Item T1County of Monroe
<r
BOARD OF COUNTY COMMISSIONERS
�
Mayor David Rice, District 4
IleOI1da Keys
��x
t t 0.
Mayor Pro Tem Sylvia J. Murphy, District 5
Danny L. Kolhage, District I
P f,<
George Neugent, District 2
a
Heather Carruthers, District 3
County Commission Meeting
March 21, 2018
Agenda Item Number: T.1
Agenda Item Summary #4002
BULK ITEM: No DEPARTMENT: County Administrator
TIME APPROXIMATE: STAFF CONTACT: Lindsey Ballard (305) 292 -4443
11:45 A.M. SOUNDING BOARD
AGENDA ITEM WORDING: Request to speak to the Board of County Commissioners by Laura
Reynolds, Founding and Managing Member of Conservation Concepts, LLC in regards to Florida
Power and Light.
ITEM BACKGROUND:
PREVIOUS RELEVANT BOCC ACTION:
CONTRACT /AGREEMENT CHANGES:
N/A
STAFF RECOMMENDATION:
DOCUMENTATION:
Sounding Board Presentation request
FINANCIAL IMPACT:
Effective Date:
Expiration Date:
Total Dollar Value of Contract:
Total Cost to County:
Current Year Portion:
Budgeted:
Source of Funds:
CPI:
Indirect Costs:
Estimated Ongoing Costs Not Included in above dollar amounts:
Revenue Producing:
Grant:
County Match:
Insurance Required:
Additional Details:
If yes, amount:
REVIEWED BY:
Bob Shillinger Completed 03/06/2018 5:22 PM
Kathy Peters Completed 03/06/2018 5:24 PM
Board of County Commissioners Pending 03/21/2018 9:00 AM
From:
Laura Revnolds
To:
Ballard - Lindsey
Cc:
Tennyson -Lisa
Subject:
Sounding Board Presentation request
Date:
Tuesday, March 06, 2018 4:37:16 PM
This is an official request to be on the sounding board to present about Florida Power and
Light.
Thank you,
LR
Laura Reynolds
Founding and Managing Member
c: (786) 543- 1926
lrc nol sna,conseryationconce tsl lc.org
Florida Keys
Aqueduct Authority
1100 Kennedy Drive ,
Key West, Florida 33040 D
Telephone (305) 296 -2454
www.fkaa.com
Press Release
For Immediate Release
J. Robert Dean
Chairman
District 3
Richard J. Toppino
Vice - Chairman
District 2
David C. Ritz
Secretary/Treasurer
District 5
Antoinette M. Appall
District 4
Cara Higgins
District 1
Kirk C. Zuelch
Executive Director
Media Contact: Julie Cheon (305) 295 -2150, (305) 814 -7333. jcheon @fkaa.com
FKAA Board of Directors Advocates for Decommissioning of Turkey Point Cooling Canals
Florida Keys — March 2, 2018 - The FKAA Board of Directors listened to a compelling presentation
regarding the advancement of hypersaline waters from Florida Power and Light's Cooling Canal
System (CCS) at the Turkey Point Nuclear Power Plant in Miami -Dade County.
FPL currently utilizes 168 miles of cooling canals as a recirculating system to cool its two nuclear
reactors which is the only system of its kind still allowed in the United States. Since initial operation
back in 1973, evaporative losses were replenished with seawater from Biscayne Bay resulting in a
hypersaline water that has been leaching into and contaminating the Biscayne Aquifer. This
underground plume of hypersaline water is actively monitored by FKAA, and although not an
immediate threat, it has been advancing radially at a rate of approximately one mile every 10 years.
This plume is of significant concern as it threatens to contaminate the primary source of drinking
water for FKAA, and thus of all Monroe County, if left unfettered.
Recently both Miami -Dade County and the State of Florida have required remedial action on the part
of FPL to halt and retract the plume. In addition, Miami -Dade is considering partnering with FPL to
build a wastewater treatment plant in a cost - sharing arrangement that would utilize recycled water
generated from the new facility to freshen the CCS with a less saline water supply. In updating the
FKAA Board, consulting hydrogeologist Kirk Martin explained that this action would increase the head
pressure on the existing underground hypersaline plume resulting in continued radial expansion of the
plume. While using recycled water as makeup to mitigate evaporative losses in the CCS is a positive
step, implementing this option would not address the existing contamination already threatening
FKAA's water supply, and would continue to exacerbate the existing threat.
