Item D1BOARD OF COUNTY COMMISSIONERS
AGENDA ITEM SUMMARY
Meeting Date: _April 13, 2016 Division: Mayor / BOCC_3
Bulk Item: Yes No X Department: _ Heather Carruthers 3
Staff Contact /Phone #: _Carol Schreck
305- 292 -3430
AGENDA ITEM WORDING: Discussion regarding Florida Power & Light Cooling Canal System
(CCS) serving the Turkey Point nuclear facility.
ITEM BACKGROUND:
The CCS serving the Turkey Point facility (comprised of multiple power generating units) is a network
of 5,900 acres of unlined canals which dissipate heat from the water used in the operation of Units 3
and 4, as well as Unit 1 when in operation. Monroe County's wellfield, which is the only water supply
for the residents of the Keys, is approximately 9.5 miles west of the CCS. The CCS is also 1.8 miles
from the Monroe County/Miami Dade County line and 3.5 miles from Ocean Reef in northern Key
Largo. A portion of the Biscayne Bay Aquatic Preserve on the eastern side of Turkey Point is also
located within Monroe County.
Although the CCS is operated as a closed -loop system, meaning no direct surface water discharges,
data shows that water from the CCS has moved beyond its boundaries. This hypersaline plume extends
two or three miles west of the CCS and continues to move westward.
PREVIOUS RELEVANT BOCC ACTION:
CONTRACT /AGREEMENT CHANGES:
STAFF RECOMMENDATIONS:
TOTAL COST: INDIRECT COST: 0 BUDGETED: Yes No
DIFFERENTIAL OF LOCAL PREFERENCE:
COST TO COUNTY: 0 SOURCE OF FUNDS:
REVENUE PRODUCING: Yes No 0 AMOUNT PER MONTH Year
APPROVED BY: County Atty _ OMB /Purchasing Risk Management
DOCUMENTATION: Included x Not Required
DISPOSITION: AGENDA ITEM #
Revised 7/09
BOARD OF COUNTY
COMMISSIONERS
Mayor Heather Carruthers, District 3
Mayor Pro Tern George Neugent, District 2
Danny L. Kolhage, District 1
David Rice, District 4
Sylvia J. Murphy, District 5
April 13, 2016
Mayor Carlos Gimenez
Stephen P. Clark Center
111 N.W. I st Street — Suite 2910
Miami, FL 33128
Dear Mayor Gimenez:
I write to share Monroe County's concerns regarding the Cooling Canal System ( "CCS ") serving
the Turkey Point facility. Our wellfield, which is the only water supply for the residents of the
Keys, is approximately 9.5 miles west of the CCS. The CCS is also 1.8 miles from the Monroe
County/Miami Dade County line and 3.5 miles from Ocean Reef in northern Key Largo. A
portion of the Biscayne Bay Aquatic Preserve on the eastern side of Turkey Point is also located
within Monroe County. We have reviewed the Miami Dade County Report date March 7, 2016
regarding the CCS, and given our mutual interests in protecting our shared environmental and
water resources, we are hopeful that opening a dialogue will result in more substantial progress
on ameliorating the problems associated with CCS operations.
The Coolina Canal System
As you are aware, the CCS serving the Turkey Point facility (comprised of multiple power
generating units) is a network of 5,900 acres of unlined canals which dissipate heat from the
water used in the operation of Units 3 and 4, as well as Unit 1 when in operation. As water
evaporates from the CCS salinity has increased over time. Additions of water into the CCS
include plant process water, rainfall, stormwater runoff, and groundwater seepage. An
approximately 18 foot deep Interceptor Ditch located along the west side of the CCS was
designed and constructed to create a hydraulic barrier to keep water in the CCS from migrating
inland or westward.
Although the CCS is operated as a closed -loop system, meaning no direct surface water
discharges, data shows that water from the CCS has moved beyond its boundaries. This
hypersaline plume extends two or three miles west of the CCS and continues to move westward.
It is pushing the saline water interface, which is now four or five miles west of the CCS. The
saline water interface is moving westward at the rate of 400 to 600 feet per year.' There is also
concern that the CCS water is migrating east into Biscayne Bay.
1 Tropical Audubon Society v. FP &L and SFWMD, Case 15- 3845, ¶ 46 (DOAH Rec'd Order Dec. 31, 2015).
Key Findings from the March 7 2016 Miami Dade County Report
We have reviewed the March 7, 2016 Miami Dade County Report on Recent Biscayne Bay
Water Quality Observations Associated with Florida Power and Light Turkey Point Cooling
Canal System Operations - Directive 152884 ( " the Report") which also includes a Notice of
Violation ( "NOV ") issued October 2, 2015 and the Consent Agreement entered into between
Miami Dade County and FPL on December 6, 2015. The NOV is related to chloride levels
which constitute violations of the water quality standards in Section 24 -42(4) of the Code of
Miami Dade County. Finally, we have reviewed the April 1, 2016 request for extension of the
timeframes in the NOV submitted by FPL to Miami Dade County as well as the April 6, 2016
response from Miami Dade granting that request to comply by May 16, 2016.
