L-2019-088, Subsequent License Renewal Application FPL Comments Regarding the NRC Biological Assessment

Subsequent License Renewal Application FPL Comments Regarding the NRC Biological Assessment

ML19112A023
Person / Time
Site:	Turkey Point
Issue date:	04/18/2019
From:	Maher W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2019-088
Download: ML19112A023 (14)

Text

• l=PL..

L-2019-088 10 CFR 54.17 April 18, 2019 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 Turkey Point Units 3 and 4 Subsequent License Renewal Application FPL Comments Regarding the NRC Biological Assessment

Reference:

NRC Letter to U.S. Fish and Wildlife Service dated December 19, 2018, Request for Formal Consultation Under the Endangered Species Act Regarding the Proposed Subsequent License Renewal of Turkey Point Nuclear Generating Unit Nos. 3 and 4 (ADAMS Accession Nos. ML18333A205 and ML18353A835)

With the referenced letter, the NRC provided its biological assessment (BA) to the U.S.

Fish and Wildlife Service (USFWS) to comply with the provisions of Section 7 of the Endangered Species Act, in support of the NRC staffs review of Florida Power & Light Company's (FPL's) subsequent license renewal (SLR) application for Turkey Point Units 3 and 4 (PTN 3 & 4). The NRC also requested formal consultation with the USFWS regarding the potential adverse impacts to the American crocodile and eastern indigo snake, and is seeking USFWS concurrence with its determination that continued operation of PTN 3 & 4 "may effect, but is not likely to adversely affect" an additional 13 species identified in its BA.

The purpose of this letter is to provide the attached FPL comments regarding the

• referenced BA. While FPL was not afforded the opportunity to review the BA in advance of its publication, these comments are intended now to assist USFWS' preparation of a more complete, accurate, and timely biological opinion of PTN 3 & 4 SLR.

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

Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 L-2019-088 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on April 18, 2019.

Sincerely, .

-~~-

William Maher Senior Licensing Director Florida Power & Light Company WDM/RFO

Attachment:

FPL Comments Regarding the NRG Biological Assessment (BA) cc:

Senior Resident Inspector, USNRC, Turkey Point Plant Regional Administrator, USNRC, Region II Project Manager, USNRC, Turkey Point Plant Plant Project Manager, USNRC, SLRA Plant Project Manager, USNRC, SLRA Environmental Ms. Cindy Becker, Florida Department of Health Mr. Jose Rivera, U.S. Fish and Wildlife Service

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment .(BA)

L-2019-088 Attachment Page 1 of 12 BA FPL Comment Page 1 6 The CCS was built followino the 1971 Consent Decree, not in the 1960's as stated.

6 Cooling water and process water for Unit 5 are ob_tained from Upper Floridan Aquifer saline production wells. Unit 5 does not use the cooling canals for cooling but does use the CCS for stormwater discharge and cooling tower blowdown.

7 In Fioure 2, the N-S Canal inside CCS labeled "Card Sound Canal" should be "Grand Canal."

7 The purpose of the interceptor ditch is to restrict inland movement of cooling canal water by maintaining a seaward ground water gradient during times when a natural seaward gradient does not exist. During the wet season and the early part of the dry season a natural seaward gradient usually does exist. During the rest of the year, however, it is necessary to artificially generate a seaward gradient east of the L-31 E Levee by pumping water out of the interceptor ditch. The interceptor ditch has been effective at restricting the movement of water west of the L-31 E in the uooer portions of the Biscayne Aquifer. However, at depth the interceptor ditch was less effective.

8 The marine wells are located on the Turkey Point peninsula near Biscayne Bay and obtain saline groundwater from the Biscayne aquifer only. No water is withdrawn from Biscayne Bay.

8 The 2018 Turkey Point Annual Monitoring Report water budget shows that more water leaves the CCS (13.6 MGD) than enters the CCS (6. 74 MGD). The rate of seepage and recharge varies with rainfall and water level within the canals. FPL uses the water budget as a tool for understanding how the CCS has and will operate under varying meteorological, hydrological, and operational conditions. The accurate simulation of changing CCS inflows, outflows, water elevations, and salinities is complex due to the different components of the balance model and their varying impacts on CCS water storage. Though the model is able to simulate the complex dynamics associated with the CCS over a 12-month timeframe with reasonable accuracy, there are periods of time wh~re the simulated flows of water do not accurately reflect observed conditions. The NRC incorrectly states that twice the volume of water enters the* CCS than leaves the CCS via the Biscayne aquifer. The 2018 Turkey Point Annual Monitoring Report which the NRC cites, presents information on the water budget. The calculated water budget in the 2018 report shows more water leaving the CCS through the Biscayne Aquifer than entering the system. However, the rate of seepage and recharge varies with seasonal changes in rainfall and water level, and is generally assumed to 1 Biological Assessment for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 Proposed Subsequent License Renewal, U.S. Nuclear Regulatory Commission, December 2018 (ADAMS Accession No. ML18353A835)

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 2 of 12 BA.

