tritium

Turkey Point Power Plant seen from Bay side.
Used with permission from FP&L

This is the second installment in the series. You can find the first installment here. This post is focused on answering the following question.

• Is the Turkey Point power station violating the Clean Water Act (CWA)?

Bottom line up front (BLUF): FP&L is complying with the Clean Water Act at Turkey Point. SACE’s contentions are wrong and based on faulty assumptions. SACE is not acting on this issue because it is a pressing water pollution issue. It is seeking to capture media attention using scary words like “tritium” and “radioactive.”

It is interested in shutting down two operating emission-free nuclear plants and in stopping the plant’s planned expansion.

SACE allegations and intent to file citizens’ suit under CWA

On March 22, 2016, the Southern Alliance for Clean Energy (SACE) issued a press release headlined Citizen groups signal intent to file Federal lawsuit against Florida Power and Light (FPL), citing radioactive elements and other water pollution discharged into Biscayne Bay. The press release was accompanied by a press conference, which was covered by CBS Miami in a segment titled Environmental Groups To Sue FPL Over Reported Turkey Point Leak, shown below.

Aside: I’d bet that Stephen Smith and Laura Reynolds, both from SACE, flew from their headquarters in Knoxville, TN to Miami, FL via a private plane owned by Turbo Arrow Aviation LLC. According to SACE’s 2014 IRS form 990 schedule L “Transactions with Interested Persons”, the non-profit organization entered into a five-year agreement beginning in August 2012 that pays Turbo Arrow Aviation $1,000 per month for priority scheduling to transport staff members to meetings throughout the southeast. Actual flight time is compensated at a rate of $275 per hour.

This arrangement met the reporting criteria because Turbo Arrow Aviation is an LLC owned by Stephen Smith, the Clean Energy group’s Executive Director and one of the stars of the press conference. In 2014, the arrangement resulted in a payment of $152,649 to Smith’s charter air transportation LLC. That indicates that company spent 511 hours in the air transporting SACE staff members to meetings and press conferences.

I wonder who was flying the company’s plane on August 22, 2012 when it chose an unusually wet place to land. Could there be a relation between the effects of that landing and the new arrangement with SACE? End Aside.

Here are some quotes from the press release.

Last week, following an extensive review of the growing body of evidence documenting leaks of radioactive elements and other pollutants into Florida surface and ground water, the Southern Alliance for Clean Energy and Tropical Audubon Society issued a 60-day notice of intent to file a citizen lawsuit against Florida Power & Light (FPL) under the Clean Water Act (CWA).
…
Among those contaminants is tritium, a radioactive isotope of hydrogen produced by nuclear reactors most often found as a groundwater contaminant at nuclear plants. Radioactive tritium has been documented in both surface and groundwater outside the Turkey Point nuclear complex and studies confirm a growing plume of hyper-saline water and other pollutants in all directions including into the Biscayne Aquifer.
…
Section 301(a) of the Act U.S.C. § 1311(a), prohibits the discharge of pollutants from a point source to waters of the United States except in compliance with, among other conditions, a National Pollutant Discharge Elimination System (NPDES) permit issued pursuant to section 402 of the Act, 33 U.S.C. § 1342. Each violation of the permit, and each discharge that is not authorized by the permit, is a violation of the CWA.
FPL has violated and is violating its NPDES Permit by unauthorized discharges of the pollutants, including, but not limited to, excess salinity, phosphorus, ammonia, TKN, total nitrogen, and radioactive tritium, into waters of the United States in Biscayne Bay. Additionally, FPL has violated its NPDES Permit by discharges of hyper-saline water contaminated with radioactive tritium into ground water, threatening the water supply for Miami-Dade County and the Florida Keys. FPL has also violated the Clean Water Act by discharging pollutants without an NPDES permit and causing violations of water quality standards in Biscayne Bay, which is protected from degradation as an Outstanding National Resource and Outstanding Florida Waters.

I called the media contact number provided in the press release and left a message that included an article deadline as requested. After the deadline passed, I called again and spoke to a pleasant young lady who informed me that her boss had tried to call back but wasn’t able to reach me. We diagnosed that the person who had passed the message had transposed a couple of numbers in my area code.

