L-2018-086, Subsequent License Renewal Application Appendix E Environmental Report Supplemental Information

Subsequent License Renewal Application Appendix E Environmental Report Supplemental Information

ML18102A521
Person / Time
Site:	Turkey Point
Issue date:	04/10/2018
From:	Maher W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-086
Download: ML18102A521 (35)

Text

FPL..

April 10, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re: Florida Power & Light Company Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2018-086 10 CFR 54.17 Turkey Point Units 3 and 4 Subsequent License Renewal Application Appendix E Environmental Report Supplemental Information

Reference:

1. FPL Letter L-2018-004 to NRC dated January 30, 2018, Turkey Point Units 3 and 4 Subsequent License Renewal Application Florida Power & Light Company (FPL) submitted a subsequent license renewal application (SLRA) for Turkey Point Units 3 and 4 to the NRC on January 30, 2018 (Reference 1 ). FPL provides, as attachments to this letter, supplemental information for the SLRA Environmental Report provided in the Reference 1 letter.

If you have any questions, or need additional information, please contact me at 561-691-2294.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 10, 2018.

Sincerely, William Maher Senior Licensing Director Florida Power & Light Company WDM/RFO Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408

L Turkey Point Units 3 and 4 Docket Nos.52-040 and 52-041 L-2018-086 Page 2 of 2 : SLRA Appendix E Section 4.5.3.4 Supplemental Information : Technical Memorandum - Evaluation of Drawdown in the Upper Floridan Aquifer Due to Proposed Salinity Reduction-based Withdrawals (November 13, 2014) : SLRA Appendix E Section 4.6.6.4 Supplemental Information cc w/

Enclosure:

Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Nuclear Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant Project Manager, USNRC, SLRA Plant Project Manager, USNRC, SLRA Environmental Ms. Cindy Becker, Florida Department of Health

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Page 1 of 5 SLRA Appendix E - Applicant's Environmental Report Subsequent Operating License Renewal Stage SLRA Appendix E Section 4.5.3.4: Groundwater Use Conflicts (Plants that Withdraw more than 100 GPM) Analysis SUPPLEMENTAL INFORMATON:

Introduction The following information supplements and supports the discussion provided in section 4.5.3.4 of FPL's Environmental Report, with specific consideration of the evaluation of the groundwater use impacts performed as part of the state and local regulatory process.

Water use at Turkey Point Nuclear Units 3 & 4 (PTN) is conducted in accordance with Chapter 373, F.S. which enables and directs the South Florida Water Management District (SFWMD) to regulate the use of water within its jurisdictional boundaries. The purpose of the water use regulatory program is to ensure the water use is reasonably beneficial, will not interfere with any presently existing legal uses of water, and is consistent with the public interest. During the permitting process, the impacts of the water use on existing land uses, pre-existing water rights, and the environment are fully evaluated by the applicant and subject to public review and challenge prior to water rights being granted. Florida Power & Light Company (FPL) has demonstrated it meets the requirements of Chapter 373, F.S. and provided the following information to the regulatory agencies during the permitting process, resulting in regulatory approvals.

Floridan Aquifer The 2005 Site Certification authorized Upper Floridan Aquifer water use for cooling and process water for Unit 5. In 2014, FPL pursued a modification to the Site Certification, requesting an additional 14 million gallons per day (MGD) of Upper Floridan Aquifer water for cooling canal system (CCS) salinity reduction and to re-allocate Upper Floridan Aquifer water from the existing Unit 5 wells for process water for Units 3 & 4. The 2014 Site Certification modification was granted and authorizes an average daily withdrawal of 28.06 MGD from the upper production zones of the Floridan Aquifer (FDEP, 2016a). This allocation is further divided as follows: 14.06 MGD for cooling water for Unit 5 and process water for Units 1, 2, 3, 4, & 5 and 14 MGD for salinity reduction in the CCS (FDEP, 2016a). The discussion that follows pertains to the evaluation conducted as part of the 2014 Site Certification modification which requests water use allocation in support of Unit 3 & 4 operations (FDEP, 2016a). is a technical evaluation conducted by FPL in support of the proposed use of the Upper Floridan Aquifer conducted as part of the 2014 Site Certification modification

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Page 2 of 5 which proposed 14 MGD to reduce salinity in the CCS. The evaluation conducted used the ECFAS2 model, developed for the SFWMD, and which meets the minimum requirements of the SFWMD Basis of Review (BOR) for water use permitting. This model was subsequently adapted to site-specific conditions and re-calibrated using two Aquifer Performance Tests (APTs) performed at PTN. The resulting regional calibrated groundwater flow model assesses drawdown at nearby existing Upper Floridan Aquifer water users.

The proposed pumping of 14 MGD was projected to result in a maximum Upper Floridan Aquifer drawdown of 14.4 to 15.1 feet at PTN. The extent of drawdown, as defined by the 1 foot drawdown contour, encompasses five existing legal users: Card Sound Golf Club, Ocean Reef Club, the Floridan Keys Aqueduct Authority, Miami-Dade Water and Sewage Department South Miami Heights wellfield, and FPL Unit 5 wells (Enclosure 1 - Figure 8). The maximum drawdown due to the proposed salinity reduction wells experienced by the nearest (non-FPL) user is 2.26 feet and occurs at the South Miami Heights wellfield, located approximately 10.3 miles away. The drawdown comprises approximately 4.6% of the cumulative drawdown simulated at this site. The drawdown contribution by the proposed salinity reduction wells is a conservative estimate (greater than would actually be experienced), since the drawdown in the wellbore at each nearby user due to localized pumping is under-simulated by the model (Enclosure 1 )..

The model evaluated the cumulative drawdown solely due to the permitted pumping by existing legal Floridan Aquifer users (i.e. no pumping simulated at the proposed salinity reduction wells) and compared that to a cumulative drawdown scenario that includes the proposed salinity wells. The results of the comparison show there is no significant difference between the two scenarios. This demonstrates the proposed pumping of the Upper Floridan Aquifer water by the salinity reduction wells will not significantly exacerbate drawdowns in the Aquifer beyond those induced by existing permitted pumping (Enclosure 1 ).

In addition to a demonstration of minimal drawdown induced at wells of permitted users within the 1-foot drawdown contour, the SFWMD BOR water use permitting also stipulates that the proposed pumping not impact the saltwater interface, as defined by the 250 mg/L isochlor. As the quality of Upper Floridan Aquifer water in the area already exceeds such a concentration, and no saltwater interface exists, this stipulation does not apply. Moreover, the operation of the salinity reduction well is not expected to impact Upper Floridan Aquifer water quality in a regional sense. This conclusion is supported by the SFWMD which found that local changes in water quality are expected to be minor, as demonstrated for other Upper Floridan Aquifer water use in the region (Enclosure 1 ).

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Page 3 of 5 Biscayne Aquifer Pursuant to Florida Department of Environmental Protection's (FDEP) Consent Order (FDEP, 2016b) and the Consent Agreement by Miami-Dade County (MDC) Department of Environmental Resource Management (DERM) (MDC, 2015), FPL is required to capture hypersaline water in the Biscayne Aquifer using a Recovery Well System (RWS). The RWS will extract 15 MGD from 10 wells (each withdrawing 1.5 MGD) for a predicted 10 year period beginning in 2018. The authorized extraction rates result in a maximum monthly withdrawal of 465 million gallons and an annual extraction of 5,475 million gallons from the Biscayne Aquifer. These allocations are based on FDEP and MDC DERM approved groundwater remediation plans, associated modeling, and regulatory review process which resulted in issuance of SFWMD permit number 13-06251 -W. The discussion below includes a summary of the evaluation conducted by FPL in support of the proposed use of the Biscayne Aquifer titled, "Florida Power &

Light Company Turkey Point Groundwater Remediation Water Use Permit Supplemental Information" (SFWMD, 2016). Also discussed below are the conclusions reached by the SFWMD in a staff report issued as part of the final water use permit 13-06251-W (SFWMD, 2016).

