L-2015-142, 2014 Annual Environmental Operating Report

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2014 Annual Environmental Operating Report
ML15126A097
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 04/28/2015
From: Katzman E
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2015-142
Download: ML15126A097 (50)


Text

0FPL.

April 28, 2015 L-2015-142 10 CFR 50.4 U. S. Nuclear Regulatory Commission CERTIFIED MAIL Attn: Document Control Desk RETURN RECEIPT REQUESTED Washington, DC 20555 7011 3500 0000 7495 7010 Re: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 2014 Annual Environmental Operating Report In accordance with Section 5.4.1.2 of the St. Lucie Units 1 and 2 Environmental Protection Plans (EPP), attached is the Annual Environmental Operating Report for calendar year 2014.

Sincerely, Eric S. Katzman Licensing Manager St. Lucie Plant ESK/tlt

Attachment:

Florida Power & Light Company - St. Lucie Plant Annual Environmental Operating Report 2014 (49 pages) cc: FDEP Siting Office Florida Power & Light Company I-; 5-6501 S. Ocean Drive, Jensen Beach, FL 34957 ý-ku - e-

FLORIDA POWER & LIGHT COMPANY ST. LUCIE PLANT ANNUAL ENVIRONMENTAL OPERATING REPORT 2014 FLORIDA POWER & LIGHT COMPANY JUNO BEACH, FLORIDA INWATER RESEARCH GROUP, INC.

JENSEN BEACH, FLORIDA

Environmental Operating Report Table of Contents A c ro ny m s ........................................................................................................................ 1 Executive Sum mary ................................................................................................. 2 1.0 Background .................................................................................................... 4 1.1 Area Description ............................................................................................. 4 1.2 Power Plant Description .................................................................................. 4 1.3 Environmental Reporting ................................................................................ 4 2.0 Sea Turtle Nest Monitoring ................................................................................ 6 2.1 Methodology ................................................................................................... 6 2.1.1 Previous Methods and Projects .............................................................. 6 2.1.2 Current Methods ...................................................................................... 7 2.2 Results for 2014 ............................................................................................ 8 2.2.1 Loggerhead Nesting ............................................................................... 9 2.2.2 Green Nesting ........................................................................................ 10 2.2.3 Leatherback Nesting ............................................................................. 10 2.2.4 Predation .............................................................................................. 11 3.0 Intake Canal Monitoring .................................................................................. 12 3.1 Methodology ................................................................................................. 12 3.1.1 Barrier Nets ............................................................................................ 12 3.1.2 Turtle Capture ........................................................................................ 13 3.1.3 Data Collection ...................................................................................... 14 3.2 Results for 2014 .......................................................................................... 14 3.2.1 Loggerhead Captures ........................................................................... 15 3.2.2 Green Captures ...................................................................................... 16 3.2.3 Leatherback, Hawksbill, and Kemp's ridley Captures ........................... 16 3.2.4 Recaptures ............................................................................................ 16 3.2.5 Relative Condition ................................................................................. 17 3.2.6 Mortalities and Injuries ........................................................................... 18 4.0 Sea Turtle Protective Activities ......................................................................... 19 4.1 NMFS Section 7 Consultations .................................................................... 19 4.2 Sea Turtle Stranding and Salvage Network and Turtle Walks .................... 20 4.2.1 Results for 2014 ................................................................................... 20

4.3 Collaborative Efforts .................................................................................... 21 4.4 Barrier Net Maintenance ............................................................................. 21 4.5 Intake Pipe Cleaning and Maintenance ........................................................ 22 5.0 References .......................................................................................................... 23 6.0 Figures and Tables .......................................................................................... 27 7.0 Annual Environm ental Operating Report ........................................................ 43 7.1 Introduction ................................................................................................... 43 7.2 Sea Turtle Monitoring and Associated Activities .......................................... 43 7.3 Taprogge Condenser Tube Cleaning System Operation ............................. 43 7.4 Other Routine Reports ................................................................................. 45 7.5 Figures and Tables ...................................................................................... 46

Acronyms ABI Applied Biology, Inc.

BO Biological Opinion EAI Ecological Associates, Inc.

ESA Endangered Species Act EPP Environmental Protection Plan FWC Florida Fish and Wildlife Conservation Commission FPL Florida Power & Light IRG Inwater Research Group, Inc.

NMFS National Marine Fisheries Service NRC Nuclear Regulatory Commission PIT Passive Integrated Transponder SSCL Straight Standard Carapace Length STSSN Sea Turtle Stranding and Salvage Network USFW U.S. Fish and Wildlife Service UESI Underwater Engineering Services, Inc.

UIDS Underwater Intrusion Detection System 1

Executive Summary Florida Power & Light Company (FPL) - St. Lucie Plant, located on South Hutchinson Island, consists of two 1,000 MWe nuclear-fueled electric generating units that use nearshore ocean water for the plant's once-through condenser cooling system. Water for this system enters through three submerged intake structures located 365 m offshore. Water passes through the structures and into submerged pipes (two 3.7 m and one 4.9 m in diameter) running under the beach. It then passes into a 1,500 m long intake canal, which transports water to the power plant. Turtles entering the ocean intake structures are entrained with cooling water and rapidly transported through the intake pipes into the enclosed canal system where they must be manually captured and returned to the ocean.

South Hutchinson Island is also an important rookery for loggerhead (Caretta caretta),

green (Chelonia mydas), and leatherback (Dermochelys coriacea)turtles. Under the Endangered Species Act (ESA), the federal government has classified the loggerhead turtle as a threatened species while leatherbacks and the Florida nesting population of green turtles are classified as endangered. One of FPL's primary environmental concerns is to ensure that the operation of the St. Lucie Plant does not adversely affect sea turtle nesting and to monitor nesting trends they have sponsored nesting surveys on the island since 1971. Biologists use all-terrain vehicles to survey the island each morning during nesting season. New nests, non-nesting emergences (false crawls),

and nests negatively affected by predators are recorded. Data collected from beach nesting surveys are reported to the Florida Fish and Wildlife Conservation Commission (FWC) as part of a statewide survey program. In 2014, 7,027 loggerhead, 221 green and 352 leatherback nests were recorded on South Hutchinson Island.

Since the plant became operational in 1976, turtles entrained in the intake canal have been systematically captured, measured, weighed, tagged, and released. During 2014, 414 sea turtles were removed from the intake canal, including 275 loggerheads, 134 greens, three hawksbills and two Kemp's ridleys. The majority of these turtles (95.4 %)

were captured alive and released back to the ocean. Fifteen (3.6%) were taken to rehabilitation facilities for treatment of injuries or disease and four turtles (1.0%) were found dead.

Injuries and mortalities are categorized in two ways: 1) causal to power plant operations or 2) non-causal to power plant operations. These decisions are made in consultation with FWC and/or a qualified veterinarian. Not all mortalities and injuries are causal to power plant operations, as some sea turtles enter the canal in either a moribund state or have pre-existing conditions related to fisheries, boat interactions, or disease. Injuries causal to power plant operations are recorded and are applied against the take limit 2

established by the most recent Biological Opinion (BO) set forth by the National Marine Fisheries Service (NMFS). The Incidental Take Statement in the most recent BO states that FPL will exceed their take limits for a calendar year if any of the following occur: 1) more than 1,000 sea turtles are captured, 2) more than 1% of the total number of loggerhead and green turtles (combined) are injured/killed due to plant operation, 3) more than two Kemp's ridley sea turtles are injured/killed due to plant operation or 4) if any hawksbill or leatherback sea turtles are injured/killed due to plant operation. In the case where 1% of the combined loggerhead and green turtle captures is not a whole number, it is rounded up (e.g. 520 combined captures = take limit of 6). Under section 7 of the ESA, a new consultation with NMFS is required if FPL meets or exceeds the take limits specified in the Incidental Take Statement.

During 2014, there were no mortalities or injuries of loggerhead or green turtles that were causal to power plant operations. No leatherback, hawksbill or Kemp's ridley turtles were injured or killed due to power plant operation. Based on the latest BO issued by NMFS, FPL did not exceed its take limit during 2014. However, FPL did exceed their sea turtle take limit at the St. Lucie Power Plant in 2006 and reinitiating a Section 7 consultation was required. This consultation is currently ongoing between NMFS and the Nuclear Regulatory Commission (NRC). A new BO is expected in 2015.

FPL has identified and responded to correct the contributing factors that led to exceeding the take limit in 2006.

The current BO also mandates that FPL participate in the Sea Turtle Stranding and Salvage Network (STSSN) as well as Public Service Turtle Walks. As participants in the STSSN, biologists routinely respond to sea turtle strandings in St. Lucie and Martin Counties. This activity involves the collection of information on turtles that are found dead, debilitated, or that have been impacted by human-related activities. During 2014, IRG biologists responded to 16 stranding events. Additionally, IRG biologists responded to seven strandings at other FPL facilities. Sea turtle nesting walks are conducted by FPL as public service programs during the summer sea turtle nesting season. These turtle walks educate the public about relevant sea turtle protection issues and, in most cases, allow the public to view a nesting loggerhead sea turtle.

