FPL Remedial Action Annual Status Report 2021

Remedial Action Annual
Status Report
Turkey Point Clean Energy Center
Year 3
November 15, 2021
FPL Turkey Point RAASR Report Year 3
Novem ber 2021 List of Tables
TABLE OF CONTENTS
Section Page
Executive Summary ....................................................................... 1

1 Introduction ....................................................................... 1-1
1.1 Background .......................................................................................................... 1-1
1.2 Scope of the Remedial Action Annual Status Report .......................................... 1-2
1.3 Status of Consent Agreement/Consent Order Implementation ............................ 1-3
2 Recovery Well System Year 3 Operation Summary ............ 2-1
2.1 Hypersaline Extraction/Disposal Operations ....................................................... 2-1
2.2 Recovery Well System Monitoring Results and Hypersaline Groundwater/Salt
Mass Removed ..................................................................................................... 2-3
2.3 Recovery Well System Drawdown Assessment .................................................. 2-5
2.4 Interceptor Ditch Operations................................................................................ 2-6
3 Groundwater Monitoring Data............................................ 3-1
3.1 Groundwater Monitoring ..................................................................................... 3-1
3.2 2021 Year 3 Water Quality Conditions and Trends............................................. 3-2
3.3 Chloride Concentration Contour Maps ................................................................ 3-7
3.4 Groundwater Level Trends .................................................................................. 3-8
4 Continuous Surface Electromagnetic Survey Summary ...... 4-1
4.1 Introduction .......................................................................................................... 4-1
4.2 Approach and Methods ........................................................................................ 4-2
4.2.1 Data Processing ........................................................................................ 4-3
4.2.2 Quality Control of 3D CSEM Data Inversion.......................................... 4-4
4.2.3 Conversion of CSEM Resistivity to Estimated Chloride
Concentrations of Ground Water ............................................................. 4-5
4.2.4 CSEM Method Uncertainty Analysis .................................................... 4-10
4.2.5 Method Minimum Reliable Chloride Concentration ............................. 4-12
4.2.6 Creation of a 3D Chloride Ion Voxel Grid ............................................ 4-13
4.3 Discussion of Findings ....................................................................................... 4-13
4.3.1 Natural Occurrence of Hypersaline Water ............................................. 4-13
4.3.2 Spatial Extent CSEM-Derived Chloride Concentrations ....................... 4-14
4.3.3 Comparison of the 2018 and 2021 CSEM Survey Results .................... 4-15
4.3.4 Volume of the Hypersaline Plume ......................................................... 4-19
4.3.5 Summary of Comparison of 2018 and 2021 CSEM Survey Results ..... 4-20
5 Groundwater Model ............................................................ 5-1
5.1 Model Overview and Evolution ........................................................................... 5-1
5.1.1 Objectives ................................................................................................ 5-1

5.1.2 Model Versions ........................................................................................ 5-2
5.1.3 Sensitivity Analysis with the Version 5 Model ....................................... 5-4
5.1.4 Description of Version 6 Model .............................................................. 5-4
5.2 Model Modifications/Calibration......................................................................... 5-6
5.2.1 Model Calibration Process ....................................................................... 5-6
5.2.2 Model Calibration Results ....................................................................... 5-7
5.3 Remediation Years 5 and 10 Forecast ................................................................. 5-8
5.3.1 Description of Remediation Simulations ................................................. 5-8
5.3.2 Remediation Forecast............................................................................... 5-9
5.3.3 Sensitivity Simulation ............................................................................ 5-10
5.3.4 Model Recommendations ..................................................................... 5-11
6 Summary and Recommendations ....................................... 6-1
6.1 Overall Summary ................................................................................................. 6-1
6.2 Refinements ......................................................................................................... 6-3
6.3 Recommendations ................................................................................................ 6-4
7. References.......................................................................... 7-1
Appendices
A Status of Consent Agreement and Consent Order Activities
B Groundwater Remediation Extraction Well Results
C RWS Analytical Data
D Data Usability Summaries for RWS Analytical Results
E Monitoring Well Trends
F 2018 Baseline CSEM Survey Results
G 2021 Year 3 CESM Survey Results
H Documentation of the Groundwater Flow and Salt Transport Model of the Biscayne
Aquifer (Version 6)
I Year 3 Performance and Compliance Evaluation
LIST OF TABLES
Table Page
2.2-1. RWS Chloride Monitoring Results (mg/L)...................................................................... 2-7
3.1-1. Monitoring Well Baseline and Year 3 Quarterly (Dec 2020 to Sept 2021) Chloride
Concentration Data. ......................................................................................................... 3-9
3.1-2. Monitoring Well Baseline and Year 3 Quarterly (Dec 2020 to Sept 2021) Tritium
Concentration Data. ....................................................................................................... 3-11
3.2-1. Assessment of Analytical Chloride, Tritium, and Automated Salinity Data from
Monitoring Wells. .......................................................................................................... 3-13
4.2-1. Thickness and Depth to Bottom for each Layer in the CSEM Model ........................... 4-21
4.2-2. June 2021 Water Quality Data from TPGW Wells. ...................................................... 4-22
4.2-3. CSEM (AEM) Resistivity Associated with 19,000 mg/L Chloride Listed by
Survey Year ................................................................................................................... 4-23
4.3-1. Correspondence Between TPGW Screened Zones and the CSEM Model Layer ......... 4-24
4.3-2. CSEM-Derived Chloride Volume Estimates of Hypersaline Aquifer Material for
2018 and 2021 by Layer (m3)........................................................................................ 4-25
5.1-1. Summary of Groundwater Model Versions.................................................................... 5-12

5.2-1. Calibration Statistic Summary for the Version 6 Model. ............................................... 5-13
5.2-2. Comparison of CSEM and Model Representations of Remediation Progress. .............. 5-14
A.1-1 Permitting Activity Status ............................................................................................... A-1

A.1-2 Overall Status of 2020-2021 Compliance Activities ....................................................... A-6
A.1-3 Overall Status of Additional Activities.......................................................................... A-10
B.1-1 Weekly Summary of RWS Volume Pumped, Salt Mass Removed, Salinity, and
TDS ..............................................................................................................................B.1-1
B.2-1 Weekly Summary of UICPW-1 and -2 Volume Pumped, Salt Mass Removed,
Salinity, and TDS .........................................................................................................B.2-1
B.4-1 Automated RWS Qualifier Table (Oct 2020 – Sept 2021) ...........................................B.4-1
C.1-1 Summary of RWS Analytical Results from the October 2020 Sampling Event ..........C.1-1
C.1-2 Summary of RWS Analytical Results from the November 2020 Sampling Event ......C.1-1
C.1-3 Summary of RWS Analytical Results from the December 2020 Sampling Event .......C.1-2
C.1-4 Summary of RWS Analytical Results from the January 2021 Sampling Event ...........C.1-2
C.1-5 Summary of RWS Analytical Results from the February 2021 Sampling Event .........C.1-3
C.1-6 Summary of RWS Analytical Results from the March 2021 Sampling Event .............C.1-3
C.1-7 Summary of RWS Analytical Results from the April 2021 Sampling Event ...............C.1-4
C.1-8 Summary of RWS Analytical Results from the May 2021 Sampling Event ................C.1-4
C.1-9 Summary of RWS Analytical Results from the June 2021 Sampling Event ................C.1-5
C.1-10 Summary of RWS Analytical Results from the July 2021Sampling Event..................C.1-5
C.1-11 Summary of RWS Analytical Results from the August 2021 Sampling Event ............C.1-6
C.1-12 Summary of RWS Analytical Results from the September 2021 Sampling Event ......C.1-6
C.3-1 RWS Data Removed from Analysis .............................................................................C.3-1
Novem ber 2021 List of Figures
LIST OF FIGURES
Figure Page
2.1-1. Operation of RWS in Year 3 (Pumping with more than 4 hours of flow in a day). ........ 2-8
2.2-1. RWS Chloride Results (mg/L). ........................................................................................ 2-9
3.1-1. Groundwater Monitoring Wells used in the assessment of the RWS system. ............... 3-14
3.2-1. Summary of Monitoring Well Influences from RWS Operations in Year 3. ................ 3-15
3.2-2. Chloride Values at TPGW-1S, TPGW-2S, and TPGW-15S. ........................................ 3-16
3.3-1. Dry Season Water Level Contour Map (April 1, 2021)................................................. 3-17
3.3-2. Wet Season Water Level Contour Map (September 24, 2021). .................................... 3-18
3.4-1. Groundwater Chloride Contour Map based on 2021 Shallow Monitoring Well
Data and CSEM Horizon Chloride Values .................................................................... 3-19
3.4-2. Groundwater Chloride Contour Map based on 2021 Middle Monitoring Well Data
and CSEM Horizon Chloride Values ............................................................................. 3-20
3.4-3. Groundwater Chloride Contour Map based on 2021 Deep Monitoring Well Data
and CSEM Horizon Chloride Values ............................................................................. 3-21
3.4-4. Comparison of the 2018 Baseline and 2021 Year 3 Inland Extent of Hypersaline
Groundwater (19,000 mg/L Chloride Isochlor) based on Shallow Horizon
Monitoring Well Data .................................................................................................... 3-22
Groundwater (19,000 mg/L Chloride Isochlor) based on Middle Horizon
Groundwater (19,000 mg/L Chloride Isochlor) based on Deep Horizon
4.2-1. 2021 CSEM Survey Area, Flight Lines, and Monitoring Well Locations .................... 4-26
4.2-2. Locations of the Decoupled and Removed Data (Red Lines) Along the CSEM
Flight Lines and the Data Used in the Inversion (Blue Lines). ..................................... 4-27
4.2-3. Relationship Between Borehole Induction Log Resistivity and CSEM Resistivity. ..... 4-28
4.2-4. Comparison of 2021 Formation Water Resistivity versus CSEM Resistivity ............... 4-29
4.2-5. Comparison of 2021 Formation Water Resistivity versus Lab Chloride

Concentration ................................................................................................................. 4-30
4.2-6. AEM Resistivity v. Lab Water Resistivity Plot Including TPGW-22 Data;
Locations of the TPGW-22 Data Identified Relative to the Trend Line. ....................... 4-31
4.2-7. Compliance Area Hypersaline (>19,000 mg/L) Volume Trends................................... 4-32
4.2-8. Comparison of 2021 Lab Chloride and CSEM-Derived Chloride Concentrations ....... 4-32
4.2-9. Monitor Well Screened Zone vs. CSEM Layer ............................................................. 4-33
4.2-10. Normal Probability Plot of 2021 Error Distribution ...................................................... 4-33
4.2-11. Chloride Depth Slice (Layer 12) for 2021 CSEM Survey ............................................. 4-34
4.3-1. Layer 7, 19,000 mg/L Chloride Concentration Contours for 2018 and 2021 ................ 4-35
4.3-2. Layer 9, 19,000 mg/L Chloride Concentration Contours for 2018 and 2021 ................ 4-36
4.3-3. Layer 10, 19,000 mg/L Chloride Concentration Contours for 2018 and 2021 .............. 4-37
4.3-4. Layer 13, 19,000 mg/L Chloride Concentration Contours for 2018 and 2021 .............. 4-38
4.3-5. 2018 and 2021 Hypersaline Volume (> 19,000 mg/L) by Layer ................................... 4-39
4.3-6. Normalized Percent Change: 2018 to 2021 (> 19,000 mg/L) from the Total 2018
Volume........................................................................................................................... 4-39
5.1-1. Model Study Area Overlain by the Active Model Grid; Red Dashed Line
Represents the Location of the Model Cross Section Shown in 5.1-2........................... 5-15
5.1-2. Model Cross Section Showing Model Layering and Hydrogeologic Formations
(Location of Cross Section Shown in 5.1-1). ................................................................. 5-16
5.2-1. Comparison of Model and Observed Changes in Relative Salinity with Time by
Well Between April 2018 and June 2021. ..................................................................... 5-17
5.2-2. Comparison of Model and Observed Total Mass Extracted by the RWS Between
May 2018 and June 2021. .............................................................................................. 5-18
5.2-3. Comparison of Model and Observed Mass Extracted by Well Between May 2018
and June 2021. ............................................................................................................... 5-19
5.3-1a. Location of Initial, Year 5, and Year 10 Hypersaline Interface in Model Layer 4........ 5-20
5.3-1b. Location of Initial, Year 5, and Year 10 Hypersaline Interface in Model Layer 8. ....... 5-21
5.3-1c. Location of Initial, Year 5, and Year 10 Hypersaline Interface in Model Layer 11. ..... 5-22
5.3-2. Predicted 10-yr Capture Zones for Model Layers 4, 8, and 10...................................... 5-23
B.3-1 RWS-1 Salinity and Chloride .........................................................................................B.3-1


B.3-10 RWS-10 Salinity and Chloride .....................................................................................B.3-5
C.4-1 Mann-Kendall Chloride Results for RWS-1 (March 2018 – September 2021) .............C.4-1
C.4-10 Mann-Kendall Chloride Results for RWS-10 (March 2018 – September 2021)........C.4-10
E.1-1 TPGW-1 Analytical Chloride and Automated Salinity (March 2018 – Sept 2021) ..... E.1-1
E.1-2 TPGW-2 Analytical Chloride and Automated Salinity (March 2018 – Sept 2021) ..... E.1-2
E.1-3 TPGW-12 Analytical Chloride and Automated Salinity (March 2018 – Sept 2021) ... E.1-3
E.1-8 TPGW-L3-58 Analytical Chloride (March 2018 – Sept 2021) .................................... E.1-8
E.1-9 TPGW-L5-58 Analytical Chloride (March 2018 – Sept 2021) .................................... E.1-9
E.1-10 TPGW-22 Automated Salinity (February 2021 – September 2021) .......................... E.1-10
E.2-1 TPGW-1 Analytical Tritium (March 2018 – June 2021).............................................. E.2-1

E.2-2 TPGW-2 Analytical Tritium (March 2018 – June 2021).............................................. E.2-2

E.2-3 TPGW-12 Analytical Tritium (March 2018 – June 2021)............................................ E.2-3
E.2-8 TPGW-L3-58 Analytical Tritium (March 2018 – June 2021) ...................................... E.2-8
E.2-9 TPGW-L5-58 Analytical Tritium (March 2018 – June 2021) ...................................... E.2-8
Novem ber 2021 Acronym s and Abbreviations
ACRONYMS AND ABBREVIATIONS
2D/3D 2-dimensional/3-dimensional
AEM aerial electromagnetic
AGF Aqua Geo Frameworks
CA Consent Agreement
CCS Cooling Canal System
CO Consent Order
CSEM Continuous Surface Electromagnetic Mapping
DERM Department of Environmental Resources Management
DIW deep injection well
DUS data usability summary
EDMS Electronic Data Monitoring System
EM electromagnetic
ET evapotranspiration
ETo NEXRAD reference evapotranspiration
FDEP Florida Department of Environmental Protection
FPL Florida Power & Light Company
ft foot/feet
ft/d feet per day
HEM helicopter electromagnetic
HSI saline-hypersaline interface
ID interceptor ditch
IMT MT3DMS
LCI laterally constrained inversion
m meter/meters
MDC Miami-Dade County
mg/L milligrams per liter
mgd million gallons per day
NEXRAD Next Generation Radar
PEST parameter estimation
PSU practical salinity unit
QAPP Quality Assurance Project Plan
R2 coefficient of determination
RAASR Remedial Action Annual Status Report
RAP Remedial Action Plan
RWS recovery well system
SCADA Supervisory Control and Data Acquisition
SCI spatially-constrained inversion
SFWMD South Florida Water Management District
SkyTEM SkyTEM Canada Inc.
SSMP Supplemental Salinity Management Plan
Novem ber 2021 Acronym s and Abbreviations
TDS total dissolved solids

TEM transient electromagnetic
TPGW Turkey Point Groundwater
TPSCW Turkey Point Surface Water Canal
Turkey Point Turkey Point Power Plant
UIC underground injection control
UICPW Underground Injection Control Production Test Well
US 1 U. S. Highway 1
USEPA United States Environmental Protection Agency
USGS United States Geologic Survey
V1,V2 Version 1, Version 2, etc.
VDF variable density flow
FPL Turkey Point RAASR Year 3
Novem ber 2021 Ex ecutive Sum m ary
EXECUTIVE SUMMARY
Florida Power & Light Company employs three types of data and associated analyses (i.e.,
monitoring, electromagnetic surveys, and modeling) to assess progress in meeting the objectives of
the Miami-Dade County Consent Agreement and Florida Department of Environmental Protection
Consent Order. Analyses of data through Year 3 of remediation demonstrate that the net westward
migration of the hypersaline plume has been halted; hypersaline groundwater from the canal
cooling system is being intercepted, captured, contained, and retracted by RWS operations. The
CSEM data shows that the volume of hypersaline water in the compliance area has been reduced by
42% since remediation began in 2018.
The Florida Power & Light Company (FPL) has prepared this Remedial Action Annual Status
Report (RAASR) to document the results of the Year 3 Recovery Well System (RWS) operation,
in compliance with the monitoring and reporting objectives of the Miami-Dade County (MDC)
Consent Agreement (CA) and Florida Department of Environmental Protection (FDEP) Consent
Order (CO). Pursuant to the MDC CA and FDEP CO, the RWS groundwater remediation
system is designed to intercept, capture, contain, and retract hypersaline groundwater located to
the west and north of FPL’s property without creating adverse environmental impacts. The RWS
consists of 10 extraction wells that remove hypersaline water from the Biscayne Aquifer and
dispose of it in the Boulder Zone, more than 3,000 feet below the base of the aquifer, through an
underground injection control (UIC) well system. FPL successfully initiated operations of the
Turkey Point RWS on May 15, 2018.
FPL uses three primary tools to assess remediation progress: groundwater monitoring,
continuous surface electromagnetic (CSEM) survey, and groundwater modeling (i.e., variable
density flow and salt transport model). Data collected from groundwater monitoring wells from
2018 to Year 3 (October 1, 2020, to September 30, 2021) of remediation, in conjunction with the
comparative 2018-2021 CSEM surveys and updated and recalibrated modeling results, were used
collectively to assess changes in the extent of the hypersaline plume. The groundwater model
was also used to estimate future reductions to the hypersaline plume based on 3 years of
remediation model simulations. Data and modeling confirm that the objectives of the CA and
the CO through Year 3 have been met. The following is a summary of the major findings of this
evaluation:
• The Year 3 CSEM results, compared to the 2018 baseline survey results, indicate the
volumetric extent of the hypersaline plume has been reduced by 42% after only 3 years of
RWS operation.
• Since inception of the remediation system, approximately 18.45 billion gallons of

hypersaline groundwater and 7.32 billion pounds of salt have been extracted from the
Biscayne Aquifer. Approximately 5.92 billion gallons of hypersaline water and 2.32
billion pounds of salt were removed during this reporting period.
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Novem ber 2021 Ex ecutive Sum m ary
• In total, 20 of 23 monitoring wells showed a statistically significant declining trend in

one or more parameters (quarterly chloride, quarterly tritium, and weekly average
automated salinity) and at least one or more parameters that were the lowest this
reporting period compared to the baseline and Years 1 and 2.
• Based on CSEM data, the greatest reduction in percent hypersalinity volume is occurring
in the lower portion of the aquifer, while the more significant reductions in groundwater
monitoring well salinities are being measured in the upper portion of the aquifer as the
plume shrinks from top to bottom.
• The Year 3 recalibrated V6 model forecast simulations for Years 5 and 10 show
continuous improvement in hypersaline retraction, with complete retraction achieved in
the upper two-thirds of the aquifer by Year 10. However, complete retraction in the
southern portion of layer 9 and all of layers 10 and 11 are not achieved by Year 10 of the
simulation. Further improvements to the model are needed to reliably represent the
dynamics of the hypersaline plume responses to the RWS in the lower portions of the
aquifer. It is expected that these differences will continue to be reduced as the model is
informed by subsequent annual remediation results.
• Given the significant progress of remediation since initiation of the RWS, FPL does not
propose any changes to the agencies’ approved remediation plan at this time.
In addition to the agency-approved remedial action plan described above, FPL has taken
additional measures to help further the objectives of the CA and CO which include:
• Reactivating the UIC test production wells which extracted up to 3 mgd of hypersaline
groundwater beneath the CCS in the reporting period. Reduction of hypersalinity and
driving head beneath the CCS will increase the capture radius of the RWS to the west of
the RWS, facilitating plume remediation.
• Increasing the CCS freshening allocation from 14 mgd to 30 mgd (34 mgd maximum
monthly allocation) which will allow FPL to maintain seawater salinity levels during
drought periods. By maintaining average annual salinities in the CCS at the CO target of
34 practical salinity units, the formation of hypersaline water in the CCS will be
prevented.
It is important to note that the aquifer system is complex and subject to many external factors
beyond the CCS and RWS; therefore, continued monitoring, model updates, and scientific data
analyses are performed to improve our understanding of the impact of RWS operations in
concert with these other factors. FPL will continue to monitor and evaluate progress in meeting
the requirements of the CA and CO and make recommendations for modifications as needed.
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Novem ber 2021 1 I ntroduction
1 INTRODUCTION
1.1 BACKGROUND
Florida Power & Light Company (FPL) submits this Year 3 Remedial Action Annual Status
Report (RAASR) pursuant to paragraphs 17.b.ii and 17.d.v of the Miami-Dade County (MDC)
Department of Regulatory and Economic Resources’ (DERM) Consent Agreement (CA) and
paragraphs 28, 29.c. and 33 of the Florida Department of Environmental Protection (FDEP)
Consent Order (CO). FPL entered into the CA on October 7, 2015, and the CO on June 20,
2016. FPL agreed to conduct specific actions, including the remediation of hypersaline
groundwater adjacent to the FPL Turkey Point Power Plant (Turkey Point). The specific
objectives of the CA are to demonstrate a statistically valid reduction in the salt mass and
volumetric extent of hypersaline water in groundwater west and north of FPL’s property without
creating adverse environmental impacts and to reduce the rate of, and ultimately arrest, migration
of hypersaline groundwater. The specific hypersaline groundwater remediation objectives of the
CO are to halt the westward migration of the hypersaline plume from the Cooling Canal System
(CCS) within 3 years and reduce the westward extent of the hypersaline plume to the L-31E
canal within 10 years. Hypersaline groundwater, as defined in the CO and CA, is groundwater
with a chloride concentration greater than 19,000 milligrams per liter (mg/L).
FPL initiated the evaluation and design of a recovery well system (RWS) as part of a Remedial
Action Plan (RAP) to intercept, capture, and retract hypersaline groundwater west and north of
the FPL property boundary in accordance with the requirements of the CA and CO. To design
the RWS, FPL developed a groundwater flow and salt transport model, which was extensively
reviewed by the South Florida Water Management District (SFWMD), FDEP, MDC, the United
States Environmental Protection Agency (USEPA), and the University of Florida. The model
and remediation design were ultimately approved by MDC on May 15, 2017. After obtaining all
required environmental and well construction permits, FPL initiated the construction of the
RWS, which included 10 groundwater recovery wells, a conveyance pipeline system, and a deep
injection well (DIW) more than 3,000 feet (ft) below the base of the aquifer. The system was
fully operable on May 15, 2018. FPL submitted an RWS startup report to MDC in October 2018
(FPL 2018a), and quarterly RWS status reports through May 2019 (FPL 2018b, 2019a, 2019b).
These reports provided information on the design and operation of the approved RWS.
Annual reports were then subsequently submitted with the first year of operation (Year 1)
covering the period from May 15, 2018, through May 31, 2019 (FPL 2019c). In Year 2,
collection of the Continuous Surface Electromagnetic (CSEM) survey data was delayed from the
originally scheduled end of May 2020 timeframe until September 2020 due to restrictions on
international travel and health risks associated with the COVID-19 pandemic. This resulted in
the Year 2 RAASR having 16 months of data and being submitted in two parts: groundwater
monitoring data from June 2019 to September 2020 (FPL 2020b) and the Year 2 CSEM survey
and groundwater model (FPL 2021a). This report’s timeframe encompasses October 1, 2020, to
1-1
September 30, 2021; and the 12-month period will be referred to as “Year 3”. This includes the
CSEM survey conducted from June 19 to June 22 with groundwater monitoring trend analyses
covering the year from October 2020 to September 2021. Groundwater model calibration covers
data from August to October of each year using the May-June CSEM survey results and
groundwater monitoring and plant operations data for the reporting period.
Data and accompanying analysis in the Year 1 reports indicated a statistically valid reduction in
salt mass and a 22% reduction in the volumetric extent of hypersaline groundwater west and
north of the FPL property. An additional 12 % in reductions were observed in the second year of
operation which were documented in the Year 2 RAASR (FPL 2021a). In addition to capturing
and reducing the plume extent, particle tracking using the V5 updated model demonstrated that
the RWS creates a hydraulic barrier that intercepts and contains hypersaline groundwater located
beneath the CCS from migrating west and north.
The Year 3 monitoring data show that the net number of monitoring wells with declining trends
in chloride, salinity, and/or tritium have increased in all three depth intervals indicating positive
signs of remediation vertically in the aquifer. In addition, the June 2021 CSEM survey shows a
further reduction of 8% since the previous CSEM survey conducted in September 2020, in the
horizontal and vertical extent of hypersaline plume. This is a positive indication that the
remediation is meeting the objectives of the CA and CO.
1.2 SCOPE OF THE REMEDIAL ACTION ANNUAL STATUS

