacts report, the amount of sea-level rise experienced in any one location “depends on 

whether and how much the local land is sinking...or rising, and changes in offshore currents.” 

In its report, the GCRP 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.” 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. The GCRP cites the Southeast 

Florida Regional Compact as an “excellent example” of regional cooperative efforts among 

local, state, and federal agencies to develop “a comprehensive action plan” to adapt to impacts 

from climate change and sea-level rise. 

The NRC staff also considered localized sea level rise associated with changes in regional 

ocean currents (Ezer et al. 2013-TN4734; Park and Sweet 2015-TN4733). The NRC staff 

determined that these localized changes were adequately bounded by the 1 to 4 ft sea level rise 

projected in the GCRP report. 

The Southeast region currently contains “...existing power plant capacity to produce 32 percent 

of the nation’s electricity,” but also currently consumes 27 percent of the nation’s total capacity, 

more than any other GCRP-defined region. Higher temperatures and increased use of air 

conditioning are projected to increase regional energy demand, “potentially stress[ing] electricity 

generating capacity, distribution infrastructure, and energy costs” (GCRP 2014-TN3472). 

Other climate change impacts in the Southeast region identified in the GCRP report and 

relevant to the Turkey Point area include ecosystem exposure to risks from sea-level rise, 

particularly in tidal marshes, swamps, and wetlands; compromised protection of coastal lands 

and people against storm surge due to tidal wetland loss; effects on fisheries and fishery 

habitats due to wetland loss; spread of non-native plants; decreased crop production and 

livestock yield; increased formation of allergens and air pollutants, including ozone; and 

increases in harmful algal blooms and other surface-waterborne disease-causing agents. In 

addition, the GCRP indicates the potential for ocean warming leading to changes in local 

species composition, growth rates, spawning seasons, and/or migratory patterns; increased 

wildfire frequency, intensity, and size; effects on vector-borne and zoonotic (animal to human) 

disease transmission; increased insurance costs or unavailability of insurance coverage due to 

increased flooding incidents; stresses on society and infrastructure due to movement of people 

from vulnerable areas; effects of changes in energy costs on lower income households, the 

elderly, native tribes, and other vulnerable communities; and damage to transportation 

infrastructure. 

I.3 Assessment Summary 

This section summarizes the review team’s assessment of the effects of climate change on 

relevant resource areas using the process outlined in Section I.1. 
Appendix I 

October 2016 I-5 NUREG–2176 

I.3.1 Land Use 

I.3.1.1 Land-Use Summary 

Climatological changes are not likely to influence, or lead to, any plant operational impacts on 

local/regional land-use classifications or economic development plans. 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. However, once the operational 

workforce is housed in the initial years of operation, operation of a reactor is not expected to 

alter land use. Therefore, there is little potential for interaction between land-use changes 

resulting from climate change and land-use changes caused by later operational years of the 

reactor. 

I.3.1.2 Land-Use Conclusion 

Climatological changes are not expected to affect the land-use operational impact level 

assigned in Chapter 5. 

I.3.2 Hydrology 

I.3.2.1 Summary 

Climatological changes are not expected to affect the anticipated hydrologic alterations resulting 

from station operation, or influence (or lead to) plant operations impacts on other water uses 

and users. Sea-level rise will result in greater depth of Biscayne Bay near the Turkey Point site. 

Because of the current very shallow conditions of Biscayne Bay in this vicinity even a modest 

increase in sea level may help to improve circulation (reducing the hypersalinity of water 

entering the radial collector well system). Circulation is also controlled by flow conditions away 

from the site. The review team presumed that the cooling canals’ water-surface elevation would 

likely also rise in response to the rise in sea level. This rise would increase the volume of water 

in the canals, but it is not expected to appreciably change the gradient between Biscayne Bay 

and the cooling canals. Therefore, no change in the interface between the canals and the Bay 

is expected. 

Sea-level rise will also push the freshwater–seawater interface further inland. This will put 

further stresses on freshwater resources inland. However, because the proposed Units 6 and 7 

would use reclaimed wastewater for most of its water needs, this would not alter the impact of 

the plant. Groundwater modeling analyses performed by the NRC staff explicitly considered the 

changes in impacts of operation of the radial collector wells that would occur with reduced 

inland recharge (e.g. drought) and increased sea level (see Appendix G.3). While saltwater 

intrusion is shown to move farther inland under both of these scenarios, the radial collector wells 

are shown to not have contributed to the saltwater intrusion. 

Sea-level rise combined with more frequent Category 4 and 5 storms will increase the potential 

for damaging storm surge events at the Turkey Point site (Little et al. 2015-TN4729). The final 

SER discusses the safety of the proposed plants in regard to natural flooding hazards, including 

hazards from extreme hurricanes combined with other factors such as sea level rise. An 

extreme natural flood at the site, however, could damage features at the site, including the IWF 
Appendix I 

NUREG–2176 I-6 October 2016 

for the existing units, piles of spoils from muck removal for the construction of the proposed 

units, and non-safety related structures built for the proposed units. While storm surge damage 

to these features would result in the release of sediment and nutrients to Biscayne Bay, such 

damage would not be localized to the Turkey Point site. The contribution of the Turkey Point 

site to the release of sediment and nutrients to Biscayne Bay as result of an extreme flood 

would likely be a small fraction of the total sediment and nutrient load that would enter the local 

waterways.

As discussed in Section I.2, precipitation amounts in South Florida are projected to shift in 

different directions in different seasons. Even if total precipitation increases, if the majority of 

this increase is in response to intense storms it would not result in a proportional increase in 

recharge to groundwater. The increase in temperature may also increase evapotranspiration, 

thereby further reducing recharge. The review team determined that overall recharge to the 

Biscayne Bay aquifer may be reduced as a result of climate change. However, because the 

proposed plant would use reclaimed wastewater for most of its water needs, this would not alter 

the plant’s impact on the environment. 

The review team could not determine whether an increase in temperature or changes in 

precipitation patterns would result in any change in the supply of wastewater for the plant’s 

cooling system. A substantial increase in sea level rise, however, could impact the wastewater 

treatment plant that provides the primary source of cooling water for proposed Units 6 and 7. 

Given the abundance of wastewater in this region, the review team determined that a sufficient 

supply of wastewater would remain available regionally. In the event of substantial sea level 

rise, Miami Dade County may adapt some of its wastewater treatment infrastructure. Given the 

critical public health role of these facilities, the review team determined that such adaptations 

are reasonably foreseeable. 

I.3.2.2 Conclusion 

The review team identified no shift in the Chapter 5-assigned impacts on water use and water 

quality caused by the operation of the proposed plant due to a reasonably foreseeable alteration 

in the environmental baseline associated with climate change. 

I.3.3 Terrestrial & Wetland Ecology 

I.3.3.1 Summary 

Climatological changes could affect the impact of plant operations from facility and landscape 

maintenance, noise, and traffic on terrestrial habitats and wildlife. In particular, climate change 

could increase stress on terrestrial habitats, especially the freshwater and brackish water 

wetlands comprising the Everglades, the mangrove wetlands adjoining Biscayne Bay, and the 

tree islands and remnant patches of pine rocklands that dot the surrounding landscape. Climate 

change could result in longer periods between precipitation events, drier conditions during some 

seasons, and more frequent wildfires that could facilitate introduction of new diseases and 

pests. Sea-level rise could stress mangrove forests due to inundation and could stress 

surviving wetland vegetation by introducing brackish water farther inland, while the expected 

tendency to armor fastlands could prevent concurrent establishment of more inland mangrove 
Appendix I 

October 2016 I-7 NUREG–2176 

forests and other coastal wetlands. Climate change would place additional stress on the same 

habitats and wildlife affected by the operational impacts discussed in Section 5.3.1. Particularly 

noteworthy is that the stresses on wetlands and other terrestrial habitats caused by climate 

change could result in greater introduction of exotic species such as Melaleuca, Australian pine, 

and the Burmese python. 

The expected climatological changes could exacerbate the effects of plant operations 

(discussed in Section 5.3.1) on terrestrial habitats, wetlands, and species. In particular, climate 

change could lead to drier conditions due to longer periods between precipitation events and 

wildfires. Climate change could reduce the extent of mangrove forests primarily due to coastal 

inundation and sawgrass in the Everglades primarily due to alteration of hydroperiod, stressing 

vegetation and wildlife. Increased introduction of exotic species could further reduce the 

ecological and hydrological function of wetlands and reduce the suitability of various upland and 

wetland habitats to threatened, endangered, and rare species. 

The expected climatological changes could worsen the minor effects of plant and transmission 

line operations on birds, bats, and other wildlife due to collisions, electrocution, or 

electromagnetic radiation effects (discussed in Section 5.3.1). Climate change could 

substantially alter the hydroperiod of habitats traversed by the proposed corridors for the two 

transmission lines, including the eastern Everglades and remnant pine rockland patches. These 

changes could stress wildlife dependent on the affected habitats, including birds, bats, and other 

wildlife. Even though the effects on wildlife from collisions, electrocution, and electromagnetic 

radiation are typically minor (see Section 5.3.1), the stresses could be exacerbated when 

combined with the effects of climate change. 

Although climate change could potentially interact synergistically with plant operations to raise 

impact levels on terrestrial wildlife from plant operations and influence the impact of the 

proposed units on terrestrial resources and wetlands, the ability to coordinate with other 

agencies should not be noticeably impeded. The importance of close coordination would, 

however, be greater. 

The expected climatological changes could affect the overall impact of plant operations on 

regional standing stocks of important terrestrial species, including plant impacts on species’ 

tolerance of environmental changes and their natural survival rates. The increased potential for 

substantial adverse effects on the sensitive wetland and upland habitats surrounding the Turkey 

Point site and proposed new offsite corridors would concurrently place increased stresses on 

species using those habitats, including important species. The increased stresses caused by 

climate change could reduce the tolerance of some important species to collisions, noise, and 

other plant operational impacts. Furthermore, many of the identified important species are 

species whose populations have already been severely lowered by recent decades of drainage 

and development, and thus are less capable of recovery from new stresses. 

The stresses placed on terrestrial habitats by climate change could lead to a greater potential 

for introduction of disease organisms and invasive species. Climate change could stress those 

habitats by decreasing the hydroperiod and by inducing the introduction of exotic species 

adapted to warmer climates and seasonally drier habitats. The subject habitats have already 
Appendix I 

NUREG–2176 I-8 October 2016 

been stressed by a history of introduction of numerous invasive species. Additional stresses to 

native vegetation can be expected to encourage the further establishment of invasive species. 

I.3.3.2 Conclusion 

Climate change could place multiple new stresses on wetlands and other terrestrial habitats, 

especially the hydrologically sensitive Everglades and Everglades National Park, the extensive 

mangrove forests bordering Biscayne Bay, including those within Biscayne National Park, and 

other unique ecological communities such as pine rocklands. Climate change would place 

additional stress on the same habitats and wildlife stressed by plant operations and could cause 

an increase in the impacts on terrestrial resources discussed in Section 5.3.1. 

I.3.4 Aquatic Ecology 

I.3.4.1 Summary 

Climatological changes would have minimal influence on the impact of the operation of 

proposed Units 6 and 7 on aquatic resources using either reclaimed water or radial collector 

wells. A change in sea level would not influence the availability of reclaimed water, so an 

increase of cooling-water withdrawal by the radial wells is not expected. Sea-level rise will 

increase the depth of Biscayne Bay but it is not expected to affect the operation of the radial 

wells. Entrainment, entrapment, and impingement are highly unlikely due to the use of 

reclaimed water and RCW operation, and there is no evidence operation would directly affect 

aquatic resources. There is no evidence that proposed Units 6 and 7 would affect species 

tolerance or natural survival rates, or contribute to an increase in invasive or introduced species. 

Given the proposed cooling-system configurations, influence on the water quality of nearby 

receiving water would be negligible. Changes in baseline conditions due to climate change are 

not expected to alter this result. Climate change is not expected to noticeably impede the ability 

of agencies to coordinate on the protection of aquatic species. The importance of close 

coordination would, however, be greater.

I.3.4.2 Conclusion 

The review team identified no shift in the Chapter 5-assigned impacts on aquatic ecology 

caused by the operation of the proposed plant due to a reasonably foreseeable alteration of 

baseline conditions associated with climate change. 

