ML19078A330

NUREG-1437 Dfc, Supplement 5, Second Renewal, Generic Environmental Impact Statement for License Renewal of Nuclear Plants - Supplement 5, Second Renewal - Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3

ML19078A330
Person / Time
Site:	Turkey Point
Issue date:	03/31/2019
From:	David Drucker NRC/NRR/DMLR/MRPB
To:
Drucker D, NRR-DMLR 415-6223
References
NUREG-1437 DFC S5
Download: ML19078A330 (429)

Text

[[:#Wiki_filter:NUREG-1437 Supplement 5, Second Renewal Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5, Second Renewal Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 Draft Report for Comment Office of Nuclear Reactor Regulation

AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as books, the NRCs Public Electronic Reading Room at journal articles, transactions, Federal Register notices, http://www.nrc.gov/reading-rm.html. Publicly released Federal and State legislation, and congressional reports. records include, to name a few, NUREG-series Such documents as theses, dissertations, foreign reports publications; Federal Register notices; applicant, and translations, and non-NRC conference proceedings licensee, and vendor documents and correspondence; may be purchased from their sponsoring organization. NRC correspondence and internal memoranda; bulletins Copies of industry codes and standards used in a and information notices; inspection and investigative substantive manner in the NRC regulatory process are reports; licensee event reports; and Commission papers maintained at and their attachments. The NRC Technical Library NRC publications in the NUREG series, NRC Two White Flint North regulations, and Title 10, Energy, in the Code of 11545 Rockville Pike Federal Regulations may also be purchased from one Rockville, MD 20852-2738 of these two sources. These standards are available in the library for reference

1. The Superintendent of Documents use by the public. Codes and standards are usually U.S. Government Publishing Office copyrighted and may be purchased from the originating organization or, if they are American National Standards, Washington, DC 20402-0001 from Internet: http://bookstore.gpo.gov American National Standards Institute Telephone: 1-866-512-1800 11 West 42nd Street Fax: (202) 512-2104 New York, NY 10036-8002 http://www.ansi.org

2. The National Technical Information Service (212) 642-4900 5301 Shawnee Road Alexandria, VA 22161-0002 http://www.ntis.gov Legally binding regulatory requirements are stated only in laws; NRC regulations; licenses, including technical 1-800-553-6847 or, locally, (703) 605-6000 specifications; or orders, not in NUREG-series publications. The views expressed in contractor-A single copy of each NRC draft report for comment is prepared publications in this series are not necessarily available free, to the extent of supply, upon written those of the NRC.

request as follows: The NUREG series comprises (1) technical and U.S. Nuclear Regulatory Commission administrative reports and books prepared by the staff Office of Administration (NUREG-XXXX) or agency contractors Multimedia, Graphics and Storage & Distribution Branch (NUREG/CR-XXXX), (2) proceedings of conferences Washington, DC 20555-0001 (NUREG/CP-XXXX), (3) reports resulting from E-mail: distribution.resource@nrc.gov international agreements (NUREG/IA-XXXX), (4) Facsimile: (301) 415-2289 brochures (NUREG/BR-XXXX), and (5) compilations of legal decisions and orders of the Commission and Atomic and Safety Licensing Boards and of Directors Some publications in the NUREG series that are decisions under Section 2.206 of NRCs regulations posted at the NRCs Web site address (NUREG-0750). http://www.nrc.gov/reading-rm/doc-collections/nuregs are updated periodically and may differ from the last DISCLAIMER: This report was prepared as an account of printed version. Although references to material work sponsored by an agency of the U.S. Government. found on a Web site bear the date the material was Neither the U.S. Government nor any agency thereof, nor accessed, the material available on the date cited any employee, makes any warranty, expressed or may subsequently be removed from the site. implied, or assumes any legal liability or responsibility for any third partys use, or the results of such use, of any information, apparatus, product, or process disclosed in this publication, or represents that its use by such third party would not infringe privately owned rights. SR-CR 10/2017

NUREG-1437 Supplement 5, Second Renewal Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5, Second Renewal Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 Draft Report for Comment Manuscript Completed: March 2019 Date Published: March 2019 Office of Nuclear Reactor Regulation

COMMENTS ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT Any interested party may submit comments on this draft supplemental environmental impact statement for consideration by the NRC staff. Please specify NUREG-1437, Supplement 5, Second Renewal, draft, in the subject or title line for your comments. Send comments by the end of the comment period specified in the Federal Register notice announcing the availability of this draft supplemental environmental impact statement. You may submit comments electronically by searching for Docket ID NRC-2018-0101 at the Federal Rulemaking Web site, http://www.regulations.gov. Please include Docket ID NRC-2018-0101 in the subject line of your comments. You may also mail comments to the following address: Office of Administration TWFN-7-A60M ATTN: Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 You may also email comments to: TurkeyPoint34SLREIS.Resource@nrc.gov The NRC cautions you not to include identifying or contact information that you do not want to be publicly disclosed in your comment submission. The NRC will post all comment submissions at http://www.regulations.gov as well as enter the comment submissions into the NRCs Agencywide Documents Access and Management System (ADAMS). The NRC does not routinely edit comment submissions to remove identifying or contact information. For any questions about the material in this draft supplemental environmental impact statement, please contact: David Drucker, Senior Project Manager, by phone at 301-415-6223 or by e-mail at david.drucker@nrc.gov.

1 COVER SHEET 2 Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor 3 Regulation. The U.S. National Park Service, Southeast Region, is a cooperating agency. 4 Title: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, 5 Supplement 5, Second Renewal, Regarding Subsequent License Renewal for Turkey Point 6 Nuclear Generating Unit Nos. 3 and 4, Draft Report for Comment (NUREG-1437). 7 For additional information or copies of this document contact: 8 U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation 9 11555 Rockville Pike, Mail Stop O-11F1 10 Rockville, MD 20852 11 Email: david.drucker@nrc.gov 12 ABSTRACT 13 The U.S. Nuclear Regulatory Commission (NRC) staff prepared this draft supplemental 14 environmental impact statement (SEIS) as part of its environmental review of Florida Power & 15 Light Companys subsequent license renewal application, to renew the operating licenses for 16 Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point or Turkey Point Units 3 and 4) 17 for an additional 20 years. This draft SEIS includes the NRC staffs preliminary evaluation of the 18 environmental impacts of the subsequent license renewal as well as alternatives to subsequent 19 license renewal. Alternatives to subsequent license renewal considered in this draft SEIS 20 include: (1) a new nuclear power plant, (2) a new natural gas combined-cycle power plant, and 21 (3) the combination of a new natural gas combined-cycle power plant and new solar 22 photovoltaic power generation. In addition to replacement power alternatives, this draft SEIS 23 evaluates an alternative cooling water system to mitigate potential impacts associated with the 24 continued use of the existing cooling canal system. The NRC staffs preliminary 25 recommendation is that the adverse environmental impacts of subsequent license renewal for 26 Turkey Point are not so great that preserving the option of subsequent license renewal for 27 energy-planning decisionmakers would be unreasonable. The NRC staff based its 28 recommendation on the following: 29

• the analysis and findings in NUREG-1437, Generic Environmental Impact Statement 30 for License Renewal of Nuclear Plants 31
• the environmental report submitted by Florida Power & Light Company 32
• the NRC staffs consultation with Federal, State, Tribal, and local government agencies 33
• the NRC staffs independent environmental review 34
• the NRC staffs consideration of public comments 35 Comments on this draft SEIS should be filed no later than 45 days after the date on which the 36 U.S. Environmental Protection Agency (EPA) notice, stating that this draft SEIS has been filed 37 with the EPA, is published in the Federal Register. Comments received after the expiration of 38 the comment period will be considered if it is practical to do so, but assurance of consideration 39 of late comments cannot be given.

iii

1 TABLE OF CONTENTS 2 COVER SHEET .........................................................................................................................iii 3 ABSTRACT ...............................................................................................................................iii 4 TABLE OF CONTENTS .............................................................................................................v 5 LIST OF FIGURES ....................................................................................................................xi 6 LIST OF TABLES ....................................................................................................................xiii 7 EXECUTIVE

SUMMARY

..........................................................................................................xv 8 ABBREVIATIONS AND ACRONYMS .....................................................................................xxi 9 1 INTRODUCTION .................................................................................................................1-1 10    1.1 Proposed Federal Action ............................................................................................1-1 11    1.2 Purpose and Need for the Proposed Federal Action ..................................................1-1 12    1.3 Major Environmental Review Milestones ....................................................................1-2 13    1.4 Generic Environmental Impact Statement ..................................................................1-3 14    1.5 Supplemental Environmental Impact Statement .........................................................1-5 15    1.6 Decisions To Be Supported by the SEIS ....................................................................1-6 16    1.7 Cooperating Agencies ................................................................................................1-6 17    1.8 Consultations .............................................................................................................1-7 18    1.9 Correspondence.........................................................................................................1-7 19    1.10 Status of Compliance .................................................................................................1-8 20    1.11 Related State and Federal Activities...........................................................................1-8 21 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION .................................................2-1 22    2.1 Proposed Action .........................................................................................................2-1 23         2.1.1    Plant Operations during the Subsequent License Renewal Term .................2-2 24         2.1.2    Refurbishment and Other Activities Associated with Subsequent 25                  License Renewal ..........................................................................................2-2 26         2.1.3    Termination of Nuclear Power Plant Operations and Decommissioning 27                  after the Subsequent License Renewal Term ...............................................2-3 28    2.2 Alternatives ................................................................................................................2-3 29         2.2.1    No-Action Alternative ....................................................................................2-4 30         2.2.2    Replacement Power Alternatives..................................................................2-5 31         2.2.3    Cooling Water System Alternative ..............................................................2-12 32    2.3 Alternatives Considered but Eliminated ....................................................................2-13 33         2.3.1    Solar Power................................................................................................2-13 34         2.3.2    Wind Power ................................................................................................2-14 35         2.3.3    Biomass Power ..........................................................................................2-15 36         2.3.4    Demand-Side Management........................................................................2-15 37         2.3.5    Hydroelectric Power ...................................................................................2-16 38         2.3.6    Geothermal Power .....................................................................................2-16 39         2.3.7    Wave and Ocean Energy ...........................................................................2-17 40         2.3.8    Municipal Solid Waste ................................................................................2-17 v

1 2.3.9 Petroleum-Fired Power ..............................................................................2-18 2 2.3.10 Coal-Fired Power .......................................................................................2-18 3 2.3.11 Fuel Cells ...................................................................................................2-19 4 2.3.12 Purchased Power .......................................................................................2-19 5 2.3.13 Delayed Retirement....................................................................................2-20 6 2.4 Comparison of Alternatives ......................................................................................2-20 7 3 AFFECTED ENVIRONMENT ..............................................................................................3-1 8 3.1 Description of Nuclear Power Plant Facility and Operation .........................................3-1 9 3.1.1 External Appearance and Setting .................................................................3-1 10 3.1.2 Nuclear Reactor Systems .............................................................................3-4 11 3.1.3 Cooling and Auxiliary Water Systems ...........................................................3-4 12 3.1.4 Radioactive Waste Management Systems .................................................3-12 13 3.1.5 Nonradioactive Waste Management Systems ............................................3-19 14 3.1.6 Utility and Transportation Infrastructure ......................................................3-20 15 3.1.7 Nuclear Power Plant Operations and Maintenance ....................................3-22 16 3.2 Land Use and Visual Resources ..............................................................................3-23 17 3.2.1 Land Use ....................................................................................................3-23 18 3.2.2 Visual Resources .......................................................................................3-24 19 3.3 Meteorology, Air Quality, and Noise .........................................................................3-25 20 3.3.1 Meteorology and Climatology .....................................................................3-25 21 3.3.2 Air Quality ..................................................................................................3-25 22 3.3.3 Noise ..........................................................................................................3-28 23 3.4 Geologic Environment ..............................................................................................3-29 24 3.4.1 Physiography, Geology, and Soils ..............................................................3-29 25 3.4.2 Economic Resources .................................................................................3-29 26 3.4.3 Seismic Setting ..........................................................................................3-30 27 3.5 Water Resources .....................................................................................................3-31 28 3.5.1 Surface Water ............................................................................................3-32 29 3.5.2 Groundwater Resources.............................................................................3-53 30 3.6 Terrestrial Resources ...............................................................................................3-86 31 3.6.1 Vegetative Communities.............................................................................3-86 32 3.6.2 Wildlife .......................................................................................................3-89 33 3.6.3 Important Species and Habitats..................................................................3-90 34 3.6.4 Invasive and Non-Native Species ...............................................................3-94 35 3.7 Aquatic Resources ...................................................................................................3-94 36 3.7.1 South Florida Coastal Plain Ecoregion .......................................................3-94 37 3.7.2 Aquatic Resources near the Turkey Point Site ...........................................3-95 38 3.7.3 Aquatic Resources on the Turkey Point Site...............................................3-96 39 3.7.4 Biscayne Bay and Card Sound Semiannual Monitoring ............................3-102 40 3.7.5 Additional Information on Aquatic Resources ...........................................3-104 vi

1 3.8 Special Status Species and Habitats ......................................................................3-104 2 3.8.1 Species and Habitats Protected Under the Endangered Species Act .......3-104 3 3.8.2 Species and Habitats Protected under the Magnuson-Stevens Act .........3-112 4 3.9 Historic and Cultural Resources .............................................................................3-114 5 3.9.1 Cultural Background .................................................................................3-114 6 3.9.2 Historic and Cultural Resources at Turkey Point ......................................3-115 7 3.10 Socioeconomics .....................................................................................................3-116 8 3.10.1 Power Plant Employment .........................................................................3-117 9 3.10.2 Regional Economic Characteristics ..........................................................3-117 10 3.10.3 Demographic Characteristics ...................................................................3-119 11 3.10.4 Housing and Community Services ............................................................3-122 12 3.10.5 Tax Revenues ..........................................................................................3-124 13 3.10.6 Local Transportation.................................................................................3-126 14 3.11 Human Health ........................................................................................................3-127 15 3.11.1 Radiological Exposure and Risk ...............................................................3-127 16 3.11.2 Chemical Hazards ....................................................................................3-128 17 3.11.3 Microbiological Hazards ...........................................................................3-129 18 3.11.4 Electromagnetic Fields .............................................................................3-129 19 3.11.5 Other Hazards ..........................................................................................3-129 20 3.12 Environmental Justice ............................................................................................3-130 21 3.13 Waste Management and Pollution Prevention ........................................................3-135 22 3.13.1 Radioactive Waste ...................................................................................3-135 23 3.13.2 Nonradioactive Waste ..............................................................................3-135 24 4 ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS ...............................4-1 25 4.1 Introduction ................................................................................................................4-1 26 4.2 Land Use and Visual Resources ................................................................................4-7 27 4.2.1 Proposed Action ...........................................................................................4-7 28 4.2.2 No-Action Alternative ....................................................................................4-7 29 4.2.3 Replacement Power Alternatives: Common Impacts ....................................4-8 30 4.2.4 New Nuclear Alternative ...............................................................................4-9 31 4.2.5 Natural Gas Combined-Cycle Alternative .....................................................4-9 32 4.2.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 33 Photovoltaic Generation) ............................................................................4-10 34 4.2.7 Cooling Water System Alternative ..............................................................4-11 35 4.3 Air Quality and Noise ...............................................................................................4-11 36 4.3.1 Proposed Action .........................................................................................4-12 37 4.3.2 No-Action Alternative ..................................................................................4-12 38 4.3.3 Replacement Power Alternatives: Common Impacts ..................................4-13 39 4.3.4 New Nuclear Alternative .............................................................................4-14 40 4.3.5 Natural Gas Combined-Cycle Alternative ...................................................4-15 vii

1 4.3.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 2 Photovoltaic Generation) ............................................................................4-17 3 4.3.7 Cooling Water System Alternative ..............................................................4-18 4 4.4 Geologic Environment ..............................................................................................4-19 5 4.4.1 Proposed Action .........................................................................................4-19 6 4.4.2 No-Action Alternative ..................................................................................4-20 7 4.4.3 Replacement Power Alternatives: Common Impacts ..................................4-20 8 4.4.4 New Nuclear Alternative .............................................................................4-20 9 4.4.5 Natural Gas Combined-Cycle Alternative ...................................................4-20 10 4.4.6 Combination Natural Gas Combined-Cycle and Solar Photovoltaic 11 Alternative ..................................................................................................4-20 12 4.4.7 Cooling Water System Alternative ..............................................................4-21 13 4.5 Water Resources .....................................................................................................4-21 14 4.5.1 Proposed Action .........................................................................................4-21 15 4.5.2 No-Action Alternative ..................................................................................4-35 16 4.5.3 Replacement Power Alternatives: Common Impacts ..................................4-36 17 4.5.4 New Nuclear Alternative .............................................................................4-39 18 4.5.5 Natural Gas Combined-Cycle Alternative ...................................................4-39 19 4.5.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 20 Photovoltaic Generation) ............................................................................4-40 21 4.5.7 Cooling Water System Alternative ..............................................................4-41 22 4.6 Terrestrial Resources ...............................................................................................4-42 23 4.6.1 Proposed Action .........................................................................................4-42 24 4.6.2 No-Action Alternative ..................................................................................4-46 25 4.6.3 Replacement Power Alternatives: Common Impacts ..................................4-47 26 4.6.4 New Nuclear Alternative .............................................................................4-47 27 4.6.5 Natural Gas Combined-Cycle Alternative ...................................................4-48 28 4.6.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 29 Photovoltaic Generation) ............................................................................4-48 30 4.6.7 Cooling Water System Alternative ..............................................................4-48 31 4.7 Aquatic Resources ...................................................................................................4-49 32 4.7.1 Proposed Action .........................................................................................4-49 33 4.7.2 No-Action Alternative ..................................................................................4-57 34 4.7.3 Replacement Power Alternatives: Common Impacts ..................................4-57 35 4.7.4 New Nuclear Alternative .............................................................................4-58 36 4.7.5 Natural Gas Combined-Cycle Alternative ...................................................4-59 37 4.7.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 38 Photovoltaic Generation) ............................................................................4-59 39 4.7.7 Cooling Water System Alternative ..............................................................4-59 40 4.8 Special Status Species and Habitats ........................................................................4-60 41 4.8.1 Proposed Action .........................................................................................4-60 42 4.8.2 No-Action Alternative ..................................................................................4-68 viii

1 4.8.3 Replacement Power Alternatives: Common Impacts ..................................4-69 2 4.9 Historic and Cultural Resources ...............................................................................4-71 3 4.9.1 Proposed Action .........................................................................................4-71 4 4.9.2 No-Action Alternative ..................................................................................4-73 5 4.9.3 Replacement Power Alternatives: Common Impacts ..................................4-73 6 4.9.4 Cooling Water System Alternative ..............................................................4-76 7 4.10 Socioeconomics .......................................................................................................4-76 8 4.10.1 Proposed Action .........................................................................................4-76 9 4.10.2 No-Action Alternative ..................................................................................4-77 10 4.10.3 Replacement Power Alternatives: Common Impacts ..................................4-78 11 4.10.4 New Nuclear Alternative .............................................................................4-79 12 4.10.5 Natural Gas Combined-Cycle Alternative ...................................................4-80 13 4.10.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 14 Photovoltaic Generation) ............................................................................4-81 15 4.10.7 Cooling Water System Alternative ..............................................................4-82 16 4.11 Human Health ..........................................................................................................4-84 17 4.11.1 Proposed Action .........................................................................................4-84 18 4.11.2 No-Action Alternative ..................................................................................4-86 19 4.11.3 Replacement Power Alternatives: Common Impacts ..................................4-86 20 4.11.4 New Nuclear Alternative .............................................................................4-87 21 4.11.5 Natural Gas Combined-Cycle Alternative ...................................................4-87 22 4.11.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 23 Photovoltaic Generation) ............................................................................4-87 24 4.11.7 Cooling Water System Alternative ..............................................................4-88 25 4.12 Environmental Justice ..............................................................................................4-88 26 4.12.1 Proposed Action .........................................................................................4-89 27 4.12.2 No-Action Alternative ..................................................................................4-91 28 4.12.3 Replacement Power Alternatives: Common Impacts ..................................4-91 29 4.12.4 Cooling Water System Alternative ..............................................................4-94 30 4.13 Waste Management .................................................................................................4-95 31 4.13.1 Proposed Action .........................................................................................4-95 32 4.13.2 No-Action Alternative ..................................................................................4-95 33 4.13.3 Replacement Power Alternatives: Common Impacts ..................................4-95 34 4.13.4 New Nuclear Alternative .............................................................................4-95 35 4.13.5 Natural Gas Combined-Cycle Alternative ...................................................4-96 36 4.13.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 37 Photovoltaic Generation) ............................................................................4-96 38 4.13.7 Cooling Water System Alternative ..............................................................4-97 39 4.14 Evaluation of New and Significant Information .........................................................4-97 40 4.15 Impacts Common to All Alternatives .........................................................................4-99 41 4.15.1 Fuel Cycle ..................................................................................................4-99 42 4.15.2 Terminating Power Plant Operations and Decommissioning ....................4-100 ix

1 4.15.3 Greenhouse Gas Emissions and Climate Change ....................................4-102 2 4.16 Cumulative Impacts................................................................................................4-111 3 4.16.1 Air Quality ................................................................................................4-113 4 4.16.2 Water Resources......................................................................................4-114 5 4.16.3 Terrestrial Resources ...............................................................................4-118 6 4.16.4 Aquatic Resources ...................................................................................4-119 7 4.16.5 Socioeconomics .......................................................................................4-122 8 4.16.6 Historic and Cultural Resources ...............................................................4-123 9 4.16.7 Human Health ..........................................................................................4-124 10 4.16.8 Environmental Justice ..............................................................................4-125 11 4.16.9 Waste Management and Pollution Prevention ..........................................4-126 12 4.16.10 Global Greenhouse Gas Emissions ..........................................................4-127 13 4.17 Resource Commitments Associated with the Proposed Action...............................4-129 14 4.17.1 Unavoidable Adverse Environmental Impacts ..........................................4-129 15 4.17.2 Relationship between Short-Term Use of the Environment and 16 Long-Term Productivity ............................................................................4-129 17 4.17.3 Irreversible and Irretrievable Commitment of Resources ..........................4-130 18 5 CONCLUSION ....................................................................................................................5-1 19 5.1 Environmental Impacts of Subsequent License Renewal ...........................................5-1 20 5.2 Comparison of Alternatives ........................................................................................5-1 21 5.3 Preliminary Recommendation ....................................................................................5-2 22 6 REFERENCES ....................................................................................................................6-1 23 7 LIST OF PREPARERS .......................................................................................................7-1 24 8 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF 25 THIS SEIS ARE SENT ........................................................................................................8-1 26 9 INDEX .................................................................................................................................9-1 27 COMMENTS RECEIVED ON THE TURKEY POINT NUCLEAR 28 GENERATING UNITS 3 AND 4 ENVIRONMENTAL REVIEW ....................... A-1 29 APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS ..... B-1 30 CONSULTATION CORRESPONDENCE ....................................................... C-1 31 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE ..... D-1 32 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS ................... E-1 x

1 LIST OF FIGURES 2 Figure 1-1 Environmental Review Process.........................................................................1-3 3 Figure 1-2 Environmental Issues Evaluated for License Renewal ......................................1-5 4 Figure 3-1 Map Showing the 50-mi (80-km) Radius Around the Turkey Point Site .............3-3 5 Figure 3-2 Generic Cooling System with Cooling Canal System ........................................3-5 6 Figure 3-3 Flow of Water Through the Cooling Canal System ............................................3-7 7 Figure 3-4 Cooling Canal System and Adjacent Canals ...................................................3-10 8 Figure 3-5 Turkey Point In-Scope Transmission Lines (FPL 2018f)..................................3-22 9 Figure 3-6 Geologic Stratigraphy and Major Aquifers Beneath the Turkey Point Site .......3-31 10 Figure 3-7 Turkey Point Site, Biscayne Bay, Card Sound, and Regional Canals ..............3-33 11 Figure 3-8 FEMA Flood Zones Map of the Turkey Point Property ....................................3-38 12 Figure 3-9 Florida Department of Environmental Protection NPDES Permitted Outfalls ...3-40 13 Figure 3-10 Locations of Surface Water Monitoring Stations ..............................................3-43 14 Figure 3-11 Generalized Diagram of the Freshwater-Saltwater Interface in a Coastal 15 Water Table Aquifer ........................................................................................3-55 16 Figure 3-12 Groundwater Monitoring Locations and Saltwater Interface, Turkey Point 17 Site .................................................................................................................3-60 18 Figure 3-13 Extent of Tritium in the Deep Interval of the Biscayne Aquifer in the 19 Vicinity of the Turkey Point Site, 2017 .............................................................3-66 20 Figure 3-14 Layout of Biscayne Aquifer Recovery Well System and Testing Wells ............3-72 21 Figure 3-15 Turkey Point Groundwater Protection Initiative Monitoring Well Locations ......3-78 22 Figure 3-16 Location of Groundwater Production Wells on the Turkey Point Site ...............3-85 23 Figure 3-17 Average Height of Sawgrass Blades Within Freshwater Marsh Transects 24 from October 2011 through February 2017 .....................................................3-87 25 Figure 3-18 Live Sawgrass Biomass Within Freshwater Marsh Transects from 26 October 2011 through February 2017 .............................................................3-88 27 Figure 3-19 Live Biomass Within Two Red Mangrove Plots (M1-2 and M3-2) from 28 October 2011 through February 2017 .............................................................3-89 29 Figure 3-20 Turkey Point Site Fish Survey Sample Locations, June 2009 .........................3-98 30 Figure 3-21 Cooling Canal System Characterization Survey Sample Locations, 31 December 2016 ............................................................................................3-100 32 Figure 3-22 Biscayne Bay and Card Sound Semiannual Monitoring Ecological 33 Transection Locations ...................................................................................3-103 34 Figure 3-23 2010 CensusMinority Block Groups Within a 50-mi (80-km) Radius of 35 Turkey Point..................................................................................................3-133 36 Figure 3-24 2012-2016, American Community Survey 5-Year Estimates 37 Low-Income Block Groups Within a 50-mi (80-km) Radius of Turkey Point ...3-134 xi

xii 1 LIST OF TABLES 2 Table ES-1 Summary of NRC Conclusions Relating to Site-Specific Impacts of 3 Subsequent License Renewal at Turkey Point ................................................. xviii 4 Table 2-1 Summary and Key Characteristics of Replacement Power Alternatives 5 Considered In Depth .........................................................................................2-7 6 Table 2-2 Summary of Environmental Impacts of the Proposed Action and 7 Alternatives .....................................................................................................2-22 8 Table 3-1 Ambient Air Quality Standards ........................................................................3-26 9 Table 3-2 Permitted Air Emission Sources at Turkey Point Units 3 and 4 .......................3-27 10 Table 3-3 Estimated Air Pollutant Emissions from Turkey Point Units 3 and 4 ................3-28 11 Table 3-4 Summary of Groundwater Monitoring Results for Selected Biscayne 12 Aquifer Wells (Shallow and Deep Intervals), Turkey Point Uprate 13 Monitoring Program ........................................................................................3-63 14 Table 3-5 Representative Groundwater and Storm Drain Monitoring Results for 15 Tritium, Turkey Point Groundwater Protection Program, 2017 (in 16 PicoCuries per Liter) .......................................................................................3-76 17 Table 3-6 Groundwater Withdrawals at the Turkey Point Site .........................................3-81 18 Table 3-7 Migratory Birds Protected under the Migratory Bird Treaty Act That Are 19 Most Likely to Occur at Turkey Point ...............................................................3-92 20 Table 3-8 Aquatic Species Reported from the Cooling Canal System, November 21 2007................................................................................................................3-96 22 Table 3-9 Number and Relative Abundance of Fish Captured at Seven Locations on 23 the Turkey Point Site, June 2009 ....................................................................3-99 24 Table 3-10 Federally Listed Species under U.S. Fish and Wildlife Service Jurisdiction ...3-106 25 Table 3-11 Federally Listed Endangered or Threatened Species Under National 26 Marine Fisheries Service Jurisdiction in Biscayne Bay ..................................3-111 27 Table 3-12 Designated Essential Fish Habitat near the Turkey Point Site .......................3-113 28 Table 3-13 Residence of Permanent Turkey Point Employees by County.......................3-117 29 Table 3-14 Employment by Industry in Miami-Dade County (2016 Estimates) ................3-118 30 Table 3-15 Estimated Income Information for Miami-Dade County and Florida 31 (2016 Estimate) ............................................................................................3-118 32 Table 3-16 Population and Percent Growth in Miami-Dade County 1990-2060 ..............3-119 33 Table 3-17 Demographic Profile of the Population in Miami-Dade County in 2010..........3-120 34 Table 3-18 Demographic Profile of the Population in Miami-Dade County, 2016 35 Estimates ......................................................................................................3-120 36 Table 3-19 2016 Estimated Seasonal Housing in Counties Located Within 50 mi 37 (80 km) of Turkey Point .................................................................................3-121 38 Table 3-20 2012 Migrant Farm Workers and Temporary Farm Labor in Counties 39 Located within 50 mi of Turkey Point.............................................................3-122 xiii

1 Table 3-21 Housing in Miami-Dade County (2016) .........................................................3-123 2 Table 3-22 Major Public Water Suppliers in Miami-Dade County ....................................3-124 3 Table 3-23 Miami-Dade County Total Operating Revenues, Miami-Dade County 4 School Board Revenues, and Florida Power & Light Turkey Point 5 Property Tax Payments (2012-2017)............................................................3-125 6 Table 3-24 2017 Annual Average Daily Traffic in the Vicinity of Turkey Point .................3-126 7 Table 4-1 Applicable Category 1 (Generic) Issues for Turkey Point ..................................4-2 8 Table 4-2 Applicable Category 2 (Site-Specific) Issues for Turkey Point ...........................4-5 9 Table 4-3 Average Maximum Daily Temperature at CCS Outfall 001..............................4-55 10 Table 4-4 Effect Determinations for Federally Listed Species Under U.S. Fish and 11 Wildlife Service Jurisdiction .............................................................................4-60 12 Table 4-5 Effect Determinations for Federally Listed Species Under National Marine 13 Fisheries Service Jurisdiction ..........................................................................4-63 14 Table 4-6 Estimated Greenhouse Gas Emissions(a) from Operation at Turkey Point, 15 Units 3 and 4.................................................................................................4-103 16 Table 4-7 Direct Greenhouse Gas Emissions from Facility Operations Under the 17 Proposed Action and Alternatives .................................................................4-104 18 Table 4-8 Comparison of Greenhouse Gas Emission Inventories .................................4-128 19 Table 7-1 List of Preparers ...............................................................................................7-1 20 Table 8-1 List of Agencies, Organizations, and Persons to Whom Copies of this 21 SEIS Are Sent...................................................................................................8-1 22 Table B-1 Federal and State Requirements ..................................................................... B-2 23 Table B-2 Federal, State, and Local Permits and Other Requirements ............................ B-7 24 Table C-1 National Historic Preservation Act Correspondence ......................................... C-4 25 Table D-1 Environmental Review Correspondence .......................................................... D-1 xiv

1 EXECUTIVE

SUMMARY

2 Background

3 By letter dated January 30, 2018, Florida Power & Light Company (FPL) submitted to the 4 U.S. Nuclear Regulatory Commission (NRC) an application requesting subsequent license 5 renewal for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 renewed facility operating 6 licenses (Agencywide Documents Access and Management System (ADAMS) Package 7 Accession No. ML18037A812). FPL subsequently supplemented its application by letters dated 8 February 9, 2018 (ADAMS Accession No. ML18044A653), February 16, 2018 (ADAMS 9 Package Accession No. ML18053A123), March 1, 2018 (ADAMS Package Accession 10 No. ML18072A224), and April 10, 2018 (ADAMS Package Accession No. ML18113A132). The 11 Turkey Point Unit No. 3 current renewed facility operating license (DPR-31) expires at midnight 12 on July 19, 2032; the Turkey Point Unit No. 4 current renewed facility operating license 13 (DPR-41) expires at midnight on April 10, 2033. In its application, FPL requested license 14 renewal for a period of 20 years beyond the dates when the current renewed facility operating 15 licenses expire, to July 19, 2052 for Turkey Point Unit No. 3 and April 10, 2053 for Turkey Point 16 Unit No. 4. 17 Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 51.20(b)(2), the renewal of a 18 power reactor operating license requires preparation of an environmental impact 19 statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c), Operating 20 License Renewal Stage, states that, in connection with the renewal of an operating license, the 21 NRC shall prepare an EIS, which is a supplement to the Commissions NUREG-1437, Generic 22 Environmental Impact Statement for License Renewal of Nuclear Plants. 23 Once the NRC officially accepted FPLs application, the NRC staff began the environmental 24 review process as described in 10 CFR Part 51, Environmental Protection Regulations for 25 Domestic Licensing and Related Regulatory Functions. The environmental review begins by 26 the NRC publishing a notice of intent in the Federal Register to prepare a supplemental 27 environmental impact statement (SEIS) and to conduct environmental scoping. To prepare the 28 Turkey Point SEIS, the NRC staff performed the following: 29

• conducted two public scoping meetings on May 31, 2018, near the Turkey Point site in 30 Homestead, FL 31
• conducted a severe accident mitigation alternatives in-office audit in Rockville, MD, from 32 July 5 to July 13, 2018, and an onsite environmental audit at Turkey Point from 33 June 19 to July 22, 2018 34
• reviewed FPLs environmental report (ER) and compared it to NUREG-1437, Generic 35 Environmental Impact Statement for License Renewal of Nuclear Plants (the GEIS) 36
• consulted with Federal, State, Tribal, and local government agencies 37
• conducted a review of the issues following the guidance set forth in 38 NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental 39 Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal, Final 40 Report 41
• considered public comments received xv

1 Proposed Action 2 FPL initiated the proposed Federal action (i.e., issuance of renewed facility operating licenses) 3 by submitting an application for subsequent license renewal of Turkey Point. The existing 4 Turkey Point renewed facility operating licenses expire at midnight on July 19, 2032, for 5 Unit No. 3 (DPR-31) and April 10, 2033, for Unit No. 4 (DPR-41). The NRCs Federal action is 6 to decide whether to issue renewed licenses authorizing an additional 20 years of operation. If 7 the NRC issues the renewed licenses, Turkey Point Unit Nos. 3 and 4 would be authorized to 8 operate until July 19, 2052 and April 10, 2053, respectively. The regulation at 10 CFR 2.109, 9 Effect of Timely Renewal Application, states that if a licensee of a nuclear power plant files an 10 application for renewal of an operating license at least 5 years before the expiration of the 11 existing license, the existing license will not be deemed to have expired until the NRC staff 12 completes its safety and environmental reviews of the application, and the NRC makes a final 13 decision on whether to issue a renewed license for the additional 20 years. 14 Purpose and Need for Proposed Action 15 The purpose and need for the proposed action (i.e., issuance of renewed licenses) is to provide 16 an option that allows for power generation capability beyond the term of the current nuclear 17 power plant operating licenses to meet future system generating needs. Energy-planning 18 decisionmakers such as States, utility operators, and, where authorized, Federal agencies 19 (other than the NRC) may determine these future system generating needs. The Atomic Energy 20 Act of 1954, as amended, and the National Environmental Policy Act of 1969, as amended, 21 require the NRC to perform a safety review and an environmental review of the proposed action. 22 The above definition of purpose and need reflects the NRCs recognition that, unless there are 23 findings in the safety review or in the environmental review that would lead the NRC to reject a 24 license renewal application, the NRC does not have a role in the energy-planning decisions as 25 to whether a particular nuclear power plant should continue to operate. 26 Environmental Impacts of License Renewal 27 This SEIS evaluates the potential environmental impacts of the proposed action. The NRC 28 designates the environmental impacts from the proposed action as SMALL, MODERATE, or 29 LARGE. NUREG-1437, Generic Environmental Impact Statement for License Renewal of 30 Nuclear Plants (the GEIS), evaluates 78 environmental issues related to plant operation and 31 classifies each issue as either a Category 1 issue (generic to all or a distinct subset of nuclear xvi

1 power plants) or a Category 2 issue (specific to individual power plants). Category 1 issues are 2 those that meet all the following criteria: 3

• The environmental impacts associated with the issue SMALL: Environmental effects 4 apply either to all plants or, for some issues, to plants are not detectable or are so 5 having a specific type of cooling system or other specified minor that they will neither 6 plant or site characteristics. destabilize nor noticeably alter any important attribute of the 7
• A single significance level (i.e., SMALL, MODERATE, or resource.

MODERATE: Environmental 8 LARGE) has been assigned to the impacts except for effects are sufficient to alter 9 collective offsite radiological impacts from the fuel cycle noticeably, but not to destabilize, 10 and from high-level waste and spent fuel disposal. important attributes of the resource. 11

• Mitigation of adverse impacts associated with the issue is LARGE: Environmental effects 12 considered in the analysis, and it has been determined are clearly noticeable and are 13 that additional plant-specific mitigation measures are sufficient to destabilize important attributes of the resource.

14 likely not to be sufficiently beneficial to warrant 15 implementation. 16 For Category 1 issues, no additional site-specific analysis is required in this SEIS unless new 17 and significant information is identified. For most issues, the NRC staff did not identify any new 18 and significant information during its review of Florida Power & Light Companys (FPLs) 19 environmental report, the site audits, or the scoping period that would change the conclusions in 20 the GEIS. Therefore, there are no impacts related to these Category 1 issues beyond those 21 already discussed in the GEIS. 22 Category 2 issues are site-specific issues that do not meet one or more of the criteria for 23 Category 1 issues; therefore, a SEIS must include additional site-specific review for these 24 non-generic issues. In this SEIS, the NRC staff evaluated Category 2 issues applicable to 25 Turkey Point, as well as cumulative impacts and considered new information regarding severe 26 accident mitigation alternatives (SAMAs). 27 The NRC staff identified and evaluated new and potentially significant information for two 28 existing Category 1 issues (i.e., groundwater quality degradation (plants with cooling ponds in 29 salt marshes) and cooling system impacts on terrestrial resources (plants with once-through 30 cooling systems or cooling ponds)). In addition, the NRC staff identified and evaluated one new 31 issue not categorized as Category 1 or 2 (i.e., water quality impacts on adjacent water bodies 32 (plants with cooling ponds in salt marshes)). As described in Chapter 4 of this SEIS, the 33 impacts of each of these issues is SMALL. Chapter 4 also presents the process for identifying 34 new and significant information. 35 Table ES-1 summarizes the Category 2 issues relevant to Turkey Point and the NRC staffs 36 findings related to those issues. If the NRC staff determined that there were no Category 2 37 issues applicable for a particular resource area, the findings of the GEIS, as documented in 38 Appendix B to Subpart A, Environmental Effect of Renewing the Operating License of a 39 Nuclear Power Plant, of 10 CFR Part 51, are incorporated for that resource area. xvii

1 Table ES-1 Summary of NRC Conclusions Relating to Site-Specific Impacts of 2 Subsequent License Renewal at Turkey Point Resource Area Relevant Category 2 Issues Impacts Groundwater Resources - Groundwater use conflicts (plants that SMALL to MODERATE withdraw more than 100 gallons per minute)

                                  - Radionuclides released to groundwater         SMALL Terrestrial Resources            - Effects on terrestrial resources (non-cooling SMALL system impacts)

Aquatic Resources - Impingement and entrainment of aquatic SMALL to MODERATE organisms (plants with once-through cooling systems or cooling ponds)

                                  - Thermal impacts on aquatic organisms          SMALL to MODERATE (plants with once-through cooling systems or cooling ponds)

Special Status Species and - Threatened, endangered, and protected Likely to adversely affect the Habitats species and essential fish habitat American crocodile and eastern indigo snake May affect, but is not likely to adversely affect or no effect to all other species May result in adverse modification to American crocodile critical habitat No adverse modification to West Indian manatee critical habitat No adverse effects on Essential Fish Habitat Historic and Cultural - Historic and cultural resources Would not adversely affect known Resources historic properties or historic and cultural resources Human Health - Electric shock hazards SMALL Environmental Justice - Minority and low-income populations No disproportionately high and adverse human health and environmental effects Cumulative Impacts - Cumulative Impacts See SEIS Section 4.16 3 Alternatives 4 As part of its environmental review, the NRC is required to consider alternatives to license 5 renewal and to evaluate the environmental impacts associated with each alternative. These 6 alternatives can include other methods of power generation (replacement power alternatives), 7 as well as not renewing the Turkey Point operating licenses (the no-action alternative). 8 In total, the NRC staff initially considered 16 replacement power alternatives; the NRC staff later 9 dismissed 13 of these because of technical, resource availability, or commercial limitations that xviii

1 currently exist and that the NRC staff believes are likely to still exist when the current Turkey 2 Point licenses expire. 3 This left three feasible and commercially viable replacement power alternatives which, in 4 addition to the no-action alternative, the staff evaluates in depth in this report: 5

• new nuclear power 6
• natural gas combined-cycle 7
• combination alternative: natural gas combined-cycle and solar photovoltaic (PV) 8 These are the 13 additional alternatives that the NRC staff considered but ultimately dismissed:

9

• solar power 10
• wind power 11
• biomass power 12
• demand-side management 13
• hydroelectric power 14
• geothermal power 15
• wave and ocean energy 16
• municipal solid waste 17
• petroleum-fired power 18
• coal (integrated gasification combined-cycle) 19
• fuel cells 20
• purchased power 21
• delayed retirement of nearby generating facilities 22 The NRC staff evaluated the environmental impacts of each replacement power alternative, 23 using the same resource areas that it used in evaluating the impacts from subsequent license 24 renewal. In addition, this SEIS evaluates the environmental impacts of an alternative 25 closed-cycle cooling water system, which might be used to mitigate potential impacts associated 26 with the continued use of the existing cooling canal system. Finally, this SEIS evaluates any 27 new and significant information that could alter the conclusions of the SAMA analysis that was 28 performed previously, in connection with the initial license renewal of Turkey Point 29 Unit Nos. 3 and 4.

30 Preliminary Recommendation 31 The NRC staffs preliminary recommendation is that the adverse environmental impacts of 32 subsequent license renewal for Turkey Point are not so great that preserving the option of 33 license renewal for energy-planning decisionmakers would be unreasonable. The NRC staff 34 based its recommendation on the following: 35

• the analysis and findings in NUREG-1437, Generic Environmental Impact Statement 36 for License Renewal of Nuclear Plants 37
• the environmental report submitted by FPL 38
• the NRC staffs consultation with Federal, State, Tribal, and local government agencies 39
• the NRC staffs independent environmental review 40
• the NRC staffs consideration of public comments xix

1 ABBREVIATIONS AND ACRONYMS

 °C         degree(s) Celsius
 °F         degree(s) Fahrenheit
 µg/m3      micrograms per cubic meter AADT       average annual daily traffic ac         acre(s)

ACHP Advisory Council on Historic Preservation ACR Atlantic Coastal Ridge ADAMS Agencywide Documents Access and Management System AEA Atomic Energy Act of 1954 (as amended) ALARA as low as reasonable achievable APE Area of Potential Affects AQCR Air Quality Control Region ARB Homestead Air Reserve Base ASLB Atomic Safety and Licensing Board BLM Bureau of Land Management bls below land surface BMPs best management practices CAA Clean Air Act CCS cooling canal system CCW component cooling water CDMP Comprehensive Master Development Plan CEQ Council on Environmental Quality CERP Comprehensive Everglades Restoration Plan CFR Code of Federal Regulations cfs cubic foot (feet) per second CH4 methane CO carbon monoxide CO2 carbon dioxide CO2/MWh carbon dioxide per megawatt hour CO2eq carbon dioxide equivalents COL combined license CVCS chemical and volume control system CWA Clean Water Act CZMA Coastal Zone Management Act dBA A-weighted decibels xxi

DERM Miami-Dade County Division of Environmental Resource Management DOE U.S. Department of Energy DOH Florida Department of Health DPS distinct population segment EAI Ecological Associates, Inc. EB Encyclopedia Britannica ECFAS2 East Coast Floridan Aquifer System Model - Phase 2 ECOS Environmental Conservation Online System EFH essential fish habitat EIA Energy Information Administration EIS environmental impact statement ELF-EMF extremely low frequency-electromagnetic field EO Executive Order EPA U.S. Environmental Protection Agency ER Environmental Report ESA Endangered Species Act of 1973, as amended FAC Florida Administrative Code FDACS Florida Department of Agriculture and Consumer Services FDEP Florida Department of Environmental Protection FDOT Florida Department of Transportation FE federally listed as endangered FEIS final environmental impact statement FFWCC Florida Fish and Wildlife Conservation Commission FLDOE Florida Department of Education FPL Florida Power & Light fps feet per second FR Federal Register FRN Federal Register notice ft foot (feet) FT federally listed as threatened ft3 cubic foot (feet) FWS U.S. Fish and Wildlife Service g gram(s) gal gallon(s) GEIS generic environmental impact statement GHG Greenhouse Gases gpd gallon(s) per day gpm gallon(s) per minute GT gigatons GWP global warming potential xxii

H2O water vapor ha hectare(s) HAP Hazardous Air Pollutant HFC hydrofluorocarbons HIC high integrity container ICW intake cooling water IPaC Information for Planning and Conservation IPCC Intergovernmental Panel on Climate Change ISFSI independent spent fuel storage installation IWW industrial wastewater kg kilogram(s) km kilometer(s) kW kilowatt(s) kWe kilowatt(s) electric L/min liter(s) per minute lb pound(s) LLRW Low-level radioactive waste LLW low level waste Lpd liters per day LRA license renewal application m meter(s) m/s meter(s) per second m3/day cubic meters per day m3/s cubic meter(s) per second MBTA Migratory Bird Treaty Act MDC Miami-Dade County MDWSD Miami-Dade Water and Sewer Department mgd million gallons per day mgy million gallons per year mi mile(s) min minute(s) MMT million metric tons mph mile(s) per hour MSA Magnuson-Stevens Fishery Conservation and Management Act MSL mean sea level mSv millisievert MT metric ton(s) MW megawatt(s) MWe megawatt(s) electric MWh megawatt hour(s) xxiii

MWt megawatt(s) thermal N2O nitrous oxide NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act of 1969, as amended NESHAP National Emission Standards for Hazardous Air Pollutants NGCC natural gas combined-cycle NHPA National Historic Preservation Act of 1966, as amended NIEHS National Institute of Environmental Health Sciences NMFS National Marine Fisheries Service (of the National Oceanic and Atmospheric Administration) NO2 nitrogen dioxide NOV notice of violation NOx nitrogen oxide(s) NPDES National Pollutant Discharge Elimination System NPS National Park Service NRC U.S. Nuclear Regulatory Commission NRHP National Register of Historic Places O3 ozone ODCM offsite dose calculation manual OSHA Occupational Safety and Health Administration Pb lead PFC perfluorocarbons PM particulate matter PM10 particulate matter diameter between 2.5 and 10 micrometers PM2.5 particulate matter diameter of 2.5 micrometers or less ppb parts per billion ppm parts per million PPSA Power Plant Siting Act ppt parts per thousand PRA probabilistic risk assessment PSD Prevention of Significant Deterioration PSU Practical Salinity Unit PV photovoltaic PWR pressurized water reactor RCS reactor coolant system REMP radiological environmental monitoring program RICE reciprocating internal combustion engines ROI region of influence RWS recovery well system RWST refueling water storage tank xxiv

SAMA severe accident mitigation alternative SAT federally listed due to similarity of appearance to another listed species SDWA Safe Drinking Water Act SDWWTP Miami-Dade County South District Waste Water Treatment Plant SEIS supplemental environmental impact statement SER safety evaluation report SF6 sulfur hexafluoride SFRCCC Southeast Florida Regional Climate Change Compact SFWMD South Florida Water Management District SIP State implementation plan SLRA subsequent license renewal application SO2 sulfur dioxide SPCC Spill Prevention, Control, and Countermeasure SSC structure, system, and component Sv sievert TDS total dissolved solids Turkey Point Turkey Point Nuclear Generating Unit Nos. 3 and 4 U.S. United States UF University of Florida UFA Upper Floridan aquifer UFSAR updated final safety analysis report USCB U.S. Census Bureau USCG U.S. Coast Guard USDOT U.S. Department of Transportation USGCRP U.S. Global Change Research Program USGS U.S. Geological Survey VOC Volatile Organic Compounds WHT waste holdup tanks yd3 cubic yard(s) g microgram m micrometer xxv

1 1 INTRODUCTION 2 The U.S. Nuclear Regulatory Commissions (NRCs) environmental protection regulations in 3 Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental Protection 4 Regulations for Domestic Licensing and Related Regulatory Functions, implement the National 5 Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.). This Act is commonly 6 referred to as NEPA. The regulations at 10 CFR Part 51 require the NRC to prepare an 7 environmental impact statement (EIS) before making a decision on whether to issue an 8 operating license or a renewed operating license for a nuclear power plant. 9 The Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.), specifies that licenses 10 for commercial power reactors can be granted for up to 40 years. The initial 40-year licensing 11 period was based on economic and antitrust considerations rather than on technical limitations 12 of the nuclear facility. NRC regulations permit these licenses to be renewed beyond the initial 13 40-year term for an additional period of time, limited to 20-year increments per renewal, based 14 on the results of an assessment to determine whether the nuclear facility can continue to 15 operate safely during the proposed period of extended operation. There are no limitations in the 16 AEA or NRC regulations restricting the number of times a license may be renewed. 17 The decision to seek a renewed license rests entirely with nuclear power facility owners and 18 typically is based on the facilitys economic viability and the investment necessary to continue to 19 meet NRC safety and environmental requirements. The NRC makes the decision to grant or 20 deny a renewed license based on whether the applicant has demonstrated reasonable 21 assurance that it can meet the environmental and safety requirements in the agencys 22 regulations during the period of extended operation. 23 1.1 Proposed Federal Action 24 Florida Power & Light Company (FPL) initiated the proposed Federal action by submitting an 25 application for subsequent license renewal for Turkey Point Nuclear Generating 26 Unit Nos. 3 and 4 (Turkey Point or Turkey Point Units 3 and 4). The current renewed licenses 27 expire at midnight on July 19, 2032, for Unit No. 3 (DPR-31) and at midnight on April 10, 2033, 28 for Unit No. 4 (DPR-41). The NRCs Federal action is to decide whether to issue renewed 29 licenses for an additional 20 years. 30 1.2 Purpose and Need for the Proposed Federal Action 31 The purpose and need for the proposed Federal action (issuance of subsequent renewed 32 licenses for Turkey Point Unit Nos. 3 and 4) is to provide an option that allows for power 33 generation capability beyond the term of the current renewed nuclear power plant operating 34 licenses to meet future system generating needs. Such needs may be determined by 35 energy-planning decisionmakers such as State regulators, utility owners, and Federal agencies 36 other than the NRC. This definition of purpose and need reflects the NRCs recognition that, 37 unless there are findings in the NRCs safety review (required by the Atomic Energy Act) or 38 findings in the NRCs environmental analysis (required by NEPA) that would lead the NRC to 39 reject a subsequent license renewal application, the NRC does not have a role in 40 energy-planning decisions as to whether a particular nuclear power plant should continue to 41 operate. 1-1

1 1.3 Major Environmental Review Milestones 2 FPL submitted an environmental report (ER) (FPL 2018f) as an appendix to its subsequent 3 license renewal application (SLRA) on January 30, 2018 (FPL 2018a). After reviewing the 4 SLRA and environmental report, as supplemented on February 9 (FPL 2018b), February 16 5 (FPL 2018c), March 1 (FPL 2018d), and April 10, 2018 (FPL 2018e), the NRC staff accepted 6 the application for a detailed technical review on April 26, 2018 (NRC 2018a). On May 2, 2018, 7 the NRC staff published a Federal Register notice of acceptability and opportunity for hearing 8 (Volume 83 of the Federal Register (FR), page 19304 (83 FR 19304)). On May 22, 2018, the 9 NRC published another notice in the Federal Register (83 FR 23726) informing members of the 10 public of the staffs intent to conduct an environmental scoping process, thereby beginning a 11 30-day scoping comment period. 12 The NRC staff held two public scoping meetings on May 31, 2018, near the Turkey Point site in 13 Homestead, FL. In January 2019, the NRC issued its Supplemental Environmental Impact 14 Statement Scoping Process Summary Report, Turkey Point Nuclear Generating Unit 15 Nos. 3 and 4, Miami-Dade County, Florida, which includes the comments received during the 16 scoping process and the NRC staffs responses to those comments (NRC 2019). 17 To independently verify information that FPL provided in its environmental report, the NRC staff 18 conducted an onsite audit at Turkey Point in June 2018, and an in-office severe accident 19 mitigation alternatives audit at NRC headquarters in July 2018. In a letter dated July 20, 2018, 20 the staff summarized the onsite audit and listed the attendees (NRC 2018c). In a letter dated 21 August 31, 2018, the staff summarized the in-office severe accident mitigation alternatives audit 22 and listed the attendees (NRC 2018d). During these audits, the NRC staff held meetings with 23 plant personnel, reviewed site-specific documentation, toured the facility, and held a 24 government-to-government meeting hosted by the U.S. National Park Service. 25 Upon completion of the scoping period and audits, and completion of its review of FPLs 26 environmental report and related documents, the NRC staff compiled its findings in this draft 27 supplemental environmental impact statement (SEIS). The NRC staff will make this draft SEIS 28 available for public comment for 45 days. Based on the information gathered during this public 29 comment period, the NRC staff will amend the draft SEIS findings, as necessary, and will then 30 publish the final SEIS. Figure 1-1 shows the major milestones of the environmental review 31 portion of the NRCs subsequent license renewal application review process. 1-2

1 Figure 1-1 Environmental Review Process 2 The NRC has established a license renewal process that can be completed in a reasonable 3 period of time and that includes clear requirements to assure safe plant operation for up to an 4 additional 20 years of plant life. This process consists of separate environmental and safety 5 reviews, which the NRC staff conducts simultaneously and documents in two reports: (1) the 6 SEIS documents the environmental review and (2) the safety evaluation report (SER) 7 documents the safety review. The staffs findings in the SEIS and the SER are both factors in 8 the NRCs decision to grant or deny the issuance of a renewed license. This process is used for 9 both initial and subsequent license renewal. 10 1.4 Generic Environmental Impact Statement 11 To improve the efficiency of its license renewal review process, the NRC staff performed a 12 generic assessment of the environmental impacts associated with license renewal. 13 NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 14 Power Plants (known as the GEIS) (NRC 1996, NRC 1999, NRC 2013a), documents the 15 results of the NRCs systematic approach to evaluating the environmental consequences of 16 renewing the licenses of individual nuclear power plants and operating them for an additional 17 20 years. In the GEIS, the staff analyzed in detail and resolved those environmental issues that 18 could be resolved generically. The NRC issued the GEIS in 1996 (NRC 1996), Addendum 1 to 19 the GEIS in 1999 (NRC 1999), and Revision 1 to the GEIS in 2013 (NRC 2013a). Unless 20 otherwise noted, all references to the GEIS include the original 1996 GEIS, Addendum 1, and 21 the 2013 revision. The conclusions in the GEIS apply to both initial and subsequent license 22 renewal. 23 The GEIS establishes separate environmental impact issues for the NRC staff to independently 24 evaluate. Appendix B to Subpart A of 10 CFR Part 51, Environmental Effect of Renewing the 1-3

1 Operating License of a Nuclear Power Plant, provides a summary of the staffs findings in the 2 GEIS. For each environmental issue addressed in the GEIS, the NRC staff: 3

• describes the activity that affects the environment 4
• identifies the population or resource that is affected 5
• assesses the nature and magnitude of the impact on the affected population or resource 6
• characterizes the significance of the effect for both beneficial and adverse effects 7
• determines whether the results of the analysis apply to all plants 8
• considers whether additional mitigation measures would be warranted for impacts that 9 would have the same significance level for all plants 10 The NRC established its standard of significance for impacts using the Council on 11 Environmental Quality terminology for significant. The NRC established three levels of 12 significance for potential impactsSMALL, MODERATE, and LARGEas defined below.

13 SMALL: Environmental effects are not detectable or Significance indicates the importance 14 are so minor that they will neither destabilize nor of likely environmental impacts and is 15 noticeably alter any important attribute of the determined by considering two 16 resource. variables: context and intensity. 17 MODERATE: Environmental effects are sufficient to Context is the geographic, 18 alter noticeably, but not to destabilize, important biophysical, and social context in 19 attributes of the resource. which the effects will occur. Intensity refers to the severity of the 20 LARGE: Environmental effects are clearly impact in whatever context it occurs. 21 noticeable and are sufficient to destabilize important 22 attributes of the resource. 23 The GEIS includes a determination of whether the analysis of the environmental issue could be 24 applied to all plants (or a distinct subset of plants, as defined in the GEIS) and whether 25 additional mitigation measures would be warranted. Issues are assigned a Category 1 (generic 26 to all or a subset of plants) or Category 2 (site-specific) designation. As established in the 27 GEIS, Category 1 issues are those that meet the following three criteria: 28

• The environmental impacts associated with the issue have been determined to apply 29 either to all plants or, for some issues, to plants that have a specific type of cooling 30 system or other specified plant or site characteristics.

31

• A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 32 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 33 high-level waste and spent fuel disposal).

34

• Mitigation of adverse impacts associated with the issue has been considered in the 35 analysis, and it has been determined that additional plant-specific mitigation measures 36 are likely not to be sufficiently beneficial to warrant implementation.

37 For generic issues (Category 1), the SEIS requires no additional site-specific evaluation unless 38 new and significant information has been identified. Chapter 4 of this report describes the 1-4

1 process for identifying new and significant information for site-specific analysis. Site-specific 2 issues (Category 2) are those that do not meet the three criteria of Category 1 issues; therefore, 3 the SEIS requires additional site-specific review for these issues. 4 The 2013 GEIS evaluates 78 environmental issues, provides generically applicable findings for 5 numerous issues (subject to the consideration of any new and significant information on a 6 site-specific basis), and concludes that a site-specific analysis is required for 17 of the 7 78 issues. Figure 1-2 illustrates the license renewal environmental review process. The results 8 of that site-specific review are documented in the SEIS. 9 Figure 1-2 Environmental Issues Evaluated for License Renewal 10 1.5 Supplemental Environmental Impact Statement 11 This SEIS presents the NRC staffs analysis of the environmental effects of the continued 12 operation of Turkey Point through the subsequent license renewal period, alternatives to 13 subsequent license renewal, and mitigation measures for minimizing adverse environmental 14 impacts. Chapter 4, Environmental Consequences and Mitigating Actions, contains an 15 analysis and comparison of the potential environmental impacts from subsequent license 16 renewal and alternatives to subsequent license renewal. Chapter 5, Conclusion, presents the 17 NRCs recommendation on whether the environmental impacts of subsequent license renewal 18 are so great that preserving the option of subsequent license renewal would be unreasonable. 19 The NRC staff will make its final recommendation to the Commission on Turkey Point 1-5

1 subsequent license renewal in the final SEIS, which the NRC staff will issue after considering 2 comments received on the draft SEIS during the public comment period. 3 In the preparation of the Turkey Point draft SEIS, the NRC staff carried out the following 4 activities: 5

• reviewed the information provided in FPLs environmental report 6
• consulted with Federal, State, Tribal, and local government agencies 7
• conducted an independent environmental review, including the environmental and 8 severe accident mitigation analysis site audits 9
• considered public comments 10 New information can come from many sources, 11 including the applicant, the NRC, other agencies, New and significant information. To merit 12 or public comments. If the information reveals a additional review, information must be 13 new issue, the staff will first analyze the issue to both new and significant and it must bear 14 determine whether it is within the scope of the on the proposed action or its impacts.

15 license renewal environmental evaluation. If the 16 staff determines that the new issue bears on the 17 proposed action, the staff will then determine the significance of the issue for the plant and 18 analyze the issue in the SEIS, as appropriate. 19 1.6 Decisions To Be Supported by the SEIS 20 This SEIS supports the NRCs decision on whether to issue renewed operating licenses for 21 Turkey Point for an additional 20 years. The regulation at 10 CFR 51.103(a)(5) specifies the 22 NRCs decision standard as follows: 23 In making a final decision on a license renewal action pursuant to Part 54 of this 24 chapter [10 CFR], the Commission shall determine whether or not the adverse 25 environmental impacts of license renewal are so great that preserving the option 26 of license renewal for energy planning decisionmakers would be unreasonable. 27 There are many factors that the NRC takes into consideration when deciding whether to renew 28 the operating license of a nuclear power plant. The analyses of environmental impacts in this 29 SEIS will provide the NRCs decisionmaker (in this case, the Commission) with important 30 environmental information for use in the overall decisionmaking process. Other decisions are 31 made outside the regulatory scope of license renewal, by the NRC or other decisionmakers. 32 These include decisions related to: (1) changes to plant cooling systems, (2) disposition of spent 33 nuclear fuel, (3) emergency preparedness, (4) safeguards and security, (5) need for power, and 34 (6) seismicity and flooding (NRC 2013a). 35 1.7 Cooperating Agencies 36 The U.S. National Park Service, Southeast Region (NPS), is participating in the environmental 37 review of subsequent license renewal for Turkey Point as a cooperating agency. The NPS does 38 not have any specific regulatory actions related to the proposed subsequent license renewal; 39 however, NPS is providing special expertise for environmental issues pertaining to the areas in 40 and around Biscayne National Park, which is located next to the Turkey Point site. In a letter 1-6

1 dated March 5, 2019, the NPS provided comments to the NRC staff on preliminary sections of 2 the draft SEIS discussing water resources, terrestrial resources, aquatic resources, and special 3 status species and habitats (NPS 2019). 4 1.8 Consultations 5 The Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) (ESA); the 6 Magnuson-Stevens Fishery Conservation and Management Act of 1996, as amended 7 (16 U.S.C. 1801 et seq.) (MSA); and the National Historic Preservation Act of 1966, as 8 amended (54 U.S.C. 300101 et seq.) (NHPA), require Federal agencies to consult with 9 applicable State and Federal agencies and organizations before taking an action that may affect 10 endangered species, fisheries, or historic and archaeological resources, respectively. The NRC 11 staff consulted with the following agencies and organizations during this environmental review: 12

• U.S. Fish and Wildlife Service 13
• Miami-Dade County Office of Historic Preservation 14
• Miccosukee Tribe of Indians of Florida 15
• Muscogee (Creek) Nation 16
• Poarch Band of Creek Indians 17
• The Seminole Nation of Oklahoma 18
• Seminole Tribe of Florida 19
• Florida Department of State, Division of Historical Resources 20
• Federal Advisory Council on Historic Preservation 21 Appendix C, Consultation Correspondence, of this SEIS discusses the consultations that the 22 NRC staff conducted in support of this environmental review.

23 In addition, on June 18, 2018, the NRC staff participated in an interagency meeting related to 24 the proposed subsequent license renewal action. Participating Federal, State, and local 25 agencies included the National Park Service (NPS), U.S. Environmental Protection Agency 26 (EPA), U.S. Fish and Wildlife Service (FWS), National Oceanic and Atmospheric Administration 27 (NOAA), Florida Department of Environmental Protection (FDEP), and Miami-Dade County 28 Division of Environmental Resources Management (DERM). The primary goals of the meeting 29 included the following: 30

• Provide an overview of NRCs environmental review process related to FPLs application 31 to renew the operating licenses at Turkey Point.

32

• Gather input from other Federal, State, and local agencies regarding available 33 environmental data and issues.

34 During the meeting, the NRC staff provided an overview of the subsequent license renewal 35 process, several agencies presented environmental data and issues related to Turkey Point, 36 and lastly, participants held a general discussion related to the environmental review 37 (NRC 2018l). Information provided by the meeting participants has been considered by the 38 NRC staff in preparing this SEIS. 39 1.9 Correspondence 40 During the course of the environmental review, the NRC staff contacted Federal, State, regional, 41 local, and Tribal government agencies listed in Section 1.8 above. Appendix C, Consultation 1-7

1 Correspondence, chronologically lists all correspondence the NRC staff sent and received 2 during its environmental review, associated with the ESA, the MSA, and the NHPA. 3 Appendix D, Chronology of Environmental Review Correspondence, chronologically lists all 4 other correspondence. 5 1.10 Status of Compliance 6 FPL is responsible for complying with all NRC regulations and other applicable Federal, State, 7 and local requirements. Appendix F of the GEIS describes some of the major applicable 8 Federal statutes. Numerous permits and licenses are issued by Federal, State, and local 9 authorities for activities at Turkey Point. Appendix B of this SEIS contains further information 10 about FPLs status of compliance. 11 1.11 Related State and Federal Activities 12 The NRC reviewed the possibility that activities of other Federal agencies might affect the 13 renewal of the operating licenses for Turkey Point. There are no Federal projects that would 14 make it necessary for another Federal agency to become a cooperating agency in the 15 preparation of this SEIS. 16 Two Indian reservations, the Miccosukee Indian Reservation (approximately 47 miles (75 km) 17 northwest of Turkey Point) and the Seminole Tribe of Florida, Hollywood Reservation 18 (approximately 43 mi (68 km) north of Turkey Point), are located with 50 miles (80 km) of 19 Turkey Point. The area surrounding the Turkey Point site is low, swampy, and sparsely 20 populated. The Turkey Point site is adjacent to waters and coastal lands that are part of the 21 Biscayne National Park and is within 2 miles (3.2 km) of the Model Lands Basin, a South Florida 22 Water Management District conservation area. A portion of the Biscayne Bay Aquatic Preserve 23 is located immediately east of the Turkey Point site, and a separate portion of the preserve, 24 along with the Florida Keys National Marine Sanctuary, is located adjacent to the 25 south-southeastern border of the Turkey Point site boundary. The Turkey Point site is also 26 located just east of the 13,000-acre Everglades Mitigation Bank. The Homestead Bayfront Park, 27 a city park, is located approximately 2 miles (3.2 km) north-northwest of Turkey Point. 28 (FPL 2018f) 29 Section 102(2)(C) of NEPA requires the NRC to consult with and obtain the comments of any 30 Federal agency that has jurisdiction by law or special expertise with respect to any 31 environmental impact involved in the subject matter of the SEIS. In accordance with this 32 requirement, during the course of preparing the SEIS, the NRC consulted, for example, with the 33 U.S. Fish and Wildlife Service. Appendix C provides a complete list of consultation 34 correspondence. 1-8

1 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION 2 The U.S. Nuclear Regulatory Commissions (NRCs) decisionmaking authority for subsequent 3 license renewal focuses on deciding whether or not to issue a subsequent renewed operating 4 license to a nuclear power plant. The agencys implementation of the National Environmental 5 Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.) (NEPA), requires the NRC to consider 6 potential alternatives to issuing a subsequent renewed operating license as well as the 7 environmental impacts of these alternatives. Considering the environmental impacts of 8 subsequent license renewal and comparing those impacts to the environmental impacts of 9 alternatives allows the NRC to determine whether the environmental impacts of subsequent 10 license renewal are so great that it would be unreasonable for the agency to preserve the option 11 of subsequent license renewal for energy-planning decisionmakers (Title 10 of the Code of 12 Federal Regulations (10 CFR) 51.95(c)(4)). Ultimately, decisionmakers such as the plant 13 operator, State, or non-NRC Federal officials will decide whether to carry out the proposed 14 action and continue operating the plant for an additional 20 years (if the NRC renews the 15 license) or shut down the plant and choose an alternative power generation source. Economic 16 and environmental considerations play important roles in the decisions of these non-NRC 17 energy-planning decisionmakers. 18 In general, the NRCs responsibility is to ensure the safe operation of nuclear power facilities, 19 not to formulate energy policy, promote nuclear power, or encourage or discourage the 20 development of alternative power generation sources. The NRC does not engage in 21 energy-planning decisions, and it makes no judgment as to which energy alternatives evaluated 22 in the SEIS would be the best or most-likely alternative to be selected in any given case. 23 This chapter provides (1) a description of the proposed action (i.e., subsequent renewal of the 24 operating licenses for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point, or 25 Turkey Point Units 3 and 4)), (2) an in-depth evaluation of reasonable alternatives to the 26 proposed action (including the no-action alternative), and (3) a brief description of the 27 alternatives to the proposed action that the NRC staff considered but ultimately eliminated from 28 in-depth evaluation. 29 2.1 Proposed Action 30 As stated in Section 1.1 of this document, the NRCs proposed Federal action is to decide 31 whether to renew the Turkey Point operating licenses for an additional 20 years. To evaluate 32 the environmental impacts from the continued operation of Turkey Point, the staff will begin with 33 an overview of the facility and the facilitys operations, and then consider the affected 34 environment and potential impacts to the affected environment. 35 Section 2.1.1 below provides a description of normal power plant operations during the 36 subsequent license renewal term. In brief, Turkey Point is a two-unit, nuclear-powered, 37 steam-electric generating facility that began commercial operation in December 1972 (Unit 3) 38 and September 1973 (Unit 4). The nuclear reactors are both Westinghouse pressurized-water 39 reactors (PWRs) and have a combined generating capacity of 1,632 megawatts electric (MWe). 40 Operating at an average capacity factor of 92 percent, the reactors provide approximately 41 1,500 MWe of net generation (FPL 2018f). 2-1

1 2.1.1 Plant Operations during the Subsequent License Renewal Term 2 Most plant operation activities during the subsequent license renewal term would be the same 3 as, or similar to, those occurring during the current renewed license term. NUREG-1437, 4 Volume 1, Revision 1, Generic Environmental Impact Statement for License Renewal of 5 Nuclear Plants, (NRC 2013a) (also known as the GEIS) describes the issues that would have 6 the same impact at all nuclear power plants (or a distinct subset of plants, as defined in the 7 GEIS) (i.e., generic issues) as well as those issues that may have different impact levels at 8 different nuclear power plants (i.e., site-specific issues). The impacts of generic issues are 9 described in NUREG-1437 as Category 1 issues; those impacts are set out in NUREG-1437 10 and Table B-1 of 10 CFR Part 51, Appendix B, and those determinations apply to each license 11 renewal application, subject to the consideration of any new and significant information on a 12 plant-specific basis. A second group of issues (Category 2) was identified in NUREG-1437 as 13 having potentially different impacts at each plant, on a site-specific basis; those issues with 14 plant-specific impact levels need to be discussed in a plant-specific supplemental environmental 15 impact statement (SEIS) to the GEIS, like this one. 16 Section 2.1.1 of the GEIS, Plant Operations during the License Renewal Term, describes the 17 general types of activities that are carried out during the operation of all nuclear power plants. 18 These general types of activities include the following: 19

• reactor operations 20
• waste management 21
• security 22
• office and clerical work 23
• laboratory analysis 24
• surveillance, monitoring, and maintenance refueling and other outages 25 As part of its subsequent license renewal application, Florida Power & Light Company (FPL) 26 submitted an environmental report. FPLs environment report states that Turkey Point will 27 continue to operate during the subsequent license renewal term in the same manner as it would 28 during the current license term with the exception of additional aging management programs to 29 address structure and component aging in accordance with 10 CFR Part 54, Requirements for 30 Renewal of Operating Licenses for Nuclear Power Plants.

31 2.1.2 Refurbishment and Other Activities Associated with Subsequent License Renewal 32 Refurbishment activities include replacement and repair of major structures, systems, and 33 components. The major refurbishment class of activities characterized in the GEIS is intended 34 to encompass actions that typically take place only once in the life of a nuclear plant, if at all 35 (NRC 2013a). For example, replacement of pressurized-water reactor steam generator 36 systems is a refurbishment activity. Refurbishment activities may have an impact on the 37 environment beyond those that occur during normal operations and may require evaluation, 38 depending on the type of action and the plant-specific design. 39 In preparation for its license renewal application, FPL evaluated major structures, systems, and 40 components in accordance with 10 CFR 54.21, Contents of applicationtechnical information, 41 to identify major refurbishment activities necessary for the continued operation of Turkey Point 42 during the proposed 20-year period of extended operation (FPL 2018a). 2-2

1 FPL did not identify any major refurbishment activities necessary for the continued operation of 2 Turkey Point beyond the end of the current renewed operating license term (FPL 2018f). 3 2.1.3 Termination of Nuclear Power Plant Operations and Decommissioning after the 4 Subsequent License Renewal Term 5 NUREG-0586, Supplement 1, Volumes 1 and 2, Final Generic Environmental Impact 6 Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of 7 Nuclear Power Reactors (NRC 2002a) (also known as the decommissioning GEIS), describes 8 the impacts of decommissioning. The majority of plant operations activities would cease with 9 permanent reactor shutdown. However, some activities (e.g., security and oversight of spent 10 nuclear fuel) would remain unchanged, whereas others (e.g., waste management, office and 11 clerical work, laboratory analysis, surveillance, monitoring, and maintenance) would continue at 12 reduced or altered levels. Systems dedicated to reactor operations would cease operations; 13 however, if these systems are not removed from the site after permanent reactor shutdown, 14 their physical presence may continue to impact the environment. Impacts associated with 15 dedicated systems that remain in place or with shared systems that continue to operate at 16 normal capacities could remain unchanged. 17 Decommissioning will occur whether Turkey Point is permanently shut down at the end of its 18 current renewed operating license term, or at the end of the subsequent period of extended 19 operation 20 years later. There are no site-specific issues related to decommissioning. The 20 license renewal GEIS concludes that license renewal would have a negligible (SMALL) effect on 21 the impacts of terminating operations and decommissioning on all resources (NRC 2013a). 22 2.2 Alternatives 23 As stated above, the National Environmental Policy Act of 1969, as amended (NEPA), requires 24 the NRC to consider reasonable alternatives to the proposed action of issuing subsequent 25 renewed operating licenses for Turkey Point. For a replacement power alternative to be 26 reasonable, it must be both (1) commercially viable on a utility scale and (2) operational before 27 the reactors operating license expires or expected to become commercially viable on a utility 28 scale and operational before the expiration of the reactors operating license (NRC 2013a). The 29 2013 GEIS incorporates the latest information on replacement power alternatives; however, 30 rapidly evolving technologies are likely to outpace the information in the GEIS. As such, for 31 each supplement to the GEIS, the NRC staff must perform a site-specific analysis of 32 replacement power alternatives that accounts for changes in technology and science since the 33 preparation of the most recent GEIS revision. 34 The first alternative to the proposed action of the NRC issuing subsequent renewed operating 35 licenses for Turkey Point is for the NRC to not issue the licenses. This is called the no-action 36 alternative. Section 2.2.1 below describes the no-action alternative. In addition to the no-action 37 alternative, this chapter discusses three reasonable replacement power alternatives. These 38 alternatives seek to replace Turkey Points generating capacity by meeting the regions energy 39 needs through other means or sources. Sections 2.2.2.1 through 2.2.2.3 describe replacement 40 power alternatives for Turkey Point. In addition, Section 2.2.3 describes a mechanical draft 41 cooling water system alternative, which the NRC staff evaluated as an alternative to Turkey 42 Points use of the existing cooling canal system (CCS) to provide cooling water for Turkey Point 43 Units 3 and 4. 2-3

1 2.2.1 No-Action Alternative Alternatives Evaluated in Depth:

• new nuclear 2 At some point, all operating nuclear power 3 plants will permanently cease operations and
• natural gas combined-cycle (NGCC) 4 undergo decommissioning. The no-action
• combination alternative (NGCC and 5 alternative represents a decision by the NRC solar power) 6 to not issue renewed operating licenses to a 7 nuclear power plant beyond the current Other Alternatives Considered but 8 operating license term. Under the no-action Eliminated:

9 alternative, the NRC does not issue the

• solar power 10 subsequent renewed operating licenses for 11 Turkey Point, such that the units would shut
• wind power 12 down at or before the expiration of the current
• biomass 13 licenses in 2032 (Unit 3) and 2033 (Unit 4).

14 The GEIS describes the environmental

• demand-side management 15 impacts that arise directly from permanent
• hydroelectric power 16 plant shutdown. The NRC expects shutdown
• geothermal power 17 impacts to be relatively similar whether they 18 occur at the end of the current license term
• wave and ocean energy 19 (i.e., after 60 years of operation) or at the end
• municipal solid waste 20 of a subsequent renewed license term (i.e.,
• petroleum-fired power 21 after 80 years of operation).
• coal-fired power 22 After permanent shutdown, plant operators
• fuel cells 23 will initiate decommissioning in accordance 24 with 10 CFR 50.82, Termination of license.
• purchased power 25 The decommissioning GEIS (NRC 2002a)
• delayed retirement of other 26 describes the environmental impacts from generating facilities 27 decommissioning a nuclear power plant and 28 related activities. The analysis in the decommissioning GEIS bounds the environmental impacts 29 of decommissioning at such time as FPL terminates reactor operations at Turkey Point.

30 Chapter 4 of the license renewal GEIS (NRC 2013a) and Section 4.15.2 of this SEIS describe 31 the incremental environmental impacts of subsequent license renewal on decommissioning 32 activities. 33 Termination of operations at Turkey Point would result in the total cessation of electrical power 34 production by Turkey Point Units 3 and 4, but not the electrical power produced by the balance 35 of the plant (e.g., Turkey Point Unit 5). Unlike the replacement power alternatives described 36 below in Section 2.2.2, the no-action alternative does not expressly meet the purpose and need 37 of the proposed action, as described in Section 1.2, because the no-action alternative does not 38 provide a means of delivering baseload power to meet future electric system needs. Assuming 39 that a need currently exists for the power generated by Turkey Point Units 3 and 4, the 40 no-action alternative would likely create a need for a replacement power alternative. The 41 following section describes a wide range of replacement power alternatives, and Chapter 4 42 assesses their potential environmental impacts. Although the NRCs authority only extends to 43 deciding whether to renew Turkey Point Units 3 and 4s current renewed operating licenses, the 44 replacement power alternatives described in the following sections represent possible options 45 for energy-planning decisionmakers if the NRC decides not to issue subsequent renewed 46 operating licenses for Turkey Point Units 3 and 4. 2-4

1 2.2.2 Replacement Power Alternatives 2 In evaluating alternatives to subsequent license renewal, the NRC considered energy 3 technologies or options currently in commercial operation, as well as technologies not currently 4 in commercial operation but likely to be commercially available by the time the current Turkey 5 Point renewed operating licenses expire on July 19, 2032 (Unit 3) and April 10, 2033 (Unit 4). 6 The GEIS presents an overview of some alternative energy technologies but does not conclude 7 which alternatives are most appropriate. Because alternative energy technologies are 8 continually evolving in capability and cost and because regulatory structures have changed to 9 either promote or impede the development of particular technologies, the analyses in this 10 chapter rely on a variety of sources of information to determine which alternatives would be 11 available and commercially viable when the current licenses expire. FPLs environmental report 12 provides a discussion of replacement power alternatives. In addition to the information FPL 13 provided in its environmental report, the NRC staffs analyses in this chapter include updated 14 information from the following sources: 15

• the U.S. Department of Energys U.S. Energy Information Administration (EIA) 16
• other offices within the U.S. Department of Energy (DOE) 17
• the U.S. Environmental Protection Agency (EPA) 18
• industry sources and publications 19 In total, the NRC staff considered 16 replacement power alternatives to the proposed action 20 (see text box) and eliminated 13 of these, which left the three reasonable replacement power 21 alternatives for in-depth evaluation described in Sections 2.2.2.1 through 2.2.2.3. The NRC 22 staffs in-depth evaluation of these three alternatives is presented in Chapter 4.

23 The staff eliminated from in-depth evaluation those alternatives that could not provide the 24 equivalent of Turkey Point Unit 3 and Unit 4s current generating capacity, as they would not be 25 able to satisfy the objective of replacing the power generated by these Turkey Point units. Also, 26 in some cases, the staff eliminated those alternatives whose costs or benefits could not justify 27 inclusion in the range of reasonable alternatives. Further, the staff eliminated as unfeasible 28 those alternatives not likely to be constructed and operational by the time the Turkey Point 29 licenses expire in 2032 (Unit 3) and 2033 (Unit 4). Section 2.3 of this report contains a brief 30 discussion of each eliminated alternative and provides the basis for its elimination. To ensure 31 that the alternatives considered in the SEIS are consistent with State or regional energy 32 policies, the NRC staff reviewed energy-related statutes, regulations, and policies within the 33 Turkey Point region. 34 The evaluation of each alternative considers the environmental impacts across the following 35 impact categories: 36

• land use and visual resources 37
• air quality and noise 38
• geologic environment 39
• water resources 40
• ecological resources 41
• historic and cultural resources 42
• socioeconomics, human health, environmental justice 43
• waste management 2-5

1 The GEIS assigns most site-specific issues (called Category 2 issues) a significance level of 2 SMALL, MODERATE, or LARGE. For ecological resources subject to the Endangered 3 Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) (ESA) and the Magnuson-Stevens 4 Fishery Conservation and Management Act of 1996, as amended (16 U.S.C. 1801 et seq.) 5 (MSA); and historic and cultural resources subject to the National Historic Preservation Act 6 of 1966, as amended (54 U.S.C. 300101 et seq.) (NHPA), the impact significance determination 7 language is specific to the authorizing legislation. The order in which this SEIS presents the 8 different alternatives does not imply increasing or decreasing level of impact; nor does the order 9 presented imply that an energy-planning decisionmaker would be more (or less) likely to select 10 any given alternative. 11 Region of Influence 12 If the NRC does not issue subsequent renewed licenses, procurement of replacement power for 13 Turkey Point Units 3 and 4 may be necessary. Turkey Point is owned and operated by FPL, 14 which provides electricity through its own bulk transmission system to a 35-county service area 15 concentrated in southern Florida and along Floridas Atlantic coast (FPL 2018g). The FPL 16 service territory constitutes the region of influence for the NRCs analysis of Turkey Point 17 replacement power alternatives. 18 In 2016, electric generators in Florida had a net summer generating capacity of approximately 19 58,000 megawatts (MW). This capacity included units fueled by natural gas (65 percent), coal 20 (17 percent), petroleum (9 percent), and nuclear power (6 percent). Lesser amounts associated 21 with several other miscellaneous energy sources comprised the balance of generating capacity 22 in the State (EIA 2018a). 23 The electric industry in Florida provided approximately 238 million megawatt hours (MWh) of 24 electricity in 2016. This electrical production was dominated by natural gas (67 percent), coal 25 (17 percent), and nuclear power (12 percent). Petroleum, biomass, and other miscellaneous 26 energy sources collectively produced the other 4 percent of the electricity in Florida 27 (EIA 2018b). 28 In the United States, natural gas generation rose from 16 percent of electricity generated in 29 2000 to 31 percent in 2017. Given known technological and demographic trends, the U.S. 30 Energy Information Administration predicts that by 2050, natural gas will account for 35 percent 31 of electricity generated in the United States (EIA 2013a, EIA 2016a, EIA 2018c). Electricity 32 generated from renewable energy is expected to grow from 13 percent of total generation in 33 2015 to 30 percent in 2050 (EIA 2016a, EIA 2018d). However, Floridas renewable energy 34 growth may not follow nationwide forecasts. Florida currently obtains only a small portion of its 35 energy from renewable resources, with most of that production primarily generated from 36 biomass, and to a lesser degree from solar and hydroelectric resources (EIA 2017a). The State 37 of Florida does not have a mandatory renewable portfolio standard, and there are other 38 uncertainties that could affect forecasts. In particular, the implementation of policies aimed at 39 reducing greenhouse gas (GHG) emissions could have a direct effect on fossil-fuel-based 40 generation technologies (LBNL 2017a). 2-6

1 The remainder of this section describes in depth the three reasonable replacement power 2 alternatives to Turkey Point subsequent license renewal. These three reasonable alternatives 3 are as follows: 4

• a new nuclear alternative (Section 2.2.2.1) 5
• a natural gas combined-cycle alternative (Section 2.2.2.2) 6
• a combination of natural gas combined-cycle and solar power alternative 7 (Section 2.2.2.3) 8 Table 2-1 below summarizes key design characteristics of these three alternative replacement 9 power technologies. Section 2.2.3 also describes a possible cooling water system alternative.

10 Table 2-1 Summary and Key Characteristics of Replacement Power Alternatives 11 Considered In Depth Natural Gas Combined-Cycle and Solar Natural Gas Photovoltaic Combination New Nuclear Alternative Combined-Cycle Alternative Alternative Summary of Two-unit nuclear plant, Three 500-MWe units for a Approximately 1,420 MWe Alternative each with 750 MWe, for a total of approximately from natural gas combined-total of 1,500 MWe 1,500 MWe cycle (three units), and 80 MWe from solar PV (four units) Location Located within the Turkey Located within the Turkey Partially located within the Point site, but outside the Point site (same location as Turkey Point site (same current footprint of Turkey New Nuclear Alternative). location as New Nuclear Point (Units 3 and 4). Also, Alternative for the natural outside the footprint of Replacement plant would gas combined-cycle plant Unit 5 (natural gas) and the share existing and planned and one of the four solar proposed footprint of infrastructure supporting PV units; the other three Units 6 and 7 (nuclear), other Turkey Point units. solar PV units would be which are assumed to be May also require some located at offsite locations operational. infrastructure upgrades as within the ROI). well as construction of a Replacement plant would new or upgraded pipeline. Replacement plants would share existing and planned (FPL 2018f). share existing and planned infrastructure supporting infrastructure supporting these other units (FPL other Turkey Point units. 2018f). May also require some infrastructure upgrades as well as construction of a new or upgraded pipeline. (FPL 2018f). 2-7

Natural Gas Combined-Cycle and Solar Natural Gas Photovoltaic Combination New Nuclear Alternative Combined-Cycle Alternative Alternative Cooling System Closed cycle with Closed cycle with Natural gas combined-cycle mechanical draft cooling mechanical draft cooling units would use closed-towers. Cooling water towers. Cooling water cycle cooling systems with withdrawal38 mgd; withdrawal10.5 mgd; mechanical draft cooling consumptive water use consumptive water use towers. 29 mgd (NRC 2016a). 8.1 mgd (NETL 2013). Cooling water withdrawal for these units would be 9.9 mgd; consumptive water use would be 7.7 mgd (NETL 2013). No cooling system would be required for the solar facilities. Land Approximately 360 ac Approximately 75 ac Approximately 540 ac Requirements (150 ha). (30 ha) for the plant, with (220 ha) onsite at FPL for (FPL 2018f). up to an additional 1,200 ac the natural gas (490 ha) for right-of-way to combined-cycle and solar connect with existing units, with up to an natural gas supply lines additional 1,200 ac (490 ha) north of the site. for right-of-way to connect No new gas wells would be with existing natural gas needed to support the supply lines north of the facility (FPL 2018f). site. No new gas wells would be needed. Three offsite solar units would require approximately 470 ac (190 ha) each, for an offsite total of approximately 1,400 ac (570 ha) (FPL 2018f). Work Force 3,900 workers during peak 1,200 workers during peak Natural gas combined-cycle construction and 800 construction and 150 and solar units would workers during operations workers during operations collectively require 1,400 (NRC 2016a). (NRC 2016a). workers during peak construction and 160 workers during operations. (NRC 2016a, DOE 2011). Key: ac = acres, ha = hectares, mgd = million gallons per day, MWe = megawatts electric, NGCC = natural gas combined-cycle (alternative), PV = photovoltaic, and ROI = region of influence. 1 2.2.2.1 New Nuclear Alternative 2 The NRC staff considers the construction of a new nuclear plant to be a reasonable alternative 3 to Turkey Point subsequent license renewal. Nuclear generation currently provides 4 approximately 12 percent of the electricity in Florida (EIA 2018b). One other nuclear power 2-8

1 plant operates in the region of influence: the St. Lucie Plant, Units 1 and 2, is located 2 approximately 130 miles (209 km) north of Turkey Point. The NRC staff determined that there 3 may be sufficient time for FPL to prepare and submit an application, build, and operate two new 4 nuclear units using a certified design before the Turkey Point Units 3 and 4 licenses expire in 5 2032 and 2033. 6 In evaluating the new nuclear alternative, the NRC staff assumed that FPL would build two new 7 nuclear reactors on a portion of the approximately 9,500-acre (3,800-ha) Turkey Point property. 8 The construction would allow for the maximum use of existing ancillary facilities (e.g., support 9 buildings and transmission infrastructure at location). In addition to Turkey Point Units 3 and 4, 10 the Turkey Point property currently includes Units 1 and 2 (two retired natural gas/oil units), as 11 well as Unit 5 (an operating natural gas combined-cycle unit (FPL 2018f). 12 In 2018, as part of a separate licensing action, the NRC issued combined licenses (COLs) to 13 FPL for the construction and operation of two new AP1000 nuclear reactor units (Turkey Point 14 Units 6 and 7) at the Turkey Point site (NRC 2018e). These proposed new units would have a 15 combined net electrical output of approximately 2,200 MWe and would be constructed on 16 approximately 220 acres (ac) (89 hectares (ha)) immediately south of Turkey Point Units 3 17 and 4 (NRC 2018f). 18 For the purpose of this subsequent license renewal analysis, the NRC staff assumed two 19 separate Westinghouse AP1000 reactors would replace Turkey Point Units 3 and 4. The 20 AP1000 reactors would use the same general design as that described in Chapter 3 of 21 NUREG-2176, Environmental Impact Statement for Combined Licenses (COLs) for Turkey 22 Point Nuclear Plant Units 6 and 7 (NRC 2016a); however, the new nuclear alternative reactors 23 location and generating capacity would differ from Turkey Point Units 6 and 7. For the new 24 nuclear alternative, the replacement power facility would be located within the Turkey Point 25 property, but outside the current footprints of Turkey Point Units 3 and 4 and Turkey Point 26 Unit 5, as well as outside the proposed footprint of the not-yet-constructed Turkey Point Units 6 27 and 7 (FPL 2018f). In addition, the replacement nuclear power facility would be scaled to 28 replace the Turkey Point Units 3 and 4 current net electrical output of approximately 29 1,500 MWe. This is approximately 32 percent less net electrical output than what the staff 30 evaluated in NUREG-2176 for Turkey Point Units 6 and 7. Accordingly, the heat rejection 31 demands of these new nuclear reactors would also be similar to those of Turkey Point 32 Units 3 and 4. As stated in FPLs environmental report, the new nuclear alternative would use a 33 mechanical draft cooling tower system. Consistent with the approach and analyses presented 34 in NUREG-2176 (the EIS for the Units 6 and 7 combined licenses), this closed-cycle cooling 35 system would primarily use reclaimed wastewater from the Miami-Dade Water and Sewer 36 Department, with saltwater produced from radial collection wells under Biscayne Bay used as a 37 temporary backup source (FPL 2018f, NRC 2016a). The NRC staff assumes that existing 38 Turkey Point Unit 5 and planned and licensed Turkey Point Units 6 and 7 will continue to be 39 operational during the construction and operation of the new nuclear alternative, and that 40 necessary infrastructure supporting Units 5, 6, and 7 will be available for shared use by the 41 replacement nuclear power facility. Similarly, the NRC staff assumes that the existing 42 transportation and transmission line infrastructure at Turkey Point will be adequate to support 43 the new nuclear alternative, since Units 3 and 4 would not be operating. 44 The NRC staff also considered the installation of multiple small modular reactors as a new 45 nuclear alternative to renewing the Turkey Point Units 3 and 4 licenses. The NRC established 46 the Advanced Reactor Program in the Office of New Reactors because of considerable interest 47 in small modular reactors along with anticipated license applications from vendors. Small 2-9

1 modular reactors generate approximately 300 MW or less, so they have lower initial capacity 2 than that of traditional large-scale units. However, they have greater siting flexibility because 3 they can fit in locations not large enough to accommodate traditional nuclear reactors 4 (DOE 2018b). The NRC received the first design certification application for a small modular 5 reactor in December 2016 (NRC 2017a). Following NRC certification, this design could 6 potentially achieve operation on a commercial scale by 2026 (NuScale 2018). The NRC staff 7 assumes that the resource requirements and key characteristics associated with constructing 8 and operating small modular reactors would be bounded by the larger nuclear units evaluated in 9 this SEIS. 10 2.2.2.2 Natural Gas Combined-Cycle Alternative 11 As discussed earlier, natural gas represents approximately 65 percent of the installed 12 generation capacity and 67 percent of the electrical power generated in Florida (EIA 2018a, 13 EIA 2018b). The NRC staff considers the construction of a natural gas combined-cycle power 14 plant to be a reasonable alternative to Turkey Point subsequent license renewal because 15 natural gas is a feasible, commercially available option for providing baseload electrical 16 generating capacity beyond the expiration of Turkey Points current licenses. 17 Baseload natural gas combined-cycle power plants (abbreviated in this section as natural gas 18 plants) have proven their reliability and can have capacity factors as high as 87 percent 19 (EIA 2015a). In a natural gas combined-cycle system, electricity is generated using a gas 20 turbine that burns natural gas. A steam turbine uses the heat from gas turbine exhaust through 21 a heat recovery steam generator to produce additional electricity. This two-cycle process has a 22 high rate of efficiency because the natural gas combined-cycle system captures the exhaust 23 heat that otherwise would be lost and reuses it. Similar to other fossil fuel sources, natural gas 24 power plants are a source of greenhouse gases, including carbon dioxide (CO2). However, a 25 natural gas combined-cycle power plant produces significantly fewer greenhouse gases per unit 26 of electrical output than conventional coal powered plants (NRC 2013a). 27 For this alternative, the NRC staff assumes that three natural gas units would be constructed 28 and operated to replace Turkey Points generating capacity. Each natural gas unit would have a 29 gross capacity of approximately 575 MWe and be operated using an 87 percent capacity factor. 30 Together, the three units would collectively replace Turkey Points approximate net generating 31 capacity of 1500 MWe. Each unit configuration would consist of two combustion turbine 32 generators, two heat recovery steam generators, and one steam turbine generator with 33 mechanical draft cooling towers for heat rejection. The NRC staff assumes that the natural gas 34 power plant will incorporate a selective catalytic reduction system to minimize the plants 35 nitrogen oxide emissions (NETL 2007). Natural gas would be extracted from the ground 36 through wells, treated to remove impurities, and then blended to meet pipeline gas standards 37 before being piped through the States pipeline system to the Turkey Point site. The natural gas 38 alternative would produce waste, primarily in the form of spent catalysts used for control of 39 nitrogen oxide emissions. 40 Similar to the new nuclear alternative (Section 2.2.2.1), the NRC staff assumes that the natural 41 gas replacement power facility would be built on a portion of the approximately 9,500 ac 42 (3,800 ha) Turkey Point property and would allow for the maximum use of the locations existing 43 ancillary facilities (e.g., support buildings and transmission infrastructure). Approximately 75 ac 44 (30 ha) would be used to construct and operate the natural gas plant (FPL 2018f). Depending 45 on the specific site location and proximity of existing natural gas pipelines, the natural gas 46 alternative may also require up to 1,200 ac (490 ha) of land for right-of-way to connect with 2-10

1 existing natural gas supply lines north of the site. In its environmental report, FPL states that no 2 new gas wells would be needed to support the natural gas combined-cycle alternative 3 (FPL 2018f). 4 The NRC staff assumes that the natural gas combined-cycle plant would use a closed-cycle 5 cooling system with mechanical draft cooling towers. To support the plants cooling needs, this 6 cooling system would withdraw approximately 10.5 million gallons per day (mgd) (39,000 cubic 7 meters per day (m3/d)) of water and consume 8.1 mgd (31,000 m3/d) of water (NETL 2013). 8 Because of the high overall thermal efficiency of this type of plant, the natural gas combined-9 cycle alternative would require less cooling water than Turkey Point subsequent license 10 renewal. Onsite visible structures could include the cooling towers, exhaust stacks, intake and 11 discharge structures, transmission lines, natural gas pipelines, and an electrical switchyard. 12 Construction materials could be delivered by a combination of truck and barge. 13 2.2.2.3 Combination Alternative (Natural Gas Combined-Cycle and Solar) 14 This alternative combines natural gas and solar replacement power generation to meet the 15 needs and purpose of the Turkey Point subsequent license renewal. Natural gas and solar 16 power generating facilities currently operate within the region of influence. For the purpose of 17 this evaluation, the NRC staff assumes that (1) a natural gas combined-cycle plant would supply 18 1,420 MWe, and (2) four separate solar power plants would supply approximately 80 MWe. 19 Further, the staff assumes that the natural gas combined-cycle facility and one of the four solar 20 plants would be located within the Turkey Point property and would use existing available site 21 infrastructure to the extent practicable. The other three solar facilities would be located at offsite 22 locations within the region of influence, specifically within Miami-Dade and Broward counties 23 (FPL 2018f). 24 Natural Gas Combined-Cycle Portion of Combination Alternative 25 The natural gas portion of the combination alternative would be generated using a natural gas 26 combined-cycle plant located in the ROI. Although similar in function and appearance to the 27 three-unit natural gas plant described in Section 2.2.2.2, the natural gas plant considered under 28 the combination alternative would have slightly less generating capacity. Specifically, the NRC 29 assumes that the plant would consist of three approximately 545 MWe natural gas units that 30 would be constructed and operated using an 87 percent capacity factor (EIA 2015a) to 31 collectively provide an approximate net generating capacity of 1,420 MWe. 32 Approximately 70 ac (28 ha) of land would be required to construct and operate the natural gas 33 units (FPL 2018f). Depending on the specific site location and proximity of existing natural gas 34 pipelines, the natural gas portion of this alternative may also require up to 1,200 ac (490 ha) of 35 land for right-of-way to connect with existing natural gas supply lines north of the site. In its 36 environmental report, FPL states that no new gas wells would be needed to support a natural 37 gas combined-cycle power plant (FPL 2018f). 38 The NRC staff assumes that the natural gas plant would use a closed-cycle cooling system with 39 mechanical draft cooling towers. To support the plants cooling needs, this system would 40 withdraw approximately 9.9 million gallons-per-day (mgd) (37,000 m3/d) of water and consume 41 7.7 mgd (29,000 m3/d) of water (NETL 2013). 2-11

1 Solar Portion of Combination Alternative 2 The solar portion of the combination alternative would be generated using solar photovoltaic 3 energy facilities located in the region of influence. For the purpose of this analysis, the NRC 4 assumes that four, approximately 75 MWe, standalone utility-scale solar facilities would be 5 constructed and operated to provide a gross generating capacity of 300 MWe. One of these 6 units would be located on FPL-owned lands in the Turkey Point area, and three units would be 7 located at offsite locations in Miami-Dade County and/or Broward County (FPL 2018f). 8 Assuming a 26-percent capacity factor, the solar units collectively would have an approximate 9 net generating capacity of 80 MWe (FPL 2018f). 10 Nationwide, growth in utility-scale solar photovoltaic facilities (greater than 1 MW) has resulted 11 in an increase from 70 MW in 2008 to over 20,000 MW installed capacity in 2017 (EIA 2017b). 12 Although Florida has the 3rd-highest solar potential in the Nation, the State only ranks 12th in 13 installed capacity with approximately 725 MW. However, solar energy is projected to supply the 14 most new-renewable-energy capacity to the State over the next decade, and FPL plans to add 15 more than 2,000 MW of additional solar generation capacity during that timeframe (EIA 2017a, 16 FPL 2018f). 17 Solar photovoltaic resources across Florida range from 5.0 to 5.5 kilowatt hours per square 18 meter per day (kWh/m2/day) (NREL 2017). The feasibility of solar energy resources serving as 19 alternative baseload power is dependent on the location, value, accessibility, and constancy of 20 solar radiation. Solar photovoltaic power generation uses solar panels to convert solar radiation 21 into usable electricity. Solar cells are formed into solar panels that can then be linked into 22 photovoltaic arrays to generate electricity. The electricity generated can be stored, used 23 directly, fed into a large electricity grid, or combined with other electricity generators as a hybrid 24 plant. Solar photovoltaic cells can generate electricity whenever there is sunlight, regardless of 25 whether the sun is directly or indirectly shining on the solar panels. Therefore, solar 26 photovoltaic technologies do not need to directly face and track the sun. This capability has 27 allowed solar photovoltaic systems to have broader geographical use than concentrating solar 28 power (which relies on direct sun) (DOE 2011). Because the region of influence contains 29 above-average solar photovoltaic resources and because solar photovoltaic technology is a 30 commercially available option for providing electrical generating capacity, the NRC staff 31 considers the construction of solar photovoltaic facilities to be a reasonable alternative to 32 subsequent license renewal when combined with natural gas combined-cycle facilities. 33 Utility-scale solar facilities require large areas of land to be cleared for the solar panels. For 34 standalone sites, solar photovoltaic facilities may require approximately 6.2 ac per megawatt 35 (NRC 2013a). Therefore, approximately 470 ac (190 ha) would be required for each of the four 36 proposed solar power installations needed under this alternative (FPL 2018f). Although not all 37 of this land would be cleared of vegetation and permanently impacted, it represents the land 38 enclosed in the total site boundary of the solar facility (NREL 2013). Solar photovoltaic systems 39 do not require water for cooling purposes but do require a small amount of water to clean the 40 panels and for potable water for the workforce. 41 2.2.3 Cooling Water System Alternative 42 In addition to replacement power alternatives, this SEIS evaluates an alternative cooling water 43 system technology for Turkey Point Units 3 and 4 that might be used to mitigate the potential 44 impacts associated with continued use of the existing cooling canal system. The purpose of this 45 analysis is for the NRC staff to compare an alternative closed-cycle cooling system approach 2-12

1 with the proposed action to inform the NRCs licensing decision, decisions by other 2 decisionmakers and the public, as applicable, under NEPA. However, the NRC has neither the 3 statutory nor the regulatory authority to determine which system or technology should be used, 4 or to decide other permitting issues, for which the State of Florida has been delegated 5 regulatory authority under the Clean Water Act. 6 The NRC staffs analysis of the alternative cooling water system draws upon an application 7 which FPL submitted to the NRC in 2009, for COLs to build and operate two new onsite nuclear 8 reactors (Turkey Point Units 6 and 7). The NRC staff conducted an environmental review of 9 that COL application and published it as NUREG-2176. Section 3.2.2.2 of the COL EIS 10 describes a cooling water system alternative to Turkey Points existing cooling canal system that 11 consists of onsite mechanical draft cooling towers (NRC 2016a). Under the cooling water 12 system alternative that is evaluated by the NRC staff in this license renewal SEIS, Turkey Point 13 Units 3 and 4 would each use three similar closed-cycle wet-cooling towers (six cooling towers 14 in total) to dissipate heat from the reactor cooling water systems. These mechanical draft water 15 towers would be octagonal in shape and extend approximately 70 feet (20 m) in height and 16 250 feet (75 m) in diameter (NRC 2016a). 17 The Units 3 and 4 cooling towers would have the same general design, construction, and 18 operating characteristics as the cooling water system associated with the new nuclear 19 alternative described in Section 2.2.2.1 of this SEIS. As in the new nuclear alternative, the 20 primary source of cooling water is assumed to be reclaimed wastewater. Similarly, as 21 summarized in Table 2-1 of this SEIS, cooling water makeup would be approximately 38 mgd 22 (144,000 m3/d) and consumptive water use would be approximately 29 mgd (110,000 m3/d). 23 Other discrete resource requirements associated with constructing and operating these cooling 24 towers would be a subset of the overall resource requirements identified in NUREG-2167 (the 25 EIS for the Turkey Point Units 6 and 7 combined licenses) in Tables 3-4 and 3-6 (NRC 2016a). 26 2.3 Alternatives Considered but Eliminated 27 The NRC staff originally considered 16 replacement power alternatives to Turkey Point Unit 3 28 and 4s subsequent license renewal, but ultimately eliminated 13 of these from detailed study. 29 The staff eliminated these 13 alternatives because of technical reasons, resource availability 30 limitations, or commercial or regulatory limitations. Many of these limitations will likely still exist 31 when the current Turkey Point licenses expire in 2032 and 2033, such that these 13 alternatives 32 are not expected to be reasonably available when needed to replace the power generated by 33 Turkey Point Units 3 and 4. 34 2.3.1 Solar Power 35 Solar power, including solar photovoltaic (PV) and concentrating solar power (CSP) 36 technologies, produce power generated from sunlight. Solar photovoltaic components convert 37 sunlight directly into electricity using solar cells made from silicon or cadmium telluride. 38 Concentrating solar power uses heat from the sun to boil water and produce steam. The steam 39 then drives a turbine connected to a generator to ultimately produce electricity (NREL 2014). 40 Solar generators are considered an intermittent resource because their availability depends on 41 ambient exposure to the sun, also known as solar insolation (EIA 2017c). Insolation rates of 42 solar photovoltaic resources in Florida range from 5.0 to 5.5 kWh/m2/day (NREL 2017a). Due to 43 higher solar insolation requirements associated with concentrating solar power, utility-scale 44 application of this technology has generally only occurred in western States with high solar 2-13

1 thermal resources and large, contiguous tracts of land in arid environments (i.e., California, 2 Arizona, and Nevada) (EIA 2016c). The exception is FPLs Martin generating station, the only 3 concentrating solar power plant east of the Rocky Mountains, which produced approximately 4 22 percent of the states utility-scale net solar generation in 2016 (EIA 2017d). 5 Although Florida has abundant solar resource potential, it generates only a small part of its 6 energy from solar or other renewable resources (EIA 2017a). In addition, Florida does not have 7 a mandatory renewable portfolio standard that would require generators to consider solar power 8 (EIA 2017a). To be considered a viable alternative, a solar alternative must replace the amount 9 of electricity that Turkey Point provides. Assuming capacity factors of 25 to 50 percent 10 (DOE 2011), approximately 3,000 to 6,000 MWe of additional gross solar capacity would need 11 to be installed in the region of influence, which substantially exceeds existing capacity across 12 the state and plans for additional solar generation capacity in the region of influence over the 13 next decade (EIA 2017a, FPL 2018f). 14 Considering the above factors, the NRC staff concludes that solar power energy facilities alone 15 do not provide a reasonable alternative to Turkey Point subsequent license renewal. However, 16 the NRC staff does consider an alternative using solar power in combination with natural gas 17 combined-cycle power, as described above in Section 2.2.2.3. 18 2.3.2 Wind Power 19 As is the case with other renewable energy sources, the feasibility of wind power serving as 20 alternative baseload power is dependent on the location (relative to expected electricity users), 21 value, accessibility, and constancy of the resource. Wind energy must be converted to 22 electricity at or near the point where it is extracted, and currently there are limited energy 23 storage opportunities available to overcome the intermittency and variability of wind resources. 24 To be considered a reasonable replacement power alternative to Turkey Point subsequent 25 license renewal, the wind power alternative must replace the amount of electricity that Turkey 26 Point provides. Assuming a capacity factor of 35 percent for land-based wind and 40 percent 27 for offshore wind, a combination of land-based and offshore wind energy facilities in the region 28 of influence would have to generate a range of approximately 3,750 to 4,300 MWe of electricity. 29 The American Wind Energy Association reports a total of more than 90,000 MW of installed 30 wind energy capacity nationwide as of March 31, 2018 (DOE 2018d). Texas leads all other 31 States in installed land-based wind energy capacity with over 23,000 MW. In contrast, Florida 32 currently has no installed land-based wind power capacity and little overall wind potential to 33 support the development of future wind energy systems (DOE 2018a, EIA 2017a). 34 Similarly, Florida does not have any utility-scale offshore wind farms in operation. In 2016, a 35 30 MW project off the coast of Rhode Island become the first operating offshore wind farm in the 36 United States (Energy Daily 2016). Although approximately 20 offshore wind projects 37 representing more than 15,000 MW of capacity were in the planning and permitting process as 38 of 2015, most of these projects are concentrated along the North Atlantic coast, and none are 39 currently planned off the shores of Florida (EIA 2015b, DOE 2018a). 40 Given the amount of wind capacity necessary to replace Turkey Point, the intermittency of the 41 resource, the current lack of any installed wind capacity in the State, and the limited potential for 42 any new development in the region of influence, the NRC staff finds a wind-based alternative 2-14

1 either land based, offshore, or some combination of the twoto be an unreasonable alternative 2 to Turkey Point subsequent license renewal. 3 2.3.3 Biomass Power 4 Using biomass-fired generation for baseload power depends on the geographic distribution, 5 available quantities, constancy of supply, and energy content of biomass resources. For this 6 analysis, the NRC staff assumed that biomass would be combusted for power generation in the 7 electricity sector. Biomass is also used for space heating in residential and commercial 8 buildings and can be converted to a liquid form for use in transportation fuels. 9 Biomass fuels are abundant in Florida, and currently provide the largest share of Floridas 10 renewable electricity generation (EIA 2017a). In 2016, Florida had a total installed capacity of 11 approximately 1,300 MW, and approximately 2 percent of the States total system power was 12 produced from biomass (EIA 2018a, EIA 2018b). 13 For utility-scale biomass electricity generation, the NRC staff assumes that the technologies 14 used for biomass conversion would be similar to fossil fuel plants, including the direct 15 combustion of biomass in a boiler to produce steam (NRC 2013a). Biomass generation is 16 generally more cost effective when co-fired with coal plants (IEA 2007). In 2013, Florida 17 opened the 103-MW Gainesville Renewable Energy Center, one of the largest new biomass 18 plants in the United States (EIA 2016b). Replacing the generating capacity of Turkey Point 19 using only biomass would require the construction of approximately 15 additional facilities of this 20 size. However, most biomass-fired generation plants generally only reach capacities of 50 MW, 21 which means replacing the generating capacity of Turkey Point would require the construction of 22 twice as many new average-sized biomass facilities. Sufficiently increasing biomass-fired 23 generation capacity by expanding existing biomass units or constructing new biomass units by 24 the time Turkey Points licenses expire in 2032 and 2033, is unlikely. For this reason, the NRC 25 staff does not consider biomass-fired generation to be a reasonable alternative to Turkey Point 26 subsequent license renewal. 27 2.3.4 Demand-Side Management 28 Energy conservation can include reducing energy demand through behavioral changes or 29 altering the shape of the electricity load, and usually does not require the addition of new 30 generating capacity. Conservation and energy efficiency programs are more broadly referred to 31 as demand-side management. 32 Conservation and energy efficiency programs can be initiated by a utility, transmission 33 operators, the State, or other load-serving entities. In general, residential electricity consumers 34 have been responsible for the majority of peak load reductions and participation in most 35 programs is voluntary. Therefore, the existence of a program does not guarantee that 36 reductions in electricity demand would occur. The GEIS concludes that, although the energy 37 conservation or energy efficiency potential in the United States is substantial, the NRC staff is 38 aware of no cases where an energy efficiency or conservation program alone has been 39 implemented expressly to replace or offset a large baseload generation station (NRC 2013a). 40 FPL estimates that demand-side management efforts from 1978 to 2017 have resulted in a total 41 savings of approximately 4,800 MW across its service territory (FPL 2018g). In 2014, the 42 Florida Public Services Commission established FPLs current demand-side management 43 goals, and FPL has accounted for these goals in its planning process through at least 2027. 2-15

1 However, it is unlikely that further cost-effective reductions in electrical demand, particularly in 2 Broward and Miami-Dade counties, could replace Turkey Points generation (FPL 2018f). 3 Therefore, the NRC staff does not consider demand-side management and energy efficiency 4 programs to be a reasonable alternative to Turkey Point subsequent license renewal. 5 2.3.5 Hydroelectric Power 6 Currently, approximately 2,000 hydroelectric facilities operate in the United States. 7 Hydroelectric technology captures flowing water and directs it to a turbine and generator to 8 produce electricity (NRC 2013a). There are three variants of hydroelectric power: 9 (1) run-of-the-river (diversion) facilities that redirect the natural flow of a river, stream, or canal 10 through a hydroelectric facility, (2) store-and-release facilities that block the flow of the river by 11 using dams that cause water to accumulate in an upstream reservoir, and (3) pumped storage 12 facilities that use electricity from other power sources to pump water to higher elevations during 13 off-peak load periods to be released during peak load periods through the turbines to generate 14 additional electricity. 15 A comprehensive survey of hydropower resources, completed in 1997, identified Florida as 16 having only 43 MW of potential hydroelectric capacity when adjusted for environmental, legal, 17 and institutional constraints (Conner et. al., 1998). These constraints could include (1) scenic, 18 cultural, historical, and geological values, (2) Federal and State land use, and (3) legal 19 protection issues, such as wild and scenic legislation and threatened or endangered fish and 20 wildlife legislative protection. A separate DOE assessment of non-powered dams (dams that do 21 not produce electricity) concludes that there is potential for 173 MW of electricity in Florida 22 (ORNL 2012). These non-powered dams serve various purposes, such as providing water 23 supply to inland navigation. However, hydroelectric power accounted for less than one percent 24 of the States electric power production in 2016 (EIA 2018b). Although the U.S. Energy 25 Information Administration projects that hydropower will remain a leading source of renewable 26 generation in the United States through 2040, there is little expected growth in hydropower 27 capacity (EIA 2013a). The potential for future construction of large hydropower facilities has 28 diminished because of increased public concerns over flooding, habitat alteration and loss, and 29 destruction of natural river courses (NRC 2013a). 30 Given the projected lack of growth in hydroelectric power production, the low potential capacity 31 in Florida, the competing demands for water resources, and the expected public opposition to 32 the large environmental impacts and significant changes in land use that would result from the 33 construction of hydroelectric facilities, the NRC staff concludes that the expansion of 34 hydroelectric power is not a reasonable alternative to Turkey Point subsequent license renewal. 35 2.3.6 Geothermal Power 36 Geothermal technologies extract the heat contained in geologic formations to produce steam to 37 drive a conventional steam turbine generator. Facilities producing electricity from geothermal 38 energy have demonstrated capacity factors of 95 percent or greater, making geothermal energy 39 a potential source of baseload electric power. However, the feasibility of geothermal power 40 generation to provide baseload power depends on the regional quality and accessibility of 41 geothermal resources. Utility-scale geothermal energy generation requires geothermal 42 reservoirs with a temperature above 200 °F (93 °C). Known geothermal resources are 43 concentrated in the western United States, specifically Alaska, Arizona, California, Colorado, 44 Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming. In 45 general, most assessments of geothermal resources have been concentrated on these western 2-16

1 States (DOE 2013a, USGS 2008a). Geothermal resources are used in the Turkey Point region 2 of influence for heating and cooling purposes, but no electricity is currently being produced from 3 geothermal resources in the region of influence (EIA 2017e). Given the low resource potential 4 in the region of influence, the NRC staff does not consider geothermal to be a reasonable 5 alternative to Turkey Point subsequent license renewal. 6 2.3.7 Wave and Ocean Energy 7 Waves, currents, and tides are often predictable and reliable, making them attractive candidates 8 for potential renewable energy generation. Four major technologies may be suitable to harness 9 wave energy: (1) terminator devices that range from 500 kilowatts to 2 MW, (2) attenuators, 10 (3) point absorbers, and (4) overtopping devices (BOEM undated). Point absorbers and 11 attenuators use floating buoys to convert wave motion into mechanical energy, driving a 12 generator to produce electricity. Overtopping devices trap a portion of a wave at a higher 13 elevation than the sea surface; waves then enter a tube and compress air that is used to drive a 14 generator that produces electricity (NRC 2013a). Some of these technologies are undergoing 15 demonstration testing at commercial scales, but none are currently used to provide baseload 16 power (BOEM undated). 17 Resource assessments show that modest energy production potential is associated with the 18 Florida Current of the Gulf Stream along Floridas southeastern coast (DOE 2018c). However, 19 wave and ocean energy generation technologies are still in their infancy and currently lack 20 commercial application. For these reasons, the NRC staff does not consider wave and ocean 21 energy to be a reasonable alternative to Turkey Point subsequent license renewal. 22 2.3.8 Municipal Solid Waste 23 Energy recovery from municipal solid waste converts non-recyclable waste materials into usable 24 heat, electricity, or fuel through combustion (EPA 2014a). The three types of combustion 25 technologies include mass burning, modular systems, and refuse-derived fuel systems 26 (EPA 2014b). Mass burning is the method used most frequently in the United States. The heat 27 released from combustion is used to convert water to steam, which is used to drive a turbine 28 generator to produce electricity. Ash is collected and taken to a landfill, and particulates are 29 captured through a filtering system (EPA 2014b). As of 2016, 77 waste-to-energy plants are in 30 operation in 22 States, processing approximately 30 million tons of waste per year. These 31 waste-to-energy plants have an aggregate capacity of 2,547 MWe. Although some plants have 32 expanded to handle additional waste and to produce more energy, no new plants have been 33 built in the United States since 1995 (EPA 2014a, Michaels 2016). The average 34 waste-to-energy plant produces about 50 MWe, with some reaching 77 MWe, and can operate 35 at capacity factors greater than 90 percent (Michaels 2010). In 2017, municipal solid waste 36 accounted for approximately 450 MW of Floridas electrical capacity (FDACS 2017). 37 Approximately 30 average-sized waste-to-energy plants would be necessary to provide the 38 same level of output as Turkey Point Units 3 and 4. 39 The decision to burn municipal waste to generate energy is usually driven by the need for an 40 alternative to landfills rather than a need for energy. Given the improbability that additional 41 stable supplies of municipal solid waste would be available to support 30 new facilities in the 42 region of influence, the NRC staff does not consider municipal solid waste combustion to be a 43 reasonable alternative to Turkey Point subsequent license renewal. 2-17

1 2.3.9 Petroleum-Fired Power 2 Petroleum-fired electricity generation accounted for approximately 1 percent of Floridas 3 statewide total electricity generation in 2016 (EIA 2018b). The variable costs and environmental 4 impacts of petroleum-fired generation tend to be greater than those of 5 natural gas-fired generation. The historically higher cost of oil has also resulted in a steady 6 decline in its use for electricity generation, and the U.S. Energy Information Administration 7 forecasts no growth in capacity using petroleum-fired power plants through 2040 (EIA 2013a, 8 EIA 2015c). Therefore, the NRC staff does not consider petroleum-fired generation to be a 9 reasonable alternative to Turkey Point subsequent license renewal. 10 2.3.10 Coal-Fired Power 11 Although coal has historically been the largest source of electricity in the United States, the 12 U.S. Energy Information Administration expects natural gas generationand potentially even 13 renewable energy generationto surpass coal generation at the national level by 2040 14 (EIA 2016a). Florida exemplifies this trend, with coal historically fueling the largest share of 15 electricity generated in the state until 2003, when it was surpassed by natural gas (EIA 2017a). 16 In 2016, coal-fired generation accounted for approximately 17 percent of all electricity generated 17 in Florida, a 21-percent decrease from 2000 levels (EIA 2018b). 18 Baseload coal units have proven their reliability and can routinely sustain capacity factors as 19 high as 85 percent. Among the technologies available, pulverized coal boilers producing 20 supercritical steam (supercritical pulverized coal or SCPC boilers) are increasingly common for 21 new coal-fired plants given their generally high thermal efficiencies and overall reliability. 22 Supercritical pulverized coal facilities are more expensive than subcritical coal-fired plants to 23 construct, but they consume less fuel per unit output, reducing environmental impacts. In a 24 supercritical coal-fired power plant, burning coal heats pressurized water. As the supercritical 25 steam and water mixture moves through plant pipes to a turbine generator, the pressure drops 26 and the mixture flashes to steam. The heated steam expands across the turbine stages, which 27 then spin and turn the generator to produce electricity. After passing through the turbine, any 28 remaining steam is condensed back to water in the plants condenser. Integrated gasification 29 combined cycle is another technology that generates electricity from coal. It combines modern 30 coal gasification technology with both gas turbine and steam turbine power generation. The 31 technology is cleaner than conventional pulverized coal plants because some of the major 32 pollutants are removed from the gas stream before combustion. 33 An integrated gasification combined-cycle power plant consists of coal gasification and 34 combined-cycle power generation. Coal gasifiers convert coal into a gas (synthesis gas, also 35 referred to as syngas), which fuels the combined-cycle power generating units. Nearly 36 100 percent of the nitrogen from the syngas is removed before combustion in the gas turbines 37 and this results in lower nitrogen oxide emissions when compared to conventional coal fired 38 power plants (DOE 2010). 39 Although several smaller, integrated gasification combined-cycle power plants have been in 40 operation since the mid-1990s, more recent large-scale projects using this technology have 41 experienced a number of setbacks and opposition that have hindered the technology from fully 42 integrating into the energy market. The most significant roadblock has been the high capital 43 cost of an integrated gasification combined-cycle power plant as compared to conventional coal-44 fired power plants. Both the Duke Energy Edwardsport Generation Station project in Indiana 45 and the Kemper County integrated gasification combined-cycle project in east central 2-18

1 Mississippi have experienced cost and schedule overruns. The Kemper County project 2 suspended work towards startup of the gasifier component in June 2017 (Energy Daily 2017). 3 Other issues associated with integrated gasification combined cycle include a limited track 4 record for reliable performance and opposition based on environmental concerns. In its 5 environmental report, FPL states that it currently has no plans to add new coal-fired generation 6 to its energy production portfolio (FPL 2018f). Based upon these considerations, the NRC staff 7 concludes that coal-fired technologies do not provide a reasonable source of baseload power to 8 replace Turkey Point Units 3 and 4 by the time their current licenses expire in 2032 and 2033. 9 2.3.11 Fuel Cells 10 Fuel cells oxidize fuels without combustion and therefore without the environmental side effects 11 of combustion. Fuel cells use a fuel (e.g., hydrogen) and oxygen to create electricity through an 12 electrochemical process. The only byproducts are heat, water, and carbon dioxide (depending 13 on the hydrogen fuel type) (DOE 2013b). Hydrogen fuel can come from a variety of 14 hydrocarbon resources. Natural gas is a typical hydrogen source. 15 Fuel cells are not economically or technologically competitive with other alternatives for 16 electricity generation. The U.S. Energy Information Administration estimates that fuel cells may 17 cost $7,108 per installed kilowatt (total overnight capital costs in 2012 dollars), which is high 18 compared to other alternative technologies analyzed in this section (EIA 2013b). More 19 importantly, fuel cell units are likely to be small in size (approximately 10 MW). The worlds 20 largest fuel cell facility is a 59 MWe plant that came online in South Korea in 2014 (PEI 2017). 21 Using fuel cells to replace the power that Turkey Point provides would be extremely costly. It 22 would require the construction of approximately 150 average-sized units and modifications to 23 the existing transmission system. Given the immature status and high cost of fuel cell 24 technology, the NRC staff does not consider fuel cells to be a reasonable alternative to Turkey 25 Point subsequent license renewal. 26 2.3.12 Purchased Power 27 It is possible that replacement power may be imported from outside the Turkey Point region of 28 influence. Although purchased power would likely have little or no measurable environmental 29 impact in the vicinity of Turkey Point, impacts could occur where the power is generated or 30 anywhere along the transmission route, depending on the generation technologies used to 31 supply the purchased power (NRC 2013a). 32 As discussed in its report, 2018-2027 Ten Year Power Plant Site Plan, FPL purchases power 33 from generation sources outside of its service area (FPL 2018g). In 2016 and 2017, FPL 34 purchased 826 MW of firm capacity generation from other such facilities. However, two 35 coal-fired units at the St. Johns River Power Park, in Jacksonville, FL, which provided 382 MW 36 of FPLs purchased power, retired in January 2018 (FPL 2018f, FPL 2018g). FPL also projects 37 that it will cancel a 330 MW purchase power agreement with a separate coal-fired facility by 38 2020 because it is no longer cost-effective. Overall, FPLs firm capacity purchases are 39 expected to average only 250 MW over the next decade (FPL 2018g). 40 Additionally, purchased power is generally economically adverse because the cost of generated 41 power historically has been less than the cost of the same power provided by a third party 42 (NRC 2013a). Power purchase agreements also carry the inherent risk that the other plant will 43 not deliver the contracted power. 2-19

1 Based on these considerations, the NRC staff concludes that purchased power does not 2 provide a reasonable alternative to Turkey Point subsequent license renewal. 3 2.3.13 Delayed Retirement 4 The retirement of a power plant ends its ability to supply electricity. Delaying the retirement of a 5 power plant enables it to continue supplying electricity. A delayed retirement alternative would 6 delay the retirement of generating facilities within or near the region of influence. 7 Power plant retirement occurs for several reasons. Because generators are required to adhere 8 to additional regulations that will require significant reductions in plant emissions, some power 9 plants may opt for early retirement of older units rather than incur the cost for compliance. 10 Additional retirements may be driven by low natural gas prices, slow growth in electricity 11 demand, and requirements of the Mercury and Air Toxics Standards (EIA 2015c, EPA 2015). 12 Most units that are near or past retirement age generate more pollutants and are less efficient 13 than new units. Often, utility owners retire units because operation is no longer economical. In 14 some cases, the cost of environmental compliance or necessary repairs or upgrades are too 15 great to justify continued operation. 16 FPL reviews its existing fleet for cost-effective opportunities to modernize the fleet and extend 17 operations, as well as to evaluate the need to close older inefficient plants. In its 2018-2027 18 Ten Year Power Plant Site Plan, FPL identifies the companys intention to retire two large 19 (approximately 800 MW) generating units at its Martin facility by 2019. These units have been 20 in operation for nearly 40 years and are relatively inefficient. FPL is in the process of 21 modernizing several of its gas-fired generation facilities within its service area, and these 22 ongoing efforts will only partially offset the loss of the Martin units (FPL 2018g). However, FPL 23 has not identified opportunities within its existing fleet that would provide for the replacement of 24 Turkey Points net generation (FPL 2018f). 25 Because of these conditions, the NRC staff concludes that delayed retirement does not provide 26 a reasonable alternative to Turkey Point subsequent license renewal. 27 2.4 Comparison of Alternatives 28 In this chapter, the NRC staff considered in depth one alternative to Turkey Point subsequent 29 license renewal that does not replace the plants energy generation (the no-action alternative) 30 and three alternatives to subsequent license renewal that may reasonably replace Turkey 31 Points energy generation. These three replacement power alternatives are (1) new nuclear 32 generation, (2) natural gas combined-cycle generation, and (3) a combination of natural gas 33 combined-cycle generation and solar photovoltaic generation. The environmental impacts of 34 the proposed action and of the alternatives are described and assessed in Chapter 4. Table 2-2 35 summarizes the environmental impacts of the three replacement power alternatives to Turkey 36 Point subsequent license renewal. 37 The environmental impacts of the proposed action (subsequent renewal of the Turkey Point 38 operating licenses) would be SMALL for all impact categories except for groundwater resources 39 and aquatic resources. The impacts to groundwater resources range from SMALL to 40 MODERATE because of groundwater use conflicts and because the site-specific impacts of the 41 Category 1 Issue, Groundwater Quality Degradation (Plants with Cooling Ponds in Salt 42 Marshes), are assessed as MODERATE for current and continued operations during the initial 2-20

1 license renewal term but are projected to be SMALL during subsequent license renewal. Due to 2 impingement, entrainment, and thermal impacts on the aquatic organisms in the canal cooling 3 system, the impact of the Turkey Point subsequent license renewal to aquatic resources would 4 be SMALL to MODERATE. 5 In comparison, each of the three reasonable replacement power alternatives have 6 environmental impacts in at least two resource areas that are greater than the environmental 7 impacts of the proposed action of subsequent license renewal. In addition, the replacement 8 power alternatives also involve the environmental impacts inherent to new construction projects. 9 If the NRC adopts the no-action alternative and does not issue subsequent renewed licenses for 10 Turkey Point, energy-planning decisionmakers would likely implement one of the three power 11 replacement power alternatives discussed in-depth in this chapter. Based on the NRC staffs 12 review of these three replacement power alternatives, the no-action alternative, and the 13 proposed action, the staff concludes that the environmentally preferred alternative is the 14 proposed action of subsequent license renewal. Therefore, the NRC staff proposes to 15 recommend that the NRC issue subsequent renewed operating licenses for Turkey Point 16 Units 3 and 4. 2-21

1 Table 2-2 Summary of Environmental Impacts of the Proposed Action and Alternatives Turkey Point Combination Subsequent Alternative License Natural Gas (Natural Gas Renewal Combined- Combined-Cycle Cooling Water Impact Area (Proposed No-Action New Nuclear Cycle and Solar System (Resource) Action) Alternative Alternative Alternative Photovoltaic) Alternative Land Use SMALL SMALL SMALL to SMALL to SMALL to LARGE SMALL MODERATE MODERATE Visual Resources SMALL SMALL SMALL to SMALL to SMALL to LARGE SMALL to MODERATE MODERATE MODERATE Air Quality SMALL SMALL SMALL SMALL to SMALL to SMALL MODERATE MODERATE Noise SMALL SMALL SMALL to SMALL to SMALL to SMALL to MODERATE MODERATE MODERATE MODERATE Geologic Environment SMALL SMALL SMALL SMALL MODERATE SMALL Surface Water Resources SMALL SMALL SMALL SMALL SMALL SMALL 2-22 Groundwater Resources SMALL to SMALL SMALL SMALL SMALL SMALL MODERATE Terrestrial Resources SMALL SMALL MODERATE MODERATE MODERATE MODERATE Aquatic Resources SMALL to SMALL MODERATE MODERATE to MODERATE to MODERATE MODERATE to LARGE LARGE LARGE Special Status Species and See Note(a) See Note(b) See Note(b) See Note(b) See Note(b) See Note(b) Habitats Historic and Cultural Resources See Note(c) See Note(d) See Note(e) See Note(e) See Note(f) See Note(e) Socioeconomics SMALL SMALL SMALL to SMALL SMALL SMALL MODERATE Transportation SMALL SMALL SMALL to SMALL to SMALL to SMALL to LARGE MODERATE MODERATE MODERATE Human Health SMALL(g) SMALL(g) SMALL(g) SMALL(g) SMALL(g) SMALL(g) Environmental Justice See Note(h) See Note(i) See Note(j) See Note(j) See Note(k) See Note(j) Waste Management and Pollution SMALL(l) SMALL(l) SMALL (l) SMALL SMALL SMALL Prevention

Turkey Point Combination Subsequent Alternative License Natural Gas (Natural Gas Renewal Combined- Combined-Cycle Cooling Water Impact Area (Proposed No-Action New Nuclear Cycle and Solar System (Resource) Action) Alternative Alternative Alternative Photovoltaic) Alternative (a) The NRC staff concludes that the proposed Turkey Point subsequent license renewal is likely to adversely affect the American crocodile and the eastern indigo snake and may result in adverse modification to designated critical habitat for the American crocodile. The proposed action may affect, but is not likely to adversely affect, the Florida bonneted bat, Florida panther, West Indian manatee, red knot, piping plover, wood stork, Everglades snail kite, Kirtlands warbler, Blodgetts silverbush, Cape Sable thoroughwort, Florida semaphore cactus, sand flax, Florida bristle fern, loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and smalltooth sawfish. The proposed action would result in no adverse modification to designated critical habitat of the West Indian manatee. The proposed action would have no adverse effects on Essential Fish Habitat. The evaluation of impacts to species and habitats under the U.S. Fish and Wildlife Services jurisdiction can be found in the NRCs Biological Assessment (NRC 2018n). The evaluation for species and habitats under the National Marine Fisheries Services jurisdiction can be found in Section 4.8. (b) The types and magnitudes of adverse impacts to species listed pursuant to the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.), designated critical habitat, and Essential Fish Habitat would depend on Turkey Point shutdown activities, the proposed alternative site, plant design, and operation, as applicable, and on the listed species and designated critical habitats present when the alternative is implemented. Therefore, the NRC staff cannot forecast a particular level of impact for this alternative. (c) Based on (1) the location of National Register of Historic Places-eligible historic properties within the area of potential effect, (2) tribal input, (3) FPLs cultural resource protection plans, (4) the fact that no license renewal-related physical changes or ground-disturbing activities would occur, (5) Florida State 2-23 Historic Preservation Office input, and (6) cultural resource assessment, license renewal would not adversely affect any known historic properties (Title 36 of the Code of Federal Regulations 800.4(d)(1), No Historic Properties Affected). (d) As a result of facility shutdown, land-disturbing activities or dismantlement are not anticipated as these would be conducted during decommissioning. Therefore, facility shutdown would have no immediate effect on historic properties or historic and cultural resources. (e) Since the alternative would be located at the Turkey Point site, which has a low archeological potential, and avoidance of significant resources would be possible, this alternative would not adversely affect known historic properties. (f) The impacts from the construction and operation of the solar component would depend on where solar facilities are constructed. The historic and cultural resource impact could range from no adverse effect to adverse effect. (g) The chronic effects of electromagnetic fields on human health associated with operating nuclear power and other electricity generating plants are uncertain. (h) There would be no disproportionately high and adverse impacts to minority and low-income populations. (i) A reduction in tax revenue resulting from the shutdown of Turkey Point could decrease the availability of public services in the Turkey Point area. However, the effects to minority and low-income populations would not be disproportionately high and adverse. (j) Based on the analysis of human health and environmental impacts presented in this SEIS, the location of the alternative, and the assumed alternative design and characteristics, this alternative would not likely have disproportionately high and adverse human health and environmental effects on minority and low-income populations. (k) This alternative would not likely have disproportionately high and adverse human health and environmental effects on minority and low-income populations. However, this determination would depend on the location of the solar facilities. Therefore, the NRC staff cannot determine whether the solar portion of the combination alternative would result in disproportionately high and adverse human health and environmental effects on minority and low-income populations. (l) NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, (NRC 2014c) discusses the environmental impact of spent fuel storage for the timeframe beyond the licensed life for reactor operations.

1 3 AFFECTED ENVIRONMENT 2 In conducting its environmental review of the Turkey Point Nuclear Generating Unit 3 Nos. 3 and 4 (Turkey Point, or Turkey Point Units 3 and 4) subsequent license renewal 4 application, the U.S. Nuclear Regulatory Commission (NRC) first defines and describes the 5 environment that could be affected by the subsequent license renewal. For this review, the 6 NRC staff defines the affected environment as the environment that currently exists at and 7 around the Turkey Point site. Because existing conditions are at least partially the result of past 8 construction and operations at the plant, this chapter presents the nature and impacts of these 9 past actions as well as ongoing actions, and evaluates how, together, these actions have 10 shaped the current environment. The effects of ongoing reactor operations at Turkey Point 11 have become well established as environmental conditions have adjusted to the presence of the 12 nuclear power plant. Sections 3.2 through 3.13 describe the affected environment for each 13 resource area. The resource discussions in this chapter include new and updated information 14 that became available since the NRC issued the supplemental environmental impact statement 15 (SEIS) for the initial Turkey Point license renewal in 2002, as NUREG-1437, Supplement 5 16 (NRC 2002c). 17 3.1 Description of Nuclear Power Plant Facility and Operation 18 The physical presence of Turkey Point buildings and facilities, as well as the plants operations, 19 are integral to the environment that currently exists at and around the site. This section 20 describes Turkey Point buildings, certain nuclear power plant operating systems, and certain 21 plant infrastructure, operations, and maintenance. 22 3.1.1 External Appearance and Setting 23 Turkey Point is located on the southeastern coast of Florida in unincorporated southeastern 24 Miami-Dade County. The site borders Biscayne Bay and Card Sound. Turkey Point is 25 approximately 25 miles (mi) (40 kilometers (km)) south-southwest of the city of Miami, which is 26 the largest population center in the region with an estimated population of 424,632. Portions of 27 Homestead Air Reserve Base and the cities of Florida City and Homestead are located within 28 approximately 9 mi (14.5 km) of the Turkey Point site. Miami, Florida City, Homestead, 29 Homestead Air Reserve Base, and Turkey Point are all located in Miami-Dade County, FL. 30 Florida City is located approximately 9 mi (14.5 km) west of Turkey Point and has an estimated 31 population of 12,000. The city of Homestead is located approximately 9 mi (14.5 km) 32 west-northwest of Turkey Point and has an estimated population of 65,000. Homestead Air 33 Reserve Base is located approximately 6 mi (9.7 km) northwest of Turkey Point and has an 34 estimated population of 1,100 (FPL 2018f). 35 Turkey Point Units 3 and 4 are two pressurized-water nuclear reactors located on approximately 36 9,460 acres (ac) (38.3 kilometers squared (km2)) of FPL-owned land. In addition to nuclear 37 generating Units 3 and 4, the Turkey Point site also houses three fossil fuel power plants: 38 Units 1 and 2 are retired, natural-gas/oil steam-generating units; and Unit 5 is an operating, 39 natural-gas combined-cycle steam generating unit. In addition to these five currently operating 40 and retired units, the Turkey Point site also features a 5,900-ac (24 km2) artificial body of water 41 called the cooling canal system (CCS). This network of canals forms a closed, recirculating 42 source of water that is used by Units 3 and 4 for reactor heat rejection. Unit 5 does not use the 43 cooling canals for heat rejection but does use the CCS for stormwater discharge and cooling 44 water blowdown. The principal structures for Turkey Point Units 3 and 4 are the reactor 3-1

1 containments, auxiliary building, control building, turbine building, radioactive waste 2 management building, intake structure, discharge structures, steam generator storage 3 compound, and administration building. The main structures outside the power block are an 4 independent spent fuel storage installation (ISFSI), a sewage treatment plant, a 230-kilovolt (kV) 5 switchyard, a meteorological tower, the cooling water intake canal, the cooling water discharge 6 canal, and the 5,900-ac (24 km2) network of cooling canals between them (FPL 2018f). 3-2

1 Figure 3-1 Map Showing the 50-mi (80-km) Radius Around the Turkey Point Site 2 (FPL 2018f) 3-3

1 3.1.2 Nuclear Reactor Systems 2 Turkey Point Units 3 and 4 are Westinghouse, three-loop pressurized-water reactors (PWRs) 3 with dry, ambient pressure containments. The NRCs predecessor agency, the Atomic Energy 4 Commission, issued the Turkey Point Unit 3 facility operating license on July 19, 1972 and the 5 Unit 4 facility operating license on April 10, 1973. Subsequently, on June 6, 2002, the NRC 6 issued renewed facility operating licenses for Turkey Point Units 3 and 4, authorizing an 7 additional 20 years of operation (NRC 2002b). Turkey Point Units 3 and 4 are each rated for a 8 reactor core power level of 2,644 megawatts thermal (MWt) (FPL 2018f). Together, Units 3 and 9 4 produce a combined total of 1,632 megawatts electric (MWe) (FPL 2018f). 10 Both the Unit 3 and Unit 4 reactor cores are composed of uranium dioxide pellets enclosed in 11 Zircaloy-4, ZIRLO, Optimized ZIRLO' high-performance fuel cladding material tubes with 12 welded end plugs. A spring clip grid structure supports the tubes in assemblies. The 13 mechanical control rods consist of clusters of stainless steel-clad absorber rods and guide tubes 14 located within the fuel assemblies (FPL 2018f). 15 3.1.3 Cooling and Auxiliary Water Systems 16 As mentioned earlier, Turkey Point Units 3 and 4 are both PWRs. PWRs heat water under 17 pressure to very high temperatures to create steam. That steam turns the turbines that then 18 generate electricity. PWRs use a closed-cycle cooling system to dissipate the heat in the water. 19 The closed-cycle cooling system uses three heat exchange loops to cool the water: (1) the 20 primary coolant loop, (2) the secondary loop, and (3) the cooling water loop. These are as 21 follows. 22 Primary Coolant Loop: In the primary coolant loop, water is drawn into the reactor and heated to 23 very high temperatures while under great pressure. The pressure keeps the water from turning 24 into steam. Water in the primary loop that has been heated in the reactor passes through a 25 steam generator where heat is transferred to water in a secondary loop. Once the heat is 26 transferred, the water in the primary coolant loop returns to the reactor to be heated again under 27 high pressure. 28 Secondary Loop: In the heat transfer process, the water in the primary loop and the water in the 29 secondary loop do not come into contact with each other. In the steam generator, the heated 30 water in the secondary loop is allowed to flash into steam, which is what drives the turbines that 31 in turn produce electricity. The water in the secondary loop (now in steam form), then travels to 32 the condenser where it transfers its heat energy to water in the third loop (called the cooling 33 water loop). When heat is transferred, the water temperature decreases and the steam water in 34 the secondary loop condenses back to liquid water. The liquid water in the secondary loop then 35 returns to the steam generator to be reheated. 36 Cooling Water Loop: As is the case with the transfer of heat between the primary coolant loop 37 and the secondary loop, in the condenser, the water in the secondary loop and the water in the 38 cooling water loop do not come into contact with one another. From the condenser, water in the 39 cooling water loop (third loop) can either flow to cooling towers (not present for Units 3 and 4) 40 where it is cooled by evaporation or it can be discharged directly to an external body of water 41 (NRC 2013a). Figure 3-2 below shows a simple schematic diagram of a generic PWR cooling 42 system with a cooling canal system. At Turkey Point, water from the cooling water loop is 43 discharged into a closed body of water called the cooling canal system (CCS). 3-4

1 The sections below describe in greater detail the cooling water loop, the CCS, the auxiliary 2 cooling water system, the fire protection water system, and the potable water system at Turkey 3 Point. Unless otherwise cited herein, the NRC staff drew information about Turkey Points 4 cooling and auxiliary water systems from the following sources: FPLs environmental report that 5 it submitted as part of the subsequent license renewal application (FPL 2018f), the NRC staffs 6 2002 SEIS for the initial Turkey Point license renewal published as NUREG-1437, 7 Supplement 5 (NRC 2002c), and the NRC staffs onsite environmental audit at Turkey Point in 8 June 2018. 9 Source: Modified from NRC 2013a 10 Figure 3-2 Generic Cooling System with Cooling Canal System 11 3.1.3.1 General Description of Cooling Water Loop 12 In a PWR closed-cycle cooling system, the primary function of the third loopthe cooling water 13 loopis to transport heat from inside the reactor to the outside environment. At Turkey Point, 14 the cooling water loop withdraws water from an artificially constructed body of water called the 15 cooling canal system (CCS) and discharges water back to the CCS. As described earlier in this 16 chapter, the CCS is a large body of water comprised of a network of canals spread over about 17 5,900 ac (24 km2). As with the rest of the Turkey Point site, FPL does not allow the public to 18 access the CCS. The CCS does not connect to any other surface water bodies. It is an 19 industrial wastewater (IWW) facility under the Clean Water Act and is not considered waters of 20 the United States or waters of the State (Figure 3-3). 21 The reactors discharge heated water from the cooling water loop into the discharge canal of the 22 CCS. From the discharge canal, the heated water travels through the length of the canal and 23 loses heat through evaporation. By the time the water returns to the Units 3 and 4 cooling water 24 intake canal, it is lower in temperature than when it was discharged. From the cooling water 25 intake canal, some water is pumped back into the cooling water loop where it is used to 26 dissipate heat from the secondary loop so that the steam water in the secondary loop 27 condenses back into liquid water. 28 Figure 3-3 illustrates the location where the Units 3 and 4 discharge structure releases heated 29 water into the CCS, the direction of water flow through the CCS, and the location where the 3-5

1 Units 3 and 4 intake structure draws cooling water from the CCS. Section 3.1.3.2, Cooling 2 Canal System (CCS), discusses the CCS and its operation in greater detail. 3 At the Units 3 and 4 cooling water intake structure, water from the CCS flows through bars that 4 prevent large objects from entering the intake structure. Then, the water flows through steel 5 trash racks and into four separated screen wells. The trash racks protect vertical traveling 6 screens against damage from heavy debris. The traveling screens have a 0.38-in (1-cm) mesh 7 size to remove smaller debris. The water then flows to one of four circulating water pumps. 8 The intake structure also contains three pumps that supply water to the condenser. Under 9 normal plant operating conditions, either one, two, or all three of these pumps may be in 10 operation. Inside the cooling water tubes of the condenser, plastic foam balls minimize 11 biological growth and other fouling. 12 The combined intake of water at the Turkey Point intake structure is 1,872 million gallons per 13 day (mgd) (7 million m3/day). This water is discharged back to the CCS where it is recirculated 14 for reuse again as cooling water. 3-6

1 Source: FPL 2018f 2 Figure 3-3 Flow of Water Through the Cooling Canal System 3 FPL originally built the CCS to service its fossil-fueled units and nuclear generating units. The 4 CCS currently services two nuclear generating units (Units 3 and 4), two retired fossil-fueled 5 units (Units 1 and 2), and one currently operating fossil-fueled unit (Unit 5) in varying capacities. 6 The NRC does not license the operation of the fossil-fueled units. 3-7

1 Historically, the CCS was also part of the cooling water system for Units 1 and 2. The CCS 2 functioned for them as it does for Units 3 and 4. As mentioned earlier, FPL retired Units 1 3 and 2, so these units no longer generate electricity. However, these retired units still circulate 4 water from the CCS (i.e., discharge water into and withdraw water from the CCS). FPL has 5 placed both units into synchronous condenser mode, which means they support transmission 6 reliability and help to stabilize and optimize electrical grid performance. FPL plans to continue 7 operating Units 1 and 2 in this mode through the period of subsequent license renewal. While in 8 synchronous condenser mode, Units 1 and 2 circulate 17.3 mgd (65,488 m3/day) of water from 9 the CCS. As Units 1 and 2 no longer produce steam, unlike Units 3 and 4, they no longer 10 discharge heated water to the CCS. 11 Unit 5 is a currently operating fossil fuel power plant that produces electricity through natural-12 gas combined-cycle steam generation. It uses four natural gas turbines and one heat-recovery 13 steam-powered generator. It does not use the CCS as part of its cooling water system. 14 Instead, Unit 5 uses cooling towers and obtains water for cooling from groundwater from the 15 Upper Floridan aquifer (see Section 3.5, Groundwater Resources). Heat generated by Unit 5 16 is lost to the atmosphere by the evaporation of water in the plants cooling towers. 17 While Unit 5 does not use the CCS for cooling, it does discharge blowdown water from its 18 cooling towers into the CCS. Blowdown water is produced as a result of the evaporation of 19 water in the cooling tower. Evaporation causes the mineral content of the remaining water that 20 does not evaporate to increase. Blowdown is produced by draining water with high mineral 21 concentrations from the cooling tower and replacing it with fresh water. Blowdown from Unit 5 22 cooling towers does not contribute heat to the CCS. At 10,000 gallons per day (gpd) 23 (38 m3/day), the volume of blowdown water discharged from Unit 5 to the CCS is relatively 24 small. 25 3.1.3.2 Cooling Canal System (CCS) 26 This section describes the physical dimensions of the CCS and its operation. 27 Layout of the Cooling Canal System 28 The CCS covers an area approximately 2-mi (3.2-km) wide by 5-mi (8-km) long and covers an 29 area of approximately 5,900 ac (24 km2). It was built to act as a cooling reservoir for Units 1, 2, 30 3, and 4 and as an industrial wastewater facility for liquid discharges from all operations at the 31 Turkey Point site. As previously described, while water from the CCS is circulated through 32 Units 1 and 2, only Units 3 and 4 now use the CCS for cooling. The CCS receives heated water 33 from Units 3 and 4 and distributes the water into 32 feeder channels (canals). Water in the 34 feeder channels flows south into a single collector channel that distributes water to seven return 35 channels (Figure 3-4). As the water flows through the channels, heat is lost, largely through 36 evaporation. Water in the return channels flows north where it is used to cool Units 3 and 4. 37 Units 3 and 4 return heated water to the CCS to repeat the cycle. Flows through the CCS are 38 approximately 1.3 million gallons per minute (gpm) (4.9 million liters per minute (Lpm)) 39 (FPL 2018f). 40 Prior to the construction of Units 3 and 4, the cooling system for Units 1 and 2 used a cooling 41 system with a once-through design. It withdrew water from and discharged water to Biscayne 42 Bay. However, a 1971 consent decree by the Federal District Court for the Southern District of 43 Florida (United States v. Florida Power and Light Company) required FPL to discharge all 44 cooling water from Turkey Point facilities into a closed-cycle cooling canal system. To comply 3-8

1 with this decree, FPL designed and constructed the CCS and ensured that it had no surface 2 water connection to any outside water body (i.e., Biscayne Bay or Card Sound) (NRC 2016a). 3 The CCS then replaced the previous Units 1 and 2 once-through cooling system. 4 The CCS consists of interconnected channels excavated into the underlying bedrock. The 5 bedrock is limestone and forms the top of the Biscayne aquifer. It is important to note that the 6 CCS is not built up above the land surface; instead, it was excavated into the bedrock. Water 7 levels in the channels are below the level of the land surface and below the top of the bedrock 8 (i.e., below the top of the Biscayne aquifer). Therefore, the limestone rock of the Biscayne 9 aquifer forms the bottom and sides of the CCS. 10 Perimeter berms surround the CCS. These berms are constructed on top of the bedrock and do 11 not contact the water in the CCS. They vary in height from 4 to 10 ft (1.2 to 3 m) above the 12 surface of the bedrock. The widths of the perimeter berms vary from 25 feet to well over 13 100 feet (7.6 m to 30.5 m) with an average width of more than 50 ft (15.2 m). The perimeter 14 berms are not in contact with water within the CCS. As mentioned previously, the water in the 15 CCS is below the top of the bedrock, while the perimeter berms are built on top of the bedrock. 16 The berms are not designed and built to contain CCS water; rather, these berms are designed 17 and built to prevent surface water from entering the CCS. 18 Most of the channels within the CCS are about 200 feet (60 m) wide and have a water depth of 19 1 to 3 feet (0.3 to 1 m). The average canal depth is 2.8 ft (0.85 m) (FPL 2018f). They are 20 separated by 90 foot (27 m) wide berms (NRC 2002c). A few of the channels within the CCS 21 have been excavated to a depth of approximately 20 ft (6.1 m). These deep channels are: 22

• The east-west distribution channel along the north side of the CCS 23
• The east-west collection channel along the south side of the CCS 24
• The north-south channel within the CCS, originally built to discharge water to Card 25 Sound 26
• The north-south channel along the east side of the CCS 27
• A few channels in the northeast corner of the CCS that connect to the intake basin 28 (Golder 2008, Morgan & Eklund 2010) 29 When the CCS was constructed, the previous canals that functioned as intake and discharge 30 canals into Biscayne Bay or Card Sound were either incorporated into the CCS or excluded 31 from it. Those previous canals that were excluded from the CCS have now become remnant 32 dead-end canals. The Barge Turning Basin in Biscayne Bay was walled off from the CCS.

33 Earthen plugs were installed between the CCS and the remnant dead end canals. Within the 34 plugs in the Turtle Point remnant canal that connects to Biscayne Bay and in the Card Sound 35 remnant canal that connects to Card Sound (see Figure 3-4), cement and bentonite slurry walls 36 have been constructed to prevent water seepage through them. In addition, both sides of these 37 plugs are protected with a layer of limestone rock to prevent surface erosion of the plug. The 38 Turtle Point remnant canal plug varies in width from 25 to 40 ft (7.6 to 12 m) and the Card 39 Sound remnant canal plug varies in width from 25 to 50 ft (7.6 to 15 m) (FPL 2016f). 40 In addition to the channels (canals) within the CCS, an interceptor ditch is located outside and 41 against the west side of the CCS. The ditch is not connected to the CCS or other surface 42 waters. However, it is a part of CCS operations. It parallels the entire length of the west side of 43 the CCS. It is constructed to a depth of approximately 18 ft (5.5 m) (Golder 2008). The purpose 3-9

1 of the interceptor ditch is to limit the amounts of saline groundwater that move from beneath the 2 CCS to areas west of the Canal L-31E Levee, to those amounts which would have moved to 3 those areas if the CCS did not exist (Figure 3-4) (FPL 2018f). 4 Source: Modified from SFWMD 2011a 5 Figure 3-4 Cooling Canal System and Adjacent Canals 3-10

1 Depending on the head levels (water levels) in the Biscayne aquifer relative to the head levels in 2 Biscayne Bay, groundwater beneath and around the Turkey Point site can either flow towards 3 the bay (east) or inland away from the bay (west). During wet times of the year, when 4 groundwater levels are high, groundwater flow is usually towards the bay. During dry times of 5 the year, when groundwater levels are low, groundwater flow is usually inland away from the 6 bay. 7 When surface water and groundwater monitoring data around the Turkey Point site indicate that 8 there is a potential for groundwater to flow inland (west), water is pumped from the interceptor 9 ditch and discharged into the CCS. This causes near-surface groundwater to flow towards the 10 interceptor ditch and captures near-surface groundwater below the CCS that is moving west 11 (FPL 2018f). The capture effect is likely limited to the depth of the interceptor ditch, which, at a 12 depth of about 18 ft (5.5 m), is a little deeper than the bottom of the L-31E Canal (Golder 2008). 13 Cooling Canal System Operation 14 Units 3 and 4 discharge heated water into the CCS. As this water travels through the length of 15 the CCS, it loses heat through evaporation. Evaporation not only removes heat from the water 16 in the CCS, but it also removes some of the water. Water lost through evaporation is replaced 17 by three main sources. The single largest contributor of new water to the CCS is water from 18 precipitation (e.g., rain). Historically, the second largest contributor has been saltwater from the 19 Biscayne aquifer that seeps into the CCS through the limestone bedrock. However, more 20 recently, a different water source has likely overtaken Biscayne aquifer seepage as the second 21 largest contributor of new water to the CCS. Specifically, as further discussed in 22 Section 3.5.2.3, Groundwater Use, brackish water supplied by FPLs wells that withdraw water 23 from the Floridan aquifer is likely a larger contributor of new water to the CCS than is provided 24 by the seepage of water from the Biscayne aquifer. 25 The CCS receives relatively minor additions of water from discharges from the interceptor ditch 26 and Unit 5 cooling tower blowdown. In extraordinary circumstances, FPL may add water to the 27 CCS from wells (marine wells near Biscayne Bay) that withdraw saltwater from the Biscayne 28 aquifer (see Section 3.5.2.3 for more detail). However, FPL seldom uses these marine wells 29 (FPL 2018f). 30 As mentioned earlier in this chapter, water in the CCS is not in contact with other surface water 31 bodies. However, the water in the CCS is in direct contact with the Biscayne aquifer and with 32 earthen plugs located in the perimeter of the CCS. These plugs seal off remnant canals from 33 the water in the CCS (FPL 2018f). As the Biscayne aquifer is highly permeable, water would be 34 more readily transmitted through it than through the relatively small areas occupied by the low 35 permeability earthen plugs on the perimeter of the CCS. The perimeter berms are not a likely 36 pathway for water to seep from the CCS as they are not in contact with the CCS water. 37 Not only does water leave the CCS by evaporation, some of the water also leaves the CCS 38 through the Biscayne aquifer. However, more water moves into the CCS from the Biscayne 39 aquifer than leaves the CCS to the Biscayne aquifer. FPL estimates that the inflow of 40 groundwater from the Biscayne aquifer into the CCS is about twice the volume of outflow of 41 water from the CCS into the Biscayne aquifer (FPL 2018f). 42 Sediments can build up in the channels of the CCS. These sediments can obstruct the lateral 43 flow of water through the CCS and can also lower the rate of water movement into the CCS 3-11

1 from the Biscayne aquifer. Therefore, CCS maintenance activities include the removal of 2 accumulated sediments as required to maintain adequate water flow in the CCS (FPL 2018f). 3 3.1.3.3 Auxiliary Cooling Water System 4 In addition to the cooling water loop, heat is also removed from Turkey Point operations by the 5 auxiliary cooling water system. This system is much smaller in its water requirements than the 6 cooling water loop. Auxiliary cooling water systems can include emergency core cooling 7 systems, containment spray and cooling systems, emergency feedwater systems, component 8 cooling water systems, and spent fuel pool water systems. At Turkey Point, the auxiliary cooling 9 water system consists of three loops: (1) the component cooling loop, (2) the residual heat 10 removal loop, and (3) the spent fuel pit cooling loop. These loops obtain water from the 11 Miami-Dade County public water supply system and discharge water to the CCS. 12 3.1.3.4 Fire Protection Water System 13 Fire protection water protects the plant in the event of a fire. At Turkey Point, the Miami-Dade 14 County public water supply system supplies the fire protection water as described below. 15 3.1.3.5 Potable Water System 16 Turkey Point uses approximately 1 mgd (3,800 m3/day of water from the Miami-Dade County 17 public water supply system. However, a water treatment plant, which supplies pure water for 18 steam-related use, was completed in 2017. This new plant has the ability to treat brackish 19 water at a rate of more than 1 mgd (3,800 m3/day from onsite wells that withdraw water from the 20 Upper Floridan aquifer (see Section 3.5.2.3, Groundwater Use). This will significantly reduce 21 the volume of potable water that FPL needs to obtain from the Miami-Dade County public water 22 supply system. 23 Potable water is used by the auxiliary cooling water system, fire protection system, and drinking 24 water system. Turkey Point discharges treated waste-process waters into the CCS, and 25 domestic wastewater is sent to an onsite sewage treatment plant. After treatment, FPL 26 disposes of water from the sewage treatment plant into the Biscayne aquifer through an 27 injection well. Beneath the Turkey Point site, the Biscayne aquifer contains saltwater (see 28 Section 3.5.1.4, Adjacent Surface Water Quality and Cooling Canal System Operation). 29 3.1.4 Radioactive Waste Management Systems 30 As a result of normal operations, equipment repairs and replacements, and normal maintenance 31 activities, nuclear power plants routinely generate both radioactive and nonradioactive waste. 32 Nonradioactive waste includes hazardous and nonhazardous waste. There is also a class of 33 wastecalled mixed wastewhich is both radioactive and hazardous. This section describes 34 the systems that FPL uses to manage (i.e., treat, store, and dispose of) these wastes. This 35 section also discusses other waste minimization and pollution prevention measures commonly 36 employed at nuclear power plants. 37 The NRC licenses all nuclear plants with the expectation that they will release some radioactive 38 material to both the air and water during normal operations. However, NRC regulations require 39 that gaseous and liquid radioactive releases from nuclear power plants must meet radiation 40 dose-based limits specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 20, 41 Standards for Protection Against Radiation, and the as-low-as-is-reasonably-achievable 3-12

1 (ALARA) criteria in 10 CFR Part 50, Appendix I, Numerical Guides for Design Objectives and 2 Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for 3 Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents. In other words, 4 the NRC places regulatory limits on the radiation dose that members of the public can receive 5 from a nuclear power plants radioactive effluents. For this reason, all nuclear power plants use 6 radioactive waste management systems to control and monitor radioactive wastes. 7 Turkey Point uses the waste disposal system, as needed, to collect and process radioactive 8 materials contained in liquid, gaseous, and solid waste produced as a byproduct of plant 9 operations. The waste disposal system ensures that the dose to members of the public from 10 radioactive effluents is reduced to levels that are ALARA in accordance with the NRCs 11 regulations. 12 Under an agreement between FPL and the Florida Department of Health (DOH), the DOH 13 Bureau of Radiation Control conducts the Turkey Point radiological environmental monitoring 14 program (REMP). Through the REMP, the Bureau of Radiation Control documents the 15 radiological impact, if any, to the public, site employees, and the environment from radioactive 16 effluents released during operations at Turkey Point. Section 3.1.4.5 below discusses the 17 REMP in more detail. 18 FPL uses its Offsite Dose Calculation Manual (ODCM) that contains the methods and 19 parameters for calculating offsite doses resulting from liquid and gaseous radioactive effluents. 20 These methods ensure that radioactive material discharges from Turkey Point meet NRC and 21 U.S. Environmental Protection Agency (EPA) regulatory dose standards. The ODCM also 22 contains the requirements for the REMP (FPL 2018f). 23 3.1.4.1 Radioactive Liquid Waste Management 24 FPL uses waste management systems to collect, analyze, and process radioactive liquids 25 produced at Turkey Point. These systems reduce radioactive liquids before they are released to 26 the environment. The Turkey Point Units 3 and 4 waste disposal system meets the design 27 objectives of 10 CFR Part 50, Appendix I, and controls the processing, disposal, and release of 28 radioactive liquid, gaseous, and solid wastes. 29 The plant collects liquid radioactive waste in sumps and tanks in the waste disposal system. 30 Plant personnel then sample and analyze these collected liquid wastes to determine the level of 31 radioactivity and to determine if subsequent treatment is necessary. Personnel then process 32 the liquid radioactive wastes as required by 10 CFR Part 20 and release them into the CCS 33 discharge streams. FPL uses radiation monitors and applies safety features for the discharge 34 stream to avoid releases in excess of 10 CFR Part 20 standards (FPL 2016i). 35 Radioactive liquid waste entering the waste holdup tanks (WHT) via gravity feed include 36 effluents from the chemistry laboratories, containment sumps, floor drains, showers, and other 37 miscellaneous sources which flow to waste and monitoring holdup tanks. The laundry waste is 38 segregated into one of two monitor tanks. In addition, other sources of liquid wastes include 39 Turkey Point steam generator blowdown and storm drains. These liquids are then pumped to 40 the waste monitor tank where the activity level is determined and recorded prior to discharge 41 through the radiation monitor. The chemical and volume control system (CVCS) receives 42 radwaste liquids from the reactor coolant loop drains, accumulators, and excess letdown. 3-13

1 According to FPLs environmental report submitted as part of the subsequent license renewal 2 application, liquid requiring cleanup before being discharged to the environment is processed by 3 the waste disposal demineralizer. Turkey Point routes the liquid from the waste disposal 4 demineralizer directly to one of the three radwaste facility waste monitor tanks or one of two 5 waste disposal system monitor tanks (FPL 2016i, Section 11.1.2). When one of the waste 6 monitor tanks is filled, it is isolated, recirculated, and sampled for analysis while one of the other 7 two tanks is in service. If analysis confirms the activity level is suitable for discharge, the liquid 8 is pumped through a flow meter and a radiation monitor and then released to the cooling canals 9 of the industrial wastewater facility. Otherwise, it can be returned to a waste holdup tank for 10 reprocessing (FPL 2016i, Section 11.1.2). Turkey Point monitors radioactive liquid discharge 11 from its systems to ensure that activity concentrations do not exceed regulatory limits. 12 FPLs use of these radioactive waste systems and the procedural requirements in the Offsite 13 Dose Calculation Manual ensure that the dose from radioactive liquid effluents at Turkey Point 14 complies with NRC and EPA regulatory dose standards. 15 FPL calculates dose estimates for members of the public using radioactive liquid and gaseous 16 effluent release data and atmospheric and aquatic transport models. Unit 3 and Unit 4 share 17 the liquid waste treatment system. Generally, FPL allocates all liquid releases on a 50/50 basis 18 to each unit. In addition, both units also share the gaseous releases from the shared gaseous 19 waste treatment system on a 50/50 basis. Turkey Points annual radioactive effluent release 20 reports contain a detailed presentation of the radioactive liquid and gaseous effluents released 21 from Turkey Point and the resultant calculated doses. The NRC staff reviewed 5 years of 22 radioactive effluent release data from 2013 through 2017 (FPL 2013b, 2014d, 2015a; 2016l, 23 FPL 2017e). A 5-year period provides a dataset that covers a broad range of activities that 24 occur at a nuclear power plant, such as refueling outages, routine operation, and maintenance 25 that can affect the generation of radioactive effluents. The NRC staff compared the data against 26 NRC dose limits and looked for indications of adverse trends (e.g., increasing dose levels) over 27 the period spanning from 2013 through 2017. Since the radioactive liquid effluents are released 28 from common areas shared by both Unit 3 and Unit 4, the resultant calculated doses presented 29 in the effluent release are divided in half to evaluate compliance with the Appendix I to 10 CFR 30 Part 50 dose criteria. The NRC staffs review of Turkey Points radioactive liquid effluent control 31 program showed that radiation doses to members of the public were controlled within the NRCs 32 and EPAs radiation protection standards contained in Appendix I to 10 CFR Part 50, 33 10 CFR Part 20, and 40 CFR Part 190. No adverse trends were observed in the dose levels. 34 Routine plant refueling and maintenance activities currently performed will continue during the 35 license renewal term. Based on the past performance of the radioactive waste system to 36 maintain doses from radioactive liquid effluents to be ALARA, similar performance is expected 37 during the license renewal term. The following summarizes the calculated doses from 38 radioactive liquid effluents released from Turkey Point Units 3 and 4 during the most recent 39 available year (2017): 40 Turkey Point Unit 3 in 2017 41

• The total-body dose to an offsite member of the public from Turkey Point Unit 3 42 radioactive effluents was 2.38x104 millirem (mrem) (2.38x106 millisievert (mSv)), which 43 is well below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50.

44

• The maximum organ dose (gastrointestinal tract) to an offsite member of the public from 45 Turkey Point Unit 3 radioactive effluents was 2.76x104 mrem (2.76x106 mSv), which is 46 well below the 10 mrem (0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50.

3-14

1 Turkey Point Unit 4 in 2017 2

• The total-body dose to an offsite member of the public from Turkey Point Unit 4 3 radioactive effluents was 2.38x104 millirem (mrem) (2.38x106 millisievert (mSv)), which 4 is well below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50.

5

• The maximum organ dose (gastrointestinal tract) to an offsite member of the public from 6 Turkey Point Unit 4 radioactive effluents was 2.76x104 mrem (2.76x106 mSv), which is 7 well below the 10 mrem (0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50.

8 The NRC staffs review of FPLs radioactive liquid effluent control program shows that the 9 applicant maintained radiation doses to members of the public that were within NRCs and 10 EPAs radiation protection standards in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 11 Title 40, Protection of Environment, of the Code of Federal Regulations (40 CFR) Part 190, 12 Environmental Radiation Protection Standards for Nuclear Power Operations. The NRC staff 13 observed no adverse trends in the dose levels. 14 Routine plant refueling and maintenance activities at Turkey Point will continue during the 15 subsequent license renewal term. Based on FPLs past performance in operating a radioactive 16 waste system at Turkey Point that maintains ALARA doses from radioactive liquid effluents, the 17 NRC staff expects that FPL will maintain similar performance during the subsequent license 18 renewal term. 19 3.1.4.2 Radioactive Gaseous Waste Management 20 Radioactive gaseous waste generated at Turkey Point is collected, processed, and stored until 21 its radioactivity level is low enough to permit discharge to the environment at concentrations 22 below 10 CFR Part 20 standards (FPL 2016i, Section 1.2.4) through the waste disposal system. 23 Sources of the radioactive gaseous waste at Turkey point include gas decay tanks, containment 24 purges, the refueling water storage tank via the vent line, the Turkey Point equipment hatch 25 during outages, and releases incidental to plant operations. This radioactive gaseous waste is 26 created during plant operation from degassing reactor coolant discharge to the chemical and 27 volume control system, displacement of cover gases, miscellaneous equipment vents, relief 28 valves, and sampling operation and gas analysis for hydrogen and oxygen in cover gases. 29 Most of the gas received by the waste disposal system is cover gas displaced from the chemical 30 and volume control system holdup tanks as they fill with liquid. Gaseous waste is stored in 31 decay tanks for natural decay and is then released through the monitored plant vent. The cover 32 gas is reused to minimize the number of tank releases. The gaseous waste is monitored and 33 released at a permissible rate and activity as prescribed by the ODCM. Radioactive gaseous 34 effluents from Turkey Point Units 3 and 4 are released through four monitored release points: a 35 common plant vent via a stack above the containment building (~200 feet), the Unit 3 spent fuel 36 pit vent (~110 feet), and the condenser air ejector vents (~51 feet) from each unit. 37 Gases that are vented to the vent header flow to the waste gas compressor suction header. 38 One of two compressors is in continuous operation with the second unit instrumented to act as 39 backup for peak load conditions or failure of the first compressor. From the compressors, gas 40 flows to one of the gas decay tanks. Gas held in the decay tanks can either be returned to the 41 chemical and volume control system holdup tanks or discharged to the atmosphere via the plant 42 vent at a controlled rate through a radiation monitor if it has decayed sufficiently for release 43 (FPL 2016i, Section 11.1.2). The gases in the tanks are sampled and analyzed to determine 44 the radioactivity level. The radioactivity level contained in each gas decay tank is restricted 3-15

1 (1) to ensure that if an uncontrolled release of the tank's contents were to occur, the resulting 2 total body exposure to an individual at the exclusion area boundary would not exceed 3 500 mrem/yr (5 mSv/yr) and (2) to control the concentration of potentially explosive gases to 4 below flammability limits. The decay tanks are used to contain the compressed waste gases 5 (hydrogen, nitrogen, and fission gases) until they decay and are ready to be vented to the 6 atmosphere. 7 FPLs use of this gaseous radioactive waste system and adherence to the procedural 8 requirements in the ODCM ensure that the dose from radioactive gaseous effluents complies 9 with NRC and EPA regulatory dose standards. 10 As discussed above, FPL calculates dose estimates for members of the public using radioactive 11 liquid and gaseous effluent release data and atmospheric and aquatic transport models. Unit 3 12 and Unit 4 share the gaseous waste treatment system. The following summarizes the 13 calculated doses from radioactive gaseous effluents released from Turkey Point during 2017: 14 Turkey Point Unit 3 in 2017 15

• The air dose at the site boundary from gamma radiation in gaseous effluents from 16 Turkey Point Unit 3 was 1.30x105 millirad (mrad) (1.3x107 milligray), which is well 17 below the 10 mrad (0.1 milligray) dose criterion in Appendix I to 10 CFR Part 50.

18

• The air dose at the site boundary from beta radiation in gaseous effluents from Turkey 19 Point Unit 3 was 2.96x105 mrad (2.96x107 milligray) dose which is well below the 20 20 mrad (0.2 milligray) dose criterion in Appendix I to 10 CFR Part 50.

21

• The dose to an organ (thyroid) from radioactive iodine, radioactive particulates, and 22 carbon from Turkey Point Unit 3 was 1.01x101 mrem (1.01x10-3 mSv), which is below 23 the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50.

24 Turkey Point Unit 4 in 2017 25

• The air dose at the site boundary from gamma radiation in gaseous effluents from 26 Turkey Point Unit 4 was 9.02x106 mrad (9.02x108 milligray), which is well below the 10 27 mrad (0.1 milligray) dose criterion in Appendix I to 10 CFR Part 50.

28

• The air dose at the site boundary from beta radiation in gaseous effluents from Turkey 29 Point Unit 4 was 2.07x105 mrad (2.07x107 milligray) dose which is well below the 30 20 mrad (0.2 milligray) dose criterion in Appendix I to 10 CFR Part 50.

31

• The dose to an organ (thyroid) from radioactive iodine, radioactive particulates, and 32 carbon from Turkey Point Unit 4 was 1.19x101 mrem (1.19x10-3 mSv), which is below 33 the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50.

34 The NRC staffs review of Turkey Points radioactive gaseous effluent control program showed 35 radiation doses to members of the public that were well below NRC and EPA radiation 36 protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 37 40 CFR Part 190. The NRC staff observed no adverse trends in the dose levels. 38 Routine plant refueling and maintenance activities at Turkey Point will continue during the 39 subsequent license renewal term. FPLs past performance operating the radioactive waste 40 system demonstrates that it is able to maintain ALARA doses from radioactive gaseous 3-16

1 effluents. Based on this record of past performance, the NRC staff expects that FPL will 2 maintain similar performance during the subsequent license renewal term. 3 3.1.4.3 Radioactive Solid Waste Management 4 At Turkey Point, low-level radioactive wastes (LLRW) are packaged and stored for subsequent 5 shipment and offsite burial under the plants waste disposal system. FPL packages Turkey 6 Point radioactive waste shipments in accordance with NRC requirements (10 CFR Part 71, 7 Packaging and Transportation of Radioactive Material), and U.S. Department of 8 Transportation (USDOT) requirements (Title 49, Transportation, of the Code of Federal 9 Regulations Part 173, ShippersGeneral Requirements for Shipments and Packagings, and 10 Part 178, Specifications for Packagings). 11 Under the waste disposal system, FPL packages all solid wastes in high-integrity containers 12 (HICs) for removal to disposal facilities. The HICs are designed to be placed into transfer casks 13 for shipment offsite for disposal. The HICs are also designed to be stored in the LLRW storage 14 facility while awaiting shipment offsite for disposal. The waste disposal system has been 15 designed as a waste process system, which includes demineralizers, monitor tanks, a 16 condensate tank, and associated pumps. Solid radioactive waste and potentially radioactive 17 wastes include spent resins, spent filters, and miscellaneous materials. Solid radioactive 18 wastes also include solids recovered from the reactor coolant system (RCS), solids in contact 19 with the liquids or gases associated with the reactor coolant process systems, and solids used 20 in support of the reactor coolant system operation. The largest volume of solid radioactive 21 waste is LLRW, which includes bead resin, spent filters, and dry active waste from outages and 22 routine maintenance. Turkey Point has developed long-term plans which ensure that 23 radioactive waste generated during the subsequent license renewal term will be sent directly for 24 disposal, stored onsite in existing structures, or shipped to an offsite licensed facility for 25 processing and disposal (FPL 2018f). 26 LLRW is classified as Class A, Class B, or Class C (minor volumes are classified as greater 27 than Class C). Class A includes both dry active waste and processed waste (e.g., dewatered 28 resins). Classes B and C normally include processed waste and irradiated hardware. The 29 majority of LLRW generated at Turkey Point during the subsequent license renewal period is 30 expected to be Class A waste and could be shipped to licensed processors, such as the Energy 31 Solutions facility in Oak Ridge, TN, for reduction and repackaging, and then shipped to a Class 32 A disposal facility such as the Energy Solutions facility in Clive, UT. Class B and C wastes 33 would constitute a low percentage by volume of the total LLRW generated. The LLRW storage 34 facility at Turkey Point can currently store approximately 5 years of Class B and Class C 35 wastes. 36 Class B and C wastes can be shipped to the Energy Solutions facility in Oak Ridge, TN, where 37 they can then be shipped to the Waste Control Specialist facility in Texas, which is licensed for 38 disposal of Classes A, B, and C wastes. Disposal of waste greater than Class C is the 39 responsibility of the Federal Government. The NRC licenses the storage of LLRW waste under 40 the general license provided to power reactor licensees under 10 CFR Part 50 (FPL 2016f). 41 In 2017, a total of eight LLRW shipments were made from Turkey Point to the Energy Solutions, 42 Bear Creek Road Facility (Oak Ridge, TN) (FPL 2018f) and Energy Solutions, Gallaher Road 43 Facility (Kingston, TN) (FPL 2018f). The total volume and radioactivity of LLRW shipped offsite 44 in 2017 was 6.00x102 cubic meters (m3) (2.12x104 cubic feet (ft3)) and 1.11x100 curies (Ci) 45 (4.12x104 megabecquerels (MBq)), respectively (FPL 2018f). During the subsequent license 3-17

1 renewal period, Turkey Point would continue with routine plant operation, refueling outages, and 2 maintenance activities that generate radioactive solid waste. The NRC also expects Turkey 3 Point to continue to ship radioactive solid waste offsite for disposal during the subsequent 4 license renewal period. 5 3.1.4.4 Radioactive Waste Storage 6 At Turkey Point, LLRW is stored temporarily onsite before being shipped offsite for treatment or 7 disposal at licensed LLRW treatment and disposal facilities. In its environmental report for the 8 Turkey Point subsequent license renewal application, FPL states that Turkey Point has 9 sufficient existing capability to store LLRW onsite. FPL also states in its environmental report 10 that its long-term needs for generated LLRW storage (including during the subsequent license 11 renewal term) do not require constructing additional onsite storage facilities (FPL 2018a). 12 Turkey Point stores its spent fuel in a spent fuel pool and in an onsite independent spent fuel 13 storage installation (ISFSI). The ISFSI safely stores spent fuel onsite in licensed and approved 14 dry cask storage containers. 15 If the U.S. Department of Energy does not begin to take possession of the spent nuclear fuel in 16 2031, FPL may need to expand the existing capacity of the Turkey Point Units 3 and 4 ISFSI. 17 This would require FPL to construct a new ISFSI pad to accommodate additional spent nuclear 18 fuel generated during the subsequent license renewal term (FPL 2018g). Alternatively, FPL 19 may choose to utilize a higher density storage system to create additional storage capacity and, 20 thereby, reduce the need to expand the ISFSI. At this time, FPL has not yet determined 21 whether to expand the ISFSI. 22 3.1.4.5 Radiological Environmental Monitoring Program 23 As stated above, the Florida Department of Health (DOH) Bureau of Radiation Control, per an 24 agreement between FPL and the DOH, conducts a radiological environmental monitoring 25 program (REMP) to assess the radiological impact, if any, to the public and the environment 26 from the operations at Turkey Point Units 3 and 4. 27 The REMP measures the aquatic, terrestrial, and atmospheric environment for ambient 28 radiation and radioactivity. Monitoring is conducted for the following: direct radiation, air, water, 29 groundwater, broad leaf vegetation, fish, shellfish, and sediment. The REMP also measures 30 background radiation (i.e., cosmic sources, global fallout, and naturally occurring radioactive 31 material, including radon). 32 In addition to the REMP, Turkey Point has an onsite groundwater protection program designed 33 to monitor the onsite plant environment for detection of leaks from plant systems and pipes 34 containing radioactive liquid (FPL 2018f). Information on the groundwater protection program is 35 contained in Section 3.5.2, Groundwater Resources, of this SEIS. 36 FPL states in its environmental report that it has detected tritium in groundwater but has not 37 detected Turkey Point Units 3 and 4-related gamma-emitting isotopes since establishing its NEI 38 07-07, Industry Ground Water Protection Initiative, program (FPL 2018f). Section 3.5.2 39 provides a summary of radionuclides detected in groundwater. For 2017, the highest observed 40 level of tritium in Turkey Point groundwater was reported as 13,600 pCi/L. For comparison, the 41 EPA primary drinking water standard or maximum contaminant level (MCL) for tritium is 42 20,000 pCi/L (40 CFR 141.16). Tritium is also found in surface water onsite. For 2017, the 3-18

1 maximum level measured was 24,483 pCi/L in the CCS. While some tritium levels measured in 2 the CCS were found to be higher than the EPA drinking water standard of 20,000 pCi/L, they 3 were still lower than the limits prescribed by Turkey Point Unit 3 and 4s Offsite Dose 4 Calculation Manual (FPL 2013a) for the plant, which for tritium is 30,000 pCi/L. Further, no 5 surface water or groundwater at the site is used for potable purposes. 6 The NRC staff reviewed 5 years of annual radiological environmental monitoring data from 2013 7 through 2017 (FPL 2014c, FPL 2015b, FPL 2016j, FPL 2017d, FPL 2018k). A 5-year period 8 provides a dataset that covers a broad range of activities that occur at a nuclear power plant, 9 such as refueling outages, routine operation, and maintenance that can affect the generation 10 and release of radioactive effluents into the environment. The NRC staff looked for indications 11 of adverse trends (e.g., increasing radioactivity levels) over the period of 2013 through 2017. 12 Based on its review of this information, the NRC staff found no apparent increasing trend in 13 concentration or pattern indicating either a new inadvertent release or persistently high tritium 14 concentrations that might indicate an ongoing inadvertent release from Turkey Point Units 3 15 and 4. The groundwater monitoring program at Turkey Point Units 3 and 4 is robust, and any 16 future leaks that might occur during the subsequent license renewal period should be readily 17 detected. All spills are well monitored, characterized, and actively remediated. The data show 18 that there were no significant radiological impacts to the environment from operations at Turkey 19 Point Units 3 and 4. 20 3.1.5 Nonradioactive Waste Management Systems 21 Like any other industrial facility, nuclear power plants generate wastes that are not 22 contaminated with either radionuclides or hazardous chemicals. 23 Turkey Point has a nonradioactive waste management system to handle its nonradioactive 24 hazardous and nonhazardous wastes. The waste is managed in accordance with FPLs 25 procedures. Turkey Point has a contact stabilization treatment plant for sanitary waste 26 (FPL 2018f) which is located west of the power block area. The treated wastewater is disposed 27 of through an approximately 25-cm (10-in.) diameter, 15-m (50-ft) deep underground injection 28 well located adjacent to the treatment facility. FPL disposes of residuals (wet sludge) at the 29 Miami-Dade Water and Sewer Departments (MDWSD) South District Wastewater Treatment 30 Facility (FPL 2018f). 31 The Miami-Dade County Department of Solid Waste Management is responsible for solid waste 32 collection, transport, and disposal in unincorporated portions of the county and in eight 33 municipalities. The Department of Solid Waste Management solid waste disposal system 34 consists of a resource recovery waste-to-energy facility and two landfills: (1) the North Dade 35 Landfill (a trash-only facility) and (2) the South Dade Landfill (a garbage and trash facility), 36 which are supported by three regional waste transfer stations. An approved solid waste 37 contractor collects and transports the solid waste generated at Turkey Point for disposal at 38 county facilities (FPL 2018f). Listed below is a summary of the types of waste materials 39 generated and managed at Turkey Point. 40

• Turkey Point is classified as a small quantity, hazardous waste generator. The amounts 41 of hazardous wastes generated are only a small percentage of the total wastes 42 generated. These wastes consist of paint wastes; spent, off-specification, and shelf-life 43 expired chemicals; and occasional project-specific wastes (FPL 2018f).

3-19

1

• Turkey Points nonhazardous wastes include plant trash and nonradioactive waste 2 (FPL 2018f).

3

• Other wastes include fluorescent lamps, batteries, and devices containing mercury; 4 electronics; and antifreeze (FPL 2018f).

5 For the fossil fuel facilities (Units 1 and 2, and Unit 5) and the Turkey Point site land 6 management facilities, FPL routes sanitary waste from showers, water closets, toilets, etc. to 7 Miami-Dade County-approved onsite septic systems. For the nuclear generating Units 3 and 4, 8 FPL routes domestic wastewater to an onsite, county- and State-permitted, contact stabilization 9 sewage treatment plant. This wastewater treatment plant (WWTP) discharges effluents to an 10 onsite, permitted, single Class V, Group 3 gravity underground injection well used to dispose of 11 domestic wastewater effluent (FPL 2018f). Wastewater residuals generated by this plant are 12 transported to an approved offsite facility (FPL 2018f). The clarified wastewater sludge is 13 monitored according to operational protocol 0-NCAP-103 to ensure that the disposed material 14 does not present an environmental or public health risk. 15 3.1.6 Utility and Transportation Infrastructure 16 The utility and transportation infrastructure at a nuclear power plant typically interfaces with the 17 public infrastructure systems available in the region. Such public infrastructure includes utilities, 18 such as suppliers of electricity, fuel, and water, as well as roads and railroads that provide 19 access to the site. The following sections briefly describe the existing utility and transportation 20 infrastructure at Turkey Point. Unless otherwise cited, the source of the Turkey Point 21 site-specific information in this section is FPLs environmental report submitted as part of the 22 subsequent license renewal application (FPL 2018f). 23 3.1.6.1 Electricity 24 Nuclear power plants generate electricity for other users; however, they also use their own 25 generated electricity to operate. In the event of a malfunction or interruption of onsite nuclear 26 power generation at Turkey Point, the facility would depend on offsite power sources to provide 27 power to engineered safety features and emergency equipment. If both Turkey Point nuclear 28 power generation and offsite power sources fail, the facility will use planned independent 29 backup power sources. 30 3.1.6.2 Fuel 31 Under its current renewed facility operating licenses, Turkey Point Units 3 and 4 are licensed for 32 fuel that is slightly enriched uranium dioxide (up to 5.0 percent by weight uranium-235). FPL 33 operates the reactors at an equilibrium core maximum fuel discharge burnup rate of 34 62,000 megawatt-days per metric ton uranium (MWd/MTU). FPL refuels each nuclear unit on 35 an 18-month schedule, which means at least one refueling every year and two refuelings every 36 third year. FPL loads the core fuel in three regions. New fuel is introduced into the outer 37 region, and partially spent fuel is moved inward into a checkerboard pattern at successive 38 refuelings when the inner region fuel is discharged to spent fuel storage (FPL 2018f). 39 The Turkey Point spent fuel storage pit provides underwater storage of spent fuel assemblies 40 and control rods after their removal from the reactor. The spent fuel pit is located in the auxiliary 41 building and can store up to 1,535 fuel assemblies, including 131 spent or fresh fuel assemblies 42 in the cask area rack, as well as miscellaneous fuel handling tools. FPL designed the cask area 3-20

1 of the spent fuel pit for the installation of a fuel transfer cask to allow fuel transfer operations. 2 The Turkey Point site has an ISFSI to provide Unit 3 and Unit 4 spent fuel capacity (FPL 2018f). 3 3.1.6.3 Potable Water 4 In addition to cooling and auxiliary water (previously described in detail in Section 3.1.3), 5 nuclear power plants require potable water for sanitary and everyday uses by personnel 6 (e.g., drinking, showering, cleaning, laundry, toilets, and eye washes). At Turkey Point, the 7 Miami-Dade County public water supply system supplies potable water to the site. 8 3.1.6.4 Transportation Systems 9 All nuclear power plants are served by controlled access roads. In addition to roads, many 10 plants also have railroad connections for moving heavy equipment and other materials. Plants 11 located on navigable waters may have facilities to receive and ship loads on barges. 12 The Turkey Point site transportation network includes U.S. highways, interstate highways, 13 multilane divided State highways, and local streets. Miami-Dade County operates public 14 transportation services including rail and bus service. Miami-Dade County also offers air 15 transportation infrastructure including airports, heliports, and a seaplane base; a seaport for 16 commercial freight and passenger service; and an intermodal transportation hub for air, rail, and 17 ship (FPL 2018f). Section 3.10.6, Local Transportation, describes these systems in more 18 detail. 19 3.1.6.5 Power Transmission Systems 20 For license renewal, including subsequent license renewal, the NRC (2013b) evaluates as part 21 of the proposed action the continued operation of those power transmission lines that connect 22 the nuclear power plant to the substation where it feeds electricity into the regional power 23 distribution system. The NRC also evaluates the continued operation of the transmission lines 24 that supply outside power to the nuclear plant from the grid. In its environmental report, FPL 25 stated the locations of in-scope transmission lines, which are shown in Figure 3-5 (FPL 2018f). 26 Turkey Point is connected to the 230-kV switchyard through an approximately 590-foot (180-m) 27 transmission line (FPL 2018f). 3-21

1 Figure 3-5 Turkey Point In-Scope Transmission Lines (FPL 2018f) 2 3.1.7 Nuclear Power Plant Operations and Maintenance 3 FPLs Turkey Point maintenance activities include inspection, testing, and surveillance to 4 maintain the current licensing basis of the facility and to ensure compliance with environmental 5 and safety requirements. Various programs and activities are currently in place at Turkey Point 6 to maintain, inspect, and monitor the performance of facility structures, systems, and 7 components. These activities include, but are not limited to, (1) in-service inspections of 3-22

1 safety-related structures, systems, and components, (2) quality assurance program, (3) fire 2 protection program, and (4) monitoring of radioactive and nonradioactive water chemistry. 3 Additional Turkey Point maintenance programs include those implemented to meet technical 4 specification surveillance requirements and those implemented in response to NRC generic 5 communications. Such additional programs include various periodic maintenance, testing, and 6 inspection procedures necessary to manage the effects of aging on structures and components. 7 FPL performs certain program activities during the operation of the units and performs others 8 during scheduled refueling outages. As stated above, reactor refueling at Turkey Point occurs 9 on an 18-month cycle (FPL 2018f). 10 3.2 Land Use and Visual Resources 11 Section 2.2.1 of NUREG-1437, Supplement 5 (the SEIS for the Turkey Points initial license 12 renewal) describes the general land use at Turkey Point Units 3 and 4 (NRC 2002c). This 13 information is incorporated here by reference. Section 2.2 of NUREG-2176, Environmental 14 Impact Statement for Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7 15 (NRC 2016a), also describes the land use at the Turkey Point site. This information is also 16 incorporated here by reference (NRC 2016a). No new and significant information was identified 17 during the review of FPLs environmental report for the Turkey Point Units 3 and 4 subsequent 18 license renewal (FPL 2018f), during the site audit at Turkey Point, the scoping process, or the 19 evaluation of other available information that would alter the discussion contained in the SEIS 20 for Turkey Points initial license renewal. 21 3.2.1 Land Use 22 Turkey Point Units 3 and 4 are located on the shore of Biscayne Bay in south Florida's 23 Miami-Dade County. The plant site is approximately 25 mi (40 km) south-southwest of Miami. 24 The nearest incorporated city limits are Homestead, which is approximately 9 mi (14.5 km) 25 west-northwest of the plant site, and Florida City, which is approximately 9 mi (14.5 km) west of 26 the plant site. The nearest community to the south is Key Largo, which is in Monroe County, FL 27 and is approximately 30 mi (48 km) by road from the plant site. 28 3.2.1.1 Onsite Land Use 29 Turkey Point Units 3 and 4 and associated structures and features, including the cooling canal 30 system, occupy approximately 8,000 ac (3,200 ha). The largest land use and land cover 31 categories within the Turkey Point property boundary are wetlands and open water, which 32 together compose approximately 93 percent of the site. The next largest land use category is 33 developed land (to support Turkey Point plant operations), which is approximately 6 percent of 34 the site (FPL 2018f). 35 Miami-Dade County has designated the land use zoning at the Turkey Point site, including all 36 units, undeveloped lands, and the cooling canal system, as either IU-3 (industrial districts, 37 unlimited manufacturing) or GU (interim district, uses depend on the character of the 38 neighborhood). Specifically, Turkey Point Units 3 and 4 are located on land zoned IU-3. The 39 remainder of the Turkey Point site is zoned GU, an interim district. In an interim district, zoning-40 assigned land uses depend on the character of the neighborhood; otherwise, EU-2 standards 41 apply (single-family 5-ac estate district) (FPL 2018f). 3-23

1 3.2.1.2 Coastal Zone 2 Section 307(c)(3)(A) of the Coastal Zone Management Act (CZMA) (16 U.S.C. 1456(c)(3)(A)) 3 requires that applicants for Federal licenses who conduct activities in a coastal zone provide a 4 certification that the proposed activity complies with the enforceable policies of the State's 5 coastal zone program. Turkey Point Units 3 and 4 are within the Florida coastal zone. The 6 Florida Department of Environmental Protection (FDEP) issued a license that constitutes 7 concurrence that FPLs activities at Turkey Point are consistent with the State of Floridas 8 approved coastal management program. The most recent conditions of certification for Turkey 9 Point Units 3 through 5 (PA 03-45) show Turkey Point Units 3 and 4 as being certified to be 10 consistent in 2008, with several modifications since then, the most recent having been issued 11 on March 29, 2016 (FDEP 2016b). 12 Land to the south and west of the Turkey Point site is in the Everglades Mitigation Bank where 13 wetlands are created, restored, or enhanced to provide compensatory mitigation of wetland 14 losses elsewhere. Under the joint federally and State-operated mitigation bank program, both 15 public and private entities can own lands in the program. FPL owns the Everglades Mitigation 16 Bank land, which comprises approximately 13,000 ac (5,300 ha) of relatively undisturbed 17 freshwater and estuarine wetlands. The U.S. Army Corps of Engineers, the U.S. Environmental 18 Protection Agency (EPA), the Natural Resources Conservation Service, the U.S. Fish and 19 Wildlife Service (FWS), and the National Marine Fisheries Service (NMFS) provide guidance on 20 the use of the mitigation bank to satisfy mitigation requirements of specific laws and provisions, 21 including Section 404 of the Federal Water Pollution Control Act (also known as the Clean 22 Water Act [CWA]) permit program, the wetland conservation provisions of the Food Security 23 Act, the National Environmental Policy Act (NEPA), and several other statutory provisions. The 24 FDEP, the South Florida Water Management District (SFWMD), and Miami Dade County guide 25 the mitigation bank program within Florida pursuant to the Florida Mitigation Banking Rule and 26 other State authorities. 27 3.2.1.3 Offsite Land Use 28 Biscayne Bay, located immediately adjacent to Turkey Point, is the predominant natural feature 29 in the vicinity of the Turkey Point site. As described earlier, the largest land use and land cover 30 category at Turkey Point is wetlands and open water, of which open water is the largest 31 component. The next largest land use and land cover category is wetland areas, comprised of 32 woody and emergent herbaceous wetlands. And finally, the third largest land use and land 33 cover category is developed land. 34 The pattern of land use and urban growth has remained essentially unchanged in 35 Miami-Dade County since 1975, which is when the County released the original Comprehensive 36 Master Development Plan (CMDP). The CMDP establishes a growth policy that encourages 37 development (1) at a rate commensurate with projected county population and economic 38 growth, (2) in a contiguous pattern around a network of high-intensity urban centers connected 39 to transportation facilities, and (3) in locations which optimize efficiency in public service delivery 40 and conservation of valuable natural resources (MDC 2017a). 41 3.2.2 Visual Resources 42 The Turkey Point site is relatively flat and sparsely populated with trees. The most visible 43 features are the containment structures for Units 3 and 4. They are the tallest structures on the 44 site at approximately 210 feet (64 m) tall (FPL 2018f). However, trees and other vegetation 3-24

1 screen most of Turkey Point Units 3 and 4 and supporting structures from roadways and 2 recreational areas west of the plant site. In addition, vegetation blocks the view of Turkey Point 3 Units 3 and 4 from the Biscayne National Park Dante Fascell Visitor Center and Homestead 4 Bayfront Park, although the units can be clearly seen from other areas of Biscayne National 5 Park, including much of Biscayne Bay. At night, light from Turkey Point is visible from several 6 locations outside the site, including from the Homestead-Miami Speedway and Biscayne Bay 7 (NRC 2016a). 8 3.3 Meteorology, Air Quality, and Noise 9 This section describes the meteorology, air quality, and noise environment in the vicinity of 10 Turkey Point. 11 3.3.1 Meteorology and Climatology 12 The State of Florida is characterized by a humid subtropical climate, with long, hot summers 13 and short, mild winters. The climate of Florida is largely influenced by the warm waters of the 14 Gulf of Mexico and western Atlantic. Air from the Gulf of Mexico moderates summer heat, 15 shortens winter cold spells, and provides moisture and heavy rainfall during all seasons. Florida 16 is subject to frequent thunderstorms during the summer, and historically, the State experiences 17 the highest annual number of thunderstorms in the United States. The State is also vulnerable 18 to tornados and tropical cyclones (tropical storms and hurricanes) that develop in the Gulf of 19 Mexico and western Atlantic. On average, tropical cyclones strike Florida three times every 20 5 years, and the Florida coast is vulnerable to severe flooding from these storms (NOAA 2013a, 21 Runkle et al. 2017). Turkey Point is located on the lower east coast of Florida. The general 22 climate in this area is subtropical marine, characterized by a long warm summer with abundant 23 rainfall followed by a mild dry winter (NCDC 2017). The Azores-Bermuda high-pressure system 24 dominates the circulation pattern in this region for most of the year, causing a tropical air mass 25 to prevail. Occasional cold continental air masses displace the maritime air during winter 26 (NRC 2016a). 27 Section 2.9.1 of the EIS for the Turkey Point Units 6 and 7 combined licenses (NRC 2016a) 28 describes in detail the areas specific climatological and meteorological conditions including 29 wind, temperature, precipitation, and severe weather. The NRC staff incorporates into this SEIS 30 the information in Section 2.9.1 of the COL EIS by reference. The NRC staff did not identify any 31 new and significant information relevant to the climatological and meteorological environment 32 beyond the information described in the EIS for the Turkey Point Units 6 and 7 combined 33 licenses that would alter the discussion contained in Section 2.9.1 of the COL EIS. 34 In the past 67 years (1950-2017), the following numbers of severe weather events have been 35 reported in Miami-Dade County (NCDC 2018): 36

• Hurricane: 10 events 37
• Tornado: 137 events 38
• Thunderstorm: 312 events 39
• Flood: 13 events 40 3.3.2 Air Quality 41 Under the Clean Air Act (CAA), 42 U.S.C. 7401, et seq., the EPA has set primary and 42 secondary National Ambient Air Quality Standards (NAAQS) (40 CFR Part 50, National Primary 3-25

1 and Secondary Ambient Air Quality Standards) for six common criteria pollutants to protect 2 sensitive populations and the environment: carbon monoxide (CO), lead (Pb), nitrogen dioxide 3 (NO2), ozone (O3), sulfur dioxide (SO2), and particulate matter (PM). NAAQS further categorize 4 particulate matter under two sizesPM10 (diameter between 2.5 and 10 micrometers) and PM2.5 5 (diameter of 2.5 micrometers or less). Table 3-1 presents the NAAQS for the six criteria 6 pollutants. 7 Table 3-1 Ambient Air Quality Standards Pollutant Averaging Time National Standard Concentration Carbon Monoxide (CO) 8-hour 9 ppm (primary standard) 1-hour 35 ppm (primary standard) Lead (Pb) Rolling 3-month average 0.15 µg/m3 Nitrogen Dioxide (NO2) 1-hour 100 ppb (primary standard) Annual 53 ppb (primary and secondary standard) Ozone (O3) 8-hour 0.070 ppm (primary and secondary standard)(a) Particulate matter less than 2.5 Annual 12 µg/m3 (secondary)

   µm (PM2.5)                                                           15 µg/m3 (secondary) 24-hour                          35 µg/m3 (primary and secondary standard)

Particulate matter less than 10 24-hour 150 µg/m3 (primary and secondary

   µm (PM10)                                                            standard)

Sulfur Dioxide (SO2) 1-hour 75 ppb (primary standard) 3-hour 0.5 ppm (secondary standard) Key: ppb = parts per billion; ppm = parts per million; µg/m3 = micrograms per cubic meter. To convert ppb to ppm, divide by 1000. (a) Final rule signed October 1, 2015, and effective December 28, 2015. The previous (2008) ozone (O3) standards additionally remain in effect in some areas. Primary standards provide public health protection, including the health of sensitive populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings. Source: EPA 2018a 8 With respect to meeting NAAQS, the EPA designates areas that meet the standards as areas of 9 attainment and areas that do not meet the standards as areas of nonattainment. Areas for 10 which there is insufficient data to determine attainment or nonattainment, the EPA designates 11 as unclassifiable. Areas that once did not meet the standards but now do meet the standards, 12 the EPA calls maintenance areas; maintenance areas are under a 10-year monitoring plan to 13 maintain the attainment designation status. States bear the primary responsibility for ensuring 14 attainment and maintenance under NAAQS. Under Section 110 of the Clean Air Act and related 15 provisions, States must submit, for EPA approval, State implementation plans (SIPs) that 16 provide for the timely attainment and maintenance of the NAAQS. 17 In Florida, air quality designations are made at the county level. For the purpose of planning 18 and maintaining ambient air quality under NAAQS, the EPA has developed air quality control 3-26

1 regions. Air quality control regions are intrastate or interstate areas that share a common 2 airshed. Turkey Point is located in Miami-Dade County, which is part of the EPAs Southeast 3 Florida Intrastate Air Quality Control Region (40 CFR 81.49, Southeast Florida Intrastate Air 4 Quality Control Region). This air quality control region consists of eight Florida counties: 5 Broward, Miami-Dade, Indian River, Martin, Monroe, Okeechobee, Palm Beach, and St. Lucie. 6 With respect to meeting NAAQS, EPA designates Miami-Dade County as 7 unclassifiable/attainment or better than national standards for all criteria pollutants 8 (40 CFR 81.310, Florida). The nearest designated nonattainment area (for the 2010 sulfur 9 dioxide primary standard) is in Hillsborough County, FL, which is nearly 200 mi (320 km) from 10 Turkey Point. 11 The Clean Air Act, Title V, Permits, requires States to develop and implement an air pollution 12 permit program. The FDEP regulates air emissions at Turkey Point under Title V air operation 13 permits (FDEP 2018c, FPL 2018f). Combined Turkey Point Units 1, 3, 4, and 5 are considered 14 one facility for purposes of the Prevention of Significant Deterioration permitting program and 15 Title V operating permits. However, FPL operates these four units under two separate Title V 16 permits: one for fossil fuel Units 1 and 5 (Permit 0250003-025-AV) (Unit 1, which has been 17 retired, was deleted from the permit upon its renewal in November 2018), and another for 18 nuclear Units 3 and 4 (Permit 0250003-028-AV). The FDEP issued Title V Air Operation 19 Permit 0250003-028-AV for Turkey Point Units 3 and 4 in April 2018, and this permit will expire 20 in 2023 (FDEP 2018c). Table 3-2 lists permitted air pollutant emission sources and air permit 21 specified conditions for Turkey Point Units 3 and 4. 22 Table 3-2 Permitted Air Emission Sources at Turkey Point Units 3 and 4 Equipment Air Permit Condition Five emergency diesel engines used to support plant equipment: PM, CO, and NOx limits

• Industrial back-up instrument air compressors (2)
• Backup service water feed system pump
• 10-meter meteorological tower generator
• Domestic wastewater system pump One emergency diesel generator engine for the South Dade 40 CFR Part 63, Subpart A, meteorological tower (NESHAP General Provisions)

One emergency diesel fire pump and 40 CFR Part 63, Subpart ZZZZ (NESHAP RICE) Four diesel-engine emergency generators Unregulated Two emergency diesel engines used to support plant equipment Key: PM = particulate matter, NOx = nitrogen oxides, CO = carbon monoxide, NESHAP = National Emission Standards for Hazardous Air Pollutants, RICE = reciprocating internal combustion engines Source: FDEP 2018c 23 Table 3-3 shows annual emissions from permitted sources at Turkey Point Units 3 and 4. FPL 24 operates diesel generators/engines at Turkey Point Units 3 and 4 only intermittently (usually 25 during testing or during outages) as these are intended to be used to supply backup emergency 26 power. According to the 2014 National Emissions Inventory, estimated annual emissions in 27 tons per year for Miami-Dade County are approximately 3,650 (sulfur dioxide); 28 49,600 (nitrogen dioxide); 335,000 (carbon monoxide); 33,000 (particulate matter less than 29 10 microns); and 86,900 (volatile organic compounds) (EPA 2018b). Turkey Point Units 3 and 4 3-27

1 air emissions from permitted sources make up 0.05 percent or less of Miami-Dade Countys 2 total annual emissions. Greenhouse gas emissions from operation of Turkey Point Units 3 and 3 4 are discussed in Section 4.15.3 of this SEIS. 4 Table 3-3 Estimated Air Pollutant Emissions from Turkey Point Units 3 and 4 Emissions (tons/year) Year SOx NOx CO PM10 VOCs 2012 1.5 16 2.1 1.8 0.8 2013 1.5 15 1.8 1.8 0.7 2014 1.8 19 2.4 2.2 0.9 2015 2.1 21 2.7 2.5 1.0 2016 1.7 17 2.0 2.0 0.8 Key: CO = carbon monoxide, NOx = nitrogen oxides, SOx = sulfur dioxides, PM10 = particulate matter less than 10 micrometers, VOC = volatile organic compounds To convert tons per year to metric tons per year, multiply by 0.90718. Source: FPL 2018f 5 The EPA promulgated the Regional Haze Rule to improve and protect visibility in national parks 6 and wilderness areas from haze, which is caused by numerous, diverse air pollutant sources 7 located across a broad region (40 CFR 51.308-51.309). Specifically, 40 CFR Part 81, Subpart 8 D, Identification of Mandatory Class I Federal Areas Where Visibility Is an Important Value, 9 lists mandatory Federal areas where visibility is an important value. The Regional Haze Rule 10 requires States to develop state implementation plans to reduce visibility impairment at Class I 11 Federal areas. At Turkey Point, the nearest Class I Federal area is Everglades National Park, 12 approximately 13 mi (21 km) west of Units 3 and 4 (FPL 2018f). Given Turkey Point Units 3 13 and 4s limited air emissions as presented in Table 3-3, there is little likelihood that ongoing 14 activities at Turkey Point Units 3 and 4 during the subsequent license renewal term would 15 adversely affect air quality and air quality-related values (e.g., visibility or acid deposition) in any 16 Class I Federal areas. 17 3.3.3 Noise 18 Section 2.2.8.4 of NUREG-1437, Supplement 5 (the SEIS for the Turkey Point initial license 19 renewal), describes general noise conditions at Turkey Point Units 3 and 4 (NRC 2002c). This 20 information is incorporated here by reference. Section 2.10.2 of the EIS for the Turkey Point 21 Units 6 and 7 combined licenses (NRC 2016a) also describes ambient noise conditions at the 22 Turkey Point site. This information is also incorporated here by reference (NRC 2016a). No 23 new and significant information about noise at the Turkey Point site was identified during the 24 review of available information, including FPLs environmental report for the Turkey Point 25 Units 3 and 4 subsequent license renewal (FPL 2018f), the site visit, or during the scoping 26 process that would alter the discussion contained in the SEIS for Turkey Points initial license 27 renewal. 28 FPL conducted a noise survey for the Turkey Point Units 6 and 7 COL application 29 environmental report in June 2008. The survey determined baseline ambient noise conditions 30 near the proposed Turkey Point Units 6 and 7 site (including describing noise from Turkey Point 31 Units 3 and 4) and identified sensitive offsite noise receptors. The nearest sensitive noise 3-28

1 receptors included residences to the northwest, a daycare facility to the west, and Homestead 2 Bayfront Park to the north (FPL 2014a). 3 In general, noise from the Turkey Point site can be detected under certain conditions by visitors 4 in Biscayne National Park. Noise is most noticeable under calm wind conditions or when the 5 wind is blowing lightly from the Turkey Point site to the park. Noise from Turkey Point 6 Units 3 and 4 is generally not an issue at the nearest sensitive noise receptors west of the plant 7 (a daycare facility) due to trees, other vegetation, and attenuation by distance. 8 3.4 Geologic Environment 9 This section describes the geologic environment of the Turkey Point site and vicinity, including 10 landforms, geology, soils, and seismic conditions. 11 3.4.1 Physiography, Geology, and Soils 12 The land surface at Turkey Point and the area around it is practically flat. Elevations rise from 13 sea level at the site to 10 feet (3 m) mean sea level (MSL) in the Homestead area 14 9 mi (14.5 km) to the west of Turkey Point. South Florida is underlain by gently dipping or 15 flat-lying sedimentary rocks. In South Florida, these sedimentary rocks are more than 15,000 ft 16 (4,572 m) thick. Limestone is the predominant rock found in the upper 5,000 ft (1,524 m) 17 (FPL 2018f). 18 The limestone rock is divided into stratigraphic units based on geologic properties. The left side 19 of Figure 3-6 identifies the stratigraphic units beneath Turkey Point down to a depth of greater 20 than 3,030 feet (924 m). For each stratigraphic unit, the figure also includes a brief description 21 of the rock characteristics (lithology), thicknesses, and depth. 22 The surficial material under Turkey Point consists of engineered fill. The surficial material within 23 the Turkey Point site, which includes Turkey Point Units 1, 2, 3, 4, and 5, and the CCS, consists 24 of either engineered fill, limestone, marl, or muck. Structures and roads are built on engineered 25 fill or limestone. Any soils within the Turkey Point site consist of marl or muck. The muck 26 consists of herbaceous organic material over limestone. The marl consists of loamy marine 27 deposits over limestone (FPL 2018f, USDA 2017). 28 3.4.2 Economic Resources 29 Significant deposits of oil, gas, and other mineable resources are not known to exist beneath the 30 Turkey Point site (NRC 2016a). Large quarries extract limestone rock in south Florida. This 31 mining area is known as the Lake Belt Region. Limestone is found at or near land surface 32 throughout the entire area. It is used as base material for roads and airport runways, as a 33 construction aggregate, and in cement manufacturing (FDOT 2007, NRC 2016a, USGS 2018b, 34 MDC 2017b). From Turkey Point, the nearest limestone quarrying is located 4.5 mi (7.2 km) 35 west of the site (MDC 2017b). Another nearby mining area is the Atlantic Civil rock mine 36 located about 10 mi (16 km) west of Turkey Point (NRC 2016a). Although the near-surface rock 37 at Turkey Point is composed of limestone, the sites location near Biscayne Bay National Park 38 and its saltwater content makes it an unlikely choice for a future limestone mine. 3-29

1 3.4.3 Seismic Setting 2 Florida has a very small probability of experiencing damaging earthquake effects 3 (FEMA 2018a). Based on historical or statistical seismic activity, Turkey Point is located in an 4 inactive area for earthquakes and far from any recorded damaging shocks (FPL 2018f). Even 5 so, the NRC evaluates the potential effects of seismic activity on a nuclear power plant in an 6 ongoing process that is separate from the license renewal process. The NRC requires every 7 nuclear plant to be designed for site-specific ground motions that are appropriate for its location. 8 Nuclear power plants, including Turkey Point, are designed and built to withstand site-specific 9 ground motion based on their location and the potential for nearby earthquake activity. The 10 seismic design basis is established during the initial siting process, using site-specific seismic 11 hazard assessments. For each nuclear power plant site, applicants estimate a design-basis 12 ground motion based on potential earthquake sources, seismic wave propagations, and site 13 responses, and then account for these factors in the plants design. In this way, nuclear power 14 plants are designed to safely withstand the potential effects of large earthquakes. Over time, 15 the NRCs understanding of the seismic hazard for a given nuclear power plant may change as 16 methods of assessing seismic hazards evolve and the scientific understanding of earthquake 17 hazards improves (NRC 2014a). As new seismic information becomes available, the NRC 18 expects that licensees will evaluate the new information to determine if safety systems at a plant 19 require changes. Independently, the NRC also evaluates new seismic information and confirms 20 that licensees appropriately consider potential changes in seismic hazards at the site. 3-30

1 Source: NRC 2016a 2 Figure 3-6 Geologic Stratigraphy and Major Aquifers Beneath the Turkey Point Site 3 3.5 Water Resources 4 This section describes surface water and groundwater resources at and around the Turkey 5 Point site, with an emphasis on Turkey Point, Units 3 and 4. 6 At the Turkey Point site, surface water (including the areas freshwater canals, wetlands, and 7 the adjoining Biscayne Bay) and groundwater are closely connected. This close relationship is 8 attributable to the very high permeability of the underlying Biscayne aquifer, which permits water 9 to move relatively freely between the surface and subsurface and vice versa. As a result, the 3-31

1 CCS is hydraulically connected to surface waters including Biscayne Bay via the groundwater 2 pathway. These factors have been considered as part of the NRC staffs characterization of 3 surface water and groundwater resources as presented in Sections 3.5.1 and 3.5.2 below, as 4 well as in the staffs impact analyses for water resources presented in Section 4.5, Water 5 Resources. 6 3.5.1 Surface Water 7 Surface water encompasses all water bodies that occur above the ground surface, including 8 rivers, streams, lakes, ponds, and man-made reservoirs or impoundments. 9 3.5.1.1 Surface Water Hydrology 10 Local and Regional Hydrology 11 Biscayne Bay and the area around Turkey Point are part of the South Florida Hydrologic 12 System (Figure 3-7). This encompasses a large area that includes the Everglades and South 13 Florida coastal areas. Human activities have extensively influenced this system principally by 14 population increases and land-use changes that resulted in the conversion of wetlands to 15 agriculture and other uses. A significant contributor to these changes was the use of canals to 16 drain land and redistribute surface water to other areas. 17 The South Florida Hydrologic System and how it has changed over time is described in the EIS 18 for the Turkey Point Units 6 and 7 combined licenses (NRC 2016a) in Section 2.3.1.1 from 19 pages 2-25 to 2-30, including Figures 2-8, 2-9, 2-10, and 2-11. The NRC staff incorporates the 20 above text and figures into this SEIS by reference. 21 The regional surface water system west of Biscayne Bay encompasses the area east and south 22 of the section of the Atlantic Coastal Ridge (ACR) near Biscayne Bay. Historically, various 23 natural swales or glades and sloughs conveyed freshwater eastward to the coastal wetlands 24 adjacent to Biscayne Bay and Card Sound. From there, freshwater discharged into Biscayne 25 Bay and Card Sound either directly by surface water from the coastal wetlands or indirectly 26 through groundwater. Under current conditions, manmade canals crisscross the landscape. 27 These canals drain the land for agriculture and urban use, provide flood control, and discharge 28 their freshwater into Biscayne Bay and Card Sound (NRC 2016a). 29 The canals also have an indirect impact on groundwater resources. Draining the land causes 30 the water level in near-surface aquifers to drop. This in turn has contributed to the inland 31 movement of groundwater that contains salt (saltwater intrusion) from Biscayne Bay and Card 32 Sound (see Section 3.5.2). The canals contain control structures to prevent the inland 33 movement of surface water from Biscayne Bay and Card Sound. During the wet season 34 (typically, the months of June - October), coastal control structures periodically open and 35 discharge freshwater to Biscayne Bay. During the dry season, coastal control structures 36 generally remain closed to maintain relatively high water levels along the coast and prevent 37 saltwater intrusion within near-surface aquifers. (USGS 2001). 38 The Turkey Point Units 6 and 7 COL EIS (NRC 2016a) in Section 2.3.1.1 (on Pages 2-31 39 and 2-32, including Figure 2-12) describes the regional surface water system west of Biscayne 40 Bay and how it has changed over time. The NRC staff incorporates this text and figure into this 41 SEIS by reference. 3-32

1 Source: Modified from NRC 2016a 2 Figure 3-7 Turkey Point Site, Biscayne Bay, Card Sound, and Regional Canals 3-33

1 Biscayne Bay and Card Sound 2 Biscayne Bay is located east of and adjacent to the Turkey Point site. (Figure 3-7). Card Sound 3 is located to the southeast of the site. Both are shallow bays that formed in depressions in the 4 limestone bedrock. The bays are bounded on the east by coral keys that are formed from 5 wave-resistant limestone. Both Biscayne Bay and Card Sound are in direct contact with the 6 Biscayne aquifer as the limestone rock of the aquifer forms the bottom of both bays (see 7 Section 3.5, Groundwater Resources) (NPS 2015a, NPS 2012, NRC 1972, USGS 2008b). 8 Biscayne Bay and Card Sound are separated by Cutter Bank which is an underwater 9 topographic rise (mud bank) (NRC 1972). Near the Turkey Point site, both Biscayne Bay and 10 Card Sound are shallow bays. Within Biscayne Bay, over most of the distance between the 11 Turkey Point site and the coral keys, the depth of the water generally ranges from 2 to 6 ft 12 (0.6 to 1.8 m), reaching a maximum depth of about 7 ft (2.1 m). Within Card Sound, over most 13 of the distance between the Turkey Point site and the coral keys, the depth of the water 14 generally ranges from 4 to 9 ft (1.2 to 2.7 m), reaching a maximum depth of about 10 ft (3 m) 15 (NOAA 2018a). Both Biscayne Bay and Card Sound are connected to the Atlantic Ocean by 16 gaps between the coral keys. However, near the Turkey Point site, the enclosed configuration 17 of the coral keys has isolated much of Biscayne Bay and Card Sound from direct marine 18 influence (USGS 2008b). 19 The hydrology and hydrodynamics of Biscayne Bay and Card Sound are influenced by several 20 factors: (1) tidal exchange of marine waters from the Atlantic Ocean, (2) surface and 21 groundwater inflows of freshwater, (3) precipitation, and (4) evaporation (NRC 2016a). All of 22 these factors also influence the salinity in Biscayne Bay and Card Sound. During the wet 23 season, precipitation decreases the salinity in the bay and the sound. During dry periods, 24 evaporation increases salinity within the bay and the sound, and salinities can become 25 hypersaline (NRC 2016a). 26 The construction of drainage canals on the mainland has also impacted salinity in the bay and 27 sound. This impact is greatest in the near-shore areas adjacent to the mainland. Prior to the 28 construction of drainage canals, freshwater entered the bay and sound from the mainland by 29 widespread sheet flow and groundwater discharge. This provided a more uniform and 30 continuous supply of freshwater to the bay and the sound than the present situation. With the 31 construction of drainage canals, freshwater was less uniformly distributed as the canals 32 discharged freshwater at discrete locations. The result is that areas near canal discharge 33 locations have less saline water than areas farther away from the discharge locations 34 (NRC 2016a). 35 Another way that drainage canals have impacted salinity in the bay and the sound is through 36 seasonal differences in the amount of canal discharge. The canals generally discharge the 37 most freshwater into the bay and sound during wet times of the year and the least during dry 38 periods. As a result, salinity concentrations throughout the year in the bay and sound are more 39 variable in time and space than prior to the construction of drainage canals (NRC 2016a). 40 Around the Turkey Point site, drainage canals discharge to Biscayne Bay north of the site and to 41 Card Sound south of the site. The Turkey Point site occupies an area of former sheet flow that 42 discharged into the bay. However, development of the sites location blocks sheet flow from 43 reaching Biscayne Bay (NRC 2016a). 3-34

1 Pollution from human activities also impacts the water quality of Biscayne Bay. Sections of the 2 shoreline of Biscayne Bay are highly developed. The southern end of Biscayne Bay and Card 3 Sound is less urbanized than the northern section of Biscayne Bay. Pollutants can potentially 4 enter Biscayne Bay from multiple sources, including boats, canals, quarrying operations, 5 landfills, military operations, a sewage-treatment plant, urban and agricultural runoff, and 6 submarine groundwater springs (USGS 2008b). 7 The EIS for the Turkey Point Units 6 and 7 combined licenses (NRC 2016a) in Section 2.3.1.1 8 (on pages 2-33 through 2-38, including Figures 2-14, and 2-15, and Table 2-8) describes the 9 hydrology and hydrodynamics of Biscayne Bay. The NRC staff incorporates the above text and 10 figures into this SEIS by reference. 11 Management of Biscayne Bay and Card Sound Water Quality 12 The Florida legislature has designated Biscayne Bay and Card Sound, including Biscayne 13 National Park, as Outstanding Florida Waters. This affords these waters the highest water 14 quality protections in the State (NRC 2016a; Robles, et al 2005; NPS 2012). The FDEP cannot 15 issue permits for direct discharges to Outstanding Florida Waters that would lower ambient 16 (existing) water quality and may not issue permits for indirect discharges that would significantly 17 degrade a nearby waterbody designated as an Outstanding Florida Water (FDEP 2017a). 18 Card Sound and the north half of Biscayne Bay are within the Biscayne Bay Aquatic Preserve. 19 The FDEPs Office of Coastal and Aquatic Managed Areas manages this preserve 20 (NRC 2016a). One of the management goals is to protect and enhance the waters of the 21 preserve so the public may enjoy the traditional recreational uses of those waters such as 22 swimming, boating, and fishing. No wastes or effluents which substantially inhibit the 23 accomplishment of these purposes can be discharged into the preserve 24 (Florida Statute 258.397). 25 The rest of Biscayne Bay is within Biscayne National Park (Park), including the Biscayne Bay 26 waters adjacent to the Turkey Point site (NRC 2016a). Biscayne National Park was established 27 in order to preserve and protect for the education, inspiration, recreation, and enjoyment of 28 present and future generations a rare combination of terrestrial, marine, and amphibious life in a 29 tropical setting of great natural beauty (USGS 2008b). The park is managed by the U.S. 30 National Park Service. In 2015, a Final General Management Plan was completed for the Park. 31 This plan contains strategies on the management of the resources and activities within the Park 32 to best fulfill Biscayne National Park's mission. It can be found under reference NPS 2015a. 33 Marshland and Mangrove Areas Adjacent to the Turkey Point Site 34 The Turkey Point site is adjacent to marshland outside its northwest, west, and southern 35 boundaries and a significant portion of its eastern boundary. Surface water within the 36 marshland lies on top of muck, which in turn lies on top of the Biscayne aquifer. The surface 37 water hydrology of the marshlands is driven by rain, surface water runoff, freshwater canal 38 overflows, and saltwater from Biscayne Bay and Card Sound (tides, storms, groundwater) 39 (FPL 2016a). Mangrove areas are located adjacent to Biscayne Bay. Soil pore water samples 40 from the marshland muck show that the marshlands adjacent to and west of the Turkey Point 41 are filled with freshwater, whereas marshlands adjacent to and south and east of the Turkey 42 Point site are filled with brackish water. The marshlands become more brackish the closer they 43 are to Biscayne Bay or Card Sound (FPL 2014b, 2016a, 2017a). 3-35

1 Canals Adjacent to the Turkey Point Site 2 A network of drainage canals provides freshwater and drainage to southeastern Florida 3 (FPL 2018f). Some of these canals can be found near the Turkey Point site (Figure 3-4). The 4 CCS does not have a surface water connection with any of these canals. North of the Turkey 5 Point site, the Florida City Canal runs east to west and discharges fresh water into Biscayne 6 Bay (FPL 2014a). West of the Turkey Point site, the L-31E Canal contains freshwater and runs 7 northeast to southwest (FPL 2016a). 8 South of the Turkey Point site, the S-20 Canal and the Sea Dade Canal remnant canal run east 9 to west. The S-20 Canal runs outside the southeast corner of the CCS. It is connected to the 10 L31E Canal by a flow control structure on its western end and connects to Card Sound south of 11 the site. The S-20 Canal contains fresh water when water is being discharged through it and 12 marine water when there is no fresh water discharge through it. The Sea Dade Canal once 13 connected to the S-20 Canal; however, under the provisions of the Everglades Mitigation Bank 14 program, the Sea Dade Canal was plugged off from the S-20 Canal. The Sea Dade Canal is 15 currently a remnant, dead-end canal with no connection to either the Card Sound or Biscayne 16 Bay. The Card Sound remnant canal is also adjacent to the CCS. It runs in a generally north-17 south direction and dead ends against the outside of the CCS. It contains marine water and 18 connects to Card Sound. 19 Potential for Flooding at the Turkey Point Site 20 The NRC evaluates the potential effects of floods on a nuclear power plant in a separate and 21 distinct process, outside of the license renewal process. The NRC addresses flood hazard 22 issues on an ongoing basis at all licensed nuclear facilities (NRC 2013a). The NRC requires 23 every nuclear power plant to be designed for site-specific floods, to assure protection for safety-24 related equipment and facilities. As new information on flood hazard issues becomes available, 25 the NRC expects each licensee to evaluate the new information to determine if its plant requires 26 changes to protect its safety systems. The NRC also evaluates new information important to 27 flood projections and independently confirms that a licensees actions appropriately consider 28 potential changes in flooding hazards at the site. 29 FPL recently completed a flood analysis for Turkey Point Units 3 and 4 and submitted its 30 analysis to the NRC in a process that was separate from subsequent license renewal. After 31 extensive review, the NRC approved this flood analysis on June 29, 2017 (NRC 2017b). FPLs 32 flood analysis used conservative methodology and assumptions, including tidal flooding during 33 hurricanes and future sea level rise during the currently licensed period (ending in July 2032 34 and April 2033 for Unit 3 and Unit 4, respectively). 35 Class 1 structures on the Turkey Point site are flood protected up to a minimum elevation of 36 20 feet (6.1 m) MSL. Components vital to safety, with the exception of the intake cooling 37 water (ICW) pumps, which are protected to 22.5 feet (6.9 m) MSL, are protected against flood 38 tides and waves up to 22 feet (6.7 m) MSL on the east side of Turkey Point (FPL 2018f). 39 In an emergency, if Turkey Point Units 3 and 4 are unable to obtain cooling water from the CCS, 40 the reactors would be placed in a safe shutdown mode. While in this mode, the reactors would 41 still need to be cooled, but would require much less cooling water. Should this situation ever 42 occur, water for cooling would be supplied from a protected well that obtains brackish water 43 from the Upper Floridan aquifer. 3-36

1 For structures that are important to the safe operation of the nuclear units, the NRC requires 2 that they be designed and operated in consideration of potential flooding. The NRC does not 3 have similar requirements for nonsafety-related. At the Turkey Point site, such structures 4 include, for example, office buildings, the Unit 5 cooling towers, and the CCS. 5 Tidal flooding during hurricanes is the major flooding concern at the Turkey Point site. The 6 highest tide nearest the site was recorded in September 1965 during Hurricane Betsy and 7 reached an elevation of 10.1 ft (3.1 m) MSL. The station where the measurement was made is 8 located north of Palm Drive on the Florida City Canal, approximately 2.3 mi (3.7 km) west of the 9 shoreline. In 1965, debris marks from the flood tide associated with Hurricane Betsy were seen 10 at an elevation of approximately 10 ft (3 m) MSL at the Turkey Point Site (FPL 2018f). 11 Because of the low flat terrain, tidal floodwaters in the Turkey Point area can move inland 12 several miles and can cover large areas. Construction of flood control projects in the area have 13 reduced the possibility of tidal floodwaters reaching agricultural and populated areas. The 14 L-31E Canal, which is not part of the Turkey Point site, is designed to provide flood protection to 15 properties further west. This canal is located west of the Turkey Point site and generally runs 16 from southwest to northeast. It includes a levee with a crest elevation of 7 ft (2.1 m) MSL. 17 However, it is not designed to prevent flooding from severe hurricanes with tidal flooding. 18 Based on published storm-tide frequency studies, it is estimated that a 7 ft (2.1 m) tide may 19 occur once every 20 to 25 years near the Turkey Point site (FPL 2018f). 20 The Federal Emergency Management Agency (FEMA) has prepared flood zone maps that 21 cover the Turkey Point site and surroundings (Figure 3-8). Except for Units 3 and 4, FEMA 22 maps most of the Turkey Point property and the surroundings as Zone A (FPL 2018f). A 23 Zone A area has a 1-percent annual chance of flooding within any single year (FEMA 2014). 24 The water depth of a flood with a 1-percent chance of annual flooding in any single year is 25 called the base flood (FEMA 2018b). 26 Within the Turkey Point site, FEMA designates a small area near the shoreline along the 27 northeastern property line as within the coastal flood zone with hazardous wave action, and with 28 base flood depths of 14 to 17 feet (4.3 to 5.2 m) (NAVD88). FEMA designates approximately 29 27 percent of the Turkey Point property as within the coastal flood zone with base flood depths 30 of 11 to 14 ft (3.4 to 4.3 m). However, the remaining 70 percent of the site where the canal 31 system is located has no base flood elevations determined by FEMA. Inland from and just 32 outside and along the western boundary of the CCS, base flood depths range from 8 to 11 ft 33 (2.4 to 3.4 m) (FPL 2018f). 34 The increased potential for future coastal flooding based on climate change projections is 35 discussed in Section 4.15.3.2 (Climate Change) of this SEIS. 36 3.5.1.2 Surface Water Consumption 37 Surface water resources are not consumed by Turkey Point operations. All water consumed by 38 Turkey Point is derived from groundwater resources. 3-37

1 Source: From FPL 2018f 2 Figure 3-8 FEMA Flood Zones Map of the Turkey Point Property 3 3.5.1.3 Surface Water Discharges 4 Operations at Turkey Point do not discharge to surface water bodies outside of the Turkey Point 5 site. All surface water discharges from Turkey Point activities are directed into the CCS, which 6 does not connect to any other surface water bodies. 7 Sanitary wastewater from Turkey Point is routed to an onsite, county- and State-permitted, 8 contact stabilization sewage treatment plant. Effluent from this wastewater treatment plant is 9 discharged to an onsite, permitted, single Class V, Group 3 gravity underground injection well. 10 The well is used to dispose of up to 35,000 gpd (132 m3/day) of domestic wastewater effluent. It 11 discharges into the top of the Biscayne aquifer and is open from 42 to 62 feet (12.8 to 19 m) 3-38

1 below ground surface. Any wastewater residuals are transported to an approved offsite facility. 2 FPL monitors the clarified wastewater sludge to ensure it does not present a risk to the 3 environment or to public health (FPL 2018f). The Florida Department of Environmental 4 Protection manages sanitary waste under FDEP Sewage Treatment Facility Domestic 5 Wastewater Facility Permit No. FLAO13612-002-DW3P and FDEP Sanitary Wastewater 6 Disposal Well Domestic Wastewater Facility Permit No. 0127512-002-UO. 7 FPL discharges stormwater and all other discharges from Turkey Point Units 3 and 4 and the 8 other facilities at the Turkey Point site to the CCS. Consistent with EPA and State 9 determinations, neither FPL nor the State of Florida considers the CCS to be waters of the 10 United States or waters of the State (FPL 2018f). FPL operates the CCS as an industrial 11 wastewater (IWW) facility under National Pollutant Discharge Elimination System 12 (NPDES)/IWW Permit No. FL0001562. This permit is issued pursuant to the Federal NPDES 13 program and the Florida Industrial Waste Water permitting program. FPL submitted a permit 14 renewal application to the State of Florida on October 21, 2009. Since that time, the 2005 15 permit has been administratively continued and remains in effect at this time. The NPDES 16 permit covers all plant discharges including discharges from Turkey Point Units 1, 2, 3, 4, and 5. 17 The NPDES permit authorizes wastewater discharges, including stormwater, through two 18 internal outfalls into the CCS. Internal Outfall I-001 is located on the southern bank of the 19 discharge canal that leads to the CCS; Internal Outfall I-002 is located in the Units 1 and 2 20 settling basins (see Figure 3-9). Stormwater from Turkey Point discharges through Internal 21 Outfall I 002 (FPL 2018f). Water quality parameters monitored by FPL under the Turkey Point 22 NPDES permit include copper, iron, lead, pH, salinity, specific conductance, temperature, total 23 suspended solids, zinc, and oil and grease (FPL 2018f). 24 The permit authorizes discharges to waters of the State. However, while the permit authorizes 25 discharges to groundwater of the State it does not authorize direct discharges to surface 26 waters of the State. The permit authorizes discharges from the CCS into the surficial aquifer, 27 which is the Biscayne aquifer. Beneath the CCS, the groundwater in the Biscayne aquifer is 28 classified as Class G-III groundwater (FDEP 2005, FPL 2018f). As a result of its high total 29 dissolved solids content, Class G-III groundwater is not considered to have a reasonable 30 potential as a future source of drinking water (FPL 2018f, FAC 62-520.410, UF 2018a). 31 While the State of Florida regulates nonradioactive liquid releases from Turkey Point, the NRC 32 regulates radioactive releases from Turkey Point. Liquid releases of radionuclides within NRC 33 allowable limits are a part of normal nuclear power plant operations. Liquid releases from 34 Turkey Point operations are discharged into the CCS via Internal Outfall I-001 (FPL 2018f). The 35 NRC monitors the amount and types of radionuclides and the calculated dose to the public to 36 confirm that releases are below NRC thresholds as defined in NRC regulations. 3-39

1 Source: From FPL 2018f 2 Figure 3-9 Florida Department of Environmental Protection NPDES Permitted Outfalls 3 CWA Section 401 Certification 4 Section 401 of the Clean Water Act (33 U.S.C. 1251 et seq.) requires an applicant for a Federal 5 license to conduct activities that may cause a discharge of regulated pollutants into navigable 6 waters to provide the licensing agency with a water quality certification from the State. This 7 Section 401 certification implies that discharges from the project or facility to be licensed will 8 comply with Clean Water Act requirements and will not cause or contribute to a violation of 9 State water quality standards. If the applicant has not received a Section 401 certification, the 3-40

1 NRC cannot issue a license unless that State has waived the requirement. The NRC 2 recognizes that some NPDES-delegated States explicitly integrate their Section 401 certification 3 process with NPDES permit issuance (NRC 2013a). 4 The Power Plant Siting Act (PPSA) certification from the State of Florida is a non-expiring permit 5 that remains valid for the life of the facility. Under the PPSA, FPL is not required to obtain a 6 new certification for NRC subsequent license renewal. The certification will remain effective, as 7 will any legal effects of the certification, including the certifications compliance with State water 8 quality standards for the life of the facility. Therefore, there is no requirement for FPL to obtain 9 a new determination of compliance with State water quality standard for Turkey Point Units 3 10 and 4 subsequent license renewal (FPL 2018f, FPL 2018g). 11 3.5.1.4 Adjacent Surface Water Quality and Cooling Canal System Operation 12 Within the Turkey Point site, the cooling canal system is the largest body of water. This section 13 of the SEIS describes recent studies to evaluate potential effects of CCS operations via the 14 movement of groundwater from the CCS to adjacent surface water bodies. 15 In response to orders from the State of Florida and Miami-Dade County, FPL conducts an 16 extensive water quality monitoring program that includes the CCS, Biscayne Bay, Card Sound, 17 marshland, mangrove areas, and canals adjacent to the CCS. A major objective of this program 18 is to evaluate the effects, if any, of CCS operation on the surrounding environment. The 19 monitoring program and some of its data and findings are contained in a number of documents 20 (FPL 2010, FPL 2011a, FPL 2014b, FPL 2016a, FPL 2016e, FPL 2016f, FPL 2016g, 21 FPL 2017a, and FPL 2017b) (See Figure 3-10). 22 This water quality monitoring program monitors surface water bodies for numerous water quality 23 parameters, including ammonia and other nutrients and salinity. Water temperature in the CCS 24 is also monitored, but FPL has not detected CCS waters affecting temperatures in adjacent 25 water bodies. 26 FDEP Administrative Order DEP #16-0111, uses tritium, in conjunction with saline water, as a 27 tracer to estimate the spatial extent of waters originating from the CCS (FDEP 2016h). At levels 28 in accordance with NRC allowable limits, Turkey Point Units 3 and 4 discharge liquid water 29 containing tritium into the CCS in batch releases. Units 3 and 4 also release tritium as a 30 gaseous emission (steam water or vapor water) into the air. 31 Tritium is a hydrogen atom with an atomic mass of three instead of one (NRC 2006a); like any 32 other hydrogen atom, it usually binds with oxygen to form a water molecule. A water molecule 33 that contains hydrogen in the form of tritium will behave in the environment just like a water 34 molecule that does not contain tritium. There are two possible pathways for tritium to leave the 35 CCS and move to another surface water body: (1) through the groundwater pathway within 36 liquid water or (2) through air within gaseous water (steam or vapor water). Therefore, for 37 surface water samples collected in bodies of water near the CCS, these two possible pathways 38 are considered when interpreting the data. 39 Tritium emits a weak form of radiation in the form of a low-energy beta particle similar to an 40 electron. This radiation does not travel very far in air and cannot penetrate the skin. If tritium 41 enters the body, it disperses quickly and is uniformly distributed throughout the soft tissues. 42 Tritium has a half-life of 12.3 years. This means that after 12.3 years, half of the tritium will be 43 gone through decay into a form that is no longer radioactive. However, if ingested, the human 3-41

1 body excretes half of the tritium ingested within approximately 10 days (NRC 2006a). For 2 tritium in drinking water, EPA has established a maximum contaminant level of 20,000 pCi/L 3 (EPA 2002, NRC 2006b). 4 At the levels that have been measured within the CCS, tritium is not a public health concern. 5 With the exception of rare outliers, measurements of tritium concentrations at sampling 6 locations within the CCS have been below the EPA maximum contaminant level of 20,000 pCi/L 7 for tritium in drinking water. Although tritium levels in some areas may somewhat exceed the 8 EPAs maximum contaminant level of 20,000 pCi/L for tritium in drinking water, salt 9 concentrations make the water in the CCS non-potable, and there are no drinking water wells 10 on or near the site. Also, while tritium has been detected in adjacent water bodies, the 11 concentrations were very low and often extremely low relative to the EPAs maximum 12 contaminant level of 20,000 pCi/L for tritium in drinking water (FPL 2010, FPL 2011a, 13 FPL 2014b, FPL 2016a, FPL 2016e, FPL 2016f, FPL 2016g, FPL 2017a, and FPL 2017b). 14 Water Quality within the Cooling Canal System 15 The following text describes ammonia and nutrients and salinity conditions within the CCS. As 16 CCS water temperatures also have an effect on CCS water salinities, the following text also 17 includes a discussion of water temperature in the CCS. Any mitigating actions within the CCS 18 to reduce any indirect effects on groundwater, ecology, and on adjacent surface water bodies 19 are also described. 20 Ammonia and Nutrients within the Cooling Canal System 21 Ammonia is released into the waters of the CCS by the decay of organic material within the 22 CCS. Between June 2010 and May 2016, ammonia concentrations within the CCS ranged from 23 below detectable levels to 0.3 mg/L and averaged 0.04 mg/L (FPL 2017c). The Miami-Dade 24 County water quality standard for ammonia is 0.5 mg/L (FPL 2018m). The Turkey Point CCS 25 values are all below this standard. 3-42

1 Source: From FPL 2017a 2 Figure 3-10 Locations of Surface Water Monitoring Stations 3 Ammonia is a nutrient. Other nutrients include phosphorus, chlorophyll, and total nitrogen. 4 Within a surface water body, if the concentration of nutrients gets too high, the nutrients can 5 cause algae blooms. These algae blooms can be toxic, deplete oxygen in the water, and 6 reduce water clarity (FDEP 2018e). 3-43

1 Nutrients are added to the water in the CCS by the erosion of soil and vegetation that falls into 2 the canals from the land that separates the individual channels within the CCS. Nutrients are 3 also added by groundwater inflows, atmospheric deposition (of nitrogen) and by the relatively 4 low levels of effluents from power plant operations. Nutrients are removed from the CCS by the 5 growth of seagrass, the harvest of seagrasses as a CCS maintenance activity, the removal of 6 biological material impinged on the plant intake screens, and the outflow of water from the CCS 7 into groundwater (FPL 2018f). 8 Prior to 2010, the CCS operated as a seagrass-based biological system. Seagrass grew 9 beneath the water on the bottom of the channels, covering an estimated 50 percent of the 10 channel bottoms. The seagrass provided habitat for aquatic life, provided natural filtration of 11 suspended material, and removed nutrients from the water within the CCS. This ecosystem 12 helped to maintain good water quality and low nutrient concentrations in the CCS waters 13 (FPL 2018f). 14 By 2010, this ecosystem had begun to change dramatically. CCS salinities had increased to the 15 point that the seagrass meadows were dying. By 2012, few seagrass beds remained. The 16 decomposition of the dead seagrass released a significant volume of nutrients into the waters of 17 the CCS. This increase in nutrients facilitated seasonal algae blooms, resulting in high turbidity 18 and generally degraded water quality within the CCS (FPL 2018f). 19 Nutrient Management Plan for the Cooling Canal System 20 In accordance with a June 20, 2016 consent order between FPL and the State of Florida 21 (FDEP 2016a), FPL submitted to the FDEP a nutrient management plan for the CCS. This 22 management plan is composed of three primary nutrient management strategies: (1) active 23 algae and nutrient removal, (2) canal and berm maintenance, and (3) salinity reduction and 24 controlled flow management. On July 7, 2017, the FDEP directed FPL to implement the plan 25 (FPL 2017b). 26 Under this nutrient management plan, FPL has performed bench and pilot tests to find the most 27 appropriate active nutrient and algae removal methods for the unique ecology and water 28 chemistry of the CCS. These nutrient and algae removal methods include using chemical 29 flocculants/coagulants, nonchemical means (i.e., physical removal), and aeration. In addition, 30 FPL reviewed Turkey Point canal practices in order to revise them to integrate the goal of 31 minimizing erosion and nutrient inputs from sediment and berm sources (FPL 2017b). 32 Temperatures within the Cooling Canal System 33 The temperature of the CCS varies in response to factors such as heated water discharged by 34 Units 3 and 4 into the CCS, air temperature, wind, precipitation, Biscayne aquifer groundwater 35 flowing into and out of the CCS, and water that FPL adds to the CCS from wells to reduce 36 salinity. To a lesser extent, discharges of water into the CCS from the interceptor ditch and the 37 Turkey Point Unit 5 cooling tower blowdown can also impact the temperature of water within the 38 CCS. 39 Historically, Turkey Points Units 1, 2, 3, and 4 all contributed heat to the CCS. Units 1 and 2 are 40 now retired and no longer contribute heat to the CCS. Even under current operations (i.e., after 41 the NRC approved power uprates for Units 3 and 4 on June 15, 2012 (NRC 2012)), the heat 42 that Units 3 and 4 discharge to the CCS is less than the amount of heat Turkey Point had 43 discharged to the CCS when Units 1, 2, 3, and 4 were all in operation. 3-44

1 Due to the discharge of heat into the CCS, water temperatures in the CCS are higher than 2 ambient air temperatures (FPL 2018f). Surface water temperatures within the CCS are warmer 3 in the summer months and cooler in the winter months (FPL 2016a). Water temperatures within 4 the CCS also vary based on location. As water moves from the discharge area, through the 5 canals, and then towards the intake area, the water temperature drops (FPL 2016a). As 6 expected, the highest water temperatures in the CCS are found where Units 3 and 4 discharge 7 hot water into the CCS (Station TPSWCCS-1); the lowest water temperatures are found at the 8 cooling water intake for Units 3 and 4. From June 2010 through May 2017, average monthly 9 temperature values collected at all seven monitoring stations within the CCS ranged from 10 52.7 °F (11.5 °C) to 115 °F (46.3 °C), and produced an average monthly temperature of 88 °F 11 (30.4 °C) (FPL 2017a). 12 The CCS serves as the ultimate heat sink to cool Units 3 and 4. On August 8, 2014, the NRC 13 established an ultimate heat sink temperature limit for the cooling canals of 104 °F (40 °C) 14 (FPL 2018f, NRC 2014d, 79 FR 44464, 80 FR 76324). To judge compliance with this limit, FPL 15 measures water temperature from a sampling location in the return canal in front of the cooling 16 water intake structure. Data from this sampling location represent the temperature of the water 17 after it has been cooled by the CCS. From June 2010 through May 2017, temperature 18 measurements at this sampling location (station TWSWCCS-6) have not exceeded the NRCs 19 ultimate heat sink limit of 104 °F (40 °C) (FPL 2017a). 20 Prior to August 2014, the NRC had set the ultimate heat sink limit at the slightly lower 21 temperature of 100 °F (37.8 °C). In early July 2014, the water temperature in the cooling canals 22 began to approach the limit of 100 °F (37.8 °C). FPL then requested an increase in the 23 temperature limit; in response, the NRC performed a safety and environmental analysis, and 24 then established the current heat sink temperature limit of 104 °F (40 °C) (NRC 2014b). 25 FPL believes that the 2014 increase in average CCS temperatures was necessitated by: 26

• low average precipitation into the CCS from 2011 through 2014 27
• poor water circulation through the CCS due to blockages and sediment accumulation 28
• reduced heat exchange efficiency caused by factors such as higher salinity, turbidity, 29 and algal concentrations that reduced evaporation rates (FPL 2018f) 30 Since 2014, FPL has worked to reduce algae concentrations, improve canal circulation, and 31 increase the inflow of groundwater from the Biscayne aquifer into the CCS by sediment removal 32 from CCS channels. For a short period of time, to help lower CCS temperatures, freshwater 33 from Canal L-31E, brackish water from the Upper Floridan aquifer, and saltwater from the 34 Biscayne aquifer was added to the CCS.