REPORT
This Year 3 RAASR report includes the following:
• Year 3 RWS operational summary, including analytical results from the RWS wells, salt
mass and hypersaline groundwater removal and operation run times
• Data and assessment from monitoring wells in Year 3 and comparisons to baseline
conditions and/or previous years
• Year 3 annual CSEM survey results with comparisons between the 2021 CSEM survey
and 2018 baseline CESM survey
• An updated RWS groundwater model description and results as well as Year 5 and Year
10 remediation forecast results
• Appendices containing additional supporting information and data used in the report
(Appendices A – H); and
• An evaluation of the RWS progress, after Year 3, in meeting the objectives of the CA
(Appendix I)
1-2
Section 2 of this report provides an overview of RWS operations, and it includes a summary of
automated and analytical data from the recovery wells and the calculation of total salt removed
by the RWS.
Section 3 of the RAASR provides automated data and/or analytical samples from monitoring
well sites (up to 28 wells) located within the areal extent of the hypersaline groundwater plume
collected from October 1, 2020, to September 30, 2021. These data along with Year 1 and Year
2 data were used to evaluate changes and trends in groundwater quality from baseline conditions
from March 2018 through September 2021 (43 months). These results were compared to the
data collected prior to the startup of RWS to identify changes likely related to RWS operations.
Groundwater chloride contour maps for the shallow, middle, and deep monitoring well horizons
augmented with CSEM data are generated for Year 3 and compared with similarly prepared 2018
baseline contour maps to identify changes in the extent of hypersalinity.
Section 4 of the RAASR includes the results of the Year 3 CSEM survey with comparisons to
the baseline 2018 CSEM survey to document changes to the extent and volume of the
hypersaline plume within the CO/CA compliance boundary that have occurred since RWS
operations began.
Section 5 of the RAASR encompasses documentation of the updated, recalibrated Turkey Point
groundwater flow and salt transport model with predictive model runs for Year 5 and Year 10 of
plume remediation.
1.3 STATUS OF CONSENT AGREEMENT/CONSENT ORDER

IMPLEMENTATION
FPL has successfully completed multiple restoration and remediation activities outlined in the MDC
CA and the FDEP CO and has made substantial progress in implementing and completing activities
outlined in the CA and CO.
The RAASR focuses on the RWS and provides the information required by the CA and CO
relevant to the RWS. Both the CA and CO include additional actions beyond the design and
operation of the RWS, and a current status of those actions is included in Appendix A. At the
time of this report, FPL has successfully completed many actions contained in the CA and the
CO. The remaining actions, such as hypersaline plume extraction, salinity and nutrient
management in the CCS, and monitoring, are ongoing, long-term activities. FPL continues to
work cooperatively and effectively with regulators and interested parties to achieve the
objectives of the CA and CO.
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Novem ber 2021 2 Recovery W ell System Year 3 Operation Sum m ary
2 RECOVERY WELL SYSTEM YEAR 3

OPERATION SUMMARY
2.1 HYPERSALINE EXTRACTION/DISPOSAL

OPERATIONS
During the reporting period, FPL’s groundwater remediation actions removed approximately 5.92
billion gallons of groundwater with an average chloride concentration of 27,000 mg/L that contained
2.32 billion pounds of salt. Since inception of the remediation system, approximately 18.45 billion
gallons of groundwater with an average chloride concentration of 27,900 mg/L and 7.32 billion
pounds of salt have been extracted from the Biscayne Aquifer.
FPL operates 10 recovery wells to extract up to 15 million gallons per day (mgd) of hypersaline
groundwater, preferentially along the base of the Biscayne Aquifer. The extraction wells are
cased to the lower high flow zone of the Biscayne Aquifer (FPL 2018a) allowing hypersaline
water to be withdrawn along the base of the plume. As the extraction wells are pumped,
hypersaline groundwater from beneath the CCS and from the plume west and north of the CCS
flows laterally toward the points of withdrawal. As hypersaline water is removed, the plume
shrinks both vertically and laterally with adjacent lower salinity groundwater replacing the area
formerly containing hypersaline groundwater. The extraction of hypersaline groundwater from
the lower extent of the Biscayne Aquifer along the western margin and north of the CCS
accomplishes the objectives listed below:
• Reduces the salt mass and volumetric extent of hypersaline groundwater west and north
of the CCS. The retraction of the hypersaline plume is accomplished primarily by direct
extraction of hypersaline groundwater, which increases the natural seaward groundwater
flow gradient eastward into the RWS capture zone, and secondarily by natural dilution
and dispersion of hypersaline water with the lower salinity waters in the aquifer.
• Creates a hydraulic barrier that intercepts and contains the westward and northward
migration of hypersaline groundwater from the CCS. RWS operations extend the
hydraulic barrier effect of the interceptor ditch (ID) operation in the upper portion of the
Biscayne Aquifer to the base of the aquifer.
• Decreases groundwater salinity and mass beneath the CCS, which reduces the driving
force that contributed to lateral movement away from the CCS and which is a component
of halting the westward migration of hypersaline groundwater from the CCS.
2-1
The hypersaline groundwater is pumped from each

recovery well into a collection system that consists of
an approximately 9-mile-long pipeline that is routed to a
DIW located near the center of the CCS for disposal.
The DIW is a 24-inch-diameter permitted Underground
Injection Control (UIC) non-hazardous Class I
industrial wastewater disposal well (Permit No.
0293962-004-UO/1I) constructed to a depth of 3,230 ft
The deep injection well.
below ground surface into the regionally confined
Boulder Zone. Near the end of Year 1, the permitted
operating capacity of the DIW was increased from 15.59 mgd to 18.64 mgd (permit modification
No. 0293962-005-UO/MM) to accommodate additional remediation flows.
The Consumptive Use Permit from SFWMD authorizes an RWS annual withdrawal allocation of
5,475 million gallons (15 mgd) and a maximum monthly allocation of 465 million gallons from
RWS extraction wells 1 through 10. In early 2020, two UIC production test wells (UICPW-1
and UICPW-2), co-located with the DIW and constructed to the base of the Biscayne Aquifer in
a similar manner as the recovery wells, were activated at a combined rate of approximately 3
mgd to remove hypersaline groundwater from beneath the CCS. This extracted hypersaline
water is disposed in the DIW along with the RWS-extracted hypersaline water, utilizing the DIW
UIC permit’s injection rate limit.
The groundwater extraction wells are controlled by a Supervisory Control and Data Acquisition
(SCADA) system that controls the operation of all wells, has the capability to monitor and
regulate individual well withdrawal rates, and maintains real-time-assigned total system
extraction capacity in the event of individual well fluctuations. This system assists the operators
in maintaining compliance with groundwater withdrawal and disposal permit limits. Flow
pumped from each well is measured by totalizers; the combined flow down the DIW is also
measured by a totalizer. All RWS and DIW flow meters were checked, calibrated, and certified
in May 2021 as part an annual calibration process. During Year 3, individual wells were also
temporarily shut down from a few hours to several days at a time for maintenance purposes (e.g.,
control system upgrades, annual calibration/fall-off test). Individual well shutdowns do not
reduce total volumes extracted because the SCADA system allows for the remaining wells to
make up the loss.
The RWS operated during 98.1% of the reporting period; there were only 7 days (1.9%) when the
system was not operational. The individual wells collectively operated 92.5% of this reporting
period, a slight increase over Year 2 (91.7%). Despite the limited outages, FPL continues to work
towards improving system performance and optimizing individual well performance.
Overall, the RWS operated 98.1% from October 1, 2020, to September 30, 2021, with only 7
days in which the system was non-operational. During four of those days (June 19 – 22), the
entire system was shutdown to reduce electrical noise for the CSEM survey.
Operational run times for each of the RWS wells are shown graphically on Figure 2.1-1. On
average, individual extraction wells operated 92.5% of the time during the reporting period, a
2-2
slight improvement in RWS operational time over the Year 2 performance. All wells had run
times over 90%, except for RWS-1 which operated 78% of the time. RWS-1’s lower run time
was attributable to several issues including wellhead repairs, pump motor failures and long lead
times for repairs. Nonetheless, FPL is continuing to work towards improving the operation of
individual wells and further optimizing system performance.
2.2 RECOVERY WELL SYSTEM MONITORING RESULTS

AND HYPERSALINE GROUNDWATER/SALT MASS
REMOVED
Automated flow, salinity, total dissolved solids (TDS), and water elevation data were
continuously recorded from each RWS extraction well. Water quality samples were collected
from each RWS well monthly and were analyzed for chloride along with field parameters.
Pursuant to execution of CA Amendment 2 on August 20, 2019, quarterly sampling of RWS
nutrients was implemented in September 2019. All sampling/monitoring was conducted in
accordance with the SFWMD-approved FPL Quality Assurance Project Plan (QAPP) (FPL
2013). Water quality data referenced in this RAASR are available in Microsoft Excel tables on
the FPL Turkey Point Electronic Data Monitoring System (EDMS) database (https://www.ptn-
combined-monitoring.com).
Automated data for all 10 RWS wells and the two UICPW wells are shown in Appendix B.
Analytic data are shown in Appendix C including the field parameters and additional analytes
(nutrients), field sampling logs, data qualifiers, and quality assurance samples. Data usability
summary (DUS) reports for the events are provided in Appendix D. Level 4 laboratory reports
from the FPL Central Laboratory can be found on FPL’s EDMS at https://www.ptn-combined-
monitoring.com.
Table 2.2-1 shows a summary of the chloride values for all recovery wells. Chloride values in
most of the recovery wells reflect hypersaline conditions, ranging between 22,000 mg/L and
32,000 mg/L in Year 3 (Figure 2.2-1). The only exception was RWS-1, which ranged between
15,000 mg/L and 20,000 mg/L and was less than 19,000 mg/L for 10 of the 12 months of the
Year 3 reporting period. Although chloride values were generally within the same range as in
Year 2, statistically significant declines in chloride concentrations were observed in all the RWS
wells based on the Mann-Kendall trend analyses using the monthly data since May 2018.
This gradual reduction in salinity of the RWS wells was documented in early modeling of the
RWS (Tetra Tech 2016). The design of the remediation system considers the fluid density of the
plume, which is why the extraction wells are open to the base of the aquifer (i.e., dense
hypersaline groundwater will naturally “sink” toward extraction points along the base of the
aquifer). Accordingly, it is expected that the salinity levels of the extracted water from the RWS
wells will remain elevated for an initial period while the thickness of the plume diminishes. As
the vertical and lateral extent of the hypersaline plume diminishes over long-term operation of
the RWS, larger portions of lower-salinity groundwater from above the extraction horizon mix
with hypersaline water moving laterally along the base of the aquifer resulting in a gradual
lowering of the extracted water salinity.
2-3
Analytical and automated data indicate that all recovery wells have lower average chloride
concentration and salinity values this reporting period compared to the first year of operation,
and most show a gradual decline. The majority of changes since start-up are modest, i.e., RWS-
2, RWS-3, RWS-7, and RWS-10 had both chloride and salinity reductions ranging between 5%
and 10 %, while RWS-4, RWS-5, RWS-6, RWS-8, and RWS-9 had one or both parameters
lower by less than 5%. However, RWS-1, has exhibited greater reduction since the first year of
operation as both average chloride and salinity values are now approximately 20% lower than at
inception. RWS-1 is located approximately 0.8 miles north of the CCS where the plume is thin;
and, as CSEM data shows, the plume has diminished significantly in this area since remediation
began in 2018. Changes to current pumpage operations will be considered when an RWS well
produces saline water that is consistently well below 19,000 mg/L chloride and when data
indicate that CCS hypersaline groundwater within the capture radius of the RWS production well
has been sufficiently remediated to warrant modifying pumpage rates.
Table B.1-1 in Appendix B shows

Volume Salt Avg Salinity/ the weekly volume of groundwater
Reporting
(billion (billion (in PSS-78
Year water pumped from each recovery
gallons) lbs) scale)
well. From October 1, 2020,
1 (12 months) 4.99 2.01 53.6 through September 30, 2021,
2 (16 months) 7.54 2.99 51.8 approximately 5.17 billion gallons
3 (12 months) 5.92 2.32 50.8 of water were extracted from the
Total 18.45 7.32 — RWS and disposed of via the DIW.
Values shown are for total water and salt mass extracted each An additional 0.75 billion gallons of
reporting period and total since startup through through hypersaline groundwater were
September 2021. extracted in Year 3 from the
UICPW wells in the middle of the
CCS (Table B.2-1), for a total of
5.92 billion gallons of hypersaline groundwater removed from the Biscayne aquifer from
October 1, 2020, to September 30, 2021.
Table B.1-1 of Appendix B also shows the automated weekly TDS values and the associated
amount of salt mass removed on a weekly basis for each recovery well, which is calculated in
accordance with paragraph 29.f of the FDEP CO. Salinity data is provided alongside the TDS
values for reference purposes because most people are familiar with salinity. The salt mass
values were based on automated flow and TDS data, and the values were then summed for daily
and weekly salt mass removal. The TDS value is calculated from specific conductance using a
preprogrammed conversion factor of 0.64 (based on empirical data from monitoring wells
TPGW-11D and TPGW-13D from 2010-2016). The equation for salt mass removal is as
follows:
gallons g mg liters
Flow � � x TDS � � x 1000 � � x 3.7854 ( ) 𝑚𝑚𝑚𝑚𝑚𝑚
min L g gallon
Salt mass removed (lbs/day) = mg 𝑥𝑥 1440 (𝑑𝑑𝑑𝑑𝑑𝑑 )
453,592.37 ( )
lbs
The total amount of salt mass removed varies since the pumping rates, run time, and
salinity/TDS differ among wells and/or over time. In Year 3, approximately 2.00 billion pounds
of salt was removed from the RWS wells (Table B.1-1) and 0.32 billion pounds for UICPW-1
2-4
and UICPW-2 (Table B.2-1), resulting in 2.32 billion pounds removed in the reporting year.
Combined with the 5 billion pounds removed in two previous reporting periods, 7.32 billion
pounds of salt have been removed from the Biscayne Aquifer to date.
2.3 RECOVERY WELL SYSTEM DRAWDOWN ASSESSMENT
Water table drawdown from combined RWS and ID operations continue to be negligible
(approximately 0.25 ft) in Year 3, consistent with previous observations.
In the 2019 RAASR (FPL 2019c), FPL determined that the drawdown solely from RWS
pumping was approximately 0.11 ft, and the combined drawdown with the RWS and ID was
approximately 0.25 ft at TPGW-15S which is located approximately 710 ft from RWS-3. The
drawdown in the other depth intervals and at TPGW-1 was of similar magnitude. This amount
of drawdown in the shallow portion of the Biscayne Aquifer is considered negligible; i.e., it is
not considered harmful to wetlands or water resources. The SFWMD regulates drawdown
impacts to wetlands and water resources. SFWMD water use rule criteria limit cumulative
drawdowns beneath seasonally inundated wetlands to 1 ft during 1-in-10-year drought conditions
and maximum authorized withdrawals (SFWMD 2015). Drawdowns that exceed this threshold
are considered harmful to wetlands and water resources. Based on the measured drawdowns of
the combined impacts of the RWS and ID operations, the combined withdrawals are negligible.
Subsequently, in the Year 2 assessment presented in the 2020 Part 1 RAASR (FPL 2020b), FPL
confirmed the above findings of negligible drawdown of 0.10 ft at TPGW-1S and TPGW-15S
from solely RWS operations as there was no time during the reporting period when the RWS was
turned off and the ID pumps were operating.
For Year 3 of operation, and similar to the previous years, several periods were selected when
the RWS wells near TPGW-1 and TPGW-15 were turned off to allow the groundwater to
stabilize when there was little-to-no rainfall that could mask drawdown. Based on a review of
RWS operations, there are two periods when this occurred that coincided with times when ID
pumps were operational:
• March 12–24, 2021, when less than 0.1 inch of rain fell over the CCS, based on Next
Generation Radar (NEXRAD) data
• May 20–31, 2021, when less than 0.1 inch of rain fell over the CCS
The results support previous findings of a combined drawdown of approximately 0.25 ft at

TPGW-1S and TPGW-15S when RWS and ID pumps are both operational. Additionally, the
impact of the RWS operations on L-31E stage levels are not discernible (in the hundredths of a
foot) when the pumps are turned on and off. The changes in water levels at the Turkey Point
surface water canals TPSWC-1, TPSWC-2, and TPSWC-3 are within the range of normal
2-5
fluctuations due to typical minor meteorological influences (e.g., wind), and do not appear to be
a result of RWS operations.
2.4 INTERCEPTOR DITCH OPERATIONS

FPL has reviewed ID operations in conjunction with RWS operations on multiple occasions in
accordance with paragraph 17.a.iii of the CA. FPL has presented these findings at various times,
including in a meeting with DERM on May 16, 2016, in a letter to DERM dated May 23, 2016,
in a presentation to DERM, FDEP, and SFWMD on May 19, 2017, in the RWS Start-Up Report
(FPL 2018a), subsequent quarterly status reports (FPL 2018b, 2019a, 2019b), as well as in FPL’s
Annual Monitoring Reports (FPL 2012, 2016, 2017, 2018c, 2019d, 2020a, 2021b). Based on
these evaluations, modifications to improve the ID function are not warranted at this time due to
the following:
• Continued effectiveness of the ID in restricting westward migration of CCS groundwater

into the upper portion of the Biscayne Aquifer, into wetlands west of the CCS, and into
the L-31E canal
• Continued effectiveness in maintaining the freshwater lens thickness in the Biscayne

Aquifer west of the CCS
• Demonstrated lack of harmful impacts to groundwater levels, wetlands, and other water
resources in the area as further described in the reports referenced above.
2-6
Novem ber 2021 Tables
Table 2.2-1. RWS Chloride Monitoring Results (mg/L).
2020 2021 Average

Current
Previous
Sample Reporting
Year
ID Oct Nov Dec Jan Feb March April May June July Aug Sept Period
(10/1/19-
(10/1/20-
9/30/20)
9/30/21)
RWS-1 17700 17400 16600 16900 20000 18200 18100 19200 18100 15300 17000 16200 18492 17558
RWS-2 24300 24000 25700 26200 25000 24600 25900 24900 22800 22900 21700 23800 25750 24317
RWS-3 27300 26800 27500 28300 28000 26500 27100 27200 25400 24900 27900 26600 27625 26958
RWS-4 29400 29000 30400 30500 31100 28200 30700 27900 28000 27000 30700 30200 29983 29425
RWS-5 29800 29100 30200 31300 28700 28700 28200 29100 27500 26600 30400 30200 29908 29150
RWS-6 28800 28600 29700 30200 28500 27200 29300 27700 27300 26200 29600 28800 29433 28492
RWS-7 29000 28100 29400 30400 27900 27400 29200 26500 26300 25300 28400 28800 29108 28058
RWS-8 29900 29300 30800 32000 29100 29100 28400 28800 27600 26800 29700 29900 29667 29283
RWS-9 28500 27800 29700 30100 27400 28000 27900 26900 26700 26100 29200 28400 29258 28058
RWS-10 25800 25400 26500 27000 24500 25300 26100 24300 24400 23300 26700 25600 26300 25408
UICPW-1 30400 NA 32300 NA NA NA 31200 NA 28900 NA 30400 NA 31400 30640
UICPW-2 NA 29600 NA NA 31300 29500 NA 29100 NA 28900 NA 32400 32100 30133
Notes:
Previous year average for UICPW-1 based on three months of data and for UICPW-2 one month of data.
Key:
NA = not available/no pumping.
2-7
Novem ber 2021 Figures
Figure 2.1-1. Operation of RWS in Year 3 (pumping with more than 4 hours of flow in a day).
2-8
Figure 2.2-1. RWS Chloride Results (mg/L).
2-9
Novem ber 2021 3. Groundw ater M onitoring Data
3 GROUNDWATER MONITORING
DATA
3.1 GROUNDWATER MONITORING

Groundwater monitoring for the assessment of the RWS was performed on well clusters
TPGW-1, TPGW-2, TPGW-4, TPGW-5, TPGW-7, TPGW-12, TPGW-15, TPGW-17, TPGW-
18, and TPGW-19, and on historical individual wells TPGW-L3, TPGW-L5, TPGW-G21, and
TPGW-G28 with samples collected for laboratory analysis in December 2020, March 2021, June
2021, and September 2021 (Figure 3.1-1). These are the same wells that were sampled as part of
the March 2018 baseline and the Years 1 and 2 RAASRs. In this reporting year, an additional
monitoring well installed by MDC, TPGW-22, was added to the monitoring network per the
MDC letter dated September 16, 2020. The well horizons for this 3-cluster well, which were
established by MDC in 2020, are screened at depths independent of consideration of the
protocols previously established for the other FPL monitoring wells (e.g., geophysical and boring
logs used to identify high flow zones, FPL/SFWMD professional geologist consultation). It is
not clear if the screened intervals were placed in high-flow zones. Accordingly, the monitoring
horizons may not be fully comparable with the zones established with the other wells currently in
the network. Data on this well has been collected since February 16, 2021
Samples for all events were collected at discrete screen intervals from the well clusters (i.e.,
shallow, intermediate, and deep intervals), except for the historic L- and G-series, which are
continuously screened wells where samples were collected at 18 ft and 58 ft below the top of
casing. Samples from the groundwater clusters were collected using dedicated tubing and per
the methods outlined in the QAPP (FPL 2013) and FDEP Standard Operating Procedures. To
aid in the assessment of the RWS, field parameters (i.e., temperature, specific conductance,
salinity, density) were measured, and samples from each of the monitoring wells were sent for
laboratory analysis of TDS, chloride, and tritium.
A summary of the Year 3 quarterly chloride and tritium results is included in Tables 3.1-1 and
3.1-2, respectively, along with baseline results for comparison. These results help gauge the
progress of remediation, and the chloride data support the calibration of CSEM survey and
groundwater modeling updates. Time-series graphs showing quarterly chloride and tritium data
from March 2018 (baseline) through September 2021 (end of Year 3 reporting period) are
provided in Appendix E and show the extent of change since RWS start-up. Note that in the first
year of monitoring, chloride samples were collected weekly for the first month of operation and
monthly for the first quarter; data was presented in the 2019 RAASR (FPL 2019c). Chloride
trend analyses conducted on monitoring data collected since RWS start-up were based on
quarterly data (i.e., early weekly/monthly values were not included) to avoid sample frequency
biases.
3-1
In addition to analytical data, all the monitoring wells, except TPGW-L3, TPGW-L5, TPGW-
G21, and TPGW-G28, are equipped with automated probes that record specific conductance,
salinity, and water levels at 1-hour intervals. Depending on when the well was installed,
automated data have been recorded since at least April 2018, with several well clusters
(TPGW-1, TPGW-2, and TPGW-12) having data that extends back to 2010. For the newly
added well site, TPGW-22, automated probes were deployed in February 2021. Appendix E
shows times-series salinity graphs of each automated instrumented well.
Nearly all the analytical and automated data for Year 3 meet the data quality objectives of the
QAPP (FPL 2013). All analytical monitoring well data are usable and exceed the QAPP
completeness goal of 90%. Collectively, automated monitoring well water quality data and
water level data are over 90% complete in Year 3, except for wells TPGW-22S, TPGW-22M,
and TPGW-22D. This well cluster (TPGW-22) has had ongoing issues, mostly with obtaining
valid automated water level readings. The automated water elevations have been
uncharacteristically variable and do not match field readings which are more accurate. The
water level readings at this station are not needed to assess the progress of remediation. FPL has
swapped out probes and cables multiple times, reset reference levels, and is working with the
manufacturer to isolate the cause of the oscillations. FPL will continue troubleshooting efforts to
improve data completeness at TPGW-22. Additional details on qualified analytical and
automated data can be found on FPL’s EDMS at https://www.ptn-combined-monitoring.com.
3.2 2021 YEAR 3 WATER QUALITY CONDITIONS AND

