L-2018-228, Environmental Protection Plan Report: Test Evaluation Report

Environmental Protection Plan Report: Test Evaluation Report

ML18362A104
Person / Time
Site:	Saint Lucie
Issue date:	12/28/2018
From:	Synder M J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2018-228
Download: ML18362A104 (132)

Text

• F=PL. .. U.S. Regulatory Commission Attn: Document Control Desk Washington , DC 20555 RE: St. Lucie Units 1 and 2 DEC 2 8 2018 Docket Nos. 50-335 and 50-389 Environmental Protection Plan Report Test Evaluation Report

Reference:

L-2018-228 10 CFR 50.4 EPP 4.2 1. NRC letter dated April 7 , 2016: Transmittal of National Marine Fisheries Service's March 24, 2016 , Final Biological Opinion For St. Lucie Plant, Uni t s 1 And 2 The attached report is being submitted pursuant to the requirements of Biological Opinion described in the above Reference 1 and Section 4.2 of the St. Lucie Units 1 and 2 Environmental Protection Plans. The Biological Opinion specifies the requirement for the attached report within Terms and Conditions (T&C 1) of Reasonable and Prudent Measures (RPM 1) as: Florida Power and Light Company (FPL) must submit a report of the test i ng and coordinate with NMFS and NRC before beginning inwater construction. The attached test evaluation report documents the preconstruction test failure of the fixed barrier device designed to be installed at the St. Lucie intake pipe velocity caps. Based on the test results, the attached test report also analyzes alternative options for the protection of sea turtles. If you have any questions or require additional information, please contact Mr. Michael Snyder, St. Lucie Licensing Manager, at (772) 467-7036. Michael J. Snyder Licensing Manager St. Lucie Plant MJS/rcs Attachment cc: Briana Grange, Biologist, U.S. Nuclear Regulatory Commission Ben Beasley, Environmental Review and NEPA Branch, NRR Audra Banks, National Marine Fisheries Service Meghan Koperski , FWC Imperiled Species Mgmt. Fl o rid a P ow er & Li g h t Company 6501 S. Ocea n Dr ive, Jensen B eac h , FL 34957

-.-.-,._ . : : ......... ---*-TEST EVALUATION REPORT TEST FAIL l) ... RE OF FIXEDBAHRJ Ea_qE)(:L CE FOR .... ... -* . --ST. LUClE NUCLEAR PLAN J (SLNPP) INTAKE PIPE VELOCITY CAP S Prepared by: Florida Power & Light Company St. Lucie Nuclear Power Plant Hutchinson Island, Florida December 6, 2018 ..... *. :

Te st F ailur e of F ixed Barrier Devi ce f o r S LNPP In t ake Pipe Veloci t y Caps 1.0 Exec u t i ve Su m mary In 2007, the Nuclear Regulatory Commission (NRC) reinitiated consultation with the National Marine Fisheries Service (NMFS) as a result of the lethal take of 22 hatchling turtles. The cause of the take was associated with an unidentified nest deposited within the intake canal. As a result of that consultation and per Section 7 of the Endangered Species Act (ESA), [Ref. 1], the National Marine Fisheries Service issued a Biological Opinion [Ref. 2] in March 2016 for the St. Lucie Nuclear Power Plant (SLNPP) with two Reasonable and Prudent Measures (RPMs): RPM 1: Avoid and minimize entrainment into the SLNPP intake canal. RPM 2: Avoid and minimize injurious or lethal take from entrainment into, entrapment in, capture in, and release from the SLNPP intake canal or from impingement at intake wells. Specifically, the 2016 Biological Opinion requires Florida Power & Light Company (FPL) to install barriers at the Ocean Intake Velocity Caps in order to avoid and minimize entrainment of mature egg-bearing sea turtles into the SLNPP intake canal. The configuration of the tu (tle barrier and subsequent testing was coordinated with the NMFS and the Nuclear Regulatory Commission

[Attachment 9]. To meet this end, FPL designed a barrier and built a test tank facility for observing and evaluating turtle interaction with the proposed barrier design. The test plan included testing 10 loggerhead turtles and 4 green turtles of various size classes. The test procedure and photos of the test facility are included in Attachment

1. Barrier testing commenced in December 2016 using live, healthy loggerhead and green sea turtles. Nine turtles were successfully exposed to the barrier without a failure. During testing of the barrier with the tenth turtle, the turtle appeared to. become wedged between the barrier cwd the mock velocity cap structure and unable to get free on his own. The test was suspended and the turtle was freed from the barrier without injury. The testing was subsequently terminated at the request of the regulato r y agencies as described in the test plan. Results of testing are included as Attachment

1. FPL consulted four experts with various types and levels of experience with turtles to analyze the test data and associated test failure (Attachments 3 thru 6). The individual reports are summarized as part of this report. The test observations and FPL's consultations with relevant experts provide reasonable evidence that any sea turtle barrier would present the potential for a turtle to be injured or killed. Moreover , excluding turtles with severe non-causal injuries reduces the opportunities for rescue and rehabilitation.

Based on the test results and consultation with these experts, FPL considered additional alternatives.

FPL considered the following two options to address the potential impact of the excluder test results: Option 1: Barrier Redesign Option 2: Maintain Programs and Identify and Minimize Negative Impacts Associated with Entrainment and Travel through the Intake Piping Assessment of Options Either of the two options proposed will adequately address the possible environmental impact to healthy adult sea turtles that may interact with the SLNPP. However, FPL has concluded that Option 2 is clearly preferab l e both in terms of plant operations as well as protection of sea turtles. Option 1: Barrier Redesign While feasible, this option would require additional testing and cannot be implemented in the timeframes provided under the 2016 Biological Opinion. This option would minimize the already small probability of a Page 2 of 33 .<>

Test F a i l ur e of F ix ed Barr i er De vi c e fo r SL N PP In take P i pe V e l oc i t y Caps lethal t a ke for healthy adult sea turtles entrained in the intake pipe (one since 2006) while it introduces a new entrainment risk at the velocity cap for sick or injured turtles. Notably, this option would also prevent the capture and rehabilitation of non-causal sick or injured sea turtles that historically have been routinely and successfully removed from the intake canal east ofthe 5-inch barrier net. Option 2: Main t ain Programs and Identify and Minimize Nega t ive Impac t s Associated with E n t rainmen t and Travel through the Intake Piping Option 2 would allow FPL to proceed without installation of a new barrier on the velocity caps at the intake structure.

Instead, under this option FPL would continue to rely on the 5-inch net in the intake canal and other enhancements that minimize negative impacts associated with entrainment and travel through the intake piping. This option offsets the minimal probability of lethal take from entrainment without a velocity cap barrier with the overwhelming benefits of rehabilitation successes for sick or injured sea turtles captured at the St. Lucie Plant. Based on the operating performance and reporting , the conservation gains associated with the capture and rehabilitation of sick and injured turtles significantly offsets the negligible adult mortality risk and minimal adult injury documented at the site. Additionally , Option 2 does not introduce the new entrainment risk associated with the velocity cap barrier. FPL has determined that Option 2 is the most appropriate action based on the material and information reviewed during FPL's barrier test, FPL's review of the literature on sea turtles and smalltooth sawfish and an evaluation demonstrating that Option 2 would result in the most benefit for the affected species. Additionally, FPL's analysis, and evaluation affirm the 2016 Biological Opinion's conclusion that continued operation of SLNPP is not likely to jeopardize the continued existence of green, hawksbill, Kemp's ridley, leatherback, or loggerhead sea turtles. Additionally, it is not likely to jeopardize the smalltooth sawfish, or to destroy or adversely modify the designated critical habitat of the loggerhead.

Because Option 2 does not include the installation of a barrier, its implementation would require the NMFS and NRC to make changes to the existing Terms and Conditions during the ongoing Section 7 consultation.

To restate simply, FPL concludes that Option 2 is the best alternative. The major reasons for this recommendation include 1) the increased risks to sick or injured turtles associated with the installation of a barrier under Option 1, 2) the very low percentage of turtle injuries currently associated with travel through the intake pipes, and 3) the concurrent benefit ofthe treatment that sick and injured (non-causal) turtles receive from staff biologists and subsequent rehabilitation, which is only made possible with the turtles' entrainment in the intake. Since Option 2 also includes additional measures to reduce harm during entrainment, FPL concludes that Option 2 provides the most benefit. Detailed discussion of the various alternatives and documentation of non-causal turtle illness, injuries and rehabilitation is provided in this report. Page 3 of 33 Test Fa ilu re of Fixed Barrier De vi ce for SLNPP I ntake Pipe Velocity Caps Table of Contents 1.0 Executive Summary ........................................................

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........................... 2 2.0 Background

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........................................ 5 2.1 Regulatory Background

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.... 5 2.2 Basis for Current Barrier Design ..............................................

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....... 6 2.3 The Tested Barrier ................................................

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8 2.4 Description of Test Facility and Procedure

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..................... 9 2.5 Rehabilitation of Sick and Injured Turtles ........................................................................................

9 3.0 Summary of Test Results ............

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12 4.0 Analysis of Test Results ....................................................

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...... 14 4.1 Analysis of Test Procedure and Facility ....................................

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..... 14 4.2 Analysis of Panel Design ...........................................

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......................... 15 4.3 Analysis of Barrier Location ............................................................................................................

15 4.4 Analysis Summary ...........................................................................................................................

16 5.0 Causal Factors ............

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............................ 17 5.1 Ocean Biota and Limited Access for Cleaning ................................................................................

18 5.2 Barrier Location ...................

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18 5.3 Limited Amount of Previous Test Data ................................................

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.. 19 5.4 Water Flow ............................................

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20 5.5 Testing Limitations

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20 6.0 Evaluation of Options ...................................................................................

...................................... 22 6.1 Option 1: Barrier Redesign .............................................................................................................

23 6.2 Option 2: Maintain Programs and Identify and Minimize Negative Impacts Associated with Entrainment and Travel through the Intake Piping ...............

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..................................... 25 6.3 Other Options ....................................................................................

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.. 30 7.0 Evaluation Summary I Recommended Actions .................

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31 7.1 Recommended Actions ......................

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31 8.0 References

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32 9.0 Attachments

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33 Page 4 of 33 T e st Fa il ure of Fixed Barr i er Dev i ce for SLNPP I ntake P i pe Ve l ocity Caps 2.0 Background

2.1 Regulatory

Background Per Section 7 of the ESA, [Ref. 1L the NMFS issued a Biological Opinion [Ref. 2] in March 2016 that requires the SLNPP to install barriers at the Ocean Intake Velocity Caps. Two separate events had resulted in that re-initiation of consultation between the NMFS and the NRC: 1) A non-lethal take of a smalltooth sawfish in May 2005. 2) A take of 211oggerhead hatchlings, due to an undetected sea turtle nest on the intake canal bank in October 2006. As part of that consultation process, a meeting between FPL, NMFS, and the NRC was held at SLNPP on April17-18, 2007 (Attachment 9). Mitigation measures to reduce impingement and entrainment of protected marine species , specifically sea turtles and smalltooth sawfish, were identified.

Actions suggested at the 2007 meeting included:

1) Removal of existing vegetation east of the 5-inch turtle net and the addition of some fo r m of material that would ensure that a turtle crawl would be visible. 2) Inspect and remove protruding debris that may adversely affect animals entrained in the intake canal. 3} Install a grating over dead end sections of 12-foot diameter intake pipes 4) Install excluder devices at the velocity caps to prevent large marine organisms from entering intake pipes. 5) Changes to FPL's smalltooth sawfish handl i ng, transportation and release protocol.

All of these items with the exception of the excluder device were completed as mitigating measures prior to the receipt of the associated Biological Opinion on March 24, 2016. Two Reasonable and Prudent Measures (RPM) were identified in the 2016 Biological Opinion: RPM 1: Avoid and Minimize Entrainment into the SLNPP Intake Canal RPM 2: Avoid and Minimize Injurious or Lethal Take from Entrainment into , Entrapment in, Capture in, and Release from the SLNPP Intake Canal or from Impingement at Intake Wells. The 2016 Biolog i cal Opinion required implementation oftwo Terms and Conditions (T&Cs) for RPM 1 and sixteen T&Cs associated with RPM 2. The barrier at the velocity caps is associated with the T&Cs for RPM 1. The T&Cs associated with RPM 1 are summarized below: T&C 1: NRC must ensure FPL designs, tests, constructs and implements excluder devices for the intake pipe velocity caps. T&C 2: FPL shall develop a monitoring and maintenance plan for the excluder devices. In accordance with the 2016 Biological Opinion requirements, the tested barrier design was developed and coordinated with the NMFS and NRC. A plan to test the barrier was developed and coordinated with the NMFS, and a test proposal was reviewed and permitted by the Florida Fish and Wildlife Conservation Commission.

FPL constructed a facility specifically to test the barrier design on site at the SLNPP. A test report summarizing the results of the testing is included as Attachment

1. Page 5 of 33 Test Fa ilu re of F i xed Barrier De vi ce for SLNPP Intake Pipe Vel oc i ty C aps 2.2 Basis for Current Barrier Design The SLNPP Ocean Intake System consists of three velocity cap structures, three ocean intake pipelines, two headwall structures and an intake canal. The function ofthe Ocean Intake System is to provide ocean water for cooling both Units' condensers and auxiliary cooling systems and minimize the entrapment of marine life into the system by limiting flow velocities to approximately one foot per second. These structures are located approximately 1200 feet offshore.

The intake structures have a vertical sheet pile section to minimize sand intake but no screens or grates are currently used to prevent marine organisms' access to the intake pipes. The velocity cap structures are constructed from reinforced concrete.

The top of each structure is approximately 6.75 feet below the water surface at Mean Low Water (MLW) [Ref. 9]. The square 5-foot thick velocity cap for the 16-foot diameter pipe is 70 feet x 70 feet and has a vertical opening of approximately 6.25 feet. The octagonal 5-foot thick velocity caps for the two 12-foot diameter pipes are 52 feet x 52 feet and have vertical openings of 6.5 feet. (Figure 1) EX!S l'!N G C ON O TTT ON o r VELOCJ1Y CAPS P i p es t o In t ake Cnn a l So u th e m 12 f-o ot Velo ci t}' Ca p N o rt h ern 1 2 f-o o t Veloci t)' C ap 1 6 r-oo t V e l o d t)' Ca p Figure 1 The velocity caps are connected to the horizontal ocean intake pipes by vertical transition pipe sections (Figures 2A & 2B). Blockage of the velocity cap openings could potentially result in flow restrictions that reduce intake canal levels and impact plant operation.

Page 6 of 33 T est Fa ilu re of Fix ed Ba r r i er De vi ce f or SL N PP I nta ke Pi pe Vel o city Caps <t_ VELOCITY CAP I ' 9 MEAN LOW WATER EL 0.00 II PZ22 ..

PILING OR I I!(.&UAL TO E L

• 70.0 . . Figure 2A -12ft. Pipe Velocity Cap and Vertical Transition Pipe Sections ' -\. -I. '=>> NGvo *' Figure 2B -16ft. Pipe Velocity Cap and Vertical Transition Pipe Sections Once the water enters the velocity cap structure and the vertical transition pipe, the flow velocity increases from approximately 1 foot per second {fps) to 6.8 fps in the 16 foot diameter pipe and 4.2 fps in the 12 foot diameter pipe. The intake pipes discharge into the intake canal, where the Page 7 of 33 Test Fa i lure of F i xed Barr i er Device for SLNPP In ta k e P i pe Ve l ocity Caps flow velocity i s nominally 1 fps. The a bov e velocities are ba s ed on calculations, considering a relatively clean system and a two unit design flow of 2300 cubic fps or approximately 1 million gallons per minute [Ref. 3]. Over the years, FPL has investigated options that would modify the behavior of turtles so they do not approach the velocity caps. The behavior modification technologies have included lights and bubble curtains , electrical fields, pneumatic guns and strobe lights, and a physical barrier. Reliability and effectiveness challenges associated with maintaining electrical and mechanical systems under severe surf conditions made most behavior modification systems impractical.

Additionally, these methods could potentially pose significant safety issues associated with commercial and recreational fisherman

[Ref 4]. 2.3 The Tested Barrier The configuration of the tested barrier is shown on Attachment

2. In general, the barrier device was designed to be comprised of multiple 17-inch mesh panel sections that are relatively light and sized to be handled by divers. These panels will attach to a tray that is secured to the velocity cap at the openings.

The barrier panels are to be held in the trays with restraining bars and stainless steel tie wraps to facilitate easy removal for cleaning and replacement, if necessary.

The barrier design was intended to minimize the potential harm to marine life as well as minimize the effect on flow into the velocity caps. Discussions with the NRC and NMFS to determine the size of the barrier openings were based on six years of historical turtle capture information provided in 2006 that determined a 17-inch fixed mesh (24-inch diagonal}

would exclude most adult animals (>33.5 inches (85 em) straight carapace length). Although the screen size only excludes 25% of the total turtle population, it excludes of the larger mature nesting females. It was estimated that an additional15%

of turtles will be excluded, because many turtles with straight line widths between 21 and 24 inches (55-60.9 em) would also be excluded because of carapace width. The size of openings in the physical barrier is also critical to the risk of blockages at the openings of the velocity caps that could impede water flow and potentially impact commercial operation of the plant. The potential blockage of intake cooling water is currently assessed as part of SOER 07-02 [Ref 6 & 7]. The barrier structure must be robust to minimize the consequences associated with environmental challenges.

The barrier structure has been evaluated for extreme wave loads, fatigue loading, impact and blockage by storm driven objects and blockage by marine growth [Ref 8]. A 3D section of the barrier located between the velocity cap columns is shown in Figure 4, below. Design drawings for the barrier installation are included as Attachment

2. Page 8 of 33 Test Failure of F i xed Barrier De vi ce fo r SL NPP Int ake Pipe Ve l ocity Caps Figure 4 2.4 Description of Test Facility and Procedure A saltwater test tank was constructed adjacent to the intake canal at the SLNPP. It is 8 feet (ft) wide, 5 ft deep and approximately 50ft long. The water in the tank is approximately 4.5 ft deep and is recirculated by pumps to maintain a flow rate of approximately 1 fps over the 4.5 ft x 8ft cross section of the tank. See Attachment 1 for drawing and p i ctures of the test tank and pictures of the completed test structure.

The test evaluated the adequacy of the grate size to prevent adult turtles from passing through the device. The test also evaluated any potential entrapment or injury to turtles. This test was not intended to analyze the physical properties of the structure supporting the barrier device and instead focused on the barrier panel and the interaction of turtles with the barrier. Two barrier panels welded together were located side by side in the tank. The bottoms of the panels were attached to the floor ofthe tank with a hinge that allowed them to be rotated 45 degrees forward and backward.

In the forward position, it simulated the lower portion of the barrier, and in the backward position, it simulated the upper portion of the barrier. A mock velocity cap was positioned over the barrier when it was rotated backwards, or the upper ba r rier position, to simulate the interface between the barrier and the top of the velocity cap. The test plan called for the barrier to be tested using 10 loggerhead and 4 green sea turtles. See Attachment 1 for the test procedure. 2.5 Rehabilitation of Sick and Injured Turtles From 2006 to 2017, there were 216 turtles transported to rehabilitation facilities. Of the 216 sea turtles, 203 (94%) were non-causal to plant operations. Injuries to these turtles included shark attacks, boat strikes, entanglements, etc. (Figure 5). Without entering the canal and receiving a full health assessment, many of these injuries would have ultimately resulted in death. Oft he 216 sea turtles taken to rehabilitation facilities, 155 turtles {72%) were successfully rehabilitated and released, 48 turtles {22%) died or were euthanized while in rehabilitation, 9 (4%) were continuing rehabilitation , and 4 {2%) were deemed non-releasable and transferred to aquariums for longterm care. Page 9 of 33 Test Failure of Fixed Barr ier Device f or SLNPP In take P ipe Veloci t y Caps Green Turtles Sent to Rehabilitation and Released St. Lucie Power Plant, 2006-2017 (n=36) 12 ,------------------------------------------------

Underwelaht, Boiltlnfurles Flshlncce.ar Sharklnjurles Paplllomu lffTll dilt e d,buoancy bsu es ,l e thiilrJIC Reason for rehabilitation Loggerheads Sent to Rehabilitation and Released St. Lucie Power Plant, 2006 -2 017 (n=116) *Ju v/SUb il dult *Adult Other Cilusal 70 ,------------------------------------------------., 60 50 40 -f !': 0 li 30 .. 20 1 0 *Juv/Subadult

• Adult Underwele;ht, Bo lt lnju rles FIJhlnel ea r Sharkln}url es P i plllom u emldate d ,b uoiilncy luu es, l et hilrclc Reason for rehabilitation Figure 5 Successful rehabilitation of other turtle species captured at the SLNPP included three Kemp's ridley turtles that were rescued and sent to rehabilitation. Two had shark bite injuries, and one had a boat strike injury. All three Kemp's ridley turtles were treated and released.

During this time frame, there was one causal mortality of an adult turtle in 2016. The adult loggerhead had extensive pre-existing injuries that were likely contributing factors when it drowned during entrainment.

Ten adult turtles had been captured with pre-existing injuries (Figure 6}. Eight of the injured adults were successfully rehabilitated, 1 remains in rehabilitation, and 1 died. The number of adult turtles rehabilitated far exceeds the one causal adult mortality.

Page 10 of 33 Test Failure of F i xed Barrier Device for SLNPP Intake Pipe Velocity C aps Ad u l t N o n-Caus a l i: n j ur i es by Year 3 2 1 I I I I 0 20 0 6 2 00 7 2 0 0 8 2 0 0 9 2 010 2 0 1.1 2 0 12 2 0 13 2 0 1 4 201 5 2 0 1 6 2017 *Ad u l t L o g ge r hea d *Ar.t u l t Gr e e n

• L ea t he rb a c k Figure 6 Page 11 of 33 Test Failure of Fixed Barr i er Dev i ce for SLNPP Intake Pipe Ve l ocity Caps 3.0 Summary of Test Results Tank testing of the excluder device began on December 8, 2016 and proceeded through February 20, 2017, in accordance with the Florida Fish & Wildlife Conservation Commission permit. A total of ten turtles (eight loggerheads and two green turtles) were tested. During active (flow on) testing, there were a total of 102 encounters with the test panel, defined as a test subject approaching within one meter of the panel. Testing was suspended on February 20, 2017 when a test subject became lodged in the test panel and was unable to extricate itself. The turtle was removed unharmed by the test staff. A brief narrative description of each test follows below (Table 2). Details of all observations for each test subject are found in Attachment

1. Some general observations can be made from the test data overall: 1. It does not appear that the test panel was in any way attractive to the test subjects.

During active (flow on) testing, all subjects of both species spent the vast majority of the time at the upstream end of the tank away from the test panel. Test subjects were within one meter of the test panel only approximately 1.1% of the time during active testing. Since this one meter area represents 9.5% of the total tank space available, it is reasonable to conclude that turtles tended to avoid the test panel. 2. Most encounters with test panel were of short duration.

For encounters for which duration was recorded, the average duration was 21.7 seconds. The average duration of an encounter was conside r ably greater when the panel was in the lower orientation

{36 seconds) than when the panel was in the upper orientation (14 seconds).

3. There were a greater number of encounters with the panel in the upper orientation (67) than with the panel in the lower orientation (35). 4. When encountering the panel, most subjects traveled along the bottom of the tank as they approached the panel. Therefore, approximately 63% of all encounters with the panel occurred at the base of the panel. Page 12 of 33 Test Fai l ure of Fixed Barrier Device for SLNPP Intake Pipe V e l ocity Caps Table 2-S ummary for individual turtle s C M-G r ee n Turtles, C C-Loggerhe a d turtles: Test Dates of Test Results Carapace Subject Width in inches (and em) CM1 Dec 8 & 9, 2016 Pass 20.4 (51.8) CM2 Dec 14 & 15, 2016 Pass 16.7 (42.4) CC1 Dec 16 & 17 , 2016 Pass 23.1 (58.7) CC2 Jan 12 & 13, 2017 Pass 24.7 (62.8) CC3 Jan 19 & 20 2017 Pass 22.9 (58.1) CC4 Jan 25 & 25, 2017 Pass 24.0 (60.9) CC5 Feb 2 & 3 , 2017 Pass 22.3 (56.7) CC6 Feb 9 & 10, 2017 Pass 23.3 (59.3) CC7 Feb 17 & 18, 2017 Pass 19.4 (49.4) CC8 Feb 20, 2017 Fail 21.9 (55.7) Page 13 of 33 Test Fai l ure of Fixed Barr i er Dev i ce for SLNPP I ntake P i pe Ve l ocit y Caps 4.0 Ana l ys i s of Test Resu l ts To analyze the results of the testing, four experts were engaged to review the video of the tests and to assess any adverse impacts of test procedure, panel design, and panel location on the test results. Recommendations for potential improvements were also requested.

The four experts that provided assessments were: 1. Jonathan Gorham, Ph.D., Vice-President and Michael Bresette, President of lnwater Research Group, lnc.(IRG), Jensen Beach, Florida. 2. Benjamin Higgins, Sea Turtle Program Manager, Sea Turtle Facility, National Marine Fisheries Service (NMFS), Southeast Fisheries Science Center, Galveston, Texas. 3. Charles Manire, D.V.M, Director of Research and Rehabilitation, Loggerhead Marinelife Center (LMC), Juno Beach, Florida. 4. John Mitchell, Unit Supervisor Harvesting Systems and Engineering Division, Southeast Fisheries Service Center, National Marine Fisheries Service (NMFS), Mississippi Laboratories, Pascagoula, Mississippi.

The following discussion is based on the individual assessments that are attached to this report. 4.1 Analysis of Test Procedure and Facility The general opinion of the reviewers was that the test tank and procedure were an appropriate method for testing the excluder but may not have simulated the conditions at the velocity caps. A general summary of the opinions is listed below. Refer to the attachments for their exact wording and context. 4.1.1 The test plan was well conceived and successfully executed, but it would be difficult or impossible to test a sufficient number ofturtles of different species, sizes and physical conditions to form a definitive conclusion that the barrier poses no hazard (Attachment 3-Bresette/

IRG). 4.1.2 The methodology is sound and acclimation of the turtles to test tank was successful.

The tank configuration may have created the suction element, but because of the tank walls, a laminar flow was created, that is not likely to be the same as an open water intake from 360 degrees. The failure was a result of water channeling in the test setup, due to laminar flow, creating an abnormal water flow which flipped the turtle into a position where it was not able to recover due to hydrodynamic pressure in the time allotted (Attachment 4-Higgins/NMFS).

4.1.3 The revisions that were made to testing protocol (to reduce the interaction time) were appropriate and there were no flaws in test tank configuration or procedure that contributed to the test failure (Attachment 5-Manire/LMC).

4.1.4 The test report provided good detail on each turtle's exposure to the excluder panel. It would have been helpful to have tabulated total time on the excluder panel. The test set up forces the turtle to continually interact with the panel and thus did not allow the turtle to escape over top of the excluder.

This would be analogous to testing a shrimp trawl turtle excluder and tying the escape hole shut. This would be a test of the efficacy of the turtle excluder in preventing turtles from going through the deflector bars but would not evaluate how it might make its escape. (Attachment 6-Mitcheii/NMFS)

Page 14 of 33 Test Fa i lure of Fixed Barrier Device for SLNPP Intake P i pe V elocity Cap s 4.2 Analysis of Panel Design Each reviewer observed that the panel design, with opening sizes that allowed the turtle to insert a head and flipper in conjunction with the constant flow, contributed to the barrier failure. A general summary of the observations is listed below. Refer to the attachments for exact wording and context. 4.2.1 The design of the test panel with the openings of different shapes and sizes offers the turtles encountering the panel a variety of mechanisms to become lodged in the panel (Attachment 3-Bresette/IRG).

4.2.2 It would be difficult to modify or build a test set up that did not have some effect due to water channeling because of the need for tank sides and bottom, but one way to remove that potential anomaly would be to have an exclusion grid pattern that was not large enough for a turtle to get a head and front flipper inside the grid and get turned ups i de down (Attachment 4-Higgins/NMFS).

4.2.3 There

are narrow gaps in the panel in which turtle appendages could become entrapped, especially with weaker individuals.

I cannot imagine a design that would eliminate such issues (Attachment 5-Manire/LMC).

4.2.4 Minimizing

the time a turtle spends interacting with the panel is key to facilitating their escape. The diamond pattern and spacing of the 0.5-inch rod of the excluder panel bars appears to allow the flipper and heads of turtles to pass through easily , thus slowing their movement across the panel and potentially swimming free from it (Attachment 6-Mitcheii/NMFS). 4.3 Analysis of Barrier Locat i on Each reviewer observed that the barrier location contributed to the failure. A general summary of the related observations is listed below. Refer to the attachments for exact wording and context. 4.3.1 The overhang creates a " wedge point" that contributed st r ongly to the test failure. When a turtle has a head and appendage through an opening in the upper half of the panel, the water tends to lift the posterior of the turtle in a partial some r sault motion until the turtle strikes the lower edge of the velocity cap (Attachment 3-Bresette/IRG). 4.3.2 Sea turtles will do everything in their power to not get flipped upside down. With their body shape being a perfect aerodynamic/hydrodynamic foil, water flowing over their body will create lift/suction similar to an airplane wing. It is common when testing higher angle straight bar excluder devices to have the head, front flippers and about 1/3 to 1/2 of the turtle body outside of the excluder device opening, while the back end and rear flippers are glued to the excluder device. As long as there is a constant water flow over the turtle, it will not be able to escape in this configuration. Lessening the angle of the excluder helps break this suction (Attachment 4-Higgins/NMFS).

4.3.3 During

the testing , the turtle that failed had body parts wedged between the top ofthe panel and the bottom ofthe cap. Even if this space could be eliminated, there are other narrow gaps within the panel in which turtle appendages could become entrapped. Installation of the excluder on the power plant caps will Page 15 of 33 Test Failure of Fixed Barrier Dev i ce for SLNPP Intake P i pe Veloc i ty Caps result in the entr a pment and drowning of some or all of the unhealthy turtle s that now are being rescued in the intake canal (Attachment 5-Manire/LMC).