35 According to its environmental report for subsequent license renewal, FPLs current plans to 36 lower CCS temperatures do not include the use of freshwater from State canals (FPL 2018f). In 37 the future, should FPL need to use freshwater from State canals, FPL would need to seek 38 permission to do so from State and county governments. FPL states that future plans to reduce 39 CCS temperatures include adding brackish water from the Upper Floridan aquifer, reducing 40 algae in the CCS, continuing to remove sediment within the CCS, and, only in extraordinary 41 circumstances, pumping saltwater from the Biscayne aquifer into the CCS (FPL 2018f). 3-45

1 Thermal Efficiency Plan for the Cooling Canal System 2 In accordance with the June 20, 2016 consent order between FPL and the State of Florida, FPL 3 submitted a thermal efficiency plan for the CCS to the FDEP (FDEP 2016a). FPL has identified 4 the maintenance of high thermal efficiency within the CCS as necessary for controlling 5 evaporation and salinity in the CCS. The plan identified primary and secondary performance 6 metrics. FPL will use these metrics to guide its actions to maintain high thermal efficiencies 7 (i.e., thermal efficiency at equal to or greater than 70 percent). On July 7, 2017, the FDEP 8 instructed FPL to implement this thermal efficiency plan (FPL 2017b). 9 Since July 2017, FPL has implemented several near-term actions under this thermal efficiency 10 plan, including (1) sediment removal in many of the CCS canals, (2) flow management within 11 the CCS, (3) water stage management, and (4) vegetation management. As a result, thermal 12 efficiency in the CCS during the 2017 reporting period met the objectives of the plan, which is to 13 maintain high thermal efficiencies at equal to or greater than 70 percent. For the period 14 between October 2016 through September 2017, FPL reported an annual CCS thermal 15 efficiency of approximately 84 percent (FPL 2017b). 16 Salinity within the Cooling Canal System 17 Water in the CCS contains significant concentrations of salt. CCS water is saltier than seawater 18 (i.e., it is hypersaline). The salinities of seawater are around 34-35 practical salinity units 19 (PSU), while the salinity of water in the CCS is presently around 60 PSU, or almost twice the 20 salinity of seawater (EB 2018, FPL 2018f). Salinities in the CCS increase when water leaves 21 the CCS and decrease when less saline water enters the CCS. The highest salinities in the 22 CCS are likely to occur during times of low precipitation and when evaporation rates are high. 23 Conversely, the lowest salinities within the CCS are likely to occur during times of high 24 precipitation and when evaporation rates are low (FPL 2012a). Salinity concentrations are 25 usually at minimum values during the wet season, with the highest salinities at the end of the 26 dry season (FPL 2018f). 27 Most of the salt in the CCS comes from the groundwater of the Biscayne aquifer which is 28 saltwater. As groundwater from the Biscayne aquifer moves into the CCS, the salt it contains 29 also moves into the CCS. The Biscayne aquifer obtains its salt from Biscayne Bay, and is 30 hydrologically connected to both the Biscayne Bay and the CCS (FPL 2018f, Tetra Tech 2014, 31 FPL 2016a). 32 Salt is removed from the CCS when water containing salt moves from the CCS into the 33 Biscayne aquifer. Water that moves from the CCS into the groundwater is likely to reflect the 34 hypersaline conditions of the CCS (around 60 PSU). With its higher salt concentrations, this 35 CCS water is denser than the groundwater of the Biscayne aquifer (FPL 2018f). 36 As previously stated, in recent years, salinity concentrations within the CCS have been about 37 60 PSU, or about twice the average concentration of seawater, which is approximately 34 to 38 35 PSU (FPL 2018a). However, when FPL first constructed the cooling canals in the 1970s, the 39 salinity of the CCS water and the surrounding Biscayne aquifer were about equal to the salinity 40 of saltwater and the adjacent Biscayne Bay (approximately 34 PSU) (FPL 2018f). 41 As previously described, CCS salinities have varied over time; usually at minimum values during 42 the wet season, with the highest salinities at the end of the dry season. During dry years 43 (periods of drought) the overall salinities at the end of the year were higher than the salinities at 3-46

1 the end of the previous year. In this way, drought years produced a ratcheting effect that 2 caused the next year to begin the seasonal cycle of salinity concentrations at higher salinities 3 than the previous year. As a result, average salinities in the CCS gradually increased from 4 approximately 34 PSU in the early 1970s to approximately 90 PSU in 2014 and 2015 5 (FPL 2017a, FPL 2017b, FPL 2018f). 6 As CCS salinities increased, the seagrasses in the CCS died off. As the seagrasses died off, 7 not only could they no longer remove nutrients from the water, their decomposition also 8 released considerable amounts of nutrients into the water. The increased nutrient 9 concentrations facilitated the growth of seasonal algae blooms (FPL 2018f). As previously 10 mentioned, from 2011 through 2014, in combination with low average precipitation and poor 11 water circulation through the CCS, the algae blooms contributed to increased temperatures and 12 salinities within the CCS (NRC 2016a). 13 To help reduce the water temperatures within the CCS, on June 27, 2014, the State of Florida 14 granted FPL permission to add saltwater from the Biscayne aquifer and brackish water from the 15 Upper Floridan aquifer to the CCS (NRC 2016a). In August 28, 2014, the South Florida Water 16 Management District granted FPL permission to add freshwater from the L-31E Canal to the 17 CCS to reduce salinity. After these additions, rainfall also added freshwater to the CCS. CCS 18 salinities and temperatures subsequently returned to pre-summer 2014 levels (around 60 PSU) 19 (FPL 2018f, NRC 2016a). 20 Salinity Management Plan 21 In December 2014, the FDEP issued an Administrative Order requiring FPL to submit a salinity 22 management plan to describe how FPL would reduce and maintain the average annual salinity 23 in the CCS at or below 34 PSU (FDEP 2014, NRC 2016a). On October 7, 2015, Miami Dade 24 County and FPL signed a consent agreement (MDC 2015a). In this agreement, it was 25 acknowledged that FPL would supply brackish water to the CCS from the Upper Floridan 26 aquifer and saltwater from the Biscayne aquifer via marine wells (wells located adjacent to 27 Biscayne Bay). However, FPL would work to avoid the use of water from the marine wells, 28 except under extraordinary circumstances. Secondly, it was acknowledged that FPL would 29 continue to use water from the L-31E canal to lower CCS salinities until a transition was made 30 to long-term sources of water for the CCS (i.e., brackish water from the Upper Floridan aquifer) 31 (MDC 2015a). 32 On June 20, 2016, a consent order (FDEP 2016a) was executed by FPL and the FDEP. The 33 consent order requires FPL to maintain the average annual salinity of the CCS at or below 34 34 PSU. Further, it states that, [i]f FPL fails to reach an annual average salinity of at or below 35 34 PSU by the end of the fourth year of freshening activities, within 30 days of failing to reach 36 the required threshold, FPL shall submit a plan to the [FDEP] detailing additional measures, and 37 a timeframe, that FPL will implement to achieve the threshold. Subsequent to attaining the 38 threshold in the manner set forth above, if FPL fails more than once in a 3 year period to 39 maintain an average annual salinity of at or below 34 PSU, FPL shall submit, within 60 days of 40 reporting the average annual salinity, a plan containing additional measures that FPL shall 41 implement to achieve the threshold salinity level (FDEP 2016a). 42 In future years, it is anticipated that Upper Floridan aquifer wells will be the water source utilized 43 for salinity reduction (FPL 2018f). As detailed in Section 3.5.2.2.3, FPL began operation of the 44 Upper Floridan aquifer freshening well system on November 28, 2016. The addition of this 45 brackish water (2.5 PSU) to the CCS is being used to help reduce the CCS salinity to an 3-47

1 average annual level of 34 PSU. The addition of this water has been important in minimizing 2 increases in CCS salinity that ordinarily occur during the dry season. Continued operation of 3 the freshening wells during the wet season should further help to reduce CCS salinities 4 (FPL 2018f). 5 Study of Water Alternatives to Reduce CCS Salinities 6 In the October 7, 2015, consent agreement between Miami-Dade County and FPL, it was 7 acknowledged that FPL would consider the practicality and appropriateness of using reclaimed 8 wastewater from the Miami-Dade County South District Waste Water Treatment Plant as an 9 alternative water resource to reduce CCS salinities. To respond to this request, FPL contracted 10 with Golder and Associates to evaluate alternative sources of water. Along with other 11 alternatives, the evaluation considered the practicality and appropriateness of using reclaimed 12 wastewater from the Miami-Dade County South District Waste Water Treatment Plant 13 (SDWWTP) (Golder 2016). 14 The study considered the following eight alternatives: 15 1) Excess surface water from the L-31E Canal 16 2) Biscayne aquifer water from the Inland Biscayne Aquifer Wellfield 17 3) Reclaimed water from SDWWTP with nutrient removal 18 4) Reclaimed water from SDWWTP with nutrient removal and advanced treatment for 19 other constituents of concern 20 5) Upper Floridan aquifer water using artesian wells flowing into the CCS 21 6) Direct Treatment of CCS water to remove salinity 22 7) Marine groundwater from wells on the Turkey Point Peninsula with additional fresh 23 water from another source 24 8) Marine surface water from Biscayne Bay or Card Sound with additional fresh water 25 from another source 26 The study considered technical, environmental, economic, and social criteria. Relative to the 27 ranking criteria, it ranked Alternative Five as the best overall and the most balanced alternative. 28 It also identified that Alternatives One and Seven should be maintained as short-term backup 29 water options to be used when appropriate and as needed during extreme conditions. It further 30 determined that Alternatives Two, Four, Six, and Eight did not provide a significant advantage 31 and should not be evaluated further unless conditions change. While the study determined that 32 Alternative Three has a high cost and very long implementation schedules; it concluded that this 33 alternative should be further evaluated as a potential long-term solution to a regional problem 34 (Golder 2016). 35 The alternatives study was reviewed by Miami-Dade County. On December 22, 2016, the 36 County decided that the use of reclaimed water with nutrient removal and advanced treatment, 37 described as (Alternative 4) in the referenced document, could provide a long-term, sustainable 38 source of water to offset CCS water deficits. The County recommended that FPL revisit this 39 alternative for further evaluation as a potential long-term solution (MDC 2016a). The current 40 status of this proposal is unclear. 3-48

1 Application of Numerical Modeling to CCS Salinity Mitigation 2 The operation of the CCS has been numerically modeled to understand and predict different 3 aspects of the CCS (Chin 2016; Golder 2008; Tetra Tech 2014a; FPL 2012a, FPL 2014b, 4 FPL 2016a, FPL 2016g, FPL 2017a). The most recent modeling was conducted by Tetra Tech 5 for FPL. The focus of this modeling was to quantify the volumes of water and the mass of salt 6 entering and exiting the CCS (FPL 2012a). Model calculations for the various components of 7 the CCS incorporate hydrological, chemical, and meteorological data collected in and around 8 the CCS (FPL 2012a). Selected model inputs were adjusted to calibrate the model against 9 observed changes in CCS water and salt storage. The calibration minimized differences 10 between simulated and observed salt and water storage changes within the CCS. The 11 calibration process builds confidence that the model will produce adequate predictions of CCS 12 behavior (FPL 2014b). 13 This tool is being used by FPL to understand the effectiveness of its mitigation measures. The 14 most recently published modeling results simulate the operation of the CCS from June 2015 15 through May 2017. The modelers concluded that over this time period, the addition of Upper 16 Floridan aquifer water helped to moderate dry season salinity without significantly increasing 17 water levels in the CCS (FPL 2017a). 18 In 2014, Tetra Tech used numerical models to estimate the volume of Upper Floridan aquifer 19 water that would be required to reduce CCS water salinity to seawater range. The modeling 20 exercise produced an estimate that with the addition of 14 mgd (53,000 m3/day) of Upper 21 Floridan aquifer water that had a salinity of 2 PSU it would require less than a year to reduce 22 salinities in the CCS to 35 PSU (Tetra Tech 2014a). However, while FPL then added an 23 average of 12.8 mgd (48,500 m3/day) of Upper Floridan aquifer brackish water to the CCS from 24 the beginning of November 2016 to the end of May 2017, salinities in the CCS did not go down 25 to 35 PSU (FPL 2017a). Rather, at the end of May 2017, average salinity concentrations in the 26 CCS were 64.9 PSU (FPL 2017b). 27 Comparing CCS data and model results, the modelers concluded that during this period (most 28 of which occurred during the dry season), evaporation rates exceeded precipitation rates. 29 Without the addition of brackish water from the Upper Floridan aquifer, the net evaporation vs. 30 precipitation rate would have caused the salinity in the CCS to increase more than was 31 observed. However, the addition of Upper Floridan aquifer water helped to moderate the effects 32 of the dry season (typically, November - April) on the CCS. For example, CCS salinities during 33 the dry seasons of 2014 and 2015, which were not as dry as 2017, exceeded 90 PSU, while the 34 addition of brackish water from the Upper Floridan aquifer and saltwater from the marine wells 35 was effective in keeping CCS salinities below 70 PSU in the 2017 dry season. The modelers 36 anticipate that under more favorable climatic conditions (e.g., less severe dry seasons), the 37 addition of Upper Floridan aquifer water should help to reduce CCS water salinities to 34 PSU 38 (FPL 2017a, FPL 2017b). 39 As previously stated, in compliance with the June 20, 2016, consent order executed by FPL and 40 the FDEP, if FPL fails to reach an annual average salinity of at or below 34 PSU by the required 41 time periods, FPL is required to submit a plan to the FDEP detailing additional measures, and a 42 timeframe, that FPL will implement to achieve the threshold (see Salinity Management Plan) 43 (FDEP 2016a). Thus, continued actions by FPL and regulatory oversight by the FDEP provide 44 assurance that the CCS should reach the required PSU levels within or close to the designated 45 period. 3-49

1 Ammonia and Nutrients within Biscayne Bay and Card Sound 2 If the concentration of nutrients in either Biscayne Bay or Card Sound get too high, they can 3 negatively impact the aquatic ecology. Excess nutrients can cause algae blooms (thick green 4 algae mats that can be toxic), deplete oxygen in the water, and reduce water clarity. The State 5 of Florida (with the approval of the EPA) has established numeric nutrient criteria for Biscayne 6 Bay and Card Sound. These water quality standards help to protect the quality of the surface 7 water in the bay and the sound, consistent with the requirements of the Clean Water Act 8 (EPA 2014c). The numeric nutrient criteria include criteria for phosphorus, chlorophyll, and total 9 nitrogen, of which ammonia is a contributor (FDEP 2018e). 10 Biscayne Bay waters are generally low in plant nutrients. This means the aquatic ecosystems 11 respond very rapidly to small nutrient enrichment, especially to increases of phosphorous. The 12 concentrations of ammonia from runoff tends to be higher in urban runoff than in wetland or 13 agricultural runoff. The Biscayne Bay watershed has a diverse agricultural, urban, and wetland 14 land use. This results in lateral differences in bay water nutrient concentrations (NPS 2011). 15 In general, ammonia concentrations are higher in the northern portion of Biscayne Bay, which is 16 most urbanized, while the lowest values are next to the Turkey Point site in Biscayne Bay and in 17 Card Sound. Seasonal ammonia values in the bay are lowest late in the dry season, with higher 18 concentrations and increased variability during the wet season (peaking in September or 19 October) (NPS 2011). 20 Sampling data by Miami-Dade County and FPL in the late fall and winter months of 2015-2016 21 revealed levels of ammonia concentration that exceeded the Countys water quality standard for 22 ammonia (0.5 mg/L) at two surface water quality monitoring stations near the CCS in Biscayne 23 Bay (MDC 2016a). The exceedances for ammonia were detected in the Barge Turning Basin 24 and the remnant canal at Turtle Point (TPBBSW-7 and TPBBSW-8). Both areas are connected 25 to Biscayne Bay. When it was constructed, the Barge Turning Basin was excavated to a depth 26 of approximately 30 ft (9.1 m) and the Turtle Point remnant canal was excavated to a depth of 27 approximately 20 ft (6.1 m). In Biscayne Bay nearby areas have a depth to the bottom of about 28 1 to 2 ft (0.3 to 0.6 m) (FPL 2018g) (Figure 3-4). 29 The ammonia exceedances were detected in samples obtained from the bottom of these 30 excavations and close to the CCS. The low dissolved oxygen, hypersalinity, and tritium 31 concentrations found at these locations are consistent with the interpretation that, close to the 32 CCS, the water quality at the bottom of these excavations may be influenced by groundwater 33 that has been in contact with CCS waters. However, the ammonia concentrations in the bottom 34 samples were consistently higher than ammonia levels in the CCS (FPL 2016g). This implies 35 that if groundwater from the CCS was moving into these excavations, some of the ammonia in 36 the Turtle Point remnant canal and the Barge Turning Basin was coming from other sources. 37 The ammonia exceedances led to the modification of a consent agreement between the County 38 and FPL in 2016. The modified consent agreement requires FPL to prepare and implement a 39 corrective action plan to address ammonia exceedances in surface water surrounding the 40 facility including, but not limited to, waters tidally connected to Biscayne Bay (MDC 2016b, 41 FPL 2016h). 42 On April 25, 2016, the FDEP issued a warning letter to FPL concerning the sampling data by 43 Miami-Dade County and FPL in the late fall and winter months of 2015-2016 which showed 44 levels of ammonia concentration were exceeding the water quality standard for ammonia 3-50

1 (0.5 mg/L). The letter requested that FPL provide facts to assist in determining whether any 2 violations of Florida law had occurred (FDEP 2016i). 3 In response to the modified consent agreement between FPL and Miami Dade County, FPL 4 submitted a corrective action plan to Miami-Dade County on September 14, 2016. The plan 5 described a program to identify the source of the ammonia and to define its vertical and 6 horizontal extent within nearby surface waters. Under the plan, an extensive sampling and 7 analysis program was then conducted by FPL that included numerous surface water, pore 8 water, canal, and groundwater sampling locations, as well as stratified surface water sampling 9 and temporal sampling based on tidal cycles. The assessment results were evaluated in detail 10 to determine the nature and extent of ammonia at Card Sound, Turkey Point, and in remnant 11 dead-end canals and the Barge Turning Basin. In addition, an evaluation of water quality within 12 the CCS was performed (FPL 2016h, FPL 2017c). 13 The study and its conclusions are contained in an assessment published on March 17, 2017 14 (FPL 2017c). The report concluded that the elevated ammonia values are attributable to the 15 degradation of plant and animal material under anoxic (low oxygen) conditions in areas with little 16 or no mixing with other surface waters. The occurrence of ammonia appears to be limited to the 17 locations of deep stagnant anoxic water bodies. Some of the deep canal sites and many of the 18 groundwater and pore water sites were anoxic and the majority of nitrogen was in the form of 19 ammonia. The studied areas are similar to many locations in coastal Southeast Florida. 20 Regional studies of background surface water quality data for Biscayne Bay indicate that 21 ammonia can be detected at many locations that are not associated with the CCS, at levels 22 greater than 0.5 mg/L (FPL 2017c). 23 The 2017 report further concluded that the elevated ammonia values were not the result of 24 contamination attributable solely to the Turkey Point site but were the result of natural microbial 25 processes in anoxic, stagnant surface and groundwater environments (FPL 2017c). Ammonia 26 concentrations in the CCS were found to be very low, and the report therefore concluded that 27 the CCS was not the direct cause of the elevated ammonia concentrations in the Turtle Point 28 remnant canal and the Barge Turning Basin. Only surface water samples collected from the 29 bottom of the dead-end canals exceeded the Miami-Dade County standard for ammonia. 30 Outside of these areas, no exceedance of the standard was detected in any other samples 31 within Biscayne Bay near the CCS or in the CCS (FPL 2017c). 32 The 2017 report also concluded that the ammonia values are consistent with the anoxic 33 conditions that exist at the bottom of remnant canals and the accumulation of organic matter 34 falling into the remnant canals from surrounding areas of the bay. Based on the information 35 obtained, additional work and a corrective action plan were not recommended (FPL 2017c). 36 On May 16, 2016, FPL submitted to the FDEP the nutrient monitoring results from certain 37 surface water monitoring stations in deep channels adjacent to the CCS for total nitrogen, total 38 phosphorous, and total Kjeldahl nitrogen. The FDEP reviewed this information and determined 39 that no exceedances of surface water quality standards were detected in Biscayne Bay 40 monitoring (FPL 2016a). However, to minimize the potential for future exceedances, the FDEP 41 ordered FPL to implement restoration projects at the Barge Turning Basin and within the 42 remnant canal at Turtle Point (FDEP 2016a). As of July 5, 2018, FPL was in the process of 43 obtaining the final permits for these restoration projects (FPL 2018f). 44 Restoration activities at the Barge Turning Basin will backfill the Barge Turning Basin up to a 45 depth of 15 ft (4.6 m) below MSL. Restoration activities at Turtle Point will backfill one-third of 3-51

1 the remnant canal up to a depth of 0.33 ft (0.1 m) below MSL (for future Mangrove Planting). 2 The rest of the remnant canal will be backfilled with a sloping fill to a final depth of 7 ft (2.1 m) 3 below MSL (FPL 2017c). The backfilled shallow portion will be stabilized with mangrove 4 plantings (FPL 2018d, FPL 2018g). This will reduce the accumulation of organic matter in these 5 deep areas and reduce or eliminate the movement of groundwater from the CCS into these 6 deep excavations connected to Biscayne Bay. Both restoration projects are to be completed 7 within the two-year timeframe required by the FDEP Consent Order (FPL 2018g). 8 Staff from Miami-Dade County reviewed the 2017 report on ammonia in surface waters and on 9 July 7, 2017, requested that FPL submit more information (MDC 2017d). On July 10, 2018, the 10 Miami-Dade County Division of Environmental Resource Management (DERM) issued a letter 11 finding that total ammonia concentrations at the Barge basin and the Turtle Point remnant canal 12 exceeded the applicable Miami-Dade County surface water standard (MDC 2018a). The DERM 13 acknowledged that the observed elevated surface water ammonia concentrations may be 14 attributable to several contributing sources, including factors not directly related to the operation 15 of the CCS; however, based on an evaluation of tritium concentrations and temperature data, 16 DERM found that the CCS is a contributing source to the ammonia concentrations in those 17 areas. 18 The DERM letter required FPL to submit a plan to address CCS nutrient impacts to groundwater 19 and surface water resources beyond the boundaries of the CCS. In the letter, DERM 20 acknowledged that management of water quality within the CCS may be effective in reducing 21 water quality impacts observed beyond the CCS facility boundaries. DERM also required FPL 22 to implement the proposed plan to fill the barge basin and the Turtle Point remnant canal 23 (MDC 2018a). 24 Salinity within Biscayne Bay and Card Sound 25 The salinity of the water in Biscayne Bay and Card Sound affects their ecosystems. Sustained 26 lower-than-seawater salinities are required to maintain the ecology of freshwater wetland, tidal 27 wetlands and mainland nearshore areas, to provide nursery habitat for fish and shellfish 28 (Audubon 2016, NPS 2012). As previously mentioned, the salinities in Biscayne Bay adjacent 29 to the Turkey Point site and Card Sound are most affected by the amount of precipitation that 30 falls in and around the bay and the sound. Also, depending on the hydraulic head in the 31 underlying Biscayne aquifer relative to the head (water levels) in Biscayne Bay, water in the 32 Biscayne Bay (and therefore salt), either moves from Biscayne Bay into the underlying aquifer 33 or from the underlying aquifer into Biscayne Bay. 34 Within Biscayne Bay and Card Sound, near-shore areas next to the mainland have a larger 35 range of salinity values than mid-bay or mid-sound locations. This is because near-shore areas 36 are more affected by freshwater inflows and evaporation than mid-bay and mid-sound locations 37 (NRC 2016a). 38 The surface water monitoring program, which, in addition to surface water samples, includes 39 pore water samples and shallow monitor well samples in the Bay, has not detected a 40 discernable effect from the CCS on the salinity of Biscayne Bay or Card Sound (FPL 2016a, 41 FPL 2018f). 3-52

1 Ammonia and Nutrients and Salinity within Marsh Land and Mangrove Areas 2 The monitoring program has not detected evidence in the surrounding marsh and mangroves 3 areas of any impacts of ammonia, nutrients, or salinity from the CCS on soil pore water quality 4 via the groundwater pathway (FPL 2014b, 2016a, 2017a, 2018f). 5 Ammonia and Nutrients and Salinity within Adjacent Canals 6 On the west side of the CCS, the interceptor ditch (which is about 18 ft (5.5 m) deep), serves to 7 keep groundwater under the CCS from moving west into the L-31E canal. However, there is no 8 interceptor ditch along the southern boundary of the CCS (Figure 3-4). Within the CCS, the 9 canal that runs along the southern boundary is 20 ft (6.1 m) deep. The S-20 canal and the Card 10 Sound remnant canal lie adjacent to the CCS with no intervening interceptor ditch. At these 11 locations, the S-20 Canal is 5 ft deep and the Card Sound remnant canal is more than 20 ft 12 (6.1 m) deep (FPL 2014b). Therefore, due to their close proximity to the CCS, these are 13 locations where CCS water may more readily move into an adjacent canal via the groundwater 14 pathway. 15 With the following exceptions, no readily apparent impacts of ammonia, other nutrients, and 16 salinity on surface water quality in canals adjacent to the Turkey Point site, from the CCS via the 17 groundwater pathway, have been detected (FPL 2016a). During the June 2014 to May 2015 18 monitoring period, monitoring detected an intermittent influence from the CCS at two monitoring 19 locations in canals immediately adjacent to the CCS. One station is located in the S-20 canal 20 and one station is located in the Card Sound remnant canal. The identification of CCS influence 21 was determined based on small temperature variations and higher tritium and salinity values 22 than would normally be expected. However, no readily discernible influence from the CCS was 23 detected at these locations during the June 2013 to May 2014 monitoring period or the 24 June 2016 to May 2017 monitoring period (FPL 2012a, FPL 2014b, FPL 2017a). Minimal, if 25 any, influence on surface water quality was detected where the canals connect to Card Sound 26 (FPL 2016a). 27 On July 10, 2018, the Miami-Dade County DERM issued a letter stating that total ammonia 28 concentrations at some sampling locations in the Card Sound remnant canal, the S-20 canal, 29 and in the Sea-Dade remnant canal, exceeded the applicable Miami-Dade County surface water 30 standard. This letter acknowledged that the elevated surface water ammonia concentrations 31 may be attributable to several contributing sources, including factors not directly related to the 32 operation of the CCS; however, based on an evaluation of tritium concentrations and 33 temperature data, the DERM found that the CCS is a contributing source to the ammonia 34 concentrations in these areas (MDC 2018a). The DERM also acknowledged that the 35 management of water quality within the CCS may be effective in reducing water quality impacts 36 beyond the CCS boundaries, and it required FPL to submit a plan to address CCS nutrient 37 impacts to groundwater and surface water resources beyond the boundaries of the CCS 38 (MDC 2018a). 39 3.5.2 Groundwater Resources 40 Groundwater includes all water below the ground surface, usually within a zone of saturation. 41 Aquifers contain groundwater in sufficient volume to supply wells, springs, and surface water. 3-53

1 3.5.2.1 Hydrogeology and Aquifers 2 The NRC staffs EIS for the Turkey Point, Units 6 and 7 combined licenses (NUREG-2176) 3 contains an extensive description and evaluation of the hydrogeologic system of the southern 4 Miami-Dade County region, focusing on the Turkey Point site (NRC 2016a). The summaries of 5 site hydrogeology in this section of the SEIS are primarily based on NUREG-2176, as well as 6 on FPLs environmental report submitted as part of the Turkey Point subsequent license 7 renewal application (FPL 2018f). Where appropriate, the NRC staff has summarized referenced 8 information or incorporated information by reference into this SEIS so that the following 9 subsections can focus on new and potentially significant information since initial license renewal 10 of Turkey Point Units 3 and 4 in 2002. The discussions and analyses that follow focus on 11 aspects of the aquifer systems and the interactions with ongoing Turkey Point operations 12 including the CCS, also called the industrial wastewater (IWW) facility. For a detailed 13 description of the CCS, see Section 3.1.3, Cooling and Auxiliary Water Systems, of this SEIS. 14 Two major aquifer systems underlie the region and the Turkey Point site: (1) the surficial aquifer 15 system consisting of the Biscayne aquifer, and (2) the deeper Floridan aquifer system 16 (FPL 2018f, NRC 2016a). Figure 3-6 in Section 3.4 of this SEIS shows the orientation, depths, 17 and thicknesses of the aquifers beneath the Turkey Point site, including the named stratigraphic 18 units and the lithologies (rock types) comprising them. 19 During the NRC staffs June 2018 environmental site audit (NRC 2018c), the staff toured the 20 facilities and locations discussed below, including the CCS and related structures, Upper 21 Floridan aquifer production (i.e., CCS freshening) well locations, hypersaline recovery wells and 22 the associated deep injection well, and the Turtle Point and Barge Basin restoration project 23 sites. 24 Biscayne Aquifer 25 As illustrated in Figure 3-6 (see Section 3.4) and as described in NUREG-2176 (NRC 2016a), 26 the Biscayne aquifer is the principal aquifer beneath southeast Florida that is used for water 27 supply. It extends from the land surface to a depth of approximately 140 feet (43 m) beneath 28 the Turkey Point, Units 3 and 4 site. It is generally an unconfined (water table) aquifer, but it 29 may be semiconfined or confined on a localized basis due to the occurrence of less permeable 30 strata (FPL 2018f, NRC 2016a). 31 Section 2.3.1.2, Hydraulic Properties of Biscayne Aquifer, of NUREG-2176 (NRC 2016a) 32 describes the permeable limestones and calcareous sandstones forming the Biscayne aquifer 33 as highly heterogeneous with varying hydraulic properties that may comprise one or more 34 aquifers separated by locally confining units. Section 2.3.1.2 of NUREG-2176 also describes 35 the differences and the inherent hydrogeologic properties of the Biscayne aquifer including 36 porosity, transmissivity, and hydraulic conductivity (NRC 2016a: 2-49-2-51). The NRC staff 37 incorporates that information into this SEIS by reference. 38 The low topographic relief of the Turkey Point site relative to sea level makes the site subject to 39 tidal inundation. As such, the waters of the Biscayne aquifer are highly saline below the Turkey 40 Point site. To the east of the site, the Biscayne aquifer is recharged by the saline waters of 41 Biscayne Bay. Freshwater recharge of the Biscayne aquifer occurs from precipitation primarily 42 during the wet season (June to October) with minimal recharge during the dry season 43 (November to May). It is likely that some freshwater recharge also occurs during the wet 44 season from freshwater marshes and sheet flow runoff. Seepage from freshwater canals 3-54

1 usually continues to recharge the aquifer during the dry season (NRC 2016a). In general, the 2 Biscayne aquifer water table responds rapidly to precipitation as well as to tidal fluctuations 3 (FPL 2018f). 4 Under natural conditions and with adequate inland recharge of freshwater, the water table in a 5 surficial aquifer like the Biscayne aquifer is higher than the average sea-level elevation, which 6 balances the higher density of seawater. In such a case, the freshwater-saltwater interface 7 (interface), the most inland point marking the diffusion boundary between freshwater and 8 seawater, is relatively stable near the coastline or offshore. This is conceptually illustrated in 9 Figure 3-11. 10 Source: Barlow 2003 11 Figure 3-11 Generalized Diagram of the Freshwater-Saltwater Interface in a Coastal 12 Water Table Aquifer 13 When the aquifer water table is lowered by pumping or canal drainage, saltwater can move 14 inland, usually at the base of the aquifer because of the higher density of seawater relative to 15 freshwater. Prior to urban and agricultural development and the construction of canals to drain 16 inland areas, wet season recharge to groundwater was greater than it is today and subsurface 17 flows of groundwater into Biscayne Bay adjacent to the Turkey Point site were also higher 18 (NRC 2016a). 19 Regionally, reduced surface water runoff and groundwater discharge to Biscayne Bay, 20 combined with pumping of groundwater for irrigation, water supply, and other uses, has caused 21 saltwater to migrate inland along the base of the Biscayne aquifer. This process is known as 22 saltwater intrusion or encroachment (FPL 2018f, NRC 2016a). 23 The Turkey Point cooling canal system (CCS) (described in Section 3.1.3, Cooling and 24 Auxiliary Water Systems) is a large, enclosed, hypersaline (i.e., having a salinity greater than 25 that of natural seawater, with chloride concentration exceeding 19,000 mg/L) water body, 26 formed by excavation into the underlying bedrock. The CCS affects the hydrology and 27 groundwater quality of the Biscayne aquifer. The CCS is unlined and hydraulically connected to 28 the upper Biscayne aquifer because permeable aquifer strata permit the movement of water 29 between the aquifer and the CCS. The rate and direction of this water movement depend on 3-55

1 the head differences between the CCS and the Biscayne aquifer (FPL 2018f, NRC 2016a). 2 Because of the movement of the hypersaline CCS water into the Biscayne aquifer, there is an 3 area of higher salinity water in the aquifer beneath the CCS and adjoining portions of the Turkey 4 Point site, called the hypersaline plume. As FPL describes in its environmental report, over the 5 operational life of the CCS, the annual average salinity of both the waters within the CCS and 6 within the hypersaline plume beneath it in the Biscayne aquifer have increased. Over the 7 operational life of the CCS, the size of the hypersaline plume has also grown larger. In its 8 environmental report, FPL states that the hypersaline plume now extends out approximately 9 1.5 mi (2.4 km) west of the CCS boundary (FPL 2018f). 10 In the wider vicinity of Turkey Point, the regional groundwater flow in the Biscayne aquifer is 11 generally to the east towards the coast. However, more directly under and near the Turkey 12 Point site, groundwater flow is affected locally by tides and drainage canals (NRC 2016a). In 13 the NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses, Section 2.3.1.2, 14 Groundwater Flow Direction, (NUREG-2176) (NRC 2016a) describes in some detail the 15 complex flow interactions between the CCS, the operation of the CCS interceptor ditch and 16 adjacent L-31E Canal, and the hydrologic and density-driven dynamics of the hypersaline 17 plume. As mentioned in the previous paragraph, the hypersaline plume has grown in size and 18 moved laterally beyond the CCS and the bordering L-31E Canal, predominantly to the west 19 within the deeper part of the Biscayne aquifer. The NRC staff incorporates the information in 20 Section 2.3.1.2 of the COL EIS here by reference (NRC 2016a: 2-51, 2-53). In this SEIS, 21 Section 3.1.3.2, Cooling Canal System (CCS), describes the interceptor ditch. The current 22 extent of the hypersaline plume emanating from the CCS and its effects on groundwater quality 23 and saltwater intrusion are further discussed below in Section 3.5.2.2, Groundwater Quality. 24 Intermediate Confining Unit 25 Separating the surficial Biscayne aquifer and the Floridan aquifer system is the hydrogeologic 26 unit called the Intermediate Confining Unit (see Figure 3-6 in Section 3.4). This unit has a 27 generally low permeability and is over 800 feet (240 m) thick beneath the Turkey Point site. It is 28 comprised of extensive layers of clay-rich sediments in the upper part of the unit (NRC 2016a). 29 Sands and limestone lenses comprise the permeable parts of this unit (Figure 3-6). Site 30 information suggests that the thickness ranges from approximately 700 feet (210 m) just to the 31 north of the Turkey Point site (at Unit 5 production well PW-3) to about 1,000 feet (300 m) 32 southwest of the site. The Intermediate Confining Unit serves as an effective aquiclude (an 33 impermeable layer or rock or stratum or sediment) for the Floridan aquifer system throughout 34 the state of Florida (FPL 2018f). 35 Floridan Aquifer System 36 The Floridan aquifer system underlies the Intermediate Confining Unit. The system is 37 composed principally of dolomite and limestone and is under confined conditions beneath the 38 Turkey Point site and throughout southeastern Florida. The Floridan aquifer system at the 39 Turkey Point site principally consists of the Upper Floridan aquifer, a middle confining unit, and 40 the saline Lower Floridan aquifer (FPL 2018f, NRC 2016a) (Figure 3-6). 41 The Upper Floridan aquifer is composed of several thin water-bearing zones interlayered with 42 thick zones of low permeability. Across most of Florida, it is a major source of potable water; 43 however, in southeastern Florida, including Miami-Dade County, the water is brackish and 44 requires treatment to meet drinking water standards. While the aquifer can be 400 feet (120 m) 45 or more in thickness across southeastern Florida, at the Turkey Point site, it is approximately 3-56

1 200 feet (60 m) thick (FPL 2018f). Regionally, groundwater flow in the aquifer is generally west 2 to east across the site toward the coast. This is confirmed by groundwater level data from 3 Upper Floridan aquifer wells located near the Turkey Point site (FPL 2018f, NRC 2016a). 4 The middle confining unit within the Floridan aquifer system consists of beds of less permeable 5 strata that are more than 1,000 feet (300 m) thick, separating the aquifers above and below 6 (FPL 2018f). As described in Section 2.3.1.2 of NUREG-2176, the middle (Floridan) confining 7 unit generally contains a relatively thin, permeable zone called the Avon Park Permeable (or 8 Producing) Zone (APPZ), and a lower confining zone (see Figure 3-6 in Section 3.4 of this 9 SEIS). However, the Avon Park zone thins to the south and was not identified at the EW-1 10 exploratory well at Turkey Point (NRC 2016a). 11 The upper part of the Lower Floridan aquifer is comprised of low permeability (confining layer) 12 rocks; the deeper part of the Lower Floridan aquifer is a well-developed, highly permeable karst 13 region of fractured carbonate rock known as the Boulder Zone (FPL 2018f, NRC 2016a). The 14 high permeability of the Boulder Zone has been attributed to a network of horizontal caverns at 15 varying depths connected by vertical tubes. Water quality in the Boulder Zone is similar to 16 modern seawater. Within the Boulder Zone, it appears that seawater moves westward from a 17 connection with the Atlantic Ocean off the coast at a depth of about 2,500 feet (760 m). At the 18 Turkey Point site, the top of the Boulder Zone has been identified at a depth of 3,030 feet 19 (994 m). This depth is consistent with statewide mapping (NRC 2016a). 20 3.5.2.2 Groundwater Quality 21 Groundwater Quality Standards and Current Designated Uses 22 The FDEP classifies groundwater within the State of Florida according to present and future 23 most beneficial uses. The State of Florida establishes water quality standards to protect 24 designated uses (FAC R62-520.300). Florida categorizes groundwater in one of five classes 25 (FAC R62-520.410). These five classes generally relate to the level of potability (i.e., use for 26 drinking and related purposes) as determined by total dissolved solids (TDS) content. 27

• Class F-I: Potable water use, groundwater in a single source aquifer described in FAC 28 R62 520.460, with a total dissolved solids content of less than 3,000 mg/L and 29 specifically reclassified as Class F-I by the Florida Environmental Regulation 30 Commission.

31

• Class G-I: Potable water use, groundwater in a single source aquifer that has a total 32 dissolved solids content of less than 3,000 mg/L and specifically reclassified by the 33 Florida Environmental Regulation Commission.

34

• Class G-II: Potable water use, groundwater in aquifers with a total dissolved solids 35 content of less than 10,000 mg/L, unless otherwise classified by the Florida 36 Environmental Regulation Commission.

37

• Class G-III: Nonpotable water use, groundwater in unconfined aquifers with a total 38 dissolved solids content of 10,000 mg/L or greater; or with a total dissolved solids 39 content of 3,000-10,000 mg/L and either reclassified by the Florida Environmental 40 Regulation Commission as having no reasonable potential as a future source of drinking 41 water or designated by the FDEP as an exempted aquifer.

42

• Class G-IV: Nonpotable water use, groundwater in confined aquifers with a total 43 dissolved solids content of 10,000 mg/L or greater.

3-57

1 The State of Florida provides single-source aquifersthose aquifers it identifies as the only 2 reasonably available source of potable water to a significant segment of the populationwith 3 the highest level of protection. The FDEP designates such aquifers as Class F-1 and G-I, which 4 have TDS concentrations of less than 3,000 mg/L (FAC R62-520.410). For comparison, the 5 Federal drinking water standard or secondary maximum contaminant level (MCL) for TDS is 6 500 mg/L (40 CFR 143.3). This secondary standard is based on aesthetic considerations 7 (i.e., taste, color, and odor) and the constituent does not present a risk to human health at the 8 specified level. The FDEP has adopted the same secondary standard for Florida drinking water 9 (FDEP 2018b). 10 Beneath the Turkey Point site and across southeastern Miami-Dade County, the quality of 11 groundwater within the Biscayne and Floridan aquifer systems varies greatly due to the 12 interaction of natural as well as human-induced factors over time. This is most apparent in the 13 surficial Biscayne aquifer as saltwater intrusion (encroachment) has occurred under a large area 14 of the southeast Florida coast, including under the Turkey Point site. 15 The NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) 16 (NRC 2016a) cites a U.S. Geological Survey (USGS) study (Prinos et al. 2014) investigating the 17 origins and extent of saltwater intrusion in the Biscayne aquifer. In the study, the USGS 18 presented its analysis of tritium measurements from USGS monitoring wells within about 6 mi 19 (10 km) of the Turkey Point site, which indicated that water from the CCS may contribute to 20 saltwater encroachment in areas northwest of the CCS (Prinos et al. 2014). 21 FPL states in its environmental report (FPL 2018f) that, even before construction of the CCS in 22 the mid-1970s, the Biscayne aquifer near the Turkey Point site was saline for the full depth of 23 the aquifer, and saltwater intrusion into the Biscayne aquifer had already occurred several miles 24 inland (FPL 2018f). This is supported by information in the NRC staffs EIS for the Turkey Point 25 Units 6 and 7 combined licenses (NUREG-2176), Section 2.3.3.2 and Figure 2-22. The NRC 26 staff incorporates Section 2.3.3.2 and Figure 2-22 of NUREG-2176 into this SEIS by reference. 27 NUREG-2176, Figure 2-22 depicts various mapped estimates by the USGS and others of the 28 saltwater interface over the period of 1951 to 2008. These USGS historic estimates depict 29 interface locations that are no less than about 4 mi (6.6 km) west and northwest of the CCS. 30 NUREG-2176, Section 2.3.3.2 contains the NRC staffs characterization of factors contributing 31 to saltwater intrusion, including contributions from the CCS (NRC 2016a: 2-68, 2-69). 32 Inland migration of the saltwater interface within the Biscayne aquifer continues across the 33 region. Based on a recent USGS estimate, the saltwater interface has moved inland across 34 portions of southeastern Miami-Dade County, west and north of the Turkey Point site, at an 35 average rate of 460 feet (140 m) per year (Prinos 2017). Figure 3-12 below depicts the current 36 location of the saltwater interface at the base of the Biscayne aquifer in relation to the Turkey 37 Point site, the CCS, and groundwater monitoring wells maintained by FPL. The saltwater 38 interface is currently located about 4.7 mi (7.6 km) west of the CCS at its closest point, based 39 on the latest (2017) USGS monitoring well data. The mapped location reflects the current 40 estimate of the 1,000 mg/L concentration boundary for chloride at the base of the Biscayne 41 aquifer (Prinos 2017). 42 In 1983, the FDEP designated as Class G-Ill (i.e., non-potable use with TDS levels of 43 10,000 mg/L or greater) the surficial groundwater (Biscayne aquifer) within the Turkey Point 44 plant property, with the west side of the CCS marking the western boundary (FPL 2018f, 45 SFWMD 2009). FDEP has classified groundwater west of the Turkey Point site (i.e., to the west 3-58

1 of the site boundary and CCS) as Class G-II, which means potable water use, with TDS levels 2 of less than 10,000 mg/L (FPL 2018f). 3 In 2014, the FDEP issued an administrative order to FPL. In this 2014 administrative order, the 4 findings of fact state that saltwater was present as early as the 1940s near the base of the 5 Biscayne aquifer west of the Turkey Point site. It further states that groundwater data from the 6 early 1970s (prior to completion of CCS construction in 1973) supported the determination that 7 non-potable groundwater (TDS exceeds 10,000 mg/L) occurred beneath much of the proposed 8 CCS at depth and within the deeper portions of the aquifer west of the site (FDEP 2014). 9 Through wells located inland of the saltwater interface, the Biscayne aquifer is the major public 10 water supply source across Miami-Dade County as well as for the Florida Keys (NRC 2016a: 2-11 60). In addition, the EPA has designated the Biscayne aquifer across all of south Florida as a 12 sole-source aquifer pursuant to Section 1424(e) of the Safe Drinking Water Act of 1974 13 (EPA 2016a, FPL 2018f, NRC 2016a). 14 The Biscayne aquifer is not the only current or potential source of drinking water in the region. 15 The Upper Floridan aquifer is also an important source of freshwater in parts of Florida. The 16 FDEP designates the Upper Floridan aquifer as an underground source of drinking water 17 because its water has a TDS concentration of less than 10,000 mg/L (FAC R62-528.200, 18 NRC 2016a). However, while the groundwater within the Upper Floridan aquifer contains less 19 than 10,000 mg/L TDS in southeastern Florida, with TDS concentrations greater than 20 2,000 mg/L, water obtained from the aquifer is too saline to be used for drinking water without 21 treatment (NRC 2016a). 3-59

1 Source: Modified from FPL 2017a Fig. 1.1-1 2 Figure 3-12 Groundwater Monitoring Locations and Saltwater Interface, Turkey 3 Point Site 3-60

1 Baseline Groundwater Quality and Changes Attributable to Turkey Point Operations 2 The SEIS for the Turkey Point Units 3 and 4 initial license renewal (NUREG-1437, 3 Supplement 5) (NRC 2002c) documents the NRC staffs environmental review of FPLs 4 application for the initial 20-year license renewal submitted in 2000. Section 2.1.3 of that EIS 5 describes the likely exchange between the canals and groundwater as well as the operation of 6 the CCS and associated interceptor ditch. As stated therein, the operation of the interceptor 7 ditch was intended to prevent the flow of hypersaline water from the cooling canals toward the 8 Everglades (i.e., inland to the west) (NRC 2002c). 9 Thus, when the NRC staff published its SEIS for the Turkey Point initial license renewal in 2002, 10 the staff acknowledged the existence of a hypersaline plume in the Biscayne aquifer directly 11 beneath the CCS. What was not fully understood at the time was the potential for the 12 hypersaline plume to migrate downward through the Biscayne aquifer and then to move laterally 13 within the Biscayne aquifer beyond the CCS boundaries. The following discussion presents 14 new information on the effects of CCS operations on hypersalinity in the Biscayne aquifer and 15 groundwater quality. 16 The interaction of water in the CCS (including cooling loop water and stormwater from Turkey 17 Point) with underlying groundwater in the Biscayne aquifer is complex. In the CCS, heat is 18 rejected to the atmosphere primarily through evaporation, resulting in a net loss of water from 19 the canals. As water evaporates from the CCS, the concentration of dissolved substances, 20 principally salts, in the CCS increases. This increases the density of the CCS water. The high 21 rate of evaporation also produces a net inflow of groundwater into the CCS, but the groundwater 22 flux between the CCS and Biscayne aquifer varies by location. The following variables and 23 factors also affect these groundwater interactions between CCS waters and Biscayne aquifer 24 waters: 25

• precipitation, specifically seasonal precipitation variation during the wet season versus 26 the dry season 27
• variations in hydraulic head (water table elevation) 28
• cooling water effluent discharge rate 29
• air temperature 30
• humidity 31
• tidal fluctuations 32 As a result of the above variables, the direction of water movement into or out of the CCS varies 33 in time and space. Over time, the denser, heated, hypersaline water migrates downward from 34 the CCS into the Biscayne aquifer. The downward movement of hypersaline water is impelled 35 by the increased density because of the elevated salinity of the water in the CCS (NRC 2016a).

36 In preparing the EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) 37 (NRC 2016a), the NRC staff reviewed modeling performed by Hughes et al. (2010), which used 38 a two-dimensional, cross-section model to evaluate the combined effects of salinity, 39 temperature, and other variables associated with operation of the CCS, including the CCSs 40 contribution to the movement of the saltwater interface. The Hughes modeling demonstrates 41 that the downward migration of hypersaline water takes the form of finger plumes that form 42 beneath the CCS and then move downward to the bottom of the permeable zone of the aquifer 3-61

1 in a period ranging from days to several years, depending on localized differences in aquifer 2 properties. These finger plume structures then mix with aquifer water through advection and 3 dispersion (NRC 2016a). The modeling also indicates that the inland migration of the saltwater 4 interface is closely related to TDS concentrations in the CCS (Hughes et al. 2010). 5 FPL operates the interceptor ditch to maintain an eastward hydraulic gradient (toward the CCS). 6 However, this operation has not completely prevented the hypersaline CCS water that enters 7 the Biscayne aquifer from migrating westward. This is primarily because the interceptor ditch 8 only functions to the depth to which it was constructed, as described in Section 3.5.1.1, Surface 9 Water Hydrology, thus enabling hypersaline water that has moved to deeper depths in the 10 aquifer to move beyond and west of the interceptor ditch. 11 Since 2009, FPL has maintained an extensive, multimedia environmental (uprate-related) 12 monitoring program in accordance with Turkey Points site certification conditions 13 (i.e., Conditions IX and X), as modified (FDEP 2016b, State of Florida Siting Board 2016) 14 pursuant to the Florida Power Plant Siting Act and related regulatory requirements, stemming 15 from the NRCs June 2012 approval of the Turkey Point extended power uprate (EPU) project. 16 The focus of this uprate monitoring program is to determine the horizontal and vertical effects of 17 CCS water on the environment. FPL conducts this program in accordance with the 2009 18 monitoring plan (SFWMD 2009) under the auspices of the FDEP, SFWMD, and the Miami-Dade 19 County Department of Environmental Resources Management (DERM). 20 FPL completed a period of pre-uprate monitoring in 2012, covering the period of June 2010 21 through June 2012, and submitted it for interagency review in October 2012 (FPL 2018f, 22 FPL 2012a). Monitoring results are reported in publicly available annual monitoring reports 23 submitted to the FDEP and partner agencies including the South Florida Water Management 24 District and Miami-Dade County. To date, the results of FPLs groundwater uprate monitoring 25 demonstrate that CCS operations have impacted groundwater quality in the Biscayne aquifer to 26 the west of the L-31E Canal as well as beneath Biscayne Bay to the east (NRC 2016a). 27 For groundwater monitoring, FPLs contractor performs quarterly field sampling from 14 well 28 clusters, comprising 42 wells in total. This is in addition to automated water quality and water 29 level measurements at each well (FPL 2017a). Each well cluster consists of three, collocated 30 Biscayne aquifer monitoring wells (i.e., shallow, intermediate, and deep), which are shown 31 above in Figure 3-12. 32 For each monitoring well, FPL collects and analyzes groundwater samples for 29 separate 33 parameters, including general water quality parameters (e.g., temperature, pH), ionic, and 34 nutrient constituents. Tritium is used as a chemical tracer in order to determine the potential 35 movement of CCS water within the Biscayne aquifer (FPL 2017a, SFWMD 2009). Specifically, 36 by interagency consensus, tritium was established as a tracer for the CCS water with a 37 threshold concentration value for tritium of 20 pCi/L in groundwater (FPL 2012a). Table 3-4 38 below summarizes the latest available analytical results for selected wells and key monitored 39 parameters. 3-62

1 Table 3-4 Summary of Groundwater Monitoring Results for Selected Biscayne Aquifer 2 Wells (Shallow and Deep Intervals), Turkey Point Uprate Monitoring Program Parameter Results(a), Current (2017)(b) and Historic (2011)(c) Well Number Chloride TDS Salinity Tritium Ammonia (PSU) (pCi/L) TPGW-1S (2017) 16,400* 27,500 28.41 698 1.08 TPGW-1D (2017) 29,900 19,400* 47.60 2,365 1.62* TPGW-1S (2011) 17,000 27,000 27.8 810 0.87 TPGW-1D (2011) 29,000 50,000 48.1 2,560 1.3 TPGW-2S (2017) 26,700 33,400 41.67 1,955 1.61* TPGW-2D (2017) 35,800* 43,400 49.95* 3,101 2.22* TPGW-2S (2011) 30,000 50,000 52.4 3,030 1.5 TPGW-2D (2011) 32,000 52,000 54.2 3,320 1.7 TPGW-4S (2017) 1,220 2,190 2.12 17.4 M TPGW-4D (2017) 17,200* 19,400 26.82 403 M TPGW-4S (2011) 670 1,400 1.4 19.4 M TPGW-4D (2011) 16,000 26,000 28.0 519 M TPGW-7S (2017) 33.8 270 0.27* 4.2*U M TPGW-7D (2017) 3,400* 5,400 5.42 26.6 M TPGW-7S (2011) 35 300 0.3 13.5 M TPGW-7D (2011) 42 310 0.3 2.2 M TPGW-9S (2017) 23.3 334 0.29* 9.7*U M TPGW-9D (2017) 25.7 348 0.31* -4.5*U M TPGW-9S (2011) 20 330 0.3 10.6 M TPGW-9D (2011) 28 350 0.3 1.5 M TPGW-10S (2017) 21,800* 28,600 36.25 69.1 0.56 TPGW-10D (2017) 28,400 36,100 47.68 1,690 1.45 TPGW-10S (2011) 19,000 33,000 33.8 18.4 0.32 TPGW-10D (2011) 22,000 36,000 37.4 8.2 0.22 TPGW-11S (2017) 23,500 17,400* 36.17 -5.6*U M TPGW-11D (2017) 26,900 35,300 44.3 1,066 M TPGW-11S (2011) 22,000 36,000 36.9 2.4 M TPGW-11D (2011) 24,000 39,000 39.3 435 M TPGW-13S (2017) 36,500 47,700 55.8 4,122 3.69* TPGW-13D (2017) 34,800 48,000 58.27 3,674 3.66* TPGW-13S (2011) 38,000 61,000 61.6 3,800 2.8 TPGW-13D (2011) 37,000 59,000 59.2 3,830 1.6 TPGW-14S (2017) 22,900 29,100 39.03 91.5 0.551 TPGW-14D (2017) 32,800 37,600 49.5 2,234 2.33 TPGW-14S (2011) 24,000 39,000 40.0 247 0.54 TPGW-14D (2011) 32,000 52,000 51.8 2,660 1.6*- Notes: D=deep well; S=shallow well; TDS=total dissolved solids. *=Denotes result qualified as estimated (+/- indicates bias); M=Denotes missing data; U=Indicates analyzed for but not detected at the reported value. Some results in the table may be rounded. 3-63

Parameter Results(a), Current (2017)(b) and Historic (2011)(c) (a) All units are reported in milligrams per liter (mg/L) except salinity (reported in practical salinity units (PSU) based on the practical salinity scale of 1978) (unitless) and tritium (picoCuries per liter (pCi/L) with 1 uncertainty error omitted). Ammonia is reported as total ammonia nitrogen. (b) Analytical results from the March 2017 quarterly sampling event (FPL 2017a). (c) Analytical results from the March 2011 quarterly sampling event (FPL 2012a). Source: FPL 2012a, FPL 2017a. 1 Monitoring well locations were established based on FPL and interagency consensus and 2 criteria as documented in the 2009 monitoring plan (SFWMD 2009). The wells are located such 3 that monitoring will be able to detect changes in groundwater quality, including migration of the 4 hypersaline plume, both in the near field (adjacent to the CCS) and at representative far-field 5 locations (i.e., at distances not currently identified as having been affected by CCS water). For 6 example, wells TPGW-13S/D are at the approximate center of the CCS, the source of the 7 hypersaline plume. Wells TPGW-1 through TPGW-7 are situated at various distances to the 8 north and west of the CCS. Well cluster TPGW-7S/D can also be considered a sentinel well as 9 it is the monitoring location nearest to the Miami-Dade Countys Newton Wellfield that supplies 10 potable water to municipal customers. Well location TPGW-9S/D is a reference well location 11 reflecting groundwater conditions unaffected by the CCS and located upgradient (west) of the 12 saltwater interface. Well locations TPGW-10S/D, TPGW-11S/D, TPGW-13S/D, and 13 TPGW-14S/D are offshore in Biscayne Bay. 14 As summarized in Table 3-4 above, the analytical results from FPLs monitoring program 15 include the deep-screened interval (Biscayne aquifer) of the listed well locations that 16 corresponds to the base of the Biscayne aquifer, as well as from the shallow (upper) interval, in 17 order to identify any vertical differences in water quality parameters. It is in the lower intervals 18 of the aquifer where hypersaline water from the CCS would be expected to preferentially move, 19 as well as where migration of the regional saltwater interface would first be evident. 20 Further, Table 3-4 compares quarterly groundwater sampling results for the same seasons (i.e., 21 March 2011 and March 2017) so that results for monitored parameters at the well locations can 22 be compared over time. March is near the end of the dry season across southeast Florida and 23 is the timeframe where the effects of CCS water incursion would likely be more discernible. 24 Additionally, data from March 2011 are included to provide an historical baseline, representing 25 the pre-extended power uprate monitoring period for Turkey Point. 26 The NRC staff has used current (2017) and historical groundwater monitoring data to document 27 baseline groundwater quality as well as changes in quality in the Biscayne aquifer within and 28 adjacent to the Turkey Point site. The results reflect the current FDEP classification for Class 29 G-III groundwater (i.e., TDS of 10,000 mg/L or greater) in the area of the site, corresponding to 30 the western boundary of the CCS and encompassing the Turkey Point property to the east. The 31 current monitoring data (Table 3-5) also establish that TDS concentrations in Class G-II 32 designated groundwater immediately to the west of the CCS boundary exceed the G-II standard 33 (TDS of less than 10,000 mg/L). Monitoring results further show the influence of CCS 34 operations on groundwater quality beneath the CCS within the Biscayne aquifer and adjacent to 35 the CCS, particularly as reflected in data for wells TPGW-2D and TPGW-4D. More precisely, 36 the data presented in Table 3-4 as well as in the broader quarterly monitoring data sets 37 (June 2016, September 2016, December 2016, and March 2017) for these wells (FPL 2017a) 38 generally show an increasing vertical trend with depth (i.e., from the shallow to the deep 39 monitored intervals) in chloride, TDS, and tritium concentrations at these locations. This is 3-64

1 indicative of the influence of CCS water in the deep interval of the Biscayne aquifer. This is 2 further reflected in data for the June 2013 to May 2015 monitoring periods (FPL 2016a). 3 Similarly, tritium levels measured in wells to the east of the CCS in Biscayne Bay 4 (i.e., TPGW-10, TPGW-11, and TPGW-14) suggest the influence of CCS water, at least in the 5 deep interval of the Biscayne aquifer. For all monitored parameters at these groundwater 6 locations (TPGW-2, -4, -10, -11, and -14), the NRC staff observes that the influence of CCS 7 water was evident prior to implementation of the extended power uprate beginning in 2012. 8 In summary, the NRC staff concludes that hypersaline groundwater in the Biscayne aquifer 9 exists under and adjacent to the CCS, with hypersaline conditions diminishing with increased 10 distance from the CCS. According to FPLs 2017 annual monitoring report, the extent of 11 potential CCS influence is 4.5 mi (7.2 km) west of the CCS. This line of influence is based on 12 the current estimate of the 20 pCi/L concentration boundary for tritium in groundwater, with the 13 mapped contour line passing just west of monitoring well TPGW-7D, which is depicted below in 14 Figure 3-13. It should be noted that tritium readings of 20 pCi/L are not significant; for 15 comparison, the EPAs primary drinking water standard or maximum contaminant level for 16 tritium is 20,000 pCi/L (40 CFR 141.16). 3-65

1 Source: Modified from FPL 2017a: Fig. 5.1-4 2 Figure 3-13 Extent of Tritium in the Deep Interval of the Biscayne Aquifer in the 3 Vicinity of the Turkey Point Site, 2017 4 As described in FPLs 2017 annual monitoring report, FPL had previously estimated the 5 historical limit, prior to CCS construction, of Class G-III groundwater (non-potable water with a 6 TDS content of 10,000 mg/L or greater). FPL based this estimate on historical TDS values from 7 groundwater wells. Where historical TDS values were not directly available, FPL used the 8 relationship between measurements of specific conductance and TDS to estimate historical 9 TDS values. The 2017 annual monitoring report concludes that most of the Biscayne aquifer 10 currently affected by the CCS never contained potable water (FPL 2017a). 11 Nevertheless, and as FPLs 2017 annual monitoring report notes, monitoring has shown 12 increases in one or more constituents (e.g., chloride, tritium) in several wells over the last 4 to 5 13 years that indicate the expansion of more saline groundwater. These wells include TPGW-7D, 14 TPGW-10D, and TPGW-11D. At TPGW-7D, the water transitioned from fresh to brackish 15 between the summer of 2013 and January 2017. FPL attributed the increase in observed ion 16 concentrations (e.g., chloride) to advance of the saltwater interface, but remained uncertain 17 about the source of the higher tritium levels (i.e., 26.6 pCi/L in 2017 versus 2.2 pCi/L in 2011, 3-66

1 see Table 3-4) (FPL 2017a). Meanwhile, wells TPGW-10D and TPGW-11D, just east of the 2 CCS in Biscayne Bay, have exhibited increases in conductance, chloride, and tritium since 3 2013. FPLs 2017 annual monitoring report suggests that the increase in tritium in these wells 4 indicates a potential increase in the amount of CCS-sourced groundwater compared to the 5 original marine groundwater (FPL 2017a). 6 Current (2017) water quality monitoring results and other available well data show that a fresher 7 groundwater lens (i.e., lower chloride and TDS concentrations) exists in the upper 8 (i.e., 18 to 20 ft (5.5 to 6.1 m)) interval of the Biscayne aquifer just to the west of the CCS. This 9 lens generally thickens to over 50 feet (15 m) in depth at TPGW-7 (see Figure 3-12). Here, in 10 the shallow interval at this monitoring location (TPGW-7S), the groundwater appears to meet 11 the Class G-II criterion for potable water use with a TDS content of less than 10,000 mg/L (see 12 Table 3-4). At a distance of over 5.5 mi (8.9 km) west of the CCS (e.g., at TPGW-9, see Table 13 3-4 and Figure 3-12), the aquifer is presently fresh at all depths (FPL 2017a). 14 Regulatory Developments with Respect to Cooling Canal System Operations and Groundwater 15 Quality 16 As discussed above, beginning in 2010, FPL implemented an expanded groundwater 17 monitoring program in support of Turkey Points extended power uprate and associated 18 regulatory approvals. This expanded groundwater monitoring program helped to identify the 19 need for FPL to take corrective actions to address onsite and offsite impacts associated with 20 operation of the CCS, especially involving salinity, chloride, and ammonia concentrations 21 (FPL 2018f: 3-90, 3-91). In consultation with and at the direction of State and local regulatory 22 agencies, since 2013, FPL has undertaken a number of actions to mitigate impacts associated 23 with CCS operation. Most of these actions focus on reducing high salinities within the CCS. 24 Most recently, these actions included active measures to halt and remediate the migration of the 25 hypersaline plume from the CCS. This section of the SEIS presents a brief summary of the 26 history, the current status, and the scope of the associated regulatory mechanisms governing 27 FPLs actions focusing on groundwater quality issues. 28 In December 2014, the FDEP issued an administrative order to FPL directing, in part, that FPL 29 develop a salinity management plan for the CCS along with additional monitoring requirements 30 (FDEP 2014a, FPL 2018f). Several entities, including Miami-Dade County, challenged the 31 FDEPs 2014 administrative order. 32 On October 2, 2015, Miami-Dade County issued a notice of violation (NOV) to FPL alleging 33 violations of county water quality standards and criteria in groundwater beyond the boundaries 34 of the CCS and FPL property (FPL 2018f, MDC 2015a). Subsequently, on October 7, 2015, 35 Miami-Dade County and FPL entered into a consent agreement (the 2015 Consent Agreement). 36 In the 2015 Consent Agreement, the County recognized the salinity reduction efforts that FPL 37 was already undertaking including the use of onsite marine production wells and plans to 38 construct six wells to withdraw water from the Upper Floridan aquifer for CCS salinity reduction. 39 The 2015 Consent Agreement requires FPL to evaluate alternative water sources to offset water 40 deficits in the CCS and to reduce chloride concentration in the CCS, including the use of 41 reclaimed wastewater from the Miami-Dade South District Wastewater Treatment Plant 42 (FPL 2018f, MDC 2015a). Moreover, the 2015 Consent Agreement specifically requires FPL to 43 maintain measures to abate hypersaline water discharges and to actively remediate the 44 hypersaline groundwater west and north of FPLs property, without creating adverse 45 environmental impacts. The stipulated remedial action is the installation and operation of a 46 Biscayne aquifer recovery well system to intercept, capture, and retract the hypersaline plume 3-67

1 from the CCS to within FPLs property boundary, along with associated deep well disposal of 2 the extracted hypersaline groundwater. The Consent Agreement also requires that FPL 3 conduct additional monitoring, submit annual reports and undertake surveys (i.e., continuous 4 surface electromagnetic mapping of the hypersaline plume) to gauge progress toward meeting 5 the terms of the agreement. Finally, FPL is required to review, report, and consult on any 6 necessary changes related to the effectiveness of the recovery well system at 7 5-year and 10-year intervals (MDC 2015a). 8 On August 15, 2016, FPL and Miami-Dade County executed an addendum revising the 9 2015 Consent Agreement. The revised agreement (the 2016 Addendum) requires FPL to take 10 action to evaluate and address alleged violations of Miami-Dade County water quality standards 11 and cleanup target levels relating to the exceedance of ammonia standards in surface water, 12 including deep remnant canals adjacent to the Turkey Point CCS. The 2016 Addendum further 13 requires that FPL prepare a site assessment report to identify the sources of ammonia 14 exceedances and to delineate their extent in surface water in accordance with a site 15 assessment plan approved by Miami-Dade County (MDC 2016a). On December 29, 2016, in 16 response to the Countys comments on the draft site assessment plan, FPL submitted an 17 amended site assessment plan, and it initiated environmental sampling on January 3, 2017, as 18 approved by Miami-Dade County (FPL 2017b). FPL submitted its completed site assessment 19 report to the County on March 17, 2017 (FPL 2017c). 20 The completed ammonia site assessment report documents the results of FPLs sampling and 21 analysis program to assess the nature and extent of ammonia in surface waters near the Turkey 22 Point site and in the CCS. It includes sampling results from numerous surface water, 23 porewater, canal water, and groundwater sampling locations as well as stratified surface water 24 sampling. With respect to groundwater, FPL sampled nine monitoring wells completed in the 25 Biscayne aquifer, including: (1) four wells northeast of the Turkey Point power block (FTF-SW, 26 FTF-NW, FTF-SE, MW-5), (2) two wells east of the power block (MW-3, MW-4) adjacent to the 27 discharge canal and Biscayne Bay, (3) two wells (South MW, North MW) southeast of the power 28 block near FPLs sanitary injection well and discharge canal, and (4) one deeper well located 29 south of the Turkey Point complex in the mud flat area known as Mud Island (C6-5). While all 30 wells had detectable ammonia, the concentrations were variable, ranging from a low of 31 0.17 mg/L at MW-3 adjacent to the intake canal and Biscayne Bay to a high of 4.6 mg/L at the 32 South MW, as compared to the surface water quality standard of 0.5 mg/L. The report states 33 that the high concentration of ammonia at South MW and relatively fresh water in the well may 34 be caused by the sanitary wastewater injection well. Well C6-5 had the second highest 35 ammonia concentration (2.48 mg/L). This deeper well (C6-5) at 90 feet (27 m) was the only well 36 sampled that also exhibited hypersalinity (52.2 PSU), indicating potential CCS influence 37 (FPL 2017c). 38 In July 2017, Miami-Dade County requested that FPL collect additional data in support of the 39 ammonia site assessment report (FPL 2017b). In November 2017, FPL responded to the 40 Countys request by submitting supplemental information. In a July 18, 2018 letter, the County 41 informed FPL that it had completed its review of the site assessment report and supplemental 42 information. The Countys letter states that based on its review of FPLs ammonia data as well 43 as its review of historical groundwater monitoring data collected from the TP-GW series uprate 44 monitoring wells (e.g., TPGW-1, TPGW-2, TPGW-10, TPGW-13, and TPGW-14), there is a 45 statistically significant increasing trend in ammonia concentrations in groundwater in the 46 intermediate and deep intervals along with a concentration gradient emanating from the CCS. 47 The Countys letter directs FPL to undertake a number of additional actions, including 48 development of a revised sampling plan for ammonia in surface water and groundwater and 3-68

1 measures to reduce nutrient impacts from the CCS on surface waters and groundwater 2 (MDC 2018a). Surface water sampling results from the ammonia site assessment report are 3 discussed in Section 3.5.1.4, Adjacent Surface Water Quality and Cooling Canal System 4 Operation, of this SEIS. 5 Separately, the FDEP issued a modified final administrative order to FPL on April 21, 2016 (the 6 2016 Final Administrative Order) (FDEP 2016h, FPL 2018f). The FDEPs 2016 Final 7 Administrative Order concludes, in part, that the preponderance of the record evidence 8 indicates the CCS is the major contributing cause of the continuing westward movement of the 9 saline water interface (FDEP 2016h). 10 On April 25, 2016, the FDEP issued a warning letter (FDEP 2016c) expressing concern that 11 CCS water was reaching Biscayne Bay. Concurrently, the FDEP issued a notice of violation to 12 FPL that incorporated findings from the FDEPs April 21, 2016 Final Administrative Order and 13 specifically directed FPL to enter into consultations to develop a consent order for corrective 14 actions to abate the CCS contribution to the hypersaline plume, reduce the size of the 15 hypersaline plume, and prevent future harm to waters of the State (FDEP 2016d, FPL 2018f). 16 To resolve the warning letter and notice of violation, FPL and the FDEP executed a consent 17 order on June 20, 2016 (the 2016 FDEP Consent Order) (FDEP 2016e). The 2016 FDEP 18 Consent Order contains three primary objectives (FDEP 2016e, FPL 2018f) as well as the 19 methods FPL must use to meet each objective. The three objectives are as follows: 20

• First Objective. Cease discharges from the CCS that impair the reasonable and 21 beneficial use of the adjacent Class G-II groundwater by maintaining the average annual 22 salinity of the CCS at or below 34 PSU, by undertaking freshening activities, by 23 eliminating the CCS contribution to the hypersaline plume, by halting the westward 24 migration of hypersaline water from the CCS, and by reducing the westward extent of 25 the hypersaline plume to the L-31E Canal within 10 years, thereby removing its influence 26 on the saltwater interface without creating adverse environmental impacts.

27

• Second Objective. Prevent releases of groundwater from the CCS to surface waters 28 connected to Biscayne Bay that result in exceedances of surface water quality standards 29 in Biscayne Bay.

30

• Third Objective. Provide mitigation for impacts related to the historic operation of the 31 CCS, including but not limited to the hypersaline plume and its influence on the saltwater 32 interface. (FDEP 2016e) 33 The First Objective of the 2016 FDEP Consent Order primarily involves reducing salinity in the 34 CCS and thereby also reducing the CCS contribution to the hypersaline plume in the Biscayne 35 Aquifer and the plumes westward migration. Since 2015, FPL has been using a variety of 36 water sources to manage salinity within the CCS. It has also implemented a number of 37 additional CCS operational and surface water quality management measures as required by the 38 2016 FDEP Consent Order, which are discussed in Section 3.5.1.2, Surface Water Hydrology, 39 of this SEIS.

40 With regard to meeting the 34 PSU salinity metric specified in the 2016 FDEP Consent Order 41 and consistent with the requirements of the 2015 Consent Agreement with Miami-Dade County, 42 FPL commenced operation of a new freshening well system on November 28, 2016, adding 43 groundwater from the Upper Floridan aquifer to the CCS. The State of Florida authorizes FPL 44 to withdraw up to 14 mgd (53,000 m3/day) from the Upper Floridan aquifer from six wells under 3-69

1 its modified site certification for the Turkey Point site; FPL has constructed five wells to date 2 (i.e., wells F-1, F-2, F-3, F-4, and F-5) (FDEP 2016b, State of Florida Siting Board 2016). By 3 adding brackish (i.e., average of 2.5 PSU) Upper Floridan aquifer groundwater to the CCS, FPL 4 intends to minimize the increase in salinity that can occur in the CCS during the yearly dry 5 season, reduce average CCS salinity to meet the 2016 FDEP Consent Order metric of 34 PSU, 6 and reduce the CCS contribution to the existing hypersaline plume (FPL 2018f). 7 Section 3.5.2.3, Groundwater Use, in this SEIS contains a separate discussion of groundwater 8 withdrawals associated with salinity reduction and other activities at the Turkey Point site. 9 In order to stop and then retract the westward migration of hypersaline groundwater originating 10 from the CCS, the 2016 FDEP Consent Order requires FPL to permit, construct, and operate a 11 recovery well system to remediate the hypersaline plume in the Biscayne aquifer (FDEP 2016e). 12 This requirement is consistent with the 2015 Consent Agreement (MDC 2015a) between FPL 13 and Miami-Dade County, as described previously. 14 From September 2016 until mid-2018, FPL conducted hypersaline extraction and deep well 15 injection testing, which had the benefit of initiating salt removal from the Biscayne aquifer. In 16 2013, FPL had sought and obtained permission from FDEP to permit Deep Injection Well DIW-1 17 as a Class I injection well by converting the existing Class V exploratory well (EW-1), originally 18 installed for the proposed new reactors, Turkey Point Units 6 and 7 (FDEP 2013). FPL used the 19 existing deep injection well (DIW-1) and four, 90-feet (27-m) deep Biscayne aquifer production 20 wells (designated PW-1 through PW-4) constructed by FPL for assessing flow rates for the 21 recovery wells (FPL 2017a, FPL 2018f) (Figure 3-14). By letter dated June 21, 2016, FDEP 22 authorized FPL to carry out the testing program in accordance with underground injection 23 control Permit 293962-002-UC and Permit Modification 293962-003-UC/MM (FDEP 2013, 24 FDEP 2016f, FDEP 2016g). 25 Meanwhile, in May 2017, Miami-Dade County approved FPLs remedial action plan for design 26 and construction of the recovery well system (MDC 2017e). FPL began construction of the full-27 scale hypersaline groundwater recovery well system on June 19, 2017 (FPL 2017a). The 28 recovery well system was completed on May 15, 2018, and it then became operational 29 (FPL 2018h). Operation of the extraction well portion of the system is authorized under a South 30 Florida Water Management District water use permit (Permit No. 13-06251-W), issued to FPL in 31 February 2017 (SFWMD 2017a). 32 In July 2018, FDEP issued underground injection control Permit No. 0293962-004-UO/1I to FPL 33 for operation of deep injection well DIW-1 for disposal of hypersaline groundwater 34 (FDEP 2018d). 35 The installed full-scale hypersaline groundwater recovery well system consists of 10 hypersaline 36 groundwater recovery (extraction) wells (i.e., numbered RW-1 through RW-10), generally 37 located along the western edge of the CCS, and the Class 1 deep injection well (DIW-1) for 38 disposal of the recovered hypersaline groundwater (Figure 3-14). Between September 2016 39 and May 2018, the testing and recovery well systems have extracted and disposed of 40 approximately 8,285 million gallons (31.4 million m3) of hypersaline groundwater, with the 41 removal of 1.92 million tons (1.74 million metric tons) of salt from the Biscayne aquifer 42 (FPL 2018h, 2018i). Section 3.5.2.3, Groundwater Use, provides additional details on the 43 recovery well system. 44 In its environmental report, FPL stated that groundwater modeling of the recovery well system 45 operation indicates that the westward migration of the hypersaline plume will be stopped in 3-70

1 3 years of operation, with retraction of the hypersaline plume north and west of the CCS 2 beginning in 5 years. FPL further projects that system operation will achieve retraction of the 3 plume back to the FPL site boundary within 10 years, as required by the 2016 FDEP Consent 4 Order with FDEP (FPL 2018f). FPL is required to conduct periodic continuous surface 5 electromagnetic mapping surveys to delineate the extent of the hypersaline plume in order to 6 measure the success of recovery and remediation efforts and report the results to FDEP. After 7 5 years of system operation, FPL must provide a report to FDEP that evaluates the 8 effectiveness of the recovery well system in retracting the hypersaline plume to the L-31E Canal 9 within 10 years. If FPLs report shows that the remediation efforts will not retract the 10 hypersaline plume to the L-31E Canal within 10 years, FPL must develop and submit an 11 alternate plan to FDEP for its approval (FDEP 2016e). 12 The Second Objective of the 2016 FDEP Consent Order focuses on the prevention of releases 13 of groundwater from the CCS to surface waters connected to Biscayne Bay. To address these 14 impacts, the 2016 FDEP Consent Order requires FPL to undertake specific environmental 15 restoration projects at Turtle Point and at the Barge Turning Basin, as well as implement a 16 nutrient management plan for the CCS, and to complete and report on the results of an 17 inspection of the periphery of the CCS (FDEP 2016e). For status summaries of these projects, 18 see the discussion in Section 3.5.1.4, Adjacent Surface Water Quality and Cooling Canal 19 System Operation, of this SEIS. 3-71

1 Source: Modified from FPL 2017b 2 Figure 3-14 Layout of Biscayne Aquifer Recovery Well System and Testing Wells 3-72

1 The Third Objective of the 2016 FDEP Consent Order requires mitigation for impacts related to 2 the historic operation of the CCS, including but not limited to the hypersaline plume and its 3 influence on the saltwater interface. Discrete mitigative actions specified in the 2016 FDEP 4 Consent Order require FPL to convey specified tracks of FPL property to the South Florida 5 Water Management District, if so requested, to facilitate the Comprehensive Everglades 6 Restoration Plan; to make financial contributions to the State of Florida to support mitigation for 7 saltwater intrusion; and to conduct water quality sampling in order to improve trend analysis in 8 Biscayne Bay and Card Sound surface waters. Moreover, the 2016 FDEP Consent Order 9 requires FPL to complete an analysis using the variable density, three-dimensional groundwater 10 model developed in accordance with the requirements of the 2015 Consent Agreement to 11 allocate relative contributions of other entities or factors to the movement of the saltwater 12 interface (FDEP 2016e). 13 In June 2018, FPL presented the results of its modeling analysis to FDEP staff. In summary, 14 FPL commissioned Tetra Tech, a consulting and engineering services company, to conduct an 15 attribution sensitivity analysis using its existing variable density flow and salinity transport model 16 (Tetra Tech 2018). Modeling runs were conducted to evaluate eight regional and environmental 17 factors as compared to a base scenario in order to assess the effects of these factors on the 18 location of the saltwater interface. These factors included: (1) operation of the Turkey Point 19 CCS, (2) sea level rise, (3) changes in land use, (4) decadal-scale changes in climate in terms 20 of precipitation recharge, (5) construction of drainage structures and changes to drainage 21 practices, (6) construction and operation of controlled freshwater canals, (7) changes to 22 groundwater use (changes to the operation and capacity of nearby wellfields), and 23 (8) management and operation of mining practices west of the CCS. 24 FPLs modeling analysis indicates that operating the CCS with salinity in excess of 35 PSU is 25 the single largest contributor to changes (movement) in the location of the saltwater interface, 26 as measured by the areal extent of the saltwater interface. Changes were measured based on 27 the average change in the area of salinity greater than 0.05 PSU west of the CCS over the 28 thickness of the Biscayne aquifer. Other than CCS salinity, the modeling indicates that the 29 next-most-influential locational factors are changes in climate, followed by canal operations over 30 time (Tetra Tech 2018). 31 Routine and Potential Inadvertent Releases of Radionuclides and Other Pollutants to 32 Groundwater 33 Nuclear power plants and other industrial facilities can impact groundwater quality by 34 inadvertent releases of chemicals and petroleum products. Nuclear power plants can also 35 impact groundwater quality through inadvertent releases of radionuclides, predominantly tritium, 36 from spills and leaks from plant systems (NRC 2013a). 37 Nuclear power plants routinely release dilute concentrations of radionuclides, including tritium, 38 in effluents (liquid and gaseous wastes) subject to compliance with NRC regulations. These 39 authorized releases are closely monitored by the plant operator and reported to the NRC, with 40 reports made available to the public on the NRCs Web site, in the form of annual radioactive 41 effluent release reports. Similarly, potential impacts to the public and to the environment from 42 plant radiological releases are evaluated and reported by NRC licensees in radiological 43 environmental operating reports, which are also publicly available. Routine radiological 44 effluents from Turkey Point Units 3 and 4, and FPLs associated effluent management and 45 radiological environmental monitoring programs are described in Section 3.1.4.1, Radioactive 3-73

1 Liquid Waste Management, Section 3.1.4.2, Radioactive Gaseous Waste Management, and 2 Section 3.1.4.5, Radiological Environmental Monitoring Program, of this SEIS. 3 Normal operation of Turkey Point Units 3 and 4 results in the release to the CCS of monitored 4 and permitted effluents containing tritium. Evaporation of CCS water results in tritium being 5 released to the atmosphere as a component of the water vapor, while radioactive decay (with a 6 half-life of approximately 12 years) limits the buildup of tritium concentrations over time in the 7 waters of the CCS (NRC 2016a). 8 In 2017, based on the results of FPLs radiological environmental monitoring, the average tritium 9 concentration in the waters of the CCS at site T08 (on the southern shore of the CCS, west of 10 Grand Canal Bridge) was 10,391 pCi/L, with a maximum level of 24,483 pCi/L (FPL 2018k). Of 11 the four supplemental surface water stations in FPLs REMP, the NRC staff assumes that this 12 sampling location may be generally representative of ambient tritium levels in the CCS. For 13 2016, the average tritium concentration at this location was 6,126 pCi/L, with a maximum level 14 of 17,456 pCi/L (FPL 2017d). For comparison, the EPAs primary drinking water standard for 15 tritium is 20,000 pCi/L (40 CFR 141.16). Section 3.5.1.4, Adjacent Surface Water Quality and 16 Cooling Canal System Operation, further describes surface water quality in the CCS. As 17 discussed there and as shown in Figure 3-13, Extent of Tritium in the Deep Interval of the 18 Biscayne Aquifer in the Vicinity of the Turkey Point Site, 2017, tritium concentrations decrease 19 significantly with increasing distance from the site, to levels substantially below the EPAs 20 primary drinking water standard. 21 Because the canals comprising the CCS are not lined, CCS water, which contains tritium, 22 migrates into the groundwater of the underlying Biscayne aquifer (FPL 2018f, NRC 2016a). 23 Within the highly permeable aquifer, diffusion is rapid and groundwater flow is relatively fast 24 (FPL 2016h). Thus, tritium occurs in underlying groundwater in the Biscayne aquifer beneath 25 the CCS as well as in adjacent areas of the aquifer that are beneath the Turkey Point, Units 3 26 and 4 plant complex. 27 An additional consideration for the presence and transport of tritium is that engineered backfill 28 (crushed, compacted limestone) was used around the Turkey Point plant complex (nuclear 29 island) with some structures extending to a depth of 45 feet (14 m) below land surface. On a 30 more localized basis, subsurface structures may alter or impede the direction of groundwater 31 flow (FPL 2016h). Further, it is likely that subsurface structures and the engineered backfill 32 itself offer a preferential flow path for water containing tritium to reach the Biscayne aquifer 33 beneath portions of the Turkey Point plant complex. Any inadvertent releases of liquids 34 containing radioactive constituents from plant facilities and systems, spills, or leaks can also 35 migrate to underlying groundwater. 36 Potentiometric surface (water table elevation) maps developed for the Turkey Point site and 37 reviewed by the NRC staff show that groundwater flow across the main plant complex is tidally 38 influenced in the shallow, intermediate, and deep monitored portions of the Biscayne aquifer. 39 FPL states in its Updated Final Safety Analysis Report, Turkey Point Units 3 & 4, that there is 40 a rather consistent tidal influence on groundwater elevations across the Turkey Point site of 0.2 41 to 0.5 ft (0.06 to 0.15 m) maximum tidal fluctuation (FPL 2016h). Groundwater flow paths are 42 further influenced by plant operations where operation of the circulating water system and 43 associated intake and discharge canals generally produces radial flow across the plant site at 44 shallow and intermediate depths during most tidal regimes. This appears to generally occur due 45 to groundwater mounding on the discharge canal (west) side of the plant complex and a 46 depressed water table surface on the intake (east side) of the plant. In contrast, during both low 3-74

1 and high tides, groundwater flow in the deep portion of the Biscayne aquifer is more 2 unidirectional, from south to north and from east to west (FPL 2018f). 3 FPL participates in the NEI 07-07, Industry Ground Water Protection Initiative (NEI 2007). The 4 initiative identifies actions to improve management and response to instances in which the 5 inadvertent (i.e., unplanned, uncontrolled, and unmonitored) release of radioactive substances 6 may result in low but detectible levels of nuclear power plant-related radioactive materials in 7 subsurface soils and water. The initiative identifies those actions necessary for the 8 implementation of a timely and effective groundwater protection program along with acceptance 9 criteria to demonstrate that the objectives have been met. 10 Since 2010, FPL has maintained a radiological environmental sampling and analysis program 11 for Turkey Point that meets the recommendations of NEI 07-07. FPL performs groundwater 12 monitoring at 28 onsite locations around Turkey Point Units 3 and 4 for potential inadvertent 13 radioactive releases through groundwater pathways at the Turkey Point site in accordance with 14 site procedures. FPL collects samples on at least a quarterly basis or more frequently if 15 deemed necessary (FPL 2018f). Some of the groundwater monitoring locations have multiple 16 (two or three) depths. 17 FPL states in its environmental report that it has detected tritium (a beta-emitting radioactive 18 isotope of hydrogen) in groundwater. Since establishing its NEI 07-07 program, FPL has 19 detected no Turkey Point-related gamma-emitting isotopes (FPL 2018f). 20 The NRC staff reviewed FPLs annual effluent release and radiological environmental operating 21 reports for a 4-year period (2014 through 2017). The NRC staff found that FPL has 22 documented seven actual or potential inadvertent releases to groundwater from Turkey Point, 23 Units 3 and 4 operations. FPL completed appropriate corrective actions and entered the events 24 and actions taken in the plant corrective action program, as appropriate. The list below 25 summarizes these unplanned liquid releases: 26

• March 19, 2014, the Turkey Point Unit 3E demineralizer fill valve leaked a small amount 27 of reactor coolant system (RCS) water (i.e., about 1 gallon (3.8 L)) on the roof of the 28 auxiliary building, which was promptly cleaned up.

29

• August 24, 2014, the Turkey Point Unit 4 refueling water storage tank purification pump 30 (4P209) drain line leaked 5 gallons (19 L) of reactor coolant system water to the ground.

31 Corrective actions included increasing sampling of Turkey Point monitoring wells (i.e., 32 PTN-MW-8S, PTN-MW-9S, and P-94-4) for gamma and tritium activity. 33

• September 23, 2014, the Unit 4 demineralizer resin fill valve and flange located on the 34 roof of Turkey Point Unit 4 auxiliary building leaked about 50 gallons (190 L) of reactor 35 coolant system water. Rainfall caused the leak to migrate to the storm drain system.

36 Contamination included 0.132 Ci of cobalt-58 and 0.019 Ci of tritium. Corrective actions 37 included monitoring the southeast storm drain as well as nearby monitoring wells (i.e., 38 PTN-MW-8S and PTN-MW-9S). 39

• October 14, 2014, the Turkey Point Unit 4 refueling water storage tank valve 4-804 B 40 leaked during the transfer of water from the refueling cavity. Approximately 1 L of 41 reactor coolant system water was released to the ground before the leak was stopped.

42 Corrective actions included monitoring nearby wells (i.e., PTN-MW-8S, PTN-MW-9S, 43 and P-94-4) monthly for gamma activity and tritium. 3-75

1

• November 11, 2014, a pump casing leak occurred from the 4P209 Unit 4 refueling water 2 storage tank purification pump. The total leak volume was not estimated but the pump 3 leak was estimated to be approximately 60 drops per minute until the pump was shut 4 down upon discovery of the leak. Corrective actions included increasing sampling of 5 wells in the vicinity (i.e., PTN-MW-8S, PTN-MW-9S, and P-94-4) to monthly for gamma 6 activity and tritium.

7

• July 26-September 15, 2015, a leak of intake cooling water contaminated with sodium-8 24 from the Turkey Point Unit 3 component cooling water (CCW) system occurred.

9 Chemical inhibitors that contain sodium become activated when the CCW travels into a 10 neutron field. The Turkey Point Unit 3 CCW heat exchanger, cooled by intake cooling 11 water, developed a leak, and CCW, which contained activated sodium, leaked into the 12 tube side of the heat exchanger. The release continued until the heat exchanger was 13 plugged. The intake cooling water discharges into the mixing basin on the western side 14 of plant, which is the same area used as discharge for the regular liquid radwaste tanks. 15 The total release volume was approximately 4,828 gal (18,280 L). The total estimated 16 quantity of sodium-24 released was 6.19 micro-Curies. 17

• October 5, 2017, the Unit 4D demineralizer resin fill valve and flange located on the roof 18 of the Unit 4 auxiliary building showed signs of leakage to the roof. The southeast storm 19 drain (in the likely flow path) was sampled and showed activity. The calculated dose 20 from the estimated activity released was determined to be well below site Offsite Dose 21 Calculation Manual limits.

22

• January 22, 2018, a spill occurred on the roof of the auxiliary building when radiation 23 workers removed the protective cover on the Unit 4D demineralizer resin fill isolation 24 valve. The spill volume was about 0.5 gal (1.9 L) and reached the storm drain system 25 after initial response efforts were ineffective. Corrective actions included a complete 26 replacement of the demineralizer rubber diaphragm valve with a new ball valve with 27 stainless steel internals in order to eliminate valve leakage. The frequency of sampling 28 of the surrounding monitoring wells (e.g., PTN-MW-8S) was increased to weekly, and no 29 significant impact to groundwater was observed following the release (FPL 2013a, 30 2015a, 2015b, 2016i, 2016j, 2017d, 2017e, 2018j, 2018h, 2018k).

31 Table 3-5 summarizes the latest available radiological groundwater monitoring results that FPL 32 has reported to the NRC for representative well locations, with the results compared to historical 33 maximum observed concentrations. Monitoring well locations are depicted in Figure 3-15 34 below. 35 Table 3-5 Representative Groundwater and Storm Drain Monitoring Results for Tritium, 36 Turkey Point Groundwater Protection Program, 2017 (in PicoCuries per Liter) Previous 4-Year First Second Third Fourth Maximum Concentration Well Number Quarter(a,b) Quarter(a,b) Quarter(a,b) Quarter(a,b) (Year-Quarter) P-94-4 947 910 633 845 3,060 (2015-Q3) PTN-MW-1S <MDC NA <MDC <MDC 80.5 (2014-Q3) PTN-MW-1I 565 NA 345 NA 700 (2016-Q1) PTN-MW-1D 1,940 NA 1,790 NA 2,310 (2015-Q3) PTN-MW-4S <MDC <MDC <MDC <MDC 1,930 (2014-Q2) PTN-MW-4I 2,840 2,780 2,900 2,490 3,570 (2016-Q1) 3-76

Previous 4-Year First Second Third Fourth Maximum Concentration Well Number Quarter(a,b) Quarter(a,b) Quarter(a,b) Quarter(a,b) (Year-Quarter) PTN-MW-4D 3,650 <MDC <MDC <MDC 3,840 (2015-Q4) PTN-MW-7S 915 1,220 1,180 867 1,070 (2015-Q4) PTN-MW-7I 1,030 1,330 1,750 1,430 2,400 (2015-Q3) PTN-MW-7D 1,160 <MDC <MDC <MDC 2,370 (2014-Q1) PTN-MW-8S 2,010 1,040 873 13,600 6,670 (2014-Q1) PTN-MW-9S 334 853 702 798 773 (2015-Q4) Northeast Storm <MDC <MDC 455 9,990 1,140 (2016-Q3) Drain PTN-MW-11S <MDC 709 623 425 804 (2014-Q3 PTN-MW-12S 855 723 1,080 963 1,140 (2016-Q1) Southeast Storm <MDC <MDC 1,570 13,000 10,600 (2016-Q3) Drain West Storm Drain 4,730 825 4,490 12,000 11,240 (2015-Q4) CRF Storm Drain No result <MDC <MDC 545 <MDC Notes: CRF=central receiving facility; MDC=minimum detectable concentration, value is less than the analytical MDC or less than 300 pCi/L tritium; NA=not applicable, as sampling not conducted or required for sampling period. S, I, and D refer to approximate monitored depth below land surface: Shallow 20 feet (6 m), Intermediate 40 feet (12 m), and Deep 60 feet (18 m). (a) FPL reports all results in picoCuries per liter (pCi/L). (b) FPL generally collects quarterly samples in January, April, July, and October. Source: FPL 2015b, FPL 2016j, FPL 2017d, FPL 2018k. 3-77

1 Source: Modified from FPL 2018k (Note: Cross-Sections Omitted) 2 Figure 3-15 Turkey Point Groundwater Protection Initiative Monitoring Well Locations 3-78

1 Based on these results, the NRC staff finds no apparent increasing trend in tritium concentration 2 or a pattern indicating either a new inadvertent release or persistently high tritium 3 concentrations that might indicate an ongoing inadvertent release from Turkey Point facilities to 4 groundwater. In 2017, the highest observed level in Turkey Point groundwater was 5 13,600 pCi/L at well PTN-MW-8S. This location is near the Turkey Point Unit 3 refueling water 6 storage tank, shown in Figure 3-15. Elevated tritium levels were also detected in storm drain 7 locations, which likely represents tritium concentrations in the CCS during periods when storm 8 drain outfalls are occasionally below the tidal mark in the canal system (FPL 2018k). 9 Nevertheless, all results are less than the limits prescribed by FPLs Offsite Dose Calculation 10 Manual (FPL 2013a) for the plant, which for tritium is 30,000 pCi/L, as groundwater at the site is 11 not designated for potable use. 12 At the time of the NRCs onsite environmental audit in 2018 for the subsequent license renewal, 13 FPL was preparing a site conceptual model as part of an effort to identify and characterize 14 groundwater flow and the occurrence and migration of tritium at the FPL property, including 15 locations such as: Turkey Point Units 1, 2, and 5, the diesel storage tank area, and portions of 16 the intake and discharge canals. Other objectives of this effort include evaluation of potential 17 human, ecological, or environmental receptors of tritium that might have been released to the 18 groundwater and development of recommendations for additional investigations and long-term 19 monitoring (FPL 2018h). 20 With respect to unplanned, non-radiological releases, FPL reported no accidental spills or 21 similar releases of nonradioactive substances, including petroleum products, at Turkey Point 22 over the past 5 years, nor any associated notices of violation issued to FPL for such releases 23 (FPL 2018f, FPL 2018h). The NRC staffs review of available information and regulatory 24 databases found no documented instances of accidental spills of chemical or petroleum 25 products to groundwater that resulted in a regulatory action over the last 5 years. 26 3.5.2.3 Groundwater Use 27 Section 2.2.2 of NUREG-1437, Supplement 5 describes water use and sanitary wastewater 28 management for Turkey Point operations (NRC 2002c). As indicated in that section, water for 29 Turkey Point process makeup (e.g., primarily demineralizer water makeup), potable water, and 30 fire protection water uses was obtained from the Miami-Dade Water and Sewer Department 31 (MDWSD). Sanitary wastewater was being processed in an onsite treatment plant and 32 discharged to groundwater (Biscayne aquifer) through an onsite injection well (i.e., IW-1). That 33 section further states that no surface water or groundwater was being withdrawn for use as 34 makeup water for the CCS at that time. The NRC staff incorporates the information in NUREG-35 1437, Supplement 5, Section 2.2.2 (NRC 2002c: 2-5, 2-17, 2-18), here by reference. The 36 following discussion presents new information regarding groundwater use for Turkey Point 37 operations, beyond the information in NUREG-1437, Supplement 5. 38 In southeast Florida and in Miami-Dade County where Turkey Point is located, groundwater 39 aquifers are used both as a water supply and as a reservoir for wastewater disposal via deep 40 well injection. Nearly all of the potable water supplied by the MDWSD to southern Miami-Dade 41 County comes from the Biscayne aquifer (MDC 2018b, NRC 2016a) (Section 3.5.2.2). The 42 exception is water from the Countys Alexander Orr, Jr. water treatment plant, which mixes 43 some brackish groundwater from the Upper Floridan aquifer with Biscayne aquifer groundwater 44 (NRC 2016a). 3-79

1 In 2015, groundwater withdrawals in Miami-Dade County totaled 409.2 mgd 2 (1.55 million m3/day) from freshwater sources and 40.5 mgd (153,300 m3/day) from saline 3 sources. Withdrawals for public water supply comprised the largest use including 338.9 mgd 4 (1.28 million m3/day) from freshwater sources and 13.0 mgd (49,200 m3/day) from saline 5 sources. Withdrawals for power generation included 1.28 mgd (4,850 m3/day) from freshwater 6 sources and 27.5 mgd (104,000 m3/day) from saline sources (USGS 2018a). 7 The MDWSD continues to supply potable water to Turkey Point for drinking and fire protection 8 water uses. Sanitary wastewater disposal continues to be accomplished through an FDEP 9 permitted injection well, as well as by septic tanks (FPL 2018f). 10 FPL completed installation of a replacement water treatment plant in 2017, which is designed to 11 supply pure/ultrapure (demineralized) water for Turkey Point uses. The new system can treat 12 either municipally supplied water (i.e., from the MDWSD) or groundwater from the Upper 13 Floridan aquifer. The use of groundwater is intended to reduce FPLs use of MDWSD water by 14 1 mgd (3,800 m3/day) and associated costs. Wastewater from the new treatment plant is 15 discharged to the CCS (FPL 2018f). Section 3.10.4.3, Public Water Supply, of this SEIS 16 describes the MDWSD public water supply system, and Section 3.1.5, Nonradioactive Waste 17 Management Systems, describes nonradioactive waste management systems that support 18 Turkey Point Units 3 and 4 operations. 19 Currently, FPL uses onsite groundwater withdrawn from the Biscayne and Upper Floridan 20 aquifers for a variety of applications in support of Turkey Point operations, as well as for other 21 activities conducted on the Turkey Point site unrelated to Turkey Point. These principal uses 22 include withdrawals from the Upper Floridan aquifer for freshening of the CCS, operation of a 23 recovery well system and associated underground injection well to extract and dispose of 24 hypersaline groundwater from the Biscayne aquifer, operation of Biscayne aquifer marine wells 25 to supplement CCS freshening, and operation of Upper Floridan Aquifer saline production wells 26 for various onsite uses. 27 Table 3-6 summarizes FPLs reported groundwater withdrawals associated with these well 28 systems for the period from January 2015 through June 2018. In 2017, FPLs groundwater 29 withdrawals from the Biscayne aquifer totaled about 8,928.8 mgy (33.8 million m3/year), or 30 approximately 24.5 mgd (92,700 m3/day). For the Upper Floridan aquifer, withdrawals totaled 31 7,137.2 mgy (27.0 million m3/year), or approximately 19.6 mgd (74,200 m3/day). 32 The nature of these withdrawals and the applicable regulatory requirements governing them are 33 further described below. 3-80

1 Table 3-6 Groundwater Withdrawals at the Turkey Point Site Withdrawals (mgy) Year UFA Saline Well Biscayne Aquifer UFA Freshening Biscayne Aquifer System (PW-1, Marine Well Well System (F-1, F- Recovery Well System PW-3, PW-4) System (PW-1, 3, F-4, F-5, F-6) (RW-1-RW-10) SW-1, and SW-2) 2015 3,339.6 6,065 0.0 0.0 2016 2,237.2 0.0 1,051.6 879.8(a) 2017 2,361.9 4,031.7 4,775.3 4,951.1(a) 2018(b) 1,329.4(b) 0.0 2,106.4(b) 1,994.2(c) Key: mgy=million gallons per year; mgd=million gallons per day; UFA=Upper Floridan aquifer. Note: Some reported values have been rounded. To convert million gallons per year (mgy) to million cubic meters (m3), divide by 264.2. To convert million gallons per day (mgd) to cubic feet per second, multiply by 1.547; for m3, multiply by 3785.4. (a) Withdrawals associated with hypersaline extraction and deep well injection program, using test extraction wells PW-1 through PW-4. (b) Partial-year withdrawal data for the period from January through June 2018. (c) Withdrawals associated with hypersaline extraction and deep well injection program, using test extraction wells PW-1 through PW-4, with the addition of recovery well system wells RW-1 through RW-10, which began operations in May 2018. Source: Compiled from FPL 2018h, FPL 2018l. 2 Turkey Point Site Water Supply Systems 3 Water for cooling and process makeup water for Turkey Point Unit 5 is obtained from Upper 4 Floridan aquifer saline production wells (i.e., wells PW-1, PW-3, and PW-4), as depicted in 5 Figure 3-16. These wells were commissioned in February 2007 (FPL 2018f). The wells are 6 authorized under FPLs modified site certification and associated conditions of certification for 7 the Turkey Point site. The wells range in depth from 1,242 to 1,247 feet (378.6 to 380.1 m), 8 each with a pump capacity of 5,000 gpm (18,900 L/min) (State of Florida Siting Board 2016, 9 FDEP 2016b). The 2016 Conditions of Certification specifically authorizes the withdrawal of 10 14.06 mgd (53,200 m3/day) of groundwater from the upper production zones of the Upper 11 Floridan aquifer for cooling water for Unit 5 and process water for Units 1, 2, 3, 4, and 5 12 (FDEP 2016b). In March 2018, FPL began using approximately 1.1 mgd (4,200 m3/day) of 13 groundwater from the Upper Floridan aquifer saline wells as makeup water to the pure/ultrapure 14 (demineralized) makeup water treatment system for Turkey Point Units 3 and 4 primary and 15 secondary system uses. This usage replaces approximately 0.65 mgd (2,500 m3/day) of 16 potable water that had been supplied by the MDWSD from the Newton Wellfield (FPL 2018h). 17 FPL completed installation of three marine wells in the 2015 timeframe (i.e., wells PW-1 (test), 18 SW-1, SW-2) to provide water for salinity reduction in the CCS (i.e., CCS freshening) 19 (FPL 2018f, FPL 2018m). These wells are located on the Turkey Point peninsula and withdraw 20 from the upper portion of the Biscayne aquifer (Figure 3-16). Consequently, the marine wells 21 withdraw saltwater (Golder Associates 2016). Before being converted to a production well in 22 late 2014 and early 2015, PW-1 was originally installed in 2009 as a 30-inch (76-cm) diameter 23 test well for evaluation of a radial collector well system for proposed new reactors, Turkey Point 24 Units 6 and 7 (FPL 2018m). Well PW-1 has a total depth of 46 feet (14 m), with an open 3-81

1 borehole from 22 to 46 feet (6.7 to 14.0 m) below the casing (HDR Engineering 2009). It is 2 equipped with a 7,000-gpm (26,500-L/min) pump (FPL 2018m). Marine wells SW-1 and SW-2 3 are 36-inches (91-cm) in diameter. The two wells are completed to total depths of 56 4 and 55 feet (17.1 and 16.8 m), respectively, with the lower 30 feet (9.1 m) of each well 5 terminating in an open borehole. Each of these wells has a 12,500-gpm (47,300 L/min) rated 6 capacity pump (FPL 2018m). Together, the three wells have a combined production capacity of 7 approximately 45 mgd (170,300 m3/day) (FPL 2018f). Notwithstanding this nominal production 8 capacity, the total water volume that can be withdrawn and conveyed to the intake canal area is 9 limited by considerations associated with measurement of the ultimate heat sink temperature 10 and compliance with the technical specifications in the Turkey Point, Units 3 and 4 operating 11 licenses. Specifically, the total flow must be less than or equal to 23,400 gpm (88,600 L/min) 12 when only one Turkey Point unit is operating and 41,600 gpm (157,500 L/min) when both Units 13 3 and 4 are operating (FPL 2018m). 14 Operation of the marine wells does not require a groundwater consumptive use permit from the 15 South Florida Water Management District because saltwater is not regulated by the State 16 (FPL 2018f). In general, users of seawater, or reclaimed water, are not required to obtain water 17 use permits (SFWMD 2015). The water withdrawn from the marine wells has an average 18 salinity of around 36 PSU (FPL 2017b). Historically, the salinity of marine well water has ranged 19 from about 34 PSU to nearly 40 PSU with chloride concentrations ranging from approximately 20 20,000 to 23,000 mg/L (FPL 2016f). FPL has used the wells during periods of peak CCS 21 salinity to moderate salinity rise (FPL 2018f). As stipulated under the 2015 Consent Agreement 22 (MDC 2015a) between FPL and Miami-Dade County, the marine wells may only be used to 23 lower salinity in the CCS under extraordinary circumstances. As a result, FPL reports that the 24 wells are used in response to extraordinary circumstances or upset recovery to support 25 regulatory requirements (FPL 2018f, FPL 2018m). 26 In 2016, FPL installed five additional production wells (i.e., wells F-1, F-3, F-4, F-5, and F-6) to 27 provide water from the Upper Floridan aquifer for use in the CCS (Figure 3-16). As previously 28 described, the freshening wells are authorized under FPLs modified site certification and 29 associated conditions of certification for the Turkey Point site, which permit a total withdrawal of 30 14 mgd (53,000 m3/day) for salinity reduction (State of Florida Siting Board 2016, FDEP 2016b). 31 The wells are artesian in nature (i.e., require no pumping) and flow is conveyed directly into the 32 CCS. The 20-inch (51-cm) diameter wells range in depth from 1,000 to 1,250 feet (304.8 to 381 33 m) (FDEP 2016b, FPL 2018f). Each well is equipped with a 2,500-gpm (9,460 L/min) capacity 34 pump (FDEP 2016b). 35 As described in Section 3.5.2.2, Groundwater Quality, in May 2018, FPL completed and began 36 operation of a recovery well system to meet the groundwater remediation objectives specified in 37 the 2015 Consent Agreement (MDC 2015a) with Miami-Dade County and the 2016 Consent 38 Order with the Florida Department of Environmental Protection (FDEP 2016e). The system 39 consists of 10 hypersaline groundwater recovery (extraction) wells (designated RW-1 through 40 RW-10) completed in the Biscayne aquifer and one deep injection well (DIW-1) for disposal of 41 hypersaline groundwater (Figure 3-14). These wells replaced the four demonstration wells 42 (designated PW-1 through PW-4) that FPL used for hypersaline groundwater recovery testing 43 from September 2016 through April 2018. 44 The 24-inch (61-cm) recovery wells are each drilled to a total depth of 110 feet (33.5 m) and are 45 cased to a depth of 70 feet (21 m) below land surface. Each recovery well is equipped with a 46 1,042-gpm (3,900-L/min) electric pump, giving the well system a combined extraction capacity 47 of 15 mgd (56,700 m3/day) (SFWMD 2017a). Each extraction well pump discharge is fitted with 3-82

1 backflow prevention, a magnetic flow meter, a pressure transducer, a pump discharge pressure 2 transmitter, sample tap, and an air release valve. Each well is also equipped with a water 3 quality monitoring station. The wells are operated with programmable logic controllers and 4 variable frequency driven well motor pump sets, and they are controlled and continuously 5 monitored by remote secure radio communication telemetry to a main control building located 6 near the deep injection well. The wells are connected in parallel by 14-inch (36-cm) diameter 7 piping which runs to a 28-inch (71-cm) header that conveys the extracted hypersaline 8 groundwater to deep injection well DIW-1. A total of about 9.5 mi (15 km) of pressure-rated 9 piping is used in the conveyance system (FPL 2018h). Recovery well operations are permitted 10 under a South Florida Water Management District-issued individual water use permit 11 (Permit No. 13-06251-W) (FPL 2018f, SFWMD 2017a). The permit specifies a maximum 12 monthly withdrawal allocation of 465 million gallons (1.76 million m3) (SFWMD 2017a). 13 The deep injection well DIW-1 discharges extracted hypersaline water to the Boulder Zone at a 14 depth of approximately 3,200 feet (975 m). DIW-1 is constructed of concentric piping (casing 15 strings) ranging from 64-inch (163-cm) diameter steel casing in the upper interval to 33 feet 16 (10 m) below land surface, 24-inch (61-cm) diameter steel casing to 2,985 feet (910 m) below 17 land surface, and followed by an 18-inch (46-cm) diameter liner to a depth of 18 2,975 feet (907 m) below land surface. The liner tubing is fiberglass reinforced pipe with a fluid 19 filled annulus. The total depth of the well borehole is 3,230 feet (984.5 m) below land surface 20 (FDEP 2013). 21 The deep injection well DIW-1 is paired with a dual-zone monitoring well (DZMW-1), which is 22 completed in the Floridan aquifer with upper and lower monitoring zones at 1,450 to 1,490 ft 23 (442 to 454 m) below land surface and 1,860 to 1,905 feet (567 to 581 m) below land surface 24 (FDEP 2013). Operation of DIW-1 is authorized under FDEP Permit No. 293962-002-UC 25 (FPL 2013, FDEP 2018d). The maximum permitted injection rate for DIW-1 is 10,826 gpm 26 (41,000 L/min), or 15.59 mgd (59,000 m3/day), and the well is required to be periodically tested 27 for injectate confinement (FDEP 2013). 28 The Boulder Zone is located in the Lower Floridan aquifer and is overlain by a confining layer 29 that retards upward migration of wastewater (FPL 2018f). The FDEP permits FPL and others to 30 discharge treated sewage and other wastes through injection wells into the Boulder Zone. All 31 Boulder Zone underground injection wells must be permitted and monitored by the FDEP 32 underground injection control program. As an example, the Miami-Dade Water and Sewer 33 Departments South District Wastewater Treatment Plant located approximately 9 mi (14 km) 34 north of the Turkey Point site disposes of municipal wastewater through as many as 13 deep 35 injection wells into the Boulder Zone (NRC 2016a). 36 Other Water Supply Wells 37 While the Biscayne aquifer is the principal source of potable water supplied by the Miami-Dade 38 Water and Sewer Department, the Biscayne aquifer is not a source of potable water in the 39 vicinity of the Turkey Point site, as discussed in Section 3.5.2.2, Groundwater Quality. Other 40 than FPL-owned water wells, described above, there are no potable water wells (drawing from 41 either the Biscayne or Floridan aquifer systems) within the Turkey Point site boundary. 42 There are no registered groundwater supply wells within a 2-m (3.2-km) band of the Turkey 43 Point site boundary (FPL 2018f). Relative to the Turkey Point site, the nearest mapped water 44 supply wells are located about 5 mi (8 km) west of the western boundary of the CCS and are 45 used to support mining operations (FDOH 2018a). 3-83

1 As for public water supply sources, the nearest wells are located about 6 mi (10 km) from the 2 northwest corner of the CCS and approximately 7 mi (11 km) from the center of the Turkey 3 Point plant complex. These wells are located at Newton Field (i.e., the Newton Wellfield) and 4 are operated by Miami-Dade County (see Figure 3-12) (FDOH 2018a, MDC 2006, MDC 2018c, 5 NRC 2016a). 6 Potable water supply for the Florida Keys comes from Biscayne aquifer wells and an Upper 7 Floridan aquifer well located west of Florida City at the Florida Keys Aqueduct Authoritys 8 J. Robert Dean Water Treatment Plant. These facilities are located approximately 9.5 mi 9 (15 km) west, northwest of the western boundary of the CCS (FDOH 2018a, MDC 2006, 10 MDC 2018c, NRC 2016a). 3-84

1 Source: Modified from FPL 2017b 2 Figure 3-16 Location of Groundwater Production Wells on the Turkey Point Site 3-85

1 3.6 Terrestrial Resources 2 This section describes the terrestrial resources of the affected environment, including the 3 surrounding ecoregion. The terrestrial resources include plant and animal species, vegetative 4 communities, and important habitats present on or in the vicinity of the Turkey Point site. This 5 section also describes important species and habitats that potentially may be present on or near 6 the Turkey Point site. Plants and animals federally listed as endangered or threatened are 7 discussed in Section 3.8, Special Status Species and Habitats. 8 3.6.1 Vegetative Communities 9 The Turkey Point site is located on the western edge of Biscayne Bay and lies within the 10 Mangrove and Coastal Glades physiographic province (McPherson and Halley 1996). This area 11 includes a broad band of wetlands at or near sea level that is often flooded by tides or 12 freshwater runoff. The ecology at and near Turkey Point is directly tied to the hydrology and 13 natural seasonal hydrologic fluctuations that occur in this region. The NRC staffs EIS for the 14 Turkey Point Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a), Section 2.4.1.1 15 and Tables 2-2 and 2-3 describe the physiographic province, the general ecology of the Turkey 16 Point site, and the land cover of various habitats within the vicinity of Turkey Point. 17 Section 2.4.1.1 of NUREG-2176 (NRC 2016a) also summarizes the results of vegetative 18 surveys of the Turkey Point site through 2011. The NRC staff incorporates the above 19 information from NUREG-2176, Section 2.4.1.1 and Tables 2-2 and 2-3 into this SEIS by 20 reference (NRC 2016a: 2-76 to 2-77; Tables 2-2 and 2-3). 21 FPL developed a vegetative survey monitoring plan as a condition of its site certification from 22 the State of Florida (FPL 2018g). This vegetative monitoring plan includes surveys of 32 plots 23 of freshwater marsh and mangrove habitat adjacent to the CCS. FPL initially surveyed these 32 24 plots in October 2010 prior to the power uprate; FPL continues to survey each of the 32 plots 25 approximately four times each year in February, May, August, and October (FPL 2012a, 26 FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a). During the survey, FPL measures the 27 percent cover, species diversity, plant height, and biomass of each plot as well as other factors 28 that may indicate changes in the health of the vegetation and habitat. FPL selected one plot 29 and transect (T6) to serve as a reference plot. The reference plot is located in an area further 30 from the CCS that would not be as susceptible to potential impacts from the CCS. For 31 additional details regarding FPLs vegetative survey methodology, see FPLs report 32 (FPL 2012a), Turkey Point Plant Comprehensive Pre-Uprate Monitoring Report, Units 3 & 4 33 Uprate Project. 34 The most common freshwater wetlands near the CCS are sawgrass (Cladium jamaicense) 35 marshes. Sawgrass marshes are flooded for the majority of the year, and the relative 36 abundance of sawgrass compared to other species tends to be positively correlated with both 37 the length of the hydroperiod (or time in which the area is flooded) as well as the depth of the 38 water during the hydroperiod (UF undated, Foti et al. 2012). Vegetative species diversity is 39 generally low within sawgrass marshes for a few reasons: (1) sawgrass plants can grow so 40 densely that few other species can establish in the limited space, and (2) sawgrass marshes 41 thrive in harsh physiological conditions, including flooding and deep water, that few plants can 42 tolerate (Brown et al. 2006). After sawgrass, the next most common plant species in the 43 freshwater wetlands near the CCS is the spikerush (Eleocharis cellulose). Species diversity 44 generally ranges from one to three plant species per plot (FPL 2012a, FPL 2014b, FPL 2016a, 45 FPL 2016b, FPL 2017a), which is typical for southern Everglades sawgrass marshes 46 (Childers et. al. 2006, Foti et al. 2012). Sawgrass cover has remained between 2 to 25 percent 3-86

1 since FPL began sampling in 2011 (FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, 2 FPL 2017a). 3 Using FPLs data from 2011 through 2017, the NRC staff plotted the height of sawgrass plants 4 and live biomass within the five freshwater marsh transects (see Figure 3-17 and Figure 3-18). 5 Sawgrass height tended to be highest during fall and winter, and slightly shorter in spring and 6 summer. Average sawgrass height decreased from October 2010 through February 2012 and 7 has fluctuated ever since without showing a consistent upward or downward trend. Live 8 biomass has also fluctuated over the past several years, also without showing a consistent 9 upward or downward trend. Most recently, live biomass decreased in August and 10 November 2016 and then increased by February 2017 and remained at a similar or higher level 11 in May 2017. The seasonal and annual changes in sawgrass height and live biomass were 12 generally similar between the reference transect (T6) chosen for being farther from the CCS, 13 and the transects closer to the CCS (T1-4). The survey shows that wetlands at different 14 distances from the CCS exhibit similar growth trends. These patterns suggest that landscape-15 scale environmental factors, such as the length of the hydroperiod or overall water depth, have 16 a greater effect on changes in live biomass and sawgrass height than proximity to the CCS. In 17 addition, the fluctuations in sawgrass height and live biomass over time suggest that there is a 18 high degree of natural variability influenced by multiple environmental parameters. 19 Sources: FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a 20 Figure 3-17 Average Height of Sawgrass Blades Within Freshwater Marsh Transects 21 from October 2011 through February 2017 3-87

1 Sources: FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a 2 Figure 3-18 Live Sawgrass Biomass Within Freshwater Marsh Transects from 3 October 2011 through February 2017 4 In scrub mangrove plots at Turkey Point, red mangrove (Rhizophora mangle) is the most 5 common species. Red mangrove forests tend to have low vegetative species diversity due to 6 the dominance of red mangrove and because few species have adapted to grow in saline 7 waters, which is physiologically demanding. Similar to biomass trends within freshwater 8 marshes, biomass within most Turkey Point mangrove plots and transects have fluctuated over 9 the past several years, showing no consistent upward or downward trend. However, biomass 10 within two of the mangrove plots (M1-2 and M3-2) has been steadily decreasing since 11 October 2011 (see Figure 3-19). In its 2017 annual Turkey Point monitoring report, FPL 12 (FPL 2017a) noted that although biomass has decreased in mangrove plots M1-2 and M3-2, 13 percent cover and height have remained relatively consistent in these plots. FPL also stated its 14 intention to closely monitor these two decreasing mangrove plots in the future. 3-88

1 Sources: FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a 2 Figure 3-19 Live Biomass Within Two Red Mangrove Plots (M1-2 and M3-2) from 3 October 2011 through February 2017 4 In 2017, the Southwest Florida Water Management District (SWFMD) issued Permit 5 No. 13-06251-W allowing FPL to recover and extract the hypersaline water within and around 6 the CCS (SFWMD 2017a). This water extraction, called dewatering, has the potential to impact 7 wetland growth because it removes water from an ecosystem where greater water depth and 8 longer hydroperiods are directly and positively related to vegetative growth and species 9 composition (UF undated, Foti et al. 2012). As part of its permit process, the SWFMD modeled 10 drought conditions (up to a 1-in-10-year drought) and determined that a maximum drawdown of 11 less than 0.3 feet (9.1 cm) of water could occur west and north of the CCS under drought 12 conditions during operation of the wells (SWFMD 2017a). This maximum drawdown limit also 13 applies to onsite as well as offsite wetlands that are west of the CCS. The L-31E Canal would 14 provide some buffering of the drawdown area due to canal water storage. In conclusion, the 15 SWFMD determined that while the authorized withdrawal would impact wetlands, the impacts to 16 onsite and offsite wetlands would be minimal (SWFMD 2017a). 17 3.6.2 Wildlife 18 Southern Florida lies at the southern tip of a temperate landmass, and its subtropical climate 19 supports a wide variety of ecosystems and wildlife, including approximately 350 bird, 50 reptile, 20 40 mammal, and 15 amphibian species (NPS 2015b). Several tropical species inhabit Floridas 21 mangroves and warm waters, while temperate species migrate south from other areas in the 22 United States. Furthermore, productive wetlands provide a source of refuge and foraging 23 grounds for numerous wildlife and bird species. Section 2.4.1.1 of the NRC staffs EIS for the 24 Turkey Point Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a) describes wildlife 25 and avian studies conducted at and near Turkey Point in 1972 and from 2005 through 2009. 26 The NRC staff incorporates the above information into this SEIS by reference (NRC 2016a: 27 pages 2-79 to 2-80). 28 On May 23, 2016, FPL conducted bird and reptile surveys within the vicinity of the Turtle Point 29 remnant canal and Barge-Turning Basin water quality improvement projects. FPL observed one 3-89

1 reptile species, the American crocodile (Crocodylus acutus), and 6 bird species: common 2 nighthawk (Chordeiles minor), brown pelican (Pelecanus occidentalis), double-crested 3 cormorant (Phalacrocorax auritus), anhinga (Anhinga anhinga), mockingbird (Mimus polyglottis), 4 and rusty blackbird (Euphagus carolinus) (FPL 2016c). The NRC staff (NRC 2016a) previously 5 identified these species as occurring at the Turkey Point site in the EIS for the Turkey Point 6 Units 6 and 7 combined licenses. 7 From December 5-7, 2016, FPL conducted its CCS characterization study (EAI 2017), which 8 primarily focused on sampling the CCS for fish and invertebrates. FPL also recorded any 9 observations of birds near and within the vicinity of the CCS. In total, FPL documented 13 bird 10 species, many of which used the CCS as a foraging ground for fish during the study. Observed 11 birds included snowy egrets (Egretta thula), little blue herons (Egretta caerulea), tricolored 12 herons (Egretta tricolor), reddish egrets (Egretta rufescens), great egrets (Ardea alba), roseate 13 spoonbills (Platalea ajaja), wood storks (Mycteria americana), American white pelicans 14 (Pelecanus erythrorhynchos), a yellow-crowned night heron (Nyctanassa violacea), a double-15 crested cormorant, an American avocet (Recurvirostra americana), great blue herons (Ardea 16 herodias), belted kingfishers (Megaceryle alcyon), and ospreys (Pandion haliaetus). 17 The NRC staff also reviewed the Florida Fish and Wildlife Conservation Commission's (FFWCC) 18 Florida Shorebird Database, which is a database of shorebird and seabird occurrences in 19 Florida (FFWCC 2018). The Florida Shorebird Database indicated that a breeding colony of 20 least terns (Sterna antillarum), which are listed by the State of Florida as a threatened species 21 in the State, occurs at Turkey Point. Least terns are discussed in further detail in 22 Section 3.7.3.1, State-Listed Species. 23 3.6.3 Important Species and Habitats 24 3.6.3.1 State-Listed Species 25 In accordance with Chapter 68A-27 of the Florida Administrative Code (FAC), the Florida Fish 26 and Wildlife Conservation Commission oversees the States Threatened and Endangered 27 Species Conservation Program. This chapter of the FAC gives the FFWCC the authority to list 28 species as State-threatened or endangered; to issue regulations necessary and advisable to 29 provide for conservation of such species; and to prohibit anyone from taking a species, which 30 includes activities that would harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or 31 collect, or to attempt to engage in such conduct. 32 Section 2.4.1.3 and Tables 2-14 and 2-15 of the NRC staffs EIS for the Turkey Point 33 Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a) describe the State-listed 34 threatened or endangered species that may occur in Miami-Dade County, not including those 35 species that are also Federally listed. This information is incorporated here by reference 36 (NRC 2016a: pages 2-97 to 2-109). The NRC staff reviewed the list of State threatened and 37 endangered species within Miami-Dade County that are not Federally listed (FNAI 2018) and 38 determined that Tables 2-14 and 2-15 in NUREG-2176 included all listed species as of 39 August 2018, except for the following, which the NRC staff here adds to the list of State-listed 40 threatened or endangered species identified in NUREG-2176: 41

• sea rosemary (Heliotropium gnaphalodes), State-listed as endangered 42
• Florida shrub thoroughwort (Koanophyllon villosum), State-listed as endangered 43
• Florida Keys ladies'-tresses (Mesadenus lucayanus), State-listed as endangered 44
• star-scale fern (Pleopeltis astrolepis), State-listed as endangered 3-90

1

• pineland spurge (Poinsettia pinetorum), State-listed as endangered 2
• mucha-gente (Xylosma buxifolia), State-listed as endangered 3 In addition, Simpson's prickly apple (Harrisia simpsonii), Fahkahatchee ladies'-tresses (Sacoila 4 lanceolata var. Paludicola), and Florida black bear (Ursus americanus floridanus) were included 5 in NUREG-2176, Tables 2-14 and 2-15. However, these species are not listed as State 6 endangered or threatened as of August 2018 (FNAI 2018). Florida pine snake (Pituophis 7 melanoleucus mugitus), Florida burrowing owl (Athene cunicularia Floridana), little blue heron, 8 reddish egret, tricolored heron, American oystercatcher (Haematopus palliates), roseate 9 spoonbill, and black skimmer (Rynchops niger) were identified as species of special concern in 10 Table 2-15 but are listed as State threatened as of August 2018. The change in classification of 11 these species therefore modifies the Tables of State-listed threatened or endangered species 12 identified in NUREG-2176.

13 Tables 2-14 and 2-15 in the EIS for the Turkey Point Units 6 and 7 combined licenses 14 (NUREG-2176) also describe whether the species has been observed at the Turkey Point site. 15 Since the NRC staff published NUREG-2176, FPL has conducted two new ecological surveys 16 (FPL 2016c, EAI 2017) as described in Section 3.7.3, Aquatic Resources on the Turkey Point 17 Site. In its May 23, 2016, survey, FPL (2016c) did not observe any State-listed species other 18 than the American crocodile, which is State- and federally listed as threatened. The crocodile is 19 addressed in Section 3.8.1.1, Species and Habitats under U.S. Fish and Wildlife Jurisdiction, 20 of this SEIS. Ecological Associates, Inc., (EAI 2017) observed five State-listed species in the 21 2016 CCS Characterization Study, including wood storks (also federally listed), little blue herons 22 (Egretta caerulea), tricolored herons, reddish egrets, and roseate spoonbills. These five 23 species had been previously observed at the Turkey Point site, as shown in NUREG-2176, 24 Table 2-15. 25 A colony of least terns nest on berms within the CCS (FPL 2018f). The Florida Fish and Wildlife 26 Conservation Commissions shorebird monitoring program suggests that this colony at the 27 Turkey Point CCS is one of the largest ground-nesting colonies of least terns on the eastern 28 coast of Florida between Key West and Melbourne and that this colony also maintains high 29 rates of nesting success (FFWCC 2016). To minimize disturbances to this nesting colony, FPL 30 installed warning signs surrounding the berms to alert site personnel that least terns are in the 31 vicinity. FPL also limits boat traffic near the colony during nesting season. FPL expects to 32 continue these activities during the subsequent license renewal period of extended operation 33 (FPL 2018g). 34 3.6.3.2 Migratory Birds 35 The U.S. Fish and Wildlife Service administers the Migratory Bird Treaty Act (MBTA), which 36 prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. 37 Regulations under the Migratory Bird Treaty Act define take as to pursue, hunt, shoot, wound, 38 kill, trap, capture, or collect, or attempt to carry out these activities (Title 50, Wildlife and 39 Fisheries, of the Code of Federal Regulations (50 CFR) 10.12, Definitions). The act protects 40 a total of 1,007 migratory bird species (75 FR 9282). The FWS (FWS 2018a) stated that 35 41 migratory birds of concern may occur on or near the Turkey Point site. Of those 35 migratory 42 bird species, FPL (FPL 2018g) identified 11 species that have been observed onsite at Turkey 43 Point. FPL (FPL 2018g) also noted that 23 additional bird species protected under the MBTA 44 have been observed onsite, although they were not included in FWSs (FWS 2018a) database. 45 The NRC staff notes that FPL has not implemented a formal monitoring or survey program for 46 migratory birds. Nonetheless, Table 3-7 describes the birds protected under the MBTA that are 3-91

1 most likely to occur at the Turkey Point site. As indicated below, migratory birds use the Turkey 2 Point site for resting, foraging, and breeding. 3 The FWS also administers the Bald and Golden Eagle Protection Act of 1940, as amended 4 (16 U.S.C. 668 et seq.), which prohibits anyone from taking bald eagles (Haliaeetus 5 Ieucocephalus) or golden eagles (Aquila chrysaetos), including their nests or eggs, without a 6 permit issued by the FWS. The FWS (FWS 2018a) determined that bald eagles may occur and 7 breed within the vicinity of the Turkey Point site throughout the year. FPL (FPL 2018g) has 8 observed bald eagles using the Turkey Point site for resting, although the species is rarely 9 observed onsite. 10 Table 3-7 Migratory Birds Protected under the Migratory Bird Treaty Act That Are Most 11 Likely to Occur at Turkey Point Frequency of Onsite Scientific Name Common Name Observations Onsite Habitat Use Anhinga anhinga occasionally resting, foraging Ardea alba great egret frequently resting, foraging Ardea herodias great blue heron frequently resting, foraging Bubo virginianus great horned owl rarely resting, foraging, breeding Bubulcus ibis cattle egret frequently resting, foraging Butorides virescens green heron frequently resting, foraging, breeding Charadrius vociferus killdeer frequently resting, foraging, breeding Chordeiles minor common nighthawk frequently resting, foraging, breeding Circus hudsonius northern harrier frequently resting, foraging Crotophaga ani smooth-billed ani rarely resting, foraging Egretta caerulea little blue heron frequently resting, foraging Egretta rufescens reddish egret frequently resting, foraging Egretta thula snowy egret frequently resting, foraging Egretta tricolor tri-colored heron frequently resting, foraging Elanoides forticatus swallow-tailed kite rarely resting, foraging Empidonax sp. flycatcher occasionally resting, foraging Eudocimus albus white ibis frequently resting, foraging Falco peregrinus peregrine falcon occasionally resting, foraging Gavia immer common loon rarely unknown Haliaeetus leucocephalus bald eagle rarely foraging Megaceryle alcyon belted kingfisher frequently resting, foraging Megascops asio screen owl occasionally resting, foraging, breeding Melanerpes carolinus red bellied woodpecker frequently resting, foraging, breeding Mycteria americana woodstork occasionally resting, foraging Pandion haliaetus osprey frequently resting, foraging Patagioenas leucocephala white-crowned pigeon frequently resting, foraging Pelecanus erythrorhynchos American white pelican frequently resting, foraging Pelecanus occidentalis brown pelican occasionally resting, foraging Phalacrocorax auritus double-crested cormorant frequently resting, foraging Platalea ajaja roseate spoonbill frequently resting, foraging 3-92

Frequency of Onsite Scientific Name Common Name Observations Onsite Habitat Use Sterna antillarum least tern frequently resting, foraging, breeding Thalasseus maximus royal tern frequently resting, foraging Tringa flavipes lesser yellowlegs occasionally resting, foraging Tyrannus dominicensis grey kingbird frequently resting, foraging Source: FWS 2018a; FPL 2018g 1 3.6.3.3 Important Habitats 2 Sections 2.2.1.6, 2.4.1.2, and 2.4.1.3 of the NRC staffs EIS for the Turkey Point Units 6 and 7 3 combined licenses (NUREG-2176) (NRC 2016a) describe several important terrestrial 4 restoration efforts and habitats located within National Parks, preserves, and other federally 5 owned, State-owned, County-owned, and privately-owned land. These include the following: 6

• Biscayne Bay National Park, which provides mangrove and other important habitat to 7 wildlife and over 200 species of birds, 21 of which are Federally listed as threatened or 8 endangered (NPS 2018a) (see pages 2-10 and 2-79 to 2-80 in NUREG-2176 9 (NRC 2016a)).

10

• Everglades National Park, which encompasses approximately 1.5 million ac 11 (607,000 ha) of wetlands, open water, and other important habitats for a variety of 12 wildlife and birds (see pages 2-11, 2-80, and 2-110 in NUREG-2176 (NRC 2016a)).

13

• The Comprehensive Everglades Restoration Plan (CERP) was approved by Congress in 14 2000 to restore, preserve, and protect the south Florida wetlands ecosystem while 15 providing for other water-related needs of the region. The area covered by this plan 16 includes the entire Everglades ecosystem. This interagency effort is one of the largest 17 ecosystem restoration efforts in the country and includes multiple smaller efforts, such 18 as the Biscayne Bay Coast Wetlands project (NPS 2018a; sees page 2-11 and 2-80 in 19 NUREG-2176 (NRC 2016a)).

20

• South Dade Wetlands Project, also referred to as Model Lands, which is co-managed by 21 Miami-Dade Countys Department of Environmental Resources and the Southwest 22 Florida Water Management System. These areas include over 20,000 ac (8,000 ha) of 23 publicly owned conservation lands, including Miami-Dade County Environmentally 24 Endangered Lands (DERM 2018). These wetlands serve as habitat and refuge for a 25 variety of wildlife, including numerous federally listed and State-listed threatened and 26 endangered species (see pages 2-10 and 2-133 in NUREG-2176 (NRC 2016a)).

27

• Everglades Mitigation Bank, which is a 13,000 ac (5,300 ha) expanse of freshwater and 28 estuarine wetlands west and south of the Turkey Point CCS. FPL owns the Everglades 29 Mitigation Bank and operates it as a commercial mitigation bank offering wetland habitat 30 credits that can be purchased to offset regional wetland impacts (see pages 2-12 and 31 2-133 in NUREG-2176 (NRC 2016a)).

32 The NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) 33 (NRC 2016a) identifies other important habitats that occur within the vicinity of the Turkey Point 34 site, such as mangrove forests (pages 2-109 to 2-110), pine rockland (page 2-110), marl prairie 3-93

1 (page 2-110), and wetlands (page 2-110). The NRC staff incorporates this information from 2 NUREG-2176 into this SEIS by reference (NRC 2016a: pages 2-109 to 2-110). Federally listed 3 and State-listed threatened or endangered species that have the potential to occur within these 4 important terrestrial habitats are described in pages 2-84 through 2-109 of NUREG-2176 5 (NRC 2016a), which information is also incorporated by reference herein. 6 3.6.4 Invasive and Non-Native Species 7 Several invasive and non-native species occur at Turkey Point. Although FPL does not formally 8 record the occurrence of such species, common invasive species on the Turkey Point site 9 include Australian pine (Casuarina equisetifolia), beach naupaka (Scaevola sericea), Brazilian 10 pepper (Schinus terebinthifolius), Burma reed (Neyraudia reynaudiana), and melaleuca 11 (Melaleuca quinquenervia) (FPL 2018g). The Argentine black-and-white tegu (Tupanimbis 12 merianae) has also been observed at Turkey Point (NRC 2016a). This egg-eating lizard is an 13 omnivore with the potential to affect many species, including alligators and crocodiles, and is the 14 subject of a multiagency control effort in the immediate vicinity of the Turkey Point site. As 15 described in Section 4.6.1.1, FPL (FPL 2018g) maintains a program to remove invasive species 16 from the CCS on an annual basis. 17 3.7 Aquatic Resources 18 This section describes the aquatic resources of the affected environment, including the South 19 Florida Coastal Plain Ecoregion, the CCS, Biscayne Bay, and Card Sound. 20 3.7.1 South Florida Coastal Plain Ecoregion 21 The Turkey Point site is located within the Southern Florida Coastal Plain ecoregion. This 22 ecoregion is characterized by a hydrologically interconnected, slow-flowing network of wetland 23 and aquatic systems, including ridge and slough landscapes, sawgrass plains, cypress and 24 mangrove swamps, and coastal lagoons and bays. The Everglades, a subtropical wetland 25 ecosystem that hosts a rich diversity of aquatic habitats and plant and animal species, comprise 26 much of the ecoregion. The Florida Keys, barrier islands that extend along the extreme 27 southern coast of the Florida Peninsula, protect estuarine bays and coves from the Atlantic 28 Ocean and create important spawning habitats. The South Florida Coastal Plain ecoregion is 29 also known for the Florida reef, the only living coral reef tract in the continental United States. 30 Beginning in the early 1900s, the hydrology of the ecoregion has been highly altered by human 31 activity to support agricultural and urban development. In 1948, Congress authorized the 32 creation of the Central and Southern Florida Flood Control Project, one of the largest water 33 management systems in the world. Through this project, a series of canals were created across 34 southern Florida to drain the land for flood control, water supply and retention, irrigation, and 35 transportation. Subsequent land drainage resulted in the loss or conversion of a substantial 36 portion of the original wetland system, reduced sheet flow dramatically, and created point-37 source discharge of freshwater into estuarine waters and coastal wetlands. The coastal areas 38 of the ecoregion have also become highly populated and dense beachfront development is 39 common. Nevertheless, a large portion of the ecoregion remains protected at the county, State, 40 or Federal level and is managed to maintain and restore the regions unique and sensitive 41 habitats. Section 2.4.2, Aquatic Ecology, of the NRC staffs EIS for the Turkey Point Units 6 42 and 7 combined licenses (NUREG-2176) (NRC 2016a) provides more detailed information on 43 the South Florida Coastal Plain ecoregion, including anthropogenic alterations and other past 3-94

1 changes to the environment. The NRC staff incorporates the NUREG-2176 descriptions of the 2 ecoregion into this SEIS by reference. 3 3.7.2 Aquatic Resources near the Turkey Point Site 4 The region surrounding Turkey Point contains shallow subtropical estuarine and marine 5 environments, including Biscayne Bay and its associated park and preserve; Florida Keys 6 National Marine Sanctuary; Card Sound and Canal; the Everglades Mitigation Bank, Model 7 Lands Basin, and Southern Glades Addition; as well as Everglades National Park and the 8 Crocodile Lake National Wildlife Refuge. 9 Biscayne Bay is a shallow subtropical saline lagoon that extends the length of 10 Miami-Dade County. A series of barrier islands belonging to the Florida Keys borders the 11 eastern edge of the bay and separates the bay from the Atlantic Ocean. The mainland forms 12 the western and northern borders of the bay. Connection between Biscayne Bay and the 13 Atlantic Ocean is greatest north of Boca Chita Key. Ocean access is most restricted in the 14 southern portion of the bay at Card Sound and Barnes Sound due to the presence of Key Largo 15 and its associated barrier islands. The average depth of the bay is approximately 5 ft (1.5 m) at 16 mean low water, and its maximum depth is approximately 13 ft (4.0 m). Salinity is highly 17 influenced by rainfall and ranges from 24 to 44 PSU. Annual surface water temperatures range 18 from 59 °F to 92 °F (15 °C to 33 °C). The bays shallow depths and low spring tidal range 19 (3 ft (0.9 m) maximum) result in a vertically well-mixed system with weak stratification. 20 Within the bay, Biscayne National Park encompasses 173,000 ac (70,000 ha) of water and 21 coastal lands as well as 42 islands. The park is home to a large segment of the Florida reef, the 22 only living coral reef tract in the continental United States. The park supports an immense array 23 of wildlife, including more than 600 fish species, many of which are commercially and 24 recreationally important, and 21 federally threatened or endangered species. Notably, the bay 25 provides habitat for the federally listed Florida manatee (Trichechus manatus latirostris), 26 smalltooth sawfish (Pristis pectinata), American crocodile (Crocodylus acutus), and Johnson's 27 seagrass (Halophila johnsonii) (FDEP 2017b). Johnson's seagrass is the first and only marine 28 plant to be listed as threatened under the Endangered Species Act. 29 The Biscayne Bay Aquatic Preserve includes 67,000 ac (27,000 ha) of sovereign submerged 30 lands managed by the Florida Department of Environmental Protections Office of Coastal and 31 Aquatic Managed Areas. The preserve runs the length of Biscayne Bay from the headwaters of 32 the Oleta River down to Card Sound near Key Largo. The Florida Department of Environmental 33 Protection designated the waters within the Biscayne Bay Aquatic Preserve as Outstanding 34 Florida Waters for waters worthy of special protection because of natural attributes. Under the 35 Outstanding Florida Waters designation, the State cannot issue permits for direct discharges 36 that would lower ambient water quality (FDEP 2017a). 37 Card Sound is a shallow bay south of the Turkey Point site with limited connection to the 38 Atlantic Ocean. It lies wholly within the boundary of the Florida Keys National Marine 39 Sanctuary. The mangrove forests surrounding Card Sound are part of the longest continuous 40 stretch of mangrove remaining on the east coast of Florida and provide a source of food and 41 refuge for approximately 70 percent of the regions commercially and recreationally important 42 marine species. Both Biscayne Bay and Card Sound are nursery areas for the spiny lobster 43 (Panulirus argus). The State of Florida has designated the area from Cape Florida near Key 44 Biscayne south to Card Sound as the Biscayne Bay-Card Sound Lobster Sanctuary. 3-95

1 Section 2.4.2 of the NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses 2 (NUREG-2176) (NRC 2016a) describes Biscayne Bay, Card Sound, and other nearby aquatic 3 resources in detail. The NRC staff incorporates those descriptions from NUREG-2176 into this 4 SEIS by reference. In addition, see Section 3.7.4 of this SEIS for a detailed discussion of FPLs 5 semiannual monitoring of Biscayne Bay and Card Sound. 6 3.7.3 Aquatic Resources on the Turkey Point Site 7 Within the Turkey Point site, the primary aquatic environment is the cooling canal system 8 (CCS). The CCS occupies an area that is approximately 2 mi (3.2 km) wide by 5 mi (8 km) long 9 and includes 168 mi (270 km) of earthen canals that cover an effective water surface area of 10 approximately of 4,370 ac (1,770 ha) and a total surface area of 5,900 ac (24 km2) (FPL 2018f, 11 NRC 2002c). The CCSs channels are about 200 feet (60 m) wide and range in depth from 1 to 12 3 feet (0.3 to 1 m) (FPL 2018f). FPL constructed the CCS to use as an industrial wastewater 13 facility. For a description of the CCS operations, see Section 3.1.3, Cooling and Auxiliary 14 Water Systems, in this SEIS. 15 The CCS has historically supported a variety of fish, mollusks, crabs, and submerged aquatic 16 vegetation that are tolerant of shallow, subtropical, hypersaline environments such as 17 sheepshead minnow (Cyprinodon variegatus) and several Fundulus species. FPL (FPL 2014a) 18 reported that the species identified in Table 3-8 were present in the CCS as of November 2007. 19 Because the CCS does not directly connect to any surface water body, aquatic organisms are 20 unable to travel between the CCS and any other water bodies. Aquatic biota in the CCS are not 21 accessible for recreational or commercial harvest because FPL controls the entirety of the CCS 22 and does not allow the public to access it. 23 Table 3-8 Aquatic Species Reported from the Cooling Canal System, November 2007 Species Common Name Fish Centropomus undecimalis common snook Cyprinodon variegatus sheepshead minnow Fundulus spp. killifish Gambusia spp. mosquitofish Megalops atlanticus tarpon Mugil spp. mullet Poecilia latipinna sailfin molly Strongylura spp. needlefish Mollusks Busycon contrarium lightning whelk Cerithium eburneum ivory cerith Isognomon alatus flat tree oyster Isognomon radiatus Listers tree oyster Marisa cornuarietis giant rams horm Melampus bidentatus eastern melamphus Melongena corona Florida crown conch 3-96

Species Common Name Tellin spp. tellin Crustaceans Cardisoma guanhumi great land crab Uca spp. fiddler crab Submerged Aquatic Vegetation Acetabularia spp. mermaids wineglass (green algae) Batophora spp. green algae Caulerpa spp. green algae Ruppia maritima widgeon grass Source: adapted from FPL 2014a 1 Other onsite aquatic resources at Turkey Point include hypersaline mudflats, remnant canals, 2 channels, dwarf mangrove wetlands, and open water. In June 2009, Tetra Tech NUS, Inc. 3 (Tetra Tech 2009) conducted fish surveys throughout the Turkey Point property in both CCS 4 and non-CCS waters. Sampling locations, which are depicted in Figure 3-20, included: 5

• mangrove wetland west of Turkey Point (TP-1) 6
• sawgrass marsh/mangrove community adjacent to Palm Drive (TP-2) 7
• south (TP-3A) and north (TP-3B) remnant canals 8
• a portion of the return canal (TP-4) 9
• shallow flats in the east-central part of the Turkey Point plant area (TP-5) 10
• a dead-end canal (TP-6) 11
• CCS north (TP-7) 12
• CCS south (TP-8) 13 During sampling, water temperatures ranged from 75.0 to 97.7 °F (23.9 to 36.5 °C), salinity was 14 above 50 PSU at six sampling stations (TP-3A, TP-4, TP-5, TP-6, TP-7, and TP-8), and salinity 15 was less than or equal to 1.5 PSU at two stations in sawgrass/mangrove habitats (TP-1 and 16 TP-2) (Tetra Tech 2009). Tetra Tech biologists collected fish with 8-foot (2.4-m) cast nets, a 17 20-ft (6-m) -long minnow seine, and standard Gee-type galvanized minnow traps. Sampling 18 yielded a total of 433 fish representing seven species. All but one of the fish collected were 19 small-bodied, short-lived, schooling species representative of two families: the killifishes (family 20 Cyprinodontidae) and the livebearers (family Poeciliidae). Sheepshead minnow was the 21 dominant species; this fish species was present in seven of the eight sampling stations and 22 represented 63 percent of the collection. Sailfin molly (Poecilia latipinna) and goldspotted 23 killifish (Floridichthys carpio) were present at the majority of the sampling stations and 24 represented 20.8 percent and 9.9 percent of collections, respectively. No fish were collected at 25 TP-2, a sawgrass marsh/mangrove community adjacent to Palm Drive. All fish were of hardy 26 species common to South Florida; no rare, unusual, sensitive, or protected species were 27 present in collections. Table 3-9 identifies the collected species, relative abundances, and 28 collection locations.

3-97

1 Source: Tetra Tech 2009, Figure 1 2 Figure 3-20 Turkey Point Site Fish Survey Sample Locations, June 2009 3-98

1 Table 3-9 Number and Relative Abundance of Fish Captured at Seven Locations on the 2 Turkey Point Site, June 2009 Number Species Common Name Collected Collection Locations Cyprinodon variegatus sheepshead minnow 273 all locations except TP-2 Poecilia latipinna sailfin molly 90 all locations except TP-2, TP-5 Floridichthys carpio goldspotted killifish 43 all locations except TP-1, TP-2 Fundulus confluentus marsh killifish 15 TP-1 Fundulus grandis gulf killifish 6 TP-1, TP-3, TP-7, TP-8 Gambusia affinis mosquitofish 5 TP-1, TP-4 Opsanus beta gulf toadfish 1 TP-4 Source: Tetra Tech 2009 3 Prior to 2010, the CCS environment was of low turbidity and contained low and stable nutrient 4 levels. Widgeon grass (Ruppia maritima) beds covered over 50 percent of the system and were 5 especially prominent in the southern sections of the CCS and in the eastern return canals. 6 Seagrasses underwent annual periods of stress and recovery as CCS salinities cycled between 7 greater than 50 PSU (stress) and less than 50 PSU (recovery). Despite the harsh environment, 8 seagrass colonies remained relatively stable from year to year (FPL 2016l). 9 In 2010, the CCS began experiencing a pronounced ecosystem shift. The average salinity of 10 the CCS increased, water quality and clarity began to degrade, and average surface water 11 temperatures increased. Seagrass colonies began to die off due to salinity- and high 12 temperature-related stress. By 2012, very few seagrass beds remained in the CCS. The 13 subsequent decomposition of the seagrasses released a significant volume of nutrients into the 14 CCS, and the increased nutrient levels facilitated algae blooms, which resulted in high turbidity 15 and degraded water quality. Algae blooms remained local and isolated in 2011 and 2012. In 16 2013 and 2014, continuously elevated concentrations of algae were observed throughout the 17 CCS. By 2016, no seagrasses remained in the CCS. The CCS currently operates as an 18 algal-based, phosphorus-limited system such that the algae life cycle primarily dictates the 19 movement of nutrients in and out of the water column (FPL 2016l). 20 To address CCS water quality degradation and as a requirement of the 2016 FDEP Consent 21 Order, FPL began implementing a nutrient management plan (FPL 2016l) in 2016. The plan 22 includes short- and long-term initiatives. One initiative is to re-establish seagrass meadows 23 within the CCS. FPL (FPL 2016l) states in its plan that a healthy seagrass population of 24 approximately 50 percent of the surface water acreage would help balance and sequester the 25 CCSs nutrient content. Seagrasses require non-turbid, clear water with near-ocean salinity 26 levels (roughly 30 to 37 PSU). Given the current turbid, hypersaline, and phosphorus-limited 27 conditions in the CCS, FPL is concentrating its efforts on removing or binding bioavailable 28 phosphorus to reduce algae growth, which would in turn reduce nitrogen fixation, increase water 29 clarity, and improve the conditions for re-establishment of seagrasses. FPL is currently 30 investigating the direct application of flocculants into the CCS, treatment of CCS water in an 31 external system, and the use of protein skimming methods to actively remove algae and 32 nutrients. Once FPL reduces nutrients and lowers salinities, FPL will cultivate and plant 33 seagrass beds within areas of the CCS with appropriate depth and substrate. As CCS 34 conditions improve, some dormant seagrass seeds in the CCS may also germinate such that 3-99

1 seagrasses may reemerge naturally. Once re-established, a healthy seagrass population will 2 provide a significant mechanism for uptake and retention of nutrients, thus reducing nutrient 3 concentrations in the water. Lower nutrient concentrations in the water will deter algal blooms 4 and fewer algal blooms will lead to greater water clarity. FPLs nutrient management plan sets a 5 seagrass colonization target at 50 percent of the CCS water acreage. Section 3.5.1.4 describes 6 the plan in more detail under the subsection titled, Nutrient Management Plan for the Cooling 7 Canal System. 8 To determine the presence, relative abundance, and distribution of fish, invertebrate, and 9 seagrass populations currently within the CCS, FPL commissioned Ecological Associates, Inc. 10 (EAI) to conduct a biological characterization study in December 2016 (EAI 2017). EAI 11 established ten sampling stations within the CCS chosen to represent different benthic habitats, 12 salinity gradients, and temperature regimes (see Figure 3-21). Seven stations were located in 13 the main CCS area, two were located in return canals, and one was located in a dead-end canal 14 in the northern section of the system. EAI sampled fish and mobile invertebrates, benthic 15 macroinvertebrates, and submerged aquatic vegetation. 16 Source: EAI 2017, Figure 1 17 Figure 3-21 Cooling Canal System Characterization Survey Sample Locations, 18 December 2016 3-100

1 To identify fish and mobile invertebrates, EAI performed cast net sampling on 2 December 5, 2016, and minnow trap sampling on December 6 and 7, 2016. Cast net sampling 3 targets large mobile organisms throughout the water column, while minnow trap sampling 4 selectively targets small species at the top and bottom of the water column. EAI collected a 5 total of 4,843 individuals of 4 taxa: sheepshead minnow, sailfin molly, eastern mosquitofish 6 (Gambusia holbrooki), and mudflat fiddler crabs (Uca rapax). Cast net samples yielded 7 282 fish: 259 sheepshead minnow, 22 sailfin molly, and 1 eastern mosquitofish. All fish 8 collected during cast netting were small (less than 45 mm (1.75 inch) standard length). 9 Minnow traps yielded 4,547 fish and 14 crabs: 3,900 sheepshead minnow, 627 sailfin mollies, 10 20 eastern mosquitofish, and 14 mudflat fiddler crabs. Fish ranged from 10 to 60 mm 11 (0.4 to 2.4 inch) standard length, and crabs ranged from 8 to 11 mm (0.3 to 0.43 inch) carapace 12 length and 11 to 15 mm (0.43 to 0.59 inch) carapace width. 13 Sheepshead minnow were abundant throughout the CCS and were found at all 10 sampling 14 stations during the CCS characterization study. This species can live and successfully 15 reproduce in high salinity waters (up to 147 PSU) and high temperatures (up to 109.4 °F 16 (43 °C)) (Johnson 1974). Sailfin mollies were moderately abundant throughout the system. 17 This species is also able to tolerate high salinities (up to 80 PSU), high temperatures (up to 18 104 °F (40 °C)), and low dissolved oxygen (Fischer and Schlupp 2009, Nordlie et al. 1992, 19 Timmerman and Chapman 2004). Eastern mosquitofish were only found at 2 of the 10 20 sampling stations and are likely rare in the CCS as a whole. This species can also tolerate high 21 temperatures (up to 100.4 °F (38 °C)), hypersaline (up to 58.8 PSU) waters with low dissolved 22 oxygen (Chervinski 1983, Specziar 2004). Mudflat fiddler crabs were captured incidentally with 23 sampling methods not designed to capture crabs, so EIA did not make any conclusions 24 regarding crab abundance in its CCS characterization study report. Nevertheless, mudflat 25 fiddler crabs have also been documented as able to withstand high temperature, high salinity, 26 and low dissolved oxygen conditions (Costa and Soares-Gomes 2015, Vernberg and 27 Tashian 1959, Zanders and Rojas 1996). Meroplankton sampling would be required to 28 conclusively determine whether mudflat fiddler crabs are actively reproducing in the CCS or 29 whether individuals were present due to recruitment by immigration into the system. EIA found 30 no evidence that the environmental conditions within the CCS were negatively affecting the 31 growth or reproduction of the species captured, all of which tended to be heat- and salinity-32 tolerant species. 33 To identify benthic macroinvertebrates, EAI collected benthic mini-ponar grabs on 34 December 6, 2016, which EAI subsequently processed in a laboratory. A total of 79 individuals 35 of 3 taxa were identified. The polychaete Capitella capitate was the most common taxon 36 collected followed by marine oligochaetes (Class Oligochaeta) and midge larvae (Family 37 Chironomidae). EAI calculated benthic macroinvertebrate densities to range from 38 30 to 489 individuals per square meter at stations with organisms present. Evidence of relic 39 gastropod and bivalve shells were also present at some stations; however, no live mollusk 40 specimens were collected. 41 In addition to fish and benthic sampling, EAI used underwater video on December 5 42 and 6, 2016, along defined video transect surveys to search for living submerged aquatic 43 vegetation (seagrasses). Widgeon grass, which was previously the predominant submerged 44 aquatic vegetation type present in the CCS, can grow in waters ranging from 64.4 to 86 °F 45 (18 to 30 °C), although temperatures above 73.4 to 77 °F (23 to 25 °C) have a negative 46 influence on photosynthesis (Arnold et al. 2017). One study on the effect of salinity on the 47 species determined that 8- to 12-week old plants could not tolerate salinities above 48 21,000 parts per million (ppm) (Mayer and Low 1970). This equates to approximately 21 PSU. 3-101

1 During the CCS characterization study, EAI observed no seagrasses. Because water clarity 2 was poor throughout the entire project area, EAI also scanned its benthic macroinvertebrate 3 collections for living vegetation. No samples contained living vegetation. In its report, EAI 4 attributed the lack of submerged aquatic vegetation to the CCSs turbid water conditions, high 5 salinity, and high temperatures. 6 While differences in sampling methods and effort make definitive conclusions difficult to 7 determine, the available information on the CCS aquatic community indicates that species 8 diversity within the system has declined over time. Submerged aquatic vegetation is no longer 9 present in the system, and a number of the fish species reported as present in the system 10 in 2007 and 2009 were not collected in 2016. The current aquatic community is of low diversity 11 and includes only those species that can withstand hot, hypersaline waters with low dissolved 12 oxygen and poor water clarity. 13 3.7.4 Biscayne Bay and Card Sound Semiannual Monitoring 14 Since September 2010, FPL has commissioned ongoing, semiannual ecological monitoring of 15 the Turkey Point site and surrounding environment, including Biscayne Bay, as a requirement of 16 the Florida Department of Environmental Protections Conditions of Certification in connection 17 with the Turkey Point extended power uprate and the South Florida Water Management 18 Districts Fifth Supplemental Agreement. Ecology & Environment, Inc. conducted the most 19 recently reported period of monitoring for Biscayne Bay in September 2016 and May 2017 (one 20 fall and one spring event). Ecology & Environment, Inc. summarized and compared the results 21 of this monitoring period with corresponding past results during the historical period of record. 22 The results appear in the 2017 Turkey Point Plant Annual Monitoring Report (E&E 2017). This 23 section briefly summarizes the monitoring methods and the 2016-2017 results. 24 FPL performs aquatic ecological sampling in three locations adjacent to the CCS within 25 Biscayne Bay and Card Sound (BB1, BB2, and BB3) and one reference site in Barnes Sound 26 (BB4), which lies directly south of Card Sound (see Figure 3-22). Within each of the study 27 areas, ecological conditions are monitored along two 2-km (1.2-mi)-long shore-parallel transects 28 (designated a and b for each study area) that lie approximately 250 and 500 m (0.16 and 29 0.32 mi) from shore. Each transect is divided into eight 250-m (0.16-mi)-long segments, and a 30 1-m2 (0.6-mi2) point was randomly selected along each of the eight segments during the initial 31 September 2010 sampling event to be used as the permanent location for all future sampling 32 events. Thus, ecological monitoring encompasses a total of 16 sampling points per study area 33 and a total of 64 sampling points across all study areas. This sampling design is based on 34 FPLs State-approved monitoring plan. 35 At each sampling location, submerged aquatic vegetation is surveyed and categorized 36 according to the Braun-Blanquet Cover Abundance Index. Sediment depth and general 37 physical and surface water parameters are collected. Turtle grass (Thalassia testudinum) 38 blades are collected for laboratory nutrient analysis. In addition to quantitative data, divers also 39 record qualitative characteristics of the benthic conditions surrounding each sampling point. 40 In the 2017 report (E&E 2017), ecological monitoring findings were similar to those reported in 41 previous post-uprate annual monitoring reports. Ecology and Environment Inc.s (E&Es 2017) 42 major findings were as follows. 43

• The marsh and mangrove areas are representative of the hydrologically modified or 44 nutrient-limited communities found along the coastal fringe of south Florida.

3-102

1

• Data collected during the reporting period continue to support the conclusion that the 2 CCS does not have an ecological impact on the surrounding areas, and there is no clear 3 evidence of CCS water in the surrounding marsh or mangrove areas from a groundwater 4 pathway. Rather, ecological changes observed during the reporting period are more 5 seasonally and meteorologically driven.

6 Source: E&E 2017, Figure 1.3-1 7 Figure 3-22 Biscayne Bay and Card Sound Semiannual Monitoring 8 Ecological Transection Locations 3-103

1 3.7.5 Additional Information on Aquatic Resources 2 Section 2.4.2, Aquatic Ecology, of the NRC staffs EIS for Turkey Point Units 6 and 7 3 combined licenses (NUREG-2176) (NRC 2016a) provides more information on the following 4 aspects of the aquatic environment: 5

• Turkey Point ecoregion (pages 2-119 to 2-122) 6
• Historical conditions and anthropogenic alterations to the Turkey Point ecoregion 7 (pages 2-119 to 2-122) 8
• Detailed descriptions of aquatic resources on the Turkey Point site (pages 2-122 to 9 2-128; Table 2-18 and Table 2-19) 10
• Descriptions of the CCS and its water quality through 2016 (pages 2-123 to 2-126) 11
• Summaries of macroinvertebrate and seagrass surveys performed in near-shore areas 12 of Biscayne Bay in 2008 and 2009 to support the Turkey Point 6 and 7 combined 13 licenses application (pages 2-123 to 2-128 and 2-159 to 2-160; Table 2-18 and 14 Table 2-20) 15
• Descriptions of nearby aquatic environments, which include Biscayne Bay and its 16 associated park and preserve, Florida Keys National Marine Sanctuary, Card Sound and 17 Canal, the Everglades Mitigation Bank, Everglades National Park, and the Crocodile 18 Lake National Wildlife Refuge (pages 2-128 through 2-134; Tables 2-21 through 2-25) 19
• Ecologically, commercially, and recreationally important species (pages 2-136 to 2-142; 20 Table 2-27) 21
• State-listed threatened or endangered species and species of concern (page 2-154 to 22 2-157; Table 2-30) 23
• Nonindigenous and invasive species (page 2-142) 24 The NRC staff incorporates this information from NUREG-2176 as indicated by the section, 25 page, and table numbers above, into this SEIS by reference. The NRC staff did not identify any 26 new or updated information relevant to the description of the aquatic environment beyond the 27 additional information previously described in this section.

28 3.8 Special Status Species and Habitats 29 This section addresses species and habitats that are federally protected under the Endangered 30 Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) (ESA), and the Magnuson-Stevens 31 Fishery Conservation and Management Act of 1996, as amended (16 U.S.C. 1801 et seq.) 32 (MSA). Prior to taking a Federal action, such as the issuance of the proposed Turkey Point 33 subsequent renewed licenses, the NRC has direct responsibilities under these statutes. The 34 terrestrial and aquatic resource sections of this SEIS (Sections 3.6 and 3.7, respectively) 35 address species and habitats protected by other Federal statutes and the State of Florida under 36 which the NRC does not have such responsibilities. 37 3.8.1 Species and Habitats Protected Under the Endangered Species Act 38 The U.S. Fish and Wildlife Service and the National Marine Fisheries Service jointly administer 39 the Endangered Species Act. The U.S. Fish and Wildlife Service manages the protection of, 40 and recovery effort for, listed terrestrial and freshwater species, and the National Marine 3-104

1 Fisheries Service manages the protection of, and recovery effort for, listed marine and 2 anadromous species. The following sections describe the Turkey Point action area and then 3 consider separately those species that could occur in the action area under the jurisdiction of 4 each Service. 5 Turkey Point Action Area 6 The implementing regulations for Section 7(a)(2) of the Endangered Species Act define action 7 area as all areas affected directly or indirectly by the Federal action and not merely the 8 immediate area involved in the action (50 CFR 402.02, Definitions). The action area 9 effectively bounds the analysis of federally listed species and critical habitats because only 10 species and habitats that occur within the action area may be affected by the Federal action. 11 For the purposes of assessing the potential impacts of Turkey Point subsequent license renewal 12 on federally listed species, the NRC staff considers the action area to consist of the Turkey 13 Point site, including the CCS, as well as Biscayne Bay. While most potential impacts 14 associated with the proposed action would be confined to the Turkey Point site, continued 15 Turkey Point operations would necessitate occasional delivery of large parts and equipment by 16 barge over the course of the subsequent license renewal term. Such deliveries would require 17 barge travel through Biscayne Bay, which is why the NRC staff includes this waterbody in the 18 Turkey Point action area for subsequent license renewal. 19 The NRC staff recognizes that while the action area is stationary, federally listed species can 20 move in and out of the action area. For instance, a migratory bird species could occur in the 21 Turkey Point action area seasonally as it forages or breeds. Thus, in its analysis, the NRC staff 22 considers not only those species known to occur within the action area, but also those species 23 that may passively or actively move into the action area. The staff then considers whether the 24 life history of each species makes it likely to move into the action area where it could be affected 25 by the proposed Turkey Point subsequent license renewal. 26 The following sections first discuss endangered or threatened species and critical habitats under 27 the U.S. Fish and Wildlife Services (FWS) jurisdiction followed by a discussion of those species 28 under the National Marine Fisheries Services (NMFS) jurisdiction. 29 3.8.1.1 Species and Habitats under U.S. Fish and Wildlife Services Jurisdiction 30 The NRC staff used the U.S. Fish and Wildlife Services Environmental Conservation Online 31 System (ECOS) Information for Planning and Conservation (IPaC) tool to determine species 32 that may be present in the Turkey Point action area. The ECOS IPaC tool identified 42 federally 33 listed endangered or threatened species under the U.S. Fish and Wildlife Services sole 34 jurisdiction with the potential to occur in the Turkey Point action area. The IPaC tool also 35 identified designated critical habitat for two of these species in the Turkey Point action area 36 (FWS 2018b) (see Table 3-10). No proposed species, candidate species, or proposed or 37 designated critical habitat occurs within the action area (FWS 2018b). Table 3-10 describes the 38 habitat requirements, occurrence patterns, and Federal status for each of the 42 federally listed 39 species under FWSs sole jurisdiction. 40 In addition to these 42 species, FWS (FWS 2018b) identified 4 species for which FWS and 41 NMFS have joint jurisdiction, including (1) the loggerhead sea turtle (Caretta caretta), 42 (2) leatherback sea turtle (Dermochelys coriacea), (3) hawksbill sea turtle (Eretmochelys 43 imbricata), and (4) the Atlantic Sturgeon (gulf Subspecies) (Acipenser oxyrinchus (oxyrhynchus) 3-105

1 desotoi). However, the proposed action would have no effect on the nesting habitat of sea 2 turtles or other portions of the life cycle that are under FWSs jurisdiction for these four species 3 (NRC 2018g). The life history and impacts to these species under the jurisdiction of NMFS is 4 described in Sections 3.8.1.2, Species and Habitats under National Marine Fisheries Service, 5 and 4.8.1.2, Species and Habitats Protected Under the Magnuson-Stevens Act. 6 Table 3-10 Federally Listed Species under U.S. Fish and Wildlife Service Jurisdiction Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Mammals Eumops floridanus Florida Suitable roosting (e.g., palm trees, tree cavities, Endangered bonneted bat Spanish tiled roofs) and foraging habitat occurs at Turkey Point (FWS 2017a); Observed within the vicinity of Turkey Point (FPL 2018f). Puma concolor Florida panther Florida Panther Focus Area occurs in the vicinity of Endangered coryi Turkey Point (FWS 1999); Observed 2 mi west of Turkey Point (SFWMD 2013a). Puma concolor (all puma No known occurrences in Florida (FWS 1999; SAT sub species except NRC 2016a). coryi) Trichechus West Indian Designated critical habitat occurs adjacent to Threatened manatus manatee Turkey Point; Observed in the vicinity of Turkey Point, including canals and nearshore seagrass beds in Biscayne Bay (FPL 2012b). Birds Ammodramus Cape Sable Suitable habitat (mixed marl prairie) does not Endangered maritimus mirabilis seaside occur at Turkey Point; No known occurrences at sparrow Turkey Point (NRC 2015a; FPL 2014a). Ammodramus Florida Extirpated from Miami-Dade County (FWS 1999). Endangered savannarum Grasshopper sparrow Aphelocoma Florida scrub- Extirpated from Dade County (FWS 1999). Threatened coerulescens jay Caladris rufa red knot Suitable habitat, such as mudflats, salt marshes, Threatened and mangroves occur onsite (FWS 2017a); Observed onsite (FPL 2014a). Campephilus ivory-billed Likely extirpated from the United States; No known Endangered principalis woodpecker occurrences on or near Turkey Point (FWS 1999 NRC 2016a). Charadrius piping plover Suitable wintering habitat occurs onsite and within Threatened melodus the vicinity, such as beaches, mudflats, and sandflats (FPL 2014a; FPL 2018f); No documented occurrences onsite (FPL 2014a; NRC 2015a) Mycteria americana wood stork Suitable foraging, resting, and roosting habitat Threatened within the CCS and onsite wetlands; Regularly observed onsite (NRC 2015a; EAI 2017; FPL 2018g). 3-106

Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Picoides borealis red-cockaded No known occurrences within Miami-Dade County Endangered woodpecker (FWS 1999; NRC 2016a). Rostrhamus Everglades Suitable habitat (lowland freshwater marshes) Endangered sociabilis snail kite occurs on and near Turkey Point (NRC 2015a); Observed within the Everglades Mitigation Bank adjacent to Turkey Point (FPL 2014a). Setophaga kirtlandi Kirtland's Suitable habitat (dense mangroves) occurs on and Endangered warbler near Turkey Point; No known observations onsite (NRC 2016a; FPL 2018f). Vermivora Bachman's No observations of this species in the United Endangered bachmani warbler States since 1988 (FWS 1999). Reptiles Alligator American Suitable freshwater habitat occurs within the SAT mississippiensis alligator vicinity of Turkey Point (FPL 2018f). Crocodylus acutus American Designated critical habitat at Turkey Point; Onsite Threatened crocodile wetlands provide habitat for nesting, rearing hatchlings, and foraging; Onsite adult and hatchling populations have existed for several decades (FPL 2018f). Drymarchon corais eastern indigo Suitable habitat, including freshwater marshes, Threatened couperi snake mangroves, and cleared areas, occurs at Turkey Point; Regularly observed onsite (FPL 2018g). Invertebrates Anaea troglodyta Florida Suitable habitat (pineland croton plants in pine Endangered floridalis leafwing rockland) does not occur at Turkey Point butterfly (FWS 2017a; FPL 2018f). Cyclargus Miami blue Only known occurrences are within Key West Endangered (=Hemiargus) butterfly National Wildlife Refuge (FFWCC undated; thomasi FPL 2018f). bethunebakeri Heraclides Schaus Suitable habitat (pineland croton plants in pine Endangered aristodemus swallowtail rockland) does not occur at Turkey Point ponceanus butterfly (FWS 2017a; FPL 2018f). Orthalicus reses Stock Island Suitable habitat (hardwood hammocks primarily in Threatened Tree Snail keys) does not occur at Turkey Point; No known occurrence within the vicinity of Turkey Point (FWS 1999; FPL 2018f). Strymon acis Bartram's Suitable habitat, which is limited to pine rockland Endangered bartrami hairstreak where its host plant pineland croton occurs, does butterfly not occur at Turkey Point (FWS 2017a; FPL 2018f). Flowering Plants Amorpha crenulata crenulate lead- Suitable habitat (pine rockland) does not occur at Endangered plant Turkey Point (FWS 2017a). Argythamnia Blodgett's Limited suitable habitat (coastal berm) may occur Threatened blodgettii silverbush onsite; Observed within the vicinity of Turkey Point (FPL 2011b; Gann et al. 2018). 3-107

Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Brickellia mosieri Florida Suitable habitat (pine rockland) does not occur at Endangered brickell-bush Turkey Point (FWS 2017a). Chamaesyce deltoid spurge Suitable habitat (pine rockland) does not occur at Endangered deltoidea ssp. Turkey Point (FWS 2017a). deltoidea Chamaesyce pineland Suitable habitat (pine rockland) does not occur at Threatened deltoidea pinetorum sandmat Turkey Point (NRC 2015a; 82 FR 6691). Chamaesyce Garber's Suitable habitat (pine rockland) does not occur at Threatened garberi spurge Turkey Point (FWS 2017a). Chromolaena Cape Sable Limited suitable habitat (coastal rock barrens) may Endangered frustrata thoroughwort occur at Turkey Point. Species does not occur in disturbed areas (FWS 2010a; FPL 2018f; NRC 2016a). Consolea Florida Limited suitable habitat (coastal berms) may occur Endangered corallicola semaphore at Turkey Point (78 FR 63796; NRC 2016a); No cactus known occurrences at Turkey Point (NRC 2016a; FPL 2018f). Cucurbita Okeechobee No known occurrences in Miami-Dade County; Not Endangered okeechobeensis Gourd likely to occur at Turkey Point due to lake of ssp. suitable habitat (NRC 2016a; Gann et al. 2018; okeechobeensis FPL 2018g). Dalea Florida prairie- Suitable habitat not likely to occur at Turkey Point Endangered carthagenensis clover because some suitable habitats (i.e. pine floridana rocklands, edges of rockland hammocks, and marl prairies) do not occur at Turkey Point and other suitable habitat (i.e., uplands) have been previously disturbed (NRC 2016a; Gann et al. 2018; FPL 2018g). Digitaria pauciflora Florida Suitable habitat (marl prairie and pine rockland) Threatened pineland does not occur at Turkey Point (NRC 2016a; crabgrass Gann et al. 2018; FPL 2018g). Galactia smallii Small's Suitable habitat (pine rockland) does not occur at Endangered milkpea Turkey Point (FWS 2017a). Jacquemontia beach Suitable habitat (pine rockland) does not occur at Endangered reclinata jacquemontia Turkey Point (FWS 2017a). Linum arenicola sand flax Potential to occur onsite given that this species Endangered grows less than 1 mi from Turkey Point and suitable habitat (i.e., pine rocklands, marl prairie, and adjacent disturbed areas) occurs within the vicinity (FPL 2018f). Linum carteri carteri Carter's small- Suitable habitat (pine rockland) does not occur at Endangered flowered flax Turkey Point (FWS 2017a). Polygala smallii tiny polygala Suitable habitat (pine rockland) does not occur at Endangered Turkey Point (FWS 2017a). Sideroxylon Everglades Suitable habitat (pine rockland habitat, marl prairie Threatened reclinatum ssp. bully habitat, and within the ecotone between both austrofloridense habitats) does not occur at Turkey Point (82 FR 46691). 3-108

Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Warea carteri Carter's Extirpated from Miami-Dade County (FWS 1999; Endangered mustard FWS 2008a). Ferns Trichomanes Florida bristle Suitable habitat (rockland hammocks, sinkhole Endangered punctatum ssp. fern habitats, and tree trunks that are in deep shade) floridanum occurs within the vicinity (Gann et al. 2018; NRC 2016a); Potential habitat onsite, although no known occurrences onsite (FPL 2018f). (a) SAT = Federally listed due to similarity of appearance to another listed species, Endangered = Federally listed as endangered, Threatened = Federally listed as threatened at 50 CFR Part 17, Endangered and Threatened Wildlife and Plants, under provisions of the Endangered Species Act Source: FWS 2018b 1 The FWS (FWS 2018b) identifies 23 animals that could occur within the Turkey Point action 2 area. Based on the information in Table 3-10, the NRC staff determined that the following six 3 species are extirpated from Miami-Dade County or are not known to occur within Miami-Dade 4 County and, therefore, the NRC will not consider these further within this SEIS: 5

• Florida grasshopper sparrow (Ammodramus savannarum) 6
• Florida scrub-jay (Aphelocoma coerulescens) 7
• ivory-billed woodpecker (Campephilus principalis) 8
• red-cockaded woodpecker (Picoides borealis) 9
• Bachman's warbler (Vermivora bachmani) 10
• Miami blue butterfly (Cyclargus (=Hemiargus) thomasi bethunebakeri) 11 The NRC staff also does not consider the following five species further within this SEIS because 12 no suitable habitat for these species occurs on the Turkey Point site, there are no known 13 occurrences of the species on site, and the species would not be expected to occur within the 14 action area given the lack of suitable habitat:

15

• Cape Sable seaside sparrow (Ammodramus maritimus mirabilis) 16
• Florida leafwing butterfly (Anaea troglodyta floridalis) 17
• Schaus swallowtail butterfly (Heraclides aristodemus ponceanus) 18
• Stock Island Tree Snail (Orthalicus reses) 19
• Bartram's hairstreak butterfly (Strymon acis bartrami) 20 The following two species are federally listed because of their similarity in appearance to a 21 federally listed endangered or threatened species. A species that is listed due to similarity of 22 appearance is not biologically endangered or threatened and is not subject to ESA Section 7 23 consultation. Therefore, this SEIS does not discuss further these two species:

24

• Puma (Puma concolor (all sub species except coryi)) which was listed for similarity in 25 appearance to the Florida panther (Puma concolor coryi) 26
• American alligator (Alligator mississippiensis) which was listed for similarity in 27 appearance to American crocodile (Crocodylus acutus) 3-109

1 The FWS (FWS 2018b) identifies 19 plant species that could occur within the action area. FPL 2 (FWS 2018f, FPL 2018n, FPL 2018g) is not aware of any federally listed endangered or 3 threatened plant species on the Turkey Point site. The NRC staff did not identify any known 4 occurrence of a federally listed plant species within the action area (FWS 1999, NRC 2016a, 5 FWS 2017a, Gann et al. 2018), although some species have been observed within the vicinity 6 of the action area and have the potential to occur onsite (FPL 2011b). The NRC staff also notes 7 that not all areas of the Turkey Point site have been surveyed for federally listed plants. Based 8 on this limited information, the NRC staff reviewed the habitat requirements for each of the 9 19 federally listed species in Table 3-10 to determine which plants have potential suitable 10 habitat within the action area. The NRC staff determined that the following 14 federally listed 11 plant species would not be expected to occur within the Turkey Point action area due to the lack 12 of suitable habitat or because the species has been extirpated from Miami-Dade County. 13

• crenulate lead-plant (Amorpha crenulata) 14
• Florida brickell-bush (Brickellia mosieri) 15
• deltoid spurge (Chamaesyce deltoidea ssp. deltoidea) 16
• pineland sandmat (Chamaesyce deltoidea pinetorum) 17
• Garber's spurge (Chamaesyce garberi) 18
• Okeechobee gourd (Cucurbita okeechobeensis ssp. okeechobeensis) 19
• Florida prairie-clover (Dalea carthagenensis floridana) 20
• Florida pineland crabgrass (Digitaria pauciflora) 21
• Small's milkpea (Galactia smallii) 22
• beach jacquemontia (Jacquemontia reclinata) 23
• Carter's small-flowered flax (Linum carteri carteri) 24
• tiny polygala (Polygala smallii) 25
• Everglades bully (Sideroxylon reclinatum ssp. austrofloridense) 26
• Carter's mustard (Warea carteri) 27 The remaining 15 federally listed species in Table 3-10 may occur within the action area. These 28 are:

29

• Florida bonneted bat (Eumops floridanus) 30
• Florida panther (Puma concolor coryi) 31
• West Indian manatee (Trichechus manatus) 32
• red knot (Caladris rufa) 33
• piping plover (Charadrius melodus) 34
• wood stork (Mycteria americana) 35
• Everglades snail kite (Rostrhamus sociabilis) 36
• Kirtland's warbler (Setophaga kirtlandi) 37
• American crocodile (Crocodylus acutus) 38
• eastern indigo snake (Drymarchon corais couperi) 39
• Blodgett's silverbush (Argythamnia blodgettii) 40
• Cape Sable thoroughwort (Chromolaena frustrata) 41
• Florida semaphore cactus (Consolea corallicola) 42
• sand flax (Linum arenicola) 43
• Florida bristle fern (Trichomanes punctatum ssp. floridanum) 44 The NRC staff evaluated the potential for the proposed action to affect these species in a 45 biological assessment (NRC 2018n) for the Turkey Point Units 3 and 4 subsequent license 3-110

1 renewal. The ESA Section 7 consultation history, life histories of these 15 species, and an 2 evaluation of impacts to the 15 species can be found in the biological assessment. The NRC 3 staff incorporates by reference that biological assessment (NRC 2018n) into this SEIS. 4 3.8.1.2 Species and Habitats under National Marine Fisheries Services Jurisdiction 5 No federally listed endangered or threatened species under the National Marine Fisheries 6 Services jurisdiction occur on the Turkey Point site itself. Five federally listed species under the 7 NMFSs jurisdiction may occur in Biscayne Bay adjacent to the Turkey Point site (see 8 Table 3-11). 9 Table 3-11 Federally Listed Endangered or Threatened Species Under National Marine 10 Fisheries Service Jurisdiction in Biscayne Bay Federally Distinct Population Listed Species Common Name Segment(s)(a) Status(b) Fish Pristis pectinata smalltooth sawfish United States Endangered Sea Turtles Caretta caretta loggerhead Threatened Chelonia mydas green North Atlantic and South Atlantic Threatened Dermochelys coriacea leatherback Endangered Eretmochelys imbricata hawksbill Endangered (a) Under the Endangered Species Act, a Distinct Population Segment is a vertebrate population or group of populations that is discrete from other populations of the species and significant in relation to the entire species. (b) Endangered = Federally listed as endangered and Threatened = Federally listed as threatened at 50 CFR Part 17, Endangered and Threatened Wildlife and Plants, under the provisions of the Endangered Species Act. Source: NMFS 2017a 11 In 2015, the NRC prepared a biological assessment for the above five species as well as other 12 species to assess the impacts of construction and operation of proposed new reactors Turkey 13 Point Units 6 and 7 (NRC 2015b). Section 5.0, Baseline Conditions for Aquatic Species, of the 14 staffs biological assessment for Turkey Point Units 6 and 7 contains life histories, habitat 15 requirements, status and distributions, factors contributing to the species decline, and the 16 occurrence and status in the project area of the smalltooth sawfish and four sea turtles identified 17 in Table 3-11 on the pages identified as follows: 18

• smalltooth sawfish (pages 5-15 to 5-18; Figure 5-4 and Figure 5-5) 19
• loggerhead sea turtle (pages 5-7 to 5-10; Figure 5-3; Table 5-3) 20
• green sea turtle (pages 5-5 to 5-7; Table 5-2) 21
• leatherback sea turtle (pages 5-12 to 5-13; Table 5-5) 22
• hawksbill sea turtle (pages 5-10 to 5-12; Table 5-4) 23 In that biological assessment, the NRC staff also identified sea turtle stranding information for 24 South Florida and in the vicinity of the Turkey Point site in the assessment (pages 5-1 to 5-5; 3-111

1 Figure 5-1 and Figure 5-2; Table 5-1). This information, as identified by page, table, and figure 2 numbers above, continues to accurately describe these species. Accordingly, the NRC staff 3 incorporates that information into this SEIS by reference. 4 Because there are no surface water connections between the CCS and any natural surface 5 water bodies, none of the species under the NMFSs jurisdiction occur in the CCS or on the 6 Turkey Point site itself. However, all five of the federally listed species may be present in 7 Biscayne Bay and are, therefore, considered to be present in the action area. Documented 8 occurrences of smalltooth sawfish in or near the Turkey Point action area are rare, and, if 9 present, would likely consist of juveniles using the near-shore mangrove communities to avoid 10 predation (NRC 2015b). Leatherback and hawksbill sea turtle stranding data indicate that these 11 species would also rarely occur in Biscayne Bay (NRC 2015b). Loggerhead and green sea 12 turtles are more likely to occur in Biscayne Bay based on stranding data, although occurrences 13 of these species within the Turkey Point action area itself are not particularly common 14 (NRC 2015b). 15 3.8.2 Species and Habitats Protected under the Magnuson-Stevens Act 16 The South Atlantic Fishery Management Council and the NMFS have designated Essential Fish 17 Habitat (EFH) pursuant to the Magnuson-Stevens Act for a number of federally managed 18 species within Biscayne Bay. During the NRC staffs environmental review for the Turkey Point 19 Units 6 and 7 combined license application, the NRC staff worked with the NMFS to identify 20 those species with EFH present near the Turkey Point site. Table 3-12 identifies these species, 21 the applicable fisheries management plan, and relevant EFH habitat designations. During the 22 preparation of this SEIS, the NRC staff confirmed through the NMFSs EFH Mapper that these 23 designations remain valid and that no new EFH has been designated in the vicinity of Turkey 24 Point since the staffs environmental review of the Turkey Point Units 6 and 7 combined license 25 application. 3-112

1 Table 3-12 Designated Essential Fish Habitat near the Turkey Point Site Essential Fish Habitat Applicable Designation(b) Common Fishery Species Seagrass and Name Management Plan(a) Mangrove Unconsolidated Bottom Farfantepenaeus pink shrimp Shrimp Fishery x x duorarum Haemulon plumieri white grunt Snapper- x Grouper Lutianus analis mutton Snapper- x snapper Grouper Lutjanus griseus gray snapper Snapper- x x Grouper Panulirus argus spiny lobster Spiny Lobster x x (a) The Fishery Management Councils and the NMFS designate EFH for federally managed species through fishery management plans. (b) Biscayne Bay and Biscayne National Park are also EFH Habitats of Particular Concern for coral, coral reefs, and hard-bottom communities. Sources: NMFS 201a, NRC 2015c, NRC 2016a, SAFMC and NMFS 2016a 2 In 2015, the NRC staff prepared an Essential Fish Habitat assessment to assess the impacts of 3 construction and operation of proposed Turkey Point Units 6 and 7 (NRC 2015c). Section 4.0, 4 EFH Species Life-History Information, of the staffs EFH assessment describes life histories, 5 habitat requirements, distributions, and population statuses of the five federally managed 6 species identified in Table 3-12 on the pages identified as follows: 7

• pink shrimp (pages 4-4 to 4-5) 8
• white grunt (page 4-3) 9
• mutton snapper (page 4-3) 10
• gray snapper (pages 4-1 to 4-2, Figure 4-1) 11
• spiny lobster (pages 4 3 to 4-4, Figure 4-2) 12 The NRC staff also described in its EFH assessment the applicable fishery management plans 13 for these species (page 3-2) and habitat areas of particular concern (page 3-3). This 14 information, as identified above, continues to accurately describe these species, and the NRC 15 staff therefore incorporates it into this SEIS by reference. The NRC staff addressed two 16 additional speciesbluestriped grunt (Haemulon sciurus) and dog snapper (Lutianus jocu) in 17 its 2015 EFH assessment. However, the South Atlantic Fishery Management Council and the 18 NMFS have since removed these species from the snapper-grouper complex (77 FR 15916, 19 81 FR 32249). Thus, the Snapper-Grouper Fishery Management Plan no longer identifies EFH 20 for these species.

21 While EFH for the species identified in Table 3-12 is designated in Biscayne Bay, neither EFH 22 nor the species themselves occur in the CCS or on the Turkey Point site because there are no 23 surface water connections between the CCS and any other natural surface water bodies. 3-113

1 3.9 Historic and Cultural Resources 2 This section describes the cultural background and the historic and cultural resources found at 3 Turkey Point and in the surrounding area. Section 106 of the National Historic Preservation Act 4 of 1966, as amended (NHPA) (54 U.S.C. 300101 et seq.), requires Federal agencies to 5 consider the effects of their undertakings on historic properties and afford the Advisory Council 6 on Historic Preservation an opportunity to review and comment on the undertaking. 7 Undertakings denote a broad range of Federal activities, including the issuance of NRC reactor 8 licenses and permits. Historic properties are defined as resources included on, or eligible for 9 inclusion on, the National Register of Historic Places (National Register). The criteria for 10 eligibility are listed in Title 36, Parks, Forest, and Public Property, of the Code of Federal 11 Regulations (36 CFR) Section 60.4, Criteria for evaluation, and include (1) association with 12 significant events in history, (2) association with the lives of persons significant in the past, 13 (3) embodiment of distinctive characteristics of type, period, or method of construction, and 14 (4) sites or places that have yielded, or are likely to yield, information important in prehistory or 15 history. 16 In accordance with 36 CFR 800.8(c), Use of the NEPA process for section 106 purposes, the 17 NRC complies with the obligation required under Section 106 of the NHPA through its 18 environmental review process under the National Environmental Policy Act of 1969, as 19 amended (NEPA) (42 U.S.C. 4321 et seq). In the context of the NHPA, the area of potential 20 effect (APE) for a license renewal action is the Turkey Point site and its immediate environs. 21 Turkey Point is located within the 9,460 ac (3,828 ha) FPL property. This property constitutes 22 the APE and consists primarily of developed land, open water, and wetlands. These land areas 23 may be impacted by continued maintenance and operations activities during the subsequent 24 license renewal term. The APE may extend beyond the immediate Turkey Point environs if 25 FPLs maintenance and operations activities affect offsite historic properties irrespective of land 26 ownership or control. 27 In accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort 28 to identify historic properties within the APE. The NRC is required to, in consultation with the 29 SHPO, determine and document the APE and identify historic properties within the APE. If the 30 NRC finds that either there are no historic properties within the APE or the undertaking 31 (subsequent license renewal) would have no effects on historic properties, the NRC provides 32 documentation of this finding to the State historic preservation officer. In addition, the NRC 33 notifies all consulting parties, including Indian tribes, and makes this finding public (through the 34 NEPA process) prior to issuing the renewed license. If historic properties are present and could 35 be affected by the undertaking, the NRC is required to assess and resolve any adverse effects 36 in consultation with the State historic preservation officer and any Indian Tribe that attaches 37 religious and cultural significance to identified historic properties. The Florida Division of 38 Historical Resources, within the Florida Department of State, is responsible for preserving and 39 promoting Floridas historical, archaeological, and folk culture resources. 40 3.9.1 Cultural Background 41 Humans have occupied the southern Florida region for about 12,000 years. The NRC staffs 42 EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176), Section 2.7.1 43 describes in detail the history of human occupation of the Turkey Point site and the surrounding 44 region (NRC 2016a). The NRC staff incorporates this prehistoric occupation description, 3-114

1 contained in pages 2-197 through 2-198 of NUREG-2176, into this SEIS by reference. 2 Prehistoric occupation of the area is divided into the following chronological sequence: 3

• Paleoindian Period (12,000-7,500 BC) 4
• Archaic Period (7,500-500 BC) 5
• Formative Period (500 BC -1513 AD) 6 The history of east coast Florida from European contact to the end of World War II is described 7 on pages 2-199 through 2-201 of NUREG-2176 (NRC 2016a). The NRC staff incorporates 8 these pages into this SEIS by reference. In brief, European arrival and contact with aboriginal 9 people of southern Florida occurred in 1513 when Spanish explorers arrived on Floridas 10 eastern coast. European colonization resulted in the loss of Tribal lands and the decline of 11 Native American populations. In 1821, Spain ceded Florida Territory to the United States, and 12 Florida was granted statehood in 1845. During World War I, several training facilities were set 13 up in the State of Florida. The States economy was boosted by the war, primarily through 14 shipbuilding and industrialization of port cities. During World War II, Florida became one of the 15 Nations major training grounds for various military branches, and the influx of thousands of 16 servicemen and their families increased industrial and agricultural production in Florida. With 17 the establishment of the Everglades National Park in 1947, tourism increased in the area and 18 became one of the major sources of the States economy. The NRC staff has identified no new 19 and significant information related to the cultural history of the Turkey Point region in its review 20 of FPLs environmental report submitted as part of the subsequent license renewal application 21 (FPL 2018f), during the onsite environmental audit at Turkey Point, or through the scoping 22 process, beyond the information in the EIS for Turkey Point Units 6 and 7.

