BEFORE THE GOVERNING BOARD OF THE =? SOUTH FLORIDA WATER MANAGEMENT DISTRICT SFWMD No, 2015-020-DA0-wu | “9 !#Ic! In re: \ AUTHORIZATION OF SHORT-TERM WATER WITHDRAWALS BY FLORIDA POWER AND LIGHT FROM THE L-31E CANAL SYSTEM IN MIAMI-DADE COUNTY, FLORIDA / FINAL ORDER The Governing Board of the South Florida Water Management District ("District’), pursuant to Sections 373.083, 373.085, 373.086, and 373.171, Florida Statutes (Fla. Stat.), after considering the recommendations of District staff and being otherwise fully appraised of the matter, issues the following Final Order containing Findings of Fact, Ultimate Facts and Conclusions of Law: FINDINGS OF FACT 1. The District is a public corporation of the State of Florida, existing pursuant to Chapter 25270, Laws of Florida, 1949, and operating pursuant to Chapter 373, Fla. Stat., and Title 40E, Florida Administrative Code ('Fla. Admin. Code’), as a multi-purpose water management district with its principal office at 3301 Gun Club Road, West Palm Beach, Florida. The District has the power and duty to protect Florida’s water resources and to administer and enforce the provisions of Chapter 373, Fla. Stat., and the rules promulgated there under, Title 40E, Fla. Admin. Code. The District has jurisdiction over the matters addressed in this Order. 4 Exhibit "A" 2. Florida Power and Light ("FPL’) is a subsidiary of NextEra Energy, Inc. As a regulated utility, FPL is granted an exclusive franchise by the Public Service Commission to provide reliable and cost-effective electric service to customers, including critical infrastructure, within its service territory in Florida. FPL’s service territory covers all or parts of 35 Florida counties and serves approximately nine million customers. 3. The customers particularly at issue in this matter are those residing in Miami-Dade and Broward counties. In these counties, FPL provides electrical service to two million customer accounts, including critical infrastructure. 4. FPL owns and operates the electric power generating facility known as the Turkey Point Power Plant (“Turkey Point’) that is the subject of this request. 5. Turkey Point is located in unincorporated southeast Miami-Dade County, east of Florida City and the City of Homestead. The Turkey Point site covers approximately 11,000 acres. Turkey Point is located approximately 25 miles south of Miami and about nine miles east of Florida City. Properties adjacent to the facility are almost exclusively undeveloped land. Turkey Point is bordered to the east by Biscayne Bay, Biscayne National Park, and Card Sound. A Turkey Point location map is attached hereto as Exhibit A. 6. Turkey Point consists of five steam electric generating units: three fossil fuel-fired units (Units 1, 2, and 5) and two nuclear units (Units 3 and 4). Units 1 and 2 constructed in the late 1960s each have a continuous generating capacity of approximately 404 megawatts (MW). Operations of units 1 and 2 are on a standby basis and not routinely in service. Unit 5 has a continuous generating capacity of approximately 1150 MW. Units 3 and 4 each have continuous generating capacity of approximately 820 MW. 7. Units 3, 4, and 5 are certified under Florida's Power Plant Siting Act (‘PPSA’). Units 1 and 2 pre-date the PPSA and are not certified. 8. FPL owns and operates a cooling canal system (“CCS”), an approximately 5,900-acre network of unlined canals at Turkey Point, to provide cooling water. Construction of the CCS was completed in 1973. The CCS is closed from the surface waters of both Biscayne Bay and Card Sound. The CCS facilities pre-date the PPSA and are not certified. Under routine operations, there are no active surface water inflows utilized to maintain CCS water levels, temperature, or salinity. 9. The L-31E Canal System is of particular importance to FPL’s request. The L-31E Canali System is part of the Central and Southern Florida Flood Control Project (“C&SF Project’) for which the District is the designated local sponsor pursuant to Section 373.1501, Fla. Stat. As local sponsor, the District operates C&SF Project components, including the L-31E Canal system and the surface water flow to tide from the associated basins, consistent with the guidance provided in the United States Army Corps of Engineers Master Water Control Manual, East Coast Canals, Volume 5. 10. The L-31E Canal System is a borrow canal and levee system that stretches north — south, intercepting water as it flows eastward to tide in southeast Dade County and providing storm surge protection. A map depicting the L-31E Canal System is attached hereto as Exhibit B. The L-31E Canal runs parallel to the South Central Biscayne Bay and across several drainage basins, six of which are named for the associated major east-west canals: Canal 100 (C-100), C-1, C-102, C-103, North Canal ? and Florida City Canal. This canal network and coastal levee system is operated for several C&SF Project purposes, including reducing the potential for flood and storm surge damage as well as limiting saline water intrusion. Water from the L-31E is discharged to Biscayne Bay at several coastal structures as depicted on Exhibit B. 11. Operation of the C&SF Project coastal structure gates in this canal network discharge excess water when rainfall causes stages to rise above the control levels and close in order to maintain sufficient water to prevent salt water intrusion among other Project purposes. Overall, these surface water inflows comprise the largest input of fresh water to Biscayne Bay and Biscayne National Park in this area. 12. In the 1990’s the U.S. Army Corps of Engineers and the District developed the Comprehensive Everglades Restoration Program (“CERP") which was approved by Congress in the Water Resources Development Act of 2000 ("WRDA 2000”). A component of CERP includes the Biscayne Bay Coastal Wetlands Phase 1 Project. This project component aims to restore the overland sheetflow in an area of up to 11,000 acres, and to improve the ecology of Biscayne Bay, including its freshwater and saltwater wetlands, nearshore bay habitat, marine nursery habitat, and the oyster reef community. 13. Implementation of the Biscayne Bay Coastal Wetlands Phase 1 Project will impound and redistribute freshwater runoff from the existing canal discharges into the coastal wetlands adjoining Biscayne Bay to provide a more natural and historical overland flow pattern through existing coastal wetlands and tidal creeks. This redistribution of freshwater runoff will improve the temporal and spatial distribution of inflows to Biscayne Bay. 14. The WRDA 2000 requires that water be reserved from allocation as an assurance that each CERP project component will meet its goals and objectives. Water is to be reserved consistent with the objectives and information contained within the Central and Southern Florida Project Comprehensive Everglades Restoration Plan Biscayne Bay Coastal Wetlands Project Phase | Final integrated Project Implementation Report and Environmental Impact Statement (‘PIR’) and other sources of information, 15. To this end, the District conducted technical studies identifying water to be reserved for the protection of fish and wildlife within the western near-shore portion of Central Biscayne Bay, engaged in rule development, and adopted the Nearshore Central Biscayne Bay reservation rule and associated implementation rules. The reservation rules and consumptive use implementing criteria is attached hereto as Exhibit C. The location of the Nearshore Central Biscayne Bay and the associated Project canal system is depicted in Figure 3-1 of Exhibit C. 16. The determination of the amount of water needed for protection of fish and wildlife in the Nearshore Central Biscayne Bay reservation rule is based on meeting a year-round salinity target for the nearshore area of central Biscayne Bay of 20 (practical salinity scale) given in the PIR. More detailed analyses were performed to determine the locations and quantities of surface water for the reservation rules. This information is contained in the District's Technical Document to Support a Water Reservation Rule for the Comprehensive Everglades Restoration Plan Biscayne Bay Coastal Wetlands Project (July 2013). 