L-2021-073, Environmental Protection Plan Report Request to Renew Industrial Wastewater Facility Permit

Environmental Protection Plan Report Request to Renew Industrial Wastewater Facility Permit

ML21106A131
Person / Time
Site:	Saint Lucie
Issue date:	04/16/2021
From:	Godes W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2021-073
Download: ML21106A131 (806)

Text

{{#Wiki_filter:April 16, 2021 L-2021-073 10 CFR 50.36.b EPP 3.2.4 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Environmental Protection Plan Report Request to Renew Industrial Wastewater Facility Permit The enclosure requests renewal of the St. Lucie Industrial Wastewater Facility Permit and is being submitted pursuant to the requirements of Section 3.2.4 of the St. Lucie Plant Units 1 and 2 Environmental Protection Plans. Please contact Christopher R. Martin at 772-467-7501 if there are any questions on this matter. Sincerely, Wyatt Godes Licensing Manager St. Lucie Plant WG/rcs

Enclosure:

VPPSL-2021-053, VPPSL-2021-053 Request to Renew Industrial Wastewater Facility Permit cc: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Plant Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

April 14, 2021 Mr. Marc Harris, P.E. Supervisor, Power Plant NPDES Permitting Industrial Wastewater Section Florida Department of Environmental Protection 2600 Blair Stone Road, MS 3545 Tallahassee, FL 32399-2400 RE: Florida Power & Light Company St. Lucie Power Plant Permit No. FL0002208 Industrial Waste Water Permit Renewal Application Please find enclosed the following forms and supporting documentation for the renewal of the above referenced National Pollutant Discharge Elimination System (NPDES) permit:

1. One copy of DEP Form 62-620.910(1) - Wastewater Permit Application Form 1

2. One copy of DEP Form 62-620.910(5) - Wastewater Permit Application Form 2CS

3. One copy of DEP Form 62-620.910(8) - Stormwater Permit Application Form 2F

4. One copy of Clean Water Act (CWA) Section 316(b) Compliance Submittal - Report providing information required by 40 CFR 122.21 (r)(2)-(13)

5. One copy of CWA Section 316(b) Facility Overview for the National Oceanic and Atmospheric Administration National Marine Fisheries Service (NOAA Fisheries) -

One page 316(b) facility overview, as requested by NOAA Fisheries Additional copies of the complete application will be filed electronically with the Department. The $7,500 application fee due to the Department will be processed as an electronic transaction. FPL understands that the Department will be sending an email with a unique link for the payment once this application is entered into the permitting database. Items to Note A Thermal Mixing Zone: FPL requests continuation of the Thermal Mixing Zone for heated water discharge. A Heated Water Plan of Study and Biological Plan of Study were completed and submitted to FDEP on December 12, 2014, in accordance with conditions 17 and 20, respectively, of the Administrative Order A0-0220TL. The studies are still applicable as plant operations have not changed since the studies were completed. B. Chlorine Dioxide Dilution and Decay Evaluation: In accordance with IWW Permit Condition l.A.19, a chlorine dioxide dilution and decay evaluation was completed. A copy of the report is provided in Attachment I. Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

C. Chemical List for IWW Permit Renewal: A chemical list and safety data sheets (SOS) for the chemicals currently being used at the plant are provided in Attachment II. Requested Permit Changes PSL's current permit includes certain parameters that are tested on a frequent basis during discharge. A review of historical records associated with these parameters show them well below the permitted compliance values. Therefore, FPL respectfully requests that the monitoring frequency of the following parameters be reduced in relation to their respective outfalls:

• Toxicity: Outfall D-001 - Reduce frequency from semi-annually to annually
• Nitrogen, ammonia, Total (as N); Nitrogen, Kjeldahl, Total (as N); Nitrite plus Nitrate, Total (as N); Nitrogen, Total, Phosphorus, Total (as P); Phosphate, Ortho (as P04): Outfall D-001 - Reduce frequency from quarterly to semi-annually
• Oil and Grease; Total Suspended Solids - Outfall l-005 - Reduce frequency from monthly to quarterly, while discharging.
• Total Suspended Solids; Oil and Grease - Outfall 1-008 - Reduce frequency to once every 2 months, while discharging
• Nitrogen, Total (as N); Phosphorus, Total (as P) - Outfall 1-008 - Reduce frequency to once every quarter from monthly
• Oil and Grease; Total Suspended Solids - Outfall l-009 - Reduce frequency to once every 2 months, per discharge Please contact Meghna Pandya at 561-691-307 4 if there are any questions on this matter.

Sincerely, Daniel DeBoer Site Vice President St. Lucie Plant VPPSL-2021-053 Electronic Copies provided to: Lisa Self - SEO FDEP Lisa.Self@floridadep.gov Delaney O'Brien - PSL Delaney.O'brien@fpl.com

Enclosures:

DEP Form 62-620.910(1) - Wastewater Permit Application Form 1 DEP Form 62-620.910(5) - Wastewater Permit Application Form 2CS DEP Form 62-620.910(8) - Stormwater Permit Application Form 2F Application Attachment I - Chlorine Dioxide Dilution and Decay Evaluation Application Attachment II - Chemical List and Safety Data Sheets Application Attachment Ill - September 2020 Toxicity Report Binder containing CWA 316(b) Compliance Submittal and 316(b) Facility Overview for NOAA Fisheries

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Wastewater Permit Application Form 1 DEP Form 62-620.910(1)

WASTEWATER FACILITY OR ACTIVITY PERMIT APPLICATION FORM 1 GENERAL INFORMATION I - IDENTIFICATION NUMBER: Facility ID FL0002208 II - CHARACTERISTICS: INSTRUCTIONS: Complete the questions below to determine whether you need to submit any permit application forms to the Department of Environmental Protection. If you answer "yes" to any questions, you must submit this form and the supplemental form listed in the parenthesis following the question. Mark "X" in the blank in the third column if the supplemental form is attached. If you answer "no" to each question, you need not submit any of these forms. You may answer "no" if your activity is excluded from permit requirements. See Section B of the instructions. See also, Section C of the instructions for definitions of the terms used here. SPECIFIC QUESTIONS YES NO FORM ATTACHED A. Is this facility a domestic wastewater facility which X N/A results in a discharge to surface or ground waters? B. Does or will this facility (either existing or proposed) include a concentrated animal feeding operation or aquatic animal X N/A production facility which results in a discharge to waters? C. Does or will this facility (other than those describe in A. or B.) discharge process wastewater, or non-process wastewater regulated by X Form 2CS effluent guidelines or new source performance standards, to surface waters? D. Does or will this facility (other than those described in A. or B.) X N/A discharge process wastewater to ground waters? E. Does or will this facility discharge non-process wastewater, not regulated by effluent guidelines or new source performance standards, to X N/A surface waters? F. Does or will this facility discharge non-process wastewater to X N/A ground waters? G. Does or will this facility discharge stormwater associated with X Form 2F industrial activity to surface waters? H. Is this facility a non-discharging/closed loop recycle system? X N/A I. Is this facility a public water system whose primary purpose is the production of potable water for public consumption and which discharges demineralization concentrate to surface water or X N/A groundwater? III - NAME OF FACILITY: (80 characters and spaces) FPL St. Lucie Power Plant 1-13 DEP Form 62-620.910(1) (Effective July 7, 2006)

Facility ID FL0002208 IV - FACILITY CONTACT: (A. 30 characters and spaces) A. Name and Title (Last, first, & title) B. Phone (area code & no.) Delaney O'brien, Env Specialist 772-429-7832 V - FACILITY MAILING ADDRESS: (A. 30 characters and spaces; B. 25 characters and spaces) A. Street or P.O. Box: 6501 S. Ocean Drive B. City or Town: Jensen Beach State: FL Zip Code: 34957 VI - FACILITY LOCATION: (A. 30 characters and spaces; B. 24 characters and spaces; C. 3 spaces (if known); D. 25 characters and spaces; E. 2 spaces; F. 9 spaces) A. Street, Route or Other Specific Identifier: 6501 S.Ocean Drive (South State Rd A1A) B. County Name: St. Lucie C. County Code (if known): 111 D. City or Town: Jensen Beach E. State: FL F. Zip Code: 34957 VII - SIC CODES: (4-digit, in order of priority)

1. Code #: 4911 (Specify) Electric Services 2. Code #: (Specify)

3. Code #: (Specify) 4. Code #: (Specify)

VIII - OPERATOR INFORMATION: (A. 40 characters and spaces; B. 1 character; C. 1 character (if other, specify); D. 12 characters; E. 30 characters and spaces; F. 25 characters and spaces; G. 2 characters; H. 9 characters) A. Name: Florida Power & Light Company B. Is the name in VIII A. the owner? Yes No C. Status of Operator: (code) (specify) D. Phone No.: F = Federal; S = State; P = Private; P Private 772-467-7101 O = Other; M = Public (other than F or S) E. Street or P. O. Box: 700 Universe Blvd. F. City or Town: Juno Beach G. State: FL H. Zip Code: 33408 IX - INDIAN LAND: A. Is the facility located on Indian lands? Yes No 1-14 DEP Form 62-620.910(1) (Effective July 7, 2006)

Facility ID FL0002208 X - EXISTING ENVIRONMENTAL PERMITS: A. NPDES Pennit No. B. UIC Pennit No. C. Other (specify) D. Other (specify) FL0002208 NA Air-Synthetic minor XI - MAP: Attach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility, the location of each of its existing and proposed intake and discharge structures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs, rivers and other surface water bodies in the map area. See instructions for precise requirements. XII - NATURE OF BUSINESS (provide a brief description) NAICS Code 221113- Nuclear Electric Power Generation XIII - CERTIFICATION (see instructions) I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that, based on my inquily of those persons immediately responsible for obtaining the information contained in the application, I believe that the infonnation is true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility offine and imprisonment. Daniel DeBoer A. Name (type or print) B. Signature Nuclear Site Vice President Official Title (type or print) C. Date Signed 1-15 DEP Form 62-620.910(1) (Effective July 7, 2006)

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Form 1 - Attachment Item XI. Facility Maps

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St Lucie Nuclear Power Plant

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FIGURE 1-1. REGIONAL LOCATION OF ST LUCIE NUCLEAR POWER PLANT Sources: ESRI USGS National Map Topo Basemap, ECT 2019. 1-2

N:\PRJ\FPL\316(b) Support\GIS\MXD\R Reports\Fig1-2_StLucie.mxd jcassada 3/17/2021 10:42:40 AM I 0 600 1,200 Feet r se D iffu fu s er o rt rt Di f Y-P lti po Mu l a na eC Big Mud Creek ar g ch Atlantic Ocean Dis Unit 1 Emergency Water Intake Unit 2 Intake 1 Offshore Velocity Cap Intake 2 5" Mesh Barrier Net l a na k eC 8" Barrier Net a Int 9" Barrier Net Indian River Lagoon FIGURE 1-2. SITE LAYOUT ST LUCIE NUCLEAR POWER PLANT Sources: ESRI World Imagery, 2017. 1-3

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Wastewater Permit Application Form 2CS DEP Form 62-620.910(5)

WASTEWATER APPLICATION FORM 2CS PERMIT TO DISCHARGE PROCESS WASTEWATER FROM NEW OR EXISTING INDUSTRIAL WASTEWATER FACILITIES TO SURFACE WATER DEP Form 62-620.910(5) 2CS-1 Effective November 29, 1994

FORM 2CS WASTEWATER APPLICATION FOR PERMIT TO DISCHARGE PROCESS WASTEWATER FROM NEW OR EXISTING INDUSTRIAL WASTEWATER FACILITIES TO SURFACE WATERS Facility I.D. Number: FL0002208 Please print or type information in the appropriate areas. I OUTFALL LOCATION For each outfall, list the X,Y coordinates and the name of the receiving water. (latitude/longitude to the nearest 15 seconds) A. Outfall B. Latitude C. Longitude D. Name of Receiving Water No. (list) Deg. Min. Sec. Deg. Min. Sec. D-001 27 21 05 80 14 26 Atlantic Ocean I-003 27 20 57 80 14 48 Plant Discharge Canal I-005 27 20 59 80 14 43 Plant Discharge Canal I-007 27 20 52 80 14 41 Plant Discharge Canal I-008 27 20 36 80 14 28 Plant Intake Canal II OUTFALL DESIGN A. Outfall B. Design Configuration and C. D. E. Elevation F. Receiving No. (List) Construction Materials Distance Diameter of Discharge Water Depth from shore Invert (MSL) at POD (MSL) D-001* Y-Port Diffuser Concrete Pipe 1,500 ft 12 ft -36 ft -42 +/- D-001* Multiport Diffuser Concerte Pipe 1,959-3,375 ft 16 ft -27 to -38 ft -33 to -44 ft+/- I-003 Stainless Steel Pipe <75 ft (canal) 3.5 in N/A -12 ft +/- I-005 Steam Generator Blowdown <75 ft (canal) 4 in N/A -12 ft +/- I-007 Two concrete sluiceways Units 1&2 On canal shore 3 ft +9 ft -30 ft +/- I-008 Southeast Evaporation Basin On canal shore 18 in +1 ft -30 ft +/-

• Please note that D-001 has more than one pipe discharging off-shore as indicated above.

DEP Form 62-620.910(5) 2CS-2 Effective November 29, 1994

Facility I.D. Number: FL0002208 III RECEIVING WATER INFORMATION For each surface water that will receive effluent, supply the following information: A. Name of Receiving Water B. Check One C. D. Type of Classification Receiving Water Fresh Salt or Brackish (See Ch. 62-302, (canal, river, lake, etc.) F.A.C.) Altantic Ocean III-Marine Ocean E. Minimum 7-day 10-year low flow of the receiving water at each outfall (if appropriate).

                           -N/A, the flow is tidally influenced; 7-day 10-year low flow data is not available.

F. Identify and describe the flow of effluent from each outfall to a major body of water. A suitably marked map or aerial photograph may be used. - Please see facility maps in Form 1 Attachment G. Do you request a mixing zone under Rule 62-4.244, F.A.C.? If yes, for what parameters or pollutants?

                           - Yes, a mixing zone is requested for thermal discharges.

IV FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent, and treatment units labeled to correspond to the more detailed descriptions in Item B. Construct a water balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a water balance cannot be determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount of any sources of water and any collection or treatment measures.

                           - Please see Form 2CS Attachment A for Industrial Wastewater Process Flow Diagram B. For each outfall, provide a description of:

1. All operations contributing wastewater to the effluent; including process wastewater, sanitary wastewater, cooling water, and stormwater runoff;

2. The average flow contributed by each operation; and

3. The treatment received by the wastewater.

Use the space on the next page. Continue on additional sheets, if necessary. - Please see Form 2CS Attachment B for additional information on major processes and associated wastestreams. DEP Form 62-620.910(5) 2CS-3 Effective November 29, 1994

V B. Contd. Facility I.D. Number: FL0002208 (1) (2) Operation(s) Contributing Flow (3) Treatment Outfall No. (a) Operation (list) (b) Avg. Flow & (a) Description (b) List Code from (List) Units Table 2CS-1 D-001 Unit 1 & Unit 2 Once-through 1,469 MGD Discharge to Surface Water 4-A, 4-B Cooling Water (OTCW) and Auxiliary Equipment Cooling Avg Daily Max Screening 1-T Water (AECW) Combined (2015-2020) Chlorination (Biofouling control) XX Discharge I-003 Low Level Waste 0.013 MGD Avg Filtration (Fiber cartidge) XX (2015-2020) Ion Exchange 2-J Discharge to Surface Water 4-A I-005 Steam Generator Blowdown 0.176 MGD Avg Reverse Osmosis I-S (2015-2020) Neutralization 2-K Discharge to Surface Water 4-A I-007 Intake Screen Wash 0.11 MGD Screening I-T Discharge to Surface Water 4-A I-008 Southeast Evaporation Basin 0.573 MGD Avg Sedimentation (Settling) I-U (2015-2020) Evaporation I-F Percolation 1-Y Discharge to Surface Water 4-A DEP Form 62-620.910(5) 2CS-4 Effective November 29, 1994

IV Contd. Facility I.D. Number: FL0002208 C. Except for storm runoff, leaks, or spills, are any of the discharges described in Items II-A or B intermittent or seasonal? Yes (complete the following table) No (go to D. below) (3) Frequency (4) Flow (1) Outfall (2)Operation(s) (a) Days (b) (a) Flow Rate (b) Total Volume No. (List) Contributing Flow(List) per Week Months (in mgd) (specify with units) (c) per Yr. Duration (specify (specify Long Term Max. Daily Long Max. (in days) avg.) avg.) Avg. Term Daily Avg. I-003 Low Level Waste 1 12 0.003 0.04 0.003 MG 0.04 MG <1 (2020 Avg) (Feb 2020) I-005 Steam Generator Blowdown 0.25 12 0.255 0.49 0.255 MG 0.49 MG <1 (2020 Avg) (Oct 2020) I-007 Intake Screen Washwater 7 12 0.11 0.11 0.019 MG 0.011 MG 0.17 I-008 SE Evaporation/Percolation <4 12 0.295 4.03 1.18 MG 4.03 MG 4(as reqd) Basin (2020 Avg) (Jul 2020) D. Describe practices to be followed to ensure adequate wastewater treatment during emergencies such as power loss and equipment failures causing shutdown of pollution abatement equipment of the proposed/permitted facilities.

                           - Please see Form 2CS Attachment B E. List the method(s) and location(s) of flow measurement. - Please see Form 2CS Attachment B V PRODUCTION A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?

Yes (complete Item V-B) No (go to Section VI) B. Are the limitations in the applicable guideline expressed in terms of production (or other measure of operation)? Yes (complete Item V-C) No (go to Section VI) C. If you answered "yes" to Item V-B, list the quantity which represents an actual measurement of your level of production, expressed in the terms and units used in the applicable effluent guideline, and indicate the affected outfalls.

1. AVERAGE DAILY PRODUCTION 2. Affected Outfalls

a. Quantity per Day b. Units of Measure c. Operation, Product, Materials, Etc. (specify) (list outfall nos.)

N/A N/A N/A N/A DEP Form 62-620.910(5) 2CS-5 Effective November 29, 1994

Facility I.D. Number: FL0002208 VI IMPROVEMENTS A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operation of wastewater treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited to, permit conditions, administrative or enforcement order, enforcement compliance schedule letter, stipulations, court orders, and grant or loan conditions. Yes (complete the following table) No (go to Item VI-B)

1. Identification of Condition, 2. Affected Outfalls 3. Brief Description 4. Final Compliance Date Agreement, Etc. a. No. b. Source of Discharge of Project a. Required B. Projected B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or planned schedules for construction.

Mark "X" if description of additional control programs is attached. VII INTAKE AND EFFLUENT CHARACTERISTICS A, B, & C: See instructions before proceeding--Complete one set of tables for each outfall -- Annotate the outfall number in the space provided. NOTE: Tables VII-A, VII-B, and VII-C are included on separate sheets number VII-1 through VII-9. D. Use the space below to list any of the pollutants listed in Table 2CS-3 of the instructions, which you know or have reason to believe is discharged or may be discharged from any outfall. For every pollutant you list, briefly describe the reasons you believe it to be present and report any analytical data in your possession.

1. Pollutant 2. Source 1. Pollutant 2. Source N/A N/A N/A N/A DEP Form 62-620.910(5) 2CS-6 Effective November 29, 1994

Facility I.D. Number: FL0002208 VIII POTENTIAL DISCHARGES NOT COVERED BY ANALYSIS Is any pollutant listed in Item VII-C a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or by-product? YES (list all such pollutants below) NO (go to IX) IX BIOLOGICAL TOXICITY TESTING DATA Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last 3 years? YES (identify the test(s) and describe their purposes below) NO (go to Section X) In accordance with the permit requirements for Outfall D-001, Chronic Whole Effluent Toxicity, 7-Day IC25 Mysidopsis bahia and Menidia beryllina tests have been performed semi-annually within the last three years. The results indicate that the samples provided did not exhibit chronic toxicity to either species. A copy of the most recent test report is included in Application Attachment III. X CONTRACT ANALYSIS INFORMATION Were any of the analyses reported in Item VII performed by a contract laboratory or consulting firm? YES (list the name, address, telephone number, and certification number of, and pollutants analyzed by each such laboratory or firm below) NO (go to Section XI) A. Name B. Address C. Telephone D. Pollutants Analyzed (list) (area code & no.) Eurofins TestAmerica, Tampa 6712 Benjamin Road Suite 100 813-885-7427 All Priority Pollutants Tampa, FL 33634 DEP Form 62-620.910(5) 2CS-7 Effective November 29, 1994

Facility I.D. Number: FL0002208 XI CONNECTION TO REGIONAL POTW A. Indicate the relationship between this project and area regional planning for wastewater treatment. List steps to be taken for this industrial wastewater facility to become part of an area-wide wastewater treatment system. There are currently no plans to integrate this facility into an area-wide wastewater treatment system. XII-A CERTIFICATIONS FOR NEW OR MODIFIED FACILITIES This is to certify the engineering features of this pollution control project have been designed by me and found to be in conformity with sound engineering principles, applicable to the treatment and disposal of pollutants characterized in the permit application. There is reasonable assurance, in my professional judgment, that the pollution control facilities, when properly maintained and operated, will discharge an effluent that complies with all applicable statutes of the State of Florida and the rules of the Department. It is also agreed that the undersigned, if authorized by the owner, will furnish the applicant a set of instructions for the proper maintenance and operation of the pollution control facilities and, if applicable, pollution sources. Signature Company Name Address Name (please type) (Affix Seal) Florida Registration No.: Telephone No:: Date I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name & Official Title (Please type or print) Signature Telephone No. (area code & No.) Date Signed DEP Form 62-620.910(5) 2CS-8 Effective November 29, 1994

XII-B CERTIFICATIONS FOR PERMIT RENEWALS This is to certify the engineering features of this pollution control project have been examined by me and found to be in conformity with sound engineering principles, applicable to the treatment and disposal of pollutants characterized in the permit application. There is reasonable assurance, in my professional judgment, that the pollution control facilities, when properly maintained and operated, will discharge an effluent that complies with all applicable statutes of the State of Florida and the rules of the Department. Florida Power and Light Company Signature Company Name Address: 700 Universe Blvd Juno Beach, FL 33408 Florida Registration No.: _7""'0. _.7""'1...4_ _ _ _ _ _ _ _ _ __ Telephone No: 561-694-3185

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Date: '3 /15' /.?o21 I certify under penaf tY W that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belie~ true, accurate, and complete. I am aware that there are significant penalties for submitting false infonnation, including the possibility of fine and imprisonment for knowing violations. Daniel DeBoer, N Site VP - St. Lucie Power Plant O~IJ.O~ Name & Official Title (Please type or print) Signature 772-467-7100 '1 /1 l.f /~I Telephone No. (area code & No.) Date Signed DEPFonn 62-620.910(5) 2CS-9 Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. D-001 PLEASE PRINT OR TYPE ONLY: You may report some or all of this information on separate sheets instead of completing these pages. Use the same format. SEE INSTRUCTIONS. VII. INTAKE AND EFFLUENT CHARACTERISTICS PART A - You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.

1. 2. Effluent 3.. Units 4. Intake (optional)

Pollutant a. Max. Daily Value b. Max. 30-day Value c. Annual Avg. Value d. No. of a. Concentration b. Mass a. Long Term Avg. Value b. No. of (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass Analyses (1) Conc. (2) Mass Analyses a.Carbonaceous Biochemical <2 <24517.6 1 mg/L lbs/day Oxygen Demand (CBOD)

b. Chemical Oxygen <50 <612940 1 mg/L lbs/day Demand (COD)

c. Total Organic 0.99I 12136 1 mg/L lbs/day Carbon (TOC)

d. Total Suspended 10 122588 1 mg/L lbs/day Solids (TSS)

e. Total Nitrogen (as N) 0.43 5271 1 mg/L lbs/day

f. Total Phosphorus (as P) 0.011 135 1 mg/L lbs/day

g. Ammonia (as N) <0.10 <1226 1 mg/L lbs/day

h. Flow - actual or 1469 MGD Value Value 1 mgd 1 mg/L projected

i. Flow - design Value Value 1 1 mg/L

j. Specific Conductivity Value 56000 Value Value 1 umhos/cm 1 mg/L

k. Temperature (winter) Value N/A Value Value 1 C Value 1

l. Temperature (summer) Value Value Value 1 C Value 1

m. pH Min. 8.2 Max. Min. Max. 1 STANDARD UNITS PART B - Mark "X" in column 2a for each pollutant you know or have reason to believe is present. Mark "X" in column 2b for each pollutant you believe to be absent. If you mark column 2a for any pollutant which is limited either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant. For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additonal details and requirements.

2. Mark "X" 3. Effluent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. be- b. be a. Maximum Daily b. Max. 30-day Value c. Long Term Avg. d. No. of a. Conc. b. Mass a. Long Term Avg. b. No. of No. (if available) lieved lieved Value (if available) Value (if available) Analyses Value Analyses present absent (1) Conc... (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass

a. Bromide (24949-67-9)

b. Chlorine, Total Residual

c. Color <5 NA p.c.u

d. Fecal Coliform <1 NA cfu/100mL

e. Fluoride 1.1 13485 1 mg/L lbs/day (16984-48-8)

f. Nitrate-Nitrite <0.054 <662 1 mg/L lbs/day (as N)

VII-1 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Item VII-B Contd. Facility ID. Number: FL0002208 Outfall No. D-001

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. .be- b. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) lieved lieved (if available) (if available) Analyses Analyses present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass

g. Nitrogen, Total 0.43 5271 Organic (as N)

h. Oil and grease 1.4 I 17162 1 mg/L

i. Phosphorus, Total 0.11 135 1 mg/L (as P) (7723-14-0)

j. Radioactivity (1) Alpha, Total (2) Beta, Total (3) Radium, Total (4) Radium 226, Total

k. Sulfate (as SO4 ) 2900 35550535 1 mg/L lbs/day 2900 (14808-79-8)

l. Sulfide (as S) <0.057 <699 1 mg/L lbs/day <0.057

m. Sulfite (as SO3 )

(14265-45-3)

n. Surfactants

o. Aluminum, Total 0.016 196 1 mg/L lbs/day 0.014 (7429-90-5)

p. Barium, Total 0.0067 82 1 mg/L lbs/day 0.007 (7440-39-3)

q. Boron, Total 4.6 56390 1 mg/L lbs/day 5 (7440-42-8)

r. Cobalt, Total 0.0005 6 1 mg/L lbs/day 0.0005 (7440-48-4)

s. Iron, Total 0.061 748 1 mg/L lbs/day 0.061 (7439-89-6)

t. Maagnesium, Total 1300 15936447 1 mg/L lbs/day 1500 (7439-95-4)

u. Molybdenum, Total 0.012 147 1 mg/L lbs/day 0.012 (7439-98-7)

v. Manganese, Total 0.0027 33 1 mg/L lbs/day 0.0025 (7439-96-5)

w. Tin, Total (7440-31-5)

x. Titanium, Total (7440-32-6)

I- The reported value is between the lab MDL and lab PQL, J3- Esitmated value. Spike recovery or RPD outside of critera, U/<- Indicates the compound was analyzed for but not detected, V-indicates the analyte was detected at or above the MDL in both samples and associated blank VII-2 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. D-001 PART C - If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you must test for. Mark "X" in column 2a for all GC/MS mark "X" in column 2b for each pollutant you know or have reason to believe is present. Mark "X" in column 2c for each pollutant you believe is absent. If you mark column 2a for any pollutant, you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant, you mus fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2a (secondary industries, non-process wastewater outfalls, and non-required GC/MS fractions), t provide the results of at least one anlysis for that pollutnat if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4,dinitrophenol, or 2-methyl-4,6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements.

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony, Total <0.0004 <4.9 1 mg/L lbs/day <0.0004 (7440-36-0) 2M. Arsenic, Total 0.02 245 1 mg/L lbs/day 0.017 (7723-14-0) 3M. Beryllium, Total <0.00015 <1.8 1 mg/L lbs/day <0.00015 (7440-41-7) 4M. Cadmium, Total <0.000043 <0.5 1 mg/L lbs/day <0.000043 (7440-43-9) 5M. Chromium, Total 0.001 I 12 1 mg/L lbs/day <0.001 (7440-47-3) 6M. Copper, Total 0.083 1018 1 mg/L lbs/day 0.084 (7440-50-8) 7M. Lead, Total <0.00006 <0.7 1 mg/L lbs/day <0.00006 (7439-92-1) 8M. Mercury, Total 0.0000012 0.015 1 mg/L lbs/day 0.0000005 I (7439-97-6) 9M. Nickel, Total 0.013 159 1 mg/L lbs/day 0.013 (7440-02-0) 10M. Selenium, Total 0.061 748 1 mg/L lbs/day 0.052 (7782-49-2) 11M. Silver, Total <0.0001 <1.2 1 mg/L lbs/day <0.0001 (7440-22-4) 12M. Thallium, Total <0.0001 1.2 1 mg/L lbs/day <0.0001 (7440-28-0) 13M. Zinc, Total 0.0056 I 68.6 1 mg/L lbs/day 0.0053 I (7440-66-6) 14M. Cyanide, Total <0.0025 30.6 1 mg/L lbs/day <0.0025 (57-12-5) 15M. Phenols, Total <0.0019 23 1 mg/L lbs/day <0.0019 DIOXIN 2,3,7,8-Tetra-chlorodibenzo-P-Dioxin (1764-01-6)

GC/MS FRACTION -VOLATILE COMPOUNDS 1V. Acrolein <0.0051 <62.5 2 mg/L lbs/day <0.0051 (107-02-8) 2V. Acrylonitrile <0.0029 <35.6 2 mg/L lbs/day <0.0029 (107-13-1) VII-3 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. D-001

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass GC/MS FRACTION - VOLATILE COMPOUNDS (continued) 3V. Benzene <0.00025 <3.1 2 mg/L lbs/day <0.00025 (71-43-2) 4V. Bis (Chloromethyl) Ether <0.0001 <12 2 mg/L lbs/day <0.0001 (542-88-1) 5V. Bromoform <0.0011 <13.5 2 mg/L lbs/day <0.0011 (75-25-2) 6V. Carbon Tetrachloride <0.0002 <3 2 mg/L lbs/day <0.0002 (56-23-5) 7V Chlorobenzene <0.0003 <3 2 mg/L lbs/day <0.0003 (108-90-7) 8V. Chlorodi- <0.0003 <4 2 mg/L lbs/day <0.0003 bromomethane (124-8-1) 9V. Chloroethane <0.0025 <31 2 mg/L lbs/day <0.0025 (74-00-3) 10V. 2-Chloro-ethylvinyl <0.001 <12 2 mg/L lbs/day <0.001 Ether (110-75-8) 11V. Chloroform <0.0003 <4 2 mg/L lbs/day <0.0003 (67-86-3) 12V. Dichloro- <0.0003 <4 2 mg/L lbs/day <0.0003 bromomethane (75-24-4) 13V. Dichloro- <0.0025 <30.6 2 mg/L lbs/day <0.0025 difluoromethane (75-71-8) 14V. 1,1-Dichloroethane <0.00032 <3.9 2 mg/L lbs/day <0.00032 (75-34-3) 15V. 1,2-Dichloroethane <0.00031 <3.8 2 mg/L lbs/day <0.00031 (107-06-2) 16V. 1,1-Dichloroethylene <0.0003 <4 2 mg/L lbs/day <0.0003 (75-35-4) 17V. 1,2,-Dichloropropane <0.00052 <6.4 2 mg/L lbs/day <0.00052 (78-87-5) 18V. 1,3-Dichloropropylene <0.0002 <3 2 mg/L lbs/day <0.0002 (542-75-6) 19V. Ethylbenzene <0.00027 <3.3 2 mg/L lbs/day <0.00027 (100-41-4) 20V. Methyl Bromide <0.0025 <31 2 mg/L lbs/day <0.0025 (74-83-9) 21V. Methyl Chloride (74-87-3) 22V. Methylene Chloride <0.0014 <17 2 mg/L lbs/day <0.0014 (74-98-2) 23V. 1,1,2,2-Tetra- <0.00017 <2 2 mg/L lbs/day <0.0002 chloroethane (79-34-5) 24V. Tetrachloroethylene <0.0004 <5 2 mg/L lbs/day <0.0004 (127-18-4)

VII-4 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. D-001

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass GC/MS FRACTION - VOLATILE COMPOUNDS (continued) 25V. Toluene (108-88-3) <0.00024 <3 2 mg/L lbs/day <0.00024 26V. 1,2-Trans- <0.0004 <5 2 mg/L lbs/day <0.0004 Dichloroethylene (156-60-5) 27V. 1,1,2-Trichloroethane <0.0003 <4 2 mg/L lbs/day <0.0003 (71-55-6) 28V. 1,1,2-Trichloroethane <0.0003 <4 2 mg/L lbs/day <0.0003 (79-00-5) 29V. Trichloroethylene <0.0004 <5 2 mg/L lbs/day <0.0004 (79-01-6) 30V. Trichloro- <0.0005 <6 2 mg/L lbs/day <0.0005 fluoromethane (75-69-4) 31V. Vinyl Chloride <0.0002 <3 2 mg/L lbs/day <0.0002 (75-01-4) 1A. 2-Chlorophenol <0.0019 <23.3 1 mg/L lbs/day <0.0019 (95-57-8) 2A. 2,4-Dichlorophenol <0.0006 <7 1 mg/L lbs/day <0.0006 (120-83-2) 3A. 2,4-Dimethylphenol <0.0005 <7 1 mg/L lbs/day <0.0005 (105-67-9) 4A. 4,6-Dinitro-O-Cresol <0.004 <45 1 mg/L lbs/day <0.004 (534-53-1) 5A. 2,4-Dinitrophenol <0.0094 <115 1 mg/L lbs/day <0.0093 (51-28-5) 6A. 2-Nitrophenol <0.0004 <4 1 mg/L lbs/day <0.0004 (88-75-5) 7A. 4-Nitrophenol <0.001 <15 1 mg/L lbs/day <0.001 (100-02-7) 8A P-Chloro-M-Cresol <0.0003 <4 1 mg/L lbs/day <0.0003 (59-50-7) 9A Pentachlorophenol <0.02 <233 1 mg/L lbs/day <0.02 (87-86-5) 10A Phenol <0.002 <23 1 mg/L lbs/day <0.002 (108-95-2) 11A 2,4,5-Trichloro- <0.0003 <3 1 mg/L lbs/day <0.0003 phenol (88-06-2) 1B. Acenaphthene <0.0003 <3 1 mg/L lbs/day <0.0003 (63-32-9) 2B. Acenaphtylene <0.0005 <6 1 mg/L lbs/day <0.0005 (208-96-8) 3B. Anthracene <0.0004 <5 1 mg/L lbs/day <0.0004 (120-12-7) 4B. Benzidine <0.047 <576 1 mg/L lbs/day <0.047 (92-87-5)

VII-5 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. D-001

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 5B. Benzo (a) Anthracene <0.0003 <4 1 mg/L lbs/day <0.0003 (56-55-3) 6B. Benzo (a) Pyrene <0.0003 <4 1 mg/L lbs/day <0.0003 (50-32-8) 7B. 3,4-Benzo-fluoranthene <0.0005 <6 1 mg/L lbs/day <0.0005 (205-99-2) 8B. Benzo (ghi) Perylene <0.0005 <6 1 mg/L lbs/day <0.0005 (191-24-2) 9B. Benzo (k) Fluoranthene (207- <0.0005 <6 1 mg/L lbs/day <0.0005 08-9) 10B. Bis (2-Chloroethoxy) <0.001 <11 1 mg/L lbs/day <0.001 Methane (111-91-1) 11B. Bis (2-chloroethyl) <0.0008 <10 1 mg/L lbs/day <0.0008 Ether (111-44-4) 12B. Bis (2-Chloroisopropyl) <0.0003 <3 1 mg/L lbs/day <0.0003 Ether (102-60-1) 13B. Bis (2-Ethylhexyl) <0.0005 <6 1 mg/L lbs/day <0.0005 Phthalate (117-81-7) 14B. 4-Bromophenyl <0.0004 <5 1 mg/L lbs/day <0.0004 Phenyl Ether (101-55-3) 15B Butyl Benzyl Phthalate <0.001 <12 1 mg/L lbs/day <0.001 (84-68-7) 16B. 2-Chloronaphthalene <0.0002 <3 1 mg/L lbs/day <0.0002 (91-58-7) 17B. 4-Chlorophenyl <0.0016 <19.6 1 mg/L lbs/day <0.0015 Phenyl Ether (7005-72-3) 18B. Chrysene <0.0005 <6 1 mg/L lbs/day <0.0005 (218-01-9) 19B. Dibenzo (a,h) <0.0005 <6 1 mg/L lbs/day <0.0005 Anthracene (53-70-3) 20B. 1,2-Dichlorobenzene <0.0002 <3 2 mg/L lbs/day <0.0002 (95-50-1) 21B. 1,3-Dichlorobenzene <0.0003 <3 2 mg/L lbs/day <0.0003 (541-73-1) 22B. 1,4-Dichlorobenzene <0.0002 <3 2 mg/L lbs/day <0.0002 (106-46-7) 23B. 3,3'-Dichlorobenzidine <0.002 <23 1 mg/L lbs/day <0.002 (92-94-1) 24B. Diethyl Phthalate <0.0004 <4 1 mg/L lbs/day <0.0004 (84-66-2) 25B. Dimethyl Phthalate <0.0002 <3 1 mg/L lbs/day <0.0002 (131-11-3) 26B. Di-N-Butyl Phthalate <0.0003 <4 1 mg/L lbs/day <0.0003 (84-74-2) 27B. 2,4-Dinitrotoluene <0.002 <20 1 mg/L lbs/day <0.002 (121-14-2) 28B. 2,6-Dinitrotoluene <0.002 <22 1 mg/L lbs/day <0.002 (606-20-2)

VII-6 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. D-001

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 29B. Di-N-Octyl Phthalate <0.0003 <4 1 mg/L lbs/day <0.0003 (117-84-0) 30B. 1,2-Diphenylhydrazine <0.0002 <3 1 mg/L lbs/day <0.0002 (as Azobenzene) (122-66-7) 31B. Fluoranthene <0.0002 <2 1 mg/L lbs/day <0.0002 (206-44-0) 32B. Fluorene (86-73-7) <0.0003 <4 1 mg/L lbs/day <0.0003 33B. Hexachlorobenzene <0.0006 <8 1 mg/L lbs/day <0.0006 (118-74-1) 34B. Hexachlorobutadiene <0.003 <38 1 mg/L lbs/day <0.003 (87-68-3) 35B. Hexachlorocyclopentadiene <0.003 <36 1 mg/L lbs/day <0.003 (77-47-4) 36B. Hexachloroethane <0.0009 <11 1 mg/L lbs/day <0.0009 (67-72-1) 37B. Indeno (1,2,3-cd) <0.0006 <8 1 mg/L lbs/day <0.0006 Pyrene (193-39-5) 38B. Isophorone <0.0002 <3 1 mg/L lbs/day <0.0002 (78-59-1) 39B. Naphthalene <0.0003 <3 1 mg/L lbs/day <0.0003 (91-20-3) 40B. Nitrobenzene <0.0008 <9 1 mg/L lbs/day <0.0008 (98-95-9) 41B N-Nitrosodimethylamine <0.0003 <3 1 mg/L lbs/day <0.0003 (62-75-9) 42B. N-Nitrosodi-N- <0.0003 <4 1 mg/L lbs/day <0.0003 Propylamine (621-64-7) 43B. N-Nitro- <0.0003 <3 1 mg/L lbs/day <0.0003 sodiphenylamine (86-30-6) 44B Phenanthrene <0.0002 <3 1 mg/L lbs/day <0.0002 (85-01-8) 45B. Pyrene (129-00-0) <0.0004 <4 1 mg/L lbs/day <0.0004 46B. 1,2,4-Trichlorobenzene <0.0006 <6 1 mg/L lbs/day <0.0006 (120-82-1)

GC/MS FRACTION - PESTICIDES 1P. Aldrin (309-00-2) 2P. -BHC (319-84-6) 3P -BHC (319-85-7) 4P. -BHC (58-89-9) 5P. -BHC (319-86-8) VII-7 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. D-001

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 6P. Chlordane (57-74-9) 7P. 4,4'-DDT (50-29-3) 8P. 4,4'-DDE (72-55-9) 9P. 4,4'-DDD (72-54-8) 10P. Dieldrin (60-57-1) 11P. -Endosulfan (115-29-7) 12P. -Endosulfan (115-29-7) 13P. Endosulfan Sulfate (1031-07-8) 14P. Endrin (72-20-8) 15P. Endrin Aldehyde (7421-92-4) 16P. Heptachlor (76-44-8) 17P. Heptachlor Epoxide (1024-57-3) 18P. PCB-1242 (53469-21-9) 19P. PCB-1254 (11097-69-1) 20P. PCB-1221 (11104-28-2) 21P. PCB-1232 (11141-16-5) 22P. PCB-1248 (12672-29-6) 23P. PCB-1260 (11096-82-5) 24P. PCB-1016 (12674-11-2) 25P. Toxaphene (8001-35-2)

VII-8 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-005 PLEASE PRINT OR TYPE ONLY: You may report some or all of this information on separate sheets instead of completing these pages. Use the same format. SEE INSTRUCTIONS. VII. INTAKE AND EFFLUENT CHARACTERISTICS PART A - You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.

1. 2. Effluent 3.. Units 4. Intake (optional)

Pollutant a. Max. Daily Value b. Max. 30-day Value c. Annual Avg. Value d. No. of a. Concentration b. Mass a. Long Term Avg. Value b. No. of (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass Analyses (1) Conc. (2) Mass Analyses a.Carbonaceous Biochemical NA NA Oxygen Demand (CBOD)

b. Chemical Oxygen NA NA Demand (COD)

c. Total Organic NA NA Carbon (TOC)

d. Total Suspended <1.3 <1.9 1 mg/L lbs/day Solids (TSS)

e. Total Nitrogen (as N) NA NA mg/L lbs/day

f. Total Phosphorus (as P) NA NA mg/L lbs/day

g. Ammonia (as N) NA NA mg/L lbs/day

h. Flow - actual or Value 0.176 mgd annual Value Value mgd mg/L projected avg.

i. Flow - design Value NA Value Value mg/L

j. Specific Conductivity Value Value Value umhos/cm mg/L

k. Temperature (winter) Value Value Value C Value

l. Temperature (summer) Value Value Value C Value

m. . pH Min. Max. Min. Max. STANDARD UNITS PART B - Mark "X" in column 2a for each pollutant you know or have reason to believe is present. Mark "X" in column 2b for each pollutant you believe to be absent. If you mark column 2a for any pollutant which is limited either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant. For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additonal details and requirements.

2. Mark "X" 3. Effluent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. be- b. be a. Maximum Daily b. Max. 30-day Value c. Long Term Avg. d. No. of a. Conc. b. Mass a. Long Term Avg. b. No. of No. (if available) lieved lieved Value (if available) Value (if available) Analyses Value Analyses present absent (1) Conc... (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass

a. Bromide Monitoring MNR (24949-67-9) not required

b. Chlorine, MNR MNR Total Residual

c. Color MNR MNR

d. Fecal Coliform MNR MNR

e. Fluoride MNR MNR (16984-48-8)

f. Nitrate-Nitrite MNR MNR (as N)

VII-9 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Item VII-B Contd. Facility ID. Number: FL0002208 Outfall No. I-005

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. .be- b. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) lieved lieved (if available) (if available) Analyses Analyses present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass

g. Nitrogen, Total MNR MNR Organic (as N)

h. Oil and grease 1.6I 2.35 mg/L lbs/day

i. Phosphorus, Total MNR MNR (as P) (7723-14-0)

j. Radioactivity (1) Alpha, Total MNR MNR (2) Beta, Total MNR MNR (3) Radium, Total MNR MNR (4) Radium 226, Total MNR MNR

k. Sulfate (as SO4 ) MNR MNR (14808-79-8)

l. Sulfide (as S) MNR MNR

m. Sulfite (as SO3 ) MNR MNR (14265-45-3)

n. Surfactants MNR MNR

o. Aluminum, Total MNR MNR (7429-90-5)

p. Barium, Total MNR MNR (7440-39-3)

q. Boron, Total MNR MNR (7440-42-8)

r. Cobalt, Total MNR MNR (7440-48-4)

s. Iron, Total MNR MNR (7439-89-6)

t. Maagnesium, Total MNR MNR (7439-95-4)

u. Molybdenum, Total MNR MNR (7439-98-7)

v. Manganese, Total MNR MNR (7439-96-5)

w. Tin, Total MNR MNR (7440-31-5)

x. Titanium, Total MNR MNR (7440-32-6)

VII-10 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-005 PART C - If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you must test for. Mark "X" in column 2a for all GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2a (secondary industries, non-process wastewater outfalls, and non-required GC/MS fractions), mark "X" in column 2b for each pollutant you know or have reason to believe is present. Mark "X" in column 2c for each pollutant you believe is absent. If you mark column 2a for any pollutant, you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant, you must provide the results of at least one anlysis for that pollutnat if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4,dinitrophenol, or 2-methyl-4,6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements.

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony, Total MNR MNR (7440-36-0) 2M. Arsenic, Total MNR MNR (7723-14-0) 3M. Beryllium, Total MNR MNR (7440-41-7) 4M. Cadmium, Total MNR MNR (7440-43-9) 5M. Chromium, Total MNR MNR (7440-47-3) 6M. Copper, Total MNR MNR (7440-50-8) 7M. Lead, Total MNR MNR (7439-92-1) 8M. Mercury, Total MNR MNR (7439-97-6) 9M. Nickel, Total MNR MNR (7440-02-0) 10M. Selenium, Total MNR MNR (7782-49-2) 11M. Silver, Total MNR MNR (7440-22-4) 12M. Thallium, Total MNR MNR (7440-28-0) 13M. Zinc, Total MNR MNR (7440-66-6) 14M. Cyanide, Total MNR MNR (57-12-5) 15M. Phenols, Total MNR MNR 2,3,7,8-Tetra- MNR MNR chlorodibenzo-P-Dioxin (1764-01-6) 1V. Acrolein MNR MNR (107-02-8) 2V. Acrylonitrile MNR MNR (107-13-1)

VII-11 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. FL0002208 Outfall No. I-005

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass GC/MS FRACTION - VOLATILE COMPOUNDS (continued) 3V. Benzene MNR MNR (71-43-2) 4V. Bis (Chloromethyl) Ether MNR MNR (542-88-1) 5V. Bromoform MNR MNR (75-25-2) 6V. Carbon Tetrachloride MNR MNR (56-23-5) 7V Chlorobenzene MNR MNR (108-90-7) 8V. Chlorodi- MNR MNR bromomethane (124-8-1) 9V. Chloroethane MNR MNR (74-00-3) 10V. 2-Chloro-ethylvinyl MNR MNR Ether (110-75-8) 11V. Chloroform MNR MNR (67-86-3) 12V. Dichloro- MNR MNR bromomethane (75-24-4) 13V. Dichloro- MNR MNR difluoromethane (75-71-8) 14V. 1,1-Dichloroethane MNR MNR (75-34-3) 15V. 1,2-Dichloroethane MNR MNR (107-06-2) 16V. 1,1-Dichloroethylene MNR MNR (75-35-4) 17V. 1,2,-Dichloropropane MNR MNR (78-87-5) 18V. 1,3-Dichloropropylene MNR MNR (542-75-6) 19V. Ethylbenzene MNR MNR (100-41-4) 20V. Methyl Bromide MNR MNR (74-83-9) 21V. Methyl Chloride MNR MNR (74-87-3) 22V. Methylene Chloride MNR MNR (74-98-2) 23V. 1,1,2,2-Tetra- MNR MNR chloroethane (79-34-5) 24V. Tetrachloroethylene MNR MNR (127-18-4)

VII-12 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-005

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass GC/MS FRACTION - VOLATILE COMPOUNDS (continued) 25V. Toluene (108-88-3) MNR MNR 26V. 1,2-Trans- MNR MNR Dichloroethylene (156-60-5) 27V. 1,1,2-Trichloroethane MNR MNR (71-55-6) 28V. 1,1,2-Trichloroethane MNR MNR (79-00-5) 29V. Trichloroethylene MNR MNR (79-01-6) 30V. Trichloro- MNR MNR fluoromethane (75-69-4) 31V. Vinyl Chloride MNR MNR (75-01-4) 1A. 2-Chlorophenol MNR MNR (95-57-8) 2A. 2,4-Dichlorophenol MNR MNR (120-83-2) 3A. 2,4-Dimethylphenol MNR MNR (105-67-9) 4A. 4,6-Dinitro-O-Cresol MNR MNR (534-53-1) 5A. 2,4-Dinitrophenol MNR MNR (51-28-5) 6A. 2-Nitrophenol MNR MNR (88-75-5) 7A. 4-Nitrophenol MNR MNR (100-02-7) 8A P-Chloro-M-Cresol MNR MNR (59-50-7) 9A Pentachlorophenol MNR MNR (87-86-5) 10A Phenol MNR MNR (108-95-2) 11A 2,4,5-Trichloro- MNR MNR phenol (88-06-2)

GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS 1B. Acenaphthene MNR MNR (63-32-9) 2B. Acenaphtylene MNR MNR (208-96-8) 3B. Anthracene MNR MNR (120-12-7) 4B. Benzidine MNR MNR (92-87-5) VII-13 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-005

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 5B. Benzo (a) Anthracene MNR MNR (56-55-3) 6B. Benzo (a) Pyrene MNR MNR (50-32-8) 7B. 3,4-Benzo-fluoranthene MNR MNR (205-99-2) 8B. Benzo (ghi) Perylene MNR MNR (191-24-2) 9B. Benzo (k) Fluoranthene (207- MNR MNR 08-9) 10B. Bis (2-Chloroethoxy) MNR MNR Methane (111-91-1) 11B. Bis (2-chloroethyl) MNR MNR Ether (111-44-4) 12B. Bis (2-Chloroisopropyl) MNR MNR Ether (102-60-1) 13B. Bis (2-Ethylhexyl) MNR MNR Phthalate (117-81-7) 14B. 4-Bromophenyl MNR MNR Phenyl Ether (101-55-3) 15B Butyl Benzyl Phthalate MNR MNR (84-68-7) 16B. 2-Chloronaphthalene MNR MNR (91-58-7) 17B. 4-Chlorophenyl MNR MNR Phenyl Ether (7005-72-3) 18B. Chrysene MNR MNR (218-01-9) 19B. Dibenzo (a,h) MNR MNR Anthracene (53-70-3) 20B. 1,2-Dichlorobenzene MNR MNR (95-50-1) 21B. 1,3-Dichlorobenzene MNR MNR (541-73-1) 22B. 1,4-Dichlorobenzene MNR MNR (106-46-7) 23B. 3,3'-Dichlorobenzidine MNR MNR (92-94-1) 24B. Diethyl Phthalate MNR MNR (84-66-2) 25B. Dimethyl Phthalate MNR MNR (131-11-3) 26B. Di-N-Butyl Phthalate MNR MNR (84-74-2) 27B. 2,4-Dinitrotoluene MNR MNR (121-14-2) 28B. 2,6-Dinitrotoluene MNR MNR (606-20-2)

VII-14 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-005

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 29B. Di-N-Octyl Phthalate MNR MNR (117-84-0) 30B. 1,2-Diphenylhydrazine MNR MNR (as Azobenzene) (122-66-7) 31B. Fluoranthene MNR MNR (206-44-0) 32B. Fluorene (86-73-7) MNR MNR 33B. Hexachlorobenzene MNR MNR (118-74-1) 34B. Hexachlorobutadiene MNR MNR (87-68-3) 35B. Hexachlorocyclopentadiene MNR MNR (77-47-4) 36B. Hexachloroethane MNR MNR (67-72-1) 37B. Indeno (1,2,3-cd) MNR MNR Pyrene (193-39-5) 38B. Isophorone MNR MNR (78-59-1) 39B. Naphthalene MNR MNR (91-20-3) 40B. Nitrobenzene MNR MNR (98-95-9) 41B N-Nitrosodimethylamine MNR MNR (62-75-9) 42B. N-Nitrosodi-N- MNR MNR Propylamine (621-64-7) 43B. N-Nitro- MNR MNR sodiphenylamine (86-30-6) 44B Phenanthrene MNR MNR (85-01-8) 45B. Pyrene (129-00-0) MNR MNR 46B. 1,2,4-Trichlorobenzene MNR MNR (120-82-1)

GC/MS FRACTION - PESTICIDES 1P. Aldrin (309-00-2) 2P. -BHC (319-84-6) 3P -BHC (319-85-7) 4P. -BHC (58-89-9) 5P. -BHC (319-86-8) VII-15 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-005

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 6P. Chlordane (57-74-9) 7P. 4,4'-DDT (50-29-3) 8P. 4,4'-DDE (72-55-9) 9P. 4,4'-DDD (72-54-8) 10P. Dieldrin (60-57-1) 11P. -Endosulfan (115-29-7) 12P. -Endosulfan (115-29-7) 13P. Endosulfan Sulfate (1031-07-8) 14P. Endrin (72-20-8) 15P. Endrin Aldehyde (7421-92-4) 16P. Heptachlor (76-44-8) 17P. Heptachlor Epoxide (1024-57-3) 18P. PCB-1242 (53469-21-9) 19P. PCB-1254 (11097-69-1) 20P. PCB-1221 (11104-28-2) 21P. PCB-1232 (11141-16-5) 22P. PCB-1248 (12672-29-6) 23P. PCB-1260 (11096-82-5) 24P. PCB-1016 (12674-11-2) 25P. Toxaphene (8001-35-2)

VII-16 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-008 PLEASE PRINT OR TYPE ONLY: You may report some or all of this information on separate sheets instead of completing these pages. Use the same format. SEE INSTRUCTIONS. VII. INTAKE AND EFFLUENT CHARACTERISTICS PART A - You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.

1. 2. Effluent 3.. Units 4. Intake (optional)

Pollutant a. Max. Daily Value b. Max. 30-day Value c. Annual Avg. Value d. No. of a. Concentration b. Mass a. Long Term Avg. Value b. No. of (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass Analyses (1) Conc. (2) Mass Analyses a.Carbonaceous Biochemical NA NA Oxygen Demand (CBOD)

b. Chemical Oxygen NA NA Demand (COD)

c. Total Organic NA NA Carbon (TOC)

d. Total Suspended 8.6 41 1 mg/L lbs/day Solids (TSS)

e. Total Nitrogen (as N) 0.95 4.54 1 mg/L lbs/day

f. Total Phosphorus (as P) 0.018 0.086 1 mg/L lbs/day

g. Ammonia (as N) NA NA mg/L lbs/day

h. Flow - actual or Value 0.573 mgd avg. Value Value mgd mg/L projected

i. Flow - design Value Value Value mg/L

j. Specific Conductivity Value Value Value umhos/cm mg/L

k. Temperature (winter) Value Value Value C Value

l. Temperature (summer) Value Value Value C Value

m. . pH Min. Max. Min. Max. STANDARD UNITS PART B - Mark "X" in column 2a for each pollutant you know or have reason to believe is present. Mark "X" in column 2b for each pollutant you believe to be absent. If you mark column 2a for any pollutant which is limited either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant. For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additonal details and requirements.

2. Mark "X" 3. Effluent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. be- b. be a. Maximum Daily b. Max. 30-day Value c. Long Term Avg. d. No. of a. Conc. b. Mass a. Long Term Avg. b. No. of No. (if available) lieved lieved Value (if available) Value (if available) Analyses Value Analyses present absent (1) Conc... (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass

a. Bromide Monitoring MNR (24949-67-9) not required

b. Chlorine, MNR MNR Total Residual

c. Color MNR MNR

d. Fecal Coliform MNR MNR

e. Fluoride MNR MNR (16984-48-8)

f. Nitrate-Nitrite <0.10 MNR (as N)

VII-17 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Item VII-B Contd. Facility ID. Number: FL0002208 Outfall No. I-008

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. .be- b. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) lieved lieved (if available) (if available) Analyses Analyses present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass

g. Nitrogen, Total MNR MNR Organic (as N)

h. Oil and grease 4.8 I 22.95 mg/L lbs/day

i. Phosphorus, Total MNR MNR (as P) (7723-14-0)

j. Radioactivity (1) Alpha, Total MNR MNR (2) Beta, Total MNR MNR (3) Radium, Total MNR MNR (4) Radium 226, Total MNR MNR

k. Sulfate (as SO4 ) MNR MNR (14808-79-8)

l. Sulfide (as S) MNR MNR

m. Sulfite (as SO3 ) MNR MNR (14265-45-3)

n. Surfactants MNR MNR

o. Aluminum, Total MNR MNR (7429-90-5)

p. Barium, Total MNR MNR (7440-39-3)

q. Boron, Total MNR MNR (7440-42-8)

r. Cobalt, Total MNR MNR (7440-48-4)

s. Iron, Total MNR MNR (7439-89-6)

t. Maagnesium, Total MNR MNR (7439-95-4)

u. Molybdenum, Total MNR MNR (7439-98-7)

v. Manganese, Total MNR MNR (7439-96-5)

w. Tin, Total MNR MNR (7440-31-5)

x. Titanium, Total MNR MNR (7440-32-6)

VII-18 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-008 PART C - If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you must test for. Mark "X" in column 2a for all GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2a (secondary industries, non-process wastewater outfalls, and non-required GC/MS fractions), mark "X" in column 2b for each pollutant you know or have reason to believe is present. Mark "X" in column 2c for each pollutant you believe is absent. If you mark column 2a for any pollutant, you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant, you must provide the results of at least one anlysis for that pollutnat if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4,dinitrophenol, or 2-methyl-4,6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements.

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony, Total MNR MNR (7440-36-0) 2M. Arsenic, Total MNR MNR (7723-14-0) 3M. Beryllium, Total MNR MNR (7440-41-7) 4M. Cadmium, Total MNR MNR (7440-43-9) 5M. Chromium, Total MNR MNR (7440-47-3) 6M. Copper, Total MNR MNR (7440-50-8) 7M. Lead, Total MNR MNR (7439-92-1) 8M. Mercury, Total MNR MNR (7439-97-6) 9M. Nickel, Total MNR MNR (7440-02-0) 10M. Selenium, Total MNR MNR (7782-49-2) 11M. Silver, Total MNR MNR (7440-22-4) 12M. Thallium, Total MNR MNR (7440-28-0) 13M. Zinc, Total MNR MNR (7440-66-6) 14M. Cyanide, Total MNR MNR (57-12-5) 15M. Phenols, Total MNR MNR 2,3,7,8-Tetra- MNR MNR chlorodibenzo-P-Dioxin (1764-01-6) 1V. Acrolein MNR MNR (107-02-8) 2V. Acrylonitrile MNR MNR (107-13-1)

VII-19 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. FL0002208 Outfall No. I-008

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass GC/MS FRACTION - VOLATILE COMPOUNDS (continued) 3V. Benzene MNR MNR (71-43-2) 4V. Bis (Chloromethyl) Ether MNR MNR (542-88-1) 5V. Bromoform MNR MNR (75-25-2) 6V. Carbon Tetrachloride MNR MNR (56-23-5) 7V Chlorobenzene MNR MNR (108-90-7) 8V. Chlorodi- MNR MNR bromomethane (124-8-1) 9V. Chloroethane MNR MNR (74-00-3) 10V. 2-Chloro-ethylvinyl MNR MNR Ether (110-75-8) 11V. Chloroform MNR MNR (67-86-3) 12V. Dichloro- MNR MNR bromomethane (75-24-4) 13V. Dichloro- MNR MNR difluoromethane (75-71-8) 14V. 1,1-Dichloroethane MNR MNR (75-34-3) 15V. 1,2-Dichloroethane MNR MNR (107-06-2) 16V. 1,1-Dichloroethylene MNR MNR (75-35-4) 17V. 1,2,-Dichloropropane MNR MNR (78-87-5) 18V. 1,3-Dichloropropylene MNR MNR (542-75-6) 19V. Ethylbenzene MNR MNR (100-41-4) 20V. Methyl Bromide MNR MNR (74-83-9) 21V. Methyl Chloride MNR MNR (74-87-3) 22V. Methylene Chloride MNR MNR (74-98-2) 23V. 1,1,2,2-Tetra- MNR MNR chloroethane (79-34-5) 24V. Tetrachloroethylene MNR MNR (127-18-4)

VII-20 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-008

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass GC/MS FRACTION - VOLATILE COMPOUNDS (continued) 25V. Toluene (108-88-3) MNR MNR 26V. 1,2-Trans- MNR MNR Dichloroethylene (156-60-5) 27V. 1,1,2-Trichloroethane MNR MNR (71-55-6) 28V. 1,1,2-Trichloroethane MNR MNR (79-00-5) 29V. Trichloroethylene MNR MNR (79-01-6) 30V. Trichloro- MNR MNR fluoromethane (75-69-4) 31V. Vinyl Chloride MNR MNR (75-01-4) 1A. 2-Chlorophenol MNR MNR (95-57-8) 2A. 2,4-Dichlorophenol MNR MNR (120-83-2) 3A. 2,4-Dimethylphenol MNR MNR (105-67-9) 4A. 4,6-Dinitro-O-Cresol MNR MNR (534-53-1) 5A. 2,4-Dinitrophenol MNR MNR (51-28-5) 6A. 2-Nitrophenol MNR MNR (88-75-5) 7A. 4-Nitrophenol MNR MNR (100-02-7) 8A P-Chloro-M-Cresol MNR MNR (59-50-7) 9A Pentachlorophenol MNR MNR (87-86-5) 10A Phenol MNR MNR (108-95-2) 11A 2,4,5-Trichloro- MNR MNR phenol (88-06-2)

GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS 1B. Acenaphthene MNR MNR (63-32-9) 2B. Acenaphtylene MNR MNR (208-96-8) 3B. Anthracene MNR MNR (120-12-7) 4B. Benzidine MNR MNR (92-87-5) VII-21 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-008

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 5B. Benzo (a) Anthracene MNR MNR (56-55-3) 6B. Benzo (a) Pyrene MNR MNR (50-32-8) 7B. 3,4-Benzo-fluoranthene MNR MNR (205-99-2) 8B. Benzo (ghi) Perylene MNR MNR (191-24-2) 9B. Benzo (k) Fluoranthene (207- MNR MNR 08-9) 10B. Bis (2-Chloroethoxy) MNR MNR Methane (111-91-1) 11B. Bis (2-chloroethyl) MNR MNR Ether (111-44-4) 12B. Bis (2-Chloroisopropyl) MNR MNR Ether (102-60-1) 13B. Bis (2-Ethylhexyl) MNR MNR Phthalate (117-81-7) 14B. 4-Bromophenyl MNR MNR Phenyl Ether (101-55-3) 15B Butyl Benzyl Phthalate MNR MNR (84-68-7) 16B. 2-Chloronaphthalene MNR MNR (91-58-7) 17B. 4-Chlorophenyl MNR MNR Phenyl Ether (7005-72-3) 18B. Chrysene MNR MNR (218-01-9) 19B. Dibenzo (a,h) MNR MNR Anthracene (53-70-3) 20B. 1,2-Dichlorobenzene MNR MNR (95-50-1) 21B. 1,3-Dichlorobenzene MNR MNR (541-73-1) 22B. 1,4-Dichlorobenzene MNR MNR (106-46-7) 23B. 3,3'-Dichlorobenzidine MNR MNR (92-94-1) 24B. Diethyl Phthalate MNR MNR (84-66-2) 25B. Dimethyl Phthalate MNR MNR (131-11-3) 26B. Di-N-Butyl Phthalate MNR MNR (84-74-2) 27B. 2,4-Dinitrotoluene MNR MNR (121-14-2) 28B. 2,6-Dinitrotoluene MNR MNR (606-20-2)

VII-22 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-008

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 29B. Di-N-Octyl Phthalate MNR MNR (117-84-0) 30B. 1,2-Diphenylhydrazine MNR MNR (as Azobenzene) (122-66-7) 31B. Fluoranthene MNR MNR (206-44-0) 32B. Fluorene (86-73-7) MNR MNR 33B. Hexachlorobenzene MNR MNR (118-74-1) 34B. Hexachlorobutadiene MNR MNR (87-68-3) 35B. Hexachlorocyclopentadiene MNR MNR (77-47-4) 36B. Hexachloroethane MNR MNR (67-72-1) 37B. Indeno (1,2,3-cd) MNR MNR Pyrene (193-39-5) 38B. Isophorone MNR MNR (78-59-1) 39B. Naphthalene MNR MNR (91-20-3) 40B. Nitrobenzene MNR MNR (98-95-9) 41B N-Nitrosodimethylamine MNR MNR (62-75-9) 42B. N-Nitrosodi-N- MNR MNR Propylamine (621-64-7) 43B. N-Nitro- MNR MNR sodiphenylamine (86-30-6) 44B Phenanthrene MNR MNR (85-01-8) 45B. Pyrene (129-00-0) MNR MNR 46B. 1,2,4-Trichlorobenzene MNR MNR (120-82-1)

GC/MS FRACTION - PESTICIDES 1P. Aldrin (309-00-2) 2P. -BHC (319-84-6) 3P -BHC (319-85-7) 4P. -BHC (58-89-9) 5P. -BHC (319-86-8) VII-23 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Facility ID. Number: FL0002208 Outfall No. I-008

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a. . b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available) Analyses Analyses required present absent (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass (1) Conc. (2) Mass 6P. Chlordane (57-74-9) 7P. 4,4'-DDT (50-29-3) 8P. 4,4'-DDE (72-55-9) 9P. 4,4'-DDD (72-54-8) 10P. Dieldrin (60-57-1) 11P. -Endosulfan (115-29-7) 12P. -Endosulfan (115-29-7) 13P. Endosulfan Sulfate (1031-07-8) 14P. Endrin (72-20-8) 15P. Endrin Aldehyde (7421-92-4) 16P. Heptachlor (76-44-8) 17P. Heptachlor Epoxide (1024-57-3) 18P. PCB-1242 (53469-21-9) 19P. PCB-1254 (11097-69-1) 20P. PCB-1221 (11104-28-2) 21P. PCB-1232 (11141-16-5) 22P. PCB-1248 (12672-29-6) 23P. PCB-1260 (11096-82-5) 24P. PCB-1016 (12674-11-2) 25P. Toxaphene (8001-35-2)

VII-24 DER Form 62-620.910(5)2CS, Effective November 29, 1994

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Form 2CS - Attachment A Item IV.A. Water Flow Diagram

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Form 2CS - Attachment B Responses to Item IV.B, D, & E List of Item IV Responses Item IV.B. Identification of Major Plant Processes and Associated Wastestreams Item IV.D. Emergency Plant Practices for Power Loss/Equipment Failures Item IV.E. Methods of Flow Measurement

FORM 2CS - ATTACHMENT B SUPPLEMENTAL INFORMATION FOR FORM 2CS FORM 2CS, ITEM IV.B. (page 2CS-17) GENERAL DESCRIPTION OF MAJOR PROCESSES AND ASSOCIATED WASTE STREAMS The St. Lucie Power Plant is located on Hutchinson Island in St. Lucie County, at latitude 27°2054 and longitude 80°1444, approximately 12 miles north of Stuart, Florida. The 1,132-acre plant site is located near the midpoint of Hutchinson Island, as shown on Figure 1. The plant site contains two nuclear power units (Unit 1 and Unit 2), both 1,000-megawatt (MW) net facilities using pressurized water reactors. Construction, design, and operation are relatively the same for both units. Both units share common once-through cooling water intake and discharge canals. Separate ocean intake and discharge pipes withdraw from and discharge to the Atlantic Ocean via the canals. Individual ocean discharge pipes may be isolated independently depending on the number of units operating. Refer to Figure 2 for the locations of the outfalls. There are three ocean intake structures for Unit 1 and Unit 2. The intake structures in the Atlantic Ocean contain vertical sections to prevent sanding and velocity caps to minimize impingement and entrainment of marine organisms. Horizontal entrance velocities at the velocity cap boundaries are estimated to be approximately 0.4 foot per second (fps) for the two 12-diameter intake pipes and 1 fps for the 16-ft intake pipe. The wastewater discharges from the St. Lucie Power Plant include once-through cooling water, steam generator blowdown, low level waste, intake screen wash wastewater, and stormwater associated with industrial activity, which includes a discharge location from the Southeast Evaporation Basin. Equipment area floor drains are routed to oil water separation systems prior to ultimate discharge to the East and West stormwater basins. The West Basin and East Basin flow into the South Basin, which overflows to the Southeast Basin. The Southeast Basin discharges to the Intake Canal via Outfall I-008. Figure 2 shows the location of these basins as well as the outfall discharge points. Mangrove Flushing Water In order to enhance the growth of isolated mangrove trees located on the east side of the plant and bounded by the plant discharge canal, State Road A1A, and the plant intake canal, seawater is pumped from the intake canal on a seasonal basis onto the discharge canal side of the mangrove area. This seawater is allowed to gravity flow back toward the intake canal. At the discharge pipe

into the intake canal, stop logs are used to regulate water level in the mangrove area and simulate flushing that would naturally occur due to tidal action. The flushing and water level control are optimized to help control mosquito growth. At the proper time, the stop logs are removed and the uncontaminated seawater is returned to the intake canal. In a letter from Bruce Barrett, dated August 11, 1987, EPA concurred that such a discharge would not require an NPDES permit. Once Through Cooling Water and Auxiliary Cooling Water (D-001) The plant uses a total of eight circulating water pumps (four per unit) having a design total capacity of 974,600 gallons per minute (gpm) or 1.4 b i l lion gallons per day (BGD) to supply once-through cooling water to Units 1 and 2. The once-through condenser and auxiliary cooling water systems discharge to the Atlantic Ocean via pipelines. One discharge pipe is equipped with a Y-port diffuser that discharges approximately 1,500 feet (ft.) from shore. The other discharge pipe has a multi-port diffuser (58 ports), each port being 16 inches in diameter. The length of the multi-port diffuser is 1,416 ft. starting 1,959 ft. from shore and having a 24-ft. spacing between ports. The diffuser manifold is optimized with ports alternately oriented north and south at an angle of 25 degrees from the manifold. The discharge of heated water through the Y-port and multi-port diffusers ensures distribution over a wide area and enables a more rapid and efficient mixing with ambient water. The once-through cooling water system is chlorinated at a maximum of 2 hours per day per unit for micro- and macro-biofouling control. FPL uses mechanical condenser tube cleaning systems on both units. These systems have sponge balls that are approximately 23 millimeters (mm) in diameter, which are forced through the condenser tubes. Approximately 1,800 sponge balls are applied at one time per condenser water box. There are four water boxes per condenser on each unit. The sponge balls scrub the tubes as they pass through. Downstream of the condensers, the sponge balls are captured by a ball strainer. The ball strainers have grills with 5-mm spacing that prevent the balls from passing through the water box outlets and into the plant discharge system. The ball strainer grills funnel the sponge balls to pipes on the side of the strainer housings where the balls are sucked out of the circulating water flow by a recirculating pump. The sponge balls pass through the recirculating pump to the ball collectors. Ft. Pierce City water is used for seal water for the recirculation pumps at approximately 3.5 gpm.

The sponge balls normally pass through the ball collectors and are returned to the inlet side of the condensers for another cycle through the condensers. When the sponge balls begin to wear out, they are collected in the ball collector. The recirculating pump is shut down and the worn out balls are removed and new balls added to the ball collector. The facility employs best management practices for the control of sponge ball loss to the environment from the tube cleaning systems. For example, sponge balls are inventoried and sponge ball loss to the environment is reported to FDEP on an annual basis. In addition to once-through cooling, up to 58,000 gpm (84 MGD) of ocean cooling water is pumped using auxiliary cooling water pumps through the auxiliary equipment heat exchangers. The solution being cooled by these heat exchangers, which in turn directly cools in-plant machinery, contains approximately 200 to 500 ppm of sodium molybdate and 10 to 30 ppm of tolytriazole. Normally this part of the system is closed, recirculating similar to an automobile cooling system. If a leak occurred in a heat exchanger, a small amount of the molybdate solution could be released. The water level in this system is carefully monitored so leaks can be identified and repairs made. Due to the large volume being discharged to the common discharge canal through the open part of the cooling water system, it is anticipated that these minor leaks would not be detectable at the heat exchanger outlet and consequently would not be detectable at the POD in the discharge canal. Low-level chlorination is applied to the auxiliary cooling water. Liquid Radwaste System Batch Releases: I-003 The flow from the radwaste treatment system is intermittent. The system permits a maximum estimated flow of 250 gpm. This waste stream originates from various maintenance and operational activities that take place in the reactor auxiliary building (RAB) and is processed for radioactive reduction by ion exchange resins and low micron filtration systems. Steam Generator Blowdown: I-005 High purity make-up water is generated at the facility by a water treatment plant using a high efficiency reverse osmosis process and ultraviolet TOC destruct process. Much of this high quality water is routed to the secondary system and steam generators as makeup for the water/steam cycle. C a u s t i c s o d a is infrequently added for pH control, and hydrazine is added for oxygen removal. Undesirable constituents such as chlorides from condenser leaks can impact the steam generator water. Strict operating specifications require that suspended and dissolved solids be maintained at very low levels; therefore, to keep the constituents at these low levels, a continuous steam generator

blowdown is required. This blowdown is either recovered and recirculated or routed to the discharge canal. The concentration of hydrazine in these discharges during plant operation normally ranges from 25 parts per billion (ppb) to 2 ppm. During overhauls and/or refueling outages the steam generators, feed water systems, and/or condensers may be placed in a static mode where the internal metal surfaces of these components must be protected from corrosion. The typical method used is to fill the system with a hydrazine/carbohydrazide/ demineralized water solution. This solution, which contains up to 300 ppm hydrazine, must then be drained and discharged to the plants discharge canal. In addition, various amine solutions such as ethanolamine (ETA) and dimethylamine (DMA) are introduced for pH control of the condensate and feed water. These discharges normally occur approximately every 18 months per unit during refueling operations or during any periods of extended maintenance. FPL monitored the discharge canal extensively at EPAs request from 1989 to 1993 during periods of wet lay-up discharge. Due to the rapid breakdown of hydrazine upon exposure to oxygen in the environment and through dilution, the hydrazine concentrations were found to be between <5 ppb and 16 ppb at the POD with most of the values being <5 ppb (the detection limit for hydrazine). Intake Traveling Screen Wash Water: I-007 Two 1,060-gpm capacity traveling screen wash pumps for both Units 1 and 2 at the intake structure withdraw ocean water for traveling screen cleaning. The traveling screens are used to prevent debris from reaching the condensers. One pump (the other standby) is normally in operation on each unit for 2 hours per day, at an average wash flow of 900 gpm per unit. The wash water is returned to the intake canal through a collection sump and drain system. Emergency Storm Water Outfall from Condenser Component Cooling Water Pits: I-009 FDEP modified this permit in November 2014 to add this intermittent discharge from e a c h u n i t s c o n d e n s e r c o o l i n g w a t e r p i t s to the plant intake and discharge canals. This discharge is used when rainfall runoff results in water levels that could inundate electrical equipment. The discharge is operated via a removable pumps that will only operate when a high water level exists in the condenser pits. D u r i n g e x t r e m e s e v e r e w e a t h e r e v e n t s , t h e p i t s a r e checked daily and when levels are such that a discharge becomes necessary, the pumps will be activated, and the discharge is monitored for flow rate and required chemical parameters. Based on past experience and average rainfall conditions, this discharge is extremely severe weather-dependent and is estimated to occur very rarely, less than once per year.

Outfall from Southeast Evaporation/Percolation Basin: I-008 FPL maintains an intermittent discharge from the Southeast Evaporation/Percolation Basin to the plant intake canal. This discharge is used when rainfall runoff results in basin water levels that would impede plant operating equipment. The discharge is operated via a valve that is only operated when a high water level exists in the basin. A staff gauge in the basin is checked daily and when levels are such that a discharge becomes necessary, the valve is opened, and the discharge is monitored for flow rate and required chemical parameters.

FORM 2CS, ITEM IV.D. Item IV.D. Describe practices to be followed to ensure adequate wastewater treatment during emergencies such as power loss and equipment failures causing shutdown of pollution abatement equipment of the proposed/permitted facilities. In the event of a power loss resulting in the shutdown of pollution abatement equipment or the failure of such equipment, the facility is capable of preventing the discharge of pollutants offsite. Most treatment system components are passive in nature and are, therefore, not impacted by power failures. Pumps are the exception. In many instances, dual pumps are used for system redundancy. In addition, the plant maintenance department staff is on-call 24 hours a day for maintenance and repair of equipment. All power losses to the facility are managed with a high priority. Any loss of power is usually brief and should not affect wastewater treatment to any significant degree. The facility also has a Hurricane Emergency Equipment Building which houses large generators that will be used when needed. FORM 2CS, ITEM IV.E. Item IV.E. List the method(s) and location(s) of flow measurement. A listing of the methods of flow calculation for the outfalls that discharge to surface waters is shown below. Outfall Purpose Flow Measurement Method D-001 Condenser Once-Through and Auxiliary Pump design flow and pump run times Equipment Cooling Water I-003 Liquid radiation waste Tank volume calculated prior to each batch discharge I-005 Steam generator blowdown Flow indicating control valve I-007 Intake screen wash Pump design flow and pump run times I-008 Discharge from SE Flowmeter evaporation/percolation basin I-009 Emergency storm water Pump design flow and pump run times discharge from Condenser Cooling Water pits

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Permit Application Form 2F DEP Form 62-620.910(8)

FORM 2F APPLICATION FOR PERMIT FOR STORMWATER DISCHARGE ASSOCIATED WITH INDUSTRIAL ACTIVITY Facility I.D. Number: FL0002208 Please type or print in black ink. If additional space is needed for your answer, use plain sheets and attach to the application form. I. Outfall Location: For each outfall, list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water. A. Outfall Number (list) B. Latitude C. Longitude D. Receiving Water (Name) I-009 27 20 52 80 14 51 Plant Intake Canal I-009* 27 20 57 80 14 40 Plant Discharge Canal I-06D* 27 20 42.8 80 14 46 Plant Intake Canal I-009 discharges to more than one location from each unit via portable pumps during extreme weather. I-06D has not discharged in the past 5 years and has no monitoring requirements. II. Improvements: A. Are you now required by any Federal, State, or local authority to meet any implementation schedule for the construction, upgrading or operation of stormwater or wastewater treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions?

1. Identification of 2. Affected Outfalls 3. Brief Description of Project 4. Final Compliance Date Conditions, Agreements No. Source of Discharge a. required b. projected N/A B. You may attach additional sheets describing any additional water pollution or other environmental projects which may affect your discharge that you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or planned schedules for construction.

III. Site Drainage Map: Attach a site map showing topography depicting the facility including each of its intake and discharge structures the drainage area of each stormwater outfall; paved areas and buildings within the drainage area of each stormwater outfall; each known past or present areas used for outdoor storage or disposal of significant materials; each existing structural control measure to reduce pollutants in stormwater runoff, materials loading and access areas, areas where pesticides, herbicides, soil conditioners and fertilizers are applied; each of its hazardous waste treatment, storage or disposal units; each well where fluids from the facility are injected underground; springs, and other surface water bodies which receive stormwater discharges from the facility. Show hazardous waste storage or disposal areas that do not require a RCRA permit separate from those which do require a permit. Please see facility maps in Form 1 Attachment DEP Form 62-620.910(8) 2F-13 Effective October 23, 2000

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Facility I.D. Number: FL0002208 VI. Significant Leaks or Spills: Provide existing information regarding the history of significant leaks or spills of toxic or hazardous pollutants at the facility in the last three years, including the approximate date and location of the spill or leak, and the type and amount of material released. VII. Discharge Information: A, B, C, & D: See instructions before proceeding. Complete one set of tables for each outfall. Annotate the outfall number in the space provided. Tables VII-A, VII-B, and VII-C are included on separate sheets numbered VII-1 and VII-2. E. Potential discharges not covered by analysis - is any toxic pollutant listed in Table 2F-2, 2F-3, or 2F-4, a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or by-product? Yes (list all such pollutants below) X No (go to section VIII) VIII. Biological Toxicity Testing Data Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last 3 years? Yes (list results below) X No (go to Section IX) IX. Contract Analysis Information Were any of the analysis reported in item VII performed by a contract laboratory or consulting firm? Yes (list the name, address, and telephone number of, and pollutants analyzed by each such laboratory or firm below) X No (go to Section X) A. Name B. Address C. Area Code & Phone No. D. Pollutants Analyzed DEP Form 62-620.910(8) 2F-15 Effective October 23, 2000

Facility I.D. Number: FL0002208 X-A. CERTIFICATIONS FOR NEW OR MODIFIED FACILITIES I certify that the engineering features of this pollution control project have been designed by me and found to be in conformity with sound engineering principles, applicable to the treatment and disposal of pollutants characterized in the permit application. There is reasonable assurance, in my professional judgment, that the pollution control facilities, when properly maintained and operated, will discharge an effluent that complies with all applicable statutes of the State of Florida and the rules of the Department. It is also agreed that the undersigned, if authorized by the owner, will furnish the applicant a set of instructions for the proper maintenance and operation of the pollution control facilities and, if applicable, pollution sources. Signature Company Name Address Name (please type) (Affix Seal) Florida Registration No.: Telephone No:: Date I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name & Official Title (Please type or print) Signature Telephone No. (area code & No.) Date Signed DEP Form 62-620.910(8) 2F-16 Effective October 23, 2000

X-B. CERTIFICATIONS FOR PERMIT RENEWALS I certify that the engineering features of this pollution control project have been examined by me and found to be in conformity with sound engineering principles, applicable to the treatment and disposal of pollutants characterized in the permit application. There is reasonable assurance, in my professional judgment, that the pollution control facilities, when properly maintained and operated, will discharge an effluent that complies with all applicable statutes of the State of Florida and the rules of the Department. I Florida Power and Light Company Company Name Diane H. Nguyen Address: 700 Universe Blvd Juno Beach, FL 33408 Florida Registration No.: 70714 Telephone No: 561-694-3185 Date 3/!Sho?-J I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Daniel DeBoer, N Site VP - St. Lucie Power Plant Name & Official Title (Please type or print) Signature 772-467-7100 Telephone No. (area code & No.) Date Signed DEP Fonn 62-620.910(8) 2F-17 Effective October 23, 2000

VII. Discharge Information (Continued from page 2F-15 of Form 2F) Facility I.D. Number: FL0002208

• Note: Outfalls I-06D and I-009 have not discharged in the past 5 years.

Part A - You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.

                                                                                                                            # of Minimum Values (include units)                Average Values (include units)                Storm            Sources of Pollutants Events Pollutant and CAS Grab Sample Taken During            Flow-weighted   Grab Sample Taken During        Flow-weighted Number (if available)           First 30 Minutes          Composite          First 30 Minutes             Composite         Sampled Oil and Grease                                              N/A Biochemical Oxygen Demand Chemical Oxygen Demand Total Suspended Solids (TSS)

Total Kjeldahl Nitrogen Nitrate + Nitrite Nitrogen Total Phosphorus pH Minimum Maximum Minimum Maximum Part B - List each pollutant that is limited in an effluent guideline which the facility is subject to or any pollutant listed in the facility's wastewater permit for its wastewater effluent if the facility is operating under an existing wastewater permit. Complete one table for each outfall. See instructions for additional details and requirements. Minimum Values (include units) Average Values (include units) # of Pollutant and CAS Storm Sources of Pollutants Grab Sample Taken Flow-weighted Grab Sample Taken During Flow-weighted Number (if During First 30 composite First 30 Minutes Composite Events available) Sampled Minutes N/A DEP Form 62-620.910(8) VII-1 Effective October 23, 2000

VII. Discharge Information (Continued from Table VII on page VII - 1 of Form 2F) Facility I.D. Number: FL0002208 Part C - List each pollutant shown in Tables 2F-2, 2F-3, and 2F-4 that you know or have reasons to believe is present. Complete one table for each outfall. See instructions for additional details.

                                                                                                                       # of Storm Minimum Values (include units)                 Average Values (include units)                          Sources of Pollutants Events Sampled Pollutant and CAS Grab Sample Taken During        Flow-weighted      Grab Sample Taken During     Flow-weighted Number (if available)         First 30 Minutes        Composite              First 30 Minutes         Composite N/A Part D - Provide data for the storm event(s) which resulted in the maximum values for the flow weighted composite sample.

1. 2. 3. 4. 5. 6. 7.

Date of Storm Event Duration of Storm Total rainfall during Number of hours Maximum flow rate Total flow Comments Event storm event between beginning of during rain event from rain (in minutes) (in inches) storm measured and end (specify units) event of previous measurable (specify rain event units) N/A Provide a description of the method of flow measurement or estimate. DEP Form 62-620.910(8) VII-2 Effective October 23, 2000

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Form 2F - Attachment Item IV.B Significant Materials

FORM 2F - ATTACHMENT SUPPLEMENTAL INFORMATION FOR FORM 2F ITEM IV.B. SIGNIFICANT MATERIALS The following narrative excludes those areas and facilities included in Form 2CS. For the remaining plant areas, no significant materials are currently, or in the past 5 years have been, treated, stored, or disposed in a manner that would be exposed to storm water. Company management practices to minimize contact of significant materials with storm water runoff include the storage of chemicals, pesticides, fertilizers, and herbicides in original containers within buildings and sheds. In addition, used oil is collected and stored in a storage tank. Liquid hazardous wastes are collected in sealed drums at satellite accumulation areas. Once the drums are full, they are relocated to the hazardous material storage area, which has secondary containment. Pesticides, herbicides, and fertilizers are used at the facility on an as-needed basis in accordance with the manufacturers guidelines.

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Application Attachment I Chlorine Dioxide Dilution and Decay Evaluation

CHLORINE DIOXIDE DILUTION AND DECAY EVALUATION FLORIDA POWER & LIGHT - ST. LUCIE NUCLEAR POWER PLANT April 6, 2021 Final Prepared by: Marta Keller ChemStaff, Consultant II marta.keller@ecolab.com Dave Morey ChemStaff, Consultant PT david.morey@ecolab.com 1l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant DISCLAIMER OF WARRANTIES AND LIMITATIONS OF LIABILITIES This document was prepared by the following organizations: CHEMStaff Neither CHEMStaff, any member of CHEMStaff, any cosponsor, or any other organizations listed, nor any person acting on behalf of any of them: Makes any warranty or representation whatsoever, expressed or implied, (1) with respect to the use of any information, apparatus, method, process, or similar item disclosed in this document, including merchantability and fitness for a particular purpose, or (2) that this document is suitable to a particular users circumstance; or assumes responsibility for any damages or other liability whatsoever (including any consequential damages, even if CHEMStaff or any CHEMStaff representative has been advised of the possibility of such damages) resulting from your selection of use of this document or any information, apparatus, method, process, or similar item disclosed in this document. 2l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant TABLE OF CONTENTS DISCLAIMER OF WARRANTIES AND LIMITATIONS OF LIABILITIES ............................................. 2 TABLE OF CONTENTS ............................................................................................................... 3 EXECUTIVE

SUMMARY

............................................................................................................. 4 INTRODUCTION ....................................................................................................................... 4 BACKGROUND INFORMATION ................................................................................................. 5 SITE COOLING WATER LAYOUT AND DESIGN................................................................................. 5 IWWF PERMIT DISCHARGE LIMITS ............................................................................................ 7 CHLORINE DIOXIDE TREATMENT SPECIFICATIONS ........................................................................... 7 METHODOLOGY ...................................................................................................................... 8 INPUTS ................................................................................................................................. 8 ASSUMPTIONS ....................................................................................................................... 8 DESCRIPTION OF METHODOLOGY ............................................................................................... 9 Chlorine Dioxide Behavior in the Canals ................................................................... 9 Chlorine Dioxide Behavior in the Enclosed Piping Leading to the Diffusers ............. 10 CALCULATIONS ...................................................................................................................... 12 CHLORINE DIOXIDE BEHAVIOR IN THE CANALS ............................................................................ 12 CHLORINE DIOXIDE BEHAVIOR IN THE ENCLOSED PIPING LEADING TO THE DIFFUSERS .......................... 15 RESULTS ................................................................................................................................ 19 CONCLUSIONS ....................................................................................................................... 19 REFERENCES .......................................................................................................................... 20 APPENDIX .............................................................................................................................. 21 3l  1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant EXECUTIVE

SUMMARY

The St. Lucie Nuclear Power Plant has implemented chlorine dioxide injection in place of sodium hypochlorite for treatment of the circulating water (CW) system and plans to make the same change for the intake cooling water (ICW) system. In conjunction with this change in treatment chemical, the site is required to conservatively estimate (based on dilution) the chlorine dioxide concentration at EFF-2, and conservatively estimate (based on dilution) the distance beyond EFF-2 required to achieve ClO2 at a level of < 0.01 mg/L, as laid out in the revised NPDES Industrial Wastewater Facility Permit issued on May 21, 2020 [1]. This report details the methods and results justifying compliance with the permit conditions. Additionally, maximum chlorine dioxide residual at the condenser train cleaning sampling (CTCS) point is calculated to provide biocide program control guidance in the event chlorine dioxide dosage is increased. INTRODUCTION The St. Lucie Nuclear Power Plant (PSL) is submitting an application for NPDES permit renewal by May 2021. Chlorine dioxide injection is being implemented in place of sodium hypochlorite for treatment of the intake cooling water (ICW) and circulating water (CW) systems. Under the current NPDES permit revision [1], the Florida Department of Environmental Protection required that a study be performed as follows: Once per month for the next six months, the permittee shall collect grab samples from one condenser train cleaning sample port(s). The samples shall be collected every 15 minutes starting when treatment begins on one condenser train and extending for 30 minutes after treatment ends for that condenser train. The condenser train being treated, time treatment begins and ends, and the times of collection for all samples shall be recorded and submitted with the chlorine dioxide (ClO2) results for the condenser being treated. All grab samples shall be tested immediately for chlorine dioxide (ClO2) by Hach Method 10126. Sample hold time shall not exceed 10 minutes. Instrument calibration, calibration verification, and chronological calibration verification data shall be included with the sampling data submitted to the Department. The permittee shall submit sampling results to the Departments Tallahassee Wastewater Management Program within 30 days of sample collection. Each month, samples shall be collected from a different condenser train to demonstrate that chlorine dioxide data is being collected from each condenser train at least once during the six months sampling period. [1] 4l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Using the results of this study, PSL is required to conservatively estimate (based on dilution) the chlorine dioxide concentration at EFF-2, and conservatively estimate (based on dilution) the distance beyond EFF-2 required to achieve ClO2 at a level of < 0.01 mg/L. [1] The purpose of this report is to estimate the ClO2 concentration at NPDES permit monitoring location EFF-2 and estimate the distance beyond EFF-2 required to achieve ClO2 at a level of < 0.01 mg/L. BACKGROUND INFORMATION PSL consists of two nuclear powered steam electric generating units (Unit 1 and Unit 2). The site is located on Hutchinson Island in Jensen Beach, Florida and utilizes intake water from the Atlantic Ocean to remove heat from the main condensers via the once-through cooling water (OTCW) and auxiliary equipment cooling water (AECW) systems. SITE COOLING WATER LAYOUT AND DESIGN The CW system removes heat from the condenser and consists of intake and discharge pipes in the ocean with canals to the plant. Each unit is equipped with four CW pumps. Normal operation is with four CW pumps in service for each unit. From the condenser, the discharged condenser cooling water is transported approximately 500 ft. in a buried pipeline and then about 580 ft. in a canal to State Road A1A. The water passes under a bridge and travels about 1200 ft. in the canal to an outfall structure, located on the western side of the sand dune. From the canal outfall structure, the cooling water discharge is carried about 1550 ft. and 3375 ft. offshore in 12 ft. and 16 ft. diameter pipelines, respectively. At its termination, the 12 ft. diameter pipe is modified with a short transition section and a two-part, Y-type high velocity jet discharge. The last 1400 ft. of the 16 ft. diameter discharge line is the multiport diffuser section, composed of 58 equally spaced 17 3/4 in. ports [2]. The ICW system consists of three pumps for each unit and associated piping and valves. Normal operation is with two ICW pumps in service and one in standby for each unit. The system removes heat from the component cooling heat exchangers, the turbine cooling heat exchangers, and the steam generator open blowdown heat exchangers and discharges it to the condenser discharge canal described above. A hypochlorite solution, to be replaced with chlorine dioxide, is continuously injected into the seawater upstream of the ICW pumps to control slime formation [2]. The overall site layout is shown in Figure 1. A drawing of the cooling water discharge pipes is shown in Figure 2. 5l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Main Discharge TRO Monitor Inlet EFF-2 D-001 Location Extended Discharge Inlet Figure 1: St. Lucie Nuclear Power Plant raw water layout and monitoring/discharge locations Figure 2: Outfall D-001 Discharge Pipes and Diffusers 6l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant IWWF PERMIT DISCHARGE LIMITS PSL operates under Industrial Wastewater Facility Permit FL0002208. Section I.A.6 of the existing permit specifies that total residual oxidants (TRO) shall not exceed a maximum instantaneous concentration of 0.1 mg/L at any one time as measured at monitoring location EFF-2 [1]. Additionally, the plant discharge water is required to meet < 0.01 mg/L TRO prior to discharge from the diffusers into the Atlantic Ocean per the Class III Marine Water Quality Standard (WQS). CHLORINE DIOXIDE TREATMENT SPECIFICATIONS The current chlorine dioxide injection feed rates and durations for CW are summarized below in Table 1. Currently, chlorine dioxide is fed to two water boxes simultaneously for one hour and then switched to two different water boxes, until all have been applied 30-35 lbs of ClO2. Table 1: Current CW Chlorine Dioxide Dosage and Duration Circulating Water ClO2 lbs PPM ClO2 Hours Daily lbs of System Flow gpm MMLbs /hr /hr fed of feed ClO2 U1 CW Pump Well A1 122,650 61.37406 0.50-0.55 30.0-35.0 60-70 1.0 U1 CW Pump Well A2 122,650 61.37406 0.50-0.55 30.0-35.0 U1 CW Pump Well B1 122,650 61.37406 0.50-0.55 30.0-35.0 60-70 1.0 U1 CW Pump Well B2 122,650 61.37406 0.50-0.55 30.0-35.0 U2 CW Pump Well A1 122,650 61.37406 0.50-0.55 30.0-35.0 60-70 1.0 U2 CW Pump Well A2 122,650 61.37406 0.50-0.55 30.0-35.0 U2 CW Pump Well B1 122,650 61.37406 0.50-0.55 30.0-35.0 60-70 1.0 U2 CW Pump Well B2 122,650 61.37406 0.50-0.55 30.0-35.0 The ICW is currently being treated continuously with sodium hypochlorite (bleach) at low levels. Based on dilution calculations, TRO existing in the ICW discharge is negligible when mixed with the CW in the canal for the purpose of this evaluation. The total applied ppm dosage for each system is approximately equal during CW chlorination while the total ICW flow is 6% of the total CW flow. Therefore, any existing TRO in the ICW discharge does not affect the overall TRO in the canal. Dilution calculations are shown in further detail in the Appendix. Once permanent chlorine dioxide generator skids are installed, ClO2 injection feed rates may be increased to double the current CW ClO2 dosage (140 lbs/hr to two water boxes at a time for one hour). The ICW system will also be treated with ClO2 in place of hypochlorite at the dosages shown in Table 2. The change in ICW treatment from hypochlorite to chlorine dioxide will lower TRO at the discharge due to lower applied dosages and a higher rate of degradation for ClO 2 compared to bleach. Therefore, ICW chlorine dioxide residual will continue to have a negligible effect on the total chlorine dioxide residual in the canal. 7l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Table 2: Future ICW Chlorine Dioxide Dosage and Duration ClO2 PPM Hours Daily lbs of ICW System Flow gpm MMLbs / Hr lbs/hr ClO2 fed of feed ClO2 U1 ICW Pump Well 1A 14500 7.2558 2 0.275642 24 48 U1 ICW Pump Well 1B 14500 7.2558 2 0.275642 24 48 U2 ICW Pump Well 2A 14500 7.2558 2 0.275642 24 48 U2 ICW Pump Well 2B 14500 7.2558 2 0.275642 24 48 METHODOLOGY Separate from this project, monthly sampling was performed on CTCS ports during and after ClO2 injection for a period of six months as stipulated in the NPDES permit revision [1]. Using the data collected during this six-month period, the ClO2 concentration at monitoring location EFF-2 and the distance required to achieve a ClO2 concentration < 0.01 mg/L were estimated following the methodology described in this section. INPUTS The following data were used as inputs for the ClO2 estimates:

• ClO2 data collected at the CTCS sampling ports for the six-month period following permit revision [1].
• Total residual oxidant data originating from the monitor at monitoring location at the bridge over the canal and collected from the plant process computer.
• St. Lucie discharge canal transit times previously determined through a permit revision

[3]. ASSUMPTIONS The following assumptions were made in the calculations described in this report. Each assumption results in a conservative estimate of the ClO2 residual.

• ICW chlorine dioxide residual has a negligible effect on the total chlorine dioxide residual in the canal. This was confirmed by dilution calculations.
• No biological demand in the enclosed pipe between the CTCS sampling location and the discharge canal or in the diffuser pipes in the ocean. This assumption is conservative because there can be significant biological growth in the enclosed piping systems.
• Chlorite and chlorate are the only decomposition products for modeling ClO2 behavior between the Main Discharge Inlet and the Diffusers. This assumption is conservative 8l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant because approximately 10 - 30% of ClO2 may decompose to other products not typically measured.

• Decomposition measured by distance behaves linearly in enclosed piping.

DESCRIPTION OF METHODOLOGY Cooling water is discharged from the PSL condensers via two distinctly different transport mechanisms: (1) open canal, and (2) enclosed piping systems. Since ClO2 is a photoreactive dissolved gas, additional losses due to photoreactive decomposition and atmospheric release are expected in the open canal that will not apply in the enclosed piping between the canal and the diffusers. Therefore, different methods are required to estimate ClO2 behavior in the canal versus the enclosed piping transport mechanism. The separate methodologies are described below for estimating ClO2 behavior for the canals and the enclosed piping leading to the diffusers. CHLORINE DIOXIDE BEHAVIOR IN THE CANALS The ClO2 concentration was measured at the CTCS sample points (condenser outlets) monthly for six months after the revised permit was issued [1]. During each of those sampling campaigns, TRO data measured by a continuous monitor located at the bridge over the discharge canal (shown in Figure 1) were collected from the plant process computer. The condenser outlet ClO2 results are adjusted for dilution and other TRO inputs as follows:

• For the two condensers being treated with ClO2 at a time, adjust the condenser outlet ClO2 sample results for dilution from untreated cooling water from the other six condenser outlets.
• As applicable, adjust the condenser outlet ClO2 sample results for any ClO2 that was being injected into other water boxes during the sampling campaign.
• Adjust the condenser outlet ClO2 sample results for dilution flow and chlorine residual from the continuously chlorinated ICW discharge stream.

The adjusted condenser outlet ClO2 values represent the ClO2 concentration net of losses in the condenser outlet flow path. These adjusted ClO2 values are then compared to the TRO monitor results from the monitor located at the bridge. This comparison represents the losses from all mechanisms (e.g., biological demand, photoreactivity, atmospheric releases, decomposition) during transit from the condenser outlet to the bridge monitoring location. This method implicitly includes TRO from the ICW discharge stream. By basing the decay curve off the total chlorine monitor in the canal, the decay rate will be conservatively low if there is additional existing TRO in the ICW discharge stream not accounted for by the adjusted CTCS ClO2 residual. 9l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant The transit times in the PSL discharge canals were determined by Geosyntec Consultants for single and dual unit operation as reported in Reference 3. Using the applicable transit distances and times in combination with the ClO2 losses determined above, the ClO2 concentration can be predicted at the Main Discharge Inlet and Extended Discharge Inlet (see Figure 1) for single and dual unit operation. CHLORINE DIOXIDE BEHAVIOR IN THE ENCLOSED PIPING LEADING TO THE DIFFUSERS Chlorine dioxide quickly decomposes to chlorite (ClO3-) and chlorate (ClO2-) in aqueous solutions. Commonly published reaction stoichiometry is shown in Equation 1. 2ClO2 + H2O ClO2- + ClO3- + 2H+ (Equation 1) However, the actual stoichiometry varies significantly from Equation 1 based on work performed at Virginia Tech by Yoon-jin Lee et.al. [4]. The objective of the Virginia Tech study was to evaluate the chlorine dioxide consumption rate and the chlorite and chlorate formation rates in water treatments using chlorine dioxide. An additional objective was to investigate factors that influence chlorite and chlorate formation and develop models for chlorite and chlorate formation from chlorine dioxide. The effects of the following factors were investigated and quantified:

• Initial chlorine dioxide concentration
• pH
• Temperature
• Organic carbon
• Ultraviolet irradiation Models were developed from laboratory data using regression analysis tools in SAS statistical software. Equation 2 and Equation 3 were developed from the regression analysis to describe chlorite and chlorate formation from ClO2 [4].

Chlorite (mg/L) = 10-2.20[ClO2]0.45[pH]0.90[temp]0.27[TOC]1.04[time]0.20 (Equation 2) Chlorate (mg/L) = 10-2.61[ClO2]1.27[pH]-0.50[temp]1.28[TOC]0.31[time]0.12 (Equation 3) These relationships were subsequently validated from measured concentrations compared to predicted concentrations using Equations 1 and 2. These comparisons are shown in Figure 3 for chlorite (Equation 2) and chlorate (Equation 3). 10 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Figure 3: Predicted and Measured Chlorite & Chlorate Comparisons [4] Equation 2 and Equation 3 can be used to estimate ClO2 decomposition behavior during transit between the Main Discharge Inlet (e.g., the end of the discharge canal) and the outlet diffuser located offshore. The Virginia Tech laboratory work showed that 70% - 90% of the ClO2 decomposed to chlorate and chlorite, with the remainder decomposing to other compounds not evaluated in the studies. The mass of ClO2 decomposition reaction products must equal the mass of ClO2, with stoichiometry for chlorite and chlorate based on lab results shown in Equation 4 Chlorine dioxide (0-0.1)Chlorate + (0.7-0.8)Chlorite + (0.1-0.3)Other (Equation 4) Disregarding the other decomposition products yields a conservative estimate for ClO2 as a function of time during decomposition (e.g., actual decomposition will be greater). Removing other decomposition products from Equation 4 yields Equation 5. Diffuser ClO2 concentration can then be determined from Equation 6. The time components of Equations 2 and 3 in combination with velocity in the discharge line is then used to determine the point in the discharge line where ClO2 is < 0.01 mg/L for a given Main Discharge Inlet concentration. Chlorine dioxide = Chlorite (Equation 2) + Chlorate (Equation 3) (Equation 5) Diffuser ClO2 (mg/L) = Main Discharge Inlet ClO2 (mg/L) - Chlorite (mg/L) - Chlorate (mg/L) (Equation 6) 11 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant CALCULATIONS Two separate approaches were utilized to estimate the chlorine dioxide residual throughout the discharge canal and diffuser pipes, as described in the Methodology section. Both approaches are conservative and result in a large margin to control chlorine dioxide residual within the FDEP permit limits. CHLORINE DIOXIDE BEHAVIOR IN THE CANALS Chlorine dioxide losses in the open canal can potentially include the following pathways:

• Dilution from the other condenser water boxes, the other unit, and the ICW discharge water
• Conversion to chlorite and chlorate
• ClO2 gas volatility
• Photodecomposition
• Remaining bulk water biological demand
• Biological demand outside the bulk water (i.e., Biofilm in the canal walls, algae, etc.)

The variability and lack of robust modeling equations for each of these pathways make it challenging to accurately model total ClO2 losses in the open canal. Therefore, the decay rate was determined using empirical data, following the methodology discussed in the section above. The residence time in the canal was previously determined in a study completed by Geosyntec Consultants [3]. Table 3: Residence Times in the Discharge Canal at Low-Tide [3] Segment Dual Unit Operation Single Unit Operation Outfall D-001 to EFF-2 35.5 minutes 33.0 minutes EFF-2 to Main Discharge Inlet 12.0 minutes 9.9 minutes The chlorine monitor is located in the canal at the bridge, measured at 580 ft. from Outfall D-001. Based on the previously determined residence times in the canal, the residence time in the canal to the bridge is 14.6 minutes at low tide with both units in operation (this is the most conservative value because transit times are higher at higher tide levels). Additionally, from the CTCS sampling locations the circulating water travels through a 95 diameter underground pipe, common for each condenser water box, to the discharge canal - a distance of approximately 500 ft. [2, 5]. Based on the flowrates listed in Tables 1 and 2, the approximate residence time in the underground pipe is 1.5 minutes. The CTCS ClO2 measured concentration was corrected for dilution and simultaneous chlorination to an additional condenser water box to estimate the initial ClO2 concentration in the total 12 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant volume of the canal. Key parameters for the dilution calculation are shown below in Table 4 for both dual and single unit operation. Table 4: Raw Water Discharge Dilution Calculation Parameters Dual Unit Single Unit CTCS ClO2 (mg/L) 0.31 0.31 Assumed CTCS ClO2 (mg/L) - 2nd chlorinated pump well 0.31 0.31 CW Pump Well Individual Flow (gpm) 122,650 122,650 CW Pump Well Individual Flow (L/min) 464,230.25 464,230.25 CW Pump Total Flow (gpm) 981,200 490,600 CW Pump Total Flow (L/min) 3,713,842 1,856,921 ICW Total Flow (gpm) 58,000 29,000 ICW Total Flow (L/min) 219,530 109,765 Canal start (diluted to include branches from both units) 0.0732 0.1463 ClO2 (mg/L) A ClO2 decay rate was empirically determined via the change in concentration between the start of the canal and the chlorine monitor located at the bridge over the canal. The segment of enclosed pipe between the CTCS sampling point and the canal was included in the total elapsed time and overall determined decay rate; however, it should be noted the isolated decay rate differs between the canal and the enclosed piping due to the lack of photodecomposition and gas volatility losses to the atmosphere. The chlorine monitor data appeared to be truncated at a total chlorine concentration of 0.012627 mg/L for each peak during CW chlorination (see graphs in Appendix). The chlorine monitor peak concentration was adjusted as follows for each set of data based on pre-CW chlorination standard deviation and minimum concentration in order to obtain a more accurate value for decay rate determination: Adjusted Cl monitor biocide injection peak = (pre-biocide mean + (minimum)) + 2*pre-biocide standard deviation The decay rate was determined for each monthly set of data and averaged for an overall decay rate of 0.0019 mg/L/min. 13 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant 0.12 EFF-2 Main Discharge Canal D-001 Inlet 0.10 0.08 Estimated [ClO2] (mg/L) [ClO2] = -0.0019*[time elapsed] + [Initial ClO2] 0.06 0.04 0.02 0.00 0 10 20 30 40 50 60 Time Elapsed (min) Dual Unit Operation - CTCS ClO2 0.44 mg/L Single Unit Operation - CTCS ClO2 0.20 mg/L Current Dosage - CTCS ClO2 0.31 mg/L (Dual Unit) Figure 4: Empirically Determined ClO2 Decay Rate for Various Initial ClO2 and Operation Statuses As shown in Figure 4, the current dosage will result in a ClO2 concentration at EFF-2 of < 0.01 mg/L. Since the chlorine dioxide dosage may be increased in the future, the maximum CTCS ClO2 concentration was calculated that will still result in a residual ClO2 concentration of < 0.01 mg/L at the end of the canal prior to the diffuser pipes. For dual unit operation, that value is 0.44 mg/L. For single unit operation, it is 0.20 mg/L. Chlorine dioxide quickly decomposes to chlorite (ClO3-) and chlorate (ClO2-), particularly when exposed to sunlight, as shown in Figure 5. The chlorine monitor located at the bridge in the canal measures total chlorine, including chlorite and chlorate. Therefore, the ClO2 concentration at that location is overestimated by using the data collected from the monitor. This conclusion is corroborated by the results of chlorine dioxide decomposition to chlorite and chlorate, as discussed in the following section. 14 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Figure 5: Variation of Residual Chlorine Dioxide Depending on UV [4] CHLORINE DIOXIDE BEHAVIOR IN THE ENCLOSED PIPING LEADING TO THE DIFFUSERS The relationship between Main Discharge Inlet ClO2 concentration and Diffuser ClO2 concentration was developed as described in the Methodology section above and is shown in Figure 6. The Main Discharge Pipe is used as the bounding case because transit times are shorter (yielding less ClO2 decomposition) compared to the Extended Discharge Pipe. The model conservatively predicts that when the Main Discharge Inlet ClO2 concentration is < 0.33 mg/L, the diffuser ClO2 concentration will be < 0.01 mg/L. A concentration of 0.33 mg/L ClO2 at the Main Discharge Inlet translates to 1.79 mg/L at the CTCS for dual unit operation and 0.88 mg/L for single unit operation, per the calculations discussed in the previous section. 1.79 mg/L and 0.88 mg/L are adjusted for dilution into the full canal volume for dual unit and single unit operation, respectively. The resulting values can be input in the equation shown in Figure 4 as [Initial ClO2]. The Main Discharge Inlet concentration is calculated to be 0.33 mg/L at 49.03 minutes for dual unit operation and 44.4 minutes for single unit operation. 15 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Figure 6: Predicted ClO2 Concentration at Diffusers versus Main Discharge Inlet ClO2 Concentration Using the Virginia Tech Model [4] The relationship in Figure 6 can be used to predict the location in the discharge lines where the ClO2 concentration will be < 0.01 mg/L. Key parameters and conversions for the calculation are shown in Table 5, along with assumed canal discharge water chemistry conditions. 16 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Table 5: Key Parameters Used in Main and Extended Discharge Pipe Calculations Main Discharge Pipe Diameter 12 feet Extended Discharge Pipe Diameter 16 feet Main Discharge Pipe Cross-Sectional Area 113.1 ft2 Extended Discharge Pipe Cross-Sectional Area 201.1 ft2 Conversion for ft3 per Gallon of Water 0.13368 ft3/gal

     % of flow entering Main Discharge Pipe                        12.62 Note 1 Length of Main pipe                                               1550           ft Length of Extended pipe                                           3375           ft Condenser Cooling Water Flow (per waterbox)                     122,650        gpm ICW Flow (per unit)                                              29,000        gpm Max Total Cooling Water Flow (minimum transit time)            1,039,200       gpm pH                                                                 7.4          SU TOC                                                                3.0         ppm Temperature                                                       30.0           °C Approximate Transit Times (Geosyntec Report Table 3) [3]
       - Main Pipe                                                      10        minutes
       - Extended Pipe                                                  11        minutes Note 1: Value calculated by iteration to yield calculated transit times that match Geosyntec measured transit times [3].

The velocity in the Main Discharge Pipe is calculated as follows: (1,039,200 gal/min x 12.62/100 x 0.13368 ft3/gal)/(113.1 ft2) = 155.0 ft/min The transit time in the Main Discharge Pipe is calculated as follows: (1550 ft)/(155.0 ft/min) = 10.0 minutes From Figure 6, the model predicts that the diffuser ClO2 concentration will be < 0.01 mg/L when the Main Discharge Inlet ClO2 is 0.33 mg/L. From this relationship, the location in the Main Discharge Line where the ClO2 concentration reaches 0.01 mg/L can be predicted and is shown in Figure 7. For the Extended Discharge Line, the model predicts that the outlet ClO2 concentration will be < 0.01 mg/L when the inlet ClO2 is 0.35 mg/L using the flow balance calculated to attain the transit times noted in the Geosyntec report [3]. From this relationship, the location in the Extended Discharge Line where the ClO2 concentration reaches 0.01 mg/L can be predicted and is shown in Figure 8. 17 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant Figure 7: Location in Main Discharge Pipe where ClO2 Concentration is < 0.01 mg/L (Distance from Inlet in Feet) Figure 8: Location in Extended Discharge Pipe where ClO2 Concentration is < 0.01 mg/L (Distance from Inlet in Feet) 18 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant RESULTS A summary of the major results of this evaluation is provided below:

1. The conservative overall decay rate in the open canal is empirically determined to be 0.0019 mg/L/min.

2. The maximum CTCS ClO2 concentration that will still result in a residual ClO2 concentration of < 0.01 mg/L at the end of the canal (i.e., at the main and extended discharge pipe inlets) is:

a) Dual unit operation: 0.44 mg/L b) Single unit operation: 0.20 mg/L.

3. The Virginia Tech model conservatively predicts that when the Main Discharge Inlet ClO2 concentration is < 0.33 mg/L, the diffuser ClO2 concentration will be < 0.01 mg/L. At the CTCS sampling location, the value is:

a) Dual unit operation: 1.79 mg/L b) Single unit operation: 0.88 mg/L

4. For CTCS ClO2 concentrations between 0.44 mg/L and 1.79 mg/L (dual unit operation) or 0.20 mg/L and 0.88 mg/L (single unit operation), the location in the main and extended discharge lines where the ClO2 concentration is <0.01 mg/L can be determined using Figure 7 (Main Discharge Pipe) and Figure 8 (Extended Discharge Pipe).

CONCLUSIONS Final conclusions from the chlorine dioxide dilution and decay study are listed below:

1. Current CW chlorine dioxide dosages will result in a ClO2 residual of < 0.01 mg/L at EFF-2.

2. Significant margin exists to increase CW chlorine dioxide dosage.

a) CW chlorine dioxide dosages can be increased to a level resulting in 1.79 mg/L at the CTCS during dual unit operation while meeting the FDEP discharge requirements. During single unit operation, CW chlorine dioxide dosages should be halved to continue meeting FDEP discharge requirements.

3. A mixing zone is not required to meet the 0.01 mg/L limit at the discharge to the Atlantic Ocean.

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Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant REFERENCES

1. Notice of Permit Revision FL0002208. Florida Department of Environmental Protection. May 21, 2020.

2. St. Lucie Plant Raw Water Strategic Chemistry Plan.

3. Evaluation of Total Residual Oxidant Attenuation at the St. Lucie Nuclear Power Plant.

Geosnytec Consultants. February 2015.

4. Yoon-jin Lee et.al., Formation of Chlorite and Chlorate from Chlorine Dioxide with Han River Water, Department of Civil and Environment Engineering, Virginia Polytechnic Institute and State University, Blacksburg, VA 24060. Korean J. Chem. Eng., 21(3), 647-653 (2004).

5. Circulating & Intake Cooling Water System Flow Diagram 8770-G-082. Florida Power &

Light Company, St. Lucie Plant. June 2, 2017. 20 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant APPENDIX ICW CHLORINE DIOXIDE DILUTION CALCULATIONS At any given time during CW chlorination the following calculations apply: CW Total Applied Dosage = 0.55 mg/L

• 2 CW pump wells = 1.1 mg/L Total CW Flowrate = 981,200 gpm
• 3.785 L/gal = 3,713,842 L/min 1.1 mg/L
• 3,713,842 L/min = 4,085,226 mg/min ICW Total Applied Dosage = 0.276 mg/L
• 4 ICW pump wells = 1.1 mg/L Total ICW Flowrate = 58,000 gpm
• 3.785 L/gal = 219,530 L/min 1.1 mg/L
• 219,530 L/min = 242,361 mg/min (242,361 mg/min / (242,361 mg/min + 4,085,226 mg/min))
• 100 = 5.6%

ICW chlorine dioxide only contributes 5.6% of the total chlorine dioxide concentration discharged to the canal and therefore does not have a significant effect on total chlorine dioxide residual at EFF-2 or at the Main Discharge Inlet. CTCS AND CHLORINE MONITOR DATA TRENDS 0.013 0.16 0.14 0.0125 0.12 0.012 CTCS ClO2 (mg/L) Cl Monitor (mg/L) 0.1 (minimum) 0.0115 0.08 0.06 0.011 0.04 0.0105 0.02 0.01 0 Cl Monitor (canal) ClO2 (CTCS) Figure 9: CW Chlorination CTCS Residual ClO2 and Chlorine Monitor Trends - 8/19/20 21 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant 0.013 0.35 0.3 0.0125 0.25 0.012 CTCS ClO2 (mg/L) Cl Monitor (mg/L) 0.2 0.0115 0.15 0.011 0.1 0.0105 0.05 0.01 0 Cl Monitor (canal) ClO2 (CTCS) Figure 10: CW Chlorination CTCS Residual ClO2 and Chlorine Monitor Trends - 9/15/20 0.013 0.3 0.0125 0.25 0.012 0.2 CTCS ClO2 (mg/L) Cl Monitor (mg/L) 0.0115 0.15 0.011 0.1 0.0105 0.05 0.01 0 Cl Monitor (canal) ClO2 (CTCS) Figure 11: CW Chlorination CTCS Residual ClO2 and Chlorine Monitor Trends - 10/21/20 22 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant 0.013 0.12 0.0125 0.1 0.012 0.08 CTCS ClO2 (mg/L) Cl Monitor (mg/L) 0.0115 0.06 0.011 0.04 0.0105 0.02 0.01 0 Cl Monitor (canal) ClO2 (CTCS) Figure 12: CW Chlorination CTCS Residual ClO2 and Chlorine Monitor Trends - 11/30/20 0.013 0.07 0.06 0.0125 0.05 0.012 CTCS ClO2 (mg/L) Cl Monitor (mg/L) 0.04 0.0115 0.03 0.011 0.02 0.0105 0.01 0.01 0 Cl Monitor (canal) ClO2 (CTCS) Figure 13: CW Chlorination CTCS Residual ClO2 and Chlorine Monitor Trends - 12/16/20 23 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

Chlorine Dioxide Dilution and Decay Evaluation St. Lucie Nuclear Power Plant 0.013 0.2 0.18 0.0125 0.16 0.14 0.012 CTCS ClO2 (mg/L) Cl Monitor (mg/L) 0.12 0.0115 0.1 0.08 0.011 0.06 0.04 0.0105 0.02 0.01 0 Cl Monitor (canal) ClO2 (CTCS) Figure 14: CW Chlorination CTCS Residual ClO2 and Chlorine Monitor Trends - 1/27/21 24 l 1601 W. DIEHL ROAD NAPERVILLE, IL 60563-1198

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Application Attachment II Chemical List and Safety Data Sheets

PSL IWW Renewal 2021 - Current Chemical List Chemical Name Purpose Concentration Frequency Sulfuric Acid (78%) Chlorine dioxide ClO2 dosage 1.451.6 ppm Daily production to reduce biofouling Sodium Hypochlorite (11 Reduce biofouling Typically <0.01 ppm Total Continuous 14%) Residual Oxidant at D001 PURATE Chlorine dioxide ClO2 dosage 1.451.6 ppm Daily production to reduce biofouling Chlorine Dioxide Reduce biofouling ClO2 dosage 1.451.6 ppm Daily Klaraid Chemical added to Liquid 3.54 ppm (once per Weekly Radioactive (Rad) Waste week) to aid in filtration system prior to and ion exchange. processing through filters and ion exchangers. Boric Acid (100%) Chemicals used in closed Normal operation: 0.01 As required for closed Primary Systems for ppm at D001 primary system control reactivity, pH and corrosion control Lithium Hydroxide (50%) Chemicals used in closed 3.5 ppm upper limit Primary Systems for Normal operations: reactivity, pH and 0.00018 ppm at D001 corrosion control Zinc Acetate Chemicals used in closed Normal operations: Primary Systems for 0.0000004 ppm at the corrosion control POD Hydrogen Peroxide (30%) Expected to decompose 10 ppm Added to 10ppm once and ion exchange out per 18 months per unit prior to reaching the waste system Hydrazine (35%) Chemical used in closed During intermittent Normal concentrations Secondary Systems for pH release: 0.00002 ppm at continuous when and corrosion control; D001 blowdown is aligned to Primary RCS for oxygen During Wet Layup: 0.01 the discharge canal removal ppm at D001 Wet layup concentrations once every 18 months per unit Dimethylamine (DMA) Discontinued use but 0.00048 ppm at D001 Twomonth period prior (2%) with the potential for to an outage, once per 18 future use during normal months per unit. operations Ethanolamine (ETA) Chemical used in closed During intermittent Intermittent release (40%) Secondary systems for pH release: 0.00048ppm at and corrosion control D001 During Wet Layup (once every 18 months per unit): 0.01 ppm at D001 Carbohydrazide (1114%) Chemical used in closed 0.01 ppm at D001 Once per 18 months per Secondary systems for unit

PSL IWW Renewal 2021 - Current Chemical List Chemical Name Purpose Concentration Frequency oxygen and corrosion control Ammonium Hydroxide small quantities to 0.005 ppm at D001 Rarely used (30%) increase Ph 3Methoxypropalamine Potential future use 0.00048 ppm at D001 (MPA) during normal operation Poly(Acrylic Acid) (PAA) Chemical used in 0.00048 ppm at D001 Intermittent release secondary systems for corrosion control Sodium Molybdate (25%) Chemicals used in closed (1601000ppm), typically Once per 18 months per loop cooling systems for 300ppm unit pH and corrosion control Sodium Nitrite (95%) Discontinued, but still (501500ppm), typically No longer used have onsite 250ppm Tolytiazole (50%) Trace amounts 10100 ppm (typically 25ppm) Potassium Hydroxide Small quantities to maintain pH (8.510.5) Sodium Hydroxide Small quantities to maintain pH (8.510.5) Glutaraldehyde Biocides used in closed Never used loop cooling systems for bacterial control (not used in last permit cycle). Controlled and monitored until not detectable. Used if needed for bacterial control. No release by procedure. Isothiazolin Backup to Never used Glutaraldehyde, never used Polyglycol Backup to Glutaraldehyde, never used

Version: 2.0 Revision Date: 01-22-2016 SAFETY DATA SHEET

1. Identification Product identifier: AMMONIUM HYDROXIDE Other means of identification Product No.: 9380, 5800, 0889, 9718, 4807, 3261, 3258, 3256, V222, V188, 6665, H893, 5980, 5820, 5817, 9741, 9733, 9731, 9721, 5604, 5358, 37826 Recommended use and restriction on use Recommended use: Not available.

Restrictions on use: Not known. Details of the supplier of the safety data sheet Manufacturer Company Name: Avantor Performance Materials, Inc. Address: 3477 Corporate Parkway, Suite 200 Center Valley, PA 18034 Telephone: Customer Service: 855-282-6867 Fax: 610-573-2610 Contact Person: Environmental Health & Safety E-mail: info@avantormaterials.com Emergency telephone number: CHEMTREC: 1-800-424-9300 within US and Canada CHEMTREC: 1-703-527-3887 outside US and Canada

2. Hazard(s) identification Hazard Classification Health Hazards Acute toxicity (Oral) Category 4 Skin Corrosion/Irritation Category 1 Serious Eye Damage/Eye Irritation Category 1 Specific Target Organ Toxicity - Category 3 Single Exposure Environmental Hazards Acute hazards to the aquatic Category 1 environment Label Elements Hazard Symbol:

Signal Word: Danger SDS_US - SDSMIX000929 1/10

Version: 2.0 Revision Date: 01-22-2016 Hazard Statement: Harmful if swallowed. Causes severe skin burns and eye damage. May cause respiratory irritation. Very toxic to aquatic life. Precautionary Statement Prevention: Do not breathe dust/fume/gas/mist/vapors/spray. Do not eat, drink or smoke when using this product. Wear protective gloves/protective clothing/eye protection/face protection. Wash hands thoroughly after handling. Avoid release to the environment. Response: IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. Call a POISON CENTER/doctor if you feel unwell. IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower. Wash contaminated clothing before reuse. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Immediately call a POISON CENTER/doctor. IF INHALED: Remove person to fresh air and keep comfortable for breathing. Collect spillage. Storage: Store locked up. Store in a well-ventilated place. Keep container tightly closed. Disposal: Dispose of contents/container to an appropriate treatment and disposal facility in accordance with applicable laws and regulations, and product characteristics at time of disposal. Other hazards which do not None. result in GHS classification:

3. Composition/information on ingredients Mixtures Common name and Chemical Identity CAS number Content in percent (%)*

synonyms AMMONIUM HYDROXIDE 1336-21-6 18 - 72%

• All concentrations are percent by weight unless ingredient is a gas. Gas concentrations are in percent by volume.

4. First-aid measures General information: Get medical advice/attention if you feel unwell. If medical advice is needed, have product container or label at hand.

Ingestion: Call a physician or poison control center immediately. Do not induce vomiting. If vomiting occurs, the head should be kept low so that stomach vomit doesn't enter the lungs. Inhalation: Move to fresh air. Call a physician or poison control center immediately. Apply artificial respiration if victim is not breathing If breathing is difficult, give oxygen. Skin

Contact:

Immediately flush with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Call a physician or poison control center immediately. Wash contaminated clothing before reuse. Destroy or thoroughly clean contaminated shoes. SDS_US - SDSMIX000929 2/10

Version: 2.0 Revision Date: 01-22-2016 Eye contact: Immediately flush with plenty of water for at least 15 minutes. If easy to do, remove contact lenses. Call a physician or poison control center immediately. Most important symptoms/effects, acute and delayed Symptoms: Causes severe skin burns and eye damage. Hazards: Corrosive. Indication of immediate medical attention and special treatment needed Treatment: Treat symptomatically. Symptoms may be delayed.

5. Fire-fighting measures General Fire Hazards: In case of fire and/or explosion do not breathe fumes.

Suitable (and unsuitable) extinguishing media Suitable extinguishing Water spray, fog, CO2, dry chemical, or regular foam. media: Unsuitable extinguishing None known. media: Specific hazards arising from Fire may produce irritating, corrosive and/or toxic gases. the chemical: Special protective equipment and precautions for firefighters Special fire fighting Move containers from fire area if you can do so without risk. Use water procedures: spray to keep fire-exposed containers cool. Cool containers exposed to flames with water until well after the fire is out. Special protective equipment Firefighters must use standard protective equipment including flame for fire-fighters: retardant coat, helmet with face shield, gloves, rubber boots, and in enclosed spaces, SCBA.

6. Accidental release measures Personal precautions, Keep unauthorized personnel away. Keep upwind. Ventilate closed spaces protective equipment and before entering them. Do not touch damaged containers or spilled material emergency procedures: unless wearing appropriate protective clothing. See Section 8 of the SDS for Personal Protective Equipment.

Methods and material for Neutralize with lime or soda ash. Absorb spill with vermiculite or other inert containment and cleaning material, then place in a container for chemical waste. Clean surface up: thoroughly to remove residual contamination. Dike far ahead of larger spill for later recovery and disposal. Notification Procedures: Inform authorities if large amounts are involved. Environmental Precautions: Prevent further leakage or spillage if safe to do so. Do not contaminate water sources or sewer. Avoid discharge into drains, water courses or onto the ground. SDS_US - SDSMIX000929 3/10

Version: 2.0 Revision Date: 01-22-2016

7. Handling and storage Precautions for safe handling: Do not breathe mist or vapor. Do not get in eyes, on skin, on clothing. Do not taste or swallow. Use only with adequate ventilation. Wash hands thoroughly after handling. See Section 8 of the SDS for Personal Protective Equipment.

Conditions for safe storage, Keep container tightly closed. Store in a well-ventilated place. Do not store including any in metal containers. incompatibilities:

8. Exposure controls/personal protection Control Parameters Occupational Exposure Limits Chemical Identity type Exposure Limit Values Source AMMONIUM HYDROXIDE STEL 35 ppm US. ACGIH Threshold Limit Values (2011)

TWA 25 ppm US. ACGIH Threshold Limit Values (2011) STEL 35 ppm 27 mg/m3 US. NIOSH: Pocket Guide to Chemical Hazards (2010) REL 25 ppm 18 mg/m3 US. NIOSH: Pocket Guide to Chemical Hazards (2010) PEL 50 ppm 35 mg/m3 US. OSHA Table Z-1 Limits for Air Contaminants (29 CFR 1910.1000) (02 2006) STEL 35 ppm 27 mg/m3 US. OSHA Table Z-1-A (29 CFR 1910.1000) (1989) Appropriate Engineering No data available. Controls Individual protection measures, such as personal protective equipment General information: Good general ventilation (typically 10 air changes per hour) should be used. Ventilation rates should be matched to conditions. If applicable, use process enclosures, local exhaust ventilation, or other engineering controls to maintain airborne levels below recommended exposure limits. If exposure limits have not been established, maintain airborne levels to an acceptable level. An eye wash and safety shower must be available in the immediate work area. Eye/face protection: Wear safety glasses with side shields (or goggles) and a face shield. Skin Protection Hand Protection: Chemical resistant gloves Other: Wear suitable protective clothing. Respiratory Protection: In case of inadequate ventilation use suitable respirator. Hygiene measures: Provide eyewash station and safety shower. Always observe good personal hygiene measures, such as washing after handling the material and before eating, drinking, and/or smoking. Routinely wash work clothing to remove contaminants. Discard contaminated footwear that cannot be cleaned.

9. Physical and chemical properties Appearance Physical state: liquid Form: liquid Color: Colorless SDS_US - SDSMIX000929 4/10

Version: 2.0 Revision Date: 01-22-2016 Odor: Ammonia odor Odor threshold: No data available. pH: 13.8 Melting point/freezing point: -74.4 °C Initial boiling point and boiling range: 27 °C Flash Point: not applicable Evaporation rate: No data available. Flammability (solid, gas): No data available. Upper/lower limit on flammability or explosive limits Flammability limit - upper (%): No data available. Flammability limit - lower (%): No data available. Explosive limit - upper (%): No data available. Explosive limit - lower (%): No data available. Vapor pressure: 288 kPa Vapor density: No data available. Relative density: 0.90 (20 °C) Solubility(ies) Solubility in water: Completely Soluble Solubility (other): No data available. Partition coefficient (n-octanol/water): No data available. Auto-ignition temperature: No data available. Decomposition temperature: No data available. Viscosity: No data available.

10. Stability and reactivity Reactivity: No dangerous reaction known under conditions of normal use.

Chemical Stability: Material is stable under normal conditions. Possibility of hazardous Hazardous polymerization does not occur. reactions: Conditions to avoid: Excessive heat. Incompatible Materials: Strong oxidizing agents. Acids. Metals. Halogens. Water. Nitromethane. Hazardous Decomposition Nitrogen Oxides ammonia Products:

11. Toxicological information Information on likely routes of exposure Ingestion: Harmful if swallowed. May cause burns of the gastrointestinal tract if swallowed.

Inhalation: Severely irritating to respiratory system. Skin

Contact:

Causes severe skin burns. Eye contact: Causes serious eye damage. SDS_US - SDSMIX000929 5/10

Version: 2.0 Revision Date: 01-22-2016 Information on toxicological effects Acute toxicity (list all possible routes of exposure) Oral Product: LD 50 (Rat): 350 mg/kg Dermal Product: No data available. Inhalation Product: No data available. Repeated dose toxicity Product: No data available. Skin Corrosion/Irritation Product: Causes severe skin burns. Serious Eye Damage/Eye Irritation Product: Causes serious eye damage. Respiratory or Skin Sensitization Product: Not a skin sensitizer. Carcinogenicity Product: This substance has no evidence of carcinogenic properties. IARC Monographs on the Evaluation of Carcinogenic Risks to Humans: No carcinogenic components identified US. National Toxicology Program (NTP) Report on Carcinogens: No carcinogenic components identified US. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050): No carcinogenic components identified Germ Cell Mutagenicity In vitro Product: No mutagenic components identified In vivo Product: No mutagenic components identified Reproductive toxicity Product: No components toxic to reproduction Specific Target Organ Toxicity - Single Exposure Product: Respiratory tract irritation. Specific Target Organ Toxicity - Repeated Exposure Product: None known. Aspiration Hazard Product: Not classified Other effects: None known. SDS_US - SDSMIX000929 6/10

Version: 2.0 Revision Date: 01-22-2016

12. Ecological information Ecotoxicity:

Acute hazards to the aquatic environment: Fish Product: LC 50 (Western mosquitofish (Gambusia affinis), 96 h): 15 mg/l Aquatic Invertebrates Product: LC 50 (Water flea (Daphnia magna), 48 h): 0.66 mg/l Chronic hazards to the aquatic environment: Fish Product: No data available. Aquatic Invertebrates Product: No data available. Toxicity to Aquatic Plants Product: No data available. Persistence and Degradability Biodegradation Product: Expected to be readily biodegradable. BOD/COD Ratio Product: No data available. Bioaccumulative Potential Bioconcentration Factor (BCF) Product: No data available on bioaccumulation. Partition Coefficient n-octanol / water (log Kow) Product: No data available. Mobility in Soil: The product is water soluble and may spread in water systems. Other Adverse Effects: Very toxic to aquatic life.

13. Disposal considerations Disposal instructions: Discharge, treatment, or disposal may be subject to national, state, or local laws.

