L-2018-169, Responses to Requests for Additional Information for Subsequent License Renewal Application No. HC-7-a L-2018-169 Environmental Review

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Responses to Requests for Additional Information for Subsequent License Renewal Application No. HC-7-a L-2018-169 Environmental Review
ML18283A313
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 10/05/2018
From:
Florida Power & Light Co
To:
Office of Nuclear Reactor Regulation
References
L-2018-169
Download: ML18283A313 (30)


Text

{{#Wiki_filter:Turkey Point Units 3 and 4 Docket Nos . 50-250 and 50-251 FPL Response to NRC RAI No . HC-7-a L-2018-169 Attachment 1 Enclosure 1 Page 1 of 30 Enclosure 1 Coastal Archaeology & History Research, Inc. and Historic Preservation Solutions, LLC "A Cultural Context of the McGregor Smith Cottage" (December 30, 2014) Florida Power and Light Company, Turkey Point Turkey Point Units 3 and 4 SLR Application NRC RAI No. HC-7-a

Turkey Point Units 3 and 4 FPL Response to NRC RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 2 of 30 A CULTURAL CONTEXT OF THE McGREGOR SMITH COTTAGE, FLORIDA POWER AND LIGHT COMPANY, TURKEY POINT Prepared for: Florida Power and Light Company Prepared by: Coastal Archaeology & History Research, Inc. and Historic Preservation Solutions, L.L.C. December 30, 2014 CARR Project#: 14012 CAHR ( ult 11.il kr<ou,,c (.on 11/tm

  • www .CAHResearch.com

Turkey Point Units 3 and 4 FPL Response to NRG RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 4 of 30 TABLE OF CONTENTS Consultant Summary*****************************************************************************************************************************:** 1 Research Design ................................................................................................................................... 1 Summary Findings ................................................................................................................................ 2 Part I: Schedule of Historic Preservation Activities ................................................................................ 3 Part II - Historical Assessment Report .................................................................................................... 4 The Early Years: 1925-1940 ..................................................................................................... ~ .......... 4 World War II and After: 1940 -1960 .................................................................................................... 4 The Atomic Age: 1945 -1970 ............................................................... .,............................................... 6 Turkey Point in the Era of Regulation: 1960- 1970 ............................................................................. 7 FPL's Environmental & Community Legacy: 1965 and Beyond ...................................................... 10 The Rangers House (a.k.a. McGregor Smith Cottage) ....................................................................... 12 Bibliography ...................................................................................................._...................................... 15 Table of Figures Figure 1. Portrait of McGregor Smith ...................................................................................................... 5 Figure 2. FPL Power Plant Locations ...................................................................................................... 6 Figure 3. McGregor Smith at the Governors' Conference, Miami Beach, Florida, 1958 ....................... 7 Figure 4. 1972 Aerial photograph showing power plant and the rangers' house .................................. 12 Figure 5. View northwest of the house .................................................................................................. 13 Figure 6. View interior living room to the kitchen ................................................................................ 13 Figure 7. 1965 Architectural drawing showing floor plan and elevations ............................................. 14 _.. ,:>*:,,,

  • Coastal Archaeology & History Research, Inc.

tAHR A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point

Turkey Point Units 3 and 4 FPL Response to NRG RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 6 of30 CONSULTANT

SUMMARY

Between November 16, 2014 and December 30, 2014 Florida Power & Light Company (FPL) contracted Coastal Archaeology and History Research, Inc. (CARR) to perform historic preservation services linked with the proposed relocation, designation, rehabilitation and adaptive reuse of the McGregor Smith Cottage (also known as the Ranger's Station) (FPL Contract# 02331464). CARR and architectural historian specialists Historic Preservation Solution, L.L.C (HPS) conducted historical research on the Florida Power & Light Company with particular emphasis on the Turkey Point Nuclear Station and McGregor Smith, FPL President 1939-1969. During this time HPS also conducted consultation with the project's general contractor, New World Builders, Inc. which is performing site planning, soil analysis and other services necessary to submit application for project permits with Miami-Dade County Planning and Zoning Dept. Summary of these meetings is provided in PART I of this report; historical findings are provided in PART II. RESEARCH DESIGN This study's research design focused on fulfilling three project objectives: 1) Establish a historical context and rationale for the historical designation of the McGregor Smith Cottage, including tangible associations with McGregor Smith, the Florida Board of Conservation, the construction of Turkey Point nuclear units 3 and 4, and other links that evidence the significance of the McGregor Smith Cottage to FPL corporate culture, or local, state, and national events. The historical research is intended to provide documentation necessary to complete a successful historical designation application to the Miami-Dade County Historic Preservation Office. 2) Identify defining structural and site locational features that contribute to the structure's overall significance. This information enabled the CARR and HPS engage with the project Contractor/ Architect in purposeful discourse regarding the methods and materials that will be used in the rehabilitation of the McGregor Smith Cottage as well as site-planning to ensure that the relocated structure will retain its original integrity as well as to preserve the "experience" of the cottage. 3) Provide baseline historical study that can be used to inform future research design for exhibits and other interpretive installations in conjunction with the rehabilitated McGregor Smith Cottage. Between November 16 and December 30, 2014 personnel from CARR and HPS conducted research in the Florida State Archives at Tallahassee, including: files of The Florida Board of Conservation and files of The Florida Board of Conservation - Reports within the Executive Director Randolph Hodges Administration 1961-1971 collection (.S 1163); Minutes 1933-1970 of the Florida State Board of Conservation in the Florida State Board of Conservation collection (.S 684). A short documentary, Out of a Wilderness, produced by the Florida Board of Conservation (1967) and highlighting FPL's Turkey Point plant was retrieved from the Florida Memory Project of the State Archive as were several historical images of McGregor Smith. Several editions of the FPL' s own publication, the "Florida Sunshine News" were retrieved from the Special Collections Library of Florida Atlantic Coastal Archaeology & History Research. Inc. A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 1

Turkey Point Units 3 and 4 FPL Response to NRG RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 7 of 30 University, Boca Raton and the State Archive. FPL provided numerous materials including copies if initial correspondence with Miami-Dade County preservation staff.

SUMMARY

FINDINGS It is the consultant's opinion, based on the material provided by FPL and the materials discovered in the Florida State Archives, that the McGregor Smith Cottage will be eligible for historic designation in Miami-Dade County in January 2016, when the building reaches fifty (50) years old (Miami-Dade County Ord. 81-13, Chapter 16A-10). This opinion is based on the information obtained from the original building plans, provided to the consultant by FPL and which indicates that the building was approved by the Miami-Dade County Building Department in August 1965. This opinion assumes that the structure was built within the year (1965).

  • If additional information can be obtained either via FPL corporate archives/records or from the Miami-Dade County Building Department (special permissions are required),

indicating that the building was completed before January 1966 then the building will be eligible for designation before January 2016. Unfortunately, archival research could not confirm that the relationship between the Florida Board of Conservation and the building, nor did archival research confirm that the building was completed as part of permitting requirement of the nuclear facility. 1 Therefore, it is also the consultant's opinion that, based on the presently available research and information, the building is not eligible for historical designation based on exceptional significance criteria the Miami-Dade County historic preservation ordinance (Ord. 81-13, Chapter 16A-10 Part 11 (f)) and therefore not eligible for designation before January 2016. The structure may be eligible for historic designation under exceptional significance criteria if:

a. Additional information can be obtained from FPL corporate records/archives indicating that the building was constructed in order to fulfill regulatory requirements in association with the construction of the nuclear generation facility at Turkey Point; or
b. Corroborative information can be obtained from FPL corporate records/archives indicating that the building was utilized by the Florida Board of Conservation.