17. Rule 40E-10.061, Fla. Admin. Code, is the water reservation rule for the Nearshore Central Biscayne Bay. Pursuant to this rule, a Target Flow to the Bay of 504 acre-feet per day, of surface water is reserved from allocation. Appendix 3, Figure 3-1 of Chapter 40E-10, Fla. Admin. Code, depicts the Nearshore Central Biscayne Bay Reservation Water Body and Protected Canal Reaches; Figures 3-4A and 3-4B depict surface water flow from the C-102 + Military + C-103 Canal through S-21A + S-20G + S- 20F into Biscayne Bay during the wet and dry seasons. (Ex. C.) 18. Water levels in the L-31E Canal System, the proposed water supply source, are influenced by the operation of coastal canal structures. Operation of the S- 20F, S-20G, and S-21A are performed consistent with guidance from the United States Army Corps of Engineers regulation schedule and Master Water Control Manual, East Coast Canals, Volume 5. Under normal operating conditions for April 30 - October 15 the S-20F, S-20G, and S-21A structures are operated in the “high range” meaning discharges’ to tide are conditionally made when stages upstream of the structure including stages within the L-31E Canal are 2.2 ft. NGVD or higher and the gates are closed when headwater stages drop to 1.8 ft. NGVD. During the agriculture drawdown season (October 15" through April 30"), S-21A, S-20G, and S-20F are set to operate with open and close ranges (Open/Close) of 1.4/1.0, 2.2/1.8, and 1.4/1.0 feet NGVD, respectively. 19. From 1993 to 2013, the District's operational records show the combined average daily flow from the C-102, Military, and C-103 canals through Structures S-21A, S-20G, and S-20F, respectively, into this portion of Biscayne Bay are 987 acre-feet per day from May 1° to October 14", with daily combined flows ranging from 0 acre-feet per day to more than 5,500 acre-feet per day during these months. From 1993 to 2013, the District's operational records show the combined average daily flow from the C-102, Military, and C-103 canals through Structures S-21A, S-20G, and S-20F, respectively, into this portion of Biscayne Bay are 492 acre-feet per day from October 15" to April 30", with daily combined flows ranging from 0 acre-feet per day to more than 3,500 acre-feet per day during these months. 20. The combined reserved target flow for structures S-21A, S-20G, and S- 20F is 504 acre feet suggesting that there is a reasonable expectation that daily flows exceeding the reservation target flows will occur during the months of June through mid- October, and potentially even through the month of November if conservative operational criteria for identifying and quantifying the amount of excess water are used. 21. Beginning in late spring, water temperatures within the CCS usually rise with temperatures at the plant intake often approaching 100°F by late spring. FPL’s operating license from the Nuclear Regulatory: Commission (“NRC”) includes a requirement prohibiting the intake side of Units 3 & 4 from exceeding 104°F. 22. In order to prevent Units 3 & 4 from being required to shut down, thereby impacting grid reliability, FPL requested authorization from the District to use water from the L-31E Canal System to reduce the salinity and temperature of the water within the CCS. After consideration of water resource constraints, such as the Nearshore Central Biscayne Bay water reservation, the District issued an Emergency Order authorizing the withdrawal of water from the L-31E Canal System above what is needed to meet the reservation subject to various identified conditions, including an operational protocol. The Emergency Order was issued on August 28, 2014. The Governing Board concurred with the Executive Director's Emergency Order on September 11, 2014. The fall 2014 Emergency Order terminated on October 15, 2014. 23. Pursuant to the limitations defined in the Fall 2014 Emergency Order, FPL pumped a limited number of days and volumes. These withdrawals, when allowed, ranged from 1 to 103 million gallons per day (‘mgd’). FPL withdrew a total of 4,135 million gallons (“mg”) of water pursuant to the Fall 2014 Emergency Order. During the same time the fall 2014 Emergency Order was in effect and FPL was authorized to pump, the District also released a combined average flow of 601 acre-feet per day of freshwater to Biscayne Bay through S-21A, S-20G, and S-20F, or 97 acre-feet per day above the target reservation flow. 24. During the term of the Fall 2014 Emergency Order, the temperature of the water in the CCS dropped 3.5°F. The salinity of the water within the CCS also dropped from 87.4 parts per thousand (“ppt”) to 75.4 ppt. There is a strong correlation between the drop in CCS water temperature and salinity from the addition of surface water. 25. FPL submitted an application to modify its site certification, requesting, in part, authorization to construct additional wells into the Floridan aquifer system ("FAS") and authorization to withdraw 14 mgd from said wells in order to provide water to the CCS. The District understands that the FAS is FPL’s intended long-term solution to reduce temperatures and salinity of the water within the CCS. 26. The Florida Department of Environmental Protection (“FDEP”) received several objections to FPL’s request. (DOAH Case No. 15-1559). A hearing date certain has been set for July 13-17, 2015. As such, the objections and final agency action on FPL’s request has not yet been determined. 27. As a temporary, interim step, FPL seeks this authorization to provide water to cool water in the CCS and reduce salinity. 28. On January 26, 2015, FPL submitted a consumptive use permit application, seeking authorization to divert and use non-reserved water from the L-31E Canal System. The purpose of the diversion is to help reduce high temperature and salinities occurring in the water in the CCS. 29. Specifically, FPL seeks to divert surface water that is available, above the water reserved by Rule 40E-10.061, Fla. Admin. Code, which would otherwise be discharged to Biscayne Bay via the S-20F, S-20G and S-21A coastal structures for the limited duration defined in this Order. 30. In support of their request, FPL provided a water/salt budget mode! for the Turkey Point CCS developed to quantify the volume of water and mass of salt entering and exiting the CCS over time and to evaluate changes in hydrodynamics associated with operational alternatives. A copy of the water/salt budget model is attached hereto as Exhibit D. The water/salt budget model ran two scenarios at multiple withdrawal rates. The first scenario simulated average weather conditions and the second scenario simulated drier than normal conditions. Each scenario was run four times under different pumping scenarios- no pumping, 30 mgd, 60 mgd, and 100 mgd and for a two (2) year timeframe. In each scenario, the results of the modeling showed that the greater the volume of water pumped into the CCS, the greater the drop in salinity of the water in the CCS. 31. As of March 24, 2015, the salinity of the water in the CCS was 85.76 ppt. The temperature of the water within the CCS was 90.45°F. These water temperatures are projected to increase during warm spring, summer, and fall months when air temperatures are high and daylight duration is at its height. The CCS water temperatures become more manageable when cooler weather and shortened days occur during south Florida’s winter and spring months. 32. —_ District staff reviewed and considered FPL’s request, historic data, District statutory authorizations and rules, and the potential water availability. District staff also met with representatives of FPL and other stakeholders to discuss this matter. Therefore, FPL has indicated its intent to withdraw application No. 150126-17, upon execution of this Order and expiration of the time to challenge the same. ULTIMATE FACTS AND CONCLUSIONS OF LAW 33. — The District is authorized to regulate connections and use of the District's rights of way, use of water, construction of new diversion facilities, initiation of new water uses, diversion and withdrawal facilities pursuant to a variety of statutes. (e.g.: §§373.083, 373.085, 373.086, 373.1501, 373.171, 373.219, Fla. Stat.) 34. The Governing Board may ‘“[iJssue orders to implement or enforce any provisions of th{e] chapter or regulations.” § 373.083(2), Fla. Stat. (2044). 35. The Governing Board is authorized to issue orders affecting the use of water, as conditions warrant, and forbidding the construction of new diversion facilities or wells, the initiation of new water uses, or the modification of any existing uses, diversion facilities, or storage facilities within the affected area. § 373.171(1), Fla. Stat. (2014). 36. Pursuant to Sections 373.085, 373.086 and 373.1501, Fla. Stat., the District is authorized to act as local sponsor and operate the C&SF Project, including those structures that are part of the L-31E Canal System and relevant to the subject reservation. 10 37. Rule 40E-10.061, Fla. Admin. Code, reserves water for protection of fish and wildlife in the Nearshore Biscayne Bay. Seasonal target flows are stated in this rule. Operation of the C&SF Project frequently involves discharge of water from the subject structures to tide in excess of those reserved such that water is periodically available for use. 38. FPL’s Turkey Point CCS has recently experienced heightened temperatures and salinity. The CCS temperatures, if sufficiently high, can result in an emergency involving potential to shutting down all or part of power production at Turkey Point. 