Page 1 ,

FPL Comm.ant be net neutral.

12 In section 4.3.2.1, the NRC misstates the genesis and objective of the MDC CA and FDEP CO stating that these agreements were, "based on the changes in water quality and concerns that water from the CCS was reaching Biscayne Bay and wetlands adjacent to the Turkey Point Site". The primary basis of the MDC CA was to acknowledge FPL's plans to reduce salinity in the CCS, and required FPL to implement actions to intercept, capture, contain, and retract hypersaline groundwater west and north of the Turkey Point CCS boundary. The principal specific objectives of the CA are for FPL: (1) to demonstrate a statistically valid reduction in salt mass and volumetric extent of the hypersaline water in groundwater west and north of FPL's property without creating adverse environmental impacts and (2) to reduce the rate of and arrest migration of hypersaline groundwater.

Frequent meetings and correspondence between FPL and MDC DERM document the continued implementation of the CA. Further, The primary objectives of the FDEP CO are to: (1) cease discharges from the CCS that impair the reasonable and beneficial use of the adjacent G-11 groundwaters west of the CCS; (2) prevent releases of groundwater from the CCS to surface waters connected to Biscayne Bay that result in exceedances of surface water quality standards in Biscayne Bay by undertaking restoration projects at Turtle Point and Barge Basin; and (3) provide mitigation to address impacts due to historic operation of the CCS. For additional information please refer to section 9.3 of the Environmental Report.

13 The NRC states in the sixth paragraph that FPL received permission from the State of Florida on June 27, 2014 to utilize portions of the Unit 5 Floridan well allocation to manage CCS temperature. Additionally, FPL received concurrence from the SFWMD that a water use permit is not required for use of water with a chloride concentration at or above 19,000 milliQrams per liter. Thus, no authorization is required to use the marine wells for the CCS.

13 The NRC states in Section 4.3.2.1 that current CCS salinity is 60 PSU. CCS salinity fluctuates throughout the year with lower salinity occurring in the wet season and higher salinity occurring during the dry season. From October 2017 to September 2018, the CCS average daily salinities ranged from a maximum of 60.5 psu on May 13, 2018 to a low of 38.8 psu on October 20, 2017. Note that very little rainfall occurred during the dry season, particularly in the first quarter of 2018, which was second driest in the 50-year historical record, based on data collected at the South Florida Water Management District (SFWMD) rain gauge S20-F. As expected, CCS salinities increased during this period. The average annual daily CCS salinity for the first full year of freshening, using the authorized UFA wells, was 50.9 psu (June 1, 2017 to May 31, 2018). This value is down from the preceding year's (June 1, 2016 to May 31, 2017) average annual salinity of 61.9 psu, durinQ which UFA fresheninQ wells were operational for

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 3 of 12 BA FPL.Comment Page 1 .

only half of the year. Considering that the highest average annual CCS salinity was 82.5 psu (June 2014 through May 2015), a substantial reduction in CCS salinity has occurred over the past several years as a result of FPL's actions.

13 The NRC states in Section 4.3.2.1 that "FDEP issued an administrative order ... ;" while this statement is true, it doesn't capture the resolution of the AO with the issuing of the FDEP CO in June 2016. On June 20, 2016, a CO was executed between FPL and the FDEP. The 2016 CO and FPL's compliance with its requirements incorporate the issues and requirements identified in the final AO. As such, the 2016 CO supersedes all requirements of the final AO and rescinds the AO. For additional information on the FPL's regulatory Orders and Agreements, please refer to section 9.3 of the Applicants Environmental Report.

15 In Section 4.3.2.1 the NRC compares CCS ammonia levels with the MDC water quality standards. Although the NRC is correct in stating that the Miami-Dade County water quality standard for ammonia is 0.5 milligrams per liter and that the CCS is below the criteria, these standards do not apply to the CCS.