I.3.5 Socioeconomics 

As discussed in Section 5.4 and summarized in Section 10.2.2, within the area of 

socioeconomics the categories of physical impacts, demographic impacts, economic impacts, 

and impacts on infrastructure and community services are assessed separately, and individual 

category impact levels are assigned. These same categories are discussed here. 

I.3.5.1 Summary 

The review team determined that all of the expected physical impacts during operations (noise, 

air quality, buildings, roads, waterways, and aesthetics) would be SMALL and would warrant no 
Appendix I 

October 2016 I-9 NUREG–2176 

mitigation. During the life of the proposed license the review team expects physical impacts on 

the listed categories would not be exacerbated by the effects of climate change and would 

remain at negligible levels. 

The impacts on the demographic makeup of the area surrounding the proposed site would be 

SMALL and would not warrant mitigation. If the speculated climate change impacts were to 

occur during the life of the proposed license, the review team believes the demographic impact 

would be an out-migration of residents to other areas with higher elevations. Consequently, the 

operations-related impacts on the demographic makeup of the area would be reduced even 

further. 

All economic impacts from operations of the proposed project would be beneficial and SMALL 

for Miami-Dade County, Homestead, and Florida City. In the event of climate change-induced 

sea-level rise, which is likely to occur gradually, the NRC requires licensees of nuclear power 

plants to implement corrective actions to mitigate conditions adverse to safety. The applicant 

would need to take measures to mitigate the effects of global climate change such that the 

proposed nuclear power plants would continue to be operated safely in accordance with 10 CFR 

Part 50 (TN249). Therefore, the review team anticipates the economic impacts of operations of 

the proposed project would continue unchanged. 

There are four major subsections in the review team’s assessment of the operations-related 

impacts on infrastructure and community services from the proposed project: traffic, recreation, 

housing, and public services. 

 Traffic. The review team determined that the operations-related impacts of traffic would be 

moderate. While the long-term effects of global climate change would have a deleterious 

impact on the current level of infrastructure in the area, the review team believes it is not 

unreasonable to expect decision makers in the area to incrementally adapt to the climate 

change effects (e.g., sea-level rise) by incorporating mitigating measures that would prevent 

the deterioration of infrastructure services (e.g., raising the elevation of roads). Such 

adaptive measures would impose significant costs on local communities, the funds for which 

would either have to come from increased revenues (taxes and tolls) or be diverted from 

other expenses (maintenance, personnel, services). Consequently, the review team 

expects that if the physical changes predicted by the GCRP report (GCRP 2014-TN3472) 

were to occur, the traffic-related impacts on the local communities would increase. 

 Recreation. The primary receptors of recreational impacts due to operations are 

accessibility and aesthetics. The review team expects that, like traffic, the long-term effects 

of climate change would significantly change the aesthetic appeal of local recreation areas 

and the public’s access to Biscayne Bay and the Everglades. However, the NRC portion of 

the total impact would remain unchanged. 

 Housing. The review team expects that any physical change in the environment from 

global climate change would occur at a rate slow enough that home owners in low-lying 

areas could either adapt their homes to the new conditions or to move out of the area. 

Consequently, the cumulative impact of global climate change on housing in the economic 

impact area would decline as the local population migrated away from the 50 mi region. 
Appendix I 

NUREG–2176 I-10 October 2016 

 Public Services. The review team expects that any physical change in the environment 

from global climate change would occur at a rate slow enough that local governments could 

adapt to whatever negative impacts may arise. Consequently, the review team determined 

the global climate change impacts on community services would decline as the population 

migrated away from the 50 mi region. 

I.3.5.2 Conclusion 

As indicated in Chapter 5, the review team identified no significant shifts in socioeconomic 

impacts of operational impacts as a result of possible climatological changes in the 

environmental baseline. Potential impacts on socioeconomics including infrastructure and 

community services as a result of climate change would continue to be addressed through 

regional and local governmental strategic adaptive plans. 

I.3.6 Environmental Justice 

I.3.6.1 Summary 

Climate change could present challenges to minority and low-income communities, which the 

GCRP climate change impacts report refers to as “socially vulnerable populations,” within the 

demographic region of the proposed project. The challenges include coping with climate 

change effects (e.g., sea-level rise), the capacity to adapt, and the ability to relocate. The 

review team believes it is not unreasonable to expect decision makers in the area to 

incrementally adapt to the climate change effects by implementing strategic adaptation plans 

and mitigating measures that would inform and assist minority and low-income communities. 

Therefore, the conclusions in Section 5.1.1 regarding environmental justice would remain 

unchanged. 

I.3.6.2 Conclusion 

Overall, the operational impact levels assigned to environmental justice in Chapter 5 did not 

change as a result of possible climatological changes in the environmental baseline. Potential 

impacts on environmental justice communities as a result of climate change would continue to 

be addressed through regional and local governmental strategic adaptive plans. 

I.3.7 Historic and Cultural Resources 

I.3.7.1 Summary 

There are no known onsite historic and cultural resources at the Turkey Point site; therefore, 

there would be no shift in the impacts on historic and cultural resources caused by the operation 

and maintenance of the proposed plant due to a reasonably foreseeable alteration in the 

environmental baseline associated with climate change. It is not known whether the change in 

the environmental baseline would cause a shift in impacts of offsite facilities (e.g., transmission 

lines). 
Appendix I 

October 2016 I-11 NUREG–2176 

I.3.7.2 Conclusion 

As previously discussed, the climatological changes would not affect the historic and cultural 

impact level assigned in Chapter 5 because of the lack of resources at the Turkey Point site. 

It is not known whether the change in the environmental baseline would affect offsite resources. 

I.3.8 Meteorology 

I.3.8.1 Summary 

The expected climatological changes would largely be unlikely to affect cooling-system impacts 

from the operating plant on local weather. Projected temperature increases due to climate 

change may lead to an increase in fogging from the cooling tower. Changes in severe weather 

intensity or length of dry spells would be unlikely to change the current parameters. 

I.3.8.2 Conclusion 

Operational impacts from the cooling system on local weather are discussed in Section 5.7.2 

and should not change as a result of reasonably foreseeable climate changes. 

I.3.9 Air Quality 

I.3.9.1 Summary 

Climatological changes may affect the sources, types, and estimates of annual air emissions 

from the operating plant and transmission lines. For example, changes in climate such as sealevel rise and increased extreme weather events may lead to an increase in air emissions from 

emergency equipment, if additional emergency backup equipment is needed for the proposed 

plants and if testing of that equipment increases. Because of expected increases in 

temperature over the period of operation, the health impacts of operational air emissions may 

increase. In a higher temperature environment, the formation of ozone due to emissions of 

nitrogen oxides (NOx) from the diesel generators and other equipment is likely to increase, 

thereby leading to an increase in health impacts. 

I.3.9.2 Conclusion 

Operational air-quality impacts are discussed in Section 5.7.1 and should not change as a result 

of reasonably foreseeable climate changes. It is unclear whether additional emergency 

equipment would actually be needed in a changing climate, or whether testing of that equipment 

would increase, causing an increase in air emissions. Any additional equipment would be 

subject to Clean Air Act (42 U.S.C. § 7401 et seq. (TN1141) Title V permitting requirements. 

Estimates of air emissions are likely to remain the same, with a possible increase in health 

impacts due to increased ozone formation from emergency equipment NOx emissions in a 

higher temperature environment. 
Appendix I 

NUREG–2176 I-12 October 2016 

I.3.10 Nonradiological Health 

I.3.10.1 Summary 

It is not known how changes in climate will affect the presence of etiological agents associated 

with plant operations (receiving waters and cooling-tower operations). However, it is reasonable 

to expect that currently existing laws and regulations protecting workers and members of the 

public would continue, or would be adjusted as necessary, to be as protective as they are under 

current climate conditions. 

Climatological changes are not likely to have an effect on noise produced by operating plants; 

therefore, there would be no change in the health impacts from noise discussed in Section 

5.8.2. 

It is not likely that climatological changes would affect potential health impacts from 

electromagnetic fields (EMFs) associated with plant operations because regulations protecting 

workers and members of the public from EMFs would likely be adjusted to avoid impacts. 

It is not likely that climatological changes would affect occupational health risks for operational 

plants because regulations protecting workers would be adjusted to avoid impacts on workers. 

As discussed in Section I.3.5.1, while the long-term effects of global climate change would have 

a deleterious impact on the current level of infrastructure in the area, the review team believes it 

is not unreasonable to expect decision makers in the area would incrementally adapt to the 

climate change effects (e.g., sea-level rise) by incorporating mitigating measures that would 

prevent the deterioration of infrastructure services (e.g., raising the elevation of roads, adjusting 

speed limits). The review team expects that if the physical changes predicted by the GCRP 

were to occur, such adaptive measures would limit potential health impacts from traffic-related 

accidents. 

I.3.10.2 Conclusion 

Overall, the expected climatological changes would not change the nonradiological health 

resource operational impact level assigned in Chapter 5. Potential impacts from noise, 

etiological agents, exposure to EMFs, and occupational injuries are and would continue to be 

regulated to be protective of human health. Although there is some uncertainty surrounding 

predicted climatological changes, it is likely that regulations governing occupational and public 

health would be adjusted accordingly if needed. 

I.3.11 Radiological Impacts 

I.3.11.1 Summary 

The review team determined that the expected climatological changes would affect the 

possibility of exposure to radiation from the operating facility as follows: 

 Existing low population exposures of humans from proposed Units 6 and 7 would remain 

low because the level of effluent releases and regulatory requirements should not 

significantly change over the time of the license. 
Appendix I 

October 2016 I-13 NUREG–2176 

 Existing low non-human biota exposures from proposed Units 6 and 7 should not change 

because the level of effluent releases and regulatory requirements should not significantly 

change over the time of the license. 

 The level of effluent releases, regulatory requirements (including those for occupational 

doses), and existing low exposures should not significantly change over the time of the 

license. 

 The level of the expected normal radioactive gaseous effluent releases would remain the 

same. Thus, monitoring activity should remain the same with the exception that the 

monitoring locations could change because of changes in the physical land and population 

distribution around the site. Normal radioactive liquid effluent releases should remain 

unchanged due to the use of deep-well injection. 

I.3.11.2 Conclusion 

The NRC staff identified no shift in the radiological impacts level caused by the operation of the 

proposed Units 6 and 7 due to reasonably foreseeable environmental alterations associated 

with climate change, because the level of effluent releases, regulatory requirements, and 

existing low population exposures should not significantly change over the time of the license. 

I.3.12 Nonradioactive Waste 

I.3.12.1 Summary 

Sea-level rise and changes in land-use decisions may lead to changes in disposal options for 

nonradioactive waste and mixed wastes. However, solid, liquid, gaseous, hazardous, and 

mixed wastes generated during operation of the proposed Turkey Point Units 6 and 7 would still 

have to be handled, transported, stored, and disposed of according to County, State, and 

Federal regulations. 

I.3.12.2 Conclusion 

Because nonradioactive and mixed wastes would still be subject to applicable Federal, State, 

and local requirements, climatological changes are unlikely to influence the SMALL impact 

determination discussed in Section 5.10.4. 

I.3.13 Accidents 

I.3.13.1 Summary 

Climatological changes are expected to affect the site-specific, 50th percentile atmospheric 

dilution factor (i.e., /Q) used to evaluate dose consequences from postulated design basis 

accidents (DBAs). The /Q around the site is dependent on local meteorological conditions 

(wind speed, direction and stability class). The expected variations for these parameters as a 

result of climate change may increase, likely leading to less stability, which would likely increase 

dispersion and decrease the corresponding radiological effects. However, the predominant 

wind direction could change such that higher /Qs could shift along the site boundary, lowpopulation zone, and beyond to areas with higher population density, which would increase the 
Appendix I 

NUREG–2176 I-14 October 2016 

impact. Therefore, the overall impact is unknown. 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. 

