United States Region 4 EPA 904/9-82-05
Environmental Protection 345 Courtland Street, NE June 1982
Agency Atlanta, GA 30365
EPA Environmental Final
Impact Statement
Jacksonville Electric
Authority
St. Johns River Power
Park
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EPA 904/9-82-096
NPDES Application Number:
FL0037S69
Final
Environmental Impact Statement
for
Proposed Issuance of A New Source National
Pollutant Discharge Elimination System Permit
to
Jacksonville Electric Authority
St. Johns River Power Park
Prepared by:
U.S. Environmental Protection Agency, Region IV
Jacksonville Electric Authority and Florida Power and Light
Company propose to jointly construct a new source 1,200
megawatt coal-fired steam electric generating station known as
the St. Johns River Power Park on a 1,656 acre site in northern
Duval County, Florida. Station operation is scheduled to begin
in 1985. This document assesses the proposed project and
alternatives with respect to impacts on the natural and
man-made environments. Measures available to mitigate adverse
impacts are evaluated. The Draft NPDES Permit is included in
the Document for public review.
Comments or inquiries should be directed to:
F. Theodore Bisterfeld, EIS Project Officer
Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 881-7458
Approved by:
R. Jeter^^ Dtete'
Regional Administrator
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EXECUTIVE SUMMARY FOR
FINAL ENVIRONMENTAL IMPACT STATEMENT
St. Johns River Power Park
Jacksonville Electric Authority and
Florida Power and Light Company
( ) Draft
(X) Final
US Environmental Protection Agency, Region IV
345 Court land Street, N.E.
Atlanta, Georgia 30365
1. Type of Action: Administrative (X) Legislative ( )
2. Description of Action
The Jacksonville Electric Authority (JEA) and Florida Power and Light
Company (FP&L) propose to jointly construct and operate a New Source 1,200
megawatt (MW) coal-fired steam electric generating station known as the St.
Johns River Power Park (SJRPP) on a 1,656-acre site in northern Duval County,
Florida. JEA has applied to the US Environmental Protection Agency (USEPA),
the Florida Department of Environmental Regulation (FDER), and other Federal
agencies for the permits necessary to construct and operate the proposed
facility.
This document constitutes the Final EIS for the SJRPP and has been pre-
pared in accordance with the Council on Environmental Quality regulations (40
CFR Part 6) for implementing NEPA. The Final EIS includes: (1) written
comments made on the Draft SAR/EIS during the public review period (Section 3.1);
(2) USEPA's responses to the written comments (Section 3.2); (3) comments made
at the public hearing and USEPA's responses to these comments (Section 3.3);
(4) JEA's comments on the draft National Pollutant Discharge Elimination
System (NPDES) permit (Section 3.4); and (5) USEPA's responses to comments on
the draft NPDES permit (Section 3.5). In an effort to reduce paperwork and
costly preparation, the text of the Draft SAR/EIS has not been reproduced in
the Final EIS. Copies of the Draft SAR/EIS are available from USEPA, Region
IV.
The Draft SAR/EIS was prepared to satisfy both the requirements of USEPA
under the National Environmental Policy Act (NEPA) and of FDER under the
Florida Power Plant Siting Act. The Draft SAR/EIS was officially issued on
October 30, 1981. The USEPA Region IV Administrator has declared the proposed
plant to be a New Source as defined by Section 306 of the Clean Water Act.
Operation of the SJRPP would require a National Pollutant Discharge Elimina-
tion System (NPDES) permit. Issuance of this permit would be a major Federal
action significantly affecting the quality of the human environment and is
therefore subject to the provisions of NEPA. Consequently, USEPA decided that
an Environmental Impact Statement (EIS) should be prepared. Because under the
Florida Power Plant Siting Act FDER is required to prepare a State Analysis
Report (SAR) containing information similar to that required in an EIS, USEPA
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and FDER entered into a Memorandum of Understanding and agreed to prepare a
single document. The joint document (Draft SAR/EIS) met the responsibilities
of both agencies.
Need for the Project
The Florida Public Service Commission (FPSC) has the responsibility for
the determination of need for a new steam electric generating facility in
Florida. JEA and FP&L applied to FPSC for a certification for startup of
SJRPP Unit 1 in 1985 and of Unit 2 in 1987. The need for SJRPP was argued by
the utilities in two ways: (1) additional capacity was needed to provided
reliable electric service to their customers; and (2) SJRPP would reduce
electric rates through the displacement of expensive oil-fired power genera-
tion.
Although no need was found for the additional capacity to be provided by
the SJRPP for 1985 or 1987, the need for economic displacement of oil as the
utilities' primary boiler fuel was clearly established. It was estimated by
the FPSC based on "expected case" economic assumptions that the SJRPP could
save JEA $95,985,000 in 1986 and $235,055,000 in 1990 and that savings for
FP&L could reach $29,604,000 and $125,717,000 in the same respective years.
On 26 June 1981, following the analysis of a variety of alternative energy
sources and oil displacement technologies including purchase of power, conver-
sion of oil-burning units to coal or coal-oil mixtures, and additional conser-
vation, the FPSC certified the need for SJRPP Units 1 and 2 in the time frame
proposed. This decision was based on what appeared to be the best available
alternative for displacing oil. With regard to the need for additional capacity,
the FPSC found that based on the conservation goals established for Florida by
the Florida Energy Efficiency and Conservation Act (FEECA), JEA would not need
the additional generating capacity provided by the SJRPP until 1991 and FP&L
would not need the additional generating capacity until 1989. Also, the FPSC
determined that from the standpoint of electrical system reliability for
peninsular Florida as a whole, the new units would not be required until 1991.
Description of the Project
The St. Johns River Power Park site is located adjacent to the JEA North-
side Generating Station (NGS) in northern Duval County adjacent to the St.
Johns River (Figure 1). The present site consists of approximately 1,656
acres of which a portion is not considered to be suitable for development
(Figure 2). The property is primarily owned by the North Shore Corporation.
Site boundaries include New Berlin Road to the west, the Jacksonville North
Landfill to the north, and marshes to the east and south (Figure 2). Trees,
shrubs, and grasses comprise the majority of the site, totalling approximately
1,307 acres (Figure 3). Wetlands comprise approximately another 289 acres.
The site is crossed by transmission lines from the NGS as well as by the
Seaboard Coast Line Railroad which serves Blount Island.
The proposed plant will consist of two 600 MW (550 MW net) coal-fired
generating units and will be aligned along an axis running from northwest to
southeast (Figure 2). The plant rail loop will be enclosed by the service
rail which will form an oval loop around the plant structures. A common stack
will be utilized by both units. Coal handling facilities to accommodate
delivery of coal by rail and for coal storage will be located to the south of
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Figure 1. Location of the SJRPP, Northside
Generating Station (NGS), and the
Blount Island Coal Terminal.
•
Proposed
Blount Island
'•^Zj* Coal Unloading
Facility
CONSOLIDATED CITY
OF
JACKSONVILLE
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(adapted from JEA/FP&L 1981a).
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the plant rail loop. A proposed coal barge unloading facility will occupy
approximately 55 acres of land on Blount Island (Figures 1, 4, and 5). The
major coal handling facilities on Blount Island will be an ocean vessel coal
unloading wharf, a stacker-reclaimer and coal storage pile, a conveyor belt
loading area, an emergency coal stackout, and a runoff sedimentation basin and
percolation pond ("Figure 5). The coal unloader and wharf will be the only
structures on or waterward of the mean high water (MHW) line.
The SJRPP will burn approximately 3,500,000 tons of coal per year. Coal
will be delivered to the site either by 72 car unit trains or by enclosed
conveyor belt from the Blount Island coal unloading facility (Figure 5). The
alignment of the enclosed conveyor belt will roughly parallel the existing JEA
transmission line right-of-way on the Blount Island site. However, the actual
design and specific location of the coal conveyor belt have not been deter-
mined as of the date of publication of the Final EIS. Any crossings of wet-
lands or waters of the U.S. by the conveyor system will be subject to the
permitting requirements of the Corps of Engineers. Particulate emissions from
the boilers will be controlled by the use of electrostatic precipitators (ESP)
with 99.78% removal efficiencies. Sulfur dioxide (S02) emissions will be
controlled to the 90% level by the use of an FGD limestone scrubber system.
The formation of nitrogen oxides and carbon monoxide during combustion would
be inhibited by the design and proper operation of the proposed boiler, fur-
nace, and combustion air control systems. Emissions of fugitive dust from
coal handling and storage will be controlled by the use of enclosed conveyors,
fabric filters at transfer points, and wetting of open storage areas. Fugi-
tive emissions (drift) from the cooling towers will be minimized by the use of
drift eliminators.
Waste heat from the boilers will be dissipated by two natural draft
cooling towers. Approximately 49.5 million gallons per day (ragd) of makeup
water will be withdrawn from the NGS discharge channel and an average of 35
mgd of blowdown will be returned to the NGS discharge channel just downstream
of the SJRPP intake. During operation all wastewater effluent and runoff from
the site also will be discharged to the NGS discharge channel. An average of
approximately 3.8 mgd of groundwater will be used at the plant to operate^the
FGD system and provide service and process water. Bottom ash will be sluiced
to dewatering bins. Subsequently, the dewatered and essentially dry waste
material will be sold or disposed of on-site. Fly ash will be collected dry
in electrostatic precipitators and sold or landfilled on-site. High quality
gypsum (calcium sulfate) will be generated as a by-product of the FGD system
and handled and stored on-site. Any revenues from the sale of by-product
gypsum will be applied as a credit against the expense of fuel by SJRPP
(Breitmoser 1981). The on-site storage of this by-product would be either
short- or long-term depending on its marketability.
Transmission lines associated with the proposed plant will terminate at
the Normandy Substation on the west side of Jacksonville and at the Fort
Caroline and Robinwood Substations to the east of Jacksonville. Transmission
lines will be routed within the proposed preferred corridor. The majority of
the preferred corridor includes an existing transmission line right-of-way
(ROW). Where it is feasible from an engineering, environmental, and system
reliability standpoint, the final new ROW will be located parallel and adjacent
to the existing ROW. A preliminary estimate is that this should occur in over
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<
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Figure 4. Location of facility components on Blount Island in
relation to vegetation community types (JEA/FP&L 1981a).
Salt Marsh
II Open Water
Hyrlca Shrub
TO PLANT #>;
SITE ••.-.":^C
I .- ~_~.\ Baccharlo Shrub
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RAIL CAR
UNLOADING.
AREA
COAL HANDLING & STORAGE AREA
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OLD
RAILCAR
LOADING
BLDG. AREA
COAL HANDLING
BUILDING
OFFSHORE
POWER
SYSTEMS
\ DRAINAGE EASEMENT
TRANSFER POINT
RECLAIM
HOPPER
RECLAIMER
TREATMENT
CAPACITYS
MILLION
JACKSONVILLE
PORT AUTHORITY
PROPERTY
LINE
PERCOLATION
POND
ST. JOHNS RIVER
FULTON-DAME POINT CUTOFF
?EET
Figure 5. Layout of Blount Island coal unloading facility (JEA/FP&L 1981a)
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90% of its' length. The new ROW will normally be 150 feet to 200 feet in
width.
3. Major Plant System Alternatives
Alternative Sites
Alternatives were considered for each major aspect of the project includ-
ing sites and plant facilities. Beginning in 1977, a detailed siting analysis
was performed to identify potential sites and to assess their environmental
and engineering suitability for a 1,200 MW coal-fired power plant. An initial
screening yielded 20 candidate sites which were further evaluated on more
specific environmental and engineering criteria and thereby reduced to six
sites. During the following three years this series of sites was evaluated.
Although two sites in Clay County (Willis Point and Waikill) were judged to be
potentially more suitable, the JEA selected a site in Duval County known as
the Eastport Site because of the economic benefits and the potential unavail-
ability and/or political opposition faced by JEA in the selection of either of
the Clay County sites.
Cooling Systems
Cooling system alternatives were evaluated with regard to the water
source, the heat dissipation system, and the discharge receiving body. Natural
draft and mechanical draft cooling towers were evaluated for heat dissipation.
Natural draft towers were selected for use at the SJRPP because of their
energy efficiency and lower potential for ground fogging. Cooling water
source alternatives included groundwater, direct withdrawal from the St. Johns
River, and reuse of cooling water from the once-through cooling system serving
JEA's Northside Generating Station (NGS). Because of the reduced impingement,
entrainment, and dredging effects and reduced costs associated with construc-
tion, the NGS discharge was selected as the makeup source for the SJRPP cooling
system. The NGS discharge channel was also selected as the blowdown discharge
point, because of the reduced costs and the reduced environmental effects on
the River during construction and operation.
Air Pollution Control Systems
Air emission control system alternatives were evaluated based on con-
sideration of the state of the art of emission control technology, environ-
mental impacts, and cost. Major sulfur dioxide (S02) control alternatives
included regenerative reactant systems, a lime spray dryer, and lime/limestone
scrubber systems. Based on the current status of the technology, cost, and
the availability of the raw material, the limestone scrubber technology was
selected. Major particulate control alternatives included fabric filters and
electrostatic precipitators (ESP). Based on the lack of experience with
fabric filters (as applied to power plants) and cost factors, an ESP tech-
nology designed to meet BACT standards was selected. Other boiler emissions
(e.g., NOx and CO) will be controlled by boiler design.
Water/Wastewater Systems
Groundwater and surface water were considered as alternative sources of
makeup water for plant systems. Because the utilities hope to be able to
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market their high volume solid wastes, groundwater was deemed preferable to
surface water as the source of makeup to the FGD and bottom ash sluicing
systems. The use of saline water from the St. Johns River would result in
excessive chloride contamination of the by-products. Wastewater systems were
designed to recirculate and reuse water throughout the plant wherever possible
and the NGS discharge channel was selected as the preferred discharge point.
Chlorine, bromine chloride, and ozone were considered for control of biologi-
cal growths in the cooling system. Although ozone and bromine chloride exhibit
promising chararcteristics as biocides, chlorination with very careful control
of residual oxidants was selected because of reduced cost and greater operating
experience.
Solid Waste Systems
Alternative systems for the handling and disposal of high volume solid
wastes (bottom ash, fly ash, and FGD sludge) were considered. Originally, wet
sluicing to a bottom ash pond was selected as the preferred method of handling
bottom ash, but this was later changed to wet sluicing, dewatering, and dry
landfill disposal because of concerns over potential groundwater contamina-
tion. Because fly ash is collected dry in the ESP's, continued dry handling
and disposal was preferred to wet sluicing with its associated wastewater
stream. Alternatives considered for management of FGD sludge included on-site
landfilling and sale as a by-product. The utilities intend to market the
sludge (gypsum) if possible, but due to uncertainties about its final quality
it may have to be land filled on-site. A five-year test program has been
required as a condition of the NPDES permit in order to determine how best to
dispose of unmarketable FGD sludge and other high volume wastes. The program
is also intended to demonstrate that the proposed long-term solid waste manage-
ment plan will protect the quality of area groundwater resources. The test
program will require that for the first five years, all solid wastes be disposed
of in a 100-acre area adjacent to the rail loop (the previously designated
bottom ash disposal area) (Figure 2). This site is located well above the 20
foot elevation which will minimize the potential for groundwater contamination
or contamination of adjacent surface waters or wetland areas with solid waste
leachates.
The five-year solid waste test program will be conducted entirely within
the old Bottom Ash Disposal Area. The program will include testing of the
quality and quantity of leachate generated in a fully lined five-acre cell,
disposal of unmarketable, physically stabilized solid wastes in several
adjacent unlined 10-acre cells, and an extensive groundwater monitoring
program. Should groundwater criteria be exceeded, appropriate mitigative
measures (i.e., cell dewatering and/or closure) would be undertaken to prevent
contamination. USEPA will review the results of the first five years of test
program data prior to approval of any other disposal areas as part of the
required final long-term solid waste disposal plan submitted by JEA. USEPA
will require that appropriate means be taken by JEA to protect groundwater
resources based on this review. The overall program will ensure protection of
valuable groundxrater resources in the vicinity of SJRPP.
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Plant Orientations
Two major alternative orientations for the plant rail loop were con-
sidered. Both were determined to impact wetlands on the site, but the
north-south orientation was selected over the east-west orientation due to its
relatively smaller degree of impact.
4. Alternatives to the Proposed Project
Section 1502.4 of NEPA requires that all reasonable alternatives to the
proposed action be considered in the EIS process. The FPSC evaluated several
means of achieving oil savings in its certification of the need for the project
Other reasonable alternatives involving combinations of various cost-effective
oil displacement technologies also exist. Independent engineering, economic,
and environmental studies were conducted to identify, develop, and evaluate
alternatives which meet the basic economic goals on which the SJRPP was justi-
fied. A major difference between the alternatives developed for the Draft
SAR/EIS and the proposed project is that they do not in all cases provide
additional capacity, and none of them provides additional capacity equal to
that provided by the SJRPP. Instead, the alternatives were selected based on
their ability to meet the following objectives:
• The alternative would replace or save an amount of oil equivalent to
or greater than the oil saved by the proposed project;
• The alternative must replace an amount of oil for each utility (JEA
and FP&L) equivalent to the oil displaced by the proposed coal-fired
power plant;
• The alternative must not result in any loss of capacity to either
utility; and
• The alternative must be implementable within the proposed time frame
of the SJRPP project (1987).
Based on these criteria, the following four alternative power systems plus the
No Action Alternative were developed for evaluation in the Draft SAR/EIS.
Alternative 1
Alternative 1 consists of constructing refuse-fired power plants in
Duval, Brevard, Seminole, Sarasota, and Manatee Counties, conversion of JEA's
Northside Units 1 and 3 from oil-burning to a coal-oil mixture, utility spon-
sored installation of residential solar water heaters in the JEA and FP&L
service areas, purchase by JEA and FP&L of a portion of Georgia Power's Vogtle
Nuclear Plant, and construction of 150 miles of transmission line from Georgia
to Florida. This alternative would result in oil savings of 5.4 million
barrels per year by FP&L and 5.9 million barrels per year by JEA. It would
increase the capacity of the FP&L system by 550 MW and the JEA system by 228
MW.
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Alternative 2
Alternative 2 consists of conversion of FP&L's Sanford Units 4 and 5 from
burning oil to coal-firing, purchase by JEA and FP&L of a portion of Georgia
Power's Vogtle Nuclear Plant, and construction of 150 miles of transmission
line. In this alternative, JEA would rely solely on power purchase for oil
displacement. This alternative would result in oil savings of 7.2 million
barrels per year by FP&L and 5.9 million barrels per year by JEA. It would
also increase the capacity of the JEA system by 550 MW and would not change
the capacity of the FP&L system.
Alternative 3
Alternative 3 consists of conversion of FP&L's Sanford Units 4 and 5 from
burning oil to coal-firing, purchase of a portion of Georgia Power's Vogtle
Nuclear Plant, and construction of a 280 MW coal-fired power plant by JEA at
the St. Johns River Power Park site. This alternative would result in oil
savings of 7.2 million barrels per year by FP&L and 5.9 million barrels per
year by JEA. It would increase the capacity of the JEA system by 550 MW and
would not change the capacity of the FP&L system.
Alternative 4
Alternative 4 consists of conversion of FP&L's Sanford Units 4 and 5 and
JEA's Norths ide Unit 3 from burning oil to coal and purchase by JEA and FP&L
of a portion of Georgia Power's Vogtle Nuclear Plant. This alternative would
result in oil savings of 7.2 million barrels per year by FP&L and 5.9 million
barrels per year by JEA. It would also increase the capacity of the JEA
system by 72 MW and would not change the capacity of the FP&L system.
5. Summary and Comparison of the Major Environmental Impacts of the Proposed
Project and the Alternatives
Impacts of the Proposed Project
Air Resources
The operation of the SJRPP was originally projected to result in a viola-
tion of the 24-hour Florida Ambient Air Quality Standard (FAAQS) for sulfur
dioxide. This potential impact was identified through modeling performed by
FDER and was shown to result primarily due to the cumulative emissions from
the SJRPP, NGS, and the Kennedy and Southside Stations. The Conditions of
Certification therefore include a requirement that the Southside facility be
shut down under maximum load conditions at SJRPP and NGS. Air quality model-
ing has shown that this restriction will prevent any violation of the FAAQS.
The SJRPP will meet all other applicable air quality standards.
In
The Clean Air Act (as amended, 1977) requires that each state develop a
State Implementation Plan (SIP) to maintain ambient air quality standards.
developing these plans, states establish emission limits which are calculated
to ensure that the standards are met. Chapter 17-2 of the Florida Administra-
tive Code (FAC) provides the basis for determining if a proposed project meets
the requirements of the State Implementation Plan for air quality. The proposed
SJRPP will be in compliance with the provisions of Chapter 17-2, FAC, if it is
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constructed and operated as specified in the State Conditions of Certification
(Appendix 6.2). -These conditions include the requirement for shutting down
the Southside plant when the NGS and SJRPP are under maximum load as described
above.
Surface Water Resources
The proposed SJRPP will result in the discharge of trace elements, oil
and grease, chlorine, and other oxidants (TRO) into the Blount Island Channel
by way of the NGS discharge channel. Ambient concentrations of copper, cyanide,
iron "mercury, silver, aluminum (maximum only), chlorine residuals, and oil
and grease (maximum only) in the vicinity of the proposed project already
exceed Florida Class III water quality criteria with varying degrees of fre-
quency. The discharge from the SJRPP will increase the frequency and degree
of these water quality criteria violations within the mixing zone and at the
POD. Mathematical modeling by FDER has shown, however, that beyond the 31
acre mixing zone water quality will not change significantly over ambient
conditions (whether the ambient conditions exceed the Class III standards or
not). As a result, the State proposes to grant water quality variances for
several parameters in the main NGS/SJRPP discharge (NPDES (discharge number
001). The request for a chlorine variance has been denied by the State.
USSPA's position and that of the FDER on this issue is further discussed in
the responses to the public comments (W-17).
Additional water quality impacts will occur as the result of the movement
of trace elements (especially iron, copper, mercury, selenium, arsenic, and
zinc) through the coal unloading facility's percolation pond into the Fulton-
Dame Point Cutoff. Leachate from solid waste disposal areas will be controlled
by institution of a five-year test program as previously described.
Ground water
Groundwater underlying the SJRPP was originally predicted to be impacted
by leachates from solid waste disposal areas, drawdown, and chloride intrusion.
As a result of extensive review and analysis conducted during the preparation
of the Draft SAR/EIS and Final EIS, however, appropriate means have been
developed to adequately protect groundwater resources in the vicinity of the
plant site.
Solid waste leachate seepage will be controlled by the previously described
solid waste management plan. A groundwater monitoring program will be included
as part of this plan. Should violations of groundwater criteria occur, mitiga-
tive measures will be taken immediately by JEA to correct the problem. These
measures will primarily include dewatering and/or closure of the waste cells.
During construction some drawdown of the shallow aquifer system is ex-
pected during periods of average and maximum usage. Average usage by SJRPP
has been shown to create a cone of depression with 15 feet of drawdown at the
nearest site boundary and approximately 9 feet of drawdown at the nearest
off-site well. Approximately 66 Floridan Aquifer wells could experience
declines of 2 to 4 feet and approximately 137 wells could experience drawdowns
of 1 to 2 feet. Under maximum usage conditions for a 24-hour period, it was
shown that the cone of depression at the site boundary was 25 feet with a
drawdown of 14 feet at the nearest off-site well. Approximately 50 wells
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could experience water level declines of greater than 1 foot and 31 wells
could experience drawdowns of greater than 2 feet. Under either average or
maximum pumping conditions, the flow of some artesian wells and the yield of
some pumped wells in the immediate vicinity of the SJRPP would be reduced.
Any increased production from the Floridan Aquifer has the potential for
inducing increased chloride concentrations within the Aquifer. Chloride
concentrations in the Floridan Aquifer can generally be correlated with high
rates of production, particularly from deeper zones. The proposed project
could therefore contribute to the overall trend of long-term increases in
chloride contamination of the Floridan Aquifer.
Aquatic and Terrestrial Biology
During construction, approximately 84 acres of valuable seasonally flooded
wetlands and habitat for associated fauna will be eliminated. To help mitigate
this loss, JEA will provide a fenced-off 200-foot buffer strip around all
remaining wetlands on the site. This will include 65 acres of bottomland
hardwood forest (no salt marsh will be affected anywhere on the main site, and
JEA has decided not to disturb any of the salt marsh on Blount Island). As a
result of negotiation with the US Fish and Wildlife Service during the course
of completing the Final EIS, JEA has also agreed to expand the area to be
fenced off. According to this plan, additional fences will be placed on the
northwest corner of the site, and along the site boundaries on either side of
Island Drive. As shown in Figure 3, the additional fences will effectively
limit public access to both upland and wetland acres of the site. This will
provide additional protection to both upland and wetland habitats.
Clearing of 364 acres of pine flatwoods will eliminate most remaining
habitat suitable for gopher tortoises, gopher frogs, indigo snakes, and other
species which depend on gopher tortoise burrows on the site. Construction
activities and human presence in the area could temporarily disturb nesting or
feeding activities of several threatened or endangered State and Federally
listed birds which may occur in wetlands adjoining the site. These same
species (as well as other animals) could also be affected by the discharges of
treated sanitary and runoff wastewaters during construction into a headwater
of Browns Creek marsh. Dredging activities in Mill Cove for transmission
tower construction and near Blount Island will produce temporary increases in
turbidity and increases in trace element levels in the water column. A formal
Section 7 consultation conducted between USEPA and the US Fish and Wildlife
Service has indicated, however, that the construction phase will not threaten
the continued existence or disturb the critical habitat of any Federally
listed species if suitable mitigative measures are employed. As a result of
the public review process, several mitigative measures will be required by the
US Army Corps of Engineers to mitigate dredging-related impacts. These will
include limitation of dredging to late fall or winter and use of a large spoil
disposal area (Quarantine Island) to allow for maximum settling time and
detoxification. These measures are aimed at avoiding impact to the endangered
Florida manatee, a marine mammal of particular concern to the US Fish and
Wildlife Service.
During the operation phase, elevated levels of trace metals at the POD
and in the mixing zone of the main discharge from the NGS/SJRPP will produce
additional stress on aquatic life in the St. Johns River. Modeling by FDER
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has shown, however, that levels o£ trace metals at the edge of the mixing zone
of the main discharge will be indistinguishable from ambient conditions in
other parts of the River. Since the mixing zone is relatively small in re-^
lation'to the entire River, the net effects on aquatic life were projected by
FDER to be minimal outside of this area.
Leachates from solid waste areas will be controlled by the institution of
the five-year solid waste disposal plan (and eventually a USEPA-approved
long-term plan). No adverse impacts on aquatic life in adjacent marshes or
the St. Johns River estuary are currently projected. However, seepage of
trace elements from the percolation pond will produce added stress on aquatic
life in the vicinity of the Blount Island coal unloading facility.
Salt emitted from the SJRPP cooling towers could have potential effects
on the surrounding natural and man-made environments. USEPA has required that
a cooling tower drift study be conducted in order to determine drift rates,
ground level salt deposition rates, and biological impacts. Should a problem
develop, mitigative measures will be required by USEPA (Condition U of the
NPDES permit; Appendix 6.1).
The overall operation phase of the SJRPP is not projected to threaten the
continued existence or critical habitat of any Federally listed threatened or
endangered species. This conclusion was reached by the USFWS as a result of a
formal Section 7 consultation with USEPA. Similarly, no adverse impacts on
State listed species are projected to result from the operational phase of the
SJRPP.
Sound Quality
Noise resulting from the normal construction activities associated with
the project would increase noise levels by only 2 dB at the nearest receptor.
The most severe noise impact would occur during steam blowout which would
occur once or perhaps twice a year. The steam blowout event would be of short
duration (approximately 3 minutes) and would be preceded by notification to
area residents.
-Cultural Resources
The proposed project will have an adverse effect on the St. Johns River
Power Park Archaeological District, a property deemed eligible for listing on
the National Register of Historic Places (Figure 6). Sites 9Du634 and 8Du669
may be eliminated as the result of the siting of the rail loop and runoff
sediment control pond. Sites 8Du677 and 8Du671 may eventually be eliminated
as a result of land modification activities related to the siting of a 90-acre
solid waste disposal landfill (solid waste area A). Mitigation of this impact
is required as a condition of the NPDES Permit.
Socioeconomic Conditions
Construction of the SJRPP will create a temporary influx of workers to
the Jacksonville area. Additional public costs will be incurred as a result
of the additional demands on various public services by the immigrant work
force and their families. These additional costs will be temporary, however,
and are expected to be moderate. The operation of the SJRPP will generate a
xv
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SOLID WASTE
DISPOSAL AREA
SOLID WASTE
DISPOSAL AREA A
BOTTOM
DISPOSAL
ARCHAEOLOGICAL SITE
LOCATION MAP
CULTURAL RESOURCE RECONNAISSANCE
fWJPOSEO COAL FWED POWER PLANT
STE. OLMH. COUNTY , FLORIDA
St. Johns River Power
Park Archaeological
District — —
Figure 6. Location of the St. Johns River Power Park Archaeological
District, determined eligible for listing on the National
Register of Historic Places.
-------
relatively small influx of workers. Although this influx is more likely to
locate permanently in the Jacksonville area, the public costs incurred will be
minimal since they, will be spread over a longer time period and will be offset
by various tax revenues.
Land Use, Recreation, and Aesthetics
No adverse impacts on land use are projected for the main SJRPP site or
the Blount Island coal unloading facility. Although a proposed auto racing
facility could occupy a portion of the SJRPP site, licensing of the facility
is not within USEPA's jurisdiction. If the facility were to be constructed,
it would represent a conflicting land use, however. This issue would have to
be considered by FDER as specified by the Florida Power Plant Siting Act. The
greatest effects on land use will result from construction of the transmission
lines. It is probable that the selected transmission line right-of-way (ROW)
will cross limited areas of medium density residential development. These
crossings could result in the displacement of a small number of residences.
The preferred corridor also includes two recreational areas—a golf course and
tennis courts. It may be possible to avoid these areas by altering tower
designs. Most of the other land uses of the selected transmission line corri-
dor would be compatible with existing patterns. The construction and operation
of SJRPP will add tall cooling towers, a 640-foot exhaust stack, a coal pile,
and 60-foot high solid waste disposal landfill cells to the existing vista of
the area. The taller structures will be visible from residences along Heckscher
Drive and New Berlin Road.
Transportation
Construction of the SJRPP will result in several impacts on transporta-
tion systems in the area of the plant. Increased traffic on Heckscher Drive
and New Berlin Road will exceed the desired level of service for urban design
conditions and traffic congestion will occur at the following intersections
during rush hours: Interstate Highway 95 and Heckscher Drive; Main Street and
Heckscher Drive; Main Street and New Berlin Road; Main Street and Eastport
Road; and Heckscher Drive and New Berlin Road.
Adverse transportation impacts due to the operation of the SJRPP will
result from coal trains entering and leaving the site. Traffic will experi-
ence delays when the unit trains cross Main Street, Eastport Road, and New
Berlin Road. The impact will be the most severe when the trains cross these
roads during rush hours.
Human Health Impacts
The operation of the SJRPP is not projected to result in violations of
the FAAQS or NAAQS if the plant is operated according to the specifications
listed in the FDER Conditions of Certification (Appendix 6.2). All other
regulated air pollutants are predicted to be in compliance with the applicable
standards. There could be a small increase in the concentration of some
respirable trace elements in the Jacksonville area, but no increase in po-
tential health risks is anticipated.
xvn
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The St. Johns River occasionally has elevated concentrations of mercury,
a pollutant which tends to magnify (concentrate) up the food chain in the
edible portions of fishery products. A long term adverse impact on human
health has not been shown but this is not conclusive. Anticipated mercury
contributions of the SJRPP are quite small but represent a potential concern
in the 31 acre mixing zone of the plant discharge.
Comparison of Alternatives
An economic analysis of the alternatives was conducted to determine
whether they meet the economic objectives of the SJRPP. Based on this anal-
ysis, it was concluded that Alternatives 2, 3, and 4 are competitive with
SJRPP on an oil displacement and cost savings basis. These alternatives,
particularly Alternative 2, rely heavily on the purchase of relatively in-
expensive power from Georgia Power's Vogtle Nuclear Plant. The Vogtle Plant
has been steadily escalating in cost and may not, in the long run, be as
economical as currently reported. Alternative 1 is prohibitively expensive
for FP&L and for the utilities combined. None of the alternatives provide
additional capacity equal to that provided by SJRPP. The cost of providing
additional capacity at a later date was not factored into the analysis of the
alternatives.
In the Draft SAR/EIS, the proposed project and the alternatives were
evaluated and compared environmentally on a resource by resource basis.
Within the limitations of the information available, the comparison was con-
ducted equally. The obvious differences in the level of detail and the broad
economic and environmental assumptions required to make comparisons among the
alternatives prevented the identification of any one overall alternative as
being clearly superior. Nonetheless, certain generalizations regarding the
environmental impacts of the No Action Alternative, the proposed SJRPP project,
and the four alternatives were made.
As expected, the No Action Alternative would result in the fewest adverse
environmental impacts. In comparing the action alternatives, it was generally
found that the greater the magnitude of the alternative, the greater the
degree of both beneficial and adverse environmental impacts. Location was
also found to be a major factor in determining the level of impacts. Based on
its relative size, the SJRPP would generate a large overall level of bene-
ficial economic impacts while also generating a large level of adverse impacts
(e.g., land consumption, air quality degradation). Alternative 1, which
includes small scale technologies, solar water heating systems, and refuse-
fired power plants, would result in significant environmental benefits in many
resource areas since these components encourage conservation and recycling.
Similarly, Alternative 2 which includes large purchases of power from Georgia
Power Company would result in reduced adverse environmental impacts in the
northeast Florida area since the resource consumption and pollutant generation
of Plant Vogtle were not considered in the analysis. The impacts of Plant
Vogtle were assumed to occur regardless of whether JEA and FP&L purchase a
portion of its power since the Plant is certified and under construction.
Location is a major factor in determining the relative potential for
impacts of a power plant. Many of the adverse impacts of the proposed project
which cannot be completely mitigated are a function of its location. The
impact on wetlands and the exacerbation of existing water quality problems may
xvi 11
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not have occurred at other alternative sites. Based on the site selection
study, however, the lack of availability of other sites and/or political
opposition to their selection appeared to present delays that could not be
economically tolerated by the City of Jacksonville. Therefore, a more readily
available but more environmentally sensitive site was selected by JEA.
6. Mitigative Measures for the Proposed Project
Several measures to mitigate the potential impacts of the proposed pro-
ject on the surrounding environment were identified during the environmental
review process. Construction-related impacts on air resources will be miti-
gated by employing suitable fugitive dust controls and emission controls for
the burning of brush and trees during clearing. Impacts of construction on
water resources and aquatic life will be mitigated by implementation of a
comprehensive erosion and sedimentation control plan and effective treatment
of wastewater discharges. Construction-related impacts on wetlands will be
mitigated by establishment of a fenced-off, 200-foot buffer zone around re-
maining wetlands on the site. Additional fencing will also be placed around
the periphery of the site to further limit public access to both upland and
wetland areas (Figure 3). This will allow these habitats to be disturbed
less, thereby improving their value to wildlife. The feasibility of a gopher
tortoise relocation program will be considered to mitigate impacts on this
protected species which inhabits the main site. Because of the potential
difficulties involved in such a program, close coordination with the State of
Florida prior to its implementation is recommended. Construction impacts
along the transmission line ROW will be minimized by adherence to Federal
Power Commission guidelines.
Potential impacts on manatees in Mill Cove and Blount Island Channel due
to dredging will be minimized by conditions placed on the Section 10/404
permit. Among these will be the requirement that dredging be conducted during
late fall or winter months. Since this is the time of year when manatees are
least active, there would be a lower probability of adverse impacts to occur
due to increased turbidity or elevated levels of trace metals. Furthermore,
the State has required that turbidity screens be employed during dredging and
has set limits on allowable turbidity levels (Appendix 6.2, FDER Conditions of
Certification). All dredge material will be disposed of in the Quarantine
Island site. This area is an approved US Army Corps of Engineers site with
more than enough capacity to store the dredge material. The large size of the
storage area will allow for maximum settling time and detoxification of the
dredged material.
Impacts on the designated St. Johns River Power Park Archaeological
District will be mitigated by JEA in accordance with the Memorandum of Agree-
ment (MOA) between the Advisory Council on Historic Preservation, the State
Historic Preservation Officer, and USEPA (Appendix 6.4). No construction or
construction-related activities are to occur within 200 meters of any ident-
ified archaeological site pending USEPA approval of the mitigation plan.
No herbicides will be used in the initial clearing operations of trans-
mission line ROW's. The use of herbicides for maintenance will be minimized.
Herbicides will be used in strict accordance with USEPA-approved products and
procedures. During ROW clearing operations and transmission line tower con-
struction, an undisturbed buffer 7.6 meters in width will be maintained adja-
xix
-------
cent to all streams, rivers, or lakes. Trees within this zone will be selec-
tively topped without disturbance to their root mats.
Operation-related impacts on surface waters will be controlled to the
best extent practicable by use of wastewater treatment facilities. A bioassay
program will be required as a condition to the NPDES permit (Appendix 6.1) to
determine the toxicity of the main NGS/SJRPP discharge. This will determine
if more stringent permit limitations are necessary to protect aquatic organisms.
Air emissions will be controlled with electrostatic precipitators, FGD systems,
and by boiler design. Fugitive coal dust will be controlled with water spray
dust suppression systems, enclosed conveyors, and fabric filters. Cooling
tower drift will be controlled to a level of 0.002% of total recirculating
water volume although controls are available to limit drift to 0.0005%. An
18-month drift study will be required as a condition of the NPDES permit in
order to determine potential salt drift impacts on surrounding natural areas
and man-made communities. A site erosion and sedimentation control plan will
help to minimize degradation of surface water quality in the vicinity of the
SJRPP. All solid wastes generated during the first five years of the plant's
life will be disposed of in a specially designated 100-acre area immediately
adjacent to the rail loop (the area previously identified as the bottom ash
disposal area). This area is located at or above the 20-foot elevation.
USEPA will require a five-year test plan to determine potential impacts on
surface and groundwater resources from solid waste leachate. USEPA must also
approve all future solid waste disposal areas on the SJRPP site pending the
results of the initial five-year program and review of JEA's long-term solid
waste management plan. The most significant mitigation relative to solid
waste management is the marketing of the FGD sludge as gypsum and combustion
ash as construction material. This would potentially eliminate most long-term
solid waste disposal problems for JEA.
7. Unresolved Issues
JEA and FP&L have resolved some of the outstanding environmental issues
identified in the SAR/EIS associated with construction and operation of the
SJRPP. These include issues relating to air quality, solid waste disposal,
wetlands, and threatened and endangered species. The specific mode for disposal
of potentially hazardous low volume waste has not been determined, and cannot
until the wastes are tested after operation of the first unit. JEA has stated
that all hazardous low volume wastes generated will be identified and disposed
of off-site at a RCRA permitted landfill and that such wastes would not be
permanently stored on-site.
The long term water quality and environmental effects of elevated mercury
levels in the combined mixing zone of the NGS and SJRPP are not fully known.
It appears likely that the concentrations of mercury actually expected in the
mixing zone will be less than those used in the analysis of worst case condi-
tions in the Draft EIS. Also, based on the fish tissue data presently avail-
able, no known existing health risks are associated with elevated mercury
levels in the St. Johns River. However, this assessment of the situation
cannot be regarded as conclusive. The actual long terra effects of persistent
elevated levels of mercury in the mixing zone on the quality of the fisheries
would have to be further studied to make more definitive statements.
xx
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To resolve the mercury concern USEPA will take three actions. The first
is to expand the data base on present concentrations of the pollutant in fish
and shellfish. Commonly taken species are being collected from the area of
the proposed plant and analyzed for mercury content. These data will be
reported in the Record of Decision which will be distributed regarding this
project. If, as expected the fish flesh data verify the limited existing
data, no significant impact is expected on the St. Johns River fishery from
the SJRPP mercury discharge. If unexpected high levels are indicated, USEPA's
decisions on NPDES Permit issuance and required approval of FDER's proposed
water quality standards variance to JEA could be affected. The second action
is to require the JEA to annually reevaluate the technology available to
control mercury discharge from the flue gas desulfurization system blowdown,
the major mercury source, and to provide for segregation of that wastestream
if greater treatment is necessary. In addition, JEA will be required to
investigate bioaccumulation of mercury in the mixing zone so that any uptake
attributable to the new plant can be closely monitored.
8. USEPA's Environmentally Preferred Alternative and Recommended Action
It must be noted that based on the initial findings of the Draft SAR/EIS,
various alternatives to the proposed project are available which appear to be
comparable to the SJRPP from an economic and an environmental standpoint.
Since these alternatives meet the oil back-out goals of the proposed project,
it can be argued that one of these alternatives could be implemented. The
selection of one of the alternatives would defer a decision on the SJRPP for
approximately three to four years when possibly the need for the project could
be better predicted and mitigation of impacts might be greater through im-
proved technology. The major alternative components, purchase of part of the
Vogtle Nuclear Plant and conversion of the oil-fired Sanford Units 4 and 5 to
coal-firing, are not necessarily pr-ecluded, however, by proceeding with SJRPP
at this time. In fact, conversion of power plants from oil t'o coal is arguably
facilitated by construction of additional capacity at SJRPP. JEA and FP&L
have indicated that careful analysis of these options is underway and if found
to be advantageous will be pursued.
Nevertheless, SJRPP has been shown to be an economically advantageous
project for Jacksonville, its citizens, and FP&L and its customers. Not only
does it displace oil, but it also provides additional generating capacity for
the utilities which would have to be provided at a later time as system demand
rises and older units are phased out of use. USEPA finds the proposed project
(SJRPP) environmentally acceptable with the proposed NPDES Permit Conditions.
However, USEPA has determined that the following features of the SJRPP would
be environmentally preferable to those selected by the applicant:
• Sulfur dioxide emission control consisting of a lime spray dryer or a
lime/limestone FGD scrubbing system with by-product resource recovery;
• Bottom ash and fly ash management consisting of dry handling and sale
as a by-product;
• On-site disposal of unmarketable FGD sludge, bottom ash, and fly ash
in landfillcells lined with a material with a permeability no less
than 1 x 10 cm/sec;
xxi
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• Coal delivery over land by rail rather than from the proposed Blount
Island coal unloading facility; and
• Natural draft cooling towers with a drift elimination system that uses
0.0005% of the total recirculating volume flow rather than 0.002%.
These systems are preferred but not required. JEA and FP&L have demonstrated
that other systems are environmentally compatible and can be approved. USEPA
regulations provide 30 days public review of this Final EIS and the Draft
NPQES Permit (Appendix 6.1) before USEPA may issue the permit. A Record of
Decision will be circulated at the time of *"he permit issuance. In addition,
USEPA must approve or disapprove any variance to water quality standards
granted for the project by the State of Florida.
9. FDER's Recommendations
FDER recommends that the SJRPP be certified by the Governor and Cabinet.
This recommendation is based on the premise that all required Conditions of
Certification (Appendix 6.2) are met.
xxii
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ................................................ ^
1. Type of Action .......................................... ^
2. Description of Action ................................... _ 1
3 . Maj or Plant Sys tern ...................................... ix
4. Alternatives to the Proposed Project .................... xi
5. Summary and Comparison of the Major Environmental
Impacts of the Proposed Project and the Alternatives-.-. xii
6. Mitigative Measures for the Proposed Project ............ xlx
7. Unresolved Issues ....................................... xx
8. USEPA's Environmentally Preferred Alternative and
Recommended Action ...................................... xxl
9 . FDER' s Recommendations .................................. xxii
LIST OF FIGURES .................................................. xxiv
LIST OF TABLES [[[ xxv
1.0 PREFACE
2 . 0 ERRATA [[[ 2
2.1 ERRATA FOR THE DRAFT SAR/EIS ........................... 2
2 . 2 ERRATA FOR THE TECHNICAL REFERENCE DOCUMENT ............ 4
3.0 PUBLIC PARTICIPATION ........................................ 6
3 . 1 WRITTEN COMMENTS ON DRAFT SAR/EIS ...................... 6
3.2 RESPONSES TO WRITTEN COMMENTS ON DRAFT SAR/EIS ......... 64
3.3 PUBLIC HEARING COMMENTS AND RESPONSES BY USEPA ......... 94
3.4 JEA COMMENTS ON DRAFT NPDES PERMIT ..................... 113
3.5 USEPA RESPONSES TO COMMENTS ON DRAFT NPDES PERMIT ...... 137
4.0 COORDINATION ................................................ 14°
5.0 LIST OF PREPARERS ........................................... 141
5.1 US ENVIRONMENTAL PROTECTION AGENCY ..................... 141
5.2 WAPORA, INC ............................................
6.0 APPENDICES
6.1 PROPOSED NPDES PERMIT AND PERMIT RATIONALE
6.2 PROPOSED FDER CONDITIONS OF CERTIFICATION
6.3 ENDANGERED SPECIES SECTION 7 CONSULTATION ADDENDUM
6.4 ARCHAEOLOGICAL MEMORANDUM OF AGREEMENT
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LIST OF FIGURES
No. Page
1. Location of the SJRPP, Northside Generating Station, and
the Blount Island coal unloading facility .................... ±±±
2. General layout of the proposed SJRPP and associated
facilities [[[ -j_v
3. Vegetation community types on the SJRPP site ................. v
4. Location of facility components on Blount Island in relation
to vegetation community types ................................
5. Layout of the Blount Island coal unloading facility
6. Archaeological district designated by the Florida SHPO
7. Relationship of the main site and Blount Island to the
historically defined (FEMA) 100-year floodplain .............. 55
8. Most recent (1981) map of Blount Island showing existing
topography and 100-year floodplain in relation to coal
unloading facilities ......................................... 55
9. Mercury concentrations in the NGS/SJRPP mixing zone for FGD
waste concentrations of 70 yg/1 and 7 yg/1 of mercury and an
ambient river concentration of 0.6 yg/1 (Envirosphere 1982).. 72
10. Cone of depression around SJRPP for two wells discharging
3,600 gpm [[[ 90
11. Cone of depression around SJRPP for three wells discharging
-------
No.
LIST OF TABLES
?aee
1. Corrections to be made concerning the status of species of
State concern listed in table 1.1-4, 1.2-1 of the Technical
Reference Document and 3.5-4 and 3.5-5 of the Draft SAR/EIS,
2. List of persons and/or organizations who provided written
comments on the Draft SAR/EIS
3. Cross references for issue categories and written comments
on the Draft SAR/EIS submitted to USEPA during the public
review process
4. Cross references for issue categories and public hearing
c omment s
XXV
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1.0 PREFACE
In October of 1981, the US Environmental Protection Agency (USEPA) pub-
lished and distributed a Florida State Analysis Report (SAR)/Environmental
Impact Statement (EIS) on the St. Johns River Power Park, proposed by the
Jacksonville Electric Authority and Florida Power and Light Company. The
joint document was written to satisfy both the requirements of USEPA under the
National Environmental Policy Act (NEPA) and of the Florida Department of
Environmental Regulation under the Florida Power Plant Siting Act. Although
the Draft SAR/EIS was a complete document, much of the detailed technical
information and supporting data were presented in a supplemental Technical
Reference Document. The Draft SAR/EIS was distributed for review to approp-
riate Federal, State, and local agencies and to interested individuals. The
Technical Reference Document was made available for review at a number of
locations and was distributed on a limited basis.
This Final Environmental Impact Statement has been prepared to conform
with the Council on Environmental Quality regulations (40 CFR Part 6) for
implementing NEPA. The essence of the NEPA decision process is contained in
the Executive Summary for the Final EIS. The Executive Summary describes the
existing problem requiring a decision, available alternatives and their asso-
ciated impacts, major concerns and issues, and USEPA's conclusions and decision,
In an effort to avoid excessive paperwork and costly preparation, the
text of the Draft SAR/EIS has not been reprinted in the Final EIS. The sup-
porting information furnished in the Draft SAR/EIS and its Technical Reference
Document are incorporated herein by reference. Both documents were widely
distributed for public and agency review.
Chapter 2.0 includes corrections to the text of the Draft SAR/EIS based
on the results of the public review process. Chapter 3.0 contains a descrip-
tion of the public participation program conducted for the Draft SAR/EIS.
Included in Chapter 3.0 are copies of written communications submitted to
USEPA in response to the Draft SAR/EIS followed by USEPA's responses to each
individual comment. These are followed by a summary of the issues raised at
the public hearing for the Draft SAR/EIS and a point-by-point response to the
hearing comments. A summary of each of the comments raised is provided due to
the length of the public hearing testimony. Sections 3.4 and 3.5 present
comments made on the Draft NPDES permit by JEA and USEPA's responses.
Chapter 4.0 lists the agencies and groups to whom the Final EIS will be
sent for review and comment and Chapter 5.0 identifies the individuals in-
volved in its preparation. Chapter 6.0 is an Appendix to the Final EIS con-
taining the NPDES permit for the St. Johns River Power Park, the FDER Con-
ditions of Certification, the addendum to the original US Fish and Wildlife
Service Section 7 consultation results, and other information.
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2.0 ERRATA
This section provides necessary corrections to substantive errors and
omissions in the Draft SAR/EIS (Section 2.1) and the Technical Reference
Document (Section 2.2). Included as Appendix 6.5 to the Final EIS are pages
4-137 and 4-138 which were omitted from some copies of the Draft SAR/EIS
during printing.
2.1 ERRATA FOR THE DRAFT SAR/EIS
Table 1 lists corrections made concerning the Florida legal status of
species reported on Tables 1.1-4, 1.2-1 of the Technical Reference Document
and Tables, 3.5-4, and 3.5-5 of the Draft SAR/EIS titled "Rare, threatened,
and endangered species which occur or could potentially occur in the vicinity
of the NGS and SJRPP and Sanford sites." The following additional corrections
in the Draft SAR/EIS should also be made on the pages indicated:
Page
2-45
2-45
3-42
3-48
3-48
Paragraph Line
Column 3 2
Column 4 2
4-51
6-19
Correction
1
Add footnote to column titled "Annual O&M
Footnote: Total Annual Cost (Annual O&M
including initial debt retirement).
2
Add footnote to column titled "Equiv. Annual .'
Footnote: Capitalized annual cost.
Change Florida status of the gopher tortoise
from "threatened" to "species of special
concern. "
Change Florida status of the wood stork from
"threatened" to "endangered."
Change Florida status of the red-cockaded
woodpecker from "endangered" to "threatened"
and "endangered" according to the Federal
government.
