ML16015A388

Official Exhibit - NRC-033-00-BD01 - S. Fla. Water Mgmt. Dist., Resolution 2009-1000, Fifth Supplemental Agreement Between the S. Fla. Water Mgmt. Dist. and Florida Power & Light Company (October 16, 2009)

ML16015A388
Person / Time
Site:	Turkey Point
Issue date:	10/16/2009
From:	NRC/OGC
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 28496, ASLBP 15-935-02-LA-BD01, 50-250-LA, 50-251-LA
Download: ML16015A388 (108)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of: FLORIDA POWER & LIGHT COMPANY NRC-033 (Turkey Point Nuclear Generating, Units 3 and 4)

Submitted Nov. 10, 2015 ASLBP #: 15-935-02-LA-BD01 Docket #: 05000250 & 05000251 Exhibit #: NRC-033-00-BD01 Identified: 1/4/2016 Admitted: 1/4/2016 Withdrawn:

Rejected: Stricken:

Other:

1 SOUTH FLORIDA WATER MANAGEMENT DISTRICT 2

3 RESOLUTION NO. 20094M 4

5 A RESOLUTION OF THE GOVERNING BOARD OF THE SOUTH FLORIDA WATER 6 MANAGEMENT DISTRICT APPROVING THE FIFTH SUPPLEMENTAL AGREEMENT 7 BETWEEN FLORIDA POWER AND LIGHT COMPANY AND THE SOUTH FLORIDA 8 WATER MANAGEMENT DISTRICT FOR THE PURPOSE OF GOVERNING THE RIGHTS 9 AND OBLIGATIONS OF THE PARTIES CONCERNING THE OPERATION AND 10 MONITORING OF THE COOLING CANAL SYSTEM FOR FLORIDA POWER AND 11 LIGHTS COMPANY'S POWER GENERATING PLANT AT TURKEY POINT IN MIAMI-12 DADE COUNTY, FLORIDA 13 14 WHEREAS, Florida Power and Light Company (hereinafter referred to as FPL) is a Florida corporation 15 pursuant to the Laws of Florida. The principal office of FPL is located at 700 Universe Boulevard, Juno Beach, Florida 16 33408; and 17 WHEREAS, FPL and the CENTRAL AND SOUTHERN FLORIDA FLOOD CONTROL DISTRICT, 18 predecessor to the SOUTH FLORIDA WATER MANAGEMENT DISTRICT (hereinafter referred to as DISTRICT),

19 originally entered into an agreement on February 2, 1972 that has subsequently been supplemented four times with the 20 Fourth Supplemental Agreement dated July 15, 1983; and 21 WHEREAS, on October 29, 2008, the Florida Department of Environmental Protection (DEP) approved 22 Power Plant Site Certification # PA 03-45 (Certification) for the FPL Turkey Point Plant Units 3 and 4 Nuclear Power 23 Plant Uprate Project; and 24 WHEREAS, the Certification included consolidated condition of certification X (consolidated among DEP, 25 DISTRICT and Miami-Dade County) that requires a fifth supplemental agreement between FPL and the DISTRICT to 26 incorporate a new monitoring plan among other things; and 27 WHEREAS, the DISTRICT, FPL, DEP and Miami-Dade County have developed a new monitoring plan that 28 includes ground water, surface water, and ecological monitoring in and around the Turkey Point cooling canal system; 29 and 30 WHEREAS, FPL and the DISTRICT desire to hereby enter into a fifth supplemental agreement that reserves 31 the rights and obligations of the parties concerning the operation and monitoring of the cooling canal system for FPL's 32 power generating plant at Turkey Point.

33 BE IT RESOLVED BY THE GOVERNING BOARD OF THE SOUTH FLORIDA WATER 34 MANAGEMENT DISTRICT:

35 Section 1. The Governing Board of the South Florida Water Management District hereby approves the Fifth 36 Supplemental Agreement with FPL.

1 Section 2. A copy of the Fifth Supplemental Agreement is attached hereto and made a part hereof.

2 Section 3. This resolution shall take effect immediately upon adoption.

3 4 PASSED and ADOPTED this / day of Oat*, 2009.

5 SOUTH FLORIDA WATER MANAGEMENT DISTRICT, BY 6 ITS GOVERNING BOARD 7

8 By:

9 Chairman 10 ATTEST:

11 12 13 Assistant ecretary 14 Approved as to form:

15 16 17 Office of Counsel 18

FIFTH SUPPLEMENTAL AGREEMENT BETWEEN THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT AND FLORIDA POWER & LIGHT COMPANY

, _LTHIS AGREEMENT is made and entered into this IC day of Octo ber , 2009, by and between FLORIDA POWER & LIGHT COMPANY

("FPL") and SOUTH FLORIDA WATER MANAGEMENT DISTRICT ("DISTRICT")

(and collectively referred to as "the Parties").

WITNESSETH WHEREAS, FPL and the CENTRAL AND SOUTHERN FLORIDA FLOOD CONTROL DISTRICT, (the "CSFFCD"), predecessor to the DISTRICT, entered into an agreement dated February 2, 1972, hereinafter referred to as "Original Agreement", governing rights and obligations of the Parties concerning the construction, operation and monitoring of the cooling canal system for FPL's power generating plant at Turkey Point in Miami-Dade County, Florida; and WHEREAS, the Original Agreement has been supplemented and amended on four separate occasions; the First Supplemental Agreement having been executed on October 21, 1974; the Second Supplemental Agreement having been executed on August 14, 1975; the Third Supplemental Agreement having been executed on September 10, 1976; and the Fourth Supplemental Agreement having been executed on July 15, 1983 (the "1983 Agreement") and the Original Agreement together with the four Supplemental Agreements are hereinafter collectively referred to as the "Prior Agreements"; and WHEREAS, the 1983 Agreement superseded the previous agreements. The 1983 Agreement provides that the purpose of the interceptor ditch system, which is part of the overall cooling canal system as depicted on the map attached hereto as Exhibit "A", made a part hereof, and located between the most westward cooling canal and Levee 31 E, is to restrict movement of saline water from the cooling canal system westward of Levee 31E adjacent to the cooling canal system to those amounts which would occur without the existence of the cooling canal system; and WHEREAS, the "cooling canal system," as referred to in this Agreement, is also referred to in Prior Agreements and related documents as the "cooling water system" and "cooling system;" and

5. WHEREAS, under the Prior Agreements, including the 1983 Agreement, FPL Page 1 of 11

has had continuing obligations to monitor for impacts of the cooling canal system on the water resources of the DISTRICT in general and on the DISTRICT'S facilities and operations in particular and to implement new operating criteria and/or engineering measures if the objectives of the 1983 Agreement are not being met.

WHEREAS, under the 1983 Agreement, those monitoring obligations include determining whether saline water has moved westward of Levee 31 E; and WHEREAS, as reasonable assurances for the DISTRICT's recommendation of approval of FPL's 2008 Uprate of Turkey Point Nuclear Units 3 and 4 ("Uprate Project"), FPL submitted information concluding that its operation of the interceptor ditch prevents seepage from the cooling canal system from moving westward of Levee 31 E thereby maintaining fresh or potable water west of the interceptor ditch (FPL Turkey Point Units 3 and 4 Uprate Application, 2008, section 2.3.4.1); and WHEREAS, based on FPL's assurances in the 2008 Uprate Certification application, the DISTRICT recommended approval of the Uprate Project conditioned on imposition of the consolidated three agency Condition of Certification X in the Power Plant Site Certification for the FPL Turkey Point Plant Units 3 and 4 Nuclear Power Plant Unit Combined Cycle Plant # PA 03-45 ("Certification"), requiring FPL to execute a SFWMD approved Fifth Supplemental Turkey Point Agreement ("Fifth Supplemental Agreement" or "Agreement") and to revise FPL's monitoring obligations for incorporation into the Agreement in a revised monitoring plan; and WHEREAS, the DISTRICT'S evaluation of recent monitoring data indicates that the interceptor ditch may not be effective in restricting the movement of saline water westward from the cooling canal system; and WHEREAS, as a necessary first step in evaluating existing conditions and, if necessary, identifying potential solutions to abate, mitigate, or remediate the movement of saline water and other water quality and ecological impacts from the cooling canal system, a full delineation of any historical and current ecologic, surface water and groundwater impacts, including, but not limited to, delineation of impacts westward of the Levee 31 E and eastward of Turkey Point into Biscayne Bay, from the operation of the cooling canal system since 1972, as well as potential for future impacts of the cooling canal system, is needed; and WHEREAS, FPL, the DISTRICT, Florida Department of Environmental Protection ("DEP"), and Miami-Dade County Department of Environmental Resource Management ("DERM") developed a revised monitoring plan, the Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan (the "2009 Plan"). The 2009 Plan is attached hereto as Exhibit "B" and made a part hereof; and

12. WHEREAS, the 2009 Plan identifies monitoring for the purpose of delineating current ecologic, surface water and groundwater impacts, from the operation of the cooling canal system on the water resources of the DISTRICT in general and the Page 2 of 11

facilities and operations of the DISTRICT, including, but not limited to, delineation of impacts westward of the Levee 31 E and eastward of Turkey Point into Biscayne Bay, and to assess whether mitigation, abatement, and other remedial measures would be necessary; and NOW THEREFORE, for good and valuable consideration as set forth herein, the Parties hereto agree as follows:

RECITALS and EFFECTIVE DATE OF THIS AGREEMENT The above recitals are true and correct and incorporated herein as a material and integral part of this Agreement. The Effective Date of this Agreement shall be the last date the Agreement is signed by the Parties.

OBLIGATIONS OF THE PARTIES (A) INTERCEPTOR DITCH SYSTEM OPERATION FPL shall operate the interceptor ditch system to restrict movement of saline water from the cooling water system westward of Levee 31 E adjacent to the cooling canal system to those amounts which would occur without the existence of the cooling canal system.

The operating criteria and procedures for the interceptor ditch system have been established by FPL in the 1983 Agreement as the manual designated "THE THIRD REVISED FLORIDA POWER & LIGHT, COMPANY, TURKEY POINT, FLORIDA, INTERCEPTOR DITCH OPERATION PROCEDURES" (Interceptor Ditch Operation Procedures). These criteria and procedures are attached hereto as Exhibit "C" and made a part hereof. The Parties shall revise these procedures within six (6) months from the effective date of this Agreement.

FPL shall operate the interceptor ditch in accordance with the Interceptor Ditch Operation Procedures subject to the provisions of Paragraph II(D).,

herein, which may require revision of such operations.

Revisions to the Interceptor Ditch Operation Procedures as may be proposed by FPL and agreed to by the Executive Director of the District or his/her designee may be accomplished by letter, for incorporation into Exhibit C without having to amend this Agreement.

5. FPL shall maintain pump operation logs in a mutually acceptable form for each interceptor ditch pumping installation and electronically transmit such pump Page 3 of 11

operation logs to the DISTRICT in the manner set forth in the Interceptor Ditch Operation Procedures and shall continue maintenance and transmittal of such logs for the duration of the operation of the Interceptor Ditch System.

6. Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(B) WATER TRANSFER FACILITIES FPL has accepted on its lands east of levee 31 E, and is responsible for the conveyance of all excess surface waters from the drainage basin of Canal 106 and 107, as shown on attached Exhibit "D", made a part hereof, which can be delivered by Structure 20 ("S-20") regardless of time and duration of discharge and quality. For reference, the C-106 canal was originally envisioned to be part of the Central and Southern Florida system, but has since been deauthorized and as a consequence, not made part of this Agreement. C-106 notwithstanding, FPL shall, at its expense, operate and maintain the drainage system from S-20 seaward to the intersection with the Seadade Canal and must maintain the discharge capacity east of the S-20.

Operation of the water transfer facilities shall be in accordance with instruction given to FPL by the DISTRICT'S Director of Field Services or his designated representative. FPL shall designate an official or employee of FPL who will be responsible for the receipt of said operating instructions and for carrying them out '

Within three months of execution of this Agreement FPL and the DISTRICT's Operations and Maintenance staff shall meet to identify required actions for maintaining that portion of the C-107 canal east of the L-31 E and downstream of S-20. FPL shall comply with such requirements, including providing a maintenance plan documenting required actions, in a timely manner.

Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(C) MONITORING PROVISIONS FPL shall commence implementing the 2009 Plan on the Effective Date of this Agreement and shall implement the 2009 Plan in accordance with its terms.

FPL shall continue the monitoring and reporting in accordance with the 2009 Plan until the DISTRICT provides written notification to FPL that monitoring can be terminated.

The Executive Director of the DISTRICT or his/her designee may Page 4 of 11

require revisions to the 2009 Plan, including but not limited to, additional or revised monitoring parameters or locations and a fully coupled three-dimensional ("3D")

surface and groundwater density dependent model or the Interceptor Ditch Operation Procedures. Any such revisions may be accomplished by letter for incorporation into the 2009 Plan without the need to amend this Agreement.

FPL shall collect and submit the data as provided in the 2009 Plan.

Raw data shall be provided to the DISTRICT at the time it is received by FPL. The Parties recognize that quality control and quality assurance (QA/QC) procedures will be conducted by FPL on the laboratory data after its receipt by the DISTRICT and that revisions and re-submittal of data to the DISTRICT may be necessary based on such evaluations. FPL shall retain all data electronically for the duration of the plant's operation and shall review and analyze the data so collected consistent with the objectives of this Agreement. Raw data is defined as data, either electronic or hard copy, that is received from a sensor or as laboratory results, that has not gone through any analysis or evaluation for (QA/QC)or other purposes.

FPL shall submit to the DISTRICT all reports required by the 2009 Plan and the Interceptor Ditch Operation Procedures (hereinafter "Reports") in a timely manner as specified in the 2009 Plan. By August 31 of each year, FPL shall submit an annual report evaluating the preceding year's events in terms of historic trends (Annual Report). The Annual Report shall include the information called for in the 2009 Plan. The Annual Report shall also contain all associated raw data in an electronic format consistent with existing District software and consistent with Paragraph II(C)3, herein. FPL shall electronically transmit the Annual Report and associated raw data in the form and manner specified in the 2009 Plan and the Interceptor Ditch Operation Procedures, as applicable.

All data collected by FPL or its representatives under either the Interceptor Ditch Operation Procedures or the 2009 Plan shall be maintained, archived, and presented in a web based application, as set forth in the 2009 Plan. As technology changes or improves, the DISTRICT may require revisions to the manner and format that FPL is required to submit and present its reports, summaries, and/or data. Upon written notification by the DISTRICT that the reporting manner and/or format needs to be changed to meet current technology improvements or changes, FPL shall implement those changes within sixty (60) days, or upon a mutually agreed upon timeframe, from receipt of the notification or by the next reporting period, whichever occurs first.

Within ninety (90) days after the DISTRICT's receipt of each Annual Report or Reports, as referenced in Paragraph II (C)(4), the DISTRICT may send a written request to FPL that FPL address concerns, questions, or omissions in the Annual Report or Reports that are reasonably related to the Annual Report or Reports. Within ninety (90) days following FPL's receipt of the request. FPL shall Page 5 of 11

provide the DISTRICT with its response(s) to each issue raised or additional information as requested. FPL's response(s) shall be required to continue to the satisfaction of the DISTRICT.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a DISTRICT request, FPL shall allow the DISTRICT to enter the Turkey Point property and/or access to FPL owned or maintained monitoring wells and stations to sample the cooling canal system and surface or ground water from all stations and monitoring wells utilized pursuant to the 2009 Plan. The DISTRICT and FPL shall coordinate the timing and location of sampling to account for planned or unplanned plant outages or emergencies and to protect the public health and safety. The DISTRICT agrees to abide by standard FPL health and safety precautions while on the Turkey Point property.

Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(D) MITIGATION, ABATEMENT, AND OTHER REMEDIAL MEASURES If the DISTRICT determines that data acquired under the 2009 Plan or other sources is insufficient to evaluate impacts of the cooling canal system, the 2009 Plan or the Interceptor Ditch Operation Procedures shall be revised, as approved by the DISTRICT, pursuant to Paragraph II (C)2.

If the DISTRICT, in its sole discretion, determines that the data from the 2009 Plan or from any other source: (i) indicates that the interceptor ditch is not effective in restricting movement of the saline water westward of Levee 31E in a manner that is consistent with the objective articulated above in Paragraph II(A)1; (ii) indicates harm or potential harm to the water resources of the DISTRICT in general or the DISTRICT'S facilities and operations in particular, including ecological resources; (iii) indicates the cooling canal system water is impacting water quality under Chapter 373, Florida Statutes; or (iv) indicates impacts inconsistent with the goals and objectives of the CERP Biscayne Bay Coastal Wetlands project, then the Executive Director or his/her designee shall notify FPL in writing of such determination.

3. Upon_receipt of the DISTRICT notification, FPL shall immediately begin consultation with the DISTRICT to identify measures to mitigate, abate or remediate impacts from the cooling canal system and then shall promptly implement those measures approved by the District. Measures may include revising the Interceptor Ditch Operation Procedures or other measures, including timelines for implementing such measures, under Paragraph II (D)5 to abate, mitigate or remediate identified impacts. Such measures and timelines for implementation shall be subject to DISTRICT approval.

Page 6 of 11

If the DISTRICT and FPL cannot timely agree on feasible engineering and/or hydrologic solutions to abate, mitigate or remediate the impacts identified under Paragraph II (D)2, above, then the Executive Director of the DISTRICT or his/her designee shall notify FPL in writing that the Parties have reached an impasse.

Such determination of an impasse shall be made at the sole discretion of the DISTRICT. The DISTRICT may then, in its sole discretion, require FPL to implement specified mitigation, abatement and remediation measures, within DISTRICT identified timeframes.

Measures to mitigate, abate, or remediate impacts identified under Paragraph II (D) 2, must be in writing and may include, but are not necessarily limited to:

revisions to the cooling canal system/interceptor ditch operating criteria; reasonable alterations in the design of the interceptor ditch system; alterations to the cooling canal system; any other feasible engineering and/or hydrologic measures regarding the cooling canal system; any other feasible engineering and/or hydrologic measures to mitigate for the cooling canal system's impacts to the region's water supply or remediation thereof; and/or a District approved fully coupled 3D surface and groundwater density dependent flow model incorporating FPL operational components to evaluate the best alternatives for abatement, mitigation or remediation.

If the District notifies FPL to implement any alterations as outlined in paragraphs (a) through (f) above, any such alterations shall not impair the reasonable operations of the existing power plant.

Consultation and implementation of DISTRICT approved measures, pursuant to Paragraph II (D), shall be undertaken and implemented within the specified time frames in the written notification from the DISTRICT.

Nothing contained in this Agreement shall limit the DISTRICT from availing itself of all other rights and remedies it may now or hereafter have to achieve the objective of Paragraph II (A)1 and remedy the impacts identified under Paragraph II (D). Further, the Power Plant Site Certification for the FPL Turkey Point Plant Units 3 and 4 Nuclear Power Plant and Unit 5 Combined Cycle Plant # PA 03-45, issued under the Power Plant Siting Act, Chapter 403, Florida Statutes, does not limit, alleviate, or modify the rights and obligations of the Parties under Chapter 373, Florida Statutes, or this Agreement.

Page 7 of 11

8. Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(E) GENERAL PROVISIONS This Agreement supersedes and replaces the Prior Agreements.

This Agreement shall be binding on the Parties and, subject to the approval of the DISTRICT which may not be unreasonably withheld, their assigns and successors.

Should any unusual event occur or should FPL contemplate any substantive physical, mechanical, structural or operational changes to be made to the cooling canal system, then FPL shall promptly notify the DISTRICT and, if the DISTRICT shall so request, a meeting of the representatives of both FPL and the DISTRICT, shall be convened at the earliest mutually convenient time to review and analyze such unusual occurrences or such contemplated substantive physical, mechanical, structural or operational changes and to determine by mutual agreement what action shall be taken in relation thereto.

This Agreement shall remain in effect until terminated by the written agreement of the Parties.

FPL shall construct, maintain and operate all monitoring facilities and other facilities required by this Agreement, including those required by the 2009 Plan, in accordance with applicable manufacturer requirements and as otherwise necessary to provide timely, reliable and accurate data. FPL shall bear all its costs associated with its obligations under this Agreement including but not limited to the construction, operation, maintenance, monitoring, replacement, alteration, modification, or relocation of any and all existing or future facilities required under this Agreement.

No delay or failure by either Party to exercise any right under this Agreement, and no partial or single exercise of that right, shall constitute a waiver of that or any other right.

7. (a) This Agreement shall be governed by and construed in accordance with the laws of the State of Florida and of the United States of America and the rules and regulations promulgated under the authority thereof. In the event it is necessary for either Party to initiate legal action regarding this Agreement, venue may be in the Fifteenth Judicial Circuit or an administrative tribunal under Chapter 120, as appropriate, for claims under state law and in the United States District Court for the Southern District of Florida for any claims which are subject to jurisdiction of federal law and the federal Court.

Page 8 of 11

Consistent with subparagraph II (E) 7(a.), FPL maintains all rights they may have to request a proceeding under Chapter 120, Florida Statutes, to challenge any proposed or final agency action taken by the DISTRICT that affects FPL's substantial interests under Sections II (A), (B), (C), and (D) of this Agreement, including the right to petition for an administrative hearing. This specifically includes the right of FPL to file a petition requesting a formal or informal administrative hearing pursuant to Section 120.569 and 120.57, Florida Statutes, objecting to the District's agency action under Section II (D). This Paragraph does not create, modify or expand FPL's rights provided under Chapter 120, Florida Statutes. Nothing in this Agreement is intended to expand, or limit, the jurisdiction of the District. The District shall not act arbitrarily or capriciously and FPL shall not cause undue delay in implementing its obligations under this Agreement.

FPL shall indemnify, save and hold the DISTRICT and its directors, employees, and contractors (the "Indemnified Parties"), harmless and will defend against any and all claims, damages, costs, expenses, and liability arising from (1) the performance by FPL or its contractors, agents, or representatives of FPL's obligations under this Agreement, or (2) the construction, operation, maintenance, replacement, alteration, modification, or relocation of any existing or future interceptor ditch, monitoring facility, water transfer facility, or abatement, remediation or mitigation made necessary by the cooling canal system or required under this Agreement. The remedy in the preceding sentence is not intended to be an exclusive and does not preclude the Indemnified Parties' exercise of any other rights or remedies available under this Agreement or which may now or subsequently exist in law or at equity. If FPL fails to perform in accordance with the terms and conditions of this Agreement, then the DISTRICT shall have the right to seek specific performance and/or an action for damages based on the reasonable cost that would be incurred by the DISTRICT, including administrative, supervisory, and staff costs, to require implementation of the mitigation, abatement, and remedial measures identified in Paragraph II (D).

In the event any provision of this Agreement is held or adjudged to be invalid or illegal or unenforceable by any court of competent jurisdiction: (1) such portion or provision shall be deemed separate and independent; (2) the Parties shall negotiate in good faith to restore, insofar as practicable, the benefits to each Party that were affected by such ruling; and (3) the remainder of this Agreement shall remain in full force and effect.

This Agreement may be executed in any number of counterparts, all of which shall together constitute one and the same instrument. A facsimile or electronic signature shall be binding.

10. This Agreement states the entire understanding and Agreement between the Parties with respect to the subject matter contained herein and supersedes any and all prior written or oral representations, statements, negotiations, or agreements.

Page 9 of 11

Unless expressly stated herein to the contrary, nothing in this Agreement, whether express or implied, is intended to confer any rights or remedies under or by reason of this Agreement on any person other than the Parties hereto.

Nothing in this Agreement is intended to relieve or discharge the obligation or liability of any third persons to any Party, nor shall any provision give any persons any right of subrogation or action over or against any Party.

The Parties shall comply with all applicable laws. Each Party shall be solely responsible for the payment of any fines or penalties levied as a result of such Party's non-compliance with any applicable legal requirement, except to the extent caused or contributed by the other Party.

In the event a dispute arises which cannot be resolved by the Parties, the Parties may agree to submit to nonbinding mediation. The mediator or mediators shall be impartial, shall be selected by the Parties, and the cost of the mediation shall be borne equally by the Parties. The mediation process shall be confidential to the extent permitted by law. Either Party may pursue its remedies available under this Agreement.

The Parties agree that time is of the essence in the performance of the obligations under this Agreement.

This Agreement shall not be construed against any Party regardless of who is responsible for its preparation. The Parties acknowledge that each contributed to, and is equally responsible for its preparation and the Agreement shall be interpreted without regard to any presumption or other rule requiring interpretation against one party or the other.

FPL and the District have the reciprocal and continuing obligation to notify the other of any personnel changes of its designated official or employee who will maintain monitoring installations and collect monitoring data and records. The following individuals shall serve as the designated points of contact for all issues and correspondence between the Parties arising in conjunction with this Agreement and by written notice to the other Party:

DISTRICT REPRESENTATIVE: FPL REPRESENTATIVE:

Title:

Assistant Deputy Executive Director

Title:

Dire_c:he-Erruitronmt;V,I\ liCsASInj South Florida Water Management District Florida Power & Light Company 3301 Gun Club Road 700 Universe Boulevard West Palm Beach, FL 33406 Juno Beach, FL 33408-0420 (561) 686-8800 (561) 611 11i Page 10 of 11

17. Each Party hereto represents and warrants that the execution of this Agreement has been duly authorized by it and that this Agreement, upon execution by the other Party, is binding on and enforceable against such Party in accordance with the terms of this Agreement. No consent to such execution is required from any person, judicial or administrative body, governmental authority or any other person other than any such consent which already has been unconditionally given. Each Party hereto represents and warrants that there is no pending litigation or, to the best of their knowledge, threatened litigation that would affect its obligations to perform hereunder.

IN WITNESS WHEREOF, the Parties hereto have set their hands and seals in duplicate originals, the day and year first above written.

FLORIDA POWER & LIGHT COMPANY, a Florida C r or tion By: (Sign)

Name: A/rcfre4 --0<f(Print)

Title:

t Date: Z/L 14 --e.10 9 SOUTH FLORIDA WATER MANAGEMENT BY ITS GOVERNING BOARD, a public corporation of the S to of Florida By: (2411 (Sign)

Name: (7i4 Pot At.),L) (Print)

Title:

77VE TZYP Date:

SFWMD Office of Counsel Approved: B y:, Ad Ka,/

Date:

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s SOUTH FLORIDA WATER MANAGEMENT DISTRICT FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan EXHIBIT B South Florida Water Management District Florida Department of Environmental Protection Miami-Dade County Department of Environmental Resource Management October 14, 2009

Table of Contents List of Tables ............................................................................................ iii List of Figures ........................................................................................... iii Acronyms and Abbreviations........................................................................... v 1: Introduction ........................................................................................... 1 1.1 Adaptive Monitoring Approach and Plan Modifications ................................. 5 2: Monitoring Plan ....................................................................................... 7 2.1 Monitoring Design Strategy .................................................................. 7 2.1.1 Landward Delineation of Groundwater Plume .................................... 7 2.1.2 Seaward Delineation of the Groundwater Plume ................................. 8 2.2 Parameter Suite ............................................................................... 8 2.2.1 Tracer Suite ............................................................................ 8 2.3 Groundwater Monitoring ................................................................... 11 2.3.1 Groundwater Monitoring Well Locations ......................................... 11 2.3.2 Groundwater Monitoring Well Installation ....................................... 13 2.3.3 Biscayne Bay Geophysical Survey ................................................. 15 2.3.4 Groundwater Sampling.............................................................. 16 2.4 CCS Monitoring .............................................................................. 17 2.4.1 Sediment and Porewater Sampling ............................................... 20 2.5 Surface Water Monitoring ................................................................. 20 2.5.1 Surface Water Locations............................................................ 20 2.5.2 Surface Water Data Collection .................................................... 22 2.6 Water Budget and Mass Balance Calculations .......................................... 23 2.6.1 Bathymetric Survey.................................................................. 23 2.6.2 Water Budget Parameters and Monitoring ....................................... 24 2.6.3 Water Budget Calculations ......................................................... 25 2.7 Interceptor Ditch Water Monitoring...................................................... 27 2.8 Ecological Monitoring....................................................................... 29 2.8.1 Overview and Strategy .............................................................. 29 2.8.2 Design ................................................................................. 30 2.8.3 Initial Ecological Condition Characterization ................................... 30 2.8.4 Broad Scale Vegetation Characterization ........................................ 32 2.8.5 Wetland Transect Locations ....................................................... 32 2.8.6 Freshwater Wetland Transect Assessments ..................................... 34 2.8.7 Saline Wetland Transect Assessment ............................................. 36 2.8.8 Biscayne Bay and Card Sound ...................................................... 37 3: Field Notification, Data Collection and Reporting ............................................ 41 3.3 Quality Assurance/Quality Control Plan ................................................. 41 3.3.1 Field Sampling and Analysis Event Notifications ................................ 42 3.3.2 Meetings............................................................................... 42 3.4 Data Collection and Reporting ............................................................ 42 FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l i

3.5 Data Collection .............................................................................. 44 3.5.1 Automated Sample Collection ..................................................... 44 3.5.2 Manual Sample Collection .......................................................... 44 3.6 Data Reporting .............................................................................. 44 3.6.1 Web Database ........................................................................ 44 3.6.2 Automated Data Reporting ......................................................... 45 3.6.3 Manual Data Reporting .............................................................. 46 3.6.4 Geology and Hydrogeology Report ................................................ 46 3.6.5 Initial Ecological Condition Characterization Report .......................... 47 3.6.6 Semiannual and Annual Comprehensive Monitoring Reports.................. 48 3.6.7 Comprehensive Pre-Uprate Report ............................................... 49 4: Schedule ............................................................................................ 51 References Cited ...................................................................................... 53 Appendix A: FDEPs Conditions of Certification IX and X related to the FPL Turkey Point Power Plant Uprate ................................................................... A-1 Appendix B: Near Shore Sonde Deployment Methods ........................................... B-1 Appendix C: Survey Parameters Collected during Groundwater and Surface Water Investigations .......................................................................... C-1 Appendix D: Special Requirements for an Electromagnetic Induction Well................. D-1 Appendix E: Tritium Sample Collection and Analysis Protocols ............................... E-1 ii l Table of Contents

List of Tables Table 2-1. Required parameters for groundwater/surface water characterization ......... 10 Table 2-2. Rationale for the groundwater monitoring locations. All locations are approximate until field verification ................................................... 13 Table 2-3. Borehole logging methods, descriptions of the properties measured, and types of data obtained .................................................................. 14 Table 2-4. Rationale for the CCS monitoring locations .......................................... 19 Table 2-5. Rationale for the surface water monitoring locations .............................. 22 Table 2-6. Ecologic monitoring: transect sampling. .............................................. 39 Table 2-7. Ecologic monitoring: initial characterization and survey sampling ............... 40 Table 3-1. Sampling frequency for field and laboratory parameters .......................... 43 Table 3-2. Proposed automated time-series data collection from surface and groundwater stations .................................................................... 44 List of Figures Figure 1-1. Turkey Point and surrounding area ...................................................... 4 Figure 2-1. Groundwater well cluster locations ................................................... 12 Figure 2-2. CCS monitoring stations ................................................................. 18 Figure 2-3. Surface water monitoring sites ......................................................... 21 Figure 2-4. CCS flowmeter locations................................................................ 26 Figure 2-5. Proposed interceptor ditch monitoring sites ......................................... 28 Figure 2-6. Ecological monitoring transects adjacent to the CCS............................... 33 Figure 2-7. Example of a proposed sampling design for ecological monitoring along the transects ................................................................................... 36 Figure E-1 Rainfall collection stations ............................................................. E-4 FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l iii

iv l List of Tables and Figures Acronyms and Abbreviations ALKA Alkalinity APT aquifer performance test BBAP Biscayne Bay Aquatic Preserve BBSW Biscayne Bay Surface Water BNP Biscayne National Park

+-

B Boron ion Ba Barium BACI Before-After-Control-Impact Br- Bromide ion bsl below sea level C Carbon

°C degrees Celsius 12 C Carbon isotope 13 C Carbon isotope Ca2+ Calcium ion CaCO3 Calcium carbonate Cl- Chloride ion CCS cooling canal system CDMP Comprehensive Development Master Plan CERP Comprehensive Everglades Restoration Plan cm Centimeter COC Conditions of Certification CRP continuous resistivity profiling D Deuterium DERM Miami-Dade County Department of Environmental Resource Management DIC dissolved inorganic carbon DO dissolved oxygen DOAH Department of Administrative Hearings FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l v

DOC dissolved organic carbon DOH Department of Health DOI U.S. Department of Interior DTS distributed temperature sensing EPA U.S. Environmental Protection Agency ESRI Environmental Systems Research Institute F- Fluoride ion F.A.C. Florida Administrative Code FDEP Florida Department of Environmental Protection FKAA Florida Keys Aqueduct Authority FPL Florida Power and Light Company fpd feet per day FWS U.S. Fish and Wildlife Service GIS Geographic Information System H Hydrogen 3

H Tritium 2

H Deuterium HCO3- Bicarbonate ion ID interceptor ditch

+

K Potassium ion km kilometer LSC liquid scintillation counting M meters m micrometer S/cm microsiemens/centimeter MDL maximum developable limit Mg2+ Magnesium cation mg/L milligrams per liter N Nitrogen Na Sodium NAD North American Datum NAVD North American Vertical Datum of 1988 NELAC National Environmental Laboratory Accreditation Conference vi l Acronyms and Abbreviations

NH3 Ammonia NH4 Ammonium NGVD National Geodetic Vertical Datum of 1929 NOAA National Oceanic & Atmospheric Administration NOx Nitrate+Nitrite NPS National Park Service NRC Nuclear Regulatory Commission NSF National Science Foundation O Oxygen 16 O Oxygen isotope 18 O Oxygen isotope ORP oxidation-reduction potential P Phosphorus pCi/L Picocuries per liter pH potential of hydrogen ppm parts per million PSS78 Practical Salinity Scale of 1978 psu practical salinity units PVC Polyvinyl chloride QA/QC Quality Assurance/Quality Control RECOVER Restoration Coordination and Verification RTK Real-time Kinematic 13C stable carbon isotope 15N stable nitrogen isotope SAV submersed aquatic vegetation SFWMD South Florida Water Management District SiO4 Silicate SO4 2- Sulfate anion Spp species (plural)

SPT standard penetration test 2+

Sr Strontium SR86 Strontium isotope SR87 Strontium isotope FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l vii

(SRP)c soluble reactive phosphorus TDS total dissolved solids TOC total organic carbon (TP)c total phosphorus TKN Total Kjeldahl nitrogen TPGW Turkey Point groundwater USACE U.S. Army Corps of Engineers USGS U.S. Geological Survey viii l Acronyms and Abbreviations

1 Introduction This Monitoring Plan (Plan) has been developed pursuant to Conditions of Certification (COC) IX and X of the Power Plant Site Certification for the Florida Power & Light (FPL)

Turkey Point Units 3 and 4 Nuclear Power Plant Unit Combined Cycle Plant PA 03-45A2 (Uprate Certification). COC IX and X are attached hereto as Appendix A. In addition, this Plan identifies monitoring required under the Fifth Supplemental Agreement between the South Florida Water Management District and Florida Power and Light Company (Fifth Supplemental Agreement or 2009 Agreement). The Plan is incorporated into and made a part of the 2009 Agreement as Exhibit B.

