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Annual Environmental Operating Report, 2016
	ML17132A212
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Site:	Saint Lucie
Issue date:	04/26/2017
From:	; Florida Power & Light Co, Inwater Research Group
To:	; Office of Nuclear Reactor Regulation
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ML17132A225	List: L-2017-078, Annual Environmental Operating Report, 2016; L-2017-078, St. Lucie, Units 1 and 2 - Submittal of 2016 Annual Environmental Operating Report; ML17132A211;
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FLORIDA POWER & LIGHT COMPANY ST. LUCIE PLANT ANNUAL ENVIRONMENTAL OPERATING REPORT 2016 FLORIDA POWER & LIGHT COMPANY JUNO BEACH, FLORIDA INWATER RESEARCH GROUP, INC.

JENSEN BEACH, FLORIDA

Environmental Operating Report Table of Contents Acronyms ......................................................................................................................... 1 Executive Summary ........................................................................................................ 2 1.1 Background ........................................................................................................ 4 1.2 Area Description ................................................................................................. 4 1.3 Power Plant Description ..................................................................................... 4 1.4 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 2016 ................................................................................................. 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 Resultsfor2016 ..................................................... ~ .......................................... 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 Smalltooth Sawfish Captures ..................................................................... 16 3.2.5 Recaptures ................................................................................................ 16 3.2.6 Relative Condition ..................................................................................... 17 3.2.7 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 2016 ........................................................................................ 21 4.3 Collaborative Efforts ......................................................................................... 21 4.4 Barrier Net Maintenance .................................................................................. 21 4.5 Intake Pipe Cleaning and Maintenance ... *......................................................... 22 6.0 Figures and Tables .............................................................................................. 27 7.0 Annual Environmental 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 ..................................................................................... 44 7.5 Figures and Table ............................................................................................ 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 FWRI Florida Fish and Wildlife Research Institute FPL Florida Power & Light IRG lnwater 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's (FPL) St. Lucie Plant, located on South Hutchinson Island, consists of two 1,000 MWe nuclear-fueled electric generating units that use nears ho re 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 (Oermochelys coriacea) turtles. Under the Endangered Species Act (ESA), the federal government has classified loggerhead and green turtles as threatened species while leatherbacks 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 2016, 9,892 loggerhead, 219 green, and 232 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 2016, 486 sea turtles were removed from the intake canal, including 316 loggerheads, 159 greens, six Kemp's ridleys, one leatherbacks, and four hawksbills. The majority of these turtles (92.8%) were captured alive and released back to the ocean. Twenty-six (5.3%)

were taken to rehabilitation facilities for treatment of injuries or disease and nine turtles (1.9%) were recorded as deceased (including one loggerhead that died during transit to rehab).

Injuries and mortalities are categorized in two ways-causal to power plant operations or non-causal to power plant operations. T~ese 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 2

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to power plant operations are recorded and are applied against the take limit established by the new 2016 Biologica.1 Opinion (BO) set forth by the National Marine Fisheries Service (NMFS). The Incidental Take Statement in the new BO states that FPL would exceed its take limit if: 1) more than 623 loggerheads, 500 green turtle, 7 hawksbills, 8 Kemp's ridleys, or 5 leatherbacks are captured annually, 2) more than 7 green turtles or 3 loggerheads are documented with severe causal injuries annually, 3) more than 5 green turtles or 3 loggerhead are documented as causal mortalities annually, 4) more than 1 hawksbill, Kemp's ridley, or leatherback are documented with either a severe causal injury or is a causal mortality every two years, 5) more than one smalltooth sawfish is captured every five years or any smalltooth sawfish are ever killed.

During 2016, there were 316 loggerheads, 159 green turtles, six Kemp's ridleys, four hawksbills, and one leatherback capture. There was one loggerhead mortality that was considered causal to power plant operations. No leatherback, hawksbill or Kemp's ridley turtles were injured or killed due plant operation. Additionally, no smalltooth sawfish were encountered. Therefore, based on the latest BO issued by NMFS, FPL did not exceed its take limit during 2016.

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 2016, IRG biologists responded to 23 stranding events. 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 2016, FPL conducted 12 turtle walks attended by 332 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 four projects in 2016.

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1.1 Background 1.2 Area Description Florida Power & Light's (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.