Contaminated Packaging: Since emptied containers retain product residue, follow label warnings even after container is emptied. SDS_US - SDSMIX000929 7/10

Version: 2.0 Revision Date: 01-22-2016

14. Transport information DOT UN Number: UN 2672 UN Proper Shipping Name: Ammonia solutions Transport Hazard Class(es)

Class(es): 8 Label(s): 8 Packing Group: III Marine Pollutant: Yes Special precautions for user: - IMDG UN Number: UN 2672 UN Proper Shipping Name: AMMONIA SOLUTION (WITH 10-35% AMMONIA) Transport Hazard Class(es) Class(es): 8 Label(s): 8 EmS No.: F-A, S-B Packing Group: III Marine Pollutant: Yes Special precautions for user: - IATA UN Number: UN 2672 Proper Shipping Name: Ammonia solution Transport Hazard Class(es): Class(es): 8 Label(s): 8 Marine Pollutant: Yes Packing Group: III Special precautions for user: -

15. Regulatory information US Federal Regulations TSCA Section 12(b) Export Notification (40 CFR 707, Subpt. D)

US. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050) None present or none present in regulated quantities. CERCLA Hazardous Substance List (40 CFR 302.4): Chemical Identity Reportable quantity AMMONIUM 1000 lbs. HYDROXIDE Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazard categories Acute (Immediate) SARA 302 Extremely Hazardous Substance None present or none present in regulated quantities. SARA 304 Emergency Release Notification Chemical Identity Reportable quantity AMMONIUM 1000 lbs. HYDROXIDE SDS_US - SDSMIX000929 8/10

Version: 2.0 Revision Date: 01-22-2016 SARA 311/312 Hazardous Chemical Chemical Identity Threshold Planning Quantity AMMONIUM HYDROXIDE 10000 lbs SARA 313 (TRI Reporting) Reporting Reporting threshold for threshold for manufacturing and Chemical Identity other users processing AMMONIUM 10000 lbs 25000 lbs. HYDROXIDE Clean Water Act Section 311 Hazardous Substances (40 CFR 117.3) Chemical Identity Reportable quantity AMMONIUM Reportable quantity: 1000 lbs. HYDROXIDE Clean Air Act (CAA) Section 112(r) Accidental Release Prevention (40 CFR 68.130): None present or none present in regulated quantities. US State Regulations US. California Proposition 65 No ingredient regulated by CA Prop 65 present. US. New Jersey Worker and Community Right-to-Know Act Chemical Identity Water AMMONIUM HYDROXIDE US. Massachusetts RTK - Substance List Chemical Identity AMMONIUM HYDROXIDE US. Pennsylvania RTK - Hazardous Substances Chemical Identity Water AMMONIUM HYDROXIDE US. Rhode Island RTK Chemical Identity AMMONIUM HYDROXIDE Inventory Status: Australia AICS: On or in compliance with the inventory Canada DSL Inventory List: On or in compliance with the inventory EINECS, ELINCS or NLP: On or in compliance with the inventory Japan (ENCS) List: On or in compliance with the inventory China Inv. Existing Chemical Substances: Not in compliance with the inventory. Korea Existing Chemicals Inv. (KECI): On or in compliance with the inventory Canada NDSL Inventory: Not in compliance with the inventory. Philippines PICCS: On or in compliance with the inventory US TSCA Inventory: On or in compliance with the inventory New Zealand Inventory of Chemicals: On or in compliance with the inventory Japan ISHL Listing: Not in compliance with the inventory. Japan Pharmacopoeia Listing: Not in compliance with the inventory. 16.Other information, including date of preparation or last revision SDS_US - SDSMIX000929 9/10

Version: 2.0 Revision Date: 01-22-2016 NFPA Hazard ID 1 Flammability Health 3 0 Reactivity Special hazard. Hazard rating: 0 - Minimal; 1 - Slight; 2 - Moderate; 3 - Serious; 4 - Severe; RNP - Rating not possible Issue Date: 01-22-2016 Revision Date: No data available. Version #: 2.0 Further Information: No data available. Disclaimer: THE INFORMATION PRESENTED IN THIS MATERIAL SAFETY DATA SHEET (MSDS/SDS) WAS PREPARED BY TECHNICAL PERSONNEL BASED ON DATA THAT THEY BELIEVE IN THEIR GOOD FAITH JUDGMENT IS ACCURATE. HOWEVER, THE INFORMATION PROVIDED HEREIN IS PROVIDED AS IS, AND AVANTOR PERFORMANCE MATERIALS MAKES AND GIVES NO REPRESENTATIONS OR WARRANTIES WHATSOEVER, AND EXPRESSLY DISCLAIMS ALL WARRANTIES REGARDING SUCH INFORMATION AND THE PRODUCT TO WHICH IT RELATES, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WITHOUT LIMITATION, WARRANTIES OF ACCURACY, COMPLETENESS, MERCHANTABILITY, NON-INFRINGEMENT, PERFORMANCE, SAFETY, SUITABILITY, STABILITY, AND FITNESS FOR A PARTICULAR PURPOSE, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING, COURSE OF PERFORMANCE, OR USAGE OF TRADE. THIS MSDS/SDS IS INTENDED ONLY AS A GUIDE TO THE APPROPRIATE PRECAUTIONARY HANDLING OF THE MATERIAL BY A PROPERLY TRAINED PERSON USING THIS PRODUCT, AND IS NOT INTENDED TO BE COMPREHENSIVE AS TO THE MANNER AND CONDITIONS OF USE, HANDLING, STORAGE, OR DISPOSAL OF THE PRODUCT. INDIVIDUALS RECEIVING THIS MSDS/SDS MUST ALWAYS EXERCISE THEIR OWN INDEPENDENT JUDGMENT IN DETERMINING THE APPROPRIATENESS OF SUCH ISSUES. ACCORDINGLY, AVANTOR PERFORMANCE MATERIALS ASSUMES NO LIABILITY WHATSOEVER FOR THE USE OF OR RELIANCE UPON THIS INFORMATION. NO SUGGESTIONS FOR USE ARE INTENDED AS, AND NOTHING HEREIN SHALL BE CONSTRUED AS, A RECOMMENDATION TO INFRINGE ANY EXISTING PATENTS OR TO VIOLATE ANY FEDERAL, STATE, LOCAL, OR FOREIGN LAWS. AVANTOR PERFORMANCE MATERIALS REMINDS YOU THAT IT IS YOUR LEGAL DUTY TO MAKE ALL INFORMATION IN THIS MSDS/SDS AVAILABLE TO YOUR EMPLOYEES. SDS_US - SDSMIX000929 10/10

BORIC ACID NS According to Reg. CE n° 1907/2006 (REACH) and to Reg.CE n°453/2010 Safety Data Sheet Emission: January 1994 Revision n. 16: October 2013 1.IDENTIFICATION OF THE SUBSTANCE AND OF THE COMPANY 1.1 Identification of substance: 1.3 Company identification: Commercial Name: Boric Acid NS SOCIETA CHIMICA LARDERELLO spa Chemical Formula: H3BO3 Headquarter: Via G. Fara n. 28 - 24124 Milano,ITALY Chemical Name/synonyms: Boric acid, Tel. +39-02-677168.1 Fax +39-02-677168.20 Orthoboric acid, Boracic acid http://www.scl.it - http://www.fertiglobal.it Chemical Family: Inorganic Borates REACH registration N°: 01-2119486683-25-0026 e-mail : bianchi@scl.it CAS registry N°: 10043-35-3 EINECS N°: 233-139-2 1.4 Emergency phone numbers: Centro Antiveleni : +39-0554277238 1.2 Use of the substance: (SERVIZIO AUTONOMO DI TOSSICOLOGIA USL 10 End uses : Abrasives, Adhesives, Autocausticising, Brake D/UNIVERSIT DEGLI STUDI DI FIRENZE fluids, Carburizing pastes, Catalysts, Ceramic glazes and frits, VIALE PIERACCINI 17 FIRENZE ) Construction materials, Cosmetics & Pharmaceuticals, Detergents and cleaners, Engine coolants, Fertilizers, Flame SCL spa : +39-02-677168.21 retardants, Glass, Intumescent Paints, Lubricants and greases, Metallurgical flux, Nuclear applications, pH Buffers, Polymer production, Printing inks, Reagent chemicals, Refractory products, Water treatment chemicals, Wallboard

2. HAZARDS IDENTIFICATION 2.1 Hazard classification: HAZARDOUS 2.3 Other dangers:

Toxic to Reproduction May damage fertility or the unborn child. Environment: Large amounts of boric acid can be harmful to plants and other species. Therefore releases to the

2.2 Label

environment should be minimised. (See sec. 12) Societ Chimica Larderello spa - Headquarter: Via G. Fara n. 28 Reproductive/Developmental: 20124 Milano Tel. 02/67716820 - Plant:Piazza Leopolda n. 2 Animal Data: Animal feeding studies in rat, mouse and 56044 Larderello (PI) Italia Tel. 0588/68811 dog, at high doses, have demonstrated effects on fertility and testes. Studies in rat, mouse and rabbit, at high doses, Dir. 67/548/CEE CLP (GHS08) demonstrate developmental effects on the foetus including foetal weight loss and minor skeletal variations. The doses administered were many times in excess of T Danger those which humans would normally be exposed to . Human data: Human epidemiological studies show no increase in pulmonary disease in occupational populations with chronic exposures to boric acid dust and sodium borate dust. Recent epidemiology studies under the conditions of normal occupational exposure to borate dusts indicated no effect on fertility. R60 - R61 Category 1b, H360FD PBT or vPvB: substance is not PBT or vPvB S53 - S45 P201,308+313 Restricted to professional users Identifier N° EINECS N° CAS Boric Acid 233-139-2 10043-35-3 SDS-C0101 Boric Acid NS - EN - 2013.doc Pag.1 di 6

BORIC ACID NS According to Reg. CE n° 1907/2006 (REACH) and to Reg.CE n°453/2010

3. COMPOSITION/INFORMATION ON INGREDIENTS Hazard R Chemical Name Conc. (%) N° EINECS N° CAS Category Symbol statement phrases Boric Acid > 99.9 233-139-2* 10043-35-3 Repr. Cat. 1B H360FD T R60-61 Concentration limits: if used in mixtures (preparations) and the Boric Acid concentration is C 5.5 % , the final mixture (preparation) has to be classified as Toxic to Reproduction , Categ. 1B, H360FD ( category 2 - R60-R61 , according the old Directive 67/548/CEE)

*For one EINECS number you can have more than one CAS number .

4 FIRST AID MEASURES 4.1 Description of first aid measures: Eye contact: it can be slightly irritant , rarely it can cause redness. Use eye wash fountain or fresh water to clean the The product is a white odourless, powdered substance that eyes. If irritation persists for more than 30 minutes, seek is not flammable, combustible, or explosive, and has low medical attention. acute oral and dermal toxicity. Usually no assistance by a doctor is required. For ingestion in Skin contact: Dermal exposure is not usually a concern excess of 5-6 grams of Boric Acid , maintain adequate kidney because Boric Acid is poorly absorbed through intact skin. function and force fluid. Gastric lavage is recommended for No treatment is necessary because non-irritating. To wash symptomatic patients only. Haemodialysis should be reserved the area with soap and abundant water some minutes . for massive acute ingestion or patients with renal failure. Possibly move the person to fresh air . Ingestion: The product is not intended for ingestion. Small 4.2 Symptoms and effects: amounts swallowed accidentally are not likely to cause effects. Swallowing amounts larger than that may cause Inhalation: Accidental inhalation may cause light irritation gastrointestinal symptoms . Give two glasses of water or to the first respiratory system. If symptoms such as nose milk to drink and seek medical attention. or throat irritation are observed, remove person to fresh air . No specific treatment is necessary. 5 FIREFIGHTING MEASURES The substance is not flammable, combustible or explosive 5.2 Fire derived risks: (some boron products are used as a flame retardant) 5.2.1 To the product itself : no effect 5.2.2. Products of combustion: The substance gradually loses 5.1 Appropriate extinguishing means and procedures: its own water of crystallization when heated Any fire extinguishing media may be used on nearby fires. 5.2.3. From fumes: no effect Forbidden extinguishing means: All means can be used. 5.3 Recommendations: To be sure that masks must protect from fire gases . 6 ACCIDENTAL RELEASE MEASURES 6.1 Personal precautions: 6.3 Methods for cleaning: Collect product into a suitable Wear goggles (class P3) and glasses when exposure is receptacle and dispose of as in section 13; wash the area with prolonged and high is concentration in the air. water, taking the appropriate precautions against pollution. Not to unload residuals in drain. 6.2 Environmental precautions : Confine spillage to avoid contamination of water bodies. Do not disperse waste in the environment or in drain. SDS-C0101 Boric Acid NS - EN - 2013.doc Pag.2 di 6

BORIC ACID NS According to Reg. CE n° 1907/2006 (REACH) and to Reg.CE n°453/2010 7 HANDLING AND STORAGE

7.1 Handling

Use the product in accordance with good 7.2 Storage: working practice, avoiding dispersal into the environment. Store in cool, dry and well-ventilated place, away from strong Handle the product in a well-ventilated and well-aerated reducing agents ; keep preferably at a temperature between location. Carefully rinse hands after handling and before 20°C and 25°C;To avoid: eating, drinking or smoking. - high air humidity

                                                                     - sunlight exposure
                                                                     - temperatures under -5 °C and over 40°C .

8 EXPOSURE CONTROLS/ PERSONAL PROTECTION 8.1 Exposure limit values: (b) Respiratory protection: Wear protective masks 3 TLV - TWA: 2 mg/m (ACGIH) (class FFP3) for long exposures and high 3 TLV - TWA: 5 mg/m (recommended by SCL) concentration levels DNEL : N.D. PNEC : N.D. (c) Eye protection: Wear security glasses for long exposures and high concentration levels . 8.2 Exposure controls 8.2.1 Occupational exposure controls: (d) Skin protection: Wear conventional working clothes. (a) Hand protection : the use of gloves for chemical 8.2.2. Environmental exposure controls protection is suggested .Wash hands after contact Respect all standards and laws concerning emission limits in with material .Do not eat or smoke while handling the atmosphere and waters (see sec.16) the product. Wash hands before eating and at the end of the work shift. 9 PHISICAL AND CHEMICAL PROPERTIES 9.1 General information Solubility: Appearance: white powder ; - Water solubility: Odour: Odourless at 20°C : 49.2 g/l H2O 9.2 Important health, safety and environmental at 100°C : 379.9 g/l H2O informations

                                                                      - soluble in ethylene glycol, glycerine, lightly in alcohols pH at 20°C:

Partition coefficient octanol/water : Concentration 1 g/L= 6.1 Log Pow : - 1.09 at 25°C Concentration 10 g/L = 5.1 Viscosity: N.D. Concentration 46,5 g/L = 3.7 (saturated solution) Evaporation rate: N.A. Boiling point: N.A. Flammability point: N.A. 9.3 Other Informations Flammability: Does not contain organic solvents Not flammable Melting point: 184°C Not combustible Specific gravity (14°C) : 1.51 Explosive properties: N.A. Molecular weight : 61.83 Comburent properties: N.A. Vapour pressure: 0.000099 Pa at 25°C Bulk Density: 1489 kg/m³ at 23 °C Relative density : 1.49 at 23 °C 10 STABILITY AND REACTIVITY The substance is stable in the suggested conditions ( see 10.2 Materials to avoid: The substance reacts as a weak acid section 7). which may cause corrosion of base metals. Reaction with strong reducing agents such as metal hydrides or alkali metals 10.1 Conditions to avoid: High temperatures and direct will generate hydrogen gas which could create an explosive contact with fire or heat sources .Boric acid is a stable hazard. product, but when heated it loses water, first forming metaboric acid (HBO2), and on further heating it is converted 10.3 Hazardous decomposition products: None into boric oxide (B2O3). SDS-C0101 Boric Acid NS - EN - 2013.doc Pag.3 di 6

BORIC ACID NS According to Reg. CE n° 1907/2006 (REACH) and to Reg.CE n°453/2010 11 TOXICOLOGICAL INFORMATIONS According to currently available data, this product has not yet Chronic toxicity: Extremely rare chronic poisonings can produced health damages. Anyway, it must be handled cause gastrointestinal symptoms carefully according to good industrial practices. This substance may have health effects on sensitive people, by Sensitising properties: No evidence found. inhalation and/or contact with eyes and/or ingestion. Carcinogenicity: No evidence found. Means of exposure: ingestion, inhalation and trough not intact skin Mutagenicity: No evidence found. Corrosiveness/Irritant properties: Reproductive toxicity: slightly irritant to eyes and first respiratory system Animal Data: Animal feeding studies in rat, mouse and dog, at high doses, have demonstrated effects on fertility and Acute toxicity: testes. Studies in rat, mouse and rabbit, at high doses,

- Ingestion : Low acute oral toxicity;                                 demonstrate developmental effects on the foetus including The ingestion can provoke disturbs to the health, that             foetal weight loss and minor skeletal variations. The doses they comprise abdominal pains with sting, nausea and               administered were many times in excess of those which vomit ; 3500 mg/kg < LD50 (rat) < 4100 mg/kg.                      humans would normally be exposed to .

- Inhalation : Low acute inhalation toxicity ; Human data: Human epidemiological studies show no The inhalation of vapours causes irritation of the inferior increase in pulmonary disease in occupational populations and advanced respiratory system with cough and with chronic exposures to boric acid dust and sodium respiratory difficulty; at elevated concentrations may borate dust. Recent epidemiology studies under the cause also edema pulmonary. LC50 (rat) >> 2 g/m3. conditions of normal occupational exposure to borate dusts - Eye irritation: Non-irritant. Fifty years of indicated no effect on fertility. occupational exposure to boric acid indicate no adverse effects on human eye. - Skin irritation: non-irritant. LD50(Rat) >> 2000 mg/Kg 12 ECOLOGICAL INFORMATIONS 12.1 Eco-toxicity Fish toxicity Boron occurs naturally in sea water at an average Sea water: concentration of 5 mg B/l and fresh water at 1 mg B/l or less. Dab, Limanda limanda 96-hr LC50 = 74 mg B/l In dilute aqueous solutions the predominant boron species present is undissociated boric acid. To convert boric acid into Fresh water: equivalent boron (B) content, multiply by 0.1748. Rainbow trout, Salmo gairdneri (embryo-larval stage) 24-day LC50 = 150 mg B/l Phytotoxicity: 32-day LC50 = 100 mg B/l Boron is an essential micronutrient for healthy growth of Goldfish, Carassius auratus (embryo-larval stage) plants, however, it can be harmful to boron sensitive plants in 7-day LC50 = 46 mg B/l higher quantities. Care should be taken to minimize the 3-day LC50 = 178 mg B/l amount of borate product released to the environment. Test substance: Sodium tetraborate Algal toxicity Boric acid Green algae, Scenedesmus subspicatus 96-hr EC10 = 24 mg B/1 12.2 Soil Mobility: Nutriment for species vegetables. The product is soluble in water and is leachable through Invertebrate toxicity normal soil Daphnids, Daphnia magna Straus 48-hr LC50 = 133 mg B/1 12.3 Persistence and degradability: Boron is naturally 21-day NOEC-LOEC = 6-13 mg B/l occurring and ubiquitous in the environment. Boric acid decomposes in the environment to natural borate. 12.4 Bioaccumulation potential: there is no bioaccumulation 12.5 PBT evaluation results : Not persistent and not bioaccumulable SDS-C0101 Boric Acid NS - EN - 2013.doc Pag.4 di 6

BORIC ACID NS According to Reg. CE n° 1907/2006 (REACH) and to Reg.CE n°453/2010 13 DISPOSAL CONSIDERATIONS 13.1 Disposal of the substance 13.2 Contaminated packaging In accordance with applicable local regulations .Not disperse Special waste to be taken to authorized disposal . in city drain or water course. Small quantities of boric acid can usually be disposed of at landfill sites. No special disposal treatment is required. Tonnage quantities of product are not recommended to be sent to landfills. 14 TRANSPORT INFORMATIONS International transportation : Boric Acid has no an UN Number, 14.1 Classification: N.A. and is not regulated under international rail, road, water or air transport regulations. 15 REGULATORY INFORMATIONS 15.1 Norms and Regulation Clean Air Act (Montreal Protocol) Boric acid was not manufactured with and does not contain Italian legislation any Class I or Class II ozone depleting substances. Cosmetics - D.Lgs.152/06 Testo Unico Ambiente e successive The EC Directive 76/768/EEC sets an upper limit of 5% Boric modificazioni ed integrazioni. acid in talcs, 0.5% in oral hygiene products and 3% in other - Dlg. 28/07/04 n° 260 products. In addition, the talcs should not be used on children - D.Lgs. 81/2008 Testo Unico della Sicurezza e successive under 3 years of age. modifiche ed integrazioni Restrictions: European and International legislation Boric Acid is listed on annex XVII, appendix 6 of Reg.(EU) n. 1907/2006 (REACH).Please check also Regulation (EU)

-     Reg. CE n° 1907/2006 (REACH) and following                 109/2012 - Restriction on consumer uses above the specific amendments                                                 concentration limit.
-     CLP regulation and following amendments
-     Reg.CE n° 790/2009 and following amendments                     Chemical Safety evaluation
-     Reg.CE n°453/2010 and following amendments                  Due to the number of pages it is not possible to attach CSE.
-     Dir. 1999/45/CE and following amendments;                   Please ask for an electronic copy to info@scl.it.
-     Dir. 67/548/CEE and following amendments ;

Chemical inventory listing This SDS is in conformance with Reg. CE n° 1907/2006 - U.S. EPA TSCA Inventory 10043-35-3 (REACH) , Reg.CE n°453/2010 and Reg.CE n° 790/2009 - Canadian DSL 10043-35-3

                                                                 - EINECS                        233-139-2
                                                                 - South Korea                   1-439
                                                                 - Japanese MITI                 (1)-63 SDS-C0101 Boric Acid NS - EN - 2013.doc                                                                                  Pag.5 di 6

BORIC ACID NS According to Reg. CE n° 1907/2006 (REACH) and to Reg.CE n°453/2010 16 OTHER INFORMATIONS 16.1 MEANING OF ASSIGNED H SENTENCES : 16.6 SANITATION CONTROLS :

                                                                - table D.P.R.303/56 and following amendments: substance Hazard statement                                                 ingredients are not included in the Table .Anyway clinical H360: May damage fertility or the unborn child                   cchecks are suggested according the results of Chemical risk evaluation (D.Lgs. 81/2008)

Risk Phrases : R60 : may impair fertility 16.7 OBLIGATORY INSURANCE R 61: may cause harm to the unborn child - D.P.R.1124/65 and following amendments: substance ingredients are not included in that Table of 16.2 MEANING OF ASSIGNED P SENTENCES industrial professional sickness. Precautionary Statement Prevention 16.8 COMPANY RESPONSIBLE SERVICE : P201 : Obtain special instructions before use HSE & Quality Director P308+313: If exposed or concerned , get medical Tel. +39-0588-68803 -0267716821 advice/attention. Fax +39-0588-68860 Safety Phrases : HSE & Quality Department S53 : Avoid exposure - obtain special instructions before use. Tel. +39-0588-68802; Fax +39-0588-68860 S45 : In case of accident or if you feel unwell, seek medical advice immediately (show the label possible). 16.9 ABBREVIATIONS:

                                                                - N.A. : Not applicable
                                                                - N.D. : Not determined; Not available 16.3 TRAINING ADVICE :

Reg. CE n° 1907/2006 (REACH) and following All information on this SAFETY DATA SHEET are, to the best of amendments our knowledge , correct, but should not be considered CLP regulation and following amendments exhaustive. It is the user's responsibility to adopt and apply this Reg.CE n° 790/2009 and following amendments data as appropriate. Reg.CE n°453/2010 and following amendments Dir. 1999/45/CE and following amendments; Societ Chimica Larderello spa assumes no responsibility for Dir. 67/548/CEE and following amendments ; damages to persons or goods resulting from the incorrect handling of this product. 16.4 GENERAL BIBLIOGRAPHY The Merck Index.; Handling Chemical Safety; Niosh (Registry of Toxic Effects of Chemical substances); ELINCS (http://ecb.jrc.it/existing-chemicals/) Software Epy-plus ; ELINCS ACGIH TLV & IBE ECHA website SDS-C0101 Boric Acid NS - EN - 2013.doc Pag.6 di 6

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max Section: 1. PRODUCT AND COMPANY IDENTIFICATION Product name  : Chlorine Dioxide Dissolved in water 4000 ppm max Other means of identification  : Not applicable. Restrictions on use  : Refer to available product literature or ask your local Sales Representative for restrictions on use and dose limits. Company  : Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 USA TEL: (630)305-1000 Emergency telephone  : (800) 424-9300 (24 Hours) CHEMTREC number Issuing date  : 11/10/2014 Section: 2. HAZARDS IDENTIFICATION GHS Classification Not a hazardous substance or mixture. GHS Label element Precautionary Statements  : Prevention: Wash hands thoroughly after handling.

Response

Specific measures: consult MSDS Section 4. Storage: Store in accordance with local regulations. Other hazards  : None known. Section: 3. COMPOSITION/INFORMATION ON INGREDIENTS Pure substance/mixture  : Mixture Chemical Name CAS-No. Concentration: (%) Chlorine Dioxide 10049-04-4 <= 0.4 Section: 4. FIRST AID MEASURES In case of eye contact  : Rinse with plenty of water. Get medical attention if symptoms occur. In case of skin contact  : Wash off with soap and plenty of water. Get medical attention if symptoms occur. If swallowed  : Rinse mouth. Get medical attention if symptoms occur. If inhaled  : Get medical attention if symptoms occur. Protection of first-aiders  : In event of emergency assess the danger before taking action. Do 1/8

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max not put yourself at risk of injury. If in doubt, contact emergency responders.Use personal protective equipment as required. Notes to physician  : Treat symptomatically. Most important symptoms  : See Section 11 for more detailed information on health effects and and effects, both acute and symptoms. delayed Section: 5. FIREFIGHTING MEASURES Suitable extinguishing media : Use extinguishing measures that are appropriate to local circumstances and the surrounding environment. Unsuitable extinguishing  : None known. media Specific hazards during  : Not flammable or combustible. firefighting Hazardous combustion  : Carbon oxides products Special protective equipment : Use personal protective equipment. for firefighters Specific extinguishing  : Fire residues and contaminated fire extinguishing water must methods be disposed of in accordance with local regulations. Section: 6. ACCIDENTAL RELEASE MEASURES Personal precautions,  : Refer to protective measures listed in sections 7 and 8. protective equipment and emergency procedures Environmental precautions  : No special environmental precautions required. Methods and materials for  : Stop leak if safe to do so. Contain spillage, and then collect with containment and cleaning up non-combustible absorbent material, (e.g. sand, earth, diatomaceous earth, vermiculite) and place in container for disposal according to local / national regulations (see section 13). Flush away traces with water. For large spills, dike spilled material or otherwise contain material to ensure runoff does not reach a waterway. Section: 7. HANDLING AND STORAGE Advice on safe handling  : For personal protection see section 8. Wash hands after handling. Conditions for safe storage  : Keep away from strong bases. Keep out of reach of children. Keep container tightly closed. Store in suitable labeled containers. Suitable material  : The following compatibility data is suggested based on similar product data and/or industry experience: Compatibility with Plastic Materials can vary; we therefore recommend that compatibility is tested prior to use. Unsuitable material  : not determined 2/8

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max Section: 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Components with workplace control parameters Exposure guidelines have not been established for this product. Available exposure limits for the substance(s) are shown below. Basis Components CAS-No. Form of Permissible exposure concentration Chlorine Dioxide 10049-04-4 TWA 0.1 ppm ACGIH STEL 0.3 ppm ACGIH STEL 0.3 ppm NIOSH REL 0.9 mg/m3 TWA 0.1 ppm NIOSH REL 0.3 mg/m3 TWA 0.1 ppm OSHA Z1 0.3 mg/m3 Engineering measures  : Good general ventilation should be sufficient to control worker exposure to airborne contaminants. Personal protective equipment Eye protection  : Safety glasses Hand protection  : Wear protective gloves. Gloves should be discarded and replaced if there is any indication of degradation or chemical breakthrough. Skin protection  : Wear suitable protective clothing. Respiratory protection  : No personal respiratory protective equipment normally required. Hygiene measures  : Wash hands before breaks and immediately after handling the product. Section: 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance  : Liquid Colour  : Light yellow Odour  : Chlorine Flash point  : does not flash pH  : no data available Odour Threshold  : no data available Melting point/freezing point  : no data available Initial boiling point and boiling : no data available range Evaporation rate  : no data available Flammability (solid, gas)  : no data available Upper explosion limit  : no data available Lower explosion limit  : no data available 3/8

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max Vapour pressure  : 5.0 mm Hg (25.0 °C) Relative vapour density  : no data available Relative density  : no data available Density  : no data available Water solubility  : completely soluble Solubility in other solvents  : no data available Partition coefficient: n-  : no data available octanol/water Auto-ignition temperature  : no data available Thermal decomposition  : no data available temperature Viscosity, dynamic  : no data available Viscosity, kinematic  : no data available VOC  : 0% Section: 10. STABILITY AND REACTIVITY Chemical stability  : Stable under normal conditions. Possibility of hazardous  : No dangerous reaction known under conditions of normal use. reactions Conditions to avoid  : None known. Incompatible materials  : Do not bring in contact with organic materials and reducing agents. Hazardous decomposition  : Chlorine, Chlorine dioxide products Carbon oxides Section: 11. TOXICOLOGICAL INFORMATION Information on likely routes of : Inhalation, Eye contact, Skin contact exposure Potential Health Effects Eyes  : Health injuries are not known or expected under normal use. Skin  : Health injuries are not known or expected under normal use. Ingestion  : Health injuries are not known or expected under normal use. Inhalation  : Health injuries are not known or expected under normal use. Chronic Exposure  : Health injuries are not known or expected under normal use. Experience with human exposure Eye contact  : No symptoms known or expected. Skin contact  : No symptoms known or expected. Ingestion  : No symptoms known or expected. 4/8

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max Inhalation  : No symptoms known or expected. Toxicity Product Acute oral toxicity  : Acute toxicity estimate : > 5,000 mg/kg Acute inhalation toxicity  : Acute toxicity estimate : > 40 mg/l Exposure time: 4 h Acute toxicity estimate : > 40 mg/l Exposure time: 4 h Acute dermal toxicity  : no data available Skin corrosion/irritation  : no data available Serious eye damage/eye  : no data available irritation Respiratory or skin  : no data available sensitization Carcinogenicity  : no data available Reproductive effects  : no data available Germ cell mutagenicity  : no data available Teratogenicity  : no data available STOT - single exposure  : Based on available data, the classification criteria are not met. STOT - repeated exposure  : no data available Aspiration toxicity  : no data available Section: 12. ECOLOGICAL INFORMATION Ecotoxicity Environmental Effects  : This product has no known ecotoxicological effects. Components Toxicity to fish  : Chlorine Dioxide LC50 Fish: 0.03 mg/l Exposure time: 96 h Persistence and degradability Greater than 95% of this product consists of inorganic substances for which a biodegradation value is not applicable. Mobility 5/8

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air  : <5% Water  : 30 - 50% Soil  : 50 - 70% The portion in water is expected to be soluble or dispersible. Bioaccumulative potential This preparation or material is not expected to bioaccumulate. Other information no data available Section: 13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261, since it does not have the characteristics of Subpart C, nor is it listed under Subpart D. Disposal methods  : Where possible recycling is preferred to disposal or incineration. If recycling is not practicable, dispose of in compliance with local regulations. Dispose of wastes in an approved waste disposal facility. Disposal considerations  : Dispose of as unused product. Empty containers should be taken to an approved waste handling site for recycling or disposal. Do not re-use empty containers. Section: 14. TRANSPORT INFORMATION The shipper/consignor/sender is responsible to ensure that the packaging, labeling, and markings are in compliance with the selected mode of transport. Land transport (DOT) Proper shipping name  : PRODUCT IS NOT REGULATED DURING TRANSPORTATION Air transport (IATA) Proper shipping name  : PRODUCT IS NOT REGULATED DURING TRANSPORTATION Sea transport (IMDG/IMO) Proper shipping name  : PRODUCT IS NOT REGULATED DURING TRANSPORTATION 6/8

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max Section: 15. REGULATORY INFORMATION EPCRA - Emergency Planning and Community Right-to-Know Act CERCLA Reportable Quantity This material does not contain any components with a CERCLA RQ. SARA 304 Extremely Hazardous Substances Reportable Quantity This material does not contain any components with a section 304 EHS RQ. SARA 311/312 Hazards  : Acute Health Hazard SARA 302  : No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302. SARA 313  : This material does not contain any chemical components with known CAS numbers that exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313. California Prop 65 This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm. INTERNATIONAL CHEMICAL CONTROL LAWS : AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS). CHINA All substances in this product comply with the Provisions on the Environmental Administration of New Chemical Substances and are listed on or exempt from the Inventory of Existing Chemical Substances China (IECSC). JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Existing and New Chemical Substances list (ENCS). KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL) NEW ZEALAND All substances in this product comply with the Hazardous Substances and New Organisms (HSNO) Act 1996,and are listed on or are exempt from the New Zealand Inventory of Chemicals. PHILIPPINES This product contains substance(s) which are not in compliance with the Republic Act 6969 (RA 6969) and may require additional review. Section: 16. OTHER INFORMATION 7/8

SAFETY DATA SHEET Chlorine Dioxide Dissolved in water 4000 ppm max NFPA: HMIS III: Flammability HEALTH 1 0 Health Instability 0 0 FLAMMABILITY 0 PHYSICAL HAZARD 0 0 = not significant, 1 =Slight, 2 = Moderate, 3 = High Special hazard. 4 = Extreme, * = Chronic Revision Date  : 11/10/2014 Version Number  : 1.1 Prepared By  : Regulatory Affairs REVISED INFORMATION: Significant changes to regulatory or health information for this revision is indicated by a bar in the left-hand margin of the SDS. The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. For additional copies of an MSDS visit www.nalco.com and request access. 8/8

SIGMA-ALDRICH sigma-aldrich.com SAFETY DATA SHEET Version 4.8 Revision Date 02/22/2015 Print Date 02/07/2016

1. PRODUCT AND COMPANY IDENTIFICATION 1.1 Product identifiers Product name  : Dimethylamine solution Product Number  : 426458 Brand  : Aldrich 1.2 Relevant identified uses of the substance or mixture and uses advised against Identified uses  : Laboratory chemicals, Manufacture of substances 1.3 Details of the supplier of the safety data sheet Company  : Sigma-Aldrich 3050 Spruce Street SAINT LOUIS MO 63103 USA Telephone  : +1 800-325-5832 Fax  : +1 800-325-5052 1.4 Emergency telephone number Emergency Phone #  : (314) 776-6555

2. HAZARDS IDENTIFICATION 2.1 Classification of the substance or mixture GHS Classification in accordance with 29 CFR 1910 (OSHA HCS)

Flammable liquids (Category 2), H225 Skin corrosion (Category 1B), H314 Serious eye damage (Category 1), H318 Specific target organ toxicity - single exposure (Category 3), Respiratory system, H335 Acute aquatic toxicity (Category 2), H401 Chronic aquatic toxicity (Category 3), H412 For the full text of the H-Statements mentioned in this Section, see Section 16. 2.2 GHS Label elements, including precautionary statements Pictogram Signal word Danger Hazard statement(s) H225 Highly flammable liquid and vapour. H314 Causes severe skin burns and eye damage. H318 Causes serious eye damage. H335 May cause respiratory irritation. H401 Toxic to aquatic life. H412 Harmful to aquatic life with long lasting effects. Precautionary statement(s) P210 Keep away from heat/sparks/open flames/hot surfaces. - No smoking. P233 Keep container tightly closed. P240 Ground/bond container and receiving equipment. Aldrich - 426458 Page 1 of 9

P241 Use explosion-proof electrical/ ventilating/ lighting/ equipment. P242 Use only non-sparking tools. P243 Take precautionary measures against static discharge. P261 Avoid breathing dust/ fume/ gas/ mist/ vapours/ spray. P264 Wash skin thoroughly after handling. P271 Use only outdoors or in a well-ventilated area. P273 Avoid release to the environment. P280 Wear protective gloves/ protective clothing/ eye protection/ face protection. P301 + P330 + P331 IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. P303 + P361 + P353 IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower. P304 + P340 + P310 IF INHALED: Remove person to fresh air and keep comfortable for breathing. Immediately call a POISON CENTER or doctor/ physician. P305 + P351 + P338 + P310 IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Immediately call a POISON CENTER or doctor/ physician. P363 Wash contaminated clothing before reuse. P370 + P378 In case of fire: Use dry sand, dry chemical or alcohol-resistant foam to extinguish. P403 + P233 Store in a well-ventilated place. Keep container tightly closed. P403 + P235 Store in a well-ventilated place. Keep cool. P405 Store locked up. P501 Dispose of contents/ container to an approved waste disposal plant. 2.3 Hazards not otherwise classified (HNOC) or not covered by GHS Lachrymator.

3. COMPOSITION/INFORMATION ON INGREDIENTS 3.2 Mixtures Formula  : C2H7N Molecular weight  : 45.08 g/mol Hazardous components Component Classification Concentration Dimethylamine CAS-No. 124-40-3 Flam. Liq. 1; Acute Tox. 4; >= 30 - < 50 %

EC-No. 204-697-4 Skin Corr. 1B; Eye Dam. 1; Index-No. 612-001-01-6 STOT SE 3; Aquatic Acute 2; Aquatic Chronic 3; H224, H302 + H332, H314, H318, H335, H401, H412 For the full text of the H-Statements mentioned in this Section, see Section 16.

4. FIRST AID MEASURES 4.1 Description of first aid measures General advice Consult a physician. Show this safety data sheet to the doctor in attendance.Move out of dangerous area.

If inhaled If breathed in, move person into fresh air. If not breathing, give artificial respiration. Consult a physician. In case of skin contact Take off contaminated clothing and shoes immediately. Wash off with soap and plenty of water. Consult a physician. In case of eye contact Rinse thoroughly with plenty of water for at least 15 minutes and consult a physician.Continue rinsing eyes during transport to hospital. Aldrich - 426458 Page 2 of 9

If swallowed Do NOT induce vomiting. Never give anything by mouth to an unconscious person. Rinse mouth with water. Consult a physician. 4.2 Most important symptoms and effects, both acute and delayed The most important known symptoms and effects are described in the labelling (see section 2.2) and/or in section 11 4.3 Indication of any immediate medical attention and special treatment needed No data available

5. FIREFIGHTING MEASURES 5.1 Extinguishing media Suitable extinguishing media Use water spray, alcohol-resistant foam, dry chemical or carbon dioxide.

5.2 Special hazards arising from the substance or mixture Carbon oxides, Nitrogen oxides (NOx) 5.3 Advice for firefighters Wear self-contained breathing apparatus for firefighting if necessary. 5.4 Further information Use water spray to cool unopened containers.

6. ACCIDENTAL RELEASE MEASURES 6.1 Personal precautions, protective equipment and emergency procedures Use personal protective equipment. Avoid breathing vapours, mist or gas. Ensure adequate ventilation. Remove all sources of ignition. Evacuate personnel to safe areas. Beware of vapours accumulating to form explosive concentrations. Vapours can accumulate in low areas.

For personal protection see section 8. 6.2 Environmental precautions Prevent further leakage or spillage if safe to do so. Do not let product enter drains. Discharge into the environment must be avoided. 6.3 Methods and materials for containment and cleaning up Contain spillage, and then collect with an electrically protected vacuum cleaner or by wet-brushing and place in container for disposal according to local regulations (see section 13). 6.4 Reference to other sections For disposal see section 13.

7. HANDLING AND STORAGE 7.1 Precautions for safe handling Avoid contact with skin and eyes. Avoid inhalation of vapour or mist.

Use explosion-proof equipment.Keep away from sources of ignition - No smoking.Take measures to prevent the build up of electrostatic charge. For precautions see section 2.2. 7.2 Conditions for safe storage, including any incompatibilities Keep container tightly closed in a dry and well-ventilated place. Containers which are opened must be carefully resealed and kept upright to prevent leakage. Storage class (TRGS 510): Flammable liquids 7.3 Specific end use(s) Apart from the uses mentioned in section 1.2 no other specific uses are stipulated

8. EXPOSURE CONTROLS/PERSONAL PROTECTION 8.1 Control parameters Components with workplace control parameters Aldrich - 426458 Page 3 of 9

Component CAS-No. Value Control Basis parameters Dimethylamine 124-40-3 TWA 5.000000 ppm USA. ACGIH Threshold Limit Values (TLV) Remarks Upper Respiratory Tract irritation Lower Respiratory Tract irritation Gastrointestinal damage Adopted values or notations enclosed are those for which changes are proposed in the NIC See Notice of Intended Changes (NIC) Not classifiable as a human carcinogen STEL 15.000000 ppm USA. ACGIH Threshold Limit Values (TLV) Upper Respiratory Tract irritation Lower Respiratory Tract irritation Gastrointestinal damage Adopted values or notations enclosed are those for which changes are proposed in the NIC See Notice of Intended Changes (NIC) Not classifiable as a human carcinogen TWA 10.000000 ppm USA. Occupational Exposure Limits 18.000000 (OSHA) - Table Z-1 Limits for Air mg/m3 Contaminants The value in mg/m3 is approximate. TWA 10.000000 ppm USA. NIOSH Recommended 18.000000 Exposure Limits mg/m3 8.2 Exposure controls Appropriate engineering controls Handle in accordance with good industrial hygiene and safety practice. Wash hands before breaks and at the end of workday. Personal protective equipment Eye/face protection Tightly fitting safety goggles. Faceshield (8-inch minimum). Use equipment for eye protection tested and approved under appropriate government standards such as NIOSH (US) or EN 166(EU). Skin protection Handle with gloves. Gloves must be inspected prior to use. Use proper glove removal technique (without touching glove's outer surface) to avoid skin contact with this product. Dispose of contaminated gloves after use in accordance with applicable laws and good laboratory practices. Wash and dry hands. Full contact Material: butyl-rubber Minimum layer thickness: 0.3 mm Break through time: 480 min Material tested:Butoject (KCL 897 / Aldrich Z677647, Size M) Splash contact Material: Nitrile rubber Minimum layer thickness: 0.2 mm Break through time: 30 min Material tested:Dermatril P (KCL 743 / Aldrich Z677388, Size M) data source: KCL GmbH, D-36124 Eichenzell, phone +49 (0)6659 87300, e-mail sales@kcl.de, test method: EN374 If used in solution, or mixed with other substances, and under conditions which differ from EN 374, contact the supplier of the CE approved gloves. This recommendation is advisory only and must be evaluated by an industrial hygienist and safety officer familiar with the specific situation of anticipated use by our customers. It should not be construed as offering an approval for any specific use scenario. Aldrich - 426458 Page 4 of 9

Body Protection Complete suit protecting against chemicals, Flame retardant antistatic protective clothing., The type of protective equipment must be selected according to the concentration and amount of the dangerous substance at the specific workplace. Respiratory protection Where risk assessment shows air-purifying respirators are appropriate use a full-face respirator with multi-purpose combination (US) or type ABEK (EN 14387) respirator cartridges as a backup to engineering controls. If the respirator is the sole means of protection, use a full-face supplied air respirator. Use respirators and components tested and approved under appropriate government standards such as NIOSH (US) or CEN (EU). Control of environmental exposure Prevent further leakage or spillage if safe to do so. Do not let product enter drains. Discharge into the environment must be avoided.

9. PHYSICAL AND CHEMICAL PROPERTIES 9.1 Information on basic physical and chemical properties a) Appearance Form: clear, liquid Colour: colourless b) Odour No data available c) Odour Threshold No data available d) pH No data available e) Melting point/freezing No data available point f) Initial boiling point and No data available boiling range g) Flash point 16 °C (61 °F) - closed cup h) Evaporation rate No data available i) Flammability (solid, gas) No data available j) Upper/lower Upper explosion limit: 14.4 %(V) flammability or Lower explosion limit: 2.8 %(V) explosive limits k) Vapour pressure 1,170.0 hPa (877.6 mmHg) at 55 °C (131 °F) l) Vapour density No data available m) Relative density 0.890 g/cm3 n) Water solubility No data available o) Partition coefficient: n- No data available octanol/water p) Auto-ignition No data available temperature q) Decomposition No data available temperature r) Viscosity No data available s) Explosive properties No data available t) Oxidizing properties No data available 9.2 Other safety information No data available

10. STABILITY AND REACTIVITY 10.1 Reactivity No data available Aldrich - 426458 Page 5 of 9

10.2 Chemical stability Stable under recommended storage conditions. 10.3 Possibility of hazardous reactions Vapours may form explosive mixture with air. 10.4 Conditions to avoid Heat, flames and sparks. 10.5 Incompatible materials Peroxides, permanganates, e.g. potassium permanganate, Oxidizing agents 10.6 Hazardous decomposition products Other decomposition products - No data available In the event of fire: see section 5

11. TOXICOLOGICAL INFORMATION 11.1 Information on toxicological effects Acute toxicity No data available Inhalation: No data available No data available Skin corrosion/irritation No data available Serious eye damage/eye irritation No data available Respiratory or skin sensitisation No data available Germ cell mutagenicity No data available Carcinogenicity IARC: No component of this product present at levels greater than or equal to 0.1% is identified as probable, possible or confirmed human carcinogen by IARC.

NTP: No component of this product present at levels greater than or equal to 0.1% is identified as a known or anticipated carcinogen by NTP. OSHA: No component of this product present at levels greater than or equal to 0.1% is identified as a carcinogen or potential carcinogen by OSHA. Reproductive toxicity No data available No data available Specific target organ toxicity - single exposure No data available Specific target organ toxicity - repeated exposure No data available Aspiration hazard No data available Additional Information RTECS: Not available To the best of our knowledge, the chemical, physical, and toxicological properties have not been thoroughly investigated. Stomach - Irregularities - Based on Human Evidence Stomach - Irregularities - Based on Human Evidence (Dimethylamine) Aldrich - 426458 Page 6 of 9

12. ECOLOGICAL INFORMATION 12.1 Toxicity No data available 12.2 Persistence and degradability No data available 12.3 Bioaccumulative potential No data available 12.4 Mobility in soil No data available 12.5 Results of PBT and vPvB assessment PBT/vPvB assessment not available as chemical safety assessment not required/not conducted 12.6 Other adverse effects An environmental hazard cannot be excluded in the event of unprofessional handling or disposal.

Toxic to aquatic life.

13. DISPOSAL CONSIDERATIONS 13.1 Waste treatment methods Product Burn in a chemical incinerator equipped with an afterburner and scrubber but exert extra care in igniting as this material is highly flammable. Offer surplus and non-recyclable solutions to a licensed disposal company. Contact a licensed professional waste disposal service to dispose of this material.

Contaminated packaging Dispose of as unused product.

14. TRANSPORT INFORMATION DOT (US)

UN number: 1160 Class: 3 (8) Packing group: II Proper shipping name: Dimethylamine solution Reportable Quantity (RQ): 2500 lbs Poison Inhalation Hazard: No IMDG UN number: 1160 Class: 3 (8) Packing group: II EMS-No: F-E, S-C Proper shipping name: DIMETHYLAMINE, AQUEOUS SOLUTION IATA UN number: 1160 Class: 3 (8) Packing group: II Proper shipping name: Dimethylamine, aqueous solution

15. REGULATORY INFORMATION SARA 302 Components No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302.

SARA 313 Components The following components are subject to reporting levels established by SARA Title III, Section 313: CAS-No. Revision Date Dimethylamine 124-40-3 2007-07-01 SARA 311/312 Hazards Fire Hazard, Acute Health Hazard, Chronic Health Hazard Massachusetts Right To Know Components CAS-No. Revision Date Dimethylamine 124-40-3 2007-07-01 Aldrich - 426458 Page 7 of 9

Pennsylvania Right To Know Components CAS-No. Revision Date Water 7732-18-5 Dimethylamine 124-40-3 2007-07-01 New Jersey Right To Know Components CAS-No. Revision Date Water 7732-18-5 Dimethylamine 124-40-3 2007-07-01 California Prop. 65 Components This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm.

16. OTHER INFORMATION Full text of H-Statements referred to under sections 2 and 3.

Acute Tox. Acute toxicity Aquatic Acute Acute aquatic toxicity Aquatic Chronic Chronic aquatic toxicity Eye Dam. Serious eye damage Flam. Liq. Flammable liquids H224 Extremely flammable liquid and vapour. H225 Highly flammable liquid and vapour. H302 + H332 Harmful if swallowed or if inhaled H314 Causes severe skin burns and eye damage. H318 Causes serious eye damage. H335 May cause respiratory irritation. H401 Toxic to aquatic life. H412 Harmful to aquatic life with long lasting effects. Skin Corr. Skin corrosion STOT SE Specific target organ toxicity - single exposure HMIS Rating Health hazard: 3 Chronic Health Hazard:

• Flammability: 3 Physical Hazard 0 NFPA Rating Health hazard: 3 Fire Hazard: 3 Reactivity Hazard: 0 Further information Copyright 2015 Sigma-Aldrich Co. LLC. License granted to make unlimited paper copies for internal use only.

The above information is believed to be correct but does not purport to be all inclusive and shall be used only as a guide. The information in this document is based on the present state of our knowledge and is applicable to the product with regard to appropriate safety precautions. It does not represent any guarantee of the properties of the product. Sigma-Aldrich Corporation and its Affiliates shall not be held liable for any damage resulting from handling or from contact with the above product. See www.sigma-aldrich.com and/or the reverse side of invoice or packing slip for additional terms and conditions of sale. Preparation Information Sigma-Aldrich Corporation Product Safety - Americas Region 1-800-521-8956 Version: 4.8 Revision Date: 02/22/2015 Print Date: 02/07/2016 Aldrich - 426458 Page 8 of 9

Aldrich - 426458 Page 9 of 9 Version: 1.0 Effective Date: Oct-21-2014 SAFETY DATA SHEET STEAMATE* PWR1440

1. Identification Product identifier STEAMATE PWR1440 Other means of identification Not available.

Recommended use Neutralizing amine Recommended restrictions None known. Company/undertaking identification GE Betz, Inc. 4636 Somerton Road Trevose, PA 19053 T 215 355 3300, F 215 953 5524 Emergency telephone (800) 877 1940

2. Hazard(s) identification Physical hazards Not classified.

Health hazards Acute toxicity, inhalation Category 3 Skin corrosion/irritation Category 1B Serious eye damage/eye irritation Category 1 Specific target organ toxicity, single exposure Category 3 respiratory tract irritation OSHA defined hazards Not classified. Label elements Signal word Danger Hazard statement Causes severe skin burns and eye damage. Causes serious eye damage. Toxic if inhaled. May cause respiratory irritation. Precautionary statement Prevention Do not breathe mist or vapor. Wash thoroughly after handling. Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection. Response If swallowed: Rinse mouth. Do NOT induce vomiting. If on skin (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower. If inhaled: Remove person to fresh air and keep comfortable for breathing. If in eyes: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Immediately call a poison center/doctor/. Specific treatment (see this label). Wash contaminated clothing before reuse. Storage Store in a well-ventilated place. Keep container tightly closed. Store locked up. Disposal Dispose of contents/container in accordance with local/regional/national/international regulations. Hazard(s) not otherwise classified None known. (HNOC) Page: 1 / 9

Supplemental information None.

3. Composition/information on ingredients Mixtures Chemical name Common name and synonyms CAS number  %

Ethanolamine 141-43-5 40 - 60

• Designates that a specific chemical identity and/or percentage of composition has been withheld as a trade secret.

Composition comments Information for specific product ingredients as required by the U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to additional sections of this SDS for our assessment of the potential hazards of this formulation.

4. First-aid measures Inhalation Remove victim to fresh air and keep at rest in a position comfortable for breathing. Oxygen or artificial respiration if needed. Do not use mouth-to-mouth method if victim inhaled the substance. Induce artificial respiration with the aid of a pocket mask equipped with a one-way valve or other proper respiratory medical device. Call a POISON CENTER or doctor/physician.

Skin contact Take off immediately all contaminated clothing. Rinse skin with water/shower. Call a physician or poison control center immediately. Chemical burns must be treated by a physician. Wash contaminated clothing before reuse. Eye contact Immediately flush eyes with plenty of low-pressure water for at least 20 minutes while removing contact lenses. Keep eyelids apart. Call a physician or poison control center immediately. Ingestion Call a physician or poison control center immediately. Rinse mouth. Do not induce vomiting. If vomiting occurs, keep head low so that stomach content doesn't get into the lungs. Most important Burning pain and severe corrosive skin damage. Causes serious eye damage. Symptoms may include symptoms/effects, acute and stinging, tearing, redness, swelling, and blurred vision. Permanent eye damage including blindness could delayed result. May cause respiratory irritation. Indication of immediate medical Provide general supportive measures and treat symptomatically. Chemical burns: Flush with water attention and special treatment immediately. While flushing, remove clothes which do not adhere to affected area. Call an ambulance. needed Continue flushing during transport to hospital. Keep victim warm. Keep victim under observation. Symptoms may be delayed. General information Ensure that medical personnel are aware of the material(s) involved, and take precautions to protect themselves. Show this safety data sheet to the doctor in attendance.

5. Fire-fighting measures Suitable extinguishing media Alcohol resistant foam. Water fog. Dry chemical powder. Carbon dioxide (CO2).

Unsuitable extinguishing media Do not use water jet as an extinguisher, as this will spread the fire. Specific hazards arising from the During fire, gases hazardous to health may be formed. chemical Special protective equipment and Self-contained breathing apparatus and full protective clothing must be worn in case of fire. precautions for firefighters Fire-fighting Move containers from fire area if you can do so without risk. equipment/instructions Specific methods Use standard firefighting procedures and consider the hazards of other involved materials. General fire hazards No unusual fire or explosion hazards noted.

6. Accidental release measures Personal precautions, protective Keep unnecessary personnel away. Keep people away from and upwind of spill/leak. Keep out of low equipment and emergency areas. Wear appropriate protective equipment and clothing during clean-up. Do not breathe mist or procedures vapor. Do not touch damaged containers or spilled material unless wearing appropriate protective clothing. Ensure adequate ventilation. Local authorities should be advised if significant spillages cannot be contained. For personal protection, see section 8 of the SDS.

Methods and materials for Large Spills: Stop the flow of material, if this is without risk. Dike the spilled material, where this is containment and cleaning up possible. Cover with plastic sheet to prevent spreading. Absorb in vermiculite, dry sand or earth and place into containers. Use water spray to reduce vapors or divert vapor cloud drift. Prevent entry into waterways, sewer, basements or confined areas. Following product recovery, flush area with water. Small Spills: Wipe up with absorbent material (e.g. cloth, fleece). Clean surface thoroughly to remove residual contamination. Never return spills to original containers for re-use. For waste disposal, see section 13 of the SDS. Environmental precautions Avoid discharge into drains, water courses or onto the ground. Material name: STEAMATE* PWR1440 Page: 2 / 9 Version number: 1.0

7. Handling and storage Precautions for safe handling Alkaline. Do not mix with acidic material. Do not breathe mist or vapor. Do not get this material in contact with eyes. Do not get this material in contact with skin. Avoid prolonged exposure. Do not get this material on clothing. Use only outdoors or in a well-ventilated area. Wear appropriate personal protective equipment. Observe good industrial hygiene practices. Use care in handling/storage.

Conditions for safe storage, Do not freeze. If frozen, thaw completely and mix thoroughly prior to use. Store in original tightly closed including any incompatibilities container. Store in a well-ventilated place. Store away from incompatible materials (see Section 10 of the SDS). Store in accordance with local/regional/national/international regulation.

8. Exposure controls/personal protection Occupational exposure limits US. OSHA Table Z-1 Limits for Air Contaminants (29 CFR 1910.1000)

Components Type Value Ethanolamine (CAS 141-43-5) PEL 6 mg/m3 3 ppm US. ACGIH Threshold Limit Values Components Type Value Ethanolamine (CAS 141-43-5) STEL 6 ppm TWA 3 ppm US. NIOSH: Pocket Guide to Chemical Hazards Components Type Value Ethanolamine (CAS 141-43-5) STEL 15 mg/m3 6 ppm TWA 8 mg/m3 3 ppm Biological limit values No biological exposure limits noted for the ingredient(s). Appropriate engineering controls Good general ventilation (typically 10 air changes per hour) should be used. Ventilation rates should be matched to conditions. If applicable, use process enclosures, local exhaust ventilation, or other engineering controls to maintain airborne levels below recommended exposure limits. If exposure limits have not been established, maintain airborne levels to an acceptable level. Eye wash facilities and emergency shower must be available when handling this product. Individual protection measures, such as personal protective equipment Eye/face protection Splash proof chemical goggles. Face shield. Skin protection Hand protection Chemical resistant gloves. The choice of an appropriate glove does not only depend on its material but also on other quality features and is different from one producer to the other. Glove selection must take into account any solvents and other hazards present. Other Wear appropriate chemical resistant clothing. Use of an impervious apron is recommended. Respiratory protection Chemical respirator with organic vapor cartridge and full facepiece. A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. Thermal hazards Wear appropriate thermal protective clothing, when necessary. General hygiene considerations Always observe good personal hygiene measures, such as washing after handling the material and before eating, drinking, and/or smoking. Routinely wash work clothing and protective equipment to remove contaminants.

9. Physical and chemical properties Appearance Color Colorless to yellow Physical state Liquid Odor Amine Odor threshold Not available.

pH (concentrated product) 12.7 pH in aqueous solution 11.8 (5% SOL.) Melting point/freezing point -9 °F (-23 °C) Material name: STEAMATE* PWR1440 Page: 3 / 9 Version number: 1.0

Initial boiling point and boiling Not available. range Flash point > 200 °F (> 93 °C) P-M(CC) Evaporation rate < 1 (Ether = 1) Flammability (solid, gas) Not available. Upper/lower flammability or explosive limits Flammability limit - lower (%) Not available. Flammability limit - upper Not available. (%) Explosive limit - lower (%) Not available. Explosive limit - upper (%) Not available. Vapor pressure 18 mm Hg Vapor pressure temp. 70 °F (21 °C) Vapor density < 1 (Air = 1) Relative density 1.02 Relative density temperature 70 °F (21 °C) Solubility(ies) Solubility (water) 100 % Partition coefficient Not available. (n-octanol/water) Auto-ignition temperature Not available. Decomposition temperature Not available. Viscosity 20 cps Viscosity temperature 70 °F (21 °C) Other information Percent volatile 40 (Estimated) Pour point -4 °F (-20 °C) Specific gravity 1.02

10. Stability and reactivity Reactivity The product is stable and non-reactive under normal conditions of use, storage and transport.

Chemical stability Material is stable under normal conditions. Possibility of hazardous reactions No dangerous reaction known under conditions of normal use. Conditions to avoid Avoid temperatures exceeding the flash point. Contact with incompatible materials. Incompatible materials Strong acids. Hazardous decomposition Oxides of carbon and nitrogen evolved in fire. Ammonia. Volatile amines. products

11. Toxicological information Information on likely routes of exposure Ingestion Causes digestive tract burns.

Inhalation Toxic if inhaled. Skin contact Causes severe skin burns. Prolonged or repeated exposure may cause liver and kidney damage. These effects have not been observed in humans. Eye contact Causes serious eye damage. Symptoms related to the physical, Burning pain and severe corrosive skin damage. Causes serious eye damage. May cause respiratory chemical and toxicological irritation. Symptoms may include stinging, tearing, redness, swelling, and blurred vision. Permanent eye characteristics damage including blindness could result. Information on toxicological effects Acute toxicity Toxic if inhaled. May cause respiratory irritation. Material name: STEAMATE* PWR1440 Page: 4 / 9 Version number: 1.0

Product Species Test Results STEAMATE PWR1440 (CAS Mixture) Acute Dermal LD50 Rabbit > 5000 mg/kg, (Estimated value) Oral LD50 Rat > 5000 mg/kg, (Estimated value) Components Species Test Results Ethanolamine (CAS 141-43-5) Acute Dermal LD50 Rabbit 1025 mg/kg Inhalation LC50 Rat > 1.5 mg/l, 4 Hour Oral LD50 Rat 1720 mg/kg

• Estimates for product may be based on additional component data not shown.

Skin corrosion/irritation Prolonged skin contact may cause temporary irritation. Serious eye damage/eye irritation Causes serious eye damage. Respiratory or skin sensitization Respiratory sensitization Not available. Skin sensitization This product is not expected to cause skin sensitization. Germ cell mutagenicity No data available to indicate product or any components present at greater than 0.1% are mutagenic or genotoxic. Carcinogenicity This product is not considered to be a carcinogen by IARC, ACGIH, NTP, or OSHA. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050) Not listed. Reproductive toxicity This product is not expected to cause reproductive or developmental effects. Specific target organ toxicity - May cause respiratory irritation. single exposure Specific target organ toxicity - Not classified. repeated exposure Aspiration hazard Not classified. Chronic effects Prolonged inhalation may be harmful. May be harmful if absorbed through skin. Prolonged or repeated exposure may cause liver and kidney damage. These effects have not been observed in humans.

12. Ecological information Ecotoxicity The product is not classified as environmentally hazardous. However, this does not exclude the possibility that large or frequent spills can have a harmful or damaging effect on the environment.

Product Species Test Results STEAMATE PWR1440 (CAS Mixture) 0% Mortality Fathead Minnow 1250 mg/L, Flow-Thru Bioassay, 96 hour 10% Mortality Fathead Minnow 2500 mg/L, Flow-Thru Bioassay, 96 hour LC50 Bluegill Sunfish 800 mg/L, Static Acute Bioassay, 96 hour Fathead Minnow 500 mg/L, Static Acute Bioassay, 96 hour NOEL Fathead Minnow 300 mg/L, Static Acute Bioassay, 96 hour Crustacea LC50 Daphnia magna 330 mg/L, Flow-Thru Bioassay, 48 hour NOEL Daphnia magna 70.5 mg/L, Flow-Thru Bioassay, 48 hour Material name: STEAMATE* PWR1440 Page: 5 / 9 Version number: 1.0

Product Species Test Results Other LC50 Rainbow Trout 370 mg/L, Static Acute Bioassay, 96 hour

• Estimates for product may be based on additional component data not shown.

Bioaccumulative potential No data available. Partition coefficient n-octanol / water (log Kow) Ethanolamine -1.3 Mobility in soil No data available. Other adverse effects No other adverse environmental effects (e.g. ozone depletion, photochemical ozone creation potential, endocrine disruption, global warming potential) are expected from this component. Environmental fate The product is not classified as environmentally hazardous. However, this does not exclude the possibility that large or frequent spills can have a harmful or damaging effect on the environment. Persistence and degradability No data is available on the degradability of this product.

    - COD (mgO2/g)                    560 (calculated data)
    - BOD 5 (mgO2/g)                  252 (calculated data)
    - BOD 28 (mgO2/g)                 250 (calculated data)
    - Closed Bottle Test (%           45 (calculated data)

Degradation in 28 days)

    - Zahn-Wellens Test (%            94 (calculated data)

Degradation in 28 days)

    - TOC (mg C/g)                    152 (calculated data)

13. Disposal considerations Disposal instructions Collect and reclaim or dispose in sealed containers at licensed waste disposal site. Incinerate the material under controlled conditions in an approved incinerator.

Local disposal regulations Dispose in accordance with all applicable regulations. Hazardous waste code D002: Waste Corrosive material [pH <=2 or =>12.5, or corrosive to steel] The waste code should be assigned in discussion between the user, the producer and the waste disposal company. Waste from residues / unused Dispose of in accordance with local regulations. Empty containers or liners may retain some product products residues. This material and its container must be disposed of in a safe manner (see: Disposal instructions). Contaminated packaging Via an authorized waste disposal contractor to an approved waste disposal site, observing all local and national regulations. Empty containers should be taken to an approved waste handling site for recycling or disposal. Since emptied containers may retain product residue, follow label warnings even after container is emptied.

14. Transport information DOT UN number UN2491 UN proper shipping name ETHANOLAMINE SOLUTION Transport hazard class(es)

Class 8 Subsidiary risk - Packing group III Special precautions for user Read safety instructions, SDS and emergency procedures before handling. ERG number 153 Some containers may be DOT exempt, please check BOL for exact container classification. IATA UN number UN2491 UN proper shipping name ETHANOLAMINE SOLUTION Transport hazard class(es) Class 8 Subsidiary risk - Packing group III Environmental hazards No. Special precautions for user Read safety instructions, SDS and emergency procedures before handling. Material name: STEAMATE* PWR1440 Page: 6 / 9 Version number: 1.0

IMDG UN number Not available. UN proper shipping name DO NOT SHIP. NOT CLASSIFIED. CALL PRODUCT COMPLIANCE. Transport hazard class(es) Class Not available. Subsidiary risk - Packing group Not applicable. Environmental hazards Marine pollutant No. EmS Not available. Special precautions for user Read safety instructions, SDS and emergency procedures before handling. DOT IATA

15. Regulatory information US federal regulations This product is a "Hazardous Chemical" as defined by the OSHA Hazard Communication Standard, 29 CFR 1910.1200.

All components are on the U.S. EPA TSCA Inventory List. TSCA Section 12(b) Export Notification (40 CFR 707, Subpt. D) Not regulated. CERCLA Hazardous Substance List (40 CFR 302.4) Not listed. SARA 304 Emergency release notification Not regulated. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050) Not listed. Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazard categories Immediate Hazard - Yes Delayed Hazard - No Fire Hazard - No Pressure Hazard - No Reactivity Hazard - No SARA 302 Extremely hazardous substance Not listed. SARA 311/312 Hazardous No chemical SARA 313 (TRI reporting) Not regulated. Material name: STEAMATE* PWR1440 Page: 7 / 9 Version number: 1.0

Other federal regulations Clean Air Act (CAA) Section 112 Hazardous Air Pollutants (HAPs) List Not regulated. Clean Air Act (CAA) Section 112(r) Accidental Release Prevention (40 CFR 68.130) Not regulated. Safe Drinking Water Act Not regulated. (SDWA) Inventory status Country(s) or region Inventory name On inventory (yes/no)* Canada Domestic Substances List (DSL) Yes Canada Non-Domestic Substances List (NDSL) No United States & Puerto Rico Toxic Substances Control Act (TSCA) Inventory Yes

    *A "Yes" indicates that all components of this product comply with the inventory requirements administered by the governing country(s)

A "No" indicates that one or more components of the product are not listed or exempt from listing on the inventory administered by the governing country(s). US state regulations California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65): This material is not known to contain any chemicals currently listed as carcinogens or reproductive toxins. US - Massachusetts RTK - Substance List Ethanolamine (CAS 141-43-5) US - Pennsylvania RTK - Hazardous Substances Ethanolamine (CAS 141-43-5) US - Rhode Island RTK Not regulated. US. California Controlled Substances. CA Department of Justice (California Health and Safety Code Section 11100) Not listed. US. New Jersey Worker and Community Right-to-Know Act Not regulated. US. California Proposition 65 California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65): This material is not known to contain any chemicals currently listed as carcinogens or reproductive toxins. US - California Proposition 65 - CRT: Listed date/Carcinogenic substance No ingredient listed. US - California Proposition 65 - CRT: Listed date/Developmental toxin No ingredient listed. US - California Proposition 65 - CRT: Listed date/Female reproductive toxin No ingredient listed. US - California Proposition 65 - CRT: Listed date/Male reproductive toxin No ingredient listed.

16. Other information, including date of preparation or last revision Issue date Oct-21-2014 Revision date Oct-21-2014 Version # 1.0 List of abbreviations CAS: Chemical Abstract Service Registration Number TWA: Time Weighted Average STEL: Short Term Exposure Limit TLV: Threshold Limit Value LD50: Lethal Dose, 50%

LC50: Lethal Concentration, 50% NOEL: No Observed Effect Level COD: Chemical Oxygen Demand BOD: Biochemical Oxygen Demand TOC: Total Organic Carbon IATA: International Air Transport Association IMDG: International Maritime Dangerous Goods Code TSRN indicates a Trade Secret Registry Number is used in place of the CAS number. ACGIH: American Conference of Governmental Industrial Hygienists NFPA: National Fire Protection Association

References:

No data available Material name: STEAMATE* PWR1440 Page: 8 / 9 Version number: 1.0

Disclaimer The information in the sheet was written based on the best knowledge and experience currently available. The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. Revision Information Product and Company Identification: Product and Company Identification Composition / Information on Ingredients: Disclosure Overrides Physical & Chemical Properties: Multiple Properties Transport Information: Material Transportation Information Regulatory Information: Risk Phrases - Labeling HazReg Data: Europe - EU GHS: Classification Prepared by This SDS has been prepared by GE Water & Process Technologies Regulatory Department (1-215-355-3300).

• Trademark of General Electric Company. May be registered in one or more countries.

Material name: STEAMATE* PWR1440 Page: 9 / 9 Version number: 1.0

SAFETY DATA SHEET Creation Date 28-Oct-2009 Revision Date 06-Jul-2016 Revision Number 3

1. Identification Product Name Hydrogen peroxide, 30%

Cat No. : H325-4; H325-4LC; H325-30GAL; H325-100; H325-500; H325-500LC Synonyms Hydrogen Dioxide; Peroxide; Carbamide Peroxide Recommended Use Laboratory chemicals. Uses advised against No Information available Details of the supplier of the safety data sheet Company Emergency Telephone Number Fisher Scientific CHEMTREC, Inside the USA: 800-424-9300 One Reagent Lane CHEMTREC, Outside the USA: 001-703-527-3887 Fair Lawn, NJ 07410 Tel: (201) 796-7100

2. Hazard(s) identification Classification This chemical is considered hazardous by the 2012 OSHA Hazard Communication Standard (29 CFR 1910.1200)

Oxidizing liquids Category 2 Acute oral toxicity Category 4 Serious Eye Damage/Eye Irritation Category 1 Label Elements Signal Word Danger Hazard Statements May intensify fire; oxidizer Harmful if swallowed Causes serious eye damage Precautionary Statements Prevention Wash face, hands and any exposed skin thoroughly after handling Page 1 / 8

Hydrogen peroxide, 30% Revision Date 06-Jul-2016 Do not eat, drink or smoke when using this product Use only outdoors or in a well-ventilated area Do not breathe dust/fume/gas/mist/vapors/spray Wear protective gloves/protective clothing/eye protection/face protection Keep away from heat/sparks/open flames/hot surfaces. - No smoking Keep/Store away from clothing/ other combustible materials Take any precaution to avoid mixing with combustibles Wear fire/flame resistant/retardant clothing

Response

Immediately call a POISON CENTER or doctor/physician Inhalation IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing Skin Wash contaminated clothing before reuse IF ON CLOTHING: Rinse immediately contaminated clothing and skin with plenty of water before removing clothes Rinse skin with water/shower Eyes IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing Ingestion Rinse mouth Do NOT induce vomiting Fire In case of fire: Use CO2, dry chemical, or foam for extinction Explosion risk in case of fire In case of fire: Evacuate area. Fight fire remotely due to the risk of explosion Storage Store locked up Store in a well-ventilated place. Keep container tightly closed Store in a well-ventilated place. Keep cool Disposal Dispose of contents/container to an approved waste disposal plant Hazards not otherwise classified (HNOC) None identified Other hazards May cause pulmonary edema.

3. Composition / information on ingredients Component CAS-No Weight %

Water 7732-18-5 65 - 80 Hydrogen peroxide 7722-84-1 20 - 35

4. First-aid measures General Advice If symptoms persist, call a physician.

Eye Contact Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Immediate medical attention is required. Skin Contact Wash off immediately with plenty of water for at least 15 minutes. Obtain medical attention. Inhalation Move to fresh air. If breathing is difficult, give oxygen. Obtain medical attention. Ingestion Do not induce vomiting. Obtain medical attention. Most important symptoms/effects Causes eye burns. Notes to Physician Treat symptomatically Page 2 / 8

Hydrogen peroxide, 30% Revision Date 06-Jul-2016

5. Fire-fighting measures Unsuitable Extinguishing Media No information available Flash Point No information available Method - No information available Autoignition Temperature No information available Explosion Limits Upper 100%

Lower 40% Sensitivity to Mechanical Impact No information available Sensitivity to Static Discharge No information available Specific Hazards Arising from the Chemical Corrosive Material. Containers may explode when heated. Oxidizer: Contact with combustible/organic material may cause fire. In the event of fire and/or explosion do not breathe fumes. Thermal decomposition can lead to release of irritating gases and vapors. Hazardous Combustion Products Hydrogen oxygen Protective Equipment and Precautions for Firefighters As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear. NFPA Health Flammability Instability Physical hazards 3 0 1 OX

6. Accidental release measures Personal Precautions Ensure adequate ventilation. Use personal protective equipment. Avoid contact with the skin and the eyes.

Do not use steel or aluminum tools or equipment Environmental Precautions Should not be released into the environment. Do not flush into surface water or sanitary sewer system. Collect spillage. See Section 12 for additional ecological information. Methods for Containment and Clean Soak up with inert absorbent material. Keep in suitable, closed containers for disposal. Up

7. Handling and storage Handling Wear personal protective equipment. Do not get in eyes, on skin, or on clothing. Avoid ingestion and inhalation. Ensure adequate ventilation.

Storage Keep containers tightly closed in a dry, cool and well-ventilated place. To maintain product quality. Keep refrigerated. Keep away from direct sunlight. Do not store in metal containers. Containers should be vented periodically in order to overcome pressure buildup.

8. Exposure controls / personal protection Exposure Guidelines Component ACGIH TLV OSHA PEL NIOSH IDLH Hydrogen peroxide TWA: 1 ppm (Vacated) TWA: 1 ppm IDLH: 75 ppm (Vacated) TWA: 1.4 mg/m3 TWA: 1 ppm TWA: 1 ppm TWA: 1.4 mg/m3 TWA: 1.4 mg/m3 Component Quebec Mexico OEL (TWA) Ontario TWAEV Hydrogen peroxide TWA: 1 ppm TWA: 1 ppm TWA: 1 ppm TWA: 1.4 mg/m3 TWA: 1.5 mg/m3 Page 3 / 8

Hydrogen peroxide, 30% Revision Date 06-Jul-2016 STEL: 2 ppm STEL: 3 mg/m3 Legend ACGIH - American Conference of Governmental Industrial Hygienists OSHA - Occupational Safety and Health Administration NIOSH IDLH: The National Institute for Occupational Safety and Health Immediately Dangerous to Life or Health Engineering Measures Ensure that eyewash stations and safety showers are close to the workstation location. Ensure adequate ventilation, especially in confined areas. Personal Protective Equipment Eye/face Protection Wear appropriate protective eyeglasses or chemical safety goggles as described by OSHA's eye and face protection regulations in 29 CFR 1910.133 or European Standard EN166. Skin and body protection Wear appropriate protective gloves and clothing to prevent skin exposure. Respiratory Protection Follow the OSHA respirator regulations found in 29 CFR 1910.134 or European Standard EN 149. Use a NIOSH/MSHA or European Standard EN 149 approved respirator if exposure limits are exceeded or if irritation or other symptoms are experienced. Hygiene Measures Handle in accordance with good industrial hygiene and safety practice.

9. Physical and chemical properties Physical State Liquid Appearance Colorless Odor Slight Odor Threshold No information available pH 3.3 Melting Point/Range -33 °C / -27.4 °F Boiling Point/Range 108 °C / 226.4 °F @ 760 mmHg Flash Point No information available Evaporation Rate 1.0 (Butyl acetate = 1.0)

Flammability (solid,gas) Not applicable Flammability or explosive limits Upper 100% Lower 40% Vapor Pressure No information available Vapor Density 1.10 Specific Gravity 1.110 Solubility Miscible with water Partition coefficient; n-octanol/water No data available Autoignition Temperature No information available Decomposition Temperature > 125°C Viscosity No information available

10. Stability and reactivity Reactive Hazard None known, based on information available Stability Stable under normal conditions. Sensitivity to light.

Conditions to Avoid Incompatible products. Excess heat. Exposure to light. Combustible material. Incompatible Materials Strong oxidizing agents, Metals, Reducing agents, Alcohols, Ammonia, copper, Copper alloys, lead oxides, Cyanides, Sulfides, lead, Acetone, Aluminium, Page 4 / 8

Hydrogen peroxide, 30% Revision Date 06-Jul-2016 Hazardous Decomposition Products Hydrogen, oxygen Hazardous Polymerization Hazardous polymerization does not occur. Hazardous Reactions None under normal processing.

11. Toxicological information Acute Toxicity Product Information Oral LD50 Category 4. ATE = 300 - 2000 mg/kg.

Dermal LD50 Based on ATE data, the classification criteria are not met. ATE > 2000 mg/kg. Component Information Component LD50 Oral LD50 Dermal LC50 Inhalation Water - Not listed Not listed Hydrogen peroxide 376 mg/kg ( Rat ) (90%) >2000 mg/kg ( Rabbit ) LC50 = 2 g/m3 ( Rat ) 4 h 910 mg/kg ( Rat ) (20-60%) 1518 mg/kg ( Rat ) (8-20% sol) Toxicologically Synergistic No information available Products Delayed and immediate effects as well as chronic effects from short and long-term exposure Irritation Causes severe eye burns May cause irritation Sensitization No information available Carcinogenicity The table below indicates whether each agency has listed any ingredient as a carcinogen. Component CAS-No IARC NTP ACGIH OSHA Mexico Water 7732-18-5 Not listed Not listed Not listed Not listed Not listed Hydrogen peroxide 7722-84-1 Not listed Not listed A3 Not listed A3 IARC: (International Agency for Research on Cancer) IARC: (International Agency for Research on Cancer) Group 1 - Carcinogenic to Humans Group 2A - Probably Carcinogenic to Humans Group 2B - Possibly Carcinogenic to Humans ACGIH: (American Conference of Governmental Industrial A1 - Known Human Carcinogen Hygienists) A2 - Suspected Human Carcinogen A3 - Animal Carcinogen ACGIH: (American Conference of Governmental Industrial Hygienists) Mexico - Occupational Exposure Limits - Carcinogens Mexico - Occupational Exposure Limits - Carcinogens A1 - Confirmed Human Carcinogen A2 - Suspected Human Carcinogen A3 - Confirmed Animal Carcinogen A4 - Not Classifiable as a Human Carcinogen A5 - Not Suspected as a Human Carcinogen Mutagenic Effects No information available Reproductive Effects No information available. Developmental Effects No information available. Teratogenicity No information available. STOT - single exposure None known STOT - repeated exposure None known Aspiration hazard No information available Symptoms / effects,both acute and No information available delayed Endocrine Disruptor Information No information available Page 5 / 8

Hydrogen peroxide, 30% Revision Date 06-Jul-2016 Other Adverse Effects The toxicological properties have not been fully investigated.

12. Ecological information Ecotoxicity Contains a substance which is:. Harmful to aquatic organisms, may cause long-term adverse effects in the aquatic environment.

Component Freshwater Algae Freshwater Fish Microtox Water Flea Hydrogen peroxide EC50 2.5 mg/L/72h LC50: 16.4 mg/L/96h Not listed EC50 7.7 mg/L/24h (P.promelas) Persistence and Degradability Persistence is unlikely Decomposes Soluble in water Bioaccumulation/ Accumulation No information available. Mobility Will likely be mobile in the environment due to its water solubility. Component log Pow Hydrogen peroxide -1.1

13. Disposal considerations Waste Disposal Methods Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste. Chemical waste generators must also consult local, regional, and national hazardous waste regulations to ensure complete and accurate classification.

14. Transport information DOT UN-No UN2014 Proper Shipping Name HYDROGEN PEROXIDE, AQUEOUS SOLUTIONS Hazard Class 5.1 Subsidiary Hazard Class 8 Packing Group II TDG UN-No UN2014 Proper Shipping Name HYDROGEN PEROXIDE, AQUEOUS SOLUTIONS Hazard Class 5.1 Subsidiary Hazard Class 8 Packing Group II IATA UN-No UN2014 Proper Shipping Name HYDROGEN PEROXIDE, AQUEOUS SOLUTION Hazard Class 5.1 Subsidiary Hazard Class 8 Packing Group II IMDG/IMO UN-No UN2014 Proper Shipping Name HYDROGEN PEROXIDE, AQUEOUS SOLUTION Hazard Class 5.1 Subsidiary Hazard Class 8 Packing Group II

15. Regulatory information International Inventories Component TSCA DSL NDSL EINECS ELINCS NLP PICCS ENCS AICS IECSC KECL Water X X - 231-791-2 - X - X X X Hydrogen peroxide X X - 231-765-0 - X X X X X Legend:

X - Listed E - Indicates a substance that is the subject of a Section 5(e) Consent order under TSCA. F - Indicates a substance that is the subject of a Section 5(f) Rule under TSCA. Page 6 / 8

Hydrogen peroxide, 30% Revision Date 06-Jul-2016 N - Indicates a polymeric substance containing no free-radical initiator in its inventory name but is considered to cover the designated polymer made with any free-radical initiator regardless of the amount used. P - Indicates a commenced PMN substance R - Indicates a substance that is the subject of a Section 6 risk management rule under TSCA. S - Indicates a substance that is identified in a proposed or final Significant New Use Rule T - Indicates a substance that is the subject of a Section 4 test rule under TSCA. XU - Indicates a substance exempt from reporting under the Inventory Update Rule, i.e. Partial Updating of the TSCA Inventory Data Base Production and Site Reports (40 CFR 710(B). Y1 - Indicates an exempt polymer that has a number-average molecular weight of 1,000 or greater. Y2 - Indicates an exempt polymer that is a polyester and is made only from reactants included in a specified list of low concern reactants that comprises one of the eligibility criteria for the exemption rule. U.S. Federal Regulations TSCA 12(b) Not applicable SARA 313 Not applicable SARA 311/312 Hazard Categories Acute Health Hazard Yes Chronic Health Hazard No Fire Hazard No Sudden Release of Pressure Hazard No Reactive Hazard No CWA (Clean Water Act) Not applicable Clean Air Act Not applicable OSHA Occupational Safety and Health Administration Component Specifically Regulated Chemicals Highly Hazardous Chemicals Hydrogen peroxide - TQ: 7500 lb CERCLA This material, as supplied, contains one or more substances regulated as a hazardous substance under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (40 CFR 302) Component Hazardous Substances RQs CERCLA EHS RQs Hydrogen peroxide - 1000 lb California Proposition 65 This product does not contain any Proposition 65 chemicals U.S. State Right-to-Know Regulations Component Massachusetts New Jersey Pennsylvania Illinois Rhode Island Water - - X - - Hydrogen peroxide X X X - X U.S. Department of Transportation Reportable Quantity (RQ): N DOT Marine Pollutant N DOT Severe Marine Pollutant N U.S. Department of Homeland Security This product contains the following DHS chemicals: Component DHS Chemical Facility Anti-Terrorism Standard Hydrogen peroxide 2000 lb STQ (concentration of at least 30%) Other International Regulations Page 7 / 8

Hydrogen peroxide, 30% Revision Date 06-Jul-2016 Mexico - Grade No information available Canada This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR WHMIS Hazard Class D1B Toxic materials E Corrosive material C Oxidizing materials

16. Other information Prepared By Regulatory Affairs Thermo Fisher Scientific Email: EMSDS.RA@thermofisher.com Creation Date 28-Oct-2009 Revision Date 06-Jul-2016 Print Date 06-Jul-2016 Revision Summary This document has been updated to comply with the US OSHA HazCom 2012 Standard replacing the current legislation under 29 CFR 1910.1200 to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

Disclaimer The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text End of SDS Page 8 / 8

Vel'llon: 4.0 Etrec:tive Date: May-14-2019 Praviou* Data: Feb-13-2018

   ~sue2 SAFETY DATA SHEET KLARAID* PC1175

1. Identification Product identifier KLARAID PC117S Other means of Identification None.

Recommended use Cationic coagulant for waste water Recommended restrictions Industrial use only. Company/undertaking identification SUEZ wrs USA, Inc. 4636 Somerton Road Trevose, PA 19053 T215356 3300, F 215953 5624 Emergency telephone ceoo) sn 1940

2. Hazard(s) identification Phyalcal hazards Not classified.

Health hazards Skin corrosion/irritation category 2 Serious eye damage/eye irritation category 2 OSHA defined hazards Not classified. Label elements Slgnalword waming Hazard atatement Causes skin initation. Causes serious eye irritation. PNcautlonary statement Prevention Wash thoroughly after handling. Wear eye protection/face protection. Wear protective gloves. Response If skin initation occul'B: Get medical advice/attention. If eye irritation persists: Get medical advice/attention. Take off contaminated clothing and wash before reuse. If on skin: wash with plenty of water. If In eyes: Rinse cautlously with water for several minutes. Remove contact lenses, if present and easy to do. Continua rinsing. Storage Store away from incompatible materials. Diapoeal Dispose of waste and residues in accordance with local authority requirements. Hazard(*) not otherwiae None known. clanified (HNOC) Supplemental infonnation None.

3. Composition/information on ingredients Mixtures Page: 1 /7

Components CAS# Percent Hexanedioic acid, polymer with N-(2-aminoethyl)-1,2-ethanediamine and 25212-19-5 20-40 (chloromethyQoxirane Composition comments Information for specific product ingredients as required by the U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to additional sections of this SDS for our assessment of the potential hazards of this formulation.

4. First-aid measures Inhalation If breathing is difficult, remove to fresh air and keep at rest in a position comfortable for breathing.

Call a physician if symptoms develop or persist. Skin contact Rinse skin with water/shower. If skin irritation occurs: Get medical advice/attention. Wash contaminated clothing before reuse. Eye contact Immediately flush eyes with plenty of water for at least 15 minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Get medical attention if irritation develops and persists. Ingestion Rinse mouth. Get medical attention if symptoms occur. Most important Severe eye irritation. Symptoms may include stinging, tearing, redness, swelling, and blurred symptoms/effects, acute and vision. Skin irritation. May cause redness and pain. delayed Indication of immediate Provide general supportive measures and treat symptomatically. Keep victim under observation. medical attention and special Symptoms may be delayed. treatment needed General information Ensure that medical personnel are aware of the material(s) involved, and take precautions to protect themselves.

5. Fire-fighting measures Suitable extinguishing media Water fog. Foam. Dry chemical powder. Carbon dioxide (C02).

Unsuitable extinguishing Do not use water jet as an extinguisher, as this will spread the fire. media Specific hazards arising from During fire, gases hazardous to health may be formed. the chemical Special protective equipment Wear full protective clothing, including helmet, self-contained positive pressure or pressure and precautions for firefighters demand breathing apparatus, protective clothing and face mask. Fire fighting In case of fire and/or explosion do not breathe fumes. Use standard firefighting procedures and equipment/instructions consider the hazards of other involved materials. Move containers from fire area if you can do so without risk. Cool containers I tanks with water spray. Specific methods Use standard firefighting procedures and consider the hazards of other involved materials. General fire hazards No unusual fire or explosion hazards noted.

6. Accidental release measures Personal precautions, Keep unnecessary personnel away. Keep people away from and upwind of spill/leak. Wear protective equipment and appropriate protective equipment and clothing during clean-up. Do not touch damaged containers emergency procedures or spilled material unless wearing appropriate protective clothing. Ensure adequate ventilation.

Local authorities should be advised if significant spillages cannot be contained. For personal protection, see section 8 of the SDS. Methods and materials for Large Spills: Stop the flow of material, if this is without risk. Dike the spilled material, where this is containment and cleaning up possible. Absorb in vermiculite, dry sand or earth and place into containers. Following product recovery, flush area with water. Small Spills: Wipe up with absorbent material (e.g. cloth, fleece). Clean surface thoroughly to remove residual contamination. Never return spills to original containers for re-use. For waste disposal, see section 13 ofthe SDS. Environmental precautions Avoid discharge into drains, waler courses or onto the ground. Water contaminated with this product may be sent to a sanitary sewer treatment facility, or a permitted waste treatment facility, in accordance with any local agreements.

7. Handling and storage Precautions for safe handling Avoid contact with eyes, skin, and clothing. Provide adequate ventilation. Wear appropriate personal protective equipment. Observe good industrial hygiene practices. Use care in handling/storage.

Conditions for safe storage, Store in accordance with locaUregionaUnational/international regulation. Do not store at elevated including any incompatibilities temperatures. Do not freeze. If frozen, thaw completely and mix thoroughly prior to use. Store in tightly closed container. Store away from incompatible materials (see Section 10 of the SDS). Material name: KLARAID* PC1175 Page: 217 Version number: 4.0

8. Exposure controls/personal protection Occupational exposure limits This mixture has no ingredients that have PEL, TLV, or other recommended exposure limit.

Biological limit values No biological exposure limits noted for the ingredient(s). Appropriate engineering Provide eyewash station and safely shower. Good general ventilation should be used. Ventilation controls rates should be matched to conditions. If applicable, use process enclosures, local exhaust ventilation, or other engineering controls to maintain airborne levels below recommended exposure limits. If exposure limits have not been established, maintain airborne levels to an acceptable level. Individual protection measures, such as personal protective equipment Eye/face protection Wear safety glasses with side shields (or goggles). Skin protection Hand protection Wear appropriate chemical resistant gloves. The choice of an appropriate glove does not only depend on its material but also on other quality features and is different from one producer to the other. Glove selection must take into account any solvents and other hazards present. Other Wear appropriate chemical resistant clothing. Respiratory protection If engineering controls do not maintain airborne concentrations below recommended exposure limits (where applicable) or to an acceptable level (in countries where exposure limits have not been established), an approved respirator must be worn. A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. Thermal hazards Wear appropriate thermal protective clothing, when necessary. General hygiene Always observe good personal hygiene measures, such as washing after handling the material considerations and before eating, drinking, and/or smoking. Routinely wash work clothing and protective equipment to remove contaminants.

9. Physical and chemical properties Appearance Color Amber Physical state Liquid Odor Strong Odor threshold Not available.

pH (concentrated product) 9.4 pH in aqueous solution 9 (5% SOL.) Melting point/freezing point 29 °F (-2 °C) Initial boiling point and boiling 220 °F (104 °C) range Flash point > 212 °F (> 100 °C) SETA(CC) Evaporation rate < 1 (Ether= 1) Flammability (solid, gas) Not applicable. Upper/lower ftammability or explosive limits Flammability limit - lower Not available. (%) Flammability limit - upper Not available. (%) Explosive limit - lower(%) Not available. Explosive limit - upper(%) Not available. Vapor pressure 18 mm Hg Vapor pressure temp. 70 °F (21 °C) Vapor density < 1(Air=1) Relative density 1.07 Relative density temperature 70 °F (21 °C) Solubility(ies) Solubility (water) 100 % Partition coefficient Not available. (n-octanol/water) Auto-ignition temperature Not available. Material name: KLARAID* PC1175 Page: 317 Version number: 4.0

Decomposition temperature Not available. Viscosity 1300 cps Viscosity temperature 70 "F (21 "C) Other information Explosive properties Not explosive. Oxidizing properties Not oxidizing. Pour point 34 "F (1 "C) Specific gravity 1.068 voe 0 % (Estimated)

10. Stability and reactivity Reactivity The product is stable and non-reactive under normal conditions of use, storage and transport.

Chemical stability Material is stable under normal conditions. Possibility of hazardous Hazardous polymerization does not occur. reactions Conditions to avoid Contact with incompatible materials. Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. Incompatible materials Strong oxidizing agents. Hazardous decomposition Hydrogen chloride, oxides of carbon and nitrogen evolved in fire. products

11. Toxicological information Information on likely routes of exposure Inhalation No adverse effects due to inhalation are expected.

Skin contact Causes skin irritation. Eye contact Causes serious eye irritation. Ingestion Expected to be a low ingestion hazard. Symptoms related to the Severe eye irritation. Symptoms may include stinging, tearing, redness, swelling, and blurred physical, chemical and vision. Skin irritation. May cause redness and pain. toxicological characteristics Information on toxicological effects Acute toxicity Product Species Test Results KL.ARAID PC1175 (CAS Mixture) Acute De1ma/ LD50 Rabbit > 2000 mg/kg Oral LD50 Rat > 5000 mg/kg Skin corrosion/inritation Causes skin irritation. Serious eye damage/eye Causes serious eye irritation. inritation Respiratory or skin sensitization Respiratory sensitization This product is not expected to cause respiratory sensitization. Skin sensitization This product is not expected to cause skin sensitization. Germ cell mutagenicity No data available to indicate product or any components present at greater than 0.1 % are mutagenic or genotoxic. Carcinogenicity IARC Monographs. Overall Evaluation of Carcinogenicity Not listed. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1052) Not regulated. US. National Toxicology Program (NTP) Report on Carcinogens Not listed. Material name: KLARAID* PC1175 Page: 417 Version number: 4.0

Reproductive toxicity This product is not expected to cause reproductive or developmental effects. Specific target organ toxicity

• Not classified.

single exposure Specific target organ toxicity

• Not classified.

repeated exposure Aspiration hazard Based on available data, the classification criteria are not met.

12. Ecological information Ecotoxicity Product Species Test Results KL.ARAID PC1175 (CAS Mixture)

Aquatic Crustacea LC50 Daphnia magna 6.6 mg/L, Static Renewal Bioassay, 48 hour NOEL Daphnia magna 0.62 mg/L, Static Renewal Bioassay, 48 hour Fish 20% Mortality Fathead Minnow 0.62 mg/L, Static Renewal Bioassay, 96 hour LC50 Bluegill Sunfish 4.5 mg/L, Static Acute Bioassay, 96 hour Fathead Minnow 0.9 mg/L, Static Renewal Bioassay, 96 hour Rainbow Trout 2.1 mg/L, Static Acute Bioassay, 96 hour NOEL Rainbow Trout 1 mg/L, Static Acute Bioassay, 96 hour Bioaccumulative potential Not bioaccumulating Mobility in soil No data available. Other adverse effects Not available. Persistence and degradability

• COD (mg02/g) 610
• BOD 5 (mg02/g) 0
• BOD 28 (mg02/g) 0

    - Closed BotUe Test(%         0 Degradation in 28 days)
    - Zahn-Wellens Test(%         9 Degradation in 28 days)

• TOC (mg C/g) 187

13. Disposal considerations Disposal instructions Collect and reclaim or dispose in sealed containers at licensed waste disposal site. Dispose of contents/container in accordance with local/regional/national/international regulations.

Hazardous waste code The waste code should be assigned in discussion between the user, the producer and the waste disposal company. Waste from residues I unused Empty containers or liners may retain some product residues. This material and its container must products be disposed of in a safe manner (see: Disposal instructions). Contaminated packaging Since emptied containers may retain product residue, follow label warnings even after container is emptied. Empty containers should be taken to an approved waste handling site for recycling or disposal.

14. Transport information DOT Not regulated as dangerous goods.

Some containers may be exempt from Dangerous Goods/Hazmat Transport Regulations, please check BOL for exact container classification. IATA Not regulated as dangerous goods. Material name: KLARAID* PC1175 Page: 517 Version number: 4.0

IMDG Not regulated as dangerous goods.

15. Regulatory information US federal regulations This product is a "Hazardous Chemical" as defined by the OSHA Hazard Communication Standard, 29 CFR 1910.1200.

TSCA Section 12(b) Export Notification (40 CFR 707, Subpt. D) Not regulated. CERCLA Hazardous Substance List (40 CFR 302.4) Not listed. SARA 304 Emergency release notification Not regulated. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1052) Not regulated. Superfund Amendments and Reauthorization Act of 1986 (SARA) SARA 302 Extremely hazardous substance Not listed. SARA 311/312 Hazardous Yes chemical Classified hazard Skin corrosion or irritation categories Serious eye damage or eye irritation SARA 313 (TRI reporting) Not regulated. Other federal regulations Clean Air Act (CAA) Section 112 Hazardous Air Pollutants (HAPs) List Not regulated. Clean Air Act (CAA) Section 112(r) Accidental Release Prevention (40 CFR 68.130) Not regulated. Safe Drinking Water Act Not regulated. (SOWA) Inventory status Country(s) or region Inventory name On inventory (yes/no)* Canada Domestic Substances List (DSL) Yes Canada Non-Domestic Substances List (NDSL) No United States & Puerto Rico Toxic Substances Control Act (TSCA) Inventory Yes

    *A Yes" indicates that all components of this product comply wijh the inventory requirements administered by the governing country(s)

A "No" indicates that one or more components of the product are not listed or exempt from listing on the inventory administered by the governing country(s). Food and drug administration 21 CFR 176.170 (components of paper and paperboard in contact with aqueous and fatty foods) 21 CFR 176.170 (components of paper and paperboard in contact with aqueous and fatty foods) US state regulations US. California Proposition 65 California Safe Drinking Water and Toxic Enforcement Act of 2016 (Proposition 65): This material is not known to contain any chemicals currently listed as carcinogens or reproductive toxins. For more information go to www.P65Wamings.ca.gov. US - California Proposition 65 - CRT: Listed date/Carcinogenic substance No ingredient listed. US - California Proposition 65 - CRT: Listed date/Developmental toxin No ingredient listed. US - California Proposition 65 - CRT: Listed date/Female reproductive toxin No ingredient listed. US - California Proposition 65 - CRT: Listed date/Male reproductive toxin No ingredient listed.

16. Other information, including date of preparation or last revision Issue date Oct-03-2014 Material name: KLARAID* PC1175 Page: 617 Version number: 4.0

Revi8ion date May-14-2019 Version# 4.0 NFPA ratings Health: 2 Flammability: 0 Instability: 0

                                ~

NFPA ratinge Uat of abbreviation* CAS: Chemical Abstract Service Registration Number ACGIH: American Conference of Govemmental Industrial Hygienists NOEL: No ObseNed Effect Leval STEL: Short Tenn Exposure Limit LC50: Lethal Concentration, 50% lWA: Time Weighted Average BOD: Biochemical Oxygen Demand COD: Chemical Oxygen Demand TOC: Total Organic Carbon IATA: lntemational Air Transport Association IMDG: International Maritime Dangerous Goods Code LD50:Letha1Dosa,500At DOT: Department of Transportation (49 CFR 172.101). GHS: Globally Harmonized System of Classification and Labeling of Chemicals. IARC: International Agency for Research on Cancer. HMIRA: Hazardous Materials lnfonnation Review Act (Canada). HPR: Hazardous Products Regulations (Canada). OSHA: Occupational Safety & Health Administration. TOG: Transportation of Dangerous Goods Regulations, Canada TSRN indicates a Trade Secret Registry Number is used in place ofthe CAS number. WHMIS: Workplace Hazardous Materials lnfonnation System. Reference.: No data available Dlaclalmer The information provided in this Safety Data Sheet is correct to the best of our knowledge, infonnation and belief at the date of its publication. The infonnation given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a wa1TBnty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. Revision information This document has undergone significant changes and should be reviewed in its entirety. Prepared by This sos has been prepared by SUEZ Regulatory Department (1-215-355-3300).

• Trademark of SUEZ. May be registered in one or more countries.

Material name: Kl..ARAID* PC1175 Page: 7 /7 Version number: 4.0

3IVI I Cerady*ne, Inc. a3Moompany LITHIUM-7LI HYDROXIDE MONOHYDRATE MATERIAL SAFETY DATA SHEET Prepared to U.S. OSHA, CMA, ANSI, Canadian WHMIS, European Union Standards, and the Japanese Industrial Standard JJS Z 7250: 2000 PART-l What is the material and what do I need to know in an emergency?

1. PRODUCT IDENTIFICATION TRADE NAME {AS LABELED): LITHIUM-7Li HYDROXIDE MONOHYDRATE

, CHEMICAL NAME/CLASS: Alkali Hydroxide . SYNONYMS: Lithium Hydrate 7 FORMULA: LiOH*H2O PRODUCT USE: Various Uses SUPPLIER/MANUFACTURER'S NAME: CERADYNE INC., a 3M company

   *ADDRESS:                                                        3250 South 614 Road, Quapaw, OK 74363 24 HR EMERGENCY PHONE:                                          InfoTrac*: 1-800-535-5053 TECHNICAL CONTACT PHONE:                                        1-918-673-2201 (8:00 a.m. to.4:30 p.m., Mon.-Fri.)
  . DATE OF UPDATE:.                                               .November 5, 2013

2. COMPOSITION and INFORMATION ON INGREDIENTS This *product is an alkali hydroxide.

CHEMICAL NAME CAS# EINECS# ENCS# w/w% EXPOSURE LIMITS IN AIR ACGIH~TLV OSHA-PEL NIOSH -OTHER TWA STEL TWA STE IDLH L ppm ppm ppm ppm ppm ppm Uthium-7Li Hydroxide 72255-97-1 Unlisted Unlisted 100 NE 2 2 NE 10 NIOSH REL: Monohydrate ceiling STEL=2 Currently there ar13 no ceiling exposure limits for t~is . compound. TIJe limits given are for Sodium Hydroxide, a related compound. . ,. EU CLASSIFICATION*: C [Corrosive]" EU RISK PHRASES: [R: 35] NE = Not Established. NOTE: ALL WHMIS required Information is included in appropriate sections based on the ANSI 2400.1-1998 format. This product has been classified in accordance with the hazard criteria of the CPR and the MSDS contains all the information required by the CPR, EU Directives and the Japanese Industrial Standard J/S Z 7250: 2000. *

3. HAZARD IDENTIFICATION

     . J:MERGENCY OVERVIEW: Lithium Hydroxide Monohydrate is white to off-white, odorless crystals. Health H~zards:

• This product is corrosive and can severely irritate and burn skin, eyes, mucous membranes, and any other contaminated tissues. Flammability Hazards: This product is not flammable. If e?(posed to extremely high temperatures, this product can decompose to generate irritating vapors and toxic gases (e.g., lithium oxides and lithium. carbonate). Reactivity Hazards: Contact of this product with water may generate some heat. See Section 1O (Stability and Reactivity Hazards).

Environmental Hazards: Re.leases to* the environment can be harmful or fatal to plants and animals. Emergency Recommendations: Persons who respond to releases of this product must protect themselves from inhalation of airborne dusts of Lithium Hydroxide Monohydrate, especially in areas which are downwind of the release. Extreme caution must be used when responding to releases. '

• SYMPTOMS OF OVEREXPOSURE BY ROUTE OF EXPOSURE: The most significant routes of overexposure for this product are skin ahd eye contact: The symptoms of overexposure to this product, via route of e~posure are as follows:

INHALATION: Inhalation of airborne dusts of this product can severely irritate and burn the nose, mouth, throat, and other tissues of the respiratory system. Inhalation overexposure may cause a life. threatening accumulation of fluid in the lungs (pulmonary edema) and ulceration of nasal passages. Effects of inhalation may be delayed. Chronic overexposure may

'    cause obstructive airway disease.                          '

• CONTACT WITH SKIN or EYES: Skin contact with Lithium Hydroxide Monohydrate can cause severe burns, ulceration, and permanent scarring. Skin damage may not be apparent until many hours following exposure,.as alkali.compounds penetrate the skin slowly. Chronic exposure to low levels can cause dermatitis.

LJTHIUM-7LI HYDROXIDE MONOHVDRATE P::inA1 OF10 November 5. 2013

3IVI I Ceradyne, Inc. a3Mcompany LITHIUM-7LI HYDROXIDE MONOHYDRATE

                             *****       3. HAZARD IDENTIFICATION (Continued)

CONTACT WITH SKIN or EYES (continued): Eye contact with the solid or a concentrated solution can disintegrate the corneal and conjunctiva! HAZARDOUS MATERIAL IDENTIFICATION SYSTEM

 - epithelia a!']d cause corneal opacification. Symptoms can include scarring, blistering, ulceration, clouding of the eye tissue, and blindness.

Delayed effects may include glaucoma and cataracts. !HEALTH HAZARD (BLUE) SKIN ABSORPTION: Skin absorption is not known to be a route of exposure for this product INGESTION: Ingestion of Lithium-7Li Hydroxide Monohydrate can irritate, burn, and damage the tissues of the mouth, throat, esophagus, FLAMMABILITY HAZARD (RED) 0 and other tissues of the digestive system. Symptoms may include burning pain, vomiting, diarrhea, hypersalivation, shortness of breath, po1enti.~.I glottic edema with respiratory compromise, and collapse. Concentrated solutions of Lithium-7Li Hydroxide Monohydrate can PHYSICAL HAZARD (YELLOW) cause perforatiqn of the stomach or gastrointestinal tract and corrosion and necrosis of the lips, mouth, tongue, pharynx, esophagus, and gastric mucosa. Ingestion of Lithiuin-7Li Hydroxide Monohydrate can be fatal. PROTECTIVE EQUIPMENT INJECTION: Injection is not a significant route of exposure for this EYES

• product. RESPIRAT6RY HANDS BODY.

HEALTH EFFECTS *oR RISKS FROM EXPOSURE: An Explanation in Lay Terms. SEE SECTION 8

• . ACUTE:*This product is corrosive, and can burn and damage eyes, skin, mucous membranes, and any other exposed tissue. Inhalation and For Routine Industrial Use and Handling Applications ingestion overexposure can be* fatal. Skin contact:can cause ulceration and permanent scarring. Eye contact can cause blindness.

CHRONIC: Chronic inhalation overexposure may cause obstructive See Section 16 for Definition of Ratings airway disease. Chronic skin exposure to low levels can cause dermatitis.

• TARGET ORGANS: . ACUTE: Skin, eyes, respiratory system. CHRONIC: Skin, respiratory system.

  *PART* U *,..*What-should I do if.a hazardous situation occurs?

4. FIRST-AID MEASURES Contaminated individuals should be taken for medical attention. Take copy of. label and MSDS to physician or health professional with contami.nated individ_ual. .

SKIN EXPOSURE: If this product contaminates the skin, immediately begin decontamination with running water. Minimum flushing is *for 15 minutes. Do not interrupt flushing. Remove exposed or contaminated clothing, taking care not to contaminate eyes. Seek immediate medical attention. EYE EXPOSURE: If this product enters the eyes, open contaminated individual's eyes while under gently running water. Use sufficient force to open eyelids. Haye contaminated individual "roll" eyes. Minimum flushing is for 15 minutes. Do not interrupt flushing. Contaminated individual must seek medical attention.

• INGESTION: If this product is swallowed, get immediate medical attention or* advice. DO NOT INDUCE VOMITING.

f\inse mouth with water to decontaminate the oral mucosa. If no respiratory compromise is present, dilute Immediately with 4 to 8 ounces of- milk or water. Never give anything by mouth to a victim who is unconscious or having convulsions.

• If victim*vomits*natlJrally;*position head lower than chest area so that aspiration into the lungs cannot occur.* Contact a physician or poison control center immediately.

INHALATION: Remove victlm(s) to fresh air as quickly as possible. Only trained personnel should administer supplemental oxygen and/or cardiopulmonary resuscitation if necessary. Do not use mouth-to-mouth method if victim ingested or inhaled the substance; induce *artificial respiration with th.e aid of a pocket mask equipped with a one-way valve or other proper respiratory medical device. Seek Immediate medical attention. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: Skin and respiratory disorders may be aggravated by prolonged overexposure to this product. RECOMMENDATIONS TO PHYSICIANS: Provide general supportive measures. Prolonged skin irrigation may be required in severe cases, occasionally up to 12 to 24 hours. Debridement of the burn and skin grafting are more successful if performed early, and may prevent delayed necrosis. Experimental treatment for eye contamination has shown that topical applic.ations and subjunctival injections of 2% ascorbic acid may significantly decrease the incidence of corneal ulcerations and perforations. This treatment was given tor 32 days. LITHIUM-7LI HYDROXIDE MONOHVDRATE b"!lnn'lnc1n Mnu.ornh.a* I:: tJl\'1-:t

3IVI I Ceradyne, Inc. a 3M company UTHIUM-7LI HYDROXIDE MONOHYDRATE

5. FIRE-FIGHTING MEASURES FLASH POINT: Not applicable.

AUTOIGNITION TEMPERATURE: Not applicable. .NFPARATING

*

• FLAMMABLE LIMITS *(1n* air byvolurile, %): * * * * * ** FLAMMAeii:,r,. *
• Lower: Not applicabre.

Upper: Not applicable. FIRE EXTINGUISHING MATERIALS: Use extinguishing material suitable to the surrounding fire. Water Spray: YES Carbon Dioxide: NO HEALTH INSTABILITY Foam: YES Dry Chemical: YES Halon: YES Other: Any "ABC" Ciass UNUSUAL FIRE AND EXPLOSION HAZARDS: This product is corrosive and presents a severe' contact hazard to firefighters. If * , exposed. io extr~r:n~ly hiQ~. temperature~, this P.roduct can decompose OTHER to generate irritating vapors and to"ic gases (e.g., lithium oxides and

• lithium carbonate). Contact of this product with water may generate See Section 16 for
• some heat. .When wet, this product may attack metals such as Definition of Ratings aluminum, tin, lead, and zinc and produce flammable and explosive hydrogen gas.

Explosion Sensitivity to Mechanical Impact: Not applicable. Explosion Sensitivity to Static Discharge: Not applicable. / SPECIAL FIRE-FIGHTING PROCEDURES: Use any method suitable for the s~rrounding fire and other materials involved. Water can be used to extinguish fire as long as the water is used in flooding amounts and care is taken to not spatter or splashithe product. Incipient fire responders should wear eye protection. Structural firefighters must wear Self-Contained

    ~,r~at~it)g,:Apparatus and full protectiv!:! equipment. Chemical resistant clothing may be necessary. Use water spray to ke~p fir.e-"exposed containers cool. Move containers from fire area if it can be done without -risk to personnel. If possible, prevent runoff. water from entering storm drains, bodies of water, or other environmentally sensitive areas.

6. ACCIDENTAL RELEASE Ml;ASURES SPILL AND LEAK RESPONSE: Uncontrolled releases should be responded to by trained personnel using pre-planned pr9..c;;e9~res. Proper protective equipment should be used. In case of a large spill, clear the affected area, protect people, anc:1 ,respond with trained personnel. Minimum Personal Protective Equipment should be Level B: triple-gloves (rubber

  ..glQves;*and niJrile gloves over latex gloves), chemical resistant suit and boots, hard hat, and Self Contained
 .'*$reath111g .Apparatus. Releases of Lithium-7U Hydroxide Monohydrate can be detected by the use of wet pH paper, which will turn blue upon contact with the released product. Sweep up spilled material carefully, avoid the generation of airborne dusts. Neutralize area with citric aqid or other agent suitable for bases. Test area with litmus paper to in~ure neutrali~~tion i~. qo~plet~.. Decontaminate th! area thoroughly. Place all spill residue In a suitable .container and seal.

Dispose of in accordance with U.S. federal, State, and local hazardous waste disposal regulations, EC States and those of Canada and its Provinces {see Section 13, Disposal Considerations). PART Ill How can I prevent hazardous situations from occurring?

7. HANDLING and STORAGE WORK PRACTICES AND HYGIENE PRACTICES: As with all chemlcals, avoid getting this product ON YOU or IN YOU.

Wash thoroughly after using this product. Do not eat, smoke, apply, cosmetics, or drink while handling this material. Avoid

• generating airborne dusts of this product. Remove contaminated clothing immediately.

STORAGE AND HANDLING PRACTICES: All employe_es who handle this material should be trained to handle it safety. Avoid breathing airborne dusts .generated by Uthium-7Li Hydroxide Monohydrate. Ensure containers of this product are properly labeled. store containers in a cool, dry location, away from direct sunlight, sources of intense heat, or where freezing is possible. Open containers slowly on a stable surface. Keep container tightly closed when not in use. Store away from incompatible material. Lithium-7Li Hydroxide Monohydrate emergency equipment should be available near the point of use. *

• Workers who handle Lithium-7Ll Hydroxide Monohydrate should wear protective clothing, as listed in Section 8 (Exposure Controls - Personal Protection).
• Instant-acting showers should be available in the event of an emergency.
• Special eye-wash fountains or similar equipment should be available for eye irrigation.
• Proper respiratory protection equipment must be provided and worke(s using such equipment must be carefully trained in its operation and limitations. . , ... . -*

LITHIUM-7LI HYDROXIDE MONOHYDRATE Paae30F10

3MI Ceradyne, Inc. a 3M company '

7. HANDLING and STORAGE (Continued)

LITHIUM-7LI HYDROXIDE MONOHYDRATE STORAGE AND HANDLING PRACTICES (continued): Ensure containers of this product are properly labeled. Store containers in a cool, dry location, away from direct sunlight, sources of intense heat, or where freezing is possible. Open containers slowly on a stable surface .. Keep container tightly closed when not in use. Store away from incompatible material. Lithium-7Li Hydroxide Monohydrate emergency equipment should be available near the point of use. PROTECTIVE PRACTICES DURING MAINTENANCE OF CONTAMINATED EQUIPMENT: Follow practices indicated in , Section.~- (Accidental R~!~ase Measµres). Make certain that application equipment is locked and tagged-out safely, as applicable. Collect all rinsates and. dispose of in accordance with U.S. Federal, State and local regulations, those of Canada and its provinces, and those of EU Mep,ber States.

8. EXPOSURE CONTROLS - PERSONAL PROTECTION INTERNATIONAL EXPOSURE LIMITS FOR COMPONENTS: Currently, there are no international exposure limits for Lithium-7Li Hydroxide Monohydrate. The following are exposure limits _in place: for the related compound Lithium Hydroxide:

LITHIUM HYDROXIDE: LITHIUM HYDROXIDE (continued): Japan: OEL = Japan: OEL = 1 mg/m3, JAN 1999 United Kingdom: STEL = 1 mg/m3, SEe.2000

  *. VENTILATION AND ENGINEERING CONTROLS: Use with adequate ventilation to ensure exposures are below limits
  * *.provided in Section 2 (Composition and Information on Ingredients). Prudent practice is to ensure eyewash/safety shower
  **. stations are available near areas where this product is used.

The following information on appropriate Personal Protective Equipment is provided to assist employers in complying with OSHA regulations found in 29 CFR Subpart I (beginning at 1910.132), equivalent standard of Canada, or standards of EU member states (including EN 149 for respiratory PPE, and EN 16£! for face/eye protection). Please reference applicable regulations arid standards for relevant details. RESPIRATORY PROTECTION: Maintain airborne contaminant concentrations below guidelines listed in Section 2 (Composition and Information on Ingredients) if applicable. If respiratory protection is needed, use only respiratory protection authorized in the U.S. Federal OSHA Respiratory.Protection Standard (29 CFR 1910.134), equivalent U.S. State standards, Canadian CSA Standard 294.4-93, the European .Standard .EN149,.standards of EU. member states, or requirements of Japan. Oxygen'levels below**19.5% are considered 'IDLH by OSHA; 'lh suqh atmospheres, use of a full-facepiece pressure/demand SCBA or a full faceplece/supplied air respirator with* au~iliary self-contained air supply is required under OSHA's Respiratory Protection Standard (1910.134-1998). The following are NIOSH respiratory guidelines for the related

    . compound, Sodium Hydroxid~.

• SODIUM HYDROXIDE**
• CONCENTRATION . -RESPIRATORY PROTECTION

.;: lip to 1O-mg/m~:* : ..>supplied f,ir Respirator'. (SAR) operated irla .continuous flow mooe; Jull facepiece respirator with

       *                     ** -* * *._;, high~efficiency particulate -filter(s); ,powered air~purifying. respirator ,with dust. a11d ;ni isfJilt¢r(s); full-
                              *.-,** facepiece*.sert~contairied.Breathing;Apparatus(SCBA); or.full~facepiece SAR.; _ .:" ..

Emergency or-Planned Entry into Unknown Concentrations or IDLH Conditions: Positive pressure, full-facepiece SCBA or positive pressure, full-facepiece SAR with an auxiliary positive pressure SCBA. ESCAPE: Full-faceplece respirator with high-efficiency particulate filter(s) or escape-type SCBA. EYE PROTECTION: Splash goggles or safety glasses. If necessary, refer to U.S. OSHA 29 CFR 1910.133, Canadian Standards, the European Standard EN166, or applicable Standards of Japan for further information. HAND PROTECTION: Wear butyl rubber gloves for routine industrial use. Check gloves for leaks prior to use. If necessary, refer to U.S. OSHA 29 CFR 1910.138, appropriate Standards of Canada, the European Economic Community, or applicable Standards of Japan. . BODY PROTECTION: If necessary, use body protection appropriate for task (e.g., lab coat, Tyvek suit, *rubber apron). If necessary, refer to appropriate Standards of Canada, the European Union, or Japan. If a hazard of injury to the feet exists due to falling objects, rolling objects, where objects may pierce the soles of the feet, or where employee's feet may be exposed to electrical hazards, use foot protection, as described in U.S. OSHA 29 CFR 1910.136. *

9. PHYSICAL and CHEMICAL PROPERTIES EVAPORATION RATE (nBuAc = 1): Not applicable. VAPOR DENSITY: Not applicable. .

     , SPECIFIC GRAVITY (water= 1): 1.51                                      MELTING/FREEZING POINT: 471 "C (880°F) [anhydrous form]

SOLUBILITY IN WATER: Soluble. BOILING POINT: 924°C (1695°F) [anhydrous form] VAPOR PRESSURE: Not applicable. Q.!:!: Approximately 14 (1N solution)

 ' ODOR TliRESHOLD: Ocl6rless.                                                MOLECULAR WEIGHT: 42.0375 COEFFICIENT OF OIL/WATER DISTRIBUTION (PARTITION COEFFICIENT): Not available.

APPEARANCE, ODOR AND COLOR: Lithium Hydroxide Monohydrate is white to off-white, odorless crystals. HOW TO DETECT THIS SUBSTANCE (warning properties): Wet litmus paper will turn blue upon contact with this material. LITHIUM*7LI HYDROXIDE MONOHYDRATE Paae4OF10 November 5, 2013

3NII Ceradyne, Inc. .a 3M tompany. ,

10. STABILITY and REACTIVITY LITHIUM-7LI HYDROXIDE MONOHYDRATE STABILITY: Can react slowly with carbon dioxide in air and form lithium carbonate.

DECOMPOSITION PRODUCTS: If exposed to extremely high temperatures, this product can decompose to generate irritating vapors and toxic gases (e.g., lithium oxides and lithium carbonate). MATERIALS WITH WHICH SUBSTANCE IS INCOMPATIBLE: This product is not compatible with carbon dioxide, strong acids, aluminum, zinc, ~nd strong oxidizers. HAZARDOUS POLYMERIZATION: Will not occur. CONDITIONS TO AVOID: Contact with incompatible chemicals. PART IV /s .there any other useful information about this material?

11. TOXICOLOGICAL INFORMATION TOXICITY DATA: Currently, there are no specific toxicology data currently available for Lithium-7Li Hydroxide Monohydrate.

The following are toxicological data for the related compound, Lith.ium Hydroxide: LITHIUM HYDROXIDE: LITHIUM HYDROXIDE (continued): LITHIUM HYDROXIDE (continued): ,: , LDso (oral, rat) = 21 O mg/kg; Behavioral: LD50 (intratracheal, rat) = 8200 µg/kg; Lungs, I..Dlo (subcutaneous, mouse)= 300 mg/kg

    . ** * .somnolence (general depressed activity),          Thorax, or Respiration: other changes;          TDLo (oral, mammal) = 9100 µg/kg/26 convulsions or effect on seizure threshold;       Blood: hemorrhage                                    weeks/intermittent; Liver: liver function tests Nutritional and Gross Metabolic: weight loss  LDso (oral, mouse) = 363 mg/kg; Behavlpral;              impaired; Blood: pigmented or nucleated red
           .or decreased weight gain.                 ,       somnolence (general depressed activity),             blood cells; Nutritional and Gross Metabolic:

LCso (inhalation, rat) * = 960 mg/m3/4 hol,JfS; convulsions or effect on seizure threshold; , weightless or decreased weight gain , Lungs, Thorax, or Respiration: other Nutritional and Gross Metabolic: weight loss rcLo (inhalation, mammal) = 8 mg/m3/4 changes or decreased weight gain * / hours/30 days/intermittent; Lungs, Thorax, or

                  * * **                                                                                           Respiration: other changes SUSPECTED CANCER AGENT: This product is not found on the following lists: FEDERAL OSHA Z LIST, NTP, IARC, and CAUOSHA, and therefore is neither considered to be *nor suspected to be cancer-causing agents by these agencies.

IRRITANCY Of :PRODUCT: This product is severely irritating and corrosive to all contaminated tissue. SENSITIZAnb'N Tb THE PRODUCT: Lithium-7Li Hydroxide Monohydrate is not known to be a human skin or respiratory sensitizer. *., .. , REPRODUCTIVE TOXICITY INFORMATION: Listed below is information concerning the effects of this gas on the human reproductive system.. * . .-* Mutaqenicity: Lithlum-7Li Hydroxide fylonohydrate is not reported to cause-reproductive effects in humans:

           .Embryoto'4icity: Lithium-7Li Hydroxide Monohydrate is not reported to produce embryotoxic* effects in humans.
        ,i;ji"fer.atogeliicity: :. Uthium-7Li .Hydroxide Monohydrate is not reported to cause teratogenic effects in humans.
         *i:.Reproductive\T.oxicity: Lithium-7LI Hydroxide Monohydrate is not reported to cause reproductive effects in humans.

A mutagen is: a *:chemical that causes permanent changes to genetic material (DNA) such that the changes will propagate through generational lines. An embrvotoxin is a chemical that causes damage to a developing embryo (i.e. within the first eight weeks of pregnancy in humans), but the damage does not propagate across generational lir,es. A teratogen is a chemical that causes damage to a developing fetus, but the damage does not propagate across generational lines. A reproductive toxin is any substance that interferes in any way with the reproductive process. BIOLOGICAL -EXPOSURES INDICES (BEls): Currently, there are no Biological Exposure Indices (BEls) applicable to this product.

• 12. ECOLOGICAL INFORMATION ALL WORK PRACTICES MUST BE AIMED AT ELIMINATING ENVIRONMENTAL CONTAMINATION.

ENVIRONMENTAL STABILITY: Tliis product can react slowly with carbon dioxide in air and form lithium.carbonate. EFFECT OF MATERIAL ON PLANTS or ANIMALS: This product can adversely affect terrestrial plants and animals, especially if release in large quantities. EFFECT OF CHEMICAL ON AQUATIC LIFE: This product can adversely affect aquatic plants and animals if released into an aquatic environment, especially if release.in large quantity.

13. DISPOSAL CONSIDERATIONS PREPARING WASTES. FOR DISPOSAL: Waste disposal must.be in accordance with appropriate Federal, State, and local regulations. This product, if unaltered by use, may be disposed of by treatment at a permitted facility or as advised by ypur local waste regulatory authority. Empty containers, as defined by appropriate sections of RCRA, are not HCRA hazardous wastes. Insure proper management of any residuals remaining in containers.

EPA WASTE NUMBER: D002 (Characteristic/Corroslvity) applicable to w1=1stes qnly of this product. LITHIUM-7LI HYDROXIDE MONOHVDRATE p,.,..,.,; nc 1n

3MI Ceradyne, Inc.; a3Mcompany

14. TRANSPORTATION INFORMATION LITHIUM-7LI HYDROXIDE MONOHYDRATE THIS PRODUCT IS HAZARDOUS AS DEFINED BY 49 CFR 172.101 BY THE U.S. DEPARTMENT OF TRANSPORTATION.

PROPER SHIPPING NAME: Lithium Hydroxide, Monohydrate HAZARD CLASS NUMBER and DESCRIPTION: Class 8 (Corrosive) UN IDENTIFICATION NUMBER: UN 2680 DOT LABEL(S) REQUIRED: *Class 8 (Corrosive) PACKAGING GROUP: II EMERGENCY RESPONSE GUIDEBOOK NUMBER (2000): 154 MARINE POLLUTANT: Not applicable (49 CFR 172.101, Appendix 8). TRANSPORT CANADA TRANSPORTATION OF DANGEROUS GOODS REGULATIONS: This product is considered as Dangerous Goods, per regulations of Transport Canada. The use of the above U.S. DOT information from the U.S. 49 CFR regulations is allowed for shipments that originate in the U.S. For shipments via ground vehicle or rail that originate in Canada1 J1e fol!9wir:ig infc;,nnation is applicable.. PROPER SHIPPING NAME: . Lithium Hydroxide Monohydrate HAZARD CLASS NUMBER and DESCRIPTION: Class 8 (Corrosive) UN IDENTIFICATION NUMBER: UN 2680 PACKING GROUP: II HAZARD LABEUS) REQUIRED: Class 8 (Corrosive) SPECIAL PROVISIONS: None EXPLOSIVE LIMIT & LIMITED QUANTITY INDEX:

• 1
• ERAP INDEX: . None PASSENGER CARRYING SHIP INDEX: None PASSENGER CARRYING ROAD OR RAIL VEHICLE INDEX: 15 MARINE POLLUTANT: ;This product is not a Marine Polh.Jtant under Transport Canada regulations.

INTERNATIONALAIRTRANSPORTASSOCIATION {IATA): This product is classified,-by rules of IATA, as follows:*. PROPER SHIPPING NAME: Lithium Hydroxide Monohydrate HAZARD CLASS NUMBER and DESCRIPTION: Class 8 (Corrosive) UN IDENTIFICATION NUMBER: UN 2680 PACKING GROUP:**. II HAZARD LABEUS) REQUIRED:

• Class 8 (Corrosive)

PASSENGER & CARGO AIRCRAFT PACKING INSTRUCTION: 814

 .PASSENGER&'CARGO AIRCRAFT-MAXIMUM NET QUANTITY/PKG: 15 kg CARGO AIRCRAFT ONLYPACKING INSTRUCTION: 816 CARGO AIRCRAFT ONLY MAXIMUM NET QUANTITY/PKG: 50 kg SPECIAL PROVISIONS:                                      None ERG CODE:                                                BL INTERNATIONAL MARITiME ORGANIZATION. (IMO): This product is classified as follows, per rules of the IMO.

UN IDENTIFICATION NUMBER: UN 2680 PROPER SHIPPING NAME: Lithium Hydroxide Monohydrate CLASS: 8 SUBSIDIARY RISK: None

  *PACKING GROUP:                                            II SPECIAL PROVISIONS:                                       None HAZARD LABEL(S) REQUIRED:                                 Class 8 (Corrosive)

LIMITED QUANTITIES: 1 kg PACKING INSTRUCTION: P002 Ems: F-A, S-B STOWAGE AND SEGREGATION: Category A. EUROPEAN AGREEMENT CONCERNING THE INTERNATIONAL CARRIAGE OF DANGEROUS GOODS BY ROAD (ADR): This is classified as follows, per regulations of the U.N. Economic Commission for Europe. UN NUMBER: UN 2680 NAME AND DESCRIPTION: Lithium Hydroxide Monohydrate CLASS: 8 CLASSIFICATION CODE: C6 PACKING GROUP: II LITHIUM-7LI HYDROXIDE MONOHYDRATE Page6OF10 November 5, 2013

Ceradyne, Inc. a 3M company UTHIUM-7LI HYDROXIDE MONOHYDRATE

14. TRANSPORTATION INFORMATIO~-(Continued)

EUROPEAN AGREEMENT CONCERNING THE INTERNATIONAL CARRIAGE OF DANGEROUS GOODS BY ROAD (ADR) [continued]: LABELS: 8 SPECIAL PROVIS-IONS: None LIMITED QUANTITIES: LQ23 PACKING INSTRUCTION: P002 MIXED PACKING INSTRUCTION:. MP10 HAZARD IDENTIFICATION NUMBER: 80

15. REGULATORY INFORMATION U.S. STATE AND FEDERAL REGULATIONS:

U.S. SARA REPORTING REQUIREMENTS: Lithium-7Li Hydroxide Monohydrate is not subject to the reporting requirements of Sections 302, 304, and 313 of Title 111 of the Superfund Amendments and Reauthorization Act.

 . U.S. SARA 302 EXTREMELY HAZARDOUS THRESHOLD PLANNING QUANTITY: Not applicable.

• .i;_u.s. SARA 304 EXTREMELY HAZARDOUS REPORTABLE QUANTITY (RQ): Not applicable:

U.S. CERCLA REPORTABLE QUANTITY (RQ): 0002 Unlisted Hazardous Wastes Characteristic .of Corrosivity = 1:QD lb (45.4 kg). U.S. TSCA INVENTORY STATUS: Lithium-7Li-Hydroxide Monohydrate is manufactured under a LVE in accordance with TSCA regulations. * *

• OTHER U.S. FEDERAL REGULATIONS: Not applicabl~.

CALIFORNIA SAFE DRINKING WATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65): Lithium-7Li Hydroxide Monohydrate is noton the California Proposition 65 Lists. _ANSl*LABELING (2129.1: Provided to Summarize Occupational Hazard Information): DANGER! CORROSIVE. CAUSES

  £~EiSKlr;,J;-GASTROINTESTINAL TRACT, AND RESPIRATORY TRACT BURNS. Do not taste or swallow. Do not get on skin,' in eyes, or on clothes. Do not breathe airborne dusts. Keep container closed. Use only witt, adequate ventilation. Wash thoroughly after handling. Wear gloves and goggles. Use in accordance with the Material Safety Data Sheet.

FIRST-AID: IF I_NHALED, remove to fresh air. Do not use mouth-to-mouth method if victim ingested or

                                . -*inhaled the substance; induce artificial respiration with the aid of a pocket mas~ equipped with a one-way valve or other proper respiratory medical device. If breathing is difficult, give oxygen.

Call a physician. IN CASE OF CONTACT, immediately flush eyes or skir:i with water for at l!:}ast 15 minutes while removing contaminated clothing and shoes. Call a physician. Wash clothing before reuse. (Discard contaminated shoes). *

• DO NOT REMOVE THIS PRODUCT LABEL..

ADDITIONAL. CANADIAN REGULATIONS: CANADIAN DSLJNDSL INVENTORY: Lithium-7Li Hydroxide Monohydrate* is not listed on the DSL or NDSL Inventories. The. related material Lithium Hydroxide is listed on the DSL Inventory. OTHER CANADIAN REGULATIONS: Not applicable. CANADIAN ENVIRONMENTAL PROTECTION AGENCY (CEPAI PRIORITY SUBSTANCES LISTS: This material is not on the CEPA Priorities.Substances Lists. * *

• CANADIAN WHMIS CLASSIFICATION and SYMBOLS: Class E: Corrosive ADDITIONAL EUROPEAN UNION INFORMATION:

EU LABELING AND CLASSIFICATiON: This product is considered to be dangerous according to current European Community Guidelines. This product meets the definition of EU Hazard Class C (Corrosive). , EU CLASSIFICATION: C.(Corrosive] EU RISK PHRASES: [R: 35): Cause severe burns. LITHIUM-7LI HYDROXIDE MONOHVDRATE Paae70F10

• 3IVI I Ceradyne, Inc.u3Mcompany ' LITHIUM-7LI HYDROXiDE MONOHYDRATE

                                          . 15.. REGULATORY INFORMATION {Continued)

ADDITIONAL EUROPEAN COMMUNITY INFORMATION (continued): EU SAFETY PHRASES: [S: i/2]: Keep locked up and out of reach of children. (This safety phrase can be omitted from the label when th~ substance or preparation is sold for industrial use only.) [S: 26]: In case of contact with the eyes, rinse

. immediately with plenty of water. [S: 37/39]: Wear suitable gloves anq eye/face protection. [S: 45]: In case of accident or if you feel unwell, seek medical advice immediately (show label where possible).

EU CLASSIFICATION SYMBOLS: A,DDITIONAL JAPANESE REGULATION_S: JAPANESE ENCS: This product is not on the ENCS Inventory, by the CAS # 72255-97-1. POISONOUS AND DELETERIOUS SUBSTANCES CONTROL LAW: This product is not a listed Specified Poisonous. Substance under the Poisonous and Deleterious Substances Control Law.

16. OTHER INFORMATION PREPAij~P BV:.. C PO Box 3519, La Mesa, CA91944-3519 (619) 670-0609 The infonnation contained herein is furnished without warranty of any .kind. Persons using this.:product .should consider these, data only as a supplement to other Information gathered by them .and must make independent determinations of suitabllity _and completeness of. informationJrom all

      **sources to assure proper use'and*disposal of this material, the safety-of* health of employees and customers and the protection of the environment.

• DEFINITIONS OF TERMS A large number of abbreviations and acronyms appear on a MSDS. Some of these, which are commonly used, include the following:

CAS #: This is *the Chemical Abstract Service Number that uniquely EXPOSURE LIMITS IN AIR (continued): identifies each _constituent. IDLH-lmmedlately Dangerous to Life.and Health: This level represents a EXPOSURE Ll~ITS IN AIR: concentration from which one can escape within 30-minutes without CEILING LEVEL:-Toe concentration that shall not be exceeded during any suffering escape-preventing or permanent injury. part.of the*.working exposure. ~. *. ,,. C::.-.1HAZARDOUs,;,,MA:TERIALS:,,dDENTIFICATION, .:SYSTEM ..,:,HAZARD lOQ:

• Limit of Quantitation. .=. *, .i.. ' *, ** ,. * . :* '. ;., , , -, ,.,) ,.;,,c'.,:; ,11:RATINGS: '!'i':rhisiraijng-:system *was{cleveloped ,by,the NiJ,tional Paint:and MAK: *Federal Republic of Germany-Maximum Concentration Values In the . **.Coating *'Association ,and *has been adopted* by industry to, identify the workplace. degree of chemical hazards.

NE: Not Established. When no exposure guidelines are established, an HEALTH HAZARD: entry of NE is made for reference. O (Minimal Hazard: No significant health risk, irritation of skin or eyes not NIC: Notice of Intended Change. anticipated. Skin Irritation: Essentially non-irritating. PII or Draize = "O". NIOSH CEILING: The exposure that shall not be exceeded during any part Eye Irritation; Essentially non-irritating, or minimal effects which clear in < of the workday. If instantaneous monitoring is not feasible, the ceiling shall 24 hours [e.g. mechanical irritation]. Draize = "On. Oral Toxicity LD60 Rat:< be assumed as a 15-minute TWA exposure (unless otherwise specified) 5000 mg/kg. Dermal Toxicity LD5/)Rat or Rabbit:< 2000 mg/kg. Inhalation th'at shall not be exceeded at any time during a workday. Toxicity 4-hrs LC50 Rat: < 20 mg/L); 1 (Slight Hazard: Minor reversible Injury NIOSH RELs: NIOSH's Recommended Exposure Limits. may occur; slightly or mildly irritating. Skin Irritation; . Slightly or mildly PEL-Permissible Exposure Limit: OSHA's P.ermissible Exposure Limits. Irritating. Eye Irritation: Slightly cir mildly irritating. Oral Toxicity LD60 Rat: > This exposure value means exactly the same as a TLV, except that ft is 500-5000 mg/kg. Dermal Toxicity lD50Rat or Rabbit: > 100().2000 mg/kg. enforceable by OSHA. The OSHA Permissible Exposure Limits are based Inhalation Toxicity LC50 4-hrs Rat: > 2-20 mg/L); 2 (Moderate Hazard: In the 1989 PELs and the June, 1993 Air Contaminants Rule (Federal Temporary or transitory injury may occur. Skin Irritation: Moderately

• Register: 58: 35338"35351 and'58: 40191). Both the current PEL.s and the irritating; primary irritant; sensitizer. PII or Dralze* > 0, < 5. Eye Irritation:

vacated PELs are indicated. The phrase, "Vacated 1989 PEL," is placed Moderately to severely irritating and/or corrosive; reversible corneal opacity; next to the PEL that was vacated by Court Order. corneal involvement or irritation clearing in 8-21 days. Dralze > 0, .s 25. SKIN: Used when a there is a danger of cutaneous absorption. Oral Toxicity LD50 Rat: > 50-500 mg/kg. Dermal Toxicity LD50Rat or Rabbit: STEL-Short Term Exposure Limit: Short Term Exposure Limit, usually a > 200-1000 mg/kg. Inhalation Toxicity LC50 4-hrs Rat: > 0.5-2 mg/L); 3 15-minute time-weighted average (TWA) exposure that should not be (Serious Hazard: Major injury likely unless prompt action is taken and exceeded at any time during a-workday, even if the 8-hr TWA is within the medical treatment Is given; high level of toxicity; corrosive. Skin Irritation: TLV-TWA, PEL-TWA or REL-TWA. Severely, Irritating and/or corrosive; may destroy dermal tissue, cause skin TLV-Threshold Limit Value: An airborne concentration of a substance that burns, dennal necrosis. PII or Dralze > 5-8 with destruction of tissue. Eye represents conditions under -which it is generally believed that nearly ail Irritation: Corrosive, irreversible destruction of ocular tissue; corneal workers may be repeatedly exposed without adverse effect. The duration involvement or irritation persisting for more than 21 days. Draize > 80 with must be considered, Including the 8-hour. effects irreversible in 21 days. Oral Toxicity LD50 Rat: > 1-50 mg/kg. TWA-Time Weighted Average: Time Weighted Average exposure . Dermal Toxicity LD50 Rat or Rabbit > 20-200 mg/kg. Inhalation Toxicity concentration for a conventional 8-hr (TLV, PEL) or up to a 10-hr (REL) LCsq 4-hrs Rat: > 0.05-0.5 mg/L); workday and a 40-hr workweek. LITHIUM*7LI HYDROXIDE MONOHYDRATE o .... - .... o ni:--1n

        /3M                  I*Ceradyne, Inc.

a3M company LITHIUM-7LI HYDROXIDE MONOHYDRATE* DEFINITIONS OF TERMS (Continued). HAZARDOUS MATERIALS IDENTIFICATION SYSTEM HAZARD HAZARDOUS MATERIALS IDENTIFICATION SYSTEM HAZARD RATINGS {continued): RATINGS (continued): HEALTH HAZARD (continued): PHYSICAL HAZARD (continued): 4 (Severe Hazard: Life-threatening; major or permanent damage may result 2 (Water Reactivity: Materials that may react violently with water. Organic from* single or repeated exposure. Skin Irritation: Not appropriate. Do not Peroxides: Materials that, In themselves, are normally unstable and will rate as a "4", based on skin irritation alone. Ey(J Irritation: Not appropriate. readily undergo violent chemical change, but will not detonate. These Do not rate as a "4", based on eye irritation alone. Oral Toxicity LDso Ffal: .s materials may also react violently with water. Explosives-. Division 1.4 - 1 mg/kg. Dermal Toxicity LDsoRat or Rabbit .s 20 mg/kg. Inhalation Explosive substances where the explosive effect are largely confined to the Toxicity Leso 4-hrs Rat: .s 0.05 mg/L). package* and no projection of fragments of appreciable size or, range are FLAMMABILITY HAZARD: expected. An external fire must not cause virtually instantaneous explosion o (Minimal Hazard-Materials that will not burn In air when exposure to a" of almost the entire contents of the package. Compressed Gases: temperature of 815.s*c [1500°F) for a period of 5 minutes.); 1 (Slight Pressurized and meet OSHA definition but< 514.7 psi absolute at 21.1°c Hazard-Materials that must be pre-heated before Ignition can occur. (70°F) [500 psig). Pyrophorics: No Rating. Oxidizers: Packing Group II Material require considerable pre-he~ting, under all ambient temperature Solids: any material that, either in concentration tested, exhipits a mean conditions before ignition and combustion can occur, Including: Materials burning time of* less than or equal to the mean buming time of a 2:3 that will bum in air when exposed to a temperature of 815.5°C (1500°F) for potassium bromate/cellulose mixture and the criteria for Packing Group I are a period of 5 minutes *or less; Wquids, solids and semisolids having a flash not met. Uguids: any material that exhibits a mean pressure rise time less

  .,* point at or above 93.3°C [200°F] (e.g. OSHA Class 111B, or; Most ordinary                than or equal to the pressure rise of a 1:1 aqueous sodium chlorate solution 1:',,. combustible materials [e.g. wood, paper, etc.]; 2 (Moderate Hazard-                    (40%)/cettutose mixture and the criteria for Packing Group I are not met.