This Plan, and any resultant actions by the Agencies and FPL, is being conducted in order to satisfy the objectives of the 1983 Agreement, the Fifth Supplemental Agreement, and the COCs.

The Plan incorporates contributions from the Florida Department of Environmental Protection (FDEP), the South Florida Water Management District (SFWMD), and Miami-Dade Countys Department of Environmental Resources Management (DERM),

(collectively, the Agencies), and FPL. The following Federal entities are contributing to the development and implementation of the Plan: Everglades National Park (ENP) and Biscayne National Park (BNP).

The Monitoring Plan shall provide information to determine the vertical and horizontal effects and extent of the cooling canal system (CCS) water on existing and projected surface and groundwater, and ecological conditions surrounding Turkey Point (see Figure 1-1). The CCS is hypersaline. There shall be a minimum of two years of monitoring of surface water, groundwater, and ecological conditions prior to the first of either Unit 3 or 4 becoming operational (defined as pre-Uprate). Monitoring shall be continuous from this pre-Uprate period throughout commencement of the Uprate (defined as post-Uprate when both Units 3 and 4 operational). Monitoring under the Plan shall continue pursuant to the 2009 Agreement and the Conditions of Certification. Prior to and following the commencement of the Uprate period, data shall be collected including monitoring for ground and surface water levels, specific conductance, temperature, CCS tracer suite constituents, tidal influences, preferential groundwater flow paths, surface and groundwater quality (including CCS constituents), rainfall, any other information necessary for the water budget, and ecological conditions.

During the pre-Uprate period, FPL shall exercise due diligence, as defined below, and due care to perform its obligations under the Plan in a timely manner. If a Force Majeure Event, FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 1

as defined below, or an unforeseen permitting delay, beyond FPLs control and FPL has pursued the permit with due diligence, as explained below, occurs causing a delay in any portion of this Plan, the Turkey Point 3 and 4 Uprate will not be delayed.

If FPL anticipates a delay in implementation of any part of this Plan due to a Force Majeure Event or an unforeseen permitting delay outside FPLs control and FPL has pursued the permit with due diligence, within fourteen days of becoming aware of such event, FPL shall notify the SFWMD in writing of the anticipated length and cause of the delay, demonstrate that such delays are due to a Force Majeure Event or outside FPLs control, and identify the probable impact on FPLs performance, the measures taken or to be taken to prevent or minimize the delay and the time table by which FPL intends to implement these measures.

Any portion of the Plan that is delayed shall not cause delays in any other unrelated portion of the Plan.

FPL shall exercise commercially reasonable due diligence to overcome the Force Majeure Event. To the extent it is able, FPL shall continue to perform under this Agreement and cause the suspension of its performance to be of no greater scope and no longer duration than the Force Majeure Event requires.

However, if FPL is not able to produce two years of monitoring data due to situations beyond its control despite FPLs exercise of due diligence and due care in the timely implementation of this plan, the Agencies shall reserve the right to evaluate the data collected to date and determine if it is sufficient to establish the pre-Uprate baseline condition.

When FPL is able to resume performance of its obligations under this Agreement, it shall immediately give SFWMD written notice to that effect and shall resume performance under this Agreement after the notice is delivered.

Force Majeure Event shall mean any event outside the control, and not the fault, of FPL that cannot be avoided or overcome by the exercise of due diligence, including but not necessarily limited to: an act of God, war, flood, lightning, fire, hurricane, tornado, explosion, civil disturbance, or the public enemy, terrorist act, military action, epidemic, work-to-rule action, go-slow or similar labor difficulty, each on an industry-wide, region-wide or nationwide basis; but does not include economic hardship, changes in market conditions, insufficiency of funds, or unavailability of equipment or supplies.

Due diligence in FPLs permitting applications means that: a) FPL submitted the permit application in sufficient time for the permitting agency to act on the application and for FPL to complete the project for which the permit is necessary in order to obtain a minimum of two years of pre-Uprate data for a sufficient baseline of data; b) FPL responded in a reasonable time to requests for information needed by the permitting agency to process the application or prepare any necessary environmental analysis; and c) FPL took practicable steps to ensure completion of the project as expeditiously as possible after issuance of the permit.

2 l Section 1: Introduction

FPL maintains all rights it may have under Chapter 120, Florida Statutes (F.S.). However, nothing in this Plan is intended to create, modify, or expand FPLs rights it may have under Chapter 120, F.S., or under Chapter 403, Part II, F.S. FPL maintains its right to request a proceeding under Chapter 120, Florida Statutes, to challenge any proposed or final agency action taken in implementing this monitoring plan that affects FPL's substantial interests.

This specifically includes the right of FPL to file a petition requesting a formal or informal administrative hearing pursuant to Section 120.569 and 120.57, Florida Statutes. The terms of the Plan do not limit any existing regulatory authority the individual Agencies have over FPL or its Turkey Point facility. The SFWMD and the FDEP have concurrent jurisdiction to determine impacts, harm or potential harm, require or allow Plan modifications, require or allow Plan termination, and require compliance as indicated in the Conditions for Certification or the Agreement.

FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 3

Figure 1-1. Turkey Point and surrounding area.

4 l Section 1: Introduction

1.1 ADAPTIVE MONITORING APPROACH AND PLAN MODIFICATIONS The development of this Plan was based on limited available hydrologic and ecological information. The intent of the adaptive monitoring approach is to streamline completion of the objectives related to the identification and monitoring through time of the CCS water tracers, state and county water quality constituents, water budget, and ecological effects. The adaptive monitoring approach includes the potential expansion or reduction of monitoring elements based on the findings of previous steps. Any party can propose enhancements or decreases in monitoring, however, such proposal by any party shall not be implemented without approval of the lead Agency (SFWMD).

Modification of the Plan may be proposed at any time either by the FDEP, SFWMD, DERM, or FPL. Any modification shall be approved/denied by FDEP or SFWMD, as applicable, after consultation with DERM. These procedures for Plan modification are in addition to any other regulatory enforcement authorities of the Agencies (FDEP, SFWMD, and DERM).

FPL shall implement Plan modifications within the timeframes established by the Agencies.

Plan modifications during the pre-Uprate monitoring period shall be implemented expeditiously in light of the limited monitoring timeframes before the Uprate is operational.

Minor field changes, such as movement/adjustment of monitoring stations or locations over short distances, due to logistical constraints or to optimize monitoring, may be initiated after Agency approval by telephone during Plan implementation. If the adjustment is deemed more significant, SFWMD may require a written request be made prior to the modification and technical information be provided before the adjustment is made. The SFWMD shall make decisions promptly to avoid delays.

FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 5

6 l Section 1: Introduction 2

Monitoring Plan 2.1 MONITORING DESIGN STRATEGY The Plan consists of an integrated system of surface, groundwater, porewater, and ecologic sampling. New monitoring wells shall be installed and a hydrogeologic investigation and surface and groundwater monitoring shall be conducted. All stage recorders and groundwater wells (top of casing) shall be referenced as described in Appendix C to allow comparison of results across the landscape and at depth. Where available or possible, data collected by other entities will be used to further enhance the understanding of baseline conditions and help determine impacts or potential impacts. Ecological monitoring shall be initiated in areas of presumed stress, along transects, and for spatial characterization.

The approach for monitoring of existing conditions at the FPL Turkey Point Power Plant (plant) and adjacent environments is to determine the relationship of CCS water and: a) the underlying groundwater in all directions; b) the freshwater wetlands and nearby canals, c) the adjacent saltwater wetlands; d) the eastern mangrove shoreline; e) the Biscayne Bay littoral zone; and f) within Biscayne Bay and Card Sound. The tracking of the CCS water movement is proposed using a combination of automated monitoring, along with manual data collection of water constituents and tracers of CCS water (discussed in Section 2.4).

The exact monitoring locations, as depicted in maps in the subsequent sections, may need to be adjusted based on access, environmental considerations (i.e., wetland and estuarine impacts), or other findings that warrant placement in alternative locations. The final locations of all sampling sites shall be approved by the Agencies prior to placement.

The monitoring area shall include the CCS and surrounding areas, as shown in Figure 1-1.

Portions of the Florida Keys National Marine Sanctuary, Biscayne Bay Aquatic Preserve (BBAP), Biscayne National Park (BNP), and the Model Land Basin are also included.

2.1.1 Landward Delineation of Groundwater Plume For groundwater beneath land (defined as being landward of the mean high water line), the vertical (to the base of the Biscayne aquifer) and horizontal extent of the plume will be determined by State and County groundwater quality standards and the CCS tracer suite, as determined by the Agencies.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 7

The plume will be delineated starting from the CCS and continue landward if State or County groundwater quality standards are exceeded and one or more of the tracer suite values are above background, unless the Agencies agree expanded landward delineation is not necessary.

However, if at a given location, one or more of the tracer suite values are above background, but groundwater quality concentrations are lower than State and County standards, but projected to increase above those standards, continued monitoring will be required and potentially expanded to determine the zone of plume movement, as determined by the Agencies.

2.1.2 Seaward Delineation of the Groundwater Plume For the purpose of groundwater plume delineation within and beneath Biscayne Bay and Card Sound (seaward of the mean high water line), monitoring will be conducted as described in the Plan. Criteria for seaward delineation shall be identified by the Agencies based on an evaluation of all available data, including initial monitoring conducted for a minimum of one year.

2.2 PARAMETER SUITE Required parameters are listed in Table 2-1 and described in the following sections of this monitoring plan: Sections 2.3.4 Groundwater Sampling; 2.4 CCS Monitoring; 2.5.2 Surface Water Collection; 2.6 Water Budget and Mass Balance Calculations; and Section 2.8 Ecological Monitoring.

2.2.1 Tracer Suite For the purpose of identifying the vertical and horizontal extent of the CCS plume, the delineation methodology shall be based, in part, on the finding of tracer values above those which would not be present in the environment, except for a contribution of water from the CCS. The tracer shall be used to identify water originating from the CCS and differentiate it from water from other sources. A subset of the analytical parameters is collected for purposes of identification of a tracer suite. The final tracer suite shall be identified by the Agencies based on all available data, including initial monitoring data collected during a minimum of one year. Samples shall be collected quarterly at each surface and groundwater monitoring station.

At the end of the initial monitoring period, which is a minimum of one year, FPL shall submit a report to present its findings (to include raw data) regarding potential tracer monitoring parameters (tracer suite) to be used in future tracer monitoring in accordance with the reporting requirements, as specified in Section 3. The Agencies shall identify the tracer suite, applicable detection levels, background levels, and any recommended changes (i.e., increases/decreases) in sampling sites and sampling frequency. If at the end of the first 8 l Section 2: Proposed Monitoring Plan

year of monitoring the Agencies determine that additional tracer monitoring parameters are needed to better assess the adequacy of specific tracers, the Agencies may require additional monitoring.

These tracer monitoring parameters are separated into three different categories and include, but are not limited to:

1. Stable Isotopes: this group includes the oxygen isotopes of water (18O/16O),

hydrogen isotopes of water (D/H), strontium (Sr87/Sr86), and stable isotopes of carbon (13C/12C) in the dissolved inorganic carbon (DIC) in water.

2. Radioactive Isotopes: tritium (H3).

3. Ions: listed in Table 2-1, plus Barium (Ba) and Iron (Fe).

The FDEPs drinking water standard for concentrations of tritium in groundwater is 20,000 pCi/L. The Agencies and FPL recognize that the concentrations of tritium from the CCS water are expected to fall below the regulatory standard used to identify the potential for human health concerns. Accordingly it is mutually understood tritium is being monitored only as a potential tracer for identifying contributions of CCS water as a source. According to the FDEP, pursuant to Chapter 62-520 and 62-550, F.A.C., the presence of tritium below 20,000 pCi/L in water does not represent a public health and safety issue.

Sample collection and analytical methodologies for potential tracer suite monitoring parameters and interpretation of tritium results are presented in Appendix E.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 9

Table 2-1. Required parameters for groundwater/surface water characterization.

Field Parametersc Temperature (T) pH Specific Conductance (conductivity at 25°C) in Oxidation-Reduction Potential (ORP)

µS/cm Salinity using the Practical Salinity Scale of Dissolved Oxygen (DO) 1978 (PSS78)

Percent Oxygen Saturation Laboratory Parameters CCS tracer suite c Strontium (87Sr/86S)

Hydrogen (3H, 2H) [Tritium, Deuterium] d Carbon (13C,12C)

Oxygen (18O, 16O) Dissolved Inorganic Carbon (DIC)

Barium (Ba) Total Iron Ionsc: Nutrients:

Calcium (Ca2+) Ammonia (NH3)c - calculated as NH3 Sodium (Na+) Ammonium (NH4+) as Nc Magnesium (Mg2+) Nitrate+Nitrite (NOX) as Nc Potassium (K+) Total Kjeldahl Nitrogen (TKN)c Strontium (Sr2+) Total Nitrogen (TN)c - calculated Chloride (Cl-) Total Phosphorus (TP)c Bromide (Br-) Soluble Reactive Phosphorus (SRP)c Sulfate (SO42-) Silicatea Fluoride (F-)

Bicarbonate (HCO3-)

Boron (B+)

Alkalinity (ALKA) Alkalinity as CaCO3 Sulfides Total Dissolved Solids (TDS)b Other:

Gross Alphaa Trace Elementsb:

Arsenic Mercury Barium Manganese Beryllium Molybdenum Cadmium Nickel Chromium (Hexavalent Chromium) Selenium Copper Thallium Iron Vanadium Lead Zinc a

Surface water CCS only.

b Groundwater only.

c Both surface and groundwater.

d At this time, it is FPLs position that tritium is not a suitable tracer.

10 l Section 2: Proposed Monitoring Plan

2.3 GROUNDWATER MONITORING The purpose of groundwater monitoring is described in COC IX and X of the Uprate Appendix A and the 2009 Agreement.

2.3.1 Groundwater Monitoring Well Locations Fish and Stewart (1991) showed that the base of the Biscayne aquifer was approximately 106 feet below sea level (bsl) at the G-3321 well location, adjacent to the northwestern portion of the CCS and the L-31E Canal (Figure 2-1). The base of the Biscayne aquifer at G-3321 is shown within a few feet of the contact between overlying limestone with relatively high hydraulic conductivity [>1,000 feet per day (fpd)] and underlying sandstone with relatively low hydraulic conductivity (10 to 100 fpd) within the Tamiami Formation. The USGS is developing the hydrostratigraphic framework of the Biscayne aquifer system for Miami-Dade County (Cunningham et al 2004, 2006a, 2006b, 2008).

Based on input with the Agencies, a series of groundwater monitoring stations shall be installed. A total of 14 well clusters are included, as shown in Figure 2-1 and Table 2-2.

These well clusters are spatially distributed to facilitate plume monitoring and are generally aligned along transects to aid in determining concentration gradients on a sub-regional scale.

The exact installation locations may need to be adjusted based on site-specific conditions (e.g., access considerations, minimization of environmental impacts) or permitting constraints.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 11

Figure 2-1. Groundwater well cluster locations.

12 l Section 2: Proposed Monitoring Plan

Table 2-2. Rationale for the groundwater monitoring locations. All locations are approximate until field verification.

Location Rationale Groundwater stations will establish baseline conditions and delineate limits of the CCS plume. A cluster of three groundwater monitoring wells at each location will enable sampling from macroporous-permeable zones.

TPGW-1 Monitor west/northwest of L-31E TPGW-2 Monitor west of the south-central portion of the CCS TPGW-3 Monitor south of the CCS TPGW-4 Monitor westward of the CCS TPGW-5 Monitor westward of the CCS TPGW-6 Monitor northwest of the CCS TPGW-7 Monitor west of the CCS and northwest of TPGW-5. Nearest well cluster to Newton Wellfield.

TPGW-8 Monitor west of the CCS and northwest of TPGW-4 TPGW-9 Reference Well TPGW-10 Monitor offshore north of the entrance to the barge turning basin TPGW-11 Monitor offshore of the CCS in Biscayne Bay TPGW-12 Monitor north of the CCS TPGW-13 Site is located in the approximate center of the CCS to monitor below the source area of the hypersaline plume.

TPGW-14 Monitor offshore of the CCS in Biscayne Bay 2.3.2 Groundwater Monitoring Well Installation Each monitoring well cluster shall be completed with discrete screen intervals in the upper, middle, and lower portions of the Biscayne aquifer. No monitoring zone shall be placed below the Biscayne aquifer system and at least one monitoring zone shall include the base of the plume within the Biscayne aquifer system. To accomplish this task, a pilot hole shall be advanced at each cluster site to delineate to the base of the Biscayne aquifer and characterize the aquifers characteristics and water quality. FPL shall conduct detailed geological sampling in the pilot hole of each cluster. Geological sampling of each pilot hole shall include continuous split spoon samples using the standard penetration test (SPT), in accordance with ASTM standards, and/or core sample collection from surface to total depth. Core samples shall be collected when SPTs are refused. Detailed geological samples shall be correlated to the downhole borehole videos in the final geological report.

Well development shall be conducted on all pilot holes prior to optical borehole imaging and all monitoring wells until clear, sand-free water is obtained and field parameters stabilize in accordance with FDEP criteria.

Monitoring well screen intervals shall be site-specific and shall represent macroporous and relatively high-permeability zones of the upper, middle, and lower Biscayne aquifer based on the combined results from optical borehole imaging (oriented camera system),

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 13

electromagnetic induction, caliper, flow, specific conductance, temperature, gamma ray, full wave form sonic, and borehole logging of the deepest hole (Table 2-3). If hydrogeologic testing of the flow intervals is not conducted at the time of well construction, such testing and data shall be provided, as determined by the Agencies, to evaluate the hydraulic conductivity of each screened flow zone in conjunction with any future model efforts.

Agency representatives shall be allowed onsite to observe field activities and shall be provided copies of field generated data upon request. The SFWMD representative(s) will pre-approve well screen intervals in the field prior to well construction. FPL shall notify SFWMD representatives in writing at least 14 calendar days, or less if agreed to by the SFWMD, before initiating well construction. If the SFWMD is notified in a timely manner and determines that no SFWMD representative will be present, FPL may proceed with the subject well construction without the SFWMD attending.

In addition, the deepest well at each cluster shall be constructed to facilitate once a year induction logging across the entire vertical extent of the well. Based on initial induction log results, a subset of wells may be selected by the Agencies for semi-annual logging. This will enable the monitoring of conductivity changes within the Biscayne aquifer and potential migration of the plume, even in zones that are not screened. Once installed, the network of wells shall be horizontally and vertically surveyed to second order accuracy and referenced to both NGVD and NAVD (Appendix C). Appendix D presents well construction requirements, which will facilitate electromagnetic induction logging.

Table 2-3. Borehole logging methods, descriptions of the properties measured, and types of data obtained.

Type of Log Properties Measured Purpose Optical borehole Imaging of borehole Determines the 360-degree image of borehole imaging (OBI) and identifies borehole condition and macroporous zones. Provides an oriented optical image of the borehole that compensates for tool spinning.

Electromagnetic Formation and fluid Provides data on specific conductance within Induction conductivity fluid and formation around the borehole.

Caliper Borehole diameter Borehole diameter; determines presence of voids and cavities.

Flow Flow rate Identifies zones of groundwater flow within borehole.

Temperature Fluid temperature Determines temperature variations across depth within borehole.

Gamma Ray Rock sediment gamma Provides information on formation radiation characteristics, including rock types and changes in lithology.

Full Wave Form Lithology and porosity Provides information on presence and location Sonic of formation of potential preferential flow paths.

14 l Section 2: Proposed Monitoring Plan

A well construction spreadsheet supplied by the SFWMD shall be constructed and maintained. The spreadsheet shall include the following parameters: drilling method, geologic sampling method, drilling mud used, well installation date, latitude, longitude, state planar, muck (ground) elevation, ground surface elevation, measuring point at top of casing, depth from top of casing, depth at top of screen, screen length, well construction material, screen slot size, gravel pack at screen interval, elevation at top of well screen, elevation at bottom of well screen, centralizers used, project manager, and the source of well information.

Data collected during well installation, including geological sampling (i.e., coring or SPTs),

detailed lithologic logs, borehole geophysics, digital optical logs, initial induction logs, temperature and flowmeter logs, field water quality data, and well construction details shall be compiled and submitted to the Agencies within 60 days of completion of each well. In addition, a summary of well drilling procedures, geophysical logging procedures, and instrumentation used shall be provided. Based on wells installed from this monitoring effort and other subsurface geologic data, scaled geologic cross-sections, including macroporosity zone and geophysical log overlays, shall be generated and included in the report. This includes information from the induction logs that reveal zones of saline water. In addition, a plan view map showing the location of significant features shall be included. The information generated from this report will enable a better understanding of the movement of groundwater in the area and will provide the basis for interpretation of tracer and water quality monitoring.

2.3.3 Biscayne Bay Geophysical Survey Broad-scale estimates of specific conductance and temperature of waters potentially influenced by the CCS are needed to assess the spatial extent and magnitude of this influence (including the identification of potential groundwater upwelling zones) and provide information to improve the monitoring design within the adaptive protocols of this Plan.

Electromagnetic resistivity surveys can provide such broad-scale salinity estimates for both surface water and groundwater (Fitterman and Desczcz-Pan 2001; Swarzenski et al. 2006).

A boat-based electromagnetic resistivity survey shall be made over Biscayne Bay (south of the latitude of the Mowry Canal) and over Card Sound. The geophysical investigation shall be performed using a combination of continuous resistivity profiling (CRP) and distributed temperature sensing (DTS) investigation. GPS technology shall be used to establish horizontal control of the geophysical survey locations. Since water has different degrees of resistivity, a CRP survey can provide both horizontal and vertical insight of saline versus fresh versus hypersaline water. A DTS survey can provide a continuous profile of temperature over a large distance with a high degree of resolution. Its use is based on distinguishing temperature contrasts between groundwater, surface water, and potentially warmer CCS water. Relatively fine-scale tracks (less than 1 km apart) shall be made parallel from shoreline to 4 km east of the shoreline, from Card Sound Road to the Mowry Canal.

South of this area, the remaining area of Biscayne Bay and Card Sound shall be coarsely surveyed with at least three transects that cross these bays eastward to Key Largo, Old FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 15

Rhodes Key, and Elliott Key. An additional track shall be made long-shore of these Keys at the eastern boundary of Biscayne Bay and Card Sound, between the southern end of Card Sound and the latitude of the Mowry Canal. The CRP survey shall be conducted from a boat with readings collected along transects. A DTS cable shall also be deployed on a grid pattern with data collected for at least two tidal cycles along the same transects. The logs of the well boreholes will be used to calibrate the results. Thus, the survey shall be initiated within three months after the Biscayne Bay wells are installed (Section 2.3.2). All available specific conductance and salinity data from the surveyed terrestrial and estuarine areas shall be used to provide the best estimates of salinity based on resistivity values.

Additional geophysical surveys may be required over the wetlands or bays in a later phase of this monitoring program to update estimated groundwater salinity distributions.

2.3.4 Groundwater Sampling Each station shall comprise a combination of three monitoring wells at each site, designed to evaluate the extent of CCS influence and to determine hydraulic gradients (i.e., vertical and horizontal) with specific focus on macroporous hydrogeologic zones. Each monitoring well shall be instrumented and automatically monitored for groundwater levels, temperature, and specific conductance. The sensors in the monitoring wells shall be placed near the midpoint of the screened section of each well. Salinities measured by sensors shall be calculated using the PSS78.

Quarterly monitoring at each groundwater cluster shall consist of field parameters, ions, TDS, and the CCS tracer suite, as listed in Table 2-1. Semiannual monitoring at each groundwater cluster shall consist of all of the above, plus the nutrient parameters in the groundwater clusters (1, 2, 10, 13, and 14) labeled in Figure 2-1. In addition, trace elements shall be monitored semiannually for one year in the groundwater clusters (1, 2, 10, 13, and 14). If trace element concentrations exceed primary and secondary drinking water standards in groundwater samples, monitoring for these parameters shall continue and may be expanded to other stations as determined by the Agencies. All applicable samples shall be analyzed in accordance with Chapter 62-160 F.A.C. at an FDEP-approved laboratory capable of analyzing samples with a wide salinity range (including hypersaline waters).

FPL shall continue to manually collect all quarterly data (from two depths) from the existing wells L-3, L-5, G-21, G-28, and G-35 to compare the information with the new wells, which are more strategically screened. Since there are over 30 years of data from these existing wells, a comparison of the information to nearby wells shall give insight into the accuracy of the historical data. Previously, these wells were monitored quarterly with field instruments.

While temperature, specific conductance, and water level shall continue to be monitored with field instruments, samples shall be collected and sent to a laboratory for analysis of the same parameters that shall be the subject of monitoring in the new wells.

To further supplement the groundwater data being collected by FPL, information collected by others, including but not limited to USGS and the FKAA, may be used upon the 16 l Section 2: Proposed Monitoring Plan

Agencies pre-approval. The Agencies will review each proposed wells applicability to the Plan based on geologic data and construction details submitted. Currently, the USGS collects chloride data on a semiannual or quarterly basis and conducts induction logs once a year from a network of coastal wells throughout Miami-Dade County. In some cases, there are only a few years of data, and in other cases, over 30 years. Some of these wells are located in the project area and are screened near the base of the Biscayne aquifer.

2.4 CCS MONITORING The purpose of sampling within the CCS is to characterize the water. A total of seven stations are included, six along the interior boundary of the CCS, and one in the central portion of the CCS. These stations, labeled TPSWCCS-1 to TPSWCCS-7, are located both at the edge and the middle of the CCS system, as well as in the areas that are of the highest and lowest stage. These data shall provide a clear spatial and temporal understanding of the specific conductance and temperature variability within the CCS (Figure 2-2 and Table 2-4).

All stations in the perimeter canals shall have a specific conductance, temperature, and depth sensor placed approximately 1 foot below the surface level, and one approximately 1 foot above the bottom of the canal. Stations in shallow water (<3 feet) shall use one water quality sensor. The site in the center of the CCS (TPSWCCS-2) shall only have one sensor approximately 1 foot above the bottom of the canal; a second sensor is not warranted due to this center canals shallow depth (~3 feet). Sensors shall monitor for temperature and specific conductance (salinity calculated from specific conductance and temperature), which will help determine the vertical profiles in the CCS canals. Water level shall be measured at each station with a fixed sensor that is surveyed as described in Appendix C.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 17

Figure 2-2. CCS monitoring stations.

In addition to the automated monitoring, quarterly monitoring at each surface water station shall consist of field parameters, major ions, and the CCS tracer suite, as listed in Table 2-1.

Semiannual monitoring at each surface water station shall consist of all of the above parameters, as well as nutrients. The total count of alpha particle radioactivity (Gross Alpha) 18 l Section 2: Proposed Monitoring Plan

shall be monitored semiannually for one year in all stations located within the CCS. All applicable samples shall be analyzed in accordance with Chapter 62-160 F.A.C. at an FDEP-approved laboratory capable of analyzing samples with a wide-range of specific conductance values, including hypersaline waters (salinity conditions in excess of typical marine conditions).

Table 2-4. Rationale for the CCS monitoring locations.

Location Samples Rationale Cooling canal system (CCS) stations characterize CCS water and monitor changes.

The monitoring of water will be just below the surface within the CCS and at bottom, unless otherwise noted.

CCS TPSWCCS-1 This site is located in Canal 32, which shall document the specific conductance and temperature of water leaving the plant, where the greatest hydraulic stage is observed and shall serve as a station associated with operation of the inceptor ditch (ID).

TPSWCCS-2 This site is in the middle of the CCS, co-located with TPGW-13, and documents the change in specific conductance and temperature as the water travels down the CCS. This shallow site shall only have one monitoring sensor.

TPSWCCS-3 This site is located in Canal 32 near the southwest corner of the CCS, characterizes water at this end of the CCS, and shall serve as a station associated with operation of the ID.

TPSWCCS-4 This site is located in the Collector Canal at the southeast corner of the CCS, and characterizes water at this end of the CCS by the scrub mangrove forest.

TPSWCCS-5 This site is located in the deepest portion of Canal E6 and characterizes the water on its return trajectory back to the plant, nearest the location where DERM has observed atypical mangroves.

TPSWCCS-6 This location in the East Canal measures water as it enters the plant in the area of lowest hydraulic stage; this site will provide insight into the degree of exchange between the CCS and surrounding subsurface hydrology.

TPSWCCS-7 This station is located in Canal 32, halfway down the CCS on the west side, and shall serve as a station associated with operation of the ID.

Preliminary investigation into the thermal anomaly located within the northwest side of the CCS shall be undertaken after the detailed bathymetric survey (Section 2.6.1) has been completed. This investigation includes detailed sampling and characterization and shall include surface water sampling for parameters required under the quarterly sampling. The approximate location of the thermal anomaly is Longitude 80 21 4.79 West, Latitude 25 24 47.13 North, and Longitude 80 21 5.46 West, Latitude 25 24 11.04 North. The exact location shall be measured during the bathymetric survey and shall be compared to existing reports.

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2.4.1 Sediment and Porewater Sampling Sampling within the sediment and porewater may be needed to help with the interpretation of geochemical and/or ecological findings. Such sampling may be phased in after initial Plan implementation based on ecological and/or geochemical results, as recommended by the Agencies. The determination of specific measurements and locations will be made by the Agencies, and may include sediment bulk analyses in duplicate cores per site and porewater analyses. Sample depths shall include surface (0-10 cm) and subsurface (40-50 cm) samples, where possible.

2.5 SURFACE WATER MONITORING The purpose of surface water monitoring is described in COC IX and X of the Uprate Certification (see Appendix A) and the 2009 Agreement. This appendix focuses on the proposed surface water monitoring in Biscayne Bay and the nearby freshwater and tidal canals, including the L-31E Canal, tidal canal downstream of the S-20 Structure, and the Card Sound Canal. Monitoring surface water in the Model Land Basin freshwater wetlands and nearshore mangroves shall be addressed in Section 2.8: Ecological Monitoring.

2.5.1 Surface Water Locations A total of five surface water stations are proposed in Biscayne Bay, extending offshore along the length of the CCS. BBSW-3 shall be co-located with groundwater cluster TPGW-11 (Figure 2-3). BBSW-1 is located in the barge cut, northeast of Barge Turning Basin. Table 2-5 shows the locations of these surface water stations and the rationale for these locations respectively. The exact installation locations may need to be adjusted based on site-specific conditions (i.e., access considerations, minimization of environmental impacts) or permitting constraints. The surface water stations shall be located as close to shore as possible, but it is recognized that the water is quite shallow immediately east for much of the CCS.

As shown in Figure 2-3 and Table 2-5, surface water monitoring stations are proposed at three non-tidal surface water locations in the L-31E Canal: one tidal location at the S-20 Discharge Canal, and one tidal location at the Card Sound Canal. A sixth location in the Card Sound Road Canal, away from the influences of the CCS, shall be monitored manually with the quarterly sampling events. This is a reference station and may indicate the Card Sound Road Canals influence on regional saltwater intrusion and the possible impact on the area between Card Sound Road and the CCS.

The L-31E Canal is the closest freshwater water body to the CCS. The L-31E Canal stations shall serve a dual purpose of providing information for the assessment of CCS influences, as well as supporting the monitoring of water levels for ID operation.

20 l Section 2: Proposed Monitoring Plan

Figure 2-3. Surface water monitoring sites.

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Table 2-5. Rationale for the surface water monitoring locations.

Location Sample Rationale Biscayne Bay BBSW-1 This site is in the cut and just offshore the Barge Turning Basin, northeast of the CCS.

BBSW-2 This site is located offshore from the scrub mangrove where DERM has observed atypical mangroves to monitor for seepage from the CCS.

BBSW-3 This site is located near the Arsenicker Keys, just offshore the mangrove forest and co-located with TPGW-11.

BBSW-4 This site monitors the offshore portion of the CCS south of the Arsenicker Keys and near the mouth of the Card Sound Canal/historical CCS outlet, and co-located with TPGW-14. This site is located in close proximity to a Department of Health radiological monitoring site.

BBSW-5 This site is located south of the CCS and mitigation bank.

L-31E Canal TPSWC-1 This site is located northwest of the CCS along ID Transect A to monitor for seepage from the CCS and to aid in the operation of the ID.

TPSWC -2 This site is located along the middle segment of the CCS and along ID Transect C to monitor for seepage from the CCS and to aid in the operation of the ID.

TPSWC -3 This site is located by the S-20 structure, at the intersection of the L-31E and C-107 Canals to monitor for seepage from the CCS. It is also part of the ID operations located along Transect E.

S-20 Discharge TPSWC 4 This sampling station is located at the S-20 Discharge Canal. This Canal site shall monitor the extent to which the tidal portions of the drainage canal downstream of the S-20 Structure is affected by the surface waters of the CCS, as well as the potential influence of Biscayne Bay on the canal around the CCS.

Card Sound TPSWC -5 This site is located in Card Sound Canal, just below the CCS, where Canal manatees have been increasingly observed as reported by DERM.

Card Sound TPSWC-6 This site is located at Card Sound Road Canal, in the general Road Canal proximity of FKS-4, and will serve as a reference station that will help document the influence of Card Sound Road Canal on groundwater. This station shall be manually monitored.

2.5.2 Surface Water Data Collection The surface water stations in Biscayne Bay shall measure conditions just above the sediment surface. All stations, with the exception of the Card Sound Road canal station, shall be automated with one set of temperature and conductivity sensors installed horizontally, approximately 1 foot above the sediment surface (Appendix B). Stations in the Biscayne Bay not co-located with groundwater stations will not have telemetry and a surface water stage recorder. Sampling stations in Table 2-5 shall be automated and instrumented similarly to the CCS stations. This will allow for the determination of water level, temperature, and specific conductance at each site.

22 l Section 2: Proposed Monitoring Plan

Data from each surface water station discussed previously shall be collected at 15-minute intervals from the top of each hour and either manually or remotely uploaded to a database.

This monitoring strategy shall allow a continuous assessment of specific conductance and temperature changes in Biscayne Bay and canals in the areas surrounding the FPL Turkey Point Power Plant. The stage sensors shall be tied to an established datum (NGVD and NAVD). All sensors shall be inspected and cleaned as needed to meet QA/QC requirements.

In addition to the proposed automated monitoring, quarterly monitoring at each surface water station shall consist of field parameters, major ions, and the CCS tracer suite, as listed in Table 2-1. Semiannual monitoring at each surface water station shall consist of all of the above parameters, as well as nutrients. All applicable samples shall be analyzed in accordance with Chapter 62-160 F.A.C. at an FDEP-approved laboratory facility capable of analyzing samples with a wide specific conductance range (including hypersaline waters).