15 In Section 4.3.2.1 the NRC discusses the 2014 authorization from the State of Florida (FDEP) and the SFWMD for supplemental water additions. On June 27., 2014, FPL received authorization from the FDEP Siting Office to use un-used allocation of the Unit 5 Upper Floridan water and received confirmation from the SFWMD that authorization was not required for use of Biscayne Aquifer water with chloride concentrations above 19,000 mg/L.

The supplemental water supplies were used to stabilize water quality in the CCS primarily to lower CCS salinity.

Temperature reduction alo'ne was not a primary objective of the water additions. Further the L31 E water additions that were authorized later in 2014 were primarily to control salinity in the CCS.

18 "Error! Reference source not found" error appears in section above Table 2 and on BA page 35 in the third paragraph, first sentence.

24 2nd paragraph, next to last sentence, "crab turtles" should be "crabs, turtles."

24 Replace "Florida" in "Florida crocodile" with "American."

24 The biaaest threats to nests and developing eggs includffift_es flooding, over ...

26 Regarding 3): Surveys do not always occur weekly every year. Methodology from the annual crocodile nesting report: During non-nesting/hatchling season, the survey is conducted approximately once per week. Due to the heavy workload exr;1erienced during the nesting and hatchling seasons, the ID surveys are conducted when r;1ersonnel are available.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 4 of 12 BA FPL Comment

• Page 1 26 4) and 5): These surveys have not been conducted since 1978. These are not part of the nesting and hatch ling surveys. The spatial distribution and capture surveys started as part of the uprate monitorinQ.

28 In FiQure 11, the Qraph shows throuQh 2016 but should also include 2017 data.

29 In addition to the American crocodile/wildlife training requirements for site personnel, FPL also provides training to contractors that will be workinQ in and around the CCS.

29 Comment on sentence: "At Turkey Point, FPL staff transport hatchlings from nesting to nursery habitats to increase the chances of hatchling survival (FPL 2018b)." The female croc may also bring the hatchlings to the nursery habitat, which is where the biologists will collect the hatchlings. The biologist will collect any remaining hatchlings from the nest when the female does not transfer them all.

32 Comment on this sentence: "Similarly, the number of hatchlings captured declined from 409 in 2015 to 119, 127, and 46 in 2015, 2016, and 2017, respectively (FPL 2018b)." The hatchling numbers are the numbers that are captured; this does not necessarily mean that number is the only number of hatch lings that hatched at TP. This chanQe should occur throuQhout the BA.

32 The NRC makes several statements throughout the Biological Assessment (i.e. page: 32, 34, 35, 40, 42, and 69) that the hypersaline conditions in the CCS has and will impact the American crocodile. Hypersaline is defined as an aquatic environment that is saltier than typical seawater (34 psu). Hypersaline conditions have existed in the CCS since salinity monitoring began in early 1974. In 2007/2008, while CCS salinity was approaching 70 psu, the number of successful crocodile nests and hatchlings captured reached its peak with 28 and 548, respectively. The data suggests that hypersalinity alone does not negatively affect the species. The USFWS reiterat~d this in the 2005 Biological Opinion which states, " ... the Service does not believe that the hypersaHnity of the cooling canal waters has adversely affected crocodiles or will adversely affect crocodiles in the future". The decline in crocodile nests and hatchling abundance occurred during a time when the CCS experienced overall water quality degradation. FPL continues to make progress in implementing measures that focus on improving water quality conditions in the Cooling Canal System (CCS). The following is a summary of recent actions taken and milestones achieved during October 2017 through September 2018:

• 4.5 billion gallons of low salinity Upper Floridan aquifer (UFA) water was added to the CCS to offset freshwater evaporation and lower salinity.

• Despite an unusually dry "dry season," UFA fresheninQ coupled with the return of a healthy wet season

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 5 of 12 BA FPL Comment Page 1 rainfall resulted in an annual aver-age salinity of 50.9 practical salinity units (psu) for the period of June 1, 2017, to May 31, 2018.

• Full-time operation of the approved groundwater recovery well sys-tern (RWS) began on May 15, 2018.

• Over 4.5 billion gallons of hypersaline groundwater, consisting of over 874,000 tons of salt, was removed from the Biscayne aquifer.