Sarah told me that her boss now had a new phone number but was no longer in the office. It was nearing 6:00 pm on Good Friday, so she commiserated with me as someone else who was working late on a holiday weekend.

At about 7:30 Dr. Smith returned my call. I admire his devotion to his work.

We did not exactly get off on the right foot. I asked him why the Southern Alliance for Clean Energy was attacking a clean power producer. He reacted by asking me if I had done my homework and read the intent to sue and the study used as the basis for that notice. At the time, I had not. I’d overlooked the links to the documents in the press release.

After admitting my failure to have done all the reading before calling, I tried to get us back to my questions. He was adamant that his organization was not going after Turkey Point because it was a nuclear plant, but because it was an industrial facility that was violating the Clean Energy Act and not being forced by regulators to stop polluting the Bay and the aquifer.

He explained that his organization recognized that the tritium levels that the studies had measured were well below the EPA’s allowable limit for drinking water. He admitted that the Bay wasn’t a drinking water source because it is a body of salt water and that the nearest drinking water wells were several miles from the cooling canal system.

I noted that the other pollutants noted in his organization’s press release are not produced in nuclear power plants. I mentioned that they are produced by natural processes within salty estuaries and by common South Florida facilities like farms, limestone rock mining, and suburban homes with lawns and swimming pools.

He insisted that the documents I had not yet read would convince me that the cooling canals were the source of the pollutants. He also accused me of pro-nuclear bias (guilty as charged) and reiterated that the objection to Turkey Point was not because it was a nuclear facility. We began getting a little loud and stopped waiting for the other to complete their thoughts.

He told me that if I had any journalistic integrity, I would read all of the relevant documents and then perhaps be more willing to ask him reasonable questions. I told him that if he had any “clean energy integrity” he would call off his attack and realize that the pollution he was claiming violated the Clean Water Act wasn’t harming the environment.

He angrily told me it didn’t matter whether or not there was any harm yet; what mattered was that FP&L was violating its permits by discharging water containing contaminants from a part of the plant in which discharges were not allowed. He said no one is allowed to break the law and that it’s not okay for FP&L to downplay the issue.

When I asked how he could say there were “discharges” when there are no pipes or other connections between the canals and the surrounding wetlands or waterways, he told me to go do my reading and ended the call.

Canal system is not in violation of any permits

As explained in part I of this series — which I wrote after having spoken with Dr. Smith and after having read both the SACE intent to sue and the paper produced by University of Miami’s Dr. Chin — tritiated water has been evaporating from the Turkey Point cooling canal system since Unit 3 first began operating in 1973.

It is perfectly legal and environmentally harmless for FP&L to discharge allowed quantities of tritium-containing water from its nuclear units into the canal system. That system has an NPDES as an industrial wastewater facility.

A competent researcher should expect to find measurable tritium in the waters and wetlands near the cooling canal. She should also be able to measure that tritiated water has percolated through the soil and that concentrations of tritium fall with increasing distance from the source.

In 2011, when the Nuclear Regulatory Commission was reviewing FP&L’s application for an Extended Power Uprate for Turkey Point Units 3 & 4, Mr. Steve Torcise, Jr. of Atlantic Civil, Inc. filed a comment alleging that the cooling canal system was obviously not a closed system and that it was in violation of its permit.

Mr. Torcise additional claimed that his employer had been harmed by the saltwater intrusion he and some researchers have attributed to the Turkey Point CCS because they were required to perform costly monitoring to prove that salt water had not intruded onto the boundaries of their limestone mine. Here is a quote from the NRC’s response to Mr. Torcise’s comment.

The CCS is operated under an industrial wastewater facility “No Discharge” National Pollutant Discharge Elimination System (NPDES) permit issued by the State of Florida Department of Environmental Protection (FDEP) for water discharges to an onsite closed-loop
recirculation cooling canal system.

In this case, closed-loop recirculation means that the cooling canal does not have a pipeline connection with water bodies surrounding the PTN site such as Biscayne Bay for receiving or discharging its water. Monitoring data show that there is indirect surface water communication between the CCS and Biscayne Bay. The NRC staff revised the surface water and aquatic resources sections in the final EA to clarify that there is some water exchange between the cooling canal and other water systems and that aquatic species within the cooling canal are unable to travel into or out of the canal system.