1 NextEra Energy "A Half Century of People Serving People, A History of Florida Power and Light Company in Four Parts, Part Four: McGregor Smith Ranger's House - Turkey Point," (Florida Power and Light Company: Miami, Florida, November 2012), 10. 2

Turkey Point Units 3 and 4 FPL Response to NRG RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 8 of 30 PARTI SCHEDULE OF HISTORIC PRESERVATION ACTIVITIES Project personnel acquired significant information about the subject property during the project's preliminary feasibility study the McGregor Smith Cottage Preservation Project: Relocation, Rehabilitation, Historic Designation & Interpretation Proposal (Florida Power and Light (FPL) Contract# 02322674). Prior fieldwork including meetings site visits between the consultant and sub-consultant provided substantial grounding for continued project development during under the current project scope. Between November 16 and December 5th, personnel from AHC and HPS conducted remote research of the Florida State Archives (Tallahassee, FL), the Library of Congress (Washington, D.C.), and the National Archives (Washington, D.C.). Personnel conducted electronic newspaper and academic database research and performed physical collections research in the Special Collections Library at Florida Atlantic University, Boca Raton. During the week of December 14t\ personnel from HPS conducted hands-on research at the State Archives in Tallahassee in order to determine tangible ties of the McGregor Smith Cottage to the Florida Board of Conservation and to establish any other historical relationships that may alter the date of eligibility for historic designation in accordance with the Miami-Dade County historic preservation ordinance (Ord. 81-13, Chapter 16A). The result of this research is provided in PART II of this study. HPS and CARR conducted telephone correspondence with staff of the Miami-Dade historic Preservation Office to confirm the findings of the 2013/2014 feasibility study with regard to the appropriateness of the structure's relocation and specific treatments to ensure retention of historical integrity and eligibility for local historical designation. During this time CARR and HPS conducted meeting (teleconference and physical) with New World Builders, Inc. (NWB). The scheduled December 1, 2014 site visit was cancelled; however, the scheduled receiver site soil-survey was performed on December 1, 2014 and a subsequent meeting also took place between NWB and HPS and Jay Archer, Architect (JAA). HPS stressed the significance of: 1) Maintaining the orientation of the structure with the environment; 2) Retention of original structure fabric, such as wooden-post pilings,% wrap-around porch with original design railings and tum-buckle supports, jalousie windows and similar. 3) Retention of accessory materials such as the anhinga mooring-ball sculptures. During the week of December ?1h personnel from CARR and HPS met with NWB and the contractor's architect JAA to ensure that site planning and proposed engineering specifications were compatible with historic preservation standards including the siting of the structure at the relocation site. Additional meeting during the week of December 14th focused on discussion of the site treatments to ensure that the building's relationship to the relocation site is not substantially altered in a way that will impact the building's historic character. Coastal Archaeology & History Research, Inc. A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 3

Turkey Point Units 3 and 4 FPL Response to NRC RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 9 of 30 PART II HISTORICAL ASSESSMENT REPORT THE EARLY YEARS: 1925-1940 In Florida, prior to 1925, consumer electrical service was provided by small community based power plants throughout the State. This inefficient system failed to provide reliable service and was incapable to keep up with the demand that resulted from the intense real estate boom occurring throughout the State. American Power and Light (APL), a large multi-state electricity provider, saw an opportunity to expand their operation. On December 28, 1925, Florida Power and Light (FPL) was incorporated as a subsidiary of APL and consolidated among many of the small, independent operations under APL' s umbrella. 2 APL had the financial wherewithal to improve the reliability of the system and to expand it to keep up with the explosion of development that was occurring. One month after FPL's incorporation construction began on a new 50,000kw power plant in Fort Lauderdale, increasing the system's capacity by over 70%. 3 The first 15 years of FPL's existence was a rocky road. Less than a year after FPL's organization, on September 17, 1926, South Florida was struck by a destructive hurricane. Just two years later, a second massive hurricane struck the State wreaking havoc in its path. Those disastrous hurricanes and serious real estate scams busted the financial boom that had been a driving force in the Florida economy. This, of course, was just a prelude to the stock market crash of 1929 and a decade long depression. The Depression had a profound impact on FPL. Not only did it bring the construction boom to a halt but a substantially reduced tourist activity decreased winter revenue as permanent residents struggled to pay their electric bills. 4 FPL, however, managed to keep itself above water through a combination of conservative management and creative activities. One creative way that FPL sought to generate additional revenue was through appliance sales. FPL's meter-readers also sold small appliances, such as irons, which made home-life easier while at the same time increasing electricity usage. 5 Between 1936 and 1939 FPL doubled its output from 115 to 243 megawatts. By the late 1930s FPL had stabilized, and in 1938 had made an advanced tax payment of $125,000 to the State of Florida to help meet payroll. 6 FPL closed the 1930s with the installation of a new dynamic manager, McGregor Smith. WORLD WAR II AND AFTER: 1940 -1960 Under the direction of newly appointed president, McGregor Smith, FPL prepared their anticipated resurgence from the depression by consolidating their business activities and expanding their capacity to generate electricity. Florida's trajectory of recovery changed on December 7, 1941 when Pearl Harbor was attacked and the United States was thrust into World 2 NextEra Energy "A Half Century of People Serving People, A History of Florida Power and Light Company in Four Parts, Part Four: McGregor Smith Ranger's House- Turkey Point," (Florida Power and Light Company: Miami, Florida, November 2012), 3. 3 Ibid, 12. 4 Ibid, 36. 5 Ibid, 36-39. 6 "FPL PAYS $125,000 ADVANCE ON TAXES," (Miami Herald: Miami, Florida, August 18, 1938). 4

Turkey Point Units 3 and 4 FPL Response to NRC RAI No. HC-7-a Docket Nos . 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 10 of 30 War Two .. Florida, with its vast unpopulated areas of land along with significant water access and ports made it strategically important for the mi litary and bases cropped up immediately. Many of the tourist areas went dark but the demand for electricity by the military increasingly absorbed the excess capacity and placed a particular strain on the company. As the military presence in Florida grew, the growing demand for electricity was satisfied by significant infrastructure expansions by FPL. Smith increased production hours from forty (40) to forty-four (44) hours per week during WWII. At the war' s end FPL was presented with a Meritorious Wartime Service commendation owing to the company' s contributions. 7 wartime -.

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                                                                                                    --u FIGURE 1. PORTRAIT OF MCGREGOR SMITH. SIGNED, "TO OUR MOST EFFICIENT SECRETARY, COLLEEN MORRIS WITH FOND MEMORIES." PHOTO COURTESY OF THE STATE ARCHfVES OF FLORIDA, FLORIDA MEMORY PROJECT.

As World War II concluded, substantial investment in increasing electrical generation capacity, poised FPL to be prepared for Florida' s post war experience. After a decade of depression and the difficultly of the War years, people needed a vacation - and there was no better place than the Sunshine State. Many who came to Florida decided to make it their home. Additionally, many of the soldiers who trained in Florida were taken with the State and also decided to come 8 back permanently. Year after year, the population of Florida grew by 3,000 people per week. FPL correctly recognized that the influx of new residents would continue for the foreseeable 1 future and engaged in an ambitious expansion program. By 1960, when Florida became the 10 h most populous state in the country, it was clear that Florida ' s population explosion would continue. Population growth and the development of air conditioning demanded that FPL increase capacity to meet the State's expanding electrical needs. In South Florida, where demand was exceeding the capacity of the Cutler power station, a new facility needed to be built in an area that could absorb the new demands and prepare for future population growth. FPL purchased 1,800 acres of land at Turkey Point, 24 miles south of Miami on Biscayne Bay, in an area dense with mangroves. 7 NextEra Energy, "Half a Century . .. ," 63 , 65-72. 8 extEraEnergy, "Haifa Century . ..," 73.

