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{{Adams
#REDIRECT [[L-2018-015, Plan of Study 316(b) Implementation]]
| number = ML18036A212
| issue date = 04/28/2017
| title = St. Lucie, Plan of Study 316(b) Implementation
| author name = Cibik S J
| author affiliation = Environmental Consulting & Technology, Inc
| addressee name =
| addressee affiliation = Florida Power & Light Co, NRC/NRR
| docket = 05000335, 05000389
| license number =
| contact person =
| case reference number = ECT 150595-ASOO, L-2018-015
| package number = ML18036A180
| document type = Report, Technical
| page count = 48
}}
 
=Text=
{{#Wiki_filter:! I
* PLAN 0-F STUDY 316(b) IMPLEMENTATION ST. LUCIE POWER PLANT Prepared for: Juno Beach, FL PrepaFed by: 7208 Falls of Neuse Road, Suite 102 Raleigh, North Carolina 27615 ECT No. 150595-ASOO Version 1.0 Last Updated: April 28, 2017 Florida Power & Light Company St. Lucie Power Plant Plan of Study 316(b) Implementation DOCUMENT REVIEW The dual signatory process is an integral part of Environmental Consulting
& Technology, Inc.'s (ECT's) Document Review Pelicy No. 9.03. All ECT documents undergo nical/peer review prior to dispatching these documents to any outside entity. This document has been authored and reviewed by the following employees:
Stephen J. Cibik Mark W. Gerath Author -Peer Review ;:_>!'14/~:-*':-.* ;~. . . . . .. :._. . . . Signature Signature April 26, 2017 April 26, 2017 Date Date N:IPRJ\FPL\3
!6(B) SUPPORTIINDIVIDUAL Pl.ANT FILESIST.
LUCIEIFINAL POS1STLUC3 I 6BP0S.DOCX--OJ 0218 1 Florida Power & Light Company St. Lucie Power Plant Plan of Study 316(b) Implementation TABLE OF CONTENTS Section Page
 
==1.0 INTRODUCTION==
 
1 2.0 l?ROJECT MILESTONES 2 J:O PROCESS OVERVIEW 3 3.1 DEFINITION OF CRITICAL PA-'TH ITEMS 3 3.1.1 2017 TO 2018 3 3.1.2 2017 3 3.1.3 2019 AND 2020 5 3.1.3.l Im12ingement BTA. and Com12letion of 316(b) Re12orts 5 3.1.3.2 Execution ofEntra1nment BTA Analyses Including Peer Review 5 3.1.4 POSTSUBMITTAL 5 3.1.5 TIMING OF IMPINGEMENT BTA ASSESSMENT 5 3.2 ENTRAINMENT CHARACTERIZATION 6 3.3 ENTRAINMENT-BTA ASSESSMENT
_6_ 33.1 MEASURES TO-BE CONSIDERED 6 3.3.2 ENTRAINMENT ASSESSMENT PROCESS OVERVIEW 7 3.3.3 PEER REVIEW PROCESS 7 3.3.4 PEER REVIEWER SELECTION 10 4.0 PROJECT TEAM 12 APPENDIX A-ENTRAINMENT CHARACTERIZATION-STUDY PLAN N:IPRJ\FPL\3 I 6(B) SUPPORT\IND!VIDUAL PLANT FlI.ES\ST.
LUCIEIFINAL POS\STLUC3
!6BP0S.DOCX--010218 11 Florida Power & Light Company St Lucie Power Plant LIST OF TABLES IWWF Permit Milestones for 316(b) Rule Compliance Plan of Study 316(b) Implementation 2 2 St. Lucie Power Plant 316(b)Compliance Project Key Staff Contacts 12 Figm:e.. 1 2 LIST OF FIGURES EntraiTu-nent BTA Assessment Process 0verview St. Lucie Anticipated Project Schedule N:\PRJ\FPL\3 l 6(B) SUPPORnINDIVIDUAL PLANT FILESIST.
LUCJE\FINAL POS\STLUCJ
! 6BPOS.DOCX-Ol 0218 lll 9 11 -EC7 Florida Power & Light Company St. Lucie Power Plant Plan of Study 316(b) Implementation LIST OF ACRONYMS AND ABBREVIATIONS AlF BTA CFR CWIS FDEP FPL IM IWWF MGD POS Actual intake flow best technology available Code of Federal Regulations cooling water intake structure Florida Department of Environmental Protection Florida Power & Light Company Impingement mortality industrial wastewater facility Million gallons per day plan of study N:\PRJ\FPL\316(B)
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LUCIEIFINAL POS\STLUC316BPOS.D0CX--Ol 0218 lV Florida Power & Light Company St. Lucie Power Plant 1.0 JNTRODUCTION Plan of Study 316(b) Implementation Florida Power & Light Company's (FPL's) St. Lucie power plant holds industrial wastewater facility (IWWF) permit No. FL0002208, issued on November 4, 2016. permit includes a requirement to meet with Florida Department of Environmental tion (FDEP) within three months of the effective date of the permit to discuss FPL's plan for compliance with i:he 316(b) rule. The meeting, c0nclucted by teleconference on ary 19, 2017, addressed applicable requirements under Title40, Part 122.2l(r), Code of Federal Regulations ECFR); previous data or studies to be used as part of the 40 CPR 122.2l(r)_compliance effort; and proposal for a peer review group. This meeting is to be followed by submittal of a plan of study (P0S) within six months of the permit's effective date (i.e., by May 4, 2017) "to address the timely-implementation of the 3 l 6(b) ... regulations" to include a schedule for the submittal "of all applicable 122.21 (r) forms, any associated reports, and peer review documentation." The materials are to be submitted as soon as practicable but no later than 180 days prior to the expiration date of the permit. This document provides the POS-calkd for by the IWWF requirement.
Note this document includes, as Appendix A, the propgsed entrainment characterization study plan. The study plan includes summary information on the St. Lucie plant's cooling water intake--straeture (CWIS) configuration, previous impingement and entrainment study results, and proposed sampling and analysis-methodologies.
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LUCIE\FINAL POSISTLUC3 I 6BPOS.DOCX--010218 1
Florida Power & Light Company St. Lucie Power Plant Plan of Study 316(b) Implementation
 
===2.0 PROJECT===
MILESTONES The IWWF permit includes milestones for implementation of 316(b) rule lated activities at the St. Lucie plant (Table 1). The following sections define activities FPL believes represent criticar path-items and presents a schedule for implementation of these items consistent with milestones defined in the IWWF permit. Tab-le 1. IWWF-Permit Milestones-for 316(b) Rule Compliance Milestone IWWF pennit is effective Meeting with FDEP Submit 316(b)-P0S Submit 3 l 6(b) reports Source:-ECT, 2017. Notes Within-tlrree months of permit effective date Within six months of the permit effective date Not later than 180 days before expiration of IWWF permit, with the permit renewal cation N:\PRJ\FPL\316(B)
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LUCIEIFINAL POS\STLUC316BP0S.DOCX-010218 2 Date 1 U04/16 02/04/17 05/04/17 05/07/21 Florida Power & Light Company St. Lucie Power Plant 3.0 PROCESS OVERVIEW Plan of Study 316(b) Implementation This section reviews the anticipated implementation process for the final rule that is sistent with the schedule constraints to be defmed in the IWWF permit, as well as specific issues such as data availability.
 