<:. Materials that must be moderately heated or exposed to relatively high Unstable Reactives: Substances that may pQlymerize, decompose,

* *

• ambient temperatures before ignition can occur. Materials In this degree condense, or self*react at ambient temperature and/or pressure, but have a would not, under normal conditions, form hazardous atmospheres in air, but low potential for significant heat generation or explosion. Substances that under high ambient temperatures or moderate heating may release vapor in readily form peroxides upon exposure to air or oxygen at room sufficient quantities to produce hazardous atmospheres in air, Including: temperature); 3 (Water Reactivity: Materials that may form explosive Liquids having a flash-point at or above 37.8°C [100°F]; Solid materials In reactions with water. Organic Peroxides: Materials that are capable of the form of course dusts that may bum rapidly but that generally do not form detonation or explosive reaction, but require a strong initiating source, or explosive atmospheres; Solid materials in a fibrous or shredded form that must be heated under confinement before initiation; or materials that react may burn rapidly and create flash fire hazards (e.g. cotton, sisal, hemp; explosively with water; Explosives:. Division 1.2 - Explosive substanqes that

      *.Solids and .semisolids that readily give off flammable vapors.); 3 (Serious            have a fire hazard and either a minor blast hazard or a minor projection
    *,,*Hazard- Uqulcfs ~nd *solids that can be ignited under almo~t all ambient               hazard or bqth, but do not have a mass explosion hazard. Compressed

;):.temperature, conditions. Materials In this degree produce hazardous Gases: Pressure 2: 514.7 psi absolute at 21.1°c (70°F) [500 psig).

     <*"atmospheres with air under almost all ambient temperatures, or, unaffected             Pyrophorics: No Rating. Oxidizers: Packing Group I Solids: any material by ainclenftemperature, are readily Ignited under almost all conditions,             that, In either concentration tested, exhibits a mean burning time less than including: Liquids having a flash point below 22.s*c [73°F] and having a             the mean burning time of a 3.:2 potassium brornate/cellulose mixture.

boiling point*at od:lbove 38°0 [100°F] and below 37.8°C [100°F] [e.g. OSHA Ligutdsi Any material that spontaneously ignites when mixed with cellulose. Class

• JB and IG]; Materials, that on account of their physical form or In a 1:1 ratio, or which exhibits a mean pressure rise time less than the
• environmental conditions can form explosive mixtures with air* and are pressure rise time of a *1 :1 perchloric acid (50%)/cellulose mixture. Unstable readily dispersed in air [e.g., dusts of combustible solids, mists or droplets of Reactives: Substances that may polymerize, decompose, condense or self-Jl_ammable liqulds];:Materials that-burn extremely rapidly, usually by reason react at ambient temperature and/or pressure and have a moderate

   ,t,fbf,setf-con~ned oxygen [e.g. dry nitrocellulose and many organic                        potential to cause significant heat generation or exploston.); 4 Water

• ,i}li?peroxitl~s]); *.4 * '(Severe i* Hazard-Materials that will rapidly or completely Reactivity:* Materials that react explosively with water without requiring heat

   *;!\'vapo*rtze'at atmospheric pressure and normal !lfllbient temperature or that            or confinement. Organic Peroxides: Materials that are readily capable of
       ** are *readily dispersed in air, and which will burn readily, including:               detonation or explosive decomposition at normal* temperature and Flammable gases; Flammable cryogenic materials; Any liquid or gaseous                pressures. Explosives:. Division 1.1 & 1.2-explosive substances that have a material that is liquid while under pressure and has a flash point below             mass explosion hazard or have a projection hazard. A mass explosion Is 22.s*c [73°F] and a'b6illng point'below 37.S"C [100°F] [e.g. OSHA Class IA;         one that affects almost the entlre toad instantaneously. Compressed Material that Ignite spontaneously when exposed to air at a temperature of           Gases: No Rating. Pyrophorics: Add to the definition of Flammability "4".

54.4°C [130°F) or below [e.g. pyrophoric]). Oxidizers: No "4" rating. Unstable Reactives: Substances that may PHYSICAL HAZARD: polymerize, decompose, condense or self-react at ambient temperature O (Water Reactivity: Materials that do not react with water. Organic and/or pressure and have a high potential

• to cause significant heat Peroxides: Materials that are normally stable, even under fire conditions and generation or explosion will not react with water. Explosives:*' Substances that are Non-Explosive. NATIONAL FIRE PROTECTION ASSOCIATION HAZARD Unstable Compressed Gases: No Rating. Pyrophorics: No Rating. RATINGS:

Oxidizers: No "O'.' rating allowed. Unstable ReactiveS'. Substances that will HEALTH HAZARD: O (material that on exposure under fire conditions would not polymerize, decompose,-condense or self-react.); 1 (Water Reactivity: offer rio hazard beyond that of ordinary combustible materials); 1 (materials Materials that change or decompose upon exposure. to moisture. Organic that on exposure under fire conditions could cause irritation or minor Peroxides: Materials that are normally stable, but can become unstable at residual injury); 2 (materials that on intense or continued exposure under high temperatures and pressures. These materials may react with water, fire conditions could cause temporary Incapacitation or possible residual but will not release energy. Explosives: Divi.slon 1.5 & 1.6 substances that injury); 3 (materials that can on short exposure could cause serious are v~ry insensitive explosives or that do not have a mass explosion hazard. temporary or residual injury); 4 (materials that under very short exposure Compressed Gases: Pressure below OSHA definition. Pyrophorics: No could cause death or major residual injury).

• Rating. Oxidizers: Packaging Group Ill; Solids: any material that in either FLAMMABILITY HAZARD: 0 Materials that will not burn under typical fire concentration tested, exhibits a mean burning time less than or equal to the conditions, including intrinsically noncombustible materials such as mean burning time of a 3:7 potassium bromate/cellulose mixture and the concrete, stone, and sand. 1 Materials that must be preheated before criteria for Packing Group I and II are not met. Liquids: any material that . ignition can occur. Materials in this degree require considerable exhibits a mean pressure rise time less than or equal to the pressure rise preheating, under all ambient temperature conditions, before ignition and time of a 1:1 nitric acid (65%)/cellulose mixture and the criteria for Packing combustion can occur 2 Materials that must be moderately heated or Group I and II are not met. Unstable Reactlves: Substances that may exposed to relatively high ambient temperatures before Ignition can occur.

decompose, condense or self-react, but only under conditions of high Materials in this degree would not under normal conditions form temperature and/or pressure and have little or no potential to cause hazardous atmospheres with air, but under high ambient temperatures or significant heat generation or explosive hazard. Substances that readily under moderate heating could release vapor in sufficient quantities to undergo hazardous polymerization in the absence of inhibitors.); produce hazardous atmospheres with air.

• LITHIUM-7LI HYDROXIDE MONOHYDRATE n---"' ,.,..,.. .,_,.._

3M I Ceradyne, Inc.

                        . a3M company                                                                               LITHIUM-7LI HYDROXIDE MONOHYDRATE DEFINITIONS OF TERMS (Continued)

NATIONAL FIRE PROTECTION ASSOCIATION HAZARD ECOLOGICAL INFORMATION: RATINGS (continued): EC ls the effect concentration in water. BCF = Bioconcentration Factor; FLAMMABILITY HAZARD (continued): 3 Liquids and solids that can be which is used to determine if a substance will concentrate in lifeforms which ignited under almost all ambient tempera1ure'conditions. Materials In this consume contaminated plant or animal matter. TLm = median threshold degree produce hazardous atmospheres with air under almost all ambient limit; Coefficient of OIi/Water Distribution is represented by log K0w or log temperatur.es or, tl:iough unaffected by ambient temperatures, are readily Ko. and is used to assess a substance's behavior.in the environment. ignited under almost all conditions. 4 Materials that will rapidly or REGULATORY INFORMATION: completely. vaporize at atmospheric pressure and normal ambient U.S. and CANADA: temperature or that are readily dispersed in air and will burn readily. ACGIH: American Conference of Governmental Industrial Hygienists, a INSTABILITY HAZARD: O Materials that in _themselves are normally professional association which establishes exposure limits. stable, even under fire conditions. 1 Materials that in themselves are This section explains the impact of various laws and regulations on the normally stable, but that can become unstable at elevated temperatures material. EPA ls the U.S. Environmental Protection Agency. NIOSH Is the and pressures. 2 Materials that readily undergo violent chemical change National Institute of Occupational Safety and Health, which is the research at elevated temperatures and pressures. 3 Materials that in themselves arm of the U.S. Occupational Safety and Health Administration (OSHA). are capable of detonation. or explosive decomposition or explosive WHMIS is the Canadian Workplace Hazardous Materials Information reaction, but that require a strong Initiating source or that must be heated System. DOT and TC are the U.S. Department of Transportation and the

    µnder confinement before initiation. 4 Materials that in themselves are               Transport Canada, respectively.              Superfund Amendments and

/ reaqily capable of detonation or explosive decomposition or explosive Reauthorization Act (SARA); the Canadian

• Domestic/Non-Domestic

  ," reaction at normal temperatures and pressures. Substances List (DSlJNDSL); the U.S. Toxic Substance Control Act

FLAMMABILITY LIMITS IN AIR: (TSCA); Marine Pollutant status according to the DOT; the Comprehensive Much of the information related \o fire and explosion is derived from the Envir~nmental Response, Compen~ation, and Liaµility Act (CERCLA or National Fire Protection AssociaHon (NFPA). , Flash Point - Minimum Superfund); and various state regulations. This secHon also includes temperature at which a liquid gives off sufficient vapors to form an ignitable information on the precautionary warnings which appear on the material's mixture with air. Autoignition Temperature: ,:he minimum temperature package label. OSHA - U.S. Occupational Safety and Health required to initiate combustion in air with no other source of ignition. LEL - Administration.

the lowest percent of vapor in air, by volume, that will explode or ignite in the EUROPEAN and INTERNATIONAL: presence of an ignition source* .!Jfil,. - the highest percent of vapor In air, by The DFG: This is the Federal Republic of Germany's Occupation Health volume, that will explode or ignite In the presence of an Ignition source. Agency, similar to the U.S. OSHA. EU is the European Union (formerly TOXICOLOGICAL INFORMATION: . known as the EEC, European Economic Community). EINECS: This ls the Human and Animal Toxicology: Possible health hazards as derived from European Inventory of Now-Existing Chemical Substq0ces. The ARD Is the human data, animal studies, or from the results of studies with similar European Agreement Concerning the International Carriage of Dangerous compounds are presented. DefinlUons of some terms used in this section Goods by Road and the RID are the International Regulations Concerning are: LDso - Lethal Dose (solids & liquids) which kills 50% of the exposed the Carriage of Dangerous Goods by Rall. AICS is the Australian Inventory animals; LCso - Lethal Concentration (gases) whicH kills 50% of the exposed of Chemical Substances. MITI Is the Japanese Minister of International ai:iimals; ppm concentration expressed in parts of material per million parts Trade and Industry of ajr or water; mg/m3 concentration expressed In weight of substance per volume of air; mg/1<1;1 quantity of material, by weight, administered to a test subject, based on their body weight in kg. Other measures of toxicity include

    .TDLo, the lowest dose to cause a symptom and TCLo the lowest conc!:)ntration to cause a symptom; TDo, LDLo,. and LDo, or TC, TCo, LCLo, and LCo, the lowest dose (or concentration) to cause lethal or toxic t:iffects. Cancer Information:

• The sources are: IARC - the International Agency for Research on Cancer; NTP - the National Toxicology Program, RTECS - the Registry of Toxic Effects.of Chemical Substances, OSHA and CAUOSHA. IARC and NTP rate chemicals on a scale of decreasing potential to cause human cancer with rankings from* 1 to 4. Subrankings (2A, 28, eto.) are also used. Other Information: ~El - ACGIH Biological Exposure Indices, represent the levels of determinants which are most likely to be observed In specimens collected from a healthy worker who has been exposed to chemicals to the same extent as a worker with inhalation exposure to the TLV.

LITHIUM-7LI HYDROXIDE MONOHYDRATE Paae10OF10 November 5, 2013

Version: 1.0 Effective Date: Feb-04-2015 SAFETY DATA SHEET OPTISPERSE* PWR6600

1. Identification Product identifier OPTISPERSE PWR6600 Other means of identification None.

Recommended use Internal boiler water treatment Recommended restrictions None known. Company/undertaking identification GE Betz, Inc. 4636 Somerton Road Trevose, PA 19053 T 215 355 3300, F 215 953 5524 Emergency telephone (800) 877 1940

2. Hazard(s) identification Physical hazards Not classified.

Health hazards Not classified. OSHA defined hazards Not classified. Label elements Hazard symbol None. Signal word None. Hazard statement The mixture does not meet the criteria for classification. Precautionary statement Prevention Observe good industrial hygiene practices. Response Wash hands after handling. Storage Store away from incompatible materials. Disposal Dispose of waste and residues in accordance with local authority requirements. Hazard(s) not otherwise classified None known. (HNOC) Supplemental information None.

3. Composition/information on ingredients Mixtures This material is not considered to be hazardous according to regulatory guidelines (see Section 15 of the SDS).

Composition comments This product does not contain hazardous ingredients in reportable concentrations. Information for specific product ingredients as required by the U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to additional sections of this SDS for our assessment of the potential hazards of this formulation.

4. First-aid measures Inhalation Move to fresh air. Call a physician if symptoms develop or persist.

Skin contact Wash off with soap and water. Page: 1 / 7

Eye contact Immediately flush eye(s) with plenty of water. Get medical attention if irritation develops and persists. Ingestion Get medical attention if symptoms occur. Most important Direct contact with eyes may cause temporary irritation. symptoms/effects, acute and delayed Indication of immediate medical Treat symptomatically. attention and special treatment needed General information Ensure that medical personnel are aware of the material(s) involved, and take precautions to protect themselves.

5. Fire-fighting measures Suitable extinguishing media Water fog. Foam. Dry chemical powder. Carbon dioxide (CO2).

Unsuitable extinguishing media Do not use water jet as an extinguisher, as this will spread the fire. Specific hazards arising from the During fire, gases hazardous to health may be formed. chemical Special protective equipment and Self-contained breathing apparatus and full protective clothing must be worn in case of fire. precautions for firefighters Fire fighting Move containers from fire area if you can do so without risk. equipment/instructions Specific methods Use standard firefighting procedures and consider the hazards of other involved materials. General fire hazards No unusual fire or explosion hazards noted.

6. Accidental release measures Personal precautions, protective Keep unnecessary personnel away. For personal protection, see section 8 of the SDS.

equipment and emergency procedures Methods and materials for Large Spills: Stop the flow of material, if this is without risk. Dike the spilled material, where this is containment and cleaning up possible. Cover with plastic sheet to prevent spreading. Absorb in vermiculite, dry sand or earth and place into containers. Following product recovery, flush area with water. Small Spills: Wipe up with absorbent material (e.g. cloth, fleece). Clean surface thoroughly to remove residual contamination. Never return spills to original containers for re-use. For waste disposal, see section 13 of the SDS. Environmental precautions Avoid discharge into drains, water courses or onto the ground.

7. Handling and storage Precautions for safe handling Observe good industrial hygiene practices.

Conditions for safe storage, Protect from freezing. If frozen, thaw completely and mix thoroughly prior to use. Store in original tightly including any incompatibilities closed container. Store away from incompatible materials (see Section 10 of the SDS).

8. Exposure controls/personal protection Occupational exposure limits No exposure limits noted for ingredient(s).

Biological limit values No biological exposure limits noted for the ingredient(s). Appropriate engineering controls Good general ventilation (typically 10 air changes per hour) should be used. Ventilation rates should be matched to conditions. If applicable, use process enclosures, local exhaust ventilation, or other engineering controls to maintain airborne levels below recommended exposure limits. If exposure limits have not been established, maintain airborne levels to an acceptable level. Individual protection measures, such as personal protective equipment Eye/face protection Splash proof chemical goggles. Skin protection Hand protection Wear appropriate chemical resistant gloves. The choice of an appropriate glove does not only depend on its material but also on other quality features and is different from one producer to the other. Glove selection must take into account any solvents and other hazards present. Other Wear suitable protective clothing. Respiratory protection In case of insufficient ventilation, wear suitable respiratory equipment. A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE. Material name: OPTISPERSE* PWR6600 Page: 2 / 7 Version number: 1.0

Thermal hazards Wear appropriate thermal protective clothing, when necessary. General hygiene considerations Always observe good personal hygiene measures, such as washing after handling the material and before eating, drinking, and/or smoking. Routinely wash work clothing and protective equipment to remove contaminants.

9. Physical and chemical properties Appearance Color Colorless to light yellow Physical state Liquid Odor Slight Odor threshold Not available.

pH (concentrated product) 8.5 pH in aqueous solution 8.5 (5% SOL.) Melting point/freezing point 30 °F (-1 °C) Initial boiling point and boiling 220 °F (104 °C) range Flash point > 212 °F (> 100 °C) P-M(CC) Evaporation rate < 1 (Ether = 1) Flammability (solid, gas) Not available. Upper/lower flammability or explosive limits Flammability limit - lower (%) Not available. Flammability limit - upper Not available. (%) Explosive limit - lower (%) Not available. Explosive limit - upper (%) Not available. Vapor pressure 18 mm Hg Vapor pressure temp. 70 °F (21 °C) Vapor density < 1 (Air = 1) Relative density 1.06 Relative density temperature 70 °F (21 °C) Solubility(ies) Solubility (water) 100 % Partition coefficient Not available. (n-octanol/water) Auto-ignition temperature Not available. Decomposition temperature Not available. Viscosity 133 cps Viscosity temperature 70 °F (21 °C) Other information Percent volatile 15 (Calculated) Pour point 35 °F (2 °C) Specific gravity 1.06 VOC (Weight %) 0.26 % Switzerland estimated

10. Stability and reactivity Reactivity The product is stable and non-reactive under normal conditions of use, storage and transport.

Chemical stability Material is stable under normal conditions. Possibility of hazardous reactions Hazardous polymerization does not occur. Conditions to avoid Protect from freezing. Incompatible materials Strong oxidizing agents. Hazardous decomposition Ammonia, oxides of carbon and nitrogen evolved in fire. products Material name: OPTISPERSE* PWR6600 Page: 3 / 7 Version number: 1.0

11. Toxicological information Information on likely routes of exposure Inhalation May cause irritation to respiratory organs.

Skin contact Prolonged or repeated contact may cause irritation. Eye contact Direct contact with eyes may cause temporary irritation. Ingestion Expected to be a low ingestion hazard. Symptoms related to the physical, Direct contact with eyes may cause temporary irritation. chemical and toxicological characteristics Information on toxicological effects Acute toxicity Product Species Test Results OPTISPERSE PWR6600 (CAS Mixture) Acute Dermal LD50 Rabbit > 5000 mg/kg, (Calculated according to GHS additivity formula) Inhalation LC50 Rat > 20 mg/l, 4 Hours, (Calculated according to GHS additivity formula) Oral LD50 Rat > 5000 mg/kg, (Calculated according to GHS additivity formula)

• Estimates for product may be based on additional component data not shown.

Skin corrosion/irritation Prolonged skin contact may cause temporary irritation. Serious eye damage/eye irritation Direct contact with eyes may cause temporary irritation. Respiratory or skin sensitization Respiratory sensitization Not available. Skin sensitization This product is not expected to cause skin sensitization. Germ cell mutagenicity No data available to indicate product or any components present at greater than 0.1% are mutagenic or genotoxic. Carcinogenicity This product is not considered to be a carcinogen by IARC, ACGIH, NTP, or OSHA. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050) Not listed. Reproductive toxicity This product is not expected to cause reproductive or developmental effects. Specific target organ toxicity - Not classified. single exposure Specific target organ toxicity - Not classified. repeated exposure Aspiration hazard Based on available data, the classification criteria are not met. May be harmful if swallowed and enters airways.

12. Ecological information Ecotoxicity The product is not classified as environmentally hazardous. However, this does not exclude the possibility that large or frequent spills can have a harmful or damaging effect on the environment.

Product Species Test Results OPTISPERSE PWR6600 (CAS Mixture) 0% Mortality Fathead Minnow 2000 mg/L, Static Bioassay with 48-Hour Renewal, 96 hour LC50 Mysid Shrimp 2640 mg/L, Static Renewal Bioassay, 96 hour Material name: OPTISPERSE* PWR6600 Page: 4 / 7 Version number: 1.0

Product Species Test Results NOEL Mysid Shrimp 1000 mg/L, Static Renewal Bioassay, 96 hour Sheepshead Minnow 8000 mg/L, Static Renewal Bioassay, 96 hour Aquatic Crustacea LC50 Daphnia magna 1250 mg/L, Static Renewal Bioassay, 48 hour NOEL Daphnia magna 687 mg/L, Static Renewal Bioassay, 48 hour

• Estimates for product may be based on additional component data not shown.

Bioaccumulative potential No data available. Mobility in soil No data available. Other adverse effects No other adverse environmental effects (e.g. ozone depletion, photochemical ozone creation potential, endocrine disruption, global warming potential) are expected from this component. Environmental fate The product is not classified as environmentally hazardous. However, this does not exclude the possibility that large or frequent spills can have a harmful or damaging effect on the environment. Persistence and degradability No data available

13. Disposal considerations Disposal instructions Collect and reclaim or dispose in sealed containers at licensed waste disposal site.

Local disposal regulations Dispose in accordance with all applicable regulations. Hazardous waste code The waste code should be assigned in discussion between the user, the producer and the waste disposal company. Waste from residues / unused Empty containers or liners may retain some product residues. This material and its container must be products disposed of in a safe manner (see: Disposal instructions). Contaminated packaging Empty containers should be taken to an approved waste handling site for recycling or disposal. Since emptied containers may retain product residue, follow label warnings even after container is emptied.

14. Transport information DOT Not regulated as dangerous goods.

Some containers may be DOT exempt, please check BOL for exact container classification. IATA Not regulated as dangerous goods. IMDG Not regulated as dangerous goods.

15. Regulatory information US federal regulations This product is not known to be a "Hazardous Chemical" as defined by the OSHA Hazard Communication Standard, 29 CFR 1910.1200. All components of this product are included on or are in compliance with the U.S. TSCA regulations.

TSCA Section 12(b) Export Notification (40 CFR 707, Subpt. D) Not regulated. CERCLA Hazardous Substance List (40 CFR 302.4) Not listed. SARA 304 Emergency release notification Not regulated. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050) Not listed. Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazard categories Immediate Hazard - No Delayed Hazard - No Fire Hazard - No Pressure Hazard - No Reactivity Hazard - No Material name: OPTISPERSE* PWR6600 Page: 5 / 7 Version number: 1.0

SARA 302 Extremely hazardous substance Not listed. SARA 311/312 Hazardous No chemical SARA 313 (TRI reporting) Not regulated. Other federal regulations Clean Air Act (CAA) Section 112 Hazardous Air Pollutants (HAPs) List Not regulated. Clean Air Act (CAA) Section 112(r) Accidental Release Prevention (40 CFR 68.130) Not regulated. Safe Drinking Water Act Not regulated. (SDWA) Inventory status Country(s) or region Inventory name On inventory (yes/no)* United States & Puerto Rico Toxic Substances Control Act (TSCA) Inventory Yes

    *A "Yes" indicates that all components of this product comply with the inventory requirements administered by the governing country(s)

A "No" indicates that one or more components of the product are not listed or exempt from listing on the inventory administered by the governing country(s). US state regulations US - Massachusetts RTK - Substance List Not regulated. US - Pennsylvania RTK - Hazardous Substances Not regulated. US - Rhode Island RTK Not regulated. US. California Controlled Substances. CA Department of Justice (California Health and Safety Code Section 11100) Not listed. US. New Jersey Worker and Community Right-to-Know Act Not listed. US. Pennsylvania Worker and Community Right-to-Know Law Not listed. US. California Proposition 65 WARNING: This product contains a chemical known to the State of California to cause cancer. US - California Proposition 65 - CRT: Listed date/Carcinogenic substance Diethanolamine (CAS 111-42-2) Listed: June 22, 2012 US - California Proposition 65 - CRT: Listed date/Developmental toxin No ingredient listed. US - California Proposition 65 - CRT: Listed date/Female reproductive toxin No ingredient listed. US - California Proposition 65 - CRT: Listed date/Male reproductive toxin No ingredient listed.

16. Other information, including date of preparation or last revision Issue date Feb-04-2015 Revision date Feb-04-2015 Version # 1.0 Material name: OPTISPERSE* PWR6600 Page: 6 / 7 Version number: 1.0

List of abbreviations CAS: Chemical Abstract Service Registration Number TWA: Time Weighted Average STEL: Short Term Exposure Limit TLV: Threshold Limit Value LD50: Lethal Dose, 50% LC50: Lethal Concentration, 50% NOEL: No Observed Effect Level COD: Chemical Oxygen Demand BOD: Biochemical Oxygen Demand TOC: Total Organic Carbon IATA: International Air Transport Association IMDG: International Maritime Dangerous Goods Code TSRN indicates a Trade Secret Registry Number is used in place of the CAS number. ACGIH: American Conference of Governmental Industrial Hygienists NFPA: National Fire Protection Association

References:

No data available Disclaimer The information in the sheet was written based on the best knowledge and experience currently available. The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. Revision Information Product and Company Identification: Product and Company Identification Composition / Information on Ingredients: Ingredients Physical & Chemical Properties: Multiple Properties Toxicological Information: Toxicological Data Transport Information: Material Transportation Information Regulatory Information: Risk Phrases - Labeling HazReg Data: Europe - EU GHS: Classification Prepared by This SDS has been prepared by GE Water & Process Technologies Regulatory Department (1-215-355-3300).

• Trademark of General Electric Company. May be registered in one or more countries.

Material name: OPTISPERSE* PWR6600 Page: 7 / 7 Version number: 1.0

SAFETY DATA SHEET Creation Date 03-Sep-2009 Revision Date 24-Jul-2015 Revision Number 6 SECTION 1: IDENTIFICATION OF THE SUBSTANCE/MIXTURE AND OF THE COMPANY/UNDERTAKING 1.1. Product identification Product

Description:

Potassium hydroxide Cat No. : P/5560/60 CAS-No 1310-58-3 EC-No. 215-181-3 Molecular Formula HKO Reach Registration Number 01-2119487136-33 1.2. Relevant identified uses of the substance or mixture and uses advised against Recommended Use Laboratory chemicals. Uses advised against No Information available 1.3. Details of the supplier of the safety data sheet Company Fisher Scientific UK Bishop Meadow Road, Loughborough, Leicestershire LE11 5RG, United Kingdom E-mail address begel.sdsdesk@thermofisher.com 1.4. Emergency telephone number Tel: 01509 231166 Chemtrec US: (800) 424-9300 Chemtrec EU: 001 (202) 483-7616 SECTION 2: HAZARDS IDENTIFICATION 2.1. Classification of the substance or mixture CLP Classification - Regulation (EC) No 1272/2008 Physical hazards Substances/mixtures corrosive to metal Category 1 Health hazards Acute oral toxicity Category 4 Skin Corrosion/irritation Category 1 A Serious Eye Damage/Eye Irritation Category 1 Environmental hazards Based on available data, the classification criteria are not met 2.2. Label elements FSUP5560 Page 1 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 Signal Word Danger Hazard Statements H290 - May be corrosive to metals H302 - Harmful if swallowed H314 - Causes severe skin burns and eye damage Precautionary Statements P280 - Wear protective gloves/ protective clothing/ eye protection/ face protection P305 + P351 + P338 - IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing P310 - Immediately call a POISON CENTER or doctor/ physician P301 + P330 + P331 - IF SWALLOWED: Rinse mouth. Do NOT induce vomiting P303 + P361 + P353 - IF ON SKIN (or hair): Remove/ Take off immediately all contaminated clothing. Rinse skin with water/ shower 2.3. Other hazards No information available SECTION 3: COMPOSITION/INFORMATION ON INGREDIENTS 3.1. Substances Component CAS-No EC-No. Weight % CLP Classification - Regulation (EC) No 1272/2008 Potassium hydroxide 1310-58-3 215-181-3 85-100 Acute Tox. 4 (H302) Skin Corr. 1A (H314) Eye Dam. 1 (H318) Met. Corr. 1 (H290) Reach Registration Number 01-2119487136-33 Full text of Hazard Statements: see section 16 SECTION 4: FIRST AID MEASURES 4.1. Description of first aid measures General Advice Immediate medical attention is required. Show this safety data sheet to the doctor in attendance. Eye Contact Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Immediate medical attention is required. Keep eye wide open while rinsing. Skin Contact Wash off immediately with soap and plenty of water while removing all contaminated clothes and shoes. Call a physician immediately. Ingestion Do not induce vomiting. Immediate medical attention is required. Never give anything by mouth to an unconscious person. Drink plenty of water. Inhalation Move to fresh air. If breathing is difficult, give oxygen. Do not use mouth-to-mouth resuscitation if victim ingested or inhaled the substance; induce artificial respiration with a FSUP5560 Page 2 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 respiratory medical device. Call a physician or Poison Control Center immediately. Protection of First-aiders Ensure that medical personnel are aware of the material(s) involved, take precautions to protect themselves and prevent spread of contamination. 4.2. Most important symptoms and effects, both acute and delayed Causes burns by all exposure routes. . Product is a corrosive material. Use of gastric lavage or emesis is contraindicated. Possible perforation of stomach or esophagus should be investigated: Ingestion causes severe swelling, severe damage to the delicate tissue and danger of perforation 4.3. Indication of any immediate medical attention and special treatment needed Notes to Physician Treat symptomatically. SECTION 5: FIREFIGHTING MEASURES 5.1. Extinguishing media Suitable Extinguishing Media CO 2, dry chemical, dry sand, alcohol-resistant foam. Extinguishing media which must not be used for safety reasons Water. 5.2. Special hazards arising from the substance or mixture The product causes burns of eyes, skin and mucous membranes. Hazardous Combustion Products Hydrogen, Potassium oxides, Thermal decomposition can lead to release of irritating gases and vapors. 5.3. Advice for firefighters As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear. Thermal decomposition can lead to release of irritating gases and vapors. SECTION 6: ACCIDENTAL RELEASE MEASURES 6.1. Personal precautions, protective equipment and emergency procedures Use personal protective equipment. Evacuate personnel to safe areas. Avoid contact with skin, eyes and clothing. 6.2. Environmental precautions Do not allow material to contaminate ground water system. Should not be released into the environment. Do not flush into surface water or sanitary sewer system. See Section 12 for additional ecological information. 6.3. Methods and material for containment and cleaning up Sweep up or vacuum up spillage and collect in suitable container for disposal. Avoid dust formation. 6.4. Reference to other sections Refer to protective measures listed in Sections 8 and 13. SECTION 7: HANDLING AND STORAGE 7.1. Precautions for safe handling FSUP5560 Page 3 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 Use only under a chemical fume hood. Wear personal protective equipment. Do not get in eyes, on skin, or on clothing. Do not breathe dust. Do not ingest. 7.2. Conditions for safe storage, including any incompatibilities Keep containers tightly closed in a dry, cool and well-ventilated place. Corrosives area. Store under an inert atmosphere. 7.3. Specific end use(s) Use in laboratories SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION 8.1. Control parameters Exposure limits List source(s): UK - EH40/2005 Containing the workplace exposure limits (WELs) for use with the Control of Substances Hazardous to Health Regulations (COSHH) 2002 (as amended). Updated by September 2006 official press release and October 2007 Supplement. IRE - 2010 Code of Practice for the Safety, Health and Welfare at Work (Chemical Agents) Regulations 2001. Published by the Health and Safety Authority. Component European Union The United Kingdom France Belgium Spain Potassium hydroxide WEL - 2 mg/m3 STEL STEL / VLCT: 2 mg/m3. STEL: 2mg/m3 VLE STEL / VLA-EC: 2 mg/m3 (15 minutos). Component Italy Germany Portugal The Netherlands Finland Potassium hydroxide Ceiling: 2 mg/m3 MAC-C: 2 mg/m3 STEL: 2 mg/m3 15 minuutteina Ceiling: 2 mg/m3 Component Austria Denmark Switzerland Poland Norway Potassium hydroxide MAK-TMW: 2 mg/m3 8 Ceiling: 2 mg/m3 TWA: 2 mg/m3 8 STEL: 1 mg/m3 15 Ceiling: 2 mg/m3 Stunden Stunden minutach TWA: 0.5 mg/m3 8 godzinach Component Bulgaria Croatia Ireland Cyprus Czech Republic Potassium hydroxide TWA: 2.0 mg/m3 STEL-KGVI: 2 mg/m3 15 STEL: 2 mg/m3 15 min TWA: 1 mg/m3 8 minutama. hodinách. Ceiling: 2 mg/m3 Component Estonia Gibraltar Greece Hungary Iceland Potassium hydroxide TWA: 2 mg/m3 8 STEL: 2 mg/m3 STEL: 2 mg/m3 15 STEL: 2 mg/m3 tundides. TWA: 2 mg/m3 percekben. CK TWA: 2 mg/m3 8

                                                                                               órában. AK Component              Russia             Slovak Republic            Slovenia               Sweden                  Turkey Potassium hydroxide                                                                      LLV: 1 mg/m3 8 timmar.

inhalable dust CLV: 2 mg/m3 Biological limit values This product, as supplied, does not contain any hazardous materials with biological limits established by the region specific regulatory bodies. Monitoring methods BS EN 14042:2003 Title Identifier: Workplace atmospheres. Guide for the application and use of procedures for the assessment of exposure to chemical and biological agents. MDHS14/3 General methods for sampling and gravimetric analysis of respirable and inhalable dust FSUP5560 Page 4 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 Derived No Effect Level (DNEL) See table for values Route of exposure Acute effects (local) Acute effects Chronic effects Chronic effects (systemic) (local) (systemic) Oral Dermal Inhalation 1 mg/m3 Predicted No Effect Concentration Not applicable. (PNEC) 8.2. Exposure controls Engineering Measures Use only under a chemical fume hood. Ensure that eyewash stations and safety showers are close to the workstation location. Wherever possible, engineering control measures such as the isolation or enclosure of the process, the introduction of process or equipment changes to minimise release or contact, and the use of properly designed ventilation systems, should be adopted to control hazardous materials at source Personal protective equipment Eye Protection Goggles (European standard - EN 166) Hand Protection Protective gloves Glove material Breakthrough time Glove thickness EU standard Glove comments Natural rubber See manufacturers - EN 374 (minimum requirement) Nitrile rubber recommendations Neoprene PVC Skin and body protection Long sleeved clothing Inspect gloves before use. Please observe the instructions regarding permeability and breakthrough time which are provided by the supplier of the gloves. (Refer to manufacturer/supplier for information) Ensure gloves are suitable for the task: Chemical compatability, Dexterity, Operational conditions, User susceptibility, e.g. sensitisation effects, also take into consideration the specific local conditions under which the product is used, such as the danger of cuts, abrasion. Remove gloves with care avoiding skin contamination. Respiratory Protection When workers are facing concentrations above the exposure limit they must use appropriate certified respirators. To protect the wearer, respiratory protective equipment must be the correct fit and be used and maintained properly Large scale/emergency use Use a NIOSH/MSHA or European Standard EN 136 approved respirator if exposure limits are exceeded or if irritation or other symptoms are experienced Recommended Filter type: Particulates filter conforming to EN 143 Small scale/Laboratory use Use a NIOSH/MSHA or European Standard EN 149:2001 approved respirator if exposure limits are exceeded or if irritation or other symptoms are experienced. Recommended half mask:- Particle filtering: EN149:2001 When RPE is used a face piece Fit Test should be conducted Hygiene Measures Handle in accordance with good industrial hygiene and safety practice. Environmental exposure controls Prevent product from entering drains. SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES 9.1. Information on basic physical and chemical properties Appearance White Physical State Solid Odor Odorless Odor Threshold No data available FSUP5560 Page 5 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 pH 13.5 0.1M aq.solution Melting Point/Range 360 °C / 680 °F Softening Point No data available Boiling Point/Range 1320 °C / 2408 °F Flash Point No information available Method - No information available Evaporation Rate Not applicable Solid Flammability (solid,gas) No information available Explosion Limits No data available Vapor Pressure No data available Vapor Density Not applicable Solid Specific Gravity / Density No data available Bulk Density No data available Water Solubility 1120 g/L (20°C) Solubility in other solvents No information available Partition Coefficient (n-octanol/water) Component log Pow Potassium hydroxide 0.83 Autoignition Temperature Decomposition Temperature No data available Viscosity Not applicable Solid Explosive Properties No information available Oxidizing Properties No information available 9.2. Other information Molecular Formula HKO Molecular Weight 56.11 SECTION 10: STABILITY AND REACTIVITY 10.1. Reactivity Yes 10.2. Chemical stability Hygroscopic. Air sensitive 10.3. Possibility of hazardous reactions Hazardous Polymerization Hazardous polymerization does not occur. Hazardous Reactions None under normal processing. 10.4. Conditions to avoid Incompatible products. Excess heat. Exposure to air. Exposure to moist air or water. 10.5. Incompatible materials Strong oxidizing agents. Acids. Acid chlorides. Acid anhydrides. Ketones. Peroxides. Water. Metals. 10.6. Hazardous decomposition products Hydrogen. Potassium oxides. Thermal decomposition can lead to release of irritating gases and vapors. SECTION 11: TOXICOLOGICAL INFORMATION 11.1. Information on toxicological effects Product Information (a) acute toxicity; Oral Category 4 Dermal No data available FSUP5560 Page 6 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 Inhalation No data available Component LD50 Oral LD50 Dermal LC50 Inhalation Potassium hydroxide 333 mg/kg ( Rat ) (b) skin corrosion/irritation; Category 1 A (c) serious eye damage/irritation; Category 1 (d) respiratory or skin sensitization; Respiratory No data available Skin No data available (e) germ cell mutagenicity; No data available (f) carcinogenicity; No data available There are no known carcinogenic chemicals in this product (g) reproductive toxicity; No data available (h) STOT-single exposure; No data available (i) STOT-repeated exposure; No data available Target Organs Skin, Respiratory system, Eyes, Gastrointestinal tract (GI). (j) aspiration hazard; Not applicable Solid Other Adverse Effects See actual entry in RTECS for complete information Symptoms / effects,both acute and Product is a corrosive material. Use of gastric lavage or emesis is contraindicated. delayed Possible perforation of stomach or esophagus should be investigated: Ingestion causes severe swelling, severe damage to the delicate tissue and danger of perforation SECTION 12: ECOLOGICAL INFORMATION 12.1. Toxicity Ecotoxicity effects Do not empty into drains. Contains a substance which is:. Harmful to aquatic organisms. The product contains following substances which are hazardous for the environment. Component Freshwater Fish Water Flea Freshwater Algae Microtox Potassium hydroxide 80 mg/L LC50 96 h 12.2. Persistence and degradability Persistence Soluble in water, Persistence is unlikely, based on information available. Degradability Not relevant for inorganic substances. Degradation in sewage Contains substances known to be hazardous to the environment or not degradable in waste treatment plant water treatment plants. 12.3. Bioaccumulative potential Bioaccumulation is unlikely Component log Pow Bioconcentration factor (BCF) Potassium hydroxide 0.83 No data available 12.4. Mobility in soil The product is water soluble, and may spread in water systems Will likely be mobile in the environment due to its water solubility. Highly mobile in soils 12.5. Results of PBT and vPvB No data available for assessment. assessment FSUP5560 Page 7 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 12.6. Other adverse effects Endocrine Disruptor Information This product does not contain any known or suspected endocrine disruptors Persistent Organic Pollutant This product does not contain any known or suspected substance Ozone Depletion Potential This product does not contain any known or suspected substance SECTION 13: DISPOSAL CONSIDERATIONS 13.1. Waste treatment methods Waste from Residues / Unused Waste is classified as hazardous. Dispose of in accordance with the European Directives Products on waste and hazardous waste. Dispose of in accordance with local regulations. Contaminated Packaging Dispose of this container to hazardous or special waste collection point. European Waste Catalogue (EWC) According to the European Waste Catalogue, Waste Codes are not product specific, but application specific. Other Information Waste codes should be assigned by the user based on the application for which the product was used. Do not empty into drains. Do not dispose of waste into sewer. Large amounts will affect pH and harm aquatic organisms. Solutions with high pH-value must be neutralized before discharge. SECTION 14: TRANSPORT INFORMATION IMDG/IMO 14.1. UN number UN1813 14.2. UN proper shipping name Potassium hydroxide, solid 14.3. Transport hazard class(es) 8 14.4. Packing group II ADR 14.1. UN number UN1813 14.2. UN proper shipping name Potassium hydroxide, solid 14.3. Transport hazard class(es) 8 14.4. Packing group II IATA 14.1. UN number UN1813 14.2. UN proper shipping name Potassium hydroxide, solid 14.3. Transport hazard class(es) 8 14.4. Packing group II 14.5. Environmental hazards No hazards identified 14.6. Special precautions for user No special precautions required 14.7. Transport in bulk according to Not applicable, packaged goods Annex II of MARPOL73/78 and the IBC Code SECTION 15: REGULATORY INFORMATION 15.1. Safety, health and environmental regulations/legislation specific for the substance or mixture International Inventories X = listed Component EINECS ELINCS NLP TSCA DSL NDSL PICCS ENCS IECSC AICS KECL Potassium hydroxide 215-181-3 - X X - X X X X X FSUP5560 Page 8 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 National Regulations Component Germany - Water Classification (VwVwS) Germany - TA-Luft Class Potassium hydroxide WGK 1 Take note of Control of Substances Hazardous to Health Regulations (COSHH) 2002 and 2005 Amendment. Take note of Dir 94/33/EC on the protection of young people at work Take note of Directive 98/24/EC on the protection of the health and safety of workers from the risks related to chemical agents at work 15.2. Chemical safety assessment A Chemical Safety Assessment/Report (CSA/CSR) has not been conducted SECTION 16: OTHER INFORMATION Full Text of H-/EUH-Statements Referred to Under Section 3 H290 - May be corrosive to metals H302 - Harmful if swallowed H314 - Causes severe skin burns and eye damage H318 - Causes serious eye damage Legend CAS - Chemical Abstracts Service TSCA - United States Toxic Substances Control Act Section 8(b) Inventory EINECS/ELINCS - European Inventory of Existing Commercial Chemical DSL/NDSL - Canadian Domestic Substances List/Non-Domestic Substances/EU List of Notified Chemical Substances Substances List PICCS - Philippines Inventory of Chemicals and Chemical Substances ENCS - Japanese Existing and New Chemical Substances IECSC - Chinese Inventory of Existing Chemical Substances AICS - Australian Inventory of Chemical Substances KECL - Korean Existing and Evaluated Chemical Substances NZIoC - New Zealand Inventory of Chemicals WEL - Workplace Exposure Limit TWA - Time Weighted Average ACGIH - American Conference of Governmental Industrial Hygienists IARC - International Agency for Research on Cancer DNEL - Derived No Effect Level PNEC - Predicted No Effect Concentration RPE - Respiratory Protective Equipment LD50 - Lethal Dose 50% LC50 - Lethal Concentration 50% EC50 - Effective Concentration 50% NOEC - No Observed Effect Concentration POW - Partition coefficient Octanol:Water PBT - Persistent, Bioaccumulative, Toxic vPvB - very Persistent, very Bioaccumulative ADR - European Agreement Concerning the International Carriage of ICAO/IATA - International Civil Aviation Organization/International Air Dangerous Goods by Road Transport Association IMO/IMDG - International Maritime Organization/International Maritime MARPOL - International Convention for the Prevention of Pollution from Dangerous Goods Code Ships OECD - Organisation for Economic Co-operation and Development ATE - Acute Toxicity Estimate BCF - Bioconcentration factor VOC - Volatile Organic Compounds Key literature references and sources for data Suppliers safety data sheet, Chemadvisor - LOLI, Merck index, RTECS Training Advice Chemical hazard awareness training, incorporating labelling, Safety Data Sheets (SDS), Personal Protective Equipment (PPE) and hygiene. Use of personal protective equipment, covering appropriate selection, compatibility, breakthrough thresholds, care, maintenance, fit and standards. First aid for chemical exposure, including the use of eye wash and safety showers. Creation Date 03-Sep-2009 Revision Date 24-Jul-2015 Revision Summary SDS sections updated, 2, 3. This safety data sheet complies with the requirements of Regulation (EC) No. 1907/2006 Disclaimer The information provided on this Safety Data Sheet is correct to the best of our knowledge, information and belief at the FSUP5560 Page 9 / 10

SAFETY DATA SHEET Potassium hydroxide Revision Date 24-Jul-2015 date of its publication. The information given is designed only as a guide for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered as a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other material or in any process, unless specified in the text. End of Safety Data Sheet FSUP5560 Page 10 / 10

SAFETY DATA SHEET PURATE Section: 1. PRODUCT AND COMPANY IDENTIFICATION Product name  : PURATE Other means of identification : Not applicable. Recommended use  : BIOCIDE PRECURSOR Restrictions on use  : Refer to available product literature or ask your local Sales Representative for restrictions on use and dose limits. Company  : Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 USA TEL: (630) 305-1000 Emergency telephone  : (800) 424-9300 (24 Hours) CHEMTREC number Issuing date  : 06/29/2020 Section: 2. HAZARDS IDENTIFICATION GHS Classification Oxidizing liquids  : Category 1 Acute toxicity (Inhalation)  : Category 4 Acute toxicity (Dermal)  : Category 4 Serious eye damage  : Category 1 GHS Label element Hazard pictograms  : Signal Word  : Danger Hazard Statements  : May cause fire or explosion; strong oxidiser. Harmful in contact with skin or if inhaled. Causes serious eye damage. Precautionary Statements  : Prevention: Keep away from heat. Keep/Store away from clothing and other combustible materials. Take any precaution to avoid mixing with combustibles. Avoid breathing dust/ fume/ gas/ mist/ vapours/ spray. Wear protective gloves/ eye protection/ face protection. Wear fire/ flame resistant/ retardant clothing.

Response

IF ON SKIN: Wash with plenty of soap and water. Call a POISON CENTER or doctor/ physician if you feel unwell. IF INHALED: Remove person to fresh air and keep comfortable for breathing. Call a POISON CENTER or doctor/ physician if you feel unwell.IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if 1 / 10

SAFETY DATA SHEET PURATE present and easy to do. Continue rinsing. Immediately call a POISON CENTER or doctor/ physician.IF ON CLOTHING: rinse immediately contaminated clothing and skin with plenty of water before removing clothes. Other hazards  : None known. Section: 3. COMPOSITION/INFORMATION ON INGREDIENTS Pure substance/mixture  : Mixture Chemical Name CAS-No. Concentration: (%) Sodium Chlorate 7775-09-9 30 - 60 Hydrogen Peroxide 7722-84-1 5 - 10 Section: 4. FIRST AID MEASURES In case of eye contact  : Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Get medical attention immediately. In case of skin contact  : Wash off immediately with plenty of water for at least 15 minutes. Use a mild soap if available. Wash clothing before reuse. Thoroughly clean shoes before reuse. Get medical attention if irritation develops and persists. If swallowed  : Rinse mouth. Get medical attention if symptoms occur. If inhaled  : Remove to fresh air. Treat symptomatically. Get medical attention. Protection of first-aiders  : In event of emergency assess the danger before taking action. Do not put yourself at risk of injury. If in doubt, contact emergency responders. Use personal protective equipment as required. Notes to physician  : Treat symptomatically. Most important symptoms  : See Section 11 for more detailed information on health effects and symptoms. and effects, both acute and delayed Section: 5. FIREFIGHTING MEASURES Suitable extinguishing media : Use extinguishing measures that are appropriate to local circumstances and the surrounding environment. Unsuitable extinguishing  : None known. media Specific hazards during  : Oxidizer. Contact with other material may cause fire. firefighting Hazardous combustion  : Decomposition products may include the following materials: Carbon oxides products nitrogen oxides (NOx) Sulphur oxides Oxides of phosphorus Special protective equipment : Use personal protective equipment. 2 / 10

SAFETY DATA SHEET PURATE for firefighters Specific extinguishing  : Fire residues and contaminated fire extinguishing water must be disposed of in methods accordance with local regulations. In the event of fire and/or explosion do not breathe fumes. Section: 6. ACCIDENTAL RELEASE MEASURES Personal precautions,  : Ensure adequate ventilation. Keep people away from and upwind of spill/leak. protective equipment and Avoid inhalation, ingestion and contact with skin and eyes. When workers are emergency procedures facing concentrations above the exposure limit they must use appropriate certified respirators. Ensure clean-up is conducted by trained personnel only. Refer to protective measures listed in sections 7 and 8. Environmental precautions  : Do not allow contact with soil, surface or ground water. Methods and materials for  : Stop leak if safe to do so. Contain spillage, and then collect with non-containment and cleaning up combustible absorbent material, (e.g. sand, earth, diatomaceous earth, vermiculite) and place in container for disposal according to local / national regulations (see section 13). For large spills, dike spilled material or otherwise contain material to ensure runoff does not reach a waterway. Flush away traces with water. Section: 7. HANDLING AND STORAGE Advice on safe handling  : Do not breathe dust/fume/gas/mist/vapours/spray. Do not get in eyes, on skin, or on clothing. Wash hands thoroughly after handling. Use only with adequate ventilation. Conditions for safe storage : Keep in a cool, well-ventilated place. Keep away from reducing agents. Keep away from combustible material. Keep out of reach of children. Keep container tightly closed. Store in suitable labelled containers. Suitable material  : The following compatibility data is suggested based on similar product data and/or industry experience: Compatibility with Plastic Materials can vary; we therefore recommend that compatibility is tested prior to use. Unsuitable material  : not determined Section: 8. EXPOSURE CONTROLS/PERSONAL PROTECTION Components with workplace control parameters Components CAS-No. Form of exposure Permissible Basis concentration Hydrogen Peroxide 7722-84-1 TWA 1 ppm ACGIH TWA 1 ppm NIOSH REL 1.4 mg/m3 TWA 1 ppm OSHA Z1 1.4 mg/m3 Engineering measures  : Effective exhaust ventilation system. Maintain air concentrations below occupational exposure standards. 3 / 10

SAFETY DATA SHEET PURATE Personal protective equipment Eye protection  : Safety goggles Face-shield Hand protection  : Wear the following personal protective equipment: Standard glove type. Gloves should be discarded and replaced if there is any indication of degradation or chemical breakthrough. Skin protection  : Wear suitable protective clothing. Respiratory protection  : When workers are facing concentrations above the exposure limit they must use appropriate certified respirators. Hygiene measures  : Handle in accordance with good industrial hygiene and safety practice. Remove and wash contaminated clothing before re-use. Wash face, hands and any exposed skin thoroughly after handling. Provide suitable facilities for quick drenching or flushing of the eyes and body in case of contact or splash hazard. The Personal Protective Equipment (PPE) recommendations provided above have been made in good faith based on typical expected conditions of use. PPE selection should always be completed in conjunction with a proper risk assessment and in accordance with a PPE management program. Section: 9. PHYSICAL AND CHEMICAL PROPERTIES Appearance  : Liquid Colour  : clear colourless to light blue yellow Odour  : Slight, Pungent Flash point  : does not flash pH  : 2-6 Odour Threshold  : no data available Melting point/freezing point  : no data available Initial boiling point and boiling : 104.0 °C range Evaporation rate  : >1 Flammability (solid, gas)  : The product is not flammable. Upper explosion limit  : no data available Lower explosion limit  : no data available Vapour pressure  : 6.7 kPa, (40 °C), Relative vapour density  : no data available Relative density  : 1.3400 - 1.3900, (25 °C), Density  : 11.4 lb/gal Water solubility  : completely soluble Solubility in other solvents  : no data available 4 / 10

SAFETY DATA SHEET PURATE Partition coefficient: n-  : no data available octanol/water Auto-ignition temperature  : no data available Thermal decomposition  : no data available Viscosity, dynamic  : 1.8 mPa.s (20 °C) Viscosity, kinematic  : no data available Oxidizing properties  : The substance or mixture is classified as oxidizing with the category 2. Molecular weight  : no data available VOC  : 0 %, Calculation method Section: 10. STABILITY AND REACTIVITY Reactivity  : No dangerous reaction known under conditions of normal use. Chemical stability  : Stable under normal conditions. Possibility of hazardous  : No dangerous reaction known under conditions of normal use. reactions Conditions to avoid  : None known. Incompatible materials  : Mineral Acids Organic materials Flammable materials Powdered metals Zinc(Zn) Hazardous decomposition  : Decomposition products may include the following materials: products Carbon oxides nitrogen oxides (NOx) Sulphur oxides Oxides of phosphorus Section: 11. TOXICOLOGICAL INFORMATION Information on likely routes of : Inhalation, Eye contact, Skin contact exposure Potential Health Effects Eyes  : Causes serious eye damage. Skin  : Harmful in contact with skin. Ingestion  : Health injuries are not known or expected under normal use. Inhalation  : Harmful if inhaled. Chronic Exposure  : Health injuries are not known or expected under normal use. 5 / 10

SAFETY DATA SHEET PURATE Experience with human exposure Eye contact  : Redness, Pain, Corrosion Skin contact  : No symptoms known or expected. Ingestion  : No symptoms known or expected. Inhalation  : No symptoms known or expected. Toxicity Product Acute oral toxicity  : Acute toxicity estimate: > 5,000 mg/kg Acute toxicity estimate: 3,555 mg/kg Acute inhalation toxicity : Acute toxicity estimate: > 10 mg/l Exposure time: 4 h Test atmosphere: vapour Acute toxicity estimate: > 40 mg/l Exposure time: 4 h Test atmosphere: vapour Acute dermal toxicity  : Acute toxicity estimate: > 1,000 mg/kg Skin corrosion/irritation : no data available Serious eye damage/eye  : Result: Irreversible effects on the eye irritation Method: Expert judgement Respiratory or skin  : no data available sensitization Carcinogenicity  : no data available Reproductive effects  : No reproductive toxic effects expected. Germ cell mutagenicity  : Contains no ingredient listed as a mutagen Teratogenicity  : no data available STOT - single exposure  : no data available STOT - repeated exposure  : no data available Aspiration toxicity  : Based on available data, the classification criteria are not met. Section: 12. ECOLOGICAL INFORMATION Ecotoxicity Environmental Effects  : Harmful to aquatic life. Components Toxicity to fish  : Sodium Chlorate LC50 Fish: > 1,000 mg/l Exposure time: 96 h Components 6 / 10

SAFETY DATA SHEET PURATE Toxicity to daphnia and other  : Sodium Chlorate aquatic invertebrates EC50 : > 1,000 mg/l Exposure time: 48 h Components Toxicity to algae  : Sodium Chlorate EC50 : > 1,000 mg/l Exposure time: 72 h Hydrogen Peroxide EC50 : 1.38 mg/l Exposure time: 72 h Persistence and degradability Greater than 95% of this product consists of inorganic substances for which a biodegradation value is not applicable. Mobility The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air  : <5% Water  : 30 - 50% Soil  : 50 - 70% The portion in water is expected to be soluble or dispersible. Bioaccumulative potential This preparation or material is not expected to bioaccumulate. Other information no data available Section: 13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261, since it does not have the characteristics of Subpart C, nor is it listed under Subpart D. Disposal methods  : The product should not be allowed to enter drains, water courses or the soil. Where possible recycling is preferred to disposal or incineration. If recycling is not practicable, dispose of in compliance with local regulations. Dispose of wastes in an approved waste disposal facility. Disposal considerations  : Dispose of as unused product. Empty containers should be taken to an approved waste handling site for recycling or disposal. Do not re-use empty containers. 7 / 10

SAFETY DATA SHEET PURATE Section: 14. TRANSPORT INFORMATION The shipper/consignor/sender is responsible to ensure that the packaging, labeling, and markings are in compliance with the selected mode of transport. Land transport (DOT) Proper shipping name  : SODIUM CHLORATE, AQUEOUS SOLUTION Technical name(s)  : UN/ID No.  : UN 2428 Transport hazard class(es)  : 5.1 Packing group  : II Air transport (IATA) Proper shipping name  : SODIUM CHLORATE, AQUEOUS SOLUTION Technical name(s)  : UN/ID No.  : UN 2428 Transport hazard class(es)  : 5.1 Packing group  : II Sea transport (IMDG/IMO) Proper shipping name  : SODIUM CHLORATE, AQUEOUS SOLUTION Technical name(s)  : UN/ID No.  : UN 2428 Transport hazard class(es)  : 5.1 Packing group  : II Section: 15. REGULATORY INFORMATION TSCA list  : No substances are subject to a Significant New Use Rule. No substances are subject to TSCA 12(b) export notification requirements. EPA Reg. No.  : 1706-242 EPCRA - Emergency Planning and Community Right-to-Know Act CERCLA Reportable Quantity This product does not contain a RQ substance, or this product contains a substance with a RQ, however the calculated RQ exceeds the reasonably attainable upper limit. SARA 304 Extremely Hazardous Substances Reportable Quantity This material does not contain any components with a section 304 EHS RQ. SARA 311/312 Hazards  : Oxidiser (liquid, solid or gas) Acute toxicity (any route of exposure) Serious eye damage or eye irritation SARA 302  : The following components are subject to reporting levels established by SARA Title III, Section 302: 8 / 10

SAFETY DATA SHEET PURATE Hydrogen Peroxide 7722-84-1 SARA 313  : This material does not contain any chemical components with known CAS numbers that exceed the threshold (De Minimis) reporting levels established by SARA Title III, Section 313. California Prop. 65 This product does not contain any chemicals known to State of California to cause cancer, birth defects, or any other reproductive harm. INTERNATIONAL CHEMICAL CONTROL LAWS : United States TSCA Inventory This product is exempted under TSCA and regulated under FIFRA. The inerts are on the Inventory List. Canadian Domestic Substances List (DSL) The substance(s) in this preparation are included in or exempted from the Domestic Substance List (DSL). Korea. Korean Existing Chemicals Inventory (KECI) All substances in this product comply with the Chemical Control Act (CCA) and are listed on the Existing Chemicals List (ECL) Japan. ENCS - Existing and New Chemical Substances Inventory All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Existing and New Chemical Substances list (ENCS). Australia. Industrial Chemical (Notification and Assessment) Act All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS). Philippines Inventory of Chemicals and Chemical Substances (PICCS) All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippines Inventory of Chemicals & Chemical Substances (PICCS). China Inventory of Existing Chemical Substances All substances in this product comply with the Provisions on the Environmental Administration of New Chemical Substances and are listed on or exempt from the Inventory of Existing Chemical Substances China (IECSC). New Zealand. Inventory of Chemicals (NZIoC), as published by ERMA New Zealand All substances in this product comply with the Hazardous Substances and New Organisms (HSNO) Act 1996,and are listed on or are exempt from the New Zealand Inventory of Chemicals. Taiwan Chemical Substance Inventory All substances in this product comply with the Taiwan Existing Chemical Substances Inventory (ECSI). Section: 16. OTHER INFORMATION 9 / 10

SAFETY DATA SHEET PURATE NFPA: HMIS III: Flammability HEALTH 3 0 Health Instability 3 3 FLAMMABILITY 0 OX PHYSICAL HAZARD 3 Special hazard. 0 = not significant, 1 = Slight, 2 = Moderate, 3 = High 4 = Extreme, * = Chronic Revision Date  : 06/29/2020 Version Number  : 1.6 Prepared By  : Regulatory Affairs REVISED INFORMATION: Significant changes to regulatory or health information for this revision is indicated by a bar in the left-hand margin of the SDS. The information provided in this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guidance for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other materials or in any process, unless specified in the text. For additional copies of an SDS visit www.nalco.com and request access. 10 / 10

Version: 2.1 Revision Date: 01-19-2016 SAFETY DATA SHEET

1. Identification Product identifier: Sodium Hydroxide, 50% Solution Other means of identification Product No.: 5673, 7706, 3735, 3730, 3725, 3719, 3727, 7705, 0897, 0339 Recommended use and restriction on use Recommended use: Not available.

Restrictions on use: Not known. Details of the supplier of the safety data sheet Manufacturer Company Name: Avantor Performance Materials, Inc. Address: 3477 Corporate Parkway, Suite 200 Center Valley, PA 18034 Telephone: Customer Service: 855-282-6867 Fax: 610-573-2610 Contact Person: Environmental Health & Safety E-mail: info@avantormaterials.com Emergency telephone number: CHEMTREC: 1-800-424-9300 within US and Canada CHEMTREC: 1-703-527-3887 outside US and Canada

2. Hazard(s) identification Hazard Classification Physical Hazards Corrosive to metals Category 1 Health Hazards Skin Corrosion/Irritation Category 1A Serious Eye Damage/Eye Irritation Category 1 Specific Target Organ Toxicity - Category 3 Single Exposure Environmental Hazards Acute hazards to the aquatic Category 3 environment Label Elements Hazard Symbol:

Signal Word: Danger SDS_US - SDSMIX000042 1/10

Version: 2.1 Revision Date: 01-19-2016 Hazard Statement: May be corrosive to metals. Causes severe skin burns and eye damage. May cause respiratory irritation. Harmful to aquatic life. Precautionary Statement Prevention: Keep only in original container. Wash thoroughly after handling. Do not breathe dust/fume/gas/mist/vapors/spray. Use only outdoors or in a well-ventilated area. Wear protective gloves/protective clothing/eye protection/face protection. Response: Absorb spillage to prevent material damage. IF SWALLOWED: Rinse mouth. Do NOT induce vomiting. IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower. Wash contaminated clothing before reuse. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. IF INHALED: Remove person to fresh air and keep comfortable for breathing. Immediately call a POISON CENTER or doctor/physician. Storage: Store in corrosive resistant container with a resistant inner liner. Store locked up. Keep container tightly closed. Store in a well-ventilated place. Disposal: Dispose of contents/container to an appropriate treatment and disposal facility in accordance with applicable laws and regulations, and product characteristics at time of disposal. Other hazards which do not None. result in GHS classification:

3. Composition/information on ingredients Mixtures Common name and Chemical Identity CAS number Content in percent (%)*

synonyms SODIUM HYDROXIDE 1310-73-2 40 - 60%

• All concentrations are percent by weight unless ingredient is a gas. Gas concentrations are in percent by volume.

4. First-aid measures General information: Get medical advice/attention if you feel unwell. Show this safety data sheet to the doctor in attendance.

Ingestion: Call a physician or poison control center immediately. Do NOT induce vomiting. If vomiting occurs, keep head low so that stomach content doesn't get into the lungs. Inhalation: Move to fresh air. If breathing stops, provide artificial respiration. If breathing is difficult, give oxygen. Call a physician or poison control center immediately. Skin

Contact:

Immediately flush with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Call a physician or poison control center immediately. Wash contaminated clothing before reuse. Destroy or thoroughly clean contaminated shoes. SDS_US - SDSMIX000042 2/10

Version: 2.1 Revision Date: 01-19-2016 Eye contact: Immediately flush with plenty of water for at least 15 minutes. If easy to do, remove contact lenses. Call a physician or poison control center immediately. Most important symptoms/effects, acute and delayed Symptoms: Corrosive to skin and eyes. Respiratory tract irritation. Indication of immediate medical attention and special treatment needed Treatment: Treat symptomatically. Symptoms may be delayed.

5. Fire-fighting measures General Fire Hazards: Product is highly caustic. Wear protective gear if spilled during fire fighting.

Suitable (and unsuitable) extinguishing media Suitable extinguishing The product is non-combustible. Use fire-extinguishing media appropriate media: for surrounding materials. Unsuitable extinguishing None known. media: Specific hazards arising from Product is highly caustic. Wear appropriate protective gear if spilled during the chemical: firefighting. Contact with metals may evolve flammable hydrogen gas. Special protective equipment and precautions for firefighters Special fire fighting Move containers from fire area if you can do so without risk. Use water procedures: spray to keep fire-exposed containers cool. Special protective equipment Firefighters must use standard protective equipment including flame for fire-fighters: retardant coat, helmet with face shield, gloves, rubber boots, and in enclosed spaces, SCBA.

6. Accidental release measures Personal precautions, Put on protective equipment before entering danger area. See Section 8 of protective equipment and the SDS for Personal Protective Equipment. Keep unauthorized personnel emergency procedures: away. Keep upwind. Ventilate closed spaces before entering them. Do not touch damaged containers or spilled material unless wearing appropriate protective clothing.

Methods and material for Neutralize spill area and washings with dilute acetic acid. Absorb spill with containment and cleaning vermiculite or other inert material, then place in a container for chemical up: waste. Collect in a non-combustible container for prompt disposal. Dike far ahead of larger spill for later recovery and disposal. Notification Procedures: Dike for later disposal. Prevent entry into waterways, sewer, basements or confined areas. Stop the flow of material, if this is without risk. Environmental Precautions: Do not contaminate water sources or sewer. Prevent further leakage or spillage if safe to do so. Avoid discharge into drains, water courses or onto the ground. SDS_US - SDSMIX000042 3/10

Version: 2.1 Revision Date: 01-19-2016

7. Handling and storage Precautions for safe handling: Use personal protective equipment as required. Avoid breathing mists or vapors. Avoid contact with eyes, skin, and clothing. Do not taste or swallow.

Wash hands thoroughly after handling. Do not eat, drink or smoke when using the product. See Section 8 of the SDS for Personal Protective Equipment. Conditions for safe storage, Do not store in metal containers. Keep container tightly closed. Store in a including any well-ventilated place. Store in a dry place. incompatibilities:

8. Exposure controls/personal protection Control Parameters Occupational Exposure Limits Chemical Identity type Exposure Limit Values Source SODIUM HYDROXIDE Ceiling 2 mg/m3 US. ACGIH Threshold Limit Values (2011)

Ceil_Time 2 mg/m3 US. NIOSH: Pocket Guide to Chemical Hazards (2010) PEL 2 mg/m3 US. OSHA Table Z-1 Limits for Air Contaminants (29 CFR 1910.1000) (02 2006) Ceiling 2 mg/m3 US. OSHA Table Z-1-A (29 CFR 1910.1000) (1989) Appropriate Engineering No data available. Controls Individual protection measures, such as personal protective equipment General information: Good general ventilation (typically 10 air changes per hour) should be used. Ventilation rates should be matched to conditions. If applicable, use process enclosures, local exhaust ventilation, or other engineering controls to maintain airborne levels below recommended exposure limits. If exposure limits have not been established, maintain airborne levels to an acceptable level. Eye/face protection: Wear safety glasses with side shields (or goggles) and a face shield. Skin Protection Hand Protection: Chemical resistant gloves Other: Wear suitable protective clothing. Respiratory Protection: In case of inadequate ventilation use suitable respirator. Hygiene measures: Provide eyewash station and safety shower. Always observe good personal hygiene measures, such as washing after handling the material and before eating, drinking, and/or smoking. Routinely wash work clothing and protective equipment to remove contaminants.

9. Physical and chemical properties Appearance Physical state: liquid Form: liquid Color: Colorless Odor: Odorless Odor threshold: No data available.

pH: 14 SDS_US - SDSMIX000042 4/10

Version: 2.1 Revision Date: 01-19-2016 Melting point/freezing point: 12 °C Initial boiling point and boiling range: 140 °C Flash Point: not applicable Evaporation rate: No data available. Flammability (solid, gas): No data available. Upper/lower limit on flammability or explosive limits Flammability limit - upper (%): No data available. Flammability limit - lower (%): No data available. Explosive limit - upper (%): No data available. Explosive limit - lower (%): No data available. Vapor pressure: No data available. Vapor density: No data available. Relative density: 1.53 (20 °C) Solubility(ies) Solubility in water: Miscible with water. Solubility (other): No data available. Partition coefficient (n-octanol/water): No data available. Auto-ignition temperature: No data available. Decomposition temperature: No data available. Viscosity: No data available.

10. Stability and reactivity Reactivity: Reacts violently with strong acids.

Chemical Stability: Material is stable under normal conditions. Possibility of hazardous Hazardous polymerization does not occur. reactions: Conditions to avoid: Avoid contact with oxidizing agents. Reacts violently with strong acids. Incompatible Materials: Oxidizing agents. Acids. Maleic Anhydride Halogens. Nitromethane. Contact with metals may evolve flammable hydrogen gas. Hazardous Decomposition Sodium oxides Products:

11. Toxicological information Information on likely routes of exposure Ingestion: May cause burns of the gastrointestinal tract if swallowed.

Inhalation: May cause damage to mucous membranes in nose, throat, lungs and bronchial system. Skin

Contact:

Causes severe skin burns. Eye contact: Causes serious eye damage. Information on toxicological effects Acute toxicity (list all possible routes of exposure) Oral Product: No data available. Dermal SDS_US - SDSMIX000042 5/10

Version: 2.1 Revision Date: 01-19-2016 Product: No data available. Inhalation Product: No data available. Repeated dose toxicity Product: No data available. Skin Corrosion/Irritation Product: Causes severe skin burns. Serious Eye Damage/Eye Irritation Product: Causes serious eye damage. Respiratory or Skin Sensitization Product: Not a skin sensitizer. Carcinogenicity Product: This substance has no evidence of carcinogenic properties. IARC Monographs on the Evaluation of Carcinogenic Risks to Humans: No carcinogenic components identified US. National Toxicology Program (NTP) Report on Carcinogens: No carcinogenic components identified US. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050): No carcinogenic components identified Germ Cell Mutagenicity In vitro Product: No mutagenic components identified In vivo Product: No mutagenic components identified Reproductive toxicity Product: No components toxic to reproduction Specific Target Organ Toxicity - Single Exposure Product: Respiratory tract irritation. Specific Target Organ Toxicity - Repeated Exposure Product: None known. Aspiration Hazard Product: Not classified Other effects: None known.

12. Ecological information Ecotoxicity:

Acute hazards to the aquatic environment: Fish Product: No data available. Specified substance(s): SDS_US - SDSMIX000042 6/10

Version: 2.1 Revision Date: 01-19-2016 SODIUM HYDROXIDE LC 50 (Western mosquitofish (Gambusia affinis), 96 h): 125 mg/l Mortality Aquatic Invertebrates Product: No data available. Specified substance(s): SODIUM HYDROXIDE EC 50 (Water flea (Ceriodaphnia dubia), 48 h): 34.59 - 47.13 mg/l Intoxication Chronic hazards to the aquatic environment: Fish Product: No data available. Aquatic Invertebrates Product: No data available. Toxicity to Aquatic Plants Product: No data available. Persistence and Degradability Biodegradation Product: Expected to be readily biodegradable. BOD/COD Ratio Product: No data available. Bioaccumulative Potential Bioconcentration Factor (BCF) Product: No data available on bioaccumulation. Partition Coefficient n-octanol / water (log Kow) Product: No data available. Mobility in Soil: The product is water soluble and may spread in water systems. Other Adverse Effects: Harmful to aquatic organisms. The product may affect the acidity (pH-factor) in water with risk of harmful effects to aquatic organisms.

13. Disposal considerations Disposal instructions: Discharge, treatment, or disposal may be subject to national, state, or local laws.

Contaminated Packaging: Since emptied containers retain product residue, follow label warnings even after container is emptied.

14. Transport information DOT UN Number: UN 1824 UN Proper Shipping Name: Sodium hydroxide solution Transport Hazard Class(es)

Class(es): 8 Label(s): 8 Packing Group: II Marine Pollutant: Not a Marine Pollutant Special precautions for user: - SDS_US - SDSMIX000042 7/10

Version: 2.1 Revision Date: 01-19-2016 IMDG UN Number: UN 1824 UN Proper Shipping Name: SODIUM HYDROXIDE SOLUTION Transport Hazard Class(es) Class(es): 8 Label(s): 8 EmS No.: F-A, S-B Packing Group: II Marine Pollutant: Not a Marine Pollutant Special precautions for user: - IATA UN Number: UN 1824 Proper Shipping Name: Sodium hydroxide solution Transport Hazard Class(es): Class(es): 8 Label(s): 8 Marine Pollutant: Not a Marine Pollutant Packing Group: II Special precautions for user: -

15. Regulatory information US Federal Regulations TSCA Section 12(b) Export Notification (40 CFR 707, Subpt. D)

US. OSHA Specifically Regulated Substances (29 CFR 1910.1001-1050) None present or none present in regulated quantities. CERCLA Hazardous Substance List (40 CFR 302.4): Chemical Identity Reportable quantity SODIUM HYDROXIDE 1000 lbs. Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazard categories Acute (Immediate) SARA 302 Extremely Hazardous Substance None present or none present in regulated quantities. SARA 304 Emergency Release Notification Chemical Identity Reportable quantity SODIUM HYDROXIDE 1000 lbs. SARA 311/312 Hazardous Chemical Chemical Identity Threshold Planning Quantity SODIUM HYDROXIDE 10000 lbs SARA 313 (TRI Reporting) None present or none present in regulated quantities. Clean Water Act Section 311 Hazardous Substances (40 CFR 117.3) Chemical Identity Reportable quantity SODIUM HYDROXIDE Reportable quantity: 1000 lbs. Clean Air Act (CAA) Section 112(r) Accidental Release Prevention (40 CFR 68.130): None present or none present in regulated quantities. US State Regulations SDS_US - SDSMIX000042 8/10

Version: 2.1 Revision Date: 01-19-2016 US. California Proposition 65 No ingredient regulated by CA Prop 65 present. US. New Jersey Worker and Community Right-to-Know Act Chemical Identity SODIUM HYDROXIDE US. Massachusetts RTK - Substance List Chemical Identity SODIUM HYDROXIDE US. Pennsylvania RTK - Hazardous Substances Chemical Identity SODIUM HYDROXIDE US. Rhode Island RTK Chemical Identity SODIUM HYDROXIDE Inventory Status: Australia AICS: On or in compliance with the inventory Canada DSL Inventory List: On or in compliance with the inventory EU EINECS List: On or in compliance with the inventory EU ELINCS List: Not in compliance with the inventory. Japan (ENCS) List: On or in compliance with the inventory EU No Longer Polymers List: Not in compliance with the inventory. China Inv. Existing Chemical Substances: On or in compliance with the inventory Korea Existing Chemicals Inv. (KECI): On or in compliance with the inventory Canada NDSL Inventory: Not in compliance with the inventory. Philippines PICCS: On or in compliance with the inventory US TSCA Inventory: On or in compliance with the inventory New Zealand Inventory of Chemicals: On or in compliance with the inventory Switzerland Consolidated Inventory: Not in compliance with the inventory. Japan ISHL Listing: Not in compliance with the inventory. Japan Pharmacopoeia Listing: Not in compliance with the inventory. 16.Other information, including date of preparation or last revision NFPA Hazard ID 0 Flammability Health 3 1 Reactivity COR Special hazard. Hazard rating: 0 - Minimal; 1 - Slight; 2 - Moderate; 3 - Serious; 4 - Severe; RNP - Rating not possible COR: Corrosive Issue Date: 01-19-2016 Revision Date: No data available. Version #: 2.1 Further Information: No data available. SDS_US - SDSMIX000042 9/10

Version: 2.1 Revision Date: 01-19-2016 Disclaimer: THE INFORMATION PRESENTED IN THIS MATERIAL SAFETY DATA SHEET (MSDS/SDS) WAS PREPARED BY TECHNICAL PERSONNEL BASED ON DATA THAT THEY BELIEVE IN THEIR GOOD FAITH JUDGMENT IS ACCURATE. HOWEVER, THE INFORMATION PROVIDED HEREIN IS PROVIDED AS IS, AND AVANTOR PERFORMANCE MATERIALS MAKES AND GIVES NO REPRESENTATIONS OR WARRANTIES WHATSOEVER, AND EXPRESSLY DISCLAIMS ALL WARRANTIES REGARDING SUCH INFORMATION AND THE PRODUCT TO WHICH IT RELATES, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WITHOUT LIMITATION, WARRANTIES OF ACCURACY, COMPLETENESS, MERCHANTABILITY, NON-INFRINGEMENT, PERFORMANCE, SAFETY, SUITABILITY, STABILITY, AND FITNESS FOR A PARTICULAR PURPOSE, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING, COURSE OF PERFORMANCE, OR USAGE OF TRADE. THIS MSDS/SDS IS INTENDED ONLY AS A GUIDE TO THE APPROPRIATE PRECAUTIONARY HANDLING OF THE MATERIAL BY A PROPERLY TRAINED PERSON USING THIS PRODUCT, AND IS NOT INTENDED TO BE COMPREHENSIVE AS TO THE MANNER AND CONDITIONS OF USE, HANDLING, STORAGE, OR DISPOSAL OF THE PRODUCT. INDIVIDUALS RECEIVING THIS MSDS/SDS MUST ALWAYS EXERCISE THEIR OWN INDEPENDENT JUDGMENT IN DETERMINING THE APPROPRIATENESS OF SUCH ISSUES. ACCORDINGLY, AVANTOR PERFORMANCE MATERIALS ASSUMES NO LIABILITY WHATSOEVER FOR THE USE OF OR RELIANCE UPON THIS INFORMATION. NO SUGGESTIONS FOR USE ARE INTENDED AS, AND NOTHING HEREIN SHALL BE CONSTRUED AS, A RECOMMENDATION TO INFRINGE ANY EXISTING PATENTS OR TO VIOLATE ANY FEDERAL, STATE, LOCAL, OR FOREIGN LAWS. AVANTOR PERFORMANCE MATERIALS REMINDS YOU THAT IT IS YOUR LEGAL DUTY TO MAKE ALL INFORMATION IN THIS MSDS/SDS AVAILABLE TO YOUR EMPLOYEES. SDS_US - SDSMIX000042 10/10

SAFETY DATA SHEET Version

11. Identification of the Substance I Preparation and of the Company / Undertaking Product Name: Vertex EPA Registered Bleach 9616-7 UN/ID No UN1791 Synonyms: VERTEX CSS-12, Liquid Bleach, Soda Bleach Formula: NaOCI Molecular Weight: 74.45 Company Name:

Vertex Chemical Corporation, 11685 Manchester Road, St. Louis, Missouri 63131. (314) 471-0500 Emergency Telephone: Email: VERTEX CHEMICAL CORPORATION 314-471-0500 vertexchem@vertexchem.com NATIONAL EMERGENCY RESPONSE CENTER: www.vertexchemical.com 1-800-424-8802 CHEMTREC (US): 1-800-424-9300 Call CHEMTREC only in the event of chemical emergencies involving a SPILL, LEAK, FIRE, EXPOSURE, or ACCIDENT involving chemicals.

12. Hazards Identification GHS - Classification Skin corrosion/irritation Category 1 Category 1B Serious eye damage/eye irritation Category 1 Specific target organ toxicity (single exposure) Category 2

~cute aquatic toxicity Category 1 Chronic aquatic toxicity Category 1 Signal Word: Danger Hazard Statements:

• Causes severe skin burns and eye damage
• May cause damage to organs
• Very toxic to aquatic life with long lasting effects Ph sical Hazards Corrosive to metals Oxidizin liquids 2 Page 1 / 9

37211 Vertex EPA Registered Bleach 9616-7

• May be corrosive to metals
• May intensify fire; oxidizer Precautionary Statements:
• P312 - Call a POISON CENTER or doctor if you feel unwell
• P301 + P330 + P331 - IF SWALLOWED: rinse mouth. Do NOT induce vomiting
• P303 + P361 + P353 - IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Rinse skin with water/shower
• P363 - Wash contaminated clothing before reuse
• P304 + P340 - IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing
• P305 + P351 + P338 - IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing
• P310 - Immediately call a POISON CENTER or doctor/physician
• P260 - Do not breathe dust/fume/gas/mist/vapors/spray
• P264 - Wash face, hands and any exposed skin thoroughly after handling
• P270 - Do not eat, drink or smoke when using this product
• P309 + P311 - IF exposed or if you feel unwell: Call a POISON CENTER or doctor/physician
• P405 - Store locked up
• P501 - Dispose of contents/container to industrial incineration plant
• P273 - Avoid release to the environment
• P501 - Dispose of contents/ container to an approved waste disposal plant
• P334 - Immerse in cool water/wrap in wet bandages
• P390 - Absorb spillage to prevent material damage
• P406 - Store in corrosive resistant aluminum container with a resistant inliner
• P210 - Keep away from heat/sparks/open flames/hot surfaces. - No smoking
• P220 - Keep/Store away from clothing/ combustible materials
• P221 - Take any precaution to avoid mixing with combustibles
• P280 - Wear protective gloves/protective clothing/eye protection/face protection
• P370 + P378 - In case of fire: Use dry sand, dry chemical or alcohol-resistant foam to extinguish
• P501 - Dispose of contents/container to industrial incineration plant

13. Composition / Information on Ingredients Hazardous Chemical Name CAS No Weight-% EC No Caustic soda 1310-73-2 1 215-185-5 Sodium chloride 7647-14-5 10 231-598-3 Sodium hypochlorite 7681-52-9 15 231-668-3 Non-Hazardous Chemical Name CASNo Wei ht-% EC No Water 7732-18-5 Balance 231-791-2

~- First Aid Measures General Advice: Immediate medical attention is required. Eye

Contact:

Immediate medical attention is required. Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes. Keep eye wide open while rinsing. Do not rub affected area. Skin

Contact:

Immediate medical attention is required . Wash off immediately with soap and plenty of water while removing all contaminated clothes and shoes. Page 2 / 9

37211 Vertex EPA Registered Bleach 9616-7 Inhalation: Move to fresh air. Call a physician or poison control center immediately. If not breathing, give artificial respiration. If breathing is difficult, give oxygen. Ingestion: Immediate medical attention is required. Do NOT induce vomiting. Drink plenty of water. Never give anything by mouth to an unconscious person. Remove from exposure, lie down. Clean mouth with water and drink afterwards plenty of water. Call a physician or poison control center immediately. Note to Physicians: Product is a corrosive material. Use of gastric lavage or emesis is contraindicated. Possible perforation of stomach or esophagus should be investigated. Do not give chemical antidotes. Asphyxia from glottal edema may occur. Marked decrease in blood pressure may occur with moist rales, frothy sputum, and high pulse pressure. Treat symptomatically. Self-protection of the First Aider: Use personal protective equipment as required. Avoid contact with skin, eyes or clothing. Flammable Properties: Not flammable; Highly exothermic reactions with organic materials and oxidizable materials may cause fires in adjacent, heat sensitive materials Explosive Properties: Containers of this material can explode as oxygen is liberated under high heat or fire conditions. Reacts to form explosive products with amines, ammonia or ammonium salts, methanol, aziridine. Explosive reaction with formic acid(@ 55°C), phenyl acetonitrile, ethylene amine Suitable Extinguishing Media: Use extinguishing measures that are appropriate to local circumstances and the surrounding environment; Water spray may be used to keep fire exposed containers cool Unsuitable Extinguishing Media: No information available Specific Hazards Arising from the Chemical: The product causes burns of eyes, skin and mucous membranes; Thermal decomposition can lead to release of irritating and toxic gases and vapors; In the event of fire and/or explosion do not breathe fumes Protective Equipment and Precautions for Firefighters: In the event of a fire, wear full protective clothing and MSHA/NIOSH (approved or equivalent) self-contained breathing apparatus with full facepiece operated in the pressure-demand or other positive pressure mode Personal Precautions: Use personal protective equipment as required. Evacuate personnel to safe areas. Avoid contact with skin, eyes or clothing. Keep people away from and upwind of spill/leak. Environmental Precautions: Do not allow into any sewer, on the ground or into any body of water. Should not be released into the environment. Prevent further leakage or spillage if safe to do so. Prevent product from entering drains. Methods for Cleaning Up: Soak up with inert absorbent material. Clean contaminated surface thoroughly. Dike far ahead of liquid spill for later disposal. Take up mechanically, placing in appropriate containers for disposal. Prevent product from entering drains. Dam up. After cleaning, flush away traces with water. Other Information: Not applicable. Page 3 / 9

37211 Vertex EPA Registered Bleach 9616-7 Advice on Safe Handling: Use personal protective equipment as required . Use only with adequate ventilation . Avoid contact with skin , eyes or clothing. In case of insufficient ventilation , wear suitable respiratory equipment. Use on ly with adequate ventilation and in closed systems. Storage Conditions: Keep container tightly closed in a dry and well-ventilated place. Keep out of the reach of children. Keep containers tightly closed in a dry, cool and well-ventilated place . Keep in properly labeled containers. Incompatible Materials: Strong acids and bases ; Oxidizing agents; Ether, ammonia compounds , hydrogen peroxide , all acids , alum , reducing agents, human or animal waste, oxidizable or combustible materials such as wood, cloth or organic materials, organic chemicals such as solvents and solvent based cleaning compounds , fuels and fuel oils , amines, methanol, propane, organic polymers , ethylene glycol , insecticides, heavy metals such as iron, copper, magnesium, aluminum, tin , steel , stainless steel, carbon steel, manganese, zinc, chromium , nickel , cobalt and their alloys, sodium sulfite, sodium bisulfite, sodium hydrosulfite, sodium thiosulfate. Do not mix this product with any of the foregoing or hazardous gases can result. Exposure Guidelines Caustic soda Ceiling: 2 mg/m 3 Ceiling : 2 mg/m 3 Ceiling: 2 mg/m 3 Ceiling Exposure Guidelines Vacated limits revoked by the Court of Appeals decision in AFL-CIO v. OSHA, 965 F.2d 962 (11th Cir., 1992) Engineering Controls: Ensure adequate ventilation , especially in confined areas Personal protective equipment (PPE) Eye/Face Protection: Tight sealing safety goggles. Face protection shield. Body Protection: Gloves made of plastic or rubber. Rubber boots. Suitable protective clothing . Wear impervious protective clothing, including boots, gloves, lab coat, apron or coveralls, as appropriate , to prevent skin contact. Wear chemical resistant clothing such as gloves, apron, boots or whole bodysuits made from neoprene, as appropriate. General Hygiene Considerations: When using do not eat, drink or smoke. Wash contaminated clothing before reuse. Keep away from food, drink and animal feed ing stuffs. Contaminated work clothing should not be allowed out of the workplace. Regular cleaning of equipment, work area and clothing is recommended . Avoid contact with skin, eyes or clothing. Take off all contaminated clothing and wash it before reuse . Wear suitable gloves and eye/face protection . 9.1. Information on basic physical and chemical properties Physical State: Liquid Appearance: Aqueous solution Odor: Pungent, Chlorine Bleach Odor Color: Clear Yellow Odor Threshold: No information available Property Values Remarks

• Method pH: 13.05 "Salt Out" Point (°F): No information available Melting Point/Freezing Point: -24 °C I -12 °F Boiling Point/Boiling Range: 107 °C / 225 °F Flash Point: No information available Evaporation Rate (BuAc=1 ): No information available Flammability (solid, gas): No information available Page 4 / 9

37211 Vertex EPA Registered Bleach 9616-7 Flammability Limits in Air: No information available Upper Flammability Limit: Lower Flammability Limit: Vapor Pressure (mm Hg) : 70.2@55 °C Vapor density (Air =1) No information available Specific Gravity (H20=1 ): 1.21 Specific Gravity (2nd value): Water Solubility: 100% soluble in water Solubility(ies): No information available Partition Coefficient No information available (n-octanol/water) Autoignition Temperature: Decomposition Temperature: No information available Kinematic Viscosity: 1.83 Centistokes @77 °F Dynamic Viscosity: No information available Oxidizing Properties: No information available Explosive Properties: Containers of this material can explode as oxygen is liberated under high heat or fire conditions. Reacts to form explosive products with amines, ammonia or ammonium salts, methanol, aziridine. Explosive reaction with formic acid(@ 55°C), phenyl acetonitrile, ethylene amine 9.2. Other information Softening Point: No information available Molecular Weight: 74.45 voe Content(%): No information available Density: No information available Bulk Density: No information available Stability: Stable under normal conditions of use and storage; Stability decreases with increased concentration, heat, light exposure, decrease in pH and contamination with heavy metals such as nickel, cobalt, copper and iron Conditions to Avoid: Exposure to air or moisture over prolonged periods; Excessive heat, exposure to light, reduced alkalinity, and contamination of any kind. Reduced alkalinity or contamination can result in evolution of chlorine (toxic) gas. Decrease in pH such as by mixing with other than water, and contamination with items mentioned below as incompatible can result in evolution of chlorine (toxic) gas Incompatible Materials: Strong acids and bases; Oxidizing agents; Ether, ammonia compounds, hydrogen peroxide, all acids, alum, reducing agents, human or animal waste, oxidizable or combustible materials such as wood, cloth or organic materials, organic chemicals such as solvents and solvent based cleaning compounds, fuels and fuel oils, amines, methanol, propane, organic polymers, ethylene glycol, insecticides, heavy metals such as iron, copper, magnesium, aluminum, tin, steel, stainless steel, carbon steel, manganese, zinc, chromium, nickel, cobalt and their alloys, sodium sulfite, sodium bisulfite, sodium hydrosulfite, sodium thiosulfate. Do not mix this product with any of the foregoing or hazardous gases can result. Hazardous Decomposition Thermal decomposition can lead to release of irritating and toxic gases and vapors Products: Possibility of Hazardous Reactions: None under normal processing Product Information Page 5 I 9

37211 Vertex EPA Registered Bleach 9616-7 Acute Toxicity: 0% of the mixture consists of ingredient(s) of unknown toxicity. The following values are calculated based on chapter 3.1 of the GHS document Caustic soda 1350 mg/kg (Rabbit) Sodium chloride 3 g/kg (Rat) 10 g/kg ( Rabbit ) 42 g/m 3 ( Rat ) 1 h Sodium hypochlorite 8200 mg/kg ( Rat ) 10000 mg/kg ( Rabbit ) Water 90 mUkg ( Rat ) Chronic Toxicity: Carcinogenicity: The table below indicates whether each agency has listed any ingredient as a carcinogen This product contains one or more substances which are classified by IARC as carcinogenic to humans (Group I), probably carcinogenic to humans (Group 2A) or possibly carcinogenic to humans (Group 28) IARC (International Agency for Research on Cancer) Not classifiable as a human carcinogen Target Organ Effects: Eyes, Respiratory system, Skin Ecotoxicity 0% of the mixture consists of components(s) of unknown hazards to the aquatic environment Very toxic to aquatic life with long lasting effects Caustic soda 45.4: 96 h Oncorhynchus mykiss mg/L LC50 static Sodium chloride 5560 - 6080: 96 h Lepomis 1000: 48 h Daphnia magna mg/L macrochirus mg/L LC50 ECS0 340. 7 - 469.2: 48 h Daphnia flow-through 6020 - 7070: 96 h magna mg/L ECS0 Static Pimephales promelas mg/L LC50 static 12946: 96 h Lepomis macrochirus mg/L LCS0 static 7050: 96 h Pimephales promelas mg/L LCS0 semi-static 6420 - 6700: 96 h Pimephales promelas mg/L LCS0 static 4747 - 7824: 96 h Oncorhynchus mykiss mg/L LCS0 flow-through Page 6 / 9

37211 Vertex EPA Registered Bleach 9616-7 Sodium hypochlorite 0.095: 24 h Skeletonema costatum 0. 06 - 0. 11: 96 h Pimephales 2. 1: 96 h Daphnia magna mg/L mg/LEC50 promelas mg/L LC50 flow-through EC50 0.033- 0.044: 48 h Daphnia

4. 5 - 7. 6: 96 h Pimephales promelas magna mg/L EC50 Static mg/L LC50 static 0.4 - 0.8: 96 h Lepomis macrochirus mg/L LC50 static 0.28 - 1: 96 h Lepomis macrochirus mg/L LC50 flow-through 0. 05 - 0. 771: 96 h Oncorhynchus mykiss mg/L LC50 flow-through 0.03 - 0.19: 96 h Oncorhynchus mykiss mg/L LC50 semi-static 0.18- 0.22: 96 h Oncorhynchus mykiss mg/L LC50 static Persistence and Degradability: No information available.

Bioaccumulation: No information available. Mobility: No information available. Waste from Residues/Unused Disposal should be in accordance with applicable regional, national and local laws and Products: regulations Contaminated Packaging: Do not reuse container. DOT --Proper shipping name HYPOCHLORITE SOLUTIONS (SODIUM HYPOCHLORITE) Hazard Class 8 UN/ID No UN1791 Packing Group Ill Description UN1791, HYPOCHLORITE SOLUTIONS (SODIUM HYPOCHLORITE), 8, PG Ill International Inventories All of the components in the product are on the following Inventory lists: TSCA (United States):, Canada (DSL/NDSL), Europe (EINECS/ELINCS/NLP), Australia (AICS), South Korea (KECL):, China (IECSC), Philippines (PICCS), This product contains a substance not listed on international inventories - it is for research and development use only. AICS Complies TSCA Complies DSL/NDSL Complies EINECS/ELINCS Complies ENCS Page 7 / 9

37211 Vertex EPA Registered Bleach 9616-7 IECSC Complies KECL Complies PICCS Complies Chemical Name AICS TSCA DSL NDSL EINECS ELINCS ENCS IECSC KECL PICCS Caustic soda Listed Listed Listed - Listed - (2)-1972 Listed KE-31487 Listed (1)-410 Sodium chloride Listed Listed Listed - Listed - (1)-236 Listed KE-31387 Present Sodium hypochlorite Listed Listed Listed - Listed - (1)-237 Listed KE-31506 Present Water Listed Listed Listed - Listed - - Listed KE-35400 Present Inventory Legend AICS - Australian Inventory of Chemical Substances TSCA - United States Toxic Substances Control Act Section 8(b) Inventory DSL/NDSL - Canadian Domestic Substances List/Non-Domestic Substances List EINECS/ELINCS - European Inventory of Existing Chemical Substances/European List of Notified Chemical Substances ENCS - Japan Existing and New Chemical Substances IECSC - China Inventory of Existing Chemical Substances KECL - Korean Existing and Evaluated Chemical Substances PICCS - Philippines Inventory of Chemicals and Chemical Substances RESTRICTIONS - REACH TITLE VII No information available US Federal Regulations CERCLA This material, as supplied , contains one or more substances regulated as a hazardous substance under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (40 CFR 302) Chemical Name CERCLA Hazardous Substances SARA Extremely Hazardous SARA Extremely Hazardous and the Reportable Quantities Substances EPCRA RQ Substances TPQ Caustic soda 1000 lb - - 454 kg Sodium hypochlorite 100Ib 100 lb - 45.4 kg SARA 313 Section 313 of Title Ill of the Superfund Amendments and Reauthorization Act of 1986 (SARA). This product does not contain any chemicals which are subject to the reporting requirements of the Act and Title 40 of the Code of Federal Regulations, Part 372 SARA 311/312 Hazard Categories Acute health hazard Yes Chronic health hazard Yes Fire hazard No Sudden release of pressure hazard No Reactive hazard No U.S. State Right-to-Know Regulations California Proposition 65: This product does not contain any Proposition 65 chemicals National Fire Protection Association (NFPA) Ratings Page 8 / 9

--1 L 37211 Vertex EPA Registered Bleach 9616-7 NSF Certification NSE Ce1rtified to NSF/ANSI 60 Maximum Use (mg/L unless 84 otherwise indicated): Prepa red By: HSE Department Issue Date: 15-Mar-2013 Revision Date: 15-Nov-2012 Revisi on Note: MSDS converted to GHS SOS Format. Disclaimer: Vertex Chemical Corporation ("Vertex") expressly disclaims all express or implied warranties of merchantability and fitness for a particular purpose, with respect to the product or information provided herein . All information appearing herein is based upon data obtained from the manufacturer and/or recognized technical sources. While the information is believed to be accurate, Vertex makes no representations as to its accuracy or sufficiency. Conditions of use are beyond Vertex's control, and, therefore, users are responsible to verify this data under their own operating conditions to determine whether the product is suitable for their particular purposes, and they assume all risks of their use, handling, and disposal of the product, or from the publication or use of, or reliance upon, information contained herein . This information relates only to the product designated herein, and does not relate to its use in combination with any other material or in any other process . End of Safety Data Sheet Page 9 / 9

SAFETY DATA SHEET Creation Date 11-Feb-2010 Revision Date 30-Oct-2014 Revision Number 1

1. Identification Product Name Sodium nitrite Cat No. : S347-10; S347-250; S347-3; S347-500 Synonyms No information available Recommended Use Laboratory chemicals.

Uses advised against No Information available Details of the supplier of the safety data sheet Company Emergency Telephone Number Fisher Scientific CHEMTREC, Inside the USA: 800-424-9300 One Reagent Lane CHEMTREC, Outside the USA: 001-703-527-3887 Fair Lawn, NJ 07410 Tel: (201) 796-7100

2. Hazard(s) identification Classification This chemical is considered hazardous by the 2012 OSHA Hazard Communication Standard (29 CFR 1910.1200)

Oxidizing solids Category 3 Acute oral toxicity Category 3 Serious Eye Damage/Eye Irritation Category 2 Specific target organ toxicity - (repeated exposure) Category 2 Target Organs - Kidney, Liver, Blood, Cardiovascular system. Label Elements Signal Word Danger Hazard Statements May intensify fire; oxidizer Toxic if swallowed Causes serious eye irritation May cause damage to organs through prolonged or repeated exposure Page 1 / 8

Sodium nitrite Revision Date 30-Oct-2014 Precautionary Statements Prevention Use personal protective equipment as required Wash face, hands and any exposed skin thoroughly after handling Do not eat, drink or smoke when using this product Wear eye/face protection Do not breathe dust/fume/gas/mist/vapors/spray Use only outdoors or in a well-ventilated area Keep away from heat/sparks/open flames/hot surfaces. - No smoking Keep/Store away from clothing/ other combustible materials Take any precaution to avoid mixing with combustibles

Response

IF exposed or concerned: Get medical attention/advice Inhalation IF INHALED: Remove victim to fresh air and keep at rest in a position comfortable for breathing Eyes IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing If eye irritation persists: Get medical advice/attention Ingestion IF SWALLOWED: Immediately call a POISON CENTER or doctor/physician Rinse mouth Fire In case of fire: Use CO2, dry chemical, or foam for extinction Storage Store locked up Store in a well-ventilated place. Keep container tightly closed Disposal Dispose of contents/container to an approved waste disposal plant Hazards not otherwise classified (HNOC) Very toxic to aquatic life

3. Composition / information on ingredients Component CAS-No Weight %

Sodium nitrite 7632-00-0 >95

4. First-aid measures Eye Contact Rinse immediately with plenty of water, also under the eyelids, for at least 15 minutes.

Obtain medical attention. Skin Contact Wash off immediately with plenty of water for at least 15 minutes. Get medical attention immediately if symptoms occur. Inhalation Move to fresh air. If breathing is difficult, give oxygen. Do not use mouth-to-mouth resuscitation if victim ingested or inhaled the substance; induce artificial respiration with a respiratory medical device. Immediate medical attention is required. Ingestion Do not induce vomiting. Call a physician or Poison Control Center immediately. Page 2 / 8

Sodium nitrite Revision Date 30-Oct-2014 Most important symptoms/effects No information available. Notes to Physician Treat symptomatically

5. Fire-fighting measures Unsuitable Extinguishing Media No information available Flash Point No information available Method - No information available Autoignition Temperature 510 °C / 950 °F Explosion Limits Upper No data available Lower No data available Oxidizing Properties Oxidizer Sensitivity to Mechanical Impact No information available Sensitivity to Static Discharge No information available Specific Hazards Arising from the Chemical Oxidizer: Contact with combustible/organic material may cause fire. May ignite combustibles (wood paper, oil, clothing, etc.). Do not allow run-off from fire fighting to enter drains or water courses.

Hazardous Combustion Products Nitrogen oxides (NOx) Sodium oxides Protective Equipment and Precautions for Firefighters As in any fire, wear self-contained breathing apparatus pressure-demand, MSHA/NIOSH (approved or equivalent) and full protective gear. Thermal decomposition can lead to release of irritating gases and vapors. NFPA Health Flammability Instability Physical hazards 3 0 2 OX

6. Accidental release measures Personal Precautions Use personal protective equipment. Ensure adequate ventilation. Avoid dust formation.

Keep people away from and upwind of spill/leak. Environmental Precautions Do not flush into surface water or sanitary sewer system. Do not allow material to contaminate ground water system. Prevent product from entering drains. Local authorities should be advised if significant spillages cannot be contained. Methods for Containment and Clean Keep combustibles (wood, paper, oil, etc) away from spilled material. Sweep up or vacuum Up up spillage and collect in suitable container for disposal. Avoid dust formation. Soak up with inert absorbent material. Keep in suitable, closed containers for disposal.

7. Handling and storage Handling Wear personal protective equipment. Ensure adequate ventilation. Avoid dust formation. Do not breathe dust. Do not get in eyes, on skin, or on clothing. Do not ingest. Keep away from clothing and other combustible materials. Wash hands before breaks and immediately after handling the product.

Storage Keep containers tightly closed in a dry, cool and well-ventilated place. Do not store near combustible materials. Store under an inert atmosphere.

8. Exposure controls / personal protection Exposure Guidelines This product does not contain any hazardous materials with occupational exposure limits established by the region specific regulatory bodies.

Page 3 / 8

Sodium nitrite Revision Date 30-Oct-2014 Engineering Measures Ensure adequate ventilation, especially in confined areas. Ensure that eyewash stations and safety showers are close to the workstation location. Personal Protective Equipment Eye/face Protection Wear appropriate protective eyeglasses or chemical safety goggles as described by OSHA's eye and face protection regulations in 29 CFR 1910.133 or European Standard EN166. Skin and body protection Wear appropriate protective gloves and clothing to prevent skin exposure. Respiratory Protection Follow the OSHA respirator regulations found in 29 CFR 1910.134 or European Standard EN 149. Use a NIOSH/MSHA or European Standard EN 149 approved respirator if exposure limits are exceeded or if irritation or other symptoms are experienced. Hygiene Measures Handle in accordance with good industrial hygiene and safety practice.

9. Physical and chemical properties Physical State Solid Appearance Light yellow Odor No information available Odor Threshold No information available pH 8-9 (10 g/l aq.sol)

Melting Point/Range 271 °C / 519.8 °F Boiling Point/Range 320 °C / 608 °F Flash Point No information available Evaporation Rate Not applicable Flammability (solid,gas) No information available Flammability or explosive limits Upper No data available Lower No data available Vapor Pressure No information available Vapor Density Not applicable Relative Density No information available Solubility 820 g/L (20°C) Partition coefficient; n-octanol/water No data available Autoignition Temperature 510 °C / 950 °F Decomposition Temperature > 320°C Viscosity Not applicable Molecular Formula N Na O2 Molecular Weight 69

10. Stability and reactivity Reactive Hazard Yes Stability Oxidizer: Contact with combustible/organic material may cause fire.

Conditions to Avoid Incompatible products. Excess heat. Combustible material. Avoid dust formation. Exposure to moist air or water. Incompatible Materials Acids, Amines, Reducing agents, Oxidizing agents, Combustible material, Strong reducing agents Hazardous Decomposition Products Nitrogen oxides (NOx), Sodium oxides Hazardous Polymerization Hazardous polymerization does not occur. Hazardous Reactions None under normal processing. Page 4 / 8

Sodium nitrite Revision Date 30-Oct-2014

11. Toxicological information Acute Toxicity Product Information Component Information Component LD50 Oral LD50 Dermal LC50 Inhalation Sodium nitrite 85 mg/kg ( Rat ) Not listed 5.5 mg/L ( Rat ) 4 h Toxicologically Synergistic No information available Products Delayed and immediate effects as well as chronic effects from short and long-term exposure Irritation Irritating to eyes Sensitization No information available Carcinogenicity The table below indicates whether each agency has listed any ingredient as a carcinogen.

Component CAS-No IARC NTP ACGIH OSHA Mexico Sodium nitrite 7632-00-0 Not listed Not listed Not listed Not listed Not listed IARC: (International Agency for Research on Cancer) IARC: (International Agency for Research on Cancer) Group 1 - Carcinogenic to Humans Group 2A - Probably Carcinogenic to Humans Group 2B - Possibly Carcinogenic to Humans Mutagenic Effects No information available Reproductive Effects No information available. Developmental Effects No information available. Teratogenicity No information available. STOT - single exposure None known STOT - repeated exposure Kidney Liver Blood Cardiovascular system Aspiration hazard No information available Symptoms / effects,both acute and No information available delayed Endocrine Disruptor Information No information available Other Adverse Effects The toxicological properties have not been fully investigated.

12. Ecological information Ecotoxicity Very toxic to aquatic organisms. The product contains following substances which are hazardous for the environment.

Component Freshwater Algae Freshwater Fish Microtox Water Flea Sodium nitrite - Oncorhynchus mykiss: LC50 - 12.5-100 mg/L 48h

                                                                 = 0.09-0.13 mg/L 96h Persistence and Degradability                Soluble in water Persistence is unlikely based on information available.

Bioaccumulation/ Accumulation No information available. Mobility Will likely be mobile in the environment due to its water solubility. Component log Pow Sodium nitrite -3.7

13. Disposal considerations Waste Disposal Methods Chemical waste generators must determine whether a discarded chemical is classified as a Page 5 / 8

Sodium nitrite Revision Date 30-Oct-2014 hazardous waste. Chemical waste generators must also consult local, regional, and national hazardous waste regulations to ensure complete and accurate classification.

14. Transport information DOT UN-No UN1500 Proper Shipping Name SODIUM NITRITE Hazard Class 5.1 Subsidiary Hazard Class 6.1 Packing Group III TDG UN-No UN1500 Proper Shipping Name SODIUM NITRITE Hazard Class 5.1 Subsidiary Hazard Class 6.1 Packing Group III IATA UN-No UN1500 Proper Shipping Name Sodium nitrite Hazard Class 5.1 Subsidiary Hazard Class 6.1 Packing Group III IMDG/IMO UN-No UN1500 Proper Shipping Name Sodium nitrite Hazard Class 5.1 Subsidiary Hazard Class 6.1 Packing Group III

15. Regulatory information International Inventories Component TSCA DSL NDSL EINECS ELINCS NLP PICCS ENCS AICS IECSC KECL Sodium nitrite X X - 231-555-9 - X X X X X Legend:

X - Listed E - Indicates a substance that is the subject of a Section 5(e) Consent order under TSCA. F - Indicates a substance that is the subject of a Section 5(f) Rule under TSCA. N - Indicates a polymeric substance containing no free-radical initiator in its inventory name but is considered to cover the designated polymer made with any free-radical initiator regardless of the amount used. P - Indicates a commenced PMN substance R - Indicates a substance that is the subject of a Section 6 risk management rule under TSCA. S - Indicates a substance that is identified in a proposed or final Significant New Use Rule T - Indicates a substance that is the subject of a Section 4 test rule under TSCA. XU - Indicates a substance exempt from reporting under the Inventory Update Rule, i.e. Partial Updating of the TSCA Inventory Data Base Production and Site Reports (40 CFR 710(B). Y1 - Indicates an exempt polymer that has a number-average molecular weight of 1,000 or greater. Y2 - Indicates an exempt polymer that is a polyester and is made only from reactants included in a specified list of low concern reactants that comprises one of the eligibility criteria for the exemption rule. U.S. Federal Regulations TSCA 12(b) Not applicable Component TSCA 12(b) Sodium nitrite Section 5 SARA 313 Component CAS-No Weight % SARA 313 - Threshold Values % Sodium nitrite 7632-00-0 >95 1.0 Page 6 / 8

Sodium nitrite Revision Date 30-Oct-2014 SARA 311/312 Hazardous Categorization Acute Health Hazard Yes Chronic Health Hazard Yes Fire Hazard No Sudden Release of Pressure Hazard No Reactive Hazard Yes Clean Water Act Component CWA - Hazardous CWA - Reportable CWA - Toxic Pollutants CWA - Priority Pollutants Substances Quantities Sodium nitrite X 100 lb - - Clean Air Act Not applicable OSHA Occupational Safety and Health Administration Not applicable CERCLA This material, as supplied, contains one or more substances regulated as a hazardous substance under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (40 CFR 302) Component Hazardous Substances RQs CERCLA EHS RQs Sodium nitrite 100 lb - California Proposition 65 This product does not contain any Proposition 65 chemicals State Right-to-Know Component Massachusetts New Jersey Pennsylvania Illinois Rhode Island Sodium nitrite X X X X - U.S. Department of Transportation Reportable Quantity (RQ): Y DOT Marine Pollutant N DOT Severe Marine Pollutant N U.S. Department of Homeland Security This product does not contain any DHS chemicals. Other International Regulations Mexico - Grade No information available Canada This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR WHMIS Hazard Class C Oxidizing materials D1B Toxic materials

16. Other information Prepared By Regulatory Affairs Page 7 / 8

Sodium nitrite Revision Date 30-Oct-2014 Thermo Fisher Scientific Email: EMSDS.RA@thermofisher.com Creation Date 11-Feb-2010 Revision Date 30-Oct-2014 Print Date 30-Oct-2014 Revision Summary This document has been updated to comply with the US OSHA HazCom 2012 Standard replacing the current legislation under 29 CFR 1910.1200 to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Disclaimer The information provided on this Safety Data Sheet is correct to the best of our knowledge, information and belief at the date of its publication. The information given is designed only as a guide for safe handling, use, processing, storage, transportation, disposal and release and is not to be considered as a warranty or quality specification. The information relates only to the specific material designated and may not be valid for such material used in combination with any other material or in any process, unless specified in the text. End of SDS Page 8 / 8

MATERIAL SAFETY DATA SHEET Sulfuric Acid Where reliability, consistency, and quality of product and service are our goals 1750 E. President Street; Savannah GA 31404 P 912-232-1101 F 912-232-1103 2600 Highway 421 North; Wilmington, NC 28401 P 910-762-5054 F 910-762-1600 4620 Highway 421 North; Wilmington, NC 28401 Page 1 P 910-762-5054 F 910-762-1600

1 CHEMICAL PRODUCT & COMPANY IDENTIFICATION Trade Name: SULFURIC ACID CAS Number: 7664-93-9 Synonym: OIL OF VITRIOL Manufacturer: Southern States Chemical, Inc. Supplier: 100 E. President Street 2600 Highway 421 North 4620 Highway 421 North AND AND Savannah GA 31404 Wilmington NC 28401 Wilmington NC 28401 24 Hour Emergency Assistance: General Assistance: [8 AM5 PM (M-F EST)] Chemtrec: 800-424-9300 Savannah GA 912-232-1101 Wilmington NC 910-762-5054 2 HAZARDS IDENTIFICATION EMERGENCY OVERVIEW: DANGER! CORROSIVE TO THE SKIN, EYES & RESPIRATORY TRACT. HEALTH HAZARD: ASPIRATION HAZARD IF SWALLOWED-CAN ENTER LUNGS AND CAUSE DAMAGE CANCER HAZARD (SEE TOXICOLOGICAL INFORMATION [SECTION #11] FOR MORE INFORMATION) FLAMMABILITY HAZARDS: NON-COMBUSTIBLE REACTIVITY HAZARDS: Exothermic Reaction- MAY REACT VIOLENTLY WITH WATER. Always add acid to water, never water to acid! POTENTIAL HEALTH EFFECTS SKIN: CORROSIVE. Contact may cause reddening, itching, inflammation, burns, blistering and possibly severe tissue damage. Repeated or prolonged contact may result in drying, red-dening, itching, pain, inflammation, cracking and possible secondary infection with tissue damage. EYE: CORROSIVE. Exposure may cause severe burns, destruction of eye tissue and possible permanent injury or blindness. Prolonged or repeated exposure may cause irritation and conjunctivitis. INHALATION: EXTREMELY IRRITATING AND CORROSIVE. May cause severe burns and tissue damage to the respiratory tract. Symptoms may include throat burns, construction of the wind-pipe (bronchospasms), severe pulmonary edema and death, depending on the concentra-tion and duration of exposure. Overexposure to this material may cause systemic damage including target organ effects listed under Toxicological Information [Section #11]. Other specific symptoms of exposure are listed under Toxicological Informa-tion [Section #11]. Page 2

2 HAZARDS IDENTIFICATION, Cont. POTENTIAL HEALTH EFFECTS INGESTION: CORROSIVE. May cause painful irritation and burning of the mouth and throat, painful swallowing, labored breathing, burns or perforation of the gastrointestinal tract leading to ulceration and secondary infection. Corrosive damage to the stomach and esophagus may be delayed. Aspiration into lungs may cause chemical pneumonia and lung damage. Overexposure to this material may cause systemic damage including target organ effects listed under Toxicological information [Section #11]. Other specific symptoms of exposure are listed under Toxicological information [Section

                        #11].

3 COMPOSITION / INFORMATION ON INGREDIENTS Ingredient Name CAS Number Concentration SULFURIC ACID 7664-93-9 6-100% 4 FIRST AID MEASURES SKIN: Immediately flush skin with plenty of water, for at least 15 minutes, while removing contaminated clothing and shoes. GET IMMEDIATE MEDICAL ATTENTION! Place contaminated clothing in closed container for storage until laundered or discarded. If clothing is to be laun-dered, inform person performing operation of contaminants hazardous properties. Discard contaminated leather goods. EYE: Flush immediately with large amounts of water for at least 15 minutes. Eyelids should be held away from the eye-ball to ensure thorough rinsing. GET IMMEDIATE MEDICAL ATTENTION! INHALATION: Remove to fresh air. If not breathing, institute rescue breathing. If breathing is difficult, ensure airway is clear and give oxygen. Keep affected person warm and at rest. GET IMMEDIATE MEDICAL ATTENTION! INGESTION: If victim is conscious and alert, give 1-3 glasses of water to dilute stomach contents. Rinse mouth out with water. Do not induce vomiting unless directed by medical personnel. Never give anything by mouth to an unconscious person. If spontaneous vomiting occurs keep head below hips to prevent aspiration and monitor for breathing diffi-culty. Keep affected person warm and at rest. GET IMMEDIATE MEDICAL ATTENTION! Page 3 SOUTHERN STATES CHEMICAL, INC.

5 FIRE FIGHTING MEASURES HAZARDOUS COMBUSTION PRODUCTS: Decomposes to form sulfur dioxide and sulfur trioxide. EXTINGUISHING MEDIA: Use carbon dioxide or dry chemical to extinguish fire. BASIC FIRE FIGHTING PROCEDURES: Do not add water to acid. Water applied directly results in evolution of heat and splattering of acid. Acid can react with metals to liberate flammable hydrogen gas, especially when diluted with water. Evacuate area and fight fire from a safe distance. Use water spray to cool adjacent structures and to protect personnel. Do not get water in-side sulfuric acid containers. Shut off source of flow if possible. Stay away from storage tank ends. Withdraw im-mediately in case of rising sound from venting safety device or any discoloration of storage tank due to fire. UNUSUAL FIRE & EXPLOSION HAZARDS: Material will not burn. Reacts with most metals to produce hydrogen gas which can form an explosive mixture with air. 6 ACCIDENTAL RELEASE MEASURES EMERGENCY ACTION: Keep unnecessary people away; isolate hazard area and deny entry. Stay upwind. Isolate for 1/2 mile in all direc-tions if tank, rail car or tank truck is involved in fire. Evacuate area endangered by release as required. (See Exposure Control/Personal Protection [Section #8] ENVIRONMENTAL PRECAUTIONS: If product is released to the environment, take immediate steps to stop and contain release. Caution should be exercised regarding personnel safety and exposure to the released product. Notify local authorities and the Na-tional Response Center, if required. SPILL OR LEAK PROCEDURE: Keep unnecessary people away. Isolate area for at least 50-100 meters (160-330 feet) to preserve public safety. For large spills, consider initial evacuation for at least 300 meters (1000 feet). Large spills may be neutralized with dilute alkaline solutions of soda ash or lime. Stop leak when safe to do so. See Exposure Controls/Personal Protection [Section #8]. 7 HANDLING AND STORAGE HANDLING: This material should be stored and shipped in plastic or plastic lined containers. Do not use with materials or equipment sensitive to acidic solutions. Do not eat, drink or smoke in areas of use or storage. STORAGE: Avoid contact with combustible materials, water, metals and alkalis. Store in a vented container. Sulfuric acid re-acts with most metals to produce hydrogen gas which can form an explosive mixture with air. Empty containers may contain product residue. Do not reuse without adequate precautions. Page 4

8 EXPOSURE CONTROLS / PERSONAL PROTECTION ENGINEERING CONTROLS: Ventilation and other forms of engineering controls are the preferred means for controlling exposures. EYE PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE) Wear chemical safety goggles and face shield. Have eye washing facilities readily available where eye contact can occur. SKIN PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE) Avoid skin contact with this material. Use appropriate chemical protective gloves when handling. Additional protection may be necessary to prevent skin contact including use of apron, gauntlets, boots, impervi-ous protective suit and face shield or splash goggles. Provide safety showers at any location where skin contact can occur. Use good personal hygiene. RESPIRATORY PROTECTION: PERSONAL PROTECTION EQUIPMENT (PPE) A NIOSH/MSHA approved air purifying respirator with an appropriate acid gas cartridge or canister may be appro-priate under certain circumstances where airborne concentrations are expected to exceed exposure limits. Pro-tection provided by air purifying respirators is limited. Use a positive pressure air supplied respirator if there is any potential for an uncontrolled release, exposure levels are not known, or any other circumstances where air purify-ing respirators may not provide adequate protection. EXPOSURE LIMITS / HEALTH HAZARDS: 1 mg/m3 8-Hour TWA (OSHA) 1 mg/m3 8-Hour TWA (ACGIH) 3 mg/m3 15-Min STEL (ACGIH)

• Values do not reflect absolute minimums and maximums; these values are typical which may vary from time to time.

9 PHYSICAL AND CHEMICAL PROPERTIES ODOR AND APPEARANCE: COLORLESS TO CLOUDY OILY LOOKING LIQUID, ALMOST ODORLESS Boiling Point 6-85% - 215-440F [102-227C], 93% - 541F [283C], 96% - 600F [316C], 99%- 625F [329C] Specific Gravity 6-85% - 1.04-1.79, 93% - 1.84, 96% - 1.84, 99% - 1.84 Vapor Pressure (6-85% <1,93%-<1,96%-<1,99%-<1) (mmHg at 100F) Solubility in Water 100% pH Value <1 Freezing Point 6-85% = 30-(-40)F [-1-(-30)C],85%=46F [8C], 93%=-20F [-29C], 96%= 5.5F [-15C], 99%=40F [4C] Molecular Formula H2SO4 Molecular Weight 98.08 Chemical Family MINERAL ACID Page 5 SOUTHERN STATES CHEMICAL, INC.

10 STABILITY AND REACTIVITY STABILITY / INCOMPATIBILITY: Avoid contact with water. Incompatible with combustible materials, water, metals and alkalis. See precautions under Handling & Stor-age [Section #7] HAZARDOUS REACTIONS / DECOMPOSITION PRODUCTS Decomposes to form sulfur dioxide and sulfur trioxide. 11 TOXICOLOGICAL INFORMATION ROUTES OF EXPOSURE: Inhalation, ingestion, skin and eye contact. LD50 LD50: Sulfuric Acid, Rat, Oral, 2140mg/kg. TOXICOLOGICAL INFORMATION: Acute or chronic overexposure to this material or its components may cause systemic toxicity, including adverse effects to the following: kidney, liver, teeth, respiratory and cardiovascular systems. Exposure to components of this material may cause the following specific symptoms, depending on the concentra-tion and duration of exposure: attacks enamel of teeth, vomiting, clammy skin, weak and rapid pulse. Other symptoms of exposure may include the following: shallow respiration, chronic bronchitis, lung function changes and scanty urine. CARCINOGENICITY: IARC has determined that there is sufficient evidence for the carcinogenicity of occupational exposure to strong inorganic acid mists containing sulfuric acid in humans (IARC Class 1). PRE-EXISTING CONDITIONS AGGRAVATED BY EXPOSURE: Pre-existing medical conditions which may be aggravated by exposure include disorders of the skin and respiratory system. 12 ECOLOGICAL INFORMATION ALL WORK PRACTICES MUST BE AIMED AT ELIMINATING ENVIRONMENTAL CONTAMINATION. ENVIRONMENTAL MOBILITY (SOIL & AIR): When released into the soil, this material may leach into groundwater. When released into the air, this material may be removed from the atmosphere to a moderate extent by dry deposition. ECOTOXICITY: Aquatic toxicity rangeSlightly to moderately toxic Bluegill sunfish, 48 Hour; LC50, 49mg/L (Tap water, 20C) Flounder, 48 Hour; LC50, 100-330mg/L (Aerated water, conditions of bioassay not specified) Shrimp, 48 Hour; LC50, 80-90mg/L (Aerated water, conditions of bioassay not specified) Page 6

13 DISPOSAL CONSIDERATIONS WASTE DISPOSAL: This product as supplied, when discarded or disposed of, is a hazardous waste according to Federal regulations (40 CFR 261) due to its corrosiveness and reactivity. Under the Resource Conservation and Recovery Act (RCRA), it is the responsibility of the user of the product to determine, at the time of disposal, whether the material is a haz-ardous waste subject to RCRA. The transportation, storage, treatment and disposal of RCRA waste material must be conducted in compliance with 40 CFR 262, 263, 264, 268, 270. Disposal can occur only in properly permitted facilities. Check state and local regulations for any additional requirements as these may be more restrictive than federal laws and regulations. Chemical additions, processing or otherwise altering this material may make the waste management information presented in this MSDS incomplete, inaccurate or otherwise inappropriate. Disposal of this material must be con-ducted in compliance with all federal, state and local regulations. 14 TRANSPORT INFORMATION BILL OF LADING - BULK (U. S. DOT): RQ, Sulfuric Acid, 8, UN 1830, PG II (use with more than 51% acid) RQ, Sulfuric Acid, 8, UN 2796, PG II (use with not more than 51% acid) BILL OF LADING - NON-BULK (U. S. DOT) RQ, Sulfuric Acid, 8, UN 1830, PG II (use with more than 51% acid) RQ, Sulfuric Acid, 8, UN 2796, PG II (use with more than 51% acid) U. S. DEPARTMENT OF TRANSPORTATION (DOT) REQUIREMENTS: General Transportation Information for Bulk Shipments Proper Shipping Name Sulfuric Acid Hazard Class 8 UN/NA Code UN 1830, UN 2796 Packaging Group PG II Labels Required Corrosive Placards Required Corrosive, UN 1830 (>51%), UN 2796 (51%) Reportable Quantity See Regulatory Information [Section #15] General Transportation Information for Non-Bulk Shipments Proper Shipping Name Sulfuric Acid Hazard Class 8 UN/NA Code UN 1830, UN 2796 Packaging Group PG II Labels Required Corrosive Reportable Quantity See Regulatory Information [Section #15] (The above description may not cover shipping in all cases. Please consult 49 CFR 172.101 for specific shipping information) Page 7 SOUTHERN STATES CHEMICAL, INC.

15 REGULATORY INFORMATION FEDERAL REGULATIONS: All ingredients are on the TSCA inventory or are not required to be listed on the TSCA inventory. This product, as supplied, contains sulfuric acid, a Hazardous Substance as per 40 CFR Part 302.4 and an Extremely Hazardous Substance as per 40 CFR Part 344. The reportable quantity for sulfuric acid is 1,000 pounds. Any release of this product equal to or exceeding the reportable quantity must be reported to the National Response Center (800-424-8802) and appropriate state and local regulatory agencies as described in 40 CFR Part 302.6 and 40 CFR 355.40, respectively. Failure to report may result in substantial civil and criminal penalties. Check state and local regulations for any additional requirements as these may be more restrictive than federal laws and regulations. This product contains one or more components designated as hazardous substances or toxic pollutants under Section 112 of the Clean Air Act. There may be specific regulations at the local, regional or state/provincial level that pertain to this product. HCS CLASSIFICATION: Oxidizing material, Highly toxic material, Corrosive material, Carcinogen, Target organ effects. STATE REGULATIONS: Based on available information this product contains components or chemicals currently known to the state of California to cause cancer. Reformulation, use or processing of this product may affect its composition and require re-evaluation. SARA TITLE III RATINGS Immediate Hazard: X Delayed Hazard: X Fire Hazard: Pressure Hazard: Reactivity Hazard: X NFPA RATINGS Health 3 Flammability 0 Reactivity 2 Special Hazards W HMIS RATINGS Health 3 Flammability 0 Reactivity 2 Following ingredients of this product are listed in SARA 313 SARA Listed Ingredient Name CAS Number Maximum% SULFURIC ACID 7664-93-9 100.0 16 OTHER INFORMATION DISCLAIMER: NOTICE: The information presented herein is based on data considered to be accurate as of the date of preparation of this Material Safety Data Sheet. However, MSDS may not be used as a commercial specification sheet of manufacturer or seller, and no warranty or representa-tion, expressed or implied, is made as to the accuracy or comprehensiveness of the foregoing data and safety information, nor is any authori-zation given or implied to practice any patented invention without a license. In addition, no responsibility can be assumed by vendor for any damage or injury resulting from abnormal use, from any failure to adhere to recommended practices, or from any hazards inherent in the nature of the product. PO Box 546 2600 Highway 421 N. 4620 Highway 421 N. 1750 E. President St. Savannah, GA 31402 Wilmington, NC 28401 Wilmington, NC 28401 Savannah, GA 31404 Phone: 912-232-1101 Phone: 910-762-5054 Phone: 910-762-5054 Phone: 912-232-1101 Fax: 912-232-1103 Fax: 910-762-1600 Fax: 910-762-1600 Fax: 912-232-1103 Last Updated 06/20/11 Page 8

Safety Data Sheet Version 1.6 Revision Date 03/01/2017

1. PRODUCT AND COMPANY IDENTIFICATION Product Name Zinc Acetate Dihydrate (DZA)

Chemical Formula (CH3COO)2 Zn

• 2H2O or C4H6O4Zn
• 2H2O Molecular Weight 219.51 g/mol CAS No. 5970-45-6 EC No. 209-170-2 Supplier Address* ISOFLEX USA P.O. Box 29475 San Francisco, CA 94129 United States Telephone +1 415-440-4433 Fax +1 415-563-4433 Emergency Phone Number +1 707-766-4207 (both supplier and manufacturer) *May include subsidiaries or affiliate companies/divisions Email iusa@isoflex.com Website www.isoflex.com Preparation Information ISOFLEX USA Product Safety

                                     +1 415-440-4433

2. HAZARDS IDENTIFICATION Classification of the Substance or Mixture GHS07 Acute Toxicity 4 H302 Harmful if swallowed Classification according to Directive 67/548/EEC or Directive 1999/45/EC Harmful Harmful if swallowed Dangerous for the environment Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment Information concerning particular hazards for human and environment: Not applicable Label elements Labelling according to EU guidelines:

The product has been classified and marked in accordance with directives on hazardous materials.

Code letter and hazard designation of product: Harmful Dangerous for the environment Risk phrases: Harmful if swallowed Very toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment Safety phrases: Avoid contact with skin and eyes. Avoid release to the environment. Refer to special instructions/safety data sheets. NFPA Ratings: (0 = Minimal; 1 = Slight; 2 = Moderate; 3 = Serious; 4 = Severe) Health Hazard = 2 Flammability = 0 Reactivity = 0 HMIS Ratings: (0 = Minimal; 1 = Slight; 2 = Moderate; 3 = Serious; 4 = Severe) Health Hazard = 2 Flammability = 0 Physical Hazard = 0 HEALTH HAZARD 2 FLAMMABILITY 0 PHYSICAL HAZARD 0 Other Hazards: Results of PBT and vPvB assessment: Not applicable

3. COMPOSITION/INFORMATION ON INGREDIENTS Chemical Name: Zinc di(acetate)

CAS No.: 5970-45-6 EC No.: 209-170-2 Chemical Formula: (CH3COO)2 Zn

• 2H2O or C4H6O4Zn
• 2H2O Molecular Weight: 219.51 g/mol

4. FIRST AID MEASURES General advice Consult a physician. Show this safety data sheet to the doctor in attendance. Move out of dangerous area.

Inhalation If breathed in, move person into fresh air. If not breathing, give artificial respiration. Consult a physician. Dermal Exposure Wash off with soap and plenty of water for at least 15 minutes. Remove contaminated clothing and shoes. Consult a physician. Eye Exposure Rinse thoroughly with plenty of water for at least 15 minutes and consult a physician. Ingestion Never give anything by mouth to an unconscious person. Rinse mouth with water. Consult a physician.

5. FIREFIGHTING MEASURES Conditions of Flammability Not flammable or combustible Suitable Extinguishing Media Use water spray, alcohol-resistant foam, dry chemical or carbon dioxide.

Special Protective Equipment Wear self-contained breathing apparatus for firefighting if necessary. for Firefighters Additional information Dispose of fire debris and contaminated firefighting water in accordance with official regulations.

6. ACCIDENTAL RELEASE MEASURES Personal Precautions Use personal protective equipment. Avoid dust formation. Avoid breathing vapors, mist, dust or gas. Ensure adequate ventilation.

Environmental Precautions Prevent further leakage or spillage if safe to do so. Do not let product enter drains. Discharge into the environment must be avoided. Methods and Materials for Pick up and arrange disposal without creating dust. Sweep up and Containment and Cleaning Up shovel. Keep in suitable, closed containers for disposal. Reference to other sections See Section 7 for information on safe handling. See Section 8 for information on personal protection equipment. See Section 13 for disposal information.

7. HANDLING AND STORAGE Handling Avoid contact with skin and eyes. Avoid formation of dust and aerosols.

Provide appropriate exhaust ventilation at places where dust is formed. Storage Keep container tightly closed in a dry and well-ventilated place. Keep in a dry place. Recommended storage temperature: 15-25 ºC. Storage class: 10-13.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION Contains no substances with occupational exposure limit values Personal protective equipment Respiratory protection For nuisance exposures use type P95 (US) or type P1 (EU EN 143) particle respirator. For higher-level protection use type OV/AG/P99 (US) or type ABEK-P2 (EU EN 143) respirator cartridges. Use respirators and components tested and approved under appropriate government standards such as NIOSH (US) or CEN (EU).

Hand protection Wear appropriate protective gloves to prevent skin exposure. Glove material must be impermeable and resistant to the product/ substance/preparation. Select the glove material with consideration of penetration times, rates of diffusion and degradation. The exact breakthrough time must be determined by the manufacturer of the protective gloves and must be observed by the user. Selection of suitable gloves depends not only on the material, but also on further marks of quality, and varies from manufacturer to manufacturer. For full contact, gloves made with the following specifications are suitable: Nitrile rubber, NBR Recommended thickness of the material: 0.11 mm Value for the permeation: Level 480 minutes

For splash contact, gloves made with the following specifications are suitable: Nitrile rubber, NBR Recommended thickness of the material: 0.11 mm Value for the permeation: Level 480 minutes Eye protection Safety glasses with side-shields conforming to EN166 Use equipment for eye protection tested and approved under appropriate government standards such as NIOSH (US) or EN 166(EU). Skin and body protection Complete suit protecting against chemicals. The type of protective equipment must be selected according to the concentration and amount of the dangerous substance at the specific workplace. Hygiene measures Handle in accordance with good industrial hygiene and safety practice. Wash hands before breaks and at end of workday.

9. PHYSICAL AND CHEMICAL PROPERTIES Appearance Form Powder Color White Safety Data pH 6.0 - 8.0 at 50 g/l at 25 °C (77 °F)

Melting point/freezing point Melting point/range: 237 °C (459 °F) Boiling point No data available Flash point No data available Flammability (solid, gaseous) Product is not flammable Ignition temperature No data available Auto-ignition temperature No data available Lower explosion limit No data available Upper explosion limit No data available Vapor pressure No data available Density at 20 ºC (68 ºF) 1.840 g/cm3 (15.355 lb/gal) Bulk density at 20 ºC (68 ºF) ~900 kg/m3 Relative density No data available Vapor density No data available Evaporation rate No data available Solubility in/miscibility with water at 20 ºC (68 ºF) 430 g/l Partition coefficient/n-octanol/water No data available Relative vapor density No data available Odor No data available Odor threshold No data available Evaporation rate No data available

10. STABILITY AND REACTIVITY Chemical Stability Stable under recommended storage conditions Possibility of Hazardous No data available Reactions Conditions to Avoid No data available Materials to Avoid Oxidizing agents Hazardous Decomposition Hazardous decomposition products formed under fire conditions -

Products Carbon oxides, zinc/zinc oxides. Other decomposition products No data available

11. TOXICOLOGICAL INFORMATION Acute toxicity Oral LD50 LD50 Oral - Rat - 794 mg/kg Remarks: Sense Organs and Special Senses (Nose, Eye, Ear, and Taste): Eye: Miosis (pupillary constriction). Vascular: BP elevation not characterized in autonomic section. Nutritional and Gross Metabolic: Weight loss or decreased weight gain.

Inhalation LC50 No data available Dermal LD50 No data available Other information No data available on acute toxicity Skin corrosion/irritation Mild skin irritation - 24 h Serious eye damage/eye Moderate eye irritation - 24 h Irritation Respiratory or skin Irritant to skin and mucous membranes Sensitization Germ cell mutagenicity Genotoxicity in vitro - Human - lymphocyte Cytogenetic analysis Carcinogenicity IARC No component of this product present at levels greater than or equal to 0.1% is identified as a probable, possible or confirmed human carcinogen by IARC. ACGIH: No component of this product present at levels greater than or equal to 0.1% is identified as a carcinogen or potential carcinogen by ACGIH. NTP: No component of this product present at levels greater than or equal to 0.1% is identified as a known or anticipated carcinogen by NTP. OSHA: No component of this product present at levels greater than or equal to 0.1% is identified as a carcinogen or potential carcinogen by OSHA. Reproductive toxicity No data available Teratogenicity No data available Specific target organ No data available toxicity - single exposure (Globally Harmonized System) Specific target organ No data available toxicity - repeated exposure (Globally Harmonized System) Potential Health Effects Ingestion Harmful if swallowed Signs and Symptoms To the best of our knowledge, the chemical, physical, and toxicological of Exposure properties have not been thoroughly investigated. Additional information RTECS: ZG8750000

12. ECOLOGICAL INFORMATION Toxicity No data available Persistence and degradability No data available Bioaccumulative potential No data available Mobility in soil No data available Ecotoxical effects Very toxic for fish Water hazard class 3 (self-assessment); extremely hazardous for water.

Poisonous for fish and plankton in bodies of water. Do not allow to enter bodies of water, waste water or soil. Very toxic for aquatic organisms. PBT and vPvB assessment: No data available Other adverse effects: No data available

13. DISPOSAL CONSIDERATIONS Product Do not allow product to reach sewage system. Offer surplus and non-recyclable solutions to a licensed disposal company. Contact a licensed professional waste disposal service to dispose of this material.

Contaminated packaging Disposal must be made according to official regulations. Dispose of contaminated packaging in the same manner as the product.

14. TRANSPORT INFORMATION UN No. (DOT, ADR, IMDG, IATA) UN3077 UN proper shipping name DOT, IMDG, IATA ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. (Zinc acetate)

ADR 3077 ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. (Zinc acetate) Transport hazard class(es) DOT, IMDG Class 9 Miscellaneous dangerous substances and articles Label 9 ADR Class 9 (M7) Miscellaneous dangerous substances and articles Label 9 IATA Class 9 Miscellaneous dangerous substances and articles Label 9

Packing group (DOT, ADR, IMDG, IATA) III Environmental Hazards Marine Pollutant: Special Marking (ADR, IATA) Special precautions for user Warning: Miscellaneous dangerous substances and articles Danger code (Kemler) 90 EMS No. F-A,S-F Transport in bulk according to Annex II of MARPOL 73/78 and the IBC Code: Not applicable UN Model Regulation UN3077, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. (Zinc acetate), 9, III

15. REGULATORY INFORMATION OSHA Hazards Harmful by ingestion, irritant SARA 302 Components No chemicals in this material are subject to the reporting requirements of SARA Title III, Section 302 SARA 313 Components The following components are subject to reporting levels established by SARA Title III, Section 313: Zinc di(acetate) / CAS No. 5970-45-6 /

Revision Date 1993-04-24. SARA 311/312 Hazards Acute Health Hazard Massachusetts Right to Zinc di(acetate) / CAS No. 5970-45-6 / Revision Date 1993-04-24 Know Components Pennsylvania Right to Know Zinc di(acetate) / CAS No. 5970-45-6 / Revision Date 1993-04-24 Components New Jersey Right To Know Zinc di(acetate) / CAS No. 5970-45-6 / Revision Date 1993-04-24 Components California Prop. 65 Components This product does not contain any chemicals known to the State of California to cause cancer, birth defects, or any other reproductive harm.