TRENDS
A multi-factored objective data assessment was used to identify meaningful changes in groundwater
quality associated with the ongoing groundwater remediation. The assessment identified 20 of the
23 RWS monitoring wells exhibited statistically significant declining trends in either chlorides, salinity,
and/or tritium since remediation began in May 2018, with three monitoring wells previously
transitioning in Years 1 or 2 from being classified as hypersaline to saline with chloride concentrations
staying below 19,000 mg/L through Year 3. In addition, the majority of the RWS monitoring wells
reported lowest values on record during the reporting period.
To assess trends and influence of RWS operations, a multifactor data screening process was
applied to analytical and automated groundwater monitoring data. This included comparing
Year 3 data against period of record low values and conducting objective statistical trend
analyses (i.e., linear regression and Mann-Kendall trend) for chloride, tritium and salinity.
Assessments for tritium help confirm chloride/salinity trends and indicate a potential precursor to
a declining chloride and salinity trend as lower tritium may indicate a reduction in CCS-sourced
water (Table 3.2-1).
In addition to identification of a new period of record low data values and statistical time series
trend analyses, data were assessed to determine if chloride values declined and remained below
19,000 mg/L in monitoring wells that were hypersaline prior to RWS operation (Table 3.1-1).
Three stations met this criterion: TPGW-1S, TPGW-2S, and TPGW-15S; these are the same
3-2
wells as noted in last year’s RAASR (FPL 2020b). Chloride concentrations in both TPGW-1S
and TPGW-15S dropped below 19,000 mg/L in Year 1 of RWS operation; and they continue to
decline with the lowest chloride concentrations of 5,850 mg/L and 3,440 mg/L, respectively,
recorded during this reporting period. At TPGW-2S, chloride concentrations transitioned below
19,000 mg/L by March 2020, and the lowest concentration over the period of record was
recorded in June 2021 (15,600 mg/L).
There are three other wells (TPGW-17S, TPGW-18M and TPGW-19M) where the chloride
concentrations are hovering around 20,000 mg/L. In the case of TPGW-17S, chloride
concentrations in March for the past two years have dropped below 19,000 mg/L. The data is
showing that the transition from hypersaline to saline is occurring first along the upper edge of
the hypersaline plume as expected, and it is anticipated to transition deeper as the thickness of
fresher groundwater increases in the aquifer as more hypersaline groundwater is removed.
Year 3 data were also reviewed against period-of-record values to determine if new low values
were observed compared to Years 1 and 2, baseline values, and/or to the entire period of record.
For well clusters TPGW-1, TPGW-2, and TPGW-12, and wells TPGW-L3 and TPGW-L5, the
period of record dates to at least mid-2010, TPGW-15 dates to September 2015, TPGW-17 and
TPGW-19 date to January 2018, and TPGW-18 dates to April 2018. The lowest value may not
be indicative of a trend, but it strongly suggests that there are some positive changes occurring
over a broad area and that reductions in concentrations are continuing. This assessment found
the following:
• Chloride – 15 out of 23 (65%) wells had the lowest analytic quarterly chloride
concentration ever recorded during Year 3. This same number of wells had the lowest
analytic chloride concentration this reporting period (Year 3) compared to baseline and
Years 1 and 2.
• Tritium – 14 out of 23 (61%) wells evaluated exhibited the lowest quarterly tritium
value ever recorded in Year 3; and 16 out of 23 (70%) wells evaluated exhibited the
lowest value in Year 3 compared to the baseline and Years 1 and 2. Reduction in tritium
levels can be caused by: 1) replacement of CCS-sourced groundwater with surrounding
less-saline, non-CCS sourced groundwater; 2) inflow of older CCS groundwater,
containing lower levels of depleted tritium, farther away from the CCS that are being
drawn eastward toward the RWS extraction wells; or 3) radioactive decay of in-place
tritium that is no longer being replenished by younger tritiated water from beneath the
CCS.
• Automated Salinity – 12 out of 21 (57%) wells with automated instrumentation

recorded the lowest average weekly salinity value in Year 3 compared to the period of
record; and 15 out of 21 (65%) wells exhibited the lowest average weekly value in Year
3 compared to the baseline and Years 1 and 2. Similar to the chloride results, the number
of stations exhibiting the lowest salinity in Year 3 indicates progress in reducing the
extent of the hypersaline plume.
3-3
In an effort to assess if these lower values were reflective of a trend, analytical data from nine
monitoring sites (23 individual monitoring wells) located within the area containing hypersaline
groundwater from the CCS (well clusters TPGW-1, TPGW-2, TPGW-12, TPGW-15, TPGW-17,
TPGW-18, and TPGW-19, and individual wells TPGW-L3 and TPGW-L5 at the 58-ft sample
depth) were statistically analyzed using the Mann-Kendall trend analyses. These analyses were
conducted with XLStat (Addinsoft Inc., Paris, France) using quarterly chloride and tritium data
from March 2018 through September 2021 to determine whether there were statistically
significant decreasing trends observed since start-up of the RWS. No trend or historical
comparative analysis was conducted on TPGW-22 due to the short period of available
monitoring data from March 2021 to September 2021.
Two key requirements for the appropriate application of the Mann-Kendall trend analysis are
that (1) there are at least four data points in a time series, and (2) the time between samples in a
data set are sufficiently large so that there is no correlation between measurements collected at
different times. Both requirements were met for the analyses. Note that for the analytical data
assessment, only quarterly analytical results were used in the Mann-Kendall analysis to compare
equally spaced time periods and to avoid skewing the results by using RWS start-up data when
more frequent sampling was conducted. For chloride and tritium analytic data, 15 quarterly
samples were available for trend analysis from the March 2018 baseline sampling event through
September 2021. Further reviews of trends were conducted on weekly average automated
salinity data where there are more data points. Since the Mann-Kendall trend analysis
recommends that the time between sampling points be sufficiently large to avoid correlations
between measurements, automated salinity data from a predetermined repeating interval (Meals
et al. 2011) was selected. An average weekly salinity value from midnight each Sunday from the
first full week after March 1, 2018, through the first full week ending before September 30,
2021, was used for the Mann-Kendall automated salinity analysis for 21 wells with automated
data. The results are shown in Table 3.2-1 and discussed below. Wells TPGW-L3-58 and
TPGW-L5-58 are not included since they do not have automated probes.
The fact that: 1) the findings in Year 1, Year 2, and Year 3 consistently show most wells having a
continual declining trend and 2) nearly all wells continue to show lower chloride, salinity, and
tritium concentrations each year, indicate positive progress in meeting the objectives of the CO and
CA.
Mann-Kendall analysis showed that 11 monitoring wells had a statistically significant declining
trend for chloride, while 17 monitoring wells for tritium and 16 monitoring wells for salinity had
statistically significant declining trends. Compared to the previous reporting period, a net of two
additional wells this reporting period showed a declining trend in chloride, while three additional
wells showed a decline in tritium, and one additional well showed a decline in salinity.
3-4
In addition to the Mann-Kendall analysis, the analytic and weekly automated salinity time series
data underwent a linear regression analysis (Statistix v. 10, Analytical Software Inc.,
Tallahassee, Florida) to further identify/confirm wells with statistically significant trends. The
regression analysis identified statistically significant declining trends for the same wells as the
Mann-Kendall analysis, plus one additional well for chloride and tritium (TPGW-15S), since the
start of RWS operations. The regression analysis for automated salinity data confirmed
statistically significant declining trends in 16 monitoring wells. Appendix E.1 shows time-series
graphs for quarterly analytical chloride results and monthly automated salinity data for each well
with linear regression statistics for chloride. Appendix E.2 shows time-series graphs for tritium.
Appendix E.3 shows the output summary from the Mann-Kendall Analysis for chloride, salinity,
and tritium.
A summary of the findings from

the above screening process is
provided in Figure 3.2-1 (see also
callout box to the right) with 20
of the 23 wells showing
statistically significant declining
trends. In Year 3, nine
monitoring wells (TPGW-1S,
TPGW-1M, TPGW-2S, TPGW-
17S, TPGW-17M, TPGW-17D,
TPGW-18S, TPGW-19S, and
TPGW-19M) had statistically
significant declining chloride and
salinity trends from the start of
RWS operations to the end of
September 2021 for both Mann Summary of Wells Influenced by RWS Operations.
Kendall and linear regression
analysis. Eight of those well
(excludes TPGW-1M) had statistically significant declining chloride, salinity trends, and tritium
trends since startup.
Ten other groundwater monitoring wells (TPGW-1D, TPGW-2D, TPGW-12M, TPGW-12D,

TPGW-15S, TPGW-15M, TPGW-18M, TPGW-18D, TPGW-19D, and TPGW-L5-58) showed
statistically significant declining trends in chloride or salinity while TPGW-2M only had a
declining trend in tritium. The remaining three wells showed no statistically significant declining
trends (TPGW-12S, TPGW-15D and TPGW-L3-58), but they exhibited at least one positive
remediation factor, such as lowest recorded value in Year 3 compared to Years 1 and 2. (Note:
TPGW-12S is not classified as a hypersaline well, but hypersaline groundwater occurs at depths
below this well so it is tracked along with co-located deeper hypersaline monitor wells TPGW-
12M and TPGW-12D to assess remediation progress.)
3-5
Although the majority of the wells

showed declining chloride, salinity,
and or tritium trends, three wells
(TPGW-12S, TPGW-15D, and
TPGW-18D) showed an increase in
chloride or salinity, but not for both.
These three wells also had increasing
trends in tritium. Groundwater at
monitoring well TPGW-12S, which is
located near Biscayne Bay north of the
plant, had chloride concentrations
around 19,000 mg/L during the
Mann-Kendall trend analysis showing an increasing number reporting period. Tritium values
of wells with statistically significant declining trends at all during the same period ranged from 22
three depth horizons over time. picocuries per liter (pCi/L) to 95
pCi/L, indicating that this well has
little to no influence from a CCS groundwater pathway. Due to this well’s proximity to
Biscayne Bay and the previously reported effect of Biscayne Bay water quality at this location
(FPL 2017), it is suspected that the trends at TPGW-12S are dominated by Biscayne Bay.
Furthermore, the lowest tritium concentration and the lowest weekly salinity value were reported
at TPGW-12S during this reporting period despite the apparent increasing trend in chloride.
Monitoring well TPGW-15D is situated east of the RWS line of extraction wells and between the
CCS and RWS-3. As a result, operations of the extraction well pull higher concentrated
hypersaline groundwater from beneath the CCS toward and into RWS-3, causing the salinity and
tritium levels in the deep monitoring horizon at TPGW-15D to increase. At the same time, the
RWS well is reducing the vertical extent of the plume, resulting in lowering of salinity in the
upper portion of the Biscayne Aquifer at this site (TPGW-15S). The increasing salinity and
tritium trends were first observed in Year 2 operation of wells TPGW-15D and TPGW-15M.
However, in Year 3, salinity in the intermediate depth well TPGW-15M transitioned from
increasing trends in Year 2 to no trend in Year 3 along with a declining trend in chloride. This is
a possible precursor to gradual reductions in saltwater at intermediate depths at this location.
The significance of the increasing trend in tritium in monitoring well TPGW-L3-58 since 2018 is
questionable at this time. During this reporting period, chloride levels reached an 11-year period
of record low levels in March and June, and show no increasing trend in salinity this year or
during Year 2. Last year, tritium at this station reached a 10-year period of record low and there
was also no trend in the data. The Year 3 trend was heavily influenced by two period of record
high tritium results in June 2021 and September 2021, which are considered anomalous. Future
data will provide additional insights as to the significance of the two out of normal tritium
values.
Lastly, monitoring well TPGW-18D showed an increasing salinity trend, but the chloride data
showed a declining trend similar to Year 2 findings. The trend for salinity was based on an
abbreviated automated data set with usable data starting in October 2018, and it does not reflect
potentially higher values (based on review of chloride and field salinity values) prior to RWS
3-6
start-up and the first part of RWS operation. Thus, the reported salinity trend may not be fully
representative of what is happening at this well because the factors for chloride and tritium all
indicate positive changes since start of RWS operation in May 2018.
With each year of RWS operation, the net number of monitoring wells with declining trends in
chloride, salinity, and/or tritium have increased in all three depth intervals indicating positive signs of
remediation vertically in the aquifer.
In total, 20 of 23 wells showed a declining trend in one or more parameters; and 20 of 23 wells
also showed at least one or more parameters that were the lowest this reporting period compared
to the baseline and Years 1 and 2. The continuation of the establishment of new low values year
after year indicate continued progress in plume remediation. Wells TPGW-15M, TPGW-17M,
TPGW-17D, and TPGW-19S went from no trend at the end of Year 2 to a declining trend at the
end of Year 3 for chloride. A similar finding was made for salinity at wells TPGW-1M,
TPGW-1D and TPGW-19S and tritium at TPGW-19D. With each year of RWS operation, there
is an increase in the net number of monitoring wells that show declining trends in chloride,
salinity, and/or tritium in all three depth intervals.
3.3 CHLORIDE CONCENTRATION CONTOUR MAPS

As requested by MDC, plan view chloride concentration contour maps were created for the
shallow, middle, and deep monitoring horizons using chloride measurements from up to 22
monitoring well sites and nine CSEM chloride measurement sites for the June 2021 CSEM
survey and for comparisons between chloride contour locations in 2018 and 2021. The contours
(isochlors) were objectively generated by Earth Volumetric Studio, a program developed by C
Tech Development Corporation using kriging algorithms. On these maps, the 90th percent
confidence interval was quantified by the kriging software and graphically shown in green
around the location of the monitoring point. The green area shows the distance around a
measured point where the estimated chloride values can be expected to be within 10% of the
measured range of chloride values. The uncertainty in the estimated chloride values increases
rapidly with distance away from the 90th percent confidence area. Isochlors were generated
using the kriging software and contoured for chloride levels of 1,000, 4,000, 9,000, 14,000,
19,000, and 24,000 mg/L (Figures 3.4.1 to 3.4-3). These figures were modified to clip or blank
isochlors that trend into areas not supported by monitoring data or outside of the remediation
compliance area east and south of the CCS.
To reduce some of the uncertainty in spatial data gaps between monitoring wells in the area
between the CCS and Tallahassee Road, which covers the western extent of the hypersaline
plume and CSEM survey data, chloride measurements from the CSEM survey were added for
mapping purposes at nine different areas at shallow, middle, and deep layers. The CSEM
chloride values were added at midpoints between monitoring wells to place the CSEM points
where the monitoring well confidence levels are lowest. The added CSEM locations and their
spatial relationship to the monitoring wells are shown graphically in Figures 3.4-1 through 3.4-6.
3-7
The 2021 chloride contour maps for the shallow, middle, and deep flow zones are shown on
Figures 3.4-1 through 3.4-3 while Figures 3.4-4 through 3.4-6 show comparative positions of the
19,000 mg/L chloride contour for the 2018 baseline condition and the 2021 Year 3 condition
along with associated bands representing the 95% confidence intervals identified in the 2018
(17,000 to 21,000 mg/L) and 2021 (16,000 to 22,000 mg/L) CSEM surveys. Comparison of the
2018 and 2021 maps show the 19,000 mg/L contour line is being retracted closer to the CCS to
varying degrees and locations for all three depth horizons, which is supported by other data
findings reported in this Year 3 RAASR. However, for the intermediate and deep horizons, most
of the locations of the 2018 and 2021 19,000 mg/L chloride isochlor lines fall within the overlap
of the 95% confidence bands for each of the surveys, meaning there is uncertainty regarding the
differences in these locations. Any definitive conclusions in specific areas, however, are
constrained in accuracy by the spatial distances between the existing monitoring wells, the
degree that chloride concentrations change spatially, inconsistencies between the CSEM and
laboratory determination of chloride concentration, the sheer size of the study area, and the
assumptions of hydraulic continuity among all monitoring wells in each layer.
3.4 GROUNDWATER LEVEL TRENDS

Groundwater levels in the area vary seasonally; levels are generally higher during the wet season
and lower during the dry season. However, the groundwater levels can also vary daily and rise
within hours of a rainfall event and, in some wells, change hourly with tides. Despite these
complicating factors, groundwater contouring can provide broad insights into regional gradients,
flow directions, and flow rates. Figures 3.3-1 and 3.3-2 show groundwater elevation contour
maps generated from daily average automated water level data for two separate days (April 1,
2021, representing dry season conditions, and September 24, 2021, representing wet season
conditions) collected from shallow monitoring wells TPGW-1S, TPGW-2S, TPGW-12S,
TPGW-15S, TPGW-17S, TPGW-18S, and TPGW-19S. A single, field water elevation
measurement was used for April 1, 2021, at TPGW-22S (the automated water elevation data was
not available, so a field measurement was recorded on that day). The contours were developed
using manual linear interpolation contouring methods and best professional judgment and
informed by the above-referenced monitoring wells and additional wells (TPGW-10, TPGW-13
and TPGW-21) which are part of other monitoring efforts.
The representative groundwater contour maps for the dry (Figure 3.3-1) and wet (Figure 3.3-2)
seasons indicate a generally eastward flow direction, with a slightly steeper gradient during the
wet season relative to the dry season. These maps are based on measured water levels and are
not adjusted for freshwater head equivalents, so care must be taken to interpret the results.
Because of the variable fluid densities in the Biscayne Aquifer, modeling tools are needed to
more accurately represent groundwater flow rates, direction, and gradients.
Regionally, the groundwater levels during the dry season were higher this year in April 1, 2021,
compared to the dry season in March 31, 2020. The wet season groundwater elevations at inland
areas west of Tallahassee Road were higher this year in September 2021 compared to the wet
season in September 2019. Continuous eastward groundwater gradients with stages equal or
above sea level are generally considered helpful in reducing saltwater intrusion and aid in plume
remediation.
3-8
Table 3.1-1. Monitoring Well Baseline and Year 3 Quarterly (Dec 2020 to Sept 2021)
Chloride Concentration Data.
Baseline
Chloride Year 3 Chloride (mg/L)
Date (mg/L)
03/2018 12/2020 03/2021 06/2021 09/2021
TPGW-1S 19400 5960 6030 12600 5850
TPGW-1M 27700 27000 25200 24900 25100
TPGW-1D 28500 28200 28200 27400 28000
TPGW-2S 24800 17100 15800 15600 16700
TPGW-2M 29500 30100 27500 28300 29800
TPGW-2D 31300 31000 28300 30500 30800
TPGW-4S 2280 932 1420 2490 1930
TPGW-4M 15100 13100 15100 14200 15900
TPGW-4D 14800 14400 15900 14900 16400
TPGW-5S 164 148 156 154 153
TPGW-5M 11700 13000 13400 10300 10800
TPGW-5D 13100 16200 15900 13000 14000
TPGW-7S 37.0 37.6 37.4 37.6 34.6
TPGW-7M 40.0 50.5 39.3 40.2 49.3
TPGW-7D 3970 4360 5000 5590 4980
TPGW-12S 16500 18900 18600 19100 19300
TPGW-12M 20900 22300 21900 21400 22300
TPGW-12D 24000 26400 26400 26600 26700
TPGW-15S 20100 3440 6920 13000 4970
TPGW-15M 30000 26800 24400 27500 27300
TPGW-15D 28800 29600 26200 29000 29700
TPGW-17S 24900 22800 18700 21800 21400
TPGW-17M 29300 29200 25800 27400 26900
TPGW-17D 28600 29200 24300 27400 28000
TPGW-18S 14200 4990 3360 3130 2810
TPGW-18M 25200 23700 23200 20500 23500
TPGW-18D 26400 23800 24100 21000 23900
TPGW-19S 1830 1020 1070 309 1350
TPGW-19M 26000 20900 20300 20100 20800
TPGW-19D 26800 24000 24500 23400 24600
TPGW-22S NA NA 15300 13900 16600
TPGW-22M NA NA 21200 20800 22800
TPGW-22D NA NA 21000 20600 22400
3-9
Baseline
Chloride Year 3 Chloride (mg/L)
Date (mg/L)
03/2018 12/2020 03/2021 06/2021 09/2021
TPGW-L3-18 2030 62.2 163 806 142
TPGW-L3-58 31400 32200 29700 28500 31700
TPGW-L5-18 1290 68.8 186 654 87.7
TPGW-L5-58 29500 29600 26100 25900 30300
TPGW-G21-18 49.2 31.5 47.7 47.5 37.7
TPGW-G21-58 7210 7610 8140 6150 7600
TPGW-G28-18 693 494 471 437 436
TPGW-G28-58 14200 13800 14300 14200 16300
Notes:
Laboratory results are reported with 3 digits although only the first 2 are significant figures.
Key:
NA = not available. TPGW-22 was added to the CA sampling requirements in March 2021.
3-10
Table 3.1-2. Monitoring Well Baseline and Year 3 Quarterly (Dec 2020 to Sept 2021)
Tritium Concentration Data.
Baseline
Tritium Year 3 Tritium (pCi/L)
Date (pCi/L)
03/2018 12/2020 03/2021 06/2021 09/2021
TPGW-1S 954 127 145 347 139
TPGW-1M 2173 1926 1768 2460 2415
TPGW-1D 2307 1788 1912 1945 1887
TPGW-2S 2166 1253 1140 1292 962
TPGW-2M 3130 2539 2404 2781 2486
TPGW-2D 3123 2391 2512 2522 2472
TPGW-4S 17.4 -1.5 14.4 23.0 22.1
TPGW-4M 342 295 300 292 314
TPGW-4D 403 317 366 368 357
TPGW-5S 10.9 -6.0 3.5 4.3 17.0
TPGW-5M 271 227 214 214 180
TPGW-5D 362 349 302 305 301
TPGW-7S 6.6 -11.3 4.4 -6.6 3.0
TPGW-7M 5.2 -5.8 -10.6 17.0 5.5
TPGW-7D 20.3 24.4 38.1 32.3 31.4
TPGW-12S 46.4 22.1 39.8 52.9 95.2
TPGW-12M 931 447 295 238 424
TPGW-12D 1344 1158 1056 1156 1110
TPGW-15S 1555 110 205 617 116
TPGW-15M 2605 4412 4473 4323 4049
TPGW-15D 2509 3064 3097 3108 3066
TPGW-17S 1482 828 721 707 634
TPGW-17M 2518 1737 1679 1537 1429
TPGW-17D 2272 1895 1871 1857 1729
TPGW-18S 550 -0.60 49.0 22.2 25.3
TPGW-18M 1568 1273 1206 1259 1189
TPGW-18D 1600 1296 1319 1288 1252
TPGW-19S 42.9 32.6 40.7 17.1 79.0
TPGW-19M 864 540 548 543 494
TPGW-19D 1082 899 842 829 857
TPGW-22S NA NA 310 347 382
TPGW-22M NA NA 640 686 612
TPGW-22D NA NA 834 864 818
3-11
Baseline
Tritium Year 3 Tritium (pCi/L)
Date (pCi/L)
03/2018 12/2020 03/2021 06/2021 09/2021
TPGW-L3-18 108 183 74.2 86.8 61.2
TPGW-L3-58 3014 3371 2934 4614 4358
TPGW-L5-18 86.7 57.4 61.9 50.5 42.6
TPGW-L5-58 2640 2110 2069 2036 1995
TPGW-G21-18 8.5 2.5 -1.4 8.6 -8.8
TPGW-G21-58 40.0 27.8 37.3 53.5 50.6
TPGW-G28-18 7.3 -9.0 -15.8 4.4 20.4
TPGW-G28-58 333 302 314 308 322
Key:
NA = not available. TPGW-22 was added to the CA sampling requirements in March 2021.
3-12
Table 3.2-1. Assessment of Analytical Chloride, Tritium, and Automated Salinity Data from Monitoring Wells.
Analytical Quarterly Chloride Data Analytical Quarterly Tritium Data Automated Salinity Data
Assessment: Year 3 minimum < Mann-Kendall