===3.1 DEFINITION===
 
OF CRITICAL PATH ITEMS Critical path items are those items that must be completed in a timely manner to provide information needed for the assessments to be included in the renewal application to be submitted in May 2021 . .The following is a brief discussion of the projecLelements-that represent the critical path, organized by the year in which they are expected to occur. These elements are represented on the project schedule as presented in the following subsecti0ns.
3.1.1 2017 TO 2018 Characterization of the rates of entrainment for the site-specific entrainment best ogy available (BTA) assessment, including the nature of the entrained fish and shellfish, is a key project element and, under the rule, must include two years' worth of data ment data. To a_gr_eat extent, analyses of costs and benefits for-the BTA assessment depend on the nature of entrainment and completion-( with documentation)-
of this effort. For this reason, important and complex elements of the project cannot-be completed until the full set of entrainment data is available.
A-Second year of entrainment data collection is uled to begin in November 2017 to supplement the 20 months of data collected the Phase II rule, and the field element of the program is expected to be completed in October 2018. Laboratory analysis and preparation ofreports will take several months after the field work is completed.
Therefore, the program elements that depend on-entrainment data cannot begin in earnest until mid-2019.
3.1.2 2017 The 2017 time frame includes identification and FDEP approval of peer reviewers.
The final rule's requirement for peer review of the entrainment BTA assessment constitutes an important critical path item, in that peer reviewers must be identified by the permittee and N:IPRJ\FPL\3 J 6(B) SUPPORT\INDIVIDUAL PLANT FJLESIST.
LUCJE\FINAL POSISTLUC316BP0S.DOCX-Ol 0218 3 
. Florida Power & Light Company St Lucie Power Plant Plan of Study 316(b} Implementation approved by FDEP. Once this selection process has been completed, the entrainment sessments must be mapped out, coordinated, and completed under a defined schedule, and peer reviewers must c0mmit to providing a timely review. FPL must then aevelop port required under 40 CFR 122.2l(r)(l3)that responds to the peer reviewers' comments and provides justification for any comments not addressed.
The impingement BTA proach nmst then be reconciled with the findings of the entrainment BTA and the 40 CFR 122.2l(r)(6) reportfmalized.
These steps must be compieted-sufficiently in vance of the application date for FPL to review and incorporate the findings-into its renewal application.
FDEP approved FPL's proposed peer reviewer for biology-(Dr.
Steven bayman) in early June 2016. FPL-proposed*peer reviewers to FDEP for engineering and economics in a letter sent March 1, 201 7, so they can be engaged in ffi.e planning of the entrainment B TA prncess to avoid adverse com.rnents late in the process. FPL notes the rule does not require peer review of the entrainment work plan or entrainment characterization report under 40 CFR 122.2l(r)(9).
Despite this, Dr. Layman has reviewed and commented on the FDEP-approved entrainment characterization study plans developed for Fort Myers and other FPL once-througp.
plants upon which this plan is modeled. 2018 AND 2019 Preliminary planning of the entrainment BIA process should begin in 2018 and continue into early 2019. The complex nature of the analyses to support assessment of entrainment BTA (discussed furtheF in the next subsection) aiso represents a critical path item. The rule is expansive in including a nu..'Ilber of factors that "must" or "may" be considered by FDEP when evaluating entrainment BTA. These faetors include environmental, economic, logical, and engineering disciplines.
These may also include factors well beyond the boundaries of the plant. Mapping out the assessment process should be undertaken to sure it is complete as the entrainment data become available in mid-2019.
N:\PRJ\FPL\316(B)
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LUCIE\FINAL POSISTLUC316BP0S.DOCX-OI 0218 4 Florida Power & Light Company St Lucie Power Plant 3.1.3 2019 AND 2020 3~1.3.l Impingement BTA and Completion of 316(b) Reports Plan of Study 316(b) Implementation Assessment of impingement BTA at St. Lucie is facil-itated by its use of offshore velocity caps, a preapproved technology_for impingement mortality (IM) BTA under the rule. ever; completion of the 316(b) reports will still be relatively involved and are plam1ed to be initiated by the fourth quarter of 2019. 3.1.3.2 Execution of Entrainment BTA Analyses Including Peer Review Execution of entrainment BTA analyses will be undertaken once the entrainment terization study has been completed and should be completed by mid-2020 to...allow review-by FPL-as well as the peer reviewers.
As noted previously herein, this work would -begin only after-a careful planning process, including appmval by FPL's pe-er reviewers.
Even with careful planning, this effort will be substantial, as it is highly integrated, disciplinary,-and-demands complex data and policy input from FPL. 3.1.4 POSTSUBMITTAL FPL anticipates discussions with FDEP, and potentially other agencies, will occur ing submittal of the documents by April 1, 2021. It is also anticipated
:B-DEP will include a condition and schedule...-i.11 the next permit (i.e., 2021 reissuance) for implementing any changes required-by the site-specific-entrainment BTA determination.
 
====3.1.5 TIMING====
OF Il\1PINGEMENT BTA ASSESSMENT The reports required under the final rule at 40 CFR 122.21(Jj, which encompass ance with both impingement-and entrainment standards, are nermally due with the cation for renewal otthe discharge permit. \Vhile the rule clearly anticipates si0n regarding entrainment -BTA should precede the determination of BTA for ment, The existing offshore velocity caps are compliant with IM BTA requirements. fore, FPL does not anticipate additional IM requirements and will submit the required umentation under 40 CFR 122.21(r)(6) with submission of the permit renewal application in 2021. N:IPRJ\FPL\3 J 6(B) SUPPORli!NDJVIDUAL PLANT FILESIST.
LUCIBIFINAL POSISTLUC316BPOS.DOCX-Ol0218 5
Florida Power & Light Company St. Lucie Power Plant 3.2 ENTRAINMENT CHARACTERIZATION Plan of Study 316(b} Implementation Appendix .kto this plan of study includes the entrainment characterization study_plan that will be executed at the St. Lucie plant to address requirements-of the rule. This effort sists of sampling every other week for_one year and will be patterned after the Phase II efforts at St. Lucie as well as programs being executed at other FPL plants in Florida. The overall approach (collecti-on gear, sampling frequency, and methods oflaboratory ment) was approved by FDEP for work previously executed at St. Lucie under the Phase II rule and, therefore, provides continuity with the prior efforts. 3.3 ENTRAINMENT BT A ASSESSMENT This subsecfa:m summarizes the process FPL will pursue to address the requirements of 40 CFR 122.2l(r)(9) through (13). These reports are all intended to_provide information to FDEP so the agency can reach a site-specific decision regarding BTA for entrainment.
While the rule calls-for-five separate reports that address d-ifferent factors relevant to trainment BTA, FPL believes the effort should integrate the relevant disciplines and analyses (see Section 3.4.2). 33.1 MEASURES TO BE-CONSIDERED The fmal rule requires facilities-with actual intake flow (.AIF) greater than 125 million lons per day (MGD) com,ider the technical feasibility,-costs, effectiveness, and benefits of the following alternative measures to reduce entrainment:
* Retrofitting to a closed-cycle recirculating cooling system.
* Use of fine mesh sereens with a mesh size of 2 millimeters or smaller. (Toe rule does not state whetner both fine mesh panels on traveling screen systems and wedgewire screens should be considered.
FPL intends to consider them both but notes constraints present in the source water are likely to make wedgewire screens far less favorable than changes to the existing traveling water screens.)
* Water reuse or alternative sources of cooling water. N:\PRJ\FPL\316(B)
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LUCIE\FJNAL POSISJLUC3 J 6BPOS.DOCX--OJ 0218 6 Florida Power & Light Company St Lucie Power Plant Plan of Study 316(b) Implementation
 