• Implementation of the 2016 Turkey Point Cooling Canal System Nutrient Management Plan (NMP) continued to show positive progress in reducing nitrogen and phosphorus levels in the CCS. Projects implemented under this plan include the planti_ng of three acres of seagrass and the installation of the protein skimmer devices.

FPL continues to see improvement in water quality parameters. In 2018 the American crocodile nesting season was a success. In 2018, nest numbers and hatchlings that were captured increased, compared to the previous three nesting seasons. Efforts made in 2018 to prepare the nesting locations, as well as the work done to improve the health of the CCS, led to the nesting and hatching success. This strategy will continue in 2019 and future years to maintain Turkey Point as habitat for the American crocodile.

The NRC and others have pointed to the recent increase in power production also known as the power uprate as the water quality decline. However, FPL believes it is a result of an ecosystem shift from a seagrass based system to an algae based system. Prior to 2010, the CCS operated as a sea grass based biological system with healthy sea grass (Ruppia maritima) meadows covering over 50 percent of the CCS, providing habitat, natural filtration, and utilization of nutrients from the water column. This ecosystem helped to maintain good water quality and low nutrient concentrations in the water column.

Salinity levels in the CCS have always been subject to seasonal variation, peaking at the end of the dry season (nominally July), and falling at the end of the wet season (no'minally December). Between 2000 and late 2009 the peak seasonal salinities steadily increased to close to 70 practical salinity units (psu). By 2010 sea grass meadows were stressed by the high salinities and dying off in the CCS. By 2012 few if any sea grass beds remained. The system-wide sea grass die-off and subsequent decomposition of the sea grasses, released a significant volume of the previously bound and sequestered nutrients into the CCS water column over a multi-year period.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 6 of 12 BA FPL Comment Page 1 The increase of nutrient levels in the CCS water column facilitated seasonal algae blooms, resulting in high water turbidity and generally degraded water quality. Initial reports of algae blooms date back to isolated observances in 2011 and 2012, with multiple verified events in 2013, followed by continuously elevated and sustained algae concentrations from the summer of 2014 to the present. This phenomenon initiated by increased salinities closely resembles similar events observed with the Florida Bay algal blooms in the 1980's (Zieman, et. al., 1999) and.a recent sea grass die-off event (Rudnick, 2016).

Pursuant to Paragraph 21.b of the FDEP CO, FPL submitted a Nutrient Management Plan (NMP) to FDEP on September 16, 2016. On July 7, 2017, FDEP instructed FPL to implement the NMP. The NMP is composed of three primary nutrient management strategies: active algae/nutrient removal, canal and berm maintenance, and salinity reduction and controlled flow management. Canal nutrient management actions implemented by FPL to date include: canal sediment removal, canal berm management, vegetation management, canal freshening with low-nutrient Florida aquifer and groundwater extraction. Recently, FPL has investigated methods to reduce nutrients in the CCS surface waters that would be compatible with the unique ecology and water chemistry of the CCS. These methods include:

• Chemical flocculants/coagulants, non-chemical physical removal methods, and aeration.

• Canal maintenance practices that integrate the goal of minimizing erosion and nutrient inputs from sediment and berm sources.

• A pilot foam collection and condenser system by which nutrient-rich foam can be collected and rendered to liquid for disposal.

• A field scale test planting of a total of 3 acres of Ruppia maritima at separate locations in the CCS to determine whether current conditions will support the repatriation of historic nutrient-moderating seagrass meadows in the CCS.

The measures taken by FPL have been effective in reducing nutrient concentrations in the CCS. Since reaching its peak in September 2013, semi-annual total nitrogen concentrations in the CCS canals have dropped from 15.2 mg/L to 3.6 mg/L in September 2018, with the March and September 2018 levels being the lowest measured since 2011. Total phosphorous concentrations peaked at 0.087 mg/Lin September 2014, and have declined to 0.029 mg/L by September 2018.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 7 of 12 BA FPL Comment

• Page 1 34 The NRC states, "Within the action area the hypersaline conditions in the CCS has been a consistent condition over the past several years." As discussed in detail in the BA page 32 comments, hypersaline conditions are defined as an aquatic environment that is saltier than typical seawater (34 psu). Hypersaline conditions within the CCS has existed since salinity monitoring began in early 1974. In 2007-2008, while CCS salinity was approaching 70 psu, the number of successful crocodile nests and hatchlings captured reached its peak with 28 and 548, respectively. The data suggests that hypersalinity alone does not negatively affect the species. The USFWS reiterated this in the 2005 Biological Opinion which states, " ... the Service does not believe that the hypersalinity of the cooling canal waters has adversely affected crocodiles or will adversely affect crocodiles in the future". The existence of hypersaline conditions is not a new occurrence in the CCS and salinity alone is not impacting the American crocodiles. Please see the BA page 32 comments for a detailed discussion on CCS water quality.