During 2014, FPL conducted 13 turtle walks attended by 428 people.

The St. Lucie Plant sea turtle program continues to assist other sea turtle researchers, universities, nonprofit organizations, and state and federal agencies by providing data, specimens and public outreach. Biologists collaborated with researchers on three projects in 2014.

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1.0 Background 1.1 Area Description Florida Power & Light Company (FPL) - St. Lucie Plant is located on a 457-hectare site on South Hutchinson Island on Florida's east coast (Figures 1 and 2). South Hutchinson Island is a barrier island that extends 36 km between inlets and attains its maximum width of 2 km at the plant site. The plant is approximately midway between Ft. Pierce and St. Lucie Inlets and is bounded on the east by the Atlantic Ocean and on the west by the Indian River Lagoon. Elevations approach five meters atop dunes bordering the beach and decrease to sea level in the mangrove swamps that are common on the western side. The Atlantic shoreline of South Hutchinson Island is composed of sand and shell hash with intermittent rocky promontories protruding through the beach face along the southern end of the island. Submerged coquinoid rock formations parallel much of the island off the ocean beaches. The ocean bottom immediately offshore from the plant site consists primarily of sand and shell sediments.

The Gulf Stream (Florida Current), which flows parallel to the continental shelf margin, begins to diverge from the coastline at West Palm Beach. At South Hutchinson Island, the current is approximately 33 km offshore. Oceanic waters associated with the western boundary of the current periodically meander over the inner shelf, especially during summer months.

1.2 Power Plant Description The St. Lucie Power Plant consists of two 1,000 MWe nuclear-fueled electric generating units that use nearshore ocean waters for the plant's once-through condenser cooling system. Unit 1 was placed on-line in March 1976 and Unit 2 in April 1983. Water for this system enters through three submerged intake structures located 365 m offshore (Figure 2). The intake structures are equipped with a velocity cap to minimize entrainment of marine life. Water passes through these structures and into submerged pipes (two 3.7 m and one 4.9 m in diameter) running under the beach. It then passes into a 1,500 m long intake canal, which transports it to the plant. After passing through the plant, the heated water is discharged into a 670 m long canal that leads to two buried discharge pipelines. These pass underneath the dunes and along the ocean floor to the submerged discharge, the first of which is 730 m north of the intake and extends approximately 365 m offshore. The second pipeline is located just to the south of the first and is nearly twice as long.

1.3 Environmental Reporting St. Lucie Units 1 and 2 use the Atlantic Ocean as a source of water for once through condenser cooling. Since 1971, the potential environmental effects resulting from the 4

intake and discharge of this water have been the subject of FPL sponsored biotic studies at the site (Applied Biology, Inc. [ABI] 1978, 1980, 1986, 1987, 1988, 1989, 1994). Jurisdiction for sea turtle studies lies with the Nuclear Regulatory Commission (NRC), which is considered to be the lead federal agency relative to consultation under the Endangered Species Act (ESA). This document has been prepared to satisfy the requirements contained in Appendix B, Environmental Protection Plan (EPP); St. Lucie Units 1 and 2 Facility Operating License Nos. DPR-67 and NPF-16. Previous results dealing with sea turtle studies are contained in thirty annual environmental operating reports covering the period from 1983 through 2013 (ABI 1983-1994; Quantum Resources, Inc. 1995-2009; Inwater Research Group, Inc. [IRG] 2010-2013). This report describes the 2014 environmental protection activities related to sea turtles as required by Subsection 4.2 of the St. Lucie Units 1 and 2 EPP. Other routine annual reporting requirements are addressed in Section 7.

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2.0 Sea Turtle Nest Monitoring Sea turtle nesting typically occurs along Florida's Atlantic coast from March through September. Furthermore, South Hutchinson Island is an important rookery for loggerhead (Caretta caretta), green (Chelonia mydas) and leatherback (Dermochelys coriacea)turtles (Meylan, Schroeder, & Mosier, 1995). Under the ESA, the federal government has classified the loggerhead turtle as a threatened species while leatherbacks and the Florida nesting population of green turtles are classified as endangered. One of FPL's primary environmental concerns is to ensure the operation of the St. Lucie Plant does not adversely affect sea turtle nesting and they have sponsored monitoring of nesting activity on the island since 1971.

2.1 Methodology 2.1.1 Previous Methods and Projects Daytime nesting surveys and nighttime turtle tagging programs were conducted in odd numbered years from 1971 through 1979. During daytime nesting surveys, nine 1.25 km-long survey areas were monitored five days per week (Figure 3). The St. Lucie Plant began operation in 1976, therefore, the first three survey years (1971, 1973, and 1975) provided baseline data for nesting activity on South Hutchinson Island. Though the power plant was not operating during 1975, St. Lucie Plant - Unit 1 ocean intake and discharge structures were installed during that year. Installation of these structures included nighttime construction activities conducted offshore from and perpendicular to the beach. The plant was in full operation during the 1977 and 1979 surveys.

A modified daytime nesting survey was conducted in 1980 during the preliminary construction of the ocean discharge structure for St. Lucie Plant Unit 2. Four of the previously established 1.25 km-long survey areas were monitored. To mitigate any adverse effects associated with construction activities, turtle nests proximal to the construction area were relocated.

The St. Lucie Plant Unit 2 discharge structure was installed during the 1981 nesting season. Construction of the Unit 2 intake structure proceeded throughout the 1982 nesting season and was completed near the end of the 1983 season. Mitigation activities associated with installation of both structures were similar to those conducted when the Unit 1 intake and discharge structures were installed. Analysis demonstrated that the construction of the plant's offshore intake and discharge structures significantly reduced nesting at the plant site during construction years 1975, 1981, 1982 and 1983 (ABI, 1987). However, nesting at the plant consistently returned to levels similar to or greater than those at a control site in years following the construction.

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During 1991, a major offshore construction project was undertaken to replace damaged velocity caps on the three intake structures. A large elevated platform, from which repair activities were conducted, was erected around the three structures. Construction occurred throughout the nesting season. Work was restricted almost entirely to daylight hours, nighttime lighting of the work area was minimal, and no equipment or materials were used on the beach. A sea turtle protection plan was implemented to mitigate any negative effects resulting from the required safety and navigational lighting on and near the platform. The plan included caging nests along a 1,500 m section of beach west of the platform and the release of hatchlings to unaffected areas to the north and south.

During this period, nests were more abundant at the construction site than at the control site.

Reconstruction of the primary dune in front of the power plant was completed by FPL prior to the beginning of the 2005 sea turtle nesting season. This project was required due to the widespread obliteration of the primary dune during the 2004 hurricane season. Despite the compact material and erosion problems associated with the reconstructed dune, nesting success was not noticeably different from nesting success in unaffected survey zones to the north and south of the project area.

In 2012, FPL implemented a construction project at the discharge canal headwall where a retaining wall was added landward of the beach-facing dune. Construction activities took place on a 100 m section on the crest of the primary dune line at the eastern end of the discharge canal. Daily sea turtle nesting surveys were performed as required by the construction permit. From the beginning of nesting season until May 2 1 st, nests were left in situ. Beginning on May 2 2 nd, nests that could have been impacted by construction activities were relocated to a hatchery area approximately 1 km north of the construction site.

Another dune restoration project in front of the power plant was completed by FPL prior to the beginning of the 2013 sea turtle nesting season. This project was required due to erosion of the previous dune restoration area. Sea turtle nesting surveys were again performed in conjunction with the restoration activities. Sand placement began in January and was completed by mid-February (prior to the start of sea turtle nesting season). The planting of dune vegetation was subsequently completed in March. No nests or false crawls were recorded during the project timeframe.

2.1.2 Current Methods Nesting surveys to satisfy environmental reporting requirements were completed in 1986 (ABI, 1987) but continued voluntarily through 1998 with agreement from federal and state agencies. In 1998, the continuation of the nesting survey program was mandated as part of the BO and Incidental Take Statement issued by the National 7

Marine Fisheries Service (NMFS). An amendment to the EPP was approved in 1999 to include these requirements.

From 1981 through 2014, 36 one km-long segments comprising the island's coastline have been surveyed seven days a week during the nesting season (Figure 3). These "zones" are identified starting with zone A at the northern end of the island and continue through zone JJ at the southem end. Since the 1994 nesting season, the southern half of the island (zone T to zone JJ) has been surveyed by Ecological Associates, Inc. (EAI) and their data are included in this report. Biologists used all-terrain vehicles to survey the island each morning. New nests, non-nesting emergences (false crawls), and nests affected by predators were recorded for each zone. Data collected from beach nesting surveys are reported to the Florida Fish and Wildlife Conservation Commission (FWC) as part of the Index Nesting Beach Survey and the Statewide Nesting Beach Survey.