As discussed in Section I.2, climate change in general and rising sea level are expected to be 

gradual. If the NRC grants the FPL COL application, the staff will inspect and otherwise moniter 

plant construction and operation. This 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 SECY-15-0137 (NRC 2015-

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. In particular, the NRC can request information from a licensee under 10 

CFR 50.54(f), and can determine whether or not a license should be modified based on the 

information provided in response the request. Such information could include the impact of 

climate change on plant operation, 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. The NRC 

staff generally expects that the low core damage frequencies (CDFs) for the AP1000 

pressurized water reactor design are unlikely to change appreciably due to climate change. 

Therefore, even if consequences of severe accidents slightly change as a result of climate 

change, severe accident risk is likely to remain SMALL because CDFs are maintained low. 

The effects of climatological changes on the severe accident mitigation alternative (SAMA) costbenefit analysis of the proposed facility are uncertain. While the averted costs have 

components that are based on local land values and the cost of evacuation and cleanup, these 

are typically not the major contributors to the total averted costs. Rather, the cost of 

replacement power has a larger effect and it is uncertain whether climate change would have an 

effect that would change the SAMA cost-benefit analysis. However, because the smallest 

difference between a cost-beneficial severe accident mitigation design alternative that was not 

studied further for the AP1000 design at the Turkey Point site (see Section 5.11.3) and the 

averted cost is approximately $400,000 (7 percent discount rate), it is difficult to see how climate 

change would affect the probability-weighted consequences from severe accidents in a manner 

to cause a finding different from SMALL for SAMAs. 

I.3.13.2 Conclusion 

The impact level assigned in Chapter 5 should remain SMALL for next-generation nuclear 

power plants like the AP1000 reactor design. The overall risks for severe accidents are 

significantly lower than the current generation of nuclear power plants and any climate change 

effect would have to change the risks by at least two orders of magnitude to result in a change 

in the impact level assigned in Chapter 5. 
Appendix I 

October 2016 I-15 NUREG–2176 

I.3.14 Transportation of Radiological Materials 

I.3.14.1 Summary 

The number and type of radioactive material shipments, regulatory requirements, and existing 

low maximally exposed individual and population exposures and risks from accidents for these 

types of shipments should not significantly change over the time of the license as a result of 

climate change. Radiological doses are strong functions of the radiation dose rate emitted from 

the shipment, exposure distance, and exposure duration. None of these parameters would be 

directly or disproportionately influenced by the impacts of climate change. Transportation 

accidents risks are a function of weather conditions. However, climate change may increase 

dispersion conditions in some areas as a result of more frequent storms and severe weather, 

but may also reduce dispersion in areas where climate change may result in more mild average 

conditions. As a result, the changes in transportation impacts potentially caused by climate 

change are not expected to be significant, but there are substantial uncertainties about impacts 

on weather conditions in specific areas and demographic changes that could affect 

transportation impacts in the region of interest. 

I.3.14.2 Conclusion 

Impact levels are not expected to change as a result of the effects of climate change, but there 

are significant uncertainties associated with the impacts of climate change on local weather 

conditions and demographics. 

I.3.15 Benefit-Cost 

I.3.15.1 Summary 

Climatological changes could affect the estimated operational benefits and costs of the 

proposed facility. Proposed Turkey Point Units 6 and 7 would continue to provide benefits in the 

form of electricity generation and economic impacts to the region such as tax impacts and other 

spending. To the extent that summer peak demand load increases, the benefit of a large 

baseload power station such as Units 6 and 7 could increase. 

Operating costs include maintenance costs, fuel costs, and annualized capital costs. Future 

climate change impacts would not affect the already incurred capital costs. However, to the 

extent that climate change events require repair or prolonged shutdown of Units 6 and 7, 

maintenance costs could increase. 

I.3.15.2 Conclusion 

Although climate change could increase or decrease the benefits and costs of the project, the 

review team expects the accrued benefits of construction and operation of Units 6 and 7 would 

still outweigh the associated costs. 
Appendix I 

NUREG–2176 I-16 October 2016 

I.3.16 U.S. Army Corps of Engineers Public Interest Review 

I.3.16.1 Summary 

Pursuant to NEPA and the USACE public interest review at 33 CFR 320.4, the USACE 

considers the effects of climate change and sea level rise on the proposed project in order to 

determine whether the proposed project is contrary to the public interest. As set forth below, the 

USACE has determined that the NRC Advanced Safety Evaluation (ASE) dated July 14, 2016, 

on the Florida Power & Light (FPL) application to the NRC considers the effects of sea level rise 

on the proposed project (NRC 2016-TN4775). 

As background, the NRC determined that the structures, systems, components, and design 

features of the AP1000 standard design comply with applicable NRC regulations and therefore 

provide adequate protection to the health and safety of the public. The NRC based its 

evaluation of the AP1000 design in part on assumed physical and environmental site features, 

such as maximum flood height compared to plant elevation, used to design the standard plant. 

The NRC calls these site features assumed for design “site parameters,” and they are specified 

in the Design Control Document (DCD) for the AP1000 standard design. In order for a company 

to obtain an NRC license to build and operate an AP1000 plant at an actual site, its application 

must show that the AP1000 design can handle the actual physical and environmental features 

of the proposed site, which the NRC calls “site characteristics.” To do this, the applicant 

compares the actual site characteristics to the site parameters postulated for design. If the site 

characteristics fall within the site parameters used to design the plant, then the standard 

AP1000 design protects the plant from the effects of the environment on the plant at that site, as 

required by NRC regulations. If a site characteristic does not fall within a site parameter, the 

applicant must provide engineering analysis to justify why the plant is nevertheless acceptable 

to build and operate on the proposed site. 

For the proposed Turkey Point Units 6 and 7 reactors, the FPL application to the NRC included 

information to demonstrate that the actual Turkey Point site characteristics fall within the site 

parameters in the AP1000 DCD, except for four site parameters. For these four site 

parameters, FPL proposed departures from the AP1000 DCD, as allowed under NRC 

regulations. The four site parameters for which FPL proposed departures are population 

distribution exclusion area (site), the operating basis wind speed, maximum safety wet-bulb 

(non-coincident) air temperature value, and maximum normal wet-bulb (non-coincident) air 

temperature value. The NRC staff evaluation of the application in the ASE for Turkey Point 

Units 6 and 7 concludes that the applicant (1) justified the four proposed departures from the 

DCD site parameters and (2) demonstrated that the other characteristics of the Turkey Point site 

fall within (are bounded by) the site parameters specified in the AP1000 DCD (NRC 2016-

TN4775). 

In assessing whether the actual site characteristics fall within the postulated site parameters in 

the DCD, both the application and the NRC ASE consider the effects of sea-level rise. In 

particular, the NRC staff evaluations in the ASE Sections 2.3.1.4.7, “Climate Change,” 2.4.5.4.4, 

“Antecedent Water Level,” 2.4.5.4.5, “Analysis of Probable Maximum Storm Surge,” 2.4.5.4.6, 

“Wave Actions,” 2.4.6.4.3, “Source Generator Characteristics,” 2.4.6.4.5, “Tsunami Water 

Levels,” and 2.4.9.4.3, “Shoreline Changes” explicitly consider the effects of sea-level rise in 
Appendix I 

October 2016 I-17 NUREG–2176 

connection with the NRC staff evaluation of the Turkey Point site characteristics. While the 

NRC staff did not explicitly consider sea level rise in its evaluation in ASE Section 2.4.12.4.12, 

“Site Characteristics for Subsurface Hydrostatic Loading,” the NRC staff determined that the 

actual groundwater level was at least twenty (20) feet below the maximum allowable 

groundwater level specified in the DCD for the AP1000 design, and that no further evaluation 

was warranted (NRC 2016-TN4775). 

I.3.16.2 Conclusion 

In view of the foregoing, the USACE has determined that the NRC staff has evaluated the 

effects of sea level rise on the proposed Turkey Point Units 6 and 7 in the context of its flooding 

evaluations in the ASE. 

I.4 References 

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of 

Production and Utilization Facilities." Washington, D.C. TN249. 

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, "Licenses, 

Certifications, and Approvals for Nuclear Power Plants." Washington, D.C. TN251. 

15 U.S.C. § 2921 et seq. Global Change Research Act of 1990. TN3330. 

42 U.S.C. § 2011 et seq. Atomic Energy Act of 1954. TN663. 

42 U.S.C. § 4321 et seq. National Environmental Policy Act (NEPA) of 1969, as amended. 

TN661. 

42 U.S.C. § 7401 et seq. Clean Air Act. TN1141. 

CEQ (Council on Environmental Quality). 2016. Memorandum from C. Goldfuss to Heads of 

Federal Departments and Agencies, dated August 1, 2016, regarding "Final Guidance for 

Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the 

Effects of Climate Change in National Environmental Policy Act Reviews." Washington, D.C. 

Accession No. ML16266A244. TN4732. 

Ezer, T. L.P. Atkinson, W.B. Corlett, and J.L. Blanco. 2013. "Gulf Stream's Induced Sea Level 

Rise and Variability Along the U.S. Mid-Atlantic Coast." Journal of Geophysical Research: 

Oceans 118:685–697, Malden, Massachusetts. TN4734. 

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). 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. 
Appendix I 

NUREG–2176 I-18 October 2016 

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. 

Little, C.M., R.M. Horton, R.E. Kopp, M. Oppenheimer, G.A. Vecchi, and G. Villarini. 2015. 

"Joint Projections of U.S. East Coast Sea Level and Storm Surge." Nature Climate Change 

5:1114–1121, London, United Kingdom. TN4729. 

NRC (U.S. Nuclear Regulatory Commission). 2014. "Climate Change Master Table." 

Washington, D.C. Accession No. ML5026A470. TN4149. 

NRC (U.S. Nuclear Regulatory Commission). 2014. "Climate Change Table Specific to Turkey 

Point." Washington, D.C. Accession No. ML15026A471. TN4150. 

NRC (U.S. Nuclear Regulatory Commission). 2015. Proposed Plans for Resolving Open 

Fukushima Tier 2 and 3 Recommendations. SECY-15-0137, Washington, D.C. Accession No. 

ML15254A006. TN4731. 

NRC (U.S. Nuclear Regulatory Commission). 2016. Letter from F.M. Akstulewicz to FPL, dated 

May 13, 2016, regarding "Turkey Point Units 6 and 7 Combined License Application Review 

Schedule Update." Washington, D.C. Accession No. ML16117A553. TN4619. 

NRC (U.S. Nuclear Regulatory Commission). 2016. Advanced Safety Evaluation for Turkey 

Point Units 6 and 7 Combined License Application, Chapter 2: "Site Characteristics." 

Washington, D.C. Accession No. ML15096A254. TN4775. 

Park, J. and W. Sweet. 2015. "Accelerated Sea Level Rise and Florida Current Transport." 

Ocean Science Discussions 12:551–572, Gottingen, Germany. TN4733. 
APPENDIX J 

GREENHOUSE GAS FOOTPRINT ESTIMATES FOR A REFERENCE 

1,000 MW(E) LIGHT-WATER REACTOR 

October 2016 J-1 NUREG–2176 

APPENDIX J 

GREENHOUSE GAS FOOTPRINT ESTIMATES FOR A REFERENCE 

1,000 MW(E) LIGHT-WATER REACTOR 

The review team has estimated the greenhouse gas (GHG) footprint of various activities 

associated with nuclear power plants. These activities include building, operating, and 

decommissioning a nuclear power plant. The estimates include direct emissions from the 

nuclear facility and indirect emissions from workforce transportation and the fuel cycle. 

Preconstruction/construction equipment estimates listed in Table J-1 are based on hours of 

equipment use estimated for a single nuclear power plant at a site requiring a moderate amount 

of terrain modification (UniStar 2007-TN1564). 