23 3.9.2 Historic and Cultural Resources at Turkey Point 24 Historic and cultural resources in the vicinity of Turkey Point can include prehistoric era and 25 historic era archaeological sites, historic districts, and buildings, as well as any site, structure, or 26 object that may be considered eligible for listing on the National Register of Historic 27 Places (NRHP). Historic and cultural resources also include traditional cultural properties that 28 are important to a living community of people for maintaining their culture. Historic property is 29 the legal term for a historic or cultural resource that is included on, or eligible for inclusion on, 30 the NRHP. The staff notes that the vicinity of a site is not equivalent to an APE; rather, it is the 31 area within a 6-mi (9.6 km) radius of the plant, as explained in NUREG-1555, Supplement 1, 32 Rev. 1. 33 A cultural resource survey was not conducted on the FPL site prior to Turkey Points 34 construction (FPL 2018f). Construction of Turkey Point likely disturbed any historic and 35 archaeological resource that may have been located within its footprint. Approximately 36 28 percent (2,700 ac (1093 ha)) of the site is undeveloped and undisturbed (FPL 2018h). 37 Although no comprehensive cultural resource survey has been completed for the entire Turkey 38 Point site, several cultural resource studies of the site were conducted on portions of the site 39 between 2004 and 2013 (FPL 2018f, Janus 2009, FPL 2018h). FPL estimates that 40 approximately 10 percent of the Turkey Point site (approximately 950 ac (384 ha)) has been 41 surveyed collectively between these cultural resource surveys (FPL 2018h). These cultural 42 resource studies did not identify archeological sites or historic resources on the Turkey Point 43 site areas that were surveyed, and they concluded that the Turkey Point site has a low 44 archeological potential (FPL 2018f and Janus 2009). 3-115

1 During the NRC staffs environmental site audit, the NRC staff became aware of three wooden 2 buildings that were part of a Boy Scouts of America camp and a cottage (known as the Range 3 House/McGregor Smith Cottage) that are over 50 years old and could have potential historic 4 significance (FPL 2018h). The Boy Scout camp was constructed by FPL between 1962 and 5 1963 (FPL 2018m). After FPL completed construction of the cooling canals in the early 1970s, 6 the Boy Scout camp was no longer used for Boy Scout activities (FPL 2018m). FPL has 7 maintained and repaired the three wooden structures associated with the former Boy Scout 8 camp, and now uses these structures for storage (NRC 1972, FPL 2018h, FPL 2018m). Two of 9 these structures have gable roofs, and the third has a pyramid roof. Although they have not yet 10 been formally evaluated, FPL has indicated that the three structures do not appear to meet the 11 criteria for listing on the NRHP (FPL 2018h, FPL 2018m). 12 The Ranger House/McGregor Smith Cottage is a wood frame elevated structure supported by 13 large cylindrical wooden posts; the ground floor space and second level wraparound porch are 14 enclosed with screens (MDC 2018d). The structure was built sometime between 1965 and 15 1968 for the purposes of housing a full-time Florida Board of Conservation ranger (FPL 2018m). 16 The structure is named after McGregor Smith, one of Florida Power & Lights first presidents 17 (from 1939-1954), who later served as chief executive officer. According to FPL, McGregor 18 Smith is also known for his involvement with the Boy Scouts and southern Florida economic 19 development (FPL 2018h). Past use of the cottage included use as a meeting space during 20 construction of Turkey Point and as a construction office and fish camp during the 1980s. 21 During the 1990s, the cottage was renovated to make it a habitable residence for senior FPL 22 staff (FPL 2018m). In 2012, FPL contacted the Miami-Dade Countys Office of Historical 23 Resources to discuss designation of the Ranger House/McGregor Smith Cottage for historical 24 landmark status and potential restoration of the cottage. According to Miami-Dade Countys 25 Office of Historical Resources, McGregor Smith was an important figure in the history of the 26 Florida Power & Light Company and the cottage played a significant role in the early history of 27 the FPL power plant at Turkey Point and is worthy of saving for future staff use and as a vestige 28 of the flurry of activity that once took place in and around the power plant during the 1960s. 29 However, in 2012 when FPL contacted the Miami-Dade Countys Office of Historical Resources, 30 the Ranger House/McGregor Smith Cottage had not yet met the 50-year benchmark required 31 for consideration for eligibility for listing in the NRHP (MDC 2018d). As of the date of publication 32 of this SEIS, FPL has not evaluated the Ranger House/McGregor Smith Cottage for eligibility for 33 listing in the NRHP (FPL 2018h). 34 FPL conducted a desktop study of offsite cultural resources within the vicinity of Turkey Point. 35 Within a 6-mi (9.6 km) radius of the Turkey Point site, there are 95 known historic and cultural 36 resources. Of these, 28 resources are ineligible for listing, 65 resources have not been 37 evaluated for listing, and 2 resources have been determined eligible for listing in the NRHP 38 (FPL 2018f). 39 3.10 Socioeconomics 40 This section describes current socioeconomic factors that have the potential to be directly or 41 indirectly affected by changes in operations at Turkey Point. Turkey Point and the communities 42 that support it can be described as a dynamic socioeconomic system. The communities supply 43 the people, goods, and services required to operate the nuclear power plant. Power plant 44 operations, in turn, supply wages and benefits for people and dollar expenditures for goods and 45 services. The measure of a communitys ability to support Turkey Point operations depends on 46 the communitys ability to respond to changing environmental, social, economic, and 47 demographic conditions. 3-116

1 3.10.1 Power Plant Employment 2 The socioeconomic region of influence (ROI) is defined by the area where Turkey Point workers 3 and their families reside, spend their income, and use their benefits, thus affecting the economic 4 conditions of the region. Currently, FPL employs a permanent workforce of approximately 5 680 workers (FPL 2018f). Approximately 85 percent of this workforce resides in Miami-Dade 6 County (Table 3-13). The remaining workers are spread among 12 counties in Florida and 7 Georgia, with numbers ranging from 1 worker to 49 workers per county (FPL 2018f). In addition 8 to permanent Turkey Point plant employees, FPL hires contract workers to support plant 9 operations. In 2017, FPL employed 366 onsite contract workers; 80 percent of the contract 10 workers resided in Miami-Dade County. The number of contract workers employed each year 11 has remained relatively stable for the last 5 years with the exception of one year. In 2013, FPL 12 employed 763 onsite contract workers as a result of the extended power uprate for Turkey Point 13 (FPL 2018h). Since the majority of permanent workers (85 percent) and contract workers 14 (80 percent) reside in Miami-Dade County, the most significant socioeconomic effects of plant 15 operations are likely to occur in this county. The focus of the impact analysis and region of 16 influence, therefore, is on the socioeconomic impacts of continued Turkey Point operations 17 during the subsequent license renewal period on Miami-Dade County. 18 Table 3-13 Residence of Permanent Turkey Point Employees by County County Number of Employees Percentage of Total Total 679 100 Florida Broward 49 7 Miami-Dade 577 85 Monroe 40 6 Palm Beach 4 1 Other states and counties 9 1 Source: FPL 2018f 19 Refueling outages for Turkey Point Units 3 and 4 occur on a staggered 18-month schedule for 20 each unit and have historically lasted 25 to 35 days per unit. During refueling outages, onsite 21 employment typically increases by an additional 1,200 workers. As there are no subsequent 22 license renewal-related refurbishment activities, FPL has no plans to add additional employees 23 to support plant operations during the subsequent license renewal period (FPL 2018f). 24 3.10.2 Regional Economic Characteristics 25 This section presents information on employment and income in the Turkey Point 26 socioeconomic region of influence. 27 3.10.2.1 Regional Employment and Income 28 In 2016, the Miami-Dade County civilian labor force was approximately 1,370,950 individuals 29 (USCB 2016a). From 2011 to 2016, the labor force in Miami-Dade County increased by 30 5.6 percent (USCB 2016a and USCB 2011). From 2011 to 2016, the number of employed 31 people in Miami-Dade County increased by 14 percent. 3-117

1 According to the U.S. Census Bureaus (USCBs) 2016 American Community Survey 1-year 2 Estimates, educational services, and health care and social assistance represents the largest 3 employment sector in Miami-Dade County (approximately 20 percent), followed by professional, 4 scientific, and management, and administrative and waste management services 5 (approximately 13 percent). A list of employment by industry in Miami-Dade County is provided 6 in Table 3-14. Turkey Points permanent workforce residing in Miami-Dade County represents 7 approximately 0.04 percent of Miami-Dade Countys employed civilian labor force. Estimated 8 income information for the Miami-Dade County and Florida, for comparison, is presented in 9 Table 3-15. National parks in the vicinity of Turkey Point, such as Biscayne National Park and 10 the Everglades National Park, attract visitors that support economic activity. For instance, in 11 2017, Biscayne National Park and the Everglades National Park supported approximately 12 1,680 jobs and $65,319,000 in labor income (NPS 2018b). 13 Table 3-14 Employment by Industry in Miami-Dade County (2016 Estimates) Industry Miami-Dade County Percent Agriculture, forestry, fishing and hunting, and mining 9,929 0.8 Construction 103,636 8.0 Manufacturing 57,130 4.4 Wholesale trade 46,086 3.6 Retail trade 158,752 12.3 Transportation and warehousing and utilities 106,084 8.2 Information 23,941 1.9 Finance, insurance, real estate, rental, leasing 97,194 7.5 Professional, scientific, and administrative and waste 160,672 12.5 management services Educational services, and health care and social assistance 252,384 19.6 Arts, entertainment, recreation, accommodation and food services 149,588 11.6 Other services (except public administration) 79,895 6.2 Public administration 44,806 3.5 Total Employed Civilian Workers 1,290,097 Source: USCB 2016a 14 Table 3-15 Estimated Income Information for Miami-Dade County and Florida 15 (2016 Estimate) Miami-Dade County Florida Median household income (dollars)(a) 45,935 50,860 Per capita income (dollars)(a) 25,700 28,621 Families living below the poverty level (percent) 14.7 10.5 People living below the poverty level (percent) 18.3 14.7 (a) In 2016 inflation-adjusted dollars Source: USCB 2016a 3-118

1 3.10.2.2 Unemployment 2 According to the USCBs 2016 American Community Survey 1-Year Estimates, the 3 unemployment rate in Miami-Dade County was 5.9 percent (USCB 2016a). Comparatively, the 4 unemployment rate in the State of Florida in 2016 was 6.0 percent (USCB 2016b). 5 3.10.3 Demographic Characteristics 6 An estimated 702,557 people live within 20 mi (32 km) of Turkey Point, which equates to an 7 average population density of 559 persons per square mile (FPL 2018f). This translates to a 8 Category 4, Least sparse population density using NUREG-1437, Generic Environmental 9 Impact Statement for License Renewal of Nuclear Plants (NRC 1996) measure of sparseness 10 (greater than 120 persons per square mile within 20 mi). An estimated 3,472,804 people live 11 within a 50-mi (80-km) radius of Turkey Point, which equates to an average population density 12 of 442 persons per square mile. This translates to a Category 4, In close proximity measure of 13 proximity (greater than 190 persons per square mile within 50 mi) using NUREG-1437, Generic 14 Environmental Impact Statement for License Renewal of Nuclear Plants (NRC 1996). Both a 15 Category 4 measure of sparseness and proximity results in a High population category based 16 on Figure C.1 of the license renewal GEIS sparseness and proximity matrix (NRC 1996). "High" 17 population category corresponds to the least sparse population category and sites that are in 18 close proximity to large cities. Therefore, Turkey Point is located in a High population area 19 based on the license renewal GEIS sparseness and proximity matrix. As shown in Figure 3-1, 20 Turkey Point is located on the coast and much of the area within a 50-mi (80-km) radius around 21 the site consists of ocean and is unpopulated. Additionally, Everglades National Park, located 22 west of the site, is unpopulated (EPA 2019). The population living within a 50-mi (80-km) radius 23 of Turkey Point is primarily concentrated north, north-northeast, and north-northwest of Turkey 24 Point. 25 Table 3-16 shows population percent growth and projections from 1990 to 2060 in 26 Miami-Dade County. Over the last several decades, Miami-Dade County has experienced 27 increasing population. Based on population projections, the population in Miami-Dade County is 28 expected to continue to increase, but at a lower rate. 29 Table 3-16 Population and Percent Growth in Miami-Dade County 1990-2060 Miami Dade County Year Population Percent Change Since Prior Entry 1990 1,937,094 - 2000 2,253,362 16.3 2010 2,496,435 10.8 2016 2,712,945 8.7(a) 2020 2,872,760 15.1(a) 2030 3,215,054 11.9 2040 3,477,569 8.2 2050 3,811,933 9.6 2060 4,127,087 8.3 (a) Percent change from 2010 Source: Decennial population data for 1970-2010 (USCB 1996, USCB 2000a, USCB 2010a); Estimated population for 2016 (USCB 2016b); Projected population for 2020-2040 (BEBR 2017); Calculated projected population for 2050-2060. 3-119

1 The 2010 Census demographic profile of the Miami-Dade County population is presented in 2 Table 3-17. According to the 2010 Census (USCB 2010a), minorities (race and ethnicity 3 combined) comprised approximately 85 percent of the total population. The largest minority 4 population in Miami-Dade County was Hispanic or Latino of any race (65 percent of the total 5 population; 77 percent of the total minority population). For comparison, according to the 2010 6 Census, minorities comprised approximately 42 percent of the total state of Florida population 7 (USCB 2010b). 8 Table 3-17 Demographic Profile of the Population in Miami-Dade County in 2010 Miami-Dade County Total Population 2,496,435 Race (Percent of Total Population) White 73.8 Black or African American 18.9 American Indian and Alaska Native 0.2 Asian 1.5 Native Hawaiian and Other Pacific Islander 0 Some other race 3.2 Two or more races 2.4 Hispanic, Latino, or Spanish Ethnicity of Any Race Hispanic or Latino 1,623,589 Percent of total population 65.0 Minority Population (Including Hispanic or Latino Ethnicity) Total minority population 2,112,884 Percent minority 84.6 Source: USCB 2010a 9 According to the USCBs 2016 American Community Survey 1-Year Estimates, since 2010, 10 minority populations in the Miami-Dade County were estimated to have increased by 11 approximately 232,000 persons (see Table 3-18). The largest increases occurred in the 12 Hispanic or Latino population (nearly 212,000 person increases since 2010, an increase of 13 approximately 13 percent). According to the Census Bureau, minorities comprised 69 percent 14 of the total Miami-Dade County population in 1990 (USCB 1990). By 2000, the countys 15 minority population had increased to 79 percent of the population (USCB 2000b). 16 Table 3-18 Demographic Profile of the Population in Miami-Dade County, 2016 17 Estimates Miami-Dade County Total Population 2,712,945 Race (Percent of Total Population) White 74.5 Black or African American 17.6 American Indian and Alaska Native 0.2 Asian 1.6 3-120

Miami-Dade County Native Hawaiian and Other Pacific Islander 0 Some other race 4.6 Two or more races 1.6 Hispanic, Latino, or Spanish Ethnicity of Any Race Hispanic or Latino 1,835,412 Percent of total population 67.8 Minority Population (Including Hispanic or Latino Ethnicity) Total minority population 2,344,897 Percent minority 86.4 Source: USCB 2016b 1 3.10.3.1 Transient Population 2 Miami-Dade County can experience seasonal transient population growth as a result of local 3 tourism, recreational activities, or university attendance. For instance, in 2017, Biscayne Bay 4 National Park had approximately 447,000 visitors and Everglades National Park had 5 approximately 1,019,000 visitors (NPS 2017a). In 2016, approximately 200,800 students were 6 enrolled in college or graduate school in Miami-Dade County (USCB 2016c). A transient 7 population creates a demand for temporary housing and services in the area. 8 Based on USCBs 2016 American Community Survey 1-Year Estimates (USCB 2016d), 9 approximately 216,677 seasonal housing units are located in the four counties within a 10 50-mi (80-km) radius of Turkey Point (Miami-Dade, Monroe, Broward, and Collier counties). Of 11 those, 66,528 seasonal housing units are located in Miami-Dade County. Table 3-19 presents 12 information about seasonal housing for the counties all partly within the 50 mi (80 km) of Turkey 13 Point. The Greater Miami Convention and Visitors Bureau estimates that in 2018, 14 Miami-Dade County had 433 hotels/motels and approximately 55,450 rooms (GMCVB 2018). 15 Table 3-19 2016 Estimated Seasonal Housing in Counties Located Within 50 mi (80 km) 16 of Turkey Point Total Vacant Housing Units: for Percent Vacant Housing Total Vacant Seasonal, Recreational, Seasonal County Units Units or Occasional Use Housing Units Miami-Dade 1,021,650 140,884 66,528 6.5 Monroe 53,129 22,811 14,854 27.5 Broward 822,980 141,506 78,911 9.6 Collier 210,147 70,625 56,384 26.8 Total 2,107,906 375,826 216,677 Source: USCB 2016b and USCB 2016d 3-121

1 3.10.3.2 Migrant Farm Workers 2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 3 crops. These workers may or may not have a permanent residence. Some migrant workers 4 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 5 Migrant workers may be members of minority or low-income populations. Because they travel 6 and can spend a significant amount of time in an area without being actual residents, migrant 7 workers may be unavailable for counting by census takers. If uncounted, these minority and 8 low-income workers would be underrepresented in the decennial Census population counts. 9 Since 2002, the Census of Agriculture reports the numbers of farms hiring migrant workers 10 defined as a farm worker whose employment required travel that prevented the worker from 11 returning to his/her permanent place of residence the same day (USDA 2012). The Census of 12 Agriculture is conducted every 5 years and results in a comprehensive compilation of 13 agricultural production data for every county and parish in the Nation. 14 Information about both migrant and temporary farm labor (persons working less than 150 days) 15 can be found in the 2012 Census of Agriculture. Table 3-20 presents information on migrant 16 and temporary farm labor in the four counties within a 50-mi radius of Turkey Point. According 17 to the 2012 Census, 9,185 farm workers were hired to work for less than 150 days and were 18 employed on 1,073 farms in the 4 counties within 50-mi of Turkey Point. The county with the 19 highest number of temporary farm workers (4,480) on 63 farms was Collier County. 20 Approximately 125 farms in the 4 counties within 50-mi of Turkey Point reported hiring 21 approximately 3,590 migrant workers (USDA 2012). 22 Table 3-20 2012 Migrant Farm Workers and Temporary Farm Labor in Counties Located 23 within 50 mi of Turkey Point Number of Number of Farm Number of Farms Farms with Number of Farms Workers Working Reporting Hired Farm Hiring Workers for for Less Than Migrant Farm County Labor Less Than 150 Days 150 Days Labor Miami-Dade 1,318 836 3,850 106 Monroe 15 7 83 - Broward 234 167 772 7 Collier 104 63 4,480 12 Total 1,671 1,073 9,185 125 USDA 2012 24 3.10.4 Housing and Community Services 25 This section presents information regarding housing and local public services, including 26 education and water supply. 27 3.10.4.1 Housing 28 Table 3-21 lists the total number of occupied and vacant housing units, the housing vacancy 29 rates, and the median value of housing units in Miami-Dade County. Based on USCBs 2016 30 American Community Survey 1-year estimates (USCB 2016e), there were approximately 3-122

1 1,022,000 housing units in Miami-Dade County, of which approximately 881,000 were occupied. 2 The median value of owner-occupied housing units is $265,200. 3 Table 3-21 Housing in Miami-Dade County (2016) Miami-Dade County Total housing units 1,021,650 Occupied housing units 880,766 Total vacant housing units 140,884 Percent total vacant 13.8 Owner occupied units 446,018 Median value (dollars) $265,200 Owner vacancy rate (percent) 1.9 Renter occupied units 434,748 Median rent (dollars/month) 1,201 Rental vacancy rate (percent) 5.2 Source: USCB 2016e 4 3.10.4.2 Education 5 The Miami-Dade County Public School District is comprised of 472 schools and approximately 6 354,000 students. The Miami-Dade County Public School District is the fourth largest school 7 district in the United States (MDCPS 2018). The 2016-2017 Miami-Dade County Public School 8 District total revenue was $4,232 million, of which approximately 59 percent was from local 9 support (see discussion in Section 3.10.5, Tax Revenues) (MDCPS 2017a). 10 3.10.4.3 Public Water Supply 11 The Miami-Dade Water and Sewer Department is the main public water supplier in Miami-Dade 12 County. Miami-Dade County relies on groundwater withdrawn from the Biscayne aquifer and 13 Floridian aquifer (see Section 3.5.2.1 for detailed discussion of these two major aquifer 14 systems). Water is provided by the Miami-Dade Water and Sewer Department through four 15 regional water treatment plants: Hialeah and John E. Preston Water Treatment Plant, the 16 Hialeah Reverse Osmosis Water Treatment Plant, the Alexander Orr, Jr. Water Treatment 17 Plant, and the South Dade Water Supply System (which is comprised of five smaller water 18 treatment plants) (MDC 2014). The Newton Water Treatment Plant (part of the South Dade 19 Water Supply System) serves Turkey Point. In addition to the Miami-Dade Water and Sewer 20 Department, four water suppliers within Miami-Dade County provide water to parts of 21 unincorporated Miami-Dade County and within their municipal boundaries: the City of North 22 Miami, the City of North Miami Beach, Florida City, and City of Homestead. The capacity of 23 wellfields and the water treatment plant facilities installed capacity are presented in Table 3-22. 24 In 2013, the Miami-Dade Water and Sewer Department system population served was 25 2,222,944 and annual average daily demand was 302 mgd. Despite increases in population, 26 water use has decreased between 2004 and 2013 by 16 percent. Decrease in water use has 27 been attributed to Miami-Dade Countys water use efficiency legislation and implementation of 28 the Countys water conservation plan (MDC 2014). According to the Miami-Dade Water Supply 29 Facilities Work Plan (MDC 2014), when taking into consideration water conservation, by 2033, 3-123

1 annual average daily water demand in the Miami-Dade Water and Sewer Department service 2 area is projected to be 352 mgd (MDC 2014). 3 Table 3-22 Major Public Water Suppliers in Miami-Dade County Wellfield Supply Installed Treatment System Name Capacity (mgd) Facility Capacity (mgd) Population Served City of North Miami 14.96 9.30 91,000 City of North Miami-Beach 39.97 32.0 164,000 City of Homestead 16.99 16.9 65,000 Florida City 4 4 9,700 Miami-Dade Water and Sewer 634.01 497.19 2,223,000 Department Service Areas (Total) Hialeah-Preston Treatment Plant 295 225 Hialeah Reverse Osmosis Water 12 10 Treatment Plant Alexander Orr, Jr. Water Treatment 308 248 Plant South Dade Water Treatment Plants 19.01 14.19 (5 plants) (Total) Elevated Tank 4.32 - Everglades Labor 5.04 - Leisure City 4.18 - Naranja 1.15 - Newton 4.32 - mgd: millions of gallons per day Source: MDC 2014 4 3.10.5 Tax Revenues 5 The State of Florida does not have a State-level property tax. Private property owners pay 6 property taxes to the county and a local school district and may also pay taxes to regional taxing 7 districts. In Florida, real estate property and tangible personal property are subject to property 8 tax. Property values are set by the county property appraiser and are collected by the county 9 tax collector. The tax rate (millage) is set by each taxing unit. County and school district 10 governments may levy taxes up to 10 mills ($10.00 per thousand of assessed valuation) each. 11 As discussed below, FPL pays property taxes (real and tangible personal property) for Turkey 12 Point to Miami-Dade County, the Miami-Dade School District, and several regional taxing 13 districts (FPL 2018f). 14 The Miami-Dade County budget is comprised of appropriations from various revenues. The 15 total Miami-Dade County operating revenues for the years 2012 through 2017 are presented in 16 Table 3-23. Property taxes are a significant source of Miami-Dade County funding. For 17 instance, property tax revenues have ranged from 23 to 33 percent of the total Miami-Dade 18 County revenues between 2012 and 2017. Miami-Dade County property taxes fund four 19 separate taxing jurisdictions: Countywide, Unincorporated Municipality Service Area, the Fire 3-124

1 Rescue District, and the Library System. Each of the four taxing jurisdictions is responsible for 2 different types of services (MDC 2016b). For instance, the County-wide jurisdiction provides 3 public health and social services, transportation, regional parks, and county roads, the court 4 systems, and the regional sheriff services and jails. Additionally, Miami-Dade County also has a 5 countywide debt and a Fire Rescue District debt millage. The revenue raised from the debt 6 service millage pays outstanding debt for voter-approved general or special obligation bonds. 7 The amount of property tax received by a taxing jurisdiction is a result of the millage rate applied 8 by each county taxing jurisdiction. For 2017, the overall property tax millage rate was 9.7074 9 (MDC 2016b). 10 The Miami-Dade County Public School District is a taxing entity separate from Miami-Dade 11 County. The Florida Education Finance Program is the primary mechanism for funding the 12 operating costs of Florida school districts (FLDOE 2017). The Florida Education Finance 13 Program allocates funds to the Miami-Dade County Public School District based on student 14 enrollment (FHR 2010). Funding for school districts comes from State, local, and Federal 15 sources. Local funding is obtained primarily from property taxes levied by Floridas counties, 16 each of which constitutes a school district. Property taxes on properties located within the 17 school district are levied after the millage rate is certified. Table 3-23 presents the Miami-Dade 18 County School Board revenues for years 2012 through 2017. Property tax revenues provided 19 approximately 45 to 52 percent of the total Miami-Dade County School Board revenues for 20 years 2012 through 2017. 21 Miami-Dade County also imposes special district millage. These include the Childrens Trust 22 Authority, the Everglades Construction Project, the Okeechobee Basin, the South Florida Water 23 Management District, and the Florida Inland Navigation District (SFWMD 2011a). Fiscal Year 24 2016-2017 total special district millage for Miami-Dade County was 0.3627 (MDC 2016c). 25 Table 3-23 Miami-Dade County Total Operating Revenues, Miami-Dade County School 26 Board Revenues, and Florida Power & Light Turkey Point Property Tax 27 Payments (2012-2017) 2012 2013 2014 2015 2016 2017 Miami-Dade County Total Operating Revenues 5.399 5.375 5.423 5.612 5.792 4.865 (in billions of dollars) Miami-Dade County School Board Revenues 3.222 3.302 3.524 3.581 3.631 3.729 (in billions of dollars) Turkey Point total property tax paid (in millions 6.653 29.613 40.594 38.995 37.882 36.570 of dollars) Tax payment assigned to Miami-Dade County 3.446 15.280 21.108 20.394 20.229 19.858 (percent of total Miami-Dade County (0.06) (0.3) (0.3) (0.5) (0.4) (0.4) Revenues) Tax payment assigned to Miami-Dade County 2.834 12.792 17.374 16.665 15.796 14.957 School District (percent of total Miami-Dade (0.08) (0.4) (0.5) (0.5) (0.4) (0.4) County School Board Revenues) Tax payment assigned to special districts 0.372 1.629 2.070 1.911 1.856 1.755 Source: FPL 2018f, FPL 2018h, MDC 2015b, MDC 2016b, MDC 2017f, MDCPS 2017b 28 FPL pays property taxes (real and tangible personal property) for Turkey Point to Miami-Dade 29 County, the Miami-Dade County Public School District, and several regional taxing districts 30 (FPL 2018f). Turkey Point property tax payment for 2012-2017 are presented in Table 3-23. 3-125

1 The increase in property tax payment from 2012 to 2013 and from 2013 to 2014 is a result of 2 plant modifications conducted to support an extended power uprate and the lien date 3 (FPL 2018f and FPL 2018h). On June 15, 2012, the NRC granted a license amendment to FPL 4 for an extended power uprate of Turkey Point (NRC 2012). Plant modifications and upgrades 5 for the extended power uprate occurred in 2012 and 2013 and the valuation of the plant 6 upgrades conducted in one year become taxable in the following year. This resulted in the 7 Turkey Point property tax increases observed in 2013 and 2014. Turkey Point property tax 8 payments to Miami-Dade County and Miami-Dade County Public School District have 9 represented less than 1 percent of the Miami-Dade County revenue and of Miami-Dade County 10 Public School District tax revenues. FPL does not expect there to be a notable or significant 11 change to future property tax payments during the subsequent license renewal period 12 (FPL 2018f). 13 In addition to property tax payments, FPL pays sales tax to Miami-Dade County for purchases. 14 In 2017, FPL paid approximately $224,000 in sale taxes to Miami-Dade County from Turkey 15 Point operation expenses (FPL 2018h). FPL also contributes $1.5 million annually to 16 community organizations (FPL 2018h). 17 3.10.6 Local Transportation 18 The transportation network surrounding the Turkey Point site is comprised of U.S. highways, 19 Interstate highways, local streets, and waterways. There are no ports or rail systems located 20 within 6 mi (9.6 km) of the Turkey Point site. The nearest rail line, provided by 21 CSX Corporation, is located approximately 10 mi (16 km) west of the Turkey Point site in 22 Homestead, FL, and the Port of Miami is located approximately 23 mi (37 km) north of the site 23 (CSX 2018). The NRC staffs EIS for the Turkey Point Units 6 and 7 combined license 24 application (NUREG-2176) describes this transportation network in Section 2.5.2.3 25 (NRC 2016a); the NRC staff incorporates pages 2-175 through 2-178 of NUREG-2176 into this 26 SEIS by reference. 27 Access to the Turkey Point site is via East Palm Drive (SW 344 St). East Palm Drive is a 28 four-lane road that turns into a two-lane road at its intersection with Tallahassee Road 29 (SW 137th Avenue) as it leads to the Turkey Point site. East Palm Drive intersects with US-1 30 approximately 8 mi from the Turkey Point Site. East Palm Drive provides access to the 31 Homestead-Miami Speedway and Homestead Bayfront Park. Table 3-24 lists U.S. highways 32 and roads near Turkey Point and their average annual daily traffic (AADT) volumes. The 2017 33 average annual daily reported two-way traffic volume for the monitoring site closest to Turkey 34 Point on East Palm Drive was 9,800 vehicles. 35 Table 3-24 2017 Annual Average Daily Traffic in the Vicinity of Turkey Point Location Mile Marker Average Annual Daily Traffic Palm Drive (SW 344 St.) East of SW 132nd Ave Intersection 2.2 9,800 Intersection of Krome Ave (SW-177) 8.6 23,000 US-1 (South Dixie Highway) South of Palm Drive Intersection 0.3 32,500 S Krome Ave Intersection of Canal Dr (SW 328) 1.7 16,400 Source: FDOT 2017 3-126

1 3.11 Human Health 2 Turkey Point is both an industrial facility and a nuclear power plant. Similar to any industrial 3 facility or nuclear power plant, the operation of Turkey Point Units 3 and 4 over the subsequent 4 license renewal period will produce various human health risks for workers and members of the 5 public. This section describes the human health risks resulting from the operation of Turkey 6 Point Units 3 and 4, including from radiological exposure, chemical hazards, microbiological 7 hazards, electromagnetic fields, and other hazards. 8 3.11.1 Radiological Exposure and Risk 9 Operation of a nuclear power plant involves the use of nuclear fuel to generate electricity. 10 Through the fission process, the nuclear reactor splits uranium atoms resulting very generally in 11 (1) the production of heat which is then used to produce steam to drive the plants turbines and 12 generate electricity and (2) the creation of radioactive byproducts. As required by NRC 13 regulations at 10 CFR 20.1101, Radiation protection programs, FPL designed a radiation 14 protection program to protect onsite personnel (including employees and contractor employees), 15 visitors, and offsite members of the public from radiation and radioactive material at Turkey 16 Point. 17 The Turkey Point Units 3 and 4 radiation protection program is extensive and includes, but is 18 not limited to, the following: 19

• Organization and Administration (e.g., a radiation protection manager who is responsible 20 for the program and who ensures trained and qualified workers for the program) 21
• Implementing Procedures 22
• ALARA (as-low-as-is-reasonably-achievable) Program to minimize dose to workers and 23 members of the public 24
• Dosimetry Program (i.e., measure radiation dose of plant workers) 25
• Radiological Controls (e.g., protective clothing, shielding, filters, respiratory equipment, 26 and individual work permits with specific radiological requirements) 27
• Radiation Area Entry and Exit Controls (e.g., locked or barricaded doors, interlocks, local 28 and remote alarms, personnel contamination monitoring stations) 29
• Posting of Radiation Hazards (i.e., signs and notices alerting plant personnel of potential 30 hazards) 31
• Recordkeeping and Reporting (e.g., documentation of worker dose and radiation survey 32 data) 33
• Radiation Safety Training (e.g., classroom training and use of mockups to simulate 34 complex work assignments) 35
• Radioactive Effluent Monitoring Management (i.e., controlling and monitoring radioactive 36 liquid and gaseous effluents released into the environment) 37
• Radioactive Environmental Monitoring (e.g., sampling and analysis of environmental 38 media, such as direct radiation, air, water, groundwater, broad leaf vegetation, fish, 3-127

1 shellfish, and sediment to measure the levels of radioactive material in the environment 2 that may impact human health) 3

• Radiological Waste Management (i.e., controlling, monitoring, processing, and disposing 4 of radioactive solid waste) 5 Regarding radiation exposure to Turkey Point Units 3 and 4 personnel, the NRC staff reviewed 6 the data contained in NUREG-0713, Volume 38, Occupational Radiation Exposure at 7 Commercial Nuclear Power Reactors and other Facilities 2016: Forty-Ninth Annual Report 8 (NRC 2018h). The forty-ninth annual report was the most recent annual report available at the 9 time of this environmental review. It summarizes the NRCs Radiation Exposure Information 10 and Reporting System databases occupational exposure data through 2016. Nuclear power 11 plants are required by 10 CFR 20.2206, Reports of individual monitoring, to report their 12 occupational exposure data to the NRC annually. Chapter 4, Environmental Consequences 13 and Mitigating Actions, in this SEIS includes further discussion of radiological doses associated 14 with the Turkey Point Units 3 and 4 subsequent license renewal.

15 NUREG-0713 calculates a 3-year average collective dose per reactor for workers at all nuclear 16 power reactors licensed by the NRC. The 3-year average collective dose is one of the metrics 17 that the NRC uses in the Reactor Oversight Program to evaluate the applicants ALARA 18 program. Collective dose is the sum of the individual doses received by workers at a facility 19 licensed to use radioactive material over a 1-year time period. There are no NRC or EPA 20 standards for collective dose. Based on the data for operating pressurized-water reactors like 21 the ones at Turkey Point Units 3 and 4, the average annual collective dose per reactor was 22 42 person-rem. In comparison, Turkey Point Units 3 and 4 had a reported annual collective 23 dose per reactor of 45 person-rem. 24 In addition, as reported in NUREG-0713, for 2016, no worker at Turkey Point Units 3 and 4 25 received an annual dose greater than 0.75 rem (0.0075 sievert (Sv)), which is much less than 26 the NRC occupational dose limit of 5.0 rem (0.05 Sv) in 10 CFR 20.1201, Occupational dose 27 limits for adults. 28 Offsite dose to members of the public is discussed in Section 3.1.4, Radioactive Waste 29 Management Systems, of this SEIS. 30 3.11.2 Chemical Hazards 31 State and Federal environmental agencies regulate the use, storage, and discharge of 32 chemicals, biocides, and sanitary wastes. Such environmental agencies also regulate how 33 facilities like Turkey Point manage minor chemical spills. Chemical and hazardous wastes can 34 potentially impact workers, members of the public, and the environment. 35 FPL currently controls the use, storage, and discharge of chemicals and sanitary wastes at 36 Turkey Point Units 3 and 4 in accordance with its chemical control procedures, waste-37 management procedures, and Turkey Point site-specific chemical spill prevention plans. FPL 38 monitors and controls discharges of chemical and sanitary wastes through Turkey Point Unit 3 39 and 4s National Pollutant Discharge Elimination System permit process. These plant 40 procedures, plans, and processes are designed to prevent and minimize the potential for a 41 chemical or hazardous waste release and, in the event of such a release, minimize impact to 42 workers, members of the public, and the environment (FPL 2018f). 3-128

1 3.11.3 Microbiological Hazards 2 Nuclear power plants that discharge thermal effluents to cooling ponds, lakes, canals, or rivers 3 have the potential to promote the increased growth of thermophilic microorganisms, which could 4 result in adverse health effects for plant workers and the public. Microorganisms of particular 5 concern include several types of bacteria (Legionella spp., Salmonella spp., Shigella spp., and 6 Pseudomonas aeruginosa) and the free-living amoeba Naegleria fowleri, all of which require 7 freshwater environments. Because Turkey Point withdraws from and discharges to the CCS, 8 which is a saline environment, the above freshwater microorganisms are not a concern at 9 Turkey Point, and this SEIS provides no further discussion of them. Section 3.9.3.1 of the 10 license renewal GEIS (NUREG-1437) (NRC 2013a) provides additional background information 11 on these microorganisms. 12 3.11.4 Electromagnetic Fields 13 Based on its evaluation in the license renewal GEIS (NUREG-1437), the NRC has not found 14 electric shock resulting from direct access to energized conductors or from induced charges in 15 metallic structures to be a problem at most operating plants. Generally, the NRC staff also does 16 not expect electric shock from such sources to be a human health hazard during the 17 subsequent license renewal period. However, a site-specific review is required to determine the 18 significance of the electric shock potential along the portions of the transmission lines that are 19 within the scope of this SEIS. Transmission lines that are within the scope of the NRCs 20 subsequent license renewal environmental review are limited to: (1) those transmission lines 21 that connect the nuclear plant to the substation where electricity is fed into the regional 22 distribution system and (2) those transmission lines that supply power to the nuclear plant from 23 the grid (NRC 2013a). 24 As discussed in Section 3.1.6.5, Power Transmission Systems, of this SEIS, the only 25 transmission lines that are in scope for Turkey Point subsequent license renewal are onsite. 26 Specifically, these onsite, in-scope transmission lines are approximately 590 feet (180 m) and 27 connect Units 3 and 4 to the onsite 230-kV switchyard (FPL 2018f). Therefore, there is no 28 potential shock hazard to offsite members of the public from these onsite transmission lines. As 29 discussed in Section 3.11.5, Other Hazards, of this SEIS, Turkey Point maintains an 30 occupational safety program, which includes protection from acute electrical shock, and is in 31 accordance with Occupational Safety and Health Administration regulations. 32 3.11.5 Other Hazards 33 This section addresses two additional human health hazards: (1) physical occupational hazards 34 and (2) occupational electric shock hazards. 35 Nuclear power plants are industrial facilities that have many of the typical occupational hazards 36 found at any other electric power generation utility. Nuclear power plant workers may perform 37 electrical work, electric power line maintenance, repair work, and maintenance activities and 38 may be exposed to some potentially hazardous physical conditions (e.g., falls, excessive heat, 39 cold, noise, electric shock, and pressure). 40 The Occupational Safety and Health Administration (OSHA) is responsible for developing and 41 enforcing workplace safety regulations. Congress created OSHA by enacting the Occupational 42 Safety and Health Act of 1970, as amended (29 U.S.C. 651 et seq.) to safeguard the health of 43 workers. With specific regard to nuclear power plants, plant conditions that result in an 3-129

1 occupational risk, but do not affect the safety of licensed radioactive materials, are under the 2 statutory authority of OSHA rather than the NRC as set forth in a memorandum of 3 understanding (NRC 2013f) between the NRC and OSHA. Occupational hazards are reduced 4 when workers adhere to safety standards and use appropriate protective equipment; however, 5 fatalities and injuries from accidents may still occur. Turkey Point Units 3 and 4 maintain an 6 occupational safety program for its workers in accordance with OSHA regulations (FPL 2018f). 7 3.12 Environmental Justice 8 Under Executive Order (EO) 12898, Federal Actions to Address Environmental Justice in 9 Minority Populations and Low-Income Populations (59 FR 7629), Federal agencies are 10 responsible for identifying and addressing, as appropriate, disproportionately high and adverse 11 human health and environmental impacts on minority and low-income populations. Independent 12 agencies, such as the NRC, are not bound by the terms of EO 12898 but are, as stated in 13 paragraph 6-604 of the executive order, requested to comply with the provisions of [the] order. 14 In 2004, the Commission issued the agencys Policy Statement on the Treatment of 15 Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040), which 16 states, The Commission is committed to the general goals set forth in [EO] 12898, and strives 17 to meet those goals as part of its NEPA review process." 18 The Council on Environmental Quality (CEQ) provides the following information in its publication 19 Environmental Justice: Guidance Under the National Environmental Policy Act (CEQ 1997): 20 Disproportionately High and Adverse Human Health Effects. 21 Adverse health effects are measured in risks and rates that could result in latent 22 cancer fatalities, as well as other fatal or nonfatal adverse impacts on human 23 health. Adverse health effects may include bodily impairment, infirmity, illness, or 24 death. Disproportionately high and adverse human health effects occur when the 25 risk or rate of exposure to an environmental hazard for a minority or low-income 26 population is significant (as employed by NEPA) and appreciably exceeds the 27 risk or exposure rate for the general population or for another appropriate 28 comparison group (CEQ 1997). 29 Disproportionately High and Adverse Environmental Effects. 30 A disproportionately high environmental impact that is significant (as employed 31 by NEPA) refers to an impact or risk of an impact on the natural or physical 32 environment in a low-income or minority community that appreciably exceeds the 33 environmental impact on the larger community. Such effects may include 34 ecological, cultural, human health, economic, or social impacts. An adverse 35 environmental impact is an impact that is determined to be both harmful and 36 significant (as employed by NEPA). In assessing cultural and aesthetic 37 environmental impacts, impacts that uniquely affect geographically dislocated or 38 dispersed minority or low-income populations or American Indian tribes are 39 considered (CEQ 1997). 40 This environmental justice analysis assesses the potential for disproportionately high and 41 adverse human health or environmental effects on minority and low-income populations that 42 could result from the operation of Turkey Point Units 3 and 4 during the subsequent license 43 renewal period of extended operation. In assessing the impacts, the NRC staff used the 3-130

1 following definitions of minority individuals, minority populations, and low-income population 2 (CEQ 1997): 3 Minority Individuals 4 Individuals who identify themselves as members of the following population 5 groups: Hispanic or Latino, American Indian or Alaskan Native, Asian, Black or 6 African American, Native Hawaiian or Other Pacific Islander, or two or more 7 races, meaning individuals who identified themselves on a Census form as being 8 a member of two or more races, for example, White and Asian. In other words, 9 everyone except persons who identified themselves as White, Not Hispanic or 10 Latino are considered minority. 11 Minority Populations 12 Minority populations are identified when (1) the minority population of an affected 13 area exceeds 50 percent or (2) the minority population percentage of the affected 14 area is meaningfully greater than the minority population percentage in the 15 general population or other appropriate unit of geographic analysis. 16 Low-income Population 17 Low-income populations in an affected area are identified with the annual 18 statistical poverty thresholds from the Census Bureaus Current Population 19 Reports, Series P60, on Income and Poverty. 20 In determining the location of minority and/or low-income populations, the geographic 21 area used to perform a comparative analysis is a 50-mi (80-km) radius from the facility. 22 The 50-mi (80-km) radius is consistent with the impact analysis conducted for human 23 health impacts. The percentage of minority and/or low-income populations in the 50-mi 24 geographic area is compared to the percentage of minority and/or low-income 25 populations in each census block group to determine which block groups exceeds the 26 percentage, thereby identifying the location of these populations (NRC 2013c). 27 Minority Population 28 According to the Census Bureaus 2010 Census data, there are a total 2,152 block groups, and 29 approximately 78 percent of the population residing within a 50-mi (80-km) radius of Turkey 30 Point identified themselves as minority individuals (USCB 2010b). The largest minority 31 populations were Hispanic or Latino of any race (approximately 55 percent) followed by Black or 32 African American (approximately 19 percent). 33 According to the Council on Environmental Quality guidance, a minority population exists if the 34 percentage of the minority population of an area (e.g., census block group) exceeds 50 percent 35 or is meaningfully greater than the minority population percentage in the general population. In 36 this SEIS, the NRC staffs environmental justice analysis applied the meaningfully greater 37 threshold in identifying higher concentrations of minority populations. The meaningfully greater 38 threshold is any percentage greater than the minority population within the 50-mi radius. 39 Therefore, for the purposes of identifying higher concentrations of minority populations, census 40 block groups within the 50-mi (80-km) radius of Turkey Point were identified as minority 41 population block groups if the percentage of the minority population in the block group exceeded 3-131

1 78 percent, which is the percent of the minority population within the 50-mi (80-km) radius of 2 Turkey Point. 3 As shown in Figure 3-23, minority population block groups are notable and located throughout 4 the 50-mi (80-km) radius of Turkey Point. Based on this analysis, there are 1,247 minority 5 population block groups (using the meaningfully greater threshold of 78 percent minority 6 population) within the 50-mi (80-km) radius of Turkey Point and minority population block groups 7 are clustered around the cities of Miami, Miramar, Miami-Gardens, Hialeah, Homestead, Florida 8 City, and the Everglades census county subdivision. Turkey Point is located in a minority 9 population block group. 10 As presented in Section 3.10, Socioeconomics, of this SEIS, in 2010, the minority population 11 in Miami-Dade County was approximately 85 percent and the minority population in the State of 12 Florida was approximately 42 percent. According to the Census Bureaus 2016 American 13 Community Survey 1-Year Estimates, since 2010, minority populations in Miami-Dade County 14 have increased by approximately 232,000 persons. The largest increases occurred in the 15 Hispanic or Latino population (nearly 212,000 person increases since 2010, an increase of 16 approximately 13 percent). 17 Low-Income Population 18 The Census Bureaus 2012-2016 American Community Survey data identify approximately 19 18 percent of individuals residing within a 50-mi (80-km) radius of Turkey Point as living below 20 the Federal poverty threshold (USCB 2016f). The 2016 Federal poverty threshold was $24,563 21 for a family of four (USCB 2016g). 22 Figure 3-24 shows the location of predominantly low-income population block groups within a 23 50-mi (80-km) radius of Turkey Point. In accordance with NRC guidance (NRC 2013a), census 24 block groups were considered low-income population block groups if the percentage of 25 individuals living below the Federal poverty threshold within the block group exceeded 26 18 percent, which is the percent of the individuals living below the Federal poverty threshold 27 within the 50-mi (80-km) radius of Turkey Point. 28 As shown in Figure 3-24, low income population block groups are clustered in the cities of 29 Miami, Hialeah, and Fort Lauderdale, and in the Everglades and Homestead census county 30 subdivisions. Based on this analysis, there are 1,010 low-income population block groups 31 (approximately 50 percent of the block groups within 50 mi (80 km) of Turkey Point) and Turkey 32 Point is located in a low-income population block group. 33 As presented in Table 3-15, people living in Miami-Dade County (the socioeconomic region of 34 influence) have lower median household and per capita incomes than average for the State of 35 Florida and a higher percentage of families and people living below the poverty level. 3-132

1 Source: USCB 2010b 2 Figure 3-23 2010 CensusMinority Block Groups Within a 50-mi (80-km) Radius of 3 Turkey Point 3-133

1 Source: USCB 2016f 2 Figure 3-24 2012-2016, American Community Survey 5-Year EstimatesLow-Income 3 Block Groups Within a 50-mi (80-km) Radius of Turkey Point 3-134

1 3.13 Waste Management and Pollution Prevention 2 Like any operating nuclear power plant, Turkey Point Units 3 and 4 will produce both radioactive 3 and nonradioactive waste during the subsequent license renewal period. This section describes 4 waste management and pollution prevention at Turkey Point. 5 3.13.1 Radioactive Waste 6 As discussed in Section 3.1.4, Radioactive Waste Management Systems, of this SEIS, Turkey 7 Point uses liquid, gaseous, and solid waste processing systems to collect and treat, as needed, 8 radioactive materials produced as a byproduct of plant operations. Radioactive materials in 9 liquid and gaseous effluents are reduced prior to being released into the environment so that the 10 resultant dose to members of the public from these effluents is well within NRC and EPA dose 11 standards. Radionuclides that can be efficiently removed from the liquid and gaseous effluents 12 prior to release are converted to a solid waste form for disposal in a licensed disposal facility. 13 3.13.2 Nonradioactive Waste 14 Waste minimization and pollution prevention are important elements of operations at all nuclear 15 power plants. Licensees are required to consider pollution prevention measures as dictated by 16 the Pollution Prevention Act (Public Law 101-508) and the Resource Conservation and 17 Recovery Act of 1976, as amended (Public Law 94-580) (NRC 2013a). 18 As described in Section 3.1.5, Nonradioactive Waste Management System, Turkey Point has 19 a nonradioactive waste management program to handle nonradioactive waste in accordance 20 with Federal, State, and corporate regulations and procedures. Turkey Point maintains a waste 21 minimization program that uses material control, process control, waste management, recycling, 22 and feedback to reduce waste. 23 Turkey Point has a Stormwater Pollution Prevention Plan that identifies potential sources of 24 pollution that may affect the quality of stormwater discharges from permitted outfalls. The 25 Stormwater Pollution Prevention Plan also describes best management practices for reducing 26 pollutants in stormwater discharges and assure compliance with the sites Florida Department of 27 Environmental Protection permit. 28 Turkey Point also has a Spill Prevention, Control, and Countermeasure (SPCC) plan (see FPLs 29 environmental report for subsequent license renewal, Section 9.5.3.6) to monitor areas within 30 the site that have the potential to discharge oil into or upon navigable waters, in accordance with 31 the regulations in 40 CFR Part 112, Oil Pollution Prevention. The SPCC plan identifies and 32 describes the procedures, materials, equipment, and facilities that FPL uses to minimize the 33 frequency and severity of oil spills at Turkey Point. 34 Turkey Point is subject to EPA reporting requirements in 40 CFR Part 110, Discharge of Oil, 35 pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Under these 36 regulations, FPL must report to the National Response Center any discharges of oil if the 37 quantity may be harmful to the public health or welfare or to the environment. From 2012 38 through 2016, FPL reported no oil discharges that triggered the EPAs reporting requirements in 39 40 CFR Part 110. 40 Turkey Point is also subject to the reporting provisions of the Florida Administrative Code (FAC) 41 at 62-780.210, Contamination Reporting, concerning the discovery of petroleum or petroleum 3-135

1 products contamination or a discharge of petroleum or petroleum products, as well as other 2 FAC reporting requirements. Thus, the NRC staff expects that petroleum and petroleum 3 product spills would be reported to the appropriate regulatory authority. 4 The NRC staff issued two requests for additional information to FPL regarding reportable spills 5 at Turkey Point. In the first request, the NRC staff asked FPL to provide additional information 6 to the NRC as to whether there have been any reportable spills (discharge of oil) that may be 7 harmful, pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act, that occurred 8 after FPL wrote and submitted its environmental report for the subsequent license renewal 9 application. In its August 2018 response (FPL 2018b, NRC RAI Number: WM-1), FPL stated 10 that based on the listing of calls received by the U.S. Coast Guard National Response Center, 11 there have been no reportable spills triggering the 40 CFR Part 110 notification requirement at 12 Turkey Point since the ER was written (USCG 2018). 13 In its second request for additional information on reportable spills, the NRC staff asked FPL to 14 provide additional information to the NRC as to whether, after the environmental report was 15 written, there have been any reportable spills (discharge of oil) at Turkey Point that may have 16 had the potential to significantly pollute surface waters or groundwater and which were not 17 confined to a building or similar structure. FPL stated in its August 2018 response (FPL 2018g, 18 NRC RAI Number: WM-2) that there have been no reportable spills since the ER was 19 submitted. 3-136

1 4 ENVIRONMENTAL CONSEQUENCES AND 2 MITIGATING ACTIONS 3 4.1 Introduction 4 In this chapter, the U.S. Nuclear Regulatory Commission (NRC) staff evaluates the 5 environmental consequences of issuing subsequent renewed licenses authorizing an additional 6 20 years of operation for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point, or 7 Turkey Point Units 3 and 4). The NRC staffs evaluation of environmental consequences 8 includes the following: 9 1) impacts associated with continued operations similar to those impacts that have 10 occurred during the current renewed license term 11 2) impacts of various alternatives to the proposed action, including a no-action 12 alternative (not issuing the subsequent renewed licenses) and replacement power 13 alternatives (new nuclear; natural gas combined-cycle; and a combination of natural 14 gas and solar power) 15 3) impacts from the termination of nuclear power plant operations and decommissioning 16 after the subsequent license renewal term (with emphasis on the incremental effect 17 caused by an additional 20 years of reactor operation) 18 4) impacts associated with the uranium fuel cycle 19 5) impacts of postulated accidents (design-basis accidents and severe accidents) 20 6) cumulative impacts of the proposed action of issuing subsequent renewed licenses 21 for Turkey Point 22 7) resource commitments associated with the proposed action, including unavoidable 23 adverse impacts, the relationship between short-term use and long-term productivity, 24 and irreversible and irretrievable commitment of resources 25 8) new and potentially significant information on environmental issues related to the 26 impacts of operation during the subsequent license renewal term 27 In this chapter, the NRC staff also compares the environmental impacts of subsequent license 28 renewal with the environmental impacts of the no-action alternative and replacement power 29 alternatives to determine whether the adverse environmental impacts of subsequent license 30 renewal are so great that it would be unreasonable to preserve the option of subsequent license 31 renewal for energy-planning decisionmakers. Chapter 2, Alternatives Including the Proposed 32 Action, of this supplemental environmental impact statement (SEIS) describes in detail the 33 attributes of the proposed action (subsequent license renewal of Turkey Point) and the 34 no-action alternative. Chapter 2, Section 2.2.2, Replacement Power Alternatives, further 35 describes the NRC staffs process for developing a range of reasonable alternatives to the 36 proposed action and the replacement power alternatives that the staff selected for detailed 37 analysis in this chapter, including supporting assumptions and data. As noted in Chapter 2, 38 Table 2.1, the site location for various replacement power alternatives would be adjacent to 39 Turkey Point Units 3 and 4. Chapter 2, Table 2.2, summarizes the environmental impacts of the 40 proposed action and alternatives to the proposed action. 41 The affected environment (i.e., environmental baseline) for each resource area considered, and 42 against which the potential environmental impacts of the alternatives are measured, is 4-1

1 described in Chapter 3, Affected Environment. As documented in Chapter 3, the effects of 2 ongoing reactor operations at Turkey Point have become well established as environmental 3 conditions have adjusted to and reflect the presence of the nuclear power plant. 4 This SEIS documents the NRC staffs environmental review of the Turkey Point subsequent 5 license renewal application and supplements the information in NUREG-1437, Generic 6 Environmental Impact Statement for License Renewal of Nuclear Plants (also known as the 7 2013 GEIS) (NRC 2013a). The 2013 GEIS identifies 78 issues (divided into Category 1 and 8 Category 2 issues) to be evaluated for the proposed action in the environmental review process. 9 Section 1.4, Generic Environmental Impact Statement, of this SEIS provides an explanation of 10 the criteria for Category 1 issues (i.e., those issues generic to all nuclear power plants or a 11 distinct subset of plants) and Category 2 issues (i.e., those issues specific to individual nuclear 12 power plants) as well as the definitions of SMALL, MODERATE, and LARGE impact 13 significance. 14 For Category 1 issues, the NRC staff can rely on the analysis in the GEIS unless otherwise 15 noted. Table 4-1 lists the Category 1 (generic) issues that apply to Turkey Point during the 16 proposed subsequent license renewal period. For each Category 1 issue, the NRC staff 17 considered whether there is any new and significant information that might alter the conclusions 18 reached in the GEIS for that issue. As discussed in Section 4.14 of this SEIS, Regulatory Guide 19 (RG) 4.2, Supplement 1, Preparation of Environmental Reports for Nuclear Power Plant 20 License Renewal Applications (NRC 2013b), defines new and significant information as 21 (1) information that identifies a significant environmental impact issue that was not considered 22 or addressed in the GEIS and, consequently, not codified in Table B-1, in Appendix B to 23 Subpart A of 10 CFR Part 51, or (2) information not considered in the assessment of impacts 24 evaluated in the GEIS leading to a seriously different picture of the environmental 25 consequences of the action than previously considered, such as an environmental impact 26 finding different from that codified in Table B-1. For most issues, the NRC staff did not identify 27 any new and significant information during its review of Florida Power & Light Companys 28 (FPLs) environmental report, the site audits, or the scoping period that would change the 29 conclusions in the GEIS. Therefore, there are no impacts related to those Category 1 issues 30 beyond those already discussed in the GEIS. The staffs process for evaluating new and 31 significant information is described in Section 4.14, Evaluation of New and Significant 32 Information. 33 The NRC staff identified and evaluated new information for two existing Category 1 issues 34 (i.e., groundwater quality degradation (plants with cooling ponds in salt marshes) and cooling 35 system impacts on terrestrial resources (plants with once-through cooling systems or cooling 36 ponds)) and identified one new issue (i.e., water quality impacts on adjacent water bodies 37 (plants with cooling ponds in salt marshes)). The NRC staffs evaluation of these three issues is 38 presented in Sections 4.5.1.1, 4.5.1.2, and 4.6.1 of this SEIS. 39 Table 4-1 Applicable Category 1 (Generic) Issues for Turkey Point GEIS Issue Section Impact Land Use Onsite land use 4.2.1.1 SMALL Offsite land use 4.2.1.1 SMALL 4-2

GEIS Issue Section Impact Visual Resources Aesthetic impacts 4.2.1.2 SMALL Air Quality Air quality impacts (all plants) 4.3.1.1 SMALL Air quality effects of transmission lines 4.3.1.1 SMALL Noise Noise impacts 4.3.1.2 SMALL Geologic Environment Geology and soils 4.4.1 SMALL Surface Water Resources Surface water use and quality (non-cooling system impacts) 4.5.1.1 SMALL Discharge of metals in cooling system effluent 4.5.1.1 SMALL Discharge of biocides, sanitary wastes, and minor chemical spills 4.5.1.1 SMALL Effects of dredging on surface water quality 4.5.1.1 SMALL Groundwater Resources Groundwater contamination and use (non-cooling system impacts) 4.5.1.2 SMALL Groundwater quality degradation resulting from water withdrawals 4.5.1.2 SMALL Groundwater quality degradation (plants with cooling ponds in salt 4.5.1.2 SMALL(b) marshes)(a) Terrestrial Resources Exposure of terrestrial organisms to radionuclides 4.6.1.1 SMALL Cooling system impacts on terrestrial resources (plants with once- 4.6.1.1 SMALL through cooling systems or cooling ponds)(a) Bird collisions with plant structures and transmission lines 4.6.1.1 SMALL Transmission line right-of-way management impacts on terrestrial 4.6.1.1 SMALL resources(c) Electromagnetic fields on flora and fauna (plants, agricultural crops, 4.6.1.1 SMALL honeybees, wildlife, livestock) Aquatic Resources Entrainment of phytoplankton and zooplankton (all plants) 4.6.1.2 SMALL Infrequently reported thermal impacts (all plants) 4.6.1.2 SMALL Effects of cooling water discharge on dissolved oxygen, gas 4.6.1.2 SMALL supersaturation, and eutrophication Effects of non-radiological contaminants on aquatic organisms 4.6.1.2 SMALL Exposure of aquatic organisms to radionuclides 4.6.1.2 SMALL Effects of dredging on aquatic resources 4.6.1.2 SMALL Effects on aquatic resources (non-cooling system impacts) 4.6.1.2 SMALL Impacts of transmission line right-of-way management on aquatic 4.6.1.2 SMALL resources(c) Losses from predation, parasitism, and disease among organisms 4.6.1.2 SMALL exposed to sublethal stresses Socioeconomics Employment and income, recreation and tourism 4.8.1.1 SMALL Tax revenues 4.8.1.2 SMALL 4-3

GEIS Issue Section Impact Community services and education 4.8.1.3 SMALL Population and housing 4.8.1.4 SMALL Transportation 4.8.1.5 SMALL Human Health Radiation exposures to the public 4.9.1.1.1 SMALL Radiation exposures to plant workers 4.9.1.1.1 SMALL Human health impact from chemicals 4.9.1.1.2 SMALL Microbiological hazards to plant workers 4.9.1.1.3 SMALL Physical occupational hazards 4.9.4.1.5 SMALL Postulated accidents Design-basis accidents 4.9.1.2 SMALL Waste Management Low-level waste storage and disposal 4.11.1.1 SMALL Onsite storage of spent nuclear fuel 4.11.1.2 SMALL Offsite radiological impacts of spent nuclear fuel and high-level 4.11.1.3 (d) waste disposal Mixed-waste storage and disposal 4.11.1.4 SMALL Nonradioactive waste storage and disposal 4.11.1.4 SMALL Uranium Fuel Cycle Offsite radiological impactsindividual impacts from other than the 4.12.1.1 SMALL disposal of spent fuel and high-level waste Offsite radiological impactscollective impacts from other than the 4.12.1.1 (e) disposal of spent fuel and high-level waste Nonradiological impacts of the uranium fuel cycle 4.12.1.1 SMALL Transportation 4.12.1.1 SMALL Termination of Nuclear Power Plant Operations and Decommissioning Termination of plant operations and decommissioning 4.12.2.1 SMALL 4-4

GEIS Issue Section Impact (a) The environmental impact of this issue includes consideration of site-specific new information for Turkey Point. (b) The NRC staff recognizes that the current impacts on this issue are greater than SMALL (i.e., the impacts are MODERATE). However, as discussed in Section 4.5.1.2 of this chapter, in response to a 2015 consent agreement with the Miami-Dade County Department of Environmental Resource Management (DERM) (MDC 2015a) and a 2016 consent order from the Florida Department of Environmental Protection (FDEP) (FDEP 2016e), FPL has implemented a recovery well system to halt and retract the hypersaline plume and to abate and remediate the effects of the hypersaline plume from the cooling canal system. These efforts are expected to remediate the hypersaline plume prior to the commencement of the subsequent license renewal term. In addition, FPLs actions to remediate the plume are subject to continued regulatory oversight by the DERM and the FDEP. Therefore, the NRC staff expects that groundwater quality degradation impacts resulting from subsequent license renewal will be SMALL. (c) This issue applies only to the in-scope portion of electric power transmission lines, which are defined as transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional power distribution system and transmission lines that supply power to the nuclear plant from the grid. (d) The environmental impact of this issue for the time frame beyond the licensed life for reactor operations is contained in NUREG-2157, the NRCs Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NRC 2014c). (e) There are no regulatory limits applicable to collective doses to the general public from fuel-cycle facilities. The practice of estimating health effects on the basis of collective doses may not be meaningful. All fuel-cycle facilities are designed and operated to meet the applicable regulatory limits and standards. The Commission concludes that the collective impacts are acceptable. The Commission concludes that the impacts would not be sufficiently large to require the National Environmental Policy Act (NEPA) conclusion, for any plant, that the option of extended operation under Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the collective impacts of the uranium fuel cycle, this issue is considered Category 1. Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 and NRC 2013a 1 The NRC staff analyzed the Category 2 (site-specific) issues applicable to Turkey Point during 2 the proposed subsequent license renewal period and assigned impacts to these issues as 3 shown below in Table 4-2. 4 Table 4-2 Applicable Category 2 (Site-Specific) Issues for Turkey Point Issue GEIS Section Impact(a) Groundwater Resources Groundwater use conflicts (plants that withdraw more than 4.5.1.2 SMALL to MODERATE 100 gallons per minute (gpm)) Radionuclides released to groundwater 4.5.1.2 SMALL Terrestrial Resources Effects on terrestrial resources (non-cooling system impacts) 4.6.1.1 SMALL Aquatic Resources Impingement and entrainment of aquatic organisms (plants 4.6.1.2 SMALL to with once-through cooling systems or cooling ponds) MODERATE(b) 4-5

Issue GEIS Section Impact(a) Thermal impacts on aquatic organisms (plants with 4.6.1.2 SMALL to once-through cooling systems or cooling ponds) MODERATE(b) Special Status Species and Habitats Threatened, endangered, and protected species and 4.6.1.3 Impact determinations essential fish habitat vary by species and habitat(c) Historic and Cultural Resources Historic and cultural resources 4.7.1 would not adversely affect known historic properties or historic and cultural resources Human Health Chronic effects of electromagnetic fields(d) 4.9.1.1.1 Uncertain Impact Electric shock hazards 4.9.1.1.1 SMALL Postulated Accidents Severe accidents 4.9.1.2 SMALL Environmental Justice 4.10.1 no disproportionately Minority and low-income populations high and adverse human health and environmental effects Cumulative Impacts Cumulative impacts 4.13 See SEIS Section 4.16 (a) Impact determinations for Category 2 issues are based on findings described in Sections 4.2 through 4.13 of this SEIS for the proposed action. (b) The conclusion of SMALL to MODERATE applies to aquatic resources in the cooling canal system. Aquatic organisms inhabiting Biscayne Bay and connected waterbodies (e.g., Card Sound, the Atlantic Ocean) are not subject to impingement and entrainment because they do not interact with the Turkey Point intake structure, and there are no thermal effects outside the cooling canal system because there are no surface water connections that allow flow between the waters of Biscayne Bay and the cooling canal system. (c) The NRC staff concludes that Turkey Point subsequent license renewal is likely to adversely affect the American crocodile and the eastern indigo snake, and may result in adverse modification to designated critical habitat of the American crocodile. The proposed action may affect, but is not likely to adversely affect, the Florida bonneted bat, Florida panther, West Indian manatee, red knot, piping plover, wood stork, Everglades snail kite, Kirtlands warbler, Blodgetts silverbush, Cape Sable thoroughwort, Florida semaphore cactus, sand flax, Florida bristle fern, loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and smalltooth sawfish. The proposed action would result in no adverse modification to designated critical habitat of the West Indian manatee. The proposed action would have no adverse effects on Essential Fish Habitat. The NRC staffs evaluation of impacts to species and habitats under the U.S. Fish and Wildlife Services jurisdiction can be found in the NRCs Biological Assessment (NRC 2018n). The evaluation of impacts to species and habitats under the National Marine Fisheries Services jurisdiction can be found in Section 4.8 of this SEIS. (d) This issue was not designated as Category 1 or Category 2 and is discussed in Section 4.11.1, Proposed Action. Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 and NRC 2013a 4-6

1 4.2 Land Use and Visual Resources 2 This section describes the potential land use and visual resources impacts of the proposed 3 action (subsequent license renewal) and alternatives to the proposed action. 4 4.2.1 Proposed Action 5 According to the GEIS (NRC 1996 and NRC 2013a), land use and visual resources would not 6 be affected by continued operations and refurbishment associated with license renewal. In 7 addition, nuclear plant operations at Turkey Point have not changed appreciably with time, and 8 no change in land use and visual resources impacts are expected during the subsequent 9 license renewal term. The NRC staff identified no new or significant information for these 10 issues. 11 In this regard, no new or significant information was identified during the review of FPLs 12 environmental report, the NRC staffs site visit, the scoping process, or the evaluation of other 13 available information. The communities in the vicinity of Turkey Point have pre-established 14 patterns of development and have adequate public services to support and guide development. 15 Consequently, people living in the vicinity of Turkey Point would not experience any land use or 16 visual changes during the subsequent license renewal term beyond what has already been 17 experienced. In addition, no adverse effects on offsite land use will occur related to the 18 Everglades Restoration Project (conducted under the Comprehensive Everglades Restoration 19 Plan (CERP)) or other Federal action in the proposed project area. Therefore, the land use and 20 visual impacts of continued reactor operations during the subsequent license renewal term 21 would not exceed the land use and visual impacts predicted in the GEIS. For these issues, the 22 GEIS predicted that the impacts would be SMALL for all nuclear plants. 23 As identified in Table 4-1, the impacts of all generic land use or visual resource issues would be 24 SMALL. Table 4-2 does not identify any site-specific (Category 2) land use or visual resource 25 issues. 26 4.2.2 No-Action Alternative 27 4.2.2.1 Land Use 28 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 29 Turkey Point Units 3 and 4 would shut down on or before the expiration of the current renewed 30 operating licenses (i.e., 2032 and 2033). Under this alternative, land uses would remain similar 31 to those that would occur under the proposed subsequent license renewal except that land 32 could be converted to other uses sooner if Turkey Point is shut down in 2032 and 2033 instead 33 of operating for an additional 20 years. Shutdown of Turkey Point under the no-action 34 alternative thus would not affect onsite land use. Plant structures and other facilities would 35 remain in place until decommissioning. Most transmission lines would remain in service after 36 the plant stops operating. Maintenance of most existing infrastructure would continue as before. 37 Therefore, land use impacts from the termination of Turkey Point Unit Nos. 3 and 4 nuclear 38 plant operations would be SMALL. 39 4.2.2.2 Visual Resources 40 Shutdown of Turkey Point under the no-action alternative would not significantly change the 41 visual appearance of the Turkey Point site. At the Turkey Point site, the reactor and turbine 4-7

1 buildings are the buildings that create the largest visual impact. Under the no-action alternative, 2 the reactor and turbine buildings would likely remain in place for some time but would eventually 3 be dismantled. This would reduce the visual impact. Overall, visual impacts from the 4 termination of Turkey Point Unit Nos. 3 and 4 nuclear plant operations would be SMALL. 5 4.2.3 Replacement Power Alternatives: Common Impacts 6 4.2.3.1 Land Use 7 The NRC staffs analysis of land use impacts focuses on the amount of land area that would be 8 affected by the construction and operation of a replacement power plant. 9 Construction 10 Construction would require the permanent commitment of land zoned for industrial use at the 11 Turkey Point site for replacement power plants and associated infrastructure. Existing Turkey 12 Point transmission lines and infrastructure would adequately support each of the replacement 13 power alternatives, thus reducing the need for additional land commitments. 14 Operations 15 Operation of new power plants would have no land use impacts beyond land committed for the 16 permanent use of the replacement power plant. Additional land may be required to support 17 power plant operations including land for mining, extraction, and waste disposal activities 18 associated with each alternative. 19 4.2.3.2 Visual Resources 20 The NRC staffs visual impact analysis focuses on the degree of contrast between the 21 replacement power plant and the surrounding landscape and the visibility of the new power 22 plant. 23 Construction 24 Land for any replacement power plant would require clearing, excavation, and the use of 25 construction equipment. Temporary visual impacts may occur during construction from cranes 26 and other construction equipment. 27 Operations 28 Visual impacts during plant operations of any of the replacement power alternatives would be 29 similar in type and magnitude. New cooling towers (if built) and their associated plumes would 30 be the most obvious visual impact and would likely be visible farther from the site than other 31 buildings and infrastructure. New plant stacks may require aircraft warning lights, which would 32 be visible at night. 4-8

1 4.2.4 New Nuclear Alternative 2 4.2.4.1 Land Use 3 Construction 4 Approximately 360 acres (ac) (150 hectares (ha)) of land would be needed to construct a new 5 nuclear power plant. Although there is sufficient land available at the Turkey Point site, some 6 wetlands may be temporarily displaced during construction. Land use impacts during 7 construction would be SMALL at the Turkey Point site since the land is already zoned for 8 industrial use. 9 Operations 10 Offsite land use impacts associated with uranium mining and fuel fabrication needed to support 11 nuclear power plant operations would generally be no different from the amount of land needed 12 to support Turkey Point Units 3 and 4 operations, although more land would be required for 13 mining additional uranium for up to 40 years of operation. Based on this information, onsite and 14 offsite land use impacts from constructing and operating a new nuclear power plant could range 15 from SMALL to MODERATE depending on how much additional land may be needed for 16 uranium mining and fuel fabrication. 17 4.2.4.2 Visual Resources 18 Construction and Operations 19 Visual impacts from a new nuclear alternative would be similar to the common impacts of all 20 replacement power alternatives described in Section 4.2.3.2, Visual Resources. The visual 21 appearance of the power block for the new nuclear power plant would be virtually identical to 22 the existing Turkey Point Units 3 and 4 power blocks. Mechanical draft cooling towers and 23 associated condensate plumes would add to the visual impact. However, the height of the 24 mechanical draft cooling towers would not likely exceed those of other buildings at the Turkey 25 Point site. Therefore, visual impacts during the construction and operation of a new nuclear 26 power plant at the Turkey Point site, including steam plumes that could be visible from great 27 distances, could range from SMALL to MODERATE depending on seasonal weather conditions. 28 4.2.5 Natural Gas Combined-Cycle Alternative 29 4.2.5.1 Land Use 30 Construction 31 The natural gas combined-cycle (NGCC or natural gas) power plant would require 75 ac (30 ha) 32 of land with up to an additional 1,200 ac (490 ha) needed for right-of-way to connect with 33 existing natural gas supply lines located approximately 100 miles (mi) (161 kilometers (km)) 34 north of the Turkey Point site. No new gas wells would be needed to support a natural gas 35 power plant (FPL 2018f). This land use impact would be partially offset by the elimination of 36 land used for uranium mining to supply fuel to Turkey Point Units 3 and 4. Land use impacts 37 caused by uranium mining and natural gas extraction and collection are described in 38 Section 4.15.1, Fuel Cycle. 4-9

1 Constructing the natural gas power plant at the Turkey Point site would make use of available 2 infrastructure. In addition, the land is already zoned for industrial use. However, some natural 3 areas could be converted to industrial use if portions of the new power plant are built outside the 4 existing industrial footprint. Although this use of the land would be noticeable, construction 5 would not likely destabilize adjacent land use, due to the current industrial nature of the Turkey 6 Point site. Accordingly, construction impacts could have SMALL to MODERATE land use 7 impacts. This is primarily due to the amount of non-industrially zoned land that could be 8 affected by this alternative. 9 Operations 10 Operation of a natural gas power plant would not cause any additional land use changes; 11 therefore, land use impacts during operations would be SMALL. Overall land use impacts of the 12 natural gas combined-cycle alternative, including both construction and operation, would 13 therefore range from SMALL to MODERATE. 14 4.2.5.2 Visual Resources 15 Construction and Operations 16 Visual impacts from a natural gas power plant would be similar to the description in 17 Section 4.2.3.2, Visual Resources, for the common impacts from all replacement power 18 alternatives. However, construction and operation of the natural gas power plant would have 19 little to no additional visual impact. The height of the mechanical draft cooling towers would not 20 likely exceed those of other buildings at the Turkey Point site. Therefore, visual impacts during 21 the construction and operation of a new NGCC facility at the Turkey Point site, including steam 22 plumes that could be visible from great distances, could range from SMALL to MODERATE 23 depending on seasonal weather conditions. 24 4.2.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 25 Generation) 26 4.2.6.1 Land Use 27 Construction and Operations 28 The natural gas power plant component of the combination alternative would require somewhat 29 less land than the full-scale natural gas power plant described in Section 4.2.5.1. The natural 30 gas power plant component would require 70 ac (28 ha) of land with up to an additional 31 1,200 ac (490 ha) needed for right-of-way to connect with existing natural gas supply lines 32 located approximately 100 mi (161 km) north of the Turkey Point site. No new gas wells would 33 be needed to support a natural gas power plant (FPL 2018f). Accordingly, land use impacts 34 would be similar to or less than those described for the full-scale natural gas power plant 35 alternative. However, the impacts could still range from SMALL to MODERATE. 36 A utility-scale solar photovoltaic (solar) facility would require approximately 470 ac (190 ha) of 37 cleared land for the three proposed offsite solar power installations (FPL 2018f). Standalone 38 solar facilities cannot be collocated with other land uses (such as grazing and crop-producing 39 agricultural fields). Land use impacts would range from MODERATE to LARGE, depending on 40 the amount and types of land uses that would be affected by construction of the four solar 41 facilities. 4-10

1 Overall land use impacts of this combination natural gas and solar alternative would therefore 2 range from SMALL to LARGE. This is primarily due to the amount and types of land uses that 3 would be affected by the solar facilities. 4 4.2.6.2 Visual Resources 5 Construction and Operations 6 Visual impacts from the combination natural gas and solar alternative would be similar to the 7 common impacts described in Section 4.2.3.2, Visual Resources, for all replacement 8 alternatives. However, construction and operation of the natural gas power plant would have 9 little to no additional visual impact. The height of the mechanical draft cooling towers would 10 likely not exceed those of other buildings at the Turkey Point site. Visual impacts of the natural 11 gas component would be similar to the impacts described in Section 4.2.5.2. 12 The visual impacts of the solar components of this alternative would vary, depending on location 13 and topography. Depending on the location, standalone solar facilities could have a 14 MODERATE to LARGE visual impact. Visual resource impacts of the combination alternative 15 could therefore range from SMALL to LARGE. This range is primarily due to the potential visual 16 impacts from the solar photovoltaic components of this alternative. 17 4.2.7 Cooling Water System Alternative 18 4.2.7.1 Land Use 19 Construction and Operations 20 Construction of two mechanical draft cooling towers for a cooling water system alternative could 21 require the relocation of existing support activities at the Turkey Point site. Because only 22 previously disturbed industrial portions of the Turkey Point site would be used to accommodate 23 the new cooling towers, land use impacts associated with the construction and operation of the 24 mechanical draft cooling towers for the cooling water system alternative would be SMALL. 25 4.2.7.2 Visual Resources 26 Construction and Operations 27 Construction and operation of the two cooling towers for a cooling water system alternative 28 would have little to no additional visual impact. The height of the mechanical draft cooling 29 towers would be similar to the height of other buildings at the Turkey Point site. Temporary 30 visual impacts may occur during construction from cranes and other construction equipment. 31 During facility operations, cooling tower steam plumes could add to the existing visual impact. 32 Therefore, visual impacts during the construction and operation of two new cooling towers at the 33 Turkey Point site, including steam plumes that could be visible from great distances, could 34 range from SMALL to MODERATE depending on seasonal weather conditions. 35 4.3 Air Quality and Noise 36 This section describes the potential air quality and noise impacts of the proposed action 37 (subsequent license renewal) and alternatives to the proposed action. 4-11

1 4.3.1 Proposed Action 2 4.3.1.1 Air Quality 3 According to the GEIS (NRC 1996 and NRC 2013a), the generic issues related to air quality as 4 identified in Table 4-1 above would not be affected by continued operations associated with 5 license renewal. As discussed in Chapter 3, the NRC staff identified no new and significant 6 information for these issues. Thus, as concluded in the GEIS, the impacts of those generic 7 issues related to air quality would be SMALL. Table 4-2 does not identify any site-specific 8 (Category 2) air quality issues for Turkey Point Units 3 and 4. 9 4.3.1.2 Noise 10 According to the GEIS (NRC 1996 and NRC 2013a), noise has not been found to be a problem 11 at operating plants and is not expected to be a problem at any plant during the subsequent 12 license renewal term. In addition, nuclear plant operations at Turkey Point Units 3 and 4 have 13 not changed appreciably with time, and no change in noise levels or noise-related impacts are 14 expected during the subsequent license renewal term. 15 The NRC staff identified no new or significant information during its review of the FPL 16 environmental report, at the site visit, through the scoping process, or in the evaluation of other 17 available information. Consequently, people living in the vicinity of Turkey Point Units 3 and 4 18 would not experience any changes in noise levels during the subsequent license renewal term 19 beyond what is currently being experienced. Therefore, the impact of continued reactor 20 operations during the subsequent license renewal term would not exceed the noise impacts 21 predicted in the GEIS. For these issues, the GEIS predicts that noise impacts would be SMALL 22 for all nuclear plants. 23 As identified in Table 4-1, the impacts of all generic noise issues would be SMALL. Table 4-2 24 does not identify any site-specific (Category 2) noise issues for Turkey Point Units 3 and 4. 25 4.3.2 No-Action Alternative 26 4.3.2.1 Air Quality 27 Under the no-action alternative, there would be a reduction in air pollutant emissions from 28 activities related to the cessation of Turkey Point operations, such as the use of combustion 29 sources (diesel generators, engines) and vehicle traffic. Activity from these air emission 30 sources would not cease, but emissions would be lower. Therefore, the NRC staff concludes 31 that if emissions decrease, the impact on air quality from the shutdown of Turkey Point would be 32 SMALL 33 4.3.2.2 Noise 34 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 35 reactor operations at Turkey Point Units 3 and 4 would shut down on or before the expiration of 36 the current renewed operating licenses. The termination of reactor operations would result in a 37 reduction in noise sources throughout the nuclear facility, including noise from turbine 38 generators, machinery, pumps, and other noise-generating equipment, and some vehicular 39 traffic. Therefore, noise impacts resulting from the no-action alternative would be SMALL. 4-12

1 4.3.3 Replacement Power Alternatives: Common Impacts 2 4.3.3.1 Air Quality 3 Construction 4 Construction of a power station under a replacement power alternative would result in 5 temporary impacts on local air quality. Air emissions would be intermittent and would vary 6 based on the level and duration of specific activities throughout the construction phase. During 7 the construction phase, the primary sources of air emissions would consist of engine exhaust 8 and fugitive dust emissions. Engine exhaust emissions would be from heavy construction 9 equipment and commuter, delivery, and support vehicular traffic traveling to and from the facility 10 as well as within the site. Fugitive dust emissions would be from soil disturbances by heavy 11 construction equipment (e.g., earthmoving, excavating, and bulldozing), vehicle traffic on 12 unpaved surfaces, concrete batch plant operations, and wind erosion to a lesser extent. 13 Various mitigation techniques and best management practices (e.g., watering disturbed areas, 14 reducing equipment idle times, and using ultra-low sulfur diesel fuel) could be used to minimize 15 air emissions and to reduce fugitive dust. Implementation of a dust-control plan would also 16 address reasonable precautions that would be needed to prevent fugitive particulate emissions 17 in accordance with Florida Administrative Code 62-296.320(4)(c)3. Air emissions include 18 criteria pollutants (particulate matter, nitrogen oxides, carbon monoxide, and sulfur dioxide), 19 volatile organic compounds, hazardous air pollutants, and greenhouse gases (GHGs). Small 20 quantities of volatile organic compounds and hazardous air pollutants would also be released 21 from equipment refueling, onsite maintenance of the heavy construction equipment, and other 22 construction finishing activities as well as from cleaning products, petroleum-based fuels, and 23 certain paints. 24 Operations 25 The impacts on air quality as a result of operation of a power station for a replacement power 26 alternative will depend on the energy technology (i.e., fossil-fuel based or nuclear). 27 Fossil fuel-based power plants result in larger amounts of air emissions than nuclear power 28 plants. Worker vehicles, auxiliary power equipment, and mechanical draft cooling tower 29 operation will result in additional air emissions. 30 4.3.3.2 Noise 31 Construction 32 Construction of a replacement power facility would be similar to the construction of any 33 industrial facility in that all involve many noise-generating activities. In general, noise emissions 34 would vary during each phase of construction, depending on the level of human activity, types of 35 equipment and machinery used, and site-specific conditions. Typical construction equipment, 36 such as dump trucks, loaders, bulldozers, graders, scrapers, air compressors, generators, and 37 mobile cranes, would be used, and pile-driving and blasting activities could take place. Other 38 noise sources include construction worker vehicle and truck delivery traffic. However, noise 39 from vehicular traffic would be intermittent and would generate noise at levels similar to noise 40 levels from Turkey Point Units 3 and 4 reactor operations. 4-13

1 Operations 2 Noise generated during operations could include noise from mechanical draft cooling towers, 3 transformers, turbines, machinery, equipment, and communication announcements and sirens, 4 as well as offsite sources, such as employee and delivery vehicular traffic. Noise from vehicles 5 would be intermittent and at levels similar to noise levels generated by vehicles at Turkey Point. 6 Similarly, with the exception of noise from mechanical draft cooling towers, operational noise 7 levels at a replacement power plant would likely be similar to existing noise levels at 8 Turkey Point Units 3 and 4. 9 4.3.4 New Nuclear Alternative 10 4.3.4.1 Air Quality 11 Construction 12 Air emissions and sources associated with construction of the new nuclear alternative would 13 include those identified as common to all replacement power alternatives in Section 4.3.3.1, Air 14 Quality. Because air emissions from construction activities would be limited, local, and 15 temporary, the NRC staff concludes that the associated air quality impacts from construction of 16 a new nuclear alternative would be SMALL. 17 Operations 18 Operation of a new nuclear generating plant would result in air emissions similar in magnitude to 19 air emissions from the operation of Turkey Point. Sources of air emissions would include 20 stationary combustion sources (e.g., diesel generators, auxiliary boilers, and fire pumps) and 21 mobile sources (e.g., worker vehicles, onsite heavy equipment, and support vehicles). 22 Additional air emissions would result from the new nuclear plants use of mechanical draft 23 cooling towers rather than the cooling canal system currently used by Turkey Point and could 24 contribute to impacts associated with the formation of visible plumes, fogging, and subsequent 25 icing downwind of the towers. In general, most stationary combustion sources at a nuclear 26 power plant would operate only for limited periods, often during periodic maintenance testing. A 27 new nuclear power plant would need to secure a permit from the Florida Department of 28 Environmental Protection for air pollutants associated with its operations (e.g., criteria 29 pollutants, volatile organic compounds, hazardous air pollutants, and greenhouse gases). The 30 NRC staff expects the air emissions for combustion sources from a new nuclear plant to be 31 similar to those currently being emitted from Turkey Point Units 3 and 4 (see Section 3.2.1). 32 Emissions from the mechanical draft cooling towers would be approximately 15 tons/year for 33 particulate matter less than 10 microns and 0.08 tons/year for particulate matter less than 34 2.5 microns (NRC 2016a). Therefore, the NRC staff expects that the combined air quality 35 impact of emissions from onsite sources would be minor. Additional air emissions would result 36 from the approximately 800 employees commuting to and from the new nuclear facility. The 37 NRC staff does not expect air emissions from operation of a new nuclear alternative to 38 contribute to National Ambient Air Quality Standard violations. The NRC staff concludes that 39 the impacts of operation of a new nuclear alternative on air quality would be SMALL. 4-14

1 4.3.4.2 Noise 2 Construction 3 Noise generated during the construction and operation of a new nuclear power plant would be 4 similar to noise for all replacement power alternatives as discussed in Section 4.3.3.2, Noise. 5 In addition, Sections 4.8.2 and 5.8.2 of the EIS for the Turkey Point Units 6 and 7 combined 6 licenses (NUREG-2176) (NRC 2016a) describe noise impacts generated during construction 7 and operation of proposed Turkey Point Units 6 and 7; those noise impacts would be similar to 8 the noise impacts of constructing and operating new nuclear plants to replace Units 3 and 4. 9 Accordingly, the NRC staff incorporates the information in Sections 4.8.2 and 5.8.2 of 10 NUREG-2176 here by reference (NRC 2016a). Noise impacts during construction would be 11 limited to the immediate vicinity of the Turkey Point site. Because of the distance of the site to 12 potential receptors, noise impacts during the construction of a new nuclear power facility at the 13 Turkey Point site could range from SMALL to MODERATE depending on the noise-sensitive 14 receptor. 15 Operations 16 Mechanical draft cooling towers generate noise during operations. Other sources of noise 17 during nuclear power plant operations would include industrial equipment, machinery, vehicles, 18 and communications. In general, noise would be limited to the immediate vicinity of the Turkey 19 Point site and, with the exception of the cooling towers, noise levels would be similar to noise 20 levels generated during the operation of Turkey Point Units 3 and 4. Therefore, noise impacts 21 during power plant operations for a new nuclear plant would be SMALL. 22 4.3.5 Natural Gas Combined-Cycle Alternative 23 4.3.5.1 Air Quality 24 Construction 25 Air emissions and sources associated with construction of the natural gas alternative would 26 include those identified as common to all replacement power alternatives in Section 4.3.3.1, Air 27 Quality. There would also be additional air emissions resulting from construction of a new or 28 upgraded pipeline that would connect to existing natural gas supply lines north of the site. Air 29 emissions would be localized, intermittent, and short lived, and adherence to well-developed 30 and well-understood construction best management practices would mitigate air quality impacts. 31 Therefore, the NRC staff concludes that construction-related impacts on air quality from a 32 natural gas alternative would be of relatively short duration and would be SMALL. 33 Operations 34 Operation of a natural gas plant would result in emissions of criteria pollutants and greenhouse 35 gases. The sources of air emissions during operation include gas turbines through heat 36 recovery steam generator stacks. The staff estimated air emissions for the natural gas 37 alternative using emission factors developed by the U.S. Department of Energys National 38 Energy Technology Laboratory (NETL 2010a). Assuming a total gross capacity of 1,726 MW 4-15

1 and a capacity factor of 0.87 (FPL 2018f), the NRC staff estimates the following air emissions 2 would result from operation of a natural gas alternative: 3

• sulfur oxides20 tons (18 metric tons (MT)) per year 4
• nitrogen oxides440 tons (400 MT) per year 5
• carbon monoxide45 tons (41 MT) per year 6
• PM1032 tons (29 MT) per year 7
• carbon dioxide equivalents (CO2eq)5.7 million tons (5.2 million MT) per year 8 Operation of the mechanical draft cooling towers and up to 150 worker vehicles would also 9 result in additional criteria emissions above those presented in the list. A new natural gas plant 10 would qualify as a major emitting industrial facility. As such, the new natural gas plant would be 11 subject to Prevention of Significant Deterioration (PSD) and Title V air permitting requirements 12 under the Clean Air Act of 1970, as amended (42 U.S.C. 7651 et seq.), to ensure that air 13 emissions are minimized and that the local air quality is not substantially degraded.

14 Additionally, various Federal and State regulations aimed at controlling air pollution would affect 15 a natural gas alternative. 16 Based on the NRC staffs air emission estimates, nitrogen oxide and greenhouse gas emissions 17 from a natural gas plant would be noticeable and significant. Carbon dioxide emissions would 18 be much larger than the threshold in the U.S. Environmental Protection Agencys (EPAs) 19 Greenhouse Gas Tailoring Rule, and nitrogen oxide emissions would exceed the threshold for 20 major sources. The NRC staff concludes that the overall air quality impacts associated with 21 operation of a natural gas alternative would be SMALL to MODERATE. 22 4.3.5.2 Noise 23 Construction 24 In addition to the common impacts discussed in Section 4.3.3.2, Noise, for all replacement 25 power alternatives, additional noise would be generated during the construction of pipelines to 26 support a natural gas power plant. Because of the distance involved in pipeline construction, 27 noise impacts during the construction of a natural gas power plant and gas pipeline could range 28 from SMALL to MODERATE depending on the location of noise-sensitive receptors along the 29 gas pipeline. 30 Operations 31 Noise generated during the operation of a natural gas power plant would include noise from 32 mechanical draft cooling towers, compressor stations, and pipeline blowdowns. However, the 33 majority of noise-producing equipment (e.g., mechanical draft cooling towers, turbines, pumps) 34 would be located inside the power block. Therefore, noise impacts during power plant 35 operations would be SMALL. 4-16

1 4.3.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 2 Generation) 3 4.3.6.1 Air Quality 4 Construction 5 Air emissions and sources associated with construction of both the natural gas and solar 6 portions of this combination alternative would include those identified as common to all 7 replacement power alternatives in Section 4.3.3.1, Air Quality. Air emissions from construction 8 would be localized and intermittent, and well-understood construction best management 9 practices would mitigate air quality impacts. Therefore, the NRC staff concludes that 10 construction-related impacts on air quality from the combination alternative would be SMALL. 11 Operations 12 Air emissions associated with the operation of the natural gas portion of the combination 13 alternative would be similar to those associated with the natural gas alternative. However, 14 emissions associated with the natural gas portion of the combination alternative are slightly 15 reduced because the electricity output of the natural gas unit under the combination alternative 16 would be approximately 95 percent of that of the natural gas-only alternative. 17 The NRC staff estimates the following air emissions for the natural gas portion of the 18 combination alternative based on emission factors developed by the U.S. Department of 19 Energys National Energy Technology Laboratory (NETL 2010a): 20

• sulfur oxides19 tons (18 metric tons (MT)) per year 21
• nitrogen oxides420 tons (380 MT) per year 22
• carbon monoxide43 tons (39 MT) per year 23
• PM1030 tons (28 MT) per year 24
• carbon dioxide equivalents (CO2eq)5.4 million tons (4.9 million MT) per year 25 Operation of the mechanical draft cooling towers and up to 150 worker vehicles would also 26 result in additional criteria emissions above those presented in the list. The new natural gas 27 units would qualify as major emitting industrial facilities and would be subject to Prevention of 28 Significant Deterioration and Title V air permitting programs aimed at controlling air pollution.

29 Carbon dioxide emissions would be greater than the threshold in EPAs Greenhouse Gas 30 Tailoring Rule, and nitrogen oxide and carbon monoxide emissions would exceed the threshold 31 for major sources. 32 Air emissions associated with the operation of solar energy facilities are negligible because no 33 fossil fuels are burned to generate electricity. Emissions from solar fields would include fugitive 34 dust and engine exhaust emissions from vehicles and heavy equipment associated with site 35 inspections, maintenance activities (panel washing or replacement), and wind erosion from 36 cleared lands and access roads. The types of emission sources and pollutants during operation 37 would be similar to those during construction, but much fewer emissions would be released 38 during operation. These emissions should not cause exceedances of air quality standards or 39 have any impacts on climate change. The NRC staff concludes that the overall air quality 40 impacts associated with operation of the combination alternative would be SMALL to 41 MODERATE. 4-17

1 4.3.6.2 Noise 2 Construction 3 Construction-related noise sources for the natural gas power plant portion of the combination 4 alternative would be similar to the impacts discussed for the natural gas-only power plant 5 alternative in Section 4.3.5.2, Noise, and the common impacts discussed in Section 4.3.3.2, 6 Noise, for all replacement power alternatives. Noise impacts during the construction of a solar 7 facility could range from SMALL to MODERATE depending on its location in proximity to 8 noise-sensitive receptors. Therefore, construction impacts from the combination alternative 9 could range from SMALL to MODERATE depending on the location of noise-sensitive 10 receptors. 11 Operations 12 Noise generated during natural gas power plant operations would include noise from 13 mechanical draft cooling towers, compressor stations, and pipeline blowdowns. Noise impacts 14 during operation of the natural gas power plant component of the combination alternative would 15 be similar to those described in Section 4.3.5.2. Except for maintenance activities, very little 16 noise would be generated by the solar facility. Therefore, noise impacts during facility 17 operations from the combination alternative would be SMALL. 18 4.3.7 Cooling Water System Alternative 19 4.3.7.1 Air Quality 20 Construction and Operations 21 Under the cooling water system alternative, three plume-abated wet mechanical draft cooling 22 towers would be constructed for each reactor unit. Air emissions from construction of the 23 cooling towers would result from the exhaust of construction equipment, worker vehicle exhaust, 24 land disturbance activities (land-clearing, excavation), and demolition activities. Fuel 25 combustion exhaust would emit criteria pollutants and greenhouse gases while land-disturbance 26 and demolition activities would result in fugitive dust. 27 Potential atmospheric impacts from cooling system operation include the formation of visible 28 plume, fogging, and subsequent icing downwind of the towers. Operation of cooling towers 29 would also result in the emission of particulate matter from cooling tower drift, with higher 30 concentrations of dissolved solids associated with the potential use of seawater as a secondary 31 source of cooling water. However, modern cooling towers equipped with drift eliminators would 32 minimize the loss of water from the cooling towers via drift. As stated in Section 5.7.2 of the 33 final EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176), cooling tower 34 emissions would be required to adhere to the New Source Performance Standards 35 (40 CFR 60.40, Applicability and Designation of Affected Facility) and demonstrate compliance 36 with ambient air-quality standards by acquiring a Prevention of Significant Deterioration permit 37 under the Clean Air Act before the cooling towers could be operated (NRC 2016a). 38 Replacement power may be needed during both construction and operation of a mechanical 39 draft cooling tower system at Turkey Point. Following cooling tower construction, 40 Turkey Point Units 3 and 4 would be offline for at least a short time during the switchover from 41 use of the cooling canal system (CCS) to cooling towers. Some replacement power could also 4-18

1 be required once Turkey Points cooling tower system is online to compensate for the additional 2 power needed to operate cooling tower pumps and fans. Replacement power would come from 3 common types of existing technology within the region (natural gas, nuclear, and coal), and it is 4 not likely that new facilities would be constructed. The impacts on air quality would depend on 5 the specific location and technology of the replacement power facilities. 6 In Sections 4.7 and 5.7 of the final EIS for the Turkey Point Units 6 and 7 combined licenses 7 (NUREG-2176), the NRC staff determined that air impacts from the construction and operation 8 of Units 6 and 7, including those associated with the construction and operation of the 9 mechanical draft cooling towers, would be SMALL (NRC 2016a). As described in Section 2.2.3, 10 Cooling Water System Alternative, of this SEIS, construction and operation of mechanical draft 11 cooling towers for Units 3 and 4 would be similar to, but proportionally smaller than, the impacts 12 described in the NUREG-2176 analysis for Units 6 and 7. Therefore, the NRC staff concludes 13 that the air quality impacts from the construction and operation of mechanical draft cooling 14 towers to support Turkey Point Units 3 and 4 would be SMALL. 15 4.3.7.2 Noise 16 Construction 17 Construction-related noise during construction of the cooling towers for the cooling water 18 system alternative would be similar to the impacts discussed in Section 4.3.3.2, Noise, as 19 common to all replacement power alternatives. Because of the distance from the site to 20 noise-sensitive receptors, noise impacts during construction of the cooling towers for the cooling 21 water system alternative at the Turkey Point site could range from SMALL to MODERATE 22 depending on the noise-sensitive receptor. 23 Operations 24 As previously discussed, mechanical draft cooling towers generate noise during operations. In 25 general, noise impacts when the cooling towers for the cooling water system alternative are 26 operating would be limited to the immediate vicinity of the Turkey Point site and would be 27 SMALL. 28 4.4 Geologic Environment 29 This section describes the potential geology and soil resource impacts of the proposed action 30 (subsequent license renewal) and alternatives to the proposed action. 31 4.4.1 Proposed Action 32 According to the 2013 GEIS (NRC 2013a), plant-specific environmental reviews conducted by 33 the NRC had not identified any significant impact issues related to geology and soil resources. 34 The NRC staffs review of the Turkey Point subsequent license renewal application has not 35 identified any new or significant information that would change the conclusion in the GEIS. 36 Thus, as concluded in the GEIS, the impacts of continued operation on geology and soil 37 resources would be SMALL. 38 As identified in Table 4-1, the impacts of the single geologic environment issue (geology and 39 soils) would be SMALL. Table 4-2 does not identify any site-specific (Category 2) geologic 40 environment issues. 4-19

1 4.4.2 No-Action Alternative 2 Under the no-action alternative, the NRC would not issue subsequent renewed licenses and 3 Turkey Point Units 3 and 4 would shut down on or before the expiration of the current renewed 4 licenses. There would not be any impacts to the geology and soils at the Turkey Point site with 5 the shutdown of the facility. With the shutdown of the facility, no additional land would be 6 disturbed. Therefore, the NRC staff concludes that impacts on geology and soil resources from 7 the no-action alternative would be SMALL. 8 4.4.3 Replacement Power Alternatives: Common Impacts 9 Under all replacement power alternatives, construction impacts would be temporary and 10 localized. During construction for all the replacement power alternatives, sources of aggregate 11 material (such as crushed stone, sand, and gravel) would be required to construct buildings, 12 foundations, roads, and parking lots. The NRC staff presumes that these resources would likely 13 be obtained from commercial suppliers using local or regional sources. 14 During construction of all replacement power alternatives, no previously undisturbed soils would 15 be impacted. Organic soil or muck on the proposed building site would be removed and 16 disposed of in several locations on the berms alongside the main return canal and southern 17 canal of the CCS (also called the industrial wastewater facility). Prior to placement of spoils 18 material, part of the surface would be excavated, and small containment berms would be 19 created to form a shallow excavation in which to place the spoils. Material that is removed from 20 the excavations and is not suitable for reuse would be placed in these areas for dewatering and 21 disposal. FPL has indicated that measures such as berms, riprap, sedimentation filters, and 22 detention ponds would be used to control drainage from the spoils piles to the CCS 23 (NRC 2016a). 24 During operation of replacement power alternatives, no additional land would be disturbed. 25 Therefore, NRC staff concludes that the common impacts of operations of replacement power 26 alternatives on geology and soil resources would be SMALL. 27 4.4.4 New Nuclear Alternative 28 The NRC staff did not identify any impacts to the geologic environment for the new nuclear 29 alternative beyond those discussed above as common to all replacement power alternatives. 30 Therefore, the NRC staff concludes that the impacts to geology and soil resources from the new 31 nuclear alternative would be SMALL. 32 4.4.5 Natural Gas Combined-Cycle Alternative 33 The NRC staff did not identify any impacts to the geologic environment for the natural gas 34 alternative beyond those discussed above as common to all replacement power alternatives. 35 Therefore, the NRC staff concludes that the impacts to geology and soil resources from the 36 natural gas alternative would be SMALL. 37 4.4.6 Combination Natural Gas Combined-Cycle and Solar Photovoltaic Alternative 38 For the natural gas component of this alternative, the NRC staff did not identify any impacts to 39 the geologic environment beyond those discussed above as common to all replacement power 40 alternatives. However, the solar component of this alternative would require land to be cleared 4-20

1 for solar power installations. The corresponding impacts on soil resources would be noticeable, 2 but they would not destabilize important attributes of the resource. Therefore, the NRC staff 3 concludes that the impacts to geology and soil resources from the combination natural gas and 4 solar alternative would be MODERATE. 5 4.4.7 Cooling Water System Alternative 6 The NRC staff did not identify any impacts to the geologic environment for the cooling water 7 system alternative beyond those discussed above as common to all replacement power 8 alternatives. Therefore, the NRC staff concludes that the impacts to geology and soil resources 9 from the cooling water system alternative would be SMALL. 10 4.5 Water Resources 11 This section describes the potential surface water and groundwater resources impacts of the 12 proposed action (subsequent license renewal) and alternatives to the proposed action. 13 4.5.1 Proposed Action 14 4.5.1.1 Surface Water Resources 15 According to the GEIS (NRC 1996 and NRC 2013a), for the most part, no significant surface 16 water impacts for Category 1 (generic) issues are anticipated during the license renewal term 17 that would be different from those occurring during the current license term. The NRC staffs 18 review of the Turkey Point SLR application has not identified any new and significant 19 information that would change the conclusion in the GEIS. Thus, as concluded in the GEIS, for 20 these Category 1 (generic) issues, the impacts of continued operation on surface water 21 resources would be SMALL. 22 Table 4-1 in Section 4.1 lists Applicable Category 1 (Generic) Issues for Turkey Point. The 23 impacts for these issues are SMALL. While no Category 2 (site-specific) issues applicable to 24 the Turkey Point site have been identified, the NRC staff did evaluate the significance of new 25 information for the impacts from the CCS on adjacent surface water bodies via the groundwater 26 pathway. As discussed below, this information was determined not to be significant for Turkey 27 Point subsequent license renewal. 28 New Issue, Water Quality Impacts on Adjacent Water Bodies (Plants with Cooling Ponds in Salt 29 Marshes) 30 As part of its review of the Turkey Point subsequent license renewal application, the NRC staff 31 identified new information regarding nuclear power plant operations that can act upon the 32 environment in a manner or in an intensity or scope (context) not previously recognized. 33 Specifically, the GEIS (NUREG-1437) did not consider how a nuclear power plant with a 34 cooling pond in a salt marsh may indirectly impact the water quality of adjacent surface water 35 bodies via a groundwater pathway. This constitutes a new, site-specific issue with respect to 36 Turkey Point, for which the NRC staff has prepared the following site-specific analysis. 37 In its environmental report, FPL identified the Category 1 issue, Altered salinity gradients, as 38 applicable to Turkey Point Units 3 and 4 operations. However, the NRC staff has determined 39 that this issue is not applicable to Turkey Point due to the unique configuration of the Turkey 40 Point CCS. As indicated in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 and as 4-21

1 further described in the GEIS (NRC 2013a), the issue, Altered salinity gradients, only applies 2 to nuclear power plants located on estuaries and changes in salinity due to the operational 3 effects of intake and discharge structures in estuaries. At Turkey Point, the intake and 4 discharge structures associated with Units 3 and 4 are located within the enclosed CCS, which 5 does not directly discharge to the surface waters of Biscayne Bay. Nonetheless, the NRC staff 6 has evaluated new and potentially significant information related to the operation of the CCS 7 and its effects on salinity within the Biscayne aquifer under the issue, Groundwater quality 8 degradation (plants with cooling ponds in salt marshes), in Section 4.5.1.2 of this SEIS rather 9 than under the new issue discussed in this section. 10 For this new issue (water quality impacts on adjacent water bodies), Sections 3.1.3, Cooling 11 and Auxiliary Water Systems, and 3.5.1, Surface Water Resources, of this SEIS present 12 relevant new information related to the water quality of surface waters adjacent to Turkey Point 13 and the Turkey Point site. Much of this information did not become available until many years 14 after the NRC had issued the initial renewed licenses for Units 3 and 4 in 2002 and was not 15 available at the time that the 2013 GEIS was prepared. The following discussion is based on 16 information summarized in the aforementioned sections of this SEIS. 17 Turkey Point Units 3 and 4 do not consume surface water or discharge directly to natural 18 surface water bodies. All surface water discharges from Turkey Point flow into the CCS. As 19 described in Section 3.1.3.2 of this SEIS, the CCS is surrounded by perimeter berms that are 20 designed to keep water from entering the CCS. The perimeter berms are built on top of the 21 bedrock, while water levels in the CCS are below the top of the bedrock. The perimeter berms 22 are not in contact with water within the CCS. However, the water in the CCS is in contact with 23 and hydrologically connected to the Biscayne aquifer. The Biscayne aquifer, in turn, is 24 hydrologically connected to the surrounding marsh land, mangrove areas, adjacent drainage 25 canals, Biscayne Bay, and Card Sound. 26 Water in the CCS is considered industrial wastewater and is not recognized as a usable 27 resource. Therefore, only the impacts from CCS operation on the water quality of adjacent 28 surface water bodies via the groundwater pathway from the CCS through the Biscayne aquifer 29 are considered in this analysis. 30 The Florida legislature has designated Biscayne Bay and Card Sound, including Biscayne 31 National Park, as Outstanding Florida Waters. This designation affords these waters the 32 highest water quality protections in the State. 33 The impact of temperature, salinity, ammonia, and nutrients on water quality has been the focus 34 of CCS operational concerns. It has been reported that increased levels of ammonia, other 35 nutrients, or salinity had been found in local areas adjacent to the CCS, however, as discussed 36 below and in Chapter 3 of this SEIS, discernable effects from CCS derived temperature, 37 ammonia, nutrients, and salinity on Biscayne Bay or Card Sound water qualities has not been 38 detected. 39 As discussed in Section 3.5.1.4 of this SEIS, ammonia concentrations in the water within the 40 CCS are below the Miami-Dade County ammonia water quality standard. Also as discussed in 41 Section 3.5.1.4, adjacent surface water bodies contain ammonia from natural sources that occur 42 within the water body (e.g., through decay of organic matter). Noticeable concentrations of 43 ammonia have been found in two deep excavations outside of and adjacent to the CCS that 44 contain stagnant water (i.e., the Barge Turning Basin and the remnant canal at Turtle Point). To 4-22

1 prevent the movement of ammonia from the CCS into these areas, FPL is undertaking 2 mitigation activities, as discussed below. 3 Thermal impacts on adjacent water bodies from the CCS have not been detected. Similarly, 4 impacts on surrounding marsh and mangrove areas from CCS contributions of ammonia, 5 nutrients, and salinity have not been detected. Impacts on adjacent canals from CCS 6 contributions of ammonia, nutrients, and salinity have been slight. Water that likely originated 7 from the CCS has sporadically been detected in two canals adjacent to the CCS. However, the 8 water quality in these two canals has not been degraded sufficiently to prevent these canals 9 from achieving their intended purpose (i.e., transporting fresh water, draining the land, and flood 10 control). Further, little if any influence on surface water quality in Card Sound was detected 11 from the discharge of these two canals into Card Sound. 12 As described in Section 3.5.2, Groundwater Resources, hypersaline water originating in the 13 CCS is moving eastward beneath Biscayne Bay at depth along the base of the Biscayne 14 aquifer. The program implemented by FPL to extract hypersaline groundwater from the 15 Biscayne aquifer (on the west side of the CCS) is not designed to remove the hypersaline 16 groundwater beneath Biscayne Bay (on the east side of the CCS). Because the hypersaline 17 groundwater is denser than seawater, the hypersaline groundwater is found at the bottom of the 18 Biscayne aquifer and is moving down the eastward dip of the aquifer. Upward movement of this 19 hypersaline water from the Biscayne aquifer and into Biscayne Bay and Card Sound has not 20 been detected in either pore water or shallow monitor well samples collected in the Bay and 21 Sound. 22 In accordance with agreements reached with and/or requirements imposed by the Florida DEP 23 and Miami-Dade County DERM, FPL is implementing programs to control ammonia and 24 nutrients and to reduce salinities within the CCS. These programs (which include adding fresh 25 or lower salinity water to the CCS, pumping hypersaline water from groundwater, and 26 monitoring and reporting requirements) are expected to reduce the impact of the CCS on 27 groundwater quality within the Biscayne aquifer. In turn, the potential impacts on surface water 28 quality via groundwater from the CCS via the groundwater pathway would also be reduced. 29 These programs are expected to reduce the amount of hypersaline groundwater originating 30 from the CCS. Hypersaline groundwater flow from the CCS beneath Biscayne Bay would, 31 however, continue to move eastward and downgradient along the base of the Biscayne aquifer. 32 While this is a new site-specific issue that has been identified for Turkey Point, upon 33 consideration of the FDEPs and DERMs existing requirements and their continuing oversight of 34 FPLs site remediation efforts, the NRC staff concludes that the impacts on adjacent surface 35 water bodies via the groundwater pathway from the CCS during the subsequent license renewal 36 term would be SMALL and, therefore, the new information that has been identified is not 37 significant. 38 4.5.1.2 Groundwater Resources 39 According to the GEIS (NRC 1996 and NRC 2013a), groundwater resources would not be 40 significantly affected by continued operations associated with license renewal in most 41 circumstances. As discussed in Section 3.5.2 of this SEIS, the NRC staff identified no new and 42 significant information for most issues relating to groundwater use and quality. As identified in 43 Table 4-1, the impacts for most applicable generic groundwater resources issues would be 44 SMALL. However, during its review of FPLs environmental report, site visit, scoping process, 45 and evaluation of other available information, the NRC staff identified new information regarding 4-23

1 the generic groundwater resource issue of Groundwater quality degradation (plants with 2 cooling ponds in salt marshes). The NRC staffs evaluation of the significance of this new 3 information follows. 4 New Information, Category 1 Issue, Groundwater Quality Degradation (Plants with Cooling 5 Ponds in Salt Marshes) 6 As referenced in Section 1.4 of this SEIS and as further described in Sections 1.5 and 1.8 of the 7 GEIS (NUREG-1437) (NRC 2013a), no additional site-specific analysis is required by the NRC 8 staff for Category 1 (generic) issues in the SEIS unless new and significant information is 9 identified that would change the conclusions in the GEIS. Where new and significant 10 information has been identified, the NRC staff will reconsider generic impacts in the SEIS. 11 The Category 1 issue, Groundwater quality degradation (plants with cooling ponds in salt 12 marshes), was first evaluated in the 1996 GEIS (NRC 1996) and was reconsidered as part of 13 the update to the GEIS, issued in June 2013 (NRC 2013a). 14 For the subject issue, the 2013 GEIS (NRC 2013a: 4-50, 4-51) provides the following technical 15 basis with respect to nuclear power plants that use cooling ponds as part of their cooling water 16 system discharge: 17 Nuclear plants that use cooling ponds as part of their cooling water system 18 discharge effluent to the pond. The effluents concentration of contaminants and 19 other solids increases relative to that of the makeup water as it passes through 20 the cooling system. These changes include increased total dissolved solids (or 21 TDS), since they concentrate as a result of evaporation, increased heavy metals 22 (because cooling water contacts the cooling system components), and increased 23 chemical additives to prevent biofouling. Because all the ponds are unlined 24 (NRC 1996), the water discharged to them can interact with the shallow 25 groundwater system and may create a groundwater mound. In this case, 26 groundwater below the pond can flow radially outward, and this groundwater 27 would have some of the characteristics of the cooling system effluent. 28 In salt marsh locations, the groundwater is naturally brackish (i.e., with a TDS 29 concentration of about 1,000 to more than 10,000 milligrams per liter [mg/L]) and, 30 thus, is already limited in its uses. As such, this issue concerns only the potential 31 for changing the groundwater use category of the underlying shallow and 32 brackish groundwater due to the introduction of cooling water contaminants. Two 33 nuclear plants, South Texas in Texas and Turkey Point in Florida, have cooling 34 systems (man-made cooling pond and cooling canal system, respectively) 35 located relatively near or constructed in salt marshes. Plants relying on brackish 36 water cooling systems would not further degrade the quality of the shallow 37 aquifer relative to its use classification. This is because groundwater quality 38 beneath salt marshes is already too poor for human use (i.e., it is non-potable 39 water) and is only suitable for industrial use. 40 The NRC staff concluded in the GEIS (NUREG-1437) (NRC 2013a: 4-50, 4-51) that operational 41 impacts from cooling ponds located in salt marshes would have a SMALL impact on 42 groundwater quality, and no new information was identified that would alter this conclusion. 4-24

1 Section 3.5.2.2 of this SEIS presents and considers in detail relevant new information related to 2 groundwater quality at the Turkey Point site that supports the staffs reconsideration of the 3 generic impacts of the subject issue. This information is summarized below. The CCS used by 4 Turkey Point Units 3 and 4 and other generating facilities at the Turkey Point site is an 5 expansive water body formed by excavation into the marshes and underlying bedrock. Because 6 the CCS is unlined, it is hydraulically connected to the upper Biscayne aquifer, permitting the 7 movement of water between the CCS and the aquifer through the bedrock. Water in the CCS is 8 hypersaline (i.e., the water has a salinity greater than that of natural seawater, with a chloride 9 concentration exceeding 19,000 mg/L). Over the operational life of the CCS, the annual 10 average salinity of the waters within the CCS and the hypersaline groundwater plume beneath it 11 has increased. The existence of a hypersaline plume beneath the CCS was known at the time 12 the NRC staff prepared its SEIS for the initial license renewal for Turkey Point in 2002. At the 13 time, however, and at the time of the 2013 update to the GEIS (NRC 2013a), the potential for 14 the hypersaline plume to migrate down through the Biscayne aquifer and then move laterally 15 beyond the boundaries of the CCS was not known. 16 Beginning in 2010, FPL initiated an expanded groundwater monitoring program in accordance 17 with State regulatory approvals of the Turkey Point extended power uprate (EPU) project, to 18 determine the horizontal and vertical effects of CCS water on the environment. Monitoring 19 results demonstrated that CCS operations have impacted groundwater quality in the Biscayne 20 aquifer beyond the boundaries of the CCS and FPL property, both to the west of the site as well 21 as beneath Biscayne Bay to the east of the Turkey Point site. The hypersaline plume 22 emanating from the CCS has migrated along the base of the Biscayne aquifer to the west into 23 groundwater designated by the State as Class G-II, potable water use (defined as having total 24 dissolved solids (TDS) levels of less than 10,000 mg/L). Currently, FPL reports that hypersaline 25 water from the CCS extends out approximately 1.5 mi (2.4 km) west of the CCS boundary. 26 The NRC staff concludes that the contribution of past CCS hypersaline water on offsite 27 groundwater quality is difficult to quantify, in that statements by the State of Florida 28 (FDEP 2014a) and analyses prepared by FPL, as referenced in Section 3.5.2.2 of this SEIS, 29 indicate that saltwater was present as early as the 1940s near the base of the Biscayne aquifer 30 west of the Turkey Point site (i.e., prior to completion of CCS construction in 1973). In addition, 31 groundwater data from the early 1970s supported the determination that non-potable 32 groundwater occurred beneath much of the area now occupied by the CCS and within the 33 deeper portions of the aquifer west of the site. Thus, portions of the Biscayne aquifer to the 34 west of the CCS did not meet Class G-II groundwater criteria prior to CCS construction. This 35 earlier groundwater quality degradation is attributable to regional saltwater intrusion, which had 36 already occurred across southeast Miami-Dade County and the Turkey Point site due to historic 37 land use alterations and groundwater withdrawals that induced saltwater migration from east to 38 west along the base of the Biscayne aquifer (FDEP 2014a, NRC 2016a). 39 However, the fact that CCS operations have measurably degraded groundwater quality beyond 40 the general confines of the CCS structure and Turkey Point site boundaries is generally not in 41 dispute. Furthermore, it is apparent that water from the CCS has migrated to the west and 42 toward areas where groundwater within the Biscayne aquifer is of sufficient quality to support its 43 use as a potable water supply. Vertical trends in monitoring wells for such parameters as 44 chloride, TDS, and tritium concentrations indicate the influence of CCS water in groundwater 45 both to the west and east of the Turkey Point site, as discussed in Section 3.5.2.2 of this SEIS. 46 Consequently, in accordance with regulatory mechanisms imposed by Miami-Dade County 47 (MDC 2015a) and FDEP (FDEP 2016e), FPL initiated operation of a groundwater remediation 4-25

1 system in May 2018, to intercept, capture, and retract the hypersaline plume within a 10-year 2 timeframe. 3 Groundwater monitoring results for tritium also indicate that the extent of potential influence of 4 CCS water (based on a tritium concentration of 20 pCi/L or greater as measured near the base 5 of the Biscayne aquifer) extends as far as 4.5 mi (7.2 km) west of the CCS at monitoring well 6 TPGW-7 and approximately 2 mi (3.2 km) east beneath Biscayne Bay (see Figure 3-13 of this 7 SEIS). These monitoring results show that the extent of tritium migration exceeds the extent of 8 the hypersaline plume from the CCS (as noted above, FPL reports that hypersaline water from 9 the CCS extends out approximately 1.5 mi (2.4 km) west of the CCS boundary). Nonetheless, 10 using 20 pCi/L for tritium as a standard, near monitoring well TPGW-7 to the west of the CCS, 11 Class G-II groundwater criteria are met in the upper part of the Biscayne aquifer with the 12 relatively fresh water band thickening to the west and away from the saltwater interface. This 13 westward boundary (defined by the current estimate of the 20 pCi/L concentration boundary for 14 tritium in groundwater) is approximately 2 mi (3.2 km) southeast of the Newton Wellfield that 15 supplies potable water from the Biscayne aquifer to parts of Miami-Dade County. At no location 16 outside the boundary of the Turkey Point site do tritium levels in groundwater approach the EPA 17 and State primary drinking water standard for tritium (20,000 pCi/L), while the highest tritium 18 levels observed in offsite monitoring wells near the site are approximately 15 percent of the 19 standard. 20 Moreover, the northwestern-most boundary of the 20 pCi/L tritium concentration in the vicinity of 21 monitoring well TPGW-7 closely aligns with the current location of the saltwater interface in the 22 Biscayne aquifer in that area, as shown in Figure 3-12 of this SEIS. Both the U.S. Geological 23 Survey (USGS) and FDEP have asserted that hypersaline water from the CCS contributes to 24 the westward migration of the saltwater interface across southeast Miami-Dade County, as 25 referenced in Section 3.5.2.2. Most recently, FPL reported to FDEP on the results of 26 groundwater modeling (Tetra Tech 2018) that was performed using a variable density flow and 27 salinity transport model to allocate relative contributions to the movement of the saltwater 28 interface. The modeling results indicate that the operation of the CCS, in which the salinity 29 exceeds 35 practical salinity units (PSU), is the single largest contributor to changes 30 (movement) in the location of the saltwater interface, as measured by the areal extent of the 31 saltwater interface (see Section 3.5.2.2). 32 Based on the information described above, the NRC staff finds that operation of the CCS under 33 hypersaline conditions, and the migration of an associated hypersaline groundwater plume in 34 the Biscayne aquifer, has contributed to the migration of the saltwater interface across portions 35 of southeastern Miami-Dade County, to the west and north of the Turkey Point site. 36 Hypersaline groundwater containing tritium has migrated beyond the boundaries of the CCS 37 and Turkey Point property at the base of the Biscayne aquifer from Class G-III groundwater 38 (i.e., non-potable groundwater) into areas designated by the State of Florida as Class G-II 39 groundwater (potable groundwater). As evidenced by elevated levels of tritium, the NRC staff 40 finds that CCS-influenced water has migrated into portions of the Biscayne aquifer that are 41 designated as a potential source of potable water. While the NRC staff also finds that the 42 constituents of concern are not a human health concern at present, the water originating from 43 the CCS has resulted in the degradation of groundwater quality to the west and east of the 44 CCS, at least at the base of the Biscayne aquifer. In addition, as a source of hypersaline water, 45 the discharge of CCS water to the base of the Biscayne aquifer has been and is currently 46 contributing to the migration of the saltwater interface. 4-26

1 These aspects of cooling pond operations and their effects on groundwater quality were not 2 considered in the GEIS as part of the technical basis for the Category 1 issue, Groundwater 3 quality degradation (plants with cooling ponds in salt marshes). The NRC staff has determined 4 that this information is both new and significant. Based on the information identified, the NRC 5 staff has concluded that the site-specific impacts for this issue at the Turkey Point site are 6 MODERATE for current operations, but will be SMALL during the subsequent license renewal 7 term as a result of ongoing remediation measures and State and county oversight, now in place 8 at Turkey Point. The NRC staff has assigned these significance levels because the plume of 9 hypersaline water from the CCS has measurably altered and degraded groundwater quality in 10 the lower part of the Biscayne aquifer beyond the CCS and Turkey Point property, but 11 hypersalinity is projected to decrease substantially as a result of ongoing remediation efforts. 12 As previously referenced and as detailed in Section 3.5.2.2, FPL entered into a consent 13 agreement (MDC 2015a) with Miami-Dade County Division of Environmental Resources 14 Management (DERM) in October 2015 and a consent order (FDEP 2016e) with FDEP in 15 June 2016. Both compliance agreements require FPL to take measures to abate hypersaline 16 water discharges from the CCS and to actively remediate the hypersaline groundwater west and 17 north of FPLs property. In accordance with those requirements, FPL completed construction 18 and commenced operation in May 2018 of a Biscayne aquifer recovery well system, to intercept, 19 capture, and retract the hypersaline plume from the CCS to within FPLs property boundary. 20 The South Florida Water Management District (SFWMD) issued FPL a water use individual 21 permit (Permit No. 13-06251-W) in February 2017 for operation of this system (SFWMD 2017a). 22 In its environmental report, FPL states that operation of its recovery well system will achieve 23 retraction of the plume back to the FPL site (i.e., Turkey Point site) boundary within 10 years, as 24 required by the 2016 consent order with FDEP (FPL 2018f). As referenced in 25 Permit No. 13-06251-W, the modeling commissioned by FPL to support the design and 26 permitting of the recovery well system consists of a three-dimensional, density-dependent, 27 groundwater flow and saltwater transport model (Tetra Tech 2016). Consistent with FPLs 28 statements in its environmental report (FPL 2018f), the modeling results for the constructed well 29 system predict retraction of the westward plume to the edge of the CCS by about 5 years and 30 complete retraction within 10 years, with minor aquifer drawdown impacts. Both the 31 2015 consent agreement with the Miami-Dade County DERM (MDC 2015a) and the 2016 FDEP 32 consent order (FDEP 2016e) require that FPL monitor the effectiveness of the system and 33 periodically report the results to the agencies. If monitoring analysis shows that the system is 34 not achieving remediation objectives, FPL must develop and submit alternative plans to the 35 agencies. In the SFWMD report included as part of the permit, SFWMD states that system 36 operation should, as part of the extraction of hypersaline groundwater, pull the saltwater 37 interface in the Biscayne aquifer to the east from its current location and increase the amount of 38 fresh groundwater in areas surrounding the CCS (SFWMD 2017a). 39 Groundwater models are approximations of natural systems and are dependent on a number of 40 input variables based on assumptions regarding present and future environmental conditions. 41 Thus, they entail substantial uncertainty. Nonetheless, the effectiveness of the recovery well 42 system in halting and retracting the hypersaline plume is subject to regulatory oversight by 43 FDEP and DERM, and the terms of the 2016 FDEP consent order and 2015 DERM consent 44 agreement. Therefore, the NRC staff concludes that as a result of FPLs operation of its 45 recovery well system and continued regulatory oversight and enforcement of the terms of the 46 consent order and consent agreement by the FDEP and DERM, the impacts on groundwater 47 quality from operations during the subsequent license renewal term would be SMALL. This 48 conclusion is further supported by the fact that the subsequent license renewal term does not 4-27

1 commence until 2032 and 2033, for Units 3 and 4, respectively, affording a substantial period of 2 time for groundwater remediation and improvement to be accomplished prior to the subsequent 3 period of extended operations. 4 Category 2 Issues 5 Table 4-2 identifies two Turkey Point site-specific (Category 2) issues related to groundwater 6 resources during the subsequent license renewal term. These issues are analyzed below. 7 Groundwater Use Conflicts (Plants That Withdraw More Than 100 Gallons per Minute) 8 For nuclear power plants that withdraw more than 100 gpm (378 L/min) of groundwater to 9 supply a plants makeup cooling, service water, or potable water needs, there can be conflicts 10 with other local groundwater users if the cone(s) of depression created by a facilitys 11 groundwater production extends to offsite well(s). This is a Category 2 issue. 12 In evaluating the potential impacts resulting from groundwater use conflicts associated with 13 subsequent license renewal, the NRC staff uses as its baseline the existing groundwater 14 resource conditions described in Sections 3.5.2.1 through 3.5.2.3 of this SEIS. These baseline 15 conditions encompass the existing hydrogeologic framework and conditions (including aquifers) 16 potentially affected by continued operations, as well as the nature and magnitude of 17 groundwater withdrawals for cooling and other purposes (as compared to relevant appropriation 18 and permitting standards). The baseline also considers other downgradient or in-aquifer uses 19 and users of groundwater. 20 As described in Section 3.5.2.3, FPL uses onsite groundwater withdrawn from the Biscayne and 21 Upper Floridan aquifers for a variety of applications in support of Turkey Point Units 3 and 4 22 operations, as well as for other activities conducted on the Turkey Point site unrelated to 23 Turkey Point Units 3 and 4 operations. Moreover, at the time of initial license renewal as 24 documented in the NRC staffs SEIS for the Turkey Point initial license renewal (NUREG-1437, 25 Supplement 5) (NRC 2002c), no groundwater was being withdrawn for use as makeup water or 26 to support salinity management (i.e., freshening) in the CCS. Since 2014, FPL has substantially 27 increased groundwater usage from both the Biscayne and Upper Floridan aquifers to support 28 freshening of the CCS and, most recently, as part of groundwater extraction activities for 29 remediation of hypersaline groundwater emanating from the CCS. 30 Conflicts Analysis for the Biscayne Aquifer 31 In 2017, FPLs groundwater withdrawals from the Biscayne aquifer totaled 8,982.8 mgy 32 (33.8 million m3/yr). This equates to an average withdrawal of 24.5 mgd (92,700 m3/d), or 33 approximately 17,000 gpm (64,300 L/min) (see Section 3.5.2.3). Approximately 55 percent of 34 the total volume withdrawn (13.5 mgd (51,100 m3/day)) from the Biscayne aquifer was 35 associated with testing for the hypersaline groundwater recovery well system, with the 36 remainder (i.e., about 11 mgd (41,800 m3/yr)) associated with use of the three marine wells 37 (i.e., wells PW-1, SW-1, and SW-2). 38 FPL did not commence full operation of the recovery well system until May 2018 39 (Section 3.5.2.2). Consequently, groundwater withdrawals for system development and testing 40 in 2017 do not reflect expected final system production rates. The installed system consists of 41 10 recovery (extraction) wells that FPL has numbered RW-1 through RW-10. These recovery 42 wells are generally located along the western edge of the CCS. The wells are located and 4-28

1 designed to extract hypersaline groundwater from near the base of the Biscayne aquifer, and to 2 limit the influence of CCS operations on the regional saltwater interface. Under optimal 3 conditions, the 10-well system has an extraction capacity of 15 mgd (56,700 m3/day), or 4 5,475 mgy (20.7 million m3/yr). 5 The SFWMD has issued FPL a water use individual permit (Permit No. 13-06251-W) for 6 operation of the recovery well system. The permit specifies a maximum monthly withdrawal 7 allocation of 465 million gal (1.76 million m3) (SFWMD 2017a). This limit bounds the total 8 installed production capacity of the recovery wells. Additionally, the permit requires that FPL 9 mitigate interference with existing legal uses of groundwater and mitigate harm to natural 10 resources, including effects on surface water or groundwater that result in lateral movement of 11 the saltwater interface or reductions in the hydroperiod of wetlands or natural water bodies, 12 causes the movement of contaminants contrary to water quality standards, or causes harm to 13 the natural system including habitats for rare or endangered species. In such cases, FPL would 14 be required to reduce or otherwise alter groundwater withdrawals to mitigate impacts. 15 As referenced above, FPL contracted Tetra Tech (Tetra Tech 2016) to develop and perform 16 numerical groundwater modeling to support FPLs water use permit application to SFWMD. The 17 NRC staff reviewed the modeling report (Tetra Tech 2016) as well the SFWMD report and 18 impacts evaluation that were included in FPLs water use individual permit 19 (Permit No. 13-06251-W) (SFWMD 2017a). 20 The modeling report assessed various operational scenarios for the recovery well system using 21 a regional, three-dimensional, density-dependent, groundwater flow and saltwater transport 22 model to simulate the effects on conditions in the Biscayne aquifer. As described by Tetra Tech 23 (Tetra Tech 2016) and summarized by FPL (FPL 2018n), the numerical model features an 24 11-layer flow system to represent the Biscayne aquifer. The model simulates interactions 25 between the CCS, Biscayne aquifer, Biscayne Bay, and affected surface water canals. Seven 26 recovery well scenarios, reflecting differences in recovery well locations, were modeled for a 27 10-year simulation period, as compared to a no-action scenario. The modeling scenario that 28 Tetra Tech (Tetra Tech 2016) identifies as alternative 3D represents the recovery well system 29 that has been constructed by FPL. Modeling results for alternative 3D show that the 30 hypersaline plume within the lower high-flow zone of the aquifer will be retracted back to the 31 eastern edge of the CCS within 10 years and that salinity concentrations are reduced to that of 32 seawater (i.e., 35 PSU) or less in the aquifer beneath the CCS. Predicted offsite drawdowns 33 (i.e., west of the L-31E Canal) are less than 0.2 feet (0.06 m) (Tetra Tech 2016). 34 The modeling results for the constructed well system predict retraction of the westward plume to 35 the edge of the CCS beginning within about 5 years, and complete retraction within 10 years, 36 with minor aquifer drawdown impacts. In the impacts evaluation included in 37 Permit No. 13-06251-W, SFWMD stated that system operation should, as part of the extraction 38 of hypersaline groundwater, pull the saltwater interface in the Biscayne aquifer to the east from 39 its current location and increase the amount of fresh groundwater in areas surrounding the CCS 40 (SFWMD 2017a). 41 As documented in the SFWMD report issued as part of the permit package for 42 Permit No. 13-06251-W and supporting documentation included in SFWMDs online application 43 file (SFWMD 2017a), SFWMD staff reviewed the modeling submitted by FPL (Tetra Tech 2016) 44 and also performed confirmatory analyses. In summary, SFWMD concluded that: (1) recovery 45 well system withdrawals would have no impact on existing legal users of the Biscayne aquifer, 46 (2) predicted drawdowns would not exceed 0.5 feet (0.15 m) with minimal potential to affect 4-29

1 water resource availability given the aquifers total saturated thickness, and (3) withdrawals 2 should result in eastward retraction of the saltwater interface and increase the availability of 3 fresh groundwater in the area of the CCS. SFWMD separately considered a modeling scenario 4 under drought conditions. The drought scenario predicted a maximum drawdown of less than 5 0.3 feet (0.09 m) in the Biscayne aquifer west and north of the CCS, resulting in minimal 6 potential to impact sawgrass marsh wetlands in the affected areas. 7 Consistent with the SFWMD report and the modeling results discussed above, FPLs 8 environmental report predicts retraction of the westward plume to the edge of the CCS by about 9 5 years and complete retraction within 10 years (i.e., by about 2028), with minor aquifer 10 drawdown impacts. Thus, FPL would achieve the compliance deadline for retraction of the 11 hypersaline plume and its effect on the location of the regional saltwater interface, as set forth in 12 its 2016 consent order with FDEP (FDEP 2016e), without undue impact on groundwater 13 resources or producing unintended groundwater use conflicts. In view of the SFWMD and Tetra 14 Tech conclusions, the NRC staff concludes that recovery well operations to be completed prior 15 to the start of the subsequent license renewal term for Turkey Point (i.e., 2032 for Unit 3 and 16 2033 for Unit 4), will achieve their intended results. Moreover, even if the groundwater 17 remediation timeframe is extended or delayed, the modeling results and the safeguards 18 imposed by SFWMD through permit conditions provide reasonable assurance that any impacts 19 on groundwater resources and users would be mitigated, while producing beneficial effects on 20 groundwater quality. 21 The marine wells, which FPL uses to pump seawater into the CCS, have a maximum production 22 capacity of about 45 mgd (170,300 m3/day). FPL has used the marine wells intermittently since 23 they were installed in 2015 to lower salinity in the CCS under abnormal conditions. For 24 instance, while the marine wells were not used in 2016, FPL diverted marine well water into the 25 CCS during a 6-month period in 2017 (FPL 2018m). Marine well water was most recently used 26 in conjunction with water pumped from the newly operational Upper Floridan aquifer freshening 27 wells (i.e., wells F-1, F-3, F-4, F-5, F-6), to manage CCS salinity levels during an exceptionally 28 dry period. This period of very low rainfall began in November 2016 and lasted through the end 29 of the dry season until September 2017 (FPL 2017a, FPL 2017b, FPL 2018m). While operation 30 of the marine wells does not require a water use permit from SFWMD, their operation is subject 31 to FPLs consent agreement (MDC 2015a) with Miami-Dade County DERM. The agreement 32 specifies that the marine wells may only be used to lower salinity in the CCS under 33 extraordinary circumstances. 34 The NRC staff does not expect that periodic use of the marine wells, as might be necessary 35 under abnormal conditions within the CCS, during the period of continued operations extending 36 through the subsequent license renewal term would have any impact on groundwater quality or 37 quantity. The marine wells, located on the Turkey Point peninsula on Biscayne Bay and east of 38 Turkey Point, withdraw saltwater from the upper part of the Biscayne aquifer and would not be 39 expected to impact any wells withdrawing water from the inland portions of the Biscayne aquifer. 40 This is because the permeable Biscayne aquifer in this area is recharged from Biscayne Bay, 41 and periodic well operation would be unlikely to substantially alter groundwater flow in the 42 affected area or result in any substantial drawdown in the Biscayne aquifer. 43 Conflicts Analysis for the Upper Floridan Aquifer 44 In 2017, FPLs groundwater withdrawals from the Upper Floridan aquifer totaled 7,137.2 mgy 45 (27.0 million m3/yr). This equates to an average withdrawal of 19.6 mgd (74,200 m3/d), or 46 approximately 13,600 gpm (51,500 L/min) (see Section 3.5.2.3). Of the total withdrawn, 4-30

1 approximately 13.1 mgd (49,600 m3/day) was associated with operation of the sites freshening 2 well system (i.e., wells F-1, F-3, F-4, F-5, F-6) for the CCS, with the remainder (i.e., about 3 6.5 mgd (24,600 m3/yr)) associated with the use of the three saline production wells (PW-1, 4 PW-3, PW-4). 5 FPLs modified site certification and associated conditions of certification for the Turkey Point 6 site authorizes the withdrawal of 14.06 mgd (53,200 m3/day) of groundwater from the upper 7 production zones of the Upper Floridan aquifer for cooling water for Unit 5 and process water for 8 Units 1, 2, 3, 4, and 5 (i.e., from the saline production wells) and an additional 14 mgd 9 (53,000 m3/day) for CCS salinity reduction (freshening). Thus, FPLs State-issued site 10 certification authorizes a total average daily withdrawal of 28.06 mgd (106,200 m3/day) from the 11 Upper Floridan aquifer (State of Florida Siting Board 2016, FDEP 2016b) (Section 3.5.2.3). 12 FPL commissioned the development of a technical evaluation by Tetra Tech (Tetra Tech 2014) 13 in support of FPLs proposed use of Upper Floridan aquifer withdrawals for CCS freshening as 14 part of the 2014 site certification modification effort (FPL 2018n). The East Coast Floridan 15 Aquifer System Model - Phase 2 (ECFAS2) was used to evaluate potential aquifer drawdown 16 and impacts on other groundwater users from the proposed groundwater use. As Tetra Tech 17 documented in its report (Tetra Tech 2014), the original ECFAS2 model is a regional, 18 density-dependent groundwater flow and transport model originally developed for the SFWMD 19 to meet SFWMDs minimum basis of review requirements for water use permitting. The 20 contractor modified and adapted the ECFAS2 model so that the groundwater flow component of 21 the model could be used and calibrated it to current regional conditions (e.g., water levels). 22 Site-specific hydrogeologic conditions were then incorporated into the adapted model by 23 recalibrating the model using two aquifer performance tests performed at Turkey Point. This 24 modified regional model (FPL Floridan model) was used to assess drawdown and potential 25 groundwater use conflicts resulting from the proposed FPL withdrawals at the Turkey Point site 26 and at offsite, regional locations, including potentially affected municipal wellfields (FPL 2018n, 27 Tetra Tech 2014). 28 As part of the modeling effort, two sets of simulations were run to assess drawdown in the 29 Upper Floridan aquifer commensurate with SFWMD requirements for water use permitting. The 30 first simulation projected drawdown due to sustained withdrawal at the maximum permitted rate 31 from the freshening system wells alone. The second simulation included the freshening system 32 well production in combination with other existing permitted withdrawals (using permitted rates) 33 in the region. Each simulation set considered two scenarios: a base case simulating pumping at 34 wells F-1 through F-5 (no pumping at F-6) and an alternative case simulating pumping at wells 35 F-1 and F-3 through F-6 (no pumping at F-2). In the simulations, the total production volume 36 was distributed evenly among FPLs wells. 37 First, SFWMDs basis of review for water use permitting requires that the 1-foot (0.3-m) 38 drawdown contour at permitted wells be determined. Based on this criterion, the modeling 39 results obtained from the FPL Floridan model (Tetra Tech 2014) show that operation of FPLs 40 freshening system wells at the maximum permitted rate results in four existing aquifer users 41 falling within the 1-foot (0.3-m) drawdown contour attributable to withdrawals from FPLs salinity 42 reduction wells. These locations include the Sound Golf Club, Ocean Reef Club, Florida Keys 43 Aqueduct Authority, MDWSD South Miami Heights wellfield, and FPL Unit 5 well (PW-1). 44 A maximum drawdown of 15.1 feet (4.6 m) is predicted to occur on the Turkey Point site (i.e., at 45 salinity reduction well F-3). For offsite, non-FPL wells, the model projects a maximum 46 drawdown of 2.26 feet (0.7 m) at the MDWSDs South Miami Heights wellfield, located 4-31

1 approximately 10.3 mi (16.6 km) north, northwest of the center point of FPLs freshening well 2 system. However, the incremental drawdown attributable to FPL freshening well system 3 withdrawals constitutes less than 5 percent of the total predicted cumulative drawdown 4 (i.e., drawdown from all permitted withdrawals from the Upper Florida aquifer) at the South 5 Miami Heights wellfield. In contrast, at the Florida Keys Aqueduct Authority located 6 approximately 10 mi (16 km) to the west, the projected incremental drawdown (i.e., 2.16 feet 7 (0.66 m)) is 12 percent of the total cumulative drawdown. The incremental drawdown 8 contribution is also higher for permitted users that are closer to the Turkey Point site. 9 Specifically, the predicted incremental drawdown (2.21 feet (0.67 m)) at Sound Golf Club and 10 Ocean Reef Club (about 9 mi (14 km) south of the FPL freshening wells) is 19 percent of the 11 total cumulative drawdown. Nevertheless, as documented in the modeling report, the predicted 12 incremental drawdowns are conservative or bounding estimates (i.e., the report overestimates 13 the drawdown due to FPL wells at offsite locations than would likely be observed). In all, the 14 modeling analysis performed demonstrates that operation of FPLs salinity reduction wells 15 (freshening well system) is likely to produce measurable, incremental drawdowns in other offsite 16 Upper Floridan aquifer wells. 17 Further, the modeling results indicate that operation of the FPL freshening well system would be 18 unlikely to result in any changes to regional water quality, as the Upper Floridan aquifer is 19 already brackish, no saltwater interface exists in the confined system, and water quality 20 changes experienced by other aquifer users have been minor (Tetra Tech 2014). Nonetheless, 21 SFWMD (SFWMD 2012) has documented that wells producing from the Upper Floridan aquifer 22 can experience a degradation in water quality due to vertical seepage (upconing) or lateral 23 movement of more saline water over time. 24 In accordance with the modified site certification and associated conditions of certification for 25 the Turkey Point site (State of Florida Siting Board 2016, FDEP 2016b), FPL is required to 26 mitigate harm to offsite groundwater users (either related to water quantity or quality) as well as 27 to offsite water bodies, land uses, and other beneficial uses. As necessary, the SFWMD can 28 order FPL to reduce withdrawals or undertake other mitigative actions. FPL is also required to 29 regularly monitor the freshening well system for a number of water quality parameters including 30 TDS and chlorides and report the results to FDEP and Miami-Dade County on a quarterly basis 31 (FDEP 2016b). Additionally, the 2015 consent agreement with Miami-Dade County DERM 32 requires FPL to evaluate alternative water sources for freshening the CCS, including the use of 33 reclaimed wastewater from the County South District Wastewater Treatment Plant, as further 34 described in Section 3.5.2.3 of this SEIS. 35 Summary of Groundwater Use Conflicts Evaluation 36 Based on the analyses performed by FPL, the NRC staffs review indicates that current and 37 projected groundwater withdrawals associated with FPLs operation of its Biscayne aquifer 38 marine well and recovery well systems would be unlikely to have any noticeable, adverse 39 impact on any supply wells beyond the confines of the Turkey Point site. This is because 40 drawdowns in the unconfined Biscayne aquifer are projected to be minor and FPLs withdrawals 41 would induce no adverse changes in the Biscayne aquifer or affect other permitted users of the 42 aquifer. Additionally, modeling projections indicate that FPLs operation of the recovery well 43 system will reduce salinity in the Biscayne aquifer and reduce the westward migration of the 44 regional saltwater interface. Recovery well system operations are expected to be completed 45 during the current renewed operating license term, although the NRC staff recognizes that some 46 uncertainty exists regarding the precise time by which the recovery well system will have 47 achieved its objectives. 4-32

1 FPLs continued operation of its Upper Floridan aquifer production wells, particularly the 2 freshening well system, is likely to affect offsite well systems by increasing drawdown in the 3 aquifer beyond that currently being experienced due to regional groundwater production alone. 4 Currently, available information indicates that FPL will need to operate the five CCS freshening 5 wells (i.e., wells F-1, F-3, F-4, F-5, F-6) in addition to its three saline production wells (PW-1, 6 P-3, PW-4) during the subsequent license renewal period of extended operation. The NRC staff 7 finds that the projected drawdowns would noticeably affect the Upper Floridan aquifer, but that 8 FPLs continued withdrawals would not destabilize the groundwater resource or impair the use 9 of the Upper Floridan aquifer by other users and well systems during the period of subsequent 10 license renewal. 11 Finally, as stated in its environmental report, FPL does not anticipate the need to withdraw 12 groundwater at a rate exceeding its current permits and/or authorizations during the subsequent 13 license renewal period (FPL 2018f). In summary, based on the evaluation presented above, the 14 NRC staff anticipates that operation of the recovery well system will not result in any 15 interference with existing permitted uses of groundwater, will not impact natural resources, and 16 will not result in lateral movement of the saltwater interface in the Biscayne aquifer. Further, 17 intermittent operation of FPLs marine wells is not expected to substantially alter groundwater 18 flow or result in any substantial drawdown in the Biscayne aquifer. For the Upper Floridan 19 aquifer, groundwater modeling performed to evaluate aquifer response from continued 20 operation of FPLs freshening well system indicates the potential for appreciable drawdowns in 21 offsite production wells, including in potable water wells located approximately 10 mi (16 km) 22 from the Turkey Point site. While the projected drawdowns would be noticeable in affected 23 offsite wells, the effects would not be expected to affect water availability or impair the Upper 24 Floridan aquifer as a resource. Consistent with these impacts, the NRC staff concludes that the 25 potential for groundwater use conflicts from FPLs groundwater withdrawals would be SMALL 26 for the Biscayne aquifer and MODERATE for the Upper Floridan aquifer during the subsequent 27 license renewal term. 28 Radionuclides Released to Groundwater 29 All commercial nuclear power plants routinely release radioactive gaseous and liquid materials 30 into the environment. These radioactive releases are designed to be planned, monitored, 31 documented, and released into the environment at designated discharge points. In contrast, 32 this issue considers the potential impact to groundwater quality from the unplanned, inadvertent 33 discharge of liquids containing radionuclides into groundwater. Such unknown, uncontrolled, 34 and unmonitored releases of radioactive liquids have occurred at nuclear power plant sites from 35 power plant systems, piping, spent fuel pools, valves, and tanks. The majority of the inadvertent 36 liquid release events involved tritium, which is a radioactive isotope of hydrogen. However, 37 other radioactive isotopes, such as cesium and strontium, have also been inadvertently 38 released into the groundwater at some sites. The inadvertent release of radionuclides to 39 groundwater is a Category 2 issue and requires a plant-specific assessment. 40 In evaluating the potential impacts on groundwater quality associated with license renewal, the 41 NRC staff uses as its baseline the existing groundwater conditions described in Sections 3.5.2.1 42 through 3.5.2.3 of this SEIS. These baseline conditions encompass the existing quality of 43 groundwater potentially affected by continued operations (as compared to relevant State or 44 Environmental Protection Agency (EPA) primary drinking water standards), as well as the 45 current and potential onsite and offsite uses and users of groundwater for drinking and other 46 purposes. The baseline also considers other downgradient or in-aquifer uses and users of 47 groundwater. 4-33

1 For the Turkey Point site, FPL participates in the Nuclear Energy Institutes NEI 07-07, Industry 2 Ground Water Protection Initiative (NEI 2007), which is focused on actions to improve 3 management and response to the inadvertent release of radioactive substances to subsurface 4 soils and water. Since 2010, FPL has maintained a radiological environmental sampling and 5 analysis program for Turkey Point to meet the recommendations of NEI 07-07. FPL performs 6 groundwater monitoring at 28 onsite locations to monitor for potential inadvertent radioactive 7 releases via potential groundwater pathways at the site in accordance with site procedures. 8 Samples are collected on at least a quarterly basis, or more frequently if deemed necessary. 9 FPL reports the results in annual radiological environmental operating reports and submits 10 these to the NRC. 11 FPL reports that it has experienced a number of inadvertent releases of radionuclides at Turkey 12 Point with the potential to reach groundwater over the last 5 years, which the NRC staff has 13 reviewed and summarized in Section 3.5.2.2 of this SEIS. Seven such releases were recorded 14 over the period of August 2014 through October 2017. FPL documents such unplanned 15 releases in its annual radioactive effluent release reports, which it submits to the NRC. The 16 NRC staff reviewed these reports as part of this environmental review. The releases generally 17 involved water containing tritium as well as other radionuclides including cobalt-58 and 18 sodium-24. 19 The largest inadvertent release, by liquid volume, involved a sustained release of component 20 cooling water from a leaking heat exchanger, totaling an estimated 4,828 gal (18,280 L). This 21 release occurred during the period from July 26 to September 15, 2015. As discussed in 22 Section 3.5.2.2 of this SEIS, other releases occurred in 2014, 2015, 2017, and 2018, involving 23 substantially smaller releases. In all cases, FPL stopped ongoing releases, surveyed the 24 release area, and increased groundwater sampling in potentially affected areas, as appropriate. 25 FPL documented all such events in the Turkey Point corrective action program, as appropriate. 26 Table 3-5 in Section 3.5.2.2 of this SEIS summarizes the latest available radiological 27 groundwater monitoring results for Turkey Point and compares the results to historical maximum 28 observed concentrations at each well location. Groundwater monitoring shows that tritium is 29 detectable in underlying groundwater in and around the Turkey Point nuclear island and in 30 areas adjoining the intake and discharge canals. This is not unexpected given the discharge of 31 monitored and permitted effluents containing tritium to the unlined CCS, which is in hydraulic 32 communication with the underlying Biscayne aquifer. 33 As shown in Table 3-6, in 2017, tritium concentrations in groundwater at Turkey Point ranged 34 from below the minimum detectable concentration to a maximum of 13,600 pCi/L at monitoring 35 well PTN-MW-8S. This maximum tritium level was observed during the fourth quarter of 2017. 36 Monitoring well PTN-MW-8S is located near the Turkey Point Unit 3 refueling water storage 37 tank, between Unit 3 and the cooling water intake canal coming off the CCS (see Figure 3-15). 38 As for plant storm drains, the peak concentration was measured in the southeast storm drain at 39 13,000 pCi/L. This location is on the south side of the intake canal and east of Unit 3 and 40 monitoring well PTN-MW-8S. As referenced in Section 3.5.2.2, measured tritium in storm drains 41 is heavily influenced by the inflow of water from the CCS. 42 Surficial groundwater (i.e., the Biscayne aquifer) that has been affected by inadvertent releases 43 within the Turkey Point plant property is classified by the FDEP as Class G-Ill waters, which 44 means it is neither a current nor potential future source of drinking water. There are no 45 discernible trends in the radiological groundwater protection monitoring results that would 46 indicate either a new inadvertent release or an ongoing inadvertent release of radionuclides to 4-34

1 groundwater at Turkey Point. Further, the data indicate that there is no occurrence or migration 2 of tritium in groundwater at concentrations exceeding either the tritium limit (30,000 pCi/L) 3 prescribed by the plant Offsite Dose Calculation Manual (FPL 2013a) or the EPA primary 4 drinking water standard (20,000 pCi/L) (40 CFR 141.16, Maximum Contaminant Levels for Beta 5 Particle and Photon Radioactivity from Man-Made Radionuclides in Community Water 6 Systems). 7 Based on the information presented and the NRC staffs review of groundwater monitoring data, 8 the NRC staff finds that inadvertent releases of radionuclides (primarily tritium) have not 9 substantially impaired site groundwater quality within the Biscayne aquifer and have not affected 10 groundwater use beyond the Turkey Point site. Thus, the NRC staff concludes that 11 groundwater quality impacts from inadvertent releases of radionuclides are SMALL and are 12 projected to remain SMALL during the subsequent license renewal term. 13 4.5.2 No-Action Alternative 14 4.5.2.1 Surface Water Resources 15 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 16 Turkey Point would shut down on or before the expiration of the current renewed operating 17 licenses. During shutdown, there would not be any surface water consumption or offsite 18 discharges to surface water bodies. All liquid discharges from the shutdown facility, including 19 storm water, would continue to flow into the CCS. Other facilities at the Turkey Point site would 20 continue to discharge to the CCS, including cooling tower blowdown from Unit 5. Water from 21 the CCS would continue to be circulated through retired fossil fuel Units 1 and 2. However, this 22 circulation would not add heat to the CCS. 23 After shutdown, the temperature of water within the CCS would be much lower and the rate of 24 evaporation of water from the CCS would decrease. The NRC staff expects that FPL would 25 continue to implement State- and County-required programs to reduce salinities and to control 26 ammonia and nutrients within the CCS, until the desired objectives are achieved. These actions 27 would reduce the potential for waters from the CCS to impact surface water bodies via the 28 groundwater pathway. Therefore, the NRC staff concludes that the impacts to surface water 29 resources from the no-action alternative would be SMALL. 30 4.5.2.2 Groundwater Resources 31 Miami-Dade Water and Sewer Department (MDWSD) supplies potable water to Turkey Point for 32 process water makeup, potable uses, and fire protection uses. The source of this water is 33 groundwater pumped from the Biscayne aquifer. With the cessation of operations, FPLs use of 34 potable water at Turkey Point for these uses would be greatly reduced but would not likely 35 cease until sometime during decommissioning. Similarly, FPLs use of groundwater from the 36 Upper Floridan aquifer to supply water for Turkey Point uses would also likely be reduced as a 37 result of shutdown and would eventually cease. 38 Sanitary wastewater discharges to the Boulder Zone via Turkey Points injection well and septic 39 systems would also be reduced as the plant workforce is drawn down. 40 As described in Section 4.5.2.1 of this SEIS, shutdown of Turkey Point would entail a gradual 41 reduction and eventual cessation of condenser cooling water and service water withdrawals 42 from, and return discharges to, the CCS. However, the NRC staff expects that the CCS would 4-35

1 continue to receive effluent discharges from Turkey Point Unit 5 for the foreseeable future as 2 well as stormwater runoff from the Turkey Point plant complex and from the balance of the 3 Turkey Point site. Consequently, water in the CCS would continue to be exchanged with 4 groundwater in the underlying Biscayne aquifer. 5 The shutdown of Turkey Point would substantially reduce thermal discharges to the CCS as well 6 as cooling water and other effluents from the plants cooling water system. This flow reduction 7 would reduce groundwater mounding (i.e., a localized increase in the water table) beneath the 8 CCS and reduce the generation of hypersaline water. As a result, the amount of water used to 9 support freshening activities in accordance with the provisions of FPLs 2015 consent 10 agreement with Miami-Dade County DERM (MDC 2015a) and the 2016 FDEP consent order 11 (FDEP 2016e) could be reduced. Currently, the principal source of water for salinity 12 management (i.e., freshening) in the CCS and for reducing the generation of hypersaline 13 groundwater beneath the CCS is derived from five production wells tapping the Upper Floridan 14 aquifer. These withdrawals are described in Section 3.5.2.3 of this SEIS and are evaluated in 15 Section 4.5.1.2 above. Nevertheless, with the shutdown of Turkey Point, the NRC staff expects 16 that some use of water by FPL for salinity management in the CCS would continue, possibly at 17 a reduced rate. 18 Based on the above considerations, the NRC staff concludes that the overall impact of the 19 no-action alternative on groundwater resources would be SMALL. 20 4.5.3 Replacement Power Alternatives: Common Impacts 21 4.5.3.1 Surface Water Resources 22 For all replacement power alternatives considered, the NRC staff assumes that surface water 23 resources would not be consumed and liquid discharges to adjacent surface water bodies would 24 not be allowed during both construction and operation. During construction, all water from 25 dewatering and other activities would be discharged into the CCS. During operations, cooling 26 tower blowdown and radiological liquid discharges would be deep well injected into the Boulder 27 Zone of the Floridan aquifer. Stormwater would be discharged into the CCS. 28 As discussed in the no-action alternative, under a replacement power alternative, the CCS 29 would no longer be used for cooling by Units 3 and 4 or by any of the replacement power 30 alternatives evaluated. Consequently, the potential for impacts from the CCS on adjacent 31 surface water bodies via the groundwater pathway would be reduced. Therefore, the NRC staff 32 concludes that the common impacts on surface water resources would be SMALL. 33 4.5.3.2 Groundwater Resources 34 Construction 35 Construction activities associated with thermoelectric power facilities at the Turkey Point site 36 would likely require groundwater dewatering, especially of deep excavations associated with 37 emplacement of facility foundations and substructures. This would require the use of 38 cofferdams, sheet pilings, sumps, wells, or other methods to address high water-table 39 conditions. Use of crushed limestone fill at construction sites would reduce the relative depth of 40 excavation work and would minimize post-construction impacts. 4-36

1 Excavation work and dewatering would affect the Biscayne aquifer. As previously evaluated by 2 the NRC staff for the construction of Turkey Point Units 6 and 7, dewatered areas of the aquifer 3 would be quickly recharged locally from surface-water features including the cooling canals, 4 Biscayne Bay, the L-31E Canal, aquifer inflow, and infiltration of rainfall. It is possible that 5 dewatering could induce groundwater flow from the inland portion of the aquifer through deeper 6 permeable layers and toward the dewatering points. However, the volume of inland 7 groundwater captured would be very small (NRC 2016a). Dewatering at the rates (400 to 8 1,200 gpm (1,500 to 4,500 L/min) projected in Section 4.2.1 of the final EIS for the Turkey Point 9 Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a) would require a water use 10 permit issued by the South Florida Water Management District (SFWMD) (FAC 40E-2). The 11 NRC staff expects that any impacts on groundwater flow and quality within the portions of the 12 Biscayne aquifer affected by dewatering would be highly localized and of short duration, with 13 minor effects on other aquifer users. 14 Once extracted, groundwater would be managed in accordance with Florida Department of 15 Environmental Protection (FDEP) requirements. For example, discharge of extracted 16 groundwater would be governed by conditions specified in an FDEP-issued NPDES general 17 (generic) permit for stormwater discharge from large and small construction activities 18 (FDEP 2018a, FPL 2018f). Dewatering flows could also be discharged to the CCS, which would 19 likely require a modification of the applicants NPDES permit (i.e., industrial wastewater facility 20 permit). A similar scenario was previously evaluated by the NRC staff in Section 4.2.1.4 of the 21 final EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176). There, the 22 NRC staff evaluated a maximum discharge rate to the CCS of 1,200 gpm (450 L/min), 23 equivalent to 1.7 mgd (6,500 m3/day) over an assumed dewatering period of 1 year. In 24 summary, the NRC staff determined that such a discharge rate would generally not be 25 detectable in the CCS as that rate of discharge would equate to about 0.06 percent of the 26 recirculating flow rate of the CCS. The NRC staff further concluded that the impacts on 27 groundwater quality, including from additional seepage from the CCS, would be minor 28 (NRC 2016a). 29 Construction of replacement power generating facilities at the Turkey Point site would increase 30 the amount of impervious surface as well as alter the subsurface strata because of excavation 31 work and the placement of backfill following facility completion. While an increase in impervious 32 surface would reduce infiltration and reduce groundwater recharge, the effects on water-table 33 elevations in the underlying Biscayne aquifer would likely be very small given the relatively small 34 surface area affected and the high permeability of the aquifer. Below-grade portions of new 35 power generating facilities at the site could alter the direction of groundwater flow. Such effects 36 would likely be localized, and the NRC staff does not expect them to affect offsite groundwater 37 users or adjacent surface water bodies, including Biscayne Bay. 38 Application of best management practices in accordance with a stormwater pollution prevention 39 plan developed for the FDEP-issued NPDES generic permit, including appropriate waste 40 management, water discharge, and spill prevention practices, would prevent or minimize any 41 areawide groundwater quality impacts during construction. 42 The construction of additional onsite underground injection wells and associated monitoring 43 wells may be necessary to support the disposal of effluent streams from operations. Such wells 44 could also be used to dispose of any wastewaters generated during facility construction. In 45 association with the construction of Turkey Point Units 6 and 7, the NRC staff evaluated the 46 construction of 10 underground injection wells, 2 backup wells, and 6 dual-zone monitoring 47 wells. The wells would be more than 3,000-feet (914-m) deep and completed in the 4-37

1 Boulder Zone of the Lower Floridan aquifer. Construction of these wells would be subject to 2 FDEP Class I industrial waste underground injection control permits (FAC 62-528). In 3 Section 4.2.3 of the final EIS for the Turkey Point Units 6 and 7 combined licenses 4 (NUREG-2176), the NRC staff determined that activities related to the construction of injection 5 wells and monitoring wells in the Boulder Zone would have negligible effects on groundwater 6 quality in the surficial Biscayne aquifer and the deeper Floridan aquifer system (NRC 2016a). 7 Water would be required for such uses as dust control and soil compaction, as well as to meet 8 the drinking and sanitary needs of the construction workforce during the construction period for 9 all facilities. The use of portable sanitary facilities, serviced by a commercial vendor, would 10 serve to reduce water use and sanitary wastewater generation by the construction workforce. 11 Consistent with the assumptions in FPLs environmental report submitted as part of this 12 subsequent license renewal application and as previously considered in the final EIS for the 13 Turkey Point Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a), the NRC staff 14 assumes that water would be obtained from the Miami-Dade Water and Sewer Department 15 (MDWSD). The principal water source for the MDWSD is the Biscayne aquifer. The NRC staff 16 projects that maximum water use to support construction would be approximately 0.8 mgd 17 (3,000 m3/day). The volume of water required would be a very small percentage of the capacity 18 of the County system (NRC 2016a). 19 Operation 20 Post-construction groundwater dewatering may be required during the operational period of the 21 onsite power generating facilities. Dewatering rates would be much lower than those projected 22 for the construction period. Operational dewatering would be subject to water use permitting 23 requirements administered by the South Florida Water Management District (SFWMD) 24 (FAC 40E-2). Once extracted, groundwater would be managed in accordance with FDEP 25 requirements, including applicable NPDES permitting requirements. 26 Onsite thermoelectric power generating facilities would use mechanical draft cooling towers for 27 condenser cooling. For the purposes of analysis and as referenced in Section 2.2 of this SEIS, 28 the NRC staff assumes that these cooling towers would be similar to those previously described 29 in Section 3.4.2.2 of the final EIS for the Turkey Point Units 6 and 7 combined licenses 30 (NUREG-2176) (NRC 2016a). The source of makeup water would be reclaimed wastewater 31 supplied by the MDWSD (see Table 2-1). The NRC staff assumes that no groundwater would 32 be directly used to support replacement power generating facilities. 33 Replacement power facilities would also require freshwater for general service water, fire 34 protection, demineralized water makeup, and potable and sanitary use. The NRC staff 35 assumes that this water would be obtained from MDWSD via an existing right-of-way and/or a 36 proposed new supply pipeline to the Turkey Point site as described in Section 3.2.3 of the final 37 EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a). 38 The onsite thermoelectric power generating facilities would produce cooling tower blowdown, 39 treated radiological wastewater, sanitary wastewater, and other effluent streams. Consistent 40 with the assumptions in the final EIS for the Turkey Point Units 6 and 7 combined licenses 41 (NUREG-2176) (NRC 2016a), the NRC staff assumes that these effluent streams would be 42 disposed of via underground injection wells to the Boulder Zone. Disposal would occur via the 43 same or similar wells as proposed for use in support of Unit 6 and 7 operations. Any new wells 44 would be constructed and operated in accordance with underground injection control permits 45 issued by the FDEP (FAC R62-528). 4-38

1 In Sections 3.4.2, 5.2.1.3, 5.2.3, and 5.8 of the final EIS for the Turkey Point Units 6 and 7 2 combined licenses (NUREG-2176) (NRC 2016a), the NRC staff evaluated the deep well 3 injection of up 90 mgd (341,000 m3/day) of cooling water blowdown and other liquid waste 4 streams from proposed Units 6 and 7. The NRC staff concluded in part that proper well design 5 and isolation of the Boulder Zone by low-permeability strata would prevent degradation of 6 overlying underground sources of drinking water. The Boulder Zone deep injection wells would 7 be permitted by FDEP. This permit would require FPL to implement institutional controls and 8 monitoring programs to detect upward migration of injected wastewater. As a result, the NRC 9 staff concluded that operational groundwater-quality impacts would be SMALL (NRC 2016a). 10 It is expected that stormwater runoff from onsite thermoelectric power generating facilities would 11 be conveyed to the CCS. Use of the CCS would require that FPL modify its NPDES permit 12 (i.e., industrial wastewater facility permit) for operation of the facility. Since the CCS is in 13 hydraulic communication with the underlying Biscayne aquifer, any pollutants in stormwater 14 runoff could reach groundwater. Nevertheless, as facility operations would be subject to 15 pollution prevention and best management practices required by FDEP, the NRC staff considers 16 potential water quality impacts on groundwater quality to be minimal. 17 4.5.4 New Nuclear Alternative 18 4.5.4.1 Surface Water Resources 19 The NRC staff did not identify any impacts to surface water resources for this alternative beyond 20 those discussed above as common to all replacement power alternatives. Therefore, the NRC 21 staff concludes that the impacts to surface water resources from this alternative would be 22 SMALL. 23 4.5.4.2 Groundwater Resources 24 Groundwater use and quality impacts from construction and operations associated with the new 25 nuclear alternative would likely be similar to but somewhat less than those described and 26 assumed as common to all alternatives in Section 4.5.3.2. This is due to the reduced 27 construction footprint and operational impacts. The staff projects that the use of reclaimed 28 wastewater for cooling tower makeup and the generation of cooling tower blowdown and other 29 effluents would be reduced by about 30 percent, as compared to the proposed 30 Turkey Point Units 6 and 7. This would produce cooling tower blowdown along with other 31 effluents at a rate of approximately 9 mgd (34,100 m3/day). These wastewaters would be 32 disposed of by deep well injection into the Boulder Zone beneath the Turkey Point site (see 33 Section 4.5.3.2). Therefore, the NRC staff concludes that the impacts on groundwater 34 resources from construction and operations associated with the new nuclear alternative would 35 be SMALL. 36 4.5.5 Natural Gas Combined-Cycle Alternative 37 4.5.5.1 Surface Water Resources 38 The NRC staff did not identify any impacts to surface water resources for this alternative beyond 39 those discussed above as common to all replacement power alternatives. Therefore, the NRC 40 staff concludes that the impacts to surface water resources from the natural gas combined-cycle 41 alternative would be SMALL. 4-39

1 4.5.5.2 Groundwater Resources 2 Groundwater use and quality impacts from construction activities and operations associated 3 with the natural gas combined-cycle alternative would be much smaller than those described in 4 Section 4.5.3.2. This is because less extensive excavation work and associated dewatering 5 would be required for construction. As for operations, the NRC staff projects that cooling water 6 demand associated with operation of cooling towers and the generation of blowdown and other 7 effluent streams would be reduced by approximately 80 and 70 percent, as compared to the 8 proposed Turkey Point Units 6 and 7 and new nuclear alternative, respectively, given the 9 comparatively lower level of cooling needed for the natural gas plant. This would produce 10 cooling tower blowdown along with other effluents at a rate of approximately 2.4 mgd 11 (9,100 m3/day), which would be disposed of by deep well injection into the Boulder Zone (see 12 Section 4.5.3.2). 13 Construction of a new natural gas pipeline would result in additional ground-disturbing impacts 14 and the need for dewatering areas around pipeline pad and pier supports. However, any 15 groundwater impacts would likely be localized and temporary. 16 For this alternative, the NRC staff concludes that the impacts on groundwater resources from 17 construction and operations would be SMALL. 18 4.5.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 19 Generation) 20 4.5.6.1 Surface Water Resources 21 The NRC staff did not identify any impacts to surface water resources for this alternative, 22 beyond those discussed above as common to all replacement power alternatives. Therefore, 23 the NRC staff concludes that the impacts to surface water resources from this alternative would 24 be SMALL. 25 4.5.6.2 Groundwater Resources 26 Groundwater use and quality impacts from construction activities and operations associated 27 with the onsite natural gas combined-cycle component of this alternative would be very similar 28 to those referenced in Section 4.5.5.2. This is because the construction and operational 29 aspects of the natural gas combined-cycle power plant would be similar. 30 The NRC staff expects that there would be little or no groundwater use or groundwater quality 31 impacts for construction and operations of the onsite and offsite solar facilities. This is because 32 groundwater dewatering would likely be minimal due to the relatively small footprint of pad sites, 33 access roads, and utility corridors where excavation, grading, and trenching might be required. 34 Based on the above, the NRC staff concludes that the overall impacts on groundwater 35 resources from construction and operations associated with the combination alternative would 36 be SMALL. 4-40

1 4.5.7 Cooling Water System Alternative 2 4.5.7.1 Surface Water Resources 3 The NRC staff did not identify any impacts to surface water resources for this alternative beyond 4 those discussed above as common to all replacement power alternatives. Therefore, the NRC 5 staff concludes that the impacts to surface water resources from this alternative would be 6 SMALL. 7 4.5.7.2 Groundwater Resources 8 No onsite groundwater would be required to support cooling tower construction. Water would 9 be required for such uses as dust control, soil compaction, as well as to meet the drinking and 10 sanitary needs of the construction workforce during the construction period for all facilities. 11 Consistent with the assumptions in the final EIS for the Turkey Point Units 6 and 7 combined 12 licenses (NUREG-2176) (NRC 2016a), the NRC staff assumes that water for such uses would 13 be obtained from the Miami-Dade Water and Sewer Department (MDWSD), which primarily 14 uses the Biscayne aquifer as a water source. The NRC staff expects that construction water 15 would be trucked to the point of use as needed from onsite service connections with MDWSD. 16 Onsite water demands to support cooling tower construction could be reduced by the use of 17 ready-mix concrete and the use of portable sanitary facilities for construction workers that are 18 serviced offsite. 19 Groundwater dewatering would likely be required in excavations associated with below-grade 20 portions of the cooling towers. Construction activities would include the use of cofferdams, 21 sheet pilings, sumps, wells, or other methods to address high water-table conditions as they 22 exist at the Turkey Point site. Depending on the rate and duration of dewatering activities, 23 dewatering activities would have to be permitted under a SFWMD-issued water use permit or, 24 more likely, under a general permit-by-rule for temporary dewatering (FAC 40E-2). The NRC 25 staff expects that any impacts on groundwater flow and quality within the portions of the 26 Biscayne aquifer affected by dewatering would be highly localized and of short duration, with 27 minor effects on other aquifer users. 28 Once extracted, the NRC staff assumes that groundwater would be properly managed in 29 accordance with FDEP requirements. Specifically, an FDEP-issued NPDES general (generic) 30 permit for stormwater discharge from large and small construction activities would govern the 31 discharge of extracted groundwater and all ground-disturbing activities. The construction 32 contractor would be required to implement best management practices and other controls 33 (including appropriate waste management, water discharge, and spill prevention practices) 34 under a stormwater pollution prevention plan (FDEP 2018a). These would serve to mitigate any 35 impacts on groundwater quality during construction. 36 During commissioning of the cooling water system alternative, Turkey Point may be offline for a 37 period of time. Groundwater production on the Turkey Point site associated with the operation 38 of the five CCS freshening wells (F-1, F-3, F-4, F-5, F-6) withdrawing from the Upper Floridan 39 aquifer and the three saline production wells (PW-1, PW-3, PW-4) would be expected to 40 continue during the transition period at current rates. 41 As described in Section 4.5.2.2 for the no-action alternative, the NRC staff expects that the CCS 42 would continue to operate under this alternative and would receive cooling tower blowdown and 43 other effluents and runoff from Turkey Point Unit 5 as well as stormwater from the Turkey Point 4-41

1 plant complex and other FPL facilities. While the NRC staff expects that groundwater demands 2 for CCS freshening would decrease over time commensurate with the reduction in thermal 3 discharge to the CCS from Turkey Point Units 3 and 4, some use of groundwater (or other water 4 sources) would likely continue into the future. The NRC staff expects that the volume of water 5 needed for CCS freshening will be governed by the provisions of FPLs 2015 consent 6 agreement with Miami-Dade County DERM (MDC 2015a) and the 2016 FDEP consent order 7 (FDEP 2016e), recognizing that those requirements are subject to possible modification in the 8 future. 9 No onsite groundwater or MDWSD-supplied groundwater would be used during operation of the 10 Turkey Point cooling water system alternative, as the cooling towers would be supplied by 11 treated, reclaimed wastewater. Otherwise, onsite use of MDWSD-supplied groundwater from 12 the Biscayne aquifer for Turkey Point potable water and fire protection use would be similar to 13 the volumes used during the current renewed license period. 14 Operation of the mechanical-draft cooling towers for condenser cooling would produce cooling 15 tower blowdown at a projected rate of 11 mgd (41,600 m3/day). This effluent stream would 16 contain cooling water treatment and conditioning chemical residuals (e.g., biocides, corrosion 17 inhibitors) necessary for proper operation and maintenance of the cooling towers and 18 Turkey Point Units 3 and 4 circulating water system. Additionally, Turkey Point Units 3 and 4 19 operations would continue to produce various process water effluents, including liquid radwaste 20 effluents. The NRC staff assumes that these effluents would be disposed of by deep well 21 injection into the Boulder Zone, which would be regulated under a Class I underground injection 22 control permit issued by the FDEP (FAC 62-528). 23 As referenced in Section 4.5.3.2, the NRC staff previously evaluated the deep well injection of 24 up 90 mgd (341,000 m3/day) of cooling water blowdown and other liquid waste streams from 25 proposed Turkey Point Units 6 and 7. The NRC staff concluded in part that proper well design 26 and isolation of the Boulder Zone by low-permeability strata would prevent degradation of 27 overlying underground sources of drinking water. The Boulder Zone deep injection wells would 28 be permitted by FDEP, and FPL would be required to implement institutional controls and 29 monitoring programs to detect upward migration of injected wastewater. As a result, the NRC 30 staff concluded that operational groundwater-quality impacts would be SMALL (NRC 2016a). 31 The NRC staff finds that the disposal of effluents by deep well injection of effluents under this 32 alternative would be bounded by the cited analysis. 33 In consideration of the information and assumptions presented above, the NRC staff concludes 34 that the impacts on groundwater resources from construction and operation of the closed-cycle 35 cooling alternative would be SMALL. 36 4.6 Terrestrial Resources 37 This section describes the potential terrestrial resources impacts of the proposed action 38 (subsequent license renewal) and alternatives to the proposed action. 39 4.6.1 Proposed Action 40 As identified in Table 4-1, Applicable Category 1 (Generic) Issues for Turkey Point, in 41 Section 4.1 of this chapter, the impacts of all generic terrestrial resource issues would be 42 SMALL. According to the GEIS (NRC 1996 and 2013a), terrestrial resources would not be 43 significantly affected by continued operations associated with license renewal. For the 4-42

1 terrestrial resource issues addressed in the 2013 GEIS, no new and significant information was 2 identified that would alter the GEIS conclusions for Category 1 issues for Turkey Point 3 subsequent license renewal. New information related to one of these categories, Cooling 4 system impacts on terrestrial resources (plants with once-through cooling systems or cooling 5 ponds), is discussed below. Also, in Section 4.1 of this chapter, Table 4-2, Applicable 6 Category 2 (Site-Specific) Issues for Turkey Point, identifies one site-specific (Category 2) 7 issue related to terrestrial resources during the subsequent license renewal term. That issue is 8 also analyzed below. 9 New Information, Category 1 Issue, Cooling System Impacts on Terrestrial Resources (Plants 10 with Once-Through Cooling Systems or Cooling Ponds) 11 As referenced in Section 1.4 of this SEIS and as further described under Sections 1.5 and 1.8 of 12 the GEIS (NUREG-1437) (NRC 2013a), no additional site-specific analysis is required by the 13 NRC staff for Category 1 (generic) issues in the SEIS unless new and significant information is 14 identified that would change the conclusions in the GEIS. Where new and significant 15 information has been identified, the NRC staff would reconsider generic impacts in the SEIS. 16 The Category 1 issue, Cooling system impacts on terrestrial resources (plants with once-17 through cooling systems or cooling ponds), was first evaluated in the 1996 GEIS (NRC 1996) 18 under the name, Cooling pond impacts on terrestrial resources. This issue was modified and 19 renamed as part of the 10-year update to the GEIS, which was issued in June 2013 20 (NRC 2013a). 21 For the subject issue, the 2013 GEIS (NRC 2013a: 4 4-69) considers potential impacts to 22 terrestrial resources from contaminants and physical alterations of the environment resulting 23 from cooling system operations. As a part of the analysis, the 2013 GEIS describes several 24 site-specific examples of plants with cooling ponds and the NRC staffs conclusions regarding 25 the effects on terrestrial resources as documented in site-specific SEISs, including the potential 26 effects from the CCS at Turkey Point. The 2013 GEIS (NRC 2013a: page 4-68) specifically 27 states the following: 28 Groundwater quality can be degraded by contaminants present in cooling ponds 29 and cooling canals. Deep-rooted terrestrial plants could be exposed to these 30 contaminants. In addition, biota could be exposed to contaminants at locations 31 of groundwater discharge, such as wetlands or riparian areas. However, as 32 noted above, contaminant concentrations are typically very low, and any effects 33 on terrestrial plants would be expected to be SMALL. Mitigation may also be 34 implemented where sensitive resources could be affected. At the Turkey Point 35 plant in Florida, for example, the flow of hypersaline groundwater from the 36 cooling canals toward the Everglades to the west is prevented by an interceptor 37 ditch, located along the west side of the canal system, from which groundwater 38 inflow is extracted (NRC 2002b). 39 Since publication of the 2013 GEIS, new information has indicated that the interceptor ditch has 40 not prevented groundwater migration west of the CCS. Section 3.6 of this SEIS presents and 41 considers relevant new information related to terrestrial resources at the Turkey Point site 42 concerning the subject issue. Specifically, Section 3.6.1 summarizes the results from FPLs 43 vegetative survey monitoring plan, which was required as a condition of its site certification from 44 the State of Florida (FPL 2018g). With respect to sawgrass (the most common species in 45 sawgrass marshes), Section 3.6.1 states that the seasonal and annual changes in sawgrass 4-43

1 height and live biomass were generally similar between the reference transect (T6), chosen for 2 being farther from the CCS, and transects that are closer to the CCS (T1-T4). The surveys 3 show that wetlands at different distances from the CCS exhibit similar growth trends. These 4 patterns suggest that landscape-scale environmental factors, such as the length of the 5 hydroperiod or overall water depth, have a greater effect on changes in live biomass and 6 sawgrass height than proximity to the CCS. In addition, the fluctuations in sawgrass height and 7 live biomass over time suggests that there is a high degree of natural variability influenced by 8 multiple environmental parameters. Therefore, even in light of the new information that the 9 hypersaline groundwater plume flows past the interceptor ditch, the most currently available 10 information described in Section 3.6.1 of this SEIS suggests that operation of the CCS does not 11 have a noticeable impact on wetlands or any other important attribute of the terrestrial resources 12 on or near Turkey Point. In conclusion, the NRC staff has determined that the new information 13 available since the publication of the 2013 GEIS is not significant because it does not change 14 the findings in the 2013 GEIS for the Category 1 issue related to Cooling system impacts on 15 terrestrial resources (plants with once-through cooling systems or cooling ponds). 16 4.6.1.1 Category 2 Issue Related to Terrestrial Resources: Effects on Terrestrial Resources 17 (Non-Cooling System Impacts) 18 According to the GEIS (NUREG-1437), non-cooling system impacts on terrestrial resources can 19 include those impacts that result from landscape maintenance activities, stormwater 20 management, elevated noise levels, and other ongoing operations and maintenance activities 21 that would occur during the subsequent license renewal period on or near a plant site. 22 Landscape Maintenance and Operational Activities 23 FPLs (FPL 2018f; FPL 2018g) landscape maintenance and operational activities during the 24 subsequent license renewal term would remain similar to those currently conducted. These 25 activities primarily consist of mowing, string trimming, hedge trimming, weed removal, herbicide 26 application, tree trimming, brush removal, debris removal, and the maintenance and repair of 27 plant infrastructure such as roadways, piping installations, fencing, and security-related 28 structures. FPL does not anticipate performing refurbishment during the subsequent license 29 renewal period (FPL 2018f). 30 Within developed portions of the sitesuch as near the power block, administrative buildings, 31 and transmission lines and associated infrastructurelandscape activities generally include 32 vegetative trimming and mowing, herbicide application, and infrastructure maintenance and 33 repair. Herbicide treatment would primarily occur in areas connecting the collector yard to the 34 switch yard. FPL (FPL 2018f) applies commercially approved herbicides in accordance with its 35 Florida site certification application and applicable Federal and State regulations. For example, 36 FPL must notify the Florida Department of Environmental Protection (FDEP) Southeast District 37 of the Department of Siting Coordination Office at least 60 days prior to the first use of an 38 herbicide. Herbicide treatment, vegetative trimming and mowing, and infrastructure 39 maintenance in these areas could disturb or displace wildlife and birds. However, most wildlife 40 near these areas are likely relatively tolerant of human activity given the current level of 41 operational activities onsite. Any wildlife that become disturbed or displaced when landscape 42 activities occur would be able to find similar habitat onsite or nearby. In addition, the 43 displacement period would be limited to a few hours or days. 44 Within less-developed portions of the site that contain high-quality terrestrial habitatssuch as 45 freshwater wetlands, mangroves, or wooded areasground-disturbing maintenance activities 4-44

1 include hand and mechanical vegetative control, hand and mechanical debris removal, 2 maintenance of the CCS access roads (e.g., mechanical scrapping and aggregate placement), 3 underground piping repair (e.g., digging and equipment staging), and equipment replacement at 4 groundwater wells and monitoring stations. FPL annually removes exotic species, such as 5 Australian pine (Casuarina equisetifolia) and Brazilian pepper (Schinus terebinthifolius), from 6 within CCS canals and berms and along the access and CCS perimeter roads. FPL removes 7 such species using an amphibious excavator backhoe and a D-3 Dozer, piling the vegetation on 8 the CCS berms and then burning the vegetation in accordance with the FPL burn permit issued 9 by the Florida Department of Agriculture and Consumer Services (FDACS) Permit 1373498 10 (FPL 2018g). Removal occurs along berms that provide habitat for federally protected species 11 (American crocodile (Crocodylus acutus)), State-protected species (least terns (Sterna 12 antillarum)), and other wildlife and birds. Within areas that FPL has defined as crocodile 13 sanctuaries, FPL maintains all native species after removing exotic species. On all other berms, 14 FPL uses power equipment to maintain a low level of small brush, grass, and weeds. Although 15 removal and burning could disturb wildlife and result in increased sedimentation within the CCS, 16 such impacts are likely minimized given that the burning activities occur in accordance with the 17 FDACS permit, and that work in or around active American crocodile nests sites is prohibited 18 from March to August. These and other potential impacts on the American crocodile are 19 addressed in detail in Section 4.8.1.1 of this SEIS, Species and Habitats Protected Under the 20 Endangered Species Act, and in the NRC staffs Biological Assessment (NRC 2018n). Wildlife 21 and birds would likely be displaced during such activities. However, displacement would be 22 limited to the short duration of the activity and similar habitat would be accessible both on and 23 within the vicinity of the site. In addition, the removal of the exotic species promotes the growth 24 of native and rare species. 25 Environmental impacts from landscape maintenance and operational activities would also be 26 minimized because FPL maintains environmental control procedures for any activities that result 27 in the clearing of land, excavation, or other activity that would alter the physical environment or 28 ecology of the site (FPL 2018f and FPL 2018g). FPLs procedures direct personnel to obtain 29 appropriate local, State, or Federal permits (or some combination of the three) before beginning 30 work; implement best management practices to protect wetlands, natural heritage areas, and 31 sensitive ecosystems (see the paragraph below, Stormwater Management); and consult the 32 appropriate agencies wherever federally or State-listed species may be affected. Turkey Points 33 Environmental Protection Plan contained in Appendix B of the current renewed operating 34 licenses requires FPL to prepare an environmental evaluation for any construction or 35 operational activities which may significantly affect the environment (NRC 2002a). If such an 36 evaluation indicates that an activity involves an unreviewed environmental question, the Turkey 37 Point Environmental Protection Plan requires that FPL obtain approval from the NRC before 38 performing the activity (NRC 2002d). The subsequent renewed licenses, if issued, would 39 include an environmental protection plan with identical or similar requirements. 40 Stormwater Management 41 Stormwater runoff from impervious surfaces can change the frequency or duration of inundation 42 and soil infiltration within wetlands, mangroves, and neighboring terrestrial habitats. Effects of 43 stormwater runoff may include erosion, altered hydrology, sedimentation, and other changes to 44 plant community characteristics. Runoff may contain sediments, contaminants and oils from 45 road or parking surfaces, or herbicides. At Turkey Point, stormwater collected in drainage 46 channels and floor drains is discharged directly to the CCS. Turkey Point does not discharge 47 stormwater directly into Biscayne Bay or any other surface waters other than the CCS. Use of 48 the stormwater conveyance system, which collects stormwater, minimizes the amount of excess 4-45

1 runoff that terrestrial habitats would receive and the associated effects. FDEP regulations 2 require a stormwater permit and Stormwater Pollution Prevention Plan for any construction 3 activities or activities that would result in the clearing of land, excavation, or other action that 4 would alter the physical environment or ecology of the site. FPLs Stormwater Pollution 5 Prevention Plan identifies potential sources of pollutants that could affect stormwater discharges 6 and identifies best management practices that FPL uses to reduce pollutants in stormwater 7 discharges to ensure compliance with applicable conditions of the permit (FPL 2018g). The 8 best management practices include soil stabilization, such as seeding and structural controls 9 (e.g., silt fences). FPL has also developed a Spill Prevention, Control, and Countermeasures 10 Plan that identifies and describes the procedures, materials, equipment, and facilities that are 11 utilized to minimize the frequency and severity of oil spills (FPL 2018f). Collectively, these 12 measures ensure that the effects to terrestrial resources from pollutants carried by stormwater 13 would be minimized during the proposed subsequent license renewal term. 14 Noise 15 The GEIS (NUREG-1437) (NRC 2013a) states that elevated noise levels from transformers and 16 other equipment could disrupt wildlife behavioral patterns or cause animals to avoid such areas. 17 However, limited wildlife occurs in areas of the Turkey Point site with elevated noise levels due 18 to the developed nature of those portions of the site, associated lack of high-quality habitat, and 19 regular presence of human activity. Wildlife that does occur in developed areas is likely tolerant 20 of disturbance due to decades of operations. Therefore, noise associated with the continued 21 operation of transformers and other plant equipment during the proposed subsequent license 22 renewal term is unlikely to create noticeable impacts on terrestrial resources. 23 Conclusion 24 Based on the NRC staffs independent review, the staff concludes that the landscape 25 maintenance activities, stormwater management, elevated noise levels, and other ongoing 26 operations and maintenance activities that FPL might undertake during the subsequent license 27 renewal term would primarily be confined to already-disturbed areas of the Turkey Point site. 28 Within less-developed portions of the site, disturbances to wildlife would be minimal, and wildlife 29 could use similar habitat nearby during the limited periods of the disturbance. Therefore, these 30 activities would neither have noticeable effects on terrestrial resources nor would they 31 destabilize any important attribute of the terrestrial resources on or in the vicinity of the Turkey 32 Point site. Accordingly, the NRC staff concludes that non-cooling system impacts on terrestrial 33 resources during the subsequent license renewal term would be SMALL. 34 4.6.2 No-Action Alternative 35 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 36 Turkey Point would shut down on or before the expiration of the current renewed licenses. 37 Some impacts on terrestrial resources would cease following reactor shutdown while other 38 impacts may continue to exist at a reduced level. For example, noise impacts and impacts 39 associated with herbicide application and landscape maintenance could continue for some time 40 following reactor shutdown depending on the level at which FPL continues to maintain 41 landscaped areas. Other impacts on terrestrial resources would be the same as if the plant 42 were still operating, such as the potential for bird collisions with plant structures and 43 transmission lines. The CCS would continue to operate under the no-action alternative because 44 it supports retired fossil fuel Units 1 and 2. FPL plans to continue to withdraw water from the 45 CCS to support these units operation in synchronous condenser mode over the course of the 4-46

1 proposed subsequent license renewal period, as described in Section 3.1.3, Cooling and 2 Auxiliary Water Systems. Additionally, Unit 5, which remains in operation, discharges 3 blowdown to the CCS. CCS conditions could change under the no-action alternative because 4 less heat would be discharged to the system, which would potentially make conditions less 5 saline and more favorable for birds and wildlife; on the other hand, flow would likely decrease 6 following shutdown because Turkey Point Units 3 and 4 would not require as much water, and 7 less flow could lead to stagnant conditions, which may be less favorable for birds and wildlife. 8 Regardless, FPL would continue CCS restoration activities, as described in Section 3.7, 9 Aquatic Resources. The State of Florida requires these activities under FPLs Nutrient 10 Management Plan which is independent of subsequent license renewal. As described in 11 Section 4.5.2.1 of this SEIS, the CCS would likely continue to provide wildlife habitat for foraging 12 and breeding. Thus, shutdown itself is unlikely to noticeably alter or have more than minor 13 effects on terrestrial resources. The NRC staff concludes that the impacts of the no-action 14 alternative on terrestrial resources during the proposed subsequent license renewal term would 15 be SMALL. 16 4.6.3 Replacement Power Alternatives: Common Impacts 17 Construction 18 Each replacement power alternative would entail construction and operation of a new energy 19 generating facility on FPLs existing Turkey Point site or the surrounding area and would result 20 in qualitatively similar impacts to terrestrial resources. During construction of a replacement 21 power facility, the use of the Turkey Point site would allow FPL to maximize existing buildings 22 and infrastructure. However, due to the prevalence of important terrestrial habitats onsite 23 such as freshwater wetlands, mangroves, and wooded habitatsit is unlikely that FPL would be 24 able to avoid impacting sensitive and important terrestrial habitats. Impacts from construction 25 could result in both the permanent and temporary loss of important terrestrial habitats, habitat 26 fragmentation, and habitat degradation as a result of runoff, erosion, and sedimentation, 27 depending on the specific areas used for construction. Wildlife and birds would likely avoid the 28 area during the construction of a replacement power facility due to noise and other 29 disturbances. Collisions with tall structures and vehicles could also result in wildlife and bird 30 mortality. Implementation of appropriate best management practices, revegetation following 31 construction, and required compensatory mitigation for unavoidable wetland impacts would 32 minimize such impacts. 33 Operation 34 In the GEIS (NUREG-1437) (NRC 2013a), the NRC staff concluded that for all nuclear power 35 plants, impacts to terrestrial resources from operation of nuclear and fossil-fueled plants would 36 be similar and would include cooling tower salt drift, noise, bird collisions with plant structures 37 and transmission lines, as well as impacts connected with herbicide application and landscape 38 management. Additional impacts to terrestrial resources during the operational period could 39 occur as a result of offsite mining, extraction, or waste disposal activities associated with each 40 plants particular type of fuel. 41 4.6.4 New Nuclear Alternative 42 The NRC staff did not identify any impacts on terrestrial resources for the new nuclear 43 alternative beyond those discussed in the impacts common to all replacement power 44 alternatives. However, the common impact onsite could be slightly more intense for the new 4-47

1 nuclear alternative as compared to the natural gas alternative. This can be attributed to the 2 larger land area required for the new nuclear power block, which could result in increased 3 erosion and potential introduction of sediments to wetland habitats. In addition, given the 4 prevalence of wetlands within the Turkey Point site, it is unlikely that FPL would be able to avoid 5 permanently filling or disturbing wetlands when siting the new nuclear alternative. Given that 6 the construction of the new nuclear alternative would result in the permanent disturbance, 7 fragmentation, and degradation of up to 360 ac (150 ha) of important terrestrial habitats, the 8 NRC staff concludes that the impacts to terrestrial resources from construction and operation of 9 a new nuclear alternative would be MODERATE. 10 4.6.5 Natural Gas Combined-Cycle Alternative 11 The onsite impacts on terrestrial resources would be less intense for construction of a natural 12 gas plant as compared to a new nuclear plant because the natural gas plant would disturb less 13 land. However, the natural gas alternative would also require construction of a 1,200-ac 14 (490-ha) long right-of-way for a gas pipeline, which could result in the loss, modification, and 15 fragmentation of important terrestrial habitats. Collocation of the right-of-way with other existing 16 rights-of-way would minimize the amount of habitat disturbance. The natural gas alternative 17 would also emit pollutants that could degrade wetland and other important habitats. The NRC 18 staff concludes that the impacts of constructing and operating the natural gas alternative on 19 terrestrial resources would be MODERATE due to the permanent disturbance, fragmentation, 20 and degradation of important terrestrial habitats. 21 4.6.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 22 Generation) 23 The NRC staff did not identify any impacts to terrestrial resources for the natural gas portion of 24 the combination alternative beyond those described for the natural gas-only alternative. For the 25 solar portion of the combination alternative, the exact level of disturbance to terrestrial habitats 26 and biota would depend on the amount of land required for each unit and the specific siting of 27 buildings and infrastructure within the site footprint. Due to the prevalence of important 28 terrestrial habitats within the areas where the solar units would be sited, it is likely that 29 construction would result in the temporary and permanent disturbance, fragmentation, and 30 degradation of important terrestrial habitats. The NRC staff concludes that the impacts of 31 implementing the combination alternative on terrestrial resources would be MODERATE during 32 construction and operation due to the impact on important terrestrial habitat. 33 4.6.7 Cooling Water System Alternative 34 The NRC staff did not identify any impacts on terrestrial resources for the cooling water system 35 alternative beyond those discussed in the impacts common to all replacement power 36 alternatives. In addition, the common impacts would be less intense for the cooling water 37 system alternative due to the smaller land area required for construction and operation. 38 Nonetheless, construction would likely result in the temporary or permanent disturbance, 39 fragmentation, and degradation of important terrestrial habitats. The NRC staff concludes that 40 the impacts to terrestrial resources from construction and operation of a cooling water system 41 alternative would be MODERATE due to the noticeable impacts from the permanent 42 disturbance, fragmentation, and degradation of important terrestrial habitats. 4-48

1 4.7 Aquatic Resources 2 This section describes the potential aquatic resources impacts of the proposed action 3 (subsequent license renewal) and alternatives to the proposed action. 4 4.7.1 Proposed Action 5 As identified in Table 4-1, Applicable Category 1 (Generic) Issues for Turkey Point, in 6 Section 4.1 of this chapter, the impacts of all generic aquatic resource issues would be SMALL. 7 The NRC staff analyzed Category 1 issues in the GEIS (NRC 2013a) and determined that the 8 impacts of continued nuclear power plant operation during a license renewal term would have 9 SMALL effects for these issues. The NRC staff has identified no new or significant information 10 for aquatic resource Category 1 issues that would call into question the GEISs conclusions for 11 subsequent license renewal of Turkey Point Units 3 and 4. Accordingly, and as concluded in 12 the GEIS, the impacts of the Category 1 aquatic resource issues identified in Table 4-1 would 13 be SMALL for the proposed Turkey Point subsequent license renewal. Table 4-2, Applicable 14 Category 2 (Site-Specific) Issues for the Turkey Point Site, in Section 4.1 of this SEIS identifies 15 two aquatic resources site-specific (Category 2) issues applicable to Turkey Point during the 16 subsequent license renewal term. These issues are analyzed below. 17 4.7.1.1 Impingement and Entrainment of Aquatic Organisms (Plants with Once-Through 18 Cooling Systems or Cooling Ponds) 19 For plants with once-through cooling systems or cooling ponds such as Turkey Point, the NRC 20 (NRC 2013a) has determined that impingement and entrainment of aquatic organisms is a 21 Category 2 issue that requires site-specific evaluation. In 2002, the NRC staff evaluated the 22 impacts of the Turkey Point initial license renewal on aquatic organisms as two issues: 23 impingement of fish and shellfish and entrainment of fish and shellfish in early life stages. 24 For both issues, the NRC staff determined that impacts would be SMALL. In 2013, the NRC 25 issued Revision 1 of the GEIS (NUREG-1437) (NRC 2013a), which combined these two issues 26 into a single site-specific issueImpingement and entrainment of aquatic organisms (plants 27 with once-through cooling systems or cooling ponds). This section evaluates this consolidated 28 issue as it applies to the proposed Turkey Point subsequent license renewal period. 29 Impingement is the entrapment of all life stages of fish and shellfish on the outer part of an 30 intake structure or against a screening device during periods of water withdrawal 31 (40 CFR 125.83, What Special Definitions Apply to This Subpart?). Impingement can kill 32 organisms immediately or contribute to later mortality resulting from exhaustion, suffocation, 33 injury, and other physical stresses. The potential for injury or death is generally related to the 34 amount of time an organism is impinged, its susceptibility to injury, and the physical 35 characteristics of the screen-washing system and fish return (if present) of the plant. 36 Entrainment is the incorporation of all life stages of fish and shellfish with intake water flow 37 entering and passing through a cooling water intake structure and into a cooling water system 38 (40 CFR 125.83). Organisms susceptible to entrainment are generally of smaller size than 39 those susceptible to impingement and include ichthyoplankton (fish eggs and larvae), larval 40 stages of shellfish and other macroinvertebrates, zooplankton, and phytoplankton. Entrained 41 organisms may experience physical trauma and stress, pressure changes, excess heat, and 42 exposure to chemicals, any of which may result in injury or death (Mayhew et al. 2000). 4-49

1 A particular species can be subject to both impingement and entrainment if several life stages 2 occur near a plants intake. For instance, adults may be impinged against the screens, while 3 larvae and eggs may be entrained. Depending on the size of the intake screen openings, 4 juveniles can be susceptible to both impingement and entrainment: larger juveniles may be 5 impinged, while smaller juveniles may be entrained. The magnitude of impacts on the aquatic 6 environment resulting from impingement and entrainment depends on 7 plant-specific characteristics of the cooling system (e.g., location of the plant intake, intake 8 velocities, withdrawal volumes, screen technologies, and presence or absence of a fish return 9 system) as well as characteristics of the aquatic resources (e.g., species present in the region, 10 population distributions, species status, management objectives, and life history characteristics). 11 Below, the NRC staff analyzes impingement and entrainment during the proposed Turkey Point 12 subsequent license renewal term in two parts. First, the staff considers impacts that would be 13 experienced by the aquatic biota in the CCS, and second, the staff considers biota in adjacent 14 natural aquatic environments, including Biscayne Bay and Card Sound. 15 Aquatic Organisms of the CCS 16 Aquatic organisms inhabiting the CCS may be impinged or entrained when water is drawn from 17 the CCS into the Turkey Point intake structure. Water from the CCS flows from the canal 18 system into eight intake channels and through 9.5-mm (0.37-inch) mesh intake screens at a rate 19 of 4.48 feet per second (fps) (1.4 meters per second (m/s)). The maximum flow per intake 20 channel is 225,375 gpm (14.2 m3/s). Debris, including fish and other aquatic organisms, that 21 become impinged on the screens are washed off and disposed of by FPL personnel. The 22 Turkey Point intake structure does not contain a fish return system (FPL 2018g). 23 FPL has not conducted any impingement or entrainment studies within the CCS. The Federal 24 Water Pollution Control Act (i.e., the Clean Water Act of 1972, as amended (CWA)) (33 U.S.C. 25 1251 et seq.) does not impose ecological study requirements because the State classifies the 26 CCS as an industrial wastewater facility and because the CCS does not directly withdraw from 27 or discharge into any natural surface waters. Due to the lack of impingement and entrainment 28 data, the NRC staff evaluates the effects of this potential effect on CCS aquatic organisms 29 qualitatively in this section. First, the NRC staff considers the baseline condition of the resource 30 (i.e., the species that would be present and susceptible to impingement and entrainment during 31 the proposed subsequent license renewal). The staff then considers whether the life history 32 characteristics of these species combined with the engineering parameters of the Turkey Point 33 intake structure would make impingement or entrainment likely. The staff then makes an overall 34 conclusion for impingement and entrainment on aquatic organisms of the CCS. 35 Baseline Condition of the Resource 36 Section 3.7.3, Aquatic Resources on the Turkey Point Site, of this SEIS describes the aquatic 37 resources on the Turkey Point site and summarizes the results of past ecological surveys of the 38 CCS. In this section, the NRC staff discusses the facts that a number of fish species reported 39 from the CCS in 2007 and 2009 ecological surveys were not collected in the most recent 2016 40 ecological survey, submerged aquatic vegetation is no longer present in the system, and 41 species diversity has generally declined over time. The surface water quality factors that have 42 contributed to this ecological shift are described in Section 3.5.1, Surface Water Resources. 43 No surface water connections between the CCS and any natural waterbodies exist that would 44 allow additional species to enter the CCS during the course of the proposed subsequent license 45 renewal term. Thus, the NRC staff assumes that the baseline condition of the resource is the 4-50

1 aquatic community as it occurs in the CCS today. The current community is of low diversity and 2 includes only those species that can withstand hot, hypersaline waters with low dissolved 3 oxygen and poor water clarity. In 2016, Ecological Associates, Inc. (EAI 2017) collected only 4 the following four species from the CCS: 5

• sheepshead minnow (Cyprinodon variegatus) 6
• sailfin molly (Poecilia latipinna) 7
• eastern mosquitofish (Gambusia holbrooki) 8
• mudflat fiddler crabs (Uca rapax) 9 Although other species may continue to occur in the CCS in small numbers that were not 10 captured during the 2016 study, the NRC staff considers the species listed above to be 11 representative of the current CCS aquatic community. For the purposes of this analysis, the 12 staff assumes that these species are also representative of the aquatic community that would 13 be present in the CCS and susceptible to impingement and entrainment during the proposed 14 subsequent license renewal term of 2032 through 2052 (Unit 3) and 2033 through 2053 (Unit 4).

