ML16015A365

Official Exhibit - NRC-019-00-BD01 - Memorandum from Briana Grange and Dennis Logan, NRC, to David J. Wrona, Chief, Environmental Review and Guidance Update Branch, NRC, Summary of Meeting with U.S. Fish and Wildlife Service'S South Florida

ML16015A365
Person / Time
Site:	Turkey Point
Issue date:	08/15/2014
From:	NRC/OGC
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 28492, ASLBP 15-935-02-LA-BD01, 50-250-LA, 50-251-LA
Download: ML16015A365 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 15, 2014 MEMORANDUM TO:

David J. Wrona, Chief Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation FROM: Briana Grange, Biologist

/RA/ Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation Dennis Logan, Aquatic Biologist

/RA Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation

SUMMARY

OF TRIP TO THE U.S. FISH AND WILDLIFE SERVICE'S SOUTH FLORIDA ECOLOGICAL SERVICES OFFICE REGARDING ENDANGERED SPECIES ACT SECTION 7 CONSULTATION FOR TURKEY POINT NUCLEAR GENERATING UNITS NOS. 3 AND 4 Participants U.S. Nuclear Regulatory Commission (NRC)

Briana Grange Dennis Logan Harriet Nash*

U.S. Fish and Wildlife Service (FWS)

Ashleigh Blackford Laura Brandt*

Patrick Pitts John Wrublik

Florida Power & Light Company (FPL)

Stacy Foster Jodie Gless James Petro*

Matthew Raffenberg

• participated via phone Location FWS South Florida Ecological Services Office 1339 20th Street Vero Beach, Florida 32960 Summary O n Tuesday, July 22, 2014, staff from the NRC, FWS, and FPL met to discuss the potential impacts of several actions on the population of American crocodiles (Crocodylus acutus) that inhabit the Turkey Point Nuclear Generating Units Nos. 3 and 4 (Turkey Point) site. These actions included: (1) the FPL's July 10, 2014, license amendment request (LAR) that would revise the ultimate heat sink (UHS) temperature limit specified in Turkey Point's technical specifications (TSs); (2) recent State approval to chemically treat the cooling canal system (CCS) to eradicate blue green algae; and (3) current and future withdrawals from the Floridan and Biscayne Aquifers. The intended outcome of the meeting was to determine whether NRC should reinitiate consultation under section 7 of the Endangered Species Act of 1973, as amended in conjunction with its LAR review. The meeting's agenda is attached as Enclosure 1, and the meeting's handouts are attached as Enclosure 2

. Elevated CCS Algae Concentrations

FPL began the meeting by explaining the history of the CCS algae issue. FPL first noticed elevated algae concentrations in 2011 during work associated with the Turkey Point extended power uprate (EPU). In August 2012, CCS water samples indicated a cell count of approximately 680,000 cyanobacteria cells/mL of water. In September 2012, the count had decreased to about 374,000 cells/mL of water. By November 2012, the cell count was back up to August 2012 levels

. FPL hired Enercon Services, Inc. to perform testing, determine the cause of the algal blooms, and propose solutions.

FPL has not been able to determine a clear cause

-and-effect relationship but believes that shutdown s of the Turkey Point units (both the nuclear Units 3 and 4 as well as the oil/natural gas-fired Units 1 and 2) may have initially contributed to the algal bloom by reducing CCS water flow and creating more favorable conditions for algal growth.

Presently, Unit 1 is brought online only during periods of peak energy demand

Unit 2 is shut down; and Units 3 and 4 were each offline at different times to complete EPU

-related work. FPL indicated that this theory was anecdotally confirmed when the algae cell count went down following restart of Units 3 and 4.

Algae Treatments In June 2014, FPL sought approval from the Florida Department of Environmental Protection (FDEP) to treat the CCS with copper sulfate (CuSO 4), hydrogen peroxide (H 2 O 2), and a bio

-stimulant on a trial basis. FDEP approved FPL's request on June 27, 2014. FPL began its first trial treatment on July 2, 2014. The treatment consisted of a 2

-day-on, 5-day-off schedule, and chemicals were added to the north side of the CCS and dispersed throughout the system through normal water flow. The algae did not appear to respond to the 2-day treatments

, so FPL has begun treating the system for 5

-day periods. A slight decrease in algae concentrations has resulted (from 1.8 million cells/mL to 1.3 million cells/mL

). FPL stated that 50,000 cells/mL would be an "okay" concentration.