While the Board recognizes the benefit of FPL collaborating to produce millions of gallons of reclaimed
water, it feels strongly that FPL must:
1. Halt movement and remediate the existing underground hypersaline plume It created; AND
2. Prevent any further contamination of the Biscayne Aquifer by its operations; AND
3. Decommission the CCS and replace them with cooling towers, which is a more modern and
industry- standard technology that will prevent any potential water supply contamination.
The Board has directed staff to aggressively advocate this position to both State and Federal
regulatory agencies and elected officials to insure the concerns are heard and action is taken.
Page 1 or 1
Turkey Point 3 & 4 Cooling Tower Retrofit
Is Feasible and Cost - Effective'
Turkey Point cooling canals have been retrofit
Turkey Point Nuclear Units 3 and 4 began
operation in 1972 and 1973 drawing and
discharging water from Biscayne Bay.
Natural gas -fired combined cycle Turkey Point
Unit 5 began operation in 2007. Unit 5 was built
with a cooling tower. Oil- and gas -fired Units 1
and 2 are retired.
■ s
taim
Initially cooling water was drawn from Biscayne
Bay at an intake point just north of Turkey Point
and was discharged back into the Bay via a
series of short canals just south of Turkey Point. The heated discharge resulted in fish kills,
reduced benthic seagrass communities, and loss of coral colonies in the vicinity of the
discharge.
A federal judge issued an order prohibiting FPL from discharging heated water into
Biscayne Bay, Card Sound or any other navigable water, due to the biological damage
caused by the thermal pollution from the discharge.
Closed -loop cooling water canals were constructed at Turkey Point, in response to the
order, to handle all the cooling water needs and process wastewater.
The cooling canal system (CCS) consists of 32 shallow cooling canals, each about 5.2
miles long, through which cooling water flows before returning to the intake system. The
CCS provides about 10 square miles of water surface area.
The polluting of Biscayne Bay, threats to the Everglades, and aquifer damage are
several reasons that cooling towers are being proposed to replace the CCS.
March 2018
1 For more information, see: Closed Cycle Cooling Tower Feasibility Assessment for Turkey Point Nuclear Units 3
and 4, July 2016, Powers Engineering. Available at: http://www.cleanenergy.org/wp-
content /uploads /PowersReport on Cool ingTowerFeasibility Assessment TurkeVPoint- Nuc1ear2016.pdf
Palisades Nuclear Plant was retrofitted to cooling towers about the same time
Another nuclear plant, the 800 MW Palisades Nuclear plant in Michigan, began
operation in early 1972 utilizing a once - through cooling system drawing water from Lake
Michigan. Subsequently the cooling system was converted to closed -cycle cooling. The
retrofit cooling towers became operational in May 1974.
Palisades Nuclear agreed to convert to wet cooling towers, and to make modifications
to the radwaste system, as the result of a settlement agreement. The cost of the
cooling tower retrofit was $18.8 million in 1973. Had FPL opted to construct cooling
towers for Units 3 & 4 in the early 1970s as Palisades did, there would be no controversy
now over environmental damage caused by the CCS and the costs to FPL customers.
FPL included cooling towers in design of proposed nuclear Units 6 & 7
FPL included round mechanical draft wet cooling towers in the design of proposed
nuclear Units 6 and 7 at Turkey Point.
Retrofit cooling towers for Units 3 & 4 are technically feasible & cost - reasonable
The approximate capital cost of wet cooling towers, including both Unit 3 & 4, would be
in the range of $220 to $310 million.
The source of makeup water for the Units 3 & 4 cooling towers would be reclaimed
water from the Miami -Dade Water and Sewer Department.
An onsite reclaimed water storage pond would assure cooling tower make -up water
supply reliability in the event of temporary reclaimed water supply interruptions.
A zero liquid discharge system would be utilized to treat blowdown from the Units 3 & 4
cooling towers to eliminate wastewater discharges to the environment.