1.3 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 discharges, the first of which are 730 m north of the intake and extend approximately 365 m offshore. The second pipeline is located just to the south of the first and is nearly twice as long.

1.4 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 intake and discharge of this water have been the subject of FPL sponsored biotic 4

studies at the site (Applied Biology, Inc. [ABI] 1978, 1980, 1986-1989, 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 32 annual environmental operating reports covering the period from 1983 through 2015 (ABI 1984-1994; Quantum Resources, Inc. 1995-2009; lnwater Research Group, Inc. [IRG] 2010-2016). This report describes the 2016 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 (Che/onia mydas), a*nd leatherback (Oermoche/ys coriacea) turtles (Meylan, Schroeder, & Mosier, 1995). Under the ESA, the federal government has classified loggerhead and greens turtle as a threatened species while leatherbacks 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, the 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 21 5 \ nests were left in situ. Beginning on May 22nd, 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 2016, 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 southern 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 2016 In 2016, Zones E-S were surveyed by lnwater 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 1st th.rough March 31st, nesting surveys were conducted every other day along South Hutchinson Island in areas A-S. Six leatherback sea turtle nests were recorded in Zones A-S prior to the beginning of formal nesting surveys on April 1st. From April 1st through October 1st, 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. Nest success was lower across all zones, due to an increase in the number of false crawls. The increase was associated with below average conditions rainfall during the peak of nesting season (June - August) that created difficult conditions (dry sand) for turtles to dig their nests. 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.

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Nest success in the zone that includes the power plant (Zone 0) was similar to the nesting success in the surrounding zones (Figure 7).

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 10,000 loggerhead nests have been deposited annually on South Hutchinson Island during the last thirty years.

In 2016, a record high 9,892 loggerhead nests were recorded on South Hutchison Island (Figure 4). In Zones A-S (the north end of the island) biologists observed 4,425

nests (Figure 8). The first recorded nest was on April 21st and the last loggerhead nest was recorded on September 1st. There were 7,298 loggerhead false crawls observed in Zones A-S.

One-hundred and seven of the 4,425 loggerhead nests were marked to assess nest productivity. Sixty-eight nests were successfully inventoried, 13 were completely predated, 17 completely washed out, six had their marking stakes removed/vandalized preventing the clutch from being located and three were predated after the first emergence. The 68 inventoried nests contained a cumulative total of 6,853 eggs. Of these, 1,905 successfully hatched and emerged from the marked nests. This represents an emergence success rate of 27.8%. Low emergence success was observed at other beaches across the state and linked to extremely high temperatures disrupting egg development. There were 67 live loggerhead hatchlings found during nest excavations.

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

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.

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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 2016, 219 green. turtle nests were recorded on South Hutchison Island (Figure 5).

Biologists observed a total of 101 green turtle nests in Zones A-S (Figure 8). The first recorded nest of the season was on June 5th and the last green turtle nest was noted on September 29th. There were 139 green turtle false crawls observed in Zones A-S.

Fourteen of the 101 green turtle nests were marked to assess nest productivity. Three nests were completely predated, one was completely washed out, and one could not be safely inventoried because a fire ant mound was built within the nest. Nine nests were successfully inventoried and contained a cumulative total of 1,082 eggs. Of these, 712 successfully hatched and emerged from the marked nests. This represents an emergence success rate of 65.8%. In addition, there were 23 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 2016, 232 leatherback turtle nests were recorded on South Hutchison Island (Figure 6). Biologists observed a total of 72 leatherback sea turtle nests in Zones A-S (Figure 8). The first recorded nest was on March 5th and the last leatherback sea turtle nest was recorded on July gth. There were 9 leatherback sea turtle false crawls observed in the surveyed areas A-S.

Fourteen of the 72 leatherback turtle nests were marked to assess nest productivity.

Twelve nests were successfully inventoried and two nests washed out. The 12 nests contained a cumulative total of 919 eggs. Of these, 471 successfully hatched and 10

emerged from the marked nests. This represents an emergence success rate of 51.3%.