Effects of Algae Treatments FWS asked if the fish population has declined or if there have been any dead crocodiles found on the site. FPL stated that its staff and contractors have not observed any fish kills as either a result of the high algae concentrations or subsequent chemical treatments, nor have any dead crocodiles been discovered in or near the CCS. This year (to date), FPL has observed about 25 crocodile nests and recorded about 396 hatchlings. FPL collects the hatchlings and releases them in the mitigation bank south of the CCS. FPL believes that this practice would initially minimize hatchlings' exposure to the CCS.

Factors Contributing to Temperature and Salinity Increases

FWS asked if CCS temperatures and salinity have increased as a result of the EPU. FPL indicated that none of the observed changes in CCS conditions (increased temperature and salinity level) can be clearly attributed to the EPU because of several compounding factors. Besides the high algae concentration s , FPL indicated that low rainfall is likely contributing to CCS conditions. FPL has only measured 4 inches of rainfall on the site so far this year, whereas they had measured 52.18, 74.25, and 19.65 inches in 2011, 2012, and 2013, respectively. This has resulted in an associated decrease in the CCS water level. FPL indicated that the CCS water level had decreased from 0.47 feet below mean sea level (MSL) in 2012 to 0.88 feet below MSL in 2014. CCS salinity levels are also high (90

-91 parts per thousand [ppt]). In the past, FPL said that the salinity level has reached 80 ppt in the summer. FPL indicated that it has incrementally powered down and powered up Units 1 and 2 and observed no effect on CCS temperatures, so FPL concludes that plant operation is not a major temperature driver. FPL thinks that cleaner water enhances heat exchange and that the turbidity from the high algae concentrations is hindering heat release.

FWS asked about reports on CCS salinity and temperature sent to FWS from the Miami

-Dade Water and Sewer Department. FPL said that the data in those reports are preliminary and won't be validated until the annual report comes out in August.

Copper Accumulation and Ongoing Monitoring FWS and NRC expressed concerns about bioaccumulation of copper from the chemical treatments. FPL said that the FDEP has required FPL to perform additional monitoring to measure copper concentrations. Additionally, physical and chemical monitoring (mostly using probes) will continue as will water budget calculations, and ecological monitoring (submerged aquatic vegetation, marshes, and bay transects) will continue around the CCS.

Long Term Solutions FPL considers the chemical treatments to be a short term fix to the algae issue and is currently seeking a long term solution. FPL is unsure of what the long term solution will be, but it is looking into aerating and demucking the bottom of the canals. This could help to remove excess copper, as well. FPL has also formed a long

-term action team, which includes a Biscayne Bay expert and crocodile experts involved in the site's crocodile monitoring program. Aquifer Withdrawals

FWS asked about FPL's plans for current and future aquifer withdrawals. FPL explained that the CCS is situated above two aquifers:

the shallower saltwater Biscayne Aquifer and the deeper brackish Floridan Aquifer. A confining layer separates the two aquifers from one another. Turkey Point, Unit 5, uses the Floridan Aquifer for cooling water. The South Florida Water Management District (SFWMD) granted FPL approval to withdraw a portion (approximately 5 million gallons per day [MGD]) of the Unit 5 withdrawal allowance for use in the CCS. FPL began pumping Floridan Aquifer water into the CCS in early July. FPL has also received temporary approval to withdraw 30 MGD from the Biscayne Aquifer, though FPL has not yet used this allowance. FPL also anticipates the FDEP to issue an Administrative Order requiring FPL to install up to six new wells that will pump approximately 14 MGD of water from the Floridan Aquifer into the CCS. Modeling performed by FPL consultants and the SFWMD indicates that in approximately two years, the withdrawals would reduce the salinity of the CCS to the equivalent of Biscayne Bay (about 34 ppt). FPL believes that such withdrawals could als o help moderate water temperatures.