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A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 5 CAHR

Turkey Point Units 3 and 4 FPL Response to NRG RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 11 of 30 THE ATOMIC AGE: 1945 -1970 Nuclear energy was a realization of World War II military ambition and in the post-WWII era the United States government concurrently centralized and expanded its atomic research under the authority of the Atomic Energy Act of 1946. The Atomic Energy Act of 1946 instituted the United States Atomic Energy Commission (AEC), a civilian Commission with "extraordinary power and independence." 9 The Commission, chaired by the President of the United States, was composed of five commissioners and a chief executive officer, each of whom were appointed by the President of the United States. In addition to creating the AEC, the Atomic Energy Act established the Congressional Joint Committee on Atomic Energy, the Military Liaison Committee, and the General Advisory Committee of outstanding scientists, each of which served in advisory capacity to 10 the AEC. In his 1953 "Atoms for Peace Address" to the United Nations, President Eisenhower acknowledged the destructive power of the world's nuclear arsenal, cautioned the implications of the United Sates - Soviet nuclear arms race and supported the United Nation's

                                                                                                                        -~

Disarmament Commission. He also advocated "that peaceful

power from atomic energy is no dream of the future. That capability, already proved, is here-now-today. Who can doubt

         . . . that this capability would rafiidly be transformed into universal, 1
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efficient, and economic usage." FIGURE 2. FPL POWER PLANT LOCATIONS. NEXTERA, "HALF A CENTURY ... " In July 1955 an experimental atomic reactor, "BORAX III" successfully powered the town of Arco, Idaho for one hour. 12 The test was the first of over 40 conducted since the 1940s to demonstrate the practical and peaceful application of atomic energy. But, nearly two decades of testing also attested to the radiological, explosive, and financial hazards associated with atomic energy. 13 Such factors precluded the private sector from embracing atomic energy and for these reasons the federal government assumed much of the risk involved in the early development and production of atomic energy. Coal and oil -fired facilities were tried-and-true and while atomic energy was alluring, industrial insurers were not willing to underwrite nuclear facilities. 9 Buck, " The Atomic Energy Commission,", I 10 Alice Buck, " The Atomic Energy Commission," (U .S. Department of Energy, Office of Management, Office of the Executive Secretariat, Office of History and Heritage Resources: Washington, D.C., Jul y 1983)., President Dwight D. Eisenhower's 1953 A ddress to the United Nations, known as the Atoms for Peace speech proposed that the United Nations be the forum for international control of atom ic energy. The proposal fell through when the Soviet Union rejected the plan . The A.C.E. is a domestic variation of the international control plan proposed by David E. Lilienthal and Under Secretary of State Dean Acheson, know more readily as the Acheson-Lilienthal report. See Buck, " The Atomic Energy Commission", as well as President Dwight D. Eisenhower, "Atoms for Peace Address," 8 December 1953. 11 Eisenhower, "Atoms for Peace Address," 1953. 12 Buck, " The Atomic Energy Commission,"; National Park Service, National Historic Landmarks Program: Experimental Breeder Reactor No. I.; L. Angelo, " Arco, Idaho," 2008. 13 L. Angelo, " Arco, [daho." 2008 . 6

Turkey Point Units 3 and 4 FPL Response to NRC RAI No . HC-7-a Docket Nos. 50-250 and 50-251 L-201 8- 169 Attachment 1 Enclosure 1 Page 12 of 30 FIGURE 3. MCGREGOR SM ITH (RIGHT), UNITED NATIONS SECRETARY GENERAL DAG HAMMERSKJOLD (MIDDLE), AND FLORIDA GOVERNOR LEROY COLLINS (LEFT) AT THE GOVERNORS' CONFERENCE, MIAMI BEACH, FLORIDA, 1958. PHOTO COURTESY OF THE STATE ARCIDVES OF FLORIDA, FLORIDA MEMORY PROJECT. The industry received a much needed boost from the Price -Anderson Nuclear Industries Indemnity Act of 1957. 14 The Price-Anderson Act, as it is known, established a no-fault insurance-type system wherein nuclear utilities established a collective pool of liability funds; in the event that a claim exceeds the available funds the federal government would then absorb the difference. Lawmakers judged that the Act was a necessary incentive for privately funded nuclear facilities. Within the year, the Shippingport Atomic Power Station became the first full-scale atomic electric power plant devoted to domestic peace-time use became operational and 15 was connected to the Duquesne Light Company power grid outside Pittsburg, Pennsylvania. TuRKEY POINT IN THE ERA OF REGULATION : 1960- 1970 In June 1964, the State of Florida issued FPL permit to construct two oil-fired electric power 16 generators at Turkey Point. The first oil-fueled generator, unit 1, went into operation on April 17 22, 1967 and the second, unit 2, on April 25, 1968. FPL had a lso proposed natural gas powered electric generators at the Turkey Point facility to compliment the facility's two oi l-fired units, but a ruling by the FPC in 1964 which prioritized "c lean-burning" natural gas to be utilized 14 Signed into law on September 2, 1957. 15 The Energy Library, " Price-Anderson Act of 1957, Un ited States," 2009; National Hi story and Heritage Committee, "Hi storic Achievement Recognized : Shippingport Atomic Power Station A National Engineering Historical Landmark" American Soc iety of Mechanical Engineering: Washington, D.C., n.d.). The Shippingport Atomic Power Station became operational on December 18, 1957. 16 Tara E. Dolan, "A Case Study of Turkey Point Nuclear Generating Station: Perception and Power in Environmental Assessment," (MA Thesis: University of Miami, 2012):2-3 ; NextEra Energy, "Our History: Space Age to Nuclear Age; 1961-1972," 2014. 17

                       !bid., 3,4; NextEra Energy, "Turkey Point Nuclear Plant: Fact Sheet," 2014; Janus Research, lnc. and Golder Associates, Inc ,
        "Cultural Resource Assessment Survey for the Turkey Point Uni ts 6 & 7 Site, Associated Non-Linear Facilities, and Spoils Areas on Plant Property," (Janus Research, Inc: Tampa, Fl, 20 12),3.

Coastal Archaeology & History Research , Inc. A Cu ltural Co ntext of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 7

Turkey Point Units 3 and 4 FPL Response to NRC RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 13 of30 in urban environments blocked natural gas transmission to Turkey Point. Per the FPC ruling, Turkey Point did not qualify as an urban area and was more well suited to oil and coal fire generators. In 1965 FPL garnered approval for natural gas units at Turkey Point, but the matter was again complicated when the FPC alleged that FPL was in violation of the Natural Gas Act by utilizing "comingled" natural gas sources via the Florida Natural Gas Transmission Company. The FPC contested that FPL was in violation of interstate trade laws and utilizing natural gas imported from adjacent regions but the allegation was inconclusive as it was impossible the identify the source of "comingled gas." So long as FPL was not utilizing more gas than was available from Florida's internal resources, it could not be demonstrated that there was any violated of the Natural Gas Act by FPL. 18 Smith seized the opportunity and utilized the FPC' s delay in natural gas permitting as an opportunity to expand FPL's production with nuclear capabilities. In the winter of 1965, McGregor Smith, President of FPL announced the company's plans to construct two nuclear energy reactors twenty-five miles south of Miami and just east of Homestead at the company's Turkey Point power plant. 19 Moreover, public perception of nuclear power was boosted in part by research that promised cheap, clean, and unlimited, and safe, nuclear energy that was not at all incompatible with the natural landscape of the Everglades whose abundance of water could be used to cool nuclear reactors. Almost immediately, FPL initiated construction of nuclear reactor unit 3 & unit 4. Units 3 and 4 were completed and running by 1972. 20 Turkey Point may have been the most ambitious project in FP&L's portfolio in 1965, but it was not the only project FP&L had in the works. By the late 1960s, FP&L had amassed millions in bonds and stocks, and announced plans for a $670 million expansion. The corporate expansion caught the attention of the United States Justice Department (USJD). For nearly a decade, Washington, D.C. regulators tried to harness FPL's expansion, first through the FPC and later through the Natural Gas Act, both of which were determined to be non-jurisdictional in the operation of FPL's utilities. 21 On Valentine's Day, 1968, the Wall Street Journal reported that McGregor Smith had resigned the presidency at FPL, his replacement; Robert H. Fite had previously served as Smith's second in command. Smith retained his seat as Chairman of the Board. 22 During the following three years, Fite led FPL through a quagmire of federal scrutiny and new regulations of the 1970s as FPL prepared to bring Turkey Point online. In 1969, following an immense fund-raising program aimed to generate capital for corporate expansion, the USJD in collusion with the Securities and Exchange Commission (SEC) and the 18 William T. Coleman, Jr. and Robert W. Maris, 'Federal Power Commission Proceedings Involving Jurisdictional Issues: of Loopholes, Gaps, and End-Runs," Natural Resources Lawyer, I, no. 4. October 1968):44-50. 19 Tara E. Dolan, "A Case Study of Turkey Point Nuclear Generating Station: Perception and Power in Environmental Assessment," (MA Thesis: University of Miami, 2012):2-3; NextEra Energy, "Our History: Space Age to Nuclear Age; 1961-1972," 2014; WSJ, "FPC Aide Rejects Plan to Ship Gas to Florida." (Wall Stree_t Journal: New York, New York, July 8, 1966): 25. See also: Rowland L. Young, "Supreme Court Report," American Bar Association 58, No. 4 (April 1972): 407-412. In 1972 FPL won a suit against the FPC when the FPC attempted to administer jurisdiction control over Florida Power and Light Company citing that FPL had sold their electricity over state lines and thus violated interstate commerce regulations. FPL used the "comingling" argument to defend that the utilities excess power was sold to a second party electricity provider within Florida and that FPL was not liable for subsequent electricity distribution was out the state by a second party. These two examples demonstrate how the Florida Utility was able to fend off Federal interests in many instances. 20 Ibid., 3,4; NextEra Energy, "Turkey Point Nuclear Plant: Fact Sheet," 2014; Janus Research, Inc. and Golder Associates, Inc.,