2.2 Results for 2014 In 2014, zones E-S were surveyed by Inwater Research Group, Inc. (IRG). EAI surveyed zones A-D as part of a beach renourishment project south of the Fort Pierce inlet. Data from those zones, as well as the south end of South Hutchinson Island, were supplied by EAI and were used to provide whole-island nesting totals (Figures 4 - 6).

From March 1 5 th through March 3 1 st, several preliminary nesting surveys were conducted along South Hutchinson Island in areas A-S. Five leatherback sea turtle nests were recorded in zones A-S prior to the beginning of formal nesting surveys on April 1 st. From April 1st through September 3 0 th, nest surveys were conducted on a daily basis.

Not all ventures onto the beach by a female turtle end in successful nests. These "false crawls" (non-nesting emergences) may occur for many reasons and are commonly encountered at other rookeries. Davis and Whiting (1977) suggest that relatively high percentages of false crawls may reflect disturbances or unsatisfactory nesting beach characteristics. Historically, the distribution of loggerhead emergences on the island has been consistent with the distribution of nests, with no difference in nesting success among zones. We can only speculate the current causes for differences in nesting success between zones (Figure 7). Recent beach renourishment, coastal construction projects, formation of large escarpments that prevent turtles from crawling above the high tide line, and light pollution from inland sources may have all contributed to lower nesting success in the northern most zones. Nest success in the zone that includes the power plant (zone 0) was lower than the nesting success in the surrounding zones (Figure 7). A dune restoration project completed in 2013 has likely contributed to this phenomenon. Storms and heavy wave action subsequently caused the formation of 8

escarpments in portions of the project area and this may have deterred some turtles from crawling above the high tide line to nest.

On August 1 4 th, Inwater biologists were alerted by FWC law enforcement officers to the poaching of sea turtle nests in zone S. The poacher was caught and a total of 299 eggs were recovered. The eggs consisted of a mix of green turtle and loggerhead eggs and were buried by the officers on the beach nearby. The eggs were monitored for hatching and excavated on October 2 4 th. Both nests were heavily predated by ghost crabs, raccoons, and plants. Only two hatched shells were found when the nests were inventoried.

2.2.1 Loggerhead Nesting Most loggerhead nesting occurs on warm temperate and subtropical beaches (Dodd, 1988). Approximately 42,000 to 74,000 loggerhead turtle nests are deposited annually on Florida beaches (Turtle Expert Working Group [TEWG], 2000), ranking this loggerhead turtle rookery the second largest in the world (NMFS and U.S. Fish and Wildlife Service [USFWS], 1991). The beaches in southeast Florida are especially prolific nesting areas, with South Hutchinson Island being a critically important nesting beach (Meylan, Schroeder, & Mosier, 1995). Between 4,000 and 8,000 loggerhead nests have been deposited annually on South Hutchinson Island during the last thirty years.

In 2014, 7,027 loggerhead nests were recorded on South Hutchison Island (Figure 4).

In zones A-S (the north end of the island) biologists observed 3,196 nests (Figure 8).

The first recorded nest was on April 1 9 th and the last loggerhead nest was recorded on September 8 th. There were 2,795 loggerhead false crawls observed in zones A-S.

Seventy-two of the 3,196 loggerhead nests were marked to assess nest productivity.

Forty nests were successfully inventoried, 18 were completely predated, seven completely washed out, one had its marking stakes removed/vandalized preventing the clutch from being located, one was predated after the first emergence, four were not inventoried because another turtle had nested on top of the marked nest and/or destroyed the marking stakes, and one was not inventoried because a hatchout from an unmarked nest was too close to differentiate clutches between nests. The 40 inventoried nests contained a cumulative total of 3,994 eggs. Of these, 2,413 successfully hatched and emerged from the marked nests. This represents an emergence success rate of 60.4%. There were 14 live loggerhead hatchlings found during nest excavations. These hatchlings were not considered to have successfully emerged from the nest.

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Loggerhead nesting activity on South Hutchinson Island fluctuates considerably from year to year (Figure 6). Annual variations in nest densities are also common at other rookeries, and probably result from non-annual reproductive behavior (Heppell, Snover,

& Crowder, 2003). No relationships between annual fluctuations in nesting activity and power plant operation or intake/discharge construction have been found. However, loggerhead nesting on South Hutchinson Island mirrors trends in nesting statewide.

2.2.2 Green Nesting The green turtle is the second most common sea turtle on Florida nesting beaches.

Approximately 99% of the green turtle nesting in Florida occurs on the Atlantic coast from Brevard through Broward Counties (Witherington, Herren, Bresette, 2006). On South Hutchinson Island, green turtles have had alternating years of nesting: a high nesting year followed by a low nesting year, although this pattern has become less distinct in recent years. This biennial pattern is also seen at other locations throughout their nesting range (Witherington et al., 2006).

In 2014, 221 green turtle nests were recorded on Hutchison Island (Figure 5).

Biologists observed a total of 103 green turtle nests in zones A-S (Figure 8). The first recorded nest of the season was on June 6 th and the last green turtle nest was noted on September 2 8 th. There were 105 green turtle false crawls observed in zones A-S.

Twelve of the 103 green turtle nests were marked to assess nest productivity. Nine nests were successfully inventoried, and three were completely predated. The nine inventoried nests contained a cumulative total of 1,121 eggs. Of these, 567 successfully hatched and emerged from the marked nests. This represents an emergence success rate of 50.6%. In addition, there were 10 live green turtles found during nest excavations. These hatchlings were not considered to have successfully emerged from the nest.

2.2.3 Leatherback Nesting Leatherback nesting occurs on subtropical and tropical beaches. Leatherbacks inhabit Florida waters primarily during the nesting season (March-June) when they are generally found in higher densities close to shore awaiting nesting forays onto the beach (Schroeder & Thompson, 1987). Outside of nesting season leatherbacks are often found in pelagic habitats as far north as the Canadian Maritimes where they feed primarily on jellyfish (Fossette et al. 2010).

In 2014, 352 leatherback turtle nests were recorded on Hutchison Island (Figure 6).

Biologists observed a total of 106 leatherback sea turtle nests in zones A-S (Figure 8).

The first recorded nest was on March 1 9 th and the last leatherback sea turtle nest was 10

recorded on July 1 7 th. There were five leatherback sea turtle false crawls observed in the surveyed areas A-S.

Twenty-three of the 106 leatherback turtle nests were marked to assess nest productivity. Seventeen nests were successfully inventoried, two were completely predated, three were unable to be located due to probable wash-outs, and one had its marking stakes removed/vandalized preventing the clutch from being located. The 17 nests contained a cumulative total of 1,229 eggs. Of these, 552 successfully hatched and emerged from the marked nests. This represents an emergence success rate of 44.9%. There were seven live leatherback turtles found during nest excavations.

These hatchlings were not considered to have successfully emerged from the nest.

The increase in leatherback nesting on South Hutchinson Island mirrors the nesting trend for the entire state Florida. The number of leatherback nests in Florida has increased more than 10% per year since 1979 (Stewart et al., 2011), but it is unknown whether the increase is from new recruits to the population or if it represents migrants from other Caribbean nesting beaches.

2.2.4 Predation Historically, raccoon (Procyon lotor) predation has been the leading cause of turtle nest destruction on South Hutchinson Island (ABI, 1989). Though turtle nests on South Hutchinson Island have probably been depredated by ghost crabs (Ocypode quadrata) since nesting surveys began, quantification of ghost crab predation did not begin until 1983. Occasionally, sea turtle nests are depredated by other animals such as bobcats (Lynx rufus), fire ants (Solenopsis invicta), and various species of birds. However, this only accounts for a small portion of the total number of predation events on South Hutchinson Island.

IRG biologists recorded a total of 704 predation events for South Hutchinson Island in 2014 within beach sections A-S (Figure 9). Sea turtle nests on South Hutchinson Island were depredated by ghost crabs, raccoons, birds, and fire ants. The most abundant predators were ghost crabs, which accounted for 218 individual predation events.

Raccoons were the second most abundant predator accounting for 157 events.

Another 316 predation events consisted of a combination of raccoon and ghost crab predation. Other predators (fire ants, domestic dogs or birds for example) accounted for 13 additional predation events.

Nest excavation provides an opportunity to more accurately account for predation activity. For example, fire ant and ghost crab predation are not always evident from a cursory inspection of the sea turtle nest's surface. Predators negatively affected 31.9 %

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of nests (23 out of 72) where hatch success could be evaluated. Twenty-three marked nests were completely predated prior to inventory.