All cooling tower construction activities can proceed with Units 3 & 4 online, with the
exception of the final sealing of the CCS canal entrances to isolate circulating water
flow. The isolation of CCS canal entrances can be coordinated with a refueling outage,
or other periodic planned extended outage, to avoid any forced outage time.
The retrofit cooling towers will remove heat in the circulating cooling water associated
with power generation. Some additional heat, in range of 1 to 2 percent of the total,
must be removed from cooling water serving onsite safety - related equipment. This is
known as the Ultimate Heat Sink (UHS) cooling system.
Either the existing UHS cooling system for Turkey Point Units 3 & 4 can continue to be
utilized without modification, or small cooling towers, for instance, can be added for this
purpose, as is the practice at some other southeastern nuclear plants, such as the
Waterford nuclear plant in Louisiana.
Units 3 & 4 provide about 10 percent of the electricity delivered by FPL. The cost of retail
electricity delivered by FPL to customers would increase about 1 percent with the
addition of retrofit cooling towers on Units 3 & 4.
Z 2002, EPA 316(b) Technical Development Document, p. 4 -3.
3 Ibid.
4 Ibid, p. 4 -5.
5 International Atomic Energy Agency, Efficient Water Management in Water Cooled Reactors, 2012, Figure 5, p. 8.
March 2018
March 1, 2018
Mayor Carlos Gimdnez
Stephen P. Clark Center
111 N.W. 1st Street, 29th Floor
Miami, Florida 33128
RE: Suggested improvements to the Joint Participation Agreement between Florida Power
& Light and Miami -Dade County for wastewater reuse
Dear Honorable Mayor Carlos Gimdnez,
On behalf of the undersigned organizations, we submit the following comments related to Miami
Dade County's draft Joint Participation Agreement (JPA) with .the Florida Power & Light
Company (FPL) over the treatment and use of wastewater at FPL's Turkey Point facility and the
draft resolution authorizing the execution of the, JPA. On, February. 9, 2018 we had the
opportunity to meet with your staff after, the deferral of the proposed JPA at the Chairman's
Policy committee meeting on February 8, 2018. This letter is a follow up to our meeting and the
prior discussion.
We applaud both parties for identifying possible solutions to three pressing problems plaguing
Miami -Dade County — (1) the need to treat and reuse 117 million gallons per day (MGD) of.,
wastewater by 2025, as mandated by the 2008 Leah Schad Memorial Ocean Outfall legislation;
(2) the need to find a long -term, sustainable water supply for FPL's Turkey Point facility, Miami
Dade County's biggest water user; and (3) the need to deliver. clean, fresh water to Biscayne Bay
and Biscayne National Park (via wetland rehydration through. the Biscayne Bay Coastal
Wetlands and/or the Model Lands close to the South Dade Wastewater Treatment Plant).
While we remain optimistic about the potential of this comprehensive solution, several changes
must be. made to the JPA to clarify goals . for this partnership and to. inform next steps for
discussion and design. County staff presented its document as an "agreement to discuss." In fact,
the JPA is a legal document enforceable by injunction. Further, this agreement commits the
County to several actions, but omits requirements we believe to be imperative: strict water
quality standards for treated wastewater and specific measures to generate additional highly
treated wastewater for the purposes of ecological restoration. This agreement has the potential to
resolve multiple, long -term problems plaguing Biscayne Bay if the JPA adequately incorporates
the following considerations:
1. A commitment by Miami - Dade „ County to continue to' seek decommissioning of Turkey
Point's cooling canal. system and implementing . upgrades to the cooling technology, and to
maintain regulatory and operational control over the wastewater treatment facility and reuse
water.
2. Any reclaimed wastewater treated for use at the Turkey Point facility must meet non-
degradation water quality standards for release into Biscayne Bay.
3. A commitment to .explore options to allocate a meaningful portion of treated wastewater for
Biscayne Bay restoration and wetland rehydration.
Page 1 of 6
The following information provides explanations to support the above.
1) A commitment by Miami -Dade County to continue to seek decommissioning of
Turkey Point's cooling canal system and implementing upgrades to the cooling
technology, and to maintain regulatory and operational control over the wastewater
treatment facility and reuse water.