====3.3.2 ENTRAINMENT====
 
ASSESSMENT PROCESS OVERVIEW Under the rule, FDEP has the authority to-determine what technologies and measures, cluding the status quo, represent BTA for entrainment.
While the rule outlines the factors that FDEP must, per 40 CFR 125.98(f)(2),_and may, per 40 CFR 125.98(+/-)(3), consider, the rnle is clear that relative weighting of each factor is up to the discretion of FDEP. The goal of the reports prepared by FPL under 40 CFR 122.21(r)(9) through (13) is to provide F_DEP with the site-specific data and analyses so the agency can reach an informed decision regarding-entrainment BTA at the site. While the rule segregates the entrainment-ETA assessment into four separate reports,*
as shown in Figure 1, a successful process will integrate the analysis of the candidate options to ensure the feasibility, casts, effectiveness, and impacts are consistently defined clearly presented.
FPL also intends to summarize the resulting findings within the context of the factors defined by-40 8FR l-25.98(f).
FPL also notes the rule provides little in the way of concrete guidance regarding the nature of the engineering and economic analyses to be pursued. The rule does call for tion of specific factors but leaves~the specifics to the applicant.
Importantly, the final rule indicates a narrative discussion is reEj"uired but indicates quantification of factors as well as their potential monetization is optional. -FPL believes these two aspects of the rule's requirements (e.g., a relatively complex, grated, multidisciplinary analysis as well as the discretion left to the applicant) require the entrainment analyses be carefully planned and managed. Therefore, while the goals and overall approach to the entrainment BTA assessment are clear, FPL will refine the process over the 316(b-) implementation process beginning in 2018 and continuing into 2019 as the entrainment characterization effort proceeds.
3.3.3 PEER REVIEW PROCESS Under the final rule, three of the reports intended to support FDEP' s consideration of trainment BT A, those defined under 40 CFR 122.21(r)(l0), (11), and (12), must be subject N:\PRJ\FPL\316(B)
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LUCIEIFINAL POS\STLUCJJ 6BPOS.DOCX---Ol 0218 7 Florida Power & Light Company St. Lucie Power Plant Plan of Study 316(bj Implementation to peer review. The results of the peer review, including a summary of the reviewers' dentials and FPL' s response to the comments, are to be summarized a-s described at 40 CFR 122.21(r)(l3).
The final-rule*provides little detail regarding the tiining and nature oft.lie peer review cess. FPL perceives*
delaying peer review until the draft final documents are available would be a poor strategy, in that substantiarcomments could be received at a time when there is little time remaining to address the comments while meeting the regulatory lines. Such a strategy would also raise the potential for costly rework of ana-lyses.
N:\PRJIFPL\3 l 6(B) SUPPORTIINDIVIDUAL PLANT FILES\ST.
LUCIE\FINAL POS\STLUC316BPOS.DOCX--0!0218 8
00 I Detir1eTechnologiesand Mes1smesc to bl:! E,iiluateci
-Closed-*:ycle-, Tinernesh screen, ,vater ret.1se-rec1t.1ired
! Assess Feasibllity and Deflnesite-SpecificFactors that Dtive Costs and Effectiveness I -Justify exclusion c-fa.nytechnologies deemed Infeasible
! DevelopEngineerlngand CompllanceCost Estimates
-Expressconslstentwith rule requirements
! Estimate Reductions i~ Entrain111entand~
as Ne<essary~
EXpress in Age-Adjusted Individuals or Define Populat/or~
Effects f Facility-Specific Rate.sot Entrainment
' -When appropriate, consider factors that 11ffectieasibility and benefit (e.g.~ seasonality, organism size} -Note any Federally listed species. .--------------------.-----.--;
MappingofSteps to Rule's Re-quirem~nts Stei:;-is dominated by requirements defined in 40 crn 122.n(r):
-{9)Enlrniml1:11t dn,11 Ht,;lF::!r iialilrn S.lutly -f10} Comprshimsw*;!T11thnic.il F8asibilitysml Cost Evaluatlcn5tudy
.: {11} senefi+/-sValuatlo1fsic:lqy . . . . .. *. -\)._:::} \t,:, ... i:_i *.\'.*::*i::::
'.,.,-,:(<.;>Li.'.
FIGURE 1.
* ENTRAINMENT BTA ASSESSMENT PROCESS OVEl)VIEW Source: ECT 2016, -.,.. -... Y:\G DP\F1301 \150595\Stluc316bPOSFlgs.xlsx\.)-04/28/17 . ***~**~ Identify Impacts to Facility Operations and Grid Reliability
-./\t1ti 1 t.ipat~ f i,n;ilily e1nU ll-y~l-EJH t;IH,ill,B~*~(t:!*H*, t.:lu~u~ li:!1 tU:!l efficie,cy)
! Describe Social Costs Associated with: -Engineering and complla11ceco:sts -Changes in availability and price of power -Changes in employment -AirPml<.'ilon,;
! Devel op Integrated Statement of 5(}cial Costs and Benefits; Develop Entrain!J"lent BTA Recommendation
-Express social costsand t:>enefitscnnsistentwith rule 1 !!4ui11=1111d11l!.-
-Perform.and document peer review -lntegratewithotherfactors.at 125,;9:S(fl
{ e.g., remain I~ far.ility lffp) I t I MonetizeReducedEntrainmentasWf!ll,asAppropriate, Other Environmental Imp-acts ....... -.".t" V",..,._ ... ,. ... , ..... , .. ,.., ........ , ... " * .,,.,. . ., ... ,. ..*.. -*****,,, ... ,., .. ,,,.,.,, . .,.. .*. , ... ,. ....... ,,. .. ,.,-..*.... ,,.,..,1 Define OtherEnvircmmental Impacts -Both po~itive and ~egative f: -Be inclusive and site-specific ii -Rely on narrative wheri possibleand prioritize relevant f *fa\:l:or5 fo.rqmrntiflcationand/orm:mctizaticn
* !I -Not;e party po\entially impacted (e.g .. , rate-payer vs:. fisher vs. tax payervs.shareJ1okler)
!1 \. ,ns-.,-" .. '<.'"'** .:;* , .. ,:.v: .-.. 11',, .****. ,~,. ,;,,.-.. .* 1>>+.. .. *, ;;, .. ,,. .. , . ...:-~* ~, ,*,v,;,-.,,,;,_*,."'c*"'1'X'nv,.r.,.,"l'.,,.!~",..*
...,.,,,,,;~,r,.(~*,*
,,, . . ,-. AUl/flli1.
Environmental I Consulting
& Technology, Inc. I Florida Power & Light Company St. Lucie Power Plant Plan of Study 316(b) Implementation To avoid these risks, FPL intends to convene the peer reviewers for an evaluation of the conceptual approach to assessing entrainment BTA prior to the completion of the analyses.
The peer reviewers' input will be considered while finalizing the proposed approaches to reduce the potential for adverse comments on the overall approach toward the end of effort. Therefore, FPL intends to engage the peer reviewers at two stages in the effort: during planning in 2018-and following preparation of draft final reports. The results of both stages will be documented in the report called for under 40,CFR 122.2l(r)(13).
3.3.4 PEER-REVIEWER SELECTION The final rule requires FPL propose peer reviewers to FDEP for the agency's consideration.
FDEP may reject peer reviewers and/or .suggest other ones. FPL understands this process and has proposed peer reviewers familiar with the rule, constraints on operation of cooling water intake structures (and in particular_those at-a nuclear facility), .and the phenomena of impingement and entrainment.
A biological peer reviewer was proposed to FDEP in cember 2015 and was approved by FDEP on June 3, 2016. FPL subsequently submitted a letter to FDEP with its proposed peer reviewers for economics and engineering on March 1, 2017 Ef igure 2). FPL intends to utilize this same panel of expert peer reviewers at the St. Lucie plant as well as its other five once-through generating facilities in Florida. N:IPRJ\FPL\3 I 6(B) SUPPOR1'1NDNIDUAL PLANT FILES\ST.
LUCIE\FINAL POS\S1LUC3 l 6BPOS.D0CX--Ol 0218 10 
\D .-i ....._ .-I m ....._ .-1 0 I' . . '. : . : e IWF: Perf11it is Effective,
* I li/14/16 !
* t} jFDE~ .Me~ting, l12/2r/16
* . j /:~ Target fDEPfpproval ofPe~r l .,,, : Review~rs, 04/01/17 ' t , 1 I 1 1 , ! 0 'POS Due, ,05/0~/17 I . . . : : I . ! ! i *Plan ping ""-""*""""""j"""""'"'""""""""J.
08/01/16: . i : OUOl/17 \D .-i ....._ .-I m ....._ m 0 I : : . : : / Pee ti Revi,ew &sect;!tue. ;b * . ) !11/15/16: . 2/01/17: ' ' . \D .-i ....._ .-1 m ....._ Lf1 0 ' j ! i ' i l ; I l \D .-i m ....._ r--. 0 \D .-i ....._ 0 m ....._ cn 0 \D r--. r--. r--. .-i .-i .-i .-i c5" O)" ....._ .-1 m N m m ....._ ....._ ....._ ....._ .-1 .-1 m Uil .-1 0 .0 CD I r--. r--. r--. co cd .-i .-i .-i .-i .-i ....._ c5" ....._ ....._ ....._ .-1 cn en .-1 m m N N m ....._ ....._ ....._ cn .-I m 0 0 .-1 0 0 FIGURE 2. ST. LUCIE ANTICIPATED PROJECT SCHEDULE Source: ECT, 2017. Y:\GDP\Fl301\150595\5tluc316bPOSFlgs.xlSK\2-05/01/17 co co co co cn cn cn cn cn cn 0 0 0 0 0 0 .-i .-i .-i .-i .-i .-i .-i .-i .-I .-1 .-I .-1 .-1 N N N N N N N N N ....._ ....._ ....._ ....._ ....._ ....._ c5" ....._ ....._ ....._ c5" ....._ ....._ ....._ ....._ ":"c,; ....._ ....._ .-I .-1 en cn en .-1 cn Rl en en cn 00 co co cn en m m N N N m m m N C'<J m N N N N N N ....._ ....._ ....._ ....._ ....._ ....._ ....._ ....._ ....._ ....._ *,-..... ....._ ;::i-....._ ....._ ....._ Lf1 cn .-1 .-1 gJ *1.11 r--. cn .-I m 1.11 r--. cn .-1 m Lf1 fl 0 0 .-1 a 0 0 '? r 0 0 0 a a .-i a a a Date Florida Power & Light Company St Lucie Power Plant 4.0 PROJECT TEAM Plan of Study 316(b) Implementation Table 2 summarizes key staff for the St. ~ucie plant's 3T6(b) effort. Table 2. St. Lucie Power Plant 316(b) Compliance Project Key Staff Contacts Staff Company Role Telephone Email Tim.Powell FPL Project manager 561-694-4015 tilnothy.powell<@fpl.com Ron Hix FPL Project advisor 561-691-7641 ron.hix@fpl~com Steve. Cibik ECT Project manager 919-861-8888" scibik@,ectinc.com MarkGerath ECT Project director 978-263-3335 mgerath@ectinc.com Source: ECT, 2017. N:\PRJ\FPL\3 i 6(B) SUPPOR1iINDIVIDUAL PLANT FILESIST.
LUCIEIFINAL POSISTLUC316BP0S.DOCX-010218 12 EC'T 
-Florida Power & Light Company St Lucie Power Plant APPENDIX A Plan of Study 316(b) Implementation ENTRAINMENT CHARACTERIZATION STUDYP:EiAN N:\PRJ\FPL\316(B)
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LUCIE\FINAL POSISTLUC316BP0S.DOCX---010218 ENTRAINMENT CHARACTE*RIZATION STUDY PLAN ST. LUCIE NUCLEAR POWER PLANT Prepared for: Juno Beach, Florida Prepared by: 7208 Falls of Neuse Road,-Suite 102 Raleigh, North Carolina 27615 ECT No. 150595-ClOO April 2017 Florida Power & Light Company St. Lucie Nuclear Power Plant DOCUMENT REVIEW Entrainment Characterization Study Plan The duaLsignatory process is an integral part of Environmental Consulting
& Technology, Inc._'s (ECT's) Document Review Policy No. 9.03. All ECT documents underg0 technicaVpeer review prior to dispatching these documents to any outside entity. This document has been authored and reviewed by the fo11owing employees:
Jennifer A. Cassada Stephen J. Cibik Author Peer Review Signature Signature April 26, 2017 April 26, 2017 Date Date Y:IGDPIF1301\150595\STLUCENTRCHARDOCX-OJ02!8 Florida Power & Light Company St Lucie Nuclear Power Plant TABLE OF CONTENTS Section
 