4.3.4 The inverted lower section of the excluder panel essentially guides the turtle to the sea floor. This part of the panel configuration can result in one or two behavior outcomes; forcing the turtle to become inverted as it tries to climb upward, keeping its plastron in contact with the excluder panel; or forcing the turtle to the bottom of the panel where it is more likely to attempt to maneuver through it (Attachment 6-Mitcheii/NMFS).

4.4 Analysis

Summary The experts' assessment reports are included as Attachments 3 thru 6. In general, the consensus was that the procedures were adequate, but the configuration of the testing, which did not exactly match actual field conditions, contributed to the test failure. Additionally, the barrier mesh design and the location under the velocity cap contributed to the creation of "wedge points" that resulted in the turtle being trapped by hydrodynamic forces from the constant flow over the turtle's shell. Page 16 of 33 Test Fai l ure of F i xed Barr ier De vi ce for SLNPP I ntake P i pe V e l ocit y Caps 5.0 Causal Factors The failed barrier test warranted additional analyses to determine the causal factors that contributed to the test failure. Figure 7 below shows the relationship between causal factors that were assembled from the test results, design considerations and the above expert observations.

The analyses of these causal factors are provided below Figure 7. Turtle Barrier Test Failure -.. j, Turtle #10 was not able to 1 1 extricate itself from test panel *-r + + + Head and The panel angle Test flow lifted flipper were with the velocity posterior of through the cap created a turtle panel wedge point + I + + Opening was Barrier geometry It was not large enough to reduce loading, anticipated that the 1 fps laminar for head and risk of damage , wedge configuration flow flipper to fit and maintenance would trap turtles **-r*** J + + *

• Sized to Limited With head and flipper 360 degrees in an ocean/ prevent flow Barrier Amount of through the panel, 1 fps wave environment cannot obstruction Location (5.2) Previous Test was sufficient to lift the be created in a tank/ Data (5.3) posterior of the turtle controlled environment

+ + Ocean Biota and Limited Access for Water Flow Testing Cleaning (5.1) (5.4) Limitations (5.5)

.... Figure 7 Page 17 of 33 Test Fa il ure of Fixed Barrier De vi ce for SLNPP In tak e P i pe Ve l ocity Caps 5.1 Ocean Biota and Limited Acce s s for Cleaning 5.1.1 Design Considerations The shallow water ocean environment exposes the barrier to many environmental challenges, such as various types of sea grasses, jellyfish and ocean debris. A main concern for the power plant is fouling of the barrier such that it would restrict cooling water to the power plant. The location of the barrier approximately 1200 feet offshore restricts access for cleaning due to safety concerns caused by wave action typical for this location most of the year. The SLNPP has recent operating experience associated with ingress of sea grass and jellyfish causing failure and maintenance issues for the 5-inch, 8-inch and 10-inch mesh turtle barriers located in the Intake Canal. The barriers located in the canal are inspected quarterly and are accessible as required.

The reinitiation of consultation in 2007 was the result of an adult turtle nesting on the canal banks. Because of this and the potential for fouling issues and loss of cooling water flow, the design ofthe barrier was not required to prevent smaller sea turtles (i.e., adult non-nesting sea turtles) from entering the intake pipes. A barrier panel with a mesh small enough to prevent the turtle from putting its head and flipper in the opening would result in fouling that could potentially result in loss of cooling water flow to the power plant. 5.1.2 Feasibility of Actions to Address Ocean Biota and Limited Access for Cleaning Reduction of the opening size to prevent a turtle from placing its head and flipper inside would result in higher rates of ocean debris clogging the barrier and an increased cleaning frequency. An increased frequency for offshore diving maintenance activities is not feasible.

5.2 Barrier

Location 5.2.1 Design Considerations The design located the barrier under the velocity cap to create a wedge, increase surface area, protect it from wave loading and damage from recreational fishing, as well as to reduce the installation costs and future maintenance.

Also due to diver safety, implementation issues for working under water, and the cost of implementation and future maintenance, the design provided standardized square panels and a simple frame structure located under the velocity cap in order to minimize the need for diver ma i ntenance.

The design utilized a convex vee design in order to increase the surface area. This prevented an increase in flow velocity due to the structural members blocking the cross section and was intended to account for some potential blockage and marine growth. Location of the barrier under the velocity cap improved resistance to vertical wave forces and reduced the exposure to anchors and fishing line from recreat i onal fishing. 5.2.2 Observable Conditions Location of the test panel under the velocity cap created a wedge point that experts concluded contributed to the failure. Page 18 of 33 Test Failure of Fixed Barr i er Dev i ce for SLNPP I ntake P i pe V elocity Caps Th e limit at ion associ a ted with the d e pth of the test tank, and the loc a tion of the test panel under the velocity cap prevented the turtle from avoiding the barrier by swimming over top of it. 5.2.3 Feasibility of Actions to Address Barrier Location Reevaluating a barrier design located on the outside of velocity cap that would eliminate wedge points, allow turtle to avoid the barrier by swimming over, reduce flow velocities, and still maintain large openings to limit fouling is feasible.

A revised conceptual design is included as Attachment

7. Redesign would significantly increase the costs of implementation and future maintenance. It would also significantly lengthen the timeline to complete the project. However, as discussed in evaluation of recommended options, the fact that a barrier redesign may be feasible does not imply that is the solution that is in the best interest of the species. The test observations and FPL's consultations with relevant experts provide reasonable evidence that any sea turtle barrier would present the potential for a turtle to be injured or killed. Moreover, excluding turtles with severe non-causal injuries reduces the opportunities for rescue and rehabilitation.

5.3 Limited

Amount of Previous Test Data 5.3.1 Design Considerations and Industry Operating Experience The situation at the SLNPP is unique due to the shallow water intake, intake flow velocity and the large number of turtles that visit the area. There are additional risk factors associated with this first of its kind design. A review of operational experience at power plants that use ocean I river water for cooling and employ mitigation barriers for large sea creatures returned the following results: 5.3.1.1 Seabrook Nuclear Plant uses a deep water intake with seal deterrent bars. The intake for this plant is located approximately 3 miles off shore in deep water (approximately 50 feet below sea level) and has approximately halfthe flow ofthe SLNPP. It uses vertical bars spaced at approximately 5 inches. 5.3.1.2 Brunswick Nuclear Plant uses a diversion structure at the mouth of the Cape Fea r River. The structure prevents small fish as well as sea turtles from entering the intake canal that is approximately 300ft wide by 18 feet deep. Flow is low and drawn mainly from the surface layer of the river. 5.3.1.3 San Onofre Nuclear Plant used a velocity cap with flow velocities of approximately 7 fps and was considering the use of a large organism excluder device (LOED) prior to decommissioning.

They encountered less than 10 turtles per year. Their mitigation was mainly for sea lions and harbor seals. 5.3.1.4 Diablo Canyon has an ocean intake structure that has an intake flow of approximately 1 fps. Entrapment at the plant averages less than one turtle per year. The plant uses bar racks, which are vertical inclined bars spaced at 3 inches apart, similar to the intake structures located within the SLNPP intake wells. Based on review of technologies, they determined additional physical could Page 19 of 33 Test Fa ilure of Fixed Barrier De v i ce for SLNPP In take P i pe Ve l oci ty Caps no t b e e mployed wi t h out e ithe r jeopardi z ing pl ant opera tion s or in c re a sing th e potential for attracting and entraining other sea creatures. [Ref. 5] 5.3.1.5 Additional reviews did not identify power plants with similar conditions for flow velocity (fps), number of turtles, and similar intake conditions.

No existing operational or testing experience was identified that could be used to model an optimal design to exclude sea turtles at the SLNPP. 5.3.2 Feasibility of Actions to Address the Limited Amount of Previous Test Data There will continue to be additional risk factors associated with a first-of-a-kind-design. If the redesign continues, then this initial test data will be valuable.

Based on FPL's review of the test data and consultations with relevant experts , it has become apparent that interaction between sea turtles and any practical redesigned barrier must be expected to occasionally impact some small number of sea turtles. 5.3.3 Related Operating Experience with Canal Barrier Netting In effect, FPL has been performing hundreds of informal sea turtle barrier tests over the past decade within the controlled and safe environment of the intake canal at the 5-inch barrier net. The 5-inch sea turtle barrier net at the SLNPP has evolved through several design changes to be safe and gentle for adults as well as juvenile sea turtles. Most turtles that make their way into the intake canal are released efficiently back into the environment following a brief health check-up and research tagging. Moreover , the 5-inch net is angled slightly to guide lethargic, sick or injured turtles to the surface, and this barrier has proven to effectively prevent healthy turtles from harm while promoting the safe capture and rehabilitation of sick or injured sea turtles. 5.4 Water Flow 5.4.1 Design Considerations Intake pipe flow rates are required for operation ofthe power plant , and reduction of flow rates would adversely impact powe r production. 5.4.2 Observable Conditions The flow at the location where the turtle interacted with the grating fps) was sufficient to lift the rear of the turtle. When a turtle has a head and appendage through an opening in the upper half of the panel, the water tends to lift the posterior of the turtle in a partial somersault motion until the turtle strikes the lower edge of the velocity cap. 5.4.3 Feasibility of Actions to Address Water Flow The flow at the location of the barrier periphery of the velocity cap 1 fps. Redesign to relocate barrier outside of the velocity cap would increase the overall diameter of the barriers and reduce flow velocities. Redesign would significantly increase the costs of implementation and future maintenance and the timeline to complete the project. The feasibility of the redesign is analyzed above in section 5.2. 5.5 Testing Limitations

5.5.1 Observable

Conditions The 360 degree open water intake cannot be simulated in a tank/controlled environment.

Page 20 of 33 Test Fai l ure of F i xed Barr i er Devi c e for SLNPP I ntake P ipe V e l ocit y Caps While the tank configuration created the water flow parameters at the barrier , the t ank walls created a laminar flow that is not the same as an open water intake from 360 degrees. The failure was a result of water channeling, due to laminar flow, in the test setup which flipped the turtle into a position where it was not able to recover in the time allotted due to hydrodynamic pressure.

5.5.2 Feasibility

of Actions to Address Testing Limitations Replicating all of the potential conditions at the velocity cap in a test tank configuration is difficult, if not impossible, thus making it not feasible. Page 21 of 33 Test Fa ilu re of F i xed Barrier Dev i ce for SLNPP I nta k e Pipe V e l ocity Caps 6.0 Eva l uation of Opt i ons As part of the design approval process, the tested turtle barrier design and alternatives were considered, conceptual designs were coordinated with regulators, and the tested design was reviewed by experts. During the testing, there was a failure of the barrier test criteria when the flow was sufficient to lift the posterior of a turtle, which resulted in it becoming trapped on the underside of the velocity cap. FPL engaged outside experts to review the failures and provide recommendations and insights. Using the information provided by these experts, FPL evaluated the barrier test failure to provide recommendations for moving forward. During the testing and subsequent review of the failure, it became apparent that the constant 1 fps flow significantly affected the turtles' interactions with the fixed barrier. The flow dynamics associated with the shape of a turtles shell and the constant force associated with the flow pose a significant risk that would need to be addressed as part of any redesign.

FPL has developed a conceptual redesign of the barrier (Option 1), which is included as Attachment

7. This redesign addresses this potential flow issue by moving the barrier further away from the velocity cap opening and maintaining a vertical inclined barrier angle to allow the turtles to avoid interaction with the barrier by swimming over the top of it. However, the potential for fouling and loss of cooling water flow is still a concern. While a redesign that addresses these issues would be feasible, with Option 1, there would still be other issues that could negatively impact turtles, maintenance personnel, or plant operations that could not be avoided through design. For instance, we would expect sick and injured adult turtles to have negative interactions with even an improved-design barrier. Currently, sick and injured turtles that enter into the intake piping are captured and sent to rehabilitation.

With a barrier in place, weak turtles that cannot get through the barrier may become entrapped on the barrier due to the constant flow associated with the intake. Even if they did not become trapped by the barrier, they would not be recovered by FPL biologists for rehabilitation.

Further, wave conditions from September to April make monitoring the barrier for damage, fouling, or interaction with marine life difficult and unpredictable.

During the testing, the importance of periodic monitoring of a fixed barrier for potential impacts to prevent flow anomalies and potential adverse conditions for the turtles became evident. Due to these issues, FPL determined that the existing turtle program (Option 2) is a better solution for the entire range of sea turtle sizes and physical capabilities.

Additional potential improvements were reviewed that may augment Option 2 to address the impacts associated with not having a barrier installed.

One ofthe potential improvements was to address the potential for turtle injuries during transit through the intake piping due to the vertical to horizontal transition of the piping. Some of these injuries could be prevented by performing periodic inspections and providing a smoother transition that removes sharp edges and protrusions.

Additionally, without a barrier, the canal bank inspections for sea turtle nests will prevent recurrence of the 2007 event that caused the reinitiation of consultation. As part of Option 2, FPL proposes that these inspections and any actions to reduce injuries should be documented in the annual environmental report to identify any potential negative trends. As there are numerous positive impacts from not having a barrier installed, such as the treatment of sick and injured turtles, the data that is collected during capture, and the removal ofthe risks Page 22 of 33 Test Failur e of Fixed Barrier Dev i ce for SLNPP I ntake P i pe Velocit y Caps associated with a barrier at the velocity cap , and only a minimal risk of ha r m to turtles from entrainment without the barrier, Option 2 is the best option for the sea turtles. 6.1 Option 1: Barrier Redesign Any approved redesign of the barrier would need to address the causes of the barrier test failure identified above. A physical barrier would need to be located outside of the velocity cap periphery to eliminate the wedge point and reduce flow velocity to reduce the potential to uflip" the turtle. The elimination of these two issues will address the actions that are feasible.

A conceptual design is included as Attachment

7. 6.1.1 Redesign Description The conceptual redesign consists of a vertically inclined (45-30 degrees from horizontal) row of bars or rods supported by a robust structure.

The velocity associated with the plant operation fps at periphery of the velocity caps) would be reduced significantly as the flow would cross the barriers outside of the velocity cap. The inclined bars angled toward the top of the velocity caps would allow the turtles to avoid interaction with the barrier by exiting over top of the velocity cap. Although the cost associated with construction and ongoing maintenance (Attachment

10) of this large structure would be considerable, it is a feasible design. As with the original design, there are a number of issues that would need to be addressed that were reinforced as a result of testing. However, it has become apparent that interaction between sea turtles and any practical redesigned barrier must be expected to occasionally impact some small number of sea turtles. 6.1.2 Access for Monitoring and Maintenance of Barrier The SLNPP is unique due to the shallow water ocean intake and the number of turtles that are encountered at the intake structure.

Due to the shallow intake, any type of excluder or diverter device has numerous environmental challenges such as the constant wave action and the large amount of biota (especially algae and jellyfish) that enters the intake. The plant has experienced down power events due to moon jellyfish and various types of macro algae in the intake canal [Ref. 7]. The location of the existing barrier nets in the canal makes them accessible for constant monitoring for weak and sick turtles and damage or fouling of the net, as well as maintenance to restore flow. In contrast, average mean wave heights in the area ofthe velocity caps in the months of September through April are greater than 3 feet and make access for maintenance and monitoring of a barrier unpredictable.

This type of wave action at the velocity caps reduces visibility and creates surges that can push the divers against the ha r d st r ucture, which can prevent them from performing inspections.

Due to diver safety and visibility issues, relatively calm ocean conditions are required to safely perform monitoring and any required maintenance.

Average mean wave heights in the months of May through August are 1.5 feet or less, making access more predictable.

Scheduled Maintenance and Monitoring would need to be scheduled during the months of May through August (Attachment 12). Hurricane season must also be factored into the schedule discussed above as related maintenance activities (including mobilization of equipment) would need a schedule flexible enough to ensure personnel safety during a forecasted storm. Even though a conservative robust design would be used during the redesign of the barrier, the constant and significant forces associated with an ocean environment could Page 23 of 33 Test Fa il ure of Fixed Barr i er Devi ce for SLNPP Intake Pipe V e l ocity Ca ps poten t i a lly damage the offshore bar r ier a nd would not be detected un t il the ne x t possible inspection.

Fouling of an offshore barrier may also occur during time periods when the wave action (or its unpredictability) prevents inspection or maintenance.

6.1.3 Testing

Barrier Prior to Installation The open ocean environment and associated plant operation flow is not feasible to create in a test facility.

No existing test facility was identified that could test our current barrier design. The current test facility was specifically designed for the initial test. It could be reconfigured to test the vertical inclined rods of the redesign, but it would be impossible to recreate flow conditions similar to those the turtle will experience at the velocity cap. Turtles of a wide range of sizes and physical conditions would be interacting with the barrier in the ocean. Testing would provide some assurance that the installation of the barrier would not result in impacts to healthy turtles, but there would still be risk involved due to the limitations ofthe tank testing. 6.1.4 Barrier Opening Size and Angle The conceptual redesign uses vertical inclined bars spaced with a 17-inch clear opening between the vertical bars, eliminating the horizontal bar. The removal of the horizontal bar, reduction in flow velocity and maintaining an angle of no more than 45 degrees from horizontal should prevent some of the binding and potential pinning of a healthy turtle to the barrier. Lessening the angle (from horizontal) of the excluder helps break the suction, and improves the situation. 6.1.5 Take Associated with Sick and Injured Turtles 6.1.6 Even ifflow velocities are reduced, physically impaired turtles could become impinged on the barrier, and would not be identified due to limited access for monitoring. Regardless of the barrier design, there would be a potential for increased mortalities of sick or injured turtles. The biologists would continue to monitor the intake canal for juvenile and sub-adult turtles that are able to traverse the barrier, but would not have access to the adults out in the open ocean. In contrast, currently, physically impaired adult turtles that enter the canal and are carried to the barrier net by the canal flow are easily identified by the biologists that are monitoring the capture area. Option 1 Summary In accordance with the requirements of the current Biological Opinion, a conceptual redesign is included as Attachment 7 to this report.

The failed test reinforced some potential issues that exist with the application of a physical barrier that would need to be resolved prior to restarting the project and redesign, including:

• Access for monitoring and maintenance is limited.

• A testing facility that can reproduce the flow conditions at the velocity cap do not exist.

• A barrier mesh opening to prevent a turtle from placing its head and/or flipper in the opening is not feasible due to potential fouling.

• There is a potential for undesirable impacts related to sick and injured turtles and to healthy turtles that struggle making their way through the barrier. 6.2 A detailed evaluation, review, and approval process would need to be completed prior to final redesign and implementation.

This would require an extension of the timeframe Page 24 of 33 Test Fa ilu re of F i xed B a rr i er De vi ce for SLNPP I ntak e P i pe Velocit y Caps currently provided in the Biological Opinion. Option 2: Maintain Programs and Identify and Minimize Negative Impacts Associated with Entrainment and Travel through the Intake Piping Option 2 would allow FPL to proceed without installation of a new barrier on the velocity caps at the intake structure.

Instead, under this option FPL would continue to rely on the 5-inch net in the intake canal and other enhancements that minimize negative impacts associated with entrainment and travel through the intake piping. This option offsets the minimal probability of lethal take from entrainment without a velocity cap barrier with the overwhelming benefits of rehabilitation successes for sick or injured sea turtles captured at the St. Lucie Plant. Rehabilitated and released adult sea turtles should be considered to be just as valuable as other adult sea turtles; therefore, the capture and rehabilitation of sick and injured turtles is the functional equivalent of (or even better than) stopping all adult turtle ingress. Additionally, Option 2 does not introduce the new entrainment mechanism associated with the velocity cap barrier. A comparison of improvements to SLNPP current processes against the installation of a physical barrier is performed below. 6.2.1 Current Situation The intake canal banks discourage nesting. Improvements to the canal banks, such as the removal of vegetation, repair of revetment, and increased canal bank monitoring by biologists have aided in preventing sea turtles from nesting on canal banks for 12 years. Currently, egg-bearing female sea turtles can enter the intake pipe and are then transported to the intake canal. Existing RPM mitigating measures have been in place to avoid injuries to turtles while in the intake canal. Additional measures have been added since the nesting event in 2006 to inspect the banks ofthe intake canal east ofthe 5-inch mesh barrier net for turtle tracks or other signs of nesting each morning during nesting season. Figure 8 Onsite biologists actively search for turtles daily. Vegetation has been removed and attempts to nest would be easily identified.

Concrete block and stone revetment makes it difficult for nesting. Page 25 of 33 Test Fai l ure of F i xed Barr i er Dev i ce fo r SL N PP Intake Pipe Ve l ocit y Caps The 5-inch turtle b a rrier net forms an improved boundary for safe capture ofturtles within the intake canal. The 5-inch net design has evolved to benefit turtles. The 5-inch net is angled slightly to guide lethargic, sick or injured turtles to the surface. It has demonstrated to be an effective barrier that prevents healthy turtles from being harmed while promoting the safe capture and rehabilitation of sick or injured sea turtles. Figure 9 6.2.2 Benefits of not installing barrier Robust 5" mesh barrier net Maintains the net in an improved configuration to en s ure turtle safety Readily accessible for monitoring and any required cleaning and maintenance Improved boundary that reduces the tu r tle capture area in the intake canal Designed to prevent turtles from reaching the plant structures 6.2.2.1 Rehabilitation of Sick and Injured Turtles The SLNPP contribution to the rehabilitation of sick and injured sea turtles is discussed in the background Section 2.5 above. 6.2.2.2 Better understanding of sea turtle biology and conservation Since the plant became operational in 1976, over 90% of sea turtles entrained in the intake canal system have been systematically captured , measured, weighed, tagged, and released.

Over 16,000 turtles, representing five different species (in order of abundance loggerhead, green, hawksbill, Kemp's ridley, and leatherback turtles), have been captured at the plant and the resultant database is the largest of its kind in the world. This information is of great value to researchers and conservationists.

The sea turtle data have been cited in more than 23 scientific publications, 17 presentations at conferences, workshops and meetings and 4 agency documents , including NMFS's recovery plans for the loggerhead and green sea turtles. In addition, the FPL sea turtle program has collaborated with at least 10 students from 7 different colleges and universities.

The data that were collected at the canal as a result ofthese collaborations were used to complete the students' Masters or Doctoral theses. This research has ranged from studies on sea turtle health to growth rates to sex ratios to site fidelity and more. The ability to study five species of sea turtles from both sexes and most age classes has made this 40+ year dataset highly valuable. Its contr i bution has led to a better understanding of sea turtle biology and conservation. Page 26 of 33 Test Failure of Fixed Barrier De vi ce for SLNPP Intake P i pe V e l ocity C aps 6.2.2.3 Elimination of potential risks as s ociated with phy s ical barrier Due to the location of the velocity caps , monitoring and maintenance of a physical barrier is unpredictable during the months of September through April due to ocean wave heights and turbid water conditions.

In contrast, the barrier nets in the intake canal can be monitored for sick and injured turtles throughout the day and inspected quarterly for any damage or fouling. Procedures are in place to mobilize divers in the event the nets are affected by environmental challenges such as jellyfish or sea weed. The diver response can be activated from the canal bank, where they are protected from wave surge by the canal environment.

Implementation of such a procedure in the open environment would be unpredictable and dependent on the weather. Daily diving activities in the intake canal result in less overall industrial safety risk to the divers and support crew compared to an annual offshore maintenance effort. While a redesign is possible, and there can be some expectation of a reduction in the already-small risk to healthy adult turtles, there would be increased risk to turtles that are either sick or injured. 6.2.3 Negative Impacts of not installing barrier 6.2.3.1 The Potential Stress of Capture and Release Since the plant became operational in 1976, most sea turtles entrained in the intake canal system have been systematically captured, measured, weighed, tagged, and released.

From 2007 to 2016, 99.5% of sea turtles that entered the intake canal were either released the same day they were captured (95.4%) or were non-causal injuries/deaths (4.1%). The Turtle Capture Program (Program) has been in place at SLNPP for over 40 years , and the experience in handling the turtles has led to an efficient operation that result in minimal stress to the turtles. For example, a recent study on the stress response of loggerhead sea turtles captured in the St. Lucie intake canal concluded that they do not appear to be stressed (per Martha Villalba-2016 ISTS Symposium Presentation).

This demonstrates that neither the entrainment process nor the capture methods used have a negative effect on the stress response of the sea turtles tested. Therefore, the potential stress on turtles from travel through the intake pipe should not be a significant consideration in the evaluation of this option. 6.2.3.2 Travel Through Intake Pipes Once a turtle enters the vertical section of the intake piping, the flow velocity increases and prevents the turtle from exiting the pipe. In a clean straight section of piping, the potential for causal injury to the turtle is minimal. It is reasonable to hypothesize that most of the causal scrape injuries (fresh scrapes) occur at the section of piping where it transitions from vertical to horizontal.

The routine data collected as part of each sea turtle capture report is used for identifying emerging trends in turtle injuries. In 2007, a trend in fresh scrapes was attributed to fouling of the intake pipes associated with a previous velocity cap failure. As a result, intake pipe cleaning was completed in spring of 2011. Page 27 of 33 Te s t Failure of Fix ed Ba rr i e r De vi ce for SLNPP In ta k e P i p e Ve l ocity Caps 5 4 3 1 0 Ad u l t Ca u sa l I nj ur i es by Y e ar I Intake pipe cleaning completed I Action s tak e n to clean i n tak e pip e s have p r ov e d succe ss ful to m i nimi ze inj u ri e s to adult turtl es 2006 2007 2008 2009 2010 2011 20 12 2 0 13 201 4 20 1 5 20 1 6 2017

• Ad ul t L ogge r head

• Adu l t G r een

• L ea t her b ack Figu r e 10 Starting in 2008 , injuries due to the pipe were categorized into three types as minor, moderate or severe scrapes. lnwater Research G r oup worked with veterinarians to verify how scrapes were categorized into the three types. The trend in turtle injuries due to the transition through the piping reduced significantly because of the cleaning that took place from 2008-2011.

After cleaning, from 2012-2017, 0.04% of turtles entrained in the canal had severe scrapes and 8.2% had moderate scrapes. All turtles with severe scrapes are sent to a rehabilitation center after consultation with the Florida Fish & Wildlife Conservation Commission.

Turtles with minor or moderate scrapes are released the same day as their capture, if no other injuries are present. 6.2.3.3 Prevention of Nesting on the Intake Canal Bank The mitigating measures implemented on the canal banks and the biologists' monitoring have effectively prevented turtles from nesting on the banks of the intake canal. Since implementation of the bank inspections east of the 5-inch mesh barrier net for turtle tracks or other signs of nesting, there have been no active nests identified.

The identification of the nests, which is intended to prevent hatchlings from entering the canal and traveling past the 5-inch barrier net, is critical to the prevention of recurrence of the event that initiated the current consultation.

6.2.3.4 Adult Turtles Injured in the Intake Canal Through a series of refinements to the program, causal mortalities have been reduced to a very low level. There has been only one instance of adult mortality in the past 12 years. In 2016, one out of the 486 tu r tles that entered the intake canal resulted in a causal mortality.

The turtle had extensive pre-existing injuries that were l i kely contributing factors when it drowned during entrainment Page 28 of 33 Test Fai l ure of Fixed Barr ier Device for S LNP P Intake Pipe Ve l ocity C aps 3 2 1 0 A d u l t Causal Morta l it i e s b y Yea r 2006 2007 20 08 2009 2010 2011 2 0 12 2013 2 0 14 201S 2016 2017 *

• A d u l t L o gg e r h ea d

• A d u l t G r e e n

• L eathe r back Figure 11 A combination of improvements to the barrier net system, increased levels of surveillance, and an aggressive program of hand capture by free divers have reduced the causal mortality rate to 0.2%. To date, no causal injuries or deaths have occurred during the capture or release. 6.2.4 Potential Improvements to Minimize Impacts 6.2.4.1 Vertical to Horizontal Transition Based on the above review of potential negative impacts, the most significant risk to the turtles is the vertical to horizontal transition in the intake pipes. Inspection and actions to provide a smoother radius and elimination of any sharp edges would further reduce the potential impact. 6.2.4.2 The 8-lnch Net In addition to the 5-inch net, there is an 8-inch mesh turtle net, which is west of the 5-inch net and east of the AlA bridge that crosses the intake canal. The 8-i nch net serves as a back-up to the 5-inch net. The 8-inch net is under less tension than the 5-inch net, and the intake flow forms it into a catenary curve. Unlike the 5-inch mesh turtle net that is angled and tensioned to provide an optimal mechanism to guide lethargic turtles to the surface, the 8-inch turtle net geometry does not effectively guide turtles to the surface. During the recent ocean cold-stunning event in January 2018, while the 5-inch net was being repaired, the back-up 8-inch net proved less effective than the 5-inch net. Because of the angle of the net, it may be better for the turtles not to have the 8-inch net as it is currently installed.

The 8-inch net could be removed without increasing turtle mortality rates. Alternatively, a second 5-inch net with similar angle and tension would provide efficient redundancy and allow one ofthe two to be removed for maintenance or replacement with no adverse impact to turtle capture activities. 6.2.4.3 Additional Reporting for Canal Nesting The canal bank inspections are critical for the identification of any nesting. The documentation of this inspection to identify any potential negative trends could be included as part of the environmental reporting.

Page 29 of 33 Test Failure of Fixed Barrier Device for S LNPP Intake Pipe Velocity C aps 6.3 Other Options Other options still exist that would modify the behavior of turtles, so they do not approach the velocity caps. FPL has investigated behavior modification technologies including lights and bubble curtains, electrical fields, pneumatic guns and strobe lights, and a physical barrier. Reliability and effectiveness concerns associated with maintaining electrical and mechanical systems under severe surf conditions made most behavior modification systems impractical and not recommended. Some of the impractical options are discussed below. 6.3.1 Lights and Bubble Curtains FPL evaluated lights and bubble curtains as a deterrent to turtles. The concept of this visual deterrent is that sea animals would avoid a curtain of bubbles or flashing lights surrounding the offshore structure.