Year 3 minimum < Statistically Year 3 minimum < Statistically Statistically
Period of Record low Mann-Kendall Period of Record low Mann-Kendall tritium Period of Record low Year 1, 2 & baseline average weekly
Year 1, 2 & baseline significant declining Year 1, 2 & baseline significant declining significant declining
in Year 3? chloride trend in Year 3? trend in Year 3? minimum weekly automated salinity
minimum chloride? linear regression? minimum tritium? linear regression? linear regression?
salinity? trend
October 2020 – October 2020 – October 2020 –
Weekly Average Weekly March 1,
Start1 – September September 2021 vs. March 1, 2018 – March 1, 2018 – Start1 – September September 2021 vs. March 1, 2018 – March 1, 2018 – June September 2021 vs. March 1, 2018 –
Period of Review: 2 Start1 to September 2018 – September 30,
30, 20212 March 2018 – September 30, 2021 September 30, 2021 30, 20212 March 2018 – September 30, 2021 30, 2021 March 2018 – September 30, 20213
30, 2021 2021
September 2020 September 2020 September 2020
TPGW-1S Yes Yes Yes Decrease Yes Yes Yes Decrease Yes Yes Yes Decrease
TPGW-1M Yes Yes Yes Decrease Yes Yes No No Trend Yes Yes Yes Decrease
TPGW-1D No No No No trend No No Yes Decrease Yes Yes Yes Decrease
TPGW-2M Yes Yes No No trend No No Yes Decrease No No No No Trend
TPGW-2D Yes Yes No No trend No No Yes Decrease No Yes Yes Decrease
TPGW-12S No No No Increase No Yes No No Trend No Yes No No Trend
TPGW-12M No No No No trend No Yes Yes Decrease Yes Yes Yes Decrease
TPGW-12D No No No No trend Yes Yes Yes Decrease No Yes Yes Decrease
TPGW-15S Yes Yes Yes No trend Yes Yes Yes Decrease Yes Yes Yes Decrease
TPGW-15M No No Yes Decrease No No No Increase No No No No Trend
TPGW-15D Yes Yes No No trend No No No Increase No No No Increase
TPGW-17S No No Yes Decrease No No Yes Decrease No No Yes Decrease
TPGW-17M Yes Yes Yes Decrease Yes Yes Yes Decrease Yes Yes Yes Decrease
TPGW-17D Yes Yes Yes Decrease Yes Yes Yes Decrease Yes Yes Yes Decrease
TPGW-18M Yes Yes No No trend Yes Yes Yes Decrease No No Yes Decrease
TPGW-18D Yes Yes Yes Decrease Yes Yes Yes Decrease No No No Increase
TPGW-19M No No Yes Decrease Yes Yes Yes Decrease Yes Yes Yes Decrease
TPGW-19D No No No No trend Yes Yes Yes Decrease Yes Yes Yes Decrease
TPGW-L3-58 Yes Yes No No trend No No No Increase - - - -
TPGW-L5-58 Yes Yes No No trend Yes Yes Yes Decrease - - - -
NOTES:
Wells with cells shaded in gray indicate station has had chloride values >19,000 mg/L.
Wells highlighted in blue have transitioned from hypersaline to saline in Year 1 or year 3 of RWS operation, and chloride concentrations have stayed below 19,000 mg/L.
Text highlighted in green are indications of postive RWS influence.
TPGW-22 came online in February 16, 2021 so insufficient data for comparative and trend analysis.
KEY:
1
Startup period varies: TPGW-1 to -12 started reporting around mid-2010; TPGW-15 started to report in September 2015; TPGW-17 and -19 started on January 10, 2018. TPGW-18 came online April 15, 2018.
2
Period included is first full week in March 2018 and first full week before the end of September 2021.
3
Trend based on abbreviated dataset from October 2018 through September 2021 and therefore does not reflect conditions during baseline or the first part of Year 1 operation.
- No analysis since stations do not have automated instrumentation.
3-13
Figure 3.1-1. Groundwater Monitoring Wells used in the assessment of the RWS system.
3-14
Figure 3.2-1. Summary of Monitoring Well Influences from RWS Operations in Year 3.
3-15
Figure 3.2-2. Chloride Values at TPGW-1S, TPGW-2S, and TPGW-15S.
3-16
Figure 3.3-1. Dry Season Water Level Contour Map (April 1, 2021).
3-17
Figure 3.3-2. Wet Season Water Level Contour Map (September 24, 2021).
3-18
Figure 3.4-1. Groundwater Chloride Contour Map based on 2021 Shallow Monitoring
Well Data and CSEM Horizon Chloride Values.
3-19
Figure 3.4-2. Groundwater Chloride Contour Map based on 2021 Middle Monitoring Well
Data and CSEM Horizon Chloride Values.
3-20
Figure 3.4-3. Groundwater Chloride Contour Map based on 2021 Deep Monitoring Well
Data and CSEM Horizon Chloride Values.
3-21
Figure 3.4-4. Comparison of the 2018 Baseline and 2021 Year 3 Inland Extent of
Hypersaline Groundwater (19,000 mg/L Chloride Isochlor) based on
Shallow Horizon Monitoring Well Data.
3-22
Hypersaline Groundwater (19,000 mg/L Chloride Isochlor) based on Middle
Horizon Monitoring Well Data.
3-23
Hypersaline Groundwater (19,000 mg/L Chloride Isochlor) based on Deep
Horizon Monitoring Well Data.
3-24
Novem ber 2021 4. CSEM Survey Sum m ary
4 CONTINUOUS SURFACE
ELECTROMAGNETIC SURVEY
SUMMARY
Year 3 Continuous Surface Electromagnetic Survey results were compared against the 2018 baseline
survey and indicate net westward migration of the hypersaline plume has been halted and the
volumetric extent has been reduced by 42% after 3 years of RWS extraction.
4.1 INTRODUCTION
Pursuant to the FDEP CO requirements of paragraph 29(a), MDC CA paragraph 17.d.iii, and as
requested in item (3b) in a letter provided to FPL by MDC dated May 15, 2017, FPL conducted
the 2018 baseline CSEM Survey from March 31 through April 6, 2018, using airborne transient
electromagnetic (TEM) methods (described in ENERCON 2016). The purpose of the 2018
baseline survey was to map the hypersaline plume west and north of the FPL property adjacent to
Turkey Point.
Paragraph 17(d)(iii) of the MDC CA, as amended on August 20, 2019, and paragraph 29(b) of
the FDEP CO required a CSEM survey be conducted 30 days after the first year of RWS
operation, which was initiated on May 15, 2018. The first-year CSEM survey was conducted
from May 24 through 26, 2019, and the results were presented in the November 15, 2019,
RAASR. Due to restrictions on international travel and health risks associated with the COVID-
19 pandemic, collection of the Year 2 CSEM survey data was delayed from the originally
scheduled May 2020 timeframe until September 26–27, 2020. The Year 3 CSEM survey was
conducted June 18–22, 2021. Pursuant to paragraph 20.c. of the FDEP CO, FPL is to implement
a remediation project that will halt the westward migration of hypersaline water from the CCS
within 3 years and reduce the westward extent of the hypersaline plume to the L-31E canal
within 10 years without adverse environmental impacts. Paragraph 20.c.iii., states for
determining compliance, the westward migration of the hypersaline plume shall be deemed
halted if the third CSEM survey shows no net increase in hypersaline water volume and no net
westward movement in the leading edge of the hypersaline plume.
Information on data collection, data analysis, error assessment, three-dimensional (3D) mapping
of the distribution of hypersaline chloride concentrations within the Biscayne Aquifer, and
comparisons of the 2021 results with those of the 2018 baseline CSEM survey are provided in
the following sections. Plan and profile color-flood maps of bulk resistivity and CSEM-derived
chloride concentrations for the 2018 and 2021 surveys as well as 3D chloride views are provided
in Appendices F (2018 baseline) and G (September 2021). The Year 3 CSEM data demonstrate
there is no net westward movement in the leading edge of the hypersaline plume. The data also
demonstrate a statistically significant reduction of 42% in the volume of the hypersaline water in
2021 as compared to 2018, with approximately 8% of that total reduction occurring during the 8-
month period between the 2020 Year 2 and 2021 Year 3 surveys. In addition, there is no CCS-
4-1
sourced hypersaline water in layers 1 through 4 (the upper 15 feet of the aquifer) west of the L-
31E canal and north of the FPL property; and there has been a statistically significant net
retraction of the western extent of the CCS-sourced hypersaline plume in layers 5 through 14.
4.2 APPROACH AND METHODS

To collect TEM data, an electrical current is sent through a large loop of wire consisting of
multiple turns which generates an electromagnetic (EM) field. The EM field switches off and on
at rapid rates. When the EM field is generated, it passes into the ground where it dissipates and
decays with time, traveling deeper and spreading wider into the subsurface. The rate of
dissipation is dependent on the electrical properties of the subsurface, which is controlled by the
material composition of the geology including the amount of mineralogical clay, the water
content, the presence of dissolved solids, and the percentage of void space. At the moment the
EM field is turned off, a secondary EM field, which also begins to decay, is generated within the
subsurface. The decaying secondary EM field generates a current in a receiver coil. This current
is measured at several different moments in time (each moment in a time band is called a “time
gate”). From the induced current, the time rate of decay of the magnetic field, “B,” is
determined, thus: dB/dt. When compiled in time, these measurements constitute a “sounding” at
that location. Short time measurements present data on near-surface conditions while longer
timed measurements collect data from greater depths below land surface. Therefore, data on the
decay of the magnetic field over multiple progressively longer time bands break up each
sounding into sequential depth layers. By maintaining a consistent elevation of the
transmitter/receiver (i.e., minor flight elevation variations are adjusted during post processing)
and by using consistent time gates, the thickness of each individual earth layer derived from the
field data is constant across the surveyed area relative to land surface; layer thickness is thinnest
near the surface and deeper layers average data over progressively greater thicknesses.
The CSEM survey area encompasses approximately 30 square miles of mostly wetlands located
to the west and north of the CCS. Figure 4.2-1 presents Turkey Point, the CCS, the survey area,
monitoring well sites used to correlate chloride concentrations, and 2021 CSEM survey flight
lines. The 2021 CSEM survey was performed using the same airborne platform and EM
technique used for the 2018, 2019, and 2020 surveys. A helicopter-borne TEM system,
developed and implemented by SkyTEM Canada, Inc. (SkyTEM), provided nearly continuous
(i.e., one sounding every 6 feet along each flight line) EM survey data within the coverage area.
The geophysical data are collected using TEM sounding equipment suspended from an airborne
platform flown along prescribed flight lines (transects) over the target area. In this application,
the individual transects primarily run from west to east with north-to-south tie lines (as shown in
Figure 4.2-1) and cover the entire region of interest.
The CSEM survey measures bulk resistivity of the ground. For water-saturated materials, bulk
resistivity, or its inverse—bulk conductivity, is principally determined by pore fluid conductivity
and porosity. When porewater chloride ion content is high, bulk conductivity and fluid
conductivity have a nearly 1:1 relationship. This allows the measurement of fluid conductivity
from bulk resistivity or conductivity values obtained from geophysical surveys. Consequently,
the high electrical conductivity of saline groundwater makes it an excellent target for electrical
geophysical methods. Due to lithologic effects, the relationship between bulk electrical
4-2
properties and fluid conductivity must be calibrated with local water quality data. ENERCON
established a relationship for the Biscayne Aquifer near the CCS during performance of the
proof-of-concept 2016 CSEM survey as reported in PTN Cooling Canal System,
Electromagnetic Conductance Geophysical Survey, Draft Final Report, Florida Power and Light
Turkey Point Power Plant (ENERCON 2016). ENERCON supplemented those data with the
2018 baseline CSEM survey and 2018 water quality data as presented in Appendix G of the
Recovery Well System Startup Report (FPL 2018a). The relationship between bulk CSEM
resistivity and laboratory chloride content was developed for the 2021 data sets as described in
Section 4.2.3 of this report. The process conducted by ENERCON to assess the vertical and
horizontal extents of a hypersaline plume in the Biscayne Aquifer in the vicinity of the CCS
follows the USGS method previously conducted for the Biscayne Aquifer (Prinos et al. 2014).
4.2.1 Data Processing
Airborne EM data acquisition was conducted by SkyTEM during June 18–22, 2021. Raw flight
data were transmitted upon landing to Aqua Geo Frameworks, Inc. (AGF) for verification and
quality control. In the event flight data was found to fall outside quality specifications, the flight
segment would be re-flown and verified before proceeding to the next flight segment. This field-
based quality control protocol helped ensure the field data were complete and verified prior to
completing the airborne data acquisition phase of the survey.
Multi-zoned groundwater monitoring wells (Figure 4.2-1 and Table 4-2.2) were sampled during
June 2021, and samples were analyzed for dissolved chloride using procedures and methods
described in the approved Turkey Point Quality Assurance Project Plan (FPL 2013). In addition,
continuous borehole induction logging was conducted by USGS from the deepest monitoring
well at each monitoring well site during March 2021. These data were used in the calibration
and conversion of the CSEM data to chloride concentrations.
Following data acquisition by SkyTEM, the field data were delivered directly to AGF for post-
processing. The AGF-ENERCON team conducted the data processing, interpretations, method
calibration, data correlations with monitoring well induction logs and water quality and prepared
the survey reports. At each sounding along a flight line, the theoretical field response of a
layered earth model was calculated and compared to the actual field data and adjacent data
points. The resistivities of the model layers were adjusted until the differences between the
calculated (model) response and the observed field response were minimized. This spatial
averaging produced laterally constrained inversions (LCIs) and spatially constrained inversions
(SCIs) of the data collected. AGF produced LCIs and SCIs of data collected with the SkyTEM
system during daily flight operations to verify and confirm the functionality of the SkyTEM
system and eliminate drift or calibration concerns. These inversions were conducted using the
Aarhus University Geophysics Workbench software that allowed for editing of the CSEM data to
remove EM couplings (noise) from power lines and pipelines. AGF also provided integration of
continuous borehole induction log data. The inversions were then combined into a 3D electrical
resistivity model of the area which generates calibrated 3D resistivity estimates for the survey
area.
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Table 4.2-1 lists the thicknesses of the 14 CSEM layers that account for the estimated thickness
of the Biscayne Aquifer in the area based on USGS maps (Fish and Stewart 1991) and used for
the 3D inversions. Layer thicknesses increase with depth as CSEM resolution decreases.
Layer 1 has a thickness of about 3 ft, while Layer 14, with a bottom depth of approximately
100 ft, has a thickness of about 13 ft. The data in this CSEM survey were inverted first to two-
dimensional (2D) resistivity sections, then to 3D resistivity versus depth data. Plan and profile
views of the CSEM resistivity model for the 2021 survey are presented in Appendix G,
Attachments 1 and 2.
4.2.2 Quality Control of 3D CSEM Data Inversion
4.2.2.1 Magnetic Field Noise
The raw field data acquired along flight lines are filtered and processed to improve data quality
and reliability. The data are converted to a uniform transmitter coil height above the ground
using the helicopter altimeter data, and a geographic global positioning system location is
determined for each data point. An analysis is made of background EM interference (noise) that
originates from sources such as thunderstorms and power lines and data points that are too noisy
(where the signal is obscured by excessive background interference to a degree the data are
unreliable). Those data are “blanked” and not included in the data inversion. The data are also
examined for “spikes” that occur over pipelines and other conductive objects. The spikes are
also blanked.
Figure 4.2-2 shows the locations of the decoupled and removed data (red lines) along the CSEM
flight lines and the data used in the inversion (blue lines) in the 2021 project area. A noisy area
near the RWS appeared during the 2019 survey. The noise was presumed to be associated with
power delivery and operation of the RWS electric pump motors. As recommended in the 2019
report, the RWS was temporarily shutdown during acquisition of the 2020 and 2021 CSEM data.
The result was a “quieter” EM setting for the 2020 and 2021 surveys that resulted in less filtering
and interpolation than in 2019.
4.2.2.2 Resistivity Model Verification
Continuous surface EM mapping resistivity measurements are in close agreement with USGS induction
(resistivity) logs collected from monitoring wells within the survey boundaries. Combined with the
good calibration with chloride samples from multi-layered monitoring wells, this provides an
independent check on the efficacy of the EM data processing method in estimating groundwater
salinity concentrations within the study area.
Borehole induction logs were conducted by the USGS at each deep well within the TPGW-series
monitoring sites located within the survey area. The induction logs were acquired with a single
frequency EM logging tool that measures the bulk resistivity of the earth materials and pore
fluids up to approximately 1 meter (m) outside the well bore. Details regarding the borehole
induction logging and the result for each site are published in the 2021 Annual Monitoring
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Report (FPL 2021b). The induction logs provide a continuous record of EM electrical resistivity
with depth at each well where the induction log data were obtained.
The layer inversions (i.e., resistivity model) from the CSEM data were compared to the induction
log data to verify that the parameters chosen in the CSEM inversion software were producing
layer resistivities that are in close agreement with the borehole induction logs. Not all wells are
located on flight lines; but several wells are close to or within a few hundred feet of a flight line,
and they were used in the verification. CSEM resistivity sections were compared to induction
logs obtained at wells TPGW-1, TPGW-2, TPGW-4, TPGW-5, TPGW-6, TPGW-12, TPGW-15,
TPGW-17, TPGW-18, TPGW-19 and TPGW-22. Direct comparisons between induction log
resistivity and the 3D CSEM resistivity inversions are shown graphically on the 2D resistivity
profiles provided in Attachment 1 of Appendix G. Where a TPGW monitoring well induction
log was performed near a CSEM flight line profile, the induction log resistivity is shown on the
profile using the same color scale as the CSEM resistivity. The 3D CSEM resistivity inversions
compare very well with the borehole induction logs, indicating that the 3D inversion has
produced estimates of the variation of bulk resistivity versus depth comparable to values
obtained in observation wells.
Another comparison between the CSEM-obtained earth resistivities and borehole induction logs
is shown in Figure 4.2-3. This figure shows the relationship between resistivities from borehole
induction logs and average CSEM resistivities from within 175 m of the borehole and in the
CSEM layers corresponding closest to the borehole depths. The coefficient of determination
(R2) for this relationship is 0.9, indicating a very strong statistical agreement between resistivities
from borehole induction logs and CSEM resistivities.
4.2.3 Conversion of CSEM Resistivity to Estimated Chloride Concentrations

of Ground Water
Quarterly water quality data from the TPGW monitoring wells were used to develop an equation
for conversion of CSEM resistivity to equivalent groundwater chloride concentration
(chlorinity). The calculations utilized the relationship established between the June 2021
laboratory samples for the TPGW wells (Table 4.2-2) and CSEM resistivity. Normal seawater
has a salinity of about 35 practical salinity units (PSU) and will have a chlorinity of about 19,000
mg/L. The CO, paragraph 8, and CA, paragraph 9, delineate 19,000 mg/L of chloride to be the
boundary between normal salinity seawater or brackish waters and hypersaline groundwater.
Chloride concentrations > 19,000 mg/L equate to standard sea water salinity > 34.32 PSU.
The calibration of the CSEM data was conducted using a two-step approach, as presented in
Fitterman and Prinos (2011) and Fitterman et al. (2012). First, a mathematical relationship was
established between CSEM resistivity and the resistivity of groundwater samples from discrete
depth intervals in the TPGW monitoring wells (water resistivity is the inverse of specific
conductance). The mean values of the CSEM resistivities within the 175-m radius (574 ft) of
each corresponding TPGW monitoring well were selected to develop a statistical range in bulk
resistivities for the CSEM model layer that was at an equivalent depth to the screened intervals in
the TPGW wells (FPL RAASR 2 Part 2, Appendix I, 2021).
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The 2021 CSEM data are plotted on a log-log plot with the mean CSEM resistivity on the x-axis
and groundwater laboratory sample resistivity on the y-axis. A regression equation is fitted to
the plot to produce a power function of the form:
(1) 𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 = 0.10867 ∙ (𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅)1.1853
with R2 = 0.84, p < 0.001, r = 0.92 (Figure 4.2-4). R2 is the percent of the variance in the
dependent variable (water resistivity) explained by the variance of the independent variable
(CSEM resistivity); the p value measures the probability that the observed relationship is due to
random variation and r is a measure of the correlation between groundwater resistivity and
CSEM resistivity, with 0.92 indicating a very strong, nearly perfect, correlation. This is an
expected strong relationship, as the groundwater samples and the CSEM resistivity soundings are
taken at similar locations and depth intervals.
The second step in the calibration process is to mathematically relate chloride to water
resistivity. As chloride concentration increases, water resistivity decreases. In groundwater
influenced by seawater, the dominant and most conductive ions are chloride and sodium. The
chloride ion comprises 55% of the total dissolved solids of sea water, so it is expected that there
will be a statistically strong relationship between water resistivity and chloride ions. Again, a
log-log plot is constructed with water resistivity of well samples on the x-axis and chloride
concentration of well samples on the y-axis.
A regression equation is fitted to the data and has the form:
(2) 𝐶𝐶ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 = 2788 ∙ (𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅)−1.1833
with R2 = 0.99, p < 0.001, r > 0.99 (Figure 4.2-5). Equations (1) and (2) are combined to form
an equation that defines chloride concentration as a function of CSEM resistivity. This equation
is then used to convert CSEM 3D inversion resistivity to chloride concentration.
4.2.3.1 CSEM System Response Shift
In the 2019 RAASR report, the AGF-ENERCON team recommended using the regression
equations derived from the 2016 and 2018 data in the two-step process to convert CSEM-
apparent resistivity values to estimated porewater chloride content for all subsequent annual
CSEM surveys. The intent was to use the 2016/2018 data as a baseline for year-to-year
comparisons. An inherent assumption of this approach is that the CSEM instrument response to
a given bulk earth resistivity does not change from survey to survey. The SkyTEM system
firmware and software are frequently updated to reduce noise, improve signal to noise ratios, and
provide better resolution of the resistivity of very shallow layers. While the CSEM instruments
are calibrated at a test site, there may be small changes from year to year in the instrument
response to a given earth resistivity.
In a review by MDC (Arcadis 2020) of the 2019 CSEM survey, it was recommended that a
procedure be implemented to evaluate and reduce the effects of any year-to-year variations in the
instrument response to a given earth resistivity. To determine if there has been any change in
instrument response, an analysis was conducted of the change in the AEM bulk resistivity value
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that correlates to an estimated porewater chloride value of 19,000 mg/L from 2018 to 2021 on
the basis of the regression equations developed for each survey year. The results indicate that
there has been a small and consistent change in instrument response through time (Table 4.2-3).
To eliminate the effects of this shift, and to comply with the MDC recommendation, the AEM
survey results in each survey year are calibrated against water samples from that year. This
procedure produces a unique AEM resistivity to chloride relationship for each survey,
eliminating the consequences of any shift in instrument response that may occur from year to
year.
Accordingly, the AGF-ENERCON team used the 2021 calibration between 2021 CSEM
resistivity and 2021 water quality data to derive estimated porewater chloride values from CSEM
resistivity data. This procedure normalizes the instrument response from year to year, produces
an independent AEM resistivity-to-chloride relationship, and allows a valid 2021 survey year to
2018 baseline comparison of the distribution of porewaters with chloride content >19,000 mg/L.
This procedure also was used for the 2020 survey to address the recommendation provided by
MDC (Arcadis 2020) to initiate a procedure to address any potential year-to-year variation in the
response of the SkyTEM system. As the AEM-derived chloride distribution for each year is
independently calculated, the instrument response drift does not impact the volume calculations
or AEM-derived chloride distribution.
4.2.3.2 Impact of Monitoring Site TPGW-22 on the Calibration Data Set
Introduction of monitoring data not included in the original 2018 baseline monitoring network results
in shifts in the CSEM resistivity versus porewater resistivity regression equation. Such shifts in the
regression affects the hypersaline voxel volume, creating discontinuities between hypersalinity
volumes calculated before and after any new monitoring station is added. To resolve this, annual
volumetric hypersalinity calculations are based on regressions calculated using year-specific porewater
chloride data collected from the original 2018 baseline monitoring network.
During 2021, a new groundwater monitoring site, TPGW-22, installed by MDC in 2019 (Figure
4.2-1), was included in the groundwater remediation monitoring network. The site contains three
monitoring wells with screened intervals corresponding to the upper, middle, and lower flow
zones within the Biscayne Aquifer. Water quality samples were collected from TPGW-22 in
June 2021. The chloride and water resistivity data for TPGW-22 were initially included in the
calibration procedure for deriving the relationship between AEM bulk resistivity and estimated
porewater chloride content. TPGW-22 data were not used in the 2018, 2019 and 2020
calibration data sets, as the well site was not part of the groundwater remediation monitoring
network when those surveys were completed.
It was noted that including the TPGW-22 data in the calibration data set results in a downward
shift in the regression line between AEM resistivity and measured porewater resistivity. The
location of each of the three TPGW-22 data points on the regression plot was below the
regression trend line (Figure 4.2-6) causing a relatively small downward shift in the resulting
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trend line and regression equation. The effect of the small shift is to slightly increase the AEM-
derived chloride concentration at any given point relative to concentrations obtained without the
addition of the TPGW-22 data. In aggregate, these relatively small increases result in a slightly
larger AEM estimated volume of hypersaline groundwater within the compliance area in Year 3
than was calculated for Year 2 based on regressions made without TPGW-22 data (Figure 4.2-7).
There was no new volumetrically significant source of hypersaline water documented during the
reporting period, given the operation of the RWS, the freshening of the CCS, and the measured
salinity levels in the monitoring well network. The calculated increase in the volume of
hypersaline water that occurred when the TPGW-22 data was added to the Year 3 monitoring
network is associated with the shift in the regression equation due to addition of new data points
that were not included in prior year regressions. This explains why the calculated hypersaline
plume volume with TPGW-22 data included does not agree with the trend in calculated volumes
from 2018 through 2020 (Figure 4.2-7).
To understand the shift in the regression trend line and the resulting effect on hypersaline
volumes, it is important to note that the AEM-to-chloride conversion relies primarily on the
following assumptions: (1) chloride is the dominant conductor in the Biscayne Aquifer, and (2)
porosity within the Biscayne is isotropic and homogeneous. Departures from these primary
assumptions are considered geologic noise and result in data departures from the regression trend
line. As the number of monitoring points (wells) included in the regression is relatively small,
additional data points that land off the trend line (due to geologic noise) can move the line and
affect the regression equation. The TPGW monitoring points used in the baseline calibration
data set (used 2018 through 2020) comprise data that are scattered geometrically around the
regression trend line. The locations of these data points tend to fall in the same general areas of
the plot from survey to survey. This suggests that the effect of the geologic noise on the AEM
resistivity to lab chloride is consistent, even as the chloride concentration changes at the
monitoring locations. The vertical position of data points on the regression line plots is
principally determined by porosity, with water quality samples from lower porosity zones
plotting above the regression line and data from higher porosity zones plotting below the
regression line. The regression line in effect yields an average porosity value.
Examination of trend lines for regressions of AEM resistivity against porewater conductivity
with and without TPGW-22 data included (Figures 4.2-6 and 4.2-4) illustrate that the three
porewater resistivity values for TPGW-22 result in data points that all plot below the regression
line, pulling the trend line down slightly. This results in a slight decrease in the AEM bulk
resistivity value that correlates with 19,000 mg/L chloride and increases the calculated volume of
the hypersaline plume. The shift in the regression equation and resulting volume calculation is
artificial, and solely due to the suspected higher than average porosity at the new well location
and the limited data set that gives relative weight to the new data. If, for example, monitor well
TPGW-22 had been present during the baseline acquisition in 2018, the calculated baseline and
Year 1-3 volumes would have been proportionally higher, and the declining trend would mirror
the trend shown in Figure 4.2-7. Consequently, if chloride data from new monitoring wells that
were not included in the 2018 baseline calibration procedure are included in subsequent years’
AEM-monitor well resistivity regressions, the new well data can move the regression line up or
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down in a different manner than a regression based on the original group of monitoring wells,
which makes resulting hypersalinity volumetric comparisons to the 2018 baseline non-sequitur.
To consistently assess the effect of the RWS on AEM estimated hypersaline pore-water volume,
the year-to-year AEM survey calibration must use the same wells as used in the baseline survey.
For this reason, the 2021 survey calibration does not explicitly use TPGW-22 water quality data
for calibration. However, TPGW-22 data are used in comparisons with borehole induction logs,
on vertical profiles of AEM estimated pore-water chloride, and (x, y) contour and color-flood
maps of AEM estimated pore-water chloride values.
Recalculating the regression line between AEM resistivity and porewater resistivity without
including TPGW-22 data results in a volume calculation that confirms the observed trend in
volume from 2018-2020 (Figure 4.2-7). In addition, groundwater monitoring data trends from
September 2020 through September 2021 demonstrate continued salinity reductions that support
the CSEM results produced from the 2021 AEM resistivity/porewater resistivity regression
excluding the TPGW-22 data. Using the wells in the original calibration set as was used in 2018,
2019, and 2020, results in a 42% decrease in the volume of the hypersaline plume compared to
the baseline 2018 volume. Again, this volume closely fits the trend in volume observed from
2018-2020 and aligns with trends observed in physical processes.
4.2.3.3 2021 Chloride Conversion
The plot of CSEM derived chloride concentration (x-axis) and lab-determined chloride
concentration (y-axis) (Figure 4.2-8) produces a regression equation with values of R2 = 0.65, r =
0.81, and p < 0.001. As previously described, R2 is the percent of the variance in the dependent
variable explained by the variance of the independent variable, the p value measures the
probability that the observed relationship is due to random variation, and r measures the strength
of the correlation between CSEM-determined chloride concentration and lab-determined
chloride concentration, with an r of 1.0 being a perfect correlation (i.e., 1:1).
The correspondence of chloride concentration calculated from CSEM resistivity and lab-derived
values of chloride concentration from TPGW wells is graphically illustrated by superimposing
the TPGW well-derived chloride values on CSEM-derived chloride concentration versus depth
profiles and using the same color-coded contour intervals (see Attachment 3 of Appendix G).
On the vertical profiles, the agreement between the CSEM-predicted chloride value and the
chloride value obtained from samples taken from the monitor wells can be visually compared. A
quantitative comparison between CSEM-estimated chloride and lab-determined chloride at
monitor wells is found in Table 4.3-1. Note that the sample area of each CSEM-estimated
chloride value is different in every case from the corresponding sample area of the monitoring
well. Accordingly, at any given point, the correspondence is affected by many factors, including
porosity variations, the location of the screened interval with respect to the assigned CSEM
layer, distance between monitoring well locations and flight lines, and EM noise.
Monitoring well chloride data collected in 2021 are also posted on the 2021 CSEM color-flood
depth layers for comparison (see Appendix G-4). The monitoring well data are posted only on
the applicable CSEM layers where the well-screened interval is contained within the layer.
Monitoring well chloride data for well screens that are at or across a layer interface are posted on
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both layers. Although TPGW-12, TPGW-15, and TPGW-22 chloride values were not included
in the CSEM calibration data set due to excessive EM noise or addition of a new station without
historic data, they are posted on the appropriate CSEM layer maps.
Monitoring well data are from the Biscayne Aquifer only. Consequently, the calibrated equation
relating CSEM resistivity to groundwater chloride concentrations is constrained to the data
collected from the CA/CO monitoring network wells. For this reason, use of this empirically
derived relationship between CSEM resistivity and chloride concentrations should not be applied
to CSEM resistivities from geologic units below the Biscayne Aquifer not monitored under the
CA/CO monitoring network.
4.2.4 CSEM Method Uncertainty Analysis
The CSEM results define the extent of the hypersaline plume both horizontally and vertically.
The 95% confidence interval for the 19,000 mg/L contour for 2021 is about 16,000 mg/L to
22,000 mg/L. This uncertainty in the horizontal plume position is illustrated in Appendix G-6
for each of the CSEM layers. Appendix G-6 shows the 19,000 mg/L contour in 2018 and 2021
and the horizontal range for estimated chloride values between 16,000 and 22,000 mg/L.
However, the estimates of porewater chloride levels derived from CSEM resistivity do not
always match measured chloride levels from discrete monitoring intervals. An important source
of differences between CSEM-estimated chloride and laboratory-determined chloride is the
assumption of constant porosity. The equation that relates CSEM bulk resistivity to chloride
uses the regression equation derived from a plot of CSEM bulk resistivity vs. porewater
resistivity measured at wells. This equation uses the best-fit relationship between CSEM bulk
resistivity and measured porewater chloride levels. In areas with higher-than-average porosity,
the CSEM estimates will overestimate chloride; and in areas with lower-than-average porosity,
the CSEM estimates will underestimate chloride. Variation of porosity horizontally and
vertically introduces some geologic noise to the CSEM chloride estimates. As there are no data
on porosity variation in the survey area, it is difficult to assess the effect of porosity variations on
estimated chloride values. However, this geologic noise is included in the overall assessment of
the error in CSEM chloride estimates. The additional data collection and modeling FPL
performs complements the CSEM survey and, together, provides certainty as to the remedial
action progress.
Another source of noise is the spatial displacement of the water quality samples taken from
discrete intervals in the monitoring wells and the location of the nearest CSEM data on a flight
line. None of the monitoring wells available for calibration of the CSEM data are on a flight
line, all well screens are shorter than the thickness of CSEM layers, and some well screens are
divided by two CSEM layers (see Figure 4.2-9). In addition, the CSEM data average the
instrument’s response to variations in chloride content over distances of a few tens of meters to
over 100 m, while well samples come from small-diameter well screens about 1 m in length. It
can be reasonably assumed that lateral changes in porewater chloride content are smooth and not
abrupt over distances of tens of meters, and the effects of spatial errors are included in the overall
assessment of CSEM estimated chloride values.
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The differences between sample-based and CSEM-based chloride estimates can be quantified.
The resulting apparent error can be used to identify and distinguish changes in chloride levels
attributable to this statistically determined error from those changes that are significantly and
statistically different between survey years. The evaluation of method error and its application in
identifying statistically significant increases or decreases in hypersaline groundwater are
discussed below.
4.2.4.1 Definition of CSEM Survey Error
There is a 95% probability that the actual location of the 19,000 mg/L contour lies within the area
bounded by the 16,000 and 22,000 mg/L contours.
The basis for evaluating the accuracy of the CSEM surveys is the aquifer porewater chloride data
obtained from the TPGW multi-level monitoring wells in and near the CCS. Each well cluster
has three screened intervals corresponding to the upper, middle, and lower flow zones within the
Biscayne Aquifer. Water quality data are available from the TPGW monitoring well system.
For comparison to CSEM data, water quality data closest in time to the CSEM survey were
selected for wells that are close to a CSEM flight line (i.e., there are no wells on a flight line) and
at screen intervals that correspond to CSEM layers. Where the well screen elevations span two
CSEM layers, the average of the two CSEM layers is used for comparison. Figure 4.2-9 shows
relative position and length of monitoring well screen (shown in red) vs. CSEM layers. Wells
located near CSEM flight lines provide 27 water quality samples obtained in 2021 for
comparison to the CSEM data. The water quality samples used in the error analysis are the same
samples used to establish the baseline relationship between CSEM bulk resistivity and porewater
chloride content, as these samples were used to establish the transfer function converting CSEM
resistivity to chloride concentrations, as described in Section 4.2.3.
The CSEM estimates of porewater chloride levels are obtained as described in Section 4.2.3.
The error between CSEM-estimated chloride values and chloride levels obtained from
monitoring wells is defined as the ratio of the CSEM-estimated chloride value to the closest
monitoring well value:
𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 = [𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒 𝑐𝑐ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙]/[𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚 𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤 𝑐𝑐ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙]
A perfect correlation between CSEM estimates of chloride and monitoring well data would have
a value of 1.0. Values > 1.0 indicate an overestimation of chloride by the CSEM data, and
values < 1.0 indicate an underestimation of chloride by the CSEM data.
An alternative error measure is the algebraic difference between the CSEM estimates and the
water quality data:
𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 = [𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒 𝑐𝑐ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙] − [𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚 𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤 𝑐𝑐ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙]
However, the magnitude of this difference error varies with the chloride level, larger for high
chloride values and smaller for low chloride values. The error defined as a ratio maintains the
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relative error between CSEM and water quality data across a wide range of chloride values. It is
similar to a percent error, where:
[𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒 𝑐𝑐ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙]