Table J-1. GHG Emissions from Equipment Used in Preconstruction/Construction and 

Decommissioning 

Equipment 

Preconstruction/ 

Construction Total(a) 

(MT CO2e) 

Decommissioning 

Total(b) 

(MT CO2e)

Earthwork and dewatering 12,000 6,000 

Batch plant operations 3,400 1,700 

Concrete 5,400 2,700 

Lifting and rigging 5,600 2,800 

Shop fabrication 1,000 500 

Warehouse operations 1,400 700 

Equipment maintenance 10,000 5,000 

Total(c) 39,000 19,000 

(a) Based on hours of equipment usage over 7-year period 

(b) Based on equipment usage over 10-year period 

(c) Results are rounded 

Preconstruction/construction equipment carbon monoxide (CO) emission estimates were 

derived from the hours of equipment use and carbon dioxide (CO2) emissions were then 

estimated from the CO emissions using a scaling factor of 172 tons of CO2 per ton of CO. The 

scaling factor is based on the ratio of CO2 to CO emission factors for diesel fuel industrial 

engines as reported in Table 3.3-1 of AP-42 (EPA 2012-TN2647). A CO2 to total GHG 

equivalency factor of 0.991 is used to account for the emissions from other GHGs such as 

methane (CH4) and nitrous oxide (N2O). The equivalency factor is based on nonroad/construction equipment (Chapman et al. 2012-TN2644). Equipment emissions estimates 

for decommissioning are assumed to be one-half of those for preconstruction/construction. 

Data on equipment emissions for decommissioning are not available; the one-half factor is 

based on the assumption that decommissioning would involve less earth moving and hauling of 

material and fewer labor hours than preconstruction/construction. 
Appendix J 

NUREG–2176 J-2 October 2016 

Table J-2 lists the review team’s estimates of the CO2 equivalent (CO2e) emissions associated 

with workforce transportation. Preconstruction/construction workforce estimates for new plant 

are conservatively based on estimates in various combined license applications (Chapman et 

al. 2012-TN2644); operational and decommissioning workforce estimates are based on 

Supplement 1 to NUREG–0586 (NRC 2002-TN665). Table J-2 lists the assumptions used to 

estimate total miles traveled by each workforce and the factors used to convert total miles to 

metric tons (MT) CO2e. The workers are assumed to travel in gasoline-powered passenger 

vehicles (i.e., cars, trucks, vans, and sport utility vehicles) that get an average of 21.6 mi/gal of 

gasoline (FHWA 2012-TN2645). Conversion from gallons of gasoline burned to CO2e is based 

on U.S. Environmental Protection Agency (EPA) emission factors (EPA 2012-TN2643). 

Table J-2. Workforce GHG Footprint Estimates 

Preconstruction/ 

Construction 

Workforce 

Operational 

Workforce 

Decommissioning 

Workforce 

SAFSTOR 

Workforce 

Commuting trips 

(round trips per day) 

1,000 550 200 40 

Commute distance 

(miles per round trip) 

40 40 40 40 

Commuting days 

(days per year) 

365 365 250 365 

Duration (years) 7 40 10 40 

Total distance traveled (mi)(a) 102,000,000 321,000,000 20,000,000 23,000,000 

Average vehicle fuel efficiency(b) 

(mi/gal) 

21.6 21.6 21.6 21.6 

Total fuel burned(a) (gal) 4,700,000 14,900,000 900,000 1,100,000 

CO2 emitted per gal(c) (MT CO2) 0.00892 0.00892 0.00892 0.00892 

Total CO2 emitted(a) (MT CO2) 42,000 133,000 8,000 10,000 

CO2 equivalent factor(c) 

(MT CO2/MT CO2e) 

0.977 0.977 0.977 0.977 

Total GHG emitted(a) 

(MT CO2e) 

43,000 136,000 8,000 10,000 

(a) Results are rounded 

(b) FHWA 2012-TN2645 

(c) EPA 2012-TN2643 

Title 10 of the Code of Federal Regulations (CFR) 51.51(a) (TN250) states that every 

environmental report prepared for the combined license stage of a light-water-cooled nuclear 

power reactor shall take Table S–3 from 10 CFR 51.51(b) (TN250) as the basis for evaluating 

the contribution of the environmental effects of the uranium fuel cycle in licensing the nuclear 

power reactor. 10 CFR 51.51(a) (TN250) further states that Table S–3 shall be included in the 

environmental report and may be supplemented by a discussion of the environmental 

significance of the data set forth in the table as weighted in the analysis for the proposed facility. 

Table S–3 does not provide an estimate of GHG emissions associated with the uranium fuel 

cycle; it only addresses pollutants that were of concern when the table was promulgated in the 

1980s. However, Table S–3 does state that 323,000 MWh is the assumed annual electric 
Appendix J 

October 2016 J-3 NUREG–2176 

energy use for the reference 1,000 MW(e) nuclear plant and this 323,000 MWh of annual 

electric energy is assumed to be generated by a 45 MW(e) coal-fired power plant burning 

118,000 MT of coal. Table S–3 also assumes approximately 135,000,000 standard cubic feet 

(scf) of natural gas is required per year to generate process heat for certain portions of the 

uranium fuel cycle. The review team estimates that burning 118,000 MT of coal and 

135,000,000 scf of natural gas per year results in approximately 253,000 MT of CO2e being 

emitted into the atmosphere per year due to the uranium fuel cycle (Harvey 2013-TN2646). 

The review team estimated GHG emissions related to plant operations from a typical usage of 

various diesel generators onsite (UniStar 2007-TN1564). CO emission estimates were derived 

assuming an average of 600 hr of emergency diesel generator operation per year (i.e., four 

generators, each operating 150 hr/yr) and 200 hr of station blackout diesel generator operation 

per year (i.e., two generators, each operating 100 hr/yr). A scaling factor of 172 was then 

applied to convert the CO emissions to CO2 emissions and a CO2 to total GHG equivalency 

factor of 0.991 was used to account for the emissions from other GHGs such as CH4 and N2O. 

Given the various sources of GHG emissions discussed above, the review team estimates the 

total life-cycle GHG footprint for a reference 1,000 MW(e) nuclear plant with an 80 percent 

capacity factor to be about 10,500,000 MT. The components of the footprint are summarized in 

Table J-3. The uranium fuel cycle component of the footprint dominates all other components. 

It is directly related to power generated. As a result, it is reasonable to use reactor power to 

scale the footprint to larger reactors. 

Table J-3. Nuclear Plant Lifetime GHG Footprint 

Source

Activity 

Duration (yr)

Total Emissions

(MT CO2e)

Preconstruction/construction equipment 7 39,000 

Preconstruction/construction workforce 7 43,000 

Plant operations 40 181,000 

Operations workforce 40 136,000 

Uranium fuel cycle 40 10,100,000 

Decommissioning equipment 10 19,000 

Decommissioning workforce 10 8,000 

SAFSTOR workforce 40 10,000 

Total(a) 10,500,000 

(a) Results are rounded 

The Intergovernmental Panel on Climate Change (IPCC) released a special report on 

renewable energy sources and climate change mitigation in 2012 (IPCC 2012-TN2648). 

Annex II of this IPCC report includes an assessment of previously published works on life-cycle 

GHG emissions from various electric generation technologies, including nuclear energy. In this 

assessment, the IPCC included only material that passes certain screening criteria for quality 

and relevance. The IPCC screening yielded 125 estimates of nuclear energy life-cycle GHG 

emissions from 32 separate references. The IPCC-screened estimates of the life-cycle GHG 

emissions associated with nuclear energy, as shown in Table A.II.4 of the report, ranged more 

than two orders of magnitude, from 1 to 220 g of CO2e/kWh, with 25 percentile, 50 percentile, 
Appendix J 

NUREG–2176 J-4 October 2016 

and 75 percentile values of 8 g CO2e/kWh, 16 g CO2e/kWh, and 45 g CO2e/kWh, respectively. 

The range of the IPCC estimates is due, in part, to assumptions regarding the type of 

enrichment technology employed, how the electricity used for enrichment is generated, the 

grade of mined uranium ore, the degree of processing and enrichment required, and the 

assumed operating lifetime of a nuclear plant. 

The review team’s life-cycle GHG estimate of approximately 10,500,000 MT CO2e for the 

reference 1,000 MW(e) nuclear plant is equal to about 37.5 g CO2e/kWh, which places the 

review team estimate between the 50 and 75 percentile values of the IPCC estimates given in 

Table A.II.4 of the report. 

In closing, the review team considers the footprint estimated in Table J-3 to be appropriately 

conservative. The GHG emissions estimates for the dominant component (uranium fuel cycle) 

are based on 30-year-old enrichment technology assuming that the energy required for 

enrichment is provided by coal-fired generation. Different assumptions related to the source of 

energy used for enrichment or the enrichment technology that would be just as reasonable 

could lead to a significantly reduced footprint. 

Emissions estimates presented in the body of this environmental impact statement have been 

scaled to values appropriate for the proposed project. The uranium fuel cycle emissions have 

been scaled by reactor power and plant capacity factor using the scaling factor determined in 

Chapter 6 and by the number of reactors to be built. Plant operations emissions have been 

adjusted to represent the number of large GHG emissions sources (e.g., diesel generators and 

boilers) associated with the project. The workforce emissions estimates have been scaled to 

account for differences in workforce numbers and commuting distance. Finally, equipment 

emissions estimates have been scaled by estimated equipment usage. As can be seen in 

Table J-3, only the scaling of the uranium fuel-cycle emissions estimates makes a significant 

difference in the total GHG footprint of the project. 

References 

10 CFR Part 51. 2011. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental 

Protection Regulations for Domestic Licensing and Related Regulatory Functions." 

Washington, D.C. TN250. 

Chapman, E.G., J.P. Rishel, J.M. Niemeyer, K.A. Cort, and S.E. Gulley. 2012. Assumptions, 

Calculations, and Recommendations Related to a Proposed Guidance Update on Greenhouse 

Gases and Climate Change. PNNL-21494, Pacific Northwest National Laboratory, Richland,

Washington. Accession No. ML12310A212. TN2644. 

EPA (U.S. Environmental Protection Agency). 2012. "Clean Energy: Calculations and 

References." Accession No. ML12292A648. TN2643. 

EPA (U.S. Environmental Protection Agency). 2012. "Stationary Internal Combustion Sources." 

Chapter 3 in Technology Transfer Network Clearinghouse for Inventories & Emissions Factors: 

AP-42. Fifth Edition, Research Triangle Park, North Carolina. Accession No. ML12292A637. 

TN2647. 
Appendix J 

October 2016 J-5 NUREG–2176 

FHWA (Federal Highway Administration). 2012. "Highway Statistics 2010 (Table VM-1)." 

Office of Highway Policy Information, Washington, D.C. Accession No. ML12292A645. 

TN2645. 

Harvey, B. 2013. “Greenhouse Emissions for the Fossil Fuel Sources Identified in Table S-3.” 

Office of New Reactors, U.S. Nuclear Regulatory Commission, Washington, D.C. Accession 

No. ML12299A401. TN2646. 

IPCC (Intergovernmental Panel on Climate Change). 2012. Renewable Energy Sources and 

Climate Change Mitigation—Special Report of the Intergovernmental Panel on Climate Change. 

Cambridge University Press, Cambridge, United Kingdom. TN2648.

NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 

Statement of Decommissioning of Nuclear Facilities: Regarding the Decommissioning of 

Nuclear Power Reactors. NUREG–0586, Supplement 1, Volumes 1 and 2, Washington, D.C. 

Accession Nos. ML023470327, ML023500228. TN665. 

UniStar (UniStar Nuclear Energy, LLC). 2007. Technical Report in Support of Application of 

UniStar Nuclear Energy, LLC and UniStar Nuclear Operating Services, LLC for Certificate of 

Public Convenience and Necessity Before the Maryland Public Service Commission for 

Authorization to Construct Unit 3 at Calvert Cliffs Nuclear Power Plant and Associated 

Transmission Lines. Public Service Commission of Maryland, Baltimore, Maryland. Accession 

No. ML090680053. TN1564. 

APPENDIX K 

POTENTIAL USACE ALTERNATIVE TRANSMISSION LINE ROUTES 

October 2016 K-1 NUREG–2176 

APPENDIX K 

POTENTIAL USACE ALTERNATIVE TRANSMISSION LINE ROUTES 

Analysis of Transmission Line Alternatives 

On June 30, 2009, the U.S. Army Corps of Engineers (USACE or Corps) received a Department 

of the Army (DA) permit application from Florida Power & Light Company (FPL) to construct the 

proposed Turkey Point Units 6 and 7, reclaimed water facility, access roads, radial collector 

wells, pipelines, transmission lines, and other related infrastructure. The proposed work would 

require a DA permit for structures in/over and under navigable waters of the United States, and 

the discharge of dredged or fill material into waters of the United States, including wetlands. 