A transient variable density groundwater flow and transport model of the Biscayne Aquifer was developed by FPL and approved by multiple state and county agencies.

The model was executed using the latest version of the SEAWAT code (Version 4 ).

Data used for the model development and calibration were derived from historic records, United States Geological Survey (USGS) reports, FPL records, and two APTs conducted at PTN along with more intensive data collected under the Turkey Point Monitoring Plan (2010 through 2015) (SFWMD, 2016a). The model domain covers an area of approximately 276 square miles and consists of 11 layers. The model was used to assess the impacts of the proposed RWS on water availability, wetlands and other surface water bodies, pollution of water resources, existing offsite land uses, and the interference with existing legal users.

The land surface elevation in the vicinity of the RWS is approximately 3.5-feet National Geodetic Vertical Datum (NGVD 29). The base of the Biscayne Aquifer occurs around

-1 DO-feet NGVD 29 in the vicinity of the extraction wells. Based on water level data obtained from USGS monitor well G-3356, the closest well with a substantial data record, located approximately 4.5-miles west of the RWS, the lowest recorded water level elevation in the Biscayne Aquifer is 0.34-feet NGVD 29. The results of the RWS groundwater modeling predicted a maximum drawdown of 0.5-feet, leaving a saturated thickness in the Biscayne Aquifer of over 99-feet. Therefore, the SFWMD concluded the potential for harm to occur to the water resource availability of the Biscayne Aquifer as a result of the withdrawal of the recommended allocation is considered minimal (SFWMD, 2016b).

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Page 4 of 5 There are no existing legal users of the Biscayne Aquifer within the predicted 0.1-foot drawdown contour resulting from the RWS proposed withdrawals. Therefore, the SFWMD concluded the potential for harm to occur to existing legal users as a result of the withdrawal is considered minimal. The cone of depression resulting from the FPL RWS encompasses lands owned mainly by FPL along with numerous small privately owned parcels and several Miami-Dade County Environmentally Endangered Land holdings (SFWMD, 2016b - Figure 8). All of these lands are undeveloped, therefore, the SFWMD concluded the use is not expected to result in significant reduction in water levels on the property of an existing offsite land use to the extent that: the designed function of a water body and related surface water management improvements are damaged (not including aesthetic values); or cause damage to agriculture, including damage resulting from reduction in soil moisture resulting from withdrawal of the recommended allocation, or land collapse or subsidence caused by reduction in water levels associated with the withdrawal of the recommended allocation (SFWMD, 2016b).

The analysis conducted by FPL in accordance with Chapter 373, F.S. supports the conclusion in the Environmental Report that impacts from groundwater withdrawals are small and do not warrant additional mitigation measures.

References:

FDEP, 2016a. Florida Power and Light Company Turkey Point Plant Units 3 - 5 Modification to Conditions of Certification Final Order. January 25, 2016. Accessible at:

'http://publicfiles.dep.state.fl.us/Siting/Outgoing/WebffurkeyPUModifications' after selecting '2016_ 4_ 1_FO_Mod_E_ TP3_5.pdf' (accessed April 7, 2018).

FDEP, 2016b. Consent Order entered into between the State of Florida, Department of Environmental Protection (Department) and Florida Power & Light Company (Respondent) to reach settlement of certain matters at issue between the Department and the Respondent. June 20, 2016. NRC ADAMS Accession No. ML16216A216.

MDC, 2015. Consent Agreement entered into by and between the Miami-Dade County, through its Department of Regulatory and Economic Resources, Division of Environmental Resources Management (DERM), and Florida Power & Light Company (FPL), Pursuant to Section 24-7(1S)(c) of the Code of Miami-Dade County. October 7, 2015. NRC ADAMS Accession No. ML16004A241.

SFWMD, 2016a. Florida Power & Light Company Turkey Point Groundwater Remediation Water Use Permit Supplemental Information. September 12, 2016.

Accessible at: 'http://my.sfwmd.gov/ePermitting/PopulateLOVs.do?flag=1 ' after entering

'13-06251-W' in the 'Permit#:' field, selecting the 'Search Records' button, selecting

'160916-12' in the 'Application#:' field, selecting 'Applications', selecting 'Application Documents', and selecting 'wu app supporting doc 091216 v2' (accessed April 6, 2018).

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Page 5 of 5 SFWMD, 2016b. Florida Power & Light Company Turkey Point Groundwater Recovery Well System Permit. February 27, 2017. Accessible at:

'http://my.sfwmd.gov/ePermitting/PopulateL0Vs.do?flag=1' after entering '13-06251-W' in the 'Permit#:' field, selecting the 'Search Records' button, selecting '160916-12' in the 'Application#:' field, selecting 'Permit & Staff Report Information', selecting 'Permit',

and selecting '160916-12' (accessed April 6, 2018).

ASSOCIATED ENCLOSURES: : Technical Memorandum - Evaluation of Drawdown in the Upper Floridan Aquifer Due to Proposed Salinity Reduction-based Withdrawals (November 13, 2014)

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 1 of 21 Turkey Point Units 3 and 4 SLRA Appendix E Section 4.5.3.4 Supplemental Information Technical Memorandum Evaluation of Drawdown in the Upper Floridan Aquifer Due to Proposed Salinity Reduction-based Withdrawals (November 13, 2014)

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 2 of 21 111: I TETRA TECH From:

To:

Date:

Subject:

TECHNICAL MEMORANDUM Peter F. Andersen and James L. Ross, Tetra Tech Rory Rahming, Florida Power & Light Company November 13, 2014 Evaluation ofDrawdown in the Upper Floridan Aquifer Due to Proposed Salinity Reduction-based Withdrawals 1

INTRODUCTION

1.1 Background

Florida Power & Light Company (FPL) is in the process of applying for a modification to site ce1tification to reflect the proposed reduction of salinity of cooling canal system (CCS) waters at the Turkey Point Power Plant, located near Florida City, Florida. A component of this project is a series of I 000-1200 foot deep wells that will extract low salinity water from the Upper Floridan Aquifer and discharge it into the CCS for the purpose of reducing the salinity of CCS water to levels commensurate with Biscayne Bay. As a step in the site certification process, FPL must demonstrate the feasibility of withdrawing approximately 14 million gallons per day (MGD) of Upper Floridan Aquifer water without adversely impacting the wells of existing legal users of the Floridan Aquifer. This memorandum describes the calibration and simulation of a groundwater flow model of the Floridan Aquifer system that is used to determine potential groundwater level (drawdown) changes resulting from the use of the Florida1l Aquifer as a source of water for CCS salinity reduction.

1.2 Scope The scope of this analysis is to calibrate a regional groundwater flow model of the Upper Floridan Aquifer, as defined from regional hydrogeologic data, including two documented Floridan Aquifer Performance Tests (APTs).

The modeling shall meet the minimum requirements of the South Florida Water Management District (SFWMD) Basis of Review (BOR) for water use permitting.