39. Addition of water from an external source can reduce CCS temperatures. 40. To avoid an emergency and better manage heightened CCS temperatures and salinity, FPL seeks a short-term approval authorizing withdraw of available surface water from the L-31E Canal System as it develops long-term water supply and other options to manage CCS temperatures and salinity. 41. Based on FPL’s request and the above-described facts, the District has considered this matter and finds that the requested use, as conditioned by the below stated withdrawal limitations and monitoring requirements, will not use water reserved for protection of fish and wildlife as defined in Rule 40E-10.061, Fla. Admin. Code, and will not cause to harm the water resources of the District. ORDER Based upon the Findings of Fact, Ultimate Facts and Conclusions of Law, the Governing Board orders that FPL is authorized to undertake the following, temporary actions in accordance with the conditions stated herein: 11 42. Short-Term Water Withdrawal Authorization a. Water Availability Restriction: FPL is prohibited from withdrawing and using water from the L-31E Canal System that is reserved for fish and wildlife by Rule 40E-10.061, Fla. Admin. Code, for the Nearshore Central Biscayne Bay. The only water available for the purpose of this Order is that water which would otherwise be discharged to tide through the S-20F, S-20G, and S-21A structures and is sufficiently in excess of the flows reserved for protection of fish and wildlife in Rule 40E-10.061, Fla. Admin. Code. This available surface water may, for the duration of this Order, be withdrawn and used within FPL’s cooling canal system in accordance with the conditions as set forth below. There are no assurances provided by this Order that water will be available for FPL’s withdrawal and use on any given day. Water availability is determined by a two-step process: Step 1) satisfaction of the calendar constraint criteria; and Step 2) the delivery of 504 acre-feet per day to the Nearshore Central Biscyane Bay from S-21A, S-20G, and S-20F each day prior to the daily withdrawal of excess water from the C-103 Basin. b. Step 1 - Calendar Constraint: FPL may potentially withdraw water from June 1 to November 30 (“Calendar Constraint’). No withdrawals are authorized from December 1 through May 31* by this Order. c. Step 2 - Withdrawal _of Excess Water from the L-31E Canal System: If the Calendar Constraint (Step 1) is met, the following procedure shall be used to identify when FPL can withdraw water from the L-31E Canal System: i. Part 1 - All pumps start each day off. 12 ii. Part 2 — All pumps remain off until the combined discharge from S-21A, S-20G, and S-20F equals or exceeds 504 acre-feet. FPL shall monitor a data feed (i.e., web page) maintained by the District that provides real time estimates of the discharges from S-21A, S-20G, and S-20F. The data populating this site will be collected by the District SCADA system and communication in the normal time frames (e.g., updates ranging in frequency from 15 minutes to an hour). iii. Part 3 - Once the data feed confirms that the combined discharge from S-21A, S-20G, and S20F equals or exceeds 504 acre-feet, FPL may withdraw water from the L-31E Canal System for the remainder of the day at up to the maximum capacity provided that the Criterion to Prevent Over-Withdrawal or Hydraulic Slope !mpact is met. iv. Part 4 — End of the Day. By the end of the Day (11:59 p.m), FPL shall turn off all pumps. Once the pumps are secured for the day, FPL shall record the daily flow totalizer for each pump. 43. Criterion to Prevent Over-Withdrawal or Hydraulic Slope Impact: FPL shail maintain a volume within the L-31E that is sufficient to ensure that there is no net withdrawal based on the expected measurement uncertainty of the flow totalizers. a. FPL shall calculate the daily volume pumped from the C-103 Basin into the L-31E as well as the daily volume pumped from the L-31E into the CCS. The volume of water pumped from the C-103 Basin into L-31E must exceed the daily volume pumped from the L-31E into the CCS. The difference in volume shall account for any calibration errors between the two flowmeters. 13 b. The pumps withdrawing water from the C-103 Basin and discharging into the L-31E Canal (North Pumps) shall always be started at least five minutes before the pumps withdrawing water from the L-31E and discharging into the CCS (South Pumps). At the close of pumping for the day, the South Pumps shall be stopped at least 5 minutes before the North Pumps. In addition to this proactive measure, FPL shall evaluate the stage response of the L-31E for drawdowns due to a net withdrawal or hydraulic slope or a combination of both and reduce the L-31E withdrawals as required to eliminate any drawdowns caused by FPL pumping. 44. Communication of Water Availability Determination: Data on the daily discharges from S-20F, S-21A, S-20G will be available on a web page for FPL to determine when it can pump excess water from the L-31E Canal System between June 1 and November 30 each calendar year. In the event the District's real-time or specific web page are inoperable on a given day or time period, FPL shall contact the District's Operation Control Center at: 561-682-6116 and occ@sfwmd.gov to report that the information is not updating so that the SFWMD can issue a remedy ticket to diagnose and correct the problem. FPL may not commence any daily withdrawal operations until the District's data feed is operable or FPL receives written (e.g., e-mail) approval to pump. The District will provide written approval only for extended (multi-day) outages of the data feed. FPL will be solely responsible for accessing the District's data and FPL own data (e.g., pumping rates) to perform the calculations required to assess the criteria and calculate the correct pumping rates and durations. 14 45. Monitoring and Reporting: FPL shall monitor and report the amount of water diverted from the L-31E Canal System to its cooling canal system on a weekly basis. a. When FPL withdraws water, FPL shall generate a daily report that includes the following detailed information: i. The water availability determination for each day based on the data from the District-provided web page; il. identification of which pump(s) were used over the course of the day; iii. The time on and time off, per pump; iv. The RPM setting, per pump, if variable; Vv. The calculated volume of water pumped, per pump; and, vi. The cumulative log flows at each pump station. vii. FPL shall collect temperature and salinity data prior to initiation of pumping pursuant to this Order and once a week thereafter for the duration of this Order during the operational period. These samples shail be collected at monitoring station TPSWCCS-1 and TPSWCCS-2 in the CCS, and the results submitted to the District by noon on the following Tuesday after their collection. b. FPL shall prepare a weekly report which summarizes the daily reports for the preceding week (Monday at midnight through Sunday at 11:59 p.m.) and includes the following additional information: 15 i. Hourly stage data for the L-31E Canal measured at TPSW-1 and TPSW-2 for the weekly reporting period, whether or not the pumps operated. The report shall include a table of the weekly data and a graph of the stages. ii. The weekly report shail include a table and graph of ithe hourly staff gage readings from SG-N (North of Palm Drive), SG-S (South of Paim Drive), and SG-PSS (South Pump Station). iii. The weekly report shall be submitted by noon on the following Tuesday of each week C. The reports shall be e-mailed to Simon Sunderland, P.G., Consulting Hydrogeologist at ssunder@sfwmd.gov or Maria Clemente, P.E., Bureau Chief at mclement@sfwmd.gov. Both reports shail reference this Final Order. Upon District review of the daily and weekly reports, conference calls may be required. d. Additionally, the District may request available monitoring data at any time and FPL shall provide the same within two hours of the District's request. 46. Special Pump Station Criteria: a. The District may require FPL to terminate pumping at any time. Upon receipt of any oral or written request from the District to terminate pumping, FPL must cease pumping within two (2) hours. b. FPL shall coordinate the pumping at both stations to assure that, from a non-flow condition, the north station pumps shall be started first. The south station pumps shall be started within five (5) minutes of the north station pumps start, with an equivalent flow. Similarly, when pump operation ceases, the south station pumps shall cease first and the north station pumps shall cease within 5 minutes. 