Studies determined that bubble c urtains and lights were not a sufficient deterrent to consider for further evaluation.

Additionally, studies at Diablo Canyon determined that they may attract fish and other organisms and the effect on turtles is unknown. [Ref 4 & 5] Therefore, FPL concluded that lights and bubble curtains were not recommended.

6.3.2 Pneumatic

Guns FPL evaluated pneumatic guns as a deterrent to turtles that would repeatedly produce bu r sts of compressed air intended to discourage approaching marine animals. lt.would be necessary to mount guns on all four sides of the velocity caps , and the guns would need to be suspended away from the structure due to potential long term dynamic effects. Each gun would require an electrical cable to fire the gun and a high pressure air hose. A shore based compressor could p r ovide necessary air. The continuous usage of these guns (a discharge every 15 seconds) and the potential for failure (0-rings and electrical connections) would require two backup guns for reliability. Thus, each structure would r equire a total of 12 guns. Periodically (estimated 6-8 week intervals), all twelve guns would need to be replaced.

Even with redundancy, 80% reliability would not be guaranteed. [Ref 4] Therefore, FPL concluded that pneumatic guns were not recommended. 6.3.3 Net covering entire intake FPL evaluated covering entire intake with a net to physically keep out marine animals. The concept of this deterrent is to simply cover the velocity caps with netting anchored at its perimeter.

This concept is a simpler more temporary version of the barrier desc r ibed in Option 1. A long-term application of netting over the velocity caps would be exposed to strong wave forces and fouling from ocean biota. Clogging of netting could adversely affect intake flow and plant operation.

[Ref 5] Therefore, FPL concluded that a net covering the intake was not recommended. 6.3.4 Dangling chains FPL evaluated a curtain of dangling chains around intake to give visual cue that would visually ward off marine animals. Similar to a bubble curtain surrounding the intake (as described above), a curtain of hanging lengths of chain could be structurally supported Page 30 of 33 Test Failure of Fixed Barrier Device for SLNPP Intake Pipe Velocity Caps around the perimeter of the velocity caps. The effect on turtles is unknown, and may attract curious species. [Ref 5] Therefore, FPL concluded that a curtain of dangling chains around intake was not recommended.

6.3.5 Bars or cage around intake structure with small spacing FPL evaluated surrounding the entire intake with a structural cage to physically keep out marine animals. The larger surface area would decrease the water velocity and allow for higher fouling rates. The concerns discussed with Option 1 are amplified by the larger size of this conceptual structure and the increased exposure to wave action and fishermen.

This concept presents safety concerns at the offshore intakes. [Ref 5] Therefore, FPL concluded that a cage around intake was not recommended.

7.0 Evaluation

Summary I Recommended Actions FPL's testing program and expert consultations revealed significant issues with a fixed barrier design (Option 1). While the design can be approved, there are still drawbacks associated with not being able to reliably monitor and perform maintenance on the barrier, as well as the exclusion and potential risk to sick and injured turtles. Conversely, there is a long and successful history with FPL's current program that demonstrates the benefit to the species associated with the data collected during capture, the low mortality rate associated with the entrainment and release as well as the benefit to adult sick and injured turtles. For these reasons, FPL concludes that the current netting technique (Option 2) is most likely to have the lowest mortality rate on the area's sea turtle populations.

As part of Option 2, FPL is also proposing additional enhancements recommended below to further reduce potential impacts. 7.1 Recommended Actions In lieu of the installation of a turtle barrier or excluder at the intake velocity caps, FPL recommends Option 2, which includes the implementation of the following actions: 7.1.1 Perform initial detailed inspection of interior of intake pipes and velocity caps to identify conditions that may cause injury to large marine animals that may travel through pipes. 7.1.2 Perform maintenance and modifications to address adverse conditions 7.1.2.1 Create a smooth transition at base of Unit 1 velocity caps where the horizontal pipe enters the vertical section of the velocity cap. 7 .1.3 Perform periodic inspections of interior of intake pipes and velocity caps to identify potential conditions that may cause injury to large marine animals. 7 .1.4 Require biologists to inspect and record observations of the intake canal banks for potential turtle nesting as part of Annual Environmental Report. Page 31 of 33 Test Failure of Fixed Barrier Device for SLNPP Intake Pipe Velocity Caps 8.0 References

1. Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531 et seq.) 2. National Marine Fisheries Service (NMFS) biological opinion pursuant to section 7(a)(2) and the conservation review pursuant to section 7(a)(1) ofthe Endangered Species Act, as amended (ESA; 16 U.S.C. 1536(a)(2)), Dated March 24, 2016. 3. U.S. Nuclear Regulatory Commission (NRC). Generic Environmental impact Statement for License Renewal of Nuclear Plants: Regarding St. Lucie Units 1 and 2-Final Report (NUREG-1437, Supplement 11). May 2003. 4. Turtle Entrainment Deterrent Study, Applied Biology, Inc. August 1980. 5. National Oceanic and Atmospheric Administration (NOAA) biological assessment for the effects of continued operation ofthe Diablo Canyon Power Plant Threatened or Endangered Marine Species, (TAC Nos. MC2289 and MC2290) Dated May 10, 2005. 6. Institute of Nuclear Power Operations (IN PO) Significant Operating Experience Report (SOER) 2007-2. (INPO SOER 07-02) "Intake Cooling Water Blockage".

7. AR/CR #02137121-SOER 07-2 Intake Cooling Water Blockage 2016 Triennial Review. 8. FPL Engineering Design Package EC284413, Revision 0, Ocean Intake Velocity Cap Turtle Barrier, St Lucie Units 1 and 2. 9. FPL Drawings of Velocity Caps a. 8770-G-664, Sh 2, Rev. 7, Circulating Water System Ocean Intake & Disch Sects & Details Sh2. b. 8770-G-664, Sh 2A, Rev. 3, Circulating Water System Cap Repair 12-Foot Pipe South Velocity Cap Plan, Section, Details-MAS

& Reinf. c. 8770-G-664, Sh 2B, Rev. 0, Circulating Water System Cap Repair 12-Foot Pipe South Velocity Cap Plan, Section, Details-MAS

& Reinf. d. 2998-G-664, Sh 28, Rev. 3, Circulating Water System Third Intake Pipeline Velocity Masonry. e. 2998-G-664, Sh 28A, Rev. 0, Circulating Water System Velocity Cap Repair 16-Foot Pipe Velocity Cap, Plan, Section, Details-MAS.

f. 2998-G-664, Sh 29, Rev. 2, Circulating Water System Third Intake Pipeline Velocity Reinforcing.

g. 2998-G-664, Sh 29A, Rev. 0, Circulating Water System Velocity Cap Repair 16-Foot Pipe Velocity Cap, Plan, Section, Details-Reinf.

Page 32 of 33 Test Failure of Fixed Barrier Device for SLNPP Intake Pipe Velocity Caps 9.0 Attachments Attachment 1-Test Report-Testing a Fixed Barrier Device with Live Loggerhead and Green Sea Turtles (54 pgs) Attachment 2 -Turtle Barrier Design Drawing (6 pgs) Attachment 3-Review of Test Data-Jonathan Gorham, Ph.D., and Michael Bresette, President of In water Research Group, Inc., Jensen Beach, Florida.(4 pgs) Attachment 4-Review of Test Data-Benjamin Higgins, Sea Turtle Program Manager, Sea Turtle Facility, National Marine Fisheries Service, Southeast Fisheries Science Center, Galveston Texas.(4 pgs) Attachment 5-Review of Test Data-Charles Manire, D.V.M, Director of Research and Rehabilitation, Loggerhead Marinelife Center, Juno Beach, Florida.(1 pg) Attachment 6-Review of Test Data-John Mitchell, Unit Supervisor Harvesting Systems and Engineering Division, Southeast Fisheries Service Center, National Marine Fisheries Service, Mississippi Laboratories, Pascagoula Mississippi.(3 pgs) Attachment 7-Conceptual Barrier Redesign (1 pg) Attachment 8-List of Publications (6 pgs) Attachment 9-Meeting Summary April17-18, 2007 (2 pgs) Attachment 10 -.Cost Estimate (5 pgs) Attachment 11-Fresh Scrape Data 2007 to 2017 (1 pg) Attachment 12-Wave Data (11 pgs) Page 33 of 33 FPL ST LUCIE PLANT SEA TURTLE EXCLUDER DEVICE TANK TESTING REPORT Prepared for: Florida Power and Light St. Lucie Nuclear Plant Prepared by: Inwater Research Group, Inc. Jensen Beach, Florida July 2017 1 Test Evaluation Report Attachment 1 Page 1 of 54 Executive Summary The Florida Power and Light Company St. Lucie Plant has had a sea turtle conservation program in place since 1976. A major facet of this program is to monitor and document federally protected sea turtles entrained in to the cooling water canal system and to safely effect their capture and release back in to the wild. The conservation program is mandated by the US Nuclear Regulatory Commission through an agreement (a Biological Opinion or BO) between the Commission and the US National Marine Fisheries Service (NMFS). Since its inception, the conservation program has undergone continuous refinements to reduce residence times of turtles in the intake canal system and to minimize the potential for injuries and mortalities causal to plant operation.

In March of 2016, NMFS issued a revised BO requiring the design, testing, and construction of an excluder device on the offshore intake structure to minimize the entrainment of sea turtles. In order to test the efficacy and safety of the proposed excluder device design , a test plan was developed and a test facility was built at the plant site that could duplicate the water flow conditions at the offshore intake structures.

A prototype barrier panel design was installed in the test tank, and a total of fourteen turtles of various species and size classes were selected to evaluate how they interacted with the test panel. This report presents the result of that testing. Tank testing of the proposed excluder device began on December 8, 2016 and proceeded through February 20, 2017. Testing was suspended on February 20, 2017 when a test subject became lodged in the test panel and was unable to extricate itself. The subject had inserted its head and left front flipper through the test panel. At that point, the test water current lifted the posterior of the turtle 45 to 60 degrees so that the posterior was in contact with the bottom of the velocity cap mockup. In this position, the turtle was unable to withdraw its head or flippers from the openings and the velocity cap mockup prevented further lifting of the posterior of the turtle, which otherwise may have allowed the turtle to free itself. In brief, the turtle became "wedged" under the velocity cap mockup in an awkward position where the front flippers were trapped and the rear flippers were not in a position where they could gain any purchase on the velocity cap mockup. The turtle was removed unharmed by the test staff. While changes in the design of the test panel and the overall design and construction of the excluder device may mitigate this particular mode of failure, a major concern remains for the ability of injured or debilitated turtles to avoid becoming impinged on any excluder device. Additionally, it will be very difficult or impossible to document any cases of impingement on the offshore intake structures.

Given the very low and precisely documented rate of mortalities to sea turtles causal to plant operation achieved by the current sea turtle conservation program operation, the desirability of construction an offshore intake excluder device should be reconsidered. 2 Introduction The Florida Power and Light Company (FPL) St. Lucie Plant has had an active and successful sea turtle conservation program in place since 1976. This conservation program includes surveillance of the cooling water intake system (Figure 1) for the presence of entrained sea turtles and their safe capture, tagging , and release as well as sea turtle nesting monitoring on the beaches adjacent to the plant. Since its inception, the conservation program has undergone continuous refinements to reduce residence times of turtles in the intake canal system and to minimize the potential for injuries and mortalities causal to plant operation.

The proposed sea turtle excluder device evaluated in this report represents the culmination of that process of refinement, and is an effort to reduce the numbers of turtles entrained into the canal in the first place rather than simply to improve the efficiency and safety of captures of turtles once they are in the intake canal system. Since the plant became operational in 1976, sea turtles entrained in the intake canal system have been systematically captured, measured, weighed, tagged, and released.

Over 16,000 turtles representing five different species (in order of abundance loggerhead, green, hawksbill, Kemp's ridley, and leatherback turtles) have been captured at the plant and the resultant database is the largest of its kind in the world. This data set has been of great value to both researchers and conservationists.

The welfare of sea turtles entrained into the intake canal system is the purview of the National Marine Fisheries Service (NMFS) under Section 7 of the Endangered Species Act (ESA). NMFS establishes terms and conditions for the operation of the cooling water system contained in a Biological Opinion (BO) issued by the agency. The goal ofthe BOis to ensure that impacts to sea turtles as a result of the operation of the plant are minimized to the greatest extent practicable.

Through a series of refinements to the program, causal mortalities have been reduced to a very low level. A combination of improvements to the barrier net system, increased levels of surveillance, and an aggressive program of hand capture by free divers has reduced the causal mortalities in 2016 to one out of a total of 486 turtles captured, for a causal mortality rate of 0.2%. Of particular concern to NMFS is the welfare of reproductively active adult female turtles in the intake canal system. For the period between their entrainment into the canal and their subsequent capture and release, these turtles are precluded from access to the nesting beach. If these adult females remain in the intake canal long enough, they may emerge from the intake canal and nest on the canal banks. When the nest hatches, emerging hatchlings then enter the intake canal where, due to their small size, they penetrate the barrier net system and may wind up in the actual plant intake. Such an event occurred in 2006, and was the impetus for a revised BO (Appendix A) including a requirement to design and install a device on the offshore intake structure (Figure 2) to exclude turtles of adult size classes from entering the intake structure and being entrained.

Prior to the revised BO from NMFS, which was issued in 2016, FPL began design and engineering work on a sea turtle excluder device for the offshore intake structures that would 3 preclude turtles with a straight carapace width (S CW) greater than about 61 em from e nterin g th e intake structure. This grid spacing was selected to exclude all adult size loggerhead and green turtles while minimizing the potential for debris to interfere with the cooling water flow. Any physical barrier on the intake structures has the potential for causing mortality if a turtle is impinged on the structure by the intake water flow. In order to evaluate this risk FPL , in consultation with NMFS and the Florida Fish and Wildlife Conservation Commission (FWC), developed a test plan to evaluate excluder design options for safety to sea turtles. A raceway tank was constructed on the plant site , with recirculating pumps of sufficient capacity to replicate the design water flow velocity at the intake structures (approximately 1.0-1.5 feet per second). Materials and Methods The excluder structure panel design selected by FPL for testing is shown in Figure 4. The excluder panel is constructed of stainless steel, and the largest opening in the panel has a diagonal width of 61 centimeters , corresponding to the maximum size turtle that is able to pass through the panel. To ma x imize surface area and resist potential clogging , the proposed design calls for two panels to be installed in a " V" shaped configuration with the point of the " V" facing outward. The lower panel is attached to the base of the intake structure and slopes outward at a 45 degree angle, where it attaches to the upper panel. The upper panel slopes inward from its attachment to the top of the lower panel and is attached to the underside of the velocity cap. A sample test panel was installed in a 50 foot long, five foot deep raceway tank (Figure 3) with two pumps that draw water from the foot end of the tank and discharge it at the head end, creating a constant flow of water with a velocity adjustable by adjusting pump RPM. The test panel was installed on a hinged base at the tank bottom which allowed the panel to be oriented with the top facing into the current flow (replicating the orientation of the lower section of the structure), or with the top of the panel facing away from the current flow (replicating the orientation of the upper section of the structure.

In the upper orientation , a mock-up of the overhanging velocity cap was installed to replicate the conditions at the intake structure as closely as possible.

During testing, observers monitored interactions of turtles with the test panel from an elevated walkway around the tank, through a window installed in the side of the tank, and by surface and underwater video.

A testing plan (Appendix B) was developed in consultation with NMFS and FWe to identify the test conditions and size classes and species of turtles to be tested, as well as criteria for test success and failure. The original version of the test plan called for a total of eight turtles (all loggerheads) to be tested. Each turtle would be subjected to eight hours of active (flow on) testing on three consecutive days for a total of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. When testing was initiated, it became apparent that the test plan was too rigorous.

Test turtles became exhausted from swimming into the current for long periods oftime, lost weight, and became lethargic.

Since turtles only encounter water flows at the intake structure similar to the test tank flow velocity for brief periods of time as they approach the structure, the long continuous test periods were deemed unnecessary and in July of2016 a revised test plan was agreed to. The revised test plan called for a total of 14 turtles (ten loggerheads and four green turtles) to be tested for reduced periods of time. Size classes of turtles tested included individuals with and sew that would allow them to pass through the panel, turtles with an sew too large to allow them to pass through the panel, and turtles near the critical sew dimension of 61 em. For the turtle tests, each turtle was allowed to acclimate to the test tank for a period of 12-24 hours prior to active testing. Each turtle was subjected to one hour of active (flow on) testing, separated by a two hour rest period with no flow and no access to the panel structure, for an active testing total of six hours over a two day period (three hours of active testing per day). At the end of the first day oftesting the turtle remained in the tank with no flow and no access to the panel structure.

After the second day of testing the turtle was released back to the ocean or back to the rehabilitation facility it was procured from. Observations of each turtles behavior were made during active testing every 15 minutes and anytime the turtle approached within one meter of the test panel. The observer noted resting and activity intervals and recorded behavior of the animal anytime it approached or interacted with the structure.

Surface and underwater video cameras were positioned to capture any interactions with the test panel, and continuous video was recorded during active testing. During the course of each six hour active test period there were three hours with the barrier panel in the upper configuration and three hours with the panel in the lower configuration.

The following Pass/Fail criteria were established for a test turtles interaction with the panel: PASS: 1. Upon attempt to move through the barrier device, a turtle larger than 61 em straight carapace width is prevented from proceeding through the device and is unharmed by the panel. 2. Any turtle smaller than 61cm straight carapace width interacts with (passes or does not pass through) the panel and is unharmed by the panel. FAIL: 1. A turtle larger than 61 em straight carapace width passes through the barrier device. 2. Any sized turtle becomes trapped while interacting with turtle panel including as a result of the panels positioning in the tank (rescue turtle and identify any potential detrimental effect to turtle; suspend test until problem is resolved).

5

3. Panel is damaged by turtles (take corr e ctive action to repair/r e install to prevent oc c urr e nc e). Every 15 minutes during active testing, a digital flowmeter was used to measure test tank water current velocity and ensure that the flow was within the testing parameters of 1.0-1.5 feet per second. At least three times per day during testing , water quality measurements (temperature , salinity , Ph , and free chlorine) were collected to insure compliance with the water quality parameters specified in the test plan. Results Tank testing of the proposed excluder device began on December 8, 2016 and proceeded through February 20, 2017. A total often turtles (eight loggerheads and two green turtles) were tested. During active (flow on) testing , there were a total of 102 encounters with the test panel, defined as a test subject approaching within one meter of the panel. Testing was suspended on February 20, 2017 when a test subject became lodged in the test panel and was unable to extricate itself. The turtle was removed unharmed by the test staff. A brief narrative description of each test follows below. Details of all observations for each test subject are found in Appendix C. Some general observations can be made from the test data overall: 1. It does not appear that the test panel was in any way attractive to the test subjects.

During active (flow on) testing, all subjects of both species spent the vast majority of the time at the upstream end of the tank away from the test panel. Test subjects were within one meter of the test panel only 1.1% of the time during active testing. Since this one meter area represents 9.5% of the total tank space available , it is reasonable to conclude that turtles tended to avoid the test panel. 2. Most encounters with test panel were of short duration.

For encounters for which duration was recorded , the average duration was 21.7 seconds. The average duration of an encounter was considerably greater when the panel was in the lower orientation (36 seconds) than when the panel was in the upper orientation (14 seconds).

3. There were a considerably greater number of encounters with the panel in the upper orientation (67) than with the panel in the lower orientation (35). 4. When encountering the panel, most subjects traveled along the bottom of the tank as they approached the panel. Therefore , approximatel y 63% of all encounters with the panel occurred at the base of the panel. Test subject cml This subject was a green turtle of undetermined sex with a straight carapace width of 51.8 em, a size that should be able to pass through the panel. Testing began at 0812h on December 8 and 6 was completed at 151 Oh on December 9. The mean water flow velocity during the testing was 1.1 0 feet per second. Testing on December 8 was conducted with the test panel in the upper orientation. There was only one encounter with the panel. At 151 Oh, the subject approached within one meter of the panel and immediately turned around without contact. Testing on December 9 was conducted with the panel in the lower orientation.

There were three encounters with the panel. At 0827 the subject approached within one meter of the panel and immediately turned around without contact. At 0853 the subject approached the panel and remained at the base ofthe panel facing upstream for a period of three minutes. At 1114h the subject again approached the panel and remained at the base of the panel facing upstream for a period of three minutes. Test subject cm2 This subject was a green turtle of undetermined sex with a straight carapace width of 42.4 em, a size that should be able to easily pass through the panel. Testing began at 0830h on December 14 and was completed at 151 Oh on December 15. The mean water flow velocity during the testing was 1.11 feet per second. Testing on December 14 was conducted with the test panel in the upper orientation.

There were four encounters with the panel. At 0846h the subject contacted the panel and crawled across it for 20 seconds. At 1454h the subject contacted the panel and remained in place for 9 seconds. At 1526h the subject contacted the panel and remained in place for 15 seconds. At 1527h, the subject contacted the panel and briefly inserted its head through one of the smaller panel operungs.

Testing on December 15 was conducted with the panel in the lower orientation. There were seven encounters with the panel. At 0827h the subject approached within one meter of the panel and crawled along the base for 20 seconds. At 0853h the subject approached the panel , briefly made contact and swam away. At 1114h the subject approached the panel and crawled along the base for 30 seconds. At 1153h the subject crawled along the base of the panel for five seconds. At 1425h the subject inserted its head through one of the smaller openings at the base of the panel and remained for 15 seconds. At 1441h the subject contacted the panel and sat facing upstream for 15 seconds. At 1443h the subject contacted the base of the panel and remained with one rear flipper through one of the smaller openings for 30 seconds. Test subject number eel This subject was a loggerhead turtle of undetermined sex with a straight carapace width of 58.7 em , a size that should be able to pass through the panel. Testing began at 0920h on December 16 and was completed at 1515h on December 17. The mean water flow velocity during the testing was 1.12 feet per second. Testing on December 16 was conducted with the test panel in the upper orientation.

There were two very brief encounters with the panel. At 1222h the subject contacted the base of the panel 7 and r e mained for fiv e seconds. A t 1247h the subject co ntacted the base of th e panel and remained for three seconds. Testing on December 17 was conducted with the panel in the lower orientation.

There were two encounters with the panel. At 0817h the subject contacted the base of the panel and remained for 35 seconds with one rear flipper through one of the smaller openings in the panel. At 1416h the subject contacted the base of the panel and remained with its head and one front flipper through two of the smaller openings in the panel for three minutes. Test subject number cc2 This subject was an adult female loggerhead turtle with a straight carapace width of 62.8 em, a size that should not be able to pass through the panel. Testing began at 0800h on January 12 and was completed at 1515h on January 13. The mean water flow velocity during the testing was 1.05 feet per second. Testing on January 12 was conducted with the test panel in the upper orientation.

There was only one very brief encounter with the panel. At 11 09h, the subject contacted the base of the panel and turned around, remaining for five seconds. Testing on December 17 was conducted with the panel in the lower orientation.

There were no encounters with the panel over the entire testing period. Test subject number cc3 This subject was a loggerhead turtle of undetermined sex with a straight carapace width of 58.1 em, a size that should be able to pass through the panel. Testing began at 0811h on January 19 and was completed at 1500h on January 20. The mean water flow velocity during the testing was 1.03 feet per second. Testing on January 19 was conducted with the test panel in the upper orientation.

This subject appeared to actively explore the panel on a number of occasions, for a total of seven encounters with the panel. At 0815h, the subject encountered the center of the panel and remained motionless for 15 seconds. At 0823h, the subject crawled slowly across the panel for 50 seconds , contacting the bottom of the velocity cap with its head. At 0830h , the subject crawled from the base to the top of the panel for 15 seconds, inserting both front flippers through the panel. At 0836h, the subject approached the top of the panel and briefly inserted one rear flipper through the panel, remaining for ten seconds. At 1101h, the subject briefly encountered the bottom on the panel and inserted one front flipper through the panel. At 1112h, the subject encountered the base of the panel and turned around, inserting both rear flippers through the panel and remained for 15 seconds. At 1401 hours0.0162 days <br />0.389 hours <br />0.00232 weeks <br />5.330805e-4 months <br />, the subject crawled slowly diagonally across the panel for a total of33 seconds. Testing on January 20 was conducted with the panel in the lower orientation.

There were three encounters with the panel, all in the first half hour of testing. At 0804h the subject contacted the base of the panel, turned around and remained in contact with the panel base for two minutes. At 8 0808h the subject again rested at the base of the panel facing upstream for 2 0 seconds. At 0817h the subject rested at the base of the panel facing upstream for 19 seconds. Test subject number cc4 This subject was a loggerhead turtle of undetermined sex with a straight carapace width of 60.9 em, a size very close to the critical dimension of the panel. Testing began at 0800h on January 24 and was completed at 1500h on January 25. The mean water flow velocity during the testing was 1. 07 feet per second. Testing on January 24 was conducted with the test panel in the upper orientation.

This subject appeared to actively explore the panel on a number of occasions , for a total of seventeen encounters with the panel. At 0803h, 0804h, 0827h , 0835h , 1116h , and 1129h the subject encountered the panel, made contact, turned around , and swam away, each encounter lasting less than ten seconds. At 0831h the subject encountered the upper section of the panel and remained with both rear flippers through the panel for 15 seconds. At 0833h the subject again approached the top of the panel and remained with both rear flippers and one front flipper through the panel for 22 seconds. At 0836h the subject again approached the upper section of the panel and remained with both rear flippers and one front flipper through the panel for 20 seconds. At 0839h the subject approached the base of the panel and remained with both rear flippers through the panel for ten seconds. At 0840h the subject again approached the base of the panel and remained with both rear flippers and one front flipper through the panel for ten seconds. At 1111h the subject crawled slowly across the top of the panel for 21 seconds , with all flippers through various openings in the panel. At 1122h the subject crawled slowly across the center of the panel for 12 seconds. At 1137h the subject encountered the top of the panel and remained for eight seconds. At 1139h and 1451h, the subject crawled slowly across the center of the panel for ten seconds. At 1459 h the subject approached the base of the panel and remained with one rear flipper through an opening for eight seconds. Testing on January 25 was conducted with the panel in the lower orientation. There were seven encounters with the panel. At 0802h the subject contacted the base of the panel and remained with its head through one of the openings in the panel for 15 seconds. At 0854h the subject briefly contacted the base of the panel and turned around , with the encounter lasting three seconds. At 0857h the subject approached the base of the panel and remained with its head and one front flipper through an opening for 15 seconds. At 1101 and 11 02h, the subject made brief encounters with the panel and inserted a front flipper through the panel, with each encounter lasting less than 10 seconds. At 1116h the subject encountered the panel and remained with one rear flipper through an opening for 17 seconds. At 1400h the subject made brief contact with the base of the panel at the start of a testing session and turned away. Test subject number cc5 This subject was a loggerhead turtle ofundetermined sex with a straight carapace width of56.7 em, a size that should be able to pass through the panel. Testing began at 0800h on February 2 and was completed at 1500h on February 3. The mean water flow velocity during the testing was 1. 07 feet per second. 9 T e sting on February 2 was c onducted with th e test pan e l in th e upp er ori e ntation. This subj ec t appeared to actively explore the panel on a number of occasions , for a total of eight encounters with the panel. At the start of testing at 0800h the subject drifted down the bottom of the tank and contacted the base of the panel for nine seconds before swimming away. At 0839h and again at 1139h , the subject crawled briefly across the bottom half of the panel, inserting a front flipper through one of the openings.

At 1116h and again at 1129h , the subject made brief contact with the center of the panel, turned and swam away. At 1158h and again at 1425h , the subject made brief contact with the base of the panel , turned and swam away , with each encounter lasting eight seconds. At 1400h the subject encountered the base of the panel and remained with its head and one front flipper through an opening for 28 seconds. Testing on February 3 was conducted with the panel in the lower orientation.

There was just one encounter with the panel , in the first half hour of testing. At 0812h the subject contacted the base of the panel , and remained for 14 seconds before turning and swimming away. Test sub;ect number cc6 This subject was a loggerhead turtle of undetermined sex with a straight carapace width of 59.3 em , a size very close to the maximum opening in the panel. Testing began at 0800h on February 9 and was completed at 1500h on February 10. The mean water flow velocity during the testing was 1.06 feet per second. Testing on February 9 was conducted with the test panel in the upper orientation.

This subject appeared to actively explore the panel on a number of occasions, for a total of seven encounters with the panel. At 0804h the subject briefly contacted the base of the panel facing upstream.

At 11 01 h the subject approached the base of the panel and remained for eight seconds , inserting one rear flipper through an opening. At 1110h the subject encountered the base of the panel and remained with its head and one front flipper through an opening for 12 seconds. At 1121h the subject crawled slowly across the center of the panel for ten seconds , inserting a front and a rear flipper through various openings.

At 1142h the subject crawled slowly across the base of the panel for eight seconds. At 1157h the subject briefly encountered the base ofthe panel, turned , and swam awa y. Testing on February 10 was conducted with the panel in the lower orientation. There was only one encounter with the panel. At 0816h the subject contacted the base of the panel for five seconds, inserting its head through an opening before turning and swimming away. Test s ubject numb e r ee l This subject was a loggerhead turtle of undetermined sex with a straight carapace width of 49.4 em , a size that should be able to easily pass through the panel. Testing began at 0800h on February 17 and was completed at 1500h on February 18. The mean water flow velocity during the testing was 1.05 feet per second. Testing on February 17 was conducted with the test panel in the upper orientation.

This subject had the largest number of encounters with the panel of any subject tested , a total of 20 encounters. This subject appeared to acti v ely ext6ore the panel on a number of occasions, and app ea r e d to bri efly b ec om e stuck on th e pan e l on two occasions.

Five e ncount ers (0808h , 0809h , 1147h , 1442h , and 1459h) were brief encounters with the base of the panel with the subject turning and swimming away in less than ten seconds. On ten occasions (0801h, 0812h, 0815h, 1102h , 1104h, 1150h, 1402h , 1403h , 1417h , and 1424h), the subject crawled slowly across the panel for 12 to 32 seconds , inserting its head and flippers through various openings. At 0841h the subject approached the upper section of the panel and inserted its head and front flippers through different openings.