There was one live leatherback turtle found during nest excavations. This hatchling was 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 depreciated by ghost crabs (Ocypode quadrata) since nesting surveys began, quantification of ghost crab predation did not begin until 1983. Occasionally, sea turtle nests are depreciated 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 366 predation events for South Hutchinson Island in 2016 within beach Sections D-S (Figure 9). Sea turtle nests on South Hutchinson Island were depreciated by ghost crabs, raccoons, birds, and fire ants. The most abundant predators were ghost crabs, which accounted for 148 individual predation events.

Raccoons were the second most abundant predator accounting for 87 events. Another 124 predation events consisted of a combination of raccoon and ghost crab predation.

Other predators (fire ants, domestic dogs or birds for example) accounted for eight 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 31.5%

of nests (28 out of 89) where hatch success could be evaluated. Fourteen marked nests were completely predated prior to inventory.

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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 A 1A 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 A1A. These turtles were further constrained downstream by an underwater intrusion detection system (UIDS) consisting, in part, of a large barrier positio*ned 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 A 1A 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 A1A 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 A1A (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 A 1A 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).

Underwater Engineering Services, Inc. (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 was completed 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 tim~s 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 2016 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 2016, a total of 486 sea turtles were removed from the intake canal, including 316 loggerheads, 159 green turtles, six Kemp's ridley turtles, four hawksbills, and one leatherbacks (Figures 10 and 11; Table 1). The majority of these turtles (92.8%) were captured alive and released back to the ocean. Twenty six (5.3%) were taken to rehabilitation facilities for treatment of injuries or disease and 9 (1.9%) turtles were found dead. One loggerhead turtle was taken to rehab facilities with injuries causal to power plant operations. The loggerhead was dead upon arrival at rehabilitation and was reported as a causal mortality. Mortalities and injuries are discussed in Section 3.2.6.

In 2016, no turtles were captured west of the primary barrier net in the intake wells. All 486 turtles entrained in the canal were captured east of the primary barrier net - 345 by tangle nets, 17 off of the primary barrier net, 27 by dip net, and 97 by hand capture.

Proactive captures (hand capture and dip net) accounted for 25.6% 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 2016, Unit 1 was in an outage from August 1st to the 28th and Unit 2 was in an outage from September 26th to November 9th. Unit 1 also underwent a forced outage from October 5th until the 13th due to Hurricane Matthew.

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 2016, monthly captures of loggerheads ranged from 9 in November to 42 in February (Table 2), with a monthly mean of 26.3. Loggerhead capture rates have exhibited considerable year-to-year fluctuation, but have shown an overall increasing trend since the plant started operation (Figure 1O; 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 316 loggerheads captured where standard straight carapace length (SSCL) .is available, 170 were juveniles (SSCL ~ 70 cm), 57 were adults (SSCL ~ 85 cm), and 89 were transitional (SSCL 70-85 cm; Hirth, 1980, Figure 12). The latter group probably includes both mature and immature individuals. Of the 57 turtles classified as adults, 54 were females and 3 were males. Five 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.

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 1O; 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 2016, monthly green turtle captures ranged from three in May and August to 36 in January and February (Table 2) with a monthly mean of 13.2. Of the 159 green turtles captured in 2016, there were 154 juveniles or sub-adults (SSCL < 83cm), three adult males, 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 2016, there were six Kemp's ridley turtles, four hawksbills, and one leatherback captured in the intake canal of the St. Lucie Plant (Table 1). The Kemp's ridley sea turtles ranged in SSCL from 48.1 cm to 57.5 cm. The hawksbill sea turtles ranged in

SSCL from 51.3 cm to 68.4 cm. The leatherback was captured March 19th and had a SSCL of 150.0 cm.

3.2.4 Smalltooth Sawfish Captures The most recent BO issued by the NMFS states that no more than one smalltooth sawfish may be captured every five years and none may be killed. No smalltooth sawfish were encountered in 2016.

3.2.5 Recaptures Since plant operation began in 1976, a total of 16,949 sea turtles (including recaptures) have been captured, including 9,795 loggerhead, 6,975 green, 68 hawksbill, 69 Kemp's ridley, and 42 leatherback turtles (Table 1).

16

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, 3,069 recapture_events (720 loggerheads and 2,349 green turtles) have* occurred. The recapture rate in 2016 was 5.4% for loggerheads and 29.6% for greens. Occasionally, turtles are captured that have been tagged by other researchers.