Additional data from other entities, such as BNP, NRC, USACE, EPA, NOAA, DOI, NPS, DOH, USGS, FWS, DERM, other local governments, and the SFWMD will be added to the information collected from this effort to form a more comprehensive understanding of this area. BNP monitors salinity at 34 sites in the area at the same 15-minute sampling frequency (Bellmund et al. 2007), and the sites around the CCS (BISC08B, BISC12B, and BISC13S) will be used to complement the monitoring efforts. Information available from the sampling network in BNP, Audubon Societys nearby sites, and the SFWMD Water Quality sampling network will be reviewed for relevance and applicability in the inclusion of data reporting.

Other data that will support this monitoring effort include the SFWMD operations of the S-20 structure, since that may affect the water quality at TPSWC-4.

2.6 WATER BUDGET AND MASS BALANCE CALCULATIONS Developing a periodic water budget for the CCS is essential in evaluating the exchange, if any, between the CCS and the groundwater, fresh surface waters, Biscayne Bay waters and the atmosphere. The monitoring and reporting described herein includes updated bathymetric survey work and provides supportive data and calculations of water and material mass within, entering, and leaving the CCS. The requirements of this section are necessary to implement FPL obligations under the Conditions for Certification as well as the Agreement with SFWMD.

2.6.1 Bathymetric Survey A key component of recharge/discharge in the water budget is a bathymetric survey because it will enable the estimation of the volume and water surface area of the CCS. A bathymetric/volumetric survey of the CCS and each segment of the interceptor ditch (ID) shall be conducted using sonar equipment, and results shall be tied to established horizontal and vertical datums as described in Appendix C. The positioning (x, y, and z) requires the FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 23

use of a high-accuracy GPS navigation system (or Real-Time Kinematic GPS survey grade equipment). The GPS vertical accuracy of the system shall be decimeter GPS. Since the volume of water in the CCS will vary hourly, the water surface shall be continuously monitored during the survey and all depths shall be corrected to reflect the depth below the vertical datums as described in Appendix C. The survey shall take into consideration the water levels collected electronically in the CCS and Biscayne Bay.

The raw sonar results of the bathymetric survey shall be converted into rectified electronic data sets with specific point elevations and coordinates and a three-dimensional rectified surface and subsurface mesh shall be developed in AutoCAD (version 14 or higher). These two surfaces must show the mean water surface elevations and actual depths within the CCS.

The volumetric calculations shall be complemented by all field water level data.

2.6.2 Water Budget Parameters and Monitoring The general water budget parameters to be collected are listed below. The units of all parameters shall be converted to similar volumes and rates.

• Daily rainfall quantities from three on-site locations and two off-site locations.

• Power plant intake and outflow velocity as measured by Acoustical Doppler current meters.

• Meteorological data (solar radiation, wind speed, wind direction, air temperature, relative humidity, or other components necessary to calculate evaporation).

• Groundwater and surface water levels in and surrounding the CCS.

• Interceptor ditch operations, flows, qualities, and rates for each segment.

• Other parameters (e.g., salinity measured from specific conductance) as needed to complete an estimated water budget.

Five rainfall stations shall be set up in and or near the CCS system. These stations will be co-located at stations TPRF-12 in the north, TPGW-13 in the center of the CCS, TPRF-L3 in the south, TPRF-L5 on the west side, and TPGW-11 on the east side (Figure E-1). Rainfall stations shall not be placed near structures that may obstruct rain or prevent accuracy in rainfall collection. Data from the rainfall buckets shall be collected with the same frequencies as the water level data. All data shall be transmitted to the FPL main server daily.

Permanent flow stations shall be established within the CCS using acoustic Doppler velocity meters. Volumetric and velocity measurements shall be conducted at three strategic locations in the CCS perimeter canal to assist in the estimation of water inputs and losses. The stream gauging locations shall be placed near the plant discharge (TPFM-1): at the constriction between the C series canals and the E series canals on the southeast side of the CCS (TPFM-2) and near the plant intake (TPFM-3) (Figure 2-4). Acoustical flow and velocity data at these stations shall be taken at each location concurrently and shall be collected at 15-minute intervals. The flow stations shall be integrated with existing CCS water quality monitoring stations when applicable. Inflows (timing, duration, and frequency) from the 24 l Section 2: Proposed Monitoring Plan

Interceptor ditch shall be monitored electronically and reported with the other water budget components.

Evaporative losses shall be calculated based on a wind speed sensor co-located at TPGW-13.

Additional parameters needed to calculate evaporative losses can be obtained from existing FPL meteorological stations. The wind parameter from the TPGW-13 station shall be combined with water temperature collected from the CCS surface water stations (Figure 2-4).

2.6.3 Water Budget Calculations A time series volumetric spreadsheet (or equivalent) shall be developed based on actual field data. This spreadsheet shall include all measured and calculated components of the water budget. This includes water volumes and material mass exchanges across the CCS boundaries estimated on a daily time step. A salt budget, estimated from specific conductance and concurrent flow measurements, shall be a component of this exchange estimate. If the water budget spreadsheet contains summarized variables, all data and supportive information shall be included for these variables. The water budget report shall use the daily time step to calculate the monthly averages (January through December) and data shall be summarized annually.

The water budget shall include a breakdown for each contribution. This includes but is not limited to:

• Losses/gains to the atmosphere as measured by rainfall and evaporation.

• Losses/gains to the surficial aquifer vertically.

• Losses/gains to the surficial aquifer horizontally.

• Losses/gains to Biscayne Bay (differentiated between Biscayne Bay groundwater and surface water to the extent practical).

Total estimated contributions from each area of potential losses and gains (shown previously) shall be calculated. After each quarterly sampling, the water budget spreadsheet shall be updated to include the results of the laboratory analysis. Combining the results will yield total load contributions for the CCS. This shall be done for the major cations, anions, and tracer suites parameters.

The updated water budget shall be thoroughly documented using the new information, and all estimates and assumptions shall be clearly noted. The water budget shall be calculated on a monthly frequency, summarized at the end of each year, and reported as specified in and reported in the annual report. After the second year of post-Uprate (as defined in Section 1),

a review of the approach and findings will be conducted.

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Figure 2-4. CCS flowmeter locations.

26 l Section 2: Proposed Monitoring Plan

2.7 INTERCEPTOR DITCH WATER MONITORING This Plan adds three water quality sensors at existing gauge stations in the ID coincident with Transects A, C, and E (TPSWID-1, TPSWID-2, and TPSWID-3) as shown in Figure 2-5. Each gauge station shall have a specific conductance, temperature, and depth sensor placed approximately 1 foot below the surface level, and one approximately 1 foot above the bottom of the ditch and be automated and instrumented similarly to the CCS stations. This will allow for the determination of water level, temperature, and specific conductance (salinity calculated) at each site. Transects B and D will still be monitored manually for stage unless automated in the future. Quarterly monitoring at each ID station shall consist of field parameters.

Data from each surface water station (Section 2.5) shall be collected at 15-minute intervals from the top of each hour and remotely uploaded to a database. This monitoring strategy shall allow a continuous assessment of stage, specific conductance, and temperature changes in the interceptor ditch. The stage sensors shall be tied to an established datum as described in Appendix C. All sensors shall be inspected and cleaned as needed.

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Figure 2-5. Proposed interceptor ditch monitoring sites.

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2.8 ECOLOGICAL MONITORING 2.8.1 Overview and Strategy The purpose of ecological monitoring design is to identify the existing baseline conditions and future impacts of CCS waters as described in the Conditions of Certification (COC) IX and X of the Uprate and in the Agreement (see Appendix A). Ecological monitoring is necessary to establish the current, pre-Uprate status of ecological conditions and biotic components, the extent to which CCS operations may be impacting conditions and components, and the extent to which Uprate implementation may result in further impacts and changes to these conditions and components now and into the future. Ecological conditions of primary, but not exclusive, interest related to CCS operations and ecological responses, are temperature, salinity, a CCS tracer suite, and nutrients. Biotic components of primary interest are marsh vegetation (i.e., freshwater graminoid and woody) in adjacent wetlands, mangroves, submersed aquatic vegetation (SAV), and benthic fauna in and adjacent to Biscayne Bay.

The strategy of this Plan is as follows:

• Spatially characterize ecological conditions via broad reconnaissance surveys.

Wetland surveys shall be completed within six months of plan approval.

Estuarine and bay surveys shall be conducted within one year of Plan approval and include a resistivity survey of Biscayne Bay and Card Sound (see Section 2.3.3), along with sampling of specific conductance (with salinity calculated) and a CCS tracer suite within the upper 60 cm of soils and sediments (porewater) in these bays and in the saline and freshwater wetlands adjacent to the CCS (Section 2.8.3 Initial Ecological Condition Characterization).

• Within three months of Plan approval, identify stressed areas in the vicinity of the CCS. This will be accomplished by synthesizing existing data relating to the distribution and density of vegetation using observations and cursory analysis of recent and historical aerial photographs. Aerial photographs of the region taken by the Comprehensive Everglades Restoration Plan (CERP) Restoration Coordination and Verification (RECOVER) team in April 2009 will be made available for this purpose. Analysis of such photographs combined with site visits will help determine the specific locations of sampling sites (Section 2.8.4 Broad Scale Vegetation Characterization).

• Establish transects and plots in freshwater and saline wetlands, including sampling of specific conductance and a CCS tracer suite, and nutrients in soils and sediments within six months of plan approval (Sections 2.8.5, 2.8.6, 2.8.7).

• Initiate Biscayne Bay benthic SAV and faunal assessment (Section 2.8.8 Biscayne Bay and Card Sound).

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2.8.2 Design Three zones, freshwater marshes, saline/coastal wetlands, and Biscayne Bay and Card Sound, shall be assessed for pre- and post-Uprate by establishing transects that are repeatedly measured over time. Results shall be compared with changes over this time in reference areas that are ecologically similar, with exposure to similar environmental factors other than CCS operations. The Triangle Area, between Card Sound Road and US Highway 1 of the Model Lands, will serve as the reference area (Figure 2-6). It is anticipated that at least a minimum of two years of pre-Uprate monitoring (as defined Section 1) shall be performed.

Within each zone, a slightly different sampling design is recommended. A transect design is to be used within the northern, eastern, western, and southern marshes (Figure 2-6). Areas that have been currently identified as containing stressed or atypical vegetation patterns shall be included in the transects and subject to additional evaluation. Such stressed areas have been identified at the following locations:

1. An atypical mangrove area, east of the CCS (25.41N, 80.32W).

2. Short fringe mangroves, south of the Sea Dade Canal (25.34N, 80.33W).

3. Stunted sawgrass site, west of CCS (25.43N, 80.35W).

4. Pond area in saltwater mangrove area east of CCS (25.3799N, 80.3268W).

5. Nearshore benthic features within Card Sound (25.4072N, 80.3273W).

Additional areas that may be identified in initial site characterizations (described in Sections 2.8.3 and 2.8.4) shall also be considered in the final transect placement after consultation with the SFWMD. A transect approach shall also be used in the mangrove wetlands east of the CCS, but because of the small area involved, and the structure of existing or remnant creeks, these transects may be modified over time to spatially conform to landscape features and areas of potential impact.

Within Biscayne Bay and Card Sound, a combination of nearshore-offshore transects and nearshore areal sampling shall be used. For any of these zones, additional sites shall be added at locations where specific CCS influence is subsequently identified; concerns are noted (e.g.,

sites of CCS derived groundwater upwelling) and/or harm or potential harm is indicated.

2.8.3 Initial Ecological Condition Characterization Assessment of biotic responses to CCS operations requires information on the spatial distribution of environmental conditions that affect biota and are potentially influenced by CCS water. A condition of primary interest is salinity, as calculated with specific conductance, especially soil and sediment specific conductance for vascular plants, but other conditions, such as temperature and nutrients, are important ecological factors (Table 2-7).

30 l Section 2: Proposed Monitoring Plan

Measurement of a CCS tracer suite is essential to establish the extent of CCS connectivity if any in a given adjacent zone. Initial information on salinity distribution will be derived from two sources: 1) an electromagnetic resistivity survey of Biscayne Bay and Card Sound (Section 2.3.3); and 2) porewater surveys of freshwater and saline wetlands adjacent to the CCS and Biscayne Bay and Card Sound (described as follows). Porewater shall be analyzed for specific conductance within the root zone (about 30 cm deep, but limited to the top 60 cm), along with the CCS tracer suite analysis at a subset of locations. Results from these surveys shall identify potential zones of CCS water connectivity with surface sediments and soils via seepage and groundwater pathways, providing information on potential ecological influence of the CCS, as well as a basis to improve the monitoring design within the adaptive protocols of this Plan.

The resistivity survey of Biscayne Bay and Card Sound, described in Section 2.3.3, shall be used to locate potential upwelling zones containing CCS water within Biscayne Bay.

A broad-scale survey of porewater temperature, specific conductance, and the CCS tracer suite shall be made in adjacent wetlands during the first dry season (December through May) after Plan implementation and in Biscayne Bay and Card Sound during the first wet season (June through November) and dry season after Plan implementation. Specific conductance and temperature profiles (at 20 cm intervals to 60 cm or refusal) shall be measured in situ, using field meter and probes at more than 100 points in the wetlands, both freshwater and saline, and more than 100 points in Biscayne Bay and Card Sound. The boundaries of the surveyed wetlands shall be as far west as Tallahassee Road and Card Sound Road, as far north as the Florida City Canal and south to Card Point, and east to the estuarine shoreline.

The boundaries of estuarine porewater surveys shall be as far east as 4 km offshore from the Biscayne Bay and Card Sound shoreline between the Mowry Canal and Card Sound Road.

Sample sites shall be approximately even in distribution, but some samples may be taken in areas of special interest, such as apparently stressed areas, tree islands, remnant creeks, or sites where groundwater inputs are suspected. If such areas are found to be distinct from adjacent marsh areas, the transect design, described in Sections 2.8.6 and 2.8.7 may be modified and/or expanded to include these areas. Water level within wetlands, and water depth, within the Bay shall also be measured, and locations of all sampling shall be tracked and identified by GPS.

Following analysis of the survey results, and after consultation with the SFWMD, CCS tracer suite measurements shall be made from porewater about 30 cm deep at a subset of sites that, based on specific conductance results, indicate the strongest CCS influence. The CCS tracer suite measurements shall include at least 30 samples in each wetland zone, both freshwater and saline, yielding a total of 60 wetland samples, and 30 samples in Biscayne Bay and Card Sound. Wetland sampling shall include a subset of deeper samples (about 60 cm deep) to help distinguish groundwater and rainfall derived tracer sources. In Biscayne Bay and Card Sound, there shall be two separate samplings, each including 30 tracer suite analyses. One sampling shall be done during a neap tide period, January through March. A second sampling shall be performed in the wet season in June through August. Pending the results of this initial porewater survey and/or the resistivity survey, additional samplings may be conducted in a later phase and may include the tracer suite and/or additional parameters.

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2.8.4 Broad Scale Vegetation Characterization Within one month of Plan approval, a broad scale vegetation assessment shall be conducted in wetland areas adjacent to the FPL facility, by review of existing information supplemented by documented ground observation. Existing data shall be synthesized relating to the distribution and density of vegetation by cursory analysis of recent and historical aerial photographs. One set of photographs that may be used was taken by RECOVER in April 2009 and copies of these photos shall be made available to FPL upon request to the SFWMD. Additional ground observations that indicate stressed vegetation or other ecological conditions shall be made and described in field logs and recorded by photographs, including GPS locations during any initial site characterizations described in Section 2.8.3.

Vegetation mapping may be initiated at a later stage of this monitoring program if analysis of vegetation in plots along transects indicates a CCS effect on the wetlands.

2.8.5 Wetland Transect Locations Ecological assessment of the wetlands shall focus primarily on patterns of plant community status and environmental conditions relevant to this community, along transects emanating from the CCS. The approximate locations are shown in Figure 2-6 and the parameters are summarized in Table 2-6. Three east-west transects (approximately 6 km long) shall be established through the freshwater wetlands (shown in yellow in Figure 2-6) from the CCS into the Model Land Basin at least as far west as Tallahassee Road. Preliminary locations for these three western transects include an area of special concern, adjacent to the CCS western boundary, where observations of sparse and stressed vegetation have been made, as well as further areas to the west that do not indicate obvious stress. Two shorter transects shall run from the northern and southern CCS boundary through freshwater wetlands (in yellow) and saline wetlands (in pink) to the Biscayne Bay and Card Sound coastline. The southern transect traverses wetlands south of the CCS from the southwest corner of the CCS to Card Sound. The northern transect traverses wetlands from the northern CCS boundary to approximately the mouth of the Florida City Canal. Three additional short transects shall run from the eastern CCS boundary to the coastline in the saline mangrove wetlands (shown in pink in Figure 2-6) with an orientation dictated by the shape of this narrow coastal area and the location of previously identified atypical mangrove growth and mangrove mortality.

A reference transect (in turquoise in Figure 2-6), approximately 9 km long through freshwater and saline wetlands shall also be established in the Triangle Area. Water levels within wetlands and water depth within the Bay shall also be measured, and locations of all sampling shall be tracked and identified by GPS. Land based areas along the transects shall be referenced back to an established elevation as described in Appendix C. This effort does not require professional surveying. However, all measurements shall be tied back into an existing datum. This includes the use of existing benchmarks, LIDAR data, EDEN network elevations and/or ground surface elevation from nearby well surveys.

32 l Section 2: Proposed Monitoring Plan

The specific site selection shall be made in consultation with the Agencies. The final location of these transects and the sample sites selected along them shall be subject to the review and approval by the Agencies within 30 days.

Figure 2-6. Ecological monitoring transects adjacent to the CCS. Freshwater wetlands are shown in yellow, saline wetlands in pink, Biscayne Bay and Card Sound benthic in white and associated reference transects in turquoise. Location of the interface of freshwater and saline wetlands shown here is conceptual.

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2.8.6 Freshwater Wetland Transect Assessments Sampling along all transects shall be at three spatial levels (shown in Figure 2-6): 20 m x 20 m major plots (turquoise squares), 5 m x 5 m subplots (pink squares), and 1 m x 1 m subplots (yellow squares). The exact locations of these plots along the transect shall be jointly determined among the Agencies after the initial dry season assessment along each transect. The measurements shall be every 500 m of field porewater specific conductance and temperature depth profiles to 60 cm depth. Each western transect shall be established with a total of four major plots, of which two are within 1.5 km of the CCS and one near the western end of the transect (Figure 2-6). This effort does not require professional surveying.

However, all measurements shall be tied back into an existing datum. This includes the use of existing benchmarks, LIDAR data, EDEN network elevations, and/or ground surface elevation from nearby well surveys.

From each major (20m x 20m) plot, species composition and abundance, woody species cover, herbaceous species cover, and canopy height shall be measured. Percent vegetative cover shall be determined from the aerial imagery, while the other parameters shall be determined from ground assessment. Photographs for each plot shall be digitized, and classification of community types defined for each plot.

During the ground assessment, one 5 m x 5 m subplot shall be randomly established within each quadrant of the larger plot (Figure 2-7). Species diversity and characteristics of woody plant species (e.g., height, diameter at breast height) shall be measured within each subplot.

Within the same quadrant, a 1 m x 1 m subplot shall also be randomly established in the marsh to determine the marsh species diversity and density. All sawgrass (C. jamaicence) culms and spikerush (Eleocharis spp.) stems shall be counted within each subplot. The number of leaves in ten C. jamaicense culms shall be counted and measured; similarly, the height of ten Eleocharis spp. stems shall be measured. Estimates of plant productivity shall be made in woody vegetation (5 x 5 m) plots from changes in morphology (e.g., diameter at breast height) and leaf litter production or alternative production methods, as approved by the Agencies. Plant productivity of dominant graminoid species (in 1 m x 1 m plots) shall be estimated by leaf biomass turnover measurements. The proposed methodology is consistent with methods used in Everglades National Park by the National Science Foundation (NSF) funded Long-Term Ecological Research Program based at Florida International University.

Major plot (20 m x 20 m) measurements shall be conducted once a year, while the 5 m subplot measurements shall be conducted twice a year, at the end of the wet season (June through November) and dry season (December through May). Leaf litter production shall be made quarterly or alternative production measurements made at a frequency as approved by the Agencies. The 1 m subplots shall be measured at three-month intervals.

Twice a year (i.e., once at the end of the wet and dry seasons), ten leaves per stems of each of the dominant species shall be randomly selected and collected from each subplot along each transect for morphological and physiological characterization. Leaf characteristics (i.e.,

leaf length, width, and thickness, water content) shall be measured prior to the leaves being dried and analyzed for C, N, and P contents, as well for 13C. Changes in these plant 34 l Section 2: Proposed Monitoring Plan

characteristics over time and among plants within and between transects shall be analyzed for trends and differences.

Water level and surface water (when present), temperature, and specific conductance shall be measured within one woody vegetation subplot (5 x 5 m) and one graminoid (1 x 1 m) subplot per each major plot every three months. Soil temperature and porewater, and specific conductance shall also be measured at two depths (about 30 cm and 60 cm) in these two subplots per each major plot every three months.

If specific conductance values of >725 S/cm (derived from 250 mg/L Cl-) are observed, two subplots will be sampled and composited (within each major plot) for the tracer suite analysis from porewaters at a depth of about 30 cm. This conductance threshold is subject to revision based on the Initial Ecological Condition Characterization survey and/or other information.

Porewater nutrients (TP, SRP, NH4, NOX, TKN) shall be measured in one graminoid subplot (1 x 1 m) and one woody vegetation (5 x5 m) subplot of each major plot within the root zone (about 30 cm) twice per year. A composite sample may be made from the two samples. Bulk soil nutrients (TP, TN, TOC) and bulk density shall be measured initially (once) in 30 cm cores. For these measurements, composite samples shall consist of 10 cm horizons (0-10 cm, 10-20 cm, and 20-30 cm) from one 30 cm core from a graminoid subplot (1 x 1 m) and one 30 cm core from woody vegetation (5 x5 m) subplot. Additionally, specific conductance and temperature shall be measured in the L-31E Canal along the line of these transects.

As described in the Initial Ecological Condition Characterization (Section 2.8.3), the specific conductance and ecological condition of tree islands along potentially remnant streams and other sites of special interest shall be assessed in a preliminary survey. If results from this survey indicate the need for additional information, then additional transects or plots near the three established transects may be added at the discretion of the Agencies. Sampling shall be consistent with that occurring along transects, but the SFWMD will coordinate Agency review prior to initiation.

Plot site selection, plot design, and sampling along the two shorter freshwater marsh transects north and south of the CCS shall be as described previously for the western transects. However, only two major plots shall be established along each of these transects.

Plot site selection, plot design, and sampling along the reference freshwater marsh transect within the Triangle Area shall be as previously described for the western transects, with a total of four plots.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 35

20 m 10 m Legend:

5m 1 m x 1 m subplots 5 m x 5 m subplots Figure 2-7. Example of a proposed sampling design for ecological monitoring along the transects.

2.8.7 Saline Wetland Transect Assessment Assessment along the five transects containing saline wetlands (shown in pink in Figure 2-6) shall focus on plant community composition, morphology, productivity, and environmental conditions, similar to that described for the freshwater wetlands. The sampling design shall also be similar, with the establishment of two major (20m x 20 m) plots per transect, each with four to eight subplots, pending the presence of herbaceous vegetation. The specific location of these plots shall be determined with the approval of the Agencies after the initial site characterization survey with porewater salinity, temperature, and the tracer suite measurements as described previously. However, along the three short eastern transects, initial site survey points shall be spaced approximately 100 to 200 m apart.

The following shall be measured as previously described for freshwater wetlands: plant community composition; cover; canopy height; leaf litter production; stage; surface water temperature and specific conductance; soil temperature; porewater specific conductance; porewater nutrients; and bulk soil nutrients and density. The tracer suite shall be measured quarterly at 30 cm depth with composited samples from two subplots per each major plot.

Should tracer suite results along a transect indicate potential contributions from the CCS, additional non-composited tracer suite sampling shall be conducted from two additional sites along the transect. Twice a year, at the end of the wet and dry seasons, ten leaves/stems from each of the dominant species shall be randomly selected and collected from each plot along the transect. Leaf characteristics (i.e., leaf length, width, thickness, and water content) shall be measured prior to the leaves being dried and analyzed for C, N, and P contents, as well as for 13C. Changes in these plant characteristics over time and among plants within and among transects shall be analyzed for trends and differences.

36 l Section 2: Proposed Monitoring Plan

The saline coastal portion of the reference transect within the Triangle Area (Figure 2-6) shall also include, at a minimum, two major plots with subplots and sampling of these subplots as described for the saline wetlands.

2.8.8 Biscayne Bay and Card Sound Ecological monitoring shall document benthic biota of Biscayne Bay and Card Sound (i.e.,

SAV, benthic and epibenthic fauna), salinity (calculated with specific conductance), and a tracer suite to distinguish the extent of CCS connectivity to these conditions. Specific conductance and the tracer suite initially shall be surveyed as described previously (see Section 2.8.3). Benthic surveys and fish and invertebrate sampling, as specified in the Plan, shall use results from existing monitoring programs within Biscayne Bay, to the extent possible. Sample methodology for work in the Plan shall be consistent with other programs within Biscayne Bay and Card Sound, but is performed in locations near Turkey Point not sampled by the other programs. Data from these programs shall be used for assessment of reference area conditions.

Benthic surveys shall be made using a transect design to discern potential CCS effects as a function of distance from shore. A set of 15 fixed transects (white lines in Figure 2-6), each 2 km long, shall be sampled randomly along each transect twice per year. The transects shall be arrayed such that each set includes five transects approximately parallel to shore that are 0.25 km, 0.5 km, 1.0 km, 2.0 km, and 4.0 km offshore. If the area is inaccessible, transect locations may be re-evaluated in consultation with the Agencies. The array shall include four sets of these transects that project from the proposed saline wetland transects: one northern zone (offshore near the power plant), one central zone (offshore of the central CCS), one southern zone (offshore of the Sea Dade Canal - southeast CCS corner), and one reference set in northern Barnes Sound (starting north of Middle Key; in turquoise in Figure 2-6).

Sampling shall be done to estimate the species composition, abundance and cover of benthic vegetation (SAV, including seagrass, and macroalgae) and large sessile fauna (e.g., corals and sponges), using the rapid Braun-Blanquet methodology currently used in Florida Bay and Biscayne Bay by RECOVER and other groups (Fourqurean et al. 2002). For each transect and sampling event, eight points shall be randomly selected, with measurements in four quadrats (0.25 m2 each) per sample point. Sampling times shall be done twice per year, once during the months of March-May and once during the months of August-October.

For each benthic survey transect, light extinction shall be measured at one point per transect.

Porewater specific conductance and temperature shall also be measured at each sampling point along these transects, with the tracer suite measured at a subset of points (one site per transect, selected based on the highest specific conductance and/or appearance of ecological stress). Should tracer suite results along a transect indicate potential contributions from the CCS, additional tracer suite sampling shall be conducted from two sites along each transect.

Sampling depth shall reflect exposure within the seagrass root zone (upper 30 cm). Nutrients in porewater shall be measured twice per year and bulk sediments shall be measured once (initially) at two sites per transect and composited as described for the saline and freshwater wetland transects (Section 2.8.6). Seagrass leaf nutrients from the dominant species (likely FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 37

turtle grass) along each transect shall also be analyzed once per year for total nutrient content (C, N, P per dry weight), as well as 13C and 15N ratios.

Nearshore benthic fauna (i.e., small fish and epibenthic macroinvertebrates, such as pink shrimp) will be monitored using methods consistent with other sampling elsewhere in Biscayne Bay. This Monitoring Plan component shall fill a gap between Mangrove Point and Turkey Point, where no such monitoring has been done, using methods that allow quantitative spatial comparison. Sampling shall be done with 30 throw trap samples per sampling event, twice during the year in the wet season and dry season. If a contractor is used that previously has not performed such sampling, consultation with parties that use this method in other areas of the Bay shall be made to ensure sampling and reporting consistencies and allow comparison with other areas within Biscayne Bay. Supporting information, needed to interpret ecological findings, shall be collected along transects and at fish and macroinvertebrate sampling sites. Bottom water specific conductance, temperature, and water depth, along with observations regarding SAV habitat, shall be measured at each site during each sampling event.

38 l Section 2: Proposed Monitoring Plan

Table 2-6. Ecologic monitoring: transect sampling.

Surface Water Soil/

Location(s) and (SW) & Porewater Biotic Sediment Zone number (PW) Parameters Parameters Parameters Frequency 3 east-west SW: Plant Nutrients Annual, bi-Freshwater Wetland transects, 2 (roughly) Water depth, community (TOC,TN, annual, and north-south temperature, and composition, TP), initial once every transects, 1 specific cover, canopy bulk three reference transect conductance. height, density. months, (Figure 2-6). All with productivity, depending 3 spatial levels (20 m PW: temperature, leaf on plot plots, 5 m and 1 m specific characteristics, level (see subplots; Figure 2-7). conductance, C, N, P text).

tracer suite, contents, and andnutrients. 13C.

Five transects plus SW: Plant Nutrients Annual, bi-Saline/ Coastal Wetland reference transect Water depth, community (TOC,TN, annual, and (Figure 2-6). 3 temperature, and composition, TP), initial once every spatial levels (20 m specific cover, canopy bulk three plots, 5 m and 1 m conductance. height, density. months, subplots; Figure 2-7). photosynthesis, depending PW: leaf on plot temperature, characteristics , level (see specific C, N, P text).

conductance, contents, and tracer suite as 13C.

indicated, nutrients.

For SAV and sessile SW: Benthic (SAV, Nutrients Two times Biscayne Bay and Card Sound benthic fauna, 4 sets Water depth, coral, sponge) (TOC, TN, per year for of 5 transects (each temperature, community TP), bulk biota and 2 km long). Eight specific composition and density. waters random sample conductance, and cover, seagrass (including points per transect. light extinction leaf nutrients porewater),

For mobile (C,N,P), 13C, one time epibenthic fauna, and 15N, fish for area between PW: and sediments.

Mangrove and Turkey temperature, invertebrate points, 30 stratified specific species random points. conductance, composition, tracer suite as and abundance.

indicated, and nutrients.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 39

Table 2-7. Ecologic monitoring: initial characterization and survey sampling.

Zone Type Location(s) and number Parameter(s) Frequency Porewater Spatially distributed within Temperature, 1 time; initiate Survey freshwater wetlands; minimum specific within the first dry Saline and of 100 conductivity samples conductance, season after Plan Freshwater and 30 tracer suite samples, tracer suite,and approval.

each for saline and freshwater water depth.

Wetland wetland areas.

Resistivity Biscayne Bay south of Mowry -- Within 3 months Biscayne Bay Survey Canal, including Card Sound. after groundwater wells within Biscayne Bay are operational.

Porewater Spatially distributed within 4 Temperature, 1 time in wetland Survey km of shore; minimum of 100 water depth, and 2 times in bays conductivity samples and 30 specific (wet and dry season);

tracer suite samples within the conductance, and initiate within 3 Bay. tracer suite. months after Plan approval.

40 l Section 2: Proposed Monitoring Plan

3 Field Notification, Data Collection and Reporting 3.3 QUALITY ASSURANCE/QUALITY CONTROL PLAN Pursuant to Chapter 62-160 F.A.C., preparation of a Quality Assurance/Quality Control (QA/QC) Plan shall be initiated immediately upon approval of the Monitoring Plan and submitted for the Agencies approval within 60 days of this Plans approval (effective date of the 2009 Agreement). The QA/QC Plan shall lay out the overall framework to ensure defensible monitoring results and quality reporting. The Plan shall outline procedures used in the field to install wells, manually collect samples, and conduct laboratory analysis. All data collected shall meet Chapter 62-160 F.A.C., SFWMD, and FDEP QA/QC requirements.

More detailed information related to calibration and maintenance of probes and other automated instrumentation shall be provided. A major part of the QA/QC Plan shall describe data management procedures to ensure the data is properly recorded and reported.

Detection limits for each parameter in the Plan shall be listed in the QA/QC Plan for Agency approval. Any request for long-term modification of sampling or analytical procedures shall be submitted in writing at least 90 days prior to the intended modification for review and approval by the Agencies. This shall include a proposed associated amendment of the QA/QC Plan.

To ensure appropriate methods are used to analyze saline and/or hypersaline samples, field measurements of salinity shall be logged and shall accompany all samples analyzed at laboratories. All contract laboratories shall be made aware of and be capable of analyzing constituents in saline and/or hypersaline waters. Field measurements for salinity shall be made in accordance with the Standard Method 2520B using the Practical Salinity Scale of 1978 (PSS78) (APHA 1998). Since the PSS78 is accurate to a salinity range of 0 to 40, it will be necessary to use chloride and TDS data from laboratory measurements to validate salinity values exceeding 40. The QA/QC plan shall include a methodology for performing these validations.

Laboratory analyses shall be performed by laboratories with NELAC certification (for analyses in this Plan that specify such certification) and methods shall be appropriate for samples with a wide range of salinities (i.e., from 0 to about 70 psu). Laboratory audits performed by the Agencies or Agency contractors shall be allowed for any facility analyzing samples from this monitoring program.

FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 41

3.3.1 Field Sampling and Analysis Event Notifications The lead Agency personnel or their designated contractor shall be notified of all field events no later than five days prior to initiation of field events, including but not limited to site surveys, well installation, surface and groundwater sampling, and ecological sampling and analysis. During long-term events, such as well installation, the lead Agency shall be notified for subtasks, such as well development and geophysical logging. Agency personnel shall have access onsite to observe field activities, with annual field audits by the Agencies, and FPL shall provide copies of field-generated notes and logs upon request. If field events are delayed, notification shall be provided as soon as practical and include the revised field event schedule.

3.3.2 Meetings To facilitate communication and keep the Agencies apprised of the monitoring efforts and any significant findings, quarterly meetings for the first year, followed by semiannual meetings of FPL staff and contractors and the Agencies shall be held. Issues of concern or suggested improvements in the monitoring effort commensurate with focused objectives of the Conditions of Certification shall be discussed.

3.4 DATA COLLECTION AND REPORTING Detailed information shall be provided to enable the Agencies to understand potential physical, chemical, and possibly ecological impacts of water movement and/or interchanges between the CCS, surface water, and groundwater. Data shall be submitted on a secure Web site and in the form of hard and electronic report copies. In accordance with the Conditions of Certification and unless stated otherwise in the Fifth Supplemental Agreement, electronic copies of all data and reports generated directly from this Monitoring Plan shall be provided to the SFWMD Director of Water Supply Management, Miami-Dade County Director of DERM, FDEP Director of the Southeast District Office, FDEP Siting Coordination Office Director, and Biscayne Bay Aquatic Preserve Manager.

Table 3-1 provides a summary of data collection efforts and frequency of collection for designated sites with continuous recorders.

42 l Section 3: Field Notifications Data Collection and Reporting

Table 3-1. Sampling frequency for field and laboratory parameters.