16. OTHER INFORMATION Prepared by ISOFLEX USA P.O. Box 29475 San Francisco, CA 94129 United States Issuing Date September 15, 2014 Revision Date April 10, 2015 Revision Number 1 Prepared By Lori McKannay Matthews Revision Note Required format update

ISOFLEX USA's Commonly Used Abbreviations and Acronyms* ACGIH American Conference of Governmental Industrial Hygienists ADR European Agreement Concerning the International Carriage of Dangerous Goods by Road ALARA As Low As Is Reasonably Achievable AMU Atomic Mass Unit ANSI American National Standards Institute BLS Basic Life Support CAM Continuous Air Monitor CAS Chemical Abstracts Service (division of the American Chemical Society) CEN European Committee for Standardization CERCLA Comprehensive Environmental Response Compensation and Liability Act CLP Classification, Labelling and Packaging (European Union) CPR Controlled Products Regulations (Canada) CWA Clean Water Act (USA) DAC Derived Air Concentration (USA) DOE United States Department of Energy (USA) DOT United States Department of Transportation (USA) DSL Domestic Substances List (Canada) EC50 Half Maximal Effective Concentration EINECS European Inventory of Existing Commercial Chemical Substances EHS Environmentally Hazardous Substance ELINCS European List of Notified Chemical Substances EMS Emergency Response Procedures for Ships Carrying Dangerous Goods EPA Environmental Protection Agency (USA) EPCRA Emergency Planning and Community Right-To-Know Act (EPCRA) of 1986 GHS Globally Harmonized System HMIS Hazardous Materials Identification System (USA) IARC International Agency for Research on Cancer IATA International Air Transport Association IBC Intermediate Bulk Containers ICAO International Civil Aviation Organization IDLH Immediately Dangerous to Life or Health IMDG International Maritime Code for Dangerous Goods LC50 Lethal concentration, 50 percent LD50 Lethal dose, 50 percent LDLO Lethal Dose Low LOEC Lowest-Observed-Effective Concentration MARPOL International Convention for the Prevention of Pollution from Ships MSHA Mine Safety and Health Administration (USA) NCRP National Council on Radiation Protection & Measurements (USA) NDSL Non-Domestic Substances List (Canada) NFPA National Fire Protection Association (USA) NIOSH National Institute for Occupational Safety and Health (USA) NOEC No Observed Effect Concentration N.O.S. Not Otherwise Specified NRC Nuclear Regulatory Commission (USA) NTP National Toxicology Program (USA) OSHA Occupational Safety and Health Administration (USA) PBT Persistent Bioaccumulative and Toxic Chemical PEL Permissible Exposure Limit PIH Poisonous by Inhalation Hazard RCRA Resource Conservation and Recovery Act (USA) RCT Radiation Control Technician REACH Registration, Evaluation, Authorisation and Restriction of Chemicals (Europe) RID Regulations Concerning the International Transport of Dangerous Goods by Rail RTECS Registry of Toxic Effects of Chemical Substances SARA Superfund Amendments and Reauthorization Act (USA) TDG Transportation of Dangerous Goods (Canada) TIH Toxic by Inhalation Hazard

TLV Threshold Limit Value TPQ Threshold Planning Quantity TSCA Toxic Substances Control Act TWA Time Weighted Average UN United Nations (Number) VOC Volatile Organic Compound vPvB Very Persistent Very Bioaccumulative Chemical WGK Wassergefhrdungsklassen (Germany: Water Hazard Classes) WHMIS Workplace Hazardous Materials Information System

• One or more of the above-listed items may not appear in this document.

General Disclaimer For terms and conditions, including limitation of liability, please refer to the purchase agreement in effect between ISOFLEX USA (or any of its affiliates and subsidiaries) and the purchaser. DISCLAIMER OF EXPRESSED AND IMPLIED WARRANTIES Although reasonable care has been taken in the preparation of this document, we extend no warranties and make no representations as to the accuracy or completeness of the information contained herein, and assume no responsibility regarding the suitability of this information for the user's intended purposes or for the consequences of its use. Each individual should make a determination as to the suitability of the information for their particular purpose(s). The above information is believed to be correct but does not purport to be all inclusive and shall be used only as a guide. ISOFLEX shall not be held liable for any damage resulting from handling or from contact with the above product.

FPL St. Lucie Power Plant FL0002208 Permit Renewal Application Application Attachment III September 2020 Toxicity Report

Prepared for: Florida Power & Light St. Lucie Power Plant 6501 South Ocean Drive Jensen Beach, FL 34957 Prepared by: Hydrosphere Research Test Location: 11842 Research Circle Alachua, FL 32615 Contact Information: Craig Watts, Lab Director (386) 4627889 cwatts@hydrosphere.net www.hydrosphere.net Test Number: FPLSL 20218 Permit Number: FL0002208 Initiated: September 22, 2020 Test Type: 7day Chronic Definitive Bioassays Hydrosphere Research is a NELAP Certified Lab (E82295) FPL-SL 20218 Page 1 of 40

Report of Routine Bioassays Performed for Florida Power & Light, St. Lucie Power Plant Abstract To comply with the routine whole effluent biomonitoring requirements of the National Pollutant Discharge Elimination System (NPDES) permit FL0002208, composite samples were collected from the St. Lucie Power Plant in St. Lucie County, Florida. Hydrosphere Research conducted a series of 7day chronic definitive bioassay tests using the samples provided. The results are summarized in the accompanying report. This report shall not be reproduced, except in full, without the written approval of the laboratory. All test results contained in this report comply with the requirements of the National Environmental Laboratory Accreditation Program (NELAP). The results discussed in this report relate only to the samples as identified on the Chain of Custody forms in Appendix A. The Laboratory Bench Sheets and Statistical Analyses are in Appendix B, and the Standard Reference Toxicity Tests are in Appendix C. Introduction To comply with the routine whole effluent biomonitoring requirements of NPDES permit FL0002208, composite samples were collected from Outfall EFF01 at the Florida Power and Light St. Lucie Power Plant, St. Lucie County, Florida. Using these samples, Hydrosphere Research conducted a series of 7day chronic definitive bioassay tests with the mysid shrimp (Mysidopsis bahia) and the inland silverside (Menidia beryllina). Materials and Methods Test Sample Composite samples were collected from Outfall EFF01 at the Florida Power and Light St. Lucie Power Plant on September 21, 23, & 25, 2020. The samples were contained in 1/2 gallon high density polyethylene containers, which were intact upon arrival. Hydrosphere Research received these samples in good condition. The Chain of Custody forms are in Appendix A. Each effluent sample tested was assigned a unique sample identification number. Upon receipt, the effluent temperature of each sample met the sample acceptance criteria. The effluent water quality values fell into expected ranges for pH, dissolved oxygen, and temperature. All other chemical characterization data for the effluent samples upon arrival in the laboratory are provided on the Sample Data Bench Sheet in Appendix B. FPL-SL 20218 Page 2 of 40

Test Methods Test methods are presented in Table 1. The dilution series used was specified in the permit. The toxicity tests were performed according to the methods listed in the table below. All tests adhered to NELAP standards. Table 1. Test Methods Test Type Species Dilution Series (%) Test Method 7day chronic static EPA821R02014, M. bahia 0, 6.25, 12.5, 25, 50, 100 renewal definitive Method 1007.0 7day chronic static EPA821R02014, M. beryllina 0, 6.25, 12.5, 25, 50, 100 renewal definitive Method 1006.0 Test Organisms M. bahia test organisms were cultured inhouse and M. beryllina test organisms were commercially obtained. All organisms appeared to be in normal condition at test initiation. Toxicity Test Monitoring Each test was monitored at the test initiation and daily thereafter for mortality, temperature, dissolved oxygen, pH, and salinity. The bioassay tests were initiated on September 22, 2020. Standard Reference Toxicity Tests A reference toxicant test was conducted for each test species to evaluate the sensitivity of the test organisms for the acute tests. The test conditions and dilution series were specific for each reference toxicant test conducted. Test Location The bioassay tests were performed at Hydrosphere Research, 11842 Research Circle, Alachua, FL 32615; telephone number (386) 4627889. The laboratory is NELAP certified by the State of Florida Department of Health and Rehabilitation Services (E82295). Statement of Quality Assurance This report was reviewed by the Hydrosphere Research Laboratory Director to ensure the procedures outlined in the Hydrosphere Research Quality Manual were followed. Testing was conducted using generally accepted lab practices. Hydrosphere Research believes the results are true and accurate and meet all NELAP standards. FPL-SL 20218 Page 3 of 40

Results & Discussion Toxicity Test Results Water quality values remained within acceptable limits during the test periods. The results of the control exposures met the test acceptability requirements specified in the methods. The bioassay tests were initiated within 36 hours of the first samples collection time and were acceptable tests based on controls and test conditions. Copies of the relevant laboratory raw data pertaining to the toxicity tests are provided in Appendix B. The toxicity test results are summarized in Table 2. Chronic Test Results and the corresponding graphs below: Table 2. Chronic Test Results M. bahia M. beryllina Biomass Biomass

                          % Effluent   % Survival                     % Effluent                        % Survival (mg/Fish)                                                        (mg/Fish)

Control 100 0.286 Control 93 1.073 6.25 100 0.268 6.25 93 1.041 12.5 98 0.263 12.5 95 1.143 25 100 0.263 25 88 0.938 50 100 0.253 50 95 1.140 100 100 0.234 100 95 1.123 IC25 >100% IC25 >100% Figure 1. M. bahia Growth Figure 2. M. beryllina Growth M. bahia Average Biomass M. beryllina Average Biomass Average Weight in mg Average Weight in mg 0.400 1.200 0.300 1.000 0.800 0.200 0.600 0.100 0.400 0.200 0.000 0.000

                                         % Effluent                                                              % Effluent All statistical calculations were made using CETIS (Tidepool Scientific Software, McKinleyville, CA). The statistical results are in Appendix B.

The samples provided did not exhibit chronic toxicity to either test species. The IC25 was >100% effluent for all bioassay tests. FPL-SL 20218 Page 4 of 40

During these tests, dissolved oxygen, temperature, and pH remained within the limits established in the test methods. Total residual chlorine, alkalinity, and hardness were also within the limits established by the test methods. No unusual observations or deviations from standard test protocol were noted. These test results only relate to the samples in this report and meet all requirements of NELAP. Standard Reference Toxicity Test Results The results of the standard reference toxicant tests indicate that M. bahia and M. beryllina were of normal sensitivity for this laboratory. The bench sheets, statistical analysis, and control charts for each standard reference toxicant test are in Appendix C. Conclusions Hydrosphere Research initiated a series of 7day chronic definitive bioassay tests using the mysid shrimp (M. bahia) and inland silverside (M. beryllina) on September 22, 2020. The tests were conducted to satisfy the requirements of NPDES permit FL0002208. The samples provided did not exhibit chronic toxicity to either test species. The IC25 was >100% effluent for all bioassay tests. All results met the chronic toxicity limitations given in the permit. References U.S. Environmental Protection Agency. ShortTerm Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Marine and Estuarine Organisms. Third Edition. EPA821R 02014. October 2002. Handbook of Analytical Quality Control in Water and Wastewater Laboratories. EPA600/479 019. March 1979. Chemical and physical parameters reported herein were determined by methods described in Methods for Chemical Analysis of Water and Waste. EPA 600/479020. March 1983. NPDES Forms The following four pages present the NPDES forms which include Table 3. NPDES Whole Effluent Toxicity Testing Report Form, Table 4. Summary of Test Conditions, Table 5. Acute Test Results, and Table 6. Chronic Test Results. FPL-SL 20218 Page 5 of 40

Table 3. NPDES Whole Effluent Toxicity Testing Report Form All blanks on this form are to be filled in. Blanks that are not used should be filled in with "N/A" or a line drawn through the blank. Please print. Attachments: Please attach the following items to this report form and indicate with an "x" in box.

1. All ChainofCustody Forms X

2. All Reference Toxicant Data for each Organism used in Test and Current Control Charts for each Organism X

3. All Raw Data (Bench Sheets) Pertaining to the Tests (i.e., all physical, chemical, and biological measurements) X

4. All Result Calculations X

5. Discharge Monitoring Reports (DMR) when Applicable NA Facility/industry/client name: Florida Power & Light - St. Lucie Power Plant Permit number: FL0002208 County: St. Lucie Consultant company name: Hydrosphere Research Telephone: (386) 4627889 Dates test(s) conductedBegin: 09/22/20 End: 09/29/20 Persons conducting test(s) (print names): R. Hewitt, P. Meyer, K. Strickland Authorized signature: Date: 10/05/20 Laboratory report #/project #: FPLSL 20218 Sampler (print name): D. Brown DMR monitoring period end date on which this test is reported (filled out by the Permitteemm/dd/yy):

Routine test: X Additional test: NA Failed routine test date: NA Samples Arrival Lab Dechlorination Date & Time Lab 24Hour Initial Residual No. Grab Temperature Collected Sample # Composite Chlorine Y/N Chemical Used (C)

1. 09/21/200630 20218A NA X 2.1 <0.04 N NA

2. 09/23/200645 20218B NA X 0.6 <0.04 N NA

3. 09/25/200655 20218C NA X 0.9 <0.04 N NA

4. NA NA NA NA NA NA NA NA

5. NA NA NA NA NA NA NA NA

6. NA NA NA NA NA NA NA NA

7. NA NA NA NA NA NA NA NA

8. NA NA NA NA NA NA NA NA

9. NA NA NA NA NA NA NA NA

10. NA NA NA NA NA NA NA NA Other Samples Aerated Wet Ice Blue Ice (describe) Yes (describe) No Refrigerant used for sample transportation: X NA NA NA X Common Samples Filtered Bus Hand Carrier Yes (describe) No Samples delivered by: NA NA X NA X FPL-SL 20218 Page 6 of 40

Table 4. Summary of Test Conditions Type Test Test Age of Amount & How Test Volume of Type # of Temp. of Concentrationsb Species Test Type of Often Chamber Effluent of Organisms/ # of Range Testa (% Effluent) Usedc Organism Food Fed Volume Used Chamber Chamber Replicates (C) F 0, 6.25, 12.5, 25, 50, 100 MS 7 days 0.05 ml Artemia 2x/ day 500 mL 200 mL Plastic Cup 5 8 26.0 +/- 1.0 F 0, 6.25, 12.5, 25, 50, 100 SS 11 days 1 ml Artemia 2x/ day 1L 500 mL Plastic Cup 10 4 25.0 +/- 1.0 Single Multiple Continuous G. "Other" type of test: NA Temperature readings: NA X NA Description of control water: Synthetic Seawater Photoperiod during test: 16 hours light / 8 hours dark Reference Toxicant Datad Dates of Test Name of Toxicant Speciesc InHouse or Commercially Obtained LC50/IC25 Begin End Cu2+ 09/01/20 09/08/20 MS InHouse IC25 = 147 µg/L Cu2+ 09/01/20 09/08/20 SS Commercially Obtained IC25 = 85 µg/L aPlease cWrite fill the "Type of Test" box with the appropriate letter: appropriate letters for the following species in this column: A. 48Hr/NonRenewal/Single Concentration (Screen) CD Ceriodaphnia dubia B. 48Hr/NonRenewal/MultiConcentration (Definitive) FM Pimephales promelas (fathead minnow) C. 96Hr/Renewed Every 48 Hrs/Single Concentration (Screen) SS Menidia beryllina (inland silverside) D. 96Hr/Renewed Every 48 Hrs/MultiConcentration (Definitive) MS Americamysis bahia (formerly Mysidopsis bahia, mysid shrimp) E. 7Day Chronic/Single Concentration (Screen)/Renewed Daily CL Cyprinella leedsi (bannerfin shiner) F. 7Day Chronic/MultiConcentration (Definitive)/Renewed Daily Other Please describe: G. Other (described in the "G" box) bList all concentrations of effluent used (i.e., 0%, 6.25%, 12.5%, 25%, 50%, 100%). dAttach all reference toxicant raw data & control charts for each organism/reference toxicant used for the test. FPL-SL 20218 Page 7 of 40

Table 5. Acute Test Results Test Grab Composite  % Mortalityd  % Mortalityd Test Species Concentrationsb LC50e Samplec Samplec (48 Hours) (96 Hours) (% Effluent) Controla NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Controla NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA aList % Control Mortality in appropriate column (48 or 96 hr) for organisms (use abbreviations shown on footnote "c" of Table 4) that you list under the word "Control." Control mortality must not exceed 10% for a valid acute test. bList all concentrations of effluent used (i.e., 0%, 6.25%, 12.5%, 25%, 50%, 100%). cRecord number that corresponds with the number of the sample in the "Date & Time Collected" column in sample section. dList % Mortality for each organism and control if you are conducting a single concentration (Screen) test. eIf multiconcentration (Definitive) tests are conducted on grab or composite samples, record the calculated LC50 in this column for each sample. Enter "N/A" in all % Mortality columns and LC50 box at bottom of this table. fIf Species LC50f a single concentration (screen) test is conducted and >50% mortality occurs in any one of the four grab or composite samples, record <100% in this column. If <50% mortality occurs in all NA NA four grabs or composites, record >100% in this column. Draw a line through the LC50 column NA NA in the above table. FPL-SL 20218 Page 8 of 40

Table 6. Chronic Test Results Test IC25 Test Concentrationsb Growthc Reproductionc Speciesa (% Effluent) MS 0, 6.25, 12.5, 25, 50, 100 >100% NA SS 0, 6.25, 12.5, 25, 50, 100 >100% NA aUse abbreviations shown on footnote "c" of Table 4. bList all concentrations of effluent used (i.e., 0%, 6.25%, 12.5%, 25%, 50%, 100%). cFor single concentration tests (Screen), if there is a significant difference (P = 0.05) between survival, growth, reproduction, or fecundity in 100% or IWC, and control, record <100% in proper column. If there is not a significant difference between survival, growth, reproduction, or fecundity in 100% or IWC, and control, record >100% in proper column. CD Survival in Control (>80%) NA Average Number of Young per Female in CD Control NA (min 15 young/surviving female) FM Survival in Control (>80%) NA Average FM Dry Weight in Control NA (min ADW 0.25 mg/FM in surviving controls) MS Survival in Control (80%) 100% Average MS Dry Weight in Control 0.286 (min ADW 0.20 mg/MS in surviving controls) SS Survival in Control (80%) 93% Average SS Dry Weight in Control 1.073 (min immediate ADW 0.50 mg/SS in surviving controls) FPL-SL 20218 Page 9 of 40

Appendix A. Chain of Custody FPL-SL 20218 Page 10 of 40

       @~ Hydrosphere           research                                                                       CHAIN OF CUSTODY Client Name                                                    Client Shipping Address FP&L                                                           St. Lucie Power Plant 6501 South Ocean Drive Jensen Beach, FL 34957 St. Lucie Power Plant                                                                                      .                                         /)

Sample Kit lnfonnation Cooler 2 of 4 Prepared and Shipped by t({/ Sample Kit Received By

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       @~                     Hydrosphere research                                                                       CHAIN OF CUSTODY Client Name                                                  Client Shipping Address FP&L                                                         St. Lucie Power Plant 6501 South Ocean Drive Jensen Beach, FL 34957
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St. Lucie Power Plant Sample Kit Information Prepared and Shipped by Sample Kit Received By .

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                                                            ~Wet Ice Samples/Hou, lI                  Volume/Sample            Ck; .sq=;. ,

Alachua, FL 32615 0 Other (deacnbe) ,..--:: (386) 462-7889 Samples must arrive at the lab :S 6.0 *c Total Hour,: Z e.( Total Volume .$ f (never frozen). Pack cooler completely Be Sure to Mark for Saturday Delivery If Appropriate Samp~~pon / with ice before shipping. Initiated D a t e ~ Time (J6 9'ct~

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                                                                     .sle Provisions on back FPL-SL 20218 Page 12 of 40

(!'/~ rHydrosphere esearch CHAIN OF CUSTODY Client Name Client Shipping Address FP&L St. Lucie Power Plant 6501 South Ocean Dnve Jensen Beach, FL 34957 St. Lucie Power Plant

                                                                                                                                                       /\

Sample Kit Information Prepared and Shipped by Sample Kit Received By I -

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                                                                                                          "J:),,9v1 Cooler 3 of 4 Container Type:             1/2 gal bottle rL#                                          7NZ:                                   -

1,)1 Signature Number of Containers: 8 Date Date 4-1--~~..> Time ( C. .__._ .--::::. Method of Shipment: FedEx Ground 91/6 1

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Ship Samples Priority Overnight To: Refrigerant Used For Shipping Composite Sample Information Hydrosphere Research 11842 Research Circle

                                                            ~Wetlce Samples/Hour 2...          Volume/Sample       /?-- I Alachua, FL 32615                                        0    Other (describe)

(386) 462-7889 Samples must anive at the lab :5 6. O °C Total Hours 2.cf Total Volume

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Appendix B. Raw Data Sheets & Statistical Results FPL-SL 20218 Page 14 of 40

Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1007.0) research Survival, Growth & Fecundi1y '( Client: I FPL - St. Lucie Power Plant Units 1 & 2 I Initiation Date: I "1 f L-°),J)1) I Termination Date: I "f/).1/i4' I Code: I FPL-SL I I 20 Job#, 1.. 1 g I Sample

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PhotoperiOu is l6*hours light nnd 8-hours dnrk, \Uuminintion i3 ambient (50 lo JOO fled) Other: Version 2 (13059*DCF} F:\Clients\FPL, Floridn Power & Llght\FPL-SL\Bcru:h\FPL-SL.MS.07.CSRD.Surv2.EP Al007 .v2~ FPL-SL 20218 Page 15 of 40

Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1007.0) r e :i.e arch Survival, Growth & Fecundity r Clion* I FPL - St. Lucie Power Plant Umts 1 & 2 I Code: I FPL-SL I Job*,l '20"2,li I Sample

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4 / 2"'\ I T;,1 l\"i*Ii) 177J1 IISS 17 In I\? i-I "ni 11'1/ //tp I DeteFinelDry Weights:I

                                                                                                                                                                                                'f/ Ja Randomization Fet.din g Type :                                   Artemia (150-uauplii/shrimp/day)                                                                                                                                   "'

N f &Commen " Temp late# Amount: I-drop of a concentrated slurry I 2x / day Morning: X. .,

                                                                   '7 c,C>          'VY            +3o              1\\17 ll 9' S,,             '\Co n,J,:;;.

(!_C/ Evenin g: !SW i1t.oO :i30 \6,,V C1c,, lSoo PhotoperiW is 16-hours light and 8-hours dark, llluminiation ls ambient (SO to 100 ftcd) Other: F:\Clicnts\FPL, Florida Power & Light\FPL-SL\Bcnch\FPL-SL.MS.o7.CSRD.Surv3.EP.A I007.v2- FPL-SL 20218 Page 16 of 40 Version 2 (13060-D CF)

CETIS Analytical Report Report Date: 05 Oct-20 09:17 (p 1 of 1) Test Code: FPL-SL 20218MSC 110-0057-2623 Mysidopsis 7-d Survival, Growth and Fecundity Test Hydrosphere Research Analysis ID: 00-9833-3091 Endpoint: Mean Dry Biomass-mg ....,,,,.. CETIS Version: CETISv1 .9.3 Analyzed: 05 Oct-20 9: 17 Analysis: Linear Interpolation (ICPIN)_., Official Results: Yes Linear Interpolation Options X Transform YTransform Seed Resamples Exp95% CL Method Linear Linear 1819128 200 Yes Two-Point Interpolation Test Acceptability Criteria TAC Limits Attribute Test Stat Lower Upper Overlap Decision Control Resp 0.286 0.2 >> Yes Passes Criteria Point Estimates Level  % 95% LCL 95% UCL TU 95% LCL 95% UCL IC25 >100 n/a n/a <1 n/a n/a Mean Dry Biomass-mg Summary Calculated Variate Isotonic Variate Cone-% Code Count Mean Min Max Sid Dev CV% %Effect Mean %Effect 0 D 8 0.286 / 0.25 0.318 0.02273 7.95% 0.0% 0,286 0.0% 6.25 8 0.2682 / 0.234 0.312 0.02276 8.49% 6.21% 0.2682 6.21% 12.5 8 0.2628/ 0.214 0.304 0.03269 12.44% 8.13% 0.263 8.04% 25 8 0.2633' 0.226 0.292 0.02258 8.58% 7.96% 0.263 8.04% 50 8 0.2525/ 0.218 0.282 0.02056 8.14% 11.71% 0.2525 11.71% 100 8 0.234 ' 0.208 0.252 0.01727 7.38% 18.18% 0.234 18.18% Mean Dry Biomass-mg Detail Cone-% Code Rep 1 Rep2 Rep3 Rep4 Reps Rep6 Rep7 Rep8 0 D 0.318 0.284 0.26 0.308 0.25 0.282 0.296 0.29 6.25 0.312 0.264 0.268 0.28 0.25 0.234 0.264 0.274 12.5 0.266 0.256 0.246 0.304 0.302 0.284 0.214 0.23 25 0.26 0.226 0.292 0.238 0.27 0.28 0.258 0.282 50 0.228 0.252 0.218 0.266 0.282 0.26 0.254 0.26 100 0.238 0.252 0.248 0.224 0.212 0.208 0.24 0.25 t ,~L c.w 002-360-881-3 CETIS' v1 .9.3.0 Analys~ QA:lo/~/LO FPL-SL 20218 Page 17 of 40

~ Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1007.0) ~ research Water Quality I f Client: I FPL - St. Lucie Power Plant Units I & 2 Hutchison Island I Initiation Date:I Di 12:). I~ I Termination Date:I "!/),4/io I Code: I FPL-SL I Job#: I j_(IJ ')_( t I Sample

Description:

Species: I Mysidopsis bahia I m,,1 ,~ *- l{j)I,. tf

                                                        '. * .. I' Sampl~

Description

                ~          oow     I old   new I old new I    old pH lablc ran= for a valid lcsl is 6 to 9' new I old           new I old      new l old   new I-' old      n=      I old    new I old Dissolved Oxygen (mg/L) la  tnble minimllll1 for a \'alid test is 4.0-mnll 1 new I old       new I old             new I old         new I old   new I old Effluent 0      I     I     I     2        I        3        I         4          I    5      I    6     I    7         0     I      1     I     2     I        3          I          4          I       5     I     6     I  7 B

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~ Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1007.0) ~~ ~research Water Quality II r Client: I FPL

• St. Lucie Power Plant Units I & 2 Hutchison Island I Initiation Date:! c, In-l 7-o I Termination Date:I ~ l'J-9\ /'JV I Code: I FPL-SL I Job#: I 101-1i I Sample

Description:

Species: I Mysidopsis bahia I m,, I lOl.!'B:= I Sample  % l,>--~~~~~~S_ah_"ni~ty~~-*)~~~-~-~---~~*==T~-~-pe=~=~=d!1=~=z~~----~1 Description Effiucnt lf--n~ew-+-old__,..=-now-+--=old_M=w+-o=ld.,,..c*~*w+-'o~ld~"'--'---<w~ol~d=*'w-+--=old~*=ow___,___~old "=<h"-'-;24-h=ex"-'cposu="'"'a"=*od~ ~ ~ = - - '

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Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1006.0) research Survival & Growth Client: j------------ FPL - St. Lucie Power Plant Units I & 2 I Control Water:I SSW I Initiation Date: I °i/2")J h I Termination Date: I '1. I ).AI:i., I Cod" I FPL-SL I Job#,I '.JO'Jd XJ ID #:I see "water quality" I Sample

Description:

Species: I I I = ss I Code: I ,:;::, =d:;==:I Menidia beryllina Test Vessel:f 1-L Plastic Cup I ID#:1 10'51.,. I A ge, Test Volume:! 500-mL I rep. I I I !'.'.I Live Counts [

• IF Q  %

Biomass (original number, fmElidry weight lwis. VnlidControl i, .5-mg{surviving fish) s,mpk De..cription EfRuent I _.,- V,./

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Wt./ Fish

                                                                                                                                                       ,,                                                                          ~m)-

0 I 2 3 4 5 6 ' 7 # (0.00001-<ml) (0.00001-m (0.00001-gms) (0.001-mgs)

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                                                                                                                                       ¥1,/J            ~Q               I  DateTareDryWeighU:I 4Ut                          Initials:  I t/
                                                                                                                                                                                                                                                                   /1, I
                                                                                                                                                      ,n-~ l                                                     :I                                             I- 7ttl7 II Date Final Dry Weights                                                   lnitialll:

Tirv..: 19 Ll-5 IIJ15 Jll 5 , ~~ 1045"'1/s~ /).fa 11'Je

i,,nR11 II Raildomization Feeding Type: Artemia Notes & Comments Templ11te# Amount: 1-mL011, twice daily © At the same time the effluent salinity is adjusted, a Salinity Control will be prepared by diluting an aliquot of control water to L

match the initial effluent salinity and then adjusting this control to the test salinity using direct addition of artificial sea salts to

~

L,r,y 1-=to - ,. Morning:

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                                                                                                                                       . d-                                mimic the efiluent salinity adjustment.

Noon (if needed): I I 13 11z1n see Artemia SOP for feeding preparation, section 5.3.B.7 .b versmn,, 1 Lo,*~~, Evening: 17 Lf-E; \'J'l--0 lt,oo IIS '.>rl I 1630 r:,c.,ien!5

                                                                                                                     \ I I(:) 1501>

t'L, ,-' ,onua C ower << 1,ig nt~ Photoperiod is 16-hours light and 8hours dark, Illuminiation is ambient (50 to 100 fled) PL-SV.Bench\Fp .,._.,,...,.,,v, ......,,,., 161( _._.,urv_.....,1-'VVV,Vl.- J; I FPL-SL 20218 Page 20 of 40 I

CETIS Analytical Report Report Date: 05 Oct-20 09:17 (p 1 of 1) Test Code: FPL-SL 20218SSC I 02-1784-0737 Inland Silverside 7-d LaNal SuNival and Growth Test Hydrosphere Research Analysis ID: 06-9559-8831 Endpoint: Mean Dry Biomass-mg .., CETIS Version: CETISv1 .9.3 Analyzed: 05 Oct-20 9: 17 Analysis: Linear Interpolation (ICPIN) - Official Results: Yes Linear Interpolation Options X Transform Y Transform Seed Resamples Exp 95% CL Method Linear Linear 103418 200 Yes Two-Point Interpolation Test Acceptability Criteria TAC Limits Attribute Test Stat Lower Upper Overlap Decision Control Resp 1.073 0.5 >> Yes Passes Criteria Point Estimates Level  % 95% LCL 95% UCL TU 95% LCL 95% UCL IC25 >100 n/a n/a <1 n/a n/a Mean Dry Biomass-mg Summary Calculated Variate Isotonic Variate Cone-% Code Count Mean Min Max Std Dev CV% %Effect Mean %Effect 0 D 4 1.073' 0.94 1.303 0.1662 15.49% 0.0% 1.086 0.0% 6.25 4 1.041' 0.912 1.156 0.1007 9.68% 3.05% 1.086 0.0% 12.5 4 1.143-' 1.022 1.285 0.1089 9.53% -6.48% 1.086 0.0% 25 4 0.9383-' 0.891 1.041 0.06955 7.41% 12.58% 1.067 1.71% 50 4 1.14.,,,, 0.957 1.22 0.1242 10.90% -6.17% 1.067 1.71% 100 4 1.123' 1.081 1.169 0.03731 3.32% -4.64% 1.067 1.71% Mean Dry Biomass-mg Detail Cone-% Code Rep 1 Rep2 Rep3 Rep4 0 D 0.94 1.087 1.303 0.963 6.25 1.031 1.156 1.063 0.912 12.5 1.148 1.285 1.022 1.116 25 0.92 1.041 0.901 0.891 50 1.216 1.22 0.957 1.165 100 1.169 1.133 1.109 1.081 002-360-881-3 CETIS' v1 .9.3.0 FPL-SL 20218 Page 21 of 40

~ Hydrosphere ~research Chronic Saltwater Method (EPA-821-R-02-014, Method 1006.0) ..,~*:a,1*,t~(

                                                                                                                                                                                    .. *.                   Water Quality I                       $ ,r Client: I        FPL - St. Lucie Power Plant Units l & 2 Hutchison Island                                   I  lnifiafion Date:I    "'l /7:2.-/ '2-n          I             Termination Date:I                "f /),,'3/tp,     I Code:  I       FPL-SL              I           Job#:       I     ?--0'")..,\ ct:              I   Sample

Description:

Species: I Menidia beryllina I rn,, I I o'?Ji ~ I

                      %,                                                        pH                                                                                            Dissolved Oxygen (mg/L)

Sample I I racccnlab[~r for a valid testis 6 to 91 (acceptable minimum for a Yalid test is 4.0-m ,If., Description Effluent new old now old now old now old oow old now old oow old now I old new I old new I old new I old new I old new I old new I old 0 I 2 3 4 s 6 7 I 2 s I I8 0 1 1 1 3 1 4 1 I 6 I 7 Control

                              ....:)

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~ Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1006.0) research Water Quality II Client: I FPL - St. Lucie Power Plant Units I & 2 Hutchison Island I Initiation Date:I C,/22/,_ I Termination Date:j '1. I). 'i /J.,,, I Code: I FPL-SL I Job#: I 'bo1--lfs' I Sample

Description:

Species: I Menidia beryllina I ID#, I \0 51.-- I Salinity (%0) Temperature {°C) Sample I % I '="'*b!c ran"" for a valid test is 25+/-!°C1 Description Measured at the end of each 24-h exposure period I Effiucnt new 0 old 1 new old 2 new old 3 11ew old 4 new old 5 new old 6 new old 7 0 1 2 3 7 4 5 7 6 7 B8 J'l-. 1 ~t ~ ['I', [m~ CV-- N-- [mo r':- ~~ ('I) CV,

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                                                                                                                                                                                                                                      "J.t-1,.S Notes & Comments (1)33.0

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~ Hydrosphere
~research Client:!           FPL - St. Lucie Power Plant Units I & 2 Hutchison Island
          ~----;========;----;::::=======~

Code:! FPL-SL I Job:~l_*?.,o_'2-_1~X----~ Sample Data Dissolved Oxygen Total Residual Sample In£o Ammonia Conductivity Salinity Alkalinity/Hanlness

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© Aeration rate is 500-mls/min (EPA-821-R-02-012, Section 9. 1.8, page 41). If sample is to be dechlorintaed then use 1-mL Effluent Dechlorinator (8-g/L NaThio) per 1-L Effluent Sample per I-ppm TRC (EPA-821-R-02-012, Section 9.1.6, pg 41) Version 3 (12040*DCF) F:\Clients\FPL, Florida Power & Light\FPL-SL\Bench\1) FPL-SL.Sample.Data.v3 FPL-SL 20218 Page 24 of 40

Appendix C. Reference Toxicant Data FPL-SL 20218 Page 25 of 40

Control Chart-I Control Limits for Standard Reference Toxicant Tests CHRONIC Mysidopsis bahia (Hydrosphere Research) 400.00 380.00 147 µg/L IC25 = _______ Mean The IC25 is within the control limits. 360.00 IC25 340.00 Upper Control Limit QA Signature:________________________ Date:___________ 09/10/20 Note: Dates with no corresponding IC25 data point, if present on chart, indicates an invalid test. Lower Control Limit 320.00 Note: If the control limit(s) for two or more consecutive tests are exceeded then the results must be explained here and the test must be repeated immediately. (EPA-821-R-02-014, Sections 4.16.4, page 15). Also, Section 4.16.5 of the same Method states 300.00 that "...reference toxicant results should not be used as a de facto criterion for rejection of individual effluent or receiving water 280.00 260.00 240.00 IC25 (µg/L Copper) . 220.00 200.00 180.00 160.00 140.00 120.00 100.00 80.00 60.00 40.00 20.00 0.00 Test Dates FPL-SL 20218 Page 26 of 40

C o n t r o l C h a r t - II Coefficient of Variation for Standard Reference Toxicant Tests CHRONIC Mysidopsis bahia (Hydrosphere Research) 0.700 0.21 CV = ________ CV 0.650 The CV is less than or equal to the National 90th percentile. Comments (if needed): National 75th % 0.600 National 90th % QA Signature:________________________ Date:___________ 09/10/20 0.550 0.500 Coefficient of Variation (CV) . 0.450 0.400 0.350 0.300 0.250 0.200 0.150 0.100 0.050 0.000 Test Dates FPL-SL 20218 Page 27 of 40

REFERENCE TOXICANT LOG Last 20 Test: 7-day Chronic Species: Mysidopsis bahia Vendor: Hydrosphere Research Toxicant: Copper Sulfate (µg Cu / liter) Lower Upper National National N Date IC25 Mean S.D. 2 SD - 2 SD + 2S.D. CV Control Control 75th % 90th % Limit Limit 121 2/5/2019 159 142.42 31.17 62.35 80.07 204.77 0.22 0.32 0.40 80.07 204.77 122 3/5/2019 114 140.92 31.80 63.61 77.31 204.52 0.23 0.32 0.40 77.31 204.52 123 4/9/2019 160 141.72 32.08 64.17 77.55 205.88 0.23 0.32 0.40 77.55 205.88 124 4/30/2019 170 143.31 32.68 65.37 77.94 208.68 0.23 0.32 0.40 77.94 208.68 125 6/4/2019 158 145.70 31.86 63.71 81.99 209.41 0.22 0.32 0.40 81.99 209.41 126 7/3/2019 77 144.71 33.72 67.43 77.27 212.14 0.23 0.32 0.40 77.27 212.14 127 8/7/2019 166 146.61 33.80 67.59 79.02 214.20 0.23 0.32 0.40 79.02 214.20 128 9/3/2019 104 142.95 34.29 68.57 74.38 211.52 0.24 0.32 0.40 74.38 211.52 129 10/1/2019 98 140.38 35.64 71.28 69.10 211.65 0.25 0.32 0.40 69.10 211.65 130 11/5/2019 153 141.68 35.60 71.20 70.48 212.87 0.25 0.32 0.40 70.48 212.87 131 12/3/2019 127 140.55 35.68 71.36 69.19 211.91 0.25 0.32 0.40 69.19 211.91 132 12/31/2019 118 139.71 36.02 72.05 67.66 211.75 0.26 0.32 0.40 67.66 211.75 133 2/4/2020 111 134.19 31.02 62.04 72.15 196.23 0.23 0.32 0.40 72.15 196.23 134 3/3/2020 120 132.29 30.65 61.29 70.99 193.58 0.23 0.32 0.40 70.99 193.58 135 3/31/2020 101 133.60 28.55 57.10 76.50 190.70 0.21 0.32 0.40 76.50 190.70 136 5/5/2020 103 132.28 29.34 58.67 73.61 190.95 0.22 0.32 0.40 73.61 190.95 137 6/2/2020 141 131.83 29.12 58.23 73.59 190.06 0.22 0.32 0.40 73.59 190.06 138 6/30/2020 117 131.65 29.20 58.40 73.25 190.05 0.22 0.32 0.40 73.25 190.05 139 8/4/2020 141 129.76 27.13 54.26 75.50 184.01 0.21 0.32 0.40 75.50 184.01 140 9/1/2020 147 129.27 26.70 53.39 75.88 182.67 0.21 0.32 0.40 75.88 182.67 FPL-SL 20218 Page 28 of 40

Chronic Saltwater Method (EPA-821-R-02-014, Method 1007.0) ,,,;v :1\ll>, Hydrosphere ----"" research SRT: Survival, Growth & Fecundity r I

                                                                                                                                                                                                                         ==========

SRTfor lhe Month of (circle one): Control Water! I SSW Initiation Date: Tlnation D,re, I 'i'J v,l'N> lity" I Toxicant (desiccated): Cu2+ Jan Feb Mar Apr May Jun Jul Aug ct Nov Dec ID#: I see "water qua 500-mL plastic I SCockSolution(Concentration): I O .l- gm Cu / L1

• ter My,;d,p,;, bohia I c,a., : MS Test Vessel; I = =

Sp"l, I = == ::' ==: ::: :::: := :: ::: = m,, 1 10:s I A'" :z J TestVolume: I 200-mLperrep. I Test Concentration (Units): I gm Cu2+ / Liter I Biomass (original number, final drywoight ho v,lid Control io,!IJ.20*mglmviving obrimp) I 17, Males Immature M p Tare Wcight Total Weight Net Weight I 10,00001---*s', '0."'" ---- , Wt. /Shrimp Females 6 10.00001-------.si

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Photoperiod is 16-hours light and 8*hours dark, Iliuminiation is ambient (50 to 100 fled) FPL-SL 20218 Page 29 of 40

Hydrosphere Chronic Saltwater Method (EPA-1!21-R-02-014, Method 1007.0) research SRT: Survival, Growth & Fecundity I I

                                                                                                                                                                                                                                       '.:::==========

Control Water. SSW Initiation Date: Termination Date: SRTfor the Month of (circle one): Jan Feb Mar Apr May Jun Jul Augct Nov Dec I see "water quality" I Tol>icant (desiccated): Cu2+ I=;;;::=.:== ID#:

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FPL-SL 20218 Page 30 of 40 Versiou 2 (l3J00*DCF) . F:\Bcnchshects, Logs & Fanns\l) BenchShc,:ts\2) CHRONICINPDES (Pcnnittcd Test:;)\SRT\SRT.C-MS.Cu\SRT.MS. 07 .CSRD.Surv3.EPAI0 07.v2g

CETIS Analytical Report Report Date; 09 Sep-20 16:31 (p 1 of 1) Test Code: SEP20 MSC I 02-0189-4768 Mysidopsis 7-d Survival, Growth and Fecundity Test Hydrosphere Research Analysis ID: 11-6034-6414 Endpoint: Mean Dry Biomass-mg CETIS Version: CETISv1 .9.3 Analyzed: 09 Sep-20 16:31 Analysis: Linear Interpolation (ICPIN) Official Results: Yes Linear Interpolation Options X Transform Y Transform Seed Resamples Exp95% CL Method Linear Linear 1031108 200 Yes Two-Point Interpolation Test Acceptability Criteria TAC Limits Attribute Test Stat Lower Upper Overlap Decision Control Resp 0.3083 0.2 >> Yes Passes Criteria Point Estimates Level* pg/L 95% LCL 95%UCL IC25 147.4 133 162.1 Mean Dry Biomass-mg Summary Calculated Variate Isotonic Variate Conc-µg/L Code Count Mean Min Max Std Dev CV% %Effect Mean %Effect 0 D 8 0.3082 0.262 0.386 0.03888 12.61% 0.0% 0.3145 0.0% 31.25 8 0.3208 0.286 0.352 0.02181 6.80% -4.07% 0.3145 0.0% 62.5 8 0.3028 0.196 0.34 0.04578 15.12% 1.78% 0.3028 3.74% 125 8 0.273 0.228 0.332 0.04027 14.75% 11 .44% 0.273 13.2% 250 8 0.06625 0 0.098 0.03112 46.97% 78.51% 0.06625 78.94% 500 8 0 0 0 0 100.0% 0 100.0% Mean Dry Biomass-mg Detail Conc-µg/L Code Rep 1 Rep2 Rep3 Rep4 Reps Rep6 Rep7 Rep8 0 D 0.288 0.32 0.338 0.286 0.262 0.292 0.386 0.294 31.25 0.3 0.3383 0.322 0.286 0.336 0.308 0.324 0.352 62.5 0.334 0.34 0.302 0.308 0.32 0.326 0.196 0.296 125 0.332 0.32 0.258 0.228 0.294 0.282 0.234 0.236 250 0.076 0.072 0 0.094 0.046 0.098 0.074 0.07 500 *o 0 0 0 0 0 0 0 002-360-881-3 CETIS' v1 .9.3.0 QA:_ Cw 09/10/20 FPL-SL 20218 Page 31 of 40

~ Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1007.0) ~ ~research SRT: Water Quality I r SRT for the Month of (circle one): Initiation Date:! i// /}e, I Termination Date: j 1Nd),, I Jan Feb Mar Apr May Jun Jul Aug~~ Oct Nov Dec Toxicant (desiccated): Cu2 + Species: I Mysidopsis bahia I Stock Solution (Concentration): I 0.1-gm Cu 2+ I Liter I ID#, I )033 I Test Concentration (Units): I gm Cu 2+ / Liter I pH Dissolved Oxygen (mg/L) new I old new I old new I old new I old new I old new old new I old new old new old new old new old new old new old new old G~ rn~ ~ 0 I I I 2 I 3 I 4 I 5 I 6 I 7 0 I 2 3 4 5 6 7

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~ Hydrosphere                                                                                                                Chronic Saltwater Method (EPA-821-R-02-014, Method 1007.0)                                   ~
~research                                                                                                                                                                               SRT: Water Quality II              r SRT for the Month of (ci7cle one):                                                           Initiation Date:I      ti. II /fl'          I          Termination Date:     I j / ~ t.'J..D        I Jan Feb Mar Apr May Jun Jul Aug~Oct Nov Dec                                                              Toxicant (desiccated):     I                      Cu2 +

I Stock Solution (Concentration): I Species: I Mysidopsis bahia I 0.1-gm Cu2 + I Liter I I lo~3 I Test Concentration (Units}: I gm Cu2+ I Liter I B ID#, mLsof Salinity (%,) Temperature(°C) Stock/ )lglL Measured in each new sample and control Measured at the end of each 24-h exposure period 1.6-Litr.rs 4 5 6 7 0 I I I 2 I 3 I 4 I 5 I 6 I 7 0 I 2 3 I Control I I~ (1t4 ~~ ~~ ~~ ~oq ~~~ ~~ [g] ~ Iu. 1I:u.D I,µ:;, ~G-7 IZv/fl '.2ltt ?to GB (".:'.l

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Control Chart-I Control Limits for Standard Reference Toxicant Tests CHRONIC Menidia beryllina (performed by Hydrosphere Research) 300 290 85 IC25 = __________ µg/L AVG 280 The IC25 is within the control limits. IC25 270 Upper Control Limit Lower Control Limit 260 250 QA Signature:________________________ Date:___________ 09/10/20 240 Note: Dates with no corresponding IC25 data point, if present on chart, indicates an invalid test. 230 Note: If the control limit(s) for two or more consecutive tests are exceeded then the results must be explained here and the test must be repeated immediately. (EPA-821-R-02-014, Sections 4.16.4, page 15). Also, Section 220 4.16.5 of the same Method states that "...reference toxicant results should not be used as a de facto criterion for 210 rejection of individual effluent or receiving water tests." 200 190 IC25 (µg/L Copper) . 180 170 160 150 140 130 120 110 100 90 80 70 60 50 40 30 20 10 0 Test Dates FPL-SL 20218 Page 34 of 40

C o n t r o l C h a r t - II Coefficient of Variation for Standard Reference Toxicant Tests CHRONIC Menidia beryllina (performed by Hydrosphere Research) 0.800 0.27 CV = __________ CV 0.750 The CV is less than or equal to the National 90th percentile. Comments (if needed): National 75th % 0.700 National 90th % 0.650 QA Signature:________________________ Date:___________ 09/10/20 0.600 0.550 Coefficient of Variation (CV) . 0.500 0.450 0.400 0.350 0.300 0.250 0.200 0.150 0.100 Test Dates FPL-SL 20218 Page 35 of 40

REFERENCE TOXICANT LOG Last 20 Test: 7-day Chronic Species: Menidia beryllina Aquatic Indicators Toxicant: Copper Sulfate (µg Cu / liter) Lower Upper National National N DATE IC25 AVG S.D. 2 SD + 2 SD - 2SD CV Control Control 75th % 90th % Limit Limit 189 02/05/19 70 97.92 35.33 70.66 168.58 27.25 0.36 0.43 0.55 27.25 168.58 190 03/05/19 73 97.42 35.62 71.25 168.67 26.17 0.37 0.43 0.55 26.17 168.67 191 04/09/19 152 97.36 35.52 71.03 168.39 26.32 0.36 0.43 0.55 26.32 168.39 192 04/30/19 58 93.24 35.09 70.17 163.41 23.06 0.38 0.43 0.55 23.06 163.41 193 06/04/19 93 93.60 35.04 70.09 163.69 23.52 0.37 0.43 0.55 23.52 163.69 194 07/02/19 82 93.78 34.97 69.94 163.72 23.84 0.37 0.43 0.55 23.84 163.72 195 08/06/19 86 93.03 34.97 69.93 162.96 23.09 0.38 0.43 0.55 23.09 162.96 196 09/09/19 103 93.57 35.04 70.07 163.64 23.50 0.37 0.43 0.55 23.50 163.64 197 10/01/19 74 93.16 35.23 70.46 163.61 22.70 0.38 0.43 0.55 22.70 163.61 198 11/05/19 60 89.37 34.44 68.88 158.25 20.49 0.39 0.43 0.55 20.49 158.25 199 12/03/19 126 86.17 26.70 53.40 139.58 32.77 0.31 0.43 0.55 32.77 139.58 200 01/07/20 93 88.21 25.47 50.93 139.14 37.28 0.29 0.43 0.55 37.28 139.14 201 02/04/20 102 90.53 24.47 48.93 139.46 41.60 0.27 0.43 0.55 41.60 139.46 202 03/03/20 108 92.77 23.91 47.82 140.59 44.95 0.26 0.43 0.55 44.95 140.59 203 03/31/20 78 91.93 24.11 48.23 140.15 43.70 0.26 0.43 0.55 43.70 140.15 204 05/05/20 114 94.02 24.11 48.21 142.23 45.80 0.26 0.43 0.55 45.80 142.23 205 06/02/20 107 92.98 23.01 46.02 138.99 46.96 0.25 0.43 0.55 46.96 138.99 206 06/30/20 77 92.70 23.17 46.35 139.05 46.36 0.25 0.43 0.55 46.36 139.05 207 08/04/20 56 91.07 24.59 49.18 140.25 41.89 0.27 0.43 0.55 41.89 140.25 208 09/01/20 85 89.84 24.22 48.45 138.28 41.39 0.27 0.43 0.55 41.39 138.28 FPL-SL 20218 Page 36 of 40

Hydrosphere Chronic Saltwater Method (EPA-821-R-02-014, Method 1006.0) research SRT: Survival & Growth . SRTfor the Month of (circle one): Jan Feb Mar Apr May Jun Jul Aug Oct Nov Dec Control Water: ID#:

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FPL-SL 20218 Page 39 of 40 FPL-SL 20218 Page 40 of 40 3701 Northwest 98th Street Gainesville, Florida 32606-5004 Clean Water Act §316(b) Compliance Submittal 40 CFR 122.21(r)(2) through (13) St. Lucie Nuclear Power Plant Florida Power & Light Company FL0002208 April 2021 ECT No. 150595-D302 Complex Challenges . . . PRACTICAL SOLUTIONS

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents Section Page 1.0 Introduction and Executive Summary 1-1 1.1 Facility Description 1-1 1.2 Regulatory Background 1-4 1.3 Executive Summary 1-5 1.3.1 Proposed IM BTA 1-6 1.3.2 Information Relevant to Entrainment BTA 1-6 1.3.2.1 Summary of the Setting 1-8 1.3.2.2 Summary of Analyses 1-8 1.3.2.3 Entrainment BTA Factors that Must Be Considered 1-15 1.3.2.4 Entrainment BTA Factors that May Be Considered 1-23 1.3.2.5 Summary of Entrainment BTA and Recommendations 1-26 1.4 Conclusion 1-29 2.0 Source Water Physical Data 40 CFR 122.21(r)(2) 2-1 2.1 Description of Source Water Body 2-1 2.2 Characterization of Source Water Body 2-3 2.2.1 Hydrology 2-3 2.2.2 Geomorphology 2-6 2.2.3 Determination of Area of Influence 2-6 2.3 Locational Maps 2-8 3.0 Cooling Water Intake Structure Data 40 CFR 122.21(r)(3) 3-1 3.1 Intake Configuration 3-1 3.2 Intake Flow and Water Balance 3-4 3.3 Engineering Drawings of Intake 3-4 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 i

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 2 of 14) Section Page 4.0 Source Water Baseline Biological Characterization Data 40 CFR 122.21(r)(4) 4-1 4.1 List of Unavailable Biological Data 4-1 4.2 List of Species and Relative Abundance in the Vicinity of CWIS 4-1 4.2.1 National Coral Reef Monitoring Program 4-2 4.2.2 Prior Studies Performed at the St. Lucie Plant 4-2 4.2.2.1 1976 to 1983 Studies 4-6 4.2.2.2 Phase II Studies 4-8 4.2.2.3 EPU Studies 4-9 4.3 Identification of Species and Life Stages Susceptible to Impingement and Entrainment 4-10 4.4 Identification and Evaluation of Primary Growth Period 4-10 4.4.1 Reproduction 4-10 4.4.2 Larval Recruitment and Period of Peak Abundance 4-11 4.5 Data Representative of Seasonal and Daily Activities of Organisms in the Vicinity of CWIS 4-11 4.6 Identification of Threatened, Endangered, and Other Protected Species Susceptible to I and E at CWIS 4-20 4.6.1 Threatened or Endangered Species Occurrence 4-20 4.6.1.1 Federally Listed Species 4-20 4.6.1.2 State-Listed Species 4-26 4.6.1.3 Designated Critical Habitat 4-26 4.6.2 Likelihood of Impingement or Entrainment 4-26 4.6.2.1 West Indian Manatee 4-26 4.6.2.2 American Alligator 4-27 4.6.2.3 Sea Turtles 4-28 4.6.2.4 Atlantic Sturgeon 4-29 4.6.2.5 Smalltooth Sawfish 4-29 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 ii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 3 of 14) Section Page 4.6.2.6 Giant Manta Ray 4-30 4.6.2.7 Scalloped Hammerhead 4-31 4.6.2.8 Johnsons Seagrass 4-31 4.7 Documentation of Consultation with Services 4-32 5.0 Cooling Water System Data 40 CFR 122.21(r)(5) 5-1 5.1 Cooling Water System Description 5-1 5.2 Calculations and Supporting Data 5-2 5.2.1 Through-screen Velocity Calculations 5-2 5.2.2 Proportion of Source Water Body Withdrawn 5-3 5.3 Description of Existing Impingement and Entrainment Reduction Measures 5-4 6.0 Chosen Method(s) of Compliance with Impingement Mortality Standard 40 CFR 122.21(r)(6) 6-1 6.1 Introduction and Background 6-1 6.2 Evaluation of Options to Address the Impingement Mortality Standard of 40 CFR 125.94(c) 6-3 6.2.1 The Existing Intake is Largely Compliant with the Requirements of an Offshore Velocity Cap 6-4 6.2.2 Overview of FPLs Assessment of Exclusion Devices at the Velocity Cap 6-7 6.2.3 No Alternative Impingement Mortality BTA Measure is Reasonable 6-9 6.3 Proposed IM BTA Measure 6-10 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 iii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 4 of 14) Section Page 7.0 Previous Studies 40 CFR 122.21(r)(7) 7-1 7.1 1976 to 1983 Studies 7-1 7.2 Phase II Studies 7-2 8.0 Operational Status 40 CFR 122.21(r)(8) 8-1 8.1 Uprates 8-2 9.0 Entrainment Characterization Study 40 CFR 122.21(r)(9) 9-1 9.1 Entrainment Data Collection Method 9-1 9.2 Biological Entrainment Characterization 9-4 9.2.1 Species composition and abundance 9-4 9.2.2 Entrainment Size Classes 9-8 9.2.3 Water Quality Measurements 9-9 9.3 Analysis and Supporting Documentation 9-10 9.3.1 Annualized Entrainment under Actual Flow Conditions 9-10 9.3.2 Seasonal and Diel Variation in Entrainment 9-14 9.3.3 Entrainment Sizes 9-19 10.0 Technical Feasibility and Cost Evaluation Study 40 CFR 122.21(r)(10) 10-1 10.1 Introduction and Background 10-1 10.1.1 Plant 10-1 10.1.2 Final Rule Requirement 10-1 10.1.3 Evaluation Approach 10-3 10.1.4 Report Organization 10-4 10.1.5 Technologies and Measures to Be Assessed 10-5 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 iv

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 5 of 14) Section Page 10.1.5.1 Overall ApproachReduced Intake Flow 10-5 10.1.5.2 Overall ApproachFixed Screening Devices 10-6 10.1.5.3 Overall ApproachModification of TWS 10-7 10.1.6 Distinction Between Facility-level and Social Costs 10-10 10.1.7 Overview of Facility Cost Development 10-10 10.1.7.1 Approach to Cost Estimation and Relationship to Design Process 10-10 10.1.7.2 Level of Facility Cost Estimation 10-11 10.1.7.3 Engineering Cost Methodology 10-12 10.1.8 Process of Estimating Social Costs 10-15 10.1.8.1 Categories of Social Costs 10-15 10.1.8.2 Financial and Regulatory Environment 10-16 10.1.8.3 Market Environment 10-19 10.1.8.4 Methods for Social Cost Estimation 10-20 10.1.9 Remaining Life of the Plant 10-22 10.2 Existing Facility 10-23 10.2.1 Site and Surroundings Summary 10-23 10.2.2 Plant Intake Flows 10-23 10.2.3 Existing Cooling System 10-28 10.2.4 Cooling Water Intake Structure 10-29 10.3 Closed-cycle Recirculating Systems 10-32 10.3.1 Cooling Tower Principles 10-32 10.3.1.1 Method of heat transfer 10-32 10.3.1.2 Method of Air Flow 10-33 10.3.1.3 Direction of Air Flow 10-34 10.3.1.4 Shape and Arrangement 10-34 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 v

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 6 of 14) Section Page 10.3.2 Cooling Tower Terminology 10-34 10.3.2.1 Heat Load 10-35 10.3.2.2 Range 10-35 10.3.2.3 Approach 10-36 10.3.2.4 Drift 10-36 10.3.2.5 Blowdown 10-37 10.3.2.6 Cycles of Concentration 10-37 10.3.2.7 Makeup Water 10-37 10.3.2.8 Cooling Tower Fill 10-37 10.3.2.9 Recirculation and Interference 10-38 10.3.3 Review of Candidate Approaches 10-38 10.3.3.1 Mechanical Draft Cooling Towers 10-39 10.3.3.2 Natural Draft Cooling Towers 10-40 10.3.3.3 Plume-Abated Towers 10-42 10.3.3.4 Dry Cooling 10-45 10.3.3.5 Condenser Replacement 10-48 10.3.3.6 Selected Cooling Tower Type 10-49 10.4 Description of the Hypothetical Closed-cycle Cooling Tower 40 CFR 122.21(r)(10)(i)(A) 10-53 10.4.1 General Concept 10-53 10.4.2 MDCT Design Assumptions 10-54 10.4.2.1 Circulating Water Flow 10-55 10.4.2.2 Temperatures 10-56 10.4.2.3 Cooling Efficiency 10-56 10.4.2.4 Water Treatment Additives 10-57 10.4.3 Cooling Tower Sizing 10-58 10.4.4 Hypothetical Cooling Tower Location 40 CFR 122.21(r)(10)(i)(B) 10-59 10.4.5 Existing Site Conditions 10-61 10.4.6 Orientation of the Cooling Tower 10-61 10.4.7 Hypothetical Cooling Tower Location A 10-65 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 vi

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 7 of 14) Section Page 10.4.8 Alternate Hypothetical Cooling Tower Locations 10-69 10.4.9 Feasibility Discussion 10-69 10.4.9.1 Retrofit Feasibility 10-69 10.4.9.2 Construction Feasibility 10-74 10.4.9.3 Operational Feasibility 10-75 10.4.9.4 Facility Operational Feasibility Due to Technology Retrofit 10-77 10.4.9.5 Overall Feasibility of Cooling Towers 40 CFR 122.21(r)(10)(i)(D) 10-77 10.4.10 Permitting Requirements 10-77 10.4.11 Hypothetical Schedule 10-78 10.4.12 Cooling Tower Costs40 CFR 122.21(r)(10)(iii) 10-78 10.4.12.1 Capital Costs 10-78 10.4.12.2 Operations & Maintenance Costs 10-80 10.4.12.3 Environmental Mitigation Costs 40 CFR 122.21(r)(12) 10-82 10.4.12.4 Facility-Level Compliance Cost (Annual and NPV) 10-83 10.4.13 Uncertainty 10-88 10.5 Fine-Mesh and Narrow-Slot Screen Retrofit 40 CFR 122.21(r)(10)(i) 10-88 10.5.1 Narrow-slot Wedgewire Screens 10-91 10.5.1.1 Description of Hypothetical Wedgewire Arrangement 10-91 10.5.1.2 Feasibility Discussion 10-92 10.5.1.3 Summary of Feasibility 10-98 10.5.2 Fine-mesh Modified Traveling Water Screens and an Organism Return System 10-98 10.5.2.1 Technology Overview 10-98 10.5.2.2 Key Design Parameters 10-100 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 vii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 8 of 14) Section Page 10.5.2.3 Selected FMS Scenario 10-112 10.5.2.4 Uncertainty and Additional Studies 10-120 10.5.2.5 Compliance Costs 10-122 10.6 Alternate Cooling Water Sources40 CFR 122.21(r)(10)(i)(C) 10-125 10.6.1 Description of Plant Water Uses 10-125 10.6.1.1 Onsite Water Reuse 10-125 10.6.2 The Approach for Evaluation of Alternate Water Sources 10-126 10.6.2.1 Treated Grey Water Sources 10-127 10.6.2.2 Groundwater Sources 10-129 10.6.3 Alternate Cooling Water Source Feasibility 10-130 10.7 Other Technologies 10-130 10.7.1 Location of the Velocity Cap 10-130 10.7.2 Variable Speed Pumps 10-131 10.7.2.1 Description of Technology 10-131 10.7.2.2 Constraints to Flow Reduction 10-132 10.7.2.3 Cost and Feasibility Considerations of Variable Speed Pumps 10-134 10.7.2.4 Summary of Variable Speed Pumps 10-135 10.8 Summary of Findings 10-135 10.8.1 Summary of the Engineering Feasibility and Cost Findings 10-135 10.8.2 Technologies Retained for Biological Efficacy and Impacts Evaluations 10-137 10.8.3 Summary of Social Costs for Candidate Technologies 10-137 11.0 Benefits Valuation Study 40 CFR 122.21(r)(11) 11-1 11.1 Introduction and Background 11-1 11.2 Review of Methods 11-2 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 viii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 9 of 14) Section Page 11.2.1 Incremental Changes in Fish and Shellfish 11-2 11.2.1.1 Definition of Baseline Losses 11-2 11.2.1.2 Entrainment Under Baseline Conditions 11-3 11.2.1.3 Retrofit to Closed-cycle Cooling 11-3 11.2.1.4 Estimating the Efficacy of FMS 11-3 11.2.2 Basis for Estimates of Changes in Stock Size or Harvest Levels 11-8 11.2.3 Basis for Monetized Values Assigned to Changes in Stock Size or Harvest Levels 11-26 11.2.3.1 Recreational Benefits 11-29 11.2.3.2 Commercial Benefits 11-29 11.2.3.3 Nonuse Benefits 11-30 11.2.4 Discussion of Mitigation Efforts Made Prior to the Final Rule 11-31 11.2.5 Discussion of Other Benefits, with Quantification and Monetization where Possible 11-32 11.2.6 Discussion of Benefits from Reductions in Thermal Discharges, with Quantification and Monetization where Possible 11-35 11.3 Baseline Fishing Conditions 11-35 11.4 Technology-specific Findings 11-36 11.4.1 Without-entrainment Condition 11-36 11.4.1.1 Changes in Fish and Shellfish 11-36 11.4.1.2 Changes in Stocks and Harvest 11-37 11.4.1.3 Monetized Value of Changes in Stocks and Harvest 11-41 11.4.2 Closed-cycle Cooling 11-46 11.4.2.1 Changes in Fish and Shellfish 11-46 11.4.2.2 Changes in Stocks and Harvest 11-47 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 ix

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 10 of 14) Section Page 11.4.2.3 Monetized Value of Changes in Stocks and Harvest 11-47 11.4.2.4 Mitigation Effort Made Prior to Rule 11-51 11.4.2.5 Other Benefits 11-51 11.4.2.6 Reduction in Thermal Discharge 11-51 11.4.3 FMS 11-52 11.4.3.1 Changes in Fish and Shellfish 11-52 11.4.3.2 Changes in Stocks and Harvest 11-52 11.4.3.3 Monetized Value of Changes in Stocks and Harvest 11-52 11.4.3.4 Mitigation Effort Made Prior to Rule 11-56 11.4.3.5 Other Benefits 11-56 11.4.3.6 Reduction in Thermal Discharge 11-56 11.4.4 Summary of Monetized Benefits for Candidate Measures 11-56 11.5 Discussion of Uncertainty 11-57 11.5.1 Cumulative Effects of Uncertainty 11-59 12.0 Non-Water Quality, Environmental and Other Impact Study 40 CFR 122.21(r)(12) 12-1 12.1 Introduction and Background 12-1 12.1.1 Rule Requirement 12-1 12.1.2 Document Organization 12-2 12.1.3 Background on the Area 12-3 12.2 Technologies and Operational Measures Evaluated in 40 CFR 122.21(r)(10) and (12) 12-7 12.2.1 Technologies and Operational Measures Discussed in 40 CFR 122.21(r)(10) 12-7 12.2.2 Practical and Hypothetically Feasible Technologies and Operational Measures Discussed in 40 CFR 122.21(r)(10) 12-8 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 x

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 11 of 14) Section Page 12.3 Closed-cycle Recirculating System 12-8 12.3.1 Energy Consumption40 CFR 21(r)(12)(i) 12-8 12.3.1.1 Description 12-8 12.3.1.2 Quantification 12-9 12.3.1.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-13 12.3.1.4 Uncertainty 12-14 12.3.2 Air Pollutant Emissions, Environmental Impacts, and Human Health40 CFR 122.21(r)(12)(ii) 12-14 12.3.2.1 Description 12-14 12.3.2.2 Quantification 12-19 12.3.2.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-26 12.3.2.4 Uncertainty 12-27 12.3.3 Noise40 CFR 122.21(r)(12)(iii) 12-27 12.3.3.1 Description 12-27 12.3.3.2 Quantification 12-29 12.3.3.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-31 12.3.3.4 Uncertainty 12-31 12.3.4 Safety40 CFR 122.21(r)(12)(iv) 12-33 12.3.4.1 Description 12-33 12.3.4.2 Quantification 12-35 12.3.4.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-38 12.3.4.4 Uncertainty 12-38 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xi

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 12 of 14) Section Page 12.3.5 Plant Reliability40 CFR 122.21(r)(12) (v) 12-38 12.3.5.1 Description 12-38 12.3.5.2 Quantification 12-39 12.3.5.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-39 12.3.5.4 Uncertainty 12-39 12.3.6 Consumptive Water Use40 CFR 122.21(r)(12)(vi) 12-40 12.3.6.1 Description 12-40 12.3.6.2 Quantification 12-40 12.3.6.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-48 12.3.6.4 Uncertainty 12-48 12.4 Fine-Mesh Screens 12-48 12.4.1 Energy Consumption40 CFR 122.21(r)(12)(i) 12-48 12.4.1.1 Description 12-48 12.4.1.2 Quantification 12-49 12.4.1.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-49 12.4.1.4 Uncertainty 12-49 12.4.2 Air Pollutant Emissions, Environmental Impacts and Human Health40 CFR 122.21(r)(12)(ii) 12-50 12.4.2.1 Description 12-50 12.4.2.2 Quantification 12-50 12.4.2.3 Impact Mitigation Methods 40 CFR 122.21(r)(12)(vii) 12-50 12.4.2.4 Uncertainty 12-51 12.4.3 Noise40 CFR 122.21(r)(12) (iii) 12-51 12.4.4 Safety40 CFR 122.21(r)(12) (iv) 12-51 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 13 of 14) Section Page 12.4.5 Plant Reliability40 CFR 122.21(r)(12) (v) 12-51 12.4.6 Consumptive Water Use 12-53 12.5 Alternate Water Sources 12-53 12.6 Other Technologies 12-54 12.6.1 Offshore Velocity Caps 12-54 12.6.2 Variable Speed Pumps 12-54 12.7 Summary of Plant Findings 12-54 13.0 Peer Review 40 CFR 122.21(r)(13) 13-1 13.1 Selection of Peer Reviewers 13-1 13.2 Peer Review Process 13-2 13.3 Peer Review Results 13-3 13.3.1 Engineering Reports 13-4 13.3.2 Biology Reports 13-4 13.3.3 Economics Reports 13-4 13.3.4 Peer Review Response to FPL Comments 40 CFR 122.21(r)(10) through (12) 13-15 14.0 References 14-1 Appendices Appendix 10-A - Social Costs of Purchasing and Installing Entrainment Reduction Technologies Appendix 11-A Surrogate Taxa Life History Summary Appendix 11-B Entrainment Reduction Benefits Study: PSL Appendix 11-C Baseline Condition, Modeling Results Expressed as Benefits of Technology Appendix 11-D Closed-cycle Cooling, Modeling Results Expressed as Benefits of Technology Appendix 11-E Fine-mesh Screens, Modeling Results Expressed as Benefits of Technology Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xiii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table of Contents (Continued, Page 14 of 14) Section Page Appendix 12-A Estimated Headlosses and Pumping Requirements for MDCT Retrofit Appendix 12-B Estimated Energy Penalty due to MDCT Operation Appendix 12-C Estimated PM Emissions due to MDCT Retrofit Appendix 12-D Estimated CO2 Emissions due to MDCT Retrofit Appendix 12-E Estimated SO2 Emissions due to MDCT Retrofit Appendix 12-F Estimated NOx Emissions due to MDCT Retrofit Appendix 12-G Estimated Forced Evaporation from Existing Cooling Water System Appendix 12-H Estimated Evaporation Due to Hypothetical MDCT Appendix 12-I Estimated CO2 Emissions due to Fine-Mesh Screen Retrofit Appendix 12-J Estimated SO2 Emissions due to Fine-Mesh Screen Retrofit Appendix 12-K Estimated NOx Emissions due to Fine-Mesh Screen Retrofit Appendix 13 A Peer Reviewer Resumes Appendix 13 B Peer Reviewer Proposal Letter to FDEP Appendix 13 C FDEP Approval of Peer Reviewers Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xiv

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Tables Table Page 1-1 Increased Air Emissions Associated with Potential Retrofits at Projected CUR 1-19 1-2 Net Benefits of Entrainment Reduction Technologies at PSL 1-21 3-1 St. Lucie Plant Pumps and Capacities 3-3 3-2 AIF at PSL - 2015 to 2019 3-3 4-1 Taxa Recorded in National Coral Reef Monitoring (2014 and 2016, Miami to Martin County) 4-3 4-2 Species Common in Recent Impingement and Entrainment Studies at PSL 4-4 4-3 List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL 4-12 4-4 List of State- and Federally Listed Species in the Vicinity of the St. Lucie Plant 4-21 4-5 Protected Aquatic Species Range and Reproductive Habits in St. Lucie County 4-24 6-1 Review of the Final Rules BTA Alternatives for Impingement 6-1 6-2 Review of Existing Offshore Velocity Cap Performance Criteria 6-5 6-3 Review of Alternative Impingement Mortality BTA Approaches at PSL 6-11 8-1 PSL Capacity Utilization 8-2 9-1 Entrainment Sample Collection Dates 9-2 9-2 Fish and Invertebrate Taxa Collected in Entrainment Samples 9-5 9-3 2017-2018 Number of Fish and Invertebrates Counted by Size Class 9-9 9-4 Water Quality Measurements Collected During 2016 to 2017 Sampling 9-10 9-5 Average Monthly Cooling Water Flow 9-11 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xv

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Tables (Continued, Page 2 of 7) Table Page 9-6 Estimated Entrainment Totals for Dominant Fish and Invertebrates 9-13 9-7 Estimated Monthly Entrainment at Actual Flows Using Year 1 (2006 to 2007) Entrainment Data 9-15 9-8 Estimated Monthly Entrainment Using Year 2 (2017 to 2018) Entrainment Data 9-17 9-9 Size Classes for Dominant Fish - Annualized Flows 2017 to 2018 9-20 9-10 Size Classes for Dominant Invertebrates - Annualized Flows 2017 to 2018 9-21 10-1 Entrainment Reduction Technologies to be Assessed 10-8 10-2 AACE Costing Categories 10-12 10-3 PSL Pump Capacities 10-27 10-4 Pertinent Design Parameters from the Existing PSL Condenser Specifications 10-29 10-5 Comparison Matrix of Cooling Tower Types 10-50 10-6 Estimated Cooling Tower Water Use at PSL 10-55 10-7 Hypothetical Cooling Tower Sizing Information for Unit 1 and Unit 2 at PSL 10-58 10-8 Alternate Cooling Tower Locations Considered 10-72 10-9 Estimated Pump Requirements for Hypothetical CCRS Retrofit 10-74 10-10 Hypothetical Cooling Tower Implementation Schedule at PSL 10-79 10-11 Cooling Tower Capital Costs at PSL (2020 $ Millions) 10-81 10-12 Cooling Tower Annual Operations & Maintenance Costs at PSL (2020 $ Millions) 10-82 10-13 Capital Cost Outlay for MDCT Installation at PSL (2020 $ Millions) 10-84 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xvi

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Tables (Continued, Page 3 of 7) Table Page 10-14 MDCT O&M Costs at PSL (Excluding Electricity Costs and Assuming Full Utilization of the Plant) 10-85 10-15 Cost of Electricity for Operating MDCT and Assuming Full Utilization of the Plant 10-86 10-16 MDCT O&M Costs at PSL (Including Electricity) Assuming the Historic Utilization of PSL 10-87 10-17 Change in Screen Open Area and Effects on TSV 10-102 10-18 CWIS Expansion Necessary to Achieve a 1.3 ft/s TSV with Through-flow MTWS 10-109 10-19 New FMS Designed for a 1.3-ft/s Through-screen Velocity 10-123 10-20 Annual Costs to Operate and Maintain the Four Existing TWS if the Existing Intake is Determined to be BTA for Entrainment 10-124 10-21 Compliance Cost Summary for New FMS Designed for a 1.3-ft/s Through-screen Velocity with a Pumped Organism Return 10-125 10-22 Radial Distance for Alternate Water Sources at PSL 10-126 10-23 Grey Water Alternate Water Source Evaluation 10-129 10-24 Unit 1 Monthly Average CUR 10-133 10-25 Unit 2 Monthly Average CUR 10-133 10-26 Summary of Findings 10-136 10-27 Technologies Retained for Further Evaluation 10-137 10-28 Total Compliance and Social Costs of Feasible Technology Options at PSL 10-138 11-1 Average FMS Exclusion at Big Bend by Family and Life Stage 11-6 11-2 Average Family Survival of Organisms Excluded on FMS at Big Bend 11-7 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xvii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Tables (Continued, Page 4 of 7) Table Page 11-3 Summary of Estimated Rate of Live Return Used in the Assessment of Benefits of FMS at PSL 11-9 11-4 Biological Model Surrogate Taxa Life History Parameters 11-14 11-5 Modeling Surrogate Taxa 11-18 11-6 Years of Projection for Technology Retrofit 11-25 11-7 Annual Benefit as Reduction in Entrainment to All Life Stages of Fish and Shellfish If PSL Were to Shut Down the Cooling Water Intake 11-36 11-8 Modelled Annual Benefits of Baseline Condition 11-38 11-9 Summary of Recreational Social Benefits with Complete Elimination of Entrainment at PSL 11-44 11-10 Summary of Commercial Social Benefits as a Result of Complete Elimination of Entrainment at the St. Lucie Plant 11-45 11-11 Summary of Nonuse Benefits for 100-Percent Entrainment Reduction at PSL 11-46 11-12 Annual Benefit (as Reduction in Entrainment) that Would Result if the St. Lucie Plant Were to Retrofit with Closed-cycle Cooling 11-47 11-13 Modelled Annual Benefits of Retrofit to Closed-cycle Cooling 11-48 11-14 Summary of Recreational Social Benefits as a Result of the Reduction in Entrainment from Closed-cycle Cooling 11-50 11-15 Summary of Commercial Social Benefits as a Result of the Reduction in Entrainment from Closed-cycle Cooling 11-50 11-16 Summary of Nonuse Benefits as a Result of the Reduction in Entrainment from Closed-cycle Cooling 11-51 11-17 Annual Benefit (as Reduction in Entrainment) that Would Result if PSL Were to Retrofit with FMS 11-52 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xviii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Tables (Continued, Page 5 of 7) Table Page 11-18 Modelled Annual Benefits of Retrofit to FMS 11-53 11-19 Summary of Recreational Social Benefits as a Result of Reduction in Entrainment from FMS 11-54 11-20 Summary of Commercial Social Benefits as a Result of Reduction in Entrainment from FMS 11-54 11-21 Summary of Nonuse Benefits as a Result of Reduction in Entrainment from FMS 11-56 11-22 Summary of Recreational and Commercial Social Benefits of Entrainment Reduction Alternatives at the St. Lucie Plant 11-57 11-23 Uncertainties of Benefits Valuation Study 11-60 12-1 Energy Consumption Due to a Hypothetical MDCT Retrofit at PSL 12-12 12-2 PSL Variables for PM Emissions 12-20 12-3 Estimated PM Emissions Due to the Operation of the Hypothetical MDCT 12-21 12-4 Estimated CO2 Emissions Due to the Operation of the Hypothetical MDCT 12-24 12-5 Estimated CO2 Emissions from Non-baseload Plants during MDCT Tie-ins Related Downtime 12-24 12-6 Estimated SO2 Emissions Due to the Operation of the Hypothetical MDCT 12-25 12-7 Estimated SO2 Emissions from Non-baseload Plants during MDCT Tie-ins Related Downtime 12-25 12-8 Estimated NOx Emissions Due to the Operation of the Hypothetical MDCT 12-26 12-9 Estimated NOx Emissions from Non-baseload Plants during MDCT Tie-ins Related Downtime 12-26 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xix

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Tables (Continued, Page 6 of 7) Table Page 12-10 St. Lucie County Sound Limits by Receiving Land Use 12-29 12-11 Common Noise Levels 12-30 12-12 Noise Level Compared to Distance 12-30 12-13 Days with Recorded Fogging Conditions at Vero Beach, FL Between January 2015 and December 2019 12-37 12-14 Estimated Monthly Forced Evaporation at PSL Unit 1 Assuming Meteorological Conditions Between January 2015 and December 2019, and Maximum Thermal Discharge Rate for Design and Actual Flow Conditions 12-43 12-15 Estimated Monthly Forced Evaporation at PSL Unit 2 Assuming Meteorological Conditions Between January 2015 and December 2019, and Maximum Thermal Discharge Rate for Design and Actual Flow Conditions 12-43 12-16 Estimated MDCT Evaporation, Drift, Blowdown, and Make-up Rates for PSL 12-45 12-17 Hypothetical Increase in Evaporation if PSL were Converted to MDCT, Using Meteorological Conditions for the Period January 2015 through December 2019 12-46 12-18 Estimated Percent Reduction in Water Use 12-47 12-19 Increase in Energy Use Due to Fine-mesh Traveling Water Screen Retrofit 12-49 12-20 Estimated Increase in Emissions Due to the Hypothetical FMS Retrofit at PSL 12-50 12-21 Summary of Findings 12-55 12-22 Summary of Impacts for Hypothetical MDCT Implementation at PSL 12-56 12-23 Summary of Impacts from Installing a Hypothetical New Screen Structure with FM MTWS at PSL 12-57 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xx

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Tables (Continued, Page 7 of 7) Table Page 13-1 Engineering Peer Review Comments and Responses 13-5 13-2 Biology Peer Review Comments and Responses 13-9 13-3 Economics Peer Review Comments and Responses 13-11 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xxi

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Figures Figure Page 1-1 Regional Location of St. Lucie Nuclear Power Plant 1-2 1-2 Site Layout St. Lucie Nuclear Power Plant 1-3 1-3 Entrainment BTA Workflow 1-9 1-4 Comparison of Social Costs and Social Benefits at PSL 1-22 2-1 NOAA Nautical Chart Near St. Lucie Nuclear Power Plant 2-2 2-2 Ambient Temperature and Salinity from 2017-2018 Entrainment Sampling 2-4 2-3 Ambient Water Temperature Near PSL - September 2006 to March 2021 2-5 3-1 Water Balance 3-5 3-2 Configuration of PSLs Two 12-Ft Diameter Offshore Velocity Cap Intake Structures 3-6 3-3 Plan and Section Views of PSLs Three Offshore Velocity Cap Intakes Structures 3-7 3-4 PSL Cooling Water Intake System 3-8 3-5 PSL Traveling Screen Detail 3-9 3-6 PSL Traveling Screen Panel Detail 3-10 7-1 Seasonal Patterns in 2006-2007 PSL Entrainment Study Results 7-3 7-2 2006-2007 PSL Entrainment Species Composition 7-4 9-1 Average Monthly Cooling Water Flows 2015-2018 9-12 9-2 Dominant Taxa of Fish and Invertebrates in Entrainment 9-14 9-3 Estimated Monthly Entrainment using Year 1 (2006 to 2007) Entrainment Data 9-16 10-1 FPL Service Territory and Major Generating Assets 10-17 10-2 FPLs Generation Portfolio and Fuel Type 10-18 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xxii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Figures (Continued, Page 2 of 3) Figure Page 10-3 PSL Location Map 10-24 10-4 PSL Layout Map 10-25 10-5 Population Density Surrounding PSL 10-26 10-6 Various Views of the Intake Canal 10-31 10-7 Relationship Between Heat Load, Range, and Approach 10-35 10-8 Condenser and Cooling Tower Water Temperature Relationships 10-36 10-9 Cooling Tower Fill 10-38 10-10 Eliminating Visible Plume from a Hybrid Cooling Tower 10-42 10-11 Cross-section Schematic of a Parallel Path Wet/Dry Cooling Tower 10-43 10-12 Cross-section Schematic of a ClearSky' Plume-abated Cooling Tower by Marley 10-44 10-13 Aerial Photograph of Air-cooled Condenser (Direct Dry Cooling) 10-46 10-14 Schematic of Indirect Dry Cooling Tower 10-47 10-15 Topography Near PSL 10-62 10-16 Wind Summary for Vero Beach, Florida 10-64 10-17 Hypothetical Cooling Tower Location A for Units 1 and 2 at PSL 10-66 10-18 National Wetlands Inventory for PSL and Surrounding Areas. 10-70 10-19 Alternate Hypothetical Cooling Tower Locations for Units 1 and 2 at PSL 10-71 10-20 Hypothetical 2.0 mm Wedgewire Screen Layout at the PSL Intake 10-94 10-21 Conceptual Design for an Expanded Intake Designed for FMS with a 1.3-ft/s Through-screen Velocity - Plan 10-115 10-22 Construction Sequence for an Expanded Intake Designed for FMS with a 1.3-ft/s TSV 10-118 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xxiii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Figures (Continued, Page 3 of 3) Figure Page 10-23 Groundwater Wells and Wastewater Treatment Plants within a 5-Mile Radius of PSL 10-128 11-1 Calculation Methodology of FMS Benefits Summary 11-4 11-2 Overview of Methodology for Estimating the Benefits of Entrainment Reductions 11-28 11-3 Total (Direct and Indirect) Changes in Recreational Yield 11-39 11-4 Total (Direct and Indirect) Changes in Commercial Yield 11-40 11-5 St. Lucie Plant Life Fishery Yield Benefit Under Baseline Conditions 11-42 11-6 Change in Expected Recreational Catch per Trip by Taxa 11-43 11-7 Change in Welfare with a 100-Percent Reduction in Entrainment at the St. Lucie Plant 11-44 11-8 Change in Commercial Value with a 100-Percent Reduction in Entrainment at PSL 11-45 11-9 St. Lucie Plant Life Fishery Yield Benefits After Retrofit to CCRS 11-49 11-10 PSL Plant Life Fishery Yield Benefits After Retrofit to FMS 11-55 12-1 PSL Location Map 12-4 12-2 Population Density Surrounding PSL Mile Radius 12-5 12-3 Population Density Surrounding PSL Mile Radius 12-6 12-4 Area Potentially Impacted by PM Deposition 12-23 12-5 Hypothetical MDCT Location and Estimated Distances to Noise Thresholds 12-32 12-6 Road Network Surrounding PSL 12-34 12-7 Airports and Helipads Surrounding PSL 12-36 Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xxiv

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Acronyms and Abbreviations T change in temperature (delta)

 °C                             degree(s) Celsius
 °F                             degree(s) Fahrenheit AACE                           Association for the Advancement of Cost Engineering ACC                            air-cooled condenser(s)

AFB aquatic filter barrier AIF actual intake flow AOI area of influence bhp brake horsepower BPJ best professional judgment BTA best technology available Btu British thermal unit(s) C/R commercial and recreational CCRS closed-cycle recirculating cooling system(s) cf cubic foot (feet) CFR Code of Federal Regulations cfs cubic foot (feet) per second Clean Water Act Federal Water Pollution Control Act of 1972 CO2 carbon dioxide COC cycle(s) of concentration CUR capacity utilization rate CWA Clean Water Act Federal Water Pollution Control Act of 1972 CWIS cooling water intake structure(s) dB decibel(s) dBA A-weighted decibel(s) DE drift eliminator efficiency DIF design intake flow DOE U.S. Department of Energy EAC equivalent annual cost(s) ECT Environmental Consulting & Technology, Inc. EIA U.S. Energy Information Administration EPA U.S. Environmental Protection Agency EPRI Electric Power Research Institute EPU extended power uprate ESA Endangered Species Act of 1973 ESE east-southeast F.A.C. Florida Administrative Code FDEP Florida Department of Environmental Protection Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xxv

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Acronyms and Abbreviations (Continued, Page 2 of 3) Final Rule National Pollutant Discharge Elimination System, Final Regulations to Establish Requirements for Cooling Water Intake Structures at Existing Facilities and Amend Requirements at Phase I Facilities, 40 CFR Parts 122 and 125 FM MTWS fine mesh modified traveling water screen(s) FMS fine mesh screen(s) FPL Florida Power & Light Company FPSC Florida Public Service Commission FR Federal Register ft foot (feet) ft/s foot (feet) per second ft3 cubic foot (feet) FWC Florida Fisheries and Wildlife Conservation Commission FWRI Florida Fish & Wildlife Research Institute gpm gallon(s) per minute hp horsepower IM impingement mortality IPaC Information Planning and Conservation kg kilogram lb/hr pound(s) per hour lbm pound-mass m meter(s) MDCT mechanical draft cooling tower(s) mg/L milligram(s) per liter MGD million gallon(s) per day mi2 square mile(s) MLW mean low water mm millimeter(s) mph mile(s) per hour MTWS modified traveling water screen(s) MW megawatt(s) MWe megawatt(s) electric MWhr megawatt-hour(s) MWhr/yr megawatt hour(s) per year NAAQS National Ambient Air Quality Standards NDCT natural draft cooling tower(s) NOAA National Oceanic and Atmospheric Administration NOAA Fisheries NOAA National Marine Fisheries Service NOx nitrogen oxides NPDES National Pollutant Discharge Elimination System Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xxvi

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) List of Acronyms and Abbreviations (Continued, Page 3 of 3) NPV net present value NRC Nuclear Regulatory Commission NSR New Source Review (air emissions) O&M operation and maintenance Plant St. Lucie Nuclear Plant PM particulate matter PM10 particulate matter less than 10 microns in diameter PM2.5 particulate matter less than 2.5 microns in diameter POTW publicly owned treatment works ppm part(s) per million ppt part(s) per thousand PSD Prevention of Significant Deterioration (air emissions) psi pound(s) per square inch psia pound(s) per square inch, absolute pressure psig pound(s) per square inch gauge PSL St. Lucie Plant PV present value QCT cooling water circulation rate per unit RTO Regional Transmission Organization SO2 sulfur dioxide T&E threatened and endangered TDD Technical Development Document for the Final Section 316(b) Existing Facilities Rule TDH total dynamic head TDS total dissolved solids tpy ton(s) per year TS total dissolved solids and total suspended solids TSCT total solids in the circulating water TSS total suspended solids TSV through-screen/slot velocity USFWS U.S. Fish & Wildlife Service USGS U.S. Geological Survey VSP variable-speed pump(s) WAFR Wastewater Facility Regulation Facilities WMO World Meteorological Organization WNW west-northwest WWTP wastewater treatment plant(s) YOY young-of-year Y:\GDP\F1301\150595\316BR\FM.DOCX033121 xxvii

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 1.0 Introduction and Executive Summary Florida Power & Light Company (FPL) owns and operates the St. Lucie Nuclear Power Plant (PSL, St. Lucie Plant, or the Plant), located on Hutchinson Island in St. Lucie County, Florida (Figure 1-1). This report has been prepared to address the final Clean Water Act (CWA) Section 316(b) rule for existing facilities (Federal Register [FR], Volume 79, No. 158, Pages 48300-48439), known as the Final Rule, which was published August 15, 2014, by the U.S. Environmental Protection Agency (EPA). Specifically, this report addresses the 316(b) rules requirements for the renewal of the St. Lucie Plants National Pollutant Discharge Elimination System (NPDES) permit as described at Title 40, Parts 122.21(r)(2) through (13), of the Code of Federal Regulations (CFR). 1.1 Facility Description The St. Lucie Plant is located on Hutchinson Island in St. Lucie County south of Fort Pierce, Florida (Figure 1-1). The plant is a two-unit, baseload nuclear-powered electricity generating facility; Unit 1 and Unit 2 have generating capacities of 1,025-megawatts (MW) and 1,032-MW, respectively (FPL, 2019). Unit 1 was originally licensed on March 1, 1976; its license was renewed on October 2, 2003. Unit 2 was originally licensed on April 6, 1983; its license was also renewed in 2003 (NRC, 2018a; NRC, 2018b). Both units are designed as pressurized water reactors. PSL uses water withdrawn from the Atlantic Ocean for condenser cooling. PSL withdraws cooling water through three offshore intakes (located in Figure 1-2) equipped with velocity caps. The design intake flow of the facility is 1,487 MGD provided through eight circulating water pumps (1,404 MGD) and auxiliary equipment cooling pumps (four of six typically operate at 83 MGD). The Unit 1 and Unit 2 intake structures each have four bays equipped with fixed bar racks (periodically cleaned with bar rakes) and four traveling water screens with 3/8-inch mesh; debris washed from the screens is collected in a trash basket for disposal (FPL, 2005). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-1

N:\PRJ\FPL\316(b) Support\GIS\MXD\R Reports\Fig_1-1_StLucie.mxd jcassada 5/1/2019 4:17:32 PM Alabama I 0 0.5 1 Georgia Miles Florida

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St Lucie Nuclear Power Plant

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FIGURE 1-1. REGIONAL LOCATION OF ST LUCIE NUCLEAR POWER PLANT Sources: ESRI USGS National Map Topo Basemap, ECT 2019. 1-2

N:\PRJ\FPL\316(b) Support\GIS\MXD\R Reports\Fig1-2_StLucie.mxd jcassada 3/17/2021 10:42:40 AM I 0 600 1,200 Feet r se D iffu fu s er o rt rt Di f Y-P lti po Mu l a na eC Big Mud Creek ar g ch Atlantic Ocean Dis Unit 1 Emergency Water Intake Unit 2 Intake 1 Offshore Velocity Cap Intake 2 5" Mesh Barrier Net l a na k eC 8" Barrier Net a Int 9" Barrier Net Indian River Lagoon FIGURE 1-2. SITE LAYOUT ST LUCIE NUCLEAR POWER PLANT Sources: ESRI World Imagery, 2017. 1-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) After passage through the facility, cooling water is discharged through a discharge canal and then through two pipelines into the Atlantic Ocean. One discharge pipe extends approximately 1,250 ft from shore and has a Y shaped diffuser. The other extends approximately 1,930 ft from shore with an additional 1,416 ft of 58-port multiport diffuser (FPL, 2017). 1.2 Regulatory Background The St. Lucie Plant is subject to the Final Rule, which regulates the location, design, construction, and operation of cooling water intake structures (CWIS) at existing facilities that hold an NPDES permit, have a design intake flow (DIF) greater than 2 million gallons per day (MGD) from Waters of the United States, and use at least 25 percent of that water exclusively for cooling purposes. The Final Rule supersedes the Phase II rule, which was remanded in 2007, and the remanded existing facility portion of the previously promulgated Phase III rule. The Final Rule became effective on October 14, 2014. The Final Rule requires that each affected facility develop and submit to the NPDES Director (i.e., the Florida Department of Environmental Protection [FDEP]) specific submittals and supporting information to address compliance with the rules performance standards. Submittal of 316(b) rule-related reports is generally coordinated with the facilitys application to renew its NPDES permit. PSLs NPDES permit (FL0002208) expires on November 3, 2021, and the 316(b)-related materials are due with the application to renew the NPDES permit which is due 180 days before that date (i.e., May 7, 2021). Existing facilities with a DIF greater than 2 MGD are required to submit a set of documents with their NPDES application for renewal to establish compliance with the Final Rule, 40 CFR 122.21(r)(2) through (8):

• 40 CFR 122.21(r)(2), Source Water Physical Data
• 40 CFR 122.21(r)(3), Cooling Water Intake Structure Data
• 40 CFR 122.21(r)(4), Baseline Biological Characterization
• 40 CFR 122.21(r)(5), Cooling Water System Data
• 40 CFR 122.21(r)(6), Chosen Method of Compliance with Impingement Mortality Standard Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

• 40 CFR 122.21(r)(7), Entrainment Performance Studies
• 40 CFR 122.21(r)(8), Operational Status Facilities such as PSL, with an AIF greater than 125 MGD, are required to submit five additional documents to establish compliance with the Final Rule per 40 CFR 122.21(r)(9) through (13):
• 40 CFR 122.21(r)(9), Entrainment Characterization Study
• 40 CFR 122.21(r)(10), Comprehensive Technical Feasibility and Cost Evaluation Study
• 40 CFR 122.21(r)(11), Benefits Valuation Study
• 40 CFR 122.21(r)(12), Non-water Quality Environmental and Other Impacts Study
• 40 CFR 122.21(r)(13), Peer Review of (r)(10), (r)(11), and (r)(12)

The sections of the document are numbered consistent with the relevant sections of 40 CFR 122.21(r); for example, Section 2 addresses the Final Rules requirements as specified at 40 CFR 122.21(r)(2). 1.3 Executive Summary This section serves as the executive summary of the submittals prepared for PSL under 40 CFR 122.21(r)(2) through (13) of the Final Rule. These submittals constitute the balance of this document. Section 1.3.1 presents FPLs provisional recommendations for impingement mortality (IM) best technology available (BTA) under the Final Rule, recognizing that a final decision on IM BTA must follow the Directors determination of BTA for entrainment. Section 1.3.2 summarizes the information relevant to assessment of entrainment BTA on a best-professional-judgment (BPJ) basis, as required by the Final Rule. Section 1.3.2.1 includes a brief summary of the analyses performed. The Final Rule includes site-specific factors available to the NPDES Director in considering entrainment BTA on a BPJ basis. These factors include those FDEP must consider per at 40 CFR 125.98(f)(2), as summarized in Section 1.3.2.2, and those FDEP may consider per 40 CFR 125.98(f)(3), as summarized in Section 1.3.2.3. Section 1.3.2.4 presents a summary of the entrainment BTA findings and recommendations. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 1.3.1 Proposed IM BTA Section 6.0 presents the information required under 40 CFR 122.21(r)(6) of the Final Rule and documents FPLs use of an offshore velocity cap as defined in 40 CFR 125.92(v), except for the definitions inclusion of bar screens or other means to exclude marine mammals, sea turtles, and other large aquatic organisms. As discussed in Section 4.6, FPL has consulted with the Nuclear Regulatory Commission (NRC), the National Oceanic and Atmospheric Administrations National Marine Fisheries Service (NOAA Fisheries), and the Florida Fish and Wildlife Conservation Commission (FWC) on the issue of installing bar screens of various designs on the velocity caps. Included in this dialogue was an extensive study of potential configurations for the exclusion devices, from which FPL has concluded that any exclusion device places the animals at increased risk. The NRC has updated its proposed action to omit exclusion devices. NOAA Fisheries is in the process of updating its biological opinion, including assessing the need for exclusion devices. FPL anticipates achieving IM BTA based on its offshore velocity caps, consistent with 40 CFR 125.94(c)(4). This compliance approach only requires monitoring of intake flows at a minimum frequency of daily. 1.3.2 Information Relevant to Entrainment BTA This section summarizes the analyses intended by the Final Rule to support FDEP in its assessment of entrainment BTA under a site-specific BPJ review. While information presented under 40 CFR 122.21(r)(2) through (8) often provides useful perspective on the entrainment BTA, this summary focuses on those reports prepared under 40 CFR 122.21(r)(9) through (13):

• The rule at 40 CFR 122.21(r)(9) requires the collection and presentation of data sufficient to characterize facility entrainment; this is referred to as an entrainment characterization study. Section 9.0 of this document characterizes entrainment at PSL using site-specific biological data from the cooling water intake, and Section 11 expresses entrainment rates consistent with the configuration and operation of the plant.
• The rule at 40 CFR 122.21(r)(10) requires that facilities with actual intake flow rates greater than 125 MGD evaluate the feasibility of cooling towers, fine-mesh screens with a mesh size of 2-mm or smaller, and alternate water sources. For those technologies found feasible, the cost of installing and operating those technologies is calculated; this is Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 1-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) done from the perspective of the facility and the perspective of society (i.e., the costs to the facility are translated based on if and how those costs affect the broader society). Section 10 of this document provides that evaluation for PSL.

• The rule at 40 CFR 122.21(r)(11) requires that Each category of [social] benefits must be described narratively, and when possible, benefits should be quantified in physical or biological units and monetized using appropriate economic valuation methods.

Section 11 evaluates the social benefits of implementing potentially feasible entrainment reduction technologies at PSL.

• The rule at 40 CFR 122.21(r)(12) requires a discussion of the non-water quality environmental (and other) impacts for each technological alternative considered in the (r)(10) report. These include changes in facility efficiency, air emissions, noise, safety, reliability, and water consumption along with a discussion of efforts to mitigate any adverse changes. Section 12 discusses these changes, all of which represent social costs.
• Per rule requirements at 40 CFR 122.21(r)(13), Sections 10 through 12 were peer reviewed by third-party professionals approved by FDEP. The documentation of this process and its results are reported in Section 13.

The information required in 40 CFR 122.21(r)(9) through (12), together with comments and resolutions in 40 CFR 122.21(r)(13), are meant to provide all relevant information the Director needs to determine entrainment BTA for the facility. The explicit purpose of calculating the social costs and social benefits associated with each alternative cooling water technology is to determine if the adoption of a specific technology is likely to leave society better off (i.e., social benefits are likely to exceed social costs) or worse off (i.e., social costs are likely to exceed social benefits). As part of its entrainment BTA decision, the Final Rule specifically identifies in 40 CFR 125.98(f)(2) and (f)(3) eleven factors the Director must or may consider when determining entrainment BTA and provides the Director with discretion as to the relative weighting of each factor. Review of these factors is provided in this executive summary based upon information provided as part of Sections 9 through 12. The rule at 40 CFR 125.98(f)(4) gives the Director latitude on determining the site-specific entrainment BTA using BPJ as to whether existing design and operational measures are BTA or if benefits, impacts and costs Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 1-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) justify the installation of closed-cycle cooling towers, fine-mesh screens, or use of an alternate cooling water source. 1.3.2.1 Summary of the Setting PSL is located on the Atlantic coastline in St. Lucie County on Hutchinson Island, Jensen Beach, Florida. The facility consists of two nuclear-powered steam electric generating units (Units 1 and 2). PSL uses water from the Atlantic Ocean for once-through cooling water to remove heat from the steam condensers and for auxiliary cooling. Intake water for the cooling system flows by gravity from three offshore intake structures into the intake canal, passes through the condensers, and is discharged back to the ocean via a discharge canal and offshore diffusers. 1.3.2.2 Summary of Analyses This section summarizes the approach used in each of the entrainment BTA-related reports. In the subsequent sections of the executive summary, the findings are summarized in the context of the entrainment BTA decision factors the Final Rule provides to FDEP. Figure 1-3 presents the sequence of analyses used in assessing entrainment BTA under the Final Rule. The workflow includes integration of information on the configuration and operation of the facility, as well as measured rates of entrainment. The steps involved in assessing social costs, social benefits, and other environmental impacts are outlined along with the peer review process. These steps are summarized in the following paragraphs. Entrainment Characterization Study40 CFR 122.21(r)(9) Following review by FDEP and FWC staff, FDEP approved the Plan of Study for 316(b) Implementation at the St. Lucie Power Plant (FPL, 2017). The Plan of Study included use of entrainment data collected between January 2006 to October 2007 under the Phase II rule to satisfy part of the Final Rules two-year entrainment data requirement. These data were supplemented by an additional year of entrainment sampling collected by FPL at PSL from November 2017 to November 2018. Section 9.0 summarizes the entrainment characterization. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-8

1-9 FIGURE 1-3. ENTRAINMENT BTA WORKFLOW Source: ECT, 2021

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Comprehensive Technical Feasibility and Cost Evaluation Study40 CFR 122.21(r)(10) The Final Rule requires the feasibility and costs of alternative entrainment measures be considered. This includes the potential quantification of the social costs of alternative entrainment control measures be estimated and compared to potential social benefits. This estimation proceeded in three steps:

• The set of potential entrainment mitigation measures was identified, and the most cost-effective 1 configuration of the measure was selected from the available options.
• Based on a conceptual design that considers site-specific constraints, the costs to the facility for retrofitting each feasible technology were estimated. These costs include those associated with construction, permitting, and increased operation and maintenance associated with the measure. Loss of generation output was also calculated based on, as appropriate for the technology, increased parasitic load, loss of generation efficiency, outage of the unit with construction, and potential for deratings.
• Social costs were estimated based on how increased facility costs are likely to be distributed to society over the life of the technology. Estimated social costs include those associated with increased price of power when lost generation must be replaced with a higher-priced source(s). Such social costs were estimated using FPLs existing power system model used to support system planning.

As required by the Final Rule, FPL considered the feasibility and costs of three potential technologies that could reduce rates of entrainment: (a) retrofit to closed-cycle cooling, (b) use of fine-mesh screens (FMS) at the intake, and (c) use of alternative water supplies to replace some or all of the water used in the once-through cooling system. FPL also considered entrainment protection provided by installation and use of variable-speed pumps (VSP) to reduce the rate of water withdrawal and, therefore, entrainment. In discussions with FPL, FDEP did not identify other entrainment measures that should be considered. Section 10.0 also provides a more general review of the available approaches to reduction of entrainment and, for each of the technologies, summarizes available alternatives. 1 In the context of the Final Rule and this document, most cost-effective means the lowest cost option technically feasible that yields a reliable and significant rate of entrainment reduction. The approach to this assessment (e.g., capturing relevant benefits while neglecting some costs) is discussed further in Section 10.0. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) No alternative water supply was found to provide a reasonable alternative to replace even a small fraction of intake flow requirements. Use of VSP was found to provide minimal potential for reduction in entrainment rates given PSLs high-capacity utilization. For the other potential measures, a conceptual design, including location on the facility, facility costs, and schedule for design, permitting, and construction, was developed. The net present value (NPV) of the social costs of each technology was also developed based on the estimated start of the technologies operation and retirement date for the facility. Section 10.0 addresses each of the requirements of the Final Rule at 40 CFR 122.21(r)(10). For potential retrofit with closed-cycle cooling, the rate of water use reduction was estimated as a means of estimating reductions in entrainment in Section 11.0. The conceptual design for each measure was used to estimate any other environmental effects as described in Section 12.0. Benefits Valuation Study40 CFR 122.21(r)(11) The goal of this section is the estimation of social benefits that would derive from additional controls on entrainment at PSL. As with the estimation of social costs, this effort proceeds by way of several steps:

• The total rate of entrainment was estimated for the current cooling water system and its operation at PSL. To illustrate the interannual variation in entrainment rates, the Phase II entrainment data and the recent sampling results under the Final Rule were considered separately. The rates were adjusted to reflect monthly flows for the facility for the combined units.
• Estimated decreases in the rates of entrainment for each technology were calculated. For potential retrofit with closed-cycle cooling, reduction in entrainment was assumed to be equal to the reduction in cooling water flow. For FMS, the separate rates of organism exclusion and post-exclusion survival were estimated based on site-specific measurements of entrained organisms as well as empirical data available from historical studies at Tampa Electrics Big Bend Units 3 and 4. Separate empirical data were available for a variety of fish and shellfish taxa, as well as different life stages for the taxa. While the available data from Big Bend included most of the organisms entrained at PSL, in no case was any entrained organism excluded from the analysis. Instead, reasonable surrogates were selected.

Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-11

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

• Various rates of entrainment, including baseline and mitigated, were used to model the effects on commercial and recreational (C/R) harvest. This estimation was based on commonly applied population models to estimate the effects of direct reductions in entrainment and impingement of C/R species, as well as the effects of loss of forage associated with the entrainment of other finfish and shellfish. Changes in harvest were considered on a numerical and mass basis. Parameters used in population modeling were derived from the literature and reflected the fishery of St. Lucie County and the adjacent Atlantic Ocean and the nature of its C/R use. Uncertainty in selection of model parameters was considered and discussed.
• Uncertainties in the biological assessments (i.e., technology effectiveness and biological modeling) were considered including alternative approaches and their potential effect on the social benefit. Generally, uncertainty was addressed in a fashion that resulted in a likely over-estimate of social benefits. For example, an important assumption associated with considerable uncertainty is the discounting of any survival by entrained organisms.
• For each entrainment scenario (baseline and potential reductions), change in social benefit associated with changes in C/R harvest were estimated using a random utility model calibrated to the use of the local fishery. This change is termed a use benefit and was calculated over the life of the technology and beyond until any effects of the technology have dissipated. The total benefit over that period was expressed as an NPV.
• As described in Section 4.6, the CWIS at PSL has recorded interactions with federally listed species: sea turtles, giant manta rays, smalltooth sawfish, and scalloped hammerhead sharks. The interactions include entry into the intake canal of many sea turtles each year. The intake canal utilizes barrier nets designed to contain and reduce the residence time of sea turtles in the intake canal. The intake canal is monitored and sea turtles are captured and assessed, as needed. After assessment they are either released to the ocean or brought to a rehabilitation center. Two giant manta rays and four smalltooth sawfish were also captured in the intake canal in the last several years and returned to the ocean. Encounters with scalloped hammerheads have been rare, with one removed from the intake canal in 1997 and sent to the Florida Aquarium and one captured live in 2012 and returned to the ocean. This rescue and release management regime has been in place for several years under an incidental take statement (ITS) issued by NOAA Fisheries.

Y:\GDP\F1301\150595\316BR\1-9.DOCX040121 1-12

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) FPL is in the process of working with NOAA Fisheries to assess installation of large animal exclusion devices or other improvements to the velocity caps to be used in conjunction with the current rescue and release program. FPL has tested a means of excluding large animals and has concluded that any such devices would increase the risk to the animals and reduce the potential for rehabilitation of animals injured prior to interaction with the intake. FPL has recommended to the NRC and NOAA Fisheries that large animal exclusion devices not be included at the velocity caps but that other improvements to the intake pipe where it transitions from vertical to horizontal may be made. The NRC has updated its proposed action to omit exclusion devices. NOAA Fisheries is in the process of updating its biological opinion, including assessing the need for exclusion devices. Measures to address interactions of sea turtles, giant manta rays, smalltooth sawfish, and scalloped hammerheads at the offshore velocity cap and within the intake canal do not include those considered among the Final Rules approaches to entrainment BTA. Any such measures would be implemented under the Endangered Species Act through an amended ITS and following an updated biological opinion by NOAA Fisheries. Therefore, the baseline condition and any entrainment BTA approaches are the same relative to effects to these species, eliminating the need to quantify the potential social benefits of the entrainment BTA measures.

• Nonuse benefits were also estimated based on EPA survey data on perception of the value of protected but unused fish and shellfish. Nonuse benefits were calculated for three separate regions: St. Lucie County, the southeastern United States, and the United States as a whole. Nonuse benefits were also expressed as an NPV to facilitate combining with use benefits and comparing with social costs.

Non-water Quality Environmental and Other Impacts Study40 CFR 122.21(r)(12) The report under 40 CFR 122.21(r)(12) calls for assessment of other environmental impacts, including estimates of the level of impact. It also calls for discussion of reasonable efforts to mitigate the impacts. Section 12.0 describes the following changes associated with the potential entrainment mitigation measures in the order they are presented in the Final Rule: Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 1-13

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

• Estimates of changes to energy consumption associated with parasitic load, loss of generation efficiency, and downtime associated with construction
• Estimates of increases in air emissions
• Estimates of changes in noise generation
• Discussion of potential impacts to safety
• Discussion of potential impacts to facility reliability
• Estimation of changes in water consumption
• Discussion of efforts to mitigate these adverse effects Sections 10.0 and 12.0 were developed with a high degree of coordination. Such coordination is necessary because the conceptual approach to each technology is defined in Section 10.0, and that approach (e.g., nature of the cooling towers, their position, etc.) has an important effect on the level of impacts. As importantly, the quantitative engineering and costing analyses performed in Section 10.0 have been developed to provide estimates of the level of impacts as well as incorporate reasonable estimates for their mitigation. For example, changes in energy consumption and production were estimated in Section 10.0 as part of the conceptual design and were used to estimate both facility and social costs. Similarly, reasonable measures to ensure facility reliability with the potential installation of FMS (e.g., expansion of screen area; two sets of MTWS in series) and potential retrofit to closed-cycle cooling (e.g., selection of critical wet bulb temperature for cooling tower design) were incorporated into the costing exercise in Section 10.0.

Therefore, in many cases, Section 12.0 summarizes analyses performed in Section 10.0, while in other cases (e.g., changes in water consumption and noise), analyses independent of those in Section 10.0 are presented. Peer Review40 CFR 122.21(r)(13) The reports prepared under 40 CFR 122.21(r)(10) through (12) were peer-reviewed by external experts as required by 40 CFR 122.21(r)(13). Three peer reviewers were retained, consisting of qualified experts in power plant engineering, aquatic biology, and resource economics. The qualifications of the peer reviewers were submitted to FDEP for review and approval and were subsequently approved by FDEP. Consistent with the Final Rules requirements, Section 13.0 provides the peer reviewers qualifications. Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 1-14

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Peer review of FPLs approach to the BTA analyses under 40 CFR 122.21(r)(9) through (12) was sought on the draft final documents as required by the Final Rule. The Final Rule requires FPL to provide an explanation for any significant reviewer comments not accepted. FPL addressed all comments by the reviewers with changes in the analyses and/or summary text. Section 13.0 provides the full set of peer reviewers comments along with FPLs responses. The peer reviewers each concurred that FPLs responses addressed their comments as documented in Section 13.0. 1.3.2.3 Entrainment BTA Factors that Must Be Considered In this section, factors the Final Rule defines as required for FDEP to assess entrainment BTA on a site-specific BPJ basis, per 40 CFR 125.98(f)(2), are considered. While each factor is considered separately for both potential mitigation measures, in the interest of brevity, references to the relevant section(s) of the report are provided along with a summary of findings relative to that factor. Factors that the Final Rule indicates may be considered by FDEP are presented in Section 1.3.2.4. Based on the review of the findings presented in Sections 10.0 through 12.0, FPL believes the net social benefit (i.e., social benefits minus social costs) is the best and most complete factor for assessing potential retrofits to mitigate entrainment. This conclusion is based on several considerations:

• Some factors (e.g., thermal discharge effects, impacts on water consumption, and availability of alternative water supplies) are not significant at PSL.
• Estimation of both social costs and social benefits integrate several other decision factors available to FDEP. For example, the social costs of potential retrofits directly incorporate:

o Land availability. o Remaining useful plant life. o Mitigation of potential impacts to facility reliability.

• Similarly, social benefits directly incorporate:

o Numbers and types of organisms entrained. o Remaining useful plant life. o Entrainment impacts on the water body. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-15

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

• The rule considers the social costs and social benefits, ensuring that the assessment focuses on the parties affected by the technology costs (e.g., the rate-payers) and benefits (e.g., those that fish in the vicinity of PSL).
• Monetizing social costs and social benefits facilitates their comparison on a common basis. Consistent with this policy objective, FPL has carefully estimated all social benefits (e.g., all entrained organisms are considered as affecting C/R fisheries either directly or indirectly; nonuse benefits are quantified) while omitting monetization of some social costs that are uncertain and/or difficult to estimate (e.g., monetization of the health effects of increased air emissions, noise, and potential safety effects). Therefore, estimates of net social benefits should be viewed as a likely overestimation.

Numbers and Types of Entrained Organisms40 CFR 125.98(f)(2)(i) Key Document Section(s)Section 11.2.1 for anticipated rates of entrainment; Section 9.0 and appendices for methods and background on entrained species. Section 9.3 presents the number and type of entrained organisms based on annualized, flow-adjusted counts of entrained organisms during the 2 years of sampling. This presentation is based on the actual plant flows and observed rates of entrainment during each study year and included enumeration of entrained finfish and shellfish. The rates of entrainment reflect the highly productive nature of the coastal waters and are typical of rates observed at other coastal plants in Florida as well as the density of entrainable organisms in those waters (see Section 9.2.1). An estimated 4.7 billion fish life stages and 64.4 billion invertebrates were entrained using the Year 1 (October 2006 to October 2007) sampling results, and 16.1 billion fish life stages and 121.3 billion invertebrates were entrained using the Year 2 (2017 to 2018) sampling results. Unidentified eggs were the most commonly entrained fish in both years; 55.1 percent for Year 1 and 74.6 percent for Year 2. Brachyuran crabs were the most commonly entrained invertebrates in both years, with 70.4 percent in Year 1 and 62.0 percent in Year 2. Importantly, no federally or state-listed species have been subject to entrainment. The average total annual foregone fishery yield for the two study years is estimated as 71,613 kilograms (kg). This number represents the annual total loss of biomass from the C/R Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-16

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) fisheries due to entrainment losses, both direct and production foregone from forage, from the operation of PSL. This estimate is designed to be an overestimation of these losses by employment of several modeling assumptions (i.e., entrainment results in 100 percent lethality, all entrainment losses affect C/R taxa and no others, and selection of various parameters to maximize the estimated effects on stocks). For perspective, the annual commercial finfish landings for St. Lucie County over the five-year period 2015 to 2019 ranged from 1,105,640 to 1,282,465 kg, or an average of 1,202,944 kg. Thus, the foregone fishery yield because of the estimated entrainment rates at PSL represents approximately 5.9 percent of the 2015-2019 average annual commercial yield of St. Lucie County. In addition to the estimated annual commercial harvest, the recreational landings in St. Lucie County, although not specifically quantified at this level, are likely to be substantially higher (based on Florida east coast data [NOAA Fisheries, 2020]) than the commercial landings for many species including black drum and spot. Therefore, the estimated losses from PSL are likely to be a very small fraction of the combined harvest from commercial and recreational fishing. The potential for reduction in entrainment with the potential installation of entrainment mitigation measures, neglecting entrainment survival, has been quantified for the two technologies retained for assessment. Potential retrofit to closed-cycle cooling was estimated to reduce entrainment by 73.4 percent for Unit 1 and 74.1 percent for Unit 2. Reduction of entrainment by year-round deployment of FMS (i.e., the product of the rate of exclusion and post-exclusion survival) was estimated to be approximately 38 to 40 percent for finfish and 94 and 83 percent for shellfish for study Years 1 and 2, respectively. These rates were used in the quantitative estimation of the social benefits of potential entrainment measures. The social costs and benefits of these options are compared in the following, but neither technology results in a significant social benefit, i.e., the present value for both is less than $1.29M. 2 In conclusion, FPL does not believe the number and type of organisms entrained provide a compelling basis under the Final Rule to evaluate additional entrainment measures. Importantly, no federally or state-listed species have been subject to entrainment. In addition, the rates of 2 Maximum total present value of social benefit for each of the technologies evaluated (see Table 1-2). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-17

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) entrainment are not believed to affect the fishery of the coastal waters off PSL. As noted previously, FPL believes quantification of the social benefits is the best means to evaluate the number and nature of entrained organisms in the context of the Final Rules goals. Impacts of Changes in Emissions of Particulates and Other Pollutants 40 CFR 125.98(f)(2)(ii) Key Document Section(s)Cooling Towers: Section 12.3.2; FMS: Section 12.4.2 The entrainment BTA assessment considers changes in pollutant emissions to the atmosphere in Section 12.0. The increase in emissions is associated with two separate factors: (1) particulate emissions from the cooling tower associated with using saltwater for make-up water, and (2) loss of generation capacity associated with parasitic loads and loss of efficiency and the resulting need to replace that power with other generator(s). Table 1-1 provides estimates of increased emissions for a closed-cycle recirculating cooling system (CCRS) conversion and FMS assuming PSL continues to operate at approximately the same capacity factor (89 percent for Unit 1 and 95 percent for Unit 2). Emissions of particulates, dominated by salts from the ocean water used as cooling tower make-up, would result from the use of mechanical draft cooling towers (MDCT) at PSL. Particulate emissions are estimated to travel approximately 3,600 ft from the saltwater cooling towers and have the potential to result in damage to vegetation and infrastructure both onsite (e.g., electrical switchyards) and offsite. Emissions associated with replacing lost generation would be dominated by carbon dioxide with far lower amounts of sulfur oxides, nitrogen oxides, and particulate matter. These increased emissions could occur on the site or at other fossil fuel-fired generators in the area. The social costs of these increased emissions were not monetized because of various uncertainties; therefore, the social benefits are likely overestimated. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-18

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 1-1. Increased Air Emissions Associated with Potential Retrofits at Projected CUR CCRS FMS Technology (tpy) (tpy) Unit 1 Unit 2 Units 1 & 2 Total PM* 226.0 to 242.4 240.8 to 258.3

• PM10* 91.5 to 99.5 97.5 to 106.1
• PM2.5* 24.2 to 26.6 25.8 to 28.4
• Estimated Increase in CO2 - operations 122,904 129,730 2,286 Estimated Increase in CO2 during tie-in period 619,482 656,168 N/A Estimated Increase in SO2 - operations 13.3 14.0 0.24 Estimated Increase in SO2 during tie-in period 67.0 70.9 N/A Estimated Increase in NOx - operations 39.9 42.1 0.74 Estimated Increase in NOx during tie-in period 200.9 212.8 N/A
• Too small to be quantified meaningfully. PM emissions due to replacement energy produced by low-emissions combined-cycle plants would likely be small. PM emissions presented here would be direct emissions from MDCT.

Note: N/A = not applicable, as retrofit can be undertaken without taking PSL offline. Source: ASA, 2021. Land Availability40 CFR 125.98(f)(2)(iii) Key Document Section(s)Cooling Towers: Section 10.3.3 for review of candidate technologies, Section 10.4.2 for cooling tower sizing, and Section 10.4.3 for assessment of potential locations; FMS: Section 10.5 The availability of space for infrastructure was considered in the assessment of entrainment BTA. The PSL site itself is highly constrained, making actual cooling tower installation and operation at any location challenging. While such a retrofit is believed to be feasible, the constrained site results in higher estimated installation costs, which affect the estimated social costs. Space constraints also exist for FMS as the potential for adding additional screens in front of the existing screens is limited due to the geometry of the intakes. However, an alternate configuration of placing FMS at the entrance to the intake canal was evaluated. Remaining Useful Plant Life40 CFR 125.98(f)(2)(iv) Key Document Section(s)Section 10.1.8 FPL manages its generation fleet in an integrated fashion, including maintaining estimates of remaining facility life. Unit 1s license expires on March 1, 2036, while Unit 2s license expires Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-19

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) on April 6, 2043. The potential social costs and social benefits were both modeled assuming the technology would be installed in a reasonable time frame and would remain in operation through that date of plant closure. Both social costs and social benefits were expressed as NPV based on implementation, operation, and retirement time frames. Social costs were estimated using FPLs power system model. 3 Not only does this model consider the facilitys retirement date, it also reflects the best available estimates of the relative dispatch priority of PSL and the other generation assets based on their costs of generation, capacity, etc. Therefore, the social costs reflect the estimated rate of facility use in the future as well as the plants lifetime (to the extent presently known; future market conditions could change future utilization rates). Quantitative and Qualitative Social Benefits and Social Costs40 CFR 125.98(f)(2)(v) Key Document Section(s)Social Costs: Section 10.1.7 for description of the process, Appendix 10-A for description of the social costing methods, Section 10.8.3 for the summary of results for cooling towers; Social Benefits: Section 11.2 for an overview of the methods employed, Section 11.4.4 for a summary of the monetized social benefits, Appendix 11-C for a review of the economics methods applied and their results. FPL has developed peer-reviewed estimates of both social costs and social benefits consistent with the Final Rules requirements. The estimation of social benefits included both use benefits (i.e., potential changes in C/R fishing stocks and their attending economic effects), as well as nonuse benefits. FPL believes considering the net social benefits of a potential activity is a sound means of deciding whether the activity represents entrainment BTA on a BPJ basis. As noted in Section 1.3.2, the Final Rule allows FDEP the discretion to reject otherwise available entrainment controls if the costs of the controls are not justified by their associated benefits (taking into account monetized, quantified, and qualitative benefits), and the other factors discussed in the Final Rule. In the event the net social benefits of a proposed set of activities are 3 The power system model is used to forecast future electricity demand, including seasonal variation, as well as match that demand to available sources of generation. As appropriate to the source of generation, the model integrates data on the efficiency, costs, fuel type, and rate of consumption and emissions. The model also incorporates constraints on transmission infrastructure that affect the priority of generation. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-20

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) negative (i.e., social costs outweigh social benefits 4), there is no reasonable justification for that activity to represent entrainment BTA. On the other hand, if the net social benefit is positive, the approach that provides for the greatest net social benefit or the greatest marginal net social benefit could be considered entrainment BTA (subject to confirmation from detailed engineering and potentially through pilot studies). The monetized social costs and social benefits associated with the candidate entrainment reduction measures estimated in Sections 9.0 through 13.0 are presented in Table 1-2 and illustrated in Figure 1-4. The figure compares the approaches to BTA to provide context for determining the maximum entrainment reduction warranted under the Final Rules site-specific entrainment evaluation. Specifically, the Final Rule requires a site-specific BTA evaluation to determine the maximum entrainment reduction warranted based, in part, on the social costs and social benefits of each technology. The vertical axis in the top portion of Figure 1-4 presents the total social costs, total social benefits, and net social benefits (total social benefits minus total social costs) of each compliance option, as arrayed on the horizontal axis. Note that the vertical axis has two breaks each above and below the origin to accommodate the discrepancy between some social costs and social benefits of two to three orders of magnitude. The total social costs (in black) are greater than the social benefits (in green) for each of the entrainment compliance options. The net social benefit is represented by a red bar which is negative for all of the options presented. Table 1-2. Net Benefits of Entrainment Reduction Technologies at PSL Entrainment Sample Year Compliance Alternative Total Social Cost* Total Social Benefits* Net Benefits Fine mesh screens $98.72M $1.15M -$97.56M Year 1 Closed-cycle cooling retrofit $1,221.59M $1.29M -$1,220.29M Fine mesh screens $98.72M $0.79M $-97.92M Year 2 Closed-cycle cooling retrofit $1,221.59M $1.02M -$1,220.57M Note: Numbers may not sum because of rounding.

• Social costs and social benefits are presented in 2020 dollars using a 3-percent discount rate. Expression of social costs and benefits using a 7-percent discount rate is presented in Sections 10 and 11.

Source: Veritas, 2021. 4 It is important to note that the calculation of the social costs and, therefore, the net social benefits, recognizes the cost of the technologies being considered are borne by the rate-payer in the form of higher electricity costs. Y:\GDP\F1301\150595\316BR\1-9.DOCX040121 1-21

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 1-4. Comparison of Social Costs and Social Benefits at PSL Legend Total Total Total Social Costs and Social Social Benefits ($) Benefit Cost

        $1,300M Net Benefits                                     $1,221.59M (Benefits minus Costs)

Entrainment Compliance Alternatives

           $125M
                                                        $98.72M
          $100M
            $75M
              $5M
                                                  $1.15M                                        $1.29M
           -$75M
          -$100M                                     -$97.56M Fine-Mesh Screens
          -$125M
                                                                                                  -$1,220.29M
       -$1,300M                                                                           Closed-Cycle Cooling Net Benefits ($)

Retrofit (Benefits minus Costs) Notes: Social benefits are estimated using the Sample Year 1 entrainment data to present the benefits associated with the highest estimate of entrained commercial and recreational equivalent adult and the highest benefit estimate. Veritas Social costs and social benefits are discounted at 3%. ECONOMICS Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-22

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Additional social costs spent on candidate entrainment measures would result in even more negative net social benefits. Retrofit to closed-cycle cooling has the most negative net social benefits, at ($1,220.29) million (Year 1 results). The FMS option, which has been determined to be tentatively feasible at PSL but requiring additional testing and design and which may be considerably more costly than estimated here, also has a net negative benefit of ($97.56) million. Given that the net benefits are negative for each of the alternatives beyond what is required for impingement, neither entrainment compliance option is warranted as BTA under the Final Rules site-specific entrainment evaluation, for, as the Final Rule notes at 40 CFR 125.98(f)(4): If all technologies considered have social costs not justified by the social benefitsthe Director may determine that no additional control requirements are necessary beyond what the facility is already doing. The Director may reject an otherwise available technology as a BTA standard for entrainment if the social costs are not justified by the social benefits. Similarly, because both of the candidate entrainment measures result in more negative net social benefits than the existing facility condition, the commonly accepted framework of efficiency for economic decision making (Boardman et al., 2018; Freeman et al., 2014) suggests that the existing configuration at PSL represents the entrainment BTA for meeting the Final Rules site-specific entrainment requirement, per 40 CFR 125.98(f). Therefore, FPL concludes neither candidate entrainment measure is justified as entrainment BTA on a BPJ basis, and the current design and operation measures at PSL is BTA for entrainment. FPL believes that such a finding is entirely consistent with the direction provided to the NPDES Director regarding situations in which social costs [are] not justified by the social benefits as described at 40 CFR 125.98(f)(4) (see Section 1.3.2.5). The analysis previously described is based on the assumption of 100 percent mortality for entrained organisms, which likely overestimates the estimate of benefits. While entrainment survival at some rate is possible, no model system exists for estimation of its rate. For these reasons, no entrainment survival is considered to occur. 1.3.2.4 Entrainment BTA Factors that May Be Considered The following are the findings of the entrainment BTA assessment relative to the factors that FDEP may consider under 40 CFR 125.98(f)(3). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-23

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Entrainment Impacts on the Water Body-40 CFR 125.98(f)(3)(i) Key Document Section(s)Section 11.2.2 for estimation of changes in stock size and harvest levels, Section 11.2.5 for discussion of other potential benefits of a technology As discussed in Section 1.3.2.2, effects of entrainment on the fishery of the coastal ocean are believed to be modest based on the stability of the fishery and the relatively small withdrawal compared to the magnitude of coastal waters. This was confirmed by quantitative modeling of the effects of entrainment, including direct losses of C/R species as well as losses of organisms that may serve as forage for C/R species. Thermal Discharge Impacts-40 CFR 125.98(f)(3)(ii) Key Document Section(s)Section 11.2.6 The thermal discharge from PSL is subject to an approved thermal mixing zone and therefore complies with Floridas water quality standards for temperature. Based on this finding, FPL concludes reduction in the thermal loading associated with the potential retrofit to closed-cycle cooling would not have a meaningful beneficial effect to the nearby aquatic community. Flow Reduction-40 CFR 125.98(f)(3)(iii) Key Document Section(s)10.7 and Appendix 10-B PSL typically runs its single-speed cooling water circulating pumps at full capacity to maximize efficiency of power generation and heat exchange across the steam condensers. Opportunities for flow reduction are limited to scheduled outages for refueling and periodic reductions for maintenance. Impacts on Reliability of Energy Delivery-40 CFR 125.98(f)(3)(iv) Key Document Section(s)Cooling Towers: Sections 12.3.1, 12.3.5; FMS: Section 12.4.1, Section 12.4.5 PSL represents a large and important asset in supplying electricity to FPLs customers. Maintenance of reliable energy delivery is an imperative of FPL and has been considered in the assessment of entrainment BTA approaches in three ways: Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-24

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

• During the conceptual design of potential measures, configurations were adjusted to improve generation reliability, including the assumption that two sets of MTWS would be necessary in series in the event FMS are pursued and the selection of a cooling tower critical wet bulb temperature that reduces the frequency of unit derating. Such design changes affect the capital and social costs estimated for the retrofit. FPL notes that it has not concluded that the FMS system considered in Section 10 would, in fact, reliably provide cooling water to PSL. The likelihood that FMS would be clogged at high frequency with the potential for their failure, interruption of cooling water supply, and/or damage to pumps is of great concern to FPL. While FPL believes that the FMS configuration considered supports the goals of the Final Rule of evaluating the technology, there is a strong possibility that the actual costs of a workable system would be far higher than estimated in Section 10. The level of uncertainty and risks to operations must therefore be addressed by additional studies.
• The potential for VSP to result in flow reduction and, therefore, entrainment reduction was evaluated relative to the need to meet PSLs thermal limits. VSP represent a highly variable opportunity to reduce flow depending on environmental and market conditions.

As stated earlier, PSL typically runs its single-speed cooling water circulating pumps at full capacity to maximize efficiency of power generation and heat exchange across the steam condensers, and to comply with the thermal limits in its discharge permit. It was concluded that very low entrainment reductions would be attainable that would not justify installation of VSP.

• Power system modeling was performed to evaluate loss of generation capacity associated with retrofit in the context of the available electricity sources, both to ensure electricity was available and to estimate the social costs of securing it.