15 Below, the staff considers the vulnerability of these species to impingement or entrainment to 16 determine the overall impact of impingement and entrainment on CCS aquatic organisms. 17 Impingement 18 To assess the risk of impingement on CCS organisms, the NRC staff compared documented 19 swim speeds of representative CCS species to the water velocity at the Turkey Point intake 20 structure. In scientific literature, fish swimming speeds are characterized as burst, prolonged, or 21 sustained. Burst speeds are the highest speeds a fish can attain over very short periods of time 22 (typically less than 20 seconds). Burst speeds are exhibited when an individual is capturing 23 prey, avoiding a predator, or negotiating high water velocities, such as those associated with 24 riffles and eddies in a fast-flowing river or the draw of a power plants intake. Sustained speeds 25 are low speeds fish can maintain indefinitely without fatigue. These speeds are observed during 26 routine activities, including foraging, holding, and schooling. Prolonged (or critical) speeds are 27 those of intermediate endurance that a fish could endure for approximately 20 to 30 minutes 28 before ending in fatigue. If a species reported swimming ability indicates that individuals can 29 typically swim faster than a power plants intake velocity, the species would exhibit a low 30 likelihood of being impinged. Certain species may not be capable of maintaining a sustained 31 speed that would allow escape from an intake velocity, but an individual could swim in a burst to 32 avoid impingement. Swim speeds are typically measured in centimeters per second (cm/s). 33 Thus, the NRC staff assumes that species with a documented burst speed less than 140 cm/s 34 (1.4 m/s; 4.48 fps), which is the velocity of the Turkey Point intake, would be susceptible to 35 impingement, and a species with a documented burst speed equal to or greater than this 36 velocity would generally not be susceptible to impingement. 37 Sheepshead minnow belong to the family Cyprinodontidae. In laboratory tests, Leavy and 38 Bonner (Leavy and Bonner 2009) determined the burst swimming speed of two species in this 39 family of fish, plains killifish (Fundulus zebrinus) and blackstripe topminnow (F. notatus), to be 40 30.7 to 43.4 cm/s (0.307 to 0.434 m/s; 1.01 to 1.42 fps). Species-specific data is not available 41 for sheepshead minnow. Therefore, for comparison, the NRC staff assumes that this range is 42 comparable to the burst swim speed of sheepshead minnow. Based on this assumption, 43 sheepshead minnow are susceptible to impingement at Turkey Point and any individuals within 44 the area influenced by the Turkey Point intake velocity are likely to become impinged. 4-51

1 Sailfin molly and eastern mosquitofish both belong to the family Poeciliidae. In laboratory tests, 2 Leavy and Bonner (Leavy and Bonner 2009) determined the burst swimming speed of two 3 Poeciliidae speciessailfin molly and largespring gambusia (Gambusia geiseri)to be 4 15.7 to 18.6 cm/s (0.157 to 0.186 m/s; 0.52 to 0.61 fps). In another test, Srean et al. 5 (Srean et al. 2016) determined the critical swim speed of adult eastern mosquitofish to be 6 14.11 cm/s (0.1411 m/s; 0.46 fps). Based on this information, both sailfin molly and eastern 7 mosquitofish are susceptible to impingement at Turkey Point. 8 Juvenile and adult mudflat fiddler crabs inhabit the intertidal zones of muddy areas of salt 9 marshes and mangroves. Therefore, they would not generally occur in the open water of the 10 CCS where they would be susceptible to impingement. Thus, mudflat fiddler crabs are likely not 11 impinged or only rarely impinged by the Turkey Point intake structure. 12 Based on the available biometric information presented above, the NRC staff assumes that all 13 fish in the CCS are susceptible to impingement. Because the Turkey Point intake structure 14 does not have a fish return system, and FPL has no plans to alter the design or function of the 15 Turkey Point cooling system under the proposed action, all impingement would result in 16 mortality. However, most fish in the CCS are not at risk of impingement due to the layout of the 17 system and the large size of the CCS relative to the small area influenced by the Turkey Point 18 intake structures withdrawal of water. Only those individuals in the CCS intake canal, 19 specifically, would be at risk of impingement and only those individuals within the smaller area 20 influenced by the intake velocity are likely to be impinged. Many fish in the CCS likely spend 21 their lives in the main canals and are never exposed to impingement risk. In contrast, for a 22 power plant whose intake draws from a river, migration or movement of fish past the plant would 23 likely necessitate passage through the zone of the power plant intakes influence. For the 24 reasons discussed above, the NRC staff concludes that while impingement at Turkey Point is 25 likely to affect CCS aquatic populations, only a small portion of aquatic organisms would be 26 susceptible to impingement at any given time. 27 Entrainment 28 A species susceptibility to entrainment is closely related to the life history characteristics of 29 early life stages. Species that lay adhesive eggs that sink to the bottom of the water column are 30 less likely to be entrained than species that lay demersal eggs that float within the water 31 column. Sheepshead minnow eggs are adhesive; these eggs stick to plants and bottom 32 substrate and are, therefore unlikely to be entrained. Sailfin molly and eastern mosquitofish 33 give birth to live young rather than laying a clutch of eggs. Newly born young of these species 34 are, therefore, at risk of entrainment if young occur in the CCS intake canal and within the area 35 influenced by the Turkey Point intake structure. Female mudflat fiddler crabs release eggs into 36 the water column where they hatch into microscopic free-swimming larvae that then go through 37 several molt stages. During this process, zoea would be susceptible to entrainment if they 38 occur in water drawn into the Turkey Point intake structure. As with impingement, the NRC staff 39 assumes that even for those species and life stages for which entrainment is possible, only a 40 small portion of susceptible individuals occur in the CCS intake canal and, thus, entrainment risk 41 is relatively low. 42 Impingement and Entrainment Conclusion for Cooling Canal System Aquatic Organisms 43 All fish inhabiting the CCS are likely susceptible to impingement, and early life stages of some 44 species are also susceptible to entrainment. The large size of the CCS relative to the small 45 area influenced by intake velocity of the Turkey Point intake structure mitigates the overall risk 4-52

1 of impingement and entrainment. In the absence of specific studies, the extent to which 2 impingement or entrainment may result in detectable or noticeable effects on the aquatic 3 populations of the CCS is unknown. However, impingement and entrainment are unlikely to 4 create effects great enough to destabilize important attributes of the aquatic environment over 5 the course of the proposed subsequent license renewal term because the CCS aquatic 6 community is composed of common species that exhibit no unique ecological value or niche 7 and have no commercial or recreational value. The NRC staff, therefore, finds that 8 impingement and entrainment during the proposed subsequent license renewal term would be 9 of SMALL to MODERATE significance on the aquatic organisms of the CCS. 10 Aquatic Organisms of Biscayne Bay 11 Aquatic organisms inhabiting Biscayne Bay are not subject to impingement or entrainment 12 because there are no surface water connections that allow flow between the waters of the 13 Biscayne Bay and the CCS. Thus, aquatic organisms in Biscayne Bay and connected 14 waterbodies (e.g., Card Sound, the Atlantic Ocean) never interact with the Turkey Point intake 15 structure. Accordingly, the NRC staff concludes that the issue of impingement and entrainment 16 during the proposed subsequent license renewal term does not apply to aquatic organisms in 17 Biscayne Bay. 18 4.7.1.2 Thermal Impacts on Aquatic Organisms (Plants with Once-Through Cooling Systems 19 or Cooling Ponds) 20 For plants with once-through cooling systems or cooling ponds such as Turkey Point, the NRC 21 staff (NRC 2013a) has determined that thermal impacts on aquatic organisms is a Category 2 22 issue that requires site-specific evaluation. In 2002, the NRC staff evaluated the impacts of the 23 Turkey Point initial license renewal on aquatic organisms as heat shock, and the NRC 24 determined that impacts would be SMALL. In 2013, the NRC issued Revision 1 of the GEIS 25 (NUREG-1437) (NRC 2013a), which renamed this issue as Thermal impacts on aquatic 26 organisms (plants with once-through cooling systems or cooling ponds). This section evaluates 27 this issue for the proposed Turkey Point subsequent license renewal period. 28 The primary form of thermal impacts that would be of concern at Turkey Point is heat shock, 29 which the NRC staff (NRC 2013a) defines as occurring when the water temperature meets or 30 exceeds the thermal tolerance of a species for some duration of exposure. In most situations, 31 fish are capable of moving out of an area that exceeds their thermal tolerance limits, although 32 some aquatic species lack such mobility. Heat shock is typically observable only for fish, 33 particularly those species that float when dead. 34 Aquatic Organisms of the CCS 35 Heated water discharged from Turkey Point moves from the discharge canal on the north end of 36 the CCS, through 32 feeder canals, and south into a single collector canal that distributes water 37 to 7 return canals. Water in the return canals flows north to the Turkey Point intakes. Excess 38 heat is naturally dissipated through evaporation and groundwater exchange as water flows 39 through the system. Thus, fish and other aquatic organisms experience the highest 40 temperatures at the north end of the CCS within the discharge canal with gradually decreasing 41 temperatures as water flows south through the system. 42 FPL has not conducted any thermal impact studies within the CCS. The Clean Water Act does 43 not impose ecological study requirements on the CCS because the State of Florida classifies 4-53

1 the CCS as an industrial wastewater facility and also because the CCS does not directly 2 withdraw from or discharge into any natural surface waters. In the absence of thermal studies, 3 the NRC staff evaluates the potential effects of thermal discharges on CCS aquatic organisms 4 by comparing CCS discharge temperature data with the thermal tolerances of the species 5 present in the CCS. 6 Baseline Condition of the Resource 7 As explained in the NRC staffs impingement and entrainment analysis in Section 4.7.1.1 of this 8 SEIS, the staff assumes that the baseline condition of the resource for the proposed action is 9 the aquatic community as it occurs in the CCS today. The current community is of low diversity 10 and includes only those species that can withstand hot, hypersaline waters with low dissolved 11 oxygen and poor water clarity. Only four speciessheepshead minnow, sailfin molly, eastern 12 mosquitofish, and mudflat fiddler crabwere collected during the last ecological survey of the 13 CCS in 2016 (EAI 2017). For the purposes of this analysis, the staff assumes that these 14 species are also representative of the aquatic community that would be present in the CCS and 15 susceptible to thermal stress during the proposed subsequent license renewal term. 16 Previous to the 2016 survey, a number of fish, mollusks, crabs, and submerged aquatic 17 vegetation were observed or recorded as occurring in the CCS (described in Section 3.7.3, 18 Aquatic Resources on the Turkey Point Site, of this SEIS). These species have either been 19 eliminated from the CCS or persist in such low numbers that they were not collected during the 20 2016 survey. Submerged aquatic vegetation was determined to be completely absent from the 21 system at the time of the 2016 survey, and EAI (EAI 2017) stated in its report that 22 temperature-related stress was one of the factors that contributed to the die-off of the CCSs 23 seagrass beds. The NRC staff acknowledges EAIs conclusion regarding seagrass and 24 recognizes that thermal discharges associated with Turkey Point have contributed not only to 25 the disappearance of seagrass within the CCS, but also to the decline of fish and other aquatic 26 biota and the observed shift towards more heat-tolerant species in recent years. The staff 27 addresses these impacts in the cumulative impact analysis in Section 4.16.4, Aquatic 28 Resources, because they are past impacts associated with the current renewed license term. 29 The analysis below focuses on future impacts that would be associated with the proposed 30 subsequent license renewal term of 2032 through 2052 (Unit 3) and 2033 through 2053 (Unit 4). 31 Cooling Canal System Discharge Temperature Data 32 For each calendar month, FPL reports the highest average daily temperature of the cooling 33 water discharge at Outfall 001 to the Florida Department of Environmental Protection as a 34 requirement of the Turkey Point industrial wastewater facility NPDES Permit No. FL0001562. 35 Table 4-3 below presents these daily maximum temperatures for the past 5 full calendar years 36 (2012-2017). As is typical for the region, the highest temperatures occur in July, and the lowest 37 temperatures occur in January. However, CCS discharge temperatures remain relatively high 38 year-round and are often above the thermal tolerances of many fish (often around 95 °F 39 (35 °C)). FPL (2018g) reports that water temperatures drop approximately 13.7 °F (7.6 °C) over 40 the course of flow from the discharge point to the south end of the CCS. Thus, the minimum 41 temperature likely ranged from roughly 69.9 to 97.9 °F (21.1 to 36.6 °C) with some thermal 42 stratification occurring such that deeper areas of the canal system would have experienced 43 slightly lower temperatures than those measured at the surface. 4-54

1 Table 4-3 Average Maximum Daily Temperature at CCS Outfall 001 Temperature (°F) (a) Month 2012 2013 2014 2015 2016 2017 January 97.3 90.6 89.9 89.1 95.7 91.0 February 94.7 68.8 106.5 100.3 94.1 98.6 March 94.7 83.6 101.1 105.0 103.2 95.4 April 91.2 93.6 106.7 109.0 90.1 94.8 May 97.1 97.6 103.2 102.7 104.6 103.4 June 90.0 109.2 107.9 112.2 109.7 104.6 July 100.2 111.6 108.2 107.2 111.5 108.3 August 89.8 106.6 106.6 110.4 110.4 110.0 September 97.6 108.4 100.2 105.2 110.4 101.9 October 97.5 101.5 99.0 94.0 94.8 101.9 November 95.0 94.2 89.0 102.6 96.3 96.8 December 93.1 94.8 103.2 94.7 100.4 97.5 (a) To convert temperatures in degrees Fahrenheit to Celsius, subtract 32 and multiply by 5/9. Source: FPL 2018g 2 Thermal Tolerances of Aquatic Species 3 Sheepshead minnow are part of the family Cyprinodontidae, which are known for their ability to 4 survive extreme seasonal and diurnal shifts in water temperature. Sheepshead minnow, 5 specifically, can be found in the harsh environments of subtropical south Texass shallow tide 6 pools at temperatures as high as 109.4 °F (43 °C) and when the combination of other abiotic 7 conditions become so extreme that no other species can persist (Strawn and Dunn 1967; 8 Harrington and Harrington 1961). In static and dynamic thermal tolerance tests of 9 800 sheepshead minnow collected from a shallow tidepool of the Brazos Santiago Pass in 10 Texas, Bennet and Beitinger (Bennett and Beitinger 1997) found that the species has the 11 largest physiological thermal tolerance range ever measured in a fish. In the tests, individuals 12 acclimated to 69.8 °F (21.0 °C) and 100.4 °F (38.0 °C) were able to tolerate temperatures up to 13 104.18 °F (40.1 °C) and 111.56 °F (44.2 °C), respectively. Bennet and Beitinger 14 (Bennett and Beitinger 1997) determined the species critical thermal maximathe temperature 15 at which activity becomes disorganized and an organism loses its ability to escape conditions 16 which will promptly lead to deathto be 113 °F (45.1 °C). 17 Both the sailfin molly and eastern mosquitofish are also rather heat-tolerant species. In critical 18 thermal maxima tests, these species have been found capable of withstanding temperatures up 19 to or slightly higher than 104 °F (40 °C) (Fischer and Schlupp 2009; Meffe et al. 1995). 20 Mudflat fiddler crabs have been documented as tolerating waters of temperatures up to 21 111.4 °F (44 °C) (Smithsonian 2009). The mobility of this species also allows individuals to 22 leave waters that are too hot and seek refuge elsewhere. 4-55

1 Thermal Impacts Discussion 2 The aquatic community of the CCS is composed of species that can survive in extreme 3 temperatures. CCS temperature data indicate that water in the system remains below the 4 thermal tolerances of the aquatic species present during the majority of the year. During the 5 summer months, waters at and near the cooling water discharge at CCS Outfall 001 may 6 approach or exceed the thermal tolerances of aquatic species. However, the CCS is a large 7 system, and the area over which water temperatures would be uninhabitable would be relatively 8 small. Thus, fish and other mobile aquatic organisms could seek refuge in cooler areas. 9 Additionally, the State has required FPL to implement a thermal efficiency plan (described in 10 detail in Section 3.5.1) as a condition of the 2016 Consent Order to control CCS salinity and 11 temperature (FDEP 2016e). FPL has begun implementing this plan, and FPLs continued 12 execution of the plan will ensure that CCS temperatures are moderated over the course of the 13 proposed subsequent license renewal term. The combination of these factors (i.e., the 14 heat-tolerant aquatic community present in the CCS, the small area of the CCS over which 15 water temperatures typically exceed species critical thermal maxima, and the State-mandated 16 requirements for FPL to control CCS temperatures and salinity) make the likelihood of mortality 17 of aquatic organisms from Turkey Points thermal effluent during the subsequent license 18 renewal term relatively low. Nevertheless, the high-temperature environment of the CCS is 19 likely to exert physiological stress on aquatic organisms that could have fitness consequences, 20 including reproductive effects, increased susceptibility to disease or infection, and reduced 21 ability to escape predators. While these effects may be noticeable, they are unlikely to 22 destabilize important attributes of the aquatic environment over the course of the proposed 23 subsequent license renewal term. 24 Thermal Impact Conclusion for CCS Aquatic Organisms 25 The aquatic community that currently inhabits the CCS can withstand high temperatures and 26 continued thermal discharges from Turkey Point over the course of the proposed subsequent 27 license renewal period are unlikely to further alter the composition of the community. Thermal 28 impacts may result in some degree of physiological stress on CCS aquatic organisms. In the 29 absence of specific studies, the extent to which such stresses may result in detectable or 30 noticeable effects is unknown. However, thermal impacts are unlikely to create effects great 31 enough to destabilize important attributes of the aquatic environment over the course of the 32 proposed subsequent license renewal term because the CCS aquatic community is composed 33 of species that exhibit no unique ecological value or niche and have no commercial or 34 recreational value. The NRC staff, therefore, finds that thermal impacts during the proposed 35 subsequent license renewal term would be of SMALL to MODERATE significance on the 36 aquatic organisms of the CCS. 37 Aquatic Organisms of Biscayne Bay 38 Aquatic organisms inhabiting Biscayne Bay are not subject to thermal impacts associated with 39 Turkey Point because there are no surface water connections that allow flow between these 40 waters and the CCS. Thus, aquatic organisms in this water body and connected waterbodies 41 (e.g., Card Sound, the Atlantic Ocean, etc.) do not interact with Turkey Points thermal 42 discharge. Accordingly, the NRC staff concludes that the issue of thermal impacts during the 43 proposed subsequent license renewal term does not apply to aquatic organisms in Biscayne 44 Bay. 4-56

1 4.7.2 No-Action Alternative 2 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 3 Turkey Point Units 3 and 4 would shut down on or before the expiration of the current renewed 4 licenses. The CCS would continue to operate to support retired fossil fuel Units 1 and 2 in 5 synchronous condenser mode. If Turkey Point Units 3 and 4 were to cease operating, impacts 6 to CCS aquatic resources would decrease or stop following reactor shutdown. The amount of 7 CCS water withdrawn for cooling purposes would decrease significantly following shutdown, 8 although some withdrawal would continue during the shutdown period as the remaining fuel 9 cools. The reduced demand for cooling water would substantially decrease the effects of 10 impingement, entrainment, thermal effluents, and other impacts to aquatic biota in the CCS. 11 Withdrawals would eventually cease, which would eliminate these impacts. 12 The CCS would continue to operate under the no-action alternative because it supports retired 13 fossil fuel Units 1 and 2. FPL plans to continue to withdraw water from the CCS to support 14 these units operation in synchronous condenser mode over the course of the proposed 15 subsequent license renewal period, as described in Section 3.1.3, Cooling and Auxiliary Water 16 Systems. Additionally, Unit 5, which remains in operation, discharges blowdown to the CCS. 17 CCS conditions could change under the no-action alternative because less heat would be 18 discharged to the system, which would potentially make conditions less saline and more 19 favorable to aquatic life. However, flow would likely decrease following shutdown because 20 Turkey Point Units 3 and 4 would not require as much water. Less flow could lead to stagnant 21 conditions and lower habitat quality. However, the CCS would continue to provide habitat for 22 the existing aquatic community. Additionally, FPL would continue CCS restoration activities, as 23 described in Section 3.7, Aquatic Resources. The State of Florida requires these activities 24 under FPLs Nutrient Management Plan which is independent of subsequent license renewal. 25 Restoration activities would likely eventually return portions of the CCS to a seagrass-based 26 ecological system. 27 The no-action alternative would not affect aquatic resources in Biscayne Bay, Card Sound, or 28 the Atlantic Ocean because there are no surface water connections that allow flow between 29 these waters and the waters of the CCS; therefore, aquatic organisms in these waterbodies do 30 not interact with the Turkey Point intake structure and are not subject to impingement, 31 entrainment, thermal discharges, or any other effects. 32 The NRC staff concludes that the impacts of the no-action alternative on aquatic resources 33 would be SMALL. 34 4.7.3 Replacement Power Alternatives: Common Impacts 35 Each replacement power alternative would entail construction and operation of a new energy 36 generating facility on the existing 9,500-ac (3,800-ha) Turkey Point site but outside the footprint 37 of Turkey Point Units 3 and 4 and outside the footprint of the proposed 38 Turkey Point Units 6 and 7. Each replacement plant would use mechanical draft cooling towers 39 that would draw water from reclaimed wastewater at varying rates depending on each 40 alternatives cooling requirements. Both alternatives involving a new natural gas plant would 41 require a pipeline to connect the new facility to an existing natural gas supply line located 42 approximately 100 mi (160 km) north of the Turkey Point site. 43 For all alternatives discussed in this section, the impacts of construction on aquatic resources 44 would be qualitatively similar. During construction, the use of the existing Turkey Point site 4-57

1 would allow FPL to use some existing buildings and infrastructure. However, an additional 2 75 to 540 ac (30 to 220 ha) of undeveloped land on or near the site would be required 3 depending on the specific alternative. The solar component of the combination alternative may 4 require up to 1,400 ac (570 ha) of additional offsite land, and rights-of-way and gas extraction 5 may require additional land, as well. Given the prevalence of wetlands, mangrove forests, 6 mudflats, and other aquatic features on and near the Turkey Point site, it is unlikely that FPL 7 would be able to completely avoid destroying or degrading these habitats during construction of 8 buildings, cooling towers, and other plant components associated with any of the replacement 9 power alternatives. Thus, construction would likely result in permanent loss of some onsite 10 aquatic habitats. The resulting habitat fragmentation could affect ecosystem function and 11 connectivity of aquatic habitats. Habitat degradation associated with runoff, erosion, and 12 sedimentation during construction could also occur. Additionally, direct mortality of aquatic 13 organisms could result from dredging, wetland and mangrove filling, and other necessary 14 in-water work. Barge traffic associated with delivery of construction supplies and plant 15 components to the site would release pollutants into aquatic habitats and could result in 16 collision-related injury or mortality of larger aquatic organisms, especially turtles and marine 17 mammals. 18 Appropriate permits would mitigate some water quality and aquatic resource impacts by 19 requiring FPL to implement best management practices or other mitigation measures during 20 construction and/or operation. The U.S. Army Corps of Engineers or the Florida Department of 21 Environmental Protection would oversee applicable Clean Water Act permitting, including 22 Section 404 permits for dredging and fill activities, Section 401 certification, and Section 402(p) 23 National Pollutant Discharge Elimination System (NPDES) general stormwater permitting. 24 While adherence to these permits would minimize effects on aquatic resources, the prevalence 25 of sensitive aquatic habitats on the Turkey Point site would make some level of impact 26 unavoidable. Construction of any of the replacement power alternatives could affect wetland or 27 mangrove connectivity and could degrade or reduce the value of these habitats as nurseries for 28 fish and shellfish. Such effects would likely be noticeable and could destabilize these attributes 29 of the aquatic environment depending on the particular alternative selected and the siting of the 30 plant. 31 During operation of any of the replacement power alternatives, the potential impacts on aquatic 32 resources would be qualitatively similar to those that would be experienced as a result of the 33 proposed action of subsequent license renewal. Once built, operation of a replacement power 34 plant would have minimal to no discernable impacts on aquatic resources given that a new 35 power plant would use reclaimed wastewater for cooling. Thus, impingement, entrainment, 36 thermal effects, and water use conflicts would not be an issue. 37 4.7.4 New Nuclear Alternative 38 The NRC staff did not identify any impacts to aquatic resources for the new nuclear alternative 39 beyond those discussed in the impacts common to all replacement power alternatives. 40 However, the common impact would be more intense for the new nuclear alternative compared 41 to the other alternatives because of the larger land area requirement, which would result in more 42 habitat loss and the potential for higher rates of erosion and sedimentation into aquatic habitats. 43 Impacts of this alternative would be MODERATE to LARGE in the local environs of the plant 44 due to the sensitive nature of the wetlands, mangrove forests, mudflats, and other nearby 45 aquatic habitats and the likelihood that construction would convert (destroy) or degrade these 46 habitats. The permanent loss or alteration of these aquatic habitats would likely result in habitat 47 fragmentation that could affect ecosystem function and connectivity of aquatic habitats. The 4-58

1 exact level of impact would depend on whether the chosen site results in the permanent loss, 2 impairment, fragmentation, or reduced ecosystem function of affected aquatic habitats. 3 4.7.5 Natural Gas Combined-Cycle Alternative 4 The common impacts described above would be less intense for the natural gas alternative 5 compared to the new nuclear alternative. Because the natural gas alternative would disturb less 6 land, it would, therefore, have less likelihood of impairing aquatic habitat connectivity or 7 function. In addition to the common impacts, the natural gas alternative would require 8 construction of a gas pipeline, which could result in erosion, sedimentation, or disturbance of 9 aquatic habitats during the construction phase. The exact degree of impacts would depend on 10 the amount and quality of aquatic habitat along the chosen pipeline route and the 11 implementation of best management practices during construction. During operation, the 12 natural gas alternative would emit pollutants that could degrade aquatic habitats. The NRC staff 13 concludes that impacts of a natural gas alternative on aquatic resources would be MODERATE 14 to LARGE in the local environs of the plant, due to the permanent loss of aquatic habitats during 15 plant siting and the potential for additional disturbance or loss of aquatic habitats during pipeline 16 construction. The exact level of impact would depend on whether the chosen plant site and 17 pipeline route results in the permanent loss, impairment, fragmentation, or reduced ecosystem 18 function of affected aquatic habitats. 19 4.7.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 20 Generation) 21 The NRC staff did not identify any impacts to aquatic resources for the natural gas portion of the 22 combination alternative beyond those already discussed above for the natural gas-only 23 alternative. For the solar portion of the combination alternative, the exact level of disturbance or 24 degradation that aquatic habitats would experience would depend on the specific siting of solar 25 panels and infrastructure. Given the large area of land that the solar component would require 26 (approximately 1,400 ac (570 ha) for three offsite solar units, in total) and the prevalence of 27 wetlands, mangrove forests, and other important aquatic habitats within the region where the 28 solar units would be sited, construction would likely result in permanent loss or impairment of 29 aquatic habitats. The NRC staff concludes that impacts of a combination alternative on aquatic 30 resources would be MODERATE to LARGE in the local environs of the plant, due to the 31 permanent loss of aquatic habitats during natural gas plant and solar panel siting. The exact 32 level of impact would depend on whether the chosen natural gas plant site and solar panel sites 33 result in the permanent loss, impairment, fragmentation, or reduced ecosystem function of 34 affected aquatic habitats. 35 4.7.7 Cooling Water System Alternative 36 The NRC staff did not identify any impacts to aquatic resources for the cooling water system 37 alternative beyond those discussed in the impacts common to all replacement power 38 alternatives. Although Turkey Point would no longer use the CCS for cooling under this 39 alternative, the CCS itself would continue to operate because it supports Units 1 and 2. FPL 40 plans to continue to withdraw water from the CCS to support the operation of Units 1 and 2 in 41 synchronous condenser mode throughout the proposed period of subsequent license renewal, 42 as described in Section 3.1.3, Cooling and Auxiliary Water Systems. FPL would continue CCS 43 restoration activities, as described in Section 3.7, Aquatic Resources, under this alternative. 44 The State of Florida requires these activities under FPLs Nutrient Management Plan which is 45 independent of subsequent license renewal. Restoration activities would likely return portions of 4-59

1 the CCS to a seagrass-based ecological system. Construction of cooling towers on the Turkey 2 Point site would result in the permanent loss or impairment of sensitive aquatic habitats and 3 could affect ecosystem function and connectivity. Therefore, the NRC staff concludes that the 4 impacts of implementing the cooling water system alternative on aquatic resources would be 5 MODERATE in the local environs of the plant. 6 4.8 Special Status Species and Habitats 7 This section describes the potential special status species and habitats impacts of the proposed 8 action (subsequent license renewal) and alternatives to the proposed action. 9 4.8.1 Proposed Action 10 Table 4-2 identifies the one Turkey Point site-specific (Category 2) issue related to special 11 status species and habitats applicable to the area during the subsequent license renewal term. 12 This issue is analyzed below. 13 4.8.1.1 Species and Habitats Protected Under the Endangered Species Act 14 Species and Habitats under U.S. Fish and Wildlife Service Jurisdiction 15 Section 3.8, Special Status Species and Habitats, in this SEIS describes 42 federally listed 16 species solely under U.S. Fish and Wildlife Services (FWS) jurisdiction that occur in the action 17 area. In that section, the NRC staff concludes that 25 of these species would not occur in the 18 action area because those species are extirpated from Miami-Dade County, are not known to 19 occur within Miami-Dade County, or no suitable habitat occurs within the action area. An 20 additional four species are under the shared jurisdiction of the FWS and the National Marine 21 Fisheries Service. The NRC staff has determined that continued operation of 22 Turkey Point Units 3 and 4 would have no effect on any portions of these species life cycles 23 that are under FWSs jurisdiction (NRC 2018g). In addition, two species are listed because of 24 similarity of appearance to other listed species and, therefore, are not subject to the 25 Endangered Species Act, Section 7 consultation requirement. 26 The NRC staff analyzes the potential impacts of the proposed Turkey Point subsequent license 27 renewal on the remaining 15 species and on the designated critical habitat of two of these 28 species within its biological assessment (NRC 2018n). The NRC staff incorporates by reference 29 the biological assessment (NRC 2018n) into this SEIS. The NRC staffs Endangered Species 30 Act effect determination for each species is summarized below in Table 4-4. 31 Table 4-4 Effect Determinations for Federally Listed Species Under U.S. Fish and 32 Wildlife Service Jurisdiction Species Common Name Status(a) Impact(b) Mammals Eumops floridanus Florida bonneted bat FE may affect, but is not likely to adversely affect Puma concolor coryi Florida panther FE may affect, but is not likely to adversely affect Puma concolor (all sub puma SAT - species except coryi) 4-60

Species Common Name Status(a) Impact(b) Trichechus manatus West Indian FT may affect, but is not manatee likely to adversely affect; no adverse modification to designated critical habitat Birds Ammodramus maritimus Cape Sable seaside FE no effect mirabilis sparrow Ammodramus Florida Grasshopper FE no effect savannarum sparrow Aphelocoma Florida scrub-jay FT no effect coerulescens Caladris rufa red knot FT may affect, but is not likely to adversely affect Campephilus principalis ivory-billed FE no effect woodpecker Charadrius melodus piping plover FT may affect, but is not likely to adversely affect Mycteria americana wood stork FT may affect, but is not likely to adversely affect Picoides borealis red-cockaded FE no effect woodpecker Rostrhamus sociabilis Everglades snail kite FE may affect, but is not likely to adversely affect Setophaga kirtlandi Kirtland's warbler FE may affect, but is not likely to adversely affect Vermivora bachmani Bachman's warbler FE no effect Reptiles Alligator mississippiensis American alligator SAT - Crocodylus acutus American crocodile FT likely to adversely affect; adverse modification to designated critical habitat Drymarchon corais eastern indigo snake FT likely to adversely affect couperi Invertebrates Anaea troglodyta Florida leafwing FE no effect floridalis butterfly Cyclargus (=Hemiargus) Miami blue butterfly FE no effect thomasi bethunebakeri Heraclides aristodemus Schaus swallowtail FE no effect ponceanus butterfly Orthalicus reses Stock Island Tree FT no effect Snail Strymon acis bartrami Bartram's hairstreak FE no effect butterfly Flowering Plants Amorpha crenulata crenulate lead-plant FE no effect 4-61

Species Common Name Status(a) Impact(b) Argythamnia blodgettii Blodgett's silverbush FT may affect, but is not likely to adversely affect Brickellia mosieri Florida brickell-bush FE no effect Chamaesyce deltoidea deltoid spurge FE no effect ssp. deltoidea Chamaesyce deltoidea pineland sandmat FT no effect pinetorum Chamaesyce garberi Garber's spurge FT no effect Chromolaena frustrata Cape Sable FE may affect, but is not thoroughwort likely to adversely affect Consolea corallicola Florida semaphore FE may affect, but is not cactus likely to adversely affect Cucurbita Okeechobee Gourd FE no effect okeechobeensis ssp. okeechobeensis Dalea carthagenensis Florida prairie-clover FE no effect floridana Digitaria pauciflora Florida pineland FT no effect crabgrass Galactia smallii Small's milkpea FE no effect Jacquemontia reclinata beach jacquemontia FE no effect Linum arenicola sand flax FE may affect, but is not likely to adversely affect Linum carteri carteri Carter's small- FE no effect flowered flax Polygala smallii tiny polygala FE no effect Sideroxylon reclinatum Everglades bully FT no effect ssp. austrofloridense Warea carteri Carter's mustard FE no effect Ferns Trichomanes punctatum Florida bristle fern FE may affect, but is not ssp. floridanum likely to adversely affect (a) SAT = Federally listed due to similarity of appearance to another listed species, FE = Federally listed as endangered, FT = Federally listed as threatened at 50 CFR Part 17, Endangered and Threatened Wildlife and Plants, under the provisions of the Endangered Species Act 1 Species and Habitats under National Marine Fisheries Service Jurisdiction 2 Section 3.8, Special Status Species and Habitats, describes five federally listed species under 3 the National Marine Fisheries Services (NMFS) jurisdiction that occur in the action area: 4 loggerhead sea turtle (Caretta caretta), green sea turtle (Chelonia mydas), leatherback sea 5 turtle (Dermochelys coriacea), hawksbill sea turtle (Eretmochelys imbricata), and smalltooth 6 sawfish (Pristis pectinata). In that section, the NRC staff concludes that all of these species 7 occur in the action area within Biscayne Bay but that none occur on the Turkey Point site itself, 8 including within the CCS. The NRC staff analyzes the potential impacts of the proposed Turkey 4-62

1 Point subsequent license renewal on these five species below. Table 4-5, below, summarizes 2 the NRC staffs Endangered Species Act effect determination for each species. 3 Table 4-5 Effect Determinations for Federally Listed Species Under National Marine 4 Fisheries Service Jurisdiction Federal Species Common Name Status(a) Effect Determination Sea Turtles Caretta caretta loggerhead FT may affect, but is not likely to adversely affect Chelonia mydas green FT(b) may affect, but is not likely to adversely affect Dermochelys coriacea leatherback FE may affect, but is not likely to adversely affect Eretmochelys imbricata hawksbill FE may affect, but is not likely to adversely affect Fish Pristis pectinata smalltooth sawfish FE(b) may affect, but is not likely to adversely affect (a) FE = Federally listed as endangered and FT = Federally listed as threatened at 50 CFR Part 17, Endangered and Threatened Wildlife and Plants, under the provisions of the Endangered Species Act. (b) The identified Federal status applies to the following distinct population segment(s) (DPS): Northwest Atlantic and South Atlantic DPSs of the green turtle and United States DPS of the smalltooth sawfish. 5 Impingement, Entrainment, and Thermal Effects 6 In the GEIS (NUREG-1437) (NRC 2013a), the NRC staff identified a number of issues (or 7 impacts) that the aquatic ecological environment could experience as a result of license renewal 8 of a nuclear plant. These impacts, as they apply to the proposed Turkey Point subsequent 9 license renewal, are identified in Table 4-1 and Table 4-2. As described in Section 4.7, Aquatic 10 Resources, because the CCS does not directly withdraw from or discharge to any other surface 11 waters, the effects of impingement, entrainment, and thermal discharges are not applicable for 12 aquatic biota in Biscayne Bay or any other natural waterbodies. Thus, federally listed sea 13 turtles and smalltooth sawfish occurring in the action area would not be subject to these 14 impacts. 15 Barge Traffic 16 Barge traffic associated with subsequent license renewal has the potential to impact sea turtles 17 and smalltooth sawfish inhabiting Biscayne Bay. Continued operation of Turkey Point during 18 the subsequent license renewal term would necessitate infrequent deliveries of large parts and 19 equipment to the Turkey Point site. FPL (FPL 2018g) estimates that up to five barges in a 20 single year at intervals of 4 to 5 years would travel to and from Turkey Point during the 21 proposed subsequent license renewal term. This level of vessel traffic would include combined 22 deliveries associated with Turkey Point Units 3 and 4; Turkey Point Units 1, 2, and 5; and the 23 onsite independent spent fuel storage installation (FPL 2018g). 4-63

1 Sea turtles and smalltooth sawfish in Biscayne Bay could be injured or killed during interactions 2 with barge vessels as the vessels travel through the Bay. However, the infrequency of vessel 3 traffic and the ability of sea turtles and smalltooth sawfish to move away from vessels to avoid 4 impact make such effects extremely unlikely to occur. The NMFS assessed the impacts of 5 barge traffic, among other effects, as part of its Endangered Species Act, Section 7 consultation 6 with the NRC for the proposed construction of Turkey Point Units 6 and 7 in 2017. Construction 7 of the two new units would involve regular barge deliveries as well as pile driving and basin 8 dredging, all of which the NMFS (NMFS 2017a) found to be discountable. The NRC staff finds 9 the same conclusion to be reasonable for the proposed Turkey Point Units 3 and 4 subsequent 10 license renewal because this action would require much less frequent barge deliveries and 11 would not involve any dredging or other in-water work. Additionally, the NRC staff is not aware 12 of any sea turtle or smalltooth sawfish injuries or mortalities associated with Turkey Point barge 13 traffic since the units began operating in 1972 (Unit 3) and 1974 (Unit 4). Compared to the 14 original license and initial renewed license terms, barge traffic would continue at similar or less 15 frequent rates during the proposed subsequent license renewal term. Accordingly, the NRC 16 staff finds this potential impact to be discountable. 17 Biscayne Bay Water Quality 18 During the NEPA scoping period, the NRC staff received comments recommending that the 19 staff consider the potential impacts of interactions between the CCS and nearby surface 20 waterbodies on federally listed species. The commenters suggestions stemmed primarily from 21 the concern that contaminants in the CCS could affect water quality in the Bay, which would in 22 turn affect federally listed species. The NRC staff evaluates this potential impact below. 23 In the GEIS (NUREG-1437), the NRC staff generically addressed for all nuclear power plants 24 the potential for both radioactive and non-radiological contaminants associated with license 25 renewal to affect aquatic biota (NRC 2013a). With regard to the potential for sea turtles and 26 smalltooth sawfish to be exposed to radionuclides, the NRC staff (NRC 2013a) determined that 27 exposure to radionuclides would be of SMALL significance for aquatic organisms during the 28 license renewal term for all nuclear power plants because exposure would be well below 29 U.S. Environmental Protection Agency guidelines developed to protect aquatic biota. The NRC 30 staff also concluded in the GEIS that effects of non-radiological contaminants on aquatic 31 organisms would be SMALL because best management practices and discharge limitations 32 contained in applicable State-issued water quality permits would minimize the potential for 33 adverse impacts. The NRC defines SMALL to mean that environmental effects are not 34 detectable or are so minor that they will neither destabilize nor noticeably alter any important 35 attribute of the resource (10 CFR Part 51, Appendix B to Subpart A, Table B-1). Such an effect 36 level would equate to insignificant in Endangered Species Act terminology (i.e., the effects 37 would never reach the scale where a take would occur and, based on best judgement, a person 38 would not be able to meaningfully measure, detect, or evaluate such effects). 39 At Turkey Point specifically, the potential pathway for exposure of aquatic organisms in 40 Biscayne Bay to water or contaminants from the CCS is indirect and complex. As described in 41 Section 3.5.1, Surface Water Hydrology, of this SEIS, the CCS is situated above the Biscayne 42 aquifer. The porous nature of the limestone bedrock that forms the Biscayne aquifer results in 43 some groundwater exchange between the CCS and the aquifer. This exchange of groundwater 44 between the CCS and the Biscayne aquifer creates a pathway through which the CCS may 45 influence Biscayne Bay. Groundwater under the Turkey Point site flows east (towards Biscayne 46 Bay) or west (inland and away from the Bay) depending on the head levels in the aquifer 47 relative to the water levels in Biscayne Bay. Within the larger regional context, South Floridas 4-64

1 water is highly influenced by a complex system of crisscrossing canals that drain surface waters 2 from the land for agricultural and urban use, provide flood control, and discharge freshwater into 3 Biscayne Bay and Card Sound. The State manages the canal system as a coastal control 4 structure to maintain relatively high water levels along the coast and prevent saltwater intrusion 5 within near-surface groundwater aquifers. The State of Florida and Miami-Dade County have 6 required FPL to take actions to abate hypersaline water discharges from the CCS and to 7 actively remediate the hypersaline groundwater west and north of FPLs property. Many of 8 FPLs current actions are specified in a June 2016 consent order issued by the Florida 9 Department of Environmental Protection or in an October 2015 consent agreement issued by 10 the Miami-Dade County Department of Environmental Resources Management (DERM) (see 11 Section 3.5.2.2, Groundwater Quality for more detailed information). Both the consent order 12 and agreement contain requirements that aim to ensure that the CCS does not adversely affect 13 the regions surface waters. Thus, the water quality experienced by sea turtles and smalltooth 14 sawfish inhabiting Biscayne Bay depends on many factors, including Biscayne Bay water 15 conditions, groundwater head levels, freshwater inflow from precipitation, the States 16 management of South Floridas regional canal system, and FPLs implementation of State- and 17 County-imposed requirements. 18 As part of the requirements of the States consent order, FPL maintains an extensive water 19 quality monitoring program. FPL monitors the CCS, Biscayne Bay, Card Sound, and other 20 nearby waterbodies for ammonia, nitrogen, phosphorus, and chloride, among other nutrients 21 and parameters. Additionally, ecological monitoring is conducted semiannually in Biscayne Bay 22 and mangrove areas and quarterly in marsh areas. In FPLs 2017 report, which analyzes data 23 collected during the reporting period of June 1, 2016, through May 31, 2017, FPL found no 24 evidence of CCS water in the surrounding marsh and mangrove areas from a groundwater 25 pathway, and FPL identified no changes in Biscayne Bay water quality trends during the 26 monitoring period when compared to past monitoring period results (E&E 2017). To date, FPL 27 has identified no evidence of an ecological impact on the areas surrounding the CCS and no 28 discernible influence from the CCS on Biscayne Bay (E&E 2017). FPLs monitoring plan and 29 associated results are described in more detail in Section 3.5.1, Surface Water Hydrology of 30 this SEIS. 31 More recently, in July 2018, the Miami-Dade County Division of Environmental Resources 32 Management (DERM) found that several sampling locations at the Barge Basin, Turtle Point 33 Canal, Card Sound Canal, S-20 Get Away Canal, and the Sea-Dade Canal exceeded the 34 applicable Miami Dade County surface water standard for total ammonia concentrations 35 (MDC 2018a). In a July 10, 2018, letter to FPL, the DERM acknowledged that the elevated 36 concentrations may be attributable to a combination of several sources, including factors not 37 directly related to the operation of the CCS. Nevertheless, because the DERM believed that the 38 CCS may be one source contributing to the elevated ammonia levels, it required FPL to take 39 action to submit and implement a mitigation plan within 90 days of the date of the letter. The 40 mitigation plan must address potential CCS nutrient impacts to groundwater and surface water 41 resources beyond the boundaries of the CCS. 42 Elevated ammonia levels are of concern in aquatic environments because when ammonia is 43 present at high enough levels in the environment, aquatic organisms have difficulty completely 44 excreting excess ammonia from their bodies. This can lead to toxic build-up, health and fitness 45 effects, and potentially death. Several water quality parameters, including pH, temperature, and 46 salinity; the rate or duration of exposure; and a species specific physiobiology affect the extent 47 to which an organism experiences toxicity from a given level of ammonia. 4-65

1 With regard to sea turtles, data on the effects of ammonia are not currently available. In the 2 absence of species-specific information, the NRC assumes that the relevant State water quality 3 criteria are reasonably protective of sea turtles because under Section 303(c) of the Clean 4 Water Act, the EPA or the States are required to adopt water quality standards to restore and 5 maintain the chemical, physical, and biological integrity of the Nations waters. For delegated 6 States, the EPA must periodically certify that a States water quality criteria, and any revisions 7 thereto, protect the designated uses of the waterbody and that the standards are consistent 8 with, or more protective than, the EPAs national recommended aquatic life criteria. Therefore, 9 if waters inhabited by sea turtles meet State water quality criteria for ammonia, the NRC staff 10 assumes that there would be no lethal effects or impairment to growth, survival, or reproduction 11 to sea turtle individuals. As described above, the Miami-Dade County DERM has identified 12 several sampling locations where the total ammonia concentrations have exceeded the water 13 quality standard. However, the sampled locations are in stagnant, or dead-end canals where 14 sea turtles are unlikely to be present rather than in Biscayne Bay itself were sea turtles are more 15 likely to be present. Even if sea turtles were to be present in the canals, exposure time would 16 be limited because sea turtles are expected to only occur transiently and for short durations, if at 17 all. Additionally, as described above, DERM is taking action to restore water quality in the canal 18 areas of elevated ammonia such that elevated ammonia levels are not expected to be a 19 long-term issue. Further, no contaminants associated with the CCS, including ammonia, have 20 been found in Biscayne Bay itself where sea turtles are more likely to be present. In summary, 21 the very low likelihood of sea turtles to be exposed to elevated ammonia levels and the short 22 duration of potential exposure is unlikely to result in measurable effects on sea turtles. 23 Toxicity data for smalltooth sawfish exposure to ammonia or for taxonomically related species 24 that would serve as a reasonable surrogate are also unavailable. However, the NRC staff 25 assumes that, as with sea turtles, the State water quality criteria are reasonably protective of 26 smalltooth sawfish. Additionally, ureotelic species (species that excrete most of their waste 27 nitrogen in the form of urea in the urine), such as the smalltooth sawfish, regulate the ion 28 concentrations in their body fluids to maintain osmotic balance with their external environment, 29 which reduces the influx of ammonia from the external environment (NMFS 2016a). Ureotelic 30 species also convert ammonia to urea and native tri-methyl amine oxide, which counteracts its 31 toxicity (NMFS 2016a). As such, smalltooth sawfish are expected to be less vulnerable to 32 ambient ammonia than many other aquatic species. In a 2016 biological opinion on the EPAs 33 approval of Florida water quality standards under Section 303(c) of the Clean Water Act, the 34 National Marine Fisheries Service (NMFS 2016a) concluded that ammonia concentrations were 35 not likely to adversely affect the survival or fitness of smalltooth sawfish individuals because 36 responses to anticipated ammonia concentrations from the implementation of the revised 37 standards would be insignificant based on what is known about nitrogen metabolism and ion 38 regulation for ureotelic elasmobranch species like the smalltooth sawfish. Based on this 39 information, the NRC staff finds that even if smalltooth sawfish are present in the canal areas 40 with elevated ammonia levels, individuals are unlikely to be measurably affected. 41 In addition to the reasons set forth above, potential water quality effects on sea turtles and 42 smalltooth sawfish would be limited because the NRC staff assumes that FPL will adhere to, 43 and that the State and County will enforce, the various mitigation requirements such that 44 ammonia and other nutrients and contaminants associated with the CCS will not discernably 45 affect the aquatic ecology of Biscayne Bay over the course of the proposed subsequent license 46 renewal term. Accordingly, water quality associated with the continued operation of Turkey 47 Point would not result in effects on sea turtles or smalltooth sawfish that would be able to be 48 meaningfully measured, detected, or evaluated. The NRC staff concludes that water quality 4-66

1 effects from the continued operation of Turkey Point would result in insignificant impacts on 2 these species. 3 Conclusion 4 In conclusion, potential impacts on federally listed species under the NMFSs jurisdiction 5 associated with the proposed action could result from (1) interactions of sea turtles and 6 smalltooth sawfish with barge vessels and (2) the potential for groundwater exchange with the 7 CCS to result in water quality impacts in Biscayne Bay, which could in turn affect sea turtles or 8 smalltooth sawfish. For the reasons set forth above, the NRC staff finds these potential impacts 9 to be discountable or insignificant. Accordingly, the NRC staff concludes that the proposed 10 subsequent license renewal of Turkey Point may affect, but is not likely to adversely affect, 11 loggerhead, green, leatherback, and hawksbill sea turtles and smalltooth sawfish. 12 Cumulative Effects 13 The Endangered Species Act regulations at 50 CFR 402.12(f)(4) direct Federal agencies to 14 consider cumulative effects as part of the proposed action effects analysis. Under the 15 Endangered Species Act, cumulative effects are defined as those effects of future State or 16 private activities, not involving Federal activities, that are reasonably certain to occur within the 17 action area of the Federal action subject to consultation (50 CFR 402.02, Definitions). Unlike 18 the National Environmental Policy Act (NEPA) definition of cumulative impacts (see 19 Section 4.16, Cumulative Impacts), cumulative effects under the Endangered Species Act do 20 not include past actions or other Federal actions requiring separate Endangered Species Act, 21 Section 7 consultation. When formulating biological opinions under formal Endangered Species 22 Act Section 7 consultation, the FWS and the NMFS (1998) consider cumulative effects when 23 determining the likelihood of jeopardy or adverse modification. Therefore, cumulative effects 24 need only be considered under the Endangered Species Act if listed species will be adversely 25 affected by the proposed action and formal Section 7 consultation is necessary (FWS 2014b). 26 Because the NRC staff concluded earlier in this section that the proposed subsequent license 27 renewal is not likely to adversely affect sea turtles or smalltooth sawfish, consideration of 28 cumulative effects for these species is not necessary. For those species under the U.S. Fish 29 and Wildlife Services jurisdiction, cumulative impacts are discussed, as appropriate, in the 30 staffs biological assessment (NRC 2018n). 31 4.8.1.2 Species and Habitats Protected Under the Magnuson-Stevens Act 32 Section 3.8, Special Status Species and Habitat, describes seven federally managed species 33 for which the South Atlantic Fishery Management Council and NMFS have designated Essential 34 Fish Habitat (EFH) in Biscayne Bay: pink shrimp (Farfantepenaeus duorarum), white grunt 35 (Haemulon plumieri), bluestriped grunt (Haemulon sciurus), mutton snapper (Lutianus analis), 36 dog snapper (Lutianus jocu), gray snapper (Lutjanus griseus), and spiny lobster (Panulirus 37 argus). In that section, the NRC staff concludes that while EFH occurs in Biscayne Bay, neither 38 EFH nor the species themselves occur on the Turkey Point site. 39 The proposed Turkey Point subsequent license renewal would not result in any impacts to EFH. 40 As described above in Section 4.8.1.1, Species and Habitats Protected Under the Endangered 41 Species Act, the only potential activity that would affect aquatic resources outside of the Turkey 42 Point site is vessel traffic associated with infrequent deliveries of large parts and equipment to 43 the Turkey Point site and specifically associated with Units 3 and 4. However, such traffic would 44 not impact any aquatic habitats (including prey) in any noticeable or measurable way and, thus, 4-67

1 would also not affect EFH. The NRC staff also does not expect that federally managed species 2 themselves or their prey would be directly affected by barge traffic because individuals could 3 swim away to avoid vessels. Additionally, several of the federally managed species or their 4 prey are bottom-dwelling species that do not typically occur in the top of the water column 5 where they might encounter vessels. Biscayne Bay water quality is not likely to be affected by 6 continued Turkey Point operations in any way that would be discernable on the aquatic ecology 7 of Biscayne Bay for the reasons set forth in Section 4.8.1.1. The NRC staff, therefore, 8 concludes that the proposed action would have no adverse effects on EFH. Accordingly, the 9 NRC staff also finds that EFH consultation for the proposed action is not required. 10 4.8.2 No-Action Alternative 11 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 12 Turkey Point would shut down on or before the expiration of the current renewed licenses. The 13 Endangered Species Act action area for the no-action alternative would most likely be the same 14 or similar to the action area described in this section for the proposed subsequent license 15 renewal. However, a determination of effects would depend on the specific shutdown activities 16 that would be included in the proposed action as well as the listed species and critical habitats 17 present when the no-action alternative is implemented. 18 The CCS would continue to operate under the no-action alternative because it supports retired 19 fossil fuel Units 1 and 2. FPL plans to continue to withdraw water from the CCS to support 20 these units operation in synchronous condenser mode over the course of the proposed 21 subsequent license renewal period, as described in Section 3.1.3, Cooling and Auxiliary Water 22 Systems. Additionally, Unit 5, which remains in operation, discharges blowdown to the CCS. 23 CCS conditions could change under the no-action alternative because less heat would be 24 discharged to the system, which would potentially make conditions less saline and create more 25 favorable habitat for ESA-listed species; on the other hand, flow would likely decrease following 26 shutdown because Turkey Point Units 3 and 4 would not require as much water, and less flow 27 could lead to stagnant conditions and lower habitat quality for ESA-listed species. Regardless, 28 FPL would continue CCS restoration activities, as described in Section 3.7, Aquatic 29 Resources. The State of Florida requires these activities under FPLs Nutrient Management 30 Plan which is independent of subsequent license renewal. The CCS would continue to operate 31 during shutdown, as described in Section 4.5.2.1. Therefore, the CCS would likely continue to 32 provide habitat for ESA-listed species. 33 FPL currently implements a crocodile management plan to help improve breeding and nesting 34 habitat and protect American crocodiles on the Turkey Point site. Many portions of this plan are 35 voluntary and not required by any Federal, State, or local permit. During shutdown, FPL would 36 decide whether to stop or continue implementing the crocodile management plan. 37 Shutdown of the plant with the currently existing cooling system would likely not affect the 38 marine environments of Biscayne Bay, Card Sound, or the Atlantic Ocean. As such, there 39 would likely be no effects on federally listed species or critical habitats under the National 40 Marine Fisheries Services jurisdiction or on Essential Fish Habitat. 41 If necessary, any reinitiated Endangered Species Act, Section 7 consultation with the U.S. Fish 42 and Wildlife Service in connection with the terms and conditions of the current (or any future) 43 biological opinion would determine effects on the American crocodile as well other terrestrial 44 and freshwater species. However, a specific determination of effects would depend on the 45 nature of shutdown activities and the proposed action, the action area associated with those 4-68

1 activities, and the listed species, critical habitats, and Essential Fish Habitat present when the 2 no-action alternative is implemented. 3 4.8.3 Replacement Power Alternatives: Common Impacts 4 All of the replacement power alternatives would entail construction and operation of a new 5 energy-generating facility on the existing Turkey Point site; certain of these alternatives would 6 also entail offsite construction, in part, which is addressed for each of those alternatives below. 7 The Endangered Species Act action area and Essential Fish Habitat potentially affected by any 8 new plant would be similar to the subsequent license renewal action area because the 9 replacement power generating alternatives would generally be sited on the existing site. 10 However, specifically defining the action area would depend on exact plant siting, planned 11 construction activities, temporary and permanent structure locations, and timeline of the 12 alternative. Similarly, the listed species, critical habitats, and Essential Fish Habitat potentially 13 affected by a particular alternative would depend on the boundaries of that alternatives effects 14 and the species and habitats protected at the time the alternative is implemented. For instance, 15 if Turkey Point continues to operate until the end of the current renewed license terms (2032 for 16 Unit 3 and 2033 for Unit 4) and the replacement power alternative is implemented at that time, 17 the Services may have listed new species, delisted currently listed species whose populations 18 may have recovered, or revised EFH designations. These listing and designation activities 19 would change the potential for the various alternatives to impact special status species and 20 habitats. Additionally, requirements for Endangered Species Act, Section 7 consultation with 21 the Services as well as EFH consultation with the National Marine Fisheries Service would 22 depend on whether Federal permits or authorizations are required in order to implement each 23 particular alternative. 24 Sections 4.6.3 and 4.7.3 (both titled Replacement Power Alternatives: Common Impacts) 25 describe the types of impacts that terrestrial and aquatic resources would experience under 26 each alternative. Impacts on special status species and habitats would likely be similar in type. 27 However, the magnitude and significance of such impacts could be larger because special 28 status species and habitats are rare and more sensitive to environmental stressors. 29 4.8.3.1 New Nuclear Alternative 30 The NRC staff did not identify any impacts to special status species and habitats for the new 31 nuclear alternative beyond those discussed in the impacts common to all replacement power 32 alternatives. Because the NRC would remain the licensing agency under this alternative, the 33 Endangered Species Act and Magnuson-Stevens Act would require the NRC to consult with the 34 U.S. Fish and Wildlife Service and National Marine Fisheries Service, as applicable, prior to 35 issuing a license for the construction and operation of the new plant in order to consider whether 36 the plant would affect any federally listed species, adversely modify or destroy designated 37 critical habitat, or result in adverse effects on Essential Fish Habitat, if present. If the new 38 power plant required a Clean Water Act, Section 404 permit, the U.S. Army Corps of Engineers 39 may be a cooperating agency for the ESA consultation. Ultimately, the magnitude and 40 significance of adverse impacts on special status species and habitats would depend on the site 41 location and layout, plant design, plant operations, and the special status species and habitats 42 present in the area when the alternative is implemented. 4-69

1 4.8.3.2 Natural Gas Combined-Cycle Alternative 2 The NRC staff did not identify any impacts to special status species and habitats for the natural 3 gas alternative beyond those discussed in the impacts common to all replacement power 4 alternatives. Unlike Turkey Point subsequent license renewal or the licensing of a new nuclear 5 alternative, the NRC does not license natural gas facilities; therefore, the NRC would not be 6 responsible for initiating Endangered Species Act, Section 7 consultation or Essential Fish 7 Habitat consultation if special status species or habitats might be adversely affected under this 8 alternative. Other Federal agencies could be responsible for addressing impacts on special 9 status species and habitats depending on the specific permits or licenses that the new plant 10 would require. For instance, if the new power plant required a Clean Water Act, Section 404 11 permit, the ESA would require the U.S. Army Corps of Engineers to consider impacts on 12 Federally-listed species and Essential Fish Habitat. If no Federal permits were required, the 13 companies or entities implementing this alternative would be responsible for ensuring that their 14 actions do not jeopardize the continued existence of listed species because the Endangered 15 Species Act, Section 9 take prohibitions apply to both Federal and non-Federal entities. The 16 Magnuson-Stevens Act only requires EFH consultation for Federal actions. Therefore, EFH 17 consultation would be required if a Federal agency, such as the U.S. Army Corps of Engineers, 18 is involved in the permitting or authorization of this alternative and adverse effects are possible. 19 Ultimately, the magnitude and significance of adverse impacts on special status species and 20 habitats would depend on the site location and layout, plant design, plant operations, and the 21 special status species and habitats present in the area when the alternative is implemented. 22 4.8.3.3 Combination Alternative (Natural Gas Combined-Cycle Alternative and Solar 23 Photovoltaic Generation) 24 The NRC staff did not identify any impacts to special status species and habitats for the 25 combination alternative beyond those discussed in the impacts common to all replacement 26 power alternatives and in the natural gas-only alternative. The magnitude and significance of 27 adverse impacts on special status species and habitats resulting from this alternative would 28 depend on the site location and layout, plant design, plant operations, and the special status 29 species and habitats present in the area when the alternative is implemented. 30 4.8.3.4 Cooling Water System Alternative 31 The NRC staff did not identify any impacts to special status species and habitats for the cooling 32 water system alternative beyond those discussed in the impacts common to all replacement 33 power alternatives. To the extent that license amendments would be necessary to authorize 34 cooling towers to dissipate excess heat during plant operation, the NRC would be the licensing 35 agency under this alternative and the Endangered Species Act and Magnuson-Stevens Act 36 would require the NRC to consult with the U.S. Fish and Wildlife Service and National Marine 37 Fisheries Service, as applicable, during the staffs review of that alternative. If the cooling water 38 system alternative required a Clean Water Act, Section 404 permit, the U.S. Army Corps of 39 Engineers could be involved in ESA consultation. The consultations would determine whether 40 the construction and operation of cooling towers would affect any federally listed species, 41 adversely modify or destroy designated critical habitat, or result in adverse effects on Essential 42 Fish Habitat, if present. Ultimately, the magnitude and significance of adverse impacts on 43 special status species and habitats would depend on the location and layout of the cooling 44 towers, the design of the cooling towers, operational parameters, and the special status species 45 and habitats present in the area when the alternative is implemented. 4-70

1 4.9 Historic and Cultural Resources 2 This section describes the potential historic and cultural resources impacts of the proposed 3 action (subsequent license renewal) and alternatives to the proposed action. 4 4.9.1 Proposed Action 5 Table 4-2 identifies one site-specific (Category 2) issue related to historic and cultural resources 6 applicable to Turkey Point during the subsequent license renewal term. This issue is analyzed 7 below. 8 4.9.1.1 Category 2 Issue Related to Historic and Cultural Resources: Historic and Cultural 9 Resources 10 The National Historic Preservation Act of 1966, as amended (54 U.S.C. 300101 et seq.) 11 (NHPA), requires Federal agencies to consider the effects of their undertakings on historic 12 properties. Issuing a subsequent renewed license to a nuclear power plant is an undertaking 13 that could potentially affect historic properties. Historic properties are defined as resources 14 included on, or eligible for inclusion on, the National Register of Historic Places (NRHP). The 15 criteria for eligibility are listed in Title 36, Parks, Forests, and Public Property, of the Code of 16 Federal Regulations (36 CFR) Section 60.4, Criteria for Evaluation, and include (a) association 17 with significant events in history, (b) association with the lives of persons significant in the past, 18 (c) embodiment of distinctive characteristics of a type, period, or method of construction, or 19 (d) sites or places that have yielded, or are likely to yield, important information. 20 The historic preservation review process (NHPA Section 106) is outlined in regulations issued 21 by the Advisory Council on Historic Preservation (ACHP) in 36 CFR Part 800, Protection of 22 Historic Properties. In accordance with NHPA provisions, the NRC establishes the undertaking 23 (subsequent license renewal), identifies the appropriate State or Tribal historic preservation 24 officer, and initiates consultation with the appropriate officer. The NRC is required to make a 25 reasonable effort to identify historic properties included in, or eligible for inclusion in, the NRHP 26 in the area of potential effect (APE). The APE for a subsequent license renewal action includes 27 the power plant site, the transmission lines up to the first substation, and immediate environs 28 that may be affected by the subsequent license renewal decision and land-disturbing activities 29 associated with continued reactor operations during the subsequent license renewal term. In 30 addition, the NRC is required to notify the State historic preservation officer if historic properties 31 would not be affected by subsequent license renewal or if no historic properties are present. In 32 Florida, State historic preservation officer responsibilities lie with the Florida Division of 33 Historical Resources. 34 4.9.1.2 Consultation 35 In accordance with 36 CFR 800.8, Coordination with the National Environmental Policy Act, on 36 May 24, 2018, the NRC initiated consultation with the Advisory Council on Historic Preservation, 37 the Florida State historic preservation officer, and the Miami-Dade County Office of Historic 38 Preservation (NRC 2018j). Also, on May 24, 2018, the NRC initiated consultation with the 39 following Federally-recognized Tribes (NRC 2018j) (see Appendix C, Consultation 40 Correspondence): 41

• Miccosukee Tribe of Indians of Florida 42
• Muscogee (Creek) Nation 4-71

1

• Poarch Band of Creek Indians 2
• Seminole Tribe of Florida 3
• Seminole Nation of Oklahoma 4 In these letters, the NRC provided information about the proposed action, provided its definition 5 of the APE, and indicated that the NHPA review would be integrated with the NEPA process, in 6 accordance with 36 CFR 800.8(c), Use of the NEPA Process for Section 106 Purposes. The 7 NRC invited participation in the identification and possible decisions concerning historic 8 properties and also invited participation in the scoping process. The Seminole Tribe of Florida 9 stated in correspondence to the NRC that they have no comments regarding license renewal at 10 this time (STOF 2018). The Florida State historic preservation officer stated in correspondence 11 that since the proposed action will not involve ground disturbance it is unlikely to affect historic 12 properties (DHR 2018). The Seminole Nation of Oklahoma requested consultation meetings 13 with the NRC (SNO 2018). The NRC held a teleconference with the Seminole Nation of 14 Oklahoma Tribal historic preservation officer on July 2, 2018 (NRC 2018k). Upon learning that 15 the proposed action pertains to the license renewal of the existing Units 3 and 4 and that the 16 plant uses a closed system of cooling canals rather than discharging into Biscayne Bay, the 17 Tribal historic preservation officer did not express concerns regarding the subsequent license 18 renewal of Turkey Point (NRC 2018k). In addition, the Seminole Nation of Oklahoma Tribal 19 historic preservation officer requested a list of flora present at the Turkey Point site; in response, 20 the NRC staff provided a 2017 ecological monitoring survey of the Turkey Point site and vicinity 21 to the Tribe on July 9, 2018 (NRC 2018k). FPL received similar responses from the Florida 22 State historic preservation office, Seminole Nation of Oklahoma, and the Seminole Tribe of 23 Florida regarding the proposed action (FPL 2018h).

24 4.9.1.3 Findings 25 As described in Section 3.9, Historic and Cultural Resources, cultural resource surveys 26 conducted within the 9,460-ac (3,828-ha) Turkey Point site did not identify archeological sites 27 and concluded that the site has a low archeological potential. However, as discussed in 28 Section 3.9, during the NRC staffs environmental site audit, NRC staff became aware of three 29 wooden buildings that were part of a Boy Scouts of America camp and a cottage (known as the 30 Ranger House/McGregor Smith Cottage) of potential historic significance on the Turkey Point 31 site that are over 50 years old (FPL 2018h, NRC 2018c). The Boy Scouts structures and the 32 Ranger House/McGregor Smith Cottage have not been evaluated for eligibility for listing in the 33 NRHP. Given the age of the Ranger House/McGregor Smith Cottage (50 years old) and known 34 association with McGregor Smith Cottage, the NRC believes that the cottage is potentially 35 eligible for listing in the NRHP under Criterion b (association with the lives of persons significant 36 in the past). McGregor Smith was known for his involvement with the Boy Scouts of America 37 and environmental conservation; it is possible that onsite Boy Scouts structures were 38 associated with McGregor Smith (FPL 2018m). Similarly, as a result of McGregor Smiths 39 known involvement with the Boy Scouts, the Boy Scouts structures on the Turkey Point site may 40 potentially be eligible for listing in the NRHP under Criterion b. 41 Within a 6-mi (9.7-km) radius of the site are two properties determined eligible for listing in the 42 NRHP: K-9 cemetery (approximately 5.9 mi (9.5 km) from Turkey Point) and a canal bridge 43 (approximately 3.6 mi (5.8 km) from Turkey Point). During the environmental site audit, the 44 NRC staff observed that Turkey Point is not visible from these two sites due to tree buffers and 45 distance (NRC 2018c). 4-72

1 FPL did not identify subsequent license renewal-related ground-disturbing activities (FPL 2018f; 2 FPL 2018h). Plant operations and maintenance activities necessary to support subsequent 3 license renewal would likely be limited to previously disturbed areas of the site (FPL 2018f). In 4 the event that ground-disturbing activities are required as a result of plant operations and 5 maintenance activities, FPL has administrative controls in place on how to handle unanticipated 6 historical and cultural finds related to potential ground-disturbing activities. If historic and 7 cultural resources are discovered within the project site, FPL will notify Floridas Division of 8 Historical Resources and the Florida Department of Environmental Protection, Southeast 9 District (FPL 2018f). Additionally, FPL provides training sessions for staff that are involved in 10 potential future ground-disturbing activities; the environmental training sessions are intended to 11 familiarize FPL staff with common artifact types and actions to be taken if cultural resources are 12 identified (FPL 2018h). 13 Based on (1) Tribal input, (2) no new ground disturbance, (3) FPLs administrative controls, and 14 (4) State historic preservation officer input, the NRC staff concludes that subsequent license 15 renewal for Turkey Point Units 3 and 4 would not adversely affect any known historic properties 16 or historic and cultural resources. 17 4.9.2 No-Action Alternative 18 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 19 FPL would terminate reactor operations on or before the expiration of the current renewed 20 licenses. As a result of facility shutdown, land-disturbing activities or dismantlement are not 21 anticipated as these would be conducted during decommissioning. Therefore, facility shutdown 22 would have no immediate effect on historic properties or historic and cultural resources. 23 4.9.3 Replacement Power Alternatives: Common Impacts 24 If construction and operation of replacement power alternatives require a Federal undertaking 25 (e.g., license, permit), the Federal agency would need to make a reasonable effort to identify 26 historic properties within the area of potential effects and consider the effects of their 27 undertakings on historic properties, in accordance with Section 106 of the National Historic 28 Preservation Act (NHPA) of 1966, as amended (54 U.S.C. 300101 et seq.). Historic and cultural 29 resources identified would need to be recorded and evaluated for eligibility for listing on the 30 NRHP. If historic properties are present and could be affected by the undertaking, adverse 31 effects would be assessed, determined, and resolved in consultation with the State historic 32 preservation officer and any Indian Tribe that attaches religious and cultural significance to 33 identified historic properties through the Section 106 process. 34 Construction 35 Impacts to historic and cultural resources from the construction of replacement power 36 alternatives are primarily related to ground disturbance (land clearing, excavations, etc.). For 37 the new nuclear alternative, natural gas combined-cycle alternative, and the natural gas 38 combined-cycle portion and one installation of the solar photovoltaic portion of the combination 39 alternative, this environmental review assumes that the new facilities would be built on the 40 Turkey Point site. For the solar portion of the combination alternative, this environmental review 41 assumes that three of the new facilities would occur at other sites in Miami-Dade County and/or 42 Broward County. As discussed in Section 3.9.2, Historic and Cultural Resources, of this SEIS, 43 while a comprehensive cultural resource survey of the entire 9,460-ac (3,828-ha) Turkey Point 44 site has not been conducted, cultural resource surveys that have been completed have 4-73

1 concluded that the Turkey Point site has a low archeological potential. Land areas not 2 previously surveyed (onsite and offsite) that are affected by the construction of power 3 alternatives would need to be surveyed to identify and record historic and cultural resources. 4 Operation 5 The potential for impacts on historic and cultural resources from the operation of replacement 6 power alternatives would be related to maintenance activities at the site as well as visual 7 impacts that would vary with plant heights and associated exhaust stack or cooling towers. The 8 replacement power alternatives located at the Turkey Point site would be in an industrialized 9 area where tall structures already exist and visible plumes from the Turkey Point Unit 5 cooling 10 towers occur. 11 4.9.3.1 New Nuclear Alternative 12 Impacts on historic and cultural resources from the construction and operation of a new nuclear 13 alternative would include those common to all replacement power alternatives. The new 14 nuclear alternative would require an estimated 360 ac (240 ha) of land on the Turkey Point site. 15 Within a 6-mi (9.7-km) radius of the site are two offsite properties (at distances of 16 3.6 mi (5.8 km) and 5.9 mi (9.5 km) from the Turkey Point site) determined to be eligible for 17 listing in the NRHP. The tallest structures would be the containment buildings at approximately 18 230 feet (70 m). A visible plume would occur from the draft cooling towers, particularly during 19 winter months, which could have a median plume length of 820 feet (250 m) (NRC 2016a). Tall 20 structures and cooling tower plumes that currently exist on the Turkey Point site are not visible 21 from the two NRHP-eligible sites. Given the presence of tree buffers and distance, the NRC 22 staff does not anticipate that the new structures and plumes as a result of the new nuclear 23 alternative would be visible from these offsite NRHP-eligible properties. As discussed in 24 Section 4.9.1.3 of this SEIS, there are historic structures on the Turkey Point site that are 25 potentially eligible for listing on the NRHP. Construction of the new nuclear alternative on or 26 near these structures, however, could be avoided. Depending on where the new nuclear 27 alternative is located within the FPL site, construction and operation of this alternative could 28 introduce additional containment buildings, stacks, and facility support structures and affect the 29 viewshed of these historic structures. However, the Turkey Point site is an industrialized area 30 restricted to the public where tall structures and plumes already exist. Therefore, construction 31 and operation of the new nuclear alternative would be compatible with the current site and not 32 out of character with the current setting. 33 Given that the Turkey Point site has a low archeological potential, that current site infrastructure 34 use would be maximized, and that avoidance of significant historic resources would be possible, 35 the NRC staff concludes that construction of the new nuclear alternative on the Turkey Point site 36 would not adversely affect historic and cultural resources. 37 4.9.3.2 Natural Gas Combined-Cycle Alternative 38 Impacts on historic and cultural resources from the construction and operation of a new natural 39 gas alternative would include those common to all replacement power alternatives. The natural 40 gas facility would require an estimated 75 ac (30 ha) for the power block and support facilities 41 and an additional 1,200 ac (490 ha) for a natural gas pipeline. Construction of the natural gas 42 pipeline would use existing utility corridors to the extent possible. Within a 6-mi (9.7-km) radius 43 of the site are two properties (approximately 3.6 mi (5.8 km) and 5.9 mi (9.5 km) from the 44 Turkey Point site) determined to be eligible for listing in the NRHP. The tallest natural gas 4-74

1 alternative structure would be the plant stacks at approximately 150-feet tall (46-m). The 2 current Turkey Point containment structures are not visible from the two NRHP-eligible sites. 3 Because the natural gas plant stacks would be shorter than the current Turkey Point 4 containment structures, the NRC staff does not anticipate that the natural gas plant stacks 5 would be visible from the NRHP-eligible sites. A visible plume would occur from the draft 6 cooling towers, particularly during winter months, which could have a median plume length of 7 820 feet (250 m) (NRC 2016a). However, the NRC staff does not anticipate that the plume 8 would be visible from these offsite NRHP-eligible sites given the presence of tree buffers and 9 distance. 10 As discussed in Section 4.9.1.3 of this SEIS, there are historic structures on the Turkey Point 11 site that are potentially eligible for listing in the NRHP. Construction of the natural gas 12 alternative on or near these structures, however, could be avoided. Depending on where the 13 natural gas alternative is located within the FPL site, construction and operation of this 14 alternative would introduce additional containment buildings, stacks, and facility support 15 structures and affect the viewshed of these historic structures. However, the Turkey Point site 16 is an industrialized area, restricted to the public, where tall structures and plumes already exist. 17 Therefore, construction and operation of the natural gas alternative would be compatible with 18 the current site and not out of character with the current setting. 19 Given that the Turkey Point site has a low archeological potential and that existing infrastructure 20 use would be maximized, including the preferential use of previously disturbed land for the 21 pipeline, the avoidance of significant historic resources would be possible. Therefore, the NRC 22 staff concludes that construction and operation of the natural gas alternative on the Turkey Point 23 site would not adversely affect historic and cultural resources. 24 4.9.3.3 Combination Alternative 25 Impacts on historic and cultural resources from the construction and operation of the natural gas 26 components of the combination alternative would be the same as the natural gas-only 27 alternative given that land requirement, location, and facility height structures would be the 28 same. Therefore, the NRC staff concludes that construction and operation of the natural gas 29 portion of the combination alternative on the Turkey Point site would not adversely affect historic 30 and cultural resources. As stated in Section 2.2.2.3 of this SEIS, the NRC staff assumes that 31 the solar portion that would be located on the Turkey Point site would maximize use of the 32 existing infrastructure, would have a low visual profile, and would be located on a site that has a 33 low archeological potential. Construction and operation of the solar alternative on or near 34 historic and cultural resources could be avoided. Therefore, construction and operation of the 35 solar component on the Turkey Point site would not adversely affect historic and cultural 36 resources. 37 Impacts on historic and cultural resources from the construction and operation of the solar 38 portion of the combination alternative would include those common to all replacement power 39 alternatives. The solar portion of the combination alternative would require an estimated 40 470 ac (190 ha) for each of the four solar facilities. The impacts from the construction and 41 operation of the solar component on historic and cultural resources would vary, depending on 42 where solar facilities are constructed. The three offsite solar facilities would be installed in 43 Miami-Dade and/or Broward Counties, but the exact locations are unknown. Depending on the 44 site and historic and cultural resources present, construction and operation of the solar facilities 45 could alter these resources within the area of potential effect. Areas with the greatest cultural 4-75

1 sensitivity could be avoided or effectively managed. Therefore, for these three sites, the historic 2 and cultural resource impact could range from no adverse effect to adverse effect. 3 4.9.4 Cooling Water System Alternative 4 If construction and operation of the cooling water system alternative were to require NRC 5 licensing actions (e.g., a license amendment), the NRC would need to comply with Section 106 6 of NHPA consultation requirements. The Section 106 process would be initiated after 7 submission of an application or request from FPL. 8 Land areas needed to support construction of the mechanical draft cooling towers would need 9 to be surveyed for historic and archeological resources. Any resources found during these 10 surveys would need to be evaluated for their eligibility for listing on the NRHP, and any adverse 11 effects would need to be mitigated. Constructing the cooling towers on previously disturbed 12 land could reduce the potential impact to historic and archaeological resources. As discussed in 13 Section 3.9.2 of this SEIS, while a comprehensive cultural resource survey of the entire 14 9,460-ac (3,828-ha) Turkey Point site has not been conducted, cultural resource surveys that 15 have been completed have concluded that the Turkey Point site has a low archeological 16 potential. Within a 6-mi (9.7-km) radius of the site there are two offsite properties 17 (approximately 3.6 mi (5.8 km) and 5.9 mi (9.5 km) from the Turkey Point site) which were 18 determined to be eligible for listing in the NRHP. The cooling towers would be approximately 19 70 feet (20 m) in height and plumes could be visible during the winter months with a median 20 length of 820 feet (250 m) (NRC 2016a). However, the plume is not anticipated to be visible 21 from these offsite NRHP-eligible sites given the presence of tree buffers and distance. 22 As discussed in Section 4.9.1.3 of this SEIS, there are historic structures on the Turkey Point 23 site that are potentially eligible for listing in the NRHP. Construction of the cooling towers on or 24 near these structures could be avoided. Depending on where the cooling towers are located 25 within the FPL site, construction and operation of this alternative would introduce additional 26 cooling towers and visible plumes and would affect the viewshed of these historic structures. 27 However, the Turkey Point site is an industrialized area, restricted to the public, where tall 28 structures and visible plumes already exist. Therefore, construction and operation of the cooling 29 towers would be compatible with the current site and not out of character with the current 30 setting. 31 The Turkey Point site has a low archeological potential and avoidance of construction and 32 operations impacts of the cooling water system alternative to significant historic resources would 33 be possible. The plume from the Turkey Point cooling towers is not anticipated to be visible 34 from offsite historic properties within a 6-mi radius of Turkey Point. Therefore, the NRC staff 35 concludes that construction and operation of the cooling water system alternative on the Turkey 36 Point site would not adversely affect historic and cultural resources. 37 4.10 Socioeconomics 38 This section describes the potential socioeconomic impacts of the proposed action (subsequent 39 license renewal) and alternatives to the proposed action. 40 4.10.1 Proposed Action 41 According to the GEIS (NRC 2013a), the impacts of license renewal on socioeconomic issues 42 would be SMALL. The NRC staff identified no new or significant information for these issues. 4-76

1 Socioeconomic effects of ongoing reactor operations at Turkey Point have become well 2 established as regional socioeconomic conditions have adjusted to the presence of the nuclear 3 power plant. Any changes in employment and tax revenue caused by subsequent license 4 renewal and any associated refurbishment activities could have a direct and indirect impact on 5 community services and housing demand, as well as traffic volumes in the communities around 6 the nuclear power plant. FPL indicated in its environmental report that it has no plans to add 7 non-outage workers during the subsequent license renewal term, does not anticipate changes in 8 tax payments during the subsequent license renewal term, and will not conduct refurbishment 9 activities. Consequently, people living in the vicinity of Turkey Point and in Miami-Dade County 10 are not likely to experience any changes in socioeconomic conditions during the subsequent 11 license renewal term beyond what is currently being experienced under the current renewed 12 licenses. 13 As identified in Table 4-1 of this SEIS, the socioeconomic impacts of continued reactor 14 operations during the subsequent license renewal term would be SMALL. Table 4-2 of this 15 SEIS does not identify any site-specific (Category 2) socioeconomic issues for Turkey Point. 16 4.10.2 No-Action Alternative 17 4.10.2.1 Socioeconomics 18 Under the no-action alternative, the NRC would not issue subsequent renewed licenses and 19 FPL would shut down Turkey Point on or before the expiration of the current renewed licenses. 20 Termination of nuclear power plant operations would result in cessation of electrical power 21 production and a loss of jobs, income, and tax revenues. Socioeconomic impacts from the 22 termination of reactor operations would be concentrated in Miami-Dade County since the 23 majority of Turkey Point Units 3 and 4 workers reside in this county. Employment and income 24 from the buying and selling of goods and services needed to operate and maintain the nuclear 25 power plant would also be reduced. 26 As jobs are eliminated, some, but not all, of the total 1,046 FPL workers (permanent and 27 contractors) could begin to leave the region. If FPL workers and their families move out of the 28 region, increased housing vacancies and decreased demand could cause housing prices to fall. 29 However, the FPL workforce that resides in Miami-Dade County (approximately 85 percent of 30 the total Turkey Point permanent workforce) represents only approximately 0.05 percent of 31 Miami-Dade Countys 2016 civilian labor force (see Section 3.10.2.1, Regional Employment 32 and Income). The remaining FPL workers similarly comprise a very small percentage (less 33 than 0.1 percent) of the civilian labor force in other nearby counties. Therefore, the migration of 34 these workers out of those nearby counties would not have a noticeable socioeconomic impact 35 in those counties. 36 The loss of tax revenue could result in the reduction or elimination of some public and 37 educational services. However, as noted in Section 3.10.5, Tax Revenues, FPL property tax 38 payments to Miami-Dade County and Miami-Dade County Public School District as a result of 39 Turkey Point Units 3 and 4 operations represent less than 1 percent of Miami-Dade County total 40 revenues and Miami-Dade County Public School District total revenues. Because Turkey Point 41 is located in a large metropolitan area, socioeconomic impacts from not subsequently renewing 42 the Units 3 and 4 operating licenses and terminating reactor operations would be SMALL. 4-77

1 4.10.2.2 Transportation 2 Traffic volume as a result of commuting workers and truck deliveries on roads in the vicinity of 3 Turkey Point Units 3 and 4 would be reduced after plant shutdown. The reduction in traffic 4 would be associated with the loss of jobs. Similarly, truck deliveries to Turkey Point would be 5 reduced. Therefore, traffic-related transportation impacts would be SMALL as a result of the 6 shutdown of Turkey Point Units 3 and 4. 7 4.10.3 Replacement Power Alternatives: Common Impacts 8 The following provides a discussion of the common socioeconomic and transportation impacts 9 during construction and operation of replacement power generating facilities. 10 4.10.3.1 Socioeconomics 11 Socioeconomic impacts are defined in terms of changes in the social and economic conditions 12 of a region. For example, the creation of jobs and the purchase of goods and services during 13 the construction and operation of a replacement power plant could affect regional employment, 14 income, and tax revenue. For each alternative, two types of jobs would be created: 15 (1) construction jobs, which are transient, short in duration, and less likely to have a long-term 16 socioeconomic impact, and (2) operations jobs, which have the greater potential for permanent, 17 long-term socioeconomic impacts. The socioeconomic region of influence is 18 Miami-Dade County for the new nuclear alternative and natural gas combined-cycle alternative. 19 The socioeconomic region of influence for the combination alternative would be Miami-Dade 20 and Broward counties. 21 Construction 22 The relative economic effect of an influx of workers on the local economy and tax revenue 23 would vary and depend on the size of the workforce and construction completion time. The 24 greatest impact would occur in the communities where the majority of construction workers 25 would reside and spend their incomes. While some construction workers would be local, 26 additional workers may be required from outside the immediate area depending on the local 27 availability of appropriate trades and occupational groups. The region of influence could 28 experience a short-term economic boom during construction from increased tax revenue, 29 income generated by expenditures for goods and services, and the increased demand for 30 temporary (rental) housing. After construction, the region of influence would likely experience a 31 return to preconstruction economic conditions. 32 Operation 33 Prior to the commencement of startup and operations, local communities could see an influx of 34 operations workers and their families resulting in an increased demand for permanent housing 35 and public services. These communities would also experience the economic benefits from 36 increased income and tax revenue generated by the purchase of goods and services needed to 37 operate a new replacement power plant. Consequently, power plant operations would have a 38 greater potential for effecting permanent, long-term socioeconomic impacts on the region. 4-78

1 4.10.3.2 Transportation 2 Transportation impacts are defined in terms of changes in level of service conditions on local 3 roads in the region. Additional vehicles on local roadways during construction and operations 4 could lead to traffic congestion, level of service impacts, and delays at intersections. 5 Construction 6 Transportation impacts during the construction of a replacement power plant would consist of 7 commuting workers and truck deliveries of equipment and material to the construction site. 8 Workers would arrive via site access roads, and the volume of traffic would increase during shift 9 changes. In addition, trucks would transport equipment and material to the construction site, 10 thus increasing the amount of traffic on local roads. The increase in traffic volumes could result 11 in levels of service impacts and delays at intersections during certain hours of the day. In some 12 instances, construction material could also be delivered by rail or barge. 13 Operation 14 Traffic-related transportation impacts would be greatly reduced after construction has been 15 completed. Transportation impacts would include daily commuting by the operations workforce 16 and deliveries of material, and the removal of commercial waste material by truck. Increased 17 commuter traffic would occur during shift changes and deliveries of materials and equipment to 18 the power plant. 19 4.10.4 New Nuclear Alternative 20 Socioeconomics 21 Construction of a new nuclear alternative would require a large workforce, approximately a peak 22 at 3,900 workers. However, peak workforce construction jobs would represent approximately 23 0.3 percent of employment in Miami-Dade County. Tax revenue increases in the form of sales 24 taxes and property taxes in the region would occur. However, because of the large tax revenue 25 of Miami-Dade County (see Section 3.10.5), the impact on tax revenues during construction, 26 while beneficial, would be relatively minimal. For instance, the NRC staff concluded that 27 construction expenses for Turkey Point Units 6 and 7 corresponded to approximately 28 seven-tenths of 1 percent of Miami-Dade County sales and use tax revenues (NRC 2016a). As 29 presented in Section 3.10.3.1, Transient Population, and 3.10.4.1, Housing, 30 Miami-Dade County has available vacant rental units and housing to support a 3,900 peak 31 construction workforce. Increases in property tax revenue are not anticipated during 32 construction since property taxes due to the new nuclear units would not occur until after 33 construction is completed (NRC 2016a). As a result of the construction workforce, service or 34 retail-related jobs would be indirectly created (NRC 2016a). The NRC staff estimated that peak 35 construction annual wage earnings of a workforce of 3,950 for Turkey Point Units 6 and 7 and 36 indirect jobs would be less than eight-tenths of 1 percent of total annual wage earnings in 37 Miami-Dade County (NRC 2016a). The construction of a new nuclear power plant would create 38 a large number of jobs (directly and indirectly) and the socioeconomic impacts would be 39 beneficial. The large workforce and jobs would be noticeable to the local communities in and 40 near Homestead, FL. Therefore, the socioeconomic impacts from construction of a new nuclear 41 alternative are SMALL to MODERATE. 4-79

1 Approximately 800 workers would be required during nuclear power plant operations, which 2 would represent approximately 0.05 percent of the jobs in Miami-Dade County. Salary earnings 3 of the workforce would be introduced into the Miami-Dade County economy, but they would not 4 be noticeable. For instance, the NRC staff estimated that annual earnings of 806 operation 5 workers for Turkey Point Units 6 and 7 would be a tenth of one percent of total wage earnings in 6 Miami-Dade County (NRC 2016a). Tax revenues would increase as a result of operations of 7 the new nuclear alternative. However, revenue generated by sales taxes and property taxes 8 from operations of a new nuclear alternative would be minor. For instance, the NRC staff 9 concluded that sales from operation of the proposed Turkey Point Units 6 and 7 would generate 10 up to $2 million in sales tax and $50.4 million in property taxes. When compared to Miami-Dade 11 County tax revenues (see Section 3.10.5, Tax Revenues), this is a small percentage. 12 Furthermore, the number of operational and outage workers for a new nuclear alternative, 13 property tax revenue, sales tax revenue, and the socioeconomic impacts would be similar to 14 those currently experienced for Units 3 and 4. Therefore, the socioeconomic impacts from 15 operating of a new nuclear power plant would be SMALL. 16 Transportation 17 During periods of peak construction activity, up to 3,900 workers would be commuting daily to 18 the construction site. Workers commuting to the site and delivery vehicles would arrive via site 19 access roads and the volume of traffic on nearby roads would increase substantially. The 20 increase in vehicular traffic would peak during shift changes and during the peak building 21 workforce use, resulting in temporary levels of service impacts and delays at intersections. In 22 addition to the workforce, delivery vehicles transporting construction material would also use 23 roads in the vicinity. A traffic study found that an additional 3,650 peak construction workforce 24 and delivery vehicles for construction of Turkey Point Units 6 and 7 would not result in the 25 exceedance capacity of local roads (along Palm Drive/SW 344th, SW 328th St, and SW 312th St) 26 in the vicinity of the Turkey Point site; however, in order to maintain an adequate level of service 27 for these roads, road improvements (additional turn lanes, roadway widening) would need to be 28 implemented (Traf Tech 2009). Therefore, additional vehicles as a result of construction would 29 noticeably alter traffic on roads in the vicinity Turkey Point, result in a loss of service for the 30 nearby roads, and, without mitigation measures, would destabilize the transportation 31 infrastructure. Therefore, the impact on transportation infrastructure in the immediate vicinity of 32 the Turkey Point site during construction of a new nuclear power plant would be LARGE. 33 Approximately 800 workers would be commuting daily to the Turkey Point site during 34 operations. Traffic on roadways would peak during shift changes and refueling outages, 35 resulting in temporary levels of service impacts and delays at intersections. However, the 36 operational and outage workforce would be similar to Turkey Point and the transportation 37 impacts for a new nuclear alternative would be similar to what is currently being experienced as 38 a result of operation for Units 3 and 4. Therefore, transportation impacts in the immediate 39 vicinity of the Turkey Point site during nuclear power plant operations for the new nuclear 40 alternative would be SMALL. 41 4.10.5 Natural Gas Combined-Cycle Alternative 42 Socioeconomics 43 Socioeconomic impacts would result from the approximately 1,200 construction workers and 44 150 workers to operate the natural gas alternative. Overall, the size of the workforce for both 45 construction and operations would be smaller than the new nuclear alternative. The natural gas 4-80

1 alternative would require 75 ac (30 ha) for the power block. While the natural gas alternative 2 power block would require less land than Turkey Point, an additional 1,200 ac (490 ha) would 3 be needed for right-of-way to connect with an existing natural gas supply line. This could result 4 in additional property tax revenue. However, given Miami-Dade Countys large funding source 5 revenues (see Section 3.10.5 for a discussion of Miami-Dade County property tax revenues), 6 additional property tax revenue from the natural gas alternative is not anticipated to be 7 noticeable. The capital costs of a natural gas-fired power plant, the building and operations 8 workforces, and the local expenditures on materials and equipment are lower at a natural-gas 9 plant than those of a nuclear facility (EIA 2016d, EIA 2017f). Therefore, these impacts would be 10 similar but of lesser magnitude than the new nuclear alternative. Therefore, the socioeconomic 11 impacts from construction and operation of a natural gas alternative would be SMALL. 12 Transportation 13 Traffic-related impacts would result from the 1,200 construction workers and 150 workers during 14 operation of the natural gas alternative, as well as delivery vehicles. The construction workforce 15 for a natural gas-fired power plant would be less than the construction and operational 16 workforce (when considering refueling outage workers) for a new nuclear alternative. The NRC 17 staff concludes that the transportation impacts in the immediate vicinity of the Turkey Point site 18 from construction would be noticeable, but not destabilizing, and therefore MODERATE. 19 The operations workforce for the natural gas alternative would be substantially less than the 20 operations workforce of a new nuclear alternative. While there would be some increase in traffic 21 in the vicinity of the Turkey Point site for the natural-gas plant during operation, that increase 22 would be less than the increase for the new nuclear alternative. Additionally, worker vehicles 23 from operation of the natural gas alternative would be less than what is experienced from 24 operation of Turkey Point. The NRC staff concludes that the transportation impacts in the 25 immediate vicinity of the Turkey Point site from operation would be SMALL. 26 Therefore, the NRC staff concludes that, overall, the transportation impacts in the immediate 27 vicinity of the Turkey Point site from constructing and operating the natural gas alternative would 28 range from SMALL to MODERATE. 29 4.10.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 30 Generation) 31 Socioeconomics 32 The workforce required to construct and operate the natural gas portion of the combination 33 alternative and land requirements would be similar to the full-power natural gas-only alternative 34 discussed in Section 4.10.5 since the natural gas unit under the combination alternative would 35 be approximately 95 percent of that of the natural gas-only alternative. Therefore, the NRC staff 36 concludes that the socioeconomic impacts from construction and operations of the natural gas 37 portion of the combination alternative would be SMALL. 38 Installation of the solar portion of the combination alternative would require up to 200 39 construction workers. Miami-Dade Countys regional employment, tax revenue, and housing is 40 discussed in Chapter 3, Affected Environment. Broward County has a civilian labor force of 41 approximately 997,404 individuals and 143,898 vacant housing units (USCB 2016h). In 2017, 42 Broward Countys property tax revenue was $0.929 billion, and its total operating revenue was 43 $4.704 billion (Broward County 2017). A construction workforce of 200 would not result in a 4-81

1 noticeable or substantial increase in housing demand, jobs, or wages given Miami-Dade and 2 Broward counties available housing and labor force. Additionally, local expenditures for goods 3 and expenditures for construction of the solar portion would not result in noticeable tax revenue 4 given both Miami-Dade and Broward counties large funding source revenues. Therefore, the 5 socioeconomic impacts from constructing the solar portion would be SMALL. 6 A small number of workers would be needed to maintain and operate the solar systems 7 (10 workers). This would not result in a noticeable or substantial increase in housing demand, 8 jobs, or wages. Operation of solar systems would generate tax revenue from operation 9 expenditures and the large amount of land required to support this alternative (total of 1,410 ac). 10 However, Miami-Dade and Broward counties both have large funding source revenues. The 11 additional tax revenue from operation of solar units is not anticipated to be noticeable given both 12 counties revenues. Therefore, the socioeconomic impacts from operation of the solar portion of 13 the combination alternative would be SMALL. 14 Transportation 15 Traffic-related impacts for the natural gas portion of the combination alternative would result 16 from worker and delivery vehicles. Since the workforce required to construct and operate the 17 natural gas power plant component of the combination alternative would be approximately the 18 same as the natural gas-only alternative discussed in Section 4.10.5, the NRC staff concludes 19 that the overall transportation impacts in the immediate vicinity of the Turkey Point site from 20 constructing and operating the natural gas portion of the combination alternative would be 21 SMALL to MODERATE. 22 In addition to delivery vehicles, the solar component of the combination alternative would 23 require an estimated 200 workers during construction and 10 workers during operation. The 24 construction and operations workforce would not result in a substantial increase in traffic in the 25 vicinity of the Turkey Point site. An additional 200 worker vehicles during construction at the 26 two additional sites in Broward County could be noticeable depending on the exact location of 27 the sites and access roads and result in level of service changes and therefore impacts could be 28 SMALL to MODERATE. However, an additional 10 worker vehicles during operations is not 29 anticipated to have noticeable changes in traffic; the transportation impacts from operation of 30 the solar portion of the combination alternative would be SMALL. Therefore, the staff concludes 31 that the overall transportation impacts from constructing and operating the solar component of 32 the combination alterative would be SMALL to MODERATE. 33 4.10.7 Cooling Water System Alternative 34 4.10.7.1 Socioeconomics 35 Site preparation, necessary plant modifications, and cooling tower installation would result in 36 short-term employment increases. The workforce necessary to construct a closed-cycle 37 mechanical-draft cooling tower system at Turkey Point is unknown. Construction workforce 38 estimates on the construction of cooling tower technologies have been prepared for other 39 nuclear power plants. A mechanical-draft cooling tower system consisting of two cooling tower 40 units at the Oyster Creek Nuclear Generating Station (single unit) was estimated to require 41 100 workers during non-peak construction months (NRC 2006b). Bechtel (2014) estimated that 42 for a closed-cycle cooling alternative (consisting of two wet mechanical draft cooling towers per 43 unit) at Diablo Canyon Power Plant, approximately 1,117 construction workers (585 workers per 44 shift and 2 work shifts) would be needed. Based on these estimates, construction of cooling 4-82

1 towers at Turkey Point could require approximately between 200 and 1,110 construction 2 workers. 3 The majority of construction workers would relocate temporarily to Miami-Dade County, 4 resulting in a short-term increase in the population and increased demand for temporary 5 housing. However, given Miami-Dade Countys population and available housing (see 6 Sections 3.10.3, 3.10.3.1, and 3.10.4) an additional 1,110 construction workers would not result 7 in a noticeable increase in population or shortages in temporary housing. Using the new 8 nuclear alternative discussed in Section 4.10.4 as a bounding analysis for the construction of 9 the cooling water system alternative, increases in property tax revenue, sales taxes, and wages 10 as a result of construction would be minor. Therefore, the socioeconomic impacts of 11 constructing the cooling water system alternative would be SMALL. 12 Once the construction of the closed-cycle cooling towers and plant modifications has been 13 completed, the size of the workforce at Turkey Point would return to normal. A small number of 14 additional workers would likely be needed to maintain and monitor the cooling towers. At Oyster 15 Creek Nuclear Generating Station (single unit), an additional 25 employees were estimated to 16 be needed for operation of the closed-cycle cooling system (NRC 2006b). Therefore, 50 17 additional operations workers would be a reasonable estimate for the number of additional 18 employees needed at Turkey Point Units 3 and 4. This would result in no noticeable increase in 19 population or housing demand. Annual property taxes could increase with an increased 20 assessed value of Turkey Point with the addition of a closed-cycle cooling system. However, 21 additional revenue generated from operating the closed-cycle system would not be noticeable. 22 Therefore, the socioeconomic impacts of operating the cooling water system alternative would 23 be SMALL. 24 4.10.7.2 Transportation 25 Transportation impacts associated with the construction and operation of the cooling water 26 system alternative would consist of commuting workers and truck deliveries of construction 27 materials to the Turkey Point site. Construction of the cooling water system alternative at 28 Turkey Point could require up to 1,110 construction workers. The increase in vehicular traffic 29 would peak during shift changes, resulting in temporary levels of service impacts and delays on 30 local roads and at intersections. Up to 1,110 construction workers, in addition to the existing 31 Turkey Point Units 3 and 4 workforce, commuting to the site would noticeably increase traffic on 32 the roads. Therefore, transportation impacts in the immediate vicinity of the Turkey Point site 33 during construction of the cooling towers could range from SMALL to MODERATE and would 34 depend on the number of worker vehicles and truck deliveries. Once the construction of the 35 cooling towers and plant modifications has been completed, the size of the workforce and truck 36 deliveries would return to normal. A small number of additional workers may be needed to 37 maintain and monitor the cooling towers. Operation of the closed-cycle cooling system would 38 have little to no effect on transportation infrastructure and, therefore, transportation impacts 39 would be SMALL. 40 Overall, transportation impacts in the immediate vicinity of the Turkey Point site from the 41 construction and operation of the cooling water system alternative could range from SMALL to 42 MODERATE. 4-83

1 4.11 Human Health 2 This section describes the potential human health impacts of the proposed action (subsequent 3 license renewal) and alternatives to the proposed action. 4 4.11.1 Proposed Action 5 According to the GEIS (NRC 1996 and NRC 2013a), the generic issues related to human health 6 as identified in Table 4-1 would have SMALL impacts resulting from license renewal. As 7 discussed in Chapter 3, the NRC staff identified no new and significant information for these 8 issues. Thus, as concluded in the GEIS, the impacts of those generic issues related to human 9 health would be SMALL. 10 Table 4-2 identifies one uncategorized issue (chronic exposure to electromagnetic fields) and 11 one site-specific (Category 2) issue (electric shock hazards) related to human health applicable 12 to Turkey Point subsequent license renewal. These issues are analyzed below. 13 4.11.1.1 Uncategorized Issue Relating to Human Health: Chronic Effects of Electromagnetic 14 Fields (EMFs) 15 The GEIS (NUREG-1437) (NRC 2013a) does not designate the chronic effects of 60-Hz 16 electromagnetic fields (EMFs) from power lines as either a Category 1 or Category 2 issue. 17 Until a scientific consensus is reached on the health implications of electromagnetic fields, the 18 NRC will not include them as Category 1 or 2 issues. 19 The potential for chronic effects from these fields continues to be studied and is not known at 20 this time. The National Institute of Environmental Health Sciences (NIEHS) directs related 21 research through the U.S. Department of Energy (DOE). 22 The report by the National Institute of Environmental Health Sciences, NIEHS Report on Health 23 Effects from Exposure to Power-Line Frequency Electric and Magnetic Fields (NIEHS 1999), 24 contains the following conclusion: 25 The NIEHS concludes that ELF-EMF [extremely low frequency-electromagnetic 26 field] exposure cannot be recognized as entirely safe because of weak scientific 27 evidence that exposure may pose a leukemia hazard. In our opinion, this finding 28 is insufficient to warrant aggressive regulatory concern. However, because 29 virtually everyone in the United States uses electricity and therefore is routinely 30 exposed to ELF-EMF, passive regulatory action is warranted such as continued 31 emphasis on educating both the public and the regulated community on means 32 aimed at reducing exposures. The NIEHS does not believe that other cancers or 33 non-cancer health outcomes provide sufficient evidence of a risk to currently 34 warrant concern. 35 This statement was not sufficient to cause the NRC to change its position with respect to the 36 chronic effects of electromagnetic fields. The NRC staff considers the GEIS finding of 37 UNCERTAIN still appropriate and will continue to follow developments on this issue. 4-84

1 4.11.1.2 Category 2 Issue Related to Human Health: Electric Shock Hazards 2 Based on the GEIS (NUREG-1437) (NRC 2013a), the Commission found that electric shock 3 resulting from direct access to energized conductors or from induced charges in metallic 4 structures has not been identified to be a problem at most operating plants and generally is not 5 expected to be a problem during the subsequent license renewal term. However, a site-specific 6 review is required to determine the significance of the electric shock potential along the portions 7 of the transmission lines that are within the scope of the Turkey Point subsequent license 8 renewal review. 9 As discussed in Section 3.11.4, Electromagnetic Fields, there are no offsite transmission lines 10 that are in scope for this SEIS. Therefore, there are no potential impacts to members of the 11 public. 12 As discussed in Section 3.11.5, Other Hazards, Turkey Point maintains an occupational safety 13 program for its workers in accordance with Occupational Safety & Health Administration 14 regulations, which includes protection from acute electric shock. Therefore, the NRC staff 15 concludes that the potential impacts from acute electric shock during the subsequent license 16 renewal term would be SMALL. 17 4.11.1.3 Environmental Consequences of Postulated Accidents 18 The GEIS (NUREG-1437) (NRC 2013a) evaluates the following two classes of postulated 19 accidents as they relate to license renewal: 20

• Design-Basis Accidents: Postulated accidents that a nuclear facility must be designed 21 and built to withstand without loss to the systems, structures, and components 22 necessary to ensure public health and safety.

23

• Severe Accidents: Postulated accidents that are more severe than design-basis 24 accidents because they could result in substantial damage to the reactor core, whether 25 or not there are serious off-site consequences.

26 As shown in Table 4-1, the GEIS (NRC 2013a) addresses design-basis accidents as a 27 Category 1 issue and concludes that the environmental impacts of design-basis accidents are of 28 SMALL significance for all nuclear power plants. 29 As shown in Table 4-2, the GEIS designates severe accidents as a Category 2 issue requiring 30 site-specific analysis. Based on information in the 2013 GEIS, the NRC determined in 31 10 CFR Part 51 that for all nuclear power plants, the probability-weighted consequences of 32 severe accidents associated with license renewal are SMALL, with a caveat: 33 The probability-weighted consequences of atmospheric releases, fallout onto 34 open bodies of water, releases to groundwater, and societal and economic 35 impacts from severe accidents are small for all plants. However, alternatives to 36 mitigate severe accidents must be considered for all plants that have not 37 considered such alternatives. (NRC 2013a) 38 As part of its initial license renewal application submitted in 2000, FPLs environmental report 39 included an assessment of severe accident mitigation alternatives (SAMAs) for Turkey Point 40 (FPL 2000). During its review of FPLs initial license renewal application, the NRC staff 41 performed a site-specific analysis of Turkey Point SAMAs and documented its findings in a 4-85

1 supplement to the GEIS (Supplement 5, Regarding Turkey Point Nuclear Plant, Units 3 & 4, to 2 NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 3 Plants) (NRC 2002c). Because the staff has previously considered SAMAs for Turkey Point 4 Units 3 and 4, FPL is not required to perform another SAMA analysis as part of its subsequent 5 license renewal application (10 CFR 51.53(c)(3)(ii)(L)). 6 However, the NRCs regulations in 10 CFR Part 51, which implement Section 102(2) of the 7 National Environmental Policy Act of 1969, as amended (NEPA), require that all applicants for 8 license renewal submit an environmental report to the NRC and in that report identify any new 9 and significant information regarding the environmental impacts of license renewal of which the 10 applicant is aware (10 CFR 51.53(c)(3)(iv)). This includes new and significant information that 11 could affect the environmental impacts related to postulated severe accidents or that could 12 affect the results of a previous SAMA assessment. Accordingly, in its subsequent license 13 renewal application environmental report, FPL evaluated areas of new and potentially significant 14 information that could affect the environmental impact of postulated severe accidents during the 15 subsequent license renewal period. The NRC staff provides a discussion of new information 16 pertaining to SAMAs in Appendix E, Environmental Impacts of Postulated Accidents, in this 17 SEIS. 18 Based on the NRC staffs review and evaluation of FPLs analysis of new and potentially 19 significant information regarding SAMAs and the staffs independent analyses as documented in 20 Appendix E, Environmental Impacts of Postulated Accidents, to this SEIS, the staff finds that 21 there is no new and significant information for Turkey Point related to SAMAs. 22 4.11.2 No-Action Alternative 23 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 24 Turkey Point would shut down on or before the expiration of the current renewed licenses. 25 Human health risks would be smaller following plant shutdown. The reactor units, which 26 currently operate within regulatory limits, would emit less radioactive gaseous, liquid, and solid 27 material to the environment. In addition, following shutdown, the variety of potential accidents at 28 the plant (radiological or industrial) would be reduced to a limited set associated with shutdown 29 events and fuel handling and storage. In Section 4.11.1, Proposed Action, the NRC staff 30 concluded that the impacts of continued plant operation on human health would be SMALL, 31 except for Chronic effects of electromagnetic fields (EMFs), for which the impacts are 32 UNCERTAIN. In Section 4.11.1.3, Environmental Consequences of Postulated Accidents, the 33 NRC staff concluded that the impacts of accidents during operation are SMALL. Therefore, as 34 radioactive emissions to the environment decrease, and as the likelihood and types of accidents 35 decrease following shutdown, the NRC staff concludes that the risk to human health following 36 plant shutdown would be SMALL. 37 4.11.3 Replacement Power Alternatives: Common Impacts 38 Impacts on human health from construction of a replacement power station would be similar to 39 impacts associated with the construction of any major industrial facility. Compliance with worker 40 protection rules, the use of personal protective equipment, training, and placement of 41 engineered barriers would limit those impacts on workers to acceptable levels. 42 The human health impacts from the operation of a power station include public risk from 43 inhalation of gaseous emissions. Regulatory agencies, including the U.S. Environmental 44 Protection Agency and Florida State agencies, base air emission standards and requirements 4-86

1 on human health impacts. These agencies also impose site-specific emission limits to protect 2 human health. 3 4.11.4 New Nuclear Alternative 4 The construction impacts of the new nuclear alternative would include those identified in 5 Section 4.11.3 above. Since the NRC staff expects that the licensee would limit access to 6 active construction areas to only authorized individuals, the impacts on human health from the 7 construction of the new nuclear alternative would be SMALL. 8 The human health effects from the operation of the new nuclear alternative would be similar to 9 those of operating the existing Turkey Point Units 3 and 4. As presented in Section 4.11.1, 10 impacts on human health from the operation of Turkey Point would be SMALL, except for 11 chronic effects of electromagnetic fields (EMFs), for which the impacts are UNCERTAIN. 12 Therefore, the NRC staff concludes that the impacts on human health from the operation of the 13 new nuclear alternative would be SMALL. 14 4.11.5 Natural Gas Combined-Cycle Alternative 15 The construction impacts of the natural gas alternative would include those identified in 16 Section 4.11.3, Replacement Power Alternatives: Common Impacts, as common to the 17 construction of all replacement power alternatives. Since the NRC staff expects that the builder 18 will limit access to the active construction area to only authorized individuals, the impacts on 19 human health from the construction of the natural gas alternative would be SMALL. 20 The human health effects from the operation of the natural gas alternative would include those 21 identified in Section 4.11.3 as common to the operation of all replacement power alternatives. 22 Health risk may be attributable to nitrogen oxide emissions that contribute to ozone formation 23 (NRC 2013a). Given the regulatory oversight exercised by the EPA and State agencies, the 24 NRC staff concludes that the human health impacts from the natural gas alternative would be 25 SMALL. 26 4.11.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 27 Generation) 28 Impacts on human health from construction of the combination natural gas and solar alternative 29 would include those identified in Section 4.11.3 as common to the construction of all 30 replacement power alternatives. Since the NRC staff expects that the builder will limit access to 31 the active construction area to only authorized individuals, the impacts on human health from 32 the construction of the combination natural gas and solar alternative would be SMALL. 33 Operational hazards at a natural gas facility are discussed in Section 4.11.5, Natural Gas 34 Combined-Cycle Alternative. 35 Solar photovoltaic panels are encased in heavy-duty glass or plastic. Due to this, there is little 36 risk that the small amounts of hazardous semiconductor material that they contain will be 37 released into the environment. In the event of a fire, hazardous particulate matter could be 38 released to the atmosphere. Given the short duration of fires and the high melting points of the 39 materials found in the solar photovoltaic panels, the impacts from inhalation are minimal. Also, 40 the risk of fire at ground-mounted solar installations is minimal due to precautions taken during 41 site preparation, such as the removal of fuels and the lack of burnable materials contained in the 4-87

1 solar photovoltaic panels. Another potential risk associated with photovoltaic systems and fire is 2 the potential for shock or electrocution from contact with a high voltage conductor. Proper 3 procedures and clear marking of system components should be used to provide emergency 4 responders with appropriate warnings to diminish the risk of shock or electrocution (OIPP 2010). 5 Photovoltaic solar panels do not produce electromagnetic fields at levels considered harmful to 6 human health as established by the International Commission on Non-Ionizing Radiation 7 Protection. These small electromagnetic fields diminish significantly with distance and are 8 indistinguishable from normal background levels within several yards (OIPP 2010). 9 Therefore, given the expected compliance with worker and environmental protection rules and 10 the use of personal protective equipment, training, and engineered barriers, the NRC staff 11 concludes that the potential human health impacts for the combination natural gas and solar 12 alternative would be SMALL. 13 4.11.7 Cooling Water System Alternative 14 The impacts of the cooling water system alternative would be similar to those identified in 15 Section 4.11.3, Replacement Power Alternatives: Common Impacts, as common to all 16 alternatives. Limiting access to the active construction area to only authorized individuals is 17 expected. 18 The human health effects from the operation of the cooling water system alternative would 19 include microbiological organisms and exposure to any biocides added to the system to limit the 20 growth of those microbiological organisms. The GEIS (NUREG-1437) evaluation of health 21 effects from plants with cooling systems discusses the potential hazard to workers from 22 microbiological organisms inhabiting the system whose presence might be enhanced by the 23 thermal conditions found in the cooling system. The microbiological organisms of concern are 24 freshwater organisms that are present at sites that use cooling ponds, lakes, or canals and that 25 discharge to small rivers (NRC 2013a). These concerns would not apply to the cooling water 26 system alternative at Turkey Point, which would be closed cycle, would use treated, reclaimed 27 wastewater, and would not be accessible by members of the public. Also, the cooling system 28 would contain cooling water treatment and conditioning chemical residuals (e.g., biocides, 29 corrosion inhibitors) necessary for proper operation, maintenance, and microorganism control of 30 the cooling towers and Turkey Point circulating water system. Incoming makeup water for the 31 cooling water system alternative will be treated reclaimed wastewater that will be stored in an 32 onsite reservoir. FPL has procedures onsite for the safe handling of any chemical usage for 33 operations, and any chemical use for the cooling water alternative is expected to be added to 34 these procedures. Also, the NRC staff assumes that any blowdown produced by the cooling 35 towers would be disposed of by deep well injection into the Boulder Zone, which would be 36 regulated under a Class I underground injection control permit issued by the Florida Department 37 of Environmental Protection (FAC 62-528). 38 In consideration of the information and assumptions presented above, the NRC staff concludes 39 that the impacts on human health from the construction and operation of the cooling water 40 system alternative would be SMALL. 41 4.12 Environmental Justice 42 In Section 3.12, Environmental Justice, of this SEIS, the NRC staff explains the basis for its 43 consideration of environmental justice impacts in an EIS and identifies environmental justice 4-88

1 populations (i.e., minority and low-income populations) within a 50-mi (80-km) radius of Turkey 2 Point. In this section, the staff describes the potential human health and environmental effects 3 of the proposed action (subsequent license renewal) and alternatives to the proposed action on 4 minority and low-income populations. 5 4.12.1 Proposed Action 6 The NRC addresses environmental justice matters for license renewal (including subsequent 7 license renewal) by (1) identifying the location of minority and low-income populations that may 8 be affected by the continued operation of the nuclear power plant during the subsequent license 9 renewal term, (2) determining whether there would be any potential human health or 10 environmental effects to these populations or to special pathway receptors (groups or 11 individuals with unique consumption practices and interactions with the environment), and 12 (3) determining whether any of the effects may be disproportionately high and adverse. 13 Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse 14 impacts on human health. Disproportionately high and adverse human health effects occur 15 when the risk or rate of exposure to an environmental hazard for a minority or low-income 16 population is significant and exceeds the risk or exposure rate for the general population or for 17 another appropriate comparison group. Disproportionately high environmental effects refer to 18 impacts or risks of impacts on the natural or physical environment in a minority or low-income 19 community that are significant and appreciably exceed the environmental impact on the larger 20 community. Such effects may include biological, cultural, economic, or social impacts. 21 Figure 3-23 and Figure 3-24 show the location of predominantly minority and low-income 22 population block groups residing within a 50-mi (80-km) radius of Turkey Point. This area of 23 impact is consistent with the 50-mi (80-km) impact analysis for public and occupational health 24 and safety. This chapter (Chapter 4) of the SEIS presents the assessment of environmental 25 and human health impacts for each resource area. The analyses of impacts for environmental 26 resource areas indicated that groundwater use conflicts would be SMALL to MODERATE 27 because FPLs continued operation of its Upper Floridan aquifer production wells is likely to 28 affect offsite well systems by increasing drawdown in the aquifer. However, as discussed in 29 Section 4.5.1.2.2 of this SEIS, while projected drawdowns would noticeably affect the Upper 30 Floridan aquifer, FPLs continued withdrawals would not be likely to destabilize the groundwater 31 resource or impair the use by other users and well systems during the subsequent license 32 renewal period. Therefore, these impacts would not be high and adverse. Additionally, the 33 staffs analysis identified SMALL to MODERATE impacts for impingement and entrainment of 34 aquatic organisms and thermal impacts on aquatic organisms in the CCS. As discussed in 35 Section 4.7.1.1, the impacts are unlikely to create effects great enough to destabilize important 36 attributes of the aquatic environment over the course of the subsequent license renewal term 37 because the CCS aquatic community is composed of common species that exhibit no unique 38 ecological value or niche and have no commercial or recreational value. The SMALL to 39 MODERATE finding applies to only those aquatic resources occurring in the CCS, to which the 40 public has no access. Impingement and entrainment and thermal effects do not apply to aquatic 41 organisms inhabiting Biscayne Bay or other natural waterbodies because there are no surface 42 water connections that allow flow between these waters and the CCS. Therefore, the impacts 43 on aquatic resources would not be disproportionately high and adverse. 44 Potential impacts on minority and low-income populations (including migrant workers or Native 45 Americans) would mostly consist of socioeconomic and radiological effects; however, radiation 46 doses from continued operations during the subsequent license renewal term are expected to 47 continue at current levels and would remain within regulatory limits. Section 4.11.1.3, 4-89

1 Environmental Consequences of Postulated Accidents, discusses the environmental impacts 2 from severe accidents that might occur during the subsequent license renewal term. The 3 Commission has determined that the probability-weighted consequences of severe accidents 4 are SMALL. Therefore, these impacts would not be high and adverse. 5 Subsistence Consumption of Fish and Wildlife 6 As part of addressing environmental justice concerns associated with subsequent license 7 renewal, the NRC staff assessed the potential radiological risk to special population groups 8 (such as migrant workers or Native Americans) from exposure to radioactive material received 9 through their unique consumption practices and interactions with the environment, including the 10 subsistence consumption of fish, wildlife, and native vegetation; contact with surface waters, 11 sediments, and local produce; absorption of contaminants in sediments through the skin; and 12 inhalation of airborne radioactive material released from the plant during routine operation. The 13 special pathway receptors analysis is an important part of the environmental justice analysis 14 because consumption patterns may reflect the traditional or cultural practices of minority and 15 low-income populations in the area. The results of this analysis are presented here. 16 Section 4-4 of Executive Order 12898, Federal Actions to Address Environmental Justice in 17 Minority Populations and Low-Income Populations (59 FR 7629), directs Federal agencies, 18 whenever practical and appropriate, to collect and analyze information about the consumption 19 patterns of populations that rely principally on fish and wildlife for subsistence and to 20 communicate the risks of these consumption patterns to the public. As part of the 21 environmental review pertaining to the proposed new Turkey Point Units 6 and 7, the NRC staff 22 concluded that subsistence activities are typically not conducted by minority or low-income 23 populations in the vicinity of Turkey Point (NRC 2016a). In this SEIS, the NRC staff considered 24 whether there were any means for minority or low-income populations to be disproportionately 25 affected by examining impacts on American Indians, Hispanics, migrant workers, and other 26 traditional lifestyle special pathway receptors. The assessment of special pathways considered 27 the levels of radiological and non-radiological contaminants in fish, sediments, water, milk, and 28 food products on or near Turkey Point. 29 Radionuclides released to the atmosphere may deposit on soil and vegetation and may 30 therefore eventually be incorporated into the human food chain. To assess the impact of Turkey 31 Point operations to humans from the ingestion pathway, FPL collects and analyzes samples of 32 air, water, sediment, fish, vegetation, and milk, if available, for radioactivity as part of its 33 ongoing, comprehensive Radiological Environmental Monitoring Program. 34 To assess the impact of nuclear power plant operations on the environment, FPL collects 35 samples annually from the environment and analyzes the samples for radioactivity. Two types 36 of samples are collected. The first type, a control sample, is collected from areas that are 37 beyond the influence of the nuclear power plant or any other nuclear facility. These control 38 samples are used as reference data to determine normal background levels of radiation in the 39 environment. The second type of samples, indicator samples, are collected near the nuclear 40 power plant from areas where any radioactivity contribution from the nuclear power plant will be 41 at its highest concentration. These indicator samples are then compared to the control samples 42 to evaluate the contribution of nuclear power plant operations to radiation or radioactivity levels 43 in the environment. An effect would be indicated if the radioactivity levels detected in an 44 indicator sample were higher than the control sample or background levels. 4-90

1 FPL collected air samples and samples from the aquatic, and terrestrial environment near 2 Turkey Point in 2017. The aquatic pathways sampled include surface water, shoreline 3 sediment, and fish. 4 Aquatic monitoring results for 2017 were consistent with previous levels and, except for tritium 5 in surface and groundwater, yielded no indication of nuclides attributable to Turkey Point 6 operation. Tritium was reported in surface and groundwater samples. Tritium concentrations in 7 water samples were below reporting limits as specified by Turkey Points Offsite Dose 8 Calculation Manual (30,000 pCi/L) and EPAs public drinking water standard (20,000 pCi/L) 9 (FPL 2013a, FPL 2018j, 40 CFR 141.16). Tritium occurs in underlying groundwater beneath the 10 CCS as well as in adjacent areas beneath the Turkey Point plant complex. Because the canals 11 comprising the CCS are not lined, CCS water containing tritium migrates into the groundwater of 12 the underlying Biscayne aquifer. Sections 3.5.2.2 and 4.5.1.2 of this SEIS discuss groundwater 13 tritium levels in the vicinity of the Turkey Point site and Turkey Points Groundwater Protection 14 Program in greater detail. As stated in Section 4.5.1.2, at no location outside the boundary of 15 the Turkey Point site do tritium levels in groundwater approach the EPA and State primary 16 drinking water standard for tritium (20,000 pCi/L), while the highest tritium levels in offsite 17 monitoring wells near the site were at 15 percent of the standard. 18 Terrestrial monitoring results for 2017 of broad leaf vegetation were consistent with previous 19 levels. Cesium-137 was detected in samples collected and it was below reporting limits as 20 specified by Turkey Points Offsite Dose Calculation Manual. Cesium-137 could be associated 21 with fallout from past atmospheric nuclear weapons and reactor accidents (FPL 2018j). Milk 22 samples were not available for testing. 23 Based on the radiological environmental monitoring data from Turkey Point, special pathway 24 receptor populations in the region are not expected to experience disproportionately high and 25 adverse human health impacts as a result of subsistence consumption of water, local food, fish, 26 and wildlife. 27 4.12.2 No-Action Alternative 28 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 29 Turkey Point would shut down on or before the expiration of the current renewed licenses. 30 Impacts on minority and low-income populations would include loss of jobs, reduction in tax 31 revenue, and potentially a reduction in public services. A decrease in the availability of services 32 could disproportionately affect minority and low-income populations that may have become 33 dependent on these services. However, as discussed in Section 4.10.2, No-Action Alternative, 34 of this SEIS, because of the large population, labor force, and tax revenue of Miami-Dade 35 County, the socioeconomic impacts from not issuing the subsequent renewed licenses and 36 terminating reactor operations at Turkey Point would be SMALL. Therefore, under the no-action 37 alternative, the effects to minority and low-income populations would not be disproportionately 38 high and adverse. 39 4.12.3 Replacement Power Alternatives: Common Impacts 40 Construction 41 Potential impacts to minority and low-income populations from the construction of a new 42 replacement power plant would mostly consist of environmental and socioeconomic effects 43 (e.g., noise, air emissions, traffic, employment, and housing impacts). Figure 3-23 and Figure 4-91

1 3-24 show the location of predominantly minority and low-income population block groups 2 residing within a 50-mi (80-km) radius of Turkey Point. Minority and low-income populations 3 residing along site access roads could be affected by increased truck traffic and increased 4 commuter vehicle traffic, especially during shift changes. However, a 2017 land-use survey 5 within a 5-mi radius of Turkey Point identified few residents in the vicinity of the Turkey Point 6 site; the nearest resident was approximately 2 mi (3.2 km) away from the site and the nearest 7 residential communities are in Homestead, approximately 6.0 mi (9.7 km) west of the site 8 (FPL 2018j). During the environmental site audit, the NRC staff confirmed that there are few 9 residents along site access roads in the immediate vicinity of the Turkey Point site, in particular 10 Palm Drive. Therefore, increased traffic along site access roads is not likely to affect minority 11 and low-income populations. 12 Noise would result from construction equipment, site activities, and additional traffic. Migrant 13 agricultural workers (see Section 3.10.3.2, Migrant Farm Workers, of this SEIS) could be 14 particularly vulnerable to noise impacts because of their outdoor presence. However, the 15 nearest farm is approximately 4.5 mi (7.2 km) away from Turkey Point (FPL 2018j); and the 16 NRC staff has determined that noise would be temporary and not significant, and that noise 17 levels would be lessened by distance. Air emissions would result from increased vehicle traffic, 18 construction equipment, and fugitive dust from construction activities. These emissions would 19 be temporary and minor (see Section 4.3.3, Replacement Power Alternatives: Common 20 Impacts, of this SEIS). Increased demand for rental housing during construction could 21 disproportionately affect low-income populations. However, there is a large housing stock 22 available in Miami-Dade County (see Table 3-20 and Table 3-22). 23 Operation 24 Low-income populations living near the power plant that rely on subsistence consumption of fish 25 and wildlife could be disproportionately affected by replacement power alternatives. Emissions 26 during power plant operations could disproportionately affect nearby minority and low-income 27 populations, depending on the type of replacement power. Noise, primarily associated with 28 cooling towers and vehicle traffic, would be intermittent and not noticeable. 29 4.12.3.1 New Nuclear Alternative 30 Potential impacts to minority and low-income populations from the construction and operation of 31 the new nuclear alternative on the Turkey Point site would be similar to the impacts discussed 32 above in Section 4.12.3 as common to all replacement power alternatives. While transportation 33 impacts on access roads in the immediate vicinity of Turkey Point during construction of a new 34 nuclear alternative would be LARGE, there are few residents along site access roads in the 35 immediate vicinity of the Turkey Point site and the nearest residential community is in 36 Homestead, approximately 6.0 mi (9.7 km) from the site. Potential impacts from operation 37 would mostly consist of radionuclide releases and effects during operations; however, radiation 38 doses would be required to meet regulatory limits, similar to the current operation of Turkey 39 Point. 40 Based on (1) the location of the new nuclear alternative, (2) the assumed plant design and 41 characteristics, and (3) the human health and environmental effects findings, construction and 42 operation of the new nuclear alternative would not likely have disproportionately high and 43 adverse human health and environmental effects on minority and low-income populations. 4-92

1 4.12.3.2 Natural Gas Combined-Cycle Alternative 2 Potential impacts to minority and low-income populations from the construction and operation of 3 the natural gas alternative on the Turkey Point site would be similar to the impacts discussed 4 above in Section 4.12.3 as common to all replacement power alternatives. While transportation 5 impacts on access roads in the immediate vicinity of Turkey Point during construction of a 6 natural gas alternative would be MODERATE, there are few residents along site access roads 7 in the vicinity of the Turkey Point site and the nearest residential community is in Homestead, 8 approximately 6.0 mi (9.7 km) from the site. As noted in Section 3.12, Environmental Justice, 9 of this SEIS and in Figure 3-23 and Figure 3-24, the Turkey Point site is in a minority and low-10 income population block group where the minority population exceeds 78 percent. As 11 discussed in Section 4.3.5, Natural Gas Combined-Cycle, of this SEIS, nitrogen oxide and 12 greenhouse gas emissions from a natural gas combined-cycle plant would be significant. 13 Therefore, there would be a high concentration of minorities in close proximity to the source of 14 air emissions. However, as discussed in Section 4.3.5, Natural Gas Combined-Cycle, of this 15 SEIS, emissions would be noticeable but not destabilizing. Therefore, these effects are not 16 likely to be high and adverse and emissions from the natural gas alternative during power plant 17 operation are not likely to disproportionately affect minority populations living in the vicinity of 18 the new power plant. 19 Based on (1) the location of the natural gas alternative, (2) the assumed plant design and 20 characteristics, and (3) the human health and environmental effects findings, construction and 21 operation of the natural gas alternative would not likely have disproportionately high and 22 adverse human health and environmental effects on minority and low-income populations. 23 4.12.3.3 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic) 24 Potential impacts to minority and low-income populations from the construction and operation of 25 the natural gas portion of the combination alternative on the Turkey Point site would be the 26 same as those discussed for the natural gas alternative (see Section 4.12.3.2 of this SEIS). 27 Therefore, the construction and operation of the natural gas portion would not likely have 28 disproportionately high and adverse human health and environmental effects on minority and 29 low-income populations. 30 Potential impacts to minority and low-income populations from the construction and operation of 31 solar facilities would mostly consist of environmental and socioeconomic effects (e.g., noise, air 32 emissions, traffic, employment, and housing impacts). Figure 3-23 and Figure 3-24 show the 33 location of predominantly minority and low-income population block groups residing within a 34 50-mi (80-km) radius of Turkey Point. Three of the solar facilities would be built in Miami-Dade 35 and/or Broward County. According to the 2010 U.S. Census, minorities comprised 56.5 percent 36 of the total Broward County population (USCB 2010c). The 2012-2016 American Survey 37 Community 5-Year Estimates shows that 14.4 percent of individuals in Broward County live 38 below the poverty threshold (USCB 2018). As noted in Chapter 3, minorities comprised 39 approximately 86 percent of the total Miami-Dade County population and 18.3 percent of 40 individuals in Miami-Dade County live below the poverty threshold. 41 Noise and air emissions impacts from construction would be short term and primarily limited to 42 onsite activities. Increased demand for rental housing during construction and operations could 43 affect low-income populations. However, given the number of construction workers and housing 44 availability in Miami-Dade and Broward Counties, the potential need for rental housing would 45 not be significant. During operations, there would not be a noticeable housing demand given 4-93

1 the small number of workers needed to maintain and operate the solar facilities. Minority and 2 low-income populations residing along site access roads would be affected by increased 3 commuter vehicle traffic during shift changes and truck traffic. Transportation impacts would be 4 SMALL to MODERATE and would depend on the location of the solar facilities in Broward 5 County. However, these effects would be temporary during certain hours of the day. 6 Based on this information and the analysis of human health and environmental impacts 7 presented in this SEIS, it is not likely that the construction and operation of the solar facilities 8 would have disproportionately high and adverse human health and environmental effects on 9 minority and low-income populations. However, this determination would depend on the 10 location of the facilities in Miami-Dade County and/or Broward County. Therefore, the NRC staff 11 cannot determine whether the solar portion of the combination alternative would result in 12 disproportionately high and adverse human health and environmental effects on minority and 13 low-income populations. 14 4.12.4 Cooling Water System Alternative 15 Potential impacts to minority and low-income populations from the construction and operation of 16 the cooling water system alternative would mostly consist of environmental and socioeconomic 17 effects (e.g., noise, air emissions, traffic, employment, and housing impacts). Figure 3-23 and 18 Figure 3-24 show the location of predominantly minority and low-income population block 19 groups residing within a 50-mi (80-km) radius of Turkey Point. As discussed in Section 4.10.7, 20 Cooling Water System Alternative, of this SEIS, transportation impacts during construction 21 would be SMALL to MODERATE on roads in the immediate vicinity of Turkey Point. Minority 22 and low-income populations residing along site access roads could be affected by increased 23 truck traffic and increased commuter vehicle traffic, especially during shift changes. However, 24 the transportation impacts would be on access roads in the immediate vicinity of Turkey Point. 25 A 2017 land-use survey within a 5-mi (8.0 km) radius of Turkey Point identified few residents in 26 the vicinity of the Turkey Point site; the nearest resident was approximately 2 mi (3.2 km) away 27 from the site and the nearest residential communities are in Homestead, approximately 6.0 mi 28 (9.7 km) west of the site (FPL 2018j). During the environmental site audit, the NRC staff 29 confirmed that there are few residents along site access roads in the immediate vicinity of the 30 Turkey Point site, in particular Palm Drive. 31 Noise would result from construction equipment, site activities, and additional traffic. Migrant 32 agricultural workers (see Section 3.10.3.2, Migrant Farm Workers, of this SEIS) could be 33 particularly vulnerable to noise impacts because of their outdoor presence. However, the 34 nearest farm is approximately 4.5 mi (7.2 km) away from Turkey Point (FPL 2018j); and the 35 NRC staff has determined that noise would be temporary, not significant, and that noise levels 36 would be lessened by distance. Air emissions would result from increased vehicle traffic, 37 construction equipment, and fugitive dust from construction activities. However, these 38 emissions would be temporary and minor (see Section 4.3.4, New Nuclear Alternative, of this 39 SEIS). 40 Replacement power will be required during the construction outage as well as a result of 41 efficiency losses or additional power needed to operate cooling tower pumps and fans once the 42 cooling system is online. Replacement power could increase air quality impacts and human 43 health effects in minority and low-income communities, depending on the location and 44 characteristics of replacement power used to replace Turkey Point power. The effects would be 45 short lived during the construction-related outages and would occur near the existing power 46 plants and would result from incremental increases rather than new effects. As discussed in 4-94

1 Section 4.12.4 of this SEIS, during operations, the cooling towers would emit particulate matter, 2 however, these emissions would be minor. 3 Based on the analysis of human health and environmental impacts presented in this SEIS, the 4 location of the alternative, and the assumed alternative design and characteristics, this 5 alternative would not likely have disproportionately high and adverse human health and 6 environmental effects on minority and low-income populations. 7 4.13 Waste Management 8 This section describes the potential waste management impacts of the proposed action 9 (subsequent license renewal) and alternatives to the proposed action. 10 4.13.1 Proposed Action 11 According to the GEIS (NRC 1996, NRC 2013a), the generic issues related to waste 12 management as identified in Table 4-1 would not be affected by continued operations 13 associated with license renewal. As discussed in Chapter 3, the NRC staff identified no new 14 and significant information for these issues. Thus, as concluded in the GEIS, the impacts of the 15 generic issues related to waste management would be SMALL. 16 Table 4-2 does not identify any Turkey Point site-specific (Category 2) waste management 17 issues resulting from issuing a subsequent renewed license for an additional 20 years of 18 operations. 19 4.13.2 No-Action Alternative 20 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 21 Turkey Point would shut down on or before the expiration of the current renewed licenses and 22 enter decommissioning. After entering decommissioning, the plant would generate less spent 23 nuclear fuel, emit less gaseous and liquid radioactive effluents into the environment, and 24 generate less low-level radioactive and nonradioactive wastes. In addition, following shutdown, 25 the variety of potential accidents at the plant (radiological and industrial) would be reduced to a 26 limited set associated with shutdown events and fuel handling and storage. Therefore, as 27 radioactive emissions to the environment decrease, and the likelihood and variety of accidents 28 decrease following shutdown and decommissioning, the NRC staff concludes that the impacts 29 resulting from waste management from the implementation of the no-action alternative would be 30 SMALL. 31 4.13.3 Replacement Power Alternatives: Common Impacts 32 Impacts from waste management common to all analyzed replacement power alternatives 33 would be from construction-related debris generated during construction activities, and this 34 waste would be recycled or disposed of in approved landfills. 35 4.13.4 New Nuclear Alternative 36 Impacts from the waste generated during the construction of a new nuclear unit would include 37 those identified in Section 4.13.3, as common to all replacement power alternatives. 4-95

1 During normal plant operations, routine plant maintenance and cleaning activities would 2 generate radioactive low-level waste, spent nuclear fuel, high-level waste, and nonradioactive 3 waste. Sections 3.1.4 and 3.1.5 of this SEIS discuss radioactive and nonradioactive waste 4 management at Turkey Point. Quantities of radioactive and nonradioactive waste generated by 5 Turkey Point would be comparable to that generated by the new nuclear plant. As stated in the 6 GEIS (NUREG-1437) (NRC 2013a), the NRC does not expect the generation and management 7 of solid radioactive and nonradioactive waste during the subsequent license renewal term to 8 result in significant environmental impacts. Based on this information, the waste impacts would 9 be SMALL for the new nuclear alternative. 10 4.13.5 Natural Gas Combined-Cycle Alternative 11 Impacts from the waste generated during the construction of a natural gas power plant would 12 include those identified in Section 4.13.3 of this SEIS as common to all replacement power 13 alternatives. 14 Waste generation from natural gas technology would be minimal. The only significant waste 15 generated at a natural gas combined-cycle power plant would be spent selective catalytic 16 reduction catalyst (plants use selective catalytic reduction catalyst to control nitrogen oxide 17 emissions). 18 The spent catalyst would be regenerated or disposed of offsite. Other than the spent selective 19 catalytic reduction catalyst, waste generation at an operating natural gas fired plant would be 20 limited largely to typical operations and maintenance nonhazardous waste (NRC 2013a). 21 Overall, the NRC staff concludes that waste impacts from the natural gas alternative would be 22 SMALL. 23 4.13.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 24 Generation) 25 Impacts from the waste generated during the construction of the natural gas combined-cycle 26 (NGCC) plant and solar photovoltaic (PV) alternative would include those identified in 27 Section 4.13.3 of this SEIS as common to the construction of all replacement power 28 alternatives. The combination alternative consists of a natural gas plant and solar PV facilities 29 that provide generation equivalent to Turkey Points 1,632 MWe with an annual generation of 30 approximately 13,154,016 MWhs. The natural gas plant would be located at the Turkey Point 31 site. Four solar PV facilities would be constructed. One solar PV facility would be located on 32 FPL-owned land on or near the Turkey Point site, and the other three solar facilities would be 33 located in Miami-Dade or Broward County. 34 During the construction of the natural gas plant and solar PV facilities, land clearing and other 35 construction activities would generate waste that could be recycled, disposed of onsite, or 36 shipped to an offsite waste disposal facility. 37 Waste generation from natural gas technology would be minimal. The only significant waste 38 generated at a natural gas combined-cycle power plant would be spent selective catalytic 39 reduction catalyst (plants use selective catalytic reduction catalyst to control nitrogen oxide 40 emissions). 41 The spent catalyst would be regenerated or disposed of offsite. Other than the spent selective 42 catalytic reduction catalyst, waste generation at an operating natural gas fired plant would be 4-96

1 limited largely to typical operations and maintenance nonhazardous waste (NRC 2013a). 2 Overall, the NRC staff concludes that waste impacts from the natural gas portion of the 3 combination alternative would be SMALL. 4 Impacts on waste management from the construction and operation of the natural gas plant and 5 pipeline component of the combination alternative would be similar to those associated with the 6 natural gas alternative. 7 The construction of the solar PV facilities would create sanitary and industrial waste, although it 8 would be of smaller quantity as compared to the natural gas plant. This waste could be 9 recycled, disposed of onsite, or shipped to an offsite waste disposal facility. All of the waste 10 would be handled in accordance with appropriate Florida Department of Environmental 11 Protection regulations. Impacts on waste management resulting from the construction and 12 operation of the solar PV facilities of the combination alternative would be minimal, and of a 13 smaller quantity as compared to the natural gas plant. In sum, the waste management impacts 14 resulting from the construction and operation of the PV facilities would be SMALL. 15 Overall, the NRC staff concludes that waste impacts for the natural gas and solar PV 16 combination alternative would be SMALL. 17 4.13.7 Cooling Water System Alternative 18 Waste management impacts from the waste generated during the construction of the cooling 19 water system alternative would include those identified in Section 4.13.3 as common to all 20 replacement power alternatives. 21 During operation, some minor amounts of chemical wastes may result from efforts to maintain 22 appropriate chemical quality of the recirculating cooling water, from the periodic maintenance 23 (i.e., descaling) of the cooling towers, and from periodic removal of settled precipitates from the 24 cooling water basins beneath each cooling tower. Operational solid wastes are expected to be 25 temporarily stored on site or ultimately treated, recycled, or disposed in appropriately permitted 26 offsite facilities. FPL would be expected to implement appropriate waste management practices 27 to minimize volume and content of waste generated from the construction and operation of the 28 cooling towers. Any cooling water treatment and conditioning chemical residuals (e.g., biocides, 29 corrosion inhibitors) necessary for proper operation, maintenance, and microorganism control of 30 the cooling towers and Turkey Point circulating water system would be disposed of and 31 managed in accordance with FDEP requirements. 32 In consideration of the information and assumptions presented above, the NRC staff concludes 33 that the impacts from waste management from the construction and operation of the cooling 34 water system alternative would be SMALL. 35 4.14 Evaluation of New and Significant Information 36 As stated in Section 4.1, Introduction, of this SEIS, for Category 1 (generic) issues, the NRC 37 staff can rely on the analysis in the GEIS (NUREG-1437) (NRC 2013a) unless otherwise noted. 38 Table 4-1 lists the Category 1 issues that apply to Turkey Point during the proposed subsequent 39 license renewal period. The NRC staff identified and evaluated new and potentially significant 40 information for two existing Category 1 issues (i.e., groundwater quality degradation (plants with 41 cooling ponds in salt marshes) and cooling system impacts on terrestrial resources (plants with 42 once-through cooling systems or cooling ponds)) and identified one new uncategorized issue 4-97

1 (i.e., water quality impacts on adjacent water bodies (plants with cooling ponds in salt 2 marshes)). The NRC staff determined that the information was both new and significant for one 3 of the issues, Groundwater quality degradation (plants with cooling ponds in salt marshes), as 4 listed in Table 4-1 and as evaluated in Section 4.5.1.2, Groundwater Resources, of this SEIS. 5 For all other issues, the NRC staff did not identify any new and significant information during its 6 review of FPLs environmental report, the site audits, or the scoping period that would change 7 the conclusions presented in the GEIS. 8 New and significant information must be new based on a review of the GEIS (NRC 2013a) as 9 codified in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51. Such information must 10 also bear on the proposed action or its impacts, presenting a seriously different picture of the 11 impacts from those envisioned in the GEIS (i.e., impacts of greater severity than the impacts 12 considered in the GEIS, considering their intensity and context). 13 The NRC defines new and significant information in Regulatory Guide (RG) 4.2, Supplement 1, 14 Preparation of Environmental Reports for Nuclear Power Plant License Renewal Applications 15 (NRC 2013b), as (1) information that identifies a significant environmental impact issue that was 16 not considered or addressed in the GEIS and, consequently, not codified in Table B-1, in 17 Appendix B to Subpart A of 10 CFR Part 51, or (2) information not considered in the 18 assessment of impacts evaluated in the GEIS leading to a seriously different picture of the 19 environmental consequences of the action than previously considered, such as an 20 environmental impact finding different from that codified in Table B-1. Further, a significant 21 environmental issue includes, but is not limited to, any new activity or aspect associated with the 22 nuclear power plant that can act upon the environment in a manner or an intensity and/or scope 23 (context) not previously recognized. 24 In accordance with 10 CFR 51.53(c), Operating license renewal stage, the applicants 25 environmental report must analyze the Category 2 (site-specific) issues in Table B-1 of 26 Appendix B to Subpart A of 10 CFR Part 51. Additionally, the applicants environmental report 27 must discuss actions to mitigate any adverse impacts associated with the proposed action and 28 environmental impacts of alternatives to the proposed action. In accordance with 29 10 CFR 51.53(c), the applicants environmental report does not need to analyze any Category 1 30 issue unless there is new and significant information on a specific issue. 31 NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews 32 for Nuclear Power Plants for Operating License Renewal describes the NRC process for 33 identifying new and significant information (NRC 2013b). The search for new information 34 includes: 35

• review of an applicants environmental report (FPL 2018f, FPL 2018n) and the process 36 for discovering and evaluating the significance of new information 37
• review of public comments 38
• review of environmental quality standards and regulations 39
• coordination with Federal, State, and local environmental protection and resource 40 agencies 41
• review of technical literature as documented through this SEIS 42 New information is evaluated for significance using the criteria set forth in the GEIS. For 43 Category 1 issues for which new and significant information is identified, reconsideration of the 4-98

1 conclusions for those issues is limited in scope to an assessment of the relevant new and 2 significant information; the scope of the assessment does not include other facets of an issue 3 that the new information does not affect. 4 The NRC staff reviewed the discussion of environmental impacts associated with operation 5 during the subsequent license renewal term in the GElS and has conducted its own 6 independent review, including a public involvement process (e.g., public meetings and 7 comments) to identify new and significant issues for the Turkey Point subsequent license 8 renewal application environmental review. 9 4.15 Impacts Common to All Alternatives 10 This section describes the impacts that the NRC staff considers common to all alternatives 11 discussed in this SEIS, including the proposed action and replacement power alternatives. The 12 continued operation of a nuclear power plant and replacement fossil fuel power plants both 13 involve mining, processing, and the consumption of fuel that result in comparative impacts 14 (NRC 2013a). In addition, the following sections discuss the termination of operations and the 15 decommissioning of both a nuclear power plant and replacement fossil fuel power plants and 16 greenhouse gas emissions. 17 4.15.1 Fuel Cycle 18 This section describes the environmental impacts associated with the fuel cycles of both the 19 proposed action and all replacement power alternatives. Most replacement power alternatives 20 employ a set of steps in the use of their fuel sources, which can include extraction, 21 transformation, transportation, and combustion. Emissions generally occur at each stage of the 22 fuel cycle (NRC 2013a). 23 4.15.1.1 Uranium Fuel Cycle 24 The uranium fuel cycle includes uranium mining and milling, the production of uranium 25 hexafluoride, isotopic enrichment, fuel fabrication, reprocessing of irradiated fuel, transportation 26 of radioactive materials, and management of low-level wastes and high-level wastes related to 27 uranium fuel cycle activities. The GEIS (NUREG-1437) describes in detail the generic potential 28 impacts of the radiological and non-radiological environmental impacts of the uranium fuel cycle 29 and transportation of nuclear fuel and wastes (NRC 1996, NRC 1999, NRC 2013a). The GEIS 30 does not identify any site-specific (Category 2) uranium fuel cycle issues. 31 As stated in the GEIS (NRC 1996, NRC 2013a), the generic issues related to the uranium fuel 32 cycle as identified in Table 4-1 would not be affected by continued operations associated with 33 license renewal. As discussed in Chapter 3, the NRC staff identified no new and significant 34 information for these issues. Thus, as concluded in the GEIS, the impacts of generic issues 35 related to the uranium fuel cycle would be SMALL. 36 4.15.1.2 Replacement Power Plant Fuel Cycles 37 Fossil Fuel Energy Alternatives 38 Fuel cycle impacts for a fossil fuel-fired plant result from the initial extraction of fuel, cleaning 39 and processing of fuel, transport of fuel to the facility, and management and ultimate disposal of 40 solid wastes from fuel combustion. These impacts are discussed in more detail in 4-99

1 Section 4.12.1.2 of the GEIS (NUREG-1437) (NRC 2013a) and can generally include the 2 following: 3

• significant changes to land use and visual resources 4
• impacts to air quality, including release of criteria pollutants, fugitive dust, volatile organic 5 compounds, and coalbed methane into the atmosphere 6
• noise impacts 7
• geology and soil impacts due to land disturbances and mining 8
• water resource impacts, including degradation of surface water and groundwater quality 9
• ecological impacts, including loss of habitat and wildlife disturbances 10
• historic and cultural resources impacts within the mine or pipeline footprint 11
• socioeconomic impacts from employment of both the mining workforce and service and 12 support industries 13
• environmental justice impacts 14
• health impacts to workers from exposure to airborne dust and methane gases 15
• generation of industrial wastes 16 New Nuclear Energy Alternatives 17 Uranium fuel cycle impacts for a nuclear plant result from the initial extraction of fuel, transport 18 of fuel to the facility, and management and ultimate disposal of spent fuel. The environmental 19 impacts of the uranium fuel cycle are discussed in Section 4.15.1.1 of this SEIS.

20 Renewable Energy Alternatives 21 The fuel cycle for renewable energy facilities is difficult to define for different technologies 22 because these natural resources exist regardless of any effort to harvest them for electricity 23 production. Impacts from the presence or absence of these renewable energy technologies are 24 often difficult to determine (NRC 2013a). 25 4.15.2 Terminating Power Plant Operations and Decommissioning 26 This section describes the environmental impacts associated with the termination of operations 27 and the decommissioning of a nuclear power plant and replacement power alternatives. All 28 operating power plants will terminate operations and be decommissioned at some point after the 29 end of their operating life or after a decision is made to cease operations. For the proposed 30 action at Turkey Point, subsequent license renewal would delay this eventuality for an additional 31 20 years beyond the current license period, which ends in 2032 (Unit 3) and 2033 (Unit 4). 32 4.15.2.1 Existing Nuclear Power Plant 33 Decommissioning would occur whether Turkey Point is shut down at the end of its current 34 renewed license or at the end of the subsequent license renewal term. NUREG-0586, 35 Supplement 1, Final Generic Environmental Impact Statement on Decommissioning of Nuclear 36 Facilities: Regarding the Decommissioning of Nuclear Power Reactors (the Decommissioning 37 GEIS), evaluates the environmental impacts from the activities associated with the 4-100

1 decommissioning of any reactor before or at the end of an initial or renewed license 2 (NRC 2002). Additionally, the License Renewal GEIS (NUREG-1437) (NRC 2013a) discusses 3 the incremental environmental impacts associated with decommissioning activities resulting 4 from continued plant operation during the renewal term. As noted in Table 4-1, there is one 5 Category 1 issue applicable to Turkey Point decommissioning following the subsequent license 6 renewal term. The License Renewal GEIS did not identify any site-specific (Category 2) 7 decommissioning issues. 8 4.15.2.2 Replacement Power Plants 9 Fossil Fuel Energy Alternatives 10 The environmental impacts from the termination of power plant operations and 11 decommissioning of a fossil fuel-fired plant are dependent on the facilitys decommissioning 12 plan. General elements and requirements for a fossil fuel plant decommissioning plan are 13 discussed in Section 4.12.2.2 of the License Renewal GEIS (NUREG-1437) and can include the 14 removal of structures to at least 3 feet (1 m) below grade; removal of all coal, combustion waste, 15 and accumulated sludge; removal of intake and discharge structures; and the cleanup and 16 remediation of incidental spills and leaks at the facility. The decommissioning plan outlines the 17 actions necessary to restore the site to a condition equivalent in character and value to the site 18 on which the facility was first constructed (NRC 2013a). 19 The environmental consequences of decommissioning are discussed in Section 4.12.2.2 of the 20 License Renewal GEIS (NUREG-1437) and can generally include the following: 21

• short-term impacts on air quality and noise from the deconstruction of facility structures 22
• short-term impacts on land use and visual resources 23
• long-term reestablishment of vegetation and wildlife communities 24
• socioeconomic impacts due to decommissioning the workforce and the long-term loss of 25 jobs 26
• elimination of health and safety impacts on operating personnel and the general public 27 New Nuclear Alternatives 28 Termination of operations and decommissioning impacts for a nuclear plant include all activities 29 related to the safe removal of the facility from service and the reduction of residual radioactivity 30 to a level that permits release of the property under restricted conditions or unrestricted use and 31 termination of a license (NRC 2013a). The environmental impacts of the uranium fuel cycle are 32 discussed in Section 4.15.1.1, Uranium Fuel Cycle.

33 Renewable Alternatives 34 Termination of power plant operation and decommissioning for renewable energy facilities 35 would be similar to the impacts discussed for fossil fuel-fired plants. Decommissioning would 36 involve the removal of facility components and operational wastes and residues to restore the 37 site to a condition equivalent in character and value to the site on which the facility was first 38 constructed (NRC 2013a). 4-101

1 4.15.3 Greenhouse Gas Emissions and Climate Change 2 The following sections discuss greenhouse gas emissions and climate change impacts. 3 Section 4.15.3.1 evaluates greenhouse gas emissions associated with operation of Turkey Point 4 Units 3 and 4 and replacement power alternatives. Section 4.15.3.2 discusses the observed 5 changes in climate and the potential future climate change during the subsequent license 6 renewal term based on climate model simulations under future global greenhouse gas emission 7 scenarios. The cumulative impacts of global greenhouse gas emissions on climate are 8 discussed in Section 4.16.10, Global Greenhouse Gas Emissions, in this SEIS. In 9 Section 4.16, Cumulative Impacts, of this SEIS, the NRC staff considers the potential 10 cumulative, or overlapping, impacts from climate change on environmental resources where 11 there are incremental impacts of the proposed action (subsequent license renewal). 12 4.15.3.1 Greenhouse Gas Emissions from the Proposed Action and Alternatives 13 Gases found in the Earths atmosphere that trap heat and play a role in the Earths climate are 14 collectively termed greenhouse gases. Greenhouse gases include carbon dioxide (CO2); 15 methane (CH4); nitrous oxide (N2O); water vapor (H2O); and fluorinated gases, such as 16 hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). The 17 Earths climate responds to changes in concentrations of greenhouse gases in the atmosphere 18 because these gases affect the amount of energy absorbed and heat trapped by the 19 atmosphere. Increasing greenhouse gas concentrations in the atmosphere generally increase 20 the Earths surface temperature. Atmospheric concentrations of carbon dioxide, methane, and 21 nitrous oxide have significantly increased since 1750 (IPCC 2007, IPCC 2013). Carbon dioxide, 22 methane, nitrous oxide, water vapor, and fluorinated gases (termed long-lived greenhouse 23 gases) are well mixed throughout the Earths atmosphere, and their impact on climate is long 24 lasting as a result of their long atmospheric lifetime (EPA 2009b). Carbon dioxide is of primary 25 concern for global climate change, due to its long atmospheric lifetime, and it is the primary gas 26 emitted as a result of human activities. Climate change research indicates that the cause of the 27 Earths warming over the last 50 years is due to the buildup of greenhouse gases in the 28 atmosphere resulting from human activities (IPCC 2013, USGCRP 2014, USGCRP 2017). The 29 EPA has determined that greenhouse gases may reasonably be anticipated both to endanger 30 public health and to endanger public welfare (74 FR 66496). 31 Proposed Action 32 Operation of Turkey Point emits greenhouse gases directly and indirectly. Turkey Points direct 33 greenhouse gas emissions result from stationary portable combustion sources (see Table 3-2) 34 and stationary refrigeration appliances. Indirect greenhouse gas emissions originate from 35 mobile combustion sources (e.g., employee vehicles, visitor vehicles, and delivery vehicles). 36 Table 4-6 below presents quantified annual greenhouse gas emissions from sources at Turkey 37 Point. 38 FPL does not maintain an inventory of greenhouse gas emissions resulting from visitor and 39 delivery vehicles. Chlorofluorocarbon and hydrochlorofluorocarbon emissions from refrigerant 40 sources can result from leakage, servicing, repair, or disposal of refrigerant sources. 41 Chlorofluorocarbons and hydrochlorofluorocarbons are ozone-depleting substances that are 42 regulated by the Clean Air Act under Title VI, Stratospheric Ozone Protection. FPL maintains 43 a program to manage stationary refrigeration appliances at Turkey Point to recycle, recapture, 44 and reduce emissions of ozone-depleting substances (FPL 2018f). Estimating greenhouse gas 45 emissions from refrigerant sources is complicated due to their ability to deplete ozone, which is 4-102

1 also a greenhouse gas, making their global warming potentials difficult to quantify. 2 Consequently, greenhouse gas emissions from refrigerant sources are commonly excluded 3 from greenhouse gas inventories (EPA 2014d). Therefore, Table 4-6 does not account for 4 potential greenhouse gas emissions from stationary refrigeration appliances or visitor and 5 delivery vehicles at Turkey Point. 6 Table 4-6 Estimated Greenhouse Gas Emissions(a) from Operation at Turkey Point, 7 Units 3 and 4 Workforce Turkey Point Combustion Commuting(c) Year Sources(b) (tons/year) (tons/year) Total (tons/year) 2012 520 3,100 3,620 2013 450 3,100 3,550 2014 560 3,100 3,660 2015 710 3,100 3,810 2016 490 3,100 3,590 (a) Emissions are rounded up. (b) Includes stationary and portable diesel and gasoline engines described in Table 3-2. (c) Emissions consider Turkey Point full-time employees and does not include additional contractor workers during refueling outages. Refueling outages occur on a staggered, 18-month schedule and last approximately 25-35 days per unit. Sources: FPL 2018f 8 No-Action Alternative 9 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 10 Turkey Point Units 3 and 4 would shut down on or before the expiration of the current renewed 11 licenses. At some point, all nuclear plants will terminate operations and undergo 12 decommissioning. The Decommissioning GEIS (NUREG-0586, NRC 2002a) considers the 13 impacts from decommissioning. Therefore, the scope of impacts considered under the 14 no-action alternative includes the immediate impacts resulting from activities at Turkey Point 15 that would occur between plant shutdown and the beginning of decommissioning (i.e., activities 16 and actions necessary to cease operation of Turkey Point). Turkey Point operations would 17 terminate at or before the expiration of the current renewed licenses. When the plant stops 18 operating, a reduction in greenhouse gas emissions from activities related to plant operation, 19 such as the use of diesel generators and employee vehicles, would occur. The NRC staff 20 anticipates that greenhouse gas emissions for the no-action alternative would be less than 21 those presented in Table 4-6, which shows the estimated greenhouse gas emissions from 22 operation of Turkey Point Units 3 and 4. 23 Since the no-action alternative would result in a loss of power generating capacity due to 24 shutdown, the sections below discuss greenhouse gas emissions associated with replacement 25 baseload power generation for each replacement power alternative analyzed. 4-103

1 New Nuclear Alternative 2 The GEIS (NUREG-1437) presents life-cycle greenhouse gas emissions associated with 3 nuclear power generation. As presented in Tables 4.12-4 through 4.12-6 of the GEIS 4 (NRC 2013a), life-cycle greenhouse gas emissions from nuclear power generation can range 5 from 1 to 288 grams carbon equivalent per kilowatt-hour (g Ceq/kWh). Nuclear power plants do 6 not burn fossil fuels to generate electricity. Sources of greenhouse gas emissions from the new 7 nuclear alternative would include stationary combustion sources such as emergency diesel 8 generators, boilers, and pumps similar to existing sources at Turkey Point (see Section 3.2.1 of 9 this SEIS). The NRC staff estimates that greenhouse gas emissions from a new nuclear 10 alternative would be similar to greenhouse gas emissions from Turkey Point. 11 Natural Gas Combined-Cycle Alternative 12 The GEIS (NRC 2013a) presents life-cycle greenhouse gas emissions associated with natural 13 gas power generation. As presented in Table 4.12-5 of the GEIS, life-cycle greenhouse gas 14 emissions from natural gas can range from 120 to 930 g Ceq/kWh. The NRC staff estimates that 15 direct emissions from the operation of three, 500-MWe natural gas combined-cycle units would 16 total 5.7 million tons (5.2 million MT) of carbon dioxide equivalents (CO2eq) per year. 17 Combination Alternative 18 For the combination alternative, greenhouse gases would primarily be emitted from the natural 19 gas component of this alternative. The NRC staff estimates that the operation of the natural 20 gas-fired units would emit a total of 5.4 million tons (4.9 million MT) of CO2eq per year. 21 Summary of Greenhouse Gas Emissions from the Proposed Action and Alternatives 22 Table 4-7 below presents the direct greenhouse gas emissions from facility operations under 23 the proposed action of subsequent license renewal and alternatives to the proposed action. 24 Greenhouse gas emissions from the proposed action (subsequent license renewal), the 25 no-action alternative, and the new nuclear alternative would be the lowest. Greenhouse gas 26 emissions from the natural gas and combination alternatives are several orders of magnitude 27 greater than those from the continued operation of Turkey Point. Therefore, if Turkey Points 28 generating capacity were to be replaced by either of these two alternatives, there would be an 29 increase in greenhouse gas emissions. Consequently, the continued operation of Turkey Point 30 (the proposed action) results in greenhouse gas emissions avoidance as compared to the 31 natural gas or combination alternative. 32 Table 4-7 Direct Greenhouse Gas Emissions from Facility Operations Under the 33 Proposed Action and Alternatives Technology/Alternative CO2eq(a) (tons/year) Proposed Action (Turkey Point subsequent license 710 renewal)(b) No-Action Alternative(c) 710 New Nuclear(d) 710 Natural Gas Combined-Cycle(e) 5.7 x 106 Combination Alternative(f) 5.4 x 106 4-104

Technology/Alternative CO2eq(a) (tons/year) (a) Carbon dioxide equivalent (CO2eq) is a metric used to compare the emissions of greenhouse gases (GHG) based on their global warming potential (GWP). The GWP is a measure used to compare how much heat a GHG traps in the atmosphere. The GWP is the total energy that a gas absorbs over a period of time compared to carbon dioxide. CO2eq is obtained by multiplying the amount of the GHG by the associated GWP. For example, the GWP of methane is 21; therefore, 1 ton of methane emission is equivalent to 21 tons of carbon dioxide emissions. (b) Greenhouse gas emissions include only direct emissions from combustion sources for the peak year presented in Table 4-6 (Source: FPL 2018f). (c) Emissions resulting from activities at Turkey Point that would occur between plant shutdown and the beginning of decommissioning and assumed not to be greater than greenhouse gas emissions from operation of Turkey Point. (d) Emissions assumed to be similar to Turkey Point operation. (e) Emissions from direct combustion of natural gas. Greenhouse gas emissions estimated using emission factors developed by the U.S. Department of Energys (DOEs) National Energy Technology Laboratory (NETL 2010). (f) Emissions from the natural gas combined-cycle component of the combination alternative. Greenhouse gas emissions estimated using emission factors developed by DOEs National Renewable Energy Laboratory (NETL 2010). 1 4.15.3.2 Climate Change 2 Observed Trends in Climate Change Indicators 3 Climate change is the decades or longer change in climate measurements (e.g., temperature 4 and precipitation) that has been observed on a global, national, and regional level (IPCC 2007, 5 EPA 2016b, USGCRP 2014). Climate change can vary regionally, spatially, and seasonally, 6 depending on local, regional, and global factors. Just as regional climate differs throughout the 7 world, the impacts of climate change can vary among locations. 8 On a global level, from 1901 to 2015, average surface temperatures rose at a rate of 0.15 F 9 (0.08 C) per decade, and total annual precipitation increased at an average rate of 10 0.08 inches (0.2 cm) per decade (EPA 2016b). The year 2017 was the second warmest on 11 record globally, second only to 2016. This finding is based on average global temperature data 12 dating back to 1880. Analyses performed by both NASA and NOAA show that globally, the 13 5 warmest years on record all have taken place since 2010 (NASA 2018). The observed global 14 change in average surface temperature and precipitation has been accompanied by an increase 15 in sea surface temperatures, a decrease in global glacier ice, an increase in sea level, and 16 changes in extreme weather events. Such extreme events include an increase in the frequency 17 of heat waves, heavy precipitation, and recorded maximum daily high temperatures 18 (IPCC 2007, EPA 2016b, USGCRP 2009, USGCRP 2014). 19 The U.S. Global Change Research Program (USGCRP) compiles the best available information 20 and current state of knowledge regarding climate change trends and effects at the regional and 21 national level. The USGCRP reports that, from 1895 to 2016, average surface temperature 22 increased by 1.8 °F (1.0 °C) across the contiguous United States and, since 1901, average 23 annual precipitation has increased by 4 percent (USGCRP 2017). On a seasonal basis, 24 warming has been the greatest in winter. Since the 1980s, NOAA data show an increase in the 25 length of the frost-free season, the period between the last occurrence of 32 F (0 °C) in the 4-105

1 spring and first occurrence of 32 F (0 °C) in the fall, across the contiguous United States. Over 2 the period 1991 through 2011, the average frost-free season was 10 days longer than between 3 1901 and 1960 (USGCRP 2014). Observed climate-related changes in the United States 4 include increases in the frequency and intensity of heavy precipitation, earlier onset of spring 5 snowmelt and runoff, rise of sea level in coastal areas, increase in occurrence of heat waves, 6 and a decrease in occurrence of cold waves. Since the 1980s, the intensity, frequency, and 7 duration of North Atlantic hurricanes has increased; however, there is no trend in landfall 8 frequency along the U.S. eastern and Gulf coasts (USGCRP 2014). 9 Temperature data indicate that the Southeast region of the United States, where Turkey Point is 10 located, did not experience significant warming overall for the time period from 1901 to 2012. In 11 the Southeast region, warming has averaged less than 1 °F (0.56 °C). The overall lack of 12 warming in the Southeast has been termed the warming hole (NOAA 2013b). A notable 13 exception is the South Florida region where average temperatures have warmed by greater 14 than 1.5 °F (0.83 °C) (EPA 2016c, USGCRP 2014: Fig 2.7). Annual and seasonal temperatures 15 across the Southeast have exhibited variability during the 20th century. However, since 1970, 16 average annual temperatures have steadily increased and have been accompanied by an 17 increase in the number of days with maximum temperatures above 90 °F (32.2 °C) in the 18 daytime and above 75 °F (23.9 °C) in the nighttime (IPCC 2007, NOAA 2013a, USGCRP 2009, 19 USGCRP 2014). Average annual precipitation data for the Southeast does not exhibit an 20 increasing or decreasing trend for the long-term period (1895-2011) (NOAA 2013b). 21 Precipitation in the Southeast region varies considerably throughout the seasons and average 22 precipitation has generally increased in the fall and decreased in the summer (NOAA 2013b, 23 USGCRP 2009). 24 Specific to South Florida, the NRC staff used the National Oceanic and Atmospheric 25 Administrations (NOAA) Climate at a Glance tool to analyze temperature and precipitation 26 trends for the period of 1895 to 2018 in the lower east coast region of Florida (NOAA 2018b). A 27 trends analysis shows that average annual temperature has increased at a rate of 28 0.2 °F (0.11 °C) per decade while average annual precipitation has remained relatively flat with 29 large year-to-year variations (NOAA 2018b). The number of extreme precipitation events 30 (defined as precipitation greater than 4 inches, averaged over 5-year periods) since 1900 has 31 been highly variable for Florida with no clear trend. In contrast, the threat of drought is 32 persistent across the State, and Florida has experienced below average precipitation over the 33 last decade (2005-2014) (Runkle et al. 2017). 34 Based on an analysis of tidal gauge data, global mean sea level has risen by approximately 35 8 to 9 inches (20 to 23 cm) since 1880, with about 3 inches (7.6 cm) of the rise having occurred 36 since 1993. Since the early 1990s, tidal gauge and satellite altimeter data indicate an 37 acceleration in the rate of sea level rise, which is now on the order of 1.2 inches (3 cm) per 38 decade. With higher sea levels, the frequency of tidal flooding that causes minor impacts or 39 nuisance floods has increased by a factor of 5 to 10 since the 1960s in several United States 40 coastal cities. The rates of increase in such flooding are accelerating in more than 25 cities 41 along the Atlantic and Gulf Coasts (USGCRP 2017). 42 Observed changes in sea level and their effects vary regionally and locally. In the United 43 States, the Mid-Atlantic and parts of the Gulf coasts have experienced the greatest sea level 44 rise, with some stations having experienced increases of more than 8 in. (20 cm) between 1960 45 and 2015 (EPA 2016b). Currently, the relative sea level rise trend at Miami, FL is 0.09 in. per 46 year (0.24 cm per year), or about 9 in. (23 cm) per century. This is based on NOAA tidal gauge 4-106

1 readings and takes into account local vertical land motion (e.g., subsidence and/or uplift) 2 (NOAA 2018c). 3 Climate Change Projections 4 Future global greenhouse gas emission concentrations (emission scenarios) and climate 5 models are commonly used to project possible climate change. Climate models indicate that 6 over the next few decades, temperature increases will continue due to current greenhouse gas 7 emission concentrations in the atmosphere (USGCRP 2014). Over the longer term, the 8 magnitude of temperature increases and climate change effects will depend on both past and 9 future global greenhouse gas emissions (IPCC 2007, IPCC 2013, USGCRP 2009, 10 USGCRP 2014). Climate model simulations often use greenhouse gas emission scenarios to 11 represent possible future social, economic, technological, and demographic development that, 12 in turn, drive future emissions. Consequently, the greenhouse gas emission scenarios, their 13 supporting assumptions, and the projections of possible climate change effects entail 14 substantial uncertainty. 15 The Intergovernmental Panel on Climate Change (IPCC) has generated various representative 16 concentration pathway (RCP) scenarios commonly used by climate-modeling groups to project 17 future climate conditions (IPCC 2000, IPCC 2013, USGCRP 2017, USGCRP 2018). For 18 instance, the A2 scenario is representative of a high-emission scenario in which greenhouse 19 gas emissions continue to rise during the 21st century from 40 gigatons (GT) of carbon dioxide 20 equivalents (CO2eq) per year in 2000 to 140 GT of CO2eq per year by 2100. The B1 scenario, on 21 the other hand, is representative of a low-emission scenario in which emissions rise from 40 GT 22 of CO2eq per year in 2000 to 50 GT of CO2eq per year midcentury before falling to 30 GT of CO2eq 23 per year by 2100 (IPCC 2000, USGCRP 2014). 24 The RCP scenarios are based on predicted changes in radiative forcing (a measure of the 25 influence that a factor, such as greenhouse gas emissions, has in changing the global balance 26 of incoming and outgoing energy) in the year 2100 relative to preindustrial conditions. The 27 RCPs are numbered in accordance with the change in radiative forcing measured in watts per 28 square meter (i.e., +2.6 (very low), +4.5 (lower), +6.0 (mid-high) and +8.5 (higher)) (USGCRP 29 2014, 2017, 2018). For example, RCP 8.5 reflects a continued increase in global emissions 30 resulting in increased warming by 2100, while RCP 2.6 assumes immediate and rapid 31 reductions in emissions resulting in less warming by 2100 (USGCRP 2014). Most recently, the 32 USGCRP has used the RCPs and associated modelling results as the basis of its climate 33 change assessments (USGCRP 2017, 2018). 34 The NRC staff considered the best available national climate change studies as part of its 35 assessment of potential changes in climate-relevant indicators during the Turkey Point 36 subsequent license renewal term (2032-2052 and 2033-2053 for Units 3 and 4, respectively). 37 As input to the Third National Climate Assessment report (USGCRP 2014), NOAA analyzed 38 future regional climate change scenarios based on climate model simulations using the high 39 (A2) and low (B1) emission scenarios. NOAAs climate model simulations (for the period 40 between 2041 and 2070 (2055 midpoint) relative to the reference period, 1971-1999) indicate 41 the following: Annual mean temperature is projected to increase by 1.5-3.5 °F (0.83-1.9 °C) 42 across the Southeast region, including southern Florida, under both a 43 low- and high-emission-modeled scenario (NOAA 2013b). Increases in temperature during this 44 time period are projected to occur for all seasons with the largest increase occurring in the 45 summertime (June, July, and August). Newer regional projections for annual mean temperature 46 are available from The Fourth National Climate Assessment under the RCP 4.5 and RCP 8.5 4-107

1 scenarios for the mid-century (2036-2065) as compared to the average for 1976-2005 2 (USGCRP 2017). The modeling predicts increases of 3.4-4.3 °F (1.9-2.4 °C) across the 3 Southeast region by mid-century. 4 As for precipitation, the climate model simulations (for the time period 2021-2050) suggest 5 spatial differences in annual mean precipitation change across the Southeast with some areas 6 experiencing an increase and others a decrease in precipitation. On a seasonal basis, climate 7 models are not in agreement on the sign or direction (increase or decrease) of modeled 8 precipitation changes. For Florida, a 0 to 3 percent decrease in annual mean precipitation is 9 predicted under both a low- and high-emission-modeled scenario; however, the predicted 10 changes in precipitation are not significant as the models indicate changes that are less than 11 normal year-to-year variations (NOAA 2013b). 12 Heavy precipitation events across the Southeast including southern Florida are expected to 13 increase in both frequency and intensity. By the end of the century, an event that now typically 14 occurs once in 20 years is projected to occur 2 to 3 times as often. Additionally, the number of 15 tropical storms will decrease globally, but those that occur will be stronger in force, yielding 16 more Category 4 and 5 storms. Rainfall rates associated with tropical storms are expected to 17 be greater (USGCRP 2014). 18 Climate models are not in agreement when projecting changes in Atlantic hurricane activity; 19 nonetheless, models agree that under a warmer climate, hurricane-associated rainfall rates and 20 wind speed will increase (EPA 2016b, USGCRP 2014). 21 In 2017, the USGCRPs issued its Fourth National Climate Assessment report (USGCRP 2017), 22 which includes updated sea level rise projections. The 2017 report updates NOAAs global sea 23 level rise scenarios presented in the report, Global Sea Level Rise Scenarios for the United 24 States National Climate Assessment (Parris et al. 2012) and which were previously used as the 25 basis of the Southeast Florida Regional Climate Change Compacts 2015 sea level projections. 26 As for future sea levels, the USGCRP reports that, relative to the year 2000, global mean sea 27 level is projected rise by 0.3 to 0.6 feet (0.09 to 0.18 m) by 2030 and 0.5 to 1.2 feet (0.15 to 28 0.37 m) by 2050 (USGCRP 2017). The USGCRP assigns very high confidence to the lower 29 bounds of these projections and medium confidence to the upper bounds. For the first half of 30 this century, future greenhouse gas emissions will have little effect as sea levels continue to 31 rise, but emissions significantly affect levels beyond mid-century. Relative sea level rise on the 32 East and Gulf Coasts of the United States is likely to be higher than the global average 33 (USGCRP 2017). 34 Beyond the 2050 timeframe (and beyond the subsequent license renewal term for Turkey Point 35 Units 3 and 4) and to the end of the century, sea levels are projected to continue to rise but the 36 projections are subject to even greater uncertainty. In Appendix I, Section I.2 of the final EIS for 37 the proposed Turkey Point Units 6 and 7 combined licenses (NUREG-2176, NRC 2016a), the 38 NRC staff cited earlier sea level rise projections from the USGCRP (USGCRP 2014) of 1 to 39 4 feet (0.3 to 1.2 m) globally by the year 2100. NUREG-2176 also cited the extreme high end 40 sea level rise estimate of 8.2 feet (2.5 m) by the year 2100 (NRC 2016a). In NUREG-2176, the 41 NRC staff conjectured that should such a high rate of sea level rise occur, much of South 42 Florida would be uninhabitable and millions of people would likely be displaced. However, the 43 NRC staff also observed that because sea level rise is likely to continue gradually, adaptation is 44 possible (NRC 2016a). The latest consensus estimates from the USGCRP (USGCRP 2017) 45 similarly indicate potential global sea level rise of 1 to 4.3 feet (0.3 to 1.3 m) by 2100. The 4-108

1 USGCRP assigned low confidence to the upper bounds estimates for the year 2100 in part 2 because future greenhouse gas emissions drive sea level rise projections for the second half of 3 the century. The USGCRP also indicated that sea level rise of 8 feet (2.4 m) or higher is 4 physically possible, although the probability of that occurring could not be assessed at the time 5 the report was written (USGCRP 2017). Nevertheless, it is apparent that future sea level rise is 6 difficult to predict and is dependent on the amount of warming, ice melt from glaciers and ice 7 sheets, and vertical land motion (e.g., local land subsidence or uplift) that may occur 8 (USGCRP 2014, USGCRP 2017). 9 In 2015, the Southeast Florida Regional Climate Change Compact (SFRCCC or the Compact) 10 published its update to the unified sea level rise projection. Its projections are intended for use 11 by counties in the Southeast Florida compact to support planning with respect to potential 12 vulnerabilities and the development of mitigation strategies to sea level rise (SFRCCC 2015). 13 The Compact produced sea level rise projections for three planning horizons (2030, 2060, and 14 2100). The projections for the medium term (i.e., 2060) most closely approximate the 15 USGCRPs 2050 projections, which encompass the subsequent license renewal term for Turkey 16 Point. Based on the Compacts estimates, relative to the year 1992, mean sea levels would rise 17 0.5 to 0.83 feet (0.15 to 0.25 m) by 2030 and 1.16 to 2.83 feet (0.35 to 0.86 m) by 2060. These 18 estimates are referenced to the tidal gauge at Key West, FL. The Compacts projections 19 (SFRCCC 2015), which are given in inches, have been converted to feet here for ease of 20 comparison with those from the USGCRP (USGCRP 2017). 21 The NRC staff observes that in the short term (i.e., by the year 2030, or prior to the subsequent 22 license renewal term), the Compacts regional estimates are not substantially different from the 23 latest estimates produced by the USGCRP, although they diverge in the medium term (2050 to 24 2060). Specifically, the USGCRP projects sea level rise of 0.5 to 1.2 feet (0.15 to 0.37 m) by 25 2050, while the Compact projects a sea level rise of 1.16 to 2.83 feet (0.35 to 0.86 m) by 2060. 26 The NRC staff observes that such divergence is not unexpected as uncertainty in the 27 projections also increases with time. The Compact acknowledges as much, stating that, sea 28 level rise in the medium and long term has a significant range of variation as a result of 29 uncertainty in future greenhouse gas emissions and their geophysical effects (SFRCCC 2015). 30 The Compacts sea level rise estimates have some inherent differences as compared to the 31 consensus-based estimates from the USGCRP. For example, the USGCRPs sea level rise 32 estimates are relative to global mean sea level while the Compacts estimates are referenced to 33 mean sea level at Key West, FL. The temporal baseline from which incremental sea level is 34 measured also varies (year 2000 for USGCRPs current estimates versus 1992 for the 35 Compact), a difference of 8 years over which time some sea level rise has inevitably already 36 occurred. Accordingly, while they are useful for future planning, the various estimates are not 37 directly comparable. 38 Based on the NRC staffs review, the staff considers the Compacts estimates to be 39 conservative or bounding estimates (i.e., they reflect a higher sea level rise than would likely be 40 observed based on the best available data from the USGCRP). As described in the Compact 41 (SFRCCC 2015), sea level rise range estimates are based on the more conservative sea level 42 rise projections or curves prepared by NOAA, the U.S. Army Corp of Engineers (USACE), and 43 the Intergovernmental Panel on Climate Change (IPCC). Specifically, the Compact cites as the 44 basis of its projections what is describes as the NOAA high curve, the USACE high curve, 45 and the median of the IPCC Fifth Assessment Reports (AR5) RCP 8.5 scenario, which is 46 described in the report, Climate Change 2013: The Physical Science Basis (IPCC 2013). 4-109

1 These scenarios in part define the upper bound (e.g., up to 2.83 feet (0.86 m) in sea level rise 2 by 2060) of the Compacts projections. 3 The NOAA high curve adopted by the Compact is derived from the highest of four global sea 4 level rise scenarios (i.e., highest, intermediate-high, intermediate-low, and lowest) presented in 5 NOAA Technical Report OAR CPO-1 (Parris et al. 2012). As stated by Parris et al. 6 (Parris et al. 2012), the highest scenario, in part, assumes the maximum possible glacier and 7 ice sheet loss. Similarly, with regard to the USACE high curve, USACE Technical Letter 8 No. 1100-2-1 (DOA 2014) indicates that the USACE high curve exceeds the upper boundaries 9 for projected sea level rise from the IPCC for 2001, 2007, and 2013. The curve further accounts 10 for the possibility of rapid ice loss from Antarctica and Greenland, and generally falls between 11 the highest and intermediate high curves given in Parris (Parris et al. 2012). Finally, the 12 Compacts adoption of RCP 8.5 represents another rather conservative assumption. As noted 13 in the USGCRP report (USGCRP 2017), the RCP 8.5 scenario in part assumes that global 14 carbon emissions continue to rise steadily due to continued fossil fuel combustion, whereas 15 other scenarios reflect varying reductions in emissions. 16 Based on the studies referenced above, it is apparent that rising sea levels will continue to have 17 measurable hydrologic effects on coastal communities, but those effects may vary in severity on 18 a local and regional basis. As sea levels rise, the incidence of tidal flooding in coastal areas 19 due to all coastal storms will increase, as will the depth and extent of such flooding. Further, the 20 USGCRP reports that there is medium confidence that the intensity of North Atlantic hurricanes 21 will increase, thus increasing the chances of extreme flooding along the East and Gulf Coasts. 22 However, there is a low level of confidence in the projected increase in frequency of Atlantic 23 hurricanes (USGCRP 2017). 24 Changes in climate have broader implications for public health, water resources, land use and 25 development, and ecosystems. For instance, changes in precipitation patterns and increases in 26 air temperature can affect water availability and quality, distribution of plant and animal species, 27 land use patterns, and land cover, which can, in turn, affect terrestrial and aquatic habitats. In 28 Section 4.16 of this SEIS, the NRC staff considers the potential cumulative, or overlapping, 29 impacts from climate change on environmental resources that could also be impacted by the 30 proposed action (subsequent license renewal). 31 The effects of climate change on Turkey Point Unit 3 and 4 structures, systems, and 32 components are outside the scope of the NRC staffs license renewal environmental review. 33 The environmental review documents the potential effects from continued nuclear power plant 34 operation on the environment. Site-specific environmental conditions are considered when 35 siting nuclear power plants. This includes the consideration of meteorological and hydrologic 36 siting criteria as set forth in 10 CFR Part 100, Reactor Site Criteria. Turkey Point was 37 designed and constructed in accordance with 10 CFR Part 50, Appendix A, General Design 38 Criteria for Nuclear Power Plants. NRC regulations require that plant structures, systems, and 39 components important to safety be designed to withstand the effects of natural phenomena, 40 such as flooding, without loss of capability to perform safety functions. Further, nuclear power 41 plants are required to operate within technical safety specifications in accordance with the NRC 42 operating license, including coping with natural phenomena hazards. The NRC conducts safety 43 reviews prior to allowing licensees to make operational changes due to changing environmental 44 conditions. Additionally, the NRC evaluates nuclear power plant operating conditions and 45 physical infrastructure to ensure ongoing safe operations under the plants initial and renewed 46 operating licenses, through the NRCs Reactor Oversight Program. If new information about 47 changing environmental conditions (such as rising sea levels that threaten safe operating 4-110

1 conditions or challenge compliance with the plants technical specifications) becomes available, 2 the NRC will evaluate the new information to determine if any safety-related changes are 3 needed at licensed nuclear power plants. This is a separate and distinct process from the NRC 4 staffs subsequent license renewal environmental review that it conducts in accordance with the 5 National Environmental Policy Act (NEPA). Nonetheless, as discussed below, the NRC staff 6 considers the impacts of climate change in combination with the effects of subsequent license 7 renewal, in assessing cumulative impacts. That discussion is provided in Section 4.16 of this 8 SEIS. 9 4.16 Cumulative Impacts 10 Cumulative impacts may result when the environmental effects associated with the proposed 11 action (e.g., subsequent license renewal) are added to the environmental effects from other 12 past, present, and reasonably foreseeable future actions. Cumulative impacts can result from 13 individually minor, but collectively significant, actions taking place over a period of time. An 14 effect that may be inconsequential by itself could result in a greater environmental impact when 15 combined with the effects of other actions. As explained in NUREG-1437, Generic 16 Environmental Impact Statement for License Renewal of Nuclear Plants (the GEIS) 17 (NRC 2013a), the effects of the license renewal action combined with the effects of other 18 actions could generate cumulative impacts on a given resource. 19 For the purposes of this analysis, past actions are those that occurred since the commencement 20 of Turkey Point Units 3 and 4 reactor operations and prior to the submittal of the license renewal 21 application. Older actions are considered as part of the affected environment in Chapter 3 of 22 this SEIS. Present actions are those that are occurring during current power plant operations. 23 Future actions are those that are reasonably foreseeable to occur through the end of power 24 plant operation, including the period of extended operation. Therefore, the cumulative impacts 25 analysis considers potential effects through the end of the current license term, as well as 26 through the end of the 20-year subsequent license renewal term. 27 The cumulative impacts analysis accounts for both geographic (spatial) and time (temporal) 28 considerations of past, present, and reasonably foreseeable future actions to determine whether 29 other potential actions are likely to contribute to the total environmental impact. In addition, 30 because cumulative impacts accrue to resources and focus on overlapping impacts with the 31 proposed action, no cumulative impacts analysis was performed for resource areas where the 32 proposed action is unlikely to have any incremental impacts on that resource. For example, 33 since FPL is prohibited from discharging effluents into surface waters of the State, and the 34 FDEP and DERM have imposed requirements for mitigation of the hypersaline plume originating 35 from the CCS, subsequent license renewal is not expected to have a cumulative impact on 36 surface water quality in combination with rising sea levels. Consequently, no cumulative 37 impacts analysis was performed for the following resource areas: land use, noise, surface 38 water, and geology and soils. 39 As noted in Section 4.15.3.2, Climate Change, of this SEIS, changes in climate could have 40 broad implications for certain resource areas. Accordingly, a climate change impact discussion 41 is provided for those resource areas that could be incrementally impacted by the proposed 42 action (subsequent license renewal). It is also important to note that the potential effects of 43 climate change would occur irrespective of the proposed action. 44 Information from FPLs environmental report; responses to requests for additional information; 45 information from other Federal, State, and local government agencies; scoping comments; and 4-111

1 information gathered during the NRC staffs visit to Turkey Point were used to identify past, 2 present, and reasonably foreseeable future actions in the cumulative impacts analysis. To 3 evaluate cumulative impacts resulting from the continued operation of Turkey Point Units 3 4 and 4, the incremental impacts of the proposed action, as described in Sections 4.2 to 4.13 of 5 this SEIS, are combined with the impacts of other past, present, and reasonably foreseeable 6 future actions regardless of which agency (Federal or non-Federal) or person undertakes such 7 actions. In general, the effects of past actions have already been described in Chapter 3 of this 8 SEIS, the affected environment, which serves as the environmental baseline for the cumulative 9 impacts analysis. 10 Chapter 7.0 of the NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses 11 (NUREG-2176) (NRC 2016a) provides a recent analysis of cumulative impacts at the Turkey 12 Point site resulting from the construction and operation Turkey Point Units 6 and 7. Table 7-1 in 13 NUREG-2176 identifies the past, present, and reasonably foreseeable future actions and other 14 actions near the Turkey Point site, including Everglades restoration, and other energy, mining, 15 and transportation projects considered in the analysis. All of this information is incorporated 16 here by reference (NRC 2016a: pages 7-1 through 7-46). 17 The NRC staff identified as an additional future action, a plan that SDI Aggregate, LLC, a private 18 project located at a quarry approximately 5.5 mi (9 km) west of Turkey Point, has to install a 19 series of injection wells to mitigate the progression of saltwater intrusion westward. The South 20 Florida Water Management District issued a consumptive use permit for this project in 2017 21 (SFWMD 2017a). 22 In addition, two potential future actions at the Turkey Point site were identified during the 23 subsequent license renewal review: (1) the possible construction and operation of a Miami-24 Dade County wastewater treatment facility and (2) the possible expansion of the Turkey Point 25 Units 3 and 4 independent spent fuel storage installation (ISFSI). FPL and Miami-Dade County 26 have agreed to investigate the potential to create a tertiary wastewater treatment facility that 27 could provide up to 60 million gallons (approximately 230 million liters) per day of reclaimed 28 wastewater for use at the Turkey Point site. Possible uses for this treated wastewater would 29 include makeup water for Turkey Point Unit 5 forced draft cooling towers and freshening water 30 to assist in managing salinity in the cooling canal system (CCS). If constructed, this tertiary 31 wastewater treatment facility could provide reclaimed water to the CCS during the subsequent 32 license renewal period of extended operations. To date, FPL and Miami-Dade County have not 33 yet committed to building this facility. 34 FPL may also need to expand the Turkey Point Units 3 and 4 ISFSI, which could require the 35 construction of a new ISFSI pad to accommodate additional spent nuclear fuel generated during 36 the subsequent license renewal term, if DOE does not begin to take ownership of the spent 37 nuclear fuel in 2031 (FPL 2018g). Conversely, FPL may choose to utilize a higher density 38 storage system to create additional storage capacity, thereby reducing the need to expand the 39 ISFSI. As a result, FPL has not yet determined whether it would expand the ISFSI. 40 Regardless, if implemented, each of these actions would likely be completed prior to the 41 commencement of the subsequent license renewal term. No other new and significant 42 information was identified during the NRC staffs review of FPLs environmental report for 43 Turkey Point Units 3 and 4 (FPL 2018f), the site audit, the scoping process, or the evaluation of 44 other available information since the Turkey Point Units 6 and 7 COL EIS was issued (NUREG 45 2176) (NRC 2016a). 4-112

1 4.16.1 Air Quality 2 The region of influence (ROI) that the NRC staff considered in the cumulative air quality analysis 3 is Miami-Dade County because air quality designations in Florida are made at the county level. 4 FPL has not proposed any refurbishment-related activities during the subsequent license 5 renewal period. As a result, the NRC staff expects that air emissions at Turkey Point during the 6 subsequent license renewal period would be similar to those presented in Section 3.3.2, Air 7 Quality. Table 7-1 of the NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses 8 (NUREG-2176) (NRC 2016a), which is incorporated by reference in Section 4-16 of this SEIS, 9 provides a list of present and reasonably foreseeable future projects that could contribute to 10 cumulative impacts to air quality in Miami-Dade County. Current air emission sources operating 11 in Miami-Dade County have not resulted in long-term National Ambient Air Quality Standards 12 (NAAQS) violations given the designated unclassifiable/attainment status for all NAAQS in 13 Miami-Dade County. Consequently, cumulative changes to air quality in Miami-Dade County 14 would be the result of future projects and actions that change present-day emissions within the 15 county. 16 The development and construction activities identified above in Section 4.16 and those 17 identified in Table 7-1 of the EIS for the Turkey Point Units 6 and 7 combined licenses 18 (NUREG-2176) (NRC 2016a) can increase air emissions during their respective construction 19 periods, but those air emissions would be temporary and localized. However, future operation 20 of new commercial and industrial facilities and increases in vehicular traffic can result in overall 21 long-term air emissions that contribute to cumulative air quality impacts. Any entity establishing 22 new stationary sources of emissions in the region of influence would be required to apply for an 23 air permit from the Florida Department of Environmental Protection and would also be required 24 to operate in accordance with applicable Federal, State, and local regulatory requirements. 25 Climate Change 26 Climate change can impact air quality as a result of changes in meteorological conditions. The 27 formation, transport, dispersion, and deposition of air pollutants depend, in part, on weather 28 conditions (IPCC 2007). Ozone has been found to be particularly sensitive to climate change 29 (IPCC 2007; EPA 2009a). Ozone is formed, in part, as a result of the chemical reaction of 30 nitrogen oxides and volatile organic compounds in the presence of heat and sunlight. Sunshine, 31 high temperatures, and air stagnation are favorable meteorological conditions for higher levels 32 of ozone (IPCC 2007, EPA 2009b). The emission of ozone precursors also depends on 33 temperature, wind, and solar radiation (IPCC 2007). According to the U.S. Environmental 34 Protection Agency (EPA), both nitrogen oxide and biogenic volatile organic compound 35 emissions are expected to be higher in a warmer climate (EPA 2009a). Although surface 36 temperatures are expected to increase in the Southeast region of the United States (where 37 Turkey Point is located), this may not necessarily result in an increase in ozone concentrations 38 (Diem et al. 2017). For instance, during the fall in the Southeast, ozone concentrations 39 correlate with humidity (Zhang and Wang 2016). Wu et al. (Wu et al. 2008) modeled changes in 40 ozone levels in response to climate change and found negligible climate change-driven ozone 41 concentrations for the Southeast region. Tao et al. (Tao et al. 2007) found differences in future 42 changes in ozone for the Southeast with decreases in ozone concentrations under a low-43 emission-modelled scenario and increase under a high-emission-modelled scenario. Among 44 modelled studies of climate-related ozone changes, model simulations for the Southeast region 45 have the least consensus. Therefore, the potential cumulative impact to air quality ozone levels 46 in the vicinity of Turkey Point due to climate change is unknown. 4-113

1 4.16.2 Water Resources 2 4.16.2.1 Groundwater Resources 3 The description of the affected environment in Section 3.5.2, Groundwater Resources, of this 4 SEIS serves as the baseline for the NRC staffs cumulative impacts assessment for 5 groundwater resources. For groundwater, the geographic area of interest is comprised of the 6 local and regional aquifer systems potentially affected by Turkey Point operations, the surficial 7 (i.e., Biscayne) and Floridan aquifer systems. As such, this review focuses on those projects 8 and activities that would withdraw water from, or discharge effluents to, the referenced aquifer 9 systems. 10 Water Use Considerations 11 As part of the NRC staffs analysis for proposed Units 6 and 7, Sections 7.2.1.2, Groundwater-12 Use Impacts, and Appendix G, Section G.3.2.3, Summary of Review Team Focused 13 Modeling, of the final EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176, 14 NRC 2016a: 7-13-7-14, G-46-G-48) evaluate the cumulative impacts on groundwater use. The 15 analysis considered preconstruction, construction, and operations of proposed Units 6 and 7 as 16 well as the other past, present, and reasonably foreseeable future actions that could affect 17 groundwater uses, including some ongoing activities at the Turkey Point site and the potential 18 continued operation of Turkey Point Units 3 and 4 through subsequent license renewal. In 19 summary, the NRC staff concluded the following: 20

• The impacts from NRC-authorized construction and operations on groundwater use 21 would be SMALL, and no further mitigation would be warranted beyond the State of 22 Florida Siting Boards final conditions of certification (State of Florida Siting Board 2014).

23

• Limited operation of the radial collection wells would have minor impacts on Biscayne 24 aquifer users, although continued development and increased groundwater use could 25 lower groundwater levels in the aquifer and cause further inland movement of the 26 saltwater interface.

27

• Alterations in hydraulic head beneath the CCS associated with the addition of 28 groundwater to the CCS for freshening combined with operation of recovery wells for 29 remediation of the hypersaline groundwater plume would result in some increase flow of 30 surficial groundwater from the west as well as CCS water toward FPLs proposed radial 31 collection wells. Radial collection well operation would result in minor localized 32 alterations in salinity distribution.

33 The NRC staff incorporates here by reference these findings from the EIS for the Turkey Point 34 Units 6 and 7 combined licenses (NRC 2016a: 7-13-7-14, G46-G-48). 35 Section 4.5.1.2 of this SEIS, Conflicts Analysis for the Upper Floridan Aquifer, separately 36 describes and evaluates the potential impacts of FPLs withdrawals from the Upper Floridan 37 aquifer. FPL is authorized to withdraw 14.06 mgd (53,200 m3/d) of groundwater from the upper 38 production zones of the Upper Floridan aquifer for cooling water for Turkey Point Unit 5 and 39 process water for Units 1, 2, 3, 4, and 5 (i.e., from three saline production wells). FPL is 40 authorized to withdraw an additional 14 mgd (53,000 m3/d) from the freshening well system 41 (i.e., wells F-1, F-3, F-4, F-5, F-6). These withdrawals are authorized under the modified site 42 certification and associated conditions of certification for the Turkey Point site (State of Florida 43 Siting Board 2016, FDEP 2016b). FPL commissioned Tetra Tech, a consulting and engineering 4-114

1 services firm, to prepare a technical evaluation and associated groundwater flow model 2 (Tetra Tech 2014) to evaluate the proposed freshening withdrawals from the Upper Floridan 3 aquifer to support FPLs 2014 site certification modification for Turkey Point (FPL 2018n). 4 The technical evaluation and results indicate that operation of the freshening well system at the 5 maximum rate of 14 mgd (53,000 m3/d) could result in maximum, offsite drawdowns of up to 6 2.26 feet (0.7 m) at the Miami-Dade Water and Sewer Departments (MDWSDs) South Miami 7 Heights wellfield, located approximately 10.3 mi (16.6 km) north, northwest of the center point of 8 FPLs freshening well system. Further, modeling shows that the incremental drawdown from 9 freshening well system operations could account for 5 percent to as much as 19 percent of the 10 total predicted cumulative drawdown from all permitted withdrawals from the Upper Florida 11 aquifer at offsite locations. Specifically, the modeling projects incremental drawdown of up to 12 2.21 feet (0.67 m) at Sound Golf Club and Ocean Reef Club (about 9 mi (14 km) south of the 13 FPL freshening wells); these drawdowns account for 19 percent of the total cumulative 14 drawdown at these locations (Tetra Tech 2014). 15 While the reported modeling results reflect conservative, bounding-case impacts, the results 16 nonetheless indicate the potential for measurable cumulative impacts on groundwater within the 17 Upper Floridan aquifer. However, the NRC staff finds that the magnitude of FPLs withdrawals 18 and projected cumulative drawdowns would be unlikely to preclude aquifer availability and 19 cause groundwater use conflicts for other users based on the aquifer yields, total thickness, and 20 regional extent, under current conditions. In addition, the State-issued modified site certification 21 and associated conditions of certification for the Turkey Point site (State of Florida Siting 22 Board 2016, FDEP 2016b) require FPL to mitigate harm to offsite groundwater users (either 23 related to water quantity or quality) as well as to offsite water bodies, land uses, and other 24 beneficial uses. As necessary, the South Florida Water Management District could require FPL 25 to reduce withdrawals or undertake other mitigative actions, as further described in 26 Section 4.5.1.2 of this SEIS. 27 Implementation of the proposed project to treat up to 60 mgd (227,000 m3/d) of sanitary 28 wastewater from Miami-Dade County for use by FPL at the Turkey Point site would likely have 29 net, beneficial cumulative impacts on groundwater use. Using treated sanitary wastewater in 30 the CCS would potentially reduce or eliminate the need to operate FPLs freshening well 31 system, which conveys artesian groundwater from the Upper Floridan aquifer into the CCS for 32 salinity management. Any reduction in groundwater withdrawals from the Upper Floridan 33 aquifer would reduce regional aquifer drawdown. 34 Operation of the proposed freshwater injection system at the limestone quarries located 35 approximately 5 mi (8 km) west of the CCS and Turkey Point property would be likely to have 36 net, beneficial cumulative impacts on groundwater use and quality. As proposed and permitted 37 by SFWMD, the project would entail the withdrawal of up to 5 mgd (19,000 m3/d) of freshwater 38 groundwater from a single well completed to a depth of 40 feet (12 m). This water would then 39 be reinjected into the aquifer through a series of 14, 75-foot (23-m) deep injection wells that are 40 aligned along the eastern edge of the quarry property. Reinjection of the groundwater is 41 intended to form an eastward hydraulic barrier to protect the quarry property from encroachment 42 of the regional saltwater interface (SFWMD 2017a). The system is also expected to contribute 43 to efforts to retract the regional saltwater interface to the east, working in conjunction with FPLs 44 recovery well system, as evaluated in Section 4.5.1.2 of this SEIS. The modeling performed by 45 the project applicant and reviewed by SFWMD staff, as documented in its staff report, indicates 46 that operation of the system would have minimal offsite drawdown in the Biscayne aquifer 47 (SFWMD 2017a). 4-115

1 The NRC staff assumes that the freshwater injection system at the limestone quarries would 2 continue at least as long as operation of FPLs recovery well system, since it is intended to work 3 alongside FPLs recovery well system. As stated in Section 4.5.1.2 of this SEIS, current 4 modeling projections indicate that FPLs recovery well system will be successful in retracting the 5 hypersaline plume back to within the boundaries of the CCS within 10 years of startup (i.e., by 6 about 2028) while also retracting the saltwater interface back to the east from its current 7 location. If these projections are realized, then it is possible that neither the freshwater injection 8 system project nor FPLs recovery well system will be operating by the start of Turkey Points 9 subsequent license renewal term (i.e., 2032 for Unit 3 and 2033 for Unit 4). In that case, neither 10 activity would contribute to cumulative impacts associated with the proposed action (subsequent 11 license renewal). 12 Water Quality Considerations 13 In Section 7.2.2.2, Groundwater-Quality Impacts, of the final EIS for the Turkey Point Units 6 14 and 7 combined licenses (NUREG-2176, NRC 2016a), the NRC staff presented its evaluation 15 of the potential cumulative impacts on groundwater quality. The analysis considered 16 preconstruction, construction, and operations of proposed Units 6 and 7 as well as the other 17 past, present, and reasonably foreseeable future actions that could affect groundwater quality, 18 including some ongoing activities at the Turkey Point site and the potential continued operation 19 of Turkey Point Units 3 and 4. In summary, the NRC staff concluded the following: 20

• The impacts from NRC-authorized construction and operations on groundwater quality 21 would be SMALL, and no further mitigation would be warranted beyond the State of 22 Florida Siting Boards final conditions of certification (State of Florida Siting Board 2014).

23

• Ongoing and future actions being undertaken by Federal, State, and local government 24 agencies to enhance freshwater recharge of the Biscayne aquifer would potentially have 25 a positive impact on groundwater quality by reducing the potential for westward 26 movement of the saltwater interface.

27

• The addition of brackish water from the Upper Floridan aquifer to the CCS would be 28 likely to lower temperature, salinity, and concentration of other constituents in the CCS; 29 this would result in lower salt concentrations in water seeping out of the CCS and into 30 the Biscayne aquifer and thus reduce impacts on the Biscayne aquifer.

31

• Deep well injection of wastewater into the Boulder Zone proposed for Units 6 and 7 32 combined with wastewater injection operations at the Miami-Dade South District 33 Wastewater Treatment Plant would be unlikely to contribute to cumulative effects on 34 groundwater quality in the Boulder Zone or result in degradation of groundwater quality 35 in the overlying Upper Floridan aquifer.

36

• Mining operations in the region to support construction of Turkey Point Units 6 and 7 37 could affect groundwater quality by increasing salinity in underlying groundwater, but 38 regulation of mining operations would ensure that cumulative impacts would be minor.

39 The NRC staff incorporates here by reference all of the above findings (NRC 2016a: 7-13, 7 40 7-18). 41 As previously described, the operation of FPLs recovery well system is projected to be 42 successful in retracting the hypersaline plume back to within the boundaries of the CCS within 43 10 years of startup (i.e., by about 2028) while also retracting the saltwater interface back to the 44 east from its current location. This would result in beneficial impacts on groundwater quality 4-116

1 within the Biscayne aquifer (i.e., Class G-II groundwater) to the west of the CCS and the Turkey 2 Point site as well as in the portions of the aquifer beneath Biscayne Bay affected by CCS 3 operations. The NRC staff finds that it is reasonable to expect that FPLs freshening well 4 system would continue to be operated during the subsequent license renewal term, and for as 5 long as necessary to maintain compliance with the terms of the 2015 consent agreement with 6 Miami-Dade County DERM (MDC 2015a) and the 2016 FDEP consent order (FDEP 2016e). 7 The continuation of CCS freshening (salinity management) activities would ensure that the 8 average annual salinity of the CCS is maintained at or below 34 PSU, to control the generation 9 and migration of a hypersaline plume in groundwater. The NRC staff expects that continued 10 operation of the freshening system, combined with proper operation and maintenance of the 11 CCS, will result in no substantial contribution to cumulative impacts on groundwater quality or 12 associated impacts on surface water quality in Biscayne Bay during the subsequent license 13 renewal period. 14 Climate Change and Related Considerations 15 The NRC staff considered the best available information regarding the potential impacts of 16 climate change at a regional and local scale, including the U.S. Global Change Research 17 Programs (USGCRPs) most recent compilations of the state of knowledge relative to global 18 climate change effects (USGCRP 2014, USGCRP 2017). In Appendix I, Section I.3.2 of the 19 final EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176, NRC 2016a), the 20 NRC staff considered potential hydrologic changes related to climate change. Climate change 21 can impact groundwater availability and quality as a result of changes in temperature and 22 precipitation, as well as due to sea level rise. 23 As discussed in Section 4.15.3.2, Climate Change, of this SEIS, average annual temperature 24 across the lower east coast region of South Florida has increased at a rate of 0.2 °F (0.11 °C) 25 per decade and is projected to continue to increase by up to 3.5 °F (1.9 °C) by 2050. Although 26 annual precipitation data show no clear trend, climate model simulations indicate a slight 27 decrease in annual mean precipitation by 2050. However, heavy precipitation events are 28 expected to increase in both frequency and intensity. Changes in temperature and precipitation 29 have important implications for near- or at-surface water table aquifers, such as the Biscayne 30 aquifer of South Florida (see Section 3.5.2.1, Hydrogeology and Aquifers, of this SEIS), which 31 is locally recharged by local precipitation and runoff and is the primary source of water supply 32 for Miami-Dade County. An increase in average annual temperature without any increase in 33 annual precipitation would likely increase evapotranspiration and reduce recharge to the 34 Biscayne aquifer. Projected increases in heavy precipitation events could increase recharge 35 during the timeframe when they occur. However, increases in heavy precipitation events and 36 intensity without an annual increase in total precipitation would be unlikely to compensate for 37 decreased recharge throughout the year. 38 The effects of climate change are projected to significantly increase water demand across most 39 of the United States. Water demand across South Florida is projected to increase by more than 40 50 percent by 2060, relative to 2005, based on combined changes in population, socioeconomic 41 conditions, and climate (NRC 2016a) (USGCRP 2014, Figure 3.11). For most of Florida, this 42 increase in demand is forecast even without assuming climate change (USGCRP 2014, 43 Figure 3.11). Regardless, climate change, mainly due to increases in temperature and 44 evapotranspiration, would decrease water availability and further drive demand. 45 By about 2050, the USGCRP projects that global sea levels may rise by an additional 0.5 to 46 1.2 feet (0.15 to 0.37 m). This rise is likely to be higher along the East Coast of the United 4-117

1 States (USGCRP 2017). Higher sea levels will increase the rate of saltwater intrusion 2 (encroachment) into coastal freshwater supplies (USGCRP 2014). This is particularly true for 3 the Biscayne aquifer, as referenced previously, but also for the confined, Upper Floridan aquifer, 4 which is a designated underground source of drinking water across South Florida (see 5 Sections 3.5.2.1 and 3.5.2.2 of this SEIS). 6 A rise in sea level would have the most direct impacts on the Biscayne aquifer. Currently, the 7 saltwater interface is located about 4.7 mi (7.6 km) west of the Turkey Point site and the CCS at 8 its closest point, as described in Sections 3.5.2.1 and 3.5.2.2 of this SEIS. As sea levels rise, 9 saltwater from the east would move along the base of the Biscayne aquifer, pushing the 10 saltwater interface farther to the west from its current location. Combined with sea level rise, 11 decreases in recharge to the Biscayne aquifer would reduce the freshwater hydraulic head in 12 the Biscayne aquifer, further increasing the potential for westerly migration of the saltwater 13 interface across Miami-Dade County. 14 The potential for additional saltwater intrusion has significant implications for Miami-Dade 15 County, other public water supply systems, and private and industrial users of the Biscayne and 16 other affected aquifers. Increased salinity levels in groundwater supplies would increasingly 17 require public and private groundwater users to invest in treatment technologies 18 (e.g., desalination), to relocate supply wells and supporting infrastructure, to seek out and 19 develop new water supply sources, or to pursue a combination of approaches to manage 20 degraded groundwater quality. 21 4.16.3 Terrestrial Resources 22 The description of the affected environment in Section 3.6, Terrestrial Resources, of this SEIS 23 serves as the baseline for the NRC staffs cumulative impacts assessment for terrestrial 24 resources. For terrestrial resources, the geographic area of interest is comprised of the Turkey 25 Point site and offsite wetlands that could be impacted by FPLs efforts to recover and extract the 26 hypersaline water within and around the CCS as described in Section 3.6.1, Vegetative 27 Communities. 28 In Section 7.3.1 of the EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176, 29 NRC 2016a), the NRC staff described the cumulative impacts that terrestrial resources on and 30 near the Turkey Point site may experience. In its assessment, the staff considered the historical 31 context of the region, including prior drainage, development, and other modifications within 32 South Florida and the concomitant loss in species diversity and habitat. Present and 33 reasonably foreseeable future activities considered in the analysis included urban development, 34 energy production, mining, manufacturing, transportation and infrastructure development, and 35 other miscellaneous activities that could affect terrestrial and wetland resources. The NRC staff 36 (NRC 2016a) also considered current efforts to restore or improve ecological habitat, including 37 the Comprehensive Everglades Restoration Program and the Southern Glades Addition. in 38 addition, the NRC staffs cumulative impacts analysis (NRC 2016a) considered the overlapping 39 impacts of construction and operation of proposed Turkey Point Units 6 and 7 with the impacts 40 from continued operations at Units 3 and 4, such as any impacts to offsite wetlands from the 41 removal of water from the L-31E Canal during periods of excess flow, for use in freshening the 42 CCS. Appendix I, Section I.3.3 describes the potential overlapping impacts with climate 43 change. The NRC staff incorporates here by reference the above cumulative impacts analyses 44 from NUREG-2176 (NRC 2016a, Section 7.3.1, pages 7-19 to 7-23). 4-118

1 Since the NRC published the EIS for the Turkey Point Units 6 and 7 combined licenses 2 (NUREG-2176) (NRC 2016a), the NRC staff has determined that the possible construction and 3 operation of a mine and a Miami-Dade County wastewater treatment facility, as well as the 4 expansion of the Turkey Point Units 3 and 4 ISFSI, could result in additional overlapping 5 impacts to wetlands and other important terrestrial resources. Construction could result in both 6 the permanent and temporary loss of important terrestrial habitats, habitat fragmentation, and 7 habitat degradation as a result of runoff, erosion, and sedimentation. Wildlife and birds would 8 likely avoid the area during construction due to noise and other disturbances. Collisions with tall 9 structures and vehicles could also result in mortality. However, the implementation of 10 appropriate best management practices, revegetation following construction, and required 11 compensatory mitigation for unavoidable wetland impacts would minimize such impacts. 12 Furthermore, locating these projects within previously disturbed areas would minimize any 13 potential impacts to important terrestrial habitats. FPL (FPL 2018g) determined that if Turkey 14 Point requires a new ISFSI, the preferable candidate site would be located on previously 15 disturbed land within or adjacent to the Units 3 and 4 protected area. 16 4.16.4 Aquatic Resources 17 The description of the affected environment in Section 3.7, Aquatic Resources, in this SEIS 18 serves as the baseline for the NRC staffs cumulative impacts assessment for aquatic 19 resources. For aquatic resources, the geographic area of interest is comprised of the CCS and 20 other surface waters on the Turkey Point site (i.e., the hypersaline mudflats, remnant canals, 21 channels, dwarf mangrove wetlands, and open water areas described in Section 3.7.3, Aquatic 22 Resources on the Turkey Point Site) as well as Biscayne Bay. As such, this review focuses on 23 those projects and activities that would affect the aquatic biota and habitats within this 24 geographic area. 25 Many natural and human activities influence the characteristics of these aquatic environments 26 and the condition of the aquatic resources found in them. In Section 4.7.1, Proposed Action, 27 the NRC staff concludes that impingement, entrainment, and thermal effects associated with the 28 proposed subsequent license renewal would result in SMALL to MODERATE effects on the 29 aquatic resources of the CCS. These effects would not apply to aquatic resources within 30 Biscayne Bay because there are no surface water connections that allow aquatic organisms 31 inhabiting the Bay to interact with Turkey Points intake or discharge. All other potential impacts 32 of subsequent license renewal on aquatic resources would be SMALL. In Section 7.3.2 of the 33 EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176), the NRC 34 (NRC 2016a) staff considered a number of past, present, and reasonably foreseeable future 35 actions whose effects could overlap, resulting in cumulative impacts on the aquatic resources 36 on the Turkey Point site and within Biscayne Bay. In its analysis, the NRC staff evaluated the 37 following cumulative effects, which the staff hereby incorporates by reference. 38

• Historical context of the region, including prior drainage, development, and other 39 modifications within South Florida (pages 7-24 to 7-25) 40
• Existing units on the Turkey Point site (i.e., Units 1, 2, 3, 4, and 5) (pages 7-25 to 7-26) 41
• Ecological restoration initiatives and management programs, including the Model Lands 42 Basin and Southern Glades Addition; the Biscayne Bay Park Fishery Management Plan; 43 the Comprehensive Everglades Restoration Program; and Florida Keys National Marine 44 Sanctuary (pages 7-26 to 7-28) 4-119

1

• Population growth and coastal development (pages 7-28 to 7-29) 2
• Future construction and operation of Turkey Point Units 6 and 7 (Section 4.3.2; 3 summarized on pages 4-97 to 4-98) 4 The NRC staff considers the following additional actions below: the past and current operations 5 of the CCS, the possible construction and operation of several new industrial facilities, and 6 climate change.