The subject was flipped upside down by the current and wedged against the bottom of the velocity cap mockup, where it appeared to struggle to extricate itself. The subject successfully freed itself after 3 0 seconds. At 11 OOh the subject approached the base of the panel , inserted its head through an opening and was flipped upside down by the current , but did not become stuck. At 1135h and 1144h, the subject had brief encounters with the center section of the panel, inserting its head and a rear flipper thorough various openings.

At 1452h the subject again approached the upper section of the panel and inserted its front flippers through different openings. The subject was flipped upside down by the current and wedged against the bottom of the velocity cap mockup, where it appeared to struggle to extricate itself. The subject successfully freed itself after 42 seconds. Testing on February 18 was conducted with the panel in the lower orientation.

The subject again had a large number of encounters (12) with the panel , including the only instance of a subject successfully passing through the panel. In seven of the encounters (0803h , 0806h, 0808h, 0845h, 0851h, 1101h , and 1104h), the subject approached the base of the panel and remained for a considerable length of time (between 24 and 65 seconds) with its head and flippers through various openings. At 1402h the subject approached the base ofthe panel and inserted a front flipper into the gap between the base of the panel and the bottom of the tank, where it remained for seven seconds. At 1406 and 1426 h, the subject approached the middle section of the panel and inserted its head and front flippers through various openings adjacent to the large opening , remaining for 24 seconds on each occasion.

At 1431h the subject again approached the middle section of the panel, this time inserting its head and front flippers through the large central opening and passing through the panel without any apparent problems.

At 1458h the subject approached the base of the panel and inserted both front flippers through one of the openings.

The subject was flipped over by the current, but did not become stuck. Test subject number cc8 This subject was a loggerhead turtle of undetermined sex with a straight carapace width of 55.7 em, a size that should be able to pass through the panel. Testing began at 0800h on February 20 and was terminated at 1435h on February 20 , when the subject apparently became trapped in the panel. The mean water flow velocity during the testing was 1.10 feet per second. Testing on February 9 was conducted with the test panel in the upper orientation.

At 0800h the subject drifted down the tank with the current when the test was initiated , contacting the base of the panel and remaining for 15 seconds. At 1101h the subject approached the middle section of the panel and remained for 50 seconds with its head and both front flippers through various openings.

The subject was flipped upside down by the current, but did not become stuck. At 1435h the subject encountered the upper section of the panel. The subject inserted its head and 11 left front flipp e r through the rectangular opening to th e upper left of the large main opening and its right front flipper through the small triangular opening above the large main opening. At that point, the test water current lifted the posterior of the turtle 45 to 60 degrees so that the posterior was in contact with the bottom of the velocity cap mockup. In this position, the turtle was unable to withdraw its head or flippers from the openings and the velocity cap mockup prevented further lifting of the posterior of the turtle, which otherwise may have allowed the turtle to free itself. In brief, the turtle became "wedged" under the velocity cap mockup in an awkward position where the front flippers were trapped and the rear flippers were not in a position where they could gain any purchase on the velocity cap mockup. We observed the subject's attempt to extricate itself for approximately two minutes. At that point , our opinion was that the turtle had exhausted all its possible options to escape the situation, and we removed the velocity cap mockup and manually pulled the turtle free. Analysis and discussion of test results will be provided in a separate report. In that report we will provide our opinion on why we believe this panel configuration failed and discuss options moving forward. We will also address issues associated with the test plan that could be improved.

12 INDIAN RIVER HUTCHINSON ISLAND INDIAN RIVER r' ATLANTIC OCEAN Figure 1. Circulating water system at St. Lucie Plant, showing location of offshore intake structures and sea turtle barrier nets. 13 Sou them 12 Foot Velocity Cap Northern 1 2 Foot Velocity Cap 16 Foot Velocity Cap 2b: 12-Foot and 16-Foot Pipe Velocity Caps Figure 2. Offshore intake structures 14

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! > '! C-6 -r ----.,.-----,---..----r---.,-----r---.---*-r-----.------.----1---.:::::.-'-'-"-----j Figure 3. Test tank design 15 1/2" x 3" P l at e (Typ.) W 0 Ro d , TRE. D ouble N u t & L ock Washers, (T yp.) Dri l l %"Holes fo r )2" Rods. Ce nt ers L oca t ed %" Above and Be l ow Cente r or 3" Pla t e to A l l ow Rods to C r oss in t h e M id d l e. F P L T UR T L E BARR I E R 43" x 4 3" P ANEL (F RONT V IE W) SCA LE: 1" -1 )2"' ,\u och m ntl I , 1n S(ltd n catin n S P F.'C-C.*I\9 5 , R e v. l S Lt. 9o f 12 Figur e 4. Excluder panel detail 16 (S I D E V I E W) , .... "

-,

r ' 1'-Bl" ... Detall1 Panel divided Into third s DetailS conoentrtc Circlet Detail2 Delail1 rot ated 45 deg rees 1'-3 1" L Detall6 l! Centened 24' Hexagoo 2'/. /. Detall3 17 bar spac ing 1'-1" --i 1'-5" _j Detail4 Detail3 rotated 45 degrees 1' Detail? Sta ck ed 2 4"' Haxsgon Figure 5. Alternative excluder panel designs. 17 APPENDIX 1 Excluder panel tank testing plan-July 2016 18 Introduction Testing a Fix ed Barrier Dev i ce with Live Sea Turtles Revised Turtle Tank Testing Plan-Dated 7/21/16 After testing three loggerhead sea turtles in a test tank with the fixed barrier proposed for installation on the velocity caps at the St. Lucie Nuclear power plant on Hutchinson Island , it was determined that modifications need to be made to the test plan. Turtles that were tested experienced flow rates of 1 foot per second for eight consecutive hours each day followed by a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> rest period. Each turtle was tested for three days before being released back to the ocean. At the end of three days of testing all turtles appeared physically exhausted. The first turtle tested, a 69.2 em SCL loggerhead with a Straight Maximum Carapace Width (SMCW) of 54.8 em was expected to be able to pass through the barrier panel openings, which it did unfettered three times during the testing period. However, the turtle lost 2.2 kg of its body weight (5%) during testing despite eating 8 squid each day after testing. The second turtle tested, a 74.9 em SCL loggerhead with a SMCW of 62.5 em was not expected to pass through the barrier panel opening. This turtle did not pass through the barrier panel after numerous attempts, but spent most of its time during testing swimming against the current. The third turtle, a 67.9 em SCL loggerhead with a SMCL of 57.7 em was expected to be able to pass through the barrier panel. This turtle did not pass through during numerous attempts.

On the third day of testing this turtle would fall asleep upstream of the barrier panel and drift along the bottom until it wound up at the base of the barrier panel. After several minutes the turtle would be prodded to confirm its health status and it would swim back upstream and repeat the scenario several times before we halted testing midway through the testing period to reevaluate the testing plan. The turtle was released the following day after a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rest period. Based on observations during initial testing the current testing plan is too rigorous and does not reflect actual field conditions a turtle would experience when interacting with the proposed barrier. At the offshore velocity cap structures turtles would only experience sustained flow rates of 1' per second for a short period of time when they physically interacted with the barrier system. However, during the current test plan the turtles experience that sustained flow rate for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> over a three day period. To reduce the physical stress on the sea turtles during testing of the barrier system, we are proposing a revised test plan that allows for more rest periods and is more reflective of actual field conditions.

The ultimate intent of the barrier device is to reduce capture rates of sea turtles inside the power plant intake canal, keep reproductively active sea turtles out of the intake canal and possibly deter other size classes of sea turtles from entering the intake structures.

19 Features to be Tested To insure the safety of sea turtles interacting with the proposed barrier structure , the Turtle Barrier Panel will be tested in a controlled environment.

A revised sketch of the prototype barrier panel device is attached, titled "Turtle Barrier Panel Drawing". The test would evaluate the barrier panel opening size adequacy to prevent adult turtles from passing through the device. The test would also evaluate any potential entrapment or injury to turtles. This test is not intended to analyze the physical properties of the barrier device , such as strength of materials , bio-fouling or flow parameters.

Approach The test would be performed in a manner that best exemplifies actual physical conditions expected in the field. In the field, the barrier device will be attached under the top concrete sections of the velocity caps. Therefore, in this revised test plan the barrier device in the Tank Facility will include construction of a mock velocity cap top structure that can be fabricated from materials that provide a similar physical setting expected in the field. The barrier panel configuration that will be proposed for the field application are comprised of a top panel angled at 45 degrees from horizontal situated on top of a bottom panel that is angled 90 degrees relative to the top panel connecting to the floor of the tank. All openings that may be created by this type of configuration must be closed to prevent turtles from passing around the barrier device. Please refer to the attached sketch titled " Turtle Barrier Tank Test' that demonstrates the proposed configuration of the barrier panels in the test facility.

A salt water test tank was constructed adjacent to the intake canal at the St. Lucie power plant. It is 8' wide, 5' deep and approximately 50' long and was designed to allow room for an adult loggerhead sea turtle to swim around the tank unfettered.

Seawater is pulled into the tank from the intake canal and recirculated by pumps to create the flow parameters required by the test criteria. The tank is drained and refilled with fresh seawater approximately every three days. A mock velocity cap (see attached sketch) with the proposed excluder grating was installed in the tank to mimic field conditions at the offshore structure.

The recirculating pumps will create a flow rate of 1' per second through the barrier panel structure during testing. The tank has two Plexiglas viewing windows to allow for observations of sea turtle interactions with the excluder device during testing. Two video cameras were installed on top of the tank to record all turtles during the testing period. An underwater camera will be put in the tank when there is significant turtle interaction with the barrier structure.

20 Pass/Fail Criteria Because the panel is being tested for its performance with regard to preventing a certain size turtle from passing through it , and in consideration that a failure of the test with regard to the safety of the turtles may not be directly linked to the panel , a pass/fail criteria is separated into two parts; panel related events and non-panel related events. This is so the panel design itself is not deemed a failure if there is a non-panel related failure associated with the tank test methods, non-panel related test equipment , or in the handling of the turtles associated with the tests. In general: ..J The panel passes if it excludes the selected sized turtles. The panel fails if it does not exclude the selected size turtles or harms any sized turtle . ..J The tank test passes if it is conducted without harm to any turtles. The tank test fails if a turtle is injured or becomes entrapped as a result of the test methods, test equipment , or handling methods. Panel Component Pass/Fail Criteria:

The following Pass/Fail criteria will be established for the panels and reported as an observation associated with the panel component when applicable:

PASS: 1. Upon attempt to move through the barrier device, a turtle larger than 61 em straight carapace width is prevented from proceeding through the device and is unharmed by the panel. 2. Any turtle smaller than 61cm straight carapace width interacts with (passes or does not pass through) the panel and is unharmed by the panel. FAlL: 1. A turtle larger than 61 em straight carapace width passes through the barrier device. 2. Any sized turtle becomes trapped while interacting with turtle panel including as a result of the panels positioning in the tank (rescue turtle and identify any potential detrimental effect to turtle; suspend test until problem is resolved). 3. Panel is damaged by turtles (take corrective action to repair/reinstall to prevent occurrence).

Tank Testing Pass/Fail Criteria The following Pass/Fail criteria will be established for the tank test and reported as an observation not associated with the panel or panel positioning with regard to entrapment when applicable:

21 P ASS: 1. The turtles involved in the tests are unharmed.

FAIL: 1. Turtle is trapped while interacting with test system (rescue turtle and identifY any potential detrimental effect to turtle; suspend test until problem is resolved)

2. A potential detrimental effect on the turtle is observed (take corrective action to eliminate effect before resuming test) 3. Panel or other system component is dislodged by turtles (take corrective action to repair/reinstall to prevent occurrence)

4. Established water parameters are not met (bring water into compliance before resuming test) Test Suspension Criteria The turtle tank test will be suspended should any injury or harm caused by the testing or handling of turtles for the test occur. The suspension shall be reported to FWC and FPL and the test shall not resume until conditions that caused the harm have been removed and upon FWC and FPL authorization.

If conditions that cause harm are unavoidable then the test must stop and FWC and FPL shall be notified by the tank test staff. The tank test staff, facility manger or turtle test project leader is responsible for notifYing FWC and FPL staff of any harm to turtles caused by activities related to the tests. Test Deliverables A report will be submitted with a complete detail of all tests including a description of all observations made by test tank staff. In addition to observation records a suite of video cameras will be recording all turtle interactions with the panel structure during testing. The video recordings will be presented in the form of an electronic file in either a wmv or mpeg file format. Two copies of the video recordings will be presented on a compact disc(s) and sufficiently labeled with the test subject reference , the test date, test location and any other relevant data. Test Tasks Sample Size A statistical power analysis was performed to provide a sample size that will provide an 84% confidence rate that we will see the true effects of turtle interactions with the barrier device in relation to the pass/fail criteria.

Results from the power analysis are provided below pwr.p.test (h = 0.8 , n =14 , sig.level

=0.05, power=) Proportion power calcu l ation for binomial distribution (arcsine transformation) h= 0.8 n= 14 Sig.level

= 0.05 Power= 0.8492831 With the testing of 14 turtles we have an 84% confidence level that we will see the true effects of any turtle's interactions with the barrier device relevant to the pass/fail criteria.

Sea Turtle Size Classes: A total often (10) loggerheads and four (4) green turtles will be observed for the barrier panel configuration proposed.

Three (3) class sizes ofloggerhead turtles and two (2) size classes of green turtles will be tested. Any change in the barrier configuration will require that the tests be conducted again in their entirety and can only be performed if authorized by FWC and FPL. The turtles that are proposed for testing will be either non-releasable turtles or turtles that have completed rehabilitation treatment and are ready for release from facilities around the state or turtles that have been captured from the intake canal of the St. Lucie power plant's intake canal. Number of loggerhead turtles in each size class to be tested: Two (2) small size class loggerheads expected to be able to pass through the barrier panel. Straight Carapace Width: 45.0-55.9 em ( 6) size class loggerheads that could pass through the barrier panel but would have difficulty domg so. Straight Carapace Width : 56.0-60.9 em Two (2) large size class loggerheads that are not expected to be able to pass through the barrier panel. Straight Carapace Width : > 61.0 em As a precaution, this revised Test Plan includes testing green turtles to assess any potential problems they have when interacting with the barrier panel. A majority of the green turtles captured at the intake canal should easily be able to pass through the large opening in the barrier panel. Number of green turtles in each size class to be tested: Two (2) small size class green turtles. Straight Carapace Width : 25.0-34.9 em Two (2) medium/large size class green turtles. Straight Carapace Width : > 3 5. 0 em 23 Test Methods: The tank test will be set up to ensure that sea water used for the test is free and clear of debris and meets the criteria established for the physical and chemical properties of the water described in more detail later in this document (FWC Sea Turtle Conservation Guidelines).

For the turtle tests, each turtle will be allowed to acclimate to the test tank for a period of 12-24 hours prior to active testing. Each turtle will undergo one (1) hour of active (flow on) testing, separated by a (2) hour rest period with no flow and no access to the panel structure, for an active testing total of six (6) hours for a two day period (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of active testing per day). At the end of the first day of testing the turtle will remain in the tank with no flow and no access to the panel structure.

After the second day of testing the turtle will be released back to the ocean or back to the rehabilitation facility it was procured from. The turtle barrier device will be positioned at one end of the tank attached to the mock section of the velocity cap structure.

The turtle will be placed on the outside (upstream side) ofthe turtle barrier device. Observations shall be made during active testing every 15 minutes and anytime the turtle approaches within three (3) feet of the structure.

The observer will note resting and activity intervals and record behavior of the animal anytime it approaches or interacts with the structure.

During the course of each six (6) hour active test period there will be three (3) hours with the barrier panel in the upper panel configuration and three (3) hours with the panel in the lower panel configuration (see drawing).

Each six (6) hour active test period will include three (3) hour periods of feeding stimulus on the inside (downstream side) of the turtle barrier device. Turtles that move through the barrier device will be returned to the other side of the barrier to the section of the tank where they were originally placed and testing will resume. Environmental Needs Turtle Safety: The handling, transporting, holding, and research related testing of sea turtles will be conducted in accordance with a sea turtle permit holders permit and shall comply with all applicable federal and state regulations, in accordance with the FWC Sea Turtle Conservation Guidelines.

These standards have been deemed acceptable to National Marine Fisheries Service (NMFS) and are further described in "Chapter 16-Sea Turtle Husbandry" by Higgens, Benjamin M.; a chapter from "The Biology of Sea Turtles, Volume IF' by Lutz, Peter L.; Musick, John A.; and Wyneken, Jeanette.

Veterinary supervision and consultation will be provided by WIDECAST staff veterinarian Dr. Nancy Mette, DVM. Turtle tests will be performed in accordance with the turtle captivity and transportation permit requirements associated with activities listed on the sea turtle permit holders permit. 24 The test tank will have adequate means of viewing the behavior of turtles interacting with the barrier device. The barrier panel will be positioned under a mock velocity cap structure that will be viewed from the surface and by underwater video equipment.

The testing staff will have adequate means to observe any turtles that may become entrapped in the test device and associated components.

The testing staff will take great care in preventing the trapping of sea turtles within the test barrier panel. The attachment of the turtle barrier panel to the tank and the mock velocity cap shall be performed in a manner that allows for quick and easy dismantling or removal from the water if a turtle becomes entrapped.

The testing staff will protect the turtles from harm and injury during transportation and while the turtles are staged before and after the tank test. Turtles may be placed in temporary holding tanks before and after the tank tests for limited time periods. The power plant has several holding tanks in close proximity to the proposed test tank. The tank size and length of time the turtle occupies these tanks shall be in accordance with the sea turtle permit holders permit conditions and applicable state and federal regulations.

In an emergency, marine turtles may be kept out of water for a maximum of four ( 4) hours per week. In these cases, the turtles will be protected from core temperature changes and from drying out or other physical damage. Care and Feeding: In general, the care and feeding of sea turtles utilized in the tests will conform to the program implemented by the facility that the turtle was procured from. In the absence of an established care and feeding program the turtles shall be cared for in accordance with standards acceptable to FWC and as described in "Chapter 16-Sea Turtle Husbandry" by Higgens, Benjamin M.; an excerpt from "The Biology of Sea Turtles, Volume IF' by Lutz, Peter L.; Musick, John A.; and Wyneken, Jeanette.

Feeding of the turtles is not required during the test, but stimulus food will be used during the test to entice turtles to enter the structure and try to get through the barrier device. The stimulus food will be food that is in compliance with the requirements of existing permits established by FWCC for the holding facility being used. Environmental Parameters The seawater surface must be unencumbered to allow the sea turtles to surface to breathe and to float. The seawater used in the tanks shall be natural seawater that will continuously meet the following water quality parameters or those recommended by National Marine Fisheries Service (NMFS) and FWC:

• The tank temperature shall be between 20.0°C to 32.0°C as measured by a thermometer accurate to 0.5°C.

• The salinity level shall be between 20ppt to 3 7ppt as measured with a refractrometer accurate to 1 ppt. 25

• Th e pH l e v e l of th e tank shall b e betw e en 7.5 and 8.5 as m e a s ur ed by a digital pH meter accurate to two (2) decimal places.

• Coliform bacteria (MPN) must not exceed 1 000/1 OOml of water. A facility may be exempt from routine testing if steps are taken to prevent bacteria proliferation.

Testing shall be as required by FWC.

• Natural diurnal light patterns should be replicated for the turtles during the tests with excess light and direct sunlight being avoided to control algae growth and to prevent elevated water temperature and sun damage to turtles. Prior to the tank tests the sea water will be tested to verify that the above environmental parameters are met. Testing and monitoring of these tank parameters will be conducted every four hours by facility staff to ensure that the sea water remains within the parameters identified.

Flow Characteristic

Varying flow velocity shall be tested. Velocity shall be measured once per every hour of active testing and recorded on the sea turtle observers data sheet. The flow shall mimic the expected velocity at the offshore intake pipe velocity cap. Velocity Required at Turtle Device: Minimum flow velocity:

1.0 ft/s Maximum flow velocity:

1.5 ft/s The tank test facility will have the ability to control and measure the velocity of the flow at the turtle barrier device to within +/-0.1 ft/s accuracy of the required test flow velocity.

Flow will be measured by a velocity meter accurate to 0.1 ft/s and located immediately downstream of the turtle barrier device and positioned so that it does not cause harm to the turtle. Staffing The following staff is proposed: 1. Responsible Scientist In-Charge (Inwater Research Group, Jonathan Gorham, Ph.D.) 2. Turtle Permit Holder(s) (Inwater Research Group, Michael Bresette)

3. Veterinarian trained in the care of marine turtles (Dr. Nancy Mette , DVM)) 4. Authorized/Qualified

• Turtle Handling/Transporting Staff (Inwater Research Group)

• Authorized/Qualified Turtle Handling/Transport staff will be specifically identified on the Turtle Permit Holders permit. 26 Risks and Contingencies

1. Injury to turtle-Turtle test staff must notify FWC and FPL immediately.

Turtle test staff will submit the appropriate "stranding report" and arrange for transport to the authorized turtle rehabilitation facility 2. Staff entering water-A second handler shall be "suited up" and ready to enter the water when another handler enters the water for any reason. A "wet person" will be on hand during all active testing and ready to remove a turtle from the Turtle Test Tank if it becomes injured or entrapped by the panel or structure.

3. Equipment Failure -In the event of critical equipment failure, equipment shall be readily available so the tank test schedule is not adversely impacted.

Critical equipment includes, but is not limited to, tanks, pumps, panel frame, and video equipment.

27 APPENDIX2 Tank testing observation log 28

________ Average Water Temp_(_q_ : ___ 23.1 1 SCL _(em): *66.9 Sl!lini_!y

_(Qp!): 24.9 ,_§CW (em): 1 51.8__ Average PH: , __ 8_.3 ---------, Observers:

l MJB , JCQ-_____ _

_ ___ CL!<-_____ __ Average current l.J I Water Panel Interacting Velocity Date Time Configuration

-With Panel Failure? (fps) , Behavioral Comments 12/8/20 16 8:12 Upper No No 1.07 Pumps on, start test 12/8/2016 8:2 7 Upper No No 1.24 Resting at south end of tank 12/8/2 016 8: 43 Upper No No 0.97 Resting at south end of tank 12/8/2016 8:58 Upper No No 0.96 Resting at south end of tank 12/8/2016 9:12 Upper No No Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/8/2016 11:12 Upper No No 0.93 Pumps on, start test 12/8/2016 11:27 Upper No No 1.07 Resting at south end of tank 12/8/2016 11:42 Upper No No 1.10 Restingat south end of tank 12/8/2016 11:57 Upper No No 0.98 Resting at south end of tank 12/8/2016 12:12 Upper No No 0.98 Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/8/2016 14:12 Upper No No 0.94 Pumps on, start test 12/8/2016 14:20 Upper No No 1.14 Swimming mid-tank 12/8/2016 14:27 Upper No No 1.14 Swimming mid-tank 12/8/2016 14:42 Upper No No 1.18 At south end of tank 12/8/2016 14:47 Upper No No 1.18 At south end of tank 12/8/2 016 14:57 Upper No No 1.21 At south end of tank 12/8/20 1 6 1 5: 1 0 Upper Yes No Approac h ed within 1m of pa n el , turned and swam back to south end of tank 12/8/2016 15:12 Upper No No Pumps off, held in test tank overnight Turtle_ID_:_;_C_M_1 Water Temp (C):_ 23.3 ------'-=

____ _,.::._A:::..c v-'-er'--'-" age Salinity J gQ!)_: ___ 24.9 -----------------------..:..: 1.-=.8 _______ ----;-A_v_:_e_ra , ge PH: 8.3 O::..b=: s:..:: e..:..rv.:...;e:..: rs.::..:=-,I F MJ-=-=B::2_, -=-J C-=-=G-t----------o A

_ __: 0_.4_4-+1-----, CLK 'Average current (_fRs 1.1 Water Panel Interacting Velocity Date Time Configuration With Panel Failure? (fps) Behavioral Comments 12/9/2016 8:10 Lower No No 1.16 Pumps on, start test 12/9/2016 8:25 Lower No No 1.16 Swimming mid-tank 12/9/2016 8:27 Lower Yes No Approached within I m of panel , tw-ned and swam back to south end of tank 12/9/2016 8:40 Lower No No 1.50 Resting at south end of tank 12/9/2016 8:53 Lower Yes No Approached panel and sat on bottom within lm for 3 minutes 12/9/2016 8:55 Lower No No 1.05 Swimming mid-tank 12/9/2016 9:10 Lower No No Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/9/2016 11: 10 Lower No No 1.06 Pumps on, start test 12/9/2016 11:14 Lower Yes No At base of panel facing upstream for 40 seconds 12/9/2016 11:25 Lower No No 1.16 Resting at south end of tank 12/9/2016 11:40 Lower No No 1.07 Swimming mid-tank 12/9/2016 11:54 Lower No No Sat on bottom near panel for 4 minutes 12/9/2016 11:55 Lower No No 1.11 Swimming mid-tank 12/9/2016 12:10 Lower No No Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/9/2016 14:10 Lower No No 0.96 Pumps on , start test 12/9/2016 14:25 Lower No No 1.02 Swimming upstream end of tank 12/9/2016 14:40 Lower No No 1.22 Swimming upstream end of tank 12/9/2016 14:55 Lower No No 1.06 Resting at south end of tank 12/9/2016 15:10 Lower No No Pumps off, end test. Turtle is removed from tank and released to ocean

__ __

SCL (em): : 53.8 Averag_e ____ 2_2_.4-+l ________________________

_ J SCW PH: 8.3 1 Observers:

1 MJB, CLK (ppm): 0.42 1 Date 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12114/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12114/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 12/14/2016 I '-----j JCG Avergae 1.11 Panel Interacting Time Configuration With Panel 8:30 Upper No 8:35 Upper No 8:39 Upper No 8:45 Upper No 8:46 Upper Yes 9:00 Upper No 9:03 Upper No 9:15 Upper No 9:16 Upper No 9:30 Upper No 11:30 Upper No 11:45 Upper No 12:00 Upper No 12:15 Upper No 12:30 Upper No 12:30 Upper No 14:30 Upper No 14: 37 Upper No 14:45 Upper No 14:52 Upper No 14:54 Upper Yes 15:00 Upper No 15:09 Upper No 15:15 Upper No 15:26 Upper Yes 15:27 Upper Yes 15:30 UQp_er No Water Velocity Failure? (fps) No 1.12 No 1.12 No No 1.10 No No 1.13 No No 1.09 No 1.08 No No No No No No No No 1.10 No No 1.13 No No No 1.16 No No 1.14 No No No Behavioral Comments Pwnps on, start test Approached panel, swam back upstream Approached panel, swam back upstream At south end of tank Crawled across panel for 20 seconds At south end of tank At south end of tank Swimming mid-tank Approached panel, swam back upstream Pwnps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins Pwnps on start test Swimming mid-tank Swimming mid-tank Swimming mid-tank Swimming mid-tank Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins Pwnps on, start test Approached panel, swam back upstream Swimming at south end of tank Approached panel, swam back upstream Interaction with panel fo 9 seconds At south end of tank Swimming mid-tank Up against panel for 15 seconds Up against panel, stuck head through grate Pwn_ps off, turtle kept in test tank overnight

---

' Water

---

'Average Salinity_(QP_!:): Average PH: _Dbserv_ers_: ____ Average Chlorine (pp_m):

_ ___, _____ _ Panel Interacting 24.0 1 22.4 1 0.42 1 1-:t1 T Water 'Velocity ----------

---*-*-------------Date Time Configuration With Panel Failure? (fps) Behavioral Comments 12/15/2016 8: 10 Lower No No 1.14 Pumps on, begin test 12/15/2016 8:25 Lower No No 1.08 Swimming mid-tank 12115/2016 8:40 Lower No No 1.16 At south end of tank 12/15/2016 8:50 Lower Yes No Swims at base of panel , 1 front flipper through , 20 seconds 12/15/2016 8:55 Lower No No 1.05 Swimming at upstream end of tank 12/15/2016 9:10 Lower No No Resting at south end of tank 12/15/2016 9:10 Lower No No Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/15/2016 11:10 Lower No No 1.12 Pumps on, begin test 12/15/2016 11:25 Lower No No 1.00 Resting at upstream end of tank 12/15/2016 11:40 Lower No No 1.05 12115/2016 11:45 Lower Yes No Hit base of panel then turned and swam away , 12 seconds 12/15/2016 11:50 Lower No No Swimming at upstream end of tank 12/15/2016 11:52 Lower Yes No Along base of panel, 30 seconds 12/15/2016 11: 53 Lower Yes No Along base of panel, 5 seconds 12/15/2016 11:55 Lower No No 1.13 Swimming at upstream end of tank 12 11 5/2016 12:10 Lower No No Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/15/2016 1410 Lower No No 1.03 Pumps on, begin test 12/15/2016 14:25 Lower Yes No 1.07 At base , head through panel , 15 seconds 12/15/2016 14:40 Lower No No 1.06 Swimming mid-tank 12/15/2016 14:41 Lower Yes No At base of panel facing upstream , 15 seconds 12/15/2016 14:43 Lower Yes No At base of panel rear flipper through grate , 30 seconds 12115/2016 14: 53 Lower No No 1.32 Resting at south end of tank 12115/2016 15:10 Lower No No Pumps off, end testing. Turtle is removed from tank and released to the oce an

_ _ 6 v-e-ra_g_e W-_-a-ter Tem_p_(_C_) : --23-_-8 ,....1 ------____ I Average Salinity_(tp_t): , _ ____: 2-::_: 1.6 11 1 _______ -* __ -Turtle ID: CC 1 -----.------<

I SCL (em): : 70.9 , sew (em): 58.7 Average PH: 'Observers:

LMI B, RCW , ____

current (__:fp_§j Panel Interacting I Date Time ! Configuration With Panel 1 Failure? 12/16/2016 9:20 Upper No No 12116/2016 9: 25 Upper No No 12/16/2016 9:50 Upper No No 12/16/2016 10:05 Upper No No 12/16/2016 10:20 Upper No No 12116/2016 12: 20 Upper No No 12/16/2016 12:22 Upper Yes No 12/16/2016 12:35 Upper No No 12/16/2016 12: 47 Upper Yes No 12/16/2016 12:50 Upper No No 12/16/2016 13: 06 Upper No No 12116/2016 13:20 Upper No No 12/16/2016 15:20 Upper No No 12/16/2016 15:35 Upper No No 12/16/2016 15:50 Upper No No 12/16/2016 16:05 Upper No No 12/16/2016 16:20 Upper No No 8.3 1 : 0.35

____ _ ---------1.12 1 Water 1 \Velocity I (fps) 1.02 1.24 1.06 1.05 0.99 1.09 1.08 1.03 1.24 Behavioral Comments Pumps on, start test Resting at south end of tank Swimming mid-tank Swimming mid-tank Resting at south end of tank, Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period Pumps on, start test On bottom of panel for 5 seconds Swimming mid-tank On bottom of panel for 3 seconds Swimming mid-tank Resting at south end of tank Swimming mid-tank, Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period Pumps on, start test Swimming mid-tank Swimming mid-tank Swimming at south end of tank Pumps off, turtle held in test tank overnight

, -=T=-=u.:::...rt.:::...le.:__:_ID_: __ __, _____ ____;.Average Water Te!!!QJ,g): , 23.8 L__ _____________________ . SCL -c 7-'-'0:..::.9=----'-----i Average Salinity (Q.p_!): 21.6 1 I i 58.7 Averag'-e_P_H-'-: ---'------,----

8_.3_,_ ____________________

---

I Observers:

j MJB, RCW: Aver'!ge Chlorine (Q.pm):-i-__ .:: 0.::::.3:..:: 5+1 ____________________

_ i JCG , Average current (fp 2_) 1.12 Water Date Time Panel Interacting Configuration

! With Panel I Velocity I Failure? (fps) Behavioral Comments 12/17/2016 8:15 Lower No No 1.03 Pumps on, begin test 12/17/2016 8:17 Lower Yes No At base of panel , one rear flipper through , 35 seconds 12/17/2016 8:30 Lower No No 1.13 Swimmimg at upstream end of tank 12/17/2016 8: 45 Lower No No 0.98 Swimming mid-tank 12/17/2016 9:00 Lower No No 1.26 Swimming mid-tank 12/17/2016 9:15 Lower No No Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/17/2016 11:15 Lower No No 1.28 Pumps on, begin test 12/17/2016 11:30 Lower No No 1.07 Swimming mid-tank 12/17/2016 11:45 Lower No No 1.19 Swimming mid-tank 12/17/2016 12:00 Lower No No 1.06 Swimming mid-tank 12/17/2016 12:15 Lower No No 1.25 Pumps off, 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period begins 12/17/2016 14:15 Lower No No Pumps on, begin test 12/17/2016 14:16 Lower Yes No 1.12 At base of panel, head and one front flipper through, 3 minutes 12/17/2016 14:30 Lower No No 1.03 Swimming at south end of tank 12/17/2016 14:45 Lower No No 1.23 Swimming at south end of tank 12/17/2016 15:00 Lower No No Swinuning at south end of tank 12/1 7/2016 15: 15 Lower No No Pumps off, turtle removed from tank and released to the ocean Turtle ID: CC2 SCL (em): 85.9 sew (em): 1 62.8 9bservers:

I MJB, JCG *CLK Date Time l/12/2017 8:00 1112/2017 8:15 l/12/2017 8:30 1112/2017 8:45 1112/2017 9:00 1112/2017 11:00 1/12/2017 11: 09 1112/2017 11:15 1112/2017 11: 30 1/12/2017 11:45 1/12/2017 12:00 1112/2017 14: 00 1112/2017 14:15 1112/2017 14:30 1112/2017 14:45 1112/2017 1500 _ _n.ll_ ____ _ ------------------

---

Average Salinity (2J)_!)'-'-: ---r---=3'-"'3...:..:.9---j-----------------------

Average PH

' 8.4 __ j AverageChlorine(ppm):

_

Average current (__fps} 1.05 I

Water Panel Interacting , Velocity (fps) 1 Configuration 1 With Pane I Failure? Behavioral Comments Upper No No 1.02 Pumps on, start test Upper No No 1.06 Swimming at upstream end of tank Upper No No 1.04 Swimming at upstream end of tank Upper No No 1.08 Swimming at upstream end of tank Upper No No Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period Upper No No 1.16 Pumps on, start test Upper Yes No Hit base of panel and swam back upstream , 5 seconds Upper No No 0.98 Swimming at upstream end of tank Upper No No 1.02 Swimming at upstream end of tank Upper No No 1.11 Swimming at upstream end of tank Upper No No Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period Upper No No 1.06 Pumps on, start test Upper No No 1.04 Swimming at upstream end of tank Upper No No 1.04 Swimming at upstream end of tank Upper No No 1.17 Swimming at upstream end of tank Upper No No Pumps off, turtle kept in test tank overnight

_ __, ______ , Average Water Tem2_(Q}_: ,

SCL (em): .,.:: ' 8:.::.5.:.:::.9 ______ Salinity.J 22!)_: ___ 3_3-'.9-!i------------------------

1 SCW(cm): 1 62.8

________________________

_ Observers:

I MJB , JCG . __ Average 0.33! J CLK Average Water 1

• Panel 1 Interacting

' I Velocity 1 Configuration I With Panel -Failure? 1 (fps) I !Date Time Behav i oral Comments 1/13/2017 8:15 Lower No No 1.02 Pumps on , begin test 1/13/2017 8:30 Lower No No 1.02 Swimming at south end of tank 1/13/2017 8:45 Lower No No 1.03 Swimming at south end of tank 1/13/2017 9:00 Lower No No 1.02 Swimming within 6' ofpane1 1/13/2017 9:15 Lower No No Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period 1/13/2017 11:15 Lower No No Pumps on, start test 1/13/2017 11:18 Lower No No 1.07 Swam within 2' ofpane1 1/13/2017 11:30 Lower No No 1.05 Swimming at south end of tank 1/13/2017 11:45 Lower No No 1.00 Swimming at south end of tank 1/13/2017 11:46 Lower No No Swam within 3' ofpane1 1/13/2017 12:00 Lower No No 1.00 Swimming at south end of tank 1/13/2017 12:15 Lower No No Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period 1/13/2017 14:15 Lower No No 1.11 Pumps on, start test 1/13/2017 14:30 Lower No No 1.13 Swimming at south end of tank 1/13/2017 14:45 Lower No No 0.99 Swimming at south end oftank 1/13/2017 15:00 Lower No No 1.00 Swimming at south end oftank 1/13/2017 15: 15 Lower No No Pumps off, turtle removed from tank and released to the ocean

'Turtle ID: 'CC3 Water TemQ_(Q---'-:-+--__ 23'-'.-'--'0 '--------------*

__ _ 'scL (cm)c:_.,_:._7.::_c l.:.:::..9 ___ L____ Average Salini_!y (p2!)_: _ 32.0 1 SCW (cm)'-'-:--'5::...: 8:_:_.1=--_______ Average PH: _ 8.4 1 Observers:

MJB, CLK' __ , A_v_e_rage Chlorine (RRm}_: _

Water Panel Interacting Velocity Date Time Configuration With Pane l Failure? (fps) I Behaviora l Comments 11 19/2017 8: 11 Upper No No 1.05 Pum_p_s on, start test 1/19/201 7 8:15 Upper Yes No Resting on panel, 15 seconds 1/19/2017 8:16 Upper No No 1.04 Swimming mid-tank 1/19/20 17 8:23 Upper Yes No Swam along panel, hit head on mock velocity cap , 50 seconds 1119/2017 8:26 Upper No No 1.00 Swimming_

mid-tank 1/19/20 17 8:30 Upper Yes No Swam to top of panel both front flippers through grate, 15 seconds 1/19/2017 8:36 Upper Yes No At top of panel one front t1 i pper stuck through, I 0 seconds 1119/2017 8:41 Upper No No 1.00 Swimming at far end of tank 1119/2017 8:56 Upper No No 1.02 Swimming at far end of tank 1/19/2017 9:11 Upper No No Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period 1/19/2017 11: 00 Upper No No 1.01 Pumps on , start test 1/19/201 7 11:01 Upper Yes No At bottom of panel one fi*ont flipper through, 5 seconds 1/19/2017 11:12 Upper Yes No At bottom of panel, rear t1 ippers through 15 seconds 1/19/2017 11:15 Upper No No 1.08 Swimming at far end of tank 1119/2017 11: 30 Upper No No 1.01 Swimming at far end of tank 1119/2017 11:45 Upper No No 1.04 Swimming at far end of tank 1/19/2017 12:00 Upper No No Pumps off. begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period 1/19/2017 14:00 Upper No No 1.01 Pumps on, start test 1/19/2017 14:01 Upper Yes No Crawe ld across panel, 33 seconds 1119/2017 14: 15 Upper No No 1.01 At far south end of tank 1119/2017 14: 30 Upper No No At far south end of tank 1/19/2017 14:45 Upper No No 1.03 At far south end of tank 1119/2017 15:00 Upper No No Pumps off. turtle kept in test tank overnight

',-:: T::.:: urt=-=le-=--=ID-"--'-:

1 23.0 1 ________________________

_ SCL ___ ;_ _____ !.Average Salini!Y_(p_pt)'-'-:---t----=-3--:-2-'-'.o-11-________________________

_

i 58.1 , Average PH: , 8.4 1

• 1 : Average current (fp_0__j 1.03

• Panel Interacting I Ve l ocity I 1 Date Time !Configuration

' WithPanel Failure? ' (fps) I Behavioral Comments 1/20/2017 8:00 Lower No No Pumps on, start test 1/20/2017 8:04 Lower Yes No 1.1 I Resting at bottom of panel, over 2 minutes l/20/2017 8:08 Lower Yes No Resting at bottom of panel, over 20 seconds 1/20/2017 8:15 Lower No No 1.10 At far south end of tank 1/20/20 1 7 8: 17 Lower Yes No At bottom of panel, 19 seconds 1120/2017 8:30 Lower No No At far south end of tank 1120/2017 8:45 Lower No No 1.08 At far south end of tank 1/20/2017 9:00 Lower No No 1.07 Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period 1/20/2017 11:00 Lower No No Pumps on, start test 1/20/2017 11:05 Lower No No 1.00 At far south end of tank 1/20/2017 11:15 Lower No No 1.00 At far south end of tank 1/20/2017 11:30 Lower No No 1.03 At far south end of tank 1120/2017 11:45 Lower No No 1.00 At far south end of tank 1120/2017 12:00 Lower No No Pumps off, begin 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest period 1/20/2017 1400 Lower No No 1.00 Pumps on, start test 1/20/2017 1415 Lower No No 1.01 At south end of tank 1/20/2017 14:30 Lower No No 1.00 At south end of tank 1/20/2017 14:45 Lower No No 1.12 At south end of tank 1/20/2017 1500 Lower No No Pumps off, turtle removed from tank and released to the ocean Turtle ID: CC4 Average Water Temp (C): 21.3 SCL (em): 65.8 Average Salinity (ppt): 31.5 sew (em): 60.9 Average PH: 8.4 Observers:

JCG, CLK Average Chlorine (ppm): 0.00 Average current ( fps) 1.07 Water Panel Interacting Velocity Date Time Confi2uration With Panel Failure? (fps) Behavioral Comments 1124/2017 8:00 Upper No No 1.25 Pumps on, start test 1/24/2017 8:03 Upper Yes No Approach grate, contacts swims away, 6 seconds 1/24/2017 8:04 Upper Yes No Approach grate, contacts swims away, 2 seconds 1124/2017 8:15 Upper No No 1.1 Swimming at upstream end 1124/2017 8:27 Upper Yes No Approach grate, contacts swims away , 8 seconds 1124/2017 8:30 Upper No No 1.07 Swimming at upstream end 1/24/2017 8: 31 Upper Yes No Both RF through panel near surface, I 5 seconds 1124/2017 8:33 Upper Yes No Both RF and 1 FF through pane l near surface, 22 seconds 1/24/2017 8:35 Upper Yes No Approaches pane l , contacts , then turns away , 2 seconds 1/24/2017 8:36 Upper Yes No Top of panel, under cap, both RF, 1 FF through, 20 seconds 1/24/2017 8: 39 Upper Yes No Both RF through panel near bottom , I 0 seconds 1/24/2017 8:40 Upper Yes No Both RF and 1 FF through panel near bottom, 10 seconds 1/24/2017 8:45 Upper No No 1.17 Swimming at upstream end 1124/2017 9:00 Upper No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 1124/2017 11:00 Upper No No 1.16 Pumps on , start test 1124/2017 I I : 11 Upper Yes No Crawls across panel near top, all flippers through grate, 21 seconds 1124/2017 11:15 Upper No No 1.1 Swimming at upstream end Turtle ID: CC4 Average Water Temp (C) : 21.3 SCL(cm): 65.8 Average Salinity (ppt): 31.5 SCW(cm): 60.9 Average PH: 8.4 Observers:

JCG, CLK Average Chlorine (ppm): 0.00 Average current : fps) 1.07 Water Panel lute racting Velocity Date Time Configuration With Panel Failure? (fps) Behavioral Comments 1/24/2017 ] 1: 16 Upper Yes No Approaches panel , contacts, then turns away , 5 seconds 1/24/2017 11: 22 Upper Yes No Crawls across panel , head and 1 RF through , 12 seconds 1/24/2017 11:23 Upper No No Approaches panel, turns away, no contact l/24/2017 11:29 Upper Yes No Swims along panel with contact, 6 seconds 1124/2017 11:30 Upper No No 1.21 Swimming at upstream end 1/24/2017 11: 37 Upper Yes No At panel near surface , 1 RF through panel , 8 seconds 1124/2017 1 1:39 Upper Yes No Crawl across pane l , mid-panel , 10 seconds 1124/2017 11:45 Upper No No 1.18 Swimming mid-tank 1/24/2017 12:00 Upper No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 1/24/2017 14:00 Upper No No 1.05 Pumps on, start test 1124/2017 14:15 Upper No No 1.14 Swimming at upstream end 1124/2017 14:30 Upper No No 1 Swimming at upstream end 1124/2017 14:45 Upper No No 1 Resting at upstream end 1/24/2017 14: 51 Upper Yes No Crawl across panel , mid-panel , 10 seconds l/24/2017 14:59 Upper Yes No Approached grate near bottom-RFF through gate , 8 seconds 1124/2017 15:00 Upper No No Pumps off, turtle kept in test tank overnight Turtle ID: CC4 Average Water Temp (C) : 21.3 SCL (em): 65.8 Average Salinity (ppt): 31.5 sew (em): 60.9 Average PH: 8.4 Observers:

JCG, CLK Average Chlorine (ppm): 0.00 Average current (fps) 1.07 Water Panel Inte raeting Velocity Date Time Configuration With Panel Failure? (fps) Behavioral Comments 1/25/2017 8:00 Lower No No 1 Pumps on, start test 1/25/2017 8:02 Lower Yes No Head through bottom of grate, 1 5 seconds 1125/2017 8:15 Lower No No 1.14 Switmning far south end of tank 1/25/2017 8:30 Lower No No 1 Swimming far south end of tank 1125/2017 8:45 Lower No No 1 Swimtning far south end of tank 1/25/2017 8:54 Lower Yes No At bottom of grate for 3 seconds 1/25/2017 8:57 Lower Yes No Flipper and head through grate , 15 seconds 1/25/2017 9:00 Lower No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 1/25/2017 11:00 Lower No No 1 Pumps on, start test 1/25/2017 11:01 Lower Yes No LFF through grate , 7 seconds l/25/2017 11:02 Lower Yes No LFF through grate, 3 seconds 1/25/2017 11:15 Lower No No 1.04 Swimming far south end of tank 1/25/2017 11:16 Lower Yes No Right FF through grate, 17 seconds 1125/2017 11:30 Lower No No 1.05 Swimming far south end of tank 1/25/2017 11:39 Lower No No Approached grate, turned and swam upstream 1/25/2017 11:45 Lower No No 1.03 Swimming far south end of tank 1/25/2017 12:00 Lower No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 1/25/2017 14:00 Lower Yes No l Start test, pumps on, at bottom of grate 1125/2017 14:15 Lower No No 1 Swimming far south end of tank 1/25/2017 14:30 Lower No No 0.98 Swimming far south end of tank 1/2 5/2017 14:45 Lower No No 0.98 Swimming far south end of tank 1/25/2017 15:00 Lower No No 1 Pumps off, turtle removed from tank and released to the ocean Turtle ID: ccs Average Water Temp (C) 21.5 SCL (em): 64.9 Average Salinity (ppt): 34.0 SCW(cm): 56.7 Average PH: 8.4 Observers:

MJB, JCG Average Chlorine (ppm): 0.49 Average current ( fps) 1.07 Water Panel Interacting Velocity Date Time Configuration With Panel Failure? (fps) Behavioral Comments 2/2/2017 8:00 Upper Yes No 1 Pw11ps on, start test , turtle at bottom of grate , 9 seconds 2/2/2017 8:15 Upper No No 1.03 Swimming at far south end of tank 2/2/2017 8:30 Upper No No 1 Swimming at far south end of tank 2/2/2017 8: 39 Upper Yes No Crawled across botton of Grate , LFF through bars, 8 seconds 2/2/2017 8:45 Upper No No 1.06 Swimming at far south end of tank 2/2/2017 9:00 Upper No No Pwnps offfor 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/2/2017 11:00 Upper No No 1.12 Pwnps on, start test 2/2/2017 11:15 Upper No No 1.33 Swimming at far south end of tank 2/2/2017 11:16 Upper Yes No Approached mid panel , RFF through grate 2/2/2017 11:29 Upper Yes No Approached mid panel , brief contact , swam away , 5 seconds 2/2/2017 11:30 Upper No No 1.09 Swimming at far south end of tank 2/2/2017 11:39 Upper Yes No Crawl led across bottom of panel , I FF through grate, 5 seconds 2/2/2017 11:45 Upper No No 1.03 Swimming at far south end of tank 2/2/2017 11 :58 Upper Yes No Approaches base, faces, upstream , swims awa y, 8 s econds 2/2/2017 12:00 Upper No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/2/2017 14:00 Upper Yes No I. II Pumps on, start test , at base of grate, head and RF F through grate , 28 seconds 2/2/2017 14:15 Upper No No 1.05 Swimming at far south end of tank 2/2/2017 14:25 Upper Yes No Bottom of grate , turned around and swam away, 8 seconds 2/2/2017 14:30 Upper No No 1.02 Swimming at far south end of tank 2/2/2017 14:45 Upper No No 1.07 Swimming at far south end of tank 2/2/2017 15:00 Upper No No Pwnps off, turtle kept in test tank overnight Turtle ID: CC5 Average Water Temp (C) 21.5 SCL(cm): 64.9 Average Salinitv (ppt): 34.0 sew (em): 56.7 Average PH: 8.4 Observers:

MJB, JCG Average Chlorine (ppm): 0.49 Average current (fus) 1.07 Water Panel Interacting Velocity Date Time Configuration With Panel Failure? (fps) Behavioral Comments 2/3/2017 8:00 Lower No No 1.03 Pumps on, start test 2/3/2017 8:12 Lower Yes No At bottom of grate for 14 seconds 2/3/2017 8: 15 Lower No No 1.03 Swimming at far south end of tank 2/3/2017 8:30 Lower No No 1.01 Swimming at far south end of tank 2/3/2017 8:45 Lower No No 1 Swimming at far south end of tank 2/3/2017 9:00 Lower No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/3/2017 11:00 Lower No No 1.02 Pumps on.. start test 2/3/2017 11:07 Lower No No Did aU-turn under grate (bottom), no contact 2/3/2017 11:23 Lower No No 1 Swimming at far south end of tank 2/3/2017 11: 30 Lower No No 1.09 Swimming at far south end of tank 2/3/2017 11: 42 Lower No No approached

/ turned around, no contact 2/3/2017 11:45 Lower No No 1.22 Swimming at far south end of tank 2/3/2017 12:00 Lower No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/3/2017 14:00 Lower No No 1.08 Pumps on, start test 2/3/2017 14:15 Lower No No 1.14 Swimming at far south end of tank 2/3/2017 14:30 Lower No No 1.06 Swimming at far south end of tank 2/3/2017 14:45 Lower No No 1.12 Swimming at far south end of tank 2/3/2017 15:00 Lower No No Pumps off. turtle removed from tank and released to the ocean Turtle ID: CC6 Average Water Temp (C) : 22.5 SCL (em): 84.4 Average Salinity (ppt): 33.9 SCW(cm): 59.3 Average PH: 8.41 Observers:

MJB,JCG Average Chlorine (oom): 0.04 Average current ( fps) 1.06 Water Panel Velocity Date Time Configuration Interactine:

With Panel Failure? (fps) Behavioral Comments 2/9/2017 8:00 Upper No No 1.24 Pumos on, start test 2/9/2017 8: 04 Upper Yes No Contact base ofoanel facing upstream, 8 seconds 2/9/2017 8:15 Upper No No 1.29 Swimming mid-tank 2/9/2017 8:30 Upper No No 1.15 Swimming mid-tank 2/9/2017 8:45 Upper No No 1.15 Swimming mid-tank 2/9/2017 9:00 Upper No No Pumos off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/9/2017 11:00 Upper No No 1.11 Pumos on. start test 2/9/2017 11: 01 Upper Yes No Bottom ofoanel, 1 RF through grate, 6 seconds 2/9/2017 11: 10 Upper Yes No Head and FF through base of panel, I 0-12 seconds 2/9/2017 11:15 Upper No No 1 Swimming at far south end of tank 2/9/2017 11:21 Upper Yes No Craw l ed across center of panel, I RF, 1 FF through , I 0 seconds 2/9/2017 11:24 Uoper Yes No Head and both FF through middle of panel, 20 seconds 2/9/2017 11:30 Upper No No 1.01 Swimming at far south end of tank 2/9/2017 11: 42 Upper Yes No Crawled across bottom of panel , 8 seconds 2/9/2017 11:45 Uooer No No 1.05 Swimming at far south end of tank 2/9/2017 11: 57 Upper Yes No Hit base of panel then swam upstream 2/9/2017 12:00 Upper No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/9/2017 14:00 Upper No No 1.01 Pumps on, start test 2/9/2017 14:15 Upper No No 1 Swimming at far south end of tank 2/9/2017 14:16 Upper No No Approached panel and turned around 2/9/2017 14:30 Uooer No No 1 Swimming at far south end of tank 2/9/2017 14:45 Upper No No 1 Swimming at far south end of tank 2/9/2017 15:00 Upper No No Pumps off turtle kent in test tank overnight Turtle ID: CC6 Average Water Temp (C): 22.5 SCL (em): 84.4 Average Salinity (ppt): 33.9 SCW(cm): 59.3 Average PH: 8.41 Observers:

MJB JCG Average Chlorine (ppm): 0.04 Average current ( fus) 1.06 Water Panel Velocity Date Time Configuration Interacting With Panel Failure? (fps) Behavioral Comments 2/10/2017 8: 00 Lower No No 1.1 Pumps on, start test 2/1 0/2017 8: 15 Lower No No 1 Swimming at far south end of tank 2/10/2017 8: 16 Lower Yes No Put head through bottom of panel , 5 seco nd s 2/10/2017 8:30 Lower No No 1.03 Swimming at far south end of tank 2/10/2017 8:45 Lower No No 1 Swimming at far south end of tank 2110/2017 9:00 Lower No No Pumos off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/10/2017 11: 00 Lower No No 1 Pumps on, start test 2/10/2017 11:15 Lower No No 1.07 Swimming at far south end of tank 2/10/2017 11:30 Lower No No 1.08 Swimming at far south end of tank 2/10/2017 11:45 Lower No No 1.01 Swimming at far south end of tank 2/10/2017 12: 00 Lower No No Pumps off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/10/2017 14:00 Lower No No 1.08 Pumps on, start test 2/10/2017 14:15 Lower No No 1 Swimming at far south end of tank 2/10/2017 14:30 Lower No No 1.03 Swimming at far south end of tank 2/10/2017 14:45 Lower No No 1.09 Swimming at far south end of tank 2/10/2017 15:00 Lower No No Pumps off, turtle removed from tank and released to the ocean Turtl e ID: CC7 Ave r age Wa t er Temp (C): 21.4 SCL(cm): 5 8.7 A ve rage S a li nitv (o ot): 3 2.1 sew (em): 49.4 Average PH: 8.45 Observers:

MJB JCG Average Chlorine (pp m): 0 CLK.RCWCRM Average curren t ( fbs) 1.0 5 Water Panel Velocity Date Time Configuration Interacting With Pa n el Failure? (fps) Behavioral Comments 2/17/2017 8:0 0 U pp er No No 1.05 Pum o s on start tes t 2/17/2 0 17 8: 01 UnDer Ye s No Middl e and bottom o f D a ne!, a ll flipp e r s throu g h , 27 se cond s 2/17/2 017 8: 08 Upp e r Y es No Bottomo f oan e l , both FF thrm;h , 8 sec ond s 2117/2 017 8: 09 Uoo e r Y es N o Hit panel a nd turn e d , 2 se cond s 2 117/2 017 8: 12 Upp e r Y e s No Acro ss entir e oan e l , all flioo e r s and he a d through , 3 0 se cond s 2 117/2 017 8: 15 Upp e r Ye s No 1.08 Mid o a n e l a ll flioo e r s throll!!h 15 se cond s 2117/2017 8:3 0 U o oer No No 1.06 Sw i mming upstream south e nd of tank 2/17/2 017 8: 41 Upp e r Ye s N o To o ofoan e l , h ea d and both FF throu g h , flipp e d U))s id e cl ow n bri e fl y b e f o r e fr ee in g its e lf, 3 0 se cond s 2/1 7/2 017 8: 45 Uo o er No No 1.0 2 Swimming midtank 2/17/2017 9: 00 U p per No No Pumos off fo r 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2/1 7/2017 11: 00 Upper Y es N o I Pumos o n , sta rt t est, turtl e at b o tt o m of gr at e, flipp e d up s id e d o wn 2/17/2 017 11: 02 Upp e r Y es No RR F & RFF through p a n e l , II se c o nd s 2/1 7/2 017 11: 04 Upp e r Y es N o U oo e r p a n e l , a ll flipper s and h ea d throu g h , 3 2 seco nd s 2/17/2017 11:15 Uooer No No 1.02 Sw i mmi n g uostream south end of tank 2/17/2 01 7 11:30 Uo o er N o N o 1 Swimming upstream south end of tank 2/17/2017 11:35 Upp e r Y es N o Mid oan e l RRF o a n e l 2/17/2 017 11: 44 Upp e r Y es No Mid panel h ea d throu g h , 12 sec ond s 2/1 7/2017 11: 45 Up p er No No Swimming midtank 2/1 7/2017 11: 47 Upper Y es No Both RF throu g h, 2 seco nd s 2 117/2 017 11:50 Uop e r Y es N o A ll flipp e r s thr o ugh p a n e l , 2 0 seco nd s 2/17/20 1 7 12: 0 0 Upper No No Pumos off for 2 ho u r rest 2/17/2 0 1 7 14:0 0 U p per No No 1.08 Pum o s on, start t es t 2/17/2 0 1 7 14: 0 2 Upp e r Y es N o A ll flioo e r s throu-;;h o a n e l , 3 0 seco nd s 2/17/2 017 14: 0 3 U op e r Y es No All flioo e r s throu g h p a n e l , mid p a n e l , 14 s e c ond s 2/17/2017 14:15 U pp er N o No 1.05 Swimming uos tr ea m so u th en d of tank 2/1 7/201 7 14:17 Upp e r Ye s N o Mid p a n e l , h ea d and a ll tlioo e r s thr o ugh pan e l , 17 se c o nd s 2/1 7/2017 14:2 4 U pp e r Y es N o B o tl1 RF a nd RFF o a nel , 12 seco nd s 2117/2017 14:30 Up p er No No 1.06 Sw i mming midtank 2/17/2 017 14: 4 2 U op e r Y es N o RR F throu gh o a nel, 2 se c o nd s 2117/20 1 7 1 4: 45 Upper No No I Swimming upstream south e n d of tank 2/17/2 017 14: 54 Upp e r Y es N o T oo of p a ne l , w e d ge d a ll fl i pp e r s thr o u gh p a n e l , flipp e d up s id e d ow n , 4 2 seco nd s 2 117/2 017 14: 59 Uooer Y es N o A ll tlioo e r s tl1rough , 6 sec ond s 2/17/2017 15:00 Upper No No Pumps off. turt l e kept in test t ank overnight Turtle ID: CC7 Average Water Temp (C): 21.4 SCL (em): 58.7 Average Salinitv (not): 32.1 SCW(cm): 49.4 Average PH: 8.45 Observers:

MJB JCG Average Chlorine (ppm): 0 CLK.,RCW CRM Average current ( fus) 1.05 Water Panel Velocity Date Time Configuration Interacting With Panel Failure? (fos) Behavioral Comments 2/18/2017 8:00 Lower No No 1.1 Pumos on, start test 2/18/2017 8:03 Lower Yes No Bottom panel, head through, 44 seconds 2/18/2017 8:06 Lower Yes No Against grate, 30 seconds 2/18/2017 8:08 Lower Yes No Bottom of grate, head and fi*ont nippers through, 65 seconds 2118/2017 8:15 Lower No No 1.05 Swimming south end of tank 2118/2017 8:30 Lower No No 1.09 Swimming south end of tank 2/18/2017 8:45 Lower Yes No 1.06 Bottom panel , front nippers and head through , 45 seconds 2/18/2017 8: 51 Lower Yes No Bottom panel , 24 seconds 2/18/2017 9:00 Lower No No Pumos off for 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> rest 2118/2017 11:00 Lower No No 1 Pumps on, start test 2/18/2017 11:01 Lower Yes No Front fl i poers through panel , 69 second s 2/18/2017 11: 04 Lower Yes No Against grate , 30 seconds 2/18/2017 11:15 Lower No No 1.11 Swimming south end of tank 2118/2017 11: 30 Lower No No 1.13 Swimming south end of tank 2/18/2017 11:45 Lower No No 1.1 Swimming south end of tank 2118/2017 12:00 Lower No No Pumos off for 2 hotrr rest 2/18/2017 14:00 Lower No No 1.02 Pmnps on, start test 2/18/2017 14:01 Lower No No Circled underneath, no contact, 3 seconds 2/18/2017 14:02 Lower Yes No Swam underneath bottom panel , LFF through , 7 seconds 2/18/2017 14:06 Lower Yes No Mid oanel , head and FF thrm;h , 24 seconds 2/18/2017 14:15 Lower No No 1 Swimming south end of tank 2/18/2017 14: 26 Lower Yes No Mid-bottom panel , Head and RFF through , 24 second s 2/18/2017 14:30 Lower No No 1.13 2/18/2017 14:31 Lower Yes No Turtle went completely through middle panel, pumps turned ofT 2/18/2017 14:34 Lower No No Pmnps turned back on, testing resumed, turtle swam underneath panel but no contact made 2/18/2017 14: 36 Lower No No Swam under oanel, no contact 2/18/2017 14:45 Lower No No 1 Swimming south end of tank 2/18/2017 14:58 Lower Yes No All flippers through gate , tliooed uoside down, then out, 24 s econds 2/18/2017 15:00 Lower No No Pmnos off, turtle removed from tank and released to the ocean T urtle ID: CC8 Average Wa t e r Temp (C 23.0 SCL (em): 69.3 Average Sa l initv (ootl: 30.9 SCW (c m): 55.7 Ave r age PH: I 8.4 O bserv e rs: MJB JCG Average C hl ori n e (ppm): 0.00 Ave r age Veloc i tv (fus) 1.1 Wat e r Pa n e l In t erac tin g Ve locity Da t e Time C o nfig urat ion W ith Pa n e l Fail u re? (f p s) Beha vio ra l C o mments 2/2 0/2 017 8: 00 Upper Ye s N o 0.9 8 Ptu11p s o n. s tart t es t. A t bonom of grat e. 15 s ec o nd s 2/20/2017 8:15 U oo e r No No 1.03 Sw i nnning upstream a t e n d of tank 2/20/2017 8:30 Upper No No 1.34 Swinnni n g uostream at end of tank 2/20/20 1 7 8:45 I Uooe r No No 1.1 Swimmi n g up stream a t end of t ank 2/20/2017 9:00 Up p e r No No Pumos off f or 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> res t 2/20/2017 11:00 Uoper No No 1 Pumps on. start t est 2/2 0/2 01 7 11: 0 1 Upp e r Y es N o Halfb o d v. h ea d a nd Oioper s thr o u *h. Oiooed uo s id e down. 5 0 se c o nd s 2/20/2017 11:10 Uppe r No No Approache d p anel an d turned to swim back upstream 2/20/20 1 7 1 1:15 Uooer No No 1.06 Sw i n n ning upstream at e n d of t ank 2/20/20 1 7 1 1:30 Uppe r No No 1.03 Swinnning upstream at end of tank 2/20/20 1 7 1 1:45 Upper No No 1.17 Sw i n nni ng u ps tr eam a t end of tank 2/20/2017 12:00 Upper No No Pumps off fo r 2 h our r est 2/20/20 1 7 14:00 U p pe r No No 1.29 P u mos on. sta rt tes t 2/20/2017 14:15 Uooe r No No 1.07 Swinnning u pstream at end of tank 2/20/20 1 7 1 4:30 Upper No No 1.03 Swinnning upstream at end of tank 2/20/2 0 1 7 14: 3 5 Upper Y es Y es T E ST FAfL-T t u1 le s tu ck f o r 2+ minut es we d ge d bet we en t o p o f panel and b o nom o f cap. pwnp s tur ne d off, t est t e r mintnt e d. tunle r e l e a se d in o ce an Test Facility Test Tank Turtle Tank Testing Plan Attachment 3 Page 1 of 6 Flow Return Piping Barrier Test Panel Turtle Tank Testing Plan Attachment 3 Page 2 of 6 2 Turtle Tank Testing Plan Attachment 3 , Page 3 o f 6 Flow Stilling Well Turtle Tank Testing Plan Attachment 3, Page 4 o f 6

\.0 ....... 0 L{)

Turtle Tank Testing Plan Attachment 3 Page 6 of 6

..... , ' "\ .KE \ liNG ) l1 / .---/ / / CAP -PLAN VIEW -664 SHEET 28A} ;.HT (FT.) OPENING NO. 6.9' 16-9 6.9' 16-10 6.9' 16-11 6.9' 16-12 6.9' 6.9' 6.9' 6.9' GULUMN::;

8'-ti" UJA.( I Yl-'.) PRECAST WAFFLE PANELS (TYP.) BARRIER ASSEMBLIES LENGTH (FT.) HEIGHT (FT.) 9.50' 6.9' 16.50' 6.9' 9.50' 6.9' 11.83' 6.9' NORTH 12" VELOCITY CAP PLAN VIEW (REF. 8770-G-664 SHEET 2A) NORTH 12" VELOCITY CAP OPENING NO. LENGTH (FT.) 12N-1 12.3' 12N-2 15.0' 12N-3 12.3' 12N-4 15.0' 12N-5 12.3' 12N-6 15.0' 12N-7 12.3' 12N-8 15.0' DRAWING REFENCES:

---** .. , .... , 12' VELOCITY CAPS INTERIOR COLUMNS 9'-6" DIA.(TYP.) SOUTH 1 2" PLJ! (REF. 8 77 0* $OUT H 12" V E l HEIGHT (FT.) OP E N I NG N O. 6' 12 S-1 6' 1 2 S-2 6' i 12S-3 6' 12S-4 6' 12S-5 6' I 12S-6 6' ' 12S-7 6' 12S-8 AFFECTED WI N G: 8770-G-I I ST. LUCi i OCE AN *

.>, TURTLE BARRIER 'CAP 145'+/-

12N h -7. JRTLE BARRIER SEMBLIES (TYP.) .INE ll12' PIPES 44'+/- 44'+/- l ( ,.-----yll12' PIPELINE 1 1 0 ...-' 0 II II II II II II II I I II II I I II TURTLE BARRIER ; ----------

I 8'-2" E X TERIO R COLUM N 16' VELOCITY CAP ; EXTERIOR COLUMN I i B AR R IER DEVICI __ L __________ _ --,-----------

I j _ _;L __________

_ CONNECTION

DETA IL 3UPPORDTRAY

ONNECTION, TYP. 3EE DETAIL (SH 2) iEMBLY rH ETAIL SEE SH 2 (TYP.)

AP OPENING :lUI RED Yz" r.HAMFFR TO_/ 6" 1 *ALTERNATE WELD DETAIL BARRIER TRAY ASSEMBLY 12' TRAY LENGTH SEE BARRIER PANEL DETAILS {SH 2 TYP.) 11' FOR BARRIER PANEL CONNECTION DETAIL SEE SH 2 (TYP.) BARRIER PANEL ASSEMBLY 12' VELOCITY CAP 12'-4" VELOCITY CAP OPENING 16 ASSEMBLIES REQUIRED Yz" 0 HOLE CHAMFER BOTH SIDES 11 1" X 1" x 3" BAR

&:: BARRIER TRAY ASSEMBLY 11 '-6" TRAY LENGTH 10'-6" FOR BARRIER PANEL CONNECTION DETAIL SEE SH 2 (TYP.) , BARRIER PANEL ASSEMBLY 16' VELOCITY CAP 11'-10"GOLUMN GAP 12 ASSEMBLIES v

c Pr.f I I (SH 2T'r BJ.I FOR BARR BA D RAWit W ORKTHI AFFECTED DRfA W I N G: 8770-G* TITLE: ST. LUCI OCEAN WIDE GAP SPACERS REQUIRED ;EMBLY NGTH I ON DETAIL (TYP.)

AP t r..:p

!UIRED PSPACER 1/2' x 3' 316 SS PLATE, (TYP.) 0 316 SS ROD, THREAD EACH( WAY WITH DOUBLE NUT AND LOCK WASHER (CHAMFER EACH END OF ROD) DRILL%" HOLES RODS.

CENTERS LOCATED Y." ABOVE AND BELOW CENTER OF 3' PLATE TO ALLOW RODS TO CROSS IN THE MIDDLE. WIDTH AS SHOWN ON BARRIER TRAY ASSEMBLY JTH AS SPECIFIED SECTION E DOWN

\ND-IT KE0348 \LL-LOK SS TIE . . n L 6" X 6" xJ.';!" SUPPORT

• CLEAR OPENING TURTLE BARRIER PANEL 3'-7" x 3'-7" PANEL-(FRONT VIEW) (180 REQ'D) k L 6" X 6" I L 6" X 6" X J.';!" 8 1/2" x 3" PL A TE (TYP.) I (SIDE GAP SPACER BAR R i l CONN EC" 3'-7" x 3'-7" PAl\ AFFECTED DRAWING: 8770-G I I; ST. LUCI OCEAN I I SH 2, SIM ..___...

SUPPORT .<\ <J <J 1" SS HILTI KWIK-BOL T 3, MIN. EMBED. 4>':!" 14 4 264 EA NUTS, 1" A-194, 8M I 5 896 EA. BOLTS, )'2" x 1 %" A-193, B8M I NUTS,W I 6 896 EA. ( A-19 4, 8M I 7 360 EA. TIE WRAPS, 400 LB MIN. CAPACITY 316 ss I 8 3,910 L.F. PLATE,>':!" x 3" (LENGTH CUT TO SUIT) A-276, TYPE 316 I 9 1,300 L.F. RODS, )'2" x 43", TBE 4" A-276, TYPE 316 I 10 1,440 EA. NUTS,)'2" A-194 , BM I 11 10 S.F. PLATE, 1" TH I CK 0-240 , TYPE 316 I ' 12 48S.F. PLATE, 1" THICK 0-240, TYPE 316 I 13 14 S.F. PLAT E , 2" THICK +-240, TYPE 316 I 14 264 EA. SUPPORT BRACKET, 6" x 5" x W TYPE 316 : : 1."1\1 WASHERS AND LOCK WASHERS AS REQUIRED <J <J .:..---(D 1" x 3" BOLT COPE ANGLE FLANGE -------_j_ ------**-L 1 .. 4 MIN. SECTION D-D (TOP AND BOlTOM) NOTES: 1. PLATES ARE STAINLESS STEEL PER ASTM A-< 2. ANGLES, BARS AND RbDS, ARE STAINLESS s* 3. BOLTING IS ASTM A-Hi3/194, GRADE B8M/8M. 4.

ARE TO BE INSH 5. ALL BOLTS ARE TO TIGHTENED 6. PRIOR ENGINEERING APPROVAL FOR CUTI IN 7. WELDED JOINTS SHALL BE MADE IN ACCORD. i i FABRICATION

1. MAXIMUM SHOP SHALL BE PROVIDE 2. DETAILS AND FABRICAT iON SHALL CONFORM T AND AISC CODE OF PRACTICE FOR SHALL BE CUT, FORMEQ , AND SHAPED TO SIZE ALLOWANCE BEING MADE FOR NORMA L BUILDI TO WORK. CUT EDGES EXPOSED IN THE FINISI SHEARED AND GROUND. SHARP OR ROUGH CC OFF, ROUNDED OR CHAMFERED SMOOTH. 3. DIMENSIONAL TOLERANCES SHALL BE IN ACCO CODE OF STANDARD PRACTICE FOR ST EEL BUI 4. BARRIER ASSEMBLIES S 1 HALL BE PREASSEMBLI COMPLIANCE WITH DRA fv iNG REQUIREMENTS.

DRAWING REFENCE;S:

WORK THIS DRAWING WITH 8770-G-644 SHEETS 6 . AFFECTED WING: 8770-G ST. LUCI OCEAN

_ _!_ ______ q __ *-----2ilEX1STING PRE CAST CONCRETE UPPER BARRIER PANEL ASSEMBLY (TRAY AND PANEL) WAFFLE PANEL TOP CONCRETE SECTION OF THE VELOCITY CAP UPPER PANEL FLOW TWO TRAY SUPPORTS FOR EACH SET OF TRAYS, LOCATE TRAY SUPPORTS TO SUIT BOLT HOLES IN TRAYS (SEE 8770-G-644 SH 7 -EC2844 1 3 SH 2 TRAY CONNECTION DETAIL) '-LOWER BARRIER PANEL ASSEMBLY (TRAY AND PANEL) EXISTING TREMIE CONCRETE BASE OF c-------:T---

---

L:.....,..--'";.

VELOCITY CAP 4 q IF TURTLE BARRIER !R PANEL ASSEMBLY -::; . <J / '---" MINIMUM 4Yo" EMBEDMENT_ . <J r--------------------, 1 I COPE ANGLE FLANGE TO ' @ 1 CLEAR SUPPORT BRACKET 0

-----.-2 1!1 '"t.. 1 /1 1

) lV 1 1'-"LL.. I \JI' I UVL 1 \ 1 I } -l;.2 I 4 14 !i..BRACKET ELEVATION VIEW I I !i. 1 X" 0 HOLE FdR 1" HKB 3 (+/-X") (TYP) 4 II I t. 21" I I 4 t--E!) -E!) -E!) -.. 4 I l--3" 3"--11" 2 9" 1' PLAN VIEW DETAIL E-SUPPORT BRACKET DETAIL ITEM 14 2 REQUIRED PER CONNECTION i AFFECTED DRA WING: 8770-G I ST. LUCI OCEAN

• .': FPL S']f. LUCIE PLANT SEA TURTLE EXCLUDER DEVICE TANK TESTING ANALYSIS Prepared for: Florida Power and Light St. Lucie Nuclear Plant Prepared by: Inwater Research Group, Inc. Jensen Beach, Florida July 2017 Test Evaluation Report Attachment 3 Page 1 of 4 IN TR ODU CTION In March of 2016, NMFS issued a revised BO requiring the design, testing, and construction of an excluder device on the offshor e intake structure to minimize the entrainment of sea turtles. In order to test the efficacy and safety of the proposed excluder device design, a test plan was developed and a test facility was built at the plant site that could duplicate the water flow conditions at the offshore intake structures.

A prototype barrier panel design was installed in the test tank, and a total of fourteen turtles of various species and size classes were selected to evaluate how they interacted with the test panel. Tiris report presents the result of that testing. Tank testing of the proposed excluder device began on December 8 , 2016 and proceeded through February 20, 2017. Testing was suspended on February 20 , 2017 when a test subject became lodged in the test panel and was unable to extricate itself. The subject had inserted its head and left front flipper through the test panel. At that point , the test water current lifted the posterior of the turtle 45 to 60 degrees so that the posterior was in contact with the bottom of the velocity cap mockup. In this position, the turtle was unable to withdraw its head or flippers from the openings and the velocity cap mockup prevented further lifting of the posterior of the turtle , which otherwise may have allowed the turtle to free itself. In brief, the turtle became "wedged" under the velocity cap mockup in an awkward position where the front flippers were trapped and the rear flippers were not in a position where they could gain any purchase on the velocity cap mockup. The turtle was removed unharmed by the test staff. ANALYSIS AND DISCUSSION Although the test plan was well conceived and successfully executed, we feel the results should be interpreted cautiously.

As a practical matter, it would be very difficult or impossible to test a sufficient number of turtles of different species, sizes, and conditions to be able to definitively state that any proposed excluder structure poses no hazard to turtles. Of particular concern are turtles in a debilitated or injured condition which may be more vulnerable than the healthy turtles tested. With the current design, there were three instances where a test subject had difficulty extricating itself from an interaction with the test panel, and it appears there were some common factors in all three instances.

In two of the instances, the subject was able to free itself. In the third instance, the observers determined the subject was unable to free itself, the turtle was manually removed from the panel, and testing was terminated.

In all three instances, the subject was a sub adult loggerhead (test number cc7 at 0841h and 1452h, and test number cc8 at 1435h) and the test panel was in the upper orientation.

In each case, the subjects inserted their head and front flipper(s) through one or more of the smaller openings in the upper half of the test panel. At that point, the current lifted the posterior of the turtle 45 to 60 degrees so that the posterior was in contact vyith the bottom of the mockup velocity cap. In this position, the turtle that failed was unable to withdraw its head or flippers from the openings and the velocity cap prevented further lifting of the posterior of the turtle, which otherwise may have allowed the turtle to free itself. In brief, the turtle became "wedged" under the velocity cap in an awkward position.

The front flippers were trapped and the rear flippers were not in a position to gain any purchase on the velocity cap to help extricate itself from the panel. The overhanging velocity cap likely played a role in the panel failure. There were similar interactions where subjects inserted head and flippers through openings near the bottom of the test panel and were flipped over by the current but did not have contact with the velocity cap. These turtle were able to extricate themselves without difficulty.

We feel that the design of the current test panel, which has openings of four different shapes and sizes, (refer to Figure 3. in the testing report) offers turtles encountering the panel a variety of mechanisms to become lodged in one or a combination of the various sized and shaped openings.

Additionally, these different openings offer a number of different ctitical dimensions.

That is an opening size that is almost, but not quite large enough to allow a turtle to pass through. Thus, the current panel design presents opp<;Jrtunities for a vatiety of different size classes of turtle to become stuck when attempting to pass through the paneL Alternative panel designs have been explored by FPL's project team and could be fabticated for additional testing .. The role of the overhanging velocity cap, common to the current panel design and any future panel designs, should also be considered.

The overhang creates a "wedge point" that contributed strongly to the test failure on February 20. When a turtle has a head and appendage(s) through an opening in the upper half of the panel, the water current tends to lift the posterior of the turtle in a partial somersault motion until the poste1ior of the turtle strikes the lower edge of the velocity cap, wedging them in a position where they are less likely to extricate themselves.

Developing an excluder panel that has geometrically identical sized openings and eliminates the 45 degree angle of the panel where it meets the velocity cap could eliminate some of the problems we saw during testing. Testing would have to be conducted on any future design changes to determine if the new configuration is reliably safe for sea turtles. We feel strongly that an additional "no action" alternative merits consideration.

The results of testing to date present an opportunity to step back and reevaluate the potential risks and benefits of an excluder structure on the offshore intakes. As discussed above, it is difficult or impossible to conduct a testing regime that will result in a design that is guaranteed to be completely safe, particularly with regard to injured or debilitated turtles that encounter the excluder.

In the most recent full year of plant operation, 10.4% (33) ofloggerhead turtles and 7.5% (12) of green turtles captured in the intake canal were determined to be in fair or poor condition due to injuries and/or debilitation.

Thus, potential impacts of any proposed excluder structure to injured or debilitated turtles are a matter of significant concern and one that we are unable to adequately test and evaluate.

The current sea turtle conservation program at the St. Lucie Power Plant has a very low rate of causal mortality (0.2% in 2016) and those mortalities and injuries are very precisely and reliably documented.

The level of surveillance in the intake canal cannot be duplicated at the offshore intak e structures, and th e concern is th at we may be trading a situatio¥ where mortality is low and very well documented for a situation where mortality is unlmown and cannot be accurately documented.

We feel the "non-action" alternative should be seriously considered, given the inherent inability to document mortalities or intervene when sick or injured turtles interact with any offshore excluder device. Efforts to reduce mortalities and injuries may be better served by evaluating and rectifying any conditions that may have harmful effects on sea turtles in the intake pipes and intake canal. Test plan evaluation During the course of implementing the test plan several methods were modified.

The surface based cameras intended to capture video of turtle interactions with the test panel did not perform as intended.

Turbulent water, surface bubbles and glare prevented the smface cameras from capturing any useful video of turtle interactions with the panel. Even after efforts to minimize surface bubbles using baffles and sprayers we we're unable to obtain any quality video. Despite the loss of the surface camera video, we still captured enough observer and underwater video data to effectively evaluate turtle interactions with the test panel. The underwater video was effective at recording turtle interactions with the test panel, but there were a few caveats. During the first hour of active testing each day the morning light would come through the observation windows and affect the underwater video quality by illuminating the bubbles in the water column. Another issue that affected video quality was bubbles that attached to the camera housing and sometimes blurred the video images. Our first attempt at using the GoPro cameras to record turtle interactions with the test panel was to put the camera in the water when a turtle approached the panel. After looking at video using this method we realized that it was difficult for the operator to attain the correct angle of the camera needed to record the turtles entire interaction with the panel. To correct this problem we put two cameras on poles and attached them to the west and east ends of the mock velocity caps. The cameras were attached to the poles during each hour of active testing and provided effective video coverage of the test panel. Using the GoPro cameras to record underwater video was effective, but getting a correct and consistent angle that provided the best coverage of the test panel was difficult.

If future testing is conducted we would recommend a fixed underwater camera connected to a surface monitor. This would provide a consistent view of the test panel and eliminate battery and angle issues that we experienced with the GoPro cameras.

Hollowell, Ed From: Sent: To: cc:

Subject:

Eaton, Kristin Wednesday, July 19, 2017 11:55 AM Hoffman, Jason; Hollowelt Ed Gless, Jodie FW: St. Lucie Excluder Device Testing From: Ben Higgins -NOAA Federal [1]

Sent: Wednesday, July 12, 2017 5:11 PM To: Gless, Jodie Cc: Eaton, Kristin

Subject:

Re: St. Lucie Excluder Device Testing CAUTION-EXTERNAL EMAIL

Dear Jodie and Kristin,

Test Evaluation Report Attachment 4 Page lof 4 I have now had a chance to review all the video. Thanks for sending the DVD, that made it much easier than the FTP site for me. If I understand the set-up correctly, the offshore intake sucks in water 360 degrees around a fixed structure.

That intake water is travelling horizontally, then makes a 90 degree turn downwards.

You are attempting to place diversionary screens on the vertical openings to the intake structures.

You have built a flume tank that mimics the horizontal flow of water across a test panel. All but one of the turtles was able to either avoid the test panel or break away from the suction. The turtles all appear to be well acclimated to the test set-up and look more comfortable than I would have envisioned, so I believe the methodology is sound and acclimation of the turtles to the test tank was successful.

The one loggerhead that could not escape from the interaction with the panel managed to get it's head and one front flipper through the panel and a combination of the turtles' actions and water pressure/suction flipped the turtle over onto it's back and into a position in which it may not have been able to escape on it's own, thus creating a "failure" of the panel. I believe the configuration of the test set-up may have created the desired suction element, but because of the directional tank walls on either side of the panel, you have also created a strong laminar flow that is not likely to be the same as an open water intalce sucking from 360 degrees. In effect, you have created something similar to the water flow within a trawl with the test panel acting like a turtle excluder device [TED]. We see strange behavior when sea turtles are introduced to current. Sea turtles will do everything in their power to not get flipped upside down. With their body shape being a perfect areodynamic/hydrodynamic foil, water flowing over their body will create lift/suction similar to an airplane wing. Airplanes, for the most part, also try not to fly upside down. It is common when testing higher angle, straight bar TEDs to have the head, front flippers and about 1/3 to 1/2 of the turtles body outside the TED opening, while the back end and rear flippers are glued to the TED which appears to the naked eye as suction. As long as there is a constant water flow over the turtle, it will not be able to escape in this configuration.

Lessening the angle of the TED helps break this suction. i.e. the further you get away from the stall angle the easier it is for the turtle to escape. Sand dollars [flat on the bottom and curved on top] that are picked up off the seafloor can stand up on edge [vertical]

along the foot rope via the same aerodynamic principal of a stall angle. 1 If yo u pl ace a logg er h ead i n to a c ir c ul ar: tank wi th a ce nt ral b o tto m dra i n and p ump in wa t er i n such a way t h a t it creates a v ort ex, th e turtle w ill even tuall y fin d a s p o t in t h e tank w h e r e it w ill ho ver mid water at an ang l e t o t he c urr en t that creat es a s t a ll i.e. th e turtl e will be s t a tion ary i n th e t a nk d es pit e the v o rt exing c urr en t. Th e fi rst few times I saw this , I thought the turtle was dead floating mid water. The turtle that failed the excluder panel test was also remarkably clean with respect to biofouling.

It is possible this turtle went though a trawl with a TED which knocked off much of the nmmal biofoling, and/or it had a rough ride through the powerplant intake which knocked off the usual barnacles, oysters and algae. It is possible this turtle was compromised physically.

Regardk s s ,.a t akeofeven.aphysically compromised turtle is still going to be considered a take.* .. I believe the failure ofthis one turtle to successfully free itself from the exCluder panel was a r e sUlt of water cha;oneling creating;an abnoimal water fl()w which flipped the turtle into a position where i t was hot able t6'recover due to hydrodynamic pressure in the time allotted, and the turtle :lmiy have been c.;pmpromisedhealthwise.

It appears the test setup works well for the most part and it would be difficult to m q cJ.jfy or build a test setup that didn't have some effect of water channeling due to* the need for tank sides and

• p pij om. I would chalk the one captUre up as atl. *a.ncnnaly. '*one way to remove that potential anomaly would be to have an exclusion grid pattern that was not large enough for a turtle to get a head and front flipper inside the grid , and get turned upside down. Regards , Ben. On Wed, May 31,2017 at 6:57PM, Gless, Jodie <Jodie.Gless@fpl.com>

wrote: Charlie , Ben and John , Thank you for agreeing to review and comment on the information related to our St. Lucie excluder device. National Marine Fisheries Service (NMFS) issued a Biological Opinion in March 2016 that requires the St. Lucie Plant (PSL) to install barriers at the Ocean Intake Velocity Caps. This consultation between the Nuclear Regulatory Commission (NRC) and the NMFS was originally initiated in 2006 and amended in 2007 as a result of: 1) A non-lethal take of a smalltooth sawfish in May 2005 2) A take of21loggerhead hatchlings , due to an undetected , yet successful , sea turtle nest deposited on the intake canal bank in October 2006. The proposed configuration of the turtle barrier and subsequent testing has been coordinated with the regulating , agencies (NMFS, FWC and NRC). A test tank facility built specifically for evaluating turtle interaction with a typical barrier cross section was constructed. The test plan included testing 10 loggerhead turtles and 4 green turtles of various size classes. The revised test plan and photos of the test facility are attached to this email. Barrier testing was started on 12/8/16. Nine separate turtles were successfully exposed to the barrier without a failure. During testing of the barrier with the tenth turtle, the turtle appeared to become wedged between the barrier and the mock velocity cap structure.

The turtle was unable to get free on its own. The test was suspended 2

and the turtl e was freed from the b arr i er w ithout injury. The t es tin g was sub seq u e ntly t ermina ted at th e re quest of the regulatory ag e nci es. We are requesting that you review the following information and provide your expert opinions.

Task 1-Review revised test plan (attached)

By reviewing the revised test plan, provide expert opinion on whether there were flaws in the test tank configuration and/or procedure that contributed to the test failure. Task 2-Review turtle excluder test report (attached)

After reviewing the report and the links with the video footage, provide expert opinion on any flaws in the Panel design that contributed to the test failure. In addition, provide expert opinion on whether the location of the barrier in reference to the velocity cap contributed to the test failure. Task 3 -Provide expert opinion on the use of an excluder device at the PSL velocity cap If the protocol, design and/or location contributed to the failure, please provide any recommendations that can be used to enhance the protocol and/or reduce risk to turtle injury or death. This can include your expert opinion on the benefits provided by Inwater Research Group (IRG) vs. the risks involved with installing a barrier. IRG is compiling all of the raw data and extra footage. Once I receive any additional information from them, I will share it with you. If you have ANY questions, please feel free to give me a call or send me an email. Once we get all of the information to you, I will schedule a follow up call with you and Inwater Research Group to clear up any questions that you may have and to get your initial thoughts.

Thank you again for taldng the time to review the documents!

Jodie Jodie Gless I Manager, Environmental Services I NextEra Energy Wildlife Florida Power & Light Company, 700 Universe Boulevard, Juno Beach, FL. 33408 T: 561.691.28011 M: 561.358.03741 jodie.gless@fpl.com 3

Ben Higgins Sea Turtle Program Manager NOAA!NMFS/Galveston Laboratory 4700AveU Galveston, Texas 77551 tel. office. 409-766-3671 tel. cell. 409-771-2893 ben.higgins@noaa.

gov 4 Test Evalua t ion Report Attachment 5 Page 1 of 1 lb GGERHE ill 1 4 2 00 U.S. Hi g hw a y On e Juno Be a ch , Fl or ida 3340 8 561.6 2 7.8280

• Fx: 561.6 2 7.8305 www.marinelife.org MARINELIFE CENTER Board of Directors Raymond E. Graziotto Chair Brtan K. Waxman Vice Chair Robert Chlebek Treasurer Ann Miller Secretary Roger Amidon Bruce A Beal Thomas Bean John D. Courls JodleGless Gordon Gray Roe Green Carrie Hanna Dawn Hoffman Todd Hutchison Dan Jennings Susan Johnson Thomas Kodadel< Kim Edward Koger, M.D. Leanna Landsmann Bart Livolsi Ed Lunsford Karen Marcus James F. Mullen IV, CPA . Morgan R. Poncy, M.D. M.J. Saunders, Ph.D. Tam! Shull Robert Weisman Lynne Wells Diana Wilkin Jeanette INyneken, Ph.D. Emeritus Members Nancy DIMarco, D.V.M. Frank W. Harris Morris G. "Skip" Miller , Esq. Gall Nelson Emmy S. Rayne President

& CEO Jack E. Lighton ;........-

• • • • r>'t 1 CHARITY NAVIGATOR

-, FourSi a rCh o rlly June 25, 2017 To Whom It May Concern, Re: Review of St. Lucie Power Plant Excluder Device Testing I have reviewed the following documents provided by

1. Testing a Fixed BatTier Device with Live Sea Turtles; Revised Turtle Tank Testing Dated 7/21116 2. Florida Power and Light St. Lucie Power Plant Sea Tuttle Excluder Device Preliminary Tank Testing Report May 2017 I was asked to provide an expert opinion on "whether there were flaws in the test tank configuration and/or procedure that contributed to the test failure," "on any flaws in the Panel design that contributed to the test failure," "whether the location of the barrier in reference to the velocity cap contributed to the test failure," and "provide any recommendations that can be used to enhance the protocol and/or reduce risk of turtle injury or death." It is my opinion that the revisions that were made to the testing protocol were appropriate and there were no flaws in the test tank configuration and no flaws in the procedure that contributed to the test failure. During the testing, the turtle that failed had body parts wedged between the top of the panel and the bottom of the cap. Even if this space could be eliminated, there are other narrow gaps within the panel in which turtle appendages could become entrapped, especially with weaker individuals.