16 Cc. FPL shall prepare a storm/hurricane contingency plan that includes securing the pump stations and ancillary equipment during a major weather event, plans to empty all fuel lines from the storage tanks to the pumps. A copy of the plan should be available for the District to review, if requested. FPL is required to monitor the weather and hurricane forecasts and make the appropriate timely preparations. 47. Pump Requirements: a. The pump stations shall be staffed on a 24-hour basis. b. Pump Discharge Curves: Pump discharge curves used in determining rates of discharge while pumps are operating, as deployed in the field, shail be provided to the District prior to pump operation for the purpose of calculating flow rates and volumes. c. Totalizing Hour Meters: FPL shall install totalizing flow meters at each pump authorized by this Order and such meters shall be available for periodic District inspection and verification. Documentation of an up-to-date and accurate calibration for each of the totalizers shall be provided before pumping commences, 48. This Order authorizes FPL to take actions under Chapter 373, Fla. Stat., as provided herein. This Order does not relieve FPL from the requirements to obtain any other federal, state, or local authorizations. 49. This Order does not constitute a water use or right-of-way permit or grant any legal right to water as set forth in Chapter 373, Fla. Stat., and associated District rules and regulations over the water intercepted and stored under this Order. 50. This Order does not convey any property right to FPL, nor any rights and privileges other than those specified in this Order. This Order shall not be construed as 17 an abandonment or any other such impairment or disposition of the District's property rights. 51. This Order shail not be construed as a substitute for, or waiver of, any right- of-way, surface water management, water use, or other permits required of FPL under the District's rules and regulations. 52. FPL shall insure that harmful impacts to the water resources, off-site land uses, or existing legal uses of water do not occur as a result of this Order. In the event such harmful impacts result from actions authorized by this Order, FPL shall implement all actions, as directed by the District, to cease such harmful impacts and, if necessary, to mitigate such impacts. Failure to comply with this requirement shall be considered a violation of this Order. 53. Failure to comply with the terms of this Order shall constitute a violation of a District Order under Chapter 373, Fla. Stat., and enforcement proceedings may be brought in any appropriate administrative or judicial forum. 54. The District reserves the right to initiate appropriate legal action, to impose civil penalties, and collect attorney's fees and costs to enforce the terms of this Order. 55. This Order may be modified or amended at any time, as appropriate for the protection of the public health, safety, and welfare and the water resources of south Florida by the Governing Board, Executive Director, or Executive Director's designee. 56. The Executive Director or Executive Directors designee may require FPL to cease withdrawal and/or use activities under this Order at any time. 57. Failure to comply with the conditions contained within this Order shall constitute a violation of a District Order under Chapter 373, Florida Statutes, and 18 enforcement proceedings may be brought in any appropriate administrative or judicial forum. 58. If the District petitions or sues for enforcement of the terms of this Order, the District reserves the right to initiate appropriate legal action, to impose civil penalties and collect attorney's fees and costs. 59. This Order shall terminate on November 30, 2016 at 11:59 p.m. or upon written notice from the District's Executive Director or the Executive Director's designee, whichever occurs first. 60. A Notice of Rights attached hereto as Exhibit E. DONE AND SO ORDERED in West Palm Beach, Florida, on this 9th day of April, 2015. SOUTH FLORIDA WATER MANAGEMENT DISTRICT WAIN, By its Governing Board sy LORI, “iy, SO ip, " = Z {7 ¥\ee Blake C. Guillory, P E. t= § E A L ee Executive Director “y ablichod eS Attested: poy 7 wes Legal Form Approved: ee Ue ich dyr. District Clerk/Secreta April _/2_, 2015 49 V JISIHXS FPL TURKEY POINT COOLING CANAL FRESHWATER RECHARGE PROJECT LOCATION FLORIDA LOCATION MAP N.T.S. fanenaecs MIAMI-DADE COUNTY, FLORIDA DRAWING INDEX COVER SHEET CONSTRUCTION NOTES PROJECT OVERVIEW INTAKE SYSTEM SITE PLAN INTAKE SYSTEM PUMP AND UNDER ROAD CROSSING DISCHARGE SYSTEM SITE PLAN DISCHARGE SYSTEM PUMP AND LEVEE CROSSING DISCHARGE SYSTEM PROFILES DISCHARGE SYSTEM PIPE CROSSING OVER INTERCEPTOR CANAL PIPE BRIDGE PLAN ANO DETAILS EROSION CONTROL PLAN LOTR MN CANAL + INI AKE SYSTEM FROM. ™~ TIE (6) CANAL TO, UIE Oty LaF @ycaNAL s : DISCHARGE SYSTFM ~ ROM L3TC (3) CANAL _~ STO.COOUNG CANAL COOLING CANAL = VICINITY MAP 475 2000" (eens EPL TURKEY BOINE COOLING: CANAL FRESHWATER RFCHARGE MINE CADE COUNTY. FCA Deter EXHIBIT CHAPTER 40E-10 WATER RESERVATIONS 40F-10.01! — Policy and Purpose 40E-10.021 Definitions 40E-10.031 | Water Reservations Implementation 40E-10.061 Water Reservation Areas: Lower East Coast Planning Area 40E-10.011 Policy and Purpose. The purpose of this chapter is to define the quantity, location and timing of waters reserved from allocation for the protection of fish and wildlife pursuant to Section 373.223(4), F.S., for specified water bodies. Water reservations are implemented in the water use program pursuant to Chapter 40E-2, F.A.C. Rulemaking Authority 373.044, 373.113, 373.171 FS, Law Implemented 373.016, 373.026, 373.036, 373.1501, 373.1502, 373.219, 373.223, 373.4592, 373.4595, 373.470 FS. History-New 7-2-09, Amended 7-14-14. 40E-10.021 Definitions. (1) Fakahatchee Estuary — The area within the Ten Thousand Islands region including the following river/bay systems, from west to east: Blackwater River/Blackwater Bay, Whitney River/Buttonwood Bay, Pumpkin River/Pumpkin Bay, Wood River, Little Wood River and Faka Union Canal/Faka Union Bay, and Fakahatchee Bay as depicted in Figure 1-3 Fakahatchee Estuary. (2) Picayune Strand - The area located southwest of the Florida Panther National Wildlife Refuge, north of the Ten Thousand Islands NWR, east of the South Belle Meade State Conservation and Recreation Lands (CARL) Project, west of the Fakahatchee Strand Preserve State Park, and northeast of Collier-Seminole State Park as depicted in Figure 1-2 Picayune Strand. The Jegal description of the Picayune Strand is contained in Appendix 1. (3) North Fork of the St. Lucie River - The area that extends from the Gordy Road structure (state plane coordinates, x85[212.831, y1116105.7470), to the confluence of the North Fork of the St. Lucie River and the C-24 canal (state plane coordinates, x873,712.20, y1064,390.41) as depicted in Appendix 2, Figure 2-1. (4) Nearshore Central Biscayne Bay - The area within Biscayne Bay up to 1640 feet (500 meters) from the shoréline beginning south of Shoal Point extending southward to north of Turkey Point as depicted in Figure 3-1. (5) Caloosahatchee River — The surface waters that flow through the S-79 structure, combined with tributary contributions below S-79 that collectively flow southwest to San Carlos Bay, as defined in subsection 40E-8.021 (2), F.A.C. (6) Caloosahatchee River (C-43) West Basin Storage Reservoir -- A reservoir located in Hendry County, Florida, west of the City of LaBelle on the east side of the Townsend Canal and south of SR 80 as described in Appendix 1-12, and depicted in Figure 1- 13 (also known as the ‘C-43 Reservoir’). Rulemaking Authority 373,044, 373.13, 373.171 FS, Law Implemented 373,016, 373.026, 373.036, 373.1501, 373.1502, 373.219, 373.223, 373.4592, 373.4595, 373.470 FS. History-New 7-2-09, Amended 3-18-10, 7-21-13, 7-16-14. 40E-10.031 Water Reservations Implementation. (1) Applicants for consumptive use permits shall meet the requirements of this rule by providing reasonable assurances that Rule 40E-2.301, F.A.C., and Section 3.11 of the “Applicant’s Handbook for Water Use Permit Applications within the South Florida Water Management District,” incorporated by reference in Rules 40E-2.091, F.A.C., are met. (2) Water reserved for the protection of fish and wildlife contained within the Picayune Strand and Fakahatchee Estuary is defined in subsections 40E-10.041(f)-(2), F.A.C. (3) Water reserved for the protection of fish and wildlife contained within the North Fork of the St. Lucie River is defined in subsection 40E-10.051(1), F.A.C. (4) Water reserved for the protection of fish and wildlife contained within Nearshore Central Biscayne Bay is defined in subsections 40E-10.061(1)-(2), FAC. (5) Water reserved for the protection of fish and wildlife contained within and released, via operation, from the Caloosahatchee River (C-43) west Basin Storage Reservoir is defined in subsection 40E-10.041(3), F.A.C. Rulemaking Authority 373.044, 373.113, 373.171 FS. Law Implemented 373.016, 373.026, 373.036, 373.1501, 373.1502, 373.219, 373.223, 373.4592, 373.4595, 373.470 FS. History-New 7-2-09, Amended 3-18-10, 7-21-13, 7-14-14, 7-16-14. EXHIBIT C 40E-10.061 Water Reservation Areas: Lower East Coast Planning Area. (1) Nearshore Central Biscayne Bay as defined in subsection 40E-10,021(6), F.A.C.: All surface water contained within Nearshore Central Biscayne Bay is reserved from allocation (see Figure 3-1). (2) Surface water flowing into Nearshore Central Biscayne Bay as identified below is reserved from allocation: (a) Surface water flows depicted on Figures 3-2.A and 3-2.B through S-123 derived from the following contributing canal reaches: |. The C-100A canal upstream of S-123 to $-120 including all integrated conveyance canals. 