Of course, non aquatic species like birds, snakes, turtles and crocodiles are free to come and go into the CCS as they please. Winds, water vapor, pollen, seeds and leaves are not prevented from flowing across the surface boundary of the open canals.

What about chemicals besides tritium?

When my wife was working for the Chesapeake Bay foundation, I learned that water quality experts lump substances like phosphorus, ammonia, TKN (Total Kjeldahl Nitrogen), and total nitrogen into a larger category of pollutants called “nutrients.” Even though these substances have numerous natural sources, they can have harmful effects in bodies of water because they stimulate algae growth, have the potential for scavenging dissolved oxygen, and can fertilize invasive plant species.

However, those substances are not generally used or produced in nuclear or fossil fuel power plants. Here is what Dr. Chin’s study (pg 9) says to explain why they are found in the CCS.

The addition of nutrients from the power-generating units into the CCS is assumed to be negligible, with nutrients likely originating from allochthonous sources.

I had to look up allochthonous. I found a useful article titled When a tree falls in a stream, there’s always something around to make use of it. The introduction to that piece explains allochthonous as follows.

Allochthonous may have some obscure usage related to rocks, but in ecology, allochthonous material is a major concept that underpins thinking about nutrient cycling and food web dynamics. In its most general definition, allochthonous material is something imported into an ecosystem from outside of it. Usually, ecologists are thinking about organic matter and the nutrients (C, N, and P) that come with it.

If CCS isn’t leaking, why are salinities and temperatures elevated?

As a condition of its NPDES permits and the environmental assessment issued in support of the Extended Power Uprate, FP&L has been monitoring its CCS, the surrounding waters and the adjacent wetlands. It has continuous indication of the temperature of the plant discharges into the CCS and the intake temperature from the CCS.

During the period from 2012-2014, the CCS experienced a drought. Measured rainfall for 2012 and 2013 was about 110 inches less than what would have normally fallen during a two year period. As a result of continued evaporation and vastly reduced freshwater input, the CCS temperature climbed and the salinity concentration increased.

The simplest, cheapest, and arguably lowest environmental impact solution for high temperatures and salinity was to obtain permission to move up to 100 million gallons of water per day from a nearby flood control canal into the CCS. Permission was granted in September 2014 from the local water management district and the board of county commissioners to install a temporary pump and pipeline network and implement that solution.

Some of the plant’s neighbors, including the still-complaining Atlantic Civil, Inc.–the same entity that tried to halt the power uprate–don’t like the solution. They have petitioned regulators to impose harsher penalties. The opposition is calling for remedies like lining the canal system, flushing out the existing inventory (with an unspecified source of clean water and an unspecified discharge location), or shutting down the power plant. They’re also blaming the extended power uprate.

“If they don’t flush out all this stuff, it’s not going to operate properly. And we’re saying no way are you going to flush out this pollution to our wellfields and Biscayne Bay,” said Tropical Audubon executive director Laura Reynolds. “They [expanded] their power plant and went too far.”

Here is what the Southern Alliance for Clean Energy (SACE) press release claimed about the plant’s improved production of emission-free electricity.

In 2012 and 2013, the two nuclear generators were ‘uprated’ to increase power production, resulting in a much higher than predicted increase in the temperature and salinity of the water in the cooling canal system. The Turkey Point Power Plant and the cooling canal system are underlain by porous limestone geology, including the Biscayne Aquifer, and the contaminated water in the cooling canal system has for many years discharged, and continues to discharge, from the cooling canal system into the groundwater and into Biscayne Bay.

These actions, and FPL’s ongoing desire to build two additional nuclear reactors at the site instead of taking the time to fix what is already broken, makes it clear that the health of Floridians is not the Company’s priority, which is why this coalition is demanding that action by regulators be taken.

“Operating an industrial power facility effectively bordered by two national parks and highly protected waters requires the highest standards and strong regulatory oversight. Anything less is unacceptable,” said Dr. Stephen Smith.