35 The NRC states, "The results suggest that the hypersaline water within the CCS is having an adverse impact on the health of crocodiles within the CCS." As discussed in detail in the BA page 32 comments, hypersaline conditions are defined as an aquatic environment that is saltier than typical seawater (34 psu). Hypersaline conditions within the CCS has existed since salinity monitoring began in early 1974. In 2007-2008, while CCS salinity was approaching 70 psu, the number of successful crocodile nests and hatchlings captured reached .its peak with 28 and 548, respectively. The data suggests that hypersalinity alone does not negatively affect the species. The USFWS reiterated this in the 2005 Biological Opinion which states, " ... the Service does not believe that the hypersalinity of the cooling canal waters has adversely affected crocodiles or will adversely affect crocodiles in the future". The existence of hypersaline conditions is not a new occurrence in the CCS and the salinity alone are not impacting the American crocodiles. The crocodiles that inhabit the CCS are not limited to only Turkey Point. Crocodiles are known to move in and out of the CCS to the Biscayne Bay and other surrounding habitats to forage, etc. Please see the BA paqe 32 comment for a detailed discussion on CCS water quality.

35 The NRC references Figure 13 from the 2016 Annual Report: American Crocodile Monitoring Program for the Turkey Point Uprate. The figure suggests there is a relationship between body condition and salinity. Hypersaline conditions have existed in the CCS since salinity monitoring began in 1974. The lower body condition values were observed during a time when the CCS experienced overall water quality degradation and only represented crocodiles that remained in the CCS. Crocodiles are known to move in and out of the CCS to the Biscayne Bay and other surrounding habitats to forage, etc. The cause of the water quality degradation in the CCS is complex, however FPL believes it is a result of an ecosvstem shift from a seaqrass based svstem to an algae based system.

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 8 of 12 BA r FPL Comment

~

• Page 1 For a more detailed discussion of CCS water quality and American crocodiles, please review FPL's BA page 32 comments.

36 FPL has agreed to a third additional year of monitoring for 2019.

37 The NRC makes several statements throughout the Biological Assessment (i.e. page 37 and 39) referencing the SFWMD's staff report supporting the recovery well system consumptive use permit. On page 37, the NRC states, "In conclusion, the SFWMD (2017) stated that the authorized withdrawal would impact wetlands; however, the impacts to onsite and offsite wetlands would be minimal." This is a misstatement and over simplification of the SFWMD's assessment. The SFWMD said, "the potential for harm to occur to wetlands as a result of th.e authorized withdrawal of the recommended allocation is considered minimal. While the SFWMD states the potential for harm is mi'nimal the NRC states h,um will occur, but will be minimal. This is a misstatement made several times in the report.

40 The NRC references Figure 13 from the 2016 Annual Report: American Crocodile Monitoring Program for the Turkey Point Uprate. The figure suggests there is a relationship between body condition and salinity. Hypersaline conditions have existed in the CCS since salinity monitoring began in 1974. The lower body condition values were observed during a time when the CCS experienced overall water quality degradation. The cause of the water quality degradation in the .ccs is complex, however FPL believes it is a result of an ecosystem shift from a seagrass based system to an algae based system. For a more detailed discussion of CCS water quality and American crocodiles, please review FPL's BA paQe 32 comments.

42 The NRC states, "the operation of Turkey Point Units 3&4 is contributing to changes in the CCS water quality ... "

There is no evidence that the operation of 3&4 is contributing to changes in the CCS. Please see the BA page 32 comments for a detailed discussion on the factors that contributed to the decline in CCS water quality.