2. The C-100C canal upstream of S-123 to S-1{9 including all integrated conveyance canals. 3. The C-100B canal upstream of S-123 to S-122 including all integrated conveyance canals. 4. The C-100 canal upstream of S-123 to S-118 including all integrated conveyance canals. (b) Surface water flows depicted on Figures 3-3.A and 3-3.B through S-21 derived from the following contributing canal reaches: |, The L-31E borrow canal upstream of S-21 to the canal terminus. 2. The C-1 canal upstream of S-21 to S-122 and S-149 including all integrated conveyance canals. 3, The C-f canal upstream of S-21 to the C-1W canal and S-338 including all integrated conveyance canals, (c) Surface water flows depicted on Figures 3-4.A and 3-4.B which is the combined flow through $-2LA, S-20G, and S-20F as derived from the following contributing canal reaches: !, The C-102 canal connecting to the C-102 N canal upstream of S-21 A to S-195. 2. The C-102 canal upstream of S-21 A to S-165. 3. The L-31E borrow canal upstream of S-21A te its terminus near S-21 including the Gould’s Canal. 4, The L-31E borrow canal upstream of S-21A south to S-20G. 5, The Military canal upstream of S-20G. 6, The C-103 canal upstream of S-20F to $-179. 7, The L-31E borrow canal upstream of S-20F to S-20G including all integrated conveyance canals. 8. The L-31E borrow canal from S-20F south to the North Canal. 9, The North Canal. 10. The L-31E borrow canal from S-20F south to the Florida City Canal. 11. The Florida City Canal from Southwest 107th Avenue to its confluence with the L-31E borrow canal. Notwithstanding the above, presently existing legal uses for the duration of a permit existing on July 18, 2013, are determined to be not contrary to the public interest pursuant to Section 373.223(4), F.S. Reservations contained in the section shail be reviewed in light of changed conditions or new information. Rulemaking Authority 373.044, 373.113, 373.171 FS. Law Implemented 373.916, 373.026, 373.036, 373.1501, 373.1502, 373.219, 373,223, 373.4592, 373.4595, 373.470 FS. History. New 7-21-13. APPENDIX 3: LOWER EAST COAST PLANNING AREA Figure 3-1 Nearshore Central Biscayne Bay Reservation Water Body and Protected Canal Reaches Bay Reservation'Water Badtyandl Protactad Canalifenches. Figure 3-2.A Surface Water Flow from the C-100 canal though S-123 into Biscayne Bay during the Wet Season (June-Octobor) (1886-2011) 12000 ‘00, 2 s Flow Rate (acre-Ruday) g ‘Target Flow to the Baye44 aze-tteay t) a a @ C 10 Percentage Time Equaled or Excesded Figure 3-2.8 Surface Water Flow irom tha C-100 canal tough S-123 Into Biscayne Bay during ha Dry Season (November-May) (1986-201 1} “y Flow Rate (acre-ttiday} Fy S ‘Target Flow to the Bay>344 acrothiey o a “a 60 0 100 Percentage Time Equated or Exceeded i i i 1 Figure 3-3.A Surface Wales Flow from the C-1 canal through S-21 into Biscayne Bay during the Wel Season (June-October) (1986-2011) 6008 J 3000, 3 Flow Rate (ocre-tuaay! Texpal Frow to the Bay=572 s0-4iay 0 2» 40 0 a 100 Parcentege Tima Equaled ar Excoadad Figure 3-3.B Surface Water Flow from the C-1 canal through S-27 Into Biscayne Bay during the Dry Season {November-May) (1986-2011) 6000 Flow Rate (acre-nidayp ‘Targat Flow to the Bay>672 pcre-titay 9 a 49 Cy a 100 Percentage Timo Equated or Exceeded Figure 3-4.A Surface Water Flow from the C-102+Military+C-103 Canal through 5-21A+S-206+S-20F into Biscayne Bay during the Wel Season (June-October) (1986-2011) 12009 y 000, S21At6-206¢5-20F Target SSE water Reserved 2000 Flow Rate (acre-ft/ctay) Percantage Time Equaled or Exceeded Figure 3-4.B Surface Water Flow from the C-102+Milltery+C-103 Canal through S-21A+S-20G+S-20F into Biscayne Bey during the Dry Season (November-May) (1986-2014) SHAS-2065-20F Targel TESSSSG Water Ratorvod Flow Rate (ecze-ttiday) Targot Flow to hs BayeS04 aero Percentage Time Equaled or Excasded 40E-2.301 Conditions for Issuance of Permits, (1) In order to obtain a permit, permit renewal, or permit modification under this chapter, an applicant must give reasonable assurances that the proposed water use at the time the permit application is deemed complete: (a) Will not cause harmful saline water intrusion; (b) Will not harm offsite land uses; (c) Will not cause harm to wetlands or other surface waters; (d) Will not cause pollution of the water resources; (c) Is otherwise a reasonable-beneficial use as defined in Section 373.019(13), F.S., with consideration given 10 the factors set forth in Rule 62-40.410, F.A.C.; (f) Will not interfere with presently existing legal uses; (g) Is in accordance with Section 373.2295, F.S., concerning interdistrict transfer of groundwater and Section 373,223(3), F.S., concerning water transport and use of groundwater or surface water across county boundaries. (h) For uses with a recommended maximum allocation which excceds [00,000 gallons per day or uses within a mandatory reuse zone, makes use of a reclaimed water source in accordance with the criteria contained in the “Applicant's Handbook for Water Use Permit Applications within the South Florida Water Management District,” incorporated by reference in Rule 40E-2.09 1, F.A.C. (i) Is in accordance with any minimum flow or level and implementation strategy established pursuant to Sections 373.042 and 373.0421, F.S.; and G) Is consistent with Sections 373.016 and 373.036, K.S., and otherwise is consistent with the public interest as prescribed by Chapter 373, F.S., and this chapter. (k) Will not withdraw water reserved under Chapter 40E-10, F.A.C. (2) In order to satisfy the conditions for permit issuance in subsection (1), the permit applicant must provide reasonable assurances that the criteria in the “Applicant's Handbook for Water Use Permit Applications within the South Florida Water Management District,” incorporated by reference in Rule 40E-2.091, F.A.C., are met. Rulemaking Authority 373.044, 373.113, 373.118, 373.171 FS. Law Implemented 373.036, 373.042, 373.083, 373.103(4), 373.1501, 373.1502, 373,223, 373.229, 373.2295, 373.470 FS. History-New 8-14-02, Amended 8-31-03, 4-23-07, 2-13-08, 7-2-09, 7-14-14. PLICANT’S DDBOOK FOR W TER PERMIT APPLICATIONS (07-16-2014 3.11.3 Nearshore Central Biscayne Bay A permit applicant shall provide reasonable assurances that the proposed use will not withdraw water reserved under subsection 40E-10.061(1), F.A.C. Compliance with the following criteria constitutes reasonable assurances that water reserved in Rule 40E- 10.061, F.A.C., will not be withdrawn. Water not reserved under Rule 40E-10.061, F.A.C., shall be allocated pursuant to this Subsection. For this section, the following definitions apply: Direct withdrawal: Withdrawal of surface water from facility intakes physically located within the surface water column of Nearshore Central Biscayne Bay as depicted on Figure 3-1 in Chapter 40E-10, F.A.C. No direct withdrawals shall be authorized pursuant to this rule. Indirect withdrawal: Withdrawal of surface water from facility intakes physically located within the surface water column of any canal reach identified in Figure 3- 1 in Chapter 40E-10, F.A.C. The following uses do not withdraw reserved water: A. Withdrawals of groundwater; B. Withdrawals authorized by Rules 40E- 2.061 (General Permits by Rule) and dewatering operations that 1) will not exceed a maximum of ten 10) mgd, with a maximum of 1,800 mg total pumpage; and 2) will not exceed a total duration of one year for the entire project; Cc. Renewals of indirect withdrawals authorized by a permit existing on July 21, 2013; D. A permit modification involving an indirect withdrawal authorized by a permit existing on July 21, 2013 that does not change the source, increase the allocation or change withdrawal locations, such as replacement of existing WU AH - 91 LICANT’S IDBOOK FOR WATE! C. -16-201 surface water pumps or intakes, crop changes that do not change the allocation or timing of use, or decrease in allocation; A new indirect withdrawal with no greater allocation and impact, including changes in