Once calibrated, the model will be used to evaluate the anticipated drawdown of the Upper Floridan Aquifer potentiometric surface at the plant site and regional settings. The drawdown information will be used to assess the likely impacts to the wells of existing legal users.

1.3 Report Orga11izatio11 Following this introduction, the memorandum provides a summary of the existing regional groundwater model developed by the SFWMD that was modified and re-calibrated. This existing model is referred to as the East Coast Floridan Aquifer System Model - Phase 2 (ECFAS2). The calibration to the two APTs is then discussed, including changes that were made to the ECFAS2 model and the Jesulting quality of calibration. Predictive regional simulations and corresponding resuJts follow.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 3 of 21 2

METHODOLOGY 2.1 Ge11eml The methodology for conducting this study follows standard groundwater modeling protocols.

As outlined in Anderson and Woessner (1992) the steps involved with model application include:

Definition of purpose Conceptual model development Code selection Model design Calibration/ verification Prediction Presentation of results 2.2 Regional Model The primary pmpose of the regional model analysis is to assess potential regional drawdown resulting from pumping water from the Upper Floridan Aquifer as a source of low-salinity water for the CCS. Some of the early steps in the modeling process, most notably conceptual model development, model design, and, to some degree, calibration, were abbreviated in this application because the ECF AS2 model (Golder Associates, 2008) was available to use as the framework for the analysis. The abbreviated relevant steps are summarized in this section. The resulting revised model marks an FPL adaptation to the ECFAS2 model, and is herein referred to as the Adapted Floridan model.

The conceptual model of the natural system is consistent with that described in the existing ECFAS2 model documentation (Golder Associates, 2008).

Additional data to modify the hydraulic parameters are available from site specific data collection and testing. Two APTs performed at the site are documented in JLA Geosciences (2006) and Dames and Moore (1975) and serve to supplement the conceptual model presented in the existing ECF AS2 model documentation (Golder Associates, 2008).

The design of the original model was generally unchanged. However, the modeled domain was truncated in the north such that the longitudinal extent of the revised model is less than that of the original. Additionally, the finite difference grid spacing was modified to account for well locations used in the APTs that are simulated in the model re-calibration. Grid modifications are described in Section 3.2. Additionally, since relative changes in flow conditions (i.e. drawdowns) are the focus of both model calibration and predictions, only the groundwater flow component of the original model is evaluated and employed, herein. Logistically, this decision facilitated efficient model calibration and predictive simulations, as consideration of density-dependent flow and transport resulted in very long run times. The original groundwater flow and transport model was calibrated to regional water levels and saltwater concentrations. To account for site-specific conditions, the model was re-calibrated to two APTs conducted at the site.

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-201 8-086 Attachment 1 Enclosure 1 Page 4 of 21 3

Regional Model Simulations 3.1 ECFAS2 Model The SFWMD, through contractors, developed a density-dependent groundwater flow and saltwater transpott model of the East Coast of Florida in two phases. The first phase, ECF AS I (HydroGeologic, 2006), simulated the southern half of the study area (the Lower East Coast of Florida); the second phase (ECFAS2) expanded the model domain northward to include more of the East Coast of Florida (Golder Associates, 2008). Both phases of the ECFAS model are available from the SFWMD; only the former has been peer-reviewed.

Nevertheless, these models represent the best available framework from which to base a permitting-level analysis of regional Floridan Aquifer impacts resulting from pumping.

The ECFAS2 model encompasses the ECFAS1 region and represents a revision to the earlier work. Consequently, the ECFAS2 model was used as the framework for this analysis. The ECFAS2 model covers the much of the East Coast of Florida, from southern Indian River County to the Florida Keys. This area is discretized into uniform 2400 by 2400 ft cells.

Vertically, the model extends from land surface to the Boulder Zone, a depth of approximately 3000 ft. The vertical section is discretized into 14 layers, with the Upper Floridan Aquifer represented as 2 layers. Boundary conditions are specified to represent flow into and out of the model domain, usually along the perimeter of the study area. Both flow (hydraulic heads) and saltwater transport (TDS concentrations) are simulated and are dependent upon one another (density-dependent flow and transpo1t). Field data from numerous borings were used to establish the strncture of the model layering, which represents the hydrostratigraphic layers. In addition, field data from APTs were used to guide the initial choice of hydraulic parameters that were used in the model calibration. The model was calibrated to both hydraulic heads and concentrations.

Even though the model was calibrated, Golder Associates (2008) found that the model's size resulted in exceptionally long rnn times such that the scope of the calibration had to be reduced from what was originally envisioned.

3.2 Adapted Floridan Model The ECFAS2 model was not usable in its available state because it covers a very large area and does not provide the resolution required to accurately assess site-specific features and impacts.

Several structural modifications were made to the model and are described herein. Modifications to the calibration of the model are discussed in this section. As previously mentioned, only the groundwater flow capabilities of the ECFAS2 model were germane to the analyses of drawdown described herein, as regional changes in water quality at1Tibutable to the proposed wells, as well as the impact of such changes on drawdown, are anticipated to be negligible. Moreover, model mn times were dramatically reduced by eliminating the density-dependence.

Since the Adapted Floridan model simulates groundwater flow and is adapted from the SEA WAT-based ECFAS2 model, the USGS simulation software MODFLOW-2000 (Harbaugh, et al, 2000), a commonly applied groundwater flow model, was used to simulate the regional model. MODFLOW-2000 is capable of addressing the requirements of the SFWMD BOR inasmuch as it:

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 5 of 21 simulates groundwater flow, is capable of addressing multiple hydrostratigraphic layers and subdividing these layers such that drawdown can be computed at multiple levels within each layer, and is in the public domain, peer-reviewed, and widely used.

The most significant structural change to the model was the grid spacing, which was originally set at 2400 ft. For calibration purposes, the grid was refined in the immediate vicinity of the Turkey Point APTs, such that the well spacing for the APTs could be accurately represented and changes in head over small distances resolved. The revised grid spacing in the model for the calibration is shown in Figure la. The minimum grid spacing used in the Adapted Floridan model, near pumping and monitoring wells, is as little as 1.5 ft. The original model grid spacing, shown in Figure lb, was used in subsequent predictive runs because it was adequate for assessment of impacts at the desired scale and was practical from a run-time perspective.

The original model layering was retained because it appeared to be generally appropriate for the level of detail required.

The Jntermediate Confining Unit (ICU), which overlies the Upper Floridan, was represented using a single layer.

The additional pumping wells that were included as a part of the calibration of the Adapted Floridan model also represent modifications to ECF AS2.

The well locations and rates are described in the calibration and model results sections below. The time stepping of the models was also modified to provide adequate resolution for the duration of the APTs and to account for intermittent pumping (Section 3.2.1.1 and 3.2. l.2).

3.2.1 Additional calibration of model Although the ECF AS2 model may represent the regional conditions fairly well, it may not represent site-specific conditions particularly well. This hypothesis was tested by running the model using documented pumping stresses on the system and comparing the modeled response to that which was observed during the test. ln general, as discussed below, the comparison was not good.

In order to obtain a reasonable representation of site-specific conditions, two additional calibrations, one to a short-term APT and another to a longer term APT, were performed. The ability to match aquifer system response to these APTs provides confidence that the model can predict the response to future proposed pumping. Modeled water levels were checked to ensure that the match to regional calibration targets had not been degraded as a result of the local changes.