Automated Field and Field Electronic Laboratory Manual Sample Type Parameters Frequency Parameters Frequency CCS Water Salinity1, 15 minutes Salinity, specific Quarterly to specific conductance, Semiannually conductance, temperature, tracer (Section 2.2.4) temperature, suite and water and water level quality parameters Groundwater Salinity1, 15 minutes Salinity, specific Quarterly to Monitoring Wells specific conductance, Semiannually conductance, temperature, tracer (Section 2.3.4) temperature, suite and water and water level quality parameters Biscayne Bay Salinity1, 15 minutes Salinity, specific Quarterly to Littoral Zone specific conductance, Semiannually Surface Water conductance, temperature, tracer (Section 2.5.2) temperature, suite and water and water level3 quality parameters Canal Surface Salinity1, 15 minutes Salinity, specific Quarterly to Water (L-31) (3 specific conductance, Semiannually Stations), L-31 conductance, temperature, tracer (Section 2.5.2)

Discharge Canal, temperature, suite and water Card Sound Canal, and water level quality parameters Card Sound Road Canal Interceptor Ditch Salinity1, 15 minutes Salinity, specific Quarterly Control (3 Stations) specific conductance, conductance, temperature temperature, and water level Ecological See Tables Monitoring 2-6 and 2-7.

1 Salinity values calculated using the PSS78.

2 All stations except for the Card Sound Road Canal Station shall be automated.

3 Water levels recorded at stations co-located with monitoring well clusters FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 43

3.5 DATA COLLECTION 3.5.1 Automated Sample Collection Proposed stations identified in Figures 2-1, 2-2, 2-3, 2-4, and 2-5 of this document shall be electronically monitored by FPL. All automated time-series specific conductance, temperature, and water level data as discussed in Section 2 and provided in Table 3-2 shall be compiled from the remote locations by telemetry. Each station as appropriate shall have a stand-alone solar power supply, onsite data loggers (with appropriate storage capacity), and the appropriate sensors needed to monitor the parameters described in Table 3-2. Each data logger shall initially be programmed to collect the required data at 15-minute intervals, unless otherwise noted, starting at the top of the hour based on time at the atomic clock and maintained in Eastern Standard Time. The data loggers shall also not account for Daylight Savings Time to retain consistency with SFWMD data collection efforts. Calibration of sensors shall be a function of the manufacturers specifications. All sensors and equipment shall be maintained per the manufacturers specifications.

Table 3-2. Proposed automated time-series data collection from surface and groundwater stations.

Parameter Units Temperature degrees (Celsius)

Level feet (NGVD and NAVD)

Specific Conductance µS cm-1 Salinity psu 3.5.2 Manual Sample Collection Data from efforts such as borehole logging, well and stage recorder surveying, manual water quality sampling, and biological monitoring shall be recorded in field notebooks prior to entry into an electronic database. As outlined in Section 2 and per Table 3-1, water quality samples shall be collected from groundwater wells, surface waters, and the CCS, as part of regular monitoring on a quarterly and/or semi-annual basis.

3.6 DATA REPORTING 3.6.1 Web Database The database shall be maintained and archived by FPL on a Web portal. This server shall be backed up and archived weekly to minimize the risk of data loss. The Agencies shall be given passwords to access the data 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day/7 days a week. A web masters contact 44 l Section 3: Field Notifications Data Collection and Reporting

information shall be clearly posted on the web page. The Web-based applications shall provide the following:

• Geologic and hydrogeologic data acquired during this investigation.

• Well construction data and spreadsheets.

• Downhole geophysical logs.

• Geophysical surveys.

• Water budget and material load input values, calculations, and sums.

• Bathymetric survey.

• Equipment calibration logs and maintained records.

• Manual sampling of COCs, field data sheets, analytical laboratory results with QA/QC documentation.

• Ecological data.

Summarized data shall include but is not limited to:

• Groundwater and surface water hydrographs.

• Spreadsheet summaries and graphical representations of current and historical manual sample results.

• Automated reports such as, but not limited to, water level, temperature, specific conductance, and ID pump operations, meteorological monitoring.

• Log of any plant operations change, system shut downs or deviations that might affect parameters in this investigation.

• All results generated as a result of ecological monitoring (Section 2.8) and, Geophysical Surveys (Section 2.3.3).

• Semiannual and annual reports in PDF formats.

• All other reports that pertain to this Monitoring Plan.

• Aerial imaging results.

If determined that additional information must be added or modified to enhance the Web site, FPL shall do this within 60 days of Agency notification.

3.6.2 Automated Data Reporting The data generated from continuous electronic monitoring of meteorological, surface and groundwater stations, and ID stage and pump operations shall be accessible real-time to the SFWMD; however, the raw data shall not become official until FPL has had a chance to conduct a QA/QC review. The data shall be provided in the comma delimited format for use in the SFWMD databases. The column headings and format will be specified by the SFWMD after consultation with FPL. This shall be done within 50 days of the date of collection. FPL shall provide electronic accessibility of the results to the Agencies. All data FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 45

shall be stored in a database maintained by FPL; this server shall be backed up and archived weekly to minimize the risk of data loss. The data shall be tabulated in downloadable Excel, comma delimited format, and where appropriate, graphically presented to allow monitoring of operations by FPL staff, quick review of time-series data variations, and sensor performance.

3.6.3 Manual Data Reporting Data collected from manual sampling and monitoring shall be stored in a database maintained by FPL; this server shall be backed up and archived weekly to minimize the risk of data loss. Electronic copies of analytical data shall be provided simultaneously to FPL and the SFWMD; however, the data shall not become official until it has undergone a QA/QC review by FPL. A summary of QA/QC analytical results shall be posted on a secure Web site. While the length of time between collecting the data and posting it will vary depending on what is collected, FPL shall post the data within three months of collection or at minimum provide a status as to when the data shall be posted. The manual data shall be compiled with automated data into reports as outlined as follows. Data files shall be made electronically available to the Agencies.

3.6.3.1 Surveyors Report FPL shall obtain a licensed Florida surveyor to conduct detailed surveys at each location where monitoring is being done, except as specified in Section 2.8 (Ecological Monitoring).

The data collected from this effort shall be compiled and documented in a report that documents all data and techniques. The order of surveying shall be documented (1st, 2nd, or 3rd order).

Data collected from the survey of the groundwater monitoring wells and surface water stations shall be documented. Appendix C provides surveying requirements for this Monitoring Plan. An electronic copy of the field notes, an electronic copy of all computation sheets, site photographs, and benchmark sheets shall also be included.

3.6.4 Geology and Hydrogeology Report Geologic and hydrogeologic data, as outlined in this Monitoring Plan, shall be collected to better understand the movement of water within the Biscayne aquifer, in the immediate vicinity of the CCS. This is relevant because subsurface conditions may influence the extent and rate of CCS water migration.

This report shall provide relevant and available information on the lithology and hydrostratigraphy of the subsurface rocks and sediments of that area.

Data collected during well installation (Section 2.3.1), including detailed lithologic logs, borehole geophysics, optical borehole logs, initial induction logs, temperature and flowmeter logs, field water quality data, and well construction details shall be compiled and submitted 46 l Section 3: Field Notifications Data Collection and Reporting

to the Agencies within 60 days of completion of each well cluster. Geophysical logs shall be provided electronically in a PDF and LAS formats. In addition, a summary of well drilling procedures, geophysical logging procedures, and instrumentation used shall be provided.

Based on wells installed from this monitoring effort and other subsurface geologic data, scaled geologic cross-sections, including macroporosity zone and geophysical log overlays, shall be generated and included in the report. This includes information from the induction logs, which reveal zones of saline water. Also, a plan view map showing the location of significant features shall be included. The information generated from this report will be used to enhance understanding of groundwater movement in the area and may be used to aid in the interpretation of tracer suite and water quality monitoring data. The final geology and hydrogeology report shall be signed and sealed by a Florida-licensed geologist experienced in hydrogeologic investigation.

3.6.4.1 Biscayne Bay Geophysical Survey Report Biscayne Bay geophysical surveys shall be initiated within three months after the Biscayne Bay wells are installed. Results from these wells shall be used to estimate salinity from resistivity values. Results from resistivity survey shall be reported within six months of completion of a survey. Reports shall include a detailed description of methodology, maps showing GPS-derived survey track line locations, and figures showing depth profiles of resistivity along track lines, and any associated measurements along the track line. Best estimates of salinity or conductivity, derived from resistivity and all available salinity or conductivity data shall be made with tabular documentation of data and calculations used for this estimate (in .xls or .xlsx format). All geophysical survey data shall be supplied to the Agencies as raw tabular data, as well as processed graphical output, and all geophysical survey reports shall be signed and sealed by a Florida-licensed geologist experienced in geophysical interpretation.

3.6.5 Initial Ecological Condition Characterization Report Initial information on salinity distribution shall be derived from porewater surveys of the freshwater and saline wetlands adjacent to the CCS and Biscayne Bay and Card Sound.

Results from these surveys shall be detailed in a report within one year of Plan approval. The report shall provide a detailed description of all sampling and analysis methods, all data (including field and laboratory measurements, with QA/QC results, such as instrument blanks and calibrations), the GPS coordinates of all sites sampled, and a map showing site locations. Climatic data from the previous month as recorded by onsite or nearby instrumentation (rain data, air temperature, etc.) shall also be indicated in the report. Results, including any calculations generated from the data, shall be provided in a spreadsheet (.xls or

.xlsx format). The details and supporting data for specific transect establishment (i.e.,

wetland and Biscayne Bay) shall be included in this report. Field observations shall be recorded by photographs in field logs, specifying the dates and GPS coordinates, which shall also be provided in the report. The report shall identify areas of CCS water connectivity with surface sediments and soils as indicated by the CCS tracer suite, and discuss evidence FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 47

concerning the potential ecological influence of the CCS. Timelines and status of completeness for any other elements of the ecological monitoring shall also be included.

3.6.6 Semiannual and Annual Comprehensive Monitoring Reports Semiannual and annual reports shall be provided to the Agencies during the pre-Uprate and post-Uprate monitoring periods. Comprehensive semiannual monitoring reports shall be submitted for documentation of site conditions, data generated as part of Plan implementation including but not limited to, groundwater monitoring, surface water monitoring, CCS monitoring, and ecological monitoring, as described in the Plan. The ecological component shall be a subsection of the report and shall provide all data generated in the report period as indicated in the Ecological Monitoring (Section 2.8), including all field and laboratory measurements made (with QA/QC results, such as instrument blanks and calibrations), the GPS coordinates of all sites sampled, and a map showing site sampling locations. The data and any calculations generated from the data shall be provided in electronic format (.xls or .xlsx format). The column headings and format will be specified by the SFWMD.

The report(s) shall be submitted within 90 days of the completion of each monitoring period (wet season [June through November] and dry season [December through May]) and include quarterly and semiannual monitoring results of the previous periods. The report(s) shall include a brief summary of the CCS operations and operational changes that result in changes in physical or chemical characteristics of cooling water effluent or flow rates. A description of monitoring activities, station modifications and station operational summaries, graphic summaries of electronic monitoring data with electronic data archives, spreadsheet summaries of physical parameters, sample results, sampling field forms and laboratory results, L-31E salinity profile reports, monitoring well induction logging reports, and ID monitoring logs shall be included. Annual reports submitted during the post-Uprate monitoring period shall include conclusions regarding change from the pre-Uprate monitoring period.

The collected monitoring information, shall be used to provide an analysis of the following, to the extent supported by the data: 1) estimates of the spatial extent of CCS derived plume migration and the rate and direction of this migration; 2) for a given location outside of the CCS, an estimated percent contribution of waters originating from the CCS (based on a comparison of tracer suite constituent concentrations and other select chemical constituent concentrations in CCS waters, with concentrations of such constituents in surface water and groundwater outside of the CCS); and 3) estimates of the quantity of water and salt load that the CCS produced based on the updated CCS water budget. The report shall include recommendations for installation of additional monitoring points or other Plan modifications if needed to complete the monitoring objectives. The report(s) shall include a completeness evaluation of specific Plan objectives and an updated monitoring schedule.

48 l Section 3: Field Notifications Data Collection and Reporting

To estimate the rate at which water is transported or dispersed from the CCS, a water budget analysis shall be performed (Section 2.6). The results of the bathymetric survey, CCS characterization, water budget, and salt and ionic loads shall be included in the Water Budget Analysis Report. This report shall be generated annually. Following collection of data during the pre- and post-Uprate period, the salt and ionic loads shall be reassessed to see if there are any significant changes from the pre-Uprate period.

The water budget report shall include a breakdown for each of the contributions as described in Section 2.6.3 (Water Budget Calculations).

3.6.7 Comprehensive Pre-Uprate Report A comprehensive Pre-Uprate Final Report shall be submitted for documentation of background conditions before implementation of the Uprate project. The report shall include summaries of data presentations included in semiannual reports with trends analysis, including incorporation of seasonal or other variations over the pre-Uprate monitoring period. The data and any calculations generated from the data shall be provided in electronic format (.xls or .xlsx format). The column headings and format will be specified by the SFWMD. To meet the objectives, the report shall include a completeness evaluation of specific Plan objectives and recommendations for additional investigation, if appropriate.

The comprehensive Pre-Uprate Final Report will take the place of one of the annual reports.

FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 49

50 l Section 3: Field Notifications Data Collection and Reporting 4

Schedule Within 60 days after the approval of the Plan (effective date of the 2009 Agreement), FPL shall submit a monitoring schedule with a detailed breakdown of timelines for implementation of monitoring components and plant Uprate activity.

Permits for installing monitoring wells and instrumentation in Biscayne National Park must be obtained and entities to conduct the work selected. It is envisioned that it will take at least six months to drill all wells, purchase instrumentation, set up the monitoring network, and be fully operational.

The Uprate project is expected by FPL to come online in the spring of 2012. Two years of data collection during the pre-Uprate (as defined in Section 1) is expected. Pre-Uprate monitoring shall continue until commencement of the Uprate. Post Uprate monitoring, as may be modified, shall continue for a time period as specified by the Agencies. During this time, both automated and manual data collection shall be conducted.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 51

52 l Section 4: Schedule References Cited APHA. 1998. Standard Methods for the Examination of Water and Wastewater. Prepared and Published Jointly by the American Public Health Association, American Water Works Association, and the Water Environmental Federation. 20th Edition, 1998.

Bellmund, S., A. Renshaw, A. Mayoral, H. Jobert, C. Tilghman. 2007. Salinity Sampling in Biscayne Bay (2005-2006). A Report to the U.S. Army Corps of Engineers for the Monitoring and Assessment Plan of the Comprehensive Everglades Restoration Plan.

151.

Cunningham K. J., J.I. Carlson, and N.F. Hurley. 2004. New Method for Quantification of Vuggy Porosity from Digital Optical Borehole Images as Applied to the Karstic Pleistocene Limestone of the Biscayne Aquifer, Southeastern Florida. Journal of Applied Geophysics, 55:77-90.

Cunningham, K. J., R.A. Renken, M.A. Wacker, M.R. Zygnerski, E. Robinson, A.M. Shapiro, and F.L. Wingard. 2006a. Application of Carbonate Cyclostratigraphy and Borehole Geophysics to Delineate Porosity and Preferential Flow in the Karstic Limestone of the Biscayne Aquifer, SE Florida. In: Harmon, R. S., and Wicks, C., eds., Perspectives on Karst Geomorphology, Hydrology, and Geochemistry - A Tribute Volume to Derek C.

Ford and William B. White, Special Paper, Geological Society of America, 404, 191-208.

Cunningham, K. J., M.A. Wacker, E. Robinson, J.F. Dixon, and F.L. Wingard. 2006b. A Cyclostratigraphic and Borehole Geophysical Approach to Development of a Three-Dimensional Conceptual Hydrogeological Model of the Karstic Biscayne Aquifer, Southeastern Florida. U.S.

Geological Survey Scientific Investigations Report 2005-5235, 69.

Cunningham, K. J., M.C. Sukop, H. Huang, P.F. Alvarez, H.A. Curran, R.A. Renken, and J.F. Dixon. 2009. Prominence of Ichnologically Influenced Macroporosity in the Karst Biscayne Aquifer: Stratiform Super-K Zones. Geological Society of America. In Press. Vol.

121(1-2), 164-180.

Fish, J.E. and M. Stewart. 1991. Hydrogeology of the Surficial Aquifer System of Dade County, Florida. USGS Water Resources Investigation Report 90(4108):50. U.S. Geological Survey, Tallahassee, FL.

Fitterman, D.E. and M. Deszcz-Pan. 2001. Saltwater Intrusion in Everglades National Park, Florida Measured by Airborne Electromagnetic Surveys. In First International Conference on Saltwater Intrusion and Coastal Aquifers Monitoring, Modeling, and Management, Essaouira, Morocco, April 23-25, 2001.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 53

Fourqurean, J.W., M.J. Durako, M.O. Hall, and L.N. Hefty. 2002. Seagrass Distribution in South Florida: A Multi-agency-Coordinated Monitoring Program. In The Everglades, Florida Bay, and Coral Reefs of the Florida Keys: An Ecosystem Sourcebook, eds. J.W.

Porter and K.W. Porter. CRC Press, Boca Raton, FL, 497-522.

Robblee, M.B. and J.A. Browder. 2008. 2008 Assessment Update: Pink Shrimp Indicator for the Southern Estuaries. U.S. Geological Survey, Center for Water and Restoration Studies and NOAA Fisheries Service, Southeast Fisheries Science Center. Available from:

http://www.sfrestore.org/scg/scg_meetings/2008_meetings/092508/Pink%20Shrimp

%20ASSESSMENT%202008.pdf State of Florida Division of Administrative Hearings (DOAH). 2008. Miami-Dade Countys Preliminary Statement of Issues, Case No. 08-0378-EPP. Florida Department of Environmental Protection (FDEP) OGC Case No. 07-2624.

Swarzenski, P.W., W.C. Burnett, Y. Weinstein, W.J. Greenwood, B. Herut, R. Peterson, and N. Dimova. 2006. Combined Time-Series Resistivity and Geochemical Tracer Techniques to Examine Submarine Groundwater Discharge at Dor Beach Israel.

Geophysical Research Letters, 33, L24405, doi:10.1029/2006GL028282.

54 l References Cited

A FDEPs Conditions of Certification IX and X Related to the FPL Turkey Point Power Plant Uprate IX. Biscayne Bay Surface Water Monitoring As proposed, the Turkey Point Units 3 and 4 Uprate project may cause an increase in temperature and salinity in the cooling canal system. Field data is needed to determine impacts of the proposed changes in the Turkey Point cooling canal system on Biscayne Bay.

A. Within 180 days following certification of Units 3 & 4, FPL shall submit a Biscayne Bay Surface Water Monitoring Plan (Plan) pursuant to Chapter 62-302, F.A.C. to the FDEP Southeast District Office for review and approval. The Plan shall include, at a minimum, the following components:

1. salinity and temperature monitoring within the surface waters of the Bay, including the Biscayne Bay Aquatic Preserve; (Specific parameters to be measured, including specific conductance and temperature, shall be sampled in accordance with Chapter 62-160, F.A.C.);

2. a minimum of five monitoring stations located near shore in the vicinity of the FPL Turkey Point Power Plant; and three specific monitoring locations, sampling frequencies and methods, and specific parameters to be monitored.

3. specific monitoring locations, sampling frequencies and methods, and specific parameters to be monitored.

B. This monitoring data shall be compared to data using compatible monitoring instrumentation already in place in Biscayne Bay.

C. FPL shall continue the monitoring of salinity and temperature in the cooling canals under its industrial wastewater facility permit.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l A-1

D. If the Department determines that the pre- and post-Uprate salinity and temperature monitoring data indicate potential adverse changes in the surface water in Biscayne Bay, then the Department may propose additional measures to evaluate or to abate such impacts to Biscayne Bay.

E. The Plan, including monitoring locations, shall be approved prior to implementation.

The Department shall indicate its approval or disapproval of the submitted Plan within 90 days of the originally submitted information. In the event that the Department requires additional information for the licensee to complete, and the Department to approve the Plan, the Department shall make a written request to the licensee for additional information no later than 30 days after receipt of the submitted information. Any changes to the approved Surface Water Monitoring Plan shall be approved by Coastal and Aquatic Managed Area personnel in consultation with other FDEP personnel. [62-160,62-302, 62-302.700,62-520.600, F.A.C.]

X. Surface Water, Groundwater, and Ecological Monitoring This is a consolidated condition agreed upon by three Agencies: Department of Environmental Protection (FDEP), Miami-Dade County Department of Environmental Resource Management (DERM), and the South Florida Water Management District (SFWMD). This consolidated condition sets forth the framework for new monitoring and, as may be needed, abatement or mitigation measures, for approval of FPLs Turkey Point Units 3 and 4 Uprate Application. Specific monitoring and potential modeling parameters will be identified and implemented pursuant to a monitoring plan as part of a supplemental agreement between FPL and the SFWMD as described as follows.

A. In addition to the monitoring framework set forth in this consolidated condition, within 180 days after Certification, FPL shall execute a SFWMD approved Fifth Supplemental Turkey Point Agreement (Fifth Supplemental Agreement) to the original 1972 Agreement between FPL and the SFWMD pertaining to FPLs obligation to monitor for impacts of the Turkey Point cooling canal system on the water resources of the SFWMD in general and the facilities and operations of the SFWMD (the "Agreement"). Subject to the SFWMD's approval, FPL shall also amend the Agreement's Revised Operating Manual as referenced in Paragraph C Monitoring Provisions (the Revised Plan) of the Fourth Supplemental Agreement, dated July 15, 1983. The Revised Plan shall be incorporated into the Fifth Supplemental Agreement and shall include assessment of potential impacts to surface water and groundwater, including wetlands, as needed, in the vicinity of the cooling canal system. The specific monitoring boundaries shall be determined as part of the Revised Plan.

A-2 l Appendix A

B. The Revised Plan shall be designed to be in concurrence with other existing and ongoing monitoring efforts in the area and shall include but not necessarily be limited to, surface water, groundwater, and water quality monitoring, and ecological monitoring to:

1. delineate the vertical and horizontal extent of the hyper-saline plume that originates from the cooling canal system and to characterize the water quality including salinity and temperature impacts of this plume for the baseline condition;

2. determine the extent and effect of the groundwater plume on surface water quality as a baseline condition; and

3. detect changes in the quantity and quality of surface and groundwater over time due to the cooling canal system associated with the Uprate project. The Revised Plan shall include installation and monitoring of an appropriate network of wells and surface water stations. The Revised Plan shall be approved by the SFWMD in consultation with the FDEP Office of Coastal and Aquatic Managed Areas, the FDEP Southeast District Office, and DERM.

C. FPL shall transmit electronic copies of all data and reports required under the Fifth Supplemental Agreement and the Revised Plan in accordance with timeframes as approved in the Fifth Supplemental Agreement to:

1. SFWMD, Director, Water Supply (or alternative transmittal procedures to be described in the Fifth Supplemental Agreement);

2. Miami-Dade County, Director, DERM; FDEP, Director, Southeast District Office;

3. FDEP Siting Coordination Office;

4. FDEP, Director, Biscayne Bay Aquatic Preserve Manager D. If the FDEP in consultation with SFWMD and DERM determines that the pre- and post-Uprate monitoring data: is insufficient to evaluate changes as a result of this project; indicates harm or potential harm to the waters of the State including ecological resources; exceeds State or County water quality standards; or is inconsistent with the goals and objectives of the CERP Biscayne Bay Coastal Wetlands Project, then additional measures, including enhanced monitoring and/or modeling, shall be required to evaluate or to abate such impacts. Additional measures include, but are not limited to:

1. the development and application of a 3-dimensional coupled surface and groundwater model (density dependent) to further assess impacts of the Uprate Project on ground and surface waters; such model shall be calibrated and verified using the data collection during the monitoring period; FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l A-3

2. mitigation measures to offset such impacts of the Uprate Project necessary to comply with State and local water quality standards, which may include methods and features to reduce and mitigate salinity increases in groundwater including the use of highly treated reuse water for recharge of the Biscayne aquifer or wetlands rehydration;

3. operational changes in the cooling canal system to reduce any such impacts; and/or

4. other measures to abate impacts as may be described in the Revised Plan.

[Sections 373.016, 373.223, F.S.; Rules 40E-4.011, 40E-4.301, 40E-4.302, F.A.C.; Sections62-302 and 62-520, F.A.C.; Section 24-42, Code of Miami-Dade County, Miami-Dade County Comprehensive Development Master Plan (CDMP) Land Use Element, Conservation Element, Intergovernmental Coordination Element, Coastal Management Element.]

A-4 l Appendix A

B Near Shore Sonde Deployment Methods The near shore sites, or mangrove sites, have sondes deployed to measure salinity using differing methods. This is due to the extremely shallow water at these locations, as well as the composition of the bottom substrate. Normally the sondes are deployed in a vertical position attached to a mooring pin, which has been cemented in place by drilling a hole in the bay floor. However, at the mangrove sites, there is insufficient water for vertical deployments, so the instruments are deployed horizontally, and the bottom is composed mainly of mud, which is unsuitable for drilling. Therefore, the instruments are deployed affixed to cement paving slabs, which have been drilled in two places at opposing corners and fitted with stainless steel eyebolts that settle into the mud, with the eyes of the eyebolts well above the bottom and in the water column. The sonde is then locked to one of the eyebolts and fastened securely to both using nylon tie-wraps. This maintains a constant horizontal position, which will remain beneath the water surface even at low tide. This positioning also provides ample space for an additional sonde to be mounted simultaneously for concurrent sampling and overlapping data at deployment and retrieval times to ensure quality control. Per instruction by YSI personnel, the instruments are oriented in a way such that the sensor's hole is not facing directly down, which could cause air bubbles to accumulate and skew the salinity data.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l B-1

B-2 l Appendix B C

Survey Parameters Collected during Groundwater and Surface Water Investigations Data collected from the survey of the groundwater monitor well, and surface water sites shall include, but not be limited to the following:

• Latitude

• Longitude

• State Planar Coordinates North American Datum of 1983 (NAD), Florida East zone

• State Planar Coordinates NAD of 1927, Florida East zone

• Natural Ground Surface Elevation Elevation in North American Vertical Datum of 1988 (NAVD)

Elevation in National Geodetic Vertical Datum of 1929 (NGVD)

• Elevation of bottom of surface water location Elevation in NAVD Elevation in NGVD

• Monitor Well Top-of-Casing Elevation Elevation in NAVD Elevation in NGVD

• Elevation of any nearby standing surface water at the time of surveying (15 feet radius from site)

An electronic copy of the field notes, an electronic copy of all computation sheets, site photographs, a surveyor report, and benchmark sheets shall also be included.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l C-1

C-2 l Appendix C D

Special Requirements for an Electromagnetic Induction Well In general, the groundwater monitoring wells shall meet normal State or Federal Regulations for monitoring wells. The USGS publication WRIR-96-4233, located on the Web, available at (http://water.usgs.gov/owq/pubs/wri/wri964233/), provides general guidelines for the installation of monitoring wells used to evaluate water quality. In addition to these general guidelines, there are some special requirements needed for a well to be logged using an electromagnetic induction probe, including:

Casing material PVC - Metal casing will interfere with the log.

Well Screen PVC - Metal screens will interfere with the log.

Well diameter generally 2 to 6 - The USGS is currently logging wells 2 to 6 in diameter. For shallow wells, 2 is acceptable. For deep wells (>150 feet), the USGS suggests 3 or 4 well diameters to make sure the probe does not get stuck. The probe is most sensitive to differences in conductivity within an 8 to 40 donut-shaped radius around the well because of bends or distortions in well casing.

Depth extending to the base of the Biscayne aquifer - This allows evaluation of changes throughout the zone of interest. Salinity is usually but not always highest at the base of the aquifer; this is generally a good depth to set the open interval. The driller needs to be careful not overshoot the bottom of the aquifer.

If the monitoring well is to be used for detecting upconing directly beneath a wellfield, there are alternate strategies. If only fresh water is found when drilling, finish the well at the base of the aquifer. Future upconing would most likely begin at or near the base of the aquifer.

If salt water is found when drilling, one can: (1) Stop drilling and screen the well at this depth so that the chloride level can be monitored at this depth, or (2) Keep drilling to the base of the aquifer and complete the well at this depth to evaluate the full thickness of encroachment and maximum salinity. This would allow one to determine if seawater is encroaching preferentially through just one zone or throughout the depth of aquifer. Either FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l D-1

way, induction logging can help detect future upconing. Option 2 describes what is happening in the aquifer, but Option 1 provides the ability to obtain a precise chloride value in mg/l.

Open Interval 5 to 10 feet - The idea of a short screen length is to be able to sample a discrete interval and avoid the effects of flow within the borehole.

Chloride Sampling - It is generally good to collect water chloride samples during drilling to determine if encroached seawater is present.

Annular Seal - Neat Cement is the best type of annular seal. A seal just above the filter pack is necessary to prevent the cement from infiltrating the filter pack. A very fine sand or bentonite is proven means of isolating the well screen.

Manhole cover - Metal is acceptable at the top of well, but no metal should be used down the hole or on the casing.

Well centralizers - Well centralizers are only acceptable if they are non-metallic; metallic screws used for well centralizers can cause problems.

Flush Mounted Finish This is usually best because the logging requires setting a tripod over the well.

Clustered wells - If wells are too close together, and one has a metal object in it, this can affect the log in the other well.

Well development - The well should be developed to clear and consolidate the filter pack.

This also needs to be done to ensure that cement did not seep into the filter pack and clog it, as well as to verify that the well is not in an impermeable zone. Well development should be performed to clear up the hole prior to well installation. If there is a lot of mud or muddy water in the hole, the first few logs might detect this. Do not use salty or electrically conductive drilling fluid.

D-2 l Appendix D

E Tritium Sample Collection and Analysis Protocols Introduction The measured tritium values along with a measure of salinity (salinity, conductivity, or chlorinity) will be used in a ternary mixing model that will estimate the proportion of the three potential end members in the sample, CCS water, BBSW, and fresh groundwater. Most of the influence of the CCS on the groundwater will be through the sub-surface connection between the CCS and the Biscayne aquifer. It is possible that tritium-enriched rainfall, which originates from evaporated CCS water, could be deposited in the area immediately surrounding the CCS. Measurements of tritium in rainfall will be used to determine if tritium-enriched rainfall is occurring. If it is, the amount of this rainfall, and thus tritium, that reaches the aquifer will be estimated by taking into account the extent to which rainwater is recycled back into the atmosphere. These measurements and calculations, and other available data as applicable will be used to determine if an adjustment is needed in what is considered background levels of tritium for groundwater surrounding the CCS.

Sample Collection and Analysis of Tritium Samples for tritium analysis will be collected in 1-L high-density polyethylene bottles. Water can be transferred into the sample bottles using any type of sampling pump. The sample bottles do not require rinsing before filling. Sampling personnel shall not wear luminous watches because these watches can contain relatively large amounts of tritium, which would contaminate the water sample. The samples will not be filtered. Samples will be stored and transported at room temperature. Each sample will at a minimum be labeled with the sample location, collection date and time, and samplers name. All groundwater and surface water stations (7 samples in the CCS at varying depths) identified in this Monitoring Plan will be sampled for tritium quarterly. In addition to these samples, rainfall samples will be collected from at least nine stations (discussed as follows). These rainfall samples will be used to assess whether deposition of evaporated CCS water could contribute detectable amounts of tritium via rainfall to the surface and groundwater surrounding the CCS.

The detection limit for tritium analysis shall be <10 pCi/L for groundwater and surface water samples, except as specified below. The analytical uncertainty measurement will be

<10 pCi/L or +/-3.5 percent, whichever is larger, and the methodology used for this analysis shall be consistent with these requirements. The laboratory performing the low-level tritium FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l E-1

analyses will participate in the International Atomic Energy Agencys tritium inter-laboratory comparison study. This proficiency testing program is carried out every four years using standards ranging in activity from <1 pCi/L to ~2000 pCi/L. The laboratory shall maintain active participation in the proficiency testing program. FPL shall propose specific tritium analytical techniques in the QA/QC plan, including the method detection limit and the uncertainty associated with the method, for review and approval by the Agencies.

During the initial monitoring period over the first year, a test methodology with a 10-pCi/L detection level will be used for all monitoring wells and surface water outside the CCS.

Detection levels for sampling within the CCS will initially be at 350 pCi/L. The adaptive monitoring approach will be used to identify appropriate changes in detection levels for specified locations.

After the first year of sampling adjustments to detection levels may be implemented if surface water samples from the CCS and wells very close to the CCS (i.e., L3 and L5) and directly underneath the CCS, have tritium levels well above the detection limits of 350 pCi/L. An acceptable alternative method would be direct liquid scintillation counting (LSC),

which has a detection limit of 350 pCi/L. It is possible that some other groundwater and surface water samples will have consistent tritium values well above the lower detection limit of 10 pCi/L. If a site has been established to have a tritium concentration >700 pCi/L by four consecutive samplings over a one-year period, then future samples may be analyzed by the LSC, or equivalent, method upon the notification and approval of the Agencies.

If eight quarterly samples taken over a two-year period from a particular groundwater or surface water sampling site indicate that the tritium concentration of these samples is < 15 pCi/L or background as determined by the Agencies, then tritium sampling at that site may be discontinued. As long as the chloride concentration of the samples collected at said sampling site remains below 250 mg/L, tritium does not need to be sampled. If chloride concentrations rise above 250 mg/L, then tritium sampling shall be resumed for a time period to determine if the source of the increased chloride is attributable to the CCS.

Tritium Measurements in Rainfall FPL shall conduct an evaluation of the extent of influence of local rainfall on tritium levels in groundwater and surface water for purposes of providing additional data for identification of background levels of tritium. Eight rainfall collection stations will be co-located with monitoring well clusters north, east, south, and west of the CCS (shown in Figure E-1).

One collector will be located to the north and one to the south. One collector will be located in Biscayne Bay to the east. One collector will be located adjacent to the L-31E Canal, two collectors will be located approximately two miles west of the plant, and two collectors will be located approximately four miles west of the plant. Collected rainfall data will be analyzed for a period of one year, and determination of future sampling will need to be assessed. After the testing period, based on all available information, a scientifically based level(s) of tritium in rainfall shall be identified across the area.

E-2 l Appendix E

Rainfall Sample Collection Protocols The following protocols shall be used for rainfall sample protection:

• Rainfall collectors will be sampled four times per year.

• Rainfall collectors will be deployed at the sampling locations continuously, and will be designed to integrate samples collected during a three-month time period.

• At the end of every three-month sampling period, collected rainfall will be sent to the laboratory for tritium analysis. Tritium rainfall averages have been reported <10 pCi/L, therefore a laboratory detection limit of <10 pCi/L shall be used for rainfall analysis. If the concentrations of tritium in the rainfall are less than or equal to the MDL, any rainfall contributions of tritium shall be considered negligible.

• Data will be correlated with either local (temporary setups alongside rainfall collectors) or nearby micrometeorological stations.

• If tritium is observed in the shallow (<30 feet deep) monitoring wells, sampling of porewater may be conducted to determine directionality of tritium movement in the ground.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l E-3

Figure E-1 Rainfall collection stations.