There were five such captures in 2016. One loggerhead was originally found stranded in Pompano Beach, Florida and rehabbed at the Miami Seaquarium. It was released in Miami-Dade County earlier in 2016. A second loggerhead was originally tagged by the University of Central Florida in the Indian River lagoon in 2003 and then documented again in 2006. A green turtle was originally found cold-stunned in Cape Cod, Massachusetts and was released on Little Talbot Island, Florida in 2014. A hawksbill was originally tagged by the Florida Hawksbill Project on the Palm Beach County reef tract in 2005. A Kemp's ridleywas originally found stranded in a pound net in Hyde County, North Carolina and rehabbed at the Topsail Turtle Hospital in 2009. The turtle was released from rehabilitation in 2010.

3.2.6 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 2016, of the 316 loggerheads captured, 89.3% (282) were alive and in good condition. Only 10.4% (33) of all loggerheads were individuals in fair or poor condition and 0.3% (one) was recorded as a mortality. The one loggerhead that was recorded as a mortality in 2016 died while in transit to rehab. Of the 159 green turtles removed from the intake canal 87.5% (139) were in good condition, 7.5% (12) were in fair or poor condition and 5.0% (eight) were found dead.

17

Of the 486 turtles removed from the intake canal during the year, 419 (86.2%) 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 (89.5%) of the scrapes were classified as minor. However, some of the scrapes (10.5%)

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

3.2.7 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 and mortalities 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 7.9% during the period 1976-1984 to 1.3% for the period 1985 to present (Table 1). Over the entire monitoring program's history (1976-2016),

180 (1.8%; including hatchlings from 2006) loggerheads and 115 (1.6%) 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. The only hawksbill mortality was recorded in 2014. There have been no leatherback mortalities in the history of the project.

In 2016, eight green turtle mortalities were recorded at the St. Lucie power plant intake canal. None of these mortalities were considered causal to power plant operations.

There was one loggerhead classified as a causal mortality (shown below).

On October 9th, a live adult female loggerhead was hand captured immediately after entrainment into the intake canal that was extremely lethargic. It had apparent old boat strike injuries consisting of a partially healed wound on the left side of the head and an old impact wound/crack in the posterior carapace. The turtle was also missing 90% of the left front flipper and 50% of the right front flipper (both partially healed). The turtle later died en route to rehabilitation and was subsequently transferred to FWC so that a necropsy could be performed. Originally designated as a live non-causal injury, this 18

turtle was determined to have drowned. According to the necropsy, the cause of death was forced submergence and the status was changed to a causal mortality.

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. It stated that FPL would 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.

19

-- ------- -----------------------------~

In 2006, FPL exceed their sea turtle take limit at the St. Lucie Power Plant and reinitiating a Section 7 consultation was required. FPL identified the contributing factors that led to exceeding the take limit in 2006 and the company 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 almost all reproductively active sea turtles from being entrained into the power plant's intake canal.

The St. Lucie Power Plant continued to operate under the 2006 BO until NMFS issued a new BO in March 2016. The most significant change in the new BO is to the Incidental Take Statement. It states that FPL would exceed its take limit if: 1) more than 623 loggerheads, 500 green turtle, 7 hawksbills, 8 Kemp's ridleys, or 5 leatherbacks are captured annually, 2) more than 7 green turtles or 3 loggerheads are documented with severe causal injuries annually, 3) more than 5 green turtles or 3 loggerhead are documented as causal mortalities annually, 4) more than 1 hawksbill, Kemp's ridley, or leatherback are documented with either a severe causal injury or is a causal mortality every two years, 5) more than one smalltooth sawfish is captured every five years or any smalltooth sawfish are ever killed.

During 2016, there were 316 loggerheads, 159 green turtles, six Kemp's ridleys, four hawksbills, and one leatherback captured during 2016. There was one loggerhead mortality that was causal to power plant operations. No leatherback, hawksbill or Kemp's ridley turtles were injured or killed due plant operation. Furthermore, no smalltooth sawfish were captured. Based on the latest BO issued by NMFS, FPL did not exceed its take limit during 2016.

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.