Potential retrofit of PSL to include closed-cycle cooling would reduce the available electrical output, particularly during summertime periods when electricity demand, and the price of electricity, is highest. Such reductions will have marginal effects on the reliability of energy delivery in FPLs service area. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-25

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Impacts on Water Consumption-40 CFR 125.98(f)(3)(v) Key Document Section(s)Cooling Towers: Section 12.3.6; FMS: Section 12.4.6 Section 12.0 considers changes in water consumption for the candidate entrainment technologies. Potential changes in water consumption with FMS and VSP would be negligible. Water consumption in the form of increased evaporation with use of cooling towers was quantified and compared to the increased evaporation associated with discharge of heated effluent from the once-through cooling system. This analysis is dependent on ambient weather conditions and was performed monthly. Cooling towers were estimated to increase water loss by 41 to 103 percent, depending on the month. Such losses are unlikely to result in important ecological or water supply effects given the source of cooling water is saline water from the Atlantic Ocean. Availability of Alternative Water Supplies-40 CFR 125.98(f)(3)(vi) Key Document Section(s)Section 10.6 Based on a review of several potential sources of water in the area, no alternative source of cooling water was found to be feasible. This assessment was based on the potential quantity of water available and the distance from the source to PSL. Groundwater use in the area is severely limited and was found to be infeasible; the use of groundwater would exacerbate saltwater intrusion. Sources of gray water are generally a small fraction of PSLs cooling water demand, have a strong potential to complicate discharge permitting, and would be costly to permit and construct the necessary conveyance systems. 1.3.2.5 Summary of Entrainment BTA and Recommendations The Final Rules summary of the requirements of the NPDES Director includes the following section under 40 CFR 125.98(f) site-specific entrainment requirements: (4) If all technologies considered have social costs not justified by the social benefits, or have unacceptable adverse impacts that cannot be mitigated, the Director may determine that no additional control requirements are necessary beyond what the facility is already doing. The Director may reject an otherwise available technology as a BTA standard for entrainment if the social costs are not justified by the social benefits. FPL has assessed the social costs and social benefits of potential retrofit to closed-cycle cooling, installation of FMS, and installation of VSP. While all three approaches are feasible, all three Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-26

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) have negative net social benefits. Brief summaries of the candidate entrainment BTA measures follow. Incorporation of Closed-cycle Cooling The conceptual design of a closed-cycle cooling retrofit was performed for the two units at PSL. This design was used to estimate capital costs for the potential project as well as ongoing operation and maintenance costs. These costs were converted to social costs that would be borne by the rate payer. The anticipated reduction in cooling water flow was used to estimate changes in entrainment and impingement, which were converted to monetized social benefits. Net social benefits over the anticipated lifetime of the plant and technology are estimated to be in excess of ($1,220.29) million based on construction costs, increased price of power, as well as increased operation and maintenance costs. Therefore, social costs exceed social benefits by a factor of approximately 946. Due to loss of generation capacity associated with parasitic loads, decreased efficiency, weather-related de-rates, and construction downtime, air emissions from replacement power sources will increase. Use of saltwater cooling towers would also result in increased particulate emissions from the new cooling tower. Fresh water in sufficient quantity for evaporative cooling tower makeup water is not available at PSL, and due to the oceans salinity, use of this source for makeup water would require making use of saltwater cooling towers. PSL discharges back to the Atlantic Ocean, a Class III marine water body. The Florida water quality standards limit increases in chlorides to no more than 10 percent above background. This restriction will limit cycles of concentration in the cooling tower to 1.3, lowering the potential reduction in intake flow. This fact is reflected in the estimation of social benefits, and, while the social costs are far higher than FMS, the monetized social benefits are only approximately 1.1 to 1.3 times higher than FMS. Therefore, retrofit to closed-cycle cooling should be rejected as entrainment BTA based on its highly negative net social benefits as well as its poor performance relative to other entrainment BTA approaches. Potential retrofit to closed-cycle cooling is also associated with the highest level of unavoidable adverse effects, including increased noise, air emissions with attending effects, and loss of generation output with attending effects on system reliability. These effects, while real, have not Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-27

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) been monetized as a part of this effort. Therefore, the net social benefits are actually lower (i.e., more negative) than the figures provided previously. Installation and Use of VSP Installation and operation of VSP at PSL would require replacement of the circulating water pumps, installation of variable-speed drives, and use of a climate-controlled facility for the drives. The potential to reduce intake flow was also examined based on 5 years of recent facility operation. The effectiveness of VSP at reducing intake flow at PSL is minimal due to the cooling demand and high-capacity factor of the plants two nuclear units. VSP were not considered a viable alternative for flow reduction and therefore not given further consideration. Installation and Operation of FMS The net social benefit for installation and operation of FMS is estimated to be approximately ($97.56 million) over the life of the technology (Year 1 results). While this is the least adverse net social benefit of the three technologies, it is still a situation in which social costs outweigh social benefits by approximately 86 to 1. FPL believes this conforms to the Final Rules criteria of social costs not justified by the social benefits. FPL also notes that the design basis for FMS systems is not well established and the installed base is small. Critically, the reliability and biological performance of such systems are understood to vary dramatically with site-specific conditions. The system considered in this analysis is patterned after a seasonally deployed FMS system at a Tampa Electric facility. Most importantly, while the FMS used at the Tampa Electric facility are workable, they are very costly to maintain and repair. The debris loading at that facility is also believed to be less than at PSL, which is subject to high debris loads and periodic entrainment of large numbers of jellyfish. All of these factors force FPL to conclude that FMS cannot be found to be feasible at PSL without extensive site-specific pilot testing. FPL believes that any modification of the screen configuration to improve the reliability and performance of the FMS screens would increase the social costs, further skewing the cost to benefit comparison. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-28

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 1.4 Conclusion The existing offshore velocity cap is a pre-approved technology for IM BTA at PSL (subject to a final determination by NOAA Fisheries on use of large animal exclusion devices; see Sections 1.3.1 and 6.2.1). The final selection of IM BTA will follow selection of entrainment BTA by FDEP, a sequence anticipated by the Final Rule and the subject of precedent. However, it is unlikely that FPLs selection of IM BTA would change based on the nature of the entrainment BTA. FPL believes none of the candidate entrainment mitigation technologies considered are justified based on their relative social costs and social benefits as well as other factors. Alternative water supplies were found to be infeasible and variable speed pumps are found to present no real opportunity for flow reduction. While both the remaining technologies have some unavoidable adverse effects, potential retrofit to closed-cycle cooling would result in more adverse effects than FMS, and although not all of the social costs of these effects are monetized in this effort, even the partial monetization of costs shows they far outweigh the social benefits. Therefore, neither approach to entrainment BTA is justified under the Final Rule at 40 CFR 125.98(f)(4) and commonly accepted economic decision processes. Neither FMS nor full closed-cycle cooling is practical at PSL, and FPL believes that the feasibility of FMS is not established. In summary, FPL believes none of the entrainment mitigation technologies are justified based on their social costs and social benefits, or any of the must or may factors in 40 CFR 125.98(f)(2) and (3). Nor is either approach practical at the site. Therefore, FPL respectfully requests FDEP reject the potential technologies as entrainment BTA and conclude the existing design and operational measures at PSL are entrainment BTA without additional measures. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 1-29

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 2.0 Source Water Physical Data 40 CFR 122.21(r)(2) This section provides information on the physical characteristics of the source water body. The following subsections are numbered and titled consistent with the sections of 40 CFR 122.21(r)(2), with information required by the Final Rule quoted in italics. 2.1 Description of Source Water Body §122.21(r)(2)(i)A narrative description and scaled drawings showing the physical configuration of all source water bodies used by your facility, including areal dimensions, depths, salinity and temperature regimes, and other documentation that supports your determination of the water body type where each cooling water intake structure is located. The St. Lucie Plant withdraws water from the Atlantic Ocean (Class III Marine Waters) on the east side of Hutchinson Island approximately 8 miles southeast of Fort Pierce, Florida (Figure 2-1). The depth near the intake is approximately 20 ft (ft) and slopes to approximately 40 ft roughly 1 mile offshore, rises back to approximately 25 ft at Pierce Shoal approximately 2 miles offshore. Beyond the shoal, the depth increases out across the continental shelf to approximately 300 ft (NOAA, 2017a), beyond which the depth of the open ocean averages approximately 11,000 ft (Britannica, 2017). The emergency cooling water intake is located on Big Mud Creek, a cove of the Indian River Lagoon. This intake is intended for use only during emergency conditions for safe shut-down of the plant. The emergency system is tested quarterly, but full-scale use has never been necessary. Big Mud Creek is a shallow (3-ft deep) arm of the Indian River Lagoon that extends almost entirely across Hutchinson Island. It was dredged for barge access and fill material during construction of the St. Lucie Plant (NRC, 1982). The NOAA chart shows a dredged depth of approximately 39 ft in 2001 (NOAA, 2017b). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 2-1

N:\PRJ\FPL\316(b) Support\GIS\MXD\R Reports\Figure_2-1_StLucie.mxd I 0 1,000 2,000 Feet 2-2 FIGURE 2-1. NOAA NAUTICAL CHART NEAR ST LUCIE NUCLEAR POWER PLANT Figure 1-1 Source: NOAA Seamless Raster Nautical Chart Web Service

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Salinity in the nearshore waters adjacent to the St. Lucie Plant is typical of ocean waters. Measurements taken during entrainment sampling from 2017 and 2018 ranged from 33.8 to 37.5 parts per thousand (ppt), while temperatures ranged from 60°F to 86°F (Figure 2-2). The Coastal Data Information Program buoy near Fort Pierce has recorded an average sea surface temperature for the period of record (September 29, 2006, to March 5, 2021) of 77.0 degrees Fahrenheit (°F), with a range of 57.0°F on January 14, 2010 to 88.7°F on September 22, 2016 (Figure 2-3). 2.2 Characterization of Source Water Body §122.21(r)(2)(ii)Identification and characterization of the source waterbodys hydrological and geomorphological features, as well as the methods you used to conduct any physical studies to determine your intakes area of influence within the waterbody and the results of such studies. The Atlantic Ocean is a large saltwater body located between North and South America on the west and Europe and Africa on the east. It is the second largest of the worlds oceans and covers approximately 20 percent of the Earth surface. It has an average depth of approximately 12,000 ft and a maximum depth of 27,480 ft at the Puerto Rico Trench. The St. Lucie cooling water intake is located along the southeastern coast of Florida. The edge of the continental shelf off Hutchinson Island is approximately 21 miles offshore. 2.2.1 Hydrology Currents in the nearshore area near the St. Lucie site are primarily influenced by winds and tides. Tides in this area are semidiurnal and have a relatively low tidal range with a mean of 2.56 ft and a spring tide range of 3.59 ft (NOAA Tide Station #8722212). The main ocean current along the Florida east coast is the Florida Gulf Stream, which flows northward offshore, beyond the 300-ft contour. The Florida Current, which is the southern portion of the Gulf Stream, flows eastward between Florida and Cuba, then turns northward along southern Florida and west of the Bahamas. It runs approximately parallel to the shelf edge, and a weak counter current may be present near shore. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 2-3

60 65 70 75 80 85 90 33.00 33.50 34.00 34.50 35.00 35.50 36.00 36.50 37.00 37.50 38.00 12/6/2017 12/6/2017 12/6/2017 FIGURE 2-2. 12/6/2017 12/20/2017 12/20/2017 Source: ECT, 2021. 1/4/2018 1/4/2018 1/17/2018 1/17/2018 1/18/2018 1/18/2018 1/31/2018 1/31/2018 2/14/2018 2/14/2018 2/28/2018 2/28/2018 3/1/2018 3/1/2018 AMBIENT TEMPERATURE AND SALINITY 3/15/2018 3/15/2018 3/28/2018 3/28/2018 4/11/2018 4/11/2018 4/12/2018 4/12/2018 4/25/2018 4/25/2018 5/9/2018 5/9/2018 2-4 5/23/2018 5/23/2018 FROM 2017-2018 ENTRAINMENT SAMPLING 5/24/2018 5/24/2018 6/6/2018 Temp (F) 6/6/2018 6/20/2018 Salinity (PSU) 6/20/2018 7/5/2018 7/5/2018 7/6/2018 7/6/2018 7/18/2018 7/18/2018 8/1/2018 8/1/2018 8/15/2018 8/15/2018 8/16/2018 8/16/2018 8/29/2018 8/29/2018 9/12/2018 9/12/2018 9/26/2018 9/26/2018 9/27/2018 9/27/2018 10/10/2018 10/10/2018 10/24/2018 10/24/2018 11/7/2018 11/7/2018 11/8/2018 11/8/2018 11/19/2018 11/19/2018 N:\PRJ\FPL\316(b) Support\Individual plant files\St. Lucie\R Reports\Figures\Templates\StLucieFGS\2-2a3/5/2021

N:\PRJ\FPL\316(b) Support\Individual plant files\St. Lucie\R Reports\Figures\Templates\StLucieFGS\2-33/5/2021 2-5 FIGURE 2-3. AMBIENT WATER TEMPERATURE NEAR PSL SEPTEMBER 2006 TO MARCH 2021 Source: CDIP, 2021.

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Longshore currents were measured for the St. Lucie Plant Environmental Impact Statement in 1973 to 1975. Currents ranged from near zero to 1.6 ft per second (ft/s) and flowed to the north 49 percent of the time and to the south 35 percent of the time. The prevailing current direction is to the north at an average speed of 0.74 ft/s near the surface and 0.54 ft/s near the bottom (FPL, 1982). 2.2.2 Geomorphology The St. Lucie Plant is located on Hutchinson Island, a barrier island that is part of a series of sandy barrier islands separated from the mainland Florida by the Indian River Lagoon. Hutchinson Island is within the Atlantic Coastal Plain physiographic province with sediments mapped as part of the Anastasia Formation (Thomas, 1993). Other than an intertidal coquina-rock formation located just south of the St. Lucie Plant at Walton Rocks, the near-shore substrate is characterized by unconsolidated sediments composed mainly of quartz and calcareous sands, broken shell fragments, and lenses of shell and clay of varying thicknesses. 2.2.3 Determination of Area of Influence The area of influence (AOI) of a CWIS appears in three of the 40 CFR 122.21(r) sections of the Final Rule for existing facilities:

     *     (2), Source Water Physical Data, requires information on the methods used to conduct any physical studies to determine the intakes AOI in the water body and the results of such studies.
     *     (4), Source Water Baseline Biological Characterization Data, states, for data collection, The study area should include, at a minimum, the AOI of the cooling water intake structure.
     *     (11), Benefits Valuation Study (relevant to existing facilities such as CCEC subject to the entrainment studies in the Final Rule), states, The study would also include discussion of recent mitigation efforts already completed and how these have affected fish abundance and ecosystem viability in the intake structures AOI.

The Section 316(b) Phase I rule for new facilities states AOI means that portion of the source water body hydraulically affected by the cooling water intake structure withdrawal of water. While this definition does not provide a clear means of estimating AOI (e.g., threshold velocity), it is common understanding the AOI is that area of the source water body directly affected by the Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 2-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) CWIS. Relative to impingeable organisms (generally juvenile and adult fish and shellfish), the concept is somewhat more concrete. It could be assumed it is the point at which the organism is no longer capable of overcoming the forces of water withdrawal and impinges upon an intake screen (Electric Power Research Institute [EPRI], 2007). This would be highly dependent on the swimming capabilities of the species and its life stage, size, and general health conditions, a point noted by EPRI in previous research on the relationship between intake approach velocity and the occurrence of impingement (EPRI, 2000). EPA considers a 0.5-ft/s through-screen velocity to be a de minimis value for the probability of impingement, which means a fish can swim freely in a flow at this velocity and avoid impingement (in fact, the studies showed a 1.0 ft/s threshold was protective, but it was halved as a safety factor). As a compliance option for impingement mortality best technology available (BTA) in the Final Rule, EPA indicates there is no need for any type of impingement protection, including impingement mortality studies, if the maximum design or actual maximum through-screen velocity of the CWIS is 0.5 ft/s or less per 40 CFR 125.94(c)(2) and (3). Under these conditions, it is considered that the facility has met the performance standards for impingement mortality. Therefore, the 0.5-ft/s contour for velocities induced by the CWIS delineates the CWISs AOI for impingement. The St. Lucie Plant has a velocity cap on each of the three intake structures, which consist of large flat concrete plates positioned above vertical shafts of the intake structure. These velocity caps convert vertical flow to horizontal flow at the intake on the premise that fish will avoid changes in horizontal flow better than they can detect and avoid vertical flow. All three velocity caps consist of square bases containing vertical pipes. For two of the caps, the bases are 52 ft on a side and the pipes are 12 ft in diameter. The third cap is 70 ft on a side with a 16 ft pipe. The two smaller caps have openings that are 6.5 ft tall while the opening in the larger cap is 6.25 ft tall. For the purposes of estimating the AOI, the horizontal flow is assumed to occur across the wall of a cylinder that is centered at the center of the pipe and is the height of the caps openings. The surface area of the cylinder wall was calculated by dividing the flow through the cap (606.5 ft3/s for the smaller caps and 1,075 ft3/s for the larger) by the 0.5 ft/s target velocity. Using that area, the formula for surface area (A = 2hr), where h is the cylinders Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 2-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) height and r is its radius, was rearranged to solve for the radius. For the smaller cap, the radius is 29.7 ft and the radius for the larger cap is 54.8 ft. These radii occur just beyond the limits of the square cap. In these calculations, the effect of the support columns on local velocity is ignored. This assumption is justified by the fact that the radius is beyond the caps and it results in an average velocity across the cylinder walls. The circular areas of the AOIs estimated in this way are 2,773 ft2 for the smaller caps and 9,427 ft2 for the larger. 2.3 Locational Maps §122.21(r)(2)(iii)Locational maps. Figures 1-1 and 1-2 provide location maps. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 2-8

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 3.0 Cooling Water Intake Structure Data 40 CFR 122.21(r)(3) This section provides information on the CWIS for the facility, with requirements from the Final Rule provided in italics at the beginning of each section. 3.1 Intake Configuration §122.21(r)(3)(i)A narrative description of the configuration of each of your cooling water intake structures and where it is located in the waterbody and in the water column. The St. Lucie intake is located approximately 1,200 ft from the shoreline in the Atlantic Ocean and consists of three vertical concrete shafts that have concrete velocity caps to change the current direction from vertical to horizontal. This technology takes into account that fish are able to detect and avoid a horizontal velocity but not a vertical velocity. The intakes are located at mid-depth (approximately 7 ft below the water surface at mean low water depth of 18 ft). Water is gravity fed through the three offshore intakes into the three submerged pipes and then into an onshore intake canal. Two of the intake pipes have an inside diameter of 12 ft, while the third has an inside diameter of 16 ft. The onshore intake canal is L-shaped and is approximately 5,000 ft long and 300 ft wide, with a maximum depth of 25 ft. The velocity caps consist of large flat concrete plates placed 6 to 6.5 ft above the vertical shaft of the intake structure. The velocity cap for the 16-ft pipe is 70 ft2, 5 ft thick, and has a vertical opening of 6.25 ft. The velocity caps for the two 12-ft diameter pipes are octagonal with the corners cut off; the long sides are 52 ft long, 5 ft thick, and have a vertical opening of 6.5 ft. Horizontal velocities at the two 12-ft pipe inlets are estimated to be 0.4 ft/s; velocities at the 16-ft pipe inlet are estimated at 1 ft/s. There is a series of barrier nets along the intake canal designed to contain and reduce the residence time of sea turtles in the intake canal. A 5-inch barrier net is located just downstream Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 3-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) of the intake headwall. A second barrier net consisting of large-diameter polypropylene rope with a mesh size of 8 by 8 inches is located near the State Road A1A bridge. The third barrier net is located near the bend in the intake canal and is constructed of 9 by 9-inch mesh. Sea turtles found in the intake canal or captured in the nets are released back to the Atlantic Ocean. Water entering the four intake bays passes through trash racks that consist of vertical bars at 3-inch spacing and through eight traveling screens (four per unit) with 0.375-inch mesh wire. The traveling screens are equipped with a spray wash system that removes debris and aquatic organisms. There is no fish return system at the St. Lucie Plant. There is an emergency cooling water intake structure located at the northwestern end of the intake canal that would allow water from Big Mud Creek, a cove of the Indian River Lagoon, into the intake canal. The intake consists of two 54-inch pipes with valves and is designed to provide emergency cooling water in the event that insufficient flow is available from the Atlantic. The system is tested quarterly by opening and closing each valve for a period of less than one minute. Depending on the head differential between Big Mud Creek and the intake canal, the testing allows approximately 100,000 gallons per valve to flow into the intake canal. §122.21(r)(3)(ii)Latitude and longitude in degrees, minutes, and seconds for each of your cooling water intake structures. The St. Lucie intakes are located at 27° 20' 50.78" north, 80° 13' 58.82" west, approximately 1,200 ft from the shoreline in the Atlantic Ocean. The emergency intakes are located on Big Mud Creek at 27° 20' 53.43" north, 80° 14' 56.93" west. §122.21(r)(3)(iii)A narrative description of the operation of each of your cooling water intake structures, including design intake flows, daily hours of operation, number of days of the year in operation and seasonal changes, if applicable. The design intake flow of the facility is 1,487 MGD (1,032,600 gpm) provided through eight circulating water pumps totaling 1,404 MGD and six auxiliary equipment cooling pumps, four of which typically operate at 83 MGD (two per unit) (Table 3-1). The emergency water intake structure has two 54-inch pipes with six auxiliary pumps capable of pumping 14,500 gpm Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 3-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) (20.88 MGD) each from Big Mud Creek. Flow monitoring data indicate an AIF from 2015 to 2019 of 1,389 MGD (Table 3-2). Table 3-1. St. Lucie Plant Pumps and Capacities Capacity Pump Type Purpose gpm MGD Circulating pumps Unit 1 (4 pump total) Once-through cooling 484,000 697 Unit 2 (4 pump total) Once-through cooling 490,600 706.5 Subtotal 974,600 1403.5 Auxiliary pumps* Auxiliary cooling 58,000 83.5 Total 1,032,600 1,487

• St. Lucie has six 14,500-gpm auxiliary cooling pumps; however, only four (two per unit) are routinely operated, and two serve as spares. The auxiliary pump capacities listed are for four pumps.

Source: FPL, 2020. Table 3-2. AIF at PSL - 2015 to 2019 Year Flow (MGD) 2015 1,314 2016 1,393 2017 1,470 2018 1,371 2019 1,395 5-Year AIF 1,389 Source: FPL, 2020. After passing through the condenser, heated water is conveyed through a 500-ft-long underground pipeline to the discharge canal. The canal is approximately 200 ft wide and 2,200 ft long and extends to a point approximately 400 ft west of the shoreline. The discharge water is then conveyed in two 12-ft concrete pipes buried under the beach and ocean floor to the two discharge structures. The older discharge built to service Unit 1 terminates approximately 1,200 ft offshore at a Y-shaped diffuser (see Figure 1-2). The second discharge extends approximately 2,800 ft offshore and ends in a linear multiport diffuser. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 3-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 3.2 Intake Flow and Water Balance §122.21(r)(3)(iv)A flow distribution and water balance diagram that includes all sources of water to the facility, recirculating flows, and discharges. A water balance diagram for the St. Lucie Plant is provided in Figure 3-1. 3.3 Engineering Drawings of Intake §122.21(r)(3)(v)Engineering drawings of the cooling water intake structure Drawings of the CWIS are provided in Figures 3-2 through 3-6. Figure 3-2 shows the configuration of the paired 12-ft diameter velocity caps. Figure 3-3 shows plan and section views of the 16-ft diameter velocity cap (left) and the two 12-ft diameter structures. Figure 3-4 illustrates the flow path from the offshore intakes through the intake canal, discharge canal, and offshore diffusers. Figure 3-5 shows representative front and side elevation views of the traveling water screens, while Figure 3-6 provides detail on the traveling screen panels and baskets. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 3-4

N:\PRJ\FPL\316(b) Support\Individual plant files\St. Lucie\R Reports\Figures\Templates\StLucieFGS\3-13/5/2021 FIGURE 3-1. WATER BALANCE ST. LUCIE NUCLEAR PLANT Source: FPL, 2016. 3-5

N:\PRJ\FPL\316(b) Support\Individual plant files\St. Lucie\R Reports\Figures\Templates\StLucieFGS\3-23/5/2021 FIGURE 3-2. CONFIGURATION OF PSLS TWO 12-FT DIAMETER OFFSHORE VELOCITY CAP INTAKE STRUCTURES Source: Source: EAI, 2001. 3-6

N:\PRJ\FPL\316(b) Support\Individual plant files\St. Lucie\R Reports\Figures\Templates\StLucieFGS\3-33/5/2021 Dimensions represent conditions after velocity cap repairs were completed in February 1992 FIGURE 3-3. PLAN AND SECTION VIEWS OF PSL's THREE OFFSHORE VELOCITY CAP INTAKE STRUCTURES Source: Source: EAI, 2001. 3-7

3-8 FIGURE 3-4. PSL COOLING WATER INTAKE SYSTEM Source: FPL, 1983.

FIGURE 3-5. PSL TRAVELING SCREEN DETAIL Source: FPL, 1999. 3-9

FIGURE 3-6. PSL TRAVELING SCREEN PANEL DETAIL Source: FPL, 1999. 3-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 4.0 Source Water Baseline Biological Characterization Data 40 CFR 122.21(r)(4) This section characterizes the biological community in the vicinity of the cooling water intake structure at the St. Lucie Plant and addresses each of the information requirements under 40 CFR 122.21(r)(4). The following subsections are numbered and titled consistent with the subsections of 40 CFR 122.21(r)(4). The discussion of threatened and endangered (T&E) species as required by 40 CFR 122.21(r)(4)(vi) has been modified to also address the requirements to list both federally and state-listed species and designated critical habitat per 40 CFR 125.95(f). 4.1 List of Unavailable Biological Data 40 CFR 122.21(r)(4)(i)A list of the data in paragraphs (r)(4)(ii) through (vi) of this section that are not available and efforts made to identify sources of the data; The data needed to prepare the elements of the requirements of 40 CFR 122.21(r)(4) were available from the literature and prior studies performed at the site. 4.2 List of Species and Relative Abundance in the Vicinity of CWIS 40 CFR 122.21(r)(4)(ii)A list of species (or relevant taxa) for all life stages and their relative abundance in the vicinity of the cooling water intake structure; Several studies were reviewed when compiling the list of species and relative abundance in the vicinity of the CWIS:

• National Coral Reef Monitoring Program 2014 and 2016.
• Multiple studies performed at the St. Lucie Plant.

o Unit 1 operational studies 1976 to 1983. o Phase II studies 2006 to 2007 Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) o Extended Power Uprate (EPU) Studies 2011 to 2015 o Entrainment characterization studies 2017 to 2018 4.2.1 National Coral Reef Monitoring Program As part of the National Coral Reef Monitoring Program, reef assessments were conducted along the eastern coast of Florida from the Dry Tortugas to Martin County. The monitoring is separated into three regions: 1) Dry Tortugas, 2) Florida Keys from Key West north to Miami and 3) Miami north to Martin County. The third region is closest to the St. Lucie Plant and data were available from 2014 and 2016, including 1,173 samples. These data are collected using a stratified random sampling method to determine sampling location and a 7.5m radius cylinder point count method. Data collections included diver observations of fish species composition, density, and size. Table 4-1 includes the species and relative abundance for the most commonly collected species within the Miami to Martin County region for the 2 years available (NOAA, 2018). 4.2.2 Prior Studies Performed at the St. Lucie Plant This section describes the historical impingement and entrainment studies and ambient monitoring conducted at PSL in the 1970s and 2000s to characterize the biological community in the vicinity of the St. Lucie Plant. Studies were conducted in the 1970s and 1980s with Unit 1 operational (prior to the construction of Unit 2), in January 2006 to October 2007 under the Phase II rule (two-unit operations), in 2011 through 2015 around the EPU, and entrainment sampling in 2017 to 2018 under the Final Rule. The ambient studies and impingement studies are summarized below while entrainment studies are discussed in more detail in Sections 7 and 9. Table 4-2 provides a summary of species that were impinged and/or entrained during these studies. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-1. Taxa Recorded in National Coral Reef Monitoring (2014 and 2016, Miami to Martin County) Scientific Name Common Name 2014 2016 Total Stegastes partitus Bicolor damselfish 15,752 17,900 33,652 Thalassoma bifasciatum Bluehead 11,852 15,025 26,877 Coryphopterus personatus Masked goby 14,841 11,574 26,415 Haemulon aurolineatum Tomtate 9,040 6,058 15,098 Haemulon sp. Grunt species 5,831 3,452 9,283 Clepticus parrae Creole wrasse 3,992 5,224 9,216 Sparisoma aurofrenatum Redband parrotfish 2,193 3,288 5,481 Acanthurus bahianus Ocean surgeon 1,998 2,680 4,678 Halichoeres garnoti Yellowhead wrasse 2,485 2,154 4,639 Haemulon flavolineatum French grunt 1,679 2,009 3,688 Acanthurus chirurgus Doctorfish 1,676 1,709 3,385 Canthigaster rostrata Sharpnose puffer 862 2,095 2,957 Halichoeres bivittatus Slippery dick 1,386 1,549 2,935 Chromis cyanea Blue chromis 1,037 1,664 2,701 Caranx crysos Blue runner 696 1,797 2,493 Chromis insolata Sunshinefish 867 1,295 2,162 Decapterus punctatus Round scad 915 1,199 2,114 Scarus iseri Striped parrotfish 483 1,237 1,720 Chromis multilineata Brown chromis 707 817 1,524 Anisotremus virginicus Porkfish 785 725 1,510 Haemulon plumierii White grunt 565 893 1,458 Chromis scotti Purple reeffish 685 765 1,450 Sparisoma atomarium Greenblotch parrotfish 907 511 1,418 Halichoeres maculipinna Clown wrasse 657 746 1,403 Chaetodon sedentarius Reef butterflyfish 368 845 1,213 Balistes capriscus Gray triggerfish 465 692 1,157 Annual Total Fish 91,273 100,962 192,235 Source: NOAA, 2018. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-2. Species Common in Recent Impingement and Entrainment Studies at PSL 2006-2007 2006-2007 2017-2018 Taxa Common Name Impinge- Entrain- Entrain-ment* ment ment Fishes Achirus lineatus Lined Sole X X X Blenniidae Combtooth blenny (family) X X Bregmaceros houdei Stellate Codlet X Diplogrammus pauciradiatus Spotted Dragonet X X Chloroscombrus chrysurus Atlantic Bumper X X X Selene setapinnis Atlantic Moonfish X X Sardinella aurita Spanish Sardine X Harengula jaguana Scaled Herring X X Etrumeus teres Atlantic Red Herring X Sardinella brasiliensis Orangespot Sardine X Anchoa lamprotaenia Big-Eye Anchovy X Anchoa hepsetus Broad-Striped Anchovy X X X Anchoa mitchilli Bay Anchovy X X X Chaetodipterus faber Atlantic Spadefish X X X Diapterus auratus Irish Pompano X Ctenogobius boleosoma Darter Goby X X Gobiosoma ginsburgi Seaboard Goby X Dormitator maculatus Fat Sleeper X X Gobiosoma robustum Code Goby X X Bathygobius soporator Frillfin Goby X X Nes longus Orangespotted Goby X Microgobius thalassinus Green Goby X Gobioides broussonnetii Violet Goby X X Labrisomidae Labrisomid blenny (family) X X Microdesmus bahianus Bahaia Wormfish X Myrophis punctatus Speckled Worm Eel X X Paralichthys oblongus Fourspot Flounder X Pomacentridae Damselfish (family) X X Scaridae Parrotfish (family) X Micropogonias undulatus Atlantic Croaker X X Umbrina coroides Sand Drum X X Bairdiella chrysoura Silver Perch X X X Leiostomus xanthurus Spot X X X Sciaenops ocellatus Red Drum X X X Larimus fasciatus Banded Drum X Cynoscion nothus Silver Seatrout X Cynoscion regalis Weakfish X X Serranidae Grouper (family) X Sphyraena borealis Sennet X Prionotus spp. North American searobin X X Lepidopa websteri A sand crab X Invertebrates Anomura Anomuran crab (non-Thalassinidea) X X Brachyura (Non-CRI) Brachyuran crab (infraorder) X X Caridea Caridean shrimp X X Euphausiacea Krill (order) X Gebiidea Burrowing shrimps (infraorder Gebiidea) X Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-2. Species Common in Recent Impingement and Entrainment Studies at PSL (Continued, Page 2 of 2) 2006-2007 2006-2007 2017-2018 Taxa Common Name Impinge- Entrain- Entrain-ment* ment ment Emerita talpoida Common mole crab X Hippolyte spp. Hippolyte shrimp X Thor spp. Shrimp (Thor) X Tozeuma spp. Shrimp (Tozeuma) X Loliginidae Loliginid squid (family) X Mysida Opossum shrimp (order) X Panopeidae Panopeid mud crabs (family) X Rimapenaeus constrictus Roughneck shrimp X X X Farfantepenaeus aztecus Brown shrimp X X X Farfantepenaeus duorarum Pink shrimp X X X Callinectes spp. Swimming crab (Callinectes genus) X X X Ovalipes spp. Swimming crab (Ovalipes genus) X Menippe mercenaria Florida stone crab X

• 2006 to 2007 impingement data were collected by trawl in the vicinity of the velocity caps.

Source: ECT 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 4.2.2.1 1976 to 1983 Studies Studies were conducted at the St. Lucie Plant in the 1970s and 1980s with Unit 1 being operational and prior to the construction of Unit 2. Impingement sampling was conducted at PSLs Unit 1 intake from 1976 to 1978 as directed by the NRC for the Unit 1 operating license. The travelling screens were sampled twice weekly for a 24-hour period divided into 8-hour samples, and annual impingement rates were estimated for the facility based on continuous operation of the one unit then in operation. There were 226 samples collected during this study. Annual fish impingement was estimated to be between 34,000 (1978) and 131,000 (1976); annual shellfish impingement was estimated at 26,000 (1976) to 37,000 shellfish (1978). The mean number of fish impinged per 24-hour period was 222, and the mean number of shellfish was 82. The dominant taxa impinged included anchovy (Anchoa sp.), grunt (Haemulidae), jack (Carangidae), croaker (Micropogonias sp.), mojarra (Gerreidae), shrimp (Panaeidae), and blue crab (Callinectes sapidus). In 1979, the NRC amended the operating license for Unit 1 to discontinue the monitoring requirement, stating that impingement losses were insignificant when compared to the fish populations in the site vicinity and the number of commercially harvested shrimp on Floridas east coast. With the addition of the second unit it was acknowledged that the impingement impacts would double with the doubling of the intake flow. However, the NRC estimated, even with doubling the weight of the organisms, impingement would only be equal to less than half of 1 percent of the commercial catch of fish and shellfish in either St. Lucie or Martin counties. Therefore, the NRC concluded the combined estimates for impingement of the two units would still be insignificant. Gill-net sampling was conducted monthly in the intake canal from 1976 through 1984 to determine the number of fish and shellfish that become entrapped in the intake canal. Gill nets of 200 ft by 10 ft with 3-inch stretch mesh were fished in the intake canal for two consecutive 24-hour periods each month. The dominant organisms collected included grunt, drum, snapper, jack, porgy, mullet, and sea robin. The average catch rate was fairly consistent throughout the study period (3.5 to 12.5 fish per 30 meters of gill net per day). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Gill net samples were also collected at six ocean sampling locations once per month from April to September and twice per month from October through March with a 183-meter-long by 3.7-meter-deep with five mesh sizes in the end: 64, 74, 84, 97, and 117 millimeters (mm). The net was fished for 30 minutes per station. Catch rate and species collected were variable over the years with catch per unit effort ranging from 8 to 94 fish per net set. Trawl samples were collected at six ocean stations using a 4.9-meter semi-balloon trawl with 127-mm stretch mesh in the bag and 6.4 millimeters (mm) stretch mesh in the cod end. Each tow consisted of 15 minutes at 2 to 3 knots and was conducted at night to reduce the avoidance response of fish. These studies showed a high variability in percent composition (relative abundance) and overall abundance across the study period, within years, and spatially. Beach seine samples were collected once a month at three stations, near the intake, near the discharge, and north of the discharge. The beach seine was 30.5 meters long by 1.8 meters deep, with a stretch mesh of 25 mm. The net was deployed at 1.2 meters from shore and fished for three replicate hauls during each sampling period. These studies indicated there is not a substantial accumulation of organisms in the intake canal. The low rate of entrapment was attributed to the velocity caps on the intakes that allow fish to detect and avoid the intake flow. Paired bongo nets were used to collect ichthyoplankton in the intake canal and nearshore habitats. Six ocean stations, one station in the intake canal, and one station in the discharge canal were sampled twice a month during the day using paired 20-centimeter, 505-micron mesh bongo nets. In the offshore stations the nets were towed for 15 minutes just below the surface. A mid-depth sample was taken near the intake, and oblique tows were taken in the canals. Sample analysis showed the mid-water samples near the intake had lower densities of ichthyoplankton than the surface samples, the intake canal had lower densities than the ocean, and the discharge canal had lower densities than the intake canal. The most common larval fish collected were herrings and anchovies, suggesting the unidentifiable eggs collected were likely the same species. Blennies, gobies, mojarras, drums, and jacks were also dominant. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) The effects from entrainment at PSL were estimated based on localized densities of entrainable organisms near the intake. Entrainment sampling was conducted over a five-year period and concluded, under normal conditions, approximately 0.4 percent of the fish eggs and larvae passing the intake would be subject to entrainment. Therefore, the NRC determined the St. Lucie Plant would have a minimal effect on the local fish populations. 4.2.2.2 Phase II Studies Studies were conducted from January 2006 to October 2007 in response to the release of the Phase II rule to characterize the biological community in the vicinity of the St. Lucie Plant. Bottom and midwater trawl samples were collected from the ocean near the intakes at three transects parallel to the shore using a 4.9-meter by 0.9-meter otter trawl. Fish densities were generally higher in the summer than the winter and higher in 2006 than 2007. Dominant fish collected in the trawls were anchovies (especially Anchoa hepsetus and A. lamprotenia), comprising 89 percent of the catch, followed by herrings (Clupeidae) with 5 percent. Shellfish densities were low (less than one per 100 cubic meters) throughout the study and were dominated by commercial shrimp (Penaeidae) and swimming crabs (Portunus spp.). Plankton samples were collected at the inlet of the intake canal using a plankton net suspended at mid-depth and fished for 5 or 10 minutes, depending on whether one or two units were operating. Fish densities from plankton collections peaked in the late spring and late summer. Densities in the intake canal were low throughout the study. A high percentage of the catch in the intake canal was unidentifiable (74.5 percent) due to developmental stage (35 percent undeveloped), damaged (24 percent), or otherwise unidentifiable (15 percent). Drums (9.5 percent) and anchovies (4 percent) were the most commonly identified. Densities of shellfish from plankton collections in the intake canal were also low throughout the study and dominated by brachyuran crabs (Brachyura, 64 percent), sergestid shrimp (Sergestoidea, 9 percent), and caridean shrimp (Caridea, 7 percent). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-8

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 4.2.2.3 EPU Studies Biological monitoring began in 2011 prior to the EPU to characterize baseline conditions and resumed for a two-year period through February 2015 following completion of the EPU (EAI, 2015). Sampling was performed every other month for a total of 8 baseline sampling events and 12 post-EPU events. These studies included gill netting, bottom trawls, plankton trawls, and beach seine sampling along with boat-based sea turtle surveys. Bottom trawl surveys resulted in 184 taxa, representing 93 fish, 76 crustaceans, 10 echinoderms, and 5 molluscs. A total of 7,530 organisms were collected (2,078 fish, 3,803 crustaceans, 1,527 echinoderms, and 122 molluscs). Clupeiformes (anchovies, herrings, and sardines), represented primarily by unidentified Engraulids and the Cuban anchovy (A. cubana), accounted for 38% of the total number of fish caught. The sand drum, unidentified anchovy (Anchoa sp.), star drum (Stellifer lanceolatus), and Atlantic bumper (Chloroscombrus chrysurus) were also caught in relatively high numbers. Collectively, these six taxa accounted for approximately 62% of the total catch. Bottom trawl samples resulted in 18 commercially or recreationally important (CRI) decapod crustacean taxa. Roughneck shrimp (Rimapenaeus constrictus), unidentified roughneck shrimp (Rimapenaeus sp.), pink shrimp (Farfantepenaeus duorarum), and speckled swimming crabs (Arenaeus cribrarius) made up 77 percent of all CRI crustaceans captured. Gill net samples included 100 taxa, representing 84 fish, 8 crustaceans, 7 echinoderms, and 1 mollusc with a total of 5,993 organisms (5,831 fish, 62 crustaceans, 99 echinoderms, and 1 mollusc) collected. The 10 most abundant species accounted for 78 percent of the catch, with four species, Atlantic sharpnose shark (Rhizoprionodon terraenovae; 15.7 percent), Atlantic bumper (15.7 percent), bonnethead shark (Sphyrna tiburo; 14.0 percent), and spot (6.6 percent) accounting for over half of the individuals caught. The only CRI invertebrate captured during gill net sampling was the speckled swimming crab, which was represented by 16 specimens. Beach seine samples included 76 taxa, representing 64 fish and 12 crustaceans, with a total of 42,289 organisms collected (42,105 fish and 184 crustaceans). The scaled sardine (Harengula jaguana) was by far the most abundant species (31,455 individuals), accounting for 75 percent of Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-9

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) all specimens collected. Four additional taxa, sand drum, Atlantic bumper, tidewater mojarra (Eucinostomus harengulus), and Spanish sardine (Sardinella aurita), were each represented by more than 1,000 individuals, and collectively these five taxa accounted for 89 percent of all fish caught. Seven taxa of CRI decapod crustaceans were captured during baseline beach seine sampling, the speckled swimming crab, three taxa of mole crabs (Albuneidae, Emerita sp., and Emerita talpoida), the spiny lobster (Panulirus argus), swimming crabs (Callinectes sp.), and pink shrimp, which collectively accounted for 178 specimens. 4.3 Identification of Species and Life Stages Susceptible to Impingement and Entrainment 40 CFR 122.21(r)(4)(iii)Identification of the species and life stages that would be most susceptible to impingement and entrainment. Species evaluated should include the forage base as well as those most important in terms of significance to commercial and recreational fisheries; The most representative data for identifying species that are susceptible to impingement and entrainment at the St. Lucie Plant are the early impingement studies (Section 4.2.2.1) and fish netting and ichthyoplankton data collected in the intake canal in 2006 to 2007 and 2017 to 2018. The commonly collected species in the more recent studies are included in Table 4-2 and discussed in the following sections. 4.4 Identification and Evaluation of Primary Growth Period 40 CFR 122.21(r)(4)(iv)Identification and evaluation of the primary period of reproduction, larval recruitment, and period of peak abundance for relevant taxa; The primary growth period for most species follows spawning and subsequent hatching. Shortly after hatching, larvae are at their greatest abundance and have rapid growth rates. The timing of these activities for species present in the Atlantic Ocean near PSL is discussed below. 4.4.1 Reproduction With some exceptions, most of the species found in the vicinity of PSL spawn in the spring and summer and therefore have their primary growth period in the summer and early fall. Exceptions include scaled herring and Labrisomid blennies which begin spawning as early as January, and Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) croaker, spot, red drum, and Irish pompano which spawn in the fall. Additionally, some species like stellate codlet, Atlantic bumper, Spanish sardine, bay anchovy, fat sleeper, damselfish and many of the invertebrates may spawn year-round. Table 4-3 summarizes the seasonal activities and spawning periods for species of common fish found in the vicinity of the CWIS. 4.4.2 Larval Recruitment and Period of Peak Abundance The larval recruitment period follows spawning by a few days to a week or more, depending on incubation times for each species and ambient water temperature. The period of peak abundance generally occurs around the time of hatching as the new larval recruits greatly add to the abundance of each species. The spawning period for most species common in this area is in the spring and summer months, leading to peak abundance in eggs around this time and larvae shortly after. Additionally, some species observed to be dominant in the nearshore Atlantic Ocean exhibit year-round spawning, with peaks typically occurring in summer. Peak abundance of juvenile fish will lag spawning and larval recruitment by weeks to a few months. Multiple-spawning fish show additional peaks through the summer and fall in relation to their multiple spawning times. 4.5 Data Representative of Seasonal and Daily Activities of Organisms in the Vicinity of CWIS 40 CFR 122.21(r)(4)(v)Data representative of the seasonal and daily activities (e.g., feeding and water column migration) of biological organisms in the vicinity of the cooling water intake structure; Table 4-3 summarizes data representative of seasonal and daily activities for the dominant species observed in the Atlantic Ocean near the CWIS. Seasonal activities consist of species migrating to and from tributary waters from offshore/deep marine environments in the spring and summer for spawning, with many species spawning offshore. Daily activities include movements for feeding and protection. Many species either move up and down in the water column or into deeper or shallower waters in response to either light, food availability, or temperature. Such trends in daily migrations are consistent with the observed higher rates of impingent and entrainment during nighttime sampling (Section 9.3). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-11

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat ACHIRIDAE Soles Found in estuaries and lagoons over sand-mud Spawning occurs in the eastern Gulf of Mexico Achirus lineatus Lined sole bottoms. Tolerates a wide range of salinities. from April to November. Feeds on benthic invertebrates and small fish. BLENNIIDAE Blennies Eggs are demersal, typically deposited in a hole or Most combtooth blennies live in shallow waters in Blenniidae Blennies crevice, or empty barnacle shell. 500 to 1,000 holes or crevices. Most feed on algae, but some eggs are typically guarded by a dominant male. are omnivorous. BREGMACEROTIDAE Bregmacerotid codfishes Spawning may occur year-round. Likely high Found on outer-continental shelf and slope waters Bregmaceros houdei Stellate codlet larval mortality. May be paedomorphic in which in mid-water. Codlet larvae are often most adults retain larval characteristics. abundant fish larvae in plankton collections. CALLIONYMIDAE Dragonets and Scooter Blennies Spawning occurs in sand patches at dusk when it Diplogrammus Inhabits seagrass beds in shallow waters. Feeds Spotted dragonet ascends into the water column to release pelagic pauciradiatus during the day and burrows in sediment at night. eggs. Females spawn once daily for three days. CARANGIDAE Jacks and Pompanos A schooling species found mostly in shallow Spawns year-round in some areas, but typically water and mangrove lagoons. Larvae may be Chloroscombrus chrysurus Atlantic bumper during spring and summer. found offshore associated with jellyfish. Feeds on fish, cephalopods, zooplankton, and detritus. Adults are usually found near the bottom in near Spawning may occur in spring through fall, likely shore waters but may form schools near the Selene setapinnis Atlantic moonfish in mid-water. surface. Juveniles are found on muddy bottoms in brackish estuaries and in coastal waters. CLUPEIDAE Herrings Schools in coastal waters from inshore to edge of May breed year-round with distinct peaks. In shelf. Migrates diurnally, ofent rising to the some areas distinct spawning periods linked with surface at night. Approaches coast and shoals Sardinella aurita Spanish sardine upwelling regimes. Juveniles remain in spawning during upwelling but retreats below the areas. thermocline during warmer periods. Feeds on zooplankton. Juveniles feed on phytoplankton. Demersal, pelagic species, found in coastal waters Spawns at night from January to September with Harengula jaguana Scaled herring over sand and mud, often near estuaries. Feeds on a peak April to August. fish and benthic organisms. Eggs and larvae are planktonic. Little is known Found in coastal waters. Usually in large schools. Etrumeus teres Atlantic Red herring about spawning habits. Feeds on zooplankton. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-12

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL (Continued, Page 2 of 8) Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat Spawns in coastal and shelf waters and young Marine, pelagic, coastal. Forms large schools. Sardinella brasiliensis Orangespot sardine move into shallow coastal or inshore waters. Juveniles often found in brackish waters. ENGRAULIDAE Anchovies Little is known about spawning behavior but Found in schools in coastal waters over likely similar to other anchovy species with continental shelf or around islands. Feeds on Anchoa lamprotaenia Big-eye anchovy spawning occurring in coastal waters in spring zooplankton and found in mixed schools with and summer. other anchovy species. Forms dense schools. Inhabits shallow coastal Spawns in harbors, estuaries, sounds, and offshore waters, frequently found in brackish bays and Anchoa hepsetus Broad-striped anchovy in spring and summer. estuaries. Feeds on copepods when young, adults eat plankton and benthic animals. Lower freshwater and estuarine reaches of coastal Spawns in spring-summer over much of Atlantic Anchoa mitchilli Bay anchovy rivers, bays, sounds, and high salinity nearshore coast, all year in southern Florida. marine waters; usually in shallow waters. EPHIPPIDAE Spadefishes Juveniles are found in shallow water in estuaries, often mimic dead leaves, or floating debris. Adults occur in large schools in coastal waters Chaetodipterus faber Atlantic spadefish Spawns May to October near structure such as wrecks, reefs, and pilings. Feeds on benthic invertebrates as well as plankton. GERREIDAE Mojarras Spawning occurs in September and October. Inhabits shallow coastal waters including Migrate downstream from brackish or freshwater Diapterus auratus Irish pompano mangrove lined creeks and lagoons, and vegetated reaches of coastal rivers to spawn in or near the sand grounds. ocean. GOBIIDAE Gobies Euryhaline, amphidromous, ranging from brackish (almost freshwater) to hypersaline Ctenogobius boleosoma Darter goby Benthic spawner. littoral lagoons. In quiet waters of bays and estuaries, in grassy, sandy, and muddy areas. Feeds on ostracods. Sexually dimorphic, spawns in deep water, often Found on reefs, in oyster beds, and the bottoms of Gobiosoma ginsburgi Seaboard goby on oyster reefs. Males incubate and guard their estuarine rivers. Ranges offshore also. own eggs, but cannibalistic on others. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-13

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL (Continued, Page 3 of 8) Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat Spawning may occur year-round. Eggs are Habitat consists of fresh and brackish waters with adhesive, typically attached to vegetation or other Dormitator maculatus Fat sleeper abundant vegetation and detritus. Primarily benthic objects. Spawning occurs in river mouths herbivorous. or lagoons. Adults guard the nest. Inhabits seagrass beds, oyster reefs and algal mats Gobiosoma robustum Code goby Spawns April to September in Florida. in very shallow, protected waters. It prefers fully saline water. In Florida, spawning occurs in July and August. Found in marine, brackish, and occasionally fresh Bathygobius soporator Frillfin goby Eggs are deposited under shells and guarded by waters. Feeds on small crustaceans and small fish. the males. Found on silty open bottoms near reefs. Obligate Gobies are demersal spawners, may lay eggs in symbiont with snapping shrimp. Feeds mainly on Nes longus Orangespotted goby nest or burrows. Eggs develop into pelagic larvae. small gastropods, crustaceans, ostracods, and isopods. Gobies are demersal spawners, may lay eggs in Demersal, inhabits muddy tide pools, creeks, and Microgobius thalassinus Green goby nest or burrows. Eggs develop into pelagic larvae. bays at low to medium salinity. Demersal, prefers muddy bays and estuaries. Also Gobies are demersal spawners, may lay eggs in Gobioides broussonnetii Violet goby found in freshwater over muddy bottoms. Feeds nest or burrows. Eggs develop into pelagic larvae. on algae and detritus. LABRISOMIDAE Labrisomid Blennies Deposit eggs on hardbottom substrate, usually in Typically inhabit shallow hardbottom, reefs, and Labrisomidae Labrisomid blenny small areas defended by the male. Spawning seagrass meadows. Feed on small fishes and occurs from January to April. invertebrates. MICRODESMIDAE Dartfishes and Wormfishes Little is known about the reproduction of Microdesmus bahianus Bahia wormfish wormfish. OPHICHTHIDAE Snake Eels and Worm Eels Adults move to open sea to spawn. Spawning Found in seagrass beds from bays and mangroves occurs between fall and early winter. Pelagic to offshore reefs. Eurythermal, euryhaline and can Myrophis punctatus Speckled worm eel leptocephalus larvae are transported north on the inhabit waters with relatively low dissolved Gulf Stream into estuarine inlets. oxygen. PARALICHTHYIDAE Lefteye Flounders Lefteye flounders spawn in the water column. Not Found in bays and sounds in the northern part of Paralichthys oblongus Fourspot flounder much is known about spawning habits, some its range and offshore and progressively deeper migrate to the edge of the shelf to spawn. water to the south. Found over soft bottom. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-14

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL (Continued, Page 4 of 8) Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat POMACENTRIDAE Damselfishes Reef-associated and non-migratory. Juveniles are Eggs are demersal and adhesive, males guard and Pomacentridae Damselfish (family) associated with sargassum, adults found over aerate. Spawns year-round. shallow reefs. Form large feeding aggregations. SCARIDAE Parrotfishes Parrotfishes are found in shallow waters, typically with seagrasses, algae, or sponges. Mainly Scaridae Parrotfish (family) Spawn in groups in the water column. herbivores using teeth to scrape algae off substrates. SCIAENIDAE Croakers and Drums Found in coastal waters and estuaries. Demersal Spawns from late-August to late-March with a over sand or mud bottoms. Also found in fresh Micropogonias undulatus Atlantic croaker peak in September to November. Spawns water. Schools on mud flats and sand bars. Feeds offshore, eggs are pelagic. on benthic crustaceans and polychaetes. Occurs in shallow water along sandy beaches. Eggs and larvae are pelagic. Spawns in the water Umbrina coroides Sand drum Also found over muddy bottoms in coastal areas column. and near coral reefs. Feeds on benthic organisms. Found mostly in coastal waters and nearshore Spawns late spring or summer. Pelagic eggs are marine environments. Young mostly stay in broadcast in coastal waters, particularly around Bairdiella chrysoura Silver perch estuaries and grass beds. Species is only inlets. Migrates to nursery and feeding areas in sometimes found in freshwater. Feeds mainly on estuaries during summer months. crustaceans, worms and occasionally fishes. Enters bays and estuaries in the spring and migrates offshore in fall for spawning. Spawns Occurs in coastal waters over sand and mud. Leiostomus xanthurus Spot fall to early spring. Larvae transported to estuaries Feeds on benthic invertebrates and detritus. and juveniles found in tidal creeks. Spawning adults move to natal estuaries in Found over sand and mud bottoms in large Sciaenops ocellatus Red drum August to November. Broadcast spawns in 2- to schools near the surface. Juveniles are dependent 4-day intervals. on estuarine nursery habitat. Spawns spring through fall offshore. Eggs are Occurs over mud and sandy mud bottoms in Larimus fasciatus Banded drum pelagic coastal waters. Feeds mainly on small shrimp. Occurs mainly over sandy bottoms in inshore Spawns late spring to summer, synchronous Cynoscion nothus Silver seatrout waters along beaches and in river mouths. Feeds spawning, small clutch sizes. on crustaceans and fishes. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-15

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL (Continued, Page 5 of 8) Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat Spawns spring through early fall, eggs are Usually found in shallow coastal waters over sand pelagic, larvae are pelagic but become demersal and sandy mud bottoms. Juveniles are euryhaline. Cynoscion regalis Weakfish early. Juveniles leave estuaries in the fall and Move to nursery and feeding grounds in estuaries migrate to outer-shelf areas. in summer. Feeds mainly on fish and crustaceans. SERRANIDAE Groupers and Sea Basses Groupers are found in a variety of habitats Groupers are water column spawners, known for Serranidae Grouper (family) including reefs, hardbottom, shallow and deep aggregating en masse prior to spawning. waters, nearshore and offshore. SPHYRAENIDAE Barracudas Little is known about the reproduction of sennet, however, in similar species spawning occurs in Nearshore schooling species that is found most Sphyraena borealis Sennet spring and summer, females may spawn multiple often over soft bottoms. times per season. TRIGLIDAE Gurnards and Searobins Searobins are found over sandy or muddy Little is known about reproduction of searobins, bottoms, from nearshore to the outer shelf. Some North American Prionotus spp. eggs are released in the water column. Some species bury themselves in the sand during the searobin spawn year-round others in winter. day and emerge at night to feed. Feed on shrimp, worms, and other benthic invertebrates. ALBUNEIDAE Mole Crabs Usually found on sandy ocean beaches at or just Lepidopa websteri A sand crab Reproduction occurs in July and August. below the low tide mark. Burrows backwards into the sand. ANOMURA Anomuran crab (non-Thalassinidea) Green Porcelain Crab (Petrolisthes armatus) Female carries a sponge with eggs on her body. Found in a variety of habitats, including coral Anomuran crab (non-Anomura Passes through three larval stages before settling reefs and marginal habitats such as seagrass beds, Thalassinidea) to the bottom as a juvenile. Larvae tend to move and mangrove creeks, as well as artificial reefs. toward deeper water during development. BRACHYURA Short-tailed Crabs Brachyuran crabs are likely fiddler crabs and mud Brachyuran crab crabs. Timing and length in larval stages varies Found in a variety of habitats. Generally along Brachyura (Non-CRI) (infraorder) among species, eggs are typically held on the shorelines with sandy or muddy substrates. body until hatching. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-16

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL (Continued, Page 6 of 8) Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat CARIDEA (Infraorder) Caridean shrimp In most species of caridean shrimp the females lay 50,000 to 1 million eggs that hatch in 24 Adults migrate back to open waters and are Caridea Caridean shrimp hours. The young go through a series of larval benthic. stages in approximately 12 days, the postlarvae migrate into estuaries, EUPHAUSIACEA (order) Krill Krill travel in swarms for protection from Spawning occurs January to March, near the predators. They are found at deeper depths during Euphausiacea Krill surface, eggs sink gradually before hatching. the day and rise to the surface at night to feed. Batch spawners of up to 10,000 eggs. Swarms can reach densities of up to 30,000 individuals in a 10 ft area. Feed on phytoplankton. GEBIIDEA (infraorder) Burrowing shrimps Some species reproduce year-round. Females Typically found burrowing in the substrate in Gebiidea Burrowing shrimps carry the eggs until hatching. intertidal and shallow water marine habitats. HIPPIDAE Sand Crabs Reproduction typically occurs from late winter Found in the swash zone of exposed sandy Emerita talpoida Common mole crab through early fall with a peak in late summer. beaches along the North American east coast. Developing eggs are attached to the female. Migrate up and down the beach with the tides. HIPPOLYTIDAE Shrimps Typically found in shallow water associated with Hippolyte spp. Hippolyte shrimp May reproduce year-round. Female carries eggs. seagrass or other vegetation. Reproduces year-round with a peak May through Thor spp. Shrimp (Thor) Found in grass flats in nearshore waters. July. Found in beds of vegetation or similar habitats in Tozeuma spp. Shrimp (Tozeuma) Reproduces year-round in Florida. shallow coastal waters. Loliginidae Squids Spawning occurs throughout the year. Eggs are Brief squid are found in warm, shallow waters, Loliginidae Loliginid squid (family) deposited in gelatinous, yolky egg masses. Eggs can tolerate low salinity and are found in hatch into tiny, fully formed young squid. estuaries. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-17

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL (Continued, Page 7 of 8) Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat MYSIDAE (order) Opossum shrimp Found in semi-protected bays, with sand, silt, and oyster shells, or clay and leaf-litter, and in more Reproduction occurs year-round in the Gulf of Mysida Opossum shrimp exposed areas over shell, gravel, and sand. Mexico, with peaks in fall and spring. Typically found n or near the bottom or swimming throughout the water column. PANOPEIDAE Panopeid mud crabs Panopeus herbsetii - females carry broods of eggs on abdomen. Larvae pass through 4 zoeal Panopeid mud crabs Mud crabs in the family Panopeidae are common Panopeidae stages and one megalopa before settling and (family) in marine intertidal and subtidal habitats metamorphosing into juveniles. Larvae remain in estuarine waters. PENAEIDAE Penaeid shrimp Spawning peaks typically occurs during the Occurs in unconsolidated sublittoral sediments, or Rimapenaeus constrictus Roughneck shrimp summer. Precopulatory courtship ritual occurs sandy or mud bottom habitats with shells up to prior to the indirect transfer of sperm. 130 meters deep. Extended spawning season that varies Commonly found in estuaries and littoral zones geographically. Spawning occurs offshore. especially muddy bottom areas in the intertidal Farfantepenaeus aztecus Brown shrimp Demersal eggs hatching within 24 hours. Larvae zone to approximately 110 meters deep. develop offshore. Postlarvae return to coastlines Opportunistic omnivore feeds mainly on algal in late winter and spring. species and small invertebrates. Spawning usually occurs in the ocean, ranging Depths of 2 to 70 meters on compacted mud, silt, from near the beaches to several miles offshore, or sandy bottoms or among shells. Juveniles Farfantepenaeus duorarum Pink shrimp typically spawn in the spring and early summer. found in marine or estuarine waters; adults are Exact timing of spawning period depends on marine. water temperature. PORTUNIDAE Swimming crab Spawning occurs from December through October, with peaks occurring in spring and summer. Females prefers high salinity Occurs in oceans and estuaries, may range into Swimming crab Callinectes spp. environments during spawning. Larvae are some freshwater habitats. May migrate into (Callinectes genus) advected offshore, and complete development in deeper waters during winter. coastal shelf waters. Larvae must remain in salinities in excess of 20 ppt during development. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-18

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-3. List of Seasonal Activities, Spawning Migration, Daily Activities, Migration, and Habitat for Dominant Species Present Near PSL (Continued, Page 8 of 8) Species Name Common name Seasonal Activities/Spawning Migration Daily Activities/Migration/Habitat The female carries the eggs under a flap on her abdomen and when the eggs hatch, they are Swimming crab Found on shallow subtidal sandy bottoms along Ovalipes spp. planktonic. The larvae molt several times before (Ovalipes genus) beaches and bays resembling an adult and settling down into the benthos. XANTHIDAE Xanthid crab Breeding occurs year-round with a peak spring to Found in sub-tidal regions where they burrow Menippe mercenaria Florida stone crab fall, especially August to September in Florida, underground or in seagrass beds. female carries egg sac. Sources: Fishbase, 2020. IUCN, 2020. Nature Serve, 2020. ADW, 2020. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-19

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 4.6 Identification of Threatened, Endangered, and Other Protected Species Susceptible to I and E at CWIS 40 CFR 122.21(r)(4)(vi)Identification of all threatened, endangered, and other protected species that might be susceptible to impingement and entrainment at your cooling water intake structures; 4.6.1 Threatened or Endangered Species Occurrence The Final Rule modified the existing requirements of 40 CFR 112.21(r)(4)(vi) by replacing the former requirement to list state- and federally listed protected species with those listed by the federal government [40 CFR 125.95(f)]. Given the likely interest in state-listed species, this section will address both state- and federally listed species. Table 4-4 presents state- and federally listed species, including terrestrial species, potentially occurring in the vicinity of PSL (IPaC, 2021; FNAI, 2021). Table 4-5 includes range and reproductive habits for protected aquatic species that may be located near the intake based on the potential presence of habitat within the area surrounding PSL and in St. Lucie County. 4.6.1.1 Federally Listed Species Federally listed T&E species and critical habitat are protected by the Endangered Species Act (ESA) of 1973 and subsequent amendments. The ESA is administered by two federal agencies, the U.S. Fish and Wildlife Service (USFWS) and NOAA Fisheries. NOAA Fisheries oversees marine species, and the USFWS has responsibility over freshwater fish and all other terrestrial and aquatic species. Federally listed T&E species have legal protection the ESA; special concern species indicate a species in danger of becoming threatened but not officially protected by the ESA. USFWS recommends use of their Information Planning and Conservation (IPaC) tool for determining which species may be affected by a project. Table 4-4 presents state- and federally listed species, including terrestrial species, in the vicinity of the St. Lucie Plant (IPaC, 2021; FNAI, 2021). Twelve federally listed aquatic species (Johnsons seagrass, Atlantic sturgeon, smalltooth sawfish, giant manta ray, scalloped hammerhead shark, West Indian manatee, American alligator, green sea turtle, Kemps ridley sea turtle, hawksbill sea turtle, leatherback sea turtle, and loggerhead sea turtle) have been recorded Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-20

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-4. List of State- and Federally Listed Species in the Vicinity of the St. Lucie Plant Status Scientific and Common Name Habitat Description Federal State Plants and Lichens Cereuseriophorus (Harrisia) var fragrans Open coastal hammocks and shell middens, E E Fragrant prickly-apple scrubby flatwoods, maritime and xeric hammocks Chamaesyce cumulicola E Coastal scrub and stabilized dunes Sand-dune spurge Cladonia perforata Rosemary scrub on the panhandle coast, Lake E E Florida perforate cladonia Wales Ridge, and Atlantic Coastal Ridge Coelorachis tuberculosa Shallow areas in lakes and ponds or wet savannahs T Piedmont jointgrass in karst areas Sandy flats or sandhills, mostly with sand pine, Conradina grandiflora T mostly near the coast; also in the vicinity of Large-flowered rosemary ancient dunes of shores Dicerandra immaculata In remnants of ancient dunes with sand pine scrub E E Lakelas Mint vegetation Sandy clearings in coastal dune swales, scrub Glandularia maritima E pinelands, and open live oak-cabbage palm woods; Coastal vervain also disturbed clearings Rhizomatous seagrass forming low mats in pure Halophila johnsonii T E stands or with shoalgrass in intertidal areas of Johnsons seagrass depths ranging from 6 inches to 6 ft Deep sands and ancient dunes, on which the most Lechea cernua common forest is a mixture of evergreen scrub T Nodding pinweed oaks; also mature scattered pine or oak forests but more frequently in sandy openings Lechea divaricata E Scrub and scrubby flatwoods Pine pinweed Linum carteri var. smallii Pine rocklands, pine flatlands, and adjacent E Smalls flax disturbed areas Polygala smallii Grassy pineland, sandy pine rockland, scrubby E E Tiny polygala flatwoods, and sandhill; often in disturbed areas Schizachyrium niveum White sand patches in rosemary scrub; also sand E Scrub bluestem pine scrub and oak scrub Tephrosia angustissima var. curtissii E Pine rocklands Coastal Hoary-pea Reptiles and Amphibians Fresh and brackish waters, including ponds, lakes, Alligator mississippiensis FT(S/ SAT swamps, rivers; often bask on land next to the American alligator A) water; spend cold months in a den Tropical and subtropical habitats, including bays, estuaries, lagoons, creeks, and mouths of rivers, Caretta caretta T FT with nesting occurring on high energy beaches Loggerhead sea turtle above high-tide mark and seaward of well-developed dunes Wide range of tropical and subtropical habitats, including shallow, low-energy waters with Chelonia mydas abundant submerged aquatic vegetation, in T FT Green sea turtle convergence zones in the open ocean, coral reefs and rocky outcrops, and beaches with coarse to fine sands Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-21

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-4. List of State- and Federally Listed Species in the Vicinity of the St. Lucie Plant (Continued, Page 2 of 3) Status Scientific and Common Name Habitat Description Federal State Wide range of tropical and subtropical habitats, ermochelys coriacea including open ocean, gulfs, bays, and estuaries; E FE Leatherback sea turtle typically, only found in shallow habitats and beaches by vegetation during nesting Drymarchon corais couperi Broad range, from scrub and sandhill to wet T FT Eastern indigo snake prairies and mangrove swamps Wide range of tropical and subtropical habitats, including shallow coastal waters with rocky Eretmochelys imbricata E FE bottoms, coral reefs, beds of sea grass or algae, Hawksbill sea turtle mangrove-bordered bays and estuaries, and submerged mud flats Dry upland habitats, including sandhills, scrub, Gopherus Polyphemus xeric oak hammock, and dry pine flatwoods; C ST Gopher tortoise commonly uses disturbed habitats such as pastures, old fields, and road shoulders Lepidochelys kempii E FE Marine coastal waters, nests on sandy beaches Kemps ridley sea turtle Birds Aphelocoma coerulescens Fire-dominated, low-growing, oak scrub on well-T FT Florida scrub-jay drained sandy soils Breed in elevated sparsely vegetated ridges or Calidris canutus rufa T FT slopes; feed adjacent to wetlands and lake edges; Red knot winter over muddy or sandy coastal areas Swampy forests, especially large bottomland river Campephilus principalis E FE swamps in the coastal plain and cypress swamps Ivory-billed woodpecker in Florida; apparently extinct Sandy upper beaches with scattered grasses, sparsely vegetated shores and islands of shallow Charadrius melodus lakes, ponds, rivers, and impoundments; nesting T FT Piping plover occurs on gently sloping foredunes and sandy open flats among shells or cobble behind foredunes Variety of wetland and other habitats, including Grus americana XN FXN coastal marshes and estuaries, inland marshes, Whooping crane lakes, ponds, wet meadows, and agricultural fields Chiefly freshwater situations: marshes, swamps, lagoons, ponds, flooded fields; depressions in marshes are important during drought, also Mycteria americana T FT brackish wetlands; nest mostly in upper parts of Wood stork cypress trees, mangroves, or dead hardwoods over water or on islands along streams or adjacent to shallow lakes Picoides (Dryobates) borealis Open, mature pinelands especially longleaf pine E FE Red-cockaded woodpecker with open understory; prefer mature pines Polyborus plancus audubonii Open areas, including dry or wet prairie with (Caracara cheriway) T FT cabbage palms, pastures, and sometimes wooded Audubons crested caracara areas Large open freshwater marshes and lakes with Rostrhamus sociabilis plumbeus E FE shallow water and low density of emergent Everglades snail kite vegetation; dependent on apple snails Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-22

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-4. List of State- and Federally Listed Species in the Vicinity of the St. Lucie Plant (Continued, Page 3 of 3) Status Scientific and Common Name Habitat Description Federal State Sternula antillarum Coastal areas, nests on well-drained sand or gravel ST Least tern with little vegetation Mammals Burrow in dune systems with grades, open sandy Peromyscus polionotus niveiventris E FE areas, scattered shrubs, and weedy coastal strands Southeastern beach mouse and scrub habitats Remote mountainous or undisturbed areas; wide Puma concolor coryi E FE variety of habitats: swamps, riparian woods, Florida panther brushy areas, or woods Puma concolor Large tracts of heavily forested areas, especially SAT Mountain lion lowlands and swamp Coastal waters, bays, rivers, and occasionally Trichechus manatus T FT lakes; requires warmwater refugia such as springs West Indian manatee or cooling effluent during cold weather Fishes Acipenser oxyrinchus oxyrinchus Primarily marine, nearshore; migrate to rivers for E FE Atlantic sturgeon spawning Manta birostris Nearshore to pelagic over the continental shelf T Giant manta ray near reef habitats and offshore islands Shallow coastal waters over muddy and sandy Pristis pectinata E bottoms especially with fringing mangroves, often Smalltooth sawfish in brackish waters near river mouths Sphyrna lewini Open ocean environments occurring over broad T* Scalloped hammerhead shark geographic ranges Insects Tropical hardwood hammocks with host plants: Cyclargus thomasi bethunebakeri E FE balloon vine (Cardiospoermum halicacabum) and Miami blue butterfly snowberry (Chiococca alba) Note: C= candidate for federal listing by UFSWS. FT = federally listed as threatened by USFWS E= endangered. and/or NOAA Fisheries. T= threatened. ST = state listed as threatened by FWC. SAT = threatened due to similarity of FXN = federally listed as an experimental population appearance. in Florida. SC = special concern. FT(S/A) = federally listed as threatened due to similarity EXPN = endangered, experimental population, of appearance. non-essential. XN = experimental population. FE = federally listed as endangered.

• Not listed for the Northwest Atlantic and Gulf of Mexico distinct population segment (DPS), which includes coastal Florida, but included here because of listing for the Central and Southwest Atlantic DPS, which includes the waters off the Bahamas.

Sources: FNAI, 2021. IPaC, 2021. NatureServe 2019. Fishbase, 2019. IUCN, 2019. NOAA Fisheries, 2021a. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-23

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-5. Protected Aquatic Species Range and Reproductive Habits in St. Lucie County Species Range Reproduction Mammals In the USA, concentrated in Florida in the winter; in summer months, found as far west as Texas and as for north as Mating, calving, and care of young often Trichechus manatus Massachusetts; Florida manatees occur in secluded canals, creeks, West Indian manatee migrate southward for winter; seasonal embayments, and lagoons migrations of at least 530 miles to wintering areas have been documented along Atlantic Coast. Reptiles and Amphibians Courtship occurs in spring, females deposit eggs in nests in May, June, or July. Nests are built of mounded leaves, mud, rotting Found from coastal North Carolina to Alligator vegetation, rocks, or other debris in marshes the Florida Keys and west to southern mississippiensis or at lake or river edges. Hatching occurs in Texas north to southeastern Oklahoma American alligator approximately 9 weeks. Female remains near and Arkansas. the nest, may help open the nest mound, may carry nestlings to water. Hatchlings remain near nest and mother for 1 to 3 years. Globally distributed over more than 2,500,000 square kilometers, migrating long distances between nesting beaches Mating in the southeastern U.S. occurs from Caretta caretta and marine waters. Nesting in the late March to early June. Nests 1-9 clutches Loggerhead sea turtle Atlantic coast from North Carolina to per season of 45 to 200 eggs each Southern Florida. Found in Florida approximately every two weeks. waters year-round with peak abundance during spring and fall migrations. Occurs in the pantropical areas of the Frequently nests on the Atlantic coast, with Atlantic Ocean, with small populations the highest concentration of nesting in the Chelonia mydas Green numbers in Florida, including nesting U.S. occurring in Palm Beach County. sea turtle beaches. Juveniles and adults occur in Nesting occurs in Florida from March to St. Lucie County waters. October. Global species that generally forages in temperate waters and nests in tropical Nests at night, March through August in and subtropical latitudes on beaches of Western Hemisphere. Eggs hatch in 8 to Dermochelys coriacea the Atlantic, Indian, and Pacific oceans. 10 weeks. Nests on sloping sandy beaches Leatherback sea turtle In the Western Hemisphere, nesting also backed up by vegetation, often near deep occurs in Florida (very rarely north to water and rough seas. Georgia), along the shores of the Gulf of Mexico. Nesting occurs on undisturbed, deep-sand, Pantropical and warm-temperate insular or mainland beaches, from high regions, rarely venturing into higher energy ocean beaches to tiny pocket beaches latitudes; Atlantic, Pacific, and Indian several meters wide contained in crevices of Eretmochelys imbricata oceans. Nests on beaches generally cliff walls; typical site would be a low-Hawksbill sea turtle between 25 degrees latitude north and energy sand beach with woody vegetation, south, including tropical Gulf Coast of such as sea grape or saltshrub, near the water Mexico, West Indies, Bahamas, and the line. Nesting occurs in Florida from March Americas. to October. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-24

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 4-5. Protected Aquatic Species Range and Reproductive Habits in St. Lucie County (Continued, Page 2 of 2) Species Range Reproduction 60 percent of nesting occurs in Rancho Adults essentially restricted to the Gulf Nuevo, Mexico where they nest in an Lepidochelys kempii of Mexico. Juveniles are found in Gulf arribada, a mass synchronized nesting event. Kemps ridley sea of Mexico and the Atlantic coast to Occasionally nesting occurs as far north as turtle Nova Scotia. North Carolina and south to Columbia. Nesting occurs April to July. Fishes Found in Atlantic coast drainages from Labrador to northern Florida. Spawns in large coastal rivers, generally in Acipenser oxyrinchus Anadromous, adults found in salt or freshwater. Formerly spawned in St. Johns oxyrinchus brackish waters, spawns in large River. Spawning occurs in spring. Females Atlantic sturgeon freshwater rivers. May currently only be lay 250,000 to 1,000,000 eggs approximately in Florida as a winter resident. Formerly every 3 years. spawned in St. Johns River. Found worldwide in tropical, Giant manta rays have very low fecundity, subtropical, and temperate waterbodies typically giving birth to only one pup every Manta birostris including the coasts of southern Africa, two to 3 years. Mating season occurs from Giant manta ray ranging from southern California to early December to late April in tropical northern Peru, North Carolina to waters. Gestation lasts 13 months and pups southern Brazil, and the Gulf of Mexico. are between 1.1 and 1.4 meters at birth. Ovoviviparous- Pregnant females give birth in April and May up to 20 young. Young are Most often found off the southwest coast born fully developed including the saw Pristis pectinata of Florida from Charlotte Harbor to the which is sheathed in a thick gelatinous Smalltooth sawfish Everglades. Juveniles live in estuaries material to protect the mother. Pups are adults move to more coastal habitats. approximately 2 ft long at birth and double in size over the first year. Gives birth to live young in shallow, nearshore areas after approximately 10 to Sphyrna lewini Open ocean environments occurring 11 months of gestation. Broods range from Scalloped over broad geographic ranges 12 to 40 pups. Size at birth approximately 15 hammerhead to 18 inches. Uses shallow bays and coastal waters as nursery areas. Plants Endemic to southeastern Florida coast Halophila johnsonii from Sebastian Inlet in Brevard County Rhizomatous seagrass that forms low mats. Johnsons seagrass to northern Biscayne Bay in Dade Does not reproduce sexually. County. Sources: NatureServe, 2019. FNAI, 2021. NOAA Fisheries, 2021a. Shuraleff II, 2000. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-25

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) to occur or likely occur in the vicinity of the PSL CWIS. Additionally, critical habitat for West Indian manatee and loggerhead sea turtle has been designated in the vicinity of the CWIS. 4.6.1.2 State-Listed Species In Florida, the list of animals designated as federally endangered or threatened, state-designated threatened, or state-designated species of special concern is maintained by FWC in accordance with sections 68A-27.003 and 68A-27.005, of the Florida Administrative Code. 4.6.1.3 Designated Critical Habitat Critical habitat has been designated in the area around PSL for the West Indian manatee and loggerhead sea turtle. Critical habitat for manatees was described in 1976 in 50 CFR 17.95 and includes coastal waters in Florida including the PSL intake and discharge canal, Indian River, and Big Mud Creek. Approximately 1,102 km (685 miles) of coastal beaches in North Carolina, South Carolina, Georgia, Florida, Alabama, and Mississippi have been designated as critical habitat for the loggerhead sea turtle, including the beaches on the ocean side of Hutchinson Island. Continued use of the CWIS at PSL is not likely to destroy or adversely modify these habitats. 4.6.2 Likelihood of Impingement or Entrainment Terrestrial species listed above are unlikely to be subject to direct effects from the CWIS. Protected aquatic species with the potential to occur near PSL include six reptiles (American alligator, loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and Kemps ridley sea turtle), one aquatic plant (Johnsons seagrass), four fish (Atlantic sturgeon, giant manta ray, smalltooth sawfish, and scalloped hammerhead), and one mammal (West Indian manatee; Table 4-5). Each of these aquatic species is discussed further in the following paragraphs. 4.6.2.1 West Indian Manatee The Florida manatee (Trichechus manatus latirostris), a subspecies of the West Indian manatee (T. manatus), was originally listed as endangered in 1967 (32 FR 4001) under the Endangered Species Preservation Act of 1966. West Indian manatees throughout their range were incorporated into the List of Endangered and Threatened Wildlife under the 1973 ESA (USFWS, Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-26

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 2017). In 2016 the USFWS issued a proposed rule to down-list the species to threatened (81 FR 1000). The reclassification was finalized in a rulemaking published on April 5, 2017 (82 FR 16668). The intake and discharge canals, Big Mud Creek, and the Indian River Lagoon are included in the designated (1976) critical habitat for the species. A Manatee Protection Plan was developed by St. Lucie County in 2002 to implement management strategies and policies to help protect manatees and manatee habitat areas (St. Lucie County, 2002). The Florida Manatee Sanctuary Act [CH. 370.12(2)(g)(5), FS], designated manatee sanctuary areas in Palm Beach County (68C-22.008) in 1994, including the Indian River and North Fork St. Lucie River. Preferred habitat for manatees typically includes inland waterways such as the Indian River Lagoon; however, they do occasionally travel up and down the coast along the shore. Habitat in the vicinity of the CWIS (e.g., Atlantic Ocean) is unsuited to support the growth of seagrasses, a major component of the manatee diet. While there is potential for the manatee to be present in the waters around the PSL CWIS, they are unlikely to spend much time there. The last time a manatee that was captured in the intake canal was in 2010. FPL coordinates the removal of these animals with appropriate agencies to safely return them to appropriate habitat (EAI, 2001). 4.6.2.2 American Alligator American alligators are large, semi-aquatic reptiles. Adults are between 10 and 15 ft in length and weigh up to 1,000 pounds with life spans exceeding 60 years. The alligator is listed due to similarity of appearance to the crocodile. Alligators are a primarily freshwater species but will venture into brackish waters and have been recorded on beaches. They lay eggs in a mounded nest near fresh water and the parents may protect the young for a period. Nests are located in marshes, or near lakes or rivers. Nesting occurs in late June to mid-July with the female laying 20 to 60 eggs. Hatchlings are approximately 6 to 8 inches long and may remain near the nest for 1 to 3 years, growing between 3 and 8 inches in length per year (SREL, 2021; NatureServe, 2021). Impingement or entrainment of adult alligators is not expected at PSL since they have strong swimming abilities that would be able to overcome intake velocities experienced at the velocity Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 4-27

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) cap. Hatchlings are unlikely to be found in the ocean. There is no record of alligators being drawn into the velocity caps. 4.6.2.3 Sea Turtles Sea turtles are long-lived large aquatic turtles that spend most of their adult lives in oceanic waters and migrate to nest on beaches. The nesting season in Florida is from March to October. Sea turtles, either endangered or threatened, are protected under the ESA and Floridas Marine Turtle Protection Act (379.2431, Florida Statutes). Five species of sea turtles may be found in the offshore waters near PSL: loggerhead, green, leatherback, hawksbill, and Kemps ridley sea turtles. Loggerhead, green, and leatherback sea turtles are known to nest on the beaches of Hutchinson Island. These five species have also been recorded in the intake canal, and FPL has a program to monitor the intake canal and return entrapped turtles to the ocean, with rehabilitation as necessary. Improvements to this program, in addition to other measures such as a series of barrier nets in the intake canal, have resulted in reductions in sea turtle mortality to a rate of 0.78 percent (EAI, 2001). A biological opinion was issued by NMFS in 2016 stating that continued operation of PSL is not likely to jeopardize the continued existence of the five species, or to destroy or adversely modify the designated critical habitat of the loggerhead sea turtle. As discussed in Section 6.0, ongoing measures for the rescue and release of sea turtles are in place at the PSL intake canal under an ITS developed by NOAA Fisheries. FPL has studied the potential to install large animal exclusion devices on the velocity caps and has concluded that such devices would increase the risk to the animals and eliminate the opportunity to rehabilitate animals injured prior to the encounter with the velocity caps. Therefore, FPL has recommended against exclusion measures. The NRC has updated its proposed action to omit exclusion devices. NOAA Fisheries is in the process of updating its biological opinion, including assessing the need for exclusion devices. Critical habitat areas for the hawksbill, leatherback, and loggerhead sea turtles were designated in 1998, 1978, and 2013, respectively. Critical habitat for loggerhead includes the area near the PSL CWIS (see Section 4.6.1.3). Critical habitats for the remaining sea turtles are not near the Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 4-28

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) CWIS. The Florida Fish & Wildlife Research Institute (FWRI) coordinates a statewide nesting beach survey program to monitor the total distribution, seasonality, and abundance of nesting sea turtles in Florida. According to nesting beach surveys conducted for loggerhead, green, and leatherback sea turtles in St. Lucie County from 2015 to 2019, the annual average of nesting individuals observed was 6,983, 690, and 114, respectively (FWC, 2021). 4.6.2.4 Atlantic Sturgeon The Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus) was listed as endangered under the Endangered Species Act in February 2012 (NOAA Fisheries, 2012). It is an ancient species dating back at least 70 million years (ASMFC, 2018) and can live up to 60 to 70 years. It takes 5 to 7 years to reach sexual maturity depending on sex. They only reproduce every 3 to 5 years which makes it hard for them to rebound from significant mortality events, thus their slow reproductive rate poses a threat for extinction. Other threats include bycatch mortality, dams blocking access to historic spawning areas, poor water quality, habitat destruction, and dredging activities (FWC, 2018; ASMFC, 2018). Historically, Atlantic sturgeon have been found from Labrador, Canada to the St. Johns River in northeast Florida. While its geographical area occupied is considered to be from Hamilton Inlet, Labrador, Canada to Cape Canaveral Florida, sightings south of the St. Johns River have been rare (NOAA Fisheries, 2016). The range of the South Atlantic Distinct Population Segment was established by NOAA Fisheries as encompassing the Ashepoo-Combahee-Edisto (ACE) Basin in South Carolina to the St. Johns River, Florida (NOAA Fisheries, 2016). Designated critical habitat in Florida is limited to the St. Marys River on the Florida-Georgia border. The St. Johns River was not included as it was considered to lack suitable habitat features. No Atlantic sturgeon has been observed at PSL among entrainment and impingement characterization efforts or incidental observations. 4.6.2.5 Smalltooth Sawfish Smalltooth sawfish are a large cartilaginous fish that live 25 to 30 years. Adults are 18 to 22 ft long and weigh up to 770 pounds. Females of this species give birth to live individuals (the saws have a protective sheath at birth) with lengths of approximately 30 inches, and the juveniles can grow up to 60 inches during the first year. Historically sawfish were found in the western Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 4-29

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Atlantic Ocean from New York to Brazil including the Gulf of Mexico, and the eastern Atlantic along the central west coast of Africa. Most occurrences in recent years have been along the western coast of Florida from Charlotte Harbor to the Everglades. Recently, the sawfish have been reported along the east coast of Florida, and seven sawfish have been caught in the Indian River Lagoon since 2016 (FAU, 2020). A smalltooth sawfish was entrapped in the intake canal in May of 2005 and a formal consultation with NMFS resulted in a biological opinion in 2016 stating that continued operation of PSL is not likely to jeopardize the continued existence of smalltooth sawfish (see Section 4.7). A second smalltooth sawfish was found in the intake canal in September 2017, a third in November 2017, and a fourth in September 2019. As discussed above relative to sea turtles, FPL has studied the potential to include large animal exclusion devices on the velocity caps. Based on its studies, FPL has concluded that such devices would increase the risk to large animals, including smalltooth sawfish, and has recommended against them in favor of continuing the rescue and release program. The NRC has updated its proposed action to omit exclusion devices. NOAA Fisheries is in the process of updating its biological opinion, including assessing the need for exclusion devices. 4.6.2.6 Giant Manta Ray The giant manta ray was listed as threatened under the Endangered Species Act on January 22, 2018 (NOAA Fisheries, 2018). The giant manta ray is the largest species of ray in the world with a wingspan of up to 29 ft. They are found in a patchy distribution in tropical, subtropical, and temperate bodies of water around the world, typically in offshore, oceanic waters and in productive coastal areas. They become sexually mature around age 5 and the mating season is early December to late April. The gestation period is approximately a year and females give birth to one or two live pups that are between 3.6 and 4.6 ft at birth (Shuralef II, 2000). Two giant manta rays have been entrapped in the intake canal, one in September 2020 and one in October 2020. Since the manta ray was not listed in 2016, they were not included in the previous biological opinion for PSL but will be addressed in the current one. Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 4-30

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 4.6.2.7 Scalloped Hammerhead A status review of scalloped hammerhead shark (Sphyrna lewini) conducted by NOAA Fisheries identified six distinct population segments (DPSs) for the species: Northwest Atlantic and Gulf of Mexico (NW Atlantic & GOM), Central and Southwest (SW) Atlantic, Eastern Atlantic, Indo-West Pacific, Central Pacific, and Eastern Pacific (Miller et al., 2014). The Central & SW Atlantic DPS and Indo-West Pacific DPS are listed as threatened under the ESA, and the Eastern Atlantic DPS and Eastern Pacific DPS are listed as endangered, effective September 2, 2014 (79 FR 38213; July 3, 2014). PSL is located within the NW Atlantic & GOM DPS which is currently not listed under the ESA; however, the adjacent waters off the western Bahamas and the Caribbean Sea are contained within the Central and SW Atlantic DPS. Scalloped hammerheads are found in coastal areas in the tropical and subtropical waters around the globe (Miller et al., 2014). They are mobile and partially migratory along continental waters and between oceanic islands. They grow to around 11 ft in length and can live over 30 years. This shark is viviparous with females moving inshore to birth between one and 40 live pups. Mating behavior is not fully understood. The gestation period is between 6 to 12 months and females are thought to reproduce every other year (Ruiz and Trujillo, 2012). Pups are 1 to 2 ft in length at birth and juveniles spend their first 2 years inshore (Florida Museum, 2021). Encounters with scalloped hammerheads at PSL have been rare with one captured live in 1997 and sent to the Florida Aquarium and one captured live in 2012 and returned to the ocean. 4.6.2.8 Johnsons Seagrass Johnsons seagrass is federally listed as threatened throughout its range and is known to occur in patchy distributions (IPAC, 2021). St. Lucie County is part of the USFWS Johnsons seagrass range (IPAC, 2021), and scattered beds of this species have been documented within the Indian River Lagoon. Critical habitat for Johnsons seagrass was designated on April 5, 2000 including near Fort Pierce Inlet (9 miles north of the St. Lucie Plant) and north of St. Lucie inlet (5 miles south of the St. Lucie Plant; NOAA Fisheries, 2021b). Johnsons seagrass is unlikely to be found near the CWIS due to lack of suitable habitat, wave action and sediment instability. Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 4-31

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 4.7 Documentation of Consultation with Services 40 CFR 122.21(r)(4)(vii)Documentation of any public participation or consultation with Federal or State agencies undertaken in development of the plan; A series of biological opinions have been issued to the NRC for the St. Lucie Plant by NOAA Fisheries regarding sea turtle takes. In 1982 NOAA Fisheries concluded that the operation of Unit 2 was not likely to jeopardize the continued existence of any listed species under its jurisdiction based on the history of sea turtle takes at Unit 1. After an increase in sea turtle takes at PSL, NRC reinitiated consultations in 1995 and a 1997 biological opinion was issued by NOAA Fisheries that also concluded the St. Lucie Plant was not likely to jeopardize the continued existence of any ESA-listed species under its jurisdiction. It included incidental take statements for five sea turtle species (loggerhead, Kemps ridley, green, leatherback, and hawksbill). This anticipated incidental take was exceeded in 1999 and the NRC reinitiated consultation in 2000. A biological opinion was subsequently issued on May 4, 2001 that concluded again that the continued operation of the St. Lucie Plant was not likely to jeopardize the continued existence of green, leatherback, hawksbill, Kemps ridley, and loggerhead sea turtles. Another incidental take statement was issued allotting take for each of the species, and the biological opinion was valid until May 4, 2011. In 2002, NRC requested informal consultation for license renewal for PSL, and NOAA Fisheries responded that no consultation was necessary. On May 16, 2005, a non-lethal smalltooth sawfish incidental take occurred at PSL. This species was listed in 2003 after the 2001 biological opinion and was therefore not included in that analysis. In 2006, the allowable incidental take for sea turtles was exceeded and consultation for sea turtles was reinitiated. The biological opinion issued on March 24, 2016 concluded that the continued operation of the PSL is not likely to jeopardize the continued existence of green sea turtle, hawksbill sea turtle, Kemps ridley sea turtle, leatherback sea turtle, Northwest Atlantic distinct population segment of loggerhead sea turtle, or U.S. distinct population segment of smalltooth sawfish or to destroy or adversely modify the designated critical habitat of the loggerhead Northwest Atlantic distinct population segment. Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 4-32

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) As noted above, consultation with NOAA Fisheries is ongoing and an updated biological opinion is expected in the next several months. It is expected to include consideration of the giant manta ray and scalloped hammerhead. Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 4-33

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 5.0 Cooling Water System Data 40 CFR 122.21(r)(5) This section provides information on the cooling water system, with Final Rule-required components listed at the beginning of each subsection. 5.1 Cooling Water System Description §122.21(r)(5)(i)A narrative description of the operation of the cooling water system and its relationship to cooling water intake structures; the proportion of the design intake flow that is used in the system; the number of days of the year the cooling water system is in operation and seasonal changes in the operation of the system, if applicable; the proportion of design intake flow for contact cooling, non-contact cooling, and process uses; a distribution of water reuse to include cooling water reused as process water, process water reused for cooling, and the use of gray water for cooling; a description of reductions in total water withdrawals including cooling water intake flow reductions already achieved through minimized process water withdrawals; a description of any cooling water that is used in a manufacturing process either before or after it is used for cooling, including other recycled process water flows; the proportion of the source waterbody withdrawn (on a monthly basis). PSLs cooling water system is a once-through circulating system utilizing a single condenser per unit to remove heat from the steam turbine exhaust and condense the steam for return to the steam cycle. As described in Section 3, the cooling water system consists of three offshore velocity cap intakes, an intake canal, four intake bays per unit with bar screens preceding standard 3/8-inch traveling screens, a discharge canal, and two offshore discharges. Unit 1 utilizes four circulating water pumps, each rated at 121,000 gpm (174.24 MGD), for a total of 484,000 gpm (696.96 MGD). Unit 1 also has three auxiliary water pumps, also known as the intake cooling water pumps (two duty, one spare), each rated at 14,500 gpm (20.88 MGD), for a total of 29,000 gpm (41.76 MGD). The Unit 1 condenser is supported by the circulating water pumps; therefore, the Unit 1 condenser water flowrate is 484,000 gpm (696.96 MGD) and the units total water use rate is 513,000 gpm (738.7 MGD). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 5-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Unit 2 also has four circulating water pumps each rated slightly higher at 122,650 gpm (176.62 MGD), for a total of 490,600 gpm (706.46 MGD). Unit 2 also has three auxiliary water pumps (two duty, one spare), each rated at 14,500 gpm (20.88 MGD), for a total of 29,000 gpm (41.76 MGD). The Unit 2 condenser is supported by the circulating water pumps; therefore, the Unit 2 condenser water flowrate is 490,600 gpm (706.46 MGD) and the units total water use rate is 519,600 gpm (748.2 MGD). The total DIF for the two units is 1,487 MGD. The bar screens are raked periodically depending on debris loads, and material is removed from the racks for offsite disposal as required by the plants NPDES permit. 5 The traveling screens are rotated periodically, with a minimum of twice every 24 hours. During periods of heavy sea grass accumulation, abundant jellyfish, or high debris loads, the screens may be run continuously. Each unit operates 24 hours per day, 365 days a year unless it is offline for a refueling or maintenance outage (outages are planned to affect only a single unit at a time). There are no seasonal changes in operation. From 2015 through 2019, the total CWIS withdrawal averaged 1,389 MGD. The cooling water system has a design intake flow of 1,487 MGD. At this DIF, the through-screen velocity is 2.6 ft/s. 5.2 Calculations and Supporting Data §122.21(r)(5)(ii)Design and engineering calculations prepared by a qualified professional and supporting data to support the description required by paragraph (r)(5)(i) of this section. 5.2.1 Through-screen Velocity Calculations For the design and configuration of the CWIS (See Section 3 for more details) two-unit operation (1,487 MGD DIF), the calculated through-screen velocity (v) is: 1 1 1

      = (   ) x (1,000,000) x                             x                x 24              60       60 0.1337  3                            1 x                 x 5

The bar screen rakes were upgraded in 2017 and 2018 with a Flexrake System. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 5-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 1 1 1 1

      = (1,487) x (1,000,000) x                      x   x   x (0.1337) x 24           60      60                               888.7
      = 2.6 /

where: total open area = 8 x x

                                         = 8 x 10  ()  23  (  )  0.483
                                         = 888.7  2 Screen open area is based on 12-gauge (0.105-in) wire and screen mesh openings of 0.375 inches by 0.375 inches.

5.2.2 Proportion of Source Water Body Withdrawn Cooling water at PSL is withdrawn from the Atlantic Ocean. Unlike intakes located on lakes or rivers, the ocean provides a comparably limitless supply at a scale that does not lend itself to a proportional calculation. As described in Section 2.1, the depth near the intake is approximately 20 ft and slopes to approximately 40 ft roughly 1 mile offshore, rises back to approximately 25 ft at Pierce Shoal almost 2.5 miles offshore. Beyond the shoal, the depth increases out across the continental shelf to approximately 300 ft, beyond which the depth off the Florida coast averages approximately 11,000 ft. As discussed in Section 2.2.1, the prevailing current travels to the north along the coastline near PSL at an average speed of 0.74 ft/s at the surface and 0.54 ft/s near the bottom. While other processes such as tides and wind drive water mixing, consideration of this current alone allows for a comparison of two rates of flow: the volume moving with the current and that withdrawn by the intake. For the purposes of this calculation, the volume of water passing the vicinity of the intake during a 24-hour period (Qa) is considered and compared to the volume withdrawn by the CWIS (the DIF) (Qi) for the same period: Percent of water body withdrawn = x 100% 1.99 8 3

      =  = 1,487  =

Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 5-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

      =  x  x 
           = 8.4 9 ft3/day where: D = average water column depth along a one-mile cross-section normal to the shoreline (perpendicular to current flow) encompassing the intake = 25 ft.

L = length of cross-section set at distance of intake from the shoreline but centered on intake = 1 nautical mile or 6,077 ft. 6 S = depth-averaged speed of water across cross-section = 0.64 ft/s or 55,296 ft per day. By this calculation the percent of nearshore current withdrawn on a daily basis is estimated to be 2.4 percent. Because of the consistent nature of this current, the percent of source water withdrawn would be the same if calculated on a monthly basis. 5.3 Description of Existing Impingement and Entrainment Reduction Measures §122.21(r)(5)(iii)Description of existing impingement and entrainment technologies or operational measures and a summary of their performance, including but not limited to reductions in impingement mortality and entrainment due to intake location and reductions in total water withdrawals and usage. FPL designed the CWIS to utilize water from the Atlantic Ocean as opposed to an intake on the more biologically productive Indian River Lagoon estuary. The CWIS employs an offshore velocity cap design to minimize impingement of fish and other aquatic organisms. The offshore location was identified following baseline habitat surveys and selected to avoid hard bottom substrate and the more biologically productive beach terrace and inshore worm reef habitats (FPL, 2001). The velocity caps are designed to withdraw water in a horizontal flow which fish can detect and avoid more easily than a vertical intake flow. The mid-depth location of the velocity caps avoids entraining eggs and larvae that may congregate near the surface or bottom 6 While selection of this distance is subjective, it is consistent with the mixing of the system perpendicular to the shoreline associated with tidal and wind-driven currents. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 5-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) depths. Such a technology is determined by the Final Rule to constitute BTA for IM as described at 40 CFR 125.94(c)(4) (see Section 6.0). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 5-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 6.0 Chosen Method(s) of Compliance with Impingement Mortality Standard 40 CFR 122.21(r)(6) 6.1 Introduction and Background Under the Final Rule, PSL must submit information required in the 40 CFR 122.21(r)(6), Chosen Method(s) of Compliance with Impingement Mortality Standard. The Final Rule under 40 CFR 125.94(c) provides seven alternative compliance options for meeting impingement mortality requirements (Table 6-1) discussed below. Two other options defined by the rule that allow for flexibility in the impingement mortality BTA requirements (rates of impingement that are de minimis and generating capacity factors of less than eight percent) are not applicable to PSL and are not discussed further. Table 6-1. Review of the Final Rules BTA Alternatives for Impingement Impingement Mortality BTA Approach (#) per 40 CFR 125.94(c) (1) Closed-cycle cooling (2) Through-screen velocity less than 0.5 ft/s; DIF (3) Through-screen velocity less than 0.5 ft/s; AIF (4) Existing Offshore Velocity cap (5) Modified traveling screens (6) System of technologies (7) Impingement mortality performance standard (<24 percent mortality) (11) De minimis rate of impingement (12) Capacity utilization rate less than 8 percent Note: AIF = actual intake flow. BTA = best technology available. CFR = Code of Federal Regulations. DIF = design intake flow. ft/s = foot per second. Source: EPA, 2014. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 6-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) The text of 40 CFR 122.21(r)(6) is as follows: The owner or operator of the facility must identify the chosen compliance method for the entire facility; alternately, the applicant must identify the chosen compliance method for each cooling water intake structure at its facility. The applicant must identify any intake structure for with a BTA determination for Impingement Morality under 40 CFR 125.94 (c)(11) or (12) is requested. In addition, the owner or operator that chooses to comply via 40 CFR 125.94 (c)(5) or (6) much also submit an impingement technology performance optimization study as described below: (i) If the applicant chooses to comply with 40 CFR 125.94(c)(5), subject to the flexibility for timing provided in 40 CFR 125.95(a)(2), the impingement technology performance optimization study must include 2 years of biological data collection measuring the reduction in impingement mortality achieved by the modified traveling screes as defined at 40 CFR 125.92(s) and demonstrating that the operation has been optimized to minimize impingement mortality. A complete description of the modified traveling screens and associated equipment must be included, including, for example, type of mesh, mesh slot size, pressure sprays and fish return mechanisms. A description of any biological data collection and data collection approach used in measuring impingement morality must be included: (A) Collecting data no less frequently than monthly. The Director may establish more frequent data collection: (B) Biological data collection representative of the impingement and the impingement mortality at the intakes subject to this provision; (C) A taxonomic identification to the lowest taxon possible of all organisms collected; (D) The method in which naturally moribund organisms are identified and taken into account; (E) The method in which mortality due to holding times is taken into account; (F) If the facility entraps fish or shellfish, a count of entrapment, as defined at 40 CFR 125.92(j), as impingement mortality; and (G) The percent impingement mortality reflecting optimized operation of the modified traveling screen and all supporting calculations. (ii) If the application chooses to comply with 40 CFR 125.94(c)(6), the impingement technology performance optimization study must include biological data measuring the reduction in impingement mortality achieved by operation of the system of technologies, operational measures and best management practices, and demonstrating that operation of the system has been optimized to minimize impingement mortality. This system of technologies, operational measures and best management practices may Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 6-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) include flow reductions, seasonal operation, unit closure, credit for intake location, and behavioral deterrent systems. The application must document how each system element contributes to the systems performance. The application must also include a description of any sampling or data collection approach used in measuring the rate of impingement mortality achieved by the system. The application must also include a description of any sampling or data collection approach used in measuring the rate of impingement, impingement mortality, or flow reductions. The following section presents PSLs proposed basis of impingement mortality BTA. PSLs proposal for impingement mortality is based on three separate lines of evidence:

• The current intake largely conforms with the requirements of impingement mortality BTA as defined by the rule per 40 CFR 125.94(c)(4).
• The single departure from the definition of velocity caps at 40 CFR 125.92(v) (use of large animal barriers) has been extensively studied and FPL has concluded that such barriers would increase the risk to protected species and reduce the opportunities to rehabilitate sick and injured animals.
• No alternative approach to impingement mortality BTA is reasonable given the configuration of the existing intake, the facility, and the source water.
• The potential for additional measures to protect federally listed species is being pursued separately under the ESA as no rule-related IM BTA would adequately address interactions with sea turtles, smalltooth sawfish, giant manta rays, or scalloped hammerhead sharks.

Each of these factors is discussed in Section 6.2 and FPLs recommendation for IM BTA is made in Section 6.3. Based on this proposal, impingement mortality BTA under 40 CFR 125.94(c)(5) or (6) is not being proposed, making submittals under 40 CFR 122.21(r)(6)(i) and (ii) irrelevant. 6.2 Evaluation of Options to Address the Impingement Mortality Standard of 40 CFR 125.94(c) The rule allows for seven different approaches to IM BTA at affected facilities, each of which, if it meets the goals defined for the approach by the Final Rule, would be considered fully compliant. In addition, two other plant-related circumstances allow the NPDES Director to Y:\GDP\F1301\150595\316BR\1-9.DOCX040121 6-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) additional latitude in considering IM BTA: the potential for de minimis rates of impingement, per 40 CFR 125.94(c)(11), and a capacity utilization rate of less than eight percent over the preceding 24 month-period, per 40 CFR 125.94(c)(12). Depending upon site-specific considerations, the potential to retrofit to achieve each of the seven IM BTA options is likely to vary substantially in terms of feasibility, cost, and effectiveness. In addition, some alternatives have performance standards and/or conformational studies that should be considered. The following subsections describe the current cooling water intake structure at PSL relative to the IM BTA options, reviews the potential that additional control measures might be considered to protect federally listed species with an emphasis on summarizing FPLs efforts to understand if barriers on the velocity caps would be protective; and provides a brief review of the other options that were considered at the plant. 6.2.1 The Existing Intake is Largely Compliant with the Requirements of an Offshore Velocity Cap The following is an excerpt of the Final Rules standards for impingement mortality summarizing the requirements of compliance by use of an existing offshore velocity cap: 40 CFR 125.94(c) BTA Standards for Impingement Mortality. (4) Existing offshore velocity cap. A facility must operate an existing offshore velocity cap as defined at § 125.92(v) that was installed on or before October 14, 2014. Offshore velocity caps installed after October 14, 2014 must make either a demonstration under paragraph (c)(6) of this section or meet the performance standard under paragraph (c)(7) of this section. In addition, you must monitor your intake flow at a minimum frequency of daily; The rules definition of offshore velocity cap is provided in the excerpt of the rule provided here: 40 CFR 125.92 Special Definitions (v) Offshore velocity cap means a velocity cap located a minimum of 800 ft from the shoreline. A velocity cap is an open intake designed to change the direction of water withdrawal from vertical to horizontal, thereby creating horizontal velocity patterns that result in avoidance of the intake by fish and other aquatic organisms. For purposes of this subpart, the velocity cap must use bar screens or otherwise exclude marine mammals, sea turtles, and other large aquatic organisms. Y:\GDP\F1301\150595\316BR\1-9.DOCX040121 6-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) PSLs intake configuration is consistent and compliant with the impingement mortality BTA requirements as defined by 40 CFR 125.94(c)(4) and 125.92(v) with the exception of inclusion of bar screens or similar mechanisms to exclude large animals (see Table 6-2). The evaluation of exclusion devices for sea turtles and other large animals is discussed below. Table 6-2. Review of Existing Offshore Velocity Cap Performance Criteria Requirement Characteristic of PSLs Intake 125.94(c)(4) - caps must be The velocity caps were constructed with the original facility and have constructed prior to October 14, been in use since the start of operation in 1976 and 1983 for Units 1 2014 and 2, respectively. 125.92(v) - cap must be located Three velocity caps are located approximately 1,200 ft offshore. at least 800 ft from the shoreline The design of the velocity caps is a standard one to achieve 125.92(v) -cap must be created horizontal flow and the permitting record makes clear that such was to induce horizontal flow the objective of the design. In coordination with NOAA Fisheries and other experts, FPL has investigated the potential design of exclusion devices including excluder device testing. After several years of investigation, FPL and 125.92(v) -cap must use bar its experts have concluded that any such exclusion device(s) is likely screens or otherwise exclude to result in increased risk to the listed large animals. The NRC has marine mammals, sea turtles, updated its proposed action to omit exclusion devices. NOAA and other large aquatic Fisheries is in the process of updating its biological opinion, organisms including assessing the need for exclusion devices. The current NOAA Fisheries-approved program of collection followed by potential rehabilitation and release mitigates the capture of large animals by the velocity caps. Source: 40 CFR 125. The current agency-endorsed practice at PSL is to collect large animals that are drawn into the velocity cap as they appear in the intake canal. In the context of these large animals, entrance to the velocity cap and intake canal has been referred to as entrainment 7. The focus of the current rescue and return system 8 is sea turtles, for which this practice is described in a biological 7 Entrainment in this context differs from the Final Rules definition in that it applies to large organisms that are drawn into the intake canal where they are retained within the eastern portion of the canal by barrier nets. Entrainment does not refer to the forced passage of smaller organisms through the cooling system, including the circulating water pumps and the condensers. For clarity, occurrences of large animals being drawn into the intake canal will be labeled entrainment with quotes and the more standard definition applicable to small animals will omit the quotes. 8 Rescue and return is used here to describe the combined monitoring of the canal, removal of sea turtles and smalltooth sawfish, evaluation of the animals, transport to rehabilitation experts as necessary, and return of the animals to the environment. Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 6-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) opinion developed by NOAA Fisheries 9. Capture and evaluation of such animals is done by permanent staff with appropriate training. The initial reach of the intake canal is arrayed with barrier nets to facilitate collection and prevent interaction of the animals with the trash rakes and traveling water screens. Under the provisions of the biological opinion, captured animals are assessed and either returned to the source water or, if the animals condition demands, brought to a rehabilitation facility for treatment and subsequent release. It is common for sea turtles encountered in the canal to be sick or injured (e.g., boat strike, shark bite, entanglement, etc.) before their interaction with the cooling water intakes. Therefore, the program provides care to animals that they would not otherwise receive. Such a program of rescue and return is unusual among 316(b)-regulated facilities and it greatly supplements the action of the velocity cap to reduce impingement rates, particularly for sea turtles which do not apparently respond to hydraulic cues as reliably as fish. As described below, FPL believes that this approach is more protective of the affected animals than installation of bar screens or other similar barriers on the velocity caps (see Sections 6.2.2 and 6.2.3). FPL believes that such a program not only avoids the risk to the animals at the exclusion devices, as observed in the excluder device tests, but it results in rehabilitation of animals that have been injured elsewhere and are found in the intake canal. FPL notes that installation of exclusion devices at the velocity caps, if effective, would likely result, over several years, in lower costs to the plant than the current program of monitoring, collection, and release. Despite this, FPL endorses continuation of the current practice as more protective albeit at higher cost to the company. FPL notes that the design basis of velocity caps, and their basis of reducing impingement, is the creation of a horizontal flow field that provides avoidance cues to swimming fish as well as 9 The biological opinion related to sea turtles is in the process of being reassessed by NOAA Fisheries. An update to the existing Incidental Take Statement is expected in the coming months. As described in Section 11, FPL believes that this assessment is, in most ways, independent of the 316(b) process, including the fact that the potential approaches to IM and entrainment BTA would not address the collection of sea turtles and other large animals in the intake canal. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 6-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) placement in offshore waters which exhibit lower densities of impingeable fish (EPA, 2014). The three velocity caps at PSL were created with the appropriate design objectives and achieve them. The Final Rule included the large animal exclusion requirement, which is not part of the standard, historical design and does not contribute to the impingement reduction performance of the caps. Therefore, FPL concludes that the existing velocity caps effectively reduce impingement consistent with their design and the goals of the Final Rule even in the absence of large animal exclusion devices. The issues associated with potential large animal exclusion devices are discussed further in the following subsection. 6.2.2 Overview of FPLs Assessment of Exclusion Devices at the Velocity Cap The NRC has engaged NOAA Fisheries in a consultation under Section 7 of the ESA to consider measures to minimize or eliminate entrainment of federally listed species into the velocity caps and the intake canal. This process began in 2007 after the site exceeded the take of sea turtle hatchlings in 2006, believed to be derived from a nest on the banks of the intake canal. In 2016, NOAA Fisheries issued a biological opinion requiring PSL to install barriers on the velocity caps to avoid and minimize entrainment of mature egg-bearing sea turtles. In coordination with NOAA Fisheries and the NRC, a design and testing study of the barrier was executed beginning in 2016. Testing involved a test tank facility for observing and evaluating sea turtle interactions with a model velocity cap and prototype barrier. Ten loggerhead and four green turtles of various sizes were included in the test plan. Nine turtles were successfully exposed to the barrier without failure. During the testing of the barrier with the tenth turtle, the turtle appeared to become wedged between the barrier and the mock velocity cap structure, requiring the testing to be stopped and the turtle to be freed from the barrier without injury. 10 The animal was uninjured, but the testing was suspended at the direction of the NRC and NOAA Fisheries. With the apparent failure of the barrier system, FPL convened a group of four experts to evaluate the test data. With the help of the experts, FPL considered two alternative actions: 10 Ongoing visual monitoring of the offshore velocity caps and reliable, timely response to an animal trapped by barriers installed there would not be possible. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 6-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

• Attempt a redesign and retesting of a barrier system; or
• Maintain the current rescue and release program and minimize negative impacts associated with entrainment and travel through the intake pipe.

Based on the available evidence and in consultation with the experts, FPL has concluded that:

• Any barrier design would present the potential for a turtle to be injured or killed; and
• Excluding turtles with illness and/or injuries not caused by the CWIS reduces the opportunities for rescue and rehabilitation.

In recommending that maintenance of the current program be continued, FPL notes that the rate of injury or death to entrained animals is very low and that the NOAA Fisheries biological opinion found there was no jeopardy for green, hawksbill, Kemps ridley, leatherback, or loggerhead sea turtles. FPL also notes that smalltooth sawfish have been entrained into the PSL intake canal at much lower rates than sea turtles. Both NOAA Fisheries and NRC are aware of these events and FPL has trained its staff for the safe handling and return of smalltooth sawfish. FPL has concluded that installation of barriers on the velocity caps would likely also put the smalltooth sawfish at increased risk. Therefore, FPL has requested of both NRC and NOAA Fisheries that the current practice of rescue and release of sea turtles and smalltooth sawfish be continued without installation of barriers on the velocity caps. In summary, FPL has concluded that the continuation of the program of rescue and release without installation of barriers on the velocity caps is the best available option because:

• It avoids the demonstrated risk to sea turtles and smalltooth sawfish associated with installation of exclusion barriers at the velocity caps.
• There is a very low rate of injury of sea turtles associated with entrainment into the intake tunnel and canal and any injury does not result in jeopardy to the local populations.
• It allows the benefit of rescue, rehabilitation, and release of sick or otherwise injured animals that would be precluded by installation of barriers at the velocity cap.

As the 316(b) reports for PSL are being completed, the NRC has updated its proposed action to omit exclusion devices. NOAA Fisheries is in the process of updating its biological opinion, Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 6-8

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) including assessing the need for exclusion devices. FPL anticipates one of two outcomes of NOAA Fisheries reassessment:

• Allow for the continuation of the current operations, potentially with additional conditions of the rescue and release program.
• Require the reassessment of barriers at the velocity caps likely including additional exclusion device testing.

In either case, FPL recommends that the existing offshore velocity caps should be considered impingement mortality BTA. In the event of the first outcome, NOAA Fisheries will have found that the requirement for barriers in the Final Rule results in less protection of the animals of concern so it is highly reasonable, if not essential, to neglect that aspect of the definition. In the case of the second outcome, FPL will return to the task of designing and testing a protective barrier with the objective of installing a barrier consistent with the Final Rule. FPL also notes that consideration of measures to protect federally listed species is an ongoing obligation of the ESA and, for the species affected at PSL, NOAA Fisheries. As described in the next section, FPL believes that measures specified by the Final Rule to reduce impingement mortality are not ideally suited for the protection of federally listed species such as sea turtles and smalltooth sawfish. FPL believes, instead, it is appropriate for NOAA Fisheries to consider measures that are both species- and site-specific to best achieve that protection. 6.2.3 No Alternative Impingement Mortality BTA Measure is Reasonable While its existing intake structure is functionally BTA for impingement mortality under the Final Rule due to the installed velocity caps, PSL has evaluated the potential that alternative impingement mortality BTA measures might provide more effective impingement mortality controls at a reasonable cost. This review considers the site-specific constraints on technology operation and effectiveness as well as the approximate cost of the measure (Table 6-3). Based on FPLs review of alternative impingement mortality BTA measures offered by the Final Rule, FPL finds that there are no alternative measures that would substantially reduce or eliminate entrainment in the intake canal of federally listed species. Y:\GDP\F1301\150595\316BR\1-9.DOCX040821 6-9

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 6.3 Proposed IM BTA Measure Based on the information presented above and the ongoing role of NOAA Fisheries in the protection of federally listed species, FPL requests that its existing system of offshore velocity caps be determined to be impingement mortality BTA under 40 CFR 125.94(c)(4). FPL acknowledges that NOAA Fisheries may require additional measures for the protection of federally listed species but does not believe that any of those measures will include the alternative forms of IM BTA offered by the Final Rule. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 6-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 6-3. Review of Alternative Impingement Mortality BTA Approaches at PSL 40 CFR 125 Title and Summary Advantages Disadvantages Decision and Basis

    .94(c)

Rejected. Costs are prohibitive given effectively Costs of construction as well as costs for lost compliant alternative for IM BTA and the generation due to parasitic load, loss of efficiency, likelihood that effects on listed species would and construction down time far higher than continue, even when making up a CCRS. EPA did alternatives. not intend the rule to force CCRS retrofit to Provides a strong basis for IM Other environmental impacts (e.g., saltwater drift) address IM BTA alone: As stated in the June 11, BTA under the rule. Potential result. 2012 NODA, EPA does not intend for facilities to for reduced rates of Closed-cycle install closed-cycle cooling solely for the purpose impingement. Entrainment Flow reduction from current condition is Recirculating System of meeting the IM requirements. In fact, EPA (1) rates would be reduced - costs relatively limited due to the need to cap increases consistent with expects all facilities could comply with IM and benefits relative to in chloride concentration. 40 CFR 125.92(c) requirements without relying on retrofitting to entrainment are assessed in closed-cycle cooling. 11 Sections 10 through 12 of this Given that no alternative water supply exists, the submittal. rate of water withdrawal would remain high, and Entrainment of listed species is expected to be the listed species would be extremely likely to continued given that intake flow for cooling tower continue to be entrained into the intake canal. makeup and blowdown dilution would exceed The need for monitoring and rescue of listed 100 MGD. The need for rescue and release species would continue. program would continue. Rejected. Capital and operation/maintenance costs would be very high relative to fully compliant The intake structure must be greatly expanded to existing intake. Permitting of construction achieve lower intake velocity resulting in greatly associated with waterways impacts would be increased costs as well as permitting constraints extremely challenging. relative to existing intake. The likely need for 0.5 ft/s Through-screen None over existing (2) intake screens at the point of 0.5 ft/s application Wedgewire screens are not feasible. The Design Velocity configuration. would require either an onshore traveling screen, alternative means of achieving reduced intake with the loss of the offshore advantages or an velocity, expanded MTWS downstream of the offshore wedgewire array that would be very velocity caps, would not eliminate capture of costly and infeasible (see Section 10.5). listed species within the intake canal. The need for rescue and release of listed species from the canal would have to be continued. See discussion of alternative 2. To maintain its full generation capacity, PSL must Rejected. PSL must be able to pump its full design Potential for smaller intake to be able to pump cooling water at its full design 0.5 ft/s Through-screen intake flow at times to generate its full power (3) achieve reduced velocity if intake flow. Full capacity operation is the routine Actual Velocity output. actual intake flow is applicable condition at PSL. Such operation would not meet See above for IM BTA alternative 2. at all times. the requirements of 40 CFR 125.94(c)(3). 11 EPA. 40 CFR Parts 122 and 125. National Pollutant Discharge Elimination System - Final Regulations to Establish Requirements for Cooling Water Intake Structures at Existing Facilities and Amend Requirements at Phase I Facilities; Final Rule. Federal Register Volume 79. p. 48329. August 15, 2014. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 6-11

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 6-3. Review of Alternative Impingement Mortality BTA Approaches at PSL (Continued, Page 2 of 2) 40 CFR 12 Title and Summary Advantages Disadvantages Decision and Basis 5.94(c) NA. Largely compliant impingement mortality BTA at no additional capital costs. Inclusion of Existing Offshore large animal exclusion devices believed to (4) Velocity Cap per Existing intake configuration None. increase risk to listed species. Existing rescue 40 CFR 195.92(v) and release program for listed species is effective. (see Section 6.2.2). Relatively high construction and maintenance costs. Position of traveling water screens interior to the intake system reduces biological Rejected. Capital, operation, and study costs are effectiveness. Fish return would be costly and of higher than fully compliant existing measure. No biological performance dubious effectiveness given inland position of the Reductions in impingement mortality likely to be Modified Traveling goal. Effective at higher intake screen houses. negligible. Impingement of federally listed species (5) Screens per velocities allowing for lower on MTWS is not a desirable outcome as their size 40 CFR 125.92(s) construction and operation Federally listed species are likely to be injured by is likely to preclude safe handling and return. The costs. exclusion and handling at MTWS. need for rescue and release program for listed species from the canal would continue. Costly requirement to perform 2 years of optimization studies per 40 CFR 122.21(r)(6)(i). Potential for application of quantitative performance goal. Allows for consideration of Difficulty in quantifying some bases of IM Rejected. Regulatory uncertainty increased. No System of Technologies multiple factors in reductions reduction (e.g., effect of intake position). clear basis to demonstrate improved listed species (6) as BTA for to IM (e.g., flow reduction, Costly requirement to perform 2 years of performance through a system of measures. The Impingement Mortality intake position and optimization studies per 40 CFR 122.21(r)(6)(i). need for rescue and release program for listed configuration, etc.) Flow reduction with variable speed pumps species from the canal would continue. unlikely to be effective given the high-capacity factor and high AIF relative to DIF. Rejected. Unacceptable regulatory risk. The preamble to rule acknowledges that few, if any, Includes ongoing performance monitoring and facilities are likely to pursue this alternative due to Impingement Mortality None apparent relative to IM (7) includes quantitative performance standard. Costs the risk and more favorable alternatives. Performance Standard BTA measure (4). are not reduced relative to IM BTA measure (4). No improvement in the protection of federally listed species would occur. Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 6-12

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 7.0 Previous Studies 40 CFR 122.21(r)(7) The final rules requirements for submittal of information from previous entrainment performance studies are as follows: 40 CFR 122.21(r)(7)The owner or operator of an existing facility must submit any previously conducted studies or studies obtained from other facilities addressing technology efficacy, through-facility entrainment survival, and other entrainment studies. Any such submittals must include a description of each study, together with underlying data, and a summary of any conclusions or results. Any studies conducted at other locations must include an explanation as to why the data from other locations are relevant and representative of conditions at your facility. In the case of studies more than 10 years old, the applicant must explain why the data are still relevant and representative of conditions at the facility and explain how the data should be interpreted using the definition of entrainment at 40 CFR 125.92(h). This section describes the historical entrainment studies conducted at the St. Lucie Plant and include sampling in the intake and discharge canals from 1977 through 1981, and similar studies under the Phase II rule in the mid-2000s. 7.1 1976 to 1983 Studies Studies were conducted at the St. Lucie Plant in the 1970s and 1980s with Unit 1 being operational and prior to the construction of Unit 2. Paired bongo nets were used to collect ichthyoplankton in the intake canal and nearshore habitats on a twice-monthly basis. Six ocean stations, one station in the intake canal, and one station in the discharge canal were sampled twice a month during the day using paired 20-centimeter, 505-micron mesh bongo nets. In the offshore stations the nets were towed for 15 minutes just below the surface. A mid-depth sample was taken near the intake, and step-oblique tows were taken in the canals. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 7-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Sample analysis showed the mid-water samples near the intake had lower densities of ichthyoplankton than the surface samples, the intake canal had lower densities than the ocean, and the discharge canal had lower densities than the intake canal. The most common larval fish collected were herrings and anchovies, suggesting the unidentifiable eggs collected were likely the same species. Blennies, gobies, mojarras, drums, and jacks were also dominant. Entrainment at PSL was estimated based on localized densities of entrainable organisms near the intake. Entrainment sampling was conducted over a five-year period and concluded, under normal conditions, approximately 0.4 percent of the fish eggs and larvae passing the intake would be subject to entrainment. Therefore, the NRC determined the St. Lucie Plant would have a minimal effect on the local fish populations. 7.2 Phase II Studies Studies were conducted in January 2006 to October 2007 in response to the release of the Phase II rule to characterize the biological community in the vicinity of the St. Lucie Plant. Plankton samples were collected by suspending a plankton net at mid-depth at the inlet of the intake canal and fished for 5 or 10 minutes, depending on whether one or two units were operating. Fish densities from plankton collections peaked in the late spring and late summer. Densities in the intake canal were low throughout the study. A high percentage of the catch in the intake canal was unidentifiable (74.5 percent) due to developmental stage (35 percent undeveloped), damaged (24 percent), or otherwise unidentifiable (15 percent). Drums (9.5 percent) and anchovies (4 percent) were the most commonly identified. Densities of shellfish in the intake canal were also low throughout the study and dominated by brachyuran crabs (Brachyura, 64 percent), sergestid shrimp (Sergestoidea, 9 percent), and caridean shrimp (Caridea, 7 percent). Figure 7-1 depicts the seasonality of fish and shellfish entrainment, and Figure 7-2 shows the species composition. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 7-2

7-3 180 160 140 120 100 80 60 40 0 5 10 15 20 25 30 20 0 01/13/06 01/13/06 01/25/06 01/25/06 02/08/06 Source: FPL 2017 02/08/06 FIGURE 7-1. 02/22/06 02/22/06 03/22/06 03/22/06 03/30/06 03/30/06 04/05/06 04/05/06 04/19/06 04/19/06 05/04/06 05/04/06 05/17/06 05/17/06 05/31/06 05/31/06 06/14/06 06/14/06 06/28/06 06/28/06 07/12/06 07/12/06 07/26/06 07/26/06 08/07/06 08/07/06 08/23/06 08/23/06 09/06/06 09/06/06 09/20/06 09/20/06 10/09/06 10/09/06 10/18/06 10/18/06 11/02/06 11/02/06 11/15/06 11/15/06 Fish 12/04/06 12/04/06 Shellfish 12/14/06 12/14/06 12/29/06 12/29/06 01/09/07 01/09/07 01/23/07 01/23/07 SEASONAL PATTERNS IN 2006-2007 PSL ENTRAINMENT STUDY RESULTS 02/07/07 02/07/07 02/21/07 02/21/07 03/07/07 03/07/07 04/04/07 04/04/07 04/17/07 04/17/07 05/03/07 05/03/07 05/17/07 05/17/07 05/30/07 05/30/07 06/12/07 06/12/07 06/25/07 06/25/07 07/09/07 07/09/07 07/23/07 07/23/07 08/07/07 08/07/07 08/27/07 08/27/07 09/05/07 09/05/07 09/18/07 09/18/07 10/03/07 10/03/07 Y:\GDP\F1301\150595\StLucEntrCharFigs.xlsx\4-104/28/17

N:\PRJ\FPL\316(b) Support\Individual plant files\St. Lucie\R Reports\Figures\Templates\StLucieFGS\7-23/10/2021 7-4 FIGURE 7-2. 2006-2007 PSL ENTRAINMENT SPECIES COMPOSITION Source: EAI, 2008.