Crocodile Monitoring FPL's next crocodile spotlight survey is scheduled for August

, and the next capture survey will be in September. Although FPL typically has the contractor provide its results in an annual report, FPL is willing to provide a semi

-annual report if FWS or NRC would like to see the results before the end of the year. FWS said that it would like a semi-annual report. FPL will have the contractor prepare a semi

-annual report and should be able to distribute that report by the end of August.

Proposed UHS Temperature Limit Increase FPL explained the regulatory process associated with FPL's July 10, 2014, application to the NRC to increase the UHS temperature limit specified in the Turkey Point TSs. FPL stated that it is not asking to put any additional heat load into the system. The request was submitted solely based on the previous topics of discussion (high algae concentrations, low rainfall conditions). FPL briefly described the NRC's granting of a Notice of Enforcement Discretion (NOED) on July 20, 2014, which allows FPL to operate up to 103°F for up to 10 days. FPL indicated that the highest temperature it had measured during the NOED period to date is 101°F.

Reinitiation of Consultation NRC asked FWS if it believes that the information reviewed at the meeting warrants reinitiation of section 7 consultation. FWS said that yes, NRC should reinitiate consultation. Based on the meeting, FWS believes that there is the potential for impacts to crocodiles. NRC should address the proposed UHS temperature increase as well as the chemical treatments and aquifer withdrawals since these are contributing to current CCS conditions

.

NRC agreed with FWS's recommendation to reinitiate consultation, and NRC and FWS discussed how the two agencies could accelerate the consultation process in order to support the NRC's expedited review of the July 10, 2014, LAR to increase the UHS TS temperature limit.

FPL agreed to provide NRC with additional written information and copies of monitoring reports to aid the NRC in developing a biological assessment.

Docket No s. 50-250 and 50-251

Enclosures:

As stated

ML14216A533

• concurred via email OFFICE LA:DLR AB:RERB:DLR AB:RERB:DLR NAME IKing* BGrange DLogan DATE 8/11/14 8/14/14 8/15/14 Memorandum to D. Wrona from B. Grange and D

. Logan dated August 15, 2014

SUMMARY

OF TRIP TO THE U.S. FISH AND WILDLIFE SERVICE'S SOUTH FLORIDA ECOLOGICAL SERVICES OFFICE REGARDING ENDANGERED SPECIES ACT SECTION 7 CONSULTATION FOR TURKEY POINT NUCLEAR GENERATING UNITS NOS. 3 AND 4 DISTRIBUTION:

E-MAIL: EndangeredSpecies Resource RidsNrrDlrRerb Resource RidsNrr PMTurkeyPoint BGrange DLogan DWrona AKlett, DORL LRegner, DORL HNash, NRO ENCLOSURE 1 AGENDA July 22, 2014 Crocodile Meeting: FWS, NRC and FPL I. Introductions II. Factors attributed to algal bloom and temperature III. Short term and long term corrective action IV. Crocodile monitoring V. Additional questions and comments VI. Adjour n ENCLOSURE 2 Current Water Quality Monitoring CCS Parameter Frequency Locations (see attached maps)

TN, TP, Total Cu, TSS BOD Weekly 4 SW locations (CCS 1,3,4 and 6)

Algae Count 2 x Week (Mon and Thurs) 3 SW location (CCS 1, 4 and 6) pH, DO, Salinity, Specific Cond., Temp 2 x Daily 4 SW locations (CCS 1,3,4 6 and injection point) pH, Salinity, Specific Cond., Temp Automated (hourly) 7 SW locations (CCS 1

-7) GW Wells Biscayne Bay (TPGW 10-11-14) Cu soil Weekly 4 locations (CCS 1,3,4 and 6) pH, DO, Salinity, Specific Cond., Temp, Turbidity, Sodium, Chloride, Tritium December and June 2 x Year All SW and GW Stations pH, DO, Salinity, Specific Cond., Temp, Turbidity, Calcium, Magnesium, Potassium Sodium Strontium, bromide Chloride, sulfate, sulfide, alkalinity and bicarbonate alkalinity.

TN, TKN, Nitrite+

Nitrate, TP, Ammonia, unionized ammonia, Ortho Phosphate, Tritium

- TDS in GW March and September 2 x Year All SW and TPGW

- 1, 2, 10, 13 and 14 Treatment process:

1. Initial 36hr Shock treatment on 07/02

- 07/04/14 - 2 days 2. 2nd 36hr treatment on 07/10

- 07/11/14 - 2 days 3. Current treatment schedule began 07/14

- scheduled to run 5 days with 2 days off for the next 6 weeks.