We acknowledge the County's continued efforts to protect Biscayne Bay and the Biscayne
Aquifer from the massive amount of pollution emanating from Turkey Point. We urge the
County to continue regulating the facility to protect the surrounding environment from further
contamination. On July 19, 2016, Miami -Dade County passed a resolution urging you to seek a
commitment from FPL to discontinue the use of the Turkey Point cooling canal system (CCS) by
2033 and to replace the outdated, failing CCS with current cooling technologies; such as cooling
towers. The proposed JPA appears to conflict with this resolution: it excludes any reference to
the County's goal of retiring the CCS. The' County must maintain their commitment outlined in
the aforementioned resolution to have FPL end reliance on the cooling canals by 2033 and
upgrade the cooling technology, since reuse water can be used for other cooling technologies that
do not cause widespread pollution.
Currently, FPL is seeking support from Miami -Dade County for its 20 -year Subsequent License
Renewal'Application (SLRAJ with the U.S. Nuclear Regulatory Commission (NRC) for Turkey
Point Reactor Units 3 and 4. If granted, the license would extend the operational life of these
units to 2053 for an additional twenty years beyond its current'license. We remain concerned that
the JPA, in its current form, represents tacit support. from the County for FPL's proposed
relicensing plan without the County first having carefully reviewed the SLRA and accompanying
operational plans. In addition, as FPL proposes to use County reuse water for water supply in the
cooling canals presumably through the relicensing period, the County must urge FPL to switch
from using cooling canals to commonly used cooling technologies that are less polluting, such as
cooling towers. The County must maintain its regulatory authority and legal right to engage in
this license renewal process, which could include proposing required conditions of license
renewal, such as FPL updating Turkey Point's cooling technology
We also have concerns that this arrangement may put Miami -Dade County in a position of
dependence on FPL to achieve compliance with the mandates of the 2008 Ocean Outfall
legislation. If FPL is for some reason unable to move forward with the partnership or an
agreement on partnership terms cannot be reached, the County may find itself without a partner
for wastewater reuse. We therefore urge the County to pursue alternative avenues to comply with
Ocean Outfall legislation. First, the County should restart discussions on the South Dade
Wastewater Reuse project, as outlined in the Comprehensive Everglades Restoration Plan
(CERP). This project includes a cost -share opportunity with the federal government and would'
result in the use of treated wastewater for ecological restoration to the County's benefit. Finally,
Resolution supporting the County Mayor in efforts to seek a commitment from Florida Power and Light Company
to discontinue use of the cooling canal system at the Turkey Point Power Plant, Miami Dade County Board of
County Commissioners, July 19, 2016. Available at
httl2://www.miamidade.gov/govaction/matter.asp?matter 61617 &fi le= true &yearFolder=Y2016
Page 2 of 6
we believe that the County must maintain regulatory and operational. control over the wastewater
treatment facility and reuse water it generates. Any agreement with FPL must .incorporate
language to ensure the County maintains such control.
2) Any reclaimed wastewater treated for use at the Turkey Point facility must meet
non- degradation water quality standards for release into Biscayne Bay.
As outlined in numerous ongoing studies and reports, most notably the 2015 tritium analysis
study by Dr. David I Chin, the cooling canal system at Turkey Point has direct hydrologic
connections to the underlying class G -II Biscayne Aquifer and Biscayne Bay. through
underground seepage via oolitic limestone and canal cuts. According to the County's own
analysis, contaminated water from the cooling canals was detected in Biscayne Bay and
Biscayne National Park with elevated levels of ammonia, phosphorus, TKN, total nitrogen, and
chlorophyll a. All pollutants contained in waters added to the cooling canals are subject to
concentration via evaporation and eventual export into the Biscayne Aquifer and surface waters
of Biscayne Bay, an Outstanding: Florida Water body (OFW), and Biscayne National Park..As
such, any water. added to the cooling canals must meet water quality standards suitable for
release into Biscayne Bay.
As written, the JPA could allow for further pollution of the Biscayne Aquifer, Biscayne Bay, and
Biscayne National Park because it does not require that reuse water to be used at Turkey Point
meet strict water quality standards. Wastewater is rich in nutrients such as nitrogen,..phosphorus
and ammonia. Biscayne Bay is a phosphorus- limited system and is extremely sensitive to the
addition of excess nutrients. Increasing nutrient pollution in Biscayne Bay has the potential to
destabilize aquatic communities, such as seagrass beds, with increased turbidity, algal blooms,
epiphyte loads, and anoxia.