E-4 l Appendix E

United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of: FLORIDA POWER & LIGHT COMPANY NRC-033 (Turkey Point Nuclear Generating, Units 3 and 4)

Submitted Nov. 10, 2015 ASLBP #: 15-935-02-LA-BD01 Docket #: 05000250 & 05000251 Exhibit #: NRC-033-00-BD01 Identified: 1/4/2016 Admitted: 1/4/2016 Withdrawn:

Rejected: Stricken:

Other:

1 SOUTH FLORIDA WATER MANAGEMENT DISTRICT 2

3 RESOLUTION NO. 20094M 4

5 A RESOLUTION OF THE GOVERNING BOARD OF THE SOUTH FLORIDA WATER 6 MANAGEMENT DISTRICT APPROVING THE FIFTH SUPPLEMENTAL AGREEMENT 7 BETWEEN FLORIDA POWER AND LIGHT COMPANY AND THE SOUTH FLORIDA 8 WATER MANAGEMENT DISTRICT FOR THE PURPOSE OF GOVERNING THE RIGHTS 9 AND OBLIGATIONS OF THE PARTIES CONCERNING THE OPERATION AND 10 MONITORING OF THE COOLING CANAL SYSTEM FOR FLORIDA POWER AND 11 LIGHTS COMPANY'S POWER GENERATING PLANT AT TURKEY POINT IN MIAMI-12 DADE COUNTY, FLORIDA 13 14 WHEREAS, Florida Power and Light Company (hereinafter referred to as FPL) is a Florida corporation 15 pursuant to the Laws of Florida. The principal office of FPL is located at 700 Universe Boulevard, Juno Beach, Florida 16 33408; and 17 WHEREAS, FPL and the CENTRAL AND SOUTHERN FLORIDA FLOOD CONTROL DISTRICT, 18 predecessor to the SOUTH FLORIDA WATER MANAGEMENT DISTRICT (hereinafter referred to as DISTRICT),

19 originally entered into an agreement on February 2, 1972 that has subsequently been supplemented four times with the 20 Fourth Supplemental Agreement dated July 15, 1983; and 21 WHEREAS, on October 29, 2008, the Florida Department of Environmental Protection (DEP) approved 22 Power Plant Site Certification # PA 03-45 (Certification) for the FPL Turkey Point Plant Units 3 and 4 Nuclear Power 23 Plant Uprate Project; and 24 WHEREAS, the Certification included consolidated condition of certification X (consolidated among DEP, 25 DISTRICT and Miami-Dade County) that requires a fifth supplemental agreement between FPL and the DISTRICT to 26 incorporate a new monitoring plan among other things; and 27 WHEREAS, the DISTRICT, FPL, DEP and Miami-Dade County have developed a new monitoring plan that 28 includes ground water, surface water, and ecological monitoring in and around the Turkey Point cooling canal system; 29 and 30 WHEREAS, FPL and the DISTRICT desire to hereby enter into a fifth supplemental agreement that reserves 31 the rights and obligations of the parties concerning the operation and monitoring of the cooling canal system for FPL's 32 power generating plant at Turkey Point.

33 BE IT RESOLVED BY THE GOVERNING BOARD OF THE SOUTH FLORIDA WATER 34 MANAGEMENT DISTRICT:

35 Section 1. The Governing Board of the South Florida Water Management District hereby approves the Fifth 36 Supplemental Agreement with FPL.

1 Section 2. A copy of the Fifth Supplemental Agreement is attached hereto and made a part hereof.

2 Section 3. This resolution shall take effect immediately upon adoption.

3 4 PASSED and ADOPTED this / day of Oat*, 2009.

5 SOUTH FLORIDA WATER MANAGEMENT DISTRICT, BY 6 ITS GOVERNING BOARD 7

8 By:

9 Chairman 10 ATTEST:

11 12 13 Assistant ecretary 14 Approved as to form:

15 16 17 Office of Counsel 18

FIFTH SUPPLEMENTAL AGREEMENT BETWEEN THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT AND FLORIDA POWER & LIGHT COMPANY

, _LTHIS AGREEMENT is made and entered into this IC day of Octo ber , 2009, by and between FLORIDA POWER & LIGHT COMPANY

("FPL") and SOUTH FLORIDA WATER MANAGEMENT DISTRICT ("DISTRICT")

(and collectively referred to as "the Parties").

WITNESSETH WHEREAS, FPL and the CENTRAL AND SOUTHERN FLORIDA FLOOD CONTROL DISTRICT, (the "CSFFCD"), predecessor to the DISTRICT, entered into an agreement dated February 2, 1972, hereinafter referred to as "Original Agreement", governing rights and obligations of the Parties concerning the construction, operation and monitoring of the cooling canal system for FPL's power generating plant at Turkey Point in Miami-Dade County, Florida; and WHEREAS, the Original Agreement has been supplemented and amended on four separate occasions; the First Supplemental Agreement having been executed on October 21, 1974; the Second Supplemental Agreement having been executed on August 14, 1975; the Third Supplemental Agreement having been executed on September 10, 1976; and the Fourth Supplemental Agreement having been executed on July 15, 1983 (the "1983 Agreement") and the Original Agreement together with the four Supplemental Agreements are hereinafter collectively referred to as the "Prior Agreements"; and WHEREAS, the 1983 Agreement superseded the previous agreements. The 1983 Agreement provides that the purpose of the interceptor ditch system, which is part of the overall cooling canal system as depicted on the map attached hereto as Exhibit "A", made a part hereof, and located between the most westward cooling canal and Levee 31 E, is to restrict movement of saline water from the cooling canal system westward of Levee 31E adjacent to the cooling canal system to those amounts which would occur without the existence of the cooling canal system; and WHEREAS, the "cooling canal system," as referred to in this Agreement, is also referred to in Prior Agreements and related documents as the "cooling water system" and "cooling system;" and

5. WHEREAS, under the Prior Agreements, including the 1983 Agreement, FPL Page 1 of 11

has had continuing obligations to monitor for impacts of the cooling canal system on the water resources of the DISTRICT in general and on the DISTRICT'S facilities and operations in particular and to implement new operating criteria and/or engineering measures if the objectives of the 1983 Agreement are not being met.

WHEREAS, under the 1983 Agreement, those monitoring obligations include determining whether saline water has moved westward of Levee 31 E; and WHEREAS, as reasonable assurances for the DISTRICT's recommendation of approval of FPL's 2008 Uprate of Turkey Point Nuclear Units 3 and 4 ("Uprate Project"), FPL submitted information concluding that its operation of the interceptor ditch prevents seepage from the cooling canal system from moving westward of Levee 31 E thereby maintaining fresh or potable water west of the interceptor ditch (FPL Turkey Point Units 3 and 4 Uprate Application, 2008, section 2.3.4.1); and WHEREAS, based on FPL's assurances in the 2008 Uprate Certification application, the DISTRICT recommended approval of the Uprate Project conditioned on imposition of the consolidated three agency Condition of Certification X in the Power Plant Site Certification for the FPL Turkey Point Plant Units 3 and 4 Nuclear Power Plant Unit Combined Cycle Plant # PA 03-45 ("Certification"), requiring FPL to execute a SFWMD approved Fifth Supplemental Turkey Point Agreement ("Fifth Supplemental Agreement" or "Agreement") and to revise FPL's monitoring obligations for incorporation into the Agreement in a revised monitoring plan; and WHEREAS, the DISTRICT'S evaluation of recent monitoring data indicates that the interceptor ditch may not be effective in restricting the movement of saline water westward from the cooling canal system; and WHEREAS, as a necessary first step in evaluating existing conditions and, if necessary, identifying potential solutions to abate, mitigate, or remediate the movement of saline water and other water quality and ecological impacts from the cooling canal system, a full delineation of any historical and current ecologic, surface water and groundwater impacts, including, but not limited to, delineation of impacts westward of the Levee 31 E and eastward of Turkey Point into Biscayne Bay, from the operation of the cooling canal system since 1972, as well as potential for future impacts of the cooling canal system, is needed; and WHEREAS, FPL, the DISTRICT, Florida Department of Environmental Protection ("DEP"), and Miami-Dade County Department of Environmental Resource Management ("DERM") developed a revised monitoring plan, the Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan (the "2009 Plan"). The 2009 Plan is attached hereto as Exhibit "B" and made a part hereof; and

12. WHEREAS, the 2009 Plan identifies monitoring for the purpose of delineating current ecologic, surface water and groundwater impacts, from the operation of the cooling canal system on the water resources of the DISTRICT in general and the Page 2 of 11

facilities and operations of the DISTRICT, including, but not limited to, delineation of impacts westward of the Levee 31 E and eastward of Turkey Point into Biscayne Bay, and to assess whether mitigation, abatement, and other remedial measures would be necessary; and NOW THEREFORE, for good and valuable consideration as set forth herein, the Parties hereto agree as follows:

RECITALS and EFFECTIVE DATE OF THIS AGREEMENT The above recitals are true and correct and incorporated herein as a material and integral part of this Agreement. The Effective Date of this Agreement shall be the last date the Agreement is signed by the Parties.

OBLIGATIONS OF THE PARTIES (A) INTERCEPTOR DITCH SYSTEM OPERATION FPL shall operate the interceptor ditch system to restrict movement of saline water from the cooling water system westward of Levee 31 E adjacent to the cooling canal system to those amounts which would occur without the existence of the cooling canal system.

The operating criteria and procedures for the interceptor ditch system have been established by FPL in the 1983 Agreement as the manual designated "THE THIRD REVISED FLORIDA POWER & LIGHT, COMPANY, TURKEY POINT, FLORIDA, INTERCEPTOR DITCH OPERATION PROCEDURES" (Interceptor Ditch Operation Procedures). These criteria and procedures are attached hereto as Exhibit "C" and made a part hereof. The Parties shall revise these procedures within six (6) months from the effective date of this Agreement.

FPL shall operate the interceptor ditch in accordance with the Interceptor Ditch Operation Procedures subject to the provisions of Paragraph II(D).,

herein, which may require revision of such operations.

Revisions to the Interceptor Ditch Operation Procedures as may be proposed by FPL and agreed to by the Executive Director of the District or his/her designee may be accomplished by letter, for incorporation into Exhibit C without having to amend this Agreement.

5. FPL shall maintain pump operation logs in a mutually acceptable form for each interceptor ditch pumping installation and electronically transmit such pump Page 3 of 11

operation logs to the DISTRICT in the manner set forth in the Interceptor Ditch Operation Procedures and shall continue maintenance and transmittal of such logs for the duration of the operation of the Interceptor Ditch System.

6. Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(B) WATER TRANSFER FACILITIES FPL has accepted on its lands east of levee 31 E, and is responsible for the conveyance of all excess surface waters from the drainage basin of Canal 106 and 107, as shown on attached Exhibit "D", made a part hereof, which can be delivered by Structure 20 ("S-20") regardless of time and duration of discharge and quality. For reference, the C-106 canal was originally envisioned to be part of the Central and Southern Florida system, but has since been deauthorized and as a consequence, not made part of this Agreement. C-106 notwithstanding, FPL shall, at its expense, operate and maintain the drainage system from S-20 seaward to the intersection with the Seadade Canal and must maintain the discharge capacity east of the S-20.

Operation of the water transfer facilities shall be in accordance with instruction given to FPL by the DISTRICT'S Director of Field Services or his designated representative. FPL shall designate an official or employee of FPL who will be responsible for the receipt of said operating instructions and for carrying them out '

Within three months of execution of this Agreement FPL and the DISTRICT's Operations and Maintenance staff shall meet to identify required actions for maintaining that portion of the C-107 canal east of the L-31 E and downstream of S-20. FPL shall comply with such requirements, including providing a maintenance plan documenting required actions, in a timely manner.

Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(C) MONITORING PROVISIONS FPL shall commence implementing the 2009 Plan on the Effective Date of this Agreement and shall implement the 2009 Plan in accordance with its terms.

FPL shall continue the monitoring and reporting in accordance with the 2009 Plan until the DISTRICT provides written notification to FPL that monitoring can be terminated.

The Executive Director of the DISTRICT or his/her designee may Page 4 of 11

require revisions to the 2009 Plan, including but not limited to, additional or revised monitoring parameters or locations and a fully coupled three-dimensional ("3D")

surface and groundwater density dependent model or the Interceptor Ditch Operation Procedures. Any such revisions may be accomplished by letter for incorporation into the 2009 Plan without the need to amend this Agreement.

FPL shall collect and submit the data as provided in the 2009 Plan.

Raw data shall be provided to the DISTRICT at the time it is received by FPL. The Parties recognize that quality control and quality assurance (QA/QC) procedures will be conducted by FPL on the laboratory data after its receipt by the DISTRICT and that revisions and re-submittal of data to the DISTRICT may be necessary based on such evaluations. FPL shall retain all data electronically for the duration of the plant's operation and shall review and analyze the data so collected consistent with the objectives of this Agreement. Raw data is defined as data, either electronic or hard copy, that is received from a sensor or as laboratory results, that has not gone through any analysis or evaluation for (QA/QC)or other purposes.

FPL shall submit to the DISTRICT all reports required by the 2009 Plan and the Interceptor Ditch Operation Procedures (hereinafter "Reports") in a timely manner as specified in the 2009 Plan. By August 31 of each year, FPL shall submit an annual report evaluating the preceding year's events in terms of historic trends (Annual Report). The Annual Report shall include the information called for in the 2009 Plan. The Annual Report shall also contain all associated raw data in an electronic format consistent with existing District software and consistent with Paragraph II(C)3, herein. FPL shall electronically transmit the Annual Report and associated raw data in the form and manner specified in the 2009 Plan and the Interceptor Ditch Operation Procedures, as applicable.

All data collected by FPL or its representatives under either the Interceptor Ditch Operation Procedures or the 2009 Plan shall be maintained, archived, and presented in a web based application, as set forth in the 2009 Plan. As technology changes or improves, the DISTRICT may require revisions to the manner and format that FPL is required to submit and present its reports, summaries, and/or data. Upon written notification by the DISTRICT that the reporting manner and/or format needs to be changed to meet current technology improvements or changes, FPL shall implement those changes within sixty (60) days, or upon a mutually agreed upon timeframe, from receipt of the notification or by the next reporting period, whichever occurs first.

Within ninety (90) days after the DISTRICT's receipt of each Annual Report or Reports, as referenced in Paragraph II (C)(4), the DISTRICT may send a written request to FPL that FPL address concerns, questions, or omissions in the Annual Report or Reports that are reasonably related to the Annual Report or Reports. Within ninety (90) days following FPL's receipt of the request. FPL shall Page 5 of 11

provide the DISTRICT with its response(s) to each issue raised or additional information as requested. FPL's response(s) shall be required to continue to the satisfaction of the DISTRICT.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a DISTRICT request, FPL shall allow the DISTRICT to enter the Turkey Point property and/or access to FPL owned or maintained monitoring wells and stations to sample the cooling canal system and surface or ground water from all stations and monitoring wells utilized pursuant to the 2009 Plan. The DISTRICT and FPL shall coordinate the timing and location of sampling to account for planned or unplanned plant outages or emergencies and to protect the public health and safety. The DISTRICT agrees to abide by standard FPL health and safety precautions while on the Turkey Point property.

Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(D) MITIGATION, ABATEMENT, AND OTHER REMEDIAL MEASURES If the DISTRICT determines that data acquired under the 2009 Plan or other sources is insufficient to evaluate impacts of the cooling canal system, the 2009 Plan or the Interceptor Ditch Operation Procedures shall be revised, as approved by the DISTRICT, pursuant to Paragraph II (C)2.

If the DISTRICT, in its sole discretion, determines that the data from the 2009 Plan or from any other source: (i) indicates that the interceptor ditch is not effective in restricting movement of the saline water westward of Levee 31E in a manner that is consistent with the objective articulated above in Paragraph II(A)1; (ii) indicates harm or potential harm to the water resources of the DISTRICT in general or the DISTRICT'S facilities and operations in particular, including ecological resources; (iii) indicates the cooling canal system water is impacting water quality under Chapter 373, Florida Statutes; or (iv) indicates impacts inconsistent with the goals and objectives of the CERP Biscayne Bay Coastal Wetlands project, then the Executive Director or his/her designee shall notify FPL in writing of such determination.

3. Upon_receipt of the DISTRICT notification, FPL shall immediately begin consultation with the DISTRICT to identify measures to mitigate, abate or remediate impacts from the cooling canal system and then shall promptly implement those measures approved by the District. Measures may include revising the Interceptor Ditch Operation Procedures or other measures, including timelines for implementing such measures, under Paragraph II (D)5 to abate, mitigate or remediate identified impacts. Such measures and timelines for implementation shall be subject to DISTRICT approval.

Page 6 of 11

If the DISTRICT and FPL cannot timely agree on feasible engineering and/or hydrologic solutions to abate, mitigate or remediate the impacts identified under Paragraph II (D)2, above, then the Executive Director of the DISTRICT or his/her designee shall notify FPL in writing that the Parties have reached an impasse.

Such determination of an impasse shall be made at the sole discretion of the DISTRICT. The DISTRICT may then, in its sole discretion, require FPL to implement specified mitigation, abatement and remediation measures, within DISTRICT identified timeframes.

Measures to mitigate, abate, or remediate impacts identified under Paragraph II (D) 2, must be in writing and may include, but are not necessarily limited to:

revisions to the cooling canal system/interceptor ditch operating criteria; reasonable alterations in the design of the interceptor ditch system; alterations to the cooling canal system; any other feasible engineering and/or hydrologic measures regarding the cooling canal system; any other feasible engineering and/or hydrologic measures to mitigate for the cooling canal system's impacts to the region's water supply or remediation thereof; and/or a District approved fully coupled 3D surface and groundwater density dependent flow model incorporating FPL operational components to evaluate the best alternatives for abatement, mitigation or remediation.

If the District notifies FPL to implement any alterations as outlined in paragraphs (a) through (f) above, any such alterations shall not impair the reasonable operations of the existing power plant.

Consultation and implementation of DISTRICT approved measures, pursuant to Paragraph II (D), shall be undertaken and implemented within the specified time frames in the written notification from the DISTRICT.

Nothing contained in this Agreement shall limit the DISTRICT from availing itself of all other rights and remedies it may now or hereafter have to achieve the objective of Paragraph II (A)1 and remedy the impacts identified under Paragraph II (D). Further, the Power Plant Site Certification for the FPL Turkey Point Plant Units 3 and 4 Nuclear Power Plant and Unit 5 Combined Cycle Plant # PA 03-45, issued under the Power Plant Siting Act, Chapter 403, Florida Statutes, does not limit, alleviate, or modify the rights and obligations of the Parties under Chapter 373, Florida Statutes, or this Agreement.

Page 7 of 11

8. Under this Section, the Parties shall have all rights identified under Paragraph II(E)7.

(E) GENERAL PROVISIONS This Agreement supersedes and replaces the Prior Agreements.

This Agreement shall be binding on the Parties and, subject to the approval of the DISTRICT which may not be unreasonably withheld, their assigns and successors.

Should any unusual event occur or should FPL contemplate any substantive physical, mechanical, structural or operational changes to be made to the cooling canal system, then FPL shall promptly notify the DISTRICT and, if the DISTRICT shall so request, a meeting of the representatives of both FPL and the DISTRICT, shall be convened at the earliest mutually convenient time to review and analyze such unusual occurrences or such contemplated substantive physical, mechanical, structural or operational changes and to determine by mutual agreement what action shall be taken in relation thereto.

This Agreement shall remain in effect until terminated by the written agreement of the Parties.

FPL shall construct, maintain and operate all monitoring facilities and other facilities required by this Agreement, including those required by the 2009 Plan, in accordance with applicable manufacturer requirements and as otherwise necessary to provide timely, reliable and accurate data. FPL shall bear all its costs associated with its obligations under this Agreement including but not limited to the construction, operation, maintenance, monitoring, replacement, alteration, modification, or relocation of any and all existing or future facilities required under this Agreement.

No delay or failure by either Party to exercise any right under this Agreement, and no partial or single exercise of that right, shall constitute a waiver of that or any other right.

7. (a) This Agreement shall be governed by and construed in accordance with the laws of the State of Florida and of the United States of America and the rules and regulations promulgated under the authority thereof. In the event it is necessary for either Party to initiate legal action regarding this Agreement, venue may be in the Fifteenth Judicial Circuit or an administrative tribunal under Chapter 120, as appropriate, for claims under state law and in the United States District Court for the Southern District of Florida for any claims which are subject to jurisdiction of federal law and the federal Court.

Page 8 of 11

Consistent with subparagraph II (E) 7(a.), FPL maintains all rights they may have to request a proceeding under Chapter 120, Florida Statutes, to challenge any proposed or final agency action taken by the DISTRICT that affects FPL's substantial interests under Sections II (A), (B), (C), and (D) of this Agreement, including the right to petition for an administrative hearing. This specifically includes the right of FPL to file a petition requesting a formal or informal administrative hearing pursuant to Section 120.569 and 120.57, Florida Statutes, objecting to the District's agency action under Section II (D). This Paragraph does not create, modify or expand FPL's rights provided under Chapter 120, Florida Statutes. Nothing in this Agreement is intended to expand, or limit, the jurisdiction of the District. The District shall not act arbitrarily or capriciously and FPL shall not cause undue delay in implementing its obligations under this Agreement.

FPL shall indemnify, save and hold the DISTRICT and its directors, employees, and contractors (the "Indemnified Parties"), harmless and will defend against any and all claims, damages, costs, expenses, and liability arising from (1) the performance by FPL or its contractors, agents, or representatives of FPL's obligations under this Agreement, or (2) the construction, operation, maintenance, replacement, alteration, modification, or relocation of any existing or future interceptor ditch, monitoring facility, water transfer facility, or abatement, remediation or mitigation made necessary by the cooling canal system or required under this Agreement. The remedy in the preceding sentence is not intended to be an exclusive and does not preclude the Indemnified Parties' exercise of any other rights or remedies available under this Agreement or which may now or subsequently exist in law or at equity. If FPL fails to perform in accordance with the terms and conditions of this Agreement, then the DISTRICT shall have the right to seek specific performance and/or an action for damages based on the reasonable cost that would be incurred by the DISTRICT, including administrative, supervisory, and staff costs, to require implementation of the mitigation, abatement, and remedial measures identified in Paragraph II (D).

In the event any provision of this Agreement is held or adjudged to be invalid or illegal or unenforceable by any court of competent jurisdiction: (1) such portion or provision shall be deemed separate and independent; (2) the Parties shall negotiate in good faith to restore, insofar as practicable, the benefits to each Party that were affected by such ruling; and (3) the remainder of this Agreement shall remain in full force and effect.

This Agreement may be executed in any number of counterparts, all of which shall together constitute one and the same instrument. A facsimile or electronic signature shall be binding.

10. This Agreement states the entire understanding and Agreement between the Parties with respect to the subject matter contained herein and supersedes any and all prior written or oral representations, statements, negotiations, or agreements.

Page 9 of 11

Unless expressly stated herein to the contrary, nothing in this Agreement, whether express or implied, is intended to confer any rights or remedies under or by reason of this Agreement on any person other than the Parties hereto.

Nothing in this Agreement is intended to relieve or discharge the obligation or liability of any third persons to any Party, nor shall any provision give any persons any right of subrogation or action over or against any Party.

The Parties shall comply with all applicable laws. Each Party shall be solely responsible for the payment of any fines or penalties levied as a result of such Party's non-compliance with any applicable legal requirement, except to the extent caused or contributed by the other Party.

In the event a dispute arises which cannot be resolved by the Parties, the Parties may agree to submit to nonbinding mediation. The mediator or mediators shall be impartial, shall be selected by the Parties, and the cost of the mediation shall be borne equally by the Parties. The mediation process shall be confidential to the extent permitted by law. Either Party may pursue its remedies available under this Agreement.

The Parties agree that time is of the essence in the performance of the obligations under this Agreement.

This Agreement shall not be construed against any Party regardless of who is responsible for its preparation. The Parties acknowledge that each contributed to, and is equally responsible for its preparation and the Agreement shall be interpreted without regard to any presumption or other rule requiring interpretation against one party or the other.

FPL and the District have the reciprocal and continuing obligation to notify the other of any personnel changes of its designated official or employee who will maintain monitoring installations and collect monitoring data and records. The following individuals shall serve as the designated points of contact for all issues and correspondence between the Parties arising in conjunction with this Agreement and by written notice to the other Party:

DISTRICT REPRESENTATIVE: FPL REPRESENTATIVE:

Title:

Assistant Deputy Executive Director

Title:

Dire_c:he-Erruitronmt;V,I\ liCsASInj South Florida Water Management District Florida Power & Light Company 3301 Gun Club Road 700 Universe Boulevard West Palm Beach, FL 33406 Juno Beach, FL 33408-0420 (561) 686-8800 (561) 611 11i Page 10 of 11

17. Each Party hereto represents and warrants that the execution of this Agreement has been duly authorized by it and that this Agreement, upon execution by the other Party, is binding on and enforceable against such Party in accordance with the terms of this Agreement. No consent to such execution is required from any person, judicial or administrative body, governmental authority or any other person other than any such consent which already has been unconditionally given. Each Party hereto represents and warrants that there is no pending litigation or, to the best of their knowledge, threatened litigation that would affect its obligations to perform hereunder.

IN WITNESS WHEREOF, the Parties hereto have set their hands and seals in duplicate originals, the day and year first above written.

FLORIDA POWER & LIGHT COMPANY, a Florida C r or tion By: (Sign)

Name: A/rcfre4 --0<f(Print)

Title:

t Date: Z/L 14 --e.10 9 SOUTH FLORIDA WATER MANAGEMENT BY ITS GOVERNING BOARD, a public corporation of the S to of Florida By: (2411 (Sign)

Name: (7i4 Pot At.),L) (Print)

Title:

77VE TZYP Date:

SFWMD Office of Counsel Approved: B y:, Ad Ka,/

Date:

Page 11 of 11

s SOUTH FLORIDA WATER MANAGEMENT DISTRICT FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan EXHIBIT B South Florida Water Management District Florida Department of Environmental Protection Miami-Dade County Department of Environmental Resource Management October 14, 2009

Table of Contents List of Tables ............................................................................................ iii List of Figures ........................................................................................... iii Acronyms and Abbreviations........................................................................... v 1: Introduction ........................................................................................... 1 1.1 Adaptive Monitoring Approach and Plan Modifications ................................. 5 2: Monitoring Plan ....................................................................................... 7 2.1 Monitoring Design Strategy .................................................................. 7 2.1.1 Landward Delineation of Groundwater Plume .................................... 7 2.1.2 Seaward Delineation of the Groundwater Plume ................................. 8 2.2 Parameter Suite ............................................................................... 8 2.2.1 Tracer Suite ............................................................................ 8 2.3 Groundwater Monitoring ................................................................... 11 2.3.1 Groundwater Monitoring Well Locations ......................................... 11 2.3.2 Groundwater Monitoring Well Installation ....................................... 13 2.3.3 Biscayne Bay Geophysical Survey ................................................. 15 2.3.4 Groundwater Sampling.............................................................. 16 2.4 CCS Monitoring .............................................................................. 17 2.4.1 Sediment and Porewater Sampling ............................................... 20 2.5 Surface Water Monitoring ................................................................. 20 2.5.1 Surface Water Locations............................................................ 20 2.5.2 Surface Water Data Collection .................................................... 22 2.6 Water Budget and Mass Balance Calculations .......................................... 23 2.6.1 Bathymetric Survey.................................................................. 23 2.6.2 Water Budget Parameters and Monitoring ....................................... 24 2.6.3 Water Budget Calculations ......................................................... 25 2.7 Interceptor Ditch Water Monitoring...................................................... 27 2.8 Ecological Monitoring....................................................................... 29 2.8.1 Overview and Strategy .............................................................. 29 2.8.2 Design ................................................................................. 30 2.8.3 Initial Ecological Condition Characterization ................................... 30 2.8.4 Broad Scale Vegetation Characterization ........................................ 32 2.8.5 Wetland Transect Locations ....................................................... 32 2.8.6 Freshwater Wetland Transect Assessments ..................................... 34 2.8.7 Saline Wetland Transect Assessment ............................................. 36 2.8.8 Biscayne Bay and Card Sound ...................................................... 37 3: Field Notification, Data Collection and Reporting ............................................ 41 3.3 Quality Assurance/Quality Control Plan ................................................. 41 3.3.1 Field Sampling and Analysis Event Notifications ................................ 42 3.3.2 Meetings............................................................................... 42 3.4 Data Collection and Reporting ............................................................ 42 FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l i

3.5 Data Collection .............................................................................. 44 3.5.1 Automated Sample Collection ..................................................... 44 3.5.2 Manual Sample Collection .......................................................... 44 3.6 Data Reporting .............................................................................. 44 3.6.1 Web Database ........................................................................ 44 3.6.2 Automated Data Reporting ......................................................... 45 3.6.3 Manual Data Reporting .............................................................. 46 3.6.4 Geology and Hydrogeology Report ................................................ 46 3.6.5 Initial Ecological Condition Characterization Report .......................... 47 3.6.6 Semiannual and Annual Comprehensive Monitoring Reports.................. 48 3.6.7 Comprehensive Pre-Uprate Report ............................................... 49 4: Schedule ............................................................................................ 51 References Cited ...................................................................................... 53 Appendix A: FDEPs Conditions of Certification IX and X related to the FPL Turkey Point Power Plant Uprate ................................................................... A-1 Appendix B: Near Shore Sonde Deployment Methods ........................................... B-1 Appendix C: Survey Parameters Collected during Groundwater and Surface Water Investigations .......................................................................... C-1 Appendix D: Special Requirements for an Electromagnetic Induction Well................. D-1 Appendix E: Tritium Sample Collection and Analysis Protocols ............................... E-1 ii l Table of Contents

List of Tables Table 2-1. Required parameters for groundwater/surface water characterization ......... 10 Table 2-2. Rationale for the groundwater monitoring locations. All locations are approximate until field verification ................................................... 13 Table 2-3. Borehole logging methods, descriptions of the properties measured, and types of data obtained .................................................................. 14 Table 2-4. Rationale for the CCS monitoring locations .......................................... 19 Table 2-5. Rationale for the surface water monitoring locations .............................. 22 Table 2-6. Ecologic monitoring: transect sampling. .............................................. 39 Table 2-7. Ecologic monitoring: initial characterization and survey sampling ............... 40 Table 3-1. Sampling frequency for field and laboratory parameters .......................... 43 Table 3-2. Proposed automated time-series data collection from surface and groundwater stations .................................................................... 44 List of Figures Figure 1-1. Turkey Point and surrounding area ...................................................... 4 Figure 2-1. Groundwater well cluster locations ................................................... 12 Figure 2-2. CCS monitoring stations ................................................................. 18 Figure 2-3. Surface water monitoring sites ......................................................... 21 Figure 2-4. CCS flowmeter locations................................................................ 26 Figure 2-5. Proposed interceptor ditch monitoring sites ......................................... 28 Figure 2-6. Ecological monitoring transects adjacent to the CCS............................... 33 Figure 2-7. Example of a proposed sampling design for ecological monitoring along the transects ................................................................................... 36 Figure E-1 Rainfall collection stations ............................................................. E-4 FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l iii

iv l List of Tables and Figures Acronyms and Abbreviations ALKA Alkalinity APT aquifer performance test BBAP Biscayne Bay Aquatic Preserve BBSW Biscayne Bay Surface Water BNP Biscayne National Park

+-

B Boron ion Ba Barium BACI Before-After-Control-Impact Br- Bromide ion bsl below sea level C Carbon

°C degrees Celsius 12 C Carbon isotope 13 C Carbon isotope Ca2+ Calcium ion CaCO3 Calcium carbonate Cl- Chloride ion CCS cooling canal system CDMP Comprehensive Development Master Plan CERP Comprehensive Everglades Restoration Plan cm Centimeter COC Conditions of Certification CRP continuous resistivity profiling D Deuterium DERM Miami-Dade County Department of Environmental Resource Management DIC dissolved inorganic carbon DO dissolved oxygen DOAH Department of Administrative Hearings FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l v

DOC dissolved organic carbon DOH Department of Health DOI U.S. Department of Interior DTS distributed temperature sensing EPA U.S. Environmental Protection Agency ESRI Environmental Systems Research Institute F- Fluoride ion F.A.C. Florida Administrative Code FDEP Florida Department of Environmental Protection FKAA Florida Keys Aqueduct Authority FPL Florida Power and Light Company fpd feet per day FWS U.S. Fish and Wildlife Service GIS Geographic Information System H Hydrogen 3

H Tritium 2

H Deuterium HCO3- Bicarbonate ion ID interceptor ditch

+

K Potassium ion km kilometer LSC liquid scintillation counting M meters m micrometer S/cm microsiemens/centimeter MDL maximum developable limit Mg2+ Magnesium cation mg/L milligrams per liter N Nitrogen Na Sodium NAD North American Datum NAVD North American Vertical Datum of 1988 NELAC National Environmental Laboratory Accreditation Conference vi l Acronyms and Abbreviations

NH3 Ammonia NH4 Ammonium NGVD National Geodetic Vertical Datum of 1929 NOAA National Oceanic & Atmospheric Administration NOx Nitrate+Nitrite NPS National Park Service NRC Nuclear Regulatory Commission NSF National Science Foundation O Oxygen 16 O Oxygen isotope 18 O Oxygen isotope ORP oxidation-reduction potential P Phosphorus pCi/L Picocuries per liter pH potential of hydrogen ppm parts per million PSS78 Practical Salinity Scale of 1978 psu practical salinity units PVC Polyvinyl chloride QA/QC Quality Assurance/Quality Control RECOVER Restoration Coordination and Verification RTK Real-time Kinematic 13C stable carbon isotope 15N stable nitrogen isotope SAV submersed aquatic vegetation SFWMD South Florida Water Management District SiO4 Silicate SO4 2- Sulfate anion Spp species (plural)

SPT standard penetration test 2+

Sr Strontium SR86 Strontium isotope SR87 Strontium isotope FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l vii

(SRP)c soluble reactive phosphorus TDS total dissolved solids TOC total organic carbon (TP)c total phosphorus TKN Total Kjeldahl nitrogen TPGW Turkey Point groundwater USACE U.S. Army Corps of Engineers USGS U.S. Geological Survey viii l Acronyms and Abbreviations

1 Introduction This Monitoring Plan (Plan) has been developed pursuant to Conditions of Certification (COC) IX and X of the Power Plant Site Certification for the Florida Power & Light (FPL)

Turkey Point Units 3 and 4 Nuclear Power Plant Unit Combined Cycle Plant PA 03-45A2 (Uprate Certification). COC IX and X are attached hereto as Appendix A. In addition, this Plan identifies monitoring required under the Fifth Supplemental Agreement between the South Florida Water Management District and Florida Power and Light Company (Fifth Supplemental Agreement or 2009 Agreement). The Plan is incorporated into and made a part of the 2009 Agreement as Exhibit B.