==1.0 INTRODUCTION==
 
2.0 -REGULATORYBACKGROlJr..TD
 
===2.1 IMPINGEMENT===
 
===2.2 ENTRAINMENT===
 
3.0 OVERVIEW-OF THE ST. -LUCIE PLANT 3.1 PLANT DESCRIPTION
 
===3.2 SOURCE===
W ATERBODY DESCRIPTION 3.3 CWIS CONFIGlJRAIION
 
===3.4 EMERGENCY===
 
WATER INTAKE Entrainment Characterization Study Plan Page 1-1 2-1 2-1 2-3 3-1 3-1 3-1 3-3 3-4 -4.0-HISTORICAL IMPil~GEMENT AND ENTRAINMENT DATA 4::1 4.1 1976 TO 1983 STUDIES 4-1 4.1.1 IMPINGEMENT STUDIES 4-1 4.1.2 GILL NETS 4-2 4.1.3 TRAWLS 4-2 4.1.4 BEACH SEINES 4-2 4.1.5 ENTRAINMENT STUDIES 4-3 4.2 PHASE II STUDIES 4-3 4.2.1 NEARFIELD TRAWLS 4-3 4.2.2 PLANKTON COLLECTIONS 4-4 5.0 THREATENED AND ENDANGERED SPECIES 5-1 6-.0 ENTRAINMENT~TUDY-PLAN 6-1 6.1 ENTRAINMENT CHARACTERIZATION 6-1 6.1.1 SAMPLING FREQUENCY AND METHODOLOGY 6-1 6.1.2 SAMPLE ANALYSIS 6-=2 6.2 SUPPORTING DATA COLLECTION 6-2 6.3 QUALITY CONTROL 6-3 6.4 REPORTING 6-3 6.5 HEAL TH AND SAFETY 6-4 6.6 SCHEDULE 6-4
 
==7.0 REFERENCES==
 
7-1 Y:\GDPIF1301
\150595\STLUCENfRCHARDOCX--Ol 0218 11 ECI Florida Power & Light Company St Lucie Nuclear Power Plant Entrainment Characterization Study Plan 5-1 3-1 4-1 4-2 LIST OF TABLES List of State-and-Federally Listed Species in the Vicinity of the St. Lucie Plant LIST OF FIGURES Site Location Map 2006 to* 2007 St. Lucie-Plant Entrainment Study Seasonality 20_06 to-2007 St. Lucie-Plant Entrainment.Study Results-Species Composition Y:IGDP\FI301\150595\STLUCEN1RCHARDOCX--010218 111 5-2 3-2 4-5 4 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan LIST OF ACRONYMS AND ABBREVIATIONS
~C degree Celsius 0 E degree Fahrenheit AIF actual intake flow BTA best technology a-vailable CFR Code of Federal Regulations CW1S cooling-water intake structure EPA U.S. Envir:onmental Protection Agency ESA -Endangered Species Act ofl973 FDEP Floi:ida Department of Environmental Protection FNAr Florida Natura:1-Areas Inventory FPL Florida Power & Light Company fps foot per second FR Federal Register ft foot gpm gallon per minute IM impingement mortality IPaC USFWS Information Planning and-Conservation MGD million gallons per_day MW megawatt NJ\1FS National Marine Fisherie~Service NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant-Discharge Elimination System NRC Nuclear Regulatory Commission ppt part per thousand SOP standard operating procedure St. Lucie Plant St. Lucie Nuclear Power Plant USFWS U.S. Fish and Wildlife Service WOUS Waters of the United States Y:IGDP\Fl30l\i50595\STLUCENTRCHARDOCX--0!0218 lV Florida Power & Light Company St. Lucie Nuclear Power Plant
 
==1.0 INTRODUCTION==
 
Entrainment Characterization Study Plan Florida -Power_ & Light Company (FP-L) owns and operates the St. Lucie Nuclear Power Plant (St. Lucie Plant), a two unit nuclear-fueled electric generating facility on Hutchinson Island in St. Lucie County, Florida, that operates under National Pollutant Discharge Elimination System (NPDES) PermifNo.
FL0002208-.
The St. Lucie Plant is subject to the final Clean Water Act Section 3 l 6(b) -rule for existing facilities 1, which was published August 15, 2014, by the U.S. Envirnnmental Protection Agency (EPA). The 3 l 6(b) rule regulates the location, design-, construction, and operation of cooling water intake structures (CWIS). The rule applies to existing facilities thatheld an NP-DES permit, withdraw more than 2 m111ion g-allons-per_day (MGD) from Waters of the United States (WOUS), and use at least 25 percent of that water exclusively for cooling purposes.
The rule supersedes the Phase II rule, which was remanded in 2007, and the remanded_e..xisting facility portion of the previously promulgated Phase III rule. The final 3 l 6(b) rule became effective on October 14, 2014. Compliance with the rule is linked to the facility's NPDES permit, and implementation of the NPDES program in Florida has been delegated by EPA to the Florida Department of Environmental Prntection (FDEP). The 3 l 6(b) rule requires each affected facility's application for renewal of their NPDES discharge permit include specific submittals ancLsupporting information to demonstrate compliance with the performance standards.
Facilities with design intake flows greater than 2 MGD must comply with the impingement mortality (IM) requirements of the rule, and facilities that wilhdraw more than 125 MGD oractual intake flow (AIF) are required to submit an entrainment characterization study to support the NPDES-director's determination of best technology available (BTA) for entrainment mortality.
This study plan has been prepared to support development of both the IM compliance strategy of Title 40, Section 122.2l(r)(6), Code of Federal Regulations (CFR), and the entrai..t:unent characterization study required in 40 CFR 122.21(r)(9).
1 Federal Register (FR), Volume 79, No. 158, Friday, August 15, 2014, pages 48300 through 48439; Title 40, Parts 122 and 125, Code of Federal Regulations (CFR), National Pollutant Discharge Elimination Final Regulations to Establish Requirements for Cooling Water Intake Structures at Existing Facilities and Amend Requirements at Phase I Facilities; Final Rule. Y:\GDPIF130l\150595\STLUCENIRCHAR.DOCX-010218 1-1 Florida Power & Light Company St Lucie Nuclear Power Plant Entrainment Characterization Study Plan Section 2~0 describes the regulatory requirements for compliance with the final existing facilities rule, and-Section
 
===3.0 provides===
a-description of the St. Lucie Plant. Section 4.0 sumrnarizes historical impingement and entrainment data, and -Section 5.0 discusses the potential for state and federally listed species to occur at tire site. Section-6.0 presents the proposed entrainment sampling plan. Y:\GDPIF1301\150595\STLUCENTRCHARDOCX-010218 1-2 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan 2.0 REGULATORY BACKGROUND The &#xa3;mal 316(b) rule establishes requirements for BTA in design and operation -of the -CWIS to minimize adverse environmental impacts due to impingement and entrainment of organisms.
Impingement occurs when organisms are trapped against the outer part of an i..11.take structure or screen, arid entrainment is when organisms are drawn through the CWIS and into the cooling water system. The main-objective of the final 3 l 6(b) rule is to reduce mortality from impingement and entrainment through establishing performance standards forBTA. 2.1 IMPINGEMENT The rule's IM requirements apply to all existing facilities with design intake flows-of greater than 2 MGD. There are nine alternatives for compliance:
L Closed-Cycle Recirculating System; 40 CFR 125.94(c)(l}-A facility-that operates a closed-cycle facility is considered compliant with IM requirements.
The rule's definition of closed-cycle per 40 CFR 125.92(c) includes cooling towers, cooling ponds that are not WOUS, and existing impoundments of WOUS constructed for the purposes of serving as part of the cooling water system. There are no specific requirements for flow reduction or cy:cles of concentration.
Facilities that comply under this alternative must monitor flow at least daily. 2. -0.5-Foot-rer-Second Through-Screen Design Velocity; 40 CFR 125.94 .{&#xa3;)ill-A facility may comply with BTA requirements by demonstrating the CWIS has a maximum design through-screen intake velocity of 0.5-foot per second (fps). The velocity must be achieved under all conditions, including during minimum ambient source water elevation and periods of maximum head loss across the screen. 3. 0.5-fps Through-Screen Actual Velocity; 40 CFR 125.94 (c)(3}-Facilities that can demonstrate the actual intake velocity does not exceed 0.5 fps can comply with the IM requirements under this alternative.
As with the 0.5-fps through-screen design velocity, the velocity must be achieved under minimum ambient source water elevation and during periods of maximum Y:\GDP\FJ30J\J50595\STLUCENIRCHARDOCX--OJ02!8 2-1 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment , Characterization Study Plan head loss across the screen. Compliance under this alternative requires daily monitoring of t..l:1e intake velocity or monitoring of flow, water depth, and intake area to support calculation of the intake velocity.
: 4. Existing Offshore Velocity Cap; 40 CFR 125.94(c)(4)-Facilities with existing velocity caps located more than 800 feet (ft) offshore per 40 CFR 125.92(v) are compliant with th~ rule's IM requirements.
Intake flow must be monitored on a-daily basis. 5. Modified Traveling Screens; 40 CFR 125.94(c)(5)-This alternative requires installing and operating modified traveling screens and a fish return, as defined in 40 CFR 125.92(s).
Facilities that select this compliance option must complete a tw0-yearimpingementtechnology performance study per 40 CFR 122:21(rJ(6)Ei).
This .study must include two years of monthly (at minimum) monitoring of the latent survival of "nonfragile" species following impingement on the screens, with the stated goal-of optimizing the performance of the technology.
: 6. Systems of Technologies as BTA for IM; 40 CFR 125.94(c)(6)-This alternative provides the NPDES director the discretion to determine a system of technologies, rnanagement practices, and-operational measures are the BTA for reducing IM. This alternative requires a two-year impingement technology performance optimization study to optimize the selected compliance goal, either: (1) reduction in impingement rate, or (2) reduction in mortality-after impingement per 40 CFR 122.2-l(r)(6)(ii).
: 7. IM Performance Standard; 4o_ CFR 125.94(c)(7)--This compliance alternative requires -achieving IM rates of no more than 24 percent on an annual basis. This must -be demonstrated with latent mortality monitoring conducted monthly on an ongoing basis through at least the initial permit term. 8. De minimis Rate of Impingement; 40 CFR 125.94(c)(l 1)-This alternative provides the NPDES director the discretion to conclude that the rates of impingement are so low that additional impingement controls are not justified.
The 316(b) rule indicates this approach may only be used in limited circumstances.
Y:\GDP\F!30!\!50595\STLUCENTRCHARDOCX-0!02!8 2-2 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan 9. Low-Capacity Power Generating Units; 40 CFR 125.94(c)(12)-The NPDES director has the discr-etion to establish less stringent IM standards for facilities with GWIS with capacity utilization rates-ofless than 8 percent averaged over a two-year period. 40 CFR 122.21(r)(6) requires the -facility select an approach for compliance with IM requirements and, depending on the alternative selected, the_ required supporting information.
For Alternatives 5, 6,_ and 7, hlolegical monitoring data are to be collected after the selected compliance technology is installed to demonstrate the technology has been optimized and/or is meeting relevant performance standards.
 