7 Past and Current Operations of the CCS 8 The CCS supports the operation of Turkey Point Units 3 and 4 as well as Turkey Point Units 1 9 and 2. Although Units 1 and 2 no longer generate electricity, their use of the CCS as a cooling 10 water source has contributed to the changes in the CCS over time. Currently, Units 1 and 2 11 circulate a small amount of water from the CCS to support synchronous condenser mode. 12 However, because Units 1 and 2 no longer produce steam, they do not discharge heated water 13 to the CCS. Section 3.1.3.2, Cooling Canal System, of this SEIS contains a detailed 14 description of the CCS and its operation. Section 3.5.1.4 of this SEIS describes water quality in 15 the CCS and adjacent surface waters as well as the State-required monitoring and mitigation 16 that FPL has undertaken or is in the process of undertaking. As described in these sections, the 17 CCS began experiencing a visible ecosystem shift beginning in 2010 and CCS water quality has 18 deteriorated over the past decade. The average salinity of the CCS has increased, water 19 quality and clarity have degraded, and average surface water temperatures have increased. 20 Seagrass colonies died off, and the subsequent decomposition of dead organic matter released 21 a significant volume of nutrients into the CCS. This facilitated algae blooms, which resulted in 22 high turbidity and further degraded water quality. Whereas the CCS had previously been a 23 seagrass-based ecological system, it now operates as an algal-based, phosphorus-limited 24 system such that the algae life cycle primarily dictates the movement of nutrients in and out of 25 the water column. As discussed in Section 4.7.1.2, Thermal Impacts on Aquatic Organisms 26 (Plants with Once-Through Cooling Systems or Cooling Ponds), a number of species of fish, 27 mollusks, crabs, and seagrasses have disappeared from the CCS in recent years. Thermal 28 stress is one factor that has likely contributed to these disappearances (EAI 2017). 29 FPL is in the process of implementing a Nutrient Management Plan as a requirement of the 30 Florida Department of Environmental Protection consent order. The plan includes an initiative 31 to re-establish seagrass meadows in the CCS. FPL (FPL 2016k) states in its Nutrient 32 Management Plan that a healthy seagrass population growing over approximately 50 percent of 33 the CCS surface water acreage would help balance and sequester the CCSs nutrient content. 34 FPLs plan to re-establish seagrass is described in more detail in Section 3.7.3, Aquatic 35 Resources on the Turkey Point Site, of this SEIS. To date, FPL has identified no clear 36 evidence that the CCS is having an ecological impact on Biscayne Bay or other adjacent 37 surface waters (see Section 3.7.4, Biscayne Bay and Card Sound Semiannual Monitoring, for 38 more details) (E&E 2017). 39 Possible Construction and Operation of New Industrial Facilities 40 Since the NRC published its EIS for the Turkey Point Units 6 and 7 combined licenses in 2016 41 (NRC 2016a), the NRC staff has identified several new industrial facilities that may be 42 constructed and operated in the vicinity of the Turkey Point site. These include a mine, a 43 Miami-Dade County wastewater treatment facility, and the expansion of the Turkey Point ISFSI. 44 Construction (or expansion) of these facilities could result in the temporary or permanent loss of 4-120

1 wetlands and mangrove forests that function as important habitats for early life stages of fish 2 and shellfish. Any permanent losses of aquatic habitats could create habitat fragmentation that 3 would affect ecosystem function and connectivity. Habitat degradation associated with runoff, 4 erosion, and sedimentation during construction could also occur. Additionally, direct mortality of 5 aquatic organisms could result from dredging, wetland and mangrove filling, and other 6 necessary in-water work. Barge traffic associated with delivery of construction supplies and 7 plant components to the site would release pollutants into aquatic habitats and could result in 8 collision-related mortality of larger aquatic organisms, especially turtles and marine mammals. 9 Appropriate permits would mitigate some water quality and aquatic resource impacts by 10 requiring implementation of best management practices or other mitigation during construction 11 and/or operation. The U.S. Army Corps of Engineers or the Florida Department of 12 Environmental Protection would oversee applicable Clean Water Act permitting, including 13 Section 404 permits for dredging and fill activities, Section 401 certification, and Section 402(p) 14 NPDES general stormwater permitting. Once built, operation of these new facilities would likely 15 have minimal to no discernable impacts on aquatic resources. 16 Climate Change 17 Section 4.15.3.2, Climate Change, of this SEIS describes current climate change research and 18 predictions across the contiguous United States as well as specific to the Southeast region of 19 the United States and South Florida. The NRC staff also describes in that section the climate 20 changes expected to occur over the course of the Turkey Point subsequent license renewal 21 term, based on currently available climate model simulations. The primary climate changes that 22 could affect aquatic resources during this timeframe include sea level rise of between 0.5 to 23 1.2 feet (0.15 to 0.37 m) by 2050 and increased storm frequency and intensity. 24 Sea level rise would likely alter the hydrological regime and flow and could result in saltwater 25 intrusion, erosion, and inundation of coastal areas. This would affect the quality, quantity, and 26 spatial distribution of wetlands and mangrove forests. Some of these habitats could become 27 open water, which would reduce available nursery habitat for early life stages of many fish and 28 shellfish. Loss of such habitats could affect the success of ongoing and planned restoration 29 activities in the region. For example, in an analysis of the effects of climate-induced sea level 30 rise on the success of the Biscayne Bay Coastal Wetlands Phase 1 Project, the U.S. Army 31 Corps of Engineers and the South Florida Water Management District estimated that by 2032, 32 approximately 8 percent of the projects ecosystem benefits were likely to be at risk from sea 33 level rise; and by 2062, the projects expected benefits would be diminished by 41 percent 34 (USACE and SFWMD 2011). 35 Storm frequency and duration would also affect aquatic habitats and coastal wetlands and 36 mangroves. If storm intensities and durations increase, these important habitats would be more 37 likely to suffer damage, which could affect hydrological regimes, quality, quantity, and 38 ecosystem function until those habitats recover. Also, with increased storm frequency, these 39 habitats would not have as much time to recover between storms. This would affect the coasts 40 ability to serve as a nursery for fish and shellfish, and this could have cascading population 41 effects over time for those species that are highly dependent upon wetlands and mangroves 42 during early life stages. 43 Another potential climate change-induced stressor on the aquatic environment in the geographic 44 area of interest is the likely use of additional shoreline infrastructure or armoring to protect cities, 45 urban areas, roads, bridges, and agricultural lands from rising sea levels. For instance, in 46 Miami-Dade County, 4,358 km2 (2,708 mi2) of land are at elevations of 5 m (16.4 feet) or less, 4-121

1 and 3,500 km2 (2,174 mi2) of land are 2 m (6.6 feet) or lower (Cela et al. 2010). Shoreline 2 protection efforts in these areas could contribute to habitat fragmentation or interfere with 3 activities designed to restore historic hydrological flow and ecological connections. Dredging 4 and other in-water work associated with shoreline protection infrastructure could result in 5 erosion, sedimentation, and water-quality degradation, although implementation of best 6 management practices and appropriate State and Federal water quality permits would mitigate 7 such effects. Direct injury or mortality of aquatic organisms could also result from these 8 activities. Associated barge traffic and construction equipment use would release pollutants into 9 aquatic habitats and could result in collision-related injury or mortality of larger aquatic 10 organisms, especially turtles and marine mammals. Coupled with continued population growth 11 and urbanization, shoreline protection infrastructure that becomes a permanent part of the 12 coastal landscape could dramatically influence the future of aquatic resources in South Florida. 13 4.16.5 Socioeconomics 14 This section addresses socioeconomic factors that have the potential to be directly or indirectly 15 affected by changes in operations at Turkey Point in addition to the aggregate effects of other 16 past, present, and reasonably foreseeable future actions. The region of influence (ROI) 17 considered in this cumulative analysis is Miami-Dade County, where approximately 85 percent 18 of FPL employees reside (see Table 3-13). This is where the economy, tax base, and 19 infrastructure would most likely be affected because the majority of Turkey Point workers and 20 their families reside, spend their incomes, and use their benefits within Miami-Dade County. As 21 discussed in Section 4.10, Socioeconomics, continued operation of Turkey Point during the 22 subsequent license renewal period would result in SMALL socioeconomic impacts. 23 Past, present, and reasonably foreseeable future actions within the ROI could contribute to 24 cumulative socioeconomic impacts. Relevant actions in this cumulative impact analysis include 25 future planned activities at the Turkey Point site that are unrelated to the proposed action of 26 subsequent license renewal, future urbanization, population increases, transportation 27 infrastructure projects, and other reasonably foreseeable planned offsite activities. Future 28 activities and planned projects in the ROI could bring additional workers and traffic, thus 29 increasing the local population and causing increased traffic on local roads and increased 30 demand for public services. For instance, the construction and operation of the proposed new 31 Turkey Point Units 6 and 7 would have an impact on Miami-Dade Countys economy including 32 impacts from traffic in the immediate vicinity of the Turkey Point site (NRC 2016a). For 33 instance, construction and operation of Turkey Point Units 6 and 7 would result in beneficial 34 socioeconomic impacts including additional wages, tax revenue, and jobs. However, 35 construction and operation of Turkey Point Units 6 and 7 would have adverse impacts on traffic 36 as a result of additional worker and delivery vehicles. Transportation infrastructure projects 37 throughout the region can have beneficial impacts on road quality and infrastructure. 38 Miami-Dade County has experienced increased migration into the county as a result of the 39 continuing effects of Hurricane Maria, which occurred in 2017 (BEBR 2018); increases in 40 population (see Table 3-17) can increase the demand for public services. 41 Changes in climate conditions could impact certain industries such as tourism and recreation, 42 which create jobs and bring significant revenue to regional economies. The U.S. Global 43 Change Research Program reports that climate changes (increases in ambient temperatures 44 and humidity) in the Southeast region of the United States by the year 2050 could create 45 unfavorable summertime outdoor conditions for recreation and tourism (USGCRP 2014). The 46 Everglades and Florida Keys are vulnerable to sea level rise and the effects of climate change 47 impacts on the availability and quality of these resources can result in tourism and revenue loss 4-122

1 (USGCRP 2014). Changes or fluctuations in sea levels, storm surges, erosion, and 2 sedimentation could affect port operations and the economic activities that ports support. In 3 2016, Port Miami contributed approximately $1.3 billion in State and local taxes, supported 4 approximately 324,400 jobs (including direct, indirect, and induced jobs) as a result of cargo and 5 cruise activity, and saw approximately 5.3 million passengers pass through its portals (Port 6 Miami 2017). Additionally, most of the petroleum products consumed by Florida are delivered 7 by barge to ports (USGCRP 2009). Rising sea levels and extreme weather events can damage 8 roads and coastal infrastructure. Property values are also vulnerable to sea level rise; studies 9 indicate that properties in lower elevations sell for less or gain in value more slowly than those 10 located in higher elevations (Keenan et al. 2018, Bernstein et al. 2017). Therefore, climate 11 changes in the ROI could result in adverse socioeconomic and transportation impacts. 12 4.16.6 Historic and Cultural Resources 13 As described in Section 4.9, Historic and Cultural Resources, of this SEIS, historic structures 14 and properties within the area of potential effect are not likely to be adversely affected by 15 subsequent license renewal-related activities since the site area has low historical, cultural and 16 archeological potential, and no ground-disturbing activities or physical changes would occur at 17 Turkey Point during the subsequent license renewal term beyond ongoing maintenance 18 activities. As discussed in Section 4.9, FPL has administrative controls on how to handle 19 unanticipated historical and cultural finds related to potential ground-disturbing activities. 20 Additionally, FPL provides training sessions to Turkey Point staff to ensure that plant personnel 21 consider cultural resources during planned maintenance activities. 22 As described in Section 3.9, Historic and Cultural Resources, of this SEIS, the geographic 23 area considered in this analysis is the area of potential effect associated with the proposed 24 undertaking (subsequent license renewal for Turkey Point Units 3 and 4). In the NRC staffs 25 EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176), Table 7-1 26 summarizes present and reasonably foreseeable future actions that could affect historic 27 properties at the Turkey Point site. Direct impact would occur if historic and cultural resources 28 in the area of potential effect were physically removed or disturbed. For instance, the potential 29 expansion of the ISFSI, the construction of a wastewater treatment facility, and the expansion of 30 roads (transportation projects) could have direct impacts on cultural resources through 31 inadvertent discovery during ground-disturbing activities or result in new above-ground 32 structures that affect the visual area of potential effect. However, reasonable onsite activities 33 conducted on the Turkey Point site could avoid the areas where historic structures, such as the 34 McGregor Smith Cottage, are located. As discussed in Section 4.9.1.3, Findings, based on 35 cultural resource surveys, the Turkey Point site has a low archeological potential. Additionally, 36 FPL has administrative controls in place on how to handle unanticipated historical and cultural 37 finds related to potential ground-disturbing activities. 38 Changes or fluctuations in sea levels because of climate change could result in the disturbance 39 or loss of terrestrial historic and cultural resources from flooding, increased erosion, or 40 inundation of shorelines and surrounding areas. As discussed in Section 4.15.3.2, Climate 41 Change, of this SEIS, sea level is projected to continue to rise. Because of 42 water-level changes, historic and cultural resources could be lost before they could be 43 documented or studied. Rising sea levels, loss of land, and changes in temperature can affect 44 the availability and access to local plant and animal species, thereby impacting the tribal 45 communities who have historically depended on them for food or medicine (USGCRP 2014). 4-123

1 4.16.7 Human Health 2 The NRC and EPA have established radiological dose limits to protect the public and workers 3 from both acute and long-term exposure to radiation and radioactive materials. These dose 4 limits are in 10 CFR Part 20, Standards for Protection Against Radiation, and 40 CFR 5 Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations. As 6 discussed in Section 4.11, Human Health, of this SEIS, the impacts to human health from 7 continued plant operations during the subsequent license renewal term are SMALL. For the 8 purposes of this cumulative impacts analysis, the geographical area considered is the area 9 within a 50-mi (80-km) radius of Turkey Point Units 3 and 4. There are no other nuclear power 10 plants within this 50-mi (80-km) radius. However, that radius does overlap with the 11 50-mi (80-km) radius around proposed Turkey Point Units 6 and 7, which would be sited directly 12 adjacent to Turkey Point Units 3 and 4. As discussed in Section 3.1.4.4, Radioactive Waste 13 Storage, of this SEIS, FPL stores spent nuclear fuel from Units 3 and 4 in a storage pool and in 14 an onsite independent spent fuel storage installation (ISFSI). As a reasonably foreseeable 15 future project, FPL has stated that if the U.S. Department of Energy (DOE) does not take 16 ownership of onsite commercial spent nuclear fuel by 2031, FPL may need to expand the 17 Turkey Point Units 3 and 4 ISFSI storage capability to account for the additional spent nuclear 18 fuel generated during the subsequent license renewal term. 19 Another reasonably foreseeable future action with the potential to contribute to cumulative 20 radiological impacts is the proposed construction and operation of two new nuclear units 21 (Turkey Point Units 6 and 7) at the Turkey Point site. The operation of Turkey Point Units 6 22 and 7 would result in radiological releases and dose impacts to workers and the public, in 23 addition to the impacts resulting from operation of Units 3 and 4. Also, spent fuel would 24 accumulate onsite as a result of the operation of Units 6 and 7, in addition to the spent fuel 25 produced by operation of Units 3 and 4. Sections 5.93, Impacts on Members of the Public, 26 5.94, Occupational Doses to Workers, and 6.1.6, Radiological Wastes, of the NRC staffs EIS 27 for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a) describe 28 those impacts in detail. The NRC staff incorporates those impact analyses from NUREG-2176 29 into this SEIS by reference. 30 EPA regulations in 40 CFR Part 190 limit the dose to members of the public from all sources in 31 the nuclear fuel cycle, including nuclear power plants, fuel fabrication facilities, waste disposal 32 facilities, and transportation of fuel and waste. As discussed in Section 3.1.4.5 in this SEIS, 33 FPL has a radiological environmental monitoring program (REMP) that measures radiation and 34 radioactive materials in the environment from Turkey Point Units 3 and 4, its ISFSI, and all other 35 sources. The NRC staff reviewed the radiological environmental monitoring results for the 36 5-year period from 2013 through 2017 as part of this cumulative impacts assessment. The 37 review of FPLs data showed no indication of an adverse trend in radioactivity levels in the 38 environment from either Turkey Point Units 3 and 4 or the ISFSI. The data showed that there 39 was no measurable impact to the environment from operations at Turkey Point Units 3 and 4. 40 Also, since the proposed Units 6 and 7 would operate under the same State and Federal 41 regulatory standards as Units 3 and 4, there would be no significant impact on the environment 42 from the operation of the proposed Turkey Point Units 6 and 7. 43 In summary, the NRC staff concludes that there is no significant cumulative effect on human 44 health resulting from the proposed action of subsequent license renewal, in combination with 45 cumulative impacts from other sources. The NRC staff bases this conclusion on its review of 46 radiological environmental monitoring program data, radioactive effluent release data, worker 47 dose data; the expectation that Turkey Point Units 3 and 4 would continue to comply with 4-124

1 Federal radiation protection standards during the period of extended operation; and the 2 continued regulation of any future development or actions in the vicinity of the Turkey Point site 3 (including proposed Turkey Point Units 6 and 7) by the NRC and the State of Florida. 4 4.16.8 Environmental Justice 5 The environmental justice cumulative impact analysis evaluates the potential for 6 disproportionately high and adverse human health and environmental effects on minority and 7 low-income populations that could result from past, present, and reasonably foreseeable future 8 actions, including the continued operational effects of Turkey Point Units 3 and 4 during the 9 subsequent license renewal term. The geographic area of interest for this environmental justice 10 cumulative impact analysis is the area within a 50-mi (80-km) radius of Turkey Point. As 11 discussed in Section 4.12, Environmental Justice, of this SEIS, there would be no 12 disproportionately high and adverse impacts on minority and low-income populations from the 13 continued operation of Turkey Point Units 3 and 4 during the subsequent license renewal term. 14 Contributory cumulative effects could come from the other reasonably foreseeable future 15 planned activities at or near the Turkey Point site that are unrelated to the proposed action 16 (subsequent license renewal), as well as from other reasonably foreseeable planned offsite 17 activities. Potential impacts to minority and low-income populations from the construction and 18 operation of proposed reactors Turkey Point Units 6 and 7 would mostly consist of certain 19 localized environmental effects (such as noise, air emissions, traffic, and housing impacts). 20 However, the NRC staff did not identify any disproportionately high and adverse impacts on 21 minority and low-income populations that would occur as a result of the construction and 22 operation of the proposed Turkey Point Units 6 and 7. Transportation projects can have 23 disproportionately high and adverse impacts on minority and low-income populations if the 24 projects bisect any minority or low-income neighborhoods, require the displacement of 25 residences in those neighborhoods, or result in minority or low-income populations 26 disproportionately bearing the effects of the project. 27 Changes in climate conditions could disproportionately affect minority and low-income 28 populations. The U.S. Global Change Research Program (USGCRP 2009) states that people 29 living in poverty are especially at risk from a variety of climate-related health effects. The 30 greatest health burdens are likely to fall on the poor, especially those lacking adequate shelter 31 and access to resources such as air conditioning (USGCRP 2014a). Climate change could 32 affect the availability and access to local plant and animal species, thereby impacting the tribal 33 communities that have historically depended on them for food or medicine (USGCRP 2014). In 34 coastal regions, social and cultural disparities vary regionally and social factors (i.e., low-35 income, minority status, educational achievement) can limit the ability of some people to adapt 36 to changing environmental conditions caused by climate change. This can result in the 37 displacement of vulnerable minority and low-income populations and lead to social disruption. 38 As discussed in Section 4.15.3 of this SEIS, climate change can result in decreases in water 39 availability and water quality as a result of saltwater intrusion into coastal fresh groundwater 40 supplies. This has significant implications for Miami-Dade Countys public water supply systems 41 as well as for private and industrial users of groundwater aquifers. As discussed in Section 42 3.10.3, according to the 2010 Census (USCB 2010a), minorities (race and ethnicity combined) 43 comprised approximately 85 percent of the total population in Miami-Dade County. Therefore, 44 climate change effects on groundwater availability and quality would be disproportionately borne 45 by the minority populations that Miami-Dade County water treatment plants serve. 4-125

1 4.16.9 Waste Management and Pollution Prevention 2 This section describes waste management impacts during the subsequent license renewal term 3 when combined with the aggregate effects of other past, present, and reasonably foreseeable 4 future actions. For the purpose of this cumulative impacts analysis, the NRC staff considered 5 the area within a 50-mi (80-km) radius of Turkey Point. In Section 4.11, Human Health, the 6 NRC staff concluded that the potential human health impacts from Turkey Points waste during 7 the subsequent license renewal term would be SMALL. 8 As discussed in Sections 3.1.4 and 3.1.5 of this SEIS, FPL maintains waste management 9 programs for radioactive and nonradioactive waste generated at Turkey Point Units 3 and 4 and 10 is required to comply with Federal and State permits and other regulatory waste management 11 requirements. The nuclear power plants and other facilities within a 50-mi (80-km) radius of 12 Turkey Point Units 3 and 4 are also required to comply with appropriate NRC, EPA, and State 13 requirements for the management of radioactive and nonradioactive waste. Current waste 14 management activities at Turkey Point Units 3 and 4 would likely remain unchanged during the 15 subsequent license renewal term, and the NRC staff expects that FPL will continue to comply 16 with Federal and State requirements for radioactive and nonradioactive waste. 17 Due to the comprehensive regulatory controls in place for management of radioactive waste, 18 FPLs compliance with these regulations, and its use of licensed treatment and disposal 19 facilities, the impacts of radioactive waste are expected to be SMALL during the subsequent 20 license renewal term. There are no other operating nuclear power plants, fuel-cycle facilities, or 21 radiological waste treatment and disposal facilities within a 50-mi (80-km) radius of Turkey 22 Point. There are industrial, medical, and research facilities in the region that use radioactive 23 materials. The NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses 24 (NUREG-2176, Volume 1, Section 7.8) (NRC 2016a) analyzed the cumulative impacts of 25 managing radioactive waste within a 50-mi (80-km) radius of Turkey Point and determined the 26 cumulative impact to be SMALL. The NRC staff likewise expects that the cumulative impact of 27 radioactive waste management, including the impacts from Turkey Point subsequent license 28 renewal, will be SMALL, given the regulatory controls in place for radioactive waste treatment 29 and disposal, FPLs established waste management practices, and its use of licensed treatment 30 and disposal facilities. 31 32 Continued operation of Turkey Point would have a small impact on nonradioactive waste 33 management facilities given FPLs program for waste management and the availability of 34 treatment and disposal facilities. The NRC staffs EIS for the Turkey Point Units 6 and 7 35 combined licenses (NUREG-2176, Volume 1, Section 7.9) analyzed the cumulative impacts of 36 nonradioactive waste from past, present, and future projects in the geographic area of interest 37 of Miami-Dade County. The EIS concluded that the cumulative impacts from nonradioactive 38 waste management would be SMALL. The NRC staff expects that FPL would continue its 39 programs of waste management and will continue to comply with its permits and waste 40 management regulations. Given that facilities within Miami-Dade County are also required to 41 comply with appropriate EPA and state requirements for the management of hazardous and 42 nonhazardous waste, and that state and local authorities would ensure that FPL continues to 43 comply with regulations governing waste management, the cumulative impact of nonradioactive 44 waste management would be small. 45 46 The additional 20 years of spent nuclear fuel generated during the subsequent license renewal 47 term would be stored in the spent fuel pools until adequately cooled and then transferred to dry 48 storage in an ISFSI. The Turkey Point onsite ISFSI is licensed under the general license 4-126

1 provided to power reactor licensees under 10 CFR 72.210. The NRC oversight of onsite spent 2 fuel storage ensures that the increased volume in onsite storage can be safely accommodated 3 with little environmental effect. No new and significant information has been identified for this 4 issue; therefore, no further analysis is required. The issue was also considered for Turkey 5 Points initial license renewal environmental review, and no new and significant information was 6 found at that time (NRC 2002c). 7 8 In summary, the NRC staff concludes that there would be no significant cumulative effect from 9 the generation of radioactive and nonradioactive waste during the period of extended operation 10 authorized by the proposed action of subsequent license renewal. The NRC staff bases its 11 conclusion on the continued compliance of FPL with Federal and State of Florida requirements 12 for radioactive and nonradioactive waste management and on the expected regulatory 13 compliance of other waste producers in the area. 14 4.16.10 Global Greenhouse Gas Emissions 15 The cumulative impact of a greenhouse gas emission source on climate is global. Greenhouse 16 gas emissions are transported by wind and become well mixed in the atmosphere as a result of 17 their long atmospheric residence time. Therefore, the extent and nature of climate change is 18 not specific to where greenhouse gases are emitted. Due to the global significance of 19 greenhouse gas emissions, a global climate change cumulative impacts analysis inherently 20 considers the entire Earths atmosphere and, therefore, emissions on a global scale (as 21 opposed to simply those emissions on a county, State, or national scale). As discussed in 22 Section 4.15.3.2, Climate Change, of this SEIS, climate change and climate-related 23 environmental changes have been observed on a global level, and climate models indicate that 24 future climate change will depend on present and future global greenhouse gas emissions. 25 Climate models indicate that short-term climate change (through the year 2030) is dependent on 26 past greenhouse gas emissions. Therefore, short-term climate change is projected to occur 27 with or without present and future greenhouse gas emissions from Turkey Point. Beyond the 28 short term, climate models indicate that with continued increases in global greenhouse gas 29 emission rates the Earths average surface temperature will continue to increase and 30 climate-related changes will persist. 31 In April 2018, EPA published its latest Greenhouse Gas Inventory report, Inventory of 32 U.S. Greenhouse Gas Emissions and Sinks: 1990-2016. As the official U.S. inventory of 33 greenhouse gas emissions, this EPA report identifies and quantifies the primary anthropogenic 34 sources (those human caused or produced) and sinks of greenhouse gases. The Greenhouse 35 Gas Inventory is an essential tool for addressing climate change and for participating with the 36 United Nations Framework Convention on Climate Change to compare the relative global 37 contribution of different emission sources and greenhouse gases to climate change. In 2016, 38 the United States emitted 6,511.3 million metric tons (MMT) of CO2eq. From 1990 to 2016, 39 emissions increased by 2.4 percent. However, from 2015 to 2016, emissions decreased by 40 1.9 percent. Across the United States, emissions attributable to electricity generation totaled 41 1,809.3 MMT of CO2eq (EPA 2018c). The Energy Information Administration (EIA) reported that 42 in 2015, Floridas electric power sector was responsible for 107.6 MMT of CO2eq (EIA 2018e). 43 Facilities that emit 25,000 MT CO2eq or more per year are required to annually report their 44 greenhouse gas emissions to the EPA. These facilities are known as direct emitters, and the 45 data are publicly available in EPAs facility-level information on greenhouse gases tool 46 (FLIGHT). In 2016, FLIGHT-identified facilities in Florida emitted a total of 134 MMT of CO2eq. 47 Facilities in Miami-Dade County emitted a total of 4.95 MMT of CO2eq (EPA 2018d). 4-127

1 Section 4.16, Cumulative Impacts, of this SEIS references current and reasonably foreseeable 2 future projects and actions that could contribute to greenhouse gas emissions. Permitting and 3 licensing requirements and other mitigative measures can minimize the impacts of greenhouse 4 gas emissions. For instance, in 2012, EPA issued a final Greenhouse Gas Tailoring Rule 5 (77 FR 41051) to address greenhouse gas emissions from stationary sources under the 6 Clean Air Act permitting requirements. The Greenhouse Gas Tailoring Rule establishes when 7 an emission source will be subject to permitting requirements and control technology to reduce 8 greenhouse gas emissions. 9 EPAs Greenhouse Gas Inventory illustrates the diversity of greenhouse gas sources, which 10 include electricity generation (including fossil fuel combustion and incineration of waste), 11 industrial processes, and agriculture. As presented in Section 4.15.3.1, Greenhouse Gas 12 Emissions and Climate Change, of this SEIS, annual direct greenhouse gas emissions from 13 combustion sources resulting from ancillary operations at Turkey Point range from 14 3,550 to 3,810 MT of CO2eq. In comparing Turkey Points greenhouse gas emission to total 15 U.S. greenhouse gas emissions, emissions from electricity production in Florida, or emissions 16 on a county level, greenhouse gas emissions from Turkey Point are relatively minor. When 17 compared to global emissions, greenhouse gas emissions associated with Turkey Point Units 3 18 and 4 operations are negligible (see Table 4-8 below). Furthermore, as presented in Table 4-7, 19 Direct Greenhouse Gas Emissions from Facility Operations Under the Proposed Action and 20 Alternatives, in Section 4.15.3.1, the natural gas and combination alternatives annual 21 greenhouse gas emissions are higher by several orders of magnitude than those from the 22 continued operation of Turkey Point Units 3 and 4. If Turkey Points generating capacity were to 23 be replaced by other non-nuclear power generating alternatives evaluated in this SEIS, there 24 would be an increase in greenhouse gas emissions. Consequently, the NRC staff concludes 25 that the continued operation of Turkey Point through the subsequent license renewal period (the 26 proposed action) would result in greenhouse gas emissions avoidance. In other words, when 27 compared to alternative baseload replacement power generation sources considered in this 28 SEIS, the continued operations of Turkey Point Units 3 and 4 would have a net, beneficial 29 contribution to greenhouse gas emissions and climate change impacts during the subsequent 30 license renewal term. 31 Table 4-8 Comparison of Greenhouse Gas Emission Inventories Source CO2eq MMT/year Global Emissions (2016) (a) 37,000 U.S. Emissions (2016)(b) 6,511 Florida (2016)(c) 134 Miami-Dade County, Florida (2016)(c) 4.95 Turkey Point (d) 3.8 x 10-3 (a) Carbon dioxide emissions obtained from the Global Carbon Project (GCP 2018) and converted to carbon dioxide equivalents (CO2eq). (b) Source: EPA 2018c. (c) Greenhouse gas emissions account only for direct emitters, those facilities that emit 25,000 MT or more a year (EPA 2018d). (d) Peak emissions over the last 5 years from FPL 2018f. Source: GCP 2018, EPA 2018c, EPA 2018d, FPL 2018f 4-128

1 4.17 Resource Commitments Associated with the Proposed Action 2 This section describes the NRC staffs consideration of potentially unavoidable adverse 3 environmental impacts that could result from the implementation of the proposed action 4 (subsequent license renewal) and alternatives to the proposed action, the relationship between 5 short-term uses of the environment and the maintenance and enhancement of long-term 6 productivity, and the irreversible and irretrievable commitments of resources. 7 4.17.1 Unavoidable Adverse Environmental Impacts 8 Unavoidable adverse environmental impacts are impacts that would occur after implementation 9 of all workable mitigation measures. Carrying out any of the replacement energy alternatives 10 considered in this SEIS, including the proposed action of subsequent license renewal for 11 Turkey Point Units 3 and 4, would result in some unavoidable adverse environmental impacts. 12 Minor unavoidable adverse impacts on air quality would occur due to emission and release of 13 various chemical and radiological constituents from power plant operations. Non-radiological 14 emissions resulting from power plant operations are expected to comply with EPA emissions 15 standards, although the alternative of operating a fossil-fueled power plant in some areas may 16 worsen existing attainment issues. Chemical and radiological emissions would not exceed the 17 national emission standards for hazardous air pollutants. 18 During nuclear power plant operations, workers and members of the public would face 19 unavoidable exposure to minor levels of radiation as well as to hazardous and toxic chemicals. 20 Workers would be exposed to radiation and chemicals associated with routine plant operations 21 and the handling of nuclear fuel and waste material. Workers would have higher levels of 22 exposure than members of the public, but doses would be administratively controlled and would 23 not exceed regulatory standards or administrative control limits. In comparison, the alternatives 24 involving the construction and operation of a non-nuclear power generating facility would also 25 result in unavoidable exposure to hazardous and toxic chemicals to workers and the public. 26 The generation of spent nuclear fuel and waste materialincluding low-level radioactive waste, 27 hazardous waste, and nonhazardous wastewould be unavoidable. Non-nuclear power 28 generating facilities would generate both hazardous and nonhazardous waste. For wastes 29 generated during operations, power plant operators would collect, store, and ship these for 30 suitable treatment, recycling, or disposal in accordance with applicable Federal and State 31 regulations. Due to the costs of handling these materials, the NRC staff expects that power 32 plant operators would optimize all waste management activities and operations in a way that 33 generates the smallest possible amount of waste. 34 4.17.2 Relationship between Short-Term Use of the Environment and 35 Long-Term Productivity 36 The operation of power generating facilities would result in short-term uses of the environment, 37 as described in Chapter 4, Environmental Consequences and Mitigating Actions, of this SEIS. 38 Short term is the period of time that continued power generating activities take place. 39 Power plant operations require short-term use of the environment and commitment of resources 40 (e.g., land and energy), indefinitely or permanently. Certain short-term resource commitments 41 are substantially greater under most energy alternatives, including subsequent license renewal, 42 than under the no-action alternative because of the continued generation of electrical power and 4-129

1 the continued use of generating sites and associated infrastructure. During operations, all 2 energy alternatives entail similar relationships between local short-term uses of the environment 3 and the maintenance and enhancement of long-term productivity. 4 Air emissions from nuclear power plant operations introduce small amounts of radiological and 5 non-radiological emissions to the region around the plant site. Over time, these emissions 6 would result in increased concentrations and exposure, but the NRC staff does not expect that 7 these emissions would impact air quality or radiation exposure to the extent that they would 8 impair public health and long-term productivity of the environment. 9 Continued employment, expenditures, and tax revenues generated during power plant 10 operations directly benefit local, regional, and State economies over the short term. Local 11 governments investing project-generated tax revenues into infrastructure and other required 12 services could enhance economic productivity over the long term. 13 The management and disposal of spent nuclear fuel, low-level radioactive waste, hazardous 14 waste, and nonhazardous waste requires an increase in energy and consumes space at 15 treatment, storage, or disposal facilities. Regardless of the location, the use of land to meet 16 waste disposal needs would reduce the long-term productivity of the land. 17 Power plant facilities are committed to electricity production over the short term. After 18 decommissioning these facilities and restoring the area, the land could be available for other 19 future productive uses. 20 4.17.3 Irreversible and Irretrievable Commitment of Resources 21 Resource commitments are irreversible when primary or secondary impacts limit the future 22 options for a resource. For example, the consumption or loss of nonrenewable resources are 23 irreversible. An irretrievable commitment refers to the use or consumption of resources for a 24 period of time (e.g., for the duration of the action under consideration) that are neither 25 renewable nor recoverable for future use. Irreversible and irretrievable commitments of 26 resources for electrical power generation include the commitment of land, water, energy, raw 27 materials, and other natural and man-made resources required for power plant operations. In 28 general, the commitments of capital, energy, labor, and material resources are also irreversible. 29 The implementation of any of the replacement energy alternatives considered in this SEIS 30 would entail the irreversible and irretrievable commitments of energy, water, chemicals, andin 31 some casesfossil fuels. These resources would be committed during the subsequent license 32 renewal term and over the entire life cycle of the power plant, and they would be unrecoverable. 33 Energy expended would be in the form of fuel for equipment, vehicles, and power plant 34 operations and electricity for equipment and facility operations. Electricity and fuel would be 35 purchased from offsite commercial sources. Water would be obtained from existing water 36 supply systems. These resources are readily available, and the NRC staff does not expect that 37 the required amounts would deplete available supplies or exceed available system capacities. 4-130

1 5 CONCLUSION 2 This draft supplemental environmental impact statement (SEIS) contains the NRC staffs 3 environmental review of Florida Power & Light Companys (FPLs) application for subsequent 4 renewed operating licenses for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey 5 Point, or Turkey Point Units 3 and 4), as required by Title 10 of the Code of Federal Regulations 6 (10 CFR) Part 51, Environmental Protection Regulations for Domestic Licensing and Related 7 Regulatory Functions. The regulations at 10 CFR Part 51 implement the National 8 Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.). This chapter briefly 9 summarizes the environmental impacts of Turkey Point subsequent license renewal, lists and 10 compares the environmental impacts of alternatives to subsequent license renewal, and 11 presents the NRC staffs conclusions and recommendation. 12 5.1 Environmental Impacts of Subsequent License Renewal 13 After reviewing new and potentially significant information with respect to two generic 14 (Category 1) environmental issues in this SEIS, the NRC staff concluded that issuing 15 subsequent renewed licenses for Turkey Point would not have impacts beyond those discussed 16 in the NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 17 Plants (NRC 2013a). 18 After reviewing the site-specific (Category 2) environmental issues and one new uncategorized 19 issue in this SEIS, the NRC staff concluded that issuing subsequent renewed licenses for 20 Turkey Point would have SMALL impacts for the Category 2 issues and the new uncategorized 21 issue applicable to subsequent license renewal at Turkey Point, with two exceptions: (1) for 22 groundwater resources, the impact would be SMALL to MODERATE, and (2) for aquatic 23 resources, the impact would be SMALL to MODERATE. The NRC staff considered mitigation 24 measures for each issue, as applicable. The NRC staff concluded that no additional mitigation 25 measure is warranted. 26 5.2 Comparison of Alternatives 27 In Chapter 4, Environmental Consequences and Mitigating Actions, of this SEIS, the NRC staff 28 considered the following alternatives to issuing subsequent renewed licenses to Turkey Point: 29

• no-action alternative 30
• new nuclear alternative 31
• natural gas combined-cycle alternative 32
• combination alternative of natural gas combined-cycle and solar photovoltaic 33 The staff also evaluated a cooling water system alternative using mechanical draft cooling 34 towers instead of the Cooling Canal System (CCS) for cooling the Turkey Point Units 3 and 4 35 reactors.

36 Based on the evaluation presented in this draft SEIS, the NRC staff concludes that the 37 environmentally preferred alternative is the proposed action of subsequent license renewal for 38 Turkey Point Units 3 and 4. As shown in Table 2-2, Summary of Environmental Impacts of the 39 Proposed Action and Alternatives, all reasonable power-generation alternatives have impacts 40 in at least two resource areas that are greater than the impacts of subsequent license renewal, 41 in addition to the environmental impacts inherent with new construction projects. 5-1

1 5.3 Preliminary Recommendation 2 The NRC staffs preliminary recommendation is that the adverse environmental impacts of 3 subsequent license renewal for Turkey Point are not so great that preserving the option of 4 subsequent license renewal for energy-planning decisionmakers would be unreasonable. The 5 NRC staff bases this recommendation on the following: 6

• the analysis and findings in NUREG-1437, Generic Environmental Impact Statement 7 for License Renewal of Nuclear Plants 8
• the environmental report submitted by FPL 9
• the NRC staffs consultation with Federal, State, Tribal, and local government agencies 10
• the NRC staffs independent environmental review 11
• the NRC staffs consideration of public comments 5-2

1 6 REFERENCES 2 10 CFR Part 2. Code of Federal Regulations, Title 10, Energy, Part 2, Agency Rules of 3 Practice and Procedure. 4 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, Standards for 5 Protection against Radiation. 6 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic Licensing of 7 Production and Utilization Facilities. 8 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental 9 Protection Regulations for Domestic Licensing and Related Regulatory Functions. 10 10 CFR Part 54. Code of Federal Regulations, Title 10, Energy, Part 54, Requirements for 11 Renewal of Operating Licenses for Nuclear Power Plants. 12 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, Reactor Site 13 Criteria. 14 36 CFR Part 60. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 15 Part 60, National Register of Historic Places. 16 36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property, 17 Part 800, Protection of Historic Properties. 18 40 CFR Part 50. Code of Federal Regulations, Title 40, Protection of Environment, Part 50, 19 National Primary and Secondary Ambient Air Quality Standards. 20 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51, 21 Requirements for Preparation, Adoption, and Submittal of Implementation Plans. 22 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60, 23 Standards of Performance for New Stationary Sources. 24 40 CFR Part 63. Code of Federal Regulations, Title 40, Protection of Environment, Part 63, 25 National Emission Standards for Hazardous Air Pollutants for Source Categories. 26 40 CFR Part 81. Code of Federal Regulations. Title 40, Protection of Environment, Part 81, 27 Designation of Areas for Air Quality Planning Purposes. 28 40 CFR Part 110. Code of Federal Regulations, Title 40, Protection of Environment, Part 110, 29 Discharge of Oil. 30 40 CFR Part 112. Code of Federal Regulations, Title 40, Protection of Environment, Part 112. 31 Oil Pollution Prevention. 32 40 CFR Part 125. Code of Federal Regulations, Title 40, Protection of Environment, Part 125, 33 Criteria and Standards for the National Pollutant Discharge Elimination System. 34 40 CFR Part 131. Code of Federal Regulations, Title 40, Protection of Environment, Part 131, 35 Water Quality Standards. 36 40 CFR Part 141. Code of Federal Regulations, Title 40, Protection of Environment, Part 141, 37 National Primary Drinking Water Regulations. 38 40 CFR Part 143. Code of Federal Regulations, Title 40, Protection of Environment, Part 143, 39 National Secondary Drinking Water Regulations. 6-1

1 40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190, 2 Environmental Radiation Protection Standards for Nuclear Power Operations. 3 50 CFR Part 17. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 17, 4 Endangered and Threatened Wildlife and Plants. 5 50 CFR Part 402. Code of Federal Regulations, Title 50, Wildlife and Fisheries, Part 402, 6 Interagency Cooperation - Endangered Species Act of 1973, as Amended. 7 51 FR 19926. U.S. Fish and Wildlife Service and National Marine Fisheries Service. 8 Interagency cooperationEndangered Species Act of 1973, as amended; final rule. Federal 9 Register 51(106):19926-19963. June 3, 1986. 10 53 FR 43950. U.S. Nuclear Regulatory Commission. Memorandum of Understanding between 11 the Nuclear Regulatory Commission and the Occupational Safety and Health Administration; 12 Worker Protection at NRC-licensed Facilities. Federal Register 53(210):43950-43952. 13 October 31, 1988. 14 59 FR 7629. Executive Order No. 12898. Federal actions to address environmental justice in 15 minority populations and low-income populations. Federal Register 59(32):7629-7634. 16 February 11, 1994. 17 61 FR 28467. U.S. Nuclear Regulatory Commission. Environmental review for renewal of 18 nuclear power plant operating licenses. Federal Register 61(109):28467-28481. 19 June 5, 1996. 20 69 FR 52040. U.S. Nuclear Regulatory Commission. Policy statement on the treatment of 21 environmental justice matters in NRC regulatory and licensing actions. Federal Register 22 69(163):52040-52048. August 24, 2004. 23 72 FR 71083. U.S. Nuclear Regulatory Commission. Sally Shaw; Denial of Petition for 24 Rulemaking. Federal Register 72(240):71083-71086. December 14, 2007. 25 74 FR 13926. U.S. Nuclear Regulatory Commission. Power reactor security requirements. 26 Federal Register 74(58):13926-13993. March 27, 2009. 27 74 FR 66496. U.S. Environmental Protection Agency. Endangerment and cause or contribute 28 findings for greenhouse gases under section 202(a) of the Clean Air Act. Federal Register 29 74(239):66496-66546. December 15, 2009. 30 75 FR 9282. Fish and Wildlife Service, Interior. General Provisions; Revised. List of Migratory 31 Birds; final rule. Federal Register 75(39):9282-9314. March 1, 2010. 32 77 FR 15916. National Marine Fisheries Service. Fisheries of the Caribbean, Gulf of Mexico, 33 and South Atlantic; Comprehensive annual catch limit amendment for the South Atlantic. 34 Federal Register 77(52):15916-15932. March 16, 2012. 35 77 FR 41051. U.S. Environmental Protection Agency. Prevention of significant deterioration 36 and Title V greenhouse gas tailoring rule step 3 and GHG plantwide applicability limits. Federal 37 Register 77(134):41051-41075. July 12, 2012. 38 78 FR 63796. U.S. Fish and Wildlife Service. Endangered and Threatened Wildlife and Plants; 39 Determination of Endangered Status for Chromolaena frustrata (Cape Sable Thoroughwort), 40 Consolea corallicola (Florida Semaphore Cactus), and Harrisia aboriginum (Aboriginal Prickly-41 Apple); Final Rule. Federal Register 78(206):63797-63821. October 24, 2013. 42 79 FR 44464. U.S. Nuclear Regulatory Commission. Environmental assessment and final 43 finding of no significant impact; issuance. Federal Register 79(147):44464-44470. 44 July 31, 2014. 6-2

1 80 FR 76324. U.S. Nuclear Regulatory Commission. Atomic Safety and Licensing Board; in 2 the Matter of Florida Power & Light Company (Turkey Point Nuclear Generating, Units 3 3 and 4). Federal Register 80(235):76324-76325. December 8, 2015. 4 81 FR 32249. National Marine Fisheries Service. Fisheries of the Caribbean, Gulf of Mexico, 5 and South Atlantic; Snapper-grouper fishery off the southern Atlantic states; Amendment 35. 6 Federal Register 81(99):32249-32255. May 23, 2016. 7 82 FR 46691. U.S. Fish and Wildlife Service. Endangered and Threatened Wildlife and Plants; 8 Endangered Species Status for Dalea carthagenensis var. floridana (Florida Prairie-clover), and 9 Threatened Species Status for Sideroxylon reclinatum ssp. austrofloridense (Everglades Bully), 10 Digitaria pauciflora (Florida Pineland Crabgrass), and Chamaesyce deltoidea ssp. pinetorum 11 (Pineland Sandmat); Final Rule. Federal Register 82(193):46691-46715. October 6, 2017. 12 83 FR 19304. U.S. Nuclear Regulatory Commission. License renewal application; opportunity 13 to request a hearing and to petition for leave to intervene. Federal 14 Register 83(85):19304-19306. May 2, 2018. 15 83 FR 23726. U.S. Nuclear Regulatory Commission. Intent to conduct scoping process and 16 preparing environmental impact statement; public meeting and request for comment. Federal 17 Register 83(99):23726-23728. May 22, 2018. 18 Arnold T.M., Zimmerman R.C., Engelhardt K.A.M., Stevenson J.C. 2017. Twenty-first century 19 climate change and submerged aquatic vegetation in a temperate estuary: the case of 20 Chesapeake Bay. Ecosystem Heath and Sustainability, 3(7):1353283. Available at 21 <https://doi.org/10.1080/20964129.2017.1353283> (accessed July 24, 2018). 22 [Audubon] Audubon Florida. 2016. Restoring Freshwater Flows to Biscayne Bay: Biscayne 23 Bay Coastal Wetlands Phase 1. April 2016. Available at 24 http://fl.audubon.org/sites/g/files/amh666/f/audubon_biscaynebaycoastalwetlands_bbcw_factsh 25 eet_august2016.pdf (accessed July 9, 2018). 26 Bald and Golden Eagle Protection Act of 1940, as amended. 16 U.S.C. Sections 668-668c. 27 Barlow P.M. 2003. Ground Water in Freshwater-Saltwater Environments of the Atlantic 28 Coast. Denver, CO: U.S. Geological Survey Circular 1262. 121 p. 2003. Available at 29 <https://pubs.usgs.gov/circ/2003/circ1262/pdf/circ1262.pdf> (accessed July 7, 2018). 30 [BEBR] Bureau of Economic and Business Research. 2017. Projections of Florida Population 31 by County, 2020-2045, with Estimates for 2016. Bureau of Economic and Business 32 Research, 50(177). April 2017. Available at <https://www.bebr.ufl.edu/population/population-33 data/projections-florida-population-county-2020-2045-estimates-2016> (accessed 34 April 30, 2018). 35 [BEBR] Bureau of Economic and Business Research. 2018. Growth of the Puerto Rican 36 Population in Florida and on the U.S. Mainland. Available at: 37 <https://www.bebr.ufl.edu/population/website-article/growth-puerto-rican-population-florida-and-38 us-mainland> (accessed September 12, 2018). 39 [Bechtel] Bechtel Power Corporation. 2014. Addendum to the Independent Third-Party Final 40 Technologies Assessment for the Alternative Cooling Technologies or Modifications to the 41 Existing Once-Through Cooling System for Diablo Canyon Power Plant Addressing the 42 Installation of Saltwater Cooling Towers in the South Parking Lot. Report 43 No. 25762-000-30H-G01G-00001. September 17, 2014. Available at 44 <http://www.swrcb.ca.gov/water_issues/programs/ocean/cwa316/rcnfpp/docs/ 45 bpc091714_4.pdf> (accessed August 9, 2018). 6-3

1 [BEIR] National Research Council. 2006. Health Risks from Exposure to Low Levels of 2 Ionizing Radiation, BEIR VII. Committee on the Biological Effects of Ionizing Radiation (BEIR). 3 National Academies Press, Washington, D.C. DOI: 10.17226/11340. 4 Bennett W.A., Beitinger T.L. 1997. Temperature tolerance of the sheepshead minnow, 5 Cyprinodon variegatus. Copeia, 1997(1):77-87. 6 Bernstein A., Gustafson M., Lewis R. 2018. Disaster on the Horizon: The Price Effect of Sea 7 Level Rise. Journal of Financial Economics, Forthcoming. Available at SSRN: 8 https://ssrn.com/abstract=3073842 (accessed August 9, 2018). 9 [BOEM] Bureau of Ocean Energy Management. undated. Ocean Wave Energy. Available at 10 <https://www.boem.gov/Renewable-Energy-Program/Renewable-Energy-Guide/Ocean-Wave-11 Energy.aspx> (accessed September 12, 2018). 12 Broward County. 2017. Fiscal Year 2017 Adopted Operating Budget. Available at: 13 <http://www.broward.org/Budget/Archives/Pages/FY2017AdoptedOperatingBudget.aspx> 14 (accessed August 6, 2018). 15 Brown M., Cohen M., Bardi E., and Ingwersen W. 2006. Species diversity in the Florida 16 Everglades, USA: A systems approach to calculating biodiversity. Aquatic Sciences. 17 68(3):254-277. January 2006. Available at 18 <https://www.researchgate.net/publication/226979308_Species_diversity_in_the_Florida_Evergl 19 ades_USA_A_systems_approach_to_calculating_biodiversity> (accessed on August 28, 2018). 20 Cela M., Hulsey J., Titus J.G. 2010. South Florida. Chapter 8 in The Likelihood of Shore 21 Protection along the Atlantic Coast of the United States. Volume 2: New England and the 22 Southeast. U.S. Environmental Protection Agency, Washington, D.C. ADAMS Accession 23 No ML12269A197. 24 [CEQ] Council on Environmental Quality. 1997. Environmental Justice: Guidance under the 25 National Environmental Policy Act. Washington, DC. December 10, 1997. Available at 26 <https://www.epa.gov/environmentaljustice/ceq-environmental-justice-guidance-under-national-27 environmental-policy-act> (accessed July 8, 2018). 28 Chervinski J. 1983. Salinity tolerance of the mosquitofish, Gambusia affinis. Journal of Fish 29 Biology, 22(1):9-11. DOI: 10.1111/j.1095-8649.1983.tb04720.x. 30 Childers D., Iwaniec D., Rondeau D., Rubio G., Verdon E., and Madden C.J. 2006. 31 Responses of sawgrass and spikerush to variation in hydrologic drivers and salinity in Southern 32 Everglades marshes. Hydrobiologia, 569(1):273-292. October 2006. 33 Chin, D.A. 2016. The Cooling-Canal System at the FPL Turkey Point Power Station. Final 34 Report. May 2016. Available at <http://www.miamidade.gov/mayor/library/memos-and-35 reports/2016/05/05.12.16-Final-Report-on-the-Cooling-Canal-Study-at-the-Florida-Power-and-36 Light-Turkey-Point-Power-Plant-Directive-151025.pdf> (accessed August 21, 2018). 37 Clean Air Act of 1970. 42 U.S.C. 7401 et seq. 38 Coastal Zone Management Act of 1972. 16 U.S.C. 1451 et seq. 39 Conner A.M., Francfort J.E., Rinehart B.N. 1998. U.S. Hydropower Resource Assessment, 40 Final Report. Idaho Falls, Idaho: Idaho National Engineering and Environmental Laboratory. 41 DOE/ID 10430.2. December 1998. Available at 42 <https://www1.eere.energy.gov/wind/pdfs/doewater-10430.pdf> (accessed 43 September 14, 2018). 6-4

1 Costa T.M.M., Soares-Gomes A. 2015. Secondary production of the fiddler crab Uca rapax 2 from mangrove areas under anthropogenic eutrophication in the Western Atlantic, Brazil. 3 Marine Pollution Bulletin, 101(2):533-538. DOI: 10.1016/j.marpolbul.2015.10.061. 4 CSX. 2018. CSX System Map. Available at 5 <https://www.csx.com/index.cfm/customers/maps/csx-system-map/> (accessed June 11, 2018). 6 [DERM] Department of Regulatory and Economic Resources, Division of Environmental 7 Resources Management. 2018. Letter from L. Hefty, Division Director, DERM, to M. Ma, 8 Director Program Management Announcements and Editing Branch, NRC. 9

Subject:

Environmental Impact Statement Scoping Comments Regarding Florida Power and 10 Light's Subsequent License Renewal Application for Turkey Point Units 3 and 4, Docket 11 Number NRC 2018-0101. June 21, 2018. ADAMS Accession No. ML18180A175. 12 [DHR] Florida Division of Historic Resources. 2018. Response to Request for Scoping 13 Comments Concerning the Environmental Review of Turkey Point Nuclear Plant, Units 3 and 4 14 Subsequent License Renewal Application. ADAMS Accession No. ML18183A482. 15 Diem J.E., Stauber C.E., Rothernberg R. 2017. Heat in the southeastern United States: 16 Characteristics, trends, and potential health impact. PLOS ONE, 12(5):e0177937. Available at 17 <http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0177937#sec009> (accessed 18 September 21, 2018). 19 [DOA] Department of the Army. 2014. Procedures to Evaluate Sea Level Change: Impacts, 20 Responses, and Adaptation. Technical Letter No. 1100-2-1. Washington, DC: U.S. Army 21 Corps of Engineers. June 30, 2014. Available at 22 <http://www.publications.usace.army.mil/Portals/76/Publications/EngineerTechnicalLetters/ETL 23 _1100-2-1.pdf> (accessed August 24, 2018). 24 [DOE] U.S. Department of Energy. 2010. Kemper County Integrated Gasification Combined 25 Cycle (IGCC) Project, Final Environmental Impact Statement. Washington, DC. 26 DOE/EIS-0409, Volume 1. May 2010. Available at 27 <https://www.energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/EIS-0409-FEIS-28 01-2010.pdf> (accessed September 13, 2018). 29 [DOE] U.S. Department of Energy. 2011. 2010 Solar Technologies Market Report. 30 Washington, DC. November 2011. Available at <https://www.nrel.gov/docs/fy12osti/51847.pdf> 31 (accessed July 2, 2018). 32 [DOE] U.S. Department of Energy. 2013a. Geothermal Basics. Washington, DC. 33 August 14, 2013. Available at <https://www.energy.gov/eere/geothermal/geothermal-basics> 34 (accessed September 6, 2018). 35 [DOE] U.S. Department of Energy. 2013b. Fuel Cell Basics. Washington, DC. 36 August 14, 2013. Available at <https://www.energy.gov/eere/fuelcells/fuel-cell-basics> 37 (accessed September 6, 2018). 38 [DOE] U.S. Department of Energy. 2018a. 2017 Offshore Wind Technologies Market Update. 39 Washington, DC. September 2018. Available at 40 <https://www.energy.gov/sites/prod/files/2018/09/f55/71709_V4.pdf> (accessed 41 September 13, 2018). 42 [DOE] U.S. Department of Energy. 2018b. Advanced Small Modular Reactors. Available at 43 <http://energy.gov/ne/nuclear-reactor-technologies/small-modular-nuclear-reactors> (accessed 44 September 13, 2018). 6-5

1 [DOE] U.S. Department of Energy. 2018c. Marine and Hydrokinetic Resource Assessment 2 and Characterization. Available at <https://www.energy.gov/eere/water/marine-and-3 hydrokinetic-resource-assessment-and-characterization> (accessed September 20, 2018). 4 [DOE] U.S. Department of Energy. 2018d. WINDExchange: U.S. Installed Wind Power 5 Capacity - Q2 2018. Available at <https://windexchange.energy.gov/maps-data/321> 6 (accessed September 13, 2018). 7 [E&E] Ecology and Environment, Inc. 2017. Turkey Point Plant Annual Monitoring Report. 8 Prepared for Florida Power & Light Company. September 2017. 415 p. Available at 9 <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-documents#> (search facility/site ID: 10 FL0001562, document date: 9/28/2017) (accessed June 13, 2018). 11 [EAI] Ecological Associates, Inc. 2017. FPL Turkey Point Cooling Canal System 12 Characterization Study. Prepared for Florida Power and Light Company. 55 p. ADAMS 13 Accession No. ML18247A514. In: FPL 2018h, Attachment 5, Enclosure 5. ADAMS Accession 14 No. ML18247A509. 15 [EB] Encyclopdia Britannica. 2018. Seawater: Salinity Distribution. Available at 16 <https://www.britannica.com/science/seawater/Salinity-distribution> (accessed July 10, 2018). 17 [EIA] U.S. Energy Information Administration. 2013a. Annual Energy Outlook 2013 with 18 Projections to 2040. DOE/EIA-0383 (2013). Washington, DC. April 2013. 244 p. Available at 19 <http://www.eia.gov/forecasts/aeo/pdf/0383(2013).pdf> (accessed June 29, 2018). 20 [EIA] U.S. Energy Information Administration. 2013b. Updated Capital Cost Estimates for 21 Utility Scale Electricity Generating Plants. Washington, DC. April 2013. 201 p. Available at 22 <http://www.eia.gov/forecasts/capitalcost/pdf/updated_capcost.pdf> 23 (accessed August 28, 2018). 24 [EIA] U.S. Energy Information Administration. 2015a. Levelized Cost and Levelized Avoided 25 Cost of New Generation Resources in the Annual Energy Outlook 2015. Washington, DC. 26 June 2015. 12 p. Available at 27 <https://www.eia.gov/outlooks/archive/aeo15/pdf/electricity_generation_2015.pdf> (accessed 28 August 7, 2018). 29 [EIA] U.S. Energy Information Administration. 2015b. Today in EnergyFirst offshore wind 30 farm in the United States begins construction. August 14, 2015. Available at 31 <http://www.eia.gov/todayinenergy/detail.cfm?id=22512> (accessed August 30, 2018). 32 [EIA] U.S. Energy Information Administration. 2015c. Annual Energy Outlook 2015 with 33 Projections to 2040. DOE/EIA-0383 (2015). Washington, DC. April 2015. 154 p. Available at 34 <http://www.eia.gov/forecasts/aeo/pdf/0383(2015).pdf> (accessed August 31, 2018). 35 [EIA] U.S. Energy Information Administration. 2016a. Annual Energy Outlook 2016 with 36 Projections to 2040. DOE/EIA-0383 (2016). Washington, DC. August 2016. 256 p. Available 37 at <http://www.eia.gov/outlooks/aeo/pdf/0383(2016).pdf> (accessed May 29, 2018). 38 [EIA] U.S. Energy Information Administration. 2016b. Today in EnergySouthern states lead 39 growth in biomass electricity generation. May 25, 2016. Available at 40 <https://www.eia.gov/todayinenergy/detail.php?id=26392> (accessed June 26, 2018). 41 [EIA] U.S. Energy Information Administration. 2016c. Today in EnergyCalifornia has nearly 42 half of the nations solar electricity generating capacity. February 5, 2016. Available at 43 <https://www.eia.gov/todayinenergy/detail.php?id=24852#> (accessed September 20, 2018). 6-6

1 [EIA] U.S. Energy Information Administration. 2016d. Capital Cost Estimated for Utility Scale 2 Electricity Generating Plants. Washington, DC. November 2016. 141 p. Available at: 3 <https://www.eia.gov/analysis/studies/powerplants/capitalcost/pdf/capcost_assumption.pdf> 4 (accessed August 3, 2018). 5 [EIA] U.S. Energy Information Administration. 2017a. Florida State Profile and Energy 6 Estimates - Analysis. Washington, DC. Last updated: September 21, 2017. Available at 7 <https://www.eia.gov/state/analysis.php?sid=FL> (accessed May 4, 2018). 8 [EIA] U.S. Energy Information Administration. 2017b. Electric Power Annual 2016, Table 1.2. 9 Summary Statistics for the United States, 2006-2016. Utility Scale Capacity: Solar 10 Photovoltaic. Washington, DC. December 2017; Revised March 2018. 231 p. Available at 11 <https://www.eia.gov/electricity/annual/> (accessed September 20, 2018). 12 [EIA] U.S. Energy Information Administration. 2017c. Today in EnergyUtility-scale solar has 13 grown rapidly over the past five years. May 4, 2017. Available at 14 <https://www.eia.gov/todayinenergy/detail.php?id=31072> (accessed September 20, 2018). 15 [EIA] U.S. Energy Information Administration. 2017d. Florida State Energy ProfileFlorida 16 Quick Facts. Last updated: September 21, 2017. Available at 17 <https://www.eia.gov/state/print.php?sid=FL> (accessed August 28, 2018). 18 [EIA] U.S. Energy Information Administration. 2017e. Geothermal ExplainedState Rankings 19 for Geothermal Electricity Generation, 2016. Last updated: May 18, 2017. Available at 20 <https://www.eia.gov/energyexplained/index.cfm?page=geothermal_use> (accessed 21 September 6, 2018). 22 [EIA] U.S. Energy Information Administration. 2017f. Electric Power Annual 2017, Table 8.4. 23 Average power plant operating expenses for major U.S. investor-owned electric utilities, 24 2007-2017. Washington, DC. October 2018. 239 p. Available at 25 <https://www.eia.gov/electricity/annual/> (accessed August 3, 2018). 26 [EIA] U.S. Energy Information Administration. 2018a. State Electricity ProfilesFlorida 27 Table 4. Electric power industry capability by primary energy source, 1990 through 2016. 28 January 25, 2018. Available at <https://www.eia.gov/electricity/state/Florida/> (accessed 29 September 20, 2018). 30 [EIA] U.S. Energy Information Administration. 2018b. State Electricity ProfilesFlorida 31 Table 5. Electric power industry generation by primary energy source, 1990 through 2016. 32 January 25, 2018. Available at <https://www.eia.gov/electricity/state/Florida/> (accessed 33 September 20, 2018). 34 [EIA] U.S. Energy Information Administration. 2018c. Today in EnergyFuture U.S. electricity 35 generation mix will depend largely on natural gas prices. February 7, 2018. Available at 36 <https://www.eia.gov/todayinenergy/detail.php?id=34852> (accessed August 30, 2018). 37 [EIA] U.S. Energy Information Administration. 2018d. Annual Energy Outlook 2018Table: 38 Electricity Supply, Disposition, Prices, and EmissionsElectricity Reference Case. 39 Available at <https://www.eia.gov/outlooks/aeo/data/browser/#/?id=8-AEO2018&region=0-40 0&cases=ref2018&start=2016&end=2050&f=A&linechart=~~ref2018-d121317a.44 41 AEO2018~ref2018-d121317a.42-8-AEO2018&ctype=linechart&sourcekey=0> 42 (accessed August 30, 2018). 43 [EIA] U.S. Energy Information Administration. 2018e. Energy-Related Carbon Dioxide 44 Emissions by State, 2000-2015. Washington, DC. January 2018. 30 p. Available at 45 <https://www.eia.gov/environment/emissions/state/analysis/pdf/stateanalysis.pdf> (accessed 46 August 24, 2018). 6-7

1 Endangered Species Act of 1973, as amended. 16 U.S.C. 1531 et seq. 2 [Energy Daily] IHS The Energy Daily. 2016. First U.S. Offshore Wind Farm Delivers Power to 3 Grid. The Energy Daily. Volume 44, Number 238. December 13, 2016. Available at 4 <http://www.theenergydaily.com> (accessed September 13, 2018). 5 [Energy Daily] IHS The Energy Daily. 2017. Southern Stops Work on Kempers Lignite 6 Gasification Technology. The Energy Daily. Volume 45, Number 124. June 29, 2017. 7 Available at <http://www.theenergydaily.com> (accessed September 13, 2018). 8 [EPA] U.S. Environmental Protection Agency. 2002. EPA Facts About Tritium. 9 Washington, DC. July 2002. 2 p. Available at 10 <http://www.trainex.org/web_courses/tritium/reference_pages/tritium%20EPA.pdf> (accessed 11 July 10, 2018). 12 [EPA] U.S. Environmental Protection Agency. 2009a. Assessment of the Impacts of Global 13 Change on Regional U.S. Air Quality: A Synthesis of Climate Change Impacts on Ground-Level 14 Ozone. EPA/600/R-07/094F. Washington, DC. April 2009. 131 p. Available at 15 <https://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=203459> (accessed 16 September 21, 2018). 17 [EPA] U.S. Environmental Protection Agency. 2009b. Endangerment and Cause or Contribute 18 Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act. Last updated: 19 July 11, 2017. Available at <https://www.epa.gov/ghgemissions/endangerment-and-cause-or-20 contribute-findings-greenhouse-gases-under-section-202a-clean> (accessed 21 September 21, 2018). 22 [EPA] U.S. Environmental Protection Agency. 2014a. Municipal Solid Waste: Energy 23 Recovery from Waste. Last updated: March 29, 2016. Available at 24 <https://archive.epa.gov/epawaste/nonhaz/municipal/web/html/index-11.html> (accessed 25 March 27, 2019). 26 [EPA] U.S. Environmental Protection Agency. 2014b. Municipal Solid Waste: Basic 27 Information about Energy Recovery from Waste. Last updated: March 29, 2016. Available at 28 <https://archive.epa.gov/epawaste/nonhaz/municipal/web/html/basic.html> (accessed 29 March 27, 2019). 30 [EPA] U.S. Environmental Protection Agency. 2014c. Numeric Nutrient Criteria for the State of 31 Florida: Withdrawing the Federal Actions. EPA-820-F-14-006. September 2014. Available at 32 <https://www.epa.gov/sites/production/files/2015-07/documents/factsheet-withdrawl-2014.pdf> 33 (accessed July 3, 2018). 34 [EPA] U.S. Environmental Protection Agency. 2014d. Greenhouse Gas Inventory Guidance: 35 Direct Fugitive Emissions from Refrigeration, Air Conditioning, Fire Suppression, and Industrial 36 Gases. Washington, DC. November 2014. 20 p. Available at 37 <https://www.epa.gov/sites/production/files/2015-07/documents/fugitiveemissions.pdf> 38 (accessed August 24, 2018). 39 [EPA] U.S. Environmental Protection Agency. 2015. Mercury and Air Toxics Standards 40 (MATS). Last updated: February 13, 2018. Available at <https://www.epa.gov/mats> 41 (accessed August 28, 2018). 42 [EPA] U.S. Environmental Protection Agency. 2016a. Sole Source Aquifers in the Southeast. 43 Last updated: February 2, 2016. Available at 44 <https://archive.epa.gov/pesticides/region4/water/groundwater/web/html/r4ssa.html#biscayne> 45 (accessed July 7, 2018). 6-8

1 [EPA] U.S. Environmental Protection Agency. 2016b. Climate Change Indicators in the United 2 States, 2016. Fourth Edition. EPA 430-R-16-004. Washington, DC. August 2016. 96 p. 3 Available at <https://www.epa.gov/climate-indicators> (accessed August 24, 2018). 4 [EPA] U.S. Environmental Protection Agency. 2016c. What Climate Change Means for 5 Florida. EPA 430-F-16-011. Washington, DC. August 2016. 2 p. Available at 6 <https://www.epa.gov/sites/production/files/2016-08/documents/climate-change-fl.pdf> 7 (accessed August 24, 2018). 8 [EPA] U.S. Environmental Protection Agency. 2017. Detailed Facility Report: FPL Turkey 9 Point Nuclear Generating Station. EPA Enforcement and Compliance History Online. 10 Available at <https://echo.epa.gov/facilities/facility-search> (search Facility ID Number 11 110000914832) (accessed April 12, 2017). 12 [EPA] U.S. Environmental Protection Agency. 2018a. National Ambient Air Quality Standards 13 Table. Last updated: December 20, 2016. Available at <https://www.epa.gov/criteria-air-14 pollutants/naaqs-table> (accessed September 14, 2018). 15 [EPA] U.S. Environmental Protection Agency. 2018b. 2014 National Emissions Inventory 16 Report. Available at <https://gispub.epa.gov/neireport/2014/> (accessed September 16, 2018). 17 [EPA] U.S. Environmental Protection Agency. 2019. EJSCREEN: EPA Environmental Justice 18 Screening and Mapping Tool. Available at <https://ejscreen.epa.gov/mapper/> 19 (accessed March 1, 2019). 20 [FAC] Florida Administrative Code, Chapter 40E-2, Consumptive Use. Available at 21 <https://www.flrules.org/gateway/ChapterHome.asp?Chapter=40E-2> (accessed 22 August 1, 2018). 23 [FAC] Florida Administrative Code, Rule 62-296.320, General Pollutant Emission Limiting 24 Standards. Available at <https://www.flrules.org/gateway/RuleNo.asp?ID=62-296.320> 25 (accessed September 21, 2018). 26 [FAC] Florida Administrative Code, Rule 62-520.300, Purpose and Intent for Ground Water. 27 Available at <https://www.flrules.org/gateway/RuleNo.asp?ID=62-520.300> (accessed 28 July 17, 2018). 29 [FAC] Florida Administrative Code, Rule 62-520.410, Classification of Ground Water, Usage, 30 Reclassification. Available at <https://www.flrules.org/gateway/RuleNo.asp?ID=62-520.410> 31 (accessed July 17, 2018). 32 [FAC] Florida Administrative Code, Chapter 62-528, Underground Injection Control. 33 Available at <https://www.flrules.org/gateway/ChapterHome.asp?Chapter=62-528> 34 (accessed December 7, 2018). 35 [FAC] Florida Administrative Code, Chapter 68A-27, Rules Relating to Endangered or 36 Threatened Species. Available at 37 <https://www.flrules.org/gateway/ChapterHome.asp?Chapter=68A-27> (accessed on 38 September 11, 2018). 39 [FDACS] Florida Department of Agriculture and Consumer Services. 2017. Office of Energy 40 Annual Report. Tallahassee, FL. 2017. 25 p. Available at 41 <https://www.freshfromflorida.com/content/download/79009/2320944/2017_Office_of_Energy_A 42 nnual_Report.pdf> (accessed September 20, 2018). 6-9

1 [FDEP] Florida Department of Environmental Protection. 2005. State of Florida: Industrial 2 Wastewater Facility Permit, Permit Number FL0001562. Issued May 6, 2005. Available at 3 <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-documents#> (search facility/site ID: 4 FL0001562, document date: 5/16/2005) (accessed July 18, 2018). 5 [FDEP] Florida Department of Environmental Protection. 2013. Underground Injection Control 6 Class I Injection Well System, Construction and Testing Permit, Permit 7 Number 293962-002-UC. Issued July 29, 2013. Available at 8 <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-documents> (search 9 facility/site ID: FL0001562, document date: 7/29/2013) (accessed July 7, 2018). 10 [FDEP] Florida Department of Environmental Protection. 2014. Administrative Order in the 11 Matter of Florida Power and Light Company, DEP State License No. PA03-45, 12 OGC No. 14-0741. December 23, 2014. ADAMS Accession No. ML15026A548. 13 [FDEP] Florida Department of Environmental Protection. 2016a. Consent Order, OGC File 14 Number 16-0241, between the State of Florida Department of Environmental Protection and 15 Florida Power & Light Company regarding settlement of Matters at Issue [Westward Migration of 16 Hypersaline Water from the Turkey Point Facility and Potential Releases to Deep Channels on 17 the Eastern and Southern Side of the Facility]. June 20, 2016. ADAMS Accession 18 No. ML16216A216. 19 [FDEP] Florida Department of Environmental Protection. 2016b. Conditions of Certification, 20 Florida Power & Light Company, Turkey Point Plant Units 3 and 4 Nuclear Power Plant Unit 5 21 Combined Cycle Plant, PA 03-45E. Last updated: March 29, 2016. Available at 22 <https://floridadep.gov/air/siting-coordination-office/content/turkey-point-power-plant> (accessed 23 July 7, 2018). 24 [FDEP] Florida Department of Environmental Protection. 2016c. Letter from F. Aschauer, Jr., 25 to J. Leon, Registered Agent, Florida Power and Light Company.

Subject:

Warning Letter 26 #WL16-000151W13SED, Turkey Point Power Plant, Facility ID No.: FL0001562, Miami-Dade 27 County. April 25, 2016. ADAMS Accession No. ML16216A215. 28 [FDEP] Florida Department of Environmental Protection. 2016d. Notice of Violation and 29 Orders for Corrective Action, OGC File No.: 16-0241, Florida Power and Light Company, Final 30 Order. April 25, 2016. ADAMS Accession No. ML16216A214. 31 [FDEP] Florida Department of Environmental Protection. 2016e. Consent Order, OGC File 32 Number 16-0241, between the State of Florida Department of Environmental Protection and 33 Florida Power & Light Company regarding settlement of Matters at Issue [Westward Migration of 34 Hypersaline Water from the Turkey Point Facility and Potential Releases to Deep Channels on 35 the Eastern and Southern Side of the Facility]. June 20, 2016. ADAMS Accession 36 No. ML16216A216. 37 [FDEP] Florida Department of Environmental Protection. 2016f. Letter from J. Haberfeld, P.G., 38 Environmental Administrator, Aquifer Protection Program, Division of Water Resource 39 Management, to M. Raffenberg, Environmental Services Director, Florida Power & Light 40 Company.

Subject:

FPL Turkey Point Class I Injection Well Construction and Testing Permit - 41 Authorization for Operational Testing. September 21, 2016. Available at 42 <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-documents#> (search 43 Permit/Application Number 293962-002) (accessed July 7, 2018). 6-10

1 [FDEP] Florida Department of Environmental Protection. 2016g. Letter from J. Haberfeld, P.G., 2 Environmental Administrator, Aquifer Protection Program, Division of Water Resource 3 Management, to M. Raffenberg, Environmental Services Director, Florida Power & Light 4 Company.

Subject:

Minor Modification to FDEP Permit 293962002UC to Allow the Inclusion 5 of Biscayne Aquifer Groundwater Disposal Directed to the Injection Well. Permit Number 6 293962 003-UC/MM. May 25, 2016. Available at 7 <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-documents#> 8 (search Permit/Application Number 293962-002) (accessed July 7, 2018). 9 [FDEP] Florida Department of Environmental Protection. 2016h. Final Order, DEP #16-0111, 10 OGC Case No. 14-0741, DOAH Case No. 15-1746, DOAH Case No. 15-1747. April 21, 2016. 11 Available at <https://floridadep.gov/ogc/ogc/documents/14-0741> (accessed July 7, 2018). 12 [FDEP] Florida Department of Environmental Protection. 2016i. Warning Letter 13 #WL16 000151Wl3SED, Turkey Point Power Plant, Facility ID No.: FL0001562, Miami-Dade 14 County. April 25, 2016. ADAMS Accession No. ML16216A215. 15 [FDEP] Florida Department of Environmental Protection. 2017a. Factsheet About Outstanding 16 Florida Waters (OFW). November 2017. 4 p. Available at 17 <https://floridadep.gov/sites/default/files/OFW%20factsheet_0.pdf> (accessed June 11, 2018). 18 [FDEP] Florida Department of Environmental Protection. 2017b. Biscayne Bay Aquatic 19 Preserves. Last updated: September 5, 2017. Available at <https://floridadep.gov/fco/aquatic-20 preserve/locations/biscayne-bay-aquatic-preserves> (accessed June 14, 2018). 21 [FDEP] Florida Department of Environmental Protection. 2018a. NPDES Permits and Forms, 22 Generic Permit for Stormwater Discharge from Large and Small Construction Activities. Last 23 updated January 8, 2018. Available at <https://floridadep.gov/water/stormwater/content/npdes-24 permits-and-forms> (accessed July 7, 2018). 25 [FDEP] Florida Department of Environmental Protection. 2018b. Standards and Facts Drinking 26 Water. Last updated April 11, 2018. Available at <https://floridadep.gov/comm/press-27 office/documents/drinking-water-standards> (accessed July 7, 2018). 28 [FDEP] Florida Department of Environmental Protection. 2018c. Title V Air Operation Permit 29 Renewal, Permit No. 0250003-028-AV. Issued April 26, 2018. Available at 30 <https://fldep.dep.state.fl.us/air/emission/apds/default.asp> (search: permit 31 number 0250003-028-AV) (accessed September 16, 2018). 32 [FDEP] Florida Department of Environmental Protection. 2018d. Underground Injection 33 Control Class I Injection Well System Operation Permit, Permit Number 0293962-004-UO/1I. 34 Issued July 12, 2018. Available at <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-35 documents> (search permit/application number: 0293962-004-UO, document date: 7/12/2018) 36 (accessed August 10, 2018). 37 [FDEP] Florida Department of Environmental Protection. 2018e. Florida Administrative Code 38 62-302.532 Estuary-Specific Numeric Interpretations of the Narrative Nutrient Criterion, OGC 39 File No. 16-0241. 2018. Available at 40 <https://www.flrules.org/gateway/RuleNo.asp?title=SURFACE%20WATER%20QUALITY%20S 41 TANDARDS&ID=62-302.532> (view Section 62-302.532, ID 17115861, effective 2/17/2016) 42 (accessed July 3, 2018). 43 [FDOH] Florida Department of Health. 2018a. Well Surveillance Mapping Site. Last updated 44 August 9, 2016. Available at <http://www.floridahealth.gov/environmental-health/drinking-45 water/well-surveillance-mapping-site.html> (accessed July 7, 2018). 6-11

1 [FDOH] Florida Department of Health. 2018b. Radioactive Materials. Last updated 2 October 1, 2015. Available at <http://www.floridahealth.gov/environmental-health/radiation-3 control/radmat/index.html> (accessed December 31, 2018). 4 [FDOT] Florida Department of Transportation. 2007. Strategic Aggregates Study: Sources, 5 Constraints, and Economic Value of Limestone and Sand in Florida, Parts I and II. Lampl 6 Herbert Consultants, Tallahassee, FL. March 12, 2007. 126 p. Available at 7 <http://www.iti.northwestern.edu/publications/dowding/acm/Lampl_Herbert_Consultants-2007-8 Strategic_Aggregates_Study_Sources_Constraints_and_Economic_Value_of_Limestone_and_ 9 Sand_in_Florida.pdf> (accessed April 30, 2018). 10 [FDOT] Florida Department of Transportation. 2017. Annual Average Daily Traffic Report. 11 Available at <https://tdaappsprod.dot.state.fl.us/fto> (accessed May 11, 2018). 12 Federal Water Pollution Control Act (Clean Water Act or CWA) of 1972, as amended. 13 33 U.S.C. 1251 et seq. 14 [FEMA] U.S. Federal Emergency Management Agency. 2014. Base Flood. Last updated: 15 November 2014. Available at <https://www.fema.gov/base-flood> (accessed August 29, 2018). 16 [FEMA] U.S. Federal Emergency Management Agency. 2018a. Earthquake Hazard Maps. 17 Last updated: April 16, 2018. Available at <https://www.fema.gov/earthquake-hazard-maps> 18 (accessed April 30, 2018). 19 [FEMA] U.S. Federal Emergency Management Agency. 2018b. Definitions of FEMA Flood 20 Zone Designations. August 2018. Available at 21 <https://snmapmod.snco.us/fmm/document/fema-flood-zone-definitions.pdf> (accessed 22 29 August 2018). 23 [FFWCC] Florida Fish and Wildlife Conservation Commission. Undated. Miami Blue Butterfly. 24 Available at <https://myfwc.com/media/2278/miami-blue-butterfly.pdf> (accessed 25 August 28, 2018). 26 [FFWCC] Florida Fish and Wildlife Conservation Commission. 2016. Email: R. Zambrano, 27 FFWCC to M. Aldecoa, FPL.

Subject:

Least Terns at Turkey Point. June 15, 2016. ADAMS 28 Accession No. ML18247A526. In: FPL 2018h, Attachment 20, Enclosure 1. ADAMS Accession 29 No. ML18247A507. 30 [FFWCC] Florida Fish and Wildlife Conservation Commission. 2018. Florida Shorebird 31 Database. Available at <https://public.myfwc.com/crossdoi/shorebirds/> (accessed 32 August 27, 2018). 33 [FHR] Florida House of Representatives. 2010. Florida Education Finance Program, 34 2010-2011 Education Fact Sheets. Pp. 23-31. Available at 35 <http://basiceducationfundingcommission.pasenategop.com/wp-36 content/uploads/sites/68/2014/10/2010-11-Florida-Education-Finance-Program-FEFP.3.pdf> 37 (accessed May 1, 2018). 38 Fischer C., Schlupp I. 2009. Differences in thermal tolerance in coexisting sexual and asexual 39 mollies (Poecilia, Poeciliidae, Teleostei). Journal of Fish Biology 74:1662-1668. 40 Fla. Stat. § 258.397. Available at 41 <http://leg.state.fl.us/Statutes/index.cfm?App_mode=Display_Statute&Search_String=&URL=02 42 00-0299/0258/Sections/0258.397.html> (accessed June 11, 2018). 43 [FLDOE] Florida Department of Education. 2017. 2017-18 Funding for Florida School 44 Districts. 2017. 43 p. Available at 45 <http://www.fldoe.org/core/fileparse.php/7507/urlt/Fefpdist.pdf> (accessed May 1, 2018). 6-12

1 [FNAI] Florida Natural Areas Inventory. 2018. Florida Natural Areas Inventory Tracking List, 2 Miami-Dade County. Last updated: March 2018. Available at < 3 http://fnai.org/trackinglist.cfm> (search: Miami-Dade County) (accessed August 15, 2018). 4 Foti R., et al. 2012. Hydroperiod regime controls the organization of plant species in 5 wetlands. Proceedings of the National Academy of Sciences of the United States of America. 6 109(48):19596-19600. Available at <https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3511740/> 7 (accessed August 27, 2018). 8 [FPL] Florida Power & Light Company. 2000. Applicant's Environmental Report - Operating 9 License Renewal Stage, Turkey Point Units 3 & 4. September 8, 2000. ADAMS Accession 10 No. ML003749667. 11 [FPL] Florida Power & Light Company. 2010. Turkey Point Monitoring Plan, South Dade 12 Water Issues Meeting. October 4, 2010. 17 p. Available at 13 <https://www.sfwmd.gov/sites/default/files/documents/fpl_tp_monitor_plan_implementation_stat 14 us.pdf> (accessed July 6, 2018). 15 [FPL] Florida Power & Light Company. 2011a. Turkey Point Plant Annual Monitoring Report 16 Units 3 & 4 Uprate Project. Ecology and Environment, Inc. August 2011. Available at 17 <ftp://ftp.sfwmd.gov/pub/SMDWIC/turkey_point/annual_monitoring_report/2011/Disk1-Annual 18 Monitoring Report 2011.zip> (accessed July 6, 2018). 19 [FPL] Florida Power & Light Company. 2011b. Turkey Point Units 6 & 7 Section 404(b)(1) 20 Alternatives Analysis. October 2011. ADAMS Accession No. ML11319A035. 21 [FPL] Florida Power & Light Company. 2012a. Turkey Point Plant - Comprehensive Pre-22 Uprate Monitoring Report, Units 3 & 4 Uprate Project. Ecology and Environment, Inc. 23 002998.FC11.01. 3841 p. October 31, 2012. ADAMS Accession No. ML15026A503. 24 [FPL] Florida Power & Light Company. 2012b. Turkey Point Units 6 & 7 Federal Biological 25 Assessment for Six Listed Species. November 2012. 255 p. ADAMS Accession 26 No. ML123390437. 27 [FPL] Florida Power & Light Company. 2013a. Offsite Dose Calculation Manual for Gaseous 28 and Liquid Effluents from the Turkey Point Plant Units 3 and 4. Revision 20. 29 December 19, 2013. ADAMS Accession No. ML14070A086. 30 [FPL] Florida Power & Light Company. 2013b. Florida Power and Light - Turkey Point Plant 31 Units 3 and 4 - Annual Radioactive Effluent Release Report - January 2012 through 32 December 2012. March 1, 2013. 281 p. ADAMS Accession No. ML13071A554. 33 [FPL] Florida Power & Light Company. 2014a. Turkey Point Units 6 & 7 COL Application, Part 34 3Environmental Report. Revision 6. December 8, 2014. 2,038 p. ADAMS Accession 35 No. ML14342A011. 36 [FPL] Florida Power & Light Company. 2014b. Turkey Point Plant Annual Post-Uprate 37 Monitoring Report, Units 3 & 4 Uprate Project - August 2014. Ecology and Environment, Inc., 38 Lancaster, New York. August 2014. 537 p. Available 39 at<ftp://ftp.sfwmd.gov/pub/SMDWIC/turkey_point/2014_annual_post_uprate_report/1-40 report_sections.zip> (accessed July 7, 2018). 41 [FPL] Florida Power & Light Company. 2014c. 2013 Annual Radiological Environmental 42 Operating Report, Turkey Point Plant - Units 3 & 4. 102 p. May 5, 2014. ADAMS Accession 43 No. ML14139A082. 6-13

1 [FPL] Florida Power & Light Company. 2014d. Turkey Point Plant, Units 3 and 4 - Annual 2 Radioactive Effluent Release Report - January 2013 through December 2013. 3 December 31, 2013. 67 p. ADAMS Accession No. ML14070A085. 4 [FPL] Florida Power & Light Company. 2015a. Turkey Point Plant, Units 3 and 4 - Annual 5 Radioactive Effluent Release Report - January 2014 through December 2014. 6 February 25, 2015. 324 p. ADAMS Accession No. ML15072A014. 7 [FPL] Florida Power & Light Company. 2015b. 2014 Annual Radiological Environmental 8 Operating Report, Turkey Point Plant, Units 3 & 4. 101 p. May 11, 2015. ADAMS Accession 9 No. ML15147A515. 10 [FPL] Florida Power & Light Company. 2016a. Turkey Point Plant Comprehensive 11 Post-Uprate Monitoring Report, Units 3 & 4 Uprate Project. Prepared by Ecology and 12 Environment, Inc., Lancaster, New York. March 31, 2016. 666 p. Available at 13 <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-documents#> (search facility/site ID: 14 FL0001562, document date: 3/31/2016) (accessed July 7, 2018). 15 [FPL] Florida Power & Light Company. 2016b. Turkey Point Plant Annual Monitoring Report - 16 August 2016. Prepared by Ecology and Environment, Inc., Lancaster, New York. 17 August 2016. Available at <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-18 documents#> (search facility/site ID: FL0001562, document date: 8/1/2016) (accessed 19 July 7, 2018). 20 [FPL] Florida Power & Light Company. 2016c. Joint Application for Individual Environmental 21 Resource Permit/Authorization to use State-Owned Submerged Lands/Federal Dredge and Fill 22 Permit, Turtle Point and Barge Canal/Basin Water Quality Improvement Projects. 23 August 2, 2016. ADAMS Accession No. ML18247A510. In: FPL 2018h, Attachment 5, 24 Enclosure 1 ADAMS Accession No. ML18247A509. 25 [FPL] Florida Power & Light Company. 2016d. Not used. 26 [FPL] Florida Power & Light Company. 2016e. Consent Agreement 2016 Annual Report. 27 November 10, 2016. Available at <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case 28 Number: HWR-00945, Date: 11/11/2016 ) also available at 29 <https://www.fpl.com/landing/pdf/ca-annual-report.pdf> (accessed July 9, 2018). 30 [FPL] Florida Power & Light Company. 2016f. Florida Power & Light Company Turkey Point 31 Power Plant Cooling Canal System (CCS) Freshening Effectiveness Report. Ecology and 32 Environment, Inc. January 29, 2016. 70 p. Available at 33 <http://prodenv.dep.state.fl.us/DepNexus/public/searchPortal> (search facility/site ID: 34 FL0001562, document date: 1/29/2016) (accessed July 9, 2018). 35 [FPL] Florida Power & Light Company. 2016g. Turkey Point Remnant Canal Site Assessment 36 Plan. September 14, 2016. Available at <http://ecmrer.miamidade.gov:8080/hpi/search> 37 (search Case Number: CLI-2016-0428, Date: 9/15/2016) (accessed July 3, 2018). 38 [FPL] Florida Power & Light Company. 2016h. Updated Final Safety Analysis Report, Turkey 39 Point Units 3 & 4. Revised September 20, 2016. ADAMS Accession No. ML18117A085 40 (Section 11.1.2 is at ADAMS Accession No. ML18117A101). 41 [FPL] Florida Power & Light Company. 2016i. Florida Power and Light, Turkey Point Plant 42 Units 3 and 4 - Annual Radioactive Effluent Release Report - January 2015 through 43 December 2015. February 26, 2016. 297 p. ADAMS Accession No. ML16109A044. 6-14

1 [FPL] Florida Power & Light Company. 2016j. 2015 Annual Radiological Environmental 2 Operating Report - Turkey Point Plant, Units 3 & 4. May 12, 2016. 100 p. ADAMS Accession 3 No. ML16144A790. 4 [FPL] Florida Power & Light Company. 2016k. Turkey Point Cooling Canal System Nutrient 5 Management Plan. September 16, 2016. 28 p. Available at 6 <http://www.psc.state.fl.us/library/filings/2017/09365-7 2017/Support/EXH%2061%2020170007%20-%20Staff's%203rd%20INT%20No.%2062%20-8 %20Attachment%20No.%202.pdf> (accessed July 19, 2018). 9 [FPL] Florida Power & Light Company. 2016l. Florida Power and Light, Turkey Point Plant, 10 Units 3 and 4 - Annual Radioactive Effluent Release Report - January 2015 through 11 December 2015. February 26, 2016. ADAMS Accession No. ML16109A044. 12 [FPL] Florida Power & Light Company. 2017a. Turkey Point Plant Annual Monitoring Report, 13 September 2017. Prepared by Ecology and Environment, Inc., Lancaster, New York. 14 September 2017. 414 p. Available at 15 <http://prodenv.dep.state.fl.us/DepNexus/public/electronic-documents#> (search facility/site ID: 16 FL0001562, document date: 9/28/2017) (accessed July 7, 2018). 17 [FPL] Florida Power & Light Company. 2017b. 2017 Annual Turkey Point Power Plant 18 Remediation/Restoration Report. November 2017. Available at 19 <http://prodenv.dep.state.fl.us/DepNexus/public/searchPortal> (search facility/site ID: 20 FL0001562, document date: 11/1/2017) (accessed July 9, 2018). 21 [FPL] Florida Power & Light Company. 2017c. Site Assessment Report - Ammonia in Surface 22 Waters. Turkey Point Facility. March 17, 2017. 1709 p. Available at 23 <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case Number: CLI-2016-0428, Date: 24 3/17/2017) (accessed July 5, 2018). 25 [FPL] Florida Power & Light Company. 2017d. 2016 Annual Radiological Environmental 26 Operating Report - Turkey Point Plant, Units 3 & 4. May 11, 2017. 102 p. ADAMS Accession 27 No. ML17131A341. 28 [FPL] Florida Power & Light Company. 2017e. Florida Power and Light, Turkey Point Plant 29 Units 3 and 4 - Annual Radioactive Effluent Release Report - January 2016 through 30 December 2016. February 28, 2017. 297 p. ADAMS Accession No. ML17067A032. 31 [FPL] Florida Power & Light Company. 2018a. "Turkey Point Units 3 and 4 - Subsequent 32 License Renewal Application. January 30, 2018. ADAMS Accession No. ML18037A812. 33 [FPL] Florida Power & Light Company. 2018b. Turkey Point Units 3 and 4 Subsequent 34 License Renewal Application - Supplement 1. February 9, 2018. ADAMS Accession 35 No. ML18044A653. 36 [FPL] Florida Power & Light Company. 2018c. Turkey Point Units 3 and 4 Subsequent 37 License Renewal Application - Supplement 2. February 16, 2018. ADAMS Accession 38 No. ML18053A123. 39 [FPL] Florida Power & Light Company. 2018d. Turkey Point Units 3 and 4 Subsequent 40 License Renewal Application - Supplement 3. March 1, 2018. ADAMS Accession 41 No. ML18072A224. 42 [FPL] Florida Power & Light Company. 2018e. Turkey Point Units 3 and 4 Subsequent 43 License Renewal Application - Revision 1. April 10, 2018. ADAMS Accession 44 No. ML18113A132. 6-15

1 [FPL] Florida Power & Light Company. 2018f. Applicants Environmental Report - Subsequent 2 Operating License Renewal Stage - Turkey Point Nuclear Plant Units 3 and 4. January 2018. 3 762 p. ADAMS Accession No. ML18037A836. 4 [FPL] Florida Power & Light Company. 2018g. Ten Year Power Plant Site Plan, 2018 - 2027. 5 April 2018. 179 p. Available at <https://www.fpl.com/company/pdf/10-year-site-plan.pdf> 6 (accessed May 18, 2018). 7 [FPL] Florida Power & Light Company. 2018h. Letter from W. Maher, Senior Licensing 8 Director, Florida Power & Light Company, to NRC Document Control Desk.

Subject:

Turkey 9 Point Units 3 and 4 Subsequent License Renewal Application Environmental Report Requests 10 for Additional Information (RAI) Responses. August 8, 2018. ADAMS Accession 11 No. ML18247A509. 12 [FPL] Florida Power & Light Company. 2018i. Monthly Hypersaline Extraction Summary. In 13 FPL 2018h, FPL Response to NRC RAI No. WR-3, L-2018-136 Attachment 44, Enclosure 1, 14 p. 1 of 5. ADAMS Accession No. ML18247A563. 15 [FPL] Florida Power & Light Company. 2018j. Florida Power and Light, Turkey Point Plant 16 Units 3 and 4 - Annual Radioactive Effluent Release Report - January 2017 through 17 December 2017. February 15, 2018. 300 p. ADAMS Accession No. ML18066A562. 18 [FPL] Florida Power & Light Company. 2018k. 2017 Annual Radiological Environmental 19 Operating Report - Turkey Point Plant, Units 3 & 4. April 23, 2018. 96 p. ADAMS Accession 20 No. ML18137A201. 21 [FPL] Florida Power & Light Company. 2018l. Supporting Monthly Volume [Groundwater 22 Withdrawal] Tables. In: FPL 2018h, FPL Response to NRC RAI No. WR-2, L-2018-136 23 Attachment 43, Enclosure 20, 3 p. ADAMS Accession No. ML18247A559. 24 [FPL] Florida Power & Light Company. 2018m. Letter from W. Maher, Senior Licensing 25 Director, Florida Power & Light Company, to NRC Document Control Desk.

Subject:

Turkey 26 Point Units 3 and 4 Subsequent License Renewal Application Environmental Review Requests 27 for Additional Information (RAI) Set 3 Responses. October 5, 2018. 62 p. ADAMS Accession 28 No. ML18283A882. 29 [FPL] Florida Power & Light Company. 2018n. Letter from W. Maher, Senior Licensing 30 Director, FPL, to NRC Document Control Desk.

Subject:

Turkey Point Units 3 and 4 31 Subsequent License Renewal Application, Appendix E Environmental Report Supplemental 32 Information. April 10, 2018. 35 p. ADAMS Accession No. ML18102A521. 33 [FPL] Florida Power & Light Company. 2019. Letter from W. Maher, Senior Licensing Director, 34 FPL, to NRC Document Control Desk.

Subject:

Turkey Point Units 3 and 4 Subsequent 35 License Renewal Application, Environmental Report Environmental Authorizations Updated 36 Information. January 23, 2019. 9 p. ADAMS Accession No. ML19025A077. 37 [FWS] U.S. Fish and Wildlife Service. 1999. South Florida multi-species recovery plan. 38 Available at <https://www.fws.gov/verobeach/ListedSpeciesMSRP.html#jump4> (accessed 39 August 28, 2018). 40 [FWS] U.S. Fish and Wildlife Service. 2008. Carters mustard (Warea carteri) 5-Year Review: 41 Summary and Evaluation. September 15, 2008. Available at 42 <https://ecos.fws.gov/docs/five_year_review/doc1977.pdf> (accessed August 30, 2018). 43 [FWS] U.S. Fish and Wildlife Service. 2010. U.S. Fish and Wildlife Service Species 44 Assessment and Listing Priority Assignment Form: Chromolaena frustrata (Cape Sable 45 Thoroughwort). April 5, 2010. 20 p. ADAMS Accession No. ML14230A018. 6-16

1 [FWS] U.S. Fish and Wildlife Service. 2017. Letter from R. Hinzman, Field Supervisor South 2 Florida Ecological Services Office, FWS, to A. Williamson, Project Manager, NRC.

Subject:

3 Biological Opinion for Combined License for Turkey Point Nuclear Plant, Units 6 and 7. 4 June 23, 2017. ADAMS Accession No. ML17177A673. 5 [FWS] U.S. Fish and Wildlife Service. 2018a. IPaC Resource List for the Turkey Point 6 Subsequent License Renewal Project. September 11, 2018. 25 p. Accession 7 No. ML18254A341. 8 [FWS] U.S. Fish and Wildlife Service. 2018b. Letter from South Florida Ecological Services 9 Field Office, FWS.

Subject:

Updated list of threatened and endangered species that may 10 occur in your proposed project location, and/or may be affected by your proposed project. 11 December 14, 2018. Accession No. ML18348A889. 12 [FWS and NMFS] U.S. Fish and Wildlife Service and National Marine Fisheries Service. 1998. 13 Endangered Species Consultation Handbook: Procedures for Conducting Consultation and 14 Conference Activities Under Section 7 of the Endangered Species Act. March 1998. 315 p. 15 Available at <http://www.fws.gov/endangered/esa-library/pdf/esa_section7_handbook.pdf> 16 (accessed August 30, 2018). 17 [GCP] Global Carbon Project. 2018. Global Carbon Atlas. Available at 18 <http://www.globalcarbonatlas.org/en/CO2-emissions> (accessed August 24, 2018). 19 [GMCVB] The Greater Miami Convention and Visitors Bureau. 2018. Miami-Dade Monthly 20 Hotel Inventory by Regions, May 2018. Available at 21 <https://www.miamiandbeaches.com/gmcvb-partners/tools-resources/research-statistics> 22 (accessed July 24, 2018). 23 [Golder] Golder Associates, Inc. 2008. Cooling Canal System Modeling Report. 24 January 13, 2008. 31 p. ADAMS Accession No. ML13072A713. 25 [Golder] Golder Associates, Inc. 2016. Water Supply Alternatives Analysis, Florida Power and 26 Light Company, Turkey Point. March 2016. 31 p. Available at 27 <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case Number: HWR-00942, Date: 28 3/31/2016) (accessed August 23, 2018). 29 Harrington R.W. Jr., Harrington E.S. 1961. Food selection among fishes invading a high 30 subtropical salt marsh from onset of flooding through the progress of a mosquito brood. 31 Ecology 42:646-666. 32 HDR Engineering, Inc. 2009. Florida Power and Light, Turkey Point Exploratory Drilling and 33 Aquifer Performance Test Program. West Palm Beach, FL. August 19, 2009. 351 p. ADAMS 34 Accession No. ML110820053. 35 Hughes, J.D., Langevin, C.D., Brakefield-Goswami, L. 2010. Effect of hypersaline cooling 36 canals on aquifer salinization. Hydrogeology Journal 18:25-38. 37 [IEA] International Energy Agency. 2007. Biomass for Power Generation and CHP. IEA 38 Energy Technology Essentials ETE03. January 2007. 4 p. Available at 39 <https://www.iea.org/publications/freepublications/publication/essentials3.pdf> (accessed 40 August 14, 2018). 41 [IPCC] Intergovernmental Panel on Climate Change. 2000. Special Report on Emissions 42 Scenarios. Nakicenovic N., Swart R. (eds.). Cambridge University Press, Cambridge, UK. 43 2000. 570 p. Available at <https://www.ipcc.ch/report/emissions-scenarios/> (accessed 44 August 10, 2018). 6-17

1 [IPCC] Intergovernmental Panel on Climate Change. 2007. Climate Change 2007: The 2 Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of 3 the Intergovernmental Panel on Climate Change. Solomon S., Qin D., et al (eds.). Cambridge 4 University Press, Cambridge, UK. 2007. 996 p. Available at 5 <https://www.ipcc.ch/report/ar4/wg1/> (accessed September 21, 2018). 6 [IPCC] Intergovernmental Panel on Climate Change. 2013. Climate Change 2013: The 7 Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the 8 Intergovernmental Panel on Climate Change. Stocker T.F., Qin D., et al (eds.). Cambridge 9 University Press, Cambridge, UK. 2013. 1535 p. Available at 10 <https://www.ipcc.ch/report/ar5/wg1/> (accessed August 10, 2018). 11 Janus Research. 2009. Cultural Resource Assessment Survey for the Turkey Point 12 Units 6 & 7 Site, Associated Non-Linear Facilities, and Spoils Areas on Plant Property. 104 p. 13 ADAMS Accession Nos. ML11109A019 and ML11109A017. 14 Johnson W.E. 1974. Morphological variation and local distribution of Cyprinodon variegatus in 15 Florida. Retrospective Theses and Dissertations. University of Central Florida. 191 p. 16 Available at <https://stars.library.ucf.edu/rtd/109/> (accessed December 15, 2018). 17 Keenan J.M., Hill T., Gumber A. 2018. Climate gentrification: from theory to empiricism in 18 Miami-Dade County, Florida. Environmental Research Letters 13:5. Available at 19 <http://iopscience.iop.org/journal/1748-9326> (accessed December 15, 2018). 20 Leavy T.R., Bonner T.H. 2009. Relationships among swimming ability, current velocity 21 association, and morphology of freshwater lotic fishes. North American Journal of Fisheries 22 Management 29:72-83. DOI: 10.1577/M07-040.1. 23 [LBNL] Lawrence Berkeley National Laboratory. 2017. U.S. Renewables Portfolio Standards 24 2017 Annual Status Report. July 2017. Available at <http://eta-25 publications.lbl.gov/sites/default/files/2017-annual-rps-summary-report.pdf> (accessed 26 August 30, 2018). 27 Magnuson-Stevens Fishery Conservation and Management Act, as amended. 28 16 U.S.C. 1801 et seq. 29 Mayer F.L., Low J.B. 1970. The effect of salinity on widgeongrass. The Journal of Wildlife 30 Management 34(3):658-661. DOI: 10.2307/3798882. 31 Mayhew D.A., Jensen L.D., Hanson D.F., Muessig P.H. 2000. A comparative review of 32 entrainment survival studies at power plants in estuarine environments. Environmental 33 Science and Policy 3:295-301. DOI: 10.1016/S1462-9011(00)00069-1. 34 McPherson B.F., Halley R. 1996. The South Florida EnvironmentA Region Under Stress. 35 U.S. Geological Survey Circular 1134. 67 p. ADAMS Accession No. ML12193A218. 36 [MDC] Miami-Dade County. 2006. Miami-Dade County Wellfield Protection Areas. Map 37 created September 23, 2006. Available at 38 <http://www.miamidade.gov/environment/wellfields.asp> (accessed July 7, 2018). 39 [MDC] Miami-Dade County. 2014. 20-year Water Supply Facilities Work Plan (2014-2033). 40 Available at <http://www.miamidade.gov/water/library/20-year-water-supply-facilities-work-41 plan.pdf> (accessed June 7, 2018). 42 [MDC] Miami-Dade County. 2015a. Consent Agreement Concerning Water Quality Impacts 43 Associated with the Cooling Canal System at Turkey Point Power Plant. October 6, 2015. 44 ADAMS Accession No. ML15286A366. 6-18

1 [MDC] Miami-Dade County. 2015b. FY 2015-16 Business Plan, Adopted Budget, and 2 Five-Year Financial Outlook. Available at <http://www.miamidade.gov/budget/archives.asp> 3 (accessed May 9, 2018). 4 [MDC] Miami-Dade County. 2016a. Addendum 1 to the October 7, 2015 Consent Agreement 5 between Miami-Dade County and Florida Power & Light Company. August 12, 2016. Available 6 at <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case Number: HWR-00851, Date: 7 8/15/2016) (accessed July 3, 2018). 8 [MDC] Miami-Dade County. 2016b. FY 2016-17 Business Plan, Adopted Budget, and Five-9 Year Financial Outlook. Available at <http://www.miamidade.gov/budget/current.asp> 10 (accessed May 9, 2018). 11 [MDC] Miami-Dade County. 2016c. 2016 Millage Tables. Available at 12 <http://www.miamidade.gov/pa/millage_tables.asp> (accessed May 1, 2018). 13 [MDC] Miami-Dade County. 2016d. Memorandum from C.A. Gimenez to J. Monestime and 14 Members of the Board of County Commissioners, dated March 7, 2016, regarding Report on 15 Recent Biscayne Bay Water Quality Observations Associated with Florida Power and Light 16 Turkey Point Cooling Canal System OperationsDirective 152884. Miami, Florida. ADAMS 17 Accession No. ML16167A518. 18 [MDC] Miami-Dade County. 2017a. Comprehensive Development Master Plan Adopted 19 Components. Available at <http://www.miamidade.gov/planning/cdmp.asp> (accessed 20 July 2018). 21 [MDC] Miami-Dade County. 2017b. Urban Expansion Area Task Force, Rockmining 22 Considerations. November 17, 2017. 166 p. Available at 23 <https://www.miamidade.gov/planning/library/presentations/2017-11-17-ueatf-rockmining-24 considerations.pdf> (accessed April 30, 2018). 25 [MDC] Miami-Dade County. 2017c. Memorandum from Jack Osterholt, Deputy Mayor/Director, 26 Department of Environmental Resources Management, to Honorable Chairman Esteban L. 27 Bovo, Jr. and Members, Board of County Commissioners,

Subject:

Class IV Permit Application 28 by Atlantic Civil. Inc to Impact 155.4 Acres of Wetlands for a Lake Excavation and to Restore 29 and Enhance 343 Acres of Wetlands as Mitigation in Florida City, Florida. June 20, 2017. 30 Available at <http://www.miamidade.gov/govaction/legistarfiles/Matters/Y2017/171467.pdf> 31 (accessed April 30, 2018). 32 [MDC] Miami-Dade County. 2017d. Letter from C. Grossenbacher, Chief, Water Resources 33 Coordination Division, to M. Raffenberg, Director, Environmental Licensing and Permitting, 34 Florida Power & Light Company.

Subject:

Site Assessment Report (SAR) dated 35 March 17, 2017 and submitted pursuant to Paragraph 34.b. of Addendum 1 to the 36 October 7, 2015 Consent Agreement for FPL's Turkey Point facility located at, near, or in the 37 vicinity of 9700 SW 344 Street, Unincorporated Miami-Dade County, Florida (DERM IW-3, 38 IW-16, IW5-6229, DWO-10, CLl-2014-0312, CLl-2016-0303, HWR-851). July 7, 2017. 39 Available at <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case Number: 40 HWR-00851, Date: 7/7/2017) (accessed July 5, 2018). 6-19

1 [MDC] Miami-Dade County. 2017e. Letter from W. Mayorga, Chief, Environmental Monitoring 2 and Restoration Division, to M. Raffenberg, Director, Environmental Licensing and Permitting, 3 Florida Power & Light Company.

Subject:

Phase 1 Remedial Action Plan Submittal dated 4 January 27, 2017 for the Florida Power and Light Facility and Cooling Canal System (DERM 5 HWR-851, IW-3 & IW-16) located at, near or in the vicinity of 9760 SW 344th Street, 6 Homestead, Miami Dade County, Florida. May 15, 2017. Available at 7 <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case Number: HWR-00851, Date: 8 5/15/2017) (accessed July 7, 2018). 9 [MDC] Miami-Dade County. 2017f. 2017-2018 Business Plan, Adopted Budget, and Five-Year 10 Financial Outlook. Available at <http://www.miamidade.gov/budget/current.asp> (accessed 11 May 9, 2018). 12 [MDC] Miami-Dade County. 2018a. Letter from W. Mayorga, Chief, Environmental Monitoring 13 and Restoration Division, to M. Raffenberg, Sr. Director, Environmental Licensing and 14 Permitting, Florida Power & Light Company.

Subject:

Site Assessment Report (SAR) dated 15 March 17, 2017 and the SAR Supplemental Information dated November 11, 2017, submitted 16 pursuant to Addendum 1 dated August 15, 2016 of the Consent Agreement between Florida 17 Power & Light (FPL) and Miami-Dade County, Division of Environmental Resources 18 Management for FPLs Turkey Point facility located at, near, or in the vicinity of 19 9700 SW 344 Street, Unincorporated Miami-Dade County, Florida (DERM IW-3, IW-16, 20 IW5-6229, DWO-10, CLI-2014-0312, CLI-2016-0303, HWR-851. July 10, 2018. Available at 21 <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case Number: CLI-2016-0428, Date: 22 7/10/2018) (accessed August 27, 2018). 23 [MDC] Miami-Dade County. 2018b. Water Supply and Treatment. Page updated 24 February 7, 2018. Available at <http://www.miamidade.gov/water/water-supply-25 treatment.asp#0> (accessed July 7, 2018). 26 [MDC] Miami-Dade County. 2018c. Environmental Considerations GIS Tool. Page updated 27 2018. Available at <https://gisweb.miamidade.gov/EnvironmentalConsiderations/> (toggle 28 Wellfield Protection Areas layer in bottom panel on page) (accessed July 7, 2018). 29 [MDC] Miami-Dade County. 2018d. Letter from S. Cody, Historic Preservation Chief, 30 Miami-Dade County, to N. Martinez, Division of Materials and License Renewal, U.S. Nuclear 31 Regulatory Commission.

Subject:

McGregor Smith Ranger House, Evaluation of Historic 32 Significance. ADAMS Accession No. ML18247A502. 33 [MDCPS] Miami-Dade County Public Schools. 2017a. Statistical Highlights 2016-2017. 34 April 2017. 6 p. Available at <http://drs.dadeschools.net/StatisticalHighlights/SH1617.pdf> 35 (accessed May 7, 2018). 36 [MDCPS] Miami-Dade County Public Schools. 2017b. Comprehensive Annual Financial 37 Report for the Fiscal Year Ended June 30, 2017. December 6, 2017. 201 p. Available at 38 <http://financialaffairs.dadeschools.net/pdfs17/CAFR_17.pdf> (accessed May 1, 2018). 39 [MDCPS] Miami-Dade County Public Schools. 2018a. Statistical Highlights, 2017-2018. 40 April 2018. 6 p. Available at <http://drs.dadeschools.net/StatisticalHighlights/SH1718.pdf> 41 (accessed May 7, 2018). 42 Meffe G.K., Weeks S.C., Mulvey M., Kandl K.L. 1995. Genetic differences in thermal tolerance 43 of eastern mosquitofish (Gambusia holbrooki; Poecillidae) from ambient and thermal ponds. 44 Canadian Journal of Fishes and Aquatic Sciences 52(12):2704-2711. DOI: 10.1139/f95-259. 6-20

1 Michaels T. 2010. The 2010 ERC Directory of Waste-to-Energy Plants. Washington, DC: 2 Energy Recovery Council. November 2010. 32 p. Available at 3 <http://www.seas.columbia.edu/earth/wtert/sofos/ERC_2010_Directory.pdf> (accessed 4 September 11, 2018). 5 Michaels T. 2016. Energy Recovery Council 2016 Directory of Waste-to-Energy Facilities. 6 Washington, DC: Energy Recovery Council. May 2016. 72 p. Available at 7 <http://energyrecoverycouncil.org/wp-content/uploads/2016/06/ERC-2016-directory.pdf> 8 (accessed September 11, 2018). 9 Migratory Bird Treaty Act of 1918, as amended. 16 U.S.C. 703 et seq. 10 [Morgan & Eklund] Morgan & Eklund, Inc. 2010. Topographic and Bathymetric Survey, Turkey 11 Point Cooling Canals, Miami-Dade County Florida, for Florida Power and Light June 2, 2010. 12 Available at <http://css-3-4-plan.com/> (accessed July 18, 2018). 13 [NASA] National Aeronautics and Space Administration. 2018. Long-Term Warming Trend 14 Continued in 2017: NASA, NOAA. Release 18-003. January 18, 2018. Available at 15 <https://www.nasa.gov/press-release/long-term-warming-trend-continued-in-2017-nasa-noaa> 16 (accessed August 10, 2018). 17 National Environmental Policy Act of 1969, as amended. 42 U.S.C. 4321 et seq. 18 [NCDC] National Climatic Data Center. 2017. Local Climatological Data Annual Summary 19 With Comparative Data, Miami, Florida (KMIA). Available 20 at <https://www1.ncdc.noaa.gov/pub/orders/IPS/IPS-C03642BD-0801-4354-B0A8-21 62B1C266FEC2.pdf> (accessed 16 September 2018). 22 23 [NCDC] National Climatic Data Center. 2018. Storm Events Database Database 24 search: Florida, Miami-Dade County, 01/1950-12/2016. Available at 25 <https://www.ncdc.noaa.gov/stormevents/choosedates.jsp?statefips=12%2CFLORIDA> 26 (accessed 13 September 2018). 27 [NEI] Nuclear Energy Institute. 2005. Severe Accident Mitigation Alternatives (SAMA) Analysis 28 Guidance Document. NEI 05-01 [Rev A]. Washington, DC: NEI. November 2005. 79 p. 29 ADAMS Accession No. ML060530203. 30 [NEI] Nuclear Energy Institute. 2007. Industry Ground Water Protection InitiativeFinal 31 Guidance Document. NEI 07-07 [Final]. Washington, DC: NEI. August 2007. 27 p. ADAMS 32 Accession No. ML072610036. 33 [NEI] Nuclear Energy Institute. 2017. Model SLR New and Significant Assessment Approach 34 for SAMA. NEI 17-04 [Rev 0]. Washington, DC: NEI. June 2017. 24 p. ADAMS Accession 35 No. ML17181A470. 36 [NETL] National Energy Technology Laboratory. 2007. Natural Gas Combined Cycle Plant. 37 4 p. Available at 38 <https://wecanfigurethisout.org/ENERGY/Web_notes/Bigger%20Picture/Where%20do%20we% 39 20go%20-%20Supporting%20-40 %20Files/Natural%20Gass%20Combined%20Cycle%20Plant%20-%20DOE.pdf> (accessed 41 June 4, 2018). 42 [NETL] National Energy Technology Laboratory. 2010. Life Cycle Analysis: Natural Gas 43 Combined Cycle (NGCC) Power Plant. DOE/NETL-403-110509. September 30, 2010. 151 p. 44 Available at <http://www.canadiancleanpowercoalition.com/files/6513/0179/9541/LA3%20-45 %20NGCC%20LCA%20Final%20Report%20-%20Report%20-%209-30-10%20-%20Final%20-46 %20Rev%202.pdf> (accessed August 24, 2018). 6-21

1 [NETL] National Energy Technology Laboratory. 2013. Cost and Performance Baseline for 2 Fossil Energy Plants, Volume 1: Bituminous Coal and Natural Gas to Electricity. Revision 2a. 3 DOE/NETL-2010/1397. September 2013. 626 p. Available at 4 <http://folk.ntnu.no/andersty/4.%20Klasse/TKP4170%20-5 %20Prosjektering%20Prosessanlegg/Report/Sources/Sigurd600pages.pdf> (accessed 6 September 13, 2018). 7 [NIEHS] National Institute of Environmental Health Sciences. 1999. NIEHS Report on Health 8 Effects from Exposure to Power-Line Frequency Electric and Magnetic Fields. Publication 9 No. 99-4493. Research Triangle Park, NC: NIEHS. May 4, 1999. 80 p. Available at 10 <https://www.niehs.nih.gov/health/assets/docs_p_z/report_powerline_electric_mg_predates_50 11 8.pdf> (accessed December 17, 2018). 12 National Historic Preservation Act of 1966, as amended. 54 U.S.C. 300101 et seq. 13 [NMFS] National Marine Fisheries Service. 2010. Letter from M. Croom, NMFS, to L. Bauer, 14 NRC, regarding response to request for information regarding proposed construction and 15 operation of Turkey Point Units 6 and 7. August 5, 2010. ADAMS Accession 16 No. ML102250231. 17 [NMFS] National Marine Fisheries Service. 2016. Endangered Species Act Section 7 Biological 18 Opinion for Approval of Florida Numeric Nutrient Criteria for Total Phosphorus, Total Nitrogen, 19 and Chlorophyll-a, Dissolved Oxygen Criteria, and Turbidity Limits under section 303(c) of the 20 Clean Water Act. PCTS No. FPR-2015-9234. August 2, 2016. 269 p. Available at 21 <http://news.caloosahatchee.org/docs/BO_FL_NNC_DO_Turbidity_FPR-2015-9134.pdf> 22 (accessed September 5, 2018). 23 [NMFS] National Marine Fisheries Service. 2017. Letter from R. Crabtree, NMFS, to 24 J. Dixon-Herrity, NRC, and A. Dodd, Department of the Army, regarding concurrence with the 25 NRCs determination that the proposed construction and operation of two new units at the 26 Turkey Point site is not likely to adversely affect federally listed species under the NMFSs 27 jurisdiction. April 26, 2017. ADAMS Accession No. ML17143A153. 28 [NOAA] National Oceanic and Atmospheric Administration. 2013a. Regional Climate Trends 29 and Scenarios for the U.S. National Climate Assessment, Part 2. Climate of the Southeast 30 U.S. NOAA Technical Report NESDIS 142-2. Washington, DC: NOAA. January 2013. 31 103 p. Available at <https://www.nesdis.noaa.gov/content/technical-reports> (accessed 32 September 16, 2018). 33 [NOAA] National Oceanic and Atmospheric Administration. 2013b. Regional Climate Trends 34 and Scenarios for the U.S. National Climate Assessment, Part 9. Climate of the Contiguous 35 United States. NOAA Technical Report NESDIS 142-9. Washington, DC: NOAA. 36 January 2013. 85 p. Available at <https://www.nesdis.noaa.gov/content/technical-reports> 37 (accessed August 10, 2018). 38 [NOAA] National Oceanic and Atmospheric Administration. 2018a. Soundings Map, Sands Key 39 to Blackwater Sound. May 18, 2018. Available at 40 <http://www.charts.noaa.gov/InteractiveCatalog/nrnc.shtml> (accessed May 24, 2018). 41 [NOAA] National Oceanic and Atmospheric Administration. 2018b. NOAA National Centers for 42 Environmental Information, Climate at a Glance: Divisional Time Series. Parameters: average 43 annual temperature and precipitation. Available at < 44 https://www.ncdc.noaa.gov/cag/divisional/time-series> (accessed August 24, 2018). 6-22

1 [NOAA] National Oceanic and Atmospheric Administration. 2018c. Sea Level Trends. Page 2 updated August 8, 2018. Available at <https://tidesandcurrents.noaa.gov/sltrends/> (accessed 3 August 24, 2018). 4 Nordlie F.G., Haney D.C., Walsh S.J. 1992. Comparisons of salinity tolerances and osmotic 5 regulatory capabilities in populations of sailfin molly (Poecilia latipinna) from brackish and fresh 6 waters. Copeia 1992(3):741-746. DOI: 10.2307/1446150. 7 [NPS] National Park Service. 2011. Ecological Impacts on Biscayne Bay and Biscayne 8 National Park from Proposed South Miami-Dade County Development, and Derivation of 9 Numeric Nutrient Criteria for South Florida Estuaries and Coastal Waters, Final Report. 10 Southeast Environmental Research Center of Florida International University. December 2011. 11 127 p. Available at <http://serc.fiu.edu/wqmnetwork/BNP/Final%20Report%20BNP.pdf> 12 (accessed July 2, 2018). 13 [NPS] National Park Service. 2012. Assessment of Natural Resource Conditions In and 14 Adjacent to Biscayne National Park. Natural Resource Report NPS/BISC/NRR2012/598. 15 December 2012. 294 p. Available at <http://npshistory.com/publications/bisc/nrr-2012-598.pdf> 16 (accessed May 24, 2018). 17 [NPS] National Park Service. 2015a. Final General Management Plan / Environmental Impact 18 Statement, Biscayne National Park, Miami-Dade County, FL. April 2015. 777 p. Available at 19 <https://parkplanning.nps.gov/document.cfm?parkID=353&projectID=11168&documentID=6580 20 1> (accessed June 12, 2018). 21 [NPS] National Park Service. 2015b. Acquisition of Florida Power & Light Company Land in 22 the East Everglades Expansion Area, Final Environmental Impact Statement. November 2015. 23 502 p. ADAMS Accession No. ML16167A520. 24 [NPS] National Park Service. 2017. National Park Service Visitor Use Statistics. Available at: 25 <https://irma.nps.gov/Stats/> (accessed June 7, 2018). 26 [NPS] National Park Service. 2018a. Letter from S. Craighead, Acting Regional Director, NPS, 27 to G. Wilson, Director of the Division of Materials and License Renewal, NRC, regarding 28 Environmental Impact Statement scoping comments regarding Florida Power & Lights 29 subsequent license renewal application for Turkey Point Units 3 and 4. June 22, 2018. ADAMS 30 Accession No. ML18193B074. 31 [NPS] National Park Service. 2018b. 2017 National Park Visitor Spending Effects. Natural 32 Resource Report NPS/NRSS/EQD/NRR2018/1616. April 2018. 56 p. Available at 33 <https://www.nps.gov/nature/customcf/NPS_Data_Visualization/docs/NPS_2017_Visitor_Spend 34 ing_Effects.pdf> (accessed September 7, 2018). 35 [NPS] National Park Service. 2019. Letter from R. Vogel, Regional Director, NPS, to 36 B. Beasley, Chief, Environmental Review and NEPA Branch, NRC, providing comments on 37 portions of the preliminary draft Supplemental Environmental Impact Statement regarding 38 Florida Power & Light's subsequent license renewal application for Turkey Point Units 3 and 4. 39 March 5, 2019. ADAMS Accession No. ML19072A162. 40 [NRC] U.S. Nuclear Regulatory Commission. 1972. Final Environmental Statement related to 41 operation of Turkey Point Plant, Florida Power and Light Company. July 1972. ADAMS 42 Accession No. ML092030310. 43 [NRC] U.S. Nuclear Regulatory Commission. 1990. Severe Accident Risks: An Assessment 44 for Five U.S. Nuclear Power Plants. NUREG-1150, Volumes 1 and 2. December 31, 1990. 45 ADAMS Accession No. ML040140729. 6-23

1 [NRC] U.S. Nuclear Regulatory Commission. 1995a. Evaluation of Potential Severe Accidents 2 During Low Power and Shutdown Operation at Grand Gulf, Unit 1. NUREG/CR-6143. 3 July 1995. 4 [NRC] U.S. Nuclear Regulatory Commission. 1995b. Evaluation of Potential Severe Accidents 5 During Low Power and Shutdown Operations at Surry, Unit 1. NUREG/CR-6144. 6 October 1995. 7 [NRC] U.S. Nuclear Regulatory Commission. 1996. Generic Environmental Impact Statement 8 for License Renewal of Nuclear Plants, Final Report. NUREG-1437, Volumes 1 and 2. 9 May 1996. ADAMS Accession Nos. ML040690705 and ML040690738. 10 [NRC] U.S. Nuclear Regulatory Commission. 1997. Issuance for Public Comment of Proposed 11 Rulemaking for Shutdown and Fuel Storage Pool Operation. SECY-97-168. Washington, 12 D.C.: NRC. 125 p. July 30, 1997. Available at <https://www.nrc.gov/reading-rm/doc-13 collections/commission/secys/1997/secy1997-168/1997-168scy.pdf> (accessed 14 December 28, 2018). 15 [NRC] U.S. Nuclear Regulatory Commission. 1999. Generic Environmental Impact Statement 16 License Renewal of Nuclear Plants, Main Report, Section 6.3Transportation, Table 9.1, 17 Summary of findings on NEPA issues for license renewal of nuclear power plants. 18 NUREG-1437, Volume 1, Addendum 1. August 1999. 100 p. ADAMS Accession 19 No. ML040690720. 20 [NRC] U.S. Nuclear Regulatory Commission. 2001. Technical Study of Spent Fuel Pool 21 Accident Risk at Decommissioning Nuclear Power Plants. NUREG-1738. Washington, D.C.: 22 NRC. February 2001. ADAMS Accession No. ML010430066. 23 [NRC] U.S. Nuclear Regulatory Commission. 2002a. Final Generic Environmental Impact 24 Statement on Decommissioning of Nuclear Facilities: Supplement 1, Regarding the 25 Decommissioning of Nuclear Power Reactors. NUREG-0586, Volumes 1 and 2. 26 November 30, 2002. 516 p. ADAMS Accession Nos. ML023470327, ML023500228, 27 and ML023500295. 28 [NRC] U.S. Nuclear Regulatory Commission. 2002b. Letter from R. Auluck, NRC, to J. Stall, 29 FPL.

Subject:

Issuance of renewed facility operating Licenses Nos. DPR-31 and DPR-41 for 30 Turkey Point Nuclear Generating Units Nos. 3 and 4. June 6, 2002. ADAMS Accession 31 No. ML021550105. 32 [NRC] U.S. Nuclear Regulatory Commission. 2002c. Generic Environmental Impact 33 Statement for License Renewal of Nuclear Plants Regarding Turkey Point Plant Units 3 and 4, 34 Final Report. NUREG-1437, Supplement 5. January 2002. 669 p. ADAMS Accession 35 Nos. ML020280119, ML020280202, and ML020280226. 36 [NRC] U.S. Nuclear Regulatory Commission. 2002d. Florida Power and Light Company, 37 Docket No. 50-250, Turkey Point Nuclear Generating Unit No. 3, Renewed Facility Operating 38 License No. DPR-31. Revised June 14, 2018. ADAMS Accession No. ML052790649. 39 [NRC] U.S. Nuclear Regulatory Commission. 2004. Protecting Our Nation-Since 9-11-01. 40 NUREG/BR-0314. Washington, DC: NRC. September 2004. ADAMS Accession 41 No. ML042650352. 42 [NRC] U.S. Nuclear Regulatory Commission. 2005a. Frequently Asked Questions on License 43 Renewal of Nuclear Power Reactors. NUREG-1850. March 31, 2006. ADAMS Accession 44 No. ML061110022. 6-24

1 [NRC] U.S. Nuclear Regulatory Commission. 2005b. Staff Review of the National Academies 2 Study of the Health Risks from Exposure to Low Levels of Ionizing Radiation (BEIR VII). 3 SECY-05-0202. Washington D.C.: NRC. October 29, 2005. ADAMS Accession 4 No. ML052640532. 5 [NRC] U.S. Nuclear Regulatory Commission. 2006a. Backgrounder: Tritium, Radiation 6 Protection Limits, and Drinking Water Standards. February 2016. 7 p. ADAMS Accession 7 No. ML062020079. 8 [NRC] U.S. Nuclear Regulatory Commission. 2006b. Generic Environmental Impact Statement 9 for License Renewal of Nuclear Plants, Regarding Oyster Creek Nuclear Generating Station-10 Final Report. NUREG-1437, Supplement 28. 360 p. ADAMS No. ML070100234. 11 [NRC] U.S. Nuclear Regulatory Commission. 2012. Letter from J. Paige, NRC, to M. Nazar, 12 FPL.

Subject:

Turkey Point Units 3 and 4 - Issuance of Amendments Regarding Extended 13 Power Uprate (TAC Nos. ME4907 and ME4908). June 15, 2012. ADAMS Accession 14 No. ML11293A365. 15 [NRC] U.S. Nuclear Regulatory Commission. 2013a. Generic Environmental Impact 16 Statement for License Renewal of Nuclear Plants. Revision 1. NUREG-1437, Volumes 1, 2, 17 and 3. June 2013. 1,535 p. ADAMS Accession Nos. ML13106A241, ML13106A242, 18 and ML13106A244. 19 [NRC] U.S. Nuclear Regulatory Commission. 2013b. Standard Review Plans for 20 Environmental Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal. 21 Revision 1. NUREG-1555. June 2013. 325 p. ADAMS Accession No. ML13106A246. 22 [NRC] U.S. Nuclear Regulatory Commission. 2013c. LIC-203, Revision 3, Procedural 23 Guidance for Preparing Categorical Exclusions, Environmental Assessments, and Considering 24 Environmental Issues. June 24, 2013. 72 p. ADAMS Accession No. ML12234A708. 25 [NRC] U.S. Nuclear Regulatory Commission. 2013d. Memorandum and Order in the Matter of 26 Exelon Generation Company, LLC (Limerick Generating Station, Units 1 and 2). CLI-13-07. 27 October 31, 2013. ADAMS Accession No. ML13304B417. 28 [NRC] U.S. Nuclear Regulatory Commission. 2013e. Order Modifying Licenses with Regard to 29 Reliable Hardened Containment Vents Capable of Operation Under Severe Accident 30 Conditions. NRC Order Number EA-13-109. June 6, 2013. ADAMS Accession 31 No. ML13130A067. 32 [NRC 2013] U.S. Nuclear Regulatory Commission. 2013f. Memorandum of Understanding 33 Between NRC and OSHA for NRC-Regulated Facilities. Final Report. October 2013. ADAMS 34 Accession No. ML11354A432. 35 [NRC] U.S. Nuclear Regulatory Commission. 2014a. Probabilistic Seismic Hazard Analysis: 36 Background Information. May 20, 2014. 6 p. ADAMS Accession No. ML14140A648. 37 [NRC] U.S. Nuclear Regulatory Commission. 2014b. Letter from A. Klett, NRC, to M. Nazar, 38 NextEra Energy,

Subject:

Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Issuance of 39 Amendments under Exigent Circumstances Regarding Ultimate Heat Sink and Component 40 Cooling Water Technical Specifications (TAC Nos. MF4392 and MF4393). April 8, 2014. 41 ADAMS Accession No. ML14199A107. 42 [NRC] U.S. Nuclear Regulatory Commission. 2014c. Generic Environmental Impact 43 Statement for Continued Storage of Spent Nuclear Fuel. NUREG-2157, Volumes 1 and 2. 44 September 2014. 1404 p. ADAMS Accession No. ML14198A440. 6-25

1 [NRC] U.S. Nuclear Regulatory Commission. 2014d. Turkey Point Nuclear Generating Unit 2 Nos 3 And 4- Issuance Of Amendments Under Exigent Circumstances Regarding Ultimate Heat 3 Sink And Component Cooling Water Technical Specifications (TAC NOS. MF4392 and 4 MF4393)). August 8, 2014. ADAMS Accession No. ML14199A107. 5 [NRC] U.S. Nuclear Regulatory Commission. 2015a. Biological Assessment for the U.S. Fish 6 and Wildlife Service, Prepared by the U.S. Nuclear Regulatory Commission and the U.S. Army 7 Corps of Engineers for Florida Power and Light Company, Turkey Point Units 6 and 7 Nuclear 8 Project, Combined License Application, Docket Nos. 052-040 and 052-041 and Permit 9 Application No. SAJ-2009-02417. February 2015. 97 p. ADAMS Accession 10 No. ML15028A372. 11 [NRC] U.S. Nuclear Regulatory Commission. 2015b. Biological Assessment for the National 12 Marine Fisheries Service, Turkey Point Nuclear Plant, Units 6 and 7 Combined License 13 Application. February 2015. 85 p. ADAMS Accession No. ML15028A378. 14 [NRC] U.S. Nuclear Regulatory Commission. 2015c. Essential Fish Habitat Assessment for 15 the National Marine Fisheries Service, Turkey Point Nuclear Plant Units 6 and 7 Combined 16 License Application. February 2015. 55 p. ADAMS Accession No. ML15028A395. 17 [NRC] U.S. Nuclear Regulatory Commission. 2015d. Letter from A. Klett, NRC, to M Nazar, 18 NextEra Energy.

Subject:

Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Issuance of 19 Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection 20 Program in Accordance with Title 10 of the Code of Federal Regulations Section 50.48(c). 21 May 28, 2015. ADAMS Accession No. ML15061A237. 22 [NRC] U.S. Nuclear Regulatory Commission. 2016a. Environmental Impact Statement for 23 Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7, Final Report. 24 October 2016. 2,092 p. ADAMS Accession No. ML16335A219. 25 [NRC] U.S. Nuclear Regulatory Commission. 2016b. Staff Assessment by the Office of 26 Nuclear Reactor Regulation Related to Seismic Hazard and Screening Report, Turkey Point 27 Nuclear Generating, Unit Nos. 3 and 4. January 22, 2016. ADAMS Accession 28 No. ML16013A472. 29 [NRC] U.S. Nuclear Regulatory Commission. 2016c. Letter from F. Vega, NRC, to M. Nazar, 30 NextEra.

Subject:

Turkey Point Nuclear Generating, Unit Nos. 3 and 4 - Staff Review of 31 Mitigation Strategies Assessment Report of the Impact of the Reevaluated Seismic Hazard 32 Developed in Response to the March 12, 2012, 50.54(f) Letter. June 16, 2016. ADAMS 33 Accession No. ML16166A321. 34 [NRC] U.S. Nuclear Regulatory Commission. 2016d. Letter from M. Halter, NRC, to M. Nazar, 35 NextEra.

Subject:

Turkey Point Nuclear Generating, Units 3 and 4 - Safety Evaluation 36 Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool 37 Instrumentation Related to Orders EA-12-049 and EA-12-051. October 28, 2016. ADAMS 38 Accession No. ML16279A455. 39 [NRC] U.S. Nuclear Regulatory Commission. 2017a. Design Certification Application-40 NuScale. Page updated October 24, 2017. Available at <https://www.nrc.gov/reactors/new-41 reactors/design-cert/nuscale.html> (accessed September 13, 2018). 42 [NRC] U.S. Nuclear Regulatory Commission. 2017b. Turkey Point Unit 3 and Unit 4, Docket 43 Nos. 50-250 and 50-251, Flooding Focused Evaluation Summary. June 29, 2017. ADAMS 44 Accession Number ML17212B180. 6-26

1 [NRC] U.S. Nuclear Regulatory Commission. 2018a. Letter from G. Wilson, NRC, to M. Nazar, 2 FPL.

Subject:

Turkey Point Nuclear Generating Units Nos. 3 and 4 - Determination of 3 Acceptability and Sufficiency for Docketing, Proposed Review Schedule, and Opportunity for a 4 Hearing Regarding the Florida Power & Light Companys Application for Subsequent License 5 Renewal. April 26, 2018. ADAMS Accession No. ML18003A050. 6 [NRC] U.S. Nuclear Regulatory Commission. 2018b. Not used. 7 [NRC] U.S. Nuclear Regulatory Commission. 2018c. Letter from L. James, NRC, to M. Nazar, 8 FPL.

Subject:

Summary of the Environmental Site Audit Related to the Review of the 9 Subsequent License Renewal Application for Turkey Point Nuclear Generating Units Nos. 3 10 and 4. July 20, 2018. ADAMS Accession No. ML18178A229. 11 [NRC] U.S. Nuclear Regulatory Commission. 2018d. Letter from L. James, NRC, to M. Nazar, 12 FPL.

Subject:

Turkey Point Nuclear Generating Units 3 and 4 - Summary of the In-Office 13 Regulatory Audit Regarding Severe Accident Mitigation Alternatives in the Subsequent License 14 Renewal Application. August 31, 2018. ADAMS Accession No. ML18214A146. 15 [NRC] U.S. Nuclear Regulatory Commission. 2018e. Issued Combined Licenses for Turkey 16 Point, Units 6 and 7 Application. Page updated April 26, 2018. Available at 17 <https://www.nrc.gov/reactors/new-reactors/col/turkey-point.html> (accessed 18 September 6, 2018). 19 [NRC] U.S. Nuclear Regulatory Commission. 2018f. Docket Nos. 52-040 and 52-041, 20 Combined License Application for Turkey Point Units 6 and 7, Summary Record of Decision. 21 April 12, 2018. 13 p. ADAMS Accession No. ML17333A164. 22 [NRC] U.S. Nuclear Regulatory Commission. 2018g. Teleconference Summary between 23 M. Moser, Biologist, NRC and L. Nester, Biologist, FWS. Call held on September 6, 2018. 24 ADAMS Accession No. ML18270A154. 25 [NRC] U.S. Nuclear Regulatory Commission. 2018h. Occupational Radiation Exposure at 26 Commercial Nuclear Power Reactors and other Facilities 2016: Forty-ninth Annual Report. 27 NUREG-0713, Volume 38. May 2018. 237 p. ADAMS Accession No. ML18151A364. 28 [NRC] U.S. Nuclear Regulatory Commission. 2018i. Generic Environmental Impact Statement 29 for License Renewal of Nuclear Plants, Supplement 58, Regarding River Bend Station, Unit 1, 30 Draft Report for Comment. NUREG-1437, Supplement 58. May 2018. 401 p. ADAMS 31 Accession No. ML18143B736. 32 [NRC] U.S. Nuclear Regulatory Commission. 2018j. Letters from B. Beasley, NRC, to 33 B. Cypress, Miccosukee Tribe of Indians of Florida; J. Floyd, Muscogee (Creek) Nation; A.S. 34 Bryan, Poarch Band of Creek Indians; G. Chilcoat, Seminole Nation of Oklahoma; M.W. 35 Osceola, Seminole Nation Tribe of Florida; S. Cody, Office of Historic Preservation; R. Nelson, 36 Office of Federal Agency Programs; and T. Parsons, Florida Department of State.

Subject:

37 Request for Scoping Comments Concerning the Environmental Review of Turkey Point Nuclear 38 Plant, Units 3 and 4 Subsequent License Renewal Application. May 24, 2018. ADAMS 39 Accession Nos. ML18114A381, ML18114A204, ML18114A202, and ML18114A206. 40 [NRC] U.S. Nuclear Regulatory Commission. 2018k. Memorandum from N. Martinez, NRC, to 41 B. Beasley, NRC.

Subject:

Summary of July 2, 2018, Teleconference Between the 42 U.S. Nuclear Regulatory Commission and the Seminole Nation of Oklahoma Regarding the 43 Turkey Point Nuclear Generating Units 3 and 4 Subsequent License Renewal Application. 44 July 19, 2018. ADAMS Accession No. ML18190A179. 6-27

1 [NRC] U.S. Nuclear Regulatory Commission. 2018l. Memorandum from M. Moser, NRC, to 2 B. Beasley, NRC.

Subject:

Summary of June 18, 2018, Interagency Meeting Related to 3 Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4. 4 December 26, 2018. ADAMS Accession No. ML18360A445. 5 [NRC] U.S. Nuclear Regulatory Commission. 2018m. Letter from G. Wilson, NRC, to 6 J. Hanson and N. Ranek, NEI.

Subject:

Interim Endorsement of NEI 17-01, Industry Guideline 7 for Implementing the Requirements of 10 CFR Part 54 for Subsequent License Renewal and 8 NEI 17-04, Model SLR New and Significant Assessment Approach for SAMA. 9 January 31, 2018. ADAMS Accession No. ML18029A368. 10 [NRC] U.S. Nuclear Regulatory Commission. 2018n. Biological Assessment for the Turkey 11 Point Nuclear Generating Unit Nos. 3 and 4 Proposed Subsequent License Renewal. 12 December 2018. ADAMS Accession No. ML18344A008. 13 [NRC] U.S. Nuclear Regulatory Commission. 2018o. Request for Formal Consulation under 14 the Endangered Species Act Regarding the Proposed Subsequent License Renewal of Turkey 15 Point Nuclear Generating Unit Nos. 3 and 4. December 19, 2018. ADAMS Accession No. 16 ML18333A205. 17 [NRC] U.S. Nuclear Regulatory Commission. 2019. Supplemental Environmental Impact 18 Statement Scoping Process, Summary Report, Turkey Point Nuclear Generating Unit Nos. 3 19 and 4, Miami-Dade County, Florida. January 2019. ADAMS Accession No. ML18342A014. 20 [NREL] National Renewable Energy Laboratory. 2013. Land-Use Requirements for Solar 21 Power Plants in the United States. Golden, Colorado: National Renewable Energy Laboratory. 22 NREL/TP-6A20-56290. June 2013. 47 p. Available at 23 <http://www.nrel.gov/docs/fy13osti/56290.pdf> (accessed August 30, 2018). 24 [NREL] National Renewable Energy Laboratory. 2014. Concentrating Solar Power Projects in 25 the United States. Available at <https://solarpaces.nrel.gov/by-country/US> (accessed 26 June 4, 2018). 27 [NREL] National Renewable Energy Laboratory. 2017. Global Horizontal Solar Resource of 28 Florida. April 4, 2017. Available at <http://www.nrel.gov/gis/solar.html> (accessed 29 September 12, 2018). 30 [NuScale] NuScale Power, LLC. 2018. NuScale FAQs. Available at 31 <http://www.nuscalepower.com/about-us/faqs#p1a5> (accessed September 13, 2018). 32 [OIPP] Office of Innovative Partnerships and Alternate Funding, Highway Division, Oregon 33 Department of Transportation, State of Oregon. 2010. Health and Safety Concerns of 34 Photovoltaic Solar Panels. Salem, Oregon. Available at <https://www.ssti.us/wp/wp-35 content/uploads/2016/09/Health_and_Safety_Concerns_of_Photovoltaic_Solar_Panels_2010_ 36 OR.pdf> (accessed September 10, 2018). 37 Occupational Safety and Health Act of 1970, as amended. 29 U.S.C. 651 et seq. 38 [ORNL] Oak Ridge National Laboratory. 2012. An Assessment of Energy Potential at 39 Non-Powered Dams in the United States. Oak Ridge, TN: ORNL. April 2012. 44 p. Available 40 at <http://www1.eere.energy.gov/water/pdfs/npd_report.pdf> (accessed September 14, 2018). 41 Parris A., et al. 2012. Global Sea Level Rise Scenarios for the United States National Climate 42 Assessment. NOAA Technical Report OAR CPO-1. Silver Spring, MD: Climate Program 43 Office. December 6, 2012. 33 p. Available at 44 <http://scenarios.globalchange.gov/sites/default/files/NOAA_SLR_r3_0.pdf> (accessed 45 August 24, 2018). 6-28

1 [PEI] Power Engineering International. 2017. South Korea fuel cell CHP plant comes online. 2 March 21, 2017. Available at <http://www.powerengineeringint.com/articles/2017/03/south-3 korea-fuel-cell-chp-plant-comes-online.html> (accessed 28 August 2018). 4 [Port Miami] Port Miami. 2017. 2016 Local and Regional Economic Impacts of PortMiami: 5 Executive Summary. Martin Associates. April 12, 2017. 4 p. Available at 6 <http://www.miamidade.gov/portmiami/library/reports/2016-economic-impact-executive-7 summary.pdf> (accessed September 11, 2018). 8 Prinos, S.T. 2017. Map of the approximate inland extent of saltwater at the base of the 9 Biscayne aquifer in the Model Land Area of Miami-Dade County, Florida, 2016. Lutz, FL: U.S. 10 Geological Survey. Scientific Investigations Map 3380, 8 p. Pamphlet, 1 sheet. Available at 11 <https://pubs.er.usgs.gov/publication/sim3380> (accessed July 7, 2018). 12 Prinos S.T., Wacker M.A., Cunningham K.J., Fitterman D.V. 2014. Origins and Delineation of 13 Saltwater Intrusion in the Biscayne Aquifer and Changes in the Distribution of Saltwater in 14 Miami-Dade County, Florida. Reston, VA: U.S. Geological Survey. 2014. Scientific 15 Investigations Report 2014-5025. 116 p. Available at <http://dx.doi.org/10.3133/sir20145025> 16 (accessed July 7, 2018). 17 Resource Conservation and Recovery Act of 1976, as amended, 42 U.S.C § 6901 et seq. 18 Robles, M.D., Armentano T., DiResta D., Lara M.R., Jones D.L. Butler, M.J. 2005. Condition 19 of the Natural Resources of Biscayne National Park. A State of the Parks Technical Report, 20 NatureServe. Arlington, Virginia. May 2005. Available at 21 <http://www.marine.usf.edu/user/djones/pubs/Robles_etal_2005b.pdf> (accessed 22 June 12, 2018). 23 Runkle, J., et al. 2017. Florida State Climate Summary. NOAA Technical Report NESDIS 24 149-FL. 5 p. Available at <https://statesummaries.ncics.org/fl> (accessed 25 September 16, 2018). 26 Safe Drinking Water Act of 1974, as amended. 42 U.S.C § 300F et seq. 27 [SAFMC and NMFS] South Atlantic Fishery Management Council and National Marine Fisheries 28 Service. 2016. Users Guide to Essential Fish Habitat Designations by the South Atlantic 29 Fisheries Management Council. November 2016, Revised August 2017. 24 p. Available at 30 <http://safmc.net/download/SAFMCEFHUsersGuideFinalRevAug17_2.pdf> (accessed 31 July 26, 2018). 32 [SFRCCC] Southeast Florida Regional Climate Change Compact, Sea Level Rise Work Group 33 (Compact). 2015. Unified Sea Level Rise Projection for Southeast Florida. October 2015. 34 35 p. Available at <http://www.southeastfloridaclimatecompact.org/wp-35 content/uploads/2015/10/2015-Compact-Unified-Sea-Level-Rise-Projection.pdf> (accessed 36 August 10, 2018). 37 [SFWMD] South Florida Water Management District. 2009. FPL Turkey Point Power Plant, 38 Groundwater, Surface Water, and Ecological Monitoring Plan. October 14, 2009. ADAMS 39 Accession No. ML12193A539. 40 [SFWMD] South Florida Water Management District. 2011a. Water Quality Characterization of 41 Southern Miami-Dade County and Nearby FPL Turkey Point Power Plant, Miami-Dade County, 42 Florida. Technical Publication WS-31. July 2011. 224 p. Available at 43 <https://www.sfwmd.gov/document/ws-31-water-quality-characterization-southern-miami-dade-44 county-and-nearby-fpl-turkey> (accessed September 10, 2018). 6-29

1 [SFWMD] South Florida Water Management District. 2011b. Resolution No. 2011-927B. 2 Available at 3 <https://www.sfwmd.gov/sites/default/files/documents/fy12_trim_gb_resolution_okeechobee_ba 4 sin.pdf> (accessed May 1, 2018). 5 [SFWMD] South Florida Water Management District. 2012. Overview and Current Use of the 6 Floridan Aquifer System in the Lower East Coast. Public Workshop, Pompano Beach, Florida. 7 April 18, 2012. 56 p. Available at 8 <https://www.sfwmd.gov/sites/default/files/documents/fas_lec_041812_final_pjk.pdf> (accessed 9 August 17, 2018). 10 [SFWMD] South Florida Water Management District. 2013. South Florida Water Management 11 District Patrol Summary, Model Lands. October 18-31, 2013. West Palm Beach, FL. ADAMS 12 Accession No. ML14328A521. 13 [SFWMD] South Florida Water Management District. 2015. Applicants Handbook for Water 14 Use Permit Applications Within the South Florida Water Management District. Effective 15 September 7, 2015. 115 p. Available at <https://www.sfwmd.gov/doing-business-with-16 us/permits/water-use-permits> (accessed July 7, 2018). 17 [SFWMD] South Florida Water Management District. 2017a. Water Use Individual Permit, 18 Permit Number 13-0625-W, Florida Power and Light Turkey Point Groundwater Recovery Well 19 System, and Water Use Staff Report. Issued February 27, 2017. Available at 20 <http://my.sfwmd.gov/ePermitting/PopulateLOVs.do?flag=1> (search permit # 13-06251-W) 21 (accessed August 1, 2018). 22 [SFWMD] South Florida Water Management District. 2017b. Water Use Individual Permit, 23 Permit Number 13-06343-W, Atlantic Civil Inc. Freshwater Injection, and Water Use Staff 24 Report. Date Issued May 9, 2017. Available at 25 <http://my.sfwmd.gov/ePermitting/PopulateLOVs.do?flag=1> (search permit # 13-06343-W) 26 (accessed August 24, 2018). 27 [Smithsonian] Smithsonian Institution Marine Station at Fort Pierce. 2009. Uca rapax, Mudflat 28 Fiddler Crab. Available at <https://naturalhistory2.si.edu/smsfp/irlspec/Uca_rapax.htm> 29 (accessed September 13, 2018). 30 [SNO] The Seminole Nation of Oklahoma. 2018. Response to Request for Scoping Comments 31 Concerning the Environmental Review of Turkey Point Nuclear Plant, Units 3 and 4 Subsequent 32 License Renewal Application. June 12, 2018. ADAMS Accession No. ML18169A152. 33 Specziar A. 2004. Life history pattern and feeding ecology of the introduced eastern 34 mosquitofish, Gambusia holbrookii, in a thermal spa under temperature climate, of Lake Heviz, 35 Hungary. Hydrobiologia 522:249-260. DOI: 10.1023/B:HYDR.0000029978.46013.d1. 36 Srean P., Almeida D., Rubio-Gracia F., Luo Y., Garcia-Berthou E. 2016. Effects of size and 37 sex on swimming performance and metabolism of invasive mosquitofish Gambusia holbrooki. 38 Ecology of Freshwater Fishes 26(3):424-433. April 27, 2016. DOI: 10.1111/eff.12286. 39 State of Florida Siting Board. 2014. Final Order on Certification, In Re: Florida Power & Light 40 Company Turkey Point Units 6 & 7 Power Plant Siting Application No. PA 03-45A3. OGC Case 41 No. 09-3107, Division of Administrative Hearings Case No. 09-03575EPP. May 19, 2014. 42 ADAMS Accession No. ML14345A291. 43 State of Florida Siting Board. 2016. Final Order, Florida Power and Light Company Turkey 44 Point Power Plant Units 3 - 5 Modification to Conditions of Certification. OGC Case 45 No. 14-0510, DOAH Case No. 15-1559EPP. April 1, 2016. Available at 46 <https://floridadep.gov/ogc/ogc/documents/14-0510> (accessed July 7, 2018). 6-30

1 [STOF] Seminole Tribe of Florida. 2018. Response to Request for Scoping Comments 2 Concerning the Environmental Review of Turkey Point Nuclear Plant, Units 3 and 4 Subsequent 3 License Renewal Application. July 3, 2018. ADAMS Accession No. ML18184A462. 4 Strawn K., Dunn J.E. 1967. Resistance of Texas salt- and freshwater-marsh fishes to heat 5 death at various salinities. Texas Journal of Science 19:57-76. 6 Tao Z., et al. 2007. Sensitivity of U.S. surface ozone to future emissions and climate 7 changes. Geophysical Research Letters, 34(8):L08811. DOI: 10.1029/2007GL029455. 8 [Tetra Tech] Tetra Tech NUS, Inc. 2009. Final Fish Surveys of the Turkey Point Property 9 Associated with Units 6 & 7, June 23-24, 2009. July 2009. ADAMS Accession 10 No. ML11168A043. 11 [Tetra Tech] Tetra Tech NUS Inc. 2014a. Technical Memorandum from P.F. Andersen and 12 J.L. Ross, Tetra Tech, to R,. Rahming, FPL, dated May 9, 2014, regarding Evaluation of 13 Required Floridan Water for Salinity Reduction in the Cooling Canal System. Pasadena, 14 California. ADAMS Accession No. ML14279A555. 15 [Tetra Tech] Tetra Tech NUS Inc. 2014b. Technical Memorandum from P. F. Andersen and J. 16 Ross, Tetra Tech, to R. Rahming, Florida Power & Light Company.

Subject:

Evaluation of 17 Drawdown in the Upper Floridan Aquifer Due to Proposed Salinity Reduction-based 18 Withdrawals. November 13, 2014. In: In: FPL 2018n, SLRA Appendix E Section 4.5.3.4 19 Supplemental Information, L-2018-086, Attachment 1, Enclosure 1. ADAMS Accession 20 No. ML18102A521. 21 [Tetra Tech] Tetra Tech NUS Inc. 2016. A Groundwater Flow and Salt Transport Model of the 22 Biscayne Aquifer. June 2016. 53 p. Attachment to email from W. Mayorga, Miami-Dade 23 Regulatory and Economic Resources, to J. Truitt, FDEP.

Subject:

FW: Supplemental 24 Groundwater Model Documentation. June 13, 2016. Available at 25 <http://ecmrer.miamidade.gov:8080/hpi/search> (search Case Number: HWR-00851, Date: 26 6/13/2016) (accessed August 1, 2018). 27 [Tetra Tech] Tetra Tech NUS Inc. 2018. Variable Density Ground Water Flow and Salinity 28 Transport Model Analysis, Attribution Analysis Results. June 19, 2018. 34 p. In: FPL 2018h, 29 FPL Response to NRC RAI No. WR-12, L-2018-136 Attachment 53 Enclosure 1. ADAMS 30 Accession No. ML18247A566. 31 Timmerman C.M., Chapman L.J. 2004. Behavioral and physiological compensation for chronic 32 hypoxia in the sailfin molly (Poecilia latipinna). Physiological and Biochemical Zoology 33 77(4):601-610. DOI: 10.1086/421754. 34 [Traf Tech] Traf Tech Engineering, Inc. 2009. Turkey Point Power Plant Peak Construction 35 Analysis. June 2009. 82 p. ADAMS Accession No. ML16167A504. 36 [USCG] U.S. Coast Guard. 2018. National Response Center, 2018 Reports. Available at 37 <http://www.nrc.uscg.mil/> (accessed July 20, 2018). 38 [UF] University of Florida. 2018a. Handbook of Florida Water Regulation: State Groundwater 39 Discharge Regulations. FE601. Available at <http://edis.ifas.ufl.edu/pdffiles/FE/FE60100.pdf> 40 (accessed July 18, 2018). 41 [UF] University of Florida. 2018b. Sawgrass Marshes. Available at 42 <https://www.floridamuseum.ufl.edu/southflorida/habitats/freshwater-marshes/sawgrass-43 marshes/> (accessed on August 27, 2018). 6-31

1 [USACE and SFWMD] U.S. Army Corps of Engineers and South Florida Water Management 2 District. 2011. Central and Southern Florida Project, Comprehensive Everglades Restoration 3 Plan, Biscayne Bay Coastal Wetlands Phase 1 Final Integrated Project Implementation Report 4 and Environmental Impact Statement, Volume 1 - Main Report. July 2011. 556 p. ADAMS 5 Accession No. ML12270A058. 6 [USCB] U.S. Census Bureau. 1990. 1990 Census of Population, General Population 7 Characteristics: Florida. Available at <https://www.census.gov/programs-surveys/decennial-8 census/decade.1990.html> (accessed August 8, 2018). 9 [USCB] U.S. Census Bureau. 1996. Population of States and Counties of the Unites States: 10 1790 to 1990. Available at <https://www.census.gov/population/www/censusdata/pop1790-11 1990.html> (accessed May 4, 2018). 12 [USCB] U.S. Census Bureau. 2000a. Census 2000: Summary File 2. Available at 13 <https://www.census.gov/census2000/sumfile2.html> (accessed June 6, 2018). 14 [USCB] U.S. Census Bureau. 2000b. Profile of General Demographic Characteristics: 2010 15 Florida. Available at 16 <http://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> 17 (August 8, 2018). 18 [USCB] U.S. Census Bureau. 2010a. Profile of General Population and Housing 19 Characteristics: 2010, Miami-Dade County, Table DP-1. Available at 20 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 21 July 10, 2018). 22 [USCB] U.S. Census Bureau. 2010b. Profile of General Population and Housing 23 Characteristics: 2010, Florida, Table DP-1. Available at 24 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 25 August 8, 2018). 26 [USCB] U.S. Census Bureau. 2010c. Profile of General Demographic Characteristics: 2010, 27 Broward County. Table DP-1. Available at 28 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 29 August 24, 2018). 30 [USCB] U.S. Census Bureau. 2011. American FactFinder, 2011 American Community Survey 31 1-Year Estimates, Table DP03 - Selected Economic Characteristics, for Miami-Dade County 32 and State of Florida. Available at: 33 https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 34 May 2, 2018). 35 [USCB] U.S. Census Bureau. 2016a. American FactFinder, 2016 American Community Survey 36 1-Year Estimates, Table DP03 - Selected Economic Characteristics for Miami-Dade County 37 and State of Florida. Available at: 38 https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t (accessed 39 May 2, 2018). 40 [USCB] U.S. Census Bureau. 2016b. American FactFinder, 2016 American Community Survey 41 1-Year Estimates, Table DP5 - Demographic and Housing Estimates for Miami-Dade, 42 Monroe, Broward, and Collier Counties. 43 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 44 May 4, 2018). 6-32

1 [USCB] U.S. Census Bureau. 2016c. American FactFinder, 2016 American Community Survey 2 1-Year Estimates, Table S1401 - School Enrollment for Miami-Dade County. Available at: 3 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 4 June 7, 2018). 5 [USCB] U.S. Census Bureau. 2016d. American FactFinder, 2016 American Community Survey 6 1-Year Estimates, Table B25002 - Occupancy Status for Miami-Dade, Monroe, Broward, and 7 Collier Counties. Available at 8 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 9 May 4, 2018). 10 [USCB] U.S. Census Bureau. 2016e. American FactFinder, 2016 American Community Survey 11 1-Year Estimates, Table DP4 - Selected Housing Characteristics for Miami-Dade County. 12 Available at <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> 13 (accessed May 4, 2018). 14 [USCB] U.S. Census Bureau. 2016f. American FactFinder, 2012-2016 American Community 15 Survey 5-Year Estimates, Table DP3 - Selected Economic Characteristics. Available at: 16 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 17 July 12, 2018). 18 [USCB] U.S. Census Bureau. 2016g. Poverty Thresholds by Size of Family and Number of 19 Related Children Under 18 Years. Available at <https://www.census.gov/data/tables/time-20 series/demo/income-poverty/historical-poverty-thresholds.html> (accessed July 9, 2018). 21 [USCB] U.S. Census Bureau. 2016h. American FactFinder, 2012-2016 American Community 22 Survey 5-Year Estimates, Table DP4 - Selected Housing Characteristics and Table DP03 - 23 Selected Economic Characteristics for Broward County. Available at 24 <https://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 25 August 10, 2018). 26 [USCB] U.S. Census Bureau. 2018. American FactFinder, 2012-2016 American Community 27 Survey 5-Year Estimates, Table DP03 - Selected Economic Characteristics for Broward 28 County. Available at: 29 <http://factfinder.census.gov/faces/nav/jsf/pages/searchresults.xhtml?refresh=t> (accessed 30 24 August 2018). 31 [USGCRP] U.S. Global Change Research Program. 2009. Global Climate Change Impacts in 32 the United States. New York, NY: NOAA National Climatic Data Center. June 2009. 196 p. 33 Available at <https://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf> 34 (accessed August 10, 2018). 35 [USGCRP] U.S. Global Change Research Program. 2014. Climate Change Impacts in the 36 United States: The Third National Climate Assessment. Washington, DC: Federal National 37 Climate Assessment and Development Advisory Committee. May 2014. Revised 38 October 2014. 841 p. DOI: 10.7930/J0Z31WJ2. Available at 39 <https://www.globalchange.gov/nca3-downloads-materials> (accessed August 10, 2018). 40 [USGCRP] U.S. Global Change Research Program. 2017. Climate Science Special Report: 41 Fourth National Climate Assessment, Volume 1. Washington, DC: USGCRP. 2017. 470 p. 42 DOI: 10.7930/J0J964J6. Available at 43 <https://science2017.globalchange.gov/downloads/CSSR2017_FullReport.pdf> (accessed 44 August 10, 2018). 6-33

1 [USDA] U.S. Department of Agriculture. 2012. Agricultural Census. Available at 2 <https://www.agcensus.usda.gov/Publications/2012/Full_Report/Volume_1,_Chapter_2_County 3 _Level/> (accessed May 4, 2018). 4 [USDA] U.S. Department of Agriculture. 2017. Custom Soil Resource Report for Turkey Point 5 Power Plants. April 27, 2018. Available at 6 <http://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx> (accessed April 27, 2018). 7 [USGS] U.S. Geological Survey. 2001. Simulation of Ground-Water Discharge to Biscayne 8 Bay, Southeastern Florida. Water-Resources Investigations Report 2000-4251. Available at 9 <https://pubs.er.usgs.gov/publication/wri004251> (accessed May 25, 2018). 10 [USGS] U.S. Geological Survey. 2008a. Assessment of Moderate- and High-Temperature 11 Geothermal Resources of the United States. Menlo Park, CA: USGS. Fact Sheet 2008-3082. 12 2008. 4 p. Available at <http://pubs.usgs.gov/fs/2008/3082/pdf/fs2008-3082.pdf> (accessed 13 September 6, 2018). 14 [USGS] U.S. Geological Survey. 2008b. U.S. Geological Survey Science Support Strategy for 15 Biscayne National Park and Surrounding Areas in Southeastern Florida. Open-File Report 16 2007-1288. 2008. 54 p. Available at <https://pubs.usgs.gov/of/2007/1288/pdf/ofr2007-17 1288_lowrez.pdf> (accessed May 25, 2018). 18 [USGS] U.S. Geological Survey. 2018a. Data tables summarizing the source-specific 19 estimated water withdrawals in Florida by category, county, and water management district, 20 2015. DOI: 10.5066/F7N29W5M. Available at 21 <https://www.sciencebase.gov/catalog/item/5a4cdec8e4b0d05ee8c4cabf> (accessed 22 August 1, 2018). 23 [USGS] U.S. Geological Survey. 2018b. South Florida Information Access: Mineral 24 Resources. Page updated April 30, 2018. Available at 25 <https://sofia.usgs.gov/publications/reports/rali/mineral.html> (accessed April 30, 2018). 26 Vernberg F.J., Tashian R.E. 1959. Studies on the physiological variation between tropical and 27 temperate zone fiddler crabs of the genus Uca I. Thermal death limits. Ecology 40(4):589-593. 28 DOI: 10.2307/1929812. 29 Wagner K.C., Gauntt R.O. 2006. Mitigation of Spent Fuel Pool Loss-of-Coolant Inventory 30 Accidents and Extension of Reference Plant Analyses to Other Spent Fuel Pools. 31 Albuquerque, NM: Sandia National Laboratories. November 2006. 120 p. ADAMS Accession 32 No. ML120970086. 33 Zanders I.P., Rojas W.E. 1996. Osmotic and ionic regulation in the fiddler crab Uca rapax 34 acclimated to dilute and hypersaline seawater. Marine Biology 125:315-320. 35 DOI: 10.1007/BF00346312. 36 Wu S., et al. 2008. Effects of 2000-2050 global change on ozone air quality in the United 37 States. Journal of Geophysical Research 113:D06302. DOI: 10.1029/2007JD008917. 38 Zhang Y., Wang Y. 2016. Climate-driven ground-level ozone extreme in the fall over the 39 Southeast United States. Proceedings of the National Academy of Sciences of the United 40 States of America 133(36):10025-10030. DOI: 10.1073/pnas.1602563113. 6-34

1 7 LIST OF PREPARERS 2 Members of the U.S. Nuclear Regulatory Commissions (NRCs) Office of Nuclear Reactor 3 Regulation (NRR) prepared this supplemental environmental impact statement with assistance 4 from other NRC organizations and support from Pacific Northwest National Laboratory. 5 Table 7-1 below identifies each contributors name, affiliation, and function or expertise. 6 Table 7-1 List of Preparers Name Education/Experience Function or Expertise NRC Staff (in alphabetical order) Benjamin Beasley M.S. Nuclear Engineering; B.S. Chemical Management Oversight Engineering; 27 years of combined industry and Government experience including nuclear plant system analysis, risk analysis, and project management, with 13 years of management experience Phyllis Clark M.S. Nuclear Engineering; M.B.A, Business Radiological and Waste Administration; B.S. Physics; 35 years of Management industry and Government experience including nuclear power plant and production reactor operations, systems engineering, reactor engineering, fuels engineering, criticality, power plant emergency response Jerry Dozier M.S. Reliability Engineering; M.B.A. Severe Accident Mitigation Business Administration; B.S. Mechanical Alternative (SAMA) Engineering; 30 years of experience including operations, reliability engineering, technical reviews David Drucker M.S. Engineering Management; Project Management B.S. General Engineering; 37 years managing projects Kevin Folk M.S. Environmental Biology; B.A. Groundwater; Greenhouse Gas Geoenvironmental Studies; 29 years of Emissions and Climate Change experience in NEPA compliance; geologic, hydrologic, and water quality impacts analysis; utility infrastructure analysis, environmental regulatory compliance; and water supply and wastewater permitting William Ford M.S. Geology; 44 years of combined Geology; Surface Water industry and Government experience working on groundwater, surface water, and geology projects Briana Grange Masters Certification - National Aquatic Resources; Terrestrial Environmental Policy Act; B.S. Resources; Special Status Conservation Biology; 13 years of Species and Habitats; experience in environmental impact Microbiological Hazards analysis, Section 7 consultations, and essential fish habitat consultations Robert Hoffman B.S. Environmental Resource Management; Alternatives; Meteorology and Air 33 years of experience in NEPA Quality 7-1

Name Education/Experience Function or Expertise compliance, environmental impact assessment, alternatives identification and development, and energy facility siting Lois James M.S. Environmental Engineering; Project Management B.S. Nuclear Engineering; 27 years of combined industry and Government experience including power plant inspection, power plant incident response, and project management Nancy Martinez B.S. Earth and Environmental Science; A.M. Historic and Cultural Resources; Earth and Planetary Science; 8 years of Socioeconomics; Environmental experience in environmental impact analysis Justice Michelle Moser M.S. Biological Sciences; B.S. Terrestrial Resources Environmental Sciences; 17 years of experience in ecological studies, environmental impact assessment, and protected resource management William Rautzen M.S. Health Physics; B.S. Health Physics; Human Health B.S. Industrial Hygiene; 9 years of experience in environmental impact analysis Jeffrey Rikhoff M.R.P. Regional Planning, M.S. Economic Land Use, Noise, and Cumulative Development and Appropriate Technology; Impacts Introduction 38 years of combined industry and Government experience including 31 years of NEPA compliance, socioeconomics and environmental justice impact analyses, cultural resource impact assessments, consultations with American Indian tribes, and comprehensive land-use and development planning studies Pacific Northwest National Laboratory Staff (in alphabetical order) Philip Meyer Ph.D. Civil Engineering; B.A. Physics; Groundwater Resources 27 years relevant experience in subsurface hydrology and contaminant transport Terri Miley M.S. Mathematics; B.S. Mathematics; Comment Response Support 13 years relevant experience in NEPA Lead comment-response and database development Rajiv Prasad Ph.D. Civil and Environmental Engineering; Surface Water Resources M. Tech. Civil Engineering; B.S. Civil Engineering; 15 years relevant experience in surface water use and quality characterization and assessment James Saulsbury M.S. Planning; B.A. History; Pacific Northwest National 31 years relevant experience in land use Laboratory Team Lead and socioeconomic impact assessment Paul Thorne M.S. Hydrology; B.S. Chemistry/Math; Groundwater Resources 34 years relevant experience in hydrogeology including analysis of groundwater flow and migration of contaminants in the subsurface 7-2

1 8 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO 2 WHOM COPIES OF THIS SEIS ARE SENT 3 Table 8-1 List of Agencies, Organizations, and Persons to Whom Copies of this SEIS 4 Are Sent Name and Title Affiliation and Address Aldridge, Jason, Supervisor of Federal and Florida Department of State State Compliance and Review, and Deputy 500 South Bronough Street SHPO R.A. Gray Building Tallahassee, FL 32399-0250 Andreacchio, Tonya Citizen Arditi-Rocha, Yoca Citizen Aronowitz, Karen Citizen Ayres, Richard E. Friends of the Earth 2923 Foxhall Road, NW. Washington, D.C. 20016 ayresr@ayreslawgroup.com Backhouse, Paul Seminole Tribe of Florida Tribal Historic Preservation Officer Ah-Ta-Thi-Ki Museum 30290 Josie Billie Hwy, PMB 1004 Clewiston, FL 33440 Baez-Hernandez, Sonia Citizen Baloyra, Enrique Citizen Barczak, Sara Southern Alliance for Clean Energy Regional Advocacy Director sara@cleanenergy.org Bauman, Laura Citizen Bausch, Joan Citizen Beck, Clyde Citizen Besford, Stacey Citizen Bonasia, Joseph Citizen Brainard, Wendy Citizen Brinkley, Brenda Citizen Bromfield, Chris Citizen Brown, Steven Citizen Bryan, Stephanie Poarch Band of Creek Indians Tribal Chair 5811 Jack Springs Road Atmore, AL 36502 Burke, Maureen Citizen Carter, Andrew Miami Waterkeeper 2103 Coral Way, 2nd Floor Miami, FL 33145 Cavros, George Citizen Chenoweth, Michael F. Friends of the Loxahatchee Refuge President P.O. Box 6777 Delray Beach, FL 33482-6777 8-1

Name and Title Affiliation and Address Chilcoat, Greg Seminole Nation of Oklahoma Principal Chief P.O. Box 1498 Wewoka, OK 74884 Clancy, Bonnie Citizen Cody, Sarah Office of Historic Preservation Chief Stephen P. Clark Center 111 NW 1st St. - 12th Floor Miami, FL 33128 Cook, Matthew Citizen Cosner, Zacharian Citizen Cox, Kelly Miami Waterkeeper 2103 Coral Way, 2nd Floor Miami, FL 33145 kelly@miamiwaterkeeper.org Culberson, Andrea Citizen Diane Curran Southern Alliance for Clean Energy Harmon, Curran, Spielberg, & Eisenberg, L.L.P. 1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com Cypress, Billy Miccosukee Tribe of Indians of Florida Chairman Tamiami Station P.O. Box 440021 Miami, FL 33144 Davidson, Maggie Citizen Dayhoff, Fred Miccosukee Tribe of Indians of Florida Section 106 and NAGPRA Coordinator HC61 SR Box 68 Old Loop Road Road Ochopee, FL 34141 Decker, Lesley Citizen Dehart, Jody Heriot Citizen deJong, Suki Citizen Dickey, Michael Citizen Nancy Diersing nancy.diersing@noaa.gov Echols, Darrell, Chief South East Region, Science and Natural Resource National Park Service Management darrell_echols@nps.gov Faehner, Bryan National Park Service, Southeast Region Energy & Environmental Protection MIB Room 2642 Specialist Atlanta Federal Center 1924 Building 100 Alabama St., SW. Atlanta, GA 30303 Fangman, Sarah NOAA Florida Keys National Marine Sanctuary 33 East Quay Road Key West, FL 33040 8-2

Name and Title Affiliation and Address Fettus, Geoffrey H. NRDC 1152 15th Street, NW, Suite 300 Washington, D.C. 20005 gfettus@nrdc.org Figueroa, Stephanie Citizen Finell, Jeffrey Citizen Finver, Jody Citizen Floyd, James Muscogee (Creek) Nation Principal Chief Office of the Administration P.O. Box 580 Okmulgee, OK 74447 Franzone, Steve Florida Power & Light Co. Licensing Manager Steve.Franzone@fpl.com Frazzini, Vincent Citizen Free, Cherie Citizen Fried, Jonathan Citizen Fuentes, Ettienne Citizen Furtak, Sarah sarah.furtak@noaa.gov Gale, Michelle Citizen Gandarilla, Eric Citizen Gardiner, Hannah Citizen Gates, Christopher Citizen Gibaldi, Mike Citizen Gold, Sheryl Citizen Gomez, Albert Citizen, albert@icassemblies.com Gonzales, Erik Citizen Gonzalez, Kimberly Citizen Goodro, Margaret, Superintendent National Park Service Biscayne National Park margaret_goodro@nps.gov Gorman, Emily Citizen Grams, Yvonne Citizen Grantham, Tiffany Citizen Grentzer, Kelsey Citizen Craig Grossenbacher Craig.Grossenbacher@miamidade.gov Gutierrez, Mary Citizen Hall, Michael Citizen Harper, Cecelia Ann U.S. Environmental Protection Agency US EPA Comprehensive Everglades harper.cecelia@epa.gov Restoration Plan Liaison Hefty, Lee Department of Regulatory and Economic Resources Director Division of Environmental Resources Management (DERM) 701 NW 1st Court, 4th Floor, Miami, Florida 33136 8-3

Name and Title Affiliation and Address Higgins, Jamie National Environmental Policy Act (NEPA) Program Office Project Manager Resource Conservation Restoration Division Region 4, Environmental Protection Agency 61 Forsyth Street, NW Atlanta, GA 30303 Hochkammer, Anna Village of Pinecrest Council Member 12645 Pinecrest Pkwy Pinecrest, FL 33156 Hopf, James Citizen Howard, Derek Assistant Monroe County Attorney Monroe County Attorneys Office 1111 12th Street, Suite 408 Key West, FL 33040 Telephone: (305) 292-3470 Howard-Derek@monroecounty-fl.gov Hunt, Melody National Park Service Hydrologist melody_hunt@nps.gov Ignetti, Gabriel Citizen Isham, Theodore Seminole Nation of Oklahoma Tribal Historic Preservation Officer P.O. Box 1498 Wewoka, OK 74884 Jacobs, Kim Citizen Jahosky, Jackie Citizen James, Jason Citizen Java, Theresa Florida Keys News Free Press Staff TJAVA@Keysnews.com Joannou Jr, Benjamin Citizen Johnson, Diane Citizen Kalson, Vince Emergency Management Radiological Emergency Preparedness Monroe County, Florida Administrator kalson-vince@monroecounty-fl.gov Kapur, Aruni Citizen Karazsia, Jocelyn jocelyn.karazsia@noaa.gov Kipnis, Dan Citizen Knowles, Yvonne Citizen Kocol, John Citizen Kotzig, Allison Citizen Landry, Ju Citizen Lennick, BrendaLee Citizen Levinson, David Citizen Levinson, Gilda Citizen Lighty, Ryan K. Esq. Morgan, Lewis & Bockius LLP 1111 Pennsylvania Ave, N.W. Washington, D.C. 20004 ryan.lighty@morganlewis.com Lopez, Jaclyn Center for Biological Diversity Florida Director jlopez@biologicaldiversity.org 8-4

Name and Title Affiliation and Address Lowe-Zepeda, Corain Muscogee (Creek) Nation Acting Tribal Historic Preservation Officer Cultural Preservation Office P.O. Box 580 Okmulgee, OK 74447 Macedo, Brenda Citizen Maher, William Florida Power & Light Company Senior Director, Licensing William.Maher@fpl.com Mahoney, Robert Citizen Marguardt, John Citizen Marin, Felipe Citizen Marin, Patricia Citizen Marquez, Orlando Citizen Martin, Drew Citizen Martinez, Jessica Citizen Masterson, Melanie Citizen McCluney, Ross Citizen McCormick, Jessica Citizen McLaughlin, Caroline National Parks Conservation Association Associate Director cmclaughlin@npca.org Menchaca, Victoria L. Seminole Tribe of Florida-THPO Compliance Review Specialist Compliance Review Section 30290 Josie Billie Hwy, PMB 1004 Clewiston, FL 33440 Mennel-Bell, Mari Citizen Messenger, Roger Citizen Metayer, Nancy Citizen Milone, Patricia Citizen Morse, Stephanie Florida Office of Public Counsel Associate Public Counsel morse.stephanie@leg.state.fl.us Murphy, Sylvia Citizen Nazar, Mano Florida Power & Light Company President and Chief Nuclear Officer Mail Stop EX/JB Nuclear Division 700 Universe Blvd Juno Beach, FL 33408 Nelson, Kent Citizen Neslon, Reid Office of Federal Agency Programs Director Advisory Council on Historic Preservation 401 F Street NW, Suite 308 Washington, DC 20001-2637 Nester, Lindsay, FWS Lindsay_Nester@fws.gov Nicholson, Carol Citizen O'Brien, Robert Citizen O'Keefe, Kevin Citizen Olivero, Carlos Citizen Olson, Brett Citizen 8-5

Name and Title Affiliation and Address ONeill, Martin J. Esq. Morgan, Lewis & Bockius LLP 1000 Louisiana St., Suite 4000 Houston, TX 77002 martin.oneill@morganlewis.com Orthen, Rick Florida Power & Light Company Richard.Orthen@fpl.com Osceola, Marcellus Seminole Tribe of Florida Chairman 6300 Stirling Road Hollywood, FL 330241 Oswald, T Citizen Parker, Michael Citizen Parra, Mana Citizen Penn, Jeremy Citizen Parsons, Timothy Florida Department of State State Historic Preservation Officer 500 South Bronough Street R.A. Gray Building Tallahassee, FL 32399-0250 Pike, Robert Citizen Pritchard, Alvera Citizen Quintero, Carolina Citizen Randall, Laura Citizen Rawal, Tatiana Citizen Remilien, Sandra Citizen Reynolds, Laura lreynolds@conservationconceptsllc.org Rippingille, Bonnie Citizen Ritz, David Ocean Reef Community Association President 24 Dockside Lane #505 Key Largo, FL 33037 Rivera, Jose, FWS Jose_Rivera@fws.gov Robinson, Janet Citizen Roff, Rhonda Citizen Rose, Simon Citizen Rosenblum, Ron Citizen Rotenberg, Edan Miami Waterkeeper, Inc. Super Law Group, LLC 180 Maiden Lane, Suite 603 New York, New York 10038 edan@superlawgroup.com Robert E. Rutkowski e_rutkowski@att.net Rybeck, Astrid astrid_rybeck@nps.gov Sagovac, Emily Citizen Schafer, Alissa Citizen Schoedinger, Steven, Chairman Ocean Reef Community Association Ocean Reef Community 58 Anchor Drive, Unit B Key Largo, FL 33037 Schooley, Doreen Citizen Schwartz, Matt Citizen 8-6

Name and Title Affiliation and Address Shlackman, Mara Citizen Short, Mark Citizen Silverstein, Rachel, Executive Director and Miami Waterkeeper Waterkeeper 2103 Coral Way, 2nd Floor Miami, FL, 33145 Singleton, Martha Citizen Smith, Jennifer, K. Jennifer.K.Smith@dep.state.fl.us Songer, Mark E. Last Stand Board President marksonger72@gmail.com Sorkin, E Citizen Spadafina, Lisa Natural Resources Division Chief Department of Regulatory and Economic Resources Environmental Resources Management Overtown Transit Village 701 NW 1st Court 6th floor Miami, FL 33136 Lisa.Spadafina@miamidade.gov Stinson, Laura Citizen Stoddard, Philip Citizen Stone, Mike Citizen Storino, Michael Citizen Sweeney, Pamela Pamela.Sweeney@miamidade.gov Tamayo, Iggy Citizen Tamson, Edward Backcountry Fly Fishers Conservation Representative P.O. Box 971 Naples, FL 34106 Teas, James Citizen Tejedor, Ignacio Monroe County Board of County Commissioners 1100 Simonton Street Key West, FL 33040 Trudeau, Stephanie Citizen Tumolo, Marlies Citizen Wald, Christina Citizen Weiss, Allan Citizen Wheeler, Lynn Citizen White, Barry Citizen White, Carolyn Poarch Band of Creek Indians Acting Tribal Historic Preservation Officer 5811 Jack Springs Road Atmore, AL 36502 White, Irene Citizen White, Susan Citizen Wilansky, Laura Sue Citizen Williams, Alek Citizen Wynn, Patricia Citizen Zapata, Monica Citizen 8-7

Name and Title Affiliation and Address Zueleh, Kirk C. Florida Keys Aqueduct Authority Executive Director 1100 Kennedy Drive Key West, FL 33040 8-8

9 INDEX accident, 3-133, 4-5, 4-7, 4-89, 4-90, 4-91, critical habitat, 2-23, 3-107, 4-72, 4-73, B-6, 4-94, 4-96, 4-100, E-1, E-2, E-3, E-4, E-5, C-1, C-2, C-3 E-6, E-7, E-8, E-9, E-10, E-12, E-13, cultural resource, xx, 2-6, 3-117, 3-118, E-14, E-15, E-16, E-17, E-18, E-19, E-21, 3-119, 4-7, 4-75, 4-77, 4-78, 4-79, 4-80, E-25 4-81, 4-105, 4-129, 4-130, B-1, B-7 Advisory Council on Historic Preservation demography, 2-7, 3-120, 3-122, 3-123, (ACHP), 1-7, 3-117, 4-75, 4-76, B-7, C-4, 3-124, 4-113 C-5 design-basis accident, 4-1, 4-90, E-1, E-2, aesthetic, 3-60, 3-134, B-6 E-3 alternative, xx, xxi, 1-2, 1-6, 2-1, 2-3, 2-4, discharge, 3-4, 3-5, 3-6, 3-8, 3-12, 3-13, 2-5, 2-6, 2-7, 2-13, 2-14, 2-19, 2-21, 2-22, 3-14, 3-15, 3-17, 3-21, 3-22, 3-34, 3-36, 3-50, 3-51, 4-1, 4-2, 4-8, 4-9, 4-10, 4-11, 3-37, 3-38, 3-40, 3-41, 3-42, 3-46, 3-47, 4-12, 4-13, 4-14, 4-16, 4-17, 4-18, 4-19, 3-69, 3-71, 3-78, 3-81, 3-82, 3-85, 3-97, 4-21, 4-22, 4-23, 4-38, 4-41, 4-42, 4-43, 3-132, 3-139, 4-3, 4-23, 4-25, 4-28, 4-37, 4-45, 4-50, 4-51, 4-60, 4-61, 4-62, 4-63, 4-38, 4-39, 4-48, 4-49, 4-56, 4-57, 4-59, 4-73, 4-74, 4-75, 4-77, 4-78, 4-79, 4-80, 4-60, 4-67, 4-68, 4-72, B-1, B-10 4-81, 4-82, 4-88, 4-90, 4-91, 4-92, 4-93, dose, 3-14, 3-15, 3-16, 3-17, 3-18, 3-131, 4-96, 4-97, 4-98, 4-100, 4-101, 4-102, 3-132, 4-6, 4-94, 4-97, 4-136, B-2, E-11, 4-103, 4-104, 4-105, 4-106, 4-107, 4-110, E-22 4-134, 4-135, 4-136, 4-137, 5-1, B-3, C-2, dredging, 4-3, 4-4, 4-61, 4-67, 4-127, B-8 E-4, E-5, E-17, E-18, E-20, E-21, E-25 eastern indigo snake, 2-23, 3-109, 3-113, American crocodile, 4-72 4-8, 4-64, C-3 archaeological resources, 1-7, 3-117, 3-118, education, 3-121, 4-82, 4-132 4-80 effluent, 3-14, 3-15, 3-16, 3-17, 3-18, 3-20, biocide, 3-132, 4-3, 4-44, 4-93, 4-102 3-21, 3-37, 3-46, 3-75, 3-76, 3-131, biological assessment, 3-113, 3-114, 3-115, 3-132, 3-139, 4-36, 4-38, 4-42, 4-44, 4-8, 4-47, 4-63, 4-71, C-1, C-2 4-45, 4-60, 4-100, 4-120 boiling water reactor, E-8, E-12 electromagnetic field, 2-23, 3-130, 4-7, burnup, 3-22, E-12, E-16 4-88, 4-89, 4-91, 4-92 chronic effect, 2-23, 4-88, 4-89, 4-91 endangered and threatened species, 7, Clean Air Act (CAA), 3-28, 3-29, 4-17, 4-20, 3-92, 3-93, 3-95, 3-96, 3-97, 3-106, 4-108, 4-134, B-3, B-4 3-107, 3-112, 3-114, 4-30, B-1, B-6, B-7, closed-cycle cooling, xxi, 2-8, 2-10, 2-11, C-1 2-12, 2-13, 3-4, 3-5, 3-9, 4-45, 4-87, 4-88 Endangered Species Act (ESA), 7, 8, 2-6, Coastal Zone Management Act (CZMA), 2-23, 3-97, 3-106, 3-107, 3-111, 3-112, 3-26, B-5, B-9 3-113, 3-114, 4-47, 4-63, 4-65, 4-66, consumptive use, 3-84, 4-118, B-9 4-67, 4-68, 4-70, 4-71, 4-72, 4-73, 4-74, cooling canal, 3-1, 3-15, 3-47, 3-48, 3-63, B-6, C-1, C-2, C-3 3-119, 4-39, 4-46, 4-76, B-8 entrainment, xx, 4-7, 4-8, 4-52, 4-53, 4-54, cooling system, xix, xx, 7, 2-8, 3-13, 4-2, 4-55, 4-56, 4-57, 4-60, 4-61, 4-66, 4-94, 4-4, 4-7, 4-26, 4-45, 4-46, 4-52, 4-56, 4-125 4-93, 4-103 environmental justice (EJ), 2-6, 3-134, core damage frequency (CDF), E-5, E-8, 3-135, 4-93, 4-95, 4-105, 4-131 E-9, E-11, E-17, E-20, E-23, E-26 essential fish habitat (EFH), xx, 3-115, Council on Environmental Quality (CEQ), 4, 3-116, 4-7, 4-71, 4-73, 4-74, B-7 3-134, 3-135 eutrophication, 4-4 9-1

Florida Department of Environmental high-level waste, 4-104 Protection (FDEP), 7, 3-26, 3-29, 3-30, impingement, 4-8, 4-52, 4-53, 4-54, 4-55, 3-37, 3-41, 3-42, 3-43, 3-45, 3-46, 3-48, 4-56, 4-57, 4-60, 4-61, 4-66, 4-94, 4-125 3-49, 3-52, 3-53, 3-54, 3-59, 3-60, 3-61, independent spent fuel storage installation 3-64, 3-66, 3-69, 3-71, 3-72, 3-73, 3-75, (ISFSI), 3-2, 3-19, 3-22, 4-67, 4-118, 3-82, 3-83, 3-84, 3-85, 3-97, 3-101, 4-125, 4-127, 4-129, 4-130, 4-131, 4-133, 3-104, 3-139, 4-6, 4-16, 4-25, 4-27, 4-28, B-8 4-29, 4-31, 4-32, 4-34, 4-36, 4-38, 4-39, Indian tribe, 3-117, 3-118, 3-134, 4-94, 4-95 4-40, 4-41, 4-44, 4-45, 4-47, 4-48, 4-57, invasive species, 3-96, 3-106 4-59, 4-61, 4-68, 4-77, 4-93, 4-102, leatherback sea turtle, 2-23, 3-108, 3-114, 4-119, 4-121, 4-123, 4-126, 4-127, B-1, 3-115, 4-8, 4-66, 4-70, C-3 B-8, B-9, B-10 loggerhead sea turtle, 2-23, 3-108, 3-114, Florida Power & Light Company, xvii, 1, 2-2, 3-115, 4-8, 4-65, 4-66, 4-70, C-3 3-119, 5-1, A-1, B-7, E-3 low-level waste, 4-101, 4-104 Generic Environmental Impact Statement Magnuson-Stevens Fishery Conservation (GEIS), xvii, xviii, xix, xxi, 3, 4, 5, 8, 2-2, and Management Act (MSA), 7, 8, 2-6, 2-3, 2-4, 2-5, 2-6, 2-16, 2-23, 3-122, 3-106, 3-108, 3-115, 4-71, 4-73, 4-74, 3-132, 3-133, 4-2, 4-3, 4-6, 4-7, 4-8, 4-9, B-7, C-4 4-13, 4-14, 4-21, 4-23, 4-25, 4-26, 4-28, Miami-Dade County Division of 4-45, 4-46, 4-48, 4-50, 4-51, 4-52, 4-56, Environmental Resources Management, 4-66, 4-67, 4-81, 4-88, 4-89, 4-90, 4-93, 7, 3-54, 3-55, 3-64, 3-95, 4-6, 4-24, 4-25, 4-100, 4-101, 4-103, 4-104, 4-105, 4-106, 4-28, 4-29, 4-32, 4-34, 4-38, 4-44, 4-69, 4-109, 4-110, 4-117, 5-1, 5-2, E-1, E-2, 4-123, B-11, B-12 E-3, E-4, E-6, E-7, E-8, E-9, E-10, E-11, mitigation, xix, 2, 4, 5, 6, 3-26, 3-51, 3-71, E-12, E-13, E-14, E-15, E-16, E-17, E-18, 3-75, 3-95, 4-15, 4-50, 4-61, 4-69, 4-70, E-19, E-20, E-22 4-84, 4-115, 4-120, 4-122, 4-125, 4-126, green sea turtle, 2-23, 3-52, 3-94, 3-99, 4-127, 4-135, 5-1, E-5, E-17, E-18, E-19, 3-114, 3-115, 4-8, 4-66, 4-70, C-3 E-20, E-23 greenhouse gases, 2-7, 2-10, 4-15, 4-16, mixed waste, 3-13 4-17, 4-18, 4-20, 4-98, 4-104, 4-107, 4- National Environmental Policy Act 108, 4-109, 4-110, 4-111, 4-112, 4-113, NEPA, 1-1, 1-9 4-114, 4-115, 4-133, 4-134 National Environmental Policy Act (NEPA), groundwater, xix, xx, 2-21, 3-8, 3-10, 3-11, xviii, 1, 9, 2-1, 2-3, 2-13, 3-26, 3-117, 3-12, 3-20, 3-33, 3-34, 3-36, 3-37, 3-39, 3-134, 4-6, 4-67, 4-71, 4-76, 4-90, 4-116, 3-41, 3-43, 3-44, 3-46, 3-47, 3-48, 3-50, 5-1, A-1, B-2, B-3, C-1, C-4, E-3, E-4, 3-52, 3-53, 3-54, 3-55, 3-56, 3-57, 3-58, E-6, E-17 3-59, 3-60, 3-61, 3-63, 3-64, 3-66, 3-67, National Marine Fisheries Service (NMFS), 3-68, 3-69, 3-70, 3-71, 3-72, 3-73, 3-75, 2-23, 3-26, 3-107, 3-108, 3-114, 3-115, 3-76, 3-77, 3-78, 3-81, 3-82, 3-83, 3-84, 3-116, 4-8, 4-63, 4-65, 4-66, 4-67, 4-70, 3-85, 3-86, 3-105, 3-127, 3-131, 3-140, 4-71, 4-72, 4-73, 4-74, B-6, B-7, C-1, C-2, 4-2, 4-6, 4-7, 4-23, 4-24, 4-25, 4-26, 4-27, C-3, C-4 4-28, 4-29, 4-30, 4-31, 4-32, 4-33, 4-34, National Pollutant Discharge Elimination 4-35, 4-36, 4-37, 4-38, 4-39, 4-40, 4-41, System (NPDES), 3-41, 3-42, 3-43, 3-4-42, 4-43, 4-44, 4-45, 4-46, 4-47, 4-56, 132, 4-39, 4-40, 4-41, 4-44, 4-57, 4-61, 4-68, 4-69, 4-70, 4-90, 4-94, 4-96, 4-103, 4-127, B-1, B-3, B-5, B-8 4-105, 4-120, 4-121, 4-122, 4-123, 4-124, Native American tribes, 3-118, 4-94, 4-95 4-132, 5-1, B-1, B-9, B-10, E-4 no-action alternative, xx, xxi, 2-1, 2-3, 2-4, hawksbill sea turtle, 2-23, 3-108, 3-114, 2-21, 4-1, 4-9, 4-14, 4-21, 4-31, 4-37, 3-115, 4-8, 4-66, 4-70, C-3 4-38, 4-44, 4-49, 4-60, 4-72, 4-77, 4-81, hazardous waste, 3-21, 3-132 4-91, 4-96, 4-100, 4-109, 4-110, 4-136, heat shock, 4-56 5-1 9-2

once-through cooling, xix, xx, 3-8, 4-2, 4-4, spent fuel, xix, 4, 2-23, 3-13, 3-17, 3-19, 4-7, 4-45, 4-46, 4-52, 4-56, 4-103 3-22, 4-5, 4-35, 4-105, 4-130, 4-133, B-8, postulated accident, 4-1, 4-89, E-1, E-3, E-7 E-13, E-18 power uprate, 3-46, 3-64, 3-66, 3-67, 3-69, State Historic Preservation Office (SHPO), 3-88, 3-104, 3-120, 3-129, 4-26, E-11, 2-23, 3-117 E-24 stormwater, 3-1, 3-41, 3-63, 3-139, 4-38, pressurized water reactor (PWR), 3-4, 3-5, 4-39, 4-41, 4-44, 4-46, 4-48, 4-49, 4-61, E-8, E-18, E-20, E-23 4-127, B-5 radionuclide, 3-20, 3-21, 3-41, 3-75, 4-4, surface water, 3-5, 3-9, 3-10, 3-12, 3-20, 4-35, 4-36, 4-37, 4-67, B-4, E-10 3-33, 3-34, 3-37, 3-38, 3-40, 3-41, 3-43, radon, 3-20 3-44, 3-45, 3-50, 3-52, 3-53, 3-54, 3-55, reactor, 1, 2-1, 2-9, 2-10, 2-13, 3-1, 3-4, 3-5, 3-56, 3-58, 3-70, 3-71, 3-73, 3-75, 3-76, 3-22, 3-38, 3-72, 3-83, 3-114, 3-132, 3-81, 3-97, 3-98, 3-101, 3-104, 3-115, 4-131, 5-1, B-2, E-6, E-12, E-17, E-19, 3-117, 3-140, 4-3, 4-8, 4-23, 4-24, 4-25, refurbishment, 2-2, 2-3, 3-120, 4-8, 4-47, 4-30, 4-31, 4-37, 4-38, 4-39, 4-41, 4-42, 4-81, 4-118 4-43, 4-48, 4-53, 4-56, 4-59, 4-60, 4-66, replacement power, xx, xxi, 2-3, 2-4, 2-5, 4-67, 4-68, 4-69, 4-94, 4-95, 4-105, 2-6, 2-7, 2-9, 2-11, 2-13, 2-14, 2-15, 2-20, 4-117, 4-123, 4-125, 4-126, B-1, B-9, C-4 2-21, 4-1, 4-9, 4-10, 4-11, 4-12, 4-14, taxes, 3-128, 3-129, 4-83, 4-84, 4-87, 4-129 4-15, 4-16, 4-17, 4-18, 4-19, 4-20, 4-21, transmission line, 2-6, 2-9, 2-10, 2-11, 2-16, 4-22, 4-38, 4-39, 4-40, 4-41, 4-42, 4-43, 2-20, 3-8, 3-23, 3-133, 4-4, 4-6, 4-9, 4-10, 4-50, 4-51, 4-60, 4-61, 4-62, 4-73, 4-74, 4-47, 4-49, 4-50, 4-75, 4-89 4-77, 4-78, 4-79, 4-80, 4-82, 4-83, 4-91, tritium, 3-20, 3-43, 3-44, 3-52, 3-54, 3-55, 4-92, 4-96, 4-97, 4-98, 4-99, 4-100, 3-56, 3-60, 3-64, 3-66, 3-67, 3-68, 3-75, 4-101, 4-102, 4-104, 4-106, 4-107, 4-109, 3-76, 3-77, 3-78, 3-79, 3-81, 4-27, 4-28, 4-135 4-35, 4-36, 4-37, 4-96 right-of-way, 2-8, 2-11, 2-12, 4-4, 4-11, 4- U.S. Army Corps of Engineers, 4-115, 12, 4-41, 4-51, 4-85 4-116, 4-127, B-5, B-8 runoff, 3-37, 3-52, 3-57, 3-58, 3-88, 4-38, U.S. Department of Energy (DOE), 2-5, 2-9, 4-41, 4-44, 4-48, 4-50, 4-61, 4-111, 4- 2-10, 2-13, 2-14, 2-15, 2-17, 2-19, 3-19, 123, 4-125, 4-127, B-5 4-17, 4-19, 4-88, 4-111, 4-118, 4-130 salinity gradient, 3-102 U.S. Environmental Protection Agency scoping, xvii, xix, 2, 3-25, 3-31, 3-118, 4-2, (EPA), 7, 2-5, 2-18, 2-20, 3-14, 3-15, 4-8, 4-14, 4-25, 4-67, 4-76, 4-103, 4-117, 3-16, 3-17, 3-18, 3-20, 3-26, 3-28, 3-29, 4-118, A-1, C-4, C-5, E-3, E-8, E-10, 3-30, 3-41, 3-44, 3-52, 3-61, 3-67, 3-76, E-11, E-12, E-13, E-14 3-122, 3-132, 3-139, 4-18, 4-19, 4-27, seismic, 3-31, 3-32, E-9, E-19, E-24 4-35, 4-36, 4-68, 4-69, 4-70, 4-91, 4-92, severe accident, 4-1, 4-90, 4-94, E-1, E-3, 4-96, 4-108, 4-111, 4-112, 4-114, 4-117, E-4, E-5, E-7, E-8, E-9, E-10, E-12, E-14, 4-119, 4-130, 4-132, 4-133, 4-134, 4-135, E-15, E-16, E-17, E-18, E-19, E-23, E-26 B-1, B-3, B-4, B-5, B-6 severe accident mitigation alternatives U.S. Fish and Wildlife Service (FWS), 7, 9, (SAMA), xvii, xix, xxi, 2, 4-90, E-4, E-5, 2-23, 3-26, 3-93, 3-94, 3-95, 3-107, 3-108, E-6, E-7, E-8, E-10, E-11, E-12, E-13, 3-109, 3-110, 3-111, 3-112, 4-8, 4-63, E-14, E-15, E-16, E-17, E-18, E-19, E-20, 4-71, 4-72, 4-73, 4-74, B-6, B-9, C-1, C-2 E-21, E-22, E-23, E-24, E-25, E-26 U.S. National Park Service (NPS), 2, 7, smalltooth sawfish, 2-23, 3-97, 3-114, 3-115, 3-36, 3-37, 3-52, 3-54, 3-91, 3-95, 3-121, 4-8, 4-66, 4-67, 4-68, 4-70, 4-71, C-3 uranium, 4-5, 4-104, 4-105, 4-107 solid waste, 3-14, 3-18, 4-102, 4-105 wastewater, 3-21, 3-41, 3-69, 3-82, 3-85, South Florida Water Management District 4-34, 4-122 SFWMD, 1-8 9-3

1 2 COMMENTS RECEIVED ON THE TURKEY POINT NUCLEAR 3 GENERATING UNITS 3 AND 4 ENVIRONMENTAL REVIEW 4 A.1 Comments Received During the Scoping Period 5 The scoping process for the environmental review of the Turkey Point Nuclear Generating Unit 6 Nos. 3 and 4 (Turkey Point, or Turkey Point Units 3 and 4) subsequent license renewal began in 7 May 2018, in accordance with the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et 8 seq.) (NEPA). On May 14, 2018, the U.S. Nuclear Regulatory Commission (NRC) issued a 9 notice of intent to prepare an environmental impact statement and conduct an environmental 10 scoping process for subsequent license renewal of Turkey Point; that notice was published in 11 the Federal Register on May 14, 2018 (83 FR 23726). The scoping process included two public 12 meetings held in Homestead, FL, on May 31, 2018. The NRC issued a press release and 13 purchased newspaper advertisements to advertise the two public meetings. In addition to 14 participation by the applicant, Florida Power & Light Company (FPL), and local officials, several 15 members of the public attended the meetings. After the NRC staff presented prepared 16 statements on the subsequent license renewal process, the staff opened the meetings for public 17 comments. Attendees were provided the opportunity to make oral statements that were 18 recorded and transcribed by a certified court reporter. A summary and transcripts of the 19 scoping meetings are available in the NRCs Agencywide Documents Access and Management 20 System (ADAMS). The ADAMS Public Electronic Reading Room is accessible at 21 http://www.nrc.gov/reading-rm/adams.html. The scoping meetings summary is available at 22 ADAMS Accession No. ML18176A404. The transcripts of the meetings are available at ADAMS 23 Accession No. ML18176A399 for the afternoon session and No. ML18176A401 for the evening 24 session. In addition to comments received during the public meetings, comments were also 25 received electronically and through the mail. 26 The NRC received numerous comments during the scoping process which identified many 27 important issues that were addressed by the NRC staff in this draft supplemental environmental 28 impact statement (SEIS) for Turkey Points subsequent license renewal. The scoping summary 29 report provides the NRC staffs responses to comments received as part of the Turkey Point 30 environmental scoping process and is available at ADAMS Accession No. ML18342A014. A-1

1 2 APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS 3 There are a number of Federal laws and regulations that affect environmental protection, health, 4 safety, compliance, and consultation at every NRC-licensed nuclear power plant. Some of 5 these laws and regulations require permits from or consultations with other Federal agencies or 6 State, Tribal, or local governments. Certain Federal environmental requirements have been 7 delegated to State authorities for enforcement and implementation. Furthermore, States have 8 also enacted their own laws to protect public health and safety and the environment. It is the 9 NRCs policy to make sure nuclear power plants are operated in a manner that provides 10 adequate protection of public health and safety and protection of the environment through 11 compliance with applicable Federal and State laws, regulations, and other requirements. 12 The Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.) (AEA), authorizes the 13 NRC to enter into an agreement with any State that allows the State to assume regulatory 14 authority for certain activities (see 42 U.S.C. 2021). Florida has been an NRC Agreement State 15 since 1964, and the Bureau of Radiation Control within the Florida Department of Health has 16 regulatory responsibility over the radioactive materials program as it is carried out under the 17 AEA Section 274b Agreement between the NRC and the State of Florida (FDOH 2018b). 18 In addition to carrying out some Federal programs, State legislatures develop their own laws. 19 State statutes can supplement, as well as implement, Federal laws for protection of air, surface 20 water, and groundwater. State legislation may address solid waste management programs, 21 locally rare or endangered species, and historic and cultural resources. 22 The U.S. Environmental Protection Agency (EPA) has the primary responsibility to administer 23 the Federal Water Pollution Control Act (33 U.S.C. 1251 et seq., herein referred to as the Clean 24 Water Act (CWA)). The National Pollutant Discharge Elimination System (NPDES) program 25 addresses water pollution by regulating the discharge of potential pollutants to waters of the 26 United States. EPA allows for primary enforcement and administration through State agencies, 27 as long as the State program is at least as stringent as the Federal program. 28 The EPA has delegated the authority to issue NPDES permits to the State of Florida. The 29 Florida Department of Environmental Protection (FDEP) provides oversight for public water 30 supplies, issues permits to regulate the discharge of industrial and municipal wastewaters 31 including discharges to groundwaterand monitors State water resources for water quality. 32 The FDEP issues NPDES permits to regulate and control water pollutants. 33 B.1 Federal and State Requirements 34 Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point, or Turkey Point Units 3 and 35 4) is subject to various Federal and State requirements. Table B-1 lists the principal Federal 36 and State regulations and laws that are used or mentioned in this supplemental environmental 37 impact statement (SEIS) for Turkey Point. B-1

1 Table B-1 Federal and State Requirements Law/regulation Requirements Current operating license and subsequent license renewal Atomic Energy Act, The Atomic Energy Act of 1954, as amended (AEA), and the Energy 42 U.S.C. 2011 Reorganization Act of 1974, as amended (42 U.S.C. 5801 et seq.), give the NRC et seq. the licensing and regulatory authority for commercial nuclear energy use. They allow the NRC to establish dose and concentration limits for protection of workers and the public for activities under NRC jurisdiction. The NRC implements its responsibilities under the AEA through regulations set forth in Title 10, Energy, of the Code of Federal Regulations (10 CFR). 10 CFR Part 2 Regulations in 10 CFR Part 2, Agency Rules of Practice and Procedure, govern the conduct of all proceedings (other than export and import licensing proceedings) for: (a) granting, suspending, revoking, amending, or taking other action with respect to any license, construction permit, or application to transfer a license, (b) issuing orders and demands for information to persons subject to the Commission's jurisdiction, including licensees and persons not licensed by the Commission, (c) imposing civil penalties under AEA Section 234, (d) rulemaking under the AEA and the Administrative Procedure Act, and (e) standard design approvals under 10 CFR Part 52. 10 CFR Part 20 Regulations in 10 CFR Part 20, Standards for Protection Against Radiation, establish standards for protection against ionizing radiation resulting from activities conducted under licenses issued by the NRC. These regulations are issued under the AEA and the Energy Reorganization Act of 1974, as amended. The purpose of these regulations is to control the receipt, possession, use, transfer, and disposal of licensed material by any licensee in such a manner that the total dose to an individual (including doses resulting from licensed and unlicensed radioactive material and from radiation sources other than background radiation) does not exceed the standards for protection against radiation prescribed in 10 CFR Part 20. 10 CFR Part 50 Regulations in 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, provide for the licensing of production and utilization facilities, including power reactors. 10 CFR Part 51 Regulations in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, implement Section 102(2) of the National Environmental Policy Act of 1969, as amended (NEPA). 10 CFR Part 54 Regulations in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, govern the issuance of renewed operating licenses and renewed combined licenses for nuclear power plants licensed pursuant to Sections 103 or 104b of the AEA, as amended, and Title II of the Energy Reorganization Act of 1974. The regulations focus on managing adverse effects of aging and are intended to ensure that important systems, structures, and components will continue to perform their intended functions during the period of extended operation. 10 CFR Part 100 Regulations in 10 CFR Part 100, Reactor Site Criteria, establish approval requirements for proposed sites for stationary power and testing reactors. B-2

Law/regulation Requirements National NEPA requires Federal agencies to integrate environmental values into their Environmental Policy decisionmaking process by considering the environmental impacts of proposed Act of 1969, as Federal actions and reasonable alternatives to those actions. NEPA establishes amended, policy and sets goals (in Section 101) and provides means for carrying out the 42 U.S.C. 4321 et policy and goals (in Section 102). NEPA Section 102(2) contains action-forcing seq. (NEPA) provisions to ensure that Federal agencies follow the letter and spirit of the act. For major Federal actions significantly affecting the quality of the human environment, Section 102(2)(C) of the act requires Federal agencies to prepare a detailed statement that includes the environmental impacts of the proposed action and other specified information. 40 CFR Part 50 Regulations in 40 CFR Part 50, National Primary and Secondary Ambient Air Quality Standards, establish the following: (1) national primary ambient air quality standards that define levels of air quality which the EPA judges are necessary to protect the public health and (2) national secondary ambient air quality standards that define levels of air quality which the EPA judges necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. 40 CFR Part 51 Regulations in 40 CFR Part 51, Requirements for Preparation, Adoption, and Submittal of Implementation Plans, include § 51.308, Regional haze program requirements (referred to as the Regional Haze Rule), which establishes requirements for implementation plans, plan revisions, and periodic progress reviews to address regional haze. 40 CFR Part 60 Regulations in 40 CFR Part 60, Standards of Performance for New Stationary Sources, contain emissions guidelines and standards of performance for new stationary sources. 40 CFR Part 63 Regulations in 40 CFR Part 63, National Emission Standards for Hazardous Air Pollutants for Source Categories, contain national emission standards for hazardous air pollutants (NESHAP) established pursuant to Section 112 of the Clean Air Act, that regulate specific categories of stationary sources that emit (or have the potential to emit) one or more hazardous air pollutants listed in this part. 40 CFR Part 81 Regulations in 40 CFR Part 81, Designation of Areas for Air Quality Planning Purposes, designate Air Quality Control Regions (Subpart B), list the standards attainment status by state areas (Subpart C), and identify Mandatory Class I Federal Areas Where Visibility is an Important Value (Subpart D). 40 CFR Part 110 Regulations in 40 CFR Part 110, Discharge of Oil, establish regulations applicable to the discharge of oil prohibited by Section 311(b)(3) of the CWA. 40 CFR Part 112 Regulations in 40 CFR Part 112, Oil Pollution Prevention, establish procedures, methods, equipment, and other requirements to prevent the discharge of oil from non-transportation-related onshore and offshore facilities into or upon the navigable waters of the United States or adjoining shorelines. 40 CFR Part 125 Regulations in 40 CFR Part 125, Criteria and Standards for the National Pollutant Discharge Elimination System, establish criteria and standards for the imposition of technology-based treatment requirements in permits under Section 301(b) of the CWA, including the application of EPA-promulgated effluent limitations and case-by-case determinations of effluent limitations under Section 402(a)(1) of the CWA. 40 CFR Part 131 Regulations in 40 CFR Part 131, Water Quality Standards, contain requirements and procedures for developing, reviewing, revising, and approving water quality standards by the States as authorized by Section 303(c) of the CWA. 40 CFR Part 141 Regulations in 40 CFR Part 141, National Primary Drinking Water Regulations, establish primary drinking water regulations pursuant to Section 1412 of the Public Health Service Act, as amended by the Safe Drinking Water Act. B-3

Law/regulation Requirements 40 CFR Part 143 Regulations in 40 CFR Part 143, National Secondary Drinking Water Regulations, establish National Secondary Drinking Water Regulations pursuant to Section 1412 of the Safe Drinking Water Act. 40 CFR Part 190 Regulations in 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations, establish limits for radiation dose equivalent to the public and the total quantity of radioactive materials entering the environment from the entire uranium fuel cycle. Air quality protection Clean Air Act, The Clean Air Act (CAA) is intended to protect and enhance the quality of the 42 U.S.C. 7401 et Nations air resources so as to promote the public health and welfare and the seq. productive capacity of its population. The CAA establishes regulations to ensure maintenance of air quality standards and authorizes individual States to manage permits. Section 109 of the CAA directs the U.S. Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS) for criteria pollutants. The EPA has identified and set NAAQS for the following criteria pollutants: particulate matter, sulfur dioxide, carbon monoxide, ozone, nitrogen dioxide, and lead. Section 111 of the CAA requires the establishment of national performance standards for new or modified stationary sources of atmospheric pollutants. Section 161 of the CAA requires that specific emission increases must be evaluated before permit approval to prevent significant deterioration of air quality. Section 112 requires specific standards for release of hazardous air pollutants (including radionuclides). These standards are implemented through plans developed by each State and approved by the EPA. The CAA requires sources to meet standards and obtain permits to satisfy those standards. Nuclear power plants may be required to comply with the CAA Title V, Sections 501-507, for sources subject to new source performance standards or sources subject to National Emission Standards for Hazardous Air Pollutants. EPA regulates the emissions of air pollutants using 40 CFR Parts 50 to 99. B-4

Law/regulation Requirements Water resources protection Clean Water Act, The Clean Water Act (CWA) was enacted to restore and maintain the chemical, 33 U.S.C. 1251 physical, and biological integrity of the Nations waters. As authorized by the et seq., and the CWA, the National Pollutant Discharge Elimination System (NPDES) permit National Pollutant program controls water pollution by regulating point sources that discharge Discharge pollutants into waters of the United States. Elimination System The NPDES program requires all facilities that discharge pollutants from any point (NPDES) source into waters of the United States to obtain an NPDES permit. A nuclear (40 CFR Part 122) power plant may also participate in the NPDES General Permit for Industrial Stormwater due to stormwater runoff from industrial or commercial facilities to waters of the United States. EPA is authorized under the CWA to directly implement the NPDES program; however, EPA has authorized many States to implement all or parts of the national program. Section 401 of the CWA requires applicants for federal permits or licenses for a facility that may discharge into navigable waters to provide a certification from the State that the permitted discharge would comply with all limitations necessary to meet established State water quality standards, treatment standards, or schedule of compliance. The U.S. Army Corps of Engineers (USACE) is the lead agency for enforcement of CWA wetland requirements (33 CFR Part 320, General Regulatory Policies). Under Section 401 of the CWA, the EPA or a delegated State agency has the authority to review and approve, condition, or deny all permits or licenses that might result in a discharge to waters of the State, including wetlands. Coastal Zone Congress enacted the Coastal Zone Management Act (CZMA) in 1972 to address Management Act the increasing pressures of over-development upon the Nations coastal of 1972, as resources. The National Oceanic and Atmospheric Administration administers amended, the Act. The CZMA encourages States to preserve, protect, develop, and, where 16 U.S.C. 1451 et possible, restore or enhance valuable natural coastal resources such as seq. wetlands, floodplains, estuaries, beaches, dunes, barrier islands, and coral reefs, as well as the fish and wildlife using those habitats. Participation by States is voluntary. To encourage States to participate, the CZMA makes Federal financial assistance available to any coastal State or territory, including those on the Great Lakes, as long as the State or territory is willing to develop and implement a comprehensive coastal management program. FAC 62-296 Florida Administrative Code Rule 62-296, Stationary SourcesEmission Standards, establishes emission limiting standards and compliance requirements for stationary sources of air pollutant emissions. FAC 62-520 Florida Administrative Code Rule 62-520, Ground Water Classes, Standards, and Exemptions, establishes water quality standards to protect designated beneficial uses of all ground waters of the State of Florida. FAC 62-528 Florida Administrative Code Rule 62-528, Underground Injection Control, establishes provisions to protect the quality of the States underground sources of drinking water and to prevent degradation of the quality of other aquifers adjacent to the injection zone that may be used for other purposes. Fla. Stat. § 258.397 Florida Statute Section 258.397, Biscayne Bay Aquatic Preserve, designates Biscayne Bay in Miami-Dade and Monroe Counties (including Card Sound) as an aquatic preserve under the provisions of Florida Statutes Title XVIII, Public Lands and Property, to be preserved in an essentially natural condition so that its biological and aesthetic values may endure for the enjoyment of future generations. B-5

Law/regulation Requirements Wild and Scenic The Wild and Scenic Rivers Act created the National Wild and Scenic Rivers Rivers Act, System, which was established to protect the environmental values of 16 U.S.C. 1271 et free-flowing streams from degradation by impacting activities, including water seq. resources projects. Waste management and pollution prevention Resource The Resource Conservation and Recovery Act (RCRA) requires the EPA to Conservation and define and identify hazardous waste; requires the EPA to establish standards for Recovery Act, its transportation, treatment, storage, and disposal; and requires permits for 42 U.S.C. 6901 persons engaged in hazardous waste activities. Section 3006, Authorized State et seq. Hazardous Waste Programs (42 U.S.C. 6926), allows States to establish and administer these permit programs with EPA approval. EPA regulations implementing the RCRA are found in 40 CFR Parts 260 through 282. Regulations imposed on a generator or on a treatment, storage, and/or disposal facility vary according to the type and quantity of material or waste generated, treated, stored, or disposed. The method of treatment, storage, or disposal also impacts the extent and complexity of the requirements. Pollution Prevention The Pollution Prevention Act establishes a national policy for waste management Act, 42 U.S.C. 13101 and pollution control that focuses first on source reduction, then on environmental et seq. issues, safe recycling, treatment, and disposal. Protected species Endangered Species The Endangered Species Act (ESA) was enacted to prevent the further decline of Act, 16 U.S.C. 1531 endangered and threatened species and to restore those species and their critical et seq. habitats. Section 7, Interagency Cooperation, of the Act requires Federal agencies to consult with the U.S. Fish and Wildlife Service (FWS) or the National Marine Fisheries Service (NMFS) on Federal actions that may affect listed species or designated critical habitats. 50 CFR Part 17 Regulations in 50 CFR Part 17, Endangered and Threatened Wildlife and Plants, implement the ESA. 50 CFR Part 402 Regulations in 50 CFR Part 402, Interagency Cooperation - Endangered Species Act of 1973, as Amended, interpret and implement Sections 7(a)-(d) of the ESA regarding endangered or threatened species of fish, wildlife, or plants (listed species) and habitats of such species that have been designated as critical (critical habitat). Magnuson-Stevens The Magnuson-Stevens Fishery Conservation and Management Act, as Fishery amended, governs marine fisheries management in U.S. Federal waters. This Conservation and Act created eight regional fishery management councils and includes measures Management Act, to rebuild overfished fisheries, protect essential fish habitat, and reduce bycatch. 16 U.S.C. 1801- Under Section 305 of this Act, Federal agencies are required to consult with the 1884 National Marine Fisheries Service for any Federal actions that may adversely affect essential fish habitat. FAC 68A-27 Florida Administrative Code Rule 68A-27, Rules Relating to Endangered or Threatened Species, establishes provisions to conserve or improve the status of endangered and threatened species in Florida. B-6

Law/regulation Requirements Historic preservation and cultural resources National Historic The National Historic Preservation Act was enacted to create a national historic Preservation Act, preservation program, including the National Register of Historic Places and the 16 U.S.C. 470 Advisory Council on Historic Preservation (ACHP). Section 106 of this Act et seq. requires Federal agencies to take into account the effects of their undertakings on historic properties. The ACHP regulations implementing Section 106 of the Act are found in 36 CFR Part 800, Protection of Historic Properties. 36 CFR Part 60 Regulations in 36 CFR Part 60, National Register of Historic Places, establish procedural requirements for listing properties on the National Register of Historic Places. 36 CFR Part 800 Regulations in 36 CFR Part 800, Protection of Historic Properties, establish provisions for public involvement in the National Historic Preservation Act Section 106 consultation process, including involvement from Indian Tribes and other interested members of the public, as applicable. 1 B.2 Operating Permits and Other Requirements 2 Table B-2 lists the permits and licenses issued by Federal, State, and local authorities for 3 activities at Turkey Point, as identified in Chapter 9 of Florida Power & Light Companys 4 environmental report submitted as part of its subsequent license renewal application. 5 Table B-2 Federal, State, and Local Permits and Other Requirements Responsible Permit Agency Number Expiration Date Authorized Activity Federal Authorizations Authorization to Southeast None Updated annually Export of LLRW outside export waste Compact the region Commission General license for NRC General permit N/A Storage of power reactor storage of spent fuel spent fuel and other at power reactor sites associated radioactive materials in an ISFSI Licensing of nuclear NRC DPR-31 7/19/2032 Operation of Unit 3 power plant Licensing of nuclear NRC DPR-41 4/10/2033 Operation of Unit 4 power plant Consent decree U.S. District 70-328-CA N/A IWW Construction, Court Operation, and Maintenance Registration U.S. Department 060911 551 091T None Hazardous materials of Transportation shipments Section 401/404 U.S. Army Corps SAJ-2016-02462 5/7/2023 Discharge of dredge and permit; of Engineers (USACE); (USACE); fill materials into waters Submerged lands (USACE) & 13-0127512-013 9/20/2021 of the U.S. (Turtle Point permit Florida (FDEP) (FDEP) and Barge Terminal) and Department of use of state-owned Environmental submerged lands Protection (FDEP) B-7

Responsible Permit Agency Number Expiration Date Authorized Activity NPDES permit - FDEP FL0001562 May 2010 Operation of IWW Industrial Waste (administratively (cooling canals) Water facility (IWW) continued (cooling canals) thereafter); draft permit issued 12/27/2018 Hazardous waste USACE & FDEP FLR000192922 N/A Small Quantity generator number Hazardous Waste Generator Endangered species U.S. Fish and TE092945-2 4/20/2018 Provides authorization to permit to take Wildlife Service (renewal in take (capture, examine, American crocodile (USFWS) progress) weigh, sex, collect tissue during monitoring samples, mark, radio-tag, radio-track, relocate, release) threatened American crocodile individuals during population monitoring Effects of operation USFWS 41420-2006- N/A Plan to minimize the on the threatened FA-0478; potential adverse effects American crocodile 41420-2006- of ongoing operations of F-0125 PTN to the American crocodile Migratory bird special USFWS MB697722-0 3/31/2021 Authorizes utilities to purpose utility permit collect, transport and temporarily possess migratory birds found dead on utility property, structures, and ROWs for avian mortality monitoring or disposal purposes State of Florida Authorizations Power plant site FDEP PA 03-45E Final conditions Certification of Turkey certification Siting Board of certification Point site, initiated by issued 3/29/2016 PTN uprate. Provides for CZMA certification confirmation and CWA 401 certification Power plant site South Florida N/A N/A Implementation of new certification Water monitoring plan that Management includes groundwater, District (SFWMD) surface water, and ecological monitoring in and around the Turkey Point CCS Operation of SFWMD 13-06251-W 2/27/2029 Use of Recovery Well Recovery Well System to extract System consumptive hypersaline plume use permit B-8

Responsible Permit Agency Number Expiration Date Authorized Activity Certification of state FDEP PA 03-45E Final conditions Discharges during water quality of certification license renewal term standards issued 3/29/2016 Operation of Class V, FDEP 0355186-001- Issued 1/25/2023 Operation of IW-1 Group 3 domestic UO/5W wastewater injection (gravity flow) well Operation of FDEP FLA013612-005- 9/27/2020 Operation of PTN domestic wastewater DW3P wastewater treatment treatment facility facility Annual storage tank FDEP Facility ID: Annual renewal Operation of above-registration 8622249 ground storage tanks Placard No.: 110600 Annual storage tank FDEP Facility ID: Annual renewal Operation of above-registration 8622251 ground storage tanks Placard No.: 110599 Title V operations FDEP 025003-028-AV 4/26/2023 Operation of facilities permit that generate air emissions Underground FDEP 29392-004-UO/1l 7/12/2023 Disposal of extracted injection control hypersaline water permit, injection well and monitoring well Operation of FDEP PA 03-45E Final conditions Withdrawal of freshening wells of certification groundwater for issued 3/29/2016 freshening of the IWW Migratory bird nest Florida Fish and LSNR 12/31/2020 Authorization to remove removal Wildlife 00026D and replace inactive Conservation nests of migratory birds Commission (FFWCC) Scientific collection FFWCC LSSC-11-00021B 12/31/2019 Scientific collection for permit avian species Special purpose FFWCC SPGS-14-35 4/10/2019 Capture, hold and permit relocate American alligators Burn permit Florida 1373498 No expiration Authorization for open Department of fires Agriculture and Consumer Service Other States Authorizations Revision of existing Utah Department None Annual Transport of radioactive general site access of Environmental authorization materials into the State permit Quality Division of Utah of Radiation Control B-9

Responsible Permit Agency Number Expiration Date Authorized Activity Revision of existing Tennessee None Annual Transport of radioactive Tennessee Department of authorization waste into the State of radioactive waste Environment and Tennessee license for delivery Conservation Division of Radiological Health Local Authorizations Stratospheric ozone Miami-Dade APCF-001747- June 30, 2019 Use of refrigerants protection annual County, 2018/2019 Annual renewal R-134A, R-22, R 410A, operations permit Department of R-502 for Robinair Environmental Recovery Units, Models Resources 25200, 25200B and Management 34700Z. (MDC DERM) Industrial waste MDC DERM IW-000003- May 31, 2019 Oil and water separators annual operations 2018/2019 Annual renewal and hazardous waste permit storage and used oil containment areas Domestic wastewater MDC DERM DWO-000010- April 14, 2019 Stabilization treatment annual operating 2018/2019 Annual renewal facility permit IW5 permit MDC DERM IW-000016- May 31, 2019 Water treatment units, oil (or waiver) 2018/2019 Annual renewal drum and compressed gasses storage, and vehicle refueling station Research permit on MDC DERM 2011 Under agency Authorization to conduct MDC DERM review ecological monitoring on environmentally county-owned endangered lands environmentally endangered lands Operation of pollution MDC DERM IW5-006229- April 30, 2019 Operation of fleet vehicle control facility permit 2018/2019 maintenance facility that generates waste oil, coolant, and used batteries with a solvent wash tank and served by septic tank Source: FPL 2019 B-10

1 2 CONSULTATION CORRESPONDENCE 3 C.1 Endangered Species Act Section 7 Consultation 4 As a Federal agency, the U.S. Nuclear Regulatory Commission (NRC) must comply with the 5 Endangered Species Act of 1973, as amended (16 United States Code (U.S.C.) Section 1531 et 6 seq.; herein referred to as ESA), as part of any action authorized, funded, or carried out by the 7 agency. In this case, the proposed agency action is whether to issue subsequent renewed 8 licenses for the continued operation of Turkey Point Nuclear Generating Unit Nos. 3 and 4 9 (Turkey Point, or Turkey Point Units 3 and 4), which would authorize operation for an additional 10 20 years beyond the end of the current renewed license terms. Under Section 7, Interagency 11 Cooperation, of the ESA, the NRC must consult with the U.S. Fish and Wildlife Service (FWS) 12 and the National Marine Fisheries Service (NMFS) (referred to jointly as the Services and 13 individually as Service), as appropriate, to ensure that the proposed agency action is not likely 14 to jeopardize the continued existence of any endangered or threatened species or result in the 15 destruction or adverse modification of designated critical habitat. 16 C.1.1 Federal Agency Obligations under Section 7 of the Endangered Species 17 Act 18 The ESA and the regulations that implement Section 7 of the ESA (Title 50, Wildlife and 19 Fisheries, of the Code of Federal Regulations (50 CFR) Part 402, Interagency Cooperation 20 Endangered Species Act of 1973, as Amended) describe the consultation process that Federal 21 agencies must follow in support of agency actions. As part of this process, the Federal agency 22 shall either request that the Services (1) provide a list of any listed or proposed species or 23 designated or proposed critical habitats that may be present in the action area or (2) request 24 that the Services concur with a list of species and critical habitats that the Federal agency has 25 created (50 CFR 402.12(c), Request for Information). If any such species or critical habitats 26 may be present, the Federal agency prepares a biological assessment to evaluate the potential 27 effects of the action on the species or critical habitat and to determine whether the species or 28 critical habitat are likely to be adversely affected by the action (50 CFR 402.12(a), Purpose; 29 16 U.S.C. 1536(c)). Biological assessments are required for any agency action that is a major 30 construction activity (50 CFR 402.12(b), Preparation Requirement), which is defined as a 31 construction project or other undertaking having construction-type impacts that is a major 32 Federal action significantly affecting the quality of the human environment under the National 33 Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.; herein referred to as 34 NEPA) (51 FR 19926). Federal agencies may fulfill their obligations to consult with the Services 35 under ESA Section 7 and to prepare a biological assessment, if required, in conjunction with the 36 interagency cooperation procedures required by other statutes, including NEPA (50 CFR 37 402.06(a)). In such cases, the Federal agency should include the results of the ESA Section 7 38 consultation in the NEPA document (50 CFR 402.06(b)). 39 C.1.2 Biological Assessment 40 Subsequent license renewal does not require the preparation of a biological assessment 41 because it is not a major construction activity. However, the NRC staff prepared a biological 42 assessment (NRC 2018n) to evaluate the potential impacts of Turkey Point subsequent license 43 renewal on the American crocodile (Crocodylus acutus), 14 other species under the FWSs 44 jurisdiction, and designated critical habitat for the American crocodile and the West Indian C-1

1 manatee (Trichechus manatus). The staff included a summary of the results of the biological 2 assessment in Section 4.8.1.1, Species and Habitats Protected Under the Endangered Species 3 Act, of this supplemental environmental impact statement (SEIS). Additionally, this SEIS 4 includes an evaluation of the potential impacts to federally listed species and critical habitats 5 under the NMFSs jurisdiction to support the NRCs ESA effect determinations for listed species 6 and critical habitats that may occur in the action area. The staff did not prepare a separate 7 biological assessment for species under the NMFSs jurisdiction due to the limited number of 8 listed species and the minimal potential effects on these species. Therefore, Section 4.8.1.1 of 9 this SEIS contains the NRC staffs assessment of impacts to NMFS-listed species. 10 The NRC staff structured its evaluation of impacts to both FWS- and NMFS-listed species in 11 accordance with the Services suggested biological assessment contents described at 12 50 CFR 402.12(f), Contents. Within Section 3.8, Special Status Species and Habitats, of this 13 SEIS and Sections 4.0 through 6.0 of the biological assessment, the NRC staff describes the 14 action area as well as the federally listed and proposed species and designated and proposed 15 critical habitats potentially present in the action area. These sections include information 16 pursuant to 50 CFR 402.12(f)(1), (2), and (3). Section 4.8, Special Status Species and 17 Habitats, of this SEIS and Sections 4.0 through 7.0 of the biological assessment provide an 18 assessment of the potential effects of the proposed Turkey Point subsequent license renewal on 19 the species and critical habitats present. These sections also contain the NRCs ESA effect 20 determinations, which are consistent with the conclusions described in Section 3.5 of the 21 Endangered Species Consultation Handbook (FWS and NMFS 1998). Finally, Section 4.8 of 22 this SEIS and Section 8.0 of the biological assessment address cumulative effects and 23 alternatives to the proposed action pursuant to 50 CFR 402.12(f)(4) and (5). 24 C.1.3 Chronology of Endangered Species Act Section 7 Consultation 25 Endangered Species Act Section 7 Consultation with the U.S. Fish and Wildlife Service 26 During its review of the Turkey Point subsequent license renewal application, the NRC staff 27 considered whether any federally listed, proposed, or candidate species or proposed or 28 designated critical habitats may be present in the action area (as defined at 50 CFR 402.02, 29 Definitions) for the proposed action. With respect to species under the FWSs jurisdiction, the 30 FWS identified 46 federally listed species, as well as designated critical habitat for two of those 31 species, that have the potential to occur in the vicinity of the action area in a letter to the NRC 32 dated December 14, 2018 (FWS 2018b). In Section 3.8 of this SEIS and Enclosure 1 of the 33 biological assessment (NRC 2018n), the NRC staff concludes that 25 species would not occur 34 in the action area because those species are extirpated from Miami-Dade County, are not 35 known to occur within Miami-Dade County, or no suitable habitat occurs within the action area. 36 In addition, two species are listed because of similarity of appearance to other listed species, 37 and therefore, are not subject to ESA Section 7 consultation. The FWS and the NMFS have 38 joint jurisdiction for four of the species; the proposed action would have no effect on the portions 39 of the life cycle that are under the FWSs jurisdiction for these species (NRC 2018g). The NRC 40 staff evaluates the impacts to the remaining 15 species and designated critical habitat for two of 41 those species in Sections 4.0 and 5.0 of the biological assessment. Section 4.8 of this SEIS 42 contains a summary of the staffs findings. In the biological assessment, the staff concludes 43 that the proposed subsequent license renewal may affect, but is not likely to adversely affect, 44 13 species and that the proposed subsequent license renewal is likely to adversely affect the 45 American crocodile and the eastern indigo snake (Drymarchon corais couperi). The staff also 46 concludes that the proposed subsequent license renewal is not likely to adversely modify 47 designated critical habitat for the West Indian manatee but may adversely modify designated C-2

1 critical habitat for the American crocodile. No other FWS listed, proposed, or candidate species 2 or proposed or designated critical habitats occur in the action area. By letter dated December 3 19, 2018 (NRC 2018o), the NRC staff submitted a copy of the biological assessment to the 4 FWS for review accompanied by a request for the FWS to concur with the staffs (1) may affect, 5 but is not likely to adversely affect determinations for 13 species, (2) not likely to adversely 6 modify designated critical habitat determination for the West Indian manatee, (3) may 7 adversely modify designated critical habitat determination for the American crocodile, and 8 (4) request to enter formal consultation for the American crocodile and the eastern indigo snake 9 in accordance with 50 CFR 402.12(j) and 50 CFR 402.14, Formal Consultation. The NRC 10 staff will update this section in the final SEIS to include any correspondence transpiring between 11 the issuance of this draft SEIS and the final SEIS. 12 Endangered Species Act Section 7 Consultation with the National Marine Fisheries Service 13 During its review of the Turkey Point subsequent license renewal application, the NRC staff 14 considered whether any federally listed, proposed, or candidate species or proposed or 15 designated critical habitats may be present in the action area (as defined at 50 CFR 402.02, 16 Definitions) for the proposed action. With respect to species under the NMFSs jurisdiction, 17 the NMFS identified five federally listed species that have the potential to occur in the vicinity of 18 the Turkey Point site in a letter to the NRC dated April 26, 2017 (NMFS 2017). The five species 19 are loggerhead sea turtle (Caretta caretta), green sea turtle (Chelonia mydas), leatherback sea 20 turtle (Dermochelys coriacea), hawksbill sea turtle (Eretmochelys imbricata), and smalltooth 21 sawfish (Pristis pectinata). The NRC staff evaluated the potential impacts to these species in 22 Section 3.8 and Section 4.8 of this SEIS. The staff concludes that the proposed subsequent 23 license renewal may affect but is not likely to adversely affect these species. No other NMFS 24 listed, proposed, or candidate species or proposed or designated critical habitats occur in the 25 action area. The NRC staff will submit a copy of this draft SEIS, upon its issuance, to the NMFS 26 for review accompanied by a request for the NMFS to concur with the staffs may affect, but is 27 not likely to adversely affect determinations in accordance with 50 CFR 402.12(j). The NRC 28 staff will update this section in the final SEIS to include any correspondence transpiring between 29 the issuance of this draft SEIS and the final SEIS. 30 C.2 Essential Fish Habitat Consultation 31 The Magnuson-Stevens Fishery Conservation and Management Act, as amended 32 (16 U.S.C. 1801-1884), requires Federal agencies to consult with the NMFS with respect to any 33 action authorized, funded, or undertaken, or proposed to be authorized, funded, or undertaken 34 that may adversely affect any Essential Fish Habitat identified under the Act. 35 In Sections 3.8 and 4.8 of this SEIS, the NRC staff concludes that although the NMFS has 36 designated Essential Fish Habitat for a number of federally managed species within Biscayne 37 Bay, neither Essential Fish Habitat nor the species themselves occur in the CCS or on the 38 Turkey Point site because there are no surface water connections between the CCS and any 39 natural waterbodies and that the proposed Turkey Point subsequent license renewal would not 40 result in any impacts to Essential Fish Habitat. Accordingly, the NRC is not required under the 41 Act to consult with the NMFS for the proposed action. 42 C.3 National Historic Preservation Act Section 106 Consultation 43 The National Historic Preservation Act of 1966, as amended (16 U.S.C. 470 et seq.; herein 44 referred to as NHPA), requires Federal agencies to take into account the effects of their C-3

1 undertakings on historic properties and consult with applicable State and Federal agencies, 2 Tribal groups, individuals, and organizations with a demonstrated interest in the undertaking 3 before taking action. Historic properties are defined as resources that are eligible for listing on 4 the National Register of Historic Places (NRHP). The historic preservation review process 5 (Section 106 of the NHPA) is outlined in regulations issued by the Advisory Council on Historic 6 Preservation (ACHP) in 36 CFR Part 800, Protection of Historic Properties. In accordance 7 with 36 CFR 800.8(c), Use of the NEPA Process for Section 106 Purposes, the NRC has 8 elected to use the NEPA process to comply with its obligations under Section 106 of the NHPA. 9 Table C-1 lists the chronology of consultation and consultation documents related to the NRCs 10 NHPA Section 106 review of the Turkey Point subsequent license renewal. The NRC staff is 11 required to consult with the noted agencies and organizations in accordance with the statute 12 and regulations listed in the previous paragraph. 13 Table C-1 National Historic Preservation Act Correspondence ADAMS Date Sender and Recipient Description Accession No. (a) May 24, 2018 B. Beasley (NRC) to B. Cypress, Request for scoping ML18114A381 Miccosukee Tribe of Indians of comments/notification of Florida Section 106 review May 24, 2018 B. Beasley (NRC) to J. Floyd, Request for scoping ML18114A381 Muscogee (Creek) Nation comments/notification of Section 106 review May 24, 2018 B. Beasley (NRC) to S.A. Bryan, Request for scoping ML18114A381 Poarch Band of Creek Indians comments/notification of Section 106 review May 24, 2018 B. Beasley (NRC) to G. Chilcoat, Request for scoping ML18114A381 Seminole Nation of Oklahoma comments/notification of Section 106 review May 24, 2018 B. Beasley (NRC) to M.W. Request for scoping ML18114A381 Osceola, Seminole Tribe of comments/notification of Florida Section 106 review May 24, 2018 B. Beasley (NRC) to T. Parsons, Request for scoping ML18114A206 Florida Department of State, comments/notification of Division of Historical Resources Section 106 review May 24, 2018 B. Beasley (NRC) to S. Cody, Request for scoping ML18114A204 Miami-Dade County Office of comments/notification of Historic Preservation Section 106 review May 24, 2018 B. Beasley (NRC) to R. Nelson, Request for scoping ML18114A202 Advisory Council on Historic comments/notification of Preservation Section 106 review June 12, 2018 T. Isham, Seminole Nation of Request for Section 106 ML18169A152 Oklahoma to N. Martinez (NRC) consultation meetings June 26, 2018 T.A. Parsons, Florida Response to request for ML18183A482 Department of State to M. Ma scoping (NRC) comments/notification of Section 106 review July 3, 2018 V. Menchaca, Seminole Tribe of Response to request for ML18184A462 Florida to J. Borges Roman scoping (NRC) C-4

ADAMS Date Sender and Recipient Description Accession No. (a) comments/notification of Section 106 review July 19, 2018 N. Martinez (NRC) to B. Beasley Summary of ML18190A179 (NRC) teleconference between the NRC and the Seminole Nation of Oklahoma (a) Access these documents through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://adams.nrc.gov/wba/. C-5

1 2 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE 3 This appendix contains a chronological listing of correspondence between the U.S. Nuclear 4 Regulatory Commission (NRC) and external parties as part of the agencys environmental 5 review of the Turkey Point Nuclear Generating Unit Nos. 3 & 4 (Turkey Point, or Turkey Point 6 Units 3 and 4) subsequent license renewal application. This appendix does not include 7 consultation correspondence or comments received during the scoping process. For a list and 8 discussion of consultation correspondence, see Appendix C, Consultation Correspondence, of 9 this supplemental environmental impact statement (SEIS). For scoping comments, see 10 Appendix A, Comments Received on the Turkey Point Nuclear Generating Units 3 and 4 11 Environmental Review, of this SEIS and the NRCs scoping summary report (NRC 2019). All 12 documents are available electronically from the NRCs Public Electronic Reading Room found 13 at: http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to ADAMS, 14 which provides text and image files of the NRCs public documents. The ADAMS accession 15 number for each document is included in the following table. 16 D.1 Environmental Review Correspondence 17 Table D-1 lists the environmental review correspondence, by date, beginning with the request 18 by Florida Power & Light Company (FPL) for subsequent license renewal of the operating 19 licenses for Turkey Point Units 3 and 4. 20 Table D-1 Environmental Review Correspondence ADAMS Accession Date Correspondence Description No. January 30, 2018 Turkey Point Units 3 and 4Submittal of Subsequent ML18037A812 License Renewal Application February 9, 2018 Turkey Point Units 3 and 4 License Renewal Application ML18044A653 Supplement 1 February 16, 2018 Turkey Point, Units 3 and 4, Subsequent License Renewal ML18053A123 ApplicationSupplement 2 March 1, 2018 Turkey Point Units 3 and 4, Subsequent License Renewal ML18072A224 ApplicationSupplement 3 March 22, 2018 Press Release 18-009: NRC Makes Available First ML18085A035 Subsequent License Renewal Application from Turkey Point Nuclear Power Plant April 10, 2018 Turkey Point, Units 3 and 4, Subsequent License Renewal ML18102A521 Application Appendix E Environmental Report Supplemental Information April 10, 2018 Turkey Point Units 3 and 4Transmittal of Subsequent ML18113A132 License Renewal Application, Revision 1 April 12, 2018 Turkey Point Nuclear Generating Units 3 and 4Status of ML18074A252 Subsequent License Renewal Application (EPID No. L-2018-RNW-0002) April 13, 2018 Receipt and Availability of the Subsequent License Renewal ML17338A141 Application for the Turkey Point Nuclear Generating Units 3 and 4 D-1

ADAMS Accession Date Correspondence Description No. April 25, 2018 Turkey Point Nuclear Generating Units 3 and 4, Subsequent ML17360A054 License Renewal Application Online Reference Portal (EPID No. L-2018-RNW-002) April 26, 2018 Determination of Acceptability and Sufficiency for ML18003A050 Docketing, Proposed Review Schedule, and Opportunity for a Hearing Regarding the Application from FPL for Subsequent Renewal of the Turkey Point Units 3 and 4 (CAC Nos. MF9747 and MF9747) Press Release 18-014: NRC Accepts Application for May 3, 2018 ML18124A078 Subsequent License Renewal of Turkey Point Reactors Notice of Intent to Prepare an Environmental Impact May 14, 2018 Statement and Conduct Scoping Process for Turkey Point ML18109A516 Nuclear Plant Units 3 and 4 May 22, 2018 Press Release 18-019: CorrectedNRC To Hold Meeting ML18145A064 on Environmental Review for Turkey Point Subsequent License Renewal May 25, 2018 05/31/2018 Public Scoping Meeting for the Environmental ML18145A201 Review of the Subsequent License Renewal Application for Turkey Point Units 3 and 4 June 13, 2018 License Renewal Environmental Site Audit Regarding the ML18158A335 Turkey Point Nuclear Generating Units 3 and 4 Subsequent License Renewal Application (EPID No. L-2018-LNE-0001). June 22, 2018 Letter from the National Park Service (S. Craighead), to the ML18193B074 NRC pertaining to the Turkey Point, Units 3 and 4 Subsequent License Renewal July 3, 2018 Turkey Point Nuclear Generating Units 3 and 4In-Office ML18178A152 Regulatory Audit Plan Regarding Severe Accident Mitigation Alternatives in the Subsequent License Renewal Application Review (EPID No. L-2018-LNE-0001) July 9, 2018 Requests for Additional Information for the Environmental ML18190A499 review of the Turkey Point Subsequent License Renewal Application (EPID No. L-2018-LNE-0001) July 17, 2018 Requests for Additional Information for the Environmental ML18198A274 Review of the Turkey Point Subsequent License Renewal ApplicationSet 2 (EPID No. L-2018-LNE-0001) July 20, 2018 Summary of the Site Environmental Audit Related to the ML18178A229 Review of the Subsequent License Renewal Application for Turkey Point Nuclear Generating Units 3 and 4 (EPID No. L-2018-LNE-0001) July 20, 2018 National Park Service Cooperating Agency Request for ML18197A294 Subsequent License Renewal of Turkey Point Nuclear Generating Units 3 and 4 (EPID No. L-2018-LNE-0001) July 23, 2018 05/31/2018 Summary of Public Scoping Meeting for the ML18176A403 Environmental Review of the Subsequent License Renewal Application for Turkey Point Units 3 and 4 (EPID No. L-2018-LNE-0001) August 8, 2018 Turkey Point Units 3 and 4 Subsequent License Renewal ML18247A507 Application Environmental Report Requests for Additional Information (RAI) Responses D-2

ADAMS Accession Date Correspondence Description No. August 17, 2018 Notice of Public MeetingTurkey Point Subsequent ML18229A111 License Renewal Application ReviewDiscussion of Responses to Two Environmental Requests for Additional InformationHC-7 and WR-2 August 31, 2018 Turkey Point Nuclear Generating Units 3 and 4Summary ML18214A146 of the In-Office Regulatory Audit Regarding Severe Accident Mitigation Alternatives in the Subsequent License Renewal Application (EPID No. L-2018-LNE-0001) September 17, 2018 Requests for Additional Information for the Turkey Point ML18248A158 Subsequent License Renewal ApplicationEnvironmental Set 3 (EPID No. L-2018-LNE-0001) September 18, 2018 08/28/2018 Summary of Meeting to Discuss Turkey Point ML18247A301 Subsequent License Renewal Application Review - Discussion of Responses to Two Environmental Requests for Additional Information - HC-7 and WR-2 (EPID No. L-2018-LNE-0001) September 27, 2018 Teleconference Summary with NRC and FWS Re: Species ML18270A154 under Joint NMFS and FWS Jurisdiction for Turkey Point Subsequent License Renewal October 5, 2018 Turkey Point, Units 3 and 4, Responses to Requests for ML18283A882 Additional Information for Subsequent License Renewal Application Environmental Review November 11, 2018 11/13/2018 Telecon Between NRC and FPL to Discuss ML18315A003 Items Associated with the Safety Review of the Turkey Point Subsequent License Renewal Application November 28, 2018 Turkey Point, Units 3 and 4, Supplemental Response to ML18334A101 Request for Additional Information (RAI) Set 1, Subsequent License Renewal Application Environmental Review December 19, 2018 Letter to FWS transmitting Biological Assessment for the ML18344A008 Turkey Point Units 3 and 4 Proposed Subsequent License Renewal December 26, 2018 06/18/18 Summary of Interagency Meeting Related to ML18360A445 Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 January 2019 Environmental Scoping Summary Report Associated with ML18342A014 the Staff's Review of the Turkey Point Nuclear Generating Units 3 and 4 Subsequent License Renewal Application (EPID No. L-2018-LNE-0001) March 5, 2019 Letter from National Parks Service to NRC providing ML19072A162 comments on preliminary drafts of parts of Chapter 3 and Chapter 4 of Turkey Point Subsequent License Renewal Draft SEIS D-3

1 2 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS 3 This section describes the environmental impacts from postulated accidents that may occur at 4 Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point, or Turkey Point Units 3 5 and 4) during the subsequent license period. The term accident refers to any unintentional 6 event outside the normal plant operational envelope that could result in either (a) an unplanned 7 release of radioactive materials into the environment or (b) the potential for an unplanned 8 release of radioactive materials into the environment. NUREG-1437, Generic Environmental 9 Impact Statement for License Renewal of Nuclear Plants (GEIS) (NRC 1996, 2013a), evaluates 10 in detail the following two classes of postulated accidents as they relate to license renewal: 11

• Design-Basis Accidents: Postulated accidents that a nuclear facility must be designed 12 and built to withstand without loss to the systems, structures, and components 13 necessary to ensure public health and safety.

