The Amy H Remley Foundation  

March 2, 2009

Testimony before Administrative Law Judge, re Levy County nuclear plants.

I am writing to you on behalf of the Amy H Remley Foundation Inc. and the Kings Bay Association. The mission of both organizations is to protect and restore local water quality. I write to protest against the Levy County nuclear generation project of Progress Energy Inc.. I have read and understood Florida Statutes Rules 28-06.104(4), 28-106.110, and Section 120.66(2). Neither I, nor the organizations I speak for, have any ex parte relations in regard to the siting of the Levy County nuclear project.

My reasons are first, the contention that nuclear energy generated electricity is necessary to meet future demand and be cost effective for the consumer is false. Second, the discharge of reactor blow down water to the Gulf of Mexico threatens the entire food web nurtured there. Third, tritium, a cancer causing by product of the proposed Levy County nuclear reactors, appears to threaten the drinking water supply and the health of more than the 140,000 inhabitants of Citrus County.

Salient points in support of these reasons are given below:

Customer Costs per kWh

The Progress Energy document, “Economic Benefits of a Nuclear Plant in Levy County”, singularly fails to mention the customer cost escalation consequent upon nuclear electricity generation. For example, my January, 2009, cost is 9.98 cents per kWh (including a 95% fossil fuel surcharge, and including costs of distributing to the customer's place of use). Nuclear generated electricity will cost 30 cents per kWh (with no fossil fuel surcharges, but, with added costs of distribution to a customer's place of use).

Craig A. Severance, in his 2009, “Business Risks and Costs of Nuclear Power”, calculates that capital costs for nuclear facilities per kWh (not counting operation or fuel costs) range between 17 to 22 cents/kWh. Nuclear generation costs per kWh (including fuel and O&M but not distribution to customers) raises the costs to between 25 and 30 cents per kWh. A higher cost than any other power generating technology.

The above quoted Progress Energy document lists benefits of increased tax dollars, job growth, enhanced local services and business opportunities, but only within Levy County. The document uses a capital cost figure between $2.5 and 3.5 billion for a new nuclear unit (which has escalated to more than $17 billion in the Levy County case.).

Clearly, nuclear powered electricity generation contributes less greenhouse gas emissions to the atmosphere than those plants burning fossil fuels such as coal and oil. Wind, solar and geothermal electricity generation technologies are similarly endowed. The assertion that nuclear powered generation alone is the answer to the global warming is false. Neither does it allow the United States to meet its own domestic requirements for electricity and contribute fewer greenhouse gas emissions.

Globally, to sufficiently reduce greenhouse gas emissions to contain the threat of global warming, is reported to require s ome two to three thousand reactors to be built worldwide, say, one a week for the next 40 years. In addition to the construction of nuclear plants, this huge amount of worldwide nuclear capacity would require 11–22 large fuel enrichment plants, 18 fuel fabrication plants, and 10 more waste disposal sites the size of Yucca Mountain. This is clearly not a feasible proposition.

Blow Down Water Discharge

Ano ther Progress Energy document, “Water Use at a Nuclear Plant” indicates the intention to take between 100 and 130 million gallons of cooling water a day (gpd) from the Cross Florida Barge Canal. Of that amount, 40% (say, 50 million gpd) would be emitted to air, and 60% (say, 60 million gpd), at elevated temperatures, would be piped to vent into the Gulf waters using an existing outlet from the Crystal River plants.

The latter is termed blow down water discharge. The Sargeant & Lundy conceptual design for this of March 21, 2008, poses serious environmental concerns.

On Page 5, a design blow down capacity for the two reactors, cited at 96.7 mgd, includes sources from cooling tower basins, retained wastewater, make up water in the event of pump downtime, liquid radwaste water and sanitary waste water. A high density polyethylene pipe system is envisaged to convey these waters to the Crystal River site for release into Gulf waters. Note that the blow down piping is single walled and not leak detected for cost reasons (Attachment A , and items 5.1 and 5.2). No mention is made of any tritium content of the water, nor any discussion of effects of Beta particle emissions on the integrity of the

12.5 mile length of the pipe system, from reactor site to the Crystal River discharge site. Elsewhere in the nation, as with the Braidwood reactor site in Illinois, serious events are on the NRC record regarding contamination of ground waters.