===2.2 ENTRAINlVIENT===
 
The 316(.b) rule does not establish specific entrainment performance standards but rather requires the NPDES director to establish BTA for each facility on a site-specific basis. 40 CFR 122.21(r)(9) requires an entrainment characterization study be conducted at facilities with an AIF greater than 125 MGD. The study is intended to provide the NPDES director with information needed to determine BTA for the facility.
The study must include a minimum of two years of entrainment data collection and must include the following components: (i) "Entrainment Data Collection Method. The study should identify -and
* document the data collection period and frequency.
The study should identify and document 0rg.anisms collected to the lowest taxon possible of all life stages of fish and shellfish that are in the vicinity of the coating water intake structure(s) and are-susGegtible to entrainment, including any identified by ffie director, and-any species protected under Federal, State, or Tribal law, including threatened or endangered species with a habitat range that includes waters in the vicinity of the cooling water intake structure.
Biological data collection must be representative of the entrainment at the intakes subject to this provision.
The owner or operator of the facility must identify and document how the location of the cooling water intake structure in the waterbody and the water column are accounted for by the data collection locations; Y:IGDP\FJ30!\!50595\STLUCEN1RCHAR.DOCX-OI02!8 2-3 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan (ii) Biological Entrainment Characterization.
Characterization of all life stages of fish, shellfish, and any species protected under Federal, State, or Tribal law (including threatened_or endangered species), including a description of their -abundaace and their temporaland spatial characteristics in the vicinity of the cooling water intake structure(s), based on sufficient data to characterize -annualy*seasonal, and diel variations in entrainment, including but not limited to variations related to climate and weather .differences, spawning, feeding, a..11d water column migration.
This characterization may include historical data that are representative of the current operation of the facility and of biological conditions at the site. Identification of all life stages offish and shellfish must include identification of any-surrogate species used, and identification of representing both motile and non-motile life-st-ages.of organisms; (iii) Analysis and Supporting Documentation.
Documentation of the current entraimnfmt of all life stages of fish, shellfish, and any species protected under Federal, State, or Tribal law (including threatened or endangered species).
The documentation may include historical data that are representative of the current operation of the facility and of biological conditions at the site. Entrainment data to support the facility's calculations must be collected during periods of representative operational flows for the cooling water intake structure, and the flows associated with the data collection must be documented.
The method used to determine latent mortality along witli data for specific mganism mortality or survival that is.applied-to other life-stages or species must be identified.
The owner or operator of -the facility must identify and.document all assumptions and calculations used to determine the total entrainment for that facility together with all methods and quality assurance/quality control procedures for data collection and data analysis.
Tlie proposed data collection and data analysis methods must be appropriate for a quantitative survey." The entrainment study plan (Section 6.0) is intended to meet the submittal requirements for an entrainment characterization study plan and describes the approach and methods to collect entrainment data to support the site-specific determination ofBTA for entrainment.
Y:\GDP\Fl30l 1150595\STLUCENTRCHAR.DOCX----OI 0218 2-4 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan 3.0 OVERVIEW OF THE ST. LUCIE PLANT 3.1 PtANT DESCRIPTION FPL' s St. Lucie plant is_ located on Hutchinson Island in St. Lucie County south of Fort Pierce, Florida (Figure 3-1). The plant consists of two nuclear-fueled generating-units with a net generating capacity-of 853-megawatts (MW) each unit. Unit 1 was placed-in operation in March 1976, and Unit 2 was added in Apri-1 1983. St.Lucie was approved for an extended uprate in 2012 that increased generation capacity of each unit from 853 to l,002MW. St. Lucie withdraws cooling water from the Atlantic Ocean through three offshore intakes equipped-with velocity caps that meet the rule's definition in 40 CFR 125.9Z(v) (Figure 3-1). The-design intake flow of the facility-is 1,487 MGD (1,032,600 gallons per minute [gpm]) provided through eight circulating water pumps (1,404 MGD) and auxiliary equipment cooling pumps (four of six typically operate at 83 MGD). After passage through the facility, cooling water is discharged through a discharge canal and then two pipelines into the Atlantic Ocean. One discharge pipe extends approximately 1,500 ft from shore and has-a Y-shaped diffuser.
The other extends approximately 1,900-ft from shore with an additional 1,400 ft of 58-port multiport diffuser (FPL, 2016). 3.2 SOURCE W ATERBODY DESCRIPTION The St. Lucie plant withdraws water-from the Atlantic Ocean (Class III Marine Waters) on the east side of Hutchinson Island approximately 8 miles southeast of Fort Pierce; Florida. The depth near the intake is approximate-ly 20-ft-and slopes to approximately 40 ft roughly 1 mile-0ffshore, rises back to approximately 25 ft at-Pierce Shoal almost 2.5 miles offshore, before deepening again out across the continental shelf to approximately 300 ft (National Oceanic and Atmospheric Administration
[NOAA], 2017) then the open ocean with an average depth of approximately 11,000 ft (Britannica, 2017). Currents in the nearshore area near the St. Lucie site are primarily influenced by winds and tides. Tides in this area are semidiurnal and have a relatively low tidal range with a mean Y:\GDPIF1301\!50595\STLUCENTRCHAllDOCX-OJ02!8 3-1 FIGURE 3-1. SITE LOCATION MAP Sources: ESRI World lmaoerv. 2014. 3-2 __,,r; l/iil!al!I Environmental Consulting
& 6= I Technology, Inc.
Florida Power & Light Company St. Lucie Nuclear Power Plant ----------
Entrainment Characterization Study Plan of 2.56 ft and a spring tide range of-3.59 ft (NOAA Tide Station #8722212).
The main ocean current along the Florida east coast is the Florida Gulf Stream, which flows northward farther offshore, beyond the JOO-ft c_ontour.
Longshore currents were measured for the St. Lucie-Plant Environmental Impact Statement in 1973 to 1975. Currents ranged from near zero to 1.6 fps and flowed to the north 49-percent of the time and to the south 35 percent of the time. The prevailing current direct-ion is to the north at an average speed of 0.74 fps near the surface and 0;54 fps near the bottom EFPL, 1982). -Salinity in the nearshore waters adjacent to the St. Lucie Plant is typical of ocean waters and varies slightly between 34 and 36 parts per thousa..'ld (ppt) (Applied Biology, Inc., 1982). The Coastal Data Information Program buoy near-Fort Pierce has recorded an average sea surface temperature for the period of record (September 29, 2006, to March 31, 2017) of 24.9 degrees Celsius (0 C) (76.8 degrees Fahrenheit
[&deg;F]), with a r-ange of 13.9.&deg;C (57.0&deg;F) to 3 l.5&deg;C (88.7&deg;F).
3.3 CWIS CONFIGURATION The St. Lucie intake is located at 27.347440 north, -80.233006 west, approximately 1,200 ft from the shoreline in the Atlantic Ocean, consists of three vertical concrete shafts tliat have concrete velocity caps to change the current direction from vertical to horizontal.
This technology takes into account that fish are able to detect and avoid a horizontal velocity but not a vertical velocity.
The intakes are located at mid-depth (approximately 7 ft below the water surface at mean low water=). Water is-gravity fed through the three offshore intakes into the three submerged pipes and then into an onshore intake canal. Two of the intake pipes have an inside diameter of 12-ft,_while the third has an inside diameter of 16 ft. The onshore intake canal is L-shaped and is 5,000-ft long and 300-ft wide, with a maximum depth-of 25 ft. The velocity caps-consist oflarge flat plates placed 6 to 7 ft above the vertical shaft of the intake structure.
The velocity cap for the 16-ft pipe is 70 ft square, 5 ft thick, and has a vertical opening of 6.25 ft. The velocity caps for the two 12-ft diameter pipes are octagonal with the comers cut off; the long sides are 52 ft long, 5 ft thick, and have a vertical opening of 6.5 ft. Horizontal velocities at the two 12-ft pipes are estimated to be 0.4 fps; velocities Y:\GDPIF130!\!50595\S1LUCEN1RCHAR.DOCX---0!0218 3-3 EC'T Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan at the 16-ft pipe are estimated at 1 fps. In-.coordination with the National Marine Fisheries Service (NMFS), the velocity caps are being fitted with large animal exclusion devices. There is a series of barrier nets along. the -intake carial designed to contain and reduce the residence time of:sea turtles in the intake canal. A 5-inch barrier net is located downstream of the intake headwall.
A second barrier net consisting of large-diameter polypropylene rope with a mesh size of 8 by 8 inches-is located near the State-Road-AlA bridge. The third barrier net is located near the_bendin the intake canal .and is constructed of 9-by 9-inch mesh. Sea turtles captured in the nets or found in the intake canal are released back to the Atl-antic-Ocean.
Water entering the four intake bays passes through trash racks that consist 0f vertical bars at 3-inch spacing and through eight traveling screens (four per unit) with 0.375-inch mesh wire. The traveling screens are equipped with a spray wash system that removes debris and aquatic organisms.
There is no fish return system at the St. Lucie Plant. 3.4 EMERGENCYWATERINTAKE There is an emergency water intake structure located at the northwestern end of the intake canal that would allow water from Big Mud-Creek, a cove of the Indian River Lagoon, into the intake canal.The intake consists of two 54-inch pipes with valves and is designed to provide emergency cooling water in the event that insufficient flow is available from the Atlantic.
The system is tested quarterly by_opening and closing-each valve for a period-of less than one minute. Depending 0n the head diff.erential bet\veen Big Muddy Creek the intake canal, the testing allows approximately 100,000-gallons per valve to11ow into the intake canal. Y:IGDP\Fl301\150595\STI..UCENTRCHAR.DOCX--OI0218 3-4 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan 4.0 HISTORICAL-IMPINGEMENT AND ENTRAINMENT DATA This section describes the historical impingement and entrainment studies conducted at the St. Lucie Plant in the 19-70s and2000s.
4.1 1976 TO 1983 STUDIES Studies were conducted at the St. Lucie Plant in the 1970s and 1980s with Unit 1 being operational and-prior to the construction of Unit 2. 4.1.1 IlV[elNGEMENT STUDIES Impingement sampling was conducted at St. Lucie's Unit l intake from 1976 to 1978 as directed by the ~uclear Regulatory Commission (NRC) Unit 1 operating license. The travelling screens were sampled-twice weekly for a 24-hour period divided into 8-hour samples, and annual impingement rates were estimated for the facility based on continuous operation of the one unit then in operation.
There were 226 sampling events during this study. Annual fish impingement was estimated tol;e-between 34,000 (1978) and 131*,ooo (1976); annual shellfish impingement was estimated at-26,000 (1976) to 37,000 shellfish (1978). The mean number of-fish impinged per 24-hour period was 222, and the mean number of sheHfish was 82. The dominant taxa impinged included anchovy (Anchoa sp.), grunt (Haemulidae), jack (Carangidae), croaker (Micropogonias sp.), mojarro (Gerreidae), shrimp (Panaeidae), and blue crab (Callinectes sapidus).
In -1979, the NRC amendeffthe operating license for Unit 1 to discontinue the monitoring-requirement, stating that impingement losses were insignificant when compared to the fish-populations in-the site vicinity and the nurnber of commercially harvested shrimp on Florida's east coast. With the addition of the second unit it was acknowledged that the impingement impacts would double with the doubling of the intake flow. However, the NRC estimated, even with doubling the weight of the organisms, impingement would only be equal to less than half of 1 percent of the commercial catch of fish and shellfish in either St. Lucie or Martin Y:\GDP\F1301\1505951S!LUCENIRCHAR.DOCX-010218 4-1 ECI Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan counties.
Therefore, the NRC conduded the combined estimates for im2ingement of the two units would still be insignificant.
4.1.2 GILL NETS Gill-net sampling was conducted monthly in the intake canal from 1976 through 1984 to determine the number of fish and shel-lfish that become entrapped in the intake canat Gill nets of 200 ft by 10 ft with 3--inch -stretch mesh were fished in the intake canal for two consecutive 24-hour-periods each month. The dominant organisms colleGted included grunt, drum,_snapper--, jack, porgy, mullet, and sea robin. The average catch rate was fairly consistentthroughout the study period (3.5 to 12.5 fish per 30 meters-of gill net per day). Gilr net samples were also collected at six ocean sampling locations once per-month-from April to September and twice per mont.l:i from October through March with a long by 3-.7-meter-deep with five mesh sizes in-the end: 64, 74, 84, 97, and 117 millimeters (mm). The net was fished for 30 minutes per station. Catch rate and species collected were variable over the years with catch per unit effort ranging from 8 to 94 fish per net set. These studies indicated there is not an accumulation of organisms-in the intake canal. The low rate of entrapment was attributed to the velocity caps on the intakes that allow fish to detect and avoid the intake flow. 4.1.3 TRAWLS Trawl samples were collected at six ocean stations using a 4.9-meter-semiballoon trawl with 127-mm stretch mesh in the bag and 6.4 mm stretch mesh in-the cod end. Each tQW consisted-of 15 minutes at 2-to 3 knots and was conducted at night to reduce the avoidance response of fish. These-studies showed a high variability in percent composition (relative abundance) and overall abundance across the study period, within years, and spatially.
 