The methodology and results of each of the additional calibrations are described below.

3.2.1.1 JLA APT JLA Geosciences (2006) conducted an APT in support of the Unit 5 site certification. Floridan water supply well PW-1 was pumped for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and drawdown was measured in two other water supply wells and a shallow observation well. The drawdown response documented during this test was believed to represent a good series of targets to match as a part of a calibration because it was local to the area of proposed pumping and was conducted under qua I ity-controlled conditions.

However, it was recognized that the short duration of the test and extent of monitoring points would provide data that may only be representative of a relatively small area.

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 6 of 21 Simulation of the APT was accomplished using the revised model grid.

Well PW-1 was represented with a single well pumping at a rate of 4500 gpm in model layers 3 and 4, which represent the Upper Floridan Aquifer, in the cell at row 166, column 143 Timestepping ranged from a minimum of 5 to a maximum of 567 minutes, Drawdown response was noted in wells PW-3 (layers 3 and 4, row 168, column 171), PW-4 (layers 3 and 4, row 180, column 157), and OBS-I (layer 2, row 166, column 143) at distances of 3036, 1686, and O feet, respectively from the pumped well. Note that OBS-I is co-located with the pumping well, but is screened near the base of the Biscayne Aquifer and did not experience drawdown in response to the APT.

Comparison of modeled to observed conditions for the original model, prior to adjustment, was not good, with a residual standard deviation of greater than I 00 ft.

However, as shown in Figure 2, this match improved considerably (residual standard deviation of 0.36 ft) after adjustment of hydraulic parameters as a part of the calibration.

In general, hydraulic conductivities were increased from their original values during calibration.

Goodness-of-fit calibration metrics are shown in Table 1 and indicate that the model provides a reasonable fit to observed data.

Table 1. Goodness of fit metrics for the JLA APT calibration.

Metric Numerical Value Mean Error, ft 0.22 Mean Absolute Error, ft 0.33 Residual Standard Deviation, ft 0.36 Range of Targets, ft 6.36 Residual Standard Deviation / Ranae *100 5.6%

Note that this calibration was conducted iteratively with the Dames and Moore APT described below and hence the calibrations strike a balance between matching the results of both APTs with the same set of parameters.

3.2.1.2 Dames and Moore APT Dames and Moore (1975) conducted an APT in support of a feasibility study for using Floridan Aquifer water to cool the original Turkey Point nuclear units. Floridan Aquifer production test well (PTW) was pumped for 90 days and drawdown was measured in eight monitoring wells at various distances from the pumped well and depths in the aquifer. The drawdown response documented during this test was believed to represent a good series of targets to match as a part of a calibration because of its long duration and use of monitoring points that were distant from the pumping well. Thus, this test was complementary to the shorter duration, more local JLA APT described above.

As in the simulation of the JLA APT, the simulation of the Dames and Moore APT was accomplished using the refined model grid. Well PTW was represented with a single well pumping at a rate of 5000 gpm in cell layers 3 and 4, row 220, and column 97. Timestepping ranged from a minimum of 73 minutes to a maximum of 11.8 days.

Drawdown response was noted in wells OW-A (row 229, column 108), OW-B (row 238, column 120), OW-C (row 207,column 82), and OW-D (row 258, column 181) at distances of 100 feet, 500 feet, 2000 feet, and 48,000 feet, respectively from the pumped well. Drawdown was recorded in the Upper and Middle Floridan aquifers at each of the four observation well sites, which are represented by layers 3 and 4, and 7 and 8, respectively 5

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 7 of 21 Comparison of modeled to observed conditions for the original model, prior to adjustment, was not good (residual standard deviation in excess of IO ft), as was the case for the JLA APT. As shown i11 Figure 3, this match also improved considerably (with a residual standard deviation of 0.77 ft) after adjustment of hydraulic parameters as a part of the calibration. Goodness-of-fit calibration metrics are shown in Table 2 and indicate that the model provides a reasonable fit to observed data.

Table 2. Goodness of fit metrics for the Dames and Moore APT calibration Metric Numerical Value Mean Erro~r,_f_t _ _______

-0_._30 __ --t Mean Absolute_E_r_ro_r,~f_t ___ _,_ ___

o_.6_6 __

--1 Residual Standard _D_e_vi_a_tio_n...,_, _ft ______

o_. 7_7 __ --t Ran e of Targ_,e_t~s,_f_t _______

1_1_.8 __ __,

Residual Standard Devia_tio_n_l_R_a_n_.1i:i._e_*_1_0_0_._ ___

6_.5=%_o _ __.

Though the wells shown in Figure 3 are not an exhaustive representation of the calibration targets, they are a microcosm of the quality of the model match to this APT. The lateral and vertical proximity to the pumping well precluded a reasonable match to the observed drawdown at well OW-A (Upper); as such, this well was omitted from the calibration.

3.2.1.3 Adjustments to the calibration The primary parameters that were changed as a result of the additional calibration were hydraulic conductivities of the Upper Floridan Aquifer (UFA), ICU, Middle Confining Unit (MCU), and the Middle Floridan Aquifer (MF A). These parameters were all raised from their original values, as shown in Table 3.

Note that the parameter changes were made within zones that were near the Turkey Point site and mostly in areas potentially affected by drawdown from proposed salinity reduction wells, as shown in Figure 4, 5, and 6.

The changes made to the hydraulic properties in the Adapted Floridan model are not expected to significantly impact the quality of the model match to the water level and water quality targets employed in the calibration of the ECF AS2 model. The changes made to the Adapted Floridan model were generally minor, and the preponderance of the ECFAS2 model calibration targets are located outside of the Adapted Floridan model domain. Water levels at well ENP-100, located about 17 miles to west of Turkey Point, were simulated to be approximately 36 ft, which slightly underestimates observed water levels (approximately 37.5 ft NGVD29). The ECFAS2 model simulates a water level of 39 feet at this location, after 350 days of simulation. Simulated water levels at WASA-South, located to the no11h of Turkey Point, are approximately 35 ft NGVD 29; this well, however, was omitted from the ECF AS2 modeling analysis due to anomalous water levels (Golder Associates, 2008).

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 8 of 21 Tnblc3 P arameter c rnne:es rcsultme: rom cnhbrallo11 o t,c Atlante f

f I

<IFI 'I on( an model.

ECFAS2 model FPL Floridan Model Hydrologic Model Aquifer (original)

(recalibrated)

Unit Layers Parameter magnitude magnitude Kz (ft/d) 0.0006 0.001 ICU 2

0.000075 0.001 Kh (ft/d) 0.000075 0.001 5.2 100 Kz (ft/d) 9 15 72.5 225 0.33 225 UFA 3,4 52 100 Kh (ft/d) 90 150 725 330 3.33 330 Ss 5.25E-07 8.00E-07 0.004 0.000002 0.003 Kz (ft/d) 0.08 0.4 MCU 5,6 0.003 0.002 0.08 0.02 Kh (ft/d) 0.00001 0.08 0.4 0.03 Kz (ft/d) 5.2 30 450 900 MFA 7,8 300 600 Kh (ft/d) 180 1200 52 600 MC2 9, 10, 11 Kz (fVd) 0.0015 0.01 0.0002 0.02 3.3 Predictive Sim11/atiom, Once calibration of the regional Floridan model was confirmed, equilibrium flow conditions were established by running the model, holding all flow boundaries (e.g. specified heads) constant until changes in the simulated flow field in the Floridan Aquifer System were negligible. No pumping was simulated in this equilibrium model. The resulting equilibrated state formed the initial conditions for ensuing predictive simulations. Equilibrated regional water 7

TETRA TECH

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 9 of 21 levels, especially near Turkey Point, were generally lower than observed water levels; this is due to the exclusion of salt transport and the associated density-dependent flow. However, given that purpose of this model is to provide estimates of relative changes in water level, the low simulated water levels were deemed irrelevant. Since the focus of the salinity reduction well evaluation is regional drawdown, the original 2400-ft grid spacing was employed for predictive simulations.