14

• Severe Accidents: Postulated accidents that are more severe than design-basis 15 accidents because they could result in substantial damage to the reactor core, whether 16 or not there are serious off-site consequences.

17 This section first describes the evaluation of new and significant information as it relates to 18 design-basis accidents, followed by an evaluation of new and significant information for severe 19 accidents. 20 E.1 Background 21 Although this supplemental environmental impact statement documents the NRC staffs review 22 of a subsequent license renewal application, it is helpful to keep in mind that long before any 23 license renewal actions, an operating reactor has already completed the NRC licensing process 24 for the original 40-year operating license. To receive a license to operate a new nuclear power 25 reactor, an applicant must submit to the NRC an operating license application that includes, 26 among many other requirements, a safety analysis report. The applicants safety analysis 27 report presents the design criteria and design information for the proposed reactor and includes 28 comprehensive data on the proposed site. The applicants safety analysis report also describes 29 various design-basis accidents and the safety features designed to prevent or mitigate their 30 impacts. The NRC staff reviews the operating license application to determine if the plants 31 designincluding designs for preventing or mitigating accidentsmeet the NRCs regulations 32 and requirements. 33 E.1.1 Design-Basis Accidents 34 Design-basis accidents are postulated accidents that a nuclear facility must be designed and 35 built to withstand without loss to the systems, structures, and components necessary to ensure 36 public health and safety. Planning for design-basis accidents ensures that the proposed plant 37 can withstand normal transients (rapid changes in the reactor coolant system temperature or 38 pressure, or rapid changes in reactor power), as well as a broad spectrum of postulated 39 accidents without undue hazard to the health and safety of the public. Many of these 40 design-basis accidents may occur, but are unlikely to occur even once during the life of the 41 plant; nevertheless, carefully evaluating each design-basis accident is crucial to establishing the 42 design basis for the preventive and mitigative safety systems of the proposed nuclear power E-1

1 plant. Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of 2 Production and Utilization Facilities, and 10 CFR Part 100, Reactor Site Criteria, describe the 3 NRCs acceptance criteria for design-basis accidents. 4 Before the NRC will issue an operating license for a new nuclear power plant, the applicant 5 must demonstrate the ability of its proposed reactor to withstand all design-basis accidents. 6 The applicant and the NRC staff evaluate the environmental impacts of design-basis accidents 7 for the hypothetical maximum-exposed individual. The results of these evaluations of 8 design-basis accidents are found in the reactors original licensing documents such as the 9 applicants final safety analysis report, the NRC staffs safety evaluation report, and the final 10 environmental statement (FES). Once the NRC issues the operating license for the new 11 reactor, the licensee is required to maintain the acceptable design and performance criteria 12 (which includes withstanding design-basis accidents) throughout the operating life of the nuclear 13 power plant, including any license renewal periods of extended operation. The consequences 14 for these events are evaluated for the hypothetical maximum exposed individual; as such, 15 changes in the plant environment will not affect these evaluations. 16 Pursuant to 10 CFR 54.29(a), license renewal applicants are required to manage the effects of 17 aging and perform any required time-limited aging analyses (as further described in the 18 regulation), such that there is reasonable assurance that the activities authorized by the 19 renewed license will continue to be conducted in accordance with the plants current licensing 20 basis (CLB) and any changes made to the plants CLB in order to comply with section 54.29 are 21 in accordance with the Atomic Energy Act and the Commissions regulations. In other words, 22 because of the requirements that the existing design-basis and aging management programs be 23 in effect for license renewal, the environmental impacts of design-basis accidents as calculated 24 for the original operating license application should not differ significantly from the 25 environmental impacts of design-basis accidents at any other time during plant operations, 26 including during the initial license renewal and subsequent renewal periods. Accordingly, the 27 design of the nuclear power plant, relative to design-basis accidents during the period of 28 extended operation, is considered to remain acceptable. 29 E.1.2 Design-Basis Accidents and License Renewal 30 The early identification and resolution of the design-basis accidents (prior to subsequent license 31 renewal) makes them a part of the current licensing basis (CLB) of the plant. The NRC requires 32 licensees to maintain the CLB of the plant under the current operating license, as well as during 33 any license renewal period. Therefore, under the provisions of 10 CFR 54.30, Matters not 34 Subject to a Renewal Review, design-basis accidents are not subject to review under license 35 renewal. 36 As stated in Section 5.3.2 of the 1996 GEIS, the environmental impact from design-basis 37 accidents was assessed in the individual plant-specific EISs at the time of the initial license 38 application review. Since the licensee is required to maintain the plant within acceptable design 39 and performance criteria, including during any license renewal term, these environmental 40 impacts are not expected to change significantly. Therefore, additional assessment of the 41 environmental impacts from design-basis accidents is not necessary (NRC 2013a). 42 The GEIS concludes that the environmental impacts of design-basis accidents are of SMALL 43 significance for all nuclear power plants, because the plants were designed to successfully 44 withstand these accidents. For the purposes of initial or subsequent license renewal, the NRC 45 designates design-basis accidents as a Category 1 generic issueapplicable to all nuclear E-2

1 power plants (see 10 CFR Part 51, Subpart A, Appendix B, Table B-1, Summary of Findings on 2 NEPA Issues for License Renewal of Nuclear Power Plants). During the license renewal 3 review process, the NRC staff adopts the applicable Category 1 issue conclusions from the 4 GEIS (unless there exists new and significant information about the issue). Hence, the NRC 5 staff need not address most Category 1 issues (like design-basis accidents) in the site-specific 6 supplemental environmental impact statement for license renewal, in the absence of new and 7 significant information pertinent to those issues. 8 In its environmental report for the Turkey Point subsequent license renewal application, Florida 9 Power & Light Company (FPL) did not identify any new and significant information related to 10 design-basis accidents at Turkey Point (FPL 2018f). The NRC staff also did not identify any 11 new and significant information related to design-basis accidents during its independent review 12 of FPLs environmental report, through the scoping process, or in its evaluation of other 13 available information. Therefore, the NRC staff concludes that there are no environmental 14 impacts related to design-basis accidents at Turkey Point during the subsequent license 15 renewal period beyond those already discussed generically for all nuclear power plants in 16 the GEIS. 17 E.1.3 Severe Accidents 18 Severe accidents are postulated accidents that are more severe than design-basis accidents 19 because severe accidents can result in substantial damage to the reactor core, whether or not 20 there are serious offsite consequences. Severe accidents can entail multiple failures of 21 equipment or function. The likelihood of a severe accident occurring is generally even lower 22 than the likelihood of a design-basis accident occurring. 23 E.1.4 Severe Accidents and License Renewal 24 Chapter 5 of the 1996 GEIS (NUREG-1437) conservatively predicts the environmental impacts 25 of postulated severe accidents that may occur during the period of extended operations at 26 nuclear power plants. In the 2013 GEIS, the staff updated the NRCs 1996 plant-by-plant 27 severe accident environmental impact assessments (NRC 2013a, Appendix E). In the GEIS, 28 the impacts of severe accidents that were considered include: 29

• dose and health effects of accidents 30
• economic impacts of accidents 31
• effect of uncertainties on the results 32 The NRC staff calculated these estimated impacts by studying the risk analysis of severe 33 accidents as reported in the environmental impact statements (EISs) and/or final environmental 34 statements that the NRC staff had prepared for each of the plants in support of their original 35 reactor operating licenses. When the NRC staff prepared the 1996 GEIS, 28 nuclear power 36 plant sites (44 units) had EISs or FESs that contained a severe accident analysis. Not all 37 original operating reactor licenses contain a severe accident analysis since the NRC has not 38 always required such analyses. The 1996 GEIS assessed the impacts of severe accidents 39 during the license renewal period, using the results of existing analyses and site-specific 40 information to conservatively predict the environmental impacts of severe accidents for all plants 41 during the renewal period. With few exceptions, the severe accident analyses evaluated in the 42 1996 GEIS were limited to consideration of reactor accidents caused by internal events. The 43 1996 GEIS addressed the impacts from external events qualitatively.

E-3

1 For its severe accident environmental impact analysis for each plant, the 1996 GEIS used very 2 conservative 95th percentile upper confidence bound estimates for environmental impact 3 whenever available. This approach provides conservatism to cover uncertainties, as described 4 in Section 5.3.3.2.2 of the 1996 GEIS. The 1996 GEIS concluded that the probability-weighted 5 impacts of severe accidents as related to license renewal are small compared to other risks to 6 which the populations surrounding nuclear power plants are routinely exposed. The NRCs 7 understanding of severe accident risk has continued to evolve since it issued the 1996 GEIS. 8 The updated 2013 GEIS assesses more recent information and developments in severe 9 accident analyses and how they might affect the conclusions in Chapter 5 of the 1996 GEIS. 10 The 2013 GEIS also provides comparative data where appropriate. Based on information in the 11 2013 GEIS, the NRC staff determined that for all nuclear power plants, the probability-weighted 12 consequences of severe accidents are SMALL. However, the GEIS determined that 13 alternatives to mitigate severe accidents must be considered for all plants that have not 14 considered such alternatives, as a Category 2 issue. See Table B-1, Summary of Findings on 15 NEPA Issues for License Renewal of Nuclear Power Plants, of Appendix B to Subpart A of 16 10 CFR Part 51, which states: 17 The probability-weighted consequences of atmospheric releases, fallout onto 18 open bodies of water, releases to groundwater, and societal and economic 19 impacts from severe accidents are SMALL for all plants. However, alternatives 20 to mitigate severe accidents must be considered for all plants that have not 21 considered such alternatives. 22 An analysis of severe accident mitigation alternatives was performed for Turkey Point at 23 the time of initial license renewal. The staff documented its review in NUREG-1437, 24 "Generic Environmental Impact Statement for License Renewal of Nuclear Plants," 25 Supplement 5, Regarding Turkey Point Nuclear Plant, Units 3 & 4. Any new and 26 significant information that might alter the conclusions of that analysis was considered 27 for subsequent license renewal, as discussed below. 28 E.2 Severe Accident Mitigation Alternatives 29 In a SAMA analysis, the NRC requires license renewal applicants to consider the environmental 30 impacts of severe accidents, their probability of occurrence, and potential means available to 31 mitigate those accidents. As quoted above, 10 CFR Part 51, Table B-1 states alternatives to 32 mitigate severe accidents must be considered for all plants that have not considered such 33 alternatives. This NRC requirement to consider alternatives to mitigate severe accidents can 34 be fulfilled by a severe accident mitigation alternatives (SAMA) analysis. The purpose of the 35 SAMA analysis is to identify design alternatives, procedural modifications, or training activities 36 that may further reduce the risks of severe accidents at nuclear power plants and that are also 37 potentially cost beneficial to implement. The SAMA analysis includes the identification and 38 evaluation of SAMAs that may reduce the radiological risk from a severe accident by preventing 39 substantial core damage (i.e., preventing a severe accident) or by limiting releases from 40 containment in the event that substantial core damage occurs (i.e., mitigating the impacts of a 41 severe accident) (NRC 2013b). The regulations at 10 CFR 51.53(c)(3)(ii)(L) state that each 42 license renewal applicant must submit an environmental report that considers alternatives to 43 mitigate severe accidents, If the staff has not previously considered severe accident mitigation 44 alternatives for the applicant's plant in an environmental impact statement or related supplement 45 or in an environmental assessment. E-4

1 E.2.1 Turkey Point Initial License Renewal Application and SAMA Analysis in 2 2000 3 As part of its initial license renewal application submitted in 2000, FPLs environmental report 4 included an analysis of SAMAs for Turkey Point Units 3 and 4 (FPL 2000). FPL based this 5 SAMA analysis on (1) the Turkey Point probabilistic safety assessment (PSA) for total accident 6 frequency, core damage frequency (CDF), and containment large early release frequency 7 (LERF), and (2) a supplemental analysis of offsite consequences and economic impacts for risk 8 determination. The Turkey Point PSA included a Level 1 analysis to determine the CDF from 9 internally initiated events and a Level 2 analysis to determine containment performance during 10 severe accidents. The offsite consequences and economic impacts analyses used the 11 MELCOR Accident Consequence Code System 2 (MACCS2) code, Version 1.2, to determine 12 the offsite risk impacts on the surrounding environment and the public. Inputs for the latter 13 analysis included plant/site-specific values for core radionuclide inventory, source term and 14 release fractions, meteorological data, projected population distribution (based on 1990 census 15 data, projected out to 2025), emergency response evacuation modeling, and economic data. 16 To help identify and evaluate potential SAMAs, FPL considered insights and recommendations 17 from SAMA analyses for other plants, potential plant improvements discussed in NRC and 18 industry documents, and documented insights provided by Turkey Point staff. 19 In its 2000 environmental report, FPL considered 167 SAMAs. FPL then performed a qualitative 20 screening of those SAMAs, eliminating SAMAs that were not applicable to Turkey Point or had 21 already been implemented at Turkey Point (or the design met the intent of the SAMA). Based 22 on this qualitative screening, 91 SAMAs were eliminated, leaving 76 subject to the final 23 screening and evaluation process. Of the 91 SAMAs eliminated, 64 were eliminated because 24 they had already been implemented at Turkey Point (or the design met the intent of the SAMA), 25 while 27 SAMAs were eliminated because they were not applicable to Turkey Point. The 76 26 remaining SAMAs were listed in Table F.2-2 of Appendix F of the 2000 ER (FPL 2000). The 27 final screening process involved identifying and eliminating those SAMAs whose cost exceeded 28 twice their benefit. Ultimately, FPL concluded that there were no potentially cost-beneficial 29 SAMAs associated with the initial Turkey Point license renewal (FPL 2000). 30 As part of the NRC staffs review of the initial Turkey Point license renewal application, the staff 31 reviewed FPLs analysis of SAMAs for Turkey Point Units 3 and 4 and documented this review 32 in its SEIS, which the NRC published in January 2002 as Supplement 5, Regarding Turkey 33 Point Nuclear Plant, Units 3 & 4, to NUREG-1437, "Generic Environmental Impact Statement 34 for License Renewal of Nuclear Plants" (NRC 2002c). Chapter 5 of Supplement 5 to 35 NUREG-1437 contains the NRC staffs evaluation of the potential environmental impacts of 36 plant accidents and examines each SAMA (individually and, in some cases, in combination) to 37 determine the SAMAs individual risk reduction potential. The NRC staff then compared this 38 potential risk reduction against the cost of implementing the SAMA to quantify the SAMAs 39 cost-benefit value. 40 In Section 5.2 of its 2002 SEIS for the initial Turkey Point license renewal (NUREG-1437, 41 Supplement 5), the NRC staff found that FPL used a systematic and comprehensive process for 42 identifying potential plant improvements for Turkey Point Units 3 and 4, and that its bases for 43 calculating the risk reductions afforded by these plant improvements were reasonable and 44 generally conservative. Further, the NRC staff found that FPLs estimates of the costs of 45 implementing each SAMA were reasonable and consistent with estimates developed for other 46 operating reactors. In addition, the NRC staff concluded that FPLs cost-benefit comparisons 47 were performed appropriately. The NRC staff concluded that FPLs SAMA methods and E-5

1 implementation of those methods were sound, and it agreed with FPLs conclusion that none of 2 the candidate SAMAs were potentially cost beneficial based on conservative treatment of costs 3 and benefits. The staff found FPLs conclusion consistent with the low residual level of risk 4 indicated in the Turkey Point probabilistic safety assessment, and was also consistent with the 5 fact that Turkey Point had already implemented many plant improvements identified during two 6 risk analysis processes: (1) the individual plant examination or IPE (a risk analysis that 7 considers the unique aspects of a particular nuclear power plant, identifying the specific 8 vulnerabilities to severe accident of that plant) and (2) the individual plant examination for 9 external events or IPEEE (a risk analysis that considers external events such as earthquakes, 10 internal fires, and high winds) (NRC 2002c). 11 E.2.2 Turkey Point 2018 Subsequent License Renewal Application and New and 12 Significant Information as it Relates to the Probability-Weighted 13 Consequences of Severe Accidents 14 As mentioned above, a license renewal application must include an environmental report that 15 describes SAMAs if the NRC staff has not previously evaluated SAMAs for that plant in an 16 environmental impact statement (EIS), in a related supplement to an EIS, or in an environmental 17 assessment. As also discussed above, the NRC staff performed a site-specific analysis of 18 Turkey Point SAMAs in a supplement to an EIS (Supplement 5, Regarding Turkey Point 19 Nuclear Plant, Units 3 & 4, to NUREG-1437, "Generic Environmental Impact Statement for 20 License Renewal of Nuclear Plants") (NRC 2002c). Therefore, in accordance with 21 10 CFR 51.53(c)(3)(ii)(L) and Table B-1 of Appendix B to Subpart A of 10 CFR Part 51, FPL is 22 not required to provide another SAMA analysis in its environmental report for the Turkey Point 23 subsequent license renewal application. 24 The NRCs regulations in 10 CFR Part 51, which implement Section 102(2) of the National 25 Environmental Policy Act (NEPA), require that all applicants for license renewal submit an 26 environmental report to the NRC, in which they identify any new and significant information 27 regarding the environmental impacts of license renewal of which the applicant is aware 28 (10 CFR 51.53(c)(3)(iv)). This includes new and significant information that could affect the 29 environmental impacts related to postulated severe accidents or that could affect the results of a 30 previous SAMA analysis. Accordingly, in its subsequent license renewal application 31 environmental report, FPL evaluates areas of new and significant information that could affect 32 the environmental impact of postulated severe accidents during the subsequent license renewal 33 period of extended operation, and possible new and significant information as it relates to 34 SAMAs. 35 In FPLs assessment of new and significant information related to SAMAs in its SLR application, 36 FPL utilized guidance that was recently issued by the Nuclear Energy Institute (NEI), which the 37 NRC staff has endorsed. As discussed in Section E-5 below, NEI developed a model approach 38 for license renewal applicants to use in assessing the significance of new information of which 39 the applicant is aware, that relates to a prior SAMA analysis that was performed in support of 40 the issuance of an initial license, renewed license, or combined license (COL). This effort led to 41 the publication of NEI 17-04, Model SLR New and Significant Assessment Approach for SAMA, 42 Rev. 0, on June 29, 2017 (NEI 2017). NEI 17-04 provides a tiered approach that entails a 43 3-stage screening process for the evaluation of new information. In this screening process, new 44 information is deemed to be potentially significant to the extent that it results in the 45 identification in Stage 1 (involving the use of PRA risk insights and/or risk model quantifications) 46 of an unimplemented SAMA that reduces the maximum benefit by 50 percent or more. If a 47 SAMA is found to result in a 50 percent reduction in maximum benefit in Stage 1, a Stage 2 E-6

1 assessment would then be performed (involving an updated averted cost-risk estimate for 2 implementing that SAMA). A Stage 3 assessment (involving a cost-benefit analysis) would be 3 required only for potentially significant SAMAs, i.e., those that are shown by the Stage 2 4 assessment to reduce the maximum benefit by 50 percent or more. Finally, if the Stage 3 5 assessment shows that a potentially significant SAMA is potentially cost-beneficial, thus 6 indicating the existence of new and significant information, then the applicant must supplement 7 the previous SAMA analysis. The NRC endorsed NEI 17-04 for use by license renewal 8 applicants on January 31, 2018 (NRC 2018m). FPLs assessment of new and significant 9 information related to its SAMA cost-benefit analysis is discussed in Section E.5 of this 10 Appendix. 11 Below, the NRC staff summarizes FPLs description of possible areas of new and significant 12 information and assesses FPLs conclusions. 13 E.3 Evaluation of New Information Concerning Severe Accident Consequences 14 for Turkey Point as it relates to the GEIS and the 2002 Turkey Point SEIS. 15 The 2013 GEIS considers developments in plant operation and accident analysis that could 16 have changed the assumptions made in the 1996 GEIS concerning severe accident 17 consequences. The 2013 GEIS confirmed the determination in the 1996 GEIS that the 18 probability-weighted consequences of severe accidents are small for all plants. In the 2013 19 GEIS, Appendix E provides the NRC staffs evaluation of the environmental impacts of 20 postulated accidents. Table E-19, Summary of Conclusions, shows the developments that the 21 NRC staff considered as well as the staffs conclusions. Consideration of the listed items was 22 the basis for the NRC staff's overall determination in the 2013 GEIS that the probability-23 weighted consequences of severe accidents remain small for all plants. 24 For subsequent license renewal for Turkey Point, the staff confirmed that there is no new and 25 significant information that would change the 2013 GEIS or the 2002 Turkey Point SEIS 26 conclusions on the consequences of severe accidents. The NRC staff evaluated FPLs 27 information related to the 2013 GEIS, Table E-19, Summary of Conclusions, during the onsite 28 Turkey Point audit and by reviewing docketed information (NRC 2018c). The results of that 29 review follow. 30 E.3.1 New Internal Events Information (Section E.3.1 of the 2013 GEIS) 31 After FPL submitted the Turkey Point initial license renewal application environmental report in 32 2000 and the NRC issued its corresponding SAMA review in its 2002 SEIS, there have been 33 many improvements to Turkey Points risk profile. The Turkey Point internal events core 34 damage frequency in the initial license renewal SAMA was approximately 1.6x10-5/year. The 35 current Turkey Point internal events probabilistic risk assessment (PRA) model of record has a 36 core damage frequency of approximately 7.0x10-7/year. This change represents a 37 96-percent reduction or a factor-of-23 reduction in core damage frequency for each unit. This 38 substantial improvement in CDF makes any proposed new SAMA or previously evaluated 39 SAMA less likely to be cost beneficial. 40 In the 2013 GEIS, the NRC staff reviewed the updated boiling-water reactor (BWR) and 41 pressurized-water reactor (PWR) internal event core damage frequencies (CDFs). The CDF is 42 an expression of the likelihood that, given the way a reactor is designed and operated, an 43 accident could cause the fuel in the reactor to be damaged. The 2013 GEIS addresses new 44 information on the risk and environmental impacts of severe accidents caused by internal E-7

1 events which had emerged following issuance of the 1996 GEIS and included consideration of 2 Turkey Points plant-specific PRA analysis. The new information addressed in the 2013 GEIS 3 indicates that PWR and BWR CDFs evaluated for the 2013 GEIS are generally comparable to 4 or less than the CDFs that formed the basis of the 1996 GEIS (NRC 2013a). 5 Therefore, the NRC staff concludes that the offsite consequences of severe accidents initiated 6 by internal events during the subsequent license renewal term would not exceed the impacts 7 predicted in the 2013 GEIS. For these issues, the GEIS predicted that the impacts would be 8 SMALL for all nuclear plants. The NRC staff identified no new and significant information 9 regarding internal events during its review of FPLs environmental report, during the SAMA 10 audit, through the scoping process, or through the evaluation of other available information. 11 Thus, the NRC staff agrees with FPLs conclusion that no new and significant information exists 12 for Turkey Point concerning offsite consequences of severe accidents initiated by internal 13 events that would alter the conclusions reached in the 2013 GEIS or Turkey Points previous 14 SAMA analysis. 15 E.3.2 External Events (Section E.3.2 of the 2013 GEIS) 16 Section E.3.2.3 of the 2013 GEIS concludes that the CDFs from severe accidents initiated by 17 external events, as quantified in NUREG-1150, Severe Accident Risks: An Assessment for 18 Five U.S. Nuclear Power Plants, (NRC 1990) and other sources, are comparable to CDFs from 19 accidents initiated by internal events but lower than the CDFs that formed the basis for the 20 1996 GEIS. In the 2013 GEIS, the environmental impacts from externally initiated events are 21 generally significantly lowerone or more orders of magnitude lowerthan the environmental 22 impacts from external events determined in the 1996 GEIS. 23 The 1996 GEIS concluded that severe accidents initiated by external events (such as 24 earthquakes, floods, or fires) could have potentially high consequences but also found that the 25 risks from these external events are adequately addressed through a consideration of severe 26 accidents initiated by internal events (such as a loss of cooling water). Therefore, the 1996 27 GEIS concluded that an applicant for license renewal need only analyze the environmental 28 impacts from an internal event to characterize the environmental impacts from either internal or 29 external events. 30 External Events: Seismic 31 In 2014, FPL performed a bounding seismic evaluation for Turkey Point using appropriate 32 seismic hazard curves and a plant-level fragility curve. This bounding seismic evaluation 33 demonstrated that the seismic risk at Turkey Point is not significant. By letter dated 34 January 22, 2016 (NRC 2016b), the NRC staff documented its review of FPLs Turkey Point 35 reevaluated seismic hazard, also referred to as the mitigating strategies seismic hazard 36 information. The staff confirmed FPLs conclusion that the Turkey Point reevaluated seismic 37 hazard is bounded by the current design basis at all frequencies above 1 Hertz (Hz). In 38 addition, in the staffs letter of June 16, 2016, the staff concluded that the FPL-determined 39 ground motion response spectrum adequately characterizes the reevaluated seismic hazard for 40 the Turkey Point site (NRC 2016b). For more detail, see the NRC staffs June 16, 2016 letter, 41 Turkey Point Nuclear Generating, Unit Nos. 3 And 4Staff Review of Mitigation Strategies 42 Assessment Report of the Impact of the Reevaluated Seismic Hazard Developed in Response 43 to the March 12, 2012, [10 CFR] 50.54(F) Letter (CAC Nos. MF7886 and MF7887) 44 (NRC 2016c). Thus, the NRC staff agrees with FPLs statement in its 2018 environmental E-8

1 report for Turkey Point subsequent license renewal, that Turkey Point does not require an 2 updated seismic probabilistic risk assessment for subsequent license renewal. 3 External Events: Fire 4 By letter dated May 28, 2015, the NRC approved amendments modifying the Turkey Point 5 Units 3 and 4 operating licenses and technical specifications to incorporate a new fire protection 6 licensing basis in accordance with 10 CFR 50.48(c), Fire Protection. The amendments 7 authorized the transition of Turkey Points fire protection program to a risk-informed and 8 performance-based program based on the 2001 edition of National Fire Protection Association 9 Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric 10 Generating Plants" (NRC 2015d]). FPL used the Fire PRA for consideration of the reduction in 11 benefit for the fire-related SAMAs in the Turkey Point subsequent license renewal application 12 environmental report. 13 In conclusion, there was a greater-than-a-factor-of-20 decrease in the Turkey Point internal 14 events CDF and seismic risk for Turkey Point was determined to be insignificant. Therefore, the 15 offsite consequences of severe accidents initiated by external events during the subsequent 16 license renewal term would not exceed the impacts predicted in the GEIS. For these issues, the 17 GEIS predicts that the impacts would be SMALL for all nuclear plants. The NRC staff identified 18 no new and significant information regarding external events during its review of 19 FPLs environmental report, through the SAMA audit, during the scoping process, or through the 20 evaluation of other available information. Thus, the NRC staff agrees with FPLs conclusion that 21 no new and significant information exists for Turkey Point concerning offsite consequences of 22 severe accidents initiated by external events that would alter the conclusions reached in the 23 2013 GEIS or Turkey Points previous SAMA analysis. 24 E.3.3 New Source Term Information (Section E.3.3 of the 2013 GEIS) 25 The source term refers to the magnitude and mix of the radionuclides released from the fuel 26 (expressed as fractions of the fission product inventory in the fuel), as well as their physical and 27 chemical form, and the timing of their release following an accident. The 2013 GEIS concludes 28 that, in most cases, more recent estimates give significantly lower release frequencies and 29 release fractions than was assumed in the 1996 GEIS. Thus, the environmental impacts of 30 radioactive materials released during severe accidents, used as the basis for the 1996 GEIS 31 (i.e., the frequency-weighted release consequences), are higher than the environmental impacts 32 that would be estimated today using more recent source term information. The staff also notes 33 that results from the NRCs State-of-the-Art Reactor Consequence Analysis (SOARCA) project 34 (which represents a significant ongoing effort to re-quantify realistic severe accident source 35 terms) confirm that source term timing and magnitude values calculated in the SOARCA reports 36 are significantly lower than source term values quantified in previous studies. The NRC staff 37 expects to incorporate the information gleaned from the SOARCA project in future revisions of 38 the GEIS. 39 For the reasons described above, current source term timing and magnitude at Turkey Point is 40 likely to be significantly lower than had been quantified in previous studies and the initial license 41 renewal Turkey Point SAMA analysis in 2000. Therefore, the offsite consequences of severe 42 accidents initiated with the new source term during the subsequent license renewal term would 43 not exceed the impacts predicted in the GEIS. For these issues, the GEIS predicts that the 44 impacts would be SMALL for all nuclear plants. The NRC staff identified no new and significant 45 information regarding internal events during its review of FPLs environmental report, through E-9

1 the SAMA audit, during the scoping process, or through the evaluation of other available 2 information. Thus, the NRC staff agrees with FPLs conclusion that no new and significant 3 information exists for Turkey Point concerning offsite consequences of severe accidents 4 initiated by internal events that would alter the conclusions reached in the 2013 GEIS or Turkey 5 Points previous SAMA analysis. 6 E.3.4 Power Uprate Information (Section E.3.4 of the 2013 GEIS) 7 Operating at a higher reactor power level results in a larger fission product radionuclide 8 inventory in the core than if the reactor were operating at a lower power level. In the event of an 9 accident, the larger radionuclide inventory in the core would result in a larger source term. If the 10 accident is severe, this larger source term could result in higher doses to offsite populations. 11 Large early release frequency (LERF) represents the frequency of sequences that result in early 12 fatalities. The impact of a power uprate on early fatalities can be measured by considering the 13 impact of the uprate on the LERF calculated value. To this end, Table E-14 of the 2013 GEIS 14 presents the change in LERF calculated by each licensee that has been granted a power uprate 15 of greater than 10 percent. As can be seen, the increase in LERF ranges from a minimal impact 16 to an increase of about 30 percent (with a mean of 10.5 percent). The 2013 GEIS, 17 Section E.3.4.3, Conclusion, determines that power uprates will result in a small to (in some 18 cases) moderate increase in the environmental impacts from a postulated accident. However, 19 taken in combination with the other information presented in the GEIS, the increases would be 20 bounded by the 95 percent upper confidence bound values in Table 5.10 and Table 5.11 of the 21 1996 GEIS. 22 In 2012, the NRC approved a 15 percent power uprate for Turkey Point, which included a 23 13 percent increase in core thermal power and a 1.7 percent measurement uncertainty 24 recapture, from 2,300 megawatts thermal (MWt) to 2644 MWt. Before the extended power 25 uprate, FPL calculated the Turkey Point Unit 4 internal events LERF to be 1.3x10-8/year. After 26 the extended power uprate, FPL conservatively projected the Unit 4 LERF to be 1.8x10-8/year. 27 This is a change of 4.3x10-9/year, or an increase in LERF of about 32 percent. The NRC staffs 28 safety evaluation for this extended power uprate at Turkey Point states that this increase in 29 LERF falls within the acceptance guidelines for being very small (i.e., less than 1x10-7 per 30 reactor year), set forth in Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic 31 Risk Assessment In Risk Informed Decisions on Plant Specific Changes to the Licensing Basis, 32 and therefore does not raise any concerns of adequate protection (NRC 2012). Accordingly, 33 even though the change in LERF is slightly greater than 30 percent (upper percentage increase 34 in LERF determined in the updated 2013 GEIS), the staff finds this change to be a very small 35 impact due to the very small change in LERF as defined in RG 1.174. 36 In sum, the staff finds the conclusions of the 2013 GEIS on this topic appropriate for the Turkey 37 Point subsequent license renewal application, considering that there was a very small (less 38 than 1x10-7 per reactor year) change in LERF, the increases would be bounded by the 39 95 percent upper confidence bound values in Table 5.10 and Table 5.11 of the 1996 GEIS and 40 Turkey Point had a greater-than-a-factor-of-20 decrease in the internal events CDF from the 41 original SAMA to the subsequent license renewal application (which lowers the LERF). 42 Therefore, the offsite consequences from the power uprate would not exceed the impacts 43 predicted in the GEIS. For these issues, the GEIS predicted that the impacts would be SMALL 44 to MODERATE for all nuclear plants. The NRC staff has identified no new and significant 45 information regarding power uprates during its review of FPLs environmental report, through 46 the SAMA audit, during the scoping process, or through the evaluation of other available E-10

1 information. Thus, the NRC staff agrees with FPLs conclusion that no new and significant 2 information exists for Turkey Point concerning offsite consequences due to power uprates that 3 would alter the conclusions reached in the 2013 GEIS or Turkey Points previous SAMA 4 analysis. 5 E.3.5 Higher Fuel Burnup Information (Section E.3.5 of the 2013 GEIS) 6 According to the 2013 GEIS, increased peak fuel burnup from 42 to 75 gigawatt days per metric 7 ton uranium (GWd/MTU) for PWRs, and 60 to 75 GWd/MTU for BWRs, results in small to 8 moderate increases (up to 38 percent) in environmental impacts in the event of a severe 9 accident. However, taken in combination with the other information presented in the 10 2013 GEIS, the increases would be bounded by the 95 percent upper confidence bound values 11 in Table 5.10 and Table 5.11 of the 1996 GEIS. 12 FPLs environmental report, Section 2.2.1, Reactor and Containment Systems, states that both 13 Units 3 and 4 are licensed for fuel that is slightly enriched uranium dioxide (i.e., fuel that is up to 14 5 percent by weight uranium-235). FPL operates the reactors at an equilibrium core maximum 15 fuel discharge burnup rate of 62 GWd/MTU (NRC 2018e). Therefore, the updated estimates of 16 offsite consequences remained within the bounds of the 1996 GEIS evaluation (NRC 2013a). 17 Therefore, the offsite consequences from higher fuel burnup would not exceed the impacts 18 predicted in the 2013 GEIS. For these issues, the GEIS predicted that the impacts would be 19 SMALL for all nuclear plants. The NRC staff identified no new and significant information 20 regarding higher fuel burnup during its review of FPLs environmental report, SAMA audit, the 21 scoping process, or the evaluation of other available information. Thus, the staff agrees with 22 FPLs conclusion that no new and significant information exists for Turkey Point concerning 23 offsite consequences due to higher fuel burnup that would alter the conclusions reached in the 24 2013 GEIS or Turkey Points previous SAMA analysis. 25 E.3.6 Low Power and Reactor Shutdown Event Information (Section E.3.6 of the 26 2013 GEIS) 27 The 2013 GEIS concludes that the environmental impacts from accidents at low-power and 28 shutdown conditions are generally comparable to those from accidents at full power, based on a 29 comparison of the values in NUREG/CR-6143, Evaluation of Potential Severe Accidents 30 During Low Power and Shutdown Operations at Grand Gulf, Unit 1, (NRC 1995a) and 31 NUREG/CR-6144, Evaluation of Potential Severe Accidents During Low Power and Shutdown 32 Operations at Surry, Unit 1, (NRC 1995b), with the values in NUREG-1150, Severe Accident 33 Risks: An Assessment for Five U.S. Nuclear Power Plants (NRC 1990). The 1996 GEIS 34 estimates of the environmental impact of severe accidents bound the potential impacts from 35 accidents at low power and shutdown, with margin. There are no plant configurations in low 36 power and shutdown conditions that would distinguish Turkey Point from the evaluated plants 37 such that the assumptions in the 2013 and 1996 GEISs would not apply. 38 Finally, as discussed in SECY-97-168, Issuance for Public Comment of Proposed Rulemaking 39 Package for Shutdown and Fuel Storage Pool Operation (NRC 1997), industry initiatives taken 40 during the early 1990s have also contributed to the improved safety of low-power and shutdown 41 operations for all plants. Therefore, the offsite consequences of severe accidents, considering 42 low-power and reactor shutdown events, would not exceed the impacts predicted in the 1996 or 43 2013 GEIS. For these issues, the GEIS predicts that the impacts would be SMALL for all 44 nuclear plants. The NRC staff identified no new and significant information regarding low-power E-11

1 and reactor shutdown events during its review of FPLs environmental report, through the NRC 2 staffs SAMA audit, during the scoping process, or through the evaluation of other available 3 information. Thus, the staff agrees with FPLs conclusion that no new and significant 4 information exists for Turkey Point concerning low-power and reactor shutdown events that 5 would alter the conclusions reached in the 2013 GEIS or Turkey Points previous SAMA 6 analysis. 7 E.3.7 Spent Fuel Pool Accident Information (Section E.3.7 of the 2013 GEIS) 8 The 2013 GEIS concludes that the environmental impacts from accidents involving spent fuel 9 pools (as quantified in NUREG-1738, Technical Study of Spent Fuel Pool Accident Risk at 10 Decommissioning Nuclear Power Plants (NRC 2001)), can be comparable to those from 11 reactor accidents at full power (as estimated in NUREG-1150 (NRC 1990)). Subsequent 12 analyses performed, and mitigative measures employed since 2001, have further lowered the 13 risk of this class of accidents. In addition, even the conservative estimates from NUREG-1738 14 are much lower than the impacts from full power reactor accidents estimated in the 1996 GEIS. 15 Therefore, the environmental impacts stated in the 1996 GEIS bound the impact from spent fuel 16 pool accidents for all plants. For these issues, the GEIS predicts that the impacts would be 17 SMALL for all nuclear plants. There are no spent fuel configurations that would distinguish 18 Turkey Point from the evaluated plants such that the assumptions in the 2013 and 1996 GEISs 19 would not apply. The NRC staff identified no new and significant information regarding spent 20 fuel pool accidents during its review of FPLs environmental report, the SAMA audit, the scoping 21 process, or the evaluation of other available information. Thus, the NRC staff agrees with FPLs 22 conclusion that no new and significant information exists for Turkey Point concerning spent fuel 23 pool accidents that would alter the conclusions reached in the 2013 GEIS or Turkey Points 24 previous SAMA analysis. 25 E.3.8 Use of Biological Effects of Ionizing Radiation (BEIR)-VII Risk Coefficients 26 (Section E.3.8 of the 2013 GEIS) 27 In 2005, the NRC staff completed a review of the National Academy of Sciences report, Health 28 Risks from Exposure to Low Levels of Ionizing Radiation: Biological Effects of Ionizing Radiation 29 (BEIR) VII, Phase 2 (BEIR VII 2005). The staff documented its findings in SECY-05-0202, 30 Staff Review of the National Academies Study of the Health Risks from Exposure to Low 31 Levels of Ionizing Radiation (BEIR VII) (NRC 2005a). The SECY paper states that the NRC 32 staff agrees with the BEIR VII reports major conclusionnamely, the current scientific evidence 33 is consistent with the hypothesis that there is a linear, no-threshold, dose response relationship 34 between exposure to ionizing radiation and the development of cancer in humans. The 35 BEIR VII conclusion is consistent with the hypothesis on radiation exposure and human cancer 36 that the NRC uses to develop its standards of radiological protection. Therefore, the NRC staff 37 has determined that the conclusions of the BEIR VII report do not warrant any change in the 38 NRCs radiation protection standards and regulations, which are adequately protective of public 39 health and safety and will continue to apply during Turkey Points subsequent license renewal 40 term. This general topic is discussed further in the NRCs 2007 denial of Petition for Rulemaking 41 (PRM)-51-11, which found no need to modify the 1996 GEIS in light of the BEIR VII report. For 42 these issues, the GEIS predicts that the impacts of using the BEIR VII Risk Coefficients would 43 be SMALL for all nuclear plants. 44 The NRC staff has identified no new and significant information regarding the risk coefficient 45 used in the BEIR VII report during its review of FPLs environmental report, the SAMA audit, the 46 scoping process, or the evaluation of other available information. Thus, the staff concludes that E-12

1 no new and significant information exists for Turkey Point concerning the biological effects of 2 ionizing radiation that would alter the conclusions reached in the 2013 GEIS or Turkey Points 3 previous SAMA analysis. 4 E.3.9 Uncertainties (Section E.3.9 of the 2013 GEIS) 5 Section 5.3.3 in the 1996 GEIS provides a discussion of the uncertainties associated with the 6 analysis in the GEIS and in the individual plant EISs used to estimate the environmental impacts 7 of severe accidents. The 1996 GEIS used 95th percentile upper confidence bound estimates 8 whenever available for its estimates of the environmental impacts of severe accidents. This 9 approach provides conservatism to cover uncertainties, as described in Section 5.3.3.2.2 of the 10 1996 GEIS. Many of these same uncertainties also apply to the analysis used in the 2013 GEIS 11 update. As discussed in Sections E.3.1 through E.3.8 of the 2013 GEIS, the GEIS update used 12 more recent information to supplement the estimate of environmental impacts contained in the 13 1996 GEIS. In effect, the assessments contained in Sections E.3.1 through E.3.8 of the 2013 14 GEIS provided additional information and insights into certain areas of uncertainty associated 15 with the 1996 GEIS. However, as provided in the 2013 GEIS, the impact and magnitude of 16 uncertainties, as estimated in the 1996 GEIS, bound the uncertainties introduced by the new 17 information and considerations addressed in the 2013 GEIS. Accordingly, in the 2013 GEIS, 18 the staff concluded that the reduction in environmental impacts resulting from the use of new 19 information (since the 1996 GEIS analysis) outweighs any increases in impact resulting from the 20 new information. As a result, the findings in the 1996 GEIS remain valid. The NRC staff has 21 identified no new and significant information regarding uncertainties during its review of 22 FPLs environmental report, the SAMA audit, the scoping process, or the evaluation of other 23 available information. Accordingly, the NRC staff concludes that no new and significant 24 information exists for Turkey Point concerning uncertainties that would alter the conclusions 25 reached in the 2013 GEIS or Turkey Points previous SAMA analysis. 26 27 Section E.3.9.2 of Appendix E to the 2013 GEIS discusses the impact of population increases 28 on offsite dose and economic consequences. The 2013 GEIS, in section E.3.9.2, states the 29 following: 30 31 The 1996 GEIS estimated impacts at the mid-year of each plant's license renewal period 32 (i.e., 2030 to 2050). To adjust the impacts estimated in the NUREGs and NUREG/CRs 33 to the mid-year of the assessed plant's license renewal period, the information (i.e., 34 exposure indexes [EIs]) in the 1996 GEIS can be used. The Els adjust a plant's airborne 35 and economic impacts from the year 2000 to its mid-year license renewal period based 36 on population increases. These adjustments result in anywhere from a 5 to a 30 percent 37 increase in impacts, depending upon the plant being assessed. Given the range of 38 uncertainty in these types of analyses, a 5 to 30 percent change is not considered 39 significant. Therefore, the effect of increased population around the plant does not 40 generally result in significant increases in impacts. 41 Table 3.11-2 of Turkey Points ER provides population information for the County Populations 42 Totally or Partially Included within a 50-Mile Radius of Turkey Point. As Table 3.11-2 shows, 43 FPL estimates that in 2053 (i.e., at the end of the license renewal period for unit 4) the 44 population within the 50-mile radius will be 6,890,445. Assuming a uniform increase in 45 population, the mid-year population (2043) is projected to be 6,366,881 persons (37 percent 46 higher than the U.S. Census Bureau data for the four counties in 2010). FPLs estimated 47 population increase is slightly above the 30 percent range determined by the NRC in the 2013 48 GEIS to be not significant. However, as discussed in section E.3.3 of the 2013 GEIS and this E-13

1 SEIS, more recent estimates give significantly lower release frequencies and release fractions 2 for the source term than was assumed in the 1996 GEIS. Specifically, the 2013 GEIS states 3 that a comparison of population dose from newer assessments illustrates a reduction in impact 4 by a factor of 5 to 100 when compared to older assessments, and an additional factor of 2 to 4 5 due to the conservatism built into the 1996 GEIS values. Thus, the effect of this reduction in 6 total dose from a radiological release following a severe accident far exceeds the effect of a 7 population increase. The staff concludes that the effect of increased population around the 8 plant does not result in significant increases in impacts. Thus, the staff concludes that no new 9 and significant information exists for Turkey Point concerning population increase that would 10 alter the conclusions reached in the 2013 GEIS or Turkey Points previous SAMA analysis. 11 E.3.10 Summary/Conclusion (Section E.5 of the 2013 GEIS) 12 The 2013 GEIS categorizes sources of new information by their potential effect on the 13 best-estimate environmental impacts associated with postulated severe accidents. These 14 effects can (1) decrease the environmental impact associated with severe accidents, (2) not 15 affect the environmental impact associated with severe accidents, or (3) increase the 16 environmental impact associated with severe accidents. 17 Areas of new and significant information that can result in the first effect (decrease the 18 environmental impacts associated with severe accidents) at Turkey Point include: 19

• New internal events information (significant decrease) 20
• New source term information (significant decrease) 21 Areas of new and significant information that can result in the second effect (no effect on the 22 environmental impact associated with severe accidents) or the third effect (increase the 23 environmental impact associated with severe accidents) include:

24

• Use of BEIR VII risk coefficients 25
• Consideration of external events (comparable to internal event impacts) 26
• Spent fuel pool accidents (could be comparable to full-power event impacts) 27
• Higher fuel burnup (small to moderate increases) 28
• Low power and reactor shutdown events (could be comparable to full-power event 29 impacts) 30
• Population Increase 31 The 2013 GEIS states, Given the difficulty in conducting a rigorous aggregation of these results 32 with the differences in the information sources utilized, a fairly simple approach is taken. The 33 GEIS estimated the net increase from the first five areas listed above would be (in a simplistic 34 sense) approximately an increase by a factor of 4.7. At the same time, however, for Turkey 35 Point, the reduction in risk due to newer internal event information is a decrease in risk by a 36 factor of 23. The net effect of an increase by a factor of 4.7 and a decrease by a factor of 23 37 would be overall lower estimated impact (as compared to the 1996 GEIS assessment) by a 38 factor of 18.3. Thus, the staff finds that there is no new and significant information related to the 39 severe accidents at Turkey Point that would alter the conclusions reached in the 2013 GEIS or 40 Turkey Points previous SAMA analysis.

E-14

1 Other areas of new information relating to Turkey Point severe accident risk, severe accident 2 environmental impact assessment, and cost-beneficial SAMAs are described below. These 3 areas of new information demonstrate additional conservatism in the evaluations in the GEIS 4 and FPLs ER, because they result in further reductions in the impact of a severe accident. 5 E.4 Other New Information Related to NRC Efforts to Reduce Severe Accident 6 Risk Following Publication of the 1996 GEIS 7 The Commission has considered numerous ways to mitigate severe accidents, in addition to 8 requiring a SAMA analysis at the time of initial license renewal, and has adopted various 9 regulatory requirements for mitigating severe accident risks at reactor sites. In 1996, when it 10 promulgated Table B-1 in Appendix B to Subpart A of 10 CFR Part 51, the Commission 11 explained in a Federal Register notice: 12 The Commission has considered containment improvements for all plants 13 pursuant to its Containment Performance Improvement (CPI) programand the 14 Commission has additional ongoing regulatory programs whereby licensees 15 search for individual plant vulnerabilities to severe accidents and consider cost 16 beneficial improvements (Final rule, Environmental review for renewal of nuclear 17 power plant operating licenses, 61 FR 28467 (June 5, 1996)). 18 These additional ongoing regulatory programs that the Commission mentioned include 19 the IPE (individual plant examination) and the IPEEE (individual plant examination of 20 external events) program, which consider potential improvements to reduce the 21 frequency or consequences of severe accidents on a plant-specific basis and essentially 22 constitute a broad search for severe accident mitigation alternatives. Further, the 23 Commission observed that the IPEs resulted in a number of plant procedural or 24 programmatic improvements and some plant modifications that will further reduce the 25 risk of severe accidents. Based on these and other considerations, the Commission 26 stated its belief that it is unlikely that any site-specific consideration of SAMAs for 27 license renewal will identify major plant design changes or modifications that will prove 28 to be cost-beneficial for reducing severe accident frequency or consequences 29 (61 FR 28481). The Commission noted that it may review and possibly reclassify the 30 issue of severe accident mitigation as a Category 1 issue upon the conclusion of its 31 IPE/IPEEE program, but deemed it appropriate to consider severe accident mitigation 32 alternatives for plants for which had not done so previously, pending further rulemaking 33 on this issue (61 FR 28481). 34 The Commission reaffirmed its SAMA-related conclusions in Table B-1 of Appendix B to 35 Subpart A of 10 CFR Part 51 and 10 CFR 51.53(c)(3)(ii)(L), in Exelon Generation Co., LLC 36 (Limerick Generating Station, Units 1 and 2), CLI-13-07, (Oct. 31, 2013) (ADAMS No. 37 ML13304B417). In addition, the Commission observed that it had promulgated those 38 regulations because it had determined that one SAMA analysis would uncover most cost 39 beneficial measures to mitigate both the risk and the effects of severe accidents, thus satisfying 40 our obligations under NEPA (NRC 2013d). 41 The NRC has continued to address severe accident-related issues since the agency published 42 the GEIS in 1996. Combined NRC and licensee efforts have reduced risks from accidents 43 beyond those that were considered in the 1996 GEIS. The 2013 GEIS describes many of those 44 efforts (NRC 2013a). In some cases, such as the NRCs response to the accident at 45 Fukushima, these activities are still ongoing. In the remainder of Section E.4 of this SEIS, the E-15

1 NRC staff describes efforts to reduce severe accident risk (CDF and LERF) following publication 2 of the GEIS in 1996. Each of these initiatives applies to all reactors, including Turkey Point 3 Units 3 and 4. Section E.4.1 describes requirements adopted following the terrorist attacks in 4 September 2001, to address the loss of large areas of a plant caused by fire or explosions. 5 Section E.4.2 describes the SOARCA project, which indicates that source term timing and 6 magnitude values may be significantly lower than source term values quantified in previous 7 studies using other analysis methods. Section E.4.3 describes measures adopted following the 8 Fukushima earthquake and tsunami events of 2013. Section E.4.4 discusses efforts that have 9 been made to utilize plant operating experience to improve plant performance and design 10 features. These are areas of new information that reinforce the conclusion that the probability-11 weighted consequences of a severe accident are SMALL for all plants, as stated in the 12 2013 GEIS, and further reduce the likelihood of finding a cost-beneficial SAMA that would 13 substantially reduce the severe accident risk at Turkey Point. 14 E.4.1 10 CFR 50.54(hh)(2) Requirements Regarding Loss of Large Areas of the 15 Plant Caused by Fire or Explosions 16 As discussed on page E-7 of the 2013 GEIS, following the terrorist attacks of 17 September 11, 2001, the NRC conducted a comprehensive review of the agencys 18 security program and made further enhancements to security at a wide range of NRC-19 regulated facilities. These enhancements included significant reinforcement of the 20 defense capabilities for nuclear facilities, better control of sensitive information, 21 enhancements in emergency preparedness, and implementation of mitigating strategies 22 to deal with postulated events potentially causing loss of large areas of the plant due to 23 explosions or fires, including those that an aircraft impact might create. For example, 24 the Commission issued Order EA-02-026, Interim Compensatory Measures (ICM) 25 Order. The ICM Order provided interim safeguards and security compensatory 26 measure, and ultimately led to the promulgation of a new regulation in 27 10 CFR 50.54(hh). This regulation requires commercial power reactor licensees to 28 prepare for a loss of large areas of the facility due to large fires and explosions from any 29 cause, including beyond-design-basis aircraft impacts. In accordance with 10 CFR 30 50.54(hh)(2), licensees must adopt mitigation guidance and strategies to maintain or 31 restore core cooling, containment, and spent fuel pool cooling capabilities under 32 circumstances associated with the loss of large areas of the plant due to explosion or 33 fire. 34 NRC requirements pertaining to plant security are subject to NRC oversight on an ongoing basis 35 under a plants current operating license, and are beyond the scope of license renewal. As 36 discussed in Section 5.3.3.1 of the 1996 GEIS, the NRC addresses security-related events 37 using deterministic criteria in 10 CFR Part 73, Physical Protection of Plants and Materials, 38 rather than by risk assessments or SAMAs. However, the implementation of measures that 39 reduce the risk of severe accidents, including measures adopted to comply with 10 CFR 40 50.54(hh), also have a beneficial impact on the level of risk evaluated in a SAMA analysis, the 41 purpose of which is to identify potentially cost-beneficial design alternatives, procedural 42 modifications, or training activities that may further reduce the risks of severe accidents. . . 43 Inasmuch as FPL has updated Turkey Points guidelines, strategies, and procedures to meet 44 the requirements of 10 CFR 50.54(hh), those efforts have contributed to mitigation of the risk of 45 a beyond design basis event. Accordingly, actions taken by FPL to comply with those 46 regulatory requirements have further contributed to the reduction of risk at Turkey Point. E-16

1 In sum, the new information regarding actions taken by FPL to prepare for potential loss of large 2 areas of the plant due to fire or explosions has further contributed to the reduction of severe 3 accident risk at Turkey Point. Thus, this information does not alter the conclusions reached in 4 the 2013 GEIS regarding the consequences of a severe accident or Turkey Points previous 5 SAMA analysis. 6 E.4.2 SOARCA 7 The 2013 GEIS notes that a significant NRC effort is ongoing to re-quantify realistic severe 8 accident source terms under the State-of-the-Art Reactor Consequence Analysis (SOARCA) 9 project. Preliminary results indicate that source term timing and magnitude values quantified 10 using SOARCA may be significantly lower than source term values quantified in previous 11 studies using other analysis methods (NRC 2008). The NRC staff plans to incorporate this new 12 information regarding source term timing and magnitude using SOARCA in future revisions of 13 the GEIS. 14 The NRC has completed a SOARCA study for Surry Nuclear Power Station. The Surry Nuclear 15 Power Station is a Westinghouse 3-loop PWR similar to Turkey Point. The Surry SOARCA 16 summary concludes that with SOARCA, the NRC has achieved its objective of developing a 17 body of knowledge regarding detailed, integrated, state-of-the-art modeling of the more 18 important severe accident scenarios for Surry. SOARCA analyses indicate that successful 19 implementation of existing mitigation measures can prevent reactor core damage or delay or 20 reduce offsite releases of radioactive material. All SOARCA scenarios, even when unmitigated, 21 progress more slowly and release much less radioactive material than the potential releases 22 cited in the 1982 Siting Study (NUREG/CR-2239, Technical Guidance for Siting Criteria 23 Development). As a result, the calculated risks of public health consequences of severe 24 accidents modeled in SOARCA are very small. 25 This new information regarding the SOARCA projects findings has further contributed to the 26 reduction of the calculated severe accident risk at Turkey Point, as compared to the 1996 GEIS 27 and the Turkey Point SAMA evaluation for the initial license renewal application in 2000. Thus, 28 the NRC staff finds there is no new and significant information related to Turkey Point SAMAs 29 that would alter the conclusions reached in the 2013 GEIS or Turkey Points previous SAMA 30 analysis. 31 E.4.3 Fukushima-Related Activities 32 As discussed in Section E.2.1 of the 2013 GEIS, on March 11, 2011, a massive earthquake off 33 the east coast of the main island of Honshu, Japan, produced a tsunami that struck the coastal 34 town of Okuma in Fukushima Prefecture. This event damaged the six-unit Fukushima Dai-ichi 35 nuclear power plant, causing the failure of safety systems needed to maintain cooling water flow 36 to the reactors. Because of the loss of cooling, the fuel overheated, and there was a partial 37 meltdown of fuel in three of the reactors. Damage to the systems and structures containing 38 reactor fuel resulted in the release of radioactive material to the surrounding environment 39 (NRC 2013a). 40 As further discussed in Section E.2.1 of the 2013 GEIS, in response to the earthquake, tsunami, 41 and resulting reactor accidents at Fukushima Dai-ichi (hereafter referred to as the Fukushima 42 events), the Commission directed the NRC staff to convene an agency task force of senior 43 leaders and experts to conduct a methodical and systematic review of NRC regulatory 44 requirements, programs, and processes (and their implementation) relevant to the Fukushima E-17

1 event. After thorough evaluation, the NRC required significant enhancements to U.S. 2 commercial nuclear power plants. The enhancements included: adding capabilities to maintain 3 key plant safety functions following a large-scale natural disaster; updating evaluations on the 4 potential impact from seismic and flooding events; adding new equipment to better handle 5 potential reactor core damage events; and strengthening emergency preparedness capabilities. 6 Further information regarding this matter is presented in the 2013 GEIS and the NRCs Web site 7 Fukushima-related actions at https://www.nrc.gov/reactors/operating/ops-experience/post-8 fukushima-safety-enhancements.html. 9 In sum, the Commission has imposed additional safety requirements on operating reactors 10 following the Fukushima accident (as described in the preceding paragraphs). The new 11 regulatory requirements contribute to the mitigation of the risk of a severe accident. Therefore, 12 the NRC staff concludes there is no new and significant information related to the Fukushima 13 events that would alter the conclusions reached in the 2013 GEIS or Turkey Points previous 14 SAMA analysis. 15 E.4.4 Operating Experience 16 Section E.2 of the 2013 GEIS mentions the considerable operating experience that supports the 17 safety of U.S. nuclear power plants. As with the use of any technology, greater user experience 18 generally leads to improved performance and, if applicable, improved safety. This additional 19 experience has contributed to improved plant performance (e.g., as measured by trends in 20 plant-specific performance indicators), a reduction in adverse operating events, and lessons 21 learned that improve the safety of all the operating nuclear power plants. The items above 22 contribute to improved safety as do those safety improvements not related to license renewal 23 such as generic safety issues (e.g., Generic Safety Issue 191, Assessment of Debris 24 Accumulation on PWR Sump Pump Performance). Thus, the performance and safety record of 25 nuclear power plants operating in the United States, including Turkey Point, continue to 26 improve. This is also confirmed by analysis which indicates that, in many cases, improved plant 27 performance and design features have resulted in reductions in initiating event frequency, CDF, 28 and containment failure frequency (NRC 2013a). 29 Conclusion 30 As discussed above, the NRC and the nuclear industry have addressed and continue to 31 address numerous severe accident-related issues since the publication of the 1996 GEIS and 32 the 2000 Turkey Point SAMA analysis. These actions reinforce the conclusion that the 33 probability-weighted consequences of a severe accident are SMALL for all plants, as stated in 34 the 2013 GEIS, and further reduce the likelihood of finding a cost-beneficial SAMA that would 35 substantially reduce the severe accident risk at Turkey Point. 36 E.5 Florida Power & Lights Evaluation of New and Significant Information 37 Pertaining to SAMAs, Using NEI 17-04, Model SLR New and Significant 38 Assessment Approach for SAMA 39 In its evaluation of the significance of new information, the NRC staff considers that new 40 information is significant if it provides a seriously different picture of the impacts of the Federal 41 action under consideration. Thus, for mitigation alternatives such as SAMAs, new information is 42 significant if it indicates that a mitigation alternative would substantially reduce an impact of the 43 Federal action on the environment. Consequently, with respect to SAMAs, new information may 44 be significant if it indicates a given potentially cost-beneficial SAMA would substantially reduce E-18

1 the impacts of a severe accident or the probability or consequences (risk) of a severe accident 2 occurring. 3 As discussed in Section E.2.2 above, FPL stated in its environmental report submitted as part of 4 its subsequent license renewal application, that it used the methodology in NEI 17-04, Model 5 SLR New and Significant Assessment Approach for SAMA, dated June 29, 2017 (NEI 2017) to 6 evaluate new and significant information as it relates to the Turkey Point subsequent license 7 renewal SAMAs. By letter dated January 31, 2018, the staff reviewed NEI 17-04 and found it 8 acceptable for interim use, pending formal NRC endorsement of NEI 17-04 by incorporation in 9 Regulatory Guide 4.2, Supplement 1, Preparation of Environmental Reports for Nuclear Power 10 Plant License Renewal Applications, (NRC 2018m). In general, as discussed above, the 11 NEI 17-04 methodology (NEI 2017) does not consider a potential SAMA to be significant unless 12 it reduces by at least 50 percent the maximum benefit as defined in Section 4.5, Total Cost of 13 Severe Accident Risk/Maximum Benefit, of NEI 05-01, Revision A, Severe Accident Mitigation 14 Alternatives (SAMA) Analysis Guidance Document. 15 NEI 17-04, Model SLR New and Significant Assessment Approach for SAMA, describes a 16 three-stage process for determining whether there is any new and significant information 17 relevant to a previous SAMA analysis. 18

• Stage 1: The subsequent license renewal applicant uses PRA risk insights and/or risk 19 model quantifications to estimate the percent reduction in the maximum benefit 20 associated with (1) all unimplemented Phase 2 SAMAs for the analyzed plant and 21 (2) those SAMAs identified as potentially cost beneficial for other U.S. nuclear power 22 plants and which are applicable to the analyzed plant. If one or more of those SAMAs 23 are shown to reduce the maximum benefit by 50 percent or more, then the applicant 24 must complete Stage 2. (Applicants that are able to demonstrate through the Stage 1 25 screening process that there is no potentially significant new information are not required 26 to perform the Stage 2 or Stage 3 assessments).

27

• Stage 2: The subsequent license renewal applicant develops updated averted cost-risk 28 estimates for implementing those SAMAs. If the Stage 2 assessment confirms that one 29 or more SAMAs reduce the maximum benefit by 50 percent or more, then the applicant 30 must complete Stage 3.

31

• Stage 3: The subsequent license renewal applicant performs a cost-benefit analysis for 32 the potentially significant SAMAs identified in Stage 2.

33 The following sections describe FPLs application of the NEI 17-04 methodology to Turkey Point 34 SAMAs. FPL determined that none of the SAMAs evaluated in Stage 1 reduced the maximum 35 benefit by 50 percent or more. As a result, FPL concluded it is not required to perform the 36 Stage 2 or Stage 3 evaluations for any SAMAs. 37 E.5.1 Data Collection 38 NEI 17-04 Section 3.1, Data Collection, explains that the initial step of the assessment process 39 is to identify the new information relevant to the SAMA analysis and to collect and develop 40 those elements of information that will be used to support the assessment. The guidance 41 document states that each applicant should collect, develop, and document the information 42 elements corresponding to the stage or stages of the SAMA analysis performed for the site. For 43 Turkey Point subsequent license renewal, the NRC staff reviewed the onsite information during E-19

1 an audit at NRC headquarters and determined that FPL had considered the appropriate 2 information (NRC 2018d). 3 E.5.2 Stage 1 Assessment 4 Section 4.15.3, Methodology for Evaluation of New and Significant SAMAs, of FPLs 5 environmental report describes the process it used for identifying any potentially new and 6 significant SAMAs from the 2000 SAMA analysis (FPL 2018f). In Stage 1 of the process, FPL 7 used PRA risk insights and/or risk model quantifications to estimate the percent reduction in the 8 maximum benefit associated with the following two types of SAMAs: 9 1) all unimplemented Phase 2 SAMAs for Turkey Point 10 2) those SAMAs identified as potentially cost beneficial for other U.S. nuclear power 11 plants and which are applicable to Turkey Point (FPL 2018f) 12 As discussed below, as a result of FPLs qualitative and quantitative Stage 1 screening, all 13 potential SAMAs were found to reduce the maximum benefit by less than 50 percent, and they 14 were therefore screened out from further evaluation. Therefore, Stage 2 of the NEI methodology 15 was not entered, and an update of the Turkey Point Level 3 PRA was not needed. 16 E.5.3 Florida Power & Lights Evaluation of Unimplemented Phase 2 SAMAs for 17 Turkey Point 18 In 2000, FPL submitted an application for initial operating license renewal (FPL 2000), which the 19 NRC approved in 2002. As part of that initial license renewal process, FPL performed a 20 detailed evaluation of potential SAMAs, identifying 167 potential SAMAs. FPL then qualitatively 21 screened out 93 of these potential SAMAs from further evaluation (for example, by screening 22 out SAMAs that are only applicable to boiling water reactors), leaving 76 potential SAMAs. For 23 these 76 SAMAs, FPL performed a detailed cost-benefit analysis (FPL 2000). The cost benefit 24 analysis included development of a Level 3 probabilistic risk assessment (PRA) for Turkey Point 25 Unit 3, which FPL used to calculate conditional offsite population doses and offsite economic 26 consequences for each of the PRA source term categories (STCs). FPL developed the analysis 27 for Turkey Point Unit 3, but it was applicable to the license renewal for both units (FPL 2000). 28 By calculating the reduction in source term category frequencies for each potential SAMA, the 29 present value dollar benefit of each SAMA was determined using the guidance of 30 NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook, (FPL 2000). FPL 31 then compared the benefit to a cost estimate for each to complete the cost-benefit comparison. 32 The conclusion reached by FPL in the SAMA analysis in its 2000 environmental report and by 33 the NRC staff in its 2002 SEIS was that none of the analyzed Turkey Point SAMAs were 34 potentially cost-beneficial. 35 As part of its subsequent license renewal application, FPL examined the Turkey Point 36 probabilistic risk assessment again, for insights. The purpose was to determine if there was any 37 new and significant information regarding the SAMA analyses that were performed to support 38 issuance of the initial renewed operating licenses for Turkey Point. FPL re-evaluated the 39 76 SAMAs that were considered in connection with initial license renewal, using the NEI 17-04 40 process. Based on the Phase 1 qualitative and quantitative screening results, FPL found that all 41 plant-specific and industry SAMAs were demonstrated to not be new and significant. Therefore, 42 FPL concluded that there is no new and significant information that would alter the conclusions 43 of Turkey Points SAMA analysis for initial license renewal. E-20

1 E.5.4 Florida Power & Light Evaluation of SAMAs Identified as Potentially Cost 2 Beneficial at Other U.S. Nuclear Power Plants and Which Are Applicable to 3 Turkey Point 4 The 2013 GEIS (NRC 2013a) considered the plant-specific supplemental EISs that document 5 potential environmental impacts and mitigation measures for severe accidents relevant to 6 license renewal for each plant. Some of these plant-specific supplements had identified 7 potentially cost-beneficial SAMAs. FPL reviewed the SEISs of plants with a similar design to 8 Turkey Point (large, dry PWR containment), to identify potentially cost-beneficial SAMAs. FPL 9 qualitatively screened from further evaluation any SAMAs that were not applicable to Turkey 10 Point, SAMAs that were already implemented at Turkey Point, and SAMAs that had excessive 11 implementation costs. In this regard, FPL screened out SAMAs from further consideration if the 12 initial license renewal review found that they reduced the Turkey Point maximum benefit by 13 greater than 50 percent but were found not to be cost effective due to their high estimated costs 14 of implementation. FPL grouped the remaining SAMAs based on similarities in mitigation 15 equipment or risk reduction benefits. FPL then evaluated all the remaining SAMAs for the 16 impact they would have assuming those SAMAs were implemented at Turkey Point. 17 Section 4.15.4.2 of FPLs subsequent license renewal environmental report provides the Turkey 18 Point Stage 1 screening evaluation, using the methodology in NEI 17-04 Model SLR New and 19 Significant Assessment Approach for SAMA. FPL evaluated 76 Turkey Point-specific SAMAs 20 and 263 potentially cost-beneficial SAMAs identified at similarly designed nuclear power plants 21 (industry SAMAs). The SAMAs were related to both internal and external events. Qualitative 22 screening resulted in elimination from further analysis of all external event SAMAs in the Turkey 23 Point subsequent license renewal application, based on application of the screening criteria in 24 section 3.2.1 of NEI 17-04. Qualitative screening of internal event SAMAs, along with binning of 25 similar SAMAs, reduced the total number of SAMAs requiring further evaluation to 13. FPL 26 binned the SAMAs in a manner that allowed bounding cases that completely addressed a plant 27 risk contributor to be defined to estimate the maximum possible benefits for any of the grouped 28 SAMAs. For example, all intersystem loss-of-coolant accident (ISLOCA)-related SAMAs could 29 be represented by a single case in which all ISLOCA events are set to zero (i.e., the risk of an 30 ISLOCA event was assumed to be completely eliminated by SAMA implementation). The NRC 31 staff finds that this bounding approach provides a conservative analysis. 32 Table 4.15-1 of FPLs environmental report lists the 13 SAMAs identified by FPL as requiring a 33 quantitative screening analysis, including the industry internal events SAMAs and the Turkey 34 Point-specific SAMAs. FPL then performed quantitative screening using the full internal events 35 Turkey Point Level 2 probabilistic risk assessment and the CDF/LERF portions of the fire and 36 flood probabilistic risk assessments. Specifically, FPL quantitatively screened SAMAs if the 37 bounding Turkey Point-specific case yielded a reduction of less than 50 percent in the frequency 38 of each source term category group. As stated in Section 4.15.4.1 of the environmental report, 39 the criterion for quantitative screening from further evaluation in the Stage 1 evaluation was that 40 the SAMA does not reduce any source term category group frequency by at least 50 percent; if 41 a SAMA was found to reduce at least one source term category group frequency by at least 50 42 percent, the SAMA would be evaluated in a Stage 2 assessment (as described in section E.5). 43 In accordance with this approach, FPL performed the qualitative and quantitative Stage 1 44 screening, and determined that all potential SAMAs were screened out from further evaluation. 45 Since none of the SAMAs were found to reduce the maximum benefit by at least 50 percent, 46 FPL determined that the SAMAs are not potentially significant and a Stage 2 assessment is 47 not needed. Therefore, FPL concluded it was not required to proceed to a Stage 2 assessment E-21

1 for any SAMAs. As stated in NEI 17-04, if a plant is able to demonstrate that none of the 2 SAMAs evaluated in the Stage 1 assessment are potentially significant, then the Stage 2 inputs, 3 such as the projected population within a 50-mile radius of the plant, should be listed as new 4 information, but no work to estimate the actual 50-mile population is required. Accordingly, 5 consistent with NEI 17-04, there was no need for FPL to conduct a quantitative assessment of 6 the effect of an increase in population numbers relative to the population considered in its initial 7 license renewal SAMA analysis 8 The NRC staff reviewed Turkey Points onsite information and its SAMA identification and 9 screening process, during an in-office audit at NRC headquarters (NRC 2018d). The staff found 10 that FPL had used a methodical and reasonable approach to identify any SAMAs that might 11 reduce the maximum benefit by at least 50 percent and therefore be considered to be potentially 12 significant. Therefore, the NRC staff finds that FPL properly concluded, in accordance with the 13 NEI 17-04 guidance, that a Stage 2 assessment was not needed. 14 E.5.5 Other New information 15 As discussed in FPLs subsequent license renewal application environmental report and in 16 NEI 17-04, there are some inputs to the SAMA analysis that are expected to change or to 17 potentially change for all plants. These inputs include the following: 18

• Updated Level 3 PRA model consequence results, which may be impacted by multiple 19 inputs, including, but not limited to, the following:

20 o population, as projected within a 50-mile (80-km) radius of the plant 21 o value of farm and nonfarm wealth 22 o core inventory (e.g., due to power uprate) 23 o evacuation timing and speed 24 o Level 3 PRA methodology updates 25 o cost-benefit methodology updates 26 In addition, other changes that could be considered to be new information may be dependent on 27 plant activities or site-specific changes. These types of changes (listed in NEI 17-04) include 28 the following: 29

• Identification of a new hazard (e.g., a fault that was not previously analyzed in the 30 seismic analysis) 31 o Updated plant risk model (e.g., a fire probabilistic risk assessment that replaces 32 the individual plant examination of external events (IPEEE) analysis).

33

• Impacts of plant changes that are included in the plant risk models will be reflected in the 34 model results and do not need to be assessed separately.

35

• Non-modeled modifications to the plant 36 o Modifications determined to have no risk impact need not be included 37 (e.g., replacement of the condenser vacuum pumps), unless they impact a 38 specific input to SAMA (e.g., new low-pressure turbine in the power conversion 39 system that results in a greater net electrical output) 40 Offsite consequence codes used in SAMA analyses consider plant-specific inputs as provided 41 above. A detailed SAMA analysis would be able to analyze numerous plant-specific variables 42 and the sensitivity of a SAMA analysis to these variables. However, inasmuch as a thorough E-22

1 SAMA analysis was previously performed for Turkey Points initial license renewal, a new SAMA 2 analysis is not required by 51.53(c)(3)(ii)(L) and 10 CFR Part 51, Table B-1. Rather, as 3 explained above, the licensee is required to consider new and significant information, i.e., new 4 information that provides a seriously different picture of the consequences of the Federal action 5 under consideration. With respect to SAMAs, new information may be significant if it indicated a 6 SAMA would substantially reduce the probability or consequences of a severe accident. 7 The NEI methodology in NEI 17-04 uses maximum benefit to determine if SAMA-related 8 information is new and significant. Maximum benefit (MB) is defined in Section 4.5 of NEI 05-9 01, Revision A, Severe Accident Mitigation Alternatives (SAMA) Analysis Guidance Document, 10 (NEI 2005), as the benefit a SAMA could achieve if it eliminated all risk. The total off-site dose 11 and total economic impact are the baseline risk measures from which the maximum benefit is 12 calculated. The NEI methodology in NEI 17-04 considers a SAMA to be potentially significant if 13 it reduces the maximum benefit by at least 50 percent. The NRC staff finds the criterion of 14 exceeding a 50-percent reduction in MB to be a reasonable significance threshold, because its 15 correlates with the significance determination used in the ASME/ANS PRA standard, NUMARC 16 93-01, and NEI 00-04, all of which have been endorsed by the staff. It is also a reasonable 17 quantification of the qualitative criterion for significance, which states that new information is 18 significant if it presents a seriously different picture of the impacts of the Federal action under 19 consideration. Furthermore, it is consistent with the criterion that was accepted by the NRC 20 staff in the Limerick Generating Station license renewal FSEIS. 21 In evaluating the guidance in NEI 17-04, the NRC staff found the 50-percent reduction approach 22 described in NEI 17-04 to be reasonable because, with respect to SAMAs, the staff concluded 23 that new information may be significant if it indicates a potentially cost-beneficial SAMA could 24 substantially reduce the probability or consequences (risk) of a severe accident occurring. The 25 implication of this statement is that significance is not solely related to whether a SAMA is cost 26 beneficial (which may be affected by economic factors, increases in population, etc.), but 27 depends also on a SAMAs potential to significantly reduce risk to the public. 28 E.5.6 Conclusion 29 As described above, FPL evaluated a total of 339 SAMAs for Turkey Point subsequent license 30 renewal and did not find any SAMAs that would reduce the maximum benefit by 50 percent or 31 more, and that further analysis was not required based on the guidance in NEI 17-04. The NRC 32 staff reviewed FPLs evaluation and concludes that the methods used, and the results obtained, 33 were reasonable. Based on Turkey Points Phase 1 qualitative and quantitative screening 34 results, FPL demonstrated that none of the plant-specific and industry SAMAs that it considered 35 constitute new and significant information in that none changed the conclusion of Turkey Points 36 previous SAMA analysis. Further, the NRC staff has not identified any other new and significant 37 information that would alter the conclusions reached in the previous SAMA analysis for Turkey 38 Point. Therefore, the NRC staff finds no new and significant information that would alter the 39 conclusions of the SAMA analysis performed for Turkey Points initial license renewal. 40 The NRC staff reviewed FPLs new and significant information analysis for severe accidents and 41 SAMAs at Turkey Point during the subsequent license renewal period and finds the analysis 42 and the methods used to be reasonable. Given the low residual risk at Turkey Point, the 43 substantial decrease in CDF at Turkey Point since the previous SAMA analysis, and the fact 44 that no potentially cost-beneficial SAMAs were identified during the Turkey Points initial license 45 renewal review, the staff considers it unlikely that FPL would have found any potentially cost-46 beneficial SAMAs for subsequent license renewal. Further, FPLs implementation of actions to E-23

1 satisfy the NRCs orders and regulatory requirements regarding beyond-design-basis events 2 after the 9/11 and Fukushima events, as well as the conservative assumptions used in earlier 3 severe accident studies and SAMA analyses, also made it unlikely that FPL would have found 4 any potentially significant cost-beneficial SAMAs during its subsequent license renewal review. 5 For all of the reasons stated above, the NRC staff concludes that the conclusions reached by 6 FPL in its subsequent license renewal environmental report regarding SAMAs are reasonable 7 and that there is no new and significant information regarding any potentially cost-beneficial 8 SAMA that would substantially reduce the risks of a severe accident at Turkey Point. E-24

NUREG-1437 Supplement 5, Second Renewal Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5, Second Renewal Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 Draft Report for Comment Office of Nuclear Reactor Regulation

AVAILABILITY OF REFERENCE MATERIALS IN NRC PUBLICATIONS NRC Reference Material Non-NRC Reference Material As of November 1999, you may electronically access Documents available from public and special technical NUREG-series publications and other NRC records at libraries include all open literature items, such as books, the NRCs Public Electronic Reading Room at journal articles, transactions, Federal Register notices, http://www.nrc.gov/reading-rm.html. Publicly released Federal and State legislation, and congressional reports. records include, to name a few, NUREG-series Such documents as theses, dissertations, foreign reports publications; Federal Register notices; applicant, and translations, and non-NRC conference proceedings licensee, and vendor documents and correspondence; may be purchased from their sponsoring organization. NRC correspondence and internal memoranda; bulletins Copies of industry codes and standards used in a and information notices; inspection and investigative substantive manner in the NRC regulatory process are reports; licensee event reports; and Commission papers maintained at and their attachments. The NRC Technical Library NRC publications in the NUREG series, NRC Two White Flint North regulations, and Title 10, Energy, in the Code of 11545 Rockville Pike Federal Regulations may also be purchased from one Rockville, MD 20852-2738 of these two sources. These standards are available in the library for reference

1. The Superintendent of Documents use by the public. Codes and standards are usually U.S. Government Publishing Office copyrighted and may be purchased from the originating organization or, if they are American National Standards, Washington, DC 20402-0001 from Internet: http://bookstore.gpo.gov American National Standards Institute Telephone: 1-866-512-1800 11 West 42nd Street Fax: (202) 512-2104 New York, NY 10036-8002 http://www.ansi.org

2. The National Technical Information Service (212) 642-4900 5301 Shawnee Road Alexandria, VA 22161-0002 http://www.ntis.gov Legally binding regulatory requirements are stated only in laws; NRC regulations; licenses, including technical 1-800-553-6847 or, locally, (703) 605-6000 specifications; or orders, not in NUREG-series publications. The views expressed in contractor-A single copy of each NRC draft report for comment is prepared publications in this series are not necessarily available free, to the extent of supply, upon written those of the NRC.

request as follows: The NUREG series comprises (1) technical and U.S. Nuclear Regulatory Commission administrative reports and books prepared by the staff Office of Administration (NUREG-XXXX) or agency contractors Multimedia, Graphics and Storage & Distribution Branch (NUREG/CR-XXXX), (2) proceedings of conferences Washington, DC 20555-0001 (NUREG/CP-XXXX), (3) reports resulting from E-mail: distribution.resource@nrc.gov international agreements (NUREG/IA-XXXX), (4) Facsimile: (301) 415-2289 brochures (NUREG/BR-XXXX), and (5) compilations of legal decisions and orders of the Commission and Atomic and Safety Licensing Boards and of Directors Some publications in the NUREG series that are decisions under Section 2.206 of NRCs regulations posted at the NRCs Web site address (NUREG-0750). http://www.nrc.gov/reading-rm/doc-collections/nuregs are updated periodically and may differ from the last DISCLAIMER: This report was prepared as an account of printed version. Although references to material work sponsored by an agency of the U.S. Government. found on a Web site bear the date the material was Neither the U.S. Government nor any agency thereof, nor accessed, the material available on the date cited any employee, makes any warranty, expressed or may subsequently be removed from the site. implied, or assumes any legal liability or responsibility for any third partys use, or the results of such use, of any information, apparatus, product, or process disclosed in this publication, or represents that its use by such third party would not infringe privately owned rights. SR-CR 10/2017

NUREG-1437 Supplement 5, Second Renewal Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 5, Second Renewal Regarding Subsequent License Renewal for Turkey Point Nuclear Generating Unit Nos. 3 and 4 Draft Report for Comment Manuscript Completed: March 2019 Date Published: March 2019 Office of Nuclear Reactor Regulation

COMMENTS ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT Any interested party may submit comments on this draft supplemental environmental impact statement for consideration by the NRC staff. Please specify NUREG-1437, Supplement 5, Second Renewal, draft, in the subject or title line for your comments. Send comments by the end of the comment period specified in the Federal Register notice announcing the availability of this draft supplemental environmental impact statement. You may submit comments electronically by searching for Docket ID NRC-2018-0101 at the Federal Rulemaking Web site, http://www.regulations.gov. Please include Docket ID NRC-2018-0101 in the subject line of your comments. You may also mail comments to the following address: Office of Administration TWFN-7-A60M ATTN: Program Management, Announcements and Editing Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 You may also email comments to: TurkeyPoint34SLREIS.Resource@nrc.gov The NRC cautions you not to include identifying or contact information that you do not want to be publicly disclosed in your comment submission. The NRC will post all comment submissions at http://www.regulations.gov as well as enter the comment submissions into the NRCs Agencywide Documents Access and Management System (ADAMS). The NRC does not routinely edit comment submissions to remove identifying or contact information. For any questions about the material in this draft supplemental environmental impact statement, please contact: David Drucker, Senior Project Manager, by phone at 301-415-6223 or by e-mail at david.drucker@nrc.gov.

1 COVER SHEET 2 Responsible Agency: U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor 3 Regulation. The U.S. National Park Service, Southeast Region, is a cooperating agency. 4 Title: Generic Environmental Impact Statement for License Renewal of Nuclear Plants, 5 Supplement 5, Second Renewal, Regarding Subsequent License Renewal for Turkey Point 6 Nuclear Generating Unit Nos. 3 and 4, Draft Report for Comment (NUREG-1437). 7 For additional information or copies of this document contact: 8 U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation 9 11555 Rockville Pike, Mail Stop O-11F1 10 Rockville, MD 20852 11 Email: david.drucker@nrc.gov 12 ABSTRACT 13 The U.S. Nuclear Regulatory Commission (NRC) staff prepared this draft supplemental 14 environmental impact statement (SEIS) as part of its environmental review of Florida Power & 15 Light Companys subsequent license renewal application, to renew the operating licenses for 16 Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point or Turkey Point Units 3 and 4) 17 for an additional 20 years. This draft SEIS includes the NRC staffs preliminary evaluation of the 18 environmental impacts of the subsequent license renewal as well as alternatives to subsequent 19 license renewal. Alternatives to subsequent license renewal considered in this draft SEIS 20 include: (1) a new nuclear power plant, (2) a new natural gas combined-cycle power plant, and 21 (3) the combination of a new natural gas combined-cycle power plant and new solar 22 photovoltaic power generation. In addition to replacement power alternatives, this draft SEIS 23 evaluates an alternative cooling water system to mitigate potential impacts associated with the 24 continued use of the existing cooling canal system. The NRC staffs preliminary 25 recommendation is that the adverse environmental impacts of subsequent license renewal for 26 Turkey Point are not so great that preserving the option of subsequent license renewal for 27 energy-planning decisionmakers would be unreasonable. The NRC staff based its 28 recommendation on the following: 29

• the analysis and findings in NUREG-1437, Generic Environmental Impact Statement 30 for License Renewal of Nuclear Plants 31
• the environmental report submitted by Florida Power & Light Company 32
• the NRC staffs consultation with Federal, State, Tribal, and local government agencies 33
• the NRC staffs independent environmental review 34
• the NRC staffs consideration of public comments 35 Comments on this draft SEIS should be filed no later than 45 days after the date on which the 36 U.S. Environmental Protection Agency (EPA) notice, stating that this draft SEIS has been filed 37 with the EPA, is published in the Federal Register. Comments received after the expiration of 38 the comment period will be considered if it is practical to do so, but assurance of consideration 39 of late comments cannot be given.

iii

1 TABLE OF CONTENTS 2 COVER SHEET .........................................................................................................................iii 3 ABSTRACT ...............................................................................................................................iii 4 TABLE OF CONTENTS .............................................................................................................v 5 LIST OF FIGURES ....................................................................................................................xi 6 LIST OF TABLES ....................................................................................................................xiii 7 EXECUTIVE

SUMMARY

..........................................................................................................xv 8 ABBREVIATIONS AND ACRONYMS .....................................................................................xxi 9 1 INTRODUCTION .................................................................................................................1-1 10    1.1 Proposed Federal Action ............................................................................................1-1 11    1.2 Purpose and Need for the Proposed Federal Action ..................................................1-1 12    1.3 Major Environmental Review Milestones ....................................................................1-2 13    1.4 Generic Environmental Impact Statement ..................................................................1-3 14    1.5 Supplemental Environmental Impact Statement .........................................................1-5 15    1.6 Decisions To Be Supported by the SEIS ....................................................................1-6 16    1.7 Cooperating Agencies ................................................................................................1-6 17    1.8 Consultations .............................................................................................................1-7 18    1.9 Correspondence.........................................................................................................1-7 19    1.10 Status of Compliance .................................................................................................1-8 20    1.11 Related State and Federal Activities...........................................................................1-8 21 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION .................................................2-1 22    2.1 Proposed Action .........................................................................................................2-1 23         2.1.1    Plant Operations during the Subsequent License Renewal Term .................2-2 24         2.1.2    Refurbishment and Other Activities Associated with Subsequent 25                  License Renewal ..........................................................................................2-2 26         2.1.3    Termination of Nuclear Power Plant Operations and Decommissioning 27                  after the Subsequent License Renewal Term ...............................................2-3 28    2.2 Alternatives ................................................................................................................2-3 29         2.2.1    No-Action Alternative ....................................................................................2-4 30         2.2.2    Replacement Power Alternatives..................................................................2-5 31         2.2.3    Cooling Water System Alternative ..............................................................2-12 32    2.3 Alternatives Considered but Eliminated ....................................................................2-13 33         2.3.1    Solar Power................................................................................................2-13 34         2.3.2    Wind Power ................................................................................................2-14 35         2.3.3    Biomass Power ..........................................................................................2-15 36         2.3.4    Demand-Side Management........................................................................2-15 37         2.3.5    Hydroelectric Power ...................................................................................2-16 38         2.3.6    Geothermal Power .....................................................................................2-16 39         2.3.7    Wave and Ocean Energy ...........................................................................2-17 40         2.3.8    Municipal Solid Waste ................................................................................2-17 v

1 2.3.9 Petroleum-Fired Power ..............................................................................2-18 2 2.3.10 Coal-Fired Power .......................................................................................2-18 3 2.3.11 Fuel Cells ...................................................................................................2-19 4 2.3.12 Purchased Power .......................................................................................2-19 5 2.3.13 Delayed Retirement....................................................................................2-20 6 2.4 Comparison of Alternatives ......................................................................................2-20 7 3 AFFECTED ENVIRONMENT ..............................................................................................3-1 8 3.1 Description of Nuclear Power Plant Facility and Operation .........................................3-1 9 3.1.1 External Appearance and Setting .................................................................3-1 10 3.1.2 Nuclear Reactor Systems .............................................................................3-4 11 3.1.3 Cooling and Auxiliary Water Systems ...........................................................3-4 12 3.1.4 Radioactive Waste Management Systems .................................................3-12 13 3.1.5 Nonradioactive Waste Management Systems ............................................3-19 14 3.1.6 Utility and Transportation Infrastructure ......................................................3-20 15 3.1.7 Nuclear Power Plant Operations and Maintenance ....................................3-22 16 3.2 Land Use and Visual Resources ..............................................................................3-23 17 3.2.1 Land Use ....................................................................................................3-23 18 3.2.2 Visual Resources .......................................................................................3-24 19 3.3 Meteorology, Air Quality, and Noise .........................................................................3-25 20 3.3.1 Meteorology and Climatology .....................................................................3-25 21 3.3.2 Air Quality ..................................................................................................3-25 22 3.3.3 Noise ..........................................................................................................3-28 23 3.4 Geologic Environment ..............................................................................................3-29 24 3.4.1 Physiography, Geology, and Soils ..............................................................3-29 25 3.4.2 Economic Resources .................................................................................3-29 26 3.4.3 Seismic Setting ..........................................................................................3-30 27 3.5 Water Resources .....................................................................................................3-31 28 3.5.1 Surface Water ............................................................................................3-32 29 3.5.2 Groundwater Resources.............................................................................3-53 30 3.6 Terrestrial Resources ...............................................................................................3-86 31 3.6.1 Vegetative Communities.............................................................................3-86 32 3.6.2 Wildlife .......................................................................................................3-89 33 3.6.3 Important Species and Habitats..................................................................3-90 34 3.6.4 Invasive and Non-Native Species ...............................................................3-94 35 3.7 Aquatic Resources ...................................................................................................3-94 36 3.7.1 South Florida Coastal Plain Ecoregion .......................................................3-94 37 3.7.2 Aquatic Resources near the Turkey Point Site ...........................................3-95 38 3.7.3 Aquatic Resources on the Turkey Point Site...............................................3-96 39 3.7.4 Biscayne Bay and Card Sound Semiannual Monitoring ............................3-102 40 3.7.5 Additional Information on Aquatic Resources ...........................................3-104 vi

1 3.8 Special Status Species and Habitats ......................................................................3-104 2 3.8.1 Species and Habitats Protected Under the Endangered Species Act .......3-104 3 3.8.2 Species and Habitats Protected under the Magnuson-Stevens Act .........3-112 4 3.9 Historic and Cultural Resources .............................................................................3-114 5 3.9.1 Cultural Background .................................................................................3-114 6 3.9.2 Historic and Cultural Resources at Turkey Point ......................................3-115 7 3.10 Socioeconomics .....................................................................................................3-116 8 3.10.1 Power Plant Employment .........................................................................3-117 9 3.10.2 Regional Economic Characteristics ..........................................................3-117 10 3.10.3 Demographic Characteristics ...................................................................3-119 11 3.10.4 Housing and Community Services ............................................................3-122 12 3.10.5 Tax Revenues ..........................................................................................3-124 13 3.10.6 Local Transportation.................................................................................3-126 14 3.11 Human Health ........................................................................................................3-127 15 3.11.1 Radiological Exposure and Risk ...............................................................3-127 16 3.11.2 Chemical Hazards ....................................................................................3-128 17 3.11.3 Microbiological Hazards ...........................................................................3-129 18 3.11.4 Electromagnetic Fields .............................................................................3-129 19 3.11.5 Other Hazards ..........................................................................................3-129 20 3.12 Environmental Justice ............................................................................................3-130 21 3.13 Waste Management and Pollution Prevention ........................................................3-135 22 3.13.1 Radioactive Waste ...................................................................................3-135 23 3.13.2 Nonradioactive Waste ..............................................................................3-135 24 4 ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS ...............................4-1 25 4.1 Introduction ................................................................................................................4-1 26 4.2 Land Use and Visual Resources ................................................................................4-7 27 4.2.1 Proposed Action ...........................................................................................4-7 28 4.2.2 No-Action Alternative ....................................................................................4-7 29 4.2.3 Replacement Power Alternatives: Common Impacts ....................................4-8 30 4.2.4 New Nuclear Alternative ...............................................................................4-9 31 4.2.5 Natural Gas Combined-Cycle Alternative .....................................................4-9 32 4.2.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 33 Photovoltaic Generation) ............................................................................4-10 34 4.2.7 Cooling Water System Alternative ..............................................................4-11 35 4.3 Air Quality and Noise ...............................................................................................4-11 36 4.3.1 Proposed Action .........................................................................................4-12 37 4.3.2 No-Action Alternative ..................................................................................4-12 38 4.3.3 Replacement Power Alternatives: Common Impacts ..................................4-13 39 4.3.4 New Nuclear Alternative .............................................................................4-14 40 4.3.5 Natural Gas Combined-Cycle Alternative ...................................................4-15 vii

1 4.3.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 2 Photovoltaic Generation) ............................................................................4-17 3 4.3.7 Cooling Water System Alternative ..............................................................4-18 4 4.4 Geologic Environment ..............................................................................................4-19 5 4.4.1 Proposed Action .........................................................................................4-19 6 4.4.2 No-Action Alternative ..................................................................................4-20 7 4.4.3 Replacement Power Alternatives: Common Impacts ..................................4-20 8 4.4.4 New Nuclear Alternative .............................................................................4-20 9 4.4.5 Natural Gas Combined-Cycle Alternative ...................................................4-20 10 4.4.6 Combination Natural Gas Combined-Cycle and Solar Photovoltaic 11 Alternative ..................................................................................................4-20 12 4.4.7 Cooling Water System Alternative ..............................................................4-21 13 4.5 Water Resources .....................................................................................................4-21 14 4.5.1 Proposed Action .........................................................................................4-21 15 4.5.2 No-Action Alternative ..................................................................................4-35 16 4.5.3 Replacement Power Alternatives: Common Impacts ..................................4-36 17 4.5.4 New Nuclear Alternative .............................................................................4-39 18 4.5.5 Natural Gas Combined-Cycle Alternative ...................................................4-39 19 4.5.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 20 Photovoltaic Generation) ............................................................................4-40 21 4.5.7 Cooling Water System Alternative ..............................................................4-41 22 4.6 Terrestrial Resources ...............................................................................................4-42 23 4.6.1 Proposed Action .........................................................................................4-42 24 4.6.2 No-Action Alternative ..................................................................................4-46 25 4.6.3 Replacement Power Alternatives: Common Impacts ..................................4-47 26 4.6.4 New Nuclear Alternative .............................................................................4-47 27 4.6.5 Natural Gas Combined-Cycle Alternative ...................................................4-48 28 4.6.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 29 Photovoltaic Generation) ............................................................................4-48 30 4.6.7 Cooling Water System Alternative ..............................................................4-48 31 4.7 Aquatic Resources ...................................................................................................4-49 32 4.7.1 Proposed Action .........................................................................................4-49 33 4.7.2 No-Action Alternative ..................................................................................4-57 34 4.7.3 Replacement Power Alternatives: Common Impacts ..................................4-57 35 4.7.4 New Nuclear Alternative .............................................................................4-58 36 4.7.5 Natural Gas Combined-Cycle Alternative ...................................................4-59 37 4.7.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 38 Photovoltaic Generation) ............................................................................4-59 39 4.7.7 Cooling Water System Alternative ..............................................................4-59 40 4.8 Special Status Species and Habitats ........................................................................4-60 41 4.8.1 Proposed Action .........................................................................................4-60 42 4.8.2 No-Action Alternative ..................................................................................4-68 viii

1 4.8.3 Replacement Power Alternatives: Common Impacts ..................................4-69 2 4.9 Historic and Cultural Resources ...............................................................................4-71 3 4.9.1 Proposed Action .........................................................................................4-71 4 4.9.2 No-Action Alternative ..................................................................................4-73 5 4.9.3 Replacement Power Alternatives: Common Impacts ..................................4-73 6 4.9.4 Cooling Water System Alternative ..............................................................4-76 7 4.10 Socioeconomics .......................................................................................................4-76 8 4.10.1 Proposed Action .........................................................................................4-76 9 4.10.2 No-Action Alternative ..................................................................................4-77 10 4.10.3 Replacement Power Alternatives: Common Impacts ..................................4-78 11 4.10.4 New Nuclear Alternative .............................................................................4-79 12 4.10.5 Natural Gas Combined-Cycle Alternative ...................................................4-80 13 4.10.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 14 Photovoltaic Generation) ............................................................................4-81 15 4.10.7 Cooling Water System Alternative ..............................................................4-82 16 4.11 Human Health ..........................................................................................................4-84 17 4.11.1 Proposed Action .........................................................................................4-84 18 4.11.2 No-Action Alternative ..................................................................................4-86 19 4.11.3 Replacement Power Alternatives: Common Impacts ..................................4-86 20 4.11.4 New Nuclear Alternative .............................................................................4-87 21 4.11.5 Natural Gas Combined-Cycle Alternative ...................................................4-87 22 4.11.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 23 Photovoltaic Generation) ............................................................................4-87 24 4.11.7 Cooling Water System Alternative ..............................................................4-88 25 4.12 Environmental Justice ..............................................................................................4-88 26 4.12.1 Proposed Action .........................................................................................4-89 27 4.12.2 No-Action Alternative ..................................................................................4-91 28 4.12.3 Replacement Power Alternatives: Common Impacts ..................................4-91 29 4.12.4 Cooling Water System Alternative ..............................................................4-94 30 4.13 Waste Management .................................................................................................4-95 31 4.13.1 Proposed Action .........................................................................................4-95 32 4.13.2 No-Action Alternative ..................................................................................4-95 33 4.13.3 Replacement Power Alternatives: Common Impacts ..................................4-95 34 4.13.4 New Nuclear Alternative .............................................................................4-95 35 4.13.5 Natural Gas Combined-Cycle Alternative ...................................................4-96 36 4.13.6 Combination Alternative (Natural Gas Combined-Cycle and Solar 37 Photovoltaic Generation) ............................................................................4-96 38 4.13.7 Cooling Water System Alternative ..............................................................4-97 39 4.14 Evaluation of New and Significant Information .........................................................4-97 40 4.15 Impacts Common to All Alternatives .........................................................................4-99 41 4.15.1 Fuel Cycle ..................................................................................................4-99 42 4.15.2 Terminating Power Plant Operations and Decommissioning ....................4-100 ix

1 4.15.3 Greenhouse Gas Emissions and Climate Change ....................................4-102 2 4.16 Cumulative Impacts................................................................................................4-111 3 4.16.1 Air Quality ................................................................................................4-113 4 4.16.2 Water Resources......................................................................................4-114 5 4.16.3 Terrestrial Resources ...............................................................................4-118 6 4.16.4 Aquatic Resources ...................................................................................4-119 7 4.16.5 Socioeconomics .......................................................................................4-122 8 4.16.6 Historic and Cultural Resources ...............................................................4-123 9 4.16.7 Human Health ..........................................................................................4-124 10 4.16.8 Environmental Justice ..............................................................................4-125 11 4.16.9 Waste Management and Pollution Prevention ..........................................4-126 12 4.16.10 Global Greenhouse Gas Emissions ..........................................................4-127 13 4.17 Resource Commitments Associated with the Proposed Action...............................4-129 14 4.17.1 Unavoidable Adverse Environmental Impacts ..........................................4-129 15 4.17.2 Relationship between Short-Term Use of the Environment and 16 Long-Term Productivity ............................................................................4-129 17 4.17.3 Irreversible and Irretrievable Commitment of Resources ..........................4-130 18 5 CONCLUSION ....................................................................................................................5-1 19 5.1 Environmental Impacts of Subsequent License Renewal ...........................................5-1 20 5.2 Comparison of Alternatives ........................................................................................5-1 21 5.3 Preliminary Recommendation ....................................................................................5-2 22 6 REFERENCES ....................................................................................................................6-1 23 7 LIST OF PREPARERS .......................................................................................................7-1 24 8 LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF 25 THIS SEIS ARE SENT ........................................................................................................8-1 26 9 INDEX .................................................................................................................................9-1 27 COMMENTS RECEIVED ON THE TURKEY POINT NUCLEAR 28 GENERATING UNITS 3 AND 4 ENVIRONMENTAL REVIEW ....................... A-1 29 APPLICABLE LAWS, REGULATIONS, AND OTHER REQUIREMENTS ..... B-1 30 CONSULTATION CORRESPONDENCE ....................................................... C-1 31 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE ..... D-1 32 ENVIRONMENTAL IMPACTS OF POSTULATED ACCIDENTS ................... E-1 x

1 LIST OF FIGURES 2 Figure 1-1 Environmental Review Process.........................................................................1-3 3 Figure 1-2 Environmental Issues Evaluated for License Renewal ......................................1-5 4 Figure 3-1 Map Showing the 50-mi (80-km) Radius Around the Turkey Point Site .............3-3 5 Figure 3-2 Generic Cooling System with Cooling Canal System ........................................3-5 6 Figure 3-3 Flow of Water Through the Cooling Canal System ............................................3-7 7 Figure 3-4 Cooling Canal System and Adjacent Canals ...................................................3-10 8 Figure 3-5 Turkey Point In-Scope Transmission Lines (FPL 2018f)..................................3-22 9 Figure 3-6 Geologic Stratigraphy and Major Aquifers Beneath the Turkey Point Site .......3-31 10 Figure 3-7 Turkey Point Site, Biscayne Bay, Card Sound, and Regional Canals ..............3-33 11 Figure 3-8 FEMA Flood Zones Map of the Turkey Point Property ....................................3-38 12 Figure 3-9 Florida Department of Environmental Protection NPDES Permitted Outfalls ...3-40 13 Figure 3-10 Locations of Surface Water Monitoring Stations ..............................................3-43 14 Figure 3-11 Generalized Diagram of the Freshwater-Saltwater Interface in a Coastal 15 Water Table Aquifer ........................................................................................3-55 16 Figure 3-12 Groundwater Monitoring Locations and Saltwater Interface, Turkey Point 17 Site .................................................................................................................3-60 18 Figure 3-13 Extent of Tritium in the Deep Interval of the Biscayne Aquifer in the 19 Vicinity of the Turkey Point Site, 2017 .............................................................3-66 20 Figure 3-14 Layout of Biscayne Aquifer Recovery Well System and Testing Wells ............3-72 21 Figure 3-15 Turkey Point Groundwater Protection Initiative Monitoring Well Locations ......3-78 22 Figure 3-16 Location of Groundwater Production Wells on the Turkey Point Site ...............3-85 23 Figure 3-17 Average Height of Sawgrass Blades Within Freshwater Marsh Transects 24 from October 2011 through February 2017 .....................................................3-87 25 Figure 3-18 Live Sawgrass Biomass Within Freshwater Marsh Transects from 26 October 2011 through February 2017 .............................................................3-88 27 Figure 3-19 Live Biomass Within Two Red Mangrove Plots (M1-2 and M3-2) from 28 October 2011 through February 2017 .............................................................3-89 29 Figure 3-20 Turkey Point Site Fish Survey Sample Locations, June 2009 .........................3-98 30 Figure 3-21 Cooling Canal System Characterization Survey Sample Locations, 31 December 2016 ............................................................................................3-100 32 Figure 3-22 Biscayne Bay and Card Sound Semiannual Monitoring Ecological 33 Transection Locations ...................................................................................3-103 34 Figure 3-23 2010 CensusMinority Block Groups Within a 50-mi (80-km) Radius of 35 Turkey Point..................................................................................................3-133 36 Figure 3-24 2012-2016, American Community Survey 5-Year Estimates 37 Low-Income Block Groups Within a 50-mi (80-km) Radius of Turkey Point ...3-134 xi

xii 1 LIST OF TABLES 2 Table ES-1 Summary of NRC Conclusions Relating to Site-Specific Impacts of 3 Subsequent License Renewal at Turkey Point ................................................. xviii 4 Table 2-1 Summary and Key Characteristics of Replacement Power Alternatives 5 Considered In Depth .........................................................................................2-7 6 Table 2-2 Summary of Environmental Impacts of the Proposed Action and 7 Alternatives .....................................................................................................2-22 8 Table 3-1 Ambient Air Quality Standards ........................................................................3-26 9 Table 3-2 Permitted Air Emission Sources at Turkey Point Units 3 and 4 .......................3-27 10 Table 3-3 Estimated Air Pollutant Emissions from Turkey Point Units 3 and 4 ................3-28 11 Table 3-4 Summary of Groundwater Monitoring Results for Selected Biscayne 12 Aquifer Wells (Shallow and Deep Intervals), Turkey Point Uprate 13 Monitoring Program ........................................................................................3-63 14 Table 3-5 Representative Groundwater and Storm Drain Monitoring Results for 15 Tritium, Turkey Point Groundwater Protection Program, 2017 (in 16 PicoCuries per Liter) .......................................................................................3-76 17 Table 3-6 Groundwater Withdrawals at the Turkey Point Site .........................................3-81 18 Table 3-7 Migratory Birds Protected under the Migratory Bird Treaty Act That Are 19 Most Likely to Occur at Turkey Point ...............................................................3-92 20 Table 3-8 Aquatic Species Reported from the Cooling Canal System, November 21 2007................................................................................................................3-96 22 Table 3-9 Number and Relative Abundance of Fish Captured at Seven Locations on 23 the Turkey Point Site, June 2009 ....................................................................3-99 24 Table 3-10 Federally Listed Species under U.S. Fish and Wildlife Service Jurisdiction ...3-106 25 Table 3-11 Federally Listed Endangered or Threatened Species Under National 26 Marine Fisheries Service Jurisdiction in Biscayne Bay ..................................3-111 27 Table 3-12 Designated Essential Fish Habitat near the Turkey Point Site .......................3-113 28 Table 3-13 Residence of Permanent Turkey Point Employees by County.......................3-117 29 Table 3-14 Employment by Industry in Miami-Dade County (2016 Estimates) ................3-118 30 Table 3-15 Estimated Income Information for Miami-Dade County and Florida 31 (2016 Estimate) ............................................................................................3-118 32 Table 3-16 Population and Percent Growth in Miami-Dade County 1990-2060 ..............3-119 33 Table 3-17 Demographic Profile of the Population in Miami-Dade County in 2010..........3-120 34 Table 3-18 Demographic Profile of the Population in Miami-Dade County, 2016 35 Estimates ......................................................................................................3-120 36 Table 3-19 2016 Estimated Seasonal Housing in Counties Located Within 50 mi 37 (80 km) of Turkey Point .................................................................................3-121 38 Table 3-20 2012 Migrant Farm Workers and Temporary Farm Labor in Counties 39 Located within 50 mi of Turkey Point.............................................................3-122 xiii

1 Table 3-21 Housing in Miami-Dade County (2016) .........................................................3-123 2 Table 3-22 Major Public Water Suppliers in Miami-Dade County ....................................3-124 3 Table 3-23 Miami-Dade County Total Operating Revenues, Miami-Dade County 4 School Board Revenues, and Florida Power & Light Turkey Point 5 Property Tax Payments (2012-2017)............................................................3-125 6 Table 3-24 2017 Annual Average Daily Traffic in the Vicinity of Turkey Point .................3-126 7 Table 4-1 Applicable Category 1 (Generic) Issues for Turkey Point ..................................4-2 8 Table 4-2 Applicable Category 2 (Site-Specific) Issues for Turkey Point ...........................4-5 9 Table 4-3 Average Maximum Daily Temperature at CCS Outfall 001..............................4-55 10 Table 4-4 Effect Determinations for Federally Listed Species Under U.S. Fish and 11 Wildlife Service Jurisdiction .............................................................................4-60 12 Table 4-5 Effect Determinations for Federally Listed Species Under National Marine 13 Fisheries Service Jurisdiction ..........................................................................4-63 14 Table 4-6 Estimated Greenhouse Gas Emissions(a) from Operation at Turkey Point, 15 Units 3 and 4.................................................................................................4-103 16 Table 4-7 Direct Greenhouse Gas Emissions from Facility Operations Under the 17 Proposed Action and Alternatives .................................................................4-104 18 Table 4-8 Comparison of Greenhouse Gas Emission Inventories .................................4-128 19 Table 7-1 List of Preparers ...............................................................................................7-1 20 Table 8-1 List of Agencies, Organizations, and Persons to Whom Copies of this 21 SEIS Are Sent...................................................................................................8-1 22 Table B-1 Federal and State Requirements ..................................................................... B-2 23 Table B-2 Federal, State, and Local Permits and Other Requirements ............................ B-7 24 Table C-1 National Historic Preservation Act Correspondence ......................................... C-4 25 Table D-1 Environmental Review Correspondence .......................................................... D-1 xiv

1 EXECUTIVE

SUMMARY

2 Background

3 By letter dated January 30, 2018, Florida Power & Light Company (FPL) submitted to the 4 U.S. Nuclear Regulatory Commission (NRC) an application requesting subsequent license 5 renewal for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 renewed facility operating 6 licenses (Agencywide Documents Access and Management System (ADAMS) Package 7 Accession No. ML18037A812). FPL subsequently supplemented its application by letters dated 8 February 9, 2018 (ADAMS Accession No. ML18044A653), February 16, 2018 (ADAMS 9 Package Accession No. ML18053A123), March 1, 2018 (ADAMS Package Accession 10 No. ML18072A224), and April 10, 2018 (ADAMS Package Accession No. ML18113A132). The 11 Turkey Point Unit No. 3 current renewed facility operating license (DPR-31) expires at midnight 12 on July 19, 2032; the Turkey Point Unit No. 4 current renewed facility operating license 13 (DPR-41) expires at midnight on April 10, 2033. In its application, FPL requested license 14 renewal for a period of 20 years beyond the dates when the current renewed facility operating 15 licenses expire, to July 19, 2052 for Turkey Point Unit No. 3 and April 10, 2053 for Turkey Point 16 Unit No. 4. 17 Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 51.20(b)(2), the renewal of a 18 power reactor operating license requires preparation of an environmental impact 19 statement (EIS) or a supplement to an existing EIS. In addition, 10 CFR 51.95(c), Operating 20 License Renewal Stage, states that, in connection with the renewal of an operating license, the 21 NRC shall prepare an EIS, which is a supplement to the Commissions NUREG-1437, Generic 22 Environmental Impact Statement for License Renewal of Nuclear Plants. 23 Once the NRC officially accepted FPLs application, the NRC staff began the environmental 24 review process as described in 10 CFR Part 51, Environmental Protection Regulations for 25 Domestic Licensing and Related Regulatory Functions. The environmental review begins by 26 the NRC publishing a notice of intent in the Federal Register to prepare a supplemental 27 environmental impact statement (SEIS) and to conduct environmental scoping. To prepare the 28 Turkey Point SEIS, the NRC staff performed the following: 29

• conducted two public scoping meetings on May 31, 2018, near the Turkey Point site in 30 Homestead, FL 31
• conducted a severe accident mitigation alternatives in-office audit in Rockville, MD, from 32 July 5 to July 13, 2018, and an onsite environmental audit at Turkey Point from 33 June 19 to July 22, 2018 34
• reviewed FPLs environmental report (ER) and compared it to NUREG-1437, Generic 35 Environmental Impact Statement for License Renewal of Nuclear Plants (the GEIS) 36
• consulted with Federal, State, Tribal, and local government agencies 37
• conducted a review of the issues following the guidance set forth in 38 NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental 39 Reviews for Nuclear Power Plants, Supplement 1: Operating License Renewal, Final 40 Report 41
• considered public comments received xv

1 Proposed Action 2 FPL initiated the proposed Federal action (i.e., issuance of renewed facility operating licenses) 3 by submitting an application for subsequent license renewal of Turkey Point. The existing 4 Turkey Point renewed facility operating licenses expire at midnight on July 19, 2032, for 5 Unit No. 3 (DPR-31) and April 10, 2033, for Unit No. 4 (DPR-41). The NRCs Federal action is 6 to decide whether to issue renewed licenses authorizing an additional 20 years of operation. If 7 the NRC issues the renewed licenses, Turkey Point Unit Nos. 3 and 4 would be authorized to 8 operate until July 19, 2052 and April 10, 2053, respectively. The regulation at 10 CFR 2.109, 9 Effect of Timely Renewal Application, states that if a licensee of a nuclear power plant files an 10 application for renewal of an operating license at least 5 years before the expiration of the 11 existing license, the existing license will not be deemed to have expired until the NRC staff 12 completes its safety and environmental reviews of the application, and the NRC makes a final 13 decision on whether to issue a renewed license for the additional 20 years. 14 Purpose and Need for Proposed Action 15 The purpose and need for the proposed action (i.e., issuance of renewed licenses) is to provide 16 an option that allows for power generation capability beyond the term of the current nuclear 17 power plant operating licenses to meet future system generating needs. Energy-planning 18 decisionmakers such as States, utility operators, and, where authorized, Federal agencies 19 (other than the NRC) may determine these future system generating needs. The Atomic Energy 20 Act of 1954, as amended, and the National Environmental Policy Act of 1969, as amended, 21 require the NRC to perform a safety review and an environmental review of the proposed action. 22 The above definition of purpose and need reflects the NRCs recognition that, unless there are 23 findings in the safety review or in the environmental review that would lead the NRC to reject a 24 license renewal application, the NRC does not have a role in the energy-planning decisions as 25 to whether a particular nuclear power plant should continue to operate. 26 Environmental Impacts of License Renewal 27 This SEIS evaluates the potential environmental impacts of the proposed action. The NRC 28 designates the environmental impacts from the proposed action as SMALL, MODERATE, or 29 LARGE. NUREG-1437, Generic Environmental Impact Statement for License Renewal of 30 Nuclear Plants (the GEIS), evaluates 78 environmental issues related to plant operation and 31 classifies each issue as either a Category 1 issue (generic to all or a distinct subset of nuclear xvi

1 power plants) or a Category 2 issue (specific to individual power plants). Category 1 issues are 2 those that meet all the following criteria: 3

• The environmental impacts associated with the issue SMALL: Environmental effects 4 apply either to all plants or, for some issues, to plants are not detectable or are so 5 having a specific type of cooling system or other specified minor that they will neither 6 plant or site characteristics. destabilize nor noticeably alter any important attribute of the 7
• A single significance level (i.e., SMALL, MODERATE, or resource.

MODERATE: Environmental 8 LARGE) has been assigned to the impacts except for effects are sufficient to alter 9 collective offsite radiological impacts from the fuel cycle noticeably, but not to destabilize, 10 and from high-level waste and spent fuel disposal. important attributes of the resource. 11

• Mitigation of adverse impacts associated with the issue is LARGE: Environmental effects 12 considered in the analysis, and it has been determined are clearly noticeable and are 13 that additional plant-specific mitigation measures are sufficient to destabilize important attributes of the resource.

14 likely not to be sufficiently beneficial to warrant 15 implementation. 16 For Category 1 issues, no additional site-specific analysis is required in this SEIS unless new 17 and significant information is identified. For most issues, the NRC staff did not identify any new 18 and significant information during its review of Florida Power & Light Companys (FPLs) 19 environmental report, the site audits, or the scoping period that would change the conclusions in 20 the GEIS. Therefore, there are no impacts related to these Category 1 issues beyond those 21 already discussed in the GEIS. 22 Category 2 issues are site-specific issues that do not meet one or more of the criteria for 23 Category 1 issues; therefore, a SEIS must include additional site-specific review for these 24 non-generic issues. In this SEIS, the NRC staff evaluated Category 2 issues applicable to 25 Turkey Point, as well as cumulative impacts and considered new information regarding severe 26 accident mitigation alternatives (SAMAs). 27 The NRC staff identified and evaluated new and potentially significant information for two 28 existing Category 1 issues (i.e., groundwater quality degradation (plants with cooling ponds in 29 salt marshes) and cooling system impacts on terrestrial resources (plants with once-through 30 cooling systems or cooling ponds)). In addition, the NRC staff identified and evaluated one new 31 issue not categorized as Category 1 or 2 (i.e., water quality impacts on adjacent water bodies 32 (plants with cooling ponds in salt marshes)). As described in Chapter 4 of this SEIS, the 33 impacts of each of these issues is SMALL. Chapter 4 also presents the process for identifying 34 new and significant information. 35 Table ES-1 summarizes the Category 2 issues relevant to Turkey Point and the NRC staffs 36 findings related to those issues. If the NRC staff determined that there were no Category 2 37 issues applicable for a particular resource area, the findings of the GEIS, as documented in 38 Appendix B to Subpart A, Environmental Effect of Renewing the Operating License of a 39 Nuclear Power Plant, of 10 CFR Part 51, are incorporated for that resource area. xvii

1 Table ES-1 Summary of NRC Conclusions Relating to Site-Specific Impacts of 2 Subsequent License Renewal at Turkey Point Resource Area Relevant Category 2 Issues Impacts Groundwater Resources - Groundwater use conflicts (plants that SMALL to MODERATE withdraw more than 100 gallons per minute)

                                  - Radionuclides released to groundwater         SMALL Terrestrial Resources            - Effects on terrestrial resources (non-cooling SMALL system impacts)

Aquatic Resources - Impingement and entrainment of aquatic SMALL to MODERATE organisms (plants with once-through cooling systems or cooling ponds)

                                  - Thermal impacts on aquatic organisms          SMALL to MODERATE (plants with once-through cooling systems or cooling ponds)

Special Status Species and - Threatened, endangered, and protected Likely to adversely affect the Habitats species and essential fish habitat American crocodile and eastern indigo snake May affect, but is not likely to adversely affect or no effect to all other species May result in adverse modification to American crocodile critical habitat No adverse modification to West Indian manatee critical habitat No adverse effects on Essential Fish Habitat Historic and Cultural - Historic and cultural resources Would not adversely affect known Resources historic properties or historic and cultural resources Human Health - Electric shock hazards SMALL Environmental Justice - Minority and low-income populations No disproportionately high and adverse human health and environmental effects Cumulative Impacts - Cumulative Impacts See SEIS Section 4.16 3 Alternatives 4 As part of its environmental review, the NRC is required to consider alternatives to license 5 renewal and to evaluate the environmental impacts associated with each alternative. These 6 alternatives can include other methods of power generation (replacement power alternatives), 7 as well as not renewing the Turkey Point operating licenses (the no-action alternative). 8 In total, the NRC staff initially considered 16 replacement power alternatives; the NRC staff later 9 dismissed 13 of these because of technical, resource availability, or commercial limitations that xviii

1 currently exist and that the NRC staff believes are likely to still exist when the current Turkey 2 Point licenses expire. 3 This left three feasible and commercially viable replacement power alternatives which, in 4 addition to the no-action alternative, the staff evaluates in depth in this report: 5

• new nuclear power 6
• natural gas combined-cycle 7
• combination alternative: natural gas combined-cycle and solar photovoltaic (PV) 8 These are the 13 additional alternatives that the NRC staff considered but ultimately dismissed:

9

• solar power 10
• wind power 11
• biomass power 12
• demand-side management 13
• hydroelectric power 14
• geothermal power 15
• wave and ocean energy 16
• municipal solid waste 17
• petroleum-fired power 18
• coal (integrated gasification combined-cycle) 19
• fuel cells 20
• purchased power 21
• delayed retirement of nearby generating facilities 22 The NRC staff evaluated the environmental impacts of each replacement power alternative, 23 using the same resource areas that it used in evaluating the impacts from subsequent license 24 renewal. In addition, this SEIS evaluates the environmental impacts of an alternative 25 closed-cycle cooling water system, which might be used to mitigate potential impacts associated 26 with the continued use of the existing cooling canal system. Finally, this SEIS evaluates any 27 new and significant information that could alter the conclusions of the SAMA analysis that was 28 performed previously, in connection with the initial license renewal of Turkey Point 29 Unit Nos. 3 and 4.

30 Preliminary Recommendation 31 The NRC staffs preliminary recommendation is that the adverse environmental impacts of 32 subsequent license renewal for Turkey Point are not so great that preserving the option of 33 license renewal for energy-planning decisionmakers would be unreasonable. The NRC staff 34 based its recommendation on the following: 35

• the analysis and findings in NUREG-1437, Generic Environmental Impact Statement 36 for License Renewal of Nuclear Plants 37
• the environmental report submitted by FPL 38
• the NRC staffs consultation with Federal, State, Tribal, and local government agencies 39
• the NRC staffs independent environmental review 40
• the NRC staffs consideration of public comments xix

1 ABBREVIATIONS AND ACRONYMS

 °C         degree(s) Celsius
 °F         degree(s) Fahrenheit
 µg/m3      micrograms per cubic meter AADT       average annual daily traffic ac         acre(s)

ACHP Advisory Council on Historic Preservation ACR Atlantic Coastal Ridge ADAMS Agencywide Documents Access and Management System AEA Atomic Energy Act of 1954 (as amended) ALARA as low as reasonable achievable APE Area of Potential Affects AQCR Air Quality Control Region ARB Homestead Air Reserve Base ASLB Atomic Safety and Licensing Board BLM Bureau of Land Management bls below land surface BMPs best management practices CAA Clean Air Act CCS cooling canal system CCW component cooling water CDMP Comprehensive Master Development Plan CEQ Council on Environmental Quality CERP Comprehensive Everglades Restoration Plan CFR Code of Federal Regulations cfs cubic foot (feet) per second CH4 methane CO carbon monoxide CO2 carbon dioxide CO2/MWh carbon dioxide per megawatt hour CO2eq carbon dioxide equivalents COL combined license CVCS chemical and volume control system CWA Clean Water Act CZMA Coastal Zone Management Act dBA A-weighted decibels xxi

DERM Miami-Dade County Division of Environmental Resource Management DOE U.S. Department of Energy DOH Florida Department of Health DPS distinct population segment EAI Ecological Associates, Inc. EB Encyclopedia Britannica ECFAS2 East Coast Floridan Aquifer System Model - Phase 2 ECOS Environmental Conservation Online System EFH essential fish habitat EIA Energy Information Administration EIS environmental impact statement ELF-EMF extremely low frequency-electromagnetic field EO Executive Order EPA U.S. Environmental Protection Agency ER Environmental Report ESA Endangered Species Act of 1973, as amended FAC Florida Administrative Code FDACS Florida Department of Agriculture and Consumer Services FDEP Florida Department of Environmental Protection FDOT Florida Department of Transportation FE federally listed as endangered FEIS final environmental impact statement FFWCC Florida Fish and Wildlife Conservation Commission FLDOE Florida Department of Education FPL Florida Power & Light fps feet per second FR Federal Register FRN Federal Register notice ft foot (feet) FT federally listed as threatened ft3 cubic foot (feet) FWS U.S. Fish and Wildlife Service g gram(s) gal gallon(s) GEIS generic environmental impact statement GHG Greenhouse Gases gpd gallon(s) per day gpm gallon(s) per minute GT gigatons GWP global warming potential xxii

H2O water vapor ha hectare(s) HAP Hazardous Air Pollutant HFC hydrofluorocarbons HIC high integrity container ICW intake cooling water IPaC Information for Planning and Conservation IPCC Intergovernmental Panel on Climate Change ISFSI independent spent fuel storage installation IWW industrial wastewater kg kilogram(s) km kilometer(s) kW kilowatt(s) kWe kilowatt(s) electric L/min liter(s) per minute lb pound(s) LLRW Low-level radioactive waste LLW low level waste Lpd liters per day LRA license renewal application m meter(s) m/s meter(s) per second m3/day cubic meters per day m3/s cubic meter(s) per second MBTA Migratory Bird Treaty Act MDC Miami-Dade County MDWSD Miami-Dade Water and Sewer Department mgd million gallons per day mgy million gallons per year mi mile(s) min minute(s) MMT million metric tons mph mile(s) per hour MSA Magnuson-Stevens Fishery Conservation and Management Act MSL mean sea level mSv millisievert MT metric ton(s) MW megawatt(s) MWe megawatt(s) electric MWh megawatt hour(s) xxiii

MWt megawatt(s) thermal N2O nitrous oxide NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act of 1969, as amended NESHAP National Emission Standards for Hazardous Air Pollutants NGCC natural gas combined-cycle NHPA National Historic Preservation Act of 1966, as amended NIEHS National Institute of Environmental Health Sciences NMFS National Marine Fisheries Service (of the National Oceanic and Atmospheric Administration) NO2 nitrogen dioxide NOV notice of violation NOx nitrogen oxide(s) NPDES National Pollutant Discharge Elimination System NPS National Park Service NRC U.S. Nuclear Regulatory Commission NRHP National Register of Historic Places O3 ozone ODCM offsite dose calculation manual OSHA Occupational Safety and Health Administration Pb lead PFC perfluorocarbons PM particulate matter PM10 particulate matter diameter between 2.5 and 10 micrometers PM2.5 particulate matter diameter of 2.5 micrometers or less ppb parts per billion ppm parts per million PPSA Power Plant Siting Act ppt parts per thousand PRA probabilistic risk assessment PSD Prevention of Significant Deterioration PSU Practical Salinity Unit PV photovoltaic PWR pressurized water reactor RCS reactor coolant system REMP radiological environmental monitoring program RICE reciprocating internal combustion engines ROI region of influence RWS recovery well system RWST refueling water storage tank xxiv

SAMA severe accident mitigation alternative SAT federally listed due to similarity of appearance to another listed species SDWA Safe Drinking Water Act SDWWTP Miami-Dade County South District Waste Water Treatment Plant SEIS supplemental environmental impact statement SER safety evaluation report SF6 sulfur hexafluoride SFRCCC Southeast Florida Regional Climate Change Compact SFWMD South Florida Water Management District SIP State implementation plan SLRA subsequent license renewal application SO2 sulfur dioxide SPCC Spill Prevention, Control, and Countermeasure SSC structure, system, and component Sv sievert TDS total dissolved solids Turkey Point Turkey Point Nuclear Generating Unit Nos. 3 and 4 U.S. United States UF University of Florida UFA Upper Floridan aquifer UFSAR updated final safety analysis report USCB U.S. Census Bureau USCG U.S. Coast Guard USDOT U.S. Department of Transportation USGCRP U.S. Global Change Research Program USGS U.S. Geological Survey VOC Volatile Organic Compounds WHT waste holdup tanks yd3 cubic yard(s) g microgram m micrometer xxv

1 1 INTRODUCTION 2 The U.S. Nuclear Regulatory Commissions (NRCs) environmental protection regulations in 3 Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental Protection 4 Regulations for Domestic Licensing and Related Regulatory Functions, implement the National 5 Environmental Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.). This Act is commonly 6 referred to as NEPA. The regulations at 10 CFR Part 51 require the NRC to prepare an 7 environmental impact statement (EIS) before making a decision on whether to issue an 8 operating license or a renewed operating license for a nuclear power plant. 9 The Atomic Energy Act of 1954, as amended (42 U.S.C. 2011 et seq.), specifies that licenses 10 for commercial power reactors can be granted for up to 40 years. The initial 40-year licensing 11 period was based on economic and antitrust considerations rather than on technical limitations 12 of the nuclear facility. NRC regulations permit these licenses to be renewed beyond the initial 13 40-year term for an additional period of time, limited to 20-year increments per renewal, based 14 on the results of an assessment to determine whether the nuclear facility can continue to 15 operate safely during the proposed period of extended operation. There are no limitations in the 16 AEA or NRC regulations restricting the number of times a license may be renewed. 17 The decision to seek a renewed license rests entirely with nuclear power facility owners and 18 typically is based on the facilitys economic viability and the investment necessary to continue to 19 meet NRC safety and environmental requirements. The NRC makes the decision to grant or 20 deny a renewed license based on whether the applicant has demonstrated reasonable 21 assurance that it can meet the environmental and safety requirements in the agencys 22 regulations during the period of extended operation. 23 1.1 Proposed Federal Action 24 Florida Power & Light Company (FPL) initiated the proposed Federal action by submitting an 25 application for subsequent license renewal for Turkey Point Nuclear Generating 26 Unit Nos. 3 and 4 (Turkey Point or Turkey Point Units 3 and 4). The current renewed licenses 27 expire at midnight on July 19, 2032, for Unit No. 3 (DPR-31) and at midnight on April 10, 2033, 28 for Unit No. 4 (DPR-41). The NRCs Federal action is to decide whether to issue renewed 29 licenses for an additional 20 years. 30 1.2 Purpose and Need for the Proposed Federal Action 31 The purpose and need for the proposed Federal action (issuance of subsequent renewed 32 licenses for Turkey Point Unit Nos. 3 and 4) is to provide an option that allows for power 33 generation capability beyond the term of the current renewed nuclear power plant operating 34 licenses to meet future system generating needs. Such needs may be determined by 35 energy-planning decisionmakers such as State regulators, utility owners, and Federal agencies 36 other than the NRC. This definition of purpose and need reflects the NRCs recognition that, 37 unless there are findings in the NRCs safety review (required by the Atomic Energy Act) or 38 findings in the NRCs environmental analysis (required by NEPA) that would lead the NRC to 39 reject a subsequent license renewal application, the NRC does not have a role in 40 energy-planning decisions as to whether a particular nuclear power plant should continue to 41 operate. 1-1

1 1.3 Major Environmental Review Milestones 2 FPL submitted an environmental report (ER) (FPL 2018f) as an appendix to its subsequent 3 license renewal application (SLRA) on January 30, 2018 (FPL 2018a). After reviewing the 4 SLRA and environmental report, as supplemented on February 9 (FPL 2018b), February 16 5 (FPL 2018c), March 1 (FPL 2018d), and April 10, 2018 (FPL 2018e), the NRC staff accepted 6 the application for a detailed technical review on April 26, 2018 (NRC 2018a). On May 2, 2018, 7 the NRC staff published a Federal Register notice of acceptability and opportunity for hearing 8 (Volume 83 of the Federal Register (FR), page 19304 (83 FR 19304)). On May 22, 2018, the 9 NRC published another notice in the Federal Register (83 FR 23726) informing members of the 10 public of the staffs intent to conduct an environmental scoping process, thereby beginning a 11 30-day scoping comment period. 12 The NRC staff held two public scoping meetings on May 31, 2018, near the Turkey Point site in 13 Homestead, FL. In January 2019, the NRC issued its Supplemental Environmental Impact 14 Statement Scoping Process Summary Report, Turkey Point Nuclear Generating Unit 15 Nos. 3 and 4, Miami-Dade County, Florida, which includes the comments received during the 16 scoping process and the NRC staffs responses to those comments (NRC 2019). 17 To independently verify information that FPL provided in its environmental report, the NRC staff 18 conducted an onsite audit at Turkey Point in June 2018, and an in-office severe accident 19 mitigation alternatives audit at NRC headquarters in July 2018. In a letter dated July 20, 2018, 20 the staff summarized the onsite audit and listed the attendees (NRC 2018c). In a letter dated 21 August 31, 2018, the staff summarized the in-office severe accident mitigation alternatives audit 22 and listed the attendees (NRC 2018d). During these audits, the NRC staff held meetings with 23 plant personnel, reviewed site-specific documentation, toured the facility, and held a 24 government-to-government meeting hosted by the U.S. National Park Service. 25 Upon completion of the scoping period and audits, and completion of its review of FPLs 26 environmental report and related documents, the NRC staff compiled its findings in this draft 27 supplemental environmental impact statement (SEIS). The NRC staff will make this draft SEIS 28 available for public comment for 45 days. Based on the information gathered during this public 29 comment period, the NRC staff will amend the draft SEIS findings, as necessary, and will then 30 publish the final SEIS. Figure 1-1 shows the major milestones of the environmental review 31 portion of the NRCs subsequent license renewal application review process. 1-2

1 Figure 1-1 Environmental Review Process 2 The NRC has established a license renewal process that can be completed in a reasonable 3 period of time and that includes clear requirements to assure safe plant operation for up to an 4 additional 20 years of plant life. This process consists of separate environmental and safety 5 reviews, which the NRC staff conducts simultaneously and documents in two reports: (1) the 6 SEIS documents the environmental review and (2) the safety evaluation report (SER) 7 documents the safety review. The staffs findings in the SEIS and the SER are both factors in 8 the NRCs decision to grant or deny the issuance of a renewed license. This process is used for 9 both initial and subsequent license renewal. 10 1.4 Generic Environmental Impact Statement 11 To improve the efficiency of its license renewal review process, the NRC staff performed a 12 generic assessment of the environmental impacts associated with license renewal. 13 NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear 14 Power Plants (known as the GEIS) (NRC 1996, NRC 1999, NRC 2013a), documents the 15 results of the NRCs systematic approach to evaluating the environmental consequences of 16 renewing the licenses of individual nuclear power plants and operating them for an additional 17 20 years. In the GEIS, the staff analyzed in detail and resolved those environmental issues that 18 could be resolved generically. The NRC issued the GEIS in 1996 (NRC 1996), Addendum 1 to 19 the GEIS in 1999 (NRC 1999), and Revision 1 to the GEIS in 2013 (NRC 2013a). Unless 20 otherwise noted, all references to the GEIS include the original 1996 GEIS, Addendum 1, and 21 the 2013 revision. The conclusions in the GEIS apply to both initial and subsequent license 22 renewal. 23 The GEIS establishes separate environmental impact issues for the NRC staff to independently 24 evaluate. Appendix B to Subpart A of 10 CFR Part 51, Environmental Effect of Renewing the 1-3

1 Operating License of a Nuclear Power Plant, provides a summary of the staffs findings in the 2 GEIS. For each environmental issue addressed in the GEIS, the NRC staff: 3

• describes the activity that affects the environment 4
• identifies the population or resource that is affected 5
• assesses the nature and magnitude of the impact on the affected population or resource 6
• characterizes the significance of the effect for both beneficial and adverse effects 7
• determines whether the results of the analysis apply to all plants 8
• considers whether additional mitigation measures would be warranted for impacts that 9 would have the same significance level for all plants 10 The NRC established its standard of significance for impacts using the Council on 11 Environmental Quality terminology for significant. The NRC established three levels of 12 significance for potential impactsSMALL, MODERATE, and LARGEas defined below.

13 SMALL: Environmental effects are not detectable or Significance indicates the importance 14 are so minor that they will neither destabilize nor of likely environmental impacts and is 15 noticeably alter any important attribute of the determined by considering two 16 resource. variables: context and intensity. 17 MODERATE: Environmental effects are sufficient to Context is the geographic, 18 alter noticeably, but not to destabilize, important biophysical, and social context in 19 attributes of the resource. which the effects will occur. Intensity refers to the severity of the 20 LARGE: Environmental effects are clearly impact in whatever context it occurs. 21 noticeable and are sufficient to destabilize important 22 attributes of the resource. 23 The GEIS includes a determination of whether the analysis of the environmental issue could be 24 applied to all plants (or a distinct subset of plants, as defined in the GEIS) and whether 25 additional mitigation measures would be warranted. Issues are assigned a Category 1 (generic 26 to all or a subset of plants) or Category 2 (site-specific) designation. As established in the 27 GEIS, Category 1 issues are those that meet the following three criteria: 28

• The environmental impacts associated with the issue have been determined to apply 29 either to all plants or, for some issues, to plants that have a specific type of cooling 30 system or other specified plant or site characteristics.

31

• A single significance level (i.e., SMALL, MODERATE, or LARGE) has been assigned to 32 the impacts (except for collective offsite radiological impacts from the fuel cycle and from 33 high-level waste and spent fuel disposal).

34

• Mitigation of adverse impacts associated with the issue has been considered in the 35 analysis, and it has been determined that additional plant-specific mitigation measures 36 are likely not to be sufficiently beneficial to warrant implementation.

37 For generic issues (Category 1), the SEIS requires no additional site-specific evaluation unless 38 new and significant information has been identified. Chapter 4 of this report describes the 1-4

1 process for identifying new and significant information for site-specific analysis. Site-specific 2 issues (Category 2) are those that do not meet the three criteria of Category 1 issues; therefore, 3 the SEIS requires additional site-specific review for these issues. 4 The 2013 GEIS evaluates 78 environmental issues, provides generically applicable findings for 5 numerous issues (subject to the consideration of any new and significant information on a 6 site-specific basis), and concludes that a site-specific analysis is required for 17 of the 7 78 issues. Figure 1-2 illustrates the license renewal environmental review process. The results 8 of that site-specific review are documented in the SEIS. 9 Figure 1-2 Environmental Issues Evaluated for License Renewal 10 1.5 Supplemental Environmental Impact Statement 11 This SEIS presents the NRC staffs analysis of the environmental effects of the continued 12 operation of Turkey Point through the subsequent license renewal period, alternatives to 13 subsequent license renewal, and mitigation measures for minimizing adverse environmental 14 impacts. Chapter 4, Environmental Consequences and Mitigating Actions, contains an 15 analysis and comparison of the potential environmental impacts from subsequent license 16 renewal and alternatives to subsequent license renewal. Chapter 5, Conclusion, presents the 17 NRCs recommendation on whether the environmental impacts of subsequent license renewal 18 are so great that preserving the option of subsequent license renewal would be unreasonable. 19 The NRC staff will make its final recommendation to the Commission on Turkey Point 1-5

1 subsequent license renewal in the final SEIS, which the NRC staff will issue after considering 2 comments received on the draft SEIS during the public comment period. 3 In the preparation of the Turkey Point draft SEIS, the NRC staff carried out the following 4 activities: 5

• reviewed the information provided in FPLs environmental report 6
• consulted with Federal, State, Tribal, and local government agencies 7
• conducted an independent environmental review, including the environmental and 8 severe accident mitigation analysis site audits 9
• considered public comments 10 New information can come from many sources, 11 including the applicant, the NRC, other agencies, New and significant information. To merit 12 or public comments. If the information reveals a additional review, information must be 13 new issue, the staff will first analyze the issue to both new and significant and it must bear 14 determine whether it is within the scope of the on the proposed action or its impacts.

15 license renewal environmental evaluation. If the 16 staff determines that the new issue bears on the 17 proposed action, the staff will then determine the significance of the issue for the plant and 18 analyze the issue in the SEIS, as appropriate. 19 1.6 Decisions To Be Supported by the SEIS 20 This SEIS supports the NRCs decision on whether to issue renewed operating licenses for 21 Turkey Point for an additional 20 years. The regulation at 10 CFR 51.103(a)(5) specifies the 22 NRCs decision standard as follows: 23 In making a final decision on a license renewal action pursuant to Part 54 of this 24 chapter [10 CFR], the Commission shall determine whether or not the adverse 25 environmental impacts of license renewal are so great that preserving the option 26 of license renewal for energy planning decisionmakers would be unreasonable. 27 There are many factors that the NRC takes into consideration when deciding whether to renew 28 the operating license of a nuclear power plant. The analyses of environmental impacts in this 29 SEIS will provide the NRCs decisionmaker (in this case, the Commission) with important 30 environmental information for use in the overall decisionmaking process. Other decisions are 31 made outside the regulatory scope of license renewal, by the NRC or other decisionmakers. 32 These include decisions related to: (1) changes to plant cooling systems, (2) disposition of spent 33 nuclear fuel, (3) emergency preparedness, (4) safeguards and security, (5) need for power, and 34 (6) seismicity and flooding (NRC 2013a). 35 1.7 Cooperating Agencies 36 The U.S. National Park Service, Southeast Region (NPS), is participating in the environmental 37 review of subsequent license renewal for Turkey Point as a cooperating agency. The NPS does 38 not have any specific regulatory actions related to the proposed subsequent license renewal; 39 however, NPS is providing special expertise for environmental issues pertaining to the areas in 40 and around Biscayne National Park, which is located next to the Turkey Point site. In a letter 1-6

1 dated March 5, 2019, the NPS provided comments to the NRC staff on preliminary sections of 2 the draft SEIS discussing water resources, terrestrial resources, aquatic resources, and special 3 status species and habitats (NPS 2019). 4 1.8 Consultations 5 The Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) (ESA); the 6 Magnuson-Stevens Fishery Conservation and Management Act of 1996, as amended 7 (16 U.S.C. 1801 et seq.) (MSA); and the National Historic Preservation Act of 1966, as 8 amended (54 U.S.C. 300101 et seq.) (NHPA), require Federal agencies to consult with 9 applicable State and Federal agencies and organizations before taking an action that may affect 10 endangered species, fisheries, or historic and archaeological resources, respectively. The NRC 11 staff consulted with the following agencies and organizations during this environmental review: 12

• U.S. Fish and Wildlife Service 13
• Miami-Dade County Office of Historic Preservation 14
• Miccosukee Tribe of Indians of Florida 15
• Muscogee (Creek) Nation 16
• Poarch Band of Creek Indians 17
• The Seminole Nation of Oklahoma 18
• Seminole Tribe of Florida 19
• Florida Department of State, Division of Historical Resources 20
• Federal Advisory Council on Historic Preservation 21 Appendix C, Consultation Correspondence, of this SEIS discusses the consultations that the 22 NRC staff conducted in support of this environmental review.

23 In addition, on June 18, 2018, the NRC staff participated in an interagency meeting related to 24 the proposed subsequent license renewal action. Participating Federal, State, and local 25 agencies included the National Park Service (NPS), U.S. Environmental Protection Agency 26 (EPA), U.S. Fish and Wildlife Service (FWS), National Oceanic and Atmospheric Administration 27 (NOAA), Florida Department of Environmental Protection (FDEP), and Miami-Dade County 28 Division of Environmental Resources Management (DERM). The primary goals of the meeting 29 included the following: 30

• Provide an overview of NRCs environmental review process related to FPLs application 31 to renew the operating licenses at Turkey Point.

32

• Gather input from other Federal, State, and local agencies regarding available 33 environmental data and issues.

34 During the meeting, the NRC staff provided an overview of the subsequent license renewal 35 process, several agencies presented environmental data and issues related to Turkey Point, 36 and lastly, participants held a general discussion related to the environmental review 37 (NRC 2018l). Information provided by the meeting participants has been considered by the 38 NRC staff in preparing this SEIS. 39 1.9 Correspondence 40 During the course of the environmental review, the NRC staff contacted Federal, State, regional, 41 local, and Tribal government agencies listed in Section 1.8 above. Appendix C, Consultation 1-7

1 Correspondence, chronologically lists all correspondence the NRC staff sent and received 2 during its environmental review, associated with the ESA, the MSA, and the NHPA. 3 Appendix D, Chronology of Environmental Review Correspondence, chronologically lists all 4 other correspondence. 5 1.10 Status of Compliance 6 FPL is responsible for complying with all NRC regulations and other applicable Federal, State, 7 and local requirements. Appendix F of the GEIS describes some of the major applicable 8 Federal statutes. Numerous permits and licenses are issued by Federal, State, and local 9 authorities for activities at Turkey Point. Appendix B of this SEIS contains further information 10 about FPLs status of compliance. 11 1.11 Related State and Federal Activities 12 The NRC reviewed the possibility that activities of other Federal agencies might affect the 13 renewal of the operating licenses for Turkey Point. There are no Federal projects that would 14 make it necessary for another Federal agency to become a cooperating agency in the 15 preparation of this SEIS. 16 Two Indian reservations, the Miccosukee Indian Reservation (approximately 47 miles (75 km) 17 northwest of Turkey Point) and the Seminole Tribe of Florida, Hollywood Reservation 18 (approximately 43 mi (68 km) north of Turkey Point), are located with 50 miles (80 km) of 19 Turkey Point. The area surrounding the Turkey Point site is low, swampy, and sparsely 20 populated. The Turkey Point site is adjacent to waters and coastal lands that are part of the 21 Biscayne National Park and is within 2 miles (3.2 km) of the Model Lands Basin, a South Florida 22 Water Management District conservation area. A portion of the Biscayne Bay Aquatic Preserve 23 is located immediately east of the Turkey Point site, and a separate portion of the preserve, 24 along with the Florida Keys National Marine Sanctuary, is located adjacent to the 25 south-southeastern border of the Turkey Point site boundary. The Turkey Point site is also 26 located just east of the 13,000-acre Everglades Mitigation Bank. The Homestead Bayfront Park, 27 a city park, is located approximately 2 miles (3.2 km) north-northwest of Turkey Point. 28 (FPL 2018f) 29 Section 102(2)(C) of NEPA requires the NRC to consult with and obtain the comments of any 30 Federal agency that has jurisdiction by law or special expertise with respect to any 31 environmental impact involved in the subject matter of the SEIS. In accordance with this 32 requirement, during the course of preparing the SEIS, the NRC consulted, for example, with the 33 U.S. Fish and Wildlife Service. Appendix C provides a complete list of consultation 34 correspondence. 1-8

1 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION 2 The U.S. Nuclear Regulatory Commissions (NRCs) decisionmaking authority for subsequent 3 license renewal focuses on deciding whether or not to issue a subsequent renewed operating 4 license to a nuclear power plant. The agencys implementation of the National Environmental 5 Policy Act of 1969, as amended (42 U.S.C. 4321 et seq.) (NEPA), requires the NRC to consider 6 potential alternatives to issuing a subsequent renewed operating license as well as the 7 environmental impacts of these alternatives. Considering the environmental impacts of 8 subsequent license renewal and comparing those impacts to the environmental impacts of 9 alternatives allows the NRC to determine whether the environmental impacts of subsequent 10 license renewal are so great that it would be unreasonable for the agency to preserve the option 11 of subsequent license renewal for energy-planning decisionmakers (Title 10 of the Code of 12 Federal Regulations (10 CFR) 51.95(c)(4)). Ultimately, decisionmakers such as the plant 13 operator, State, or non-NRC Federal officials will decide whether to carry out the proposed 14 action and continue operating the plant for an additional 20 years (if the NRC renews the 15 license) or shut down the plant and choose an alternative power generation source. Economic 16 and environmental considerations play important roles in the decisions of these non-NRC 17 energy-planning decisionmakers. 18 In general, the NRCs responsibility is to ensure the safe operation of nuclear power facilities, 19 not to formulate energy policy, promote nuclear power, or encourage or discourage the 20 development of alternative power generation sources. The NRC does not engage in 21 energy-planning decisions, and it makes no judgment as to which energy alternatives evaluated 22 in the SEIS would be the best or most-likely alternative to be selected in any given case. 23 This chapter provides (1) a description of the proposed action (i.e., subsequent renewal of the 24 operating licenses for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point, or 25 Turkey Point Units 3 and 4)), (2) an in-depth evaluation of reasonable alternatives to the 26 proposed action (including the no-action alternative), and (3) a brief description of the 27 alternatives to the proposed action that the NRC staff considered but ultimately eliminated from 28 in-depth evaluation. 29 2.1 Proposed Action 30 As stated in Section 1.1 of this document, the NRCs proposed Federal action is to decide 31 whether to renew the Turkey Point operating licenses for an additional 20 years. To evaluate 32 the environmental impacts from the continued operation of Turkey Point, the staff will begin with 33 an overview of the facility and the facilitys operations, and then consider the affected 34 environment and potential impacts to the affected environment. 35 Section 2.1.1 below provides a description of normal power plant operations during the 36 subsequent license renewal term. In brief, Turkey Point is a two-unit, nuclear-powered, 37 steam-electric generating facility that began commercial operation in December 1972 (Unit 3) 38 and September 1973 (Unit 4). The nuclear reactors are both Westinghouse pressurized-water 39 reactors (PWRs) and have a combined generating capacity of 1,632 megawatts electric (MWe). 40 Operating at an average capacity factor of 92 percent, the reactors provide approximately 41 1,500 MWe of net generation (FPL 2018f). 2-1

1 2.1.1 Plant Operations during the Subsequent License Renewal Term 2 Most plant operation activities during the subsequent license renewal term would be the same 3 as, or similar to, those occurring during the current renewed license term. NUREG-1437, 4 Volume 1, Revision 1, Generic Environmental Impact Statement for License Renewal of 5 Nuclear Plants, (NRC 2013a) (also known as the GEIS) describes the issues that would have 6 the same impact at all nuclear power plants (or a distinct subset of plants, as defined in the 7 GEIS) (i.e., generic issues) as well as those issues that may have different impact levels at 8 different nuclear power plants (i.e., site-specific issues). The impacts of generic issues are 9 described in NUREG-1437 as Category 1 issues; those impacts are set out in NUREG-1437 10 and Table B-1 of 10 CFR Part 51, Appendix B, and those determinations apply to each license 11 renewal application, subject to the consideration of any new and significant information on a 12 plant-specific basis. A second group of issues (Category 2) was identified in NUREG-1437 as 13 having potentially different impacts at each plant, on a site-specific basis; those issues with 14 plant-specific impact levels need to be discussed in a plant-specific supplemental environmental 15 impact statement (SEIS) to the GEIS, like this one. 16 Section 2.1.1 of the GEIS, Plant Operations during the License Renewal Term, describes the 17 general types of activities that are carried out during the operation of all nuclear power plants. 18 These general types of activities include the following: 19

• reactor operations 20
• waste management 21
• security 22
• office and clerical work 23
• laboratory analysis 24
• surveillance, monitoring, and maintenance refueling and other outages 25 As part of its subsequent license renewal application, Florida Power & Light Company (FPL) 26 submitted an environmental report. FPLs environment report states that Turkey Point will 27 continue to operate during the subsequent license renewal term in the same manner as it would 28 during the current license term with the exception of additional aging management programs to 29 address structure and component aging in accordance with 10 CFR Part 54, Requirements for 30 Renewal of Operating Licenses for Nuclear Power Plants.

31 2.1.2 Refurbishment and Other Activities Associated with Subsequent License Renewal 32 Refurbishment activities include replacement and repair of major structures, systems, and 33 components. The major refurbishment class of activities characterized in the GEIS is intended 34 to encompass actions that typically take place only once in the life of a nuclear plant, if at all 35 (NRC 2013a). For example, replacement of pressurized-water reactor steam generator 36 systems is a refurbishment activity. Refurbishment activities may have an impact on the 37 environment beyond those that occur during normal operations and may require evaluation, 38 depending on the type of action and the plant-specific design. 39 In preparation for its license renewal application, FPL evaluated major structures, systems, and 40 components in accordance with 10 CFR 54.21, Contents of applicationtechnical information, 41 to identify major refurbishment activities necessary for the continued operation of Turkey Point 42 during the proposed 20-year period of extended operation (FPL 2018a). 2-2

1 FPL did not identify any major refurbishment activities necessary for the continued operation of 2 Turkey Point beyond the end of the current renewed operating license term (FPL 2018f). 3 2.1.3 Termination of Nuclear Power Plant Operations and Decommissioning after the 4 Subsequent License Renewal Term 5 NUREG-0586, Supplement 1, Volumes 1 and 2, Final Generic Environmental Impact 6 Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of 7 Nuclear Power Reactors (NRC 2002a) (also known as the decommissioning GEIS), describes 8 the impacts of decommissioning. The majority of plant operations activities would cease with 9 permanent reactor shutdown. However, some activities (e.g., security and oversight of spent 10 nuclear fuel) would remain unchanged, whereas others (e.g., waste management, office and 11 clerical work, laboratory analysis, surveillance, monitoring, and maintenance) would continue at 12 reduced or altered levels. Systems dedicated to reactor operations would cease operations; 13 however, if these systems are not removed from the site after permanent reactor shutdown, 14 their physical presence may continue to impact the environment. Impacts associated with 15 dedicated systems that remain in place or with shared systems that continue to operate at 16 normal capacities could remain unchanged. 17 Decommissioning will occur whether Turkey Point is permanently shut down at the end of its 18 current renewed operating license term, or at the end of the subsequent period of extended 19 operation 20 years later. There are no site-specific issues related to decommissioning. The 20 license renewal GEIS concludes that license renewal would have a negligible (SMALL) effect on 21 the impacts of terminating operations and decommissioning on all resources (NRC 2013a). 22 2.2 Alternatives 23 As stated above, the National Environmental Policy Act of 1969, as amended (NEPA), requires 24 the NRC to consider reasonable alternatives to the proposed action of issuing subsequent 25 renewed operating licenses for Turkey Point. For a replacement power alternative to be 26 reasonable, it must be both (1) commercially viable on a utility scale and (2) operational before 27 the reactors operating license expires or expected to become commercially viable on a utility 28 scale and operational before the expiration of the reactors operating license (NRC 2013a). The 29 2013 GEIS incorporates the latest information on replacement power alternatives; however, 30 rapidly evolving technologies are likely to outpace the information in the GEIS. As such, for 31 each supplement to the GEIS, the NRC staff must perform a site-specific analysis of 32 replacement power alternatives that accounts for changes in technology and science since the 33 preparation of the most recent GEIS revision. 34 The first alternative to the proposed action of the NRC issuing subsequent renewed operating 35 licenses for Turkey Point is for the NRC to not issue the licenses. This is called the no-action 36 alternative. Section 2.2.1 below describes the no-action alternative. In addition to the no-action 37 alternative, this chapter discusses three reasonable replacement power alternatives. These 38 alternatives seek to replace Turkey Points generating capacity by meeting the regions energy 39 needs through other means or sources. Sections 2.2.2.1 through 2.2.2.3 describe replacement 40 power alternatives for Turkey Point. In addition, Section 2.2.3 describes a mechanical draft 41 cooling water system alternative, which the NRC staff evaluated as an alternative to Turkey 42 Points use of the existing cooling canal system (CCS) to provide cooling water for Turkey Point 43 Units 3 and 4. 2-3

1 2.2.1 No-Action Alternative Alternatives Evaluated in Depth:

• new nuclear 2 At some point, all operating nuclear power 3 plants will permanently cease operations and
• natural gas combined-cycle (NGCC) 4 undergo decommissioning. The no-action
• combination alternative (NGCC and 5 alternative represents a decision by the NRC solar power) 6 to not issue renewed operating licenses to a 7 nuclear power plant beyond the current Other Alternatives Considered but 8 operating license term. Under the no-action Eliminated:

9 alternative, the NRC does not issue the

• solar power 10 subsequent renewed operating licenses for 11 Turkey Point, such that the units would shut
• wind power 12 down at or before the expiration of the current
• biomass 13 licenses in 2032 (Unit 3) and 2033 (Unit 4).

14 The GEIS describes the environmental

• demand-side management 15 impacts that arise directly from permanent
• hydroelectric power 16 plant shutdown. The NRC expects shutdown
• geothermal power 17 impacts to be relatively similar whether they 18 occur at the end of the current license term
• wave and ocean energy 19 (i.e., after 60 years of operation) or at the end
• municipal solid waste 20 of a subsequent renewed license term (i.e.,
• petroleum-fired power 21 after 80 years of operation).
• coal-fired power 22 After permanent shutdown, plant operators
• fuel cells 23 will initiate decommissioning in accordance 24 with 10 CFR 50.82, Termination of license.
• purchased power 25 The decommissioning GEIS (NRC 2002a)
• delayed retirement of other 26 describes the environmental impacts from generating facilities 27 decommissioning a nuclear power plant and 28 related activities. The analysis in the decommissioning GEIS bounds the environmental impacts 29 of decommissioning at such time as FPL terminates reactor operations at Turkey Point.

30 Chapter 4 of the license renewal GEIS (NRC 2013a) and Section 4.15.2 of this SEIS describe 31 the incremental environmental impacts of subsequent license renewal on decommissioning 32 activities. 33 Termination of operations at Turkey Point would result in the total cessation of electrical power 34 production by Turkey Point Units 3 and 4, but not the electrical power produced by the balance 35 of the plant (e.g., Turkey Point Unit 5). Unlike the replacement power alternatives described 36 below in Section 2.2.2, the no-action alternative does not expressly meet the purpose and need 37 of the proposed action, as described in Section 1.2, because the no-action alternative does not 38 provide a means of delivering baseload power to meet future electric system needs. Assuming 39 that a need currently exists for the power generated by Turkey Point Units 3 and 4, the 40 no-action alternative would likely create a need for a replacement power alternative. The 41 following section describes a wide range of replacement power alternatives, and Chapter 4 42 assesses their potential environmental impacts. Although the NRCs authority only extends to 43 deciding whether to renew Turkey Point Units 3 and 4s current renewed operating licenses, the 44 replacement power alternatives described in the following sections represent possible options 45 for energy-planning decisionmakers if the NRC decides not to issue subsequent renewed 46 operating licenses for Turkey Point Units 3 and 4. 2-4

1 2.2.2 Replacement Power Alternatives 2 In evaluating alternatives to subsequent license renewal, the NRC considered energy 3 technologies or options currently in commercial operation, as well as technologies not currently 4 in commercial operation but likely to be commercially available by the time the current Turkey 5 Point renewed operating licenses expire on July 19, 2032 (Unit 3) and April 10, 2033 (Unit 4). 6 The GEIS presents an overview of some alternative energy technologies but does not conclude 7 which alternatives are most appropriate. Because alternative energy technologies are 8 continually evolving in capability and cost and because regulatory structures have changed to 9 either promote or impede the development of particular technologies, the analyses in this 10 chapter rely on a variety of sources of information to determine which alternatives would be 11 available and commercially viable when the current licenses expire. FPLs environmental report 12 provides a discussion of replacement power alternatives. In addition to the information FPL 13 provided in its environmental report, the NRC staffs analyses in this chapter include updated 14 information from the following sources: 15

• the U.S. Department of Energys U.S. Energy Information Administration (EIA) 16
• other offices within the U.S. Department of Energy (DOE) 17
• the U.S. Environmental Protection Agency (EPA) 18
• industry sources and publications 19 In total, the NRC staff considered 16 replacement power alternatives to the proposed action 20 (see text box) and eliminated 13 of these, which left the three reasonable replacement power 21 alternatives for in-depth evaluation described in Sections 2.2.2.1 through 2.2.2.3. The NRC 22 staffs in-depth evaluation of these three alternatives is presented in Chapter 4.

23 The staff eliminated from in-depth evaluation those alternatives that could not provide the 24 equivalent of Turkey Point Unit 3 and Unit 4s current generating capacity, as they would not be 25 able to satisfy the objective of replacing the power generated by these Turkey Point units. Also, 26 in some cases, the staff eliminated those alternatives whose costs or benefits could not justify 27 inclusion in the range of reasonable alternatives. Further, the staff eliminated as unfeasible 28 those alternatives not likely to be constructed and operational by the time the Turkey Point 29 licenses expire in 2032 (Unit 3) and 2033 (Unit 4). Section 2.3 of this report contains a brief 30 discussion of each eliminated alternative and provides the basis for its elimination. To ensure 31 that the alternatives considered in the SEIS are consistent with State or regional energy 32 policies, the NRC staff reviewed energy-related statutes, regulations, and policies within the 33 Turkey Point region. 34 The evaluation of each alternative considers the environmental impacts across the following 35 impact categories: 36

• land use and visual resources 37
• air quality and noise 38
• geologic environment 39
• water resources 40
• ecological resources 41
• historic and cultural resources 42
• socioeconomics, human health, environmental justice 43
• waste management 2-5

1 The GEIS assigns most site-specific issues (called Category 2 issues) a significance level of 2 SMALL, MODERATE, or LARGE. For ecological resources subject to the Endangered 3 Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) (ESA) and the Magnuson-Stevens 4 Fishery Conservation and Management Act of 1996, as amended (16 U.S.C. 1801 et seq.) 5 (MSA); and historic and cultural resources subject to the National Historic Preservation Act 6 of 1966, as amended (54 U.S.C. 300101 et seq.) (NHPA), the impact significance determination 7 language is specific to the authorizing legislation. The order in which this SEIS presents the 8 different alternatives does not imply increasing or decreasing level of impact; nor does the order 9 presented imply that an energy-planning decisionmaker would be more (or less) likely to select 10 any given alternative. 11 Region of Influence 12 If the NRC does not issue subsequent renewed licenses, procurement of replacement power for 13 Turkey Point Units 3 and 4 may be necessary. Turkey Point is owned and operated by FPL, 14 which provides electricity through its own bulk transmission system to a 35-county service area 15 concentrated in southern Florida and along Floridas Atlantic coast (FPL 2018g). The FPL 16 service territory constitutes the region of influence for the NRCs analysis of Turkey Point 17 replacement power alternatives. 18 In 2016, electric generators in Florida had a net summer generating capacity of approximately 19 58,000 megawatts (MW). This capacity included units fueled by natural gas (65 percent), coal 20 (17 percent), petroleum (9 percent), and nuclear power (6 percent). Lesser amounts associated 21 with several other miscellaneous energy sources comprised the balance of generating capacity 22 in the State (EIA 2018a). 23 The electric industry in Florida provided approximately 238 million megawatt hours (MWh) of 24 electricity in 2016. This electrical production was dominated by natural gas (67 percent), coal 25 (17 percent), and nuclear power (12 percent). Petroleum, biomass, and other miscellaneous 26 energy sources collectively produced the other 4 percent of the electricity in Florida 27 (EIA 2018b). 28 In the United States, natural gas generation rose from 16 percent of electricity generated in 29 2000 to 31 percent in 2017. Given known technological and demographic trends, the U.S. 30 Energy Information Administration predicts that by 2050, natural gas will account for 35 percent 31 of electricity generated in the United States (EIA 2013a, EIA 2016a, EIA 2018c). Electricity 32 generated from renewable energy is expected to grow from 13 percent of total generation in 33 2015 to 30 percent in 2050 (EIA 2016a, EIA 2018d). However, Floridas renewable energy 34 growth may not follow nationwide forecasts. Florida currently obtains only a small portion of its 35 energy from renewable resources, with most of that production primarily generated from 36 biomass, and to a lesser degree from solar and hydroelectric resources (EIA 2017a). The State 37 of Florida does not have a mandatory renewable portfolio standard, and there are other 38 uncertainties that could affect forecasts. In particular, the implementation of policies aimed at 39 reducing greenhouse gas (GHG) emissions could have a direct effect on fossil-fuel-based 40 generation technologies (LBNL 2017a). 2-6

1 The remainder of this section describes in depth the three reasonable replacement power 2 alternatives to Turkey Point subsequent license renewal. These three reasonable alternatives 3 are as follows: 4

• a new nuclear alternative (Section 2.2.2.1) 5
• a natural gas combined-cycle alternative (Section 2.2.2.2) 6
• a combination of natural gas combined-cycle and solar power alternative 7 (Section 2.2.2.3) 8 Table 2-1 below summarizes key design characteristics of these three alternative replacement 9 power technologies. Section 2.2.3 also describes a possible cooling water system alternative.

10 Table 2-1 Summary and Key Characteristics of Replacement Power Alternatives 11 Considered In Depth Natural Gas Combined-Cycle and Solar Natural Gas Photovoltaic Combination New Nuclear Alternative Combined-Cycle Alternative Alternative Summary of Two-unit nuclear plant, Three 500-MWe units for a Approximately 1,420 MWe Alternative each with 750 MWe, for a total of approximately from natural gas combined-total of 1,500 MWe 1,500 MWe cycle (three units), and 80 MWe from solar PV (four units) Location Located within the Turkey Located within the Turkey Partially located within the Point site, but outside the Point site (same location as Turkey Point site (same current footprint of Turkey New Nuclear Alternative). location as New Nuclear Point (Units 3 and 4). Also, Alternative for the natural outside the footprint of Replacement plant would gas combined-cycle plant Unit 5 (natural gas) and the share existing and planned and one of the four solar proposed footprint of infrastructure supporting PV units; the other three Units 6 and 7 (nuclear), other Turkey Point units. solar PV units would be which are assumed to be May also require some located at offsite locations operational. infrastructure upgrades as within the ROI). well as construction of a Replacement plant would new or upgraded pipeline. Replacement plants would share existing and planned (FPL 2018f). share existing and planned infrastructure supporting infrastructure supporting these other units (FPL other Turkey Point units. 2018f). May also require some infrastructure upgrades as well as construction of a new or upgraded pipeline. (FPL 2018f). 2-7

Natural Gas Combined-Cycle and Solar Natural Gas Photovoltaic Combination New Nuclear Alternative Combined-Cycle Alternative Alternative Cooling System Closed cycle with Closed cycle with Natural gas combined-cycle mechanical draft cooling mechanical draft cooling units would use closed-towers. Cooling water towers. Cooling water cycle cooling systems with withdrawal38 mgd; withdrawal10.5 mgd; mechanical draft cooling consumptive water use consumptive water use towers. 29 mgd (NRC 2016a). 8.1 mgd (NETL 2013). Cooling water withdrawal for these units would be 9.9 mgd; consumptive water use would be 7.7 mgd (NETL 2013). No cooling system would be required for the solar facilities. Land Approximately 360 ac Approximately 75 ac Approximately 540 ac Requirements (150 ha). (30 ha) for the plant, with (220 ha) onsite at FPL for (FPL 2018f). up to an additional 1,200 ac the natural gas (490 ha) for right-of-way to combined-cycle and solar connect with existing units, with up to an natural gas supply lines additional 1,200 ac (490 ha) north of the site. for right-of-way to connect No new gas wells would be with existing natural gas needed to support the supply lines north of the facility (FPL 2018f). site. No new gas wells would be needed. Three offsite solar units would require approximately 470 ac (190 ha) each, for an offsite total of approximately 1,400 ac (570 ha) (FPL 2018f). Work Force 3,900 workers during peak 1,200 workers during peak Natural gas combined-cycle construction and 800 construction and 150 and solar units would workers during operations workers during operations collectively require 1,400 (NRC 2016a). (NRC 2016a). workers during peak construction and 160 workers during operations. (NRC 2016a, DOE 2011). Key: ac = acres, ha = hectares, mgd = million gallons per day, MWe = megawatts electric, NGCC = natural gas combined-cycle (alternative), PV = photovoltaic, and ROI = region of influence. 1 2.2.2.1 New Nuclear Alternative 2 The NRC staff considers the construction of a new nuclear plant to be a reasonable alternative 3 to Turkey Point subsequent license renewal. Nuclear generation currently provides 4 approximately 12 percent of the electricity in Florida (EIA 2018b). One other nuclear power 2-8

1 plant operates in the region of influence: the St. Lucie Plant, Units 1 and 2, is located 2 approximately 130 miles (209 km) north of Turkey Point. The NRC staff determined that there 3 may be sufficient time for FPL to prepare and submit an application, build, and operate two new 4 nuclear units using a certified design before the Turkey Point Units 3 and 4 licenses expire in 5 2032 and 2033. 6 In evaluating the new nuclear alternative, the NRC staff assumed that FPL would build two new 7 nuclear reactors on a portion of the approximately 9,500-acre (3,800-ha) Turkey Point property. 8 The construction would allow for the maximum use of existing ancillary facilities (e.g., support 9 buildings and transmission infrastructure at location). In addition to Turkey Point Units 3 and 4, 10 the Turkey Point property currently includes Units 1 and 2 (two retired natural gas/oil units), as 11 well as Unit 5 (an operating natural gas combined-cycle unit (FPL 2018f). 12 In 2018, as part of a separate licensing action, the NRC issued combined licenses (COLs) to 13 FPL for the construction and operation of two new AP1000 nuclear reactor units (Turkey Point 14 Units 6 and 7) at the Turkey Point site (NRC 2018e). These proposed new units would have a 15 combined net electrical output of approximately 2,200 MWe and would be constructed on 16 approximately 220 acres (ac) (89 hectares (ha)) immediately south of Turkey Point Units 3 17 and 4 (NRC 2018f). 18 For the purpose of this subsequent license renewal analysis, the NRC staff assumed two 19 separate Westinghouse AP1000 reactors would replace Turkey Point Units 3 and 4. The 20 AP1000 reactors would use the same general design as that described in Chapter 3 of 21 NUREG-2176, Environmental Impact Statement for Combined Licenses (COLs) for Turkey 22 Point Nuclear Plant Units 6 and 7 (NRC 2016a); however, the new nuclear alternative reactors 23 location and generating capacity would differ from Turkey Point Units 6 and 7. For the new 24 nuclear alternative, the replacement power facility would be located within the Turkey Point 25 property, but outside the current footprints of Turkey Point Units 3 and 4 and Turkey Point 26 Unit 5, as well as outside the proposed footprint of the not-yet-constructed Turkey Point Units 6 27 and 7 (FPL 2018f). In addition, the replacement nuclear power facility would be scaled to 28 replace the Turkey Point Units 3 and 4 current net electrical output of approximately 29 1,500 MWe. This is approximately 32 percent less net electrical output than what the staff 30 evaluated in NUREG-2176 for Turkey Point Units 6 and 7. Accordingly, the heat rejection 31 demands of these new nuclear reactors would also be similar to those of Turkey Point 32 Units 3 and 4. As stated in FPLs environmental report, the new nuclear alternative would use a 33 mechanical draft cooling tower system. Consistent with the approach and analyses presented 34 in NUREG-2176 (the EIS for the Units 6 and 7 combined licenses), this closed-cycle cooling 35 system would primarily use reclaimed wastewater from the Miami-Dade Water and Sewer 36 Department, with saltwater produced from radial collection wells under Biscayne Bay used as a 37 temporary backup source (FPL 2018f, NRC 2016a). The NRC staff assumes that existing 38 Turkey Point Unit 5 and planned and licensed Turkey Point Units 6 and 7 will continue to be 39 operational during the construction and operation of the new nuclear alternative, and that 40 necessary infrastructure supporting Units 5, 6, and 7 will be available for shared use by the 41 replacement nuclear power facility. Similarly, the NRC staff assumes that the existing 42 transportation and transmission line infrastructure at Turkey Point will be adequate to support 43 the new nuclear alternative, since Units 3 and 4 would not be operating. 44 The NRC staff also considered the installation of multiple small modular reactors as a new 45 nuclear alternative to renewing the Turkey Point Units 3 and 4 licenses. The NRC established 46 the Advanced Reactor Program in the Office of New Reactors because of considerable interest 47 in small modular reactors along with anticipated license applications from vendors. Small 2-9

1 modular reactors generate approximately 300 MW or less, so they have lower initial capacity 2 than that of traditional large-scale units. However, they have greater siting flexibility because 3 they can fit in locations not large enough to accommodate traditional nuclear reactors 4 (DOE 2018b). The NRC received the first design certification application for a small modular 5 reactor in December 2016 (NRC 2017a). Following NRC certification, this design could 6 potentially achieve operation on a commercial scale by 2026 (NuScale 2018). The NRC staff 7 assumes that the resource requirements and key characteristics associated with constructing 8 and operating small modular reactors would be bounded by the larger nuclear units evaluated in 9 this SEIS. 10 2.2.2.2 Natural Gas Combined-Cycle Alternative 11 As discussed earlier, natural gas represents approximately 65 percent of the installed 12 generation capacity and 67 percent of the electrical power generated in Florida (EIA 2018a, 13 EIA 2018b). The NRC staff considers the construction of a natural gas combined-cycle power 14 plant to be a reasonable alternative to Turkey Point subsequent license renewal because 15 natural gas is a feasible, commercially available option for providing baseload electrical 16 generating capacity beyond the expiration of Turkey Points current licenses. 17 Baseload natural gas combined-cycle power plants (abbreviated in this section as natural gas 18 plants) have proven their reliability and can have capacity factors as high as 87 percent 19 (EIA 2015a). In a natural gas combined-cycle system, electricity is generated using a gas 20 turbine that burns natural gas. A steam turbine uses the heat from gas turbine exhaust through 21 a heat recovery steam generator to produce additional electricity. This two-cycle process has a 22 high rate of efficiency because the natural gas combined-cycle system captures the exhaust 23 heat that otherwise would be lost and reuses it. Similar to other fossil fuel sources, natural gas 24 power plants are a source of greenhouse gases, including carbon dioxide (CO2). However, a 25 natural gas combined-cycle power plant produces significantly fewer greenhouse gases per unit 26 of electrical output than conventional coal powered plants (NRC 2013a). 27 For this alternative, the NRC staff assumes that three natural gas units would be constructed 28 and operated to replace Turkey Points generating capacity. Each natural gas unit would have a 29 gross capacity of approximately 575 MWe and be operated using an 87 percent capacity factor. 30 Together, the three units would collectively replace Turkey Points approximate net generating 31 capacity of 1500 MWe. Each unit configuration would consist of two combustion turbine 32 generators, two heat recovery steam generators, and one steam turbine generator with 33 mechanical draft cooling towers for heat rejection. The NRC staff assumes that the natural gas 34 power plant will incorporate a selective catalytic reduction system to minimize the plants 35 nitrogen oxide emissions (NETL 2007). Natural gas would be extracted from the ground 36 through wells, treated to remove impurities, and then blended to meet pipeline gas standards 37 before being piped through the States pipeline system to the Turkey Point site. The natural gas 38 alternative would produce waste, primarily in the form of spent catalysts used for control of 39 nitrogen oxide emissions. 40 Similar to the new nuclear alternative (Section 2.2.2.1), the NRC staff assumes that the natural 41 gas replacement power facility would be built on a portion of the approximately 9,500 ac 42 (3,800 ha) Turkey Point property and would allow for the maximum use of the locations existing 43 ancillary facilities (e.g., support buildings and transmission infrastructure). Approximately 75 ac 44 (30 ha) would be used to construct and operate the natural gas plant (FPL 2018f). Depending 45 on the specific site location and proximity of existing natural gas pipelines, the natural gas 46 alternative may also require up to 1,200 ac (490 ha) of land for right-of-way to connect with 2-10

1 existing natural gas supply lines north of the site. In its environmental report, FPL states that no 2 new gas wells would be needed to support the natural gas combined-cycle alternative 3 (FPL 2018f). 4 The NRC staff assumes that the natural gas combined-cycle plant would use a closed-cycle 5 cooling system with mechanical draft cooling towers. To support the plants cooling needs, this 6 cooling system would withdraw approximately 10.5 million gallons per day (mgd) (39,000 cubic 7 meters per day (m3/d)) of water and consume 8.1 mgd (31,000 m3/d) of water (NETL 2013). 8 Because of the high overall thermal efficiency of this type of plant, the natural gas combined-9 cycle alternative would require less cooling water than Turkey Point subsequent license 10 renewal. Onsite visible structures could include the cooling towers, exhaust stacks, intake and 11 discharge structures, transmission lines, natural gas pipelines, and an electrical switchyard. 12 Construction materials could be delivered by a combination of truck and barge. 13 2.2.2.3 Combination Alternative (Natural Gas Combined-Cycle and Solar) 14 This alternative combines natural gas and solar replacement power generation to meet the 15 needs and purpose of the Turkey Point subsequent license renewal. Natural gas and solar 16 power generating facilities currently operate within the region of influence. For the purpose of 17 this evaluation, the NRC staff assumes that (1) a natural gas combined-cycle plant would supply 18 1,420 MWe, and (2) four separate solar power plants would supply approximately 80 MWe. 19 Further, the staff assumes that the natural gas combined-cycle facility and one of the four solar 20 plants would be located within the Turkey Point property and would use existing available site 21 infrastructure to the extent practicable. The other three solar facilities would be located at offsite 22 locations within the region of influence, specifically within Miami-Dade and Broward counties 23 (FPL 2018f). 24 Natural Gas Combined-Cycle Portion of Combination Alternative 25 The natural gas portion of the combination alternative would be generated using a natural gas 26 combined-cycle plant located in the ROI. Although similar in function and appearance to the 27 three-unit natural gas plant described in Section 2.2.2.2, the natural gas plant considered under 28 the combination alternative would have slightly less generating capacity. Specifically, the NRC 29 assumes that the plant would consist of three approximately 545 MWe natural gas units that 30 would be constructed and operated using an 87 percent capacity factor (EIA 2015a) to 31 collectively provide an approximate net generating capacity of 1,420 MWe. 32 Approximately 70 ac (28 ha) of land would be required to construct and operate the natural gas 33 units (FPL 2018f). Depending on the specific site location and proximity of existing natural gas 34 pipelines, the natural gas portion of this alternative may also require up to 1,200 ac (490 ha) of 35 land for right-of-way to connect with existing natural gas supply lines north of the site. In its 36 environmental report, FPL states that no new gas wells would be needed to support a natural 37 gas combined-cycle power plant (FPL 2018f). 38 The NRC staff assumes that the natural gas plant would use a closed-cycle cooling system with 39 mechanical draft cooling towers. To support the plants cooling needs, this system would 40 withdraw approximately 9.9 million gallons-per-day (mgd) (37,000 m3/d) of water and consume 41 7.7 mgd (29,000 m3/d) of water (NETL 2013). 2-11

1 Solar Portion of Combination Alternative 2 The solar portion of the combination alternative would be generated using solar photovoltaic 3 energy facilities located in the region of influence. For the purpose of this analysis, the NRC 4 assumes that four, approximately 75 MWe, standalone utility-scale solar facilities would be 5 constructed and operated to provide a gross generating capacity of 300 MWe. One of these 6 units would be located on FPL-owned lands in the Turkey Point area, and three units would be 7 located at offsite locations in Miami-Dade County and/or Broward County (FPL 2018f). 8 Assuming a 26-percent capacity factor, the solar units collectively would have an approximate 9 net generating capacity of 80 MWe (FPL 2018f). 10 Nationwide, growth in utility-scale solar photovoltaic facilities (greater than 1 MW) has resulted 11 in an increase from 70 MW in 2008 to over 20,000 MW installed capacity in 2017 (EIA 2017b). 12 Although Florida has the 3rd-highest solar potential in the Nation, the State only ranks 12th in 13 installed capacity with approximately 725 MW. However, solar energy is projected to supply the 14 most new-renewable-energy capacity to the State over the next decade, and FPL plans to add 15 more than 2,000 MW of additional solar generation capacity during that timeframe (EIA 2017a, 16 FPL 2018f). 17 Solar photovoltaic resources across Florida range from 5.0 to 5.5 kilowatt hours per square 18 meter per day (kWh/m2/day) (NREL 2017). The feasibility of solar energy resources serving as 19 alternative baseload power is dependent on the location, value, accessibility, and constancy of 20 solar radiation. Solar photovoltaic power generation uses solar panels to convert solar radiation 21 into usable electricity. Solar cells are formed into solar panels that can then be linked into 22 photovoltaic arrays to generate electricity. The electricity generated can be stored, used 23 directly, fed into a large electricity grid, or combined with other electricity generators as a hybrid 24 plant. Solar photovoltaic cells can generate electricity whenever there is sunlight, regardless of 25 whether the sun is directly or indirectly shining on the solar panels. Therefore, solar 26 photovoltaic technologies do not need to directly face and track the sun. This capability has 27 allowed solar photovoltaic systems to have broader geographical use than concentrating solar 28 power (which relies on direct sun) (DOE 2011). Because the region of influence contains 29 above-average solar photovoltaic resources and because solar photovoltaic technology is a 30 commercially available option for providing electrical generating capacity, the NRC staff 31 considers the construction of solar photovoltaic facilities to be a reasonable alternative to 32 subsequent license renewal when combined with natural gas combined-cycle facilities. 33 Utility-scale solar facilities require large areas of land to be cleared for the solar panels. For 34 standalone sites, solar photovoltaic facilities may require approximately 6.2 ac per megawatt 35 (NRC 2013a). Therefore, approximately 470 ac (190 ha) would be required for each of the four 36 proposed solar power installations needed under this alternative (FPL 2018f). Although not all 37 of this land would be cleared of vegetation and permanently impacted, it represents the land 38 enclosed in the total site boundary of the solar facility (NREL 2013). Solar photovoltaic systems 39 do not require water for cooling purposes but do require a small amount of water to clean the 40 panels and for potable water for the workforce. 41 2.2.3 Cooling Water System Alternative 42 In addition to replacement power alternatives, this SEIS evaluates an alternative cooling water 43 system technology for Turkey Point Units 3 and 4 that might be used to mitigate the potential 44 impacts associated with continued use of the existing cooling canal system. The purpose of this 45 analysis is for the NRC staff to compare an alternative closed-cycle cooling system approach 2-12

1 with the proposed action to inform the NRCs licensing decision, decisions by other 2 decisionmakers and the public, as applicable, under NEPA. However, the NRC has neither the 3 statutory nor the regulatory authority to determine which system or technology should be used, 4 or to decide other permitting issues, for which the State of Florida has been delegated 5 regulatory authority under the Clean Water Act. 6 The NRC staffs analysis of the alternative cooling water system draws upon an application 7 which FPL submitted to the NRC in 2009, for COLs to build and operate two new onsite nuclear 8 reactors (Turkey Point Units 6 and 7). The NRC staff conducted an environmental review of 9 that COL application and published it as NUREG-2176. Section 3.2.2.2 of the COL EIS 10 describes a cooling water system alternative to Turkey Points existing cooling canal system that 11 consists of onsite mechanical draft cooling towers (NRC 2016a). Under the cooling water 12 system alternative that is evaluated by the NRC staff in this license renewal SEIS, Turkey Point 13 Units 3 and 4 would each use three similar closed-cycle wet-cooling towers (six cooling towers 14 in total) to dissipate heat from the reactor cooling water systems. These mechanical draft water 15 towers would be octagonal in shape and extend approximately 70 feet (20 m) in height and 16 250 feet (75 m) in diameter (NRC 2016a). 17 The Units 3 and 4 cooling towers would have the same general design, construction, and 18 operating characteristics as the cooling water system associated with the new nuclear 19 alternative described in Section 2.2.2.1 of this SEIS. As in the new nuclear alternative, the 20 primary source of cooling water is assumed to be reclaimed wastewater. Similarly, as 21 summarized in Table 2-1 of this SEIS, cooling water makeup would be approximately 38 mgd 22 (144,000 m3/d) and consumptive water use would be approximately 29 mgd (110,000 m3/d). 23 Other discrete resource requirements associated with constructing and operating these cooling 24 towers would be a subset of the overall resource requirements identified in NUREG-2167 (the 25 EIS for the Turkey Point Units 6 and 7 combined licenses) in Tables 3-4 and 3-6 (NRC 2016a). 26 2.3 Alternatives Considered but Eliminated 27 The NRC staff originally considered 16 replacement power alternatives to Turkey Point Unit 3 28 and 4s subsequent license renewal, but ultimately eliminated 13 of these from detailed study. 29 The staff eliminated these 13 alternatives because of technical reasons, resource availability 30 limitations, or commercial or regulatory limitations. Many of these limitations will likely still exist 31 when the current Turkey Point licenses expire in 2032 and 2033, such that these 13 alternatives 32 are not expected to be reasonably available when needed to replace the power generated by 33 Turkey Point Units 3 and 4. 34 2.3.1 Solar Power 35 Solar power, including solar photovoltaic (PV) and concentrating solar power (CSP) 36 technologies, produce power generated from sunlight. Solar photovoltaic components convert 37 sunlight directly into electricity using solar cells made from silicon or cadmium telluride. 38 Concentrating solar power uses heat from the sun to boil water and produce steam. The steam 39 then drives a turbine connected to a generator to ultimately produce electricity (NREL 2014). 40 Solar generators are considered an intermittent resource because their availability depends on 41 ambient exposure to the sun, also known as solar insolation (EIA 2017c). Insolation rates of 42 solar photovoltaic resources in Florida range from 5.0 to 5.5 kWh/m2/day (NREL 2017a). Due to 43 higher solar insolation requirements associated with concentrating solar power, utility-scale 44 application of this technology has generally only occurred in western States with high solar 2-13

1 thermal resources and large, contiguous tracts of land in arid environments (i.e., California, 2 Arizona, and Nevada) (EIA 2016c). The exception is FPLs Martin generating station, the only 3 concentrating solar power plant east of the Rocky Mountains, which produced approximately 4 22 percent of the states utility-scale net solar generation in 2016 (EIA 2017d). 5 Although Florida has abundant solar resource potential, it generates only a small part of its 6 energy from solar or other renewable resources (EIA 2017a). In addition, Florida does not have 7 a mandatory renewable portfolio standard that would require generators to consider solar power 8 (EIA 2017a). To be considered a viable alternative, a solar alternative must replace the amount 9 of electricity that Turkey Point provides. Assuming capacity factors of 25 to 50 percent 10 (DOE 2011), approximately 3,000 to 6,000 MWe of additional gross solar capacity would need 11 to be installed in the region of influence, which substantially exceeds existing capacity across 12 the state and plans for additional solar generation capacity in the region of influence over the 13 next decade (EIA 2017a, FPL 2018f). 14 Considering the above factors, the NRC staff concludes that solar power energy facilities alone 15 do not provide a reasonable alternative to Turkey Point subsequent license renewal. However, 16 the NRC staff does consider an alternative using solar power in combination with natural gas 17 combined-cycle power, as described above in Section 2.2.2.3. 18 2.3.2 Wind Power 19 As is the case with other renewable energy sources, the feasibility of wind power serving as 20 alternative baseload power is dependent on the location (relative to expected electricity users), 21 value, accessibility, and constancy of the resource. Wind energy must be converted to 22 electricity at or near the point where it is extracted, and currently there are limited energy 23 storage opportunities available to overcome the intermittency and variability of wind resources. 24 To be considered a reasonable replacement power alternative to Turkey Point subsequent 25 license renewal, the wind power alternative must replace the amount of electricity that Turkey 26 Point provides. Assuming a capacity factor of 35 percent for land-based wind and 40 percent 27 for offshore wind, a combination of land-based and offshore wind energy facilities in the region 28 of influence would have to generate a range of approximately 3,750 to 4,300 MWe of electricity. 29 The American Wind Energy Association reports a total of more than 90,000 MW of installed 30 wind energy capacity nationwide as of March 31, 2018 (DOE 2018d). Texas leads all other 31 States in installed land-based wind energy capacity with over 23,000 MW. In contrast, Florida 32 currently has no installed land-based wind power capacity and little overall wind potential to 33 support the development of future wind energy systems (DOE 2018a, EIA 2017a). 34 Similarly, Florida does not have any utility-scale offshore wind farms in operation. In 2016, a 35 30 MW project off the coast of Rhode Island become the first operating offshore wind farm in the 36 United States (Energy Daily 2016). Although approximately 20 offshore wind projects 37 representing more than 15,000 MW of capacity were in the planning and permitting process as 38 of 2015, most of these projects are concentrated along the North Atlantic coast, and none are 39 currently planned off the shores of Florida (EIA 2015b, DOE 2018a). 40 Given the amount of wind capacity necessary to replace Turkey Point, the intermittency of the 41 resource, the current lack of any installed wind capacity in the State, and the limited potential for 42 any new development in the region of influence, the NRC staff finds a wind-based alternative 2-14

1 either land based, offshore, or some combination of the twoto be an unreasonable alternative 2 to Turkey Point subsequent license renewal. 3 2.3.3 Biomass Power 4 Using biomass-fired generation for baseload power depends on the geographic distribution, 5 available quantities, constancy of supply, and energy content of biomass resources. For this 6 analysis, the NRC staff assumed that biomass would be combusted for power generation in the 7 electricity sector. Biomass is also used for space heating in residential and commercial 8 buildings and can be converted to a liquid form for use in transportation fuels. 9 Biomass fuels are abundant in Florida, and currently provide the largest share of Floridas 10 renewable electricity generation (EIA 2017a). In 2016, Florida had a total installed capacity of 11 approximately 1,300 MW, and approximately 2 percent of the States total system power was 12 produced from biomass (EIA 2018a, EIA 2018b). 13 For utility-scale biomass electricity generation, the NRC staff assumes that the technologies 14 used for biomass conversion would be similar to fossil fuel plants, including the direct 15 combustion of biomass in a boiler to produce steam (NRC 2013a). Biomass generation is 16 generally more cost effective when co-fired with coal plants (IEA 2007). In 2013, Florida 17 opened the 103-MW Gainesville Renewable Energy Center, one of the largest new biomass 18 plants in the United States (EIA 2016b). Replacing the generating capacity of Turkey Point 19 using only biomass would require the construction of approximately 15 additional facilities of this 20 size. However, most biomass-fired generation plants generally only reach capacities of 50 MW, 21 which means replacing the generating capacity of Turkey Point would require the construction of 22 twice as many new average-sized biomass facilities. Sufficiently increasing biomass-fired 23 generation capacity by expanding existing biomass units or constructing new biomass units by 24 the time Turkey Points licenses expire in 2032 and 2033, is unlikely. For this reason, the NRC 25 staff does not consider biomass-fired generation to be a reasonable alternative to Turkey Point 26 subsequent license renewal. 27 2.3.4 Demand-Side Management 28 Energy conservation can include reducing energy demand through behavioral changes or 29 altering the shape of the electricity load, and usually does not require the addition of new 30 generating capacity. Conservation and energy efficiency programs are more broadly referred to 31 as demand-side management. 32 Conservation and energy efficiency programs can be initiated by a utility, transmission 33 operators, the State, or other load-serving entities. In general, residential electricity consumers 34 have been responsible for the majority of peak load reductions and participation in most 35 programs is voluntary. Therefore, the existence of a program does not guarantee that 36 reductions in electricity demand would occur. The GEIS concludes that, although the energy 37 conservation or energy efficiency potential in the United States is substantial, the NRC staff is 38 aware of no cases where an energy efficiency or conservation program alone has been 39 implemented expressly to replace or offset a large baseload generation station (NRC 2013a). 40 FPL estimates that demand-side management efforts from 1978 to 2017 have resulted in a total 41 savings of approximately 4,800 MW across its service territory (FPL 2018g). In 2014, the 42 Florida Public Services Commission established FPLs current demand-side management 43 goals, and FPL has accounted for these goals in its planning process through at least 2027. 2-15

1 However, it is unlikely that further cost-effective reductions in electrical demand, particularly in 2 Broward and Miami-Dade counties, could replace Turkey Points generation (FPL 2018f). 3 Therefore, the NRC staff does not consider demand-side management and energy efficiency 4 programs to be a reasonable alternative to Turkey Point subsequent license renewal. 5 2.3.5 Hydroelectric Power 6 Currently, approximately 2,000 hydroelectric facilities operate in the United States. 7 Hydroelectric technology captures flowing water and directs it to a turbine and generator to 8 produce electricity (NRC 2013a). There are three variants of hydroelectric power: 9 (1) run-of-the-river (diversion) facilities that redirect the natural flow of a river, stream, or canal 10 through a hydroelectric facility, (2) store-and-release facilities that block the flow of the river by 11 using dams that cause water to accumulate in an upstream reservoir, and (3) pumped storage 12 facilities that use electricity from other power sources to pump water to higher elevations during 13 off-peak load periods to be released during peak load periods through the turbines to generate 14 additional electricity. 15 A comprehensive survey of hydropower resources, completed in 1997, identified Florida as 16 having only 43 MW of potential hydroelectric capacity when adjusted for environmental, legal, 17 and institutional constraints (Conner et. al., 1998). These constraints could include (1) scenic, 18 cultural, historical, and geological values, (2) Federal and State land use, and (3) legal 19 protection issues, such as wild and scenic legislation and threatened or endangered fish and 20 wildlife legislative protection. A separate DOE assessment of non-powered dams (dams that do 21 not produce electricity) concludes that there is potential for 173 MW of electricity in Florida 22 (ORNL 2012). These non-powered dams serve various purposes, such as providing water 23 supply to inland navigation. However, hydroelectric power accounted for less than one percent 24 of the States electric power production in 2016 (EIA 2018b). Although the U.S. Energy 25 Information Administration projects that hydropower will remain a leading source of renewable 26 generation in the United States through 2040, there is little expected growth in hydropower 27 capacity (EIA 2013a). The potential for future construction of large hydropower facilities has 28 diminished because of increased public concerns over flooding, habitat alteration and loss, and 29 destruction of natural river courses (NRC 2013a). 30 Given the projected lack of growth in hydroelectric power production, the low potential capacity 31 in Florida, the competing demands for water resources, and the expected public opposition to 32 the large environmental impacts and significant changes in land use that would result from the 33 construction of hydroelectric facilities, the NRC staff concludes that the expansion of 34 hydroelectric power is not a reasonable alternative to Turkey Point subsequent license renewal. 35 2.3.6 Geothermal Power 36 Geothermal technologies extract the heat contained in geologic formations to produce steam to 37 drive a conventional steam turbine generator. Facilities producing electricity from geothermal 38 energy have demonstrated capacity factors of 95 percent or greater, making geothermal energy 39 a potential source of baseload electric power. However, the feasibility of geothermal power 40 generation to provide baseload power depends on the regional quality and accessibility of 41 geothermal resources. Utility-scale geothermal energy generation requires geothermal 42 reservoirs with a temperature above 200 °F (93 °C). Known geothermal resources are 43 concentrated in the western United States, specifically Alaska, Arizona, California, Colorado, 44 Hawaii, Idaho, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming. In 45 general, most assessments of geothermal resources have been concentrated on these western 2-16

1 States (DOE 2013a, USGS 2008a). Geothermal resources are used in the Turkey Point region 2 of influence for heating and cooling purposes, but no electricity is currently being produced from 3 geothermal resources in the region of influence (EIA 2017e). Given the low resource potential 4 in the region of influence, the NRC staff does not consider geothermal to be a reasonable 5 alternative to Turkey Point subsequent license renewal. 6 2.3.7 Wave and Ocean Energy 7 Waves, currents, and tides are often predictable and reliable, making them attractive candidates 8 for potential renewable energy generation. Four major technologies may be suitable to harness 9 wave energy: (1) terminator devices that range from 500 kilowatts to 2 MW, (2) attenuators, 10 (3) point absorbers, and (4) overtopping devices (BOEM undated). Point absorbers and 11 attenuators use floating buoys to convert wave motion into mechanical energy, driving a 12 generator to produce electricity. Overtopping devices trap a portion of a wave at a higher 13 elevation than the sea surface; waves then enter a tube and compress air that is used to drive a 14 generator that produces electricity (NRC 2013a). Some of these technologies are undergoing 15 demonstration testing at commercial scales, but none are currently used to provide baseload 16 power (BOEM undated). 17 Resource assessments show that modest energy production potential is associated with the 18 Florida Current of the Gulf Stream along Floridas southeastern coast (DOE 2018c). However, 19 wave and ocean energy generation technologies are still in their infancy and currently lack 20 commercial application. For these reasons, the NRC staff does not consider wave and ocean 21 energy to be a reasonable alternative to Turkey Point subsequent license renewal. 22 2.3.8 Municipal Solid Waste 23 Energy recovery from municipal solid waste converts non-recyclable waste materials into usable 24 heat, electricity, or fuel through combustion (EPA 2014a). The three types of combustion 25 technologies include mass burning, modular systems, and refuse-derived fuel systems 26 (EPA 2014b). Mass burning is the method used most frequently in the United States. The heat 27 released from combustion is used to convert water to steam, which is used to drive a turbine 28 generator to produce electricity. Ash is collected and taken to a landfill, and particulates are 29 captured through a filtering system (EPA 2014b). As of 2016, 77 waste-to-energy plants are in 30 operation in 22 States, processing approximately 30 million tons of waste per year. These 31 waste-to-energy plants have an aggregate capacity of 2,547 MWe. Although some plants have 32 expanded to handle additional waste and to produce more energy, no new plants have been 33 built in the United States since 1995 (EPA 2014a, Michaels 2016). The average 34 waste-to-energy plant produces about 50 MWe, with some reaching 77 MWe, and can operate 35 at capacity factors greater than 90 percent (Michaels 2010). In 2017, municipal solid waste 36 accounted for approximately 450 MW of Floridas electrical capacity (FDACS 2017). 37 Approximately 30 average-sized waste-to-energy plants would be necessary to provide the 38 same level of output as Turkey Point Units 3 and 4. 39 The decision to burn municipal waste to generate energy is usually driven by the need for an 40 alternative to landfills rather than a need for energy. Given the improbability that additional 41 stable supplies of municipal solid waste would be available to support 30 new facilities in the 42 region of influence, the NRC staff does not consider municipal solid waste combustion to be a 43 reasonable alternative to Turkey Point subsequent license renewal. 2-17

1 2.3.9 Petroleum-Fired Power 2 Petroleum-fired electricity generation accounted for approximately 1 percent of Floridas 3 statewide total electricity generation in 2016 (EIA 2018b). The variable costs and environmental 4 impacts of petroleum-fired generation tend to be greater than those of 5 natural gas-fired generation. The historically higher cost of oil has also resulted in a steady 6 decline in its use for electricity generation, and the U.S. Energy Information Administration 7 forecasts no growth in capacity using petroleum-fired power plants through 2040 (EIA 2013a, 8 EIA 2015c). Therefore, the NRC staff does not consider petroleum-fired generation to be a 9 reasonable alternative to Turkey Point subsequent license renewal. 10 2.3.10 Coal-Fired Power 11 Although coal has historically been the largest source of electricity in the United States, the 12 U.S. Energy Information Administration expects natural gas generationand potentially even 13 renewable energy generationto surpass coal generation at the national level by 2040 14 (EIA 2016a). Florida exemplifies this trend, with coal historically fueling the largest share of 15 electricity generated in the state until 2003, when it was surpassed by natural gas (EIA 2017a). 16 In 2016, coal-fired generation accounted for approximately 17 percent of all electricity generated 17 in Florida, a 21-percent decrease from 2000 levels (EIA 2018b). 18 Baseload coal units have proven their reliability and can routinely sustain capacity factors as 19 high as 85 percent. Among the technologies available, pulverized coal boilers producing 20 supercritical steam (supercritical pulverized coal or SCPC boilers) are increasingly common for 21 new coal-fired plants given their generally high thermal efficiencies and overall reliability. 22 Supercritical pulverized coal facilities are more expensive than subcritical coal-fired plants to 23 construct, but they consume less fuel per unit output, reducing environmental impacts. In a 24 supercritical coal-fired power plant, burning coal heats pressurized water. As the supercritical 25 steam and water mixture moves through plant pipes to a turbine generator, the pressure drops 26 and the mixture flashes to steam. The heated steam expands across the turbine stages, which 27 then spin and turn the generator to produce electricity. After passing through the turbine, any 28 remaining steam is condensed back to water in the plants condenser. Integrated gasification 29 combined cycle is another technology that generates electricity from coal. It combines modern 30 coal gasification technology with both gas turbine and steam turbine power generation. The 31 technology is cleaner than conventional pulverized coal plants because some of the major 32 pollutants are removed from the gas stream before combustion. 33 An integrated gasification combined-cycle power plant consists of coal gasification and 34 combined-cycle power generation. Coal gasifiers convert coal into a gas (synthesis gas, also 35 referred to as syngas), which fuels the combined-cycle power generating units. Nearly 36 100 percent of the nitrogen from the syngas is removed before combustion in the gas turbines 37 and this results in lower nitrogen oxide emissions when compared to conventional coal fired 38 power plants (DOE 2010). 39 Although several smaller, integrated gasification combined-cycle power plants have been in 40 operation since the mid-1990s, more recent large-scale projects using this technology have 41 experienced a number of setbacks and opposition that have hindered the technology from fully 42 integrating into the energy market. The most significant roadblock has been the high capital 43 cost of an integrated gasification combined-cycle power plant as compared to conventional coal-44 fired power plants. Both the Duke Energy Edwardsport Generation Station project in Indiana 45 and the Kemper County integrated gasification combined-cycle project in east central 2-18

1 Mississippi have experienced cost and schedule overruns. The Kemper County project 2 suspended work towards startup of the gasifier component in June 2017 (Energy Daily 2017). 3 Other issues associated with integrated gasification combined cycle include a limited track 4 record for reliable performance and opposition based on environmental concerns. In its 5 environmental report, FPL states that it currently has no plans to add new coal-fired generation 6 to its energy production portfolio (FPL 2018f). Based upon these considerations, the NRC staff 7 concludes that coal-fired technologies do not provide a reasonable source of baseload power to 8 replace Turkey Point Units 3 and 4 by the time their current licenses expire in 2032 and 2033. 9 2.3.11 Fuel Cells 10 Fuel cells oxidize fuels without combustion and therefore without the environmental side effects 11 of combustion. Fuel cells use a fuel (e.g., hydrogen) and oxygen to create electricity through an 12 electrochemical process. The only byproducts are heat, water, and carbon dioxide (depending 13 on the hydrogen fuel type) (DOE 2013b). Hydrogen fuel can come from a variety of 14 hydrocarbon resources. Natural gas is a typical hydrogen source. 15 Fuel cells are not economically or technologically competitive with other alternatives for 16 electricity generation. The U.S. Energy Information Administration estimates that fuel cells may 17 cost $7,108 per installed kilowatt (total overnight capital costs in 2012 dollars), which is high 18 compared to other alternative technologies analyzed in this section (EIA 2013b). More 19 importantly, fuel cell units are likely to be small in size (approximately 10 MW). The worlds 20 largest fuel cell facility is a 59 MWe plant that came online in South Korea in 2014 (PEI 2017). 21 Using fuel cells to replace the power that Turkey Point provides would be extremely costly. It 22 would require the construction of approximately 150 average-sized units and modifications to 23 the existing transmission system. Given the immature status and high cost of fuel cell 24 technology, the NRC staff does not consider fuel cells to be a reasonable alternative to Turkey 25 Point subsequent license renewal. 26 2.3.12 Purchased Power 27 It is possible that replacement power may be imported from outside the Turkey Point region of 28 influence. Although purchased power would likely have little or no measurable environmental 29 impact in the vicinity of Turkey Point, impacts could occur where the power is generated or 30 anywhere along the transmission route, depending on the generation technologies used to 31 supply the purchased power (NRC 2013a). 32 As discussed in its report, 2018-2027 Ten Year Power Plant Site Plan, FPL purchases power 33 from generation sources outside of its service area (FPL 2018g). In 2016 and 2017, FPL 34 purchased 826 MW of firm capacity generation from other such facilities. However, two 35 coal-fired units at the St. Johns River Power Park, in Jacksonville, FL, which provided 382 MW 36 of FPLs purchased power, retired in January 2018 (FPL 2018f, FPL 2018g). FPL also projects 37 that it will cancel a 330 MW purchase power agreement with a separate coal-fired facility by 38 2020 because it is no longer cost-effective. Overall, FPLs firm capacity purchases are 39 expected to average only 250 MW over the next decade (FPL 2018g). 40 Additionally, purchased power is generally economically adverse because the cost of generated 41 power historically has been less than the cost of the same power provided by a third party 42 (NRC 2013a). Power purchase agreements also carry the inherent risk that the other plant will 43 not deliver the contracted power. 2-19

1 Based on these considerations, the NRC staff concludes that purchased power does not 2 provide a reasonable alternative to Turkey Point subsequent license renewal. 3 2.3.13 Delayed Retirement 4 The retirement of a power plant ends its ability to supply electricity. Delaying the retirement of a 5 power plant enables it to continue supplying electricity. A delayed retirement alternative would 6 delay the retirement of generating facilities within or near the region of influence. 7 Power plant retirement occurs for several reasons. Because generators are required to adhere 8 to additional regulations that will require significant reductions in plant emissions, some power 9 plants may opt for early retirement of older units rather than incur the cost for compliance. 10 Additional retirements may be driven by low natural gas prices, slow growth in electricity 11 demand, and requirements of the Mercury and Air Toxics Standards (EIA 2015c, EPA 2015). 12 Most units that are near or past retirement age generate more pollutants and are less efficient 13 than new units. Often, utility owners retire units because operation is no longer economical. In 14 some cases, the cost of environmental compliance or necessary repairs or upgrades are too 15 great to justify continued operation. 16 FPL reviews its existing fleet for cost-effective opportunities to modernize the fleet and extend 17 operations, as well as to evaluate the need to close older inefficient plants. In its 2018-2027 18 Ten Year Power Plant Site Plan, FPL identifies the companys intention to retire two large 19 (approximately 800 MW) generating units at its Martin facility by 2019. These units have been 20 in operation for nearly 40 years and are relatively inefficient. FPL is in the process of 21 modernizing several of its gas-fired generation facilities within its service area, and these 22 ongoing efforts will only partially offset the loss of the Martin units (FPL 2018g). However, FPL 23 has not identified opportunities within its existing fleet that would provide for the replacement of 24 Turkey Points net generation (FPL 2018f). 25 Because of these conditions, the NRC staff concludes that delayed retirement does not provide 26 a reasonable alternative to Turkey Point subsequent license renewal. 27 2.4 Comparison of Alternatives 28 In this chapter, the NRC staff considered in depth one alternative to Turkey Point subsequent 29 license renewal that does not replace the plants energy generation (the no-action alternative) 30 and three alternatives to subsequent license renewal that may reasonably replace Turkey 31 Points energy generation. These three replacement power alternatives are (1) new nuclear 32 generation, (2) natural gas combined-cycle generation, and (3) a combination of natural gas 33 combined-cycle generation and solar photovoltaic generation. The environmental impacts of 34 the proposed action and of the alternatives are described and assessed in Chapter 4. Table 2-2 35 summarizes the environmental impacts of the three replacement power alternatives to Turkey 36 Point subsequent license renewal. 37 The environmental impacts of the proposed action (subsequent renewal of the Turkey Point 38 operating licenses) would be SMALL for all impact categories except for groundwater resources 39 and aquatic resources. The impacts to groundwater resources range from SMALL to 40 MODERATE because of groundwater use conflicts and because the site-specific impacts of the 41 Category 1 Issue, Groundwater Quality Degradation (Plants with Cooling Ponds in Salt 42 Marshes), are assessed as MODERATE for current and continued operations during the initial 2-20

1 license renewal term but are projected to be SMALL during subsequent license renewal. Due to 2 impingement, entrainment, and thermal impacts on the aquatic organisms in the canal cooling 3 system, the impact of the Turkey Point subsequent license renewal to aquatic resources would 4 be SMALL to MODERATE. 5 In comparison, each of the three reasonable replacement power alternatives have 6 environmental impacts in at least two resource areas that are greater than the environmental 7 impacts of the proposed action of subsequent license renewal. In addition, the replacement 8 power alternatives also involve the environmental impacts inherent to new construction projects. 9 If the NRC adopts the no-action alternative and does not issue subsequent renewed licenses for 10 Turkey Point, energy-planning decisionmakers would likely implement one of the three power 11 replacement power alternatives discussed in-depth in this chapter. Based on the NRC staffs 12 review of these three replacement power alternatives, the no-action alternative, and the 13 proposed action, the staff concludes that the environmentally preferred alternative is the 14 proposed action of subsequent license renewal. Therefore, the NRC staff proposes to 15 recommend that the NRC issue subsequent renewed operating licenses for Turkey Point 16 Units 3 and 4. 2-21

1 Table 2-2 Summary of Environmental Impacts of the Proposed Action and Alternatives Turkey Point Combination Subsequent Alternative License Natural Gas (Natural Gas Renewal Combined- Combined-Cycle Cooling Water Impact Area (Proposed No-Action New Nuclear Cycle and Solar System (Resource) Action) Alternative Alternative Alternative Photovoltaic) Alternative Land Use SMALL SMALL SMALL to SMALL to SMALL to LARGE SMALL MODERATE MODERATE Visual Resources SMALL SMALL SMALL to SMALL to SMALL to LARGE SMALL to MODERATE MODERATE MODERATE Air Quality SMALL SMALL SMALL SMALL to SMALL to SMALL MODERATE MODERATE Noise SMALL SMALL SMALL to SMALL to SMALL to SMALL to MODERATE MODERATE MODERATE MODERATE Geologic Environment SMALL SMALL SMALL SMALL MODERATE SMALL Surface Water Resources SMALL SMALL SMALL SMALL SMALL SMALL 2-22 Groundwater Resources SMALL to SMALL SMALL SMALL SMALL SMALL MODERATE Terrestrial Resources SMALL SMALL MODERATE MODERATE MODERATE MODERATE Aquatic Resources SMALL to SMALL MODERATE MODERATE to MODERATE to MODERATE MODERATE to LARGE LARGE LARGE Special Status Species and See Note(a) See Note(b) See Note(b) See Note(b) See Note(b) See Note(b) Habitats Historic and Cultural Resources See Note(c) See Note(d) See Note(e) See Note(e) See Note(f) See Note(e) Socioeconomics SMALL SMALL SMALL to SMALL SMALL SMALL MODERATE Transportation SMALL SMALL SMALL to SMALL to SMALL to SMALL to LARGE MODERATE MODERATE MODERATE Human Health SMALL(g) SMALL(g) SMALL(g) SMALL(g) SMALL(g) SMALL(g) Environmental Justice See Note(h) See Note(i) See Note(j) See Note(j) See Note(k) See Note(j) Waste Management and Pollution SMALL(l) SMALL(l) SMALL (l) SMALL SMALL SMALL Prevention

Turkey Point Combination Subsequent Alternative License Natural Gas (Natural Gas Renewal Combined- Combined-Cycle Cooling Water Impact Area (Proposed No-Action New Nuclear Cycle and Solar System (Resource) Action) Alternative Alternative Alternative Photovoltaic) Alternative (a) The NRC staff concludes that the proposed Turkey Point subsequent license renewal is likely to adversely affect the American crocodile and the eastern indigo snake and may result in adverse modification to designated critical habitat for the American crocodile. The proposed action may affect, but is not likely to adversely affect, the Florida bonneted bat, Florida panther, West Indian manatee, red knot, piping plover, wood stork, Everglades snail kite, Kirtlands warbler, Blodgetts silverbush, Cape Sable thoroughwort, Florida semaphore cactus, sand flax, Florida bristle fern, loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and smalltooth sawfish. The proposed action would result in no adverse modification to designated critical habitat of the West Indian manatee. The proposed action would have no adverse effects on Essential Fish Habitat. The evaluation of impacts to species and habitats under the U.S. Fish and Wildlife Services jurisdiction can be found in the NRCs Biological Assessment (NRC 2018n). The evaluation for species and habitats under the National Marine Fisheries Services jurisdiction can be found in Section 4.8. (b) The types and magnitudes of adverse impacts to species listed pursuant to the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.), designated critical habitat, and Essential Fish Habitat would depend on Turkey Point shutdown activities, the proposed alternative site, plant design, and operation, as applicable, and on the listed species and designated critical habitats present when the alternative is implemented. Therefore, the NRC staff cannot forecast a particular level of impact for this alternative. (c) Based on (1) the location of National Register of Historic Places-eligible historic properties within the area of potential effect, (2) tribal input, (3) FPLs cultural resource protection plans, (4) the fact that no license renewal-related physical changes or ground-disturbing activities would occur, (5) Florida State 2-23 Historic Preservation Office input, and (6) cultural resource assessment, license renewal would not adversely affect any known historic properties (Title 36 of the Code of Federal Regulations 800.4(d)(1), No Historic Properties Affected). (d) As a result of facility shutdown, land-disturbing activities or dismantlement are not anticipated as these would be conducted during decommissioning. Therefore, facility shutdown would have no immediate effect on historic properties or historic and cultural resources. (e) Since the alternative would be located at the Turkey Point site, which has a low archeological potential, and avoidance of significant resources would be possible, this alternative would not adversely affect known historic properties. (f) The impacts from the construction and operation of the solar component would depend on where solar facilities are constructed. The historic and cultural resource impact could range from no adverse effect to adverse effect. (g) The chronic effects of electromagnetic fields on human health associated with operating nuclear power and other electricity generating plants are uncertain. (h) There would be no disproportionately high and adverse impacts to minority and low-income populations. (i) A reduction in tax revenue resulting from the shutdown of Turkey Point could decrease the availability of public services in the Turkey Point area. However, the effects to minority and low-income populations would not be disproportionately high and adverse. (j) Based on the analysis of human health and environmental impacts presented in this SEIS, the location of the alternative, and the assumed alternative design and characteristics, this alternative would not likely have disproportionately high and adverse human health and environmental effects on minority and low-income populations. (k) This alternative would not likely have disproportionately high and adverse human health and environmental effects on minority and low-income populations. However, this determination would depend on the location of the solar facilities. Therefore, the NRC staff cannot determine whether the solar portion of the combination alternative would result in disproportionately high and adverse human health and environmental effects on minority and low-income populations. (l) NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel, (NRC 2014c) discusses the environmental impact of spent fuel storage for the timeframe beyond the licensed life for reactor operations.

