ML12097A268
| ML12097A268 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/17/2012 |
| From: | Susco J NRC/NRR/DLR/RERGUB |
| To: | Dohner C US Dept of Interior, Fish & Wildlife Service |
| Balsam B | |
| References | |
| Download: ML12097A268 (105) | |
Text
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NUCLEAR REGULATORY COMMISSION
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Ms. Cindy Dohner Southeast Regional Director U.S. Fish and Wildlife Service 1875 Century Blvd., Suite 400 Atlanta, GA 30345-3319
SUBJECT:
BIOLOGICAL ASSESSMENT FOR FORMAL SECTION 7 CONSULTATION AT THE ST. LUCIE PLANT, UNITS 1 AND 2
Dear Ms. Dohner:
On March 26,2012, the U.S. Nuclear Regulatory Commission (NRC, the staff) requested initiation of formal section 7 consultation under the Endangered Species Act of 1973, as amended (ESA), at St. Lucie Plant, Units 1 and 2 (St. Lucie). St. Lucie is located on Hutchinson Island in St. Lucie County, Florida. The NRC requested initiation of formal consultation because Florida Power and Light Company, which owns and operates St. Lucie, intends to construct a sheet pile seawall to protect the facility's cooling water discharge canal, and this project may affect nesting leatherback (Oermoche/ys coriacea), loggerhead (Caretta caretta), and green (Chelonia mydas) sea turtles.
With this letter, the NRC transmits its biological assessment to support the previous request for consultation. The biological assessment concludes that the discharge headwall project may affect, but is not likely to adversely affect, the three sea turtle species. NRC did not identify any other Federally listed species that have the potential to be affected by the project.
Please contact Ms. Briana Balsam, Biologist, of my staff with any questions you may have on this project. You can reach her at 301-415-1042 or bye-mail atBriana.Balsam@nrc.gov. The NRC has coordinated with Mr. Jeffrey Howe at the U.S. Fish and Wildlife Service Vero Beach Field Office and is forwarding him a copy of this letter and the enclosed biological assessment.
Sincerely, Jeremy J. Susco, Acting Chief Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389
Enclosure:
Biological assessment cc w/encl: Listserv
Identical letter sent to:
Mr. Larry Williams Vero Beach Field Supervisor U.S. Fish and Wildlife Service 1339 20th St.
Vero Beach, FL 32960
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UNITED STATES
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~ ~ April 17,2012 1-" ~O Mr. Larry Williams Vero Beach Field Supervisor U.S. Fish and Wildlife Service 1339 20th St.
Vero Beach, FL 32960
SUBJECT:
BIOLOGICAL ASSESSMENT FOR FORMAL SECTION 7 CONSULTATION AT THE ST. LUCIE PLANT, UNITS 1 AND 2
Dear Mr. Williams:
On March 26,2012, the U.S. Nuclear Regulatory Commission (NRC, the staff) requested initiation of formal section 7 consultation under the Endangered Species Act of 1973, as amended (ESA), at St. Lucie Plant, Units 1 and 2 (St. Lucie). St. Lucie is located on Hutchinson Island in St. Lucie County, Florida. The NRC requested initiation of formal consultation because Florida Power and Light Company, which owns and operates St. Lucie, intends to construct a sheet pile seawall to protect the facility's cooling water discharge canal, and this project may affect nesting leatherback (Oermochelys coriacea), loggerhead (Caretta caretta), and green (Chelonia mydas) sea turtles.
With this letter, the NRC transmits its biological assessment to support the previous request for consultation. The biological assessment concludes that the discharge headwall project may affect, but is not likely to adversely affect, the three sea turtle species. NRC did not identify any other Federally listed species that have the potential to be affected by the project.
Please contact Ms. Briana Balsam, Biologist, of my staff with any questions you may have on this project. You can reach her at 301-415-1042 or bye-mail atBriana.Balsam@nrc.gov. The NRC has coordinated with Mr. Jeffrey Howe at the U.S. Fish and Wildlife Service Vero Beach Field Office and is forwarding him a copy of this letter and the enclosed biological assessment.
Jeremy J. Susco, Acting Chief Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389
Enclosure:
Biological Assessment cc w/encl: Listserv
Identical letter sent to:
Ms. Cindy Dohner Southeast Regional Director U.S. Fish and Wildlife Service 1875 Century Blvd., Suite 400 Atlanta, GA 30345-3319
Biological Assessment St. Lucie Plant, Units 1 and 2 Discharge Headwall Project April 2012 Docket Numbers 50-335, 50-389 U.S. Nuclear Regulatory Commission Rockville, Maryland Prepared by:
Briana Balsam Division of License Renewal Office of Nuclear Reactor Regulation
Table of Contents 1.0 Introduction .............................................................................................................1 2.0 Description of the Action ........................................................................................1 2.1 Site Location and Description ................................................................................1 2.2 Discharge Headwall Project Description ................................................................ 1 2.3 Project Timeline and Proposed Work Conditions ................................................... 4 2.4 State and Local Permits and Approvals ................................................................. 8 3.0 Action Area: Hutchinson Island ............................................................................. 8 4.0 Federally Listed Species Considered .................................................................... 9 4.1 Section 7 Consultation History and Listed Species Previously Considered ............ 9 4.2 Green Turtles ....................................................................................................... 11 4.3 Loggerhead Turtles .............................................................................................. 12 4.4 Leatherback Turtles ............................................................................................. 12 4.5 Sea Turtle Nesting Surveys ................................................................................. 13 5.0 Action Effects Analysis ......................................................................................... 19 6.0 Conclusion and Determination of Effects............................................................ 20 7.0 References ............................................................................................................. 21 Appendix A FDEP Permit for Construction ............................................................. A-1 Appendix B FPLs Sea Turtle Protection Plan......................................................... B-1 Appendix C St. Lucie County Land Development Code Chapter 6.04.02, Sea Turtle Protection .................................................................................................................. C-1 ii
Figures Figure 1. Geographic Location of St. Lucie Along the Florida Atlantic Coast ................... 2 Figure 2. St. Lucie Site Boundary ....................................................................................3 Figure 3. St. Lucie Cooling Water System Diagram ......................................................... 5 Figure 4. Discharge Headwall Project Boundaries........................................................... 6 Figure 5. Project Work Areas ..........................................................................................7 Figure 6. Green Turtle Florida Index Nesting Beach Survey Totals, 1989-2011 ............ 14 Figure 7. Loggerhead Florida Index Nesting Beach Survey Totals, 1989-2011 ............. 14 Figure 8. Leatherback Florida Index Nesting Beach Survey Totals, 1989-2011 ............. 15 Figure 9. Nesting Survey Beach Segments ................................................................... 17 Figure 10. Average Monthly Green Turtle Nests on Hutchinson Island, Beach Segments O and N, 2004-2011 ....................................................................................... 18 Figure 11. Average Monthly Loggerhead Nests on Hutchinson Island, Beach Segments O and N, 2004-2011 ....................................................................................... 18 Figure 12. Average Monthly Leatherback Nests on Hutchinson Island, Beach Segments O and N, 2004-2011 ....................................................................................... 19 Tables Table 1. Previously Considered Federally Listed Species ............................................. 10 Table 2. Sea Turtle Nest Survey Totals in St. Lucie County, 2007-2011........................ 15 Table 3. Sea Turtle Nest Survey Totals on Hutchinson Island Beach Segments N and O, 2002-2011 ....................................................................................................... 16 iii
Abbreviations, Acronyms, and Symbols cm centimeter DPS distinct population segment ESA Endangered Species Act of 1973, as amended FPL Florida Power and Light Company FR Federal Register fps feet per second ft foot FFWCC Florida Fish and Wildlife Conservation Commission FWS U.S. Fish and Wildlife Service in. inch(es)
INBS Index Nesting Beach Survey kg kilogram km kilometer lb pound m meter(s) m/s meters per second mi mile NMFS National Marine Fisheries Service NRC U.S. Nuclear Regulatory Commission SNBS Statewide Nesting Beach Survey iv
Biological Assessment of the Potential Effects on Sea Turtles from St.