Reuse water used in the cooling canal system (or for other beneficial uses such as wetland
rehydration) must be treated to the non - degradation. water quality target standards for Class
III/Outstanding Florida Waters: (OFW), requiring that discharges not degrade ambient water
quality at a discharge site. The Biscayne Bay Coastal Wetlands Rehydration Project Delivery
Team analyzed possible impacts of rehydrating the Biscayne Bay Coastal Wetlands with highly -
treated reclaimed wastewater, including potential effects to the ecosystem. The 2003 Treatment
Objectives Draft Report by the U.S. Army Corps of Engineers - South Florida Water Management
District identified target non- degradation standards for use in Biscayne Bay in Table 5.1 of the
report. The 2011 Biscayne Bay Coastal Wetlands Rehydration Pilot Project found: that it was
possible to meet these non - degradation targets with highly treated wastewater. Target water
2 The Cooling -Canal System at the FPL Turkey Point Power Station, Chin, 2015, University of Miami.
3 Miami -Dade County Report on Biscayne Bay Water Quality Observations associated with the Turkey Point
Cooling Canal System Operations, March 7, 2016, Memorandum from Carlos A. Gimdnez, Mayor, to Chairman
Jean Monestime and Members, Board of County Commissions, p. 4.
4 As determined for Class III/Outstanding Florida Waters & the Biscayne Bay Coastal Wetlands Rehydration Pilot
Project: Pilot Plant Closeout Report. July 2011. Table 2 -1.
5 Effects of Nutrient Enrichment on Seagrass Population dynamics: evidence and synthesis from the biomass—
density relationships, Cabaco, et al. 2013, Journal of Ecology DOI 10.1111/1365- 2745.12134
6 U.S. Army Corps of Engineers & South Florida Water Management District,.Treatment Objectives Draft Report,
September 25, 2003, Wastewater Reuse Pilot Project Miami -Dade, p. 10.
Page 3 of 6
quality standards are enumerated in that report in Table 2 -1:' Water from the cooling canals
discharges directly into the Biscayne Aquifer and Biscayne Bay. Therefore, County reuse water
used by FPL to freshen the cooling canals must meet non = degradation standards for Biscayne
Bay.
The County has been proactive in holding FPL accountable for the widespread environmental
contamination caused by the cooling canals system at Turkey Point. It would be inconsistent for
the County to now allow FPL to add the County's own. wastewater to the cooling canals if that
water further contributes to the pollution of the Biscayne Aquifer and Biscayne Bay. We ask that
the County explicitly reference these water quality standards as a goal of the partnership in the
JPA.
3) A commitment to explore options to allocate a meaningful portion of treated
wastewater for Biscayne Bay restoration and wetland rehydration.
Biscayne Bay and Biscayne National Park are ecological treasures and significant contributors to
the economy of Miami -Dade County. However, Biscayne Bay is chronically starved for
freshwater, as are the surrounding wetlands that feed the Bay. Lack of freshwater flow has
caused damage to important habitats, including freshwater wetlands, mangrove forests, coral
reefs, tidal creeks, and near -shore ecosystems. Fish and wildlife, including threatened and
endangered species like the wood stork and American crocodile, are struggling to survive due to
severe habitat alteration. Furthermore, declining fish populations have harmed local fishing and
tourism industries. Restoring freshwater flow to the ecosystem, particularly through the Biscayne
Bay Coastal Wetlands (BBCW) project, will help to restore coastal wetlands and tributaries: It
will lower nearshore salinity levels and improve nursery habitat for fish and shellfish.
In addition to benefitting the health of local ecosystems, steps toward restoring Biscayne Bay
and Biscayne National Park will provide key economic and social gains for our communities. In
the wake of the spate of recent hurricanes that devastated many of our nation's coastal areas, the
County must work to improve the resilience of our communities to future storm events. Healthy,
robust wetlands act as critical buffers between communities and the impacts of hurricanes and
storm surge. Restoring Biscayne � Bay will help to improve shorelines and other' coastal
ecosystems in southern Miami -Dade County, thus enhancing shoreline resiliency. Moreover,
increasing freshwater flow to coastal areas and contributing to aquifer recharge will help buffer
against saltwater intrusion, protecting the drinking water supply for nearly 8 million people in
South Florida.