The USACE is participating as a cooperating agency with the U.S. Nuclear Regulatory 

Commission (NRC) in preparing this environmental impact statement (EIS). 

Transmission line siting in Florida is regulated under the Florida Power Plant Siting Act (PPSA) 

(Fla. Stat. 29-403.501 2011-TN1068), and Chapter 62-17 of the Florida Administrative Code 

(Fla. Admin. Code 62-17-TN1247). The PPSA provides a centralized review process for new 

electrical generating facilities in Florida, involving a balancing of "the increasing demand for 

electrical power plants with the broad interests of the public." FPL undertook a route-selection 

process to select the transmission line corridors that were submitted for approval under the 

Florida PPSA (Fla. Stat. 29-403.501 2011-TN1068). Public comments requested that the 

transmission lines be buried under ground to minimize impacts. Underground transmission 

lines were considered but FPL indicated that the technology may not be available to support the 

high temperatures over long distances. This issue is currently being evaluated as part of the 

remand from the State of Florida to review the approved State Certification and will be 

considered as part of the Corps’ Clean Water Act Section 404(b)(1) Guidelines analysis to 

determine the least environmentally damaging practicable alternative (LEDPA). 

K.1 Summary of All Transmission Line Corridors Considered 

FPL submitted two main transmission line corridors in their 2009 application to distribute the 

power generated from the proposed nuclear reactors. The first corridor, labeled the West 

corridor, proposes lines from Turkey Point and the Clear Sky substation to the Pennsuco 

substation. This corridor is generally located in the western half of Miami-Dade County, and is 

proposed in five (5) segments (Figure K-1). The second corridor, labeled the East corridor, 

proposes lines from Turkey Point and the Clear Sky substation to the Miami substation. This 

corridor is generally located in the eastern half of Miami-Dade County, and is proposed in one 

(1) segment (Figure K-1). 
Appendix K 

NUREG–2176 K-2 October 2016 

Figure K-1. Transmission Line Segments 
Appendix K 

October 2016 K-3 NUREG–2176 

Figure K-1. (contd) 
Appendix K 

NUREG–2176 K-4 October 2016 

FPL originally considered several alignments within the northwest portion of the West corridor 

due to potential impacts on higher quality wetland areas, including Everglades National Park 

(ENP). In 2009, the application contained the East Preferred corridor, the West Secondary 

corridor, and the West Preferred corridor and the State of Florida Site Certification Application 

(SCA) contained a series of unnamed corridors associated with the East corridor (FPL 2010-

TN272). In 2011, several options were submitted, including Agency Staff Alternative Routes 1, 

2, 3; West Krome Avenue; and East Krome Avenue (Figure K-2). Via letter correspondence 

dated September 11, 2013, FPL provided the USACE with additional options for the West 

corridor, which included routes labeled Miami-Dade Limestone Products Association (MDLPA) 

1, MDPLA 2, MDPLA 3, and National Parks Conservation Association (NPCA). In the 

September 11, 2013 letter, FPL did not modify the USACE application to include the West 

Consensus corridor because they could not yet determine the viability of the West Consensus 

corridor (using MDLPA Alternate Corridor 2) option (FPL 2013-TN4754). In December 2013, 

FPL introduced the West Consensus corridor to the USACE as a viable option (FPL 2013-

TN4779). On July 8, 2016, FPL decided on and conveyed to the USACE their final option within 

the West corridor: the West Consensus corridor (Figure K-3; FPL 2016-TN4745). All of the 

above-listed options are within FPL’s proposed segments 3 and 4 for the Western transmission 

line corridor. All commence at SW 120th Street and theoretical SW 204th Avenue, and end at 

the Levee substation. 

FPL originally considered several alignments within the northern portion of the East corridor 

(Figure K-4; FPL 2010-TN272)) along existing transmission line corridors, established 

transportation corridors, and older neighborhoods where pipelines, sidewalks, and other 

residential infrastructure are already located. In October 2013, the Village of Pinecrest and the 

City of Coral Gables proposed the Village of Pinecrest/City of Coral Gables Alternate corridor. 

This alignment was submitted to the State of Florida as part of the SCA process but FPL never 

modified the Corps application and the State of Florida did not certify this transmission line 

corridor (Figure K-5). The segment connecting the Clear Sky and Davis substations traverses 

the same area as the East Preferred corridor. These unnamed routes follow the same route 

from the Clear Sky-to-Davis substation but start to diverge after that point. They all terminate at 

the Miami substation.
Appendix K 

October 2016 K-5 NUREG–2176 

Figure K-2. FPL Turkey Point Transmission Line West Corridor – All Potential Routes 
Appendix K 

NUREG–2176 K-6 October 2016 

Figure K-3. FPL Turkey Point Transmission Line West Consensus Corridor 
Appendix K 

October 2016 K-7 NUREG–2176 

Figure K-4. East Alternatives Routes and Preferred Route (FPL 2010-TN272) 
Appendix K 

NUREG–2176 K-8 October 2016 

Figure K-5. East Preferred Corridor and Village of Pinecrest/City of Coral Gables 

Alternative (FPL 2013-TN4777) 
Appendix K 

October 2016 K-9 NUREG–2176 

K.2 Alternatives Carried Forward for Detailed Review 

The East corridor and the West corridor, including the West Secondary corridor, West Preferred 

corridor, and the West Consensus corridor, were carried forward for further review. The other 

previously discussed alignments were eliminated from further consideration because of a 

combination of issues, including right-of-way acquisition; length alignment; buildings in proximity 

to the alignment; non-FPL parcels crossed; FPL substations crossed; collocation opportunities 

along the FPL right-of-way and other linear facilities; existing parks, recreation areas, and 

conservation lands; forested and nonforested wetlands; eagle nest and wading bird colonies; 

space restrictions; impacts on the Miami-Dade Urban Development Boundary; impacts on 

Native American lands; conflicts with existing mining operations; and proximity to residential 

development. This information was submitted by FPL via letter correspondence dated 

December 21, 2011 and September 11, 2013, in response to several USACE requests for 

additional information (FPL 2011-TN4753; FPL 2013-TN4754). Additionally, the USACE used 

information submitted to the State of Florida regarding the East corridor. The USACE 

independently reviewed FPL’s assessment of alternative alignments and considered that the 

Agency Staff Alternative Routes 1, 2, 3; West Krome Avenue; East Krome Avenue; MDLPA 1, 

MDPLA 2, MDPLA 3, and NPCA; several unnamed segments in the northern portion of the East 

corridor and the Village of Pinecrest/City of Coral Gables Alternate corridor should be eliminated 

from detailed study. Even though in most cases the proposed transmission line corridors were 

mapped to be collocated with existing infrastructure, there was not enough room to safely install 

another pole to accommodate the new lines. Because the eastern corridor is predominantly 

urban landscape, residential and commercial infrastructure dominates. Significant acquisition 

and demolition of buildings would be needed to achieve the necessary safe distance to 

construct the new power poles needed to construct the new transmission line which the USACE 

determined would not be practicable. The USACE retained the West Secondary corridor for a 

more detailed review because the land swap associated with the West Preferred corridor had 

not been finalized even though FPL withdrew it from the application prior to the public notice 

being published. The land swap involves a Congressionally mandated exchange of lands on 

the eastern boundary of ENP for the lands located inside the West Secondary corridor. 

K.3 Purpose and Need 

The Corps has determined the basic project purpose is to meet the public’s need for electric 

energy. The overall project purpose is to meet the public’s need for reliable increased electrical 

baseload generating capacity in FPL’s service territory. The transmission lines are necessary to 

distribute power to the continuously expanding population of Miami-Dade County. Specifically, 

the transmission lines will deliver approximately 2,200 MW of new generation from Turkey Point 

Units 6 and 7 to the State's electric grid through connections to other existing FPL substations in 

Miami-Dade County. Both eastern and western transmission lines are required because power 

from the new units must be delivered to different substations for distribution in order to maintain 

electrical system reliability. The East and West Preferred corridors both commence at the 

Turkey Point substation and connect to the Clear Sky substation, which is approximately 0.4 mi 

away. Improvements would be made to the Turkey Point substation to accommodate the new 

230 kV line from Clear Sky substation. 
Appendix K 

NUREG–2176 K-10 October 2016 

The East transmission corridor includes a 230 kV transmission line between the proposed Clear 

Sky Substation at Turkey Point to the Miami substation at the northeast intersection of SW 2nd 

Avenue and the Miami River. The West transmission corridor includes two 500 kV transmission 

lines between the proposed Clear Sky Substation and the Levee substation located east of 

State Road 997/Krome Avenue and north of U.S. Highway 41/Tamiami Trail, and one 230-kV 

transmission line between the proposed Clear Sky Substation and the Pennsuco Substation 

located along NW 106th Street, south of U.S. Highway 27 near Medley. 

K.4 No Action 

If the transmission lines are not constructed, power that would be generated from proposed 

Units 6 and 7 would not be able to reach consumers (i.e., the Miami baseload). The existing 

distribution system is unable to handle such an additional power load. FPL selected 

transmission line corridors that could be collocated with disturbed linear facilities such as 

existing roadways, canals, and rights-of-way. Collocation with existing linear features minimizes 

the amount of additional clearing of rights-of-way required for construction and reduces wetland 

impacts associated with access roads and structure pads. The no-action alternative would not 

allow the applicant to achieve the project purpose. 

K.5 Summary of Reasonable Alternatives 

The proposed project includes two transmission line corridors: an eastern corridor and a 

western corridor. The originally proposed West corridor includes a main corridor that diverges 

into two options—a West Preferred corridor and a West Secondary corridor—and re-forms into 

one corridor from the Levee substation to the Pennsuco substation. The proposed West 

corridor, with either option, would include two 500 V single-circuit transmission lines connecting 

the new Clear Sky substation to the existing Levee substation and one 230 kV single-circuit 

transmission line connecting the Clear Sky substation to the existing Pennsuco substation. A 

third option, the West Consensus corridor, was proposed and accepted into the SCA as a 

Condition of Certification on December 5, 2013. It would also contain infrastructure similar to 

that described above for the two other West corridor options. The proposed East Preferred 

corridor consists of a new 230 kV, approximately 19 mi long, transmission line constructed to 

connect the proposed new Clear Sky substation to the existing Davis substation, and a new 

230 kV line approximately 18 mi long, would be constructed to connect the Davis substation to a 

new 230 kV bay position at the Miami substation (Figure K-3). 

K.5.1 General Description of Impacts on the West Corridor 

The West corridor consists of the construction of two 500 kV lines from the new Clear Sky 

substation to the Levee substation and a 230 kV line to the Pennsuco substation. FPL 

proposes to construct the West corridor in five segments. These segments were based on the 

type of hydroperiod (deep, moderate, short) present, which correlates to the amount of fill FPL 

would need to construct the project. Segment 1 starts at the proposed Clear Sky substation and 

Segment 5 culminates at the Pennsuco substation. Segments 1, 2, and 5 are the same for the 

West corridor. Segments 3 and 4 show the variations between the three options, which are 

named the West Preferred, West Secondary, and West Consensus corridors. One of these 

three options would be constructed within a single right-of-way of approximately 330 ft in width 
Appendix K 

October 2016 K-11 NUREG–2176 

up to the Levee substation. From the Levee substation to the Pennsuco substation, the single 

230 kV line would be constructed largely within an existing multi-circuit right-of-way that is 

approximately 170 ft in width. 

Overall, potential impacts associated with the West corridor generally include impacts on 

agricultural land, residential communities, environmentally protected lands, and lands within the 

Miami-Dade County wellfield protection areas. Wetlands would also be affected, in addition to 

hydrology and freshwater flows that benefit the ENP and associated estuaries, and habitat 

supporting threatened and endangered plant and animal species. The segment connecting the 

Clear Sky and Levee substations would be built in three segments (legs). The first leg would 

pass just south of Homestead and Florida City, then travel north to SW 120th St. Major land 

use includes fields, pastures, row crops, tree nurseries, and citrus groves. 

During multiple public meetings and the public notice comment period, over 20,000 comments 

were received. Those that pertain to the transmission line corridors included concerns about 

viewscape and enjoying the National Park experience. Underground transmission lines were 

considered but the technology may not be available to support the high temperatures over long 

distances. This issue is currently being evaluated as part of the remand from the State of 

Florida to review the approved State Certification and will be considered as part of the Corps’ 

LEDPA analysis. 