        "Cultural Resource Assessment Survey for the Turkey Point Units 6 & 7 Site, Associated Non-Linear Facilities, and Spoils Areas on Plant Property," (Janus Research, Inc: Tampa, Fl, 2012),3.

21 Tara E. Dolan, "A Case Study of Turkey Point Nuclear Generating Station: Perception and Power in Environmental Assessment," (MA Thesis: University of Miami, 2012):2-3; NextEra Energy, "Our History: Space Age to Nuclear Age; 1961-1972," (2014). 22 Wall Street Journal, "Florida P&L Names Fite, President , as Top Executive," (Wall Street Journal: New York, New York, February 14, 1968)12. 8

Turkey Point Units 3 and 4 FPL Response to NRG RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 14 of 30 Florida Public Service Commission (FPSC) broke open FPL's ledger book looking for evidence of fault or fraudulent, specifically with regard to recent rate increases. 23 Florida Attorney General, Early Faircloth exclaimed, "Florida Power & Light Co. is a monopoly. It is also a public utility and is legally and legislatively constituted as such. The public has a right to the facts and a right to see the books and records upon which rates are based."24 Indeed, FPL was a large corporation with incredible power, but it was not unique in this regard; concurrently, in fact, Attorney General Faircloth filed similar complaints against the Florida Power Corporation (FPC), the Tampa Electric Company (TEC), and Gulf Power Company (GPC)," 'to determine if customers of these utilities are paying too much' for service." 25 In January 1969, the passage of the National Environmental Policy Act (NEPA) assured that the utility's growth would be scrutinized by Washington, D.C. environmentalists. Between 1969 and 1970, environmental monitoring mandated under NEPA and required in part by the newly dedicated Biscayne National Park, hinted at unforeseen ecological impacts that the Turkey Point facility had been affecting since units I and 2 went on line in the mid- l 960s. 26 A number of environmental studies conducted between 1968 and 1973 identified that hot-water discharge at Turkey Point was causing unsustainable damage to submerged biota in Biscayne Bay. 27 In the winter of 1970, FPL was excavating a six-mile cooling canal proposed in 1965 to usher heated water out of the plant's nuclear unit three and unit four into Biscayne Bay. Once activated, the canal would facilitate transfer of cooling water. In February 1970, Secretary of the Interior (SOI) Walter J. Hickel threatened FPL with court action if FPL did not alter its plans to construct the cooling canal. In March 1970, the DOJ filed suit against FPL and in November FPL shareholders also filed a $300 million suit against FPL charging environmental mismanagement. Ms. Abigail Starr Avery, a shareholder from Massachusetts contended that the principal officers of the company had spent millions of dollars constructing two conventional and two nuclear generators, "without the necessary Federal and state permits." 28 Following the 1970 injunction filed by the US Justice Department, FPL and the Department of the Interior settled on a development plant aimed to mitigate the discharge of heated water into Biscayne Bay. The complexity of the suit must be considered within a broad context. In the 1960s, FPL's Florida constituency expressed little concern over the proposed nuclear units which, after all, would increase available connections in South Florida, bring local jobs, and generally benefit the community. 29 The suit brought forth by the DOJ, citing a violated the Rivers and Harbors Act 23 WSJ, "Florida P&L Bond Bidding," (Wall Street Journal: New York, New York, June 1, 1959)18.; "Florida P&L Building Budget," (Wall Street Journal: New York, New York, February 17, 1970) 36.;"Florida P&L, Combustion Engineering Talk of Nuclear Facility Costing $200 Million,"(Wall Street Journal :New York, New York, December 5, 1967)11,; "Florida P&L Files Share Offer," (Wall Street Journal: New York, New York, November 14, 1969)31; Wall Street Journal, "Florida P&L Sees 8% Rise in 3ro Period Revenue," (Wall Street Journal: New York, New York, September 26, 1967)33. 24 Wall Street Journal, "Florida Pans to Fight to Open the Books of Florida P&L," (Wall Street Journal: New York, New York, October 15, 1969): 5. 25 Wall Street Journal, "Attorney General is Dissatisfied with Commission's Handling of Florida P&L Fee Proceedings," (Wall Street Journal: New York, New York, April 7, 1969):15. 26 Jay Clarke, "Biscayne Bay gets a wildlife sanctuary with its new power plant," New York Times: New York, New York, April 2, 1967)505. . 27 A Thorhaug, D. Segar, and M.A. Roessler, "Impact of a power plant on a subtropical estuarine enviromnent," Marine Pollution Bulletin 4, no. 11 (School of Medicine, University of Miami: Miami, Florida, 1973): 166-169; M.A. Roessler, "Enviromnental changes associated with a Florida power plant," Marine Pollution Bulletin 2, No. 6 (School of Medicine, University ofMiami: Miami, Florida, 1971) 87-90; 28 E.W. Kenworthy, "U.S. Suit Fights Heat Pollution," (New York Times: New York, New York, March 14, 1970)31; New York Times, "Enviromnental Suit Is Filed in Florida," (New York Times: New York, New York, November 23, 1970)24. 29 NextEra Energy, "A Haifa Century," 9, 10, 12. Coastal Archaeology & History Research, Inc. A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 9

Turkey Point Units 3 and 4 FPL Response to NRG RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 15 of 30 ofl 899 by discharging "thermal pollution," was the first of its kind. 30 In FPL' s defense they evidenced that the plan, to direct cooling water through dredged canals into Biscayne bay, was approved by the Dade County pollution control officer who considered that it was in the best interest of the public in both protecting the environment and assuring necessary electric power." 31 Construction at Turkey Point began, and considerable permitting secured prior to the enactment of the National Environmental Protection Act. Support for nuclear power was boosted in part by research that promised cheap, clean, and unlimited, and safe, nuclear energy that was not at all incompatible with the natural landscape of the Everglades whose abundance of water could be used to cool nuclear reactors. Turkey Point was envisioned as a technological and environmental achievement that would continue to promote FPL's longstanding commitment to social and ecological stability of south Florida. But the five short years since its inception, had seen dramatic increase in environmental awareness, improvement in environmental protections, and increased standards in environmental regulation. In 1969 for example, the same year that Congress enacted the National Environmental Protection Ace, the California Senate passed the toughest clean water act in the country. 32 Across the nation, environmental research and environmentalism was gathering momentum. The charges levied against FPL directly conflicted with the Company's own public good-will and long-standing commitment to environmental and community stewardship. In September

        *1971, FPL and the Justice Department filed an agreement at the US District Court in Miami.