Lucie Plant, Units 1 and 2, Discharge Headwall Project 1.0 Introduction The regulations that implement the Endangered Species Act of 1973, as amended (ESA) stipulate that Federal agencies must initiate formal section 7 consultation in cases where an action may affect listed species or critical habitat (50 CFR 402.14(a)).
Florida Power and Light Company (FPL), which owns and operates St. Lucie Plant, Units 1 and 2 (St. Lucie), intends to construct a sheet pile seawall (which is part of FPLs discharge headwall project) to protect the facilitys cooling water discharge canal. A series of storms and hurricanes between 2004 and 2005 have eroded the beach seaward of the cooling systems discharge canal. FPL undertook several dune restoration projects, but subsequent storms have eroded these restoration efforts. FPL intends to complete construction of the sheet pile seawall prior to the 2012 hurricane season to prevent further erosion. As such, FPL will need to perform work on the beach during sea turtle nesting season. The beach in the vicinity of St. Lucie is known nesting habitat for leatherback (Dermochelys coriacea), loggerhead (Caretta caretta),
and green (Chelonia mydas) sea turtles. Thus, this project has the potential to adversely affect listed sea turtles.
2.0 Description of the Action The action that this biological assessment considers is the construction of a sheet pile seawall to prevent further beach erosion near St. Lucies cooling water discharge canal. The following sections provide a site description and project details.
2.1 Site Location and Description St. Lucie lies on Hutchinson Island in St. Lucie County, Florida. The nearest municipalities to the north, west, and south are Fort Pierce, which is approximately 11 km (7 mi) northwest of the plant; Port St. Lucie, which is approximately 7 km (4.5 mi) to the west; and Stuart, which is approximately 13 km (8 mi) to the south. St. Lucie is located in a relatively flat, sheltered area of Hutchinson Island. Directly west of the facility, the land slopes downward, and mangroves cover the intertidal shoreline of the Indian River Lagoon. Dunes and ridges separate the facility from the Atlantic Ocean to the east. Figure 1 shows the location of St. Lucie along Floridas Atlantic Coast, and Figure 2 shows the St. Lucie site boundary and surrounding water bodies.
2.2 Discharge Headwall Project Description FPL intends to construct a sheet pile seawall and to restore eroded beach dunes to protect the seaward end of the facilitys cooling water discharge canal. The cooling system withdraws water from the Atlantic Ocean to cool the condensers of the two operating reactors. The Atlantic Ocean provides cooling and receiving waters for both units condensers and auxiliary cooling systems through common intake and discharge canals.
A series of storms and hurricanes between 2004 and 2005 have eroded the beach seaward of the cooling systems discharge canal (FPL 2012). Since that time, FPL has completed several dune restoration projects, but subsequent storms have eroded these restoration efforts. FPL intends to complete construction of the sheet pile seawall prior to the 2012 hurricane season to prevent further erosion (FPL 2012). As such, FPL will need to perform work on the beach during sea turtle nesting season. The beach near St. Lucie is known nesting habitat for the leatherback, loggerhead, and green sea turtles.
1
Figure 1. Geographic Location of St. Lucie Along the Florida Atlantic Coast (5-Mile Radius Map)
Figure Source: FPL 2011b 2
Figure 2. St. Lucie Site Boundary Figure Source: NRC 2003 3
On March 1, 2012, FPL constructed a sand dune seaward of the proposed seawall. The sand restores the dune profile, which is approximately 45 ft (14 m) from top to toe, and provides a stable seawall construction work area, which is immediately adjacent to the access road.
(FPL 2012)
The remaining work will be done in such a way as to avoid impacts to nesting sea turtles.
Contractors will access the work site from the canal maintenance access road (FPL 2011a).
FPL will do as much work as possible from the west side of the rigid coastal structure. Work in this area will not disturb the beach or dunes. The remainder of the project will involve an approximately 7- to 10-ft (2- to 3-m) beach area directly adjacent to the seaward side of the wall (FPL 2012). FPL will use this area to construct the seawall and support equipment and work activities. After May 1, FPL has committed to allowing only foot traffic (no vehicles) on the seaward side of the seawall (FPL 2011a). FPL will stage all equipment on the landward side of the dune (FPL 2011a). Figure 5 shows the maintenance road, staging area, and location of the restored dunes and future sheetpile seawall.
FPL will use a small drill rig and its associated support (wood cribbing) to drill in the tieback rods for the seawall. This activity may encroach or extend into beach area. FPL will also use hand tools to install the tieback rods and construct the concrete tie beams. Foot traffic associated with these activities will also occur during working hours (FPL 2012). FPL will excavate less than 4 to 5 ft (1.2 to 1.5 m) in depth along the length of the wall to support installation of the concrete tie beam at the top of the sea wall (FPL 2012).