Se~ 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 20

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 2016 During 2016, IRG biologists responded to 23 (six loggerhead, 16 green, and one Kemp's ridley species) stranding events in St. Lucie County. Eight live turtles were transported to rehabilitation facilities. The 15 dead turtles were found in various stages of decomposition. The probable cause of stranding included two boat strikes, three in an emaciated body condition, one fishing line/trap entanglement, one nesting adult stuck behind the dune, one turtle stuck behind an oil boom, and one washback post-hatchling.

The remaining 14 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.

FPL conducted 12 turtle walks between June 1oth and July 16th, 2016. During these programs, a total of 332 people attended and on 10 of the 12 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 four research projects in 2016.

IRG biologists collected blood samples from juvenile green turtles for analysis of health parameters by the University of Georgia and the Georgia Sea Turtle Center. Unhatched eggs from loggerhead nests were also collected for stable isotope analysis conducted by Florida Fish and Wildlife Research Institute (FWRI). Measurements of hatchlings I

orientation direction were also collected for a separate study by FWRI. IRG biologists also collaborated with Southeastern Louisiana State University to collect blood to examine stress levels in adult female loggerheads.

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 UESI. In addition to scheduled inspections and cleaning of the nets, divers are deployed when the integrity of the nets 21

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 2016, there were no net failures. No turtles were spotted west of the 5" net or

. subsequently captured in the intake wells. Routine inspections of the temporary primary barrier net and the A1A net were completed quarterly. During these inspections, debris was removed from both nets. No holes were found during the quarterly inspections in the primary barrier or A 1A barrier nets.

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 prompt~d 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 Refe~ences .

Applied Biology, Inc. (1978). Ecological Monitoring at the Florida Power & Light Company, St. Lucie Plant, Annual Report 1977, Volumes I and II (AB-101).

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

Applied Biology, Inc. (1980). Florida Power & Light Company, St. Lucie Plant Annual Non-radiological Environmental Monitoring Report 1979, Volumes II and Ill, Biotic Monitoring (AB-244). Prepared by Applied Biology, Inc. for Florida Power & Light Company, Miami.

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

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

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

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

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

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

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

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

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

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

23

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

Bresette, M., Gorham, J., & Peery, B. (1998). Site fidelity and size frequencies of

juvenile green turtles (Che/onia mydas) utilizing nearshore 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 biological data on the loggerhead sea turtle Caretta caretta (Linnaeus1758). U.S. Fish and Wildlife Service Biological Report 88(14).

Ecological Associates, Inc. (2000). Physical and Ecological Factors Influencing Sea Turtle Entrainment Levels at the St. Lucie Power Plant 1976-1998. ,Submitted to FPL.

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. Journal of 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, Am_erican Zoologist, 20, 507-523.

lnwater Research Group, Inc. (2010). Florida Power & Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2009. Prepared by lnwater Research Group, Inc. for Florida Power & Light Company, Juno Beach, FL.

lnwater Research Group, Inc. (2011 ). Florida Power & Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2010. Prepared by lnwater Research Group, Inc. for Florida Power & Light Company, Juno Beach, FL.

lnwater Research Group, Inc. (2012). Florida Power & Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2011. Prepared by lnwater Research Group, Inc. for Florida Power & Light Company, Juno Beach, FL.

lnwater Research Group, Inc. (2013). Florida Power & Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2012. Prepared by lnwater Research Group, Inc. for Florida Power & Light Company, Juno Beach, FL.

lnwater Research Group, Inc. (2014). Florida Power & Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2013. Prepared by lnwater Research Group, Inc. for Florida Power & Light Company, Juno Beach, FL.

lnwater Research Group, Inc. (2015). Florida Power & Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2014. Prepared by lnwater Research Group, Inc. for Florida Power & Light Company, Juno Beach, FL.

24

lnwater Research Group, Inc. (2015). Florida Power & Light Company, St. Lucie Unit 2 Annual Environmental Operating Report 2015. Prepared by lnwater Research Group, Inc. for Florida Power & Light Company, Juno Beach, FL.

Meylan, A.B., Schroeder, B. & Mosier, A. (1995), Sea turtle nesting activity in the state of Florida, 1979-1992. Florida Marine Research Publications, 52, 1-51.

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

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

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

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

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

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

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

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

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

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

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

25

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

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

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

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

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

Schroeder, B.A. & Thompson, N.B. (1987). Distribution of the loggerhead turtle (Caretta caretta) and leatherback turtle (Oermochelys coriacea) in the Cape Canaveral, Florida area; results from aerial surveys (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. Ecological Applications, 21(1), 263-273.