Delete portion of paragraph reading "...Under
average. . .less than 24 hours)." and replace
with the following: Under conditions of
average long-term production of 3,600 gallons
per minute from the two wells at the plant
site, nine wells could potentially be affected
by drawdown of greater than 4 feet. Of
those nine wells, five are associated with
the Northside Generating Station, one is at
the North Landfill, one is the Capital
Concrete well (D-1255, the nearest well to
the site), and only two (D-402 and D-737)
would appear to be associated with private
homes. An additional six inventoried wells
and 60 potential Floridan wells associated
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Table 1. Corrections to be made concerning the status of
species of State concern listed in Tables 1.1-4, 1.2-1
of the Technical Reference Document and 3.5-4, and
3.5-5 of the Draft SAR/EIS.
Common Name
Gopher tortoise
Florida gopher frog
Eastern indigo snake
West Indian manatee
Arctic peregrine falcon
Red-cockaded woodpecker
Osprey
Sherman's fox squirrel
Status given in
original Table
of SAR/EIS
Threatened
Threatened
Threatened
Threatened
Endangered
Endangered
Threatened
Threatened
Correct State Status
Species of Special Concern
Species of Special Concern
Species of Special Concern
Species of Special Concern
No State Status
Threatened
Not Currently Listed
Species of Special Concern
-------
Pa ragraph Line Correction
with private homes could experience drawdowns
in the range of 2 to 4 feet, and 17 inventoried
wells and 120 potential wells associated
with private homes could experience drawdowns
between 1 and 2 feet. Under conditions of
maximum production of 5,400 gallons per
minute for a short period of time (assumed
to be no more than 24 hours), nine inventoried
wells and seven potential wells associated
with private homes might experience drawdowns
greater than 6 feet. An additional 41
inventoried wells and 400 potential wells
associated with private homes could experience
drawdowns of greater than one foot.
4_73 2 2 Omit word "rare" from sentence
4_73 5 1 Delete line 1, and replace with "Migratory
birds which pass...".
4_73 7 1-2 Delete Florida scrub jays since it is not
probable that they occur on the site.
(Florida scrub jays are highly sedentary
and there is no suitable habitat on the
main site).
4_77 For Table 4.7-2 in column labelled "Esti-
mated Concentration at Edge of Mixing Zone,"
under avg. column for cyanide, iron, and
aluminum, change the letter 1 to L; also
change footnote 1 to L.
4_3! 4 3 Change 0.9 mg/m2/hr to 0.5 mg/m2/hr.
2.2 ERRATA FOR THE TECHNICAL REFERENCE DOCUMENT
The following corrections in the Draft Document should be made on the
pages indicated:
0_20 2 2 Change Florida status of the gopher tortoise
from "threatened" to "species of special
concern."
0_2o 3 10 Change Florida status of the gopher frog
from "threatened" to "species of special
concern."
0_2o 4 3 Change Florida status of the Eastern indigo
snake from "species of special concern" to
"threatened."
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Page Paragraph Line • Correction
0-21 3 5 Delete Christmas count data since they
are based on observations of eastern kestrels,
a separate subspecies of the American kestrel.
0-21 4 1-2 The osprey is no longer recognized by the
Florida GFWFC as a threatened species.
0-22 3 2 Change Florida status of the red-cockaded
woodpecker from "endangered" to "threatened."
0-23 1 3 Change the Florida status of the West Indian
manatee from "threatened" to "endangered."
0-29 6 7 Delete "rare" and replace with "species of
special concern."
0-31 4 4 Delete Florida scrub jay.
0-32 2 1-2 Delete line 1, and replace with "Migratory
birds which pass...".
0-32 3 1 Delete Florida scrub jays since it is not
probable that they occur on or near the
site.
0-33 1 4 Following "threatened" insert (Federal).
0-36 4 9 Delete "rare" and replace with species of
concern.
0-42 For Table 2.2-1 in column labelled "Estimated
Concentration at Edge of Mixing Zone," under
avg. column for cyanide, iron, and aluminum,
change letter 1 to L; also change footnote 1
to L.
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3.0 PUBLIC PARTICIPATION
The Draft Florida State Analysis Report/Environmental Impact Statement
was published in October 1981 and made available to the Council on Environ-
mental Quality and the public. The Draft SAR/EIS was provided to numerous
Federal, State, and local agencies as well as concerned individuals, interest
groups, and public officials. Notice of a joint public hearing held by the US
Environmental Protection Agency in conjunction with the Florida Department of
Environmental Regulation on the Draft SAR/EIS was published 29 October 1981.
The public hearing was held 1 December 1981 and was attended by 114 participants.
The public hearing transcript is summarized by issue and speaker in this
chapter.
The comment period on the Draft SAR/EIS remained open through 14 December
1981. Section 3.1 includes the letters which were received during the comment
period. The designations in the margins of the letters (numbered W-l through
W-120) identify those specific comments for which responses have been developed
by USEPA in Section 3.2. Section 3.3 summarizes each issue raised at the
public hearing as well as appropriate responses by USEPA. The designations
P-l through P-49 identify the comments. Sections 3.4 and 3.5 present comments
on the draft NPDES permit made by JEA and responses by USEPA to certain of
these comments.
3.1 WRITTEN COMMENTS
This section presents the written comments on the Draft SAR/EIS which
were made during the public review period. The comment letters are listed
sequentially according to the dates that they were received by USEPA. Each
comment has been assigned an identification number (W-l through W-120) .
Immediately following the letters (Section 3.2), USEPA's responses to each
numbered comment are presented. Table 2 provides an index of each comment and
identifies the pages on which responses by USEPA are listed. Table 3 provides
an index of comments by subject or resource area.
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Table 2. List of persons and/or organizations who provided written comments
on the Draft SAR/EIS.
Person or Agency
Thomas D. Sims
Department of the Air Force
C.L. Irwin
Florida Department of Transportation
D.T. Van Liere
Offshore Power Systems
Glenn C. Woodard Jr.
Federal Emergency Management Agency
Robert D. Raisch
US Forest Service
Barney L. Capehart
Sierra Club
Horace Black
Heckscher Drive Fish Camp,
Marina and Business Association
George L. Reinert
Florida Department of Agriculture &
Consumer Services
Charles N. Straub
US Department of Housing and Urban
Development
Donald J. Hankla
US Department of the Interior
Comment
Number Page
W-l
W-2
10
11
W-3 through W-7 14-15
W-8, W-9
16
W-10 through W-l5 17
W-l 6
W-l 7
19-21
23
W-18 through W-20 24
W-21, W-2 2
26
Response
Number Page
W-l
W-2
W-3 through 7
W-8, W-9
63
63
63
64,67
W-23 through W-27 27-30
W-10 through W-l5 67,68
W-l6 68-71
W-l7 71-73
W-18 through 20 74
W-21, W-2 2 74
W-23 through W-27 74-76
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Table 2. List of persons and/or organizations who provided written comments
on the Draft SAR/EIS (continued).
00
Person or Agency
Sherrard Coleman Foster
Defenders of Wildlife
Frank S. Lisella, Ph.D.
Department of Health & Human Services
Mat Roland
Mat Roland Seafood Company
Stella D. Andrews
Sea Oats Garden Circle
Lee Pelej
Roy L. Beach
Law Offices of George W. Kent, Jr.
Bruce Blanchard
US Department of the Interior
William R. Fryan
Florida Lung Association
Mrs. Shirley Rogers
Robin Leigh
Royce Lyles
JEA
C omme nt
Numbe r Page
W-28, W-29
W-35
31-36
W-30 through W-34 37-38
39-40
W-36 through W-41 41-43
W-42 44
W-43 through W-47 45-50
W-48 through W-58 51-54
W-59 through W-64 55
W-65 through W-76 56
W-77 through W-l 19 57-62
W-120 through W-147 133-148
Response
Numbe r Page
W-28, W-29
W-35
W-36 through W-41
W-42
76-77
W-30 through W-34 77-80
80
81
81
W-43 through W-47 81-82
W-48 through W-58 83-88
W-59 through W-64 88
W-65 through W-76 88-91
W-77 through W-l19 91-101
W-120 through W-147 149-152
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Table 3. Cross references for issues and written comments on the
Draft SAR/EIS submitted to USEPA during the public review process.
Written comments made on major issues are listed under each major
issue category.
Air Quality
W-7
W-21
W-60
W-61
W-62
W-63
W-64
W-65
W-88
W-94
W-102
W-108
W-lll
P-36
Terrestrial Ecology
W-19
Wetlands Impacts
W-25
W-38
W-46
W-50
W-54
W-57
W-58
Groundwater Impacts
W-8
W-9
W-33
W-34
W-36
W-41
W-42
W-44
W-45
W-55
W-56
W-66
W-67
W-68
W-69
W-70
W-71
W-7 3
W-84
W-8 5
W-8 6
W-8 9
W-9 7
W-9 8
W-103
W-107
W-113
Surface Water Quality
W-10
W-17
W-23
W-24
W-28
W-29
W-35
W-37
W-40
W-43
W-54
W-55
W-59
W-7 3
W-74
W-7 5
W-9 6
W-9 9
W-112
W-114
W-115
Alternatives to SJRPP - $
W-16
W-47
W-48
W-52
W-7 8
W-79
W-80
W-8 2
W-8 3
W-8 7
W-91
W-9 2
W-93
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DEPARTMENT OF THE AIR FORCE
REGIONAL CIVIL ENGINEER, EASTERN REGION (HQ AFESC)
526 TITLE BUILDING. 30 PRYOR STREET. S.W.
ATLANTA, GEORGIA 30303
ROV2 27 October 1981
Draft Environmental Impact Statement (DEIS), State Analysis Report,
Jacksonville Electric Authority, St. Johns River Power Park (NPDES FL0033869)
U. S. Environmental Protection Agency
Region IV
Attn: Mr. Johr. E. Hagan, III, P. E.
Chief, EI3 Branch
3^5 Courtland Street, N. S.
Atlanta, Georgia 30365
Development of the subject project will not adversely affect Air Force
operations in Florida. Thank you for the opportuntiy to review 'this
DEIS. Our point of contact is Mr. Winfred G. Dodson, commercial telephone
number 221-6821/6776.
THOMAS D. SIMS Cy to: USAF/LEEV
Chief
Environmental Planning Division
>(.: -":!{{
;V U-J Of) 'Cp; ;»;;
'"
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Florida * V Department of Transportation
>
60S Suwannee 3'roe! *ai:.inassee
80S GRAHAM Xi^X \ 1 JACOB 0. VAHN
GOVERNOR '^. I SECRETAHY
November 2, 1981
Mr. F. T. Bisterfeld
EIS Project Officer
U. S. Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Dear Mr.. Bisterfeld:
Subject: Florida Power Plant Siting
Application No. PA 81-13
The following comments are issued pursuant to review of
the subject document.
There should be close coordination with the Lake City
District Department of Transportation Office relative to
the increase in traffic and the congestion predicted due to
constructing this plant. Any modifications to the trans- ,
portation system proposed by the Department of Transportation s
should be given consideration as your plant construction
progresses. Alternate rail crossing designs should be con-
sidered in lieu of at-grade crossings to alleviate delays
predicted during rush hours.
We appreciate the opportunity to comment.
C. L. Irwin, Administrator
Environmental Impact Review
CLI/mnb
cc: Mr. W. W. Page
11
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Offshore Power Systems
November 16, 1981
Mr. Ted Bisterfeld
EIS Branch
U. S. Environmental Protection Agency
Region IV
345 Court!and Street, N.E.
Atlanta, Georgia 30365
Subject: Offshore Power Systems Statement for the
Record of Public Hearing on St. Johns River
Power Park of December 1, 1981
Dear Mr. Bisterfeld:
In accordance with paragraphs 4, 5 and 7 of the Notice
of Certification Hearing on an Application to Construct
and Operate an Electrical Pov/er Plant on a site to be
located near Jacksonville, Florida as it appreared in
the October 31, 1981 Times-Union and Jacksonville Journal,
enclosed is a Statement from Offshore Power Systems to
be considered as comments and/or a petition to the
hearing officer.
OPS solicits your consideration of the noted serious
impacts upon it in your preparation of the final Environ-
mental Impact Statement and requests to be kept apprised
of future hearings, releases, or other developments on
^his certification action.
I am mailing a copy of the same Statement to Mr. Chris
H. Bentley of the Division of Administrative Hearings
for his consideration in the certification deliberations
and to Mr. Hamilton S. Oven, Jr. of DER for his consider-
ation in preparing the final SAR.
.>','ENT
12
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November 16, 1981
Mr. Ted Bisterfeld
Page 2
Please contact the undersigned or Mr. H. H. Fawcett, Jr.
if you require additional information on this matter
which is of the cravest concern to OPS.
Very truly yours,
D. T. Van Liere
Director of Operations
DVLipac
Enclosure
cc: Mr. A. R. Collier, President, OPS
Mr. W. J. Staten, Vice President, Administration, OPS
Mr. J. R. Mackroth, Managing Director, JPA
13
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STATEMENT FOR THE RECORD
December 1, i981, Public Hean'nn hv the State Division of Administrative Hearings,
"EPA, and the State Department of Environmental Regulation
on the
St. Johns River Power Park Certification
Offshore Power Systems (OPS) has constructed a major manufacturing facility
on the eastern half of Blount Island, Jacksonville, Florida, for the purpose of
manufacturing floating nuclear power plants. The OPS facilities are contiguous
to the site of the proposed St. Johns River Power Park coal unloading facilities
on Blount Island.
OPS does not take a position for or against the proposed coal fired power_
plants, however, there are several serious imoacts to OPS brought about by their
construction with most impacts having to do with the coal handling facility's
location on Blount Island. The one most severe impact will not be acceptable and
that is the multiple blockage of the sole entrance to the OPS manufacturing facility
by the coal shuttle train rail loop.
It should be noted that the only means of vehicular access to the OPS manu-
facturing facility and the other activities on Blount Island is via a two-lane
vehicular bridge across the St. Johns River. The bridge connects on the mainland
with Hecksher Drive (State Road 105) which is a two-lane paved arterial between
the built-up areas of Jacksonville to the west and Ft. George to the east. Approxi-
mately 90 percent of the Blount Island traffic arrives from or departs for the west.
The sketches in the Certification Application and the draft EIS/SAR show a
planned rail loop from the Blount Island coal unloading facility to the Power
Park which crosses Heckscher Drive to the west of the vehicular bridge and the
main access road to the OPS manufacturing facility in three places. Use of :he
railroad track for coal shuttle trains as currently proposed would, therefore,
block or severely reduce access and egress to and from the only bridge over the
St. Johns River to Offshore Power Systems' manufacturing facility for: (1) personnel
going to and from the facility, (2) heavy truck transport of product materials and
equipment, and (3) emergency vehicles in the event of an accident. Jhis blockage
would occur both when empty cars were coming to be filled and when full coal cars
were returning to the power plant.
Discussions have indicated that the Jacksonville Electric Authority is
investigating alternatives to the use of a shuttle train to transport coal from
the Blount Island coal unloading facility. There have been, however, no indications
that a final decision on the transport method has been reached.
Because a coal shuttle train loop on Blount Island will: (1) block or severely
restrict access to our manufacturing facility; (2) nave to be constructed part,ally
on our property; and, (3) cause blockage of Heckscher Drive from the west and access
to the only bridge across the St. Johns River leading to Blount Island, Offshore
Power Systems request that, as a condition to siting certification approval, you
require the Jacksonville Elctric Authority to design and construct a method other
than a coal shuttle train for transporting coal from the Blount Island unloading
facility to the St. Johns River Power Park.
14
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OPS submitted a Statement for the Record after the April 9, 1981 public
hearings on this project. Some of the several concerns expressed in that_statement
wiii no doubt be mitigated by the various permit conditions as indicated in the .
Draft EIS/SAR. It appears that reasonable solutions to remaining serious impacts
that would be caused' by the construction on Blount Island could be found through
negotiation and cooperation between JEA and OPS. JEA should be required to resolve
these points with OPS before authorization to proceed (ATP) is granted.
These remaining points may be summarized as follows:
1. Railroad Service to OPS Facilities - The OPS manufacturing operations on
Blount Island will be served by a single track extension to the existing railroad
trackage now terminated near the 0DS property line at the south side ot the isiand.
This trackage will serve the major manufacturing areas and a central warehouse
complex on OPS property. AT! OPS rail traffic will transit JPA property on shared
right-of-way and will be merged with existing JPA Terminal rail traffic to snare
the single-track railroad bridge access to Blount Island. The proposed it. Johns
River Power Park coal shuttle operations, apparently, will use the same single
track railroad bridge to the mainland. This will impede the smooth flow of al i
other rail traffic on and off Blount Island. Alternate means of coal transport
woild eliminate this conflict.
2 New Railroad Trackage on Blount Island - Sketches accompanying the permit
aDplicatioHTTndicate that the easterly coal shuttle railroad trackage will be
constructed partially on a drainage and utility easement held by OPS on JPA Property;
and partially on wholly owned OPS property. Construction of trackage on the OPS
drainage easement must not impede the free drainage of OPS property nor interfere
with construction by OPS of required utilities and access trackage within the ease-
ment.
A portion of the easterly coal shuttle trackage is also shov.n to be
constructed on the easterly side slope of an elevated dike on JPA property which
borders wet lands and a marsh area on OPS property. This segment of trackage, IT
it is built, must be constructed in a manner to prevent erosion damage or siltation
on OPS property. Again, an alternate transport system would eliminate the concern.
3 Routing of Transmission Corridor Across Blount Island - Alignment of the
proposed transmission corridor north of Blount Island with the continuation of the
corridor across Mill Cove south of Blount Island, as shown on sketches in the
permit application, suggeststhat the route across Blount Island will be a|m°st
wholly on OPS property/ This routing should be reviewed with OPS prior to further
consideration to assure compatibility with OPS manufacturing operations and future
land use.
4. Air Quality Considerations - The St. Johns River Power Park and its_proposed
coal unloadTn? facility on Blount Island are in an air quality area shared with uhe
OPS manufacturing facility and JPA terminal operations. The coal unloading operation
are extremely dust inducing and will be in competition with the necessary open air
metal blasting operations of OPS for utilization of any available PSD increment in
total suspended particulates. Strinqent dust control measures must be applied to
the coal unloading, storage, and transfer operations to prevent impairment ot the
OPS ability to obtain any air pollution permit'; necessary for manufacturing.
15
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Federal Emergency Management Agency
Region IV 1375 Peachtree Street, NE Atlanta, Georgia 30309
November 17, 1981
Mr. John E. Hagan III, Chief
EIS Branch
U. S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Re: NPDES # FLOO33869
Dear Mr. Hagan:
Upon review of the Environmental Impact Statement, Jacksonville Electric
Authority, St. Johns River Power Park (Public Notice No. PH81FL196), we have
the following comments with regards to Executive Order 11988.
1. All structures should be located outside of the 100-year floodplain, loo
or 500-year floodplain if a critical action is involved. . JS
If Number (1) is determined to be impracticable then,
2. Any insurable structures must be elevated or flood-proofed (if
nonresidential) to elevation 7.0' MSL, the stillwater elevation of
the 100-year storm. This is a local government requirement as a
part of their floodplain management ordinance. We recommend that
even a higher elevation be used (8.Q1 MSL) based on a recent, but
unpublished restudy.
We have enclosed a copy of the Flood Insurance Rate Map for this area. We
thank you for this opportunity to comment.
Sincerely yours.
oodard, Jr.
Director
Insurance and Mitigation Division
Enclosure
\r
- .. ..
REGION
16
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United StatSS
Department of
Agriculture
Forest
Service
Southeastern
Area
1720 Peachtree Road, NW
Atlanra, Georgia 30367
Reoly:o 1950 (P&PD)
oa,e November 20, 1981
Mr. F. Theodore Bisterfeld
EIS Project Officer
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Bisterfeld:
We have reviewed the draft environmental impact statement on the Jackson-
ville Electric Authority, St. Johns River Power Park and have the following
comments.
In the discussion of the construction and maintenance of transmission
corridors, we suggest that indications should be made on whether .and what
types of herbicides will be used and, if so, should assess their effects and
mitigation. Mitigation of impacts from fuel, oil and toxic chemical spills
should also be addressed.
Since there is forested land involved in the various alternatives, we suggest
the following information be obtained for inclusion in the final EIS.
1. The approximate acreage,
project.
by forest type, within the boundaries of the
2. The approximate acreage of prime timber land involved. (Prime timber |cj
land is defined as that land capable of producing a minimum of 85 cubic feet jj
of timber per acre per year.)
3. The approximate yield of timber, per year, which could be expected to
be produced if the commercial forest land were managed intensively and not
destroyed by the project.
4. The expected long term effects (loss of wood and wood products) =md
the effects on the local economy from committing CGiLuiercial forest lands to
the project.
5. The current stumpage value for each'timber species in the major
commercial forest types and the total value of wood products lost as the
result of the project.
If the above information is presented, the reviewer will be able to
determine the trade-offs in timber volumes and wood products lost and can
17
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Mr. F. Theodore Bisterfeld 2
formulate the project's impact on the forest and socioeconomic environment.
We would suggest that you contact trie Florida Division of Forestry, John
Bethea, Director, Collins Building, Tallahassee, Florida 32301, for forest
inventory and evaluation information.
We appreciate the opportunity to review the draft EIS and look forward to
receiving a copy of the final EIS whan it is published.
Sincerely,
ROBERT- D. RAISCH
ea Director
18
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SIERRA CLUB
FLORIDA CHAP7ER-
November 30, 1981
Mr. John Hagan, Chief
EIS Branch
US EPA
Atlanta, GA 30365
Dear Mr. Hagan:
The Florida Chapter Sierra Club, as well as other citizen's groups and
individual citizens, participated in the joint USEPA/FDER Public Scoping Meeting
of April 9, 1981. Our comments regarding the study of energy conservation
alternatives were in concert with most of those presented where the overwhelming
majority of citizens wanted cleaner and cheaper energy conservation instead "f
two expensive and polluting 600 MW coal fired power plants. The USEPA is to be
commended for its interest in studying alternatives, and presenting four such
alternatives to construction of the SJRPP. To my knowledge this is the first EIS
in the state of Florida that has presented any meaningful alternative to building
a new electric power plant.. As such, it represents a major step forward in
implementing a public policy choice mechanism for delivery of energy services.
The major question regarding these alternatives is why was one of them not selecte-
as the preferred action? The Draft EIS states clearly that"... various alternate
to the proposed project are available which appear to be at least comparable to
the SJRPP from an economic and an environmental standpoint." In addition, the
Draft EIS states"... these alternatives meet the oil backout goals of the proposed
project " Why then does the USEPA recommend the action that produces adverse
impact on wetlands and the excerbation of existing water quality problems? And
how is the best interest of the public served when better alternatives are clearly
identified, and yet purposefully discarded in favor of poorer alternatives?
While USEPA's inclusion of generation alternatives is to be applauded, the
major alternative asked for by Sierra Club and many citizens - energy consei -ation
was basically ignored. Only one of the four alternatives proposed by USEPA
contained any element of energy conservation and that was a small program of solar
water heaters (10% of existing customers and 25% of new customers). The remaining
three alternatives were entirely devoid of energy conservation components. In
the Sierra Club comments of April 9, 1981, we stated:
"The U.S. EPA has a legal responsibility to assure that viable
alternatives are identified and studied. Ii, particular, the Sierra
Club requests the following actions from EPA with respect to the
EIS on the JEA/FPL application:
19
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1. that conservation/use of renewable sources be included
as one of the alternatives to be studied in the EIS
process;
2. that the conservation/renewable sources alternative receive
consideration and study equal to any other altnerative as
required by NEPA; and
3. that EPA use the Environmental Defense Fund-Willey model,
previously endorsed by EPA in the BLM Allen-Warner Valle:
Energy System EIS process to conduct a rigorous analysis
of the conservation/renewable sources alternative."
The minor inclusion of conservation/renewable sources as one element of one
alternative hardly qualifies as a legitimate response to this request. Building
a new coal fired power plant at $1000 per KW capacity provides electricity at a
cost of about-9 cents per KWH. At this price, many programs of conservation,
renewable sources and cogeneration become cost-effective. In addition, the same
oil reduction possible from burning coal is obtained by these cheaper and cleaner
alternatives which do not have the severe environmental problems with their use
as coal does. The EPA has not only failed in its legal obligation to provide a
thorough analysis of conservation, but it has also, failed the vast majority of
Florida citizens who want clean air, clean water and the least expensive approach
to satisfying their energy service needs.
This Draft EIS is clearly inadequate by any standards. It violates the CEO
Guidelines for preparing environmental impact statements. The 1973 Guidelines
touched upon the requirement that energy conservation alternatives to power plan.
construction be considered. 40 C.F.R. §1500.8(a)(4). This requirement was
expanded in the 1978 Guidelines which require a discussion of all reasonable
alternatives including reasonable alternatives not within the jurisdiction of
the lead agency (40 C.F.R. §1502.14(c)). The energy requirements and conservation
potential of various alternatives must be discussed. 40 C.F.R. 1502.16(c).
The adequacy of environmental impact statements was recently examined in
depth by the United States District Court for the Eastern District of California
in the case of California v. Sergland, ~483 F. Supp. 465 (E.D. Cal. 1980). The
court pointed out that an agency need not "ferret out every possible u.ternative,
regardless of how uncommon or unknown," Vermont Yankee Nuclear Power Corp. v.
N R D C , 435 U.S. 519, 551 (1978), but it said an agency could not ignore
obvious alternatives. "83 F. Supp. at 488. A program of energy conservation
measures is clearly an obvious alternative which cannot be ignored. The United
States Supreme Court refused to find a Nuclear Regulatory Commission EIS inadequate
for failure to examine energy conservation as an alternative in the 1978
Vermont Yankee case, 435 U.S. 519, but the opinion in that case revolves around
the point that the EIS was developed at a time ,,hen "there was little senou.
thought in most Government circles of energy conservation alternatives.
435 U S at 552-553. The Court pointed out that the concept of alternatives is
an "evolving" one and listed the evolutions of agency requirements for consideraticr
of conservation alternatives. _Id. There can certainly be no argument now that
energy conservation is not a serious alternative.
20
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The Sierra Club feels that a porgram of energy conservation measures is
a reasonable alternative to SJRPP. We have attached an app£.w:x outlining one
such program. The EPA should issue and circulate a supplement to the DEIS
reviewing this alternative before the final EIS is published.
As the court said in California v. Beroland, failure to discuss a reasonable
range of alternatives or to reveal the criteria employed for selecting reasonable
alternatives suggests either that the agency has not taken a hard look at the
environmental factors involved and has therefore acted arbitarily or that it has
simply failed to reveal its process of decision making. 48o F. Supp. at 488.
Either way, the ELS will be fatally deficient.
The Draft EIS for SJRPP has not examined a true energy conservation alter-
native. Failure to address this alternative, or failure to explain why this
alternative was left out-means that EPA has not made the full environmental
disclosure contemplated by NEPA. 483 F. Supp. 488. Unless this Draft EIS is
amended to include analysis of the conservation alternative, it will be susceptible
of being judged similarly deficient.
In summary, the EPA has a legal responsibility to identify and study all
viable alternatives. Furthermore, EPA has already established a precedent for
studying the conservation alternative in the Allen-Warner Valley Enprgy System
The Sierra Club reiterates its formal request that EPA adhere to the
requirements of the law in formulating the EIS for the SJRPP. EPA must include
a legitimate conservation alternative to satisfy the requirements. Following
minimum legal requirements should be standard agency procedure and should not
require legal battles from citizen groups to assure such compliance.
Very truly yours,
Barney L. Capeharl
Chairman, Power Plant
Si u"'ng Committee
21
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ATTACHMENT I
Conservation Alternative to JEA Unit
A. Energy Output of JEA Unit
600 MW capacity at 60% use
600,000 KW x 5256 KWH/XW = 3154 GWH
B. Residential Conservation Measures
(based on 230,000 customers)
1. Replace refrigerators by high efficiency models
Savings of 924 KWH/customer
100% saturation of refrigerators
924 x 230,000 = 213 GWH
2. Replace resistance water heaters with solar models or with dedicated
heat pump water heaters
Savings of 2700 KWH
85% saturation of electric w/h
.85 x 2700 x 230,000 = 528 GHH
3. Replace strip heaters by heat pump units
Savings of 2826 KWH
32% saturation of strip heaters
.32 x 2826 x 230,000 = 208 GWH
4 Replace central air conditioners with high efficiency units
Savings of 2000 KWH
52% saturation of central a/c
.52 x 2000 x 230,000 = 239 GWH
5. Replace window air conditioners with high efficiency units
Savings of 666 KWH
34% saturation of window a/c
.34 x 666 x 230,000 =52 GWH
Total savings 1240 GWH
The conservation share from the residential sector is 1240/3154 = 39.3%.
Since this sector accounts for only 37% of JEA's load, it meets the
proportional savings required.
C. Commercial arl Industrial Conservation-siirlar savings are possible in "he
commercial and industrial sector from energy efficiency improvements in
space heating, space cooling, lighting, refrigeration and cogeneration.
Jacksonville already has the largest commercial cogeneration facility in the
county at Regency Square.
D. The conclusion is that energy conservation is a viable alternative to
building JEA 1.
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HSCKSCHE3 DPT'rE
FISE CAMF, MARINA AND BUSINESS ASSOCIATION
P.O. Box 343 Ft George Island, Fla 32226
Dec 7, 1981
U.S. Environmental Protection Agency
Region IV
Consolidated Permit Branch
345 Courtland Street M.S.
Atlanta, Georgia 30365
Sirs:
The majority of the members of our Business Association ^re
directly or indirectly dependent upon the recreational and commercial
fishing and boating areas of the St Johns River, North shore.
We are appalled to learn that the Jacksonville Electric Authority
is requesting a variance to discharge into the St Johns river estuaries
contaminated water from piles of coal necessary for their planned
coal fired plants . Two of our fish can:ps are located on Browns Creek,
the main discharge area. Other Fish Camps are located near by. This is
one of the finest fishing areas in Florida. The marshes provide the
breeding grounds for fish and shrimp that range the entire,north coastal
area*
The theory expressed by one witness that the river already exceeds
mercury pollution standards and a little more pollution v:ill not make
much difference is particularly shocking. The posting of signs along the
river warning people not to eat fish caught near the coal fired plant
will have a devastating effect on near by fish camps and leave a question
of doubt on all•the northshore fishing areas. This type of belligerent
disregard for the purity of the St Johns River and its detrimental effect
on OUT Business and residential community should not be tolerated.
As an organization v/e request that no variance or permits of any
type be granted to JEA that would allow for even a minute pollution
of the St Johns River.
FOR THE ASSOCIATION
/ -si. • -£• /'•- ^-^ , ~^
Horace Black, President
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OF FLORIDA 3
%
I FLORIDA DEPARTMENT OF AGRP'LTURh £ CONSUMER SERVK
DIVISION OF FORESTRY
COLLINS BUILDING
TALLAHASSEE 3230J
FREP
December 8, 1981
Mr. Hamilton S. Oven, Administrator
Power Plant Site Certification Section
Department of Environmental Regulation
2600 Blairstone Road
Tallahassee, FL 32301
RE: Jacksonville Electric Authority Revision to St. Johns
River Power Park Units 1 & 2 Application
Dear Mr. Oven:
Attached are some forestry recommendations formulated by Duval County
Forester James A. Bryan following a field examination of the above
referenced site.
If the Jacksonville Electric Authority needs any assistance with imple-
mentation of any of the recommendations, they can contact Mr. Bryan at
our Jacksonville District office, telephone, 904/781-1434.
Sincerely yours,
George L. Reinert
Attachment
cc: County Forester Bryan
ttt\". "••'• '"'
: ' i
REGi
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OF
FLORIDA DEPARTMENT OF AGRiCULTURL S CONSUMER SERV
OOYI.E CONNER
S'VlSiONQF FORESTRY
COLLINS BUILDING
FREP
EIS
Power Plants
MLAHASSEE 32:
DSC .& 1961
December 7, 1981
MEMORANDUM
DIVISION OF FORESTRY
F.R.E.P. BUREAU
TO: George L. Reinert, Chief, FREP Bureau
FROM: James A. Bryan, -orester I, Duval County -~T~
904/781-1434 J c
SUBJECT: JEA - Revision to St. Johns River Power Park Application
At your request I inspected the site for the proposed JEA coal fired
plant. The vegetative cover is accurately described in the JEA assess-
ment. The site is basically a cut over flatwoods area interspersed with
cypress and hardwood strands. The site is located in one of the least
productive areas in Duval County for timber growth. Thus, from a fores-
try standpoint, the elimination of the area from the forest land base is
not significant. Also, because of the low productive capacity of the
area, any pollutants that are emitted will not significantly lower forest
productivity.
The vegetative cover which will be retained within the site boundaries
is best suited for aesthetic and wildlife management. To control erosion
I strongly recommend the planting of slash nine and other native trees
and shrubs found in the immediate vicinity.
I suggest before the land clearing begins that JEA allow private indivi-
duals to salvage standing and down timber for firewood. It would also
be appropriate for JEA to allow a plant dig in which individuals could
dig up any trees or shrubs which would otherwise be bulldozed.
In summary, I feel that the proposed coal fi^ed plant will not signif-
icantly impact torest production.
CO
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<. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
\ ATLANTA REGIONAL OFFICE
*£ RICHARDS. RUSSELL FEDERAL BUILDING
j>° 75 SPRING STREET, S.W.
*A3C **
ATLANTA, GEORGIA 30303
REGION iv Decembers, 1981 IN REPLY REFER TO:
Mr. John E. Hagan, III, Chief EIS Branch
U. S. Environmental Protection Agency
345 Courtland St., N. E.
Atlanta, GA 30365
Dear Mr. Hagan:
This is in reference to the Draft EIS for the St. Johns River Power
Park of the Jacksonville Electric Authority.
We have completed our review of the DEIS for the proposed project.
Our primary concern relates to increased ground level concentrations
of S02j N02, particulates, and the anticipated noise impact that
would occur during the steam blowouts. This department reviews all
proposed HUD-assisted (Mortgage Insurance) housing project sites for
environmental quality considerations. When applications for proposed
housing sites are to be located in the vicinity of a "Power Park" are
submitted to HUD we will closely examine the impact of additional air
emissions and noise upon the prospective occupants of the sites. If
these concerns are considered to be significant, the site may be
rejected and mortgage insurance or financial assistance denied by
the department.
We agree with your proposal concerning the sale of fly ash collected
in the electrostatic precipitators. However, we recommend that ap-
propriate measures be taken to make certain that significant quantities
of the fly ash are not lost during the transporting away from the plant
site.
We appreciate and thank you for the opportunity to review and comment on
this Draft EIS.
-*•
Sincerely, , ?-,
CXI
I
Charles N. Straub
Regional Environmental Clearance Officer
Office of Regional Community
Planning and Development
AREA OFFICES
ATLANTA. GEORGIA- BIRMINGHAM, ALABAMA- COLUMBIA, SOUTH CAROLINA • G P E ENS S C R O , NORTH CAROLINA -JACKSON. MiSSiSSIf
JACKSONVILLE. F'.OSIDA- KNOXVILLE. TENNESSEE- LO'J'SVILLE. KENTUCKY
26
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
15 NOR" AURA STREET
JACKSONVILLE. FLORIDA 32202
December 9, 1981
Mr. Robert B. Howard, Chief - EIS Preparation Section
U.S. Environmental Protection Ag .icy
345 Courtland Street
Atlanta, Georgia 30308
FWS Log No. 4-1-81-134
Dear Mr. Howard,
This presents the Fish and Wildlife Service's Biological Opinion in
accordance with Section 7 of the Endangered Species Act, with reference
to the issuance of a new source NPDES permit to Jacksonville Electric
Authority (JEA) for the St. Johns River Power Park. Formal consultation
was initiated by your agency on October 30, 1981. In our letter of July
14, 1981, we identified the following threatened and endangered species
that should be evaluated with reference to the power plant and
attendant transmission lines: West Indian manatee, brown pelican,
eastern indigo snake, American alligator, bald eagle, and red-cockaded
woodpecker. A complete administrative record of this Consultation is on
file in this office.
Your letter of October 26, 1981 stated that the Environmental Protection
Agency (EPA) had determined that the proposed action would affect the
above listed species, and submitted the Draft Environmental Impact
Statement (DEIS) in lieu of the Biological Assessment as required under
Section 7(c). To assist in the preparation of this opinion we have
conducted a field inspection of the Eastport and Blount Island sites and
visited the Northside Generating Station, as well as utilizing other
sources of information.
There were a number of alternatives identified in the DEIS and in
summary, they included No Action, modified development of the Eastport
site, converting 2 generators at the Florida Power and Light's Sanford
plant from burning oil to coal, and purchasing power from Georgia Power
Company.
This Biological Opinion addresses only the proposed action, that of
constructing a -ew 1,200 megawatt coal-fire ^nerating station at the
Eastport site in Jacksonville, a coal unloading facility on Blount
Island, and attendant transmission lines.
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Mr. Robert
Howard Page 2
In order to separate potential impacts related to the different phases
of the proposed project, we have divided the opinion into three parts:
1. Power Plant 2. Coal unloading facility 3. Transmission lines.
1. Power Plant
The proposed plant will generate a maximum of 1,200 megawatts from two
600 megawatt coal-fired units. The site selected for the plant is
referred to as Eastport, and is located adjacent to the existing Northside
Generating Station (NGS) in northern Duval County. Eastport is 1,656
acres, made-up of sandhill ridges, pine flatwoods, bay and cypress heads
and salt marsh. The actual plant will require about 300 acres, the
remainder being utilized .as a buffer area and for solid waste disposal.
Coal will be transported into the power plant by either rail or barge to
Blount Island, with a shuttle train delivery to the plant. Make-up
water to cool the generator units will be drawn from the NGS discharge
channel and blowdown water will be discharged into the NGS discharge
channel. At the present time, the warm water discharge from NGS is moved from
an elevated discharge basin into a pipe that has its point of discharge
in the St.-Johns River. The point of discharge is located 28 feet under
water. The intent is to prevent warm water from being discharged into
San Carlos Creek. On/or about 12 November, we were notified that three
manatees were observed in close proximity to this discharge basin. We
confirmed this observation on 16 November, and noticed that a leak had
developed in the basin. On 3 December, we did not observe any manatees in
the area and water temperature directly outside of the discharge basin,
within the area of the breech,averaged about 64°.
The primary impacts associated with this phase are initial site clearing,
road construction, and constructing waste disposal facilities. Based
upon your threatened and endangered surveys for the Eastport site, it is
our opinion that this phase is not likely to jeopardize the continued
existence of the brown pelican, eastern indigo snake, American alligator,
red-cockaded woodpecker, bald eagle or manatee. We do recommend that in
addition to relocating gopher tortoises, as suggested by the Florida
Game and Fresh Water Fish Commission, a concerted effort be made to also
relocate the eastern indigo snake, if tound on the site. Relocation
efforts should be coordinated with the State and U.S. Fish and Wildlife
Service - Jacksonville Area Office.
With reference to the manatee, we don't foresee any problem with the
small increase in temperature within the vicinity of the NGS point of
discharge. Our only concern is the existing breech within the discharge
basin. At the present tine, it appears to us that amount of warm water
leaking from the discharge basin would not be a primary attractant to
manatees in cold weather.
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Mr lobert B. Howard Page 3
There are several warm water refugia located approximately 6 miles down
river of NGS that are used by manatees during periods of cold weather.
We would suggest, however, that if NGS is planning to repair this leak,
repairs should be initiated during the warmer months; thereby eliminating
the potential of adversely impacting manatees. If this is not possible,
JEA should contact our office prior to this work.
II. Coal Unloading Facility
This facility will be located on the south end of Blount Island. This
island was created in 1950 from material dredged from the ship channel.
The proposed facility will require 55 acres with an additional 31 acres
utilized for a rail line. Much of Blount Island is in highly disturbed
state consisting of 4 primary plant communities: grassy shrub, Myrica
shrub, Baccharis shrub, and salt marsh.
Based upon your threatened and endangered surveys, it is our opinion
that this phase of the proposed action is not likely to jeopardize the
aforementioned listed species. With reference to the manatee, potential
impacts that may result from the proposed dredging and barge operations
will be addressed through a separate Section 7 Consultation with the
Jacksonville District Corps of Engineers.
III. Transmission Line Corridors
The proposal is to construct two-230 KV transmission lines from the
power plant to the Normandy Substation on the west side of Jacksonville
and two other lines to the Fort Caroline and Robinwood Substations on
the east side of Jacksonville. The preferred corridors in which the
transmission lines will be constructed follow existing transmission line
rights-of-way over more than 90% of their length. They will, however,
require a width expansion of 150 feet to accommodate the new lines. The
construction of a new right-of-way will require about 200 feet.
Af-T reviewing the DEIS and discussing the methods used to survey the
corridors for threatened and endangered species, it is our opinion tha;
the corridors will not jepordi?:e the continued existence of the bald
eagle, red-cockaded woodpecker, eastern-indigo snake, or American alligator.
Potential impacts to the manatee resulting from the placement of transmission
towers in Mill Cove will be addressed through a separate Section 7
Consultation with the Jacksonville District Corps of Engineers.
The bald eagle n..st that is located norch of Craig Municipal Airport is
approximately 1/2 mile west of the existing right-of-way. No additional
work is anticipated in this particular section of the right-of-way.
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Mr. Robert B. Howard . PaSe 4
In summary, the proposed power plant, coal unloading facility and attendant
transmission lines are not likely to jeopardize the continued existence
of the American alligator, eastern indigo snake, bald eaglei red-cockaded
woodpecker, brown pelican or manatee, or adversely modify the manatee s
Critical Habitat. With reference to the proposed dredging operations
that will be required at Blount Island and at Mill Cove, and its potential
impact on manatees, the Fish and Wildlife Service will request a separate
Section 7 Consultation from the Jacksonville District Corps of Engineers.
This Biological Opinion is intended to assist thi Environmental Protection
Agency in meeting its responsibilities under Section 7. This completes
consultation under Section 7 of the Endangered Species Act. If there
are any modifications made in the project or if additional information
becomes available relating to threatened or endangered species, reinitiation
of consultation may be necessary.
Sincerely yours,
Donald J. Hankla
Area Manager
•-11 ••—; i ^ .
—'<—.; < \
'n^uu
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OF WILDLIFE December 10, 1981
i ! •
Mr. F. Theodore Bisterfeld
EIS Project Officer u L;
U.S. Environmental Protection K'I~J,\ -.
Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: Draft Environmental Impact Statement (DEIS) for
Proposed Issuance of a New Source National Pollutant
Discharge Elimination System Permit: St. Johns River
Power Park, EPA 904/4-81-088.
Dear Mr. Bisterfeld:
Defenders of Wildlife (Defenders) t/submits the following brief
comments in response to the above-referenced DEIS. The scope of
Defenders' concerns and observations regarding the proposed con-
struction of the St. Johns River Power Park is generally limited to
consideration of that activity's effects upon the West'Indian
Manatee (.Trichechus manatus) .
The West Indian Manatee is a highly endangered species of
marine mammal, whose numbers in Florida have been reduced to
approxiamtely 800-1,000 animals.i/ Manatees have been protected
by Florida State law since 1893, and by Federal law since 1967, but
there is little or no indication that the species is recovering.
Pre-exploitation population figures are poorly documented; however,
it is known that manatees were historically hunted by Indians as a
food source between the 16th and 19th centuries. There was
additionally some poaching of manatees during the Depressiqi) and
World War II, when meat supplies were severely
he Depression
diminished.-2/
Manatees additionally have been, and continue to be, more
seriously imperiled by increased human intervention into warm water
habitats. These docile, slow-moving vegetarians must contend with
ever-increasing powerboat and barge encounters, as well as with
flood control structures, fishing gear, vandalism, and alteration
of habitat and food source availability through dredging, sewage,
anci wastewater disposal activitites. When these direct impacts
i
I/ Defenders of Wildlife is a national, non-profit, tax-exempt
organization with a membership of approximately 55,000 citizens,
and is dedicated to the protection of the nation's wildlife
resources and the natural environment.
2/ "West Indian Manatee Recovery Plan," prepared by Robert L.
Biownell and West Indian Manatee Recovery Team, April 1980, p. 3.
3/ Ibid, pp.2-3.
1244 NINETEENTH STREET, NVV * WASHINGTON, DC 20036 * (202) 659-9510
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-2-
are coupled with the species' extreme sensitivity to water
temperature ,-=•/ it is something of a wonder these creatures manage
to survive at all. Indeed, the Marine Mammal Commission has
stated:
"There is little question that if the population
numbers only 1,000 animals and the present levels of
mortality continue, the Florida manatee population
will soon become extinct."-^/
It is with respect to water temperature sensitivity in
particular, and water quality generally, that the DEIS must concern
its discussion of manatees. The effects of manmade (or artificial)
warmwater refugia may, in a real sense, be beneficial to manatees.
Some researchers have endorsed such facilities more strongly:
"Numerous reports of animals succumbing to the
cold indicate such refugia may be necessary for
survival in Florida during protracted freezes (Layne
1965; Moore 1951a, 1956; Krumholz 1943; Hamilton 1941;
Cahn 1940; Bangs 1895)." i/
The introduction of facilities such as the proposed Power
Park, however, also presents a double-edged sword:
"The winter of 1976-77 was the coldest winter in
the recorded history of Florida. Campbell and Irvine
C1978) reported on a substantial die-off of manatees
during this winter in Brevard, Duval and St. Johns
Counties, all north of the species' known historical
range.... They hypothesized that the availability of
artificial refugia in northern Florida (Brevard Co.)
has caused some manatees to winter in areas not
naturally suited to their needs. When the artificial
warmth proved inadequate due to the combination of a
partial shutdown and the unusually severe weather,some
of these animals apparently died of cold-related
causes."!/ (.Emphasis added.)
oo
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4/ According to Dr. Howard Campbell, Manatee Research Program
(National Fish and Wildlife Laboratory), manatees are extremely
vulnerable to cold water and appear to be unable to survive
prolonged periods in waters less than 65°F. (Dr. Campbell's
views were cited in "Mermaids in Danger," by Kyle Hill,
Florida Wildlife, May-June, 1980, p. 31.)
5_/ "Annual Report of the Marine Mammal Commission, Calendar Year
1980: A Report to Congress," p. 19.
6/ "The West Indian Manatee," by Sandra L. Husar, Fish and Wild-
life Service, U.S. Department of the Interior, Wildlife
Research Report 7, 1977, p. 10.
7/' "Manatee Recoverv Plan." n. 8,
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Power generating stations, such as that currently proposed,
become in effect artificial manatee habitats, by providing"warm-
water areas the animals may not be able to locate elsewhere.
Production of such facilities may not proceed without a finding,
through consultation, that the manatee's continued existence
will not be jeopardized — either directly or by destruction or
adverse modification of its critical habitat. This consultation
is mandated by Section 7(a) to the Endangered Species Act of
1973, as amended (ESA) (P.L. 93-205). Following consultation,
Section 7(b) directs the Secretary (of the Interior) to promptly
provide a written opinion, "detailing how the agency action
affects the species or its critical habitat." The opinion shall:
.suggest those reasonable and prudent
alternatives which he believes would avoid
jeopardizing the continued existence of any
endangered or threatened species or adversely
modifying the critical habitat of such species,
and which can be taken by the Federal agency or
the permit or license applicant in implementing
the agency action." (.§ 7 (b) I..
In order to arrive at such final opinion, Section 7(c) directs
that:
"... such agency shall conduct a biological
assessment for the purpose of identifying any
endangered species or threatened species which is
likely to be affected by such action."
The DEIS offers little indication these mandates have been
met by the applicant. Other than providing a listing (Table 3.5-5)
of "rare, threatened, and endangered species" occurring in the
project vicinity, there is no indication in the DEIS that Section
7 consultation has been initiated. Table 3.5-5 does note, however,
that the project site occurs within manatee critical habitat.
Virtually the only other discussion of the manatee is found
in Appendix 0 (Biological Resources), which is accompanied by a
statement indicating that neither the Florida Department of
Environmental Regulation nor the U.S. Environmental Protection
Agency has yet reviewed its contents. TLo discussion itself
consists of the following informational statements: 1) the
proposed project occurs "well within the recognized critical
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habitat for the manatee;" 2} a JEA/FP&L survey conducted in the
area between January and April 1980 revealed no manatee sightings,
although "several other sightings" were reported by local resi-
dents during the summer; and 3) accidental collisions with boats
and barges, canal lock operations, vandalism, and loss of habitat
to "incompatible human water traffic" all contribute to the
decline of the manatee. (p. 0-23).. These few sentences, com-
bined with Table 3.5-5, must not be considered compliance with
Section 7 to the ESA. With the permitted construction of this
facility also comes the legally mandated responsibility to ensure
related activities do not jeopardize the manatee or its critical
habitat. It is not a responsibility to be taken lightly.
Defenders urges that the results of a comprehensive Section 7
consultation be made available to the public in the FEIS.
Such consultation should also address the contingency of
power outages, and the resultant impact on manatees dependent
upon warmwater effluent. Dr. Ross Wilcox (Florida Power and
Light) has stated that plant operators are "aware of the risk to
the manatee should all generating units at a plant be shut down
at the same time during the winter season."!/ Plant operators '
must exhibit more than awareness. Inasmuch as plant construction
and operation create artificial habitats which may become hazard-
ous to manatees during planned (or unplanned) power outages, the
applicants must accept responsibility for the animals' welfare.
Defenders additionally expresses concern at the acknowledged
adverse effects the proposal will have on water quality and thus
on all aquatic life in the St. Johns River. Wastewater discharges
will further contaminate an area which "already contains excessive
amounts of those contaminants." (p. xi). Aquatic communities
are "currently stressed by poor water quality caused by elevated
nutrient and pollutant loadings." (p. 3-36). Although some
discussion is presented on aquatic plant communities, for instance,
there is no connection made in the DEIS from anticipated impacts
on water quality to plant life to the availability of food sources
for manatees tor other plant consumers). As part of its compre-
nensive consideration of manatees, the FEIS should identify what
Comments of Dr. Ross Wilcox, Florida Power and Light Company,
at the 19th Meeting of the Marine Manual Commission, and the
15th Meeting of the Committee of Scientific Advisors on
Marine Mammals, Tampa, Florida, February 21-22, 1980.
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natant and emergent plant species (assuming,as the DEIS does,
that submergent vascular species are not present in the Blount
Island Channel) are important food sources to the manatee, and
whether those species are present in the proposal area. For
instance, are any of the following found in the area: Eichornia
crassipes, Alternanthera philoxeroides, or Salvinia rotundifolia?