% 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 = 1 − ∗ 100
[𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚 𝑤𝑤𝑤𝑤𝑤𝑤𝑤𝑤 𝑐𝑐ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙]
4.2.4.2 Distribution of Error
An evaluation was performed to determine whether there is a bias in the distribution of error.
The error distribution is close to a normal distribution (Figure 4.2-10). For 2021, the relative
error of AEM chloride estimates was assessed using 2021 data only to reduce any effects of
changes in instrument response that may have occurred between 2018 and 2021. The mean error
of the 2021 data is 0.89 and the standard error is 0.07. The equation for the 95% confidence
interval is
CI95 = (average error) * (1.96) * (s/n0.5)
where s is the standard error and n is the number of samples. For the 2021 data set, n is 27, and
the 95% confidence interval is 0.154, or about ±15%. As applied to the 19,000 mg/L estimated
chloride value, the 95% confidence interval is ± 2,926 mg/L, or 16,074 mg/L to 21,926 mg/L.
For mapping purposes, these values were rounded to 16,000 to 22,000 mg/L. Plan-view maps
showing the 19,000 mg/L contour and associated area within the 95% confidence interval for the
2018 and 2021 surveys are contained in Appendix G-6. Where the confidence intervals for the
2018 and 2021 19,000 mg/L contours do not overlap, there has been a statistically significant
movement of the 19,000 mg/L contour between 2018 and 2021.
4.2.4.3 Global Error
For 2021, point-to-point comparisons of CSEM estimated chloride values have a 95%
confidence interval of about ±15%. For a CSEM chloride estimate of 19,000 mg/L, a ±15%
interval is from about 16,000 mg/L to 22,000 mg/L. For global estimates, as the error in the
CSEM-estimated porewater chloride content at a point is approximately normally distributed, the
positive and negative errors often cancel. Consequently, for error summations such as the
volume of the hypersaline plume within a layer or the volume of the entire plume, the CSEM
estimate error is related to the mean error of 11%.
4.2.5 Method Minimum Reliable Chloride Concentration
Although the CSEM time-domain resistivity survey at Turkey Point was designed to map the
extent of aquifer porewaters with > 19,000 mg/L chloride concentration, FPL was asked by
MDC to assess the method reliability for portions of the aquifer containing lower salinity
concentrations. The 2018 Recovery Well System Startup Report (FPL 2018a) provides a
discussion on the derivation of the minimum reliable chloride reporting limit. As discussed,
prediction accuracy decreases significantly for porewater chloride ion contents < 10,000 mg/L.
Based on this analysis, the reliable lower limit of the CSEM survey for mapping chloride
concentration within the Biscayne Aquifer is 10,000 mg/L.
4-12
4.2.6 Creation of a 3D Chloride Ion Voxel Grid
A voxel is a 3D grid cell, or “volume element.” The CSEM-derived chloride values were
interpolated to a uniform voxel grid to allow for more effective graphical visualization of the
chloride ion distribution. Each voxel has lateral (x, y) dimensions of 328 ft x 328 ft (100 m x
100 m) and a thickness equivalent to the individual 3D CSEM resistivity layers (Table 4.2-1).
The bottom of layer 14 is at a depth of about 100 ft below land surface (30.3 m). As a result of
the interpolation process to develop the voxel model, CSEM-derived chloride concentrations
near monitoring wells located in “blanked” areas (due to excessive background EM noise) can be
compared to water quality data obtained from those wells and used to assess remediation
progress. For example, TPGW-12 and -15 were excluded from the CSEM bulk resistivity model
because there were no usable data within the radial criterion of 175 m (due to EM noise and
proximity of flight line data). However, these data points are useful for comparison with AEM-
derived chloride in the plan-view and cross-sectional maps.
Depth slices, profile views, and 3D views of the CSEM-derived chloride concentrations are
provided in Appendix G for the 2021 survey. Chloride concentrations between 10,000 mg/L and
19,000 mg/L are shown in shades of gray; chloride concentrations above 19,000 mg/L are shown
with a colored scale, with red representing the highest concentrations (up to ~40,000 mg/L) and
blue representing the lowest concentrations (~19,000 mg/L). An example of a chloride depth
slice is shown in Figure 4.2-11, representing CSEM layer 12.
4.3 DISCUSSION OF FINDINGS
CSEM data demonstrate there is no net westward movement in the leading edge of the hypersaline
plume. The data also demonstrate a statistically significant reduction of 42% in the volume of the
hypersaline Biscayne Aquifer materials in 2021 as compared to 2018. In addition, there is no CCS-
sourced hypersaline water in layers 1 through 4 (upper 15 feet of the aquifer), and there has been a
statistically significant net retraction of the western extent of the CCS-sourced hypersaline plume in
layers 5 through 14.
4.3.1 Natural Occurrence of Hypersaline Water
Two sources of hypersaline groundwater occur within the CSEM survey area adjacent to the
CCS. The predominant source is CCS groundwater while the other source is naturally occurring
non-CCS sourced evaporated seawater that originates in the coastal wetland margins referred to
as the “white zone” and documented by the USGS (Prinos et al. 2014). Salinities exceeding 40
PSU (> 22,000 mg/L) have been documented to occur in coastal waters in western Florida Bay
and Taylor River, well outside of any influences from the CCS (SFNRC 2012), as well as north
and south of the CCS as discussed in Section 4.3.3.2 below. Hypersaline surface water with
fluid densities greater than underlying groundwater will sink into groundwater, resulting in both
shallow and deep expressions of hypersaline groundwater. This is significant to the RWS
remediation assessment as the CA and CO do not require FPL to extract naturally occurring
hypersaline groundwater.
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Fitterman et al. (2012) used helicopter electromagnetic (HEM) surveys to map the distribution of
saline groundwater in the C-111 and Model Lands basin areas of southeast MDC. The HEM
data were presented as resistivity-depth profiles. Comparison of geophysically determined
formation resistivity and salinity concentrations from well samples (Fitterman and Prinos 2011)
shows that formation resistivities of 1 to 2 ohm-m represent geologic units saturated with
groundwater close to or at normal seawater chloride concentrations of 19,000 mg/L. Formation
resistivities with values of 1 ohm-m or less represent hypersaline groundwater with chlorinity >
19,000 mg/L. Fitterman et al.’s (2012) HEM data show that at a depth of approximately 17 ft
(5 m), hypersaline groundwater is present between Card Sound Road and U.S. Highway 1 (US 1)
in a coast-parallel band 4,000 to 6,000 ft wide. The hypersaline groundwater in Fitterman’s
coastal band is not from the CCS as there is no mechanism for dense hypersaline water to travel
westward along the coast for a distance of 4 miles at a depth of only 17 feet. This hypersaline
water corresponds to a coast-parallel zone of lower vegetative density in the coastal wetlands as
viewed from satellite images known as the “white zone.” It is common in coastal wetlands in
this area for evaporation of seawater to form hypersaline groundwater that moves downward into
the sediments under a density gradient (Prinos et al. 2014). Salinities in shallow groundwater in
coastal wetlands can reach 60 to 100 PSU (34,000 to 56,000 mg/L) (Stringer et al. 2010) and will
migrate downward due to the increased density as compared to normal seawater. Close to the
coast, evaporation of seawater can create a wide band of hypersaline groundwater. The HEM
data of Fitterman et al. (2012) suggest that this band of naturally created hypersaline
groundwater extends to the base of the Biscayne Aquifer between Card Sound Road and
southwest past US 1. This band of naturally occurring hypersaline groundwater forms in the
coastal margin both north and south of Turkey Point, as has been documented by surface water
salinity monitoring stations in the Everglades Mitigation Bank and by CSEM surveys.
4.3.2 Spatial Extent CSEM-Derived Chloride Concentrations
Color-flood maps that illustrate the 2D plan-view variation in CSEM-estimated chloride content
of groundwater (i.e., representation of “groundwater contours” utilizing CSEM) for the 2021
survey (Year 3) are provided in Attachment 4 of Appendix G. As discussed in Section 4.2.4.3,
the 95% confidence interval of ±15% provides an estimate of the uncertainty of the location of
the 19,000 mg/L contour. There is a 95% confidence that the 19,000 mg/L contour is within an
area bounded by the 16,000 and 22,000 mg/L contours. It is not possible to illustrate the ±15%
error zone on these maps. This makes interpretation of any differences in the 2018 and 2021
hypersaline boundaries using color-flood maps difficult to assess. Nevertheless, the color-flood
maps provide insights into changes in chloride concentrations over time, which is also helpful in
assessing impacts of the RWS on plume reduction. To better assess changes in the spatial extent
of the hypersaline plume edges, contoured difference maps were created, as described below, to
compare the 2018 baseline results with Year 3 (2021). These comparisons are shown for each
CSEM layer in Appendix G-6, and an example is shown below in Figure 4.3-1.
As noted above, the 19,000 mg/L ±15% “error band” is about 16,000 mg/L to 22,000 mg/L. In
the plan view, this creates a zone of uncertainty with the 19,000 mg/L contour approximately in
the middle of the error band. Where the 2018 uncertainty zone overlaps the 2021 zone, the
separation of the 2018 and 2021 19,000 mg/L contours is not statistically significant at the 95%
confidence interval (i.e., there is a < 5% chance that the separation is due to random error).
4-14
Where the error zones for 2018 and 2021 do not overlap, the separation between the two
contours is statistically significant.
4.3.2.1 Spatial Comparison and Volumetric Determination Methodologies
As described above, the CSEM porewater chloride estimates were interpolated to a voxel grid
with horizontal dimensions of 100 m x 100 m for each grid cell. The thickness of each cell is the
thickness of a given CSEM layer (see Table 4.2-1). The voxels with estimated chloride values
> 19,000 mg/L can be counted and their volumes calculated. This allows an estimate of the
volume of the hypersaline plume (> 19,000 mg/L) to be made. This comparison of hypersaline
volume can be made layer by layer or for the entire thickness of the Biscayne Aquifer. The error
analysis suggests that this summation should have an accuracy of about ±11%.
4.3.3 Comparison of the 2018 and 2021 CSEM Survey Results
4.3.3.1 CSEM Layers and High Flow Zones
Monitoring wells within and surrounding the Plant are constructed into high permeability zones
in the upper, middle, and lower Biscayne Aquifer that are based on review of pilot well lithologic
and borehole geophysical data. As the elevations of the screens in the monitoring wells vary in
depth and the elevations of the CSEM layers are constant across the survey area, the CSEM
layers that represent the upper, middle, and lower flow zones of the Biscayne Aquifer can vary.
Table 4.3-1 lists the TPGW monitoring wells used in the chloride calibration procedure (except
for TPGW-12 and -15 located in areas affected by EM noise), and the CSEM layer associated
with the screened interval. For example, the upper flow zone is present in CSEM layers 6
through 8, the middle flow zone is present in CSEM layers 10 and 11, and the lower flow zone is
present in CSEM layers 12 through 14. The three CSEM layers that include the most upper,
middle, and lower monitoring well intervals are CSEM layers 7, 10, and 13 respectively.
4.3.3.2 Comparison of 2018 and 2021 Plan View Contour Maps of Estimated
Chloride
Plan-view hypersaline boundary (19,000 mg/L) contour maps were prepared for each layer with
the 2018 and 2021 CSEM surveys. These maps are provided in Appendix F-5 and Appendix
G-5, and selected figures are presented at the end of this chapter. The maps also show the voxels
in each layer that have estimated CSEM salinities of 16,000 to 22,000 mg/L for 2021. These
voxels represent the approximate 2021 95% confidence intervals for the 19,000 mg/L contours.
The 95% confidence range for the 2018 data is 17,000 to 21,000 mg/L. Where the 2018 and 2021
confidence intervals do not overlap, the separation between the 2018 and 2021 contours is
statistically significant at the 95% confidence level. Where they do overlap, any movement of
the 2021 19,000 mg/L contour is not statistically significant at the 95% level.
Comparing the 2018 baseline survey to the 2021 survey, the volumetric extent of the plume has
shown a statistically significant reduction of 42% from 2018 to 2021. Overall, the Year 3 survey
shows there are net reductions in the extent and total volume of CCS-sourced hypersaline
groundwater within the compliance area, in all layers compared to the 2018 baseline condition
that existed prior to the RWS startup in May 2018. The survey indicates there is no CCS-
4-15
sourced hypersaline groundwater west of the L-31E canal or north of the FPL property in the
upper 15 feet (4.7 m) of the aquifer in layers 1 – 4. Reductions in layers 1 – 3 and increases in
layers 4 and 5 are caused by non-CCS sourced hypersaline surface water formed by evaporation
of the Hurricane Irma storm surge that has been sinking through the upper Biscayne Aquifer over
the past several years in the northeast corner of the compliance area. Layers 6 – 14 show a
volumetric reduction in CCS-sourced hypersaline groundwater, the amount of which varies from
layer to layer based on several factors, including the degree to which hypersaline groundwater
existed in the layer, the hydraulic characteristics of the layer, the distance between the RWS
wells and the edge of the plume, and the concentration of the plume. Regarding the spatial
extent of the plume, all CSEM layers that identified CCS-sourced hypersaline groundwater
within the compliance area in the 2018 baseline survey have shown net movement of the western
and northern plume extent back toward the CCS/RWS extraction wells. However, there are
localized areas in each layer where the leading edge of the plume does not show statistically
significant retraction toward the CCS; and in some areas, there is small movement to the west or
north. These deviations may be the result of localized heterogeneity in the aquifer that will be
resolved over time as the remediation continues. The 2021 survey also identifies reductions in
chloride concentration within the plume that indicate a progressive reduction of salt mass within
the plume associated with the RWS operations. A more detailed description of changes to
notable layers follows.
Layers 1 through 5: North of CCS
A shallow zone of > 19,000 mg/L aquifer porewater has previously occurred on the north-east
side of Palm Drive and the east side of the L-31E levee. The shallow zone of hypersalinity
layers 1 through 3, was observed in the 2018 baseline survey, which occurred approximately 6
months after the Hurricane Irma storm surge of 3–5 ft inundated the coastal reaches of the Model
Lands basin. Seawater that flooded the coastal wetlands up to the L-31E levee and the Turkey
Point entrance road north of the Plant was trapped and became concentrated via evaporation
during the dry season. This evaporative-sourced hypersaline groundwater was limited to the
upper 7 to 10 ft of the aquifer as shown in 2018 CSEM survey layers 1–3 (2019 RAASR,
Appendix E Figures 1a, 2a, 3a). At the same time, at depths of 20 to 25 feet (CSEM layers 5 and
6), groundwater salinities were lower with chloride levels similar to or less than seawater. From
2018 to 2021, this more-dense, naturally sourced hypersaline groundwater has migrated
downward under a density gradient, from layers 1, 2 and 3 to layers 4 and 5 resulting in
temporary increases in non-CCS sourced hypersaline aquifer volume (see Appendix G-4 and
Table 4.3-2 below). In layers 4 and 5, this shallow hypersaline water is not vertically connected
to the main hypersaline plume at depth just north of the CCS (see Appendix G.3: 2D Chloride
Concentration Profiles). The CSEM data do not show continuity of hypersalinity in the
inundated area with the CCS-sourced hypersaline plume. It is expected that the volume of
hypersaline aquifer material in layers 4 and 5 will decrease as the evaporative sourced plume
sinks to deeper elevations of like salinity. As this northeast portion of the compliance area is
tidally influenced, periodically producing hypersaline waters in the upper layers that migrate
downward, it is expected that the measured hypersaline volumes by layer will continue to change
cyclically. A new monitoring well cluster, TPGW-23, will be constructed on the west side of the
L-31E canal north of TPGW-19. This monitoring site may provide additional data to further
evaluate the source of hypersaline groundwater in this area.
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Layers 1 through 5: South of S-20
Similar to the coastal area north of the CCS, overland infiltration of marine water from Card
Sound has been observed in the coastal wetlands south of the S-20 Discharge Canal and the L-
31E Levee associated with storm surges, king tides. In the 2018 baseline CSEM survey,
hypersaline water was mapped in the upper 3 to 6 feet of sediment (layers 1 and 2) after Irma’s
storm surge flooded the area in November 2017. However, at depths from 6 to 9 feet the salinity
in the area was below 19,000 mg/L Cl. By 2019, some of the hypersaline water from Layers 1
and 2 had moved into layer 3. A similar event occurred in this area in September 2020 when
hypersalinity was identified in layers 1 and 2 south of the S-20 Discharge Canal. In the
subsequent June 2021 survey, the hypersaline groundwater in layers 1 and 2 had dissipated and
increased in layer 3. Storm water releases from the S-20 structure provide freshwater flow that
flush saltwater out of the area during the wet season. Beginning on October 8, 2019, SFWMD
implemented a temporary deviation for the S-20 that increased the headwater stage when storm
water releases were made. As a result of extended dry conditions and the temporary deviation,
no substantive stormwater freshwater releases from the S-20 to this area were made from mid-
September 2018 until mid-November 2020. Reductions to the frequency and duration of S-20
freshwater releases to this area will result in more frequent conditions favoring hypersalinity
which impacts both the groundwater remediation efforts of FPL (by increasing the volume of
non-CCS sourced hypersaline groundwater FPL removes and disposes) and wetlands that are
being impacted by high salinity conditions.
Layer 7
Layer 7 most closely represents the upper flow zone in the Biscayne Aquifer near the CCS (see
Figure 4.3-1). This layer shows a 74% reduction in the volume of hypersaline water between the
2018 and 2021 CSEM surveys (Table 4.3-2) and indicates there is no hypersaline water west of
L-31E for a distance of approximately 1.5 miles south of the northwest corner of the CCS. This
retraction is statistically significant. In the southern portion of the 2021 CSEM survey, there is a
statistically significant eastward retraction of the 19,000 mg/L boundary from 2018 to 2021
ranging between 400 to over 1,200 m (0.25 to 0.75 mile).
Layer 9
Overall, layer 9 (Figure 4.3-2) shows a 40% reduction in the volume of hypersaline water from
2018 to 2021 with much of the discontinuous hypersaline area in the southwest survey area
remaining unchanged while significant retraction has occurred in the area adjacent to the CCS.
Retraction of the contiguous hypersaline plume in the range of 1,300 to 2,600 feet have occurred
west and north of the CCS during the first 3 years of remediation.
A broad area 1 to 2 miles west of TPGW-2 and TPGW-17 shows convoluted discontinuous
patterns of hypersalinity in both the 2018 and 2021 surveys (Figure 4.3-2). As shown by the
underlying 16,000 to 22,000 mg/L confidence intervals, nearly the entire area has estimated
chloride values between 16,000 and 22,000 mg/L, within the range for normal Biscayne Bay
salinity. There is little discernible statistically significant change in the position of the 19,000
mg/L contour between 2018 and 2021, and the contours are convoluted. Lithologic, acoustic
imaging, and seismic borehole logs for TPGW-2 and TPGW-4 (JLA 2010) and data described in
4-17
Fish and Stewart (1991) (E-E geologic cross section) suggest that at least the upper part of layer
9 is a lower permeability sandstone or sandy limestone near the bottom of the Ft. Thompson
Formation. The driller’s log for TPGW-22, shows extensive silty materials. Silty materials have
inherently higher porosities compared to bedrock, which may result in CSEM estimates of
salinity being higher than actual salinity. The possible lower permeability of layer 9 may
contribute to the broad area of slightly hypersaline to slightly less than hypersaline aquifer
porewaters in the SW corner of the survey area. This is supported by the hypersaline CSEM
chloride estimates recorded in the vicinity of well TPGW-4M from 2018 through 2021 while lab
chlorides for this well from September 2010 to present have consistently averaged around 15,000
mg/L.
Layer 10
Layer 10 (Figure 4.3-3) most closely represents the middle flow zone of the Biscayne Aquifer
near the CCS. Overall, the 19,000 mg/L contour shows a 33% statistically significant retraction
of the hypersaline plume toward the RWS between 2018 and 2021. In some areas of layer 10,
the confidence intervals for 2018 and 2021 19,000 mg/L contours overlap; however, the plan
view, color-flood chloride map for 2021 shows large areas of reduced chlorinity since 2018,
indicating additional statistically significant reduction to the hypersaline plume can be expected
in the layer in the near future (see Appendix G-4).
East of TPGW-5, there is a roughly circular area about 1,100 m in diameter that suggests a
statistically significant increase between 2018 and 2021 in an isolated hypersaline zone. This
apparent expansion cannot be currently explained as it is discontinuous with the CCS-sourced
hypersaline groundwater, and there is no known source of hypersaline water. There is also a
small statistically significant area north of TPGW-19 where the plume has expanded. This is
unusual as it occurs proximal to the RWS-1 extraction well and in an area where there are
statistically significant retractions in the northern extent of the plume in layer 12. As part of the
annual data collection and review, FPL will continue to monitor and evaluate these areas.
Layers 11 and 12
Layers 11 and 12 showed a 44% and 39% reduction, respectively, of the hypersaline plume since
2018; and much of the area where hypersaline voxels dropped below the 19,000 mg/L chloride
was over 1 mile west of the CCS. This is significant as it indicates the remediation is working in
the lower portion of the aquifer and at significant distances west of the CCS. Factors that could
be contributing to reductions in chlorinity at distances further west than the capture radii of the
RWS extraction wells include the prevailing east-southeasterly groundwater gradient, the halting
of net westward flow of hypersaline groundwater from beneath the CCS, and reduction in fluid
density west of the CCS (due to decreasing salinity concentrations), thus facilitating increased
inflow of fresher groundwater from the west.
Layer 13
Layer 13 (Figure 4.3-4) most closely represents the lower flow zone within the Biscayne
Aquifer. While there are no large areas in CSEM layer 13 with statistically significant
movement of the hypersaline interface between the 2018 and 2021 CSEM surveys, over most of
4-18
the CSEM survey area, the 2021 19,000 mg/L contour is east of the 2018 contour in layer 13;
however, these shifts are not significant based on the 95% confidence interval. There is an
anomalous area on the south side of the Florida City Canal at the northwest corner of the CSEM
survey. This area is separated from the main hypersaline plume by more than 4,000 m. This
apparent high-chloride area does not appear in CSEM layers 12 or 14. This roughly circular area
is considerably smaller in the 2021 results than in 2018. The source of this elevated salinity area
at depth is not known; however, as part of the annual data collection and review, FPL will
continue to monitor and evaluate these areas.
4.3.4 Volume of the Hypersaline Plume
The voxel volume is primarily rock with approximately 20–30% groundwater. As a result, the voxel
volume of hypersalinity reduced should not be construed as the volume of hypersaline water
“removed” from within the aquifer. The voxel volume represents the volume of the Biscayne Aquifer
that is saturated with aquifer porewaters with chloride values > 19,000 mg/L.
The volume of the hypersaline plume is estimated by summing the volume of the CSEM grid
cells (voxels) that have an estimated chloride level > 19,000 mg/L. This has been done for all 14
layers of the baseline 2018 and Year 3 2021 surveys. It is very important to note that the volume
of each voxel represents aquifer matrix measured by the resistivity survey to be hypersaline and
consists of rock matrix plus aquifer porewater. Most of the voxel volume is rock, while a
smaller percentage (approximately 20–30%) is groundwater. As a result, the reduction in
volume of the Biscayne Aquifer saturated with aquifer porewater with chloride content
> 19,000 mg/L should not be construed as the volume of hypersaline water “removed” from
within the aquifer. Table 4.3-2 lists the measured volume of hypersaline aquifer matrix by layer
for the 2018 and 2021 CSEM surveys and summarizes the volumetric changes by layer from
2018 to 2021, expressed both as a percent change in a layer and as a fraction of the total volume.
The reduction of hypersaline volume between the 2018 baseline survey and the Year 3 survey is
42%. The volumes are illustrated in Figures 4.3-5 and 4.3-6.
As previously described, the CSEM layer geometry increases with depth, and the volumes of the
voxels increase with depth. As a result, care should be exercised when comparing the percent
reduction of the volume of the aquifer saturated with hypersaline water for different layers. The
lower CSEM layers have substantially greater volume per voxel than the shallowest layers. To
illustrate a relative change in hypersaline aquifer volume between the 2018 and 2021 CSEM
surveys, the 2018 and 2021 hypersaline voxel volumes are tabulated and plotted (Table 4.3-2 and
Figure 4.3-5). Figure 4.3-6 clearly illustrates that most of the reduction in hypersaline plume
volume between 2018 and 2021 occurred in layers 6-14, corresponding to the three zones of
preferential flow in the Biscayne Aquifer. Columns 4 and 5 of Table 4.3-2 list the relative
percentage changes in hypersaline voxels by layer between 2018 and 2021 (e.g., positive
percentages indicate an increase from 2018). The changes in layer volumes are reported as
percentages of the 2018 total volume. The sum of the individual layer changes is the 42%
change in the total plume volume from 2018 to 2021. The layer percentages represent the
relative contribution of each layer to the total volume change.
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For the 2021 survey, the error in estimated CSEM chloride at any voxel is about 15%. However,
the error is approximately normally distributed; therefore, when averaged over a large number of
voxels, the error in the number of voxels with estimated CSEM chloride > 19,000 mg/L
approaches the average error of about 11% for the 2021 CSEM chloride estimates. There is a
sufficiently large number of hypersaline voxels in CSEM layers 4-14 for the error in the
estimated volume change in any layer to be close to the mean error.
4.3.5 Summary of Comparison of 2018 and 2021 CSEM Survey Results
There has been a statistically significant reduction in the volume of the hypersaline Biscayne
Aquifer materials of 42% in 2021 as compared to 2018. Of this total reduction in hypersaline
aquifer volume, approximately 8 percent of the reduction occurred during the 8-month period
from the September 2020 Year 2 survey and the June 2021 Year 3 survey indicating robust
plume remediation is continuing west and north of the CCS in all layers and at distances over 1
mile from the CCS. There is no CCS-sourced hypersaline water in layers 1 through 4 (i.e., the
upper 15 feet of the aquifer) west of the L-31E levee. The volume of the hypersaline plume
decreases between 2018 and 2021 in CSEM layers 6 through 14, with the largest volume
decreases in layers 7 through 14. There are areas of statistically significant net retraction of the
western extent of the CCS-sourced hypersaline plume in layers 5 through 14, particularly at the
northern end of the CCS as indicated by the > 19,000 mg/L contour maps. The area of
hypersalinity located in layers 1 and 2 in the northeastern corner of the compliance area in 2018
was not sourced from the CCS and, since 2018, has sunk into layers 3 and 4 by 2019 and into
layers 4 and 5 by 2021. Layers 1, 2, and 3 do not contain porewaters > 19,000 mg/L in 2021.
4-20
Table 4.2-1. Thickness and Depth to Bottom for each Layer in the CSEM Model.
4-21
Table 4.2-2. June 2021 Water Quality Data from TPGW Wells.
Well Screen (from Top of Casing) Specific