The reactor power increase was limited by the NRC license amendment to a total of 688 MWth. One third of that additional heat input from the reactors is being converted into electricity. Approximately 500 MWth of additional heat from units 3 and 4 is being added to the CCS. However, after uprating the nuclear plant and completing a modern, efficient combined cycle gas turbine power plant (unit 5) the two earliest and no longer needed 450 MWe gas/oil fired power plants are no longer operating.

Unit 5 has a separate cooling system and does not use the CCS. The two oil/gas units were each producing about 900 MWth of waste heat when in operation. Shutting down the two fossil units subtracted 1800 MWth from the heat rejected to the CCS while the power uprate added just 500 MWth for a net decrease of 1300 MWth. The drought is what caused the increased CCS temperatures.

If the opponent’s concerns were limited to the alleged discharges from the CCS, there would have been no reason to introduce any comment about the future installation of units 6 and 7. Those new plants will have their own low rise cooling towers supplied with reclaimed water from the nearby megalopolis that I escaped about 40 years ago by heading off to college.

What is the nearby water contamination issue that FP&L has reported to its regulators and is working to correct?

FP&L’s monitoring program discovered that water near the bottom of four deep excavations outside of the CCS — one adjacent to a refueling ship dock, two associated with the no-longer-used once through cooling system used for units 1 & 2 before the construction of the CCS, and one deep water canal used for heavy equipment deliveries to the plant — have excess nutrients and salinity. These areas have very low or zero flushing rates, a large amount of decaying plant matter, and would be affected by the same kind of imbalance between evaporation and rainfall that caused a problem with the CCS.

The company is working with regulators to devise a solution for those isolated pockets of water that does not meet specifications but no qualified observer believes that the plant is the source of the salt or nutrients found in the stagnant deep pools.

To be continued.

Note: I have uncovered some interesting possibilities that might help to explain the virulence of the current attacks on Turkey Point. Surprisingly enough, it is possible that the real motive for discrediting the site isn’t just due to opposition to nuclear energy or expansion of the existing power capacity of the plant. I think I might have found some interests that see the power plant site itself as a roadblock. It might take some time to find confirmation of my developing theory.

Aerial view Turkey Point looking to Biscayne Bay
Used with permission from FP&L

This will be a multi-part post aimed at addressing a convoluted and emotional issue. It will attempt to satisfactorily answer the following questions.

• Why are organizations targeting the Turkey Point power station?
• Why do they claim that the plant is threatening the Everglades National Park, the Biscayne Bay National Park and the groundwater adjacent to the facility?
• What are the documented concerns and what impact do they have?
• Do the tritium measurements that have been reported in various news media really indicate that Turkey Point Units 3 & 4 (the nuclear units at the 5-unit power station) are “leaking?”

I’m biased

This is a story with a very personal aspect. Many of you have heard me tell the story of the time nearly 50 years ago when my father came home from work and told me about the new power plant that his company was building that did not even need smokestacks. Turkey Point was the unnamed power plant in that story; its construction began in 1967, the year I celebrated my 8th birthday.

That was the beginning of my appreciation of the advantages that nuclear fission has over its hydrocarbon competition.

I also have a life long fondness for Florida Power & Light (FP&L). The company and its employees were topics of many family discussions while I was growing up; in fact, Mom occasionally expressed some minor annoyance at Dad for bringing his work home so often. A fair portion of the adults that played a role in my life while growing up proudly worked in various roles at the company. I eagerly looked forward to the annual company Christmas party and the annual company picnics held on the site of the Cutler Plant.

The big banyan trees were great fun for climbing and swinging on the roots.

I fondly remember the Tuesday each month when my white collar, long distance-commuting Dad was able to linger with us at breakfast in his more casual “storm training” attire. Unlike the Miami office where he worked the other 19 days of the month, storm training was held in much closer and accessible Ft. Lauderdale; he didn’t need to allow 45-60 minutes for the traffic.

On storm training days, Dad made sure that his hardhat was in the car before he left for the monthly practical exercises in power system restoration, which is an “all hands on deck” effort for a power company. I’ve lived in places where the power was knocked out by storms and remember at least three separate instances where the whole neighborhood gathered on the street and cheered the power company employees who turned the lights back on. Sometimes the crews were from companies located several states away.

Living in the home of a good man devoted to his service-oriented profession helped inspire me choose a career in the service of others.