FPL pledged to undertake a five-year, $30 million dollar closed-system canal construction project. The canal isolated the plant's super-heated cooling water, allowing it to naturally cool before being recirculated back through the power plant. FPL agreed to interim inspections as well as to prohibit discharge of superheated water into Biscayne Bay. 33 Turkey Point's nuclear reactors went into operation in 1971 and 1972 upon completion. of the closed-system cooling canal. The two nuclear units increased Turkey Point power station's electrical output by 1386 Megawatts, and the total corporate financial expenditure for the nuclear facility is estimated at 1.2 billion. Today the system is cooled by an expanded canal network totaling nearly 170 miles long. 34 FPL's ENVIRONMENTAL & COMMUNITY LEGACY: 1965 AND BEYOND Robert H. Fite guided FPL out of an unforeseen environmental catastrophe and worked to maintain FPL's well established environmental and community stewardship programs founded by McGregor Smith. In post-War Miami, depression era organized crime and gambling began to resurge. In 1946 McGregor Smith and fellow Miami heavy-hitters James L. Knight, publisher of the Miami Herald; Dan Mahoney, publisher of the Miami Daily News; Frank Kazentine, principle owner of radio station WKAT; George Whitten, principal owner of Burdines; and John Clark principle owner of the Hialeah Race Track formed the "Secret Six," a collective of local 30 Gladwin Hill, "Hickel Warns Power Company on Canal: Asks Halt to Facility to Take Hot Water to Biscayne Bay," (New York Times: New York, New York, February 25, 1970)73; Gillman, "Florida Power Plant told to cool Water," (The New York time: New York, New York, February 27, 1970)10. 31 Kenworthy, 1970:31. 32 Jerry Gillam, "Senate Oks Toughest State Water Pollution Bill in U.S.," (Los Angeles Times: Los Angeles, California, July 3, 1969)Al. 33 Associated Press, "Utility Pledges Halt to Heat Pollution in Biscayne Bay," (New York Time: New York, New York, September2, 1971)56; Associated Press, "U.S. Pollution Suite Settled In Florida," (New York Times: New York, New York, September 12, 1971)80. 34 Florida Power and Light Company, "Turkey Pioint Nuclear Power Plant Fact Sheet," (FPL: Miami, Florida, 2014 ). 10

Turkey Point Units 3 and 4 FPL Response to NRG RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 16 of 30 power-brokers who tackled organized crime. 35 The group merged with the Dade County Bar Association to form the Crime Commission of Greater Miami as was headed by former Federal Bureau of Investigation agent Daniel P. Sullivan. Smith's efforts to clean-up Miami, as well as his firm connections to the Miami Herald and Miami Daily News brought himself and FPL significant praise. 36 Smith also held in strong appreciation south Florida's natural environment and he leveraged his political and personal clout in favor of environmental preservation and promotion of Florida's resources. In 1947 Smith facilitated introductions between John D. Pennekamp, editor of the Miami Herald and members of the Florida Legislature at FPL's corporate fishing camp in Lake Marion, Florida. As result of the meeting Pennekamp gained favor for his interests in Everglades National Park and received $2 million from the Florida legislature to purchase right-of-way for the park. Smith himself served as Chairman at the park dedication ceremony. 37 In 1963, Smith threw his support, and by association the support of FPL, behind Florida agricultural interests as Chair of the Finance Committee for the Florida World's Fair Authority, whose task was to oversee the development of the Florida pavilion and exhibit, including the Citrus Tower, at the 1964 New York World's Fair. 38 Smith wasn't just the President of the Florida Power and Light Company; he was a spokesman for Florida. Smith ensured that his dedication to the community was more than superficial and he encouraged a similar responsibility from company employees. During the 1960s, roughly ninety-five percent (95%) of FPL's 2261 employees were donors to the Dade County United Fund. McGregor Smith insisted that, "[FP&L] want[s] to participate in the community, and a man is not intelligent if he won't pull his load". 39 Smith's community-minded business sense paid dividends to FPL's corporate image, an image that was further bolstered by the realization that between 1939 and the middle 1960s, under Smith's guidance, FPL had mana§ed to grow exponentially while it either maintained or reduced electrical rates to its consumers. 4 Through the 1960s, under Smith's leadership, FPL made substantial contributions to the local environmental community and fostered a well-respected natural resource preservation program. In 1967, FPL had already erected a 1,700 acre playground for the local citizenry. At the site on the shore of Biscayne Bay, FPL had previously constructed a 1,500 acre Boy-scout camp, and a Girl Scout camp was also under construction. Turkey Point's four miles of cooling canals were made available to the public for recreational use. In addition the Turkey Point facility played host to an Air Force air-sea survival school and a large shrimp breeding pond jointly managed by the University of Miami. In the years following the 1971 agreement with the DOJ, FPL has strived to address concerns raised by the Audubon Society as well as the Secretary of the Interior 35 Ron Chepesiuk, Gangsters of Miami: True Tales of Mobsters, Gamblers, Hitmen, Con Men and Gang Bangers from the Magic City, (Barricade Books: Fort Lee, New Jersey, 2009). 36 Ibid. 37 Everglades National Park Commission, "Everglades National Park Dedication, December 6, 1947," (Everglades National Park Commission: Miami, Florida, 1947); Allen Morris, The Language and Lore of Lawmaking in Florida. (Clerk of the Florida House of Representatives: Tallahassee, Florida, 1979):87. 38 1963 New York World's Fair 1964-1965 Corporation. "Dedication of the Florida Citrus Tower at the New York World's Fair 1964

        - 1965". June 24, 1963.
                   "'Richard F. Carter, The Gentle Legions: National Voluntary Health Organizations in America. (Transaction Publishers, 1992):277.

40 Florida Power and Light Company (FPL), "A Half a Century of People Serving People, A History of Florida Power and Light Company, Part Four: McGregor Smith Ranger's House-Turkey Point," (Florida Power and Light: Miami, Florida, November 2012), 7-9. Note: In modem terms, 1 megawatt is capable of providing energy to approximately 250-300 homes.

        -**l*,.,

tAHR Coastal Archaeology & History Research, Inc. A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 11

Turkey Point Units 3 and 4 FPL Response to NRC RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 17 of 30 over the ecological impact of the facility on th e biota of Biscayne Bay National Monument and the Everglades. 41 Together, FPL and Smith made "good neighbors," and a vast majority of FPL's acquired lands remaining in a natural state, Turkey Point became the largest primitive nature sanctuary m Miami-Dade County. To assist m the management of the environmental preservation programs, FPL, m 1965 , constructed a house for a full time Florida Board of

  • Conservat10n ranger. 42 FIG URE 4. 1972 AERIAL PHOTOGRA PH SHOWCNG THE RELATIONSHCP BETWEEN THE POW ER PLANTS AND THE RANGERS HOUSE (RED ARROW).