From (ft) To (ft) From (m) To (m) Salinity Conductance
Well ID Cl (mg/L) (PSU) (µS/cm)
TPGW-1S 32.00 34.00 9.76 10.37 12,600 20.78 33,274
TPGW-1M 52.10 54.10 15.88 16.49 24,900 42.55 63,139
TPGW-1D 85.30 89.30 26.01 27.23 27,400 47.98 70,124
TPGW-2S 27.97 31.97 8.53 9.75 15,600 29.88 46,165
TPGW-2M 53.88 55.88 16.43 17.04 28,300 50.70 73,590
TPGW-2D 88.79 90.79 27.07 27.68 30,500 52.16 75,429
TPGW-4S 23.20 25.20 7.07 7.68 2,490 4.72 8,502
TPGW-4M 38.10 43.10 11.62 13.14 14,200 25.89 40,546
TPGW-4D 61.60 65.60 18.78 20.00 14,900 26.65 41,612
TPGW-5S 28.60 32.60 8.72 9.94 154 0.47 951
TPGW-5M 49.30 54.30 15.03 16.55 10,300 18.94 30,562
TPGW-5D 67.00 72.00 20.43 21.95 13,000 23.19 36,714
TPGW-6S 25.09 27.09 7.65 8.26 328 0.85 1,691
TPGW-6M 51.61 55.61 15.73 16.95 8,500 14.36 23,717
TPGW-6D 84.70 88.70 25.82 27.04 8,870 15.23 25,049
TPGW-12S 25.19 27.19 7.68 8.29 19,100 32.50 49,750
TPGW-12M 59.21 63.21 18.05 19.27 21,400 35.66 54,029
TPGW-12D 93.24 97.24 28.43 29.65 26,600 45.09 66,420
TPGW-15S 24.32 29.32 7.41 8.94 13,000 24.30 38,437
TPGW-15M 44.39 49.39 13.53 15.06 27,500 48.55 71,005
TPGW-15D 79.31 84.31 24.18 25.70 29,000 49.55 72,294
TPGW-17S 32.11 37.11 9.79 11.31 21,800 36.71 55,433
TPGW-17M 49.95 54.95 15.23 16.75 27,400 45.68 67,221
TPGW-17D 86.81 91.81 26.47 27.99 27,400 47.69 69,750
TPGW-18S 35.25 40.25 10.75 12.27 3,130 5.55 9,882
TPGW-18M 63.25 68.25 19.28 20.81 20,500 39.04 58,502
TPGW-18D 84.27 91.27 25.69 27.83 21,000 39.78 59,482
TPGW-19S 27.37 31.37 8.34 9.56 309 0.77 1,540
TPGW-19M 48.39 52.39 14.75 15.97 20,100 33.98 51,751
TPGW-19D 84.35 89.35 25.72 27.24 23,400 40.85 60,918
TPGW-22S 29.00 32.00 8.84 9.75 13,900 26.76 41,752
TPGW-22M 54.00 57.00 16.46 17.37 20,800 36.43 54,992
TPGW-22D 69.00 72.00 21.03 21.94 20,600 37.33 56,191
4-22
Table 4.2-3. CSEM (AEM) Resistivity Associated with 19,000 mg/L Chloride
Listed by Survey Year.
Survey Year 19,000 CSEM Resistivity (ohm-m)
2021 1.656
2020 1.719
2019 1.879
2018 1.968
4-23
Table 4.3-1. Correspondence Between TPGW Screened Zones and the CSEM
Model Layer.
Depth Below Land Surface CSEM

2021 Chloride CSEM Model Groundwater Estimated
Well ID From (m) To (m) From (ft) To (ft) (mg/L) Layer Model Layer Layer Cl (mg/L)
TPGW-4S 7.1 7.7 23.2 25.2 2,490 6 4 3,921
TPGW-15S 7.4 8.9 24.3 29.3 13,000 6 5 5,290*
TPGW-6S 7.6 8.3 25.1 27.1 328 6 5 231
TPGW-12S 7.7 8.3 25.2 27.2 19,100 6 5 18,850*
TPGW-2S 8.5 9.7 28.0 32.0 15,600 7 4 18,158
TPGW-5S 8.7 9.9 28.6 32.6 154 7 5 197
TPGW-6S 7.6 8.3 25.1 27.1 328 7 5 231
TPGW-15S 7.4 8.9 24.3 29.3 13,000 7 5 5,290*
TPGW-19S 8.3 9.6 27.4 31.4 309 7 5 1,556
TPGW-22S 8.8 9.8 29.0 32.0 13,900 7 5 7,812
TPGW-1S 9.8 10.4 32.0 34.0 12,600 8 5 11,287
TPGW-17S 9.8 11.3 32.1 37.1 21,800 8 5 25,832
TPGW-18S 10.7 12.3 35.3 40.2 3,130 8 4 11,387
TPGW-4M 11.6 13.1 38.1 43.1 14,200 9 8 19,933
TPGW-18S 10.7 12.3 35.3 40.2 3,130 9 4 11,387
TPGW-15M 13.5 15.1 44.4 49.4 27,500 9 8 12,380*
TPGW-15M 13.5 15.1 44.4 49.4 27,500 10 8 12,380*
TPGW-1M 15.9 16.5 52.1 54.1 24,900 10 8 21,224
TPGW-2M 16.4 17.0 53.9 55.9 28,300 10 8 19,091
TPGW-5M 15.0 16.6 49.3 54.3 10,300 10 8 10,482
TPGW-6M 15.7 17.0 51.6 55.6 8,500 10 9 3,274
TPGW-17M 15.2 16.8 50.0 55.0 27,400 10 8 35,987
TPGW-19M 14.8 16.0 48.4 52.4 20,100 10 7 26,387
TPGW-22M 16.5 17.4 54.0 57.0 20,800 10 9 15,780
TPGW-12M 18.1 19.3 59.2 63.2 21,400 11 8 14,938*
TPGW-4D 18.8 20.0 61.6 65.6 14,900 11 11 7,378
TPGW-22M 16.5 17.4 54.0 57.0 20,800 11 9 15,780
TPGW-4D 18.8 20.0 61.6 65.6 14,900 12 11 7,378
TPGW-5D 20.4 22.0 67.0 72.0 13,000 12 10 6,245
TPGW-18M 19.3 20.8 63.3 68.3 20,500 12 7 18,308
TPGW-22D 21.0 21.9 69.0 72.0 20,600 12 10 10,089
TPGW-15D 24.2 25.7 79.3 84.3 29,000 13 11 34,301*
TPGW-1D 26.0 27.2 85.3 89.3 27,400 13 11 17,937
TPGW-6D 25.8 27.0 84.7 88.7 8,870 13 11 7,252
TPGW-18D 25.7 27.8 84.3 91.3 21,000 13 10 19,420
TPGW-19D 25.7 27.2 84.3 89.4 23,400 13 11 8,635
TPGW-1D 26.0 27.2 85.3 89.3 27,400 14 11 17,937
TPGW-2D 27.1 27.7 88.8 90.8 30,500 14 10 32,066
TPGW-6D 25.8 27.0 84.7 88.7 8,870 14 11 7,252
TPGW-17D 26.5 28.0 86.8 91.8 27,400 14 11 38,002
TPGW-18D 25.7 27.8 84.3 91.3 21,000 14 10 19,420
TPGW-19D 25.7 27.2 84.3 89.4 23,400 14 11 8,635
TPGW-12D 28.4 29.6 93.2 97.2 26,600 14 11 17,310*
Note: CSEM-derived Cl produced from average resistivity within 175 m radius of borehole and converted to Cl using regression equation.
* TPGW-12 and TPGW-15 CSEM estimated chloride data are calculated from nearest Cl voxel due to locations within EM noise.
4-24
Table 4.3-2. CSEM-Derived Chloride Volume Estimates of Hypersaline Aquifer

Material for 2018 and 2021 by Layer (m3).
% Volumetric Change
2018 Volume 2021 Volume % Volumetric Change by Layer (2018 to 2021)
> 19,000 > 19,000 by Layer (2018 to Relative to Total
Layer mg/L (m3) mg/L (m3) 2021) Volume
1 1,920,000 0 -100 -0.4
2 2,026,000 0 -100 -0.4
3 1,587,000 0 -100 -0.3
4 858,000 2,106,000 145 0.3
5 2,595,500 3,799,000 46 0.3
6 12,672,000 5,024,000 -60 -2
7 22,896,000 5,850,000 -74 -4
8 20,480,000 4,920,000 -76 -3
9 33,770,000 20,306,000 -40 -3
10 68,281,500 45,668,000 -33 -5
11 92,840,000 51,837,500 -44 -9
12 89,822,500 54,442,500 -39 -8
13 63,181,000 40,568,500 -36 -5
14 43,050,000 28,665,000 -33 -3
Totals: 455,979,500 263,186,500 -42 -42
4-25
Figure 4.2-1. 2021 CSEM Survey Area, Flight Lines, and Monitoring Well Locations.
4-26
Figure 4.2-2. Locations of the Decoupled and Removed Data (Red Lines) Along
the CSEM Flight Lines and the Data Used in the Inversion (Blue Lines).
4-27
Figure 4.2-3. Relationship Between Borehole Induction Log Resistivity and CSEM
Resistivity.
4-28
Figure 4.2-4. Comparison of 2021 Formation Water Resistivity versus CSEM

Resistivity.
4-29
Figure 4.2-5. Comparison of 2021 Formation Water Resistivity versus Lab

Chloride Concentration.
4-30
Figure 4.2-6. AEM Resistivity v. Lab Water Resistivity Plot Including TPGW-22
Data; Locations of the TPGW-22 Data Identified Relative to the Trend Line.
4-31
Figure 4.2-7. Compliance Area Hypersaline (>19,000 mg/L) Volume Trends.
Figure 4.2-8. Comparison of 2021 Lab Chloride and CSEM-Derived Chloride

Concentrations.
4-32
Figure 4.2-9. Monitor Well Screened Zone vs. CSEM Layer.
Figure 4.2-10. Normal Probability Plot of 2021 Error Distribution.
4-33
Figure 4.2-11. Chloride Depth Slice (Layer 12) for 2021 CSEM Survey.
4-34
Figure 4.3-1. Layer 7, 19,000 mg/L Chloride Concentration Contours for 2018 and
2021.
4-35
2021.
4-36
2021.
4-37
2021.
4-38
Figure 4.3-5. 2018 and 2021 Hypersaline Volume (> 19,000 mg/L) by Layer.
Figure 4.3-6. Normalized Percent Change: 2018 to 2021 (> 19,000 mg/L) from the
Total 2018 Volume.
4-39
Novem ber 2021 5. Groundw ater M odel
5 GROUNDWATER MODEL
Data from the 2018 baseline, Year 1, Year 2, and Year 3 remediation operations have been
incorporated into and assessed in the Turkey Point variable density dependent solute transport
model in order to provide a better understanding of the hydrogeology of the study area, improve
the model’s ability as a predictive tool, and contribute to the assessment of the progress of
remediation and predictions of future performance.
5.1 MODEL OVERVIEW AND EVOLUTION

5.1.1 Objectives
The variable density flow and salt transport model developed for the design of the FPL Turkey
Point Biscayne Aquifer RWS has been updated and recalibrated using data from the third year of
operation of the RWS. This update represents the sixth version of the model. The objectives of
the update and recalibration are to reduce the uncertainty of the model and to improve alignment
of model responses with new and existing monitoring data in order to assess progress of the
ongoing hypersaline groundwater plume remediation effort.
These objectives are accomplished by the following actions:
1. Incorporation of the salinity, water level, and mass extraction data (RWS and UIC test
production wells) collected during the third year of the recovery system operation
2. Derivation of monthly salinity change targets at groundwater monitoring locations to

further emphasize the accurate simulation of the movement of the saline and hypersaline
interfaces during the third year of RWS operation
3. Incorporation of changes from baseline to Year 3 CSEM salinity targets into the model
calibration process
4. Incorporation of vertical hydraulic conductivity profiles derived from inspection of drill