To this day, FP&L is a positive influence on my family; Mom is one of those famous “widows” — as in “this stock is suitable for widows and orphans” — that receives reliable dividend checks from FP&L. She also receives the survivor’s portion of the pension Dad earned during his 35 years of employment with the company. There are hundreds of thousands of people who can share similar personal stories about positive family associations with FP&L.

There are tens of millions of Florida residents and tourists that have benefitted from FP&L’s 90 years of service as a rate-regulated electric utility with an obligation to provide power to all customers at the highest possible level of reliability within cost constraints determined by the public utility commission.

All of that information is my way of disclosing that I instinctively distrust people that demonize “the power company.” I’m offended when out-of-state special interest groups like the deceptively-named¹ “Southern Alliance for Clean Energy” attack an admirable company that has achieved a long record of service and stewardship.

If you’re looking for balanced reporting, you might want to stop reading now. If you want informed answers to the questions I listed at the beginning of the article from someone who is not a company spokesperson or an employee but is also not an anti-corporate hater with an agenda, I hope to make this worth your time.

Turkey Point is under attack

I started hearing about recent efforts to publicize what opponents have characterized as “leaks of radioactive elements and other pollutants into Florida surface and ground water” a couple of weeks ago. I was energized into action after finding a March 22 New York Times story titled Nuclear Plant Leak Threatens Drinking Water Wells in Florida.

Though the headline — obviously designed to attract attention — claimed that the nuclear plants were “threatening” groundwater, the story clearly stated that tritium “was found in doses far too low to harm people” and later quoted a company spokesperson.

He [Robert L. Gould] emphasized that the trace levels of tritium were far below the danger levels set by the Environmental Protection Agency for drinking water. The company has been in contact with the federal agency, he said.

None of these problems, Mr. Gould said, are threatening the state’s drinking water supply or even the bay’s health. The problem is mostly in areas right near the plant, he added. The closest the saltwater plume is to the water wells is about four miles away. “I really need to stress that there is no safety risk: There is no risk to the bay or to the drinking water,” Mr. Gould said. “The way it’s been portrayed by some is simply unfair. It’s extremely misleading.”

Before providing what should be calming information, here’s how the New York Times story sought to capture readers that were initially attracted by the sensational headline.

When Florida’s largest power company added two nuclear reactors to an existing plant that sat between two national parks — Biscayne Bay and the Everglades — the decision raised the concerns of environmentalists and some government officials about the possible effects on water quality and marine life.

Now more than four decades later, Florida Power & Light’s reactors at Turkey Point, built to satisfy the power needs of a booming Miami, are facing their greatest crisis. A recent study commissioned by the county concluded that Turkey Point’s old cooling canal system was leaking polluted water into Biscayne Bay.

There are several problems with that statement.

Problem 1: The Turkey Point power station existed long before Biscayne National Park, which was formally established in 1980. It existed before 1968 when the area first gained some development protection when it was designated by Congress and President Johnson as a National Monument. At the time that the power station was built, the area was a prime development target for a project known as the city of Islandia.

FP&L’s 1964 decision to purchase land and build a power plant at Turkey Point is one of the prime reasons that the area was protected from intensive development. McGregor Smith, the chairman of the board of FP&L was committed to preserving as much of the waterways and land surrounding the plant as possible.

Found on Newspapers.com

He envisioned the area as a multi-use area that would include a wildlife refuge, a Boy Scout and Girl Scout camping area, a marine research laboratory, picnic areas and beaches. Smith’s visions were largely achieved. Much of what the company preserved from development was later incorporated into the Biscayne National Park. The park is a place that has received numerous accolades over the years lauding its environmental and recreational value. Park Vision has a nicely illustrated story about the park.

Crocodile Hatchlings from Turkey Point CCS.
Used with permission from FPL

One positive, but unintended effect of the Turkey Point plant and its cooling canal system (CCS) is that endangered crocodiles were attracted to the warm salty waters as a good place to lay eggs and incubate them to hatchlings. The crocodile’s decision to begin using Turkey Point’s CCS as an incubator, along with the protection afforded the reptiles by FP&L biologists and security personnel has been credited by conservationists with helping the crocodile population increase enough to move it off of the endangered species list to a status of “threatened.”