Any of the three portions of the West corridor could also potentially affect four wood stork 

colonies. The distance between the four wood stork colonies varies from less than 500 ft to 

12 mi. The proposed work is also being coordinated to ensure that any proposed work that 

could modify a Congressionally authorized Comprehensive Everglades Restoration Plan 

(CERP) project would require review and approval pursuant to Section 14 of the Rivers and 

Harbors Act of 1899 (33 U.S.C. § 408) (TN4746). The three options within the West corridor 

may also be inconsistent with the County Code and Comprehensive Development Master Plan. 

Detailed impact analysis and citations explaining this conclusion are provided in the State of 

Florida, Division of Administrative Hearings, DEP OGC Case No. 09-3107 document in sections 

entitled, "Impacts Associated with Proposed Transmission Line Corridors within and adjacent to 

the Everglades National Park” and "Impacts to Conflict with County Code Section 338, East 

Everglades Area of Critical Environmental Concern" (State of Florida 2012-TN1248).

The proposed transmission facilities between the Clear Sky and Pennsuco substations traverse 

the King’s Highway Pineland within an existing right-of-way. A number of Federally threatened 

and endangered plants are known to occur within pine rockland habitats of Miami-Dade County, 

including the Bartrams’ scrub-hairstreak (Strymon acis bartrami) and the Florida leafwing 

(Anaea troglodyte floridalis), which rely upon the non-listed pineland croton (Croton linearis). 

The proposed design limits impacts within the King’s Highway Pineland to 0.84 ac by using 

areas that have been previously disturbed. All areas of construction would be isolated from 

adjacent areas through installation of silt fencing to limit disturbance. FPL would also be 

required to conduct pre-construction/pre-clearing surveys to provide an updated assessment for 

listed species, which shall note all habitat, occurrence, or evidence of listed species. FPL would 

be required to follow Florida Fish and Wildlife Conservation Commission and U.S. Fish and 

Wildlife Service (FWS) current survey protocols for all listed species that may occur within the 

site and associated facilities prior to conducting detailed surveys.
Appendix K 

NUREG–2176 K-12 October 2016 

Only one transmission line corridor will be built in the West corridor; however, at a point near 

SW 120 St. and theoretical SW 204 Avenue, the West corridor diverges into three different 

options or sub-routes that converge at the Levee substation. The options are described in 

greater detail below. 

K.5.1.1 West Secondary Corridor 

FPL acquired the Clear Sky-Levee right-of-way in the 1960s and early 1970s in anticipation of 

the future need for electrical facilities to serve electrical load growth in Miami-Dade County and 

southeast Florida. Approximately 7.4 mi of this right-of-way was encompassed by the addition 

of the Everglades National Park Expansion Area to the ENP in 1989. As a result, a total of 

approximately 12 mi of FPL’s existing right-of-way is proposed for relocation, including a short 

portion that was encompassed by the 8.5 Square Mile Area (SMA) project (immediately south of 

the ENP). The remaining portion of the right-of-way to be relocated extends across the 

southeast corner of Water Conservation Area 3B (WCA-3B) immediately north of ENP. This 

portion of the existing FPL right-of-way is the West Secondary corridor (Figure K-3). 

The West Secondary corridor starts at SW 120th Street and theoretical SW 204 Avenue in the 

8.5 SMA and continues to follow FPL’s existing right-of-way directly northward through the ENP 

Expansion Area for approximately 7.4 mi to U.S. 41/Tamiami Trail. There the West Secondary 

corridor crosses U.S. 41/Tamiami Trail and then turns northeastward along FPL’s existing rightof-way to its intersection with Krome Avenue. The West Secondary corridor is approximately 

330 to 370 ft wide, is wholly located within the existing FPL right-of-way, and is located 

approximately 2 mi inside the current ENP boundary. This right-of-way is privately owned by 

FPL even though it is located inside ENP. The total length of FPL’s West Secondary corridor is 

approximately 51 mi. 

This corridor was eliminated from detailed analysis prior to the issuance of the Corps’ public 

notice and publication of the draft EIS due to the proposed land exchange between the U.S. 

Department of the Interior and FPL, which included the exchange of the existing FPL right-ofway through the ENP (known as the West Secondary corridor) for a replacement right-of-way 

located adjacent to the existing L-31N Canal (known as the West Preferred corridor-discussed 

below). The land exchange provides the opportunity to minimize impacts on high-quality 

wetlands within the ENP by collocating the new transmission facilities with existing disturbed 

linear features. The West Secondary corridor contains impacts on 190.63 ac of higher quality 

wetlands, 0.94 ac of surface-water impacts, and 23.67 ac of exotic dominated wetlands. 

If this corridor were built, the environmental consequences would likely include disruption of 

natural sheet flow to the eastern boundary of ENP due to the construction of the access road for 

the transmission lines. Culverts were proposed as needed to maintain flow in an attempt to 

reduce impacts to sheet flow because the access roads are continuous. 

In addition, programmatic general permits (PGPs) were developed by the USACE Regulatory 

Division for the East Bird Drive, Bird Drive, and North Trail wetland basins under SAJ-59 

(DOA 1994-TN4749) and SAJ-74 (DOA 2005-TN4751). SAJ-59 was issued on April 12, 1989, 

as a PGP administered by Miami-Dade County to allow filling of wetlands in the East Bird Drive 

Basin (DOA 1989-TN4748; DOA 1994-TN4749). Mitigation funds were collected by Miami-
Appendix K 

October 2016 K-13 NUREG–2176 

Dade County until September 30, 1999, and exotic plant species treatment was conducted in 

the East Everglades Expansion Area in ENP next to the transmission line corridors until 2013 

(DOI and Miami-Dade County 2011-TN4750). The final version of the SAJ-74, which covered 

the Bird Drive and North Trail Wetlands, expired on May 31, 2010 (DOA 2005-TN4751). SAJ74 was a PGP administered by Miami-Dade County. Even though the majority of mitigation 

funds were used primarily for acquiring conservation lands in Miami-Dade County outside of 

ENP, some mitigation funding was authorized for exotic species treatment in 34 various 

locations in and around ENP, some near the Tamiami Trail and Krome Avenue and some near 

SW 136 and Krome Avenue. Biological control agents psyllids (Boreioglycaspis melaleucae)

and weevils (Oxyops vitiosa) were released in areas where Melaleuca, an invasive exotic 

plant, was located (USDA 2010-TN4747). The construction of this portion of the corridor would 

likely negatively affect the 34 locations where biological control agents were introduced as 

mitigation associated with these general permits (or PGPs). The construction of the 

transmission lines and access roads would result in the filling of wetlands that were likely 

recipient sites of mitigation funds, which were designated for wetland enhancement. 

As part of the mitigation associated with Lake Belt limestone mines, the Lake Belt Mitigation 

Committee designed and constructed a 2 mi long subterranean seepage wall (Phase I) on the 

eastern side of the L-31N Levee to help prevent the loss of groundwater into the canal. For 

Phase II of the mitigation, an additional 3 mi long subterranean wall is currently being proposed. 

The Lake Belt Mitigation Committee seepage wall would likely not be affected by the 

construction of this corridor because the proposed transmission line corridor is located 2 mi 

west of this structure and impacts associated with this corridor would likely not impede flow 

toward the seepage wall. 

There would also be an increased likelihood of impacts on the wood stork and other avian 

species by the construction and operation of the transmission towers and lines. Factors that 

contribute to avian electrocutions include bird size, bird behavior (does the species find the 

structures an attractive nuisance, are the structures conducive to perching and roosting), bird 

abundance and habitat use, and structural design (less than 60 in. vertically between wires). 

The closer the lines, the more likely a large bird’s wingspan can touch both lines, resulting in 

electrocution. By moving the transmission line corridor 2 mi inside of ENP, there would likely be 

an increase in the possibility of impacts on the wood stork since there are 4 active wood stork 

colonies in close proximity. The closest colony is less than 500 ft away. 

Because ENP has minimal invasive species in this area, the construction and maintenance of 

the new transmission line routes would introduce exotic plant species by creating upland/ 

disturbed areas that would allow exotics greater ability to colonize on the side slopes of the 

access road. Exotic seeds could also be introduced through the use of construction equipment 

brought in from other sites. 

Viewshed impacts for ENP visitors would increase because the structures would be 2 mi inside 

the eastern boundary of the ENP. The pads would be 330 ft wide to accommodate a 230 kV 

line and two, 500 kV lines. Standard height for these structures would be a minimum of 135 ft. 
Appendix K 

NUREG–2176 K-14 October 2016 

K.5.1.2 West Preferred Corridor 

The West Preferred corridor deviates from the West Secondary corridor at SW 120th Street and 

theoretical SW 204 Avenue in the 8.5 SMA and continues east along a portion of the southern 

boundary of ENP, and then continues north along the L-31N Levee. The West Preferred 

corridor crosses U.S. 41/Tamiami Trail and then turns northeastward continuing along Krome 

Avenue to its intersection with the West Secondary corridor. The West Preferred corridor is 

approximately 330 to 370 ft wide and is wholly located within the land swap area, whereby FPL 

will swap the West Secondary corridor land for the land directly west of the L-31N Levee, 

thereby moving the ENP boundary westward. This right-of-way is privately owned by FPL. The 

total length of FPL’s West Preferred corridor is approximately 52 mi; the length where it differs 

from the West Secondary corridor is 1 mi. 

Part of the West Preferred corridor abuts the eastern perimeter of the ENP, which is 

characterized by high-quality wetlands, is located closer to four existing wood stork colonies, 

and is located predominantly inside the current eastern boundary of ENP. This corridor has the 

potential to be the most damaging on ENP viewscape and wood stork colonies. Portions of the 

West Preferred corridor outside of ENP contain disturbed wetlands with some agricultural land, 

limerock quarries, and scattered urban development. Based on conceptual designs, 

construction of transmission facilities within the West Preferred corridor would cause impacts on 

approximately 198.92 ac of higher quality wetlands, 0.31 ac of surface waters, and 28.11 ac of 

exotic dominated wetlands resulting in 227.34 ac of permanent impacts on jurisdictional 

wetlands. 

If this corridor were built, the environmental consequences would likely include impacts on 

Federal projects, including the L-31N Levee, Modified Water Deliveries to Everglades National 

Park (Mod Waters), and other CERP components. Building an access road with the associated 

pads at the toe of slope on the western side of the L-31N Levee would likely affect the structural 

integrity of the levee and would require authorization pursuant to 33 U.S.C. § 408 (TN4746). 

The Mod Waters project and several CERP projects, including the refurbishment of several 

water control structures, were designed to bring water to the eastern part of ENP. 

In addition, PGPs were developed by the USACE Regulatory Division for the East Bird Drive, 

Bird Drive, and North Trail wetland basins under SAJ-59 (DOA 1994-TN4749) and SAJ-74 

(DOA 2005-TN4751). SAJ-59 was issued on April 12, 1989, as a PGP administered by MiamiDade County to allow filling of wetlands in the East Bird Drive Basin (DOA 1989-TN4748; 

DOA 1994-TN4749). Mitigation funds were collected by Miami-Dade County until September 

30, 1999, and exotic plant species treatment was conducted in the East Everglades Expansion 

Area, near the transmission line corridors in ENP until 2013 (DOI and Miami-Dade County 2011-

TN4750). The final version of the SAJ-74, which covered Bird Drive and North Trail Wetlands, 

expired on May 31, 2010 (DOA 2005-TN4751). SAJ-74 was a PGP administered by MiamiDade County. Even though the majority of mitigation funds were used primarily for acquiring 

conservation lands in Miami-Dade County outside of ENP, some mitigation funding was 

authorized for exotic species treatment in 34 various locations in and around ENP, some near 

the Tamiami Trail and Krome Avenue and some near SW 136 Street and Krome Avenue. 