Given the proximity of the Turkey Point facility and CCS to the Monroe County line, Biscayne
Bay and our wellfield, we felt it important to highlight several aspects of the Report that cause us
concern including the following:
• Water from the CCS is migrating outside its boundaries away from the Turkey Point
facility property with impacts measured in both surface and groundwater (Pg. 5 of the
Report);
• The long term water quality in the CCS is degrading (Pg. 1 of the Report);
• Monitoring data indicate that a hyper- saline groundwater plume originating from the
CCS has migrated landward and is impacting water quality (Pg. 3 of the Report); and
• Results for tritium provide the most compelling evidence that water originating from the
CCS is reaching tidal surface waters connected to Biscayne Bay (Pg. 4 of the Report).
Monroe County's Concerns
A challenge in addressing the CCS impacts is the complexity of the multiple agencies,
authorizations and remedies being initiated. In the above list of approvals and authorizations,
some of the actions are new, some are duplicative but captured across the various authorizations.
While the Miami Dade Consent Agreement includes components of a long term plan for FPL to
address water quality issues associated with the CCS, some assert the actions on the table do not
go far enough to fully correct the situation. For instance at a recent presentation at a Palmetto
Bay Village Council Meeting (April 4, 2016) there were very different depictions on the extent
of the western edge of the hypersaline plume, it's rate of movement and whether or not the
addition of water and extraction wells will not only contain but also clean up the impacts.
Adding freshwater to the CCS to reduce salinity is a strategy being employed by FPL through the
various agency authorizations. While pumping additional water into the CCS to reduce its
salinity is already being implemented, there are concerns with potential offsite migration of CCS
water as a consequence of pumping this additional water from the L31 E Canal (along with
additional sources of water) into the CCS. The March 7 Miami Dade County Report states that
sample results have included higher than normal salinities and temperatures, as well as higher
than expected levels for chlorophyll (which can be an indication of algal blooms) and the data
indicate that those increases coincide with higher water stages within the CCS through rainfall,
discharges or whatever source (Pg. 4 of the Report). The point is that one of the key solutions
2 http: / /Palmettobay. granicus. com /MediaPlayer.php ?view_id =2 &clip_id =664
being implemented could be exacerbating the migration of the CCS outside of the system
boundaries.
Conclusions
We are working to gain a full understanding of all the solutions being proposed by the multiple
agencies involved, how those solutions will fix the situation (or not) and what can be done to
comprehensively remediate the hypersaline plume. It is our hope that all of the agencies
involved, including Miami Dade County, are working collaboratively with FPL to not only fix
the migration of water from the CCS to the west and east, but also to comprehensively develop a
solution that cleans up the discharges from the CCS. The solution is not just about stopping the
western or eastern advancement of the plume, which may be exacerbated by the introduction of
more water and /or high water stages in the CCS. The solution must also stop the migration from
occurring at all.
While we recognize that there are other influences in the region that contribute to impacts in
groundwater and surface water, that there is more data that must be collected and that there are
technical challenges to solving this problem, the migration of water from the CCS is not a new
discovery that just now warrants action. Acknowledging that, we are also concerned that there is
already delay in the implementation of the actions required in the NOV as evidenced by the
request and grant for time extensions associated with the NOV. As your neighbor sharing
concerns regarding the CCS impacts to our environmental and water resources, we'd like to
work with you in these efforts to get to a comprehensive solution with FPL and hope that by
opening this dialogue, we can assist in that effort. Please feel free to contact me at (305) 292-
3430 for any questions you might have regarding this correspondence.