On page 9, concern is expressed at the possible content of tritium in the blow down water requiring discharge through the larger of two egress channels, and the building of containment embankments, to guard against overflow seepage into ground waters. Such contamination could equally occur after venting by return flow to the Barge canal, and into open aquifer conduits (fracture sets) extending into Gulf waters, due to pressures induced by sea level rises (tidal or by storm surge).

It is well reported in science literature how injecting power plant effluent at temperatures above ambient into coastal waters degrades sea grass meadows there. To include toxic waste in those discharges increases this probability further. The entire food web nurtured there is put at risk. Professional and recreational fishing could be significantly impaired. The wellbeing of protected species, such as the West Indian Manatee, which feeds there in summer months, is put in jeopardy. Not only is such environmental interference prohibited by state and federal law, the livelihood of many who depend upon those resources is threatened also.

Radioactive Water

The Progress Energy website includes this statement, "Tritium is a byproduct of generating electricity at nuclear power plants. All nuclear plants release tritium into both the water and air. The U.S. Environmental Protection Agency (EPA) regulates the acceptable level of tritium concentrations in ground water and drinking water" .

This, of itself, is a misleading statement, since detection of tritium, and other radio-nuclides, at “safe” levels at sampling sites, does not reveal their build up over time to dangerous concentrations in groundwaters being dispersed naturally elsewhere. Moreover, one must question the concept of a "safe" level when one Beta particle is considered sufficient to sever a chemical bond in a living organism. Also, it is understood that the safe drinking water standard, at 740 Bequerelles per liter, postulates an adult who might drink and evacuate the contaminated water within a few days. With a tritium contaminated supply a cumulative effect is introduced.

Tritium is unstable, emitting Beta particles (high energy electrons) as a radioactive isotope of hydrogen. Tritium replaces atoms of hydrogen in water molecules to produce radioactive water. There is no known method of removing tritium from water. Tritium has a half life of 12.42 years (IATA,1981), and is considered radioactive over ten periods of half life, (120) years. Furthermore, tritium is classed by EPA as a human carcinogen, and probably a mutagen by disturbing DNA arrangements. The Beta particles sever chemical bonds in living organisms. No information is available on effects of tritium on the fetus, babies, children, expectant mothers or the elderly, nor upon micro-organisms so important to regional environmental health.

The above mentioned Progress Energy statement also omits any mention of calculations of amounts of anticipated tritium releases from the untried new AP1000 reactors. Neither is there a definitive indication of contaminated ground water flows within, say, ten to twenty miles of the proposed site after distribution by underground piezometric flows and in conduits, fracture sets or fault lines.

The proposed location of the plant is up wind of and near to a significant piezometric (pressure) high for ground water, (published by Progress Energy on a map plan confirming the site position on the west flank of this piezometric high). The water flow direction to the west shown on that illustration is misleading, albeit true within that particular locality. Prevailing winds convey airborne water molecules which precipitate out to join groundwater flows to the south and east into northeast Citrus County on path to the site of well fields suppling drinking water to the population of Citrus County.

There are many words and figures in application documentation focusing upon cost effectiveness calculations applied to selected food products, but little or no focus upon geologically influenced underground water source contamination.


It would therefore appear probable that emissions, and waste water effluent from the plant site would pollute the atmosphere, people, ground water and the Gulf of Mexico waters with dangerous toxins. Particularly as rains cause airborne emissions to return to the ground water as precipitation close to the site.

The provision of nuclear electricity generation facilities in the location predicated by Progress Energy in Levy County, represents unwarranted risks to the region's unconfined (unprotected) aquifer, and near offshore waters. Furthermore, the business case for it is fatally flawed. Filling the generating capacity needs with alternative solar measures promises to be more speedy, safer, less controversial, and more cost efficient to the customer, to the nation and to the corporation. In any event, the chosen site exposes so many to radiation risks.

NOTE. Further discussion can seen on the Amy H Remley Foundation website under Education Section/Alternative Energy, and Education Section/Aquifers/Geology.

Norman Hopkins. Director, Kings Bay Association, Director Amy H Remley Foundation Inc.

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