42 The NRC discusses the impacts of hypersaline conditions have on American crocodile. As discussed in detail in the BA page 32 comments, hypersaline conditions are defined as an aquatic environment that is saltier than typical seawater (34 psu). Hypersaline conditions within the CCS has existed since salinity monitoring began in. early 1974. In 2007-2008, while CCS salinity was approaching 70 psu, the number of successful crocodile nests and hatchlings captured reached its peak with 28 and 548, respectively. The data suggests that hypersalinity alone does not negatively affect the species. The USFWS reiterated this in the 2005 Biological Opinion which states,

" ... the Service does not believe that the hyper-salinity of the cooling canal waters has adversely affected crocodiles or will adversely affect crocodiles in the future". The existence of hypersaline conditions is not a new occurrence in

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 9 of 12 BA

FPL Comment Page 1 the CCS and the salinity alone are not impacting the American crocodiles. Please see the BA page 32 comments for a detailed discussion on CCS water quality.

44 This statement is made several times regarding the UF report: Squires et al. (2017) determined that the maximum air temperature and maximum salinity within the CCS negatively affected body condition for crocodiles. This statement needs a global change from "air' to "water' when this report is referenced.

44 The correct permit number is TE092945-3.

45 References to the "Florida Fish and Wildlife Department" should be "Florida Fish and Wildlife Conservation Commission."

45 This incident occurred outside the action area in the Everglades Mitigation Bank and was not associated with activities related to Units 3 & 4 but was related to Ever-glades Mitigation Bank activities.

45 FPL crocodile biologists conducted the surveys, workinQ under the Orianne Society's research permit.

45 This work was not associated with the operation of Units 3 and 4, it was for work associated with the Everglades Mitigation Bank.

46 Last sentence in first full paragraph should refer to indigo snakes and not crocodiles.

46 This was a contractor vehicle associated with EMB work.

53 It is unclear what data the NRC is relying on to conclude the CCS temperature has increased and will increase in the subsequent period of operation.

57 The NRC makes several statements throughout the Biological Assessment (i.e. pages 57, 60, and 61) discussing*

the hydrologic conn~ction between the CCS and Biscayne Bay and the transfer of contaminants that may impact the West Indian manatee. While FPL agrees with the NRC's conclusion that the likelihood of manatees found in Biscayne Bay to be exposed to contaminants associated with the CCS would be limited, the information presented by the NRG to reach this conclusion does not fully capture the complex hydrogeologic conditions and sources of contaminants in Biscayne Bay.

The NRC's position that there is a groundwater connection from the CCS to Biscayne Bay which could potentially transport contaminants, including ammonia, is an oversimplification of the complex hydrogeologic conditions at Turkey Point. Groundwater data collected since 2010 from stations surrounding the CCS show, groundwater ammonia concentrations are consistently below MDC Chapter 24-44 Clean-up Target Levels (CTLs} (Section 24-

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 10 of 12 BA FPL Comment Page 1 44.(2)(f)(v) of the Code of Miami-Dade County) and as such, provide an acceptable level of protection for human health, public safety and environmental resources and are below the point at which a site rehabilitation action is determined to be accomplished (Section 24-44.(2)(a) of the Code of Miami-Dade County). Further, the average ammonia levels within the CCS canals are well below Chapter 24-42(4) surface water standards of 0.5 ppm (Source: EPU semi-annual data from 6/2010 through 3/2018: 0.33 mg/Land L-31 E weekly data from 5/31/2015 through 8/6/2018: 0.26 mg/L). Measured ammonia concentrations in several of the deep samples greatly exceeded the total nitrogen concentrations in the CCS and in groundwater beneath the CCS demonstrating that there are sources of nitrogen other than the CCS causing exceedances of county ammonia standards in the bottom of the deep canals.

As identified in FPL's Site Assessment Report (SAR), while the data cannot delineate contribution levels of groundwater underlying the CCS to the ammonia levels in surrounding waters, the SAR analysis demonstrated that for those adjacent surface water areas that exceeded the Miami-Dade limit for ammonia, the maximum contribution was 2% or less. The SAR also established that the range of contribution (including Surface Waters that met the 0.5 mg/L standard) ranged from 0.4 to 16%. Thus, if there is any contribution to ammonia concentrations in adjacent surface water from groundwater beneath the CCS, it is de minimis.

The restoration projects being implemented by FPL which include filling two remnant man-made deep-cut canals adjacent to the CCS are required by the FDEP CO. The FDEP CO states, "the Department [FDEP] ... determined that no exceedances of surface water quality standards were detected in Biscayne Bay monitoring. [The Consent Order] is intended to minimize the potential for future exceedances."