According to state regulations, responsibilities for manatee
protection are vested with both the Department of Natural Resources
and the Florida Game and Fresh Water Fish Commission. Yet the
Commission, in its final report (Appendix H) cddly makes no
reference to manatees, although several salient points are made
concerning the overall unsuitability of the proposal site:
"Early in the site selection process, the
Eastport site was ranked last in a group of eight
alternate sites because of the adverse environmental
impacts expected to occur at this location. A more
environmentally sensitive site of the proposed
power plant could hardly have been chosen. However,
since JEA has selected Eastport as its preferred
site and wishes to pursue it, we feel very strongly
that the utility has an obligation to aggressively
pursue and solve the environmental problems associa-
ted with siting a power plant in this sensitive area.
This includes making every effort to move the plant
away from the marsh, carefully collecting and treating
all stormwater runoff, providing proper wastewater
treatment so that no variance to water quality
standards is necessary, providing adequate liners for
all waste disposal areas to prevent groundwater
contamination, and evaluating the potential for acid
rain problems emanating from the proposed plant."
Defenders also notes that Appendix 0 indicates the presence
of Delphinus delphis (Common Dolphin) in the estuarine area
adjacent to the Eastport site. (p. 0-33). There appears to be
no further discussion of dolphins in the DEIS. The applicants
should provide more information about the occurrence of this
marine mammal in the proposal area. Is there a potential, as a
result of plant construction or operation, for unintentional
"taking" of these animals? Are the dolphins, like the manatees,
subject to encounters with boat traffic as either a direct or an
indirect result of plant construction and operation? These
questions should also be addressed in the FEIS.
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Defenders' succinct conclusion regarding the DEIS is to
remind the applicants of their responsibilities to the West
Indian Manatee and to other wildlife species. Applicants must
ensure that, as a result of project-related activities, the
manatees' future is not rendered so much more precarious.
Sincerely,
(Ms.) Sherrard Coleman Foster
Marine Issues Specialist
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(404) 262-664'.
December 11, 1981
Mr. John E. Hagan, III
Chief, EIS Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
We have reviewed the Draft Environmental Impact Statement (EIS) for the
Proposed Issuance of a New Source National Pollutant Discharge Elimination
System Permit to the Jacksonville Electric Authority and the Florida Power
and Light Company - St. Johns River Power Park, Duval County, Florida. We
are responding on behalf of the Public Health Service and are offering the
following comments for your consideration in preparing the final document.
We understand that the applicants have proposed to jointly construct and
operate a New Source 1,200 megawatt coal-fired steam electric generating
station on a 1,656-acre site. In general, we have no major objections to
the proposed action and, with some exceptions, we find that the EIS ade-
quately discloses both the significant effects of the proposed action and
the mitigation steps that will or could be incorporated into the project's
permits and contracts,
General
The Draft EIS omitted several public health sections in error. These omissions
included a portion of 4.13.13 Other Vectors and 4.13.2, pages 4-137 and 4-138.
Please send these to us at your earliest convenience.
Noise
The EIS should address the potential noise impacts to any sensitive land uses
from increased usage of the Seaborne Coast Line Railroad from (1) coal
delivery unit trains when or if the coal cannot be delivered to the Blount
Island coal terminal by ocean-going barges or (2) shuttle train deliveries
to the plant from the Blount Island coal terminal.
Vectors
It is important that this proposal not be allowed to increase any local vector
populations capable of causing vector-borne disease or nuisance problems. The
EIS should include a brief history of vector-borne disease and nuisance problems
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Page 2 - Mr. John E. Hagan, III
that have occurred in the area and the local efforts to mitigate these problems.
In view of the potential vector habitat areas to be created by the applicants,
we recommend that a vector control management plan be developed by the applicant
and that it be approved by the local health department. The EIS should address
the project's potential vector-borne impacts; this information can be obtained
from the local health department.
Water Supply
Under maximum usage conditions, the EIS declares that the cone of depression
at the site boundary was 25 feet with a drawdown of 14 feet at the nearest
off-site well. Will any off-site wells require additional drilling or pump
level adjustments to avoid any problems associated with the projected drawdowns?
The cumulative long-term impacts upon the Floridan Aquifer from the project
and others in the area should be better described.
While a long-term groundwater monitoring program to evaluate the potential for
groundwater contamination from solid waste disposal leachate is necessary, the
steps that will be taken in the future if contamination becomes a problem
should be discussed. A more positive approach would be to incorporate design
features into the solid waste disposal areas that would prevent the occurrence
of leachate contamination rather than wait for contamination to occur.
We appreciate the opportunity to review the Draft EIS. Please send us one copy
of the final document when it becomes available. Should you have any questions
about our comments, please call Mr. Robert Kay of my staff or me at FTS
236-6649.
Sincerely yours,
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Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
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Mat Roland
P. O. Box 37
Mayport, FL 322c
(904) 246-9443
December 11, 1981
Mr. John Hagan, III
Chief oi E.I.S., Region IV
345 Courtland St., 1C. E.
Atlanta, GA 30365
Dear Mr. Hagan:
The coal fired electrical plant proposed by the J.E.A.
of Jacksonville, Florida will constitute a serious threat to the
environment. We petition your office to deny the J.E.A. the
permit to build the plant. The J.E.A. has asked for a variance
to allow greater amounts of mercury to be dumped into the
estuaries and tributaries of the St. Johns River. The river
already is at nearly the limit on mercury standards by state
standards. There are times when even these standards are
exceeded.
To grant a variance to the J.E.A. on mercury standards
should be illegal. A greater amount of mercury in the river
will constitute a great threat to the seafood industry, not only
in this area but also to the whole state and also to fisheries in
Georgia, South Carolina, and North Carolina.
Fish and shrimp are migratory animals and it has been
proven through studies undertaken by National Marine Fisheries
Service that shrimp travel between South Carolina and Florida.
This fact alone makes a variance in mercury levels in
the St. Johns River a matter of Federal jurisdiction. For the
J.E.A. to make statements that fish shou1d not be eaten if caught
within a distance from the plant is, of course, ridiculous.
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Mr. John Hagan, III
December 11, 1981
One very important fact to be considered on mercury is
that it accumulates in fish and the amount increases as the size
of the fish increases. Small fish ingest mercury. Then larger
fish also ingest mercury from the river, but larger fish ingest
greater proportional amounts of mercury because they also eat
the smaller fish which have accumulated the mercury in their
systems. So, as the fish get larger and the more fish they eat,
the greater the threat of mercury poisoning becomes.
A mercury scare would be devastating to parts of the
economy of the State of Florida. First, and most important of
all, would be the threat to the health of the people who would
eat the seafood containing concentrated amounts of mercury.
Second would be the almost totally destructive effect it would
have on the seafood industry. Next, there would be a threat
to the tourist industry and the restaurant business in the State
of Florida.
Please note that we petition rejection of permit by your
office for the plant proposed by the I.E. A.
Mat Roland Seafood Co.
Southeastern Fisheries Association <•'
Fishermen of Florida
Florida S'hrim- Co-Op
fv;
CO
3
Miss Becky Seafood
Atlantic Seafood Co.
40
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STELLA D. ANDREWS
115 Palm Ave- *
Jacksonville, PI 32218
December 12th, 1981.
Ref: 4.SA-SIS'
RSI St. Johns River Power Park SIS/SAB:
F. Theodore Bisterfield
SIS Project Officer
United States Environmental Protection Agency
Region 17
3A5 Gourtland Street
Atlanta. Georgia 30365.
Dear Mr. Bisterfield,
lour kind offer of further comments- from organisations and citizens- in opposing
the proposed JE£ Power Park are herewith cited for jour attention:
1.
Quoting from an enclose* article in the Fla Times Union dated Sec 10th, 1931 r
"a. Johns River Management member Trustee- in Gainesville Lynne Capehart said a 10
percent drawdown of underwater- levels can be expected when Jacksonville builds its
proposed new power plants on the north side of the
2.
Quoting from and editorial appearing in the Fla Times Union December 13, I98t
The idea- of the St. Johns River as a mighty natural system with its headwaters in its
acient marshes, cleansing and storing the water and nurturing aquatic life that feeds
birds and other animals, probably has: about six- months to live.
Unless there is a real outcry from the area extending fro.-n Verobeach to Joc'-sonvilL
-ne river seems doomed to lo*e about a hundred miles of its ecosystem and Brevard
enclosed) ^^ tC 1OSe Clean Wat9r " needs:t° SUPP1T its coastal population." (article
3. -Vow let us go back to January 9, T971 and quote Nathaniel P. Reed, Chair-an,
Dept of Air and Water Pollution Control, before the Florida Wildlife Federation in
Jac'-'sinville Florida:
"Those, the local or County Planning and Zoning Boards, ire the most danee^ous
beards in existence - they can wipe out in minutes what it took God cent-ries to cr-ate
To 3uote from the Planning Board in Jax at the time:
The Jacksonville Planning Board in April of I96H published a Ions-rinse land-i.se
study, financed in part oy an urban planning grant from HUD -sold locally 'for ~?5 00
and entitled "Plan 1990". It w*s a thing of beauty, colored ~aps, etc.
The Plan proposed two areas for 'open spo.cel: Turner's Fond or. the old I.-y»son
Airport property, and the vast Tidal salt marshes on the north siie of the S*. Johns
u.orth of Heckscher Drive, east of Clapboard Creek Co-plex.
Burner's Pond was a a acre lake filled with •_ qarba!?e du-T5 and then sold for a" in-
dustrial Park. "
41
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2— of Comments-^ by Stella D. Andrews Raf St. Johns Power Park proposed Site in
Jacksonville, Florida.
— Industrial Park.
Those great salt marshes---known as the Hannah Mills Greek Tidal Complex were set
aside for 'open use - conservation1 in the original Zonin.q Code. The area has been
the center of conservationist's concern since 1967, because the Jacksonville Port
Authority designated --with the approval of the Florida Cabinet - sorre 1200 acres
of the Hannah Mills Complex to bo used to Dusrp dredge spoil. . (An update to
du-ping drsdge spoil; recently I read an article in the Times Union where they were
quoting the Corp of Engineera on rahibilitating Mill Cove Complex which will cost
around 5 million dollars of tax money.) On the night of December 5, 1963, developers
decended upon the Zoning Board at a meeting in the'Planning Board's Office.
Immediately after that meeting, the Zoning Board eliminated Hannah Mills Complex
as-an 'open space1 and designated these priceless tidal marshes as 'industrial
development Iarea.
Cn a personal note: My husband and I" moved to Heckscher Drive in 1953 and bought
a home backing on Clapboard Creek. V9 were under heavy restrictions-within the^
original deed from North Shore Corporation and these restrictions as to appurtances-
were to continue until T975.. ~^e looked into building a dock facing the creek and
found that Seaboard Coast Line Railway owned a risht-a-way adjoining the creek.
They graciously gave us a buffer of 200 feet and we left happy, thinking that footage
placed the railway into deep water and that we would not be bothered further.
The Jacksonville based representative of North Shore Corporation at one time advised
us against any more improvements on our property 'because it is all ^Din* Heavy
Industry down to the mouth of the St, Johns River I At the time they were%elling lots-.
for residential purposes*
In summing up tha above I refer to pgh£?_: The river flows both north and south
From numerous sources we believe the headwaters are short lived. It is known that
from Palatka to the entrance to the harbor that the river, at times, is polutted.
Seminole Coal fired plant received exceptions to polutting the river. Jacksonville
Power .ark Plant is asking for the same exceptions - adding real danger to the river.
CO
Referring to pgh 1. ; With the drawdown of water from Stflegis Paper mill, JEA as it
exists, Coal fired Slectric plant at Fernandina, Alton Box Factory ,nd numerous other
plants using water that we ars jeopardising the coastal water supply -rid th-t we
should look to placing any further plants- further inland.
I served in a Citizens Advisory capacity on both the 1990 Plan and the 2005 Plan
*e missed getting the '90 Plan through as an Ordinance but were promised that the
State demanded that the 2005 Plan be passed as an Ordinance, otherwise I woul^3 rot
have served on the latter Committee* An Ordinance would have reauired an exception
before a deed was given for this plant sifle. ..>
Respectfully, .-C7~~6/ - /~ // C
Slella b. A^rews-; S& ffetir fear^erT ClS-cle
115 Palm Avenue, Jacksonville, Fl 32213
42
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-n Orlando Siting Flan(10 vear )
To
Scfflc -'r. C;:rry fr.rtchinson, Ausust 8r 1980:
Until such ti-.e as JEA submits more derailed infor-«tion. on sources, poirts
of .miKrrTrir discharge, proposed treatment facilities, etc., it is not possible
to project the environmental impact upon the discharges previously noted.
TT
ater Supply:At the proposed Eastpoct site, there arrears to be no reason
to seriously doubt that there vill be sufficient ^rc^nd'an- surface water to meet
the needs of the City and JEA, provided proper environmental studies are conducted
during the planning and permitting process, These should irclure well ?i«l/»
studies. . ---
Very trnly yours,
Donald C. Bayly, Assistant Chief.
To .
Kr. Curry Hutchinson, Sept 16 1980:
Jacksonville Electrical Authority - Although the Site selection Study did not '
find that Sastport was the best site., it has been chosen as' the
preterred site for the addition of two 600 Ha coal units.. It remains to be
seen if the site can be developed in an environmentally sound manner. We have bee
working with JEA during the site selection and study process, and will continue
to prcvido assirrtanc.3. through the Site Certification process.
Colonel Robert M. Brantly, Executive Directo
Dept of Community Affairs Divn local Resource Xanase-
October 23rd 1980
To Curry Hutchinson
*ro:i Tasha 3uford
Subject: Jacksonville Electric Authority Ten-Year Site Flan Review -1980
We have reviewed the -Tea Plan with re?ard to the Bureau's Development of
Regional Impact and Critical Area Fro^rass. We offer The following com-entst
JEA is prepssing two fossil steam power generating units with a designed ye»r-ro
capacit" of SSS^e. The primarv fueld '/ill bt coal and the alternate fuel'«ill b
heavy oil $6 and sas. Air pollution will be de^lt with through boiler design,
electrostatic precipit.ator, and scrubbers. The plant will incorporate a closed c
condenser coolincr tower in ±J2 its Jesisn.
The primary site n=>~sd for the units is Eastpoint. 'This site is located in :~n
-ival County alon^ t/.s St."oh -s ^iver ?.•• " consists o'" 1,50" ac^es. ""-i~ site i~ ~.
l~cnt=c -ear an ar:-a :T critical state c~nsern, b:-i±—l^-rre is- ane"D?J in' "i^nr-
nor are there any DRI's in close "rc:-:i-ity.
Ths alternative sits 13 Willis Feint located at the southe-stern *--' of Clay
County, Mir the St.Johns River. I-is .its is is not w.icci'rsd -e- - ,ren of
43
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(This memo retyped from handwritten original)
12/21/81
Telcom
Lee Pelej
Re: Comment SJRPP DEIS
Page 4-46 Cone of depression impact.
Should present potential for any freshwater wetlands to go dry
at places of high depression.
It could happen in areas where surficial and Florida are relatively
contiguous.
44
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TO: Mr. Ted Bisterfeld
Environmental Assessment Branch
U.S E.P.A.
345 Courtland Street, N.E.
Atlanta, Georgia 30365
FROM: Law offices of George W. Ker . , Jr.
Roy L. Beach, Esquire
Dear Mr. Bisterfelo:
I would like to bring to your attention a few points of
contention that the Heckscher Drive Community Club, Clean Air
Coalition, and the Sea Dates Garden Circle, referred to hereafter
as the Intervenors, feel have not r::en adequately addressed by
the applicants in this case.
The first point that we wish to discuss concerns the request
for a variance for the dumping of heavy metals into the St. Johns
River in excess of the water quality standards. The applicants
contend that the heavier concentrations of heavy metals, specifically
mercury, will not have an adverse effect on human beings and
thusly the variance should be granted. The Intervenors, however,
are at a loss to see how the applicant reached this conclusion.
The applicants have conducted NO studies or analysis of fish
Caught in the area where the wastewater from the plant would be
discharged in order to find the current level of contamination of
mercury in those fish; have not attempted to project the future
amount of mercury that will be bio-accumulated in those fish once
I
the applicant starts to exceed the w?«ter quality standards; nor
has the applicant tried to link up the results obtained by such
testing with any published data concerning the effects of mercury
poisoning on human beings. The applicant h^s blithely stated
that no harm will come from the granting of the variance and yet
they have not conducted any tests to find out. It may well be
that no ill effects will occur from the granting of the variance,
BUT the converse is equally true and great harm might result.
Without conducting any sort of studies or tests on the fish in
the river, HOW CAM WE BE SUF-E ONE WAY op. .M-TCrHEn? The possible
harm which would result if the applicant is wrong is just too
45
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areat to be overridden by any wish to save the few thousand
dollars that would have to be expended in order to find out for
sure whether or not the increased mercury concentration in the
wastewater discharge would have a harmful effect on the fish
in the river. It should be pointed out that a fine summer week-
end brings out anywhere from 200-400 people who fish off a bridge
that would be within the requested mixing zone. You should
require that the applicant conduct studies on the fish in the
river and correlate the results of those studies with nationally
oublished, widely accepted data on the possible ill effects that
mercurv ooisoning has on human beings.
The second point that we would like to call to your attention
concerns the statements by the applicant that the withdrawal of
5.2-7+ million gallons of water per day from the Florida Aquifer
would not have an adverse impact on neighboring wells, both residential
and agricultural. The data that the applicant used in making the
determinations of no harmful impact through draw-down, etc. is
dated 1979-1980 at the latest. You should be made aware that since
roughly September of 1980 to present, northeast Florida has been
going through a period of "deficient rainfall", what could be
called a drought. The gentleman from the St. Johns River Water
Management District who testified at the administrative hearings
that ran from December 1 to December 4, 1981, Mr. Thompson
acknowledged this shortage of rainfall and testified that several
areas in the jurisidiction of the water management district were
under mandatory water controls due to this shortage of rainfall.
Roughly one/fourth of Duval County is under mandatory water control.
It is the position of the Intervenors that the applicant used
inaccurate data when they used the 1979-1980 data mentioned above.
If mandatory water use controls have been imposed in 1981 in
parts of Duval Cou^'iy, said county being where the ; lant is pro-
posed to be constructed, then one need not be an expert to wonder
if the data from 1979-1980, a time of no mandatory water controls
in Duval County, is still valid over one year later. This, too,
mavbe a situation where no harm will be caused but ANY result from
i
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ANY calculations based on potentially erroneous data io suspect.
The burden here is on the applicant and thus the applicant should
either:
1. Demonstrate that their data is still accurate,
LTI
2. Show that the potential discrepencey raised by the Intervenors
will not materially alter the applicant's conclusions, or,
3. Run a new series of tests with data which takes into account
the prolonged period of shortage of rainfall and any depletion of
the acquifier resulting from the shortage of rainfall.
The Intervenors also wish to call to your attention the Con-
cerns of some within- the Florida Department of Environmental Re-
gulations regarding the wetlands that would be affected by the
plant. Some of the witnesses called by the Intervenors at the
Site Certification Hearings held December 1-December 4, are members
of the DER and seriously questioned Envirosphere's experts' state-
ments regarding the impact on the wetlands that the filling in of
.'.round 31 acres of wetlands would have on the surrounding marshlands.
Those witnesses contend that those lands are an interconnected,
vO
vital part of the eco-system and should be viewed as such. Further, j_
those witnesses questioned the completeness of the studies con-
ducted on the area in this regard and feel that the extent of
damage due to the filling has not been adequately addressed.
Lastly we would like to draw your attention to the alternate
proposed by Jack Russo, C.Branvold, and Col. Petit at the public
hearings on December 1, 1981 at Jacksonville, Florida. Their
figures are at a variance with the'applicants and the Intervenors
urge that both sets of figures be closely scrutinized by your de-
partment ;
For example in the draft EIS/SAR, page 2-45, table 2.5-6,
the applicant puts forth an operating and maintenance figure for
the suipher dioxide control alternatives which ranges from 599,997 to
i—
3151,542. If we use the smaller- figure (rounded off to 5100,000) f
and compute how much i: to be spent on operating and maintenance
over the life of the plant for this equipment, a 0% inflation
rate gives a figure of 54 billion dollars. A 9% inflation rate
which is still low, gives a figure of S52 billion, rounded off.
47
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Thus, 52 billion dollars is to be spent just to control one type
of pollution. The gentleman from Ebasco who testified before you
C
O
on December 1, 1981 at the Public Hearings gave a figure consider- ^o
ably less than 52 billion. It should be noted that these figures
4_
do not include the cost of operating the particulate alternatives &
as outlined on Page 2-42, Table 2.5-4 of the Draft EIS/SAR.
Royce Lyles, manager of the JEA admitted on the stand that
he would consider another plan submitted to him which would give all
the benefits of the proposed power park and which woul'1 have a
lesser environmental impact. Page 6.8 of the official transcript 5
i
of the hearings, lines 21-24. We would also like to point out
to you the fact that Seminole Electric is building a plant similar
in size to this proposed plant down in'Palatka, Florida, roughly
100 miles south of Jacksonville.
In conclusion, tne Intervenors urge you to do all in your
power to save the environmentally sensitive wetlands which would
be damaged by this project, and to assure the safety and -welfare
of literally thousands of people who live, work and play in this
area. Require the applicant to conduct fish studies and to justify
it's data re the Florida Aquifier. Also scrutinize the plan
proposed at the December 1, 1981 Public Hearings by Mr. Russo,
Mr. Branvold, and Col. Petit. While it may very well be true
that we need the increased power, that does not necess?-ily mean
that this proposed power park is the best way of obtaining that
power despite the applicant's contention that it is.
Si ncerely,
Roy I. Beach, Esquire
Co-Counsel to the
Heckscher Drive Community
Club, Clean *ir Coalition.
and the Sea Oateb Garden
Circle
Law Offices of:
George W. Kent, Jr.
2105 Park Ave. r21
Orange Park, Fl 32073
(904) 269-5369
r; -.
48
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/
^^"TT-
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-\ :i,i u M u . i. ^ lj , i-t r i- .-* i i v. i\ .1 " r1 -< L i •; c •" -J .-< I
******•*•********-*•»•**•*****•*•-******•*•*••**
BASE AMOUNT 5124,623,000
_LN.LL.AT_iaN^EAvTOR.
PERIOD OF YEARS
STARTING Y5AR
IMPACT YEAR
_1 ..3.9.
45 "
1930
..19.36..
•*••»*********•*»***•****•*****-****•**-****
_YL =Ai_N.C _ C.-1LLA
9-
'3'
'' *
- *
*
;" *
'9; *
' ;" *
*
"i *
''.. :3' *
:2'! *
!_ .
*
r i- *
:?i ' *
,2ei *
C |:3!
;3=i *
i3i; *
( * *
37 *
J4! *
*
M: *
37! *
:3' *
;; *
"'" *
"' *
*
43 *
*
" *
46 *
*
*
45 *
" *
: *
i: *
=" *
1980 0
12S1. J
1932 2
1933 3
1934 4
1935 5
1986 6
1937 7
1 933 S
1989 9
1990 10
1991 11
1992 12
1994 14
1995 15
199ft 16
1997 17
1993 18
1999 19
2000 20
2001 21
?'DO? 2?
2003 23
2004 24
20Q5 25
2006 26
2007 27
2003 23
2009 29
2010 30
2011 11
2012 32
2013 33
2015 35
2016 36
2017 37
2013 38
2019 39
2020 40
2021 41
2022 42
2023 43
2024 44
2025 45
$124,623,000
3148,070,527
3161,396,374
3175,922,593
3191,755,626
3209,013,632
32^7,324,259
3245,329,096
3270,673,715
3321,593,331
3350,536,735
S332,G35,G96
3416,472,755
$453,955x303
3494,811 ,?3n
3539x344x295
5537,835,232
__ $640x794,957
3698,466,503
$751,323,433
$904,534x377
$935x942x471
31^074x677x293
51x171x398x249
31x276x824,091
31x391,7-55,259
31,516,994,702
51,653,524,225
31,964,552x131
52,141,361,323
$2,544,151,932
$2,773,125,660
33,294,750,596
33,591,2^3,150
31^914x493,134
34,266,797,571
S4,65CxS09,352
35^069x332^1^4
35,525,626,591
$6,022,932,934
GRAND TOTAL:
371x435,027x064
50
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United States Department of the Interior
OFrlCE OF THE SECRETARY
_^ WASHINGTON, B.C. 20240
ER-81/2261
-JAN 5 IS82
Mr. Theodore Bisterfeld
EIS Project Officer, Region IV
U.S. Environmental Protection Agencv
345 Cortland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Bisterfeld:
We have reviewed the draft environmental impact statement/state analysis report for
the proposed St. Johns River Power Park, Duval County, Florida, and have the following
comments. 3
General
Impacts associated with construction of the plant at the Eastport site include significant
loss of wetland habitat, degradation of water quality, and potential impacts on
threatened or endangered species. In view of the presence of these species, formal
consultation pursuant to Section 7 of the Endangered Species Act is underway between
EPA and the Fish and Wildlife Service. The final statement should indicate the status of
the Section 7 procedures.
A total of 1600 acres of various habitat types are present at the project site, and
approximately 289acres (17 percent) are wetlands. Of this total, approximately 84.3
wetland areas (30 percent of the wetland total) will be eliminated through filling with
leachates from solid waste disposal and/or project dredging.
In addition, the description and maps of the proposed transmission line corridors provided
in the DEIS do not allow a complete review of the potential impacts. It is also unclear
whether construction of fill roads for maintenance of the transmission lines will be
required. The final statement shu ild contain this information.
There is no discussion of potential flood stages at either the geneiating station site or
the Blount Island coal terminal. It appears both sites could be affected by hurricane-
induced tidal surges. The final statement should assess this issue.
The DEIS presents four alternatives for generating electricity which require lesser
amounts of fuel oil than are currently being burned by JEA. Some of these alternatives
may have less imparts on wetlands and related fish anc wildlife resources and may
therefore be preferable to the proposed project. The available information, however,
does not permit a comprehensive analysis.
3
I
S
CN
m
I
51
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Mr. F. Theodore Bisterfeld
Water Quality
Page 4-30, Paragraph 3. The St. Johns River currently exceeds State Water Quality
Standards for certain heavy metal parameters. However, we question the rationale for
seeking variances from these standards. Continued variances for these contaminants
only serve to compounu impacts of the pollutants on fish and wildlife resources.
Elutriate tests indicate that dredged material will exceed St*te Standards for antimony,
cadmium, copper, lead, mercury, oil and grease, and silver. These materials, if removed
from the river bottom by dredging and then reintroduced into the water column by spoil
disposal return effluent, will adversely impact aquatic organisms of the St. Johns"
estuary. In an effort to reduce the impacts on the water quality of the St. Johns, the
following preliminary recommendations should be considered.
(1) Dredging would be best conducted during the late fall and winter months to reduce
heavy metal uptake by organisms.
(2) The spoil disposal areas should be large enough to maximize retention time and
oarticulate settling:.
'&•
(3) The spoil area design should possibly include a system of quarter dikes with the
effluent directed through each pond in a series. Multiple recycling of the effluent
through the settling process may allow for further elimination of contaminants from the
effluent.
(4) Use of flocculants (pH control) in the spoil disposal area to precipitate fine sediments
and heavy metals from the water column.
Page 5-33, Last Paragraph. The final statement should discuss the toxicity effects from
total residual chlorine and impacts of free available oxidants and total residual oxidants
on water quality. The DEIS does document mitigation measures which may be considered
to reduce potential adverse impacts on receiving waters.
Page 4-38, Last Paragraph. The potential for contamination of eroundwater from
leachates originating in u,e solid waste disposal areas may contribute 100-500 pounds of
heavy metal per year into Browns Creek, a valuable salt marsh. These loadings may
cause reduced fecundity and increased mortality in invertebrates, as well as increased
heavy metal concentration in higher-level consumer organisms. The net result would be
severely reduced productivity of this unaltered marsh area.
To avoid this unacceptable impact on fish and wildlife, we recommend thata landfill
areas be lined with impervious liners or that drainage reclamation system be constructed
beneath these areas.
LO
i
52
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r~-
Mr. F. Theodore Bisterfeld
Fish and Wildlife Coordination Act
The St. Johns River is the largest river in Florida and produces and supports tremendous
numbers of birds, fish, shellfish, mammals, reptiles, .and amphibians.
While project design may minimize losses of wetland habitat, no plan for compensation of
unavoidable wetland losses is proposed in the DEIS. Suitable mitigation measures
include, but are not limited to:
(1) Management of remaining wildlife areas (upland and wetland) to maximize value to
fish and wildlif. '
(2) Restore or rehabilitate by construction of wetlands of equal acreage and value to
those lost through construction
(3) Acquire land in fee title to be set aside for wildlife management and managed more
intensively foi fish and wildlife purposes.
Since a Section 404 per—it under the Clean Water Act of 1977 would be required for
wetland filling, the Fish and Wildlife Service would be providing comments to the Corps
of Engineers pursuant to the Fish and Wildlife Coordination Act (16 USC 661, et seq). In
order to meet those requirements, the following comments are offered as a guide in
further project development.
The Fish and Wildlife Service recommends a suitable mitigation package be developed for
inclusion in this project. At this point in project development and review, it is not
possible to identify the alternatives for an acceptable mitigation plan in any specificity.
Accomplishing the definition of alternative mitigation plans and selecting the most
appropriate one will require a combined cooperative effort involving the two sponsoring »
utilities, the Corps of Engineers, and the fish and Wildlife Service, and other appropriate
reviewing agencies. This effort should begin immediately if it is to be completed at
anytime near that when the final statement is released and subsequent permitting
decisions made.
As a preliminary' guide to the likely recommendation of the Fish and Wildlife Service on
this matter, we would probably oppose issuance of any Federal permits unless an area
equal to the wetland area to be lost (84.3 acres) would be set aside and wetland area
created therein if none exists, or if a wetland area of this size exists, it be improved to a
degree equal to tha of the habitat slated for destruction.
In addition, water quality of Browns Creek and the St. Johns estuary may also be
degraded by leachates from solid waste disposal and/or project dredging. Engineering
designs to prevent contamination of water bod;es by Juavy metals, oil, grease and other
pollutants should be incorporated into the project. The Fish and Wildlife Service would
oppose granting of variances from State Standards for the spoil disposal area effluent
53
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Mr. F. Theodore Bisterfeld 4
These comments on the draft statement do not preclude further comments on any
Federal permit applications as required by the Fish and Wildlife Coordination Act. The
Fish and Wildlife Service is committed to work on this project to avoid delays and we
urge early consultation with the Area Manager, 15 North Laura Street, Jacksonville,
Florida 32202.
We iiope these comments will be helpful to you in the preparation of a final statement.
Sincerely,
X / /
^Xc^-X^^'"^-^
~s Bruce Blanchard, Director
Environmental Project Review
JAM 07 i9':;
54
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vj. .DOX
FLORIDA 2SLUNG ASSOCIATION, NORTHEAST BRANCH
I The "Christmas Seal" People
ADVISORY BOARD
ARNOLD TRITT
Chairman
POSITION STATEi-ENT - ALBERTA HIPPS. R.N.
Chairman-Eject
NORTHEAST BRANCH, FLORIDA LUNG ASSOCIATION C^Tc-fJ
REGARDING
COAL-FIRED GENERATION OF ELECTRICITY
The Northeast Branch Board of the Florida Lung Association recognizes
this nation's need to reduce its dependence on foreign oil. It is
our concern, however, that plans to achieve this independence give .
equal attention to the health effects of alternate forms of power
generation. In seeking alternate means of energy production, our
first recommendation is an ongoing search for nonpolluting sources
outside of fossil fuel usage.
Since the Jacksonville Electric Authority (JEA) plans to construct a
coal-fired generating facility in the Duval County area, our position
would favor this construction provided the following conditions are
met:
1) JEA's Kennedy and Southside Generating Stations must
have specific operating conditions as part of the site
certification in order to preclude sulfur oxide viola-
tions,
2] JSA must install and monitor a telemetry system at the
Springfield playground in order to measure potential
violations of the sulfur oxide standards,
I
I
r\i
3) JEA must have on hand, or easily available, a supply
of low sulfur fuels, oil and coal, ' 2
ro
^D
4) JEA cannot operate the coal-fired unit unless they
strictly adhere to the Federal standards. If a viola-
tion occurs, the strictest fine must be imposed,
5) We endorse the construction of two sulfur oxide and
two particulate monitoring sites in addition to the
existing sites to be operated or funded by JEA. Data
from these sites should be made immediately available
to the authorized agencies, and
6) JEA must provide adequate funds for maintenance of the
pollution control euqipment every year the plant is in ,
operation. ' —' /~N s
i
Will'iam RT~Fryar# Ed. D. , Chairman
N.E. Environmental Protection
Committee
55
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Y"
C) /-j
I
o
I am concerned about the drinking water in the vicinity of the proposed .
coal-fired plants.
During a period of drought when restrictions are put on how much water can^
•be used and at which times of the day it can be used, how can you arbitrarily
say JEA nay use as much as 7.6 millions gallons of water.on any cay as long as j 3
the yearly average is no more than 5.1 million gallons?
What is to keep JZA from using 7.6 million gallons on those dry days when our £
acquifer is already low? 3
IOC
^
3
What will you do if JEA does use more water than is allowed? What penalty
or penalities will be imposed? Who will comprise the board to check the
water usage? Residents of Keckscher Drive? or the immediate area?
How can you 'insure that JEA will not use water from the acquifer when the J r-
acquifer is below level? - 3
Kow close to the JEA is the nearest Water Management District Representative?
Is he close enough to enter the property'daily if necessary? If not, what are
the chances of appointing a representative from among those who live in the
immediate vicinity?
Another concern is the noise pollution from the proposed coal unloading facility •
at Blount Island. Have any tests been made in other areas relating to the loss
of hearing over a period of time due to increased noise?
Regarding Blount Island. Recently tides were 2 to 3 feet above normal, and many
yards in the area across from and near Blount Island were under water for several
hcurs each day. Some homes even had water in them.
Can you be sure that drainage and runoff from the lined coal pile on Blount
Island will not be washed into the River and subsequently into the yards of nearby
residents or even into their homes'when tides are this high?
CM
r-
I
ro
r^-
I
I
'.-.'ill the drainage pond be so situated that tidal waters will never reach it?
Will the drainage pond be so treated that stagnant water will not be there to
hatch mosquitoes and other insects? *
My neighbors have seen the endangered Wood Stork flying over Blount Island. If
a rookery were to be found there, what would be the environmental implications?
I
Mrs. Shirley Rogers
5512 Keckscher Drive
Jacksonville, t*L 32226
56
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MEMORANDUM
To: U. S. Environmental Protection Agency,
Florida Department of Environmental Regulation
From: Robin Leigh,
6026 Keckscher Drive,
Jacksonville,
Fl. 32226.
COMMENTS ON DRAFT EIS/SAR ON JEA/FPL SJRPP
A. Position
I recommend that the issance of the NPDES Permit and the
FDER Site Certification be deferred at leasr until:
1 The JEA has demonstrated that substantial economic benefit
to the citizens o fJacksonville will accrue from SJRPP construction
in particular, it must be shown in verifiable terms that energy cos
will be lower with SJRPP than without. Unless such economic benefit
exists, there is no justification for the unavoidable environmental
impacts.
2. That no reasonable alternatives remain to be examined and
that no alternative can be shown to provide equivalent energy
capacity and oil saving at a lesser environmental cost. If a less
damaging alternative exists, based on any criteria, it must be
implemented in .preference to SJRPP.
3. Numerous deficiences in the Draft EIS/SAR document are
corrected and questions arising therefrom are satisfactorily
>-esolved. The SJRFP site is an extremely sensitive one and poses
problems not necessarily addressed by current standards because of
the peculiar site characteristics; it must nevertheless be the
responsibility of the applicant to address all impacts which can be
Identified in advance and to demonstrate an ability to mitigate
carnage, -whether it arises from regulated emissions or otherwise.
It should be noted that more than one economic analysis
c* SJPPP shows that it will increase the cost of electricity _ ^_ _
substantially; that a reasoned program of conservation and shirting
Bating leads away from electricity has been arbitrarily exciuae
Jrora consideration; that envircnnental resources at the tit
already stressed by pollution, in some cases to the ap
statutory limits.
57
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. , oage 2
Robin Leigh,
B. SPECIFIC COMMENTARY ON DRAFT EIS/SAR
Referances are made to chapter/Section/Subsection numbers
in the Draft EIS/SAR document.
-1-4'2'1 TVO modes of transportation are available, similar to the
other sites principally considered- rail and barge/rail.
* 1'4-2'2 ^ Eastport site was poorly rated on both economic and
oriental grounds. Studies by United Engineersjncwea .hat
rotection measures.
~ ^-^ USFPA has not examined all reasonable alteratives _ to the
oroject; the adoption of unnecessarily restrictive criteria (from
FpqrM srbitr-arily precluded examination of some alteratives
"peciScally conslrvation) which were identified at the scoping
meeting.
^Figure 22-4 another one like it) should also show the
- 1% annual probability storm high water line; solid waste disposal
area B (see Fig 2.2-2) is mostly below this level.
- VThv is the 10-year 24-hour storm precipitation maximum an
-abl£ design criterion? The plant, is designed to operate for
,n v.a^c the waste piles will remain inaefinitely. Since iu is
aico^keV that precipitation maxima will occur concurrently witn
s~o?m"ich wate- levels, waste is likely to be widely cistrioured
over t:-V surrounding wetlands rather that being flusned pronp^iy
downstream. One such occurrence could cause long-term carnage to
both animals ana vegeL.a >_ion. _ __ ^ specified in terms
of performance criteria.
- HOW will a 60ft high pile be maintained aoove the level of
crcund wat-r table? Some areas intended for aispcsal are l.xe.y
ave a water table so high (1 - 2 feet) that the pile will oe
Irelsed' Sefow the water table. The relationship^between ground
• r ^ th^'s level, adjacent sensitive surface water anc uncer^yi.^
u cUCh that a try-it-ar.d=sce method or wasue
an unacceptable risk of virtually permanent
contamination .
58
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Robin Leigh page 3
2.3
Page 2-30, site selection criteria:
* Site costs at Eastport are less than in Clay County,
but plant costs would be higher because of the geographical
position, resulting in higher transmission cost.
* EAstport IK zoning is not really compatible with power
plant development; the JAP3 ' s unwillingness to approve
the required exemptions led to the re-zoning of the site
to GU. *
* The JAPE was on record as opposing the Eastport site.
* Air quality i_s_ a serious obstacle to licensing the
Eastport site.
* The Eastport barge facility is large, expensive ($103M)
and according to FPSC not necessary; it is therefore an
unjustifiable impact on the environment.
£.5.2.3
Chloride emissions from the cooling towers must be
addressed as an air pollution source; use of brackish water in
cooling tcv.-ers is a relatively untried system and must be treated
with great concern rather than ignored for lack of FAAQS criteria.
2.5.5.3
Unlined storage of FGD sludge is unacceptably risky; by the
time a problem with leaching is detected, irreversable contaminatio
of ground water will have occurred.
2.5.7.1
Problems of plant orientation are simply functions or the
unsuitablility of the site as a whole.
2.6.1
USEPA analysis of alternatives must not be limited
o
those identified by FPSC. All reasonable alternatives must be
considered by law.
t-,0
i-'C
2.6.2 and 2.6.3.1
There is no need for alternative technology to
implemented by 1987. FFSC found that capacity requirements were-
met'without SJRPP until 1991,; this greatly enhances the potential
caving from conservation by improved efficiency of appliances by
allowing ten years for natural replacement.
59
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* (This portion of Robin Leigh's written comments has been typed in
order to produce a legible copy)
2.6.3.2
Solar water heating should be supplemented by other demand-reducing
methods: e.g.,
• insulation;
• gas rather than electric backup for solar systems;
• high-efficiency appliances.
3.1.1.1
The site is frequently affected by sea-breezes in spring and summer,
which shift the prevailing SW wind to SE during afternoon hours. Briefly
strong winds (40 mph and over) frequently occur in squalls; these winds con-
tribute significantly to TSP in air and would increase fugitive dust emissions.
3.1.3
A concurrent project, the Dame Point Bridge, must be considered in air
quality models. The bridge ramps will be less than 2 miles SW of SJRPP, with
tall gates and upgrade traffic.
3.2
A variance for SJRPP would defeat the purpose of having water quality
standards. The need for a variance is a function of the unsuitability of the
site and none should be granted.
3.3.2.1
1966 water usage is not a true picture. Major water use projects have
changed the pattern in the last 15 years. In particular, all the wells ident-
ified in Appendix M, Inventory of wells, were completed after this date.
3.3.3.2
More study of the impact of withdrawal from the Floridan aquifer is
required. The lack of chloride contamination cannot be guaranteed; a north-
south fault (breach) between upper and lower zones is associated with high
chloride levels about 5 miles south of the site.
3.5.1.1
Water quality is already is problem, and Class III standards are periodi-
cally exceeded. Eastport is therefore unsuitable as a site for further concen-
trations of pollutants.
3.8.1.6
The viewshed of SJRPP represents a major incursion of industrial struc-
tures into areas not presently affected. NGS is not typical of the area,
being the only industrial structure with a significant viewshed within a 2
mile radius. The SJRPP will be two-fold increase in height with the addition
of massive cooling towers higher than any solid structure in Duval County.
These considerations are contrary to the JAPB St. Johns River Corridor recom-
mendations, which seek to preserve the aesthetic value of the adjacent marsh
and river views.
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3.10.1
This noise survey ignores intermittent load noises emitted by power
plants. Residents within two miles of NES are subject to disturbance (usually
at night) by steam blow-off and boiler blow-out. These events are infrequent
but highly disruptive; the proximity of SJRPP would place a double burden of
disruption on the same population.
3.12.2
The lung cancer study failed to eliminate environmental factors other
than asbestos and wood dust as contributors to the high mortality rate.
4.4.21
The well inventory is grossly inadequate; a comprehensive census of wel s
is required. A sample section containing 18 inventoried wells has in fact at
least 66 deep wells, in domestic use. Using this ratio of inventoried to
actual wells, 242 wells may have drawdowns of 2 to 4 feet. At the maximum
rate of pumping these wells may experience drawdowns in excess of 4 feet,
which would leave these wells with inadequate pressure to supply domestic
faucets. The JEA should be required to install the pumping equipment
necessary to maintain the water supplies of affected users.
Since contamination of the shallow aquifer would be essentially irre-
versible, no avoidable risks (such as experiments with unlined storage cells)
should be taken. The potential for irreversible impact is indicative of poor
site selection.
4.6.1.2
Noise impacts will occur with servicing of each unit, both an installa-
tion and during major boiler maintenance.
4.4.2.2 „,
The only significant industry within one mile is NGS but there are numerous °
residences within 1-2 miles of the plant. The frequency of disruptive noise
at these residences would be roughly doubled.
4.7.1.1 §
Unavoidable impacts on rare, threatened and endangered species show the
unsuitability of the site for power plant development.
4.7.2.1
Decreasing pollutant levels in surface water above acute toxicity levels
for some species should not be permitted. If this happens, then the site is
unsuitable.
Chloride deposition on vegetation (especially sea salt) requires careful
study; the relationship between natural deposition and precipitation is im-
portant. An increase from .41 mg/m /hr to 1.31 mg/m /hr is a very large
increase, with potential for affecting soil adsorption, runoff and erosion as
well as direct destruction of some plants.
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2.10.1.2
SJRPP construction is not consistent with existing land use; only limited
sections actually contain industrial development. Water resources occupied by
SJRPP would be unavailable for port-related industry and to that extent SJRPP
would dilute the port-related industrial designation; the JAPB, in contrast
with the Jacksonville Planning Department does not endorse the SJRPP as being
consistent with the 2005 Comprehensive Plan.
4.11.1.2
Roads leading to SJRPP are essentially rural; it is inappropriate to
apply urban traffic density standards. The costs of delay, accidents and
traffic-related pollution will be borne entirely by local residents.
5.1.1
FAAQS standard was violated in 1951 without SJRPP; the Eastport site
will exacerbate this problem.
5.1.2
St. Johns R. is already at and periodically above Class III standards;
the Eastport site is therefore unsuitable for further discharges.
5.1.3
Floridan Aquifer
An accurate inventory of wells, including old un-permitted wells is
required. Serviceable wells must be guaranteed to existing water uses, and
especially domestic potable water uses.
Shallow Aquifer
Water is used for potable water within \ mile of waste disposal areas.
•It is also used for dairy forming purposes where Floridan Aquifer water is
unacceptable, mostly because of H2S. Contamination by leachate would be
irreversable and cannot be risked.
5.1.4
-------
6.1
Even with the restricted criteria, viable alternatives exist. In all
probability, SJRPP will cost its customers more than the do-nothing option.
Theefore— j ^
1. The social and environmental impacts are not offset by overriding economic j -^
benefits; | ^
I
2. SJRPP cannot be licensed at this time since all reasonable alternatives
have not been examined.
6.3 2
The criteria for acceptability of alternatives are not pertinent to the -p
project. j s
6.4
The necessary permits and licences should not be issued at this time
because-
• SJRPP is not required for reasons of capacity;
• • the conservation alternative has not been addressed;
0 future alternatives may be precluded on financial grounds because of
the cost of SJRPP ($2.3 billion should enough to spend on power).
Additionally, there must be no relaxation of impermeability requirements ^
for ponds and storage. Also, it should be an operating requirement to use
surface water for FGD systems in the event that gypsum cannot be sold.
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3.2 RESPONSES TO WRITTEN COMMENTS
This section provides the responses by USEPA to the numbered written
comments in Section 3.1. The responses are given in the same order as the
comments were received by USEPA. Where necessary, comments which are dupli-
cated by different speakers are cross-referenced to avoid repetition.
Response to Comment by US Department of the Air Force:
W-l: No response required.
Response to Comment by the Florida Department of Transportation:
W-2: No response required.
Response to Comments by Offshore Power Systems:
W-3: Since publication of the Draft SAR/EIS, JEA has decided not to use a
coal shuttle train to convey coal from Slount Island to SJRPP. Instead,
a closed conveyor belt system will be employed. The conveyor system has
not yet been designed, but it is expected to parallel the existing
transmission ROW between the NGS and Blount Island. If the conveyor
system is elevated above Heckscher Drive, there should be no impacts on
traffic movement during operation and only minor, short-term impacts
during construction.
W-4: Refer to response to comment W-3.
W-5: Refer to response to comment W-3.
W-6: No response required.
W-7: The coal transloading facility on Blount Island will utilize Best Avail-
able Control Technology (BACT) for dust suppression. BACT for the
Blount Island facility includes both wet suppression and baghouse filters.
In addition, due to the relatively low emission release height and the
small amount of emissions, little interaction between the coal facility
emissions and other sources in the area should occur.
Response to Comments by Federal Emergency Management Agency:
W-8: In order to address the comment, the most recent information concerning
floodplains on the project site has been obtained. This information
includes the 1977 FEMA floodplain map as well as additional detailed,
site-specific information generated by the JEA. Figures 7 and 8 summar-
ize this information in graphic form.
As shown in Figure 7, several areas of the main site are located within
the historical (FEMA-defined) 100-year floodplain. These areas include
a portion of the zone associated with the rail loop and small parts of
solid waste disposal area A (and possibly area B) as well as other
areas. A large part of the coal unloading facility on Blount Island is
also located within the historical (FEMA-defined) 100-year floodplain.
64
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^x
0
UNLOADING
B FACILITY _ A
LEGEND
AO Areas of 100-year shallow
flooding; flood depth I
,- --- to 3 feet; product of
flood depth (feet) and
velocity (feet per second)
less than 15.
AI-A30 Areas of 100-year flood;
" -" -, base flood elevations
-.-> --- and flood hazard factors
determi ned.
B Area between limits of 100-
year flood and 500-year flood;
areas of 100-year shallow
flooding where depths less
than I foot.
C Areas outside 500-year
flood.
FEET
UOOO
Figure 7. Relationship of the main site and Blount Island to the historically (FEMA-
defined) 100-year floodplain. Shaded areas indicate extent of historically
defined 100-year flood.
65
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EXTENT OF
CONSTRUCTION
ACTIVITY
RECLAIM HOPPER
STA0KER-
RE:CLAt^AER
V _^' I ; MARSH
k
\\\ ' STORAGrE->,
PERCOLATION
POND
100 YEAR FLOOD ELEVATION
PROPOSED WHARF
ST. JOHNS RIVER FULTON-DAME POINT CUTOFF
FEET
0 267
Figure 8 Most recent (1981) map of Blount Island showing actual existing topography
100-year floodplain in relation to coal unloading facilities.
66
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As indicated on the flood hazard map, some of the facilities within the
SJRPP would be floodprone if the present topography were not altered.
Areas within the 100-year floodplain in the main plant rail loop will
have to be filled prior to construction. The rail loop will be con-
structed at a level well above the 100-year floodplain. The area to be
used for the first five years of solid waste disposal (refer to response
to comment W-34) is entirely above the 100-year floodplain (Figure 7).
The JEA will not be allowed to dispose of solid wastes in any portions
of waste disposal areas A or B which might be located in the 100-year
floodplain. Portions of waste disposal areas A and B which are not
within the 100-year floodplain will only be approved for solid waste
disposal after completion and evaluation of the five-year testing and
monitoring program as described in the response to comment W-34.
Figure 8 indicates that a large portion of the area to be used for the
coal unloading facility on Blount Island is within the historical (FEMA-
defined) 100-year floodplain. However, because this same area has been
used as a dredge material disposal zone for many years, the existing
topography is very different from that shown in the FEMA map which was
based on outdated topographic data. A recent (1981) survey conducted by
JEA has shown that this area is well above the existing 100-year flood-
plain (Figure 8). Therefore, the coal unloading facility will not be
prone to flood damage. In addition, a 10 foot high dike currently
surrounds the southern shore of the facility and would act as a further
safeguard against flood damage.
W-9: Refer to response to comment W-8.
Response to Comments by US Department of Agriculture, Forest Service:
W-10: The NPDES permit has been conditioned so that no.herbicide use will be
allowed during the construction phase (Appendix 6.1). Mechanical
mowers for clearing will be utilized in most areas that are accessible
during maintenance of all ROW's. For limited access areas, JEA will
employ "CLEARWAY," a USEPA registered herbicide. The USEPA regis-
tration requires that the user adhere to the required rates and method
of application to prevent adverse health or ecological impacts. Adher-
ence to these approved measures will ensure that no adverse impacts due
to herbicide application will result.