While I am not an engineer, I cannot a design that would eliminate such issues, so I do .riot feel that a flaw in the panel design contributed to the test failure. It is also my opillion that the location of the banier with respect to the velocity cap did not contribute to the test failure. Finally, given that the testing was done with no r mal, healthy turtles which couLd p.ot escapej , j td s c fu: J'i'O piftioidhiit' installation

'ofthe

• excl ude fOn;tlie 'powe r**'P.Hilit *caps*w ill ;;r esiil t d n*the'eritrapmerit arid drowning'bfsome or all ofthe utiliealthy i tt.frtles'thathbw are being

.the intake canaL It is my opinion that installation of the excluder would increase the number of sea turtle deaths attributed to the power plant (increased take) and therefore should be avoided. The current situation using Inwater Research Group should be maintained instead.

Charles A. Manire, D.V.M. Director of Research and Rehabilitation

'I Jodie Gless, Manager, Environmental Services NextEra Energy Wildlife Florida Power & Light Company 700 Universe Boulevard, Juno Beach, FL 33408

Dear Jodie,

UNITED STATES DEPARTMEN T OF COMMERCE N at i o nal O c e anic and Atm o spheric Adm i nistra tio n National Marine Fisheries S ervice Southeast Fisheries Science Center Mississippi Laboratories P.O. Drawer 1207 Pascagoula, MS 39568-1207 July 14,2017 Test Eval uation Report Attachment 6 Page 3 of3 Thank you for the opportunity to review the tests of the proposed turtle excluder barrier for the St. Lucie Plant ocean intake velocity caps. The video clips of the tests were most helpful in understanding how the excluder panel design might work in a real world situation.

Assisting me in the review of the tests and associated documentation was Kendall Falana. Mr. Falana is the lead fisheries methods and equipment specialist for the NOAA Fisheries Harvesting Systems Unit and has extensive experience in the design and testing of turtle excluder devices for the shrimp fishery. Our review has been separated into three subjects as you have requested. Review revised test plan

• Overall we felt the revised test plan was an appropriate method of conducting a controlled evaluation of sea turtle interaction with the excluder panel. However, the test does not appear to allow turtles to maneuver over the top of the panel and thus make an escape from suction as they might in actual field conditions.

• The current test set-up forces the turtle to continually interact with the panel and thus did not reflect any possible interaction

-escapement over the top of the panel. In the video clips, the turtles did a lot of exploration of the panel, some of which may have resulted in escapement over the top of the velocity cap had there been a clear space above. In my work, this would be analogous to testing a shrimp trawl turtle excluder device and tying the escape hole shut. You would be testing the efficacy of the TED frame in preventing turtles from going through the deflector bars (and thus becoming captured in the trawl bag), but you would not be evaluating how it might make it's escape out of the TED opening as the device is designed to do.

• While the above may be an intentional test set-up intended to maximize turtle interaction time with the panel, it might be helpful to conduct some trials with an unobstructed space above the panel to observe how turtles will maneuver over the top of the panel and escape suction.

• The single failed test (turtle capture) might have been prevented had there been a clear space above the panel.

• The sample size and pass/fail criteria for evaluating the tank test and excluder panel efficacy were described adequately and seem appropriate.

j Review turtle excluder test

• The test report was helpful and provided good detail on each turtle exposure to the excluder panel.

• For each individual test/exposure , it would have been helpful to have tabulated

total time on excluder panel"; basically the sum of the time each turtle spent moving around or interacting with the panel. Provide expert opinion on the use of an excluder device at the PSL velocity cap Diamond Mesh configuration and spacing of excluder panel bars

• Minimizing the time a turtle spends interacting with the panel is key to facilitating their escape. The diamond pattern and spacing of the YS.-inch rod of the excluder panel bars appears to allow the flippers and heads of turtles to pass through the pand easily, thus slowing their movement across the panel and potentially swimming free from it. Our recommendation would be to use vertical bars spaced closer together.

• Vertical bar spacing would need to be determined based on the desired size of turtle to be excluded.

Based on the size of the turtles in the tests which were conducted, we feel that 10-inch vertical bar spacing would be effective.

• Vertical bars could be reinforced with horizontal bracing, insuring that no part of the horizontal brace protrudes beyond the face excluder panel which might hinder turtle movement.

Vertical bars could be constructed from '!.!-inch flat bar to help minimize the surface area of the excluder panel. Inverted Clower) section of excluder panel

• The inverted lower section of the excluder panel appears problematic in that it essentially guides the turtle to the sea floor, almost forcing an interaction with the panel. This part of the panel configuration can result in one of two behavioral outcomes; forcing the turtle to become inverted as it tries to climb upward, keeping it's plastron in contact with the excluder panel (unnatural .for a turtle and resulting in more time on the panel) or; forcing the turtle to the bottom of the panel where it is more likely to attempt to maneuver through it (illustrated in video clip "CC through panel).

• We again would recommend that an excluder panel configured with parallel, vertical c bars i continlJPUS from , the top ofthe velocity cap tO the sea floor as a more 'effective

'designt6frilrtle exclusion.

, The angle of the vertical bars should be no greater than 45 degrees (the lower angle, the better).

Moving excluder panel away from the velocity cap

• We considered the following statement made in the revised test plan document; "At the offthore velocity cap structures turtles would only experience sustained flow rates of 1 'per second for a short period of time when they physically interacted with the barrier system. " Presuinably the flow rate diminishes considerably as one moves further away for the velocity cap. In order to minimize the suction experienced by turtles, we that

• featill'e s the'angJ_ed, vertical bar cohl:igurati6ri described above with the panel base 10 to *15 feet awa)i'fromf he" base of the vdciCity Cap. This design might permit turtles to move freely along and around the base and eventually away from the structure.

Please do not hesitate to contact me if may provide additional information.

Sincerely, John Mitchell, Unit Supervisor Harvesting Systems and Engineering Division Cc; Harriet Nash, NMFS/OPR/ESAICD Audra Livergood, NMFS/SER/SERO/PRD/ESB ST9x35 112"l1J U-80LT, ONE END BENT, DNE END LOCK WASHER&NUT 16' VELOCITY CAPS INTERIOR AND EXTERIOR COLUMNS DlA.(TYP.)

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A tt achment 8-Li st of Pub l icat i ons Test Eval u ation Report Attac h ment 8 Page 1 of 6 Publications in scienti f ic journals using sea turtle da t a from the St. Lucie P o wer Plant: Bjorndal, K. A., Schroeder, B. A., Foley, A. M., Witherington, B. E., Bresette, M., Clark, D., ... Meylan, P. A. {2013). Temporal, spatial, and body size effects on growth rates of loggerhead sea turtles (Caretta caretta) in the Northwest Atlantic. Marine biology, 160(10), 2711-2721.

Kaplan, A. J., Stacy, N. 1., Jacobson, E., Le-Bert, C. R., Nollens, H. H., Origgi, F. C., ... Hernandez, J. A. {2015). Development and validation of a competitive enzyme-linked immunosorbent assay for the measurement of total plasma immunoglobulins in healthy loggerhead sea (Caretta caretta) and green turtles (Chelonia mydas). Journal of Veterinary Diagnostic Investigation, 1040638715617804. Goshe, L. R., Avens, L., Scharf, F. S., & Southwood, A. L. (2010). Estimation of age at maturation and growth of Atlantic green turtles (Chelonia mydas) using skeletochronology. Marine Biology , 157(8), 1725-1740. Kubis, S., Chaloupka, M., Ehrhart, L., & Bresette, M. (2009). Growth rates of juvenile green turtles, Chelonia mydas, from three ecologically distinct foraging habitats along the east central coast of Florida, USA. Mar Ecol Prog Ser, 389, 257-269. McGOWIN, A. E., Truong, T. M., Corbett, A.M., Bagley , D. A., Ehrhart, L. M., Bresette, M. J., ... Clark, D. (2011). Genetic barcoding of marine leeches (Ozobranchus spp.) from Florida sea turtles and their divergence in host specificity.

Molecular ecology resources, 11(2), 271-278. Osborne, A. G., Jacobson, E. R., Bresette , M. J., Singewald, D. A., Scarpino, R. A., & Bolten , A. B. (2010). Reference intervals and relationships between health status, carapace length , body mass, and water temperature and concentrations of plasma total protein and protein electrophoretogram fractions in Atlantic loggerhead sea turtles and green turtles. Journal of the Ame r ican Veterinary Medical Association , 237(5), 561-567. Witherington, B., Kubilis, P., Brost , B., & Meylan, A. (2009). Decreasing annual nest counts in a globally important loggerhead sea turtle population.

Ecological Applications, 19(1), 30-54. Atkins , A., Jacobson, E., Hernandez, J., Bolten, A. B., & Lu, X. (2010). Use of a portable care (Vetscan VS2) biochemical analyzer for measur i ng plasma biochemical levels in free-living loggerhead sea turtles (Caretta caretta).

Journal of Zoo and Wildlife Medicine, 41(4), 585-593. Foley, A.M., Schroeder, B. A., Redlow, A. E., Fick-Child, K. J., & Teas , W. G. (2005). Fibropapillomatosis in st r anded green turtles (Chelonia mydas) from the eastern United States (1980-98):

trends and associations with environmental factors. Journal of Wildlife Diseases, 41(1), 29-41.

Witherington, B., Herren, R., & Bresette, M. {2006}. Caretta caretta-loggerhead sea turtle. Chelonian Research Monographs, 3, 74-89. Witherington B, Bresette M, Herren R {2006} Chelonia mydas-green turtle. Chelonian Research Monographs 3:90-104 Witzelt W. N., Bass, A. L., Bresette, M. J., Singewald, D. A., & Gorham, J. C. {2002}. Origin of immature loggerhead sea turtles (Caretta caretta) at Hutchinson Island, Florida: evidence from mtDNA markers. Fishery Bulletin, 100(3L 624-631. Bresette, M., Gorham, J., & Peery, B. {1998}. Site fidelity and size frequencies of juvenile green turtles (Chelonia mydas) utilizing near shore reefs in St. Lucie County, Florida. Marine Turtle Newsletter, 82{5}. Bresette, M., & Gorham, J. {2001}. Growth rates of juvenile green turtles (Chelonia mydas) from the Atlantic coastal waters of St. Lucie County, Florida, USA. Marine Turtle Newsletter, 91, 5-6. Bresette, M. J., Foley, A.M., Singewald, D. A., Singe!, K. E., Herren, R. M., & Redlow, A. E. {2003}. The first report of oral tumors associated with fibropapillomatosis in Florida, USA. Marine Turtle Newsletter, 101, 21-23. Frick, M.G., Williams, K. L., Bresette, M., Singewald, D. A., & Herren, R. M. {2006}. On the occurrence of Columbus crabs (Planes minutus) from loggerhead turtles in Florida, USA. Mar Turt News/, 114, 12-14. Keller, J. M., Alava, J. J., Aleksa, K., Young, B., & Kucklick, J. R. {2005}. Spatial trends of polybrominated diphenyl ethers {PBDEs} in loggerhead sea turtle eggs and plasma. Organohalogen Compounds, 67, 610-611. Alava, J. J., Keller, J. M., Kucklick, J. R., Wyneken, J., Crowder, L., & Scott, G. I. {2006}. Loggerhead sea turtle (Caretta caretta) egg yolk concentrations of persistent organic pollutants and lipid increase during the last stage of embryonic development.

Science of the total environment, 367(1L 170-181. Bass, A. L., & Witzelt W. N. {2000}. Demographic composition of immature green turtles (Chelonia mydas) from the east central Florida coast: evidence from mtDNA markers. Herpetologica, 357-367. Proffitt, C. E., Martin, R. E., Ernest, R. G., Graunke, B. J., LeCroy, S. E., Muldoon, K. A., ... Williams-Walls, N. {1986}. Effects of power plant construction and operation on the nesting of the loggerhead sea turtle (Caretta caretta):

1971-84. Copeia, 1986(3L 813-816.

Wibbels, T., Mar t in, R. E., Owens, D. W., & Amoss Jr, M.S. {1991). Female-biased sex ratio of immature loggerhead sea turtles inhabiting the Atlantic coastal waters of Florida. Canadian Journal of Zoology, 69(12), 2973-2977.

Williams-Walls, N., O'Hara, J., Gallagher, R. M., Worth, D. F., Peery, B. D., & Wilcox, J. R. {1983). Spatial and temporal trends of sea turtle nesting on Hutchinson Island, Florida, 1971-1979.

Bulletin of Marine Science, 33(1), 55-66. O'Hara, J., & Wilcox, J. R. {1990). Avoidance responses of loggerhead turtles, Caretta caretta, to low frequency sound. Copeia, 1990(2), 564-567. National Marine Fisheries Service and US Fish and Wildlife Service. 1991. Recovery Plan for U.S. Population of Atlantic Green Turtle. National Marine Fisheries Service. 2008 Recovery Plan for the Northwest Atlantic Population of the Loggerhead Sea Turtle {Caretta caretta) Eaton, C., McMichael, E., Witherington, B., Foley, A., Hardy, R., & Meylan, A. {2008). In-water sea turtle monitoring and research in Florida: review and recommendations. Florida Fish and Wildlife Conservation Commission, Fish and Wildlife Research Institute.

Wyneken, J., & Witherington, D. (2001). The anatomy of sea turtles {Vol. 470). Southeast Fisheries Science Center, National Marine Fisheries Service, National Oceanic and Atmospheric Administration, US Department of Commerce.

Presentations at meetings and symposia using sea turtle data from the St. Lucie Plant: Norton, T., Keller, J.M., Peden-Keller, M., Day, R.D., Stedman, N., Segars, A., ... Schroeder, B. (2004). Debilitated loggerhead turtle {Caretta caretta) syndrome along the southeastern US coast: incidence, pathogenesis, and monitoring.

Proceedings of the American Association of Zoo Veterinarians, American Association of Wildlife Veterinarians, and Wildlife Disease Association.

Edited by CK Baer, 91-93. Clark D.R., Mott C.R., Weege S.T., Guertin J., Gomas J.A., Bresette M.J. {2012) Characterization of sea turtles in the southern Indian River Lagoon. Abstracts, Indian River Lagoon Symposium 2012, Fort Pierce, Florida, February 9, 2012 p7. Bresette, M. J., Herren, R. M., Singewald, D. A. Sea turtle captures at the St. Lucie nuclear power plant: a 25-year synopsis.

Proceedings ofthe Twenty-Second Annual Symposium on Sea Turtle Biology and Conservation. NOAA Technical Memorandum NMFS-SEFSC-503, 308 pp.; 2003, p. 46 Bresette, M. J., Herren, R. M., Singewald, D. A. Comparison offibropapilloma rates of green tur t les {Chelonia myd a s) f r o m two diffe r en t si t e s in St. Lucie County, Flo ri d a Bresette, M. J., Herren, R. M., Singewald, D. A. Proceedings of the Twenty-First Annual Symposium on Sea Turtle Biology and Conservation. NOAA Technical Memorandum SEFSC-528.

368 pp.; 2004, p. 125-126 Bresette, M. J., Singewald, D., De Maye, E. Recruitment of post-pelagic green turtles {Chelonia mydas) to nearshore reefs on Florida's east coast. 26th Annual Symposium on Sea Turtle Biology and Conservation. International Sea Turtle Society, Athens, Greece. 376 pp. 2006, p.288 Gorham, J., Bresette, M. Bias-free estimates of measurement error in sea turtle morphometric data collection. Proceedings of the Nineteenth Annual Symposium on Sea Turtle Biology and Conservation. U.S. Dept. Commerce.

NOAA Tech. Memo. NMFS-SEFSC-443.

291 pp.; 2000, p. 178-179 Wilcox, J. R., Bouska, G., Gorham, J., Peery, B., & Bresette , M. {1998). Knee deep in green turtles: recent trends in capture rates at the St. Lucie Nuclear Power Plant. Proceedings ofthe sixteenth annual symposium on sea turtle biology and conservation. NOAA Tech. Memo. SEFSC-412.

Gorham, J. C., Bresette, M. J., Peery, B. D. Comparative tag retention rates for two styles of flipper tags. Proceedings of the Seventeenth Annual Sea Turtle Symposium.

U.S. Dep. Cammer. NOAA Tech Memo. NMFS-SEFSC-415.

294 pp.; 1998, p. 179-182 Gorham, J. C., Bresette, M. J., Peery, B. D. Bias-free estimates of measurement error in sea turtle morphometric data collection.

Proceedings of the Eighteenth International Sea Turtle Symposium. U.S. Dept. of Commerce.

NOAA Technical Memorandum NMFS-SEFSC-436, 293 pp.; 2000, p. 164 Herren, R. M., Bresette, M. J., Singewald, D. A. Loggerhead

{Caretta caretta) growth rates from nearshore Atlantic waters. Proceedings of the Twenty-First Annual Symposium on Sea Turtle Biology and Conservation.

NOAA Technical Memorandum NMFS-SEFSC-528. 368 pp.; 2004, p. 186-187 Singewald, D. A., Herren, R. M., Bresette, M. J. Assessment of loggerhead

{Caretta caretta) reproductive success on Hutchinson Island, Florida; Summer 2000. Proceedings ofthe First Annual Symposium on Sea Turtle Biology and Conservation.

NOAA Technical Memorandum NMFS-SEFSC-528.

368 pp.; 2004, p. 329-330 Holloway-Adkins, K. G., Bresette, M. J., Ehrhart, L. M. Juvenile green turtles ofthe sabellariid worm reef. Proceedings of the Twenty-Third Annual Symposium on Sea Turtle Biology and Conservation.

NOAA Technical Memorandum NMFS-SEFSC-536.

261 pp.; 2006, p. 259 Scarpino, R. A., Bresette, M., Singewald, D., DeMaye, E. Post-c apture movements of logge r head and green turtles from Florida's southeast coast using tag return data. Proceedings of the 27th Annual Symposium on Sea Turtle Biology and Conservation.

NOAA Technical Memorandum NMFS-SEFSC-569, 262 pp. 2008, p.58-59. Broadstone, M., Witherington, B., Gorham, J., Bresette, M., Ehrhart, L., Bagley, D., Kubis, S., Herren, R. Abundance and distribution of green turtles within shallow, hard-bottom foraging habitat adjacent to a Florida nesting beach. Proceedings of the Twenty-Second Annual Symposium on Sea Turtle Biology and Conservation.

NOAA Technical Memorandum SEFSC-503, 308 pp.; 2003, p. 242 Bagley, D. A., Kubis, S. A., Bresette, M. J., Ehrhart, L. M. Satellite tracking juvenile green turtles from Florida's east coast: the missing size classes found. Proceedings of the 27th Annual Symposium on Sea Turtle Biology and Conservation.

NOAA Technical Memorandum NMFSSEFSC-569, 262 pp. 2008, p.37 Estes, J., Wibbels, T., Tucker, T., Wyneken, J., Ehrhart, L. M., Carthy, R., Martin, R. E., Ernest, R., Bresette, M., Johnson, C., Ball, B., Schmid, J., Phillips, J., Dawsey, S., Drye, B., Watson, K. Evaluation of loggerhead nesting beach temperatures throughout the southeastern United States. Proceedings of the Twenty-eighth Annual Symposium on Sea Turtle Biology and Conservation.

NOAA Technical Memorandum NOAA-NMFS-SEFSC-602. 272 pp. 2010, p.81 Masters and doctoral thesis using sea turtle data from the St. Lucie Plant: Myre, Brianna Lynn. Ovarian dynamics in free-ranging loggerhead sea turtles (Caretta caretta).

Master's Dissertation.

Southeastern Louisiana University, 2015. Sterner, A. T. Modeling Survival of Immature Loggerheads

{Caretta caretta) and Green Turtles {Chelonia mydas) from 10 Years of Mark-recapture Data at the Florida Power and Light St. Lucie Plant. Doctoral dissertation, University of Central Florida, 2013. Sanchez, C. L. Sex ratios of juvenile green turtles {Chelonia mydas) in three developmental habitats along the east coast of Florida. Doctoral dissertation, University of Central Florida, 2013. Vaughan, J. R. Evaluation of length distributions and growth variance to improve assessment of the loggerhead sea turtle {Caretta caretta).

Master's dissertation, Oregon State University, 2009. Guzman, A. Bite performance and feeding kinematics in loggerhead turtles {Caretta caretta) within the context of longline fishery interactions.

Doctoral dissertation, Texas A&M University, 2008.

Sh a mbli n , Br i an Mi c hael. Population s t r uctu re of loggerhead sea t ur t l e s {Care tta car e tta) nesting in the southeastern United States inferred from mitochondrial DNA sequences and microsatellite loci. Master's dissertation, University of Georgia, 2007. Norem, A. D. Injury assessment of sea turtles utilizing the neritic zone of the southeastern United States. Doctoral dissertation, University of Florida, 2005. Bagley , D. A. Characterizing juvenile green turtles,(Chelonia mydas}, from three east central Florida developmental habitats.

University of Central Florida , 2003. Holloway-Adkins, K. G. (2001}. A comparative study of the feeding ecology of Chelonia mydas {Green Turtle) and the incidental ingestion of Prorocentrum spp. Master's thesis, University of Central Florida, 2001. Owens, D. W., Morris, Y. A., & Amoss, M.S. Sexing techniques and sex ratios for immature loggerhead sea turtles captured along the Atlantic coast of the United States (pp. 65-74}. Texas A & M University, Sea Grant College Program, 1987.

( Stacy Foster Florida Power & Light Company Environmental Services 700 Universe Blvd. Juno Beach, FL 33408 Shelley Norton National Marine Fisheries Service 263 13th Avenue South St. Petersburg, FL 33701 Test Evaluation Report Attachment 9 Page 1 of2

SUMMARY

OF APRIL 17-18, 2007 MEETING REGARDING FORMAL CONSULTATION UNDER SECTION 7 OF THE ENDANGERED SPECIES ACT REGARDING OPERATION OF THE ST. LUCIE NUCLEAR POWER PLANT (TAC NOS. MD4260 AND MD4261)

Dear Ms. Foster and Ms. Norton:

Under Section 7 of the Endangered Species Act, the U.S. Nuclear Regulatory Commission (NRC) reinitiated formal consultation with the National Marine Fisheries Service (NMFS) regarding the continued operation of the St. Lucie Nuclear Power Plant (SLNPP), after the incidental take limit for sea turtles was exceeded in 2006. At that time, NRC and NMFS were already in consultation regarding the capture of a smalltooth sawfish (Pristis pectinata) at SLNPP, and the agencies agreed that the consultations could be combined for a comprehensive biological opinion addressing sea turtles and the smalltooth sawfish. On April 17-18, 2007, representatives of the NRC, NMFS, and Florida Power & Light Company (FPL) met to observe the inspection of the southern 12-ft-diameter intake pipe and discuss possible mitigation measures to reduce impingement and entrainment of protected marine species, specifically sea turtles and smalltooth sawfish, into the SLNPP intake canal. As a result of the October 2006 loggerhead turtle (Caretta caretta) hatchling impingements at the intake wells, NRC, NMFS, and FPL discussed potential mitigation measures.

NRC and NMFS suggested that FPL remove the existing vegetation east of the 5" turtle net and add some form of material that a turtle crawl will be visible in, as soon as possible.

NRC and NMFS suggested that this prudent measure should be implemented as soon as possible since the 2007 sea turtle nesting season has already begun. During the April 2007 outage at SLNPP, FPL inspected the intake and discharge pipes. Inspection results are expected to identify the amount and location of any significant biofouling and debris accumulation that extend into the flow path of the intake pipes. NRC and NMFS suggested that FPL develop an implementation plan based on the pipe inspection report for cleaning the intake pipes during the fall 2007 outage, to remove protruding debris that may adversely affect animals entrained in the intake canal. NRC and NMFS suggested that FPL should coordinate and obtain concurrence of the implementation plan from the NRC and NMFS prior to implementation.

NRC and NMFS believe that removal of significant biofouling and debris could reduce adverse effects on animals entrained into the intake canal. The exploration of the intake pipes also revealed a dead-end section in each 12-ft-diameter intake pipe. A live green turtle (Chelonia mydas) was discovered in the dead-end section of the

( / (! \ southern 12-ft-diameter intake pipe. The NRC , NMFS, and FPL observed the turtle breathe from an air pocket in the dead-end pipe section. FPL was able to blow air into that section so the turtle could continue breathing f rom the pocket overnight.

It is expected that the turtle would enter the intake canal when full flow was restored in the pipe. This event, however, revealed the potential for animals to be trapped in this section, and since it has no functional purpose , NRC and NMFS suggested that FPL seal off the dead-end sections of the 12-ft-diameter intake pipes during the fall 2007 outage. To reduce the potential for incidental takes in 2007, NRC and NMFS suggest that FPL should employ several mitigation measures:

remove existing vegetation and add some material that a crawl would be visible in, remove protruding debris in the intake pipes , and seal off the end sections of the intake pipes. In addition, the agencies suggested that FPL should develop a plan to install excluder devices at the velocity caps to prevent large marine organisms , such as adult sea turtles and smalltooth sawfish, from entering the intake pipes. NRC and NMFS observed that the design and i nstallation of such devices would likely be a longer-term project, but suggested to FPL that this project should be done as soon as possible, with a proposed implementation plan to be provided for this project no later than September 30, 2007. Finally , NRC arid NMFS suggested that if FPL conducts any dredging, bank restoration, or other similar activities within the intake canal, FPL should work with NRC and NMFS to identify appropriate mitigation measures to ensure the safety of any marine organisms that might be affected.

NRC should submit to NMFS a biological assessment regarding sea turtles and foreseeable future activities at SLNPP that may affect protected marine species. NRC and NMFS suggested that after receiving the final pipe inspection report, FPL should submit to NRC any new or updated information, including an updated description of the cooling system if necessary, for inclusion in the biological assessment for sea turtles. At the meeting, several changes were suggested to FPL's smalltooth sawfish handling, transportation, and release protocol; FPL should send the revised document to NRC and NMFS for approval.

Also, the NRC and NMFS agreed that FPL should continue communicating with both agencies regarding the design and implementation of any mitigation measures and projects that could affect protected marine species. FPL agreed to take the NRC and NMFS suggestions under advisement.

The parties agreed that all proposed recommendations would be discussed further among the parties prior to issuance of a final biological opinion. If there are any questions regarding this meeting summary or the recommendations described, please contact Ms. Elizabeth Wexler at EMW1@nrc:gov or 301-415-1522.

Docket Nos. 50-335 and 50-389 cc: See next page Sincerely , Harriet Nash, Environmental Scientist Environmental Branch A Division of License Renewal Office of Nuclear Reactor Regulation Underwater Engineering Services, Inc. Mr. Jason Hoffman FPL St. Lucie Nuclear Generating Station 6501 S Ocean Drive Jensen Beach, Fl. 34957 August 1, 2016 Test Evaluation Report Attachment 10 Page 1 of 5 Re: Request for Budgetary Cost Estimate for Installation of Turtle Exclude*rs/Barriers at FPL St. Lucie Nuclear Power Plant two (2} 12' and one (1} 16' Velocity Caps Mr. Hoffman, Underwater Engineering Services, Inc. {UESI) is pleased to provide the following Budgetary Cost Estimate to provide diving services to fabricate and install the turtle excluders/barriers on the two {2) 12' and one {1) 16' Velocity Caps at FPL/St. Lucie Nuclear Power Plant. Also included in this Budgetary Cost Estimate {as requested) is pricing for an additional ninety {90) turtle excluder/barrier panels and diving services budgetary cost estimate to remove ninety {90) turtle excluders/barriers panels annually and reinstall with new panels for annual planned maintenance.

UESI has based this budgetary cost estimate on a schedule from the 2010 Ocean Intake Pipe Cleaning, Ocean Intake Velocity Cap Concrete Removat Installation of Flow Monitoring Device and Installation of Marine Exclusion Devices project {FPL Purchase Order No. 00129004) that was performed in 2010 by UESI. All project scopes were complete with the exception of the installation of marine exclusion devices. The budget estimate assumes the vendor would provide all supervision, labor, equipment, Lift boat and turtle excluder material and fabrication for the installation of the Turtle excluders and support framing. CONCEPTUAL WORK PLAN The budget estimate is based on the following work plan assumptions. P age I o f5 I Mobilization to North and South 12' Velocity Caps The budget estimate assumes the vendor will utilize a seven (7) person dive team for this operation, consisting of one (1) Project Manager (Oversite), One (1) Dive Master, three (3) Divers, and two (2) Tenders. A project manager would be stationed on the land side working with the FPL representative for scheduling, trouble shooting, cost saving analysis, coordinating equipment and material deliveries, etc. Having a PM in place will eliminate any wasted time offshore. The land based PM will be in a position to anticipate potential problems and work with the offshore crew and FPL representative to eliminate or minimize schedule and cost impacts. The Lift boat "M/V" would be staged at the Ft. Pierce inlet. The Ft. Pierce terminal will be used to load out equipment, stock food and for fueling. The vendor will conduct a comprehensive pre-job planning and project readiness meeting ("Project Kick-off Meeting")

with all Parties associated with this phase of the 12' Velocity Cap Turtle Excluder Installation before any work has started .. Work crews will conduct a daily pre-job briefing and safety meeting to discuss relevant safety , operating experience, work task specifics, human performance measures, etc. throughout the duration of the project. With specific regards to mobilization efforts, work crews will break off into their work order task groups (after daily briefings/meetings) for the day to commence their mobilization task onto the Lift boat. The budget estimate assumes the vendor is able to stage land based resources near the Port of Ft. Pierce. Jack hammers , air compresso r s , concrete saws, chains, bars, extra dive equipment, etc., should be strategically located to facilitate delivery as needed to prevent production delays. UESI assumes a work vessel such as the 30' offshore work boat, "Troubleshooter", would be used to provide support as necessary to the Lift boat. The work boat will be utilized for retrieving the crew at the end of the work day on Saturdays and returning the crew to the Lift boat on Monday mornings.