ENCLOSURE 2

ENCLOSURE 2

ENCLOSURE 2

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 15, 2014 MEMORANDUM TO:

David J. Wrona, Chief Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation FROM: Briana Grange, Biologist

/RA/ Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation Dennis Logan, Aquatic Biologist

/RA Environmental Review and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation

SUMMARY

OF TRIP TO THE U.S. FISH AND WILDLIFE SERVICE'S SOUTH FLORIDA ECOLOGICAL SERVICES OFFICE REGARDING ENDANGERED SPECIES ACT SECTION 7 CONSULTATION FOR TURKEY POINT NUCLEAR GENERATING UNITS NOS. 3 AND 4 Participants U.S. Nuclear Regulatory Commission (NRC)

Briana Grange Dennis Logan Harriet Nash*

U.S. Fish and Wildlife Service (FWS)

Ashleigh Blackford Laura Brandt*

Patrick Pitts John Wrublik

Florida Power & Light Company (FPL)

Stacy Foster Jodie Gless James Petro*

Matthew Raffenberg

• participated via phone Location FWS South Florida Ecological Services Office 1339 20th Street Vero Beach, Florida 32960 Summary O n Tuesday, July 22, 2014, staff from the NRC, FWS, and FPL met to discuss the potential impacts of several actions on the population of American crocodiles (Crocodylus acutus) that inhabit the Turkey Point Nuclear Generating Units Nos. 3 and 4 (Turkey Point) site. These actions included: (1) the FPL's July 10, 2014, license amendment request (LAR) that would revise the ultimate heat sink (UHS) temperature limit specified in Turkey Point's technical specifications (TSs); (2) recent State approval to chemically treat the cooling canal system (CCS) to eradicate blue green algae; and (3) current and future withdrawals from the Floridan and Biscayne Aquifers. The intended outcome of the meeting was to determine whether NRC should reinitiate consultation under section 7 of the Endangered Species Act of 1973, as amended in conjunction with its LAR review. The meeting's agenda is attached as Enclosure 1, and the meeting's handouts are attached as Enclosure 2

. Elevated CCS Algae Concentrations

FPL began the meeting by explaining the history of the CCS algae issue. FPL first noticed elevated algae concentrations in 2011 during work associated with the Turkey Point extended power uprate (EPU). In August 2012, CCS water samples indicated a cell count of approximately 680,000 cyanobacteria cells/mL of water. In September 2012, the count had decreased to about 374,000 cells/mL of water. By November 2012, the cell count was back up to August 2012 levels

. FPL hired Enercon Services, Inc. to perform testing, determine the cause of the algal blooms, and propose solutions.

FPL has not been able to determine a clear cause

-and-effect relationship but believes that shutdown s of the Turkey Point units (both the nuclear Units 3 and 4 as well as the oil/natural gas-fired Units 1 and 2) may have initially contributed to the algal bloom by reducing CCS water flow and creating more favorable conditions for algal growth.

Presently, Unit 1 is brought online only during periods of peak energy demand

Unit 2 is shut down; and Units 3 and 4 were each offline at different times to complete EPU

-related work. FPL indicated that this theory was anecdotally confirmed when the algae cell count went down following restart of Units 3 and 4.

Algae Treatments In June 2014, FPL sought approval from the Florida Department of Environmental Protection (FDEP) to treat the CCS with copper sulfate (CuSO 4), hydrogen peroxide (H 2 O 2), and a bio

-stimulant on a trial basis. FDEP approved FPL's request on June 27, 2014. FPL began its first trial treatment on July 2, 2014. The treatment consisted of a 2

-day-on, 5-day-off schedule, and chemicals were added to the north side of the CCS and dispersed throughout the system through normal water flow. The algae did not appear to respond to the 2-day treatments

, so FPL has begun treating the system for 5

-day periods. A slight decrease in algae concentrations has resulted (from 1.8 million cells/mL to 1.3 million cells/mL

). FPL stated that 50,000 cells/mL would be an "okay" concentration.