Pursuant to Federal regulations, the JEA is required to prepare a Spill
Prevention Control and Count ermeasure Plan in order to mitigate poten-
tial effects of spills of toxic chemicals, fuel oil, or other materials
on the site. Adherence to this plan, as required by law, will minimize
effects of potential spills of these materials.
W-ll: The Florida Department of Agriculture and Consumer Services, Division
of Forestry, has reviewed the Draft SAR/EIS. In a letter to USEPA
dated 7 December 1981 (refer to written comments W-18, W-19, and W-20),
that agency concluded that the Eastport "site is located in one of the
least productive areas in Duval County for timber growth." The FDAC
concluded that from a forestry standpoint, the elimination of the site
from the forestry resource base would not be significant.
67
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W-12: Refer to response to comment W-ll.
W-13: Refer to response to comment W-ll.
W-14: Refer to response to comment W-ll.
W-15: Refer to response to comment W-ll.
Response to Comments by the Sierra Club:
W-16: The following paragraphs present USEPA's response to the comments by
the Sierra Club concerning selection of the alternatives analyzed in
the Draft SAR/EIS.
The Sierra Club has stated that USEPA did not adequately examine energy
conservation as an alternative to construction of the proposed SJRPP.
On the contrary, conserva tion was considered and conservation technol-
ogies were carefully evaluated in the Draft SAR/EIS. Reasonable conser-
vation goals for electric utilities in the State of Florida were estab-
lished by the Florida Public Service Commission (FPSC) under the Florida
Energy Efficiency and Conservation Act of 1980 (FEECA) . In its determi-
nation of the need for the SJRPP, the FPSC factored into the utilities'
demand projections the maximum conservation goals under FEECA. The
underlying requirement of attaining the FEECA goals in the determination
of the need for the project is presented in Section 1.5 of the Draft
SAR/EIS and in the following quote from the FPSC Final Order:
"Should the Commission's FEECA goals governing the growth of
seasonal kilowatt demand be achieved, and we are of the opinion
that they can reasonably be achieved, additional generating cap-
acity for the purpose of insuring adequate supplies of power and
energy to peninsular Florida electric consumers does not appear to
be required until 1991. Similarly, JEA and FP&L do not appear to
require additional generating capacity for reliability purposes
until 1991 and 1989 respectively, should they achieve their respec-
tive FEECA seasonal kilowatt demand goals."
The FPSC has issued orders concerning achievement of the FEECA goals by
the proposed project. These are Order No. 9552, Order Proposing Rules,
and Order No. 9634, Order Adopting Rules. Two statements contained in
these Orders are worth emphasizing. The first, from Order 9552, states:
"Each of the goals developed pursuant to the Act assumes
that it is in the interest of all to do those things which are
cost-effective, and the goals have been set assuming very aggres-
sive marketing programs to achieve high penetration of the best
available cost-effective technology and other measures."
The second, from Order 9436, states:
"These goals represent a starting point for establishing energy
conservation programs for all electric utilities. There is no
absolute assurance that these goals will be fully achieved within
the expected time frames, although the best efforts by the electric
utilities to achieve them will be required."
68
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These excerpts indicate that the FPSC considers the FEECA goals on
which the SJRPP load projections were based to be an aggressive, real-
istic basis for attainment of energy conservation in Florida.
In addition to consideration of general energy conservation goals,
specific alternatives were evaluated both by the FPSC in the need
hearings and by USEPA in the development of the Draft SAR/EIS. The
alternatives considered by the FPSC are identified in the following
quote from its Final Order regarding the SJRPP:
"On May 22 and 23, 1981, public hearings were conducted in
Tallahassee, at which time the Commission undertook a thorough
investigation and analysis of the issues pertinent to a final
decision of the need for SJRPP Units 1 and 2 to displace oil fired
generation in peninsular Florida. The potential alternatives to
the continued use of oil to insure an economical supply of bulk
electrical power and energy to JEA, FPL, and Peninsular customers
which were evaluated included: construction of SJRPP; construction
of additional 500 kv transmission lines to Georgia and within
Florida, or acceleration of currently planned lines for the purpose
of importing increased amounts of 'coal-by-wire' power and energy;
conversion of existing oil-fired units to coal; coal-oil mix (COM)
or coal-water mix; purchases from Georgia Power's Vogtle nuclear
units; additional conservation in excess of the FEECA goals; and
continued use of imported oil. The economic feasibility of each
alternative was assessed, as well as the impact of each upon the
reduction of the consumption of imported oil in the State of Florida."
These statements clearly indicate that conservation was considered by
the FPSC. These conservation features were also included in the Draft
SAR/EIS alternatives analysis.
The Sierra Club questioned the analysis of renewable resources pre-
sented in the Draft SAR/EIS. Appendix AA of the Draft SAR/EIS
addressed the issue of renewable resources. Section 2 of Appendix AA,
"Technology Screening" (pages 5 through 27), addressed various energy
resources which are considered to be renewable. These included the
following:
9 Refuse power
« Solar hot water heating
Solar central power generation
Photovoltaic conversion
Ocean thermal energy conversion
Wind power
Hydroelectric power
Biomass (wood power)
Geothermal power
As noted in Section 2.6.2 of the Draft SAR/EIS, USEPA's analysis eval-
uated these alternatives as well as others on the basis of implement-
ability, technical feasibility, and oil displacement to identify those
which should be considered in greater detail. Based on this analysis,
the renewable resources which were included for further analysis were
69
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refuse power and solar hot water heating. These two technologies were
included in one of the final alternatives (#1) and the alternative was
compared with the SJRPP on the basis of costs and environmental impacts.
Both Alternative #1 and the alternative technologies proved to be
prohibitively expensive (ref. Appendix AA).
In conclusion, USEPA feels that available alternatives were fully anal-
yzed in the Draft SAR/EIS and that conservation was adequately addressed.
Furthermore, the alternatives are consistent with the goals of the
State energy conservation plan and need for the project as defined by
the FPSC.
Response to Comments by the Heckscher Drive Fish Camp, Marina, and Business
Association:
W-17: This comment refers to the discharge of heavy metals, particularly
mercury, from the proposed SJRPP and the effect of these discharges on
the water quality of Browns Creek and the St. Johns River and the
effect of any potential bioaccumulation of mercury on the local fishery.
The sources of wastewater discharge from the proposed SJRPP are described
in Sections 2.2.6 and 2.2.7 and shown in Figure 2.2-8 of the Draft SIS.
During the construction phase of the project, treated wastewater from
construction runoff and effluent from the sanitary waste treatment
system will be discharged via the runoff sediment control pond to
Browns Creek. This wastewater will contain essentially none of the
pollutants of concern such as mercury. During the operation phase all
wastewater will be treated and discharged to the St. Johns River via
the NGS discharge channel except during heavy storm events when dis-
charges may occur from sediment ponds serving the coal piles and land-
fill sites. When these periodic overflows from the sediment ponds
occur, the runoff will go to Browns Creek.
There will be no direct discharge of coal pile runoff from the Blount
Island facility. All coal piles will be lined and the runoff will be
chemically treated prior to discharge into a percolation pond. However,
the treated runoff collected in the unlined percolation pond will enter
the existing near-surface soils on Blount Island and eventually migrate
to the Fulton-Dame Point Cutoff.
The impacts of the operation phase wastewater discharges on the water
quality of the St. Johns River are described in Section 4.3.2.2 of the
Draft EIS. Browns Creek could possibly be impacted by leachates from
the solid waste disposal areas, but these potential impacts are un-
quantified and are to be mitigated by the implementation of the solid
waste disposal and monitoring program. The discharge of treated waste-
water from the SJRPP into the St. Johns River is of concern because
several of the pollutants in the SJRPP waste stream are already present
in concentrations in the River causing periodic violations of Florida
Class III water quality standards. Because it was recognized that such
violations of water quality standards occur already, JEA petitioned
FDER for variances from water quality standards for several pollutants.
If these variances are granted, there will be a certain degree of
70
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additional degradation of water quality in the plant mixing zone and
subsequently, increased stress on aquatic life in the vicinity of the
plant discharge.
The one-year monitoring study conducted by JEA during the preparation
of the Site Certification Application showed that aluminum, copper,
cyanide, iron, mercury, oil and grease, silver, total coliform, and
(possibly) residual chlorine occurred in concentrations in the vicinity
of the SJRPP which exceeded state water quality criteria with varying
frequency (see Table 4.3-2 in the Draft EIS). The FDER has determined
that there were widespread violations of the standards for these param-
eters in the back channel of the St. Johns River, the Dames Point
Channel, and in tributary creeks in the immediate vicinity of the
proposed SJRPP. Elevated concentrations of several pollutants in-
cluding mercury are also known to occur in and above the Jacksonville
metropolitan area. These periodic violations now occur and form the
basis of the request for variances by JEA. The actual causes of the
violations are not known at the present time, however.
Wastewater discharges from the SJRPP will increase the concentration of
pollutants of concern in the plant's 31 acre mixing zone. Because of
the potential effects of bioaccumulation on the quality of the fishery,
mercury is of particular concern. Mercury will be discharged primarily
from two sources; cooling tower blowdown and flue gas desulfurization
(FGD) wastewaters. The cooling system will withdraw water from the NGS
discharge channel, concentrate it 1.5 times by evaporation, and dis-
charge blowdown back to the NGS discharge channel. This will increase
the concentration of mercury in the mixing zone, but will result in no
net increase in the quantity of mercury in the River. However, the FGD
wastewaters contain mercury and other pollutants derived from burning
coal. The variance from Class III water quality standards requested by
JEA was based on the expected quality of wastewater generated by the
various systems and FDER is considering the magnitude of the variances
which may be granted based on the JEA estimates. The mercury contribu-
tion of the FGD system alone is of particular interest because at a
discharge concentration of 70 ug/1 as projected by JEA, it would con-
stitute, under average conditions, more than 99% of the mercury from
the plant processes and about 3.7% of the total mercury in the river
under low flow conditions. USEPA has analyzed the literature available
on FGD systems and has found that a more appropriate estimate of the
concentration of mercury in the FGD waste is an order of magnitude
lower, about 7 ug/1. The predicted concentration of mercury in the
mixing zone using worst case operating conditions (minimum dilution
flow via NGS and average discharge from SJRPP) and an FGD system dis-
charge of 7 ug/1 mercury is 0.76 ug/1 as seen in Figure 9 (Envirosphere
1982). This concentration is a reduction by more than 50 percent of
the JEA's predicted POD mercury concentration of 1.67 ug/1 using 70
ug/1 as FGD system input. Using 7 ug/1 case for the FGD system contri-
bution alone, the mercury concentration at the POD can be reduced from
16 times the water quality standard of 0.1 ug/1 to 7 times the standard.
This, of course, is during the periods when the ambient River quality
itself exceeds the mercury standard by 6 times, a situation observed
during pre-application monitoring. Also notable is the reduction in
concentration at the boundary of a 31 acre mixing zone from 0.7 ug/1 to
71
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1.3 ..
1.2 ..
1.1
o>
3
C
O
C
O
O
C
O
O
1 ..
.9
.8 ..
.7 ..
Minimum Dilution Case
Hg Standard - .1 ug/L
Fob NGS-90808 gpm
FOB at 78 ug/L
Concentration • 1.87
POD to River
FOB »t 7 ug/L
and .76
Rmblent - .6
.6
ftmblent Cono.
.5.
15
flrea In ficras
30
Figure 9. Mercury concentrations in the NGS/SJRPP
mixing zone for FGD waste concentrations of 70 yg/1
and 7 yg/1 of mercury and an ambient river concentratio-
of 0.6 yg/1 (Envirosphere 1982).
-------
about 0.61 ug/1 for the 70 ug/1 and 7 ug/1 cases, respectively. With
ambient conditions at 0.80 ug/1 mercury, a mixing zone concentration of
0.61 ug/1 is approximately a 2 percent increase compared to the 17
percent for the 70 ug/1 mercury.
The JEA formally applied to FDER for variances from the following water
quality criteria included in Chapter 17-3, FAC:
Oil and Grease
Aluminum
Total Residual Chlorine
Copper
Cyanide
Iron
Mercury
Silver
7-3
Section 17-
Section 17-
Section 17-
Section 17-
Section 17-
Section 17-
Section 17-
Section 17-3.121(27)
7-3
061 (j)
3.121(2)
3.121(10)
3.121(11)
3.121(12)
3.121(16)
121(18)
Variances for all these parameters except chlorine are currently being
considered by FDER and must be approved by the Governor and Cabinet.
Variances for copper, silver, and mercury are being considered for only
two years following plant startup pending review of the results of the
bioassay program and additional water quality monitoring as required in
the NPDES Permit and State Conditions of Certification. The variances
for these parameters would apply pnly to the area within the assigned
mixing zone (the maximum allowed mixing zone is 31 acres). Based on
the results of mathematical modeling conducted by FDER, it was con-
cluded that there would be very little difference in levels of the
above parameters at the edge of the NGS/SJRPP discharge mixing zone and
all areas outside the mixing zone. The modeling also showed that this
conclusion would hold whether ambient water quality outside the mixing
zone exceeded the State water quality standards or not. This implies
that the SJRPP discharge would have little effect on ambient water
quality outside the mixing zone. Nevertheless, degradation of water
quality and added stress on aquatic life within-the mixing zone and at
the POD will result, as stated in the Draft SAR/EIS.
Mercury can be concentrated in the tissues of fish and other aquatic
organisms at much greater levels than are found in the surrounding
environment. Mercury bioaccumulation has been investigated on a limited
basis by the Jacksonville Bio-environmental Services Division. In a
limited sampling of fish and shellfish from the St. Johns River, no
mercury levels were found approaching the Food and Drug Administration's
limitation for mercury in fish flesh of 1 mg. per kg. This indicates
that there is probably not a health risk associated with existing con-
ditions in the River or with the small increase associated with the
operation of the proposed plant. However, due to the small amount of
data available, this assessment of the situation should not be regarded
as conclusive. USEPA is obtaining additional bioaccumulation data to
verify the accuracy of present information. If, as expected the fish
flesh data verify the limited existing data, no significant impact is
expected on the St. Johns River fishery from the SJRPP mercury discharge.
Further, the decision on the NPDES permit will be made after these data
have been obtained and evaluated.
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Due to concern over the expected mercury concentrations in the discharge
mixing zone several actions will be taken to assess the effects of the
proposed SJRPP.
• JEA will be required by their NPDES Permit to conduct a bioassay
test program on their effluent to determine aquatic toxicity.
• JSA will be required to investigate bioaccumulation of mercury
in the mixing zone.
• JEA will be required to annually reevaluate the FGD system
effluent and determine if newer technology has become available
which would allow a reduction in the amount of mercury discharged
from the system. In addition, JEA will be required to design the
plant to enable .segregation of the FGD wastewaters for greater
treatment should USEPA determine it to be warranted.
Response to Comments by Florida Department of Agriculture and Consumer Services:
W-18: No response required.
W-19: A complete construction erosion control plan was included in the SCA/EID
(JEA/FP&L 1981). This plan included measures to control erosion such
as contouring of the site, mulching, berming, and seeding. In addition,
JEA is currently preparing a complete landscape plan for the site which
includes planting of shrubs and other types of vegetation. This will
also help minimize erosion during the operational phase of the SJRPP.
W-20: Although the forestry value of the site is poor, many trees occur there
which would be of value as firewood. However, it would be difficult
for JEA to allow public access to the site because of the potential for
liability suits to be brought against the Authority should accidents
occur to private citizens during tree cutting operations. JEA has
decided not to institute a public program for this reason. A non-public
program for salvaging valuable hardwoods will probably be instituted by
JEA during site clearing.
Response to Comments by US Department of Housing and Urban Development:
W-21: No response required.
W-22: If the fly ash is transported, it will be wetted before loading onto
trucks to improve the handling characteristics and reduce fugitive
emissions. Also, trucks will be covered during transport to reduce
spillage.
Response to Comments by US Department of Interior, Fish and Wildlife Service
(Jacksonville Area Office);
W-23: The Florida Game and Fresh Water Fish Commission has issued an informal
statement concerning the feasibility of relocation of the gopher tor-
toise and eastern indigo snake (FGFWFC 1982). The Commission stated
74
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that gopher tortoises are abundant on the site and indigo snakes and
other gopher burrow commensals potentially occur on-site. These spe-
cies will virtually be eliminated in the vicinity of site construction.
Because such species are legally protected, a means of minimizing
potentially adverse impacts must be found.
One possible mitigative measure would be to require JEA to purchase
additional natural areas that meet the habitat requirements of the
impacted species. In addition, gopher tortoises, indigo snakes, and
other State-listed burrow inhabitants encountered during construction
could be captured and released just beyond the perimeter of the area to
be developed.
The Game and Fish Commission noted that relocation is often proposed as
an expedient means of dealing with jeapordized animals. They consider
wildlife relocation to be generally biologically unsound, however.
Animals often cannot be transplanted to already occupied habitats
because of the possibility of parasite or disease transmission, dis-
ruption of existing social orders, increased competition resulting in
intolerable stress for resident as well as relocated populations, or
other potential problems. The Commission would not necessarily reject
the idea of relocation, but before accepting such a plan would have to
evaluate a detailed relocation proposal and be kept appraised of prog-
ress. In any case, only those areas once harboring these species but
now vacant because of over-exploitation or other factors would be even
minimally acceptable as reintroduction sites. Follow-up studies to any
approved relocations should also be undertaken to determine the success
or failure of the effort. If JEA decides on a relocation plan, the
State would be the ultimate authority in granting approval.
W-24: No response required.
W-25: No response required.
W-26: No response required.
W—27: No response required.
Response to Comments by Defenders of Wildlife;
W-28: As the result of a formal Section 7 Consultation, the US Fish and
Wildlife Service has officially determined that the construction and
operation of the main plant site, coal unloading facility, and trans-
mission lines (including dredging) will not jeopardize the continued
existence of the manatee or adversely modify the manatee's critical
habitat (Comment W-23). However, the USFWS did express specific con-
cern about possible effects of dredging on manatees (Appendix 6.3).
Potential effects of dredging will be mitigated by incorporation of
several mitigative measures into the Section 10/404 permit (Appendix
6.3). The US Army Corps of Engineers has agreed to condition the
permit to include certain of these measures. The Corps will request
that dredging be limited to late fall or winter months which is the
period of lowest manatee activity. The Corps will also require that
the Quarantine Island area be utilized for dredge material disposal.
This area is sufficiently large to store the dredged material, and the
75
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large size of the area will ensure adequate time for settling and
detoxification of the dredged material (Refer to response to comment
W-54 for a more complete discussion concerning mitigation of adverse
effects due to dredging)
W-29: The proposed project will not adversely affect bottlenose dolphins in
the St. Johns'River (dolphins were observed in the vicinity of the
plant during the manatee survey conducted during the completion of the
SCA/EID). Thermal discharges to the River will not pose a threat to
dolphin populations because the actual increase in the heat load will
be extremely small and would be limited to a relatively small mixing
zone of 17 acres. Wastewater discharges will be rapidly diluted in the
relatively small mixing zone (Refer to response to Comment W-17) and
will not adversely affect local dolphin populations which might be
migrating into or out of the estuary. Since the SJRPP will use the NGS
discharge as its source of cooling water, virtually no entrainment
effects will be produced by the plant. Thus, no impacts on the estu-
arine food chain would result that could ultimately affect dolphins.
JEA is making a continued effort to make the fish removal system at NGS
more efficient. The added impingement caused by the SJRPP could have
adverse effects on local fish populations (page 4-79 of the Draft
SAR/EIS). It is highly unlikely, however, that this would adversely
affect dolphins. JEA is currently conducting a fish impingement study
and is attempting to improve the efficiency of the fish return system.
Response to Comments by US Public Health Service, Department of Health
and Human Services:
W-30: The comment has been noted. The appropriate missing pages concerning
public health have been included in Appe-ndix 6.5.
W-31: Two unit trains per day are expected to deliver coal to the SJRPP. Due
to the present level of use, two trains per day probably would have a
minimal effect on ambient noise levels in the vicinity of SJRPP. The
plan to use shuttle trains to move coal from Blount Island to SJRPP has
been dropped. A new proposal by JEA calls for the use of a conveyor
system to deliver coal to SJRPP from Blount Island rather than shuttle
trains. The conveyor system will be covered so that noise and air
pollution will be minimal.
W-32: The City Health Department and Florida Department of Environmental
Regulation do not require a formal written vector control plan to be
submitted. During the Site Certification process, however, FDER con-
siders vector control as a factor in reviewing the design of solid
waste disposal areas.
W-33: The projected impacts of the proposed withdrawal on surrounding wells
are presented in Section 4.4.2.1 of the Draft SAR/EIS. Certain re-
visions to the information presented in the SAR/EIS are presented in
Chapter 2.0 of this Final EIS. Analysis of recent potentiometric
surface maps (September 1980) shows that artesian flow from the Flori-
dan Aquifer occurs in the area at a head of approximately 15 to 20 feet
above land surface. Thus, with an average case drawdown of 9 feet at
the nearest well, it would appear that no wells in the area would lose
76
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artesian flow solely as a result of average pumpage for the proposed
plant.- It is recognized that the rates of discharge will decrease due
to the SJRPP which will cause pumped wells to operate longer to produce
a given quantity of water. It is unlikely pump level adjustments will
be necessary so long as artesian flow conditions exist. For those
users currently utilizing artesian wells, the flow could be substan-
tially reduced, possibly necessitating the use of pumps to deliver the
same quantity of water. The general level of the Floridan Aquifer has
been falling by approximately one-half foot per year since the 1940's.
Some wells in the area may lose artesian flow at some time in the
future regardless of whether the SJRPP is built or not. Nevertheless,
the project could cause the impact to occur sooner.
W-34: The proposed NPDES Permit has been conditioned by USEPA to allow JEA a
period of five years to conduct a solid waste disposal test program.
The program is intended to demonstrate the environmental acceptability
and feasibility of JEA's proposed long-term solid waste management
plan. Following the five-year test program, USEPA will reevaluate the
proposed long-term solid waste management plan and require any changes
necessary to assure compliance with State groundwater quality standards
and any applicable Federal groundwater quality standards.
During the five-year test program, all solid waste disposal will be
limited to an area' of approximately 100 acres located between the plant
rail loop and Island Drive (Figures 2 and 7). This is one of the areas
of highest elevation on the SJRPP site and will provide the greatest
possible separation from the groundwater table. It is also more than
large enough to accommodate all of the solid waste generated by the
plant during the first five years of operation even if none of the
solid waste disposal material were marketed as gypsum.
The solid waste disposal test program will be carried out entirely
within the 100-acre area shown in Figure 2. The program will include
three major features: (1) a leachate test program in a fully lined
five-acre test cell; (2) a program for disposal of unmarketable solid
wastes in several adjacent unlined 10-acre cells (employing physical
stabilization of these wastes and soils at a minimum); and (3) a detailed
geological/ groundwater study of all solid waste disposal areas on the
site.
The test program should determine the effectiveness of the disposal
cell design in minimizing leachate contamination of area groundwater
supplies. The five-acre test cell will be provided with a sand
blanket, underdrains, and an impermeable plastic liner in order to
allow recovery and measurement of leachate. The test cells will be
surrounded by a lined ditch to allow sample collection and measurement
of runoff. Underdrains will convey leachate to a common point for
sampling and flow measurement. Other monitoring systems (e.g., rain
gaging, observation wells) will be installed as required. The upper
surface of the waste pile will be compacted, sloped, and seeded to
minimize infiltration. All leachate and runoff generated at the test
facility will be directed to an existing plant wastewater stream for
treatment, discharge, or reuse.
77
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All solid waste materials which are not used for the test program
and/or which are not marketed will be disposed of in adjacent ten-acre
cells. The cells will be constructed well above the water table and
the bottom material as well as the waste will be compacted in layers to
minimize leachate. Berms and ditches will be constructed around the
cells to divert site runoff away from the landfill area. Runoff from
the cells themselves will be collected and treated in sedimentation
ponds and routed to the chemical wastewater treatment system. When the
layers of waste material and cover soil have reached a height of about
60 feet, the cells will be capped off with gravel and soil. The cells
will then be sloped and seeded.
The third major element of the test program will be a detailed study of
the geologic and groundwater characteristics of the site. The objec-
tive of this program will be to relate solid waste disposal and leach-
ate transport to existing groundwater conditions. This program will
include groundwater monitoring in the five-year test cell disposal
areas as well as in solid waste areas A and B (Appendix 6.1). Due to
concern over the potential for the leaching of trace metals from the
waste disposal cells without impermeable liners, special care must be
taken to assure that the bottom layers of each cell are not in contact
with the near surface groundwater. This is of particular concern in
disposal areas A and B (Figure 7) since they are in lower areas with
somewhat higher water tables. The site investigation will include
continuous monitoring of groundwater elevations in all solid waste
disposal areas in order to determine the historical high elevations and
durations. In addition, testing will also be conducted to determine
the possibility of an interconnection between the near surface ground-
water and the shallow rock aquifer (Also refer to response to comment
P-21 concerning hazardous waste handling).
Based on the results of the leachate tests, the monitoring of the
unlined cells, and the further investigations of disposal areas A and
B, JEA will submit a long-term plan to US EPA for the disposal of solid
wastes at the SJRPP. The plan will be submitted after the first five
years of monitoring and will cover the remaining 35 years of the plant s
expected life. US EPA must review and approve the plan prior to use of
either disposal areas A or B by JEA. Appropriate measures including
(if necessary) liners, chemical fixation, or other means will be util-
ized for each portion of the site in order to assure that groundwater
contamination does not occur. In order to further assure protection
during the interim of the five-year test program and for the 40-year
duration of the project, JEA will be required by the FDER Conditions of
Certification to monitor the groundwater in both the surface ground-
water table and the shallow rock aquifers at a distance no more than
200 feet downgradient of each cell. If at any time the test or monitor-
ing programs indicate a potential for violation of groundwater quality
standards, the cell(s) will be sealed, relocated, or its operation will
be altered to correct the problem.
Response to Comments by Mr. Mat Roland:
W-35: Refer to the response to comment W-17.
78
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Response to Comments by Stella D. Andrews:
W-36: No response required.
W-37: No response required.
W-38: No response required.
W-39 : No response required.
W-40: Refer to response to comment W-17.
W-41: Refer to response to comment W-33.
Response to Comment by Lee Pelej :
W-42: It is unlikely that drawdown of the Floridan Aquifer will affect fresh-
water wetlands because the shallow aquifer system will not be affected
by withdrawals. This is because the shallow aquifers are separated
from the deeper Floridan Aquifer by the Hawthorne Formation, which acts
as an aquiclude (Section 4.4.2.1 of the Draft SAR/EIS).
Response to Comments by "Intervenors":
W-43: Refer to response to comment W-17.
W-44: The recent drought and water use controls announced by the St. Johns
River Water Management District (SJRWMD) do not materially alter the
conclusions reached in the Draft SAR/EIS regarding the effects of the
proposed groundwater withdrawal at SJRPP. First, according to infor-
mation from the SJRWMD, the water use restrictions imposed in Duval
County are only voluntary on the north side of the St. Johns River
where the SJRPP is located and specifically do not apply to power
plants anywhere in the County (Thompson 1982). Secondly, the drought
experienced in northeast Florida in 1981 was rather severe and was
estimated to be a once in 200-year to once in 400-year occurrence. As
a result of the drought, the level of the Floridan Aquifer in the
Jacksonville area declined by several feet leading to the imposition of
water usage controls. The SJRWMD now reports that with the return of
normal rainfall patterns, the level of the Aquifer has begun to rise
again (Thompson 1982).
In spite of the drought, the conclusions reached in the modeling analy-
sis should remain valid. The fluctuations in water level have all
occurred within the same formation, so that factors such as transmis-
sivity and leakance (which affect the model) would remain constant.
Therefore, small changes in the level of the Aquifer would not change
the validity of the drawdown estimates predicted by the SJRWMD model.
The conclusions reached concerning the effect of the additional draw-
down on surrounding wells also should not be significantly affected.
With the aquifer level rising from its drought condition, it still
appears unlikely that any of the surrounding wells would lose artesian
flow solely as a result of the withdrawal proposed by JEA. The with-
drawal would, as discussed in the Draft SAR/EIS, reduce the rate of
79
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discharge, thereby causing pumped wells to operate longer to produce
the same amount of water and substantially reducing the production of
artesian wells. Because general water levels in the Floridan Aquifer
have been falling at a rate of approximately 0.5 ft/year since the
1940's, there would be a general decline in the productivity of artesian
wells in Duval County in the future regardless of whether the SJRPP is
built (Thompson 1982).
W-45 : Refer to comment W-44.
W-46: The proposed project will result in the eventual filling or elimination
of a total of 84.3 acres of seasonally flooded wetlands, including 1.5
acres of bottomland hardwood, 32.6 acres of cypress swamp, 22.7 acres
of bayhead, and 27.5 acres of hardwood swamp (Section 4.7.1.1 of the
Draft'SAR/EIS). No salt marsh will be eliminated during construction
since it has been determined that the areas of Blount Island which were
originally thought to be impacted are located in a transmission line
ROW and would actually not need to be eliminated.
The 84.3 acres of seasonally flooded wetlands represent about 34% of
the total acreage (249 acres) of these types of communities on the
site. The remaining areas of seasonally flooded wetland not affected
by the site will be protected by a 200 foot buffer zone bordered by a
fence. The original area to be fenced off has also been increased in
order to provide additional protection to these areas from human in-
trusion. These areas and the salt marshes of nearby Brown and Clap-
board Creeks will be futher protected during construction by collection
of all runoff from open or filled areas in several sedimentation ponds.
The NPDES permit (Appendix 6.1) has set effluent limits on the dis-
charge from the main sediment pond in order to minimize impacts, specific-
ally in the Browns Creek marsh. Furthermore, these same areas are not
projected to be affected by drawdown of groundwater during operation
since the Hawthorne formation effectively separates the surficial
aquifers from the Floridan Aquifer (from which the SJRPP will take its
groundwater). In conclusion, filling of seasonally flooded wetlands on
the site and operation of the SJRPP will not result in a major adverse
impact on adjacent wetlands. However, as stated in the Draft SAR/EIS,
the eventual elimination of the 84.3 acres of seasonally flooded wet-
lands on the SJRPP during the life of the project will constitute the
most important overall adverse impact on wetlands. This impact must be
weighed against the social and economic benefits of the project.
W-47: The value presented in Table 2.5-6 of the Draft SAR/EIS for O&M rep-
resents the annual cost for operation and maintenance, but also includes
the initial cost of the equipment spread over the projected life of the
facility. The annual cost for O&M only is projected to be $68,498,000
(EBASCO Services, Inc. 1982).
W-48: No response required by USEPA.
Response to US Department of Interior Office of the Secretary:
W-49: The Section 7 consultation with the Jacksonville Area USFWS Office
concerning the power plant, coal unloading facility, and transmission
80
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line corridor has been completed (Refer to comments W-23 through W-27).
The results of the consultation indicate that the continued existence
of Federally listed species which occur in the vicinity of the SJRPP or
on the site would not be threatened by the proposed project. An adden-
dum to the original Section 7 consultation has also been completed
concerning the potential effects on Federally listed species due to
dredging activities associated with the coal unloading facility and
transmission line towers. A copy of this Biological Opinion is in-
cluded in Appendix 6.3 of the Final EIS. It includes conditions that
will be required in the Section 10/404 US Army Corps of Engineers
permit in order to mitigate potential dredging-related impacts on
Federally listed species. The conclusion of the Biological Opinion was
that the continued existence of Federally listed species which occur in
the study area would not be threatened by dredging activities if these
measures are followed. The US Army Corps of Engineers agreed that
certain of these measures will be instituted as a requirement of the
Section 10/404 permit (Refer to response to comment W-54 for a more
complete explanation of mitigation measures to be employed).
W-50: The transmission lines would parallel existing ROW's, so that no addi-
tional access roads would be required. Furthermore, the amount of
clearing required will be minimal. Appendix 0 of the Technical Refer-
ence Document for the Draft SAR/EIS provided a detailed summary of
transmission line impacts. In order to fully address the comment, the
following excerpt from that discussion is provided:
"The construction of two 230 kV transmission lines from the
proposed site to the Normandy Substation and to the Fort Caroline
and Robinwood Substations will be directly associated with power
plant development. Following site certification approval, a right-
of-way (ROW) alignment will be established. The preferred corridor
includes an existing transmission line ROW from the Northside
Station to the respective substations. For over 90% of the new
ROW, it is anticipated that the existing ROW will simply be ex-
panded by up to 150 feet to accommodate the new facilities. Where
the existing ROW is not followed, a new ROW of up to 200 feet in
width will be constructed."
"The preferred corridors to the JEA's Robinwood and Normandy
Substations include wooded wetlands with very little salt marsh
found in the proposed plant to Robinwood section. The wooded
wetland areas in the preferred corridor have been largely drained.
Thus, ROW alignment would have little effect on corridor wetlands
as a whole. No major wooded wetland stands would be completely
cleared or bisected by new ROW construction. The largest undis-
turbed wooded wetland area to be affected is a cypress dome near
the Normandy Substation. Assuming that the new ROW will be adja-
cent to the existing ROW, relatively little additional clearing
would be required through this habitat (less than 150 feet)."
"With proper construction care, salt marshes would not be
adversely impacted by transmission line construction. Corridor
vegetation consists of herbaceous species that do not impair the
establishment and maintenance of a transmission line. By using
81
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mats to support heavy equipment in the marsh, lasting damage to the
marsh would be avoided. If towers must be located in a marsh, the
marsh habitat would be disturbed only in the immediate tower founda-
tion areas. This would result in temporarily increased turbidity
levels. When construction in a particular area is complete, the
mats would be removed and affected habitats would recover. Construc-
tion noise would temporarily disturb water birds feeding in nearby
salt marshes."
"Impacts on upland communities would be greater in forested
areas than in open habitats. ROW clearing would result in removal
of all trees and brush in ^he ROW that could interfere with the
safe operation of the transmission line. Wood and brush material
removed would be disposed of in landfills, sold, or burned. Move-
ment of timber harvesting and construction equipment is expected to
churn, rut, and compact soil in wet areas. Increased erosion may
result. Forested areas would be replaced by early secondary eco-
logical successional stages. No major forest stands will be in-
volved in ROW preparation and no chemical herbicides and pesticides
are planned to be used during ROW preparation."
"The only areas of open water to contain transmission towers
will be in Mill Cove. The entire width of the St. Johns River will
be spanned without placing a tower in the open channel. New trans-
mission tower locations will be east of existing towers in habitats
exposed at low tide. Dredging (dragline) equipment will be brought
into the Mill Cove area by barge via the existing channel. Efforts
will be made to minimize sediment disturbances including barging in
of equipment during high tide periods. Streams and channels will
be spanned and, where necessary, culverts will be placed to avoid
altering stream flow characteristics."
"The most important wildlife to be potentially affected by
construction of the transmission lines and towers are colonial and
raptorial bird species. Potential impacts to other wildlife species
are not anticipated to be serious due to their relatively larger
abundances or local absence."
"The special areas of wildlife importance include Blount Island
and the NGS area. On Blount Island, spoil areas on and near the
existing ROW have the potential to become nesting habitat for
several species of shorebirds as well as least terns (Sterna albifrons),
However, if construction takes place during the breeding season
(April-August), these birds may be driven away from nesting areas.
Similarly, the osprey (Pandion haliaetus) frequently nests in
transmission towers and has nested in towers on Blount Island and
in the salt marsh near the NGS. Construction in the areas of
nesting terns and osprey will be avoided. Fresh spoil mounds left
behind or introduced to the area may expand potential nesting
habitat for the terns."
W-51: Refer to the response to comment W-8.
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W-52: Potential impacts of each alternative on wetlands and related fish and
wildlife resources were discussed in more detail in the Technical
Reference Document for the Draft SAR/EIS. However, an in-depth analy-
sis equivalent to that conducted for the Eastport site was not possib •=
primarily due to the lack of adequate information concerning the FP&L
Sanford Plant and other portions of the FP&L service area.
W-53: Refer to the response to comment W-17.
W-54: The USFWS has subsequently completed an addendum to the original
Section 7 consultation (Refer to comments W-23 through W-27). The
addendum concerns the potential impacts of dredging on threatened and
endangered species. The results of this consultation are provided in
Appendix 6.3. The USFWS concluded that if the appropriate mitigative
measures are employed, the continued existence of Federally listed
species in the study area will not be threatened. The US Army Corps of
Engineers has agreed to require that certain of the recommended measures
be instituted as a condition of the Section 10/404 permit. As requested
by the US Fish and Wildlife Service, the US Army Corps of Engineers
will require that dredging be conducted during the late fall and winter
months which is the period of lowest manatee activity. The Corps has
also determined that the Quarantine Island disposal area is more than
large enough to contain the amount of dredge material resulting from
the SJRPP project. Because of the large size of the disposal area, the
Corps feels that quarter dikes are not necessary as a mitigative measure.
The dredge material will be spread over a large area and the liquid
fraction will have a long retention and settling time prior to dis-
charge via a wier. These factors will allow for maximum settling time
as well as flocculation of trace metals (and subsequently effective
removal from the overflow discharge). The Corps will not require the
applicant to utilize chemical flocculants in the spoil disposal area.
W-55: The Florida Department of Environmental Regulation is recommending
denial of JEA's request for a variance for chlorine. The FDER is
recommending that chlorine levels at the POD of the combined main
discharge of the NGS/SJRPP be limited to 0.10 mg/1 at all times and
that chlorine concentrations not exceed 0.01 mg/1 past the 17-acre
instantaneous mixing zone (Appendix 6.2). The original limits given in
the Draft SAR/EIS were 0.20 mg/1 at the POD for a maximum period of 2
hours per day per cooling tower. The proposed NPDES Permit (Appendix
6.1) limits total residual oxidants (TRO) in the NGS/SJRPP discharge
(NPDES 001) to 0.10 mg/1 (instantaneous maximum) at the POD. Both the
State and Federal limits are based on the Florida Water Quality Stan-
dards [17-4.244(4)] which prohibit a maximum pollutant concentration
within an assigned mixing zone which exceeds the amount lethal to 50%
of the test organisms in 96 hours (96-hr LC5()). The 96-hr LC5Q of the
blue crab of 0.10 mg/1 was used to establish this limit within the
mixing zone.
W-56: Refer to response to comment W-34.
W-57: Wetlands compensation has been formulated through interagency coordina-
tion with the JEA. It has been required as a condition of the NPDES
permit (Appendix 6.1). The wetlands compensation will consist primar-
ily of fencing off additional areas of land on the site in order to
83
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more completely limit public access (Figure 3). Fencing will be added
along the full length of the property lines on Island Drive and also
along a portion of the northwest corner of the site (Figure 3). By
limiting access in this manner, remaining undisturbed areas (including
both upland and wetland communities) within the property lines of the
site will be protected. In addition to agreeing to the additional
fencing, JEA has also agreed not to disturb the 1 acre of salt marsh
located in Blount Island (Figure 4) that was originally slated for
elimination. The original 200-foot buffer zone around all seasonally
flooded wetlands remaining on the site following construction will also
be maintained.
W-58: Refer to response to comment W-57.
W-59: Refer to the response to comment W-34.
Response to Comments from the Florida Lung Association:
W-60: The State Conditions of Certification for the SJRPP (Part I-E)
(Appendix 6.2) specify the operational restrictions which JEA must
follow to ensure that there will be no violations of the Florida Air
Quality Standard for sulfur dioxide. Under maximum load conditions at
SJRPP and NGS, the Southside Generating Station will be shut down.
W-61: No response required.
W-62: The sulfur content of the coal and oil used for SJRPP will meet the
requirements specified in the PSD permit to ensure that no violations
of the FAAQS or NAAQS for sulfur dioxide will occur.
W-63: No response required.
W-64: No response required.
W-65: No response required.
Response to Comments by Mrs. Shirley Rogers:
W-66: The use of groundwater at the SJRPP will be regulated as stated in
Section III of the FDER Conditions of Certification. Groundwater will
be required at the SJRPP for a variety of uses including operation of
the FGD systems, potable water supply, fire protection, plant service
water, and makeup to the boiler water demineralizer system. The largest
single demand will be the daily average of 3.09 mgd required to run the
FGD system. Periods of peak operation may occasionally occur when
other water uses are required, increasing demand to a peak level (about
equal to 7.6 mgd). Fluctuations in the groundwater demand of the power
plant should be relatively minor, however, and peak demand situations
should be of short duration (approximately 24 hours). It does not
appear that the plant's peak demand would conflict with the current
water use restrictions imposed by the St. Johns River Water Management
District (SJRWMD). The restrictions on the north side of the River
where the SJRPP is located are voluntary and power plants are specifi-
cally exempted from the restrictions at this time. For further discus-
sion, refer to the response to comment W-44.
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W-67: As noted in the response to comment W-66, the peak water demand of the
SJRPP would be exempted from the current water use restrictions al-
though internal plant recycling will be used to keep water use as low
as possible. A provision has been included in the FDER Conditions of
Certification (III-C) which could be used to establish limits to the
drawdown caused by SJRPP. However, a problem with excessive drawdown
is not likely to occur since the recent water shortage was not a common
event. Estimates by the SJRWMD indicate that the recent drought was
between a once in 200-year and once in 400-year occurrence (Thompson
1982).
W-68: Chloride intrusion into the Floridan Aquifer in the vicinity of the
SJRPP was described in Section 4.4.2.1 (page 4-54) of the Draft SAR/EIS.
It was noted that the wells at the SJRPP would be installed in such a
way as to minimize chloride upconing. Nonetheless, the pumping of
additional water from the Aquifer would contribute to an overall trend
of gradual chloride increase which has been occurring for more than 30
years due to the extensive areawide use of groundwater. If chloride
intrusion becomes a serious problem locally, the SJRWMD can require
that SJRPP shut down its wells.
W-69: Limitations on the use of groundwater by the SJRPP are covered in
Section III of the FDER Conditions of Certification (Appendix 6.2).
JEA will be limited to pumping an average daily withdrawal of 5.1 mgd
and a daily withdrawal of 7.6 mgd maximum. The utility will be re-
quired to operate and maintain a record of pumpage from each well and a
continuous record of water levels in the Floridan Aquifer. Represen-
tatives of the SJRWMD and FDER will have the authority to come on-site
to inspect the facilities and records at any time. Violation of re-
strictions or reporting requirements could be punished by revocation of
JEA's authority to withdraw water from the Floridan Aquifer or other
action deemed appropriate by FDER or the SJRWMD.
W-70: Provisions are included in Section III of the FDER Conditions of Certi-
fication to require JEA to reduce or cease its withdrawal of ground-
water during emergency situations.
W-71: The St. Johns River Water Management District offices are located in
Palatka. Representatives of the SJRWMD and FDER will be authorized to
enter the site for inspections at any time. At this time there are no
plans to designate any citizen representatives to perform inspections.
W-72: An assessment of noise levels at the Blount Island coal handling facil-
ity is presented on page T-23 of the Technical Reference Document. The
maximum noise level experienced by the nearest receptor to the facility
will be 43 dBA. This is 9 dBA below the existing noise level at the
receptor and 27 dBA below the level USEPA considers as possibly harmful
with continuous exposure.
W—73: No response required.
W-74: The drainage pond will be located above the 100-year floodplain on
Blount Island. Therefore, no coal pile drainage or runoff will enter
the River even during unusually high tides. The 10 foot high dike
85
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around the southern edge of the facility will add further protection
against flooding. Refer to the response to comment W-8 concerning
floodplain impacts.
W-75: The coal pile drainage pond would not be reached by tidal waters since
it is located above the 100-year floodplain.
W-76: The drainage pond will be designed so that water continually percolates
downward into the soil. Except for periods of high rainfall, there
will usually be little water in the pond. Evaporation will further
reduce the amount of standing water in the pond. These factors will
reduce the use of the pond as a mosquito breeding area. In addition,
the pond is very small in area as compared to available mosquito breed-
ing grounds in the vicinity.
W-77: The nearest nesting colony of wood storks is located about 25 miles
south-southeast of the site in southern Duval County. Because of the
relatively industrialized and disturbed nature of Blount Island, it is
unlikely that wood storks would nest there.
Response to Comments by Mr. Robin Leigh;
W-78: Refer to the response to public hearing comment P-22 for a discussion
of the relative costs of each of the alternatives considered in the
Draft SAR/EIS. Also refer to the response to written comment W-16 for
a discussion of the achievement of conservation goals and analysis of
alternatives. It was demonstrated in the Draft SAR/EIS that the SJRPP
would be economically competitive with the other alternatives over the
short run (through the year 2000) and that it would provide additional
generating capacity now that would have to be provided at additional
cost under the alternatives at some later date. Refer to Section 2.6.4
and Appendix BB of the Draft SAR/EIS for a more detailed discussion of
the economic comparisons of the alternatives.
W-79: Refer to the response to comment W-78.
W-80: No response required.
W-81: No response required.
W-82: Refer to the response to public hearing comment P-4. The Eastport Site
actually possesses several economic advantages.
W-83: USEPA conducted a completely independent evaluation of available alter-
natives based on the need for power as identified by the FPSC. This
analysis was conducted in direct response to issues raised at the
scoping meeting. Refer to the response to written comment W-16 for a
discussion of the choice of alternatives analyzed in the Draft SAR/EIS.
W-84: Figure 7 illustrates the relationship of the site to the FEMA-defined
historical floodplain. As shown in the figure, only a small area of
solid waste area B is actually within the 100-year floodplain. Refer
to the response to comment W-8 for details concerning floodplain bound-
aries and impacts of the project on floodplains.
86
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W-85: USEPA Effluent Guidelines for the Steam Electric Power Generating Point
Source Category defines the design basis for coal pile runoff as the
10-year, 24-hour storm. Specifically, this requirement is given in the
Federal Register, Volume 39, Number 196, October 8, 1974 [Code of
Federal Regulations, Title 40, Part 423.40 and 423.45 (promulgated)]
and Federal Register, Volume 45, Number 200 [Code of Federal Regula-
tions, Title 40, Part 423.15 (proposed)]. Runoff from higher intensity
storms is expected to be extremely dilute and of little impact. The
only two sediment ponds to be lined with plastic (polyethylene) include
the main plant pond and the Blount Island coal pile runoff pond. The
wastewater from these ponds will be treated prior to discharge. The
sediment ponds to control runoff from the solid waste disposal areas
will not be lined.
W-86: Refer to the response to comment W-34.
W-87: The site selection studies did show that transmission costs were higher
at the Eastport site due to its location. The availability of two
types of coal delivery (rail or barge) made the Eastport site more
attractive, however, and outweighed the higher transmission cost in the
judgement of JEA. Also, the Clay County Coalition was clearly opposed
to the Clay County site and indicated that a lawsuit would result if
JEA decided to build the SJRPP in that County.
The proposed SJRPP is, in fact, consistent with the present industrial
land uses of the area and the IH zoning. The Jacksonville Planning
Department, acting as staff to the Jacksonville Area Planning Board,
determined the proposed project to be consistent with the policies and
land uses of the Land Use Element of the 2005 Comprehensive Plan. The
staff ruled that the proposed power plant facility meets the criteria
for water-related industrial uses which is the anticipated use for most
of this site according to the Land Use Plan Map. The use is also in
compliance with zoning regulations pursuant to Ordinance 80-1290-700,
adopted by the City Council on 24 February 1981, which rezoned the land
for the power plant to GU (Government Use) at such time as the Jackson-
ville Electric Authority acquires fee simple title to the property.
Potential air quality impacts are addressed in Section 4.2 of the Draft
SAR/EIS.
The impacts of the construction and operation of the Blount Island coal
unloading facility are expected to be minimal with the exception of
trace element loading to the River from the coal pile percolation pond.
Sections 3.2 and 3.5 of the Draft SAR/EIS discuss the impacts of these
loadings on the River.
W-88: Brackish water cooling systems are used at power generating stations in
Florida and along other coastal areas of the U.S. The impacts of
emissions from the cooling towers are addressed in pages 0-59 to 0-61
of the Technical Reference Document. The controlled particulate emis-
sions from the cooling towers are predicted to be 8.4 grams per second.
Refer to the response to comment W-108 for a summary of potential salt
deposition impacts. In addition, USEPA is conditioning the proposed
NPDES Permit to require that JEA conduct an 18-month salt drift study
87
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(Appendix 6.1) which will include calculation of drift rates, ground
level measurements of salt deposition, and estimates of biological
impacts. Should problems with salt drift be encountered, suitable
mitigation measures will be required by USEPA. Such increases could
include use of better drift emission control by JEA.
W-89: Refer to response to comment W-34.
W-90: No response required.
W-91: Refer to responses to comments W-16, W-83, and P-22.
W-92: Refer to responses to comments P-22, W-16, and W-83.
W-93: No response required.
W-94: Air quality modeling performed for the SJRPP used actual meteorological
data for Jacksonville and therefore reflects actual windspeeds and
directions on an hourly basis. Rapid dispersion of pollutants occurs
at high wind speed with highest concentrations occurring during calm
wind conditions.
W-95: Refer to response to public hearing comment P-45.
W-96: Refer to response to comment W-17 concerning granting of wastewater
variances and water quality impacts.
W-97: The groundwater usage figures presented in Section 4.4.2.1 of the Draft
SAR/EIS were intended to present an overview of groundwater use in the
entire region surrounding Jacksonville. They were not intended to
represent the specific area around the SJRPP and were not used in the
modeling of groundwater withdrawal impacts. The inventory of wells in
the vicinity of the SJRPP was compiled to help characterize the local
aquifers in terms of formation, water quality, and yield. The current
(1980) water use of major users in the vicinity of the SJRPP was taken
into account in the assessment of impacts.
W-98: Refer to response to comment W-68.
W-99: Refer to response to comment W-17.
W-100: Refer to response to public hearing comment P-46.
W-101: No response required.
W-102: Comment noted. No response required.
W-103: As noted in the response to comment W-96 above, the well inventory
conducted for this study was designed to obtain hydrologic data in
order to help characterize local aquifers and was not intended to
identify every well existing in the vicinity of the site. It is
recognized that in the vicinity of the SJRPP site, as well as else-
where in the Jacksonville area, small diameter wells completed within
the Floridan Aquifer and used for such purposes as lawn and garden
-------
irrigation are common. Whereas 65 or more private artesian wells have
been reported along Heckscher Drive between wells D-2273 and D-1051,
the USGS topographic map of the vicinity indicates approximately 65
individual homes in the same area. Thus it is conceivable that every
private home in the vicinity of the SJRPP site may have at least one
associated small diameter Floridan Aquifer artesian well. Using this
as a working hypothesis, an estimate of the number of private domestic
wells in the site vicinity can be made.