This Plan, and any resultant actions by the Agencies and FPL, is being conducted in order to satisfy the objectives of the 1983 Agreement, the Fifth Supplemental Agreement, and the COCs.

The Plan incorporates contributions from the Florida Department of Environmental Protection (FDEP), the South Florida Water Management District (SFWMD), and Miami-Dade Countys Department of Environmental Resources Management (DERM),

(collectively, the Agencies), and FPL. The following Federal entities are contributing to the development and implementation of the Plan: Everglades National Park (ENP) and Biscayne National Park (BNP).

The Monitoring Plan shall provide information to determine the vertical and horizontal effects and extent of the cooling canal system (CCS) water on existing and projected surface and groundwater, and ecological conditions surrounding Turkey Point (see Figure 1-1). The CCS is hypersaline. There shall be a minimum of two years of monitoring of surface water, groundwater, and ecological conditions prior to the first of either Unit 3 or 4 becoming operational (defined as pre-Uprate). Monitoring shall be continuous from this pre-Uprate period throughout commencement of the Uprate (defined as post-Uprate when both Units 3 and 4 operational). Monitoring under the Plan shall continue pursuant to the 2009 Agreement and the Conditions of Certification. Prior to and following the commencement of the Uprate period, data shall be collected including monitoring for ground and surface water levels, specific conductance, temperature, CCS tracer suite constituents, tidal influences, preferential groundwater flow paths, surface and groundwater quality (including CCS constituents), rainfall, any other information necessary for the water budget, and ecological conditions.

During the pre-Uprate period, FPL shall exercise due diligence, as defined below, and due care to perform its obligations under the Plan in a timely manner. If a Force Majeure Event, FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 1

as defined below, or an unforeseen permitting delay, beyond FPLs control and FPL has pursued the permit with due diligence, as explained below, occurs causing a delay in any portion of this Plan, the Turkey Point 3 and 4 Uprate will not be delayed.

If FPL anticipates a delay in implementation of any part of this Plan due to a Force Majeure Event or an unforeseen permitting delay outside FPLs control and FPL has pursued the permit with due diligence, within fourteen days of becoming aware of such event, FPL shall notify the SFWMD in writing of the anticipated length and cause of the delay, demonstrate that such delays are due to a Force Majeure Event or outside FPLs control, and identify the probable impact on FPLs performance, the measures taken or to be taken to prevent or minimize the delay and the time table by which FPL intends to implement these measures.

Any portion of the Plan that is delayed shall not cause delays in any other unrelated portion of the Plan.

FPL shall exercise commercially reasonable due diligence to overcome the Force Majeure Event. To the extent it is able, FPL shall continue to perform under this Agreement and cause the suspension of its performance to be of no greater scope and no longer duration than the Force Majeure Event requires.

However, if FPL is not able to produce two years of monitoring data due to situations beyond its control despite FPLs exercise of due diligence and due care in the timely implementation of this plan, the Agencies shall reserve the right to evaluate the data collected to date and determine if it is sufficient to establish the pre-Uprate baseline condition.

When FPL is able to resume performance of its obligations under this Agreement, it shall immediately give SFWMD written notice to that effect and shall resume performance under this Agreement after the notice is delivered.

Force Majeure Event shall mean any event outside the control, and not the fault, of FPL that cannot be avoided or overcome by the exercise of due diligence, including but not necessarily limited to: an act of God, war, flood, lightning, fire, hurricane, tornado, explosion, civil disturbance, or the public enemy, terrorist act, military action, epidemic, work-to-rule action, go-slow or similar labor difficulty, each on an industry-wide, region-wide or nationwide basis; but does not include economic hardship, changes in market conditions, insufficiency of funds, or unavailability of equipment or supplies.

Due diligence in FPLs permitting applications means that: a) FPL submitted the permit application in sufficient time for the permitting agency to act on the application and for FPL to complete the project for which the permit is necessary in order to obtain a minimum of two years of pre-Uprate data for a sufficient baseline of data; b) FPL responded in a reasonable time to requests for information needed by the permitting agency to process the application or prepare any necessary environmental analysis; and c) FPL took practicable steps to ensure completion of the project as expeditiously as possible after issuance of the permit.

2 l Section 1: Introduction

FPL maintains all rights it may have under Chapter 120, Florida Statutes (F.S.). However, nothing in this Plan is intended to create, modify, or expand FPLs rights it may have under Chapter 120, F.S., or under Chapter 403, Part II, F.S. FPL maintains its right to request a proceeding under Chapter 120, Florida Statutes, to challenge any proposed or final agency action taken in implementing this monitoring plan that affects FPL's substantial interests.

This specifically includes the right of FPL to file a petition requesting a formal or informal administrative hearing pursuant to Section 120.569 and 120.57, Florida Statutes. The terms of the Plan do not limit any existing regulatory authority the individual Agencies have over FPL or its Turkey Point facility. The SFWMD and the FDEP have concurrent jurisdiction to determine impacts, harm or potential harm, require or allow Plan modifications, require or allow Plan termination, and require compliance as indicated in the Conditions for Certification or the Agreement.

FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 3

Figure 1-1. Turkey Point and surrounding area.

4 l Section 1: Introduction

1.1 ADAPTIVE MONITORING APPROACH AND PLAN MODIFICATIONS The development of this Plan was based on limited available hydrologic and ecological information. The intent of the adaptive monitoring approach is to streamline completion of the objectives related to the identification and monitoring through time of the CCS water tracers, state and county water quality constituents, water budget, and ecological effects. The adaptive monitoring approach includes the potential expansion or reduction of monitoring elements based on the findings of previous steps. Any party can propose enhancements or decreases in monitoring, however, such proposal by any party shall not be implemented without approval of the lead Agency (SFWMD).

Modification of the Plan may be proposed at any time either by the FDEP, SFWMD, DERM, or FPL. Any modification shall be approved/denied by FDEP or SFWMD, as applicable, after consultation with DERM. These procedures for Plan modification are in addition to any other regulatory enforcement authorities of the Agencies (FDEP, SFWMD, and DERM).

FPL shall implement Plan modifications within the timeframes established by the Agencies.

Plan modifications during the pre-Uprate monitoring period shall be implemented expeditiously in light of the limited monitoring timeframes before the Uprate is operational.

Minor field changes, such as movement/adjustment of monitoring stations or locations over short distances, due to logistical constraints or to optimize monitoring, may be initiated after Agency approval by telephone during Plan implementation. If the adjustment is deemed more significant, SFWMD may require a written request be made prior to the modification and technical information be provided before the adjustment is made. The SFWMD shall make decisions promptly to avoid delays.

FPL Turkey Point Power Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 5

6 l Section 1: Introduction 2

Monitoring Plan 2.1 MONITORING DESIGN STRATEGY The Plan consists of an integrated system of surface, groundwater, porewater, and ecologic sampling. New monitoring wells shall be installed and a hydrogeologic investigation and surface and groundwater monitoring shall be conducted. All stage recorders and groundwater wells (top of casing) shall be referenced as described in Appendix C to allow comparison of results across the landscape and at depth. Where available or possible, data collected by other entities will be used to further enhance the understanding of baseline conditions and help determine impacts or potential impacts. Ecological monitoring shall be initiated in areas of presumed stress, along transects, and for spatial characterization.

The approach for monitoring of existing conditions at the FPL Turkey Point Power Plant (plant) and adjacent environments is to determine the relationship of CCS water and: a) the underlying groundwater in all directions; b) the freshwater wetlands and nearby canals, c) the adjacent saltwater wetlands; d) the eastern mangrove shoreline; e) the Biscayne Bay littoral zone; and f) within Biscayne Bay and Card Sound. The tracking of the CCS water movement is proposed using a combination of automated monitoring, along with manual data collection of water constituents and tracers of CCS water (discussed in Section 2.4).

The exact monitoring locations, as depicted in maps in the subsequent sections, may need to be adjusted based on access, environmental considerations (i.e., wetland and estuarine impacts), or other findings that warrant placement in alternative locations. The final locations of all sampling sites shall be approved by the Agencies prior to placement.

The monitoring area shall include the CCS and surrounding areas, as shown in Figure 1-1.

Portions of the Florida Keys National Marine Sanctuary, Biscayne Bay Aquatic Preserve (BBAP), Biscayne National Park (BNP), and the Model Land Basin are also included.

2.1.1 Landward Delineation of Groundwater Plume For groundwater beneath land (defined as being landward of the mean high water line), the vertical (to the base of the Biscayne aquifer) and horizontal extent of the plume will be determined by State and County groundwater quality standards and the CCS tracer suite, as determined by the Agencies.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 7

The plume will be delineated starting from the CCS and continue landward if State or County groundwater quality standards are exceeded and one or more of the tracer suite values are above background, unless the Agencies agree expanded landward delineation is not necessary.

However, if at a given location, one or more of the tracer suite values are above background, but groundwater quality concentrations are lower than State and County standards, but projected to increase above those standards, continued monitoring will be required and potentially expanded to determine the zone of plume movement, as determined by the Agencies.

2.1.2 Seaward Delineation of the Groundwater Plume For the purpose of groundwater plume delineation within and beneath Biscayne Bay and Card Sound (seaward of the mean high water line), monitoring will be conducted as described in the Plan. Criteria for seaward delineation shall be identified by the Agencies based on an evaluation of all available data, including initial monitoring conducted for a minimum of one year.

2.2 PARAMETER SUITE Required parameters are listed in Table 2-1 and described in the following sections of this monitoring plan: Sections 2.3.4 Groundwater Sampling; 2.4 CCS Monitoring; 2.5.2 Surface Water Collection; 2.6 Water Budget and Mass Balance Calculations; and Section 2.8 Ecological Monitoring.

2.2.1 Tracer Suite For the purpose of identifying the vertical and horizontal extent of the CCS plume, the delineation methodology shall be based, in part, on the finding of tracer values above those which would not be present in the environment, except for a contribution of water from the CCS. The tracer shall be used to identify water originating from the CCS and differentiate it from water from other sources. A subset of the analytical parameters is collected for purposes of identification of a tracer suite. The final tracer suite shall be identified by the Agencies based on all available data, including initial monitoring data collected during a minimum of one year. Samples shall be collected quarterly at each surface and groundwater monitoring station.

At the end of the initial monitoring period, which is a minimum of one year, FPL shall submit a report to present its findings (to include raw data) regarding potential tracer monitoring parameters (tracer suite) to be used in future tracer monitoring in accordance with the reporting requirements, as specified in Section 3. The Agencies shall identify the tracer suite, applicable detection levels, background levels, and any recommended changes (i.e., increases/decreases) in sampling sites and sampling frequency. If at the end of the first 8 l Section 2: Proposed Monitoring Plan

year of monitoring the Agencies determine that additional tracer monitoring parameters are needed to better assess the adequacy of specific tracers, the Agencies may require additional monitoring.

These tracer monitoring parameters are separated into three different categories and include, but are not limited to:

1. Stable Isotopes: this group includes the oxygen isotopes of water (18O/16O),

hydrogen isotopes of water (D/H), strontium (Sr87/Sr86), and stable isotopes of carbon (13C/12C) in the dissolved inorganic carbon (DIC) in water.

2. Radioactive Isotopes: tritium (H3).

3. Ions: listed in Table 2-1, plus Barium (Ba) and Iron (Fe).

The FDEPs drinking water standard for concentrations of tritium in groundwater is 20,000 pCi/L. The Agencies and FPL recognize that the concentrations of tritium from the CCS water are expected to fall below the regulatory standard used to identify the potential for human health concerns. Accordingly it is mutually understood tritium is being monitored only as a potential tracer for identifying contributions of CCS water as a source. According to the FDEP, pursuant to Chapter 62-520 and 62-550, F.A.C., the presence of tritium below 20,000 pCi/L in water does not represent a public health and safety issue.

Sample collection and analytical methodologies for potential tracer suite monitoring parameters and interpretation of tritium results are presented in Appendix E.

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Table 2-1. Required parameters for groundwater/surface water characterization.

Field Parametersc Temperature (T) pH Specific Conductance (conductivity at 25°C) in Oxidation-Reduction Potential (ORP)

µS/cm Salinity using the Practical Salinity Scale of Dissolved Oxygen (DO) 1978 (PSS78)

Percent Oxygen Saturation Laboratory Parameters CCS tracer suite c Strontium (87Sr/86S)

Hydrogen (3H, 2H) [Tritium, Deuterium] d Carbon (13C,12C)

Oxygen (18O, 16O) Dissolved Inorganic Carbon (DIC)

Barium (Ba) Total Iron Ionsc: Nutrients:

Calcium (Ca2+) Ammonia (NH3)c - calculated as NH3 Sodium (Na+) Ammonium (NH4+) as Nc Magnesium (Mg2+) Nitrate+Nitrite (NOX) as Nc Potassium (K+) Total Kjeldahl Nitrogen (TKN)c Strontium (Sr2+) Total Nitrogen (TN)c - calculated Chloride (Cl-) Total Phosphorus (TP)c Bromide (Br-) Soluble Reactive Phosphorus (SRP)c Sulfate (SO42-) Silicatea Fluoride (F-)

Bicarbonate (HCO3-)

Boron (B+)

Alkalinity (ALKA) Alkalinity as CaCO3 Sulfides Total Dissolved Solids (TDS)b Other:

Gross Alphaa Trace Elementsb:

Arsenic Mercury Barium Manganese Beryllium Molybdenum Cadmium Nickel Chromium (Hexavalent Chromium) Selenium Copper Thallium Iron Vanadium Lead Zinc a

Surface water CCS only.

b Groundwater only.

c Both surface and groundwater.

d At this time, it is FPLs position that tritium is not a suitable tracer.

10 l Section 2: Proposed Monitoring Plan

2.3 GROUNDWATER MONITORING The purpose of groundwater monitoring is described in COC IX and X of the Uprate Appendix A and the 2009 Agreement.

2.3.1 Groundwater Monitoring Well Locations Fish and Stewart (1991) showed that the base of the Biscayne aquifer was approximately 106 feet below sea level (bsl) at the G-3321 well location, adjacent to the northwestern portion of the CCS and the L-31E Canal (Figure 2-1). The base of the Biscayne aquifer at G-3321 is shown within a few feet of the contact between overlying limestone with relatively high hydraulic conductivity [>1,000 feet per day (fpd)] and underlying sandstone with relatively low hydraulic conductivity (10 to 100 fpd) within the Tamiami Formation. The USGS is developing the hydrostratigraphic framework of the Biscayne aquifer system for Miami-Dade County (Cunningham et al 2004, 2006a, 2006b, 2008).

Based on input with the Agencies, a series of groundwater monitoring stations shall be installed. A total of 14 well clusters are included, as shown in Figure 2-1 and Table 2-2.

These well clusters are spatially distributed to facilitate plume monitoring and are generally aligned along transects to aid in determining concentration gradients on a sub-regional scale.

The exact installation locations may need to be adjusted based on site-specific conditions (e.g., access considerations, minimization of environmental impacts) or permitting constraints.

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Figure 2-1. Groundwater well cluster locations.

12 l Section 2: Proposed Monitoring Plan

Table 2-2. Rationale for the groundwater monitoring locations. All locations are approximate until field verification.

Location Rationale Groundwater stations will establish baseline conditions and delineate limits of the CCS plume. A cluster of three groundwater monitoring wells at each location will enable sampling from macroporous-permeable zones.

TPGW-1 Monitor west/northwest of L-31E TPGW-2 Monitor west of the south-central portion of the CCS TPGW-3 Monitor south of the CCS TPGW-4 Monitor westward of the CCS TPGW-5 Monitor westward of the CCS TPGW-6 Monitor northwest of the CCS TPGW-7 Monitor west of the CCS and northwest of TPGW-5. Nearest well cluster to Newton Wellfield.

TPGW-8 Monitor west of the CCS and northwest of TPGW-4 TPGW-9 Reference Well TPGW-10 Monitor offshore north of the entrance to the barge turning basin TPGW-11 Monitor offshore of the CCS in Biscayne Bay TPGW-12 Monitor north of the CCS TPGW-13 Site is located in the approximate center of the CCS to monitor below the source area of the hypersaline plume.

TPGW-14 Monitor offshore of the CCS in Biscayne Bay 2.3.2 Groundwater Monitoring Well Installation Each monitoring well cluster shall be completed with discrete screen intervals in the upper, middle, and lower portions of the Biscayne aquifer. No monitoring zone shall be placed below the Biscayne aquifer system and at least one monitoring zone shall include the base of the plume within the Biscayne aquifer system. To accomplish this task, a pilot hole shall be advanced at each cluster site to delineate to the base of the Biscayne aquifer and characterize the aquifers characteristics and water quality. FPL shall conduct detailed geological sampling in the pilot hole of each cluster. Geological sampling of each pilot hole shall include continuous split spoon samples using the standard penetration test (SPT), in accordance with ASTM standards, and/or core sample collection from surface to total depth. Core samples shall be collected when SPTs are refused. Detailed geological samples shall be correlated to the downhole borehole videos in the final geological report.

Well development shall be conducted on all pilot holes prior to optical borehole imaging and all monitoring wells until clear, sand-free water is obtained and field parameters stabilize in accordance with FDEP criteria.

Monitoring well screen intervals shall be site-specific and shall represent macroporous and relatively high-permeability zones of the upper, middle, and lower Biscayne aquifer based on the combined results from optical borehole imaging (oriented camera system),

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 13

electromagnetic induction, caliper, flow, specific conductance, temperature, gamma ray, full wave form sonic, and borehole logging of the deepest hole (Table 2-3). If hydrogeologic testing of the flow intervals is not conducted at the time of well construction, such testing and data shall be provided, as determined by the Agencies, to evaluate the hydraulic conductivity of each screened flow zone in conjunction with any future model efforts.

Agency representatives shall be allowed onsite to observe field activities and shall be provided copies of field generated data upon request. The SFWMD representative(s) will pre-approve well screen intervals in the field prior to well construction. FPL shall notify SFWMD representatives in writing at least 14 calendar days, or less if agreed to by the SFWMD, before initiating well construction. If the SFWMD is notified in a timely manner and determines that no SFWMD representative will be present, FPL may proceed with the subject well construction without the SFWMD attending.

In addition, the deepest well at each cluster shall be constructed to facilitate once a year induction logging across the entire vertical extent of the well. Based on initial induction log results, a subset of wells may be selected by the Agencies for semi-annual logging. This will enable the monitoring of conductivity changes within the Biscayne aquifer and potential migration of the plume, even in zones that are not screened. Once installed, the network of wells shall be horizontally and vertically surveyed to second order accuracy and referenced to both NGVD and NAVD (Appendix C). Appendix D presents well construction requirements, which will facilitate electromagnetic induction logging.

Table 2-3. Borehole logging methods, descriptions of the properties measured, and types of data obtained.

Type of Log Properties Measured Purpose Optical borehole Imaging of borehole Determines the 360-degree image of borehole imaging (OBI) and identifies borehole condition and macroporous zones. Provides an oriented optical image of the borehole that compensates for tool spinning.

Electromagnetic Formation and fluid Provides data on specific conductance within Induction conductivity fluid and formation around the borehole.

Caliper Borehole diameter Borehole diameter; determines presence of voids and cavities.

Flow Flow rate Identifies zones of groundwater flow within borehole.

Temperature Fluid temperature Determines temperature variations across depth within borehole.

Gamma Ray Rock sediment gamma Provides information on formation radiation characteristics, including rock types and changes in lithology.

Full Wave Form Lithology and porosity Provides information on presence and location Sonic of formation of potential preferential flow paths.

14 l Section 2: Proposed Monitoring Plan

A well construction spreadsheet supplied by the SFWMD shall be constructed and maintained. The spreadsheet shall include the following parameters: drilling method, geologic sampling method, drilling mud used, well installation date, latitude, longitude, state planar, muck (ground) elevation, ground surface elevation, measuring point at top of casing, depth from top of casing, depth at top of screen, screen length, well construction material, screen slot size, gravel pack at screen interval, elevation at top of well screen, elevation at bottom of well screen, centralizers used, project manager, and the source of well information.

Data collected during well installation, including geological sampling (i.e., coring or SPTs),

detailed lithologic logs, borehole geophysics, digital optical logs, initial induction logs, temperature and flowmeter logs, field water quality data, and well construction details shall be compiled and submitted to the Agencies within 60 days of completion of each well. In addition, a summary of well drilling procedures, geophysical logging procedures, and instrumentation used shall be provided. Based on wells installed from this monitoring effort and other subsurface geologic data, scaled geologic cross-sections, including macroporosity zone and geophysical log overlays, shall be generated and included in the report. This includes information from the induction logs that reveal zones of saline water. In addition, a plan view map showing the location of significant features shall be included. The information generated from this report will enable a better understanding of the movement of groundwater in the area and will provide the basis for interpretation of tracer and water quality monitoring.

2.3.3 Biscayne Bay Geophysical Survey Broad-scale estimates of specific conductance and temperature of waters potentially influenced by the CCS are needed to assess the spatial extent and magnitude of this influence (including the identification of potential groundwater upwelling zones) and provide information to improve the monitoring design within the adaptive protocols of this Plan.

Electromagnetic resistivity surveys can provide such broad-scale salinity estimates for both surface water and groundwater (Fitterman and Desczcz-Pan 2001; Swarzenski et al. 2006).

A boat-based electromagnetic resistivity survey shall be made over Biscayne Bay (south of the latitude of the Mowry Canal) and over Card Sound. The geophysical investigation shall be performed using a combination of continuous resistivity profiling (CRP) and distributed temperature sensing (DTS) investigation. GPS technology shall be used to establish horizontal control of the geophysical survey locations. Since water has different degrees of resistivity, a CRP survey can provide both horizontal and vertical insight of saline versus fresh versus hypersaline water. A DTS survey can provide a continuous profile of temperature over a large distance with a high degree of resolution. Its use is based on distinguishing temperature contrasts between groundwater, surface water, and potentially warmer CCS water. Relatively fine-scale tracks (less than 1 km apart) shall be made parallel from shoreline to 4 km east of the shoreline, from Card Sound Road to the Mowry Canal.

South of this area, the remaining area of Biscayne Bay and Card Sound shall be coarsely surveyed with at least three transects that cross these bays eastward to Key Largo, Old FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 15

Rhodes Key, and Elliott Key. An additional track shall be made long-shore of these Keys at the eastern boundary of Biscayne Bay and Card Sound, between the southern end of Card Sound and the latitude of the Mowry Canal. The CRP survey shall be conducted from a boat with readings collected along transects. A DTS cable shall also be deployed on a grid pattern with data collected for at least two tidal cycles along the same transects. The logs of the well boreholes will be used to calibrate the results. Thus, the survey shall be initiated within three months after the Biscayne Bay wells are installed (Section 2.3.2). All available specific conductance and salinity data from the surveyed terrestrial and estuarine areas shall be used to provide the best estimates of salinity based on resistivity values.

Additional geophysical surveys may be required over the wetlands or bays in a later phase of this monitoring program to update estimated groundwater salinity distributions.

2.3.4 Groundwater Sampling Each station shall comprise a combination of three monitoring wells at each site, designed to evaluate the extent of CCS influence and to determine hydraulic gradients (i.e., vertical and horizontal) with specific focus on macroporous hydrogeologic zones. Each monitoring well shall be instrumented and automatically monitored for groundwater levels, temperature, and specific conductance. The sensors in the monitoring wells shall be placed near the midpoint of the screened section of each well. Salinities measured by sensors shall be calculated using the PSS78.

Quarterly monitoring at each groundwater cluster shall consist of field parameters, ions, TDS, and the CCS tracer suite, as listed in Table 2-1. Semiannual monitoring at each groundwater cluster shall consist of all of the above, plus the nutrient parameters in the groundwater clusters (1, 2, 10, 13, and 14) labeled in Figure 2-1. In addition, trace elements shall be monitored semiannually for one year in the groundwater clusters (1, 2, 10, 13, and 14). If trace element concentrations exceed primary and secondary drinking water standards in groundwater samples, monitoring for these parameters shall continue and may be expanded to other stations as determined by the Agencies. All applicable samples shall be analyzed in accordance with Chapter 62-160 F.A.C. at an FDEP-approved laboratory capable of analyzing samples with a wide salinity range (including hypersaline waters).

FPL shall continue to manually collect all quarterly data (from two depths) from the existing wells L-3, L-5, G-21, G-28, and G-35 to compare the information with the new wells, which are more strategically screened. Since there are over 30 years of data from these existing wells, a comparison of the information to nearby wells shall give insight into the accuracy of the historical data. Previously, these wells were monitored quarterly with field instruments.

While temperature, specific conductance, and water level shall continue to be monitored with field instruments, samples shall be collected and sent to a laboratory for analysis of the same parameters that shall be the subject of monitoring in the new wells.

To further supplement the groundwater data being collected by FPL, information collected by others, including but not limited to USGS and the FKAA, may be used upon the 16 l Section 2: Proposed Monitoring Plan

Agencies pre-approval. The Agencies will review each proposed wells applicability to the Plan based on geologic data and construction details submitted. Currently, the USGS collects chloride data on a semiannual or quarterly basis and conducts induction logs once a year from a network of coastal wells throughout Miami-Dade County. In some cases, there are only a few years of data, and in other cases, over 30 years. Some of these wells are located in the project area and are screened near the base of the Biscayne aquifer.

2.4 CCS MONITORING The purpose of sampling within the CCS is to characterize the water. A total of seven stations are included, six along the interior boundary of the CCS, and one in the central portion of the CCS. These stations, labeled TPSWCCS-1 to TPSWCCS-7, are located both at the edge and the middle of the CCS system, as well as in the areas that are of the highest and lowest stage. These data shall provide a clear spatial and temporal understanding of the specific conductance and temperature variability within the CCS (Figure 2-2 and Table 2-4).

All stations in the perimeter canals shall have a specific conductance, temperature, and depth sensor placed approximately 1 foot below the surface level, and one approximately 1 foot above the bottom of the canal. Stations in shallow water (<3 feet) shall use one water quality sensor. The site in the center of the CCS (TPSWCCS-2) shall only have one sensor approximately 1 foot above the bottom of the canal; a second sensor is not warranted due to this center canals shallow depth (~3 feet). Sensors shall monitor for temperature and specific conductance (salinity calculated from specific conductance and temperature), which will help determine the vertical profiles in the CCS canals. Water level shall be measured at each station with a fixed sensor that is surveyed as described in Appendix C.

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Figure 2-2. CCS monitoring stations.

In addition to the automated monitoring, quarterly monitoring at each surface water station shall consist of field parameters, major ions, and the CCS tracer suite, as listed in Table 2-1.

Semiannual monitoring at each surface water station shall consist of all of the above parameters, as well as nutrients. The total count of alpha particle radioactivity (Gross Alpha) 18 l Section 2: Proposed Monitoring Plan

shall be monitored semiannually for one year in all stations located within the CCS. All applicable samples shall be analyzed in accordance with Chapter 62-160 F.A.C. at an FDEP-approved laboratory capable of analyzing samples with a wide-range of specific conductance values, including hypersaline waters (salinity conditions in excess of typical marine conditions).

Table 2-4. Rationale for the CCS monitoring locations.

Location Samples Rationale Cooling canal system (CCS) stations characterize CCS water and monitor changes.

The monitoring of water will be just below the surface within the CCS and at bottom, unless otherwise noted.

CCS TPSWCCS-1 This site is located in Canal 32, which shall document the specific conductance and temperature of water leaving the plant, where the greatest hydraulic stage is observed and shall serve as a station associated with operation of the inceptor ditch (ID).

TPSWCCS-2 This site is in the middle of the CCS, co-located with TPGW-13, and documents the change in specific conductance and temperature as the water travels down the CCS. This shallow site shall only have one monitoring sensor.

TPSWCCS-3 This site is located in Canal 32 near the southwest corner of the CCS, characterizes water at this end of the CCS, and shall serve as a station associated with operation of the ID.

TPSWCCS-4 This site is located in the Collector Canal at the southeast corner of the CCS, and characterizes water at this end of the CCS by the scrub mangrove forest.

TPSWCCS-5 This site is located in the deepest portion of Canal E6 and characterizes the water on its return trajectory back to the plant, nearest the location where DERM has observed atypical mangroves.

TPSWCCS-6 This location in the East Canal measures water as it enters the plant in the area of lowest hydraulic stage; this site will provide insight into the degree of exchange between the CCS and surrounding subsurface hydrology.

TPSWCCS-7 This station is located in Canal 32, halfway down the CCS on the west side, and shall serve as a station associated with operation of the ID.

Preliminary investigation into the thermal anomaly located within the northwest side of the CCS shall be undertaken after the detailed bathymetric survey (Section 2.6.1) has been completed. This investigation includes detailed sampling and characterization and shall include surface water sampling for parameters required under the quarterly sampling. The approximate location of the thermal anomaly is Longitude 80 21 4.79 West, Latitude 25 24 47.13 North, and Longitude 80 21 5.46 West, Latitude 25 24 11.04 North. The exact location shall be measured during the bathymetric survey and shall be compared to existing reports.

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2.4.1 Sediment and Porewater Sampling Sampling within the sediment and porewater may be needed to help with the interpretation of geochemical and/or ecological findings. Such sampling may be phased in after initial Plan implementation based on ecological and/or geochemical results, as recommended by the Agencies. The determination of specific measurements and locations will be made by the Agencies, and may include sediment bulk analyses in duplicate cores per site and porewater analyses. Sample depths shall include surface (0-10 cm) and subsurface (40-50 cm) samples, where possible.

2.5 SURFACE WATER MONITORING The purpose of surface water monitoring is described in COC IX and X of the Uprate Certification (see Appendix A) and the 2009 Agreement. This appendix focuses on the proposed surface water monitoring in Biscayne Bay and the nearby freshwater and tidal canals, including the L-31E Canal, tidal canal downstream of the S-20 Structure, and the Card Sound Canal. Monitoring surface water in the Model Land Basin freshwater wetlands and nearshore mangroves shall be addressed in Section 2.8: Ecological Monitoring.

2.5.1 Surface Water Locations A total of five surface water stations are proposed in Biscayne Bay, extending offshore along the length of the CCS. BBSW-3 shall be co-located with groundwater cluster TPGW-11 (Figure 2-3). BBSW-1 is located in the barge cut, northeast of Barge Turning Basin. Table 2-5 shows the locations of these surface water stations and the rationale for these locations respectively. The exact installation locations may need to be adjusted based on site-specific conditions (i.e., access considerations, minimization of environmental impacts) or permitting constraints. The surface water stations shall be located as close to shore as possible, but it is recognized that the water is quite shallow immediately east for much of the CCS.

As shown in Figure 2-3 and Table 2-5, surface water monitoring stations are proposed at three non-tidal surface water locations in the L-31E Canal: one tidal location at the S-20 Discharge Canal, and one tidal location at the Card Sound Canal. A sixth location in the Card Sound Road Canal, away from the influences of the CCS, shall be monitored manually with the quarterly sampling events. This is a reference station and may indicate the Card Sound Road Canals influence on regional saltwater intrusion and the possible impact on the area between Card Sound Road and the CCS.

The L-31E Canal is the closest freshwater water body to the CCS. The L-31E Canal stations shall serve a dual purpose of providing information for the assessment of CCS influences, as well as supporting the monitoring of water levels for ID operation.

20 l Section 2: Proposed Monitoring Plan

Figure 2-3. Surface water monitoring sites.

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Table 2-5. Rationale for the surface water monitoring locations.

Location Sample Rationale Biscayne Bay BBSW-1 This site is in the cut and just offshore the Barge Turning Basin, northeast of the CCS.

BBSW-2 This site is located offshore from the scrub mangrove where DERM has observed atypical mangroves to monitor for seepage from the CCS.

BBSW-3 This site is located near the Arsenicker Keys, just offshore the mangrove forest and co-located with TPGW-11.

BBSW-4 This site monitors the offshore portion of the CCS south of the Arsenicker Keys and near the mouth of the Card Sound Canal/historical CCS outlet, and co-located with TPGW-14. This site is located in close proximity to a Department of Health radiological monitoring site.

BBSW-5 This site is located south of the CCS and mitigation bank.

L-31E Canal TPSWC-1 This site is located northwest of the CCS along ID Transect A to monitor for seepage from the CCS and to aid in the operation of the ID.

TPSWC -2 This site is located along the middle segment of the CCS and along ID Transect C to monitor for seepage from the CCS and to aid in the operation of the ID.

TPSWC -3 This site is located by the S-20 structure, at the intersection of the L-31E and C-107 Canals to monitor for seepage from the CCS. It is also part of the ID operations located along Transect E.

S-20 Discharge TPSWC 4 This sampling station is located at the S-20 Discharge Canal. This Canal site shall monitor the extent to which the tidal portions of the drainage canal downstream of the S-20 Structure is affected by the surface waters of the CCS, as well as the potential influence of Biscayne Bay on the canal around the CCS.

Card Sound TPSWC -5 This site is located in Card Sound Canal, just below the CCS, where Canal manatees have been increasingly observed as reported by DERM.

Card Sound TPSWC-6 This site is located at Card Sound Road Canal, in the general Road Canal proximity of FKS-4, and will serve as a reference station that will help document the influence of Card Sound Road Canal on groundwater. This station shall be manually monitored.

2.5.2 Surface Water Data Collection The surface water stations in Biscayne Bay shall measure conditions just above the sediment surface. All stations, with the exception of the Card Sound Road canal station, shall be automated with one set of temperature and conductivity sensors installed horizontally, approximately 1 foot above the sediment surface (Appendix B). Stations in the Biscayne Bay not co-located with groundwater stations will not have telemetry and a surface water stage recorder. Sampling stations in Table 2-5 shall be automated and instrumented similarly to the CCS stations. This will allow for the determination of water level, temperature, and specific conductance at each site.

22 l Section 2: Proposed Monitoring Plan

Data from each surface water station discussed previously shall be collected at 15-minute intervals from the top of each hour and either manually or remotely uploaded to a database.

This monitoring strategy shall allow a continuous assessment of specific conductance and temperature changes in Biscayne Bay and canals in the areas surrounding the FPL Turkey Point Power Plant. The stage sensors shall be tied to an established datum (NGVD and NAVD). All sensors shall be inspected and cleaned as needed to meet QA/QC requirements.

In addition to the proposed automated monitoring, quarterly monitoring at each surface water station shall consist of field parameters, major ions, and the CCS tracer suite, as listed in Table 2-1. Semiannual monitoring at each surface water station shall consist of all of the above parameters, as well as nutrients. All applicable samples shall be analyzed in accordance with Chapter 62-160 F.A.C. at an FDEP-approved laboratory facility capable of analyzing samples with a wide specific conductance range (including hypersaline waters).

Additional data from other entities, such as BNP, NRC, USACE, EPA, NOAA, DOI, NPS, DOH, USGS, FWS, DERM, other local governments, and the SFWMD will be added to the information collected from this effort to form a more comprehensive understanding of this area. BNP monitors salinity at 34 sites in the area at the same 15-minute sampling frequency (Bellmund et al. 2007), and the sites around the CCS (BISC08B, BISC12B, and BISC13S) will be used to complement the monitoring efforts. Information available from the sampling network in BNP, Audubon Societys nearby sites, and the SFWMD Water Quality sampling network will be reviewed for relevance and applicability in the inclusion of data reporting.