A sheet pile installer, which rides on top of the installed sheets, will extend over the beach area directly adjacent to the seaward side of the wall and will not put excess pressure on the sand (FPL 2012). The initial sheets will require work from the ground, but FPL will start installing sheets on the wing walls west of the rigid coastal structure. The sheet pile installer uses a press-in method to penetrate the ground, which does not generate noise or vibration (Giken 2012). Dunkelberger Engineering, an independent engineering company, will also monitor vibration during the installation project to ensure that vibration is minimized (FPL 2012).
FPL may also install a fence about 10 ft (3 m) east of the seawall location to provide a visible work boundary for the contractor. This fence would also prevent female sea turtles from nesting within the fenced area. Figure 3 is a schematic of the St. Lucie cooling system. Figure 4 indicates the location of the proposed fence, which is identified as turtle barrier on the image.
(FPL 2012) 2.3 Project Timeline and Proposed Work Conditions Prior to May 1, 2012, FPL will complete installation of the seawall sheet pile and associated anchors. FPLs Florida Department of Environmental Protection (FDEP) construction permit stipulates that all work on this project seaward of the sheetpile seawall must be completed by May 30, 2012. By mid-June, FPL will install the concrete cap, tension the anchors, and brace the sheet piles. All work performed between May 30 and mid-June will be done from the landward side of the seawall.
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Figure 3. St. Lucie Cooling Water System Diagram Figure Source: NRC 2003 5
Figure 4. Discharge Headwall Project Boundaries Figure Source: FPL 2012 6
Figure 5. Project Work Areas Source: FPL 2011a 7
2.4 State and Local Permits and Approvals In addition to consulting with the U.S. Fish and Wildlife Commission (FWS) to ensure compliance with the ESA, FPL must obtain several State and local permits and approvals that include conditions to protect sea turtles.
The Florida Department of Environmental Protection (FDEP) requires a construction permit when construction activities occur seaward of the dune crest during the turtle nesting season (March 1 through November 15). The FDEP granted FPL final authorization to proceed with construction on March 13, 2012. Appendix A contains a copy of the construction permit.
Section 6.04.04 of St. Lucie Countys Land Development Code (LDC) requires that developers follow a sea turtle protection plan for all coastal development projects that occur during the sea turtle nesting season seaward of the primary dune or at night. The LDC 6.04.04 also includes standards for site development, beach access points, and lighting during nesting season.
Appendix B contains FPLs sea turtle protection plan, and Appendix C contains LDC 6.04.04.
3.0 Action Area: Hutchinson Island St. Lucie lies on Hutchinson Island in St. Lucie County, Florida. Hutchinson Island is a long, thin barrier island off the coast of mainland Florida that stretches from Fort Pierce to Stuart, Florida.
St. Lucie is located in a relatively flat, sheltered area of Hutchinson Island. Directly west of the facility, the land slopes downward, and mangroves cover the intertidal shoreline of the Indian River Lagoon. Dunes and ridges separate the facility from the Atlantic Ocean to the east. The seaward side of the dunes near St. Lucie has little to no vegetation, and the inland side of the dunes is dominated by sea oats (Unida paniculata), sea grape (Coccoloba uvifera), salt marsh hay (Spartina patens), Australian pine (Casuarina equisetifolia), marsh ox-eye (Barrichia frutescens), beach sunflower (Helianthus debilis), marsh elder (Iva frutescens), bay bean (Canaualia rosea), and railroad vine (Ipomoea pescaprae) (NRC 2003).
Prior to the 1930s, the mangrove swamps on the western side of the island were maintained by tidal and occasional storm-driven incursions of seawater, as well as by rain. The swales were dominated by red mangrove (Rhizophora mangle). Some black mangrove (Avicennia nitida) and white mangrove (Raguncularia racemosa) inhabited higher and less frequently flooded ground.
However, much of the natural mangrove swamps were destroyed during the 1930s and 1940s as part of a mosquito control program initiated by the Work Project Administration. The swamps were trenched, diked, and flooded with seawater to reduce mosquito populations. Since that time, the swales have been partially restored, but local mosquito control districts continue to maintain much of the area an inundated state. (NRC 2003)
A few small tropical hammock habitats exist on Hutchinson Island near the St. Lucie site, the largest of which is found in the mangrove stands north of the discharge canal. These habitats are unusual this far north. Prominent species include gumbo-limbo (Bursera simaruba),
paradise tree (Simarouba glauca), white and Spanish stoppers (Eugenia axillaris and E. foetida), wild lime (Zanthoxylum fagara), white indigo berry (Randia aculeata), mastic (Mastichodendron foetidissimum), and snow berry (Chiocococca alba). (NRC 2003) 8
The Atlantic nearshore and offshore marine communities in the vicinity of St. Lucie were studied in detail prior to the start of Unit 1 operation in 1976 (NRC 2003). Three subtidal Atlantic microhabitats exist within the discharge pipeline and thermal plume area: shallow beach terrace, Pierce Shoal (approximately 2 mi (1.6 km) from shore), and a 30- to 40-ft (9- to 12-m) trough between the two areas. Each microhabitat differs by depth and sediment composition with the trough habitat area supporting the greatest diversity of macroinvertebrate species. The nearshore habitat intertidal worm reef communities support unique assemblages of macroalgae and macroinvertebrates (EAI 2001). No seagrass habitat exists in the vicinity, although intermittent hard bottom habitat now exists to the north of the discharge pipelines, which is likely due to recent hurricane activity in 2004 and 2005.
Fisheries assessments in association with startup and operations of St. Lucie provided information on offshore and transitional assemblages of marine organisms. Bottom trawls and beach seines collected ichthyoplankton and fish at five offshore locations in the vicinity of the discharge and intake with the startup and operation of St. Lucie. Monitoring identified 49 fish species, of which five species accounted for nearly 70 percent of the catch: Atlantic bumper (Chloroscombrus chrysurus), Spanish mackerel (Scomberomorus maculatus), Atlantic croaker (Micropogonias undulatus), spot (Leiostomus xanthurus), and bluefish (Pomatomus saltatrix)
(NRC 2003).