According the SFWMD BOR, predictive evaluations made with the calibrated model must be conducted using monthly stress periods that simulate average annual groundwater withdrawals subject to rainfall that alternates between average and 1-in-l O year draught conditions (3 months of average conditions, followed by 12 months of drought conditions, followed by 6 months of average conditions). As such, the predictive models were conducted using 21 monthly stress periods.. Due to the specified head boundary in the topmost layer of the model, climatic stressess were not varied between average and drought conditions. Moreover, it is not anticipated that variation in rainfall would impact the Floridan aquifer over the 21-month timeframe of the simulation.

Additionally, the BOR stipulates that the 1-ft drawdown contour associated with the proposed pumping be simulated and the impacts to existing legal users' wells within that contour be evaluated. The process by which this was accomplished is described below.

3.3.J Proposed Salinity Reduction Well Operation There are six proposed salinity reduction wells. At any one time, five of these wells will collectively pump 14 MGD of low salinity water from the Upper Floridan aquifer. The six wells will be spaced approximately J 900 ft apart, along the northernmost canal of the Cooling Canal System and along the Interceptor Ditch (Figure 7). In the model, the 14 MGD of pumping is distributed evenly amongst the five active wells and is assumed to be a constant rate of pumping over the course of the 25-year simulation. Two alternative pumping scenarios are considered in this modeling analysis and differ in the allocation of pumping to wells F-2 and F-6. The base scenario simulates pwnping at wells F-1 through F-5 (no pumping at F-6); the alternative scenario simulates pumping at wells F-1 and F-3 through F-6 (no pumping at F-2).

The salinity reduction wells were simulated, starting from an equilibrium flow field. Aside from these salinity reduction wells, no pumping was simulated in this model such that the permitted users within the 1-ft drawdown contour could be delineated. At the conclusion of the 21-month simulation, the simulated drawdowns in the regional model are those attributable only to the five proposed salinity reduction wells. Figure 8a illustrates these regional drawdowns associated with the base pumping scenal'io. In this base simulation, the drawdowns at a distance from the site are affected by variations in hydraulic conductivity; this is evident upon inspection of the 1-ft drawdown contour, which generally has an oblong shape, whose major axis is oriented north-to-south. Nearer to the site, the drawdown contours radiate outward from the wells in a more uniform manner, where the maximum drawdown is approximately 15. l ft, near well F-3. In the alternative scenario, the maximum drawdown is approximately 14.4 ft, near well F-5.

As previously mentioned, the SFWMD BOR dictates that drawdown at permitted users' wells encircled by the 1-ft drawdown contom be determined. As illustrated in Figure 8a, the fo llowing permitted users fall within the 1-ft drawdown contour:

8 TETRA TECH

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 1 O of 21 Card Sound Golf Club, Ocean Reef Club, the Floridan Keys Aqueduct Authority (FKAA),

Miami-Dade Water and Sewage Department South Miami Heights Wellfield, and FPL Unit 5 We.lls.

A second 2 I-month simulation was conducted wherein pumping by permitted users and the proposed salinity reduction wells was simulated. Predicted drawdowns attributable solely to permitted Floridan pumping were determined by comparing drawdowns from this simulation (Figure 8b) to those attributable to the proposed salinity reduction wells alone (Figure 8a).

These permitted well-based drawdowns are illustrated in Figure 9 for the base pumping scenario. Predicted drawdowns at Floridan wells of these existing legal users due to the proposed operation of the salinity reduction wells are presented in Table 4. These drawdowns are calculated at the center of the model grid cells in which the respective wells are simulated. In addition to drawdowns attributable to the proposed wells for the base pumping allocation scenario, cumulative drawdowns at nearby wells due lo both pumping at permitted and proposed wells are provided in Table 4. Withdrawals by nearby users were simulated at their respective permitted rates.

Tnble 4. Predicted dmwdown at nearby users for the proposed Salinity Reduction Wells due to the base oumoin!!: scenal'io.

Permitted Distance Base Scenario Base Scenario Facility Location Withdrawal from Drawdown at Cumulative (L,R,C) well F-2 3,15, and 21

{MGD)

(miles\\

Months (ft\\

Drawdown (ft)

Card Sound Golf (3-Club (WUP 44-0.58 8.8 1.85/2.20/2.21 9.83/11.47/11.54 00001) 4,173,93)

Ocean Reef Club (3-1.42 8.8 1.85/2.20/2.21 9.83/11.47/11.54 (WUP 44-00002\\

4,173,93)

FKAA (3-9.70 10.3 1.76/2.15/2.16 416.06/17.78/17.85 (WUP 13-00005) 4,155,61)

South Miami Hts (3-4,133-23.3 10.3 1.83/2.25/2.26 46.71/48.72/48.80

{WUP 13-00017) 135,79)

FPL Unit 5 Well (3-14.3

< 1.0 11.44/11.85/11.86 34.11/35.92/35.99 (PW-1) 4,156,85)

A second evaluation was conducted in which the altemative pumping allocation (wells F-1 and F-3 through F-6) for the salinity reductions wells was simulated. The resulting simulated drawdowns at legal users within the 1-ft drawdown contour are provided in Table 5; cumulative drawdowns are also tabulated. Inspection of the drawdowns in Table 5 reveals that they are not significantly different from those produced by the base pumping allocation.

The cumulative drawdown due to permitted pumping, as illustrated in Figure 9, are not significantly different than those produced by the combination of proposed and permitted withdrawals (Figure 8b). This suggests that the proposed pumping of Floridan water by the salinity reduction wells will not significantly exacerbate drawdowns in the Upper Floridan aquifer beyond those induced by existing permitted pumping.

9 TETRA TECH

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 11 of 21 Table 5. Predicted drnwdown at nearby users for the proposed Salinity Reduction Wells clue to the It f

a erna 1ve 1mmome seen a no.

Alternative Alternative Location Distance Scenario Scenario Facility (L,R,C}

from well Drawdown at Cumulative F-2 (miles) 3,15, and 21 Months (ft)

Drawdown (ft)

Card Sound Golf Club (3-4, 173,93) 8.8 1.86/2.21/2.22 9.84/11.48/11.56 (WUP 44-00001)

Ocean Reef Club (3-4, 173,93) 8.8 1.86/2.21/2.22 9.84/11.48/11.56 (WUP 44-00002)

FKAA (3-4, 155,61) 10.3 1.78/2.17/2.18 16.08/17.80/17.87 (WUP 13-00005)

South Miami Hts (3-4,133-10.3 1.81/2.22/2.24 46.68/48.69/48. 78 (WUP 13-00017) 135,79)

FPL Unit 5 Well (PW-1)

(3-4,156,85)

< 1.0 9.92/1 0.33/10.35 32.59/34.40/34.47 4

Conclusions The evaluation of drawdown due to pumping at the proposed salinity reduction wells is based on the ECFAS2 model developed for the SFWMD. This model was subsequently adapted to site-specific conditions and re-calibrated to two APTs performed at Turkey Point. The resulting regional calibrated groundwater flow model provides assessment of drawdown at nearby existing Floridan water users.