60 Following the second paragraph, the NRC states, "Thus ammonia." The sentence is incomplete and it is unclear what is intended 60 The NRC discusses the manatee exposure in Biscayne Bay to contaminants found in the CCS via a groundwater pathway. As discussed in detail in the BA page 45 comment, groundwater data collected since 2010 from stations surrounding the CCS show, groundwater ammonia concentrations are consistently below MDC Chapter 24-44 Clean-up Target Levels (CTLs) (Section 24-44.(2)(f)(v) of the Code of Miami-Dade County) and as such, provide an acceptable level of protection for human health, public safety and environmental resources and are below the point at which a site rehabilitation action is determined to be accomplished (Section 24-44.(2)(a) of the Code of Miami-

Turkey- Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 11 of 12 BA Page 1 FPL Comment Dade County). Further, the average ammonia levels within the CCS canals are well below Chapter 24-42(4) surface water standards of 0.5 ppm (Source: EPU semi-annual data from 6/2010 through 3/2018: 0.33 mg/L and L-31 E weekly data from 5/31/2015 through 8/6/2018: 0.26 mg/L). Measured ammonia concentrations in several of the deep samples greatly exceeded the total nitrogen concentrations in the CCS and in groundwater beneath the CCS demonstrating that there are sources of nitrogen other than the CCS causing exceedances of county ammonia standards in the bottom of the deep canals. Please see the BA page 45 comment for a detailed discussion on Biscayne Bay, ammonia, and impacts to the West Indian manatee.

61 The NRC discusses DERM's allegations that total ammonia concentrations have exceeded the surface water standard at several sampling locations in canals that connect to Biscayne Bay. As discussed in detail in the BA page 45 comment, groundwater data collected since 2010 from stations surrounding the CCS show, groundwater ammonia concentrations are consistently below MDC Chapter 24-44 Clean-up Target Levels (CTLs) (Section 24-44.(2)(f)(v) of the Code of Miami-Dade County) and as such, provide an acceptable level of protection for human health, public safety and environmental resources and are below the point at which a site rehabilitation action is determined to be accomplished (Section 24-44.(2)(a) of the Code of Miami-Dade County). Further, the average ammonia levels within the CCS canals are well below Chapter 24-42(4) surface water standards of 0.5 ppm (Source: EPU semi-annual data from 6/2010 through 3/2018: 0.33 mg/Land L-31 E weekly data from 5/31/2015 through 8/6/2018: 0.26 mg/L). Measured ammonia concentrations in several of the deep samples greatly exceeded the total nitrogen concentrations in the CCS and in groundwater beneath the CCS demonstrating that there are sources of nitrogen other than the CCS causing exceedances of county ammonia standards in the bottom of the deep canals. Please see the BA page 45 comment for a detailed discussion on Biscayne Bay and CCS contributions.

61 First paragraph fourth line states, "as described in." It is unclear what information is being conveyed here.

61 The NRC incorrectly states that DERM is taking action to restore water quality in the canal areas with elevated ammonia. FPL is taking action to restore the remnant man-made deep-cut canals adjacent to the CCS, by placing beach quality fill within the canals to restore the hydrology. The restoration is required by the FDEP CO which states, "the Department [FDEP] ... determined that no exceedances of surface water quality standards were detected in Biscayne Bay monitoring. [The Consent Order] is intended to minimize the potential for future exceedances."

69 The NRC discusses the impacts of hypersaline conditions have on American crocodile. As discussed in detail in the

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 FPL Comments Regarding the NRC Biological Assessment (BA)

L-2019-088 Attachment Page 12 of 12 BA FPL Comment Page 1 BA page 32 comments, hypersaline conditions are defined as an aquatic environment that is saltier than typical seawater (34 psu). Hypersaline conditions within the CCS has existed since salinity monitoring began in early 1974. In 2007-2008, while CCS salinity was approaching 70 psu, the number of successful crocodile nests and hatchlings captured reached its peak with 28 and 548, respectively. The data suggests that hypersalinity alone does not negatively affect the species. The USFWS reiterated this in the 2005 Biological Opinion which states, II

... the Service does not believe that the hyper-salinity of the cooling canal waters has adversely affected crocodiles or will adversely affect crocodiles in the future". The existence of hypersaline conditions is not a new occurrence in the CCS and the salinity alone are not impacting the American crocodiles. Please see the BA page 32 comments for a detailed discussion on GCS water quality.