timing, than a terminated or reduced permit that was existing on July 21, 2013 and occurs upstream of the same coastal structure; and, Indirect withdrawals which do not withdraw reserved water as defined in Rule 40E-10.061 F.A.C. WU AH - 92 [7] TETRATECH JECHNICAL MEMORANDUM From: Peter F. Andersen and James L. Ross, Tetta Tech To: Stacy Foster and Scott Burns, Florida Power & Light Company Date: March 13, 2015 Subject Evaluation of L-31E Water Addition Impacts on CCS Salinity Reduction Intreduction This technical memorandum describes water and salt balance modeling of the addition of L-31B water as a salinity reduction measure m the Florida Power & Light (FPL) Cooling Canal System (CCS), located at the Turkey Point Nuclear Power Plant. The modeling was conducted to provide an assessment of the effects of adding L~31E water to the CCS between June 1 and November 30 in 2015 and 2016 in an effort to reduce the salinity of the CCS. Knowledge of the effects of adding this water will help to identify how effective it is at reducing CCS salinity under different assumptions of water availability and maximum daily withdrawals A spreadshcet-based water and salt balance model was employed for this analysis. This model was developed as a part of the Tukey Point Uprate monitoring program. The South Florida Water Management Distt ict has reviewed the model at various stages of its development and application, The version of this model employed for the predictive analysis is transient and calibrated to 45 months of hydrologic and water quality data collected within the CCS and in the surrounding environment (Ecology and Environment, 2014), This model was modified and executed to provide estimates of the effect of adding various amounts of L-31E water in an effort to attain teductions in CCS salinity Background The CCS 4s a constiueted surface water body that receives heated water from Turkey Point Power-Geneiating Units 1,3, and 4 As the heated water travels southward along the discharge canals and northward back to the plant along return canals, it is cooled by evaporation and mixing with inflowing water from the Biscayne Aquifer. Due to the evaporative process, which is facilitated by the clevated temperature of the water, a portion ot the water from the CCS is lost to the atmosphere, leaving dissolved solids behind in the CCS and producing hypetsalme conditions in the CCS Hypersaline water exhibits salinities greater than that of seawater, which has a salinity of approximately 35 PSU Over the 10 years prior to 2014, salinity in the CCS has ranged between 42 and 69 PSU, During 2014, salnity in the CCS increased to a maximum daily average of approximately 99 PSU (monitoring station TPSWCCS-4, September 9, 2014) Subsequent to that peak, salinities reduced and vasied between 65 and 75 PSU in the fall of 2014 Pait of this salinity 1eduction 1s attributable to measures undertaken by FPL that included addition of L-31E water and groundwater from a Floridan well associated with Unit 5. In order to mitigate the contibution of hypersaline water to the underlying Biscayne Aquiter, and return the CCS to equilibrium consistent with pte-2014 conditions, FPL is evaluating remedial measures to moderate CCS salinities and prevent significant incteases in the neat future. In the course of prio: evaluations conducted to investigate the response of CCS salinity to TETRA TECH EXHIBIT D Page me the addition of less saline wares , an inspcotiom on imennittoaieng dav bretanrese, 200) aucal 2bii2 revealed a correlation between daily zaintilllem Hie CCS and OCS salinity, where einlall events, were generally followed by short team spaleeitinnn im CCS sabinettty. Two plheneunene wuse evident im this review of CCS monitoring date: 1) CCS salinities gencsally sedbee: desing cxliny snore: (May through October); 2) significa miediall emewts punliere wateblec maturities OCS sxarniny The latter phenomenon is effectively Mleatumtedl ley alage (2-7 iieelacn) sacolell csmeatt ev inte September 2010 that induced an appresianate: 10 RU! chap im dhe zeccage: CCS: salient. Because precipitation events are simply fiesinwster inflome in the CLS, they efizeriively thine the water and reduce salinity Based os the offbevitencenafenchs lew-aalieiiy inlhionvs ice cxttaniny salinity, the addition of L-31E wares te the CCS wean puagesedl dhesiong sioner weibern snicit: seten was, available. The water and salt balance nadie! asetiioned abane: wom mecmeliigened ts ewainnie tikes salinity reduction measure with respect to itt: efiibethinemcen fen meliietSing Weigle CCS: sleet ii Mixs near fiture. These evaluations and asyaciatied! semntite andl comelesioun aur disinescedi nelle. Reconfiguration of Water Balance te Repreanet Retere Preliictions Calibrated Water and Sait Balance Model Based on monitoring data in and ovtude of thee COR, Veta: Teeth ecomettancrete a. toraeusiiona swcnten and salt balance model of the CCS audi calidinatica it ts 46 nomen off gpttantorsia: andl nelivrety data collected fiom the CCS between Septewubex 1, 20110) and bMlay 3H, 2014 (Ecology amd Environment, 2014). This model caleulates intloms ime CCS (c.g, precipitation, seepage fio. groundwater) and outflows from the CCS: (c.g. cxmponattion, seepage te: pemendbeaton) once daily timestep using hydrologic, water quality, avd metraseliogicall date. These: dita wuexe collectel a inter vals 1anging from 15-minute fo l-ciay theomplient Biecagee: Aquilts, Discaywe Bay, the CC8, and nearby canals. The model uses the callentatind| daily fellowes andl ovat flenns ee efficetineiy symulate daily changes in CCS wates and salt stowage: Thane: clones: inn steeage ave: dren employed to calculate daily changes im CUS, water ilesvells aml scale, This mode! was later revised to incorgeale: data aed siematale comdlstenss: ttomypit Oinzalbes BDA Because this timeframe witnessed sigwithicaet shennes on the: CCS, iecketing cileatet exaparninee loses from the CCS, relatively low purcigpitnttions-Drased ieetlowm, oul the: iadlex off penmgnd 1-318 water, it was determined that a modell ealidlwattell ta tie: cxxtemlicall tsnediczsewe: wont Bre: catepast anu a better predictive tool. With minor clempen to» made pamaretica wallness, she: «-alitewattedl 45-sevenndls mode! was extended and re-calibratedl gp ellizesinelty piermoliate: de: S8-tmesath: ter ficasene: Moemnieeh October 2014 The quality of the model is Miiestratiedl ny the: neanmealblly accrcciatc: seemeetetion ef daily changes 12 average CCS wates Jewethn amell sliettiy omer tite: 56)-manalh pest (Fijggnse (1). ft should be noted that the model conceedity siemesliaties: sesdieetiionn: iin sclliaitey that eset Sone. hed large rainfall events (e.g. October 1, 2010) all the: acdidibion alt RE seater Claete Siegpteemedlines throngh mid-October 2014). The ability the mvattclh the: responee olf salkcritty tc tus: adidirtom aff. known. quantity and quality of watex punviidies comdidiere: tieett Wee: nmadie!l io: alban: grrentiien changes in CCS salinity due to presexithed CICS salinity sedbctiion mezoneen, Predictive Water and Salt Balance dticdet! in order to predict hiture changes iim C2'S: water fesieli axed canfbentty, thee: aomooneth remntd tis: conbkenidate CCS inflows and outflows was changed! relative te, that employed far dic lnamracall teetizame on the following manner. During the 5¢-mantlt histotiizal! pentiod: (Sapneratser 20% eheygh-“Ootaoer TEMRA TECH 2014), the calculation of water andl sails exchanges: between the COS send the: sunanmacdios environment retied on meavured CCS water lenells aud salinities. Becanse: titwce OCS condstions are unknown, predicted CCS intiionms med cedttlons ane cabewlated naling simulated CCS water levels and salinities As previously mentioned, the calibysked wale and salltielenee wodlell sieecdlates daily changes in CCS water level and salinity through Octithen 3, 20014. As sel, he: predictive sinwedatin, commences on November |, 2014, dao siemmiation extenls evex? years thongs Newember 30 , 2016. The initial predictive wate lewis thumephoné tiie CCS aur based os CLE water ievels observed on October 31, 2014 sax the: elhomage: hom wali Howell duc: ho thie nalamce: of wraler foes calculated for that day. Jn other wands, the siveniieed! Nawemelber |, 2004 water lewis theomghount the CCS are the sum of the messed CCS water loweis om Oepebes 3 and he eallewilated changes in water level due to the exlentates CCR ineflonsa: aed eniones fon that dey. The initial salinity conditions for the predictive mode ae ealleulated i am analiegons: maneex;, the sieauilated salinities throughout the CCS: on Nowemlbex 1 as the sam off the awvxage observed CCS salizaties on October 3 and the caleulated chumage: jie walialty dine: tin the balance of salt flows callealsted fox that day The daily exchanges of welew aad salt betmren he CICS and the seercoendiag environment