Following the commencement of Unit 2 operations, benthic studies in the vicinity of St. Lucie reported 934 macroinvertebrate taxa. The studies also revealed minimal change from baseline conditions to operational conditions in the immediate vicinity of the thermal discharge. Likewise, sampled fish assemblages did not change significantly between operation of only Unit 1 and operation of both Units 1 and 2 (EAI 2001).
Nearshore hydrology patterns include a tidal range of 0.8 m (3 ft) and a rotary tidal current that continuously changes direction during a 12.4-hour cycle at an average speed of 0.74 fps (0.23 m/s) near the surface. The prevailing northerly current flows parallel along the east Florida coast and the secondary current flows to the south (FPL 2001).
4.0 Federally Listed Species Considered 4.1 Section 7 Consultation History and Listed Species Previously Considered The NRC and FWS have previously consulted under section 7 of the ESA in 2002 concerning the St. Lucie license renewal. During that consultation, NRC staff performed a biological assessment (NRC 2002a) that assessed the impacts to 14 Federally listed species under FWSs jurisdiction and submitted that biological assessment to the FWS on July 24, 2002 (NRC 2002b). The FWS replied by letter dated October 4, 2002, in which the FWS concurred with the NRCs determinations of no effect or not likely to adversely affect the 14 species. Table 1 lists these species and the NRCs effect determinations. The NRC did not identify any potential impacts to these species that could occur as a result of the discharge headwall project.
Therefore, the NRC will not consider these species in any further detail in this biological assessment.
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Table 1. Previously Considered Federally Listed Species Species Effect Determination Birds Florida scrub-jay not likely to adversely affect (Aphelocoma coerulescens) bald eagle* no effect (Haliaeetus leucocephalus) wood stork no effect (Mycteria americana) red-cockaded woodpecker no effect (Picoides borealis)
Audubons crested caracara no effect (Polyborus plancus audubonii)
Everglades snail kite no effect (Rostrhamus sociabilis)
Mammals southeastern beach mouse no effect (Peromyscus polionotus)
Florida manatee not likely to adversely affect (Trichechus manatus)
Plants four-petal paw paw not likely to adversely affect (Asimina tetramera)
Lakelas mint no effect (Dicerandra immaculate) fragrant prickly apple not likely to adversely affect (Harrisia eriophorus) tiny milkwort no effect (Polygala smallii)
Reptiles eastern indigo snake not likely to adversely affect (Drymarchon corias couperi)
American alligator no effect (Alligator mississipiensis)
- Since the preparation of the NRCs 2002 biological assessment, the FWS has delisted the bald eagle.
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The NRC did not consider sea turtle species as part of the 2002 consultation with FWS because the NRC did not anticipate any impacts to sea turtles on land as a result of the license renewal.
However, the NRC has consulted with the National Marine Fisheries Service (NMFS) regarding sea turtles since the early 1980s because of the potential for sea turtles to get entrapped in St.
Lucies intake canal. The NMFS issued its most recent biological opinion for St. Lucie in 2001, which stipulates that FPL may incidentally take a limited number of green turtles (Chelonia mydas), loggerheads (Caretta caretta), Kemps ridley turtles (Lepidochelys kempii),
leatherbacks (Dermochelys coriacea), and hawksbill turtles (Eretmochelys imbricata) as a result of St. Lucie operations (NMFS 2001). The incidental take limits established in the 2001 biological opinion are as follows. On an annual basis, FPL may incidentally take:
Dead or injured causally related to plant operations
- No more than 1% of total annual take may be green or loggerhead
- 1 leatherback or hawksbill per 2 years Total alive or dead, regardless of causality
- 1000 turtles in any combination of species In 2006, St. Lucie exceeded the limits set forth in the incidental take statement. St. Lucie entrained a total of 662 green and loggerhead turtles, of which 29 were dead or injured causally related to plant operations, which exceeded the one percent limit (FPL 2007). In April 2007, NRC sent a letter requesting inclusion of sea turtles in an ongoing formal section 7 consultation for the smalltooth sawfish (Pristis pectinata) (NRC 2007). Previously, the NRC had reinitiated formal section 7 consultation with NMFS in July 2005 after FPL captured a smalltooth sawfish in the St. Lucie intake canal (NRC 2005). Consultation with NMFS regarding sea turtles and smalltooth sawfish is ongoing at this time.
Because the Kemps ridley and hawksbill turtles do not nest in Florida, they will not be affected by the discharge headwall project. The green, loggerhead, and leatherback turtles nest in Florida, and these species will be considered in further detail in the following sections.
4.2 Green Turtles The Federally threatened green turtle occurs circumglobally in waters between the northern and southern 68 F (20 C) isotherms and may inhabit the coastal waters of as many as 140 countries (NMFS and FWS 2007a). In U.S. Atlantic waters, green turtles inhabit the coastal waters of the U.S. Virgin Islands, Puerto Rico, and the continental United States from Texas to Massachusetts (NMFS and FWS 1991). Within the U.S., nesting grounds extend from Texas to North Carolina. Green turtles also nest in the U.S. Virgin Islands and Puerto Rico. Important feeding grounds along the U.S. Atlantic coast and within the Gulf of Mexico includes the Indian River Lagoon, the Florida Keys, Florida Bay, Crystal River, and St. Joseph Bay (NOAA 2012a).
The NMFS has designated green turtle critical habitat in waters around Isla Culebra, Puerto Rico (NOAA 2012a).
The green turtle is the largest of the hard-shelled sea turtles. Its carapace is olive brown in color with darker streaks and spots, and its plastron is yellow. Full grown adult green turtles weigh 220 to 330 lb (100 to 150 kg) and attain a straight carapace length of 35 to 40 in. (90 to 100 cm)
(Pritchard et al. 1983; Witherington and Ehrhart 1989).
Green turtles reach sexual maturity at 20 to 50 years of age (NOAA 2012a). Within Florida, loggerheads nest between June and late September. Males mate each year; however, females 11
only nest every one to three years. During nesting years, females lay an average of three to five clutches about 12 days apart from one another (FFWCC 2012a). Clutches contain an average of 128 eggs (FFWCC 2012a). Eggs hatch within 45 to 60 days (Hopkins and Richardson 1984). Hatchlings emerge at night, travel quickly to water, and swim out to sea.
Hatchlings are about 0.88 oz (25 g), 2.2 in. (5.5 cm) long, and have a black carapace that is white on the ventral side.