Turtle Expert Working Group. (2000). Assessment update for the Kemp's ridley and loggerhead sea 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.),

Proceeding of the Second Western Atlantic Turtle Symposium, Mayaguez, Puerto Rico, 12-16October1987 (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.

26

6.0 Figures and Tables FLORIDA GULF OF MEXICO

~

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

27

HUTCHINSON ISLAND INDIAN RIVER OISCHAnOE l'll'E~

ATLANTIC OCEAN INDIAN RIVER r'

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

28

-N-

~

I FPL

/.ff..-\lf~;.,__- ST. LUCIE PLANT p

a:)

R

~LIMITOF CURRENT s SURVEY DRAWING NOT TO SCALE Figure 3. Designation and location of nine 1.25 km segments (in brackets) and 36 one km segments surveyed for sea turtle nesting on South Hutchinson Island (1971-2016).

29

11,000 10,000 9,000 8,000 7,000

~

QI z 6,000 5,000 4,000

+ +

+

3,000

+

2,000 U)

~

U)

'en""

..... 'en""

co 'enen"" en en '""

0 0

0 0 0"""" 0 N N N N

'"" '"" '"" Year '""

Figure 4. Number of loggerhead turtle nests on South Hutchinson Island from 1971 through 2016. Values for 1971 through 1979 are estimates (Section 2.1.1 ); values for 1981 through 2016 are from whole island surveys.

30

1,000 900 800 700 600

~

CIJ 500 z

400 300 200 100 0

""'en

- \£)

"""en ""'coen

\£)

co en ""'enen

\£)

en en ""'00 N

U) 0 0

N ""'N""'0 w

""'0 N

""' ""' ""' ""' ""' Year Figure 5. Number of green turtle nests on South Hutchinson Island from 1971 through 2016. Values for 1971 through 1979 are estimates (Section 2.1.1 ); values for 1981 through 2016 are from whole island surveys.

31

600 500 400 200 100

~ U) ~

0 0 ~ ~

0 0 0 0 N N N N Year Figure 6. Number of leatherback turtle nests on South Hutchinson Island from 1971 through 2016. Values for 1971 through 1979 are estimates (Section 2.1.1 ); values for 1981 through 2016 are from whole island surveys.

32

100%

Loggerhead D Green J 75%

25%

0%

A B c D E F G H J K L M N 0 p Q R s Zone 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 2016 nesting season.

33

700

Loggerhead D Leatherback D Green 600 500 400 300 200 100 0

A B c D E F G H J K L M N 0 p Q R s Zone t

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 2016 nesting season (N=4 ,599 nests).

34

40%

% Raccoons Only 35% D % Crabs Only D % Raccoons and Crabs

%Other 30%

c 25%

.2

~

"C GI

i... 20%

c..

"'GI z 15%

10%

5%

0%

A B c D E F G H J K L M N 0 p Q R s Zones t Power Plant Figure 9. Percentage of sea turtle nests depreciated by 1 km Zones A through S (North to South) on South Hutchinson Island for the 2016 nesting season .

35

1000 -

- DGreen *Loggerhead 900 -

I I - - ~r----

800 700 Ill 600 -

GI

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'l"'I 'l"'I 'l"'I 'l"'I 'l"'I 'l"'I 'l"'I 'l"'I 'l"'I N N N N N N 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 2016.

36

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0 N N N N N N N N N 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 2016.

37

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Figure 12. Size distribution (Straight Standard Carapace Length; SSCL) of loggerhead turtles (N=316) captured and removed from the intake canal at the St. Lucie Power Plant during 2016.

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Figure 13. Size distribution (Straight Standard Carapace Length; SSCL) of green turtles (N=158) captured and removed from the intake canal at the St. Lucie Power Plant during 2016.