PHOTO COURTESY OF THE STATE A RC HIVES OF FLORIDA, FLORIDA MEMORY PROJECT. TH E RA GERS HO USE (A.K.A. M CGREGOR SMITH COTTAGE) The Rangers House was built based on plans that were permitted by Dade County in 1965. It is located just so uth of the supply-channel connecting the plant to Biscayne Bay and was built to provide living quarters and a work space for a full time Florida Board of Conservation Ranger. The house has a simple rectangular form with a hip roof. Its dimensions are 24' x 28' plus 6' porches on the north, east and south sides. It is built of wood fram e construction in a utilitarian vernacular style. It is elevated approximately 8 feet above the grade and supported utility poles for columns. The cottage exterior is sided with a texturized panel system exhibiting suggestive of vertical boards. The original plans show jalousie windows on the north, east and so uth sides so that the wi ndows would not protrude into the porch when open while the west side had aluminum framed awning windows. All of the windows have since been replaced with aluminum framed awning windows. Wall air conditioning units have also been installed . The interior has a simple layout with an open living room/kitchen and two bedrooms with a full bathroom between them. The proposed relocation, rehabilitation and preservation plan, anticipated for 2015 - 2016 will relocate the cottage to the north side of the supply-channel and into the public access beachfront park. There, the building will be placed on a new foundation that replicates, to the extent that 41 WSJ, " U.S. Threatens Suit to Stop Construction Of Canal in Florida," (Wall Street Journal: ew York, New York, February 25 , 1970) 34 . Frank J. Mazzotti and Michael S. Cherkiss, Fort Lauderdale Research and Education Center. Status and Conservation of the American Crocodile in Florida: Recovering Endangered Species While Restoring an Endangered Ecosystem. Volume I. (Davie, Florida: Fort Lauderdale Research and Education Center, 2003).; Richard H. Gilluly, " Finding a Place to Put the Heat," Science and News 98 , no. 5 {Aug. I, 1971): 98-99.; Tara E. Dolan, " A Case Study of Turkey Point Nuclear Generating Station: Perception and Power in Environmental Assessment," MA Thesis (University of Miami, 2012). 42 NextEra Energy, " A Haifa Century," 10. 12

Turkey Point Units 3 and 4 FPL Response to NRC RAI No . HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 18 of 30 code will allow, the orientation look and feel of the house in the existing location. Historically significance elements of the building' s exterior will be retained and repaired, or replaced " in-kind" as appropriate to preserve the building' s historical character. The interior of the structure will be designed in coordination with FPL in order to fulfill the desired adaptive reuse functions of the space. FIGURE 5. (ABOVE)VIEW FROM THE NORTHWEST OF THE FRONT OF THE HOUSE (AUTHOR 'S PHOTO). FIGURE 6. (ABOVE) VIEW OF THE INTERIOR FROM THE LIVING ROOM TO THE KITCHEN (AUTHOR' S PHOTO). (4'*. *. Coastal Archaeology & History Research , Inc. A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 13 CAHR

Turkey Point Units 3 and 4 FPL Response to NRC RAI No . HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 19 of 30

                             -- ** ~:::..:: ~
                               ~~

FIGURE 7. ARCI-UTECTURAL DRAWING DATED 1965 SHOW ING FLOOR PLAN AND ELEVATIONS. 14

Turkey Point Units 3 and 4 FPL Response to NRC RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 20 of 30 BIBLIOGRAPHY 1963 New York World's Fair 1964- 1965 Corporation. "Dedication of the Florida Citrus Tower at the New York World's Fair 1964-1965." 1963 New York World's Fair 1964-1965 Corporation: New York, 1963. Accessed November 24, 2014. http://worldsfairphotos.comnywf64/booklets/florida-dedication-9-24-63.pdf. Adams, Walter. "Corporate Gigantism, Ethics, and the Public Interest." Review ofSocial Economy, 21, no. 1 (March 1963): 1-18. Accessed November 18, 2014. http://www.jstor.org/stable/29767715. Angelo, L. Arco, Idaho. Last updated 2008. Accessed November 21, 2014. http://www.eoearth.org/view/article/l 50178 Associated Press. "$I-Billion voted by Senate To Fight Water Pollution." New York Times (1923-Current File), November 13, 1969. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):1. *

                   "3 Killed by Blast in Atom Reactor: A.C.E. Isolates Idaho Site in a Move to Allay Fears of Radiation Danger." New York Times (1923-Current File), January 5, 1961. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):1 "Blackout Laid to Defect." New York Times (1923-Current File), April 6, 1973. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):39.
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                   "Hot weather poses threat to cooling canals at Turkey Point nuclear plant near Miami. The Republic, July 17, 2014. Accessed November 18, 2014.

http://www.therepublic.com/view/story/56c763c261764120b037ccc71982l5l9/FL--Hot-W eather-Nuclear-Plant.

                   "Power Blackout Hits Miami Area: Explosion Causes a Failure - 2 Million Affected." New York Times (1923-Currentfile), August 6, 1969. Accessed December 1, 2014. ProQuest historical Newspapers: New York Times (1851-2010): 34.
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May 17, 1977. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):16. r*4(:*:*\ Coastal Archaeology & History Research, Inc. CA}-{R A Cultural Context of the McGregor Smith Cottage, Florida Power and Light Company, Turkey Point 15

Turkey Point Units 3 and 4 FPL Response to NRG RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 21 of 30 "Senate Panel Shelves License Plan That Benefits Nuclear Power Plants." New York Times (1923-Current File), July 20, 1972. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):25.

                   "U.S. Pollution Suit Settled in Florida." New York Times (1923-Current File), September 12, 1971. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):80.
                   "Utility Pledges Halt To Heat Pollution In Biscayne Bay." New York Times (1923-Current File), September 2, 1971. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):56.

Blight, James G., and Aaron Belkin. "USSR's Third World Orphans: Deterring Desperate Dependents." Third World Quarterly, 13, no. 4 (1992): 715-726. Accessed November 18, 2013. http://www.istor.org/stable/3992385. Buck, Alice. "The Atomic Energy Commission." U.S. Department of Energy, Office of Management, Office of the Executive Secretariat, Office of History and Heritage Resources: Washington, D.C., July 1983. Accessed November 21, 2014. http://energy.gov/sites/prod/files/AEC%20History.pdf Carlyle, Thomas. Past and Present Book Four: The Horoscope. England, 1843. Carter, Luther. The Florida Experience: Land and Water Policy in a Growth State. Routledge: New York, New York, 2013. Carter, Richard. The Gentle Legions: National Health Organizations in America. Transaction Publishers: Edison, New Jersey, 1992. Chepesiuk, Ron. Gangsters of Miami: True Tales of Mobsters, Gamblers, Hitmen, Con Men and Gang Bangers from the Magic City. Barricade Books: Fort Lee, New Jersey, 2009. Clarke, Jay. "Biscayne Bay Gets a Wildlife Sanctuary With Its New Power Plant." New York Times (1923-Current File) April 2, 1967. ProQuest Historical Newspapers: New York Times (1851-2010):505. Coleman, William T. Jr. and Robert W. Maris. "Federal Power Commission Proceedings Involving Jurisdictional Issues: of Loopholes, Gaps and End-Runs." Natural Resources Lawyer l, no. 4 (October, 1968):44-50. Accessed November 18, 2014. http://www.jstor.org/stable/40921926. Coll, Albert R. "United States Strategic Interest in Latin America: An Assessment." Journal of Interamerican Studies and World Affairs, 39, no. 1 (Spring 1997): 45-57. http://www.jstor.org/stable/166495. 16

Turkey Point Units 3 and 4 FPL Response to NRC RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 22 of 30 Dolan, Tara E. "A Case Study of Turkey Point Nuclear Generating Station: Perception and Power in Environmental Assessment." MA Thesis, University of Miami, (2012). Open Access Theses, Paper 354. EG&G Idaho, Inc., and Allied Chemical Corporation. "NUREG/CR-1629: In-Plant Source Term Measurements at Turkey Point Station - Units 3 and 4." Prepared for Division of Safeguards, Fuel Cycle and Environmental Research Office of. Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, D.C. (Washington, D.C.: Government Printing Office, 1980). Eisenhower, Dwight D. "Atoms for Peace Address." 8 December 1953. Accessed November 24, 2014 http://www.eisenhower.archives.gov/All About Ike/Speeches/Atoms for Peace.pdf "Statement by the President Upon Signing the Atomic Energy Act of 1954." August 30, 1954. Accessed November 24, 2014. http://www.presidency.ucsb.edu/ws/index.php?pid=10012 Elliot, John M. "Environmental Aspects of Nuclear Power." The Urban Lawyer 4, no. 1 (winter 1971):33-58. Accessed November 18, 2014. http://www.jstor.org/stable/27892805. Everglades National Park Commission. "Everglades National Park Dedication, December 6, 1947." Everglades National Park Commission: Miami, Florida, 1947. Finney, John W. "Atomic Industry Now Optimistic On Outlook for Cheap Electricity." New York Times (1923-Current File), November 27, 1962. Accessed December 1, 2014.ProQuest Historical Newspapers: New York Times (1851-2010):75. Florida Department of Natural Resources. Out of a Wilderness. V-240 CA 291. Florida Department ofNatural Resources, April 21, 1967. Florida Electrical Power Plant Siting§ 403.501-403.518 (2013). http://www.leg.state.fl.us/Statutes/index.cfm?App mode=Display Statute&Search String=&U RL=0400-0499 /0403/Sections/0403 .5 0 I .html. Florida Power and Light Company. "1953 Year in Review: Bountiful Florida ... Land of Fabulous Growth." Sunshine Service News, Florida Power and Light Company: Miami, Florida, 1954.