In a regional sense, the proposed pumping of 14 MGD is projected to result in a maximum Upper Floridan Aquifer drawdown ranging between 14.4 ft (alternative scenario) and 15.1 ft (base scenario) at the Turkey Point site; simulated drawdowns at a distance from Turkey Point are not significantly different between the two pumping scenarios. The extent of drawdown, as defined by the I-ft drawdown contour encompasses four existing legal users. Overall, the impacts to off-site permitted wells are minor. The maximum drawdown due to the proposed salinity reduction wells experienced by the nearest (non-FPL) users is 2.26 ft and occurs at the South Miami Heights wellfield, located approximately 10.3 miles away. This drawdown comprises approximately 4.6% of the cumulative drawdown simulated at this site. The drawdown contribution by the proposed salinity reduction wells is a conservative estimate (greater than would actually be experienced), since the drawdown in the wellbore at each nearby user due to localized pumping is undersimulated by the coarse-gridded regional model.

In addition to a demonstration of minimal drawdown induced at wells of permitted users within the 1-fi drawdown contour, the BOR also stipulates that the proposed pumping not impact the saltwater interface, as defined by the 250 mg/L isochlor. As the quality of Upper Floridan Aquifer water in this area already exceeds such a concentration, and no saltwater interface exists, this stipulation does not apply to the proposed project. Moreover, the operation of the salinity reduction well is not expected impact Upper Floridan water quality in a regional sense. Local changes in water quality are expected to be minor, as demonstrated by other Upper Floridan water users in the region (SFWMD, 2012).

10 TETRA TECH

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 12 of 21 5

References Anderson, M.P., and Woessner, W.W., 1992, Applied Groundwater Modeling - Simulation of Flow and Advective Transport: San Diego, Ca, Academic Press, 381 p.

Dames and Moore, 1975. Floridan Aquifer Water Supply Investigation, Turkey Point Area, Florida.

Golder Associates, 2008. East Coast Floridan Aquifer System Model, Phase 2, Southeastern Florida, final Model Documentation Report, October 2008, 259pp.

Harbaugh, A.W., Banta, E.R., Hill, M.C., and McDonald, M.G., 2000, MODFLOW-2000, the U.S. Geological Survey modular ground-water model -- User guide to modularization concepts and the Ground-Water Flow Process: U.S. Geological Survey Open-File Report 00-92, 121 p.

HydroGeoLogic, 2006. Development of a Density-Dependent Saltwater Intrusion Model for the Lower East Coast Project Area, April 2006. 166 pp JLA Geosciences, 2006. Well Completion Report for Floridan Aquifer Wells PW-1, PW-3, and PW-4. FPL Turkey Point Expansion Project (Unit 5) Homestead, Florida.

Langevin, C.D., D.T. Thorne, Jr, A.M. Dausman, M.C. Sukop, and W. Guo, 2008, SEAWAT Version 4: A Computer Program for Simulation of Multi-Species Solute and Heat Transport: USGS Techniques and Methods Book 6, Chapter A22, 39 p.

South Florida Water Management District (SFWMD), 2012, Overview and Current Use of the Floridan Aquifer System in the Lower East Coast, Public Workshop, Pompano Beach, Florida, April 18, 2012.

Zheng, C., and P. Wang, 1999, MT3DMS, A modular three-dimensional multi-species transport model for simulation of advection, dispersion and chemical reactions of contaminants in groundwater systems; documentation and user's guide, U.S. Army Engineer Research and Development Center Contract Report SERDP-99-1, Vicksburg, MS, 202 p 11 TETRA TECH

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 13 of 21 P.IFPL\\SIIIM)' Rt<NC11on\\GIS\\Flg1_Moclo1Gfld IMd Legend D

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 16 of 21 Legend Original Conductivity -- Cooling Canals 3.0E-06 ft/d 0

7.5E-05 ft/d 0

6.0E-04 ft/d 2.5E-03 ft/d 9.SE-03 ft/d Calibrated Conductivity 3.0E-06 ft/d 6.0E-04 ft/d 1.0E-03ft/d 2.SE-03 ft/d 9.SE-03 ft/d 18

"b1strlbullon or Vertical Hydraulic Conductivity In the Intermediate Confining Unit a) Original Model, Prior to Additional Calibration and b) After Additional Calibration Turkey Point, Florida

[ 11:] TETRA TECH PROJ 117-28260 19 DATE 03/102014 4

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 17 of 21 Legend Original Conductivity 725 IVd D

224.995 rud G:] 100 fVd 90 IUd I 55 tud r

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 18 of 21 Legend Original Conductivity -- Cooling Canals 2.0E-06 fUd CJ 2.0E-03 fUd CJ 4.0E-03 fUd 5.0E-03 fUd 1.SE-02 ft/d I

I Calibrated Conductivity W 2.0E-03 fUd 3.0E-03 ft/d CJ 4.0E-03 ft/d 1.SE-02 fUd 8.0E-02 fUd CJ 4.0E-01 fUd b) r *

• =.

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rrrLE: Oislribulion of Vertical Hydraulic Conductivity in the Middle Confining Unit a) Original Model, Prior to Additional Calibration and b) Aller Additional Calibration Turkey Point, Florida PFA flGURE:

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 19 of 21 P:\\FPL\\Safinity Reducllon'GIS\\Newwens_SCA.mxd Legend TITLE:

Proposed Wells LOCATION:

Existing Unit 5 Wells Location of Proposed Salinity Reduction Wells Screened in the Upper Floridan A uifer Turkey Point, Florida

[11:) TETRA TECH CHECKE PFA DRAFTED JLR PROJ 117-282601 9 DATE 03/31/2014 t

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Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 20 of 21 0

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[ 11:]

TETRA TECH FIGURI!;

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PROJ 117-2826019 DATE 11/Sl2014

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.5.3.4 Supplemental Information L-2018-086 Attachment 1 Enclosure 1 Page 21 of 21 P:IFPL\\Sallnlty Reduction1£lt51Permilled_Q...DDN_21Mo_SCA.m<d Legend TITLE:

-- Drawdown Contours LOCATION:

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8 16 Scolo In Miles Simulated Equilibrium Drawdown in Upper Floridan Aquifer due to Permitted Pumping Turkey Point, Florida

[ 11: l TETRA TECH FIGURE:

9

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.6.6.4 Supplemental Information L-2018-086 Attachment 2 Page 1 of 7 SLRA Appendix E - Applicant's Environmental Report Subsequent Operating License Renewal Stage SLRA Appendix E Section 4.6.6.4: Threatened, Endangered, and Protected Species, and Essential Fish Habitat Analysis SUPPLEMENTAL INFORMATON:

The following information supplements and supports the discussion provided in section 4.6.6.4 of FPL's Environmental Report (ER) and provides specific conclusions regarding the potential impacts of renewed operation on listed species.