Effects of Algae Treatments FWS asked if the fish population has declined or if there have been any dead crocodiles found on the site. FPL stated that its staff and contractors have not observed any fish kills as either a result of the high algae concentrations or subsequent chemical treatments, nor have any dead crocodiles been discovered in or near the CCS. This year (to date), FPL has observed about 25 crocodile nests and recorded about 396 hatchlings. FPL collects the hatchlings and releases them in the mitigation bank south of the CCS. FPL believes that this practice would initially minimize hatchlings' exposure to the CCS.

Factors Contributing to Temperature and Salinity Increases

FWS asked if CCS temperatures and salinity have increased as a result of the EPU. FPL indicated that none of the observed changes in CCS conditions (increased temperature and salinity level) can be clearly attributed to the EPU because of several compounding factors. Besides the high algae concentration s , FPL indicated that low rainfall is likely contributing to CCS conditions. FPL has only measured 4 inches of rainfall on the site so far this year, whereas they had measured 52.18, 74.25, and 19.65 inches in 2011, 2012, and 2013, respectively. This has resulted in an associated decrease in the CCS water level. FPL indicated that the CCS water level had decreased from 0.47 feet below mean sea level (MSL) in 2012 to 0.88 feet below MSL in 2014. CCS salinity levels are also high (90

-91 parts per thousand [ppt]). In the past, FPL said that the salinity level has reached 80 ppt in the summer. FPL indicated that it has incrementally powered down and powered up Units 1 and 2 and observed no effect on CCS temperatures, so FPL concludes that plant operation is not a major temperature driver. FPL thinks that cleaner water enhances heat exchange and that the turbidity from the high algae concentrations is hindering heat release.

FWS asked about reports on CCS salinity and temperature sent to FWS from the Miami

-Dade Water and Sewer Department. FPL said that the data in those reports are preliminary and won't be validated until the annual report comes out in August.

Copper Accumulation and Ongoing Monitoring FWS and NRC expressed concerns about bioaccumulation of copper from the chemical treatments. FPL said that the FDEP has required FPL to perform additional monitoring to measure copper concentrations. Additionally, physical and chemical monitoring (mostly using probes) will continue as will water budget calculations, and ecological monitoring (submerged aquatic vegetation, marshes, and bay transects) will continue around the CCS.

Long Term Solutions FPL considers the chemical treatments to be a short term fix to the algae issue and is currently seeking a long term solution. FPL is unsure of what the long term solution will be, but it is looking into aerating and demucking the bottom of the canals. This could help to remove excess copper, as well. FPL has also formed a long

-term action team, which includes a Biscayne Bay expert and crocodile experts involved in the site's crocodile monitoring program. Aquifer Withdrawals

FWS asked about FPL's plans for current and future aquifer withdrawals. FPL explained that the CCS is situated above two aquifers:

the shallower saltwater Biscayne Aquifer and the deeper brackish Floridan Aquifer. A confining layer separates the two aquifers from one another. Turkey Point, Unit 5, uses the Floridan Aquifer for cooling water. The South Florida Water Management District (SFWMD) granted FPL approval to withdraw a portion (approximately 5 million gallons per day [MGD]) of the Unit 5 withdrawal allowance for use in the CCS. FPL began pumping Floridan Aquifer water into the CCS in early July. FPL has also received temporary approval to withdraw 30 MGD from the Biscayne Aquifer, though FPL has not yet used this allowance. FPL also anticipates the FDEP to issue an Administrative Order requiring FPL to install up to six new wells that will pump approximately 14 MGD of water from the Floridan Aquifer into the CCS. Modeling performed by FPL consultants and the SFWMD indicates that in approximately two years, the withdrawals would reduce the salinity of the CCS to the equivalent of Biscayne Bay (about 34 ppt). FPL believes that such withdrawals could als o help moderate water temperatures.

Crocodile Monitoring FPL's next crocodile spotlight survey is scheduled for August

, and the next capture survey will be in September. Although FPL typically has the contractor provide its results in an annual report, FPL is willing to provide a semi

-annual report if FWS or NRC would like to see the results before the end of the year. FWS said that it would like a semi-annual report. FPL will have the contractor prepare a semi

-annual report and should be able to distribute that report by the end of August.