                   "Donna's Aftermath: Reddy Power Plant." Sunshine Service News 23, No. 10. Florida Power and Light Company: Miami, 1960.
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                   "Those Were the Days." Sunshine Service News (October/November 1970). Florida Power and Light Company: Miami, 1970.

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  • Coastal Archaeology & History Research. Inc.

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Turkey Point Units 3 and 4 FPL Response to NRC RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 23 of 30 Gaby, Ronald, Mark P. McMahon, Frank J. Mazzotti, W. Neil Gillies, and J. Ross Wilcox. "Ecology of a Population of Crocodylus acutus at a Power Plant Site in Florida." Journal of Herpetology, 19, no. 2 (June, 1985): 189-198. Accessed November 18, 2014. http://www.jstor.org/stable/1564172. Garb, "Review of Critical Masses." Journal of Political Ecology, 6 No. 1 (1999). Gilluly, Richard H. "Finding a Place to Put the Heat." Science and News 98, no. 5 (Aug. 1, 1971): 98-99. Accessed November 28, 2014. http://www.jstor.org/stable/3955799. Gilman, Jerry. "Senate Oks Toughest State Water Pollution Bill in U.S." Los Angeles Times, July 3, 1969. Accessed December 1, 2014. ProQuest Historical Newspapers: Los Angeles Times (1881-1990):Al. Harkaway, William I. "Air Pollution-The Federal Power Commission and Other Federal Agencies." Natural Resources Lawyer, 3, no. 1 (January, 1970): 66-73. Accessed November 18, 2014. http://www.istor.org/stable/40921645. Hill, Gladwin. "Florida Power Plant Told to Cool Water." New York Times (1923-Current File), February 27, 1970. Accessed December 1, 2014. ProQuest Historical Newspapers: The New York Times (1851-2010):10.

                   "Hickel Warns Power Company on Canal: Asks Halt to Facility to Take Hot Water to Biscayne Bay." New York Times (1923-Currentfile), February 25, 1970. ProQuest Historical Newspapers: New York Times (1851-2010):73.

Janus Research, Inc. and Golder Associates, Inc. Cultural Resource Assessment Survey for the Turkey Point Units 6 & 7 Site, Associated Non-Linear Facilities, and Spoils Areas on Plant Property. June, 2012. On file at the Florida Master Site File, Division of Historic Resources, Florida Department of State, Tallahassee, Florida. Kenworthy, E.W. "U.S. Suit Fights Heat Pollution: Justice Department Acts to Protect Biscayne Bay." New York Times (1923-Current File), March 14, 1970. Accessed December 1, 2014. ProQuest Historical Newspapers: New York Times (1851-2010):31. Latin, Howard A., Gary W. Tannehill, and Robert E. White. "Remote Sensing and Environmental Law." California Law Review, 64, no. 6 (December, 1976). Accessed November 18, 2014. http://www.istor.org/stable/3480040. Los Angeles Times. "Three Killed by Atomic Core Blast: Radiation Scare Started by Idaho Reactor Explosion ATOM." Los Angeles Times, January 5, 1961: 1,3,7. Accessed December 1, 2014. ProQuest Historical Newspapers: Los Angeles Times (1881-1990). Mazzotti, Frank J. and Michael S. Cherkiss. Fort Lauderdale Research and Education Center. Status and Conservation of the American Crocodile in Florida: Recovering Endangered Species 18

Turkey Point Units 3 and 4 FPL Response to NRC RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 24 of 30 While Restoring an Endangered Ecosystem. Volume 1. Davie, Florida: Fort Lauderdale Research and Education Center, 2003. Mehta, Michael D. Risky business: nuclear power and public protest in Canada. Lexington Books: Canada, 2005. McDonald, Harry A. "Today at the S.E.C." Address delivered by Harry A. McDonald, Chairman, Securities and Exchange Commission before the 43rd Annual Dinner of the Detroit Stock Exchange. The Statler Hotel, Detroit, Michigan. February 21, 1950. Morris, Allen "The Language and Lore of Lawmaking in Florida." Florida Morrow, Edward A. "Accord Reached On Pollution Curb: U.S. Transportation Unit to Push Waterways Cleanup." New York Times (1923-Current File), April 10, 1968. Accessed December 1, 2014. ProQuest historical Newspapers: New York Times (1851-2010):93. National Park Service. National Historic Landmarks Program: Experimental Breeder Reactor No. l. Accessed November 24, 2014. http://tps.cr.nps.gov/nhl/detail.cfm?Resourceid=l98&ResourceType=Bui1ding National History and Heritage Committee, "Historic Achievement Recognized: Shippingport Atomic Power Station, A National Engineering Historical Landmark," American Society of Mechanical Engineering: Washington, D.C., n.d.). Accessed November 30, 2014 .. http ://files.asme.org/ASMEORG/Communities/History/Landmarks/5 64 3. pdf NextEra Energy "A Half a Century of People Serving People. A History of Florida Power and Light Company in Four Parts, Part Four: McGregor Smith Ranger's House -Turkey Point." Florida Power and Light: Miami, Florida, November 2012.

                        "About Turkey Point." n.d. http://www.fpl.com/environmnt/nuclear/about turkey point.shtml.

Accessed November 18, 2014.

                        "Our History: Space Age to Nuclear Age; 1961-1972." 2014. Accessed December 2, 2014.

http://www.nexteraenergy.com/company/history.shtml.

                        "Our History: The Building Years; 1945-1960." 2014. Accessed December 2, 2014.

http://www.fpl.com/about/history/the building years 1945 1960.shtml.

                        "Turkey Point Nuclear Plant: Fact Sheet." 2014. Accessed November 24, 2014.

http://www.fpl.com. Nuclear Energy Institute. "Turkey Point's Positive Impact on South Florida." 2014. Accessed November 26, 2014. http://www.nei.org/News-Media/News/News-Archives/Turkey-Point-s-Positive-Impact-on-South-Florida.

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Turkey Point Units 3 and 4 FPL Response to NRG RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 25 of 30 Quarles, John R., Jr. *"Functions of the Environmental Protection Agency." Natural Resources Lawyer, 5, no. 2 (April 1972): 330-337. Accessed November 18, 2014. http://www.jstor.org/stable/40921804. Ray, Dixie Lee. "A Biologist Looks at the Energy Crisis." BioScience, 24, no. 9 (September 1974): 495-497. Accessed November 18, 2014. http://www.jstor.org/stable/1296884. Rhodes, Richard. Dark Sun: The Making of the Hydrogen Bomb. New York, New York: Simon and Schuster, 1995. Roessler, M.A. "Environmental Changes Associated with a Florida Power Plant." Marine Pollution Bulletin 2, no. 6 (June 1971 ): 87-90. Accessed December 1, 2014, http://dx.doi:l0.l016/2005-326x(71)90196-2. Rodgers, William H., Jr. "Industrial Water Pollution and the Refuse Act: A Second Chance for Water Quality." The University of Pennsylvania Law Review, 119, no. 5 (April, 1971). Accessed November 18, 2014. http://www.jstor.org/stable/3311223. Rudig, Wolfgang. Anti-nuclear Movements: A World Survey of Opposition to Nuclear Energy, Longman, 1990. Schrick, Ray J. "Atoms & Safety: AEC Pushes Testing In Idaho, Seeks Safer and Cheaper Reactors." Wall Street Journal (1923-Currentfile), November 7, 1960. Accessed December 1, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889 - 1996): 1. Schroeder, Stanley W. "Pollution in Perspective: A Survey of the Federal Effort and the Case Approach." Natural Resources Lawyer, 4, no. 2 (April, 1971):381-428. Accessed November 18, 2014. http://www.jstor.org/stable/40921719. Securities and Exchange Commission. "Florida P&L to Sell Bonds." News Digest: A brief summary offinancial proposals filed with and actions by the S.E.C.. , December 14, 1970. Securities Exchange Commission: Washington, D.C, 1970.