1 3 AFFECTED ENVIRONMENT 2 In conducting its environmental review of the Turkey Point Nuclear Generating Unit 3 Nos. 3 and 4 (Turkey Point, or Turkey Point Units 3 and 4) subsequent license renewal 4 application, the U.S. Nuclear Regulatory Commission (NRC) first defines and describes the 5 environment that could be affected by the subsequent license renewal. For this review, the 6 NRC staff defines the affected environment as the environment that currently exists at and 7 around the Turkey Point site. Because existing conditions are at least partially the result of past 8 construction and operations at the plant, this chapter presents the nature and impacts of these 9 past actions as well as ongoing actions, and evaluates how, together, these actions have 10 shaped the current environment. The effects of ongoing reactor operations at Turkey Point 11 have become well established as environmental conditions have adjusted to the presence of the 12 nuclear power plant. Sections 3.2 through 3.13 describe the affected environment for each 13 resource area. The resource discussions in this chapter include new and updated information 14 that became available since the NRC issued the supplemental environmental impact statement 15 (SEIS) for the initial Turkey Point license renewal in 2002, as NUREG-1437, Supplement 5 16 (NRC 2002c). 17 3.1 Description of Nuclear Power Plant Facility and Operation 18 The physical presence of Turkey Point buildings and facilities, as well as the plants operations, 19 are integral to the environment that currently exists at and around the site. This section 20 describes Turkey Point buildings, certain nuclear power plant operating systems, and certain 21 plant infrastructure, operations, and maintenance. 22 3.1.1 External Appearance and Setting 23 Turkey Point is located on the southeastern coast of Florida in unincorporated southeastern 24 Miami-Dade County. The site borders Biscayne Bay and Card Sound. Turkey Point is 25 approximately 25 miles (mi) (40 kilometers (km)) south-southwest of the city of Miami, which is 26 the largest population center in the region with an estimated population of 424,632. Portions of 27 Homestead Air Reserve Base and the cities of Florida City and Homestead are located within 28 approximately 9 mi (14.5 km) of the Turkey Point site. Miami, Florida City, Homestead, 29 Homestead Air Reserve Base, and Turkey Point are all located in Miami-Dade County, FL. 30 Florida City is located approximately 9 mi (14.5 km) west of Turkey Point and has an estimated 31 population of 12,000. The city of Homestead is located approximately 9 mi (14.5 km) 32 west-northwest of Turkey Point and has an estimated population of 65,000. Homestead Air 33 Reserve Base is located approximately 6 mi (9.7 km) northwest of Turkey Point and has an 34 estimated population of 1,100 (FPL 2018f). 35 Turkey Point Units 3 and 4 are two pressurized-water nuclear reactors located on approximately 36 9,460 acres (ac) (38.3 kilometers squared (km2)) of FPL-owned land. In addition to nuclear 37 generating Units 3 and 4, the Turkey Point site also houses three fossil fuel power plants: 38 Units 1 and 2 are retired, natural-gas/oil steam-generating units; and Unit 5 is an operating, 39 natural-gas combined-cycle steam generating unit. In addition to these five currently operating 40 and retired units, the Turkey Point site also features a 5,900-ac (24 km2) artificial body of water 41 called the cooling canal system (CCS). This network of canals forms a closed, recirculating 42 source of water that is used by Units 3 and 4 for reactor heat rejection. Unit 5 does not use the 43 cooling canals for heat rejection but does use the CCS for stormwater discharge and cooling 44 water blowdown. The principal structures for Turkey Point Units 3 and 4 are the reactor 3-1

1 containments, auxiliary building, control building, turbine building, radioactive waste 2 management building, intake structure, discharge structures, steam generator storage 3 compound, and administration building. The main structures outside the power block are an 4 independent spent fuel storage installation (ISFSI), a sewage treatment plant, a 230-kilovolt (kV) 5 switchyard, a meteorological tower, the cooling water intake canal, the cooling water discharge 6 canal, and the 5,900-ac (24 km2) network of cooling canals between them (FPL 2018f). 3-2

1 Figure 3-1 Map Showing the 50-mi (80-km) Radius Around the Turkey Point Site 2 (FPL 2018f) 3-3

1 3.1.2 Nuclear Reactor Systems 2 Turkey Point Units 3 and 4 are Westinghouse, three-loop pressurized-water reactors (PWRs) 3 with dry, ambient pressure containments. The NRCs predecessor agency, the Atomic Energy 4 Commission, issued the Turkey Point Unit 3 facility operating license on July 19, 1972 and the 5 Unit 4 facility operating license on April 10, 1973. Subsequently, on June 6, 2002, the NRC 6 issued renewed facility operating licenses for Turkey Point Units 3 and 4, authorizing an 7 additional 20 years of operation (NRC 2002b). Turkey Point Units 3 and 4 are each rated for a 8 reactor core power level of 2,644 megawatts thermal (MWt) (FPL 2018f). Together, Units 3 and 9 4 produce a combined total of 1,632 megawatts electric (MWe) (FPL 2018f). 10 Both the Unit 3 and Unit 4 reactor cores are composed of uranium dioxide pellets enclosed in 11 Zircaloy-4, ZIRLO, Optimized ZIRLO' high-performance fuel cladding material tubes with 12 welded end plugs. A spring clip grid structure supports the tubes in assemblies. The 13 mechanical control rods consist of clusters of stainless steel-clad absorber rods and guide tubes 14 located within the fuel assemblies (FPL 2018f). 15 3.1.3 Cooling and Auxiliary Water Systems 16 As mentioned earlier, Turkey Point Units 3 and 4 are both PWRs. PWRs heat water under 17 pressure to very high temperatures to create steam. That steam turns the turbines that then 18 generate electricity. PWRs use a closed-cycle cooling system to dissipate the heat in the water. 19 The closed-cycle cooling system uses three heat exchange loops to cool the water: (1) the 20 primary coolant loop, (2) the secondary loop, and (3) the cooling water loop. These are as 21 follows. 22 Primary Coolant Loop: In the primary coolant loop, water is drawn into the reactor and heated to 23 very high temperatures while under great pressure. The pressure keeps the water from turning 24 into steam. Water in the primary loop that has been heated in the reactor passes through a 25 steam generator where heat is transferred to water in a secondary loop. Once the heat is 26 transferred, the water in the primary coolant loop returns to the reactor to be heated again under 27 high pressure. 28 Secondary Loop: In the heat transfer process, the water in the primary loop and the water in the 29 secondary loop do not come into contact with each other. In the steam generator, the heated 30 water in the secondary loop is allowed to flash into steam, which is what drives the turbines that 31 in turn produce electricity. The water in the secondary loop (now in steam form), then travels to 32 the condenser where it transfers its heat energy to water in the third loop (called the cooling 33 water loop). When heat is transferred, the water temperature decreases and the steam water in 34 the secondary loop condenses back to liquid water. The liquid water in the secondary loop then 35 returns to the steam generator to be reheated. 36 Cooling Water Loop: As is the case with the transfer of heat between the primary coolant loop 37 and the secondary loop, in the condenser, the water in the secondary loop and the water in the 38 cooling water loop do not come into contact with one another. From the condenser, water in the 39 cooling water loop (third loop) can either flow to cooling towers (not present for Units 3 and 4) 40 where it is cooled by evaporation or it can be discharged directly to an external body of water 41 (NRC 2013a). Figure 3-2 below shows a simple schematic diagram of a generic PWR cooling 42 system with a cooling canal system. At Turkey Point, water from the cooling water loop is 43 discharged into a closed body of water called the cooling canal system (CCS). 3-4

1 The sections below describe in greater detail the cooling water loop, the CCS, the auxiliary 2 cooling water system, the fire protection water system, and the potable water system at Turkey 3 Point. Unless otherwise cited herein, the NRC staff drew information about Turkey Points 4 cooling and auxiliary water systems from the following sources: FPLs environmental report that 5 it submitted as part of the subsequent license renewal application (FPL 2018f), the NRC staffs 6 2002 SEIS for the initial Turkey Point license renewal published as NUREG-1437, 7 Supplement 5 (NRC 2002c), and the NRC staffs onsite environmental audit at Turkey Point in 8 June 2018. 9 Source: Modified from NRC 2013a 10 Figure 3-2 Generic Cooling System with Cooling Canal System 11 3.1.3.1 General Description of Cooling Water Loop 12 In a PWR closed-cycle cooling system, the primary function of the third loopthe cooling water 13 loopis to transport heat from inside the reactor to the outside environment. At Turkey Point, 14 the cooling water loop withdraws water from an artificially constructed body of water called the 15 cooling canal system (CCS) and discharges water back to the CCS. As described earlier in this 16 chapter, the CCS is a large body of water comprised of a network of canals spread over about 17 5,900 ac (24 km2). As with the rest of the Turkey Point site, FPL does not allow the public to 18 access the CCS. The CCS does not connect to any other surface water bodies. It is an 19 industrial wastewater (IWW) facility under the Clean Water Act and is not considered waters of 20 the United States or waters of the State (Figure 3-3). 21 The reactors discharge heated water from the cooling water loop into the discharge canal of the 22 CCS. From the discharge canal, the heated water travels through the length of the canal and 23 loses heat through evaporation. By the time the water returns to the Units 3 and 4 cooling water 24 intake canal, it is lower in temperature than when it was discharged. From the cooling water 25 intake canal, some water is pumped back into the cooling water loop where it is used to 26 dissipate heat from the secondary loop so that the steam water in the secondary loop 27 condenses back into liquid water. 28 Figure 3-3 illustrates the location where the Units 3 and 4 discharge structure releases heated 29 water into the CCS, the direction of water flow through the CCS, and the location where the 3-5

1 Units 3 and 4 intake structure draws cooling water from the CCS. Section 3.1.3.2, Cooling 2 Canal System (CCS), discusses the CCS and its operation in greater detail. 3 At the Units 3 and 4 cooling water intake structure, water from the CCS flows through bars that 4 prevent large objects from entering the intake structure. Then, the water flows through steel 5 trash racks and into four separated screen wells. The trash racks protect vertical traveling 6 screens against damage from heavy debris. The traveling screens have a 0.38-in (1-cm) mesh 7 size to remove smaller debris. The water then flows to one of four circulating water pumps. 8 The intake structure also contains three pumps that supply water to the condenser. Under 9 normal plant operating conditions, either one, two, or all three of these pumps may be in 10 operation. Inside the cooling water tubes of the condenser, plastic foam balls minimize 11 biological growth and other fouling. 12 The combined intake of water at the Turkey Point intake structure is 1,872 million gallons per 13 day (mgd) (7 million m3/day). This water is discharged back to the CCS where it is recirculated 14 for reuse again as cooling water. 3-6

1 Source: FPL 2018f 2 Figure 3-3 Flow of Water Through the Cooling Canal System 3 FPL originally built the CCS to service its fossil-fueled units and nuclear generating units. The 4 CCS currently services two nuclear generating units (Units 3 and 4), two retired fossil-fueled 5 units (Units 1 and 2), and one currently operating fossil-fueled unit (Unit 5) in varying capacities. 6 The NRC does not license the operation of the fossil-fueled units. 3-7

1 Historically, the CCS was also part of the cooling water system for Units 1 and 2. The CCS 2 functioned for them as it does for Units 3 and 4. As mentioned earlier, FPL retired Units 1 3 and 2, so these units no longer generate electricity. However, these retired units still circulate 4 water from the CCS (i.e., discharge water into and withdraw water from the CCS). FPL has 5 placed both units into synchronous condenser mode, which means they support transmission 6 reliability and help to stabilize and optimize electrical grid performance. FPL plans to continue 7 operating Units 1 and 2 in this mode through the period of subsequent license renewal. While in 8 synchronous condenser mode, Units 1 and 2 circulate 17.3 mgd (65,488 m3/day) of water from 9 the CCS. As Units 1 and 2 no longer produce steam, unlike Units 3 and 4, they no longer 10 discharge heated water to the CCS. 11 Unit 5 is a currently operating fossil fuel power plant that produces electricity through natural-12 gas combined-cycle steam generation. It uses four natural gas turbines and one heat-recovery 13 steam-powered generator. It does not use the CCS as part of its cooling water system. 14 Instead, Unit 5 uses cooling towers and obtains water for cooling from groundwater from the 15 Upper Floridan aquifer (see Section 3.5, Groundwater Resources). Heat generated by Unit 5 16 is lost to the atmosphere by the evaporation of water in the plants cooling towers. 17 While Unit 5 does not use the CCS for cooling, it does discharge blowdown water from its 18 cooling towers into the CCS. Blowdown water is produced as a result of the evaporation of 19 water in the cooling tower. Evaporation causes the mineral content of the remaining water that 20 does not evaporate to increase. Blowdown is produced by draining water with high mineral 21 concentrations from the cooling tower and replacing it with fresh water. Blowdown from Unit 5 22 cooling towers does not contribute heat to the CCS. At 10,000 gallons per day (gpd) 23 (38 m3/day), the volume of blowdown water discharged from Unit 5 to the CCS is relatively 24 small. 25 3.1.3.2 Cooling Canal System (CCS) 26 This section describes the physical dimensions of the CCS and its operation. 27 Layout of the Cooling Canal System 28 The CCS covers an area approximately 2-mi (3.2-km) wide by 5-mi (8-km) long and covers an 29 area of approximately 5,900 ac (24 km2). It was built to act as a cooling reservoir for Units 1, 2, 30 3, and 4 and as an industrial wastewater facility for liquid discharges from all operations at the 31 Turkey Point site. As previously described, while water from the CCS is circulated through 32 Units 1 and 2, only Units 3 and 4 now use the CCS for cooling. The CCS receives heated water 33 from Units 3 and 4 and distributes the water into 32 feeder channels (canals). Water in the 34 feeder channels flows south into a single collector channel that distributes water to seven return 35 channels (Figure 3-4). As the water flows through the channels, heat is lost, largely through 36 evaporation. Water in the return channels flows north where it is used to cool Units 3 and 4. 37 Units 3 and 4 return heated water to the CCS to repeat the cycle. Flows through the CCS are 38 approximately 1.3 million gallons per minute (gpm) (4.9 million liters per minute (Lpm)) 39 (FPL 2018f). 40 Prior to the construction of Units 3 and 4, the cooling system for Units 1 and 2 used a cooling 41 system with a once-through design. It withdrew water from and discharged water to Biscayne 42 Bay. However, a 1971 consent decree by the Federal District Court for the Southern District of 43 Florida (United States v. Florida Power and Light Company) required FPL to discharge all 44 cooling water from Turkey Point facilities into a closed-cycle cooling canal system. To comply 3-8

1 with this decree, FPL designed and constructed the CCS and ensured that it had no surface 2 water connection to any outside water body (i.e., Biscayne Bay or Card Sound) (NRC 2016a). 3 The CCS then replaced the previous Units 1 and 2 once-through cooling system. 4 The CCS consists of interconnected channels excavated into the underlying bedrock. The 5 bedrock is limestone and forms the top of the Biscayne aquifer. It is important to note that the 6 CCS is not built up above the land surface; instead, it was excavated into the bedrock. Water 7 levels in the channels are below the level of the land surface and below the top of the bedrock 8 (i.e., below the top of the Biscayne aquifer). Therefore, the limestone rock of the Biscayne 9 aquifer forms the bottom and sides of the CCS. 10 Perimeter berms surround the CCS. These berms are constructed on top of the bedrock and do 11 not contact the water in the CCS. They vary in height from 4 to 10 ft (1.2 to 3 m) above the 12 surface of the bedrock. The widths of the perimeter berms vary from 25 feet to well over 13 100 feet (7.6 m to 30.5 m) with an average width of more than 50 ft (15.2 m). The perimeter 14 berms are not in contact with water within the CCS. As mentioned previously, the water in the 15 CCS is below the top of the bedrock, while the perimeter berms are built on top of the bedrock. 16 The berms are not designed and built to contain CCS water; rather, these berms are designed 17 and built to prevent surface water from entering the CCS. 18 Most of the channels within the CCS are about 200 feet (60 m) wide and have a water depth of 19 1 to 3 feet (0.3 to 1 m). The average canal depth is 2.8 ft (0.85 m) (FPL 2018f). They are 20 separated by 90 foot (27 m) wide berms (NRC 2002c). A few of the channels within the CCS 21 have been excavated to a depth of approximately 20 ft (6.1 m). These deep channels are: 22

• The east-west distribution channel along the north side of the CCS 23
• The east-west collection channel along the south side of the CCS 24
• The north-south channel within the CCS, originally built to discharge water to Card 25 Sound 26
• The north-south channel along the east side of the CCS 27
• A few channels in the northeast corner of the CCS that connect to the intake basin 28 (Golder 2008, Morgan & Eklund 2010) 29 When the CCS was constructed, the previous canals that functioned as intake and discharge 30 canals into Biscayne Bay or Card Sound were either incorporated into the CCS or excluded 31 from it. Those previous canals that were excluded from the CCS have now become remnant 32 dead-end canals. The Barge Turning Basin in Biscayne Bay was walled off from the CCS.

33 Earthen plugs were installed between the CCS and the remnant dead end canals. Within the 34 plugs in the Turtle Point remnant canal that connects to Biscayne Bay and in the Card Sound 35 remnant canal that connects to Card Sound (see Figure 3-4), cement and bentonite slurry walls 36 have been constructed to prevent water seepage through them. In addition, both sides of these 37 plugs are protected with a layer of limestone rock to prevent surface erosion of the plug. The 38 Turtle Point remnant canal plug varies in width from 25 to 40 ft (7.6 to 12 m) and the Card 39 Sound remnant canal plug varies in width from 25 to 50 ft (7.6 to 15 m) (FPL 2016f). 40 In addition to the channels (canals) within the CCS, an interceptor ditch is located outside and 41 against the west side of the CCS. The ditch is not connected to the CCS or other surface 42 waters. However, it is a part of CCS operations. It parallels the entire length of the west side of 43 the CCS. It is constructed to a depth of approximately 18 ft (5.5 m) (Golder 2008). The purpose 3-9

1 of the interceptor ditch is to limit the amounts of saline groundwater that move from beneath the 2 CCS to areas west of the Canal L-31E Levee, to those amounts which would have moved to 3 those areas if the CCS did not exist (Figure 3-4) (FPL 2018f). 4 Source: Modified from SFWMD 2011a 5 Figure 3-4 Cooling Canal System and Adjacent Canals 3-10

1 Depending on the head levels (water levels) in the Biscayne aquifer relative to the head levels in 2 Biscayne Bay, groundwater beneath and around the Turkey Point site can either flow towards 3 the bay (east) or inland away from the bay (west). During wet times of the year, when 4 groundwater levels are high, groundwater flow is usually towards the bay. During dry times of 5 the year, when groundwater levels are low, groundwater flow is usually inland away from the 6 bay. 7 When surface water and groundwater monitoring data around the Turkey Point site indicate that 8 there is a potential for groundwater to flow inland (west), water is pumped from the interceptor 9 ditch and discharged into the CCS. This causes near-surface groundwater to flow towards the 10 interceptor ditch and captures near-surface groundwater below the CCS that is moving west 11 (FPL 2018f). The capture effect is likely limited to the depth of the interceptor ditch, which, at a 12 depth of about 18 ft (5.5 m), is a little deeper than the bottom of the L-31E Canal (Golder 2008). 13 Cooling Canal System Operation 14 Units 3 and 4 discharge heated water into the CCS. As this water travels through the length of 15 the CCS, it loses heat through evaporation. Evaporation not only removes heat from the water 16 in the CCS, but it also removes some of the water. Water lost through evaporation is replaced 17 by three main sources. The single largest contributor of new water to the CCS is water from 18 precipitation (e.g., rain). Historically, the second largest contributor has been saltwater from the 19 Biscayne aquifer that seeps into the CCS through the limestone bedrock. However, more 20 recently, a different water source has likely overtaken Biscayne aquifer seepage as the second 21 largest contributor of new water to the CCS. Specifically, as further discussed in 22 Section 3.5.2.3, Groundwater Use, brackish water supplied by FPLs wells that withdraw water 23 from the Floridan aquifer is likely a larger contributor of new water to the CCS than is provided 24 by the seepage of water from the Biscayne aquifer. 25 The CCS receives relatively minor additions of water from discharges from the interceptor ditch 26 and Unit 5 cooling tower blowdown. In extraordinary circumstances, FPL may add water to the 27 CCS from wells (marine wells near Biscayne Bay) that withdraw saltwater from the Biscayne 28 aquifer (see Section 3.5.2.3 for more detail). However, FPL seldom uses these marine wells 29 (FPL 2018f). 30 As mentioned earlier in this chapter, water in the CCS is not in contact with other surface water 31 bodies. However, the water in the CCS is in direct contact with the Biscayne aquifer and with 32 earthen plugs located in the perimeter of the CCS. These plugs seal off remnant canals from 33 the water in the CCS (FPL 2018f). As the Biscayne aquifer is highly permeable, water would be 34 more readily transmitted through it than through the relatively small areas occupied by the low 35 permeability earthen plugs on the perimeter of the CCS. The perimeter berms are not a likely 36 pathway for water to seep from the CCS as they are not in contact with the CCS water. 37 Not only does water leave the CCS by evaporation, some of the water also leaves the CCS 38 through the Biscayne aquifer. However, more water moves into the CCS from the Biscayne 39 aquifer than leaves the CCS to the Biscayne aquifer. FPL estimates that the inflow of 40 groundwater from the Biscayne aquifer into the CCS is about twice the volume of outflow of 41 water from the CCS into the Biscayne aquifer (FPL 2018f). 42 Sediments can build up in the channels of the CCS. These sediments can obstruct the lateral 43 flow of water through the CCS and can also lower the rate of water movement into the CCS 3-11

1 from the Biscayne aquifer. Therefore, CCS maintenance activities include the removal of 2 accumulated sediments as required to maintain adequate water flow in the CCS (FPL 2018f). 3 3.1.3.3 Auxiliary Cooling Water System 4 In addition to the cooling water loop, heat is also removed from Turkey Point operations by the 5 auxiliary cooling water system. This system is much smaller in its water requirements than the 6 cooling water loop. Auxiliary cooling water systems can include emergency core cooling 7 systems, containment spray and cooling systems, emergency feedwater systems, component 8 cooling water systems, and spent fuel pool water systems. At Turkey Point, the auxiliary cooling 9 water system consists of three loops: (1) the component cooling loop, (2) the residual heat 10 removal loop, and (3) the spent fuel pit cooling loop. These loops obtain water from the 11 Miami-Dade County public water supply system and discharge water to the CCS. 12 3.1.3.4 Fire Protection Water System 13 Fire protection water protects the plant in the event of a fire. At Turkey Point, the Miami-Dade 14 County public water supply system supplies the fire protection water as described below. 15 3.1.3.5 Potable Water System 16 Turkey Point uses approximately 1 mgd (3,800 m3/day of water from the Miami-Dade County 17 public water supply system. However, a water treatment plant, which supplies pure water for 18 steam-related use, was completed in 2017. This new plant has the ability to treat brackish 19 water at a rate of more than 1 mgd (3,800 m3/day from onsite wells that withdraw water from the 20 Upper Floridan aquifer (see Section 3.5.2.3, Groundwater Use). This will significantly reduce 21 the volume of potable water that FPL needs to obtain from the Miami-Dade County public water 22 supply system. 23 Potable water is used by the auxiliary cooling water system, fire protection system, and drinking 24 water system. Turkey Point discharges treated waste-process waters into the CCS, and 25 domestic wastewater is sent to an onsite sewage treatment plant. After treatment, FPL 26 disposes of water from the sewage treatment plant into the Biscayne aquifer through an 27 injection well. Beneath the Turkey Point site, the Biscayne aquifer contains saltwater (see 28 Section 3.5.1.4, Adjacent Surface Water Quality and Cooling Canal System Operation). 29 3.1.4 Radioactive Waste Management Systems 30 As a result of normal operations, equipment repairs and replacements, and normal maintenance 31 activities, nuclear power plants routinely generate both radioactive and nonradioactive waste. 32 Nonradioactive waste includes hazardous and nonhazardous waste. There is also a class of 33 wastecalled mixed wastewhich is both radioactive and hazardous. This section describes 34 the systems that FPL uses to manage (i.e., treat, store, and dispose of) these wastes. This 35 section also discusses other waste minimization and pollution prevention measures commonly 36 employed at nuclear power plants. 37 The NRC licenses all nuclear plants with the expectation that they will release some radioactive 38 material to both the air and water during normal operations. However, NRC regulations require 39 that gaseous and liquid radioactive releases from nuclear power plants must meet radiation 40 dose-based limits specified in Title 10 of the Code of Federal Regulations (10 CFR) Part 20, 41 Standards for Protection Against Radiation, and the as-low-as-is-reasonably-achievable 3-12

1 (ALARA) criteria in 10 CFR Part 50, Appendix I, Numerical Guides for Design Objectives and 2 Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for 3 Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents. In other words, 4 the NRC places regulatory limits on the radiation dose that members of the public can receive 5 from a nuclear power plants radioactive effluents. For this reason, all nuclear power plants use 6 radioactive waste management systems to control and monitor radioactive wastes. 7 Turkey Point uses the waste disposal system, as needed, to collect and process radioactive 8 materials contained in liquid, gaseous, and solid waste produced as a byproduct of plant 9 operations. The waste disposal system ensures that the dose to members of the public from 10 radioactive effluents is reduced to levels that are ALARA in accordance with the NRCs 11 regulations. 12 Under an agreement between FPL and the Florida Department of Health (DOH), the DOH 13 Bureau of Radiation Control conducts the Turkey Point radiological environmental monitoring 14 program (REMP). Through the REMP, the Bureau of Radiation Control documents the 15 radiological impact, if any, to the public, site employees, and the environment from radioactive 16 effluents released during operations at Turkey Point. Section 3.1.4.5 below discusses the 17 REMP in more detail. 18 FPL uses its Offsite Dose Calculation Manual (ODCM) that contains the methods and 19 parameters for calculating offsite doses resulting from liquid and gaseous radioactive effluents. 20 These methods ensure that radioactive material discharges from Turkey Point meet NRC and 21 U.S. Environmental Protection Agency (EPA) regulatory dose standards. The ODCM also 22 contains the requirements for the REMP (FPL 2018f). 23 3.1.4.1 Radioactive Liquid Waste Management 24 FPL uses waste management systems to collect, analyze, and process radioactive liquids 25 produced at Turkey Point. These systems reduce radioactive liquids before they are released to 26 the environment. The Turkey Point Units 3 and 4 waste disposal system meets the design 27 objectives of 10 CFR Part 50, Appendix I, and controls the processing, disposal, and release of 28 radioactive liquid, gaseous, and solid wastes. 29 The plant collects liquid radioactive waste in sumps and tanks in the waste disposal system. 30 Plant personnel then sample and analyze these collected liquid wastes to determine the level of 31 radioactivity and to determine if subsequent treatment is necessary. Personnel then process 32 the liquid radioactive wastes as required by 10 CFR Part 20 and release them into the CCS 33 discharge streams. FPL uses radiation monitors and applies safety features for the discharge 34 stream to avoid releases in excess of 10 CFR Part 20 standards (FPL 2016i). 35 Radioactive liquid waste entering the waste holdup tanks (WHT) via gravity feed include 36 effluents from the chemistry laboratories, containment sumps, floor drains, showers, and other 37 miscellaneous sources which flow to waste and monitoring holdup tanks. The laundry waste is 38 segregated into one of two monitor tanks. In addition, other sources of liquid wastes include 39 Turkey Point steam generator blowdown and storm drains. These liquids are then pumped to 40 the waste monitor tank where the activity level is determined and recorded prior to discharge 41 through the radiation monitor. The chemical and volume control system (CVCS) receives 42 radwaste liquids from the reactor coolant loop drains, accumulators, and excess letdown. 3-13

1 According to FPLs environmental report submitted as part of the subsequent license renewal 2 application, liquid requiring cleanup before being discharged to the environment is processed by 3 the waste disposal demineralizer. Turkey Point routes the liquid from the waste disposal 4 demineralizer directly to one of the three radwaste facility waste monitor tanks or one of two 5 waste disposal system monitor tanks (FPL 2016i, Section 11.1.2). When one of the waste 6 monitor tanks is filled, it is isolated, recirculated, and sampled for analysis while one of the other 7 two tanks is in service. If analysis confirms the activity level is suitable for discharge, the liquid 8 is pumped through a flow meter and a radiation monitor and then released to the cooling canals 9 of the industrial wastewater facility. Otherwise, it can be returned to a waste holdup tank for 10 reprocessing (FPL 2016i, Section 11.1.2). Turkey Point monitors radioactive liquid discharge 11 from its systems to ensure that activity concentrations do not exceed regulatory limits. 12 FPLs use of these radioactive waste systems and the procedural requirements in the Offsite 13 Dose Calculation Manual ensure that the dose from radioactive liquid effluents at Turkey Point 14 complies with NRC and EPA regulatory dose standards. 15 FPL calculates dose estimates for members of the public using radioactive liquid and gaseous 16 effluent release data and atmospheric and aquatic transport models. Unit 3 and Unit 4 share 17 the liquid waste treatment system. Generally, FPL allocates all liquid releases on a 50/50 basis 18 to each unit. In addition, both units also share the gaseous releases from the shared gaseous 19 waste treatment system on a 50/50 basis. Turkey Points annual radioactive effluent release 20 reports contain a detailed presentation of the radioactive liquid and gaseous effluents released 21 from Turkey Point and the resultant calculated doses. The NRC staff reviewed 5 years of 22 radioactive effluent release data from 2013 through 2017 (FPL 2013b, 2014d, 2015a; 2016l, 23 FPL 2017e). A 5-year period provides a dataset that covers a broad range of activities that 24 occur at a nuclear power plant, such as refueling outages, routine operation, and maintenance 25 that can affect the generation of radioactive effluents. The NRC staff compared the data against 26 NRC dose limits and looked for indications of adverse trends (e.g., increasing dose levels) over 27 the period spanning from 2013 through 2017. Since the radioactive liquid effluents are released 28 from common areas shared by both Unit 3 and Unit 4, the resultant calculated doses presented 29 in the effluent release are divided in half to evaluate compliance with the Appendix I to 10 CFR 30 Part 50 dose criteria. The NRC staffs review of Turkey Points radioactive liquid effluent control 31 program showed that radiation doses to members of the public were controlled within the NRCs 32 and EPAs radiation protection standards contained in Appendix I to 10 CFR Part 50, 33 10 CFR Part 20, and 40 CFR Part 190. No adverse trends were observed in the dose levels. 34 Routine plant refueling and maintenance activities currently performed will continue during the 35 license renewal term. Based on the past performance of the radioactive waste system to 36 maintain doses from radioactive liquid effluents to be ALARA, similar performance is expected 37 during the license renewal term. The following summarizes the calculated doses from 38 radioactive liquid effluents released from Turkey Point Units 3 and 4 during the most recent 39 available year (2017): 40 Turkey Point Unit 3 in 2017 41

• The total-body dose to an offsite member of the public from Turkey Point Unit 3 42 radioactive effluents was 2.38x104 millirem (mrem) (2.38x106 millisievert (mSv)), which 43 is well below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50.

44

• The maximum organ dose (gastrointestinal tract) to an offsite member of the public from 45 Turkey Point Unit 3 radioactive effluents was 2.76x104 mrem (2.76x106 mSv), which is 46 well below the 10 mrem (0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50.

3-14

1 Turkey Point Unit 4 in 2017 2

• The total-body dose to an offsite member of the public from Turkey Point Unit 4 3 radioactive effluents was 2.38x104 millirem (mrem) (2.38x106 millisievert (mSv)), which 4 is well below the 3 mrem (0.03 mSv) dose criterion in Appendix I to 10 CFR Part 50.

5

• The maximum organ dose (gastrointestinal tract) to an offsite member of the public from 6 Turkey Point Unit 4 radioactive effluents was 2.76x104 mrem (2.76x106 mSv), which is 7 well below the 10 mrem (0.1 mSv) dose criterion in Appendix I to 10 CFR Part 50.

8 The NRC staffs review of FPLs radioactive liquid effluent control program shows that the 9 applicant maintained radiation doses to members of the public that were within NRCs and 10 EPAs radiation protection standards in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 11 Title 40, Protection of Environment, of the Code of Federal Regulations (40 CFR) Part 190, 12 Environmental Radiation Protection Standards for Nuclear Power Operations. The NRC staff 13 observed no adverse trends in the dose levels. 14 Routine plant refueling and maintenance activities at Turkey Point will continue during the 15 subsequent license renewal term. Based on FPLs past performance in operating a radioactive 16 waste system at Turkey Point that maintains ALARA doses from radioactive liquid effluents, the 17 NRC staff expects that FPL will maintain similar performance during the subsequent license 18 renewal term. 19 3.1.4.2 Radioactive Gaseous Waste Management 20 Radioactive gaseous waste generated at Turkey Point is collected, processed, and stored until 21 its radioactivity level is low enough to permit discharge to the environment at concentrations 22 below 10 CFR Part 20 standards (FPL 2016i, Section 1.2.4) through the waste disposal system. 23 Sources of the radioactive gaseous waste at Turkey point include gas decay tanks, containment 24 purges, the refueling water storage tank via the vent line, the Turkey Point equipment hatch 25 during outages, and releases incidental to plant operations. This radioactive gaseous waste is 26 created during plant operation from degassing reactor coolant discharge to the chemical and 27 volume control system, displacement of cover gases, miscellaneous equipment vents, relief 28 valves, and sampling operation and gas analysis for hydrogen and oxygen in cover gases. 29 Most of the gas received by the waste disposal system is cover gas displaced from the chemical 30 and volume control system holdup tanks as they fill with liquid. Gaseous waste is stored in 31 decay tanks for natural decay and is then released through the monitored plant vent. The cover 32 gas is reused to minimize the number of tank releases. The gaseous waste is monitored and 33 released at a permissible rate and activity as prescribed by the ODCM. Radioactive gaseous 34 effluents from Turkey Point Units 3 and 4 are released through four monitored release points: a 35 common plant vent via a stack above the containment building (~200 feet), the Unit 3 spent fuel 36 pit vent (~110 feet), and the condenser air ejector vents (~51 feet) from each unit. 37 Gases that are vented to the vent header flow to the waste gas compressor suction header. 38 One of two compressors is in continuous operation with the second unit instrumented to act as 39 backup for peak load conditions or failure of the first compressor. From the compressors, gas 40 flows to one of the gas decay tanks. Gas held in the decay tanks can either be returned to the 41 chemical and volume control system holdup tanks or discharged to the atmosphere via the plant 42 vent at a controlled rate through a radiation monitor if it has decayed sufficiently for release 43 (FPL 2016i, Section 11.1.2). The gases in the tanks are sampled and analyzed to determine 44 the radioactivity level. The radioactivity level contained in each gas decay tank is restricted 3-15

1 (1) to ensure that if an uncontrolled release of the tank's contents were to occur, the resulting 2 total body exposure to an individual at the exclusion area boundary would not exceed 3 500 mrem/yr (5 mSv/yr) and (2) to control the concentration of potentially explosive gases to 4 below flammability limits. The decay tanks are used to contain the compressed waste gases 5 (hydrogen, nitrogen, and fission gases) until they decay and are ready to be vented to the 6 atmosphere. 7 FPLs use of this gaseous radioactive waste system and adherence to the procedural 8 requirements in the ODCM ensure that the dose from radioactive gaseous effluents complies 9 with NRC and EPA regulatory dose standards. 10 As discussed above, FPL calculates dose estimates for members of the public using radioactive 11 liquid and gaseous effluent release data and atmospheric and aquatic transport models. Unit 3 12 and Unit 4 share the gaseous waste treatment system. The following summarizes the 13 calculated doses from radioactive gaseous effluents released from Turkey Point during 2017: 14 Turkey Point Unit 3 in 2017 15

• The air dose at the site boundary from gamma radiation in gaseous effluents from 16 Turkey Point Unit 3 was 1.30x105 millirad (mrad) (1.3x107 milligray), which is well 17 below the 10 mrad (0.1 milligray) dose criterion in Appendix I to 10 CFR Part 50.

18

• The air dose at the site boundary from beta radiation in gaseous effluents from Turkey 19 Point Unit 3 was 2.96x105 mrad (2.96x107 milligray) dose which is well below the 20 20 mrad (0.2 milligray) dose criterion in Appendix I to 10 CFR Part 50.

21

• The dose to an organ (thyroid) from radioactive iodine, radioactive particulates, and 22 carbon from Turkey Point Unit 3 was 1.01x101 mrem (1.01x10-3 mSv), which is below 23 the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50.

24 Turkey Point Unit 4 in 2017 25

• The air dose at the site boundary from gamma radiation in gaseous effluents from 26 Turkey Point Unit 4 was 9.02x106 mrad (9.02x108 milligray), which is well below the 10 27 mrad (0.1 milligray) dose criterion in Appendix I to 10 CFR Part 50.

28

• The air dose at the site boundary from beta radiation in gaseous effluents from Turkey 29 Point Unit 4 was 2.07x105 mrad (2.07x107 milligray) dose which is well below the 30 20 mrad (0.2 milligray) dose criterion in Appendix I to 10 CFR Part 50.

31

• The dose to an organ (thyroid) from radioactive iodine, radioactive particulates, and 32 carbon from Turkey Point Unit 4 was 1.19x101 mrem (1.19x10-3 mSv), which is below 33 the 15 mrem (0.15 mSv) dose criterion in Appendix I to 10 CFR Part 50.

34 The NRC staffs review of Turkey Points radioactive gaseous effluent control program showed 35 radiation doses to members of the public that were well below NRC and EPA radiation 36 protection standards contained in Appendix I to 10 CFR Part 50, 10 CFR Part 20, and 37 40 CFR Part 190. The NRC staff observed no adverse trends in the dose levels. 38 Routine plant refueling and maintenance activities at Turkey Point will continue during the 39 subsequent license renewal term. FPLs past performance operating the radioactive waste 40 system demonstrates that it is able to maintain ALARA doses from radioactive gaseous 3-16

1 effluents. Based on this record of past performance, the NRC staff expects that FPL will 2 maintain similar performance during the subsequent license renewal term. 3 3.1.4.3 Radioactive Solid Waste Management 4 At Turkey Point, low-level radioactive wastes (LLRW) are packaged and stored for subsequent 5 shipment and offsite burial under the plants waste disposal system. FPL packages Turkey 6 Point radioactive waste shipments in accordance with NRC requirements (10 CFR Part 71, 7 Packaging and Transportation of Radioactive Material), and U.S. Department of 8 Transportation (USDOT) requirements (Title 49, Transportation, of the Code of Federal 9 Regulations Part 173, ShippersGeneral Requirements for Shipments and Packagings, and 10 Part 178, Specifications for Packagings). 11 Under the waste disposal system, FPL packages all solid wastes in high-integrity containers 12 (HICs) for removal to disposal facilities. The HICs are designed to be placed into transfer casks 13 for shipment offsite for disposal. The HICs are also designed to be stored in the LLRW storage 14 facility while awaiting shipment offsite for disposal. The waste disposal system has been 15 designed as a waste process system, which includes demineralizers, monitor tanks, a 16 condensate tank, and associated pumps. Solid radioactive waste and potentially radioactive 17 wastes include spent resins, spent filters, and miscellaneous materials. Solid radioactive 18 wastes also include solids recovered from the reactor coolant system (RCS), solids in contact 19 with the liquids or gases associated with the reactor coolant process systems, and solids used 20 in support of the reactor coolant system operation. The largest volume of solid radioactive 21 waste is LLRW, which includes bead resin, spent filters, and dry active waste from outages and 22 routine maintenance. Turkey Point has developed long-term plans which ensure that 23 radioactive waste generated during the subsequent license renewal term will be sent directly for 24 disposal, stored onsite in existing structures, or shipped to an offsite licensed facility for 25 processing and disposal (FPL 2018f). 26 LLRW is classified as Class A, Class B, or Class C (minor volumes are classified as greater 27 than Class C). Class A includes both dry active waste and processed waste (e.g., dewatered 28 resins). Classes B and C normally include processed waste and irradiated hardware. The 29 majority of LLRW generated at Turkey Point during the subsequent license renewal period is 30 expected to be Class A waste and could be shipped to licensed processors, such as the Energy 31 Solutions facility in Oak Ridge, TN, for reduction and repackaging, and then shipped to a Class 32 A disposal facility such as the Energy Solutions facility in Clive, UT. Class B and C wastes 33 would constitute a low percentage by volume of the total LLRW generated. The LLRW storage 34 facility at Turkey Point can currently store approximately 5 years of Class B and Class C 35 wastes. 36 Class B and C wastes can be shipped to the Energy Solutions facility in Oak Ridge, TN, where 37 they can then be shipped to the Waste Control Specialist facility in Texas, which is licensed for 38 disposal of Classes A, B, and C wastes. Disposal of waste greater than Class C is the 39 responsibility of the Federal Government. The NRC licenses the storage of LLRW waste under 40 the general license provided to power reactor licensees under 10 CFR Part 50 (FPL 2016f). 41 In 2017, a total of eight LLRW shipments were made from Turkey Point to the Energy Solutions, 42 Bear Creek Road Facility (Oak Ridge, TN) (FPL 2018f) and Energy Solutions, Gallaher Road 43 Facility (Kingston, TN) (FPL 2018f). The total volume and radioactivity of LLRW shipped offsite 44 in 2017 was 6.00x102 cubic meters (m3) (2.12x104 cubic feet (ft3)) and 1.11x100 curies (Ci) 45 (4.12x104 megabecquerels (MBq)), respectively (FPL 2018f). During the subsequent license 3-17

1 renewal period, Turkey Point would continue with routine plant operation, refueling outages, and 2 maintenance activities that generate radioactive solid waste. The NRC also expects Turkey 3 Point to continue to ship radioactive solid waste offsite for disposal during the subsequent 4 license renewal period. 5 3.1.4.4 Radioactive Waste Storage 6 At Turkey Point, LLRW is stored temporarily onsite before being shipped offsite for treatment or 7 disposal at licensed LLRW treatment and disposal facilities. In its environmental report for the 8 Turkey Point subsequent license renewal application, FPL states that Turkey Point has 9 sufficient existing capability to store LLRW onsite. FPL also states in its environmental report 10 that its long-term needs for generated LLRW storage (including during the subsequent license 11 renewal term) do not require constructing additional onsite storage facilities (FPL 2018a). 12 Turkey Point stores its spent fuel in a spent fuel pool and in an onsite independent spent fuel 13 storage installation (ISFSI). The ISFSI safely stores spent fuel onsite in licensed and approved 14 dry cask storage containers. 15 If the U.S. Department of Energy does not begin to take possession of the spent nuclear fuel in 16 2031, FPL may need to expand the existing capacity of the Turkey Point Units 3 and 4 ISFSI. 17 This would require FPL to construct a new ISFSI pad to accommodate additional spent nuclear 18 fuel generated during the subsequent license renewal term (FPL 2018g). Alternatively, FPL 19 may choose to utilize a higher density storage system to create additional storage capacity and, 20 thereby, reduce the need to expand the ISFSI. At this time, FPL has not yet determined 21 whether to expand the ISFSI. 22 3.1.4.5 Radiological Environmental Monitoring Program 23 As stated above, the Florida Department of Health (DOH) Bureau of Radiation Control, per an 24 agreement between FPL and the DOH, conducts a radiological environmental monitoring 25 program (REMP) to assess the radiological impact, if any, to the public and the environment 26 from the operations at Turkey Point Units 3 and 4. 27 The REMP measures the aquatic, terrestrial, and atmospheric environment for ambient 28 radiation and radioactivity. Monitoring is conducted for the following: direct radiation, air, water, 29 groundwater, broad leaf vegetation, fish, shellfish, and sediment. The REMP also measures 30 background radiation (i.e., cosmic sources, global fallout, and naturally occurring radioactive 31 material, including radon). 32 In addition to the REMP, Turkey Point has an onsite groundwater protection program designed 33 to monitor the onsite plant environment for detection of leaks from plant systems and pipes 34 containing radioactive liquid (FPL 2018f). Information on the groundwater protection program is 35 contained in Section 3.5.2, Groundwater Resources, of this SEIS. 36 FPL states in its environmental report that it has detected tritium in groundwater but has not 37 detected Turkey Point Units 3 and 4-related gamma-emitting isotopes since establishing its NEI 38 07-07, Industry Ground Water Protection Initiative, program (FPL 2018f). Section 3.5.2 39 provides a summary of radionuclides detected in groundwater. For 2017, the highest observed 40 level of tritium in Turkey Point groundwater was reported as 13,600 pCi/L. For comparison, the 41 EPA primary drinking water standard or maximum contaminant level (MCL) for tritium is 42 20,000 pCi/L (40 CFR 141.16). Tritium is also found in surface water onsite. For 2017, the 3-18

1 maximum level measured was 24,483 pCi/L in the CCS. While some tritium levels measured in 2 the CCS were found to be higher than the EPA drinking water standard of 20,000 pCi/L, they 3 were still lower than the limits prescribed by Turkey Point Unit 3 and 4s Offsite Dose 4 Calculation Manual (FPL 2013a) for the plant, which for tritium is 30,000 pCi/L. Further, no 5 surface water or groundwater at the site is used for potable purposes. 6 The NRC staff reviewed 5 years of annual radiological environmental monitoring data from 2013 7 through 2017 (FPL 2014c, FPL 2015b, FPL 2016j, FPL 2017d, FPL 2018k). A 5-year period 8 provides a dataset that covers a broad range of activities that occur at a nuclear power plant, 9 such as refueling outages, routine operation, and maintenance that can affect the generation 10 and release of radioactive effluents into the environment. The NRC staff looked for indications 11 of adverse trends (e.g., increasing radioactivity levels) over the period of 2013 through 2017. 12 Based on its review of this information, the NRC staff found no apparent increasing trend in 13 concentration or pattern indicating either a new inadvertent release or persistently high tritium 14 concentrations that might indicate an ongoing inadvertent release from Turkey Point Units 3 15 and 4. The groundwater monitoring program at Turkey Point Units 3 and 4 is robust, and any 16 future leaks that might occur during the subsequent license renewal period should be readily 17 detected. All spills are well monitored, characterized, and actively remediated. The data show 18 that there were no significant radiological impacts to the environment from operations at Turkey 19 Point Units 3 and 4. 20 3.1.5 Nonradioactive Waste Management Systems 21 Like any other industrial facility, nuclear power plants generate wastes that are not 22 contaminated with either radionuclides or hazardous chemicals. 23 Turkey Point has a nonradioactive waste management system to handle its nonradioactive 24 hazardous and nonhazardous wastes. The waste is managed in accordance with FPLs 25 procedures. Turkey Point has a contact stabilization treatment plant for sanitary waste 26 (FPL 2018f) which is located west of the power block area. The treated wastewater is disposed 27 of through an approximately 25-cm (10-in.) diameter, 15-m (50-ft) deep underground injection 28 well located adjacent to the treatment facility. FPL disposes of residuals (wet sludge) at the 29 Miami-Dade Water and Sewer Departments (MDWSD) South District Wastewater Treatment 30 Facility (FPL 2018f). 31 The Miami-Dade County Department of Solid Waste Management is responsible for solid waste 32 collection, transport, and disposal in unincorporated portions of the county and in eight 33 municipalities. The Department of Solid Waste Management solid waste disposal system 34 consists of a resource recovery waste-to-energy facility and two landfills: (1) the North Dade 35 Landfill (a trash-only facility) and (2) the South Dade Landfill (a garbage and trash facility), 36 which are supported by three regional waste transfer stations. An approved solid waste 37 contractor collects and transports the solid waste generated at Turkey Point for disposal at 38 county facilities (FPL 2018f). Listed below is a summary of the types of waste materials 39 generated and managed at Turkey Point. 40

• Turkey Point is classified as a small quantity, hazardous waste generator. The amounts 41 of hazardous wastes generated are only a small percentage of the total wastes 42 generated. These wastes consist of paint wastes; spent, off-specification, and shelf-life 43 expired chemicals; and occasional project-specific wastes (FPL 2018f).

3-19

1

• Turkey Points nonhazardous wastes include plant trash and nonradioactive waste 2 (FPL 2018f).

3

• Other wastes include fluorescent lamps, batteries, and devices containing mercury; 4 electronics; and antifreeze (FPL 2018f).

5 For the fossil fuel facilities (Units 1 and 2, and Unit 5) and the Turkey Point site land 6 management facilities, FPL routes sanitary waste from showers, water closets, toilets, etc. to 7 Miami-Dade County-approved onsite septic systems. For the nuclear generating Units 3 and 4, 8 FPL routes domestic wastewater to an onsite, county- and State-permitted, contact stabilization 9 sewage treatment plant. This wastewater treatment plant (WWTP) discharges effluents to an 10 onsite, permitted, single Class V, Group 3 gravity underground injection well used to dispose of 11 domestic wastewater effluent (FPL 2018f). Wastewater residuals generated by this plant are 12 transported to an approved offsite facility (FPL 2018f). The clarified wastewater sludge is 13 monitored according to operational protocol 0-NCAP-103 to ensure that the disposed material 14 does not present an environmental or public health risk. 15 3.1.6 Utility and Transportation Infrastructure 16 The utility and transportation infrastructure at a nuclear power plant typically interfaces with the 17 public infrastructure systems available in the region. Such public infrastructure includes utilities, 18 such as suppliers of electricity, fuel, and water, as well as roads and railroads that provide 19 access to the site. The following sections briefly describe the existing utility and transportation 20 infrastructure at Turkey Point. Unless otherwise cited, the source of the Turkey Point 21 site-specific information in this section is FPLs environmental report submitted as part of the 22 subsequent license renewal application (FPL 2018f). 23 3.1.6.1 Electricity 24 Nuclear power plants generate electricity for other users; however, they also use their own 25 generated electricity to operate. In the event of a malfunction or interruption of onsite nuclear 26 power generation at Turkey Point, the facility would depend on offsite power sources to provide 27 power to engineered safety features and emergency equipment. If both Turkey Point nuclear 28 power generation and offsite power sources fail, the facility will use planned independent 29 backup power sources. 30 3.1.6.2 Fuel 31 Under its current renewed facility operating licenses, Turkey Point Units 3 and 4 are licensed for 32 fuel that is slightly enriched uranium dioxide (up to 5.0 percent by weight uranium-235). FPL 33 operates the reactors at an equilibrium core maximum fuel discharge burnup rate of 34 62,000 megawatt-days per metric ton uranium (MWd/MTU). FPL refuels each nuclear unit on 35 an 18-month schedule, which means at least one refueling every year and two refuelings every 36 third year. FPL loads the core fuel in three regions. New fuel is introduced into the outer 37 region, and partially spent fuel is moved inward into a checkerboard pattern at successive 38 refuelings when the inner region fuel is discharged to spent fuel storage (FPL 2018f). 39 The Turkey Point spent fuel storage pit provides underwater storage of spent fuel assemblies 40 and control rods after their removal from the reactor. The spent fuel pit is located in the auxiliary 41 building and can store up to 1,535 fuel assemblies, including 131 spent or fresh fuel assemblies 42 in the cask area rack, as well as miscellaneous fuel handling tools. FPL designed the cask area 3-20

1 of the spent fuel pit for the installation of a fuel transfer cask to allow fuel transfer operations. 2 The Turkey Point site has an ISFSI to provide Unit 3 and Unit 4 spent fuel capacity (FPL 2018f). 3 3.1.6.3 Potable Water 4 In addition to cooling and auxiliary water (previously described in detail in Section 3.1.3), 5 nuclear power plants require potable water for sanitary and everyday uses by personnel 6 (e.g., drinking, showering, cleaning, laundry, toilets, and eye washes). At Turkey Point, the 7 Miami-Dade County public water supply system supplies potable water to the site. 8 3.1.6.4 Transportation Systems 9 All nuclear power plants are served by controlled access roads. In addition to roads, many 10 plants also have railroad connections for moving heavy equipment and other materials. Plants 11 located on navigable waters may have facilities to receive and ship loads on barges. 12 The Turkey Point site transportation network includes U.S. highways, interstate highways, 13 multilane divided State highways, and local streets. Miami-Dade County operates public 14 transportation services including rail and bus service. Miami-Dade County also offers air 15 transportation infrastructure including airports, heliports, and a seaplane base; a seaport for 16 commercial freight and passenger service; and an intermodal transportation hub for air, rail, and 17 ship (FPL 2018f). Section 3.10.6, Local Transportation, describes these systems in more 18 detail. 19 3.1.6.5 Power Transmission Systems 20 For license renewal, including subsequent license renewal, the NRC (2013b) evaluates as part 21 of the proposed action the continued operation of those power transmission lines that connect 22 the nuclear power plant to the substation where it feeds electricity into the regional power 23 distribution system. The NRC also evaluates the continued operation of the transmission lines 24 that supply outside power to the nuclear plant from the grid. In its environmental report, FPL 25 stated the locations of in-scope transmission lines, which are shown in Figure 3-5 (FPL 2018f). 26 Turkey Point is connected to the 230-kV switchyard through an approximately 590-foot (180-m) 27 transmission line (FPL 2018f). 3-21

1 Figure 3-5 Turkey Point In-Scope Transmission Lines (FPL 2018f) 2 3.1.7 Nuclear Power Plant Operations and Maintenance 3 FPLs Turkey Point maintenance activities include inspection, testing, and surveillance to 4 maintain the current licensing basis of the facility and to ensure compliance with environmental 5 and safety requirements. Various programs and activities are currently in place at Turkey Point 6 to maintain, inspect, and monitor the performance of facility structures, systems, and 7 components. These activities include, but are not limited to, (1) in-service inspections of 3-22

1 safety-related structures, systems, and components, (2) quality assurance program, (3) fire 2 protection program, and (4) monitoring of radioactive and nonradioactive water chemistry. 3 Additional Turkey Point maintenance programs include those implemented to meet technical 4 specification surveillance requirements and those implemented in response to NRC generic 5 communications. Such additional programs include various periodic maintenance, testing, and 6 inspection procedures necessary to manage the effects of aging on structures and components. 7 FPL performs certain program activities during the operation of the units and performs others 8 during scheduled refueling outages. As stated above, reactor refueling at Turkey Point occurs 9 on an 18-month cycle (FPL 2018f). 10 3.2 Land Use and Visual Resources 11 Section 2.2.1 of NUREG-1437, Supplement 5 (the SEIS for the Turkey Points initial license 12 renewal) describes the general land use at Turkey Point Units 3 and 4 (NRC 2002c). This 13 information is incorporated here by reference. Section 2.2 of NUREG-2176, Environmental 14 Impact Statement for Combined Licenses (COLs) for Turkey Point Nuclear Plant Units 6 and 7 15 (NRC 2016a), also describes the land use at the Turkey Point site. This information is also 16 incorporated here by reference (NRC 2016a). No new and significant information was identified 17 during the review of FPLs environmental report for the Turkey Point Units 3 and 4 subsequent 18 license renewal (FPL 2018f), during the site audit at Turkey Point, the scoping process, or the 19 evaluation of other available information that would alter the discussion contained in the SEIS 20 for Turkey Points initial license renewal. 21 3.2.1 Land Use 22 Turkey Point Units 3 and 4 are located on the shore of Biscayne Bay in south Florida's 23 Miami-Dade County. The plant site is approximately 25 mi (40 km) south-southwest of Miami. 24 The nearest incorporated city limits are Homestead, which is approximately 9 mi (14.5 km) 25 west-northwest of the plant site, and Florida City, which is approximately 9 mi (14.5 km) west of 26 the plant site. The nearest community to the south is Key Largo, which is in Monroe County, FL 27 and is approximately 30 mi (48 km) by road from the plant site. 28 3.2.1.1 Onsite Land Use 29 Turkey Point Units 3 and 4 and associated structures and features, including the cooling canal 30 system, occupy approximately 8,000 ac (3,200 ha). The largest land use and land cover 31 categories within the Turkey Point property boundary are wetlands and open water, which 32 together compose approximately 93 percent of the site. The next largest land use category is 33 developed land (to support Turkey Point plant operations), which is approximately 6 percent of 34 the site (FPL 2018f). 35 Miami-Dade County has designated the land use zoning at the Turkey Point site, including all 36 units, undeveloped lands, and the cooling canal system, as either IU-3 (industrial districts, 37 unlimited manufacturing) or GU (interim district, uses depend on the character of the 38 neighborhood). Specifically, Turkey Point Units 3 and 4 are located on land zoned IU-3. The 39 remainder of the Turkey Point site is zoned GU, an interim district. In an interim district, zoning-40 assigned land uses depend on the character of the neighborhood; otherwise, EU-2 standards 41 apply (single-family 5-ac estate district) (FPL 2018f). 3-23

1 3.2.1.2 Coastal Zone 2 Section 307(c)(3)(A) of the Coastal Zone Management Act (CZMA) (16 U.S.C. 1456(c)(3)(A)) 3 requires that applicants for Federal licenses who conduct activities in a coastal zone provide a 4 certification that the proposed activity complies with the enforceable policies of the State's 5 coastal zone program. Turkey Point Units 3 and 4 are within the Florida coastal zone. The 6 Florida Department of Environmental Protection (FDEP) issued a license that constitutes 7 concurrence that FPLs activities at Turkey Point are consistent with the State of Floridas 8 approved coastal management program. The most recent conditions of certification for Turkey 9 Point Units 3 through 5 (PA 03-45) show Turkey Point Units 3 and 4 as being certified to be 10 consistent in 2008, with several modifications since then, the most recent having been issued 11 on March 29, 2016 (FDEP 2016b). 12 Land to the south and west of the Turkey Point site is in the Everglades Mitigation Bank where 13 wetlands are created, restored, or enhanced to provide compensatory mitigation of wetland 14 losses elsewhere. Under the joint federally and State-operated mitigation bank program, both 15 public and private entities can own lands in the program. FPL owns the Everglades Mitigation 16 Bank land, which comprises approximately 13,000 ac (5,300 ha) of relatively undisturbed 17 freshwater and estuarine wetlands. The U.S. Army Corps of Engineers, the U.S. Environmental 18 Protection Agency (EPA), the Natural Resources Conservation Service, the U.S. Fish and 19 Wildlife Service (FWS), and the National Marine Fisheries Service (NMFS) provide guidance on 20 the use of the mitigation bank to satisfy mitigation requirements of specific laws and provisions, 21 including Section 404 of the Federal Water Pollution Control Act (also known as the Clean 22 Water Act [CWA]) permit program, the wetland conservation provisions of the Food Security 23 Act, the National Environmental Policy Act (NEPA), and several other statutory provisions. The 24 FDEP, the South Florida Water Management District (SFWMD), and Miami Dade County guide 25 the mitigation bank program within Florida pursuant to the Florida Mitigation Banking Rule and 26 other State authorities. 27 3.2.1.3 Offsite Land Use 28 Biscayne Bay, located immediately adjacent to Turkey Point, is the predominant natural feature 29 in the vicinity of the Turkey Point site. As described earlier, the largest land use and land cover 30 category at Turkey Point is wetlands and open water, of which open water is the largest 31 component. The next largest land use and land cover category is wetland areas, comprised of 32 woody and emergent herbaceous wetlands. And finally, the third largest land use and land 33 cover category is developed land. 34 The pattern of land use and urban growth has remained essentially unchanged in 35 Miami-Dade County since 1975, which is when the County released the original Comprehensive 36 Master Development Plan (CMDP). The CMDP establishes a growth policy that encourages 37 development (1) at a rate commensurate with projected county population and economic 38 growth, (2) in a contiguous pattern around a network of high-intensity urban centers connected 39 to transportation facilities, and (3) in locations which optimize efficiency in public service delivery 40 and conservation of valuable natural resources (MDC 2017a). 41 3.2.2 Visual Resources 42 The Turkey Point site is relatively flat and sparsely populated with trees. The most visible 43 features are the containment structures for Units 3 and 4. They are the tallest structures on the 44 site at approximately 210 feet (64 m) tall (FPL 2018f). However, trees and other vegetation 3-24

1 screen most of Turkey Point Units 3 and 4 and supporting structures from roadways and 2 recreational areas west of the plant site. In addition, vegetation blocks the view of Turkey Point 3 Units 3 and 4 from the Biscayne National Park Dante Fascell Visitor Center and Homestead 4 Bayfront Park, although the units can be clearly seen from other areas of Biscayne National 5 Park, including much of Biscayne Bay. At night, light from Turkey Point is visible from several 6 locations outside the site, including from the Homestead-Miami Speedway and Biscayne Bay 7 (NRC 2016a). 8 3.3 Meteorology, Air Quality, and Noise 9 This section describes the meteorology, air quality, and noise environment in the vicinity of 10 Turkey Point. 11 3.3.1 Meteorology and Climatology 12 The State of Florida is characterized by a humid subtropical climate, with long, hot summers 13 and short, mild winters. The climate of Florida is largely influenced by the warm waters of the 14 Gulf of Mexico and western Atlantic. Air from the Gulf of Mexico moderates summer heat, 15 shortens winter cold spells, and provides moisture and heavy rainfall during all seasons. Florida 16 is subject to frequent thunderstorms during the summer, and historically, the State experiences 17 the highest annual number of thunderstorms in the United States. The State is also vulnerable 18 to tornados and tropical cyclones (tropical storms and hurricanes) that develop in the Gulf of 19 Mexico and western Atlantic. On average, tropical cyclones strike Florida three times every 20 5 years, and the Florida coast is vulnerable to severe flooding from these storms (NOAA 2013a, 21 Runkle et al. 2017). Turkey Point is located on the lower east coast of Florida. The general 22 climate in this area is subtropical marine, characterized by a long warm summer with abundant 23 rainfall followed by a mild dry winter (NCDC 2017). The Azores-Bermuda high-pressure system 24 dominates the circulation pattern in this region for most of the year, causing a tropical air mass 25 to prevail. Occasional cold continental air masses displace the maritime air during winter 26 (NRC 2016a). 27 Section 2.9.1 of the EIS for the Turkey Point Units 6 and 7 combined licenses (NRC 2016a) 28 describes in detail the areas specific climatological and meteorological conditions including 29 wind, temperature, precipitation, and severe weather. The NRC staff incorporates into this SEIS 30 the information in Section 2.9.1 of the COL EIS by reference. The NRC staff did not identify any 31 new and significant information relevant to the climatological and meteorological environment 32 beyond the information described in the EIS for the Turkey Point Units 6 and 7 combined 33 licenses that would alter the discussion contained in Section 2.9.1 of the COL EIS. 34 In the past 67 years (1950-2017), the following numbers of severe weather events have been 35 reported in Miami-Dade County (NCDC 2018): 36

• Hurricane: 10 events 37
• Tornado: 137 events 38
• Thunderstorm: 312 events 39
• Flood: 13 events 40 3.3.2 Air Quality 41 Under the Clean Air Act (CAA), 42 U.S.C. 7401, et seq., the EPA has set primary and 42 secondary National Ambient Air Quality Standards (NAAQS) (40 CFR Part 50, National Primary 3-25

1 and Secondary Ambient Air Quality Standards) for six common criteria pollutants to protect 2 sensitive populations and the environment: carbon monoxide (CO), lead (Pb), nitrogen dioxide 3 (NO2), ozone (O3), sulfur dioxide (SO2), and particulate matter (PM). NAAQS further categorize 4 particulate matter under two sizesPM10 (diameter between 2.5 and 10 micrometers) and PM2.5 5 (diameter of 2.5 micrometers or less). Table 3-1 presents the NAAQS for the six criteria 6 pollutants. 7 Table 3-1 Ambient Air Quality Standards Pollutant Averaging Time National Standard Concentration Carbon Monoxide (CO) 8-hour 9 ppm (primary standard) 1-hour 35 ppm (primary standard) Lead (Pb) Rolling 3-month average 0.15 µg/m3 Nitrogen Dioxide (NO2) 1-hour 100 ppb (primary standard) Annual 53 ppb (primary and secondary standard) Ozone (O3) 8-hour 0.070 ppm (primary and secondary standard)(a) Particulate matter less than 2.5 Annual 12 µg/m3 (secondary)

   µm (PM2.5)                                                           15 µg/m3 (secondary) 24-hour                          35 µg/m3 (primary and secondary standard)

Particulate matter less than 10 24-hour 150 µg/m3 (primary and secondary

   µm (PM10)                                                            standard)

Sulfur Dioxide (SO2) 1-hour 75 ppb (primary standard) 3-hour 0.5 ppm (secondary standard) Key: ppb = parts per billion; ppm = parts per million; µg/m3 = micrograms per cubic meter. To convert ppb to ppm, divide by 1000. (a) Final rule signed October 1, 2015, and effective December 28, 2015. The previous (2008) ozone (O3) standards additionally remain in effect in some areas. Primary standards provide public health protection, including the health of sensitive populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings. Source: EPA 2018a 8 With respect to meeting NAAQS, the EPA designates areas that meet the standards as areas of 9 attainment and areas that do not meet the standards as areas of nonattainment. Areas for 10 which there is insufficient data to determine attainment or nonattainment, the EPA designates 11 as unclassifiable. Areas that once did not meet the standards but now do meet the standards, 12 the EPA calls maintenance areas; maintenance areas are under a 10-year monitoring plan to 13 maintain the attainment designation status. States bear the primary responsibility for ensuring 14 attainment and maintenance under NAAQS. Under Section 110 of the Clean Air Act and related 15 provisions, States must submit, for EPA approval, State implementation plans (SIPs) that 16 provide for the timely attainment and maintenance of the NAAQS. 17 In Florida, air quality designations are made at the county level. For the purpose of planning 18 and maintaining ambient air quality under NAAQS, the EPA has developed air quality control 3-26

1 regions. Air quality control regions are intrastate or interstate areas that share a common 2 airshed. Turkey Point is located in Miami-Dade County, which is part of the EPAs Southeast 3 Florida Intrastate Air Quality Control Region (40 CFR 81.49, Southeast Florida Intrastate Air 4 Quality Control Region). This air quality control region consists of eight Florida counties: 5 Broward, Miami-Dade, Indian River, Martin, Monroe, Okeechobee, Palm Beach, and St. Lucie. 6 With respect to meeting NAAQS, EPA designates Miami-Dade County as 7 unclassifiable/attainment or better than national standards for all criteria pollutants 8 (40 CFR 81.310, Florida). The nearest designated nonattainment area (for the 2010 sulfur 9 dioxide primary standard) is in Hillsborough County, FL, which is nearly 200 mi (320 km) from 10 Turkey Point. 11 The Clean Air Act, Title V, Permits, requires States to develop and implement an air pollution 12 permit program. The FDEP regulates air emissions at Turkey Point under Title V air operation 13 permits (FDEP 2018c, FPL 2018f). Combined Turkey Point Units 1, 3, 4, and 5 are considered 14 one facility for purposes of the Prevention of Significant Deterioration permitting program and 15 Title V operating permits. However, FPL operates these four units under two separate Title V 16 permits: one for fossil fuel Units 1 and 5 (Permit 0250003-025-AV) (Unit 1, which has been 17 retired, was deleted from the permit upon its renewal in November 2018), and another for 18 nuclear Units 3 and 4 (Permit 0250003-028-AV). The FDEP issued Title V Air Operation 19 Permit 0250003-028-AV for Turkey Point Units 3 and 4 in April 2018, and this permit will expire 20 in 2023 (FDEP 2018c). Table 3-2 lists permitted air pollutant emission sources and air permit 21 specified conditions for Turkey Point Units 3 and 4. 22 Table 3-2 Permitted Air Emission Sources at Turkey Point Units 3 and 4 Equipment Air Permit Condition Five emergency diesel engines used to support plant equipment: PM, CO, and NOx limits

• Industrial back-up instrument air compressors (2)
• Backup service water feed system pump
• 10-meter meteorological tower generator
• Domestic wastewater system pump One emergency diesel generator engine for the South Dade 40 CFR Part 63, Subpart A, meteorological tower (NESHAP General Provisions)

One emergency diesel fire pump and 40 CFR Part 63, Subpart ZZZZ (NESHAP RICE) Four diesel-engine emergency generators Unregulated Two emergency diesel engines used to support plant equipment Key: PM = particulate matter, NOx = nitrogen oxides, CO = carbon monoxide, NESHAP = National Emission Standards for Hazardous Air Pollutants, RICE = reciprocating internal combustion engines Source: FDEP 2018c 23 Table 3-3 shows annual emissions from permitted sources at Turkey Point Units 3 and 4. FPL 24 operates diesel generators/engines at Turkey Point Units 3 and 4 only intermittently (usually 25 during testing or during outages) as these are intended to be used to supply backup emergency 26 power. According to the 2014 National Emissions Inventory, estimated annual emissions in 27 tons per year for Miami-Dade County are approximately 3,650 (sulfur dioxide); 28 49,600 (nitrogen dioxide); 335,000 (carbon monoxide); 33,000 (particulate matter less than 29 10 microns); and 86,900 (volatile organic compounds) (EPA 2018b). Turkey Point Units 3 and 4 3-27

1 air emissions from permitted sources make up 0.05 percent or less of Miami-Dade Countys 2 total annual emissions. Greenhouse gas emissions from operation of Turkey Point Units 3 and 3 4 are discussed in Section 4.15.3 of this SEIS. 4 Table 3-3 Estimated Air Pollutant Emissions from Turkey Point Units 3 and 4 Emissions (tons/year) Year SOx NOx CO PM10 VOCs 2012 1.5 16 2.1 1.8 0.8 2013 1.5 15 1.8 1.8 0.7 2014 1.8 19 2.4 2.2 0.9 2015 2.1 21 2.7 2.5 1.0 2016 1.7 17 2.0 2.0 0.8 Key: CO = carbon monoxide, NOx = nitrogen oxides, SOx = sulfur dioxides, PM10 = particulate matter less than 10 micrometers, VOC = volatile organic compounds To convert tons per year to metric tons per year, multiply by 0.90718. Source: FPL 2018f 5 The EPA promulgated the Regional Haze Rule to improve and protect visibility in national parks 6 and wilderness areas from haze, which is caused by numerous, diverse air pollutant sources 7 located across a broad region (40 CFR 51.308-51.309). Specifically, 40 CFR Part 81, Subpart 8 D, Identification of Mandatory Class I Federal Areas Where Visibility Is an Important Value, 9 lists mandatory Federal areas where visibility is an important value. The Regional Haze Rule 10 requires States to develop state implementation plans to reduce visibility impairment at Class I 11 Federal areas. At Turkey Point, the nearest Class I Federal area is Everglades National Park, 12 approximately 13 mi (21 km) west of Units 3 and 4 (FPL 2018f). Given Turkey Point Units 3 13 and 4s limited air emissions as presented in Table 3-3, there is little likelihood that ongoing 14 activities at Turkey Point Units 3 and 4 during the subsequent license renewal term would 15 adversely affect air quality and air quality-related values (e.g., visibility or acid deposition) in any 16 Class I Federal areas. 17 3.3.3 Noise 18 Section 2.2.8.4 of NUREG-1437, Supplement 5 (the SEIS for the Turkey Point initial license 19 renewal), describes general noise conditions at Turkey Point Units 3 and 4 (NRC 2002c). This 20 information is incorporated here by reference. Section 2.10.2 of the EIS for the Turkey Point 21 Units 6 and 7 combined licenses (NRC 2016a) also describes ambient noise conditions at the 22 Turkey Point site. This information is also incorporated here by reference (NRC 2016a). No 23 new and significant information about noise at the Turkey Point site was identified during the 24 review of available information, including FPLs environmental report for the Turkey Point 25 Units 3 and 4 subsequent license renewal (FPL 2018f), the site visit, or during the scoping 26 process that would alter the discussion contained in the SEIS for Turkey Points initial license 27 renewal. 28 FPL conducted a noise survey for the Turkey Point Units 6 and 7 COL application 29 environmental report in June 2008. The survey determined baseline ambient noise conditions 30 near the proposed Turkey Point Units 6 and 7 site (including describing noise from Turkey Point 31 Units 3 and 4) and identified sensitive offsite noise receptors. The nearest sensitive noise 3-28

1 receptors included residences to the northwest, a daycare facility to the west, and Homestead 2 Bayfront Park to the north (FPL 2014a). 3 In general, noise from the Turkey Point site can be detected under certain conditions by visitors 4 in Biscayne National Park. Noise is most noticeable under calm wind conditions or when the 5 wind is blowing lightly from the Turkey Point site to the park. Noise from Turkey Point 6 Units 3 and 4 is generally not an issue at the nearest sensitive noise receptors west of the plant 7 (a daycare facility) due to trees, other vegetation, and attenuation by distance. 8 3.4 Geologic Environment 9 This section describes the geologic environment of the Turkey Point site and vicinity, including 10 landforms, geology, soils, and seismic conditions. 11 3.4.1 Physiography, Geology, and Soils 12 The land surface at Turkey Point and the area around it is practically flat. Elevations rise from 13 sea level at the site to 10 feet (3 m) mean sea level (MSL) in the Homestead area 14 9 mi (14.5 km) to the west of Turkey Point. South Florida is underlain by gently dipping or 15 flat-lying sedimentary rocks. In South Florida, these sedimentary rocks are more than 15,000 ft 16 (4,572 m) thick. Limestone is the predominant rock found in the upper 5,000 ft (1,524 m) 17 (FPL 2018f). 18 The limestone rock is divided into stratigraphic units based on geologic properties. The left side 19 of Figure 3-6 identifies the stratigraphic units beneath Turkey Point down to a depth of greater 20 than 3,030 feet (924 m). For each stratigraphic unit, the figure also includes a brief description 21 of the rock characteristics (lithology), thicknesses, and depth. 22 The surficial material under Turkey Point consists of engineered fill. The surficial material within 23 the Turkey Point site, which includes Turkey Point Units 1, 2, 3, 4, and 5, and the CCS, consists 24 of either engineered fill, limestone, marl, or muck. Structures and roads are built on engineered 25 fill or limestone. Any soils within the Turkey Point site consist of marl or muck. The muck 26 consists of herbaceous organic material over limestone. The marl consists of loamy marine 27 deposits over limestone (FPL 2018f, USDA 2017). 28 3.4.2 Economic Resources 29 Significant deposits of oil, gas, and other mineable resources are not known to exist beneath the 30 Turkey Point site (NRC 2016a). Large quarries extract limestone rock in south Florida. This 31 mining area is known as the Lake Belt Region. Limestone is found at or near land surface 32 throughout the entire area. It is used as base material for roads and airport runways, as a 33 construction aggregate, and in cement manufacturing (FDOT 2007, NRC 2016a, USGS 2018b, 34 MDC 2017b). From Turkey Point, the nearest limestone quarrying is located 4.5 mi (7.2 km) 35 west of the site (MDC 2017b). Another nearby mining area is the Atlantic Civil rock mine 36 located about 10 mi (16 km) west of Turkey Point (NRC 2016a). Although the near-surface rock 37 at Turkey Point is composed of limestone, the sites location near Biscayne Bay National Park 38 and its saltwater content makes it an unlikely choice for a future limestone mine. 3-29

1 3.4.3 Seismic Setting 2 Florida has a very small probability of experiencing damaging earthquake effects 3 (FEMA 2018a). Based on historical or statistical seismic activity, Turkey Point is located in an 4 inactive area for earthquakes and far from any recorded damaging shocks (FPL 2018f). Even 5 so, the NRC evaluates the potential effects of seismic activity on a nuclear power plant in an 6 ongoing process that is separate from the license renewal process. The NRC requires every 7 nuclear plant to be designed for site-specific ground motions that are appropriate for its location. 8 Nuclear power plants, including Turkey Point, are designed and built to withstand site-specific 9 ground motion based on their location and the potential for nearby earthquake activity. The 10 seismic design basis is established during the initial siting process, using site-specific seismic 11 hazard assessments. For each nuclear power plant site, applicants estimate a design-basis 12 ground motion based on potential earthquake sources, seismic wave propagations, and site 13 responses, and then account for these factors in the plants design. In this way, nuclear power 14 plants are designed to safely withstand the potential effects of large earthquakes. Over time, 15 the NRCs understanding of the seismic hazard for a given nuclear power plant may change as 16 methods of assessing seismic hazards evolve and the scientific understanding of earthquake 17 hazards improves (NRC 2014a). As new seismic information becomes available, the NRC 18 expects that licensees will evaluate the new information to determine if safety systems at a plant 19 require changes. Independently, the NRC also evaluates new seismic information and confirms 20 that licensees appropriately consider potential changes in seismic hazards at the site. 3-30

1 Source: NRC 2016a 2 Figure 3-6 Geologic Stratigraphy and Major Aquifers Beneath the Turkey Point Site 3 3.5 Water Resources 4 This section describes surface water and groundwater resources at and around the Turkey 5 Point site, with an emphasis on Turkey Point, Units 3 and 4. 6 At the Turkey Point site, surface water (including the areas freshwater canals, wetlands, and 7 the adjoining Biscayne Bay) and groundwater are closely connected. This close relationship is 8 attributable to the very high permeability of the underlying Biscayne aquifer, which permits water 9 to move relatively freely between the surface and subsurface and vice versa. As a result, the 3-31

1 CCS is hydraulically connected to surface waters including Biscayne Bay via the groundwater 2 pathway. These factors have been considered as part of the NRC staffs characterization of 3 surface water and groundwater resources as presented in Sections 3.5.1 and 3.5.2 below, as 4 well as in the staffs impact analyses for water resources presented in Section 4.5, Water 5 Resources. 6 3.5.1 Surface Water 7 Surface water encompasses all water bodies that occur above the ground surface, including 8 rivers, streams, lakes, ponds, and man-made reservoirs or impoundments. 9 3.5.1.1 Surface Water Hydrology 10 Local and Regional Hydrology 11 Biscayne Bay and the area around Turkey Point are part of the South Florida Hydrologic 12 System (Figure 3-7). This encompasses a large area that includes the Everglades and South 13 Florida coastal areas. Human activities have extensively influenced this system principally by 14 population increases and land-use changes that resulted in the conversion of wetlands to 15 agriculture and other uses. A significant contributor to these changes was the use of canals to 16 drain land and redistribute surface water to other areas. 17 The South Florida Hydrologic System and how it has changed over time is described in the EIS 18 for the Turkey Point Units 6 and 7 combined licenses (NRC 2016a) in Section 2.3.1.1 from 19 pages 2-25 to 2-30, including Figures 2-8, 2-9, 2-10, and 2-11. The NRC staff incorporates the 20 above text and figures into this SEIS by reference. 21 The regional surface water system west of Biscayne Bay encompasses the area east and south 22 of the section of the Atlantic Coastal Ridge (ACR) near Biscayne Bay. Historically, various 23 natural swales or glades and sloughs conveyed freshwater eastward to the coastal wetlands 24 adjacent to Biscayne Bay and Card Sound. From there, freshwater discharged into Biscayne 25 Bay and Card Sound either directly by surface water from the coastal wetlands or indirectly 26 through groundwater. Under current conditions, manmade canals crisscross the landscape. 27 These canals drain the land for agriculture and urban use, provide flood control, and discharge 28 their freshwater into Biscayne Bay and Card Sound (NRC 2016a). 29 The canals also have an indirect impact on groundwater resources. Draining the land causes 30 the water level in near-surface aquifers to drop. This in turn has contributed to the inland 31 movement of groundwater that contains salt (saltwater intrusion) from Biscayne Bay and Card 32 Sound (see Section 3.5.2). The canals contain control structures to prevent the inland 33 movement of surface water from Biscayne Bay and Card Sound. During the wet season 34 (typically, the months of June - October), coastal control structures periodically open and 35 discharge freshwater to Biscayne Bay. During the dry season, coastal control structures 36 generally remain closed to maintain relatively high water levels along the coast and prevent 37 saltwater intrusion within near-surface aquifers. (USGS 2001). 38 The Turkey Point Units 6 and 7 COL EIS (NRC 2016a) in Section 2.3.1.1 (on Pages 2-31 39 and 2-32, including Figure 2-12) describes the regional surface water system west of Biscayne 40 Bay and how it has changed over time. The NRC staff incorporates this text and figure into this 41 SEIS by reference. 3-32

1 Source: Modified from NRC 2016a 2 Figure 3-7 Turkey Point Site, Biscayne Bay, Card Sound, and Regional Canals 3-33

1 Biscayne Bay and Card Sound 2 Biscayne Bay is located east of and adjacent to the Turkey Point site. (Figure 3-7). Card Sound 3 is located to the southeast of the site. Both are shallow bays that formed in depressions in the 4 limestone bedrock. The bays are bounded on the east by coral keys that are formed from 5 wave-resistant limestone. Both Biscayne Bay and Card Sound are in direct contact with the 6 Biscayne aquifer as the limestone rock of the aquifer forms the bottom of both bays (see 7 Section 3.5, Groundwater Resources) (NPS 2015a, NPS 2012, NRC 1972, USGS 2008b). 8 Biscayne Bay and Card Sound are separated by Cutter Bank which is an underwater 9 topographic rise (mud bank) (NRC 1972). Near the Turkey Point site, both Biscayne Bay and 10 Card Sound are shallow bays. Within Biscayne Bay, over most of the distance between the 11 Turkey Point site and the coral keys, the depth of the water generally ranges from 2 to 6 ft 12 (0.6 to 1.8 m), reaching a maximum depth of about 7 ft (2.1 m). Within Card Sound, over most 13 of the distance between the Turkey Point site and the coral keys, the depth of the water 14 generally ranges from 4 to 9 ft (1.2 to 2.7 m), reaching a maximum depth of about 10 ft (3 m) 15 (NOAA 2018a). Both Biscayne Bay and Card Sound are connected to the Atlantic Ocean by 16 gaps between the coral keys. However, near the Turkey Point site, the enclosed configuration 17 of the coral keys has isolated much of Biscayne Bay and Card Sound from direct marine 18 influence (USGS 2008b). 19 The hydrology and hydrodynamics of Biscayne Bay and Card Sound are influenced by several 20 factors: (1) tidal exchange of marine waters from the Atlantic Ocean, (2) surface and 21 groundwater inflows of freshwater, (3) precipitation, and (4) evaporation (NRC 2016a). All of 22 these factors also influence the salinity in Biscayne Bay and Card Sound. During the wet 23 season, precipitation decreases the salinity in the bay and the sound. During dry periods, 24 evaporation increases salinity within the bay and the sound, and salinities can become 25 hypersaline (NRC 2016a). 26 The construction of drainage canals on the mainland has also impacted salinity in the bay and 27 sound. This impact is greatest in the near-shore areas adjacent to the mainland. Prior to the 28 construction of drainage canals, freshwater entered the bay and sound from the mainland by 29 widespread sheet flow and groundwater discharge. This provided a more uniform and 30 continuous supply of freshwater to the bay and the sound than the present situation. With the 31 construction of drainage canals, freshwater was less uniformly distributed as the canals 32 discharged freshwater at discrete locations. The result is that areas near canal discharge 33 locations have less saline water than areas farther away from the discharge locations 34 (NRC 2016a). 35 Another way that drainage canals have impacted salinity in the bay and the sound is through 36 seasonal differences in the amount of canal discharge. The canals generally discharge the 37 most freshwater into the bay and sound during wet times of the year and the least during dry 38 periods. As a result, salinity concentrations throughout the year in the bay and sound are more 39 variable in time and space than prior to the construction of drainage canals (NRC 2016a). 40 Around the Turkey Point site, drainage canals discharge to Biscayne Bay north of the site and to 41 Card Sound south of the site. The Turkey Point site occupies an area of former sheet flow that 42 discharged into the bay. However, development of the sites location blocks sheet flow from 43 reaching Biscayne Bay (NRC 2016a). 3-34

1 Pollution from human activities also impacts the water quality of Biscayne Bay. Sections of the 2 shoreline of Biscayne Bay are highly developed. The southern end of Biscayne Bay and Card 3 Sound is less urbanized than the northern section of Biscayne Bay. Pollutants can potentially 4 enter Biscayne Bay from multiple sources, including boats, canals, quarrying operations, 5 landfills, military operations, a sewage-treatment plant, urban and agricultural runoff, and 6 submarine groundwater springs (USGS 2008b). 7 The EIS for the Turkey Point Units 6 and 7 combined licenses (NRC 2016a) in Section 2.3.1.1 8 (on pages 2-33 through 2-38, including Figures 2-14, and 2-15, and Table 2-8) describes the 9 hydrology and hydrodynamics of Biscayne Bay. The NRC staff incorporates the above text and 10 figures into this SEIS by reference. 11 Management of Biscayne Bay and Card Sound Water Quality 12 The Florida legislature has designated Biscayne Bay and Card Sound, including Biscayne 13 National Park, as Outstanding Florida Waters. This affords these waters the highest water 14 quality protections in the State (NRC 2016a; Robles, et al 2005; NPS 2012). The FDEP cannot 15 issue permits for direct discharges to Outstanding Florida Waters that would lower ambient 16 (existing) water quality and may not issue permits for indirect discharges that would significantly 17 degrade a nearby waterbody designated as an Outstanding Florida Water (FDEP 2017a). 18 Card Sound and the north half of Biscayne Bay are within the Biscayne Bay Aquatic Preserve. 19 The FDEPs Office of Coastal and Aquatic Managed Areas manages this preserve 20 (NRC 2016a). One of the management goals is to protect and enhance the waters of the 21 preserve so the public may enjoy the traditional recreational uses of those waters such as 22 swimming, boating, and fishing. No wastes or effluents which substantially inhibit the 23 accomplishment of these purposes can be discharged into the preserve 24 (Florida Statute 258.397). 25 The rest of Biscayne Bay is within Biscayne National Park (Park), including the Biscayne Bay 26 waters adjacent to the Turkey Point site (NRC 2016a). Biscayne National Park was established 27 in order to preserve and protect for the education, inspiration, recreation, and enjoyment of 28 present and future generations a rare combination of terrestrial, marine, and amphibious life in a 29 tropical setting of great natural beauty (USGS 2008b). The park is managed by the U.S. 30 National Park Service. In 2015, a Final General Management Plan was completed for the Park. 31 This plan contains strategies on the management of the resources and activities within the Park 32 to best fulfill Biscayne National Park's mission. It can be found under reference NPS 2015a. 33 Marshland and Mangrove Areas Adjacent to the Turkey Point Site 34 The Turkey Point site is adjacent to marshland outside its northwest, west, and southern 35 boundaries and a significant portion of its eastern boundary. Surface water within the 36 marshland lies on top of muck, which in turn lies on top of the Biscayne aquifer. The surface 37 water hydrology of the marshlands is driven by rain, surface water runoff, freshwater canal 38 overflows, and saltwater from Biscayne Bay and Card Sound (tides, storms, groundwater) 39 (FPL 2016a). Mangrove areas are located adjacent to Biscayne Bay. Soil pore water samples 40 from the marshland muck show that the marshlands adjacent to and west of the Turkey Point 41 are filled with freshwater, whereas marshlands adjacent to and south and east of the Turkey 42 Point site are filled with brackish water. The marshlands become more brackish the closer they 43 are to Biscayne Bay or Card Sound (FPL 2014b, 2016a, 2017a). 3-35

1 Canals Adjacent to the Turkey Point Site 2 A network of drainage canals provides freshwater and drainage to southeastern Florida 3 (FPL 2018f). Some of these canals can be found near the Turkey Point site (Figure 3-4). The 4 CCS does not have a surface water connection with any of these canals. North of the Turkey 5 Point site, the Florida City Canal runs east to west and discharges fresh water into Biscayne 6 Bay (FPL 2014a). West of the Turkey Point site, the L-31E Canal contains freshwater and runs 7 northeast to southwest (FPL 2016a). 8 South of the Turkey Point site, the S-20 Canal and the Sea Dade Canal remnant canal run east 9 to west. The S-20 Canal runs outside the southeast corner of the CCS. It is connected to the 10 L31E Canal by a flow control structure on its western end and connects to Card Sound south of 11 the site. The S-20 Canal contains fresh water when water is being discharged through it and 12 marine water when there is no fresh water discharge through it. The Sea Dade Canal once 13 connected to the S-20 Canal; however, under the provisions of the Everglades Mitigation Bank 14 program, the Sea Dade Canal was plugged off from the S-20 Canal. The Sea Dade Canal is 15 currently a remnant, dead-end canal with no connection to either the Card Sound or Biscayne 16 Bay. The Card Sound remnant canal is also adjacent to the CCS. It runs in a generally north-17 south direction and dead ends against the outside of the CCS. It contains marine water and 18 connects to Card Sound. 19 Potential for Flooding at the Turkey Point Site 20 The NRC evaluates the potential effects of floods on a nuclear power plant in a separate and 21 distinct process, outside of the license renewal process. The NRC addresses flood hazard 22 issues on an ongoing basis at all licensed nuclear facilities (NRC 2013a). The NRC requires 23 every nuclear power plant to be designed for site-specific floods, to assure protection for safety-24 related equipment and facilities. As new information on flood hazard issues becomes available, 25 the NRC expects each licensee to evaluate the new information to determine if its plant requires 26 changes to protect its safety systems. The NRC also evaluates new information important to 27 flood projections and independently confirms that a licensees actions appropriately consider 28 potential changes in flooding hazards at the site. 29 FPL recently completed a flood analysis for Turkey Point Units 3 and 4 and submitted its 30 analysis to the NRC in a process that was separate from subsequent license renewal. After 31 extensive review, the NRC approved this flood analysis on June 29, 2017 (NRC 2017b). FPLs 32 flood analysis used conservative methodology and assumptions, including tidal flooding during 33 hurricanes and future sea level rise during the currently licensed period (ending in July 2032 34 and April 2033 for Unit 3 and Unit 4, respectively). 35 Class 1 structures on the Turkey Point site are flood protected up to a minimum elevation of 36 20 feet (6.1 m) MSL. Components vital to safety, with the exception of the intake cooling 37 water (ICW) pumps, which are protected to 22.5 feet (6.9 m) MSL, are protected against flood 38 tides and waves up to 22 feet (6.7 m) MSL on the east side of Turkey Point (FPL 2018f). 39 In an emergency, if Turkey Point Units 3 and 4 are unable to obtain cooling water from the CCS, 40 the reactors would be placed in a safe shutdown mode. While in this mode, the reactors would 41 still need to be cooled, but would require much less cooling water. Should this situation ever 42 occur, water for cooling would be supplied from a protected well that obtains brackish water 43 from the Upper Floridan aquifer. 3-36

1 For structures that are important to the safe operation of the nuclear units, the NRC requires 2 that they be designed and operated in consideration of potential flooding. The NRC does not 3 have similar requirements for nonsafety-related. At the Turkey Point site, such structures 4 include, for example, office buildings, the Unit 5 cooling towers, and the CCS. 5 Tidal flooding during hurricanes is the major flooding concern at the Turkey Point site. The 6 highest tide nearest the site was recorded in September 1965 during Hurricane Betsy and 7 reached an elevation of 10.1 ft (3.1 m) MSL. The station where the measurement was made is 8 located north of Palm Drive on the Florida City Canal, approximately 2.3 mi (3.7 km) west of the 9 shoreline. In 1965, debris marks from the flood tide associated with Hurricane Betsy were seen 10 at an elevation of approximately 10 ft (3 m) MSL at the Turkey Point Site (FPL 2018f). 11 Because of the low flat terrain, tidal floodwaters in the Turkey Point area can move inland 12 several miles and can cover large areas. Construction of flood control projects in the area have 13 reduced the possibility of tidal floodwaters reaching agricultural and populated areas. The 14 L-31E Canal, which is not part of the Turkey Point site, is designed to provide flood protection to 15 properties further west. This canal is located west of the Turkey Point site and generally runs 16 from southwest to northeast. It includes a levee with a crest elevation of 7 ft (2.1 m) MSL. 17 However, it is not designed to prevent flooding from severe hurricanes with tidal flooding. 18 Based on published storm-tide frequency studies, it is estimated that a 7 ft (2.1 m) tide may 19 occur once every 20 to 25 years near the Turkey Point site (FPL 2018f). 20 The Federal Emergency Management Agency (FEMA) has prepared flood zone maps that 21 cover the Turkey Point site and surroundings (Figure 3-8). Except for Units 3 and 4, FEMA 22 maps most of the Turkey Point property and the surroundings as Zone A (FPL 2018f). A 23 Zone A area has a 1-percent annual chance of flooding within any single year (FEMA 2014). 24 The water depth of a flood with a 1-percent chance of annual flooding in any single year is 25 called the base flood (FEMA 2018b). 26 Within the Turkey Point site, FEMA designates a small area near the shoreline along the 27 northeastern property line as within the coastal flood zone with hazardous wave action, and with 28 base flood depths of 14 to 17 feet (4.3 to 5.2 m) (NAVD88). FEMA designates approximately 29 27 percent of the Turkey Point property as within the coastal flood zone with base flood depths 30 of 11 to 14 ft (3.4 to 4.3 m). However, the remaining 70 percent of the site where the canal 31 system is located has no base flood elevations determined by FEMA. Inland from and just 32 outside and along the western boundary of the CCS, base flood depths range from 8 to 11 ft 33 (2.4 to 3.4 m) (FPL 2018f). 34 The increased potential for future coastal flooding based on climate change projections is 35 discussed in Section 4.15.3.2 (Climate Change) of this SEIS. 36 3.5.1.2 Surface Water Consumption 37 Surface water resources are not consumed by Turkey Point operations. All water consumed by 38 Turkey Point is derived from groundwater resources. 3-37

1 Source: From FPL 2018f 2 Figure 3-8 FEMA Flood Zones Map of the Turkey Point Property 3 3.5.1.3 Surface Water Discharges 4 Operations at Turkey Point do not discharge to surface water bodies outside of the Turkey Point 5 site. All surface water discharges from Turkey Point activities are directed into the CCS, which 6 does not connect to any other surface water bodies. 7 Sanitary wastewater from Turkey Point is routed to an onsite, county- and State-permitted, 8 contact stabilization sewage treatment plant. Effluent from this wastewater treatment plant is 9 discharged to an onsite, permitted, single Class V, Group 3 gravity underground injection well. 10 The well is used to dispose of up to 35,000 gpd (132 m3/day) of domestic wastewater effluent. It 11 discharges into the top of the Biscayne aquifer and is open from 42 to 62 feet (12.8 to 19 m) 3-38

1 below ground surface. Any wastewater residuals are transported to an approved offsite facility. 2 FPL monitors the clarified wastewater sludge to ensure it does not present a risk to the 3 environment or to public health (FPL 2018f). The Florida Department of Environmental 4 Protection manages sanitary waste under FDEP Sewage Treatment Facility Domestic 5 Wastewater Facility Permit No. FLAO13612-002-DW3P and FDEP Sanitary Wastewater 6 Disposal Well Domestic Wastewater Facility Permit No. 0127512-002-UO. 7 FPL discharges stormwater and all other discharges from Turkey Point Units 3 and 4 and the 8 other facilities at the Turkey Point site to the CCS. Consistent with EPA and State 9 determinations, neither FPL nor the State of Florida considers the CCS to be waters of the 10 United States or waters of the State (FPL 2018f). FPL operates the CCS as an industrial 11 wastewater (IWW) facility under National Pollutant Discharge Elimination System 12 (NPDES)/IWW Permit No. FL0001562. This permit is issued pursuant to the Federal NPDES 13 program and the Florida Industrial Waste Water permitting program. FPL submitted a permit 14 renewal application to the State of Florida on October 21, 2009. Since that time, the 2005 15 permit has been administratively continued and remains in effect at this time. The NPDES 16 permit covers all plant discharges including discharges from Turkey Point Units 1, 2, 3, 4, and 5. 17 The NPDES permit authorizes wastewater discharges, including stormwater, through two 18 internal outfalls into the CCS. Internal Outfall I-001 is located on the southern bank of the 19 discharge canal that leads to the CCS; Internal Outfall I-002 is located in the Units 1 and 2 20 settling basins (see Figure 3-9). Stormwater from Turkey Point discharges through Internal 21 Outfall I 002 (FPL 2018f). Water quality parameters monitored by FPL under the Turkey Point 22 NPDES permit include copper, iron, lead, pH, salinity, specific conductance, temperature, total 23 suspended solids, zinc, and oil and grease (FPL 2018f). 24 The permit authorizes discharges to waters of the State. However, while the permit authorizes 25 discharges to groundwater of the State it does not authorize direct discharges to surface 26 waters of the State. The permit authorizes discharges from the CCS into the surficial aquifer, 27 which is the Biscayne aquifer. Beneath the CCS, the groundwater in the Biscayne aquifer is 28 classified as Class G-III groundwater (FDEP 2005, FPL 2018f). As a result of its high total 29 dissolved solids content, Class G-III groundwater is not considered to have a reasonable 30 potential as a future source of drinking water (FPL 2018f, FAC 62-520.410, UF 2018a). 31 While the State of Florida regulates nonradioactive liquid releases from Turkey Point, the NRC 32 regulates radioactive releases from Turkey Point. Liquid releases of radionuclides within NRC 33 allowable limits are a part of normal nuclear power plant operations. Liquid releases from 34 Turkey Point operations are discharged into the CCS via Internal Outfall I-001 (FPL 2018f). The 35 NRC monitors the amount and types of radionuclides and the calculated dose to the public to 36 confirm that releases are below NRC thresholds as defined in NRC regulations. 3-39

1 Source: From FPL 2018f 2 Figure 3-9 Florida Department of Environmental Protection NPDES Permitted Outfalls 3 CWA Section 401 Certification 4 Section 401 of the Clean Water Act (33 U.S.C. 1251 et seq.) requires an applicant for a Federal 5 license to conduct activities that may cause a discharge of regulated pollutants into navigable 6 waters to provide the licensing agency with a water quality certification from the State. This 7 Section 401 certification implies that discharges from the project or facility to be licensed will 8 comply with Clean Water Act requirements and will not cause or contribute to a violation of 9 State water quality standards. If the applicant has not received a Section 401 certification, the 3-40

1 NRC cannot issue a license unless that State has waived the requirement. The NRC 2 recognizes that some NPDES-delegated States explicitly integrate their Section 401 certification 3 process with NPDES permit issuance (NRC 2013a). 4 The Power Plant Siting Act (PPSA) certification from the State of Florida is a non-expiring permit 5 that remains valid for the life of the facility. Under the PPSA, FPL is not required to obtain a 6 new certification for NRC subsequent license renewal. The certification will remain effective, as 7 will any legal effects of the certification, including the certifications compliance with State water 8 quality standards for the life of the facility. Therefore, there is no requirement for FPL to obtain 9 a new determination of compliance with State water quality standard for Turkey Point Units 3 10 and 4 subsequent license renewal (FPL 2018f, FPL 2018g). 11 3.5.1.4 Adjacent Surface Water Quality and Cooling Canal System Operation 12 Within the Turkey Point site, the cooling canal system is the largest body of water. This section 13 of the SEIS describes recent studies to evaluate potential effects of CCS operations via the 14 movement of groundwater from the CCS to adjacent surface water bodies. 15 In response to orders from the State of Florida and Miami-Dade County, FPL conducts an 16 extensive water quality monitoring program that includes the CCS, Biscayne Bay, Card Sound, 17 marshland, mangrove areas, and canals adjacent to the CCS. A major objective of this program 18 is to evaluate the effects, if any, of CCS operation on the surrounding environment. The 19 monitoring program and some of its data and findings are contained in a number of documents 20 (FPL 2010, FPL 2011a, FPL 2014b, FPL 2016a, FPL 2016e, FPL 2016f, FPL 2016g, 21 FPL 2017a, and FPL 2017b) (See Figure 3-10). 22 This water quality monitoring program monitors surface water bodies for numerous water quality 23 parameters, including ammonia and other nutrients and salinity. Water temperature in the CCS 24 is also monitored, but FPL has not detected CCS waters affecting temperatures in adjacent 25 water bodies. 26 FDEP Administrative Order DEP #16-0111, uses tritium, in conjunction with saline water, as a 27 tracer to estimate the spatial extent of waters originating from the CCS (FDEP 2016h). At levels 28 in accordance with NRC allowable limits, Turkey Point Units 3 and 4 discharge liquid water 29 containing tritium into the CCS in batch releases. Units 3 and 4 also release tritium as a 30 gaseous emission (steam water or vapor water) into the air. 31 Tritium is a hydrogen atom with an atomic mass of three instead of one (NRC 2006a); like any 32 other hydrogen atom, it usually binds with oxygen to form a water molecule. A water molecule 33 that contains hydrogen in the form of tritium will behave in the environment just like a water 34 molecule that does not contain tritium. There are two possible pathways for tritium to leave the 35 CCS and move to another surface water body: (1) through the groundwater pathway within 36 liquid water or (2) through air within gaseous water (steam or vapor water). Therefore, for 37 surface water samples collected in bodies of water near the CCS, these two possible pathways 38 are considered when interpreting the data. 39 Tritium emits a weak form of radiation in the form of a low-energy beta particle similar to an 40 electron. This radiation does not travel very far in air and cannot penetrate the skin. If tritium 41 enters the body, it disperses quickly and is uniformly distributed throughout the soft tissues. 42 Tritium has a half-life of 12.3 years. This means that after 12.3 years, half of the tritium will be 43 gone through decay into a form that is no longer radioactive. However, if ingested, the human 3-41

1 body excretes half of the tritium ingested within approximately 10 days (NRC 2006a). For 2 tritium in drinking water, EPA has established a maximum contaminant level of 20,000 pCi/L 3 (EPA 2002, NRC 2006b). 4 At the levels that have been measured within the CCS, tritium is not a public health concern. 5 With the exception of rare outliers, measurements of tritium concentrations at sampling 6 locations within the CCS have been below the EPA maximum contaminant level of 20,000 pCi/L 7 for tritium in drinking water. Although tritium levels in some areas may somewhat exceed the 8 EPAs maximum contaminant level of 20,000 pCi/L for tritium in drinking water, salt 9 concentrations make the water in the CCS non-potable, and there are no drinking water wells 10 on or near the site. Also, while tritium has been detected in adjacent water bodies, the 11 concentrations were very low and often extremely low relative to the EPAs maximum 12 contaminant level of 20,000 pCi/L for tritium in drinking water (FPL 2010, FPL 2011a, 13 FPL 2014b, FPL 2016a, FPL 2016e, FPL 2016f, FPL 2016g, FPL 2017a, and FPL 2017b). 14 Water Quality within the Cooling Canal System 15 The following text describes ammonia and nutrients and salinity conditions within the CCS. As 16 CCS water temperatures also have an effect on CCS water salinities, the following text also 17 includes a discussion of water temperature in the CCS. Any mitigating actions within the CCS 18 to reduce any indirect effects on groundwater, ecology, and on adjacent surface water bodies 19 are also described. 20 Ammonia and Nutrients within the Cooling Canal System 21 Ammonia is released into the waters of the CCS by the decay of organic material within the 22 CCS. Between June 2010 and May 2016, ammonia concentrations within the CCS ranged from 23 below detectable levels to 0.3 mg/L and averaged 0.04 mg/L (FPL 2017c). The Miami-Dade 24 County water quality standard for ammonia is 0.5 mg/L (FPL 2018m). The Turkey Point CCS 25 values are all below this standard. 3-42

1 Source: From FPL 2017a 2 Figure 3-10 Locations of Surface Water Monitoring Stations 3 Ammonia is a nutrient. Other nutrients include phosphorus, chlorophyll, and total nitrogen. 4 Within a surface water body, if the concentration of nutrients gets too high, the nutrients can 5 cause algae blooms. These algae blooms can be toxic, deplete oxygen in the water, and 6 reduce water clarity (FDEP 2018e). 3-43

1 Nutrients are added to the water in the CCS by the erosion of soil and vegetation that falls into 2 the canals from the land that separates the individual channels within the CCS. Nutrients are 3 also added by groundwater inflows, atmospheric deposition (of nitrogen) and by the relatively 4 low levels of effluents from power plant operations. Nutrients are removed from the CCS by the 5 growth of seagrass, the harvest of seagrasses as a CCS maintenance activity, the removal of 6 biological material impinged on the plant intake screens, and the outflow of water from the CCS 7 into groundwater (FPL 2018f). 8 Prior to 2010, the CCS operated as a seagrass-based biological system. Seagrass grew 9 beneath the water on the bottom of the channels, covering an estimated 50 percent of the 10 channel bottoms. The seagrass provided habitat for aquatic life, provided natural filtration of 11 suspended material, and removed nutrients from the water within the CCS. This ecosystem 12 helped to maintain good water quality and low nutrient concentrations in the CCS waters 13 (FPL 2018f). 14 By 2010, this ecosystem had begun to change dramatically. CCS salinities had increased to the 15 point that the seagrass meadows were dying. By 2012, few seagrass beds remained. The 16 decomposition of the dead seagrass released a significant volume of nutrients into the waters of 17 the CCS. This increase in nutrients facilitated seasonal algae blooms, resulting in high turbidity 18 and generally degraded water quality within the CCS (FPL 2018f). 19 Nutrient Management Plan for the Cooling Canal System 20 In accordance with a June 20, 2016 consent order between FPL and the State of Florida 21 (FDEP 2016a), FPL submitted to the FDEP a nutrient management plan for the CCS. This 22 management plan is composed of three primary nutrient management strategies: (1) active 23 algae and nutrient removal, (2) canal and berm maintenance, and (3) salinity reduction and 24 controlled flow management. On July 7, 2017, the FDEP directed FPL to implement the plan 25 (FPL 2017b). 26 Under this nutrient management plan, FPL has performed bench and pilot tests to find the most 27 appropriate active nutrient and algae removal methods for the unique ecology and water 28 chemistry of the CCS. These nutrient and algae removal methods include using chemical 29 flocculants/coagulants, nonchemical means (i.e., physical removal), and aeration. In addition, 30 FPL reviewed Turkey Point canal practices in order to revise them to integrate the goal of 31 minimizing erosion and nutrient inputs from sediment and berm sources (FPL 2017b). 32 Temperatures within the Cooling Canal System 33 The temperature of the CCS varies in response to factors such as heated water discharged by 34 Units 3 and 4 into the CCS, air temperature, wind, precipitation, Biscayne aquifer groundwater 35 flowing into and out of the CCS, and water that FPL adds to the CCS from wells to reduce 36 salinity. To a lesser extent, discharges of water into the CCS from the interceptor ditch and the 37 Turkey Point Unit 5 cooling tower blowdown can also impact the temperature of water within the 38 CCS. 39 Historically, Turkey Points Units 1, 2, 3, and 4 all contributed heat to the CCS. Units 1 and 2 are 40 now retired and no longer contribute heat to the CCS. Even under current operations (i.e., after 41 the NRC approved power uprates for Units 3 and 4 on June 15, 2012 (NRC 2012)), the heat 42 that Units 3 and 4 discharge to the CCS is less than the amount of heat Turkey Point had 43 discharged to the CCS when Units 1, 2, 3, and 4 were all in operation. 3-44

1 Due to the discharge of heat into the CCS, water temperatures in the CCS are higher than 2 ambient air temperatures (FPL 2018f). Surface water temperatures within the CCS are warmer 3 in the summer months and cooler in the winter months (FPL 2016a). Water temperatures within 4 the CCS also vary based on location. As water moves from the discharge area, through the 5 canals, and then towards the intake area, the water temperature drops (FPL 2016a). As 6 expected, the highest water temperatures in the CCS are found where Units 3 and 4 discharge 7 hot water into the CCS (Station TPSWCCS-1); the lowest water temperatures are found at the 8 cooling water intake for Units 3 and 4. From June 2010 through May 2017, average monthly 9 temperature values collected at all seven monitoring stations within the CCS ranged from 10 52.7 °F (11.5 °C) to 115 °F (46.3 °C), and produced an average monthly temperature of 88 °F 11 (30.4 °C) (FPL 2017a). 12 The CCS serves as the ultimate heat sink to cool Units 3 and 4. On August 8, 2014, the NRC 13 established an ultimate heat sink temperature limit for the cooling canals of 104 °F (40 °C) 14 (FPL 2018f, NRC 2014d, 79 FR 44464, 80 FR 76324). To judge compliance with this limit, FPL 15 measures water temperature from a sampling location in the return canal in front of the cooling 16 water intake structure. Data from this sampling location represent the temperature of the water 17 after it has been cooled by the CCS. From June 2010 through May 2017, temperature 18 measurements at this sampling location (station TWSWCCS-6) have not exceeded the NRCs 19 ultimate heat sink limit of 104 °F (40 °C) (FPL 2017a). 20 Prior to August 2014, the NRC had set the ultimate heat sink limit at the slightly lower 21 temperature of 100 °F (37.8 °C). In early July 2014, the water temperature in the cooling canals 22 began to approach the limit of 100 °F (37.8 °C). FPL then requested an increase in the 23 temperature limit; in response, the NRC performed a safety and environmental analysis, and 24 then established the current heat sink temperature limit of 104 °F (40 °C) (NRC 2014b). 25 FPL believes that the 2014 increase in average CCS temperatures was necessitated by: 26

• low average precipitation into the CCS from 2011 through 2014 27
• poor water circulation through the CCS due to blockages and sediment accumulation 28
• reduced heat exchange efficiency caused by factors such as higher salinity, turbidity, 29 and algal concentrations that reduced evaporation rates (FPL 2018f) 30 Since 2014, FPL has worked to reduce algae concentrations, improve canal circulation, and 31 increase the inflow of groundwater from the Biscayne aquifer into the CCS by sediment removal 32 from CCS channels. For a short period of time, to help lower CCS temperatures, freshwater 33 from Canal L-31E, brackish water from the Upper Floridan aquifer, and saltwater from the 34 Biscayne aquifer was added to the CCS.

35 According to its environmental report for subsequent license renewal, FPLs current plans to 36 lower CCS temperatures do not include the use of freshwater from State canals (FPL 2018f). In 37 the future, should FPL need to use freshwater from State canals, FPL would need to seek 38 permission to do so from State and county governments. FPL states that future plans to reduce 39 CCS temperatures include adding brackish water from the Upper Floridan aquifer, reducing 40 algae in the CCS, continuing to remove sediment within the CCS, and, only in extraordinary 41 circumstances, pumping saltwater from the Biscayne aquifer into the CCS (FPL 2018f). 3-45

1 Thermal Efficiency Plan for the Cooling Canal System 2 In accordance with the June 20, 2016 consent order between FPL and the State of Florida, FPL 3 submitted a thermal efficiency plan for the CCS to the FDEP (FDEP 2016a). FPL has identified 4 the maintenance of high thermal efficiency within the CCS as necessary for controlling 5 evaporation and salinity in the CCS. The plan identified primary and secondary performance 6 metrics. FPL will use these metrics to guide its actions to maintain high thermal efficiencies 7 (i.e., thermal efficiency at equal to or greater than 70 percent). On July 7, 2017, the FDEP 8 instructed FPL to implement this thermal efficiency plan (FPL 2017b). 9 Since July 2017, FPL has implemented several near-term actions under this thermal efficiency 10 plan, including (1) sediment removal in many of the CCS canals, (2) flow management within 11 the CCS, (3) water stage management, and (4) vegetation management. As a result, thermal 12 efficiency in the CCS during the 2017 reporting period met the objectives of the plan, which is to 13 maintain high thermal efficiencies at equal to or greater than 70 percent. For the period 14 between October 2016 through September 2017, FPL reported an annual CCS thermal 15 efficiency of approximately 84 percent (FPL 2017b). 16 Salinity within the Cooling Canal System 17 Water in the CCS contains significant concentrations of salt. CCS water is saltier than seawater 18 (i.e., it is hypersaline). The salinities of seawater are around 34-35 practical salinity units 19 (PSU), while the salinity of water in the CCS is presently around 60 PSU, or almost twice the 20 salinity of seawater (EB 2018, FPL 2018f). Salinities in the CCS increase when water leaves 21 the CCS and decrease when less saline water enters the CCS. The highest salinities in the 22 CCS are likely to occur during times of low precipitation and when evaporation rates are high. 23 Conversely, the lowest salinities within the CCS are likely to occur during times of high 24 precipitation and when evaporation rates are low (FPL 2012a). Salinity concentrations are 25 usually at minimum values during the wet season, with the highest salinities at the end of the 26 dry season (FPL 2018f). 27 Most of the salt in the CCS comes from the groundwater of the Biscayne aquifer which is 28 saltwater. As groundwater from the Biscayne aquifer moves into the CCS, the salt it contains 29 also moves into the CCS. The Biscayne aquifer obtains its salt from Biscayne Bay, and is 30 hydrologically connected to both the Biscayne Bay and the CCS (FPL 2018f, Tetra Tech 2014, 31 FPL 2016a). 32 Salt is removed from the CCS when water containing salt moves from the CCS into the 33 Biscayne aquifer. Water that moves from the CCS into the groundwater is likely to reflect the 34 hypersaline conditions of the CCS (around 60 PSU). With its higher salt concentrations, this 35 CCS water is denser than the groundwater of the Biscayne aquifer (FPL 2018f). 36 As previously stated, in recent years, salinity concentrations within the CCS have been about 37 60 PSU, or about twice the average concentration of seawater, which is approximately 34 to 38 35 PSU (FPL 2018a). However, when FPL first constructed the cooling canals in the 1970s, the 39 salinity of the CCS water and the surrounding Biscayne aquifer were about equal to the salinity 40 of saltwater and the adjacent Biscayne Bay (approximately 34 PSU) (FPL 2018f). 41 As previously described, CCS salinities have varied over time; usually at minimum values during 42 the wet season, with the highest salinities at the end of the dry season. During dry years 43 (periods of drought) the overall salinities at the end of the year were higher than the salinities at 3-46

1 the end of the previous year. In this way, drought years produced a ratcheting effect that 2 caused the next year to begin the seasonal cycle of salinity concentrations at higher salinities 3 than the previous year. As a result, average salinities in the CCS gradually increased from 4 approximately 34 PSU in the early 1970s to approximately 90 PSU in 2014 and 2015 5 (FPL 2017a, FPL 2017b, FPL 2018f). 6 As CCS salinities increased, the seagrasses in the CCS died off. As the seagrasses died off, 7 not only could they no longer remove nutrients from the water, their decomposition also 8 released considerable amounts of nutrients into the water. The increased nutrient 9 concentrations facilitated the growth of seasonal algae blooms (FPL 2018f). As previously 10 mentioned, from 2011 through 2014, in combination with low average precipitation and poor 11 water circulation through the CCS, the algae blooms contributed to increased temperatures and 12 salinities within the CCS (NRC 2016a). 13 To help reduce the water temperatures within the CCS, on June 27, 2014, the State of Florida 14 granted FPL permission to add saltwater from the Biscayne aquifer and brackish water from the 15 Upper Floridan aquifer to the CCS (NRC 2016a). In August 28, 2014, the South Florida Water 16 Management District granted FPL permission to add freshwater from the L-31E Canal to the 17 CCS to reduce salinity. After these additions, rainfall also added freshwater to the CCS. CCS 18 salinities and temperatures subsequently returned to pre-summer 2014 levels (around 60 PSU) 19 (FPL 2018f, NRC 2016a). 20 Salinity Management Plan 21 In December 2014, the FDEP issued an Administrative Order requiring FPL to submit a salinity 22 management plan to describe how FPL would reduce and maintain the average annual salinity 23 in the CCS at or below 34 PSU (FDEP 2014, NRC 2016a). On October 7, 2015, Miami Dade 24 County and FPL signed a consent agreement (MDC 2015a). In this agreement, it was 25 acknowledged that FPL would supply brackish water to the CCS from the Upper Floridan 26 aquifer and saltwater from the Biscayne aquifer via marine wells (wells located adjacent to 27 Biscayne Bay). However, FPL would work to avoid the use of water from the marine wells, 28 except under extraordinary circumstances. Secondly, it was acknowledged that FPL would 29 continue to use water from the L-31E canal to lower CCS salinities until a transition was made 30 to long-term sources of water for the CCS (i.e., brackish water from the Upper Floridan aquifer) 31 (MDC 2015a). 32 On June 20, 2016, a consent order (FDEP 2016a) was executed by FPL and the FDEP. The 33 consent order requires FPL to maintain the average annual salinity of the CCS at or below 34 34 PSU. Further, it states that, [i]f FPL fails to reach an annual average salinity of at or below 35 34 PSU by the end of the fourth year of freshening activities, within 30 days of failing to reach 36 the required threshold, FPL shall submit a plan to the [FDEP] detailing additional measures, and 37 a timeframe, that FPL will implement to achieve the threshold. Subsequent to attaining the 38 threshold in the manner set forth above, if FPL fails more than once in a 3 year period to 39 maintain an average annual salinity of at or below 34 PSU, FPL shall submit, within 60 days of 40 reporting the average annual salinity, a plan containing additional measures that FPL shall 41 implement to achieve the threshold salinity level (FDEP 2016a). 42 In future years, it is anticipated that Upper Floridan aquifer wells will be the water source utilized 43 for salinity reduction (FPL 2018f). As detailed in Section 3.5.2.2.3, FPL began operation of the 44 Upper Floridan aquifer freshening well system on November 28, 2016. The addition of this 45 brackish water (2.5 PSU) to the CCS is being used to help reduce the CCS salinity to an 3-47

1 average annual level of 34 PSU. The addition of this water has been important in minimizing 2 increases in CCS salinity that ordinarily occur during the dry season. Continued operation of 3 the freshening wells during the wet season should further help to reduce CCS salinities 4 (FPL 2018f). 5 Study of Water Alternatives to Reduce CCS Salinities 6 In the October 7, 2015, consent agreement between Miami-Dade County and FPL, it was 7 acknowledged that FPL would consider the practicality and appropriateness of using reclaimed 8 wastewater from the Miami-Dade County South District Waste Water Treatment Plant as an 9 alternative water resource to reduce CCS salinities. To respond to this request, FPL contracted 10 with Golder and Associates to evaluate alternative sources of water. Along with other 11 alternatives, the evaluation considered the practicality and appropriateness of using reclaimed 12 wastewater from the Miami-Dade County South District Waste Water Treatment Plant 13 (SDWWTP) (Golder 2016). 14 The study considered the following eight alternatives: 15 1) Excess surface water from the L-31E Canal 16 2) Biscayne aquifer water from the Inland Biscayne Aquifer Wellfield 17 3) Reclaimed water from SDWWTP with nutrient removal 18 4) Reclaimed water from SDWWTP with nutrient removal and advanced treatment for 19 other constituents of concern 20 5) Upper Floridan aquifer water using artesian wells flowing into the CCS 21 6) Direct Treatment of CCS water to remove salinity 22 7) Marine groundwater from wells on the Turkey Point Peninsula with additional fresh 23 water from another source 24 8) Marine surface water from Biscayne Bay or Card Sound with additional fresh water 25 from another source 26 The study considered technical, environmental, economic, and social criteria. Relative to the 27 ranking criteria, it ranked Alternative Five as the best overall and the most balanced alternative. 28 It also identified that Alternatives One and Seven should be maintained as short-term backup 29 water options to be used when appropriate and as needed during extreme conditions. It further 30 determined that Alternatives Two, Four, Six, and Eight did not provide a significant advantage 31 and should not be evaluated further unless conditions change. While the study determined that 32 Alternative Three has a high cost and very long implementation schedules; it concluded that this 33 alternative should be further evaluated as a potential long-term solution to a regional problem 34 (Golder 2016). 35 The alternatives study was reviewed by Miami-Dade County. On December 22, 2016, the 36 County decided that the use of reclaimed water with nutrient removal and advanced treatment, 37 described as (Alternative 4) in the referenced document, could provide a long-term, sustainable 38 source of water to offset CCS water deficits. The County recommended that FPL revisit this 39 alternative for further evaluation as a potential long-term solution (MDC 2016a). The current 40 status of this proposal is unclear. 3-48

1 Application of Numerical Modeling to CCS Salinity Mitigation 2 The operation of the CCS has been numerically modeled to understand and predict different 3 aspects of the CCS (Chin 2016; Golder 2008; Tetra Tech 2014a; FPL 2012a, FPL 2014b, 4 FPL 2016a, FPL 2016g, FPL 2017a). The most recent modeling was conducted by Tetra Tech 5 for FPL. The focus of this modeling was to quantify the volumes of water and the mass of salt 6 entering and exiting the CCS (FPL 2012a). Model calculations for the various components of 7 the CCS incorporate hydrological, chemical, and meteorological data collected in and around 8 the CCS (FPL 2012a). Selected model inputs were adjusted to calibrate the model against 9 observed changes in CCS water and salt storage. The calibration minimized differences 10 between simulated and observed salt and water storage changes within the CCS. The 11 calibration process builds confidence that the model will produce adequate predictions of CCS 12 behavior (FPL 2014b). 13 This tool is being used by FPL to understand the effectiveness of its mitigation measures. The 14 most recently published modeling results simulate the operation of the CCS from June 2015 15 through May 2017. The modelers concluded that over this time period, the addition of Upper 16 Floridan aquifer water helped to moderate dry season salinity without significantly increasing 17 water levels in the CCS (FPL 2017a). 18 In 2014, Tetra Tech used numerical models to estimate the volume of Upper Floridan aquifer 19 water that would be required to reduce CCS water salinity to seawater range. The modeling 20 exercise produced an estimate that with the addition of 14 mgd (53,000 m3/day) of Upper 21 Floridan aquifer water that had a salinity of 2 PSU it would require less than a year to reduce 22 salinities in the CCS to 35 PSU (Tetra Tech 2014a). However, while FPL then added an 23 average of 12.8 mgd (48,500 m3/day) of Upper Floridan aquifer brackish water to the CCS from 24 the beginning of November 2016 to the end of May 2017, salinities in the CCS did not go down 25 to 35 PSU (FPL 2017a). Rather, at the end of May 2017, average salinity concentrations in the 26 CCS were 64.9 PSU (FPL 2017b). 27 Comparing CCS data and model results, the modelers concluded that during this period (most 28 of which occurred during the dry season), evaporation rates exceeded precipitation rates. 29 Without the addition of brackish water from the Upper Floridan aquifer, the net evaporation vs. 30 precipitation rate would have caused the salinity in the CCS to increase more than was 31 observed. However, the addition of Upper Floridan aquifer water helped to moderate the effects 32 of the dry season (typically, November - April) on the CCS. For example, CCS salinities during 33 the dry seasons of 2014 and 2015, which were not as dry as 2017, exceeded 90 PSU, while the 34 addition of brackish water from the Upper Floridan aquifer and saltwater from the marine wells 35 was effective in keeping CCS salinities below 70 PSU in the 2017 dry season. The modelers 36 anticipate that under more favorable climatic conditions (e.g., less severe dry seasons), the 37 addition of Upper Floridan aquifer water should help to reduce CCS water salinities to 34 PSU 38 (FPL 2017a, FPL 2017b). 39 As previously stated, in compliance with the June 20, 2016, consent order executed by FPL and 40 the FDEP, if FPL fails to reach an annual average salinity of at or below 34 PSU by the required 41 time periods, FPL is required to submit a plan to the FDEP detailing additional measures, and a 42 timeframe, that FPL will implement to achieve the threshold (see Salinity Management Plan) 43 (FDEP 2016a). Thus, continued actions by FPL and regulatory oversight by the FDEP provide 44 assurance that the CCS should reach the required PSU levels within or close to the designated 45 period. 3-49

1 Ammonia and Nutrients within Biscayne Bay and Card Sound 2 If the concentration of nutrients in either Biscayne Bay or Card Sound get too high, they can 3 negatively impact the aquatic ecology. Excess nutrients can cause algae blooms (thick green 4 algae mats that can be toxic), deplete oxygen in the water, and reduce water clarity. The State 5 of Florida (with the approval of the EPA) has established numeric nutrient criteria for Biscayne 6 Bay and Card Sound. These water quality standards help to protect the quality of the surface 7 water in the bay and the sound, consistent with the requirements of the Clean Water Act 8 (EPA 2014c). The numeric nutrient criteria include criteria for phosphorus, chlorophyll, and total 9 nitrogen, of which ammonia is a contributor (FDEP 2018e). 10 Biscayne Bay waters are generally low in plant nutrients. This means the aquatic ecosystems 11 respond very rapidly to small nutrient enrichment, especially to increases of phosphorous. The 12 concentrations of ammonia from runoff tends to be higher in urban runoff than in wetland or 13 agricultural runoff. The Biscayne Bay watershed has a diverse agricultural, urban, and wetland 14 land use. This results in lateral differences in bay water nutrient concentrations (NPS 2011). 15 In general, ammonia concentrations are higher in the northern portion of Biscayne Bay, which is 16 most urbanized, while the lowest values are next to the Turkey Point site in Biscayne Bay and in 17 Card Sound. Seasonal ammonia values in the bay are lowest late in the dry season, with higher 18 concentrations and increased variability during the wet season (peaking in September or 19 October) (NPS 2011). 20 Sampling data by Miami-Dade County and FPL in the late fall and winter months of 2015-2016 21 revealed levels of ammonia concentration that exceeded the Countys water quality standard for 22 ammonia (0.5 mg/L) at two surface water quality monitoring stations near the CCS in Biscayne 23 Bay (MDC 2016a). The exceedances for ammonia were detected in the Barge Turning Basin 24 and the remnant canal at Turtle Point (TPBBSW-7 and TPBBSW-8). Both areas are connected 25 to Biscayne Bay. When it was constructed, the Barge Turning Basin was excavated to a depth 26 of approximately 30 ft (9.1 m) and the Turtle Point remnant canal was excavated to a depth of 27 approximately 20 ft (6.1 m). In Biscayne Bay nearby areas have a depth to the bottom of about 28 1 to 2 ft (0.3 to 0.6 m) (FPL 2018g) (Figure 3-4). 29 The ammonia exceedances were detected in samples obtained from the bottom of these 30 excavations and close to the CCS. The low dissolved oxygen, hypersalinity, and tritium 31 concentrations found at these locations are consistent with the interpretation that, close to the 32 CCS, the water quality at the bottom of these excavations may be influenced by groundwater 33 that has been in contact with CCS waters. However, the ammonia concentrations in the bottom 34 samples were consistently higher than ammonia levels in the CCS (FPL 2016g). This implies 35 that if groundwater from the CCS was moving into these excavations, some of the ammonia in 36 the Turtle Point remnant canal and the Barge Turning Basin was coming from other sources. 37 The ammonia exceedances led to the modification of a consent agreement between the County 38 and FPL in 2016. The modified consent agreement requires FPL to prepare and implement a 39 corrective action plan to address ammonia exceedances in surface water surrounding the 40 facility including, but not limited to, waters tidally connected to Biscayne Bay (MDC 2016b, 41 FPL 2016h). 42 On April 25, 2016, the FDEP issued a warning letter to FPL concerning the sampling data by 43 Miami-Dade County and FPL in the late fall and winter months of 2015-2016 which showed 44 levels of ammonia concentration were exceeding the water quality standard for ammonia 3-50

1 (0.5 mg/L). The letter requested that FPL provide facts to assist in determining whether any 2 violations of Florida law had occurred (FDEP 2016i). 3 In response to the modified consent agreement between FPL and Miami Dade County, FPL 4 submitted a corrective action plan to Miami-Dade County on September 14, 2016. The plan 5 described a program to identify the source of the ammonia and to define its vertical and 6 horizontal extent within nearby surface waters. Under the plan, an extensive sampling and 7 analysis program was then conducted by FPL that included numerous surface water, pore 8 water, canal, and groundwater sampling locations, as well as stratified surface water sampling 9 and temporal sampling based on tidal cycles. The assessment results were evaluated in detail 10 to determine the nature and extent of ammonia at Card Sound, Turkey Point, and in remnant 11 dead-end canals and the Barge Turning Basin. In addition, an evaluation of water quality within 12 the CCS was performed (FPL 2016h, FPL 2017c). 13 The study and its conclusions are contained in an assessment published on March 17, 2017 14 (FPL 2017c). The report concluded that the elevated ammonia values are attributable to the 15 degradation of plant and animal material under anoxic (low oxygen) conditions in areas with little 16 or no mixing with other surface waters. The occurrence of ammonia appears to be limited to the 17 locations of deep stagnant anoxic water bodies. Some of the deep canal sites and many of the 18 groundwater and pore water sites were anoxic and the majority of nitrogen was in the form of 19 ammonia. The studied areas are similar to many locations in coastal Southeast Florida. 20 Regional studies of background surface water quality data for Biscayne Bay indicate that 21 ammonia can be detected at many locations that are not associated with the CCS, at levels 22 greater than 0.5 mg/L (FPL 2017c). 23 The 2017 report further concluded that the elevated ammonia values were not the result of 24 contamination attributable solely to the Turkey Point site but were the result of natural microbial 25 processes in anoxic, stagnant surface and groundwater environments (FPL 2017c). Ammonia 26 concentrations in the CCS were found to be very low, and the report therefore concluded that 27 the CCS was not the direct cause of the elevated ammonia concentrations in the Turtle Point 28 remnant canal and the Barge Turning Basin. Only surface water samples collected from the 29 bottom of the dead-end canals exceeded the Miami-Dade County standard for ammonia. 30 Outside of these areas, no exceedance of the standard was detected in any other samples 31 within Biscayne Bay near the CCS or in the CCS (FPL 2017c). 32 The 2017 report also concluded that the ammonia values are consistent with the anoxic 33 conditions that exist at the bottom of remnant canals and the accumulation of organic matter 34 falling into the remnant canals from surrounding areas of the bay. Based on the information 35 obtained, additional work and a corrective action plan were not recommended (FPL 2017c). 36 On May 16, 2016, FPL submitted to the FDEP the nutrient monitoring results from certain 37 surface water monitoring stations in deep channels adjacent to the CCS for total nitrogen, total 38 phosphorous, and total Kjeldahl nitrogen. The FDEP reviewed this information and determined 39 that no exceedances of surface water quality standards were detected in Biscayne Bay 40 monitoring (FPL 2016a). However, to minimize the potential for future exceedances, the FDEP 41 ordered FPL to implement restoration projects at the Barge Turning Basin and within the 42 remnant canal at Turtle Point (FDEP 2016a). As of July 5, 2018, FPL was in the process of 43 obtaining the final permits for these restoration projects (FPL 2018f). 44 Restoration activities at the Barge Turning Basin will backfill the Barge Turning Basin up to a 45 depth of 15 ft (4.6 m) below MSL. Restoration activities at Turtle Point will backfill one-third of 3-51

1 the remnant canal up to a depth of 0.33 ft (0.1 m) below MSL (for future Mangrove Planting). 2 The rest of the remnant canal will be backfilled with a sloping fill to a final depth of 7 ft (2.1 m) 3 below MSL (FPL 2017c). The backfilled shallow portion will be stabilized with mangrove 4 plantings (FPL 2018d, FPL 2018g). This will reduce the accumulation of organic matter in these 5 deep areas and reduce or eliminate the movement of groundwater from the CCS into these 6 deep excavations connected to Biscayne Bay. Both restoration projects are to be completed 7 within the two-year timeframe required by the FDEP Consent Order (FPL 2018g). 8 Staff from Miami-Dade County reviewed the 2017 report on ammonia in surface waters and on 9 July 7, 2017, requested that FPL submit more information (MDC 2017d). On July 10, 2018, the 10 Miami-Dade County Division of Environmental Resource Management (DERM) issued a letter 11 finding that total ammonia concentrations at the Barge basin and the Turtle Point remnant canal 12 exceeded the applicable Miami-Dade County surface water standard (MDC 2018a). The DERM 13 acknowledged that the observed elevated surface water ammonia concentrations may be 14 attributable to several contributing sources, including factors not directly related to the operation 15 of the CCS; however, based on an evaluation of tritium concentrations and temperature data, 16 DERM found that the CCS is a contributing source to the ammonia concentrations in those 17 areas. 18 The DERM letter required FPL to submit a plan to address CCS nutrient impacts to groundwater 19 and surface water resources beyond the boundaries of the CCS. In the letter, DERM 20 acknowledged that management of water quality within the CCS may be effective in reducing 21 water quality impacts observed beyond the CCS facility boundaries. DERM also required FPL 22 to implement the proposed plan to fill the barge basin and the Turtle Point remnant canal 23 (MDC 2018a). 24 Salinity within Biscayne Bay and Card Sound 25 The salinity of the water in Biscayne Bay and Card Sound affects their ecosystems. Sustained 26 lower-than-seawater salinities are required to maintain the ecology of freshwater wetland, tidal 27 wetlands and mainland nearshore areas, to provide nursery habitat for fish and shellfish 28 (Audubon 2016, NPS 2012). As previously mentioned, the salinities in Biscayne Bay adjacent 29 to the Turkey Point site and Card Sound are most affected by the amount of precipitation that 30 falls in and around the bay and the sound. Also, depending on the hydraulic head in the 31 underlying Biscayne aquifer relative to the head (water levels) in Biscayne Bay, water in the 32 Biscayne Bay (and therefore salt), either moves from Biscayne Bay into the underlying aquifer 33 or from the underlying aquifer into Biscayne Bay. 34 Within Biscayne Bay and Card Sound, near-shore areas next to the mainland have a larger 35 range of salinity values than mid-bay or mid-sound locations. This is because near-shore areas 36 are more affected by freshwater inflows and evaporation than mid-bay and mid-sound locations 37 (NRC 2016a). 38 The surface water monitoring program, which, in addition to surface water samples, includes 39 pore water samples and shallow monitor well samples in the Bay, has not detected a 40 discernable effect from the CCS on the salinity of Biscayne Bay or Card Sound (FPL 2016a, 41 FPL 2018f). 3-52

1 Ammonia and Nutrients and Salinity within Marsh Land and Mangrove Areas 2 The monitoring program has not detected evidence in the surrounding marsh and mangroves 3 areas of any impacts of ammonia, nutrients, or salinity from the CCS on soil pore water quality 4 via the groundwater pathway (FPL 2014b, 2016a, 2017a, 2018f). 5 Ammonia and Nutrients and Salinity within Adjacent Canals 6 On the west side of the CCS, the interceptor ditch (which is about 18 ft (5.5 m) deep), serves to 7 keep groundwater under the CCS from moving west into the L-31E canal. However, there is no 8 interceptor ditch along the southern boundary of the CCS (Figure 3-4). Within the CCS, the 9 canal that runs along the southern boundary is 20 ft (6.1 m) deep. The S-20 canal and the Card 10 Sound remnant canal lie adjacent to the CCS with no intervening interceptor ditch. At these 11 locations, the S-20 Canal is 5 ft deep and the Card Sound remnant canal is more than 20 ft 12 (6.1 m) deep (FPL 2014b). Therefore, due to their close proximity to the CCS, these are 13 locations where CCS water may more readily move into an adjacent canal via the groundwater 14 pathway. 15 With the following exceptions, no readily apparent impacts of ammonia, other nutrients, and 16 salinity on surface water quality in canals adjacent to the Turkey Point site, from the CCS via the 17 groundwater pathway, have been detected (FPL 2016a). During the June 2014 to May 2015 18 monitoring period, monitoring detected an intermittent influence from the CCS at two monitoring 19 locations in canals immediately adjacent to the CCS. One station is located in the S-20 canal 20 and one station is located in the Card Sound remnant canal. The identification of CCS influence 21 was determined based on small temperature variations and higher tritium and salinity values 22 than would normally be expected. However, no readily discernible influence from the CCS was 23 detected at these locations during the June 2013 to May 2014 monitoring period or the 24 June 2016 to May 2017 monitoring period (FPL 2012a, FPL 2014b, FPL 2017a). Minimal, if 25 any, influence on surface water quality was detected where the canals connect to Card Sound 26 (FPL 2016a). 27 On July 10, 2018, the Miami-Dade County DERM issued a letter stating that total ammonia 28 concentrations at some sampling locations in the Card Sound remnant canal, the S-20 canal, 29 and in the Sea-Dade remnant canal, exceeded the applicable Miami-Dade County surface water 30 standard. This letter acknowledged that the elevated surface water ammonia concentrations 31 may be attributable to several contributing sources, including factors not directly related to the 32 operation of the CCS; however, based on an evaluation of tritium concentrations and 33 temperature data, the DERM found that the CCS is a contributing source to the ammonia 34 concentrations in these areas (MDC 2018a). The DERM also acknowledged that the 35 management of water quality within the CCS may be effective in reducing water quality impacts 36 beyond the CCS boundaries, and it required FPL to submit a plan to address CCS nutrient 37 impacts to groundwater and surface water resources beyond the boundaries of the CCS 38 (MDC 2018a). 39 3.5.2 Groundwater Resources 40 Groundwater includes all water below the ground surface, usually within a zone of saturation. 41 Aquifers contain groundwater in sufficient volume to supply wells, springs, and surface water. 3-53

1 3.5.2.1 Hydrogeology and Aquifers 2 The NRC staffs EIS for the Turkey Point, Units 6 and 7 combined licenses (NUREG-2176) 3 contains an extensive description and evaluation of the hydrogeologic system of the southern 4 Miami-Dade County region, focusing on the Turkey Point site (NRC 2016a). The summaries of 5 site hydrogeology in this section of the SEIS are primarily based on NUREG-2176, as well as 6 on FPLs environmental report submitted as part of the Turkey Point subsequent license 7 renewal application (FPL 2018f). Where appropriate, the NRC staff has summarized referenced 8 information or incorporated information by reference into this SEIS so that the following 9 subsections can focus on new and potentially significant information since initial license renewal 10 of Turkey Point Units 3 and 4 in 2002. The discussions and analyses that follow focus on 11 aspects of the aquifer systems and the interactions with ongoing Turkey Point operations 12 including the CCS, also called the industrial wastewater (IWW) facility. For a detailed 13 description of the CCS, see Section 3.1.3, Cooling and Auxiliary Water Systems, of this SEIS. 14 Two major aquifer systems underlie the region and the Turkey Point site: (1) the surficial aquifer 15 system consisting of the Biscayne aquifer, and (2) the deeper Floridan aquifer system 16 (FPL 2018f, NRC 2016a). Figure 3-6 in Section 3.4 of this SEIS shows the orientation, depths, 17 and thicknesses of the aquifers beneath the Turkey Point site, including the named stratigraphic 18 units and the lithologies (rock types) comprising them. 19 During the NRC staffs June 2018 environmental site audit (NRC 2018c), the staff toured the 20 facilities and locations discussed below, including the CCS and related structures, Upper 21 Floridan aquifer production (i.e., CCS freshening) well locations, hypersaline recovery wells and 22 the associated deep injection well, and the Turtle Point and Barge Basin restoration project 23 sites. 24 Biscayne Aquifer 25 As illustrated in Figure 3-6 (see Section 3.4) and as described in NUREG-2176 (NRC 2016a), 26 the Biscayne aquifer is the principal aquifer beneath southeast Florida that is used for water 27 supply. It extends from the land surface to a depth of approximately 140 feet (43 m) beneath 28 the Turkey Point, Units 3 and 4 site. It is generally an unconfined (water table) aquifer, but it 29 may be semiconfined or confined on a localized basis due to the occurrence of less permeable 30 strata (FPL 2018f, NRC 2016a). 31 Section 2.3.1.2, Hydraulic Properties of Biscayne Aquifer, of NUREG-2176 (NRC 2016a) 32 describes the permeable limestones and calcareous sandstones forming the Biscayne aquifer 33 as highly heterogeneous with varying hydraulic properties that may comprise one or more 34 aquifers separated by locally confining units. Section 2.3.1.2 of NUREG-2176 also describes 35 the differences and the inherent hydrogeologic properties of the Biscayne aquifer including 36 porosity, transmissivity, and hydraulic conductivity (NRC 2016a: 2-49-2-51). The NRC staff 37 incorporates that information into this SEIS by reference. 38 The low topographic relief of the Turkey Point site relative to sea level makes the site subject to 39 tidal inundation. As such, the waters of the Biscayne aquifer are highly saline below the Turkey 40 Point site. To the east of the site, the Biscayne aquifer is recharged by the saline waters of 41 Biscayne Bay. Freshwater recharge of the Biscayne aquifer occurs from precipitation primarily 42 during the wet season (June to October) with minimal recharge during the dry season 43 (November to May). It is likely that some freshwater recharge also occurs during the wet 44 season from freshwater marshes and sheet flow runoff. Seepage from freshwater canals 3-54

1 usually continues to recharge the aquifer during the dry season (NRC 2016a). In general, the 2 Biscayne aquifer water table responds rapidly to precipitation as well as to tidal fluctuations 3 (FPL 2018f). 4 Under natural conditions and with adequate inland recharge of freshwater, the water table in a 5 surficial aquifer like the Biscayne aquifer is higher than the average sea-level elevation, which 6 balances the higher density of seawater. In such a case, the freshwater-saltwater interface 7 (interface), the most inland point marking the diffusion boundary between freshwater and 8 seawater, is relatively stable near the coastline or offshore. This is conceptually illustrated in 9 Figure 3-11. 10 Source: Barlow 2003 11 Figure 3-11 Generalized Diagram of the Freshwater-Saltwater Interface in a Coastal 12 Water Table Aquifer 13 When the aquifer water table is lowered by pumping or canal drainage, saltwater can move 14 inland, usually at the base of the aquifer because of the higher density of seawater relative to 15 freshwater. Prior to urban and agricultural development and the construction of canals to drain 16 inland areas, wet season recharge to groundwater was greater than it is today and subsurface 17 flows of groundwater into Biscayne Bay adjacent to the Turkey Point site were also higher 18 (NRC 2016a). 19 Regionally, reduced surface water runoff and groundwater discharge to Biscayne Bay, 20 combined with pumping of groundwater for irrigation, water supply, and other uses, has caused 21 saltwater to migrate inland along the base of the Biscayne aquifer. This process is known as 22 saltwater intrusion or encroachment (FPL 2018f, NRC 2016a). 23 The Turkey Point cooling canal system (CCS) (described in Section 3.1.3, Cooling and 24 Auxiliary Water Systems) is a large, enclosed, hypersaline (i.e., having a salinity greater than 25 that of natural seawater, with chloride concentration exceeding 19,000 mg/L) water body, 26 formed by excavation into the underlying bedrock. The CCS affects the hydrology and 27 groundwater quality of the Biscayne aquifer. The CCS is unlined and hydraulically connected to 28 the upper Biscayne aquifer because permeable aquifer strata permit the movement of water 29 between the aquifer and the CCS. The rate and direction of this water movement depend on 3-55

1 the head differences between the CCS and the Biscayne aquifer (FPL 2018f, NRC 2016a). 2 Because of the movement of the hypersaline CCS water into the Biscayne aquifer, there is an 3 area of higher salinity water in the aquifer beneath the CCS and adjoining portions of the Turkey 4 Point site, called the hypersaline plume. As FPL describes in its environmental report, over the 5 operational life of the CCS, the annual average salinity of both the waters within the CCS and 6 within the hypersaline plume beneath it in the Biscayne aquifer have increased. Over the 7 operational life of the CCS, the size of the hypersaline plume has also grown larger. In its 8 environmental report, FPL states that the hypersaline plume now extends out approximately 9 1.5 mi (2.4 km) west of the CCS boundary (FPL 2018f). 10 In the wider vicinity of Turkey Point, the regional groundwater flow in the Biscayne aquifer is 11 generally to the east towards the coast. However, more directly under and near the Turkey 12 Point site, groundwater flow is affected locally by tides and drainage canals (NRC 2016a). In 13 the NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses, Section 2.3.1.2, 14 Groundwater Flow Direction, (NUREG-2176) (NRC 2016a) describes in some detail the 15 complex flow interactions between the CCS, the operation of the CCS interceptor ditch and 16 adjacent L-31E Canal, and the hydrologic and density-driven dynamics of the hypersaline 17 plume. As mentioned in the previous paragraph, the hypersaline plume has grown in size and 18 moved laterally beyond the CCS and the bordering L-31E Canal, predominantly to the west 19 within the deeper part of the Biscayne aquifer. The NRC staff incorporates the information in 20 Section 2.3.1.2 of the COL EIS here by reference (NRC 2016a: 2-51, 2-53). In this SEIS, 21 Section 3.1.3.2, Cooling Canal System (CCS), describes the interceptor ditch. The current 22 extent of the hypersaline plume emanating from the CCS and its effects on groundwater quality 23 and saltwater intrusion are further discussed below in Section 3.5.2.2, Groundwater Quality. 24 Intermediate Confining Unit 25 Separating the surficial Biscayne aquifer and the Floridan aquifer system is the hydrogeologic 26 unit called the Intermediate Confining Unit (see Figure 3-6 in Section 3.4). This unit has a 27 generally low permeability and is over 800 feet (240 m) thick beneath the Turkey Point site. It is 28 comprised of extensive layers of clay-rich sediments in the upper part of the unit (NRC 2016a). 29 Sands and limestone lenses comprise the permeable parts of this unit (Figure 3-6). Site 30 information suggests that the thickness ranges from approximately 700 feet (210 m) just to the 31 north of the Turkey Point site (at Unit 5 production well PW-3) to about 1,000 feet (300 m) 32 southwest of the site. The Intermediate Confining Unit serves as an effective aquiclude (an 33 impermeable layer or rock or stratum or sediment) for the Floridan aquifer system throughout 34 the state of Florida (FPL 2018f). 35 Floridan Aquifer System 36 The Floridan aquifer system underlies the Intermediate Confining Unit. The system is 37 composed principally of dolomite and limestone and is under confined conditions beneath the 38 Turkey Point site and throughout southeastern Florida. The Floridan aquifer system at the 39 Turkey Point site principally consists of the Upper Floridan aquifer, a middle confining unit, and 40 the saline Lower Floridan aquifer (FPL 2018f, NRC 2016a) (Figure 3-6). 41 The Upper Floridan aquifer is composed of several thin water-bearing zones interlayered with 42 thick zones of low permeability. Across most of Florida, it is a major source of potable water; 43 however, in southeastern Florida, including Miami-Dade County, the water is brackish and 44 requires treatment to meet drinking water standards. While the aquifer can be 400 feet (120 m) 45 or more in thickness across southeastern Florida, at the Turkey Point site, it is approximately 3-56

1 200 feet (60 m) thick (FPL 2018f). Regionally, groundwater flow in the aquifer is generally west 2 to east across the site toward the coast. This is confirmed by groundwater level data from 3 Upper Floridan aquifer wells located near the Turkey Point site (FPL 2018f, NRC 2016a). 4 The middle confining unit within the Floridan aquifer system consists of beds of less permeable 5 strata that are more than 1,000 feet (300 m) thick, separating the aquifers above and below 6 (FPL 2018f). As described in Section 2.3.1.2 of NUREG-2176, the middle (Floridan) confining 7 unit generally contains a relatively thin, permeable zone called the Avon Park Permeable (or 8 Producing) Zone (APPZ), and a lower confining zone (see Figure 3-6 in Section 3.4 of this 9 SEIS). However, the Avon Park zone thins to the south and was not identified at the EW-1 10 exploratory well at Turkey Point (NRC 2016a). 11 The upper part of the Lower Floridan aquifer is comprised of low permeability (confining layer) 12 rocks; the deeper part of the Lower Floridan aquifer is a well-developed, highly permeable karst 13 region of fractured carbonate rock known as the Boulder Zone (FPL 2018f, NRC 2016a). The 14 high permeability of the Boulder Zone has been attributed to a network of horizontal caverns at 15 varying depths connected by vertical tubes. Water quality in the Boulder Zone is similar to 16 modern seawater. Within the Boulder Zone, it appears that seawater moves westward from a 17 connection with the Atlantic Ocean off the coast at a depth of about 2,500 feet (760 m). At the 18 Turkey Point site, the top of the Boulder Zone has been identified at a depth of 3,030 feet 19 (994 m). This depth is consistent with statewide mapping (NRC 2016a). 20 3.5.2.2 Groundwater Quality 21 Groundwater Quality Standards and Current Designated Uses 22 The FDEP classifies groundwater within the State of Florida according to present and future 23 most beneficial uses. The State of Florida establishes water quality standards to protect 24 designated uses (FAC R62-520.300). Florida categorizes groundwater in one of five classes 25 (FAC R62-520.410). These five classes generally relate to the level of potability (i.e., use for 26 drinking and related purposes) as determined by total dissolved solids (TDS) content. 27

• Class F-I: Potable water use, groundwater in a single source aquifer described in FAC 28 R62 520.460, with a total dissolved solids content of less than 3,000 mg/L and 29 specifically reclassified as Class F-I by the Florida Environmental Regulation 30 Commission.

31

• Class G-I: Potable water use, groundwater in a single source aquifer that has a total 32 dissolved solids content of less than 3,000 mg/L and specifically reclassified by the 33 Florida Environmental Regulation Commission.

34

• Class G-II: Potable water use, groundwater in aquifers with a total dissolved solids 35 content of less than 10,000 mg/L, unless otherwise classified by the Florida 36 Environmental Regulation Commission.

37

• Class G-III: Nonpotable water use, groundwater in unconfined aquifers with a total 38 dissolved solids content of 10,000 mg/L or greater; or with a total dissolved solids 39 content of 3,000-10,000 mg/L and either reclassified by the Florida Environmental 40 Regulation Commission as having no reasonable potential as a future source of drinking 41 water or designated by the FDEP as an exempted aquifer.

42

• Class G-IV: Nonpotable water use, groundwater in confined aquifers with a total 43 dissolved solids content of 10,000 mg/L or greater.

3-57

1 The State of Florida provides single-source aquifersthose aquifers it identifies as the only 2 reasonably available source of potable water to a significant segment of the populationwith 3 the highest level of protection. The FDEP designates such aquifers as Class F-1 and G-I, which 4 have TDS concentrations of less than 3,000 mg/L (FAC R62-520.410). For comparison, the 5 Federal drinking water standard or secondary maximum contaminant level (MCL) for TDS is 6 500 mg/L (40 CFR 143.3). This secondary standard is based on aesthetic considerations 7 (i.e., taste, color, and odor) and the constituent does not present a risk to human health at the 8 specified level. The FDEP has adopted the same secondary standard for Florida drinking water 9 (FDEP 2018b). 10 Beneath the Turkey Point site and across southeastern Miami-Dade County, the quality of 11 groundwater within the Biscayne and Floridan aquifer systems varies greatly due to the 12 interaction of natural as well as human-induced factors over time. This is most apparent in the 13 surficial Biscayne aquifer as saltwater intrusion (encroachment) has occurred under a large area 14 of the southeast Florida coast, including under the Turkey Point site. 15 The NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) 16 (NRC 2016a) cites a U.S. Geological Survey (USGS) study (Prinos et al. 2014) investigating the 17 origins and extent of saltwater intrusion in the Biscayne aquifer. In the study, the USGS 18 presented its analysis of tritium measurements from USGS monitoring wells within about 6 mi 19 (10 km) of the Turkey Point site, which indicated that water from the CCS may contribute to 20 saltwater encroachment in areas northwest of the CCS (Prinos et al. 2014). 21 FPL states in its environmental report (FPL 2018f) that, even before construction of the CCS in 22 the mid-1970s, the Biscayne aquifer near the Turkey Point site was saline for the full depth of 23 the aquifer, and saltwater intrusion into the Biscayne aquifer had already occurred several miles 24 inland (FPL 2018f). This is supported by information in the NRC staffs EIS for the Turkey Point 25 Units 6 and 7 combined licenses (NUREG-2176), Section 2.3.3.2 and Figure 2-22. The NRC 26 staff incorporates Section 2.3.3.2 and Figure 2-22 of NUREG-2176 into this SEIS by reference. 27 NUREG-2176, Figure 2-22 depicts various mapped estimates by the USGS and others of the 28 saltwater interface over the period of 1951 to 2008. These USGS historic estimates depict 29 interface locations that are no less than about 4 mi (6.6 km) west and northwest of the CCS. 30 NUREG-2176, Section 2.3.3.2 contains the NRC staffs characterization of factors contributing 31 to saltwater intrusion, including contributions from the CCS (NRC 2016a: 2-68, 2-69). 32 Inland migration of the saltwater interface within the Biscayne aquifer continues across the 33 region. Based on a recent USGS estimate, the saltwater interface has moved inland across 34 portions of southeastern Miami-Dade County, west and north of the Turkey Point site, at an 35 average rate of 460 feet (140 m) per year (Prinos 2017). Figure 3-12 below depicts the current 36 location of the saltwater interface at the base of the Biscayne aquifer in relation to the Turkey 37 Point site, the CCS, and groundwater monitoring wells maintained by FPL. The saltwater 38 interface is currently located about 4.7 mi (7.6 km) west of the CCS at its closest point, based 39 on the latest (2017) USGS monitoring well data. The mapped location reflects the current 40 estimate of the 1,000 mg/L concentration boundary for chloride at the base of the Biscayne 41 aquifer (Prinos 2017). 42 In 1983, the FDEP designated as Class G-Ill (i.e., non-potable use with TDS levels of 43 10,000 mg/L or greater) the surficial groundwater (Biscayne aquifer) within the Turkey Point 44 plant property, with the west side of the CCS marking the western boundary (FPL 2018f, 45 SFWMD 2009). FDEP has classified groundwater west of the Turkey Point site (i.e., to the west 3-58

1 of the site boundary and CCS) as Class G-II, which means potable water use, with TDS levels 2 of less than 10,000 mg/L (FPL 2018f). 3 In 2014, the FDEP issued an administrative order to FPL. In this 2014 administrative order, the 4 findings of fact state that saltwater was present as early as the 1940s near the base of the 5 Biscayne aquifer west of the Turkey Point site. It further states that groundwater data from the 6 early 1970s (prior to completion of CCS construction in 1973) supported the determination that 7 non-potable groundwater (TDS exceeds 10,000 mg/L) occurred beneath much of the proposed 8 CCS at depth and within the deeper portions of the aquifer west of the site (FDEP 2014). 9 Through wells located inland of the saltwater interface, the Biscayne aquifer is the major public 10 water supply source across Miami-Dade County as well as for the Florida Keys (NRC 2016a: 2-11 60). In addition, the EPA has designated the Biscayne aquifer across all of south Florida as a 12 sole-source aquifer pursuant to Section 1424(e) of the Safe Drinking Water Act of 1974 13 (EPA 2016a, FPL 2018f, NRC 2016a). 14 The Biscayne aquifer is not the only current or potential source of drinking water in the region. 15 The Upper Floridan aquifer is also an important source of freshwater in parts of Florida. The 16 FDEP designates the Upper Floridan aquifer as an underground source of drinking water 17 because its water has a TDS concentration of less than 10,000 mg/L (FAC R62-528.200, 18 NRC 2016a). However, while the groundwater within the Upper Floridan aquifer contains less 19 than 10,000 mg/L TDS in southeastern Florida, with TDS concentrations greater than 20 2,000 mg/L, water obtained from the aquifer is too saline to be used for drinking water without 21 treatment (NRC 2016a). 3-59

1 Source: Modified from FPL 2017a Fig. 1.1-1 2 Figure 3-12 Groundwater Monitoring Locations and Saltwater Interface, Turkey 3 Point Site 3-60

1 Baseline Groundwater Quality and Changes Attributable to Turkey Point Operations 2 The SEIS for the Turkey Point Units 3 and 4 initial license renewal (NUREG-1437, 3 Supplement 5) (NRC 2002c) documents the NRC staffs environmental review of FPLs 4 application for the initial 20-year license renewal submitted in 2000. Section 2.1.3 of that EIS 5 describes the likely exchange between the canals and groundwater as well as the operation of 6 the CCS and associated interceptor ditch. As stated therein, the operation of the interceptor 7 ditch was intended to prevent the flow of hypersaline water from the cooling canals toward the 8 Everglades (i.e., inland to the west) (NRC 2002c). 9 Thus, when the NRC staff published its SEIS for the Turkey Point initial license renewal in 2002, 10 the staff acknowledged the existence of a hypersaline plume in the Biscayne aquifer directly 11 beneath the CCS. What was not fully understood at the time was the potential for the 12 hypersaline plume to migrate downward through the Biscayne aquifer and then to move laterally 13 within the Biscayne aquifer beyond the CCS boundaries. The following discussion presents 14 new information on the effects of CCS operations on hypersalinity in the Biscayne aquifer and 15 groundwater quality. 16 The interaction of water in the CCS (including cooling loop water and stormwater from Turkey 17 Point) with underlying groundwater in the Biscayne aquifer is complex. In the CCS, heat is 18 rejected to the atmosphere primarily through evaporation, resulting in a net loss of water from 19 the canals. As water evaporates from the CCS, the concentration of dissolved substances, 20 principally salts, in the CCS increases. This increases the density of the CCS water. The high 21 rate of evaporation also produces a net inflow of groundwater into the CCS, but the groundwater 22 flux between the CCS and Biscayne aquifer varies by location. The following variables and 23 factors also affect these groundwater interactions between CCS waters and Biscayne aquifer 24 waters: 25

• precipitation, specifically seasonal precipitation variation during the wet season versus 26 the dry season 27
• variations in hydraulic head (water table elevation) 28
• cooling water effluent discharge rate 29
• air temperature 30
• humidity 31
• tidal fluctuations 32 As a result of the above variables, the direction of water movement into or out of the CCS varies 33 in time and space. Over time, the denser, heated, hypersaline water migrates downward from 34 the CCS into the Biscayne aquifer. The downward movement of hypersaline water is impelled 35 by the increased density because of the elevated salinity of the water in the CCS (NRC 2016a).

36 In preparing the EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) 37 (NRC 2016a), the NRC staff reviewed modeling performed by Hughes et al. (2010), which used 38 a two-dimensional, cross-section model to evaluate the combined effects of salinity, 39 temperature, and other variables associated with operation of the CCS, including the CCSs 40 contribution to the movement of the saltwater interface. The Hughes modeling demonstrates 41 that the downward migration of hypersaline water takes the form of finger plumes that form 42 beneath the CCS and then move downward to the bottom of the permeable zone of the aquifer 3-61

1 in a period ranging from days to several years, depending on localized differences in aquifer 2 properties. These finger plume structures then mix with aquifer water through advection and 3 dispersion (NRC 2016a). The modeling also indicates that the inland migration of the saltwater 4 interface is closely related to TDS concentrations in the CCS (Hughes et al. 2010). 5 FPL operates the interceptor ditch to maintain an eastward hydraulic gradient (toward the CCS). 6 However, this operation has not completely prevented the hypersaline CCS water that enters 7 the Biscayne aquifer from migrating westward. This is primarily because the interceptor ditch 8 only functions to the depth to which it was constructed, as described in Section 3.5.1.1, Surface 9 Water Hydrology, thus enabling hypersaline water that has moved to deeper depths in the 10 aquifer to move beyond and west of the interceptor ditch. 11 Since 2009, FPL has maintained an extensive, multimedia environmental (uprate-related) 12 monitoring program in accordance with Turkey Points site certification conditions 13 (i.e., Conditions IX and X), as modified (FDEP 2016b, State of Florida Siting Board 2016) 14 pursuant to the Florida Power Plant Siting Act and related regulatory requirements, stemming 15 from the NRCs June 2012 approval of the Turkey Point extended power uprate (EPU) project. 16 The focus of this uprate monitoring program is to determine the horizontal and vertical effects of 17 CCS water on the environment. FPL conducts this program in accordance with the 2009 18 monitoring plan (SFWMD 2009) under the auspices of the FDEP, SFWMD, and the Miami-Dade 19 County Department of Environmental Resources Management (DERM). 20 FPL completed a period of pre-uprate monitoring in 2012, covering the period of June 2010 21 through June 2012, and submitted it for interagency review in October 2012 (FPL 2018f, 22 FPL 2012a). Monitoring results are reported in publicly available annual monitoring reports 23 submitted to the FDEP and partner agencies including the South Florida Water Management 24 District and Miami-Dade County. To date, the results of FPLs groundwater uprate monitoring 25 demonstrate that CCS operations have impacted groundwater quality in the Biscayne aquifer to 26 the west of the L-31E Canal as well as beneath Biscayne Bay to the east (NRC 2016a). 27 For groundwater monitoring, FPLs contractor performs quarterly field sampling from 14 well 28 clusters, comprising 42 wells in total. This is in addition to automated water quality and water 29 level measurements at each well (FPL 2017a). Each well cluster consists of three, collocated 30 Biscayne aquifer monitoring wells (i.e., shallow, intermediate, and deep), which are shown 31 above in Figure 3-12. 32 For each monitoring well, FPL collects and analyzes groundwater samples for 29 separate 33 parameters, including general water quality parameters (e.g., temperature, pH), ionic, and 34 nutrient constituents. Tritium is used as a chemical tracer in order to determine the potential 35 movement of CCS water within the Biscayne aquifer (FPL 2017a, SFWMD 2009). Specifically, 36 by interagency consensus, tritium was established as a tracer for the CCS water with a 37 threshold concentration value for tritium of 20 pCi/L in groundwater (FPL 2012a). Table 3-4 38 below summarizes the latest available analytical results for selected wells and key monitored 39 parameters. 3-62

1 Table 3-4 Summary of Groundwater Monitoring Results for Selected Biscayne Aquifer 2 Wells (Shallow and Deep Intervals), Turkey Point Uprate Monitoring Program Parameter Results(a), Current (2017)(b) and Historic (2011)(c) Well Number Chloride TDS Salinity Tritium Ammonia (PSU) (pCi/L) TPGW-1S (2017) 16,400* 27,500 28.41 698 1.08 TPGW-1D (2017) 29,900 19,400* 47.60 2,365 1.62* TPGW-1S (2011) 17,000 27,000 27.8 810 0.87 TPGW-1D (2011) 29,000 50,000 48.1 2,560 1.3 TPGW-2S (2017) 26,700 33,400 41.67 1,955 1.61* TPGW-2D (2017) 35,800* 43,400 49.95* 3,101 2.22* TPGW-2S (2011) 30,000 50,000 52.4 3,030 1.5 TPGW-2D (2011) 32,000 52,000 54.2 3,320 1.7 TPGW-4S (2017) 1,220 2,190 2.12 17.4 M TPGW-4D (2017) 17,200* 19,400 26.82 403 M TPGW-4S (2011) 670 1,400 1.4 19.4 M TPGW-4D (2011) 16,000 26,000 28.0 519 M TPGW-7S (2017) 33.8 270 0.27* 4.2*U M TPGW-7D (2017) 3,400* 5,400 5.42 26.6 M TPGW-7S (2011) 35 300 0.3 13.5 M TPGW-7D (2011) 42 310 0.3 2.2 M TPGW-9S (2017) 23.3 334 0.29* 9.7*U M TPGW-9D (2017) 25.7 348 0.31* -4.5*U M TPGW-9S (2011) 20 330 0.3 10.6 M TPGW-9D (2011) 28 350 0.3 1.5 M TPGW-10S (2017) 21,800* 28,600 36.25 69.1 0.56 TPGW-10D (2017) 28,400 36,100 47.68 1,690 1.45 TPGW-10S (2011) 19,000 33,000 33.8 18.4 0.32 TPGW-10D (2011) 22,000 36,000 37.4 8.2 0.22 TPGW-11S (2017) 23,500 17,400* 36.17 -5.6*U M TPGW-11D (2017) 26,900 35,300 44.3 1,066 M TPGW-11S (2011) 22,000 36,000 36.9 2.4 M TPGW-11D (2011) 24,000 39,000 39.3 435 M TPGW-13S (2017) 36,500 47,700 55.8 4,122 3.69* TPGW-13D (2017) 34,800 48,000 58.27 3,674 3.66* TPGW-13S (2011) 38,000 61,000 61.6 3,800 2.8 TPGW-13D (2011) 37,000 59,000 59.2 3,830 1.6 TPGW-14S (2017) 22,900 29,100 39.03 91.5 0.551 TPGW-14D (2017) 32,800 37,600 49.5 2,234 2.33 TPGW-14S (2011) 24,000 39,000 40.0 247 0.54 TPGW-14D (2011) 32,000 52,000 51.8 2,660 1.6*- Notes: D=deep well; S=shallow well; TDS=total dissolved solids. *=Denotes result qualified as estimated (+/- indicates bias); M=Denotes missing data; U=Indicates analyzed for but not detected at the reported value. Some results in the table may be rounded. 3-63

Parameter Results(a), Current (2017)(b) and Historic (2011)(c) (a) All units are reported in milligrams per liter (mg/L) except salinity (reported in practical salinity units (PSU) based on the practical salinity scale of 1978) (unitless) and tritium (picoCuries per liter (pCi/L) with 1 uncertainty error omitted). Ammonia is reported as total ammonia nitrogen. (b) Analytical results from the March 2017 quarterly sampling event (FPL 2017a). (c) Analytical results from the March 2011 quarterly sampling event (FPL 2012a). Source: FPL 2012a, FPL 2017a. 1 Monitoring well locations were established based on FPL and interagency consensus and 2 criteria as documented in the 2009 monitoring plan (SFWMD 2009). The wells are located such 3 that monitoring will be able to detect changes in groundwater quality, including migration of the 4 hypersaline plume, both in the near field (adjacent to the CCS) and at representative far-field 5 locations (i.e., at distances not currently identified as having been affected by CCS water). For 6 example, wells TPGW-13S/D are at the approximate center of the CCS, the source of the 7 hypersaline plume. Wells TPGW-1 through TPGW-7 are situated at various distances to the 8 north and west of the CCS. Well cluster TPGW-7S/D can also be considered a sentinel well as 9 it is the monitoring location nearest to the Miami-Dade Countys Newton Wellfield that supplies 10 potable water to municipal customers. Well location TPGW-9S/D is a reference well location 11 reflecting groundwater conditions unaffected by the CCS and located upgradient (west) of the 12 saltwater interface. Well locations TPGW-10S/D, TPGW-11S/D, TPGW-13S/D, and 13 TPGW-14S/D are offshore in Biscayne Bay. 14 As summarized in Table 3-4 above, the analytical results from FPLs monitoring program 15 include the deep-screened interval (Biscayne aquifer) of the listed well locations that 16 corresponds to the base of the Biscayne aquifer, as well as from the shallow (upper) interval, in 17 order to identify any vertical differences in water quality parameters. It is in the lower intervals 18 of the aquifer where hypersaline water from the CCS would be expected to preferentially move, 19 as well as where migration of the regional saltwater interface would first be evident. 20 Further, Table 3-4 compares quarterly groundwater sampling results for the same seasons (i.e., 21 March 2011 and March 2017) so that results for monitored parameters at the well locations can 22 be compared over time. March is near the end of the dry season across southeast Florida and 23 is the timeframe where the effects of CCS water incursion would likely be more discernible. 24 Additionally, data from March 2011 are included to provide an historical baseline, representing 25 the pre-extended power uprate monitoring period for Turkey Point. 26 The NRC staff has used current (2017) and historical groundwater monitoring data to document 27 baseline groundwater quality as well as changes in quality in the Biscayne aquifer within and 28 adjacent to the Turkey Point site. The results reflect the current FDEP classification for Class 29 G-III groundwater (i.e., TDS of 10,000 mg/L or greater) in the area of the site, corresponding to 30 the western boundary of the CCS and encompassing the Turkey Point property to the east. The 31 current monitoring data (Table 3-5) also establish that TDS concentrations in Class G-II 32 designated groundwater immediately to the west of the CCS boundary exceed the G-II standard 33 (TDS of less than 10,000 mg/L). Monitoring results further show the influence of CCS 34 operations on groundwater quality beneath the CCS within the Biscayne aquifer and adjacent to 35 the CCS, particularly as reflected in data for wells TPGW-2D and TPGW-4D. More precisely, 36 the data presented in Table 3-4 as well as in the broader quarterly monitoring data sets 37 (June 2016, September 2016, December 2016, and March 2017) for these wells (FPL 2017a) 38 generally show an increasing vertical trend with depth (i.e., from the shallow to the deep 39 monitored intervals) in chloride, TDS, and tritium concentrations at these locations. This is 3-64

1 indicative of the influence of CCS water in the deep interval of the Biscayne aquifer. This is 2 further reflected in data for the June 2013 to May 2015 monitoring periods (FPL 2016a). 3 Similarly, tritium levels measured in wells to the east of the CCS in Biscayne Bay 4 (i.e., TPGW-10, TPGW-11, and TPGW-14) suggest the influence of CCS water, at least in the 5 deep interval of the Biscayne aquifer. For all monitored parameters at these groundwater 6 locations (TPGW-2, -4, -10, -11, and -14), the NRC staff observes that the influence of CCS 7 water was evident prior to implementation of the extended power uprate beginning in 2012. 8 In summary, the NRC staff concludes that hypersaline groundwater in the Biscayne aquifer 9 exists under and adjacent to the CCS, with hypersaline conditions diminishing with increased 10 distance from the CCS. According to FPLs 2017 annual monitoring report, the extent of 11 potential CCS influence is 4.5 mi (7.2 km) west of the CCS. This line of influence is based on 12 the current estimate of the 20 pCi/L concentration boundary for tritium in groundwater, with the 13 mapped contour line passing just west of monitoring well TPGW-7D, which is depicted below in 14 Figure 3-13. It should be noted that tritium readings of 20 pCi/L are not significant; for 15 comparison, the EPAs primary drinking water standard or maximum contaminant level for 16 tritium is 20,000 pCi/L (40 CFR 141.16). 3-65

1 Source: Modified from FPL 2017a: Fig. 5.1-4 2 Figure 3-13 Extent of Tritium in the Deep Interval of the Biscayne Aquifer in the 3 Vicinity of the Turkey Point Site, 2017 4 As described in FPLs 2017 annual monitoring report, FPL had previously estimated the 5 historical limit, prior to CCS construction, of Class G-III groundwater (non-potable water with a 6 TDS content of 10,000 mg/L or greater). FPL based this estimate on historical TDS values from 7 groundwater wells. Where historical TDS values were not directly available, FPL used the 8 relationship between measurements of specific conductance and TDS to estimate historical 9 TDS values. The 2017 annual monitoring report concludes that most of the Biscayne aquifer 10 currently affected by the CCS never contained potable water (FPL 2017a). 11 Nevertheless, and as FPLs 2017 annual monitoring report notes, monitoring has shown 12 increases in one or more constituents (e.g., chloride, tritium) in several wells over the last 4 to 5 13 years that indicate the expansion of more saline groundwater. These wells include TPGW-7D, 14 TPGW-10D, and TPGW-11D. At TPGW-7D, the water transitioned from fresh to brackish 15 between the summer of 2013 and January 2017. FPL attributed the increase in observed ion 16 concentrations (e.g., chloride) to advance of the saltwater interface, but remained uncertain 17 about the source of the higher tritium levels (i.e., 26.6 pCi/L in 2017 versus 2.2 pCi/L in 2011, 3-66

1 see Table 3-4) (FPL 2017a). Meanwhile, wells TPGW-10D and TPGW-11D, just east of the 2 CCS in Biscayne Bay, have exhibited increases in conductance, chloride, and tritium since 3 2013. FPLs 2017 annual monitoring report suggests that the increase in tritium in these wells 4 indicates a potential increase in the amount of CCS-sourced groundwater compared to the 5 original marine groundwater (FPL 2017a). 6 Current (2017) water quality monitoring results and other available well data show that a fresher 7 groundwater lens (i.e., lower chloride and TDS concentrations) exists in the upper 8 (i.e., 18 to 20 ft (5.5 to 6.1 m)) interval of the Biscayne aquifer just to the west of the CCS. This 9 lens generally thickens to over 50 feet (15 m) in depth at TPGW-7 (see Figure 3-12). Here, in 10 the shallow interval at this monitoring location (TPGW-7S), the groundwater appears to meet 11 the Class G-II criterion for potable water use with a TDS content of less than 10,000 mg/L (see 12 Table 3-4). At a distance of over 5.5 mi (8.9 km) west of the CCS (e.g., at TPGW-9, see Table 13 3-4 and Figure 3-12), the aquifer is presently fresh at all depths (FPL 2017a). 14 Regulatory Developments with Respect to Cooling Canal System Operations and Groundwater 15 Quality 16 As discussed above, beginning in 2010, FPL implemented an expanded groundwater 17 monitoring program in support of Turkey Points extended power uprate and associated 18 regulatory approvals. This expanded groundwater monitoring program helped to identify the 19 need for FPL to take corrective actions to address onsite and offsite impacts associated with 20 operation of the CCS, especially involving salinity, chloride, and ammonia concentrations 21 (FPL 2018f: 3-90, 3-91). In consultation with and at the direction of State and local regulatory 22 agencies, since 2013, FPL has undertaken a number of actions to mitigate impacts associated 23 with CCS operation. Most of these actions focus on reducing high salinities within the CCS. 24 Most recently, these actions included active measures to halt and remediate the migration of the 25 hypersaline plume from the CCS. This section of the SEIS presents a brief summary of the 26 history, the current status, and the scope of the associated regulatory mechanisms governing 27 FPLs actions focusing on groundwater quality issues. 28 In December 2014, the FDEP issued an administrative order to FPL directing, in part, that FPL 29 develop a salinity management plan for the CCS along with additional monitoring requirements 30 (FDEP 2014a, FPL 2018f). Several entities, including Miami-Dade County, challenged the 31 FDEPs 2014 administrative order. 32 On October 2, 2015, Miami-Dade County issued a notice of violation (NOV) to FPL alleging 33 violations of county water quality standards and criteria in groundwater beyond the boundaries 34 of the CCS and FPL property (FPL 2018f, MDC 2015a). Subsequently, on October 7, 2015, 35 Miami-Dade County and FPL entered into a consent agreement (the 2015 Consent Agreement). 36 In the 2015 Consent Agreement, the County recognized the salinity reduction efforts that FPL 37 was already undertaking including the use of onsite marine production wells and plans to 38 construct six wells to withdraw water from the Upper Floridan aquifer for CCS salinity reduction. 39 The 2015 Consent Agreement requires FPL to evaluate alternative water sources to offset water 40 deficits in the CCS and to reduce chloride concentration in the CCS, including the use of 41 reclaimed wastewater from the Miami-Dade South District Wastewater Treatment Plant 42 (FPL 2018f, MDC 2015a). Moreover, the 2015 Consent Agreement specifically requires FPL to 43 maintain measures to abate hypersaline water discharges and to actively remediate the 44 hypersaline groundwater west and north of FPLs property, without creating adverse 45 environmental impacts. The stipulated remedial action is the installation and operation of a 46 Biscayne aquifer recovery well system to intercept, capture, and retract the hypersaline plume 3-67

1 from the CCS to within FPLs property boundary, along with associated deep well disposal of 2 the extracted hypersaline groundwater. The Consent Agreement also requires that FPL 3 conduct additional monitoring, submit annual reports and undertake surveys (i.e., continuous 4 surface electromagnetic mapping of the hypersaline plume) to gauge progress toward meeting 5 the terms of the agreement. Finally, FPL is required to review, report, and consult on any 6 necessary changes related to the effectiveness of the recovery well system at 7 5-year and 10-year intervals (MDC 2015a). 8 On August 15, 2016, FPL and Miami-Dade County executed an addendum revising the 9 2015 Consent Agreement. The revised agreement (the 2016 Addendum) requires FPL to take 10 action to evaluate and address alleged violations of Miami-Dade County water quality standards 11 and cleanup target levels relating to the exceedance of ammonia standards in surface water, 12 including deep remnant canals adjacent to the Turkey Point CCS. The 2016 Addendum further 13 requires that FPL prepare a site assessment report to identify the sources of ammonia 14 exceedances and to delineate their extent in surface water in accordance with a site 15 assessment plan approved by Miami-Dade County (MDC 2016a). On December 29, 2016, in 16 response to the Countys comments on the draft site assessment plan, FPL submitted an 17 amended site assessment plan, and it initiated environmental sampling on January 3, 2017, as 18 approved by Miami-Dade County (FPL 2017b). FPL submitted its completed site assessment 19 report to the County on March 17, 2017 (FPL 2017c). 20 The completed ammonia site assessment report documents the results of FPLs sampling and 21 analysis program to assess the nature and extent of ammonia in surface waters near the Turkey 22 Point site and in the CCS. It includes sampling results from numerous surface water, 23 porewater, canal water, and groundwater sampling locations as well as stratified surface water 24 sampling. With respect to groundwater, FPL sampled nine monitoring wells completed in the 25 Biscayne aquifer, including: (1) four wells northeast of the Turkey Point power block (FTF-SW, 26 FTF-NW, FTF-SE, MW-5), (2) two wells east of the power block (MW-3, MW-4) adjacent to the 27 discharge canal and Biscayne Bay, (3) two wells (South MW, North MW) southeast of the power 28 block near FPLs sanitary injection well and discharge canal, and (4) one deeper well located 29 south of the Turkey Point complex in the mud flat area known as Mud Island (C6-5). While all 30 wells had detectable ammonia, the concentrations were variable, ranging from a low of 31 0.17 mg/L at MW-3 adjacent to the intake canal and Biscayne Bay to a high of 4.6 mg/L at the 32 South MW, as compared to the surface water quality standard of 0.5 mg/L. The report states 33 that the high concentration of ammonia at South MW and relatively fresh water in the well may 34 be caused by the sanitary wastewater injection well. Well C6-5 had the second highest 35 ammonia concentration (2.48 mg/L). This deeper well (C6-5) at 90 feet (27 m) was the only well 36 sampled that also exhibited hypersalinity (52.2 PSU), indicating potential CCS influence 37 (FPL 2017c). 38 In July 2017, Miami-Dade County requested that FPL collect additional data in support of the 39 ammonia site assessment report (FPL 2017b). In November 2017, FPL responded to the 40 Countys request by submitting supplemental information. In a July 18, 2018 letter, the County 41 informed FPL that it had completed its review of the site assessment report and supplemental 42 information. The Countys letter states that based on its review of FPLs ammonia data as well 43 as its review of historical groundwater monitoring data collected from the TP-GW series uprate 44 monitoring wells (e.g., TPGW-1, TPGW-2, TPGW-10, TPGW-13, and TPGW-14), there is a 45 statistically significant increasing trend in ammonia concentrations in groundwater in the 46 intermediate and deep intervals along with a concentration gradient emanating from the CCS. 47 The Countys letter directs FPL to undertake a number of additional actions, including 48 development of a revised sampling plan for ammonia in surface water and groundwater and 3-68

1 measures to reduce nutrient impacts from the CCS on surface waters and groundwater 2 (MDC 2018a). Surface water sampling results from the ammonia site assessment report are 3 discussed in Section 3.5.1.4, Adjacent Surface Water Quality and Cooling Canal System 4 Operation, of this SEIS. 5 Separately, the FDEP issued a modified final administrative order to FPL on April 21, 2016 (the 6 2016 Final Administrative Order) (FDEP 2016h, FPL 2018f). The FDEPs 2016 Final 7 Administrative Order concludes, in part, that the preponderance of the record evidence 8 indicates the CCS is the major contributing cause of the continuing westward movement of the 9 saline water interface (FDEP 2016h). 10 On April 25, 2016, the FDEP issued a warning letter (FDEP 2016c) expressing concern that 11 CCS water was reaching Biscayne Bay. Concurrently, the FDEP issued a notice of violation to 12 FPL that incorporated findings from the FDEPs April 21, 2016 Final Administrative Order and 13 specifically directed FPL to enter into consultations to develop a consent order for corrective 14 actions to abate the CCS contribution to the hypersaline plume, reduce the size of the 15 hypersaline plume, and prevent future harm to waters of the State (FDEP 2016d, FPL 2018f). 16 To resolve the warning letter and notice of violation, FPL and the FDEP executed a consent 17 order on June 20, 2016 (the 2016 FDEP Consent Order) (FDEP 2016e). The 2016 FDEP 18 Consent Order contains three primary objectives (FDEP 2016e, FPL 2018f) as well as the 19 methods FPL must use to meet each objective. The three objectives are as follows: 20

• First Objective. Cease discharges from the CCS that impair the reasonable and 21 beneficial use of the adjacent Class G-II groundwater by maintaining the average annual 22 salinity of the CCS at or below 34 PSU, by undertaking freshening activities, by 23 eliminating the CCS contribution to the hypersaline plume, by halting the westward 24 migration of hypersaline water from the CCS, and by reducing the westward extent of 25 the hypersaline plume to the L-31E Canal within 10 years, thereby removing its influence 26 on the saltwater interface without creating adverse environmental impacts.

27

• Second Objective. Prevent releases of groundwater from the CCS to surface waters 28 connected to Biscayne Bay that result in exceedances of surface water quality standards 29 in Biscayne Bay.

30

• Third Objective. Provide mitigation for impacts related to the historic operation of the 31 CCS, including but not limited to the hypersaline plume and its influence on the saltwater 32 interface. (FDEP 2016e) 33 The First Objective of the 2016 FDEP Consent Order primarily involves reducing salinity in the 34 CCS and thereby also reducing the CCS contribution to the hypersaline plume in the Biscayne 35 Aquifer and the plumes westward migration. Since 2015, FPL has been using a variety of 36 water sources to manage salinity within the CCS. It has also implemented a number of 37 additional CCS operational and surface water quality management measures as required by the 38 2016 FDEP Consent Order, which are discussed in Section 3.5.1.2, Surface Water Hydrology, 39 of this SEIS.

40 With regard to meeting the 34 PSU salinity metric specified in the 2016 FDEP Consent Order 41 and consistent with the requirements of the 2015 Consent Agreement with Miami-Dade County, 42 FPL commenced operation of a new freshening well system on November 28, 2016, adding 43 groundwater from the Upper Floridan aquifer to the CCS. The State of Florida authorizes FPL 44 to withdraw up to 14 mgd (53,000 m3/day) from the Upper Floridan aquifer from six wells under 3-69

1 its modified site certification for the Turkey Point site; FPL has constructed five wells to date 2 (i.e., wells F-1, F-2, F-3, F-4, and F-5) (FDEP 2016b, State of Florida Siting Board 2016). By 3 adding brackish (i.e., average of 2.5 PSU) Upper Floridan aquifer groundwater to the CCS, FPL 4 intends to minimize the increase in salinity that can occur in the CCS during the yearly dry 5 season, reduce average CCS salinity to meet the 2016 FDEP Consent Order metric of 34 PSU, 6 and reduce the CCS contribution to the existing hypersaline plume (FPL 2018f). 7 Section 3.5.2.3, Groundwater Use, in this SEIS contains a separate discussion of groundwater 8 withdrawals associated with salinity reduction and other activities at the Turkey Point site. 9 In order to stop and then retract the westward migration of hypersaline groundwater originating 10 from the CCS, the 2016 FDEP Consent Order requires FPL to permit, construct, and operate a 11 recovery well system to remediate the hypersaline plume in the Biscayne aquifer (FDEP 2016e). 12 This requirement is consistent with the 2015 Consent Agreement (MDC 2015a) between FPL 13 and Miami-Dade County, as described previously. 14 From September 2016 until mid-2018, FPL conducted hypersaline extraction and deep well 15 injection testing, which had the benefit of initiating salt removal from the Biscayne aquifer. In 16 2013, FPL had sought and obtained permission from FDEP to permit Deep Injection Well DIW-1 17 as a Class I injection well by converting the existing Class V exploratory well (EW-1), originally 18 installed for the proposed new reactors, Turkey Point Units 6 and 7 (FDEP 2013). FPL used the 19 existing deep injection well (DIW-1) and four, 90-feet (27-m) deep Biscayne aquifer production 20 wells (designated PW-1 through PW-4) constructed by FPL for assessing flow rates for the 21 recovery wells (FPL 2017a, FPL 2018f) (Figure 3-14). By letter dated June 21, 2016, FDEP 22 authorized FPL to carry out the testing program in accordance with underground injection 23 control Permit 293962-002-UC and Permit Modification 293962-003-UC/MM (FDEP 2013, 24 FDEP 2016f, FDEP 2016g). 25 Meanwhile, in May 2017, Miami-Dade County approved FPLs remedial action plan for design 26 and construction of the recovery well system (MDC 2017e). FPL began construction of the full-27 scale hypersaline groundwater recovery well system on June 19, 2017 (FPL 2017a). The 28 recovery well system was completed on May 15, 2018, and it then became operational 29 (FPL 2018h). Operation of the extraction well portion of the system is authorized under a South 30 Florida Water Management District water use permit (Permit No. 13-06251-W), issued to FPL in 31 February 2017 (SFWMD 2017a). 32 In July 2018, FDEP issued underground injection control Permit No. 0293962-004-UO/1I to FPL 33 for operation of deep injection well DIW-1 for disposal of hypersaline groundwater 34 (FDEP 2018d). 35 The installed full-scale hypersaline groundwater recovery well system consists of 10 hypersaline 36 groundwater recovery (extraction) wells (i.e., numbered RW-1 through RW-10), generally 37 located along the western edge of the CCS, and the Class 1 deep injection well (DIW-1) for 38 disposal of the recovered hypersaline groundwater (Figure 3-14). Between September 2016 39 and May 2018, the testing and recovery well systems have extracted and disposed of 40 approximately 8,285 million gallons (31.4 million m3) of hypersaline groundwater, with the 41 removal of 1.92 million tons (1.74 million metric tons) of salt from the Biscayne aquifer 42 (FPL 2018h, 2018i). Section 3.5.2.3, Groundwater Use, provides additional details on the 43 recovery well system. 44 In its environmental report, FPL stated that groundwater modeling of the recovery well system 45 operation indicates that the westward migration of the hypersaline plume will be stopped in 3-70

1 3 years of operation, with retraction of the hypersaline plume north and west of the CCS 2 beginning in 5 years. FPL further projects that system operation will achieve retraction of the 3 plume back to the FPL site boundary within 10 years, as required by the 2016 FDEP Consent 4 Order with FDEP (FPL 2018f). FPL is required to conduct periodic continuous surface 5 electromagnetic mapping surveys to delineate the extent of the hypersaline plume in order to 6 measure the success of recovery and remediation efforts and report the results to FDEP. After 7 5 years of system operation, FPL must provide a report to FDEP that evaluates the 8 effectiveness of the recovery well system in retracting the hypersaline plume to the L-31E Canal 9 within 10 years. If FPLs report shows that the remediation efforts will not retract the 10 hypersaline plume to the L-31E Canal within 10 years, FPL must develop and submit an 11 alternate plan to FDEP for its approval (FDEP 2016e). 12 The Second Objective of the 2016 FDEP Consent Order focuses on the prevention of releases 13 of groundwater from the CCS to surface waters connected to Biscayne Bay. To address these 14 impacts, the 2016 FDEP Consent Order requires FPL to undertake specific environmental 15 restoration projects at Turtle Point and at the Barge Turning Basin, as well as implement a 16 nutrient management plan for the CCS, and to complete and report on the results of an 17 inspection of the periphery of the CCS (FDEP 2016e). For status summaries of these projects, 18 see the discussion in Section 3.5.1.4, Adjacent Surface Water Quality and Cooling Canal 19 System Operation, of this SEIS. 3-71

1 Source: Modified from FPL 2017b 2 Figure 3-14 Layout of Biscayne Aquifer Recovery Well System and Testing Wells 3-72

1 The Third Objective of the 2016 FDEP Consent Order requires mitigation for impacts related to 2 the historic operation of the CCS, including but not limited to the hypersaline plume and its 3 influence on the saltwater interface. Discrete mitigative actions specified in the 2016 FDEP 4 Consent Order require FPL to convey specified tracks of FPL property to the South Florida 5 Water Management District, if so requested, to facilitate the Comprehensive Everglades 6 Restoration Plan; to make financial contributions to the State of Florida to support mitigation for 7 saltwater intrusion; and to conduct water quality sampling in order to improve trend analysis in 8 Biscayne Bay and Card Sound surface waters. Moreover, the 2016 FDEP Consent Order 9 requires FPL to complete an analysis using the variable density, three-dimensional groundwater 10 model developed in accordance with the requirements of the 2015 Consent Agreement to 11 allocate relative contributions of other entities or factors to the movement of the saltwater 12 interface (FDEP 2016e). 13 In June 2018, FPL presented the results of its modeling analysis to FDEP staff. In summary, 14 FPL commissioned Tetra Tech, a consulting and engineering services company, to conduct an 15 attribution sensitivity analysis using its existing variable density flow and salinity transport model 16 (Tetra Tech 2018). Modeling runs were conducted to evaluate eight regional and environmental 17 factors as compared to a base scenario in order to assess the effects of these factors on the 18 location of the saltwater interface. These factors included: (1) operation of the Turkey Point 19 CCS, (2) sea level rise, (3) changes in land use, (4) decadal-scale changes in climate in terms 20 of precipitation recharge, (5) construction of drainage structures and changes to drainage 21 practices, (6) construction and operation of controlled freshwater canals, (7) changes to 22 groundwater use (changes to the operation and capacity of nearby wellfields), and 23 (8) management and operation of mining practices west of the CCS. 24 FPLs modeling analysis indicates that operating the CCS with salinity in excess of 35 PSU is 25 the single largest contributor to changes (movement) in the location of the saltwater interface, 26 as measured by the areal extent of the saltwater interface. Changes were measured based on 27 the average change in the area of salinity greater than 0.05 PSU west of the CCS over the 28 thickness of the Biscayne aquifer. Other than CCS salinity, the modeling indicates that the 29 next-most-influential locational factors are changes in climate, followed by canal operations over 30 time (Tetra Tech 2018). 31 Routine and Potential Inadvertent Releases of Radionuclides and Other Pollutants to 32 Groundwater 33 Nuclear power plants and other industrial facilities can impact groundwater quality by 34 inadvertent releases of chemicals and petroleum products. Nuclear power plants can also 35 impact groundwater quality through inadvertent releases of radionuclides, predominantly tritium, 36 from spills and leaks from plant systems (NRC 2013a). 37 Nuclear power plants routinely release dilute concentrations of radionuclides, including tritium, 38 in effluents (liquid and gaseous wastes) subject to compliance with NRC regulations. These 39 authorized releases are closely monitored by the plant operator and reported to the NRC, with 40 reports made available to the public on the NRCs Web site, in the form of annual radioactive 41 effluent release reports. Similarly, potential impacts to the public and to the environment from 42 plant radiological releases are evaluated and reported by NRC licensees in radiological 43 environmental operating reports, which are also publicly available. Routine radiological 44 effluents from Turkey Point Units 3 and 4, and FPLs associated effluent management and 45 radiological environmental monitoring programs are described in Section 3.1.4.1, Radioactive 3-73

1 Liquid Waste Management, Section 3.1.4.2, Radioactive Gaseous Waste Management, and 2 Section 3.1.4.5, Radiological Environmental Monitoring Program, of this SEIS. 3 Normal operation of Turkey Point Units 3 and 4 results in the release to the CCS of monitored 4 and permitted effluents containing tritium. Evaporation of CCS water results in tritium being 5 released to the atmosphere as a component of the water vapor, while radioactive decay (with a 6 half-life of approximately 12 years) limits the buildup of tritium concentrations over time in the 7 waters of the CCS (NRC 2016a). 8 In 2017, based on the results of FPLs radiological environmental monitoring, the average tritium 9 concentration in the waters of the CCS at site T08 (on the southern shore of the CCS, west of 10 Grand Canal Bridge) was 10,391 pCi/L, with a maximum level of 24,483 pCi/L (FPL 2018k). Of 11 the four supplemental surface water stations in FPLs REMP, the NRC staff assumes that this 12 sampling location may be generally representative of ambient tritium levels in the CCS. For 13 2016, the average tritium concentration at this location was 6,126 pCi/L, with a maximum level 14 of 17,456 pCi/L (FPL 2017d). For comparison, the EPAs primary drinking water standard for 15 tritium is 20,000 pCi/L (40 CFR 141.16). Section 3.5.1.4, Adjacent Surface Water Quality and 16 Cooling Canal System Operation, further describes surface water quality in the CCS. As 17 discussed there and as shown in Figure 3-13, Extent of Tritium in the Deep Interval of the 18 Biscayne Aquifer in the Vicinity of the Turkey Point Site, 2017, tritium concentrations decrease 19 significantly with increasing distance from the site, to levels substantially below the EPAs 20 primary drinking water standard. 21 Because the canals comprising the CCS are not lined, CCS water, which contains tritium, 22 migrates into the groundwater of the underlying Biscayne aquifer (FPL 2018f, NRC 2016a). 23 Within the highly permeable aquifer, diffusion is rapid and groundwater flow is relatively fast 24 (FPL 2016h). Thus, tritium occurs in underlying groundwater in the Biscayne aquifer beneath 25 the CCS as well as in adjacent areas of the aquifer that are beneath the Turkey Point, Units 3 26 and 4 plant complex. 27 An additional consideration for the presence and transport of tritium is that engineered backfill 28 (crushed, compacted limestone) was used around the Turkey Point plant complex (nuclear 29 island) with some structures extending to a depth of 45 feet (14 m) below land surface. On a 30 more localized basis, subsurface structures may alter or impede the direction of groundwater 31 flow (FPL 2016h). Further, it is likely that subsurface structures and the engineered backfill 32 itself offer a preferential flow path for water containing tritium to reach the Biscayne aquifer 33 beneath portions of the Turkey Point plant complex. Any inadvertent releases of liquids 34 containing radioactive constituents from plant facilities and systems, spills, or leaks can also 35 migrate to underlying groundwater. 36 Potentiometric surface (water table elevation) maps developed for the Turkey Point site and 37 reviewed by the NRC staff show that groundwater flow across the main plant complex is tidally 38 influenced in the shallow, intermediate, and deep monitored portions of the Biscayne aquifer. 39 FPL states in its Updated Final Safety Analysis Report, Turkey Point Units 3 & 4, that there is 40 a rather consistent tidal influence on groundwater elevations across the Turkey Point site of 0.2 41 to 0.5 ft (0.06 to 0.15 m) maximum tidal fluctuation (FPL 2016h). Groundwater flow paths are 42 further influenced by plant operations where operation of the circulating water system and 43 associated intake and discharge canals generally produces radial flow across the plant site at 44 shallow and intermediate depths during most tidal regimes. This appears to generally occur due 45 to groundwater mounding on the discharge canal (west) side of the plant complex and a 46 depressed water table surface on the intake (east side) of the plant. In contrast, during both low 3-74

1 and high tides, groundwater flow in the deep portion of the Biscayne aquifer is more 2 unidirectional, from south to north and from east to west (FPL 2018f). 3 FPL participates in the NEI 07-07, Industry Ground Water Protection Initiative (NEI 2007). The 4 initiative identifies actions to improve management and response to instances in which the 5 inadvertent (i.e., unplanned, uncontrolled, and unmonitored) release of radioactive substances 6 may result in low but detectible levels of nuclear power plant-related radioactive materials in 7 subsurface soils and water. The initiative identifies those actions necessary for the 8 implementation of a timely and effective groundwater protection program along with acceptance 9 criteria to demonstrate that the objectives have been met. 10 Since 2010, FPL has maintained a radiological environmental sampling and analysis program 11 for Turkey Point that meets the recommendations of NEI 07-07. FPL performs groundwater 12 monitoring at 28 onsite locations around Turkey Point Units 3 and 4 for potential inadvertent 13 radioactive releases through groundwater pathways at the Turkey Point site in accordance with 14 site procedures. FPL collects samples on at least a quarterly basis or more frequently if 15 deemed necessary (FPL 2018f). Some of the groundwater monitoring locations have multiple 16 (two or three) depths. 17 FPL states in its environmental report that it has detected tritium (a beta-emitting radioactive 18 isotope of hydrogen) in groundwater. Since establishing its NEI 07-07 program, FPL has 19 detected no Turkey Point-related gamma-emitting isotopes (FPL 2018f). 20 The NRC staff reviewed FPLs annual effluent release and radiological environmental operating 21 reports for a 4-year period (2014 through 2017). The NRC staff found that FPL has 22 documented seven actual or potential inadvertent releases to groundwater from Turkey Point, 23 Units 3 and 4 operations. FPL completed appropriate corrective actions and entered the events 24 and actions taken in the plant corrective action program, as appropriate. The list below 25 summarizes these unplanned liquid releases: 26

• March 19, 2014, the Turkey Point Unit 3E demineralizer fill valve leaked a small amount 27 of reactor coolant system (RCS) water (i.e., about 1 gallon (3.8 L)) on the roof of the 28 auxiliary building, which was promptly cleaned up.

29

• August 24, 2014, the Turkey Point Unit 4 refueling water storage tank purification pump 30 (4P209) drain line leaked 5 gallons (19 L) of reactor coolant system water to the ground.

31 Corrective actions included increasing sampling of Turkey Point monitoring wells (i.e., 32 PTN-MW-8S, PTN-MW-9S, and P-94-4) for gamma and tritium activity. 33

• September 23, 2014, the Unit 4 demineralizer resin fill valve and flange located on the 34 roof of Turkey Point Unit 4 auxiliary building leaked about 50 gallons (190 L) of reactor 35 coolant system water. Rainfall caused the leak to migrate to the storm drain system.

36 Contamination included 0.132 Ci of cobalt-58 and 0.019 Ci of tritium. Corrective actions 37 included monitoring the southeast storm drain as well as nearby monitoring wells (i.e., 38 PTN-MW-8S and PTN-MW-9S). 39

• October 14, 2014, the Turkey Point Unit 4 refueling water storage tank valve 4-804 B 40 leaked during the transfer of water from the refueling cavity. Approximately 1 L of 41 reactor coolant system water was released to the ground before the leak was stopped.

42 Corrective actions included monitoring nearby wells (i.e., PTN-MW-8S, PTN-MW-9S, 43 and P-94-4) monthly for gamma activity and tritium. 3-75

1

• November 11, 2014, a pump casing leak occurred from the 4P209 Unit 4 refueling water 2 storage tank purification pump. The total leak volume was not estimated but the pump 3 leak was estimated to be approximately 60 drops per minute until the pump was shut 4 down upon discovery of the leak. Corrective actions included increasing sampling of 5 wells in the vicinity (i.e., PTN-MW-8S, PTN-MW-9S, and P-94-4) to monthly for gamma 6 activity and tritium.

7

• July 26-September 15, 2015, a leak of intake cooling water contaminated with sodium-8 24 from the Turkey Point Unit 3 component cooling water (CCW) system occurred.

9 Chemical inhibitors that contain sodium become activated when the CCW travels into a 10 neutron field. The Turkey Point Unit 3 CCW heat exchanger, cooled by intake cooling 11 water, developed a leak, and CCW, which contained activated sodium, leaked into the 12 tube side of the heat exchanger. The release continued until the heat exchanger was 13 plugged. The intake cooling water discharges into the mixing basin on the western side 14 of plant, which is the same area used as discharge for the regular liquid radwaste tanks. 15 The total release volume was approximately 4,828 gal (18,280 L). The total estimated 16 quantity of sodium-24 released was 6.19 micro-Curies. 17

• October 5, 2017, the Unit 4D demineralizer resin fill valve and flange located on the roof 18 of the Unit 4 auxiliary building showed signs of leakage to the roof. The southeast storm 19 drain (in the likely flow path) was sampled and showed activity. The calculated dose 20 from the estimated activity released was determined to be well below site Offsite Dose 21 Calculation Manual limits.

22

• January 22, 2018, a spill occurred on the roof of the auxiliary building when radiation 23 workers removed the protective cover on the Unit 4D demineralizer resin fill isolation 24 valve. The spill volume was about 0.5 gal (1.9 L) and reached the storm drain system 25 after initial response efforts were ineffective. Corrective actions included a complete 26 replacement of the demineralizer rubber diaphragm valve with a new ball valve with 27 stainless steel internals in order to eliminate valve leakage. The frequency of sampling 28 of the surrounding monitoring wells (e.g., PTN-MW-8S) was increased to weekly, and no 29 significant impact to groundwater was observed following the release (FPL 2013a, 30 2015a, 2015b, 2016i, 2016j, 2017d, 2017e, 2018j, 2018h, 2018k).