4.3 Loggerhead Turtles The Federally listed loggerhead turtle occurs cirumglobally and inhabits continental shelves, bays, lagoons, and estuaries in the temperate, subtropical, and tropical waters of the Atlantic, Pacific, and Indian Oceans (Dodd 1988). In the western Atlantic Ocean, loggerhead turtles occur from Argentina northward to Newfoundland (Dodd 1988; Nelson 1988). Loggerheads sporadically nest throughout the tropical and warmer temperate range of the species distribution, but the most important nesting areas are the Atlantic coasts of Florida, Georgia, and South Carolina (Hopkins and Richardson 1984). In September 2011, NMFS published a final rule (76 FR 58868) to list nine loggerhead distinct population segments (DPSs). Loggerheads that nest in Florida are part of the Northwest Atlantic Ocean DPS, which is listed as threatened.
Loggerheads have a slightly elongated, heart shaped carapace that tapers towards the posterior and have a broad, triangular head (Pritchard et al. 1983). Loggerheads normally weigh up to 450 lb (200 kg) and attain a straight carapace length of up to 48 in. (120 cm) (Pritchard et al.
1983). Their general coloration is reddish-brown dorsally and creamy-yellow ventrally.
Adults reach sexual maturity at about 35 years of age (NOAA 2012c). Within Florida, females nest every one to three years between April and September (FFWCC 2012d). During nesting years, females lay four to seven clutches about 14 days apart (FFWCC 2012d). Nests contain an average of 100 to 126 eggs (FFWCC 2012d). Eggs hatch in 46 to 68 days, and 2-in. (5-cm) hatchlings emerge at night, move rapidly towards the water, and swim out to sea (Hopkins and Richardson 1984).
4.4 Leatherback Turtles The Federally endangered leatherback occurs circumglobally in the Atlantic, Indian, and Pacific Oceans. The range is as far north as Labrador, Canada, and the state of Alaska to as far south as Chile and the Cape of Good Hope. The leatherback is highly migratory, and tagged females have been found to migrate from French Guiana to the east coast of North America and as far north as Newfoundland (NOAA 2012c). The species is able to maintain a body temperature warmer than the surrounding seawater over a long period of time due to its counter-current body heat exchange, high oil content, and large body size. These adaptations likely account for its occurrence farther north than other sea turtle species (NOAA 2012c). Shoop et al. (1981) reported that, from April to November, leatherbacks occur from North Carolina north to Nova Scotia but that during the summer months, individuals most likely restrict their range from the Gulf of Maine south to Long Island. The NMFS designated critical habitat for the species in the coastal waters adjacent to Sandy Point, St. Croix, U.S. Virgin Islands (44 FR 17710).
The leatherback is the largest living sea turtle and is the only sea turtle that does not have a hard, bony shell. It has an elongated, somewhat triangularly shaped body with longitudinal keels and a leathery, blue-black shell composed of a thick layer vascularized, cartilaginous material strengthened by a mosaic of small bones. Leatherbacks can weigh up to 2,000 lb (900 kg) and attain a straight carapace length of 55 in. (140 cm) (NOAA 2012b; Pritchard et al. 1983).
Leatherbacks reach sexual maturity at the age of 12 to 15 years. Leatherbacks mate in waters adjacent to nesting grounds, and the species nests around the world including along the coasts 12
of northern South America, west Africa, the U.S. Caribbean, the U.S. Virgin Islands, and southeast Florida (NOAA 2012b). Within Florida, about 50 percent of leatherback nesting occurs in Palm Beach County (FFWCC 2012c). Females nest every two to four years between April and July and lay six to nine clutches per nesting year. Nests contain an average of 80 fertilized eggs covered by a layer of about 40 unfertilized eggs, which serves as a protective barrier from predators (FFWCC 2012c). Eggs hatch within 50 to 75 days (Hopkins and Richardson 1984).
Two to 3-in. (50- to 77-cm) hatchlings weighing 1.4 to 1.8 oz (40 to 50 g) emerge at night, travel quickly to the water, and swim out to sea.
4.5 Sea Turtle Nesting Surveys The Florida Fish and Wildlife Conservation Commission (FFWCC)s Fish and Wildlife Research Institute coordinates sea turtle nesting data collection as part of two statewide surveys: the Statewide Nesting Beach Survey (SNBS), which the FFWCC and FWS initiated cooperatively in 1979, and the Index Nesting Beach Survey (INBS), which the FFWCC established in 1988.
Figures 6, 7, and 8 show green, loggerhead, and leatherback INBS nest counts along 320 km (200 mi) of Florida nesting beaches from 1989 through 2011.
Both green turtle and leatherback nesting survey totals indicate that the number of nests is increasing. The number of loggerhead nests, however, has declined over the survey period, but the FFWCC (2012d) notes that the past five years of data indicates that loggerhead numbers may be stabilizing. The NMFSs loggerhead DPS final rule supports the FFWCCs view that the population size appears to be stabilizing (77 FR 58868). Witherington et al. (2009) argue that the decline in numbers of loggerhead nests in Florida is likely the result of an increased adult female mortality rate.
Within St. Lucie County, the FFWCC collects SNBS and INBS nesting data from a total of 34.5 km (21.4 mi) of beaches. Table 2 lists the number of nests reported in the past five years (2007 through 2011) by species. Although green turtle nests accounted for the majority (53.4 percent) of sea turtle nests statewide, loggerhead nests make up the overwhelming majority (89.1 percent) of nests within St. Lucie County. St. Lucie County contained 3.4 percent of Floridas surveyed green turtle nests, 7.7 percent of Floridas loggerhead nests, and 5.9 percent of Floridas leatherback nests from 2007 through 2011.
On Hutchinson Island, FPL biologists assist with a portion of the SNBS and INBS surveys.
Figure 9 shows the survey segments along Hutchinson Island. Each lettered segment represents a 1-km (0.60-mi) stretch of beach. Segments N and O are directly in front of the discharge canal, and activities associated with the discharge headwall project would occur in both of these segments. Table 3 lists the total number of nests observed in these segments by species from 2002 through 2011.
Loggerheads nest on beach segments N and O with far more frequency than either green turtles or leatherbacks. Leatherbacks nest the earliest of the three species with nesting beginning in April. Peak nesting for all species occurs in June and July. Figures 10, 11, and 12 show the average number of nests per month by species for the period 2004 through 2011.