====4.1.4 BEACH====
SEINES Beach seine samples were collected once a month at three stations, near the intake, near the discharge, and north of the discharge.
The beach seine was 30.5 meters long by Y:\GDPIFJ30!\150595\S1LUCENTRCHARDOCX---OJ02!8 4-2 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan 1. 8 meters deep, with a stretch mesh of 25 mm. The net was deployed at 1.2 meters from shore and fished for three replicate hauls during each sampling period. 4.1.5 ENTRAINMENT STUDIES Paired bEmgo nets were used to collect ichthyoplankton in the intake-canal and nearshore habitats.
Six ocean stations, one station in the intake canal, and one station in the discharge canal were sampled twice a month during the day using paired 20-centimeter, 505-micron mesh bongo nets. In the offshore stations_the nets were towed for 15 minutes just below -the surface. A mid-depth sample was taken near the intake, and oblique tows were taken in the canals. Sample analysis-showed the mid-water samples near the intake had lower densities -of ichthyoplankton than the surface san:ip_les, the intake canal had lower densities than the ocean, and the discharge canal had lower densities-than the intake canal. It was-also noted most of the larval fish collected in the intake canal were damaged. The most common larval fish collected were herrings and anchovies, suggesting the unidentifiable eggs collected were likely the same species. Blennies, gobies, mojarras, drums, and jacks were also dominaRt.
Entrainment at the St. Lucie P-lant was estimated based on localized densities of entrainable organisms near the intake. Entrainment sampling was conducted-over a five-:Year period and concluded, under: normal conditions, approximately
 