3.0 Intake Canal Monitoring Entrainment of sea turtles at the St. Lucie Plant has been attributed to the presumed physical attractiveness of the offshore structures housing the intake pipes rather than to plant operating characteristics (Ecological Associates, Inc., 2000). The velocity caps, which are supported above the openings to each intake pipe, eliminate vertical water entrainment and substantially reduce current velocities near the structures by spreading horizontal draw over a wider area. Even when both units are operating at full capacity, turtles must actively swim into the mouth of one of the structures before they encounter current velocities sufficient enough to entrain them. Turtles entering the ocean intake structures are entrained with cooling water and rapidly transported through the intake pipes into an enclosed canal system where they must be manually captured and returned to the ocean. Since the plant became operational in 1976, turtles entrained in the intake canal have been systematically captured, measured, weighed, tagged, and released.

3.1 Methodology 3.1.1 Barrier Nets In 1978, a barrier net at the AlA Bridge (Figure 2) was constructed to confine turtles to the easternmost section of the intake canal where capture techniques have been most effective. This net is constructed of large diameter polypropylene rope and has a mesh size of 20.3 cm x 20.3 cm. A cable and series of large floats are used to keep the top of the net above the water's surface and the bottom of the net is anchored by a series of concrete blocks. The net is inclined at a slope of 1:1, with the bottom positioned upstream of the surface cable. This reduces bowing in the center and minimizes the risk of a weak or injured turtle being pinned underwater by strong currents.

In the past, the integrity of the barrier net was occasionally compromised, and turtles were able to move west of AlA. These turtles were further constrained downstream by an underwater intrusion detection system (UIDS) consisting, in part, of a large barrier positioned perpendicular to the north-south arm of the canal (Figure 2). The UIDS security barrier has a mesh size of 22.9 cm x 22.9 cm. Prior to completion of the UIDS in December 1986, turtles unconfined by the AlA barrier net were usually removed from the canal at the intake wells of Units 1 and 2 (Figure 2). They were then retrieved by means of large mechanical rakes or specially designed nets. Following construction of the UIDS barrier, only the smallest individuals were able to reach the intake wells.

Improvements made to the AlA barrier net in 1990 have effectively confined all turtles 12

larger than 32.5 cm carapace length (28.7 cm carapace width) to the eastern end of the canal.

In January 1996 (in response to the large numbers of small green turtles entrained in the intake canal in the early 90s) an improved barrier net design involving a smaller 12.7 x 12.7 cm mesh size was erected 150 m east of AlA (Figure 2). This additional "primary barrier net" was designed to confine all turtles with a carapace width greater than 18 cm to the extreme eastern portion of the intake canal. However, the integrity of this net was often compromised by incursions of seaweed, drift algae, jellyfish, and siltation. During these events, water velocities around the net increased dramatically creating an insufficient net slope that caused several sea turtle mortalities. To address this design problem and to further alleviate mortalities, FPL constructed a new net with a stronger mesh and added support structures. Dredging of the canal east of the AlA net was also conducted to minimize water velocities around the new barrier net.

Construction was completed in November 2002.

In October 2009 the primary barrier net and support structures failed due to an algae event, submerging the north half of the net 0.6-1.5 m underwater (IRG, 2010). UESI installed large floating buoys onto the primary net in order to create a temporary barrier.

However, this temporary barrier net was found to be susceptible to partial submergence or failure due to severe algae/jellyfish events or at extreme high tides. Construction on a new permanent primary barrier net began in 2014 and is scheduled for completion in January 2015.

3.1.2 Turtle Capture Historically, most turtles entrained in the St. Lucie Plant intake canal were removed using large-mesh tangle nets set near the intake canal headwalls at the extreme eastern end of the intake canal (Figure 2). Nets used were from 30 to 40 m in length, 3 to 4 m deep, and composed of 40 cm stretch mesh multifilament nylon. Large floats were attached to the surface and unweighted lines were used along the bottom. Turtles entangled in the nets generally remained at the water's surface until removed. Nets were usually deployed on Monday morning and retrieved on Friday afternoon. During periods of deployment, the nets were inspected for captures at least twice each day (mornings and afternoons). St. Lucie Plant personnel checked the nets periodically and biologists were notified immediately if a capture was observed. Sea turtle specialists were on call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day to retrieve captured turtles from the plant intake canal system.

Beginning in April 1990, after consultation with NMFS, net deployment was scaled back to daylight hours only. Concurrently, surveillance of the intake canal was increased and biologists remained on site for the duration of each day's netting activities. This 13

measure decreased response time for removal of entangled turtles and provided an opportunity to improve daily assessments of turtle abundance within the canal.

During each day's directed capture efforts, formal inspections of the intake canal were made to determine the number, location and species of turtles present. Surface observations were augmented with periodic underwater inspections, particularly in and around the barrier nets. These observations allowed for a rough estimate of how many sea turtles were in each section of the canal on a given day.

The canal capture program has been under continual review and refinement in an attempt to minimize both entanglement time and injuries/mortalities to sea turtles.

Better utilization of currents and eddies, adjustments to tethering lines, multi-net deployments and increased efforts to hand capture and dip net turtles have contributed to reduced residency times in recent years.

3.1.3 Data Collection Regardless of capture method, all turtles removed from the canal are identified to species, measured, weighed, tagged, and examined for overall condition (wounds, abnormalities, parasites, etc.). Since 1994, captured turtles have been photographed dorsally and ventrally prior to release. Additionally, as of July 2001, Passive Integrated Transponder (PIT) tags were injected subcutaneously into the right front flipper of all turtles as outlined in the BO issued by NMFS in May 2001. Healthy turtles were released into the ocean the same day of capture. When treatment was warranted, turtles were transported to an approved rehabilitation facility after consultation with FWC. Beginning in 1982, necropsies were conducted on dead turtles found in fresh condition. Currently, fresh dead turtles are held on ice and taken to a qualified veterinarian for necropsy. Methodologies associated with the canal capture program have remained essentially unchanged since 1994, making data comparable from that year through the current reporting period.

3.2 Results for 2014 Methods to remove sea turtles from the intake canal included the use of tangle nets, dip nets, and hand capture. Long handled dip nets employed from small boats, the canal banks, and headwall structures were moderately effective in capturing turtles with carapace lengths of 40 cm or less. Divers were employed to hand capture turtles whenever water visibility permitted. This technique has proven highly effective in the capture of turtles of all sizes, particularly less active individuals that are often found partially buried in the sediment near the primary barrier net. Hand capture efforts have successfully reduced residency times for turtles in the intake canal.

14

During 2014, a total of 414 sea turtles were removed from the intake canal, including 275 loggerheads, 134 green turtles, two Kemp's ridley turtles, and three hawksbills (Figures 10 and 11; Table 1). The majority of these turtles (95.4%) were captured alive and released back to the ocean. Fifteen (3.6%) were taken to rehabilitation facilities for treatment of injuries or disease and four (1.0%) turtles were found dead. None of the turtles taken to rehab facilities had injuries causal to power plant operations. None of the four turtles found dead were causal to power plant operations. Mortalities and injuries are discussed in Section 3.2.6.

In 2014, all 414 turtles entrained in the canal were captured east of the primary barrier net-235 by tangle nets, 11 off of the primary barrier net, 21 by dip net and 147 by hand capture. Proactive captures (hand capture and dip net) accounted for 40.6% of the turtles removed from the intake canal.

Decreased water flow during plant outages likely reduces the number of turtles entrained into the intake canal. In 2014, Unit 2 was in an outage from March 3 rd until April 2 3 rd.

3.2.1 Loggerhead Captures Historically, loggerheads have been the most abundant species entrained into the canal. The number of loggerheads captured each year ranged from 62 in 1981 to 623 in 2004. During 2014, monthly captures of loggerheads ranged from 13 in November to 36 in June (Table 2), with a monthly mean of 22.9. Loggerhead capture rates have exhibited considerable year-to-year fluctuation, but have shown an overall increasing trend since the plant started operation (Figure 10; Table 1). The size frequency of loggerheads captured at the intake canal of the power plant ranges from predominately juvenile to sub-adult animals, with mature adult animals captured mainly during the nesting season of April through September (Figure 12).

Of the 275 loggerheads captured where standard straight carapace length (SSCL) is available, 183 were juveniles (SSCL < 70 cm), 31 were adults (SSCL > 85 cm), and 61 were transitional (SSCL 70-85 cm; Hirth, 1980, Figure 12). The latter group probably includes both mature and immature individuals. Of the 31 turtles classified as adults, 30 were females and one was a male. Two additional loggerheads were recorded as males even though their SSCL was less than 85 cm because sex was apparent from the animal's tail length. Eleven additional loggerheads were recorded as females even though their SSCL was less than 85 cm because sex was apparent from ultrasounds taken.

15

3.2.2 Green Captures The number of green turtles captured each year has ranged from three in 1979 to a record high of 673 in 1995 (Figure 10; Table 1). A spike in green turtle captures, driven mainly by small juveniles (Bresette, Gorham, & Peery, 1998), during the mid-1990s has leveled off to a capture rate consistently greater than numbers recorded prior to 1994.