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 8.0 Operational Status 40 CFR 122.21(r)(8) The owner or operator of an existing facility must submit a description of the operational status of each generating, production, or process unit that uses cooling water, including but not limited to: (i) For power production or steam generation, descriptions of individual unit operating status including age of each unit, capacity utilization rate (or equivalent) for the previous 5 years, including any extended or unusual outages that significantly affect current data for flow, impingement, entrainment, or other factors, including identification of any operating unit with a capacity utilization rate of less than 8 percent averaged over a 24-month block contiguous period, and any major upgrades completed within the last 15 years, including but not limited to boiler replacement, condenser replacement, turbine replacement, or changes to fuel type; (ii) Descriptions of completed, approved, or scheduled uprates and Nuclear Regulatory Commission relicensing status of each unit at nuclear facilities; (iii)For process units at your facility that use cooling water other than for power production or steam generation, if you intend to use reductions in flow or changes in operations to meet the requirements of 40 CFR 125.94(c), descriptions of individual production processes and product lines, operating status including age of each line, seasonal operation, including any extended or unusual outages that significantly affect current data for flow, impingement, entrainment, or other factors, any major upgrades completed within the last 15 years, and plans or schedules for decommissioning or replacement of process units or production processes and product lines; (iv) For all manufacturing facilities, descriptions of current and future production schedules; and (v) Descriptions of plans or schedules for any new units planned within the next 5 years. The St. Lucie Plant is a two-unit, baseload nuclear-powered electricity generating facility; Unit 1 and Unit 2 have generating capacities of 1,025-megawatts (MW) and 1,032-MW, respectively (FPL, 2019). Unit 1 came online in March 1976 and Unit 2 came online in April 1983. Both units are designed as pressurized water reactors. PSL uses water withdrawn from the Atlantic Ocean for condenser cooling. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 8-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) FPL schedules refueling outages approximately every 18 months. Unit outages for refueling and periodic maintenance are planned to affect only a single unit at a time and are therefore on a staggered schedule. Table 8-1 presents the capacity utilization for each unit for the period 2016 to 2020. Table 8-1. PSL Capacity Utilization Net Capacity Factor (%) Year Unit 1 Unit 2 2016 80.27 100.00 2017 99.05 91.55 2018 92.10 88.46 2019 70.85 102.67 2020 101.27 93.12 5-year Average 88.7 95.2 Source: FPL, 2021. 8.1 Uprates §122.21(r)(8)(ii)Descriptions of completed, approved, or scheduled uprates and Nuclear Regulatory Commission [NRC] relicensing status of each unit at nuclear facilities; Following approval by FDEP under the Florida Electrical Power Plant Siting Act on January 7, 2008, FPL submitted applications to the NRC for extended power uprates (EPUs) for PSL Units 1 and 2 on November 22, 2010 and February 25, 2011, respectively (77 FR 40093). The applications requested a license amendment allowing PSL to increase the maximum thermal power level from 2,700 megawatts thermal (MWt) to 3,020 MWt for each unit, an 11.85 percent increase. The project included replacing pipes, valves, pumps, heat exchangers, electrical transformers, and generators. The EPUs were approved by the NRC and completed by FPL in April 2013. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 8-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 9.0 Entrainment Characterization Study 40 CFR 122.21(r)(9) The final rules requirements for an Entrainment Characterization Study are as follows: 40 CFR 122.21(r)(9)The owner or operator of an existing facility that withdraws greater than 125 MGD AIF, where the withdrawal of cooling water is measured at a location within the cooling water intake structure that the Director deems appropriate, must develop for submission to the Director an Entrainment Characterization Study that includes a minimum of 2 years of entrainment data collection. The Entrainment Characterization Study must include the following components: (i) Entrainment Data Collection Method; (ii) Biological Entrainment Characterization; and, (iii) Analysis and Supporting Documentation. In its approval of PSLs Plan of Study for 316(b) Implementation (FPL, 2017), FDEP agreed that the 1 year of entrainment data collected under Phase II would satisfy part of the Final Rules two-year data requirement. An additional year of entrainment sampling was conducted at PSL between November 2017 and November 2018 (Table 9-1). The following sections respond to the requirements of 40 CFR 122.21(r)(9) of the Final Rule. The data were used in the analysis of social benefits associated with potential entrainment mitigation measures as described in Section 11.0. 9.1 Entrainment Data Collection Method The entrainment studies conducted under the Phase II rule were collected in accordance with a Proposal for Information Collection submitted to FDEP (FPL, 2005) and conducted under a fleetwide 316(b) Quality Assurance Project Plan (FPL, 2006a) and a facility-specific Standard Operating Procedure (FPL, 2006b). The sampling plan for the second year of entrainment studies under the 2014 Final Rule employed similar methodologies as the Phase II collections to ensure data comparability and was implemented in accordance with the FDEP-approved Plan of Study/Entrainment Characterization Study Plan (FPL, 2017). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-1. Entrainment Sample Collection Dates Year 0.5 Year 1 Year 2 Event No. Date # Samples Date # Samples Date # Samples 1 01/12/06 2 10/18/06 2 12/06/17 4 2 01/24/06 2 11/01/06 2 12/20/17 4 3 02/07/06 2 11/14/06 2 01/04/18 4 4 02/21/06 2 12/04/06 2 01/17/18 4 5 03/23/06 2 12/28/06 2 01/31/18 4 6 03/29/06 2 01/09/07 2 02/14/18 4 7 04/04/06 2 01/23/07 2 02/28/18 4 8 04/18/06 2 02/07/07 2 03/14/18 4 9 05/04/06 2 02/21/07 2 03/28/18 4 10 05/16/06 2 03/07/07 2 04/11/18 4 11 05/31/06 2 04/02/07 2 04/25/18 4 12 06/14/06 2 04/17/07 2 05/09/18 4 13 06/27/06 2 05/03/07 2 05/23/18 4 14 07/11/06 2 05/17/07 2 06/06/18 4 15 07/25/06 2 05/29/07 2 06/20/18 4 16 08/08/06 2 06/12/07 2 07/05/18 4 17 08/22/06 2 06/26/07 2 07/18/18 4 18 09/05/06 2 07/10/07 2 08/01/18 4 19 09/19/06 2 07/24/07 2 08/15/18 4 20 10/10/06 2 08/08/07 2 08/29/18 4 21 08/27/07 2 09/12/18 4 22 09/05/07 2 09/26/18 4 23 09/19/07 2 10/10/18 4 24 10/04/07 2 10/24/18 4 25 11/07/18 4 26 11/19/18 4 Total Number Samples 40 48 104 Source: FPL, 2010; ECT, 2021. Phase II sampling at PSL included data collections from January 2006 through October 2007. The portion of these data from October 2006 to October 2007 were used as the first year of entrainment data in this analysis (Year 1). The partial first year of data were included to depict interannual variability. Data collected January 2006 through early October 2007 are referred to as Year 0.5 and October 2006 through October 2007 are referred to as Year 1. Additional data were collected from November 2017 through November 2018 and are referred to as Year 2 in the Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) following sections. Entrainment samples were collected every two weeks over a 24-hour period, with entrainment subsamples being collected approximately every 6 hours. Entrainment samples were collected using a 300-micron mesh plankton net and collected at the seaward end of the intake canal as water first enters from the offshore velocity caps. This represents the best location to define the rate of entrainment from the source water into the cooling system. The net had a 1-meter diameter mouth, 5:1 length-to-diameter ratio, and 300-micron mesh and was fished at mid-depth for approximately 5 minutes when both units were running or 10 minutes if only one unit was running. This method sampled approximately 130 to 200 cubic meters, and the actual sample volume was measured using a flow meter at the mouth of the net. At the conclusion of each sample collection, the contents of the plankton net were rinsed down with source water from the outside of the net and carefully transferred to labeled sample jars and preserved for analysis. In the laboratory, ichthyoplankton and targeted shellfish meroplankton were separated from detritus (sorted), identified to the lowest practical taxon, and enumerated by life stage. For ichthyoplankton, notochord length and the greater of either body depth or head capsule height were measured to the nearest 0.1 mm for a subset of 30 individuals of each taxon of fish larvae to allow for assessment of fine-mesh screen performance. For shellfish meroplankton taxa, the greatest body dimension was measured for a sufficient number of each life stage to characterize the number of meroplankton in each of the following size classes: less than 1 mm, 1 to 2 mm, 2 to 9 mm, and greater than 9 mm. Since only a subset of individuals was measured, these measurements were assumed to represent the total number collected in the sample and extrapolated by distributing the percent of individuals in each size class across the total number collected in the sample. If no individuals of a certain taxon were measured from a sample they were considered unmeasured. Supporting data collection included in situ measurements of pH, temperature, salinity, and dissolved oxygen during each sample collection. Field notes were taken to note wind and weather conditions, tide stage, departures from the standard sampling protocol, and observed departures from normal plant operations (e.g., circulating water pump or screen wash operations, Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) etc.). Daily circulating water pump rates were obtained from plant operators for normalization of results to actual flow rates. Entrainment results were compiled in a Microsoft Excel database along with supporting data and circulating water pumping rates obtained from plant operations. Detailed life stages that are often taxon-specific were lumped into broader categories for data processing (e.g., egg, yolk-sac larvae, post-yolk-sac larvae, or juvenile for fish; zoea or megalopa for shellfish). Detailed length data were also categorized for data processing. Tabular and graphical summaries of taxa collected, raw counts, collection times, and flow normalized entrainment rates were produced. Entrainment rates (densities) were calculated by dividing the total number of specimens of each taxon collected by the total sample volume, from which a taxa-specific day and night entrainment rate was calculated for each sampling period. Additionally, ichthyoplankton and meroplankton were tabulated to depict size ranges by taxa and life stage. 9.2 Biological Entrainment Characterization Data from the 2006 to 2007 (Year 0.5 and Year 1) and 2017 to 2018 (Year 2) studies were tabulated to present total numbers, densities, and relative abundance for each year, sampling event, and diel (day and night) period. 9.2.1 Species composition and abundance A total of 169,618 specimens were counted in 40 samples in Year 0.5, including 24,756 fish and 169,618 invertebrates, representing 35 fish taxa and 69 invertebrate taxa. A total of 284,955 specimens were counted in 48 samples in Year 1, including 22,792 fish and 262,163 invertebrates, representing 58 fish taxa and 29 invertebrate taxa. A total of 1,188,658 specimens were counted in 104 samples in 2017 to 2018, including 122,784 fish and 1,065,874 invertebrates, representing 138 fish taxa and 27 invertebrate taxa. During all three periods, the most commonly reported fish taxon was unidentifiable eggs and the most commonly reported invertebrates were Brachyuran crab zoea. The combined taxa list for both studies (2006 to 2007 and 2017 to 2018) includes 164 fish and 87 invertebrate taxa (Table 9-2). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-2. Fish and Invertebrate Taxa Collected in Entrainment Samples Scientific Name Common Name Scientific Name Common Name Fishes Diodontidae Burrfish (family) Abudefduf saxatilis Sergeant major Diplogrammus Spotted dragonet Acanthostracion pauciradiatus Scrawled cowfish quadricornis Doratonotus megalepis Dwarf wrasse Achiridae Scrawled sole (family) Dormitator maculatus Fat sleeper Achirus lineatus Lined sole Eleotridae Sleeper (family) Ahlia egmontis Key worm eel Elops saurus Ladyfish Anchoa hepsetus Broad-striped anchovy Elops spp. Ladyfish spcies Anchoa mitchilli Bay anchovy Engraulidae Anchovy (family) Anchoa spp. Anchovy (genus) Etropus crossotus Fringed flounder Anisotremus surinamensis Black margate Etropus microstomus Smallmouth flounder Anisotremus virginicus Porkfish Etrumeus teres Atlantic red herring Apogonidae Cardinalfish (family) Eucinostomus spp. Mojarra (genus) Atherinopsidae Silverside (family) Exocoetidae Flyingfish (family) Bairdiella chrysoura Silver perch Gerreidae Mojarra (family) Bathygobius soporator Frillfin goby Gobiesox strumosus Skilletfish Combtooth blenny Gobiidae Goby (family) Blenniidae (family) Gobioides broussonnetii Violet goby Blennioidei Blenny (suborder) Gobionellus oceanicus Highfin goby Bregmaceros atlanticus Antenna codlet Gobiosoma ginsburgi Seaboard goby Bregmaceros cantori Striped codlet Gobiosoma robustum Code goby Bregmaceros houdei Stellate codlet Gobiosoma spp. Naked gobies Bregmaceros spp. Codlet Gymnothorax spp. Morays Bregmacerotidae Codlets (family) Haemulidae Grunt (family) Brevoortia spp. Herring Haemulon plumierii Grunt Callionymidae Dragonet (family) Haemulon spp. Grunt Canthigaster rostrata Sharpnose pufferfish Halichoeres spp. Wrasse Carangidae Jack (family) Harengula jaguana Scaled herring Centropomus spp. Snook spp. Hemiramphidae Halfbeak (family) Centropomus undecimalis Common snook Hippocampus erectus Lined seahorse Centropristis striata Black sea bass Hypleurochilus multifilis Featherduster blenny Chaetodipterus faber Atlantic spadefish Labridae Wrasse (family) Chloroscombrus Labrisomid blenny Atlantic bumper Labrisomidae chrysurus (family) Chromis spp. Chromis Labrisomus nuchipinnis Hairy blenny Citharichthys Cichlids and Surfperches Angelfin whiff Labroidei gymnorhinus (suborder) Citharichthys spilopterus Bay whiff Lachnolaimus maximus Hogfish Citharichthys spp. Whiff (genus) Lagodon rhomboides Pinfish Clupeidae Herring (family) Leiostomus xanthurus Spot Anchovies and herrings Lophiiformes Anglerfish (order) Clupeiformes (order) Lutjanidae Snapper (family) Congridae Conger Eels (family) Lutjanus spp. Snapper (genus) Coryphopterus spp. Goby species Lutjanus synagris Lane snapper Ctenogobius boleosoma Darter goby Megalops atlanticus Tarpon Ctenogobius spp. True Goby Menticirrhus americanus Southern kingfish Cynoglossidae Tonguefish Menticirrhus littoralis Gulf kingfish Cynoscion regalis Weakfish Menticirrhus spp. Kingfish Cynoscion spp. Seatrout Microdesmidae Dartfish (family) Dactyloscopidae Stargazer (family) Microdesmus bahianus Wormfish bahianus Decapterus macarellus Mackerel scad Microdesmus lanceolatus Lancetail wormfish Decapterus punctatus Round scad Microdesmus longipinnis Pink wormfish Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-2. Fish and Invertebrate Taxa Collected in Entrainment Samples (Continued, Page 2 of 3) Scientific Name Common Name Scientific Name Common Name Microdesmus spp. Wormfish Sphoeroides spp. Pufferfish spp. Microgobius thalassinus Green goby Sphoeroides testudineus Checkered puffer Micropogonias undulatus Atlantic croaker Sphyraena barracuda Great barracuda Monacanthidae Filefish (family) Sphyraena spp. Barracuda (genus) Monacanthus ciliatus Fringed filefish Stellifer lanceolatus American stardrum Muraenidae Morays (family) Symphurus plagiusa Blackcheek tonguefish Myctophidae Lanternfish (family) Symphurus spp. Tonguefishes (family) Myrophis punctatus Speckled worm eel Syngnathus louisianae Chain pipefish Nes longus Orangespotted goby Syngnathus spp. Pipefish Ophichthidae Snake eel (family) Synodontidae Lizardfishes Ophidiidae Cusk eels (family) Synodus foetens Inshore lizardfish Ophidion josephi Crested cusk eel Tetraodontidae Pufferfish (family) Ophidion selenops Mooneye cusk-eel Tetraodontiformes Filefish (order) Ophidion spp. Cusk-eel (genus) Thalassoma bifasciatum Bluehead Orthopristis chrysoptera Pigfish Triglidae Searobin (family) Paralichthyidae Flounder (family) Trinectes maculatus Hogchoker Paralichthys albigutta Gulf flounder Umbrina coroides Sand drum Paralichthys lethostigma Southern flounder Unidentified Unidentifiable Paralichthys oblongus Fourspot flounder Unidentified eggs Unidentifiable eggs Paralichthys spp. Largetooth flounders Unidentified fish Unidentifiable fish Pareques spp. Paraques genus Invertebrates Pareques umbrosus Cubbyu Acetes americanus Sergestid shrimp Perciformes Perch-like fishes (order) Acetes spp. Sergestid shrimp Righteye flounders Albunea spp. Mole crab Pleuronectidae (family) Alpheidae Snapping shrimp Flatfishes, flounders and Alpheus heterochaelis Bigclaw snapping shrimp Pleuronectiformes soles (order) Alpheus spp. Pistol shrimp Pogonias cromis Black drum Anomuran crab (non-Anomura Pomacentridae Damselfish (family) Thalassinidea) Prionotus spp. North American searobin Arcidae Arc clam (family) Psilotris alepis Scaleless goby Arenaeus cribrarius Speckled crab Ptereleotris spp. Dartfish Ghost shrimps (infraorder Axiidea Rachycentron canadum Cobia Axiidea) Rhynchoconger gracilior Whiptail conger Bivalvia Bivalve Sardinella brasiliensis Orangespot sardine Brachyura (Non-CRI) Brachyuran crab (family) Saurida brasiliensis Brazilian lizardfish Callianassa spp. Ghost shrimp Scaridae Parrotfish (family) Callianassidae Ghost shrimp (family) Scartella cristata Molly miller Swimming crab Callinectes spp. Sciaenidae Drum (family) (Callinectes genus) Sciaenops ocellatus Red drum Cardiidae Cockle Scombridae Tuna (family) Caridea Caridean shrimp Scorpaenidae Scorpionfishes and allies Clibanarius vittatus Thinstripe hermit Mail-cheeked fishes Decapoda Decapod crabs (order) Scorpaeniformes (order) Pea crab (Dissodactylus Dissodactylus spp. Selar crumenophthalmus Bigeye scad genus) Selene setapinnis Atlantic moonfish Emerita spp. Mole crab Serraniculus pumilio Pygmy sea bass Emerita talpoida Common mole crab Serranidae Grouper (family) Eualus spp. Hippolyte Shrimp Serraninae Subfamily of Groupers Euphausiacea Krill (order) Sparidae Porgy (family) Farfantepenaeus aztecus Brown shrimp Sphoeroides maculatus Northern puffer Farfantepenaeus Pink shrimp Sphoeroides nephelus Southern puffer duorarum Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-2. Fish and Invertebrate Taxa Collected in Entrainment Samples (Continued, Page 3 of 3) Scientific Name Common Name Scientific Name Common Name Panaeid shrimp Penaeidae Penaeid shrimp (family) Farfantepenaeus spp. (Farfantepenaeus genus) Penaeid shrimp (Penaeus Penaeus spp. Burrowing shrimps genus) Gebiidea (infraorder Gebiidea) Pilumnus sayi Spineback hairy crab Gonodactylid mantis Pilumnus spp. Mud crab Gonodactyloidea shrimps (superfamily) Pinnixa spp. Pea crab (Pinnixa genus) Hippolyte spp. Hippolyte Shrimp Pinnotheridae Pea crab (family) Hippolytidae Hippolyte shrimp (family) Porcellanidae Porcelain crab (family) Latreutes spp. Hippolyte Shrimp Portunidae Portunid crab (family) Lepidopa benedicti Mole crab Portunus gibbesii Iridescent swimming crab Lepidopa spp. Mole crab Portunus spp. Portunid crab (genus) Lepidopa websteri A sand crab Rimapenaeus constrictus Roughneck shrimp Leptochela spp. Glass shrimp (family) Rimapenaeus spp. Penaeid shrimp Libinia dubia Longnose spider crab Sergestidae Sergestid shrimp Libinia spp. Spider crab (genus) Sergestoidea Sergestid shrimp Loliginidae Loliginid squid (family) Solecurtidae Saltwater clams Lucifer faxoni Sergestid shrimp Solenocera spp. A Solenocerid shrimp Lucifer spp. Sergestid shrimp Squilla empusa Mantis shrimp Lysiosquillid mantis Squilla spp. Mantis shrimp Lysiosquilloidea shrimps (family) Mantis shrimp Lysmata spp. Hippolyte Shrimp Squilloidea (superfamily) Mactridae Surf clam (family) Tellinidae Tellin clam Menippe mercenaria Florida stone crab Ghost and mud shrimp Thalassinidea Menippe nodifrons Cuban stone crab (infraorder) Menippe spp. Stone crab Thor spp. Shrimp (Thor) Mysida Opossum shrimp (order) Tozeuma spp. Shrimp (Tozeuma) Mytilidae Mussel (family) Uca spp. Fiddler crab (genus) Naushonia crangonoides Burrowing mud shrimp Unidentified Crab Unidentifiable crab Swimming crab (Ovalipes Unidentified Unidentifiable Ovalipes spp. genus) meroplankton meroplankton Paguridae Right-handed hermit crab Unidentified Shrimp Unidentifiable shrimp Pagurus longicarpus Long-armed hermit crab Upogebia affinis Coastal mud shrimp Pagurus spp. Hermit crab (genus) Upogebia spp. Mud shrimp Grass shrimp Veneridae Venus clams Palaemonetes spp. (Palaemonetes genus) Zaops spp. Pea crab (genus) Panopeid mud crabs Panopeidae (family) Source: ECT, 2021 Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Unidentifiable eggs primarily consisted of undeveloped eggs with no differential characteristics that would allow further taxonomic differentiation. Undeveloped eggs could include eggs that may have been spawned shortly before collection and thus cell division was not yet evident, or eggs that were not fertilized or viable. Eggs likely consisted of many of the larval species present during the sampling, including herring species, blennies, drum, and gobies. More fish were collected in night samples than day samples in all periods (88.9 percent at night in Year 0.5, 83.4 percent at night Year 1, and 81.6 percent at night Year 2). Invertebrates were also more abundant at night during all sample periods (55.8 percent at night in Year 0.5, 61.9 percent at night in Year 1, and 66.0 percent at night in Year 2). 9.2.2 Entrainment Size Classes A subset of ichthyoplankton and meroplankton were measured in the 2017 to 2018 sampling. No measurements were taken in the 2006 to 2007 sampling. Meroplankton and eggs were sorted into size classes and ichthyoplankton were measured to 0.1 mm and were sorted into size categories. Measurements taken during the 2017 to 2018 sampling were intended to provide size distributions for subsequent evaluations of screening technologies. For fish, notochord length and the larger of either body depth or head capsule depth were measured to the nearest 0.1 mm for a subset of 30 individuals of each taxon. Meroplankton were measured for total length only. Meroplankton and eggs were reported in size classes (<1 mm, 1-2 mm, 2-9 mm, and >9 mm). To facilitate data analysis, ichthyoplankton lengths were also sorted into size classes. Measured entrained fish taxa in the 2017 to 2018 sampling included 9,568 fish, most of which were eggs, larval, and post-larval stages. Most of the fish measured were <1 mm in length. A total of 11,110 meroplankton were measured in the 2017 to 2018 sampling. Lengths were categorized by smallest dimension for 2017 to 2018 for invertebrate taxa and head capsule depth for fish taxa. Table 9-3 includes numbers of fish and invertebrates measured in each size class. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-8

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-3. 2017-2018 Number of Fish and Invertebrates Counted by Size Class Life Stage <1 mm 1-2 mm 2-9 mm >9 mm Total Fishes Egg 5,059 1,027 18 6,104 Larvae/zoea 1,124 2 102 1,228 Post larvae/megalopa 992 788 408 2,188 Juvenile 1 27 16 44 Adult 1 1 Other 3 3 Total 7,179 1,844 544 1 9,568 Invertebrates Zoea 1,767 3,858 2,107 9 7,741 Megalopa 177 845 21 1,043 Juvenile 1 93 914 8 1,016 Adult 1,116 194 1,310 Total 1,768 4,128 4,982 232 11,110 Note: Fish measured in the shortest dimension. Invertebrates measured for total length. Source: ECT, 2021. For fish, 83 percent of eggs, 92 percent of larvae, and 45 percent of post larvae measured were less than 1 mm; 17 percent of eggs, 0.2 percent of larvae, and 36 percent of post larvae were 1 to 2 mm; and less than 1 percent of eggs and larvae, and 8.3 percent of post larvae were 2 to 9 mm. Meroplankton were somewhat larger, with only 16 percent of total meroplankton measured less than 1 mm; 37 percent were 1 to 2 mm, 45 percent were 2 to 9 mm, and 2 percent were greater than 9 mm. Meroplankton zoea were 23 percent less than 1 mm, 50 percent 1 to 2 mm, 27 percent 2 to 9 mm, and 0.1 percent greater than 9 mm, while megalopa were 17 percent 1 to 2 mm, 81 percent 2 to 9 mm, and 2 percent greater than 9 mm. 9.2.3 Water Quality Measurements Supporting data collection included in-situ measurements of pH, temperature, salinity, and dissolved oxygen during each entrainment sample. Field notes included wind and weather conditions, tide stage, departures from the standard sampling protocol, and observed departures from normal plant operations (e.g., circulating water pump or screen wash operations, etc.). Daily circulating water pump rates were subsequently obtained from plant operators for Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-9

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) normalization of results to actual flow rates. The minimum, maximum, and mean for the water quality measurements collected during the 2017 to 2018 survey are included in Table 9-4. Table 9-4. Water Quality Measurements Collected During 2016 to 2017 Sampling Temperature Salinity Dissolved Parameter pH (ºC) (PSU) Oxygen (mg/L) Minimum 22.46 31.6 7.07 5.79 Maximum 31.26 36.8 8.16 6.98 Average 26.7 35.2 6.5 Source: ECT, 2021. 9.3 Analysis and Supporting Documentation Sample results were analyzed to determine annual entrainment rates for the two sampling periods, as well as diel and seasonal trends evident in the data. 9.3.1 Annualized Entrainment under Actual Flow Conditions Sample results were extrapolated to determine an estimated total entrainment for a year. Species-specific diel densities (number/MG) during each sampling event were flow rated for measured withdrawals between events. These estimates assume that entrainment is proportional to cooling water flow and the event-specific densities are representative of rates throughout the period surrounding the sample (typically two weeks). Annual estimates were calculated based on the average actual daily flow for that interpolated period from 2015 through 2018. As cooling water flow rates for PSL were only available as a total flow for each day, diel monthly flows were estimated based on the proportion of each day between sunrise and sunset. Flow rates were therefore higher during the longer daytime period in summer and during longer nighttime periods in the winter. Table 9-5 and Figure 9-1 include the monthly average cooling water flows. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-5. Average Monthly Cooling Water Flow Average Day Average Night Average Month (MG) (MG) (MG) January 659.1 827.8 1,486.9 February 662.6 753.5 1,416.1 March 659.9 660.2 1,320.1 April 668.7 579.1 1,247.8 May 836.7 650.2 1,486.9 June 857.4 629.6 1,486.9 July 846.8 640.2 1,486.9 August 791.0 660.0 1,451.0 September 600.7 569.9 1,170.6 October 554.6 602.1 1,156.6 November 649.3 794.2 1,443.5 December 647.3 839.9 1,487.1 Average 682.5 656.8 1,339.2 Source: Average flows calculated from daily flows provided by FPL from 2015 through 2018. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-11

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 9-1. Average Monthly Cooling Water Flows 2015-2018 Source: FPL, 2019. An estimated 4.7 billion fish life stages and 64.4 billion invertebrates were entrained using the Year 1 (October 2006 to October 2007) sampling results, and 16.1 billion fish life stages and 121.3 billion invertebrates were entrained using the Year 2 (2017 to 2018) sampling results. Unidentified eggs, which were substantially higher in Year 2, were the most commonly entrained fish in both years; 55.1 percent for Year 1 and 74.6 percent for Year 2. Brachyuran crabs were the most commonly entrained invertebrates in both years, with 70.4 percent in Year 1 and 62.0 percent in Year 2. Table 9-6 provides the estimated total entrainment for the 2 sampling years while Figure 9-2 shows the relative distribution of entrained taxa. Table 9-6 also includes the estimated entrainment for the sampling conducted in Year 0.5 (January to October 2006). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-12

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-6. Estimated Entrainment Totals for Dominant Fish and Invertebrates Common Name Year 1 Year 2 Year 0.5 Fishes Unidentifiable eggs 2,590,795,426 12,031,357,870 4,655,153,812 Herring (family) 1,059,784,623 1,564,256,269 275,270,783 Combtooth blenny (family) 227,557,662 688,648,319 27,809,374 Drum (family) 109,864,558 430,102,584 50,022,688 Anchovy (family) 46,344,670 83,893,821 432,984,089 Darter goby 11,339,765 402,120,935 11,637,560 Goby (family) 16,834,985 142,217,377 224,066,219 Perch-like fishes (order) 132,536,748 15,038,196 Labrisomid blenny (family) 3,357,892 131,246,795 Blenny (suborder) 127,549,870 Other Fish 375,542,701 653,710,836 279,771,859 Total Fish 4,701,508,900 16,127,554,807 5,971,754,579 Invertebrates Brachyuran crab (family) 45,320,002,594 75,133,952,342 25,847,647,092 Anomuran crab (non-Thalassinidea) 3,600,150,390 3,929,588,879 3,121,560,935 Ghost and mud shrimp (infraorder) 2,075,918,641 495,445,141 Common mole crab 136,033,399 114,306,381 Brown shrimp 2,739,686 5,332,501 91,658,313 Arc clam (family) 38,908,646 14,750,321 Loliginid squid (family) 35,246,855 Krill (order) 27,717,877 A sand crab 17,061,209 Lysiosquillid mantis shrimps (family) 4,218,964 Other Invertebrates 13,205,429,580 42,098,502,094 15,860,435,203 Invertebrate Total 64,379,182,936 121,251,620,722 45,545,803,386 Total 69,080,691,836 137,379,175,529 51,517,557,965 Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-13

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 9-2. Dominant Taxa of Fish and Invertebrates in Entrainment Source: ECT, 2021. 9.3.2 Seasonal and Diel Variation in Entrainment The following sections include estimated day and night entrainment totals for each month using the data from the 2006 to 2007 sampling and from the 2017 to 2018 sampling. Table 9-7 and Figure 9-3 depict the estimated monthly entrainment for the 2006 to 2007 sampling, and Table 9-8 and Figure 9-4 depict the estimated monthly entrainment for the 2017 to 2018 sampling. Fish entrainment was variable throughout each year but generally higher in the spring and fall, and was generally higher at night than during the day for both sampling years. Invertebrate entrainment was higher in the summer than in the winter and more evenly entrained in the day and night samples. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-14

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-7. Estimated Monthly Entrainment at Actual Flows Using Year 1 (2006 to 2007) Entrainment Data Day Night Day Night Month Fishes Invertebrates 1 15,326,189 56,795,929 1,184,654,565 2,159,394,392 2 46,596,084 55,555,795 499,972,699 384,602,024 3 77,570,325 533,865,883 1,662,223,640 684,009,477 4 36,655,575 718,447,154 2,547,090,608 4,030,764,520 5 89,989,952 747,469,418 3,301,579,687 2,529,962,334 6 71,477,771 124,731,156 3,702,454,115 2,809,135,716 7 41,160,177 241,450,976 3,937,024,466 4,381,834,868 8 82,646,000 650,243,536 5,280,124,124 17,711,266,133 9 526,841,254 409,750,441 2,759,845,847 1,737,376,781 10 15,361,301 84,733,631 688,581,910 628,808,069 11 13,093,514 20,737,935 261,150,419 687,451,666 12 10,398,488 30,610,416 188,413,839 621,461,037 Total 1,027,116,630 3,674,392,270 26,013,115,918 38,366,067,017 Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-15

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 9-3. Estimated Monthly Entrainment using Year 1 (2006 to 2007) Entrainment Data Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-16

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-8. Estimated Monthly Entrainment Using Year 2 (2017 to 2018) Entrainment Data Day Night Day Night Month Fishes Invertebrates 1 62,555,044 52,832,845 338,436,527 571,215,438 2 149,681,849 3,346,455,631 1,216,819,560 1,087,909,350 3 3,560,662,497 359,515,355 3,898,507,302 3,979,679,657 4 172,605,959 330,994,010 2,818,504,131 2,641,172,778 5 40,052,626 786,191,612 4,719,892,961 8,277,046,847 6 87,276,852 2,148,677,562 12,287,504,046 19,071,788,599 7 312,903,104 1,143,631,907 10,459,916,706 17,581,362,797 8 710,660,816 1,560,831,766 4,289,147,269 10,322,251,193 9 219,090,337 380,004,648 2,510,698,911 3,440,595,953 10 11,403,487 18,215,370 1,573,993,603 1,739,553,532 11 11,202,236 184,224,851 1,331,033,830 6,933,352,138 12 16,767,740 461,116,705 1,220,432,129 1,826,540,972 Total 5,354,862,546 10,772,692,261 46,664,886,973 77,472,469,255 Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-17

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 9-4. Estimated Monthly Entrainment Using Year 2 (2017 to 2018) Entrainment Data Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-18

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 9.3.3 Entrainment Sizes As presented in Section 9.2.2, fish and invertebrates were categorized into size ranges, intended to provide size distributions for subsequent evaluations of screening technologies. Table 9-9 presents size distribution data for the smallest measured dimension for measured taxa of fish and Table 9-10 provides results for invertebrates. These measurements include head capsule depth for fish which has been shown to be a better predictor of exclusion on fine mesh screens than total length. Unmeasured individuals were categorized based on the proportion of measured individuals in each size class in the taxa. The not measured category includes taxa where none of the collected individuals were measured during the sample event. Total length data for ichthyoplankton are available in the project database but are not presented here. Note also as described in Section 9.1, detailed life stages were lumped into broader categories for data processing. Overall, 25 percent of annualized entrainment based on 2017 to 2018 sampling were less than 1 mm, 40 percent were 1 to 2 mm, 34 percent were 2 to 9 mm, 1 percent were greater than 9 mm; less than 0.001 percent were not measured. The majority of fish entrainment (88 percent) were less than 1 mm, while invertebrate entrainment was mostly 1 to 2 mm (43 percent) or 2 to 9 mm (38 percent; Tables 9-9 and 9-10). Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-19

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-9. Size Classes for Dominant Fish - Annualized Flows 2017 to 2018 Not Scientific Name Common Name Life Stage <1 mm 1-2 mm 2-9 mm >9 mm Measured Unidentified eggs Unidentifiable eggs Egg 96.0% 4.0% 0.03% Egg 44.5% 55.5% Clupeidae Herring (family) Larvae 100% Post larvae 71.9% 27.2% 0.9% Egg 100% Combtooth blenny Blenniidae Larvae 99.6% 0.03% 0.3% (family) Post larvae 45.1% 51.6% 3.3% Egg 99.9% 0.1% Sciaenidae Drum (family) Larvae 100% Post larvae 79.6% 20.4% Ctenogobius Darter goby Post larvae 3.2% 96.8% 0.03% boleosoma Egg 100% Gobiidae Goby (family) Larvae 100% Post larvae 97.2% 2.8% Labrisomid blenny Larvae 100% Labrisomidae (family) Post larvae 92.1% 7.9% Egg 100% Engraulidae Anchovy (family) Larvae 100% Post larvae 87.3% 4.3% 8.5% Gobiosoma Larvae 100% Seaboard goby ginsburgi Post larvae 58.0% 41.8% 0.2% Chloroscombrus Larvae 100% Atlantic bumper chrysurus Post larvae 78.7% 16.9% 4.4% Dormitator Fat sleeper Post larvae 13.8% 86.2% maculatus Eucinostomus spp. Mojarra (genus) Post larvae 6.6% 28.1% 65.3% Egg 1.2% 98.8% Synodontidae Lizardfishes Larvae 100% Micropogonias Larvae 100% Atlantic croaker undulatus Post larvae 10.7% 89.3% Brevoortia spp. Herring Post larvae 37.4% 37.3% 25.3% Fish Total 88.1% 11.0% 0.9% 0.002% 0.006% Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-20

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 9-10. Size Classes for Dominant Invertebrates - Annualized Flows 2017 to 2018 Not Scientific Name Common Name Life Stage <1 mm 1-2 mm 2-9 mm >9 mm Measured Juvenile 1.6% 27.2% 71.2% Brachyura (Non- Brachyuran crab Zoea 26.8% 60.6% 12.7% CRI) (family) Megalopa 95.4% 4.6% Adult 84.4% 15.6% Juvenile 98.9% 1.1% Sergestoidea Sergestid shrimp Zoea 1.2% 45.0% 53.7% 0.02% Megalopa 100% Adult 100% Juvenile 93.2% 6.8% Caridea Caridean shrimp Zoea 16.5% 83.5% Megalopa 99.5% 0.5% Adult 97.8% 2.2% Opossum shrimp Mysida Juvenile 9.9% 90.1% (order) Megalopa 85.0% 15.0% Anomuran crab Zoea 32.8% 63.8% 3.4% Anomura (non-Thalassinidea) Megalopa 74.0% 26.0% Burrowing shrimps Zoea 41.1% 58.9% Gebiidea (infraorder Megalopa 100% Gebiidea) Zoea 83.0% 12.8% 4.1% Emerita spp. Mole crab Megalopa 100% Ghost shrimps Axiidea (infraorder Zoea 100% Axiidea) Menippe spp. Stone crab Zoea 78.3% 21.7% Albunea spp. Mole crab Zoea 40.5% 59.5% Loliginid squid Juvenile 100% Loliginidae (family) Zoea 84.5% 15.5% Rimapenaeus Roughneck shrimp Zoea 100% constrictus Invertebrate Total 16.7% 43.3% 38.4% 1.6% 0.0% Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\1-9.DOCX033121 9-21

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.0 Technical Feasibility and Cost Evaluation Study 40 CFR 122.21(r)(10) 10.1 Introduction and Background 10.1.1 Plant Florida Power & Light Companys (FPLs) St. Lucie Nuclear Plant (the Plant or PSL) is a two-unit, baseload nuclear-powered electricity generating facility; Unit 1 and Unit 2 have generating capacities of 1,025-megawatts (MW) and 1,032-MW, respectively (FPL, 2019). Unit 1 came online in March 1976, and Unit 2 came online in April 1983 (NRC, 2018a; NRC, 2018b). FPL owns the entirety of St. Lucies Unit 1 and 85 percent of Unit 2 (NextEra, 2019). The remaining 15-percent ownership share of Unit 2 belongs to the Florida Municipal Power Agency (FMPA) and the Orlando Utilities Commission (OUC) (FMPA, 2020, nFront Consulting, 2019). Both units are designed as pressurized water reactors. PSL uses water withdrawn from the Atlantic Ocean for condenser cooling. 10.1.2 Final Rule Requirement PSL is regulated under the U.S. Environmental Protection Agencys (EPAs) 2014 Rule for existing facilities developed under the Clean Water Acts (CWA) Section 316(b) (Final Rule) because it has a design intake flow (DIF) of greater than 2 million gallons per day (MGD), uses more than 25 percent of the total water withdrawn exclusively for cooling, and its discharge is authorized by a National Pollutant Discharge Elimination System (NPDES) permit (NPDES No. FL0002208). The Plants actual intake flow (AIF) is greater than 125 MGD; therefore, the Plant is required to submit information requested in the Code of Federal Regulations (CFR), Title 40, Part 122.21(r)(10), among others. This report addresses requirements in 40 CFR 122.21(r)(10). In 40 CFR 122.21(r)(10), Comprehensive Technical Feasibility and Cost Evaluation Study, the regulations state: Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The owner or operator of an existing facility that withdraws greater than 125 MGD AIF must develop for submission to the Director an engineering study of the technical feasibility and incremental costs of candidate entrainment control technologies.

i. Technical feasibility. An evaluation of the technical feasibility of closed-cycle recirculating systems as defined at 40 CFR 125.92(c), fine-mesh screens with a mesh size of 2 millimeters or smaller, and water reuse or alternate sources of cooling water. In addition, this study must include:

(A) A description of all technologies and operational measures considered (including alternative designs of closed-cycle recirculating systems such as natural draft cooling towers, mechanical draft cooling towers, hybrid designs, and compact or multi-cell arrangements); (B) A discussion of land availability, including an evaluation of adjacent land and acres potentially available due to generating unit retirements, production unit retirements, other buildings and equipment retirements, and potential for repurposing of areas devoted to ponds, coal piles, rail yards, transmission yards, and parking lots; (C) A discussion of available sources of process water, grey water, waste water, reclaimed water, or other waters of appropriate quantity and quality for use as some or all of the cooling water needs of the facility; and (D) Documentation of factors other than cost that may make a candidate technology impractical or infeasible 1 for further evaluation. ii. Other entrainment control technologies. An evaluation of additional technologies for reducing entrainment may be required by the Director. iii. Cost evaluations. The study must include engineering cost estimates of all technologies considered in paragraphs (r)(10)(i) and (ii) of this section. Facility costs must also be adjusted to estimate social costs. All costs must be presented as the net present value (NPV) and the corresponding annual value. Costs must be clearly labeled as compliance costs or social costs. The applicant must separately discuss facility level compliance costs and social costs, and provide documentation as follows: (A) Compliance costs are calculated as after-tax, while social costs are calculated as pre-tax. Compliance costs include the facility's administrative costs (including costs of permit applications) while the social cost also include Government administrative costs. Any outages, downtime, or other impacts to facility net revenue, are included in compliance costs, while only that portion of lost net revenue that does 1 Based on the distinction made regarding infeasibility and impracticality, this evaluation defines infeasibility as a technology that cannot be implemented by allocating additional resources to it, and impractical as a technology that can be implemented if significant resources are allocated to it, but when it does not make sense to implement it. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) not accrue to other producers is included in social costs. Social costs are discounted using social discount rates of 3 percent and 7 percent. Assumptions regarding depreciation schedules, tax rates, interest rates, discount rates and related assumptions must be identified; (B) Costs and explanation of any additional facility modifications necessary to support construction and operation of technologies considered in paragraphs (r)(10)(i) and (ii) of this section, including but not limited to relocation of existing buildings or equipment, reinforcement or upgrading of existing equipment, and additional construction and operating permits. Assumptions regarding depreciation schedules, interest rates, discount rates, useful life of the technology considered, and any related assumptions must be identified; and (C) Costs and explanation for addressing any non-water quality environmental and other impacts identified in paragraph (r)(12) of this section. The cost evaluation must include a discussion of all reasonable attempts to mitigate each of these impacts. In fulfillment of the requirements of 40 CFR 122.21(r)(10), this document evaluates the technical feasibility and associated costs of a closed-cycle recirculating system (CCRS), fine-mesh screens (FMS: both fine-mesh traveling screens and narrow-slot wedgewire screens), and alternate cooling water sources for PSL. In addition, this report discusses the potential entrainment benefits of variable speed pumps (VSP). 10.1.3 Evaluation Approach Pursuant to the aforementioned regulations governing PSL, this document provides the evaluation results for the technical feasibility and costs related to entrainment control technologies considered at the Plant. The evaluation also considers implementation of potential technologies in the least costly manner by minimizing to the extent practicable, capital construction costs, operations and maintenance (O&M) costs, and outage costs. Tie-ins of entrainment reduction technologies to the existing Plant or other modifications to the existing cooling system invariably increase outage time and associated costs. Therefore, this evaluation considers scenarios under which, to the extent practicable, much of the (hypothetical) construction work required to implement the alternatives considered would be carried out without disrupting the Plants operations, with tie-ins and invasive construction steps taking place after most of the required construction is complete. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Retrofitting an existing and active facility is significantly different than constructing a new facility; maintaining safe conditions and minimizing outages are paramount during a retrofit. Potential major modification at the Plant would need to be approved by the Nuclear Regulatory Commission (NRC). Additionally, several other federal, state, and local entities would need to review and approve modifications. While key approvals that may be required are discussed in the evaluation of each technology, agency review may adversely affect scope, costs, and schedule of any potential retrofit. 10.1.4 Report Organization This report is organized as follows:

• The remainder of this subsection discusses the feasibility and cost evaluation approach in this report, provides an overview of technology types to be assessed, and discusses the social cost evaluation approach.
• Section 10.2 provides an overview of the existing Plant to the extent needed to evaluate feasibility and costs of technologies. Additional Plant data may be found in the 122.21(r)(3), (5), and (8) Reports.
• Section 10.3 discusses the specific approaches and costs of a hypothetical CCRS retrofit at PSL. A matrix comparing the different cooling tower types as they apply to the Plant is provided in Section 10.3.3.
• Section 10.4 discusses the feasibility and cost of retrofitting PSL with CCRS.
• Section 10.5 discusses the feasibility and cost of replacing the existing coarse-mesh traveling screens with fine-mesh traveling screens or narrow-slot wedgewire screens.
• Section 10.6 evaluates alternate water sources, such as onsite water reuse, groundwater, and grey water sources. Current water uses and needs are compared to potential alternate water sources within a reasonable distance from the Plant.
• Section 10.7 discusses other technologies that may reduce entrainment at PSL.
• Section 10.8 provides a summary of findings regarding the technical feasibility and cost evaluations.

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Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.1.5 Technologies and Measures to Be Assessed The focus of this section, as well as 40 CFR 122.21(r)(11) and (12), is to examine various measures that may reduce entrainment rates. The Final Rule requires that at least three technologies be considered at the relevant facilities: retrofit to closed-cycle cooling, installation of FMS in the form of traveling water screens or narrow-slot wedgewire screens, and water reuse and/or the securing of alternative water supplies. While the focus of the assessment is a reduction in entrainment, it is very useful to consider how each candidate technology or measure may address impingement mortality (IM) as well. While IM compliance is the subject of the 40 CFR 122.21(r)(6) report, the candidate approaches in this section will be considered in the context of both IM and entrainment Best Technology Available (BTA). Measures and technologies that are focused more exclusively on impingement compliance rather than entrainment BTA are not considered here, but are in the 40 CFR 122.21(r)(6) report. Finally, it should be noted that the range of measures that can be reasonably expected to reduce entrainment is relatively limited. Given the largely planktonic (or non-motile) nature of most entrained organisms, behavioral deterrents will not be effective. Similarly, entrained organisms are generally small in size (e.g., on the order of a single millimeter) so that coarse-mesh screening devices are ineffective. Therefore, a relatively limited set of technologies and measures are available and will be considered here. In the following discussion, the measures are grouped by their essential mode of action (e.g., exclusion, intake flow reduction). 10.1.5.1 Overall ApproachReduced Intake Flow Specific Technology: Retrofit to Closed-cycle Cooling Under this scenario, the existing once-through cooling system would be retrofitted to allow for a CCRS 2. A variety of closed-cycle configurations are available and will be considered below (refer to Section 10.3). A common characteristic of all the systems is that intake flow is reduced substantially, potentially by more than 80 percent in saltwater systems, relative to once-through 2 CCRS as defined in the regulations at 40 CFR § 125.92 includes cooling towers, a system of impoundments, or any combination thereof. Because PSL does not have any existing impoundments, this report will focus on cooling towers as a hypothetical CCRS retrofit. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) cooling systems. On the other hand, a retrofit to CCRS must account for the existing infrastructure and its constraints. Therefore, consideration of this scenario involves evaluation of several factors related to the existing facility and the potential closed-cycle retrofit. Specific Technology: Variable Speed Pumps This technology is based on changing the pumping rate to match the generation rate, while meeting thermal criteria in the NPDES permit. Reductions in flow would reduce entrainment as well. The facility needs to be able to use the necessary water quantities to support generation, therefore this technology does not allow the facility to commit to potential future reduction rates. This technology is discussed in Section 10.7.2. Specific Technology: Water Reuse and/or Alternative Water Supplies This measure relies on the potential for one or more alternate water sources to replace part or all the cooling water withdrawn from waters of the United States (i.e., the Atlantic Ocean). Water reuse within the facility is also to be considered. This measure will consider alternate sources of water to supply the existing once-through system rather than a hypothetical CCRS, as described above. 10.1.5.2 Overall ApproachFixed Screening Devices Specific Technology: Wedgewire Screens This technology relies on the exclusion of the organisms from the intake flow by a fixed screen (typically cylindrical, thus they are commonly referred to as bullet screens) with slot width of 2 mm. It is common for these systems to have low through-slot velocities to reduce entrainment as well as address IM. Such systems can be quite large at facilities with high electricity generating capabilities and have the potential to interfere with navigation in the source waterbody. The technologys effectiveness in biological exclusion is greatly facilitated by water moving across and past the screen at velocities that are similar to or higher than the through-slot velocity. Such water movement is referred to as a sweeping flow. Specific Technology: Aquatic Filter Barrier (AFB) AFBs consist of fabric barriers that are suspended from the water surface and secured to the bottom such that all cooling water should pass through the fabric. The pore size in the fabric is Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) fine enough that entrainable fish and shellfish larger than the pore size are excluded. Design guidelines for AFBs include target through-fabric velocities to prevent organism impingement as well as address other operational issues. AFBs include cleaning systems generally based on release of compressed air from within the AFB to directly remove debris and biofouling as well as shaking these materials from the AFB face. Specific Technology: Porous Dikes In theory, porous dikes operate in a fashion that is similar to AFB, but the system is based on a structure that emerges from the water surface. The dike is porous enough to allow water passage while excluding organisms. Porous dikes are not common, because they require several acres of area and can pose significant operational challenges, depending on the operating environment. Porous dikes constructed of a fine-grained material have been considered as a means of excluding entrainable organisms. PSL has a deep offshore velocity cap which would not be conducive to retrofitting to a porous dike. 10.1.5.3 Overall ApproachModification of TWS Specific Technology: Installation of FMS on Traveling Water Screens with Fish Handling and Return System This system is based on the exclusion and collection of otherwise entrainable organisms from intake water, washing them from the FMS, and returning them to the source waterbody. This represents one of the two forms of FMS (e.g., 2 mm mesh or slot), the other one being wedgewire screens (refer to Section 10.1.5.2). Based on the assessment provided in Table 10-1, the following approaches will be discussed further: both forms of FMS (i.e., fine-mesh traveling water screens, fixed wedgewire screens), alternate water sources, closed-cycle cooling, and variable speed pumps. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-1. Entrainment Reduction Technologies to be Assessed Retained for Effectiveness at Reducing Alternative Approach to IM BTA More Detailed Basis of Decision Entrainment Assessment? Traveling Screen Modifications Modified traveling screens, consistent Based on rates of exclusion and Potential approach to FMS, assessment with Modified traveling screens per Yes, post-exclusion survival as affected of which is required by 40 CFR 125.92(s), 40 CFR 125.94(c)(5) Section 10.5 by mesh size and species type 40 CFR 122.21(r)(10) with fine-mesh and an organism return Fixed Screening Devices Wedgewire screens Through-screen velocity Potential alternative approach to FMS, with narrow-slot and (TSV) less than 0.5 ft/s at DIF Slot size of 0.5 mm expected to Yes, assessment of which is required by through-slot velocity consistent with exclude entrainable organisms. Section 10.5 40 CFR 122.21(r)(10) 0.5 ft/s 40 CFR 125.94(c)(2) AFBs have very limited application. Potentially reduced TSV, AFBs suitable in quiescent settings. 40 CFR 125.94(c)(2), or Ambient conditions in the Atlantic contribution to system of Ocean are also not suitable for AFBs measures, Low to high depending upon due to tide range, wave action, AFB No 40 CFR 125.94(c)(6); installation and reliability. necessary screen area, and potential for significant reduction in IM hurricanes. There are only a few possible if system is properly installations of AFBs and their use for installed and reliable. entrainment control is de-emphasized by the manufacturer. A porous dike cannot be built to meet ambient conditions found at the Plant. Constraints would also be severe in the Atlantic Ocean including the necessity Potential contribution to Likely low due to imperfect to fill substantial portions surrounding Porous dike system of measures, exclusion and creation of artificial No the velocity caps. Such a system would 40 CFR 125.94(c)(6) habitat. represent an unacceptable impediment to navigation even if it were believed to be effective. Pore clogging. Insufficient space. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-8

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-1. Entrainment Reduction Technologies to be Assessed (Continued, Page 2 of 2) Retained for Effectiveness at Reducing Alternative Approach to IM BTA More Detailed Basis of Decision Entrainment Assessment? Flow Reduction IM BTA under High. Approximately 80 percent Yes, Assessment is required by CCRS 40 CFR 125.94(c)(1). reduction in entrainment possible. Section 10.4 40 CFR 122.21(r)(10). PSL is expected to generate over 90 Variable speed Potential contribution to Reductions in entrainment percent of the time on average; there Yes, pumps or variable system of measures, generally estimated as proportional would be little opportunity to further Section 10.7 frequency drives 40 CFR 125.94(c)(6) to flow. reduce flow using variable speed pumps. Potentially contributes to IM Reductions in entrainment Alternate water Yes, Assessment is required by reduction under generally estimated as proportional sources Section 10.6 40 CFR 122.21(r)(10). 40 CFR 125.94(c)(6) to flow. Other Measures The velocity cap per se may not reduce entrainment, but the No; discussed location of the velocity cap and Velocity cap in 122.21(r)(6) Continue to maintain and distance from shore may reduce Not a proven technology for consistent with under IM operate existing velocity cap. entrainment. This location was entrainment compliance. 40 CFR 125.94(c)(4). compliance originally selected for its low measures productivity relative to the Indian River Lagoon. Note: A variety of other measures (including louvers, angled screens, and behavioral deterrents) have been applied at other facilities in an attempt to reduce rates of impingement, they do not provide meaningful reductions in entrainment and, therefore, are not considered here. Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-9

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.1.6 Distinction Between Facility-level and Social Costs EPAs interpretation and expectations of facility-level compliance costs and social costs are discussed in 79 FR 48367. Social costs represent the burden on all members of society; they are the sum of all opportunity costs incurred, whereas facility-level costs represent only those costs that would be incurred by the facility. Per EPA (2014), social costs may be higher or lower than facility-level costs. Key differences between facility-level costs and social costs include:

• Facility-level costs include taxes, whereas social costs do not, as taxes are viewed as a transfer and not a real resource cost.
• When estimating present value (PV), facility-level costs use the market cost of capital in the interest rate, whereas the Final Rule requires that social costs be evaluated using both 3- and 7-percent discount rates.
• Social costs include the Directors (i.e., the Governments) administrative costs (e.g.,

costs for agencies to review permits and evaluate compliance).

• Facility downtime associated with tie-ins results in lost revenue to the facility; however, if another facility is required to compensate for lost generation, then the social cost would include only the increase in marginal cost of production at the other facility.

10.1.7 Overview of Facility Cost Development This subsection will provide context for the nature of the facility cost estimation process. 10.1.7.1 Approach to Cost Estimation and Relationship to Design Process The goal of this report is to understand the feasibility and approximate costs of a set of measures that may be appropriate to reduce entrainment at PSL, and in no case is it a detailed design developed for these measures. Instead, an estimate of the technology configuration at the site is used to develop approximate facility costs as well as identify constraints on installation and operation that would affect costs, feasibility, and effectiveness. While this is appropriate for this report, there is a possibility that some significant constraint (e.g., subsurface obstacles to construction) has not been identified by this process, and that a more complete design process would result in higher facility costs and/or lower feasibility. This evaluation attempts to develop Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) a one to 15 percent design to enable an Association for the Advancement of Cost Engineering (AACE) Class 4 estimate to facilitate a BTA determination (refer to Section 10.1.7.2). Similarly, the development of these estimates has required decisions to be made regarding the specific technology configurations to be used (e.g., the nature and target velocity of the FMS; the nature and location of potential cooling towers). These items will be discussed in the relevant sections below, but the fact remains that a more complete design process may reach different conclusions about the best configurations and operational strategies. With this in mind, we have attempted to specify a system for each technology that overcomes clear operational problems (e.g., does not result in unacceptable intake velocities; does not exceed the pressure specification of the condensers; accounts for obvious constraints on air emissions and discharge of cooling tower blowdown) while minimizing the facility level costs to the extent practicable. A good example of this tradeoff is the selection of evaporative cooling towers over air-cooled condensers. Tie-ins to the existing facility or other modifications to the existing cooling system invariably increase downtime and associated costs. Therefore, this evaluation considers scenarios where much of the hypothetical construction work would be carried out without disrupting the Plants operations to the extent practicable, and the tie-ins and invasive construction steps would only be performed after the majority of the new construction is complete. This tradeoff will be considered in several places in the following subsections. 10.1.7.2 Level of Facility Cost Estimation The engineering evaluation presented herein aims to develop a Class 4 cost estimate as defined by AACE. A Class 4 costs estimate was conducted for all technologies except where otherwise indicated. As shown in Table 10-2, a Class 4 estimate suggests costs between 1 and 15 percent design of the system, and is meant to assess the feasibility of a project (which is also the goal of the 40 CFR 122.21(r)(10) engineering evaluation). A Class 4 estimate does not need to assess all costs in detail; parametric estimates that apply to the system are acceptable. Such an estimate is expected to be accurate to -15 and -30 percent on the lower end to 20 and 50 percent on the Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-11

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) upper end. Additional information about cost estimating accuracy may be found at AACE (2016). Table 10-2. AACE Costing Categories Primary Secondary Characteristic Characteristic LEVEL OF EXPECTED PREPARATION Estimate PROJECT END USAGE ACCURACY METHODOLOGY EFFORT Class DEFINITION Typical RANGE Typical estimating Typical degree of Expressed as % purpose of Typical variation method effort relative to of complete estimate in low and high least cost index of 1 definition ranges Capacity Factored, Concept L: -20% to -50% Class 5 0% to 2% Parametric Models, 1 Screening H: +30% to +100% Judgment, or Analogy Study of Equipment Factored or L: -15% to -30% Class 4 1% to 15% 2 to 4 Feasibility Parametric Models H: +20% to +50% Budget, Semi-Detailed Unit L: -10% to -20% Class 3 10% to 40% Authorization, Costs with Assembly 3 to 10 H: +10% to +30% or Control Level Line Items Detailed Unit Cost with Control or L: -5% to -15% Class 2 30% to 70% Forced Detailed Take- 4 to 20 Bid/Tender H: +5% to +20% Off Check Detailed Unit Cost with L: -3% to -10% Class 1 50% to 100% Estimate or 5 to 100 Detailed Take-Off H: +3% to +15% Bid/Tender Source: AACE, 2016. 10.1.7.3 Engineering Cost Methodology The overall engineering cost estimate for each feasible/practical entrainment reduction technology will include the following cost elements:

• Capital and operational and maintenance (O&M) costs
• Facility owners taxes on capital and O&M costs
• Facilitys administrative costs
• Facility downtime costs
• Mitigation costs associated with non-water quality impacts (discussed in the Section 12)

Capital costs would include (as appropriate):

i. Key components based on site-specific conditions such as:

• Equipment.
• Installation.

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Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13)

• Foundation costs, potentially including piles depending on subsurface conditions.
• Key electrical equipment.
• Earth moving (assuming non-hazardous soils).

ii. Parametric estimates for:

• Pumps.
• Pipelines.
• Conduits and pipes.

iii. Lump sum placeholders for:

• Permits.
• Valves.
• Signage.

iv. Costs for modifying, restoring, or relocating infrastructure impacted by the installation of the entrainment reduction technology.

• These items will be identified, and associated costs developed to the extent practicable for the purposes of this evaluation. These costs will be biased low to present a conservative cost to the permit writer and for the cost-benefit analysis.

O&M Costs will include (as applicable):

• Labor to maintain the new system.
• Electricity needed to power new facility systems.
• Chemicals associated with increased water treatment.
• Maintenance and repair costs.
• Solids/sludge removal from cooling tower basin.

For simplicity, the evaluation assumed the Plants administrative costs would be approximately 10 percent of the total project costs and spending in each year would be proportional to project spending. For facility downtime costs, the engineering evaluation estimated the potential downtime durations associated with each technology implementation. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-13

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Mitigation costs associated with non-water quality impacts (discussed in the Section 12 Report): When mitigation measures were proposed in the Section 12 Report, associated costs were included in this report. The costs were estimated using material quantities and labor estimates developed from the conceptual designs. Most of the costing information is based on published materials and labor costs for Fort Lauderdale, FL (RS Means, 2020). Technology-specific costs are based on manufacturer quotes from several similar facilities that were adjusted for identifiable differences in project sizes and operations. The combined costs allow a valid comparison of the cost difference between alternatives and their associated benefits. Construction-related shutdowns could have a significant impact on the feasibility and costs of the selected intake technologies. For this analysis construction techniques and sequencing were selected to minimize construction-related shutdowns and their impacts. However, when shutdowns could not be avoided, a cost of $68.60/MWh was used to determine the penalty associated with lost power generation. 3 Site-specific conditions, construction techniques, and sequencing identified during the detailed design of a selected technology may result in construction related shutdowns beyond those identified in this study. The impact of construction related shutdowns identified in this study were included in the overall cost estimates, but uncertainty in the length and timing of any construction related shutdowns could result in higher construction costs. Annual O&M costs were determined for each of the selected technologies. These costs are based on the power, labor, and minor component replacement costs needed to operate and maintain each technology. They are based on the same assumptions used in calculating the capital costs. The power cost to operate each technology was assumed to be $68.60/MWh. Energy penalty costs represent the estimated loss in revenue associated with generating inefficiencies related to flow or operating restrictions. This cost includes both the cost to produce 3 The cost of $68.60/MWh is based on the average January 2020 industrial electricity rate for Florida of 7.36 cents per kilowatt-hour (EIA 2020). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-14

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) the electricity and profits lost by that power no longer being available for sale. A cost of $68.60/MWh was used to determine the penalty associated with lost generation, based on the average industrial electricity rate in Florida for January 2020 (EIA, 2020). Engineering costs will be presented as PV and equivalent annual costs (EAC). PV is provided to convert all the present and future costs to a base year, assumed to be 2020. This was done to estimate the present cost of each alternative over its lifespan. EAC is the annual costs of owning, operating, and maintaining each option over the life of the technology. The costs used for the NPV and EAC analysis are based on the incremental charges that FPL could incur if it had to reduce both IM and entrainment, compared to changes to reduce only IM. As discussed below, any costs associated with operation according to the status quo, or dedicated to addressing IM compliance alone, are not considered in the cost estimation for the entrainment BTA measure. A period of 16 years (2020-2036) was used for the cost analysis based on an expected retirement date of 2036 for Unit 1; a period of 23 years (2020-2043) was used for the cost analysis based on an expected retirement date of 2043 for Unit 2 (NRC, 2018a; NRC, 2018b). Permitting and preconstruction study costs are assumed to start at the end of 2021. Capital costs are assumed to occur after completion of the design and permitting, with annual and periodic costs occurring thereafter. Taxes were assumed to be 6 percent; the interest/discount rate was assumed to be 7.55 percent; the escalation rate was assumed to be 3 percent (FPL, 2019). 10.1.8 Process of Estimating Social Costs 10.1.8.1 Categories of Social Costs Social costs can be delineated as each of the following:

• Compliance costs-direct purchase installation and operation
• Government regulatory costs-monitoring, administration, enforcement
• Power system costs-increased fuel cost impacts from energy penalty and proposed outages.
• Environmental externalities-changes in environmental quality such as those to water flow, noise, emissions, and viewsheds.
• Economic Impacts-unit closures and long-term electricity price increases.

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Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Because the Final Rule does not require quantification of all social cost components, only those social cost components expected to be large and easily quantified were monetized. Thus, the analysis conducted for PSL includes quantitative estimates for the first three categories listed above. Social cost components likely to be small and/or difficult to quantify (for example, unit closure and electricity price increases) were not estimated. The result is therefore best characterized as a partial social cost estimate. Compliance costs result from purchasing, installing, and operating technologies at PSL. Government regulatory costs are developed from EPAs estimates in the Final Rule (79 FR 158, 48300-48439). The social costs from power system effects are developed from evaluating backpressure and auxiliary load effects, capacity losses from each of the technologies with estimated outage times, and electricity consumption associated with each technology (Veritas, 2020). Externality costs represent the environmental impacts associated with the installation of entrainment reducing technologies. Operation of a closed-cycle cooling system has the potential to affect nearby recreation and property values. The methods and results of those studies are presented in Appendix 10-A of this report. 10.1.8.2 Financial and Regulatory Environment PSL is operated by FPL, a regulated, investor-owned public utility that is a subsidiary of NextEra Energy. FPL owns the entirety of St. Lucies Unit 1 and 85 percent of Unit 2 (NextEra 2019). The remaining 15-percent ownership share of Unit 2 belongs to the Florida Municipal Power Agency (FMPA) and the Orlando Utilities Commission (OUC) (FMPA 2020, nFront Consulting 2019). The analysis assumes that compliance costs would be passed on to FPLs, FMPAs, and OUCs electric customers proportionally to their ownership shares (refer to Appendix 10-B for specific implications on social costs). FPL generates, transmits, distributes, and sells electricity across nearly half the state of Florida. Over 5 million residential, commercial, and industrial customers are served in 35 Florida counties. FPLs assets include approximately 23,970 MW of nuclear, coal, oil, natural gas, and solar generating capacity (FPL, 2019a). Figure 10-1 presents FPLs electric service territory and location of generating assets, and Figure 10-2 illustrates FPLs generation portfolio by fuel type (FPL, 2019a). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-16

FIGURE 10-1. FPL SERVICE TERRITORY AND MAJOR GENERATING ASSETS Source: Veritas, 2020. 10-17

10-18 FIGURE 10-2. FPL'S GENERATION PORTFOLIO AND FUEL TYPE Source: Veritas, 2020.

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) FPL is potentially eligible to recover all or part of the costs of installing entrainment reduction technologies. Electric utilities operating in Florida can file a rate request to the Florida Public Service Commission (FPSC) for recovery of costs. The FPSC holds hearings and based on the facts can approve a settlement agreement authorizing cost recovery (FPSC, 2019). Procedures involved in rate request hearings include allowing intervener comments and FPL rebuttals. Since installing entrainment-reducing technologies is a regulatory environmental compliance requirement (as opposed to typical O&M), these costs are expected to be passed on to customers in the form of higher rates. These costs would need to be included in a future rate case filing. FPLs recent rate case history is instructive with respect to the implications of additional rate increase filings. In November 2016, the FPSC issued a four-year rate agreement order which allowed for a base rate increase phased in over three years (NextEra Energy, 2017). Effective January 1, 2017, base rates were increased by $400 million. An additional $211 million increase in base rates was implemented on January 1, 2018. The agreement includes a provision to allow for the recovery of an additional $200 million in base rate increases to cover the costs of the new 1,750 MW natural gas combined-cycle generation station in Okeechobee County. The costs associated with new entrainment reduction technologies would be additional costs that could potentially lead to another rate increase filing which would result in higher prices for residential, commercial, and industrial customers. The magnitude of these additional increases could also lead to economic impacts that can accompany electricity price increases (Deschenes, 2010). Changes in electricity prices can lead to economy-wide employment impacts through their effect on residential and business electricity consumers. For business electricity impacts, the commercial and industrial sectors are all major users of electricity as an input to production. Electricity price increases would raise the costs of providing final goods and services in these sectors. The analysis does not quantify this effect on other sectors of the economy. 10.1.8.3 Market Environment Retail electric markets in Florida are currently not deregulated. The state has three investor-owned regulated utilities that collectively serve approximately 75 percent of the customers in Florida. The remainder is served by regulated municipalities and electric cooperatives. The Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-19

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) regulated utilities generate power and transmit, distribute, and sell electricity to local customers who live in their defined geographic service territory. The FPSC regulates the utilities through a rate-making process that ensures electricity is produced and delivered at the lowest possible cost while allowing the utility to recover costs along with a fair rate of return. In addition to being subject to rate case discovery and hearings to prove costs are just and reasonable, electric utilities are required to submit annual forecasted earnings surveillance reports to the FPSC to ensure the utilities rate of return is within an approved range. The state of Florida does not participate in any of the multi-state Regional Transmission Organizations (RTO). Rates are set for each regulated utility to cover the costs to produce and deliver reliable power to customers. To ensure reliability, rates include reserve capacity that is available as needed for peak periods, extreme weather events, planned plant outages for maintenance, inspections and refueling, and for any unplanned outage that may occur. FPLs integrated resource planning protocol sets a minimum reserve capacity at 20 percent of total capacity (FPL, 2018). Customers pay for the year-round availability of this reserve margin within their rates regardless of whether they use this electricity or not. PSL produces a significant amount of electricity for FPLs electric customers, representing approximately 7 percent of FPLs total generation (Figure 10-2). Temporary outages to install cooling towers would have an impact on FPLs operations. If feasible, construction would be scheduled during off-peak months and during a time when other generating plants are not undergoing routine scheduled maintenance. Under these conditions, a construction outage may not impact FPLs ability to meet reserve capacity requirements; projected reserves are at or above required reserves through 2027 (FPL, 2018). 10.1.8.4 Methods for Social Cost Estimation The first step in estimating the social costs of compliance is to determine whether entrainment-reducing technology costs result in the plant becoming uneconomic to operate. A premature shutdown of the plant would have social costs related to loss of jobs, income, expenditures, and tax base; increased electricity costs due to generation being dispatched at a higher price from less efficient plants; and increased infrastructure costs to maintain grid reliability. Installing entrainment-reducing technologies at PSL to comply with EPAs 316(b) Final Rule represents an Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-20

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) additional operation cost that would most likely be passed on to FPLs customers in the form of higher rates. PSLs significance in FPLs generating portfolio suggests only an extraordinarily expensive conversion requirement would lead to premature closure. Therefore, this analysis specifies FPL will incur the entrainment-reducing compliance costs and continue to operate PSL, and pass on the compliance costs to FPLs customers. The social costs of installing entrainment reduction technologies are estimated by first determining the design, construction, and installation costs of the evaluated technologies along with the O&M, permitting, and fuel costs. Based on FPLs market conditions and ability to submit environmental compliance costs for rate recovery, this analysis specifies that all PSLs compliance costs would be passed on to FPLs customers. Following the requirements of the Final Rule, social costs are evaluated under two discount rates: 3 and 7 percent (79 FR 158, page 48428). For determination of social costs, PSL Unit #1 is estimated to retire in 2036 while Unit #2 is assumed to retire in 2043, consistent with the capital costs analysis. Therefore, engineering costs are specified as occurring over the remaining lifetime of PSL to develop the social cost estimates. Fuel costs are specified to occur during the time of both construction and operation. Regulatory documents will be submitted in 2021 and the timing for activities related to installation are dependent on the technology being installed. The social costs of each technology include the expected electricity price increases associated with each technology, the additional system-level fuel costs that would be incurred with each technology, permitting costs, and externality costs. As previously noted, the analysis specifies that all the engineering costs are passed on to FPLs rate payers resulting in increased electricity prices. To develop the price increases, the design, construction, and installation costs are allocated over the specified construction and installation time period. O&M costs are then added for each year the technology is operational, and the future stream of those costs are discounted by 3 and 7 percent to develop the present value estimate for each discount rate. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-21

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Fuel costs represent the additional power needed to operate the new technologies and the net differences in fuel consumption from running other units during installation construction outages. The fuel costs are developed from evaluating backpressure and auxiliary load effects, capacity losses from each of the technologies with estimated outage times, and electricity consumption associated with each technology. Details of the fuel cost estimates are presented in Appendix 10-A. Government administrative costs include the total costs associated with permitting, monitoring, administering, and enforcing the technology selection and installation. Costs are incurred by the government as the permitting and review process is undertaken. These vary with the type of technology, as certain technologies require substantially more permitting. Those with more significant environmental effects would have higher permitting costs. These costs are initially borne by the government, but ultimately paid by taxpayers. Permitting costs are developed from EPAs estimates in the Final Rule (79 FR 158, 48300-48439) and are specified to be 0.02 percent of direct capital costs. Externality costs may result from installing cooling towers at PSL. A closed-cycle conversion may produce physical changes that result in recreation and property value changes. The view from a recreational site could be affected by the profile of a cooling tower and by the presence of a visible plume. Noise levels at a recreational site could be affected by the operation of cooling tower pumps and fans. Details of the externality costs estimates are presented in Appendix 10-A. 10.1.9 Remaining Life of the Plant The estimated remaining life of Units 1 and 2 affect the specific technology impacts and benefits, O&M costs, social costs, and potential future technology repair costs. A 16-year operational life span for Unit 1 (i.e., the unit will operate through 2036), and a 23-year operational life span for Unit 2 (i.e., the unit will operate through 2043) have been estimated assuming the NRC operating license expiration dates (NRC, 2018a and 2018b). If the original entrainment reduction technology is in good operating order at that time, it is assumed that the technology would be retired then. Any potential salvage value is assumed to be minor and is not evaluated here. If the estimated life of the technology is projected to be shorter than the remaining life of the unit, then Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-22

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) this evaluation assumes that the technology would be repaired or rebuilt and somehow made available to service the generating units through 2036 (Unit 1) and 2043 (Unit 2). 10.2 Existing Facility 10.2.1 Site and Surroundings Summary PSL is located in an unincorporated area of St. Lucie County on Hutchinson Island northeast of Port St. Lucie, Florida. Hutchinson Island is a barrier island. The Plant withdraws cooling water from the Atlantic Ocean through three velocity caps; the Plant also has an emergency intake system located on Big Mud Creek, a cove of the Indian River Lagoon. The Atlantic Ocean is used for commercial fishing and shipping, as well as for recreational and other boating uses. The Indian River Lagoon is used for similar purposes. The Plant has barge slip access via the Indian River Lagoon. The general location and layout of the Plant and its surroundings are shown on Figure 10-3 and Figure 10-4. Figure 10-5 provides the population density in the general vicinity of the Plant. Because the Plant is located on the barrier island, the population density within a 1-mile radius of the Plant is low except for the area southeast of the Plant on the island and increases beyond 1 mile from the Plant. Potential visual, noise, and deposition impacts (discussed in the Section 12.0 report) are typically higher when the population density immediately surrounding the Plant is high. 10.2.2 Plant Intake Flows Relevant portions of the cooling water system are described here; additional information can be found in Sections 3 and 5 reports. Per 40 CFR 125.92(g), DIF is defined as the maximum instantaneous rate of flow of water the cooling water intake system is capable of withdrawing from a source waterbody. The regulations allow the DIF to reflect any permanent changes to the system, such as removing pumps from service. In addition, the definition of DIF states that it does not include values Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-23

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-3. PSL Location Map Source: ASA, 2020. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-24

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-4. PSL Layout Map Source: ASA, 2020. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-25

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-5. Population Density Surrounding PSL Source: ASA, 2020. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-26

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) associated with emergency and fire suppression capacity or redundant pumps (i.e., back-up pumps). Unit 1 includes four circulating water pumps, each rated at 121,000 gallons per minute (gpm; 174.24 MGD), for a total of 484,000 gpm (696.96 MGD). Unit 1 also has three auxiliary water pumps 4 (two duty, one spare), each rated at 14,500 gpm (20.88 MGD), for a total of 29,000 gpm (41.76 MGD). The Unit 1 condenser is supported by the circulating water pumps; therefore, the Unit 1 condenser water flowrate is 484,000 gpm (696.96 MGD) and the units total water use rate is 513,000 gpm (738.7 MGD). Unit 2 also has four circulating water pumps each rated slightly higher at 122,650 gpm (176.62 MGD), for a total of 490,600 gpm (706.46 MGD). Unit 2 also has three auxiliary water pumps (two duty, one spare), each rated at 14,500 gpm (20.88 MGD), for a total of 29,000 gpm (41.76 MGD). The Unit 2 condenser is supported by the circulating water pumps; therefore, the Unit 2 condenser water flowrate is 490,600 gpm (706.46 MGD) and the units total water use rate is 519,600 gpm (748.2 MGD). Table 10-3 provides an overview of the pump capacities. Table 10-3. PSL Pump Capacities Pump Total Flow Number of Unit Flow Regimes Capacity Pumps gpm MGD (gpm) Unit 1 circulating water 4 duty 121,000 484,000 696.96 Unit 1 auxiliary water (ICW) 2 duty, 1 spare 14,500 29,000 41.76 Unit 1 Total 513,000 738.72 Unit 2 circulating water 4 duty 122,650 490,600 706.46 Unit 2 auxiliary water (ICW) 2 duty, 1 spare 14,500 29,000 41.76 Unit 2 Total 519,600 748.22 Plant Total 1,032,600 1,486.94 Source: FPL 2005. 4 The auxiliary water pumps are also referred to as intake cooling water pumps (ICW pumps). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-27

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.2.3 Existing Cooling System A plants condensers and cooling towers need to complement each other; that is, all heat added at the condenser needs to be removed by the cooling tower. When designing a new power plant, the cooling tower and condenser would be evaluated in tandem to achieve optimal performance of both based on site conditions. However, when retrofitting an existing power plant with cooling towers, the existing condensers are used as-is to the extent practicable (EPRI, 2007). While certain reinforcements to the condenser tubes or waterboxes can facilitate continued use of the existing condensers, the design, construction, and age of the existing condensers may not always allow for conversion of an existing once-through system to closed-cycle (refer to Section 10.3.3.5). This evaluation assumes the existing condensers would continue to be used with a CCRS retrofit; however, if CCRS was found to be BTA, the need to modify or replace the existing condensers would be re-evaluated. The potential costs of such actions, if feasible, are not considered in the facility cost estimate developed below. This section discusses the existing condensers at PSL, and the nature of a cooling tower that could potentially be employed. Section 10.3.3.5 discusses the nature of retrofits needed if the condensers and cooling water pipes have to be replaced. Steam electric power generation facilities use steam turbines and condensers to generate electricity. Turbines typically consist of a rotor assembly, which is a shaft or drum with blades attached; steam is generated in the boiler and moves through the turbine turning the blades and shaft. The rotational energy from the rotor assembly is converted into usable energy to produce electricity 5. The exhaust steam from the turbine is then condensed to liquid state for reuse in the boiler for the steam generation system by use of a condenser, which is a type of heat exchanger. Condensers typically consist of multiple tubes encased in a shell, commonly referred to as a shell and tube. Steam flows through the shell 6 and is condensed when passed across tubes, 5 The rotor assembly operates in conjunction with an electrical generator. 6 Depending on the specific design of the condenser, the steam may be instead routed through the tubes and the cold water through the shell. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-28

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) which contain cold water. 7 The condensate is then collected and returned to the boiler to be reheated into steam and recirculated through the system. A waterbox is located on both sides of the condenser. On the inlet side, cold water enters and is directed with uniform distribution toward the tube sheet. The tube sheet is a metal sheet with perforations that allow for entry of water into the condenser tubes. On the discharge side, warmed water is collected in the outlet waterbox and removed from the condenser. In a once-through system, the warmed water is discharged to a receiving water body. In a CCRS, the warmed water is directed to the cooling tower to be cooled and reused. If a facility were retrofitted with closed-cycle cooling, the waterboxes and condenser would need to be retrofitted with new reinforced piping to form a closed-loop circulating system. Alternatively, reuse of an existing system in a closed-cycle system must accommodate the constraints on the existing system. PSL utilizes a single condenser per unit; the design parameters for the condensers that are pertinent to the cooling tower feasibility evaluation are summarized in Table 10-4. Table 10-4. Pertinent Design Parameters from the Existing PSL Condenser Specifications Parameter Unit 1 Unit 2 Units Number of condensers 1 1 Heat rejection rate, total duty (Btu/hr) 6.850 x 109 6.781 x 109 Btu/hr Temperature rise across shell (°F) 30.2 29.5 °F Cold water temperature in (°F) 75 75 °F Hot water temperature out (°F) 105.2 104.5 °F Source: FPL, 2017. 10.2.4 Cooling Water Intake Structure PSLs once-through cooling water system is supported by three velocity caps approximately 1,200-ft offshore within the Atlantic Ocean (FPL, 2005). Two of the velocity caps utilize 12-ft diameter pipes, and the third velocity cap utilizes a 16-ft diameter pipe. The tops of the velocity caps are approximately 7-ft below the water surface at mean low tide (FPL, 2005). 7 Tubes may be in a single-pass or multiple-pass arrangement, depending on the design requirements of the condenser. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-29

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Ocean water enters the intake canal through three submerged intake pipes from the velocity caps; the intake canal routes water approximately 5,000-ft to two intake structures, one per unit. The intake canal is approximately 300-ft wide and 25-ft deep (FPL, 2005). A series of three barrier nets are located in the intake canal, designed to confine turtles and to withstand unusual events, such as seaweed, algae, jellyfish, and siltation (FPL, 2005). The nets prevent turtles from traveling towards the bar racks and TWS (FPL, 2005) and protect the plant from potential human intrusion (FPL, 1995). The first net has 5-inch openings, the second net has 8-inch openings, and the third net has 9-inch openings. The second and third nets are used to assist in confining turtles that have passed each preceding net. Once water passes through the barrier nets, it reaches the intake structures at the Plant. A few photographs of the intake canal are shown in Figure 10-6. The Unit 1 and Unit 2 intake structures each have four bays equipped with fixed bar racks (cleaned with trash rakes 8) and four traveling water screens with 3/8-inch mesh; debris washed from the screens is collected in a trash basket for disposal (FPL, 2005). Cooling water is returned to the Atlantic Ocean north of the intake canal through two submerged, buried concrete pipes that discharge offshore. One discharge pipe extends approximately 1,250 ft from shore and has a Y-shaped diffuser. The other extends approximately 1,930 ft from shore with an additional 1,416 ft of 58-port multiport diffuser (FPL, 2017) (Figure 10-4). There is an emergency water intake structure that would only be utilized in an emergency event where there is insufficient water for the safe shutdown of the PSL. This emergency water intake can allow water to enter the intake canal from Big Mud Creek through two 54-in pipes and valves (FPL, 2005). To ensure the emergency water intake is operational during an emergency, the intake structure is tested quarterly by opening and closing each valve for a period of less than one minute (FPL, 2005). 8 The rake system was upgraded in 2017 and 2018 with a Flexrake System. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-30

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-6. Various Views of the Intake Canal Source: ECT, 2018. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-31

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.3 Closed-cycle Recirculating Systems 10.3.1 Cooling Tower Principles Once-through cooling systems can be retrofitted with a variety of cooling tower designs. The designs can be grouped based on factors influencing the type of design, including:

• Method of heat transfer: wet, dry, or combination wet and dry heat transfer.
• Method of air flow: natural draft, mechanical forced draft, mechanical induced draft.
• Direction of air flow: counter-flow or cross-flow.
• Shape and Arrangement: rectilinear (i.e., in-line or back-to-back) or round.

These factors impact the cooling tower size and operation, which subsequently affect environmental and social impacts. The method of heat transfer is perhaps the most important factor in determining the type of cooling tower. The types of cooling towers are described in the following subsections. 10.3.1.1 Method of heat transfer The cooling tower acts as a mechanism to transfer the waste heat 9 to the atmosphere. Heat transfer to the atmosphere can be carried out through one of three methods (SPX, 2009):

• Latent heat transfer, which is associated with the phase changes of water, such as evaporation
• Sensible heat transfer, which is associated with the incremental change in temperature of a medium, such as air in the atmosphere
• A combination of both latent heat transfer and sensible heat transfer Cooling towers that employ a combination of both sensible and latent heat transfers are evaporative-type towers and are typically referred to as wet cooling towers. Cooling towers that employ only sensible heat transfer utilize a dry-surface, finned-tube heat exchanger that transfers heat to the atmosphere; these towers are typically referred to as dry towers (SPX, 2009).

9 Heat energy is utilized in the generation of electricity; heat energy that is not converted to electricity is removed to cooling water within the condensers. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-32

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Similar to wet cooling towers, once-through cooling systems typically employ a combination of both heat transfer methods; heated water from the once-through system is discharged to a receiving waterbody, which is heated through sensible heat transfer. Latent heat transfer then drives evaporation of a small portion of the waterbody to the atmosphere for further cooling. Sensible heat transfer also occurs from the waterbody to the air, but the cooling provided by sensible heat transfer is smaller than the cooling provided by latent heat transfer. 10.3.1.2 Method of Air Flow Air flow through the cooling tower is critical to facilitate both latent and sensible heat transfer. In the absence of air exchange, moisture and heat would accumulate within the tower and retard heat transfer from the cooling tower. As noted previously, the method of air flow can be either natural draft, mechanical forced draft, or mechanical induced draft. With respect to natural draft, the hyperboloid shape has been shown to improve efficiency; the density differential between the heated, less dense air inside the cooling tower and the cooler, denser air outside the cooling tower produces air flow through the tower (SPX, 2009). Mechanical, forced draft cooling towers have a fan located on the ambient air intake side and blow air through the tower. Forced draft towers typically have high entrance velocities and low exhaust velocities; therefore, they are susceptible to recirculation (SPX, 2009). Recirculation occurs when the exhaust is drawn back into the inlet, resulting in an increased ambient air wet-bulb temperature and decreased performance of the cooling tower (SPX, 2009). Mechanical, induced draft cooling towers have a fan located on the exhaust side and draw air in through the tower. Induced draft towers can have an exhaust velocity of three to four times the entrance velocity, meaning there is little tendency for self-initiating recirculation (SPX, 2009). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-33

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.3.1.3 Direction of Air Flow As noted previously, air flow through the towers can be either counter-flow or cross-flow. In counter-flow towers, air moves vertically through the tower fill 10, counter to the downward cascade of water (SPX, 2009). In a cross-flow tower, the fills configuration is such that the air flows horizontally across the downward cascading water (SPX, 2009). In all types, the ambient air enters the cooling tower from the side and is exhausted through the top; the portion of water that evaporates into the air stream cools the remainder of the water (EPRI, 2011). 10.3.1.4 Shape and Arrangement Cooling towers can also be characterized by their shape and arrangement. While all natural draft cooling towers (NDCT) are round, mechanical draft cooling towers (MDCT) can be in a rectilinear arrangement or in a circular arrangement. In a rectilinear arrangement, the MDCT is comprised of cells that can be aligned in a single row (i.e., in-line) or in a double row (i.e., back-to-back) (EPRI, 2011). In a rectilinear arrangement, evaporative cooling towers should be arranged parallel to predominant wind direction corresponding to the warmest and most humid time of the year (SPX, 2009). Cells can be added to meet thermal performance requirements. In circular MDCT, fans are clustered as closely as possible to the center of the tower (SPX, 2009). There is an alternate version of round towers where the cells are arranged in an octagonal arrangement, allowing for larger heat loads that impact less area, compared to rectilinear towers (SPX, 2009). 10.3.2 Cooling Tower Terminology Cooling towers are chosen based on factors that affect their performance. The atmosphere has different psychrometric properties 11, and cooling towers react thermally or physically to each 10 Fill is an important component of cooling towers, because it determines the efficiency of the tower through maximizing contact surface and contact time between air and water while providing the least amount of restriction of air flow (SPX, 2009). 11 Psychrometrics is the field of study relating to physical and thermodynamic properties of gas-vapor mixtures. Typical psychrometric parameters include dry-bulb, wet-bulb, and dew point temperatures. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-34

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) property (SPX, 2009). However, some factors, such as heat load, are more significant than others. The following is a discussion of some key terms. 10.3.2.1 Heat Load Heat load is the total amount of heat removed from the circulating water by the cooling tower and is a function of the mass flow rate of water entering the cooling tower and the cooling tower range (EPRI, 2011; SPX, 2009). The heat load can be related to the approach and range temperatures; this relationship is shown on Figure 10-7. Figure 10-7. Relationship Between Heat Load, Range, and Approach Source: SPX, 2016. 10.3.2.2 Range The range is the difference between the hot water temperature entering the cooling tower and the cold-water temperature exiting the cooling tower. The cooling tower range is equivalent to the temperature rise across a facilitys condensers, which is commonly referred to as the delta T (T). The size and subsequent cost of a cooling tower is proportional to the heat load and the cooling tower range (SPX, 2009). The range is shown graphically on Figure 10-8. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-35

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-8. Condenser and Cooling Tower Water Temperature Relationships Sources: SPX, 2009. ECT, 2021. 10.3.2.3 Approach Approach is another factor considered in the thermal design and performance of a wet cooling tower. The approach is the difference between the cold-water temperature exiting the cooling tower and the ambient air wet-bulb temperature 12 entering the tower (Figure 10-8). Cooling tower performance and size are inversely proportional to the approach. When varying cooling tower size, the approach starts to become asymptotic near 5°F. Approach temperatures less than 5°F are typically not guaranteed, because errors in measurement of performance can be very significant (SPX, 2009). In addition, approach temperatures less than 10°F are not considered practical. 10.3.2.4 Drift A portion of the circulating water in the cooling tower is lost 13 due to drift, evaporation, and blowdown. Drift occurs when circulating water is lost from the tower as liquid droplets become entrained in the exhaust air stream (EPRI, 2011). To reduce the amount of water lost, drift eliminators can control the loss of water to as low as 0.0005 percent of the circulating water flow rate and can be installed in wet cooling towers (EPRI, 2011). Water is also lost due to evaporation, which is the main method of removing the waste heat from the circulating water. 12 Wet-bulb temperature is the temperature of air if it were cooled to 100% relative humidity (i.e., saturation) by evaporation of water into it through latent heat transfer. 13 Basin leaks and overflows can also cause water to be lost from the system when the towers are not properly operated. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-36

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.3.2.5 Blowdown Operating at high levels of total dissolved solids (TDS) with the continued evaporation of water can cause the impurities to reach saturation levels, which may produce scale and precipitate in the cooling system, lead to corrosion problems, and cause an increase in operation and maintenance costs (DOE, 2016; EPA, 2014). Therefore, a portion of the water that circulates between condensers and cooling towers is removed from the system to prevent the build-up of solids and minerals to concentrations high enough to cause corrosion and scaling of various cooling system components. This removal of water is called blowdown. The higher the cycles of concentration (COC), the lower the blowdown rate (refer to the following discussion of COC). Blowdown discharged to a receiving waterbody that is a water of the U.S. is permitted by a facilitys NPDES permit. 10.3.2.6 Cycles of Concentration As water is evaporated from the tower, TDS remains in the recirculated water, and the concentration of TDS continues to increase as the process continues (DOE, 2016). Cooling towers are designed to operate within a particular COC, which is defined by the EPA as the ratio of dissolved solids in the recirculated water versus that in the makeup water (EPA, 2014). 10.3.2.7 Makeup Water Circulating water that is lost from the system due to evaporation, drift, and blowdown is replaced with makeup water. Makeup water is typically withdrawn from the source waterbody through the CWIS. 10.3.2.8 Cooling Tower Fill Fill is one of the most important parts of a cooling tower and is where much of the heat transfer occurs. It consists of an approximately 7-ft high grid within each cell that allows water to cascade down through it and air to rise through it, increasing the air-water interaction time. Fill may be manufactured using several different materials (such as wood, PVC, fiberglass, and stainless steel) and different configurations (such as splash fill and film fill). Specific material and configuration would be determined by the application. Figure 10-9 shows an example of film fill. Additional information may be found in SPX (2009) and SPX (2016). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-37

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-9. Cooling Tower Fill Source: SPX, 2009. 10.3.2.9 Recirculation and Interference Recirculation occurs when the saturated air leaving the cooling tower is introduced back into the towers air inlets (SPX, 2009). Interference is similar to recirculation, with the exception that the saturated air leaving the cooling tower is introduced into a nearby cooling towers air inlet (SPX, 2009). When multiple cooling towers are utilized, a minimum distance 14 between the towers must be maintained to reduce interference 15. 10.3.3 Review of Candidate Approaches Based on an initial evaluation (described below) of standard and plume-abated MDCT, NDCT, and air-cooled condensers (ACC) described in the following sections, MDCT have been selected for more detailed evaluations in subsequent sections. NDCT and ACC have been found to be incompatible with the design and operations of the facility. These cooling towers would also 14 The minimum distance is typically a function of the length of the cooling tower, as well as the offset between multiple towers. When the site does not allow for the appropriate orientation of towers, the inefficiencies may be overcome by using more powerful fans or by using additional cooling tower cells. 15 Recirculation is minimized by limiting the size of any tower. For example, if a facility needs 48 cooling tower cells, the design can minimize recirculation by utilizing four 12-cell towers instead of a single 48-cell tower. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-38

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) result in higher facility costs that would very likely result in higher social costs compared to a standard MDCT. The following sections provide additional information on the various cooling tower types, including the applicability of each at St. Luce Nuclear Plant. 10.3.3.1 Mechanical Draft Cooling Towers Description MDCT are usually comprised of multiple rectangular cells, arranged in a rectilinear or round fashion. MDCT either induce or force air through the tower and can be susceptible to recirculation and interference from other towers (SPX, 2009). Water flows downward through fill material contacting air in either a counter-flow or cross-flow pattern. MDCT can be designed to be plume-abated; plume-abated towers are discussed in Section 10.3.3.3. Feasibility The feasibility of MDCT depends on design and siting, environmental, and overall facility impacts. The footprint of MDCT can be larger or smaller than other towers, but in most cases, the footprint will require a relatively flat, rectangular area. Both MDCT and NDCT counterflow designs have similar efficiencies. MDCT use fans to move air through the towers, so they do not rely on a density differential that NDCT rely on for cooling. However, MDCT can be significantly shorter (up to 10 times), and because their air flow is mechanically forced, they can be designed with a lower cooling tower range and approach temperature than NDCT. General environmental impacts include noise, increased particulate matter (PM) emissions, increased water consumption, local fogging and icing, and increased residual waste (sludge) generation. MDCT produce noise from the use of fans and related appurtenances in addition to the noise from cascading water. Because of the lower height of the towers, there is a higher potential for local fogging and icing due to the plume. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-39

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) MDCT typically tend to have the lowest capital costs of all cooling tower types, but the operating costs can be greater than NDCT. The smaller capital and larger operating costs of MDCT can make MDCT costlier than NDCT over the life of the facility, when both types of towers are feasible. However, the feasibility and costs need to be compared to the lifespan and operating mode of the individual facility (SPX, 2009). 10.3.3.2 Natural Draft Cooling Towers Description A NDCT is a wet cooling tower and typically has a large hyperboloid shape, which has been found to improve performance efficiency (EPRI, 2011). Similar to MDCT, water flows downward through fill material, contacting air in either a counter-flow or cross-flow pattern. NDCT are often used at facilities that require larger quantities of water to be cooled; they are typically used at near-baseload facilities. The advantage of a natural draft unit is that the power required for fans is eliminated. Although NDCT are typically very tall, the wet deck (or top of fill) is at approximately the same height as for MDCT; therefore, the energy requirements with respect to pumps is assumed to be similar (SPX, 2016). Because of the height of NDCT (up to 600 feet in height), ice and fogging impacts (if any) are not generally experienced within the immediate surroundings, but these impacts are dependent upon the meteorological conditions of the site (CTI, 2003). Feasibility The feasibility of NDCT depends on design and siting, environmental, and overall facility impacts. With respect to design and siting, compared to MDCT, the footprint area of NDCT can be larger or smaller, but in all cases, the footprint will require a relatively flat and extensive land area. The hyperboloid towers are the highest of all tower types and can be greater than 10 times the height of MDCT; therefore, they could pose potential adverse aesthetic impacts on the viewscape. The large height required by a NDCT needs to be compared to local zoning ordinances and the allowable maximum building height, if any. NDCT are similar to MDCT regarding efficiency, but a NDCT is suitable only when a high cooling tower range and approach temperature are consistent with the existing condenser and Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-40

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) cooling water system. NDCT do not have fans to force/move air through them; instead, the density differential induced by the temperature differential and saturated air causes air to move upward. When the cooling tower range is large (e.g., greater than 20°F), the density differential is relatively easily induced. When the cooling tower range is small, a taller cooling tower is needed to help induce an adequate density differential to cause air to move up through the tower. Additionally, the performance of a NDCT is dependent on the ambient wet bulb temperature. As discussed in Section 10.3.2.3, the cooling tower approach is the difference between cold water temperature and the ambient wet bulb temperature. The cooling tower performance improves and the cost decreases when the tower is designed with a large approach (i.e., warmer cold-water temperature). As the cold-water temperature comes closer to (or approaches) wet bulb temperature, the tower efficiency decreases; therefore, a larger tower is needed to compensate for the lost efficiency. As such, the tower size increases rapidly when the approach and/or the range is smaller than 15°F to 18°F. Therefore, NDCT are infeasible when both the approach and the range are smaller than 15°F (SPX, 2009). A NDCT design is more practical when the approach temperature is larger than 20°F, and the range is larger than 25°F (SPX, 2009). The NDCT cannot successfully move air through the tower if the required range is small. MDCT circumvent this issue by utilizing fans to force air through the towers. Environmental impacts are generally similar between MDCT and NDCT in terms of PM emissions, water consumption, and residual waste. While there is no fan noise related to NDCT, the noise of cascading water can be significant. Due to the height of the tower, there is a higher visible plume; however, local ground-level fogging and icing issues are reduced compared to MDCT. While operating costs for NDCT will be lower than MDCT, capital costs for NDCT can be significantly greater, with approximate costs ranging from one-and-a-half to two times the cost of MDCT (SPX, 2016). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-41

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.3.3.3 Plume-Abated Towers Description Plume-abated cooling towers can be grouped into two major groups: those that add heat to the plume above the wet deck of the cooling tower and those that do not add heat. Plume-abated cooling towers that add heat above the wet section of the cooling tower are called hybrid towers. The wet portion of a hybrid tower is similar to that of a MDCT or NDCT (assuming the system meets the necessary criteria for that type of tower) (SPX, 2009). A set of coils or finned-tubes are located above the wet portion to add heat/warmth to the near-saturated air leaving the tower to eliminate the visible plume. Addition of heat does not remove the water content, but only moves the air parcel away from the saturation curve as shown in Figure 10-10. Figure 10-10. Eliminating Visible Plume from a Hybrid Cooling Tower Source: CTI, 2010. Hybrid towers do not always need to be operated in plume-abated mode. The heat source may be applied to the dry portion of the tower during cooler months when the visible plume is more likely, and the tower may be operated in wet-only mode during other times of the year. This helps reduce the parasitic load on the facility. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-42

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Hot water from the condenser may often be used as the heat source. When operated in the hybrid mode, with hot water from condensers as the heat source for the dry portion, water enters the tower at the top of the dry portion, where sensible heat transfer lowers the temperature of the circulating water while raising the temperature of the air leaving the tower (thereby eliminating the visible plume). The slightly cooled circulating water then cascades down to the evaporative portion of the cooling tower, where water is further cooled through latent heat transfer (EPRI, 2011). No contact is made between the air and water in the dry portion of the tower, but there is contact between air and water in the lower, wet portion of the tower (EPRI, 2011). Saturated air leaving the top of cooling towers causes the plume. The dry section installed in the upper part of the cooling tower reduces the visible plume by heating wet air coming from the [lower] rain zone (SPX, 2016). Warm air has greater moisture assimilative capacity. Warming the air exiting the wet portion causes the air to become unsaturated, thereby reducing the visible plume. In the mechanical hybrid tower, the dry portion may be installed above or below the fan. When installed below the fan (like the configuration shown in Figure 10-11) the tower is called a parallel path wet/dry cooling tower. When the dry portion is installed above the fan, it is called series path wet/dry cooling tower. Parallel path wet/dry cooling towers are presently more prevalent than series path wet/dry cooling towers (CTI, 2010). Figure 10-11. Cross-section Schematic of a Parallel Path Wet/Dry Cooling Tower Source: CTI, 2010. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-43

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The second type of plume-abated tower developed by SPX is called ClearSky'. It blows additional cooler ambient air into the chamber above the wet portion to condense the moisture (Figure 10-12). The condensate may be collected for use in various facility equipment that requires high quality water. If the condensate is not collected, it would cascade down to the basin to be recirculated. This technology eliminates the visible plume by removing moisture from air leaving the tower. Operation of additional fans during cooler months poses a higher energy penalty than a standard MDCT. Figure 10-12. Cross-section Schematic of a ClearSky' Plume-abated Cooling Tower by Marley Source: SPX, 2016. Feasibility Plume-abated towers are available and are typically used in areas where the plume can have an adverse impact by way of fogging or icing, or in areas where long-range visibility is needed. Due to their design, hybrid towers have a base by approximately one to three times larger and a height of approximately one-and-one-half times that of standard MDCT. In addition, these towers are restricted to in-line arrangement (i.e., cooling tower arrays must be a single cell wide). Hybrid towers have a lower efficiency, lower summer output, and higher energy penalty Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-44

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) compared to standard MDCT. According to SPX (2016), this also is the case for its ClearSkyTM tower. Other than fan noise, most environmental impacts are less than or similar to those of MDCT. Plume-abated towers can be operated in plume-abated mode by actuating the air-cooled portion of the tower (in hybrid towers) or the additional fans (in ClearSky'), and when operated as such, there is usually a minimal or no visible plume. There is, however, greater fan noise with the use of plume-abated towers. Both capital and operating costs are greater compared to MDCT (EPRI, 2011). Plume-abated towers would have similar challenges as MDCT, such as limited suitable space and prohibitive site topography, potential major reconstruction of existing equipment and facilities, and space constraints associated with the property. Plume-abated towers will have a larger power loss due to a lower efficiency and greater energy penalty compared to MDCT. 10.3.3.4 Dry Cooling Description There are two key dry cooling methods: direct dry cooling through use of air-cooled condensers (ACCs), and indirect dry cooling. Dry cooling towers use only sensible heat transfer and can use ambient air directly or indirectly. Through the use of direct dry cooling systems, a dry-surface, finned-tube heat exchanger provides for the non-evaporative transfer of heat to the atmosphere (SPX, 2009). Steam from the turbine is sent directly to the ACC where the steam is condensed inside air-cooled finned tubes; there is no steam surface condenser and there is no contact between the ambient air and the steam and condensate. As shown in Figure 10-13, an ACC can be up to two to three-times the height of MDCT. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-45

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-13. Aerial Photograph of Air-cooled Condenser (Direct Dry Cooling) Source: Enexio, 2017a. Indirect dry cooling systems use a combination of a dry cooling tower (natural or mechanical draft) with a steam surface condenser. In these cooling towers, the heated water is pumped to heat exchangers arranged vertically around what looks like a standard wet cooling tower. But as shown in Figure 10-14, no water cascades down through the tower; instead, water flows through the bundles of tubes placed around the tower. Air flow through the tower cools the water within the bundles of tubes (SPX, 2017). There is no contact between air and the circulating water (EPRI, 2011). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-46

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Source: SPX, 2016. Source: Enexio, 2017b. Figure 10-14. Schematic of Indirect Dry Cooling Tower Feasibility ACCs require the largest area of land of all towers because they only utilize sensible heat transfer. 16 ACCs have the lowest cooling efficiency and lowest summer output of all towers, which results in the greatest energy penalty (EPRI, 2011). ACCs have a considerable energy requirement to operate its fans. Cooling of ACCs is limited by the dry-bulb temperature, rather than the wet-bulb temperature. Because the dry-bulb temperature is always higher than the wet-bulb temperature, the resulting cold-water temperature is higher compared to wet cooling tower water temperatures. Therefore, the energy penalty with dry cooling is significantly higher than that of wet cooling towers. 16 Wet cooling towers utilize both sensible and latent heat to transfer heat from water to air. The latent heat of vaporization for water is 970.3 British thermal units (Btu) per Pound mass (lbm) (Lindeburg 2003). The specific heat of water is 1 Btu/lbm-°F. That is, it takes 970.3 Btu to evaporate a pound of water, and it takes only 1 Btu to raise the temperature of water by 1°F. Wet cooling towers operate by evaporating a small quantity of water and cooling the remaining large quantity of water. The portion that evaporates absorbs energy from the remaining hot water, which then cools. Cooling through evaporation of water using latent heat transfer is more effective than using sensible heat transfer. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-47

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Because dry cooling systems use sensible heat transfer, there is no visible plume or related PM emissions, cascading water noise, water consumption, scale, sediment, or sludge accumulation. Dry cooling systems result in the greatest reduction in water use of all towers. However, they result in the highest fan noise and in the largest land footprint, including potential land use impacts. Capital and operating costs for dry cooling systems, especially ACCs, are the highest of all towers. Capital costs can be up to four to six times that of MDCT. ACCs are generally not compatible with existing condensers due to unacceptable turbine back pressure and hydraulic pressure on the condensers (EPRI, 2007). For this reason, installation of ACCs typically requires significant redesign and reconstruction of existing condensers, facility buildings, equipment, and piping. Due to the large energy penalty, ACCs may have impacts on the reliability of the facility and electric transmission distribution system. 10.3.3.5 Condenser Replacement The previous discussion of cooling tower types (NDCT, MDCT, plume-abated towers and dry cooling) was based on reusing the existing condensers. Such a hypothetical closed-cycle cooling tower retrofit would have to accommodate the existing condenser characteristics such as its pressure rating, backpressure impacts, water flow rate, and temperature rise. A plants condensers and cooling towers need to complement each other; that is, all heat added at the condenser needs to be removed by the cooling tower. Replacing the existing condensers with new condensers would eliminate those constraints, because the new condenser would be selected to meet the new hypothetical cooling tower performance criteria. However, a condenser replacement for both Unit 1 and Unit 2 would result in significant reconstruction at PSL, increased outages (resulting in lower grid reliability), higher cost, additional NRC permitting and approvals, and greater disturbance to site and surroundings, resulting in greater adverse impacts. Owing to the longer construction outage and greater adverse impacts that would result from condenser replacement to accommodate different types of cooling towers, this option is considered impractical and will not be evaluated further. Instead, this evaluation assumes that the Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-48

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) existing condenser would remain in place and that the cooling tower retrofit would conform to the constraints of the existing condenser. As indicated previously, if CCRS was found to be BTA, the need to modify or replace the existing condensers would be re-evaluated. 10.3.3.6 Selected Cooling Tower Type A standard MDCT is the most appropriate design for hypothetical implementation at PSL Based on the types of cooling towers discussed in this section, as well as PSLs condenser design, cooling water piping design, and other site considerations (discussed in Sections 10.4 through 10.4.10), NDCT and dry cooling have been deemed infeasible and impractical at PSL and eliminated from further evaluation. Because of its higher cost and site constraints, the larger plume-abated MDCT are considered to be infeasible and impractical compared to standard MDCT. As discussed in Section 10.4, the hypothetical CCRS retrofit considered for PSL has an approach of 10°F, and a range of 30.2°F for Unit 1 and 29.5°F for Unit 2 (FPL, 2017; SPX, 2020). Per SPX (2018), a NDCT cannot be designed for this small an approach temperature. The approach temperature must be greater for a NDCT as discussed in Section 10.3.3.2. The hot water from the condensers is not warm enough to facilitate a natural draft through the tower. Due to the larger circulating water flow and smaller approach of PSL, NDCT are technically infeasible. Due to the large site requirements, incompatibility with the existing steam turbines, significant facility redesign, and reduction in facility and regional electricity reliability, ACCs are considered infeasible from an engineering perspective. Much of PSLs site is occupied with existing equipment, and a large portion of the remaining open areas are wetlands. Practical space for a hypothetical cooling tower is limited. Because plume-abated cooling towers are larger than standard MDCT, a plume-abated tower would likely need to be split into two smaller towers, which creates additional difficulties and uncertainties in siting multiple towers on a site with minimal available space. Therefore, a plume-abated MDCT is not considered feasible or practical, due to the existing site constraints. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-49

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-5. Comparison Matrix of Cooling Tower Types Cooling Tower Types Standard Mechanical Draft Plume-Abated Mechanical Attribute Natural Draft Cooling Tower Dry Air-Cooled Condensers Cooling Tower Draft Cooling Tower Base Case Compare to Base Case Compare to Base Case Compare to Base Case Design and Siting Impacts Larger than base case, and Larger or smaller footprint than Largest area required, cannot be configured as back-Footprint Area Base case base case approximately 2 to 4 times the to-back therefore challenging Large, circular areas required area required for the base case to locate at this site Highest of all towers Owing to small range and Taller than base case, approach temperatures, greater Approximately 2 times the Height Base case approximately 70 feet than 600 feet, which is beyond height of a MDCT. the typical cooling tower design height. The existing steam turbines are designed to exhaust into a This type of tower is infeasible vacuum less than 25 inches at PSL, therefore its efficiency Efficiency (the mercury, which dry air-cooled cannot be evaluated ability to cool, Lower than MDCT systems cannot achieve, making Base case Suitable/applicable only when compared to system Lower summer output this technology infeasible. both cooling tower range and energy consumption) Lowest cooling system approach temperature are efficiency. relatively large Lowest summer electricity output. This alternative has the highest energy penalty. Large energy requirement for fans. Cooling is limited by dry-bulb Higher than base case temperature rather than wet-Additional pumping, fans, and Additional pumping, fans, and Lower than base case with bulb temperature; dry-bulb Energy Penalty related appurtenances increase related appurtenances increase respect to fan requirements. temperature always higher than energy penalty energy penalty wet-bulb temperature. Therefore, these systems have the highest resulting cold-water temperature, with largest energy penalty in the height of the summer. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-50

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-5. Comparison Matrix of Cooling Tower Types (Continued, 2 of 3) Cooling Tower Types Standard Mechanical Draft Plume-Abated Mechanical Attribute Natural Draft Cooling Tower Dry Air-Cooled Condensers Cooling Tower Draft Cooling Tower Base Case Compare to Base Case Compare to Base Case Compare to Base Case Environmental Impacts Visible plume at higher Minimal to no visible plume Potential for plume elevation No visible plume Visible Plume Lower probability for ground-Potential ground level fogging Reduced ground-level fogging No fogging level fogging due to height of plume emission Dependent upon source water PM Emissions TDS, cycles of concentration, and Similar to base case Similar to base case No PM emissions drift eliminator efficiency Additional fan noise Potentially higher than base No fan noise Greatest fan noise Noise Emissions Cascading water noise case but not permittable Cascading water noise No water noise No water consumption Slightly less consumptive water Water Consumption Base case Similar to base case Greatest reduction in water use use than base case of alternatives Dependent upon water and air No scale, sediment, or sludge Residual Waste quality, basin sizing, and use of Similar to base case Similar to base case accumulation chemical additives Overall Plant Impacts Higher than base case but not Highest capital costs, Capital Costs Base case Likely higher than base case permittable approximately 4 to 6 times Higher than base case but not Operating Costs Base case Lower than base case Highest operating costs permittable Infeasible due to small Major reconstruction of existing approach temperatures Infeasible undeveloped area Large towers may have an Incompatible with existing Major reconstruction of Site-Specific Plume may impact traffic on State adverse visual impact on area condensers existing undeveloped area Applicability Road A1A, as well as visibility Plume may impact traffic on Insufficient suitable space Minimal plume impacts and security of the protected area State Road A1A, as well as Impact plant and regional of the Plant. visibility and security of the reliability protected area of the Plant. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-51

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-5. Comparison Matrix of Cooling Tower Types (Continued, 3 of 3) Cooling Tower Types Standard Mechanical Draft Plume-Abated Mechanical Attribute Natural Draft Cooling Tower Dry Air-Cooled Condensers Cooling Tower Draft Cooling Tower Base Case Compare to Base Case Compare to Base Case Compare to Base Case Several construction and Infeasible due to existing operations period challenges. condenser characteristics. Likely impractical and potentially Given large site requirements Not feasible or practical owing Infeasible due to low approach Overall Feasibility infeasible from an engineering and expected high resultant to its need for more space. temperatures perspective. Retained for further cold water temperatures, this evaluation because this is the least alternative is infeasible from an infeasible of cooling tower types. engineering perspective Sources: EPRI, 2002 and 2011. CTI, 2003. Maulbetsch and Stallings 2012. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-52

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The following matrix in Table 10-5 provides a summary comparison of the various cooling tower types. The next section will evaluate MDCT in greater detail and estimate the cost of retrofitting PSL with a CCRS. 10.4 Description of the Hypothetical Closed-cycle Cooling Tower40 CFR 122.21(r)(10)(i)(A) Based on the evaluation performed in Section 10.3, a standard MDCT has been selected for further evaluation and cost estimation. 10.4.1 General Concept The general concept at PSL is to install two 32-cell back-to-back MDCT (one per unit) east of the Station, in an area presently covered by mangroves and between the main plant and the ocean. The intent is to have minimal construction-related impacts on PSL operations, therefore most of the construction work would be confined to the mangrove area. A new pipe would route hot water from the discharge canal to the two cooling towers. A booster pumphouse located at each MDCT would pump hot water to the top of the MDCT wet deck. Cold water from the two MDCT would be returned to the cold-water canal via another new cold-water pipeline (Figure 10-17). Three large diameter pipes presently convey water from the velocity caps to the upstream end of the intake canal. The terminus of these three pipes would be retrofitted with valves. One valve would be opened to allow makeup water to enter the intake canal. The other two would normally be closed. The three pipes would be cycled on and off to keep them in good operating order. On occasions when the MDCT would be unable to provide sufficient cooling, PSL would operate in once-through mode, and all three pipes would be opened, allowing water to enter the once-through system. A new divider wall would be built across the intake canal upstream of the existing first barrier net. The divider would include gates that would usually be closed, but could be opened if PSL were to revert to once-through mode. A new makeup water pumphouse would be constructed within the new enclosed section of the intake canal. The makeup water pumps would withdraw Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-53

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) water from the enclosed section and pump to the open section of the intake canal where the makeup water would comingle with the cooling tower return water. New dilution water pumps would also be located within the enclosed section of the intake canal. Dilution water pumps will withdraw water from the enclosed section of the intake canal and pump directly to the enclosed section of the discharge canal (see the following). These makeup water pumps and dilution water pumps would control the water withdrawal rate from the Atlantic Ocean. A new divider wall would also be built across the discharge canal. As with the cold-water side, the divider would include gates that would usually be closed, but opened were PSL revert to once-through mode. New blowdown pumps installed near the divider would pump hot water from the open side of the discharge canal to the enclosed section of the discharge canal. Dilution water would be pumped directly from the enclosed section of the intake canal to the enclosed section of the discharge canal. Blowdown and dilution water would flow out through the existing concrete pipes back to the Atlantic Ocean, albeit at a much slower rate. Due to the construction that would be necessary downstream of the existing traveling screens, there is no practical way to convert the Plant to closed-cycle mode while maintaining service water in once-through mode. Therefore, for the purposes of this evaluation, it is assumed that both circulating and service water would be withdrawn from the intake canal, which would receive cooled water from the MDCT; makeup, service and circulating water would all be returned to the existing discharge canal. This concept assumes that the service water system would not undergo any direct modification, and thereby its water supply would be converted to closed cycle. The following sections describe specific components and sizing, which are used to develop the cost and schedule for this retrofit. 10.4.2 MDCT Design Assumptions Several design conditions have been assumed with the selection of a hypothetical new standard MDCT; these assumptions are described in the following sections. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-54

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.4.2.1 Circulating Water Flow This evaluation uses the cooling water and service water flow rates described in Section 10.2.2 for the below calculations. Water evaporation rate in the cooling tower necessary to dissipate the required design heat load has been estimated and is listed in Table 10-6. The evaporation rate is estimated to be approximately 24,642 gpm total for both units (approximately 12,388 gpm for Unit 1 and 12,254 gpm for Unit 2). These values assume a cooling tower range of 30.2°F for Unit 1s hypothetical MDCT, a range of 29.5°F for Unit 2s hypothetical MDCT, and cooling tower flow rates equal to the existing water withdrawal rate for each unit (513,000 gpm and 519,600 gpm for Units 1 and 2, respectively). Table 10-6. Estimated Cooling Tower Water Use at PSL Water Use Unit 1 Unit 2 Once-through water withdrawal rate (gpm) 513,000 519,600 Condenser circulating water flow rate (gpm) 484,000 490,600 Evaporation rate (gpm) 12,388 12,254 Drift rate (gpm) 2.6 2.6 Blowdown rate (gpm) 41,291 40,846 Makeup rate (gpm)* 53,681 53,103 Dilution water rate (gpm) 82,582 81,691 Reduction in circulating water flow rate (%) 73.4% 74.1%

• Assumes there are no other leaks in the system. Makeup rate equals the sum of evaporation, drift, and blowdown.

Source: ASA, 2021. The blowdown rate is a function of source water quality and NPDES permit discharge water quality requirements and is estimated to be 82,136 gpm total (41,291 gpm for Unit 1 and 40,846 gpm for Unit 2). The Atlantic Ocean TDS levels are estimated to range between 34,500 and 37,000 parts per million (ppm) (FPL, 2010). This evaluation assumes 1.3 COC 17 to meet the Florida Department of Environmental Protection (FDEP) marine water quality standard for chlorides (FAC 2016), and assumes the blowdown would be diluted with additional Atlantic 17 The design and actual COC may vary during operation due to changes in water quality. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-55

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Ocean water (164,273 gpm total, 82,582 gpm for Unit 1 and 81,691 gpm for Unit 2) so the chloride concentration in the discharge would be no more than 110 percent of that of the receiving water. This evaluation assumes that the MDCT would employ the most efficient drift eliminators presently on the market with a 0.0005 percent efficiency. Drift from the Unit 1 and Unit 2 towers would be approximately 2.6 gpm and 2.6 gpm, respectively (5.2 gpm total). These values are discussed in more detail in the Section 12 report. Engineering estimates of evaporation, drift, blowdown, makeup, and flow reductions are provided in the Section 12 appendices. 10.4.2.2 Temperatures The cold-water temperature exiting the cooling tower is assumed to be approximately 90°F, which accounts for an ambient wet bulb temperature of 80°F and a minimum approach temperature of 10°F (WMO, 2020). 18 The cooling tower range, which is equivalent to the T across the condensers, is approximately 30.2°F for Unit 1 and 29.5°F for Unit 2 (FPL, 2017). Therefore, hot water entering the towers at around 120°F would be cooled to approximately 90°F. When only one unit is in operation, the corresponding MDCT would be used to achieve appropriate cooling. 10.4.2.3 Cooling Efficiency The potential for plume recirculation and interference can exist when towers are not aligned with the prevailing wind direction and when towers are located downwind from other towers. Depending on the amount of potential recirculation or interference, it is possible to increase the number of required cells or the power to the fans. The hypothetical CCRS retrofit assumed for PSL consists of two cooling towers. To achieve the highest cooling efficiency, cooling towers are typically oriented parallel to the predominant summer wind direction. The hypothetical cooling towers would both be located between the 18 This is the practical minimum approach temperature. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-56

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) intake and discharge canals and oriented in an east-southeast (ESE) and west-northwest (WNW) direction (WMO, 2020) (Figure 10-17). 10.4.2.4 Water Treatment Additives Maintaining and operating a cooling system with a cooling tower at optimum efficiency often requires the use of chemical additives to treat circulating water and service water. These additives are typically used to prevent and control corrosion, scaling, and fouling. In some instances, additives are dosed at such a concentration so that the chemicals are neutralized (i.e., used up) in the water prior to discharge. For example, acids or bases may be used to control the pH in the discharge water to meet state regulations; these chemicals will not typically be discharged into a receiving waterbody, as they will be consumed in the water through chemical reactions. In other instances, the additives will not be fully neutralized, and the remaining concentration may need to be discharged into the receiving waterbody. The blowdown quality needs to meet effluent limits that would be imposed through PSLs NPDES permit. Further evaluation of MDCT with respect to use of current and potential future water treatment additives would need to be completed prior to any cooling tower retrofit at the Plant. The evaluation would need to confirm the compatibility of any chemicals used with the cooling tower, including the fill material. The fill material of the cooling tower can be susceptible to chemical damage, including clogging and degradation of materials. In addition, chemical additives in the water could potentially be emitted from the tower, both in the exhaust emissions and drift water droplets. Whenever the circulating water is chlorinated, the blowdown stream would likely need to be dechlorinated. Use of a dispersant is assumed to be necessary to remove microbiological slime and disperse unwanted deposits. A scale and corrosion inhibitor is assumed to be required to protect the cooling water system from scale build-up and metallic corrosion. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-57

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.4.3 Cooling Tower Sizing Based on the design inputs described in Section 10.4.1, two hypothetical standard MDCT have been preliminarily sized for the cooling system at PSL. Each MDCT would consist of 32 cells. The cells would be organized in a back-to-back arrangement; each cell is assumed to be approximately 53 feet in length, 50 feet in width, and 53 feet in height. Information in Table 10-7 has been used to size the hypothetical new cooling towers for Units 1 and 2. Table 10-7. Hypothetical Cooling Tower Sizing Information for Unit 1 and Unit 2 at PSL Description Unit 1 Unit 2 Tower type MDCT MDCT Number of cells (total) 32 32 Number of towers 1 1 Cells per tower 32 32 CT type/arrangement Back-to-Back Back-to-Back Approximate cell size (l x w x h) (ft) 53 x 50 x 53 53 x 50 x 53 CT basin size (l x w xx d) (ft) 808 x 114 x 6 808 x 114 x 6 Motor output power for fans (bhp) 250 250 Total fan motor output power (hp) 8,000 8,000 Water flow rate (gpm) 513,000 519,600 Design approach temperature (°F) 10 10 Design conditions for summer duty Condenser temperature differential (°F) 30.2 29.5 Design wet bulb temperature (°F) 80 80 Design wet bulb temperature percentile (%)* 99 99 Prevailing wind direction ESE ESE

• Would be exceeded 1 percent of the time.

Sources: FPL, 2017. SPX, 2020 The cooling towers would be positioned directly above a collection basin, often referred to as the basin, which would accumulate the cascading water and direct it to the existing intake canal, which is assumed in the CCRS scenario to be partitioned to allow makeup water into a small portion of the intake canal, and for the remaining section of the canal to convey cold water to the Plant intake structure (refer to Section 10.4.6). Each basin is assumed to extend an additional 4 feet from each side of the tower, resulting in a potential length of 808 feet and width of 114 feet and depth of approximately 6 feet. The total fan motor output power requirement for each Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-58

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) cooling tower would be approximately 8,000 horsepower 19 (hp), assuming one fan for each cell, with a motor power requirement of 250 brake horsepower (bhp) for each fan. The flow rate through the hypothetical MDCT is assumed to be equivalent to the design condenser flows for Unit 1 and Unit 2, approximately 513,000 gpm (738.7 MGD) and 519,600 gpm (748.2 MGD), respectively. The hypothetical cooling towers would require the use of additional lift pumps (discussed in subsection 10.4.4). Under the design web-bulb temperature, the prevailing wind direction is from the ESE, so the preferred cooling tower orientation would be in a parallel orientation (WMO, 2020). Further siting and location of the cooling tower is discussed in Section 10.4.4. 10.4.4 Hypothetical Cooling Tower Location40 CFR 122.21(r)(10)(i)(B) The following aspects were considered when identifying potential locations for siting the hypothetical cooling tower; one potential location was then selected for use in the remainder of the feasibility evaluation:

• Cooling tower construction or operation should not interfere with the Plants operation or safety. Structures or plume should not impact the view of the Protected Area perimeter.

Whenever possible, cooling towers should be located away from switchyards and transmission lines.

• Each location must have existing space available for construction - the footprint of the cooling tower basins, booster pumphouses 20 and sumps/wet wells, construction access, excavation spaces, and spaces to setup equipment were considered in this category.

Additionally, the topography of the site should be amenable to construction or re-grading.

• Each location must minimize impacts to nuclear safety-related buildings and equipment at the Plant.
• To minimize construction within the Protected Area to the extent practical, the evaluation attempted to keep large construction activities outside the Protected Area.

19 1 hp is equivalent to 745.7 watts; therefore, 8,000 hp is approximately 6 MW. 20 The booster pumphouse would be located at the end of the hot water pipes, at the base of the MDCT. Booster pumps would route hot water from the booster pumphouse wet well to the top of the MDCT. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-59

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13)

• Each location needs to be downwind or sufficiently separated from switchyards and transmission corridors to prevent electrical arcing and icing during severe winters.
• The sites ability to protect key equipment from storm damage and flooding.
• Each location must have open space available for cooling tower operation - good air circulation is needed for cooling towers to operate efficiently.
• Each location must minimize, to the extent practicable, retrofit-related Plant outages. Plant outages are costly and can affect the reliability of the electric grid.
• Each location must minimize, to the extent practicable, O&M costs - the evaluation attempted to locate the cooling tower and other related new equipment to minimize fuel, labor, and other maintenance costs.
• Each location must be close to the existing condensers or to existing hot- and cold-water piping or canal. The need to construct long new water conveyances and route water significantly longer distances increase the cost of construction, and increases head loss through the system that would need to be compensated with larger pumps. Therefore, the distance between intake and discharge canals (or condensers) and MDCT was minimized to the extent practicable during the assessment.
• Each location must be close to the existing intake and discharge canals to use those existing structures to the extent possible and minimize disturbance to the Plant by using existing pipeline alignments.
• Each location must have pipe or channel routes available between the condensers and the MDCT - power plants have a myriad of above-ground and underground infrastructure. Pipe routes that avoid crossing transmission corridors and other densely utilized areas of the site are preferable. MDCT locations that allow for practical hot and cold-water channel routes are also preferred. The evaluation also attempted to avoid cooling water pipe crossings.
• Each location must facilitate minimal construction-related disturbance to the extent practicable - restoring a construction site is costly. This evaluation attempts to locate and sequence work to minimize areas disturbed.
• Areas of particular ecological value or concern were to be avoided, if possible.
• Each location must have existing space available for equipment laydown - it is convenient and cost-effective for contractors to have laydown space readily available near construction activities. When there is insufficient space, equipment must be hauled to the construction site as needed.

Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-60

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) This evaluation identifies spaces that meet, to the extent possible, most of the above requirements. 10.4.5 Existing Site Conditions Figure 10-15 shows the topography and flooding potential of the area around PSL. The property is relatively flat, elevations generally vary between 5 feet and 10 feet throughout much of the property. Bedrock at PSL is deep (FPL, 1991). During the original PSL construction the surficial deposits of the site had been excavated to 60 feet below ground surface and backfilled with Class I fill (PSL, 2016). The cost of excavating to a significant depth and then backfilling with high integrity clean fill had been less costly than supporting each structure on piles in that project (FPL, 1991). Considering the linear nature of the infrastructure that would need to be constructed for the hypothetical MDCT project, replacing all the subsurface material with high integrity clean fill would not be cost effective; therefore, this evaluation assumed that concrete-filled steel piles driven 60 ft would support the hypothetical MDCT, booster pumphouses, makeup water pumphouse, blowdown pumphouse, and the new hot- and cold-water pipes. Additional geotechnical investigations and borings would need to be completed to evaluate the specific depth to bedrock and the most efficient geotechnical approaches in the event PSL were required to construct MDCT. 10.4.6 Orientation of the Cooling Tower Wind speed and direction significantly influence cooling tower performance, as well as the potential effects of facility emissions. While moderate wind speeds are critical for transporting the saturated plume away from the tower and increasing cooling tower performance, excessive wind speeds can diminish cooling tower performance by restricting the plume from rising out of the tower. A cooling tower array performs best when its primary (long) axis is oriented in the predominant wind direction because this orientation minimizes the potential for saturated air recirculation. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-61

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-15. Topography Near PSL Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-62

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) When space and other physical conditions allow, a MDCT should be oriented with the dominant wind direction that coincides with design wet bulb temperature. Meteorological data from the World Meteorological Organization (WMO Plant Number 722045) for Vero Beach, FL was used for this evaluation (WMO, 2020). Wind roses 21, which depict prevailing wind direction and percent frequency of observed wind speeds, for Vero Beach, FL, for the different months of the year, are shown on Figure 10-16. The winter (December, January, and February) wind rose shows that most of the prevailing winds are from the west-northwest to north directions; wind from these directions occurs approximately 33 percent of the time (Figure 10-16). The spring (March, April, and May) and summer (June, July, and August) wind roses show that most of the prevailing winds are from the east to southeast directions and occurs approximately 30-31 percent of the time (Figure 10-16). The autumn (September, October, and November) wind rose shows that most of the prevailing winds are from the east-northeast to east-southeast directions, occurring approximately 31 percent of the time (Figure 10-16). During all four periods, wind speeds are commonly between 6 and 14 knots 22 (approximately 7 and 16 miles per hour [mph]); however, wind speeds greater than 34 knots (39 mph) have been experienced. The predominant wind during the design wet bulb temperature condition is from the east-southeast directions (WMO, 2019); therefore, the preferred orientation for the hypothetical MDCT would be east-southeast to west-northwest. 21 A wind rose is a graphical representation of how prevailing wind direction and percent frequency of wind speed are distributed at a specific location, for a given period of record of data. The wind rose is plotted in a circular format. Straight lines directing towards the center represent the prevailing wind direction; the concentric circles (or dashes on the straight lines) represent the percent frequencies of wind speed, which increase in percent frequency from the center of the wind rose (NRCS 2016). The percent of time the wind speed is observed as calm is typically provided as a note to the wind rose. Wind speeds may be provided in units of either miles per hour (mph) or in knots. 22 A knot is a velocity measured in nautical miles per hour, where one nautical mile is equivalent to 1,852 m, or approximately 6,076 feet. To convert from knots to mph, the value in knots should be multiplied by 6,076 feet per hour per knot and then divided by 5,280 feet per mile. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-63

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) December, January, and February March, April, and May Percent Calm = 15.14 Percent Calm = 11.36 June, July, and August September, October, and November Percent Calm = 20.88 Percent Calm = 16.12 Labels of Percent Frequency on North Axis Figure 10-16. Wind Summary for Vero Beach, Florida Source: WMO, 2020. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-64

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.4.7 Hypothetical Cooling Tower Location A Several onsite locations were initially considered prior to selecting an appropriate area for siting the hypothetical cooling tower. Of the locations evaluated, Location A discussed below has been determined the least infeasible based on cooling tower footprints. However, site constraints and difficulties make actual cooling tower installations at any location, including at Location A, challenging. The calculations and discussions presented in this report, as well as in Section 12, reflect siting cooling towers at Location A. The area immediately north of the intake canal, south of the discharge canal, west of the Atlantic Ocean, and east of the Unit 1 and Unit 2 reactors has been selected as Location A and the most reasonable site (Figure 10-17). While space constraints at the Plant limit the potential locations for additional equipment, this location has been chosen because it may have the least impact on the existing operations of the Plant, is relatively flat topographically, and well-connected to the existing Plant intake and discharge canals. The concept for this location includes converting the existing once-through system to a CCRS by installing two cooling towers at Location A, separated by a distance of approximately one cooling tower length, oriented in an ESE to WNW direction, and separating the majority of the intake canal from surface waters (Figure 10-17). The existing intake canal and discharge canal would continue to service the PSL cooling water system. Small sections of the intake and discharge canals would be isolated using divider walls to create areas for makeup water and blowdown management. The intake and discharge canals are not jurisdictional waters of the U.S., therefore, modifying the canals would not require a dredge and fill permit. The existing velocity caps, existing cooling water conveyance pipes between the velocity caps and intake canal, the existing diffusers, and existing pipes between the discharge canal and diffusers would remain in place and would be used for makeup water, dilution water and blowdown systems. The hot condenser discharge water would be directed to the discharge canal as the plant is currently designed. A common hot water channel 30 ft wide, 18 ft deep and 1,500 ft long would route hot water from the existing discharge canal to the booster pumphouse wet wells. Ten booster pumps installed at each of the two booster pumphouses would pump hot water to the top of the wet deck of the MDCT. Water would then cascade down MDCT fill into each MDCT Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-65

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-17. Hypothetical Cooling Tower Location A for Units 1 and 2 at PSL Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-66

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) basin. Water would then get routed to a new common cold-water channel, also 30 ft wide, 18 ft deep and 1,500 ft long, that would route cold water back to the intake canal. Makeup water would be pumped directly to the intake canal. Once in the intake canal, the water would be routed to the existing circulating water pumps to be sent to the condensers and restart the cycle. Dilution and makeup water pumps would be co-located within a new intake structure located at the divider wall near the upstream end of the intake canal. Makeup and dilution water would be withdrawn from the enclosed section of the intake canal, which would be replenished with water from the velocity caps. Makeup water would be sent to the intake canal and dilution water would be routed to the enclosed section of the discharge canal, where it would combine with blowdown water from the hot water discharge canal. The dilution and blowdown would be conveyed via the existing discharge piping and diffusers to the Atlantic Ocean. In this hypothetical retrofit, the service water would also be converted to closed cycle. This allows for minimal changes to be made to the existing system, particularly in the protected area, and the option may allow for once-through operation (the existing conditions) with the use of the gates in the divider walls. However, due to the change in the service water source (recirculated water as opposed to once-through water), significant further evaluation and NRC review and approval may be needed if closed-cycle cooling were selected as BTA for PSL. This hypothetical retrofit also assumes that there would be no changes to the existing emergency water intake structure which withdraws water from Big Mud Creek (a cove on the Indian River Lagoon). There are challenges associated with cooling tower construction and installation at Location A, as discussed below:

• Location A is east of the plant and adjacent to Florida State Road A1A (SR A1A), which is a north-south Florida State Road that runs along the Atlantic Ocean. The prevailing wind direction under the design wet bulb temperature is from the east, which means that the hypothetical new cooling towers would be directing the tower plume, drift, and salt drift across SR A1A and over the plant and into the protected area. Plumes could inhibit the visibility of drivers along SR A1A, as well as the visibility of security within the Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-67

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) protected area of the plant. Additional evaluations of the impacts of the plume on plant security would need to be performed if closed-cycle cooling were selected as BTA for PSL. 23

• The retrofit concept assumes that the existing circulating water pumps would continue to route water to the condensers, and that the water would return to the discharge canal.

Therefore, the system would need new booster, makeup water, dilution, and blowdown pumps. The increase in the number of cooling water system components would increase the O&M costs at PSL.

• This concept assumes that a small section of the existing intake canal would be hydraulically separated from the rest of the intake canal using a divider wall and a series of gates. The new enclosed section of the intake canal would continue to be hydraulically connected to the Atlantic Ocean; all three cooling water conveyance pipes would have valves on the downstream end and only one pipe would be open at any time. This configuration would allow for the system to revert from closed-cycle to once-through mode in case of an emergency. But it also means that the O&M effort associated with the PSL cooling water system would increase significantly.
• To meet the FDEP (2016) marine water quality standard for chlorides, this retrofit concept assumes that dilution water would be pumped from the enclosed section of the intake canal to the enclosed section of the discharge canal using dilution water pumps installed alongside makeup water pumps. The dilution water pipe is shown with a dotted light blue line and arrows in Figure 10-17.
• To minimize outage time, the evaluation assumes that as much of the hypothetical new structures as possible would be constructed with PSL in operation (e.g., hypothetical new MDCT, booster pumphouses, hot and cold-water pipelines to and from the new towers, makeup water pipeline, dilution pipeline, and plant roads). Walling off a section of the intake canal and the discharge canal, valving the intake pipes, and tying in any other related equipment and appurtenances would occur during an outage. These activities would need to be coordinated so as not to cutoff service and emergency water to the intake and minimize plant downtime.

23 Plume-abated towers may resolve issues with respect to plumes and visibility across SR A1A and with plant security; however, plume-abated towers at PSL may require twice the amount of space and a complex arrangement of piping and considerable construction within mangrove and wetland areas surrounding the plant. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-68

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13)

• The hypothetical MDCT have been sited in an area presently classified as estuarine and marine wetlands by USFWS and inhabited by mangroves (Figure 10-18). The mangroves would need to be cleared and a new roadway built to provide construction access to this section. Such an activity would be subject to permitting by the US Army Corps of Engineers (for impacts fully or partially within Retained Waters) or by FDEP (for impacts entirely outside of Retained Waters) with input from other agencies. Mangroves have a variety of ecological functions and their displacement would be controversial and require extensive restoration and replication of the resource. Depending on whether impacts lie within state or federal permitting jurisdiction, the Section 404 permitting may be a federal activity subject to review under the National Environmental Policy Act (NEPA). Because of the linear nature of most of the construction, the evaluation assumes that MDCT, booster pumphouses and hot and cold-water channels would be supported on driven piles.

Other potential locations were considered to be less suitable for the construction of a cooling tower and are discussed in the following subsection. 10.4.8 Alternate Hypothetical Cooling Tower Locations The following alternate cooling tower locations (Table 10-8; Figure 10-19) were considered but were found to be less feasible than Location A, and therefore eliminated from further consideration for the reasons discussed. Areas that are located underneath transmission corridors have been deemed impractical as construction and operation of a cooling tower under or near transmission lines could pose a safety hazard. 10.4.9 Feasibility Discussion The feasibility of construction, operation, and retrofitting PSL with hypothetical MDCT is discussed below, assuming Location A as the location. 10.4.9.1 Retrofit Feasibility The condenser tubes for Unit 1 and Unit 2 are designed for a once-through cooling system which operates at a lower pressure than a closed-cycle system. If the existing cooling water system Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-69

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-18. National Wetlands Inventory for PSL and Surrounding Areas. Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-70

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-19. Alternate Hypothetical Cooling Tower Locations for Units 1 and 2 at PSL Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-71

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-8. Alternate Cooling Tower Locations Considered Location Current Use and Challenges with Siting a Cooling Tower Intake canal. This is a critical part of the cooling water system and cannot be B dismantled and repurposed. This area is infeasible for locating hypothetical cooling towers. Discharge canal. This is a critical part of the cooling water system and cannot be C dismantled and repurposed. This area is infeasible for locating hypothetical cooling towers. Unit 1 and Unit 2 Reactors, condensers, turbines, intake structures, all critical D components of PSL and unable to be repurposed. This area is infeasible for locating hypothetical cooling towers. Maintenance and service buildings; retention basins. There is insufficient E available space in the orientation required for the towers. Parking lots. There is insufficient space, and they are too close to the protected F area. G Helipad and parking lot. There is insufficient space at this location. Emergency water intake system, water treatment system, admin and maintenance H buildings, barge slip, parking lots. There is insufficient space at this location. Switchyard, transmission towers, and transmission lines. This area is infeasible I for locating hypothetical cooling towers. Security buildings, security training/range, recreation facility/area. No access to J the existing discharge canal. K Wetlands, undeveloped lands. No access to the existing discharge canal. Red mangrove swamp/wetlands, boat slip, undeveloped lands. No access to the L intake or discharge canal. Wetlands, nature trail, hammock areas, undeveloped lands. No access to the M intake canal. Walton Rocks Park, mangroves/wetlands, undeveloped lands. No access to the N discharge canal. Red mangrove swamp/wetlands, undeveloped lands. No access to intake or O discharge canal. Too far from the cooling water system. Beach and dunes. Insufficient space and located along coastline with attending P hazards and impacts. Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-72

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) were retrofitted with a single set of pumps that could route water from each cooling tower basin through the condensers, the hot water pipes, and up to the cooling towers, such pumps would need to develop significant head, which the existing condensers, or the existing cooling water pipes would not be able to withstand. A retrofit would require the condensers to be replaced and the cooling water pipes be reinforced or replaced. This would involve work on infrastructure that is in and under the generators and other key Plant infrastructure. If such a retrofit were feasible, it would essentially rebuild the Plant at significant cost, time, and effort. This evaluation, therefore, assumes that two sets of pumps would be used to circulate water through each units cooling water system. The existing circulating water pumps would be used to pump water along the existing intake canal, the Plant intake and through the existing condensers, out to the discharge canal and into the new hot water channel that leads to the booster pumphouse. The hypothetical cooling tower booster pumps would then pump hot water to the top of the MDCT. Water would cascade down into the cold-water basin, and be routed to the intake canal to restart the cycle. Two makeup pumps per unit would be used to convey makeup water from the enclosed section of the intake canal to the intake channel to replenish water lost to evaporation, drift, and blowdown. Two dilution water pumps per unit would withdraw water from the enclosed section of the intake canal and pump water to the enclosed section of the discharge canal to be combined with the blowdown and routed to the diffusers. The estimated number of pumps, pump rating, and total dynamic head (TDH) for the hypothetical system are provided in Table 10-9. The existing circulating pumps will continue to be used. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-73

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-9. Estimated Pump Requirements for Hypothetical CCRS Retrofit Estimated Pump Requirements Unit 1 Unit 2 Number 10 10 Cooling tower booster pumps Rating (gpm) 51,300 51,960 TDH (ft) 105 105.3 Number 2 2 Makeup water pumps Rating (gpm) 26,841 26,551 TDH (ft) 27.5 27.4 Number 2 2 Dilution water pumps Rating (gpm) 41,291 40,846 TDH (ft) 33.1 33 Number 2 2 Blowdown water pumps Rating (gpm) 20,645 20,423 TDH (ft) 15.9 15.8 Source: ASA, 2021. A hypothetical retrofit of the existing PSL cooling system with two MDCT would be impractical, but the site and surroundings are too complex to be able to determine if the closed-cycle retrofit is infeasible. Key areas that need further assessment are the use of the mangrove and wetlands areas, which would need regulatory consultation; the possibility of supporting new infrastructure on driven piles needs additional evaluations; and the impact of the plume on plant operations and safety within the protected area requires further study. 10.4.9.2 Construction Feasibility Constructing the aboveground or near ground level sections of cooling towers, walling off the intake and discharge canals, rerouting the existing hot water discharge to the towers, routing the cold water from the towers to the intake canal, installing blowdown pumps and dilution piping, and constructing a makeup/dilution water intake structure would likely be feasible, but challenging and impractical. However, the ability to support such infrastructure and build the foundations for these components need further evaluation. This evaluation assumed that the hypothetical new MDCT would be sited at Location A, east of the plant and between the existing intake and discharge canals, and that portions of the existing intake and discharge canals would be walled-off from the remainder of the cooling water system. The intake canal would be divided into two sections, one for water entering from the Atlantic Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-74

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Ocean for makeup and dilution water, and the second section would be part of the cold water conveyance system. These modifications would be possible, but extremely challenging. The existing site west of SR A1A has very little unused space; Location A has sufficient unused space and consists of mangrove. The evaluation assumed that this area would be developed by clearing the mangroves for the purposes of installing the hypothetical MDCT, booster pumps, hot and cold-water canals, dilution water piping, and any related appurtenances and plant roads. Whether clearing the mangroves would be ecologically permittable is unknown at this time. Whether the existing subsurface material can be built upon (with driven piles) or if all subsurface material at Location A would need to be removed and replaced with clean-fill (as in the original PSL construction) is presently unknown. The evaluation assumed that the existing intake and discharge canals would not need to be lined when the cooling system was converted from once-through to closed-cycle. If operations requirements necessitated lining of the canals, then the construction aspects of the hypothetical MDCT may become infeasible. Based on the construction challenges including filling and constructing on mangrove/wetlands, sectioning the existing intake and discharge canals, and other modifications at Location A, the construction of a cooling tower at Location A is deemed challenging and impractical, and potentially infeasible. 10.4.9.3 Operational Feasibility The hypothetical MDCT would be designed for the 99th percentile upper wet bulb temperature, which means that one percent of the time annually (approximately 88 hours on average), but concentrated during the warmest times of the year, the towers would not be able to cool the full circulating water load. Electricity demand is generally highest during such days based on air conditioning demand. PSL would not be able to generate at full capacity when the cooling tower is not fully available, incurring a cost penalty, and reducing the reliability of the grid when electricity is most needed. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-75

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Operation of the MDCT would create a plume. When the wind blows from the east, the plume would sit over the main plant areas and the protected areas. The potential safety and security impacts need further evaluation. The intensity of the plume and its associated hazard over State Road A1A also needs further evaluation. Operation of standard MDCT would involve the addition of pumps, fans, and related equipment, which would consume additional energy. These parasitic losses would reduce the amount of electricity the Plant could supply to the grid. Parasitic losses are presented in the Section 12 report. As indicated previously, additional noise would be generated due to operation of fans and the cascading of water inside the towers. Noise impacts are discussed in the Section 12 report. Residual waste generated through operation of the cooling towers, such as scale, sediment, and sludge, would increase, compared to that of the existing cooling water system. The increase in the amount of residual waste would be dependent upon the extent of chemicals used and the cycles of concentration. Residuals management would increase the Plants maintenance burden. The existing intake and discharge canal bottoms have articulated concrete tiles which do not provide an impermeable boundary between canal water and groundwater. The hypothetical cooling water system would need chemicals to prevent scaling, corrosion, etc. Additionally, substances present in groundwaters could enter the circulating water system and impact its metallurgy. If further evaluations find that an impermeable layer is needed between the circulating water and groundwater, then the intake and discharge canals would need to be lined with a geotextile or other liner, which would necessitate the canals to be drained for the duration of such work. The Plants emergency intake may need to be activated during that time to provide service water to PSL. The evaluation assumed that closed-cycle modifications would try to maintain once-through system components to be used in case of an emergency. Maintaining two cooling systems including periodic testing would also increase the maintenance burden at PSL. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-76

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The mangroves and wetlands at Location A help mitigate against floods. Once they are cleared the sites potential for flooding could increase. Given the operational considerations, retrofitting the existing once-through system to operate in closed-cycle mode is deemed operationally impractical and potentially infeasible. 10.4.9.4 Facility Operational Feasibility Due to Technology Retrofit Whenever the cooling towers cannot cool the full condenser load (i.e., for approximately 88 hours during the warmest and most humid periods in the summer), the Plant would not be able to generate at full capacity or supply full power to PSL during those periods. Additionally, the parasitic load on the system would be highest during the warmest periods, when the greatest number of fans would need to operate to facilitate cooling or to reduce the visible plume. These periods would also coincide with peak demand days for energy usage. Considering the operational aspects of the Plant itself, converting the existing once-through system to closed-cycle mode is deemed impractical. 10.4.9.5 Overall Feasibility of Cooling Towers40 CFR 122.21(r)(10)(i)(D) Several reasons make the construction and operation of cooling towers at PSL impractical and potentially infeasible. These include regulatory constraints on clearing and building in an area of mangroves, the unknown features of subsurface material at Location A, whether or not the intake and discharge canals would need to be lined, the potential impact of the plume on the protected area and State Road A1A, the high parasitic load, and the complexity of construction. Given these issues, the closed-cycle retrofit is deemed impractical and potentially infeasible. 10.4.10 Permitting Requirements Construction and operation of a cooling tower at PSL could trigger additional federal, state, and local permitting efforts, including:

• NRC Review and Coordination.
• FDEP Division of Industrial Wastewater.
• FDEP Air Permitting modification.
• FDEP Modification to Storm Water Pollution Prevention Plan.

Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-77

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13)

• NPDES General Permit for Construction Stormwater and Construction Dewatering Discharge to Surface Waters Permit.
• USACE or FDEP for dredging and filling of wetland resources.
• FDEP Site Coordination and Amendment to Site Certification (potential).
• Florida Fish and Wildlife Conservation Commission.
• Coordination with the National Marine Fisheries Service.
• Coordination with the U.S. Fish and Wildlife Service.
• Florida Public Service Commission.
• St. Lucie County approvals.

10.4.11 Hypothetical Schedule The hypothetical cooling tower retrofit project schedule is shown in Table 10-10. Depending on NRC review and coordination and permit approval timelines for other agencies, the schedule could be substantially longer than presented here. 10.4.12 Cooling Tower Costs40 CFR 122.21(r)(10)(iii) 10.4.12.1 Capital Costs Based on the existing conditions, the conceptual-level design presented, and assumptions stated, the AACE Class 4 24 estimate for retrofitting the once-through cooling systems for Units 1 and 2 with MDCT is presented in this section. The construction cost estimates utilize union wage rates for Fort Lauderdale, FL, budgetary equipment pricing obtained from major equipment suppliers, and construction standard pricing (using RS Means data). Capital costs are presented in 2020 U.S. dollars. Contingency, which includes cost components that were not explicitly costed in the engineers conceptual design, was included at 20 percent of all project costs. Owners costs (project management and planning by the owner, permit application reviews, project site supervision and bill payment by owner) was included as 10 percent of all project costs. 24 A Class 4 estimate is typically used for study and feasibility purposes only, with a project percent completion between 1 percent and 15 percent; the accuracy may be between -30 percent and +50 percent of the estimated cost (AACE 2016). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-78

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-10. Hypothetical Cooling Tower Implementation Schedule at PSL Task Completion Project Year Implementation Item Month May 2021 -0.5 Submit 316(b) application November 2021 0 Permit expiration November 2021 0 Permit issuance/final BTA determination May 2022 0.5 Engineering contract Engineering evaluations and construction May 2023 1.5 methods; regulatory/NRC coordination November 2023 2 30-percent design Site investigations - geotechnical borings, soil, May 2024 2.5 and topographic surveys; prepare and submit permit applications November 2024 3 60 percent design NRC approval; 95-percent design; receive long-May 2025 3.5 lead permit approvals; procure long-lead contracts Bid construction work; select contractor; general November 2025 4 conditions; receive long-lead permit approvals; apply for and receive local permits May 2026 4.5 Site clearing; construct access roads Construct hypothetical MDCT basins and wet November 2026 5 wells Construct hot- and cold-water channels; chemical May 2027 5.5 systems; electrical work Install cooling towers and pumps; intake canal modifications, discharge canal modifications, November 2027 6 makeup/dilution water pumphouse, dilution water pumphouse (Outage 8 weeks - likely September and October 2027) May 2028 6.5 Commissioning 2037 U2 CT fill replacement Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-79

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The Class 4 estimate for the capital costs for labor and materials for the implementation of MDCT at PSL would be approximately $910 million (Table 10-11), in 2020 dollars, and includes the following components:

• Mangrove clearing and replacing existing subsurface material with clean fill where necessary.
• Equipment costs, including MDCT structural components and fill, cooling tower booster pumps.
• Cooling tower basin construction.
• Installing new hot- and cold-water channels to route hot water from the discharge canal to the cooling towers and cold water from the cooling towers to the intake canal.
• Constructing walls with gates across the intake and discharge canals to isolate areas for the makeup and dilution systems, blowdown systems, constructing makeup, dilution water, and blowdown pumphouses.
• Earth moving and civil work, including site restoration.
• Piping and electrical work.
• Engineering and design of retrofit with the existing Plant and condensers.
• Permitting the MDCT, makeup and dilution water intake modifications.
• Non-water quality environmental and other impacts mitigation.

The evaluation has attempted to minimize disruptions to generation and sequence construction work to minimize outages. The evaluation expects that most construction, except for work within the intake and discharge canals, would occur with PSL in operation. 10.4.12.2 Operations & Maintenance Costs O&M costs for the MDCT are estimated at approximately $13.6 million per year (in 2020 dollars) and include labor; chemicals 25; solids removal; parts replacement for makeup, dilution, and booster pumps; and cooling tower fans. The electricity to operate pumps and fans would cost approximately another $28 million. Blowdown is also assumed to be dechlorinated whenever the circulating water is chlorinated. In addition, circulating water is assumed to be treated to reduce 25 This evaluation assumes that a dispersant and a corrosion/scale inhibitor would be added continuously at a low dose. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-80

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-11. Cooling Tower Capital Costs at PSL (2020 $ Millions) Cost Component 2020 $M Construction Direct Costs Demolition $1.93 Civil/Sitework $174.14 Mechanical $209.49 Structural $42.92 Electrical and I&C $23.62 Subtotal Construction Direct Costs $452.09 Construction Indirect Costs Contractor Site Supervision $11.45 General Conditions $43.37 General Administration & Profit $76.04 Subtotal Construction Indirect Costs $130.85 Total Construction Cost $582.94 Design Engineering and Construction Management $86.76 Permits and Approvals $1.90 Project Management (Engineering) $18.08 Owners Costs $68.97 Contingency $151.73 Total Capital Cost $910.38 Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-81

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) corrosion and scaling within the system. O&M Cost breakouts for 100 percent and average utilization rates are provided in Table 10-12. The average capacity utilization rates 26 (CUR) for Units 1 and 2 between January 2015 and December 2019 were 89.5 and 94.2 percent, respectively. Table 10-12. Cooling Tower Annual Operations & Maintenance Costs at PSL (2020 $ Millions) Annual O&M $M Annual O&M $M O&M Cost Component (100% CUR) (Average CUR) Chemicals for cooling water $0.52 $0.47 Solids removal* $0.05 $0.05 Parts replacement and maintenance $13 $13 Electricity for pumps and fans and loss due to

                                                                        $28                           $26§ backpressure energy penalty Total                                                                  $41.6                          $39.2

• Primarily cooling tower solids removal. This could be conducted every few years, but costs are presented as annual.