39

Year Leatherback Hawksbill Kemp's ridley Total 1976-1984 156 7 2 3 1130 1985 157 14 1 172 1986 195 22 1 1 1 220 1987 175 35 2 6 218 1988 134 42 5 181 1989 111 17 1 2 2 133 1990 112 20 132 1991 107 12 1 1 121 1992 123 61 1 2 187 1993 147 179 5 2 4 337 1994 164 193 2 2 361 1995 254 673 1 5 933 1996 349 549 5 3 906 1997 188 191 2 1 382 1998 393 268 1 2 2 666 1999 302 190 1 1 1 495 2000 344 345 2 691 2001 270 321 2 6 1 600 2002 341 292 3 636 2003 538 394 4 6 2 944 2004 623 286 2 2 1 914 2005 484 428 2 3 917 2006 419 267 1 2 3 692 2007 227 101 1 1 330 2008 420 299 4 2 725 2009 260 161 1 2 424 2010 295 2 444 2 3 7 751 2011 302 ru 217 2 521 2012 232 r' 1 127 2 1 362 2013 302 . ~* 197 2 2 503 2014 275 ii! 134 3 2 414 2015 274 !I! 181 2 1 7 465 2016 . 316 159 1 4 6

' 486 Total 9795 6975 42 68 69 16949 Mean* 250.5 178.8 1.1 1.7 1.8 433.9 Table 1. Total number of captured turtles removed from the intake canal at the St. Lucie Power Plant from 1976 through 2016. 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 2016 Total of 2016 Total of Months Captures Captures Captures Mean Captures Captures Captures Mean January 29 905 9.3% 23.2 36 873 12.5% 22.4 February 42 877 9.0% 22.5 36 747 10.7% 19.2 March 27 1031 10.6% 26.4 19 821 11.8% 21.1 April 39 959 9.8% 24.6 12 496 7.1%. 12.7 May 21 886 9.1% 22.7 3 472 6.8% 12.1 June 34 1052 10.8% 27.0 8 418 6.0% 10.7 July 41 1270 13.0% 32.6 4 404 5.8% 10.4 August 23 842 8.6% 21.6 3 396 5.7% 10.2 September 27 589 6.0% 15.1 9 521 7.5% 13.4 October 14 495 5.1% 12.7 16 662 9.5% :).7.0 November 9 376 3.8% 9.6 9 573 8.2% 14.7 December 10 487 5.0% 12.5 4 592 8.5% 15.2 Total 316 9769 242.4 159 6975 178.8 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 2016. Monthly totals exclude the partial year 1976 when 26 loggerheads were captured.

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Leatherback Hawks bill Kemp's ridley Percent Percent Percent 2016 Total of 2016 Total of 2016 Total of Months Captures Captures Captures Mean Captures Captures Captures Mean Captures Captures Captures Mean January 0 5 11.9% 0.1 0 1 1.5% 0.0 0 11 15.9% 0.3 February 1 5 11.9% 0.1 1 2 2.9% 0.1 4 19 27.5% 0.5 March 0 13 31.0% 0.3 0 8 11.8% 0.2 1 16 23.2% 0.4 April 0 7 16.7% 0.2 0 3 4.4% 0.1 1 12 17.4% 0.3 May 0 5 11.9% 0.1 0 3 4.4% 0.1 0 2 2.9% 0.1 June 0 2 4.8% 0.1 0 2 2.9% 0.1 0 2 2.9% 0.1 July 0 0 0.0% 0.0 1 14 20.6% 0.4 0 2 2.9% 0.1 August 0 1 2.4% 0.0 1 10 14.7% 0.3 0 0 0.0% 0.0 September 0 2 4.8% 0.1 0 12 17.6% 0.3 0 0 0.0% 0.0 October 0 0 0.0% 0.0 1 6 8.8% 0.2 0 1 1.4% 0.0 November 0 1 2.4% 0.0 0 6 8.8% 0.2 0 1 1.4% 0.0 December 0 1 2.4% 0.0 0 1 1.5% 0.0 0 3 4.3% 0.1 Total 1 42 1.1 4 68 1.7 6 69 1.8 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 2016. 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 1,800 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 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 43

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 CTCS ball loss. The results of the program for 2015 are presented in Table 1.

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 On May 20, 2016, St. Lucie submitted to the NRC a letter of Noncompliance for a violation of the St. Lucie NPDES Permit. Two chemicals were discharged from the plant that was not on the approved chemical discharge list; Sodium Bi-Sulphate, Vitec 5100, and Vitec 3000 (proprietary). Discharge of these chemicals was halted until such time that a minor revision to the site's NPDES Permit was obtained. Notification to the NRC occurred via FPL letter L-2016-125.