Size class frequencies of green turtles at the intake canal are dominated by juvenile animals with adults captured in relatively small numbers during the nesting season of May through October (Figure 13).

During 2014, monthly green turtle captures ranged from one in October to 40 in January (Table 2) with a monthly mean of 11.2. Of the 134 green turtles captured in 2014, there were 132 juveniles or sub-adults (SSCL < 83cm) and two adult females (SSCL > 83 cm; Witherington and Ehrhart, 1989, Figure 13).

3.2.3 Leatherback, Hawksbill, and Kemp's ridley Captures Captures of leatherback, hawksbill, and Kemp's ridley turtles have been infrequent and scattered throughout the years (Figure 11 and Table 1). However, each species has shown rather pronounced seasonal occurrences (Table 3). Leatherbacks are typically captured in March and April, hawksbills are captured between July and September, and Kemp's ridleys are caught between December and April.

In 2014, there were two Kemp's ridley turtles and three hawksbills captured in the intake canal of the St. Lucie Plant (Table 1). Two subadult Kemp's ridley sea turtles were captured on January 11 th and January 3 0 th, with an SSCL of 47.5 cm and 46.9 cm, respectively. A female hawksbill was captured on March 2 7 th and had a SSCL of 72.4 cm. A juvenile hawksbill was captured on September 4 th and had a SSCL of 36.8 cm.

The remains of an adult hawksbill most likely entrained post-mortem were found at the bottom of the intake canal on January 14 th. No leatherbacks were entrained into the intake canal in 2014.

3.2.4 Recaptures Since plant operation began in 1976, a total of 15,998 sea turtles (including recaptures) have been captured, including 9,206 loggerhead, 6,634 green, 63 hawksbill, 56 Kemp's ridley, and 39 leatherback turtles (Table 1).

Most turtles removed from the intake canal have been tagged and released into the ocean at various locations along South Hutchinson Island. Consequently, individual turtles can be identified as long as they retain their tags. Over the history of the program at the St. Lucie Plant, 2,931 recapture events (691 loggerheads and 2,240 16

green turtles) have occurred. The recapture rate in 2014 was 7.6% for loggerheads and 46.3% for greens. Occasionally, turtles are captured that have been tagged by other researchers. There were three such captures in 2014, all loggerheads. One loggerhead was originally tagged by South Carolina DNR in northern Florida. Another loggerhead was tagged off the coast of Spain. The last loggerhead was tagged by the University of Central Florida on Melbourne Beach, FL. In 2014, there were two incidences of turtles tagged at the intake canal that were subsequently observed by other research groups. One loggerhead was spotted by UCF researchers monitoring sea turtle nesting in Melbourne Beach, FL. One green turtle was entrained in the intake wells of the FPL Riviera Beach Clean Energy Center in Riviera Beach, FL.

3.2.5 Relative Condition Turtles captured alive in the intake canal of the St. Lucie Plant are assigned a relative condition based on weight, activity, parasite infestation, epibiont coverage, injuries, and any other abnormalities that might affect overall vitality. Relative condition ratings can be influenced by a number of factors, some related and others unrelated to entrainment into the intake canal. A rating of good indicates that turtles have not been negatively impacted by their entrapment in the canal, as evidenced by physical appearance.

Although ratings of fair or poor imply reduced vitality, the extent to which entrainment and entrapment are responsible is often indeterminable. In some instances, acute injuries responsible for lower overall condition ratings, such as boat collision, fisheries gear entanglement, or disease were obviously sustained prior to entrainment. However, in recent years, turtles have been found with fresh scrapes and cuts incurred during the entrainment process. Some of these incidents have had a negative effect on a sea turtle's overall condition and have been categorized as directly causal to power plant operation. Causal determinations are made by consultation with personnel from FWC and/or a qualified veterinarian.

During 2014, of the 275 loggerheads captured, 93.1% (256) were alive and in good condition. Only 6.5% (18) of all loggerheads were individuals in fair or poor condition, and 0.4% (1) was found dead. Of the 134 green turtles removed from the intake canal 91.0% (122) were in good condition, 7.5% (10) were in fair or poor condition and 1.5%

(2) were found dead.

Of the 414 turtles removed from the intake canal during the year, 352 (85.1%) were observed with fresh cuts and scrapes that may have been incurred during transit through the intake pipes. The scrapes varied in degree of severity, although most (90.6%) of the scrapes were classified as minor. However, some of the scrapes (9.4%)

were moderate. No turtles had a fresh scrape categorized as severe and warranted the turtle being sent to a rehabilitation facility.

17

3.2.6 Mortalities and Injuries Injuries and mortalities are categorized in two ways-causal to power plant operation or non-causal to power plant operation. These decisions are made in consultation with FWC and/or a qualified veterinarian. Not all mortalities and injuries are causal to power plant operation, as some sea turtles enter the canal in either a moribund state or have had pre-existing conditions related to fisheries, boat interactions or disease. Injuries causal to power plant operation are recorded and are applied against the take limit established by the most recent BO set forth by NMFS.

Sea turtle mortalities have been closely monitored throughout the history of the capture program in an attempt to assign probable cause and take remedial action to minimize future occurrences. Modifications to capture procedures, improvements to barrier nets, and virtual elimination of low flow conditions within the intake pipes have resulted in a substantial reduction in sea turtle mortalities over the life of the canal capture program.

Mortality rate declined from 7.8% during the period 1976-1984 to 1.3% for the period 1985 to present (Table 1). Over the entire monitoring program's history (1976-2014),

178 (2.0%; including hatchlings from 2006) loggerheads and 97 (1.5%) green turtles entrained in the canal were found dead. Only four Kemp's ridley mortalities have been documented at the St. Lucie Plant during 1987 and 1988. In 2014, the first hawksbill mortality was recorded. There have been no leatherback mortalities in the history of the project.

In 2014, four mortalities were recorded at the St. Lucie Power Plant intake canal: one loggerhead, two green turtles, and one hawksbill turtle. No mortalities were considered causal to power plant operations.

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4.0 Sea Turtle Protective Activities 4.1 NMFS Section 7 Consultations In accordance with Section 7 of the ESA, FPL must submit a Biological Assessment to NMFS for review if FPL exceeds the incidental take limit established by the most recent BO. The BO is an analytical document that looks at the effects of a federal action on endangered and threatened species.

Section 7(b)(4) of the ESA refers to the incidental take of listed species. It sets forth the requirements when a proposed agency action is found to be consistent with section 7(a)(2) of the ESA and the proposed action may incidentally take listed species. NMFS is responsible for issuing a statement that specifies the impact of any incidental take of endangered or threatened species. It also states that reasonable and prudent measures, and terms and conditions to implement the measures, be provided to minimize such impacts.

In 1999, FPL exceeded their anticipated incidental take limit established by the 1997 BO set forth by NMFS. This required reinitiating of consultation under Section 7 of the ESA.

As part of this consultation, FPL conducted a study on the factors influencing sea turtle entrainment (EAI, 2000). NMFS considered this new information when developing the new opinion. On May 4, 2001, NMFS issued its BO as part of the reinitiating of consultation subsequent to the 1997 BO.

In the 2001 BO there were a number of changes, most importantly in the Incidental Take Statement. This states that FPL will exceed their take limits for a calendar year if any of the following occur: 1) more than 1000 sea turtles are captured, 2) more than 1%

of the total number of loggerhead and green turtles (combined) are injured/killed due to plant operation, 3) more than two Kemp's ridley sea turtles are injured/killed due to plant operation, or 4) if any hawksbill or leatherback sea turtles are injured/killed due to plant operation. In the case where 1% of the combined loggerhead and green turtle captures is not a whole number, it is rounded up (e.g. 520 combined captures = take limit of 6).

Under section 7 of the Endangered Species Act a new consultation with NMFS is required If FPL meets or exceeds the take limits specified in the Incidental Take Statement.

During 2014, there were no sea turtle mortalities or injuries that were causal to power plant operations. No leatherback, hawksbill or Kemp's ridley turtles were injured or killed due plant operation. A total of 414 turtles were captured in the FPL intake canal for the year. Based on the latest BO issued by NMFS, FPL did not exceed its take limit during 2014. However, FPL did exceed their sea turtle take limit at the St. Lucie Power Plant in 2006 and reinitiating a Section 7 consultation was required. This consultation is 19

currently ongoing between NMFS and the NRC. A new BO is expected in 2015. FPL has identified the contributing factors that led to exceeding the take limit in 2006 and the company has responded by cleaning the intake pipes and developing a plan to install turtle excluder panels on the offshore intake structures. These grated panels would exclude all adult sea turtles from being entrained into the power plant's intake canal.