Assumed to be generated by FPL. Assume a total parasitic load (for pumps and fans) of approximately 181,929 and 183,694 MWhr for Units 1 and 2, respectively. §When St. Lucie Nuclear Power Plant is operating at full capacity, Units 1 and 2 can lose up to 13.1 and 13 MW of generating capacity, respectively, due to backpressure energy penalty alone, which would add up to approximately 114,973 MWhr/yr for Unit 1 and 114,197 MWhr/yr for Unit 2. Backpressure would be impacted during warmest months when the Plant would be operating near-continuously. Therefore, backpressure energy penalty would be approximately the same under both full and projected utilization rates. Source: ASA, 2021. 10.4.12.3 Environmental Mitigation Costs40 CFR 122.21(r)(12) The design already incorporates the following impact mitigation measures:

• Reduction of additional energy consumption by assuming implementation of the most energy-efficient equipment 26 Generator CUR can be calculated in a variety of ways, and may depend on how the information would be used.

The different calculation methods could result in slightly different CUR. In this section, CUR was based on data on the capacity of the two steam turbines available with high temporal resolution. These data are useful in other aspects of the engineering assessment. In Section 8, integrated data developed by FPL are reported for the average annual CUR for the two units. The average CUR reported in Sections 8 and 10 differ by a one or two percent based on their different origin. Such differences will not have a material effect on either the facility or social costs estimated for entrainment measures. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-82

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13)

• Operation of the cooling towers at low COC and dilution of the blowdown so the discharge would meet NPDES requirements and eliminate the need for New Source Review
• Minimization of disturbance to the plant to thereby reduce outage time No additional environmental mitigation efforts or costs are estimated, because additional measures are not expected to be technically feasible.

10.4.12.4 Facility-Level Compliance Cost (Annual and NPV) Considering the 8-year operating period for the Unit 1 MDCT, the evaluation assumed that the Unit 1 MDCT fill would not need to be replaced. With a 15-year operating period for the Unit 2 MDCT, the evaluation assumed that its fill would be replaced once in 2037. Per the schedule presented in Section 10.4.11, the MDCT for both units would be operational and commissioned in May 2028. Table 10-13 through Table 10-16 provide a series of cost layouts. Table 10-13 overlays the capital costs presented in Table 10-12 on the project schedule presented in Table 10-10; column 4 presents costs in 2020 dollars; column 5 escalates the costs in column 4 to the applicable year; and column 6 gives the present value of each task in 2020 dollars. Table 10-14 presents O&M costs excluding electricity costs assuming that the Plant would be operated continuously: costs in 2020 dollars (column 2); costs in a given year (column 3); and the present value of each years costs in 2020 dollars (column 4). Table 10-15 presents electricity costs for continuous operation (100 percent CUR) of fans and pumps. Table 10-16 present O&M costs, including electricity costs, assuming that the Plant would be operated at its historic average CUR from January 2015 through December 2019. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-83

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-13. Capital Cost Outlay for MDCT Installation at PSL (2020 $ Millions) Cost if Task Costs in Present Project Implemented Completion Implementation Item Given Year Value Year in 2020 Date ($M) (2020 $M) ($M) May 2021 -0.5 Submit 316(b) application November 0 Permit expiration 2021 November Permit issuance/final BTA 0 2021 determination May 2022 0.5 Engineering contract $1.43 $1.52 $1.31 Engineering evaluations and May 2023 1.5 construction methods; $30.30 $33.11 $26.62 regulatory/NRC coordination November 2 30-percent design $36.77 $40.18 $32.29 2023 Site investigations: geotechnical borings, soil, and topographic May 2024 2.5 $20.20 $22.74 $17.00 surveys; prepare and submit permit applications November 3 60-percent design $25.43 $28.62 $21.39 2024 NRC approval; 95-percent design; receive long-lead permit May 2025 3.5 $8.49 $9.84 $6.84 approvals; procure long-lead contracts Bid construction work; select contractor; general conditions; November 4 receive long-lead permit $29.97 $34.75 $24.15 2025 approvals; apply for and receive local permits Site clearing; construct access May 2026 4.5 $123.22 $147.14 $95.07 roads November Construct hypothetical MDCT 5 $247.37 $295.38 $190.86 2026 basins and wet wells Construct hot- and cold-water May 2027 5.5 channels; chemical systems; $243.12 $299.00 $179.64 electrical Install cooling towers and pumps; intake canal modifications, November discharge canal modifications, 6 $131.09 $161.22 $96.86 2027 makeup/dilution water pumphouse, dilution water pumphouse (outage 8 weeks) May 2028 6.5 Commissioning $12.98 $16.44 $9.19 2037 Unit 2 fill replacement $54.40 $89.91 $26.09 Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-84

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-14. MDCT O&M Costs at PSL (Excluding Electricity Costs and Assuming Full Utilization of the Plant) Unit 1 Unit 2 O&M Present O&M Present O&M O&M Year Costs in a Value of Costs in a Value of Costs Costs Given Year O&M Given Year O&M (2020 $M) (2020 $M) ($M) (2020 $M) ($M) (2020 $M) 2028 $3.97 $5.03 $2.81 $3.97 $5.03 $2.81 2029 $6.80 $8.88 $4.61 $6.81 $8.88 $4.61 2030 $6.80 $9.14 $4.42 $6.81 $9.15 $4.42 2031 $6.80 $9.42 $4.23 $6.81 $9.42 $4.23 2032 $6.80 $9.70 $4.05 $6.81 $9.70 $4.05 2033 $6.80 $9.99 $3.88 $6.81 $10.00 $3.88 2034 $6.80 $10.29 $3.71 $6.81 $10.30 $3.72 2035 $6.80 $10.60 $3.56 $6.81 $10.60 $3.56 2036 $1.70 $2.73 $0.85 $6.81 $10.92 $3.41 2037 $6.81 $11.25 $3.26 2038 $6.81 $11.59 $3.13 2039 $6.81 $11.94 $2.99 2040 $6.81 $12.29 $2.87 2041 $6.81 $12.66 $2.75 2042 $6.81 $13.04 $2.63 2043 $1.70 $3.36 $0.63 Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-85

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-15. Cost of Electricity for Operating MDCT and Assuming Full Utilization of the Plant Unit 1 Unit 2 O&M Present O&M Present O&M O&M Year Costs in a Value of Costs in a Value of Costs Costs Given Year O&M Given Year O&M (2020 $M) (2020 $M) ($M) (2020 $M) ($M) (2020 $M) 2028 $8.14 $10.31 $5.76 $8.17 $10.35 $5.78 2029 $13.95 $18.21 $9.46 $14.00 $18.27 $9.49 2030 $13.95 $18.75 $9.06 $14.00 $18.82 $9.09 2031 $13.95 $19.32 $8.67 $14.00 $19.38 $8.70 2032 $13.95 $19.90 $8.31 $14.00 $19.96 $8.33 2033 $13.95 $20.49 $7.96 $14.00 $20.56 $7.98 2034 $13.95 $21.11 $7.62 $14.00 $21.18 $7.64 2035 $13.95 $21.74 $7.30 $14.00 $21.81 $7.32 2036 $3.49 $5.60 $1.75 $14.00 $22.47 $7.01 2037 $14.00 $23.14 $6.71 2038 $14.00 $23.84 $6.43 2039 $14.00 $24.55 $6.16 2040 $14.00 $25.29 $5.90 2041 $14.00 $26.05 $5.65 2042 $14.00 $26.83 $5.41 2043 $3.50 $6.91 $1.30 Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-86

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-16. MDCT O&M Costs at PSL (Including Electricity) Assuming the Historic Utilization of PSL Unit 1 Unit 2 O&M Present O&M Present O&M O&M Year Costs in a Value of Costs in a Value of Costs Costs Given Year O&M Given Year O&M (2020 $M) (2020 $M) ($M) (2020 $M) ($M) (2020 $M) 2028 $11.24 $14.23 $7.95 $11.65 $14.76 $8.24 2029 $19.26 $25.13 $13.05 $19.97 $26.06 $13.54 2030 $19.26 $25.89 $12.50 $19.97 $26.84 $12.96 2031 $19.26 $26.66 $11.97 $19.97 $27.65 $12.41 2032 $19.26 $27.46 $11.47 $19.97 $28.48 $11.89 2033 $19.26 $28.29 $10.98 $19.97 $29.33 $11.39 2034 $19.26 $29.14 $10.52 $19.97 $30.21 $10.90 2035 $19.26 $30.01 $10.07 $19.97 $31.12 $10.44 2036 $4.82 $7.73 $2.41 $19.97 $32.05 $10.00 2037 $19.97 $33.01 $9.58 2038 $19.97 $34.00 $9.17 2039 $19.97 $35.02 $8.79 2040 $19.97 $36.07 $8.41 2041 $19.97 $37.16 $8.06 2042 $19.97 $38.27 $7.72 2043 $4.99 $9.85 $1.85 Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-87

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.4.13 Uncertainty Key uncertainties associated with this evaluation are listed below:

• The hypothetical CCRS retrofit assumes that there would be no associated potential security or nuclear safety-related implications. If there were security or nuclear safety-related implications that could not be addressed, the retrofit would be deemed infeasible.
• Location A selected for the hypothetical MDCT is assumed to be available for construction i.e., that the mangroves may be cleared and the subsurface material conducive for construction.
• The need to line the intake and discharge canals would greatly increase construction costs and extend the construction timeline.
• This evaluation did not assess the metallurgy of the existing cooling system and assumed that the minor changes in circulating water quality would be acceptable to the cooling water system equipment.
• Except for dechlorination, the blowdown would not need to be treated prior to discharge.

For the purposes of this evaluation, it is assumed that makeup water would not need to be treated prior to use, and this assumption is conservative.

• The evaluation anticipates that much of the existing Plant infrastructure, equipment, and piping would continue to be used in the closed-cycle system. If the condition of these items is unsuitable for continued use or if the items are found to be incompatible with the hypothetical CCRS retrofit, then those items would need to be replaced at higher cost and longer construction and outage durations, assuming replacement of the item(s) is feasible.
• The evaluation assumed that the existing circulating water pipes and velocity caps and the existing discharge pipes and diffuser may be used for the makeup, dilution water and blowdown systems. The evaluation assumed that those systems would work with significantly lower flow rates. Additional hydraulic modeling would need to be performed to verify this.

10.5 Fine-Mesh and Narrow-Slot Screen Retrofit 40 CFR 122.21(r)(10)(i) This section will discuss the potential approaches to retrofitting the PSL CWIS with fine mesh screens (FMS) to reduce rates of entrainment. While the Final Rule only requires a reduction in Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-88

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) entrainment and not entrainment mortality, the reduction in entrainment mortality is a major contributor to the overall benefit of an entrainment control technology estimated as part of the Benefits Valuation Study, per 40 CFR 122.21(r)(11). Therefore, what the rule calls conversion, or exclusion of entrainable organisms by FMS, should also consider the potential that the organism may not survive the exclusion event 27. This important goal complicates the consideration of FMS because it necessitates quantitative estimation of biological performance given a variety of site-specific factors (e.g., hydraulic behavior at the intake, the taxa and life stages of entrained organisms, the candidate approach to FMS, etc.). Per the Final Rule, FMS are those with openings of 2 mm or less. The rule does not make clear distinctions between two alternative FMS technologies: 1) narrow-slot wedgewire screens; and

2) use of FMS on Modified Traveling Water Screens (FM MTWS). For this reason, this section will consider both technologies as potential means to address entrainment BTA at PSL.

While the two technologies have important differences, both rely on the exclusion of otherwise entrainable organisms, typically eggs and larvae, in a fashion that attempts to ensure their continued survival within the source waterbody. As noted in the Final Rules Technical Development Document (TDD; EPA 2014), the nature of the interaction between the screen and the organism is very likely to affect both rates of exclusion and rates of post-exclusion survival. For example, at a high through-screen velocity (TSV), organisms may be held to the screen and either extruded through it or damaged by it prior to being washed off. 28 More importantly, application of FMS, without expanding the screen area, will reduce the open area available for water passage, increasing the TSV and raising the potential for unacceptable head loss across the screen and related adverse hydraulic effects within the CWIS and cooling system. FMS are also likely to be subject to increased rates of debris retention and biofouling, both of which would contribute to hydraulic, station reliability and safety concerns. 27 Throughout this section and in Section 11, FMS effectiveness will be considered relative to the exclusion, survival, and live return to the source water. FPL believes that there is a growing consensus that a substantial fraction of entrained organisms is likely to survive passage through the plant. Consideration of the potential incremental benefit of FMS relative to entrainment survival will be discussed in Section 11. 28 The duration of the organisms association with the screen has been found to be positively correlated with increased mortality (EPRI 2010). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-89

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) As will be discussed below, the two FMS technologies are subject to very different performance constraints including how they could comply with the IM BTA portions of the rule. Neither technology has been commonly applied at the intake flows needed at PSL, particularly at nuclear facilities or in marine environments. There are few CWIS that employ FM MTWS, and, therefore, the design parameters (e.g., target TSV) are not well established. These issues require careful consideration during the conceptual design of potential FMS retrofit to ensure that the system evaluated is reliable, biologically effective, and properly costed. The potential necessity to expand the CWIS to accommodate FMS is of great importance in estimating capital costs. For these reasons, the following sections will introduce the two technologies and will discuss approaches to their conceptual design. It is important to note that in the preamble to the Rule 29, EPA wrote: Converting traveling screens from coarse mesh to fine mesh often requires adding more screens in order to maintain the same flow, since the open area of a fine mesh screen is less than the open area of a coarse mesh screen. Adding more screens is one way to maintain that flow. [Footnote: A facility could also increase its intake velocity.] EPA estimates that as many as 17 percent of existing intakes could not be enlarged to accommodate a 2 mm mesh, and as many as 55 percent of existing intakes could not accommodate a 0.5 mm slot size under conditions of low-intake velocities. For these reasons, fine mesh screens are available for some locations, but they are not the best performing technology and are not an available technology for the industry as a whole for IM&E. As noted below, the TDD for the Final Rule (EPA, 2014) assumed, as the basis for cost estimation for the rulemaking that the CWIS would have to be expanded to allow for a TSV of less than 0.5 ft/s. EPA also indicated that a facility could increase its intake velocity to accommodate FMS but did not provide an alternative TSV to 0.5 ft/s 30. The relevance of this finding for PSL will be carefully considered in the following discussion of both narrow-slot wedgewire screens and FM MTWS. 29 Federal Register. Vol. 79, p. 48335. August 15, 2014. 30 The TDD also assumed that traveling water screens with TSV in excess of 3.0 ft/s would not be able to achieve the IM BTA standard with MTWS alone but would require either expansion to reduce the TSV or application of wedgewire screens (refer to Section 8.2.2.1 in EPA 2014). While FPL believes that this threshold is uncertain, EPAs concern represents another constraint on application of FMS to MTWS. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-90

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.5.1 Narrow-slot Wedgewire Screens 10.5.1.1 Description of Hypothetical Wedgewire Arrangement Narrow-slot wedgewire screens represent a potential approach to entrainment BTA at PSL under the Final Rule. This technology has a typical design intake velocity of 0.5 ft/s or less when used at power-plant intakes. This velocity is consistent with the velocity EPA used as the basis for cost estimation for the rulemaking as noted above. With a velocity of 0.5 ft/s or less, these screens would achieve impingement mortality BTA, under Impingement Mortality Compliance Alternative 2, per 40 CFR 125.94(c)(2). Cylindrical, narrow-slot, wedgewire screens have been successfully used at a very limited number of marine/estuarine facilities and those with intake flows that are a small fraction of the PSL CWIS. Narrow-slot cylindrical wedgewire screens have not been used at any nuclear facilities in the USA. As discussed below, environmental conditions at marine and estuarine facilities present a myriad of issues that need to be addressed to achieve a successful wedgewire screen installation and operation. A conceptual wedgewire screen arrangement was developed for PSL. This alternative uses screens with 2.0 mm slot openings, the largest opening classified by EPA as fine-mesh. Finer slot sizes are available but space requirements, biofouling, and debris loading concerns, as discussed later in this section, are more severe with smaller slots. Therefore, 2.0 mm slot openings are considered as a means of evaluating the overall feasibility of narrow-slot wedgewire screens, as well as comparing them to FM MTWS. The 2.0 mm slot screens will, however, exclude a lower proportion of organisms than either wedgewire or a traveling water screen equipped with smaller mesh openings. Thirty-six 84-inch diameter wedgewire tee-screens with 2.0-mm slot widths would be necessary to screen the PSL intake flow (1,032,600 gpm) with an intake velocity of less than 0.5 ft/s. The screens would be mounted to six, 10-foot diameter header pipes located seaward of the existing offshore intake, approximately 1,400 ft to 1,500 ft offshore. These pipes would connect to a large plenum constructed around the existing offshore intakes. The plenum would be constructed using earth filled double sheet pile walls with a concrete cap. These walls would Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-91

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) support a work deck and the required screen cleaning equipment. The top of the platform would be located above the maximum wave height and the screen cleaning equipment placed in weather-tight enclosures to reduce the probability of damage during large storm events. An approximately 1,265 ft long, 20-ft wide pier would be used to access the offshore plenum and screen cleaning equipment. Large bypass gates were included in the conceptual design to reduce the likelihood of a loss of cooling water if the wedgewire screens fail. Power to the screen cleaning system would be routed along this pier. A plan of the wedgewire layout is provided on Figure 10-20. The hypothetical wedgewire layout is intended for illustrative purposes only because, as described below, there are many uncertainties and barriers that need to be addressed when determining the feasibility of wedgewire screens at PSL. 10.5.1.2 Feasibility Discussion Use of wedgewire screens for cooling water withdrawals has some precedent in the United States but the installed systems are either relatively small (i.e., capacity of approximately 10 MGD), or their slot width is considerably larger than 2.0 mm, or both. FPL is aware of no precedent for a marine intake system with intake flows approaching PSLs that uses narrow-slot wedgewire screens. This lack of precedent indicates that there is a high degree of uncertainty regarding the performance and reliability of such systems. The major concerns that need to be considered when determining the feasibility of a narrow-slot wedgewire screen installation at PSL include; head loss, navigational hazards, presence of sweeping currents, debris accumulation, sedimentation, biofouling, organism attraction, and corrosion. These issues are discussed in the sections below. Head Losses Head losses associated with wedgewire screen installations are related to head losses through the screen openings, screen assembly, and piping. With a through-slot velocity of less than 0.5 ft/s, the head loss through the screen wires would be less than an inch with clean screens. The losses through the screen assembly would be less than 1 ft and the losses through the intake piping would be approximately 1 ft. Overall, a wedgewire screen assembly would reduce water levels in Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-92

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) the intake canal and the circulating water pumps by 2 ft or less (assuming a good hydraulic design, debris loading and fouling would not be a significant problem). Debris and biofouling of the screens and intake piping would further increase the head loss through the system. This may adversely affect pump performance resulting in pump cavitation, pump failure, and an overall reduction in station reliability and safety. A hydraulic model study would be needed to balance the flow distribution through the screens, and to identify any potential pump performance issues. If pump performance issues are identified, their impact on station operations would be evaluated and quantified. Costs for the pump performance study are included in the overall project cost estimates. This feasibility analysis assumes that if the screens can be maintained a clean condition, lower water levels at the circulating water pumps would not result in any lost generation or adversely impact nuclear safety. The ability to maintain the screens in a clean condition under the sediment and debris loading conditions as discussed below is questionable and may affect the overall feasibility of narrow-slot wedgewire screens. Navigation The conceptual wedgewire installation is presented in Figure 10-20. The PSL intake is located approximately 1,400 ft to 1,500 ft offshore. This area is approximately 9.5 miles south of the Fort Pierce inlet and 13.5 miles north of the St. Lucie inlet and outside of any commercial navigation lanes. A boater exclusion zone would be needed around the wedgewire screens to prevent interaction between the screens and recreational boating. Overall, the wedgewire screens are expected to have a minor impact on navigation near the site. Sweeping Currents A sweeping current is strongly recommended with wedgewire screens to effectively transport organisms and debris past the screens. Based on laboratory evaluations, velocities as low as 0.25 ft/s are capable of carrying debris removed from the screens a sufficient distance to avoid re-impingement following cleaning. Any non-motile organisms, including eggs and larvae, that encounter the screens will be drawn to the screens in the absence of a sufficient sweeping current to move them off and away from the screens. While not essential to reduce entrainment, a sweeping velocity is necessary to improve the impingement performance and post-exclusion Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-93

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-20. Hypothetical 2.0 mm Wedgewire Screen Layout at the PSL Intake Source: Alden, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-94

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) survival benefit of wedgewire screens, particularly with less motile organisms and life stages that cannot actively swim away from the screens. Sweeping currents are also needed to move debris past the screens. Without sufficient currents, debris will accumulate around the screens, eventually overwhelming the screen cleaning system, leading to increased head losses. This could lead to screen failure, pump cavitation and an overall reduction in station reliability. At marine facilities such as PSL, longshore currents are typically the driving force behind sweeping flows. At PSL the longshore currents are variable, but predominantly north to south. The magnitude of these currents was not investigated as part of this analysis. A more detailed hydrologic and hydraulic analysis of the ocean conditions at PSL would be necessary to better estimate the magnitude of sweeping currents past the screens prior to a BTA determination utilizing narrow-slot wedgewire screens being made. Debris PSL has a history of jellyfish intrusions reaching back to 1984. These intrusions have overwhelmed the traveling water screens, screen cleaning equipment and turtle nets, leading to numerous shutdowns and power reductions. Additionally, there have been increasing reports of jellyfish blooms around the world with impacts to cooling systems in many countries including the U.S., Israel, Scotland, and Japan (Schrope, 2012). Operational issues associated with jellyfish blooms would be exacerbated by the addition of narrow-slot wedgewire screens. The large mass of jellyfish within the water column during blooms would reduce the ability of an automatic cleaning system, including a continuous brush cleaning system, to remove jellyfish from around the screens, leading to plugging of the screen surface. Jellyfish tentacles and parts removed during the cleanings would be able to enter the slots between the screens and become entwined on the screen support bars and internal manifolds. Removal of the jellyfish from the internal screen components would be very labor intensive and could not be accomplished until after the bloom. Local ocean conditions would limit the work window when divers could access the screens, extending the period when the screens are bypassed after jellyfish events. When large amounts of jellyfish are expected, the narrow-slot wedgewire screens could be bypassed to reduce the impact of jellyfish on operations. The screens may still however become inundated Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-95

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) with jellyfish and jellyfish parts, requiring extensive cleanings. The inability to maintain the screens under all the debris loading conditions at the PSL make the use of narrow-slot wedgewire screens infeasible. Dredging and Sediment Sediment buildup in and around the screens is a common concern at wedgewire screen installations. Unchecked, sediment deposition can lead to screens becoming buried. As discussed earlier, longshore currents are expected to be the predominant current past the screens. Longshore currents are ocean currents that move parallel to shore and are responsible for the movement of sediment along the coast. A southbound sediment transport of approximately 175,000 m3/yr (222,351 yd3/yr) was estimated for the Ft. Pierce Inlet (van Gaalen, 2004) 31. Sediments are currently entrained in the intake flow leading to sediment deposition within the intake canal. This deposition requires periodic dredging of the intake canal. The large plenum and screen array would act as a current break, resulting in a sediment deposition zone on the south side of the screens. Removing sediment around the screens would require diver-operated suction dredging to avoid damaging the screens or intake pipes. This type of dredging is very labor-intensive and may require PSL to be shut down during dredging to prevent large amounts of sediment from entering the circulating water system. Worker safety issues would prevent dredging of the intake during storm events that may inundate the screens, resulting in forced outages. Biofouling Biofouling of the existing TWS has not been a major concern with the existing intake at PSL, but is likely to become an issue with wedgewire screens because they are permanently submerged with a constant flow directed toward the screens. Recent advances in screen cleaning technology and antifouling coating have the potential to limit the impact of biofouling on the screens but would not address biofouling on internal screen components or the intake pipes. These technologies and coatings are also untested in the estuarine environments similar to those at PSL. 31 van Gaalen, Joseph F., "Longshore Sediment Transport from Northern Maine To Tampa Bay, Florida: A Comparison Of Longshore Field Studies To Relative Potential Sediment Transport Rates Derived From Wave Information Study Hindcast Data" (2004). Graduate Theses and Dissertations. https://scholarcommons.usf.edu/etd/1280. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-96

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Without additional research on the current and potential future biofouling community at PSL, a definitive determination of the ability to practicably manage and control biofouling cannot be determined. Organism Attraction The wedgewire screen arrays and intake pipes will result in a large artificial structure leading from the shoreline to the screens. This structure would provide habitat that attracts a variety of species similar to what is provided by artificial reef structures. Artificial reefs constructed in St. Lucie County provide habitat for more than 100 species of fish, including adult snapper and grouper, snook, sharks and other fish, shelter for baitfish and juvenile fish, as well as habitat for benthic organisms such as echinoderms and cnidarians (St. Lucie County, 2021). The higher abundance of organisms within close proximity of the screens may result in more organisms being susceptible to entrainment. Corrosion Metals are prone to corrosion when exposed to salt and brackish waters. The rate of corrosion varies depending on the salinity and material, with stainless steel being less prone to corrosion when compared to other metals such as copper and copper alloys. Over time this corrosion, even with stainless steels, can lead to premature screen failure or the need for replacement. Cathodic protection from sacrificial anodes, attached to the screen and other submerged equipment, will be needed to reduce corrosion on a wedgewire screen array at PSL. These anodes would be inspected regularly and replaced as necessary. While corrosion can be an issue, neither potential corrosion, nor the effort required to inspect and replace the sacrificial anodes would preclude the use of wedgewire screens at PSL. Permitting, Construction, and Maintenance The scale of the construction of the hypothetical wedgewire screen-based system would result in a very complicated and controversial permitting process as well as very high costs of construction and maintenance. The potential for damage to the 1,265 ft long, 20-ft wide access pier used to access the offshore plenum and screen cleaning equipment due to storms and hurricanes, while designed to state standards, is still high and was considered in the assessment. Large bypass gates were included in the conceptual design to reduce the likelihood of a loss of Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-97

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) cooling water if the wedgewire screens fail; however, restoration costs were not considered. These are factors that contribute to the overall infeasibility of such an intake system. 10.5.1.3 Summary of Feasibility There are many uncertainties and constraints that make the use of wedgewire screens infeasible at PSL. In particular, debris and sediments are critical issues that will increase head losses through the screens impacting both screen and station reliability. The inability to maintain the screens under expected sediment, biofouling, and debris loading represents a fatal flaw that would preclude the use of wedgewire screens at PSL. Debris loading during jellyfish blooms is a particular concern at PSL. Other issues such as sweeping currents, corrosion and habitat formation, permitting, and costs are more tractable problems but still represent important challenges and uncertainties. Therefore, narrow-slot wedgewire screens were eliminated from consideration as infeasible at PSL. 10.5.2 Fine-mesh Modified Traveling Water Screens and an Organism Return System This section will consider the application of FM MTWS at PSL. The potential for FMS to be incorporated with MTWS, including the need to expand the intake screens, is of primary importance to this analysis and will be discussed in the balance of this section. 10.5.2.1 Technology Overview By decreasing the mesh size on MTWS from coarse (i.e., standard 3/8-in mesh, equivalent to 9.5 mm) to fine (e.g., 2 mm or less), the biological performance and reliability of the resulting system must be considered. FMS can be applied to MTWS as either overlay panels on the existing coarse mesh screens (i.e., overlays) or full-time fine-mesh. These screens rely on a three-step process to reduce entrainment mortality:

• Exclusion of the organisms
• Survival of the excluded organism and removal from the screen
• Live return of the organisms to the source water Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-98

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) In reality, none of these three processes is likely to be perfectly effective. For example, by-pass of the screens either through gaps around the screens or by extrusion through the FMS has been observed in installed systems. Similarly, the rate of survival of excluded organisms has been observed to be less than 100 percent and, in some cases, quite low (EPA, 2014b). Unfortunately, prediction of the rates of exclusion, survival, and live return is very difficult and there is not a consensus regarding design parameters to estimate and maximize the rates. With installation of finer mesh sizes within an existing CWIS, the open area available for water passage decreases resulting in increased TSV and head loss. Undue head loss has the potential to affect screen integrity and to result in hydraulic issues in the cooling system such as pump cavitation, especially during low water levels and/or high debris loading periods. The smaller opening size of finer meshes increases debris retention and the potential for screen blockage, biofouling, and/or blinding of the screens. These phenomena may rapidly worsen, resulting in accelerating head loss and cooling system failure. Conditions that affect system reliability are highly variable in time and across facilities making design challenging and motivating pilot testing of FMS systems. FM MTWS are currently installed at two nuclear facilities in the USA, Prairie Island Nuclear Station on the Upper Mississippi River in Minnesota and Brunswick Nuclear Generating Station on the Cape Fear River Estuary in North Carolina. Prairie Island Nuclear Station has eight, 10-ft wide MTWS with seasonally deployed 0.5 mm mesh screens. These screens are located in a screen house located at the mouth of a large intake canal. From April through August, the coarse-mesh panels are replaced by fine-mesh panels to reduce the number of fish eggs and larvae entrained. The remainder of the year a 9.5 mm coarse-mesh is used. At a flow of 800 cfs (517 MGD) and low water levels, the traveling water screens approach velocity is 0.5 ft/sec. At the maximum intake flow (1,500 cfs; 970 MGD), the velocity approaching the traveling water screens is less than 1.0 ft/sec. The fine-mesh panels are easily damaged requiring approximately 12.5 percent of the panels to be replaced every year. A second screen house located at the end of the intake canal is equipped with bar racks, standard TWS and the circulating and cooling water pumps for the station. This CWIS provides secondary screening to remove any debris that makes it past the FMS or originates within the canal. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-99

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Brunswick Nuclear Generating Station has eight, 10-ft wide fish-friendly traveling water screens with 1.0-mm mesh panels overlaid on 9.5-mm mesh. These screens are located at the end of an intake canal that is pre-screened by bar racks and -inch by 3/4-inch mesh fixed-panel screens. Six of the eight traveling water screens have 1.0-mm Nytex mesh overlays on each screen panel. The two remaining screens have 1.0-mm mesh overlays on alternating panels. At a full flow of approximately 2,411 cfs (1,558 MGD) and mean low tide level, the velocity approaching the circulating water traveling water screens is 1.2 ft/sec. These screens have suffered numerous recurring and emergency failures due to mechanical issues; however, plant personnel have indicated that shell growth is less on the overlay mesh screens compared to the coarse-mesh screens. Tampa Electrics Big Bend Station Units 3 and 4 have been equipped for over 30 years with seasonally deployed 0.5 mm FM MTWS with a TSV of approximately 1.3 ft/s. While not a nuclear station the performance of this system relative to exclusion and latent survival rates of several taxa and life stages also present at PSL has been studied and the resulting data are available in the public domain. The operational constraints of this system are also well documented, including the need for replacement screens and necessary level of effort associated with maintenance. 32 This information provides an empirical basis for system design and performance estimation that has been applied elsewhere and will be used to inform the discussion below. 10.5.2.2 Key Design Parameters While considering application of FMS in the context of MTWS, there are three factors of great importance: (a) the wire type and opening size of the FMS, (b) the choice between application of FMS overlays on a regular coarse mesh or use of full time FMS as the only screen or over a wide spaced backing mesh (a choice which affects the screen open area and TSV), and (c) the target TSV based on the first two factors and total area of the screen. These factors will be considered in the rest of this section. Other aspects of the design (e.g., the potential means of expanding the screens, whether to include two screens in series as has been done at Big Bend Units 3 and 4, 32 The debris load at Big Bend is relatively modest but failure of the FMS is still a common occurrence. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-100

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) potential for seasonal deployment 33), should be considered as well but the listed three factors are fundamental to any conceptual design and will be key determinants of estimated cost, biological effectiveness, and reliability. Mesh Type and Size Consideration of smaller mesh size involves several trade-offs. The wire size used for a selected mesh opening can vary, but are typically 0.59 mm (0.023 inch) in diameter for 2.0 mm mesh, 0.43 mm (0.017 inch) for 1.0 mm mesh and 0.31 mm (0.012 inch) for 0.5 mm mesh. A backing mesh with larger wires can be used to support the fine wires which are not as strong as the thicker wires. This backing mesh provides some level of debris protection if the fine-mesh wires break. Larger diameter wires or the use of a backing mesh results in more robust screens, but they have a smaller open area that results in an increased TSV. The selection of mesh size is a tradeoff between excluding smaller organisms versus reducing the screen open area with its attending issues of reduced reliability and biological performance due to increased TSV. An illustration of the effect of decreasing mesh size and different wire meshes on the open area of a clean screen and resulting TSV is provided in Table 10-17. The existing PSL screens do not include any fish-friendly features and would be replaced with MTWS if used in conjunction with FMS 34. FPL notes that the NPDES permit requires that the intake through-screen velocity shall be maintained at current levels such that existing maximum velocity is not exceeded. 35 This requirement effectively limits the TSV of a potential FMS retrofit to the existing maximum without a permit modification. The distinction between full-time and overlay application of FMS is discussed in the next section. 33 Seasonal deployment of FMS is used at Big Bend Units 3 and 4 because approximately 98% of annual entrainment occurs in seven months of the year. Such seasonal deployment reduces operations and maintenance costs. 34 The figures presented in Table 10-17 are for illustration purposes. The obstacles to installing and operating a successful organism return system from the existing screens are very substantial. 35 Part I.A.10 of NPDES permit FL0002208; effective date November 4, 2016. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-101

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-17. Change in Screen Open Area 36 and Effects on TSV TSV Increase Fine-mesh Approximate TSV Relative to Existing Mesh Wire Diameter Open Area (ft/s) Conditions (inches) (%) (%) Existing TWS NA 48.3 2.6 0 2.0 mm (full time)* 0.023 41.1 3.0 18 1.0 mm (full time)* 0.017 33.4 3.7 45 0.5 mm (full time)* 0.012 28.0 4.4 73 2.0 mm (Overlay)* 0.023 29.3 4.2 65 1.0 mm (Overlay)* 0.017 23.8 5.2 103 0.5 mm (Overlay)* 0.012 19.9 6.2 142

• Based on a generic MTWS with an 80-percent framing open area.

Assumes fine-mesh placed with the identified wire size over a 1-inch-square backing mesh with an 85-percent open area. Assumes used in conjunction with MTWS with 3/8-inch mesh and a 90-percent open area for fine-mesh panel support framing. Source: Alden, 2021. The general goal in assessing FMS is to exclude as many entrainable organisms as possible under conditions that would allow their survival and return to the source water. This suggests comparing the size of the organisms 37 entrained to the mesh size and selecting the mesh that maximizes these two goals (i.e., exclusion 38 and post-exclusion survival). Unfortunately, quantitative prediction of these two factors for the range of entrained organisms is not supported by the available literature. For example, while certain organism dimensions have been found to be predictive of the rate of exclusion relative to mesh size (refer to Section 11.0), such an approach was found to over-predict exclusion rates when compared to empirical data. More importantly, as discussed below, no reliable quantitative relationship between the rate of post-exclusion survival and TSV is available. This is particularly true given the variation in survival rates by taxa and life stage in the context of the range of organisms subject to entrainment. 36 Open areas percentages assume that the screen is completely clean. Debris and biofouling would reduce the open area and increase the TSV. 37 With this in mind, various length data were collected on a broad subset of entrained organisms at PSL. Estimation of the rates of exclusion is discussed in Section 11. 38 At PSL, approximately 64% of shellfish measure less than 2 mm in length and 99% of fish have a smallest dimension of less than 2 mm. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-102

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Overlays or Dedicated FMS? Selection of FMS as overlay panels to a coarse-mesh MTWS or dedicated FMS must be informed by three factors:

• The potential for the dedicated FMS to fail or require removal for servicing at a high enough frequency that the cooling system performance is jeopardized by passage of debris
• Reduction of the open area with a FMS overlay such that a TSV critical to biological performance and/or cooling system reliability is exceeded, motivating or exacerbating the need for intake expansion (Table 10-17)
• The potential for seasonal deployment of FMS to target a specific entrainment period and/or removal of FMS during known periods of high debris loading Fine-mesh material uses thinner wires than coarse mesh screens to maintain a reasonable open area. The thinner wires are more prone to failure as a result of erosion, debris impact and debris load. These wires can also be easily damaged by fouled spraywash nozzles. A single partially fouled nozzle combined with continuous rotation has the ability to quickly damage a large number of fine-mesh screen panels. Therefore, damaged FMS may fail to exclude entrainable organisms and may allow entry of debris large enough to plug the condensers. FMS are typically used in conjunction with a redundant mesh to reduce debris entry if the FMS fails.

Configurations using redundant meshes include fine-mesh overlaying a 3/8-inch or similar MTWS, fine-mesh with a 1-inch-square backing mesh, or FM MTWS in series with redundant TWS 39. Jellyfish intrusion events, which have led to power reductions and unit shutdowns, occur at PSL every few years. The two turtle excluder nets with 8- and 5-inch openings collect some of the jellyfish. Jellyfish that make it through the nets reach the CWISs, where they have overloaded the bar racks and the TWS. The finer wires associated with FMS are more prone to failure during heavy debris loading situations and would fail at a lower differential pressure than a comparable 39 PSL is compliant with the IM BTA standards by virtue of its use of an offshore velocity cap per 40 CFR 125.94(c)(4) (refer to Section 6) making installation of MTWS at the coarse mesh screens unnecessary. As noted above, installation and operation of an organism return from the current coarse mesh screens is extremely problematic. Issues related to the return and safety-requirements affecting the canal proximal to the coarse mesh screens are part of the motive for the placement of the hypothetical FM MTWS well upstream in the intake canal. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-103

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) coarse-mesh screen. A thicker 3/8-inch woven wire mesh would be needed to screen debris if the fine-mesh failed. A 1-inch backer mesh was not selected because if the fine-mesh failed, jellyfish and other debris larger than the condenser tube diameter would be able to enter the circulating water system. This could lead to the condenser plugging, reducing the ability to cool the units and ultimately unit shutdowns. For this reason, it has been concluded that robust coarse mesh must be operated in series with the hypothetical FM MTWS to allow for debris control when FMS fail or require service. 40 Therefore, application of dedicated FM MTWS, without a backup screen, was determined to be infeasible. Seasonal changes in the rates of entrainment are more modest at PSL and other plants on the east coast of Florida than at Big Bend and extended periods of very low entrainment rates are not as apparent. For that reason, seasonal deployment of FMS overlay panels was not considered further at PSL. Finally, as discussed below, while overlays require a greater expansion of the CWIS, application of either mode of FMS required some expansion to maintain relatively low TSV (e.g., the current 2.6 ft/s or to achieve operational conditions similar to Big Bend Units 3 and 4). As a conceptual approach, the simplest means of achieving organism exclusion and reliable debris control at PSL would likely be based on a system similar to the Big Bend configuration:

• A dedicated FM MTWS system will be installed and placed in the intake canal upstream of the existing coarse-mesh TWS
• The new FM MTWS system would be designed to achieve critical TSV and exclude and return otherwise entrainable organisms 41. Therefore, the new screens would require separate debris and fish/organism handling systems and nearly continuous rotation.
• The existing coarse-mesh TWS would remain in the existing CWISs to remove debris during periods of FMS failure or service.

40 The CWIS at Big Bend Units 3 and 4 uses a form of screen redundancy based on two sets of traveling water screens in series. The upstream set has FMS alone which are deployed for seven months a year while the downstream screens are normal coarse mesh. Debris control is achieved by the downstream set of coarse mesh screens when the FMS are either not deployed or have failed. Such a system would require expansion of the screens and is subject to the same constraints at PSL as those considered below. Importantly, only the new fine-mesh screens would include fish-friendly modifications, employ fish handling and return systems as well as debris wash and disposal systems consistent with the rules definition of MTWS. 41 Such a FM MTWS would be compliant with the IM BTA requirements of 40 CFR 125.94(c)(5) - MTWS and organism return in order to achieve the exclusion and return of entrainable organisms. Such a system would be redundant for the IM BTA standard due to the use of an offshore velocity cap. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-104

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Through-screen Velocity In its discussion of FM MTWS, EPA (2014b) summarizes the performance of some of the installed FMS systems (including Big Bend Units 3 and 4) and discusses issues associated with the performance and conceptual design of FMS systems. As summarized in the next few paragraphs, EPA (2014) makes several important observations:

• Application of FMS converts some normally entrainable organisms to ones that are impinged on the finer mesh.
• The converts may be subject to mortality on the FMS and the rate of mortality depends on the taxa and TSV.
• In its costing exercise, EPA (2014) assumed that the TSV would be reduced to 0.5 ft/s but the motives for this threshold appear to be targeted at both entrainment and impingement BTA.

Despite adopting a target TSV of 0.5 ft/s for FMS for the costing exercise, EPA (2014) does not endorse a specific TSV as a general design basis. EPA (2014) notes that if the [otherwise entrained] organisms can withstand the initial impingement on the fine mesh screen, the majority of organisms survive after passing through a fish return [p. 2-19]. In a discussion of the general phenomenon of impingement, the agency notes that: Fine mesh screens may prevent entrainment, but may also lead to increased mortality of impinged organisms (specifically eggs and larvae that would otherwise have been entrained). [p. 6-23]. EPA further notes that: For fine mesh traveling screens, impingement of converts increases as mesh size is reduced, with survival of the converts being dependent upon species and intake velocity. [p. 6-48]. When discussing reduced intake velocity EPA notes, Reducing the intake velocity generally does not similarly reduce entrainment. [pg. 6-67]. EPA (2014) concludes that: [Intake] Velocity increases beyond a certain range would be unacceptable because they might increase impingement of other organisms and would increase the mortality of eggs and larvae captured on the fine mesh screen panels. [p. 6-45]. EPA (2014) stated that: Intakes with high screen velocities (greater than 3.0 ft/s) are assumed to be unable to meet IM requirement with Ristroph traveling screens alone and are assigned either new larger Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-105

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) intakes or wedgewire screens. [p. 8-9]. 42 To avoid these undesirable effects, EPA (2014) assumed the new larger intake would have a through-screen velocity of 0.5 ft/s when estimating the screen area factor and technology costs for a new larger intake. [p. 6-45]. FPL notes that EPA selected the use a 0.5 ft/s TSV for a new larger intake only with regards to meeting the IM requirements of the Final Rule based on velocity alone. In the discussion of new larger intakes in the TDD (EPA, 2014) EPA clarifies this point and adds; As a result, the intake will not be required to include a fish handling and return system or the full suite of modified Ristroph traveling screen features. [p.8-16]. EPAs motives for using a 0.5 ft/s TSV with new larger intakes designed with FMS are somewhat ambiguous. 43 What is clear is that EPA (2014) did not consider FM MTWS when developing costing modules and only assumed an intake would be expanded if the TSV was greater than 3.0 ft/s. Further, as quoted above, EPA, in the preamble to the rule, concludes that a high proportion of facilities would find screen expansion to allow low intake velocities (approximately 0.5 ft/s) while employing FMS to be infeasible. 44 EPA is not clear on an appropriate design velocity to use when assessing the feasibility of FM MTWS. Based on discussion in the TDD, EPA (refer to page 8-21), a TSV of 2.5 ft/s represents the maximum TSV velocity for use in determining if expansion is necessary with FM MTWS. FPL used this maximum velocity when evaluating the feasibility of FM MTWS in the existing intakes. Under 40 CFR 122.21(r)(10)(i) of the Final Rule, the expected biological efficacy of a technology is not considered when determining the technical feasibility of an entrainment control technology. TSV and intake expansion would be considered when evaluating the impracticality or infeasibility of different fine-mesh technology arrangements based on site-specific constraints. 42 EPA (2014) [p. 8-21]: EPA notes that at proposal this value was set at 2.5 ft/s based on recommendations from a technology vendor (see DCN 12-6657). However, a re-evaluation showed that this threshold was more applicable to fine mesh screens. 43 EPA further confounds the issue by discussing the use of Cost Module 3 for estimating the costs for expanding an existing intake structure as part of a FMS retrofit. EPA clearly states at p 8-6 of the TDD (EPA 2014) that; Module 3 was modified so that the traveling screens were sized based on a through-screen velocity of 0.5 ft/s and coarse (3/8-in) mesh instead of fine mesh screens. 44 EPA (2014) [p. 6-48] also quotes the representative of a screen vendor with the following: 0.5 mm fine mesh requires low screen velocities (i.e., approximately 0.5 ft/s). Unfortunately, from the context of the statement, it is not clear if that purported requirement is to maintain biological performance, screen stability, cooling system reliability, or all three. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-106

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) While there is a consensus that high TSV is likely to increase the mortality of excluded organisms, the literature does not provide concrete guidelines on supportable maximum TSVs. EPRI (2010) performed a literature review of FMS studies including their settings, available information regarding the physical configuration of the CWIS, the species and life stages considered, and any data on post-exclusion survival. The various studies performed at Big Bend are included in that summary. Several studies were focused on temperate freshwater species that are irrelevant to PSL. In addition to the Big Bend investigations, two studies included marine species but both of those reported only initial survival and not latent survival. The intake velocities, as represented by the screen approach velocities, differed substantially between the two studies referenced by EPRI (2010) (i.e., 0.75 ft/s vs. 2.5 ft/s). The plant on the Gulf Coast, with the lower approach velocity, found high rates of post-exclusion survival (i.e., an overall average of 86.3 percent) while the other plant experienced a broad range of survival depending upon the taxa measured. FPL does not consider this comparison in the studies to be definitive in supporting the lower intake velocity. EPRI (2010) also reported on laboratory assessments of post-exclusion survival for a number of freshwater species. Screen approach velocity was a variable in this study and, for larger entrainable organisms of 12 mm or more length 45 of some taxa, survival was substantial at higher approach velocities (e.g., 2 ft/s, roughly corresponding to a TSV of 4 ft/s). For smaller organisms, survival of the taxa tested was very poor regardless of intake velocity. Unfortunately, this study does not provide FPL with a target TSV for the following reasons:

• The study employed a set of freshwater fish (and no shellfish) that can be reared in the laboratory and are not relevant to PSL.
• A limited suite of life stages was evaluated. In particular, no fish eggs, common among the PSL entrainment data, were assessed.
• Consideration of approach velocity and TSV were not a focus of the study design and a quantitative relationship between survival and TSV is not supported.

45 Development of musculature and other structures associated with maturation beyond a certain size was concluded to make the excluded organism resistant to damage on the screen. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-107

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) This study does, however, indicate that survival of larger entrainable sized organisms (greater than 12 mm total length) may be substantial at velocities in excess of those at the existing PSL CWIS (i.e., 2.6 ft/s). The EPRI study does not support a finding that earlier life stages of marine taxa would have meaningful survival rates at roughly 1.2 to 2.4 times the existing TSV following application of FMS within the existing CWIS. As discussed with the two other key design parameters, the operating Big Bend FM MTWS system provides a biologically effective, workable FM MTWS configuration. It also allows for use of empirical data on exclusion and survival rates that are predicated on a known set of conditions and a set of taxa and life stages that are relevant to PSL. Use of this model system and the attending performance data obviates the need to extrapolate exclusion and survival rates from one set of conditions and organisms to another without any quantitative bases for doing so. Therefore, FPL will consider that hypothetical FM MTWS should be designed to achieve similar hydraulic (approximately 1.3 ft/s TSV) and exclusion (0.5-mm mesh) characteristics as the Big Bend FM MTWS installation. This target TSV was selected as TSV is expected to be a significant factor in determining survival of the life stages collected by these screens. The use of an expanded intake may not, however, be as critical a goal for the use of FMS with 2.0 mm openings because TSV may play a smaller role in the overall survival of the larger fish collected by this mesh as discussed by EPRI (2010). Exclusion and post-exclusion survival rates for shellfish for 2.0 mm and elevated TSV (e.g., 4.2 ft/s) is poorly understood. The potential for application of 2.0 mm mesh with the existing CWISs at PSL is discussed further in the following paragraphs. As presented in Table 10-18, FPL notes that depending on the configuration and mesh size, placement of FMS overlays on new MTWS, although providing redundant screening would substantially increase the TSV, exceeding the permit requirement to not increase the current TSV. Similarly, to achieve a target TSV of 1.3 ft/s, using typical FMS with full-time 0.5 mm mesh and 1-inch square backing mesh, the screen area of the PSL would need to be expanded by a factor of 3.3 (Table 10-18). Using Big Bend style screens with full-time 0.5 mm mesh, the Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-108

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) through-screen area would need to be expanded by a factor of 3.3 46. Redundant coarse-mesh MTWS are needed with the Big Bend style screens to reduce debris entry if the FMS fails. These estimates are consistent with findings in the Final Rules preamble. Table 10-18. CWIS Expansion Necessary to Achieve a 1.3 ft/s TSV with Through-flow MTWS Approximate Open TSV if Installed in Expansion Mesh Area the Existing CWIS Necessary for (%) (ft/s) 1.3 ft/s Existing TWS 48.3 2.6 1.9 2.0 mm (full time)* 41.1 3.0 2.3 1.0 mm (full time)* 33.4 3.7 2.8 0.5 mm (full time)* 28.0 4.4 3.3 2.0 mm (overlay)* 29.3 4.2 3.2 1.0 mm (overlay)* 23.8 5.2 3.9 0.5 mm (overlay)* 19.9 6.2 4.7

• Based on a generic MTWS with an 80-percent framing open area.

Assumes fine-mesh placed with the identified wire size over a 1-inch-square backing mesh with an 85-percent open area. Assumes used in conjunction with MTWS with 3/8-inch mesh and a 90-percent open area for fine-mesh panel support framing. Source: Alden, 2021. Consideration of FMS Overlays at PSL While the scenario selected for assessment of monetized costs and benefits has clear advantages in that it has been demonstrated to be reliable 47 and effective, a brief review of a far simpler approach, application of FMS overlays on coarse-mesh MTWS in the existing CWIS is likely to provide useful perspective on the selected scenario. At PSL, application of FMS overlays could be achieved at relatively low capital costs when compared to an expanded intake option. Only 2.0 mm fine-mesh was considered for use as an overlay because there is some evidence in the literature that larger fish, such as those that would be excluded by 2.0 mm, may survive even at 46 FPL has not included a safety factor for debris loading, etc., as is generally done for designing conformance with IM BTA through a reduced TSV per 40 CFR 125.94(c)(2) or (3). No such allowance is included in the Big Bend FMS design. FPL believes that the target 1.3 ft/s TSV provides it with an appropriate safety factor to maintain compliance with the NPDES permit TSV limitation. 47 Reliability and performance have been demonstrated at Big Bend, which has relatively low debris loading. As discussed below, PSL can experience substantial debris loading and the existing coarse mesh system has been subject to failure with resulting cooling system damage. For this reason, FPL cannot conclude that a system similar to that of Big Bend Units 3&4 would be reliable and feasible at PSL. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-109

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) relatively high TSV (EPRI, 2010). 48 Despite these potential positive factors, there are several issues that indicate that 2.0 mm overlays would be infeasible and poorly effective at PSL. These issues are discussed only in relation to 2.0 mm overlays as the open area of meshes finer than 2.0 mm will further increase TSV. This would exacerbate operational issues and mitigate the expected biological benefit associated with increased organism retention:

• Application of 2.0-mm FMS overlays on coarse-mesh MTWS represents a nearly 96-percent reduction in mesh opening size (90.3 mm2 versus 4 mm2). The decrease in mesh size would collect more debris, leaving the screens more susceptible to clogging and failure. Without the ability to bypass the screens and provide redundant screening this could lead to loss of cooling water events and forced station outages.
• Overlaying coarse-mesh MTWS with 2.0 mm fine-mesh would decrease the screen open area from approximately 48.3 percent to approximately 29.3 percent. The clean-screen TSV would increase by approximately 65 percent (Table 10-17). The increase in TSV will increase the head loss across the screen by approximately three inches under clean screen conditions. At 50-percent plugged, the screens with a 2.0-mm overlay would experience approximately 17 inches of additional head loss than the existing screens.

Critically, the resulting screen system would be more at risk to rapid increases in head loss as smaller debris that would otherwise pass through the existing coarse-mesh screens would be retained on the fine-mesh screens that already have a reduced open area. Such events put the screens and cooling water systems at unacceptable risk.

• The rate of exclusion of otherwise entrainable organisms is estimated to be low but is highly uncertain. Only 1 percent of fish have a head capsule depth (HCD) of greater than 2 mm; therefore, 99 percent of entrained fish are predicted to pass through the 2-mm screens (refer to Section 11). At Big Bend, using HCD to estimate exclusion was found to over-estimate the measured rate of exclusion (refer to Section 11). 49 Additionally, only 36 percent of shellfish were measured to have a largest body dimension of greater than 48 FPL notes that a lead investigator on that effort has indicated the effects of TSV on organism survival was not a focus of the study and conclusions that larger organisms are insensitive to TSV should be made with caution. He also noted that laboratory studies, while useful for evaluating the injury and mortality associated with fish interacting with the screens and the underlying mechanisms of mortality, tend to overestimate survival because test organisms are healthy and have not been exposed to environmental conditions that may contribute to mortality (e.g.,

variations in water quality and temperature, debris loading, predation). 49 At Big Bend Units 3 and 4, side and boot seals have been optimized to reduce organism passage but some undoubtedly still occurs. Direct passage through the screen based on compression of the organism is also likely. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-110

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 2.0 mm, indicating that at least 64 percent of shellfish would likely pass through the 2-mm screens. However, there is no consensus that this is a reasonable basis to predict exclusion rates and it is reasonable to expect that, as with HCD, one of the smaller body dimensions is a better predictor of the rate of exclusion, not the largest.

• The rate of post-exclusion survival is essentially unknown for this combination of taxa, life stages, mesh size, and TSV. While it can be expected that the rate of survival of excluded organisms will be lower at TSVs of 4.2 ft/s, relative to 1.3 ft/s, there is no sound basis to estimate the change.
• The screen system at Big Bend Units 3 and 4, which was selected as the design basis for PSL, is designed to provide screening redundancy and achieve TSV at the FMS that facilitates exclusion and post-exclusion survival. Departure from this model introduces high degrees of uncertainty in the estimated reliability of the system and its biological performance. Even the Big Bend system with its lower TSV, redundant systems, and seasonal deployment requires extensive maintenance beyond that required by the coarse-mesh screens located downstream of the fine-mesh MTWS. The annual cost of the FMS maintenance has been reduced through careful planning in recent years but still approaches $500,000 per year. Even with this level of maintenance, the FMS experience failures and the NPDES permit recognizes that some of the FMS may be out of service at a given time.

Based on these factors, application of 2.0 mm and other fine-mesh overlays on coarse-mesh MTWS in the existing CWISs was eliminated from further consideration. The potential social costs and social benefits were not estimated due to the extreme uncertainty in the design of the hypothetical system and any resulting estimates. FPL wants to emphasize that it could not replace the existing TWS with MTWS designed for 2.0 mm or any other overlays as entrainment BTA, without careful consideration of how increases in rate and magnitude of head loss across partially plugged screens would affect station reliability during both normal and high debris loading conditions, such as jellyfish intrusions. The ability to bypass the FMS along with redundant coarse-mesh screening is considered a required component of any FMS option at PSL to reduce the risks to the screens and cooling water systems. FPL also notes that rates of exclusion and post-exclusion survival are highly uncertain and, for most Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-111

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) organisms, are likely to be low. For these reasons, FPL believes that 2.0 mm or any other overlays are essentially infeasible and cannot represent entrainment BTA. 10.5.2.3 Selected FMS Scenario In summary, in assessing the feasibility, costs, and performance of a hypothetical retrofit of PSLs CWISs with FMS, FPL has assumed the following screen configuration consistent with the intakes at Big Bend Units 3 and 4:

• The FMS would have 0.5 mm mesh. This mesh size is selected to maximize the exclusion of entrainable organisms as well as allow use of the data on the rates of exclusion and rates of post-exclusion survival measured at Big Bend Units 3 and 4. The latter factor is critical to enabling sound estimates of biological effectiveness and monetized social benefits.
• The target TSV for the FMS would be 1.3 ft/s. Again, use of this design parameter is consistent with the demonstrated system at Big Bend 3 and 4. Of course, this target TSV is nearly three-fold higher than the value assumed by EPA (2014b) in its costing exercise and would result in a hypothetical expanded intake of approximately one-third the size considered by EPA. FPL believes that this assumption is a sound one given the precedent available at Big Bend. Use of this design parameter also allows application of measured biological performance data, greatly reducing the uncertainty in estimation of the monetized benefits.
• The FMS would be deployed year-round.
• The FMS would be placed in a new intake structure located in the intake canal well upstream of the two existing CWIS. Construction in the intake canal in closer proximity to the existing screens is not possible due to the designation of the upper intake canals volume as emergency service water. Placement nearer the inlet of the intake canal also potentially increases survivability by reducing the length of the organism return system.
• The new FMS would be designed for only fine-mesh and not overlaying a redundant mesh, reducing the TSV but also increasing the rate of FMS failure. The existing coarse-mesh TWS would act as backups for debris control in the event of FMS failure. The offshore velocity caps are expected to meet the IM requirements of the Rule, negating the need to replace the existing screens with MTWS.

Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-112

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13)

• The FMS with an integrated 1-inch-square backing were not elected as the primary (seaward) screen because of the increase in TSV and the conclusion that the FMS would, despite the backing, be subject to a similar rate of damage and debris by-pass as the unsupported screen. Similarly, FMS with backing was rejected as the only screen material in the existing screen bays due the potential for FMS failure and TSV that is likely to reduce biological effectiveness.
• The new set of fine-mesh MTWS would be dual-flow screens which allow for an increase in screen area within a more limited footprint. Such screens also improve debris control because the debris is collected on both the ascending and descending side of the screen, with no means to carry over to the clean side. Finally, the screens would be bay-less in that they are enclosed in a shroud that hangs from a deck. This approach is less expensive and simpler to install than more typical MTWS which are installed in individual screen bays. The bay-less and dual-flow features are both employed in the FMS system at Big Bend Units 3 and 4.

Such a system for PSL, including twelve dual-flow screens, with approximately 9.8-ft wide baskets and a 21 ft screening depth at low water levels is presented in Figure 10-21. This design represents a doubling of the surface area from the existing PSL screens. 50 A new organism return to transport collected organisms back to the ocean is included in the design as indicated in Figure 10-21. Design The expanded intake would be designed for twelve, 10-foot-wide fish-friendly no-well dual-flow screens with 0.5 mm mesh, each providing a 19.6 ft wide effective screening width (twice the basket width). The velocity through these screens would be approximately 1.3 ft/s during low water levels (El. -8.0 ft). The screens would be spaced approximately 20 feet on-center. The hydraulic conditions approaching the screens would need to be investigated to determine if the spacing is sufficient to provide fairly uniform flow (i.e., velocity) through the screens. Poor screen hydraulics can lead to uneven velocity distribution, increasing loads on the screens and motors and reduced screen service life. Costs for a computational model study of this alternative 50 This figure does not consider any debris loading on the screen, consistent with the design at Big Bend Units 3 and 4. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-113

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) are included in the overall cost estimate. If the results of this model study indicate unsatisfactory hydraulic conditions for this option, the intake may need to be expanded further. The new screen house would be located within the intake canal, approximately 0.3 miles downstream from where the intake tunnels enter the intake canal and 0.7 miles upstream of the existing CWISs. The invert of the new screen house was assumed to be at elevation -29 ft, which is 3 inches above the original invert of the intake canal. The new 295 ft long screen house would have 14 openings, 12 for the new FMS and two emergency bypass openings. The emergency bypass openings would be used during periods of heavy debris loading, such as a jellyfish intrusion, to reduce the likelihood of screen failure. The two emergency bypass bays would include all the equipment necessary to allow spare FMS to be installed in the emergency bypass openings when screens are removed for maintenance. Costs for two spare FMS are included in the cost estimate. The expanded screen house would also include a work deck, bar racks with rakes, a lifting crane to install and remove the FMS and new screen wash pumps. The FMS would be mounted to custom bulkhead openings built into a concrete wall used to create a plenum between the FMS and the existing CWISs. Extensive dredging and widening of the intake canal would be needed to accommodate the new screen house. The expanded intake structure is shown in Figure 10-21. Fish and debris removed by the low-pressure spray washes from the FMS would flow into a new organism return line. This new line would run to the east for approximately 2,200 ft, and extend approximately 300 ft offshore. This location is expected to be outside of the surf zone while still being outside of the intakes zone of influence, limiting the potential for non-volitional reimpingement. Several obstacles related to essential systems at the plant, and transit of a highway, forested wetlands, the dune/beach system, and the surf zone would make installation and operation of the organism return to the source water extremely challenging. A pumped organism return, similar to what is installed at Big Bend would be necessary to overcome these obstacles. A fish-friendly pump located in a dry well would provide the driving force for the organism return. Two pumps are included in the cost estimate to provide a redundant system in the event that the main pump needs to be taken offline. The organism return Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-114

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-21.Conceptual Design for an Expanded Intake Designed for FMS with a 1.3-ft/s Through-screen Velocity - Plan Source: Alden, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-115

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) line would be located in a trench until reaching the beach. The organism return would be encased in rip-rap across the beach and out past the surf zone. Separate high-pressure sprays would be used to remove debris, which would then be conveyed through a separate trough and deposited into a roll-off dumpster for offsite disposal. The hypothetical FM MTWS system would likely not encounter large fish and sea turtles given the existing set of barrier nets in front of the FM MTWS location required under ongoing consultation with NOAA Fisheries. Under this scenario, these nets would be maintained during construction and operation, and the established capture and release program required by NOAA Fisheries would be continued. Construction Prior to the construction of the expanded intake, the intake canal would be dredged down to an invert of El. -35 ft, 6 ft below the invert of the new FMS and approximately 5.75 ft below the original invert of the intake canal. A silt barrier would be installed around the active dredging areas to reduce silt egress into the CWIS and condensers. Construction of the expanded intake would be constructed in the dry. This would be accomplished in two phases to reduce effects on station operations. During the first stage of construction, one side of the intake canal will be excavated and a large cofferdam constructed. This cofferdam would be built using shore-based methods and extend approximately 2/3 of the way across the intake canal. The remaining third of the canal will remain open to provide flow to the station. This work would be conducted downstream of the existing barrier nets to avoid interactions with listed species or other large organisms. Once the cofferdam is complete and the active construction area dewatered, construction can start on the expanded intake. Reinforced concrete would be used for the bulkhead wall. Concrete filled steel pipes would be used for the areas upstream and downstream of the bulkhead wall. The work deck, screen lifting crane, bar racks and rake would be installed next. The new screens will not be installed at this time. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-116

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Once the first section of intake is complete the construction area would be re-watered and the cofferdam removed. A new cofferdam would be constructed on the other side of the intake canal. This new cofferdam would tie into the partially constructed intake. Flow would pass through bulkhead openings in the completed intake. Construction of the second section of intake would follow the same construction sequence as the rest of the intake. After the structural portion of the expanded intake is complete, the cofferdam will be removed. The spray-wash pumps and FMS would then be installed. Once this is completed the emergency bypass gates would be closed and all the flow would be directed through the FMS. The organism return would be constructed at the same time as the expanded intake. A large pump well would be constructed adjacent to the expanded intake. The organism return pipe would be installed below grade out to the beach. The pipe would then run at grade as it crosses the beach and out past the surf zone. This section of the organism return would be encased in rip-rap. The rip-rap would protect and anchor the organism return. The rip-rap would also extend above the normal high water level providing access during construction, allowing for shore-based construction and for inspections of the organism return outfall. Retrofitting PSL with an expanded intake with FMS is expected to take approximately 65 months from design to completion, with active construction accounting for approximately 18 months. Sequencing construction to allow the intake flow to bypass the active construction areas would allow PSL to operate throughout the construction period. Single unit outages may be necessary to reduce the intake flow for short durations. If unit shutdowns are needed they are assumed to occur during previously scheduled outages 51, limiting their impact on station generation. The overall schedule for this option including detailed design and engineering, permitting, and construction is provided on Figure 10-22. 51 Unit outages for refueling are typically exploited for a variety of maintenance activities. Outages are planned to affect only a single unit at a time. It is possible that construction circumstances such as substantial interruption of water supply could require outage of both units. This would substantially impact project costs as well as social costs associated with replacing the capacity of both idled units. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-117

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-22. Construction Sequence for an Expanded Intake Designed for FMS with a 1.3-ft/s TSV Source: Alden, 2021. Operation and Maintenance (O&M) Operation and maintenance procedures for the new screens is based on information on the maintenance strategies and cost for the FMS installed at Big Bend Stations Units 3 and 4 which are operated in a similar fashion as anticipated by this potential option at PSL. The FMS would be rotated and cleaned continuously or near continuously, throughout the year, versus for only seven months at Big Bend. Two FMS per year would also be removed and sent back to the screen manufacture for a major overhaul. This major overhaul is expected to cost approximately $750,000 per screen or $1,500,000 per year for two screens. Two spare screens, for a total of fourteen screens, would be purchased allowing the two spare screens to be stored onsite. Each of the spare screens would be installed in an emergency bypass bay before a screen is removed from service. FMS use small diameter wires that are more prone to damage from debris and fouled spray wash nozzles than coarse-mesh. As a result, approximately 25 percent of the fine-mesh material would be replaced annually. Power requirements to clean and operate the FMS, spray wash pumps and organism return pump would be approximately 4,999 MWh per year, assuming all 12 screens are rotated continuously. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-118

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The organism return line and pump sump would be inspected daily. If any signs of debris or biofouling are seen the organism return line would be cleaned. An annual diver inspection and minor dredging of the intake canal directly in front of the expanded intake is expected to be required to limit sediment buildup in the intake. Regular inspection and maintenance of the organism return, FMS, and intake are expected to cost $868,000 per year, not including major screen overhauls. When the FMS are in place, the existing coarse-mesh TWS would be rotated for approximately 1 hour per day to prevent fouling and maintain them in operational condition. If the FMS need to be bypassed, the existing TWS would rotate under a similar schedule to current operations. Each of the existing TWS were assumed to need a major overhaul every 6 years, resulting in an annualized cost of $341,000. Power requirements to clean and operate the existing TWS and spray wash pumps would be approximately 112 MWh per year assuming the screens are rotated an average of 1 hour per day. Regular maintenance on the existing screens including disposal of debris removed from the screens is expected to cost approximately $109,000. The reduction in maintenance costs of the existing TWS is accounted for in the facility cost estimation of the potential installation of FM MTWS. With both the FMS and the TWS installed, the clean screen head loss would increase by approximately 1.8 inches at the circulating water pumps. This change in head loss is not expected to impact the operation of the circulating pumps. However, hydraulic modeling of the intake with the new screens should be initiated to ensure balanced flow through the screens and to determine the effect of debris loading on head loss across the screens and station operations. Permitting Installation of the FMS option would require construction and dredging activities within the PSL intake canal and disposal of the dredged material. The new fish and debris return would parallel the intake canal, cross over the beach and pass through the surf zone. Construction activities from the dunes through the surf zone would trigger the need for federal, state, and local permits and authorizations. These construction activities would be timed to limit interactions with sea turtle and bird nesting seasons. The organism return discharge would be considered a new outfall Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-119

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) and would need to be permitted accordingly under the NPDES program. The cost for these permits was taken as 2 percent of the direct capital costs estimated for this project. Sixteen to 24 months were anticipated for the application process, assuming all applications are submitted and reviewed concurrently. PSL is subject to additional safety and security measures as required by the Nuclear Regulatory Commission (NRC). Any technologies selected to meet §316(b) requirements should not compromise the safety or security requirements established by the NRC. This assessment did not consider the 10 CFR 50.59 analysis (NRC, 2001) required by the NRC. The 10 CFR 50.59 analysis requires a detailed assessment of proposed design changes on nuclear safety and security. This analysis will have to be completed before any decisions are finalized. At this point, conducting such an analysis would be premature. Costs to conduct the 10 CFR 50.59 analysis were assumed to be 1 percent of the direct capital costs estimated for this alternative. This cost was added to the overall permitting cost. 10.5.2.4 Uncertainty and Additional Studies Many of the design concepts and O&M costs are based on the Big Bend fine-mesh expanded intake which uses fine-mesh (and coarse-mesh) screens for approximately seven months of the year and coarse-mesh MTWS only for the rest of the year. It is possible that O&M characteristics at PSL would be different from Big Bend because of the difference in environmental setting, debris loading, nuclear safety requirements, etc. In many respects, the system evaluated would be a first-in-kind, and as such several additional evaluations and studies are needed prior to designing, constructing, or installing this system at PSL. Debris Handling and Clogging Study There is limited data on the ability to maintain FMS screens under the debris loading conditions at PSL. Of particular concern is the ability to maintain the screen during jellyfish intrusions. A pilot study should be conducted at PSL to determine if fine-mesh screens can be installed under the debris conditions at the site. A study using one of the existing traveling water screens retrofitted with a fine-mesh overlay to evaluate the debris handling and head loss characteristics through the screen was assumed for this evaluation. This study would not evaluate the biological performance of the screen, but would identify the size and quantity of debris that would be Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-120

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) collected on FMS at the site. Costs for this study, including adding FM overlays to one of the existing TWS are expected to be approximately $150,000 for a 1 year fine-mesh deployment. If retrofitting one of the existing screens with fine-mesh material would negatively impact nuclear safety, a barge based pilot study could be conducted. The costs for a barge based study in the intake canal would be approximately three to four times the costs of a study using an existing screen. Study to Evaluate Screen Impact on Cooling Water Pump Performance Head loss across the screens will impact the water level at the circulating water pumps for both units. The increase in head loss with the selected option is expected to be approximately 1.8 inches under clean conditions. Potential operational issues associated with reduced water levels on the pumps and nuclear safety would need to be identified prior to moving forward with any retrofit option; therefore, a pump intake model would be necessary. This pump intake model would be used as part of the 10 CFR 50.59 analysis to ensure that the expanded intake with FMS does not impact the safety or security requirements established by the NRC. Both physical and numerical model studies are expected to be needed. These studies are expected to cost approximately $350,000 and are included in the overall cost estimate for this option. Study to Evaluate the Screen Hydraulics A uniform screen approach velocity is necessary to ensure balanced flow through the new screens. Unbalanced flow can lead to areas of high TSV, head loss, and debris loading. This would increase the torque on the screens, accelerate wear, and may lead to premature failure of the screens. The intake models used to investigate any impacts to the pump performance would be expanded for use in optimizing the flow distribution through the screens. Modifying the pump models and completing a physical model study is expected to cost approximately $50,000. Organism Return Hydraulic Study A pumped organism return is necessary at PSL to return fish to the source waterbody. Big Bend has had a pumped organism return for several decades, there are however limited design guidance to aid in the selection of an appropriate organism friendly pump and development of a pumped organism return for PSL. A detailed hydraulic analysis of the pump sump and organism Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-121

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) return would be needed to ensure that organisms are safely returned to the source waterbody. This study is expected to cost $30,000 and is included in the overall cost estimate. The organism return discharge location is expected to be adequate to prevent re-impingement for non-motile entrainable organisms and would not need additional study. Pre-construction studies Additional studies including topographic, wetland delineation, geotechnical, and seismic investigations would be needed to determine the final layout and design the expanded CWIS. Cost for individual studies were not estimated as part of the preliminary designs, but were accounted for as part of the indirect costs. 10.5.2.5 Compliance Costs Feasibility level costs consistent with AACE Class 4 cost estimates were developed for the FMS option designed for a 1.3 ft/s through-screen velocity. These costs are intended to be used to facilitate a BTA determination. This estimate is composed of order-of-magnitude costs for direct, indirect, annual and periodic O&M, energy penalty, and compliance study costs. The capital and O&M costs were multiplied by cost factors to account for additional burdens as a result of added security and safety requirements associated with nuclear facilities like PSL. A 1.2 multiplier was applied to all labor for productivity (loss) for work outside the protected area. (e.g., if it takes 1 man-hour to do something at a fossil facility, it takes 1.2 man-hours at a nuclear facility). This accounts for additional staff/supervision requirements. An additional 1.3 multiplier was applied on wages, because only a subset of contractors are badged/able to work at nuclear stations. All activities associated with the expanded intake area was assumed to occur outside of the protected area. Accounting for both factors results in an overall adjustment factor of 1.56. This factor was applied to labor during both construction and operation of the expanded intake. The direct, indirect, annual, and periodic O&M, energy penalty and compliance study costs to expand the intake and add FMS designed for a 1.3 ft/s through-screen velocity and a pumped organism return are presented in Table 10-19. The O&M costs in Table 10-19 include the costs for both the FMS and TWS, assuming the FMS can be installed throughout the entire year. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-122

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-19. New FMS Designed for a 1.3-ft/s Through-screen Velocity Capital Costs Estimated Cost Indirect Design and Permitting Costs Pre-construction engineering studies (indirect costs) $9,139,000 Permitting $1,828,000 Hydraulic and pilot studies $570,000 Total Indirect Project Costs (2020$) $11,537,000 Direct Construction Costs Mobilization and demobilization $5,539,000 Dredging and earthwork $2,912,000 Cofferdam and sheet piling $12,602,000 Intake structure $8,508,000 Screen lifting crane $166,000 New fine-mesh screens $25,274,000 Fine-mesh spraywash system $2,670,000 Fish and debris return system $3,258,000 Direct Costs (2020$) $60,929,000 Taxes and depreciation (6.5% of Materials) $2,511,000 Distributable costs (15%) $9,139,000 Overhead and profit (10%) $6,093,000 Subtotal $78,672,000 Allowance for indeterminates/contingencies (20%) $15,734,000 FPL administrative (10%) $7,867,000 Total Direct Project Costs (2020$) $102,273,000 Construction Activities and Impacts Permitting (months) 16 to 24 Active construction duration (months) 18 Outage (months per unit) 0 Total Annual and Periodic Costs Annual labor and equipment* $907,000 Major screen overhaul $1,860,000 Annual energy (MWh) 5,057

• Inspect and maintain 12 FMS and 4 TWS, including replacement of 25 percent of the fine-mesh material annually.

Each FMS and TWS is replaced every 6 years. Continuous rotation of the FMS for 12 months. The existing TWS are rotated and cleaned for 1 hour per day. Source: Alden, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-123

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The design of the existing offshore velocity cap is expected to be selected as BTA for impingement. As a result, the existing TWS would not need to be upgraded to MTWS as part of a retrofit to expand the intake for FMS with a 1.3 ft/s through-screen velocity. The estimated annual operating costs associated with maintaining the current operation of the existing TWS, in lieu of installing FMS are presented in Table 10-20. Operating costs for the existing TWS were estimated as part of this study to allow for the development of incremental operating costs associated with FMS. Table 10-20. Annual Costs to Operate and Maintain the Four Existing TWS if the Existing Intake is Determined to be BTA for Entrainment Cost Component Total Annual and Periodic Costs Annual labor and equipment* ($) $117,000 Major screen overhaul ($) $360,000 Annual energy (MWh) 115

• Inspect and maintain the 4 TWS.

Annualized cost to rebuild each TWS every 6 years. Screens and spray wash system operated an average of 2 hours per day. Source: Alden, 2021. The capital and O&M costs for FMS only, shown in Table 10-21, are the incremental cost difference between the design and operation of the existing CWIS representing IM BTA via Compliance Alternative 4 and FM MTWS designed for a 1.3 ft/s through-screen velocity. These costs represent the additional compliance cost that FPL will incur if FMS are selected as BTA for entrainment. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-124

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-21. Compliance Cost Summary for New FMS Designed for a 1.3-ft/s Through-screen Velocity with a Pumped Organism Return Capital Costs Estimated Cost Years Incurred Total indirect project costs (2020$) $11,537,000 2022 to 2025 Total direct project costs (2020$) $102,273,000 2026 to 2028 Total capital costs (2020$) $113,810,000 Incremental annual costs* Annual labor and equipment $790,000 2028 to retirement Major screen overhaul $1,500,000 2028 to retirement Annual energy (MWh) 4,942 2028 to retirement

• Difference in annual costs between maintaining current operations of the existing TWS and the expanded intake with FMS.

Source: Alden, 2021. 10.6 Alternate Cooling Water Sources 40 CFR 122.21(r)(10)(i)(C) PSL uses the Atlantic Ocean for source water. The Final Rule requires the facility to evaluate alternate water sources to reduce the surface water withdrawal rate. This evaluation considered the use of groundwater and treated wastewater as described below, and reuse of existing water sources. 10.6.1 Description of Plant Water Uses The Plant utilizes the Atlantic Ocean as source water for its once-through cooling system and auxiliary equipment cooling (a total of 1,486.94 MGD for Unit 1 and Unit 2). Raw water for the water treatment facility, potable water, sanitary water, and water for fire protection systems for the Plant is provided by the Fort Pierce Municipal Water Supply (approximately 4 million gallons per month) (FPL, 2011). The Plant does not have any direct withdrawals of groundwater; onsite wells are limited to recovery wells (FPL, 2011). 10.6.1.1 Onsite Water Reuse Onsite water use primarily consists of circulating water, service/process water, screen backwash water at the plant intakes, and potable uses. Water reuse onsite would include reusing water from existing Plant uses in support of the condenser cooling water. Intake screen backwash water is Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-125

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) not suitable for reuse, as it is intended to remove debris from the screens. Potable water uses must be kept available for Plant personnel use. Process water must be kept available, as it is essential to make demineralized water for makeup to various plant systems, including primary and secondary reactor cooling loops and the spent fuel pool (FPL, 2011). As water from the CWIS is already used for the cooling water system and other auxiliary equipment cooling purposes and potable and process waters are kept for personnel use, and as there are no direct groundwater withdrawal wells, there is no viable source of water that could be reused on the site to supplement the circulating water system. As a result, water reuse is not evaluated further. 10.6.2 The Approach for Evaluation of Alternate Water Sources The below evaluation has been performed in two steps. The first step is to shortlist additional sizable alternate water sources located within a reasonable distance. The second step involves a further analysis of shortlisted sources. In the first step, the daily flow rate of any alternate water source within a specific radius is compared to the Plants DIF (Table 10-22). Due to permitting challenges such as highway crossings, numerous rights-of-way required over private properties, and prohibitive construction costs, alternate water sources greater than a radial distance of five miles from the Plant are not considered to be practicable. Table 10-22. Radial Distance for Alternate Water Sources at PSL Approximate Minimum Target Distance from Facility Percent of Facilitys DIF Flow Rate for Further Evaluation (miles) (%) (MGD)

                <1                                   5                               74 1 to 2                            10                              149 2 to 3                            15                              223 3 to 4                            20                              297 4 to 5                            25                              372 Note: PSLs DIF = 1,486.94 MGD.

Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-126

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) For shortlisted alternate water sources, the evaluation will include an approximate pipeline alignment from the alternate source to the Plant, and assess the source for:

• Reliability of supply.
• Water quality compatibility with the Plants uses.
• Additional necessary treatment and approximate costs.
• Cost of conveying water from the source to the Plant.
• The relative effort to negotiate rights-of-way on each property parcel crossed.
• The impact of discharge, including permitting issues.

Groundwater sources with sufficient well yields to serve as a viable source will be further evaluated for the following:

• Water quality compatibility with Plants equipment
• Groundwater and Atlantic Ocean water compatibility
• Groundwater discharge options and the potential impacts of comingling groundwater and Atlantic Ocean water
• Potential need for additional chemical use
• Cursory evaluation of the impact of groundwater on the biota in the Atlantic Ocean
• Impact of groundwater extraction on the aquifer, other wells, and other groundwater uses 10.6.2.1 Treated Grey Water Sources Two wastewater treatment plants (WWTPs) have been identified within a five-mile radius of the Plant on the barrier islands (Table 10-23). Several more facilities located within a five-mile radius have been identified west of the Indian River Lagoon, which separates the Plant and these WWTPs; owing to conveyance challenges, these WWTPs have not been included as part of the analysis. It is assumed that those facilities west of the Indian River Lagoon would not be considered for further evaluation due to the impracticality and infeasibility of piping the water across the Indian River Lagoon in the necessary quantity. All WWTPs are shown on Figure 10-23. WWTPs represent a hypothetical supply of reclaimed wastewater that, if used to reduce the amount of water that PSL withdraws, could reduce potential entrainment.

Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-127

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Figure 10-23. Groundwater Wells and Wastewater Treatment Plants within a 5-Mile Radius of PSL Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-128

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-23. Grey Water Alternate Water Source Evaluation Maximum Distance Percent of Candidate Available Grey Water Source* from Plant Plant DIF for Further Flow (miles) (%) Evaluation (MGD) South Hutchinson Island

                                         <1                 1.6              <1                    No Wastewater Reclamation Facility Island Dunes Country Club                  2 to 3           0.09             <1                    No

• Located on the barrier islands east of the Indian River Lagoon. It is assumed that those facilities west of the Indian River Lagoon would not be considered for further evaluation due to the impracticality and infeasibility of piping the water across the Indian River Lagoon.

PSLs DIF = 1,486.94 MGD Sources: SFWMD 2006. FDEP 2018b. The evaluation of the WWTPs maximum rated treatment capacity (SFWMD, 2006) compared to PSLs DIF is presented in Table 10-23. It is important to note that the maximum treatment capacity listed for each facility would not be available to PSL, as flow conditions, weather, and other circumstances would impact the discharge rate from a WWTP. The values used here are therefore the upper limits. The capacity of each WWTP is less than 1 percent of PSLs circulating water flow, and therefore neither is a candidate for further evaluation (Table 10-23). 10.6.2.2 Groundwater Sources The following sections describe the groundwater availability for PSL and offsite wells within a five-mile radius of the Plant. Onsite Wells PSL does not have any direct withdrawals of groundwater. The only onsite groundwater withdrawals are those associated with recovery wells that average less than 7.5 gpm (FPL, 2011). Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-129

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Offsite Wells According to groundwater well GIS databases maintained by FDEP (2018a; 2020), there are several active private or public water supply wells within a five-mile radius of PSL but none has a sufficiently large flow to be a candidate for further evaluation (Figure 10-23), and there are no wells located on the barrier islands; all wells found in the FDEP databases are located west of the Indian River Lagoon (FDEP, 2018a; 2020). Due to the impracticality and infeasibility of piping groundwater from multiple sources across the Indian River Lagoon, groundwater from offsite wells is not considered a viable option for further evaluation. 10.6.3 Alternate Cooling Water Source Feasibility Based on findings presented in this subsection, alternate water sources are deemed infeasible and impractical as supplemental cooling water sources and will not be evaluated further. 10.7 Other Technologies This section discusses other technologies that already reduce entrainment at PSL or could have the potential to reduce entrainment. 10.7.1 Location of the Velocity Cap The original design moved PSLs intakes from the Indian River Lagoon to the Atlantic Ocean. PSL withdraws circulating water and service water through three offshore velocity caps located approximately 1,200-ft offshore in the Atlantic Ocean. At the time of the original design, this velocity cap location was selected in consultations with the EPA to reduce impingement and entrainment by locating the velocity cap in an area with relatively low biological productivity. The PSL intake was positioned, designed, and constructed as BTA for impingement and entrainment. A study prepared for FPL (FPL, 2010) verified that offshore intakes located at mid-depth in the water column reduced impingement potential due to the lower fish and shellfish densities present at this depth compared to that observed at sea bottom depth; in addition, the study indicates that the intake withdraws cooler water compared to water from the Indian River Lagoon, which reduces the amount of water required for cooling. This results in a lower entrainment potential. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-130

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) The 2010 study supported the decision to relocate the Plants CWIS from the Indian River Lagoon to the Atlantic Ocean, and the original BTA determination that the velocity caps at mid-depth reduce impingement. 10.7.2 Variable Speed Pumps Variable speed pumps (VSP) could allow the operator to increase or decrease the pumping rate (within the pumps capacity) based on the Unit 1 and Unit 2 operating or regulatory requirements. The intention is to pump only the amount of water needed to adequately condense steam associated with the steam turbines electric load, thereby reducing the water withdrawal rate while meeting regulatory thermal criteria. PSL is a nuclear power plant that operates at near-full capacity and has little opportunity to reduce flow. In addition, the constraints on a variable speed pump system would make installation difficult and costly. 10.7.2.1 Description of Technology Pump speed refers to the rotational speed of the pump shaft. The shaft is connected to the impeller, and the impeller transfers energy to the water (Europump & the Hydraulic Institute, 2004). Slowing the rotation of the impeller reduces energy transfer rate to water and the water withdrawal rate from the waterbody. Adjusting of the pump speed is achieved by a variable speed drive (VSD) that controls the rotation speed of the pumps electric motors. Matching the VSD to the motor and pump is subject to complex constraints, with some motor/pump combinations being unsuitable for VSD. In addition, the tunable range of pump speed must be defined and is subject to system constraints as well as the potential opportunity for reductions in intake flow. VSD must be housed in a dust, humidity, and temperature-controlled environment. A separate building would need to be constructed adjacent to the existing CWIS and as close as possible to the circulating pump motors to house these drives; the new building would need its own heating, ventilation, and air-conditioning system to provide the necessary controlled environment. The PSL Protected Area is fully built-up, and the existing intake structure is surrounded by Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-131

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) underground piping and utilities; there is no space to construct a new building close enough to the existing pumps to house VSD. 10.7.2.2 Constraints to Flow Reduction There are limitations on the allowable reductions in flow through the condensers. Key constraints are discussed below.

• Generation data for periods 2015 through 2019 shows that PSL generated at or near 100 percent of its rated daily capacity unless it was in a refueling or maintenance outage.

Monthly averaged capacity utilization rates are shown in Table 10-24 for Unit 1 and Table 10-25 for Unit 2. Planned or unplanned outages occurred in portions of 15 of the 60 months of record presented for Unit 1 and in 10 of the 60 months of record for Unit 2. The Unit 1 utilization rate exceeded 100 percent in 42 of the 60 months. The Unit 2 utilization rate exceeded 100 percent in 49 of the 60 months. Therefore, while facilities with fluctuating generation may be able to reduce water use during reduced generation periods, PSL, as a baseload facility, has experienced very few fluctuations in generation, and does not expect to experience them in the foreseeable future.

• The PSL cooling water flow may be reduced only to the extent allowable by the temperature limits of the NPDES permit. The permit requires the daily maximum temperature of the discharge to be no more than 115°F during normal operation and a daily maximum temperature differential between intake and discharge of no more than 30°F. This evaluation therefore assumes that flow reduction would not be allowed if the intake temperature is at or greater than 85°F.
• The PSLs consistently high-capacity utilization rate translates to minimal opportunity to reduce flow, given that the units are often operated at full capacity.
• To extend the life of the pumps, VSP should not vary pump/motor speed frequently.

Given the large size of pumps, this evaluation assumes that changing the pump speed at most once every four hours would be allowable. Predicted opportunities to reduce cooling water flow that occur within those four hours would be difficult to exploit.

• Given that PSL needs to be able to operate at its maximum capacity whenever market conditions demand it, the Plant cannot commit to reducing future generation. This evaluation assumes that historical market demand is representative of future demand.

Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-132

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-24. Unit 1 Monthly Average CUR Month 2015 2016 2017 2018 2019 1 102% 100% 99% 102% 102% 2 102% 102% 77% 102% 102% 3 84% 101% 102% 58% 102% 4 35% 101% 101% 64% 83% 5 101% 101% 101% 100% 0% 6 101% 100% 101% 102% 41% 7 102% 100% 101% 100% 101% 8 92% 8% 101% 101% 100% 9 100% 87% 94% 100% 50% 10 101% 0% 100% 94% 45% 11 101% 67% 101% 101% 63% 12 101% 102% 102% 102% 102% Note: Months with full or partial outages are highlighted and italicized. Source: ASA, 2021. Table 10-25. Unit 2 Monthly Average CUR Month 2015 2016 2017 2018 2019 1 103% 103% 103% 103% 103% 2 85% 103% 68% 102% 103% 3 100% 103% 19% 103% 103% 4 68% 102% 102% 102% 102% 5 101% 102% 102% 102% 102% 6 102% 101% 102% 102% 102% 7 102% 101% 102% 100% 102% 8 101% 101% 101% 81% 101% 9 23% 101% 100% 0% 101% 10 17% 73% 90% 70% 101% 11 100% 102% 102% 102% 102% 12 102% 102% 102% 102% 103% Note: Months with full or partial outages are highlighted and italicized. Source: ASA, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-133

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13)

• The volume of water flow through condensers must be sufficient to allow scouring of the condenser tubes necessary to avoid deposition of solids. Reducing the flow through the condensers reduces water flow velocity. While the actual deposition velocity depends on the various substances in the water, a velocity of 3 ft/s or greater is needed to scour the tubes (Lindeburg, 2003).
• Under all circumstances, even those within the operating specifications of the condenser, reducing flow would increase the temperature across the condenser and thereby increase the turbine backpressure. As discussed in the evaluation of potential cooling tower retrofit, increasing turbine backpressure reduces the facilitys output of electricity.

10.7.2.3 Cost and Feasibility Considerations of Variable Speed Pumps It is impractical and potentially infeasible to install or operate VSP or VFD at PSL for the following reasons:

• Lack of space to house the drives and controls
• Minimal flow reduction potential due to typical high utilization rate (nearly or greater than 100 percent)
• High uncertainty with respect to both conditions being amenable to variable flows, and the ability to retrofit pumps with variable frequency drives (which could necessitate complete replacement of pumps)

Due to VSP/VFDs being considered impractical and potentially infeasible, costs have not been developed at this time. If costs were to be estimated in the future, they would need to include the cost of variable frequency drives (if the existing pumps may be retrofitted) or new variable speed pumps (if the pumps cannot be retrofitted and need to be replaced in their entirety); a building complete with climate control for housing the drives; new power source and power distribution; instrumentation and controls; temperature and flow monitoring system upgrades and feedback logic to control the drives; direct and indirect construction costs; construction management; project management; permitting; a design change package to update existing plant drawings and specifications. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-134

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.7.2.4 Summary of Variable Speed Pumps Considering that PSL normally generates at full capacity and that there is no appreciable gap between historic data and permit limit, this evaluation concludes that PSL cannot reduce its circulating water flow in a meaningful way using VFDs/VSP to reduce entrainment. 10.8 Summary of Findings This report evaluated the following technologies as potential entrainment reduction measures at PSL to comply with the Final Rule:

• Closed-cycle recirculating cooling systems including:

o NDCT. o Standard MDCT. o Plume-abated MDCT. o Dry air-cooled condensers.

• Fine-mesh screen systems including:

o Fine-slot wedgewire screens located at a newly constructed offshore structure. o Fine-mesh modified traveling water screens allowing for a design through-screen velocity of 1.3 ft/sec with an organism return that relies on pumping.

• Alternate water sources and water reuse options.
• Other technologies, including:

o Location of velocity caps. o Entrainment reduction potential of variable speed pumps. 10.8.1 Summary of the Engineering Feasibility and Cost Findings Evaluation findings are summarized in Table 10-26. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-135

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-26. Summary of Findings Feasibility/Practicality Technology Key Reasoning for Finding Finding Closed-Cycle Recirculating Cooling System Design incompatibility. The approach to wet Natural draft cooling Infeasible bulb temperature is smaller than can be towers supported by a natural draft cooling tower. Impractical and Standard mechanical Most reasonable of CCRS options and evaluated potentially infeasible but draft cooling towers further. evaluated further Larger and costlier than standard MDCT. Plume-abated mechanical Impractical and Inferior to standard MDCT therefore not draft cooling towers infeasible evaluated further. Insufficient space, and unacceptable energy Air-cooled condensers Infeasible penalty. Fine-mesh Screens Major concerns regarding control of biofouling, debris, and sedimentation resulting in Narrow-slot wedgewire unacceptable headloss and impact to water Infeasible screens supply reliability. The potential for corrosion and habitat formation is also of concern. Capital and maintenance costs would be very high. Major retrofit of the intake canal would be necessary to achieve target through-screen velocities. This would be very costly to construct FM MTWS with a Impractical and and operate. Several issues related to reliability pumped organism return potentially infeasible given episodic debris and/or organism loading would require additional assessment to determine feasibility. Alternate Water Sources Reuse existing water No opportunities to reuse service water or Infeasible sources screenwash water. Replace existing surface Flowrates of alternate water sources are water source with Infeasible considered infeasible and impractical compared alternate reclaimed water to PSL DIF. or groundwater sources Flowrates of PSL and existing wells are Groundwater Infeasible considered infeasible and impractical compared to the Plants DIF. Other Entrainment Protection Measures Implemented and constructed to reduce Offshore velocity caps PSL already employs this technology impingement and entrainment Baseload Plant operating close to its permitted Impractical and heat load; no opportunity to reduce flow and still Variable speed pumps potentially infeasible support reliable operations and consistent compliance Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX040121 10-136

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) 10.8.2 Technologies Retained for Biological Efficacy and Impacts Evaluations Based on the summary in Table 10-26, technologies retained for biological and costing evaluations are listed in Table 10-27. Table 10-27. Technologies Retained for Further Evaluation Technology Retained for Further Evaluation Natural draft cooling towers No Mechanical draft cooling towers Yes Plume-abated mechanical draft cooling towers No Air-cooled condensers No Narrow-slot wedgewire screens No FM MTWS with a pumped organism return Yes Re-use existing water sources No Replace Atlantic Ocean water with other alternate No reclaimed water or groundwater sources Offshore velocity caps Implemented Variable speed pumps No Source: ECT, 2021. 10.8.3 Summary of Social Costs for Candidate Technologies Based on the information presented above, Veritas Economic Consulting calculated social costs of potential retrofit of PSL with closed-cycle cooling and with FMS as described in Appendix 10-A. Table 10-28 provides a summary comparison of the social costs for each candidate technology at both annual and net present value and a 3- and 7-percent discount rate. This feasibility evaluation found that cooling towers are either infeasible or impractical; fine-slot wedgewire screens are also infeasible; and fine-mesh traveling screens are impractical and potentially infeasible. There are no viable alternate water sources or additional water reuse options. Y:\GDP\F1301\150595\316BR\10.DOCX033121 10-137

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Table 10-28. Total Compliance and Social Costs of Feasible Technology Options at PSL Compliance Costs* (million $) Social Costs (Present Value) (million $) Discount Technology Electricity Price Increases Total Design, Government Total Annual Rate Type Annual Screen Full Fill Resulting from Externality Construction, and Regulatory Social Social O&M Costs Replacement§ Replacement£ Compliance Power Costs Installation Costs Costs Costs Costs Costs System Costs Closed-cycle

                                    $910.38         $13.39           N/A            $54.40         $714.72        $450.50         $56.22         $0.15       $1,221.59    $76.35 cooling retrofit 3%

Fine-mesh

                                    $113.81          $0.79          $1.50            N/A             $96.04          $2.66         $0            $0.02          $98.72     $6.17 screens Closed-cycle
                                    $910.38         $13.39           N/A            $54.40         $412.49        $266.38         $41.28         $0.11         $720.26    $45.02 cooling retrofit 7%

Fine-mesh

                                    $113.81          $0.79          $1.50            N/A             $55.32          $1.90         $0            $0.01          $57.23     $3.58 screens

• Undiscounted and in 2020 dollars.

Discounted at 3- and 7-percent using the specifications outlined in Appendix 10-A and in 2020 dollars. Numbers may not sum due to rounding. Average undiscounted value. The actual annual values are incorporated in social costs through the electricity price increases resulting from compliance costs. To avoid double-counting in the social cost analysis, the O&M portion of compliance costs does not include engineering estimates of parasitic load costs (e.g., costs to run pumps and fans for cooling towers) or costs from backpressure effects. Those costs are estimated in the power system modeling component of social costs and included in the electricity price increases resulting from power system costs. Annual closed-cycle cooling retrofit O&M costs presented in Table 10-28 are the average O&M costs calculated over the lifetime of the technology. §Specified to occur annually, with two screens being replaced each year. £Specified to occur in 2037. Include decreases in social wellbeing resulting from recreation and property value impacts. Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\10.DOCX040121 10-138

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant - FL0002208 40 CFR 122.21(r2) through (13) Appendix 10-A Social Costs of Purchasing and Installing Entrainment Reduction Technologies Y:\GDP\F1301\150595\316BR\10.DOCX033121

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 11.0 Benefits Valuation Study 40 CFR 122.21(r)(11) 11.1 Introduction and Background This section provides information on the incremental benefits of the candidate entrainment reduction technologies and operational measures evaluated in Section 10.0 using the entrainment characterization results presented in Section 9.0. The following is the text of 40 CFR 122.21(r)(11): The benefits valuation study must include, but is not limited to, the following elements: (i) Incremental changes in the numbers of individual fish and shellfish lost due to impingement and entrainments as defined in 40 CFR 125.92, for all life stages of each exposed species; (ii) Description of basis for any estimates of changes in the stock sizes or harvest levels of commercial and recreational fish or shellfish species or forage fish species; (iii) Description of basis for any monetized values assigned to changes in the stock size or harvest levels of commercial and recreational fish or shellfish species, forage fish and to any other ecosystem or non-use benefits; (iv) A discussion of mitigation efforts completed prior to October 14, 2014, including how long they have been in effect and how effective they have been; (v) Discussion, with quantification and monetization, where possible, of any other benefits expected to accrue to the environmental and local communities, including but not limited to improvements for mammals, birds, and other organisms and aquatic habitats; (vi) Discussion, with quantification and monetization, where possible, of any benefits expected to result from any reductions in thermal discharges from entrainment technologies. The methodology described in the following subsections is similar to that of EPA as presented in the Case Study Analysis for the Proposed Section 316(b) Phase II Existing Facilities Rule Part D: Tampa Bay Watershed Case Study document (EPA, 2002). The steps pursued during the analysis are described in Section 11.2. Y:\GDP\F1301\150595\316BR\11.DOCX 11-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 11.2 Review of Methods The estimation of benefits was a multistep process:

• Calculate incremental changes in entrained organisms annually.
• Convert incremental changes into equivalent adults (EAs) and foregone production, using commonly applied and accepted models.
• Transfer the foregone production of forage taxa to a commercially important finfish (Spanish mackerel [Scomberomorus maculatus]) using a trophic transfer model.
• Calculate equivalent yield of commercial/recreational C/R taxa by combining the foregone production of each C/R taxa with the trophic transferred foregone production of forage taxa.
• Monetize the changes in yield (recreational, commercial, and nonuse values).

The baseline losses estimated for PSL were calculated using the observed organism entrainment rates from each of the two study years, interpolated between samples using actual flows, and then annualized (Section 9.3). This process was followed to calculate the reductions in entrainment for retrofitting to closed-cycle cooling in the form of MDCT and for fine mesh screens. As noted in Section 10.0, alternative water supplies and variable speed pumps were determined to be infeasible and were not carried forward to the estimation of benefits. PSL currently employs a compliant IM BTA technology in the form of an offshore velocity cap (Section 6.0). 11.2.1 Incremental Changes in Fish and Shellfish Incremental changes in fish and shellfish entrainment were calculated by using the baseline losses and calculating the percent reduction in entrainment for CCRS and FMS. 11.2.1.1 Definition of Baseline Losses To quantify the loss of fish and shellfish due to the operation of PSL, a determination of the annual losses of fish and shellfish was calculated from the sample event densities observed at PSL and cooling water intake flow as detailed in Section 9.0. Presentation of this information addresses two functions in this report: Y:\GDP\F1301\150595\316BR\11.DOCX 11-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

• It provides a clear illustration of the methods used to estimate impacts and monetize their social benefit without confounding factors associated with the differential effectiveness of the additional entrainment technologies; and
• It illustrates the maximum potential social benefit associated with complete reduction in entrainment at PSL.

For this assessment and subsequent discussions, shellfish are defined to include crustaceans and mollusks, regardless of their C/R status. That is, shellfish with no C/R value but that may serve as forage have been considered in addition to direct losses of C/R species. Because of the potentially large proportion of forage shellfish that may be entrained at PSL and their potential contribution to the food web of commercially and recreationally important species, FPL believed it prudent to account for their losses and subsequent benefits with the application of each technology. 11.2.1.2 Entrainment Under Baseline Conditions Appendix 11-C provides estimated annualized baseline entrainment rates for the two study periods by taxa and life stage. The rate of entrainment of fish and shellfish (commercial, recreational, and forage) that occurs at PSL was calculated as follows: sample event densities (number per gallon) from each sample year (2006 and 2007 as Year 1, and 2017 to 2018 as Year

2) were independently interpolated between sample events and multiplied by the AIF for 2015 through 2018 for the interpolated sampling period.

11.2.1.3 Retrofit to Closed-cycle Cooling Retrofitting PSL with closed-cycle cooling is estimated to result in a 74 percent reduction in cooling water withdrawal (see Table 11-13 and calculations in Appendix 12-H) which will result in a commensurate reduction in entrainment. 11.2.1.4 Estimating the Efficacy of FMS The addition of FMS at PSL is assumed to reduce entrainment based on the rate of live return of those organisms excluded by the FMS. Exclusion efficiencies and survival off the screens were applied to the annual entrainment numbers calculated for PSL (Figure 11-1). Y:\GDP\F1301\150595\316BR\11.DOCX 11-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-1. Calculation Methodology of FMS Benefits Summary Y:\GDP\F1301\150595\316BR\11.DOCX 11-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Exclusion efficiencies () and post-exclusion survival were estimated based on site-specific measurements of entrained organisms as well as empirical data available from historical studies at Tampa Electrics Big Bend Units 3 and 4. While certain organism dimensions have been found to be predictive of the rate of exclusion relative to mesh size, such an approach was found to over-predict exclusion rates when compared to empirical data. This discrepancy is likely due to factors such as areas in the screens that allow organisms to pass through, through-screen velocity forcing organisms through mesh, and the orientation of the organism relative to the mesh opening. Exclusion of fish on a 0.5 mm screen using measured dimensions was estimated to be 100 percent, while fish exclusion based on the empirical data was estimated to be 70 percent. Similarly, invertebrate exclusion estimated using measured organism dimensions was 100 percent and based on empirical data was 87 percent. Separate empirical data for exclusion and post-exclusion survival were available for a variety of fish and shellfish taxa, as well as different life stages for the taxa. While the available data from Big Bend included most of the organisms entrained at PSL, surrogates were used to ensure that in no case was any entrained organism excluded from the analysis. Big Bend exclusion and survival data were chosen for use in this analysis based on availability, similarity of facility, and relative location in peninsular Florida. The exclusion portion of the Big Bend study included collecting organisms in front of and behind the FMS at Big Bend and calculating the estimated percent exclusion (Table 11-1). The survival portion of the study involved collecting organisms washed off the FMS at Big Bend Unit 4 into the screen return and recording the initial and 48 hours post-exclusion survival (Brueggemeyer et al., 1988). The average survival rates (or live return frequency) were calculated using the initial survival at the organism return discharge station values and applied at the family level (Table 11-2). Initial survival rates were chosen over the extended survival due to the limited number of taxa included in the extended survival analysis. Given that extended survival is most commonly less than initial survival, use of initial survival would tend to over-estimate benefits (see Section 11.5). Rates of exclusion and survival were calculated by taxa (i) and life stage (j), when possible. The combined taxa and life stage is referred to as Class (k). Y:\GDP\F1301\150595\316BR\11.DOCX 11-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-1. Average FMS Exclusion at Big Bend by Family and Life Stage Post- Family Family Egg Larvae Juvenile Adult Unknown larvae Average FISH Achiridae 77.2 64.2 73.5 70.0 71.2 Atherinidae 100.0 100.0 Atherinopsidae 86.7 100.0 93.3 Belonidae 100.0 100.0 Blenniidae 58.4 100.0 79.2 Carangidae 100.0 85.7 100.0 100.0 96.4 Clupeidae 16.7 100.0 40.5 52.4 Cynoglossidae 79.6 79.6 Diodontidae 100.0 100.0 Elopidae 100.0 100.0 Engraulidae 66.5 68.4 64.6 0.0 0.0 39.9 Ephippidae 81.1 0.0 40.5 Gerridae 100.0 100.0 Gobiesocidae 62.2 62.2 Gobiidae 58.8 25.0 20.0 34.6 Hameulidae 100.0 100.0 Microdesmidae 32.8 32.8 Monacanthidae 100.0 100.0 Polynemidae 50.0 50.0 Sciaenidae 77.4 61.7 77.5 33.3 33.3 56.6 Soleidae/Triglidae 99.6 99.6 Sparidae 100.0 100.0 Stromatidae 100.0 100.0 Syngnathidae 85.3 83.3 100.0 89.5 Tetraodontidae 75.0 75.0 Triglidae 76.9 40.1 33.3 50.1 Unidentified Fish 76.8 66.7 54.3 50.0 62.0 SHELLFISH Loliginidae 66.8 100.0 83.4 Penaeidae 100.0 100.0 Portunidae 100.0 100.0 Xanthoidea 81.2 0.0 40.6 Average 70.1 79.4 77.2 54.5 100.0 50.4 71.9 Source: Brueggemeyer et al., 1988. Y:\GDP\F1301\150595\316BR\11.DOCX 11-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-2. Average Family Survival of Organisms Excluded on FMS at Big Bend Post-Yolk-sac Egg Larvae/Zoea Family Average Family Larvae/Megalops (%) (%) (%) (%) Fish Blennidae 100 100 Clupeidae 49 0 25 Engraulidae 30 12 21 Gobiidae 0 0 Sciaenidae 40 29 33 Soleidae 62 0 31 Fish average 45 24 32 Shellfish Caridea 69 69 Grapsidae 95 76 86 Paguridae 78 78 Penaeidae 50 50 Pinnotheridae 83 83 Portunidae 100 100 Xanthoidea 88 80 84 Shellfish average 81 78 80 Source: Brueggemeyer et al., 1988. Because of the lack of empirical data on exclusion and survival for some taxa and life stages, weighted averages for exclusion were calculated based on family as well as genus, when possible. Exclusion and survival values were based on family groupings. If the average species value was based on less than five individuals, the family values were used. If no family values were available, the average fish and shellfish exclusion and survivability was applied. The rate of survival (Survival) of otherwise entrainable organisms is the product of their rate of exclusion for the class and the live return frequency by class:

      =  x The reduction in EM (annual estimated live return number per year) with the application of the FMS 1 was calculated by the product of the rate of Survival for the class and the sum of the product of the density of individuals in the class (Density) during the sampling period (l) and the AIF for the period:

1 Referred to in Figure 11-1 as the annual estimated live return. Y:\GDP\F1301\150595\316BR\11.DOCX 11-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13)

         =  x   x The exclusion rate and average survival rates for the taxa/life stage pairs and, when necessary, their surrogates, are provided in Table 11-3.

11.2.2 Basis for Estimates of Changes in Stock Size or Harvest Levels To quantify the benefits to aquatic organisms of a technology for comparison between technologies, the annual entrainment losses of C/R taxa were converted to EAs using the forward projection approach (EPRI, 2012). The forward projection approach uses the life history parameters of the taxa (i.e., growth rate and rate of survival) to estimate the number of individuals of the taxa to survive to a specific age as well as their mass at that age. For C/R taxa, the age of equivalence is defined for each surrogate taxon as described in Table 11-4. Table 11-4 summarizes the parameters used in the models while Appendix 11-A provides a summary of life history for each species. Prior to calculating the EAs and production foregone, surrogates were assigned to individual taxa if and when life-history parameters were not available for that taxa. Surrogates were selected based on taxonomic characteristics as well as considerations such as commercial or recreational importance. Table 11-5 summarizes the application of surrogates. Where a taxon either was not assigned to a specific surrogate or was unknown, the category fish or shellfish, as necessary, was used, and their annualized counts were applied to the identified surrogates based on the proportion of the surrogates to the total annualized count Unknown life stage numbers were distributed in the same manner across the life stages of the candidate surrogates. Thus, all organisms entrained and impinged have been accounted for in the benefits analysis. No group or individual was excluded for any reason. Appendix 11-C includes a table of annualized entrainment counts of surrogates for the baseline condition. Y:\GDP\F1301\150595\316BR\11.DOCX 11-8

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-3. Summary of Estimated Rate of Live Return Used in the Assessment of Benefits of FMS at PSL Estimated Live Return (%) Survival Exclusion Post-Species Larvae/ Unidenti-Surrogate Surrogate Egg Larvae/ Juvenile Adult Zoea fied Megalopa Fish Abudefduf saxatilis Fish Fish 3.31 Acanthostracion quadricornis Fish Fish 3.85 Achiridae Achiridae Achiridae 41.42 73.45 Achirus lineatus Achiridae Achiridae 41.42 64.19 73.45 Ahlia egmontis Fish Fish 3.31 Anchoa hepsetus Engraulidae Engraulidae 0.78 0.00 12.81 Anchoa mitchilli Bay anchovy Engraulidae 0.48 Anchoa spp. Bay anchovy Engraulidae 0.51 0.48 0.00 Anisotremus surinamensis Fish Hameulidae 5.11 Anisotremus virginicus Fish Hameulidae 5.11 5.11 Apogonidae Fish Fish 3.85 Atherinopsidae Atherinopsidae Atherinopsidae 25.05 Bairdiella chrysoura Fish Sciaenidae 11.84 14.88 23.35 Bathygobius soporator Gobiidae Gobiidae 0.00 0.00 Blenniidae Fish Fish 37.66 3.31 2.99 35.87 Blennioidei Fish Blenniidae 3.31 2.99 35.87 Bregmaceros atlanticus Fish Fish 38.18 Bregmaceros cantori Fish Fish 3.85 Bregmaceros houdei Fish Fish 3.31 3.85 Bregmaceros spp. Fish Fish 3.85 Bregmacerotidae Fish Fish 3.85 Brevoortia spp. Clupeidae Clupeidae 0.32 Callionymidae Fish Fish 3.85 Canthigaster rostrata Fish Tetraodontidae 3.84 Carangidae Fish Fish 37.66 32.67 28.00 Centropomus spp. Fish Fish 3.85 Centropomus undecimalis Fish Fish 3.31 3.85 Centropristis striata Fish Fish 38.18 Chaetodipterus faber Fish Ephippidae 2.07 4.15 Chloroscombrus chrysurus Fish Sciaenidae 32.67 28.00 23.35 Chromis spp. Fish Fish 3.31 Citharichthys gymnorhinus Fish Fish 3.85 Citharichthys spilopterus Fish Fish 3.85 38.18 Citharichthys spp. Fish Fish 3.31 3.85 Clupeidae Clupeidae Clupeidae 7.30 0.79 0.32 15.79 Clupeiformes Clupeidae Clupeidae 0.32 Congridae Fish Fish 3.85 Coryphopterus spp. Gobiidae Gobiidae 0.00 Ctenogobius boleosoma Gobiidae Gobiidae 0.00 Ctenogobius spp. Gobiidae Gobiidae 0.00 Cynoglossidae Fish Fish 3.31 3.85 Cynoscion regalis Cynoscion spp. Sciaenidae 12.17 Cynoscion spp. Cynoscion spp. Sciaenidae 12.17 Dactyloscopidae Fish Fish 3.31 3.85 Decapterus macarellus Sciaenidae Carangidae 28.00 Decapterus punctatus Sciaenidae Sciaenidae 20.15 Diodontidae Fish Diodontidae 5.11 Diplogrammus pauciradiatus Fish Fish 3.85 Doratonotus megalepis Fish Fish 38.18 Dormitator maculatus Gobiidae Gobiidae 0.00 0.00 Eleotridae Fish Fish 3.85 Elops saurus Fish Elopidae 5.11 Elops spp. Fish Elopidae 5.11 Y:\GDP\F1301\150595\316BR\11.DOCX 11-9

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-3. Summary of Estimated Rate of Live Return Used in the Assessment of Benefits of FMS at PSL (Continued, Page 2 of 5) Estimated Live Return (%) Survival Exclusion Post-Species Larvae/ Unidenti-Surrogate Surrogate Egg Larvae/ Juvenile Adult Zoea fied Megalopa Engraulidae Bay anchovy Engraulidae 28.81 0.83 0.48 24.20 Etropus crossotus Fish Fish 3.85 Etropus microstomus Fish Fish 3.85 Etrumeus teres Clupeidae Clupeidae 0.32 Eucinostomus spp. Fish Gerreidae 5.11 Exocoetidae Fish Fish 37.66 Gerreidae Fish Gerreidae 5.11 Gobiesox strumosus Gobiidae Gobiidae 0.00 Gobiidae Fish Gobiidae 18.58 0.00 0.00 Gobioides broussonnetii Gobiidae Gobiidae 0.00 Gobionellus oceanicus Gobiidae Gobiidae 0.00 Gobiosoma ginsburgi Seaboard goby Gobiidae 0.00 0.00 Gobiosoma robustum Gobiidae Gobiidae 0.00 Gobiosoma spp. Gobiidae Gobiidae 0.00 Gymnothorax spp. Fish Fish 3.31 Haemulidae Fish Fish 3.31 5.11 Haemulon plumierii Fish Hameulidae 5.11 Haemulon spp. Fish Hameulidae 5.11 Halichoeres spp. Labridae Fish 0.00 Harengula jaguana Clupeidae Clupeidae 0.32 Hemiramphidae Fish Fish 37.66 Hippocampus erectus Fish Syngnathidae 58.38 Hypleurochilus multifilis Fish Blenniidae 2.99 Labridae Fish Fish 37.66 0.00 Labrisomidae Fish Fish 3.31 3.85 Labrisomus nuchipinnis Fish Fish 38.18 Labroidei Fish Fish 3.85 Lachnolaimus maximus Fish Fish 3.85 Lagodon rhomboides Fish Sparidae 5.11 Leiostomus xanthurus Fish Sciaenidae 20.15 3.96 Lophiiformes Fish Fish 3.85 Lutjanidae Fish Fish 3.31 3.85 Lutjanus spp. Fish Fish 3.31 3.85 38.18 Lutjanus synagris Fish Fish 3.85 Megalops atlanticus Fish Fish 3.31 Menticirrhus americanus Menticirrhus spp. Sciaenidae 0.00 Menticirrhus littoralis Menticirrhus spp. Sciaenidae 0.00 Menticirrhus spp. Menticirrhus spp. Sciaenidae 0.00 0.00 Microdesmidae Fish Fish 1.68 38.18 Microdesmus bahianus Fish Fish 3.31 1.68 Microdesmus lanceolatus Fish Microdesmidae 1.68 Microdesmus longipinnis Fish Microdesmidae 1.68 Microdesmus spp. Fish Fish 3.31 1.68 Microgobius thalassinus Gobiidae Gobiidae 0.00 Micropogonias undulatus Sciaenidae Sciaenidae 20.15 25.32 Monacanthidae Fish Fish 3.85 Monacanthus ciliatus Fish Fish 3.85 Muraenidae Fish Fish 3.85 Myctophidae Fish Fish 3.85 Myrophis punctatus Fish Fish 3.31 3.85 38.18 Nes longus Gobiidae Fish 0.00 Ophichthidae Fish Fish 3.31 Ophidiidae Fish Fish 3.85 Y:\GDP\F1301\150595\316BR\11.DOCX 11-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-3. Summary of Estimated Rate of Live Return Used in the Assessment of Benefits of FMS at PSL (Continued, Page 3 of 5) Estimated Live Return (%) Survival Exclusion Post-Species Larvae/ Unidenti-Surrogate Surrogate Egg Larvae/ Juvenile Adult Zoea fied Megalopa Ophidion josephi Fish Fish 3.85 Ophidion selenops Fish Fish 3.85 Ophidion spp. Fish Fish 3.31 3.85 Orthopristis chrysoptera Fish Fish 3.31 5.11 Paralichthyidae Fish Fish 37.66 2.72 3.16 Paralichthys albigutta Pleuronectidae Fish 2.72 Paralichthys lethostigma Pleuronectidae Fish 3.16 Paralichthys oblongus Fish Fish 37.66 2.72 3.16 Paralichthys spp. Fish Fish 37.66 2.72 3.16 Pareques spp. Fish Sciaenidae 3.96 Pareques umbrosus Fish Sciaenidae 3.96 Perciformes Fish Fish 3.31 3.85 Pleuronectidae Soleidae Fish 43.39 Pleuronectiformes Soleidae Fish 43.39 Pogonias cromis Black drum Sciaenidae 33.25 Pomacentridae Fish Fish 37.66 3.31 3.85 Prionotus spp. Fish Triglidae 2.05 2.05 Psilotris alepis Gobiidae Gobiidae 0.00 Ptereleotris spp. Fish Microdesmidae 1.68 Rachycentron canadum Fish Fish 37.66 Rhynchoconger gracilior Fish Fish 3.31 Sardinella brasiliensis Clupeidae Clupeidae 0.32 Saurida brasiliensis Fish Fish 3.85 Scaridae Fish Fish 34.76 3.85 Scartella cristata Fish Blenniidae 2.99 Sciaenidae Sciaenidae Sciaenidae 45.58 20.15 25.32 Sciaenops ocellatus Sciaenidae Sciaenidae 20.15 25.32 Scombridae Fish Fish 3.31 3.85 Scorpaenidae Fish Fish 3.85 Scorpaeniformes Fish Fish 3.85 Selar crumenophthalmus Sciaenidae Carangidae 28.00 Selene setapinnis Sciaenidae Carangidae 76.10 Serraniculus pumilio Fish Fish 3.85 Serranidae Fish Fish 37.66 3.31 3.85 Serraninae Fish Fish 3.85 Sparidae Fish Sparidae 5.11 5.11 Sphoeroides maculatus Fish Tetraodontidae 3.84 Sphoeroides nephelus Fish Tetraodontidae 52.54 Sphoeroides spp. Fish Tetraodontidae 3.84 3.84 52.54 Sphoeroides testudineus Fish Tetraodontidae 3.84 Sphyraena barracuda Fish Fish 38.18 Sphyraena spp. Fish Fish 3.31 Stellifer lanceolatus Sciaenidae Sciaenidae 20.15 25.32 Symphurus plagiusa Fish Cynoglossidae 4.07 Symphurus spp. Fish Cynoglossidae 4.07 Syngnathus louisianae Fish Syngnathidae 58.38 Syngnathus spp. Fish Syngnathidae 70.05 Synodontidae Fish Fish 37.66 3.31 3.85 Synodus foetens Fish Fish 15.03 38.18 Tetraodontidae Fish Tetraodontidae 3.84 3.84 Tetraodontiformes Fish Tetraodontidae 3.84 Thalassoma bifasciatum Fish Fish 37.66 Triglidae Fish Triglidae 2.05 Y:\GDP\F1301\150595\316BR\11.DOCX 11-11

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-3. Summary of Estimated Rate of Live Return Used in the Assessment of Benefits of FMS at PSL (Continued, Page 4 of 5) Estimated Live Return (%) Survival Exclusion Post-Species Larvae/ Unidenti-Surrogate Surrogate Egg Larvae/ Juvenile Adult Zoea fied Megalopa Trinectes maculatus Pleuronectidae Achiridae 2.70 Umbrina coroides Fish Sciaenidae 3.96 Unidentified Fish Fish 41.23 3.41 2.78 37.58 Unidentified eggs Fish Fish 41.23 Unidentified fish Fish Fish 3.31 3.85 41.98 Shellfish Acetes americanus Shellfish Invertebrate 96.70 Acetes spp. Shellfish Invertebrate 96.70 70.68 Albunea spp. Shellfish Invertebrate 79.84 Alpheidae Shellfish Invertebrate 79.84 Alpheus heterochaelis Shellfish Invertebrate 70.68 Alpheus spp. Shellfish Invertebrate 79.84 79.84 Anomura Shellfish Invertebrate 79.84 83.14 96.70 Arcidae Shellfish Invertebrate 96.70 Arenaeus cribrarius Shellfish Portunidae 96.70 Axiidea Shellfish Invertebrate 79.84 Bivalvia Shellfish Invertebrate 96.70 96.70 70.68 Brachyura (Non-CRI) Shellfish Invertebrate 79.84 83.14 96.70 96.70 Callianassa spp. Caridea Invertebrate 71.23 Callianassidae Caridea Invertebrate 71.23 Callinectes spp. Blue crab Portunidae 100.00 83.14 96.70 Cardiidae Shellfish Invertebrate 96.70 Caridea Caridea Invertebrate 71.23 83.14 96.70 96.70 Clibanarius vittatus Shellfish Invertebrate 79.84 Decapoda Shellfish Invertebrate 79.84 Dissodactylus spp. Shellfish Invertebrate 79.84 Emerita spp. Shellfish Invertebrate 79.84 83.14 70.68 Emerita talpoida Shellfish Invertebrate 79.84 Eualus spp. Shellfish Invertebrate 96.70 Euphausiacea Shellfish Invertebrate 79.84 96.70 Farfantepenaeus aztecus Shellfish Penaeidae 91.77 83.14 Farfantepenaeus duorarum Shellfish Penaeidae 91.77 83.14 Farfantepenaeus spp. Shellfish Penaeidae 91.77 83.14 96.70 Gebiidea Shellfish Invertebrate 79.84 83.14 Gonodactyloidea Shellfish Invertebrate 83.14 Hippolyte spp. Shellfish Invertebrate 79.84 83.14 96.70 96.70 70.68 Hippolytidae Shellfish Invertebrate 83.14 Latreutes spp. Shellfish Invertebrate 79.84 Lepidopa benedicti Shellfish Invertebrate 79.84 Lepidopa spp. Shellfish Invertebrate 79.84 Lepidopa websteri Shellfish Invertebrate 79.84 Leptochela spp. Shellfish Invertebrate 79.84 Libinia dubia Shellfish Invertebrate 83.14 70.68 Libinia spp. Shellfish Invertebrate 83.14 Loliginidae Shellfish Invertebrate 61.33 96.70 Lucifer faxoni Shellfish Invertebrate 79.84 70.68 Lucifer spp. Shellfish Invertebrate 79.84 70.68 Lysiosquilloidea Shellfish Achiridae 58.91 Lysmata spp. Shellfish Invertebrate 79.84 83.14 Mactridae Shellfish Invertebrate 96.70 96.70 70.68 Menippe mercenaria Xanthidae Xanthoidea 76.19 Menippe nodifrons Xanthidae Xanthoidea 76.19 Menippe spp. Xanthidae Xanthoidea 76.19 Y:\GDP\F1301\150595\316BR\11.DOCX 11-12

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-3. Summary of Estimated Rate of Live Return Used in the Assessment of Benefits of FMS at PSL (Continued, Page 5 of 5) Estimated Live Return (%) Survival Exclusion Post-Species Larvae/ Unidenti-Surrogate Surrogate Egg Larvae/ Juvenile Adult Zoea fied Megalopa Mysida Shellfish Invertebrate 83.14 96.70 96.70 Mytilidae Shellfish Invertebrate 96.70 96.70 Naushonia crangonoides Shellfish Invertebrate 79.84 Ovalipes spp. Shellfish Portunidae 91.77 Paguridae Shellfish Invertebrate 79.84 Pagurus longicarpus Shellfish Invertebrate 79.84 70.68 Pagurus spp. Shellfish Invertebrate 79.84 70.68 Palaemonetes spp. Shellfish Invertebrate 79.84 Panopeidae Shellfish Invertebrate 79.84 83.14 96.70 70.68 Penaeidae Shellfish Penaeidae 91.77 83.14 96.70 Penaeus spp. Shellfish Penaeidae 91.77 Pilumnus sayi Shellfish Invertebrate 96.70 Pilumnus spp. Shellfish Xanthoidea 81.68 38.41 Pinnixa spp. Shellfish Invertebrate 70.68 Pinnotheridae Shellfish Invertebrate 79.84 83.14 96.70 Porcellanidae Shellfish Invertebrate 79.84 96.70 Portunidae Shellfish Invertebrate 91.77 96.70 Portunus gibbesii Shellfish Invertebrate 96.70 Portunus spp. Shellfish Invertebrate 96.70 Rimapenaeus constrictus Shellfish Penaeidae 91.77 83.14 Rimapenaeus spp. Shellfish Penaeidae 96.70 Sergestidae Shellfish Invertebrate 79.84 Sergestoidea Shellfish Invertebrate 79.84 83.14 96.70 96.70 Solecurtidae Shellfish Invertebrate 96.70 Solenocera spp. Shellfish Invertebrate 79.84 Squilla empusa Shellfish Invertebrate 79.84 83.14 96.70 Squilla spp. Shellfish Invertebrate 83.14 Squilloidea Shellfish Invertebrate 79.84 83.14 Tellinidae Shellfish Invertebrate 96.70 Thalassinidea Shellfish Invertebrate 79.84 83.14 96.70 Thor spp. Shellfish Invertebrate 79.84 83.14 96.70 96.70 Tozeuma spp. Shellfish Invertebrate 79.84 83.14 Uca spp. Shellfish Invertebrate 79.84 83.14 Unidentified crab Shellfish Invertebrate 79.84 83.14 70.68 Unidentified meroplankton Shellfish Invertebrate 79.84 96.70 70.68 Unidentified shrimp Shellfish Invertebrate 79.84 70.68 Upogebia affinis Shellfish Invertebrate 79.84 Upogebia spp. Shellfish Invertebrate 79.84 Veneridae Shellfish Invertebrate 83.14 96.70 Zaops spp. Shellfish Invertebrate 79.84 Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX 11-13

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-4. Biological Model Surrogate Taxa Life History Parameters Total Fishing Stage Common Trophic Stage Mortality  %  % Fecundity (n Start Taxa Status Lifestage Duration References Rationale for age of equivalence Name Level Mortality (per Mature Female per year) Weight (g) (d) (per stage) stage) FISH Egg 1.384 0 8 0% 50% - 2.21E-04 Larvae 3.096 0 36 0% 50% - 7.40E-04 Menidia Atlantic EPRI, 2012 Forage 3.19 Juvenile 3.21 0 321 0% 50% - 0.05 Age when 100% mature menidia silverside EPA, 2002 1 0.013 0 365 100% 50% 5,000 7.2 2 0 0 0 100% 50% 5,000 16 Egg 1.05 0 1 0% 50% - 7.83E-07 Prolarvae 1.57 0 2 0% 50% - 8.42E-06 Postlarvae 1 2.11 0 11 0% 50% - 4.21E-05 Postlarvae 2 (10-20) 4.04 0 21 0% 50% - 2.09E-03 Juvenile 1 (20-30) 0.08 0 21 0% 50% - 0.023 Anchoa Bay Forage 3.46 Juvenile 2 (30-40) 0.09 0 22 0% 50% - 0.090 EPRI, 2012 Age when 100% mature mitchilli anchovy Juvenile 3 (40-50) 0.13 0 33 0% 50% - 0.24 Juvenile 4 (50-60) 1.00 0 254 0% 50% - 0.52 1 1.62 0 365 100% 50% 38,206 0.91 2 1.62 0 365 100% 50% 38,206 1.63 3 1.62 0 365 100% 50% 38,206 1.85 Egg 0.96 0 3 0% 50% - 5.74E-05 Early larval 1.92 0 12 0% 50% - 5.74E-05 Late larval 2.81 0 78 0% 50% - 0.0008 Early juvenile 1.20 0 92 0% 50% - 0.10 Late juvenile 2.38 0 180 0% 50% - 22.7 1 1.39 0 365 0% 50% - 65.4 EPRI, 2012 Brevoortia Atlantic Age of equivalence is age of high fishing Forage 3.2 2 1.35 0 365 12% 50% - 195.5 EPA, 2002 tyrannus menhaden mortality 3 1.57 0 365 85% 50% 22,139 331.9 ASMFC 2019 (fishing mortality) 4 1.32 0 365 100% 50% 37,388 445.3 5 1.00 0 365 100% 50% 51,097 531.6 6 0.88 0 365 100% 50% 62,051 594.1 7 0.88 0 365 100% 50% 62,051 641.4 8 0.880 0 365 100% 50% 62,051 675 Egg 2.69 0 1.2 0% 50% - 5.0E-5 Larvae 2.80 0 34 0% 50% - 5.00E-05 Juvenile 2.35 0 329.6 0% 50% - 5.0E-3 1 0.88 0 365 0% 50% - 4.00 Trinectes EPRI, 2012 Hogchoker Forage 3.4 2 0.88 0 365 100% 50% 7,579 18.00 Age when 100% mature maculatus EPA, 2002 3 0.88 0 365 100% 50% 11,822 27.00 4 0.88 0 365 100% 50% 20,146 47.00 5 0.88 0 365 100% 50% 29,205 68.00 6(_max) 0.88 0 365 100% 50% 37,295 86.00 Egg 0.63 0 1.1 0% 50% - 4.70E-05 Yolk sac larvae 0.38 0 3.4 0% 50% - 4.70E-05 Post-yolk sac larvae 1.30 0 20 0% 50% - 4.70E-05 Juvenile 2.51 0 340.5 0% 50% - 5.30E-02 Gerriedae Mojarra Forage 3.03 1 1.5 0 365 100% 50% 100,000 30.90 EPRI, 2012 Age when 100% mature 2 1.5 0 365 100% 50% 100,000 48.60 3 1.5 0 365 100% 50% 100,000 67.70 4 1.5 0 365 100% 50% 100,000 87.00 5 1.5 0 365 100% 50% 100,000 105.60 Y:\GDP\F1301\150595\316BR\11.DOCX 11-14

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-4. Biological Model Surrogate Taxa Life History Parameters (Continued, Page 2 of 4) Total Fishing Stage Stage Common Trophi Mortality  %  % Fecundity (n Start Taxa Status Lifestage Mortality Duration References Rationale for age of equivalence Name c Level (per Mature Female per year) Weight (g) (per (d) stage) stage) Egg 0.09 0 5 0% 50% - 1.0E-04 Larvae 0.54 0 31 0% 50% - 1.0E-04 Juvenile 5.74 0 329 0% 50% - 0.009 Gobiosoma Naked Forage 3.2 1 1.93 0 365 100% 50% 904 0.050 EPRI, 2012 Age when 100% mature bosc goby 2 1.93 0 365 100% 50% 1,419 0.14 3 1.93 0 365 100% 50% 2,207 0.37 4 (A_max) 1.93 0 365 100% 50% 3,157 0.77 Egg 3.02 0 1.6 0% 50% - 3.60E-05 Prolarvae 1.42 0 3.2 0% 50% - 3.60E-05 Postlarvae 6.09 0 18.5 0% 50% - 1.70E-04 Juvenile 2.89 0 237.2 0% 50% - 29.55 Drums and Commercial/ Sciaenidae 4.21 1 1.14 0.028 288.5 90% 50% 541,880 74.50 EPRI, 2012 Age of highest fishing mortality croakers Recreational 2 1.16 0.1355 365 100% 50% 1,156,310 161.00 3 1.21 0.268 365 100% 50% 1,809,316 263.00 4 1.285 0.218 365 100% 50% 2,499,391 381.00 5 (A_max) 0.56 0.177 365 100% 50% 243,829 1050.00 Egg 4.18 0 1.2 0% 50% - 4.70E-05 Yolk sac larvae 1.12 0 3.4 0% 50% - 4.70E-05 Post-yolk sac larvae 4.20 0 20 0% 50% - 4.70E-05 Bairdiella Silver Juvenile 3.78 0 343.4 0% 50% - 5.30E-02 Forage 3.2 EPRI, 2012 Age when 100% mature chrysoura perch 1 2.01 0 365 100% 50% 1,079,186 29 2 2.01 0 365 100% 50% 2,294,933 62 3 2.01 0 365 100% 50% 3,568,181 96 4 2.01 0 365 100% 50% 4,880,269 132 Egg 1.01 0 2 0% 50% - 3.60E-05 Early larvae 1.30 0 3 0% 50% - 3.60E-05 Late larvae 6.13 0 17 0% 50% - 1.70E-04 Early juvenile 2.36 0 131 0% 50% - 0.01 Late juvenile 1.22 0 212 0% 50% - 59.1 1 0.56 0.028 365 90% 50% 4,574 120 2 0.56 0.1355 365 100% 50% 17,686 260 3 0.56 0.268 365 100% 50% 50,451 430 Cynoscion Commercial/ FWC, 2011. Weakfish 3.77 4 0.56 0.218 365 100% 50% 118,512 630 Age of maximum fishing mortality regalis Recreational EPRI, 2012. 5 0.56 0.177 365 100% 50% 243,829 1050 6 0.56 0.1265 365 100% 50% 455,727 1610 7 0.56 0.123 365 100% 50% 790,330 2980 8 0.56 0.123 365 100% 50% 1,293,948 4920 9 0.56 0.123 365 100% 50% 2,015,934 5000 10 0.56 0.123 365 100% 50% 3,031,887 5680 11 0.56 0.123 365 100% 50% 4,407,990 5800 12 (A_max) 0.56 0.123 365 100% 50% 6,229,687 6000 Y:\GDP\F1301\150595\316BR\11.DOCX 11-15

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-4. Biological Model Surrogate Taxa Life History Parameters (Continued, Page 3 of 4) Total Fishing Stage Stage Start Common Trophi Mortality  %  % Fecundity Taxa Status Lifestage Mortality Duration Weight References Rationale for age of equivalence Name c Level (per Mature Female (n per year) (per (d) (g) stage) stage) Eggs 2.39 0 0% 50% 0 Larvae 10.6 0 0% 50% 0 Juvenile 0.916 0 95% 50% 0 1 0.52 0 365 100% 50% 140 2 0.62 0.25 365 100% 50% 232 3 0.62 0.25 365 100% 50% 290 4 0.62 0.25 365 100% 50% 341 Scomberom 5 0.62 0.25 365 100% 50% 375 EPA, 2006 Spanish Commercial/ orus 4.53 6 0.62 0.25 365 100% 50% 417 SEDAR, 2012 Age when fishing mortality begins mackerel Recreational maculatus 7 0.62 0.25 365 100% 50% Between 463 ICCAT, 2006 8 0.62 0.25 365 100% 50% 26,057 and 499 9 0.62 0.25 365 100% 50% 149,736 513 10 0.62 0.25 365 100% 50% 522 11 0.62 0.25 365 100% 50% 554 12 0.62 0.25 365 100% 50% 554 13 0.62 0.25 365 100% 50% 554 14 0.62 0.25 365 100% 50% 554 INVERTEBRATES Egg and zoea 4.12 0 28 0% 50% - 5.70E-05 Birkley and Gulliksen, 2003 Anomuran Megalopa 2.50 0 17 0% 50% - 0.013 Diaz, 1980; Rees, 1959 Anomura Forage 2.6 Age when 100% mature crabs Juvenile 3.36 0 255 0% 50% - 0.10 Ricciardi and Bourget, 1998 Adult (max) 3.00 0 300 100% 50% 1,491 0.50 Petracco et al., 2003; Edritanti et al., 2016 Eggs 0.03 0 12 0% 50% - 2.05E-05 NOAA, 1984 Callinectes Commercial/ Zoea and megalopae 14.80 0 40 0% 50% - 7.60E-05 Kannupandi et al., 1999. Age of equivalence chosen as earliest age Blue crab 4 sapidus Recreational Juvenile 7.34 0 313 0% 50% - 0.010 PSEG, 1999 of maximum fishing mortality Adult (max) 1.13 0.45 330 100% 50% 5,500,000 177.50 EPRI, 2012 Eggs and Zoea 2.03 0 11.5 0% 50% - 7.60E-05 Megalopae 3.17 0 17.8 0% 50% - 2.10E-04 EPRI, 2012; Dame and Vernberg, 1982; Juvenile 3.54 0 336 0% 50% - 0.35 Welch and Epifanio, 1995; Epifanio et al., 1 0.51 0 365 100% 50% 11,700 2.50 1994; Murphy et al., 2007; Sastry, 1970; Brachyuran Brachyura Forage 2.6 2 0.51 0 365 100% 50% 11,700 4.60 Lin, 1990; Epifanio, 1971; McDonald, Age when 100% mature crabs 3 0.51 0 365 100% 50% 11,700 13.90 1982; Epifanio et al., 1991; Birkely and 4 0.51 0 365 100% 50% 11,700 25.00 Gulliksen, 2003; McKinney et al., 2004; 5 0.51 0 365 100% 50% 11,700 40.00 Peterson and Wroblewski, 1984 6(_max) 0.51 0 365 100% 50% 11,700 60.00 Eggs and Larvae 4.34 0 16 0% 50% - 5.86E-06 Peterson and Wroblewski, 1984; Schultze Grass and Anger 1997; Provenzano et al., 1978; Caridea Forage 2.6 Post-Larvae/Juvenile 0.75 0 30 0% 50% - 0.006 Age when 100% mature shrimp Birkley and Gulliksen, 2003; Anderson, Adult 4.64 0 330 100% 66% 31 0.13 1985; Welsh, 1975 Y:\GDP\F1301\150595\316BR\11.DOCX 11-16

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-4. Biological Model Surrogate Taxa Life History Parameters (Continued, Page 4 of 4) Total Fishing Stage Common Trophic Stage Mortality  %  % Fecundity Start Taxa Status Lifestage Duration References Rationale for age of equivalence Name Level Mortality (per Mature Female (n per year) Weight (g) (d) (per stage) stage) Eggs 3.57 0 1.5 0% 50% - 7.60E-06 Pink shrimp harvested as adults outside of estuaries and adult stage is therefore set as age of equivalence Prolarvae 1.89 0 9.5 0% 50% - 5.70E-05 since this is when they contribute to fishery. Fishing EPRI, 2012; Kasper, 2017; pressure appears to be greatest as pre-adults, Postlarvae 1.89 0 15 0% 50% - 8.00E-04 Birkely and Gulliksen, 2003; Penaeid Commercial Commercial/ because fishing mortality value is a consequence of 3 Franco et. al., 2006; shrimp shrimp Recreational Juvenile 1.74 0 56 0% 50% - 0.0053 assigning same daily fishing mortality as daily Ramirez-Rodriquez and natural mortality (EPRI, 2012) and balancing. Since Arreguin-Sanchez, 2003 Pre-adult 3.88 3.50 125 0% 50% - 2.50 subadult experience greatest natural mortality, under stated assumptions for modelling purposes, Adults 0.16 0.14 323 100% 50% 3,571,429 6.60 they also experience greatest fishing mortality. Egg and Zoea 1 1.93 0.000 4 0% 50% - 4.58E-05 Zoea 2 1.93 0.000 4 0% 50% - 1.89E-04 Zoea 3 1.93 0.000 4 0% 50% - 4.94E-04 Zoea 4 1.93 0.000 4 0% 50% - 1.03E-03 EPA, 2002; Croker, 1962; Recruitment to the Florida fishery occurs at age 3 Starck, 1971; Claro-Madruga and for males and age 4 for females (based on CW and Zoea 5 1.93 0.000 4 0% 50% - 1.84E-03 Menippe Commercial/ Bustamete Pola, 1977; Porter, associated claw size). Age of equivalence of age 3 Stone crab 2.6 Megalopae 1.93 0.000 5 0% 50% - 3.00E-03 mercenaria Recreational 1960, Binford, 1913, Noe, 1967 was chosen since this is the age that 50% are Juvenile 1.93 0.000 297 0% 50% - 8.26E-03 ADW, 2017; McKinney et al. vulnerable to the fishery and all have reached 1 0.94 0.000 365 0% 50% - 16.50 2004; Gerhart and Bert, 2008. maturity. 2 0.94 0.000 365 100% 50% 2,512,500 86.31 3 1.31 0.376 365 100% 50% 2,512,500 184.89 4+ (A_max) 1.69 0.751 365 100% 50% 2,512,500 330.32 Shading indicates EA age used in the models. Sources: EPRI, 2012. EPA, 2002. Sea Around Us, 2017. ECT, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX 11-17

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-5. Modeling Surrogate Taxa Surrogate Scientific Name Common Name Brevoortia spp. Menhaden Clupeidae Herring (family) Atlantic menhaden Harengula jaguana Scaled herring Sardinella brasiliensis Orangespot sardine Atlantic silverside Atherinopsidae Silverside (family) Anchoa hepsetus Broad-striped anchovy Anchoa mitchilli Bay anchovy Bay anchovy Anchoa spp. Anchovy (genus) Clupeiformes Anchovies and herrings (order) Engraulidae Anchovy (family) Abudefduf saxatilis Sergeant major Acanthostracion quadricornis Scrawled cowfish Apogonidae Cardinalfish (family) Bregmaceros cantori Striped codlet Bregmaceros spp. Codlet Bregmacerotidae Codlets (family) Callionymidae Dragonet (family) Canthigaster rostrata Sharpnose puffer Centropomus spp. Snook spp. Centropomus undecimalis Common snook Chaetodipterus faber Atlantic spadefish Chromis spp. Chromis Congridae Conger eels (family) Cynoglossidae Tonguefish Diodontidae Burrfish (family) Diplogrammus pauciradiatus Spotted dragonet Doratonotus megalepis Dwarf wrasse Elops saurus Ladyfish Fish Elops spp. Ladyfish species Exocoetidae Flyingfish (family) Gymnothorax spp. Morays Halichoeres spp. Wrasse Hippocampus erectus Lined seahorse Labridae Wrasse (family) Labrisomus nuchipinnis Hairy blenny Labroidei Cichlids and surfperches (suborder) Lachnolaimus maximus Hogfish Lagodon rhomboides Pinfish Lophiiformes Anglerfish (order) Megalops atlanticus Atlantic tarpon Monacanthidae Filefish (family) Monacanthus ciliatus Fringed filefish Myctophidae Lanternfish (family) Myrophis punctatus Speckled worm eel Ophichthidae Snake eel (family) Ophidiidae Cusk eels (family) Ophidion josephi Crested cusk eel Y:\GDP\F1301\150595\316BR\11.DOCX 11-18

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-5. Modeling Surrogate Taxa (Continued, Page 2 of 5) Surrogate Scientific Name Common Name Ophidion selenops Mooneye cusk-eel Ophidion spp. Cusk-eel (genus) Perciformes Perch-like fishes (order) Pomacentridae Damselfish (family) Prionotus spp. North American searobin Rachycentron canadum Cobia Rhynchoconger gracilior Whiptail conger Saurida brasiliensis Brazilian lizardfish Scaridae Parrotfish (family) Scombridae Mackerel (family) Scorpaenidae Scorpionfishes and allies Scorpaeniformes Mail-cheeked fishes (order) Sparidae Porgy (family) Sphoeroides maculatus Northern puffer Sphoeroides nephelus Southern puffer Fish Sphoeroides spp. Pufferfish spp. Sphoeroides testudineus Checkered puffer Sphyraena barracuda Great barracuda Sphyraena spp. Barracuda (genus) Syngnathus louisianae Chain pipefish Synodontidae Lizardfishes Synodus foetens Inshore lizardfish Tetraodontidae Pufferfish (family) Tetraodontiformes Filefish (order) Thalassoma bifasciatum Bluehead Triglidae Searobin (family) Unidentified eggs Unidentifiable eggs Unidentified fish Unidentifiable fish Achiridae Scrawled sole (family) Achirus lineatus Lined sole Citharichthys gymnorhinus Angelfin whiff Citharichthys spilopterus Bay whiff Citharichthys spp. Whiff (genus) Etropus crossotus Fringed flounder Etropus microstomus Smallmouth flounder Paralichthyidae Flounder (family) Hogchoker Paralichthys albigutta Gulf flounder Paralichthys lethostigma Southern flounder Paralichthys oblongus Fourspot flounder Paralichthys spp. Largetooth flounders Pleuronectidae Righteye flounders (family) Symphurus plagiusa Blackcheek Tonguefish Symphurus spp. Tonguefishes (family) Eucinostomus spp. Mojarra (genus) Mojarra Gerreidae Mojarra (family) Y:\GDP\F1301\150595\316BR\11.DOCX 11-19

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-5. Modeling Surrogate Taxa (Continued, Page 3 of 5) Surrogate Scientific Name Common Name Bathygobius soporator Frillfin goby Blenniidae Combtooth blenny (family) Blennioidei Blenny (suborder) Coryphopterus spp. Goby species Ctenogobius boleosoma Darter goby Ctenogobius spp. True goby Dactyloscopidae Stargazer (family) Dormitator maculatus Fat sleeper Eleotridae Sleeper (family) Gobiesox strumosus Skilletfish Gobiidae Goby (family) Gobioides broussonnetii Violet goby Gobionellus oceanicus Highfin goby Naked goby Gobiosoma ginsburgi Seaboard goby Gobiosoma robustum Code goby Gobiosoma spp. Naked gobies Hypleurochilus multifilis Featherduster blenny Labrisomidae Labrisomid blenny (family) Microdesmidae Dartfish (family) Microdesmus bahianus Bahaia wormfish Microdesmus lanceolatus Lancetail wormfish Microdesmus longipinnis Pink wormfish Microdesmus spp. Wormfish Microgobius thalassinus Green goby Nes longus Orangespotted goby Scartella cristata Molly miller Anisotremus surinamensis Black margate Anisotremus virginicus Porkfish Carangidae Jack (family) Centropristis striata Black sea bass Chloroscombrus chrysurus Atlantic bumper Decapterus macarellus Mackerel scad Decapterus punctatus Round scad Haemulidae Grunt (family) Haemulon plumierii Grunt Haemulon spp. Grunt Sciaenidae Hemiramphidae Halfbeak (family) Leiostomus xanthurus Spot Lutjanidae Snapper (family) Lutjanus spp. Snapper (genus) Lutjanus synagris Lane snapper Menticirrhus americanus Southern kingfish Menticirrhus littoralis Gulf kingfish Menticirrhus spp. Kingfish Micropogonias undulatus Atlantic croaker Orthopristis chrysoptera Pigfish Pareques spp. Paraques genus Y:\GDP\F1301\150595\316BR\11.DOCX 11-20

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-5. Modeling Surrogate Taxa (Continued, Page 4 of 5) Surrogate Scientific Name Common Name Pareques umbrosus Cubbyu Sciaenidae Drum (family) Sciaenops ocellatus Red drum Selar crumenophthalmus Bigeye scad Sciaenidae Serraniculus pumilio Pygmy sea bass Serraninae Subfamily of groupers Stellifer lanceolatus American stardrum Umbrina coroides Sand drum Silver perch Bairdiella chrysoura Silver perch Cynoscion regalis Weakfish Weakfish Cynoscion spp. Seatrout Anomuran crabs Anomura Anomuran crab (non-Thalassinidea) Arenaeus cribrarius Speckled swimming crab Callinectes spp. Swimming crab (Callinectes genus) Decapoda Decapod crabs (order) Blue crab Portunidae Portunid crab (family) Portunus gibbesii Iridescent swimming crab Portunus spp. Portunid crab (genus) Albunea spp. Mole crab Brachyura (Non-CRI) Brachyuran crab (infraorder) Dissodactylus spp. Pea crab (Dissodactylus genus) Brachyuran crabs Emerita spp. Sand crab Lepidopa benedicti Mole crab Lepidopa spp. Mole crab Lepidopa websteri A sand crab Axiidea Ghost shrimps (infraorder Axiidea) Caridea Caridean shrimp Euphausiacea Krill (order) Grass shrimp Mysida Opossum shrimp (order) Sergestoidea Sergestoid shrimp Thalassinidea Ghost and mud shrimp (infraorder) Arcidae Arc clam (family) Bivalvia Bivalve Cardiidae Cockle Emerita talpoida Common mole crab Loliginidae Loliginid squid (family) Mactridae Surf clam (family) Shellfish Mytilidae Mussel (family) Solecurtidae Saltwater clams Tellinidae Tellin clam Unidentified crab Unidentifiable crab Unidentified meroplankton Unidentifiable meroplankton Veneridae Venus clams Farfantepenaeus aztecus Brown shrimp Farfantepenaeus duorarum Pink shrimp Penaeid shrimp Farfantepenaeus spp. Panaeid shrimp (Farfantepenaeus genus) Gebiidea Burrowing shrimps (infraorder Gebiidea) Y:\GDP\F1301\150595\316BR\11.DOCX 11-21

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-5. Modeling Surrogate Taxa (Continued, Page 5 of 5) Surrogate Scientific Name Common Name Gonodactyloidea Gonodactylid mantis shrimps (superfamily) Lysiosquilloidea Lysiosquillid mantis shrimps (superfamily) Penaeidae Penaeid shrimp (family) Penaeid shrimp Rimapenaeus constrictus Roughneck shrimp Solenocera spp. A Solenocerid shrimp Squilla empusa Mantis shrimp Squilloidea Mantis shrimp (superfamily) Menippe mercenaria Florida stone crab Stone crab Menippe spp. Stone crab Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX 11-22

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Foregone production of biomass for each sample year for each surrogate taxon was also calculated using Ragos (1984) model as described by EPRI (2012). The biomass of unknown taxa was accounted for through the dispersion of their counts across the other surrogate taxa as described previously. The life history parameters used in the EA model and production foregone models were largely based on parameters presented in EPRI (2012). However, because of errors observed for some models, rebalancing 2 of the parameters was needed in some cases. In addition, some species were not covered adequately by EPRI (2012) (i.e., stone crab, blue crab, caridean shrimp, brachyuran crabs, anomuran crabs, penaeid shrimp, and Spanish mackerel), so life history parameters were provided by other sources and, when necessary, balanced appropriately. Life history parameters do not assume any density dependence. Thus, as the population increases, it is able to do so unhindered by the number of individuals in the population. Similarly, if the populations sizes are below the systems capacity, the rate of survival and recruitment does not exhibit compensation to exploit that capacity. This is clearly not how ecosystems function; however, it provides a method of accounting for changes in populations that is useful for this type of assessment and supported by EPA (2002). To analyze the benefit of each proposed technology carried forward from Section 10, the total benefit that would be observed if there were no entrainment at PSL was calculated (without-entrainment). In this case, benefit is defined as the addition of C/R taxa that would occur because of the complete survival of the entrained and impinged fish and shellfish at PSL. The first step was to transfer the kilograms of production foregone of forage fish and invertebrate surrogate taxa to the C/R taxa that occur within the nearshore Atlantic Ocean and have recorded landings in St. Lucie County. For entrainment, Spanish mackerel was chosen as the taxa of finfish to model as benefiting from the increased forage based on many factors including the high trophic level, availability of life history information, presence in both years of entrainment 2 Life history parameters are called balanced when the modeled population replaces itself from generation to generation. Checking for balance and providing adjustments in the parameters to achieve balance is performed using solvers in Excel. Y:\GDP\F1301\150595\316BR\11.DOCX 11-23

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) sampling (Appendix 11-C) at PSL, and the presence of a C/R fishery within St. Lucie County (FWC, 2020, Section 11.3.1). While applying the foregone biomass to one taxon is not realistic, as there are many consumers within the nearshore Atlantic Ocean (i.e., jacks, tarpon, snook, sharks, etc. [FWC, 2020]), it provides a simple method of accounting that allows for comparisons between technologies and provides a method of incorporating the forage base into the C/R harvest analysis (see also Section 11.5). The conversion of forage biomass as production foregone to Spanish mackerel was conducted using a trophic transfer model. Table 11-4 provides the trophic level of each surrogate taxa modelled. For a transfer between trophic levels differing by less than or equal to one full trophic level, a 10-percent transfer efficiency was used (EPA 2002; May 1976; Pauly and Christensen, 1995). For a transfer between trophic levels greater than one, trophic transfer coefficient (TT) was calculated as follows (Lindeman, 1942):

    , = 10 where: TTi,j =              aggregate trophic transfer coefficient from forage taxa j, to Spanish mackerel.