Biological control agents psyllids (Boreioglycaspis melaleucae) and weevils (Oxyops vitiosa) 

were released in areas where Melaleuca, an invasive exotic plant, was located (USDA 2010-
Appendix K 

October 2016 K-15 NUREG–2176 

TN4747). The construction of this portion of the corridor would likely negatively affect the 34 

locations where biological control agents were introduced as mitigation associated with these 

general permits (or PGPs). The construction of the transmission lines and access roads would 

result in the filling of wetlands that were likely recipient sites of mitigation funds designated for 

wetland enhancement. 

As part of the mitigation associated with Lake Belt limestone mines, the Lake Belt Mitigation 

Committee designed and constructed a 2 mi long subterranean seepage wall (Phase I) on the 

eastern side of the L-31N Levee to help prevent the loss of groundwater into the canal. For 

Phase II of the mitigation, an additional 3 mi long subterranean wall is currently being proposed. 

If the access road and fill pads were constructed, the modeling associated with this seepage 

wall would need to be recalculated to determine if the construction of the access road and fill 

pads would be beneficial or detrimental to the seepage wall project. 

There would also be an increased likelihood of impacts on the wood stork and other avian 

species by the construction and operation of the transmission towers and lines. Factors that 

contribute to avian electrocutions include bird size, bird behavior (does the species find the 

structures an attractive nuisance, are the structures conducive to perching and roosting), bird 

abundance and habitat use, and structural design (less than 60 in. vertically between wires). By 

moving the transmission line corridor 2 mi east, there would likely be a reduction in the 

possibility of impacts on the wood stork because there are four active wood stork colonies in 

close proximity. The closest colony is less than 500 ft away. 

Because ENP has minimal invasive species in this area, the construction and maintenance of 

the new transmission line routes would create upland/disturbed areas that would allow exotics 

greater ability to colonize. Exotic seeds could also be introduced through the use of 

construction equipment brought in from other sites. 

Viewshed impacts for ENP visitors would be reduced because the structures would be moved to 

the eastern boundary of the ENP. 

K.5.1.3 West Consensus Corridor 

The West Consensus corridor deviates from the West Preferred corridor at SW 120th Street and 

theoretical SW 187 Avenue in the 8.5 SMA and continues to follow the L-31N Levee northward. 

The West Consensus corridor turns east, just south of the Krome Detention Center and then 

turns north within a large swath of the Bird Drive Basin. The West Consensus corridor crosses 

U.S. 41/Tamiami Trail and heads north through the Pennsuco Wetland Basin until it intersects 

with the infrastructure associated with the Levee substation where it then turns east. The West 

Consensus corridor is approximately 330 to 370 ft wide, is located within the existing FPL rightof-way, and is proposed to be located to the east of the current ENP boundary. The total length 

of FPL’s West Consensus corridor is approximately 52.5 mi; it differs in length from the West 

Preferred corridor by 0.5 mi. 

The West Consensus corridor is the latest alternative that was added to the Corps’ permit 

application evaluation in December 2013, prior to publication of the Corps’ public notice. It 

differs from the West Preferred corridor only in that portions of the segment have been shifted to 

the east to avoid affecting the majority of the eastern perimeter of the current boundary of ENP. 
Appendix K 

NUREG–2176 K-16 October 2016 

This corridor still crosses a landscape consisting mostly of wetlands and has a small impact on 

the current ENP boundary; the wetlands range in quality from high quality to disturbed, but FPL 

states that its use would reduce the potential for adverse impacts on multiple Federally 

endangered species (FPL 2013-TN2941). 

Based on conceptual designs, construction of transmission facilities within the West Consensus 

corridor would contain impacts on 169.53 ac of higher quality wetlands, 0.29 ac of surface 

waters, and 42.24 ac of exotic dominated wetlands resulting in 212.06 ac of permanent impacts; 

which is a reduction of approximately 15 ac of wetland impacts, compared to the West Preferred 

corridor. 

FPL is in the process of acquiring lands to obtain the right-of-way to construct this corridor. The 

selection of the West Consensus corridor as FPL's preferred alternative for the West corridor 

was confirmed in FPL's letter to the USACE dated July 8, 2016 (FPL 2016-TN4745). Prior to 

that date, FPL requested that both the West Preferred and West Consensus corridors be 

authorized as options in the USACE final decision document; however, the Corps determined 

that a LEDPA determination could not be reached pursuant to Section 404 of the Clean Water 

Act with two potential options. 

Impacts on sheet flow inside ENP would be nonexistent because the corridor would be located 

outside ENP boundaries. Access roads would need to be culverted so as not to interfere with 

sheet flow of adjacent wetlands located within the Bird Drive, Pennsuco, or North Trail wetland 

basins. 

If this corridor were built, the environmental consequences would likely include de minimis 

impacts on Federal projects, including the L-31N Levee, Mod Waters, and other CERP 

components because it completely avoids the Federal projects. 

In addition, PGPs were developed by the USACE Regulatory Division for the East Bird Drive, 

Bird Drive and North Trail wetland basins under SAJ-59 (DOA 1994-TN4749) and SAJ-74 

(DOA 2005-TN4751). SAJ-59 was issued on April 12, 1989, as a PGP administered by MiamiDade County to allow filling of wetlands in the East Bird Drive Basin (DOA 1989-TN4748; 

DOA 1994-TN4749). Mitigation funds were collected by Miami-Dade County until September 

30, 1999, and exotic plant species treatment was conducted in the East Everglades Expansion 

Area, next to the transmission line corridors in ENP until 2013 (DOI and Miami-Dade 

County 2011-TN4750). The final version of the SAJ-74, which covered the Bird Drive and North 

Trail Wetlands, expired on May 31, 2010 (DOA 2005-TN4751). SAJ-74 was a PGP 

administered by Miami-Dade County. Even though the majority of mitigation funds were used 

primarily for acquiring conservation lands in Miami-Dade County outside of ENP, some 

mitigation funding was authorized for exotic species treatment in 34 various locations in and 

around ENP, some near the Tamiami Trail and Krome Avenue and some near SW 136 Street 

and Krome Avenue. Biological control agents psyllids (Boreioglycaspis melaleucae) and 

weevils (Oxyops vitiosa) were released in areas where Melaleuca, an invasive exotic plant, 

was located (USDA 2010-TN4747). The construction of this portion of the corridor would likely 

negatively impact the 34 locations where biological control agents were introduced as mitigation 

associated with these general permits (or PGPs). The construction of the transmission lines 
Appendix K 

October 2016 K-17 NUREG–2176 

and access roads would result in the filling of wetlands that were likely recipient sites of 

mitigation funds designated for wetland enhancement. 

As part of the mitigation associated with Lake Belt limestone mines, the Lake Belt Mitigation 

Committee designed and constructed a 2 mi long subterranean seepage wall (Phase I) on the 

eastern side of the L-31N Levee to help prevent the loss of groundwater into the canal. For 

Phase II of the mitigation, an additional 3 mi long subterranean wall is currently being proposed. 

If the access road and fill pads were constructed, the modeling associated with this seepage 

wall would need to be recalculated to determine if the construction of the access road and fill 

pads would be beneficial or detrimental to the seepage wall project. 

The Lake Belt Mitigation Committee seepage wall would likely not be affected by the 

construction of this corridor because this corridor is located 1 mi or more away from the 

mitigation site. 

This corridor would have the least adverse impacts on the wood stork and other avian species 

by constructing the transmission towers and lines closer to a disturbed/urban area, moving the 

impacts farthest away from four existing wood stork colonies. 

Factors that contribute to avian electrocutions include bird size, bird behavior (does the species 

find the structures an attractive nuisance, are the structures conducive to perching and 

roosting), bird abundance and habitat use, and structural design (less than 60 in. vertically). By 

moving the transmission line corridor farther east, outside of ENP, there would likely be a 

reduction in the possibility of impacts on the wood stork and other avian species. 

The majority of construction would occur outside of ENP; therefore, there is a decreased 

likelihood of introducing exotic plant species into ENP through the construction and 

maintenance of the new transmission line route. Impacts on the park would be limited to the 

southern boundary along SW 120th Street, where the corridor would still be partially located in 

the park. 

Impacts on the viewshed for ENP visitors would be greatly reduced because the majority of the 

construction would occur outside of ENP. The impacts that would likely still be inside ENP 

would be situated around the east-west route along SW 120 Street. 

K.5.1.4 East Preferred Corridor 

The proposed East Preferred corridor transmission lines would be largely collocated in an 

existing right-of-way or other linear/transportation corridors. The segment connecting the Clear 

Sky and Davis substations traverses a mostly rural landscape consisting predominantly of 

agricultural land interspersed with wetlands and rangeland and with widely scattered urban 

areas and forests. The segment between the Davis and Miami substations would traverse a 

mostly urban landscape but would be built mostly along existing roadways. 

The proposed East Preferred corridor would include an overhead, single-circuit 230 kV 

transmission line. This line would provide connection from the Clear Sky substation to the 

existing Davis and Miami substations located in Miami-Dade County. The Davis substation is 
Appendix K 

NUREG–2176 K-18 October 2016 

located at the intersection of SW 136th Street and SW 127th Avenue. The Miami substation, 

located within the city limits of Miami, is at the intersection of SW 2nd Avenue and SW 3rd 

Street along the Miami River. There would be improvements made to both substations to 

accommodate the new 230 kV line. The Clear Sky-Davis portion of the East Preferred corridor 

would be constructed within an existing, 19 mi long, multi-circuit FPL transmission line right-ofway. 

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). The Davis-Miami portion of the East 

Preferred corridor is approximately 18 mi long and is predominantly within an existing 

transmission line corridor with the exception of the portion that runs along the US-1 corridor. 

There are several areas where there is more uncertainty and where the proposed expanded 

corridor exceeds the 330 ft width. The most extensive expansions occur from SW 140 Street to 

SW 128 Street and between SW 127 Avenue and theoretical SW 124 Avenue (which affects the 

Nixon-Smiley Pineland, a Miami-Dade County, Environmentally Endangered Land ); along US-1 

from SW 100 Street to SW 80 Street (which affects the Snapper Creek Canal crossing, a 

Federal project); along US-1 from Orange Street to just north of Bird Avenue (which does not 

affect wetlands or canal crossings); along US-1 from SW 28 Terrace. to SW 27 Terrace. (which 

does not affect wetlands or canal crossings); and along US-1 near SW 22 Terrace. until the 

terminus at the Miami substation (which affects the crossing underneath the Miami River, a 

Federal project). Please note that the impacts/crossings of Federal projects would require 

authorization pursuant to 33 U.S.C. § 408 (TN4746). 

Various environmental consequences are associated with the proposed East Preferred corridor. 

Impacts on residential and commercial areas traversed by East Preferred corridor segments 

would include aesthetics, vegetation removal and the scale of the poles. The proposed 

transmission lines and utility poles would permanently alter the eastern skyline for Miami-Dade 

residents and property owners, especially those who live in units above the tree line. The 

proposed East Preferred corridor would impact the dense urban environment of US1 from the 

Miami substation in downtown Miami to the southern end of the Busway near SW 136th Street 

(C-100A Canal at US-1). US-1 has special Miami-Dade County designations and is classified 

as a Gateway corridor. Anticipated aesthetic impacts and impacts to trees and vegetation 

would adversely affect the quality of this corridor. Existing street trees provide shelter for 

pedestrians and bicyclists from the elements such as sun, heat, rain, wind, and vehicles. 

Impacts to this urban vegetation will additionally affect the aesthetics of US-1 by removing 

natural buffers to incompatible land uses (as determined by Miami-Dade County) and street 

fixtures. The proposed East Preferred corridor would also potentially impact pedestrian 

gateways (bridges) at US-1 and NW 12th Avenue and US-1 and SW 88th Street. Overhead 

lines in segments along US-1 may restrict efforts to build high-quality development projects 

designed for pedestrians. Removal of trees in the urban areas throughout the East Preferred 

corridor is likely to cause an increase in greenhouse gas emissions and the urban heat island 

effect. 

If this corridor were built, the environmental consequences would likely include de minis impacts 

to Federal projects, including the L-31N Levee, Mod Waters and other CERP components 
Appendix K 

October 2016 K-19 NUREG–2176 

because this corridor is located 18 m or greater away from the L-31N Levee and Mod Waters, 

projects. The distance factor would also be the rationale as why the CERP components 

adjacent to ENP or the Bird Drive Basin would not be affected by the East Preferred corridor. 