Problem 2: The easternmost boundary of Everglades National Park is about six miles west of the CCS for the Turkey Point Power station, on the other side of US 1. That’s a pretty substantial buffer area.

Problem 3: The referenced study did not prove that the plant was leaking polluted water into Biscayne Bay.

Analysis of study being used as basis for recent attacks

Dr. David Chin, a civil engineering professor at the University of Miami, was commissioned by Miami-Dade County to perform a study and produce a deliverable within a 120 day time frame. He documents the limitations of the study and what it was unable to determine. His commissioned study does not list any other authors and does not display the obvious signs of having been peer reviewed.

Chin’s document includes measurements indicating that there are deep pockets of water adjacent to the CCS that exhibited higher than expected concentrations of certain chemicals or elements.

Dr. Chin hypothesized that the isotopes and compounds migrated from the cooling canals into the dredged deep spots and from there into the adjacent aquifer and bay waters. Those deep areas are identified by dark blue circles on the map below.

Chin asserts that the boundary of the hypersaline that has percolated from the cooling canals is defined by a tritium concentration of 20 pCi/liter. He states that level is sufficiently elevated from the natural level to be a good marker. His chosen marker is 1/1000th of the 20,000 pCi/liter EPA says is safe for safe drinking water.

Aside: Here is the basis for the EPA limit. If a person drank nothing but water containing that level of tritium, her dose from tritium would be 0.04 mSv/year.

According to the Health Physics Society position paper titled Radiation Risk in Perspective, no discernable health effects occur for doses below 50 – 100 mSv. End Aside.

This is Dr. Chin’s explanation for his selection of 20 pCi/liter as the boundary. Note: A picocurie (pCi) is 10e-12 curies. That is one millionth of a millionth curies. A picocurie is even smaller than the incredibly tiny SI unit of a bequerel (defined as one decay per second). It takes 27 picocuries to equal one bequerel.

Natural groundwater at the base of the Biscayne Aquifer would be expected to have relatively low concentrations of tritium. A threshold concentration of 20 pCi/L has been used as a baseline to infer the presence of groundwater originating from the CCS. Groundwater with concentrations below 20 pCi/L are presumed not to be affected by the CCS. FPL does not concur with the selection of 20 pCi/L as a threshold or background tritium concentration for surface water, pore water, or shallow groundwater.

The basis of FPL’s contention regarding the 20 pCi/L threshold is that multiple factors such as atmospheric deposition, vapor exchange, and errors in laboratory analysis can influence reported tritium levels. The FPL assertion is reasonable and is supported by measured data that indicate atmospheric and vapor exchange effects on tritium concentrations can be particularly significant in surface water and shallow groundwater, with significance decreasing with distance from the CCS. However, at depth, the CCS appears to be the primary source of tritium, and using tritium as a tracer in the lower elevations of the Biscayne Aquifer is reasonable.

Reported measurements show groundwater tritium concentrations in excess of 3000 pCi/L near the CCS, with concentrations decreasing with distance from the CCS, and found at concentrations of hundreds of pCi/L three miles west of the CCS at depth. The approximate limit of the 20 pCi/L concentration contour is 3.8 – 4.7 mi west of the CCS and 2.1 mi east of the CCS. Based on the strength of these data and supporting analyses, it is reasonable to conclude that operation of the CCS has impacted the salinity of the Biscayne Aquifer within the limits of the 20 pCi/L contour.
(Source: Chin, David A. The Cooling-Canal System at the FPL Turkey Point Power Station Pg 12-13)

I question Dr. Chin’s logic. He does not explain why he says “at depth, the CCS appears to be the primary source of tritium…”

FP&L’s reactors, like all other water cooled reactors, produce some tritium. That low activity hydrogen isotope is inseparable from water. The company is permitted to discharge tritiated water into the cooling canal system, which is separated from the surrounding waters and aquifers by soil boundaries. Tritium concentration in the cooling canals range from about 1200 pCi/liter to about 15,000 pCi/liter at certain peak times.

There is no cover on the canal system; tritiated water in the canal water will evaporate along with all other water. Especially on cool days during dry spells, when the cooling canal temperature is roughly 100 ℉, there is vapor above the body of water. Any breezes coming off of the Bay and blowing across the CCS will move tritiated vapor inland. Winds in the opposite direction move tritiated vapor towards the Bay.