                   "Florida P&L to Sell Stocks." News Digest: A brief summary offinancial proposals filed with and actions by the S.E.C., November 18, 1969. Securities Exchange Commission:

Washington, D.C., 1969.

                   "Florida Power & Light to Sell Bonds." News Digest: A brief summary offinancial proposals filed with and actions by the S.E. C., October 25, 1968. Securities Exchange Commission:

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                   "Florida Power and Light Company." News Digest: A brief summary offinancial proposals filed with and actions by the S.E.C., April 17, 1957. Securities Exchange Commission:

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                   "Florida Power and Light Proposes Bond Offering." News Digest: A brief summary of financial proposals filed with and actions by the S.E. C., June 27, 1962. Securities Exchange Commission: Washington, D.C., 1962.

Smith, Turner T., Jr. "Electricity and the Environment -The Generating Plant Siting Problem." The Business Lawyer 26, no. 2 (November 1970): 169-197. Accessed November 18, 2014. http://www.jstor.org/stable/40684703. Staletovich, Jenny. "Hot cooling canals threaten shutdown of Turkey Point nuclear power plants." Miami Herald, July 16, 2014. http://www.miamiherald.com/2014/07/16/4239899/hot-weather-threatens-cooling.html. State Archives of Florida, Florida Memory, http://floridamemory.com/items/show/35133. Governor LeRoy Collins walking with U.N. Secretary General Dag Hammerskjold at Governors' Conference - Miami Beach, Florida, 1958. Accessed November 16, 2014. http://www.floridamemory.com/items/show/35133. State Archives of Florida, Florida Memory, http://floridamemory.com/items/show/154889. McGregor Smith, President of Florida Power & Light Company. Accessed November 16, 2014. http://www.floridamemory.com/items/show/1548 89. The Energy Library. The Price-Anderson Act of 1957, United States." 2009. Accessed November 22, 2014. http://www.theenergylibrary.com/node/520. Thorhaug, A., D. Segar, and M.A. Roessler. "Impact of a Power Plant on a Subtropical Estuarine Environment." Marine Pollution Bulletin 4, no. 11 (November 1973):166-169. Accessed December 1, 2014, http://dx.doi:10.l016/0025-326x(73)90l76-8. Torres, Andrea. "FPL faces algae bloom challenge in Turkey Point's waste water canals: algae outbreak in cooling canals threatens FPL's reliability." Local JO.com, July 16, 2014. http://www.local 10 .com/news/fpl-faces-algae-bloom-challenge-in-turkey-points-waste-water-canals/26981970. United States Atomic Energy Commission. Director of Licensing. Environmental Statement Related to Operation of Turkey Point Plant, Florida Power and Light Company. Dockets No. 50-250 and 50-251. July, 1972. Washington, D.C.: Nuclear Regulatory Commission, 1972. Accessed November 20, 2014. http://www.nrc.gov/reading-rm/adams.html. United States Nuclear Regulatory Commission. "A Short History of Nuclear Regulation, 1946-1999. Last modified March 29, 2012. http://www.nrc.gov/about-nrc/short-history.html. Florida Power and Light Company Docket No. 50-250 Turkey Point Nuclear Generating Unit 3 Amendment to Facility Operating License. June 5, 1975. Washington, D.C.: United States

       /*1.::**-.\   Coastal Archaeology & History Research, Inc.
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Turkey Point Units 3 and 4 FPL Response to NRC RAJ No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 27 of 30 Nuclear Regulatory Commission, 1975. Accessed December 1, 2014. http://www.nrc.gov/reading-rm/adams.html. Florida Power and Light Company Docket No. 50-250 Turkey Point Nuclear Generating Unit 3 Amendment to Facility Operating License. [Annotated]. June 5, 1975. Washington, D.C.: United States Nuclear Regulatory Commission, 1975. Accessed December 1, 2014. http://www.nrc.gov/reading-rm/adams.html. Wall Street Journal. "AEC Finds Evidence of Errant Nuclear Reaction In Fatal Idaho Explosion." Wall Street Journal (1923-Current File), January 10, 1961. Accessed December 1, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889-1996):20.

                   "Ebasco Service Gets Award for Florida P&L Generator." Wall Street Journal (1923-Current file), July 15, 1959. Accessed November 20, 2014. ProQuest Historical Newspapers: Wall Street Journal (1899- 1996):4.
        ----- "Combustion Engineering Says Florida P&L Buys Atom Unit." Wall Street Journal(1923-Currentfile), May 2, 1968. Accessed November 20, 2014. ProQuest Historical Newspapers:

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        ---- "Dividend News: Florida P&L Holders Approve 2-for-1 Stock Split." Wall Street Journal (1923-Currentfile), May 12, 1959. Accessed November 20, 2014. ProQuest Historical Newspapers:

The Wall Street Journal (1899-1996):19.

        ----- "Florida P&L Agrees To Government Decree." Wall Street Journal (1923-Currentfile),

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        ----- "Florida P&L, Combustion Engineering Talk of Nuclear Facility Costing $200 Million." Wall Street Journal (1923-Currentfile), December 5, 1967. Accessed November 20, 2014.

ProQuest Historical Newspapers: Wall Street Journal (1889-1996): 11.

        ----- "Florida P&L Files Share Offer." Wall Street Journal (1923-Currentfile), November 14, 1969.

Accessed November 20, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889-1996):31.

        ----- "Florida P&L Meeting Hears Chairman, 71, Play Musical Finale." Wall Street Journal (1923-Currentfile), May 17, 1971. Accessed November 20, 2014. ProQuest Historical Newspapers:

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Turkey Point Units 3 and 4 FPL Response to NRG RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 28 of 30

        ----- "Florida P&L Names Fite, President, as Top Executive." Wall Street Journal (1923-Current file),

February 14, 1968. Accessed November 20, 2014. ProQuest Historical Newspapers: The Wall Street Journal (1889-1996):12.

        ------ "Florida P&L Names Fullerton President And Top Executive." Wall Street Journal (1923-Currentfile), August 12, 1969. Accessed November 20, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889-1996):17.
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         ----- "Florida P&L Plans $20 Million Bond Issue About November 17." Wall Street Journal (1923-Currentfile), August 18, 1959. Accessed November 20, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889-1996):19.
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        ----- "Florida P&L Registers Bond Issue of $25 Million." Wall Street Journal (1923-Current file),

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        ----- "Florida P&L Spending." Wall Street Journal (1923-Currentfile) December 2, 1970. Accessed June 20, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889-1996):12.
        ----- "Florida P&L Spending $670.6 Million in '66-70 To Expand its Service." Wall Street Journal (1923-Currentfile), August 4, 1966. November June 20, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889-1996):6.
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        ----- "Florida Plans Fight to Open The Books of Florida P&L." Wall Street Journal(1923-Current file), October 15, 1969. Accessed November 20, 2014. ProQuest Historical Newspapers:

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        -----"FPC Aide Rejects Plan To Ship Gas to Florida." Wall Street Journal (1923-Current file), July 8, 1966. Accessed November 20, 2014. ProQuest Historical Newspapers: Wall Street Journal (1889-1996):25.
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        ----- "Harmonic Lends 'Sunshine' To Florida P&L Meeting." Wall Street Journal (1923-Current file),

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Turkey Point Units 3 and 4 FPL Response to NRG RAI No. HC-7-a Docket Nos. 50-250 and 50-251 L-2018-169 Attachment 1 Enclosure 1 Page 30 of 30

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