for Nuvember | ate diekexntingd! waiing the: calewlated initial water llewels and salinitios throughout the CCS, The bellemee of these Slows iindionns the predicted OOS water level and salinity, respectively, tor the sesh day, The senlel ecvotiomues step- nse eslcalations of water levels and salinity in this mannes thuonghoet dhe: 25-peoctth puedictione: simellation. Predictive Scenarios In order to represent conditions oulsigde of the CCK, olbsenwed! deka frown te historical period was repeated and acted as 2 swwrogate Yor fatuce: bydiallestir, walter quality, aed meckeacclogical conditions in Biseayne Acuiter, Biscayne Bay, macau coral, andl the amesphese. Additionally, the mode! does not currently evaluate a CCS thenmal balemce,, so OCS weaker teampecaimnes observed during the historical pexlod wexe camplayeal to: mepceseat:Sirtuee: ermal condisions Because external conditiuns and, especially, CIOS wares temperainens play 2. large eole an inducing changes to CCS water levels anal salliaity, kn lheeliiee perdlictine scemanins were evaluated, cach scenario is distinet it whkat Intec! daa wns mand te oxpurscet fietace conditions. Predictive Scenario A asameies: hele: comdidiions mimic: these slbserwed betmoen November |, 201.0 and Octobey 31, 2012. Cowdttiinns: destin: tts: Gieefiame: seftoried monexa! weather patierns and were conducive: to modesnltiing CCS salinity. Puedective Scenario B assuorc: future conditions mimic those observed between Nowenfien Il, 2003 and Oemaber 32, 2014, a time duting which environmental comdidions (¢.g. perciigitation, CCS walter hempecatanes) reflected dry weather patterns and puudmerd! deamutic incncasen en CCS salieity. This |~year timeframe was repeated to produce: 2pean prndintiive: sikenladion (iy leew scemanios, the conditions observed during the fast Nienmlbex (2010, 2013) weer mypeated to carats manogate conditions for the last month. (Noweniber 2016) of the 24-neutih purdiictive :melation Predicted water levels and. salinities sumalatedl by Seemanion A are shame in Fugue 2, Seonatio B predictions are lustrated in Figo. 3. Companisna off thewe fignies, ceveads defiterenoes m how the CCS would respond to assumed fivtune condisions: Rindlictedl CCS: selmity scnenity decreases over the 2-year timeframe vader Scenaniio A, whereas COS salinity genexalty cies corms the 2 yeat predictive simulation under Sersasio B. The, xeanoe finer thie déspastty between these two predictive scenarios with respect to simulated sabiniiy andl wwates levels is. at promowsly TETRA TECH Page mentioned, the different histoncally absexvedi extemal conditions aud CCS wales temperateres, assumed fo persist over the next two years; Sconanio A aemees condilions consistent with thaw: observed between November 2010 sand Oxdathen 2002, evbexeas Serna B anmmce comditionss consistent with the November 2013 thuoagh Oktatier 2014 teeekame eceuning hwice sequentially. Between Novembex 2010 mad Ostateex 2002, aleervedl CCS salinities averaged S-4.¢ PSU and peaked at 68.2 PSU (at station TRSWICICE-6). Beteres Newensher 2013 aad October 2014, salinity in the CCS averaped 79. PSU andl eachedl a peak of appemsimaicly 98.5 PSU (a1 station TPSWCCS-4), Water levels beteren Nemrmiber 2010) and October 2012 were generally higher than those between Noventhes 2013 aed Otter 2014. it 1s, clear from: this companion that environmental conditions during the fiest tmp gear peniod wene: none effectere at CCS salinity than those: conditions observed! bethvzem Novexder 2013 and Ociober 2014. Thus, construction and simulation of tee pudictive semaston is pardtcated on two motivations. First, predicted CCS water levels and salieity made with mended Scenarios A and B will provide 2 range of anticipated conditions in the OCS im the seat fieieme, Predictions made with Seematio A will reficct environmental conditions thet axe comdincine to selatincky lew and stable saliwitios ux: the CCS, whereas predictions made with Seesanie 8 will eeflert the deleterions conditions that can coerce the CCS into a new equillitatann with hijgher saleeity sed lowes waler levels. Second, the two predictive scenarios will help to chacidatt: the relative efleetiweness of L-3HE water additions under different environmental conditions, Predictions with bell scenatios will help tio provide a realistic range of CCS salinity changes dive: te the prapesedl scaneslial rocanmes. These salinity reduction measures and thea: regareiine extrenees. ane. discussed below. Simulation of L-3LE Water Determination of Avaitable Water In order to provide an. estimate of potentially available water i L~ 24 oomsssvont wile tae tivo predictive scenarios, daily combined stormwater dimehwage welenes Umcongh $-21.4, $-20G, and §-20F into L-31B were determined Siw she: bistesical pesiedlc that iadnens beth Seenaaio 4 (November 201.0 through Octobex 2012) andl Semecntio B (Nawendhex 2013 Maoeyeh October 2014). The daily reservation flow volame (254 0) was then saliached fines the combined caity discharge, The resulting daily L-31E flow volemos arpacsent water that can potentially be added to the CCS as.a salinity reduction soca: Che dags hetercen Jame: i and November 30 winare the reservation flow exceeded combiend dailly dischaoge, it was aanmeed that wo 1 -3/.E water was availabie for allocation to the CCS In addition to oniieg: bistonical 1-31 E stomewater discharge volumes, L-3}E salinities observed chaiieg thie tame hiichntical teeefiaenes were ased Mdefiae sh assumed future salinity of L-3LE wattex addled tha he OCS. In order to evaluate the effcel of addiiag the excens I -30E stommmates water under dhifSenent assumptions of availability, feasibédity, aed pennitted allonations, thane comsinemd oniieria wer: applied to the excess flow volumes. These adiiitiionall nmnstuains defined a exxxiounen daily volume of available 1-3 UE wates thas could be:afileested to the OCS; tae theee constraint volumes evaluated are 30 MGD, 60 MGD, and 100 MG The 10 SGD constraint cefleets 2 sitnation in which the volume of L-31E that cam be allacatind! te the: OCS ra. tasted onty by the woratladnawal pump capacity. Of the three flow constyauety the 14% MIGD constadnt comlts tn the greatest volume of water added to the CCS from L-3UE Exense dauly stormewater dischanges to L-31 E for the two historical periods evaluated, constamed! to a caaxummm.of 105 MGD, are plotted an TETRA TECH Haye Figure 4 Sunudation Resulis The addition of L-3)E flow voles wen mnocichond by the quertictiive wats and! ned elmo models (both Scenario A. and Scesentio B). The modelled acthons: cexpsnag the adidet watter, enc associated changes to simulated CUB conditions, were sepersentedl by aecompeceting te additional prescribed flow aod assecioted mum: ie tke dilly water aad salt halaene eqentinns, respectely. These modeled actions damappal the sinelatodl CUS: water levels and saltsities fics the base mode! results in Figures 2 and 3. Ima gemauall, sinnilniell CCS waterkeveis annexed aed simulated CCS salinities decreased chatine: he the line cane pociortioe: simcintons, The simulated water levels in cack of tbe: thure addi water anameplions, a6 well 2s the cieediated water levels tor the base case, fix predintive: Semana A: ave plledied im Bignwe §. The water levels associated with predictive Scenatn Bau: plotled! ise Kigare: 6 Bleith Siguees dememstcate Meat 1 31E water added to the CCS results imam lineseane: inthe: OCS stagy:. Table: | paperidies the anretanye CCS water levels over the 25-nosth presirtiive: tiemetionse: few tiie lane: (ae action) case andl constramed L-318 flow assumptions mmdiee lini aresge: andl dry cxmtanesacxtz! cnmdilions. These results show that the average CCS stage imeneaos: ly 2: snanionnenna af O22, Roe andl @ 18 feet for Scenarios A and B, respestiwedy (bein fie the: MUR AGI) seaninamen L.-SiE altlacatne)) Note that these averages are taken aves the enter 25:monib pesiicdl aed dexiahems ia stapes relative to the base case: are moxe peommmmced Ihettmenn June: I aad Momensibes 29 wedees [315 water is permitted to be added to tbe: CUS. as, ewisdizaet ini Figqaues, 5 amma &. Table 1. 25-month averaged CCS walex kevelbs amas didizuent anacqpriions eff 31K adbihitions (in feet, NA VDB88) Environmental Conditions Scenario A “il ____faverage) Scenario B Simulated CCS salinities in respec: wo the adidied 1-31 wat, an, quel an dee sheamdaadl anlinitios, for the base case for predictive Semnceiin A auc: platted. im Figne 7) The pandlicted sallantiies tar Scenario B are plotted in Figuie: § Biotih tiguars: demonattatte: that aeawe (SIE weaker addled tto the CCS results m a greater decrease: in salinity Talblie 2 prowiiden the: acme: CCS ealiaaillees ames the 25-month predictrve tune frame: fiw the: bess: (ne actben) came andl tie cometzaieedl L-SIE Bow assumptions under both average, avd diy eanivemental! conditions: The: garatent decscase in average salinity occurs whem the L-OtE water added! to the CCS is constrained! exeily bey dhe withdrawal pump capacity (xnorboames of 100) MGI}, im this: exmediall case, the, 25-emeesin varie: salinity reduces by 28.7 PSU relative: to the: bese: case: for Seemarvo, & aad Yoy Gl PSU mellerave to the base case for Scenario B As in the case: of addiana: stage, these vallmities ane ameraged ovor the entire 25-month predictive puncfume: The mnpectod added water on sella us ans! ‘TETRA TECH & pronounced when the L-3 HE water is aememned! tov bre anded tm tthe CLG (Getween me § aied November 30). Fable 2. 