It will precipitate out and sink into the aquifer like any other water. The tritium concentration falls as distance from the source increases.

The people attacking the plant point out that the cooling canal system is not lined, but that is the way that the system was designed and approved. It is a permitted industrial waste water facility. It’s worth contemplating the environmental consequences of building and maintaining a lined canal system that covers 9 square miles of swampland lined with mangrove forests. It’s also important to note that the water depth in the CCS is less than 4 feet, with an average of less than 3 feet.

Since FP&L is a rate regulated monopoly utility, it would be allowed to include any costs associated with building a lined system in its rate base and it would be allowed to receive a modest rate of return on that investment. Despite what some opponents say, FP&L’s decision to build the canals as they are was not driven by corporate greed.

Salt Water Intrusion

Even after defining the plume boundary as just 20 pCi/liter, Dr. Chin concluded that the hypersalinity water — which he blames on seepage from the CCS — was still several miles seaward of the closest drinking water wells. Historical documents indicate that saltwater intrusion was measured at about the same location (5 miles inland from the Biscayne Bay) before the Turkey Point power station was ever built.

As a reasonably aware middle and high school student in South Florida, I have a clear memory of studying salt water intrusion issues and learning that the effect is often exacerbated by pumping too much water out of aquifers. Excessive withdrawal reduces the pressure (head) that generally keeps salt water out and allows it to invade the fresh water deposits. The problem is worsened by droughts, thirsty green lawns, green golf courses, limestone quarries and the impervious development roads, parking lots and shopping centers associated with suburbia.

Here is what Dr. Chin wrote about sea water intrusion.

The landward extent of the saltwater interface (i.e., the 1000 mg/L isochlor) varies naturally in response to a variety of factors, such as seasonal variations groundwater recharge and variations in rates at which groundwater is pumped from the aquifer. For example, prolonged droughts or excessive water usage inland that reduce water-table elevations can cause increased salinity intrusion. Prior to the construction of the CCS, the groundwater underlying the Turkey Point site was naturally saline due to the proximity of the site to the coast. In fact, had the groundwater not been saline, construction of the cooling-canal system at Turkey Point would not have been permitted.
…
It has always been recognized that construction of the CCS without any mitigating salinity-control systems would cause the saltwater interface to move further inland.
(Emphasis added)

Dr. Chin’s study hypothesizes that small variations in levels in the cooling canal, along with changes in density due to variations in salinity from the balance between rainfall and evaporation plays a large role in pushing water out of the canals and through the porous limestone characteristic of the South Florida subsurface. He does not mention the impact of withdrawal rates in helping saltwater plumes to move, if that is what is actually happening.

Dr. Chin also makes a few guesses about the source of recent temperature, salinity and algae challenges in the cooling canals that are demonstrably false. For example, he calculates that the heat rejection rate from the power plants into the cooling canals experienced a step increase from 2800 MW to 5500 MW.

He attributes that jump to a power upgrade on units 3 & 4. That uprate changed the licensed thermal power generation from each plant from 2300 MWth to 2644 MWth. During the time that elapsed between the two measured total heat rejection rates, FP&L shut down a 450 MWe oil/natural gas steam plant that also used the CCS as its heat sink. Since that time, it has shut down the other fossil unit using the CCS.

In a future article, I’ll provide more details about the actual heat balances. With the information already provided, it should be reasonably obvious that Dr. Chin’s model was giving incorrect information.

One of the major problems I have with Dr. Chin’s study is that it only includes the word “drought” once, and that was just in a paragraph describing hypothetical effects. He is apparently unaware that the measured rainfall into the canal cooling system in 2012 and 2013 averaged 20″ per year when the normal average is 75″. As of September 2014, only 26″ of rain had fallen into the canal system.

To be continued.

¹ “Southern Alliance for Clean Energy is a not-for-profit, non-partisan organization working to promote responsible energy choices that solve climate change problems and ensure clean, safe and healthy communities throughout the Southeast.” (IRS Form 990, SACE 2014) What that description fails to mention is that SACE actively campaigns against nuclear energy.