===0.4 percent===
of the fish eggs and larvae passing the intake would be subject to entrainment.
Therefore, the NRC determined the St. Lucie Plant would a minimal effect on the local fish populations~
4.2 &#xa3;HASE II STUDIES Studies were conducted in January 2006 to October 2007 inTesponse to the release of the Phase II rule to characterize the biological community in the vicinity of the St. Lucie Plant. 4.2.1 NEARFIELD TRAWLS Bottom and midwater trawl samples were collected from the ocean near the intakes at three transects parallel to the shore using a 4.9-meter by 0.9-meter otter trawl. Fish densities Y:\GDPIF1301\!50595\STI..UCENTilCHAR_DOCX--0!0218 4-3 Florida Power & Light Company St. Lucie Nuclear Power Plant -Entrainment Characterization Study Plan were generally higher in the summer than the winter and higher in 2006 than 2007. Dominant fish collected in the trawls were anchovies (especially Anchaa hepsetus and A. lamprotenia), comprising 89 percent of the-catch, followed by herrings (Clupeidae) with 5 percent. Shellfish densities were low (less tlian one per 100 cubic meters) throughout the study and were dominated by commercial shrimp (Penaeidae) and-swimming crabs (Portunus spp.). 4.2.2 PLANKTON COLLECTIONS Plankton samples were collected by pumping intake water as it is drawn into the intake canal through a 1-meter diameter plankton net-with 30-micron mesh. The plankton net was suspended at mid-Eiepth and fished for 5 or 10 minutes, depending on whether one. or two units were operating.
Fish densities from plankton collections peaked in the late spring and lat-e summer. Densities in the intake canal -were low throughout the study. A high percentage of the catch in the intake canal was unidentifiable (74.5 percent) due to developmental stage (35 percent undeveloped), damaged (24 percent), or otherwise unidentifiable (15 percent).
Drums (9.5 percent) and anchovies (4 percent) were the most commonly identified.
Densities of shellfish in-the intake canal were alsoJow throughout the study and dominated by brachyuran crabs (Brachyura, 64 percent), sergestid*
shrimp (Sergestoidea, 9 percent), and caridean shrimp (Caridea, 7 percent). -Figure 4-1 depicts the seasonality of fish and shellfish entrainment, and-Figure 4-2 shows the-species composition.
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Fish FIGURE 4-2. iii Unidentified eggs ;) He~rings !"ill Anchovies Ill Drums/Flounders/Grunts cqmplex Blennies (family) tli Gobies ts:l Blennies (suborder) fill Pe!rch-like fishes I !\! Drums r1I Other 2006-2007 ST LUCIE Ef'\JTRAINMENT SPECIES CiOMPOSITION Source: EAi, 2008. Y:\GDPIFI 30 l\150595\StLucf-ntrChiuFigs.xlsx\4-i-04/28/l 7 ii1ll Brachyuran crabs m Sergestid shrimps m Caridean shrimps II Anomuran crabs Stone crab m Ghost and mud shrimps ru Panopeid mud crabs f.l~ Unidentified
~rab species IJ Renaejd shrimps [I! Other ---r;* * .,, Enyiro11mental .JpJJrll:
I Consultmg
& .J/llltt/lfl . * . Technology, Inc.
Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Studv Plan 5.0 THREATENED .AND ENDANGERED SPECIES Federally listed threatened and endangered species and designated-crifical habitat are protected bf the Endangered Species Act of 1973 (ESA) and subsequent amendments.
The ESA is administered by two federal agencies:
the U.S. Fish and Wildlife Service and NMFS. NMFS oversees marine species, and US-FWS has responsibility over freshwater fish and all other terrestrial-and aquatic species. During preparation of the final 3 l 6(b) rule, EPA conducted an ESA consultation with USFWS and NMFS. As a result, NMFS and USFWS issued a joint biological opinion commenting on the proposed ru-le's potential effects on listed species and/or critical habitat tr.at stated the rule-is not likely to-result in jeopardy to_any federally listed species, because it includes provisions for USFWS and NMFS review and requires the applicant to identify "based on readily available information
... all federally listed threatened and endangered species and/or designated critical habitat that are or may be present in the action area." Information regarding the potential presence of federally listed species or critical habitat was obtained from online databases including the USFW-S Information Planning and Conservation (IPaC) website, NMFS website, and Florida Natural Areas Inventory (FNAI) biodiversity matrix. Table 5-1 includes federa]ly and state-listed species that have the potential to occur near the-St. Lucie Plant, as well as l1a:bi-tat preferences for each listed species. Critical habitat for loggerhea-d sea turtle (the beaches along Hutchinson Island) and-West Indian manatee (Indian River Lagoon) is found near the St. Lucie Plant. While it is unlikelJ federally*Hsted species wilri5e entrained during the planned sampling efforts, any such occurrence will be reported-to FPL and the appropriate agency promptly after the organism is identified, as well as reported in the entrainment characterization study report. Y:IGDPIFI30!\150595\SILUCENTRCHARDOCX--0!0218 5-1 ...,.. .... _&;1:,-I Florida Power & Light Company St Lucie Nuclear Power Plant Entrainment Characterization Study Plan Table 5-1. List of State-and Federally Listed Species in the Vicinity of the St. Lucie Plant Status* Scientific Name Common Name State Federal-Habitat-Rynchops niger Black-skimmer SC Coastal and inland waters, nests on sandy beaches and islands and -also roo:f'-.ops Sternula antillarum Least tern T Coastal areas, nests on well-drainecLsand or gravel with little vegetation Halophila j ohnsonii Johnson's seagrass E T Shallow tidal inlets, sandy shoals, and mouths of canals Mycteria americana Wood stork T T Nests in inundated forested wetlands, forages in shallow-water Dermochelys coriacea Leatherback sea turtle E E Oceanic waters; nests on coastal sand beaches Caretta Loggerhead sea turtle T T Marine coastal and oceanic waters; nests on coastal sand beaches; juveniles frequent coastal bays, inlets, and lagoons Chelonia mydas Green sea turtle E E Estuarine and marine coastal and oceanic waters; nests on coastal sandy beaches; juveniles frequent coastal bays, irJets, and lagoons Acipensel'-oxyrinchus Atlantic sturgeon E E -Primarily marine, nearshore; migrates to rivers for spawning Pristis pectinata Smalltooth sawfish E E Juveniles:
estuaries, river mouths, and bays.-Adults:
open water. Aphelocoma coerulescens Florida scrub-jay T T Fire-dominated oak scrub on well-drained sandy soils -Chamaesyce cumulicola Sand-dune spurge E Coastal-scrub and stabilized dunes Charadrius melodus Piping ple-ver T T Open sandy beaches and tidal mudflats Cladonia pe,forata Perforate reindeer lichen E E Rosemary scrub Coelorachis tuberculosa Piedmont jointgrass T Shallow areas in lakes and ponds or wet savannahs in karst areas Conradina grandiflora Large-flowered T Sandy flats or sandhills rosemary Drymarchon couperi Eastern indigo snake T T Broad range of terrestrial habitats Glandularia maritima Coastal vervain E Sandy clearings in coastal scrub and forested habitats Y:\GDPIF1301\!50595\STI.UCEN!RCHARDOCX--010218 5-2 Florida Power & Light Company St Lucie Nuclear Power Plant Entrainment Characterization Study Plan Table 5-1. List of State-and Federally Listed Species in the Vicinity of the St. Lucie Plant (Continued, Page 2 of2) Scientific Name Gopherus polyphemus Lechea cernua Lechea divaricata Lepidochelys kempii Common Name Gopher tortoise Nodding pinweed Pm.e pinweed Kemp's ridley sea turtle Status-* State Federal T C E Linum carteri var. smallii .Small's flax E Peromyscus polionotus niveiventris Pituophis melanoleucus mugitus P olygala smallii Rivulus marmoratus Rostrhamus sociabilis Schizachyrium niveum Tephrosia angustissima var. curtissii Trichechus manatus *C= E= candidate species. endangered.
Southeastern beach mouse Florida pine snake Tiny polygala Mangrove rivulus Snail kite Scrub bluestem *coastal hoary-pea West Indian manatee T SC E SC E E E T = threatened.
T E SC E E SC = species of concern. Habitat Variety of terrestrial-haoitats with well-drained sandy soils *Deep sands in openings in-scrub oakor mixed forests Scrub and scrubby flatwoods Marine coastal waters, nests on sandy beaches Pine rocklands, pine flatwoods and adjacent disturbed areas Sand .dunes with moderate . vegetated cover and adjacent palmetto flats Open areas with dry sandy soils; sand.hills, fields, scrub Pine rocklands, scrub, sand.hills Coastal brackish and saltwater especially mangrove and saltmarsh Large open freshwater marshes or shallow lakes with apple snails White sand patches in rosemary scrub; *also sand pine scrub and oak scrub Pine rocklands Coastal waters Source: FNAI within 7-square-mile matrix units (67302, 67476, 67477, 67478, 67645, 67646, 67647), including St. Lucie plant, intake and discharge canals, and into the Atlantic Ocean. http://www.fnai.org/biointro.cfin.
Accessed April 6, 2017. IPaC Application Accessed April 6, 2017. Y:\GDPIF1301\150595\S1LUCENTRCHAR.DOCX--Dl0218 5-3 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan The operating license for Unit 1 was issued by the NRC in 197 6, but no ESA consultation was conducted.
In 1982, 1997, 2001, and 2016, NMFS issued biological opinions to the NRC for the operation of the St. Lucie Plant The 1982 biological opinion concluded Unit 2 was not likely to jeopardize the continued existence of any-listed species under NMFS jurisdiction, but no estimate of incidental take was made. Due to the incidence of sea turtle takes at the facility, the NRC r:einitiated consultations in 1995. NMFS issued a biological opinion in 1997 with the conclusion that continued operation of the St. Lucie P-lant was not likely to jeopardize the continued existence of listed species under NMFS-jurisdiction.
NM.FS also issued-antic1pated annual incidental take numbers for five sea turtle species:=-foggerhead (Caretta caretta), Kemp's ridley (Lepi-dochelys-kempiz), green (Chelonia mydas), leatherback (Dermochelys coriacea), and hawksbill (Eretmochelys--imbricata).
In 1999, the St. Lucie Plant exceeded the anticipated incidental take of green sea turtles, and the NRC reinitiated consultation again. NMFS issued a biological opinion in 2oq1 that concluded the continued operation of the St. Lucie Plant was not likely to jeopardize the continued existence of green, leath~rback, hawksbill, or Kemp's ridley sea turtles or loggerhead sea turtles, and an incidental take authorization for these species was issued. -FPL, NRC, and NMFS interacted throughout the 2000s and 201 Os, and small tooth sawfish was added to the biological opinion that was issued in 2016. This biological opinion concluded the continued operation of the St. Lucie Plant is not likely to jeopardize the continued existence of green, hawks bill_, Kem_p' s ridley, or leatherback sea turtle; northwest Atlantic distinct population se_gment of loggerhead sea turtle; or United States distinct population segment of smalltooth sawfish. NMFS also-found-the St. Lucie Plant is rrot likely to destroy or adversely modify the designated critical habitat of the northwest Atlantic distinct population segment. An incidental take statement was included for sea turtles and smalltooth sawfish. Y:\GDP\Fl30J\150595\STLUCENTRCHAR.DOCX-OJ0218 5-4 Florida Power & Light Company St. Lucie Nuclear Power Plant 6.0 ENTRAINMENT STUDY PLAN Entrainment Characterization Study Plan This-section provides an overview of the entrainment sampling-to be conducted at the St. Lucie Plant. A site-specific standard operating procedure (SOP} will be developed prior to the initiation of sampling activities, along with a site-specific-health and safety plan. 6.1 ENTRAil~lVIENT -CHARACTERIZATION The objective of the entrainment sampling program is to identify and quantify or:ganisms that pass through the intakes' screening systems and become entrained during normal plant operations.
Vulr.1erability to entrainment is relatecl to size, motility, and-habitat preferences, hut entrainable organisms generally
_include fish-eggs, larvae, small juveniles, and larval stages of shellfish.
Data coilected within this sampling program will be used to identify species and life stages affected,_
characterize temporal trends in entrainment rates (both diel and seasonal), and support the site-specific determination ofBTA for entrainment.
Entrainment will be considered in absolute terms and extrapolated to a common-age basis to estimate loss of standing stock and/or monetized loss. The data on entrainment will also inform the evaluation-of the effectiveness_of fine-mesh screens_and potential for seasonal deployment of entrainment mitigation measures ( e.g., flow reduction, fine-mesh that are deployed for portions of the year). Consistent with-these goals, entrainment samples will be enumerated, identified, and-subjected to length measurements.
6.1.1 SAMPLING_FREQlJEN-cY AND METHODOLOGY Entrainment sampling wi-11 occur every two weeks (biweekly) over a 24-hour period, with entrainment subsamples being collected apprnximately every -six hours. The sampling program will include one year of entrainment sampling to supplement the 21 months of data collected during the Phase II rule. Sampling methodology will therefore, to a great extent, follow the Phase II study protocols.
Samples will be collected at the seaward end of the intake canal as water first enters the cooling system, which is defined by the rule to include the canal. This represents the best location to define the rate of entrainment from the source water into the cooling system. Samples will be collected twice during the day and twice at night to approximately coincide with periods of high and low tide. The high-Y:\GDPIF1301\150595\STLUCENlRCHARDOCX--010218 6-1 Florida Power & Light Company St. Lucie Nuclear Power Plant Entrainment Characterization Study Plan and low-tide samples for each photoperiod will be composited in the laboratory, yielding a total of two entrainment samples per sampling event (i.e., a day and night sample). Samples will be collected using a plankton net lowered into the intake-canal.
1.=he net :will have a I-meter diameter mouth, 5:1 length-to-diameter ratio, and300-micron mesh and will be fished at* mid-depth for approximately 5 minutes if both units are running-or lff minutes if only one unit is running. This method will sample approximately 130 to 200 cubic meters, and the actual sample volume will be measur-ed using a flow meter at the mouth of the net. At the conclusion of each sample collection, the contents of the plankton net will be rinsed-down with source water from-the outside of the net and carefully transferred to labeled sample jars and preserved for-,malysis.
 