cores and geophysical logs as templates for specification of depth-discrete hydraulic
conductivity values
5. Performance of a sensitivity analysis with the model used in the prior RAASR (version 5)
to investigate the causes of that model’s inability to align the saline-hypersaline interface
(HSI) position along the base of the aquifer and retract the HSI in a manner consistent
with monitor well and CSEM data (details of this sensitivity evaluation is described in
Chapter 4 of Appendix H)
6. Incorporation of the results of the sensitivity analysis into the version 6 model calibration
process.
5-1
The revised model was then used to predict RWS impacts on the degree of CCS sourced
hypersaline groundwater plume retraction at Year 5 and 10 of remediation.
5.1.2 Model Versions
The current groundwater flow and salt transport model documented in Appendix H is the sixth
version (V6) of a 3D regional model developed by FPL to evaluate various projects associated
with the Turkey Point CCS. The model has undergone an evolutionary process as the objectives
of the modeling changed, as progressively more data are added, and as the knowledge base
expands. The evolution of the model to date is summarized below.
FPL originally developed a 3D SEAWAT (Langevin et al. 2008) model wherein density varied
as a function of both salinity and temperature (Tetra Tech 2016a). This model is referred to as
the V1 model. The purpose of the V1 model was to evaluate alternatives for compliance with the
MDC CA and FDEP CO that required stopping the westward migration of hypersaline water and
retracting hypersaline water north and west of the CCS to the western extent of the FPL property.
This model simulated the period from pre-development (early 1940’s) through 2015 and was
calibrated by manual methods to measured water levels and salinity. The model was used to
evaluate a number of potential groundwater remediation projects that resulted in the selection of
Alternative 3D, which involved implementing a groundwater recovery well system (RWS)
consisting of 10 wells screened to the base of the Biscayne Aquifer capable of pumping 15 mgd
of hypersaline groundwater that would be disposed in an existing UIC DIW. Subsequent to the
submittal of the model and the preferred alternative to the agencies on May 16, 2016, FPL was
requested to make several additions/improvements that are documented in a Tetra Tech report
(2016a). These changes included responding to regulatory comments; primarily regarding
boundary conditions (Tetra Tech 2016b); the use of an automated calibration tool (i.e., Parameter
Estimation [PEST]) (Tetra Tech 2016c); and introducing a spatially variable hydraulic
conductivity field into certain model layers (Tetra Tech 2017). Although these changes are
considered to improve the model, they did not alter the choice or design of Alternative 3D.
Based on these model changes and the associated results related to the retraction of the
hypersaline plume, the model’s application in the assessment of Alternative 3D were
conditionally approved by MDC on September 29, 2016.
In addition to using the model to aid in the evaluation and selection of a groundwater
remediation system, FPL was directed by FDEP to use the variable density 3D groundwater
model developed under the MDC CA to allocate relative contributions of the CCS and other
entities or factors on the movement of the saltwater interface. In order to conduct this
evaluation, several modifications, including many of those required by MDC, were necessary.
FPL subsequently updated and recalibrated the V1 model to create the V2 model for
apportionment of contributing factors on migration of saltwater in the region. Primary changes
that were incorporated into the V2 model were: (1) inclusion of data from MDC wellfields; (2)
land use time series, including rock mines and quarries; (3) separate simulation of recharge and
evapotranspiration processes rather than a single net recharge term; (4) inclusion of detailed
precipitation data; (5) consideration and incorporation of canal and surface water methodology
from the Hughes and White (2014) model; and (6) incorporation of sea level rise. The model
was recalibrated using PEST, and this resulted in a 34% reduction in the overall error statistic
5-2
that was used as the objective function in calibrating the model. The V2 model was used to
simulate alternate historical scenarios and assess their individual and cumulative impacts on the
saltwater interface as required under the FDEP CO. The results of the V2 modeling were
presented to FDEP on June 19, 2019.
In compliance with paragraph 17.b.ii., and 17.d.11 of the MDC CA, as amended on August 20,
2019, FPL updated the variable density flow and salt transport model informed with data
collected during the first year of operation of the RWS. This model, referred to as the V3 model,
was updated using the V2 model as a starting point. Updates included (1) incorporation of
compatible elements of the surface water routing package developed by USGS and implemented
by Hughes and White (2014); (2) incorporation of geologic information obtained during the
installation of the groundwater recovery system and newly installed TPGW monitoring wells; (3)
incorporation of baseline CSEM salinity targets into the model calibration process; (4) inclusion
of hydrogeologic data collected by other entities west of the RWS, and (5) calibration of the
model using objective automated parameter estimation techniques. The model was calibrated to
conditions leading up to the start of the RWS (May 2018) and verified to the first year of RWS
operation (through May 2019). The verification consisted of simulating the RWS for one year of
operation and comparing the simulation results to observed results (i.e., water levels, salinity at
monitoring wells and CSEM targets, and mass extracted). The model was then used to simulate
the effect of operating the RWS for 10 years. Compliance with the CA were supported by model
predictions indicated by figures and tables of hypersaline plume retraction, mass removal, and
declines in salinity versus time in monitoring wells during the 10-year simulation. The model
documentation was included as Appendix H of the RAASR (FPL 2019c).
The next version of the model was called V4 and was originally intended to use data from and
evaluate the second year of RWS operation for the second RAASR. However, COVID-19
delayed the scheduled acquisition of Year 2 CSEM data from May to September 2020. The V4
model was updated without the Year 2 CSEM data and used to support FPL’s application to
FDEP to increase the CCS freshening allocation referred to as the Supplemental Salinity
Management Plan (SSMP). The updates to the V4 model included (1) calibration to data (e.g.,
salinity, water levels, and mass extracted) collected from the first year of operation of the RWS;
(2) incorporation of geologic information obtained during and after the installation of the RWS
and newly installed monitoring wells; (3) incorporation of CCS sediment sampling and testing
information into the assignment of the CCS boundary condition; (4) incorporation of changes
from baseline to Year 1 CSEM salinity targets into the model calibration process; and (5)
calibration of the model using two separate search algorithms contained within objective
automated parameter estimation techniques. Note that the original RAASR included a
verification of model results to the Year 1 CSEM data but, due to time constraints, did not
include calibration to Year 1 CSEM data. Calibration to Year 1 CSEM data was accomplished
with the V4 model. The V4 model was used to assess impacts resulting from discharging
additional water to the CCS from the Floridan Aquifer and to support the SSMP.
The development of the V5 model used the V4 model as its starting point and built upon the
knowledge gained from calibration and execution of the V4 model. The V5 model included the
Year 2 CSEM data that was collected in September 2020, later than originally planned, as
5-3
described above. A key change to the model calibration procedure was the manner in which the
CSEM data were used as targets. Rather than using a random subset of discrete CSEM
measurements as was done in earlier versions of the model, the target assignment involved
averaging CSEM measurements over approximate 1000-ft by 1000-ft areas in each model layer.
These averaged CSEM targets were then compared to modeled salinities at the centroid of each
CSEM target area. This revised procedure used fewer CSEM targets than previous versions, but
they covered the same area and depth as prior versions’ CSEM targets. In addition, the
averaging procedure created a smoother CSEM salinity distribution that contained less apparent
outliers than the prior versions. Model calibration involved running two search algorithms, as
was done in prior versions of the model. Following calibration, the model was used to make
projections regarding the operation of the RWS over the next eight years. Compliance with the
CA was supported by figures and tables of hypersaline plume retraction, mass removal, and
declines in salinity versus time in monitoring wells during the 8-year simulation. The model
documentation was included as Appendix H of the Second Remedial Action Annual Status
Report (FPL 2021a).
Features of each model version, including the current V6 model, are summarized in Table 5.1-1.
5.1.3 Sensitivity Analysis with the Version 5 Model
One of the recommendations in the second RAASR report (FPL 2021a) was to investigate the
causes of the V5 model’s inability to align the saline-hypersaline interface position along the
base of the aquifer and retract the HSI in a manner consistent with monitor well and CSEM data.
To address this recommendation, sensitivity analyses were performed using the V5 model prior
to development of the V6 model (Appendix H, Chapter 5). The sensitivity analysis identified
several factors that were important for more accurate calibration and prediction: (1) use of
hydraulic conductivity distributions that were more consistent with those developed through
visual core inspection by a geologist; (2) use of accurate vertical hydraulic conductivities; (3)
obtaining an accurate end-of-calibration location of the hypersaline interface; (4) use of spatially
variable porosity fields instead of the previously used layer-wide porosity specification; and (5)
accurate vertical resolution of the plume through the use of a different numerical solution
technique. The sensitivity analysis also suggested that the climate pattern used in the model
predictions was important. These findings were considered in the development, calibration, and
predictive simulations with the V6 model.
5.1.4 Description of Version 6 Model
Detailed descriptions of the V6 model assembly, calibration, and predictive simulations are
included in Appendix H. The V6 model uses the same basic framework as the prior V1 though
V5 models. It simulates a 276-square-mile area that is subdivided from west to east into 274
columns and from north to south into 295 rows. The width of the rows and columns vary
between 200 ft and 500 ft, with smaller grid cell dimensions located near the CCS. The model
domain overlain by the model grid is shown on Figure 5.1-1.
Vertically, the modeled Biscayne Aquifer (which varies in thickness from approximately 50 ft in
the west to approximately 100 ft in the east) is divided into 11 layers, for a total of approximately
5-4
890,000 grid cells. The uppermost model layers (layers 1 through 4) represent the Miami Oolite.
The thicker Fort Thompson Formation was divided into seven layers (layers 5 through 11).
Many of the well borings that were analyzed to define geologic contact elevations contained
zones with large, connected voids. These features were represented in the model as thin layers
with high hydraulic conductivity. Two zones of high hydraulic conductivity material (i.e., high-
flow zones) were identified from the various well borings analyzed to define the two high-flow
zones represented in the regional model. The upper high-flow zone (i.e., layer 4) occurs at the
base of the Miami Oolite, and the lower high-flow zone (i.e., layer 8) is located in the
approximate middle of the Fort Thompson Formation. A third, lower high-flow zone, located
along the contact between the Fort Thompson and Tamiami formations, is monitored by the
regional groundwater network; but it is not expressly represented as a unique hydraulic
conductivity zone in the model. Hydraulic conductivities within the high-flow zones were
calibrated using targets of hydraulic head, salinity, and a range in hydraulic conductivity
estimated by a geologist through inspection of geologic logs. This methodology allowed the
high-conductivity zones to be discontinuous or to be present in multiple layers besides layers 4
and 8. Figure 5.1-2 provides a cross-sectional view of the 11 layers of the groundwater flow
model and how they correspond to the hydrogeologic formations. The location of this cross-
section, along row 116 of the model, is shown on Figure 5.1-1.
The USGS groundwater flow and solute transport modeling tool SEAWAT Version 4 (Langevin
et al. 2008) was used in this analysis as well as the prior (V1 through V5) modeling analyses.
This SEAWAT version includes: (1) solute transport simulations through the integrated
MT3DMS (IMT) Process (Zheng and Wang 1998); and (2) variable-density flow (VDF)
simulation through the VDF process. SEAWAT’s VDF package was used to simulate the
density effects of both temperature and salinity. SEAWAT inputs and outputs are specified in
terms of “point-water heads” (Langevin et al. 2008), which represent the hydraulic head at a
given location based on salinity and temperature. SEAWAT solves the groundwater flow and
transport equations after converting point-water heads to “reference heads” or “equivalent
freshwater head at the reference temperature.”
The boundary conditions applied to the V6 model are also very similar to those applied in the
prior models. Namely, specified head-boundary conditions are used to simulate the effects of
temporal changes in Biscayne Bay and the various canals (including the CCS) on groundwater
flow and transport. General-head boundaries are used to simulate the exchange of groundwater
across the model’s lateral boundaries on all sides. NEXRAD-based rainfall rates and historical
patterns (spatial and temporal) in land use are used to estimate the amount of groundwater
recharge throughout the model domain. Reference evapotranspiration (ETo) data and land
use/land cover data are used similarly to estimate groundwater evapotranspiration (ET) rates as a
function of groundwater head. Consumptive use of groundwater for agricultural purposes and
some industrial uses (e.g., the Blue Water Industries and Card Sound quarries) are simulated as
specified withdrawals; and they were estimated based on land cover, estimated local
rainfall/recharge, and ET rates. Municipal and other industrial groundwater uses are also
simulated as specified withdrawals and are based on data as much as possible. The temperatures
and salinities assigned to water entering from the various boundaries simulated are also based on
actual data, as much as possible.
5-5
The V6 model incorporates canal hydraulics and groundwater interactions based on Hughes and
White’s (2014) modeling for MDC that were added in the V2 model. Details of these additions
are included in Appendix H. Two key changes to the calibration approach include the
characterization of porosity and hydraulic conductivity. Whereas a single porosity was
calibrated within each model layer of the V5 model, a pilot point methodology that allowed
variable porosity with a layer was utilized in the V6 calibration, based on insights gained from
the sensitivity analyses discussed above. In addition, horizontal hydraulic conductivity estimates
provided by JLA Associates, based on geologic cores and geophysical logs collected from
TPGW monitoring wells and RWS production wells, were included in the V6 model calibration
process. Unlike in V5 where the TPGW and RWS interpreted hydraulic conductivities were
calibration targets, hydraulic conductivities at these locations were adjusted during the course of
calibration. The percent differences in hydraulic conductivity across model layers 5–7 and 9–11
were maintained at each location while hydraulic conductivities in layers 1, 2, 4, 5, 8, and 9 were
calibrated for each pilot point.
In order to perform reliable predictions and satisfactorily meet the objectives of this modeling
effort, the SEAWAT model required calibration. Model calibration is the process of adjusting
parameters and boundary conditions within reasonable ranges to match historical observations,
such as hydraulic heads and salinities, reasonably well. The ability to replicate past conditions in
the calibration period provides confidence that the model is capable of simulating future
conditions in the model applications. The calibration model is subdivided into four time frames,
each of which simulates the development and movement of the saltwater wedge under different
hydrologic and anthropogenic stresses.
5.2 MODEL MODIFICATIONS/CALIBRATION
The model was calibrated to 81 years of data, including Years 1 through 3 of operation of the RWS.
The resulting calibration indicates the model is a reasonable tool to be used in conjunction with
monitoring data and CSEM results to assess progress in meeting the groundwater remediation
objectives of the MDC CA and FDEP CO. However, improvements in the model's alignment with
CSEM and monitoring well data at the edge of the hypersaline plume in 2018, prior to remediation
and during subsequent remediation years, is needed to improve reliability of long-range remediation
forecasts.
5.2.1 Model Calibration Process
The process for developing a model capable of providing accurate projections of RWS operation
involves calibration of the model to prior measured data that are similar to those of the
projections it is to make.
Model calibration is the process of adjusting parameters and boundary conditions within
reasonable ranges to match historical observations reasonably well. This model calibration
involved matching: (1) water level and salinity observations; and (2) salinity estimates based on
5-6
spring 2018, spring 2019, fall 2020, and summer (June) 2021 CSEM datasets 1. The calibration
period includes the V5 model calibration period (i.e., pre-development through September 2020)
plus an additional 9 months. This nine-month period includes the June 2021 CSEM dataset. The
calibration model is subdivided into four time frames, each of which simulates the development
and movement of the saltwater wedge under different hydrologic and anthropogenic stresses.
These periods are defined as follows:
7. Pre-development steady-state flow model (prior to 1940)

8. Steady-state flow and transient transport calibration model (1940–1968)
9. Seasonal transient flow and transport calibration model (1968–2010)
10. Monthly transient flow and transport calibration model (2010–2021)
Calibration was performed primarily using automated PEST.
The final period includes the first, second, and third year of RWS operation. Operational
pumping rates for each RWS well are input on a monthly basis. All available precipitation and
boundary condition (i.e., canal stage) data are also used. Model results for water levels, salinities
at monitoring wells, CSEM salinity distribution, and mass extracted by the RWS are compared to
measured values.
5.2.2 Model Calibration Results
The calibration results for water levels and relative salinities are shown in Table 5.2-1. Seasonal
and monthly transient model water levels and relative salinities are shown separately in
Appendix H. In general, the monthly data set is considered more reliable than the seasonal data
set because it uses the multi-depth and short-screened TPGW wells. The monthly data set also
has considerably more data despite its shorter duration (2010-2021). A robust assessment of
model calibration quality and statistics is provided in Appendix H.
The model responds similarly to the hydrologic system during the first three years of RWS
operation in that salinity changes are only observed in wells relatively close to the RWS. In
addition, responses are noted only in the shallow and intermediate wells. Model versus
measured change in salinity for the shallow and intermediate zones of wells TPGW-1, TPGW-2,
TPGW-4, TPGW-15, TPGW-17, and TPGW-19 are shown on Figure 5.2-1. Comparison of
model to measured salinity change is very good for these wells, though inexact. There is some
over-simulation of salinity decline in two intermediate wells (TPGW-2M and TPGW-15M)
though the match to salinity decline in the shallow zones of these wells is quite good.
The model shows a similar response as the CSEM data to the movement of the hypersaline (i.e.,
chloride >19,000 mg/L) interface. Table 5.2-2 compares the number of CSEM targets (i.e.,
1000-ft by 1000-ft composite cells in the model) and model targets that change from hypersaline
to saline between the 2018 to 2019, 2019 to 2020, 2020 to 2021, and entire 2018 to 2021 periods.
There is fairly good agreement with the number of cells that change over the entire 2018 to 2021
1
Whereas the simulated salinities coincident with the 2016 CSEM survey were reviewed during the course of the
calibration, these data were not used to guide the adjustment of model parameters.
5-7
remediation period, although the model shows fewer cells (707) turning saline than does the
CSEM data (815). In individual years, the match between the model and CSEM results is
generally favorable. Despite any differences, both the model and CSEM data indicate retraction
of the plume during the first 3 years of operation, although to different degrees and at different
locations.
The model has an excellent match to measured total salt mass extracted by the RWS (Figure
5.2-2). The match for individual wells is also good (Figure 5.2-3), with the largest discrepancies
noted in wells RWS-4, RWS-7, and RWS-8. There is also some over-simulation of mass
extracted in RWS-1 in the final 6 months of operation, likely due to over-simulation of salinity in
this area.
Based on the success in meeting the calibration goals, the sequence of calibration models was
deemed satisfactory to employ in the execution of the forecast model.
5.3 REMEDIATION YEARS 5 AND 10 FORECAST
Predictive model runs indicate the RWS will fully retract the HSI in the upper two-thirds of the
Biscayne Aquifer (layers 1-8) to the FPL property within 10 years of RWS operation. The
simulations indicate the HSI retracts to the FPL property in the northern half of the CCS in layer 9,
expands slightly in layers 10 and 11 during the first 5 years of RWS operation, but stabilizes
between Years 5 and 10. However, the results in the lower model layers differ from CSEM-
measured changes suggesting additional evaluation of the model forecast and CSEM trends are
needed.
5.3.1 Description of Remediation Simulations
The projected results of operation of the RWS during Years 4 through 10 were simulated in a
similar fashion as the operations of the RWS during the Years 1 through 3. The initial conditions
for the simulation were the ending conditions (i.e., salinity, temperature, and water level) of the
final period of the calibration simulation (June 2021). Climate conditions (e.g., precipitation,
evaporation, canal stages) for the 2018-2021 period used in the calibration were repeated during
the predictive period. This sequence uses precipitation that is below normal for the first year,
above normal for the second year, and close to average for the third year, based on site-specific
meteorological data. For comparison, June to May precipitation for the first year is documented
at Miami International Airport to be 52.7 inches, 81.7 inches for the second year, and 69.6 inches
for the third year (NOWData 2021). Average annual precipitation during the period 2010
through 2020 was 70.6 inches, which was close to the average of 68.0 inches used in the 3-year
sequence. This methodology uses data and conditions that represent a recent time frame of
varied hydrologic conditions and is a likely reasonable approximation of future conditions. The
RWS was simulated to operate according to the design: 1.5 mgd from each RWS well, for a total
of 15 mgd withdrawal. The CCS was set at a salinity of 34 PSU for the duration of the
predictive period. In addition, the UIC test production wells were set to withdraw a total of
3 mgd from beneath the CCS for the duration of the remediation period.
5-8
5.3.2 Remediation Forecast
Model forecasts of the position of the hypersaline/saline water interface in Years 5 and 10 of
remediation were determined using the V6 model, and they are similar to prior forecasts.
Retraction to the L-31E canal is generally achieved in the upper 8 model layers (approximately
67% of the Biscayne aquifer thickness) but is not fully achieved in layer 9. The model forecasts
minor westward expansion of the plume in layers 10 and 11 by Year 5 but stabilizes from Year 5
through Year 10 (Figures 5.3-1 a, b, c). This forecast is contrary to Year 3 CSEM survey results
that show net retractions of the plume along the base of the aquifer. Layer 8 shows a small
portion of hypersaline groundwater persists west of the L-31E canal adjacent to the southern end
of the CCS, which has not been the case in prior model versions. In addition, the model
identifies a small area of hypersalinity north of the plant in Year 10, which is not identified to be
contiguous with the CCS in CSEM surveys.
At this point, it is not clear whether the incomplete retraction is a result of a physical
phenomenon or inaccuracies in the model. The physical phenomenon of the lower high-flow
zone overlying the RWS wells may create a preferred vertical flow path for RWS pumping that
renders modeled horizontal retraction in these layers difficult. This conceptual model is
supported by the layer 10 capture zones being smaller than the capture zones in overlying but
unpumped layers (Figure 5.3-2). This pattern suggests primarily vertical flow in layer 10 near
the RWS wells. In addition, there appears to be contribution from non-CCS, coastal,
evaporative-formed hypersaline groundwater that is recharging the hypersaline plume north and
south of the CCS. The V6 and earlier versions of the model have shown this process to be
simulated with the surface-formed hypersalinity migrating vertically in the aquifer and
recharging the lower model layers. Retraction in the northern and southern areas surrounding the
CCS could be hampered by continued addition of hypersaline water from the plume to the south.
Additional evaluation of the model’s representation and extent of this process should be
evaluated to determine the degree to which this source of hypersalinity could impact the CCS
remediation objectives.
Particle tracking, conducted using the V6 model (Figure 5.3-2), confirmed the hypersaline water
from the CCS is intercepted, captured, and contained beneath the CCS, and no longer migrates
into the compliance zone. This analysis was conducted for all model layers from initiation of the
RWS operations through 10 years of remediation. It indicates the hydraulic constraint to the
migration of hypersaline groundwater from beneath the CCS was halted shortly after RWS
operations began and are maintained through Year 10. Figure 5.3-2 shows the predicted capture
zones of layers 4, 8, and 10; particle tracking for additional layers is shown in Appendix H.
These figures are generated by initializing particles in cells surrounding the RWS wells (in the
areas shaded grey in Figure 5.3-2) for all layers and highlighting the starting locations (in
orange) of each particle that ends at the RWS. It is clear that there is an extensive capture zone
to the east and west in shallow high-flow zones despite these layers not being pumped. In
contrast, capture zones with comparatively smaller radii surround each of the RWS wells in
layers 10 and 11, indicate these wells obtain a smaller portion of their water laterally within
those layers and more vertically from shallower overlying high flow layers. Moreover, Figure
5.3-2 illustrates that the RWS prevents water from the CCS from flowing through, and westward
5-9
past, the RWS. This includes the deep layer where further analysis revealed that the apparent
gaps between RWS-6, RWS-7, and RWS-8 are stagnation areas where the particles do not follow
a consistent pathway and are neither captured nor allowed to discharge westward past the RWS.
Stagnation zones develop in areas between adjacent extraction wells with overlapping
drawdowns in pump and treat operations that result in low hydraulic gradients. Cohen et al.
(1994), provide examples of stagnation zones associated with different pumping schemes
including the distribution of multiple stagnation zones at a complex field site.
Another potential inaccuracy in the model is that the simulated hydraulic conductivities in layers
9–11 south of the CCS and between the RWS and Tallahassee Road are significantly lower than
estimated by inspection of geologic cores. The simulated hydraulic conductivities in layers 9–11
in wells TPGW-4 and TPGW-5 (located west of the CCS near Tallahassee Road) are 310 and
453 feet per day (ft/d), respectively, while estimated hydraulic conductivities for these wells are
2,460 and 4,890 ft/d. The low hydraulic conductivities estimated in the model in this area act to
impede lateral movement of salinity in these layers. Such disparities are evident at TPGW-1,
TPGW-2, and TPGW-3. However, comparison of estimated and calibrated hydraulic
conductivities at nearby RWS wells indicates a reasonably accurate match. Higher hydraulic
conductivities could also result in the plume moving farther west than documented to occur at
the beginning of the remediation, a disparity that already exists in this and prior model versions.
Both the physical explanations and potential inaccuracies in the model that hamper saline-
hypersaline interface retraction in the lower layers should be explored in the V7 model
assessment.
5.3.3 Sensitivity Simulation
A sensitivity simulation evaluating an initial location of the hypersaline plume that is closer to the
RWS (less extended to the west) than the predictive simulation produced greater retraction in layers
8 and 9 and salinity reduction in layers 10 and 11. The sensitivity simulation suggests the
importance of accurate quantification of the initial plume and configuring the model to be able to
reproduce the CSEM plume orientations prior to and during remediation.
A sensitivity simulation was made to test the effect of the accuracy of the location of the
hypersaline plume at the start of the RWS. It has been recognized for some time that the model
calibration tends to result in an initial plume that extends further west than supported by the
CSEM data. Though conservative (i.e., a condition where plume retraction is more difficult), it
is not clear if and how much additional plume retraction would result from a more accurate
initial plume location. This condition was evaluated by replacing modeled salinities within the
compliance zone with data from the 2021 CSEM study as initial conditions for the simulation of
RWS operation.
The results of this simulation are similar to the original simulation in the upper 7 layers. The
plume for this simulation is less extended to the west in the lower layers than in the original
model, with a salinity below 45 PSU in layer 10 that is within the compliance zone. However,
5-10
consistent with the original model, there is only a small amount of retraction in layers 10 and 11
in years 5 through 10. This simulation highlights the importance of having an accurate initial
hypersaline interface location for the predictive simulations. However, plume retraction in the
lower layers is still incomplete, despite having an initial condition that is now aligned with the
CSEM data. The sensitivity simulation also highlights the importance of having the model
construction and hydraulic properties be capable of reproducing the CSEM initial plume more
accurately.
5.3.4 Model Recommendations
Six recommendations for future evaluations of system performance are offered:
1. The continuity and hydraulic conductivity of the lower high-flow zone should be
investigated and incorporated accurately into the model.
2. The hydraulic properties vertically adjacent to the lower high-flow zones should be
investigated and incorporated accurately into the model.
These two recommendations are important because it appears from the capture zones and
the model’s inability to retract the hypersaline interface within the pumped layers that the
high-flow zone located in the middle model layers serves as a preferential pathway that
minimizes the model’s ability to draw water from the lower layers resulting in a lack of
retraction of the hypersaline plume in these layers.
3. Detailed evaluation and incorporation of CCS sediment and sampling information should
be used to guide how the modeled connection of the CCS to groundwater needs to be
revised and represented.
4. FPL’s CCS water and salt-balance model should continue to be used to inform the model
with respect to amounts and timing of canal and groundwater seepage to and from the
CCS.
The third and fourth recommendations seek to obtain through calibration a more accurate
present-day location of the hypersaline interface. The modeled plume appears to be more
extensive than suggested by the CSEM data. Although conservative, the larger plume
represented in the model is further outside the capture radius of the RWS and results in
more hypersaline volume and mass than may actually be present.
5. CCS salinities and climate conditions should continue to be monitored and the model
updated and recalibrated with more data reflective of longer RWS operations. The longer
period of RWS operation and consequent changes to salinities over a progressively larger
area will help inform the model and increase its accuracy in simulating the effect of the
RWS and forecasting longer-term performance.
6. Evaluations should be conducted to verify the degree to which model-generated, non-

CCS hypersaline groundwater impacts remediation objectives.
5-11
Table 5.1-1. Summary of Groundwater Model Versions.