25-month averaged CCS salinity under diffteent: amumptiions: of 1-ib additions (ie PSU) SccnanoA | (average) Scenario B Summary This analysis cvaluates the effectivensss of L-SILE dineftacgs: freed] saliincy nedmetion measures for the Turkey Point CCS. The: framsiiont watex andl gait tallance:deweleped forthe Upaatc Proyoce was used in 2 predictive, forward looking, sess. Banc exmedtail meeasmme: was modeled usisg two different assumptions for future conditions. The teem acenanion panwide: a hownd on. expected responses and show any differences: im eliietiinenean: lest eauit Raven ening: different faters background conditions. Deinils regeudiing the areomlligneatiea afftive: nendell to simulate the two future conditions are presented in the seememadines., This analysis suggests. that the addition ef L- RIE! watts to tee CCS in am effective means of reducing CCS salinities over the preslicsime 2-year tlonctaane: i light of todd average andl dry environmental conditions. One: of the key measaus that L-3LE wales seo efftative at ameliorating elevated CCS salinities is the fact thet the addition off thes: watex canepensates fox evaporative losses from: the CCS. Because evapenation remenes fivsiamates (and leaves suspended solids in the CCS), this outflow of water increases: the selionitty eff tee OCS. The addatiog of L-3LE water can help to replace freshwater lost tn exapenatiion aed lane saltieity sclatiwely low. This is particularly truc during dry condiname whene guccipitiatiinn 1 law aed fiestewater inflows arc more critical The pronounced effert ef L-SWE adititions dinung divy comedians. i. Hlestrated io Figure 8 and Table 2. References Ecology and Environment, 2014, Toxkey Pont Mam Caunpeetienstive: Most-Uipeake Monitoring Report Untt 3 & 4 Uprate Project, Piepancd fon Ploniida Posen & Licthtt, Ampust 2044. TETRA TECH Page 7 2 ae aa i on Se oo oe __“Sbiestense sirname 2.5 = 2 - —-— Simulated Water Elevations is M5)q » Measured Water Elevations ve] 4 Se eee a ae —<——— i: Be - | 2 8 os iz Z 0 70.5 Igo: | ki “LS i | EE — Figure 1. Observed and simulated CCS water levels (top) and salinity (bottom) produced by the 50-month calibrated balance model TETRA TECH Page & Salinity (Psu} Nov-45 Fep-46 Figure 2. Predictions of salinity (top) and water level (bottom) for model Seenario A TETRA TECH May-45 Augis Nov-15 Figure 3. Predictions of salinity (top) and water level (bottom) for model Seenario B TETRA TECH Hal WaLa. ‘SIOZ Suns [BUN sausumtes o} pauunase JOU aly SUOAEAQTIA MOL SIR YANCY “PLOT OQUWISAON Uy sugag vORBNuns aAnofperd aqy :c16N - (exoued) q Shienesg pue (det) Y Ofsstesg 1g; aHieqosip ate maueis {i ¢-T s[qaiwoorye GIN XBA “> amery Mw Ss L “ om S ec _ we ah - ee 4 og Ys s ee &, it re , 8 ee ES H i j OL 98eg Page |] 1 - [Normal Weather Scenario - Nov. 2010 to Oct. 2012 | Figure 5. Simulated CCS water levels for predictive Scenario A base case and the constrained L-31E allocations TETRA TECH Page 12 Le 4 [Dry Weather Scenario - Nov. 2013 to Oct. 2014] . | | a= No Action | asses Max 30 MGB ee iax 60 MGB Max 190 MGD May-15 “15 + Figure 6. Simulated CCS water levels for predictive Scenario B base ease and the constrained L-31 5 allovations TETRA TICH Page 13 200 Normal Weather Scenario - Nov. 2010 to Oct. 2012 180 160 e==== No Action seers Max 30 MGD 140 - ———= Max 60 MGD —— Max 100 MGD : Nov-14 Fab-15 May-15 Aug-15 Nov-15 Feb-16 May-16 Aug-16 Nov-16 Figure 7. Simulated CCS salinities for predictive Scenario A base case and the constrained L=31E alloeations TETRA TECH Page 14 200 ; Dry Weather Scenario - Nov. 2013 to Oct. 2014 | 180 .—-[——No Action -—- AY AM | : | : i | Bococg Max 30 MGD 160 741 ~~ Max 60 MeD otf i) ne Mix too MeD | . ; ———— ~, | E “ | ’ / | 40 4. —— j | 1 A a - re - 7 . | B+ en gy a pe eer oo Nov-1a Peb-15 May-45 Aug-15 Nowis Feb-16 May-16 Aug-16 Nov-16 Figure 8. Simulated CCS salinities for predfetive Scenario B base cuse and the constrained L=31£ allocations TETRA TECH CERTIFICATION The work documented in this memorandum has been performed by or under the direct supervision of the undersigned Florida Registered Professional Engineer. Either [ or engineering staff working under my supervision completed all work described herein and | have expertise tn the discipline used in the production of this document. This report has been prepared in accordance with commonly accepted procedures consistent with applicable standards of practice, and is not a guaranty or warranty, either expressed or implied. AUT 7, we F. AN Dg, Mn, SRO GENS eG SRP SCENE Se, SS No 62133 % ; i. 3 * : 23%, stare or jus 22), stare oF {WS van S ene ~ = = = = = Peter F. Andersen Principal Engineer Registered Professional Engineer Florida License No. 62133 pa: O11 /Z01s As required by Sechons 120,56(1), andl 12000003), Fla Sit, the, foleuwing @ notice of the opportunities which may be available for adrrinstratwe being or jaelinahweview witem lee substantial miesesis of a party are delerrnined by an agency. Please nike: tall thes Netitw off Rightsiss matt ielended ts: peowidielegat adidinn No! all the legal proceedings detated below mew be: am applieaille en agpunpelale: sesieny, Vou say wish to consuil an.atiorney regarding your legal rafts: RIGHT TO REQUEST ADMINISTRATIVE HEARING A person whose: substantial interests axe at maw the afffzelind! lay the Siemlth Flowielei Wale Managernery District's (SFWMD or Disitict) acdon has the mghtt iar quest am adinininiative headieg an Wat action pursuant to Sections 120.560 and 120187, He. Stat, Perens. seetiieg ai hearing oni a SUMED decision which does or may affect their substantial intexests stall jie'a petition fie heating with the Distict Clark within 21 days of receipt of written calc off the: dasinion, usicas: ee of (ike folleniing sierter time periods apply 1} within 14 days of the notice’ of compolictaledt ietemt Ne quant or clemy concumentty rexioweed applications for environmental resource: penesits andl wee of RoMeNeign gaiieeesged lands parsaanl io Section 373 427, Fla. Stat; or 2) within 14 days, of sending olf an Adnininialive Calor passat to Subsection 373.119{1), Fla Stat, “Receip! of witten woltice of agency decisithl” means ceceiel of ellieer weilien fitting through mail, electronic mall, or posting tat the SFWMMD has cr iefeml: te tale final ageecy achon, or publication of notice that the SFYWMD thas au ielenslts tim (ale finell agemey aetion, Any pers sive receives wniten notice of a SFWMD. decision, andl fails to fe ai wrillean seeunatt fest hearing within tte tmefame descnbed above waives the right 'yeqpiet 2: necting ann tteaitdeeiaioa. FILING INSTRUCTIONS. The Petition must be filed with the Office, of the Didi Clerik oft the: SFWIMD, Fiiegys wiih thes Dratriat Clark May be made by mail, hand-dekvery, on eran Fillings ny facodbnilin willl ned! he anempied alter Ontober 1, 2014. A petition for administrate hearng, on cer diananentti G2Qmed fled upce meceial during norrnal business hours by the District Clerk af SFWHMD hendlgwantiers «West Palen Beach, Hindi. iny document received by the office of the District Clerk affix SiO) pun sitall dre fier! an of BAND a.m yn line, eat regular business day. Additonal filing instructions are: as. fiotlowa:. Filings by mail must be addressed tm the Offer: of tte Diatret Citent, P.O Bax Qenit,, Yeest Palm Beach, Florida 329416 «Filings by hand-delivery must be delivers to the Office: oft tee Divhiiek Cex. Delimery of a petition to the SFWMD's security desl does matt Comatitate: Sing, Te exneme: propex filing, it will be necessary to request the SPMD: seemily elficer le comtze! the Clewt's office. An employee of the SFWMD'S Cles'¢. office mil mean aval le lees pation, Filings by e-mail must be transmuted! to tes Didhlet Clee; Olfice al clesiathsemed cov. Tne fling date for a document tramsmittied toy efesctivemsie; apa sival ine: tthe: alle: ive: Disticl Clexik. saneives the complete document. A party whe files, 2: dlocmmwent iy exeuail stall (1) sepsesemi thal the: origina! physically signed document welt Le: rettalinen! kay that pomly low the: chxalion olf the panneeding and of any subsequent appeal or subsequent prremediing im that comme and thal te: porky stkall produce it upon the request of other parties. and (2) bie: RESPONSE fon