American crocodile (Crocodylus acutus)

Turkey Point Nuclear Units 3 & 4 (PTN) is one of three nesting locations in Florida and as described in Section 4.6.6 of the ER, operation of PTN has positively affected this species. As a requirement of the Site Certification, crocodiles on the site are monitored with a focus on the enhancement of crocodile nesting habitat as well as the monitoring the reproductive success, growth, and survival of hatchlings (FDEP, 2016). No construction or clearing activities are anticipated to occur as the result of subsequent license renewal and no increase in traffic volume is anticipated to result from the continued operation of PTN. Therefore, FPL concludes the continued operation of PTN will have no adverse effect to the crocodile or it's critical habitat.

Florida [West Indian] Manatee (Florida [West Indian] Manatee (Tricechus manatus latirostris))

The Florida or West Indian manatee is classified as endangered by both the Florida Fish and Wildlife Conservation Commission (FWC) and the United States Fish and Wildlife Service (USFWS). Manatees are known to occur in Biscayne Bay, but do not occur within the PTN area or the surrounding CCS, as the isolated CCS does not connect to the surface waters of Biscayne Bay. (NRC, 2016a: Section 2.4.1.3) The Plant utilizes the closed loop recirculating cooling canal system for cooling needs, and does not contribute any thermal discharge into Biscayne Bay that could attract manatees during winter months. Therefore, FPL concludes the continued operation of PTN will have no effect to the manatee.

Plants Crenulate Lead-Plant (Amorpha herbacea var. crenulata)

This species does not occur within a 6-mile radius of PTN (NRC, 2016a: Section 2.4.1.3). No impact to this species is expected as a result of subsequent license

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.6.6.4 Supplemental Information L-2018-086 Attachment 2 Page 2 of 7 renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the crenulate lead-plant.

Blodgett's Silverbush [Blodgett's Wild-mercury] (Argythamnia b/odgetti1)

This species has been observed in the vicinity of PTN (NRC, 2016a: Section 2.4.1.3).

No clearing activities are anticipated to occur as a result of subsequent license renewal.

Therefore, FPL concludes the continued operation of PTN will have no effect to the Blodgett's silverbush.

Florida Brickell-Bush (Brickellia eupatorioides [mosieri] var. floridana)

No critical habitat for this species has been designated within 6 miles of PTN (NRC, 2016a: Section 2.4.1.3). No clearing activities are anticipated to occur as a result of subsequent license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the Florida Brickell-bush.

Hairy Deltoid Spurge (Chamaesyce deltoidea ssp. adhaerens)

Berms within the CCS created with limestone fill may provide suitable habitat. However, plant surveys have not been conducted within the CCS and it is unknown if this species occurs at PTN. However, no clearing activities are anticipated to occur as a result of subsequent license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the hairy deltoid spurge.

Deltoid Spurge (Chamaesyce deltoidea ssp. deltoidea)

The deltoid spurge has been observed in the vicinity of PTN, and habitat preferences indicate berms within the CCS created with limestone fill may provide suitable habitat.

Plant surveys were not conducted within the CCS, and it is unknown if this species occurs on the PTN site (NRC, 2016a: Section 2.4.1.3). However, no clearing activities are anticipated to occur as a result of subsequent license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the deltoid spurge.

Pineland Sandmat [Pineland Spurge] (Chamaesyce de/toidea ssp. pinetorum)

It is endemic to southern Florida and has been observed in the vicinity PTN (NRC, 2016a: Section 2.4.1.3). However, no clearing activities are anticipated to occur as a result of subsequent license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the pineland sandmat.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.6.6.4 Supplemental Information L-2018-086 Attachment 2 Page 3 of 7 Wedge Spurge (Chamaesyce deltoidea ssp. serpyllum)

As discussed in the Environmental Report (ER), due to its restricted range, this species is not likely to occur at PTN. Therefore, FPL concludes the continued operation of PTN will have no effect to the wedge spurge.

Garber's Spurge (Chamaesyce garben)

This species is not known to occur within the vicinity of the PTN (NRG, 2016a: Section 2.4.1.3). Therefore, FPL concludes the continued operation of PTN will have no effect to the Garber's spurge.

Cape Sable Thoroughwort (Chromo/aena frustrata)

The Cape Sable thoroughwort is not known to occur on PTN. Land cover information indicates hammock habitats are not present on the PTN site. Therefore, suitable habitat for this species is not likely to occur on the PTN site (NRG, 2016a: Section 2.4.1.3).

Therefore, FPL concludes the continued operation of PTN will have no effect to the Cape Sable thoroughwort.

Florida Semaphore Cactus (Conso/ea [Opuntia} coral/ico/a)

As discussed in the ER, due to its restricted range, this species is not likely to be located at PTN. Therefore, FPL concludes the continued operation of PTN will have no effect to the Florida semaphore cactus.

Okeechobee Gourd (Cucurbita okeechobeensis ssp. okeechobeensis)

As discussed in the ER, due to its restricted range, this species is not likely to be located at PTN. Therefore, FPL concludes the continued operation of PTN will have no effect to the Okeechobee gourd.

Florida Prairie-Clover (Oa/ea carthagenensis floridana)

As discussed in the ER, suitable habitat is likely not present at PTN. Therefore, FPL concludes the continued operation of PTN will have no effect to the Florida prairie-clover.

Florida Pineland Crabgrass (Digitaria pauciflora)

FPL has reported Florida pineland crabgrass was observed in the vicinity of the Turkey Point site (NRG, 2016a: Section 2.4.1.3). However, no clearing activities are anticipated to occur as a result of subsequent license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the Florida pineland crabgrass.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.6.6.4 Supplemental Information L-2018-086 Attachment 2 Page 4 of 7 Small's Milkpea (Galactia smallit)

As of 2007 this species was only known at two sites near Homestead. A 1994 survey found the plant at seven conservation areas, and it may occur in two additional conservation areas. None of these areas are within a 6-mile radius of PTN (NRC, 2016a: Section 2.4.1.3). Therefore, FPL concludes the continued operation of PTN will have no effect to the Small's milkpea.

Johnson's Seagrass (Halophi/a johnsoni1)

This species may occur near Key Biscayne north and east of PTN and to the south in Card Sound, but it has not been observed near the PTN site or in the CCS (NRC, 2016a : Section 2.4.1.3). Therefore, FPL concludes the continued operation of PTN will have no effect to the Johnson's seagrass.

Beach Jacquemontia (Jacquemontia reclinata)

Fewer than 500 plants of this species are known from nine sites, all of which are more than 6 miles from PTN. Beach jacquemontia was not observed during previous surveys for threatened and endangered species on the PTN site (NRC, 2016a: Section 2.4.1.3).

Therefore, FPL concludes the continued operation of PTN will have no effect to the beach.

Sand Flax (Unum arenicola)

Sand flax occurs in Homestead Bayfront Park, which is less than one mile north of PTN.

FPL has noted sand flax was observed in the vicinity of the PTN site (NRC, 2016a:

Section 2.4.1.3). Based on the proximity of observed populations to Turkey Point, this species may be located at PTN. However, no clearing activities are anticipated to occur as a result of subsequent license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the sand flax.

Carter's Small-Flowered Flax (Unum carteri var. carten)

This species has been observed in the vicinity of PTN (NRC, 2016a: Section 2.4.1.3),

and therefore may occur on the site. However, no clearing activities are anticipated to occur as the result of subsequent license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the Carter's small-flowered flax.

Tiny Polygala (Polygala smalli1)

This species has been observed in the vicinity of PTN (NRC, 2016a: Section 2.4.1.3).

However, no clearing activities are anticipated to occur as a result of subsequent

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.6.6.4 Supplemental Information L-2018-086 Attachment 2 Page 5 of 7 license renewal. Therefore, FPL concludes the continued operation of PTN will have no effect to the tiny polygala.