4.2 Sea Turtle Stranding and Salvage Network and Turtle Walks An amendment to the EPP, Requirement 4.2.1 of the St. Lucie Unit 2 operating license Appendix B, was approved in 1999. This mandated that participation in the Sea Turtle Stranding and Salvage Network (STSSN) and Public Service Turtle Walks was to become part of the BO and Incidental Take Statement issued by NMFS.

As participants in the STSSN, IRG's sea turtle biologists routinely respond to sea turtle strandings in St. Lucie and Martin Counties. This activity involves the collection of information on turtles that are found dead, debilitated, or that have been impacted by human-related activities. All permit holders participating in this program are required to complete a STSSN stranding report for each dead or debilitated turtle encountered.

Completed stranding reports are then sent to FWC.

Sea turtle nesting walks are conducted by FPL as part of their public outreach programs during the summer sea turtle nesting season. These turtle walks educate the public about relevant sea turtle protection issues and, in most cases, allow the public to view a nesting loggerhead sea turtle.

4.2.1 Results for 2014 During 2014, IRG biologists responded to 16 (6 loggerhead, 10 green) stranding events in St. Lucie County. The turtles were found in various stages of decomposition. Of these 16 turtles, the probable cause of stranding included three boat strikes, three with severe fibropapilloma tumors, two shark attacks, and two fishing line entanglements.

The remaining 6 turtles were either too decomposed, had injuries of an unknown origin, or otherwise lacked any salient wounds or abnormalities to indicate a probable cause of death.

IRG biologists also responded to strandings at one other FPL facility. Four live loggerheads (two juveniles and two subadults) and three live juvenile green turtles were documented at the Riviera Beach Clean Energy Center. These turtles were captured, measured and if found with injuries were taken to a rehabilitation facility. If not injured the turtles were released back into Lake Worth Lagoon.

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FPL conducted 13 turtle walks between June 6 h and July 2 4 th, 2014. During these programs, a total of 428 people attended and on 12 of the 13 turtle walks participants were able to view a nesting female loggerhead turtle.

4.3 Collaborative Efforts IRG biologists continue to assist other sea turtle researchers, universities, nonprofit organizations, and state and federal agencies by providing data, specimens, and public outreach. IRG biologists at the St. Lucie Power Plant continued to collaborate with other researchers on three research projects in 2014.

IRG biologists collected blood samples and assisted with ultrasounds from 38 loggerheads (> 80 cm SCL) captured in the canal and 11 nesting females for a study on ovarian dynamics. The research was conducted by a graduate student from Southeastern Louisiana University. Lateral photographs of two loggerhead turtles (< 55 cm SCL) were taken for a growth research conducted at Florida Atlantic University.

Unhatched eggs from loggerhead nests were also collected for stable isotope analysis conducted by University of Central Florida.

4.4 Barrier Net Maintenance Maintaining the integrity of the barrier nets is essential to reducing mortality rates and residency times of entrained sea turtles and is mandated by the most recent BO issued by NMFS. Daily inspections are performed from a small boat to remove floating debris and to repair holes at or near the water's surface. Quarterly inspections and cleaning debris from the net when warranted was conducted by Underwater Engineering Services, Inc. (UESI). In addition to scheduled inspections and cleaning of the nets, divers are deployed when the integrity of the nets are threatened by algae events.

These algae events can cause undue stress to the net structures and may cause the net to fail. Net failures increase both the risk of sea turtle mortalities and residency times. Turtles can become tangled in or pinned under a failed barrier net, leading to a causal drowning mortality. Furthermore, if turtles have access to larger portions of the intake canal, then it becomes more challenging to quickly entrap and release these animals back into their natural environment. The primary barrier net, with few exceptions, has effectively confined sea turtles to the eastern 200 meters of the intake canal.

During 2014, there was one net failure. On February 18th, a small section of the 5" primary net failed due to a severe algae build-up on the net. UESI divers returned the net height to above the water line within 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. IRG biologists began monitoring west of the 5" during the failure. No turtles were spotted west of the 5" net or subsequently captured in the intake wells. In 2014, routine quarterly inspections of the 21

temporary primary barrier net and the AlA net were completed. During these inspections, debris was removed from both nets. No holes were found during the quarterly inspections in the primary barrier or Al A barrier nets. One hole in the primary net was discovered and repaired by UESI during an algae intrusion event.

4.5 Intake Pipe Cleaning and Maintenance Beginning in 2002 there was a steady increase in the number of sea turtles incurring scrapes during transit through the power plant intake pipes. These scrapes varied in degree of severity, with most being minor and similar to those found on sea turtles that inhabit nearshore reefs. However, some scrapes were moderate or severe, causing some turtles to be sent to rehabilitation facilities for treatment. This prompted FPL to inspect the intake pipes in 2006 and schedule cleaning of bio-fouling and marine debris that were thought to be causing the scrapes to entrained sea turtles.

Cleaning and removal of debris from the intake pipes and offshore intake structures began in October of 2007 and was completed in February 2011. Additionally, two openings that extended from the top of the two 12' intake pipes were also sealed off during this time.

22

5.0 References Applied Biology, Inc. (1978). Ecologicalmonitoring at the FloridaPower & Light Company, St. Lucie Plant,Annual Report 1977, Volumes I and II (AB-1 01).

Prepared by Applied Biology, Inc. for Florida Power & Light Co., Miami, FL.

Applied Biology, Inc. (1980). Florida Power & Light Company, St. Lucie PlantAnnual Non-radiologicalEnvironmentalMonitoring Report 1979, Volumes II and Ill, Biotic monitoring (AB-244). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Miami FL..

Applied Biology, Inc. (1984). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1983 (AB-533). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach,FL.

Applied Biology, Inc. (1985). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1984. Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

Applied Biology, Inc. (1986). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1985 (AB-563). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

Applied Biology, Inc. (1987). Florida Power and Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1986 (AB-579). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

Applied Biology, Inc. (1988). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1987 (AB-595). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

Applied Biology, Inc. (1989). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1988 (AB-596). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

Applied Biology, Inc. (1990). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1989). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

Applied Biology, Inc. (1991). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1990 (AB-610). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach FL.

Applied Biology, Inc. (1992). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1991 (AB-617). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

Applied Biology, Inc. (1993). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalOperating Report 1992 (AB-623). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Juno Beach, FL.

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Applied Biology, Inc. (1994). Florida Power & Light Company, St. Lucie Unit 2 Annual EnvironmentalMonitoring Report 1993 (AB-631). Prepared by Applied Biology, Inc., for Florida Power & Light Company, Juno Beach, FL.

Bresette, M., Gorham, J., & Peery, B. (1998). Site fidelity and size frequencies of juvenile green turtles (Chelonia mydas) utilizing near shore reefs in St. Lucie County, Florida. Marine Turtle Newsletter, 82, 5-7.

Davis, G.E., & Whiting, M.C. (1977). Loggerhead sea turtle nesting in Everglades National Park, Florida, USA, Herpetologica, 33, 18-28.

Dodd, C.K., Jr. (1988). Synopsis of the biologicaldata on the loggerheadsea turtle Caretta caretta (Linnaeus1758). U.S. Fish and Wildlife Service Biological Report 88(14).

Ecological Associates, Inc. (2000). Physicaland EcologicalFactorsinfluencing Sea Turtle EntrainmentLevels at the St. Lucie Power Plant 1976-1998. Submitted to Florida Power & Light Company.

Fossette, S., Hobson, V.J., Girard, C., Calmettes, B., Gaspar, P., Georges, J., & Hays, G.C. (2010). Spatio-temporal foraging patterns of a giant zooplanktivore, the leatherback turtle. Journalof Marine Systems, 81, 225-234.

Heppel, S.S., Snover, M.L., & Crowder, L.B. (2003). Sea Turtle Population Ecology. In P. L. Lutz, J. A. Musick, & J. Wyneken (Eds.), Biology of Sea Turtles Volume II (pp. 275-306).

Hirth, H.F. (1980). Some aspects of the nesting behavior and reproductive biology of sea turtles, American Zoologist, 20, 507-523.

Inwater Research Group, Inc. (2010). Florida Power and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 2009. Prepared by Inwater Research Group, Inc. for Florida Power and Light Company, Juno Beach, FL.

Inwater Research Group, Inc. (2011). Florida Power and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 2010. Prepared by Inwater Research Group, Inc. for Florida Power and Light Company, Juno Beach, FL.

Inwater Research Group, Inc. (2012). Florida Power and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 2011. Prepared by Inwater Research Group, Inc. for Florida Power and Light Company, Juno Beach, FL.

Inwater Research Group, Inc. (2013). Florida Power and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 2012. Prepared by Inwater Research Group, Inc. for Florida Power and Light Company, Juno Beach, FL Meylan, A.B., Schroeder, B. & Mosier, A. (1995). Sea turtle nesting activity in the state of Florida, 1979-1992. FloridaMarine Research Publications,52, 1-51.

