The Amy H Remley Foundation  

March 9, 2009

Added testimony before Administrative Law Judge Johnston, re. Levy County Nuke plants.

Please accept this document as fleshing out my previous testimony to you of 3 March 2009. In it I attempt to “connect the dots” in regard to the perceived threat to drinking water supplies, occasioned by the proposed siting of the nuclear power plants in Levy County.


  • Tritium is a radioactive isotope of hydrogen, with a half life of 12.43 years (IATA, 1981), which emits high energy Beta particles over a period of time exceeding 120 years, when naturally it decays to become helium, &

  • These Beta particles, as high energy electrons, can sever chemical bonds in living organisms. Tritium is officially classed as a human carcinogen, which we can take into our bodies by breathing, though the pores in the skin, and by eating or drinking contaminated fluids or food. ( No information could be traced regarding impact of such radiation upon micro organisms and ecology systems), &

  • Tritium is formed as cosmic energy rays strike the upper atmosphere causing some hydrogen atoms, as distinct from protium and deuterium, to adopt a second neutron and become unstable, emitting Beta particle radiation, &

  • Atomic tritium replaces hydrogen atoms in water molecules in the atmosphere, known as triated water. This water soaks into the ground on falling to earth as precipitation, where it constitutes a measure of natural background radiation in ground water, &

  • Atmospheric testing of nuclear weapons increased amounts of tritium in the atmosphere, such that levels of tritium radiation in local ground water peaked by several orders of magnitude in 1963. Although levels have decreased since then, they still measure higher levels than existed prior to the tests, &

  • Tritium radiation levels have been used to determine age of local ground waters, &

  • A Progress Energy document avers, "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", &

  • No information is available on the quantity of tritium released from the proposed two AP1000 reactors. However, other Progress Energy documentation indicates the intention to take between 100 and 130 million gallons of 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, 70 million gpd) would be piped to the Crystal River 3 facility for discharge into the Gulf of Mexico (refer to section on Blow Down water in previous testimony), &

  • Wind and precipitation are expected to cause a pattern of fall out of triated water from the Levy site contaminating ground waters (just as that from the weapons testing, conducted many thousands of miles distant, caused local contamination in the 1960s), &

  • Patricia Hanley, on 3 March, 2009, testified to increases in incidence of cancer in the vicinity of the Braidwood and Dresden Nuclear Power Plants, in Illinois. Reports listed on the NRC website indicate tritium releases. The increase in cancer cases cited tend to indicate that the EPA regulation of acceptable levels of tritium concentrations is ineffective in the real world, and insufficiently preventative, &

  • The late Dr Robert O. Vernon, in 1951, in Geological Bulletin No. 33, Geology of Citrus and Levy Counties, Florida, first recorded data on rock fractures (Figure 11, page 48) together with direction of piezometric flow of groundwater of the Floridian Aquifer (Figure 40, page 242), See USACE entry below, &

  • In 1973, the U.S. GEOLOGICAL SURVEY completed the Water-Resources Investigations Report, I-73, GEOHYDROLOGY OF THE CROSSFLORIDA BARGE CANAL AREA WITH SPECIAL REFERENCE TO THE OCALA VICINITY (Prepared in cooperation with: U.S. DEPARTMENT OF THE ARMY CORPS OF ENGINEERS). The author, Dr Glen L. Faulkner, referring to the two figures 17 and 22 from the report underlined the relationship between potentiometric (piezometric) flows and conduit flows along fracture sets. From p 60 of the I-73 report, referring to Figure 22, he asserts: Ground water moves downgradient from the potentiometric highs ... along flow paths approximately perpendicular to the equipotential lines (piezometric contours). In addition to showing general directions and preferential routes of ground-water flow, he further states that the maps of the potentiometric surface help to demonstrate important hydrogeologic relationships in the area. For instance, the configuration of the potentiometric surface tends to confirm routes of concentrated groundwater flow suggested by the fracture trace maps, &

  • Progress Energy Florida Part 3 - Environmental Report, Fig 2. 3-20 dated March 6, 2007, Potentiometric Surface Map of the Surficial/Overburden Aquifer, correctly shows the local site piezometric flow westward. However, it fails to show any fracture sets to the west which would convey flows southward into Citrus County and toward Crystal River/Kings Bay. Moreover, aerial discharges of triated water entering groundwaters as fallout, according to the I-73 Figure 22 of Dr Faulkner, would appear to gravitate toward the Citrus County well field supplying drinking water to residents of all ages and states of health, and even the yet to be born, exposing them to cancer risks similar to those testified before you with respect to the Braidwood and Dresden Nuclear Power Plants, in Illinois, &

  • A United States Army Corps of Engineers, 2004, report on Lineament Analysis in South Florida affirms that studies of lineaments (photolinears) discernable on aerial photographs have revealed that these linears are abundant natural, and are systematically oriented in four principal groups of external stresses in the WNW, NNW, NNE, and ENE directions. Fractures are formed predominately by terrestrial or earth tides due to gravitational effects of the moon and sun, tectonic forces, diagenetic, or weathering processes (Blanchet, 1957). Furthermore, numerous investigations have shown that most of the fractures and faults identified as photolinears are vertical or near-vertical zones of fracture concentrations (Kaiser, 1950; Blanchet, 1957; Lattman, 1958; Lattman and Matzke, 1961; Lattman and Parizek, 1964), &

  • The same, 2004, report asserts that the following paragraphs present excerpts of a good summary on fracture-trace mapping principles by Diodato (1999):

Photolinear analysis is a type of remote sensing analysis wherein investigators map linear features (photolinears) observable on aerial photographs or other remotely-sensed images. The use of photolinears for ground-water well siting was pioneered by Lattman and Parizek (1964). For linear features of geologic origin, lineaments are defined as those photolinear features greater than one mile in length, whereas fracture traces are the same type of feature having a total length of less than one mile. The width of these zones of fracture concentration can vary from a few to tens of meters. In general, longer lineaments tend to have wider surface expressions of the zone of fracture and wider zones of fracture concentration at greater depths. Because the fracture trace is the surface expression of the vertical zone of fracture concentration, Parizek has suggested the "fracture zone trace" might be a more appropriate descriptive term (Parizek and Diodato, 1995).

Zones of fracture concentration in soluble rocks such as carbonates and evaporates can lead to enhanced dissolution of these rocks due to accelerated chemical and physical weathering. In the case of rocks prone to karstification, White (1999) has determined that the development of karst conduits begin when fracture apertures reach about one centimeter.

In south Florida, linear features (photolinears) are detected and identified based primarily upon indicators such as aligned solution depressions, surface ponds, vegetation, and variations in soil tone (Trainer and Ellison, 1967, Parizek, 1975). Doline (sinkhole) development can be expected to follow orientation of photolinears, as these represent areas of higher permeability and porosity.


  • To expose a local population to such risks of cancer and death by contaminated ( triated) domestic water supplies is morally indefensible, &

  • Moreover, the risk exposure to an impacted population in the circumstances would in all probability not be an insurable risk - as being avoidable by Progress Energy, &

  • Consequently, no permit to proceed on the chosen Levy County site should be sanctioned until the risks are proven otherwise to be the case.

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

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