The maximum area of one foot or more of drawdown produced by the SJRPP
water supply wells is estimated to be a circle of radius of approxi-
mately 14,400 feet or 2.73 miles. From the topographic base map used
to develop the well inventory map (Figure 4.4-2 of the Draft SAR/EIS),
there appear to be about 430 individual homes and 55 inventoried
Floridan Aquifer wells within a 2.73 mile radius of the midpoint of
the proposed Floridan aquifer production well field at the plant site.
Utilizing the number of private homes indicated on the topographic
maps as an estimate of the number of private Floridan Aquifer wells
within the site vicinity, it is possible to estimate the number of
wells which might be affected by a given amount of drawdown induced by
pumpage from the SJRPP production wells. Under conditions of average
long-term production of 3,600 gallons per minute from the two wells at
the plant site, nine wells could potentially be affected by drawdown
of greater than 4 feet (Figure 10). Of those nine wells, five are
associated with the Northside Generating Station, one is at the North
Landfill, one is the Capital Concrete well (D-1255, the nearest well
to the site), and only two (D-402 and D-737) would appear to be asso-
ciated with private homes. An additional six inventoried wells and 60
potential Floridan wells associated with private homes could experi-
ence drawdowns in the range of 2 to 4 feet and 17 inventoried wells
and 120 potential wells associated with private homes could experience
drawdowns between 1 and 2 feet. Under conditions of maximum produc-
tion of 5,400 gallons per minute for a short period of time (assumed
to be no more than 24 hours), nine inventoried wells and seven poten-
tial wells associated with private homes might experience drawdowns of
greater than 6 feet (Figure 11). An additional 41 inventoried wells
and 400 potential wells associated with private homes could experience
drawdowns of greater than 1 foot. (The estimate for the maximum
pumping condition was incorrectly stated in the Draft SAR/EIS and is
corrected here).
For wells with pumping equipment, the effect of this lowered head
would be to slightly reduce the well discharge rates. Consequently,
those wells would have to produce for a slightly longer period of time
than they currently do in order to produce a given volume of water.
For artesian wells, the rate of flow would fall somewhat as a result
of the proposed SJRPP production, but the wells should remain in
production until the regional decline in piezometric levels of the
Floridan Aquifer falls below ground levels. In this event, pumping
equipment would be required.
Refer to the response to comment W-34 concerning solid waste disposal.
89
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••*» •'•'- \-(& Q • .'-. • >••»<*>'
Ci., / 34/....,l .'p.—V, ...... S^',
Y-T-T^L^ >»*
^g^L^L^^^-^
14 .'.'./K^' -^
^^-—
**.."? it^^S^iSftSf^Jfeftjitir^ " -
Figure 10. Cone of depression around SJRPP for two wells discharging
3,600 gpm (average pumping condition) (adapted from JEA/FP&L
1981a and Vergara 1981).
90
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^'33 I f. - I . /*•""' '
4-1 / 'V,-1 .ftfe-
4-i^*'.,...^ /V
^-T-'-.S'..,.. ., /;/
IS "1 foot
•'""" drawdown,
foo'^xPpntour ^ _ .
rawdownN/ " ""' *"""
O W.ttr Quality Dit*. Tibia D-7
-f- Hiitorlc.l Vicer Uveli Plotted, Figur
^;,fb
••:.;--/A
.,,,
."
Figure 11. Cone of depression around SJRPP for three wells discharging
5,400 gpm (maximum expected rate) (adapted from JEA/FP&L 1981a and
Vergara 1981).
91
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W-104: No response required.
W-105- The only significant increase in noise due to SJRPP will result
from steam blowout. However, this will only occur once or twice a
year during scheduled maintenance periods and is not considered to be
a significant impact on area residences.
W-106- Based on the results of the official Section 7 consultation with the
USFWS and the analysis provided in the Draft SAR/EIS, the SJRPP will
not threaten the continued existence of Federally listed rare, threat-
ened, or endangered species.
W-107: Refer to response to comment W-17.
W-108- On page 4-81 of the Draft SAR/EIS, it was stated that there would be
an increase in total salt deposition of 0.9 mg/m2/hr. The rate of 0.9
mg/m2/hr was a typographical error which is corrected here in the
Final EIS. As shown in Appendix 0 of the Technical Reference Document
for the Draft SAR/EIS, the actual increase in deposition was estimated
to be about 0.5 mg/m2/hr (total salts). Given a background rate of
0 42 mg/m2/hr total salts, the actual total increase would therefore
be approximately 0.92 mg/m2/hr, not 1.31 mg/m2/hr as indicated in the
Draft SAR/EIS and comment W-108. Approximately 55% of the total salts
will consist of chlorides. As shown in Appendix 0, the rates of salt
deposition represented worst case seasonal averages at a point 1,000
feet to the west of New Berlin Road. Average case depositions would
be much lower. The assessment of potential effects due to salt deposi-
tion from the two proposed natural draft cooling towers is therefore
highly conservative. Beyond the site boundaries the maximum deposition
rate would typically be less than one-half of the rate used in the
assessment. In addition, the comparison of maximum deposition rates
with reported injury thresholds was based on the assumption that no
rain would occur during the period of deposition which would wash off
any salt accumulation (JEA/FP&L 1981). USEPA has required as a condi-
tion of the NPDES permit that an 18-month drift study be conducted in
order to determine potential biological impacts of salt on the surround-
ing area (Appendix 6.1).
W-109: Refer to the second paragraph of the response to comment W-87.
W-110: Traffic on local roadways in the vicinity of SJRPP will approach
level of service C during the short period of time when both construc-
tion and operation of the facility coincide. Level of service C is
defined as stable traffic flow where most drivers are restricted in
selecting their speed, but where all traffic will clear a signalized
intersection. After the construction phase of SJRPP, the increase in
traffic near SJRPP will be insignificant.
W-lll: Air quality modeling has shown that there is a possibility of a
violation of the FAAQS for sulfur dioxide as a result of the simul-
taneous maximum load operation of the SJRPP, NGS, and Kennedy and
Southside stations under certain meteorological conditions. The FDER
Conditions of Certification (Part I-E) (Appendix 6.2) therefore state
that under maximum load conditions at SJRPP and NGS, the Southside
facility will be shut down. Air quality modeling has shown that this
restriction will prevent any violations of the FAAQS.
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W-112: Refer to response to comment W-17.
W-113: JEA cannot be expected to assure the serviceability
of all existing wells in the area since JEA is not the only user
affecting the level of the Aquifer or the quality of the water.
However, if genuine cases of water use impact develop where JEA is the
cause, JEA should incur the cost.
W-114: Refer to response to comment W-17.
W-115: Refer to response to comment W-107.
W-116 : No response required.
W-117: Refer to the response to comment W-16.
W-118: No response required.
W-119: Refer to response to comment W-16.
W-120: Refer to the response to comment W-34.
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3.3 PUBLIC HEARING COMMENTS AND RESPONSES BY US EPA
This section summarizes the comments made by the speakers at the public
hearing held on 1 December 1981. Because of the length of the public hearing
testimony, the issues raised by each speaker have been summarized. An approp-
riate US EPA response follows each comment made at the hearing. Comments are
listed sequentially (P-l through P-49) according to the order in which the
speakers gave their testimony. Table 4 provides a cross reference for major
issue categories commented on at the hearing.
P-l. Grace Hardy:
The burning of fossil fuels causes an accumulation of carbon dioxide in
the atmosphere. Each ton of coal produces three tons of carbon dioxide
which, in generating the same amount of energy, is 20% more than that
produced by oil and 70% more than natural gas. The rise in global tem-
perature produced by carbon dioxide could bring about climatic changes
which are of agricultural and economic concern.
Response:
The primary concern regarding the addition of large amounts of carbon
dioxide to the atmosphere from the combustion of fossil fuels is the
possibility of modifying world climatic patterns. Changes in atmos-
pheric carbon dioxide levels have been postulated to induce climatic
changes by modifying regional and global heat budgets.
The basic problem in determining the potential for climate modification
due to the combustion of fossil fuels and the consequent releases of
carbon dioxide is the number of considerable uncertainties regarding
both the carbon cycle and climate and their interdependence. In addi-
tion, the potential effect of carbon dioxide on climate is complicated
by the addition of other industrial gases and particulates to the
atmosphere which may reinforce or counteract the carbon dioxide effects.
Unfortunately, these uncertainties can only be resolved by the compre-
hensive, coordinated efforts of many scientific disciplines. Because
such an effort has not yet been undertaken, it is not possible to iden-
tify the potential effects of an individual activity or industry on
future climatic patterns.
The possible effects on world climate due to the combustion of fossil
fuels is a policy issue that should be addressed on a national or
global level rather than a local level because of both the complexity
and the magnitude of the issue. Therefore, we do not attempt to make a
definitive analysis of this issue at the present time.
P-2. Margeret Snyder:
The construction of the SJRPP will destroy the aesthetic appeal of
wetlands in the study area.
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Table 4. Cross reference for issues categories
and public hearing comments.
Air Quality
P-l
P-13
P-14
P-15
P-16
P-20
P-23
P-33
P-36
P-39
P-45
Terrestrial Ecology
P-18
Wetlands Impacts
P-2
P-6
P-8
P-31
Alternatives to SJRPP - $
P-22
P-30
P-35
P-40
P-41
P-42
P-43
P-44
Groundwater Impact
P-7
P-10
P-12
P-l 9
P-21
P-25
P-37
P-38
Surface Water Quality
P-3
P-ll
P-17
P-24
P-26
P-27
P-28
P-29
P-3 2
P-34
P-48
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Respo nse:
A 200 foot wide buffer strip will be maintained between all site facil-
ities and adjoining wetlands. This will minimize aesthetic impacts by
providing a visual shield between adjoining areas and habitat disturbed
on the main site.
P-3. Robert Creech:
Degradation of water quality in the St. Johns River could result from
the operation of the JEA facility and might impact populations of fish
and shellfish.
Response:
Refer to comment W-17.
P-4. Ms. Jerry Leigh:
The Eastport site is the most environmentally sensitive of all the sites
considered. Based on the amount of pollution control equipment required
for the site, its selection should be reconsidered. It is uncertain
that the marshes in the vicinity can tolerate .any pollution. The equip-
ment which will be used to control air emissions and discharges to the
St. Johns River cannot be trusted to function properly at all times.
Response:
The amount of pollution control equipment required at the Eastport site
would not be expected to differ greatly from other potential sites in
the JEA service area and would therefore not provide a basis for site
selection. Several other factors in addition to environmental concerns
also led to the selection of the Eastport site. These were fully addressed
in Appendix W of the Technical Reference Document of the Draft SAR/EIS.
Primary among these factors are: (1) the rejection of the preferred
Clay County site by a Clay County citizens group; (2) excellent barge
and rail access at Eastport; (3) the fact that the Eastport site was
already suitably zoned; and (4) use of the NGS discharge as cooling
water for the SJRPP virtually eliminated entrainment problems.
The most important potential source of pollution to adjoining marshes
would include leachate from solid waste disposal areas. However, pos-
sible contamination of adjoining marshlands by solid waste leachates
will be minimized by implementation of a five-year test program which
has been approved by USEPA. Refer to the response to written comment
W-34 for a description of this plan.
P-5. Ms. Jerry Leigh;
The public was not given full representation in the site selection
process. Public opposition existed to the Eastport site selection, but
was not aired due to assurances from elected officials that Eastport
would not be chosen.
96
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Respo ase:
The public was provided with numerous opportunities to contribute to the
site selection process and various individuals and groups (for example,
the Clay County Coalition) did actively participate. A detailed summary
of the events leading to the selection of the Eastport site was provided
in Appendix W of the Technical Reference Document of the Draft SAR/EIS.
One of the important factors leading to the selection of the Eastport
site was the effective opposition to building the plant in Clay County
that was voiced by the Clay County Coalition. Numerous other examples
of citizen input are given in Appendix W of the Technical Reference
Document.
P-6. Ms. Jerry Leigh:
The St. Johns River marshes are endangered and should be protected.
Response:
The construction of the SJRPP will not have direct adverse impacts on
area salt marshes. The salt marsh lost in the construction of SJRPP and
the associated coal unloading facility was originally estimated conserva-
tively at less than one acre. This area is located at the Blount Island
facility and is not continuous with any large marsh system. Furthermore,
JEA has recently decided that since most of this area is beneath the
transmission line ROW, it would not be necessary to disturb it. On the
main site,- a 200 foot wide buffer will be maintained between adjoining
salt marshes (and remaining seasonally flooded wetlands) and the power
plant facilities. In addition, approximately 65 acres of hardwood swamp
within the main site boundary will be fenced off and permanently pre-
served.
Operation of the SJRPP could potentially affect area salt marshes. The
most important potential source of pollution which could affect adjoin-
ing salt marshes would include leachate from the solid waste disposal
areas. These impacts will be minimized, however, by institution of a
USEPA-approved five-year waste disposal plan. Refer to the response to
comment W-34 for a description of this plan.
P-7. Donald Moore:
Does the statement on page M-50 of the Technical Reference Document
which reads "for those users currently utilizing artesian wells, the
flow could be substantially reduced, possibly necessitating the use of
pumps to deliver the same quantity of water" take into consideration
future water usage requirements by Offshore Power Systems and St. Regis?
Response:
The assessment of impacts on existing wells in the vicinity of SJRPP
took into account the water usage of all facilities in existence at the
time that the analysis was conducted. Future withdrawals were not
factored into the analysis of SJRPP. Such withdrawals would contribute
to a long-standing pattern in the area in which the level of the Floridan
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Aquifer has been falling at a rate of 0.5 ft/year since the 19-40's. It
is probable, given this pattern, that artesian wells in the area will
continue to decline in productivity in the future with or without SJRPP.
Refer to the responses to written comments W-33, W-42, W-66, W-68, and
W-69 for further details concerning water withdrawal issues.
P-8. Jeane Creech:
The St. Johns River, Nassau Valley marshes are some of the State's most
important commercial and recreational fisheries and should be preserved.
Response:
Refer to responses to comments P-4 and P-6.
P-9. Jeane Creech:
What effect on property values will result from coal trains travelling
back and forth to Blount Island?
Response:
Since publication of the Draft SAR/EIS, JEA has decided not to use coal
trains to carry coal from Blount Island to the plant. Instead, an
enclosed coal conveyer belt will be used. Since the design and specific
location of the conveyor belt has not been determined as of the publica-
tion of this Final EIS, this comment cannot be responded to adequately
at this time.
P-10. Jeane Creech:
What will happen to the water pressure of surrounding homes as the
power plant draws down on the wells?
Response:
Refer to the response to comment W-103.
P-ll. Walter Armstrong, Jr.
The mercury danger to the fish in the St. Johns River is unacceptable.
Response:
Refer to the response to comment W-17.
P-12. Walter Armstrong, Jr.:
The drinking water supply of the surrounding area is endangered by the
JEA project.
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Response:
All of the drinking water in the vicinity of the SJRPP is supplied from
wells. Most of these wells are located in the Floridan Aquifer. As
indicated in Section 4.4.2.1, page 4-54 of the Draft SAR/EIS, the
operation of the SJRPP would have a potential but unquantifiable impact
on the water quality of the Floridan Aquifer. The SJRPP withdrawal
would contribute to the gradual regional increase in chloride intrusion
which has been associated with increasing regional withdrawals. However,
the chloride intrusion problem has been occurring for some time as a
result of generally greater groundwater use throughout northeast Florida
and the extent to which the SJRPP would affect it is uncertain.
There was also initial concern that contaminated leachate from solid
waste disposal areas might possibly affect the quality of the water
table and shallow rock aquifers. However, steps have been taken to
assure that groundwater resources are protected from possible leachate
contamination by requiring that JEA institute a five-year solid waste
disposal plan. As specified in the plan, all solid wastes not marketed
as gypsum must be disposed of in the area previously designated as the
bottom ash pond. This area is located above the 20-foot elevation on
the site and is well above the groundwater table. The careful design
of the landfill will ensure that groundwater criteria are not violated.
A monitoring program will be instituted to keep a constant check on the
quality of groundwater in the vicinity of the disposal area. Refer to
the response to written comment W-34 concerning details of the plan and
means by which groundwater quality will be protected.
P-13. Walter Armstrong, Jr.;
Duval County is the nation's leading producer of lung cancer and the
addition of a coal-fired plant will only add to the already existing
problem.
Response:
The potential health impacts of the SJRPP were addressed in the Draft
SAR/EIS. The conclusion of this analysis was that the proposed emis-
sion controls would be adequate to mitigate any adverse impacts on
human health. The emissions will meet all State and Federal air qual-
ity standards.
P-14. Walter Armstrong, Jr.:
Electrostatic precipitators and flue gas controls are unreliable and
JEA's proposed facility has no fail-safe capacity.
Response:
The design control efficiency and reliability of electrostatic pre-
cipitators and flue gas controls have been reviewed and approved by
US EPA. Also, because the systems have 100% backup, the probability of
a system-wide failure of pollution control devices is extremely minute.
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P-15. Joseph Wilson:
The Draft SAR/EIS fails to address the issue of carbon dioxide.
Response:
Refer to response to comment P-l.
P-16. Joseph Wilson:
The Draft SAR/EIS does not adequately cover the issue of acid rain.
Response;
In recent years the increase in rainfall acidity levels across Florida
and other parts of the country has been ascribed in part to the air
emissions from coal-fired power plants. This has led to the require-
ment for emission controls on these plants designed to reduce the
potential acid causing factors. Generally, sulfur dioxide and oxides
of nitrogen are believed to be the primary agents contributing to
rainfall acidification. However, a great deal remains unknown about
the amount that these two gases contribute to the problem as well as
how and where the acidification takes place.
Rainfall under unpolluted conditions tends to be somewhat acidic with a
pH on the order of 5.6-5.7. This is due to the absorption of carbon
dioxide in water in the atmosphere. Also, neither sulfur dioxide nor
nitrogen dioxide by themselves are acidic. However, after about 3 to 4
days, these gases typically interact with sunlight, water vapor, ammonia,
and other chemical compounds in the atmosphere and are converted to
sulfuric and nitric acid. Scientists are studying the rate of these
reactions, ways to prevent the end acidic product from affecting the
environment, where the end product eventually produces its impacts, and
numerous other questions relating to the conversion reactions. It is
universally agreed that the entire cause and effect relationship is
very complex.
Most of the acidity is derived from sulfur dioxide sources in the
northeastern United States. Conversion from sulfur dioxide into sul-
furic acid may begin to affect the environment more than 50 km from the
source and the acid is susceptible to long-range transport. Florida is
subject to frequent cold fronts moving into the State in the winter
months which are suspected of bringing in northern-based pollutants
(JEA/FP&L 1981).
Florida itself has relatively few coal-fired industries at this time,
but combustion of oil and gas as well as emissions from heavy indus-
tries such as pulp mills and the phosphate industry make significant
contributions to S02 and NOx loadings. Florida tends to be the re-
cipient of acid rain forming pollutants due to long range transport
from out of state sources. As more coal-fired industry is utilized,
this balance may begin to shift. The SJRPP would contribute slightly
to the problem, but effects would be expected to occur approximately
100 km away from the plant. Some studies have indicated that the
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majority of acidic fallout impacts may occur 200 to 300 kilometers from
the source. The degree of actual impact at a particular point source
is extremely difficult to quantify, however.
Stringent sulfur emission controls will be required prior to operation
of 3JRPP Units 1 and 2, thereby reducing the impact of this pollutant.
These units will thus have less impact than that of other existing
units in Florida which do not employ such emission controls. The SJRPP
Units 1 and 2 will utilize flue gas desulfurization scrubbers to limit
sulfur emissions. Oxides of nitrogen will be controlled by boiler
design. Such control will help mitigate potential acid rain problems.
Construction of new coal-fired units may possibly even have a slightly
positive effect on the acid rain problem in Florida. Results of the
Florida Sulfur Oxides Study (In JEA/FP&L 1981) indicated that the
conversion of sulfur dioxide to sulfuric acid forms two to three times
faster in the exhaust plume from an oil-fired power plant than from a
coal-fired power plant. Oil-fired power plants in Florida do not have
emission controls for sulfur oxides or nitrogen oxides in most instances,
As new coal-fired power plants are built with pollution control devices,
and as these new coal plants replace the oil plants that emit greater
quantities of SOx and NOx, then that portion of air pollution produced
by these sources (which contribute to acid rain) may decrease.
Acid rain may have potential adverse impacts on aquatic life, but these
are very difficult to attribute to a single emission source. The pH
levels in Florida lakes, primarily those in the northern part of the
State, have been dropping (e.g. , becoming more acidic) over the past
two decades. Many of Florida's perched sand lakes have little or no
buffering capacity and are therefore more susceptible to acid rain. As
noted by the Florida Game and Fresh Water Fish Commission (GFWFC) in
Appendix H of the Technical Reference Document, such areas exist 30
miles to the west of the proposed plant. The extreme western portion
of Nassau County, most of Baker and Columbia Counties, the western half
of Clay County, the eastern half of Bradford County, and parts of
Georgia are characterized by surface waters of pH 4.0-5.0.
The proposed plant has some potential for further reducing the pH of
the surface waters in these areas which could have an adverse impact on
aquatic organisms. The assessment by the Florida GFWFC is a subjective
estimate based on the amounts of sulfur and nitrogen oxides to be
produced, the prevailing wind direction, and the proximity of the areas
of concern (Appendix H). However, it is extremely difficult to attri-
bute acid rain impacts to any particular point source (JEA/FP&L 1981).
Therefore, these assertions cannot be supported scientifically at this
time.
P-17. Joseph Wilson:
The Draft SAR/EIS fails to adequately address the issue of the effects
on manatees in the St. Johns River.
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Response:
To determine the potential occurrence of manatees in the vicinity of
the SJRPP and NGS, a manatee watch was instituted as described in
Section 6.2.4.2, page 6.2-24 of the SCA/EID (JEA/FP&L 1981). One hour
observations were'made at NGS, Alton Box Company, Kennedy Generating
Station, and Southside Generating Station from February through April
1980. Watches were conducted weekly at each location. Field notes
taken at each observation included physical water measurements, time of
day, location, number of manatees, and their size.
Results of the watch (Section 2.8.7 of the SCA/EID) showed that mana-
tees did not use the NGS discharge as a warm water refuge during the
colder months of the year. However, a manatee was sighted in the
Blount Island Channel during the summer.
The US Fish and Wildlife Service, Jacksonville Area Office, has com-
pleted an official Section 7 consultation (Refer to response to comment
W-24 and Appendix 6.3) to determine the potential impacts of the opera-
tion and construction phases (including dredging effects) on manatees.
The USFWS determined that if JEA employed suitable mitigative measures
(Refer to response to written comments W-28 and W-54), the continued
existence of the manatee would not be threatened by the dredging opera-
tions. The US Army Corps of Engineers has agreed to condition the
Section 10/404 permit to incorporate certain of these measures (Refer
to response to written comment W-54). Therefore, no adverse impacts on
manatees due to the proposed project are projected.
P-18. Joseph Wilson;
The Draft SAR/EIS fails to provide adequate mitigation for habitat dis-
turbance of endangered species. Specifically this includes bald eagles,
osprey, peregrine falcons, brown pelicans, and wood storks.
Response:
No mitigation plan would actually be needed to protect these species.
The following paragraphs summarize the potential impacts on each of
these animals and demonstrate why such plans are not necessary.
The nearest bald eagle nest is located near Craig Field, seven miles
south of the site. Eagle nesting habitat potentially occurs on the
eastern edge of the SJRPP site. The surrounding area is relatively
industrialized, however, which greatly reduces the possibility of
eagles actually nesting in this area. It is therefore unlikely that
eagles would be affected by the proposed project. This nest is located
about 4,000 feet from the proposed transmission line.
Osprey use the River for feeding and currently nest in three locations
on tranmission line towers near the site. Consequently, they may even
benefit from the additional tower nesting habitat. No osprey nesting
habitat will be disturbed by the project.
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Peregrine falcons are migratory and do not nest in the area. Their two
local sources of food might be waterfowl (on the River or in area salt
marshes) and birds feeding at the sanitary landfill. Plant construc-
tion and operation will not affect these resources.
Eastern brown pelicans feed in the discharge area of the NGS and on the
River. Because the SJRPP will utilize the NGS discharge, no new major
intake or discharge structures are planned for the River. For this
reason, their feeding resources should not be measurably affected. No
nesting colonies could be affected because the nearest colonies to the
south are at Daytona Beach and to the north near Charleston, SC.
The nearest nesting colony of wood storks is at the Dee Dot Ranch about
25 miles south-southeast of the site in southern Duval County. This
distance is far in excess of the distance wood storks would travel for
food resources to support a colony. No mitigation plan therefore is
needed.
P-19. Joseph Wilson;
The impact on colonial nesters from leachate in the Browns Creek estu-
ary needs to be addressed if adequate liners are not used in the construc-
tion of the power plant.
Response:
Impacts due to solid waste leachates will be carefully monitored during
the five-year test program. Refer to the response to comment W-34
concerning leachates from the solid waste disposal area and the long-
term solid waste plan.
P-20. Joseph Wilson:
If plant specifications do not include the USEPA suggested limit of
salt drift, this issue needs to be addressed in more detail.
Response;
Discussions of the expected effects of salt drift deposition were in-
cluded in the SCA/EID (JEA/FP&L 1981) and Appendices K and 0 of the
Draft SAR/EIS. Refer to the response to written comment W-108 for a
discussion of potential salt drift impacts. Appendix 0 of the Technical
Reference Document also includes a detailed analysis of salt drift
impacts. As a result of the concern over possible salt drift effects,
USEPA is requiring as a condition of the proposed NPDES Permit
(Appendix 6.2) that JEA conduct a salt drift monitoring study. This
study will require drift rate estimates, ground level measurements of
salt deposition, and estimates of biological impacts. Should a problem
occur, suitable mitigative measures will be employed. Such measures
could include the employment of better drift controls by JEA.
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P-21. Joseph Wilson:
The disposal of low volume hazardous wastes needs to be determined and
mitigation addressed in the Final SIS.
Response:
Low volume wastes include settled solids from the various sedimentation
ponds, the metal cleaning retention basin, and the cooling tower basin;
separated oil and grease from the oil-water separators; and sludges
from the sanitary waste treatment facility and the central wastewater
treatment facility. Some of these solids, such as oily waste removed
from the oil-water separators and sludge produced during sanitary waste
treatment, will be collected for off-site disposal. Some oily wastes
may be suitable for incineration in the boilers. None will be disposed
of in the on-site solid waste disposal area.
Only one of the low volume solid wastes, the settled solids from the
metal cleaning waste retention basin, has a potential for being defined
as hazardous. If a determination is made that these wastes meet the
criteria of hazardous or fall under the auspices of the Resource Conserva-
tion and Recovery Act (RCRA), then they will be disposed of off-site at
a RCRA permitted disposal facility. No hazardous or potentially hazard-
ous wastes are to be permanently stored or disposed of on-site.
P-22. Joseph Wilson:
Why was Alternative 1 not chosen as the preferred alternative? This
alternative would be viable for JEA and would provide 228 MW of addi-
tional power.
Response:
Alternative 1 consisted of four separate actions which must be achieved
to realize the same oil displacement as SJRPP. These actions included:
• Residential solar conversion
• Refuse firing
• Coal-oil mixtures
• Purchase of power (Vogtle Nuclear Plant)
While USEPA did not make a detailed evaluation of the feasibility of
each component, it did present information showing the relative impact
of each. Table 5, page 32 of Appendix BB of the Draft SAR/EIS illus-
trated the effect on the total costs ($/bbl saved) of the components of
Alternative 1. When compared to the proposed action, refuse-fired
generation was shown to be 22% more costly; solar domestic hot water
133% more costly; coal-oil mixture 0.01% less costly; and purchase of
power from the Vogtle Nuclear Plant 15% less costly.
This comparison illustrated dramatically that the assumptions concern-
ing the costs of purchase of power from the Vogtle Nuclear Plant caused
the apparent comparability of this alternative to the SJRPP project.
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USEPA recognized the uncertainty surrounding any alternative which
consisted of a large interest in a nuclear power plant. As stated on
page 18 of Appendix B3, Georgia Power recently announced a 22-month
delay in the scheduling of the Vogtle Nuclear Plant and a resulting
$1.259 billion cost increase. Since it will be seven years before both
units at the Vogtle Nuclear Plant will be completed, USEPA performed an
analysis considering a 50% increase in the cost of the plant for Alter-
native 2. As stated on page 29 of Appendix BB, if the Vogtle Nuclear
Plant were to overrun its current estimated cost by 50%, Alternative 2,
which relies heavily on Vogtle, would be significantly more expensive
than the SJRPP.
Since the Vogtle Nuclear Plant comprised approximately 58% of Alter-
native 1, if a similar analysis was performed on Alternative 1, the
results would also make it significantly more expensive than SJRPP.
Finally, as stated on page 3 of Appendix BB:
"It is also important to realize that this is not intended as a
utility planning analysis. It is intended to show whether the four
alternatives can meet the same economic goal as SJRPP—low-cost
displacement of oil. The analysis does not. attempt to weigh the
other economic and non-economic factors which the utility management
considers in selecting and implementing a long-range generation
plan."
This qualification is necessary because JEA has demonstrated a capacity
need for 550 MW in the early 1990's. Alternative 1 only provided an
increase of 228.4 MW, far short of JEA's need. The costs of providing
the additional capacity were not included in the USEPA analysis.
In addition, of the four actions identified in Alternative 1, only one,
coal-oil mixture, appeared to offer a $/bbl saved comparable to SJRPP.
Conversion studies are already being performed by JEA to determine if
conversion is technically and economically feasible for oil displace-
ment beyond that provided by SJRPP. Also, conversion of existing units
to either coal or coal-oil mixtures would reduce the capability of
JEA's system and accelerate its capacity requirements.
P-23. Joseph Wilson;
Precipitators for particulate emission control should be required in
order to achieve USEPA's suggested emission levels.
Response;
Electrostatic precipitators will be used to control particulate emis-
sions from the SJRPP. The design and control efficiency of these units
have been reviewed and approved by USEPA.
P-24. Joseph Wilson;
It is recommended that the cooling system chlorine level be limited to
2 milligrams per liter for one hour per day with an ultimate residual
of no more than 0.1 milligram per liter in the discharge.
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Response:
Refer to response to written onment W-148.
P-25. Joseph Wilson:
It is recommended that bottom ash and fly ash be dry handled rather
than wet handled and that these materials be stored in impermeable
lined cells or lined with material of no less than 1 x 10 cm/sec
permeability.
Response;
Although the bottom ash is collected in a wet condition, it is de-
watered prior to disposal. Therefore, these wastes are disposed of in
an essentially dry state. Fly ash, with the exception of minor wetting
to avoid fugitive dust emissions during transportals proposed to be
handled in a dry state. A permeability of 1 x 10 cm/sec is an estab-
lished solid waste landfill criterion. USEPA has imposed this require-
ment on other new source power generating projects when the applicant
does not wish to undertake a leachate testing program to aid in determin-
ing suitable permeabilities of liners or waste piles.
P-26. Joseph Wilson;
If a water quality variance is issued, it should not allow any dis-
charge into the River which periodically exceeds the current standards.
Response:
Refer to the response to comment W-17.
p-27. Joseph Wilson;
Discharge limits should be set well below toxicity levels of resident
organisms to assure that no effluents exceed toxicity limits.
Response;
Refer to the response to comment W-17.
P-28. Joseph Wilson;
If the water quality variances are issued, they should be issued only
after a complete baseline survey is conducted of benthic organisms and
fish in the St. Johns River, in Browns Creek estuary, and at the mouth
of all downstream rivers where there may be backup flushing from the
tidal effects of the River. This program should also include bioassay
testing.
Response;
Refer to the response to comment W-17. Both the USEPA and FDER are
requiring that the JEA conduct a bioassay program on the main SJRPP/NGS
discharge (Appendices 6.1 and 6.2).
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P-29. Joseph Wilson
The proposed variance for aluminum is of concern due to its potential
for reducing fertility in organisms.
Response:
Aluminum requires acidic conditions to maintain a solubility above
2.0 mg/1. Under estuarine conditions where ocean waters are mixed with
fresh water, the system is well buffered and consequently the solubility
of aluminum is low. As shown in the Draft SAR/EIS, species indigenous
to the St. Johns River estuary have threshold toxicity levels well
above 2.0 mg/1 (Also see USEPA reply to W-17).
P-30. Joseph Wilson;
Re-evaluation of Alternative 1 should be considered for one of the 600
MW plants and a possible relocation of the second plant to a less
environmentally sensitive area due to the possibility of low volume
hazardous wastes being stored on-site.
Response;
Refer to the response to public hearing comment P-21 concerning low
volume wastes.
P-31. Joseph Wilson:
The US Fish and Wildlife Service publication, A Biologist's Manual
for the Evaluation of Impacts of Coal-Fired Power Plants on Fish,
Wildlife, and Their Habitats, states that the siting of a power plant
close to wetlands may have adverse impacts on the quality of life, the
diversity of species, and conditions essential to the survival of the
wetland ecosystem such as water level and water quality.
Response:
Potential impacts of physical elimination, changes in water quality,
and changes in hydrologic regime on wetlands were discussed in
Section 4.7 and Appendix 0 of the Draft SAR/EIS. Potential physical
impacts on salt marsh communities of Brown and Clapboard Creeks due to
site construction activities will be mitigated by provision of a 200
foot wide buffer strip of natural vegetation along the edge of the
construction areas.
No impacts on adjacent wetlands due to groundwater withdrawal are
projected since near surface aquifers will not be utilized by the
SJRPP. Instead, the deeper Floridan Aquifer will be the source of
groundwater for the SJRPP. Since the Floridan Aquifer is separated
from the surficial aquifer system by the Hawthorne Formation which acts
as an aquiclude, levels of groundwater in the shallow rock and surfi-
cial aquifer systems will not be altered.
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The most important potential sources of groundwater contamination which
could affect adjacent wetlands are the solid waste disposal areas.
However, the five-year test program will not allow use of solid waste
disposal areas A or B which are immediately adjacent to Brown and
Clapboard Creek marshes until the specific limitations and mitigation
requirements for each site have been determined (Refer to response to
written comment W-34). Instead, the area previously designated as the
bottom ash disposal area will be used for all solid wastes produced
during the first five years of the plant's life. This area is located
at or above the 20 foot elevation and would pose a much lower risk of
contamination of local marshes than areas A or B. The disposal cell
design will minimize tht. potential for contamination and a rigorous
monitoring program will be instituted to assure that groundwater criteria
are met. This program will minimize the potential for impacts on
marshes to occur in the vicinity of the site.
Impacts on seasonally flooded wetlands located on the site will still
result. These impacts were described in Section 4.7 of the Draft
SAR/EIS.
P-32. Joseph Wilson;
Rail shipment is the preferable alternative to barge shipment to avoid
disturbance to the Blount Island site from dredging and sedimentation.
Response;
Effects of dredging at the Blount Island site will be largely short-
term in nature (Section 4.2 of the Draft SAR/EIS). Furthermore, the US
Army Corps of Engineers has required that any potential impacts of
dredging be minimized by incorporating several required mitigative
measures into the Section 10/404 permit (Refer to response to written
comment W-54). Impacts of sedimentation during site construction will
be minimized by adherence by the JEA to a State-approved erosion and
sedimentation control plan.
P-33. Joseph Wilson:
FDER's recommendation for non-violation of State S02 standards should
be required for Southside Generating Station Units 1 and 2 and also
Kennedy Generating Station.
Response:
It is agreed between JEA and FDER that during maximum load operation of
the NGS and SJRPP, the Southside Units 1 and 2 will be shut down (Appendix
6.2). Air modeling has shown this action to meet the Florida standards
for 24-hour S02 levels.
P-34. Joseph Wilson;
Dredging should be for a finite time period not to exceed two years and
should be subject to modification depending on water quality changes in
the River.
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Res po ns e:
The actual period of dredging itself will amount only to approximately
two months. The two-year variance was requested only to allow for
adequate scheduling and coordination of plant construction and dredging
activities. The US Army Corps of Engineers Section 10/404 permit will
also be conditioned to mitigate potential dredging-related impacts on
Federally listed species (Refer to responses to comment W-54).
P-35. Barney Capehart:
The Draft SAR/EIS for the SJRPP does not disclose full environmental
issues by not examining a true energy conservation alternative.
Response;
Refer to the response to comment W-16 concerning selection of alterna-
tives and conservation.
P-36. Curtis Moore:
The issue of the effects of trace element emissions from coal-fired
plants is not fully addressed in the Draft SAR/EIS. Specifically, it
does not relate the effects of trace elements on the neighboring dairy
farm and the milk produced for human consumption on this farm.
Response;
During the preparation of the Draft SAR/EIS, an extensive effort was
made by USEPA to locate publications dealing with this subject, but
none were found. To the best of US EPA's knowledge no such studies have
been published. In addition, members of the Electrical Power Research
Institute (EPRI) and several utilities were contacted in an effort to
determine the status of knowledge concerning the potential effects of
power plant trace element emissions on dairy farms and dairy cows.
Again, however, no information was obtained concerning this subject and
none of these sources knew of any such studies. While USEPA recognizes
that this is of concern, it is not possible to add to the analysis
presented in the Draft SAR/EIS at the present time due to the paucity
of information concerning this subject (Refer to Appendix 0 of the
Technical Reference Document for a more detailed discussion than that
presented in the Draft SAR/EIS).
P-37. Curtis Moore:
The operation of the SJRPP will reduce the flow of artesian wells cur-
rently in use in the immediate area, necessitating the use of pumps to
deliver the needed amount of water. The neighboring cattle farm depends
upon five artesian wells and seven rock wells to maintain its herd.
There is concern over the possibility of having to pump the necessary
water.
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Response:
The dairy farm in question is located on New Berlin Road northwest of
the SJRPP. Two of the wells on the farm were inventoried by JEA during
preparation of the SCA/EID and are indicated as D-999 and D-1000 in
Figures 4.4-1 and 4.4-2 of the Draft SAR/EIS. As shown in these figures,
the drawdown of the Floridan Aquifer at the farm should be on the order
of 1 foot during normal operation of the SJRPP and may reach approx-
imately 2 feet for short periods during maximum pumping at the plant.
The loss of 1 to 2 feet of hydraulic head at this site should leave the
artesian wells flowing with a remaining head on the order of 13 to 18
feet. There will be a slight decrease in the yield of these wells and
pumping may be required in order to sustain yields at their present
rate. The proposed withdrawals from the Floridan Aquifer are not ex-
pected to affect yields from wells at the farm which are completed in
the shallow rock aquifer.
P-38. Curtis Moore:
Lining of the sludge ponds is needed to protect the quality of the
water supply of the adjacent cattle farm.
Response:
It is assumed that this statement is referring to any ponds used for
settling solid materials from wastewaters. Several ponds will be used
for this purpose. Of these, the coal pile sedimentation pond, the
metal cleaning waste retention basin, and the flow equalization basin
will be lined with polyethylene or equivalent material. All other
wastewater containing ponds will be unlined, but do not pose a threat
to groundwater resources.
P-39. Curtis Moore:
What effects will dust emissions of the coal unloading facility have on
the thousands of new automobiles parked on Blount Island?
Response;
No adverse effects due to coal dust emissions are projected because:
(1) the average storage time of cars on Blount Island will be only five
days; (2) most of the cars are coated with a layer of cosmoline to
protect their paint; and (3) air quality modeling indicated that only
0.11 grams of coal dust would be deposited on any given car in the
vicinity over an eight-day period (JEA/FP&L 1981).
P-40. Jack Russo:
The projected construction costs for the two JEA units have been gross-
ly underestimated. What will the end result be when finances are
expended and the two units are still incomplete?
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Response:
Construction cost projections made for the SJRPP by JEA included care-
ful consideration of numerous factors including inflation. Assuming
that no extensive delays in licensing of the SJRPP are encountered,
these estimates should be reasonably accurate.
P-41. Charles Pettet:
International rates for crude oil have recently been reduced, thus
making it more economically feasible to continue operating the old JEA
units.
Response:
The economic feasibility of the SJRPP and consideration of alternatives
was analyzed in detail in Appendices AA and BB of the Technical Refer-
ence Document for the Draft SAR/EIS. Sections 1.0 and 2.0 of the Draft
SAR/EIS summarize this information. This analysis showed that for
three (high, medium, low) oil price levels, the SJRPP was economically
feasible and that it would be economically advantageous to the Jackson-
ville area given any reasonable fluctuation in oil prices. In addition,
many of the old JEA units will have to be replaced within the next 10
to 20 years due to their age, and they could not continue to be operated
indefinitely.
P-42. Chuck Brandvoid:
The proposed JEA facility will accelerate consumer electric costs to
the range of $180 to $200 per thousand kilowatt hours beginning in the
years 1986-1987. Other alternatives are available. Specifically, this
includes the purchase of power from Seminole Electric Coop at approx-
imately one-third the cost of that generated by the proposed JEA facil-
ity.
Response:
USEPA is not in a position to evaluate the rates charged by JEA to its
customers and JEA has not provided any such information. The alterna-
tive of purchasing power from Seminole Electric Cooperative was examined
by the Florida Public Service Commission during the hearings on the
need for the proposed project. Information provided in Table RL-8 of
the testimony of Royce Lyles for the hearings showed that purchase of
power from Seminole did not offer significant cost advantages over
similar power purchase agreements offered by the Southern Companies,
and in neither case did the offer extend a period of time equal to the
service life of the SJRPP. According to JEA, it was found more cost-
effective to purchase power from Southern Companies to satisfy short-
term needs and pursue SJRPP as a long-term solution. This argument was
accepted by the Public Service Commission.
Ill
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P-43. Robin Leigh:
It must be proven that the proposed JEA facility will be of economic
benefit to the citizens and that the cost of electricity (dollars per
thousand kilowatt hours) will be less with the plant than without it.
Response:
Refer to responses to public comment P-42 and written comment W-16.
P-44. Robin Leigh:
Permits for the proposed facility should be deferred until all reason-
able alternatives have been examined and until an alternative is found
which provides equivalent energy capacity for lower environmental
costs.
Response:
Refer to responses to public hearing comment P-42 and written comment
W-16.
P-45. Robin Leigh;
Data from a concurrent project, the Dames Point Bridge, are missing
from the air quality models and should be included to fully assess the
impact of the SJRPP.
Response:
Based on the information provided by the Jacksonville Bio-Environmental
Services Division and by FDER regarding air pollution emission sources,
the Dames Point Bridge Project is not an active project that would
produce emissions.
P-46. Robin Leigh:
The two-fold increase in structure height from the addition of the
massive cooling towers represents a violation of visual aesthetics.
Reponse:
In fact, the area in the vicinity of the proposed site is already
partially industrialized and is assuming an increasingly industrial
appearance. The existing view toward the proposed site is influenced
by the buildings, water tower, and stacks of the NGS; the transmission
towers and lines associated with NGS; the Offshore Power Systems crane
and shipping cranes on Blount Island; and structures of the St. Regis
paper mill. The SJRPP would therefore not constitute a major incursion
into the existing viewshed. In addition, since the area in the vicin-
ity of the site is already zoned for heavy industry, additional changes
in the aesthetic viewshed would occur regardless of whether the SJRPP
were built.
112
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P-47. Robin Leigh:
Residents within two miles of the Northside Generating Station are cur-
rently subject to intermittent loud noises and the addition of two more
boilers will cause a substantial increase in the frequency of these
dis turbances.
Response:
The Northside Generating Station has in fact experienced some unusual
problems which resulted in the steam releases and related noise effects.
However, the SJRPP will only very infrequently (on the order of once or
twice per year) produce similar levels of noise due to steam blowout
during scheduled maintenance.
P-48. Matt Roland:
The elimination of sensitive wetlands on-site and the pollution dis-
charged into the wetlands will damage productive estuarine areas adja-
cent to the site and have a major impact on the seafood and sport
fishing industries.
Response;
Refer to the responses to public hearing comments P-6, P-21, P-24,
P-29, P-31 and P-38 as well as written comment W-17.
P-49. John Kern:
The cumulative impacts of OPS and JEA on Blount Island need to be
addressed in terms of the addition of 12,000 employees, the traffic,
and the fugitive dust produced by the facility.
Response:
These impacts were fully addressed in the Draft SAR/EIS (Sections 4.2
and 4.9).
3.4 JEA'S COMMENTS ON THE DRAFT NPDES PERMIT
This section presents relevant comments which were made by JEA during
the review of the Draft NPDES Permit proposed by USEPA. Each comment has been
assigned an identification number (W-120 through W-149) as was done for the
written comment letters. USEPA's responses to JEA's comments are presented in
Section 3.5 immediately following the letters.
113
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Jacksonville Electric Authority
Mavetber 20, 196:
Kr. Jjmes Patrick, Acting Chief . _- , - ,
Vater Perxlu Branch v
r. S. Environmental Protection Agency
Regioe IT -,'.-.
345 Cocrtland Street, K.E.
Atlanta. Georgia 30303
Dear Mr. Patrick:
Subject: jAdSOSTIIlE ELTCTRIC ALTBOPJTY
sr. JOHSS arm. POWER PARK nais 142
KATIOKAL POUITANT DISCHARGE ELDCCKATIOK STSTD1 PEEKIT
FL0037869
Encloseii please find two copies of our cooncnts to Uw draft KFDL5 pertlt
for the St. Johns River Pover Park, laaued October 29, 1981, for public
notice. The first set of cococrts. Attachment A. vas provided to Mr. Charles
Kaplan and discussed with his in your offices on Koveaber 12. 1961. The
second set of cements. Attachment B. has been prepared in response to the
guidance provided by Kr. Kaplan at that •eetlnR. Attach^mt B also
Iccludts a reediest for «J_nor clarificatiocs of ontfall deccriptioos.
In addition to transmitting these ccna«cati to you, we have included, at
Mr. lUplas's request, a discussion of the devatering activities which v!13
occur during the initial phase of plant construction. This final enclosure.
Attachment C, is an explanation of the techniques ve plan to employ for
devatering certain areas of the plant site and the anticipated effects
these activities Bar have on vater qualltr. In this enclosure please find
our re-v
Koyce Lyles
W./pag
Enclosures
Managing Director
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II. COMMENTS ON DRAFT NPDES PERMIT
General
Issue:
Discharge limitations should be incorporated by reference to
state conditions of certification.
For the ileus listed in the table below, the following
paragraph should be Included as a footnote where indicated.
"The Florida Departnent of Environmental Regulation has
certified the discharge(s) covered by this permit with
conditions (See Attachment _ ). Section 401 of the Act
requires that conditions of certification shall become a
condition of the permit. The effluent limits and monitoring
requirements, If specified In the attached state
certification, shall be as indicated for those parameters
Included In the certification."
Outfall Serial Number (OSN)
002, Page 1-2
(Add above paragraph as
footnote 2 for each Item)
Item
Oil and Grease
Total Residual Chlorine
005, Pages 1-5 and 1-6
(Add above paragraph as
footnote 3 for this item)
006, Pages 1-7 and 1-8
(Delete existing footnotes 4
and 6. Substitute above
paragraph as new footnote 4)
006, Pages 1-9 and 1-10
(Delete existing footnotes 4
and 5. Substitute above
paragraph as new footnote 4)
Cycles of Concentration
Aluminum, Copper, Cyanide,
Iron, Mercury, Nickel
Selenium, Silver and Zinc
Aluminum, Copper, Cyanide
Iron, Mercury, Nickel,
Selenium, Silver and Zinc
13
Resolution: Section 122.62(d) of the consolidated permit rules requires
that requirements more stringent than or in addition to
technology-based limitations be Imposed In NPDES permits when
necessary to achieve compliance with state water quality
standards under Section 303 of the Clean Water Act and state
certification requirements under Section 401 of the Clean
Water Act.
Conditions applicable to permits may be Incorporated by
reference. 40 CFR Parts 122.7, 122.8. State conditions of
certification promulgated under Section 401 of the Clean Water
Act are typically incorporated within the NPDES permit by
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reference. FDER effluent limitations established as part of a
state variance proceeding under the Florida Power Plant Siting
Act should similarly be Included by reference rather than
expressly.
Page 1-1 and III-l.B
Issue: Temperature limitation on Main Plant Discharge to the
Northslde Generating Station Discharge Channel - Dally Maximum
of 33.9*C or 93.0'F.
Resolution: This requirement does not appear to conform to federal or
state requirements. Federal performance standards (40 CFR
423.15 (1)) state that "Heat may be discharged In blovdovm
from reclrculated cooling water systems provided the
temperature at which the blowdown Is discharged does not
exceed at any time the lowest temperature of reclrculated
cooling water prior to the addition of the makeup water." The
blowdown from the cooling towers Is withdrawn from the tower
basins and so must always be at the lowest temperature of the
recirculatlng cooling water. Since this discharge is
physically constrained to satisfy the federal performance
itandards, a numerical temperature limit at this location Is
not necessary. The 93'F limit proposed.was taken from
Information presented In the Site Certification Application.
CN
Cxi
This information was based on a period of record that Is
shorter than the anticipated lifetime of the proposed plant.
It is conceivable that meteorological conditions could occur
which would force the lowest temperature of reclrculated
cooling water to exceed 93°F. A 93°F discharge limit at
such a time would clearly not have any relation at all to the
federal performance standards.
The state of Florida and the I) SEP A under the existing
Northslde Generating Station NPDES permit, have already
established a limit of 104°F (40°C) for waters discharged
into the Northslde Station discharge channel. The proposed
limit of 93°F can serve no purpose in protecting either the
discharge channel or the mixing zone In the Blount Island
Channel from temperatures between 93°F and 104°F. In
fact, the mixing zone Is restricted to 9.5 acres and the
discharge Is limited to 105°F In Part III page III-l, Item
B, of the proposed permit (Other Requirements).
Since there Is no apparent reason for Instituting the 93°F
limitation. It should be removed and replaced with the
requirement that only water at the lowest temperature in the
recirculatlng cooling water system can be discharged,
consistent with the applicable federal regulations.
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The proposed limit of 9.5 acres for the nixing tone (2 degree
r Isotherm) is also Inappropriate. This limit was also taken
from Information presented In the Site Certification
Application. It Is also based on a period of record that Is
shorter than the anticipated plant life. More Importantly, It
does not Include operation of all 3 NGS units at full load.
As discussed In Appendix C.I of the Site Certification
Application (Figures C.19 and C.20). NGS operating alone, at
full load, could produce a nixing rone of approximately 17
acres (2 degrees F Isotherm). Since no Justification has been
presented for reducing the permitted 102.27 acre mixing zone
which NGS currently operates under, the 9.5 acre limit should
be changed to at least 17.0 acres.