The work boat shall be launched at the Ft. Pierce inlet boat launch, so taxiing and removal will begin and end there. UESI has also budgeted the cost for a 100' work vessel to resupply fuel, water, and food to the Lift boat every two (2) weeks. Installation of North and South 12' Velocity Cap Turtle E x cluders While a (3) man crew is staging equipment at the Ft. Pierce Port Term i nal, a (4) man dive team will utilize the work vessel "Troubleshooter", to make a dive on the 12' velocity cap. The Lift boat charter requires that a bottom survey be performed and GPS readings taken or buoys set on Page 2 of 5 I location to identify were the Lift boat will be staged. This process will be necessary each time the Lift boat is relocated to ensure that the Lift boat and FPL property will not be damaged. Upon the completion of staging of equipment onto Lift boat, the vendor will direct and assist the Lift boat (M/V) to the project site location.

Initially this will take approximately

3.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />s

from port to the location of the 12' Velocity cap. This is dependent on the existing sea conditions.

The overall transit and entire Jack up process on location at the 12' Velocity Cap is anticipated to take 5 to 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. It is UESI's assumption that work crews will live aboard the Lift boat in order to facilitate schedule adherence and maintain work operational readiness at all times. Once the Lift boat is in position over atop of the 12' intake velocity cap, the dive crew will utili z e a six (6) person certified dive team consisting of one (1) Dive Master , three (3) divers and two (2) tenders. A light weight template will be used to identify locations for the turtle excluder bracket mounting holes. This template will be utilized to assist in drilling into the concrete floor and ceiling. If the concrete floor needs to be adjusted for turtle barrier fit-up, divers will utilize a 30 lbs. hydraulic jack hammer with a chisel bit. Divers will then measure and mark distances on the concrete floor per the specification.

Once measurements are verified to be accurate for placement of barrier bracket bracing, place the light weight template on the floor. Divers will use this as a guide to assist in drilling the holes to specifications.

Divers will only drill one side at a time to insure that the barrier support bolt hole pattern will not be misaligned.

Once measurements are confirmed, two divers will start the drilling process. Divers will utilize a hydraulic hammer drill. The drill will have a stop drill attachment adjusted at 6" depth to assure accurate concrete penetration for bolt installation.

It is important not to over-drill or under-drill. The diver will use a go-no-go gage to verify that the depth anchor bolt holes meet specifications.

A certified rigger and crane operator will utilize the Lift boat crane to lower barrier support brackets to diver. At no time shall divers be around live loads except to assist in positioning.

Once a barrier support bracket is positioned close to the velocity cap window, the crane operator will stop and secure crane. The dive master will then notify the lead diver to move towards the bar r ier support bracket. The lead diver will retrieve the tag line and coordinate final placement with the crane operator.

The lead diver will attempt to get the barrier support bracket as close to the subject velocity cap window before releasing from crane. The lead diver will then set the bracket on the concrete near velocity cap window to be readied for release from the crane. The lead diver will radio crane operator to prepare for next pick. Page 3 of5

' A second diver will assist in positioning the barrier bracket for installation of anchor bolts. Use marline spikes as needed to align bracket into drilled holes. One diver will hold barrier bracket in place while the lead diver tightens down the first set of KB3 31655 anchor bolts. Once the first set of bolts have been tightened and the bracket is stable, the divers will verify template hole placement, and if correct, drill the rest of the holes, and finish tightening down the bolts with hydraulic impact wrench and/or manually with 1" open faced wrench. Once the barrier support is secured, divers will then install the barrier panel assemblies.

Barrier panel assemblies will be lowered down using the Lift boat crane. Two divers will lift barrier panels into place and complete the securing of the barrier panels per the specification.

This installation sequence will be used for the north and south 12' Velocity Caps. Once the installation of the north and south 12' Velocity Caps Turtle Excluders has been completed, a final inspection will be performed to include measurements and video documenting the final as built condition.

Installation of 16' Velocity Cap Turtle Excluders The same work sequence used at the north and south velocity caps will be utilized for the installation of the turtle excluders at the 16' velocity cap. Budgetary Cost Proposal Budgetary Cost Proposal for Installation of North and South 12' and 16' Velocity Cap Turtle Excluders DATE: INQUIRY NO: PROJECT NAME: CONTRACT TYPE: SITE: TASK: PREPARED BY: --------' 8/1/2016 ' N/A Install Turtle Excluders at the two (2) 12' and one (1) 16' Velocity Caps Fixed Price FPL-St. Lucie Nuclear Power Plant Summary RexWamsher Page 4 of5

.00 648.65 .00 719.71 719.71 786.90 15 $1,310,064

.00 $1,310,064.00 Note: );> The main budget cost for the hardware includes more hardware then reflected on the BOM in the right hand of sheet 3 of 4. The BOM doesn't add up to what the details show, so we went off the details. );> A276 31655 materials were called for on the angle portion of the restrainer cradle frame. All the mills substituted A1069 laser fused material.

);> If the barrier Panel Tray material A276 31655 could be substituted with A-240 formed angle material, the material and fabrication of the turtle excluder panels and support frames total pricing could be reduced to $1,069,713.00.

Sincerely, RexWamsher Vice President/Nuclear Division Page5of5 Attachment 11, pg 1 of 1 None Minor Moderate Severe Total Cc Cm Ei De lk Total *2007 59 271 330 2007 227 101 1 1 0 330 2008 90 398 231 6 725 2008 420 299 4 0 2 725 2009 37 274 107 6 424 2009 260 161 2 1 0 42 4 2010 68 552 130 1 751 2010 295 444 3 2 7 751 2011 44 421 56 0 521 2011 302 217 2 0 0 521 2012 62 263 37 0 362 2012 232 127 1 2 0 36 2 2013 94 361 47 1 503 2013 303 196 2 2 0 503 2014 62 319 33 0 414 2014 275 134 3 0 2 414 2015 75 355 35 0 465 2015 274 181 1 2 7 465 2016 67 375 44 0 486 2016 316 159 4 1 6 486 **2017 23 171 11 0 205 **2017 167 38 0 0 0 205 5186 5 186

• In 2007, onl y the presence or absence of fresh scrapes was noted (scrape sever it y was not recorded for every affected turtle). ** 2017 is a partia l year (through 8/25/17)

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% O F T O TAL; PARABOLIC FIT OF PE AK S PEC TRAL 1q_!:l,V)::

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<S.o s.o-s.o-1.0-e.o-9.0-1 o.o-12.0-14.0-1 6.0-5.9 6.9 7.9 8.9 9.9 11.9 :3.9 15.9 LONGER 3 9 3 142 376 1 46 432 72 6 43 2 123 257 150 690 773 143p 1817 2464 1091 753 1 11 1 19 632 849 50 0 69C 2051 912 51 123 Sl 269 376 51 5 468 1 38 4 440 35 31 27 13C 305 428 996 523 11 111 222 1 82 219 15 9 5 1 23 11 3 5 1 393 363 1 810 25 1 5 3 0 23 4152 7 9 29 3578 11 3 1 5 27 83 19 112.0 2CS5 6370 25.3 2 419 9542 6064 3609 2420 747 259 8 1 83 19 l'PP {SE!C) "" l 0 .1 FINITE A'rLAN'l'!C NAV:S HINDCAST MONTH: Apr FOR YEARS PROC:SSED STATION LOCATION : ( -8 0. 00 N DE PT H : 64.0 rr-; ST63453 v03 lSBO -2014 I 27.25 N ) PER,CEN T OCCURRENCE (X1000) OF P..EIGH T AN I:l I?E lUCD BY DIREC'LON CENTRAL LOCAL ANGLE BAND CE' 67.5 (+/-1 1.25 PEG\ NO. CASES 6421 HEIGH'l' PARABOLIC FIT IN <5.0 5.0'-6.0-METERS 6.9 0.10-0.4 9 67 154 154 o.so-0.99 333 253 345 1.00-1. 49 146 .630 460 1. 50-1. 9S 170 6/(i 2.00-2,11£ 190 2.50-'2.99 3.00 ,-3.49 3.50-3.99 % o r TO'l'AL: PEAK PER!O D *:!N SECONDS) i.O-8.0-.9.0-10.0-12.0-14.0-16.0-7.9 8.9 9.9 ..:.1. 9 13.9 15.9 LONGER 83 373 257 4 40 253 222 107 960 1761 2142 2865 92 1 4 76 91 496 884 1321 2404 527 182 11 591 .539 630 1*448 123 257 35 309 341 1 2 3 246 15 170 126 H6 35 27 TOTAL 211 0 10047 " 1061 4467 122 4 482 62 0 4.00-4,49 0 4.50+ 0 'TOTP..L 546 1207 1823 2439 4068 ,1634 7616 1 72 4 1152 244 MEA..N H r no CM) 1.1 LARGEST Hmo (l*l) "" 3. 1

= 9.6 FINITE ' htto://wis

.usace.anny.mil/data/atl/pc n t/wave/63453/ST63453

• wAVE 1980 2014 04.txt 8/28/2017 Page 3 of9 Jl.T LA NTIC fo\'AVE HINDCAS'I

l'10NTH: Apr F OR YEARS PROCESSED 1 93 0 -2014 S'l'A'l'lON LOC ATION ; -80. 00 l'i' I 27.25 N ) DEP'rH : 64

• 0 m PERCENT OCCURRENCE

{X l OOO) OF HE IG HT AND ?ER I O D BY DI RECTION m:. Gat I N METERS o.to-0.49 0.50-0.99 1.00-l.H 1. so-1.99 2. 00-2. 49 2.50-2.9 9 3.00-3. 49 3.50-3.9.9 4.00-4.4S 4.50+ '1 0TAL NEM l:l'llo W.) CE: NTRXI.L LOC.IU. ANGL E: 6P.fJD Or 90.0 {+/-1 1.25 D£G:* NO. CASES 37 4 4 % OF rOTAJJ: PAAASO L IC li'IT Of PEA K SPECTRPW WAVE PERIOD (IN S ECON D S) <5.0 5.0-6.0-'7' 0-8.0-9.0-1 0.0-J_:?., O-14.0-16.0-5.9 6.9 7.9 8.9 9.9 11.9 13.9 1 5.S\ LONGER 1 19 43 19 242 337 25 7 49 6 202 75 8 3 1119 130 95 309 9Be 1333 45 2 238 -* 46 8 690 150 210 SO l 111 5 837 242 75 23 3 428 313 67 166 47Z 35 63 :2.18 19 39 55 il 2 3 1709 1291 795 847 263' 2B87 522 1 09 1.4.9 T QTJ*..L 1873 6135 46 11 1793 402 23 0 0 0 0 :..o LARGEST Hmo (M) : 2.7 MEAN

= 8.8 FINIT E ATLANTIC WAVE HINDCAS T MONTH: Apr F OR EROCES SE D LOCA110N ; ( -80,00 W DEPTE : 64.0 m : S T634 53_v 03 198 0 -20 14 I 27.25 N ) PERCENT OCCOR R.E N C E {XlO O O) OF H E IGR T AND ERID:J B Y DIREC'I: ION CENTRAL LOCAL B AND OF 1 12.5 (+i-1 1.25 DEG) l:lEIGB T IN NETERS 0.1 0-0.49 0.5 0-0.99 1. 00-1. 4 9 l. 50-1. 99 2.00-2.50-2.99 3.00-3.49 3.50-3.99 4.'00-4.50+ TO TAL PARABOL IC F!T <S.o s.o-6.0-5.9 6.9 376 15 11 1 468 218 35 956 HBO 47 317 71 31 NO. CASES t OF OF PEAK S PECT RAL WAVE PERIOD SECONDS) 7.0-8.0-1 0.0-12.0-14.0-1 6.0-7. 9 8. 9 9. 9 11.9 13. 9 15. 9 LON3 ER 43 3 1 75 198 222 1 1 ? 196 595 503 222 1 42 19 H 265 2 53 396 35 59 3 1 5 136 : 1 15 2800 20 3 0 BS 248 894 8 78 12!3 3 227 26 2292 9*.1 989 35:l.O 618 31 0 0 0 0 0 Hmo ( t-!) "' 1. 0 :i:.ARG3ST Hmo (tw i) 2.3 t1EAN TPP [SEC) = 7 . .3 F'INITE n If"\ (I i,....f\1,.,

ATLAN'I'JC l.VJW8 H INDGAS'l' MONTH: A p r FOR YEA R S E'ROCESSEC STJ.I..TION LO CAT ION : ( -8 0. CO W DEPTH : 64.0 m : S!J.'63453

_y03 1980 -2 014 I 27.25 N l Page 4 of9 ?ERC E NT OCCORRENCE (Xl O O O) HEIGH T AND FERIOJ BY D I RECTION CEN T RAL LOCA L AN G LE B.ZJ,ND OF 135.0 (+i-11.2 5 D E G) NC*. CAS3S 1167 %O F 4.6 HE I G R'f PA..'mBOLIC F I T OE' PEAK S PE:::'l 1 RAL WtWE : N SECONDS) I N 5.0-6.0-7.0-8.0-9.(1-10.0-12.0-H.O-1 6.D-5.9 6.9 7. 9 8.9 9.9 1 1.9 13.9 15 . .9 LONGER 0.10-0. 4 9 13 8 31 7 63 31 39 3C9 0.5 0-0.99 1329 H2 3 10 7 257 79 59 71 3 2 070 1. 00-1.49 42 0 1142 47 7 31 67 23 1731 1.5 0-1.99 1 98 194 27 3 11 433 2.00-2.4.9 63 63 2.50-2.99 0 3. 3 * .tl.9 0 3.50-3.99 0 4.00-4.49 0 4 .so .. 0 *ro*r :'-ili 1 86 7 1 53 3 314 0 114 35 1 2 0 4 10 1 1 0 5 .., ,) MEAN Hm o*:t-lj 1.0 LARG EST Elmo (f-*1) 2.2 l"lE-l!N rP? (SE:C} = 6.1 F il'UTE ATLANTIC F.I NDCAST : S T 63 4 53 v03 MONTH: Apr FOR YEARS PROCESSED 1SSO -i0:!.4 STATION LOC.Z\l'ION

( -80.00 l-1 I 27.25 N ) DEPTH : 64.C m PERCENT OCCURRENCE (X1000) OF HE IGHT PE RIOD BY DIRECT I ON CENTRAL L OCAL ANGLE BAND 07 157.5 (+/-1 1.25 bE G) NO. CASES 445 % Of' TOTA:.: 1.8 .B E IGBT PARABOLIC FIT O F PEAK SPEC T RAL NAV E PER I OD (IN SECO ND S.) IN <5.0 5.0'-6.0-'1. 0-a.o-9.0-10.0-12.0-14.0-16.0-TOTAL l-1ETE RS 5.9 6.9 7.9 S.9 9.9 11.9 13.9 1.5.9 L ON G ER o. 0-o. 4 9 2 3 23 0.50-0.99 57 9 134 39 43 27 11 833 1.00-l. 49 75 4'88 130 .3 3 7 11 7 47 771 1. 1. 99 1 5 91 15 1 21 2.0 0-2.49 3 3 2.50-2.99 0 3.00-3. 49 0 3.50-3.99 0 4.00-0 4.50+ 0 TOTAL 677 637 224 18 3 45 54 34 58 0 MEAN Hm o (M) = 1.0 LARGEST Hmo :: 2.0 t*JEAN 'IP?(S EC) 5.9 FINITE Q/")Q/")()1

'7

' ' AT L A N T I C N lf V E H INDCli.S T MONT H: Ap r F OR Y E ARS P R OC E SS ED STATIO N I.OCA'I'IO

'N : -8 0. 0 0 1r J

6 4.0 m : s T63 4:.3 v 0 3 1 980 -20 1 4 I 2 7.25 K ) P a g e 5 o f 9 P..:!..RCE N'l' OCCURR EN CE (X l0 0 0) OF HE I G H T AND PE RI O D BY DI RECTION CltN'r R.l\L LOCAL BAND O F l SO.O (+i-1l.25 DEGI c. CASES 9 B % O F T O TAL: 0. 4 HE I G H T PARABOL I C Fl'::' OF PEAK SPECTRA W AVE PElUOD (l N S EC: O ND Si I N <5.0 5.0-6.1)-7.0-a.o-9. c-10.0-1 2.0-H.O-16.0-TO'l'AL CJ!E'l'E RS 5.9 6.9 7.9 8.9 5.9 1 1.9 1 3.9 1 5.9 LO li)GE R 0.10-0. 4 9 2 3 23 0.5 0-0.99 1 3 4 39 11 3 2 3 210 1. 0 0-1.4 9 15 67 31 3 3 119 1.50-1. 99 15 11 215 2.00-2.4 9 D 2.50-2.9 9 0 3.0 0-3, 4.9 0 3.50-:2.99 0 4.00-4.4.9 0 4.50-0 T OT At 1 72 12 1 42 {) Q 14 6 23 0 0 l i(EAN Hm o \l*l) 0 a ,_, LARGES T H m o 1.8 ME A N TP P (SEC) 5.8 FI NI TE AT L A NT I C WAVE H INDCAS':' S T63453 v03 Apr F OR YEARS PROCESSE C 1 980 -2 0ltl S T ATION L:: lC ATION ; ( -80.0 0 I 21.25 N ) DEP'l'H : 64. 0 m P ER C E N T O C CU R R ENC E (X;l OOO) O F !!EI GHT AN D PE RI O D BY D I RECTIO N CEN TRAL L O::::e.L A N GLE BAN D OF 2 0 2,5 (+/-11.2 5 D E G) HEIG HT IN ME TE RS 0.1 0-0.4 9 0.50-o. 95 1.00-1.4 9 1.5 0-1. 9 9 2.00-2. 4 9 2.50-2;99 3.00-3. 4 9 3.5 0-3.99 4.00-L4 9 4.5 0+ T O TAL HlTl o ( f-1) "' NO. CASES 34 % O F TOTAL: C.l PARA BO LI C F I T :J E' P E AK S PE.C'r AAL NA VE PER,IOD ,;IN SE CON DS :* <5.8 6.0-7.0-8.0-9.0-10.0-1 2.0-14.0-T O T AL 7 5 9 15 8 1 0.9 5.9 6.9 7, 9 3.9 9.9 11.9 13.9 1 5.9 15 11 26 7 7 14 0 LA I\GEST H m o

"' 0 1.7 7 7 0 0 0 D 7 8 1 3 3 7 0 0 0 0 0 0 TPP (SE C) = 5.0 Q /'1 S H'1fl1 7 Page 6 of9 AT.LAN'UC ivAVE HWDCAS'l'

ST63453_ v03 1-lO N':'H: Apr F03. YEl'illS PROCESSED 1980 -2014 STATION LOCATION ; ( -80.00 W / 27.25 N ) DEPTH : IS4.0 m P 8 RCENT OCCURRENCE (XlODO) Of HEIGHT PERIOD BY DIREC T ION CEWI'R-% L OCAL AHGLE BAND 225.0 (+/-11.25 DEG) NO.

20 % OF TOT.'i.L:

0 . 1 BEIG.:-l'l' IN PARABOL I C FIT OE' Pl!:l\K SEEC'l'R.l\L!

PER I O J (IN S E CONDS :* <s.o 5,o-6.0-7.0-s.o-s.o-10.0-12.0-14.0-16.o-TO T AL 0.10-0.49 0.50-0.99 1.00-1 149 t. 50-l. 99 2.00-2..49 2.50-2.99 3*.00-;3.49 3.50-3.99 1:.00-4.49 L50+ TOTAL 23 7 3 33 S.9 6.9 ?.9 8.9 9.9 11.9 13.9 1 5.9 LONGER 1l 3 14 11 11 0 0 0 11 3 0 0 0 1ill.lill H."Tl c ( M) 1.0 LARGEST Hmo U'1) = 1, 6 TPP ( SEC) "" 5.1 F H HTE ATLAl'IT!C

!-lAVE HINDCAST Ap r STATION LOCATION : ( -80.00 '!-1 DEPTH : 6 4.0 m : S T 63453 '703 1.980 -2014 I 27.25 N ) PERCENT O CCURRENCE (61000) OF HEIGHT Al'ID PERIOD BY DIRECTION CENTRAL LOCAL ANGLE BAND OF 247 . .5 (+/-11.25 DEG) NO. CASES 16 0.1 0 45 24 3 0 0 0 0 0 0 JIEIGHT IN % OF TOTAL; PARABO,LIC F IT OF PEAK SPEC T RAL W AVE PERi O D SECON D S) <5.o 6.0-7.0-s.o-9.0-1o.o-12.0-14.o-1 6.0-5.9 6.9 7.9 8.9 9.9 1 1.9 13.9 15.9 LO N GER TO'l'fo..L t:viETERS 0.1 0-0.49 0.5 0-0 . .9.9 1.00-1.49 1.5 0-1. 9 9 2.0 0-2.4:9 2.5 0-2.99 3.0 0-:3.49 3.5 0-3.99 4.0 0-4.49 4 .50+ TOT J'IL 3 27 1 5 3 48 0.9 0 0 Rmo (N) 1.6 3 7 3 7 0 t*lEJ..N T PP (SEG} 0 0 S.l FIN I'f E 3 37 15 3 0 0 0 0 0 0 Page 7 of9 A T LANTIC Wl l VE HI N D C AST I*30NT H: Apr FOR YEARS ?ROCESSED STATION LOCA T I ON : ( -8C.OO W DEPTH : 64.0 : ST 63 45 3 v03 980 -2014 J 27.25 N ) f'ER::: ENT O CC O?.RE: N CE (X l OOO) O F HElGE T l'tND PE:i.UOD BY D IR E!C TION BAND 0! 27 0.J :+/-11.25 D EG) NO. CJI..SES ill O F' T O T AL: PARABO LI C F: T OF PEAK SPECTPAL f?E R I OD (IN .SECONDS) 18 0.1 HEIGHT IN <5.0 5.0-6.0-7.0-8.0-3.0-10.0-12.0-1 4.0-16.0-TOT A L METERS 0.10-0.49 0.50-0.99 l. 00-l. 49 1. 50-1. 99 2.00-2.49 2.50-2.99 3.00-3.49 3.50-3.99 11. 00-4. 4 9 4.5 0+ T OTAL 27 23 3 53 S.9 6.9 7.9 8.9 9.9 11.9 1 3.9 1 5.9 LONGER 3 0 0 0 0 3 7 3 10 0 0 0 i)IJEAN H."llo (M) 1.0 LARGEST Hm.o (l-1) "" 1.6 M EAN Tt?P (SEC) 5.3 FINITE HEIGHT A T LP..NTIC WAVE HBDCAST ST63453 v03 MONTH: Apr FOR YEARS PROCESSE D 1980 -2014 S TA'IION LOCATION ! ( -80. DO vJ / 27. N ) DEPTE : 64.0 m PERCE N T OCCDRRENCE

{XlOOO) Q j H E I GHT AN C PERIO D BY CENTRAL LOCAL AN G LE OF 292.5 (+/-11.25 DEG! NC. CASES % OF 'I'OTAL: 29 0.1 0 34 2 9 3 0 0 0 0 0 0 IN PARABOLIC FIT <5.0 s.c-6.0-5.9 6.9 OF PEAK SP E O:TRAL 'NiWE PERIOD SE:::mms) 7.0-8.0-9.0-10.0-12.0-:4.0-1 6.0-'I'O T AL f 1 1ETERS 0.1 0-0.49 0.5 0-0.9.9 '1. DO-1. 4 9 1. 50-1. 99 2.0 0-2.-a9 2.50-2.99 00-3. 4 9 3.50-3.99 4. 00-4. 49 4. 5 0-'IO'fAL 3 39 5 1 93 1.0 3 3 7.9 8.9 9.9 11,9 1 3.9 1 5.9 LONGER 3 3 7 0 0 3 10 0 0 0 LA.RGES'l' Hrno = 1. 7 t>iF.AA 'I'PP (SEC) 0 F:N I TE 3 45 SB 3 0 0 0 0 0 0 A T L AN T IC t U ND C M':' : S'l'63 45 3 v 0 3 1-lON':'H: A pr FO R Y EP..RS PROCESS E D 19 80 -20H S':.'A T ION

( -80.00 I 27.25 N J D E P'l'H ; 6 4. 0 n P E RC ENT OC C liF.RENC E (X 1 0D0) OF BE IGJIT l u'i!D PE R IOD BY DI RE CTION CENTr:\.'1\L LOCAL _ll.NGLE BP J.JD O F' :: IS. 0 (+/-_1.2 5 D EG) H E I G HT I N t.S ETERE 0.10-C.49 0.50-C.9Sl 1. 00-1. 4 9 1. 5 0-1. 99 2. 0 0-2. 4 9 2.50-2.9 9 3. 00-3. 4 9 3.5 0-3.9 9 4. 0 0-.4. 4.5 0-'IO T AL Nb. CAS E: S % O F' TO TAL: ?ARAB OLIC IT!T" *:)F FEAK S l?ECTAAL N 1 W E I?E:Rl iJ D i!N S:SC D'N DS) <s.o s.o-&.o-7.o-e.o-9.0-1 0.0-1 2.0-14.0-1 6.0-5.9 6.9 7.9 9.9 9.9 11.9 1 3.9 15.9 L Q N G8 R 7 7 67 3 1 5 1 5 14 6 i 7 7 15 1 1 3 22 0 2 8 0 0 0 22 40 0 D 0 Page 8 B l 0.3 TOTAL 14 10 0 1 67 2 6 3 0 0 0 0 0 l'l!:A N Hmo (M) -1.1 LARGES T H m o 0"') 2.0 5. B F I NITE H EI GHT TN fl.r LA NTIC WJI.VE HIND C AST Apr F O R Y E:ARS f:1RO C ESSE: D S TATION L::>CATION

{ -B O. 00 N DEPTH : 6 4.0 m : S T 6 3 4.5 3 v03 1 990 -20 1 4 I 2 7.25 N :* P ERC E N T OCCORRENCE OF HE I GJ T PE RI::>D BY DIR EC TION C E N TRAL :., QCl!.L ANGLE BAN J OF 3 37.5 (+/-11.25 OEG)

Cl\E;ES % OF TOTAL! PARABO L I C F!T O F PE AK SPEC T::mL WA VE PERIOD *: I N SECONDS) <5.0 5.0-6.0-7.0-B.C-9.0-1 D.O-,1 2.0-14 .. 0-16. o-1.3 T OT AL M ET E R S 5,9 6.9 7.9 8.9 .9.9 U.9 13.9 15.9 LONGE R 0.;1,.0-19 15 53 0.5 0-8.99 26 9 s-s 3 15 51 31 424 1.00-1. 49 234 5 1 35 1 9 75 !:i56 1. 50-1. 99 3 lli 8.3 35 1 5 247 2.00-2.49 1 9 7 26 2.50-2.99 0 3.00-3.49 0 3.50-3.99 0 4-00-<]. 4 9 0 4..50+ 0 TOTAL 419 156 92 0 70 136 0 0 0 MEAN Hmo :)1) 1.2 L.!l RGEST Hmo (L-1) 2.3

'l'PP (SEC) 6.2 FINI'l'E HEIGH'.J1 TN METERS 0.00-0.10 0.10-0.49 0.5 0-0.99 1.0 0-1.49 l. 50-1. 93 z.oo-2.4:9 2.50-2.'99 3.00-3.49 3.50-3.99 4. 00-4. 4 9 4.50+ 'l'O'l'AL

\t'U\VE. H INIJCAS'f' : S'l'6 3 4 53 v03 :'t-IONTH:

Ap r f'OR YEARS I?RCC ESS.K J ],.980 -2[)}.i Sl'ATIO N LCCATION : { -80,00 W / 27.25 N I D EP T H : PERCENT (XlCOO) O F E:!:IG FIT AND ?8 RIOP FOR ALL DIRBC T IO.'S Pl-\RABO;LIC F l'l' <5.0 5.0-6.0-5.9 6.9 1059 4 68 38 4 6'7 30 2027 2400 2738 5563 2849 19 14 *10 2138 3 587 10 546 9 5 01 8358 NQ. CASES : NO. CALfv!S : OF PEAK SPEC T RAL WAVE P8 R IO D (I N SECO N DS) 1.0-s.o-9.o-1 2.0-1 4.0-1 6.0-7.9 B.9 : 1.9 13.9 :5.9 8 1 7 980 1238 273 4 5738 6948 L853 2 710 38 92 1M6 1698 1 7 65 646 95E 746 11 361 38 8 1 5 158 2C 71 8531 6!: 8 3 3535 1269 316 222 3 1202 3317 2083 869 5 23 2 18 11 51 4 56 1 98 1888 269 6 1 5 222 412 99 99 3 15 2.7 83 19 870 7 12458 151 2 7 2259 0 82 7 4 3617 788 Page 9 of9 25200 0 'f OTAL 0 8865 4058 2 3D lOB 13621 482 9 1357 1121 Bl B3 :9 MEAN Hmo!M) ; 1.1 LARGEST Rmo {C.!} = 4. 5 filEAN o:: 8.9 FINITE' n f l"'\0 '"rL 1,..,

V'/ 'DO SIG WAVE HEGHT (m) Atlanti c W I S S t ation 6 3453 All A pn;: 1 980

• 20 1 4 Long: -80° La l: 27.25° D e pl h: E4 m T o la l O bs : 252 0 0 WAVE.RO*SE 0 180 s , . 1*2 M ... .... Page 1 of I 90 E 0/'"10/'"lf\1,.,