Proposed UHS Temperature Limit Increase FPL explained the regulatory process associated with FPL's July 10, 2014, application to the NRC to increase the UHS temperature limit specified in the Turkey Point TSs. FPL stated that it is not asking to put any additional heat load into the system. The request was submitted solely based on the previous topics of discussion (high algae concentrations, low rainfall conditions). FPL briefly described the NRC's granting of a Notice of Enforcement Discretion (NOED) on July 20, 2014, which allows FPL to operate up to 103°F for up to 10 days. FPL indicated that the highest temperature it had measured during the NOED period to date is 101°F.

Reinitiation of Consultation NRC asked FWS if it believes that the information reviewed at the meeting warrants reinitiation of section 7 consultation. FWS said that yes, NRC should reinitiate consultation. Based on the meeting, FWS believes that there is the potential for impacts to crocodiles. NRC should address the proposed UHS temperature increase as well as the chemical treatments and aquifer withdrawals since these are contributing to current CCS conditions

.

NRC agreed with FWS's recommendation to reinitiate consultation, and NRC and FWS discussed how the two agencies could accelerate the consultation process in order to support the NRC's expedited review of the July 10, 2014, LAR to increase the UHS TS temperature limit.

FPL agreed to provide NRC with additional written information and copies of monitoring reports to aid the NRC in developing a biological assessment.

Docket No s. 50-250 and 50-251

Enclosures:

As stated

ML14216A533

• concurred via email OFFICE LA:DLR AB:RERB:DLR AB:RERB:DLR NAME IKing* BGrange DLogan DATE 8/11/14 8/14/14 8/15/14 Memorandum to D. Wrona from B. Grange and D

. Logan dated August 15, 2014

SUMMARY

OF TRIP TO THE U.S. FISH AND WILDLIFE SERVICE'S SOUTH FLORIDA ECOLOGICAL SERVICES OFFICE REGARDING ENDANGERED SPECIES ACT SECTION 7 CONSULTATION FOR TURKEY POINT NUCLEAR GENERATING UNITS NOS. 3 AND 4 DISTRIBUTION:

E-MAIL: EndangeredSpecies Resource RidsNrrDlrRerb Resource RidsNrr PMTurkeyPoint BGrange DLogan DWrona AKlett, DORL LRegner, DORL HNash, NRO ENCLOSURE 1 AGENDA July 22, 2014 Crocodile Meeting: FWS, NRC and FPL I. Introductions II. Factors attributed to algal bloom and temperature III. Short term and long term corrective action IV. Crocodile monitoring V. Additional questions and comments VI. Adjour n ENCLOSURE 2 Current Water Quality Monitoring CCS Parameter Frequency Locations (see attached maps)

TN, TP, Total Cu, TSS BOD Weekly 4 SW locations (CCS 1,3,4 and 6)

Algae Count 2 x Week (Mon and Thurs) 3 SW location (CCS 1, 4 and 6) pH, DO, Salinity, Specific Cond., Temp 2 x Daily 4 SW locations (CCS 1,3,4 6 and injection point) pH, Salinity, Specific Cond., Temp Automated (hourly) 7 SW locations (CCS 1

-7) GW Wells Biscayne Bay (TPGW 10-11-14) Cu soil Weekly 4 locations (CCS 1,3,4 and 6) pH, DO, Salinity, Specific Cond., Temp, Turbidity, Sodium, Chloride, Tritium December and June 2 x Year All SW and GW Stations pH, DO, Salinity, Specific Cond., Temp, Turbidity, Calcium, Magnesium, Potassium Sodium Strontium, bromide Chloride, sulfate, sulfide, alkalinity and bicarbonate alkalinity.

TN, TKN, Nitrite+

Nitrate, TP, Ammonia, unionized ammonia, Ortho Phosphate, Tritium

- TDS in GW March and September 2 x Year All SW and TPGW

- 1, 2, 10, 13 and 14 Treatment process:

1. Initial 36hr Shock treatment on 07/02

- 07/04/14 - 2 days 2. 2nd 36hr treatment on 07/10

- 07/11/14 - 2 days 3. Current treatment schedule began 07/14

- scheduled to run 5 days with 2 days off for the next 6 weeks.

ENCLOSURE 2

ENCLOSURE 2

ENCLOSURE 2