The runoff treatment pond shall be capable of containing the
10-year, 24-hour rainfall event (61 acre-feet) plus all
accumulated silt. Not less than once per month, permittee
shall ascertain that available settling volume meets this
requirement and shall report this finding when submitting
Discharge Monitoring Reports.
Resolution: Delete the referenced sentences. The runoff treatment pond
should not be limited by a design volume of 61 acre-feet plus
all accumulated silt. The U.S. EPA's development documents of
March, 1974 and September, 1980, and the effluent guidelines
Page 1-2
Issue:
under 40 CRF Part 423 do not provide guidance regarding
accumulated silt. However, EPA does provide guidance for
sediment control and accumulted allt In their October 1976
technology transfer seminar publication (U.S. EPA. October,
1976. Erosion and Sediment Control: Surface Mining in the
Eastern U.S. - Design. EPA-625/3-76-O06 ) . In this
publication, EPA, In Table 1-15, states that the sedimentation
pond is "to be cleaned when sediment accumulation approaches
60 percent design capacity." Design capacity Is based on the
10-year, 24-hour precipitation. Accordingly, the accumulated
silt for the SJRPP runoff treatment pond should be limited to
60 percent, or about 36.6 acre-feet, of the design volume.
The rules under 40 CFR Part 423, In the current and proposed
language, do not specifically require a "containment"
stipulation. Instead, the language directs the permittee to
have a facility designed, constructed, and operated to treat
the runoff, not contain.
The permittee Is required to meet a discharge limitation for
total suspended solids (TSS) of 50 Bg/1 from the pond In
question. Therefore, It Is the responsibility of permittee to
see that the control technology used to meet the 50 Bg/1 TSS
is functioning. Just as no NPDES restrictions are applicable
to sludge thickness In a primary clarlfier, NPDES restrictions
on the permittee ascertaining accumulated silt volumes are not
appropriate.
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00
Page 1-2
Issue: A need may exist for having effluent from the dewaterlng
activities Included In the NPDES Permit.
Resolution: The description for outfall serial number 002 should read,
"Runoff Sedimentation Control Pond discharge to Browns Creek
(Includes construction and yard drainage, effluent from
dewaterlng activities, effluent from ....).
The attached Figure 1 shows where modifications would be made
to the flows Into the runoff sediment control pond. At this
time, dewaterlng flows are anticipated at about 1,000 gpm.
The largest dewaterlng requirement will be associated with an
excavation In the coal/limestone unloader pit area.
Dewaterlng associated with this excavation could require
production of relatively large quantities of water, about
1,000 gpm, over a period of up to one year. Effluent will
pass through screens and filters prior to being discharged
Into the runoff aedlment control pond. No dewaterlng
activities of significant sire will be concurrent with this
excavation.
Page 1-3
Issue: Monitoring for pH at OSN 003.
FIGURE 1
CONSTRUCTION PHASE DRAINAGE-SCHEMATIC
CN
i—i
CONCRETE TRUCK
WASHING AREA
fc
CONSTRUCTION
SEDIMENTATION
PONDS
r
CONSTRUCTION 27
AREA RUNOFF
— — — —
LOCAL/INTERMEDIATE
SEDIMENTATION PONDS
A
L
(1000)
OEWATERING
ACTIVITIES
(REVISION)
SEDI
CON
k PON
A
'
OFF
FROL
]
k
[M]
19
SANITARY WAST
TREATMENT
303 TO ST.JOHNS RIVER ^
fOOT] VIA BROWNS CREEK "
/NPDES DISCHARGE NUMBERS
-^ FLOW DIRECTION
000 ANNUAL AVERAGE FLOW. GPM
(000) ESTIMATED MAXIMUM FLOW. GPM
E
CM
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Resolution: Measuring pH it OSN 003 Is unnecessary .8 pH will be measured
•t both OSN 002 during construction and at the punp sump
during operation. Outfall 002 Is the appropriate location for
measuring the pH of effluents generated during conatructIon.
as these combine In the construction runoff sediment control
pond prior to discharging Into Brown's Creek. Any excursion
from the 6.0 to 9.0 range it the punp sump will trigger return
of the final treated effluent to the coal pile runoff
sedimentation pond for additional treatment.
Page 1-5
IB sue: Typo for FRO.
Resolution: In the first sentence, which begins, "Until the date noted",
the term FRO should be changed to read FAO.
Page 1-5
Issue:
Restriction on Total Residual Oxldants (TRO) discharge at
proposed plant while discharging at Northslde Generating
Station-
Resolution: The statement "TRO .hall not be discharged during periods when
TRO is being discharged from any unit at Northslde Generating
Station' should be omitted.
CNI
i—(
CM
r i
There Is no reason to Impose the ibove restriction on the
discharge at outfall aerial number (OSN) 005 as long as the
discharge at OSN 001 meets Its TRO llmltstlon at the end of
the Northslde Discharge Channel. Because monitoring at the
end of the channel would pick up chlorine Introduced by either
generating station. It Is unnecessary to restrict plant
operations at both stations by specifying when TRO may be
discharged. Additionally, the NGS may discharge TRO because
It Is present In the Intake water, not because of chlorlnatlon
operations. In these Instances, the proposed plant would not
be allowed to discharge TRO, according to the statement above,
despite the fact that the NGS Is not chlorinating.
Page 1-5
Issue: Limitation of TRO discharge duration.
Resolution: The statement "TRO shall not be discharged for more than two
hours per day" should be omitted.
If the limitation for chlorine discharge proposed In the
October 14, 1980, regulations Is to be Imposed on the
permittee, then the limitation should be Imposed as It appears
In these regulations. There Is no restriction regarding TRO
discharge duration for cooling tower blowdown. Discussions at
CM
r-l
J3
oo
CM
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the federal level Indicate that EPA's Intent regarding this
discharge la properly presented In theae regulations. The
discharge Is not restricted by either Intermittent or
continuous operation, but the TRO concentration discharged
cannot exceed 0.14 ng/1 at any one tine.
OO
CM
,—<
I
Pile Runoff Sedimentation Pond. Since the flows can be
simultaneous, a dally average concentration of 36 mg/1 Is
reasonable. The use of a combined stream limitation is
consistent vlth the permit rationale used by EPA to develop
oil and grease concentrations.
Page 1-7
Issue:
Typos
Resolution: "Dally Ave" should be "Dally Avg"
"Dally Avg" should be "Dally Max"
Page 1-7
Issue: Total Suspended Solids - Discharge Limitations: Dally Average
of 130 kg/day, or 280 Ibs/day, at a concentration of 30 mg/1.
Dally maximum of 210 kg/day, or 470 Ibs/day, at a
O . concentration of 50 mg/1.
Resolution: Total Suspended Solids - Discharge Limitations: Dally average
of 153 kg/day, or 338 Ibs/day, at a concentration of 36 mg/1.
Dally maximum of 928 kg/day, or 2043 Ibe/day, at a
concentration of 100 mg/1.
The average dally TSS limitations should reflect an average
flow rate of 547 gpm with a concentration of 30 mg/1 from the
Flow Equalization Pond plus 235 gpm at 50 mg/1 from the Coal
C\l
i—l
O
CO
The maximum dally TSS limitations should reflect a maximum
flow rate of 1200 gpm with a concentration of 100 mg/1 from
the Flow Equalization Pond plus 1000 gpm at 50 mg/1 from the
Coal Pile Runoff Sedimentation Pond. The concentration
limitation should be at 100 ng/1 since the Flow Equalization
Pond effluent can be the sole source of wastewater being
treated In the Central Wastewater Treatment Facility.
Page 1-7
Issue: Oil and Crease - Discharge Limitation - Dally maximum of 60
kg/day, or 130 Ibs/day.
Resolution: Discharge limitation should be 131 kg/day, or 288 Ibs/day.
Maximum flow rate for the effluent from the Flow Equalization
Basin Is 1200 gpm for one unit operation. Using a
concentration limit of 20 ng/1 the resultant requirement Is
about 131 kg/day, or 288 Ibe/day. The permit rationale
assumes average flow with a maximum concentration instead of
the possible maximum flow and aiaximum concentration.
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Pages 1-8 and 1-10
lasue: Frequency of monitoring required after start of commercial
operation of each unit. *
Resolution: The monitoring frequencies described In Footnote 4 should be
reduced to provide information which will be both more useful
and more representative of the wastewater treatment facility's
compliance with the designated pollutant standards. Once per
week for the first six months after commercial operation of
each unit end once per two weeks for the following six months
are inappropriate monitoring frequencies to determine the
operational efficiency of the facility. It Is expected that
this facility, as Is true of other treatment facilities, will
require some period after startup of each unit for fine-tuning
of systems and stabilization of operating procedures and
conditions. Monitoring for the metals listed at any frequency
greater than once per month would not be representative of the
ultimate treatment efficiency provided by the central
wastewater treatment facility. Monthly monitoring should be
sufficient to demonstrate Improvement In system operation and
compliance*
Page 1-9
Issue:
Csl
CO
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13
Total Suspended Solids - Discharge Limitations: Dally average
of 220 kg/day, or 480 Ibs/day at a concentration of 30 mg/1.
Dally maximum of 360 kg/day, or 800 Ibs/day, at a
concentration of 50 ng/1. \
Resolution: Total Suspended Solids - Discharge Limitations. Dally average
of 243 kg/day, or 536 Ibs/day, at a concentration of 34 ng/1.
Dally maximum of 1582 kg/day, or 3485 Ibs/day, at a
concentration of 100 ng/1.
The average dally TSS limitations should reflect an average
flow rate of 1094 gpm with a concentration of 30 mg/1 from the
Flow Equalization Pond plus 235 gpm at 50 mg/1 from the Coal
Pile Runoff Sedimentation Pond. Since these flows can be
simultaneous, a dally average concentration of 34 mg/1 is
reasonable. The use of a combined stream limitation is
consistent with the permit rationale used by EPA to develop
oil and grease llmltations-
The maximum dally TSS limitations should reflect a maximum
flow rate of 1200 gpm with • concentration of 100 mg/1 from
the Flow Equalization Pond plus 1000 gpm at 50 mg/1 from the
Coal Pile Runoff Sedimentation Pond. The concentration
ro
ro
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K3
limitation should be at 100 mg/1 since the Flow Equalization
Pond effluent can be the sole source of wactewater being
treated in the Central Wastewater Treatment Facility.
Page 1-9
Issue; Oil and Grease - Discharge Limitation: Dally maximum of 120
kg/day, or 270 Ibs/day.
Resolution: Discharge limitation should be 262 kg/day, or 577 Ibs/day.
Maximum flow rate for the effluent from the Flow Equalization
Basin Is 2400 gpm for two unit operation. Using a
concentration limit of 20 mg/1 the resultant requirement is
•bout 288 Ibs/day, or 131 kg/day. The permit rationale only
assumes average flow with a maximum concentration Instead of
the possible maximum flow and maximum concentration.
Page 1-11
Issue: Monitoring metal cleaning wastes for phosphate and reporting
results as "PO".
4
Resolution; Results of all phosphorus analyses should be reported as "P"
not as "PO^". (Methods for Chemical Analysis of Water and
Wastes", EPA-600/4-79-020; p. 365.1-1 to 365.4-3). In
addition, lime (CaO) will be used to neutralize metal cleaning
0")
CO
10
Issue:
wastes and non-phosphate containing cleaners will be used In
pre-operational cleaning. Therefore no phosphate containing
compounds will enter this waste stream either prior to or
during commercial operation, thereby Making the measurement of
phosphates in this waste stream unnecessary.
Monitoring metal cleaning wastes for COD.
Resolution: The measurement of COD In any waste stream at the SJRPP would
serve no useful purpose because there would be no way to
compare Individual waste stream COD values to those present In
the final effluent. The high chloride concentrations present
In the St. Johns River will produce a positive error In any
COD analyses conducted on the final effluent. Obviously, this
Is why there were no requirements In either the HPDES permit
or the Conditions of Certification for measurement of COD at
the final effluent* Therefore. If there Is nothing to compare
the waste stream COD values to, there is no practical reason
to measure them.
Page 1-12
Issue: Reporting results of phosphorus nonitorlng as "PO ".
CO
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Resolution: Footnote 2 refers to the total quantity of "phosphate" to be
discharged. This should be "phosphorus as P" to be consistent
with the procedures recommended in EPA's Methods for Chemical
Analysis of Water and Wastes. (See same comment on p. 1-11).
r--
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The need to Monitor at OSN 004 and 009 Is reasonable when any
discharge occurs. Accordingly, incorporating by reference the
requirements in the Draft Conditions of Certification for
metals and other substances detailed under Section II, 16,
B,l, Chemical Monitoring, is recommended.
NJ
U>
Page III-l, C
Issue: Additional monitoring for several parameters listed In Item C
is not appropriate.
ResolutIon: Item C should read, "additional monitoring shall include:
total suspended solids, copper, and Iron*" Further, the
requirement for monitoring for TSS, copper, and Iron is
redundant for OSN 006 and 007.
The Draft Conditions of Certification address the monitoring
and reporting of metals and other substances st OSN 006, 007
and 010. It Is reasonable for the NPDES permit to Incorporate
by reference the monitoring snd reporting requirements as
Identified by the Draft Conditions of Certification for these
locations. This approach Is consistent with 40 CFR Part 122.
Since no limitations for TSS, copper, and Iron are promulgated
under 40 CFR Part 423 for cooling tower blowdown and since
compliance for these parameters Is required at the pump sump,
no limitations or monitoring in the combined streams, OSN 001,
Is warranted.
00
CO
Page 1-16, 111-2,3
Issue: Requirements unrelated to point source discharges to waters of
the U.S. should be deleted.
Resolution: The NPDES program requires permits for the discharge of
pollutants from any point source Into waters of the United
States. 40 CFR Section 122.51(c). Only conditions applicable
to the N?DES program may be Incorporated within an NPDES
permit. Such conditions are referenced in Sections 122.7,
122.60, and 122.62.
Those paragraphs which are recommended for deletion within the
draft NPDES permits are beyond the Jurisdiction of the NPDES
program since they contain conditions unrelated to the point
source discharge of pollutants Into waters of the United
States. Such paragraphs slso contain requirements outside the
scope of the Clean Water Act contained in Sections 101 and
402. The following changes to the draft permit are
recommended:
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1-16 Delete paragraphs B.l.e, f and g
III-2.3 Delete paragraphs L, M. N, 0, F, Q. R. and S.
Page 1-16 and III-4
la sue: Effluent Bloassay Program
Resolution! The itate conditions of certification specifically address the
•ubject of bloassays under Condition 11.15, Variances to Water
Quality Standards. Because state conditions of certification
promulgated under Section 401 of the Clean Water Act typically
•re Incorporated Into the NPDES permit by reference
(consistent with 40CFR Part 122), the following modifications
should be made to Item h. Page 1-16 and Item T, Page III-4.
Substitute the following paragraph for parts (1), (2), and (3)
of Item h, and for Item T:
O
-a-
ATTACHMENT
"The Florida Department of Environmental Regulation has
certified the discharge(s) covered by this penult with
conditions (See Attachment _ ). Section 401 of the Act
requires that conditions of certification shall become a
condition of the penult. Therefore, th«»e conditions
pertinent to the bloassay program shall be Incorporated herein
by reference to the state conditions of certification."
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Attachment B
Additional Comments on Draft NPDES Permit
Page 1-1 and III-l.B
Issue: Temperature limitation on Main Plant Discharge to the
Northside Generating Station Discharge Channel - Daily
Maximum of 33.9°C or 93.0°F.
Resolution: This limitation should be changed to allow a maximum of
96°F. unless this limitation is removed altogether or
replaced with the requirement that only water at the lowest
temperature in the recirculating cooling water system can
be discharged. The 93°F maximum value included in the
NPDES permit application was based solely on data collected
during one year. Utilizing a longer period of record
(though still not as long as the anticipated plant lifetime)
and assuming worst case meteorological conditions, a model
predicting recirculated cooling water temperatures was run.
resulting in a new maximum discharge temperature of 96°F
for the main discharge. This value is certainly more
reasonable as a maximum value, particularly because the
existing NGS discharge has a current temperature limitation
of 104°F. Therefore, we would prefer the following wording:
"During those periods in which the Nortnslde Generating
Station has no thermal discharge, the maximum discharge
limitation from SJRPP will be 96*F."
Page III-3, Item 0
Issue: This requirement is overly restrictive and as a minimum
inconsistent with the Florida Department of Environmental
Regulation (DER) Conditions of Certification. See DER's
Item XII. B.
Resolution: We suggest that the text of this item be changed to read
as follows and be consistent with DER's Condition XII. B.
"Permittee may implement a test program to demonstrate the
quality and quantity of leachate from an un lined or un-
controlled waste facility. During the testing program,
Permittee shall either provide an Impermeable liner under
the solid waste disposal areas or shall utilize a chemical
fixation process, stabilization or other approved methods
to control leachate from the solid waste. Upon an affirmative
showing that an uncontrolled solid waste facility will not
cause violation of groundwater quality criteria, the
Florida Department of Environmental Regulation (FDER) may
approve use of non-lined or uncontrolled landfill cells."
As discussed In the solid waste management plan, any leachate
generated at landfill areas during the course of the solid
waste test program is not expected to result in violation
of Class I-B water quality standards beyond the-property
boundary. If the results of the test program indicate that
there will be no groundwater contamination as a result of
solid waste leachate, then no further action will be
-------
required. If the solid waste test program demonstrates
the possibility of ultimately exceeding Class I-B water
quality standards beyond the property boundary, then the
subsequent solid waste and the solid waste material generated
during the test program will be disposed of in lined or
capped landfills or treated in such a manner to preclude
further generation of leachate. Consequently, It is suffi-
cient to provide for solid waste disposal In a well managed,
unlined landfill during the course of the test program in con-
Junction with a lined test facility which will provide for suf-
ficient information to demonstrate the long term protection of
the shallow aquifer groundwater resource.
Page III-3, Item P
Issue: This requirement should be consistent with the DER Con-
dition XII.C.
Resolution: Rewrite as follows:
"Permittee shall utilize solid waste disposal area "B",
north of Island Drive or the area previously designated
for the bottom ash pond, prior to using disposal area "A."
Page III-3, Item Q
Issue: Requirement Q relating to buffer zones during construction
requires clarification.
13
ro
Resolution: Requirement Q should be rewritten as follows:
"To the maximum extent feasible, an undisturbed buffer
zone of approximately 200 feet In width shall be maintained
between all construction activity areas and on-site wetlands
contiguous with the St. Johns River or its tributaries.
The buffer zone is to be defined by placement of a fence
on the upland limit of the buffer zone as depicted on
Figure 4.3-1 of the Revised SCA/EID."
Page III-3, Item S
Issue: Inconsistency with DER Conditions of Certification.
Resolution: Rewrite Item S as follows:
"After review by EPA, the Permittee shall institute a
groundwater monitoring program as outlined in the State
of Florida Conditions of Certification. Sections II.B.2
and III.G."
Page III-4, Item T
Issue: Structure and requirements of bioassay program.
Resolution: Rewrite Item T as follows to be consistent with DER's
Condition II.A.15.
"The Permittee shall Implement a Bioassay Test Program for
copper, mercury, and total residual chlorine. The Bioassay
-------
Test Program shall be Implemented after review and approval
by the Florida Department of Environmental Regulation (FDER)
and review by EPA. The test program shall be submitted
to FDER and EPA by December 1, 1983. The FDER shall indi-
cate Its approval or disapproval within sixty (60) days,
and the EPA shall perform its review in the same time
period."
A T T A C H M E N T
-------
ro
oo
NFDES Permit No. FL 0037869
Page 1-2, OSN 002
Issue: A need exists to have the sources which comprise this outfall
better defined.
Resolution: The JEA is requesting that the effluent from dewatering
activities be included as an additional source of wasteuater
to this outfall. Therefore, the description for outfall
serial number 002 should read, "Runoff Sediment Control Pond
discharge to Browns Creek (Includes construction and yard
drainage, effluent from devatering activities, effluent
from . . .)."
During the construction phase, water resulting from dewatering
activities will be discharged through the Runoff Sediment
Control Pond which will discharge to Browns Creek. In addition
to discharges from this source, the Runoff Sediment Control
Pond will receive discharges from the concrete truck washing
area, the construction area runoff and the sanitary waste-
water treatment facility. A schematic diagram of the con-
struction phase drainage system is presented in Figure 1.
Mitigating measures will be used to control the solids content
of water collected during the dewatering activities. Effects
of dewatering on the plant site and mitigating measures to be
employed during the construction phase are discussed In the
revised SCA/EID, Section A.1.7 Water Bodies and Uses (pp
4.1-23 to 4.1-26). A system of pump screens or filters will
be built into each well point in order to remove solid
materials which would affect pump operation. Because of
site-specific requirements due to local soil types,
specifications regarding the size of particles to be
removed will be determined by the JEA's sub-contractor
responsible for site dewatering activities.
An indication of the expected quality of the groundwater
entering this pond and thence into Browns Creek can be
gained from Table 1, which shows comparisons of observed
groundwater quality (from samples obtained at a groundwater
monitoring well near the proposed site of the pond), on-site
surface water quality (from a sampling location near the
proposed pond site), and appropriate state water quality
criteria.
As noted in Table 1, the only chemical constituent of either
the groundwater or the surface water observed in a concentra-
tion in excess of its Class III criterion was the average
observed groundwater concentration of iron. However, a mass
balance analysis Indicates that only approximately 308 gpn
(less than 0.7 cfs) of surface water will be necessary to
dilute 1000 gpm of groundwater with this iron concentration
to the Class III criterion of 0.3 mg/1.
-------
Figure 1 indicates annual average flows from the concrete
truck washing area, construction area runoff, and sanitary
wastewater treatment facility will amount to approximately
303 gpm. The iron concentration of these waters is expected
to be less than that observed in the on-site stream monitoring,
and since the 1000 gpm flow of the dewatering activities is
a maximum flow, not an average flow. It is expected that
there will be sufficient dilution within the Runoff Sediment
Control Pond to provide a final effluent with an iron con-
centration below the Class III standard of 0.3 mg/1. Addi-
tional reduction of the iron concentration can be expected
due to oxidation, precipitation and sedimentation of iron
within the pond. This is reasonable because the pond design
is for approximately 56 million gallons, which at about
1,303 gpm Is Just over 31-day retention time.
Page 1-1, OSN 001
Issue; Possible Inclusion of dewatering activity effluent into
outfall serial number 001.
Resolution: Current design of the makeup water intake structure is not
anticipated to require any form of dewatering effluent. The
structure will be constructed In its final location and the
concrete walls will be placed by the formed lift method as
the excavation inside the structure progresses. The excava-
tion will be continued until the structure reaches its final
Table 1
QUALITY OF WATER ENTERING RUNOFF SEDIMENT CONTROL POND
oo
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FIGURE 1
CONSTRUCTION PHASE DRAINAGE-SCHEMATIC
CONCRETE TRUCK
WASHING AREA
fc
CONSTRUCTION
SEDIMENTATION
PONDS
I
r
i
CONSTRUCTION V
AREA RUNOFF
1 -
1
LOCAL/INTERMEDIATE
SEDIMENTATION PONDS
1(1000)
DEWATERING
ACTIVITIES
(REVISION]
w 8EOI
CON1
— — ^ Dni"
A
1
1
'
IFF
FROL
)
k
[0031
19
SANITARY WAST
TREATMENT
303 TO ST.JOHNS RIVER ^
[W| VIA BROWNS CREEK ™
/NPOES DISCHARGE NUMBERS
-^ FLOW DIRECTION
000 ANNUAL AVERAGE FLOW. GPM
1000) ESTIMATED MAXIMUM FLOW. GPM
E
-------
Jacksonville Electric Authority
233 WEST DUVAL STREET • P. O. BOX 53015 • JACKSONVILLE, FLORIDA 32201
December 10, 1981
Mr. John Hagan, Acting Chief
Environmental Assessment Branch
U.S. Environmental Protection Agency - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
Subject: JACKSONVILLE ELECTRIC AUTHORITY
ST. JOHNS RIVER POWER PARK UNITS 1 & 2
DRAFT NPDES PERMIT NO. FL 0037869
Re: Letter of 11/20/81 to Mr. James Patrick, US EPA
Enclosed please find a detailed discussion of the present design
and proposed operating sequence for chlorination of the cooling
towers at the St. Johns River Power Park Units 1 & 2 (SJRPP).
This discussion is the Jacksonville Electric Authority's (JEA)
rationale for assuring compliance of the cooling tower blowdown,
(OSN005), with requirements of 40 CFR 423.15 and is in response
to Item HE of the NPDES "Fact Sheet".
In particular JEA is assuring that neither free available oxidant
(FAO) nor total residual oxidants (TRO) will be discharged from
either SJRPP cooling tower for more than two hours per day.
Further, neither FAO nor TRO will be discharged from more than
one cooling tower at any one time. Both assurances are provided
with the understanding that under 40 CFR 423.15, the JEA retains
the right to demonstrate to the Regional Administrator that the
SJRPP cannot operate at or below this level of chlorination.
Total residual oxidant concentrations in the St. Johns River
were measured above detection limits during the JEA's one year
pre-application monitoring program, as noted in the discussion.
With the presence of TRO in the St. Johns River, which serves
as makeup to the cooling towers after passing through the
Northside Generating Station's (NGS) circulating water system,
some TRO can be expected to be present in the blowdown. However,
the presence of TRO in the blowdown as a result of its presence
in the makeup should not be charged against the two conditions
noted above. We suggest the NPDES Permit for OSN 005 be rephrased
so as to account for the presence of TRO in the makeup water
from the St. Johns River. Accordingly, we have provided
alternative language in the enclosed discussions.
(CONT.)
131
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Mr. John Hagan
December 10, 1918
Page 2.
Should you require clarification on any of the enclosed
material, please contact me at (904) 633-4517.
Very truly yours,
Richard Breitmoser, P.E.
Division Chief
Research & Environmental
Affairs Division
RB/lwr
cc: D. A. Moehle
D. H. Lucas
L. L. Leskovjan
132
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TABLE 1
NOTATIONS AND ASSUMPTIONS
1. C, - initial chlorine demand in blowdown, at time - 0 hrs. (mg/1)
bo
2. C « initial chlorine demand in water returning from the condenser,
ro at time - 0 hrs; assuming 1 mg/1 free available oxidant
3. Dose - 60 minutes, beginning at time - 0 hrs.
A. F - fraction of the residual chlorine which flashes or decomposes as it
passes through the cooling tower fill
133
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FIGURE 1
CHLORINE LEVEL IN SJRPP BLOWDOWN
^)
JD
C OB
•o
E
e
•o
U CO
It
•o
JO
•o
E
•o
U
CM
•
I
Cbo- 6 (Initial Demand In Slowdown)
Coo- 3.75 (Initial Demand In Slowdown)
(Fraction of TRO which Decay*)
(Initial Demand from Condenser)
Minute*
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Time in Hours
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Attachment A
Issue; NPDES "Fact Sheet", Item 6.H.E., Effluent Limitations, OSN 005 -
Cooling Tower Slowdown
Resolution:
A mathematical model was developed to predict the residual chlorine levels
in the blowdown from each cooling tower at the St. Johns River Power Park
(SJRPP). The model follows one developed by G. Nelson of the U.S. EPA (Nelson,
G. R. 1973, Predicting and Controlling Residual Chlorine in Cooling Tower
Blowdown. EPA-R2-73-273. US EPA). Appropriate design volumes and pump flow
rates were included in the model to make it site specific. Further, results
from chlorination studies on Northside Generating Station's (NGS) circulating
water system were used to provide chlorine demand data. In particular, the
TRO demand of 6 mg/1 was found applicable to the St. Johns River water serving
as makeup.
Modeling results are shown in Figure 1, Chlorine Level in SJRPP Blowdown,
and an explanation of notation is provided in Table 1. (Note: Although ana-
lytical measurements for total residual chlorine, TRC, and free available
chlorine, FAC, suggest calculating results as mg/1 of chlorine, the actual
measurement is of total oxidizing power. Accordingly, for the remainder of this
discussion, TRC will be replaced by total residual oxidants, TRO, and FAC by
free available oxidants, FAO).
The presence of TRO in cooling tower blowdown is indicated by a negative
value on the ordinate (Figure 1). Therefore, for an initial demand of 6 mg/1
in the blowdown, or tower basin, TRO is predicted to occur for approximately
one hour in the blowdown. If C, were only 3.75 mg/1, then TRO is predicted
to occur for approximately one and one-half hours (1.5 hours) in the blowdown.
In both cases, the presence of TRO in the cooling tower blowdown complies with
time limitations under 40 CFR 423.15.
In reviewing Figure 1, it should be noted that chlorination begins at time
zero and continues for one hour, thus the curve passes from a positive ratio to
a negative ratio. After chlorination ceases, demand is still present and the
curve passes from a negative ratio, where TRO is present, to a positive ratio,
where TRO is not present.
Model results shown in Figure 1 are conservative for two reasons. First,
the chlorination application time is set at 60 minutes whereas typical values
are 30 minutes as a maximum (Nelson, 1973). A shorter chlorination time reduces
the time during which TRO would be present in the blowdown. Secondly, a value
of zero was assigned to F, i.e., the fraction of the TRO which flashes or de-
composes as it passes through the cooling tower fill. Nelson correctly notes
more reasonable values for F are from 0.3 to 0.5. A value of 0.3 was modeled
and the case of C equal to 6 mg/1 showed a decrease in TRO present in the
blowdown from the §0 minutes noted in Figure 1 to approximately 54 minutes.
Together, these two assumptions yield time values for TRO concentrations in
the blowdown significantly longer than those anticipated. Thus, it is demon-
strated that current design, coupled with worst case operating assumptions,
result in TRO being released for less than two hours per day per unit.
135
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Attachment A (cont.)
TRO was observed in the St. Johns River during the one-year pre-application
monitoring program (see Chapter 2.5 and Appendix C of the SCA/EID). Because
SJRPP's towers in essence use St. Johns River water as makeup, the presence
of TRO in the makeup from other than SJRPP or NGS operation must be recognized
in the NPDES Permit. Accordingly, Page 1-5 of the permit should be modified
to read:
"Until the date noted. . .during all periods of FAO discharge. . .
Neither FAO nor TRO may be discharged from either cooling tower for more
than two hours in any one day, except if due to the presence of TRO in
the cooling tower makeup, and not more than one tower from either unit
may discharge FAO or TRO at any time, except if due to the presence of
TRO in the cooling tower makeup, unless the permittee can satisfactorily
demonstrate. . .chlorination. TRO shall not be discharged during periods
when TRO is being discharged from any unit at Northside Generating Station,
except if due to the presence of TRO in the cooling tower makeup (ambient
or from chlorination of Northside Units)."
One final note, as mentioned in Section 5.1.4.2 of the SJRPP SCA/EID, the con-
denser cooling system for the plant will use mechanical cleaning to reduce
bio-fouling. The on-line mechanical cleaning system for the condensers will
consist of two independent systems (one for each half of the condenser) and
should decrease the need for chlorination in terms of frequency and duration.
136
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3.5 USEPA'S RESPONSES TO COMMENTS ON THE DRAFT NPDES PERMIT
This section provides the responses by USEPA to the numbered comments in
Section 3.4. The responses are given in the order of the comments and are
referenced by the corresponding comment number (W-120 through W-149).
W-121: A footnote has been added in regard to Proposed Permit page 1-2 as
follows: "Condition of State Certification, see Attachment B."
Footnotes have also been added to pages 1-5 and 1-6, 1-7 and 1-8, and
1-9 and 1-10 indicating that limitations are a condition of the vari-
ance to water quality standards criteria. Also see response to written
comment W-17. The last paragraph in Part III includes the requested
paragraph language and is not repeated on each page. Limitations and
monitoring requirements, however, have been specifically retained in
the Proposed NPDES Permit. Under conditions of the Clean Water Act,
an NPDES permit must assure compliance with both applicable effluent
guidelines and applicable water quality standards. Therefore, limita-
tions, monitoring, and reporting requirements are included in the
NPDES Permit as they relate to the variance request or to assuring
that discharges are as projected by the applicant and are within an
acceptable range for compliance with Federally approved water quality
standards. Additionally, since the entire "Conditions of Certifica-
tion" under the Florida Power Plant Siting Act (as opposed to the
State 401 Certification - Attachment B) will be included by reference
only, monitoring frequencies are necessary in the NPDES Permit and
have been modified in conjunction with State personnel.
W-122: Inclusion of temperature limitations on cooling tower blowdown in the
Proposed NPDES Permit (as included in the NPDES application, EIS
evaluation, and other documentation) is consistent with other similar
permitting actions. The temperature limitation on page 1-1 has been
increased to 96° F, based on additional information submitted by the
applicant. The mixing zone size in Part III.B has been increased to
17 acres.
W-123: Deleted as requested.
W-124: The phrase, "effluent from dewatering activities," has been included
in the OSN 002 description as requested.
W-125: Changed as requested.
W-126: Typo corrected.
W-127: Additional language has been included to clarify the USEPA intent.
W-128: Deleted as requested.
W-129: Typos corrected.
W-130: See NPDES Permit Rationale, Appendix 6.1, Item II.F.3. for response.
137
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W-131: See NPDES Permit Rationale, Appendix 6,1, Item TT.F.3. for response.
W-132: Monitoring frequencies have been modified somewhat and start of sampling
has been changed to "90 days after commercial start-up of Unit 1."
W-133: See NPDES Permit Rationale, Appendix 6.1, Item II.F.3. for response.
W-134: See NPDES Permit Rationale, Appendix 6.1, Item II.F.3. for response.
W-135: Corrected as requested.
W-136: COD is included for monitoring the organic component of the discharge
and does not require direct comparison to River water. While BOD
could have been substituted, COD is considered to be a more reasonable
parameter for this discharge. It is agreed that COD analysis on St.
Johns River water or the combined discharge (which includes saline
cooling tower blowdown) would not be appropriate due to chloride
content, monitoring of OSN 007 is appropriate. The discharge limita-
tion of 100 mg/1 has been deleted in conjunction with State personnel.
A requirement has been included stating that USEPA be notified if any
chemicals other than those previously proposed are to be used.
W-137: Corrected as requested.
W-138: Additional monitoring requirements are considered warranted to quanti-
fy discharge of heavy metals from OSN 007 to assure that applicant's
projections are correct and that impacts on water quality have been
accurately evaluated. Since monitoring for TSS, iron, and copper are
I/day during discharge, no additional sample would be required by Part
III.C. for these parameters. Monitoring and reporting requirements
are retained in the NPDES Permit for OSN 004, 007, and 009 for the
reasons indicated in response to comment W-120 above. Part III.C.
requirements have been deleted for OSN 001 as requested. Part III.C.
requirements have also been deleted from OSN 006 and 010; however,
specific monitoring requirements have been added for these discharges.
W-139: USEPA may impose conditions on NPDES permits which come about as a
result of mitigation developed during the EIS process. USEPA's author-
ity to impose such conditions has been upheld in court and has been
incorporated into the Agency's regulations for the implementation of
NEPA. The USEPA Office of General Counsel has rendered opinions that
such conditions must be imposed when the Agency determines that they
are required to make the project environmentally supportable.
W-140: The bioassay program required by USEPA is appropriate given the public
and regulatory concerns over the impact of the proposed discharge.
W-141: Refer to response to written comment W-121.
W-142: USEPA has conditioned the Proposed NPDES Permit as described in the
response to written comment W-34. The Agency deems the permit condi-
tion appropriate to assure that impacts from solid waste disposal on
the site are minimized and carefully controlled.
138
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W-.143: USEPA has conditioned the Proposed NPDES Permit to allow a five-year
test program as described in the response to written comment W-34.
During this period, waste disposal will be limited to the waste dis-
posal area immediately adjacent to the rail loop and Island Drive.
The conditions and order in which waste disposal areas A and B may be
used will be determined after completion of the program.
W-144: Fencing of the SJRPP site will be expanded to offer protection to a
greater portion of the wetlands and undisturbed natural areas on the
SJRPP site as described in the response to written comment W-56.
Requirement Q will be modified to reflect the revised fence line.
W-145: USEPA has agreed to allow JEA to institute a five-year solid waste
disposal test program as described in the response to written comment
W-34. This program will include short-term and long-term groundwater
monitoring.
W-146: Refer to the response to written comment W-139.
W-147: Refer to response to written comment W-123.
W-148: No action required.
W-149: At the time of the Draft EIS, concern was expressed with the ability
of the applicant to comply with effluent limitations in the Draft
NPDES Permit for residual oxidants. The applicant has submitted
results of mathematical modeling of the cooling system which indicate
that total residual oxidants resulting from system chlorination will
not be discharged for more than two hours per day per cooling tower.
The die-away coefficients and other aspects of the model, however,
have not been verified by field measurements in a salt water cooling
tower system. The USEPA staff remains concerned with the applicant's
ability to comply with permit conditions for TRO in the cooling tower
blowdown without added controls. The applicant proposes to install a
mechanical cleaning system for the condensers which will reduce the
need for chlorine addition to that portion of the cooling system.
Additionally, dechlorination techniques have been demonstrated else-
where, and can be used by the applicant, if necessary. Since the
applicant has expressed his commitment to comply with NPDES conditions
and limitations, a specific requirement to provide dechlorination
facilities has not been included in the Proposed NPDES Permit.
Additions to the paragraph on page 1-5 have been included as
requested.
139
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4.0 COORDINATION
The following Federal, State, and local agencies, public officials,
organizations, and interest groups have been requested to comment on this
impact statement.
Federal Agencies
Department of Agriculture
Department of the Army
Department of Commerce
Department of Energy
Department of Health, Education,
and Welfare
Department of the Interior
Energy Research & Development
Administration
Federal Aviation Administration
Federal Emergency Management
Agency
Federal Energy Regulatory Commission
Federal Highway Administration
State Agencies
Department of Administration
Florida Department of Environmental
Regulation
Florida Department of Transportation
Florida Game and Fresh Water Fish
Commission
Florida Public Service Commission
State of Florida Department of State
Jacksonville Area Planning Board
Northeast Florida Regional Planning
Council
St. John's River Water Management
District
State Historic Preservation
Officer
Florida Department of Veteran
and Community Affairs
Interest Groups
Heckscher Drive Community Club
Sierra Club, Power Plant Siting
Committee, Florida Chapter
Sierra Club, Jacksonville Chapter
Duval Audubon Society, Inc.
Florida Lung Association
Sea Oats Garden Club
Defenders of Wildlife
140
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5.0 LIST OF PREPARERS
5.1 US ENVIRONMENTAL PROTECTION AGENCY
Robert B. Howard
F. Theodore Bisterfeld
Charles H. Kaplan
Henry G. Strickland
David Holroyd
Louis Nagler
Ronald Raschke, Ph.D.
Gail Mitchell
Michael J. Hartnett
William L. Kruczynski, Ph.D.
5.2 WAPORA, INC.
Ronald B. McNeill
Steven D. Bach, Ph.D.
Lawrence Olinger
Jerald D. Hitzemann
William J. March, Ph.D.
Mirza Meghji, Ph.D.
David M. Conner
Chief
EIS Preparation Section
Sanitary Engineer
Project Officer
Biologist
NPDES Permit Coordinator
Chief, Power Plant/Synfuel Unit
Water Quality
Engineer
Air Resources
Engineer
Meteorologist
Aquatic Resources
Aquatic Ecologist
Groundwater
Groundwater Hydrogeologist
Residuals Management
Engineer
Wetlands Resources
Biologist
Project Manager
Assistant Project Manager/Biologist
Project Administrator
Quality Control
Hydrologic Engineer/Meteorologist
Environmental Engineer
Air/Acoustical Engineer
141
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Kenneth Simonton
Ruthanne L. Mitchell
Kim Banks
Fred C. Mason III
Walker J. Duncan
Jan E. Dillard
Mark L. Cameron
Alyse Gardner
Greg Seegert
Wesley Powell
Acoustical/Transportation Specialist
Assistant Cultural Geographer/Draftsperson
Archaeologist
Geologist
Geologist
Socioecnomist/Planner
Socioeconomis t/Planner
Biologist
Biologist
Editor
142
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APPENDIX 6.1
NPDES PERMIT
AND
PERMIT RATIONALE
-------
Note: Changes made to October 29, 1981 Draft Permit and Rationale contained
in the SAR/Draft EIS are indicated by a bar in the right and margin.
-------
Permit No.: FL0037869
.,.,'*
wfelffl
WV.'ii \,'^A W>
w^
ATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
343 COURTLAND STREET
ATLANTA. GEORGIA 30365
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Clean Water Act, as amended
(33 U.S.C. 1251 et. seq; the "Act"),
Jacksonville Electric Authority
233 West Duval Street
Jacksonville , Florida 32201
is authorized to discharge from a facility located at
St. Johns River Power Park
Units 1 and 2
New Berlin Road and Island Drive
Jacksonville , Florida 32226
to receiving waters named St. Johns River and Browns Creek
from discharge points enumerated herein as serial numbers 001
through 009 .
in accordance with effluent limitations, monitoring requirements and
other conditions set forth in Parts I, II, and III hereof. The permit
consists of this cover sheet, Part I 16 pages(s), Part II 12 page(s)
and Part III 5page(s).
This permit shall become effective on
This permit and the authorization to discharge shall expire at
midnight, (5 years)
Date Signed
Paul J. Traina, Director
Water Management Division
I
-------
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 001 - Main Plant Discharge to the
Northside Generating Station (NPDES No. FL0001031) Discharge Channel (to the St. Johns River).
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirements
Inst. Maximum Daily Maximum Measurement Sample
Frequency Type
Temperature °C (°F) N/A 35.6 (96.0) Continuous Recorder
Total Residual Oxidants(mg/l) 0.10 NA 1/week V Muulp" grabs
Copper 0.18 NA 21 throughout the day
A £/ 24-hour composite
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored
I/week on a grab sample.
There shall be no discharge of floating solids or visible foam In other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Main Plant Discharge prior to entry into the Northside Discharge Channel, except that chlorine
and copper shall be monitored at the end of the Northside Discharge Channel. chlorine
I/ From start of chlorination of each unit, analyses shall follow each application until sufficient
operating experience has been obtained to assure conformance with limitations and then analysis frequency
may be reduced to one day per week. y
21 Once per week starting 90 days after commercial start-up for three months, two per month for the next six
months and once per month thereafter. All data shall be submitted monthly during the period of once per
week sampling (and summarized quarterly in DMR's).
tP
cp
I
(D 0) 0)
H 00 >-|
a n> n
o
o
00
-J
00
-------
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Durine the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial numbers) 002 - Runoff Sedimentation Control
Pond discharge to Browns Creek (includes construction and yard drainage, effluent from Concrete Truck Washing
Settling Pond, effluent from dewatering activities, and Sanitary Wastewater Treatment Facility effluent (OSN -J
003)). .
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirements
Instantaneous Maximum Measurement Sample
Frequency Type
Flow-m3/Day (MGD) N/A I/week Grab
Total Suspended Solids (mg/1) 50 I/ I/week Grab
ToJal^esidual Chlorine (mg/1) o'.01~2/ I/week Multiple Grabs •
To the extent practicable, water for concrete truck washing shall be recycled from the concrete washing
settling pond.
The pH shall not be less than 6.0 standard units nor greater than 8.5 standard units and shall be monitored
I/week by grab sample !_/, 2_/.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): point of discharge from the Runoff Sedimentation Control Pond, except that oil and grease and •
chlorine shall be at the borrow pit into Browns Creek. ** 1? £?
I/ Applicable to any flow up to the flow resulting from a 24-hour rainfall event with a probable recurrence
~ interval of once in ten years.
21 Condition of State Certification, see Attachment B.
STRINGENT REQUIREMENTS
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 003 \j - Sanitary Wastewater
Treatment Facility effluent (Two units in parallel) to OSN 002 during construction of Unit 1 and OSN 001
during operation.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirements
Daily Average Daily Maximum Measurement Sample
(mg/1 except as noted) Frequency Type
Flow-m3/Day (MGD) N/A 114 (0.030) 2J 2/week Grab
BODj 30 60 I/month 8-hour composite
Total Suspended Solids 30 60 I/month 8-hour composite
The pH shall not be less than N/A standard units nor greater than N/A standard units and shall be monitored N/A fl|
by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Combined sewage treatment plant effluent prior to mixing with any other waste stream.
I/ Serial number assigned for identification and monitoring purposes.
2/ Neither unit shall be loaded at greater than one-half the value shown.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial numbers) 004 - Coal Pile Runoff Sedimentation
Pond overflow to Browns Creek.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirements
—— t
Daily Average Daily Maximum Measurement Sample
Frequency Type
N/A N/A During Occurrence Estimate
III.C.) N/A N/A During Occurrence Representative
Discharge to Browns Creek is not permitted except when flow results from a 24-hour rainfall event with a
probable recurrence interval of once in ten years (10Q24) or greater. All periods of discharge shall be
reported.
Discharge of water from the plant main pump sump to the coal pile runoff sedimentation pond is permitted during
periods when the PH of OSN 006 is not within permitted limitations, provided that available excess detention
volume not less than that required for a 10Q24 storm is maintained. Water level interlocks or other acceptable
positive methods shall be provided to assure control. A report defining the proposed control measures shall be
submitted not later than 12 months prior to commercial operation date of Unit 1.
The pH shall be monitored during discharge by representative grab samples.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Discharge from the coal pile runoff sedimentation pond.
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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 005 \J - Unit 1 and 2 Cooling Tower
Blowdowns to OSN 001.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Flow-m3/Day (MGD)
Free Available Oxidants - FAO
Total Residual Oxidants - TRO
Time of TRO discharge (minutes/day/tower)
Cycles of Concentration
Discharge Limitations
(mg/1 unless noted)
Chlorination Period
Average Inst. Max.
Monitoring Requirements
N/A
N/A
See Below
See Below
See Below
See Below
Measurement
Frequency
Daily
I/week 2/
I/week 2/
I/week 2J
I/day 3/
Sample
Type
Pump logs
Multiple Grabs
Multiple Grabs
Determinations
Calculation
Until the date noted in the next paragraph, FAO shall not exceed an average concentration of 0.2 mg/1 nor a
maximum of 0.5 mg/1 in the blowdown from either cooling tower during all periods of FAO discharge during any
day. Neither FAO nor TRO may be discharged from either cooling tower for more than two hours in any one day,
except if due to the presence of TRO in cooling tower make-up, and not more than one tower from either unit
may discharge FAO or TRO at any time, except if due to the presence of TRO in cooling tower make-up, unless
the permittee can satisfactorily demonstrate to the Regional Administrator that the units cannot operate at or
below this level of chlorination. TRO shall not be discharged during periods when TRO is being discharged
from any unit at Northside Generating Station, except if due to the presence of TRO in the cooling tower
make-up (ambient or from chlorination of Northside Units).
Not later than three years afer promulgation or July 1, 1987, whichever is earlier, TRO shall not exceed a
maximum concentration of 0.14 mg/1 in the combined cooling tower blowdown discharge. Note: In the event that
BAT regulations for control of TRO or chlorine are promulgated in a manner inconsistent with the October 14,
1980, proposed guidelines, requirements of this paragraph will be modified consistent with the promulgated
regulations (40 CFR 423).
There shall be no discharge of detectable amounts of materials added for corrosion inhibition (including, but
not limited to, zinc, chromium or phosphorus) or any chemicals added which contain the 129 priority pollutants.
Cycles of concentration shall not exceed 1.5 and shall be calculated by dividing the 24-hour average intake
flow by the 24-hour average blowdown flow for each tower.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 005 17 -Unit 1 and 2 Cooling Tower
Blowdowns to OSN 001. (Continued)
The permittee shall notify the Director, Enforcement Division in writing not later than four months prior to
instituting use of any biocide or chemical used in cooling systems, other than chlorine, which may be toxic to
aquatic life, other than those previously reported to the Environmental Protection Agency. Such notification
shall include:
1. name and general composition of biocide or chemical, CJ
2. 96-hour median tolerance limit data for organisms representative of the biota of the waterway into ^
which the discharge shall occur, •<
3. quantities to be used, ***
4. frequencies of use, __,
5. proposed discharge concentrations, and **•
6. EPA registration number, if applicable. Is
The pH shall not be less than NA standard units nor greater than NA standard units and shall be monitored NA.
There shall be no discharge of floating solids or visible foam In other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Discharge from each of the cooling towers prior to mixing with other waste streams.
I/ Serial number assigned for identification and monitoring purposes.
21 From start of chlorination of each unit, analyses shall follow each application of chlorine until
~ sufficient operating experience has been obtained to assure conformance with limits and then analysis ha
frequency may be reduced to one day per week. g <
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning \l and lasting through 2_/,
the permittee is authorized to discharge from outfall(s) serial number(s) 006 3_/ - Unit 1 Central Wastewater
Treatment Facility effluent to OSN 001.
Such discharges shall be limited and monitored by the permittee as specified below:
£d
Effluent Characteristic
Flow-m3/Day (MGD)
Total Suspended Solids
Oil and Grease
Aluminum, total
Arsenic, total
Chromium, total
Copper, total
Iron, total
Lead, total
Mercury, total
Nickel, total
Selenium, total
Silver, total
Zinc, total
Discharge Limitations Monitoring Requirements
kg/day (Ibs/day) Other Units (mg/1)
(except as noted) Measurement Sample
Daily Avg Daily Max Daily Avg Daily Max Frequency Type
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H
N/A
130(280)
45(100)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
360(800)
60(130)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
7/
N/A
30
ioV
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
50l/
N/A
N/A
0.3i/
N/A
o.oooii/
N/A
N/A
0.00005.6/
N/A
Daily
2/week I/
2/week
y
y
y
V
y
y
4/
y
4/
I/
4/
Pump hour meter
24-hour compos!11
3-grab composite
24-bour compos! t<
24-hour compos!ti
24-hour composite)
24-hour compos!t<
24-hour composltel
24-hour compositel
24-hour compositel
24-hour composite!
24-hour compositel
24-hour composite!
24-hour compositel
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored by
continuous recorder.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
locatlon(s): Discharge from the central wastewater treatment facility prior to mixing with any other waste
stream, except that pH and metals shall be from the Pump Sump. Daily flow records of both the discharge from I
the Flow Equalization Basin and Coal Pile Runoff Sedimentation Pond also shall be maintained by pump hour
recorders.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning I/ and lasting through 2_/,
the permittee is authorized to discharge from outfall(s) serial number(s) 006 3/ - Unit 1 Central Wastewater
Treatment Facility effluent to OSN 001. (Continued)
I/ Start of discharge from Unit 1.
21 Start of discharge from Unit 2.
3/ Serial number assigned for identification and monitoring purposes.