====6.1.2 SAMPLE====
ANALYSIS -In the laboratory, ichthyoplankton-and targeted shellfish meroplankton will be separated from detritus (sorted), identified to the lowest practical taxon, and enumerated by life stage (e.g., egg, yolk-sac larvae, post-yolk-sac larvae, or juvenile for fish; zoea or megalopa for shellfish).
For ichthyoplankton, notochord length and the greater of either body depth or head capsule height will -be measured to the nearest O .1 mm for a subset of 3 0 individuals of each taxon of fish larvae to allow for assessment of fine-mesh screen performance.
For shellfish meroplankton taxa, the greatest body dimension will be measured for a sufficient number of each life stage to characterize the numb-er of meroplankters in size classes of less than 1 mm, 1 to 2 mm, 2 to 9 mm, and greater than 9 mm. Ecological Associates Inc.' s laboratory SOP -provides_a detailed.
description of laboratory procedures.
 
===6.2 SUPPORTING===
 
DATA COLLECTION Supporting data collection will include in situ measurements of pH, temperature, salinity, and dissolved oxygen during each sample collection.
Field notes will be taken to note wind and weather conditions, tide stage, departures from the standard sampling protocol, and observed departures from normal plant operations ( e.g., circulating water pump or screen wash operations, etc.). Daily circulating water pump rates will be obtained from plant operators for normalization of results to actual flow rates. Y:\GDP\Fl301\!50595\STLUCENIRCHAllDOCX-010218 6-2 Florida Power & Light Company St. Lucie Nuclear Power Plant 6.3 QUALITY CONTROL Entrainment Characterization Study Plan The field data will be collec1ed m compliance with the quality assurance protocols established h1 the site-specific SOP. The SOP establishes consistent, accurate, --and reliable methods for aata capture and outlines general procedures used programwide to ensure data are scientifically valid and defensible.
Included in the SOP are procedures to ensure the sorting of entrainment samples is performed consistently, and sorters are provided initial training_
and certification so_ each_ sorter achieves at least 95-percent sorting efficiency.
In addition, taxonomic quality assm:ance is conducted-by a-second taxonomist for 10-percent of the sampies. -Percent taxonomic disagreement (number of taxonomic disagreements divided by the total number of organisms in the sample)_must be below.15 percent. Identifications in disagreement are discussed between the taxonomists, and an agreement is reached through consultation-with the scientific literature, comparison with reference specimens, and/or verification by additional taxonomists.
In addition to the quality assurance measurements described herein, the data, from collection through reporting, -go through a series of verification checks. Prior to leaving the field; the field team leader reviews the field data sheets to_ensure the required-data have been collected and the forms are complete.
In the laboratory, data are entered into efectronic databases, and entries are verified against the original field data sheets. Once the-data are assembled into report tables, the tables are checked against the electronic database to ensllre the summaries are correct. 6.4 REPORTING Reports from the laboratory will be generated to include electronic databases (Microsoft EY.cel&#x17d; or Access&#x17d;) containing the resulting sample data along with relevant metadata (e.g., sample volume, date and time, water quality).
The sample results will then be summarized Ill the entrainment characterization report called for under 40 CFR 122.21(r)(9).
Y:\GDPIFl3 01 \150595\STLUCENTRCHAR.DOCX--Ol 0218 6-3 Florida Power & Light Company St Lucie Nuclear Power Plant 6.5 HEAL TH AND SAFETY Entrainment Characterization Study Plan A site-specific health and safety plan will be developed prior to field sampling to ensure the safety of both individuals collecting the samples as well as plant staff. -Prior to conducting the first field sampling at the plant, employees will undergo training required for working at the nuclear plant. During each sampli.r1g event and prior to initiating a sampling activity onsite, the field team leader will also conduct a safety tailgate meeting with the field team members to review expected weather conditions, sampling procedures, potential hazards and risks, and pertinent field safety issues prior to the-commencement of field operations.
Personnel involved in sampli...1g and relevant hazard/safety issues discussed prior to work onsite will be recorded for each event~ 6.6 SCHEDULE Entrainment sampling is tentatively scheduled-to begin in November 2017 and will continue-through mid-October 2018. Y:\GDP\FI301\!50595\STI.UCENTRCHARDOCX-0!0218 6-4 Florida Power & Light Company St Lucie Nuclear Power Plai1t
 
==7.0 REFERENCES==
 
Entrainment Characterization Study Plan Applied Biology, Inc. 1982. Florida Power & Light Company St. Lucie Plant Annual Non-radiological Environmental Monitoring Report -1981. February.
Britannica.
2017. Atlantic Ocean. Encyclopredia BritanniGa.
Accessed online March 2017. https://www.britannica.com/place/
Atlantic-Ocean.
Coastal Data Information Program. 2017. Buoy 134-Fort Pierce, FL. Accessed online March 2017. http://cdip.ucsd.edu/?nav=historic&sub=data&stn=
134-&stream=p 1 Ecological Associates, Inc. 2001. Survey of Aquatic Environments Potentially .Affected by the Operation of the St. Lucie Power Plant; Hutchinson Island, Florida. April. Florida Power & Light Company (FPL)~ 2005. Clean Water AG_Ll>ection 3 l 6(b) Phase II -Proposal for Information Collection St-Lucie Nuclear Power Plant. Prepared-for FPL by Golder Associates, -May. ---. 2016. St. Lucie Power Plant Permit No. FL0002208 IWW Permit Renewal Application.
Submitted to FDEP. March 29. Florida Natural Areas Inventory (FNAI). 2017. FNAI Biodiversity Matrix. http://www.fnai.org/biointro.cfm.
Accessed April 2017. National Marine Fisheries Service (NMFS). 2015. Endangered and Threatened Marine Species under Nl\1FS' JurisdiGtion.
http://www.nmfs.noaa.gov/pr/species/esa/
listed.htm.
Accessed April 2015. Natiunal Oceanic and Atmospheric-Administration (NOAA). 2016. Endangered-Species Act of 1973. Section 7-Biological Opinion for the Continued Operatiorrof St. Lucie Nuclear Power Plant, Units 1 and 2 in St. Lucie County, Florida. March. ---. 2017a. Chart 11472 36th edition,-Februar-y 2014, Last Corrected March 15,2017. Accessed March 2011. http:/h.vww.charts.noaa.gov/OnLineViewer/11472.shtmL
---. 2017b. Chart 11474 11th edition, February 2011. Last-corrected January 20, 2016-. Accessed March 201 T. http://www_charts.noaa.ge:v/OnLineViewer/
11474.shtml.
U.S-. Nuclear Regulatory Commission (NRC). 1982. Final Environmental Statement related to the operation of St. Lucie Plant Unit No. 2, Docket No. 50-389, Florida Power & Light Company. April. Y:\GDPIF1301\150595\S1LUCENTRCHAR.DOCX-010218 7-1 i=C'T}}

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