Version 1 Version 2 Version 3 Version 4 Version 5 Version 6
Date June 2016 June 2018 October 2019 September 2020 April 2021 September 2021
FDEP attribution Year 1 verification of Year 1 Calibration to Year 2 Calibration to Year 3 Calibration to
Purpose Design RWS
analysis RWS RWS RWS RWS
Calibration
Manual Automated (PEST) Automated (PEST) Automated (PEST) Automated (PEST) Automated (PEST)
Method
Heterogeneous in
Hydraulic
layers 4,8,9,10,11.
Conductivity Uniform within Heterogeneous in Heterogeneous in Heterogeneous in Heterogeneous in
Contrast between
Representatio layers layers 4,8,9,10,11 layers 4,8,9,10,11 layers 4,8,9,10,11 layers 4,8,9,10,11
5,6, and 7; 9,10, and
n
11 based on JLA
Recharge Precipitation and Precipitation and Precipitation and Precipitation and Precipitation and
Net
Formulation Evapotranspiration Evapotranspiration Evapotranspiration Evapotranspiration Evapotranspiration
CSEM Data
No Yes Yes Yes Yes Yes
Used?
Predictions 10-year forward 40-year backward 10-year forward 9-year forward 8-year forward 7-year forward
Recent TPGW & 3rd round of CSEM 4th round of CSEM

Differentiate between
RWS wells as and recent TPGW & and recent TPGW &
Assess Recharge and ET, 2nd round of CSEM
targets; incorporation RWS wells as RWS wells as
Primary alternatives for detailed surface water and recent TPGW &
of geologic targets; revision to targets; porosity as a
Change / compliance; representation, CSEM RWS wells as
information at TPGW CSEM targets to spatially variable
Focus selected targets evaluate causal targets; verify with
and RWS locations eliminate localized parameter, sensitivity
alternative 3D factors of regional stress (RWS).
significant changes in analysis to guide
saltwater intrusion
salinity calibration
5-12
Table 5.2-1. Calibration Statistic Summary for the Version 6 Model.

Model Target Type Units ME MAE RMSE MAE ÷ Range
Seasonal Hydraulic Head ft -0.129 0.432 0.567 6.3%

(1968-2010) Relative Salinity R.S. -0.113 0.163 0.243 9.7%
Monthly Hydraulic Head ft -0.210 0.302 0.398 4.9%

(2010-2021) Relative Salinity R.S. 0.128 0.182 0.232 9.5%
2018 CSEM Survey R.S. 0.082 0.226 0.312 11.0%

CSEM (2018, 2019 CSEM Survey R.S. 0.087 0.204 0.276 9.9%
through
2021) 2020 CSEM Survey R.S. 0.101 0.207 0.295 10.0%
2021 CSEM Survey R.S. 0.143 0.211 0.300 10.3%
Note: One Relative Salinity (R.S.) Unit = 35 PSU = 19,400 mg/L Cl
5-13
Table 5.2-2. Comparison of CSEM and Model Representations of Remediation Progress.

2018-2019 2019-2020 2020-2021 2018-2021
Category
CSEM Model CSEM Model CSEM Model CSEM Model
Number of hypersaline targets

387 243 285 315 276 167 815 707
that change to saline
Number of initially (2018)

1728 2076 1728 2076 1728 2076 1728 2076
hypersaline targets
Percent of initial (2018)

hypersaline targets that 22% 12% 16% 15% 16% 8% 47% 34%
change to saline
Note:
The CSEM calculated reduction of 42% in section 4 is based on the number of 100 m X 100 m CSEM voxels that changed from
hypersaline to hypersaline. The model target cell sizes are 1,000 x 1,000 feet which, when overlain over the CSEM defined
hypersaline layers, result in a small difference between the CSEM calculated percent reduction and the model cell-based
accounting results.
5-14
Figure 5.1-1. Model Study Area Overlain by the Active Model Grid; Red Dashed Line
Represents the Location of the Model Cross Section Shown in Figure 5.1-
2.
5-15
Figure 5.1-2. Model Cross Section Showing Model Layering and Hydrogeologic Formations (Location of Cross Section
Shown in Figure 5.1-1).
5-16
Novem ber 2021
5. Groundw ater M odel
5.2-1. Comparison of Model and Observed Changes in Relative Salinity with Time by Well
Between April 2018 and June 2021.
5-17
Novem ber 2021
Salt Removed Per Month (Millions of Pounds)

220
200
Salt Removed (lbs x 10E+06)
180
160
140
120
100
80
60 Published (Data-Based) Estimate
40
20 Calibrated
0
05/18 07/18 10/18 01/19 05/19 07/19 10/19 01/20 04/20 07/20 10/20 01/21 04/21
Date
Figure 5.2-2. Comparison of Model and Observed Total Mass Extracted by the RWS
Between May 2018 and June 2021.
5-18
Novem ber 2021
RWS-1 (Million Pounds per Month) RWS-6 (Million Pounds per Month)
25 25
Published (Data-Based) Estimate

Calibrated
20 20
15 15
10 10
5 5 Published (Data-Based) Estimate
Calibrated
0 0
05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21 05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21
Date Date
25 25

Calibrated 20
20
15 15
10 10
Calibrated
0 0
05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21 05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21
Date Date
25 25
Calibrated
20 20
15 15
10 10
Calibrated
0 0
05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21 05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21
Date Date
25 25
20 20
15 15
10 10

Calibrated
Calibrated
0 0
05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21 05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21
Date Date
25 25
20 20
15 15
10 10
5 Published (Data-Based) Estimate 5 Published (Data-Based) Estimate

Calibrated Calibrated
0 0
05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21 05/18 08/18 11/18 02/19 05/19 08/19 11/19 02/20 05/20 08/20 11/20 02/21 05/21
Date Date
Figure 5.2-3. Comparison of Model and Observed Mass Extracted by Well Between May
2018 and June 2021.
5-19
Novem ber 2021
Figure 5.3-1a. Location of Initial, Year 5, and Year 10 Hypersaline Interface in Model Layer
4.
5-20
Novem ber 2021
Figure 5.3-1b. Location of Initial, Year 5, and Year 10 Hypersaline Interface in Model
Layer 8.
5-21
Novem ber 2021
Figure 5.3-1c. Location of Initial, Year 5, and Year 10 Hypersaline Interface in Model Layer
11.
5-22
Novem ber 2021
Figure 5.3-2. Predicted 10-yr Capture Zones for Model Layers 4, 8, and 10.
5-23
Novem ber 2021 6. Sum m ary and Recom m endations
6 SUMMARY AND
RECOMMENDATIONS
6.1 OVERALL SUMMARY
FPL employs three types of data and associated analyses (monitoring, electromagnetic surveys, and
modeling) to assess progress in meeting the objectives of the Consent Agreement and Consent
Order. Analyses of data through Year 3 of remediation demonstrate that the net westward
migration of the hypersaline plume has been halted, hypersaline groundwater from the CCS is being
intercepted, captured, contained, and retracted by RWS operations. The CSEM data shows that the
volume of hypersaline water in the compliance area has been reduced by 42% since remediation
began in 2018.
FPL submits this Year 3 RAASR, which covers the third year of RWS operation from October 1,
2020, to September 30, 2021, in compliance with the monitoring and reporting objectives of the
MDC CA and the FDEP CO. While the COVID-19 pandemic impacted the Year 2 RAASR
schedule and resulted in that report being submitted in two parts and covering 16 months of data,
the schedule for the Year 3 RAASR has returned to normal with a single report covering a 12-
month period. This report includes RWS operations and groundwater monitoring data collected
from October 2020 to September 2021, Year 3 CSEM survey results based on the June 2021
survey, groundwater monitoring well contour mapping, and the updated/recalibrated regional
3-dimensional, density-dependent solute transport groundwater model (Version 6 [V6]). This
report also includes a Performance and Compliance evaluation (Appendix I) addressing the first
3 years of RWS operation with respect to achieving the objectives of intercepting, capturing,
containing, and documenting the extent of retraction of the plume. The following is a summary
of the major findings of this evaluation:
• After 3 years of remediation operations, the CA objectives to intercept, capture, contain

and demonstrate statistically valid reductions in the salt mass and volumetric extent
(retraction) of hypersaline groundwater from the CCS have been met. The CO
requirement to halt the westward migration of hypersaline water from the CCS within 3
years was documented to have been achieved in the April 2021 Year 2 Part 2 RAASR,
and it has been confirmed by analyses conducted in this report.
• The RWS operated 98.1% of the reporting period; there were only 7 days (1.9%) when
the entire system was shut off for maintenance. The individual wells collectively
operated, on average, 92.5% this reporting period, a slight increase over Year 2 (91.7%).
• With each year of RWS operation, the net number of monitoring wells with statistically
significant declining trends in chloride, salinity, and/or tritium have increased in all three
6-1
depth intervals, indicating RWS operations are effectively reducing hypersalinity

throughout the vertical extent of the plume.
• Approximately 5.92 billion gallons of hypersaline water and 2.32 billion pounds of salt
were removed during this reporting period. Since inception of the remediation system,
approximately 18.45 billion gallons of hypersaline groundwater and 7.32 billion pounds
of salt have been extracted from the Biscayne Aquifer.
• In total, 20 of 23 monitoring wells showed a statistically significant declining trend in

one or more parameters (i.e., quarterly chloride, quarterly tritium, and weekly average
automated salinity) and at least one or more parameters that were the lowest this
reporting period compared to baseline and Years 1 and 2.
• The Year 3 CSEM results, compared to the 2018 baseline survey results, indicate the
volumetric extent of the hypersaline plume has been reduced by 42% after 3 years of
RWS operation. There are areas of statistically significant net retraction of the CCS-
sourced hypersaline plume throughout the Biscayne aquifer west and north of the Plant
site.
• Based on CSEM data, the greatest reduction in hypersalinity volume is occurring in the
lower portion of the aquifer while the more significant reductions in groundwater
monitoring well salinities are being measured in the upper portion of the aquifer as the
plume shrinks from top to bottom.
• Two sources of hypersaline groundwater, coastal naturally occurring evaporated seawater

and the CCS, occur within the survey area. Coastal evaporated seawater has been
identified in both CSEM and modeling north of Plant, east of the plant entrance road, and
east of the L31 levee, as well as in the area south of the S-20 structure east of the L31E
levee and south of the CCS. Hypersaline surface water and shallow groundwater with
fluid densities greater than underlying groundwater sink downward, resulting in both
shallow and deep expressions of hypersaline groundwater.
• The groundwater model has been updated with Year 3 RWS data, groundwater
monitoring well data, and CSEM data, and has been recalibrated to Years 1, 2, and 3
remediation data. These updates have reduced total model error (defined as the
cumulative difference between model estimated value and actual measured values) and
improved model representations of plume reductions associated with 3 years of
remediation. However, significant differences remain between measured aquifer
conditions and the model representation of these conditions. It is expected that these
differences will continue to be reduced as the model is informed by subsequent annual
remediation results.
• The Year 3 recalibrated V6 model forecast simulations for Years 5 and 10 of remediation
shows an improved hypersaline retraction result in the northern portions of layers 9, but
the southern portion and layers 10 and 11 do not show retraction by simulated Year 10 of
6-2
remediation. While improvements in modeled orientation of the plume extent are

achieved by the V6 model, further improvements are needed to reliably represent the
dynamics of the hypersaline plume responses to the RWS in the lower portions of the
aquifer. It is expected that these differences will continue to be reduced as the model is
informed by subsequent annual remediation results.
6.2 REFINEMENTS
FPL has implemented actions, including the following, to enhance the ongoing remediation and
to further the objectives of the CO and CA:
Cooling Canal System Salinity Reduction
• A modification to the site certification license PA 03-45F was issued to FPL (October 19,
2021), authorizing use of the new F-7 CCS freshening well and increasing the UFA
allocation for wells F-1 through F-7 from 14 mgd (5,110 million gallons per year) to 30
mgd (10,950 million gallons per year) with a maximum monthly allocation of 34 mgd
(1,033.6 million gallons per month). This additional allocation will offset evaporative
losses of fresh water from the CCS that exceed the 14 mgd previously allocated, thereby
limiting dry season salinity increases that occur under the previous allocation and
stabilizing CCS salinities at 34 PSU. FPL began increasing freshening inflows starting in
November 2021.
Hypersaline Groundwater Remediation
• Extraction of up to 3 mgd of hypersaline groundwater from beneath the CCS using two
existing Biscayne aquifer underground injection control test production wells was
initiated during the Year 2 reporting period.
• Modifications to the UIC test production well connection and well operations are being
implemented to maximize UICTPW production capacity to 3.6 mgd.
Groundwater Monitoring Network Expansion
• TPGW-22 was incorporated into the remediation compliance monitoring network on

February 16, 2021. Data on groundwater salinity and analytic chemistry is being
collected from all three monitoring well intervals, although automated water level data
has yet to be reliably produced.
• An application for a SFWMD right-of-way permit for monitoring well site TPGW-23
was filed on May 13, 2021, and issued by SFWMD on July 22, 2021. The U.S. Army
Corps of Engineers 408 permit application is under review at the time this report was
filed.
6-3
6.3 RECOMMENDATIONS
Given the significant progress of remediation since initiation of the RWS, FPL does not propose
any changes to the agencies’ approved remediation plan at this time. However, based on review
of Year 3 CSEM survey data and the updated/recalibrated Year3 V6 forecast modeling, FPL
shall incorporate the following actions and recommendations:
• Continue to utilize sensitivity analysis to investigate methods to better align model

calculated plume orientations with CSEM and monitoring well data, particularly in the
lower model layers, in order to produce more reliable long-range remediation forecasts.
• Investigate the continuity and hydraulic conductivity of the lower high flow zone and
incorporate it accurately into the model. Similarly, the hydraulic properties vertically
adjacent to the lower high flow zones should be investigated and incorporated accurately
into the model.
• Detailed evaluation and incorporation of CCS sediment and sampling information should
be used to guide how the modeled connection of the CCS to groundwater needs to be
revised and represented.
• FPL’s CCS water and salt-balance model should be used to inform the three-dimensional
groundwater flow and salt transport model with respect to amounts of seepage to and
from the CCS.
• CCS salinities and climate conditions should continue to be monitored and the model
updated and recalibrated with more data reflective of longer RWS operations. The longer
period of RWS operation, and consequent changes to salinities over a progressively
larger area, will help inform the model and increase its accuracy in simulating the effect
of the RWS and compliance with regulatory requirements.
• Evaluations should be conducted to verify the degree to which model-generated, non-

CCS hypersaline groundwater impacts remediation objectives.
It is important to note that the aquifer system is complex and subject to many external factors
beyond the CCS and RWS; therefore, continued monitoring, model updates, and scientific data
analyses are performed to improve our understanding of the impact of RWS operations in
concert with these other factors. FPL will continue to monitor and evaluate progress in meeting
the requirements of the CA and CO and make recommendations for modifications as needed.
6-4
Novem ber 2021 7. R eferences
7. REFERENCES
Arcadis 2020. Review of Aerial Electromagnetic Surveys at Turkey Point Power Plant, Southern
Florida; prepared for Miami-Dade County Department of Environmental Resource
Management.
Cohen, R.M., Vincent, A.H., Mercer, J.W., Faust, C.R. and Spalding, C.P., 1994. Methods for
Monitoring Pump-and-Treat Performance. U.S. Environmental Protection Agency, Office
of Research and Development. EPA/600/R-94/123.
ENERCON. 2016. PTN Cooling Canal System, Electromagnetic Conductance Geophysical

Survey, Draft Final Report, Florida Power and Light Turkey Point Power Plant, 9700 SW
344th Street, Homestead, FL 33035.
Fish, J.E. and M. Stewart. 1991. Hydrogeology, aquifer characteristics, and ground-water flow of
the surficial aquifer system, Dade County, Florida. U.S. Geological Survey, Water
Resources Inv. 91-4000.
Fitterman, D.V. and S.T. Prinos. 2011. Results of time-domain electromagnetic soundings in
Miami-Dade and Southern Broward Counties, Florida. U.S. Geological Society Open- File
Report 2011-1299, ix, 42 p.
Fitterman, D.V., M. Deszcz-Pan, and T. Scott. 2012. Helicopter Electromagnetic Survey of the
Model Land Area, Southeastern Miami-Dade County, Florida. U.S. Geological Society
Open-File Report 2012–1176:77.
Florida Power & Light Company (FPL). 2012. Florida Power & Light Company
Comprehensive Pre-Uprate Monitoring Report for the Turkey Point Monitoring Project.
Prepared for Florida Power & Light Company by Ecology and Environment, Inc. October
31, 2012.
__________. 2013. Florida Power & Light Company Quality Assurance Project Plan (QAPP)
for the Turkey Point Monitoring Project. Prepared for Florida Power & Light Company by
Ecology and Environment, Inc. June 2013.
__________. 2016. Florida Power & Light Company Comprehensive Post-Uprate Monitoring
Report for the Turkey Point Monitoring Project. Prepared for Florida Power & Light
Company by Ecology and Environment, Inc. March 2016.
__________. 2017. Florida Power & Light Company Annual Monitoring Report for the Turkey
Point Monitoring Project. Prepared for Florida Power & Light Company by Ecology and
Environment, Inc. September 2017.
7-1
__________. 2018a. Florida Power & Light Company Recovery Well System Startup Report.
Prepared for Florida Power & Light Company by Ecology and Environment, Inc. October
2018.
__________. 2018b. Florida Power & Light Company Turkey Point Recovery Well System
(RWS) Second Quarter Status Report. December 2018.
__________. 2018c. Florida Power & Light Company Annual Monitoring Report for the
Turkey Point Monitoring Project. Prepared for Florida Power & Light Company by
Ecology and Environment, Inc. August 2018.
__________. 2019a. Florida Power & Light Company Turkey Point Recovery Well System
(RWS) Third Quarter Status Report. March 2019.
__________. 2019b. Florida Power & Light Company Turkey Point Recovery Well System
(RWS) Fourth Quarter Status Report. June 2019.
__________. 2019c. Florida Power & Light Company Turkey Point Remedial Action Annual
Status Report. November 2019.
__________. 2019d. Florida Power & Light Company Annual Monitoring Report for the
Ecology and Environment, Inc. August 2019.
__________. 2020a. Florida Power & Light Company Remedial Action Annual Monitoring
Report for the Turkey Point Monitoring Project. Prepared for Florida Power & Light
Company by WSP Inc. August 2020.
__________. 2020b. Florida Power & Light Company Turkey Point Remedial Action Annual
Status Report, Year 2, Part 1. Prepared for Florida Power & Light Company by WSP.
November 2020.
__________. 2021a. Florida Power & Light Company Turkey Point Remedial Action Annual
Status Report, Year 2, Part 2. Prepared for Florida Power & Light Company by Stantec.
April 2021.
__________. 2021b. Florida Power & Light Company Annual Monitoring Report for the
Stantec. August 2021.
Hughes J.D. and White, J.T., 2014. Hydrologic Conditions in Urban Miami-Dade County,
Florida, and the Effect of Groundwater Pumpage and Increased Sea Level on Canal
Leakage and Regional Groundwater Flow. U.S. Geological Survey Scientific
Investigations Report 2014–5162, 175 pp. https://doi.org/10.3133/sir20145162.
7-2
JLA Geoscience, Inc. 2010. Geology and Hydrogeology Report for FPL, Turkey Point Plant
Groundwater, Surface Water, and Ecological Monitoring Plan, FPL, Turkey Point Plant,
Homestead, Florida. Prepared for Florida Power & Light Company. October 2010.
Langevin, C.D., Thore, D.T., Dausman A.M., Sukop, M.C., and Guo, W., 2008. SEAWAT
Version 4: A Computer Program for Simulation of Multi-Species Solute and Heat
Transport: USGS Techniques and Methods Book 6, Chapter A22, 39 p.
Meals, D.W., Spooner, J., Dressing, S.A. and J.B. Harcum. 2011. Statistical Analysis for
Monotonic Trends, Tech Notes 6, November 2011. Developed for U.S. Environmental
Protection Agency by Tetra Tech, Inc., Fairfax, VA, 23 p. Available online at
https://www.epa.gov/polluted-runoff-nonpoint-source-pollution/nonpoint-source-
monitoringtechnical-notes.
NOWData—NOAA Online Weather Data, 2021. http://www.weather.gov/wrh/climate?wfo-

mfl Accessed November 9.
Prinos, S.T., M.A. Wacker, K.J. Cunningham, and D.V. Fitterman. 2014. Origins and delineation
of saltwater intrusion in the Biscayne aquifer and changes in the distribution of saltwater in
Miami-Dade County, Florida. U.S. Geological Survey Scientific Investigations Report
2014–5025. 101 pp. http://dx.doi.org/10.3133/sir20145025.
South Florida Natural Resources Center (SFNRC). 2012. Hydrology and Salinity of Florida
Bay. Status and trends: 1990-2009. Technical Series 2012:1.
South Florida Water Management District (SFWMD). 2015. Applicant’s Handbook for Water
Use Permit Applications within the South Florida Water Management District.
Stringer, C.E., M.C. Rains, S. Kruse, and D. Whigham. 2010. Controls on water levels and
salinity in a barrier island mangrove, Indian River Lagoon, Florida. Wetlands. 30(4):725-
734.
Tetra Tech, 2016a. A Groundwater Flow and Salt Transport Model of the Biscayne Aquifer,
Technical Memorandum provided to Florida Power & Light, June 10, 2016.
Tetra Tech, 2016b. Application of Parameter Estimation Techniques to Simulation of Remedial

Alternatives at the FPL Turkey Point Cooling Canal System, Technical Memorandum
provided to Florida Power & Light, July 14, 2016.
Tetra Tech, 2016c. Addendum to Regional Biscayne Aquifer Model Report (Tetra Tech, 2016),
Technical Memorandum provided to Florida Power & Light, October 12, 2016.
Tetra Tech, 2017. Biscayne Aquifer Groundwater Flow and Transport Model: Heterogeneous
Hydraulic Conductivity Analyses, Technical Memorandum provided to Florida Power &
Light, January 2017.
7-3

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Remedial Action Annual

Executive Summary ....................................................................... 1

5.1.1 Objectives ................................................................................................ 5-1

5.1-1. Summary of Groundwater Model Versions.................................................................... 5-12

A.1-1 Permitting Activity Status ............................................................................................... A-1

4.2-5. Comparison of 2021 Formation Water Resistivity versus Lab Chloride

B.3-1 RWS-1 Salinity and Chloride .........................................................................................B.3-1

B.3-3 RWS-3 Salinity and Chloride .........................................................................................B.3-2

E.2-1 TPGW-1 Analytical Tritium (March 2018 – June 2021).............................................. E.2-1

E.2-2 TPGW-2 Analytical Tritium (March 2018 – June 2021).............................................. E.2-2

ACRONYMS AND ABBREVIATIONS

TDS total dissolved solids

• Since inception of the remediation system, approximately 18.45 billion gallons of

• In total, 20 of 23 monitoring wells showed a statistically significant declining trend in

1.2 SCOPE OF THE REMEDIAL ACTION ANNUAL STATUS

1.3 STATUS OF CONSENT AGREEMENT/CONSENT ORDER

2 RECOVERY WELL SYSTEM YEAR 3

2.1 HYPERSALINE EXTRACTION/DISPOSAL

The hypersaline groundwater is pumped from each

2.2 RECOVERY WELL SYSTEM MONITORING RESULTS

Table B.1-1 in Appendix B shows

2.3 RECOVERY WELL SYSTEM DRAWDOWN ASSESSMENT

The results support previous findings of a combined drawdown of approximately 0.25 ft at

2.4 INTERCEPTOR DITCH OPERATIONS

• Continued effectiveness of the ID in restricting westward migration of CCS groundwater

• Continued effectiveness in maintaining the freshwater lens thickness in the Biscayne

Table 2.2-1. RWS Chloride Monitoring Results (mg/L).

2020 2021 Average

Figure 2.2-1. RWS Chloride Results (mg/L).

3.1 GROUNDWATER MONITORING

3.2 2021 YEAR 3 WATER QUALITY CONDITIONS AND

• Automated Salinity – 12 out of 21 (57%) wells with automated instrumentation

A summary of the findings from

Ten other groundwater monitoring wells (TPGW-1D, TPGW-2D, TPGW-12M, TPGW-12D,

Although the majority of the wells

3.3 CHLORIDE CONCENTRATION CONTOUR MAPS

3.4 GROUNDWATER LEVEL TRENDS

Assessment: Year 3 minimum < Mann-Kendall

Figure 3.2-2. Chloride Values at TPGW-1S, TPGW-2S, and TPGW-15S.

4.2 APPROACH AND METHODS

4.2.1 Data Processing

4.2.2 Quality Control of 3D CSEM Data Inversion

4.2.2.1 Magnetic Field Noise

4.2.2.2 Resistivity Model Verification

4.2.3 Conversion of CSEM Resistivity to Estimated Chloride Concentrations

(1) 𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊𝑊 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 = 0.10867 ∙ (𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅)1.1853

A regression equation is fitted to the data and has the form:

4.2.3.1 CSEM System Response Shift

4.2.3.2 Impact of Monitoring Site TPGW-22 on the Calibration Data Set

4.2.3.3 2021 Chloride Conversion

4.2.4 CSEM Method Uncertainty Analysis

4.2.4.1 Definition of CSEM Survey Error

[𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶 𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒𝑒 𝑐𝑐ℎ𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙𝑙]

4.2.4.2 Distribution of Error

CI95 = (average error) * (1.96) * (s/n0.5)

4.2.4.3 Global Error

4.2.5 Method Minimum Reliable Chloride Concentration

4.2.6 Creation of a 3D Chloride Ion Voxel Grid

4.3 DISCUSSION OF FINDINGS