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Figure 6. Green Turtle Florida Index Nesting Beach Survey Totals, 1989-2011 Figure Source: FFWCC 2012b Figure 7. Loggerhead Florida Index Nesting Beach Survey Totals, 1989-2011 Figure Source: FFWCC 2012b 14
Figure 8. Leatherback Florida Index Nesting Beach Survey Totals, 1989-2011 Figure Source: FFWCC 2012b Table 2. Sea Turtle Nest Survey Totals in St. Lucie County, 2007-2011 Year Green Loggerhead Leatherback 2007 454 3,589 197 2008 297 4,523 116 2009 212 3,936 235 2010 486 5,459 203 2011 398 5,763 254 St. Lucie County Total 1,847 23,270 1,005 Statewide Total 55,018 301,220 16,903 Percent of Statewide Total 3.4% 7.7% 5.9%
in St. Lucie County Table Sources: FFWCC 2012e, 2012Lf, 2012g 15
Table 3. Sea Turtle Nest Survey Totals on Hutchinson Island Beach Segments N and O, 2002-2011 Loggerhead Green Leatherback Total Nests Observed by Beach Segment Year N O N O N O 2002 220 239 14 6 7 2 2003 152 202 2 7 12 8 2004 162 167 8 7 8 6 2005 206 204 13 14 8 3 2006 92 142 4 5 6 3 2007 144 86 12 7 7 4 2008 152 172 7 11 7 4 2009 129 164 10 8 12 13 2010 233 168 9 17 6 2 2011 242 301 26 42 7 5 Table Source: FPL 2012 16
Figure 9. Nesting Survey Beach Segments Source: FPL 2012 17
Figure 10. Average Monthly Green Turtle Nests on Hutchinson Island, Beach Segments O and N, 2004-2011 Beach Segment O Beach Segment N 6
5 4 4 3
2 1 1 0 0 0 0 0 0 March April May June July August September Figure 11. Average Monthly Loggerhead Nests on Hutchinson Island, Beach Segments O and N, 2004-2011 Beach Segment O Beach Segment N 74 69 60 57 25 21 21 18 0 0 0 0 0 0 March April May June July August September 18
Figure 12. Average Monthly Leatherback Nests on Hutchinson Island, Beach Segments O and N, 2004-2011 Beach Segment O Beach Segment N 3 3 2 2 2 1
0 0 0 0 0 0 0 0 March April May June July August September 5.0 Action Effects Analysis Based on the average monthly nests documented in the project area from 2004 through 2001 (Figures 10-12), construction associated with the discharge headwall project will overlap with sea turtle nesting activities. Potential direct effects include destruction or disturbance of nests by construction activities; disturbance or interference with females attempting to nest; nesting female behavior modification; and disturbance of hatchling emergence and migration to the ocean.
Green turtle nests have not been recorded in the project area until June, at which point all construction activities on the beach will be complete. Therefore, this species is unlikely to be adversely affected by the project. Loggerhead and leatherbacks, however, nest on Hutchinson Island as early as April. Based on average monthly nest counts, leatherbacks will lay about one nest per week in April and May, and loggerheads will lay about 1.5 nests per day in May.
Nest Disturbance or Destruction The period of time when FPL will conduct construction activities from the seaward side of the seawall (through May 30) could inadvertently disturb or destroy nests. FPLs sea turtle protection plan and the FDEP construction permit contain conditions to prevent nest disturbance or destruction. FPL has proposed a number of additional conditions for work that will mitigate adverse effects to sea turtle nests.
Per FPLs sea turtle protection plan, an FFWCC-permitted monitoring agent will survey the beachfront in front of the construction site prior to the start of work each morning to identify nests and collect nesting activity data. In accordance with LDC Section 6.04.02.G.h, the monitoring agent will survey all areas where construction occurs within turtle nesting habitat, including areas used to transport equipment back and forth from the site. If the monitoring agent 19
identifies a nest that requires relocation due to construction activity or some other factor, such as location with respect to water level, FPL will contact FFWCC to relocate the nest.
The FDEP construction permit requires FPL to mark all nests and false crawls within 600 ft (180 m) of the construction area with stakes and survey tape at a radius of 10 ft (3 m). Marked nests must be inspected daily to ensure that the markers are still present. Markings will prevent workers from unintentionally disturbing or destroying nests.
Nesting Female Disturbance and Behavior Modification Construction activities could disturb or modify the behavior of nesting females. Vibrations and noise caused by construction activities could frighten nesting turtles. Materials, construction equipment, and ruts and berms produced by heavy equipment could create barriers to nesting females. Each of these effects could result in a higher incidence of false crawls.
FPLs sea turtle monitoring plan specifies that all construction must occur during daylight hours, which will minimize the potential for activities to disturb nesting females. FPL will monitor and record nesting and reproductive success, which will help determine if the incidence of false crawls increases during the construction period. Additionally, FPLs FDEP construction permit stipulates that FPL must fill or level all excavations, equipment tracks, or other temporary alterations of beach topography prior to 9:00PM each day. This requirement should minimize the potential for false crawls due to beach topography.
Artificial lighting can deter females from emerging from the surf to nest. However, FPLs FDEP construction permit prohibits FPL from using temporary lighting in the construction area at any time of day during the sea turtle nesting season.
Hatchling Disturbance Construction activities could disturb hatchlings emerging from nests. Ruts and berms from construction equipment can create obstacles for hatchlings moving from nests to the ocean.
Hatchlings that encounter vehicle ruts can lose their line of site to the ocean horizon, become disoriented, and follow the vehicle track rather than crossing over it to reach water (Hughes and Caine 1994). The extra time spent on the beach could increase hatchlings susceptibility to weakening, dehydration, and predation. FPLs FDEP construction permit stipulates that FPL must fill or level all excavations, equipment tracks, or other temporary alterations of beach topography prior to 9:00PM each day. This requirement should minimize the potential for hatchlings to become disoriented upon emergence.
6.0 Conclusion and Determination of Effects The NRC concludes that the discharge headwall project may affect, but is not likely to adversely affect leatherback, loggerhead, and green sea turtles. Though construction activities will take place on beach habitat within sea turtle nesting season, FPLs sea turtle protection plan, conditions of FPLs FDEP-issued construction permit, and stipulations set forth in LDC 6.04.04 will mitigate the majority of potential impacts. If FPL carries out these mitigation measures, impacts that result from unintentional nest, hatchling, or nesting female disturbance are likely to be insignificant and discountable.