31 Table 3-5 summarizes the latest available radiological groundwater monitoring results that FPL 32 has reported to the NRC for representative well locations, with the results compared to historical 33 maximum observed concentrations. Monitoring well locations are depicted in Figure 3-15 34 below. 35 Table 3-5 Representative Groundwater and Storm Drain Monitoring Results for Tritium, 36 Turkey Point Groundwater Protection Program, 2017 (in PicoCuries per Liter) Previous 4-Year First Second Third Fourth Maximum Concentration Well Number Quarter(a,b) Quarter(a,b) Quarter(a,b) Quarter(a,b) (Year-Quarter) P-94-4 947 910 633 845 3,060 (2015-Q3) PTN-MW-1S <MDC NA <MDC <MDC 80.5 (2014-Q3) PTN-MW-1I 565 NA 345 NA 700 (2016-Q1) PTN-MW-1D 1,940 NA 1,790 NA 2,310 (2015-Q3) PTN-MW-4S <MDC <MDC <MDC <MDC 1,930 (2014-Q2) PTN-MW-4I 2,840 2,780 2,900 2,490 3,570 (2016-Q1) 3-76

Previous 4-Year First Second Third Fourth Maximum Concentration Well Number Quarter(a,b) Quarter(a,b) Quarter(a,b) Quarter(a,b) (Year-Quarter) PTN-MW-4D 3,650 <MDC <MDC <MDC 3,840 (2015-Q4) PTN-MW-7S 915 1,220 1,180 867 1,070 (2015-Q4) PTN-MW-7I 1,030 1,330 1,750 1,430 2,400 (2015-Q3) PTN-MW-7D 1,160 <MDC <MDC <MDC 2,370 (2014-Q1) PTN-MW-8S 2,010 1,040 873 13,600 6,670 (2014-Q1) PTN-MW-9S 334 853 702 798 773 (2015-Q4) Northeast Storm <MDC <MDC 455 9,990 1,140 (2016-Q3) Drain PTN-MW-11S <MDC 709 623 425 804 (2014-Q3 PTN-MW-12S 855 723 1,080 963 1,140 (2016-Q1) Southeast Storm <MDC <MDC 1,570 13,000 10,600 (2016-Q3) Drain West Storm Drain 4,730 825 4,490 12,000 11,240 (2015-Q4) CRF Storm Drain No result <MDC <MDC 545 <MDC Notes: CRF=central receiving facility; MDC=minimum detectable concentration, value is less than the analytical MDC or less than 300 pCi/L tritium; NA=not applicable, as sampling not conducted or required for sampling period. S, I, and D refer to approximate monitored depth below land surface: Shallow 20 feet (6 m), Intermediate 40 feet (12 m), and Deep 60 feet (18 m). (a) FPL reports all results in picoCuries per liter (pCi/L). (b) FPL generally collects quarterly samples in January, April, July, and October. Source: FPL 2015b, FPL 2016j, FPL 2017d, FPL 2018k. 3-77

1 Source: Modified from FPL 2018k (Note: Cross-Sections Omitted) 2 Figure 3-15 Turkey Point Groundwater Protection Initiative Monitoring Well Locations 3-78

1 Based on these results, the NRC staff finds no apparent increasing trend in tritium concentration 2 or a pattern indicating either a new inadvertent release or persistently high tritium 3 concentrations that might indicate an ongoing inadvertent release from Turkey Point facilities to 4 groundwater. In 2017, the highest observed level in Turkey Point groundwater was 5 13,600 pCi/L at well PTN-MW-8S. This location is near the Turkey Point Unit 3 refueling water 6 storage tank, shown in Figure 3-15. Elevated tritium levels were also detected in storm drain 7 locations, which likely represents tritium concentrations in the CCS during periods when storm 8 drain outfalls are occasionally below the tidal mark in the canal system (FPL 2018k). 9 Nevertheless, all results are less than the limits prescribed by FPLs Offsite Dose Calculation 10 Manual (FPL 2013a) for the plant, which for tritium is 30,000 pCi/L, as groundwater at the site is 11 not designated for potable use. 12 At the time of the NRCs onsite environmental audit in 2018 for the subsequent license renewal, 13 FPL was preparing a site conceptual model as part of an effort to identify and characterize 14 groundwater flow and the occurrence and migration of tritium at the FPL property, including 15 locations such as: Turkey Point Units 1, 2, and 5, the diesel storage tank area, and portions of 16 the intake and discharge canals. Other objectives of this effort include evaluation of potential 17 human, ecological, or environmental receptors of tritium that might have been released to the 18 groundwater and development of recommendations for additional investigations and long-term 19 monitoring (FPL 2018h). 20 With respect to unplanned, non-radiological releases, FPL reported no accidental spills or 21 similar releases of nonradioactive substances, including petroleum products, at Turkey Point 22 over the past 5 years, nor any associated notices of violation issued to FPL for such releases 23 (FPL 2018f, FPL 2018h). The NRC staffs review of available information and regulatory 24 databases found no documented instances of accidental spills of chemical or petroleum 25 products to groundwater that resulted in a regulatory action over the last 5 years. 26 3.5.2.3 Groundwater Use 27 Section 2.2.2 of NUREG-1437, Supplement 5 describes water use and sanitary wastewater 28 management for Turkey Point operations (NRC 2002c). As indicated in that section, water for 29 Turkey Point process makeup (e.g., primarily demineralizer water makeup), potable water, and 30 fire protection water uses was obtained from the Miami-Dade Water and Sewer Department 31 (MDWSD). Sanitary wastewater was being processed in an onsite treatment plant and 32 discharged to groundwater (Biscayne aquifer) through an onsite injection well (i.e., IW-1). That 33 section further states that no surface water or groundwater was being withdrawn for use as 34 makeup water for the CCS at that time. The NRC staff incorporates the information in NUREG-35 1437, Supplement 5, Section 2.2.2 (NRC 2002c: 2-5, 2-17, 2-18), here by reference. The 36 following discussion presents new information regarding groundwater use for Turkey Point 37 operations, beyond the information in NUREG-1437, Supplement 5. 38 In southeast Florida and in Miami-Dade County where Turkey Point is located, groundwater 39 aquifers are used both as a water supply and as a reservoir for wastewater disposal via deep 40 well injection. Nearly all of the potable water supplied by the MDWSD to southern Miami-Dade 41 County comes from the Biscayne aquifer (MDC 2018b, NRC 2016a) (Section 3.5.2.2). The 42 exception is water from the Countys Alexander Orr, Jr. water treatment plant, which mixes 43 some brackish groundwater from the Upper Floridan aquifer with Biscayne aquifer groundwater 44 (NRC 2016a). 3-79

1 In 2015, groundwater withdrawals in Miami-Dade County totaled 409.2 mgd 2 (1.55 million m3/day) from freshwater sources and 40.5 mgd (153,300 m3/day) from saline 3 sources. Withdrawals for public water supply comprised the largest use including 338.9 mgd 4 (1.28 million m3/day) from freshwater sources and 13.0 mgd (49,200 m3/day) from saline 5 sources. Withdrawals for power generation included 1.28 mgd (4,850 m3/day) from freshwater 6 sources and 27.5 mgd (104,000 m3/day) from saline sources (USGS 2018a). 7 The MDWSD continues to supply potable water to Turkey Point for drinking and fire protection 8 water uses. Sanitary wastewater disposal continues to be accomplished through an FDEP 9 permitted injection well, as well as by septic tanks (FPL 2018f). 10 FPL completed installation of a replacement water treatment plant in 2017, which is designed to 11 supply pure/ultrapure (demineralized) water for Turkey Point uses. The new system can treat 12 either municipally supplied water (i.e., from the MDWSD) or groundwater from the Upper 13 Floridan aquifer. The use of groundwater is intended to reduce FPLs use of MDWSD water by 14 1 mgd (3,800 m3/day) and associated costs. Wastewater from the new treatment plant is 15 discharged to the CCS (FPL 2018f). Section 3.10.4.3, Public Water Supply, of this SEIS 16 describes the MDWSD public water supply system, and Section 3.1.5, Nonradioactive Waste 17 Management Systems, describes nonradioactive waste management systems that support 18 Turkey Point Units 3 and 4 operations. 19 Currently, FPL uses onsite groundwater withdrawn from the Biscayne and Upper Floridan 20 aquifers for a variety of applications in support of Turkey Point operations, as well as for other 21 activities conducted on the Turkey Point site unrelated to Turkey Point. These principal uses 22 include withdrawals from the Upper Floridan aquifer for freshening of the CCS, operation of a 23 recovery well system and associated underground injection well to extract and dispose of 24 hypersaline groundwater from the Biscayne aquifer, operation of Biscayne aquifer marine wells 25 to supplement CCS freshening, and operation of Upper Floridan Aquifer saline production wells 26 for various onsite uses. 27 Table 3-6 summarizes FPLs reported groundwater withdrawals associated with these well 28 systems for the period from January 2015 through June 2018. In 2017, FPLs groundwater 29 withdrawals from the Biscayne aquifer totaled about 8,928.8 mgy (33.8 million m3/year), or 30 approximately 24.5 mgd (92,700 m3/day). For the Upper Floridan aquifer, withdrawals totaled 31 7,137.2 mgy (27.0 million m3/year), or approximately 19.6 mgd (74,200 m3/day). 32 The nature of these withdrawals and the applicable regulatory requirements governing them are 33 further described below. 3-80

1 Table 3-6 Groundwater Withdrawals at the Turkey Point Site Withdrawals (mgy) Year UFA Saline Well Biscayne Aquifer UFA Freshening Biscayne Aquifer System (PW-1, Marine Well Well System (F-1, F- Recovery Well System PW-3, PW-4) System (PW-1, 3, F-4, F-5, F-6) (RW-1-RW-10) SW-1, and SW-2) 2015 3,339.6 6,065 0.0 0.0 2016 2,237.2 0.0 1,051.6 879.8(a) 2017 2,361.9 4,031.7 4,775.3 4,951.1(a) 2018(b) 1,329.4(b) 0.0 2,106.4(b) 1,994.2(c) Key: mgy=million gallons per year; mgd=million gallons per day; UFA=Upper Floridan aquifer. Note: Some reported values have been rounded. To convert million gallons per year (mgy) to million cubic meters (m3), divide by 264.2. To convert million gallons per day (mgd) to cubic feet per second, multiply by 1.547; for m3, multiply by 3785.4. (a) Withdrawals associated with hypersaline extraction and deep well injection program, using test extraction wells PW-1 through PW-4. (b) Partial-year withdrawal data for the period from January through June 2018. (c) Withdrawals associated with hypersaline extraction and deep well injection program, using test extraction wells PW-1 through PW-4, with the addition of recovery well system wells RW-1 through RW-10, which began operations in May 2018. Source: Compiled from FPL 2018h, FPL 2018l. 2 Turkey Point Site Water Supply Systems 3 Water for cooling and process makeup water for Turkey Point Unit 5 is obtained from Upper 4 Floridan aquifer saline production wells (i.e., wells PW-1, PW-3, and PW-4), as depicted in 5 Figure 3-16. These wells were commissioned in February 2007 (FPL 2018f). The wells are 6 authorized under FPLs modified site certification and associated conditions of certification for 7 the Turkey Point site. The wells range in depth from 1,242 to 1,247 feet (378.6 to 380.1 m), 8 each with a pump capacity of 5,000 gpm (18,900 L/min) (State of Florida Siting Board 2016, 9 FDEP 2016b). The 2016 Conditions of Certification specifically authorizes the withdrawal of 10 14.06 mgd (53,200 m3/day) of groundwater from the upper production zones of the Upper 11 Floridan aquifer for cooling water for Unit 5 and process water for Units 1, 2, 3, 4, and 5 12 (FDEP 2016b). In March 2018, FPL began using approximately 1.1 mgd (4,200 m3/day) of 13 groundwater from the Upper Floridan aquifer saline wells as makeup water to the pure/ultrapure 14 (demineralized) makeup water treatment system for Turkey Point Units 3 and 4 primary and 15 secondary system uses. This usage replaces approximately 0.65 mgd (2,500 m3/day) of 16 potable water that had been supplied by the MDWSD from the Newton Wellfield (FPL 2018h). 17 FPL completed installation of three marine wells in the 2015 timeframe (i.e., wells PW-1 (test), 18 SW-1, SW-2) to provide water for salinity reduction in the CCS (i.e., CCS freshening) 19 (FPL 2018f, FPL 2018m). These wells are located on the Turkey Point peninsula and withdraw 20 from the upper portion of the Biscayne aquifer (Figure 3-16). Consequently, the marine wells 21 withdraw saltwater (Golder Associates 2016). Before being converted to a production well in 22 late 2014 and early 2015, PW-1 was originally installed in 2009 as a 30-inch (76-cm) diameter 23 test well for evaluation of a radial collector well system for proposed new reactors, Turkey Point 24 Units 6 and 7 (FPL 2018m). Well PW-1 has a total depth of 46 feet (14 m), with an open 3-81

1 borehole from 22 to 46 feet (6.7 to 14.0 m) below the casing (HDR Engineering 2009). It is 2 equipped with a 7,000-gpm (26,500-L/min) pump (FPL 2018m). Marine wells SW-1 and SW-2 3 are 36-inches (91-cm) in diameter. The two wells are completed to total depths of 56 4 and 55 feet (17.1 and 16.8 m), respectively, with the lower 30 feet (9.1 m) of each well 5 terminating in an open borehole. Each of these wells has a 12,500-gpm (47,300 L/min) rated 6 capacity pump (FPL 2018m). Together, the three wells have a combined production capacity of 7 approximately 45 mgd (170,300 m3/day) (FPL 2018f). Notwithstanding this nominal production 8 capacity, the total water volume that can be withdrawn and conveyed to the intake canal area is 9 limited by considerations associated with measurement of the ultimate heat sink temperature 10 and compliance with the technical specifications in the Turkey Point, Units 3 and 4 operating 11 licenses. Specifically, the total flow must be less than or equal to 23,400 gpm (88,600 L/min) 12 when only one Turkey Point unit is operating and 41,600 gpm (157,500 L/min) when both Units 13 3 and 4 are operating (FPL 2018m). 14 Operation of the marine wells does not require a groundwater consumptive use permit from the 15 South Florida Water Management District because saltwater is not regulated by the State 16 (FPL 2018f). In general, users of seawater, or reclaimed water, are not required to obtain water 17 use permits (SFWMD 2015). The water withdrawn from the marine wells has an average 18 salinity of around 36 PSU (FPL 2017b). Historically, the salinity of marine well water has ranged 19 from about 34 PSU to nearly 40 PSU with chloride concentrations ranging from approximately 20 20,000 to 23,000 mg/L (FPL 2016f). FPL has used the wells during periods of peak CCS 21 salinity to moderate salinity rise (FPL 2018f). As stipulated under the 2015 Consent Agreement 22 (MDC 2015a) between FPL and Miami-Dade County, the marine wells may only be used to 23 lower salinity in the CCS under extraordinary circumstances. As a result, FPL reports that the 24 wells are used in response to extraordinary circumstances or upset recovery to support 25 regulatory requirements (FPL 2018f, FPL 2018m). 26 In 2016, FPL installed five additional production wells (i.e., wells F-1, F-3, F-4, F-5, and F-6) to 27 provide water from the Upper Floridan aquifer for use in the CCS (Figure 3-16). As previously 28 described, the freshening wells are authorized under FPLs modified site certification and 29 associated conditions of certification for the Turkey Point site, which permit a total withdrawal of 30 14 mgd (53,000 m3/day) for salinity reduction (State of Florida Siting Board 2016, FDEP 2016b). 31 The wells are artesian in nature (i.e., require no pumping) and flow is conveyed directly into the 32 CCS. The 20-inch (51-cm) diameter wells range in depth from 1,000 to 1,250 feet (304.8 to 381 33 m) (FDEP 2016b, FPL 2018f). Each well is equipped with a 2,500-gpm (9,460 L/min) capacity 34 pump (FDEP 2016b). 35 As described in Section 3.5.2.2, Groundwater Quality, in May 2018, FPL completed and began 36 operation of a recovery well system to meet the groundwater remediation objectives specified in 37 the 2015 Consent Agreement (MDC 2015a) with Miami-Dade County and the 2016 Consent 38 Order with the Florida Department of Environmental Protection (FDEP 2016e). The system 39 consists of 10 hypersaline groundwater recovery (extraction) wells (designated RW-1 through 40 RW-10) completed in the Biscayne aquifer and one deep injection well (DIW-1) for disposal of 41 hypersaline groundwater (Figure 3-14). These wells replaced the four demonstration wells 42 (designated PW-1 through PW-4) that FPL used for hypersaline groundwater recovery testing 43 from September 2016 through April 2018. 44 The 24-inch (61-cm) recovery wells are each drilled to a total depth of 110 feet (33.5 m) and are 45 cased to a depth of 70 feet (21 m) below land surface. Each recovery well is equipped with a 46 1,042-gpm (3,900-L/min) electric pump, giving the well system a combined extraction capacity 47 of 15 mgd (56,700 m3/day) (SFWMD 2017a). Each extraction well pump discharge is fitted with 3-82

1 backflow prevention, a magnetic flow meter, a pressure transducer, a pump discharge pressure 2 transmitter, sample tap, and an air release valve. Each well is also equipped with a water 3 quality monitoring station. The wells are operated with programmable logic controllers and 4 variable frequency driven well motor pump sets, and they are controlled and continuously 5 monitored by remote secure radio communication telemetry to a main control building located 6 near the deep injection well. The wells are connected in parallel by 14-inch (36-cm) diameter 7 piping which runs to a 28-inch (71-cm) header that conveys the extracted hypersaline 8 groundwater to deep injection well DIW-1. A total of about 9.5 mi (15 km) of pressure-rated 9 piping is used in the conveyance system (FPL 2018h). Recovery well operations are permitted 10 under a South Florida Water Management District-issued individual water use permit 11 (Permit No. 13-06251-W) (FPL 2018f, SFWMD 2017a). The permit specifies a maximum 12 monthly withdrawal allocation of 465 million gallons (1.76 million m3) (SFWMD 2017a). 13 The deep injection well DIW-1 discharges extracted hypersaline water to the Boulder Zone at a 14 depth of approximately 3,200 feet (975 m). DIW-1 is constructed of concentric piping (casing 15 strings) ranging from 64-inch (163-cm) diameter steel casing in the upper interval to 33 feet 16 (10 m) below land surface, 24-inch (61-cm) diameter steel casing to 2,985 feet (910 m) below 17 land surface, and followed by an 18-inch (46-cm) diameter liner to a depth of 18 2,975 feet (907 m) below land surface. The liner tubing is fiberglass reinforced pipe with a fluid 19 filled annulus. The total depth of the well borehole is 3,230 feet (984.5 m) below land surface 20 (FDEP 2013). 21 The deep injection well DIW-1 is paired with a dual-zone monitoring well (DZMW-1), which is 22 completed in the Floridan aquifer with upper and lower monitoring zones at 1,450 to 1,490 ft 23 (442 to 454 m) below land surface and 1,860 to 1,905 feet (567 to 581 m) below land surface 24 (FDEP 2013). Operation of DIW-1 is authorized under FDEP Permit No. 293962-002-UC 25 (FPL 2013, FDEP 2018d). The maximum permitted injection rate for DIW-1 is 10,826 gpm 26 (41,000 L/min), or 15.59 mgd (59,000 m3/day), and the well is required to be periodically tested 27 for injectate confinement (FDEP 2013). 28 The Boulder Zone is located in the Lower Floridan aquifer and is overlain by a confining layer 29 that retards upward migration of wastewater (FPL 2018f). The FDEP permits FPL and others to 30 discharge treated sewage and other wastes through injection wells into the Boulder Zone. All 31 Boulder Zone underground injection wells must be permitted and monitored by the FDEP 32 underground injection control program. As an example, the Miami-Dade Water and Sewer 33 Departments South District Wastewater Treatment Plant located approximately 9 mi (14 km) 34 north of the Turkey Point site disposes of municipal wastewater through as many as 13 deep 35 injection wells into the Boulder Zone (NRC 2016a). 36 Other Water Supply Wells 37 While the Biscayne aquifer is the principal source of potable water supplied by the Miami-Dade 38 Water and Sewer Department, the Biscayne aquifer is not a source of potable water in the 39 vicinity of the Turkey Point site, as discussed in Section 3.5.2.2, Groundwater Quality. Other 40 than FPL-owned water wells, described above, there are no potable water wells (drawing from 41 either the Biscayne or Floridan aquifer systems) within the Turkey Point site boundary. 42 There are no registered groundwater supply wells within a 2-m (3.2-km) band of the Turkey 43 Point site boundary (FPL 2018f). Relative to the Turkey Point site, the nearest mapped water 44 supply wells are located about 5 mi (8 km) west of the western boundary of the CCS and are 45 used to support mining operations (FDOH 2018a). 3-83

1 As for public water supply sources, the nearest wells are located about 6 mi (10 km) from the 2 northwest corner of the CCS and approximately 7 mi (11 km) from the center of the Turkey 3 Point plant complex. These wells are located at Newton Field (i.e., the Newton Wellfield) and 4 are operated by Miami-Dade County (see Figure 3-12) (FDOH 2018a, MDC 2006, MDC 2018c, 5 NRC 2016a). 6 Potable water supply for the Florida Keys comes from Biscayne aquifer wells and an Upper 7 Floridan aquifer well located west of Florida City at the Florida Keys Aqueduct Authoritys 8 J. Robert Dean Water Treatment Plant. These facilities are located approximately 9.5 mi 9 (15 km) west, northwest of the western boundary of the CCS (FDOH 2018a, MDC 2006, 10 MDC 2018c, NRC 2016a). 3-84

1 Source: Modified from FPL 2017b 2 Figure 3-16 Location of Groundwater Production Wells on the Turkey Point Site 3-85

1 3.6 Terrestrial Resources 2 This section describes the terrestrial resources of the affected environment, including the 3 surrounding ecoregion. The terrestrial resources include plant and animal species, vegetative 4 communities, and important habitats present on or in the vicinity of the Turkey Point site. This 5 section also describes important species and habitats that potentially may be present on or near 6 the Turkey Point site. Plants and animals federally listed as endangered or threatened are 7 discussed in Section 3.8, Special Status Species and Habitats. 8 3.6.1 Vegetative Communities 9 The Turkey Point site is located on the western edge of Biscayne Bay and lies within the 10 Mangrove and Coastal Glades physiographic province (McPherson and Halley 1996). This area 11 includes a broad band of wetlands at or near sea level that is often flooded by tides or 12 freshwater runoff. The ecology at and near Turkey Point is directly tied to the hydrology and 13 natural seasonal hydrologic fluctuations that occur in this region. The NRC staffs EIS for the 14 Turkey Point Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a), Section 2.4.1.1 15 and Tables 2-2 and 2-3 describe the physiographic province, the general ecology of the Turkey 16 Point site, and the land cover of various habitats within the vicinity of Turkey Point. 17 Section 2.4.1.1 of NUREG-2176 (NRC 2016a) also summarizes the results of vegetative 18 surveys of the Turkey Point site through 2011. The NRC staff incorporates the above 19 information from NUREG-2176, Section 2.4.1.1 and Tables 2-2 and 2-3 into this SEIS by 20 reference (NRC 2016a: 2-76 to 2-77; Tables 2-2 and 2-3). 21 FPL developed a vegetative survey monitoring plan as a condition of its site certification from 22 the State of Florida (FPL 2018g). This vegetative monitoring plan includes surveys of 32 plots 23 of freshwater marsh and mangrove habitat adjacent to the CCS. FPL initially surveyed these 32 24 plots in October 2010 prior to the power uprate; FPL continues to survey each of the 32 plots 25 approximately four times each year in February, May, August, and October (FPL 2012a, 26 FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a). During the survey, FPL measures the 27 percent cover, species diversity, plant height, and biomass of each plot as well as other factors 28 that may indicate changes in the health of the vegetation and habitat. FPL selected one plot 29 and transect (T6) to serve as a reference plot. The reference plot is located in an area further 30 from the CCS that would not be as susceptible to potential impacts from the CCS. For 31 additional details regarding FPLs vegetative survey methodology, see FPLs report 32 (FPL 2012a), Turkey Point Plant Comprehensive Pre-Uprate Monitoring Report, Units 3 & 4 33 Uprate Project. 34 The most common freshwater wetlands near the CCS are sawgrass (Cladium jamaicense) 35 marshes. Sawgrass marshes are flooded for the majority of the year, and the relative 36 abundance of sawgrass compared to other species tends to be positively correlated with both 37 the length of the hydroperiod (or time in which the area is flooded) as well as the depth of the 38 water during the hydroperiod (UF undated, Foti et al. 2012). Vegetative species diversity is 39 generally low within sawgrass marshes for a few reasons: (1) sawgrass plants can grow so 40 densely that few other species can establish in the limited space, and (2) sawgrass marshes 41 thrive in harsh physiological conditions, including flooding and deep water, that few plants can 42 tolerate (Brown et al. 2006). After sawgrass, the next most common plant species in the 43 freshwater wetlands near the CCS is the spikerush (Eleocharis cellulose). Species diversity 44 generally ranges from one to three plant species per plot (FPL 2012a, FPL 2014b, FPL 2016a, 45 FPL 2016b, FPL 2017a), which is typical for southern Everglades sawgrass marshes 46 (Childers et. al. 2006, Foti et al. 2012). Sawgrass cover has remained between 2 to 25 percent 3-86

1 since FPL began sampling in 2011 (FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, 2 FPL 2017a). 3 Using FPLs data from 2011 through 2017, the NRC staff plotted the height of sawgrass plants 4 and live biomass within the five freshwater marsh transects (see Figure 3-17 and Figure 3-18). 5 Sawgrass height tended to be highest during fall and winter, and slightly shorter in spring and 6 summer. Average sawgrass height decreased from October 2010 through February 2012 and 7 has fluctuated ever since without showing a consistent upward or downward trend. Live 8 biomass has also fluctuated over the past several years, also without showing a consistent 9 upward or downward trend. Most recently, live biomass decreased in August and 10 November 2016 and then increased by February 2017 and remained at a similar or higher level 11 in May 2017. The seasonal and annual changes in sawgrass height and live biomass were 12 generally similar between the reference transect (T6) chosen for being farther from the CCS, 13 and the transects closer to the CCS (T1-4). The survey shows that wetlands at different 14 distances from the CCS exhibit similar growth trends. These patterns suggest that landscape-15 scale environmental factors, such as the length of the hydroperiod or overall water depth, have 16 a greater effect on changes in live biomass and sawgrass height than proximity to the CCS. In 17 addition, the fluctuations in sawgrass height and live biomass over time suggest that there is a 18 high degree of natural variability influenced by multiple environmental parameters. 19 Sources: FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a 20 Figure 3-17 Average Height of Sawgrass Blades Within Freshwater Marsh Transects 21 from October 2011 through February 2017 3-87

1 Sources: FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a 2 Figure 3-18 Live Sawgrass Biomass Within Freshwater Marsh Transects from 3 October 2011 through February 2017 4 In scrub mangrove plots at Turkey Point, red mangrove (Rhizophora mangle) is the most 5 common species. Red mangrove forests tend to have low vegetative species diversity due to 6 the dominance of red mangrove and because few species have adapted to grow in saline 7 waters, which is physiologically demanding. Similar to biomass trends within freshwater 8 marshes, biomass within most Turkey Point mangrove plots and transects have fluctuated over 9 the past several years, showing no consistent upward or downward trend. However, biomass 10 within two of the mangrove plots (M1-2 and M3-2) has been steadily decreasing since 11 October 2011 (see Figure 3-19). In its 2017 annual Turkey Point monitoring report, FPL 12 (FPL 2017a) noted that although biomass has decreased in mangrove plots M1-2 and M3-2, 13 percent cover and height have remained relatively consistent in these plots. FPL also stated its 14 intention to closely monitor these two decreasing mangrove plots in the future. 3-88

1 Sources: FPL 2012a, FPL 2014b, FPL 2016a, FPL 2016b, and FPL 2017a 2 Figure 3-19 Live Biomass Within Two Red Mangrove Plots (M1-2 and M3-2) from 3 October 2011 through February 2017 4 In 2017, the Southwest Florida Water Management District (SWFMD) issued Permit 5 No. 13-06251-W allowing FPL to recover and extract the hypersaline water within and around 6 the CCS (SFWMD 2017a). This water extraction, called dewatering, has the potential to impact 7 wetland growth because it removes water from an ecosystem where greater water depth and 8 longer hydroperiods are directly and positively related to vegetative growth and species 9 composition (UF undated, Foti et al. 2012). As part of its permit process, the SWFMD modeled 10 drought conditions (up to a 1-in-10-year drought) and determined that a maximum drawdown of 11 less than 0.3 feet (9.1 cm) of water could occur west and north of the CCS under drought 12 conditions during operation of the wells (SWFMD 2017a). This maximum drawdown limit also 13 applies to onsite as well as offsite wetlands that are west of the CCS. The L-31E Canal would 14 provide some buffering of the drawdown area due to canal water storage. In conclusion, the 15 SWFMD determined that while the authorized withdrawal would impact wetlands, the impacts to 16 onsite and offsite wetlands would be minimal (SWFMD 2017a). 17 3.6.2 Wildlife 18 Southern Florida lies at the southern tip of a temperate landmass, and its subtropical climate 19 supports a wide variety of ecosystems and wildlife, including approximately 350 bird, 50 reptile, 20 40 mammal, and 15 amphibian species (NPS 2015b). Several tropical species inhabit Floridas 21 mangroves and warm waters, while temperate species migrate south from other areas in the 22 United States. Furthermore, productive wetlands provide a source of refuge and foraging 23 grounds for numerous wildlife and bird species. Section 2.4.1.1 of the NRC staffs EIS for the 24 Turkey Point Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a) describes wildlife 25 and avian studies conducted at and near Turkey Point in 1972 and from 2005 through 2009. 26 The NRC staff incorporates the above information into this SEIS by reference (NRC 2016a: 27 pages 2-79 to 2-80). 28 On May 23, 2016, FPL conducted bird and reptile surveys within the vicinity of the Turtle Point 29 remnant canal and Barge-Turning Basin water quality improvement projects. FPL observed one 3-89

1 reptile species, the American crocodile (Crocodylus acutus), and 6 bird species: common 2 nighthawk (Chordeiles minor), brown pelican (Pelecanus occidentalis), double-crested 3 cormorant (Phalacrocorax auritus), anhinga (Anhinga anhinga), mockingbird (Mimus polyglottis), 4 and rusty blackbird (Euphagus carolinus) (FPL 2016c). The NRC staff (NRC 2016a) previously 5 identified these species as occurring at the Turkey Point site in the EIS for the Turkey Point 6 Units 6 and 7 combined licenses. 7 From December 5-7, 2016, FPL conducted its CCS characterization study (EAI 2017), which 8 primarily focused on sampling the CCS for fish and invertebrates. FPL also recorded any 9 observations of birds near and within the vicinity of the CCS. In total, FPL documented 13 bird 10 species, many of which used the CCS as a foraging ground for fish during the study. Observed 11 birds included snowy egrets (Egretta thula), little blue herons (Egretta caerulea), tricolored 12 herons (Egretta tricolor), reddish egrets (Egretta rufescens), great egrets (Ardea alba), roseate 13 spoonbills (Platalea ajaja), wood storks (Mycteria americana), American white pelicans 14 (Pelecanus erythrorhynchos), a yellow-crowned night heron (Nyctanassa violacea), a double-15 crested cormorant, an American avocet (Recurvirostra americana), great blue herons (Ardea 16 herodias), belted kingfishers (Megaceryle alcyon), and ospreys (Pandion haliaetus). 17 The NRC staff also reviewed the Florida Fish and Wildlife Conservation Commission's (FFWCC) 18 Florida Shorebird Database, which is a database of shorebird and seabird occurrences in 19 Florida (FFWCC 2018). The Florida Shorebird Database indicated that a breeding colony of 20 least terns (Sterna antillarum), which are listed by the State of Florida as a threatened species 21 in the State, occurs at Turkey Point. Least terns are discussed in further detail in 22 Section 3.7.3.1, State-Listed Species. 23 3.6.3 Important Species and Habitats 24 3.6.3.1 State-Listed Species 25 In accordance with Chapter 68A-27 of the Florida Administrative Code (FAC), the Florida Fish 26 and Wildlife Conservation Commission oversees the States Threatened and Endangered 27 Species Conservation Program. This chapter of the FAC gives the FFWCC the authority to list 28 species as State-threatened or endangered; to issue regulations necessary and advisable to 29 provide for conservation of such species; and to prohibit anyone from taking a species, which 30 includes activities that would harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or 31 collect, or to attempt to engage in such conduct. 32 Section 2.4.1.3 and Tables 2-14 and 2-15 of the NRC staffs EIS for the Turkey Point 33 Units 6 and 7 combined licenses (NUREG-2176) (NRC 2016a) describe the State-listed 34 threatened or endangered species that may occur in Miami-Dade County, not including those 35 species that are also Federally listed. This information is incorporated here by reference 36 (NRC 2016a: pages 2-97 to 2-109). The NRC staff reviewed the list of State threatened and 37 endangered species within Miami-Dade County that are not Federally listed (FNAI 2018) and 38 determined that Tables 2-14 and 2-15 in NUREG-2176 included all listed species as of 39 August 2018, except for the following, which the NRC staff here adds to the list of State-listed 40 threatened or endangered species identified in NUREG-2176: 41

• sea rosemary (Heliotropium gnaphalodes), State-listed as endangered 42
• Florida shrub thoroughwort (Koanophyllon villosum), State-listed as endangered 43
• Florida Keys ladies'-tresses (Mesadenus lucayanus), State-listed as endangered 44
• star-scale fern (Pleopeltis astrolepis), State-listed as endangered 3-90

1

• pineland spurge (Poinsettia pinetorum), State-listed as endangered 2
• mucha-gente (Xylosma buxifolia), State-listed as endangered 3 In addition, Simpson's prickly apple (Harrisia simpsonii), Fahkahatchee ladies'-tresses (Sacoila 4 lanceolata var. Paludicola), and Florida black bear (Ursus americanus floridanus) were included 5 in NUREG-2176, Tables 2-14 and 2-15. However, these species are not listed as State 6 endangered or threatened as of August 2018 (FNAI 2018). Florida pine snake (Pituophis 7 melanoleucus mugitus), Florida burrowing owl (Athene cunicularia Floridana), little blue heron, 8 reddish egret, tricolored heron, American oystercatcher (Haematopus palliates), roseate 9 spoonbill, and black skimmer (Rynchops niger) were identified as species of special concern in 10 Table 2-15 but are listed as State threatened as of August 2018. The change in classification of 11 these species therefore modifies the Tables of State-listed threatened or endangered species 12 identified in NUREG-2176.

13 Tables 2-14 and 2-15 in the EIS for the Turkey Point Units 6 and 7 combined licenses 14 (NUREG-2176) also describe whether the species has been observed at the Turkey Point site. 15 Since the NRC staff published NUREG-2176, FPL has conducted two new ecological surveys 16 (FPL 2016c, EAI 2017) as described in Section 3.7.3, Aquatic Resources on the Turkey Point 17 Site. In its May 23, 2016, survey, FPL (2016c) did not observe any State-listed species other 18 than the American crocodile, which is State- and federally listed as threatened. The crocodile is 19 addressed in Section 3.8.1.1, Species and Habitats under U.S. Fish and Wildlife Jurisdiction, 20 of this SEIS. Ecological Associates, Inc., (EAI 2017) observed five State-listed species in the 21 2016 CCS Characterization Study, including wood storks (also federally listed), little blue herons 22 (Egretta caerulea), tricolored herons, reddish egrets, and roseate spoonbills. These five 23 species had been previously observed at the Turkey Point site, as shown in NUREG-2176, 24 Table 2-15. 25 A colony of least terns nest on berms within the CCS (FPL 2018f). The Florida Fish and Wildlife 26 Conservation Commissions shorebird monitoring program suggests that this colony at the 27 Turkey Point CCS is one of the largest ground-nesting colonies of least terns on the eastern 28 coast of Florida between Key West and Melbourne and that this colony also maintains high 29 rates of nesting success (FFWCC 2016). To minimize disturbances to this nesting colony, FPL 30 installed warning signs surrounding the berms to alert site personnel that least terns are in the 31 vicinity. FPL also limits boat traffic near the colony during nesting season. FPL expects to 32 continue these activities during the subsequent license renewal period of extended operation 33 (FPL 2018g). 34 3.6.3.2 Migratory Birds 35 The U.S. Fish and Wildlife Service administers the Migratory Bird Treaty Act (MBTA), which 36 prohibits anyone from taking native migratory birds or their eggs, feathers, or nests. 37 Regulations under the Migratory Bird Treaty Act define take as to pursue, hunt, shoot, wound, 38 kill, trap, capture, or collect, or attempt to carry out these activities (Title 50, Wildlife and 39 Fisheries, of the Code of Federal Regulations (50 CFR) 10.12, Definitions). The act protects 40 a total of 1,007 migratory bird species (75 FR 9282). The FWS (FWS 2018a) stated that 35 41 migratory birds of concern may occur on or near the Turkey Point site. Of those 35 migratory 42 bird species, FPL (FPL 2018g) identified 11 species that have been observed onsite at Turkey 43 Point. FPL (FPL 2018g) also noted that 23 additional bird species protected under the MBTA 44 have been observed onsite, although they were not included in FWSs (FWS 2018a) database. 45 The NRC staff notes that FPL has not implemented a formal monitoring or survey program for 46 migratory birds. Nonetheless, Table 3-7 describes the birds protected under the MBTA that are 3-91

1 most likely to occur at the Turkey Point site. As indicated below, migratory birds use the Turkey 2 Point site for resting, foraging, and breeding. 3 The FWS also administers the Bald and Golden Eagle Protection Act of 1940, as amended 4 (16 U.S.C. 668 et seq.), which prohibits anyone from taking bald eagles (Haliaeetus 5 Ieucocephalus) or golden eagles (Aquila chrysaetos), including their nests or eggs, without a 6 permit issued by the FWS. The FWS (FWS 2018a) determined that bald eagles may occur and 7 breed within the vicinity of the Turkey Point site throughout the year. FPL (FPL 2018g) has 8 observed bald eagles using the Turkey Point site for resting, although the species is rarely 9 observed onsite. 10 Table 3-7 Migratory Birds Protected under the Migratory Bird Treaty Act That Are Most 11 Likely to Occur at Turkey Point Frequency of Onsite Scientific Name Common Name Observations Onsite Habitat Use Anhinga anhinga occasionally resting, foraging Ardea alba great egret frequently resting, foraging Ardea herodias great blue heron frequently resting, foraging Bubo virginianus great horned owl rarely resting, foraging, breeding Bubulcus ibis cattle egret frequently resting, foraging Butorides virescens green heron frequently resting, foraging, breeding Charadrius vociferus killdeer frequently resting, foraging, breeding Chordeiles minor common nighthawk frequently resting, foraging, breeding Circus hudsonius northern harrier frequently resting, foraging Crotophaga ani smooth-billed ani rarely resting, foraging Egretta caerulea little blue heron frequently resting, foraging Egretta rufescens reddish egret frequently resting, foraging Egretta thula snowy egret frequently resting, foraging Egretta tricolor tri-colored heron frequently resting, foraging Elanoides forticatus swallow-tailed kite rarely resting, foraging Empidonax sp. flycatcher occasionally resting, foraging Eudocimus albus white ibis frequently resting, foraging Falco peregrinus peregrine falcon occasionally resting, foraging Gavia immer common loon rarely unknown Haliaeetus leucocephalus bald eagle rarely foraging Megaceryle alcyon belted kingfisher frequently resting, foraging Megascops asio screen owl occasionally resting, foraging, breeding Melanerpes carolinus red bellied woodpecker frequently resting, foraging, breeding Mycteria americana woodstork occasionally resting, foraging Pandion haliaetus osprey frequently resting, foraging Patagioenas leucocephala white-crowned pigeon frequently resting, foraging Pelecanus erythrorhynchos American white pelican frequently resting, foraging Pelecanus occidentalis brown pelican occasionally resting, foraging Phalacrocorax auritus double-crested cormorant frequently resting, foraging Platalea ajaja roseate spoonbill frequently resting, foraging 3-92

Frequency of Onsite Scientific Name Common Name Observations Onsite Habitat Use Sterna antillarum least tern frequently resting, foraging, breeding Thalasseus maximus royal tern frequently resting, foraging Tringa flavipes lesser yellowlegs occasionally resting, foraging Tyrannus dominicensis grey kingbird frequently resting, foraging Source: FWS 2018a; FPL 2018g 1 3.6.3.3 Important Habitats 2 Sections 2.2.1.6, 2.4.1.2, and 2.4.1.3 of the NRC staffs EIS for the Turkey Point Units 6 and 7 3 combined licenses (NUREG-2176) (NRC 2016a) describe several important terrestrial 4 restoration efforts and habitats located within National Parks, preserves, and other federally 5 owned, State-owned, County-owned, and privately-owned land. These include the following: 6

• Biscayne Bay National Park, which provides mangrove and other important habitat to 7 wildlife and over 200 species of birds, 21 of which are Federally listed as threatened or 8 endangered (NPS 2018a) (see pages 2-10 and 2-79 to 2-80 in NUREG-2176 9 (NRC 2016a)).

10

• Everglades National Park, which encompasses approximately 1.5 million ac 11 (607,000 ha) of wetlands, open water, and other important habitats for a variety of 12 wildlife and birds (see pages 2-11, 2-80, and 2-110 in NUREG-2176 (NRC 2016a)).

13

• The Comprehensive Everglades Restoration Plan (CERP) was approved by Congress in 14 2000 to restore, preserve, and protect the south Florida wetlands ecosystem while 15 providing for other water-related needs of the region. The area covered by this plan 16 includes the entire Everglades ecosystem. This interagency effort is one of the largest 17 ecosystem restoration efforts in the country and includes multiple smaller efforts, such 18 as the Biscayne Bay Coast Wetlands project (NPS 2018a; sees page 2-11 and 2-80 in 19 NUREG-2176 (NRC 2016a)).

20

• South Dade Wetlands Project, also referred to as Model Lands, which is co-managed by 21 Miami-Dade Countys Department of Environmental Resources and the Southwest 22 Florida Water Management System. These areas include over 20,000 ac (8,000 ha) of 23 publicly owned conservation lands, including Miami-Dade County Environmentally 24 Endangered Lands (DERM 2018). These wetlands serve as habitat and refuge for a 25 variety of wildlife, including numerous federally listed and State-listed threatened and 26 endangered species (see pages 2-10 and 2-133 in NUREG-2176 (NRC 2016a)).

27

• Everglades Mitigation Bank, which is a 13,000 ac (5,300 ha) expanse of freshwater and 28 estuarine wetlands west and south of the Turkey Point CCS. FPL owns the Everglades 29 Mitigation Bank and operates it as a commercial mitigation bank offering wetland habitat 30 credits that can be purchased to offset regional wetland impacts (see pages 2-12 and 31 2-133 in NUREG-2176 (NRC 2016a)).

32 The NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176) 33 (NRC 2016a) identifies other important habitats that occur within the vicinity of the Turkey Point 34 site, such as mangrove forests (pages 2-109 to 2-110), pine rockland (page 2-110), marl prairie 3-93

1 (page 2-110), and wetlands (page 2-110). The NRC staff incorporates this information from 2 NUREG-2176 into this SEIS by reference (NRC 2016a: pages 2-109 to 2-110). Federally listed 3 and State-listed threatened or endangered species that have the potential to occur within these 4 important terrestrial habitats are described in pages 2-84 through 2-109 of NUREG-2176 5 (NRC 2016a), which information is also incorporated by reference herein. 6 3.6.4 Invasive and Non-Native Species 7 Several invasive and non-native species occur at Turkey Point. Although FPL does not formally 8 record the occurrence of such species, common invasive species on the Turkey Point site 9 include Australian pine (Casuarina equisetifolia), beach naupaka (Scaevola sericea), Brazilian 10 pepper (Schinus terebinthifolius), Burma reed (Neyraudia reynaudiana), and melaleuca 11 (Melaleuca quinquenervia) (FPL 2018g). The Argentine black-and-white tegu (Tupanimbis 12 merianae) has also been observed at Turkey Point (NRC 2016a). This egg-eating lizard is an 13 omnivore with the potential to affect many species, including alligators and crocodiles, and is the 14 subject of a multiagency control effort in the immediate vicinity of the Turkey Point site. As 15 described in Section 4.6.1.1, FPL (FPL 2018g) maintains a program to remove invasive species 16 from the CCS on an annual basis. 17 3.7 Aquatic Resources 18 This section describes the aquatic resources of the affected environment, including the South 19 Florida Coastal Plain Ecoregion, the CCS, Biscayne Bay, and Card Sound. 20 3.7.1 South Florida Coastal Plain Ecoregion 21 The Turkey Point site is located within the Southern Florida Coastal Plain ecoregion. This 22 ecoregion is characterized by a hydrologically interconnected, slow-flowing network of wetland 23 and aquatic systems, including ridge and slough landscapes, sawgrass plains, cypress and 24 mangrove swamps, and coastal lagoons and bays. The Everglades, a subtropical wetland 25 ecosystem that hosts a rich diversity of aquatic habitats and plant and animal species, comprise 26 much of the ecoregion. The Florida Keys, barrier islands that extend along the extreme 27 southern coast of the Florida Peninsula, protect estuarine bays and coves from the Atlantic 28 Ocean and create important spawning habitats. The South Florida Coastal Plain ecoregion is 29 also known for the Florida reef, the only living coral reef tract in the continental United States. 30 Beginning in the early 1900s, the hydrology of the ecoregion has been highly altered by human 31 activity to support agricultural and urban development. In 1948, Congress authorized the 32 creation of the Central and Southern Florida Flood Control Project, one of the largest water 33 management systems in the world. Through this project, a series of canals were created across 34 southern Florida to drain the land for flood control, water supply and retention, irrigation, and 35 transportation. Subsequent land drainage resulted in the loss or conversion of a substantial 36 portion of the original wetland system, reduced sheet flow dramatically, and created point-37 source discharge of freshwater into estuarine waters and coastal wetlands. The coastal areas 38 of the ecoregion have also become highly populated and dense beachfront development is 39 common. Nevertheless, a large portion of the ecoregion remains protected at the county, State, 40 or Federal level and is managed to maintain and restore the regions unique and sensitive 41 habitats. Section 2.4.2, Aquatic Ecology, of the NRC staffs EIS for the Turkey Point Units 6 42 and 7 combined licenses (NUREG-2176) (NRC 2016a) provides more detailed information on 43 the South Florida Coastal Plain ecoregion, including anthropogenic alterations and other past 3-94

1 changes to the environment. The NRC staff incorporates the NUREG-2176 descriptions of the 2 ecoregion into this SEIS by reference. 3 3.7.2 Aquatic Resources near the Turkey Point Site 4 The region surrounding Turkey Point contains shallow subtropical estuarine and marine 5 environments, including Biscayne Bay and its associated park and preserve; Florida Keys 6 National Marine Sanctuary; Card Sound and Canal; the Everglades Mitigation Bank, Model 7 Lands Basin, and Southern Glades Addition; as well as Everglades National Park and the 8 Crocodile Lake National Wildlife Refuge. 9 Biscayne Bay is a shallow subtropical saline lagoon that extends the length of 10 Miami-Dade County. A series of barrier islands belonging to the Florida Keys borders the 11 eastern edge of the bay and separates the bay from the Atlantic Ocean. The mainland forms 12 the western and northern borders of the bay. Connection between Biscayne Bay and the 13 Atlantic Ocean is greatest north of Boca Chita Key. Ocean access is most restricted in the 14 southern portion of the bay at Card Sound and Barnes Sound due to the presence of Key Largo 15 and its associated barrier islands. The average depth of the bay is approximately 5 ft (1.5 m) at 16 mean low water, and its maximum depth is approximately 13 ft (4.0 m). Salinity is highly 17 influenced by rainfall and ranges from 24 to 44 PSU. Annual surface water temperatures range 18 from 59 °F to 92 °F (15 °C to 33 °C). The bays shallow depths and low spring tidal range 19 (3 ft (0.9 m) maximum) result in a vertically well-mixed system with weak stratification. 20 Within the bay, Biscayne National Park encompasses 173,000 ac (70,000 ha) of water and 21 coastal lands as well as 42 islands. The park is home to a large segment of the Florida reef, the 22 only living coral reef tract in the continental United States. The park supports an immense array 23 of wildlife, including more than 600 fish species, many of which are commercially and 24 recreationally important, and 21 federally threatened or endangered species. Notably, the bay 25 provides habitat for the federally listed Florida manatee (Trichechus manatus latirostris), 26 smalltooth sawfish (Pristis pectinata), American crocodile (Crocodylus acutus), and Johnson's 27 seagrass (Halophila johnsonii) (FDEP 2017b). Johnson's seagrass is the first and only marine 28 plant to be listed as threatened under the Endangered Species Act. 29 The Biscayne Bay Aquatic Preserve includes 67,000 ac (27,000 ha) of sovereign submerged 30 lands managed by the Florida Department of Environmental Protections Office of Coastal and 31 Aquatic Managed Areas. The preserve runs the length of Biscayne Bay from the headwaters of 32 the Oleta River down to Card Sound near Key Largo. The Florida Department of Environmental 33 Protection designated the waters within the Biscayne Bay Aquatic Preserve as Outstanding 34 Florida Waters for waters worthy of special protection because of natural attributes. Under the 35 Outstanding Florida Waters designation, the State cannot issue permits for direct discharges 36 that would lower ambient water quality (FDEP 2017a). 37 Card Sound is a shallow bay south of the Turkey Point site with limited connection to the 38 Atlantic Ocean. It lies wholly within the boundary of the Florida Keys National Marine 39 Sanctuary. The mangrove forests surrounding Card Sound are part of the longest continuous 40 stretch of mangrove remaining on the east coast of Florida and provide a source of food and 41 refuge for approximately 70 percent of the regions commercially and recreationally important 42 marine species. Both Biscayne Bay and Card Sound are nursery areas for the spiny lobster 43 (Panulirus argus). The State of Florida has designated the area from Cape Florida near Key 44 Biscayne south to Card Sound as the Biscayne Bay-Card Sound Lobster Sanctuary. 3-95

1 Section 2.4.2 of the NRC staffs EIS for the Turkey Point Units 6 and 7 combined licenses 2 (NUREG-2176) (NRC 2016a) describes Biscayne Bay, Card Sound, and other nearby aquatic 3 resources in detail. The NRC staff incorporates those descriptions from NUREG-2176 into this 4 SEIS by reference. In addition, see Section 3.7.4 of this SEIS for a detailed discussion of FPLs 5 semiannual monitoring of Biscayne Bay and Card Sound. 6 3.7.3 Aquatic Resources on the Turkey Point Site 7 Within the Turkey Point site, the primary aquatic environment is the cooling canal system 8 (CCS). The CCS occupies an area that is approximately 2 mi (3.2 km) wide by 5 mi (8 km) long 9 and includes 168 mi (270 km) of earthen canals that cover an effective water surface area of 10 approximately of 4,370 ac (1,770 ha) and a total surface area of 5,900 ac (24 km2) (FPL 2018f, 11 NRC 2002c). The CCSs channels are about 200 feet (60 m) wide and range in depth from 1 to 12 3 feet (0.3 to 1 m) (FPL 2018f). FPL constructed the CCS to use as an industrial wastewater 13 facility. For a description of the CCS operations, see Section 3.1.3, Cooling and Auxiliary 14 Water Systems, in this SEIS. 15 The CCS has historically supported a variety of fish, mollusks, crabs, and submerged aquatic 16 vegetation that are tolerant of shallow, subtropical, hypersaline environments such as 17 sheepshead minnow (Cyprinodon variegatus) and several Fundulus species. FPL (FPL 2014a) 18 reported that the species identified in Table 3-8 were present in the CCS as of November 2007. 19 Because the CCS does not directly connect to any surface water body, aquatic organisms are 20 unable to travel between the CCS and any other water bodies. Aquatic biota in the CCS are not 21 accessible for recreational or commercial harvest because FPL controls the entirety of the CCS 22 and does not allow the public to access it. 23 Table 3-8 Aquatic Species Reported from the Cooling Canal System, November 2007 Species Common Name Fish Centropomus undecimalis common snook Cyprinodon variegatus sheepshead minnow Fundulus spp. killifish Gambusia spp. mosquitofish Megalops atlanticus tarpon Mugil spp. mullet Poecilia latipinna sailfin molly Strongylura spp. needlefish Mollusks Busycon contrarium lightning whelk Cerithium eburneum ivory cerith Isognomon alatus flat tree oyster Isognomon radiatus Listers tree oyster Marisa cornuarietis giant rams horm Melampus bidentatus eastern melamphus Melongena corona Florida crown conch 3-96

Species Common Name Tellin spp. tellin Crustaceans Cardisoma guanhumi great land crab Uca spp. fiddler crab Submerged Aquatic Vegetation Acetabularia spp. mermaids wineglass (green algae) Batophora spp. green algae Caulerpa spp. green algae Ruppia maritima widgeon grass Source: adapted from FPL 2014a 1 Other onsite aquatic resources at Turkey Point include hypersaline mudflats, remnant canals, 2 channels, dwarf mangrove wetlands, and open water. In June 2009, Tetra Tech NUS, Inc. 3 (Tetra Tech 2009) conducted fish surveys throughout the Turkey Point property in both CCS 4 and non-CCS waters. Sampling locations, which are depicted in Figure 3-20, included: 5

• mangrove wetland west of Turkey Point (TP-1) 6
• sawgrass marsh/mangrove community adjacent to Palm Drive (TP-2) 7
• south (TP-3A) and north (TP-3B) remnant canals 8
• a portion of the return canal (TP-4) 9
• shallow flats in the east-central part of the Turkey Point plant area (TP-5) 10
• a dead-end canal (TP-6) 11
• CCS north (TP-7) 12
• CCS south (TP-8) 13 During sampling, water temperatures ranged from 75.0 to 97.7 °F (23.9 to 36.5 °C), salinity was 14 above 50 PSU at six sampling stations (TP-3A, TP-4, TP-5, TP-6, TP-7, and TP-8), and salinity 15 was less than or equal to 1.5 PSU at two stations in sawgrass/mangrove habitats (TP-1 and 16 TP-2) (Tetra Tech 2009). Tetra Tech biologists collected fish with 8-foot (2.4-m) cast nets, a 17 20-ft (6-m) -long minnow seine, and standard Gee-type galvanized minnow traps. Sampling 18 yielded a total of 433 fish representing seven species. All but one of the fish collected were 19 small-bodied, short-lived, schooling species representative of two families: the killifishes (family 20 Cyprinodontidae) and the livebearers (family Poeciliidae). Sheepshead minnow was the 21 dominant species; this fish species was present in seven of the eight sampling stations and 22 represented 63 percent of the collection. Sailfin molly (Poecilia latipinna) and goldspotted 23 killifish (Floridichthys carpio) were present at the majority of the sampling stations and 24 represented 20.8 percent and 9.9 percent of collections, respectively. No fish were collected at 25 TP-2, a sawgrass marsh/mangrove community adjacent to Palm Drive. All fish were of hardy 26 species common to South Florida; no rare, unusual, sensitive, or protected species were 27 present in collections. Table 3-9 identifies the collected species, relative abundances, and 28 collection locations.

3-97

1 Source: Tetra Tech 2009, Figure 1 2 Figure 3-20 Turkey Point Site Fish Survey Sample Locations, June 2009 3-98

1 Table 3-9 Number and Relative Abundance of Fish Captured at Seven Locations on the 2 Turkey Point Site, June 2009 Number Species Common Name Collected Collection Locations Cyprinodon variegatus sheepshead minnow 273 all locations except TP-2 Poecilia latipinna sailfin molly 90 all locations except TP-2, TP-5 Floridichthys carpio goldspotted killifish 43 all locations except TP-1, TP-2 Fundulus confluentus marsh killifish 15 TP-1 Fundulus grandis gulf killifish 6 TP-1, TP-3, TP-7, TP-8 Gambusia affinis mosquitofish 5 TP-1, TP-4 Opsanus beta gulf toadfish 1 TP-4 Source: Tetra Tech 2009 3 Prior to 2010, the CCS environment was of low turbidity and contained low and stable nutrient 4 levels. Widgeon grass (Ruppia maritima) beds covered over 50 percent of the system and were 5 especially prominent in the southern sections of the CCS and in the eastern return canals. 6 Seagrasses underwent annual periods of stress and recovery as CCS salinities cycled between 7 greater than 50 PSU (stress) and less than 50 PSU (recovery). Despite the harsh environment, 8 seagrass colonies remained relatively stable from year to year (FPL 2016l). 9 In 2010, the CCS began experiencing a pronounced ecosystem shift. The average salinity of 10 the CCS increased, water quality and clarity began to degrade, and average surface water 11 temperatures increased. Seagrass colonies began to die off due to salinity- and high 12 temperature-related stress. By 2012, very few seagrass beds remained in the CCS. The 13 subsequent decomposition of the seagrasses released a significant volume of nutrients into the 14 CCS, and the increased nutrient levels facilitated algae blooms, which resulted in high turbidity 15 and degraded water quality. Algae blooms remained local and isolated in 2011 and 2012. In 16 2013 and 2014, continuously elevated concentrations of algae were observed throughout the 17 CCS. By 2016, no seagrasses remained in the CCS. The CCS currently operates as an 18 algal-based, phosphorus-limited system such that the algae life cycle primarily dictates the 19 movement of nutrients in and out of the water column (FPL 2016l). 20 To address CCS water quality degradation and as a requirement of the 2016 FDEP Consent 21 Order, FPL began implementing a nutrient management plan (FPL 2016l) in 2016. The plan 22 includes short- and long-term initiatives. One initiative is to re-establish seagrass meadows 23 within the CCS. FPL (FPL 2016l) states in its plan that a healthy seagrass population of 24 approximately 50 percent of the surface water acreage would help balance and sequester the 25 CCSs nutrient content. Seagrasses require non-turbid, clear water with near-ocean salinity 26 levels (roughly 30 to 37 PSU). Given the current turbid, hypersaline, and phosphorus-limited 27 conditions in the CCS, FPL is concentrating its efforts on removing or binding bioavailable 28 phosphorus to reduce algae growth, which would in turn reduce nitrogen fixation, increase water 29 clarity, and improve the conditions for re-establishment of seagrasses. FPL is currently 30 investigating the direct application of flocculants into the CCS, treatment of CCS water in an 31 external system, and the use of protein skimming methods to actively remove algae and 32 nutrients. Once FPL reduces nutrients and lowers salinities, FPL will cultivate and plant 33 seagrass beds within areas of the CCS with appropriate depth and substrate. As CCS 34 conditions improve, some dormant seagrass seeds in the CCS may also germinate such that 3-99

1 seagrasses may reemerge naturally. Once re-established, a healthy seagrass population will 2 provide a significant mechanism for uptake and retention of nutrients, thus reducing nutrient 3 concentrations in the water. Lower nutrient concentrations in the water will deter algal blooms 4 and fewer algal blooms will lead to greater water clarity. FPLs nutrient management plan sets a 5 seagrass colonization target at 50 percent of the CCS water acreage. Section 3.5.1.4 describes 6 the plan in more detail under the subsection titled, Nutrient Management Plan for the Cooling 7 Canal System. 8 To determine the presence, relative abundance, and distribution of fish, invertebrate, and 9 seagrass populations currently within the CCS, FPL commissioned Ecological Associates, Inc. 10 (EAI) to conduct a biological characterization study in December 2016 (EAI 2017). EAI 11 established ten sampling stations within the CCS chosen to represent different benthic habitats, 12 salinity gradients, and temperature regimes (see Figure 3-21). Seven stations were located in 13 the main CCS area, two were located in return canals, and one was located in a dead-end canal 14 in the northern section of the system. EAI sampled fish and mobile invertebrates, benthic 15 macroinvertebrates, and submerged aquatic vegetation. 16 Source: EAI 2017, Figure 1 17 Figure 3-21 Cooling Canal System Characterization Survey Sample Locations, 18 December 2016 3-100

1 To identify fish and mobile invertebrates, EAI performed cast net sampling on 2 December 5, 2016, and minnow trap sampling on December 6 and 7, 2016. Cast net sampling 3 targets large mobile organisms throughout the water column, while minnow trap sampling 4 selectively targets small species at the top and bottom of the water column. EAI collected a 5 total of 4,843 individuals of 4 taxa: sheepshead minnow, sailfin molly, eastern mosquitofish 6 (Gambusia holbrooki), and mudflat fiddler crabs (Uca rapax). Cast net samples yielded 7 282 fish: 259 sheepshead minnow, 22 sailfin molly, and 1 eastern mosquitofish. All fish 8 collected during cast netting were small (less than 45 mm (1.75 inch) standard length). 9 Minnow traps yielded 4,547 fish and 14 crabs: 3,900 sheepshead minnow, 627 sailfin mollies, 10 20 eastern mosquitofish, and 14 mudflat fiddler crabs. Fish ranged from 10 to 60 mm 11 (0.4 to 2.4 inch) standard length, and crabs ranged from 8 to 11 mm (0.3 to 0.43 inch) carapace 12 length and 11 to 15 mm (0.43 to 0.59 inch) carapace width. 13 Sheepshead minnow were abundant throughout the CCS and were found at all 10 sampling 14 stations during the CCS characterization study. This species can live and successfully 15 reproduce in high salinity waters (up to 147 PSU) and high temperatures (up to 109.4 °F 16 (43 °C)) (Johnson 1974). Sailfin mollies were moderately abundant throughout the system. 17 This species is also able to tolerate high salinities (up to 80 PSU), high temperatures (up to 18 104 °F (40 °C)), and low dissolved oxygen (Fischer and Schlupp 2009, Nordlie et al. 1992, 19 Timmerman and Chapman 2004). Eastern mosquitofish were only found at 2 of the 10 20 sampling stations and are likely rare in the CCS as a whole. This species can also tolerate high 21 temperatures (up to 100.4 °F (38 °C)), hypersaline (up to 58.8 PSU) waters with low dissolved 22 oxygen (Chervinski 1983, Specziar 2004). Mudflat fiddler crabs were captured incidentally with 23 sampling methods not designed to capture crabs, so EIA did not make any conclusions 24 regarding crab abundance in its CCS characterization study report. Nevertheless, mudflat 25 fiddler crabs have also been documented as able to withstand high temperature, high salinity, 26 and low dissolved oxygen conditions (Costa and Soares-Gomes 2015, Vernberg and 27 Tashian 1959, Zanders and Rojas 1996). Meroplankton sampling would be required to 28 conclusively determine whether mudflat fiddler crabs are actively reproducing in the CCS or 29 whether individuals were present due to recruitment by immigration into the system. EIA found 30 no evidence that the environmental conditions within the CCS were negatively affecting the 31 growth or reproduction of the species captured, all of which tended to be heat- and salinity-32 tolerant species. 33 To identify benthic macroinvertebrates, EAI collected benthic mini-ponar grabs on 34 December 6, 2016, which EAI subsequently processed in a laboratory. A total of 79 individuals 35 of 3 taxa were identified. The polychaete Capitella capitate was the most common taxon 36 collected followed by marine oligochaetes (Class Oligochaeta) and midge larvae (Family 37 Chironomidae). EAI calculated benthic macroinvertebrate densities to range from 38 30 to 489 individuals per square meter at stations with organisms present. Evidence of relic 39 gastropod and bivalve shells were also present at some stations; however, no live mollusk 40 specimens were collected. 41 In addition to fish and benthic sampling, EAI used underwater video on December 5 42 and 6, 2016, along defined video transect surveys to search for living submerged aquatic 43 vegetation (seagrasses). Widgeon grass, which was previously the predominant submerged 44 aquatic vegetation type present in the CCS, can grow in waters ranging from 64.4 to 86 °F 45 (18 to 30 °C), although temperatures above 73.4 to 77 °F (23 to 25 °C) have a negative 46 influence on photosynthesis (Arnold et al. 2017). One study on the effect of salinity on the 47 species determined that 8- to 12-week old plants could not tolerate salinities above 48 21,000 parts per million (ppm) (Mayer and Low 1970). This equates to approximately 21 PSU. 3-101

1 During the CCS characterization study, EAI observed no seagrasses. Because water clarity 2 was poor throughout the entire project area, EAI also scanned its benthic macroinvertebrate 3 collections for living vegetation. No samples contained living vegetation. In its report, EAI 4 attributed the lack of submerged aquatic vegetation to the CCSs turbid water conditions, high 5 salinity, and high temperatures. 6 While differences in sampling methods and effort make definitive conclusions difficult to 7 determine, the available information on the CCS aquatic community indicates that species 8 diversity within the system has declined over time. Submerged aquatic vegetation is no longer 9 present in the system, and a number of the fish species reported as present in the system 10 in 2007 and 2009 were not collected in 2016. The current aquatic community is of low diversity 11 and includes only those species that can withstand hot, hypersaline waters with low dissolved 12 oxygen and poor water clarity. 13 3.7.4 Biscayne Bay and Card Sound Semiannual Monitoring 14 Since September 2010, FPL has commissioned ongoing, semiannual ecological monitoring of 15 the Turkey Point site and surrounding environment, including Biscayne Bay, as a requirement of 16 the Florida Department of Environmental Protections Conditions of Certification in connection 17 with the Turkey Point extended power uprate and the South Florida Water Management 18 Districts Fifth Supplemental Agreement. Ecology & Environment, Inc. conducted the most 19 recently reported period of monitoring for Biscayne Bay in September 2016 and May 2017 (one 20 fall and one spring event). Ecology & Environment, Inc. summarized and compared the results 21 of this monitoring period with corresponding past results during the historical period of record. 22 The results appear in the 2017 Turkey Point Plant Annual Monitoring Report (E&E 2017). This 23 section briefly summarizes the monitoring methods and the 2016-2017 results. 24 FPL performs aquatic ecological sampling in three locations adjacent to the CCS within 25 Biscayne Bay and Card Sound (BB1, BB2, and BB3) and one reference site in Barnes Sound 26 (BB4), which lies directly south of Card Sound (see Figure 3-22). Within each of the study 27 areas, ecological conditions are monitored along two 2-km (1.2-mi)-long shore-parallel transects 28 (designated a and b for each study area) that lie approximately 250 and 500 m (0.16 and 29 0.32 mi) from shore. Each transect is divided into eight 250-m (0.16-mi)-long segments, and a 30 1-m2 (0.6-mi2) point was randomly selected along each of the eight segments during the initial 31 September 2010 sampling event to be used as the permanent location for all future sampling 32 events. Thus, ecological monitoring encompasses a total of 16 sampling points per study area 33 and a total of 64 sampling points across all study areas. This sampling design is based on 34 FPLs State-approved monitoring plan. 35 At each sampling location, submerged aquatic vegetation is surveyed and categorized 36 according to the Braun-Blanquet Cover Abundance Index. Sediment depth and general 37 physical and surface water parameters are collected. Turtle grass (Thalassia testudinum) 38 blades are collected for laboratory nutrient analysis. In addition to quantitative data, divers also 39 record qualitative characteristics of the benthic conditions surrounding each sampling point. 40 In the 2017 report (E&E 2017), ecological monitoring findings were similar to those reported in 41 previous post-uprate annual monitoring reports. Ecology and Environment Inc.s (E&Es 2017) 42 major findings were as follows. 43

• The marsh and mangrove areas are representative of the hydrologically modified or 44 nutrient-limited communities found along the coastal fringe of south Florida.

3-102

1

• Data collected during the reporting period continue to support the conclusion that the 2 CCS does not have an ecological impact on the surrounding areas, and there is no clear 3 evidence of CCS water in the surrounding marsh or mangrove areas from a groundwater 4 pathway. Rather, ecological changes observed during the reporting period are more 5 seasonally and meteorologically driven.

6 Source: E&E 2017, Figure 1.3-1 7 Figure 3-22 Biscayne Bay and Card Sound Semiannual Monitoring 8 Ecological Transection Locations 3-103

1 3.7.5 Additional Information on Aquatic Resources 2 Section 2.4.2, Aquatic Ecology, of the NRC staffs EIS for Turkey Point Units 6 and 7 3 combined licenses (NUREG-2176) (NRC 2016a) provides more information on the following 4 aspects of the aquatic environment: 5

• Turkey Point ecoregion (pages 2-119 to 2-122) 6
• Historical conditions and anthropogenic alterations to the Turkey Point ecoregion 7 (pages 2-119 to 2-122) 8
• Detailed descriptions of aquatic resources on the Turkey Point site (pages 2-122 to 9 2-128; Table 2-18 and Table 2-19) 10
• Descriptions of the CCS and its water quality through 2016 (pages 2-123 to 2-126) 11
• Summaries of macroinvertebrate and seagrass surveys performed in near-shore areas 12 of Biscayne Bay in 2008 and 2009 to support the Turkey Point 6 and 7 combined 13 licenses application (pages 2-123 to 2-128 and 2-159 to 2-160; Table 2-18 and 14 Table 2-20) 15
• Descriptions of nearby aquatic environments, which include Biscayne Bay and its 16 associated park and preserve, Florida Keys National Marine Sanctuary, Card Sound and 17 Canal, the Everglades Mitigation Bank, Everglades National Park, and the Crocodile 18 Lake National Wildlife Refuge (pages 2-128 through 2-134; Tables 2-21 through 2-25) 19
• Ecologically, commercially, and recreationally important species (pages 2-136 to 2-142; 20 Table 2-27) 21
• State-listed threatened or endangered species and species of concern (page 2-154 to 22 2-157; Table 2-30) 23
• Nonindigenous and invasive species (page 2-142) 24 The NRC staff incorporates this information from NUREG-2176 as indicated by the section, 25 page, and table numbers above, into this SEIS by reference. The NRC staff did not identify any 26 new or updated information relevant to the description of the aquatic environment beyond the 27 additional information previously described in this section.

28 3.8 Special Status Species and Habitats 29 This section addresses species and habitats that are federally protected under the Endangered 30 Species Act of 1973, as amended (16 U.S.C. 1531 et seq.) (ESA), and the Magnuson-Stevens 31 Fishery Conservation and Management Act of 1996, as amended (16 U.S.C. 1801 et seq.) 32 (MSA). Prior to taking a Federal action, such as the issuance of the proposed Turkey Point 33 subsequent renewed licenses, the NRC has direct responsibilities under these statutes. The 34 terrestrial and aquatic resource sections of this SEIS (Sections 3.6 and 3.7, respectively) 35 address species and habitats protected by other Federal statutes and the State of Florida under 36 which the NRC does not have such responsibilities. 37 3.8.1 Species and Habitats Protected Under the Endangered Species Act 38 The U.S. Fish and Wildlife Service and the National Marine Fisheries Service jointly administer 39 the Endangered Species Act. The U.S. Fish and Wildlife Service manages the protection of, 40 and recovery effort for, listed terrestrial and freshwater species, and the National Marine 3-104

1 Fisheries Service manages the protection of, and recovery effort for, listed marine and 2 anadromous species. The following sections describe the Turkey Point action area and then 3 consider separately those species that could occur in the action area under the jurisdiction of 4 each Service. 5 Turkey Point Action Area 6 The implementing regulations for Section 7(a)(2) of the Endangered Species Act define action 7 area as all areas affected directly or indirectly by the Federal action and not merely the 8 immediate area involved in the action (50 CFR 402.02, Definitions). The action area 9 effectively bounds the analysis of federally listed species and critical habitats because only 10 species and habitats that occur within the action area may be affected by the Federal action. 11 For the purposes of assessing the potential impacts of Turkey Point subsequent license renewal 12 on federally listed species, the NRC staff considers the action area to consist of the Turkey 13 Point site, including the CCS, as well as Biscayne Bay. While most potential impacts 14 associated with the proposed action would be confined to the Turkey Point site, continued 15 Turkey Point operations would necessitate occasional delivery of large parts and equipment by 16 barge over the course of the subsequent license renewal term. Such deliveries would require 17 barge travel through Biscayne Bay, which is why the NRC staff includes this waterbody in the 18 Turkey Point action area for subsequent license renewal. 19 The NRC staff recognizes that while the action area is stationary, federally listed species can 20 move in and out of the action area. For instance, a migratory bird species could occur in the 21 Turkey Point action area seasonally as it forages or breeds. Thus, in its analysis, the NRC staff 22 considers not only those species known to occur within the action area, but also those species 23 that may passively or actively move into the action area. The staff then considers whether the 24 life history of each species makes it likely to move into the action area where it could be affected 25 by the proposed Turkey Point subsequent license renewal. 26 The following sections first discuss endangered or threatened species and critical habitats under 27 the U.S. Fish and Wildlife Services (FWS) jurisdiction followed by a discussion of those species 28 under the National Marine Fisheries Services (NMFS) jurisdiction. 29 3.8.1.1 Species and Habitats under U.S. Fish and Wildlife Services Jurisdiction 30 The NRC staff used the U.S. Fish and Wildlife Services Environmental Conservation Online 31 System (ECOS) Information for Planning and Conservation (IPaC) tool to determine species 32 that may be present in the Turkey Point action area. The ECOS IPaC tool identified 42 federally 33 listed endangered or threatened species under the U.S. Fish and Wildlife Services sole 34 jurisdiction with the potential to occur in the Turkey Point action area. The IPaC tool also 35 identified designated critical habitat for two of these species in the Turkey Point action area 36 (FWS 2018b) (see Table 3-10). No proposed species, candidate species, or proposed or 37 designated critical habitat occurs within the action area (FWS 2018b). Table 3-10 describes the 38 habitat requirements, occurrence patterns, and Federal status for each of the 42 federally listed 39 species under FWSs sole jurisdiction. 40 In addition to these 42 species, FWS (FWS 2018b) identified 4 species for which FWS and 41 NMFS have joint jurisdiction, including (1) the loggerhead sea turtle (Caretta caretta), 42 (2) leatherback sea turtle (Dermochelys coriacea), (3) hawksbill sea turtle (Eretmochelys 43 imbricata), and (4) the Atlantic Sturgeon (gulf Subspecies) (Acipenser oxyrinchus (oxyrhynchus) 3-105

1 desotoi). However, the proposed action would have no effect on the nesting habitat of sea 2 turtles or other portions of the life cycle that are under FWSs jurisdiction for these four species 3 (NRC 2018g). The life history and impacts to these species under the jurisdiction of NMFS is 4 described in Sections 3.8.1.2, Species and Habitats under National Marine Fisheries Service, 5 and 4.8.1.2, Species and Habitats Protected Under the Magnuson-Stevens Act. 6 Table 3-10 Federally Listed Species under U.S. Fish and Wildlife Service Jurisdiction Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Mammals Eumops floridanus Florida Suitable roosting (e.g., palm trees, tree cavities, Endangered bonneted bat Spanish tiled roofs) and foraging habitat occurs at Turkey Point (FWS 2017a); Observed within the vicinity of Turkey Point (FPL 2018f). Puma concolor Florida panther Florida Panther Focus Area occurs in the vicinity of Endangered coryi Turkey Point (FWS 1999); Observed 2 mi west of Turkey Point (SFWMD 2013a). Puma concolor (all puma No known occurrences in Florida (FWS 1999; SAT sub species except NRC 2016a). coryi) Trichechus West Indian Designated critical habitat occurs adjacent to Threatened manatus manatee Turkey Point; Observed in the vicinity of Turkey Point, including canals and nearshore seagrass beds in Biscayne Bay (FPL 2012b). Birds Ammodramus Cape Sable Suitable habitat (mixed marl prairie) does not Endangered maritimus mirabilis seaside occur at Turkey Point; No known occurrences at sparrow Turkey Point (NRC 2015a; FPL 2014a). Ammodramus Florida Extirpated from Miami-Dade County (FWS 1999). Endangered savannarum Grasshopper sparrow Aphelocoma Florida scrub- Extirpated from Dade County (FWS 1999). Threatened coerulescens jay Caladris rufa red knot Suitable habitat, such as mudflats, salt marshes, Threatened and mangroves occur onsite (FWS 2017a); Observed onsite (FPL 2014a). Campephilus ivory-billed Likely extirpated from the United States; No known Endangered principalis woodpecker occurrences on or near Turkey Point (FWS 1999 NRC 2016a). Charadrius piping plover Suitable wintering habitat occurs onsite and within Threatened melodus the vicinity, such as beaches, mudflats, and sandflats (FPL 2014a; FPL 2018f); No documented occurrences onsite (FPL 2014a; NRC 2015a) Mycteria americana wood stork Suitable foraging, resting, and roosting habitat Threatened within the CCS and onsite wetlands; Regularly observed onsite (NRC 2015a; EAI 2017; FPL 2018g). 3-106

Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Picoides borealis red-cockaded No known occurrences within Miami-Dade County Endangered woodpecker (FWS 1999; NRC 2016a). Rostrhamus Everglades Suitable habitat (lowland freshwater marshes) Endangered sociabilis snail kite occurs on and near Turkey Point (NRC 2015a); Observed within the Everglades Mitigation Bank adjacent to Turkey Point (FPL 2014a). Setophaga kirtlandi Kirtland's Suitable habitat (dense mangroves) occurs on and Endangered warbler near Turkey Point; No known observations onsite (NRC 2016a; FPL 2018f). Vermivora Bachman's No observations of this species in the United Endangered bachmani warbler States since 1988 (FWS 1999). Reptiles Alligator American Suitable freshwater habitat occurs within the SAT mississippiensis alligator vicinity of Turkey Point (FPL 2018f). Crocodylus acutus American Designated critical habitat at Turkey Point; Onsite Threatened crocodile wetlands provide habitat for nesting, rearing hatchlings, and foraging; Onsite adult and hatchling populations have existed for several decades (FPL 2018f). Drymarchon corais eastern indigo Suitable habitat, including freshwater marshes, Threatened couperi snake mangroves, and cleared areas, occurs at Turkey Point; Regularly observed onsite (FPL 2018g). Invertebrates Anaea troglodyta Florida Suitable habitat (pineland croton plants in pine Endangered floridalis leafwing rockland) does not occur at Turkey Point butterfly (FWS 2017a; FPL 2018f). Cyclargus Miami blue Only known occurrences are within Key West Endangered (=Hemiargus) butterfly National Wildlife Refuge (FFWCC undated; thomasi FPL 2018f). bethunebakeri Heraclides Schaus Suitable habitat (pineland croton plants in pine Endangered aristodemus swallowtail rockland) does not occur at Turkey Point ponceanus butterfly (FWS 2017a; FPL 2018f). Orthalicus reses Stock Island Suitable habitat (hardwood hammocks primarily in Threatened Tree Snail keys) does not occur at Turkey Point; No known occurrence within the vicinity of Turkey Point (FWS 1999; FPL 2018f). Strymon acis Bartram's Suitable habitat, which is limited to pine rockland Endangered bartrami hairstreak where its host plant pineland croton occurs, does butterfly not occur at Turkey Point (FWS 2017a; FPL 2018f). Flowering Plants Amorpha crenulata crenulate lead- Suitable habitat (pine rockland) does not occur at Endangered plant Turkey Point (FWS 2017a). Argythamnia Blodgett's Limited suitable habitat (coastal berm) may occur Threatened blodgettii silverbush onsite; Observed within the vicinity of Turkey Point (FPL 2011b; Gann et al. 2018). 3-107

Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Brickellia mosieri Florida Suitable habitat (pine rockland) does not occur at Endangered brickell-bush Turkey Point (FWS 2017a). Chamaesyce deltoid spurge Suitable habitat (pine rockland) does not occur at Endangered deltoidea ssp. Turkey Point (FWS 2017a). deltoidea Chamaesyce pineland Suitable habitat (pine rockland) does not occur at Threatened deltoidea pinetorum sandmat Turkey Point (NRC 2015a; 82 FR 6691). Chamaesyce Garber's Suitable habitat (pine rockland) does not occur at Threatened garberi spurge Turkey Point (FWS 2017a). Chromolaena Cape Sable Limited suitable habitat (coastal rock barrens) may Endangered frustrata thoroughwort occur at Turkey Point. Species does not occur in disturbed areas (FWS 2010a; FPL 2018f; NRC 2016a). Consolea Florida Limited suitable habitat (coastal berms) may occur Endangered corallicola semaphore at Turkey Point (78 FR 63796; NRC 2016a); No cactus known occurrences at Turkey Point (NRC 2016a; FPL 2018f). Cucurbita Okeechobee No known occurrences in Miami-Dade County; Not Endangered okeechobeensis Gourd likely to occur at Turkey Point due to lake of ssp. suitable habitat (NRC 2016a; Gann et al. 2018; okeechobeensis FPL 2018g). Dalea Florida prairie- Suitable habitat not likely to occur at Turkey Point Endangered carthagenensis clover because some suitable habitats (i.e. pine floridana rocklands, edges of rockland hammocks, and marl prairies) do not occur at Turkey Point and other suitable habitat (i.e., uplands) have been previously disturbed (NRC 2016a; Gann et al. 2018; FPL 2018g). Digitaria pauciflora Florida Suitable habitat (marl prairie and pine rockland) Threatened pineland does not occur at Turkey Point (NRC 2016a; crabgrass Gann et al. 2018; FPL 2018g). Galactia smallii Small's Suitable habitat (pine rockland) does not occur at Endangered milkpea Turkey Point (FWS 2017a). Jacquemontia beach Suitable habitat (pine rockland) does not occur at Endangered reclinata jacquemontia Turkey Point (FWS 2017a). Linum arenicola sand flax Potential to occur onsite given that this species Endangered grows less than 1 mi from Turkey Point and suitable habitat (i.e., pine rocklands, marl prairie, and adjacent disturbed areas) occurs within the vicinity (FPL 2018f). Linum carteri carteri Carter's small- Suitable habitat (pine rockland) does not occur at Endangered flowered flax Turkey Point (FWS 2017a). Polygala smallii tiny polygala Suitable habitat (pine rockland) does not occur at Endangered Turkey Point (FWS 2017a). Sideroxylon Everglades Suitable habitat (pine rockland habitat, marl prairie Threatened reclinatum ssp. bully habitat, and within the ecotone between both austrofloridense habitats) does not occur at Turkey Point (82 FR 46691). 3-108

Federally Common Listed Species Name Habitat Requirements and Occurrence Patterns Status(a) Warea carteri Carter's Extirpated from Miami-Dade County (FWS 1999; Endangered mustard FWS 2008a). Ferns Trichomanes Florida bristle Suitable habitat (rockland hammocks, sinkhole Endangered punctatum ssp. fern habitats, and tree trunks that are in deep shade) floridanum occurs within the vicinity (Gann et al. 2018; NRC 2016a); Potential habitat onsite, although no known occurrences onsite (FPL 2018f). (a) SAT = Federally listed due to similarity of appearance to another listed species, Endangered = Federally listed as endangered, Threatened = Federally listed as threatened at 50 CFR Part 17, Endangered and Threatened Wildlife and Plants, under provisions of the Endangered Species Act Source: FWS 2018b 1 The FWS (FWS 2018b) identifies 23 animals that could occur within the Turkey Point action 2 area. Based on the information in Table 3-10, the NRC staff determined that the following six 3 species are extirpated from Miami-Dade County or are not known to occur within Miami-Dade 4 County and, therefore, the NRC will not consider these further within this SEIS: 5

• Florida grasshopper sparrow (Ammodramus savannarum) 6
• Florida scrub-jay (Aphelocoma coerulescens) 7
• ivory-billed woodpecker (Campephilus principalis) 8
• red-cockaded woodpecker (Picoides borealis) 9
• Bachman's warbler (Vermivora bachmani) 10
• Miami blue butterfly (Cyclargus (=Hemiargus) thomasi bethunebakeri) 11 The NRC staff also does not consider the following five species further within this SEIS because 12 no suitable habitat for these species occurs on the Turkey Point site, there are no known 13 occurrences of the species on site, and the species would not be expected to occur within the 14 action area given the lack of suitable habitat:

15

• Cape Sable seaside sparrow (Ammodramus maritimus mirabilis) 16
• Florida leafwing butterfly (Anaea troglodyta floridalis) 17
• Schaus swallowtail butterfly (Heraclides aristodemus ponceanus) 18
• Stock Island Tree Snail (Orthalicus reses) 19
• Bartram's hairstreak butterfly (Strymon acis bartrami) 20 The following two species are federally listed because of their similarity in appearance to a 21 federally listed endangered or threatened species. A species that is listed due to similarity of 22 appearance is not biologically endangered or threatened and is not subject to ESA Section 7 23 consultation. Therefore, this SEIS does not discuss further these two species:

24

• Puma (Puma concolor (all sub species except coryi)) which was listed for similarity in 25 appearance to the Florida panther (Puma concolor coryi) 26
• American alligator (Alligator mississippiensis) which was listed for similarity in 27 appearance to American crocodile (Crocodylus acutus) 3-109

1 The FWS (FWS 2018b) identifies 19 plant species that could occur within the action area. FPL 2 (FWS 2018f, FPL 2018n, FPL 2018g) is not aware of any federally listed endangered or 3 threatened plant species on the Turkey Point site. The NRC staff did not identify any known 4 occurrence of a federally listed plant species within the action area (FWS 1999, NRC 2016a, 5 FWS 2017a, Gann et al. 2018), although some species have been observed within the vicinity 6 of the action area and have the potential to occur onsite (FPL 2011b). The NRC staff also notes 7 that not all areas of the Turkey Point site have been surveyed for federally listed plants. Based 8 on this limited information, the NRC staff reviewed the habitat requirements for each of the 9 19 federally listed species in Table 3-10 to determine which plants have potential suitable 10 habitat within the action area. The NRC staff determined that the following 14 federally listed 11 plant species would not be expected to occur within the Turkey Point action area due to the lack 12 of suitable habitat or because the species has been extirpated from Miami-Dade County. 13

• crenulate lead-plant (Amorpha crenulata) 14
• Florida brickell-bush (Brickellia mosieri) 15
• deltoid spurge (Chamaesyce deltoidea ssp. deltoidea) 16
• pineland sandmat (Chamaesyce deltoidea pinetorum) 17
• Garber's spurge (Chamaesyce garberi) 18
• Okeechobee gourd (Cucurbita okeechobeensis ssp. okeechobeensis) 19
• Florida prairie-clover (Dalea carthagenensis floridana) 20
• Florida pineland crabgrass (Digitaria pauciflora) 21
• Small's milkpea (Galactia smallii) 22
• beach jacquemontia (Jacquemontia reclinata) 23
• Carter's small-flowered flax (Linum carteri carteri) 24
• tiny polygala (Polygala smallii) 25
• Everglades bully (Sideroxylon reclinatum ssp. austrofloridense) 26
• Carter's mustard (Warea carteri) 27 The remaining 15 federally listed species in Table 3-10 may occur within the action area. These 28 are:

29

• Florida bonneted bat (Eumops floridanus) 30
• Florida panther (Puma concolor coryi) 31
• West Indian manatee (Trichechus manatus) 32
• red knot (Caladris rufa) 33
• piping plover (Charadrius melodus) 34
• wood stork (Mycteria americana) 35
• Everglades snail kite (Rostrhamus sociabilis) 36
• Kirtland's warbler (Setophaga kirtlandi) 37
• American crocodile (Crocodylus acutus) 38
• eastern indigo snake (Drymarchon corais couperi) 39
• Blodgett's silverbush (Argythamnia blodgettii) 40
• Cape Sable thoroughwort (Chromolaena frustrata) 41
• Florida semaphore cactus (Consolea corallicola) 42
• sand flax (Linum arenicola) 43
• Florida bristle fern (Trichomanes punctatum ssp. floridanum) 44 The NRC staff evaluated the potential for the proposed action to affect these species in a 45 biological assessment (NRC 2018n) for the Turkey Point Units 3 and 4 subsequent license 3-110

1 renewal. The ESA Section 7 consultation history, life histories of these 15 species, and an 2 evaluation of impacts to the 15 species can be found in the biological assessment. The NRC 3 staff incorporates by reference that biological assessment (NRC 2018n) into this SEIS. 4 3.8.1.2 Species and Habitats under National Marine Fisheries Services Jurisdiction 5 No federally listed endangered or threatened species under the National Marine Fisheries 6 Services jurisdiction occur on the Turkey Point site itself. Five federally listed species under the 7 NMFSs jurisdiction may occur in Biscayne Bay adjacent to the Turkey Point site (see 8 Table 3-11). 9 Table 3-11 Federally Listed Endangered or Threatened Species Under National Marine 10 Fisheries Service Jurisdiction in Biscayne Bay Federally Distinct Population Listed Species Common Name Segment(s)(a) Status(b) Fish Pristis pectinata smalltooth sawfish United States Endangered Sea Turtles Caretta caretta loggerhead Threatened Chelonia mydas green North Atlantic and South Atlantic Threatened Dermochelys coriacea leatherback Endangered Eretmochelys imbricata hawksbill Endangered (a) Under the Endangered Species Act, a Distinct Population Segment is a vertebrate population or group of populations that is discrete from other populations of the species and significant in relation to the entire species. (b) Endangered = Federally listed as endangered and Threatened = Federally listed as threatened at 50 CFR Part 17, Endangered and Threatened Wildlife and Plants, under the provisions of the Endangered Species Act. Source: NMFS 2017a 11 In 2015, the NRC prepared a biological assessment for the above five species as well as other 12 species to assess the impacts of construction and operation of proposed new reactors Turkey 13 Point Units 6 and 7 (NRC 2015b). Section 5.0, Baseline Conditions for Aquatic Species, of the 14 staffs biological assessment for Turkey Point Units 6 and 7 contains life histories, habitat 15 requirements, status and distributions, factors contributing to the species decline, and the 16 occurrence and status in the project area of the smalltooth sawfish and four sea turtles identified 17 in Table 3-11 on the pages identified as follows: 18

• smalltooth sawfish (pages 5-15 to 5-18; Figure 5-4 and Figure 5-5) 19
• loggerhead sea turtle (pages 5-7 to 5-10; Figure 5-3; Table 5-3) 20
• green sea turtle (pages 5-5 to 5-7; Table 5-2) 21
• leatherback sea turtle (pages 5-12 to 5-13; Table 5-5) 22
• hawksbill sea turtle (pages 5-10 to 5-12; Table 5-4) 23 In that biological assessment, the NRC staff also identified sea turtle stranding information for 24 South Florida and in the vicinity of the Turkey Point site in the assessment (pages 5-1 to 5-5; 3-111

1 Figure 5-1 and Figure 5-2; Table 5-1). This information, as identified by page, table, and figure 2 numbers above, continues to accurately describe these species. Accordingly, the NRC staff 3 incorporates that information into this SEIS by reference. 4 Because there are no surface water connections between the CCS and any natural surface 5 water bodies, none of the species under the NMFSs jurisdiction occur in the CCS or on the 6 Turkey Point site itself. However, all five of the federally listed species may be present in 7 Biscayne Bay and are, therefore, considered to be present in the action area. Documented 8 occurrences of smalltooth sawfish in or near the Turkey Point action area are rare, and, if 9 present, would likely consist of juveniles using the near-shore mangrove communities to avoid 10 predation (NRC 2015b). Leatherback and hawksbill sea turtle stranding data indicate that these 11 species would also rarely occur in Biscayne Bay (NRC 2015b). Loggerhead and green sea 12 turtles are more likely to occur in Biscayne Bay based on stranding data, although occurrences 13 of these species within the Turkey Point action area itself are not particularly common 14 (NRC 2015b). 15 3.8.2 Species and Habitats Protected under the Magnuson-Stevens Act 16 The South Atlantic Fishery Management Council and the NMFS have designated Essential Fish 17 Habitat (EFH) pursuant to the Magnuson-Stevens Act for a number of federally managed 18 species within Biscayne Bay. During the NRC staffs environmental review for the Turkey Point 19 Units 6 and 7 combined license application, the NRC staff worked with the NMFS to identify 20 those species with EFH present near the Turkey Point site. Table 3-12 identifies these species, 21 the applicable fisheries management plan, and relevant EFH habitat designations. During the 22 preparation of this SEIS, the NRC staff confirmed through the NMFSs EFH Mapper that these 23 designations remain valid and that no new EFH has been designated in the vicinity of Turkey 24 Point since the staffs environmental review of the Turkey Point Units 6 and 7 combined license 25 application. 3-112

1 Table 3-12 Designated Essential Fish Habitat near the Turkey Point Site Essential Fish Habitat Applicable Designation(b) Common Fishery Species Seagrass and Name Management Plan(a) Mangrove Unconsolidated Bottom Farfantepenaeus pink shrimp Shrimp Fishery x x duorarum Haemulon plumieri white grunt Snapper- x Grouper Lutianus analis mutton Snapper- x snapper Grouper Lutjanus griseus gray snapper Snapper- x x Grouper Panulirus argus spiny lobster Spiny Lobster x x (a) The Fishery Management Councils and the NMFS designate EFH for federally managed species through fishery management plans. (b) Biscayne Bay and Biscayne National Park are also EFH Habitats of Particular Concern for coral, coral reefs, and hard-bottom communities. Sources: NMFS 201a, NRC 2015c, NRC 2016a, SAFMC and NMFS 2016a 2 In 2015, the NRC staff prepared an Essential Fish Habitat assessment to assess the impacts of 3 construction and operation of proposed Turkey Point Units 6 and 7 (NRC 2015c). Section 4.0, 4 EFH Species Life-History Information, of the staffs EFH assessment describes life histories, 5 habitat requirements, distributions, and population statuses of the five federally managed 6 species identified in Table 3-12 on the pages identified as follows: 7

• pink shrimp (pages 4-4 to 4-5) 8
• white grunt (page 4-3) 9
• mutton snapper (page 4-3) 10
• gray snapper (pages 4-1 to 4-2, Figure 4-1) 11
• spiny lobster (pages 4 3 to 4-4, Figure 4-2) 12 The NRC staff also described in its EFH assessment the applicable fishery management plans 13 for these species (page 3-2) and habitat areas of particular concern (page 3-3). This 14 information, as identified above, continues to accurately describe these species, and the NRC 15 staff therefore incorporates it into this SEIS by reference. The NRC staff addressed two 16 additional speciesbluestriped grunt (Haemulon sciurus) and dog snapper (Lutianus jocu) in 17 its 2015 EFH assessment. However, the South Atlantic Fishery Management Council and the 18 NMFS have since removed these species from the snapper-grouper complex (77 FR 15916, 19 81 FR 32249). Thus, the Snapper-Grouper Fishery Management Plan no longer identifies EFH 20 for these species.

21 While EFH for the species identified in Table 3-12 is designated in Biscayne Bay, neither EFH 22 nor the species themselves occur in the CCS or on the Turkey Point site because there are no 23 surface water connections between the CCS and any other natural surface water bodies. 3-113

1 3.9 Historic and Cultural Resources 2 This section describes the cultural background and the historic and cultural resources found at 3 Turkey Point and in the surrounding area. Section 106 of the National Historic Preservation Act 4 of 1966, as amended (NHPA) (54 U.S.C. 300101 et seq.), requires Federal agencies to 5 consider the effects of their undertakings on historic properties and afford the Advisory Council 6 on Historic Preservation an opportunity to review and comment on the undertaking. 7 Undertakings denote a broad range of Federal activities, including the issuance of NRC reactor 8 licenses and permits. Historic properties are defined as resources included on, or eligible for 9 inclusion on, the National Register of Historic Places (National Register). The criteria for 10 eligibility are listed in Title 36, Parks, Forest, and Public Property, of the Code of Federal 11 Regulations (36 CFR) Section 60.4, Criteria for evaluation, and include (1) association with 12 significant events in history, (2) association with the lives of persons significant in the past, 13 (3) embodiment of distinctive characteristics of type, period, or method of construction, and 14 (4) sites or places that have yielded, or are likely to yield, information important in prehistory or 15 history. 16 In accordance with 36 CFR 800.8(c), Use of the NEPA process for section 106 purposes, the 17 NRC complies with the obligation required under Section 106 of the NHPA through its 18 environmental review process under the National Environmental Policy Act of 1969, as 19 amended (NEPA) (42 U.S.C. 4321 et seq). In the context of the NHPA, the area of potential 20 effect (APE) for a license renewal action is the Turkey Point site and its immediate environs. 21 Turkey Point is located within the 9,460 ac (3,828 ha) FPL property. This property constitutes 22 the APE and consists primarily of developed land, open water, and wetlands. These land areas 23 may be impacted by continued maintenance and operations activities during the subsequent 24 license renewal term. The APE may extend beyond the immediate Turkey Point environs if 25 FPLs maintenance and operations activities affect offsite historic properties irrespective of land 26 ownership or control. 27 In accordance with the provisions of the NHPA, the NRC is required to make a reasonable effort 28 to identify historic properties within the APE. The NRC is required to, in consultation with the 29 SHPO, determine and document the APE and identify historic properties within the APE. If the 30 NRC finds that either there are no historic properties within the APE or the undertaking 31 (subsequent license renewal) would have no effects on historic properties, the NRC provides 32 documentation of this finding to the State historic preservation officer. In addition, the NRC 33 notifies all consulting parties, including Indian tribes, and makes this finding public (through the 34 NEPA process) prior to issuing the renewed license. If historic properties are present and could 35 be affected by the undertaking, the NRC is required to assess and resolve any adverse effects 36 in consultation with the State historic preservation officer and any Indian Tribe that attaches 37 religious and cultural significance to identified historic properties. The Florida Division of 38 Historical Resources, within the Florida Department of State, is responsible for preserving and 39 promoting Floridas historical, archaeological, and folk culture resources. 40 3.9.1 Cultural Background 41 Humans have occupied the southern Florida region for about 12,000 years. The NRC staffs 42 EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176), Section 2.7.1 43 describes in detail the history of human occupation of the Turkey Point site and the surrounding 44 region (NRC 2016a). The NRC staff incorporates this prehistoric occupation description, 3-114

1 contained in pages 2-197 through 2-198 of NUREG-2176, into this SEIS by reference. 2 Prehistoric occupation of the area is divided into the following chronological sequence: 3

• Paleoindian Period (12,000-7,500 BC) 4
• Archaic Period (7,500-500 BC) 5
• Formative Period (500 BC -1513 AD) 6 The history of east coast Florida from European contact to the end of World War II is described 7 on pages 2-199 through 2-201 of NUREG-2176 (NRC 2016a). The NRC staff incorporates 8 these pages into this SEIS by reference. In brief, European arrival and contact with aboriginal 9 people of southern Florida occurred in 1513 when Spanish explorers arrived on Floridas 10 eastern coast. European colonization resulted in the loss of Tribal lands and the decline of 11 Native American populations. In 1821, Spain ceded Florida Territory to the United States, and 12 Florida was granted statehood in 1845. During World War I, several training facilities were set 13 up in the State of Florida. The States economy was boosted by the war, primarily through 14 shipbuilding and industrialization of port cities. During World War II, Florida became one of the 15 Nations major training grounds for various military branches, and the influx of thousands of 16 servicemen and their families increased industrial and agricultural production in Florida. With 17 the establishment of the Everglades National Park in 1947, tourism increased in the area and 18 became one of the major sources of the States economy. The NRC staff has identified no new 19 and significant information related to the cultural history of the Turkey Point region in its review 20 of FPLs environmental report submitted as part of the subsequent license renewal application 21 (FPL 2018f), during the onsite environmental audit at Turkey Point, or through the scoping 22 process, beyond the information in the EIS for Turkey Point Units 6 and 7.

23 3.9.2 Historic and Cultural Resources at Turkey Point 24 Historic and cultural resources in the vicinity of Turkey Point can include prehistoric era and 25 historic era archaeological sites, historic districts, and buildings, as well as any site, structure, or 26 object that may be considered eligible for listing on the National Register of Historic 27 Places (NRHP). Historic and cultural resources also include traditional cultural properties that 28 are important to a living community of people for maintaining their culture. Historic property is 29 the legal term for a historic or cultural resource that is included on, or eligible for inclusion on, 30 the NRHP. The staff notes that the vicinity of a site is not equivalent to an APE; rather, it is the 31 area within a 6-mi (9.6 km) radius of the plant, as explained in NUREG-1555, Supplement 1, 32 Rev. 1. 33 A cultural resource survey was not conducted on the FPL site prior to Turkey Points 34 construction (FPL 2018f). Construction of Turkey Point likely disturbed any historic and 35 archaeological resource that may have been located within its footprint. Approximately 36 28 percent (2,700 ac (1093 ha)) of the site is undeveloped and undisturbed (FPL 2018h). 37 Although no comprehensive cultural resource survey has been completed for the entire Turkey 38 Point site, several cultural resource studies of the site were conducted on portions of the site 39 between 2004 and 2013 (FPL 2018f, Janus 2009, FPL 2018h). FPL estimates that 40 approximately 10 percent of the Turkey Point site (approximately 950 ac (384 ha)) has been 41 surveyed collectively between these cultural resource surveys (FPL 2018h). These cultural 42 resource studies did not identify archeological sites or historic resources on the Turkey Point 43 site areas that were surveyed, and they concluded that the Turkey Point site has a low 44 archeological potential (FPL 2018f and Janus 2009). 3-115

1 During the NRC staffs environmental site audit, the NRC staff became aware of three wooden 2 buildings that were part of a Boy Scouts of America camp and a cottage (known as the Range 3 House/McGregor Smith Cottage) that are over 50 years old and could have potential historic 4 significance (FPL 2018h). The Boy Scout camp was constructed by FPL between 1962 and 5 1963 (FPL 2018m). After FPL completed construction of the cooling canals in the early 1970s, 6 the Boy Scout camp was no longer used for Boy Scout activities (FPL 2018m). FPL has 7 maintained and repaired the three wooden structures associated with the former Boy Scout 8 camp, and now uses these structures for storage (NRC 1972, FPL 2018h, FPL 2018m). Two of 9 these structures have gable roofs, and the third has a pyramid roof. Although they have not yet 10 been formally evaluated, FPL has indicated that the three structures do not appear to meet the 11 criteria for listing on the NRHP (FPL 2018h, FPL 2018m). 12 The Ranger House/McGregor Smith Cottage is a wood frame elevated structure supported by 13 large cylindrical wooden posts; the ground floor space and second level wraparound porch are 14 enclosed with screens (MDC 2018d). The structure was built sometime between 1965 and 15 1968 for the purposes of housing a full-time Florida Board of Conservation ranger (FPL 2018m). 16 The structure is named after McGregor Smith, one of Florida Power & Lights first presidents 17 (from 1939-1954), who later served as chief executive officer. According to FPL, McGregor 18 Smith is also known for his involvement with the Boy Scouts and southern Florida economic 19 development (FPL 2018h). Past use of the cottage included use as a meeting space during 20 construction of Turkey Point and as a construction office and fish camp during the 1980s. 21 During the 1990s, the cottage was renovated to make it a habitable residence for senior FPL 22 staff (FPL 2018m). In 2012, FPL contacted the Miami-Dade Countys Office of Historical 23 Resources to discuss designation of the Ranger House/McGregor Smith Cottage for historical 24 landmark status and potential restoration of the cottage. According to Miami-Dade Countys 25 Office of Historical Resources, McGregor Smith was an important figure in the history of the 26 Florida Power & Light Company and the cottage played a significant role in the early history of 27 the FPL power plant at Turkey Point and is worthy of saving for future staff use and as a vestige 28 of the flurry of activity that once took place in and around the power plant during the 1960s. 29 However, in 2012 when FPL contacted the Miami-Dade Countys Office of Historical Resources, 30 the Ranger House/McGregor Smith Cottage had not yet met the 50-year benchmark required 31 for consideration for eligibility for listing in the NRHP (MDC 2018d). As of the date of publication 32 of this SEIS, FPL has not evaluated the Ranger House/McGregor Smith Cottage for eligibility for 33 listing in the NRHP (FPL 2018h). 34 FPL conducted a desktop study of offsite cultural resources within the vicinity of Turkey Point. 35 Within a 6-mi (9.6 km) radius of the Turkey Point site, there are 95 known historic and cultural 36 resources. Of these, 28 resources are ineligible for listing, 65 resources have not been 37 evaluated for listing, and 2 resources have been determined eligible for listing in the NRHP 38 (FPL 2018f). 39 3.10 Socioeconomics 40 This section describes current socioeconomic factors that have the potential to be directly or 41 indirectly affected by changes in operations at Turkey Point. Turkey Point and the communities 42 that support it can be described as a dynamic socioeconomic system. The communities supply 43 the people, goods, and services required to operate the nuclear power plant. Power plant 44 operations, in turn, supply wages and benefits for people and dollar expenditures for goods and 45 services. The measure of a communitys ability to support Turkey Point operations depends on 46 the communitys ability to respond to changing environmental, social, economic, and 47 demographic conditions. 3-116

1 3.10.1 Power Plant Employment 2 The socioeconomic region of influence (ROI) is defined by the area where Turkey Point workers 3 and their families reside, spend their income, and use their benefits, thus affecting the economic 4 conditions of the region. Currently, FPL employs a permanent workforce of approximately 5 680 workers (FPL 2018f). Approximately 85 percent of this workforce resides in Miami-Dade 6 County (Table 3-13). The remaining workers are spread among 12 counties in Florida and 7 Georgia, with numbers ranging from 1 worker to 49 workers per county (FPL 2018f). In addition 8 to permanent Turkey Point plant employees, FPL hires contract workers to support plant 9 operations. In 2017, FPL employed 366 onsite contract workers; 80 percent of the contract 10 workers resided in Miami-Dade County. The number of contract workers employed each year 11 has remained relatively stable for the last 5 years with the exception of one year. In 2013, FPL 12 employed 763 onsite contract workers as a result of the extended power uprate for Turkey Point 13 (FPL 2018h). Since the majority of permanent workers (85 percent) and contract workers 14 (80 percent) reside in Miami-Dade County, the most significant socioeconomic effects of plant 15 operations are likely to occur in this county. The focus of the impact analysis and region of 16 influence, therefore, is on the socioeconomic impacts of continued Turkey Point operations 17 during the subsequent license renewal period on Miami-Dade County. 18 Table 3-13 Residence of Permanent Turkey Point Employees by County County Number of Employees Percentage of Total Total 679 100 Florida Broward 49 7 Miami-Dade 577 85 Monroe 40 6 Palm Beach 4 1 Other states and counties 9 1 Source: FPL 2018f 19 Refueling outages for Turkey Point Units 3 and 4 occur on a staggered 18-month schedule for 20 each unit and have historically lasted 25 to 35 days per unit. During refueling outages, onsite 21 employment typically increases by an additional 1,200 workers. As there are no subsequent 22 license renewal-related refurbishment activities, FPL has no plans to add additional employees 23 to support plant operations during the subsequent license renewal period (FPL 2018f). 24 3.10.2 Regional Economic Characteristics 25 This section presents information on employment and income in the Turkey Point 26 socioeconomic region of influence. 27 3.10.2.1 Regional Employment and Income 28 In 2016, the Miami-Dade County civilian labor force was approximately 1,370,950 individuals 29 (USCB 2016a). From 2011 to 2016, the labor force in Miami-Dade County increased by 30 5.6 percent (USCB 2016a and USCB 2011). From 2011 to 2016, the number of employed 31 people in Miami-Dade County increased by 14 percent. 3-117

1 According to the U.S. Census Bureaus (USCBs) 2016 American Community Survey 1-year 2 Estimates, educational services, and health care and social assistance represents the largest 3 employment sector in Miami-Dade County (approximately 20 percent), followed by professional, 4 scientific, and management, and administrative and waste management services 5 (approximately 13 percent). A list of employment by industry in Miami-Dade County is provided 6 in Table 3-14. Turkey Points permanent workforce residing in Miami-Dade County represents 7 approximately 0.04 percent of Miami-Dade Countys employed civilian labor force. Estimated 8 income information for the Miami-Dade County and Florida, for comparison, is presented in 9 Table 3-15. National parks in the vicinity of Turkey Point, such as Biscayne National Park and 10 the Everglades National Park, attract visitors that support economic activity. For instance, in 11 2017, Biscayne National Park and the Everglades National Park supported approximately 12 1,680 jobs and $65,319,000 in labor income (NPS 2018b). 13 Table 3-14 Employment by Industry in Miami-Dade County (2016 Estimates) Industry Miami-Dade County Percent Agriculture, forestry, fishing and hunting, and mining 9,929 0.8 Construction 103,636 8.0 Manufacturing 57,130 4.4 Wholesale trade 46,086 3.6 Retail trade 158,752 12.3 Transportation and warehousing and utilities 106,084 8.2 Information 23,941 1.9 Finance, insurance, real estate, rental, leasing 97,194 7.5 Professional, scientific, and administrative and waste 160,672 12.5 management services Educational services, and health care and social assistance 252,384 19.6 Arts, entertainment, recreation, accommodation and food services 149,588 11.6 Other services (except public administration) 79,895 6.2 Public administration 44,806 3.5 Total Employed Civilian Workers 1,290,097 Source: USCB 2016a 14 Table 3-15 Estimated Income Information for Miami-Dade County and Florida 15 (2016 Estimate) Miami-Dade County Florida Median household income (dollars)(a) 45,935 50,860 Per capita income (dollars)(a) 25,700 28,621 Families living below the poverty level (percent) 14.7 10.5 People living below the poverty level (percent) 18.3 14.7 (a) In 2016 inflation-adjusted dollars Source: USCB 2016a 3-118

1 3.10.2.2 Unemployment 2 According to the USCBs 2016 American Community Survey 1-Year Estimates, the 3 unemployment rate in Miami-Dade County was 5.9 percent (USCB 2016a). Comparatively, the 4 unemployment rate in the State of Florida in 2016 was 6.0 percent (USCB 2016b). 5 3.10.3 Demographic Characteristics 6 An estimated 702,557 people live within 20 mi (32 km) of Turkey Point, which equates to an 7 average population density of 559 persons per square mile (FPL 2018f). This translates to a 8 Category 4, Least sparse population density using NUREG-1437, Generic Environmental 9 Impact Statement for License Renewal of Nuclear Plants (NRC 1996) measure of sparseness 10 (greater than 120 persons per square mile within 20 mi). An estimated 3,472,804 people live 11 within a 50-mi (80-km) radius of Turkey Point, which equates to an average population density 12 of 442 persons per square mile. This translates to a Category 4, In close proximity measure of 13 proximity (greater than 190 persons per square mile within 50 mi) using NUREG-1437, Generic 14 Environmental Impact Statement for License Renewal of Nuclear Plants (NRC 1996). Both a 15 Category 4 measure of sparseness and proximity results in a High population category based 16 on Figure C.1 of the license renewal GEIS sparseness and proximity matrix (NRC 1996). "High" 17 population category corresponds to the least sparse population category and sites that are in 18 close proximity to large cities. Therefore, Turkey Point is located in a High population area 19 based on the license renewal GEIS sparseness and proximity matrix. As shown in Figure 3-1, 20 Turkey Point is located on the coast and much of the area within a 50-mi (80-km) radius around 21 the site consists of ocean and is unpopulated. Additionally, Everglades National Park, located 22 west of the site, is unpopulated (EPA 2019). The population living within a 50-mi (80-km) radius 23 of Turkey Point is primarily concentrated north, north-northeast, and north-northwest of Turkey 24 Point. 25 Table 3-16 shows population percent growth and projections from 1990 to 2060 in 26 Miami-Dade County. Over the last several decades, Miami-Dade County has experienced 27 increasing population. Based on population projections, the population in Miami-Dade County is 28 expected to continue to increase, but at a lower rate. 29 Table 3-16 Population and Percent Growth in Miami-Dade County 1990-2060 Miami Dade County Year Population Percent Change Since Prior Entry 1990 1,937,094 - 2000 2,253,362 16.3 2010 2,496,435 10.8 2016 2,712,945 8.7(a) 2020 2,872,760 15.1(a) 2030 3,215,054 11.9 2040 3,477,569 8.2 2050 3,811,933 9.6 2060 4,127,087 8.3 (a) Percent change from 2010 Source: Decennial population data for 1970-2010 (USCB 1996, USCB 2000a, USCB 2010a); Estimated population for 2016 (USCB 2016b); Projected population for 2020-2040 (BEBR 2017); Calculated projected population for 2050-2060. 3-119

1 The 2010 Census demographic profile of the Miami-Dade County population is presented in 2 Table 3-17. According to the 2010 Census (USCB 2010a), minorities (race and ethnicity 3 combined) comprised approximately 85 percent of the total population. The largest minority 4 population in Miami-Dade County was Hispanic or Latino of any race (65 percent of the total 5 population; 77 percent of the total minority population). For comparison, according to the 2010 6 Census, minorities comprised approximately 42 percent of the total state of Florida population 7 (USCB 2010b). 8 Table 3-17 Demographic Profile of the Population in Miami-Dade County in 2010 Miami-Dade County Total Population 2,496,435 Race (Percent of Total Population) White 73.8 Black or African American 18.9 American Indian and Alaska Native 0.2 Asian 1.5 Native Hawaiian and Other Pacific Islander 0 Some other race 3.2 Two or more races 2.4 Hispanic, Latino, or Spanish Ethnicity of Any Race Hispanic or Latino 1,623,589 Percent of total population 65.0 Minority Population (Including Hispanic or Latino Ethnicity) Total minority population 2,112,884 Percent minority 84.6 Source: USCB 2010a 9 According to the USCBs 2016 American Community Survey 1-Year Estimates, since 2010, 10 minority populations in the Miami-Dade County were estimated to have increased by 11 approximately 232,000 persons (see Table 3-18). The largest increases occurred in the 12 Hispanic or Latino population (nearly 212,000 person increases since 2010, an increase of 13 approximately 13 percent). According to the Census Bureau, minorities comprised 69 percent 14 of the total Miami-Dade County population in 1990 (USCB 1990). By 2000, the countys 15 minority population had increased to 79 percent of the population (USCB 2000b). 16 Table 3-18 Demographic Profile of the Population in Miami-Dade County, 2016 17 Estimates Miami-Dade County Total Population 2,712,945 Race (Percent of Total Population) White 74.5 Black or African American 17.6 American Indian and Alaska Native 0.2 Asian 1.6 3-120

Miami-Dade County Native Hawaiian and Other Pacific Islander 0 Some other race 4.6 Two or more races 1.6 Hispanic, Latino, or Spanish Ethnicity of Any Race Hispanic or Latino 1,835,412 Percent of total population 67.8 Minority Population (Including Hispanic or Latino Ethnicity) Total minority population 2,344,897 Percent minority 86.4 Source: USCB 2016b 1 3.10.3.1 Transient Population 2 Miami-Dade County can experience seasonal transient population growth as a result of local 3 tourism, recreational activities, or university attendance. For instance, in 2017, Biscayne Bay 4 National Park had approximately 447,000 visitors and Everglades National Park had 5 approximately 1,019,000 visitors (NPS 2017a). In 2016, approximately 200,800 students were 6 enrolled in college or graduate school in Miami-Dade County (USCB 2016c). A transient 7 population creates a demand for temporary housing and services in the area. 8 Based on USCBs 2016 American Community Survey 1-Year Estimates (USCB 2016d), 9 approximately 216,677 seasonal housing units are located in the four counties within a 10 50-mi (80-km) radius of Turkey Point (Miami-Dade, Monroe, Broward, and Collier counties). Of 11 those, 66,528 seasonal housing units are located in Miami-Dade County. Table 3-19 presents 12 information about seasonal housing for the counties all partly within the 50 mi (80 km) of Turkey 13 Point. The Greater Miami Convention and Visitors Bureau estimates that in 2018, 14 Miami-Dade County had 433 hotels/motels and approximately 55,450 rooms (GMCVB 2018). 15 Table 3-19 2016 Estimated Seasonal Housing in Counties Located Within 50 mi (80 km) 16 of Turkey Point Total Vacant Housing Units: for Percent Vacant Housing Total Vacant Seasonal, Recreational, Seasonal County Units Units or Occasional Use Housing Units Miami-Dade 1,021,650 140,884 66,528 6.5 Monroe 53,129 22,811 14,854 27.5 Broward 822,980 141,506 78,911 9.6 Collier 210,147 70,625 56,384 26.8 Total 2,107,906 375,826 216,677 Source: USCB 2016b and USCB 2016d 3-121

1 3.10.3.2 Migrant Farm Workers 2 Migrant farm workers are individuals whose employment requires travel to harvest agricultural 3 crops. These workers may or may not have a permanent residence. Some migrant workers 4 follow the harvesting of crops, particularly fruit, throughout rural areas of the United States. 5 Migrant workers may be members of minority or low-income populations. Because they travel 6 and can spend a significant amount of time in an area without being actual residents, migrant 7 workers may be unavailable for counting by census takers. If uncounted, these minority and 8 low-income workers would be underrepresented in the decennial Census population counts. 9 Since 2002, the Census of Agriculture reports the numbers of farms hiring migrant workers 10 defined as a farm worker whose employment required travel that prevented the worker from 11 returning to his/her permanent place of residence the same day (USDA 2012). The Census of 12 Agriculture is conducted every 5 years and results in a comprehensive compilation of 13 agricultural production data for every county and parish in the Nation. 14 Information about both migrant and temporary farm labor (persons working less than 150 days) 15 can be found in the 2012 Census of Agriculture. Table 3-20 presents information on migrant 16 and temporary farm labor in the four counties within a 50-mi radius of Turkey Point. According 17 to the 2012 Census, 9,185 farm workers were hired to work for less than 150 days and were 18 employed on 1,073 farms in the 4 counties within 50-mi of Turkey Point. The county with the 19 highest number of temporary farm workers (4,480) on 63 farms was Collier County. 20 Approximately 125 farms in the 4 counties within 50-mi of Turkey Point reported hiring 21 approximately 3,590 migrant workers (USDA 2012). 22 Table 3-20 2012 Migrant Farm Workers and Temporary Farm Labor in Counties Located 23 within 50 mi of Turkey Point Number of Number of Farm Number of Farms Farms with Number of Farms Workers Working Reporting Hired Farm Hiring Workers for for Less Than Migrant Farm County Labor Less Than 150 Days 150 Days Labor Miami-Dade 1,318 836 3,850 106 Monroe 15 7 83 - Broward 234 167 772 7 Collier 104 63 4,480 12 Total 1,671 1,073 9,185 125 USDA 2012 24 3.10.4 Housing and Community Services 25 This section presents information regarding housing and local public services, including 26 education and water supply. 27 3.10.4.1 Housing 28 Table 3-21 lists the total number of occupied and vacant housing units, the housing vacancy 29 rates, and the median value of housing units in Miami-Dade County. Based on USCBs 2016 30 American Community Survey 1-year estimates (USCB 2016e), there were approximately 3-122

1 1,022,000 housing units in Miami-Dade County, of which approximately 881,000 were occupied. 2 The median value of owner-occupied housing units is $265,200. 3 Table 3-21 Housing in Miami-Dade County (2016) Miami-Dade County Total housing units 1,021,650 Occupied housing units 880,766 Total vacant housing units 140,884 Percent total vacant 13.8 Owner occupied units 446,018 Median value (dollars) $265,200 Owner vacancy rate (percent) 1.9 Renter occupied units 434,748 Median rent (dollars/month) 1,201 Rental vacancy rate (percent) 5.2 Source: USCB 2016e 4 3.10.4.2 Education 5 The Miami-Dade County Public School District is comprised of 472 schools and approximately 6 354,000 students. The Miami-Dade County Public School District is the fourth largest school 7 district in the United States (MDCPS 2018). The 2016-2017 Miami-Dade County Public School 8 District total revenue was $4,232 million, of which approximately 59 percent was from local 9 support (see discussion in Section 3.10.5, Tax Revenues) (MDCPS 2017a). 10 3.10.4.3 Public Water Supply 11 The Miami-Dade Water and Sewer Department is the main public water supplier in Miami-Dade 12 County. Miami-Dade County relies on groundwater withdrawn from the Biscayne aquifer and 13 Floridian aquifer (see Section 3.5.2.1 for detailed discussion of these two major aquifer 14 systems). Water is provided by the Miami-Dade Water and Sewer Department through four 15 regional water treatment plants: Hialeah and John E. Preston Water Treatment Plant, the 16 Hialeah Reverse Osmosis Water Treatment Plant, the Alexander Orr, Jr. Water Treatment 17 Plant, and the South Dade Water Supply System (which is comprised of five smaller water 18 treatment plants) (MDC 2014). The Newton Water Treatment Plant (part of the South Dade 19 Water Supply System) serves Turkey Point. In addition to the Miami-Dade Water and Sewer 20 Department, four water suppliers within Miami-Dade County provide water to parts of 21 unincorporated Miami-Dade County and within their municipal boundaries: the City of North 22 Miami, the City of North Miami Beach, Florida City, and City of Homestead. The capacity of 23 wellfields and the water treatment plant facilities installed capacity are presented in Table 3-22. 24 In 2013, the Miami-Dade Water and Sewer Department system population served was 25 2,222,944 and annual average daily demand was 302 mgd. Despite increases in population, 26 water use has decreased between 2004 and 2013 by 16 percent. Decrease in water use has 27 been attributed to Miami-Dade Countys water use efficiency legislation and implementation of 28 the Countys water conservation plan (MDC 2014). According to the Miami-Dade Water Supply 29 Facilities Work Plan (MDC 2014), when taking into consideration water conservation, by 2033, 3-123

1 annual average daily water demand in the Miami-Dade Water and Sewer Department service 2 area is projected to be 352 mgd (MDC 2014). 3 Table 3-22 Major Public Water Suppliers in Miami-Dade County Wellfield Supply Installed Treatment System Name Capacity (mgd) Facility Capacity (mgd) Population Served City of North Miami 14.96 9.30 91,000 City of North Miami-Beach 39.97 32.0 164,000 City of Homestead 16.99 16.9 65,000 Florida City 4 4 9,700 Miami-Dade Water and Sewer 634.01 497.19 2,223,000 Department Service Areas (Total) Hialeah-Preston Treatment Plant 295 225 Hialeah Reverse Osmosis Water 12 10 Treatment Plant Alexander Orr, Jr. Water Treatment 308 248 Plant South Dade Water Treatment Plants 19.01 14.19 (5 plants) (Total) Elevated Tank 4.32 - Everglades Labor 5.04 - Leisure City 4.18 - Naranja 1.15 - Newton 4.32 - mgd: millions of gallons per day Source: MDC 2014 4 3.10.5 Tax Revenues 5 The State of Florida does not have a State-level property tax. Private property owners pay 6 property taxes to the county and a local school district and may also pay taxes to regional taxing 7 districts. In Florida, real estate property and tangible personal property are subject to property 8 tax. Property values are set by the county property appraiser and are collected by the county 9 tax collector. The tax rate (millage) is set by each taxing unit. County and school district 10 governments may levy taxes up to 10 mills ($10.00 per thousand of assessed valuation) each. 11 As discussed below, FPL pays property taxes (real and tangible personal property) for Turkey 12 Point to Miami-Dade County, the Miami-Dade School District, and several regional taxing 13 districts (FPL 2018f). 14 The Miami-Dade County budget is comprised of appropriations from various revenues. The 15 total Miami-Dade County operating revenues for the years 2012 through 2017 are presented in 16 Table 3-23. Property taxes are a significant source of Miami-Dade County funding. For 17 instance, property tax revenues have ranged from 23 to 33 percent of the total Miami-Dade 18 County revenues between 2012 and 2017. Miami-Dade County property taxes fund four 19 separate taxing jurisdictions: Countywide, Unincorporated Municipality Service Area, the Fire 3-124

1 Rescue District, and the Library System. Each of the four taxing jurisdictions is responsible for 2 different types of services (MDC 2016b). For instance, the County-wide jurisdiction provides 3 public health and social services, transportation, regional parks, and county roads, the court 4 systems, and the regional sheriff services and jails. Additionally, Miami-Dade County also has a 5 countywide debt and a Fire Rescue District debt millage. The revenue raised from the debt 6 service millage pays outstanding debt for voter-approved general or special obligation bonds. 7 The amount of property tax received by a taxing jurisdiction is a result of the millage rate applied 8 by each county taxing jurisdiction. For 2017, the overall property tax millage rate was 9.7074 9 (MDC 2016b). 10 The Miami-Dade County Public School District is a taxing entity separate from Miami-Dade 11 County. The Florida Education Finance Program is the primary mechanism for funding the 12 operating costs of Florida school districts (FLDOE 2017). The Florida Education Finance 13 Program allocates funds to the Miami-Dade County Public School District based on student 14 enrollment (FHR 2010). Funding for school districts comes from State, local, and Federal 15 sources. Local funding is obtained primarily from property taxes levied by Floridas counties, 16 each of which constitutes a school district. Property taxes on properties located within the 17 school district are levied after the millage rate is certified. Table 3-23 presents the Miami-Dade 18 County School Board revenues for years 2012 through 2017. Property tax revenues provided 19 approximately 45 to 52 percent of the total Miami-Dade County School Board revenues for 20 years 2012 through 2017. 21 Miami-Dade County also imposes special district millage. These include the Childrens Trust 22 Authority, the Everglades Construction Project, the Okeechobee Basin, the South Florida Water 23 Management District, and the Florida Inland Navigation District (SFWMD 2011a). Fiscal Year 24 2016-2017 total special district millage for Miami-Dade County was 0.3627 (MDC 2016c). 25 Table 3-23 Miami-Dade County Total Operating Revenues, Miami-Dade County School 26 Board Revenues, and Florida Power & Light Turkey Point Property Tax 27 Payments (2012-2017) 2012 2013 2014 2015 2016 2017 Miami-Dade County Total Operating Revenues 5.399 5.375 5.423 5.612 5.792 4.865 (in billions of dollars) Miami-Dade County School Board Revenues 3.222 3.302 3.524 3.581 3.631 3.729 (in billions of dollars) Turkey Point total property tax paid (in millions 6.653 29.613 40.594 38.995 37.882 36.570 of dollars) Tax payment assigned to Miami-Dade County 3.446 15.280 21.108 20.394 20.229 19.858 (percent of total Miami-Dade County (0.06) (0.3) (0.3) (0.5) (0.4) (0.4) Revenues) Tax payment assigned to Miami-Dade County 2.834 12.792 17.374 16.665 15.796 14.957 School District (percent of total Miami-Dade (0.08) (0.4) (0.5) (0.5) (0.4) (0.4) County School Board Revenues) Tax payment assigned to special districts 0.372 1.629 2.070 1.911 1.856 1.755 Source: FPL 2018f, FPL 2018h, MDC 2015b, MDC 2016b, MDC 2017f, MDCPS 2017b 28 FPL pays property taxes (real and tangible personal property) for Turkey Point to Miami-Dade 29 County, the Miami-Dade County Public School District, and several regional taxing districts 30 (FPL 2018f). Turkey Point property tax payment for 2012-2017 are presented in Table 3-23. 3-125

1 The increase in property tax payment from 2012 to 2013 and from 2013 to 2014 is a result of 2 plant modifications conducted to support an extended power uprate and the lien date 3 (FPL 2018f and FPL 2018h). On June 15, 2012, the NRC granted a license amendment to FPL 4 for an extended power uprate of Turkey Point (NRC 2012). Plant modifications and upgrades 5 for the extended power uprate occurred in 2012 and 2013 and the valuation of the plant 6 upgrades conducted in one year become taxable in the following year. This resulted in the 7 Turkey Point property tax increases observed in 2013 and 2014. Turkey Point property tax 8 payments to Miami-Dade County and Miami-Dade County Public School District have 9 represented less than 1 percent of the Miami-Dade County revenue and of Miami-Dade County 10 Public School District tax revenues. FPL does not expect there to be a notable or significant 11 change to future property tax payments during the subsequent license renewal period 12 (FPL 2018f). 13 In addition to property tax payments, FPL pays sales tax to Miami-Dade County for purchases. 14 In 2017, FPL paid approximately $224,000 in sale taxes to Miami-Dade County from Turkey 15 Point operation expenses (FPL 2018h). FPL also contributes $1.5 million annually to 16 community organizations (FPL 2018h). 17 3.10.6 Local Transportation 18 The transportation network surrounding the Turkey Point site is comprised of U.S. highways, 19 Interstate highways, local streets, and waterways. There are no ports or rail systems located 20 within 6 mi (9.6 km) of the Turkey Point site. The nearest rail line, provided by 21 CSX Corporation, is located approximately 10 mi (16 km) west of the Turkey Point site in 22 Homestead, FL, and the Port of Miami is located approximately 23 mi (37 km) north of the site 23 (CSX 2018). The NRC staffs EIS for the Turkey Point Units 6 and 7 combined license 24 application (NUREG-2176) describes this transportation network in Section 2.5.2.3 25 (NRC 2016a); the NRC staff incorporates pages 2-175 through 2-178 of NUREG-2176 into this 26 SEIS by reference. 27 Access to the Turkey Point site is via East Palm Drive (SW 344 St). East Palm Drive is a 28 four-lane road that turns into a two-lane road at its intersection with Tallahassee Road 29 (SW 137th Avenue) as it leads to the Turkey Point site. East Palm Drive intersects with US-1 30 approximately 8 mi from the Turkey Point Site. East Palm Drive provides access to the 31 Homestead-Miami Speedway and Homestead Bayfront Park. Table 3-24 lists U.S. highways 32 and roads near Turkey Point and their average annual daily traffic (AADT) volumes. The 2017 33 average annual daily reported two-way traffic volume for the monitoring site closest to Turkey 34 Point on East Palm Drive was 9,800 vehicles. 35 Table 3-24 2017 Annual Average Daily Traffic in the Vicinity of Turkey Point Location Mile Marker Average Annual Daily Traffic Palm Drive (SW 344 St.) East of SW 132nd Ave Intersection 2.2 9,800 Intersection of Krome Ave (SW-177) 8.6 23,000 US-1 (South Dixie Highway) South of Palm Drive Intersection 0.3 32,500 S Krome Ave Intersection of Canal Dr (SW 328) 1.7 16,400 Source: FDOT 2017 3-126

1 3.11 Human Health 2 Turkey Point is both an industrial facility and a nuclear power plant. Similar to any industrial 3 facility or nuclear power plant, the operation of Turkey Point Units 3 and 4 over the subsequent 4 license renewal period will produce various human health risks for workers and members of the 5 public. This section describes the human health risks resulting from the operation of Turkey 6 Point Units 3 and 4, including from radiological exposure, chemical hazards, microbiological 7 hazards, electromagnetic fields, and other hazards. 8 3.11.1 Radiological Exposure and Risk 9 Operation of a nuclear power plant involves the use of nuclear fuel to generate electricity. 10 Through the fission process, the nuclear reactor splits uranium atoms resulting very generally in 11 (1) the production of heat which is then used to produce steam to drive the plants turbines and 12 generate electricity and (2) the creation of radioactive byproducts. As required by NRC 13 regulations at 10 CFR 20.1101, Radiation protection programs, FPL designed a radiation 14 protection program to protect onsite personnel (including employees and contractor employees), 15 visitors, and offsite members of the public from radiation and radioactive material at Turkey 16 Point. 17 The Turkey Point Units 3 and 4 radiation protection program is extensive and includes, but is 18 not limited to, the following: 19

• Organization and Administration (e.g., a radiation protection manager who is responsible 20 for the program and who ensures trained and qualified workers for the program) 21
• Implementing Procedures 22
• ALARA (as-low-as-is-reasonably-achievable) Program to minimize dose to workers and 23 members of the public 24
• Dosimetry Program (i.e., measure radiation dose of plant workers) 25
• Radiological Controls (e.g., protective clothing, shielding, filters, respiratory equipment, 26 and individual work permits with specific radiological requirements) 27
• Radiation Area Entry and Exit Controls (e.g., locked or barricaded doors, interlocks, local 28 and remote alarms, personnel contamination monitoring stations) 29
• Posting of Radiation Hazards (i.e., signs and notices alerting plant personnel of potential 30 hazards) 31
• Recordkeeping and Reporting (e.g., documentation of worker dose and radiation survey 32 data) 33
• Radiation Safety Training (e.g., classroom training and use of mockups to simulate 34 complex work assignments) 35
• Radioactive Effluent Monitoring Management (i.e., controlling and monitoring radioactive 36 liquid and gaseous effluents released into the environment) 37
• Radioactive Environmental Monitoring (e.g., sampling and analysis of environmental 38 media, such as direct radiation, air, water, groundwater, broad leaf vegetation, fish, 3-127

1 shellfish, and sediment to measure the levels of radioactive material in the environment 2 that may impact human health) 3

• Radiological Waste Management (i.e., controlling, monitoring, processing, and disposing 4 of radioactive solid waste) 5 Regarding radiation exposure to Turkey Point Units 3 and 4 personnel, the NRC staff reviewed 6 the data contained in NUREG-0713, Volume 38, Occupational Radiation Exposure at 7 Commercial Nuclear Power Reactors and other Facilities 2016: Forty-Ninth Annual Report 8 (NRC 2018h). The forty-ninth annual report was the most recent annual report available at the 9 time of this environmental review. It summarizes the NRCs Radiation Exposure Information 10 and Reporting System databases occupational exposure data through 2016. Nuclear power 11 plants are required by 10 CFR 20.2206, Reports of individual monitoring, to report their 12 occupational exposure data to the NRC annually. Chapter 4, Environmental Consequences 13 and Mitigating Actions, in this SEIS includes further discussion of radiological doses associated 14 with the Turkey Point Units 3 and 4 subsequent license renewal.

15 NUREG-0713 calculates a 3-year average collective dose per reactor for workers at all nuclear 16 power reactors licensed by the NRC. The 3-year average collective dose is one of the metrics 17 that the NRC uses in the Reactor Oversight Program to evaluate the applicants ALARA 18 program. Collective dose is the sum of the individual doses received by workers at a facility 19 licensed to use radioactive material over a 1-year time period. There are no NRC or EPA 20 standards for collective dose. Based on the data for operating pressurized-water reactors like 21 the ones at Turkey Point Units 3 and 4, the average annual collective dose per reactor was 22 42 person-rem. In comparison, Turkey Point Units 3 and 4 had a reported annual collective 23 dose per reactor of 45 person-rem. 24 In addition, as reported in NUREG-0713, for 2016, no worker at Turkey Point Units 3 and 4 25 received an annual dose greater than 0.75 rem (0.0075 sievert (Sv)), which is much less than 26 the NRC occupational dose limit of 5.0 rem (0.05 Sv) in 10 CFR 20.1201, Occupational dose 27 limits for adults. 28 Offsite dose to members of the public is discussed in Section 3.1.4, Radioactive Waste 29 Management Systems, of this SEIS. 30 3.11.2 Chemical Hazards 31 State and Federal environmental agencies regulate the use, storage, and discharge of 32 chemicals, biocides, and sanitary wastes. Such environmental agencies also regulate how 33 facilities like Turkey Point manage minor chemical spills. Chemical and hazardous wastes can 34 potentially impact workers, members of the public, and the environment. 35 FPL currently controls the use, storage, and discharge of chemicals and sanitary wastes at 36 Turkey Point Units 3 and 4 in accordance with its chemical control procedures, waste-37 management procedures, and Turkey Point site-specific chemical spill prevention plans. FPL 38 monitors and controls discharges of chemical and sanitary wastes through Turkey Point Unit 3 39 and 4s National Pollutant Discharge Elimination System permit process. These plant 40 procedures, plans, and processes are designed to prevent and minimize the potential for a 41 chemical or hazardous waste release and, in the event of such a release, minimize impact to 42 workers, members of the public, and the environment (FPL 2018f). 3-128

1 3.11.3 Microbiological Hazards 2 Nuclear power plants that discharge thermal effluents to cooling ponds, lakes, canals, or rivers 3 have the potential to promote the increased growth of thermophilic microorganisms, which could 4 result in adverse health effects for plant workers and the public. Microorganisms of particular 5 concern include several types of bacteria (Legionella spp., Salmonella spp., Shigella spp., and 6 Pseudomonas aeruginosa) and the free-living amoeba Naegleria fowleri, all of which require 7 freshwater environments. Because Turkey Point withdraws from and discharges to the CCS, 8 which is a saline environment, the above freshwater microorganisms are not a concern at 9 Turkey Point, and this SEIS provides no further discussion of them. Section 3.9.3.1 of the 10 license renewal GEIS (NUREG-1437) (NRC 2013a) provides additional background information 11 on these microorganisms. 12 3.11.4 Electromagnetic Fields 13 Based on its evaluation in the license renewal GEIS (NUREG-1437), the NRC has not found 14 electric shock resulting from direct access to energized conductors or from induced charges in 15 metallic structures to be a problem at most operating plants. Generally, the NRC staff also does 16 not expect electric shock from such sources to be a human health hazard during the 17 subsequent license renewal period. However, a site-specific review is required to determine the 18 significance of the electric shock potential along the portions of the transmission lines that are 19 within the scope of this SEIS. Transmission lines that are within the scope of the NRCs 20 subsequent license renewal environmental review are limited to: (1) those transmission lines 21 that connect the nuclear plant to the substation where electricity is fed into the regional 22 distribution system and (2) those transmission lines that supply power to the nuclear plant from 23 the grid (NRC 2013a). 24 As discussed in Section 3.1.6.5, Power Transmission Systems, of this SEIS, the only 25 transmission lines that are in scope for Turkey Point subsequent license renewal are onsite. 26 Specifically, these onsite, in-scope transmission lines are approximately 590 feet (180 m) and 27 connect Units 3 and 4 to the onsite 230-kV switchyard (FPL 2018f). Therefore, there is no 28 potential shock hazard to offsite members of the public from these onsite transmission lines. As 29 discussed in Section 3.11.5, Other Hazards, of this SEIS, Turkey Point maintains an 30 occupational safety program, which includes protection from acute electrical shock, and is in 31 accordance with Occupational Safety and Health Administration regulations. 32 3.11.5 Other Hazards 33 This section addresses two additional human health hazards: (1) physical occupational hazards 34 and (2) occupational electric shock hazards. 35 Nuclear power plants are industrial facilities that have many of the typical occupational hazards 36 found at any other electric power generation utility. Nuclear power plant workers may perform 37 electrical work, electric power line maintenance, repair work, and maintenance activities and 38 may be exposed to some potentially hazardous physical conditions (e.g., falls, excessive heat, 39 cold, noise, electric shock, and pressure). 40 The Occupational Safety and Health Administration (OSHA) is responsible for developing and 41 enforcing workplace safety regulations. Congress created OSHA by enacting the Occupational 42 Safety and Health Act of 1970, as amended (29 U.S.C. 651 et seq.) to safeguard the health of 43 workers. With specific regard to nuclear power plants, plant conditions that result in an 3-129

1 occupational risk, but do not affect the safety of licensed radioactive materials, are under the 2 statutory authority of OSHA rather than the NRC as set forth in a memorandum of 3 understanding (NRC 2013f) between the NRC and OSHA. Occupational hazards are reduced 4 when workers adhere to safety standards and use appropriate protective equipment; however, 5 fatalities and injuries from accidents may still occur. Turkey Point Units 3 and 4 maintain an 6 occupational safety program for its workers in accordance with OSHA regulations (FPL 2018f). 7 3.12 Environmental Justice 8 Under Executive Order (EO) 12898, Federal Actions to Address Environmental Justice in 9 Minority Populations and Low-Income Populations (59 FR 7629), Federal agencies are 10 responsible for identifying and addressing, as appropriate, disproportionately high and adverse 11 human health and environmental impacts on minority and low-income populations. Independent 12 agencies, such as the NRC, are not bound by the terms of EO 12898 but are, as stated in 13 paragraph 6-604 of the executive order, requested to comply with the provisions of [the] order. 14 In 2004, the Commission issued the agencys Policy Statement on the Treatment of 15 Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040), which 16 states, The Commission is committed to the general goals set forth in [EO] 12898, and strives 17 to meet those goals as part of its NEPA review process." 18 The Council on Environmental Quality (CEQ) provides the following information in its publication 19 Environmental Justice: Guidance Under the National Environmental Policy Act (CEQ 1997): 20 Disproportionately High and Adverse Human Health Effects. 21 Adverse health effects are measured in risks and rates that could result in latent 22 cancer fatalities, as well as other fatal or nonfatal adverse impacts on human 23 health. Adverse health effects may include bodily impairment, infirmity, illness, or 24 death. Disproportionately high and adverse human health effects occur when the 25 risk or rate of exposure to an environmental hazard for a minority or low-income 26 population is significant (as employed by NEPA) and appreciably exceeds the 27 risk or exposure rate for the general population or for another appropriate 28 comparison group (CEQ 1997). 29 Disproportionately High and Adverse Environmental Effects. 30 A disproportionately high environmental impact that is significant (as employed 31 by NEPA) refers to an impact or risk of an impact on the natural or physical 32 environment in a low-income or minority community that appreciably exceeds the 33 environmental impact on the larger community. Such effects may include 34 ecological, cultural, human health, economic, or social impacts. An adverse 35 environmental impact is an impact that is determined to be both harmful and 36 significant (as employed by NEPA). In assessing cultural and aesthetic 37 environmental impacts, impacts that uniquely affect geographically dislocated or 38 dispersed minority or low-income populations or American Indian tribes are 39 considered (CEQ 1997). 40 This environmental justice analysis assesses the potential for disproportionately high and 41 adverse human health or environmental effects on minority and low-income populations that 42 could result from the operation of Turkey Point Units 3 and 4 during the subsequent license 43 renewal period of extended operation. In assessing the impacts, the NRC staff used the 3-130

1 following definitions of minority individuals, minority populations, and low-income population 2 (CEQ 1997): 3 Minority Individuals 4 Individuals who identify themselves as members of the following population 5 groups: Hispanic or Latino, American Indian or Alaskan Native, Asian, Black or 6 African American, Native Hawaiian or Other Pacific Islander, or two or more 7 races, meaning individuals who identified themselves on a Census form as being 8 a member of two or more races, for example, White and Asian. In other words, 9 everyone except persons who identified themselves as White, Not Hispanic or 10 Latino are considered minority. 11 Minority Populations 12 Minority populations are identified when (1) the minority population of an affected 13 area exceeds 50 percent or (2) the minority population percentage of the affected 14 area is meaningfully greater than the minority population percentage in the 15 general population or other appropriate unit of geographic analysis. 16 Low-income Population 17 Low-income populations in an affected area are identified with the annual 18 statistical poverty thresholds from the Census Bureaus Current Population 19 Reports, Series P60, on Income and Poverty. 20 In determining the location of minority and/or low-income populations, the geographic 21 area used to perform a comparative analysis is a 50-mi (80-km) radius from the facility. 22 The 50-mi (80-km) radius is consistent with the impact analysis conducted for human 23 health impacts. The percentage of minority and/or low-income populations in the 50-mi 24 geographic area is compared to the percentage of minority and/or low-income 25 populations in each census block group to determine which block groups exceeds the 26 percentage, thereby identifying the location of these populations (NRC 2013c). 27 Minority Population 28 According to the Census Bureaus 2010 Census data, there are a total 2,152 block groups, and 29 approximately 78 percent of the population residing within a 50-mi (80-km) radius of Turkey 30 Point identified themselves as minority individuals (USCB 2010b). The largest minority 31 populations were Hispanic or Latino of any race (approximately 55 percent) followed by Black or 32 African American (approximately 19 percent). 33 According to the Council on Environmental Quality guidance, a minority population exists if the 34 percentage of the minority population of an area (e.g., census block group) exceeds 50 percent 35 or is meaningfully greater than the minority population percentage in the general population. In 36 this SEIS, the NRC staffs environmental justice analysis applied the meaningfully greater 37 threshold in identifying higher concentrations of minority populations. The meaningfully greater 38 threshold is any percentage greater than the minority population within the 50-mi radius. 39 Therefore, for the purposes of identifying higher concentrations of minority populations, census 40 block groups within the 50-mi (80-km) radius of Turkey Point were identified as minority 41 population block groups if the percentage of the minority population in the block group exceeded 3-131

1 78 percent, which is the percent of the minority population within the 50-mi (80-km) radius of 2 Turkey Point. 3 As shown in Figure 3-23, minority population block groups are notable and located throughout 4 the 50-mi (80-km) radius of Turkey Point. Based on this analysis, there are 1,247 minority 5 population block groups (using the meaningfully greater threshold of 78 percent minority 6 population) within the 50-mi (80-km) radius of Turkey Point and minority population block groups 7 are clustered around the cities of Miami, Miramar, Miami-Gardens, Hialeah, Homestead, Florida 8 City, and the Everglades census county subdivision. Turkey Point is located in a minority 9 population block group. 10 As presented in Section 3.10, Socioeconomics, of this SEIS, in 2010, the minority population 11 in Miami-Dade County was approximately 85 percent and the minority population in the State of 12 Florida was approximately 42 percent. According to the Census Bureaus 2016 American 13 Community Survey 1-Year Estimates, since 2010, minority populations in Miami-Dade County 14 have increased by approximately 232,000 persons. The largest increases occurred in the 15 Hispanic or Latino population (nearly 212,000 person increases since 2010, an increase of 16 approximately 13 percent). 17 Low-Income Population 18 The Census Bureaus 2012-2016 American Community Survey data identify approximately 19 18 percent of individuals residing within a 50-mi (80-km) radius of Turkey Point as living below 20 the Federal poverty threshold (USCB 2016f). The 2016 Federal poverty threshold was $24,563 21 for a family of four (USCB 2016g). 22 Figure 3-24 shows the location of predominantly low-income population block groups within a 23 50-mi (80-km) radius of Turkey Point. In accordance with NRC guidance (NRC 2013a), census 24 block groups were considered low-income population block groups if the percentage of 25 individuals living below the Federal poverty threshold within the block group exceeded 26 18 percent, which is the percent of the individuals living below the Federal poverty threshold 27 within the 50-mi (80-km) radius of Turkey Point. 28 As shown in Figure 3-24, low income population block groups are clustered in the cities of 29 Miami, Hialeah, and Fort Lauderdale, and in the Everglades and Homestead census county 30 subdivisions. Based on this analysis, there are 1,010 low-income population block groups 31 (approximately 50 percent of the block groups within 50 mi (80 km) of Turkey Point) and Turkey 32 Point is located in a low-income population block group. 33 As presented in Table 3-15, people living in Miami-Dade County (the socioeconomic region of 34 influence) have lower median household and per capita incomes than average for the State of 35 Florida and a higher percentage of families and people living below the poverty level. 3-132

1 Source: USCB 2010b 2 Figure 3-23 2010 CensusMinority Block Groups Within a 50-mi (80-km) Radius of 3 Turkey Point 3-133

1 Source: USCB 2016f 2 Figure 3-24 2012-2016, American Community Survey 5-Year EstimatesLow-Income 3 Block Groups Within a 50-mi (80-km) Radius of Turkey Point 3-134

1 3.13 Waste Management and Pollution Prevention 2 Like any operating nuclear power plant, Turkey Point Units 3 and 4 will produce both radioactive 3 and nonradioactive waste during the subsequent license renewal period. This section describes 4 waste management and pollution prevention at Turkey Point. 5 3.13.1 Radioactive Waste 6 As discussed in Section 3.1.4, Radioactive Waste Management Systems, of this SEIS, Turkey 7 Point uses liquid, gaseous, and solid waste processing systems to collect and treat, as needed, 8 radioactive materials produced as a byproduct of plant operations. Radioactive materials in 9 liquid and gaseous effluents are reduced prior to being released into the environment so that the 10 resultant dose to members of the public from these effluents is well within NRC and EPA dose 11 standards. Radionuclides that can be efficiently removed from the liquid and gaseous effluents 12 prior to release are converted to a solid waste form for disposal in a licensed disposal facility. 13 3.13.2 Nonradioactive Waste 14 Waste minimization and pollution prevention are important elements of operations at all nuclear 15 power plants. Licensees are required to consider pollution prevention measures as dictated by 16 the Pollution Prevention Act (Public Law 101-508) and the Resource Conservation and 17 Recovery Act of 1976, as amended (Public Law 94-580) (NRC 2013a). 18 As described in Section 3.1.5, Nonradioactive Waste Management System, Turkey Point has 19 a nonradioactive waste management program to handle nonradioactive waste in accordance 20 with Federal, State, and corporate regulations and procedures. Turkey Point maintains a waste 21 minimization program that uses material control, process control, waste management, recycling, 22 and feedback to reduce waste. 23 Turkey Point has a Stormwater Pollution Prevention Plan that identifies potential sources of 24 pollution that may affect the quality of stormwater discharges from permitted outfalls. The 25 Stormwater Pollution Prevention Plan also describes best management practices for reducing 26 pollutants in stormwater discharges and assure compliance with the sites Florida Department of 27 Environmental Protection permit. 28 Turkey Point also has a Spill Prevention, Control, and Countermeasure (SPCC) plan (see FPLs 29 environmental report for subsequent license renewal, Section 9.5.3.6) to monitor areas within 30 the site that have the potential to discharge oil into or upon navigable waters, in accordance with 31 the regulations in 40 CFR Part 112, Oil Pollution Prevention. The SPCC plan identifies and 32 describes the procedures, materials, equipment, and facilities that FPL uses to minimize the 33 frequency and severity of oil spills at Turkey Point. 34 Turkey Point is subject to EPA reporting requirements in 40 CFR Part 110, Discharge of Oil, 35 pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Under these 36 regulations, FPL must report to the National Response Center any discharges of oil if the 37 quantity may be harmful to the public health or welfare or to the environment. From 2012 38 through 2016, FPL reported no oil discharges that triggered the EPAs reporting requirements in 39 40 CFR Part 110. 40 Turkey Point is also subject to the reporting provisions of the Florida Administrative Code (FAC) 41 at 62-780.210, Contamination Reporting, concerning the discovery of petroleum or petroleum 3-135

1 products contamination or a discharge of petroleum or petroleum products, as well as other 2 FAC reporting requirements. Thus, the NRC staff expects that petroleum and petroleum 3 product spills would be reported to the appropriate regulatory authority. 4 The NRC staff issued two requests for additional information to FPL regarding reportable spills 5 at Turkey Point. In the first request, the NRC staff asked FPL to provide additional information 6 to the NRC as to whether there have been any reportable spills (discharge of oil) that may be 7 harmful, pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act, that occurred 8 after FPL wrote and submitted its environmental report for the subsequent license renewal 9 application. In its August 2018 response (FPL 2018b, NRC RAI Number: WM-1), FPL stated 10 that based on the listing of calls received by the U.S. Coast Guard National Response Center, 11 there have been no reportable spills triggering the 40 CFR Part 110 notification requirement at 12 Turkey Point since the ER was written (USCG 2018). 13 In its second request for additional information on reportable spills, the NRC staff asked FPL to 14 provide additional information to the NRC as to whether, after the environmental report was 15 written, there have been any reportable spills (discharge of oil) at Turkey Point that may have 16 had the potential to significantly pollute surface waters or groundwater and which were not 17 confined to a building or similar structure. FPL stated in its August 2018 response (FPL 2018g, 18 NRC RAI Number: WM-2) that there have been no reportable spills since the ER was 19 submitted. 3-136

1 4 ENVIRONMENTAL CONSEQUENCES AND 2 MITIGATING ACTIONS 3 4.1 Introduction 4 In this chapter, the U.S. Nuclear Regulatory Commission (NRC) staff evaluates the 5 environmental consequences of issuing subsequent renewed licenses authorizing an additional 6 20 years of operation for Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point, or 7 Turkey Point Units 3 and 4). The NRC staffs evaluation of environmental consequences 8 includes the following: 9 1) impacts associated with continued operations similar to those impacts that have 10 occurred during the current renewed license term 11 2) impacts of various alternatives to the proposed action, including a no-action 12 alternative (not issuing the subsequent renewed licenses) and replacement power 13 alternatives (new nuclear; natural gas combined-cycle; and a combination of natural 14 gas and solar power) 15 3) impacts from the termination of nuclear power plant operations and decommissioning 16 after the subsequent license renewal term (with emphasis on the incremental effect 17 caused by an additional 20 years of reactor operation) 18 4) impacts associated with the uranium fuel cycle 19 5) impacts of postulated accidents (design-basis accidents and severe accidents) 20 6) cumulative impacts of the proposed action of issuing subsequent renewed licenses 21 for Turkey Point 22 7) resource commitments associated with the proposed action, including unavoidable 23 adverse impacts, the relationship between short-term use and long-term productivity, 24 and irreversible and irretrievable commitment of resources 25 8) new and potentially significant information on environmental issues related to the 26 impacts of operation during the subsequent license renewal term 27 In this chapter, the NRC staff also compares the environmental impacts of subsequent license 28 renewal with the environmental impacts of the no-action alternative and replacement power 29 alternatives to determine whether the adverse environmental impacts of subsequent license 30 renewal are so great that it would be unreasonable to preserve the option of subsequent license 31 renewal for energy-planning decisionmakers. Chapter 2, Alternatives Including the Proposed 32 Action, of this supplemental environmental impact statement (SEIS) describes in detail the 33 attributes of the proposed action (subsequent license renewal of Turkey Point) and the 34 no-action alternative. Chapter 2, Section 2.2.2, Replacement Power Alternatives, further 35 describes the NRC staffs process for developing a range of reasonable alternatives to the 36 proposed action and the replacement power alternatives that the staff selected for detailed 37 analysis in this chapter, including supporting assumptions and data. As noted in Chapter 2, 38 Table 2.1, the site location for various replacement power alternatives would be adjacent to 39 Turkey Point Units 3 and 4. Chapter 2, Table 2.2, summarizes the environmental impacts of the 40 proposed action and alternatives to the proposed action. 41 The affected environment (i.e., environmental baseline) for each resource area considered, and 42 against which the potential environmental impacts of the alternatives are measured, is 4-1

1 described in Chapter 3, Affected Environment. As documented in Chapter 3, the effects of 2 ongoing reactor operations at Turkey Point have become well established as environmental 3 conditions have adjusted to and reflect the presence of the nuclear power plant. 4 This SEIS documents the NRC staffs environmental review of the Turkey Point subsequent 5 license renewal application and supplements the information in NUREG-1437, Generic 6 Environmental Impact Statement for License Renewal of Nuclear Plants (also known as the 7 2013 GEIS) (NRC 2013a). The 2013 GEIS identifies 78 issues (divided into Category 1 and 8 Category 2 issues) to be evaluated for the proposed action in the environmental review process. 9 Section 1.4, Generic Environmental Impact Statement, of this SEIS provides an explanation of 10 the criteria for Category 1 issues (i.e., those issues generic to all nuclear power plants or a 11 distinct subset of plants) and Category 2 issues (i.e., those issues specific to individual nuclear 12 power plants) as well as the definitions of SMALL, MODERATE, and LARGE impact 13 significance. 14 For Category 1 issues, the NRC staff can rely on the analysis in the GEIS unless otherwise 15 noted. Table 4-1 lists the Category 1 (generic) issues that apply to Turkey Point during the 16 proposed subsequent license renewal period. For each Category 1 issue, the NRC staff 17 considered whether there is any new and significant information that might alter the conclusions 18 reached in the GEIS for that issue. As discussed in Section 4.14 of this SEIS, Regulatory Guide 19 (RG) 4.2, Supplement 1, Preparation of Environmental Reports for Nuclear Power Plant 20 License Renewal Applications (NRC 2013b), defines new and significant information as 21 (1) information that identifies a significant environmental impact issue that was not considered 22 or addressed in the GEIS and, consequently, not codified in Table B-1, in Appendix B to 23 Subpart A of 10 CFR Part 51, or (2) information not considered in the assessment of impacts 24 evaluated in the GEIS leading to a seriously different picture of the environmental 25 consequences of the action than previously considered, such as an environmental impact 26 finding different from that codified in Table B-1. For most issues, the NRC staff did not identify 27 any new and significant information during its review of Florida Power & Light Companys 28 (FPLs) environmental report, the site audits, or the scoping period that would change the 29 conclusions in the GEIS. Therefore, there are no impacts related to those Category 1 issues 30 beyond those already discussed in the GEIS. The staffs process for evaluating new and 31 significant information is described in Section 4.14, Evaluation of New and Significant 32 Information. 33 The NRC staff identified and evaluated new information for two existing Category 1 issues 34 (i.e., groundwater quality degradation (plants with cooling ponds in salt marshes) and cooling 35 system impacts on terrestrial resources (plants with once-through cooling systems or cooling 36 ponds)) and identified one new issue (i.e., water quality impacts on adjacent water bodies 37 (plants with cooling ponds in salt marshes)). The NRC staffs evaluation of these three issues is 38 presented in Sections 4.5.1.1, 4.5.1.2, and 4.6.1 of this SEIS. 39 Table 4-1 Applicable Category 1 (Generic) Issues for Turkey Point GEIS Issue Section Impact Land Use Onsite land use 4.2.1.1 SMALL Offsite land use 4.2.1.1 SMALL 4-2

GEIS Issue Section Impact Visual Resources Aesthetic impacts 4.2.1.2 SMALL Air Quality Air quality impacts (all plants) 4.3.1.1 SMALL Air quality effects of transmission lines 4.3.1.1 SMALL Noise Noise impacts 4.3.1.2 SMALL Geologic Environment Geology and soils 4.4.1 SMALL Surface Water Resources Surface water use and quality (non-cooling system impacts) 4.5.1.1 SMALL Discharge of metals in cooling system effluent 4.5.1.1 SMALL Discharge of biocides, sanitary wastes, and minor chemical spills 4.5.1.1 SMALL Effects of dredging on surface water quality 4.5.1.1 SMALL Groundwater Resources Groundwater contamination and use (non-cooling system impacts) 4.5.1.2 SMALL Groundwater quality degradation resulting from water withdrawals 4.5.1.2 SMALL Groundwater quality degradation (plants with cooling ponds in salt 4.5.1.2 SMALL(b) marshes)(a) Terrestrial Resources Exposure of terrestrial organisms to radionuclides 4.6.1.1 SMALL Cooling system impacts on terrestrial resources (plants with once- 4.6.1.1 SMALL through cooling systems or cooling ponds)(a) Bird collisions with plant structures and transmission lines 4.6.1.1 SMALL Transmission line right-of-way management impacts on terrestrial 4.6.1.1 SMALL resources(c) Electromagnetic fields on flora and fauna (plants, agricultural crops, 4.6.1.1 SMALL honeybees, wildlife, livestock) Aquatic Resources Entrainment of phytoplankton and zooplankton (all plants) 4.6.1.2 SMALL Infrequently reported thermal impacts (all plants) 4.6.1.2 SMALL Effects of cooling water discharge on dissolved oxygen, gas 4.6.1.2 SMALL supersaturation, and eutrophication Effects of non-radiological contaminants on aquatic organisms 4.6.1.2 SMALL Exposure of aquatic organisms to radionuclides 4.6.1.2 SMALL Effects of dredging on aquatic resources 4.6.1.2 SMALL Effects on aquatic resources (non-cooling system impacts) 4.6.1.2 SMALL Impacts of transmission line right-of-way management on aquatic 4.6.1.2 SMALL resources(c) Losses from predation, parasitism, and disease among organisms 4.6.1.2 SMALL exposed to sublethal stresses Socioeconomics Employment and income, recreation and tourism 4.8.1.1 SMALL Tax revenues 4.8.1.2 SMALL 4-3

GEIS Issue Section Impact Community services and education 4.8.1.3 SMALL Population and housing 4.8.1.4 SMALL Transportation 4.8.1.5 SMALL Human Health Radiation exposures to the public 4.9.1.1.1 SMALL Radiation exposures to plant workers 4.9.1.1.1 SMALL Human health impact from chemicals 4.9.1.1.2 SMALL Microbiological hazards to plant workers 4.9.1.1.3 SMALL Physical occupational hazards 4.9.4.1.5 SMALL Postulated accidents Design-basis accidents 4.9.1.2 SMALL Waste Management Low-level waste storage and disposal 4.11.1.1 SMALL Onsite storage of spent nuclear fuel 4.11.1.2 SMALL Offsite radiological impacts of spent nuclear fuel and high-level 4.11.1.3 (d) waste disposal Mixed-waste storage and disposal 4.11.1.4 SMALL Nonradioactive waste storage and disposal 4.11.1.4 SMALL Uranium Fuel Cycle Offsite radiological impactsindividual impacts from other than the 4.12.1.1 SMALL disposal of spent fuel and high-level waste Offsite radiological impactscollective impacts from other than the 4.12.1.1 (e) disposal of spent fuel and high-level waste Nonradiological impacts of the uranium fuel cycle 4.12.1.1 SMALL Transportation 4.12.1.1 SMALL Termination of Nuclear Power Plant Operations and Decommissioning Termination of plant operations and decommissioning 4.12.2.1 SMALL 4-4

GEIS Issue Section Impact (a) The environmental impact of this issue includes consideration of site-specific new information for Turkey Point. (b) The NRC staff recognizes that the current impacts on this issue are greater than SMALL (i.e., the impacts are MODERATE). However, as discussed in Section 4.5.1.2 of this chapter, in response to a 2015 consent agreement with the Miami-Dade County Department of Environmental Resource Management (DERM) (MDC 2015a) and a 2016 consent order from the Florida Department of Environmental Protection (FDEP) (FDEP 2016e), FPL has implemented a recovery well system to halt and retract the hypersaline plume and to abate and remediate the effects of the hypersaline plume from the cooling canal system. These efforts are expected to remediate the hypersaline plume prior to the commencement of the subsequent license renewal term. In addition, FPLs actions to remediate the plume are subject to continued regulatory oversight by the DERM and the FDEP. Therefore, the NRC staff expects that groundwater quality degradation impacts resulting from subsequent license renewal will be SMALL. (c) This issue applies only to the in-scope portion of electric power transmission lines, which are defined as transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional power distribution system and transmission lines that supply power to the nuclear plant from the grid. (d) The environmental impact of this issue for the time frame beyond the licensed life for reactor operations is contained in NUREG-2157, the NRCs Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel (NRC 2014c). (e) There are no regulatory limits applicable to collective doses to the general public from fuel-cycle facilities. The practice of estimating health effects on the basis of collective doses may not be meaningful. All fuel-cycle facilities are designed and operated to meet the applicable regulatory limits and standards. The Commission concludes that the collective impacts are acceptable. The Commission concludes that the impacts would not be sufficiently large to require the National Environmental Policy Act (NEPA) conclusion, for any plant, that the option of extended operation under Title 10 of the Code of Federal Regulations (10 CFR) Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, should be eliminated. Accordingly, while the Commission has not assigned a single level of significance for the collective impacts of the uranium fuel cycle, this issue is considered Category 1. Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 and NRC 2013a 1 The NRC staff analyzed the Category 2 (site-specific) issues applicable to Turkey Point during 2 the proposed subsequent license renewal period and assigned impacts to these issues as 3 shown below in Table 4-2. 4 Table 4-2 Applicable Category 2 (Site-Specific) Issues for Turkey Point Issue GEIS Section Impact(a) Groundwater Resources Groundwater use conflicts (plants that withdraw more than 4.5.1.2 SMALL to MODERATE 100 gallons per minute (gpm)) Radionuclides released to groundwater 4.5.1.2 SMALL Terrestrial Resources Effects on terrestrial resources (non-cooling system impacts) 4.6.1.1 SMALL Aquatic Resources Impingement and entrainment of aquatic organisms (plants 4.6.1.2 SMALL to with once-through cooling systems or cooling ponds) MODERATE(b) 4-5

Issue GEIS Section Impact(a) Thermal impacts on aquatic organisms (plants with 4.6.1.2 SMALL to once-through cooling systems or cooling ponds) MODERATE(b) Special Status Species and Habitats Threatened, endangered, and protected species and 4.6.1.3 Impact determinations essential fish habitat vary by species and habitat(c) Historic and Cultural Resources Historic and cultural resources 4.7.1 would not adversely affect known historic properties or historic and cultural resources Human Health Chronic effects of electromagnetic fields(d) 4.9.1.1.1 Uncertain Impact Electric shock hazards 4.9.1.1.1 SMALL Postulated Accidents Severe accidents 4.9.1.2 SMALL Environmental Justice 4.10.1 no disproportionately Minority and low-income populations high and adverse human health and environmental effects Cumulative Impacts Cumulative impacts 4.13 See SEIS Section 4.16 (a) Impact determinations for Category 2 issues are based on findings described in Sections 4.2 through 4.13 of this SEIS for the proposed action. (b) The conclusion of SMALL to MODERATE applies to aquatic resources in the cooling canal system. Aquatic organisms inhabiting Biscayne Bay and connected waterbodies (e.g., Card Sound, the Atlantic Ocean) are not subject to impingement and entrainment because they do not interact with the Turkey Point intake structure, and there are no thermal effects outside the cooling canal system because there are no surface water connections that allow flow between the waters of Biscayne Bay and the cooling canal system. (c) The NRC staff concludes that Turkey Point subsequent license renewal is likely to adversely affect the American crocodile and the eastern indigo snake, and may result in adverse modification to designated critical habitat of the American crocodile. The proposed action may affect, but is not likely to adversely affect, the Florida bonneted bat, Florida panther, West Indian manatee, red knot, piping plover, wood stork, Everglades snail kite, Kirtlands warbler, Blodgetts silverbush, Cape Sable thoroughwort, Florida semaphore cactus, sand flax, Florida bristle fern, loggerhead sea turtle, green sea turtle, leatherback sea turtle, hawksbill sea turtle, and smalltooth sawfish. The proposed action would result in no adverse modification to designated critical habitat of the West Indian manatee. The proposed action would have no adverse effects on Essential Fish Habitat. The NRC staffs evaluation of impacts to species and habitats under the U.S. Fish and Wildlife Services jurisdiction can be found in the NRCs Biological Assessment (NRC 2018n). The evaluation of impacts to species and habitats under the National Marine Fisheries Services jurisdiction can be found in Section 4.8 of this SEIS. (d) This issue was not designated as Category 1 or Category 2 and is discussed in Section 4.11.1, Proposed Action. Source: Table B-1 in Appendix B, Subpart A, to 10 CFR Part 51 and NRC 2013a 4-6

1 4.2 Land Use and Visual Resources 2 This section describes the potential land use and visual resources impacts of the proposed 3 action (subsequent license renewal) and alternatives to the proposed action. 4 4.2.1 Proposed Action 5 According to the GEIS (NRC 1996 and NRC 2013a), land use and visual resources would not 6 be affected by continued operations and refurbishment associated with license renewal. In 7 addition, nuclear plant operations at Turkey Point have not changed appreciably with time, and 8 no change in land use and visual resources impacts are expected during the subsequent 9 license renewal term. The NRC staff identified no new or significant information for these 10 issues. 11 In this regard, no new or significant information was identified during the review of FPLs 12 environmental report, the NRC staffs site visit, the scoping process, or the evaluation of other 13 available information. The communities in the vicinity of Turkey Point have pre-established 14 patterns of development and have adequate public services to support and guide development. 15 Consequently, people living in the vicinity of Turkey Point would not experience any land use or 16 visual changes during the subsequent license renewal term beyond what has already been 17 experienced. In addition, no adverse effects on offsite land use will occur related to the 18 Everglades Restoration Project (conducted under the Comprehensive Everglades Restoration 19 Plan (CERP)) or other Federal action in the proposed project area. Therefore, the land use and 20 visual impacts of continued reactor operations during the subsequent license renewal term 21 would not exceed the land use and visual impacts predicted in the GEIS. For these issues, the 22 GEIS predicted that the impacts would be SMALL for all nuclear plants. 23 As identified in Table 4-1, the impacts of all generic land use or visual resource issues would be 24 SMALL. Table 4-2 does not identify any site-specific (Category 2) land use or visual resource 25 issues. 26 4.2.2 No-Action Alternative 27 4.2.2.1 Land Use 28 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 29 Turkey Point Units 3 and 4 would shut down on or before the expiration of the current renewed 30 operating licenses (i.e., 2032 and 2033). Under this alternative, land uses would remain similar 31 to those that would occur under the proposed subsequent license renewal except that land 32 could be converted to other uses sooner if Turkey Point is shut down in 2032 and 2033 instead 33 of operating for an additional 20 years. Shutdown of Turkey Point under the no-action 34 alternative thus would not affect onsite land use. Plant structures and other facilities would 35 remain in place until decommissioning. Most transmission lines would remain in service after 36 the plant stops operating. Maintenance of most existing infrastructure would continue as before. 37 Therefore, land use impacts from the termination of Turkey Point Unit Nos. 3 and 4 nuclear 38 plant operations would be SMALL. 39 4.2.2.2 Visual Resources 40 Shutdown of Turkey Point under the no-action alternative would not significantly change the 41 visual appearance of the Turkey Point site. At the Turkey Point site, the reactor and turbine 4-7

1 buildings are the buildings that create the largest visual impact. Under the no-action alternative, 2 the reactor and turbine buildings would likely remain in place for some time but would eventually 3 be dismantled. This would reduce the visual impact. Overall, visual impacts from the 4 termination of Turkey Point Unit Nos. 3 and 4 nuclear plant operations would be SMALL. 5 4.2.3 Replacement Power Alternatives: Common Impacts 6 4.2.3.1 Land Use 7 The NRC staffs analysis of land use impacts focuses on the amount of land area that would be 8 affected by the construction and operation of a replacement power plant. 9 Construction 10 Construction would require the permanent commitment of land zoned for industrial use at the 11 Turkey Point site for replacement power plants and associated infrastructure. Existing Turkey 12 Point transmission lines and infrastructure would adequately support each of the replacement 13 power alternatives, thus reducing the need for additional land commitments. 14 Operations 15 Operation of new power plants would have no land use impacts beyond land committed for the 16 permanent use of the replacement power plant. Additional land may be required to support 17 power plant operations including land for mining, extraction, and waste disposal activities 18 associated with each alternative. 19 4.2.3.2 Visual Resources 20 The NRC staffs visual impact analysis focuses on the degree of contrast between the 21 replacement power plant and the surrounding landscape and the visibility of the new power 22 plant. 23 Construction 24 Land for any replacement power plant would require clearing, excavation, and the use of 25 construction equipment. Temporary visual impacts may occur during construction from cranes 26 and other construction equipment. 27 Operations 28 Visual impacts during plant operations of any of the replacement power alternatives would be 29 similar in type and magnitude. New cooling towers (if built) and their associated plumes would 30 be the most obvious visual impact and would likely be visible farther from the site than other 31 buildings and infrastructure. New plant stacks may require aircraft warning lights, which would 32 be visible at night. 4-8

1 4.2.4 New Nuclear Alternative 2 4.2.4.1 Land Use 3 Construction 4 Approximately 360 acres (ac) (150 hectares (ha)) of land would be needed to construct a new 5 nuclear power plant. Although there is sufficient land available at the Turkey Point site, some 6 wetlands may be temporarily displaced during construction. Land use impacts during 7 construction would be SMALL at the Turkey Point site since the land is already zoned for 8 industrial use. 9 Operations 10 Offsite land use impacts associated with uranium mining and fuel fabrication needed to support 11 nuclear power plant operations would generally be no different from the amount of land needed 12 to support Turkey Point Units 3 and 4 operations, although more land would be required for 13 mining additional uranium for up to 40 years of operation. Based on this information, onsite and 14 offsite land use impacts from constructing and operating a new nuclear power plant could range 15 from SMALL to MODERATE depending on how much additional land may be needed for 16 uranium mining and fuel fabrication. 17 4.2.4.2 Visual Resources 18 Construction and Operations 19 Visual impacts from a new nuclear alternative would be similar to the common impacts of all 20 replacement power alternatives described in Section 4.2.3.2, Visual Resources. The visual 21 appearance of the power block for the new nuclear power plant would be virtually identical to 22 the existing Turkey Point Units 3 and 4 power blocks. Mechanical draft cooling towers and 23 associated condensate plumes would add to the visual impact. However, the height of the 24 mechanical draft cooling towers would not likely exceed those of other buildings at the Turkey 25 Point site. Therefore, visual impacts during the construction and operation of a new nuclear 26 power plant at the Turkey Point site, including steam plumes that could be visible from great 27 distances, could range from SMALL to MODERATE depending on seasonal weather conditions. 28 4.2.5 Natural Gas Combined-Cycle Alternative 29 4.2.5.1 Land Use 30 Construction 31 The natural gas combined-cycle (NGCC or natural gas) power plant would require 75 ac (30 ha) 32 of land with up to an additional 1,200 ac (490 ha) needed for right-of-way to connect with 33 existing natural gas supply lines located approximately 100 miles (mi) (161 kilometers (km)) 34 north of the Turkey Point site. No new gas wells would be needed to support a natural gas 35 power plant (FPL 2018f). This land use impact would be partially offset by the elimination of 36 land used for uranium mining to supply fuel to Turkey Point Units 3 and 4. Land use impacts 37 caused by uranium mining and natural gas extraction and collection are described in 38 Section 4.15.1, Fuel Cycle. 4-9

1 Constructing the natural gas power plant at the Turkey Point site would make use of available 2 infrastructure. In addition, the land is already zoned for industrial use. However, some natural 3 areas could be converted to industrial use if portions of the new power plant are built outside the 4 existing industrial footprint. Although this use of the land would be noticeable, construction 5 would not likely destabilize adjacent land use, due to the current industrial nature of the Turkey 6 Point site. Accordingly, construction impacts could have SMALL to MODERATE land use 7 impacts. This is primarily due to the amount of non-industrially zoned land that could be 8 affected by this alternative. 9 Operations 10 Operation of a natural gas power plant would not cause any additional land use changes; 11 therefore, land use impacts during operations would be SMALL. Overall land use impacts of the 12 natural gas combined-cycle alternative, including both construction and operation, would 13 therefore range from SMALL to MODERATE. 14 4.2.5.2 Visual Resources 15 Construction and Operations 16 Visual impacts from a natural gas power plant would be similar to the description in 17 Section 4.2.3.2, Visual Resources, for the common impacts from all replacement power 18 alternatives. However, construction and operation of the natural gas power plant would have 19 little to no additional visual impact. The height of the mechanical draft cooling towers would not 20 likely exceed those of other buildings at the Turkey Point site. Therefore, visual impacts during 21 the construction and operation of a new NGCC facility at the Turkey Point site, including steam 22 plumes that could be visible from great distances, could range from SMALL to MODERATE 23 depending on seasonal weather conditions. 24 4.2.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 25 Generation) 26 4.2.6.1 Land Use 27 Construction and Operations 28 The natural gas power plant component of the combination alternative would require somewhat 29 less land than the full-scale natural gas power plant described in Section 4.2.5.1. The natural 30 gas power plant component would require 70 ac (28 ha) of land with up to an additional 31 1,200 ac (490 ha) needed for right-of-way to connect with existing natural gas supply lines 32 located approximately 100 mi (161 km) north of the Turkey Point site. No new gas wells would 33 be needed to support a natural gas power plant (FPL 2018f). Accordingly, land use impacts 34 would be similar to or less than those described for the full-scale natural gas power plant 35 alternative. However, the impacts could still range from SMALL to MODERATE. 36 A utility-scale solar photovoltaic (solar) facility would require approximately 470 ac (190 ha) of 37 cleared land for the three proposed offsite solar power installations (FPL 2018f). Standalone 38 solar facilities cannot be collocated with other land uses (such as grazing and crop-producing 39 agricultural fields). Land use impacts would range from MODERATE to LARGE, depending on 40 the amount and types of land uses that would be affected by construction of the four solar 41 facilities. 4-10

1 Overall land use impacts of this combination natural gas and solar alternative would therefore 2 range from SMALL to LARGE. This is primarily due to the amount and types of land uses that 3 would be affected by the solar facilities. 4 4.2.6.2 Visual Resources 5 Construction and Operations 6 Visual impacts from the combination natural gas and solar alternative would be similar to the 7 common impacts described in Section 4.2.3.2, Visual Resources, for all replacement 8 alternatives. However, construction and operation of the natural gas power plant would have 9 little to no additional visual impact. The height of the mechanical draft cooling towers would 10 likely not exceed those of other buildings at the Turkey Point site. Visual impacts of the natural 11 gas component would be similar to the impacts described in Section 4.2.5.2. 12 The visual impacts of the solar components of this alternative would vary, depending on location 13 and topography. Depending on the location, standalone solar facilities could have a 14 MODERATE to LARGE visual impact. Visual resource impacts of the combination alternative 15 could therefore range from SMALL to LARGE. This range is primarily due to the potential visual 16 impacts from the solar photovoltaic components of this alternative. 17 4.2.7 Cooling Water System Alternative 18 4.2.7.1 Land Use 19 Construction and Operations 20 Construction of two mechanical draft cooling towers for a cooling water system alternative could 21 require the relocation of existing support activities at the Turkey Point site. Because only 22 previously disturbed industrial portions of the Turkey Point site would be used to accommodate 23 the new cooling towers, land use impacts associated with the construction and operation of the 24 mechanical draft cooling towers for the cooling water system alternative would be SMALL. 25 4.2.7.2 Visual Resources 26 Construction and Operations 27 Construction and operation of the two cooling towers for a cooling water system alternative 28 would have little to no additional visual impact. The height of the mechanical draft cooling 29 towers would be similar to the height of other buildings at the Turkey Point site. Temporary 30 visual impacts may occur during construction from cranes and other construction equipment. 31 During facility operations, cooling tower steam plumes could add to the existing visual impact. 32 Therefore, visual impacts during the construction and operation of two new cooling towers at the 33 Turkey Point site, including steam plumes that could be visible from great distances, could 34 range from SMALL to MODERATE depending on seasonal weather conditions. 35 4.3 Air Quality and Noise 36 This section describes the potential air quality and noise impacts of the proposed action 37 (subsequent license renewal) and alternatives to the proposed action. 4-11

1 4.3.1 Proposed Action 2 4.3.1.1 Air Quality 3 According to the GEIS (NRC 1996 and NRC 2013a), the generic issues related to air quality as 4 identified in Table 4-1 above would not be affected by continued operations associated with 5 license renewal. As discussed in Chapter 3, the NRC staff identified no new and significant 6 information for these issues. Thus, as concluded in the GEIS, the impacts of those generic 7 issues related to air quality would be SMALL. Table 4-2 does not identify any site-specific 8 (Category 2) air quality issues for Turkey Point Units 3 and 4. 9 4.3.1.2 Noise 10 According to the GEIS (NRC 1996 and NRC 2013a), noise has not been found to be a problem 11 at operating plants and is not expected to be a problem at any plant during the subsequent 12 license renewal term. In addition, nuclear plant operations at Turkey Point Units 3 and 4 have 13 not changed appreciably with time, and no change in noise levels or noise-related impacts are 14 expected during the subsequent license renewal term. 15 The NRC staff identified no new or significant information during its review of the FPL 16 environmental report, at the site visit, through the scoping process, or in the evaluation of other 17 available information. Consequently, people living in the vicinity of Turkey Point Units 3 and 4 18 would not experience any changes in noise levels during the subsequent license renewal term 19 beyond what is currently being experienced. Therefore, the impact of continued reactor 20 operations during the subsequent license renewal term would not exceed the noise impacts 21 predicted in the GEIS. For these issues, the GEIS predicts that noise impacts would be SMALL 22 for all nuclear plants. 23 As identified in Table 4-1, the impacts of all generic noise issues would be SMALL. Table 4-2 24 does not identify any site-specific (Category 2) noise issues for Turkey Point Units 3 and 4. 25 4.3.2 No-Action Alternative 26 4.3.2.1 Air Quality 27 Under the no-action alternative, there would be a reduction in air pollutant emissions from 28 activities related to the cessation of Turkey Point operations, such as the use of combustion 29 sources (diesel generators, engines) and vehicle traffic. Activity from these air emission 30 sources would not cease, but emissions would be lower. Therefore, the NRC staff concludes 31 that if emissions decrease, the impact on air quality from the shutdown of Turkey Point would be 32 SMALL 33 4.3.2.2 Noise 34 Under the no-action alternative, the NRC would not issue subsequent renewed licenses, and 35 reactor operations at Turkey Point Units 3 and 4 would shut down on or before the expiration of 36 the current renewed operating licenses. The termination of reactor operations would result in a 37 reduction in noise sources throughout the nuclear facility, including noise from turbine 38 generators, machinery, pumps, and other noise-generating equipment, and some vehicular 39 traffic. Therefore, noise impacts resulting from the no-action alternative would be SMALL. 4-12

1 4.3.3 Replacement Power Alternatives: Common Impacts 2 4.3.3.1 Air Quality 3 Construction 4 Construction of a power station under a replacement power alternative would result in 5 temporary impacts on local air quality. Air emissions would be intermittent and would vary 6 based on the level and duration of specific activities throughout the construction phase. During 7 the construction phase, the primary sources of air emissions would consist of engine exhaust 8 and fugitive dust emissions. Engine exhaust emissions would be from heavy construction 9 equipment and commuter, delivery, and support vehicular traffic traveling to and from the facility 10 as well as within the site. Fugitive dust emissions would be from soil disturbances by heavy 11 construction equipment (e.g., earthmoving, excavating, and bulldozing), vehicle traffic on 12 unpaved surfaces, concrete batch plant operations, and wind erosion to a lesser extent. 13 Various mitigation techniques and best management practices (e.g., watering disturbed areas, 14 reducing equipment idle times, and using ultra-low sulfur diesel fuel) could be used to minimize 15 air emissions and to reduce fugitive dust. Implementation of a dust-control plan would also 16 address reasonable precautions that would be needed to prevent fugitive particulate emissions 17 in accordance with Florida Administrative Code 62-296.320(4)(c)3. Air emissions include 18 criteria pollutants (particulate matter, nitrogen oxides, carbon monoxide, and sulfur dioxide), 19 volatile organic compounds, hazardous air pollutants, and greenhouse gases (GHGs). Small 20 quantities of volatile organic compounds and hazardous air pollutants would also be released 21 from equipment refueling, onsite maintenance of the heavy construction equipment, and other 22 construction finishing activities as well as from cleaning products, petroleum-based fuels, and 23 certain paints. 24 Operations 25 The impacts on air quality as a result of operation of a power station for a replacement power 26 alternative will depend on the energy technology (i.e., fossil-fuel based or nuclear). 27 Fossil fuel-based power plants result in larger amounts of air emissions than nuclear power 28 plants. Worker vehicles, auxiliary power equipment, and mechanical draft cooling tower 29 operation will result in additional air emissions. 30 4.3.3.2 Noise 31 Construction 32 Construction of a replacement power facility would be similar to the construction of any 33 industrial facility in that all involve many noise-generating activities. In general, noise emissions 34 would vary during each phase of construction, depending on the level of human activity, types of 35 equipment and machinery used, and site-specific conditions. Typical construction equipment, 36 such as dump trucks, loaders, bulldozers, graders, scrapers, air compressors, generators, and 37 mobile cranes, would be used, and pile-driving and blasting activities could take place. Other 38 noise sources include construction worker vehicle and truck delivery traffic. However, noise 39 from vehicular traffic would be intermittent and would generate noise at levels similar to noise 40 levels from Turkey Point Units 3 and 4 reactor operations. 4-13

1 Operations 2 Noise generated during operations could include noise from mechanical draft cooling towers, 3 transformers, turbines, machinery, equipment, and communication announcements and sirens, 4 as well as offsite sources, such as employee and delivery vehicular traffic. Noise from vehicles 5 would be intermittent and at levels similar to noise levels generated by vehicles at Turkey Point. 6 Similarly, with the exception of noise from mechanical draft cooling towers, operational noise 7 levels at a replacement power plant would likely be similar to existing noise levels at 8 Turkey Point Units 3 and 4. 9 4.3.4 New Nuclear Alternative 10 4.3.4.1 Air Quality 11 Construction 12 Air emissions and sources associated with construction of the new nuclear alternative would 13 include those identified as common to all replacement power alternatives in Section 4.3.3.1, Air 14 Quality. Because air emissions from construction activities would be limited, local, and 15 temporary, the NRC staff concludes that the associated air quality impacts from construction of 16 a new nuclear alternative would be SMALL. 17 Operations 18 Operation of a new nuclear generating plant would result in air emissions similar in magnitude to 19 air emissions from the operation of Turkey Point. Sources of air emissions would include 20 stationary combustion sources (e.g., diesel generators, auxiliary boilers, and fire pumps) and 21 mobile sources (e.g., worker vehicles, onsite heavy equipment, and support vehicles). 22 Additional air emissions would result from the new nuclear plants use of mechanical draft 23 cooling towers rather than the cooling canal system currently used by Turkey Point and could 24 contribute to impacts associated with the formation of visible plumes, fogging, and subsequent 25 icing downwind of the towers. In general, most stationary combustion sources at a nuclear 26 power plant would operate only for limited periods, often during periodic maintenance testing. A 27 new nuclear power plant would need to secure a permit from the Florida Department of 28 Environmental Protection for air pollutants associated with its operations (e.g., criteria 29 pollutants, volatile organic compounds, hazardous air pollutants, and greenhouse gases). The 30 NRC staff expects the air emissions for combustion sources from a new nuclear plant to be 31 similar to those currently being emitted from Turkey Point Units 3 and 4 (see Section 3.2.1). 32 Emissions from the mechanical draft cooling towers would be approximately 15 tons/year for 33 particulate matter less than 10 microns and 0.08 tons/year for particulate matter less than 34 2.5 microns (NRC 2016a). Therefore, the NRC staff expects that the combined air quality 35 impact of emissions from onsite sources would be minor. Additional air emissions would result 36 from the approximately 800 employees commuting to and from the new nuclear facility. The 37 NRC staff does not expect air emissions from operation of a new nuclear alternative to 38 contribute to National Ambient Air Quality Standard violations. The NRC staff concludes that 39 the impacts of operation of a new nuclear alternative on air quality would be SMALL. 4-14

1 4.3.4.2 Noise 2 Construction 3 Noise generated during the construction and operation of a new nuclear power plant would be 4 similar to noise for all replacement power alternatives as discussed in Section 4.3.3.2, Noise. 5 In addition, Sections 4.8.2 and 5.8.2 of the EIS for the Turkey Point Units 6 and 7 combined 6 licenses (NUREG-2176) (NRC 2016a) describe noise impacts generated during construction 7 and operation of proposed Turkey Point Units 6 and 7; those noise impacts would be similar to 8 the noise impacts of constructing and operating new nuclear plants to replace Units 3 and 4. 9 Accordingly, the NRC staff incorporates the information in Sections 4.8.2 and 5.8.2 of 10 NUREG-2176 here by reference (NRC 2016a). Noise impacts during construction would be 11 limited to the immediate vicinity of the Turkey Point site. Because of the distance of the site to 12 potential receptors, noise impacts during the construction of a new nuclear power facility at the 13 Turkey Point site could range from SMALL to MODERATE depending on the noise-sensitive 14 receptor. 15 Operations 16 Mechanical draft cooling towers generate noise during operations. Other sources of noise 17 during nuclear power plant operations would include industrial equipment, machinery, vehicles, 18 and communications. In general, noise would be limited to the immediate vicinity of the Turkey 19 Point site and, with the exception of the cooling towers, noise levels would be similar to noise 20 levels generated during the operation of Turkey Point Units 3 and 4. Therefore, noise impacts 21 during power plant operations for a new nuclear plant would be SMALL. 22 4.3.5 Natural Gas Combined-Cycle Alternative 23 4.3.5.1 Air Quality 24 Construction 25 Air emissions and sources associated with construction of the natural gas alternative would 26 include those identified as common to all replacement power alternatives in Section 4.3.3.1, Air 27 Quality. There would also be additional air emissions resulting from construction of a new or 28 upgraded pipeline that would connect to existing natural gas supply lines north of the site. Air 29 emissions would be localized, intermittent, and short lived, and adherence to well-developed 30 and well-understood construction best management practices would mitigate air quality impacts. 31 Therefore, the NRC staff concludes that construction-related impacts on air quality from a 32 natural gas alternative would be of relatively short duration and would be SMALL. 33 Operations 34 Operation of a natural gas plant would result in emissions of criteria pollutants and greenhouse 35 gases. The sources of air emissions during operation include gas turbines through heat 36 recovery steam generator stacks. The staff estimated air emissions for the natural gas 37 alternative using emission factors developed by the U.S. Department of Energys National 38 Energy Technology Laboratory (NETL 2010a). Assuming a total gross capacity of 1,726 MW 4-15

1 and a capacity factor of 0.87 (FPL 2018f), the NRC staff estimates the following air emissions 2 would result from operation of a natural gas alternative: 3

• sulfur oxides20 tons (18 metric tons (MT)) per year 4
• nitrogen oxides440 tons (400 MT) per year 5
• carbon monoxide45 tons (41 MT) per year 6
• PM1032 tons (29 MT) per year 7
• carbon dioxide equivalents (CO2eq)5.7 million tons (5.2 million MT) per year 8 Operation of the mechanical draft cooling towers and up to 150 worker vehicles would also 9 result in additional criteria emissions above those presented in the list. A new natural gas plant 10 would qualify as a major emitting industrial facility. As such, the new natural gas plant would be 11 subject to Prevention of Significant Deterioration (PSD) and Title V air permitting requirements 12 under the Clean Air Act of 1970, as amended (42 U.S.C. 7651 et seq.), to ensure that air 13 emissions are minimized and that the local air quality is not substantially degraded.

14 Additionally, various Federal and State regulations aimed at controlling air pollution would affect 15 a natural gas alternative. 16 Based on the NRC staffs air emission estimates, nitrogen oxide and greenhouse gas emissions 17 from a natural gas plant would be noticeable and significant. Carbon dioxide emissions would 18 be much larger than the threshold in the U.S. Environmental Protection Agencys (EPAs) 19 Greenhouse Gas Tailoring Rule, and nitrogen oxide emissions would exceed the threshold for 20 major sources. The NRC staff concludes that the overall air quality impacts associated with 21 operation of a natural gas alternative would be SMALL to MODERATE. 22 4.3.5.2 Noise 23 Construction 24 In addition to the common impacts discussed in Section 4.3.3.2, Noise, for all replacement 25 power alternatives, additional noise would be generated during the construction of pipelines to 26 support a natural gas power plant. Because of the distance involved in pipeline construction, 27 noise impacts during the construction of a natural gas power plant and gas pipeline could range 28 from SMALL to MODERATE depending on the location of noise-sensitive receptors along the 29 gas pipeline. 30 Operations 31 Noise generated during the operation of a natural gas power plant would include noise from 32 mechanical draft cooling towers, compressor stations, and pipeline blowdowns. However, the 33 majority of noise-producing equipment (e.g., mechanical draft cooling towers, turbines, pumps) 34 would be located inside the power block. Therefore, noise impacts during power plant 35 operations would be SMALL. 4-16

1 4.3.6 Combination Alternative (Natural Gas Combined-Cycle and Solar Photovoltaic 2 Generation) 3 4.3.6.1 Air Quality 4 Construction 5 Air emissions and sources associated with construction of both the natural gas and solar 6 portions of this combination alternative would include those identified as common to all 7 replacement power alternatives in Section 4.3.3.1, Air Quality. Air emissions from construction 8 would be localized and intermittent, and well-understood construction best management 9 practices would mitigate air quality impacts. Therefore, the NRC staff concludes that 10 construction-related impacts on air quality from the combination alternative would be SMALL. 11 Operations 12 Air emissions associated with the operation of the natural gas portion of the combination 13 alternative would be similar to those associated with the natural gas alternative. However, 14 emissions associated with the natural gas portion of the combination alternative are slightly 15 reduced because the electricity output of the natural gas unit under the combination alternative 16 would be approximately 95 percent of that of the natural gas-only alternative. 17 The NRC staff estimates the following air emissions for the natural gas portion of the 18 combination alternative based on emission factors developed by the U.S. Department of 19 Energys National Energy Technology Laboratory (NETL 2010a): 20

• sulfur oxides19 tons (18 metric tons (MT)) per year 21
• nitrogen oxides420 tons (380 MT) per year 22
• carbon monoxide43 tons (39 MT) per year 23
• PM1030 tons (28 MT) per year 24
• carbon dioxide equivalents (CO2eq)5.4 million tons (4.9 million MT) per year 25 Operation of the mechanical draft cooling towers and up to 150 worker vehicles would also 26 result in additional criteria emissions above those presented in the list. The new natural gas 27 units would qualify as major emitting industrial facilities and would be subject to Prevention of 28 Significant Deterioration and Title V air permitting programs aimed at controlling air pollution.

29 Carbon dioxide emissions would be greater than the threshold in EPAs Greenhouse Gas 30 Tailoring Rule, and nitrogen oxide and carbon monoxide emissions would exceed the threshold 31 for major sources. 32 Air emissions associated with the operation of solar energy facilities are negligible because no 33 fossil fuels are burned to generate electricity. Emissions from solar fields would include fugitive 34 dust and engine exhaust emissions from vehicles and heavy equipment associated with site 35 inspections, maintenance activities (panel washing or replacement), and wind erosion from 36 cleared lands and access roads. The types of emission sources and pollutants during operation 37 would be similar to those during construction, but much fewer emissions would be released 38 during operation. These emissions should not cause exceedances of air quality standards or 39 have any impacts on climate change. The NRC staff concludes that the overall air quality 40 impacts associated with operation of the combination alternative would be SMALL to 41 MODERATE. 4-17

1 4.3.6.2 Noise 2 Construction 3 Construction-related noise sources for the natural gas power plant portion of the combination 4 alternative would be similar to the impacts discussed for the natural gas-only power plant 5 alternative in Section 4.3.5.2, Noise, and the common impacts discussed in Section 4.3.3.2, 6 Noise, for all replacement power alternatives. Noise impacts during the construction of a solar 7 facility could range from SMALL to MODERATE depending on its location in proximity to 8 noise-sensitive receptors. Therefore, construction impacts from the combination alternative 9 could range from SMALL to MODERATE depending on the location of noise-sensitive 10 receptors. 11 Operations 12 Noise generated during natural gas power plant operations would include noise from 13 mechanical draft cooling towers, compressor stations, and pipeline blowdowns. Noise impacts 14 during operation of the natural gas power plant component of the combination alternative would 15 be similar to those described in Section 4.3.5.2. Except for maintenance activities, very little 16 noise would be generated by the solar facility. Therefore, noise impacts during facility 17 operations from the combination alternative would be SMALL. 18 4.3.7 Cooling Water System Alternative 19 4.3.7.1 Air Quality 20 Construction and Operations 21 Under the cooling water system alternative, three plume-abated wet mechanical draft cooling 22 towers would be constructed for each reactor unit. Air emissions from construction of the 23 cooling towers would result from the exhaust of construction equipment, worker vehicle exhaust, 24 land disturbance activities (land-clearing, excavation), and demolition activities. Fuel 25 combustion exhaust would emit criteria pollutants and greenhouse gases while land-disturbance 26 and demolition activities would result in fugitive dust. 27 Potential atmospheric impacts from cooling system operation include the formation of visible 28 plume, fogging, and subsequent icing downwind of the towers. Operation of cooling towers 29 would also result in the emission of particulate matter from cooling tower drift, with higher 30 concentrations of dissolved solids associated with the potential use of seawater as a secondary 31 source of cooling water. However, modern cooling towers equipped with drift eliminators would 32 minimize the loss of water from the cooling towers via drift. As stated in Section 5.7.2 of the 33 final EIS for the Turkey Point Units 6 and 7 combined licenses (NUREG-2176), cooling tower 34 emissions would be required to adhere to the New Source Performance Standards 35 (40 CFR 60.40, Applicability and Designation of Affected Facility) and demonstrate compliance 36 with ambient air-quality standards by acquiring a Prevention of Significant Deterioration permit 37 under the Clean Air Act before the cooling towers could be operated (NRC 2016a). 38 Replacement power may be needed during both construction and operation of a mechanical 39 draft cooling tower system at Turkey Point. Following cooling tower construction, 40 Turkey Point Units 3 and 4 would be offline for at least a short time during the switchover from 41 use of the cooling canal system (CCS) to cooling towers. Some replacement power could also 4-18

1 be required once Turkey Points cooling tower system is online to compensate for the additional 2 power needed to operate cooling tower pumps and fans. Replacement power would come from 3 common types of existing technology within the region (natural gas, nuclear, and coal), and it is 4 not likely that new facilities would be constructed. The impacts on air quality would depend on 5 the specific location and technology of the replacement power facilities. 6 In Sections 4.7 and 5.7 of the final EIS for the Turkey Point Units 6 and 7 combined licenses 7 (NUREG-2176), the NRC staff determined that air impacts from the construction and operation 8 of Units 6 and 7, including those associated with the construction and operation of the 9 mechanical draft cooling towers, would be SMALL (NRC 2016a). As described in Section 2.2.3, 10 Cooling Water System Alternative, of this SEIS, construction and operation of mechanical draft 11 cooling towers for Units 3 and 4 would be similar to, but proportionally smaller than, the impacts 12 described in the NUREG-2176 analysis for Units 6 and 7. Therefore, the NRC staff concludes 13 that the air quality impacts from the construction and operation of mechanical draft cooling 14 towers to support Turkey Point Units 3 and 4 would be SMALL. 15 4.3.7.2 Noise 16 Construction 17 Construction-related noise during construction of the cooling towers for the cooling water 18 system alternative would be similar to the impacts discussed in Section 4.3.3.2, Noise, as 19 common to all replacement power alternatives. Because of the distance from the site to 20 noise-sensitive receptors, noise impacts during construction of the cooling towers for the cooling 21 water system alternative at the Turkey Point site could range from SMALL to MODERATE 22 depending on the noise-sensitive receptor. 23 Operations 24 As previously discussed, mechanical draft cooling towers generate noise during operations. In 25 general, noise impacts when the cooling towers for the cooling water system alternative are 26 operating would be limited to the immediate vicinity of the Turkey Point site and would be 27 SMALL. 28 4.4 Geologic Environment 29 This section describes the potential geology and soil resource impacts of the proposed action 30 (subsequent license renewal) and alternatives to the proposed action. 31 4.4.1 Proposed Action 32 According to the 2013 GEIS (NRC 2013a), plant-specific environmental reviews conducted by 33 the NRC had not identified any significant impact issues related to geology and soil resources. 34 The NRC staffs review of the Turkey Point subsequent license renewal application has not 35 identified any new or significant information that would change the conclusion in the GEIS. 36 Thus, as concluded in the GEIS, the impacts of continued operation on geology and soil 37 resources would be SMALL. 38 As identified in Table 4-1, the impacts of the single geologic environment issue (geology and 39 soils) would be SMALL. Table 4-2 does not identify any site-specific (Category 2) geologic 40 environment issues. 4-19

1 4.4.2 No-Action Alternative 2 Under the no-action alternative, the NRC would not issue subsequent renewed licenses and 3 Turkey Point Units 3 and 4 would shut down on or before the expiration of the current renewed 4 licenses. There would not be any impacts to the geology and soils at the Turkey Point site with 5 the shutdown of the facility. With the shutdown of the facility, no additional land would be 6 disturbed. Therefore, the NRC staff concludes that impacts on geology and soil resources from 7 the no-action alternative would be SMALL. 8 4.4.3 Replacement Power Alternatives: Common Impacts 9 Under all replacement power alternatives, construction impacts would be temporary and 10 localized. During construction for all the replacement power alternatives, sources of aggregate 11 material (such as crushed stone, sand, and gravel) would be required to construct buildings, 12 foundations, roads, and parking lots. The NRC staff presumes that these resources would likely 13 be obtained from commercial suppliers using local or regional sources. 14 During construction of all replacement power alternatives, no previously undisturbed soils would 15 be impacted. Organic soil or muck on the proposed building site would be removed and 16 disposed of in several locations on the berms alongside the main return canal and southern 17 canal of the CCS (also called the industrial wastewater facility). Prior to placement of spoils 18 material, part of the surface would be excavated, and small containment berms would be 19 created to form a shallow excavation in which to place the spoils. Material that is removed from 20 the excavations and is not suitable for reuse would be placed in these areas for dewatering and 21 disposal. FPL has indicated that measures such as berms, riprap, sedimentation filters, and 22 detention ponds would be used to control drainage from the spoils piles to the CCS 23 (NRC 2016a). 24 During operation of replacement power alternatives, no additional land would be disturbed. 25 Therefore, NRC staff concludes that the common impacts of operations of replacement power 26 alternatives on geology and soil resources would be SMALL. 27 4.4.4 New Nuclear Alternative 28 The NRC staff did not identify any impacts to the geologic environment for the new nuclear 29 alternative beyond those discussed above as common to all replacement power alternatives. 30 Therefore, the NRC staff concludes that the impacts to geology and soil resources from the new 31 nuclear alternative would be SMALL. 32 4.4.5 Natural Gas Combined-Cycle Alternative 33 The NRC staff did not identify any impacts to the geologic environment for the natural gas 34 alternative beyond those discussed above as common to all replacement power alternatives. 35 Therefore, the NRC staff concludes that the impacts to geology and soil resources from the 36 natural gas alternative would be SMALL. 37 4.4.6 Combination Natural Gas Combined-Cycle and Solar Photovoltaic Alternative 38 For the natural gas component of this alternative, the NRC staff did not identify any impacts to 39 the geologic environment beyond those discussed above as common to all replacement power 40 alternatives. However, the solar component of this alternative would require land to be cleared 4-20

1 for solar power installations. The corresponding impacts on soil resources would be noticeable, 2 but they would not destabilize important attributes of the resource. Therefore, the NRC staff 3 concludes that the impacts to geology and soil resources from the combination natural gas and 4 solar alternative would be MODERATE. 5 4.4.7 Cooling Water System Alternative 6 The NRC staff did not identify any impacts to the geologic environment for the cooling water 7 system alternative beyond those discussed above as common to all replacement power 8 alternatives. Therefore, the NRC staff concludes that the impacts to geology and soil resources 9 from the cooling water system alternative would be SMALL. 10 4.5 Water Resources 11 This section describes the potential surface water and groundwater resources impacts of the 12 proposed action (subsequent license renewal) and alternatives to the proposed action. 13 4.5.1 Proposed Action 14 4.5.1.1 Surface Water Resources 15 According to the GEIS (NRC 1996 and NRC 2013a), for the most part, no significant surface 16 water impacts for Category 1 (generic) issues are anticipated during the license renewal term 17 that would be different from those occurring during the current license term. The NRC staffs 18 review of the Turkey Point SLR application has not identified any new and significant 19 information that would change the conclusion in the GEIS. Thus, as concluded in the GEIS, for 20 these Category 1 (generic) issues, the impacts of continued operation on surface water 21 resources would be SMALL. 22 Table 4-1 in Section 4.1 lists Applicable Category 1 (Generic) Issues for Turkey Point. The 23 impacts for these issues are SMALL. While no Category 2 (site-specific) issues applicable to 24 the Turkey Point site have been identified, the NRC staff did evaluate the significance of new 25 information for the impacts from the CCS on adjacent surface water bodies via the groundwater 26 pathway. As discussed below, this information was determined not to be significant for Turkey 27 Point subsequent license renewal. 28 New Issue, Water Quality Impacts on Adjacent Water Bodies (Plants with Cooling Ponds in Salt 29 Marshes) 30 As part of its review of the Turkey Point subsequent license renewal application, the NRC staff 31 identified new information regarding nuclear power plant operations that can act upon the 32 environment in a manner or in an intensity or scope (context) not previously recognized. 33 Specifically, the GEIS (NUREG-1437) did not consider how a nuclear power plant with a 34 cooling pond in a salt marsh may indirectly impact the water quality of adjacent surface water 35 bodies via a groundwater pathway. This constitutes a new, site-specific issue with respect to 36 Turkey Point, for which the NRC staff has prepared the following site-specific analysis. 37 In its environmental report, FPL identified the Category 1 issue, Altered salinity gradients, as 38 applicable to Turkey Point Units 3 and 4 operations. However, the NRC staff has determined 39 that this issue is not applicable to Turkey Point due to the unique configuration of the Turkey 40 Point CCS. As indicated in Table B-1 of Appendix B to Subpart A of 10 CFR Part 51 and as 4-21

1 further described in the GEIS (NRC 2013a), the issue, Altered salinity gradients, only applies 2 to nuclear power plants located on estuaries and changes in salinity due to the operational 3 effects of intake and discharge structures in estuaries. At Turkey Point, the intake and 4 discharge structures associated with Units 3 and 4 are located within the enclosed CCS, which 5 does not directly discharge to the surface waters of Biscayne Bay. Nonetheless, the NRC staff 6 has evaluated new and potentially significant information related to the operation of the CCS 7 and its effects on salinity within the Biscayne aquifer under the issue, Groundwater quality 8 degradation (plants with cooling ponds in salt marshes), in Section 4.5.1.2 of this SEIS rather 9 than under the new issue discussed in this section. 10 For this new issue (water quality impacts on adjacent water bodies), Sections 3.1.3, Cooling 11 and Auxiliary Water Systems, and 3.5.1, Surface Water Resources, of this SEIS present 12 relevant new information related to the water quality of surface waters adjacent to Turkey Point 13 and the Turkey Point site. Much of this information did not become available until many years 14 after the NRC had issued the initial renewed licenses for Units 3 and 4 in 2002 and was not 15 available at the time that the 2013 GEIS was prepared. The following discussion is based on 16 information summarized in the aforementioned sections of this SEIS. 17 Turkey Point Units 3 and 4 do not consume surface water or discharge directly to natural 18 surface water bodies. All surface water discharges from Turkey Point flow into the CCS. As 19 described in Section 3.1.3.2 of this SEIS, the CCS is surrounded by perimeter berms that are 20 designed to keep water from entering the CCS. The perimeter berms are built on top of the 21 bedrock, while water levels in the CCS are below the top of the bedrock. The perimeter berms 22 are not in contact with water within the CCS. However, the water in the CCS is in contact with 23 and hydrologically connected to the Biscayne aquifer. The Biscayne aquifer, in turn, is 24 hydrologically connected to the surrounding marsh land, mangrove areas, adjacent drainage 25 canals, Biscayne Bay, and Card Sound. 26 Water in the CCS is considered industrial wastewater and is not recognized as a usable 27 resource. Therefore, only the impacts from CCS operation on the water quality of adjacent 28 surface water bodies via the groundwater pathway from the CCS through the Biscayne aquifer 29 are considered in this analysis. 30 The Florida legislature has designated Biscayne Bay and Card Sound, including Biscayne 31 National Park, as Outstanding Florida Waters. This designation affords these waters the 32 highest water quality protections in the State. 33 The impact of temperature, salinity, ammonia, and nutrients on water quality has been the focus 34 of CCS operational concerns. It has been reported that increased levels of ammonia, other 35 nutrients, or salinity had been found in local areas adjacent to the CCS, however, as discussed 36 below and in Chapter 3 of this SEIS, discernable effects from CCS derived temperature, 37 ammonia, nutrients, and salinity on Biscayne Bay or Card Sound water qualities has not been 38 detected. 39 As discussed in Section 3.5.1.4 of this SEIS, ammonia concentrations in the water within the 40 CCS are below the Miami-Dade County ammonia water quality standard. Also as discussed in 41 Section 3.5.1.4, adjacent surface water bodies contain ammonia from natural sources that occur 42 within the water body (e.g., through decay of organic matter). Noticeable concentrations of 43 ammonia have been found in two deep excavations outside of and adjacent to the CCS that 44 contain stagnant water (i.e., the Barge Turning Basin and the remnant canal at Turtle Point). To 4-22

1 prevent the movement of ammonia from the CCS into these areas, FPL is undertaking 2 mitigation activities, as discussed below. 3 Thermal impacts on adjacent water bodies from the CCS have not been detected. Similarly, 4 impacts on surrounding marsh and mangrove areas from CCS contributions of ammonia, 5 nutrients, and salinity have not been detected. Impacts on adjacent canals from CCS 6 contributions of ammonia, nutrients, and salinity have been slight. Water that likely originated 7 from the CCS has sporadically been detected in two canals adjacent to the CCS. However, the 8 water quality in these two canals has not been degraded sufficiently to prevent these canals 9 from achieving their intended purpose (i.e., transporting fresh water, draining the land, and flood 10 control). Further, little if any influence on surface water quality in Card Sound was detected 11 from the discharge of these two canals into Card Sound. 12 As described in Section 3.5.2, Groundwater Resources, hypersaline water originating in the 13 CCS is moving eastward beneath Biscayne Bay at depth along the base of the Biscayne 14 aquifer. The program implemented by FPL to extract hypersaline groundwater from the 15 Biscayne aquifer (on the west side of the CCS) is not designed to remove the hypersaline 16 groundwater beneath Biscayne Bay (on the east side of the CCS). Because the hypersaline 17 groundwater is denser than seawater, the hypersaline groundwater is found at the bottom of the 18 Biscayne aquifer and is moving down the eastward dip of the aquifer. Upward movement of this 19 hypersaline water from the Biscayne aquifer and into Biscayne Bay and Card Sound has not 20 been detected in either pore water or shallow monitor well samples collected in the Bay and 21 Sound. 22 In accordance with agreements reached with and/or requirements imposed by the Florida DEP 23 and Miami-Dade County DERM, FPL is implementing programs to control ammonia and 24 nutrients and to reduce salinities within the CCS. These programs (which include adding fresh 25 or lower salinity water to the CCS, pumping hypersaline water from groundwater, and 26 monitoring and reporting requirements) are expected to reduce the impact of the CCS on 27 groundwater quality within the Biscayne aquifer. In turn, the potential impacts on surface water 28 quality via groundwater from the CCS via the groundwater pathway would also be reduced. 29 These programs are expected to reduce the amount of hypersaline groundwater originating 30 from the CCS. Hypersaline groundwater flow from the CCS beneath Biscayne Bay would, 31 however, continue to move eastward and downgradient along the base of the Biscayne aquifer. 32 While this is a new site-specific issue that has been identified for Turkey Point, upon 33 consideration of the FDEPs and DERMs existing requirements and their continuing oversight of 34 FPLs site remediation efforts, the NRC staff concludes that the impacts on adjacent surface 35 water bodies via the groundwater pathway from the CCS during the subsequent license renewal 36 term would be SMALL and, therefore, the new information that has been identified is not 37 significant. 38 4.5.1.2 Groundwater Resources 39 According to the GEIS (NRC 1996 and NRC 2013a), groundwater resources would not be 40 significantly affected by continued operations associated with license renewal in most 41 circumstances. As discussed in Section 3.5.2 of this SEIS, the NRC staff identified no new and 42 significant information for most issues relating to groundwater use and quality. As identified in 43 Table 4-1, the impacts for most applicable generic groundwater resources issues would be 44 SMALL. However, during its review of FPLs environmental report, site visit, scoping process, 45 and evaluation of other available information, the NRC staff identified new information regarding 4-23

1 the generic groundwater resource issue of Groundwater quality degradation (plants with 2 cooling ponds in salt marshes). The NRC staffs evaluation of the significance of this new 3 information follows. 4 New Information, Category 1 Issue, Groundwater Quality Degradation (Plants with Cooling 5 Ponds in Salt Marshes) 6 As referenced in Section 1.4 of this SEIS and as further described in Sections 1.5 and 1.8 of the 7 GEIS (NUREG-1437) (NRC 2013a), no additional site-specific analysis is required by the NRC 8 staff for Category 1 (generic) issues in the SEIS unless new and significant information is 9 identified that would change the conclusions in the GEIS. Where new and significant 10 information has been identified, the NRC staff will reconsider generic impacts in the SEIS. 11 The Category 1 issue, Groundwater quality degradation (plants with cooling ponds in salt 12 marshes), was first evaluated in the 1996 GEIS (NRC 1996) and was reconsidered as part of 13 the update to the GEIS, issued in June 2013 (NRC 2013a). 14 For the subject issue, the 2013 GEIS (NRC 2013a: 4-50, 4-51) provides the following technical 15 basis with respect to nuclear power plants that use cooling ponds as part of their cooling water 16 system discharge: 17 Nuclear plants that use cooling ponds as part of their cooling water system 18 discharge effluent to the pond. The effluents concentration of contaminants and 19 other solids increases relative to that of the makeup water as it passes through 20 the cooling system. These changes include increased total dissolved solids (or 21 TDS), since they concentrate as a result of evaporation, increased heavy metals 22 (because cooling water contacts the cooling system components), and increased 23 chemical additives to prevent biofouling. Because all the ponds are unlined 24 (NRC 1996), the water discharged to them can interact with the shallow 25 groundwater system and may create a groundwater mound. In this case, 26 groundwater below the pond can flow radially outward, and this groundwater 27 would have some of the characteristics of the cooling system effluent. 28 In salt marsh locations, the groundwater is naturally brackish (i.e., with a TDS 29 concentration of about 1,000 to more than 10,000 milligrams per liter [mg/L]) and, 30 thus, is already limited in its uses. As such, this issue concerns only the potential 31 for changing the groundwater use category of the underlying shallow and 32 brackish groundwater due to the introduction of cooling water contaminants. Two 33 nuclear plants, South Texas in Texas and Turkey Point in Florida, have cooling 34 systems (man-made cooling pond and cooling canal system, respectively) 35 located relatively near or constructed in salt marshes. Plants relying on brackish 36 water cooling systems would not further degrade the quality of the shallow 37 aquifer relative to its use classification. This is because groundwater quality 38 beneath salt marshes is already too poor for human use (i.e., it is non-potable 39 water) and is only suitable for industrial use. 40 The NRC staff concluded in the GEIS (NUREG-1437) (NRC 2013a: 4-50, 4-51) that operational 41 impacts from cooling ponds located in salt marshes would have a SMALL impact on 42 groundwater quality, and no new information was identified that would alter this conclusion. 4-24

1 Section 3.5.2.2 of this SEIS presents and considers in detail relevant new information related to 2 groundwater quality at the Turkey Point site that supports the staffs reconsideration of the 3 generic impacts of the subject issue. This information is summarized below. The CCS used by 4 Turkey Point Units 3 and 4 and other generating facilities at the Turkey Point site is an 5 expansive water body formed by excavation into the marshes and underlying bedrock. Because 6 the CCS is unlined, it is hydraulically connected to the upper Biscayne aquifer, permitting the 7 movement of water between the CCS and the aquifer through the bedrock. Water in the CCS is 8 hypersaline (i.e., the water has a salinity greater than that of natural seawater, with a chloride 9 concentration exceeding 19,000 mg/L). Over the operational life of the CCS, the annual 10 average salinity of the waters within the CCS and the hypersaline groundwater plume beneath it 11 has increased. The existence of a hypersaline plume beneath the CCS was known at the time 12 the NRC staff prepared its SEIS for the initial license renewal for Turkey Point in 2002. At the 13 time, however, and at the time of the 2013 update to the GEIS (NRC 2013a), the potential for 14 the hypersaline plume to migrate down through the Biscayne aquifer and then move laterally 15 beyond the boundaries of the CCS was not known. 16 Beginning in 2010, FPL initiated an expanded groundwater monitoring program in accordance 17 with State regulatory approvals of the Turkey Point extended power uprate (EPU) project, to 18 determine the horizontal and vertical effects of CCS water on the environment. Monitoring 19 results demonstrated that CCS operations have impacted groundwater quality in the Biscayne 20 aquifer beyond the boundaries of the CCS and FPL property, both to the west of the site as well 21 as beneath Biscayne Bay to the east of the Turkey Point site. The hypersaline plume 22 emanating from the CCS has migrated along the base of the Biscayne aquifer to the west into 23 groundwater designated by the State as Class G-II, potable water use (defined as having total 24 dissolved solids (TDS) levels of less than 10,000 mg/L). Currently, FPL reports that hypersaline 25 water from the CCS extends out approximately 1.5 mi (2.4 km) west of the CCS boundary. 26 The NRC staff concludes that the contribution of past CCS hypersaline water on offsite 27 groundwater quality is difficult to quantify, in that statements by the State of Florida 28 (FDEP 2014a) and analyses prepared by FPL, as referenced in Section 3.5.2.2 of this SEIS, 29 indicate that saltwater was present as early as the 1940s near the base of the Biscayne aquifer 30 west of the Turkey Point site (i.e., prior to completion of CCS construction in 1973). In addition, 31 groundwater data from the early 1970s supported the determination that non-potable 32 groundwater occurred beneath much of the area now occupied by the CCS and within the 33 deeper portions of the aquifer west of the site. Thus, portions of the Biscayne aquifer to the 34 west of the CCS did not meet Class G-II groundwater criteria prior to CCS construction. This 35 earlier groundwater quality degradation is attributable to regional saltwater intrusion, which had 36 already occurred across southeast Miami-Dade County and the Turkey Point site due to historic 37 land use alterations and groundwater withdrawals that induced saltwater migration from east to 38 west along the base of the Biscayne aquifer (FDEP 2014a, NRC 2016a). 39 However, the fact that CCS operations have measurably degraded groundwater quality beyond 40 the general confines of the CCS structure and Turkey Point site boundaries is generally not in 41 dispute. Furthermore, it is apparent that water from the CCS has migrated to the west and 42 toward areas where groundwater within the Biscayne aquifer is of sufficient quality to support its 43 use as a potable water supply. Vertical trends in monitoring wells for such parameters as 44 chloride, TDS, and tritium concentrations indicate the influence of CCS water in groundwater 45 both to the west and east of the Turkey Point site, as discussed in Section 3.5.2.2 of this SEIS. 46 Consequently, in accordance with regulatory mechanisms imposed by Miami-Dade County 47 (MDC 2015a) and FDEP (FDEP 2016e), FPL initiated operation of a groundwater remediation 4-25

1 system in May 2018, to intercept, capture, and retract the hypersaline plume within a 10-year 2 timeframe. 3 Groundwater monitoring results for tritium also indicate that the extent of potential influence of 4 CCS water (based on a tritium concentration of 20 pCi/L or greater as measured near the base 5 of the Biscayne aquifer) extends as far as 4.5 mi (7.2 km) west of the CCS at monitoring well 6 TPGW-7 and approximately 2 mi (3.2 km) east beneath Biscayne Bay (see Figure 3-13 of this 7 SEIS). These monitoring results show that the extent of tritium migration exceeds the extent of 8 the hypersaline plume from the CCS (as noted above, FPL reports that hypersaline water from 9 the CCS extends out approximately 1.5 mi (2.4 km) west of the CCS boundary). Nonetheless, 10 using 20 pCi/L for tritium as a standard, near monitoring well TPGW-7 to the west of the CCS, 11 Class G-II groundwater criteria are met in the upper part of the Biscayne aquifer with the 12 relatively fresh water band thickening to the west and away from the saltwater interface. This 13 westward boundary (defined by the current estimate of the 20 pCi/L concentration boundary for 14 tritium in groundwater) is approximately 2 mi (3.2 km) southeast of the Newton Wellfield that 15 supplies potable water from the Biscayne aquifer to parts of Miami-Dade County. At no location 16 outside the boundary of the Turkey Point site do tritium levels in groundwater approach the EPA 17 and State primary drinking water standard for tritium (20,000 pCi/L), while the highest tritium 18 levels observed in offsite monitoring wells near the site are approximately 15 percent of the 19 standard. 20 Moreover, the northwestern-most boundary of the 20 pCi/L tritium concentration in the vicinity of 21 monitoring well TPGW-7 closely aligns with the current location of the saltwater interface in the 22 Biscayne aquifer in that area, as shown in Figure 3-12 of this SEIS. Both the U.S. Geological 23 Survey (USGS) and FDEP have asserted that hypersaline water from the CCS contributes to 24 the westward migration of the saltwater interface across southeast Miami-Dade County, as 25 referenced in Section 3.5.2.2. Most recently, FPL reported to FDEP on the results of 26 groundwater modeling (Tetra Tech 2018) that was performed using a variable density flow and 27 salinity transport model to allocate relative contributions to the movement of the saltwater 28 interface. The modeling results indica]]