Cordially,
Heather Carruthers
Mayor, Monroe County
(Attachment)
Cc: Governor Rick Scott
Eric Silagy, President & CEO Florida Power & Light
Carlos Curbelo, US Congressman, Florida Congressional District 26
Senator Anitere Flores, Florida State Senate / District 37
Holy Raschein, Florida House of Representatives / District 120
Danny Kolhage, Monroe County Commissioner District 1
George Neugent, Monroe County Commissioner District 2
David Rice, Monroe County Commissioner District 4
Sylvia Murphy, Monroe County Commissioner District 5
Roman Gastesi, Monroe County Administrator
Bob Shillinger, Monroe county Attorney
SUMMARY OF ACTIONS TO ADDRESS FPL COOLING CANAL SYSTEM
OPERATIONS
In the past year, several agency actions have been required or authorized to address the issues
regarding the migration of the CCS water by the South Florida Water Management District
( "SFWMD "), the Department of Environmental Protection ( "DEP "), the Siting Board and Miami
Dade County. Some of these actions have been authorized or required in the context of existing
agreements or regulatory approvals, some authorized or required as a result of legal actions or
enforcement in the last two years. Regardless of the impetus for the action, we do recognize that
several efforts are being made to address the issues related to the CCS impacts and the following
list may not reflect every action being undertaken, but should be considered a summary of the
most recent ones. This summary of those efforts includes:
Actions approved by the SFWMD In August 2014 FPL requested, and the SFWMD issued, an
emergency order to withdraw water from the L -31 E Canal and discharge it to the CCS to reduce
salinity and temperature. FPL sought and obtained another emergency order to use water from
the L -31E Canal during the 2015 rainy season (June 1 to November 30). On June 1, 2015, the
SFWMD provided notice of its intent to issue Individual Water Use Permit No. 13- 05856 -W to
FPL. The permit was legally challenged but ultimately issued. It authorized:
• FPL to pump up to 100 million gallons per day ( "MGD ") during the period June 1
through November 30 in 2015 and 2016 (from the L -31 E North Canal to the L -31 E
Canal where it would flow south to a point where two pumps would withdraw the
water and discharge it through two pipes into the CCS).
• The proposed permit did not identify temperature or salinity objectives, but FPL is
required to submit weekly water temperature and salinity data to demonstrate that the
water use is reducing the temperature and salinity of the water within the CCS
In addition to these actions, the SFWMD has an Agreement with FPL for the operations of the
CCS. This has been updated 5 times and in the Fifth Supplemental Agreement, FPL was
required to implement a surface water and groundwater monitoring program in and around the
CCS. This program includes monitoring data for water levels, fluid density, salt concentrations,
and conductivity from 42 groundwater monitoring wells. FPL also collects water level data at
seven locations within the CCS on an hourly basis. 1
Actions approved by the Siting Board: On September 5, 2015, FPL filed a petition to modify the
Conditions of Certification for Turkey Point Units 3, 4, and 5 under the Power Plant Siting Act,
Chapter 403, Part II, F.S. including improvements to the Plant for CCS salinity and temperature
management purposes. These Conditions of Certification were approved by DEP and were
legally challenged but upheld. On March 29, 2016, the Governor and Cabinet sitting as the
Siting Board met to "consider a proposed Final Order approving Florida Power & Light
1 Tropical Audubon Society v. FP &L and SFWMD, Case 15 -3845, 1 46 (DOAH Rec'd Order Dec. 31, 2015).
Company's request to modify the Power Plant Siting Act Conditions of Certification for the
Turkey Point Power Plant ". The modifications include:
• Construction and operation of new Upper Floridan Aquifer ( "UFA ") production wells
for the addition of 14 million gallons per day ( "MGD ") to the CCS to lower salinity;
• Utilization of one of the new production wells to comply with a recent order of the U.
S. Nuclear Regulatory Commission related to availability of emergency cooling water
for Units 3 and 4;
• Re- allocation of authorized water withdrawn from the existing well utilized for Unit
5, as a source of process water for Units 3 and 4; and
• Monitoring the proposed production wells and reporting the information to DEP, the
SFWMD, and Miami -Dade County.
Actions Required by Recommended Order in case Appealing DEP's Administrative
Order: On December 23, 2014, DEP issued an Administrative Order OGC No. 14 -0741 ( "the
AO ") related to the CCS. That Administrative Order was legally challenged and is currently
pending amendment or rescission by DEP pursuant to a Recommended Order (required by the
middle of May 2016). It currently requires:
FPL to submit a Salinity Management Plan that includes an analysis of the factors
contributing to the western movement of saltier groundwater and options that could
eliminate the CCS's contribution. The primary goal of the Management Plan shall be
to reduce the hypersalinity of the CCS to abate westward movement of CCS
groundwater into class G -II (< 10,000 mg /L TDS) groundwaters of the State.
Monitoring salinity in the CCS and reporting to the agencies to determine the
effectiveness of salinity management operations.
Actions Required by the Miami Dade County Consent Agreement: On October 6, 2015,
Miami Dade County and FPL entered into a Consent Agreement to resolve a NOV and Order for
Corrective Action for a violation of Chapter 24 of the Code of Miami Dade County. It requires:
• Construction of Floridan wells (also required by Siting Board below)
• Continue use of already- operating marine wells
• L -31E discharges to the CCS
• Evaluation of alternative water sources
• Evaluation of Interceptor Ditch operations
• Biscayne Aquifer Recovery Well System to intercept, capture and address the plume
with further evaluation based on modeling to supports its design
• Raise control elevations in Everglades Mitigation Bank and fill in portions of
wetlands in Everglades Mitigation Bank
Z Staff Report, March 29, 2016 for Item #2, "Florida Power & Light Company Final Order /Modification to Conditions
of Certification /Turkey Point Power Plant (Units 3 -5)."
■ Further monitoring, mapping and data reporting