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7.0 References References that appear with an Agencywide Document Access and Management System (ADAMS) accession number can be accessed through NRCs web-based ADAMS at the following URL: http://adams.nrc.gov/wba/.
44 FR 17710. National Oceanic and Atmosphere Administration. Designated critical habitat, determination of critical habitat for the leatherback sea turtle. Federal Register 44(58):17710-17712. March 23, 1979. Available at <http://www.nmfs.noaa.gov/pr/pdfs/fr/fr44-17710.pdf>
(accessed 16 March 2012).
76 FR 58868. National Oceanic and Atmospheric Administration. Endangered and threatened species; determination of nine distinct population segments of loggerhead sea turtles as endangered or threatened. Federal Register 76(184):58868-58952. September 22, 2011.
Endangered Species Act of 1973. 16 U.S.C. 1531, et seq.
Dodd K Jr. 1988. Synopsis of the biological data on the loggerhead turtle Caretta caretta (Linneaus 1758). FWS Biological Report 88(14). 110 pp.
[EAI] Ecological Associates, Inc. 2001. Survey of Aquatic Environments Potentially Affected by the Operation of the St. Lucie Power Plant, Hutchinson Island, Florida. Prepared for Florida Power & Light Company, April 2001. ADAMS No. ML021430397.
[FPL] Florida Power & Light Company. 2001. Applicants Environmental Report - Operating License Renewal Stage St. Lucie Units 1 and 2. Docket Nos. 50-335 and 50-389. Miami, Florida. Available at <http://www.nrc.gov/reactors/operating/licensing/
renewal/applications/st-lucie/stlucieapplenv.pdf> (accessed 21 March 2012).
[FPL] Florida Power & Light Company. 2011a. Sea Turtle Protection PlanPlant Discharge Canal Headwall Stabalization Project. October 2011. 56 p. ADAMS No. ML12082A066.
[FPL] Florida Power & Light Company. 2011b. St. Lucie Unit 2 EPU Licensing Report, License Amendment Request Extended Power Uprate, Attachment 2. ADAMS No. ML110730282.
[FPL] Florida Power & Light Company. 2007. Letter from G. Johnson, Site Vice President, FPL, to NRC Document Control Desk.
Subject:
St. Lucie Units 1 and 2 notification that turtle incidental take exceeded. February 1, 2007. ADAMS No. ML070460595.
[FPL] Florida Power & Light Company. 2012. Email from J. Gless, to D. Logan, NRC.
Subject:
St. Lucie discharge headwall project. March 6, 2012. ADAMS No. ML12073A151.
[FFWCC] Florida Fish and Wildlife Conservation Commission. 2012a. Green Turtle Nesting in Florida. Available at <http://myfwc.com/research/wildlife/sea-turtles/nesting/green-turtle/>
(accessed 19 March 2012).
[FFWCC] Florida Fish and Wildlife Conservation Commission. 2012b. Index Nesting Beach Survey Totals (1989-2011). Available at <http://myfwc.com/research/wildlife/sea-turtles/nesting/beach-survey-totals/> (accessed 19 March 2012).
[FFWCC] Florida Fish and Wildlife Conservation Commission. 2012c. Leatherback Nesting in Florida. Available at <http://myfwc.com/research/wildlife/sea-turtles/nesting/leatherback/>
(accessed 19 March 2012).
[FFWCC] Florida Fish and Wildlife Conservation Commission. 2012d. Loggerhead Nesting in Florida. Available at <http://myfwc.com/research/wildlife/sea-turtles/nesting/loggerhead/>
(accessed 19 March 2012).
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[FFWCC] Florida Fish and Wildlife Conservation Commission. 2012e. Statewide Nesting Beach Survey Program Green Turtle Nesting Data, 2007-2011. February 8, 2012. Available at
<http://myfwc.com/media/2078426/GreenTurtleNestingData.pdf> (accessed 19 March 2012).
[FFWCC] Florida Fish and Wildlife Conservation Commission. 2012f. Statewide Nesting Beach Survey Program Leatherback Nesting Data, 2007-2011. February 8, 2012. Available at
<http://myfwc.com/media/2078429/LeatherbackNestingData.pdf> (accessed 19 March 2012).
[FFWCC] Florida Fish and Wildlife Conservation Commission. 2012g. Statewide Nesting Beach Survey Program Loggerhead Nesting Data, 2007-2011. February 8, 2012. Available at
<http://myfwc.com/media/2078432/LoggerheadNestingData.pdf> (accessed 19 March 2012).
[Giken] Giken Seisakusho Company, Ltd. 2012. Press-in Method. Available at
<http://www.giken.com/en/press-in/principle/> (accessed 15 March 2012).
Hopkins SR, Richardson JI. 1984. Recovery Plan for Marine Turtles. Washington, DC: U.S.
Government Printing Office. 355 p.
Hughes AL, Caine EA. 1994. The effect of beach features on hatchling loggerhead sea turtles.
In Proceedings of the Fourteenth Annual Symposium on Sea Turtle Biology and Conservation, March 1994, Hilton Head, South Carolina. NMFS Technical Memorandum NMFS-SEFSC-351.
[NMFS] National Marine Fisheries Service. 2001. Biological Opinion for the Continued Operation of the St. Lucie Nuclear Power Plants Circulating Seawater Cooling System, Jensen Beach, Hutchinson Island, Florida (F/SER/2000/01394). May 18, 2001. ADAMS No.
[NMFS and FWS] National Marine Fisheries Service and the U.S. Fish and Wildlife Service.
1991. Recovery Plan for U.S. Population of Atlantic Green Turtle. August 6, 1991. Available at
<http://www.nmfs.noaa.gov/pr/pdfs/recovery/turtle_green_
atlantic.pdf> (accessed 16 March 2012).
[NMFS and FWS] National Marine Fisheries Service and the U.S. Fish and Wildlife Service.
2007a. Green Sea Turtle (Chelonia mydas) 5-Year Review: Summary and Evaluation. August 2007. Available at <http://www.nmfs.noaa.gov/pr/pdfs/species/
greenturtle_5yearreview.pdf> (accessed 16 March 2012).
Nelson DA. 1988. Life History and Environmental Requirements of Loggerhead Turtles. U.S.