Other data that will support this monitoring effort include the SFWMD operations of the S-20 structure, since that may affect the water quality at TPSWC-4.

2.6 WATER BUDGET AND MASS BALANCE CALCULATIONS Developing a periodic water budget for the CCS is essential in evaluating the exchange, if any, between the CCS and the groundwater, fresh surface waters, Biscayne Bay waters and the atmosphere. The monitoring and reporting described herein includes updated bathymetric survey work and provides supportive data and calculations of water and material mass within, entering, and leaving the CCS. The requirements of this section are necessary to implement FPL obligations under the Conditions for Certification as well as the Agreement with SFWMD.

2.6.1 Bathymetric Survey A key component of recharge/discharge in the water budget is a bathymetric survey because it will enable the estimation of the volume and water surface area of the CCS. A bathymetric/volumetric survey of the CCS and each segment of the interceptor ditch (ID) shall be conducted using sonar equipment, and results shall be tied to established horizontal and vertical datums as described in Appendix C. The positioning (x, y, and z) requires the FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 23

use of a high-accuracy GPS navigation system (or Real-Time Kinematic GPS survey grade equipment). The GPS vertical accuracy of the system shall be decimeter GPS. Since the volume of water in the CCS will vary hourly, the water surface shall be continuously monitored during the survey and all depths shall be corrected to reflect the depth below the vertical datums as described in Appendix C. The survey shall take into consideration the water levels collected electronically in the CCS and Biscayne Bay.

The raw sonar results of the bathymetric survey shall be converted into rectified electronic data sets with specific point elevations and coordinates and a three-dimensional rectified surface and subsurface mesh shall be developed in AutoCAD (version 14 or higher). These two surfaces must show the mean water surface elevations and actual depths within the CCS.

The volumetric calculations shall be complemented by all field water level data.

2.6.2 Water Budget Parameters and Monitoring The general water budget parameters to be collected are listed below. The units of all parameters shall be converted to similar volumes and rates.

• Daily rainfall quantities from three on-site locations and two off-site locations.

• Power plant intake and outflow velocity as measured by Acoustical Doppler current meters.

• Meteorological data (solar radiation, wind speed, wind direction, air temperature, relative humidity, or other components necessary to calculate evaporation).

• Groundwater and surface water levels in and surrounding the CCS.

• Interceptor ditch operations, flows, qualities, and rates for each segment.

• Other parameters (e.g., salinity measured from specific conductance) as needed to complete an estimated water budget.

Five rainfall stations shall be set up in and or near the CCS system. These stations will be co-located at stations TPRF-12 in the north, TPGW-13 in the center of the CCS, TPRF-L3 in the south, TPRF-L5 on the west side, and TPGW-11 on the east side (Figure E-1). Rainfall stations shall not be placed near structures that may obstruct rain or prevent accuracy in rainfall collection. Data from the rainfall buckets shall be collected with the same frequencies as the water level data. All data shall be transmitted to the FPL main server daily.

Permanent flow stations shall be established within the CCS using acoustic Doppler velocity meters. Volumetric and velocity measurements shall be conducted at three strategic locations in the CCS perimeter canal to assist in the estimation of water inputs and losses. The stream gauging locations shall be placed near the plant discharge (TPFM-1): at the constriction between the C series canals and the E series canals on the southeast side of the CCS (TPFM-2) and near the plant intake (TPFM-3) (Figure 2-4). Acoustical flow and velocity data at these stations shall be taken at each location concurrently and shall be collected at 15-minute intervals. The flow stations shall be integrated with existing CCS water quality monitoring stations when applicable. Inflows (timing, duration, and frequency) from the 24 l Section 2: Proposed Monitoring Plan

Interceptor ditch shall be monitored electronically and reported with the other water budget components.

Evaporative losses shall be calculated based on a wind speed sensor co-located at TPGW-13.

Additional parameters needed to calculate evaporative losses can be obtained from existing FPL meteorological stations. The wind parameter from the TPGW-13 station shall be combined with water temperature collected from the CCS surface water stations (Figure 2-4).

2.6.3 Water Budget Calculations A time series volumetric spreadsheet (or equivalent) shall be developed based on actual field data. This spreadsheet shall include all measured and calculated components of the water budget. This includes water volumes and material mass exchanges across the CCS boundaries estimated on a daily time step. A salt budget, estimated from specific conductance and concurrent flow measurements, shall be a component of this exchange estimate. If the water budget spreadsheet contains summarized variables, all data and supportive information shall be included for these variables. The water budget report shall use the daily time step to calculate the monthly averages (January through December) and data shall be summarized annually.

The water budget shall include a breakdown for each contribution. This includes but is not limited to:

• Losses/gains to the atmosphere as measured by rainfall and evaporation.

• Losses/gains to the surficial aquifer vertically.

• Losses/gains to the surficial aquifer horizontally.

• Losses/gains to Biscayne Bay (differentiated between Biscayne Bay groundwater and surface water to the extent practical).

Total estimated contributions from each area of potential losses and gains (shown previously) shall be calculated. After each quarterly sampling, the water budget spreadsheet shall be updated to include the results of the laboratory analysis. Combining the results will yield total load contributions for the CCS. This shall be done for the major cations, anions, and tracer suites parameters.

The updated water budget shall be thoroughly documented using the new information, and all estimates and assumptions shall be clearly noted. The water budget shall be calculated on a monthly frequency, summarized at the end of each year, and reported as specified in and reported in the annual report. After the second year of post-Uprate (as defined in Section 1),

a review of the approach and findings will be conducted.

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Figure 2-4. CCS flowmeter locations.

26 l Section 2: Proposed Monitoring Plan

2.7 INTERCEPTOR DITCH WATER MONITORING This Plan adds three water quality sensors at existing gauge stations in the ID coincident with Transects A, C, and E (TPSWID-1, TPSWID-2, and TPSWID-3) as shown in Figure 2-5. Each gauge station shall have a specific conductance, temperature, and depth sensor placed approximately 1 foot below the surface level, and one approximately 1 foot above the bottom of the ditch and be automated and instrumented similarly to the CCS stations. This will allow for the determination of water level, temperature, and specific conductance (salinity calculated) at each site. Transects B and D will still be monitored manually for stage unless automated in the future. Quarterly monitoring at each ID station shall consist of field parameters.

Data from each surface water station (Section 2.5) shall be collected at 15-minute intervals from the top of each hour and remotely uploaded to a database. This monitoring strategy shall allow a continuous assessment of stage, specific conductance, and temperature changes in the interceptor ditch. The stage sensors shall be tied to an established datum as described in Appendix C. All sensors shall be inspected and cleaned as needed.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 27

Figure 2-5. Proposed interceptor ditch monitoring sites.

28 l Section 2: Proposed Monitoring Plan

2.8 ECOLOGICAL MONITORING 2.8.1 Overview and Strategy The purpose of ecological monitoring design is to identify the existing baseline conditions and future impacts of CCS waters as described in the Conditions of Certification (COC) IX and X of the Uprate and in the Agreement (see Appendix A). Ecological monitoring is necessary to establish the current, pre-Uprate status of ecological conditions and biotic components, the extent to which CCS operations may be impacting conditions and components, and the extent to which Uprate implementation may result in further impacts and changes to these conditions and components now and into the future. Ecological conditions of primary, but not exclusive, interest related to CCS operations and ecological responses, are temperature, salinity, a CCS tracer suite, and nutrients. Biotic components of primary interest are marsh vegetation (i.e., freshwater graminoid and woody) in adjacent wetlands, mangroves, submersed aquatic vegetation (SAV), and benthic fauna in and adjacent to Biscayne Bay.

The strategy of this Plan is as follows:

• Spatially characterize ecological conditions via broad reconnaissance surveys.

Wetland surveys shall be completed within six months of plan approval.

Estuarine and bay surveys shall be conducted within one year of Plan approval and include a resistivity survey of Biscayne Bay and Card Sound (see Section 2.3.3), along with sampling of specific conductance (with salinity calculated) and a CCS tracer suite within the upper 60 cm of soils and sediments (porewater) in these bays and in the saline and freshwater wetlands adjacent to the CCS (Section 2.8.3 Initial Ecological Condition Characterization).

• Within three months of Plan approval, identify stressed areas in the vicinity of the CCS. This will be accomplished by synthesizing existing data relating to the distribution and density of vegetation using observations and cursory analysis of recent and historical aerial photographs. Aerial photographs of the region taken by the Comprehensive Everglades Restoration Plan (CERP) Restoration Coordination and Verification (RECOVER) team in April 2009 will be made available for this purpose. Analysis of such photographs combined with site visits will help determine the specific locations of sampling sites (Section 2.8.4 Broad Scale Vegetation Characterization).

• Establish transects and plots in freshwater and saline wetlands, including sampling of specific conductance and a CCS tracer suite, and nutrients in soils and sediments within six months of plan approval (Sections 2.8.5, 2.8.6, 2.8.7).

• Initiate Biscayne Bay benthic SAV and faunal assessment (Section 2.8.8 Biscayne Bay and Card Sound).

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 29

2.8.2 Design Three zones, freshwater marshes, saline/coastal wetlands, and Biscayne Bay and Card Sound, shall be assessed for pre- and post-Uprate by establishing transects that are repeatedly measured over time. Results shall be compared with changes over this time in reference areas that are ecologically similar, with exposure to similar environmental factors other than CCS operations. The Triangle Area, between Card Sound Road and US Highway 1 of the Model Lands, will serve as the reference area (Figure 2-6). It is anticipated that at least a minimum of two years of pre-Uprate monitoring (as defined Section 1) shall be performed.

Within each zone, a slightly different sampling design is recommended. A transect design is to be used within the northern, eastern, western, and southern marshes (Figure 2-6). Areas that have been currently identified as containing stressed or atypical vegetation patterns shall be included in the transects and subject to additional evaluation. Such stressed areas have been identified at the following locations:

1. An atypical mangrove area, east of the CCS (25.41N, 80.32W).

2. Short fringe mangroves, south of the Sea Dade Canal (25.34N, 80.33W).

3. Stunted sawgrass site, west of CCS (25.43N, 80.35W).

4. Pond area in saltwater mangrove area east of CCS (25.3799N, 80.3268W).

5. Nearshore benthic features within Card Sound (25.4072N, 80.3273W).

Additional areas that may be identified in initial site characterizations (described in Sections 2.8.3 and 2.8.4) shall also be considered in the final transect placement after consultation with the SFWMD. A transect approach shall also be used in the mangrove wetlands east of the CCS, but because of the small area involved, and the structure of existing or remnant creeks, these transects may be modified over time to spatially conform to landscape features and areas of potential impact.

Within Biscayne Bay and Card Sound, a combination of nearshore-offshore transects and nearshore areal sampling shall be used. For any of these zones, additional sites shall be added at locations where specific CCS influence is subsequently identified; concerns are noted (e.g.,

sites of CCS derived groundwater upwelling) and/or harm or potential harm is indicated.

2.8.3 Initial Ecological Condition Characterization Assessment of biotic responses to CCS operations requires information on the spatial distribution of environmental conditions that affect biota and are potentially influenced by CCS water. A condition of primary interest is salinity, as calculated with specific conductance, especially soil and sediment specific conductance for vascular plants, but other conditions, such as temperature and nutrients, are important ecological factors (Table 2-7).

30 l Section 2: Proposed Monitoring Plan

Measurement of a CCS tracer suite is essential to establish the extent of CCS connectivity if any in a given adjacent zone. Initial information on salinity distribution will be derived from two sources: 1) an electromagnetic resistivity survey of Biscayne Bay and Card Sound (Section 2.3.3); and 2) porewater surveys of freshwater and saline wetlands adjacent to the CCS and Biscayne Bay and Card Sound (described as follows). Porewater shall be analyzed for specific conductance within the root zone (about 30 cm deep, but limited to the top 60 cm), along with the CCS tracer suite analysis at a subset of locations. Results from these surveys shall identify potential zones of CCS water connectivity with surface sediments and soils via seepage and groundwater pathways, providing information on potential ecological influence of the CCS, as well as a basis to improve the monitoring design within the adaptive protocols of this Plan.

The resistivity survey of Biscayne Bay and Card Sound, described in Section 2.3.3, shall be used to locate potential upwelling zones containing CCS water within Biscayne Bay.

A broad-scale survey of porewater temperature, specific conductance, and the CCS tracer suite shall be made in adjacent wetlands during the first dry season (December through May) after Plan implementation and in Biscayne Bay and Card Sound during the first wet season (June through November) and dry season after Plan implementation. Specific conductance and temperature profiles (at 20 cm intervals to 60 cm or refusal) shall be measured in situ, using field meter and probes at more than 100 points in the wetlands, both freshwater and saline, and more than 100 points in Biscayne Bay and Card Sound. The boundaries of the surveyed wetlands shall be as far west as Tallahassee Road and Card Sound Road, as far north as the Florida City Canal and south to Card Point, and east to the estuarine shoreline.

The boundaries of estuarine porewater surveys shall be as far east as 4 km offshore from the Biscayne Bay and Card Sound shoreline between the Mowry Canal and Card Sound Road.

Sample sites shall be approximately even in distribution, but some samples may be taken in areas of special interest, such as apparently stressed areas, tree islands, remnant creeks, or sites where groundwater inputs are suspected. If such areas are found to be distinct from adjacent marsh areas, the transect design, described in Sections 2.8.6 and 2.8.7 may be modified and/or expanded to include these areas. Water level within wetlands, and water depth, within the Bay shall also be measured, and locations of all sampling shall be tracked and identified by GPS.

Following analysis of the survey results, and after consultation with the SFWMD, CCS tracer suite measurements shall be made from porewater about 30 cm deep at a subset of sites that, based on specific conductance results, indicate the strongest CCS influence. The CCS tracer suite measurements shall include at least 30 samples in each wetland zone, both freshwater and saline, yielding a total of 60 wetland samples, and 30 samples in Biscayne Bay and Card Sound. Wetland sampling shall include a subset of deeper samples (about 60 cm deep) to help distinguish groundwater and rainfall derived tracer sources. In Biscayne Bay and Card Sound, there shall be two separate samplings, each including 30 tracer suite analyses. One sampling shall be done during a neap tide period, January through March. A second sampling shall be performed in the wet season in June through August. Pending the results of this initial porewater survey and/or the resistivity survey, additional samplings may be conducted in a later phase and may include the tracer suite and/or additional parameters.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 31

2.8.4 Broad Scale Vegetation Characterization Within one month of Plan approval, a broad scale vegetation assessment shall be conducted in wetland areas adjacent to the FPL facility, by review of existing information supplemented by documented ground observation. Existing data shall be synthesized relating to the distribution and density of vegetation by cursory analysis of recent and historical aerial photographs. One set of photographs that may be used was taken by RECOVER in April 2009 and copies of these photos shall be made available to FPL upon request to the SFWMD. Additional ground observations that indicate stressed vegetation or other ecological conditions shall be made and described in field logs and recorded by photographs, including GPS locations during any initial site characterizations described in Section 2.8.3.

Vegetation mapping may be initiated at a later stage of this monitoring program if analysis of vegetation in plots along transects indicates a CCS effect on the wetlands.

2.8.5 Wetland Transect Locations Ecological assessment of the wetlands shall focus primarily on patterns of plant community status and environmental conditions relevant to this community, along transects emanating from the CCS. The approximate locations are shown in Figure 2-6 and the parameters are summarized in Table 2-6. Three east-west transects (approximately 6 km long) shall be established through the freshwater wetlands (shown in yellow in Figure 2-6) from the CCS into the Model Land Basin at least as far west as Tallahassee Road. Preliminary locations for these three western transects include an area of special concern, adjacent to the CCS western boundary, where observations of sparse and stressed vegetation have been made, as well as further areas to the west that do not indicate obvious stress. Two shorter transects shall run from the northern and southern CCS boundary through freshwater wetlands (in yellow) and saline wetlands (in pink) to the Biscayne Bay and Card Sound coastline. The southern transect traverses wetlands south of the CCS from the southwest corner of the CCS to Card Sound. The northern transect traverses wetlands from the northern CCS boundary to approximately the mouth of the Florida City Canal. Three additional short transects shall run from the eastern CCS boundary to the coastline in the saline mangrove wetlands (shown in pink in Figure 2-6) with an orientation dictated by the shape of this narrow coastal area and the location of previously identified atypical mangrove growth and mangrove mortality.

A reference transect (in turquoise in Figure 2-6), approximately 9 km long through freshwater and saline wetlands shall also be established in the Triangle Area. Water levels within wetlands and water depth within the Bay shall also be measured, and locations of all sampling shall be tracked and identified by GPS. Land based areas along the transects shall be referenced back to an established elevation as described in Appendix C. This effort does not require professional surveying. However, all measurements shall be tied back into an existing datum. This includes the use of existing benchmarks, LIDAR data, EDEN network elevations and/or ground surface elevation from nearby well surveys.

32 l Section 2: Proposed Monitoring Plan

The specific site selection shall be made in consultation with the Agencies. The final location of these transects and the sample sites selected along them shall be subject to the review and approval by the Agencies within 30 days.

Figure 2-6. Ecological monitoring transects adjacent to the CCS. Freshwater wetlands are shown in yellow, saline wetlands in pink, Biscayne Bay and Card Sound benthic in white and associated reference transects in turquoise. Location of the interface of freshwater and saline wetlands shown here is conceptual.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 33

2.8.6 Freshwater Wetland Transect Assessments Sampling along all transects shall be at three spatial levels (shown in Figure 2-6): 20 m x 20 m major plots (turquoise squares), 5 m x 5 m subplots (pink squares), and 1 m x 1 m subplots (yellow squares). The exact locations of these plots along the transect shall be jointly determined among the Agencies after the initial dry season assessment along each transect. The measurements shall be every 500 m of field porewater specific conductance and temperature depth profiles to 60 cm depth. Each western transect shall be established with a total of four major plots, of which two are within 1.5 km of the CCS and one near the western end of the transect (Figure 2-6). This effort does not require professional surveying.

However, all measurements shall be tied back into an existing datum. This includes the use of existing benchmarks, LIDAR data, EDEN network elevations, and/or ground surface elevation from nearby well surveys.

From each major (20m x 20m) plot, species composition and abundance, woody species cover, herbaceous species cover, and canopy height shall be measured. Percent vegetative cover shall be determined from the aerial imagery, while the other parameters shall be determined from ground assessment. Photographs for each plot shall be digitized, and classification of community types defined for each plot.

During the ground assessment, one 5 m x 5 m subplot shall be randomly established within each quadrant of the larger plot (Figure 2-7). Species diversity and characteristics of woody plant species (e.g., height, diameter at breast height) shall be measured within each subplot.

Within the same quadrant, a 1 m x 1 m subplot shall also be randomly established in the marsh to determine the marsh species diversity and density. All sawgrass (C. jamaicence) culms and spikerush (Eleocharis spp.) stems shall be counted within each subplot. The number of leaves in ten C. jamaicense culms shall be counted and measured; similarly, the height of ten Eleocharis spp. stems shall be measured. Estimates of plant productivity shall be made in woody vegetation (5 x 5 m) plots from changes in morphology (e.g., diameter at breast height) and leaf litter production or alternative production methods, as approved by the Agencies. Plant productivity of dominant graminoid species (in 1 m x 1 m plots) shall be estimated by leaf biomass turnover measurements. The proposed methodology is consistent with methods used in Everglades National Park by the National Science Foundation (NSF) funded Long-Term Ecological Research Program based at Florida International University.

Major plot (20 m x 20 m) measurements shall be conducted once a year, while the 5 m subplot measurements shall be conducted twice a year, at the end of the wet season (June through November) and dry season (December through May). Leaf litter production shall be made quarterly or alternative production measurements made at a frequency as approved by the Agencies. The 1 m subplots shall be measured at three-month intervals.

Twice a year (i.e., once at the end of the wet and dry seasons), ten leaves per stems of each of the dominant species shall be randomly selected and collected from each subplot along each transect for morphological and physiological characterization. Leaf characteristics (i.e.,

leaf length, width, and thickness, water content) shall be measured prior to the leaves being dried and analyzed for C, N, and P contents, as well for 13C. Changes in these plant 34 l Section 2: Proposed Monitoring Plan

characteristics over time and among plants within and between transects shall be analyzed for trends and differences.

Water level and surface water (when present), temperature, and specific conductance shall be measured within one woody vegetation subplot (5 x 5 m) and one graminoid (1 x 1 m) subplot per each major plot every three months. Soil temperature and porewater, and specific conductance shall also be measured at two depths (about 30 cm and 60 cm) in these two subplots per each major plot every three months.

If specific conductance values of >725 S/cm (derived from 250 mg/L Cl-) are observed, two subplots will be sampled and composited (within each major plot) for the tracer suite analysis from porewaters at a depth of about 30 cm. This conductance threshold is subject to revision based on the Initial Ecological Condition Characterization survey and/or other information.

Porewater nutrients (TP, SRP, NH4, NOX, TKN) shall be measured in one graminoid subplot (1 x 1 m) and one woody vegetation (5 x5 m) subplot of each major plot within the root zone (about 30 cm) twice per year. A composite sample may be made from the two samples. Bulk soil nutrients (TP, TN, TOC) and bulk density shall be measured initially (once) in 30 cm cores. For these measurements, composite samples shall consist of 10 cm horizons (0-10 cm, 10-20 cm, and 20-30 cm) from one 30 cm core from a graminoid subplot (1 x 1 m) and one 30 cm core from woody vegetation (5 x5 m) subplot. Additionally, specific conductance and temperature shall be measured in the L-31E Canal along the line of these transects.

As described in the Initial Ecological Condition Characterization (Section 2.8.3), the specific conductance and ecological condition of tree islands along potentially remnant streams and other sites of special interest shall be assessed in a preliminary survey. If results from this survey indicate the need for additional information, then additional transects or plots near the three established transects may be added at the discretion of the Agencies. Sampling shall be consistent with that occurring along transects, but the SFWMD will coordinate Agency review prior to initiation.

Plot site selection, plot design, and sampling along the two shorter freshwater marsh transects north and south of the CCS shall be as described previously for the western transects. However, only two major plots shall be established along each of these transects.

Plot site selection, plot design, and sampling along the reference freshwater marsh transect within the Triangle Area shall be as previously described for the western transects, with a total of four plots.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 35

20 m 10 m Legend:

5m 1 m x 1 m subplots 5 m x 5 m subplots Figure 2-7. Example of a proposed sampling design for ecological monitoring along the transects.

2.8.7 Saline Wetland Transect Assessment Assessment along the five transects containing saline wetlands (shown in pink in Figure 2-6) shall focus on plant community composition, morphology, productivity, and environmental conditions, similar to that described for the freshwater wetlands. The sampling design shall also be similar, with the establishment of two major (20m x 20 m) plots per transect, each with four to eight subplots, pending the presence of herbaceous vegetation. The specific location of these plots shall be determined with the approval of the Agencies after the initial site characterization survey with porewater salinity, temperature, and the tracer suite measurements as described previously. However, along the three short eastern transects, initial site survey points shall be spaced approximately 100 to 200 m apart.

The following shall be measured as previously described for freshwater wetlands: plant community composition; cover; canopy height; leaf litter production; stage; surface water temperature and specific conductance; soil temperature; porewater specific conductance; porewater nutrients; and bulk soil nutrients and density. The tracer suite shall be measured quarterly at 30 cm depth with composited samples from two subplots per each major plot.

Should tracer suite results along a transect indicate potential contributions from the CCS, additional non-composited tracer suite sampling shall be conducted from two additional sites along the transect. Twice a year, at the end of the wet and dry seasons, ten leaves/stems from each of the dominant species shall be randomly selected and collected from each plot along the transect. Leaf characteristics (i.e., leaf length, width, thickness, and water content) shall be measured prior to the leaves being dried and analyzed for C, N, and P contents, as well as for 13C. Changes in these plant characteristics over time and among plants within and among transects shall be analyzed for trends and differences.

36 l Section 2: Proposed Monitoring Plan

The saline coastal portion of the reference transect within the Triangle Area (Figure 2-6) shall also include, at a minimum, two major plots with subplots and sampling of these subplots as described for the saline wetlands.

2.8.8 Biscayne Bay and Card Sound Ecological monitoring shall document benthic biota of Biscayne Bay and Card Sound (i.e.,

SAV, benthic and epibenthic fauna), salinity (calculated with specific conductance), and a tracer suite to distinguish the extent of CCS connectivity to these conditions. Specific conductance and the tracer suite initially shall be surveyed as described previously (see Section 2.8.3). Benthic surveys and fish and invertebrate sampling, as specified in the Plan, shall use results from existing monitoring programs within Biscayne Bay, to the extent possible. Sample methodology for work in the Plan shall be consistent with other programs within Biscayne Bay and Card Sound, but is performed in locations near Turkey Point not sampled by the other programs. Data from these programs shall be used for assessment of reference area conditions.

Benthic surveys shall be made using a transect design to discern potential CCS effects as a function of distance from shore. A set of 15 fixed transects (white lines in Figure 2-6), each 2 km long, shall be sampled randomly along each transect twice per year. The transects shall be arrayed such that each set includes five transects approximately parallel to shore that are 0.25 km, 0.5 km, 1.0 km, 2.0 km, and 4.0 km offshore. If the area is inaccessible, transect locations may be re-evaluated in consultation with the Agencies. The array shall include four sets of these transects that project from the proposed saline wetland transects: one northern zone (offshore near the power plant), one central zone (offshore of the central CCS), one southern zone (offshore of the Sea Dade Canal - southeast CCS corner), and one reference set in northern Barnes Sound (starting north of Middle Key; in turquoise in Figure 2-6).

Sampling shall be done to estimate the species composition, abundance and cover of benthic vegetation (SAV, including seagrass, and macroalgae) and large sessile fauna (e.g., corals and sponges), using the rapid Braun-Blanquet methodology currently used in Florida Bay and Biscayne Bay by RECOVER and other groups (Fourqurean et al. 2002). For each transect and sampling event, eight points shall be randomly selected, with measurements in four quadrats (0.25 m2 each) per sample point. Sampling times shall be done twice per year, once during the months of March-May and once during the months of August-October.

For each benthic survey transect, light extinction shall be measured at one point per transect.

Porewater specific conductance and temperature shall also be measured at each sampling point along these transects, with the tracer suite measured at a subset of points (one site per transect, selected based on the highest specific conductance and/or appearance of ecological stress). Should tracer suite results along a transect indicate potential contributions from the CCS, additional tracer suite sampling shall be conducted from two sites along each transect.

Sampling depth shall reflect exposure within the seagrass root zone (upper 30 cm). Nutrients in porewater shall be measured twice per year and bulk sediments shall be measured once (initially) at two sites per transect and composited as described for the saline and freshwater wetland transects (Section 2.8.6). Seagrass leaf nutrients from the dominant species (likely FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 37

turtle grass) along each transect shall also be analyzed once per year for total nutrient content (C, N, P per dry weight), as well as 13C and 15N ratios.

Nearshore benthic fauna (i.e., small fish and epibenthic macroinvertebrates, such as pink shrimp) will be monitored using methods consistent with other sampling elsewhere in Biscayne Bay. This Monitoring Plan component shall fill a gap between Mangrove Point and Turkey Point, where no such monitoring has been done, using methods that allow quantitative spatial comparison. Sampling shall be done with 30 throw trap samples per sampling event, twice during the year in the wet season and dry season. If a contractor is used that previously has not performed such sampling, consultation with parties that use this method in other areas of the Bay shall be made to ensure sampling and reporting consistencies and allow comparison with other areas within Biscayne Bay. Supporting information, needed to interpret ecological findings, shall be collected along transects and at fish and macroinvertebrate sampling sites. Bottom water specific conductance, temperature, and water depth, along with observations regarding SAV habitat, shall be measured at each site during each sampling event.

38 l Section 2: Proposed Monitoring Plan

Table 2-6. Ecologic monitoring: transect sampling.

Surface Water Soil/

Location(s) and (SW) & Porewater Biotic Sediment Zone number (PW) Parameters Parameters Parameters Frequency 3 east-west SW: Plant Nutrients Annual, bi-Freshwater Wetland transects, 2 (roughly) Water depth, community (TOC,TN, annual, and north-south temperature, and composition, TP), initial once every transects, 1 specific cover, canopy bulk three reference transect conductance. height, density. months, (Figure 2-6). All with productivity, depending 3 spatial levels (20 m PW: temperature, leaf on plot plots, 5 m and 1 m specific characteristics, level (see subplots; Figure 2-7). conductance, C, N, P text).

tracer suite, contents, and andnutrients. 13C.

Five transects plus SW: Plant Nutrients Annual, bi-Saline/ Coastal Wetland reference transect Water depth, community (TOC,TN, annual, and (Figure 2-6). 3 temperature, and composition, TP), initial once every spatial levels (20 m specific cover, canopy bulk three plots, 5 m and 1 m conductance. height, density. months, subplots; Figure 2-7). photosynthesis, depending PW: leaf on plot temperature, characteristics , level (see specific C, N, P text).

conductance, contents, and tracer suite as 13C.

indicated, nutrients.

For SAV and sessile SW: Benthic (SAV, Nutrients Two times Biscayne Bay and Card Sound benthic fauna, 4 sets Water depth, coral, sponge) (TOC, TN, per year for of 5 transects (each temperature, community TP), bulk biota and 2 km long). Eight specific composition and density. waters random sample conductance, and cover, seagrass (including points per transect. light extinction leaf nutrients porewater),

For mobile (C,N,P), 13C, one time epibenthic fauna, and 15N, fish for area between PW: and sediments.

Mangrove and Turkey temperature, invertebrate points, 30 stratified specific species random points. conductance, composition, tracer suite as and abundance.

indicated, and nutrients.

FPL Turkey Point Plant Groundwater, Surface Water, and Ecological Monitoring Plan l 39

Table 2-7. Ecologic monitoring: initial characterization and survey sampling.

Zone Type Location(s) and number Parameter(s) Frequency Porewater Spatially distributed within Temperature, 1 time; initiate Survey freshwater wetlands; minimum specific within the first dry Saline and of 100 conductivity samples conductance, season after Plan Freshwater and 30 tracer suite samples, tracer suite,and approval.

each for saline and freshwater water depth.

Wetland wetland areas.

Resistivity Biscayne Bay south of Mowry -- Within 3 months Biscayne Bay Survey Canal, including Card Sound. after groundwater wells within Biscayne Bay are operational.

Porewater Spatially distributed within 4 Temperature, 1 time in wetland Survey km of shore; minimum of 100 water depth, and 2 times in bays conductivity samples and 30 specific (wet and dry season);

tracer suite samples within the conductance, and initiate within 3 Bay. tracer suite. months after Plan approval.

40 l Section 2: Proposed Monitoring Plan

3 Field Notification, Data Collection and Reporting 3.3 QUALITY ASSURANCE/QUALITY CONTROL PLAN Pursuant to Chapter 62-160 F.A.C., preparation of a Quality Assurance/Quality Control (QA/QC) Plan shall be initiated immediately upon approval of the Monitoring Plan and submitted for the Agencies approval within 60 days of this Plans approval (effective date of the 2009 Agreement). The QA/QC Plan shall lay out the overall framework to ensure defensible monitoring results and quality reporting. The Plan shall outline procedures used in the field to install wells, manually collect samples, and conduct laboratory analysis. All data collected shall meet Chapter 62-160 F.A.C., SFWMD, and FDEP QA/QC requirements.

More detailed information related to calibration and maintenance of probes and other automated instrumentation shall be provided. A major part of the QA/QC Plan shall describe data management procedures to ensure the data is properly recorded and reported.

Detection limits for each parameter in the Plan shall be listed in the QA/QC Plan for Agency approval. Any request for long-term modification of sampling or analytical procedures shall be submitted in writing at least 90 days prior to the intended modification for review and approval by the Agencies. This shall include a proposed associated amendment of the QA/QC Plan.

To ensure appropriate methods are used to analyze saline and/or hypersaline samples, field measurements of salinity shall be logged and shall accompany all samples analyzed at laboratories. All contract laboratories shall be made aware of and be capable of analyzing constituents in saline and/or hypersaline waters. Field measurements for salinity shall be made in accordance with the Standard Method 2520B using the Practical Salinity Scale of 1978 (PSS78) (APHA 1998). Since the PSS78 is accurate to a salinity range of 0 to 40, it will be necessary to use chloride and TDS data from laboratory measurements to validate salinity values exceeding 40. The QA/QC plan shall include a methodology for performing these validations.

Laboratory analyses shall be performed by laboratories with NELAC certification (for analyses in this Plan that specify such certification) and methods shall be appropriate for samples with a wide range of salinities (i.e., from 0 to about 70 psu). Laboratory audits performed by the Agencies or Agency contractors shall be allowed for any facility analyzing samples from this monitoring program.

FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 41

3.3.1 Field Sampling and Analysis Event Notifications The lead Agency personnel or their designated contractor shall be notified of all field events no later than five days prior to initiation of field events, including but not limited to site surveys, well installation, surface and groundwater sampling, and ecological sampling and analysis. During long-term events, such as well installation, the lead Agency shall be notified for subtasks, such as well development and geophysical logging. Agency personnel shall have access onsite to observe field activities, with annual field audits by the Agencies, and FPL shall provide copies of field-generated notes and logs upon request. If field events are delayed, notification shall be provided as soon as practical and include the revised field event schedule.

3.3.2 Meetings To facilitate communication and keep the Agencies apprised of the monitoring efforts and any significant findings, quarterly meetings for the first year, followed by semiannual meetings of FPL staff and contractors and the Agencies shall be held. Issues of concern or suggested improvements in the monitoring effort commensurate with focused objectives of the Conditions of Certification shall be discussed.

3.4 DATA COLLECTION AND REPORTING Detailed information shall be provided to enable the Agencies to understand potential physical, chemical, and possibly ecological impacts of water movement and/or interchanges between the CCS, surface water, and groundwater. Data shall be submitted on a secure Web site and in the form of hard and electronic report copies. In accordance with the Conditions of Certification and unless stated otherwise in the Fifth Supplemental Agreement, electronic copies of all data and reports generated directly from this Monitoring Plan shall be provided to the SFWMD Director of Water Supply Management, Miami-Dade County Director of DERM, FDEP Director of the Southeast District Office, FDEP Siting Coordination Office Director, and Biscayne Bay Aquatic Preserve Manager.

Table 3-1 provides a summary of data collection efforts and frequency of collection for designated sites with continuous recorders.

42 l Section 3: Field Notifications Data Collection and Reporting

Table 3-1. Sampling frequency for field and laboratory parameters.