Miami -Dade County has long been a champion of restoring Biscayne Bay, particularly through
supporting the BBCW _project. Unfortunately, progress on the project, particularly, in terms of
advancing planning for. BBCW Phase II, has been stymied by an apparent absence of freshwater
needed for restoration. Using highly- treated wastewater from Miami -Dade County was always
considered to be an option but was tabled due to high cost estimates due to an energy- intensive
treatment process. However, with Miami -Dade County now considering a 'cost -share
arrangement with FPL to construct and operate a wastewater treatment facility, there is a huge
Miami =Dade County Water & Sewer Department, Biscayne Bay Coastal Wetlands Rehydration Pilot Project, Pilot
Plant Closeout Report, July 2011, p. 2 -7.
Page 4 of 6
opportunity to reinitiate discussions as to how highly- treated wastewater from the County could
be used for ecological restoration. It is imperative that the JPA explicitly contemplate providing
a meaningful supply of additional reuse water for Biscayne Bay restoration and rehydration.
Further, we urge the County to reinitiate discussions with the U.S. Army Corps of Engineers
regarding the South Dade Wastewater Reuse project and BBCW, as authorized in CERP, to
identify potential avenues for using highly- treated wastewater for restoring Biscayne Bay and
achieving a federal cost share partner.
Overall, we believe that this agreement, if executed properly, truly has. the potential to provide a
comprehensive solution to numerous problems by: 1) providing �a sustainable; long -term water
supply and upgraded cooling technology system for Turkey Point, 2) meeting legal requirements
for County wastewater reuse, and 3) providing a clean, freshwater supply for the restoration of
Biscayne Bay and Biscayne National Park. However, in order to ensure a "win- win - win," the
County must address the concerns outlined by this letter. We look forward to supporting a
revised agreement at the upcoming March 8, 2018 Chairman's Policy Committee meeting. This
is an exciting opportunity and we see the potential for this agreement to benefit both the health of
Biscayne Bay and the future of Miami -Dade County.
Please find attached an Appendix which includes: (1) The Closed Cycle Cooling Tower
Feasibility Assessment for Turkey Point Nuclear Units 3 and 4, Bill Powers, July 2016, Powers
Engineering; (2) Treatment Objectives Draft Report, Keiser- Lopez, 2003, U.S. Army Corps of
Engineers -South Florida Water Management District; and (3) Class III /Outstanding Florida
Waters & the Biscayne Bay Coastal Wetlands Rehydration Pilot Project: Pilot Plant Closeout
Report, July 2011.
Please contact Laura Reynolds with any questions you may have regarding the content of this
communication, 786 -543 -1926 or lreynoldsnconservationconcentsllc .org
Sincerely,
Alan Farago
Conservation Chair, Friends of the Everglades
alanfaragogme.com
Rachel Silverstein, Ph.D.
Executive Director & Waterkeeper, Miami Waterkeeper
rachel@miamiwaterkeeper.org
Caroline McLaughlin
Biscayne Program Manager, National Parks Conservation Association
cmclaughlin@npca.org
Stephen A. Smith
Executive Director, Southern Alliance for Clean Energy
sasmithkcleanenergy.org
Page 5 of 6
Erin Clancy
Conservation Director, Tropical Audubon Society
conservationstrobicalaudubon .oro
cc: Chairman Esteban Bovo and the Miami -Dade Board of County Commissioners
Jack Osterholt,.Deputy Mayor, Miami -Dade County, Regulatory and Economic Resources
Lee Hefty, Director, Miami -Dade County Division of Environmental Resources Management
Kevin Lynskey, Director, Miami -Dade County Water and Sewer Department
Abigail Price - Williams, County Attorney, Miami -Dade County
Dennis Kerbel, Assistant County Attorney, Miami -Dade County
Henry Gillman, Assistant County Attorney, Miami -Dade County
Appendix
Page 6 of 6