CERP components near the eastern portion of Miami-Dade County in the Biscayne Bay Coastal 

Wetlands would also likely experience de minimis impacts because the East Preferred corridor 

proposes only 0.06 ac of impacts on coastal wetlands. Please note that the impacts/crossings 

of Federal projects would require authorization pursuant to 33 U.S.C. § 408 (TN4746). 

Mitigation associated with PGPs SAJ-59 (DOA 1994-TN4749) and SAJ-74 (DOA 2005-TN4751) 

would likely not be affected by construction of this corridor because it is located 18 mi or more 

away from the mitigation site. 

The Lake Belt Mitigation Committee seepage wall would likely not be affected by the 

construction of this corridor because this corridor is located 18 mi or more away from the 

mitigation site. 

Factors that contribute to avian electrocutions include bird size, bird behavior (does the species 

find the structures an attractive nuisance, are the structures conducive to perching and roosting), 

bird abundance and habitat use, and structural design (at a minimum 60 in. between wires). 

By moving the transmission line corridor further east, there would likely be a reduction in the 

possibility of impacts on the wood stork and but an increase in impacts on other avian species. 

In the southern portion of this corridor from the point where the transmission lines leave the 

Turkey Point site, continuing north to theoretical SW 261 Street then heading west to 

approximately SW 122 Avenue, construction of East Preferred corridor infrastructure may also 

affect 0.06 ac of coastal wetlands and wetland hydrology and sheetflows or freshwater flows to 

Biscayne National Park (BNP), habitat supporting threatened and endangered plant and animal 

species, and protected lands adjacent to the transmission lines. The impacts on wood stork 

colonies would be minimal because the proposed fill locations are more than 18.6 mi away from 

the colonies throughout most of the East Preferred corridor. 

Because the majority of construction would occur outside of BNP, there is a decreased 

likelihood of introducing exotic plant species into BNP through the construction and 

maintenance of the new transmission line route. 

Impacts on the viewshed BNP visitors would be minimal because the East Preferred corridor 

would be constructed within an existing transmission line corridor, which already contains 

transmission lines and poles that are visible from BNP. 

K.6 Mitigation Measures 

Avoidance and minimization are being partially addressed by FPL’s final selection of the West 

Consensus corridor, which has the least amount of impacts on wetlands in the West corridor. In 

addition, impacts on exotic dominated wetlands (exotic wetland hardwoods) and other nonwetland waters (canals, ditches) are helping to minimize impacts on high-quality wetlands. 

Further avoidance and minimization will be considered and addressed once a final, refined 

layout is received, according to FPL’s letter to the USACE, dated July 8, 2016 (FPL 2016-

TN4745). 
Appendix K 

NUREG–2176 K-20 October 2016 

FPL has identified the West Consensus corridor as its preferred corridor alignment alternative 

for the West corridor. The West Consensus corridor has the least amount of impacts on 

wetlands of the West corridor alignment alternatives. This alternative also affects exotic 

dominated wetlands (exotic wetland hardwoods) and other non-wetland waters (canals, 

ditches,) in order to avoid and minimize impacts on high-quality wetlands. Further avoidance 

and minimization will be considered and addressed once a final, refined layout is received, 

according to FPL’s letter to the USACE dated July 8, 2016 (FPL 2016-TN4745). 

Unavoidable impacts on herbaceous wetland impacts are proposed to be mitigated through the 

purchase of credits from the ENP Hole-in-the-Donut (HID) In-Lieu-Fee Mitigation Project. These 

credits were calculated through the use of the HID’s functional assessment methodology 

Uniform Mitigation Assessment Methodology. Unavoidable impacts on coastal wetlands are 

proposed to be mitigated through the purchase of credits from the FPL Everglades Mitigation 

Bank (EMB). These credits were calculated through the use of the EMB’s functional 

assessment methodology, Wetland Assessment Technique for Environmental Reviews 

(WATER). Final mitigation calculations will be documented in the USACE’s record of decision 

after the Corps determines the LEDPA pursuant to Section 404 of the Clean Water Act (40 CFR 

230-TN427). 

The NRC is currently in consultation with the FWS pursuant to Section 7 of the Endangered 

Species Act (73 FR 76272-TN973). The NRC determined that the proposed transmission lines 

may affect, and are likely to adversely affect the Florida panther. FWS typically considers 

impacts on the Florida panther by determining the projects impacts on panther habitat units 

(PHUs). FWS has a pre-determined amount of PHUs associated with each EMB WATER 

credit. The FWS determines whether the amount of WATER credits will compensate for the 

PHUs lost as a result of the construction of this project. When consultation is complete, FWS 

will likely prescribe the number of WATER credits the applicant must acquire in order to offset 

impacts on the panther by using the WATER functional assessment methodology. Final 

mitigation calculations will be documented in the USACE’s record of decision after consultation 

with FWS is complete. 

Other mitigative measures proposed will attempt to reduce impacts on avian species. Impacts 

can include collisions with powerlines and electrocution. Collisions are proposed to be reduced 

through the use of flight diverters and perch discouragers. Flight diverters are typically attached 

to the ground wire and are intended to increase visibility of the powerlines. Marker balls are an 

example of a flight diverter. They are brightly colored, lightweight, and round, and are secured 

on distribution lines to increase visibility. Wood storks are especially vulnerable to collisions 

with overhead wires due to their size, body mass, and flight behavior. Abundance of bird 

species, habitat use and structural design (lines vertically spaced less than 60 in. apart) also 

contribute to avian collisions with overhead lines. 

Perch discouragers can include perch guards, bird platforms, and insulator shield designs, and 

are intended to keep birds from using powerlines and poles for perching. Bird guano is 

especially problematic in these perching scenarios. When feces build up on the insulator 

structures or skirts, the insulating qualities become compromised and this can cause an 

electrical fault. Another major issue is that arcing can occur when birds produce a large stream 
Appendix K 

October 2016 K-21 NUREG–2176 

of excrement. Arcing can happen when a strong current jumps a gap in a circuit. A bird may be 

electrocuted without even touching both powerlines. 

Additionally, raptors can use these structures to locate prey because the landscape in South 

Florida is flat, thus giving them a hunting advantage. 

FPL has proposed to conduct a monitoring study during the first wood stork nesting season after 

construction has commenced along the marked stretch of the transmission lines near the 

currently known wood stork colonies. Their proposed monitoring study is based on a previous 

study conducted by Frederick and Deng (1997-TN4752) on the FPL Levee-Midway 

Transmission Line to confirm whether or not these structures are effective in reducing impacts 

to avian species. 

K.7 404 (b)(1) Guidelines and the Least Environmentally Damaging Practicable 

Alternative 

As part of the National Environmental Policy Act process, the USACE evaluated the corridors in 

this appendix. The Corps considered all reasonable alternatives, including those eliminated 

from detailed study, alternatives outside of the Corps’ jurisdiction, and the no-action alternative. 

The Corps evaluated the environmental consequences of the East corridor, and several 

alignments in the West corridor, and proposed mitigative measures. As part of its ongoing 

review of the project, the Corps will further refine its review of practicable alternatives of the 

proposed project as required by the 404(b)(1) Guidelines (40 CFR 230-TN427). This analysis 

will ultimately yield the LEDPA determination for this proposal, which will be included in the 

USACE record of decision.

K.8 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. 

73 FR 76272. December 16, 2008. “Interagency Cooperation Under the Endangered Species 

Act.” Federal Register, U.S. Fish and Wildlife Service, Washington, D.C. TN973. 

33 U.S.C. § 408. Section 408 of the Rivers and Harbors Appropriation Act of 1899. TN4746. 

DOA (Department of the Army). 1989. Department of the Army General Permit No. 59: 

"Residential Fill in Wetlands East of 144th Avenue in Bird Drive—Everglades Basin, Dade 

County." SAJ-59, Jacksonville District, Corps of Engineers, Jacksonville, Florida. Accession 

No. ML16266A245. TN4748. 

DOA (Department of the Army). 1994. Department of the Army General Permit No. 59 

(Revision): "Residential Fill in Wetlands East of 144th Avenue in Bird Drive—Everglades Basin, 

Dade County." SAJ-59, Jacksonville District, Corps of Engineers, Jacksonville, Florida. 

Accession No. ML16266A246. TN4749. 
Appendix K 

NUREG–2176 K-22 October 2016 

DOA (Department of the Army). 2005. Department of the Army General Permit SAJ-74: "For 

Installation of Fill for Residential and Commercial Activities and Limited Clearing Activities, 

Surveying Activities, and Construction of Roadway Projects to Support the Permitted Activities 

(within the Specific Area Described Below) Located within the Bird Drive and North Trail Basins 

in Miami-Dade County, Florida." SAJ-74, Jacksonville District, Corps of Engineers, 

Jacksonville, Florida. TN4751. 

DOI (Department of the Interior) and Miami-Dade County. 2011. "Memorandum of Agreement 

Between United States Department of the Interior, National Park Service, Everglades National 

Park, Homestead, Florida, and Miami-Dade County, Florida." Agreement Number: 5297-11-

0029, Miami, Florida. Accession No. ML16266A247. TN4750. 

Fla. Admin. Code (FAC) 62-17. 2012. Chapter 62-17, "Electrical Power Plant Siting." Florida 

Administrative Code Annotated, Tallahassee, Florida. TN1247. 

Fla. Stat. 29-403.501. 2009. "Electrical Power Plant and Transmission Line Siting [also known 

as Florida Electrical Power Plant Siting Act]." Florida Statutes, Tallahassee, Florida. TN1068. 

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. Turkey Point Units 6 & 7 U.S. Army Corps of 

Engineers Request for Additional Information Responses—Transmission Lines. SAJ-2009-

02417 (IP-MLC), Juno Beach, Florida. TN4753. 

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 M.J. Raffenberg to Jacksonville 

District Corps of Engineers, dated September 11, 2013, regarding Request for Additional 

Information Concerning FPL's Application for a Department of the Army Permit Associated with 

the Turkey Point Units 6 & 7 Project, Specifically Transmission Lines. Juno Beach, Florida. 

TN4754. 

FPL (Florida Power & Light Company). 2013. Aerial Map of the East Preferred Corridor and 

Village of Pinecrest/City of Coral Gables Alternative. Figure FPL-KB-45, Juno Beach, Florida. 

Accessed September 19, 2016, at 

http://publicfiles.dep.state.fl.us/Siting/Outgoing/FPL_Turkey_Point/Units_6_7/East_Corridor/FPL

_Corridors_Aerial.pdf. TN4777. 

FPL (Florida Power & Light Company). 2013. Letter from M.J. Raffenberg to Jacksonville 

District Corps of Engineers, dated December 23, 2013, regarding "FPL Turkey Point Units 6 & 7 
Appendix K 

October 2016 K-23 NUREG–2176 

Project, Application No. SAJ-2009-02417 (IP-MLC)." FPLACE-13-0696, Juno Beach, Florida. 

TN4779. 

FPL (Florida Power & Light Company). 2016. Letter from M.J. Raffenberg to Jacksonville 

District Corps of Engineers, dated July 8, 2016, regarding "FPL Turkey Point Units 6 & 7 

Project, Application No, SAJ-2009-02417 (IP-MLC)." Juno Beach, Florida. Accession No. 

ML16214A362. TN4745. 

Frederick, P.C. and J. Deng. 1997. Bird-Strike Mortality on the Everglades Section of the 

Levee-Midway Powerline. Gainesville, Florida. Accession No. ML16266A251. TN4752. 

State of Florida. 2012. Miami-Dade County Agency Report and Proposed Conditions for FPL 

Proposed Transmission Lines for Turkey Point Nuclear Units 6 & 7. Division of Administrative 

Hearings, Case No. 09–03575–EPP, Tallahassee, Florida. Accession No. ML14216A578. 

TN1248. 

USDA (U.S. Department of Agriculture). 2010. Biological Control of Melaleuca quinquenervia 

in Southern Florida. Annual Report (May 23, 2009–May 22, 2010, Agricultural Research 

Service, Fort Lauderdale, Florida. Accession No. ML16266A242. TN4747. 





NUREG-2176, Vol. 3

Final

Environmental Impact Statement for Combined Licenses (COLs) for

Turkey Point Nuclear Plant Units 6 and 7