Fish and Wildlife Service Biol. Rep. 88(23). U.S. Army Corps of Engineers TR EL-86-2 (Rev.).
34 pp. Available at <http://www.dtic.mil/dtic/tr/fulltext/u2/a200160.pdf> (accessed 16 March 2012).
[NOAA] National Oceanic and Atmospheric Administration. 2012a. Green Turtle (Chelonia mydas). Available at <http://www.nmfs.noaa.gov/pr/species/
turtles/green.htm> (accessed 16 March 2012).
[NOAA] National Oceanic and Atmospheric Administration. 2012b. Leatherback Turtle (Dermochelys coriacea). Available at <http://www.nmfs.noaa.gov/pr/species/
turtles/leatherback.htm> (accessed 16 March 2012).
[NOAA] National Oceanic and Atmospheric Administration. 2012c. Loggerhead Turtle (Caretta caretta). Available at <http://www.nmfs.noaa.gov/pr/species/turtles/
loggerhead.htm> (accessed 16 March 2012).
[NRC] U.S. Nuclear Regulatory Commission. 2002a. Biological Assessment for St. Lucie, Units 1 and 2, License Renewal Review. June 2002. 13 p. ADAMS No. ML022060314.
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[NRC] U.S. Nuclear Regulatory Commission. 2002b. Letter from P.T. Kuo, License Renewal Division Director, to J. Slack, Field Supervisor, FWS South Florida Ecological Service Office.
Subject:
Biological assessment for license renewal at St. Lucie, Units 1 and 2, and request for informal consultation. July 24, 2002. ADAMS No. ML022060232.
[NRC] U.S. Nuclear Regulatory Commission. 2003. Generic Environmental Impact Statement for License Renewal of Nuclear Plants, St. Lucie Units 1 and 2. NUREG-1437, Supplement 11, Volumes 1 and 2. Washington, D.C., May 2003. Available at <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1437/supplement11/> (accessed 21 February 2012).
[NRC] U.S. Nuclear Regulatory Commission. 2005. Letter from P.T. Kuo, License Renewal Division Director, to D. Bernhart, Southeast Assistant Regional Administrator for Protected Resources, NMFS.
Subject:
Request for reinitiation of section 7 consultation under the Endangered Species Act regarding smalltooth sawfish, Pristis pectinata, at the St. Lucie Nuclear Power Plant. July 8, 2005. ADAMS No. ML051920400.
[NRC] U.S. Nuclear Regulatory Commission. 2007. Letter from E. Benner, Chief, Environmental Branch A, NRC, to D. Bernhart, Southeast Assistant Regional Administrator for Protected Resources, NMFS.
Subject:
Request for reinitiation of section 7 consultation under the Endangered Species Act regarding sea turtles at the St. Lucie Nuclear Power Plant. April 4, 2007. ADAMS No. ML070871059.
Pritchard P, Bacon P, Berry F, Carr A, Fletemeyer J, Gallagher R, Hopkins S, Lankford R, Márquez R, L. Ogren L, Pringle W, Reichardt H, Witham R. 1983. Manual of Sea Turtle Research and Conservation Techniques, Second Edition. Edited by K. Bjorndal and G. Balazs.
Center for Environmental Education: Washington, D. C.
Shoop CP, Doty T, Bray N. 1981. Sea Turtles in the Region of Cape Hatteras and Nova Scotia in 1979 in A Characterization of Marine Mammals and Turtles in the Mid- and North Atlantic Areas of the U.S. Outer Continental Shelf. University of Rhode Island, Kingston, R.I.
Witherington BE, Ehrhart LM. 1989. Status and Reproductive Characteristics of Green Turtles (Chelonia mydas) Nesting in Florida in Ogren L, Berry F, Bjorndal K, Kumpf H, Mast R, Medina G, Reichart H, Witham R (eds.), Proceedings of the Second Western Atlantic Turtle Symposium. NOAA Technical Memorandum NMFS-SEFC-226. Available at
<http://www.sefsc.noaa.gov/turtles/TM_226_Ogren_etal_WATSII.pdf> (accessed 16 March 2012).
Witherington B, Kubilis P, Brost B, Meylan A. 2009. Decreasing annual nest counts in a globally important loggerhead sea turtle population. Ecological Applications 19(1):30-54. Available at
<http://research.myfwc.com/engine/download_redirection_process.asp?
file=09witheringto%5F0717%2Epdf&objid=58494&dltype=publication> (accessed 19 March 2012).
Wolke RE, George A. 1981. Sea Turtle Necropsy Manual. NOAA Technical Memorandum NMFS-SEFC-24, 20 pp. December 1981. Available at
<http://www.sefsc.noaa.gov/turtles/TM_24_Wolke_George.pdf> (accessed 16 March 2012).
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Appendix A FDEP Permit for Construction A-1
A-2 A-3 A-4 A-5 A-6 A-7 A-8 A-9 Appendix B FPLs Sea Turtle Protection Plan B-1
B-2 B-3 B-4 B-5 B-6 B-7 B-8 B-9 B-10 B-11 B-12 B-13 B-14 B-15 B-16 B-17 B-18 B-19 B-20 B-21 B-22 B-23 B-24 B-25 B-26 B-27 B-28 B-29 B-30 B-31 B-32 B-33 B-34 B-35 B-36 B-37 B-38 B-39 B-40 B-41 B-42 B-43 B-44 B-45 B-46 B-47 B-48 B-49 B-50 B-51 B-52 B-53 B-54 B-55 B-56 B-57 Appendix C St. Lucie County Land Development Code Chapter 6.04.02, Sea Turtle Protection C-1
C-2 C-3 C-4 C-5 C-6
ML12097A268 OFFICE PM:RERB:DLR LA:RPB1:DLR AB:RERB:DLR BC:RERB:DLR NAME BBalsam YEdmonds DLogan JSusco DATE 4/16/12 4/12/12 4/16/12 4/17/12 Letter to C. Dohner, et al. from J. Susco dated April 17, 2012
SUBJECT:
BIOLOGICAL ASSESSMENT FOR FORMAL SECTION 7 CONSULTATION AT THE ST. LUCIE PLANT, UNITS 1 AND 2 DISTRIBUTION:
E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsOgcMailCenter Resource RidsNrrPMStLucie BBalsam DLogan JSusco Jeffrey_howe@fws.gov Larry_williams@fws.gov