5.4.2(b) Changes in Station Design or Operation, Tests, and Experiments in Accordance with EPP Subsection 3.1 The waste water treatment process was augmented to add two additional discharge chemicals to the Industrial Wastewater Permit.

5.4.1.2(c) Non-routine reports were submitted to the NRC for the year 2016 in accordance with EPP Subsection 5.4.2.

44

On December 12, 2015, a deceased juvenile green sea turtle (Chelonian mydas) was removed from the plant's intake canal. Notification of the mortality to the NRC occurred via FPL Letter L-2016-001.

On March 29, 2016, St. Lucie submitted to the NRC a copy of a request for renewal of the plant's Industrial Wastewater Permit. Notification to the NRC occurred via FPL letter L-2016-069.

On April 27, 2016, St. Lucie submitted to the NRC a copy of the 2015 Annual Environmental Operating Report. The report was submitted via FPL letter L-2016-095.

bn April 29, 2016, St. Lucie submitted to the NRC a License Amendment Request to update Appendix B of the Technical Specifications to incorporate the changes to the 2016 Biological Opinion. Notification to the NRC occurred via FPL letter L-2016-072 On May 20, 2016, St. Lucie submitted to the NRC a notification of a NPDES permit Noncompliance. Notification to the NRC occurred via FPL letter L-2016-121.

On June 15, 2016, St. Lucie submitted to the NRC a request for a Minor Permit Revision to the plant's Industrial Wastewater Permit for the addition of two additional chemicals for the approved chemical discharge list. Notification to the NRC occurred via FPL letter L-2016-125.

On October 9, 2016, a female loggerhead sea turtle (Caretta caretta) was recovered in the plant's intake canal. Notification of the mortality to the NRC occurred via FPL letter L-2016-191.

On January 24, 2017, St. Lucie submitted to the NRC a copy of new approved Industrial Wastewater permit that St. Lucie received the previous November. Notification to the NRC occurred via FPL letter L-2017-012.

45

7.5 Figures and Table Table 1 PSL CTCS Ball Loss 2016 Summary lAl 1A2 lBl 1B2 PSL 1 ALL

B/W LOST #B/W LOST #B/W LOST #B/W LOST #B/W LOST COMMENTS Jan-15 4 10 2 24 3 176 3 62 12 272 Feb-15 4 0 3 84 2 75 3 3 12 162 Mar-15 3 653 1 0 4 555 4 559 12 1767 Apr-15 2 201 2 970 2 30 2 0 8 1201 May-15 10 658 4 650 7 705 6 24 27 2037 Jun-15 3 0 2 14 0 0 1 3 6 17 Jul-15 5 638 4 650 4 117 4 642 17 2047 Aug-15 1 58 2 85 0 0 0 0 3 143 Sep-15 0 0 0 0 0 0 0 0 0 0 Oct-15 0 0 0 0 0 0 0 0 0 0 Nov-15 1 0 0 0 2 75 2 63 5 138 Dec-15 1 91 1 129 1 57 1 57 4 334 Summary 34 2309 21 2606 25 1790 26 1413 106 8118 2A1 2A2 2B1 2B2 PSL 2 ALL

B/W LOST #B/W LOST #B/W LOST #B/W LOST #B/W LOST COMMENTS Jan-15 2 0 0 0 3 21 3 159 8 180 Feb-15 2 71 1 0 3 65 3 27 9 163 Mar-15 6 605 4 5 4 38 3 0 17 648 Apr-15 1 12 2 23 1 3 1 1 5 39 May-15 7 9 8 14 7 31 6 30 28 84 Jun-15 1 21 1 53 3 14 3 23 8 111 Jul-15 5 79 3 24 3 12 3 8 14 123 Aug-15 0 0 1 36 2 34 2 0 5 75 Sep-15 2 0 1 0 1 0 1 0 5 0 Oct-15 4 220 3 44 1 35 1 41 9 340 Nov-15 1 5 2 119 3 84 4 24 10 232 Dec-15 2 5 2 33 1 25 1 35 6 98 Summary 33 1027 28 351 32 362 31 348 124 2088 46

L-2017-078, Annual Environmental Operating Report, 2016

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