Automated Field and Field Electronic Laboratory Manual Sample Type Parameters Frequency Parameters Frequency CCS Water Salinity1, 15 minutes Salinity, specific Quarterly to specific conductance, Semiannually conductance, temperature, tracer (Section 2.2.4) temperature, suite and water and water level quality parameters Groundwater Salinity1, 15 minutes Salinity, specific Quarterly to Monitoring Wells specific conductance, Semiannually conductance, temperature, tracer (Section 2.3.4) temperature, suite and water and water level quality parameters Biscayne Bay Salinity1, 15 minutes Salinity, specific Quarterly to Littoral Zone specific conductance, Semiannually Surface Water conductance, temperature, tracer (Section 2.5.2) temperature, suite and water and water level3 quality parameters Canal Surface Salinity1, 15 minutes Salinity, specific Quarterly to Water (L-31) (3 specific conductance, Semiannually Stations), L-31 conductance, temperature, tracer (Section 2.5.2)

Discharge Canal, temperature, suite and water Card Sound Canal, and water level quality parameters Card Sound Road Canal Interceptor Ditch Salinity1, 15 minutes Salinity, specific Quarterly Control (3 Stations) specific conductance, conductance, temperature temperature, and water level Ecological See Tables Monitoring 2-6 and 2-7.

1 Salinity values calculated using the PSS78.

2 All stations except for the Card Sound Road Canal Station shall be automated.

3 Water levels recorded at stations co-located with monitoring well clusters FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 43

3.5 DATA COLLECTION 3.5.1 Automated Sample Collection Proposed stations identified in Figures 2-1, 2-2, 2-3, 2-4, and 2-5 of this document shall be electronically monitored by FPL. All automated time-series specific conductance, temperature, and water level data as discussed in Section 2 and provided in Table 3-2 shall be compiled from the remote locations by telemetry. Each station as appropriate shall have a stand-alone solar power supply, onsite data loggers (with appropriate storage capacity), and the appropriate sensors needed to monitor the parameters described in Table 3-2. Each data logger shall initially be programmed to collect the required data at 15-minute intervals, unless otherwise noted, starting at the top of the hour based on time at the atomic clock and maintained in Eastern Standard Time. The data loggers shall also not account for Daylight Savings Time to retain consistency with SFWMD data collection efforts. Calibration of sensors shall be a function of the manufacturers specifications. All sensors and equipment shall be maintained per the manufacturers specifications.

Table 3-2. Proposed automated time-series data collection from surface and groundwater stations.

Parameter Units Temperature degrees (Celsius)

Level feet (NGVD and NAVD)

Specific Conductance µS cm-1 Salinity psu 3.5.2 Manual Sample Collection Data from efforts such as borehole logging, well and stage recorder surveying, manual water quality sampling, and biological monitoring shall be recorded in field notebooks prior to entry into an electronic database. As outlined in Section 2 and per Table 3-1, water quality samples shall be collected from groundwater wells, surface waters, and the CCS, as part of regular monitoring on a quarterly and/or semi-annual basis.

3.6 DATA REPORTING 3.6.1 Web Database The database shall be maintained and archived by FPL on a Web portal. This server shall be backed up and archived weekly to minimize the risk of data loss. The Agencies shall be given passwords to access the data 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day/7 days a week. A web masters contact 44 l Section 3: Field Notifications Data Collection and Reporting

information shall be clearly posted on the web page. The Web-based applications shall provide the following:

• Geologic and hydrogeologic data acquired during this investigation.

• Well construction data and spreadsheets.

• Downhole geophysical logs.

• Geophysical surveys.

• Water budget and material load input values, calculations, and sums.

• Bathymetric survey.

• Equipment calibration logs and maintained records.

• Manual sampling of COCs, field data sheets, analytical laboratory results with QA/QC documentation.

• Ecological data.

Summarized data shall include but is not limited to:

• Groundwater and surface water hydrographs.

• Spreadsheet summaries and graphical representations of current and historical manual sample results.

• Automated reports such as, but not limited to, water level, temperature, specific conductance, and ID pump operations, meteorological monitoring.

• Log of any plant operations change, system shut downs or deviations that might affect parameters in this investigation.

• All results generated as a result of ecological monitoring (Section 2.8) and, Geophysical Surveys (Section 2.3.3).

• Semiannual and annual reports in PDF formats.

• All other reports that pertain to this Monitoring Plan.

• Aerial imaging results.

If determined that additional information must be added or modified to enhance the Web site, FPL shall do this within 60 days of Agency notification.

3.6.2 Automated Data Reporting The data generated from continuous electronic monitoring of meteorological, surface and groundwater stations, and ID stage and pump operations shall be accessible real-time to the SFWMD; however, the raw data shall not become official until FPL has had a chance to conduct a QA/QC review. The data shall be provided in the comma delimited format for use in the SFWMD databases. The column headings and format will be specified by the SFWMD after consultation with FPL. This shall be done within 50 days of the date of collection. FPL shall provide electronic accessibility of the results to the Agencies. All data FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 45

shall be stored in a database maintained by FPL; this server shall be backed up and archived weekly to minimize the risk of data loss. The data shall be tabulated in downloadable Excel, comma delimited format, and where appropriate, graphically presented to allow monitoring of operations by FPL staff, quick review of time-series data variations, and sensor performance.

3.6.3 Manual Data Reporting Data collected from manual sampling and monitoring shall be stored in a database maintained by FPL; this server shall be backed up and archived weekly to minimize the risk of data loss. Electronic copies of analytical data shall be provided simultaneously to FPL and the SFWMD; however, the data shall not become official until it has undergone a QA/QC review by FPL. A summary of QA/QC analytical results shall be posted on a secure Web site. While the length of time between collecting the data and posting it will vary depending on what is collected, FPL shall post the data within three months of collection or at minimum provide a status as to when the data shall be posted. The manual data shall be compiled with automated data into reports as outlined as follows. Data files shall be made electronically available to the Agencies.

3.6.3.1 Surveyors Report FPL shall obtain a licensed Florida surveyor to conduct detailed surveys at each location where monitoring is being done, except as specified in Section 2.8 (Ecological Monitoring).

The data collected from this effort shall be compiled and documented in a report that documents all data and techniques. The order of surveying shall be documented (1st, 2nd, or 3rd order).

Data collected from the survey of the groundwater monitoring wells and surface water stations shall be documented. Appendix C provides surveying requirements for this Monitoring Plan. An electronic copy of the field notes, an electronic copy of all computation sheets, site photographs, and benchmark sheets shall also be included.

3.6.4 Geology and Hydrogeology Report Geologic and hydrogeologic data, as outlined in this Monitoring Plan, shall be collected to better understand the movement of water within the Biscayne aquifer, in the immediate vicinity of the CCS. This is relevant because subsurface conditions may influence the extent and rate of CCS water migration.

This report shall provide relevant and available information on the lithology and hydrostratigraphy of the subsurface rocks and sediments of that area.

Data collected during well installation (Section 2.3.1), including detailed lithologic logs, borehole geophysics, optical borehole logs, initial induction logs, temperature and flowmeter logs, field water quality data, and well construction details shall be compiled and submitted 46 l Section 3: Field Notifications Data Collection and Reporting

to the Agencies within 60 days of completion of each well cluster. Geophysical logs shall be provided electronically in a PDF and LAS formats. In addition, a summary of well drilling procedures, geophysical logging procedures, and instrumentation used shall be provided.

Based on wells installed from this monitoring effort and other subsurface geologic data, scaled geologic cross-sections, including macroporosity zone and geophysical log overlays, shall be generated and included in the report. This includes information from the induction logs, which reveal zones of saline water. Also, a plan view map showing the location of significant features shall be included. The information generated from this report will be used to enhance understanding of groundwater movement in the area and may be used to aid in the interpretation of tracer suite and water quality monitoring data. The final geology and hydrogeology report shall be signed and sealed by a Florida-licensed geologist experienced in hydrogeologic investigation.

3.6.4.1 Biscayne Bay Geophysical Survey Report Biscayne Bay geophysical surveys shall be initiated within three months after the Biscayne Bay wells are installed. Results from these wells shall be used to estimate salinity from resistivity values. Results from resistivity survey shall be reported within six months of completion of a survey. Reports shall include a detailed description of methodology, maps showing GPS-derived survey track line locations, and figures showing depth profiles of resistivity along track lines, and any associated measurements along the track line. Best estimates of salinity or conductivity, derived from resistivity and all available salinity or conductivity data shall be made with tabular documentation of data and calculations used for this estimate (in .xls or .xlsx format). All geophysical survey data shall be supplied to the Agencies as raw tabular data, as well as processed graphical output, and all geophysical survey reports shall be signed and sealed by a Florida-licensed geologist experienced in geophysical interpretation.

3.6.5 Initial Ecological Condition Characterization Report Initial information on salinity distribution shall be derived from porewater surveys of the freshwater and saline wetlands adjacent to the CCS and Biscayne Bay and Card Sound.

Results from these surveys shall be detailed in a report within one year of Plan approval. The report shall provide a detailed description of all sampling and analysis methods, all data (including field and laboratory measurements, with QA/QC results, such as instrument blanks and calibrations), the GPS coordinates of all sites sampled, and a map showing site locations. Climatic data from the previous month as recorded by onsite or nearby instrumentation (rain data, air temperature, etc.) shall also be indicated in the report. Results, including any calculations generated from the data, shall be provided in a spreadsheet (.xls or

.xlsx format). The details and supporting data for specific transect establishment (i.e.,

wetland and Biscayne Bay) shall be included in this report. Field observations shall be recorded by photographs in field logs, specifying the dates and GPS coordinates, which shall also be provided in the report. The report shall identify areas of CCS water connectivity with surface sediments and soils as indicated by the CCS tracer suite, and discuss evidence FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 47

concerning the potential ecological influence of the CCS. Timelines and status of completeness for any other elements of the ecological monitoring shall also be included.

3.6.6 Semiannual and Annual Comprehensive Monitoring Reports Semiannual and annual reports shall be provided to the Agencies during the pre-Uprate and post-Uprate monitoring periods. Comprehensive semiannual monitoring reports shall be submitted for documentation of site conditions, data generated as part of Plan implementation including but not limited to, groundwater monitoring, surface water monitoring, CCS monitoring, and ecological monitoring, as described in the Plan. The ecological component shall be a subsection of the report and shall provide all data generated in the report period as indicated in the Ecological Monitoring (Section 2.8), including all field and laboratory measurements made (with QA/QC results, such as instrument blanks and calibrations), the GPS coordinates of all sites sampled, and a map showing site sampling locations. The data and any calculations generated from the data shall be provided in electronic format (.xls or .xlsx format). The column headings and format will be specified by the SFWMD.

The report(s) shall be submitted within 90 days of the completion of each monitoring period (wet season [June through November] and dry season [December through May]) and include quarterly and semiannual monitoring results of the previous periods. The report(s) shall include a brief summary of the CCS operations and operational changes that result in changes in physical or chemical characteristics of cooling water effluent or flow rates. A description of monitoring activities, station modifications and station operational summaries, graphic summaries of electronic monitoring data with electronic data archives, spreadsheet summaries of physical parameters, sample results, sampling field forms and laboratory results, L-31E salinity profile reports, monitoring well induction logging reports, and ID monitoring logs shall be included. Annual reports submitted during the post-Uprate monitoring period shall include conclusions regarding change from the pre-Uprate monitoring period.

The collected monitoring information, shall be used to provide an analysis of the following, to the extent supported by the data: 1) estimates of the spatial extent of CCS derived plume migration and the rate and direction of this migration; 2) for a given location outside of the CCS, an estimated percent contribution of waters originating from the CCS (based on a comparison of tracer suite constituent concentrations and other select chemical constituent concentrations in CCS waters, with concentrations of such constituents in surface water and groundwater outside of the CCS); and 3) estimates of the quantity of water and salt load that the CCS produced based on the updated CCS water budget. The report shall include recommendations for installation of additional monitoring points or other Plan modifications if needed to complete the monitoring objectives. The report(s) shall include a completeness evaluation of specific Plan objectives and an updated monitoring schedule.

48 l Section 3: Field Notifications Data Collection and Reporting

To estimate the rate at which water is transported or dispersed from the CCS, a water budget analysis shall be performed (Section 2.6). The results of the bathymetric survey, CCS characterization, water budget, and salt and ionic loads shall be included in the Water Budget Analysis Report. This report shall be generated annually. Following collection of data during the pre- and post-Uprate period, the salt and ionic loads shall be reassessed to see if there are any significant changes from the pre-Uprate period.

The water budget report shall include a breakdown for each of the contributions as described in Section 2.6.3 (Water Budget Calculations).

3.6.7 Comprehensive Pre-Uprate Report A comprehensive Pre-Uprate Final Report shall be submitted for documentation of background conditions before implementation of the Uprate project. The report shall include summaries of data presentations included in semiannual reports with trends analysis, including incorporation of seasonal or other variations over the pre-Uprate monitoring period. The data and any calculations generated from the data shall be provided in electronic format (.xls or .xlsx format). The column headings and format will be specified by the SFWMD. To meet the objectives, the report shall include a completeness evaluation of specific Plan objectives and recommendations for additional investigation, if appropriate.

The comprehensive Pre-Uprate Final Report will take the place of one of the annual reports.

FPL Turkey Point Power Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 49

50 l Section 3: Field Notifications Data Collection and Reporting 4

Schedule Within 60 days after the approval of the Plan (effective date of the 2009 Agreement), FPL shall submit a monitoring schedule with a detailed breakdown of timelines for implementation of monitoring components and plant Uprate activity.

Permits for installing monitoring wells and instrumentation in Biscayne National Park must be obtained and entities to conduct the work selected. It is envisioned that it will take at least six months to drill all wells, purchase instrumentation, set up the monitoring network, and be fully operational.

The Uprate project is expected by FPL to come online in the spring of 2012. Two years of data collection during the pre-Uprate (as defined in Section 1) is expected. Pre-Uprate monitoring shall continue until commencement of the Uprate. Post Uprate monitoring, as may be modified, shall continue for a time period as specified by the Agencies. During this time, both automated and manual data collection shall be conducted.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 51

52 l Section 4: Schedule References Cited APHA. 1998. Standard Methods for the Examination of Water and Wastewater. Prepared and Published Jointly by the American Public Health Association, American Water Works Association, and the Water Environmental Federation. 20th Edition, 1998.

Bellmund, S., A. Renshaw, A. Mayoral, H. Jobert, C. Tilghman. 2007. Salinity Sampling in Biscayne Bay (2005-2006). A Report to the U.S. Army Corps of Engineers for the Monitoring and Assessment Plan of the Comprehensive Everglades Restoration Plan.

151.

Cunningham K. J., J.I. Carlson, and N.F. Hurley. 2004. New Method for Quantification of Vuggy Porosity from Digital Optical Borehole Images as Applied to the Karstic Pleistocene Limestone of the Biscayne Aquifer, Southeastern Florida. Journal of Applied Geophysics, 55:77-90.

Cunningham, K. J., R.A. Renken, M.A. Wacker, M.R. Zygnerski, E. Robinson, A.M. Shapiro, and F.L. Wingard. 2006a. Application of Carbonate Cyclostratigraphy and Borehole Geophysics to Delineate Porosity and Preferential Flow in the Karstic Limestone of the Biscayne Aquifer, SE Florida. In: Harmon, R. S., and Wicks, C., eds., Perspectives on Karst Geomorphology, Hydrology, and Geochemistry - A Tribute Volume to Derek C.

Ford and William B. White, Special Paper, Geological Society of America, 404, 191-208.

Cunningham, K. J., M.A. Wacker, E. Robinson, J.F. Dixon, and F.L. Wingard. 2006b. A Cyclostratigraphic and Borehole Geophysical Approach to Development of a Three-Dimensional Conceptual Hydrogeological Model of the Karstic Biscayne Aquifer, Southeastern Florida. U.S.

Geological Survey Scientific Investigations Report 2005-5235, 69.

Cunningham, K. J., M.C. Sukop, H. Huang, P.F. Alvarez, H.A. Curran, R.A. Renken, and J.F. Dixon. 2009. Prominence of Ichnologically Influenced Macroporosity in the Karst Biscayne Aquifer: Stratiform Super-K Zones. Geological Society of America. In Press. Vol.

121(1-2), 164-180.

Fish, J.E. and M. Stewart. 1991. Hydrogeology of the Surficial Aquifer System of Dade County, Florida. USGS Water Resources Investigation Report 90(4108):50. U.S. Geological Survey, Tallahassee, FL.

Fitterman, D.E. and M. Deszcz-Pan. 2001. Saltwater Intrusion in Everglades National Park, Florida Measured by Airborne Electromagnetic Surveys. In First International Conference on Saltwater Intrusion and Coastal Aquifers Monitoring, Modeling, and Management, Essaouira, Morocco, April 23-25, 2001.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l 53

Fourqurean, J.W., M.J. Durako, M.O. Hall, and L.N. Hefty. 2002. Seagrass Distribution in South Florida: A Multi-agency-Coordinated Monitoring Program. In The Everglades, Florida Bay, and Coral Reefs of the Florida Keys: An Ecosystem Sourcebook, eds. J.W.

Porter and K.W. Porter. CRC Press, Boca Raton, FL, 497-522.

Robblee, M.B. and J.A. Browder. 2008. 2008 Assessment Update: Pink Shrimp Indicator for the Southern Estuaries. U.S. Geological Survey, Center for Water and Restoration Studies and NOAA Fisheries Service, Southeast Fisheries Science Center. Available from:

http://www.sfrestore.org/scg/scg_meetings/2008_meetings/092508/Pink%20Shrimp

%20ASSESSMENT%202008.pdf State of Florida Division of Administrative Hearings (DOAH). 2008. Miami-Dade Countys Preliminary Statement of Issues, Case No. 08-0378-EPP. Florida Department of Environmental Protection (FDEP) OGC Case No. 07-2624.

Swarzenski, P.W., W.C. Burnett, Y. Weinstein, W.J. Greenwood, B. Herut, R. Peterson, and N. Dimova. 2006. Combined Time-Series Resistivity and Geochemical Tracer Techniques to Examine Submarine Groundwater Discharge at Dor Beach Israel.

Geophysical Research Letters, 33, L24405, doi:10.1029/2006GL028282.

54 l References Cited

A FDEPs Conditions of Certification IX and X Related to the FPL Turkey Point Power Plant Uprate IX. Biscayne Bay Surface Water Monitoring As proposed, the Turkey Point Units 3 and 4 Uprate project may cause an increase in temperature and salinity in the cooling canal system. Field data is needed to determine impacts of the proposed changes in the Turkey Point cooling canal system on Biscayne Bay.

A. Within 180 days following certification of Units 3 & 4, FPL shall submit a Biscayne Bay Surface Water Monitoring Plan (Plan) pursuant to Chapter 62-302, F.A.C. to the FDEP Southeast District Office for review and approval. The Plan shall include, at a minimum, the following components:

1. salinity and temperature monitoring within the surface waters of the Bay, including the Biscayne Bay Aquatic Preserve; (Specific parameters to be measured, including specific conductance and temperature, shall be sampled in accordance with Chapter 62-160, F.A.C.);

2. a minimum of five monitoring stations located near shore in the vicinity of the FPL Turkey Point Power Plant; and three specific monitoring locations, sampling frequencies and methods, and specific parameters to be monitored.

3. specific monitoring locations, sampling frequencies and methods, and specific parameters to be monitored.

B. This monitoring data shall be compared to data using compatible monitoring instrumentation already in place in Biscayne Bay.

C. FPL shall continue the monitoring of salinity and temperature in the cooling canals under its industrial wastewater facility permit.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l A-1

D. If the Department determines that the pre- and post-Uprate salinity and temperature monitoring data indicate potential adverse changes in the surface water in Biscayne Bay, then the Department may propose additional measures to evaluate or to abate such impacts to Biscayne Bay.

E. The Plan, including monitoring locations, shall be approved prior to implementation.

The Department shall indicate its approval or disapproval of the submitted Plan within 90 days of the originally submitted information. In the event that the Department requires additional information for the licensee to complete, and the Department to approve the Plan, the Department shall make a written request to the licensee for additional information no later than 30 days after receipt of the submitted information. Any changes to the approved Surface Water Monitoring Plan shall be approved by Coastal and Aquatic Managed Area personnel in consultation with other FDEP personnel. [62-160,62-302, 62-302.700,62-520.600, F.A.C.]

X. Surface Water, Groundwater, and Ecological Monitoring This is a consolidated condition agreed upon by three Agencies: Department of Environmental Protection (FDEP), Miami-Dade County Department of Environmental Resource Management (DERM), and the South Florida Water Management District (SFWMD). This consolidated condition sets forth the framework for new monitoring and, as may be needed, abatement or mitigation measures, for approval of FPLs Turkey Point Units 3 and 4 Uprate Application. Specific monitoring and potential modeling parameters will be identified and implemented pursuant to a monitoring plan as part of a supplemental agreement between FPL and the SFWMD as described as follows.

A. In addition to the monitoring framework set forth in this consolidated condition, within 180 days after Certification, FPL shall execute a SFWMD approved Fifth Supplemental Turkey Point Agreement (Fifth Supplemental Agreement) to the original 1972 Agreement between FPL and the SFWMD pertaining to FPLs obligation to monitor for impacts of the Turkey Point cooling canal system on the water resources of the SFWMD in general and the facilities and operations of the SFWMD (the "Agreement"). Subject to the SFWMD's approval, FPL shall also amend the Agreement's Revised Operating Manual as referenced in Paragraph C Monitoring Provisions (the Revised Plan) of the Fourth Supplemental Agreement, dated July 15, 1983. The Revised Plan shall be incorporated into the Fifth Supplemental Agreement and shall include assessment of potential impacts to surface water and groundwater, including wetlands, as needed, in the vicinity of the cooling canal system. The specific monitoring boundaries shall be determined as part of the Revised Plan.

A-2 l Appendix A

B. The Revised Plan shall be designed to be in concurrence with other existing and ongoing monitoring efforts in the area and shall include but not necessarily be limited to, surface water, groundwater, and water quality monitoring, and ecological monitoring to:

1. delineate the vertical and horizontal extent of the hyper-saline plume that originates from the cooling canal system and to characterize the water quality including salinity and temperature impacts of this plume for the baseline condition;

2. determine the extent and effect of the groundwater plume on surface water quality as a baseline condition; and

3. detect changes in the quantity and quality of surface and groundwater over time due to the cooling canal system associated with the Uprate project. The Revised Plan shall include installation and monitoring of an appropriate network of wells and surface water stations. The Revised Plan shall be approved by the SFWMD in consultation with the FDEP Office of Coastal and Aquatic Managed Areas, the FDEP Southeast District Office, and DERM.

C. FPL shall transmit electronic copies of all data and reports required under the Fifth Supplemental Agreement and the Revised Plan in accordance with timeframes as approved in the Fifth Supplemental Agreement to:

1. SFWMD, Director, Water Supply (or alternative transmittal procedures to be described in the Fifth Supplemental Agreement);

2. Miami-Dade County, Director, DERM; FDEP, Director, Southeast District Office;

3. FDEP Siting Coordination Office;

4. FDEP, Director, Biscayne Bay Aquatic Preserve Manager D. If the FDEP in consultation with SFWMD and DERM determines that the pre- and post-Uprate monitoring data: is insufficient to evaluate changes as a result of this project; indicates harm or potential harm to the waters of the State including ecological resources; exceeds State or County water quality standards; or is inconsistent with the goals and objectives of the CERP Biscayne Bay Coastal Wetlands Project, then additional measures, including enhanced monitoring and/or modeling, shall be required to evaluate or to abate such impacts. Additional measures include, but are not limited to:

1. the development and application of a 3-dimensional coupled surface and groundwater model (density dependent) to further assess impacts of the Uprate Project on ground and surface waters; such model shall be calibrated and verified using the data collection during the monitoring period; FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l A-3

2. mitigation measures to offset such impacts of the Uprate Project necessary to comply with State and local water quality standards, which may include methods and features to reduce and mitigate salinity increases in groundwater including the use of highly treated reuse water for recharge of the Biscayne aquifer or wetlands rehydration;

3. operational changes in the cooling canal system to reduce any such impacts; and/or

4. other measures to abate impacts as may be described in the Revised Plan.

[Sections 373.016, 373.223, F.S.; Rules 40E-4.011, 40E-4.301, 40E-4.302, F.A.C.; Sections62-302 and 62-520, F.A.C.; Section 24-42, Code of Miami-Dade County, Miami-Dade County Comprehensive Development Master Plan (CDMP) Land Use Element, Conservation Element, Intergovernmental Coordination Element, Coastal Management Element.]

A-4 l Appendix A

B Near Shore Sonde Deployment Methods The near shore sites, or mangrove sites, have sondes deployed to measure salinity using differing methods. This is due to the extremely shallow water at these locations, as well as the composition of the bottom substrate. Normally the sondes are deployed in a vertical position attached to a mooring pin, which has been cemented in place by drilling a hole in the bay floor. However, at the mangrove sites, there is insufficient water for vertical deployments, so the instruments are deployed horizontally, and the bottom is composed mainly of mud, which is unsuitable for drilling. Therefore, the instruments are deployed affixed to cement paving slabs, which have been drilled in two places at opposing corners and fitted with stainless steel eyebolts that settle into the mud, with the eyes of the eyebolts well above the bottom and in the water column. The sonde is then locked to one of the eyebolts and fastened securely to both using nylon tie-wraps. This maintains a constant horizontal position, which will remain beneath the water surface even at low tide. This positioning also provides ample space for an additional sonde to be mounted simultaneously for concurrent sampling and overlapping data at deployment and retrieval times to ensure quality control. Per instruction by YSI personnel, the instruments are oriented in a way such that the sensor's hole is not facing directly down, which could cause air bubbles to accumulate and skew the salinity data.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l B-1

B-2 l Appendix B C

Survey Parameters Collected during Groundwater and Surface Water Investigations Data collected from the survey of the groundwater monitor well, and surface water sites shall include, but not be limited to the following:

• Latitude

• Longitude

• State Planar Coordinates North American Datum of 1983 (NAD), Florida East zone

• State Planar Coordinates NAD of 1927, Florida East zone

• Natural Ground Surface Elevation Elevation in North American Vertical Datum of 1988 (NAVD)

Elevation in National Geodetic Vertical Datum of 1929 (NGVD)

• Elevation of bottom of surface water location Elevation in NAVD Elevation in NGVD

• Monitor Well Top-of-Casing Elevation Elevation in NAVD Elevation in NGVD

• Elevation of any nearby standing surface water at the time of surveying (15 feet radius from site)

An electronic copy of the field notes, an electronic copy of all computation sheets, site photographs, a surveyor report, and benchmark sheets shall also be included.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l C-1

C-2 l Appendix C D

Special Requirements for an Electromagnetic Induction Well In general, the groundwater monitoring wells shall meet normal State or Federal Regulations for monitoring wells. The USGS publication WRIR-96-4233, located on the Web, available at (http://water.usgs.gov/owq/pubs/wri/wri964233/), provides general guidelines for the installation of monitoring wells used to evaluate water quality. In addition to these general guidelines, there are some special requirements needed for a well to be logged using an electromagnetic induction probe, including:

Casing material PVC - Metal casing will interfere with the log.

Well Screen PVC - Metal screens will interfere with the log.

Well diameter generally 2 to 6 - The USGS is currently logging wells 2 to 6 in diameter. For shallow wells, 2 is acceptable. For deep wells (>150 feet), the USGS suggests 3 or 4 well diameters to make sure the probe does not get stuck. The probe is most sensitive to differences in conductivity within an 8 to 40 donut-shaped radius around the well because of bends or distortions in well casing.

Depth extending to the base of the Biscayne aquifer - This allows evaluation of changes throughout the zone of interest. Salinity is usually but not always highest at the base of the aquifer; this is generally a good depth to set the open interval. The driller needs to be careful not overshoot the bottom of the aquifer.

If the monitoring well is to be used for detecting upconing directly beneath a wellfield, there are alternate strategies. If only fresh water is found when drilling, finish the well at the base of the aquifer. Future upconing would most likely begin at or near the base of the aquifer.

If salt water is found when drilling, one can: (1) Stop drilling and screen the well at this depth so that the chloride level can be monitored at this depth, or (2) Keep drilling to the base of the aquifer and complete the well at this depth to evaluate the full thickness of encroachment and maximum salinity. This would allow one to determine if seawater is encroaching preferentially through just one zone or throughout the depth of aquifer. Either FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l D-1

way, induction logging can help detect future upconing. Option 2 describes what is happening in the aquifer, but Option 1 provides the ability to obtain a precise chloride value in mg/l.

Open Interval 5 to 10 feet - The idea of a short screen length is to be able to sample a discrete interval and avoid the effects of flow within the borehole.

Chloride Sampling - It is generally good to collect water chloride samples during drilling to determine if encroached seawater is present.

Annular Seal - Neat Cement is the best type of annular seal. A seal just above the filter pack is necessary to prevent the cement from infiltrating the filter pack. A very fine sand or bentonite is proven means of isolating the well screen.

Manhole cover - Metal is acceptable at the top of well, but no metal should be used down the hole or on the casing.

Well centralizers - Well centralizers are only acceptable if they are non-metallic; metallic screws used for well centralizers can cause problems.

Flush Mounted Finish This is usually best because the logging requires setting a tripod over the well.

Clustered wells - If wells are too close together, and one has a metal object in it, this can affect the log in the other well.

Well development - The well should be developed to clear and consolidate the filter pack.

This also needs to be done to ensure that cement did not seep into the filter pack and clog it, as well as to verify that the well is not in an impermeable zone. Well development should be performed to clear up the hole prior to well installation. If there is a lot of mud or muddy water in the hole, the first few logs might detect this. Do not use salty or electrically conductive drilling fluid.

D-2 l Appendix D

E Tritium Sample Collection and Analysis Protocols Introduction The measured tritium values along with a measure of salinity (salinity, conductivity, or chlorinity) will be used in a ternary mixing model that will estimate the proportion of the three potential end members in the sample, CCS water, BBSW, and fresh groundwater. Most of the influence of the CCS on the groundwater will be through the sub-surface connection between the CCS and the Biscayne aquifer. It is possible that tritium-enriched rainfall, which originates from evaporated CCS water, could be deposited in the area immediately surrounding the CCS. Measurements of tritium in rainfall will be used to determine if tritium-enriched rainfall is occurring. If it is, the amount of this rainfall, and thus tritium, that reaches the aquifer will be estimated by taking into account the extent to which rainwater is recycled back into the atmosphere. These measurements and calculations, and other available data as applicable will be used to determine if an adjustment is needed in what is considered background levels of tritium for groundwater surrounding the CCS.

Sample Collection and Analysis of Tritium Samples for tritium analysis will be collected in 1-L high-density polyethylene bottles. Water can be transferred into the sample bottles using any type of sampling pump. The sample bottles do not require rinsing before filling. Sampling personnel shall not wear luminous watches because these watches can contain relatively large amounts of tritium, which would contaminate the water sample. The samples will not be filtered. Samples will be stored and transported at room temperature. Each sample will at a minimum be labeled with the sample location, collection date and time, and samplers name. All groundwater and surface water stations (7 samples in the CCS at varying depths) identified in this Monitoring Plan will be sampled for tritium quarterly. In addition to these samples, rainfall samples will be collected from at least nine stations (discussed as follows). These rainfall samples will be used to assess whether deposition of evaporated CCS water could contribute detectable amounts of tritium via rainfall to the surface and groundwater surrounding the CCS.

The detection limit for tritium analysis shall be <10 pCi/L for groundwater and surface water samples, except as specified below. The analytical uncertainty measurement will be

<10 pCi/L or +/-3.5 percent, whichever is larger, and the methodology used for this analysis shall be consistent with these requirements. The laboratory performing the low-level tritium FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l E-1

analyses will participate in the International Atomic Energy Agencys tritium inter-laboratory comparison study. This proficiency testing program is carried out every four years using standards ranging in activity from <1 pCi/L to ~2000 pCi/L. The laboratory shall maintain active participation in the proficiency testing program. FPL shall propose specific tritium analytical techniques in the QA/QC plan, including the method detection limit and the uncertainty associated with the method, for review and approval by the Agencies.

During the initial monitoring period over the first year, a test methodology with a 10-pCi/L detection level will be used for all monitoring wells and surface water outside the CCS.

Detection levels for sampling within the CCS will initially be at 350 pCi/L. The adaptive monitoring approach will be used to identify appropriate changes in detection levels for specified locations.

After the first year of sampling adjustments to detection levels may be implemented if surface water samples from the CCS and wells very close to the CCS (i.e., L3 and L5) and directly underneath the CCS, have tritium levels well above the detection limits of 350 pCi/L. An acceptable alternative method would be direct liquid scintillation counting (LSC),

which has a detection limit of 350 pCi/L. It is possible that some other groundwater and surface water samples will have consistent tritium values well above the lower detection limit of 10 pCi/L. If a site has been established to have a tritium concentration >700 pCi/L by four consecutive samplings over a one-year period, then future samples may be analyzed by the LSC, or equivalent, method upon the notification and approval of the Agencies.

If eight quarterly samples taken over a two-year period from a particular groundwater or surface water sampling site indicate that the tritium concentration of these samples is < 15 pCi/L or background as determined by the Agencies, then tritium sampling at that site may be discontinued. As long as the chloride concentration of the samples collected at said sampling site remains below 250 mg/L, tritium does not need to be sampled. If chloride concentrations rise above 250 mg/L, then tritium sampling shall be resumed for a time period to determine if the source of the increased chloride is attributable to the CCS.

Tritium Measurements in Rainfall FPL shall conduct an evaluation of the extent of influence of local rainfall on tritium levels in groundwater and surface water for purposes of providing additional data for identification of background levels of tritium. Eight rainfall collection stations will be co-located with monitoring well clusters north, east, south, and west of the CCS (shown in Figure E-1).

One collector will be located to the north and one to the south. One collector will be located in Biscayne Bay to the east. One collector will be located adjacent to the L-31E Canal, two collectors will be located approximately two miles west of the plant, and two collectors will be located approximately four miles west of the plant. Collected rainfall data will be analyzed for a period of one year, and determination of future sampling will need to be assessed. After the testing period, based on all available information, a scientifically based level(s) of tritium in rainfall shall be identified across the area.

E-2 l Appendix E

Rainfall Sample Collection Protocols The following protocols shall be used for rainfall sample protection:

• Rainfall collectors will be sampled four times per year.

• Rainfall collectors will be deployed at the sampling locations continuously, and will be designed to integrate samples collected during a three-month time period.

• At the end of every three-month sampling period, collected rainfall will be sent to the laboratory for tritium analysis. Tritium rainfall averages have been reported <10 pCi/L, therefore a laboratory detection limit of <10 pCi/L shall be used for rainfall analysis. If the concentrations of tritium in the rainfall are less than or equal to the MDL, any rainfall contributions of tritium shall be considered negligible.

• Data will be correlated with either local (temporary setups alongside rainfall collectors) or nearby micrometeorological stations.

• If tritium is observed in the shallow (<30 feet deep) monitoring wells, sampling of porewater may be conducted to determine directionality of tritium movement in the ground.

FPL Turkey Point Plant Groundwater, Surface Water, & Ecological Monitoring Plan l E-3

Figure E-1 Rainfall collection stations.

E-4 l Appendix E