National Marine Fisheries Service & U.S. Fish and Wildlife Service (1991). Recovery plan for U.S. population of the loggerheadturtle (Caretta caretta). National Marine Fisheries Service, Washington D.C.

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Quantum Resources Inc. (1995). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 1994. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (1996). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 1995. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (1997). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 1996. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (1998). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 1997. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (1999). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 1998. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2000). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 1999. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2001). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2000. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2002). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2001. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2003). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2002. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2004). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2003. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2005). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 2004. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2006). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2005. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2007). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2006. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

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Quantum Resources Inc. (2008). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 2007. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Quantum Resources Inc. (2009). FloridaPower and Light Company, St. Lucie Unit 2 Annual Environmental OperatingReport 2008. Prepared by Quantum Resources Inc. for Florida Power and Light Company, Juno Beach, FL.

Schroeder, B.A. & Thompson, N.B. (1987). Distribution of the loggerheadturtle (Caretta caretta)and leatherback turtle (Dermochelys coriacea) in the Cape Canaveral, Floridaarea; results from aerialsurveys (NOAA Technical Report, NMFS-53).

Stewart, K., Sims, M., Meylan, A., Witherington, B., Brost, B., & Crowder, L. (2011).

Leatherback nests increasing significantly in Florida, USA; trends assessed over 30 years using multilevel modeling. EcologicalApplications, 21(1), 263-273.

Turtle Expert Working Group. (2000). Assessment update for the Kemp's ridley and loggerheadsea turtle populations in the western Atlantic (NOAA Technical Memorandum NMFS-SEFSC-444). U.S. Department of Commerce.

Witherington, B.E., & Ehrhart, L. M. (1989). Status and reproductive characteristics of green turtles (Chelonia mydas) nesting in Florida. In Ogren, L., F. Berry, K.

Bjorndal, H. Kumpf, R. Mast, G. Medina, H. Reichart and R. Witham (Eds.),

Proceedingof the Second Western Atlantic Turtle Symposium, Mayaguez, Puerto Rico, 12-16 October 1987 (pp-351-352). NOAA Technical Memorandum NMFS-SEFC-226.

Witherington, B., Bresette, & Herren, R. (2006). Chelonia mydas - green turtle. In Meylan, P.A. (Eds.), Biology and Conservation of Florida Turtles (pp90-104).

Chelonian Research Monographs.

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6.0 Figures and Tables FLORIDA GULF OF MEXICO

-N-I b"

4-Figure 1. Location of St. Lucie Plant on South Hutchinson Island, Florida.

27

Figure 2. St. Lucie Plant cooling water intake and discharge system.

28

A FPL ST. LUCIE PLANT LIMIT OF CURRENT SURVEY U

V x

Y y

BB cc DD IFF GG NH ST. LUCIE INLET DRAWING NOT TO SCALE Figure 3. Designation and location of nine 1.25 km segments (in brackets) and thirty-six 1 km segments surveyed for sea turtle nesting on South Hutchinson Island (1971-2014).

29

9,000 8,000 7,000 11V 6,000 ro V 4-P z

5,000

  • rv ýr V\j ý 4,000 4

3,000 2,000 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I M-W4 O40 0 0 Year Figure 4. Number of loggerhead turtle nests on South Hutchinson Island from 1971 through 2014. Values for 1971 through 1979 are estimates (see section 2.1.1); values for 1981 through 2014 are from whole island surveys.

30

900 800 700 600 500 z

400 300 200 1 A tillI! /4 II I 14 I I U 100 *iAM I 1IA1'

ý *

  • 11ý, 1 4 AA"*^ V 4 V ý ý I I1 ' I F I I I I I I I I I T' I I I I I I I I I I I I I I I W ~~~~-1 ~ - -

W-4 CO Go M0 0 0 M~ M~ M On 0 00

%-N V4 NA Year Figure 5. Number of green turtle nests on South Hutchinson Island from 1971 through 2014. Values for 1971 through 1979 are estimates (see section 2.1.1); values for 1981 through 2014 are from whole island surveys.

31

600 500 400 AA W 300 III t z

200 100 n A, 'A' Go Go M0 0 0 M A n I 0 00 V-1 Nq NN Year Figure 6. Number of leatherback turtle nests on South Hutchinson Island from 1971 through 2014. Values for 1971 through 1979 are estimates (see section 2.1.1); values for 1981 through 2014 are from whole island surveys.

32

100% 11 E Loggerhead l

[Green 75%

4A 50%

25% ... ..

0% V A B C D E F G H I 7-J Zone K

-rr L M N 0 T-P Q R S Power Plant Figure 7. Loggerhead and green turtle nesting success (percentage of emergences resulting in nests) for each of the 1 km zones A through S (North to South) on South Hutchinson Island for the 2014 nesting season.

33

400 300 zv200 100 0

A B C D E F G H I J K L M N 0 P Q R S Zone Power Plant Figure 8. Number of turtle nests by species for each of the 1 km zones A through S (North to South) on South Hutchinson Island for the 2014 nesting season.

34

60%

50%

40%

~30%

Z 20%

10%

0%

A B C D E F G H I J K L M N O P Q R S Zones t

Power Plant Figure 9. Percentage of sea turtle nests depredated byl km zones A through S (North to South) on South Hutchinson Island for the 2014 nesting season.

35

1000 90Green 0 Loggerhead 900 800 700 600 Z 500 400 300 200 ,

100 W Go ~ L O O ~ ~@ O e W0 ~

Wq IqI T-4 V4 TI V4 I1V4 1 T1 I Vq 1I 4 N 4 r N N N Year Figure 10. Number of loggerhead and green turtles captured and removed each year from the intake canal at the St. Lucie Power Plant, 1976 through 2014.

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15 10 (A

5 Yea 0i o *a

  • a*
  • o*
  • a*
  • o* o* a 0 0 0 0 0 0 0 0 Year Figure 11. Number of Kemp's ridley, hawksbill, and leatherback turtles captured and removed each year from the intake canal at the St. Lucie Power Plant, 1976 through 2014.

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80 70 60 50 IA 040 (U

30 20 10

  • 0 I 4,/

4, 4,' -7 Straight Standard Carapace Length (cm)

Figure 12. Size distribution (Straight Standard Carapace Length; SSCL) of loggerhead turtles (n=275) captured and removed from the intake canal at the St. Lucie Power Plant during 2014.

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35 30 25 20 10 5

0 Straight Standard Carapace Length (cm)

Figure 13. Size distribution (Straight Standard Carapace Length; SSCL) of green turtles (n=1 34) captured and removed from the intake canal at the St. Lucie Power Plant during 2014.

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Year Loggerhead Green Leatherback Hawksbill Kemp's ridle y Total 1976- 1984 962 156 l,7 2 3 1130 89' 1985 157 141 172 197 195 22 220 2 1987 175 35 2 6 218 1988 134 42 5 181 1989 ill 17 12 2 133 1990 112 20 132 ,

1991 107 1 121 l 1992 123 61 2 187 4, 1993 147 179 5 2 4 337 1994 1419322 361 4 1995 254 673 15 933 1 19 349 549 5 3 1997 188 191 2 1 382  :

1998 393 268 1 2 2 666 495 fi 1999 302 190 1 1 2000 344 345 2 6591 200 270 321 2 6 600 2002 341 292 3 6316 2003 538 394 46 2 944 204 623 286 2 2 1 914 2005 428 2 3 917 2006 419 267 12 3 692 2007 227 101 1 1 330 2008 420 299 42 725 4,4 2009 260 161 1 2 424 751 'lz 2010 295 444 2 3 7 2011 302 217 2 521 2012 232 127 2 71 362 2013 303 162 2 503 2014 275 134 3 2 414 Total 9206 6634 39 63 1 56 I Mean*j 248.1 l174.6 1.1 1.7 01.5 ~432.4 Table 1. Total number of captured turtles removed from the intake canal at the St. Lucie Power Plant from 1c 176 through 2014. Number of mortalities is highlighted in gray. Mean excludes partial year of 1976 when 26 loggerheads were captured.

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Loggerhead Green Percent Percent 2014 Total of 2014 Total of Months Captures Captures Captures Mean Captures Captures Captures Mean January 31 848 9.2% 22.3 40 823 12.4% 21.7 February 24 808 8.8% 21.3 12 684 10.3% 18.0 March 18 962 10.5% 25.3 5 772 11.6% 20.3 April 23 912 9.9% 24.0 6 478 7.2% 12.6 May 31 846 9.2% 22.3 9 463 7.0% 12.2 June 36 975 10.6% 25.7 4 406 6.1% 10.7 July 25 1196 13.0% 31.5 10 388 5.8% 10.2 August 20 805 8.8% 21.2 8 392 5.9% 10.3 September 15 556 6.1% 14.6 14 510 7.7% 13.4 October 17 473 5.2% 12.4 1 618 9.3% 16.3 November 13 359 3.9% 9.4 11 548 8.3% 14.4 December 22 466 5.1% 12.3 14 552 8.3% 14.5 Total 275 9180 248.1 134 6634 174.6 Table 2. Total number of loggerhead and green turtles removed each month from the intake canal at the St. Lucie Power Plant from 1977 through 2014. Monthly totals exclude the partial year 1976 when 26 loggerheads were captured.