4/ Once per week starting 90 days after commercial start-up for three months, two per month for the next six
months and once per month thereafter. All data shall be submitted monthly during the period of once per
week sampling (and summarized quarterly in DMR's).
5/ During periods when coal pile runoff is not being processed, daily maximum limitation for TSS shall be
100 mg/1 and daily average and daily maximum for O&G shall be 15 and 20, respectively.
£/ Instantaneous maximum water quality standards criterion. Note; This limitation is subject to mod-
iUcation by the State of Florida in granting, modifying, or denying the requested variances and/or
by the USEPA in approving or denying a State variance, should it be granted by the State.
TJ Should runoff necessitate pumping at the rate of 1000 gpm for 24 hours during this period from the
^l^^S^.^e ^Lct^n^^ ^±nCTBT\by 21°(460) t0 a maXimUm °f
oe conducted pn a,ll such days and the number of
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning \J and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 006 2J - Units 1 and 2 Central Wastewater
Treatment Facility effluent to OSN 001.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Discharge Limitations
kg/day (Ibs/day)
Monitoring Requirements
Flow-in3/Day (MGD)
Total Suspended Solids
Oil and Grease
Aluminum, total
Arsenic, total
Chromium, total
Copper, total
Iron, total
Lead, total
Mercury, total
Nickel, total
Selenium, total
Silver, total
Zinc, total
Dally Avg
N/A
220(480)
90(200)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Dally Max
Other Units (mg/1)
(except as noted)
Daily Avg Daily Max
Measurement
Frequency
N/A
660(1460) V
120(260)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
30
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
50l/
153/
1. 5^/
N/A
N/A A/
o.oisA/
0.3A/
N/A .
o.ooo i±/
N/A
N/A
0.00005-
N/A
Daily
2/week^7
2 /week
I/month
1 /month
I/month
I/month
I/month
1 /month
I/month
1 /month
I/month
1 /month
1 /month
Sample
Type
Pump hour meter
24-hour composite
3-grab composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
During periods of metal cleaning, quantity limitations from this source shall be one-half of those noted above
(but is Increased by the actual quantities of metal cleaning waste pollutants being discharged from OSN 007).
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored by
continuous recorder.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Discharge from the central wastewater treatment facility prior to mixing with any other waste
stream, except that pH and metals shall be from the Pump Sump. Dally flow records of both the discharge from
the Flow Equalization Basin and Coal Pile Runoff Sedimentation Pond also shall be maintained by pump hour
recorders.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning 17 and lasting through expiration, ^
the permittee is authorized to discharge from outfall(s) serial number(s) 006 2_/ - Units 1 and 2 Central ^
Uastewater Treatment Facility effluent to OSN 001. (Continued) ^
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I/ Start of discharge from Unit 2. £9
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3/ During periods when coal pile runoff is not being processed, daily maximum limitation for TSS shall be
~~ 100 mg/1 and daily average and daily maximum for O&G shall be 15 and 20, respectively.
4/ Instantaneous maximum water quality standards criterion. Note; This limitation is subject to mod-
~ ification by the State of Florida in granting, modifying, or denying the requested variances and/or
by the USEPA in approving or denying a State variance, should it be granted by the State.
.57 Should runoff necessitate pumping at the rate of 1000 gpm for 24 hours during this period from the
coal pile runoff sedimentation pond, this limitation may be increased by 210(460) to a maximum of
870(1920). Sampling for TSS shall he cqnducted on all such days and the number of, samples per week
shall be increased similarly.
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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 007 !_/ - Metal Cleaning Wastes from
Units 1 and 2 to OSN 001.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Flow-m3/Day (MGD)
Total Suspended Solids
Oil and Grease
Copper, Total
Iron, Total
Phosphorus as P
Chemical Oxygen Demand 4_/
Additional Monitoring
Discharge Limitations
Other Units (mg/1)
kg (Ibs) per (except as noted)
batch Daily Avg Daily Max
N/A
2/
y
21
I/
21
27
Monitoring Requirements
N/A
30
15
1.0
1.0
N/A
N/A
See Part
N/A
100
20
1.0
1.0
1.0 3/
N/A
III.C.
Measurement
Frequency
Daily
I/Day
I/Day
I/Day
I/Day
I/Day
I/Day
I/batch
Sample
Type
Pump hour meter
24-hour composite
3-grab composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
I
Metal cleaning wastes shall mean any cleaning compounds, rinse waters (including water wash operations), or any
other waterborne residues derived from cleaning any metal process equipment including, but not limited to,
boiler tube cleaning, boiler fireside cleaning and air preheater cleaning.
Metal cleaning wastes shall not be combined with other plant wastes for treatment, except for final
neutralization.
Permittee shall notify EPA of any chemicals proposed for use in metal cleaning operations which have not been
previously reported and shall indicate the expected levels of organics, phosphorus and priority pollutants
expected in the discharge from OSN 007. Such notification shall be not less than 90 days prior to use.
Additional limitations and/or monitoring may be required after notification.
The pH shall not be less than N/A standard units nor greater than N/A standard units and shall be monitored by
continuous recorder as provided for OSN 006.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Samples taken incompliance with the monitoring requirements specified above shall be taken at
location(s): Discharge from the sand filter(s) treating metal cleaning wastes prior to combining with any
other waste stream.
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Durine the period beginning on start of discharge and lasting through expiration, ^""t^
the permittee is authorized to discharge from outfall(s) serial numoer^s; _ \_nfl
Units 1 and 2 to OSN 001. (Continued) VTj
I/ Serial number assigned for identification and monitoring purposes.
2/ The total quantity of each pollutant discharged shall be reported. In no case shall the quantity discharged
- exceed the quantity determined by multiplying the volume of the batch of metal cleaning waste generated
times the concentrations noted above [i.e., 3.8 kg (8.3 Ibs) of iron, copper, and phosphorus; 57 kg ( 25 J
Ibl) of oil and grease; and 114 kg (250 Ibs) of total suspended solids per million gallons of metal cleaning
waste generated]. Total volume of wastewater generated and discharged shall be reported.
3/ Applicable to preoperational cleaning wastes and other cleaning wastes with high initial concentration of
phosphorus, if used.
4/ Applicable to any cleaning operation containing organic acids, chelating agents or other compounds with high
oxygen demand.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 008 I/ - Oily Water Collection Basin
effluent to OSN 001.
Such discharges shall be limited and monitored by the permittee as specified below: __,
Effluent Characteristic Discharge Limitations Monitoring Requirements ^
_____ — ^
Daily Avg Daily Max Measurement Sample -•
Frequency Type co
Flow-m3/Day (MGD) N/A N/A Daily Pump hour meter
Total Suspended Solids (mg/1) 30 100 2/week 3-grab composite
Oil and Grease (mg/1) 15 20 2/week 3-grab composite
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored
2/week on a grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Basin effluent prior to mixing with any other waste source.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through expiration,
the permittee is authorized to discharge from outfall(s) serial number(s) 009 - Solid Waste Runoff
Sedimentation Pond overflow to Browns Creek.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations Monitoring Requirements
Measurement Sample
Frequency Type
Flow-m3/Day (MGD) N/A During Occurrence Estimate
Monitoring (See Part III.C.) N/A During Occurrence Representative
Discharge to Browns Creek is not permitted except when flow results from a 24-hour rainfall event with a
probable recurrence interval of once in 10 years (10Q24) or greater. All periods of discharge shall be
reported.
Any runoff settling pond shall be capable of containing the 10Q24 rainfall event from all tributary areas plus
all accumulated silt. Not less than once per quarter, permittee shall ascertain that available settling
volume meets this requirement and shall report this finding when submitting Discharge Monitoring Reports.
The pH shall be monitored during discharge by representative grab samples.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following ^^^
location(s): Solid Waste Sedimentation Pond overflow. |? $ *
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge from OSN 005 or 006, whichever occurs earlier, and lasting
through expiration, the permittee shall monitor serial number 010 \J - Plant Intake from Northside Discharge
Channel.
Characteristic
Flow-m3/Day (MGD)
Total Residual Oxidants (mg/1)
Aluminum, total
Arsenic, total
Chromium, total
Copper, total
Cyanide, total
Iron, total
Lead, total
Mercury, total
Nickel, total
Selenium, total
Silver, total
Zinc, total
Monitoring Requirements
Measurement
Frequency
Daily
I/week
y
21
2/
21
y
21
1.1
21
21
21
y
21
Sample
Type
Pump Logs
Multiple grabs through-
out the day
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
24-hour composite
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Plant Intake.
I/ Serial number assigned for identification and monitoring purposes.
2] Once per week starting 90 days after commercial start-up for three months, two per month for the next six
months and once per month thereafter. All data shall be submitted monthly during the period of once per
week sampling (and summarized quarterly in DMR's).
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Part I
MAY 2 8 1982 page 1-16
Permit No. FL0037869
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent limitations
specified for discharge in accordance with tha following schedule:
a. Achieve effluent limitations (001-009) - on start of discharge
b. Excess volume control Report (004) - 12 months prior to commercial
operation date of Unit 1
c. Flow Reports (Part III.D.)
(1) First report - 15 months after commercial operation date of Unit 1
(2) Second report - 15 months after commercial operation date of Unit 2
d. Priority Pollutant Data (Part III.K.) - Submit by 12 nuntns after
commericial operation date of Unit 1
e. Archaeological Resources Mitigation Plan (Part III.N.)
(1) Submit within 30 days of Permit issuance
f. Long-term Solid Waste Management Plan (Part III.O.)
(1) Submit 90 days prior to preparation of any solid waste disposal
areas outside previously identified bottom ash pond area.
g. FGD System Water Supply Assessment (part III.R.)
(1) Report - submit assessment 180 days after determination that gypsum
is not saleable (if such determination is ever necessary).
h. Groundwater Monitoring Program (Part III.S.)
(1) implement - 12 months prior to commercial operation date of Unit 1
following program approval
(2) Reports - Quarterly with DMR's
i. Effluent Toxicity Test and Mercury Bio-concentration Monitoring Program
(Parts III.T.and V.)
(1) Detailed Study Plan - submit six months prior to commercial
operation date of Unit 1
(2) Implement - commercial operation date of Unit 1
(3) Reports
(a) flow-through tests - quarterly with DMR's
(b) static tests - quarterly with DMR's
j. Salt Drift Monitoring Program (part III.U.)
(1) Study plan - submit six months prior to implementation date
(2) implement - one year prior to operation of first cooling tower
(3) Reports - quarterly with DMR's
k. FGD Wastewater Monitoring (Part III.V.)
(1) Implement - 90 days after commerical start-up
(2) Reports - submitted monthly for first three months of monitoring,
thereafter with DMR's quarterly
(3) FGD technology assessment - annually with first report due 12/31/83.
2. No later than 14 calendar days following a date identified in the above
schedule of compliance, the permittee shall submit either a report of
progress or, in the case of specific actions being required by identified
dates, a written notice of compliance or noncompliance. In the latter case,
the notice shall include the cause of noncompliance, and remedial actions
taken, and the probability of meeting the next scheduled requirement.
-------
2 8 Z p.g« ii-s
Signed copies of these, and all other reports required herein, shall
be submitted to the Permit Issuing Authority at the following
address(es):
Water Permits Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
3. Test Procedures
Test procedures for the analysis of pollutants shall conform to all
regulations published pursuant to Section 304(h) of the Clean Water
Act, as amended (40 CFR 136, "Guidelines Establishing Test Procedures
for the Analysis of Pollutants").
4. Recording of Results
For each measurement or sample taken pursuant to the requirements
of this permit, the permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. The person(s) who obtained the samples or measurements;
c. The dates the analyses were performed;
d. The person(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of all required analyses.
5. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s)
designated herein more frequently than required by this permit,
using approved analytical methods as specified above, the results
of such monitoring shall be included in the calculation and reporting
of the values required in the Discharge Monitoring Report Form
(EPA No. 3320-1). Such increased frequency shall also be indicated.
NOTE: WITH THE EXCEPTION OF THE CORRECTION NOTED ABOVE,
NO CORRECTIONS HAVE BEEN MADE TO PART II AS
INCLUDED IN THE DRAFT SAR/EIS, AND ARE NOT
REPRODUCED AGAIN HEREIN.
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I
PART III
Page III-l
MAY 28 I382 Permit No. FL0037869
OTHER REQUIREMENTS
A. No equipment containing polychlorinated biphenyl compounds shall be
placed on site.
B. The instantaneous zone of thermal mixing for the cooling system shall not
exceed an area of 17 acres. The temperature at the point of discharge
into the St. Johns River shall not be greater than 105 degrees F. The
temperature of the water at the edge of the mixing zone shall not exceed
the limitations of Paragraph 17-3.05(l)(d).
C. Additional monitoring shall include: total, dissolved, settleable and
suspended solids; and total aluminum, arsenic, chromium, copper, iron,
lead, mercury, nickel, selenium, silver and zinc.
D. Subsequent to commercial operation dates of Units 1 and 2, respectively,
the permittee shall conduct a detailed evaluation of actual water use and
in-plant waste discharge to confirm design flow data. Reports of this
evaluation shall cover a one-year period after start-up of each unit and
shall be submitted not later than 15 months after commercial operation
date of each unit. In the event that actual flow data are significantly
different from design data, permit may be modified by the Director, Water tt
Management Division. H
E. Permittee shall institute an evaluation of waste sources which contain or
potentially contain high concentrations of oil and grease and by
administrative procedure of facility construction shall remove oil and
grease from such streams as close to the source as possible. Routine .
evaluation and sampling of oil separator effluents shall be included in
this program.
F. Permittee shall maintain or obtain records of rainfall representative of
plant site conditions. All periods of rainfall which exceed the 10-year,
24-hour event shall be reported to EPA.
G. No direct discharge from any solid waste storage area to waters of the
U.S. is permitted by this Authorization to Discharge without prior
approval by the Director, Water Management Division, except as provided
for OSN 009.
H. No direct discharge from the Blount Island Coal Handling Facility is
permitted by this Authorization to Discharge.
I. All periods of bypass of the Central Wastewater Treatment Facility from
the Flow Splitter Box which result in a discharge to waters of the U.S.
shall be reported and sampling of the Pump Sump discharge shall include
all parameters noted in Part III.C, plus pH range. Written reports of
such bypass shall be submitted monthly, except as required by Part
II.A.3.C.
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PART III
Page III-2
MAY 2 8 1982 Permit No. FL0037869
J. In accordance with Section 306(d) of the Clean Water Act (33 USC Section
1251, et seq.) effluent limitations based on standards of performance
contained in this permit shall not be made any more stringent during a
ten year period beginning on the date of completion of such construction
or during the period of depreciation or amortization of such facility
for the purposes of Section 167 or 169 (or both) of the Internal Revenue
Code of 1954, whichever period ends first. The provisions of Section
306(d) do not limit the authority of the Environmental Protection Agency
to modify the permit to require compliance with a toxic effluent
limitation promulgated under BAT or toxic pollutant standard established
under Section 307(a) of the Clean Water Act, or to modify, as necessary,
to assure compliance with any applicable state water quality standard.
If an applicable standard or limitation is promulgated under Sections
301(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) and that effluent
standard or limitation is more stringent than any effluent limitation in
this permit or controls a pollutant not limited in this permit, this
permit shall be promptly modified or revoked and reissued to conform to
that effluent standard or limitation.
K. Not more than 12 months after the Commercial Operation Date of Unit 1,
Permittee shall submit representative data as included in 40 CFR Part
122.53 (d)(7)(ii), (iii) and (iv). In the event that any pollutant is
present at an unacceptable level, this permit shall be modified, or
alternatively, revoked and reissued, to comply with any applicable
provisions of the Clean Water Act.
L. No herbicides shall be used in the initial clearing
operations of transmission line rights of way (ROW).
Thereafter the use of herbicides for maintenance shall be
minimized and shall be used in strict accordance with
EPA-approved products and procedures.
M. During ROW clearing operations and transmission line tower
construction, an undisturbed 7.6 meters (25 feet) wide I
buffer shall be maintained adjacent to all streams, rivers
or lakes. Within this zone, selective topping of trees or
removal of conflict trees which topping would otherwise
kill is allowable but is to be done without disturbance of
the root mat.
N. Impacts to the designated St. Johns River Power Park
Archaeological District shall be mitigated by the
permittee in accordance with the Memorandum of Agreement
(MOA) between the Advisory Council on Historic
Preservation, the State Historic Preservation Officer and
the EPA. The mitigation plan, required from the permittee
by the MOA, shall be submitted to EPA within 30 days after
issuance of this permit. No construction or related
activities are to occur within 200 meters of any
identified archaeological site pending EPA approval of the
mitigation plan.*
*MOA appended to Final EIS
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. „ __ .;r, PART III
ir5" I Page IIT"3
*
ThP nermittee shall implement a 5-year program to test
waste disposal area. Failure to demonstrate that
solid waste disposal areas
h—vear period m M-«-«»iiv- «.f- *• — -> . v.i_
disposed in this area not underlain by an impermeable
?ine? shall utilize at a minimum physical stabilization
anS compaction of wastes and soils to control leaching.
Sisnosaf area "B", north of Island Drive, shall be
utSzed prior to clearing and utilization of disposal
area "A".
Q. An undisturbed buffer zone approximately 61 meters (200
feet) in width shall be maintained between all
construction activity areas and on-site wetlands
contiguous with the St. Johns River or its tributaries for
?he operational life of the plant. The buffer zone is to
be defined by placement of a fence on the upland lir^T o£
this buffer zone as depicted on Figure 3 of the Final
Eis! The buffer zone shall exist along the external
southeast side of the plant rail loop. Additional fencing
Shall be provided along the full length of the property
fronting both sides of Island Drive and Portions of tne
northwest corner of the site (Figure 3) to reduce
SJsturbance of upland wildlife habitat until these areas
are needed for plant operations.
R The use of groundwater from the wellfield for plant
service water for SJRPP shall be minimized to the greatest
extent practicable but in no case shall it exceed .33 |
m3/sec (7.6 mgd) on a maximum daily basis or .22 •
m3/sec (5.1 mgd) on an average basis. If it is «
Determined that the FGD sludge can not be economically
marketed as a gypsum product, the permittee shall assess £
tSe feasibility of using non-potable alternate water
supplies to replace high quality groundwater in •"uober
operation. The assessment is to be submitted to the EPA
and must include specific water quality requirements of
the scrubbers and levels of corrosive constituents in
alternative water supplies.
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WAV 2 8 1932
PART m
Pa8e m
Pennlt No. FL0037869
T.
S' ™8^* C°nSi!al,tft*0n -With and aPP«>val from EPA, the -
permittee shall institute a groundwater monitoring program^
^f»4-°*^1:i"^^d in the state °f Florida, Conditions of
gl£tifi£ation, sections II. B.2 and III. G. "ItoHthly data'B
shall be submitted quarterly to EPA commencing one year
prior to commercial operation of Unit 1.
An aquatic toxicity test program shall be performed on the
combined NGS/SJRPP discharge effluent (NPDES 001)i
commencing at the start of commercial operation of Unit
l. A detailed study plan must be submitted for EPA' s
review and approval at least 6 months prior to initiation
*T v, ^OX1Cltv tests' Test methodology should be that
published in the EPA 600/4-78-012 entitled "Methods for
Measuring the Acute Toxicity of Effluents to Aquatic
Organisms . Appropriate indigenous species are to be used
for the tests. Quarterly 96-hour continuous flow-through
tests are to be conducted for the first year of plant
operation. Static 48-hour definitive tests are to be
conducted on the months in which quarterly flow-through
tests are not being conducted. Based on the first full
year s testing data, EPA will determine the type and
frequency of testing necessary for the duration of the
permit.
U. The permittee shall perform a salt drift monitoring
program of the SJRPP cooling towers beginning one yea?
prior to operation of the first cooling tower. A detailed
monitoring plan must be submitted at least six months
prior to initiation to EPA for review and aoproval.
Monitoring reports shall be submitted with the quarterly
Discharge Monitoring Reports. The program shall include
calculated tower drift emission rates, measured ground
level deposition rates and measures of biological impact.
Monitoring shall be conducted at least 18 months following
operation of^ the second tower. if the reports indicate
significant impacts are occurring to the nearby area, the
permittee shall consult with EPA and shall initiate
reasonable corrective measures acceptable to EPA to
mitigate these impacts. If the reports indicate no
significant impacts are occurring to the nearby area, the
permittee may seek approval of EPA to reduce or eliminate
the drift monitoring program.
V. The permittee shall monitor the untreated blowdown and
washdown wastewaters from the FGD system. Waste stream
parameters to be monitored are: flow, discharge frequency
of washdown wastewater, and total mercury. Once per week
monitoring shall begin 90 days after commercial operation
for three months, two per month for the next six months
and thereafter reduced to once per month. Permittee may
petition for termination of monitoring after two years of
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PART III
Page III-5
Permit No, FL0037869
operational data are obtained. Also, the permittee shall
annually evaluate available data on raw and treated waste
characteristics of blowdown and washdown wastes of FGD
systems similar to that proposed for the SJRPP; and shall
evaluate available control and treatment technologies to
reduce discharge of heavy metals, with particular emphasis
on mercury. Permittee shall report the results of such
evaluations annually for three years with the first report
due on December 31, 1983. Plant design for the SJRPP
shall include capability to provide segregation of FGD
wastewaters for greater treatment than presently proposed
if the Director, Water Management Division determines that
such ultimate treatment is warranted to protect the St.
Johns River fishery. Permittee shall assess the
bio-concentration of mercury present in plant discharge
001. Analyses shall be performed on edible portions of
indigenous fish and invertebrate organisms sampled within
the 31 acre mixing zone and compared to control samples
from outside the mixing zone. Assessment will run
concurrent with the effluent toxicity test requirement
(Part III. T.) Detailed procedures shall be included in
the toxicity test study plan submitted to EPA.
W. If the permittee, after monitoring for a least 18 months, determines
that he is consistently meeting the effluent limits contained herein,
the permittee may request of the Director, Water Management Division
that the monitoring requirements be reduced to a lesser frequency or be
eliminated.
X. The Florida Department of Environmental Regulation has certified the
discharge(s) covered by this permit with conditions (see Attachment B).
Section 401 of the Act requires that conditions of certification shall
become a condition of the permit. The monitoring and sampling shall be
as indicated for those parameters Included in the certification. Any
effluent limits, and any additional requirements, specified in the
attached state certification which are more stringent supersede any less
stringent effluent limits provided herein. During any time period in
which the more stringent state certification effluent limits are stayed
or inoperable, the effluent limits provided herein shall be in effect
and fully enforceable.
I
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Attachment A
Permit No. FL0037869
JL3L.
1
fel
K
8
I!
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Permit NO. FL0037869
STATE OF FLORIDA 401 CERTIFICATION
To be provided prior to permit issuance.
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PERMIT RATIONALE
ST. JOHNS RIVER POWER PARK
UNITS 1 AND 2
JACKSONVILLE ELECTRIC AUTHORITY
MAY aS 1982 8
I. Applicable Regulations
A. Federal performance standards for new sources for the steam
electric power generating point source category (40 CFR 423) as
promulgated on October 8, 1974, and with proposed revisions flj
published on October 14, 1980. (See Environmental Impact
Statement (EIS) Table 4.3-1)
B. Florida Water Quality Standards, Chapters 17-3 and 17-4, Florida
Administrative Code. (See EIS Table 3.2-1). The receiving
waters are classified as Class III - Recreation - Propagation
and Management of Fish and Wildlife - Surface Waters.
II. Effluent Limitations
A. Outfall Serial Number (OSN) 001 - Main Plant Discharge to the
Northslde Generating Station Discharge Channel).
1. Temperature: A maximum 24-hour average discharge
temperature of 35.6°C (96.0°F) is included based on the •
application and supporting information. A mixing zone ^
consistent with Northside discharges is included in Part
III.B.
2. Total residual oxidants* (total residual chlorine):
Limitation of 0.10 mg/1 is based on Florida Water Quality
Standards (17-4.244(4)). This section precludes a maximum
pollutant concentration within an assigned mixing zone
which exceeds the amount lethal to 50 percent of the test
organisms in 96 hours (96-hr LC50) for a species
significant to the indigenous aquatic community. The
96-hr LC50 value for Blue Crab of 0.10 mg/1 has been used
to establish the effluent limit.
3. Copper: Limitation of 0.18 mg/1 is based on Florida Wate
Quality Standards [17-4.244(4)], as in the proceeding
paragraph for total residual oxidants. The species used
was Capitella capitata, a polychaete worm.
1
In salt water, addition of chlorine produces a rapid oxidation
of iodine, bromine and other chemicals as it is converted to
chloride. Therefore, in salt water systems, proper reference is
to total residual oxidants (TRO) rather than total residual
chlorine. The analysis method is unchanged.
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-2-
B. OSN 002 - Runoff Sedimentation Control Pond discharge to Browns
Creek (includes construction and yard drainage, effluent from
Concrete Truck Washing Settling Pond, effluent from dewatering •
activities and Sanitary Wastewater Treatment Facility effluent). J|
1. Oil and Grease, Total Residual Chlorine and pH:
Limitations are from Chapter 17-3.061 and -3.121 Florida
Administrative Code.
2. Total Suspended Solids: Limitation is derived as a best
professional judgement to protect sensitive benthic
organisms in Browns Creek. See EIS for further
discussions.
C. OSN 003 - Sanitary Wastewater Treatment Facility effluent.
Limitations are generally based on secondary treatment
requirements (40 CFR Part 102) for domestic waste. However, the
one-day maximum limitation of 60 mg/1 each for total suspended
solids and biochemical oxygen demand (BOD) proposed is
extrapolated from the seven-day average limitation of 45 mg/1
presented in the regulations. This extrapolation was made to
conform with the proposed monitoring frequency.
D. OSN 004 and 009 - Coal Pile Runoff Sedimentation Pond overflow
and Solid Waste Runoff Sedimentation Pond overflow,
respectively, to Browns Creek. Overflows occur only during high
intensity rainfall periods and requirements are based on best
professional judgement.
E. OSN 005 - Cooling Tower Slowdown. Limitations are as required
by promulgated 423.15(i) and (j), with proposed 423.15(j) and
(k) requirements included as a best professional judgement for
control of toxic and priority pollutants. A limitation of 1.5
cycles of concentration is included as a condition of the
variance to Florida Water Quality Standards Criteria (see Part
II.F.4 hereinafter). At the time of the Draft EIS, concern was
expressed with the ability of the applicant to comply with
effluent limitations in the Draft NPDES Permit. The applicant
has submitted results of mathematical modeling of the cooling
system which indicates that total residual oxidants resulting
from system chlorination will not be discharged for more than
two hours per day per cooling tower. The die-away coefficients
and other aspects of the model, however, have not been verified
by field measurements in a salt water cooling tower system. The
EPA staff remains concerned with the applicant's ability to
comply with permit conditions for TRO in the cooling tower
blowdown without added controls. The applicant proposes to
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-3-
to install a mechanical cleaning system for the condensers which
will reduce the need for chlorine addition to that portion of
the cooling system. Additionally, dechlorination techniques
have been demonstrated elsewhere, and can be used by the
applicant, if necessary. Since the applicant has expressed his
commitment to comply with NPDES conditions and limitations, a
specific requirement to provide dechlorination facilities has
not been included in the Proposed NPDES Permit.
F. OSN 006 - Central Wastewater Treatment Facility effluent.
1. Limitations are as required by promulgated 423.15(c) for
low volume wastes and 423.45 for coal pile runoff and
proposed 423.15(c) and 423.15(1) and (m), respectively.
2. Concentration limitations:
a. Total Suspended Solids: Thirty-day average ("daily
average") and 24-hour average ("daily maximum")
values of 30 and 50 mg/1, respectively, have been
included due to the combination of low volume waste
and coal pile runoff (and other area runoff) for
treatment in the Central Wastewater Treatment
facility. Guideline limitations are 30 mg/1 as a
daily average and 100 mg/1 as a daily maximum for
low volume wastes. Limitations for coal pile
runoff, however, is "not to exceed" 50 mg/1 (i.e.,
or Instantaneous maximum). Therefore, since
monitoring is to be by 24-hour composite, 30 mg/1
has been selected as a best professional judgement
for a daily average limitation for combined wastes
and 50 mg/1 for the daily maximum limitation.
b. Oil and grease limitations: Daily average and daily
maximum values of 10 and 15 mg/1, respectively, have
been included since there is no allowance for oil
and grease in coal pile and area runoff while low
volume wastes are limited to 15 and 20 mg/1,
respectively. Limitations are based on a reduction
in concentration which is approximately proportional
to pump design capacities:
15 or 20 mg/1 times 2400 divided by 3400
Where 2400 gpm is the Flow Equalization Pond pump
capacity and 3400 gpm is the combined capacity of
the Flow Equalization Pond and Coal Pile Runoff
Sedimentation Pond pumps (See Attachment A to the
Proposed NPDES Permit).
i^W
I
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-4-
3.
Quantity limitations:
following formula:
Calculations are based on the
Pounds per day • mg/1 x MGD x 8.345
Where, 8.345 is the appropriate conversion factor
0.454 pound/day - 1.0 kilogram/day (kg/day)
MGD - Million gallons per day - gpm x 0.00144
Flows MGD (gpm) --
Plow Equalization Pond (Low Volume Wastes)
Coal Pile Runoff Sedimentation Pond
Total
One Unit
0.79(547)
0.34(235)
1.13(782)
Total Suspended Solids - Daily Average @ 30 mg/1
Kg/day (Ib/day) ^n^SO)
Use in Permit 130(280)
Two Units
1.58(1094)
0.34 (235)
1.91(1329)
217(479)
220(480)
Total Suspended Solids - Daily Maximum: Low Volume g 100 mg/1 and Coal
£)dav\lb/day) 362(799) 660(1456)
Si In Permit 360(800* 660(1460>
Oil and Grease - Daily Aver.gj. @ 15 mg/1 for Flow^qualization^Pond Only
Kg/day (Ib/day)
Use in Permit
I
Oil and Grease - Pail:
Kg/day (Ib/day)
Use in Permit
Average @ 20 mg/1 for Flow Equalization Pond Only
a 60(131) 119(263)
60(130) 120(260)
Quantity limitations were obtained by multiplying the
expected maximum monthly average flows by the
concentrations as indicated above. This procedure is
typical of how effluent limitations are generally
developed for permits for other industrial categories in
Region IV and has been used for other power plants.
Effluent Guideline requirements for steam-electric
generating facilities (40 CFR 423) are typically stated in
the format "the quantity of pollutants discharged from low
volume waste sources shall not exceed the quantity
determined by multiplying the flow of low volume waste^
sources times the concentration in the following table
(i.e., TSS 100 mg/1 as a maximum for any day and 30 mg/1
as an average of daily values for thirty consecutive
days). Based on this phraseology, the applicant has
requested that daily maximum limitations be derived on the
basis of 100 mg/1 TSS (20 mg/1 of 0 & G) times the maximum
During periods when runoff, necessitates- pulping a,t the rate of 1QOQ gpm
for 24 hours during this.- period fronj the. coal pile runoff sedimentation
pond, this limitation -ma,^ b'.e increased ty 21Q.C46.03.,
I
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-5-
pump capacity for low volume wastes and 50 mg/1 TSS times
the maximum pump capacity for coal pile runoff. This
suggestion has not been taken as it is inconsistent with
permitting of other industrial categories in Region IV.
The basis for our best professional judgement is contained
in 40 CFR 122.63(b). This section states in part,
"...calculation of any permit limitations which are
based on production (or other measure of operation) shall
be based not upon the designed production capacity but
rather upon a reasonable measure of actual production of
the facility, such as the production during the high month
of the previous year, or the monthly average for the
highest of the previous 5 years...". The preamble (page
33342) in discussing Part 122.63(b) states, "...For
example permit limits usually are written for a maximum
daily discharge, and an average monthly discharge which is
usually lower by a factor of 1.5 or 2. Therefore, a
one-month production figure should be used to calculate
the average monthly discharge limitation, or a one day
production to calculate the maximum daily limitation."
Such calculations are based on a constant quantity factor
(i.e., so many pounds of TSS per ton of product) times a
single variable (i.e., ton of product per day or month).
In the case of the steam-electric category, the constant
factor used is the estimated high monthly average flow and
the variable is the guideline concentration factor (i.e.,
30 and 100 mg/1 TSS). Where the preamble addresses a
factor of 1.5 or 2 as reasonable, the Proposed NPDES
Permit allows a factor of 3.0 between daily maximum and
daily average TSS (1460 divided by 480 Ibs/day for two
units).
Although calculations for maximum quantity limitations
have not been increased to the extent requested by the
applicanti it is recognized that during periods of high
intensity rainfall, pumping at the rate of 1000 gpm for 24
hours will be necessary. Therefore, permit conditions allov
for an increase of 210 Kg/day (460 Ib/day) during such
conditions; i.e., (lOOOgpra - 235 gpm) at 50 mg/1.
Variance. Ambient levels of several parameters exceed
Florida Water Quality Standards Criteria in the St. Johns
River. Therefore, the addition of any of these pollutants
(or concentration by the cooling towers), regardless of
how little the concentration exceeds the ambient level
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-6-
and/or the State Criterion, would technically violate the
Water Quality Standards. The applicant has requested a
variance to certain criteria and a mixing zone for
others. The Staff of the State of Florida has proposed to
grant variances for aluminum, copper, iron, mercury and
silver (Chapter 17-3.121, Florida Administrative Code) and
for oil and grease (Chapter 17-3.061, F.A.C.) but only at
such times as the natural background levels of the St.
Johns River approach or exceed those standards. The
variances for mercury, copper, and silver are only for a
period of two years from commencement of commercial
operation, but are subject to extention based on ambient
and effluent monitoring, and on bioassays to be performed
for copper, mercury, and total residual chlorine. EPA
staff has reviewed the proposed State actions.
Limitations on aluminum, copper, iron, mercury, and silver
have also been included in the Proposed NPDES Permit as a
condition of the Variance and of Permit issurance.
Additional information on ambient conditions, expected
effluent quality and variance discussions is included in
the Draft State Analysis Report/Environmental Impact
Statement. Also see response to written comment W-17,
Section 3.2 of the Final EIS.
G. OSN 007 - Metal Cleaning Wastes. Limitations are as required by
Promulgated 423.15(f) and proposed 423.15(d), except that a best
professional judgement limitation for phosphorus has been
included.
H. OSN 008 - Oily Waste Collection Basin Effluent. Limitations are
as required for promulgated and proposed 423.15(c) for low
volume wastes. Quantity limitations have not been included due
to the highly variable nature of the area runoff flows.
I. Boiler Slowdown. Promulgated 423.15(g) provides specific
limitations for boiler blowdown; however, proposed 423.11(b)
would include boiler blowdown in the low volume waste category
(423.15(c)). Since boiler blowdown is to be reused as makeup to
the flue gas desulfurization system, a best professional
judgement is proposed which would not require separate
limitations and monitoring requirements for boiler blowdown.
III. Proposed Permit Period: Five years. The Proposed NPDES Permit
requires compliance with the most stringent requirements of either the
promulgated (October 8, 1974) or proposed (October 14, 1980) standards
of performance for new sources (40 CFR 423). Data on "priority
pollutants" can not be collected from waste sources since the plant is
not yet in operation. Evaluation of expected effluent quality
I
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-7-
submitted by the applicant and data submitted by other utilities for
operating power plants in Region IV have led the permit writer to the
tentative conclusion that additional treatment for priority pollutants
is not likely for any pollutants (other than oxidants (chlorine) as
described above) and that a full five-year permit should be issued.
However, to assure that this judgement is correct, the permittee will
be required to submit priority pollutant data not later than one year
after the commercial operation date of Unit 1. Additionally, a
reopener clause is included in the permit (Part III.K.) in the event
that excessive levels of priority pollutants are found. A further
reopener clause (Part III.J.) has been included in the event that
requirements more stringent than those proposed on October 14, 1980,
are ultimately promulgated.
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APPENDIX 6.2
FDER CONDITIONS OF CERTIFICATION
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State of Florida Department of Environmental Regulation
Jacksonville Electric Authority
SJRPP Units 1 & 2
PA 81-13
CONDITIONS OF CERTIFICATION
Table of Contents
Page
I. Ai r 1
A. Emission Limitations 1
B. Air Monitoring Program 3
C. Stack Testing - 4 •
D. Reporting 5
E. Operating Restrictions 6
II. Water Discharges 6
A. Plant Effluents and Receiving Body of Water 6
1. Receiving Body of Water (RBW) 6
2. Point of Discharge (P.O.D.) 7
3. Thermal Mixing Zone 7
4. Chemical Wastes 7
5. Coal Pile 7
6. Chlorine 7
7. pH 8
8. PoJ^chlorinated Biphenyl Compounds 8
9. Combined Low Volume Wastes and
Coal Pile Runoff 8
10. Metal Cleaning 8
11. Solid Waste and Limestone Storage Areas 9
12. Storm Water Runoff 9
13. Coal Unloading Facility Percolation Pond
Overflow 9
14. Mixing Zones 9
15. Variances to Water Quality Standards 10
16. Effluent Limitations 10
B. Water Monitoring Programs 11
1. Chemical Monitoring 11
2. Groundwater Monitoring 13
III. Groundwater 13
A. General 13
B. Well Criteria 13
C. Well Withdrawal Limits 14
D. Water Use Restriction 14
E. Emergency Shortages 14
F. Monitoring and Reporting 14
G. Shallow Aquifer Monitoring Wells 16
H. Leachate 17
1. Zone of Dishcarge 17
2. Corrective Action 17
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IV. Control Measures During Construction 17
A. Stormwater Runoff ''
B. Sanitary Wastes \7
C. Environmental Control Program ]«
V ?AT/.°,nsruction Dewatei"ing Effluent g
v- Solid Wastes Iy
VI. Operation Safeguards J-j
VII. Screening 20
VIII. Potable Water Supply System ™
X Tnv?r nT*3nd Electric Switching Gear %
XI p«n Jf D(r eterious> or Hazardous Materials ?Q
XI. Construction in Waters of the State on
A. Title 'u
B. Turbidity 20
C. Variances 21
D. Mixing Zones 21
XII. Solid Waste Landfill 2]
XIII. Transmission Lines lz
A. General 23
B. Other Construction Activities l\
C. Maintenance "
D. Archaeological Sites —
E. Road Crossing ^°
F. Emergency Reporting £?
S. Final Right-of-Way Location £
YTW 5: Compliance 26
XIV. Change in Discharge *°
XV. Non-Compliance Notification ?°
AVI Facilities Operation • ^;
XVII. Adverse Impact 27
XVIII. Right of Entry 27
XIX. Revocation or Suspension ?7
JX. Civil and Criminal Liability ,«
XXI. Property Rights "
XXII. Severabilitv 28
XXIII. Definitions 28
2e!"!ew of S1te Certification H
Modification of Conditions ^
Jlood Control Protection ^
nffSCt °f Certification II
II. Noise ^9
XXIX Archaeological Sites ^
XXX. . Blount Island Coal Unloading Facility 30
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State of Florida Department of Environmental Regulation
Jacksonville Electric Authority
SJRPP Units 1 & 2
PA 81-13
CONDITIONS OF CERTIFICATION
I. Air
The construction^and operation of SJRPP Units 1 & 2 at the
Jacksonville steam electric power plant site shall be in accordance
with all applicable provisions of Chapters 17-2, 17-4, 17-5 and 17-
7, Florida Administrative Code. In addition to the foregoing, the
permittee shall comply with the following conditions of certifi-
cation:
A. Emission Limitations
1. Based on a maximum heat input of 6,144 million BTU per
hour, stack emissions from SJRPP Unit 1 & 2 shall not
exceed the following when burning coal:
a. S02 - 1.2 Ib. per million BTU heat input, maximum
two hour average, 0.76 Ib/MMBtu on a 30-day rolling
average.
b. NOX - 0.60 Ib. per million BTU heat input.
c. Particulates - 0.03 Ib. per million BTU heat input.
d. Visible emissions - 20% (6-minute average), except
one 6-minute period per hour of not more than 27%
opacity.
2. The height of the boiler exhaust stack for SJRPP Unit 1 &
2 shall not be less than 640 ft. above grade.
3. Particulate emissions from the coal handling facilities:
a. The permittee shall not cause to be discharged into
the atmosphere from any coal processing or conveying
equipment, coal storage system or coal transfer and
loading system processing coal, visible emissions
which exceed TO. percent opacity. Particulate
emissions shall be controlled by use of control
devices.
b. The permittee must submit to the Department within
thirty (30) days after it becomes available, copies
of technical data pertaining to the selected par-
ti culate emissions control for the coal handling
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facility. These data should include, but not be
limited to, guaranteed efficiency and emission
rates, and major design parameters such as air/-
cloth ratio and flow rate. The Department may, upon
review of these data, disapprove the use of any such
device if the Department determines the selected
control device to be inadequate to meet the emission
limits specified in 3(a) above. Such disapproval
shall be issued within 30 days of receipt of the
technical data.
4. Particulate emissions from limestone and flyash handling
shall not exceed the following:
a. Limestone silos - 0.050 Ib/hr.
b. Limestone hopper/transfer conveyors - 0.65 Ib/hr.
c. Flyash handling system - 0.2 Ib/hr.
5. Visible emissions from the following facilities shall be
limited to 10% opacity: (a) limestone and flyash handling
system, (b) limestone day silos and (c) flyash silos.
6. Compliance with opacity limits of the facilities listed
in Condition 5 will be determined by EPA reference method
9 (Appendix A, 40 CFR 60).
7. Construction shall reasonably conform to the plans and
schedule given in the application.
8. The permittee shall report any delays in construction and
completion of the project which would delay commercial
operation by more than 90 days to the Department's St.
Johns River Subdistrict Office.-
9. Reasonable precautions to prevent fugitive particulate
emissions during construction, such as coating of roads
and construction sites used by contractors, regrassing or
watering areas of disturbed soils, will be taken by the
permittee.
10. Coal shall not be burned in the units unless both electro-
static precipitator and limestone scrubber are operating
properly except as provided under 40 CFR Part 60 Subpart
Da.
11. The two auxiliary boilers shall fire No. 2 fuel oil with
a maximum sulfur content of 0.76 percent by weight, a
maximum ash content of 0.01 percent by weight, an ap-
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proximate heating value of 19,500 Btu per pound and a
maximum viscosity of 3.6 centistokes at 100° F. Samples
of all fuel oil fired in the boilers shall be taken and
analyzed for sulfur content, ash content, heating value
and viscosity. Accordingly, samples shall be taken of
each fuel oil shipment received. Records of the analyses
shall be kept a minimum of the two years to be available
for FDER's inspection.
12. The same quality No. 2 fuel oil, used for the auxiliary
boilers, shall be used for the main boilers Units 1 and
2 during start-up and low load operation.
13. Maximum emissions from either of the auxiliary boilers
shall be limited to 0.8 Ib/MMBTU for S02, 0.1 Ib/MMBTU
for P.M., and 20% opacity for visible emissions.
14. Coal fired in Units 1 and 2 shall have an ash content not
to exceed 18% and a sulfur content not to exceed 4% by
weight. Coal sulfur content shall be determined and
recorded in accordance with 40 CFR 60.47a.
15. No fraction of flue gas shall be allowed to bypass the
FGD system to reheat the gases existing from the FGD
system, if the bypass will cause overall S0? removal
efficiency less than 90 percent si£ as otherwise provided
in 40 CFR Part 60, Subpart da. The percentage and
amount of flue gas bypassing the FGD system shall be
documented and records kept a minimum of two years
available for FDER's inspection.
16. JEA shall keep records of the frequency, duration, load
and manner of operation of the auxiliary boilers. During
normal operation of the plant the boilers shall not
operate more than seven (7%) percent of the time on an
annual basis without prior approval of the Department.
However, prior to commercial operation and during boiler
start-up, shutdown of the main plant or plant upset, the
auxiliary boilers may be operated more frequently.
B. Air Monitoring Program
1• Tne permittee shall install and operate continuously
monitoring devices for each main boiler exhaust for
sulfur dioxide, nitrogen oxide, carbon monoxide, carbon
dioxide and opacity. The monitoring devices shall meet
the applicable requirements of Section 17-2.710, FAC, and
40 CFR 60.47a. The opacity monitor may be placed in the
duct work between the electrostatic precipitator and the
FGD scrubber.
2- .The permittee or Jacksonville Bio-Environmental
Services Division shall operate two ambient monitoring
devices for sulfur dioxide in accordance with EPA ref-
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erence methods in 40 CFR, Part 53, and two ambient
monitoring devices for suspended particulates. The
monitoring devices shall be specifically located at a
location approved by the Department. The frequency of
operation shall be every six days commencing as specified
' by the Department.
3. The permittee shall maintain a daily log of the
amounts and types of fuel used and copies of fuel anal-
yses containing information on sulfur content, ash
content and heating values.
4. The permittee shall provide stack sampling facil-
ities as required by Rule 17-2.700(4) FAC.
5. The ambient monitoring program may be reviewed by
the Department and the permittee annually after start-up
of Unit 1. The monitoring program may be expanded or
modified as deemed necessary by the Department. Modi-
fications shall be effected in accordance with the pro
visions of Condition XXV.
6. Prior to commercial operation of the source, the
permittee shall submit to the Departement a standardized
plan or procedure that will allow the permittee to mon-
itor emission control equipment efficiency and enable the
permittee to return malfunctioning equipment to proper
operation as expeditiously as possible. The permittee
shall also submit to the Department a plan to monitor
salt drift from the cooling towers and the impact of the
salt drift on vegetation. A salt drift monitoring program
shall be implemented by December 1, 1984.
C. Stack Testing
1. Within 60 calendar days after achieving the maximum
capacity at which each unit will be operated, but no
later than 180 operating days after initial start-up, the
permittee shall conduct performance tests for partic-
ulates S02» N0x» an<^ visible emissions during normal
operations near (±10%) 6144 MMBtu/hr heat input and
furnish the Department a written report of the results of
such performance tests within 45_ days of completion of
the tests. The performance tests will be conducted in
accordance with the provisions of 40 CFR 60.46a, 48a, and
49a.
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2. Performance tests shall be conducted and data
reduced in accordance with methods and procedures out-
lined in Section 17-2.700 FAC.
3. Performance tests shall be conducted under such
conditions as the Department shall specify based on
representative performance of the facility. The per-
mittee shall make available to the Department such
records as may be necessary to determine the conditions
of the performance tests.
4. The permittee shall provide 30 days prior notice of
the performance tests in order to afford the Department
the opportunity to have an observer present.
5. Stack tests for oarticulates NOX and S02 and
visible emissions shall be performed annually in ac-
cordance with conditions C. 2, 3, and 4 above.
D. Reporting
For SJRPP, stack monitoring, fuel usage and fuel
analysis data shall be reported to the Department's St.
John's River Subdistrict Office on a quarterly basis
commencing with the start of commercial operation in
accordance with 40 CFR, Part 60, Section 60.7., and in
accordance with Section 17-2.08, FAC.
Utilizing the SAROAD or other format approved in
writing by the Department, ambient air monitoring data
shall be reported to the Bureau of Air Quality Management
of the Department quarterly. Commencing on the date of
certification, such reports shall be due within 45 days
following the quarterly reporting period.
Beginning one month after certification, the per-
mittee shall submit to the Department a quarterly status
report briefly outlining progress made on engineering
design and purchase of major pieces of air pollution
control equipment. All reports and information required
to be submitted under this condition shall be submitted
to the Administrator of Power Plant Siting, Department of
Environmental Regulation, 2600 Blair Stone Road, Tallahassee,
Florida, 32301.
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E. Operating Restrictions
1. The permittee shall not operate its Southside,
Northside, or Kennedy Generating Station in such a manner
as to cause violation of ambient air quality standards
for S02 when SJRPP is operating.
2. The permittee shall file with the Department, St.
Johns River Subdistrict Office and the Jacksonville Bio-
Environmental Services by June 1, 1934, the SJRPP/JEA
system proposed operating plan and supporting justi-
fication that will include the procedures JEA will follow
to permanently eliminate emissions from steam generating
units equivalent to the impact of the emissions of South-
side Units 1 and 2. The Secretary of the Department
shall indicate the Department's approval or disapproval
within 90 days of receipt. The proposed operating plan
shall also contain proposals for operating during air
pollution episodes pursuant to 17-2.320(3), FAC., in-
cluding use of such alternatives as washed coal at SJRPP.
3. The operating plan shall include retirement of
Southside Units 1 and 2, or equivalent units, cold
storage, construction of tall stacks or other equivalent
programs.
4. The schedule for implementation of the plan shall be
consistent with the startup of SJRPP.
II. Water Discharges
Any discharges into any waters of the State During construc-
tion and operation of SJRPP Units 1 and 2 shall be in accordance
with all applicable provisions of Chapter 17-3, Florida Admin-
istrative Code, and 40 CFR, Part 423, Effluent Guidelines and
Standards for Steam Electric Power Generating Point Source
Category, except as provided herein. Also, the permittee shall
comply with the following conditions of certification:
A. Plant Effluents and Receiving Body of Water
For discharges made from the power plant the following con-
ditions shall apply:
1. Receiving Body of Water (RBW)
The receiving body of water has been determined by
the Department to be those waters of the St. John's River
and any other waters affected which are considered to be
waters of the State within the definition of Chapter 403,
Florida Statutes.
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2. Point of Discharge (P.P.P.)
The point of discharge has been determined by the
Department to be where the effluent physically enters the
waters of the State in the St. Johns River or Browns
Creek.
3. Thermal Mixing Zones
The instantaneous zone of thermal mixing for the
cooling system shall not exceed an area of 17 acres. The
temperature at the point of discharge into the St. John's
River shall not be greater than 105 degrees F. The
temperature of the water at the edge of the mixing zone
shall not exceed the limitations of Paragraph 17-3.05(1)(d).
Cooling tower blowdown shall not exceed 96 F. as a 24
hour average.
4. Chemical Hastes
All discharges of low volume wastes (demineralizer
regeneration, floor drainage, labs drains, FGD blowdown
and similar wastes) and metal cleaning wastes shall
comply with Chapter 17-3. If violations of Chapter 17-3
occur, corrective action shall be taken. These wastes-
waters shall be directed to an adequately sized and
constructed treatment facility.
During periods when treated wastewater does not
comply with pH discharge limitations, the treated waste-
water may be recycled to the coal pile runoff sedimen-
tation pond, except when the sedimentation pond has
insufficient capacity to retain the recycled wastewater
and the runoff from a rainfall event equal to or less
than a ten year, 24 hour storm.
5. Coal Pile
Coal pile runoff shall be directed to the central
wastewater treatment Facility and shall not be directly
discharged to surface waters, except that discharge of
stormwater runoff from the coal pile is allowed only
during periods of high rainfall in excess of the ten
year, 24 hour storm.