Everglades Bully (Sideroxylon reclinatum ssp. austrofloridense)

The Everglades bully has not been observed growing in the vicinity of PTN (NRC, 2016a: Section 2.4.1.3). Therefore, FPL concludes the continued operation of PTN will have no effect to the Everglades bully.

Florida Bristle Fern (Trichomanes punctatum ssp. floridanum)

As discussed in the ER, based on the habitat needs and restricted range of this species, it is not likely to be located at PTN. Therefore, FPL concludes the continued operation of PTN will have no effect to the Florida bristle fern.

Florida Panther (Puma concolor cory1)

The USFWS recognizes much of Miami-Dade County and southern Florida as a Florida panther focus area. Although the focus area excludes the Turkey Point site, lands immediately adjacent to the Turkey Point site to the south and west are contained within the focus area and are also considered to be within the panther's primary zone. Florida panthers are susceptible to vehicle collisions; one in five deaths of, or major inju.ries to, radio-collared panthers resulted from a collision with a vehicle. However, no increase in traffic volume is anticipated to result from the continued operation of PTN. Therefore, an increased risk of collision with this species is not anticipated. Continued operation of PTN will not result in a loss of habitat (NRC, 2016a: Section 5.3.1.3). Therefore, the continued operation of PTN is not likely to adversely affect this species.

Carter's Mustard (Warea carten),

Given that continued operation of PTN does not include the construction of new facilities and that ongoing remediation activities associated with the CCS would be conducted in compliance with state and local requirements and monitoring would be conducted to ensure its effectiveness, the contribution to the overall cumulative impacts to terrestrial habitats including wetlands and terrestrial species communities would be small.

Species Not Found in Miami-Dade County Florida Scrub-jay (Aphelocoma coeru/escens)

Florida scrub-jays have been extirpated from Broward, Dade, Duval, Gilchrist, Pinellas, and St. Johns counties (FWS, 1999a).

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.6.6.4 Supplemental Information L-2018-086 Attachment 2 Page 6 of 7 Florida Grasshopper sparrow (Ammodramus savannarum f/oridanus)

The Florida grasshopper sparrow has been extirpated as a breeding bird in Collier, Miami-Dade, and Hendry counties (FWS, 1999b).

Ivory-billed woodpecker (Campephilus principalis)

The ivory-billed woodpecker inhabits cypress swamps and mature bottomland forest. It can be found from the Ohio River Valley, west to Texas, and east to Florida. The last reported sighting of the ivory-billed woodpecker was in 2004 in Arkansas; however, a confirmed sighting has not occurred since 1944. Historically, ivory-billed woodpeckers were found throughout Florida. Habitat destruction caused a serious depletion of the ivory-billed woodpecker population to the point that the species may be extinct.

Presently, habitat destruction would be the main continued threat to the species, as it depends on cypress and dead pine trees for nesting cavities (FWC, 2018a).

Red-cockaded woodpecker (Picoides borealis)

Red-cockaded woodpeckers inhabit 90 to 100 year-old long leaf pine, pond pine, pitch pine, and Virginia pine ecosystems from North Carolina, south to Florida, and west to Texas. The distribution map does not include Miami-Dade County (FWC, 2018b).

The species occurred historically in the Miami metropolitan area, Miami-Dade County, and is extirpated from this county. Therefore, the continued operation of PTN is not likely to adversely affect this species (FWS, 1999c).

Aquatic Species There are 10 federally listed species inhabiting the waters of Biscayne Bay in the vicinity of Turkey Point, including: shortnose sturgeon (Acipenser brevirostrum), Atlantic sturgeon (Acipenser oxyrhynchus oxyrhynchus), Nassau grouper (Epinephe/us striatus),

smalltooth sawfish (Pristis pectinate), loggerhead sea turtle (Caretta caretta), green sea turtle (Che/onia mydas), leatherback sea turtle (Dermochelys coriacea), hawksbill sea turtle (Eretmochelys imbricate), Kemp's ridley sea turtle (Lepidochlys kempi1), and the Florida manatee (Trichechus manatu). (NRC, 2016a: Section 2.4.2.3) PTN does not intake or discharge cooling water to Biscayne Bay, Card Sound, or other waters of the U.S. Therefore, FPL concludes the continued operation of PTN will have no effect to the shortnose sturgeon, Atlantic sturgeon, Nassau grouper, and smalltooth sawfish.

Because there are no known nesting beaches for any sea turtle species near PTN, and turtle strandings at PTN are rare, potential impacts on sea turtles are unlikely.

Therefore, FPL concludes the continued use of PTN will have no effect to the loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and Kemp's ridley sea turtle.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 SLRA Appendix E Section 4.6.6.4 Supplemental Information L-2018-086 Attachment 2 Page 7 of 7 Species Within Designated Essential Fish Habitat Gray snapper (Lutjanus griseus), dog snapper (Lutjanus jocu), mutton snapper (Lutjanus analis), bluestriped grunt (Haemulon sciurus), white grunt (Haemulon plumien), spiny lobster (Panulirus argus), and pink shrimp (Farfantepenaeus duorarum) are species within Essential Fish Habitat likely to occur near the Turkey Point site within Biscayne Bay (NRC, 2016a: Table 2-31 ). PTN does not intake or discharge cooling water to Biscayne Bay, Card Sound, or other waters of the U.S. There is no surface water exchange between the CCS and Biscayne Bay or other waters of the US; therefore, FPL concludes the continued operation of PTN will have no effect to these species.

References:

NRC, 2016a. Environmental Impact Statement for Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7. NUREG-2176, Volume 1. October 2016. NRC ADAMS Accession No. ML16300A104.

FDEP, 2016. Florida Power and Light Company Turkey Point Plant Units 3-5 Conditions of Certification. March 29, 2016. Accessible at:

http://publicfiles.dep.state.fl.us/Siting/Outgoing/Web/Certification/pa03 _ 45 _2016 _ Mod%

20E.pdf (accessed April 9, 2018).

FWS, 1999a. South Florida Multi-Species Recovery Plan. U.S. Fish & Wildlife Service Southeast Region. Accessible at:

https://www.fws.gov/verobeach/MSRPPDFs/FloridaScrubJay.pdf (accessed April 4, 2018).

FWS, 1999b. South Florida Multi-Species Recovery Plan. U.S. Fish & Wildlife Service Southeast Region. Accessible at:

https://www.fws.gov/verobeach/MSRPPDFs/FloridaGrasshopperSparrow.pdf (accessed April 4, 2018).

FWC, 2018a. Ivory-billed woodpecker: Campephilus principalis. Florida Fish & Wildlife Conservation Commission. Accessible at:

http://myfwc.com/wildlifehabitats/imperiled/profiles/birds/ivory-billed-woodpecker/

(accessed April 4, 2018).

FWC, 2018b. Red-cockaded woodpecker: Picoides borealis. Florida Fish & Wildlife Conservation Commission. Accessible at:

http://myfwc.com/wildlifehabitats/imperiled/profiles/birds/red-cockaded-woodpecker/

(accessed April 4, 2018).

FWS, 1999c. South Florida Multi-Species Recovery Plan. U.S. Fish & Wildlife Service Southeast Region. Accessible at:

https://www.fws.gov/verobeach/MSRPPDFs/Carter.PDF (accessed April 4, 2018).