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Leatherback Hawksbill Kemp's ridley Percent Percent Percent 2014 Total of 2014 Total of 2014 Total of Months Captures Captures Captures Mean Captures Captures Captures Mean Captures Captures Captures Mean January 0 5 12.8% 0.1 1 1 1.6% 0.0 2 10 17.9% 0.3 February 0 4 10.3% 0.1 0 1 1.6% 0.0 0 13 23.2% 0.3 March 0 12 30.8% 0.3 1 8 12.7% 0.2 0 12 21.4% 0.3 April 0 7 17.9% 0.2 0 3 4.8% 0.1 0 11 19.6% 0.3 May 0 4 10.3% 0.1 0 3 4.8% 0.1 0 2 3.6% 0.1 June 0 2 5.1% 0.1 0 2 3.2% 0.1 0 2 3.6% 0.1 July 0 0 0.0% 0.0 0 13 20.6% 0.3 0 1 1.8% 0.0 August 0 1 2.6% 0.0 0 9 14.3% 0.2 0 0 0.0% 0.0 September 0 2 5.1% 0.1 1 12 19.0% 0.3 0 0 0.00/0 0.0 October 0 0 0.0% 0.0 0 5 7.9% 0.1 0 1 1.8% 0.0 November 0 1 2.6% 0.0 0 5 7.9% 0.1 0 1 1.8% 0.0 December 0 1 2.6% 0.0 0 1 1.6% 0.0 0 3 5.4% 0.1 Total 0 39 1.0 1 63 1.7 2 56 1.5 Table 3. Total number of leatherback, hawksbill, and Kemp's ridley turtles removed each month from the intake canal at the St. Lucie Power Plant from 1977 through 2014. Monthly totals exclude the partial year 1976 when 26 loggerheads were captured.

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7.0 Annual Environmental Operating Report 7.1 Introduction The St. Lucie Units 1 & 2 Environmental Protection Plans (EPP) require the submittal of an annual report for various activities at the plant site including the reporting on sea turtle monitoring programs, and other matters related to Federal and State environmental permits and certifications.

7.2 Sea Turtle Monitoring and Associated Activities Surveillance and maintenance of the light screen to minimize sea turtle disorientation as required by Section 4.2.3 of the EPP is ongoing. The vegetation light screen located on the beach dune between the power plant and the ocean is routinely surveyed to determine its overall vitality. Evidence of sea turtle disorientation that occurs would also indicate any significant problems. Trees, vegetation or shade cloth are replaced as necessary to maintain the overall integrity of the light screen. Plant parking lot lighting is also designed and maintained to minimize light levels on the beach.

7.3 Taprogge Condenser Tube Cleaning System Operation A Taprogge condenser tube cleaning system (CTCS) became operational on St. Lucie Unit 2 in January 1996 and on Unit 1 in July 1996. This system utilizes sponge balls, approximately 23 mm in diameter, to clean the condenser tubes through which seawater flows to cool steam after its pass through the plant's turbines. This system improves plant performance while reducing the need for chemical treatments such and biocides or chlorine to control biofouling.

Normally, the St. Lucie CTCS utilizes about 1800 sponge balls, which are continually re-circulated through each of four "water boxes" on each unit. These sponge balls are retained in the system by a ball strainer located on the outlet of each water box. The ball strainers (mesh size 5 mm) are opened routinely to discharge debris, which can decrease flow and obstruct sponge ball movement through the system. The sponge balls are collected prior to opening, or back flushing, the ball strainers. At that time, the 43

sponge balls are examined and replaced if they are worn to the point that they can no longer effectively clean the condenser tubes.

Sponge ball inventories and estimates of sponge ball loss to the environment have been performed since system start-up on both units. Number of ball strainer back flushes has also been tracked. In addition, daily beach surveys have been performed on plant property (approximately 2.5 miles) to note any sponge balls that may occur as a result of loss from the plant. This survey area has been extended during the turtle nesting season to almost 12 miles.

Ball loss reporting is required in accordance with the St. Lucie site environmental permit, a component of the site license. Best management practices are used to minimize the discharge of CTCS balls to the Atlantic Ocean.

The sponge cleaning balls are made of natural latex which will biodegrade and break down after about two months in a high nutrient seawater environment. Biodegradation can occur while balls are in service and weaken the latex sponge, leading to premature ball fatigue failure from cycle fatigue induced by the CTCS ball circulation impeller.

Although blue stripe balls are more resistant to biodegradation compared to orange balls, they are not as effective for tube cleaning during the last two weeks of service.

The five week maximum service interval is adequate to prevent most ball failure events.

Best management practices continue to be applied to minimize the results of the program for 2014 are presented in Table 1. CTCS ball loss.

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7.4 Other Routine Reports The following items for which reporting are required are listed by section number from the plant's Environmental Protection Plan:

5.4.1.2(a) EPP Noncompliance Incidents and Corrective Actions Taken No incidents of noncompliance under EPP Section 5.4.1 (a) were determined to have occurred during 2014.

5.4.2(b) Changes in Station Design or Operation, Tests, and Experiments in Accordance with EPP Subsection 3.1 No changes in station design, operation, tests, and experiments were determined to have occurred during 2014.

5.4.1.2(c) Non-routine reports were submitted to the NRC for the year 2014 in accordance with EPP Subsection 5.4.2.

On May 22, 2014, St. Lucie Plant submitted to the NRC a copy of a Request for Minor Revision to our Industrial Waste Water (IWW) Permit pertaining to emergency storm water discharge. Notification to the NRC occurred via FPL letter L-2014-145.

On May 23, 2014, St. Lucie Plant submitted to the NRC a copy of preliminary findings for the St. Lucie Biological Plan of Study as required by the site IWW Permit.

Notification to the NRC occurred via FPL Letter L-2014-150.

On November 20, 2014, St. Lucie Plant submitted to the NRC a copy of the matter pertaining to the Heated Water Plan of Study (HWPOS) as required by the site IWW Permit. Notification to the NRC occurred via FPL Letter L-2014-347.

On December 10, 2014, St. Lucie Plant submitted to the NRC a letter from the State of Florida approving a Minor Permit Revision for Storm Water Management via the St.

Lucie Industrial Wastewater Permit No. FL0002208. Notification to the NRC occurred via FPL Letter L-2014-373.

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7.5 Figures and Tables.

Table 1 PSL CTCS Ball Loss 2014 Summary lAl 1A2 1Bi 1B2 PSL 1 ALL

  1. B/W LOST #B/W LOST #B/W LOST #B/W LOST #B/W LOST COMMENTS Jan-14 2 0 1 0 3 349 3 0 9 350 Feb-14 3 19 2 13 2 66 2 588 9 686 Mar-14 3 75 2 87 4 194 2 19 11 375 Apr-14 3 172 3 65 3 88 3 22 12 347 May-14 2 49 2 82 3 267 1 0 8 398 Jun-14 4 111 3 160 4 254 4 644 15 1169 Jul-14 4 114 5 144 4 147 4 111 17 516 Aug-14 3 129 2 112 3 283 3 124 11 648 Sep-14 3 98 2 75 3 135 2 99 10 407 Oct-14 3 142 2 100 3 112 3 949 11 1303 Nov-14 5 1994 5 601 4 138 3 54 19 2787 Dec-14 4 129 5 198 4 161 5 407 18 895 Summary 39 3032 34 1637 40 2194 37 3017 150 9881 2A1 2A2 2B1 2B2 PSL2 ALL
  1. B/W LOST #B/W LOST #B/W LOST #B/W LOST #B/W LOST COMMENTS Jan-14 3 52 3 26 0 0 3 28 9 106 Feb-14 4 128 3 76 3 80 4 98 14 382 Mar-14 0 0 1 5 1 66 1 33 3 104 Apr-14 0 0 0 0 1 49 0 0 1 50 May-14 3 68 3 192 3 173 3 161 12 594 Jun-14 3 152 2 115 2 184 2 192 9 643 Jul-14 2 28 2 31 3 82 3 416 10 557 Aug-14 3 74 3 72 2 55 2 72 10 273 Sep-14 3 213 3 43 4 205 3 894 13 1355 Oct-14 4 78 2 93 1 0 4 158 11 329 Nov-14 5 432 3 233 2 31 2 13 12 709 Dec-14 3 47 3 38 4 73 3 28 13 186 Summary 33 1272 28 924 26 998 29 2093 145 5287 1 46