TLj =trophic level of the forage taxa j. TLi =trophic level of Spanish mackerel. The trophic transfer model is one widely used to model the transfer of energy within food webs due to its simplicity and applicability to many systems (Pauly and Christensen, 1995). Trophic levels for different taxa were obtained from FishBase (2017). The biomass that was transferred to Spanish mackerel via the trophic transfer described previously was converted into EAs by dividing the biomass by the average weight of an age 2 (age fully exploited in fishery) Spanish mackerel (Table 11-4). The total number of EAs (from production foregone of forage taxa plus direct entrainment) were then used to calculate the loss of biomass to the fishery of all C/R taxa considered (Sciaenidae, Y:\GDP\F1301\150595\316BR\11.DOCX 11-24

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) weakfish, blue crab, stone crab, penaeid shrimp) because of entrainment using the Equivalent Yield model (EPRI, 2012) to provide the benefit to the fishery as kilograms of C/R catch. Biomass is representative of the whole fish or shellfish with the exception of stone crab, which are reported in the landings as claw weight. The stone crab fishery is somewhat unique in that the claws are harvested from live individuals, and these individuals are returned to the water to continue their life, and landings are reported in weight of claws harvested. Only one claw can be harvested at a time to increase the probability of survival after harvest. FWC (2006) estimates 1.2 claws are harvested from each individual crab over its lifetime, and each individual remains in the fishery for 2 years. Therefore, one crab may provide 0.6 claw for each year it remains in the fishery. To convert the whole organism weight to claw weight, the following steps were taken:

• Total biomass was multiplied by 25.5 percent to represent the proportion of a single claw weight to total weight (Duermit et al., 2015).
• Resulting biomass was multiplied by 1.2 to represent the average number of claws per stone crab that are harvested over their lifetime (FWC, 2006).
• Result was divided by 2 to account for the number of years an individual remains in the fishery (FWC, 2006).

To determine how the changes in annual entrainment as a result of the proposed technology would affect the C/R fisheries of the nearshore Atlantic Ocean, the annual benefits were projected over the life of the potential technology at the facility (Table 11-6). The life of the plant is assumed to end in 2043 which corresponds with the retirement date of Unit 2 (NRC, 2018a; 2018b). Unit 1 is projected to retire in 2036; however, the year 2043 was used for the facility as a whole to simplify the analysis and to provide a level of conservatism. Table 11-6. Years of Projection for Technology Retrofit Closed-cycle Technology Without Entrainment FMS Cooling Start year 2028 2028 2028 End year 2043 2043 2043 Source: FPL, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX 11-25

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) To simulate how the benefits would change over the life of the plant, dynamic Leslie matrix (Leslie, 1945) models are populated with survival rates and weights at age from Table 11-4 and simulated forward until they reach the estimates of EAs:

• For entrained taxa, in the year the technology comes online, there is no benefit observed, because no age class has yet hit the age of equivalence.
• The following year, each life stage is grown up (using the survival parameters from Table 11-4). Only those life stages that have reached the age of equivalence are counted.
• For subsequent years, as each life stage grows up to the age of equivalence, their numbers are added to the benefits.
• Once each age has hit their maximum age, they begin to die-off and, thus, hit a steady state of EAs, in which the rate of organisms attaining EA and those subject to mortality are equal. This steady state is the calculated total yearly EA from the models.
• When PSL is assumed to be decommissioned (2043), the maximum age EA counts decay via the survival parameter for the EA of that taxa.

The same was also done for projecting the change in forage biomass as production foregone except instead of EA (counts), the production foregone (kg) was used which also includes the biomass of organisms entrained. These projected annual EAs and production foregone underwent the same procedure as described previously to convert counts of individual organisms to biomass of C/R taxa considered. 11.2.3 Basis for Monetized Values Assigned to Changes in Stock Size or Harvest Levels Estimating the benefits of entrainment reductions requires assessing the relationship between entrainment, its corresponding changes to the relevant fishery, and the social impact of any fishery changes. The methodology uses a resource-economic simulation to evaluate the effects entrainment has on C/R fisheries as described in Appendix 11-B: Entrainment Reduction Benefits Study: St. Lucie Nuclear Power Plant. Y:\GDP\F1301\150595\316BR\11.DOCX 11-26

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) The methodology extends the most relevant fishery and resource-economic studies published in the peer-reviewed literature. Important modeling features include linking yield equivalence, expected catch, and choice-based behavioral fishing models and are used to simulate conditions under with-entrainment (utilizing conditions observed in sample Year 1 and sample Year 2) and reduced-entrainment conditions, and the differences between these two conditions determine the benefits of entrainment reductions. Figure 11-2 provides an overview of the methodology for evaluating the economic benefits of reducing entrainment at PSL. The shading in the bottom portion of the figure denotes the evaluation is separated into two parts: with-entrainment (top white portion) and reduced-entrainment (bottom shaded portion). The calculated difference in recreational and commercial yield, catch rates, trips, angler welfare, and commercial profits represent the benefits of entrainment reductions. As the top portion of the figure shows, the approach begins by specifying the with-entrainment yield for each evaluated species and dividing that into recreational (R) and commercial yield (C). The model then relates that yield to expected catch rates for the affected water body under with-entrainment conditions (for brevity, the figure illustrates this process for estimating recreational fishing benefits). Those catch rates are apportioned over the estimated number of trips occurring at affected sites. Under reduced-entrainment conditions, reduction in entrainment and the change in C/R yield that would accompany the entrainment reduction are identified. The new recreational yield is incorporated into changes in expected catch rates, and the corresponding changes in trips that would accompany increase catch rates are estimated. To calculate recreational fishing benefits, the model evaluates the differences between the with-entrainment and reduced-entrainment conditions, including yield, expected catch, and trips. The box around the expected catch and trip differentials identifies these results in the recreational fishing benefits measured as the consumer surplus differential. Consumer surplus is the difference between what an angler has to pay for a fishing trip and what the angler would be willing to pay. Y:\GDP\F1301\150595\316BR\11.DOCX 11-27

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-2. Overview of Methodology for Estimating the Benefits of Entrainment Reductions Y:\GDP\F1301\150595\316BR\11.DOCX 11-28

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Simulating the linked models produces equilibrium-based changes in stock, yield, trips, and expected catch under reduced-entrainment conditions. Equations from welfare and market-based economics are used to identify changes in consumer and producer surplus, which are then discounted to calculate present values. The following subsections provide additional detail on the recreational, commercial, and nonuse value components of the model. 11.2.3.1 Recreational Benefits The Atlantic Ocean provides a recreational fishery for residents and visitors. Anglers catch jacks, bluefish, bonito, dolphin, flounder, grouper, sailfish, snapper, sea bass, and other sportfish from the ocean. Adjoining cities and St. Lucie County enable access for anglers at several public boat ramps, multiple marinas, fishing piers, boat slips, and shore access points. Stock-level effects could be experienced as changes in catch rates by people hoping to catch the affected species in the Atlantic Ocean. Recreational anglers modeled as potentially being affected include those fishing in the Atlantic Ocean from St. Lucie County and neighboring counties. Appendix 11-B provides an in-depth description of the methodology used to estimate recreational benefits under with-entrainment and reduced-entrainment conditions. 11.2.3.2 Commercial Benefits Commercial benefits from entrainment reductions accrue in the form of increased profits attributable to the higher catch per unit effort (CPUE) associated with increases in fish populations (thereby benefiting the commercial fishery) and/or in the form of lower prices (thereby benefiting the consumer). To assess the commercial fishing benefits, the analysis specifies that price changes would occur as a result of reductions in St. Lucies entrainment and that all commercial fishing benefits accrue to consumers. Accordingly, the analysis estimates potential benefits to commercial fisheries near St. Lucie by computing consumer surplus changes based on a specification of unitary elasticity demand. The gain in consumer welfare will depend on the market quantity, the change in quantity, and the responsiveness of price to the higher quantity. Unitary elasticity Y:\GDP\F1301\150595\316BR\11.DOCX 11-29

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) indicates that price and quantity change by equal proportions but in opposite directions. A review of the literature indicates that assuming unitary elasticity (-1) is appropriate for many commercial fish species (Wessells and Anderson, 1992; Wessells and Wilen, 1994; DeVoretz and Salvanes, 1993). Commercial fishers that were modeled as potentially being affected include those fishing in the Atlantic Ocean from St. Lucie County and neighboring counties. To assess the commercial fishing benefits, the analysis applies the price per pound from the National Marine Fisheries Services 2019 data of annual St. Lucie County landings (FWC, 2020; NOAA Office of Science and Technology, 2020b) to the changes in commercial yield estimated to result from a complete elimination of entrainment at PSL. The analysis specifies the additional harvest will be sold at the 2019 prices. A detailed description of the methodology used for determining commercial benefits is provided in Appendix 11-B. 11.2.3.3 Nonuse Benefits The final category of benefits that could be monetized is nonuse benefits. Since the development of the 2004 version of the Final Rule, EPA has used several different methods to measure the potential nonuse values associated with reductions in entrainment. These include techniques such as habitat replacement cost, societal revealed preference, and the Fisher-Raucher approximation. Most recently, as part of supporting the development of the 2014 Final Rule, EPA administered a stated preference survey to develop the total values (use and nonuse) associated with the Final Rule. While EPA developed econometric models of the survey data and estimated respondents willingness to pay for alternative entrainment reductions, they did not incorporate the results of the survey into the estimate of the Final Rules benefits. Regardless, states have issued suggestions for how the stated preference survey results can be used to inform site-specific benefit estimates (e.g., Wisconsin Department of Natural Resources [WDNR], 2016). Regulators have made suggestions in public meetings that benefit valuation studies should, in the least, identify the implications that the stated preference study results have for an individual sites nonuse benefit estimates, and peer reviewers have asked whether the results of the stated preference survey have been considered as part of the 316(b) benefits valuation study. Y:\GDP\F1301\150595\316BR\11.DOCX 11-30

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Given the surveys existence and these suggestions and questions from regulators and peer reviewers, a simulation model has been developed that uses the best available information from EPAs stated preference survey and the literature to identify the implications of what the survey results imply for the potential nonuse benefits of 100-percent reduction in entrainment at PSL. Appendix 11-B provides a more detailed description of the steps taken to quantify nonuse benefits and the results of that quantification. 11.2.4 Discussion of Mitigation Efforts Made Prior to the Final Rule The Final Rule requires a discussion of mitigation efforts completed prior to October 14, 2014. PSL withdraws cooling water from the Atlantic Ocean (Class III Marine Waters) through three offshore intakes equipped with velocity caps, which the Final Rule considers a compliant technology for impingement mortality under 40 CFR 125.94(c)(4). PSLs intakes are located approximately 1,200 feet offshore where the water depth is approximately 23 feet. The offshore intake is in a less productive area than a shoreline intake or an estuarine intake in the Indian River Lagoon, and therefore reduces entrainment rates based on the lower densities of organisms located offshore. Studies comparing densities of organisms in the Indian River Lagoon to those in the Atlantic Ocean near the intake indicate that densities of impingeable and entrainable organisms are more than 80 percent lower in the Atlantic Ocean than in the Indian River Lagoon (FPL, 2010). Additionally, the intakes were sited in an area devoid of hardbottom habitat and seaward of the nearshore worm reefs. The velocity caps are large flat plates elevated above the vertical shaft of the intake structure that change the direction of the intake flow so that motile organisms are more able to detect and swim away from the current. Additionally, the velocity caps place the withdrawal at midwater depths rather than the more productive surface or bottom waters. Many fish and invertebrate early life stages are either buoyant or sink to the bottom; therefore, a midwater withdrawal reduces the potential for entrainment. Y:\GDP\F1301\150595\316BR\11.DOCX 11-31

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) The submerged intake pipes draw water under the seafloor, beach, and dunes into a 5,000-foot-long L-shaped intake canal that transports water to the intake structure on the west side of Units 1 and 2. The intake canal has a series of barrier nets to prevent larger organisms from reaching the plant intake. The canal is monitored, and entrapped organisms (especially sea turtles) are captured and returned to the ocean. These barrier nets reduce impingement on the traveling screens. 11.2.5 Discussion of Other Benefits, with Quantification and Monetization where Possible The Final Rule at 40 CFR 122.21(r)(11)(v) calls for: Discussion, with quantification and monetization, where possible, of any other benefits expected to accrue to the environmental and local communities, including but not limited to improvements for mammals, birds, and other organisms and aquatic habitats; This section addresses that requirement of the Final Rule beginning with a general review of the potential benefits of any reductions in entrainment followed by a discussion of impacts to federally listed species at PSLs CWIS. 11.2.5.1 General Considerations Other benefits that may result from a reduction in entrainment and impingement include an indirect effect on birds and terrestrial species that might use the Atlantic Ocean for habitat or food supply. However, due to the complex interactions in the ecology of the system, it is difficult to predict what kind of effect may occur. An ecosystem model was conducted for Barnegat Bay, New Jersey to quantify the potential effects of substantial reduction in water withdrawals by the Oyster Creek Generating Station. Results indicate that the changes in individual species abundance were small and the direction of the change varied. Some species that were directly affected by the intakes decreased with reduced withdrawals due to increased predation mortality (Vasslides et al., 2016). PSL is located on Hutchinson Island, a barrier island off the southeast coast of Florida. Portions of the island have been developed, but the area around PSL is mostly coastal maritime forest/hammock with sandy beach on the oceanside and mangroves along the west side bordering the Indian River Lagoon. Y:\GDP\F1301\150595\316BR\11.DOCX 11-32

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) The Indian River Lagoon to the west of PSL is designated as Jensen Beach to Jupiter Inlet Aquatic Preserve, covering the 37 miles of the lagoon from Fort Pierce to Jupiter Inlet. St. Lucie Countys Blind Creek recreational beach and preserve is located approximately one mile north of PSL, and Walton Rocks Beach is located approximately one-half mile to the south. The northern end of Hutchinson Island consists of Jupiter Inlet State Park approximately 9 miles north of PSL. Savannahs Preserve State Park is located on the mainland of Florida approximately 2 miles to the west of PSL. Avian species common in the area include coastal species such as pelicans, great blue heron, ospreys, egrets, royal terns, and seagulls. Birds and other wildlife that could benefit from a reduction in entrainment include those that eat fish, including many shore birds. For example, the population of mergansers may increase if (a) the availability of their food increases and (b) the merganser population is currently limited by food availability. Given the ecological mechanism thought to constrain many bird populations and the marginal nature of the predicted changes (Section 11.4), it is likely that bird or wildlife population levels would not change in any material sense as the result of alternative cooling water technologies at PSL. Many bird populations, particularly species of waterfowl, are thought to be constrained by density dependence on their breeding grounds and not food availability alone (Gunnarrsson et al., 2013). 11.2.5.2 Impacts to Federally Listed Species At PSL, there have been interactions between federally listed species and the CWIS, primarily species of sea turtles, with rarer occurrences of smalltooth sawfish (Pristis pectinata), giant manta rays (Mobula birostris), and scalloped hammerheads (Sphyrna lewini). This section will describe these interactions and FPLs ongoing responses as required by state and federal agencies. It will also describe that protection of these species is being pursued by measures outside of the candidate entrainment BTA approaches. Sea turtles are frequently found in the intake canal, and PSL operates a rescue and release program that includes capture, assessment, rehabilitation as necessary, and return to the ocean. Also, four smalltooth sawfish have been encountered in the intake canal (one in 2005, two in 2017, and one in 2019); two scalloped hammerhead sharks (in 1997 and again in 2012), and in Y:\GDP\F1301\150595\316BR\11.DOCX 11-33

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) one instance in January 2010 a manatee believed to have been subject to cold stress was found in the intake canal. Two giant manta rays were also found in the intake canal in 2020; this species was listed as threatened under the ESA by NOAA Fisheries in 2018. In coordination with NOAA Fisheries, FPL has studied and tested potential large animal exclusion devices for the offshore velocity caps. Based on the finding that exclusion devices represent an entrapment hazard that would put the animals at increased risk and that opportunities for rehabilitation would be precluded, FPL has recommended that such devices be avoided in favor of continued rescue and release program. The NRC has updated its proposed action to omit exclusion devices. NOAA Fisheries is in the process of updating its biological opinion, including assessing the need for exclusion devices. In no case is FPL, the NRC, or NOAA Fisheries considering the candidate entrainment BTA measures considered by the Final Rule (i.e., CCRS, FMS, alternative water supplies, or VSP) as a means of controlling interactions with these listed species. These interactions are with larger animals that are not subject to entrainment as defined by the Final Rule. As importantly, FPL does not believe that any of the entrainment BTA candidates would be effective at materially reducing those interactions. Instead, FPL believes that NOAA Fisheries will develop a biological opinion and update the Incidental Take Statement (ITS) 3 that relies on its authority under the ESA and measures beyond those intended to control entrainment. There are numerous studies in the literature that measure societys willingness to pay to protect threatened and endangered species (Amuakwa-Mensah et al., 2018; Wallmo, 2017; Wallmo and Lew, 2016; Wallmo and Lew, 2012; Lew, 2015). Because of the preventative measures FPL has undertaken and will continue to pursue as necessary, impacts to these listed species will be the same under baseline conditions as under any with entrainment reduction technology conditions; therefore, no valuation of these species is needed. 3 An ITS expresses the amount or extent of anticipated take (e.g., death, injury, harm or harassment) of listed species caused by an activity and provides an exemption from the ESA section 9 prohibitions on such take. Y:\GDP\F1301\150595\316BR\11.DOCX 11-34

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 11.2.6 Discussion of Benefits from Reductions in Thermal Discharges, with Quantification and Monetization where Possible After passing through the condenser system, cooling water from PSL is discharged into a 2,200 foot long by 60-foot-wide discharge canal. The canal terminates into two parallel 12-foot inside diameter pipelines that convey the discharge under the beach and dunes to two offshore discharge structures. The first, initially associated with Unit 1, consists of a two-port Y-diffuser that terminates 1,500 feet offshore. The second is a linear multi-port diffuser with 58 16-inch diameter ports spaced 24 feet apart along the last 1,400 feet of offshore pipe and terminates 3,400 feet offshore (NRC, 2010). The diffusers were designed to effectively mix the thermal discharge with ambient waters, and a small mixing zone for each diffuser (together totaling 1,306 m2) was established in the NPDES permit. Based on the mixing zone analysis, a daily maximum thermal limit of 115°F was established for normal operations, which can be increased to 117°F during maintenance activities. These limits coincide with a maximum temperature differential between intake and discharge (T) of 30°F during normal operations and 32°F during maintenance activities. The discharge limits therefore comply with the limitations in the Thermal Surface Water Criteria in Floridas Water Quality Standards (62-302.520, F.A.C.). Given this is the case, little or no real benefit would be expected to accrue to the biological community near the outfall. 11.3 Baseline Fishing Conditions Existing fishing conditions are defined as the current conditions at PSL, which include entrainment. The characterization of baseline fishing conditions considers recreational and commercial fishing, both current and into the future. The characterization of existing fishing conditions included an assessment of current C/R yield with entrainment at PSL, the number of C/R anglers potentially affected by the impact of entrainment at PSL on C/R yield, the number of fishing trips the anglers take, the sites those anglers visit, and catch rates was completed. Appendix 11-B provides a detailed description of how baseline fishing conditions, both recreational and commercial, are defined and estimated at PSL. Y:\GDP\F1301\150595\316BR\11.DOCX 11-35

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) 11.4 Technology-specific Findings This section presents the results of the benefits analysis for each technology considered. The without-entrainment condition is presented to estimate the benefits of a complete reduction in entrainment mortality at PSL. This scenario is presented to provide context for the benefits estimated for the technologies being considered. Appendices 11-C through 11-E provide the detailed entrainment data for the baseline condition, closed-cycle cooling, and FMS, respectively. 11.4.1 Without-entrainment Condition The without-entrainment condition is if PSL were to shut down the cooling water intake completely. This case is considered as it provides a transparent illustration of the steps involved in the biological modeling and economic assessment without any bias introduced by the differential effectiveness of the entrainment technologies. 11.4.1.1 Changes in Fish and Shellfish Table 11-7 summarizes the numbers of fish and shellfish that would no longer be entrained or impinged in the without-entrainment condition (Appendix 11-C). Table 11-7. Annual Benefit as Reduction in Entrainment to All Life Stages of Fish and Shellfish If PSL Were to Shut Down the Cooling Water Intake Sample Year (million) Animal 1 2 Fish 4,702 16,128 Shellfish 64,379 124,137 Total 69,080 140,265 Source: ECT, 2021. The average annual entrainment losses of fish eggs are estimated at 8.3 billion (range of 3.3 billion to 13.4 billion; Appendix 11-C). To put these losses in perspective, egg production by species of fish is typically very high (e.g., annual egg production for Spanish mackerel is between 500 thousand and 1.5 million [ASFMC, 2019]) indicating that the loss of eggs is associated with the production of a relatively few individuals particularly given the large number Y:\GDP\F1301\150595\316BR\11.DOCX 11-36

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) and types of fish in the nearshore Atlantic. Further, eggs experience high natural mortality rates suggesting that the losses of adults (as modeled below) are low. 11.4.1.2 Changes in Stocks and Harvest Table 11-8 provides the results of the estimation of benefits (as kilograms of C/R harvest returned to the fishery) if PSL were to shut down in 2028 (Appendix 11-C). Figure 11-3 illustrates the estimated total (direct and indirect) recreational yield changes for recreational taxa (Sciaenidae and weakfish) entrained at PSL following complete elimination of entrainment at PSL as well as the changes in Spanish mackerel as a result of changes in forage biomass. The shape of the curves is a result of the methodology described in Section 11.2.2, which has the population growing up from their respective life stages to the annual EAs and then decaying after decommissioning of the facility (2043) via the survival parameters presented in Table 11-4. Figure 11-4 illustrates the estimated changes in kilograms of commercially harvest taxa in response to the elimination of entrainment at the St. Lucie Plant. The average total annual foregone fishery yield for the two study years (Table 11-8) is estimated as 71,613 kg. This number represents the annual total loss of biomass from the C/R fisheries due to entrainment losses, both direct and production foregone from forage, from the operation of PSL. This estimate is designed to be an overestimation of these losses by employment of a number of modeling assumptions (i.e., entrainment results in 100-percent lethality, all entrainment losses affect C/R taxa and no others, and selection of various parameters to maximize the estimated effects on stocks). For perspective, the annual commercial finfish landings for St. Lucie County over the five-year period 2015 to 2019 ranged from 1,105,640 to 1,282,465 kg, or an average of 1,202,944 kg. Thus, the foregone fishery yield because of the estimated entrainment rates at PSL represents approximately 5.9 percent of the 2015-2019 average annual commercial yield of St. Lucie County. Y:\GDP\F1301\150595\316BR\11.DOCX 11-37

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-8. Modelled Annual Benefits of Baseline Condition Entrainment Entrained Equivalent Production Foregone Direct Foregone Total Foregone Scientific Name Common Name Adults (number) (kg) Fishery Yield (kg) Fishery Yield (kg) Sample Years 1 2 1 2 1 2 1 2 Fish Menidia menidia Atlantic silverside - 8 Anchoa mitchilli Bay anchovy 694 9,453 Brevoortia tyrannus Atlantic menhaden 609,588 1,030,144 Trinectes maculatus Hogchoker 10,788 7,317 Gerriedae Mojarra 642 16,413 Gobiosoma bosci Naked goby 2,497 8,560 Sciaenidae Drums and croakers 98,243 27,007 9,427 2,591 9,427 2,591 Bairdiella chrysoura Silver perch 880 198 Cynoscion regalis Weakfish 2,639 225 1,207 103 1,207 103 Production foregone of Spanish mackerel from fish 17,184 29,344 Fish Total 100,881 27,232 625,089 1,072,092 10,634 2,695 27,819 32,039 Percent reduction by technology 100% 100% 100% 100% 100% 100% 100% 100% Shellfish Anomura Anomuran crab 209,516 202,746 Callinectes sapidus Blue crab 648,155 45,791 31,079 2,196 31,079 2,196 Brachyura Brachyuran crab 1,244,237 2,881,022 Caridea Grass shrimp 280,592 2,392,161 Penaeid Commercial shrimp 345,496 566,751 296 485 296 485 Menippe mercenaria Stone crab 1,535 350 39 8.9 39 8.9 Production foregone of Spanish mackerel from shellfish 11,850 37,414 Shellfish Total 995,187 612,893 1,734,345 5,475,928 31,414 2,690 43,264 40,104 Percent reduction by technology 100% 100% 100% 100% 100% 100% 100% 100% Annual Total 1,149,778 640,125 2,359,434 6,548,021 42,048 5,384 71,082 72,143 Percent reduction by technology 100% 100% 100% 100% 100% 100% 100% 100% Shading indicates C/R taxa. Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX033121 11-38

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-3. Total (Direct and Indirect) Changes in Recreational Yield Panel A: Sample Year 1 Panel B: Sample Year 2 Recreational Yield Veritas ECONOMICS Source: Veritas, 2021 Y:\GDP\F1301\150595\316BR\11.DOCX 11-39

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-4. Total (Direct and Indirect) Changes in Commercial Yield Panel A: Sample Year 1 Panel B: Sample Year 2 Commercial Yield Veritas ECONOMICS Source: Veritas, 2021 Y:\GDP\F1301\150595\316BR\11.DOCX 11-40

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) In addition to the estimated annual commercial harvest, the recreational landings in St. Lucie County, although not specifically quantified at this level, are likely to be substantially higher (based on Florida east coast data [NOAA Fisheries, 2020]) than the commercial landings for many species including black drum and spot. Therefore, the estimated losses from PSL are likely to be a very small fraction of the combined harvest from commercial and recreational fishing. From the observed species trends, it would appear the substantial fecundity of the species affected by entrainment losses at PSL allows the populations to accommodate the ongoing losses. The facility has been operating since the 1970s and has not been shown to have an adverse effect on the aquatic community, given the longevity of the plant, the system is in a steady state currently and due to the dynamic nature of the receiving waterbody, will reach a largely similar steady state shortly after any plant changes. 11.4.1.3 Monetized Value of Changes in Stocks and Harvest The benefits from a shutdown of the cooling water intake at PSL would be experienced over the otherwise expected remaining life of the plant from the day it shut down. For modelling purposes, the year of shut down is defined as 2028 with the planned life of PSL ending in 2043. Benefits are assumed to commence on January 1 and end on December 31 for each year. No changes in density are expected to occur from one year to the next for each scenario (i.e., the organism densities are assumed to be fixed according to the year that the entrainment characterization was performed). Figure 11-5 illustrates how those benefits to species that are presumed to receive the forage production foregone (as kilograms of C/R taxa) would be realized over the projected life of PSL to define the baseline condition in which all other technologies will be compared. Note that Spanish mackerel were not found in entrainment samples but were selected to receive production foregone based on their importance to the fishery. Valuing Changes in Recreational Yield After apportioning the estimated yield changes over the affected sites identified in Appendix 11-B, the per-trip expected catch changes can be calculated. Figure 11-6 presents the per-trip change in the expected catch of each recreationally harvested taxa at each of the affected sites. Y:\GDP\F1301\150595\316BR\11.DOCX 11-41

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-5. St. Lucie Plant Life Fishery Yield Benefit Under Baseline Conditions Source: Veritas, 2021 Y:\GDP\F1301\150595\316BR\11.DOCX 11-42

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-6. Change in Expected Recreational Catch per Trip by Taxa Panel A: Sample Year 1 Panel B: Sample Year 2 Expected Catch Veritas ECONOMICS Source: Veritas, 2021 Y:\GDP\F1301\150595\316BR\11.DOCX 11-43

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-7 depicts the annual change in dollar-valued welfare associated with the estimated trip changes from a complete elimination in entrainment at PSL. Table 11-9 summarizes the total social benefits as a result of changes in the recreational stock in response to the complete elimination of entrainment at the PSL (Appendix 11-B). Values are presented in both present value (over the life of the facility) and annual value. Table 11-9. Summary of Recreational Social Benefits with Complete Elimination of Entrainment at PSL Present Value ($) Annual Value ($) Discount Entrainment Technology Sample Years Rate Reduction 1 2 1 2 3% Baseline 100% 143,174 142,455 8,948 8,903 7% Baseline 100% 76,118 75,215 4,757 4,701 Source: Veritas, 2021 Figure 11-7. Change in Welfare with a 100-Percent Reduction in Entrainment at the St. Lucie Plant Welfare Difference in US Dollars Veritas ECONOMICS Source: Veritas, 2021 Y:\GDP\F1301\150595\316BR\11.DOCX 11-44

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Valuing Changes in Commercial Yield Figure 11-8 illustrates the changes in commercial value in response to the complete elimination of entrainment at PSL. Table 11-10 summarizes the total social benefits as a result of changes in the commercial stock in response to the complete elimination of entrainment at PSL (Appendix 11-B). Values are presented in both present value (over the life of the facility) and annual value. Figure 11-8. Change in Commercial Value with a 100-Percent Reduction in Entrainment at PSL Change in Commercial Value in US Dollars Veritas ECONOMICS Table 11-10. Summary of Commercial Social Benefits as a Result of Complete Elimination of Entrainment at the St. Lucie Plant Present Value Annual Value Discount Entrainment ($) ($) Technology Rate Reduction Sample Years 1 2 1 2 3% 1,325,344 1,176,184 82,834 73,512 Baseline 100% 7% 742,764 644,812 46,423 40,301 Source: Veritas, 2021 Y:\GDP\F1301\150595\316BR\11.DOCX 11-45

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Nonuse Value Table 11-11 summarizes the nonuse benefits estimates and presents three different regions used to evaluate the nonuse benefits of reductions in entrainment at PSL:

• All the households in St. Lucie County, Florida, the county where PSL is located
• All the households in the states included in the southeast region of EPAs stated preference survey
• All the households in the United States.

Table 11-11. Summary of Nonuse Benefits for 100-Percent Entrainment Reduction at PSL 3% Discount Rate ($) 7% Discount Rate ($) Specified Population Present Value Annual Value Present Value Annual Value of Households Sample Years 1 2 1 2 1 2 1 2 St. Lucie County 1,518 647 95 40 845 357 53 22 EPAs Southeast Region* 57,751 24,625 3,609 1,539 32,168 13,595 2,010 850 United States 200,074 85,311 12,505 5,332 111,443 47,100 6,965 2,944

• Alabama, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Texas, and Virginia.

Source: Veritas, 2021. The nonuse benefits are estimated over the same time period as the C/R benefits: from 2028 to 2043. Table 11-11 presents the nonuse benefit of 100-percent reduction in PSLs entrainment across the two different entrainment sample years using two different discount rates: 3 and 7 percent. 11.4.2 Closed-cycle Cooling 11.4.2.1 Changes in Fish and Shellfish Table 11-12 summarizes annual entrainment numbers of fish and shellfish that would no longer be entrained if PSL were to retrofit with closed-cycle cooling (Appendix 11-D), representing a 73.8-percent decrease in entrainment (i.e., 50,947 M/ 69,080 M= 0.738) in entrainment (as numbers of organisms, Table 11-7). Y:\GDP\F1301\150595\316BR\11.DOCX 11-46

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-12. Annual Benefit (as Reduction in Entrainment) that Would Result if the St. Lucie Plant Were to Retrofit with Closed-cycle Cooling Sample Year (million) Animal 1 2 Fish 3,467 11,894 Shellfish 47,480 91,551 Total 50,947 103,445 Source: ECT, 2021. 11.4.2.2 Changes in Stocks and Harvest Table 11-13 provides the results of the estimation of benefits (as kilograms of C/R harvest returned to the fishery) if PSL were to be retrofit with closed-cycle cooling (Appendix 11-D). The benefits would be first observed in 2028. The average total annual foregone fishery yield is estimated as 52,814 kg (Table 11-13). 11.4.2.3 Monetized Value of Changes in Stocks and Harvest The benefits of retrofitting to closed-cycle cooling at PSL would be experienced over the expected remaining life of the plant from the day the cooling towers came online. For modeling purposes, the year of retrofit is defined as 2028 with the expected life of PSL ending in 2043. Figure 11-9 illustrates how those benefits (as kilograms of commercial taxa) would be realized over the projected life of PSL. This represents a total benefit of 73.8 percent of the baseline conditions (26.2 percent less than complete PSL closure). Valuing Changes in Recreational Yield Table 11-14 summarizes the total social benefits as a result of changes in the recreational stock in response to the reduction in entrainment resulting from the retrofit to closed-cycle cooling (Appendix 11-D). Values are presented in both present value (over the life of the facility) and annual value. Y:\GDP\F1301\150595\316BR\11.DOCX 11-47

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-13. Modelled Annual Benefits of Retrofit to Closed-cycle Cooling Entrainment Entrained Equivalent Production Foregone Direct Foregone Total Foregone Scientific Name Common Name Adults (number) (kg) Fishery Yield (kg) Fishery Yield (kg) Sample Years 1 2 1 2 1 2 1 2 Fish Menidia menidia Atlantic silverside - 6 Anchoa mitchilli Bay anchovy 512 6,972 Brevoortia tyrannus Atlantic menhaden 449,571 759,731 Trinectes maculatus Hogchoker 7,956 5,396 Gerriedae Mojarra 474 12,104 Gobiosoma bosci Naked goby 1,841 6,313 Sciaenidae Drums and croakers 72,454 19,918 6,952 1,911 6,952 1,911 Bairdiella chrysoura Silver perch 649 146 Cynoscion regalis Weakfish 1,946 166 890 76 890 76 Production foregone of Spanish mackerel from fish 12,673 21,641 Fish Total 74,400 20,084 461,003 790,668 7,843 1,987 20,516 23,629 Percent reduction by technology 74% 74% 74% 74% 74% 74% 74% 74% Shellfish Anomura Anomuran crab 154,518 149,525 Callinectes sapidus Blue crab 478,015 33,771 22,921 1,619 22,921 1,619 Brachyura Brachyuran crab 917,625 2,124,753 Caridea Grass shrimp 206,936 1,764,219 Penaeid Commercial shrimp 254,804 417,979 218 358 218 358 Menippe mercenaria Stone crab 1,132 258 29 6.60 29 6.60 Production foregone of Spanish mackerel from shellfish 8,739 27,593 Shellfish Total 733,950 452,008 1,279,079 4,038,497 23,168 1,984 31,907 29,577 Percent reduction by technology 74% 74% 74% 74% 74% 74% 74% 74% Annual Total 808,350 1,467,279 1,740,082 4,829,165 31,010 3,971 52,423 53,205 Percent reduction by technology 74% 74% 74% 74% 74% 74% 74% 74% Shading indicates C/R taxa. Source: ECT, 2021 Y:\GDP\F1301\150595\316BR\11.DOCX033121 11-48

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-9. St. Lucie Plant Life Fishery Yield Benefits After Retrofit to CCRS Y:\GDP\F1301\150595\316BR\11.DOCX 11-49

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-14. Summary of Recreational Social Benefits as a Result of the Reduction in Entrainment from Closed-cycle Cooling Present Value Annual Value Discount Entrainment ($) ($) Technology Rate Reduction Sample Years 1 2 1 2 3% 105,676 105,149 6,605 6,572 Closed-cycle cooling 73.8% 7% 56,182 55,518 3,511 3,470 Source: Veritas, 2021 Valuing Changes in Commercial Yield Table 11-15 summarizes the total social benefits as a result of changes in the commercial stock in response to the reduction in entrainment resulting from the retrofit to closed-cycle cooling (Appendix 11-D). Values are presented in both present value (over the life of the facility) and annual value. Table 11-15. Summary of Commercial Social Benefits as a Result of the Reduction in Entrainment from Closed-cycle Cooling Present Value Annual Value Discount Entrainment ($) ($) Technology Rate Reduction Sample Years 1 2 1 2 3% 1,041,691 850,896 65,106 53,181 Closed-cycle cooling 73.8% 7% 584,375 466,487 36,523 29,155 Source: Veritas, 2021 Nonuse Value Table 11-16 summarizes the nonuse benefits of reductions in entrainment at PSL due to closed-cycle cooling for all households in the United States. The nonuse benefits are estimated over the same time period as the C/R benefits for closed-cycle cooling reductions: from 2028 to 2043. Y:\GDP\F1301\150595\316BR\11.DOCX 11-50

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-16. Summary of Nonuse Benefits as a Result of the Reduction in Entrainment from Closed-cycle Cooling 3% Discount Rate ($) 7% Discount Rate ($) Specified Population Present Value Annual Value Present Value Annual Value of Households Sample Years 1 2 1 2 1 2 1 2 St. Lucie County 1,119 477 70 30 623 264 39 16 EPAs Southeast Region* 42,591 18,161 2,662 1,135 23,724 10,027 1,483 627 United States 147,555 62,917 9,222 3,932 82,189 34,736 5,137 2,171

• Alabama, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Texas, and Virginia Source: Veritas, 2021 11.4.2.4 Mitigation Effort Made Prior to Rule Refer to Section 11.2.4.

11.4.2.5 Other Benefits Refer to Section 11.2.5. CCRS will result in a reduction in approach velocity due to the reduced volumes needed for cooling purposes. This may result in a reduction in the potential for sea turtle interactions with the CWIS. However, to what extent these interactions will occur is unknown and it is unlikely that the potential changes will have any material impact on the population of sea turtles (Barnthouse, 2013). 11.4.2.6 Reduction in Thermal Discharge The rule requires the benefits expected to result from any reduction in thermal discharges from each technology be discussed. Since there will be a reduction in flow because of closed-cycle cooling of 73.8 percent, the amount of heated water entering the Atlantic Ocean will also be decreased. In addition, the water discharged from the closed-cycle cooling system in the form of blow down will not generally be heated relative to ambient to the extent the discharged currently is. This will result in a substantial reduction of the warm water addition to the discharge canal. As discussed in Section 11.2.6, PSL utilizes diffusers at the terminus of the cooling water discharges to facilitate rapid mixing with ambient ocean water. A small mixing zone for each diffuser (together totaling 1,306 m2) has been authorized in the existing NPDES permit. Y:\GDP\F1301\150595\316BR\11.DOCX 11-51

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Reduction in flow and temperature may allow some fish and shellfish to utilize this area near the discharge that otherwise might not. However, the area affected by the thermal discharge is relatively small in terms of the size of the Atlantic Ocean and is limited to surface waters. Given this is the case, little or no real benefit would be expected to accrue to the biological community near the outfall. 11.4.3 FMS 11.4.3.1 Changes in Fish and Shellfish Table 11-17 summarizes the annual entrainment number of fish and shellfish that would no longer be entrained if PSL were to be retrofit with FMS (Appendix 11-E). This represents a 77-percent decrease (i.e., 52,934 M/ 69,080 M= 0.77) in entrainment (as numbers of organisms, Table 11-7) in both sample years 1 and 2, 27 percent for fish and 80 percent for shellfish in year 1, and 33 percent for fish and 82 percent for shellfish in year 2. Table 11-17. Annual Benefit (as Reduction in Entrainment) that Would Result if PSL Were to Retrofit with FMS Sample Year (million) Animal 1 2 Fish 1,268 5,341 Shellfish 51,666 101,988 Total 52,934 107,329 Note: Differences may exist in totals due to rounding for reporting purposes. Source: ECT, 2021. 11.4.3.2 Changes in Stocks and Harvest Table 11-18 provides the results of the estimate of benefits (as kilograms of C/R harvest returned to the fishery) if PSL were to be retrofit with FMS. The benefits would be first observed in 2028. The average annual foregone fishery yield is estimated at 42,768 kg (Table 11-18). 11.4.3.3 Monetized Value of Changes in Stocks and Harvest The benefits of retrofitting PSL with FMS would be experienced over the expected remaining life of the plant from the day the FMS came online. For modeling purposes, the year of retrofit is defined as 2028 with the expected life of PSL ending in 2043. Y:\GDP\F1301\150595\316BR\11.DOCX 11-52

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-18. Modelled Annual Benefits of Retrofit to FMS Entrainment Entrained Equivalent Direct Foregone Total Foregone Production Foregone Adults Fishery Yield Fishery Yield Scientific Name Common Name (kg) (number) (kg) (kg) Sample Years 1 2 1 2 1 2 1 2 Fish Menidia menidia Atlantic silverside - 2 Anchoa mitchilli Bay anchovy 9 3,195 Lepomis macrochirus Bluegill - - Brevoortia tyrannus Atlantic menhaden 28,117 53,751 Trinectes maculatus Hogchoker 6,295 3,853 Gerriedae Mojarra 30 869 Gobiosoma bosc Naked goby 481 1,259 Sciaenidae Drums and croakers 37,704 10,788 - - 3,618 1,035 3,618 1,035 Bairdiella chrysoura Silver perch 239 30 Leiostomux xanthurus Spot - - - - - - - - Cynoscion regalis Weakfish 293 28 - - 134 13 134 13 Production foregone of Spanish mackerel from fish 1,057 1,837 Fish Total 37,997 10,816 35,171 62,960 3,752 1,048 4,809 2,886 Percent reduction by technology 38% 40% 6% 6% 35% 39% 17% 9% Shellfish Anomura Anomuran crab 172,685 162,009 Callinectes sapidus Blue crab 626,766 44,280 30,053 2,123 30,053 2,123 Brachyura Brachyuran crab 1,113,053 2,642,168 Caridea Grass shrimp 241,780 2,249,638 Penaeid Penaeid shrimp 306,694 465,849 262 399 262 399 Menippe mercenaria Stone crab 1,170 267 30 7 30 7 Production foregone of Spanish mackerel from shellfish 10,437 34,530 Shellfish Total 934,630 510,396 1,527,519 5,053,815 30,346 2,529 40,782 37,059 Percent reduction by technology 94% 83% 88% 92% 97% 94% 94% 92% Annual Total 972,627 521,212 1,562,690 5,116,775 34,098 3,577 45,591 39,944 Percent reduction by technology 85% 81% 66% 78% 81% 66% 64% 55% Note: Gray shading indicates C/R taxa. Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX033121 11-53

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-10 illustrates how the benefits (as kilograms of commercial taxa) would be experienced over the projected life of PSL. This represents an average total benefit of 60 percent from baseline conditions (40 percent less than complete closure of PSL). Valuing Changes in Recreational Yield Table 11-19 summarizes the total social benefits as a result of changes in the recreational stock in response to the reduction in entrainment resulting from the use of FMS (Appendix 11-E). Values are presented in both present value (over the life of the facility) and annual value. Table 11-19. Summary of Recreational Social Benefits as a Result of Reduction in Entrainment from FMS Present Value Annual Value Discount Entrainment ($) ($) Technology Rate Reduction Sample Years 1 2 1 2 3% FMS 1 to 97% 54,784 74,086 3,424 4,630 7% FMS 1 to 97% 29,019 39,167 1,814 2,448 Note: Reduction in rate of entrainment varies by taxa and life stage of the excluded organisms. Source: Veritas, 2021. Valuing Changes in Commercial Yield Table 11-20 summarizes the total social benefits as a result of changes in the commercial stock in response to the reduction in entrainment resulting from the use of FMS (Appendix 11-E). Values are presented in both present value (over the life of the facility) and annual value. Table 11-20. Summary of Commercial Social Benefits as a Result of Reduction in Entrainment from FMS Present Value Annual Value Discount Entrainment ($) ($) Technology Rate Reduction Sample Years 1 2 1 2 3% FMS 1 to 97% 1,030,148 695,366 64,384 43,460 7% FMS 1 to 97% 581,308 382,831 36,332 23,927 Note: Reduction in rate of entrainment varies by taxa and life stage of the excluded organisms. Source: Veritas, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX 11-54

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Figure 11-10. PSL Plant Life Fishery Yield Benefits After Retrofit to FMS Y:\GDP\F1301\150595\316BR\11.DOCX 11-55

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Nonuse Value Table 11-21 summarizes the nonuse benefits of reductions in entrainment at PSL due to FMS for all households in the United States. Table 11-21. Summary of Nonuse Benefits as a Result of Reduction in Entrainment from FMS 3% Discount Rate ($) 7% Discount Rate ($) Specified Population of Present Value Annual Value Present Value Annual Value Households Sample Years 1 2 1 2 1 2 1 2 St. Lucie County 530 166 33 10 296 92 19 6 EPAs Southeast Region* 20,184 6,301 1,262 394 11,266 3,505 704 219 United States 69,926 21,830 4,370 1,364 39,031 12,142 2,439 759

• Alabama, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Texas, and Virginia Source: Veritas, 2021.

The nonuse benefits are estimated over the same time period as the C/R benefits for FMS reductions: from 2028 to 2043. 11.4.3.4 Mitigation Effort Made Prior to Rule Refer to Section 11.2.4. 11.4.3.5 Other Benefits Refer to Section 11.2.5. 11.4.3.6 Reduction in Thermal Discharge Addition of FMS would not affect the thermal loading; therefore, there would be no change in the thermal discharge. 11.4.4 Summary of Monetized Benefits for Candidate Measures Table 11-22 summarizes the monetized recreational, commercial, and nonuse benefits of the candidate measures as detailed previously. Following the complete elimination of entrainment at PSL, closed-cycle cooling provides the greatest social benefit as is expected, because it provides the greatest reduction in entrainment. Y:\GDP\F1301\150595\316BR\11.DOCX 11-56

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-22. Summary of Recreational and Commercial Social Benefits of Entrainment Reduction Alternatives at the St. Lucie Plant Discount Entrainment Present Value ($) Annual Value ($) Technology Rate Reduction Rec Com Nonuse Total Rec Com Nonuse Total Sample Year 1 Without 100% $143,174 $1,325,344 $200,074 $1,668,593 $8,948 $82,834 $12,505 $104,287 entrainment Closed-3% 73.8% $105,676 $1,041,691 $147,555 $1,294,922 $6,605 $65,106 $9,222 $80,933 cycle FMS 1-97% $54,784 $1,030,148 $69,926 $1,154,858 $3,424 $64,384 $4,370 $72,179 Without 100% $76,118 $742,764 $111,443 $930,325 $4,757 $46,423 $6,965 $58,145 entrainment Closed-7% 73.8% $56,182 $584,375 $82,189 $722,746 $3,511 $36,523 $5,137 $45,172 cycle FMS 1-97% $29,019 $581,308 $39,031 $649,359 $1,814 $36,332 $2,439 $40,585 Sample Year 2 Without 100% $142,455 $1,176,184 $85,311 $1,403,950 $8,903 $73,512 $5,332 $87,747 entrainment Closed-3% 73.8% $105,149 $850,896 $62,917 $1,018,963 $6,572 $53,181 $3,932 $63,685 cycle FMS 1-97% $74,086 $695,366 $21,830 $791,282 $4,630 $43,460 $1,364 $49,455 Without 100% $75,215 $644,812 $47,100 $767,128 $4,701 $40,301 $2,944 $47,945 entrainment Closed-7% 73.8% $55,518 $466,487 $34,736 $556,741 $3,470 $29,155 $2,171 $34,796 cycle FMS 1-97% $39,167 $382,831 $12,142 $434,140 $2,448 $23,927 $759 $27,134 Note: Nonuse benefits are the benefits associated with the United States (Appendix 11-B; Table 1.7). Appendix B also presents these nonuse benefits at the county and southeast regional level. Source: Veritas, 2021. 11.5 Discussion of Uncertainty Due to the complex interactions of environmental systems, there is, understandably, a level of uncertainty that comes along with biological models. It is important to understand these uncertainties and how each parameter can affect the end results. Though there are statistical methods that attempt to quantify the degree of uncertainty, it was believed, for this application, such statistical methods were not necessary or useful, and a qualitative approach was taken. Table 11-23 summarizes the parameters used in the biological modelling described previously and includes a discussion, and quantification where appropriate, of how changes to the parameters affect the end results used to formulate the decision on entrainment BTA. Section 1.5 in Appendix 11-B also includes a discussion of uncertainty in the benefits assessment and is summarized below. Y:\GDP\F1301\150595\316BR\11.DOCX 11-57

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Numerous sources of uncertainty may lead to imprecision in benefit estimates. Following Finkel (1990), EPA classifies uncertainty into four general types (EPA, 2014): data uncertainty, structural uncertainty, parameter uncertainty, and engineering uncertainty. Data uncertainty refers to uncertainty in sampling in impingement and entrainment studies. This uncertainty is perhaps the largest and most difficult of these sources to characterize. Benefit estimates are based on characterizations of entrainment. An ideal estimate would be the mean value of the discounted present value of benefits from future years of entrainment. However, only two years from the past are available for modeling. This makes it impossible to empirically quantify interannual entrainment data uncertainty. Structural uncertainty reflects limited understanding of the appropriate model and relationships among model parameters. Structural uncertainty is mitigated through adherence to the best available models when possible and the selection of conservative modeling approaches. For example, the biological modeling underlying the economic results are projections-based, and age class survival rates and biomass relationships are evaluated across trophic levels. These models presume an impact where there may be no empirically measurable change. Parameter uncertainty reflects imprecision in the specific numeric values of biological and economic model parameters. It can be evaluated via a Monte Carlo analysis; however, a shortcoming of employing Monte Carlo analysis in this context is that the parameters that underly change in yield calculations are not developed statistically and therefore do not come with by-life-stage variances or across-life-stage covariances. The implication is that any quantitative evaluation of uncertainty is based on subjectively specified uncertainty parameters. The economic model does have variances and covariance, allowing for a scientific evaluation of uncertainty. However, as the economic models operate subsequent to the fishery yield models, lack of variation in the fishery yield models carries through the economic modeling. Engineering uncertainty relates to the fact that facilities do not operate in the same manner on an annual basis. PSL is a nuclear-powered facility and is expected to generate electricity and operate pumps regularly except during refueling and maintenance periods. The possibility of Y:\GDP\F1301\150595\316BR\11.DOCX 11-58

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) outages occurring during periods of high entrainment was not modeled. This would lead to lower entrainment impacts. Other than this engineering uncertainty is minimal. Finally, when completing the social costs, it is recognized that, since the modeling goes out decades into the future, differences from the current state of fishing could impact results. This means anticipated changes in site quality and availability or changes in economic conditions and fishing preferences should be expressed in the with-entrainment case going forward. Although participation in recreational fishing declined nationally years ago, fishing license sales have rebounded in recent yearsdramatically in some states. According to the National Survey of Fishing, Hunting, and Wildlife-Associated Recreation, the number of anglers rose 11 percent from 2006 to 2011. Based on fishing license sales from 2006 to 2011, fishing participation increased nearly 4.8 percent among Florida anglers. However, between 2004 and 2017, Floridas fishing license sales increased 38.8 percent (USFWS, 2018). Thus, it is reasonable to state that the current C/R fishing status is appropriate to apply to future conditions. 11.5.1 Cumulative Effects of Uncertainty Several areas of uncertainty have been described in Table 11-23. Independently, these uncertainties may not have a large impact on the final social benefits and/or they deliberately overestimate likely benefits. However, when combined, they have the potential to become additive and possibly (though unlikely in most circumstances) change the results of the assessment, including the relative ranking of potential entrainment measures. Furthermore, the cumulative effects for a technology may be greater than others, because that technology has more assumptions associated with it or the assumptions affect that technology more than others. Every effort was made to recognize, process, and choose the appropriate value for the assessment using BPJ. The decisions made for this assessment were carefully considered and vetted by the team and others and represent the BPJ at the time of writing this report. Y:\GDP\F1301\150595\316BR\11.DOCX 11-59

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-23. Uncertainties of Benefits Valuation Study Category of Input Range of Variation or Options Rationale for Value Chosen Sensitivity of Alternative Choice Entrainment data were collected January 2006 to October 2007. The portion of this Given the variation seen in the two years of data, the decision was made data from October 2006 to October 2007 was used as the first year of entrainment to consider quantitatively both sets of data. The interannual variation in data in this analysis (Year 1). Additional data were collected from November 2017 taxa especially becomes important after applying the exclusion The alternative options would fail to illustrate the variation in through November 2018 and are referred to as Year 2. The two years of data were efficiencies of FMS. entrainment and attending benefits. Depending upon approach selected Rates of entrainment variable in both magnitude and in the rates of the various taxa. Fish entrainment in (maximum, average, or minimum), the range of benefits would be Year 2 was nearly 3.5 times the number entrained in Year 1 and invertebrate Therefore, both sets will be used to estimate reductions in entrainment incompletely characterized. entrainment in Year 2 was approximately 2 times the number in Year 1. and attending social benefits. The alternative approaches of selecting one Interannual variation of this magnitude is not unusual, particularly for individual year over another or averaging the two years would fail to illustrate the taxa. variation in social benefits due to taxa variations. The trophic level of a taxa may vary based on changes in feeding habits through its The trophic levels used to model the food chain transfers were taken from life cycle, variation in feeding opportunities in space and time, and inclusion of the SeaAroundUs.org database. These values reflect the range of dietary multiple species based on the inability to perform definitive identifications. habits of the species based on their position in the ecosystem. The values No systematic bias is associated with the use of consensus trophic levels. correspond well with the trophic levels of other sources (e.g., Any divergence in the actual trophic levels are likely to be distributed It is common practice in modeling of food chain dynamics to assign an average fishbase.org). These parameters represent a consensus approach from a about the consensus value, suggesting that some parameters may be high Trophic levels trophic level to a species based on its range of feeding habits. Trophic levels are creditable source. and some low. typically expressed to the tenths place (e.g., 3.2). When necessary, alternative sources for trophic levels were obtained from Failure to model the taxa in the absence of a literature trophic level It is also common practice to assign trophic levels based on best professional the literature or developed based on best professional judgment. Such an would underestimate potential benefits. judgment when the data are missing or when individual species may be considered alternative is more appropriate than omitting the organism from the under a single higher-level category (e.g., family rather than species). modeling. There are recognized inconsistencies of the 10-percent trophic transfer efficiency with the estimates developed for recreational and commercial A trophic transfer efficiency of 10 percent was chosen due to the wide species. In particular, it is specified that higher trophic level species are The trophic transfer approach interprets observed average biomasses at different use of the value and support for application in food web modelling under fishing pressure from above (humans), rendering them unlikely to trophic levels. Typically, a 10-to-1 forage to predator ratio is applied. Additional Trophic transfer efficiency (Pauly, and Christensen, 1995). To account for variations in the trophic be constrained by forage availability. options include a blended transfer efficiency of 2.5 percent as was presented by levels, a modified transfer efficiency was applied as detailed in EPA (2002). Section 11.2.2. Use of the 10-percent trophic transfer is likely to provide an overestimate of increased C/R stocks. No alternative approach is viewed as more realistic. The literature often states the need to exercise caution when choosing and assigning life history parameters when doing EA and production foregone modelling as small changes in these parameters can have a large impact on the To the extent possible, reliance was placed on accepted sources of life final EA numbers or production foregone biomass (EPRI, 2012). Also, the number The values chosen for each species modelled was based on a thorough cycle parameters (e.g., EPRI, 2012; prior analysis by EPA). These of life stages chosen can also greatly affect these end results. Having mortalities literature search of accredited sources as well as a consideration of the parameters include the number of life stages as well as the life stage-associated with each individual life stage, especially when the mortality differs biology of each species. Each suite of life history parameters was tested specific survival rates and sizes. Each set of parameters was checked for between life stages, is felt to be the best way to model the population. This for balance and adjusted if necessary. Fishing mortality rates were balance. Life history parameters methodology also allows one to apply the proper weights and growth rates of each modified to reflect local conditions if site specific data were available. life stage to more closely model how growth progresses. Given the nature of the biological modeling, errors in parameterization Model application made no attempt to consider "compensation," the may result in substantial changes in the model estimates. While this Potential differences in growth and survival by location. phenomena of reproductive success and recruitment increasing at lower potential is acknowledged, this assessment attempted to minimize errors population densities and decreasing at higher densities. by relying on parameters developed by recognized authorities. Also, ensuring the parameters are balanced (i.e., the modeled population is stable) is important and was a crucial part of determining the appropriate life history parameter values. Choosing a different age for the EA target could have an important effect Age of equivalence is the ultimate age of the organism considered in the modeling. C/R taxa age of equivalence was assumed to be the age at which the on the final numbers and biomass of EAs. If the age is set too low, the Given that mortality prior to the age of equivalence acts to limit the number of given taxa experience the maximum C/R harvest. For C/R species, it is numbers would be overestimated, and if set too high, the numbers would organisms at that age, the assumed age of equivalence has an important effect on reasonable to define the age of equivalence at the point at which the be underestimated. As noted previously, errors in biomass under these Age of equivalence the resulting population and social benefits. On the other hand, as organisms age, organism is subject to maximum harvest. Such an approach accounts for circumstances are likely to be muted given the growth of organisms as their mass generally increases potentially mitigating mortality when considering harvest patterns as well as fishing regulations. they age. It is difficult to quantify the potential errors associated with biomass. A number of candidate ages of equivalence could be considered (e.g., age these factors. It is likely the selected age of equivalence results in at maturity, a fixed age [e.g., Age-1], onset of C/R harvest, etc.). Age of equivalence for forage species was chosen as age of maturity. overestimates for some taxa and underestimates for others. Y:\GDP\F1301\150595\316BR\11.DOCX033121 11-60

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Table 11-23. Uncertainties of Benefits Valuation Study (Continued, Page 2 of 2) Category of Input Range of Variation or Options Rationale for Value Chosen Sensitivity of Alternative Choice The identification of early life stages of fish and shellfish is difficult and in many cases was not possible or only made to the family level. While eggs typically have a very low survival rate, it is likely that the great The choice was made to include the large proportion of unknown eggs majority of the eggs collected in entrainment samples are not viable. observed in the PSL data by spreading the unidentified organisms across While distributing the unidentified eggs across the know taxa may result the identified taxa for the same life stage in the proportions that they are The two options available include incorporating unidentified taxa/lifestages into in potential error, the alternative of excluding those eggs from the Identification of early life found in entrainment samples. the entrainment data using the proportions that identified taxa are found in the assessment was viewed as unacceptable, as it would result in an stages entrainment samples or to exclude the unidentified lifestages entirely. underestimate of social benefits. This choice was made since viable or not, these unidentified life stages still contribute to the forage base as biomass and thus, there consideration Year 1: Less than 0.1 percent of shellfish were not identified. Over 84% of all in the benefits valuation was deemed appropriate entrained fish were not identified. All of which were eggs. Year 2: Nearly 93% of all fish were not identified. Of which 99.9 percent were eggs. Through the benefits valuation process, surrogates were used in two places: application of FMS exclusion efficiency and survival and modelling of EA and production foregone. The choice of surrogate for modeling purposes made every In general, the fish and invertebrate groupings were distributed into effort to maintain the taxa within the same Family if data at the species level were the surrogates based on the proportion of the surrogate taxa to the whole While use of modeling parameters derived from surrogate species results not available. Additionally, some surrogates were selected based on commercial or sample. This was done to provide a meaningful range to the potential in potential error, the alternative of excluding those organisms from the recreational importance or contribution to the forage base. However, many parameters. Application of surrogates assessment was viewed as unacceptable, as it would result in an identified taxa did not have Family surrogates, and they were subsequently placed underestimate of social benefits. into the fish or invertebrate grouping, as appropriate. These groupings The choice to exclude taxa as surrogates was based on knowledge of the accounted for less than 2 percent of the identified taxa in the entrainment. These species' life histories and observations of the type and size of organisms groupings were then distributed into the surrogates that did have life history actually being entrained at PSL. parameters for modelling. The error associated with this approach is not well understood. In the modeling of production foregone for C/R species, the assumption The alternative approach of applying increased biomass of forage shellfish was made that a single taxon, Spanish mackerel, would benefit from the to a spectrum of C/R species is likely to overestimate their increase in reduction in the losses of forage shellfish. This was done largely on harvest due to inappropriate assumptions regarding their residence in the biological grounds based on: (1) the knowledge that Spanish mackerel use area and/or their predator-prey relationship with the forage shellfish. The When modeling the potential impacts of the loss of forage biomass, it is possible to the nearshore Atlantic Ocean as feeding grounds; and (2) based on their approach selected is believed to be more realistic. consider the contribution of biomass as production foregone of a variety of C/R taxa. trophic position, they are likely to feed on forage fish and shellfish that are Approaches considered included: (1) distribution of production foregone among included in entrainment. In addition, they have a strong presence within Selection of a predator taxa that is relatively high in the food chain (i.e., C/R taxa that were subject to entrainment in proportion to their rate of C/R landings; the C/R landings of St. Lucie County (FWC, 2020). Spanish mackerel) does result in loss of biomass associated with greater and (2) application of production foregone to a single C/R taxon understood to have change in trophic levels and the attending reduction in trophic transfer. Applying forage biomass to C/R relevance and is biologically appropriate (i.e., it is known to prey on the forage The alternative approach of distributing forage shellfish among a set of C/R This is believed to be realistic and acceptable based on the attributes of C/R taxa species entrained). species was rejected because of the tenuous biological connections the taxa. implied. For example, some C/R species are known to feed and be subject Also, the model used assumes all natural mortality is a result of being consumed by to harvest in offshore waters (e.g., penaeid shrimp) and/or unlikely to prey It is important to highlight that this approach assumes all foregone predators and that no biomass is released to the environment (decomposition and in a substantial way on forage shellfish due to their similar trophic levels production of forage shellfish is consumed by C/R species. This is consumption by benthic organisms/bacteria) or completely removed from the (e.g., penaeid shrimp). certainly not the case and, therefore, results in an overestimate of potential environment (e.g., eaten by land-based predators). benefits. To take into account all possible causes of natural mortality is not possible due to the complex nature of such interactions and lack of available The assumption that all natural mortality is a result of being consumed by information on the topic in the location of PSL. predators overestimates the potential benefits. Source: ECT, 2021. Y:\GDP\F1301\150595\316BR\11.DOCX033121 11-61

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Appendix 11-A Surrogate Taxa Life History Summary Y:\GDP\F1301\150595\316BR\11.DOCX033121

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) This appendix provides life history information for taxa chosen as surrogates for the benefits valuation study. Surrogates used at PSL include Atlantic silverside, bay anchovy, Atlantic menhaden, hogchoker, mojarra, naked goby, Sciaenidae, Anomuran crabs, blue crab, Brachyuran crabs, grass shrimp, and Penaeid shrimp. In addition, Spanish mackerel was used as the predator to which the forage biomass was applied. Atlantic menhaden (Brevoortia tyrannus) Common Names: Atlantic menhaden Similar Species: Herring, shad, and sardines. Appearance: Atlantic menhaden are small silvery fish with brassy sides and a dark bluish green back. A black spot is located behind gill opening followed along lank by approximately 6 lines of smaller spots. Length: 15 inches Geographic Range: Estuaries and coastal waters from northern Florida to Nova Scotia. Habitat: Adult and juveniles form large, near-surface schools, primarily in estuaries and nearshore ocean waters from early spring through early winter. IN summer, schools stratify by size and age along coast with older menhaden found farther north. During fall through early winter, menhaden of all sizes and ages migrate south to North Carolina capes to spawn Lifespan: Eight years Fecundity: Estimated annual fecundity of 22,000 to 62,000. Food Source: Efficient filter feeders that feed on plankton (Algae and small aquatic invertebrates). Taxonomy: KingdomAnimalia Phylum Chordata Class Actinopterygii Order Clupeiformes Family Clupeidae Genus Brevoortia Speciestyrannus Sources of Information: Chesapeake Bay Program (2019) Fishbase (2019) ASMFC (2019) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Atlantic silverside (Menidia menidia) Common Names: Atlantic silverside, capucette Similar Species: Bay anchovy. Appearance: Atlantic silversides are small fish with a short head, large eyes, and a small, toothless mouth. They are small bodied with a round, translucent to white belly and are greyish green above with a metallic silver stripe along both sides. Length: 6 inches Geographic Range: Atlantic coast from Gulf of St. Lawrence to northeastern Florida Habitat: Prefer brackish or saltwater but can tolerate changes in salinity. Generally found foraging in dense schools along the shoreline or hiding in seagrass beds. Found in deeper waters in the winter and shallow waters in the summer. Lifespan: Two years Fecundity: Estimated total fecundity is 4,725 to 13,525 with an annual fecundity of 4,500 to 5,000. Food Source: Algae and small aquatic invertebrates. Taxonomy: KingdomAnimalia Phylum Chordata Class Actinopterygii Order Atheriniformes Family Atherinopsidae Genus Menidia Speciesmenidia Sources of Information: Chesapeake Bay Program (2019) Fishbase (2019) USFWS (1983) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Bay anchovy (Anchoa mitchilli) Common Names: Common anchovy, Mitchills anchovy, whitebait, little anchovy. Similar Species: Atlantic silverside. Appearance: The bay anchovy has a slender, silvery-green, translucent body. A silver stripe runs along its sides. The bay anchovy has a large mouth, a single dorsal fin on its back, and a forked tail fin. Length: Adult length is approximately 2.95 inches. Can grow to 4 inches. Geographic Range: One of the most abundant species in estuaries along the mid-Atlantic Ocean region and throughout the Gulf of Mexico. Bay anchovy range from Maine to the coastal Gulf of Mexico to Yucatan, Mexico. Habitat: Bay anchovies tolerate a wide range of temperatures and salinities. They are found along both the Atlantic and Gulf coasts of Florida. Adult anchovies inhabit shallow to moderately deep offshore water, nearshore waters off sand beaches, open bays, and muddy coves. Often appears in higher densities in vegetated areas such as eelgrass beds. Lifespan: Up to 2 years. Fecundity: The anchovy spawning period is long and typically occurs in water less than 20 meters deep. Anchovies generally spawn in the evening between 6 p.m. and 9 p.m. Females can produce 44 to 3,963 eggs. Anchovy eggs are pelagic and found throughout the water column, but they tend to concentrate near the surface. Food Source: Bay anchovies feed mostly on mysis and copepods, also small fishes, gastropods, and isopods. Taxonomy: KingdomAnimalia PhylumChordata SubphylumVertebrata ClassOsteichthyes OrderClupeiformes FamilyEngraulidae GenusAnchoa SpeciesMitchilli Sources of Information: Chesapeake Bay Program (2012) Fishbase (2019) Morton (1989) FWS (2019) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Hogchoker (Trinectes maculatus) Common Names: Freshwater Flounder, Freshwater Sole, Hogchoker Similar Species: Pleuronectes maculatus, Achirus fasciatus Appearance: The hogchoker has a flat, rounded body that grows to approximately 6 inches in length. It is a dark brownish-gray on top and pale on the bottom, with narrow, black vertical lines or spots on the top side of its body. It has a rounded head with a small mouth. Both its small eyes are located on the top side of its body. Its dorsal and anal fins stretch around its body from its head to its rounded tail fin. Length: 6 inches Geographic Range: Atlantic coast from Massachusetts to Yucatan, Mexico Habitat: Coastal waters (to approximately 75 m), estuaries, and coastal rivers; may range hundreds of miles upstream. Found in both shallow and deep waters. Bottom-dwellers that prefer sandy, silty or muddy bottoms. Lifespan: Estimated anywhere from 6-12 years along Atlantic Coast, usually 7 years Fecundity: Has been estimated at 10,000 to 34,000 eggs Food Source: Hogchokers eat worms and crustaceans. Taxonomy: KingdomAnimalia Phylum Chordata Class Actinopterygii Order Pleuronectiformes Family Achiridae Genus Trinectes Speciesmalculatus Sources of Information: Chesapeake Bay Program (2019) IUCN (2013) Hassan-Williams et al. (2007) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Mojarras (Representative: Eugerres plumieri) Common Names:. Striped mojarra, mojarra Similar Species: Diapterus plumieri. Appearance: rather deep-bodied fish, dark olive above and tan to silvery on the sides, often with a metallic sheen. Bold black stripes run along the scale rows (excluding the belly). All fins except for the pectoral fins are dusky in large adults; the pelvic and anal fins are sometimes dark orange. The pectoral fin is transparent. Length: common length: 30.0 cm TL male/unsexed Geographic Range: This species is distributed in the western Atlantic from Emerald Isle, North Carolina south along the U.S. coast, in the Gulf of Mexico from the Florida Keys to Crystal River, Florida and from Matagorda Bay, Texas along the northern Yucatan to northwestern Cuba, in the Caribbean from Cuba to Puerto Rico (except the Cayman Islands), and along the Central and South American coast from Quintana Roo, Mexico to Colombia. Habitat: inhabits shallow coastal waters in mangrove-lined creeks and lagoons (Randall and Vergara 1978). It prefers fine, sandy substrates and lower salinity (Rueda 2001). It is common in brackish waters and often enters a considerable distance into freshwater. Lifespan: Up to 2 years. Fecundity: This species has high fecundity, producing 85,345 to 953,870 eggs. Food Source: It feeds on aquatic insects, crustaceans, micro-bivalves and detritus. Taxonomy: KingdomAnimalia PhylumChordata SubphylumVertebrata Class Actinopterygii OrderPerciformes Family Gerreidae Genus Eugerres Species plumieri Sources of Information: Fishbase (2019) Fraser and Gilmore (2015) Sobczak (2017) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Naked goby (Gobiosoma bosc) Common Names: Naked Goby. Similar Species: code goby (G. robustum). Appearance: Ground color light tan to nearly black, usually brown; body with 9-10 vertical bars separated by narrow lighter interspaces, bars faint or indistinct in specimens with light or dark ground color; fins dusky. Body shape is short and stout; body depth contained fewer than seven times in standard length. Length: common length: 4.1 cm TL male/unsexed. Geographic Range: Western Atlantic: Massachusetts to Florida, (not Florida Keys), Everglade City, Florida along Gulf of Mexico coast to Veracruz, Mexico. Habitat: Inhabit estuaries and weedy, protected coastal waters and rivers, with salinity ranging from 0.0 to 33.0 ppt. Marine; brackish; demersal. Tropical; 11°C - 33°C. Lifespan: 4 years. Fecundity: Ovaries of females (27-35 mm SL) collected in Georgia contained from 701-1,382 eggs; egg diameters ranged from 0.112-0.720 mm; most nests contained 332-2,000 eggs, but three others had 3.933, 8,000, and over 9,000 eggs (Dahlberg and Conyers 1973). Egg with a bundle of adhesive eggs attached to the egg membrane serving to attach the egg to submerged objects. Food Source: Adults feed mainly on annelids and small crustaceans; also attracted to injured or dead oysters. Taxonomy: KingdomAnimalia PhylumChordata SubphylumVertebrata Class Actinopterygii OrderPerciformes Family Gobiidae Genus Gobiosoma Speciesbosc Sources of Information: Fishbase (2019) van Tassell (2015) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Spanish mackerel (Scomberomorous maculatus) Common Names: Spanish mackerel, Mackerel, Spotted cybium, Bay mackerel, Spotted mackerel. Similar Species: king mackerel, cero. Appearance: Spanish mackerel have a blueish green back fading to silver on the sides and belly with irregular yellow spots on the sides. They have a bluish-black blotch on the front of the first dorsal fin and a lateral line that slopes from behind the gill cover to the tail. Length: up to 36 inches. Geographic Range: Found in the western Atlantic from Canada to Mexico. Habitat: Found inshore, offshore and nearshore in Florida waters. Frequently over grass beds and reefs. Lifespan: Up to 12 years. Fecundity: Spanish mackerel are mature and reproducing by age 2 and spawn from April to September. They batch spawn throughout the season and a single female may have 500,000 to 1.5 million eggs in a season. Food Source: Feeds on small fish and invertebrates. Taxonomy: KingdomAnimalia PhylumChordata SubphylumVertebrata ClassTeleostei OrderPerciformes FamilyScombridae GenusScomberomorus Speciesmaculatus Sources of Information: Fishbase (2019) FWC (2019) NOAA (2019) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Silver perch (Bairdiella chrysoura) Common Names: Silver perch, silver croaker. Similar Species: Closely related to other drums such as red drum, black drum, spotted seatrout, weakfish, spot, and Atlantic croaker. Appearance: Silvery, greenish, or bluish above, bright silvery to yellowish on belly. Lower fins mostly yellowish to dusky. Mouth terminal, moderately large and oblique. Chin without barbel. Length: Adult length can be up to 11.8 inches. Geographic Range: Found along the U.S. Atlantic coast, through the Gulf of Mexico, and into northern Mexico. Silver perch are one of the top five most abundant species of sciaenids in estuaries along the Gulf of Mexico and the Atlantic coast of the U.S. Habitat: Silver perch favor estuarine and coastal waters with sandy or muddy substrates and use estuaries as nurseries and feeding areas during the warmer months. Juveniles settle in shallow seagrass beds. Silver perch may retreat to deeper bay waters in the colder months and often will migrate to warmer waters during especially cold winters. Lifespan: Up to 5 years. Fecundity: Silver perch spawn from March to May in nearshore environments. Females produce 151 to 1,387 eggs. The eggs of the silver perch are buoyant and the larvae are pelagic. Food Source: Silver perch feed mainly on crustaceans, worms, and occasionally fishes. Taxonomy: KingdomAnimalia PhylumChordata SubphylumVertebrata ClassActinopterygii (ray-finned and spiny rayed fishes) OrderPerciformes FamilySciaenidae GenusBairdiella Specieschrysoura Sources of Information: Fishbase (2019) Neely, J.A. (2015) Waggy et al. (2006) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-8

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Sand seatrout (Cynoscion arenarius) (Drums and croakers) Common Names: Sand seatrout, white trout. Similar Species: Weakfish. Appearance: Pale yellowish color above, silvery below, without well-defined spots. The center of the scales above the gill opening sometimes forms faint, oblique rows of cloudy areas. The back of a young sand seatrout is cloudy, with the cloudy areas tending to form indefinite crossbands. Sand seatrout have a large mouth, oblique, with lower jaw slightly projecting. The inside of the mouth is yellow. Length: Adult length is 12 to 15 inches. Geographic Range: West coast of Florida, Gulf of Mexico to Texas and as far south as the Gulf of Campeche, Mexico. Habitat: Sand seatrout are one of the most abundant fishes in the estuarine and nearshore waters of the Gulf of Mexico. Young sand seatrout are found in shallow bays of the Gulf Coast, especially in reduced salinity. Lifespan: Up to 3 years. Fecundity: In a prolonged period of spawning during spring and late summer, sand seatrout spawn in the lower estuarine environments or inshore waters of the Gulf of Mexico. Sand seatrout have a mean fecundity of 100,990 eggs. Post-spawn adults and post-larvae move into estuarine environments, often riding incoming tides. The inshore movement of young sand seatrout coincides with rising sea levels in the Gulf caused by surface currents and prevailing inshore winds. This movement facilitates the transport of eggs and larvae from inshore spawning areas to estuarine and gulf nurseries. Food Source: Sand seatrout feed mainly on small fish and mysid shrimp. Taxonomy: KingdomAnimalia PhylumChordata SubphylumVertebrata ClassActinopterygii (ray-finned and spiny rayed fishes) OrderPerciformes FamilySciaenidae GenusCynoscion SpeciesArenarius Sources of Information: Arenarius Technical Task Force (2011) McClane (1998) Sutter and McIlwain (1987) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-9

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Spotted seatrout (Cynoscion nebulosus) (Drums and croakers) Common Names: Speckled seatrout, spotted weakfish, seatrout, spotted seatrout, spotted squeteague, spotted trout Similar Species: Otolithus nebulosus Appearance: Body color is silvery, with the dorsal surface a darker gray tinged with blue. Many small black spots are scattered over the dorsal surface of the body above the lateral line and extend onto the dorsal and caudal fins. The spinous dorsal fin is dusky in color, while all other fins are pale to yellowish in color. The dorsal fin has 12 spines and 25-28 soft rays, with the spinous portion of the fin separated from the soft dorsal fin by a deep notch. The anal fin has 2 spines and 10-11 rays. Length: Maximum length of 100 cm Geographic Range: This species is distributed in the western Atlantic from Long Island, New York south along the U.S. coast and throughout the Gulf of Mexico except for Cuba Habitat: Occurs in shallow coastal and estuarine areas. Lifespan: The lifespan is approximately 18 years Fecundity: Fecundity increases with size in Cynoscion nebulosus. In Florida, Moody (1957) reported a 39.7 cm (15.6 inches) female collected at Cedar Key contained 464,000 eggs. Tabb (1961) reported 15,000 - 1.1 million eggs per female from a collection of females, Food Source: Consume fish and shrimp Taxonomy: KingdomAnimalia PhylumChordata SubphylumVertebrata Class Actinopterygii Order Perciformes Family Sciaenidae Genus Cynoscion Species nebulosus Sources of Information: SMS (2005) Chao et al. (2015) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-10

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Anomuran crabs (Pea crabs, Representative: Pinnotheres pisum) Common Names: Pea Crab, Oyster Crab Similar Species: Pinnotheres ostreum, Austinotheres angelicus Appearance: The body of the female is pinkish white and up to 2 cm (approximately 0.75 inch) across. An irregular stripe runs from front to back across the carapace, or back. Males, seldom seen, are smaller, dark brown, Length:. For P. Pisum, Females grow up to a maximum of 13 millimeters in length and the males only 6 millimeters. For P.maculatus, 2cm. Geographic Range: Found in oysters of the Atlantic coastal waters of North America and are especially abundant in oysters of Chesapeake Bay. P. pisum, found in European coastal waters Habitat:. Found in the shells of scallops, clams, and mussels. Living in the mantle cavity of certain bivalve mollusks, echinoderms, and polychaetes as a commensal Lifespan: Up to 2 years. Fecundity: Mean fecundity was 2677 in Stage I and 4890 embryos in females with brood masses in Stage III (Reproductive traits of the symbiotic pea crab Austinotheres angelicus (Crustacea, Pinnotheridae) living in Saccostrea palmula (Bivalvia, Ostreidae), Pacific coast of Costa Rica) Food Source:. Pea Crabs steal food from their host (oysters, mussels, etc.) in order to survive. Feed on plankton brought in by host. Taxonomy: KingdomAnimalia Phylum Arthropoda Subphylum Crustacea Class Malacostraca Order Decapoda Family Pinnotheridae Genus Pinnotheres Speciespisum Sources of Information: Encyclopedia Britannica (2008) Encyclopedia of Life (2017). Pangea Shellfish & Seafood Company, Inc. (2016) Salas-Moya et al. (2017) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-11

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Blue crab (Callinectes sapidus) Common Names: Blue Crab, Atlantic blue crab, Chesapeake blue crab. Similar Species: Callinectes similis, Callinectes ornatus Appearance: Body color is bright blue along the frontal area, especially along the chelipeds. Remainder of body is an olive brown color. Fifth leg is adapted to a paddle-shape. Females have broad triangular or rounded aprons and red fingers on the chelae. Length: 120 to 170mm. Geographic Range: Western Atlantic Ocean from Nova Scotia to Argentina. Mostly found in Cape Cod to Uruguay. Has been introduced to Hawaii and Japan. Habitat: Ranges from salt water of gulf to the freshwater of back bays. Favors estuaries. Can be found at low tide line to 120ft deep. Lifespan: 1 - 2 years. Fecundity: Females mate only once in their lifetime, producing 2-8 million eggs per spawn. Incubation time is 14-17 days. Food Source: Clams, oysters, and mussels. Also any vegetation or animal matter. Sometimes eat young crabs. Taxonomy: KingdomAnimalia Phylum Arthropoda Subphylum Crustacea Class Malacostraca Order Decapoda Family Portunidae Genus Callinectes Species sapidus Sources of Information: Bluecrab.info (2010) Bodden (2017) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-12

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Brachyuran crab (Representative: Panopeus herbstii) Common Names: Mud Crab, Atlantic Mud Crab. Similar Species: Florida stone crab, Menippe mercenaria. The strongtooth mud crab, Panopeus bermudensis; Say mud crab, Dyspanopeus sayi; Florida grassflat crab, Neopanope packardii; and the flatback mud crab, Eurypanopeus depressus. Appearance: The fingers, or top and bottom portions of the closable claw, are usually black to brown in most species; whereas, the interior portion at the base of the claw, called the palm, is usually pale. The claws are distinctly unequal in size, and the body is brownish. The carapace of P. herbstii is brownish green and slightly granular in texture. Their shells vary in color from dark blue-green to mottled brown. They have five teeth lining the outside of the carapace on each side, the first two mostly fused Length: Widths of 3-4 cm Geographic Range: The range of P. herbstii extends from Massachusetts to Brazil Habitat: Most populations inhabit muddy bottoms, mainly in mangrove swamps and oyster beds. However, both adults and juveniles can also be found on jetty rocks, shell or cobble bottoms, and marsh edges. In oyster beds and under rocks, individuals may excavate shallow burrows to a depth of 4-10 cm Lifespan: Unknown. Fecundity:. Fecundity ranged between 32,105 and 165,826 eggs per female with a mean (+/-SE) of 97,736 +/- 6,850 eggs/female. Food Source: The diet of the Atlantic mud crab is primarily carnivorous. Individuals prey on a variety of organisms, including: oysters and clams; crustaceans; annelid worms; fishes; and the marsh periwinkle Taxonomy: KingdomAnimalia Phylum Arthropoda Subphylum Crustacea Class Malacostraca Order Decapoda Family Panopeidae Genus Panopeus Species herbstii Sources of Information: Marine Education Society of Australasia (2014) SMS (2009) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-13

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Grass shrimp (Caridea) Representative: Palaemonetes pugio Common Names: common grass shrimp, grass shrimp, daggerblade grass shrimp, Similar Species: Pandalus kessleri, Palaemon spp., Macrobrachium spp., marsh grass shrimp (Palaemonetes vulgaris), brackish grass shrimp (Palaemonetes intermedius) Appearance: The common grass shrimp has a segmented, nearly transparent body that is compressed on either side. It has a pointed, serrated horn that extends over its eyes. Its first two pairs of walking legs have claws. It has well-developed eyes with globular pigmented corneas and some slight yellow pigmentation in the eyestalks. Length: The shrimp grows to 1.5 inches in length. Geographic Range: Found throughout most of the Chesapeake Bay and its tidal rivers. Habitat: Shallow waters, often among bay grass beds. May move to warmer, deeper waters in winter. Lifespan: Grass shrimp live approximately one year. Fecundity: Fecundity in P. pugio is reportedly variable depending on geographic location. Females collected from Rhode Island in June averaged 486 eggs per female, while in Texas the average was only 372 eggs/female and only up to 247 in South Carolina. Usually spawns in summer, when water temperatures warm. Females must molt before mating. Food Source: Grass shrimp forage for worms, algae and tiny crustaceans. Taxonomy: KingdomAnimalia Phylum Arthropoda Class Malacostraca Order Decapoda Family Palaemonidae Genus Palaemonetes Speciespugio Sources of Information: Chesapeake Bay Program (2019) SMS (2008) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-14

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Penaeid shrimp (Representative: Farfantepenaeus duorarum) Common Names: Pink shrimp, spotted shrimp, northern pink shrimp. Similar Species: Brown shrimp, white shrimp. Appearance: Pink shrimp can be distinguished from other families of shrimp by their antennae, which are longer than their body lengths, and by their first three pairs of walking legs. Overall body color varies, but generally it is gray, bluish, or red-brown. The sides of pink shrimp are somewhat flattened. The carapace has a medial carina that extends nearly to its posterior end and is bordered by a broad, rounded groove on either side. The rostrum bears 6-7 sharp teeth on the dorsal surface. Ventrally, the rostrum may have 1-3 teeth. The abdomen has 4-6 carinate segments, with the carina of the sixth segment ending in a spine. A dark, distinct spot between the 3rd and 4th abdominal segments distinguishes pink shrimp. Its tail is edged with blue. Length: Females grow to 11 inches long, and males grow to 10.6 inches long. Geographic Range: Pink shrimp range from the lower Chesapeake Bay, Maryland to the tip of the Yucatan Peninsula, Mexico, and have major centers of abundance along the west coast of Florida and in the Bay of Campeche. Habitat: Pink shrimp are most abundant in waters of 36-121 feet, although in some areas they may be abundant as deep as 213 feet. Pink shrimp are common in the estuaries and shallow marine waters of southern Florida and into deep water (approximately 100 meters) southeast of the Florida Keys. Pink shrimp are the dominant species within the Dry Tortugas shrimping grounds and Florida Bay. They prefer sand, sand-shell, or coral-mud bottoms. Growth of pink shrimp is optimal at 30-percent salinity. Lifespan: Pink shrimp live an average of 16 months. Fecundity: Pink shrimp begin reproducing at age 6-8 months. They migrate offshore to spawn in the spring and continue spawning migration throughout the summer. A female can release 215,000 to 1 million eggs every 3 days. Food Source: Juvenile pink shrimp eat bivalves, calcareous algae, plant detritus, copepods, and seagrass fragments. Adults eat copepods, small mollusks, benthic diatoms, algae, detritus, bacterial films, slime molds, and yeast. Taxonomy: KingdomAnimalia PhylumAnthropoda ClassMalacostraca OrderDecapoda FamilyPenaeidae GenusPenaeus SpeciesDuorarum Sources of Information: Encyclopedia of Life (2012) McMillen-Jackson and Bert (2004) Laramore et al. (2016) NOAA Sustainable Fisheries Partnership (2013) McClane (1998) Turrell Associates (undated) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-15

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Stone crab (Menippe mercenaria) Common Names: Florida stone crab. Similar Species: Mud crabs. Appearance: Stone crabs have exoskeletons and have a brown and black speckled carapace that is oval, smooth, and convex. Adult females and are smaller than adult males. The Florida stone crab has a large crusher claw with an enlarged basal tooth. The smaller pincer claw has many small teeth that can be used for cutting. Adult Florida stone crabs have a trunk composed of 14 segments and 5 pairs of stout walking legs that have reddish and yellow bands and distal hairs. Juveniles appear dark purplish-blue and have a white spot on the carpus when they are very young. Length: Adults can reach 51/2 to 6 inches carapace width (the widest part of the body). Geographic Range: Stone crabs range from Cape Lookout in North Carolina southward and throughout the Gulf of Mexico to the Yucatan Peninsula. Habitat: Stone crab larvae are planktonic and are found in nearshore coastal waters and within estuaries. Larvae are sensitive to lower salinities. Juveniles live beneath shell fragments in deeper water. As they mature, they move into the shallower waters and live in the crevices of rocks, jetties, pilings, and oyster shell rubble. Adult Florida stone crabs live in seagrass beds or rocky substrate in higher salinity waters. Lifespan: Up to 6 to 7 years. Fecundity: Spawning is believed to occur from November to March in Florida and is believed to be regulated by photoperiod and temperature. Single females can produce up to six egg masses or sponges during a single season. Each egg sponge may contain 160,000 to 1,000,000 eggs. Oyster reefs and seagrass beds may be important habitat for spawning. Food Source: The larvae and pre-juvenile stone crabs feed on smaller zooplankton. Juvenile and adult stone crabs feed on animals that are larger than the zooplankton. Adult stone crabs feed on acorn barnacles, hard shelled clams, scallops, and conch. Taxonomy: KingdomAnimalia PhylumArthropoda ClassMalacostraca OrderDecapoda Family Xanthidae GenusMenippe Speciesmercenaria Sources of Information: Brinkman (2002) Key Largo Fisheries (2010) LGL Ecological Research Associates, Inc. and Science Applications International Corporation (1998) McClane (1998) Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-16

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) References Arenarius Technical Task Force. 2011. The Sand and Silver Seatrout Fishery of the Gulf of Mexico, United States: A Fisheries Profile. Ocean Springs, MS: Gulf States Marine Fisheries Commission. Available at http://www.gsmfc.org/publications/GSMFC%20Number%20197.pdf. Retrieved on May 26, 2017. Bluecrab.Info. 2010. Blue Crab Taxonomy. Available at http://www.bluecrab.info/taxonomy.html. Retrieved on Oct. 12, 2017. Bodden, Samantha. 2017. Callinectes sapidus (Blue crab). Animal Diversity Web. Available at http://animaldiversity.org/accounts/Callinectes_sapidus/. Retrieved on Oct. 12, 2017. Brinkman, Michael. 2002. Menippe Mercenaria. Available at http://animaldiversity.org/accounts/Menippe_mercenaria/. Retrieved on May 26, 2017. Chesapeake Bay Program. 2019. Field Guide for Fish. Available at https://www.chesapeakebay.net/discover/field-guide/all/fish/all. Retrieved on July 31, 2019. Chao, L., Espinosa-Perez, H. & Barbieri, L. 2015. Cynoscion nebulosus. The IUCN Red List of Threatened Species 2015: e.T193266A49237289. http://dx.doi.org/10.2305/IUCN.UK.2015-2.RLTS.T193266A49237289.en. Retrieved on Oct. 12, 2017. DeVoretz, D.J., and K.G. Salvanes. 1993. Market Structure for Farmed Salmon. American Journal of Agricultural Economics 75:227-233. Encyclopedia Britannica. 2008. Pea crab. Available at http://www.britannica.com/animal/pea-crab. Retrieved on Oct. 12, 2017. Encyclopedia of Life. 2012. Farfantepenaeus duorarum. Available at http://eol.org/pages/325037/details. Retrieved on May 30, 2017. Encyclopedia of Life. 2017. Pea Crab - Pinnotheres pisum - Overview. Available at http://eol.org/pages/1022523/overview. Accessed October 12, 2017. FDEP. 2015. Notice of Draft Permit - FPL Lauderdale Plant. March 19, 2015. Fishbase. 2019. Froese, R. and D. Pauly. Editors. 2019. FishBase. World Wide Web electronic publication. www.fishbase.org, version (02/2019). Fraser, T. & Gilmore, G. 2015. Eugerres plumieri. The IUCN Red List of Threatened Species 2015: e.T185997A1801333. http://dx.doi.org/10.2305/IUCN.UK.2015-2.RLTS.T185997A1801333.en. Retrieved on Dec 7, 2017. FWC, 2019. Species Profiles. Florida Fish and Wildlife Conservation Commission. https://myfwc.com/wildlifehabitats/profiles/. Accessed October 2019. Hassan-Williams, Carla and Timothy H. Bonner. 2007. Texas Freshwater Fishes. Available at http://txstate.fishesoftexas.org/index.htm. Retrieved on Oct. 12, 2017. Key Largo Fisheries. 2010. Stone Crab Facts. Available at http://www.stonecrabflorida.com/stone-crab-facts.html. Retrieved on May 26, 2017. Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-17

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Laramore, Susan, William Krebs, and Amber Garr. 2016. Effects of Exposure of Pink Shrimp, Farfantepenaeus duorarum, Larvae to Macondo Canyon 252 Crude Oil and the Corexit Dispersant. J. Mar. Sci. Eng. 4(24) doi:10.3390/jmse4010024. LGL Ecological Research Associates, Inc. and Science Applications International Corporation. 1998. Cumulative Ecological Significance of Oil and Gas Structures in the Gulf of Mexico: Information Search, Synthesis, and Ecological Modeling; Phase I, Final Report. U.S. Dept. of the Interior, U.S. Geological Survey, Biological Resources Division, USGS/BRD/CR-- 1997-0006 and Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA, OCS Study MMS 97-003 6. Marine Education Society of Australasia. 2014. "Mariculture in Australia." Available at http://www.mesa.edu.au/aquaculture/aquaculture07.asp. Accessed October 12, 2017. McClane, A.J. 1998. McClanes New Standard Fishing Encyclopedia and International Angling Guide. New York: Gramercy Books. McMillen-Jackson, Anne and Theresa M Bert. 2004. Genetic diversity in the mtDNA control region and population structure in the pink shrimp (Farfantepenaeus duoraru). Journal of Crustacean Biology. 24(10): 101-109. Morton, T. 1989. Species Profiles: Life Histories and Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic)Bay Anchovy. U.S. Fish and Wildlife Service Biological Report 82(11.97), 13 pp. IUCN. 2013. Trinectes maculatus. The IUCN Red List of Threatened Species 2013: e.T190082A18130930. http://dx.doi.org/10.2305/IUCN.UK.2013-1.RLTS.T190082A18130930.en. Retrieved on Oct 12, 2017. NatureServe. 2019. NatureServe Explorer: An online encyclopedia of life [web application]. Version 7.1. NatureServe, Arlington, Virginia. Available http://explorer.natureserve.org. (Accessed: July 31, 2019 ). Neely, J.A. 2015. Silver Perch. Available at http://dnr.sc.gov/swap/supplemental/marine/silverperch2015.pdf. Retrieved on May 26, 2017. NOAA. 2019. Species Directory. NOAA Fisheries. https://www.fisheries.noaa.gov/species-directory. Accessed October 2019. NOAA Sustainable Fisheries Partnership. 2013. Gulf of MexicoFlorida Shrimp Fishery Improvement Project 2013. NRC. 2010. U.S. Nuclear Regulatory Commission License Amendment to Increase the Maximum Reactor Power Level, Florida Power & Light Company, St. Lucie, Units 1 and 2. Docket ID NRC-2011-0302 [7590-01-P] Pangea Shellfish & Seafood Company, Inc. 2016. What are pea crabs and why are they in my oysters? Available online: https://www.pangeashellfish.com/blog/what-are-pea-crabs-and-why-are-they-in-my-oysters. Accessed October 12, 2017. Salas-Moya, Carolina, et al. 2017. Reproductive traits of the symbiotic pea crab Austinotheres angelicus (Crustacea, Pinnotheridae) living in Saccostrea palmula (Bivalvia, Ostreidae), Pacific coast of Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-18

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Costa Rica. ZooKeys, Pensoft Publishers, 2014, www.ncbi.nlm.nih.gov/pmc/articles/PMC4283374/. Accessed October 12, 2017. Smithsonian Marine Station (SMS). 2005. "Cynoscion nebulosus." Available at http://www.sms.si.edu/irlspec/cynosc_nebulo.htm. Retrieved on Oct. 12, 2017. Smithsonian Marine Station (SMS). 2009. "Panopeus herbstii." Available at http://www.sms.si.edu/irlspec/Panope_herbsti.htm. Accessed October 12, 2017. Smithsonian Marine Station (SMS). 2008. "Palaemonetes pugio." Available at http://www.sms.si.edu/irlspec/Palaemonetes_pugio.htm. Accessed October 12, 2017. Sobczak, Charles. 2017. Living Sanibel: Lizardifsh and Striped Mojarra. Available at http://santivachronicle.com/Content/Default/Outdoor/Article/LIVING-SANIBEL-Charles-Sobczak-Lizardfish-and-Striped-Mojarra/-3/35/6092. Retrieved on Dec 7, 2017. U.S. Fish and Wildlife Service (FWS). 2019. Freshwater Fish of America. Accessed Online July 2019. https://www.fws.gov/fisheries/freshwater-fish-of-america.html. USFWS. 1983. Species Profiles: Life Histories and Environmental Requirements of Coastal Fishes and Invertebrates: Atlantic Silverside. Accessed Online July 31, 2019. https://www.nrc.gov/docs/ML0720/ML072060414.pdf. Sutter, F.C., and T.D. McIlwain. 1987. Species Profiles: Life Histories and Environmental Requirements of Coastal Fishes and Invertebrates (Gulf of Mexico)Sand Seatrout and Silver Seatrout. U.S. Fish and Wildlife Service Biological Report 82(11.72). U.S. Army Corps of Engineers, TR EL-82-4, 16 pp. Turrell Associates. Undated. Pink Shrimp. Available at www.turrell-associates.com/media/docs/Shrimp-AH.pdf. Retrieved on May 30, 2017. van Tassell, J., Aiken, K.A. & Tornabene, L. 2015. Gobiosoma bosc. The IUCN Red List of Threatened Species 2015: e.T186012A1803788. http://dx.doi.org/10.2305/IUCN.UK.2015-2.RLTS.T186012A1803788.en. Retrieved on Oct. 12, 2017. Waggy, Gretchen L., Nancy J. Brown-Peterson, and Mark S. Peterson. 2006. Evaluation of the Reproductive Life History of the Sciaenidae in the Gulf of Mexico and Caribbean Sea: Greater versus Lesser Strategies? 57th Gulf and Caribbean Fisheries Institute, pp. 263-281. Wessells, C.R., and J.L. Anderson. 1992. Innovations and Progress in Seafood Demand and Market Analysis. Marine Resource Economics 7:209-288. Wessells, C.R., and J.E. Wilen. 1994. Seasonal Patterns and Regional Preferences in Japanese Household Demand for Seafood. Canadian Journal of Agricultural Economics 42:87-103. Y:\GDP\F1301\150595\316BR\11.DOCX033121 A-19

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Appendix 11-B Entrainment Reduction Benefits Study: St. Lucie Nuclear Power Plant Y:\GDP\F1301\150595\316BR\11.DOCX033121

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Appendix 11-C Baseline Condition, Modeling Results Expressed as Benefits of Technology Y:\GDP\F1301\150595\316BR\11.DOCX033121

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Annualized Entrainment Counts - Baseline Condition Sample Year 1 Sample Year 2 Scientific Name Common name Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total FISH Abudefduf saxatilis Sergeant major 266,581 266,581 Acanthostracion Scrawled cowfish 172,946 172,946 quadricornis Scrawled sole Achiridae 10,092,354 10,092,354 14,013,597 14,013,597 (family) Achirus lineatus Lined sole 13,848,141 13,848,141 2,456,945 4,024,079 8,729,740 15,210,763 Broad-striped Anchoa hepsetus 3,021,088 1,267,395 272,276 4,560,759 anchovy Anchoa mitchilli Bay anchovy 33,603,403 33,603,403 719,750 719,750 Anchoa spp. Anchovy (genus) 903,866 13,118,429 11,446 14,033,741 Anisotremus Black margate 73,124 73,124 surinamensis Anisotremus virginicus Porkfish 172,946 345,892 518,839 Cardinalfish Apogonidae 133,291 133,291 (family) Atherinopsidae Silverside (family) 172,946 172,946 Bairdiella chrysoura Silver perch 371,501 371,501 656,317 4,651,896 5,308,213 Bathygobius soporator Frillfin goby 2,524,157 2,524,157 1,983,925 13,051,798 15,035,722 Combtooth blenny Blenniidae 17,523,916 66,550,760 130,746,220 12,736,766 227,557,662 41,614,196 628,851,666 18,182,457 688,648,319 (family) Blennioidei Blenny (suborder) 59,066,087 55,747,017 12,736,766 127,549,870 Bregmaceros cantori Striped codlet 139,461 139,461 Bregmaceros houdei Stellate codlet 8,309,309 15,168,276 23,477,585 Bregmaceros spp. Codlet 114,198 114,198 Bregmacerotidae Codlets (family) 107,431 107,431 Brevoortia spp. Menhaden 24,984,050 24,984,050 Callionymidae Dragonet (family) 114,198 114,198 Canthigaster rostrata Sharpnose puffer 111,341 111,341 Carangidae Jack (family) 1,055,010 16,521,209 17,576,219 1,269,947 399,928 1,669,875 Centropomus spp. Snook spp. 2,273,006 2,273,006 4,256,390 4,256,390 Centropomus Common snook 1,002,430 4,984,025 5,986,455 undecimalis Centropristis striata Black sea bass 281,802 281,802 Chaetodipterus faber Atlantic spadefish 2,356,488 2,356,488 5,752,441 2,327,146 8,079,587 Chloroscombrus Atlantic bumper 371,501 371,501 28,692,331 14,880,179 43,572,509 chrysurus Chromis spp. Chromis 228,397 228,397 Citharichthys Angelfin whiff 73,124 73,124 gymnorhinus Citharichthys spilopterus Bay whiff 2,697,558 2,697,558 Citharichthys spp. Whiff (genus) 1,544,408 1,544,408 692,858 292,498 985,356 Clupeidae Herring (family) 507,367,603 333,417,690 218,999,331 1,059,784,623 866,548,214 95,313,886 602,394,169 1,564,256,269 Anchovies and Clupeiformes 2,969,398 2,969,398 330,713 330,713 herrings (order) Congridae Conger eels (family) 4,590,561 4,590,561 Coryphopterus spp. Goby species 9,958,125 9,958,125 Ctenogobius boleosoma Darter goby 11,339,765 11,339,765 402,120,935 402,120,935 Ctenogobius spp. True goby 293,694 293,694 Cynoglossidae Tonguefish 1,055,010 1,055,010 451,933 1,141,555 1,593,487 Cynoscion regalis Weakfish 2,356,488 2,356,488 5,345,759 5,345,759 Cynoscion spp. Seatrout 51,777,517 51,777,517 107,431 107,431 Dactyloscopidae Stargazer (family) 444,395 444,395 518,120 5,147,858 5,665,978 Decapterus macarellus Mackerel scad 107,431 107,431 Decapterus punctatus Round scad 114,198 114,198 Diodontidae Burrfish (family) 248,939 248,939 Y:\GDP\F1301\150595\316BR\11.DOCX033121 C-1

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Sample Year 1 Sample Year 2 Scientific Name Common name Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Diplogrammus Spotted dragonet 5,600,831 5,600,831 10,814,848 10,814,848 pauciradiatus Doratonotus megalepis Dwarf wrasse 2,481,198 2,481,198 Dormitator maculatus Fat sleeper 36,767,297 36,767,297 Eleotridae Sleeper (family) 1,154,087 1,154,087 Elops saurus Ladyfish 4,182,541 4,182,541 Elops spp. Ladyfish species 174,434 174,434 Engraulidae Anchovy (family) 2,914,367 5,453,023 32,033,274 5,944,006 46,344,670 39,103,920 20,446,462 24,343,440 83,893,821 Etropus crossotus Fringed flounder 345,892 345,892 Smallmouth Etropus microstomus 707,182 707,182 flounder Eucinostomus spp. Mojarra (genus) 757,079 757,079 35,769,662 35,769,662 Exocoetidae Flyingfish (family) 496,069 496,069 Gerreidae Mojarra (family) 444,395 444,395 456,045 456,045 Gobiesox strumosus Skilletfish 240,722 240,722 Gobiidae Goby (family) 16,834,985 16,834,985 864,703 21,073,265 120,279,409 142,217,377 Gobioides broussonnetii Violet goby 623,401 623,401 Gobionellus oceanicus Highfin goby 1,120,559 1,120,559 Gobiosoma ginsburgi Seaboard goby 6,077,639 50,864,854 56,942,493 Gobiosoma robustum Code goby 2,186,224 2,186,224 Gobiosoma spp. Naked gobies 1,167,882 1,167,882 Gymnothorax spp. Morays 73,124 73,124 Haemulidae Grunt (family) 9,839,203 9,839,203 5,773,645 891,151 6,664,796 Haemulon plumierii Grunt 73,124 73,124 Haemulon spp. Grunt 3,231,480 3,231,480 Halichoeres spp. Wrasse 316,308 316,308 Harengula jaguana Scaled herring 340,187 340,187 Hemiramphidae Halfbeak (family) 165,356 165,356 Hippocampus erectus Lined seahorse 293,120 293,120 Featherduster Hypleurochilus multifilis 707,182 707,182 blenny Labridae Wrasse (family) 577,228 577,228 456,793 456,793 Labrisomid blenny Labrisomidae 3,357,892 3,357,892 122,472,882 8,773,913 131,246,795 (family) Labrisomus nuchipinnis Hairy blenny 143,362 143,362 Cichlids and Labroidei surfperches 11,782,435 11,782,435 (suborder) Lachnolaimus maximus Hogfish 73,124 73,124 Lagodon rhomboides Pinfish 5,604,073 5,604,073 Leiostomus xanthurus Spot 3,975,300 3,975,300 Lophiiformes Anglerfish (order) 1,823,990 1,823,990 Lutjanidae Snapper (family) 6,133,505 9,460,447 15,593,952 Lutjanus spp. Snapper (genus) 5,944,006 5,944,006 292,498 1,376,516 1,669,013 Lutjanus synagris Lane snapper 171,249 171,249 Megalops atlanticus Atlantic tarpon 172,946 172,946 Menticirrhus americanus Southern kingfish 3,058,757 3,058,757 Menticirrhus littoralis Gulf kingfish 143,362 143,362 Menticirrhus spp. Kingfish 172,946 7,043,270 7,216,216 Microdesmidae Dartfish (family) 4,002,308 222,196 4,224,504 Microdesmus bahianus Bahaia wormfish 589,365 8,459,674 9,049,039 Microdesmus lanceolatus Lancetail wormfish 2,077,327 2,077,327 Microdesmus longipinnis Pink wormfish 1,443,754 1,443,754 Microdesmus spp. Wormfish 354,322 114,198 468,521 Microgobius thalassinus Green goby 9,898,796 9,898,796 Micropogonias Atlantic croaker 258,650 26,941,062 27,199,712 undulatus Monacanthidae Filefish (family) 2,356,488 2,356,488 330,713 330,713 Monacanthus ciliatus Fringed filefish 574,289 574,289 Y:\GDP\F1301\150595\316BR\11.DOCX033121 C-2

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Sample Year 1 Sample Year 2 Scientific Name Common name Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Myctophidae Lanternfish (family) 246,071 246,071 Myrophis punctatus Speckled worm eel 1,496,777 1,496,777 12,303,867 834,686 7,966,726 21,105,279 Nes longus Orangespotted goby 14,242,393 14,242,393 Ophichthidae Snake eel (family) 1,557,952 1,557,952 Ophidiidae Cusk eels (family) 1,633,332 1,633,332 Ophidion josephi Crested cusk eel 1,642,407 1,642,407 Ophidion selenops Mooneye cusk-eel 139,461 139,461 Ophidion spp. Cusk-eel (genus) 73,124 219,373 292,498 Orthopristis chrysoptera Pigfish 3,535,910 3,535,910 651,331 365,622 1,016,953 Paralichthyidae Flounder (family) 35,139,215 4,837,686 39,976,901 1,807,732 3,320,813 5,128,545 Paralichthys albigutta Gulf flounder 194,855 194,855 Paralichthys lethostigma Southern flounder 89,748 89,748 Paralichthys oblongus Fourspot flounder 3,332,267 2,587,608 692,442 6,612,317 Largetooth Paralichthys spp. 307,710 89,748 171,249 568,707 flounders Pareques spp. Paraques genus 1,322,850 1,322,850 Pareques umbrosus Cubbyu 1,443,754 1,443,754 Perch-like fishes Perciformes 979,749 131,556,999 132,536,748 (order) Righteye flounders Pleuronectidae 1,689,302 1,689,302 (family) Pomacentridae Damselfish (family) 40,777,987 10,484,274 51,262,261 5,236,407 73,124 5,309,531 North American Prionotus spp. 114,198 8,124,878 8,239,076 searobin Psilotris alepis Scaleless goby 222,683 222,683 Ptereleotris spp. Dartfish 172,946 172,946 Rachycentron canadum Cobia 4,394,274 4,394,274 Rhynchoconger gracilior Whiptail conger 194,855 194,855 Sardinella brasiliensis Orangespot sardine 6,831,054 6,831,054 Saurida brasiliensis Brazilian lizardfish 278,921 278,921 Scaridae Parrotfish (family) 133,291 7,852,765 7,986,056 Scartella cristata Molly miller 669,597 669,597 Sciaenidae Drum (family) 28,331,817 5,331,692 76,201,049 109,864,558 380,358,826 24,098,604 25,645,154 430,102,584 Sciaenops ocellatus Red drum 2,330,416 2,330,416 4,054,528 7,280,662 11,335,189 Scombridae Mackerel (family) 1,202,186 1,544,408 2,746,594 266,581 2,265,942 2,532,523 Scorpionfishes and Scorpaenidae 2,044,524 2,044,524 allies Mail-cheeked fishes Scorpaeniformes 6,177,628 6,177,628 (order) Selar crumenophthalmus Bigeye scad 1,141,555 1,141,555 Selene setapinnis Atlantic moonfish 371,501 371,501 Serraniculus pumilio Pygmy sea bass 418,382 418,382 Serranidae Grouper (family) 3,467,611 15,207,228 18,674,839 Subfamily of Serraninae 4,451,906 4,451,906 groupers Sparidae Porgy (family) 6,278,970 5,777,198 12,056,167 Sphoeroides maculatus Northern puffer 222,196 222,196 Sphoeroides nephelus Southern puffer 145,664 145,664 Sphoeroides spp. Pufferfish spp. 468,089 468,089 114,198 1,050,376 Sphoeroides testudineus Checkered puffer 172,946 172,946 Sphyraena barracuda Great barracuda 330,713 330,713 Sphyraena spp. Barracuda (genus) 4,994,707 4,994,707 Stellifer lanceolatus American stardrum 193,608 6,133,142 6,326,750 Blackcheek Symphurus plagiusa 444,395 444,395 825,733 825,733 tonguefish Tonguefishes Symphurus spp. 6,610,595 6,610,595 278,921 278,921 (family) Syngnathus louisianae Chain pipefish 1,141,555 1,141,555 Synodontidae Lizardfishes 1,544,408 1,544,408 28,878,861 258,650 29,137,511 Y:\GDP\F1301\150595\316BR\11.DOCX033121 C-3

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Sample Year 1 Sample Year 2 Scientific Name Common name Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Synodus foetens Inshore lizardfish 194,855 73,124 267,979 Tetraodontidae Pufferfish (family) 3,266,661 3,266,661 888,082 8,766,618 9,654,700 Tetraodontiformes Filefish (order) 9,353,074 9,353,074 Thalassoma bifasciatum Bluehead 903,866 903,866 Triglidae Searobin (family) 1,141,555 1,141,555 Umbrina coroides Sand drum 2,188,773 2,188,773 Unidentified Unidentifiable 12,031,357,870 1,120,150 282,387 7,232,312 12,039,992,720 Unidentified eggs Unidentifiable eggs 2,590,795,426 2,590,795,426 Unidentified fish Unidentifiable fish 8,879,330 6,427,130 12,745,094 28,051,554 Fish Total 3,188,284,267 188,240,814 1,052,059,953 9,761,903 263,161,963 4,701,508,900 13,422,297,605 1,032,336,748 1,653,646,761 11,769,105 272,276 7,232,312 16,127,554,807 SHELLFISH Albunea spp. Mole crab 223,392,837 223,392,837 445,293,713 445,293,713 Anomuran crab Anomura 3,244,601,007 246,063,856 109,485,527 3,600,150,390 3,774,078,058 155,510,821 3,929,588,879 (non-Thalassinidea) Arcidae Arc clam (family) 38,908,646 38,908,646 Speckled swimming Arenaeus cribrarius 22,137,111 22,137,111 crab Ghost shrimps Axiidea 573,990,990 573,990,990 (infraorder Axiidea) Bivalvia Bivalve 4,414,367 4,414,367 Brachyuran crab Brachyura (Non-CRI) 43,662,869,788 1,367,541,019 286,991,077 2,600,710 45,320,002,594 72,593,135,701 1,373,035,849 1,167,780,793 75,133,952,342 (infraorder) Swimming crab Callinectes spp. 16,897,622 60,278,010 52,339,617 129,515,250 190,830,043 9,250,928 200,080,971 (Callinectes genus) Cardiidae Cockle 5,944,006 5,944,006 Caridea Caridean shrimp 2,528,574,458 1,871,781,532 206,996,099 146,494,980 4,753,847,069 6,630,926,491 3,190,135,426 338,729,620 22,032,105 10,181,823,643 Decapod crabs Decapoda 89,574,540 89,574,540 (order) Pea crab Dissodactylus spp. (Dissodactylus 1,496,777 1,496,777 genus) Emerita spp. Sand crab 21,584,607 21,584,607 1,123,128,042 23,100,065 1,146,228,108 Emerita talpoida Common mole crab 136,033,399 136,033,399 Euphausiacea Krill (order) 94,908,590 2,109,482 97,018,073 Farfantepenaeus aztecus Brown shrimp 2,739,686 2,739,686 50,327,746 50,327,746 Farfantepenaeus Pink shrimp 7,110,300 7,110,300 14,220,600 26,282,073 26,282,073 duorarum Panaeid shrimp Farfantepenaeus spp. (Farfantepenaeus 364,774,476 107,951,172 472,725,648 genus) Burrowing shrimps Gebiidea (infraorder 1,722,710,120 98,128,328 1,820,838,449 Gebiidea) Gonodactylid mantis Gonodactyloidea shrimps 2,176,404 2,176,404 (superfamily) Lepidopa benedicti Mole crab 36,754,498 36,754,498 Lepidopa spp. Mole crab 6,544,661 6,544,661 Lepidopa websteri A sand crab 93,128,770 93,128,770 Loliginid squid Loliginidae 347,241,794 167,342 347,409,136 (family) Lysiosquillid mantis Lysiosquilloidea shrimps 58,912,581 58,912,581 (superfamily) Mactridae Surf clam (family) 55,940,128 55,940,128 Menippe mercenaria Florida stone crab 2,138,476,803 2,138,476,803 Menippe spp. Stone crab 49,393,647 49,393,647 498,893,698 498,893,698 Opossum shrimp Mysida 89,688,922 2,811,421,930 1,977,381,845 4,878,492,697 (order) Y:\GDP\F1301\150595\316BR\11.DOCX033121 C-4

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Sample Year 1 Sample Year 2 Scientific Name Common name Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Mytilidae Mussel (family) 22,600,615 22,600,615 Penaeid shrimp Penaeidae 1,060,229,009 755,348 866,904 1,061,851,261 211,074,316 23,100,065 234,174,381 (family) Portunid crab Portunidae 22,137,111 22,137,111 (family) Iridescent Portunus gibbesii 371,501 371,501 swimming crab Portunid crab Portunus spp. 3,774,569 3,774,569 (genus) Rimapenaeus constrictus Roughneck shrimp 274,687,902 274,687,902 Sergestoidea Sergestoid shrimp 2,386,752,952 1,509,393,544 220,752,487 4,116,898,982 7,194,364,235 4,343,615,921 1,431,362,164 10,795,016,010 23,764,358,330 Solecurtidae Saltwater clams 12,721,653 12,721,653 A Solenocerid Solenocera spp. 903,866 903,866 shrimp Squilla empusa Mantis shrimp 28,560,135 9,011,913 707,182 38,279,230 Mantis shrimp Squilloidea 182,278,538 22,137,111 204,415,649 (superfamily) Tellinidae Tellin clam 8,989,686 8,989,686 Ghost and mud Thalassinidea 1,873,502,294 164,712,550 37,703,797 2,075,918,641 shrimp (infraorder) Unidentified crab Unidentifiable crab 2,651,234 1,496,777 4,148,011 Unidentified Unidentifiable 13,514,413 1,795,944 15,310,357 meroplankton meroplankton Veneridae Venus clams 3,357,892 43,403,991 46,761,883 Shellfish total 57,766,960,420 5,352,193,598 889,809,239 370,219,678 64,379,182,936 96,136,816,489 9,419,375,841 5,784,624,456 12,796,539,443 124,137,356,228 Grand total 3,188,284,267 57,955,201,234 6,404,253,551 899,571,142 370,219,678 263,161,963 69,080,691,836 13,422,297,605 97,169,153,237 11,073,022,602 5,796,393,561 12,796,811,719 7,232,312 140,264,911,036 Y:\GDP\F1301\150595\316BR\11.DOCX033121 C-5

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Annualized Entrainment Counts of Surrogates - Baseline Condition Proportion Sample Year 1 Sample Year 2 Surrogate of Post-larvae/ Post-larvae/ Eggs Larvae Juvenile Adult Taxa Total Eggs Larvae Juvenile Adult Taxa Total Surrogates Megalopae Megalopae FISH Atlantic silverside 0.00% 0 0 0 0 0 0 0 0 182,480 0 0 182,480 Bay anchovy 3% 15,833,011 7,955,792 90,695,374 0 0 114,484,177 388,830,281 22,441,792 43,822,917 9,648,933 272,276 465,016,201 Bluegill 0.00% 0 0 0 0 0 0 0 0 0 0 0 0 Atlantic menhaden 61% 2,849,372,849 0 501,867,446 0 0 3,351,240,295 8,616,532,309 100,186,493 669,528,514 0 0 9,386,247,316 Hogchoker 2% 197,235,968 0 47,406,061 0 0 244,642,029 217,944,383 11,467,696 14,979,498 0 0 244,391,577 Mojarra 0.19% 0 0 1,495,536 0 0 1,495,536 0 0 38,222,621 0 0 38,222,621 Naked goby 12% 95,055,489 182,214,012 297,991,089 313,545 0 575,574,135 422,389,430 822,147,338 746,858,902 0 0 1,991,395,670 Sciaenidae 21% 175,952,695 7,367,053 153,894,862 8,976,066 0 346,190,676 3,783,746,660 75,433,262 129,440,817 2,126,214 0 3,990,746,953 Silver perch 0.03% 0 0 0 498,671 0 498,671 0 689,869 4,908,328 0 0 5,598,198 Spot 0.00% 0 0 0 0 0 0 0 0 0 0 0 0 Weakfish 0.35% 0 0 67,383,380 0 0 67,383,380 0 0 5,753,792 0 0 5,753,792 Fish total 3,333,450,012 197,536,857 1,160,733,749 9,788,282 0 4,701,508,900 13,429,443,063 1,032,366,450 1,653,697,870 11,775,147 272,276 16,127,554,807 SHELLFISH Anomuran crabs 4% 0 3,253,172,164 246,287,249 140,156,246 0 3,639,615,659 0 3,787,759,272 155,510,821 0 0 3,943,270,093 Blue crab 0.3% 0 16,942,260 60,332,735 67,001,771 371,501 144,648,267 0 281,421,064 22,137,111 35,163,625 0 338,721,799 Brachyuran crabs 65% 0 44,031,899,849 1,368,782,563 367,387,299 2,600,710 45,770,670,421 0 74,560,750,754 1,396,135,914 1,167,814,576 0 77,124,701,243 Grass shrimp 27% 0 6,806,763,535 3,549,106,818 313,248,881 367,247,467 11,036,366,701 0 14,546,732,441 7,623,440,269 4,581,646,255 12,796,539,443 39,548,358,407 Penaeid shrimp 2% 0 1,464,532,535 127,684,234 2,015,042 0 1,594,231,812 0 2,459,450,747 222,151,728 0 0 2,681,602,475 Stone crab 1.4% 0 2,193,650,076 0 0 0 2,193,650,076 0 500,702,211 0 0 0 500,702,211 Shellfish total 0 57,766,960,420 5,352,193,598 889,809,239 370,219,678 64,379,182,936 0 96,136,816,489 9,419,375,841 5,784,624,456 12,796,539,443 124,137,356,228 Y:\GDP\F1301\150595\316BR\11.DOCX033121 C-6

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Entrainment Equivalent Adults of Surrogate Groupings - Baseline Condition Sample Year 1 Sample Year 2 Surrogate Post-larvae/ Post-larvae/ Eggs Larvae Juvenile Adult Taxa Total Eggs Larvae Juvenile Adult Taxa Total Megalopae Megalopae FISH Sciaenidae 50 36 3,844 94,314 98,243 1,065 369 3,233 22,341 27,007 Spot 0 0 Weakfish 2,639 2,639 225 225 Fish total 50 36 6,482 116,624 0 123,192 1,065 485 6,777 22,341 0 30,667 SHELLFISH Blue crab 0.04 87,252 560,903 648,155 0 45,791 45,791 Penaeid shrimp 211,518 121,585 12,393 345,496 355,211 211,540 566,751 Stone crab 1,535 1,535 350 350 Shellfish total 0 213,053 121,585 99,646 560,903 995,187 0 355,561 211,540 45,791 0 612,893 Entrainment Foregone Production (kg) of Surrogate Groupings - Baseline Condition Sample Year 1 Sample Year 2 Surrogate Post-larvae/ Post-larvae/ Eggs Larvae Juvenile Adult Taxa Total Eggs Larvae Juvenile Adult Taxa Total Megalopae Megalopae FISH Atlantic silverside 0 8 8 Bay anchovy 4 6 684 694 93 17 331 8,607 406 9,453 Bluegill 0 0 Atlantic menhaden 120,468 489,120 609,588 364,297 13,324 652,523 1,030,144 Hogchoker 2,374 8,414 10,788 2,623 4,694 7,317 Mojarra 642 642 16,413 16,413 Naked goby 355 2,137 5 2,497 1,576 6,984 0 8,560 Silver perch 880 880 7 191 0 198 Fish total 123,200 10,558 490,446 885 0 625,089 368,588 25,034 669,457 8,607 406 1,072,092 SHELLFISH Anomura crabs 179,927 29,589 209,516 202,746 0 202,746 Brachyuran crabs 452,341 102,220 632,583 57,092 1,244,237 765,965 104,263 2,010,794 0 2,881,022 Grass shrimp 7,035 225,815 47,742 280,592 15,034 713,577 1,663,550 2,392,161 Shellfish total 0 459,376 507,962 662,173 104,835 1,734,345 0 780,999 1,020,586 2,010,794 1,663,550 5,475,928 Y:\GDP\F1301\150595\316BR\11.DOCX033121 C-7

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Appendix 11-D Closed-cycle Cooling, Modeling Results Expressed as Benefits of Technology Y:\GDP\F1301\150595\316BR\11.DOCX033121

Florida Power & Light Company Clean Water Act §316(b) Compliance Submittal St. Lucie Nuclear Power Plant FL0002208 40 CFR 122.21(r)(2) through (13) Annualized Entrainment Counts - Closed-cycle Cooling Sample Year 1 Sample Year 2 Scientific Name Common name Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total Eggs Larvae Post-larvae Juvenile Adult Unknown Taxa Total FISH Abudefduf saxatilis Sergeant major 196,604 196,604 Acanthostracion Scrawled cowfish 127,548 127,548 quadricornis Scrawled sole Achiridae 7,443,111 7,443,111 10,335,028 10,335,028 (family) Achirus lineatus Lined sole 10,213,004 10,213,004 1,811,997 2,967,758 6,438,183 11,217,938 Broad-striped Anchoa hepsetus 2,228,052 934,703 200,804 3,363,560 anchovy Anchoa mitchilli Bay anchovy 24,782,510 24,782,510 530,815 530,815 Anchoa spp. Anchovy (genus)}}