6. Chlorine
The concentration of total residual chlorine dis-
charged from Units 1 & 2 and/or Northside Generating
Station shall not exceed 0.1 mg/1 at the POD nor 0.01
mg/1 beyond an instantaneous mixing zone of 17.0 acres.
Chlorine resulting from chlorination of either unit at
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SJRPP shall not be discharged more than two hours per day
and no unit shall be chlorinated simultaneously with any
other unit at SJRPP or at Northside Generating Station.
Levels of free available chlorine shall not exceed 0.5
mg/1 for an instantaneous maximum nor 0.2 mg/1 on a £^,0,
hour average from the blowdown of either cooling tower.
In the event that 40 CFR, Part 423 is revised with
respect to chlorine limitations, such discharge limita-
tions shall apply to cooling tower blowdown. Chlorine
shall not be discharged from the SJRPP during periods
when chlorine is being discharged from any unit at NGS
except if due to cooling tower makeup (from ambient or
from chlorination of NGS)7
7. £H_
The pH of the combined discharges shall be such that
the pH will fall within the range of 6.0 to 9.0.
8. Polychlorinated Biphenyl Compounds
There shall be no net discharge of polychlorinated
biphenyl compounds.
9. Combined Low Volume Wastes and Coal Pile Runoff
The combined low volume wastes and coal pile runoff
shall be treated to control pH, total suspended solids
and toxic metals prior to being discharged. The fol-
lowing effluent limitations will apply:
Effluent Daily Maximum Maximum 30-Day
Daily Average
TSS 50 mg/1* 30 mg/1
Oil and Grease 15 mg/1 10 mg/1
pH 6-9 6-9
The design plans and specifications of the treatment
system shall be submitted to the Department for review
and approval prior to construction. The Department will
indicate approval or disapproval within 45 days.
*100 mg/1 allowed when only low volume wastes are
being treated.
10. Metal Cleaning ~~
Metal cleaning wastes shall be treated as appro-
priate prior to discharge to the cooling water system.
The following effluent limitations shall apply:
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Effluent Daily Maximum Maxim'mum 30-Day
Daily Average
TSS 100 mg/1 30 mg/1
Oil and Grease 20 mg/1 15 mg/1
Iron 1 mg/1
Copper 1 mg/1
11. Solid Waste and Gypsum Storage Areas
There shall be no direct discharge of stormwater
runoff to surface waters from the gypsum storage areas,
nor from the solid waste areas prior to closure with-
out treatment (closure will be as defined in the solid
waste management plan).
12. Storm Water Runoff
During plant operation, necessary measures shall be
used to settle, filter, treat or absorb silt-containing
or pollutant-laden stormwater runoff to limit the sus-
pended solids to 50 mg/1 or less at the POD during rain-
fall periods less than the 10-year, 24-hour rainfall, and
to prevent an increase in turbidity of more than 50
Jackson Turbidity Units above background in waters of the
State.
Control measures shall consist at the minimum of filters,
sediment traps, barriers, berms or vegetative planting.
Exposed or disturbed soil shall be protected as soon as
possible to minimize silt - and sediment-laden runoff.
The pH shall be kept within the range of 6.0 to 8.5 at
the POD.
13. Coal Unloading Facility Percolation Pond Overflow
There shall be no direct discharge to surface waters
from the coal unloading facility wastewater treatment
system percolation pond. Any discharge from the facility
shall be reported to the Department and the Environmental
Protection Agency. The quantity of flow and duration of
flow shall be estimated during such episodes.
14. Mixing Zones
The discharge of the following pollutants shall not
violate the Water Quality Standards of Chapter 17-3, FAC,
beyond the edge of the designated instantaneous mixing
zones as described herein.
Pollutants Mixing Zone
Aluminum 125,600 M2 31 Acres
Copper 125,600 M2 31 Acres
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15.
Cyanide 125,600 M
Iron
Mercury
Silver
Oil and Grease
Selenium
Chlorides 80 M:
Variances to Water Quality Standards
125,600 M
125,600 M2
125,600 M2
125,600 M2
80 M2
31 Acres
31 Acres
31 Acres
31 Acres
31 Acres
0.02 Acres
0.02 Acres
In accordance with the provisions of Sections
403.201 and 403.511(2), F.S., Jacksonville Electric
Authority is hereby granted variances to the water
Quality Standards of Chapter 17-3.121, F.A.C., for
Aluminum, Copper, Iron, Mercury and Silver and 17-3.061,
F.A.C., for Oil and Grease but only at such times as the
natural background levels of the St. Johns River approach
or exceed those standards. In any event, the discharge
from the SJRPP shall comply with the effluent limitations
set forth in paragraph II.A.16. The variances for
mercury, copper, and silver shall only be for two years
from the commencement of commercial operation, but may
be extended by the Secretary based on results of mon-
itoring data on wastewater treatment plant efficiency and
ambient water quality and bioassays performed for copper,
mercury, and total residual chlorine. A Bioassay test
program shall be implemented after review and approval by
the Department. The test program shall be submitted to
the Department by December 1, 1983. The Department shall
indicate its approval or disapproval within 60 days.
16. Effluent Limitations
The following effluent limitations shall apply for
Aluminum, Copper, Iron, Mercury, Silver, and Oil and
Grease at the locations specified:
a. Cooling Tower Slowdown - Cycles of concentration on
a daily average shall not exceed 1.5: Daily aver-
age concentrations of chemicals in-^the cooling tower
blowdown shall not exceed 1.5 times the concen-
trations present in the intake of the applicant's
Northside Generating Station.
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Wastewater Treatment Facility Discharge - Instan-
taneous maximum concentrations shall not exceed:
Aluminum
Copper
Iron
Mercury
Silver
Oil and Grease
1.5 mg/1
1.0 mg/1
mg/1
ug/1
ug/1
1.0
41.1
6.4
20 mg/1
c. POD to the St. Johns River - Copper concentrations
shall not exceed 0.18 mg/1.
B. Water Monitoring Programs
The permittee shall monitor and report to the Department
the listed parameters on the basis specified herein. The
methods and procedures utilized shall receive written approval
by the Department. The monitoring program may be reviewed
annually by the Department, and a determination may be made as
to the necessity and extent of continuation, and may be
modified in accordance with Condition No. XXV.
1. Chemical Monitoring
The following parameters shall be monitored during
discharge as shown, commencing with the start of com-
mercial operation of SJRPP and reported quarterly to the
Department's St. Johns River Subdistrict Office:
Parameter Location
Flow, Groundwater Well field Pipeline
Flow, Cooling
Water Make-up
Flow, Cooling
Tower Slowdown
Flow, CWTF*
Flow, Oily Waste-
Water col-
llection
Basin
Intake
Cooling Towers
Prior to Pump
Sump
Prior to Pump
Sump
Sample Type
Recorder
Pump Logs
Pump Logs
Pump Logs
Pump Logs
Frequency
Continuous
Daily
Daily
Daily
Daily
*CWTF = Central Wastewater Treatment Facility
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PH
Temperature
TSS
Chlorine .Total
Residual
Free Availahlp
Oil and Grease
Metals
Aluminum
Arsenic
Chromium
Copper*
Cyanide**
Iron
Selenium
Silver
Zinc
BOD
COD
**
At POD also
At Intake only
Pump Sump
Outfall to NGS
Outfall to NGS
Recorder
Grab
Recorder
Oily Waste Basin,
Metal Cleaning
Waste Retention
Basin
CWTF and Sewage
Treatment Facility ft hnur
Grab
24 Hour Composite
Cooling Tower
Blowdown Pnn and
intake Discharge
to Browns Creek
(During con-
struction only)
Tnwpr
Multiple Grab
Continuous
One/per week
Continuous
Two/per week
One/day
Two/week
Monthly
Weekly
Oily Wastewater
Collection
Metal Cleaning
Waste Retention
Basin CWTF
Rrnwn ' «;
3 Grab Composite Two/week
As described—in rnnrH-Hnn TV A
Intake and Sump
Pump
24 Hour Composite
Once/week
starting 90
days after
commercial
start-up for
three months,
two/month
for the next
six months, then
monthly there-
after
»*
»*•*
STP Influent
and effluent
Metal Clean-
ing Waste
Facility
8 Hour Composite
24 Hour Composite
Monthly
Daily
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Phosphorus
Copper
Iron
Cycles-of-con-
centration
Metal Cleaning
Facility
24 Hour Composite
Daily (when
discharged)
II II II 1C II I
Cooling tower Calculation
Groundwater Monitoring
The groundwater levels shall be monitored con-
tinuously at selected wells as approved by the St.
Johns River Water Management District. Chemical
analyses shall be made on samples from all monitored
wells identified in Condition III. F. below. The
location, frequency and selected chemical analyses
shall be as given in Condition III.F.
The groundwater monitoring program shall be
implemented at least one year prior to operation of
SJRPP Unit 1. The chemical analyses shall be in
accord with the latest edition of Standard Methods
for the Analysis of Hater and Wastewater. The data
shall be submitted within 30 days of collection/-
analysis to the St. Johns River Water Management
District and to the DER St. Johns River Subdistrict
Office.
III. Groundwater
A. General
The use of groundwater from the well field for plant
service water for SJRPP shall be minimized to the greatest
extent practicable, but in no case shall exceed 7.6 mgd on a
maximum daily basis from any new wells or 5.1 mgd on an
average annual basis.
B. Well Criteria
The submission of well logs and test results and lo-
cation, design and construction of wells to provide plant
service water shall be in accordance with applicable rules of
the Department of Evironmental Regulation and the St. Johns
River Water Management District(SJRWMD). Total water use per
month shall be reported quarterly to SJRWMD commencing-with
the start of construction.
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C. Well Withdrawal Limits
JEA is authorized to make a combined average annual
withdrawal of 5.1 million gallons o.f water per day with a
maximum combined withdrawal rate not to exceed 7.6 million
gallons during a single day. Withdrawals may be made from a
well field consisting of up to four (4) wells whose approximate
locations are described in Figure 1.
After wells have been constructed, St. Johns River Water
Management District may evaluate the individual wells and may
recommend to the Department authorization of different with-
drawals based upon hydrologic characteristics for the in-
dividual wells. The Department pursuant to Section 403.516,
F.S. may modify the above withdrawal limitations with the
concurrence of SJRWMD and the permittee.
D. Water Use Restriction
Said water is restricted to uses other than main steam
condensing. Any change in the use of said water will require
a modification of this condition.
E. Emergency Shortages
In the event an emergency water shortage should be
declared pursuant to Section 373.175 or 373.246, F.S., by St.
Johns River Water Management District for an area including
the location of these withdrawal points, the Department
pursuant to Section 403.516, F.S., may alter, modify, or
declare to be inactive, all or parts of Condition III. A.-F.
An authorized Water Management District Representative, at any
reasonable time, may enter the property to inspect the facilities,
F. Monitoring and Reporting
JEA shall, within the time limits hereinafter set forth,
complete the following items.
1. JEA shall install a flow meter for the production well-
field and will maintain pump logs for operation of each
production well in compliance with SJRWMD specifications
on all production wells.
2. JEA shall submit to SJRWMD, on forms available from the
District, a record of pumpage for each meter installed in
F.I, above. Said pumpage shall be provided on a monthly
basis, and shall be submitted by April 15, July 15,
October 15, and January 15 for each preceding calendar
quarter.
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t-
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3. JEA shall maintain and operate a continuous water level
recorder on the standby production well located at the
test site in Duval County, Florida. Detailed hydrographs
of water level fluctuations shall be constructed with the
data collected from the water level recorder and shall be
submitted to SJRWMD by April 15, July 15, October 15, and
January 15 for each preceding calendar quarter.
4. Water quality analysis shall be performed on water
withdrawn from each production well. The water samples
collected from each of the wells shall be collected
immediately after removal by pumping of a quantity of
water equal to at least two casing volumes. The JEA and
staff of SJRWMD may determine and adjust the intervals to
be monitored in accordance with hydrologic conditions
determined from drilling logs. The water quality analyses
shall be performed monthly during the first year of
operation, quarterly during the second year and twice
each year (May and September) thereafter. Results shall
be submitted to SJRWMD and the Bio-Environmental Services
Division (3ES) within 45 days after following such anal-
yses were performed. Testing for the following para-
meters is required:
a. When Drilled:
Calcium Magnesium Sodium
Potassium Bicarbonate Sulfate
Chloride Nitrate Total Dissolved Solids
Specific con- Gross Alpha Total Phosphate
ductance
Radium 226 (only Radiation
if gross Alpha
is greater than
15 pci/1)
b. During operation:
Chloride, Sulfate, Specific Conductance, Nitrate and Total
Dissolved Solids.
5. In the event that SJRWMD or BES determines there is a
significant change in the water quality (substantially
caused by SJRPP and causing a potentially significant
effect on water use), the Department may propose pursuant
to Section 403.516, F.S., that the permittee be required
to reduce or cease withdrawal from these groundwater
sources and that additional parameters be monitored.
15
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6. Minimum Water Level Restrictions
If the Department and SJRWMD at a future date establish a
minimum water level of general applicability to all users in
the aquifer or aquifers hydro!ogically associated with these
withdrawals, they may propose pursuant to Section 403.516,
F.S. that JEA reduce or cease withdrawal from these ground-
water sources at times when water levels fall below these
mini mums.
G. Shallow Aquifer Monitoring Wells
After consulation with the DER and SJRWMD, JEA shall install
a monitoring well network to monitor groundwater quality hori-
zontally and vertically through to the top of the Hawthorne For-
mation's first clayey lithologic Unit. Groundwater quantity and
flow directions will be determined seasonally at the site through
the preparation of seasonal watertable contour maps, based upon
water level data obtained during the applicants preoperational
monitoring program. From these maps the water quality monitoring
well network will be located. Monitoring well locations and de-
signs shall be submitted to the Department and SJRWMD for review.
Approval or disapproval of the locations and design shall be granted
within 60 days. Monitoring wells shall be installed upgradient and
downgradient from each solid waste disposal area, each liquid waste
pond and each coal pile storage area. An additional monitoring
well will be placed immediately downgradient of the first section
of each solid waste landfill to be utilized. Insofar as possible,
these monitoring wells may be selected from the existing wells and
piezometers used in the permittees preoperational monitoring pro-
gram. Existing wells will be properly sealed in accordance with
Chapter 17-21, F.A.C., whenever they are abandoned due to con-
struction of facilities or landfill cells. The water samples
collected from each of the monitor wells shall be collected im-
mediately after removal by pumping of a quantity of water equal to
at least two casing volumes. The water quality analyses shall be
performed monthly during the year prior to commercial operation and
quarterly thereafter. Results shall be submitted to the Department
and the SJRWMD by the fifteenth (15th) day of the month following
the month during which such analyses were performed. Testing for
the following constituents is required around unlined ponds or
storage areas.
TDS Cadmi urn
Conductance Zinc
pH Copper
Redox Nickel
Sulfate Selenium
Sulfite Chromium
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Color Arsenic
Beryl!ium
Chloride Mercury
Iron Lead
Aluminum Gross Alpha
Conductivity shall be monitored in wells around all lined
solid waste disposal sites, coal piles, and wastewater treat-
ment and sedimentation ponds.
H. Leachate
1. Zone of Discharge
Leachate from the solid waste landfills, sludge
disposal test cells, coal storage piles, wastewater
treatment ponds, or sedimentation ponds shall not con-
taminate waters of the State (including both surface and
groundwaters) in excess of the limitations of Chapter 17-
3, FAC., beyond the boundary of a zone of discharge
extending to the top of the Hawthorne Formation below the
waste landfill cell or pond rising to a depth of 50 feet
at a horizontal distance of 200 feet from the edge of the
landfill or ponds; provided that DER may provide a
larger zone of discharge if warranted by the solidwaste
test program.
2. Corrective Action
When the groundwater monitoring system or solid
waste test program shows a potential for violation of the
groundwater water quality standards of Chapter 17-3, FAC,
at the boundary of the zone of discharge, the appropriate
ponds, FGD landfill, or coal pile shall be bottom sealed,
relocated, or the operation of the affected facility
shall be altered in such a manner as to assure the
Department that no violation of the groundwater standards
will occur beyond the boundary of the zone of discharge.
IV. Control Measures During Construction
A. Stormwater Runoff
During construction, appropriate measures shall be used
to settle, filter, treat or absorb silt-containing or pol-
lutant-laden Stormwater runoff to limit the suspended solids
to 50 mg/1 or less at the POD during rainfall periods less
than the 10-year, 24 hour rainfall, and to prevent an increase
17
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in turbidity of more than 50 Jackson Turbidity Units above
background in waters of the State beyond 50 meters from the
POD to Brown's Creek. Oil and grease shall not exceed 5 mg/1
at the discharge from the borrow pit into Brown's Creek.
Control measures shall consist at the minimum of sediment
traps, barriers, berms or vegetative planting. Exposed or
disturbed soil shall be protected as soon as possible to
minimize silt- and sediment-laden runoff. The pH shall be
kept within the range of 6.0 to 8.5 at the POD.
Final drainage plans iVTustrating any stormwater treat-
ment facilities and conveyances for construction phases and
ultimate operations for both the entire St. Johns River Power
Park site and the Blount Island coal site shall be submitted
to the St. Johns River Subdistrict Manager and the St. Johns
River Water Management District for review and approval prior
to construction of any such conveyance or facility. The
Department shall indicate its approval or disapproval within
60 days of the submittal.
Stormwater drainage to Brown's Creek and Brown's Creek
proper shall be monitored as indicated below beginning as soon
as possible but not less than 30 days prior to the commence-
ment of construction and continuing throughout construction:
Monitoring Point Parameters Frequency Sample Type
*Stormwater drainage BOD5, TOC, sus- ** **
to Brown's Creek from pended solids,
existing borrow pit turbidity, dis-
in southeast portion solved oxygen,
of site pH, TKN, Total
phosphorus,
Fecal Coliform,
Total Coifform
Oil and Grease ** **
*West Fork of Brown's BODS, TOC, sus- ** **
Creek at Point Down- pended solids,
stream from entry of turbidity, dis-
of stormwater from solved oxygen,
Power Park site by pH, TKN, Total
way of a borrow pit phosphorus, fecal
coliform, Total
coliform
*Monitoring shall be conducted at suitable points for allowing a com-
parision of the characteristics of pre-construction and construction
phase drainage and receiving waters.
**The frequency and sample type shall be as outlined in a sampling
program prepared by the applicant and submitted by February 15, 1982,
for review and approval by the St. Johns River Subdistrict Manager and
the St. Johns River Water Management District. The districts will
indicate their approval or disapproval within 30 days of submittal.
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B. Sanitary Wastes
Disposal of sanitary wastes from construction toilet
facilities shall be in accordance with applicable regulations
of the Department and appropriate local health agency. The
sewage treatment plant shall be operated in accordance with
Chapters 17-3, 17-6, 17-16, and 17-19, FAC. The discharge of
total residual chlorine to Brown's Creek from the borrow pit
shall not exceed 0.01 mg/1.
/
C. Environmental Control Program
An environmental control program shall be established
under the supervision of a qualified person to assure that all
construction activities conform to good environmental practices
and the applicable conditions of certification.
The permittee shall notify the Department by telephone if
unexpected harmful effects or evidence of irreversible environ-
mental damage are detected during construction, shall im-
mediately report in writing to the Department and shall
within two weeks provide an analysis of the problem and a plan
to eliminate or significantly reduce the harmful effects or
damage and a plan to prevent reoccurrence.
D. Construction Dewatering Effluent
Construction dewatering effluent shall be treated when
appropriate to limit surface water discharges of suspended
solids to no more than 50 mg/1. The discharge of construction
dewatering liquids shall not cause turbidity in excess of 50
Jackson Turbidity Units above ambient beyond a 20 meter radius
from the point of discharge. Weekly grab samples will be
collected and analyzed for suspended solids. ~
A program for controlling the groundwater impacts of
construction dewatering shall be submitted to the Department
and the St. Johns River Water Management District for review
prior to implementation.
V. Solid Wastes
Solid wastes resulting from construction or operation shall be
disposed of in accordance with the applicable regulations of
Chapter 17-7, FAC. The permittee shall submit a program for
approval outlining the methods to be used in handling and disposal
of solid wastes. Such program shall indicate at the least methods
for erosion control, covering, vegetation and quality control.
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Open burning in connection with land clearing shall be in
accordance with Chapter 17-5, FAC. No additional permits shall be
required, but the Division of Forestry shall be notified prior to
burning. Open burning shall not occur if the Division of Forestry
has issued a ban on burning due to fire hazard conditions.
VI. Operation Safeguards
The overall design, layout, and operation of the facilities
shall be such as to minimize hazards to humans and the environment.
Security control measures shall be utilized to prevent exposure of
the public to hazardous conditions. The Federal Occupational
Safety and Health Standards will be complied with during con-
struction and operation. The Safety Standards specified under
Section 440.56, F.S., by the Industrial Safety Section of the
Florida Department of Commerce will also be complied with.
VII. Screening
The permittee shall provide screening of the site to the
extent feasible through the use of aesthetically acceptable struc-
tures, vegetated earthen walls and/or existing or planted vege-
tation.
VIII.Potable Water Supply System
The potable water supply system shall be designed and operated
in conformance with Chapter 17-22, FAC. Information as required in
17-22.108 shall be submitted to the Department prior to construc-
tion and operation. The operator of the potable water supply
system shall be certified in accordance with Chapter 17-16, FAC.
IX. Transformer and Electric Switching Gear
The foundations for transformers, capacitors, and switching
gear necessary to connect SJRPP Units 1 & 2 to the existing dis-
tribution system shall be constructed in such a manner as to allow
complete collection and recovery of any spills or leakage of oily,
toxic, or hazardous substances.
X. Toxic, Deleterious, or Hazardous Materials
The spill of any toxic, deleterious, or hazardous materials
shall be reported in the manner specified by Condition XV.
— XI. Construction in Waters of the State
A. No construction on sovereign submerged lands shall commence
without obtaining lease easement or title from the Department
of Natural Resources and/or Trustees of the Internal Improve-
ment Trust Fund.
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Construction of intake and discharge structures, coal un-
loading wharf, and transmission towers shall be done in a
manner to minimize turbidity. Turbidity screens should be
used to prevent turbidity in excess of 50 JTUs above back-
ground beyond 150 meters from the dredging, pile driving, or
construction site.
All spoil from connecting the SJRPP intake/discharge system to
the NGS, and the coal unloading wharf shall be piped hydrau-
lically or trucked to an upland disposal site of sufficient
capacity to retain all material. Spoil from construction
access canals shall be side cast and used for restoring
natural bottom contours upon completion of construction.
C. Variances
1. Variances to the provisions of Section 17-3.061(h) for
lead and Section 17-3.121(27) for silver for a period not
to exceed a cumulative total of twelve months commencinq
on the start of dredging activities are granted in
accordance with Sections 403.201(1)(c) and 403.511(2),
F.S. at the coal unloading facility wharf site on Blount
Island. Concentrations of at the boundary of a 150 meter
radius mixing zone shall not exceed the following:
Lead 62 u g/1
Silver 6.1 u g/1
2. Variances to the provisions of Sections 17-3.121(9) for
cadmium, 17-3.061(h) for lead, 17-3.121(18) for mercury
and Section 17-3.121(27) for silver are granted pursuant
to the provisions of Sections 403.201(l)(c) and 403.511(2),
F.S. at the spoil area site overflow for a period not to
exceed a cumulative total of twelve months starting with
commencement of dredging activities. Concentrations at
the boundary of a 150 meter radius mixing zone shall not
exceed the following:
Cadmium 8.2 u g/1
Mercury 0.2 u g/1
Lead 62 u g/1
Silver 6.1 u g/1
D. Mixing Zones
During dredging activities mixing zone radii are designated
for the following parameters:
Distance to Edge
of Mixing Zone^
Parameter (m)
Aluminum 150
Antimony 13
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150
150
Cyanide 19
Iron 150
Lead . 150
Mercury 150
Oil and Grease 25
Silver . 150
XII. Solid Waste Landfill
A. The proposed solid waste landfill area shall be monitored and
studied pursuant to a detailed groundwater testing and mon-
itoring program as defined in Condition III, G. The results
of the program will be used by the Department in determining
whether JEA has affirmatively demonstrated that Florida Water
Criteria (Chapter 17-3, F.A.C.) will not be violated.
B. JEA may implement a test program to demonstrate the quality
and quantity of leachate from an unlined or uncontrolled waste
facility. During the testing program, JEA shall either
provide an impermeable liner under the solid waste disposal
areas or shall utilize a chemical fixation process, stabi-
lization or other approved methods to control leachate from
the solid waste. Upon an affirmative showing that an un-
controlled solid waste facility will not cause violation of
groundwater quality criteria, the Department may approve use
of non-lined or uncontrolled landfill cells.
C. JEA shall utilize solid waste disposal area "B", north of
Island Drive or the area previously designated for the bottom
ash pond, prior to using disposal area "A".
D. Construction of perimeter berms shall be in conformance with
the provisions of Chapter 17-9, F.A.C., regarding earthen
dams.
E. Prior to the commencement of operation of solid waste disposal
areas the following shall be submitted to the St. Johns River
Subdistrict Manager for review and approval:
(1) Plot plan - should be drawn on a scale not greater than
200 ft. to the inch showing the following:
a. Dimensions and legal description of the site.
b. Location and depth corrected to MSL of soil borings.
c. Proposed trenching plan.
d. Cover stock piles.
e. Fencing or other measures to restrict access.
f. Cross sections showing both original and proposed
fill elevation.
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g. Location, depth corrected to MSL and construction
details of monitoring wells.
(2) Design Drawings and Maps - may be combined with plot plan
and should be drawn on a scale not greater than 200 ft.
to the inch showing the following:
a. Topographic map with five foot contour intervals.
b. Proposed fill area.
c. Borrow area.
d. Access roads.
e. Grades required for proper drainage.
f. Typical cross sections of disposal site including
lifts, borrow areas and drainage controls.
g. Special drainage devices.
(3) Soil map, Interpretive Guide Sheets, and a report giving
the suitability of the site for such an operation.
(4) Contingency plan, including waste handling and disposal
methods, in case of an emergency such as equipment
failure, natural disaster or fire.
(5) Operation plans to direct and control the use of the
site.
(6) An indication by discussion or drawings or both of how
the site is designed to meet water quality standards of
Chapter 17-3 and 17-4 FAC at the boundary of the zone of
discharge.
Based on the Department's reviews of the above, additions
to or modifications of the overall monitoring program may
be required for monitoring of runoff, groundwaters, and
surface waters which may be affected by the various
landfill ing operations.
The Department shall indicate its approval or disapproval
of the submitted plans, drawings, maps, analyses and
contingency plans within 60 days.
XIII. Transmission Lines
A. General
1. Filling and construction in water of the State shall be
minimized to the extent practicable. No such activities
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shall take place without obtaining lease, title or
easement from the Department of Natural Resources and/or
TIITF where required. Construction and access roads
should avoid wetlands and be located in surrounding
uplands.
2. Placement of fill in wetland areas shall be minimized by
spanning such areas with the maximum span practicable.
3. The Department may determine that any fill required in
wetlands for construction but not required for main-
tenance purposes shall be removed and the ground restored
to its original contours after transmission line place-
ment.
4. Where fill in wetlands is necessary for access, keyhole
fills from upland areas should be oriented as nearly
parallel to surface water flow lines as possible.
5. Sufficient size and number of culverts or other struc-
tures shall be placed through fill causeways to maintain
substantially unimpaired sheet flow.
6. Turbidity control measures, including but not limited to
hay bales, turbidity curtains, sodding, mulching and
seeding, shall be employed to prevent violation of water
quality standards.
7. The Right-of-Way shall be located so as to minimize
impacts in or on stream beds such as the removal of
vegetation, to the extent practicable. Within 25 feet of
the banks of any streams, rivers, or lakes, vegetation
shall be left undisturbed, except for selective topping
of trees or removal of trees which topping would kill.
If it is necessary to remove such trees within 25 feet of
the banks of streams,- rivers, or lakes, the root mat
shall be left undisturbed.
8. Any necessary water quality certifications which must be
made to the Corps of Engineers for water crossings not
identified in the applications in this proceeding shall
be made at the time of a finding of compliance for specific
work at specific locations.
9. Construction activities should proceed as much as prac-
ticable during the dry season.
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B. Other Construction Activities
1. Maintenance roads under control of the permittee shall be
planted with native species to prevent erosion and
subsequent water quality degradation where drainage from
such roads would impact waters of the State significantly.
2. Good environmental practices such as described in
Environmental Criteria for Electric Transmission Systems
as published by the U.S. Department of Interior and the
U.S. Department of Agriculture shall be followed to the
extent practicable.
3. Compliance with the most recent version of the National
Electric Safety Code adopted by the Public Service
Commission is required.
4. Fences running parallel to the transmission line which
may become conductive shall be grounded at appropriate
intervals; fences running perpendicular to the line shall
be grounded at the edge of the right-of-way.
5. Where suitable habitat is present, field reconnaissance
of rare and endangered species shall be performed in
order to minimize impacts on these species.
6. Open burning in connection with land clearing shall be in
accordance with the applicable rules of the Department of
Agriculture and Consumer Services. No additional permits
shall be required, but the Division of Forestry shall be
notified prior to burning. Open burning shall not occur
if the Division of Forestry has issued a ban on burning
due to fire hazard conditions.
C. Maintenance
1. Vegetative clearing operations for maintenance purposes
to be carried out within the corridor shall follow the
general standards for clearing right-of-way for overhead
transmission lines as referenced in Sections XIII. A.7.
and XIII.B.2. Selective clearing of vegetation is pre-
ferred over clearing and grubbing or clear cutting.
2. If chemicals or herbicides are to be used for vegetation
control, the name, type, proposed use, locations, and
manner of application shall be provided to the Department
prior to their application for assessment of compliance
with applicable regulations.
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D. Archaeological Sites
Any archaeological sites discovered during construction of the
transmission lines shall be disturbed as little as possible
and such discovery shall be communicated to the Department of
State, Division of Archives, History and Record Management
(DAHRM). Potentially affected areas will be surveyed, and if
a significant site is located, the site shall be avoided,
protected, or excavated as directed by DAHRM.
E. Road Crossing
For all locations where the transmission line will cross State
highways, the applicant will submit materials pursuant to the
Department of Transportion's (DOT) "Utility Accomodation
Guide" to DOT'S district office for review and approval. All
applicable regulations pertaining to roadway crossings by
transmission lines shall be complied with.
F. Emergency Reporting
Emergency replacement of previously existing right-of-way or
transmission lines shall not be considered a modification
pursuant to Section 403.516, F.S. A verbal report of the
emergency shall be made to the Department as soon as possible.
Within fourteen (14) calendar days after correction of the
emergency, a report to the Department shall be made outlining
the details of the emergency and the steps taken for its
temporary relief. The report shall be a written description
of all of the work performed and shall set forth any pollution
control measures or mitigative measures which were utilized or
are being utilized to prevent pollution of waters, harm to
sensitive areas or alteration of archaeological or historical
resources.
G. Final Right-of-Way Location
A map of 1:24000 scale showing final location of the right-of-
way shall be submitted to the Department upon completion of
acquisition.
H. Compliance
Construction and maintenance shall comply with the applicable
rules and regulations of the Department and those agencies
specified in 17-17.54(2)(a) and (b), FAC.
XIV. Change in Discharge
All discharges or emissions authorized herein shall be con-
sistent with the terms and conditions of this certification. The
discharge of any pollutant not identified in the application or any
26
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discharge more frequent than, or at a level in excess of, that
authorized herein shall constitute a violation of the certifi-
cation. Any anticipated facility expansions, production increases,
or process modification which will result in new, different or
increased discharges or expansion in steam generating capacity will
require a submission of new or supplemental application pursuant to
Chapter 403, F.S.
XV. Non-Compliance Notification
If, for any reason, the permittee does not comply with or will
be unable to comply with any limitation specified in this certi-
fication, the permittee shall notify the manager of DER's St. Johns
River subdistrict office by telephone during the working day in
which permittee becomes aware of said non-compliance and shall
confirm this situation in writing within seventy-two (72) hours
supplying the following information:
a. A description and cause of non-compliance; and
b. The period of non-compliance, including exact dates and
times; or, if not corrected, the anticipated time the
non-compliance is expected to continue, and steps being
taken to reduce, eliminate and prevent recurrence of the
non-complying event.
XVI. Facilities Operation
The permittee shall at all times maintain in good working
order and operate as efficiently as possible all treatment or
control facilities or systems installed or used by the permittee to
achieve compliance with the terms and conditions of this certi-
fication. Such systems are not to be bypassed without prior
Department approval. Exceptions such as that during periods when
light oil is used for ignition, or as provided in 40 CFR 60 Subpart
Da, allow that the FGD system may be bypassed.
XVII. Adverse Impact
The permittee shall take all reasonable steps to minimize any
adverse impact resulting from non-compliance with any limitation
specified in this certification, including, but not limited to,
such accelerated or additional monitoring as necessary to determine
the nature and impact of the non-complying event.
XVIII. Right of Entry
The permittee shall allow the Secretary of the Florida
Department of Environmental Regulation and/or authorized repre-
sentatives, upon the presentation of credentials:
27
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a. To enter upon the permittee's premises where an effluent
source is located or in which records are required to be
kept under the terms and conditions of this permit; and
b. to have access to and copy all records required to be
kept under the conditions of this certification; and
c. to inspect and test any monitoring equipment or mon-
itoring method required in this certification and to
sample any discharge or pollutants; and
d. to assess any damage to the environment or violation of
ambient standards.
XIX. Revocation or Suspension
This certification may be suspended or revoked pursuant to
Section 403.512, Florida Statutes, or for violations of any Con-
dition of Certification.
XX. Civil and Criminal Liability
This certification does not relieve the permittee from civil
or criminal responsibility or liability for non-compliance with any
conditions of this certifiation, applicable rules or regulations of
the Department, or Chapter 403, Florida Statutes, or regulations
thereunder.
Subject to Section 403.511, Florida Statutes, this certi-
fication shall not preclude the institution of any legal action or
relieve the permittee from any responsibilities or penalties
established pursuant to any other applicable State Statutes or
regulations.
XXI. Property Rights
The issuance of this certification does not convey any property
rights in either real or personal property, tangible or intangible,
nor any exclusive privileges, nor does it authorize any injury to
public or private property or any invasion of personal rights, nor
any infringement of Federal, State or local laws or regulations.
The applicant will obtain title, lease or right of use to any
sovereign submerged lands occupied by the plant, transmission line
structures, or appurtenant facilities from the State of Florida.
XXII.Severability
The provisions of this certification are severable, and, if
any provision of this certification or the application of any
provision of this certification to any circumstances is held
invalid, the application of such provision to other circumstances
and the remainder of the certification shall not be affected
thereby.
28
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XXIII.
Definitions
XXIV.
The meaning of terms used herein shall be governed by the
definitions contained in Chapter 403, Florida Statutes, and any
regulation adopted pursuant thereto. In the event of any dispute
over the meaning of a term used in these general or special con-
ditions which is not defined in such statutes or regulations, such
dispute shall be resolved by reference to the most relevant de-
finitions contained in any other state or federal statute or
regulation or, in the alternative, by the use of the commonly
accepted meaning as determined by the Department.
Review of Site Certification
The certification shall be final unless revised, revoked or
suspended pursuant to law. At least every five years from the date
of issuance of this certification or any National Pollutant Dis-
charge Elimination System Permit issued pursuant to the Federal
Water Pollution Control Act Amendments of 1972 for the plant units,
the Department shall review all monitoring data that has been
submitted to it during the proceeding five-year period for the
purpose of determining the extent of the permittee's compliance
with the conditions of this certification of the environmental
impact of this facility. The Department shall submit the results
of its review and recommendations to the permittee. Such review
will be repeated at least every five years thereafter.
XXV. Modification of Conditions
The conditions of this certification may be modified in the
following manner:
A. The Board hereby delegates to the Secretary the authority
to modify, after notice and opportunity for hearing, any
conditions pertaining to consumptive use of water,
monitoring, sampling, groundwater, mixing zones, zones of
discharge, leachate control programs, effluent limitations,
air emission limitations or variances to water quality
standards.
B. All other modifications shall be made in accordance with
Sections 403.516, Florida Statutes.
XXVI. Flood Control Protection
The plant and associated facilities shall be constructed in
such a manner as to comply with the Duval County flood protection
requirements.
XXVII.
Effect of Certification
Certification and conditions of certification are predicated
upon design and performance criteria indicated in the application.
Thus, conformance to those criteria, unless specifically amended,
29
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modified, or as the Department and parties are otherwise notified,
is binding upon the applicant in the preparation, construction and
maintenance of the certified project. In those instances where a
conflict occurs between the application's design criteria and the
conditions of certification, the conditions shall prevail.
XXVIII. Noise
To mitigate the effects of noise produced by the steam blowout
of steam boiler tubes, JEA shall conduct public awareness campaigns
prior to such activities to forewarn the public of the estimated
time and duration of the noise.
XIX. Archaeological Sites
The following archaeological sites shown in Figure 2 shall be
preserved whenever practical. If they must be altered by con-
struction, then archaeological salvage excavation shall be per-
formed prior to construction under the supervision of the Florida
Department of State, Division of Archives, History and Records
Management.
Site - 8Du669 8Du670
8Du671 8Du673
8Du674 8Du675
8Du677 SDu678
XXXI. Blount Island Coal Unloading Facility
Area drainage and rainfall runoff from the lined coal pile on
Blount Island shall be directed to a lined treatment system designed
to process the runoff from the 24-hour, ten-year storm. Wastewater
treatment shall consist of as a minimum: removal of solids and
metals by precipitation and sedimentation followed by pH adjustment
to no less than 8.0 and final disposal by percolation. Sufficient
capacity shall be provided to allow for accumulation of settled
solids of up to 20 percent of the total pond volume. Solids
removed from the sedimentation pond shall be disposed in a properly
designed landfill.
The sedimentation pond liner shall be impervious and designed
for the life of the facility. The liner shall be installed in such
a manner as to prevent rupture during cleaning or removal of
solids.
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- SITE BOUNDARY is.is
\. 8DU 674 >x
/'OArchaeological Site
^"^ wich Sice Number
Fence Line
,--x/
I 7." /\~, . f ;• i
SEDIMENTATION POND /
' - \^
Protected
Wetlands
0 200 400 600
•=••=
Meters
FIGURE 2
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APPENDIX 6.3
USFWS SECTION 7 ADDENDUM
160
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
15 NORTH LAURA STREET
JACKSONVILLE, FLORIDA 32202
January 29, 1982
Mr. Robert B. Howard
Chief, EIS Preparation Section
U.S. Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
FWS Log No. 4-1-81-134
Dear Mr. Howard:
On December 9, 1981, the Service issued a Biological Opinion to your
agency with reference tu i-he issuance of a new source NPDES permit to
Jacksonville Electric Authority for the St. Johns River Power Park. The
proposed action involves the construction of a new 1,200 megawatt coal-
fired generating station at the Eastport site in Jacksonville, a coal
unloading facility on Blount Island and attendant transmission lines.
On March 16, 1981, the Jacksonville District Corps of Engineers (COE),
issued Public Notice 81P-0298 covering, in part, the dredging necessary
for the coal unloading facility and transmission line towers in Mill
Cove.
Dredging of approximately 21 acres will be required in the area of the
proposed ocean vessel coal unloading wharf. It will be dredged to a
depth of 38 feet below MSL, which is consistent with the design depth of
the Fulton-Dame Point Cutoff Channel. A total of 551,000 cubic yards of
material will be removed from this area. Of this total, 381,000 cubic
yards is suitable for fill material and 170,000 is spoil material, which
will be disposed of on Quarantine Island.
Construction of the transmission line towers in the Mill Cove area will
be accomplished via a barge mounted crane. A temporary channel will be
required for access into Mill Cove. The channel will be approximately
45 feet in width and -8 feet MSL in depth (worst case.) It is estimated
that approximately 45,000 cubic yards of material will have to be dredged,
assuming maximum barge draft and beam. The dredged material will be
temporarily placed at the side of the construction channel and turbidity
screens will be used where necessary. As each tower is completed, the
dredged material will be backfilled into the channel, restoring it to
its original level.
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We stated in our Biological Opinion that we would request a seperate
Section 7 consultation from the COE with reference to the West Indian
manatee and the proposed dredging activities. It has been pointed out
to us that EPA is the lead agency for this action, therefore it is not
necessary for the COE to carry out this consultation. It is our intention,
therefore that this letter supplement our Biological Opinion, thereby
bringing to a conclusion the Secion 7 consultation regarding this action.
x
In your October 26, 1981 letter, your agency determined that the proposed
action(s) may affect listed threatened and endangered species, which
included the manatee. While manatees are year round residents of the
St. Johns River in the Jacksonville area, wich an estimated population
of 25 or more, their distribution in the river system changes with
climatic conditions. During the warmer months they are disbursed throughout
the river and its tributaries. When the water temperature of the St.
Johns River drops below 20°C they tend to seek and stay in warmer water,
and in the case of Jacksonville, this would be in the discharge water of
the Jacksonville Electric Authority's Kennedy Generating Station and the
adjacent Alton Packaging Corporation plant on Tallyrand Road, several
miles upstream from the Eastport site.
The potential of a manatee being in the area of the proposed dredging
would, therefore, be less during the colder period of the year from mid-
November through mid-March and all dredging activity should be undertaken
during this period.
Manatees will disperse, however, into other sections of the river during
extended periods of cold water when it becomes necessary for them to
feed or during warm spells, when the St. Johns River water temperatures
rise above the 20°C range. This means that even though the potential
for harm to a manatee is substantially less during the winter months it
does not preclude the presence of the animals at the Eastport site,
therefore we believe the following precautions should also be incorporated
into permits necessary to perform the required dredging work:
The contractor will instruct all personnel associated with the
construction of the project about the presence of manatees in the
area and the need to avoid collisions with manatees. All vessels
associated with the project shall operate at "no wake" speeds at
all times while in shallow waters, or channels, where the draft of
the boat provides less than three feet clearance of the bottom.
Boats used to transport personnel shall be shallow-draft vessels,
preferably of the light-displacement category, where navigational
safety permits. Vessels transporting personnel between the landing
and the dredge shall follow routes of deep water to the extent
possible. All personnel should be advised that there are civil and
criminal penalties for harming, harassing, or killing manatees,
which are protected under the Endangered Species Act and the Marine
Mammal Protection Act. The Contractor shall be held responsible
for any manatee harmed, harassed, or killed as a j-esult of the
construction of the project.
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Any collision with a manatee will be reported immediately to the
Chief, Environment and Resources Branch and the Fish and Wildlife
Service in Jacksonville. Following project completion, a report
summarizing the above incidents shall be submitted to the Chief,
Environment and Resources Branch.
Pending acceptance of these precautions, it is our Biological Opinion
v'iat the proposed dredging operations for both the coal unloading facility
and Mill Cove Transmission lines are not likely to jeopardize the continued
existence of the West Indian manatee or adversely modify its Critical
Habitat.
As stated previously, this letter is to supplement our Biological Opinion
issued to EPA on December 9, 1981. If there are any modifications made
in the project or if additional information becomes available relating
to threatened and endangered species, reinitiation of consultation may
be necessary.
Sincerely yours,
C. Grover
Acting Area Manager
WAPORA, INC.
ATLANTA OPRCS
ENVIRONMENTAL IMPACT STATEMENT
BRANCH
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11
FEB 01. 1982
REGION IV • EPA
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APPENDIX 6.4
ARCHAEOLOGICAL MEMORANDUM
OF AGREEMENT
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Advisory
Council On
Historic
Preservation
1522 K Street. NW
Washington. DC 20005
MEMORANDUM OF AGREEMENT
WHEREAS, the Environmental Protection Agency (EPA) proposes to grant a
National Pollutant Discharge Elimination System (NPDES) permit for construction
of the St. Johns River Power Park generating station, Duval County, Florida;
and,
WHEREAS, pursuant the regulations of the Advisory Council on Historic
Preservation (Council), "Protection of Historic and Cultural Properties"
(36 CFR Part 800), EPA in consultation with the Florida State Historic
Preservation Officer (SHPO) has determined that this undertaking will
have an adverse effect on the St. Johns River Power Park Archeological
District, a property eligible for the National Register of Historic Places-
and,
WHEREAS, pursuant to Section 106 of the National Historic Preservation
Act of 1966, as amended (16 U.S.C. Sec. 470(f)) and the Council's regulations
EPA has requested the comments of the Council; and,
WHEREAS, representatives of the Council, EPA, and the Florida SHPO
have consulted and reviewed the undertaking to consider alternatives to
avoid or satisfactorily mitigate the adverse effect;
NOW, THEREFORE, it is mutually agreed that the undertaking will be
implemented in accordance with the following stipulations to avoid or
mitigate the adverse effects.
Stipulations
EPA will condition its permit on compliance with the following measures.
A. Archeological Data Recovery
1- Prior to the initiation of any construction or other land-disturbing
activities which could affect archeological sites 8 DU 669, 8
DU 677, the undisturbed portion of 8 DU 634, or other sites in
the Archeological District, a detailed data recovery plan, including
a research design that addresses both regional and more general
research problems, will be developed. The plan will be prepared
in accordance with previous archeological survey and testing
results and with reference to the standards contained in the
Council's Handbook, Treatment of Archeological Properties
(Attachment 1). c
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Page 2
Memorandum of Agreement
Environmental Protection Agency
St. Johns River Power Park
2. The plan will be submitted to the Florida SHPO and the Council
for review prior to implementation. If neither party objects
within 15 working days after receipt of the plan, the plan will
be implemented; if either party objects EPA will consult with the
Florida SHPO, the Council, and the Jacksonville Electric Authority
in order to resolve the objections.
B. Archeological Site Protection
1. EPA will ensure that plans for protecting those portions of the
St. Johns River Power Park Archeological District not directly
affected by construction or other land-disturbing activities,
including fencing and access restrictions, are developed and
implemented in consultation with Florida SHPO.
C. Transmission Line Corridors
1. Prior to the selection of the final transmission line alignment,
archeological field survey(s) will be conducted in consultation
with the Florida SHPO along any portions of the proposed rights-of-
way previously identified as archeologically sensitive in "Site
Certification Application—Environmental Information Document for
Proposed St. Johns River Power Park," Appendix K (1981). Survey
work will be undertaken with reference to 36 CFR Part 66, Appendix
B (Attachment 2).
2. Identified archeological resources will be evaluated in consultation
with Florida SHPO. If there is any question as to whether a
property meets the National Register Criteria (36 CFR Sec. 60.6),
a determination of eligibility will be requested from the Secretary
of the Interior in accordance with 36 CFR Part 63. Any archeologica:
resources found to meet the Criteria will be avoided or preserved
in place whenever feasible through minor alignment shifts, tower
placement, changes in construction methods, or other measures.
When this is not feasible, the Florida SHPO will be consulted and
a treatment consistent with the Council's Handbook, Treatment of
Archeological Properties (Attachment 1) and approved by the
Florida SHPO will be developed and implemented.
D. Additional Stipulations
1. All archeological work will be conducted under the direct supervisioi
of an archeologist(s) who meets, at a minimum, the appropriate
qualifications set forth in 36 CFR Part 66, Appendix C (Attachment 3
2. All archeological materials, along with field notes, maps, drawings,
and photographic records, will be curated at a suitable repository
agreed upon by the Florida SHPO, EPA, and the Jacksonville Electric
Authority.
3. Copies of the final reports of archeological investigations will
be supplied to the Florida SHPO, the Council, and Interagency
Archeological Services (National Park Service, Department of the
Interior, Washington, D.C. 20243) for possible submission to the
National Technical Information Service (NTIS).
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Page 3
Memorandum of Agreement
Environmental Protection Agency
St. Johns River Power Park
4. In accordance with National Register precedures (36 CFR Part 60),
documentation concerning the condition and significance of the
St. Johns River Power Park Archeological District will be forwarded
within 2 years following the completion of data recovery so that
nominations, boundary changes, and eligibility status will be
kept current.
5. If any of the signatories to the Agreement determines that the
terms of the Agreement cannot be met, or believes a change is
necessary, that signatory shall immediately request the consulting
parties to consider an amendment or addendum to the Agreement.
Such an amendment or addendum shall be executed in the same
manner as the original Agreement. t
Executive Directoi
Advisory Council
Historic Preservation
Environm/ritfal Protection Agency
Region
Florida" Slate Historic PYeservatioH Offic
(date)
Chairman
Advisory Council on Historic Preservation
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APPENDIX 6.5
Pages 4-137 and 4-138 from the Draft SAR/EIS
162
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a potential for
-an
**.«.
teachate contamination of groundwater supplies
to
4.13.2 Impacts of Alternatives
A detailed assessment of net changes
and solid waste generation has been
ment includes an evaluation oi the
brief statement as to P?ten"?i2th
native with respect to human health
is based on the assumption that when
a net increase, human health is
in air emissions water di scharges . _
£ °cf Ld Sur alternatives. A
projj£jnd f^^ ^ ^
in this section. The analysis
the environment show
com?arative health
estimates of increased
4.13.2.1 Air Emissions
There is widespread agreement
can be associated with
general degradation
the young, the
are due to conversion of
addition of a refuse-fired power plant.
Alternative 1 could resu It in er
h proposed project,
elative to t p P lncreas
^ mpac t.* _
ve
in air emissions in the Jacksonville area
Hu»an health could benefit
2
ct-rd s -- s S:^^
, and trace elements. The health ett includes an FGD system to
-
higher net air
emissions in the Sanford area.
acid from proposed refuse plants.
4 13.2.2 Wastewater Discharges
4-137
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posed project, the increases are small and thus the adverse health impacts
would be less than those for the proposed project. impacts
.
p
parameter occasionally exceeds the State standards.
4.13.2.3 Other Vectors
None of the alternatives include unlined solid waste disposal facilities
"6 ""^ t0 "* N ^ ad-
I TOO
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7.0 BIBLIOGRAPHY
Breitmoser, Richard. 1981. By letter, Richard Breitmoser Division Chief,
Research and Environmental Affairs Division, Jacksonville Electric
Authority, to F. Theodore Bisterfeld, US Environmental Protection
Agency, Region IV, 10 September 1981.
EBASCO Services, Inc. 1978. 600 MW coal-fired standard plant, project
description. In: JEA/FP&L. 1981. Site certification application -
EID for proposed St. Johns River Power Park.
Envirosphere. 1982. Supplemental modeling information on in-stream
mercury concentrations for various effluent and ambient mercury
concentrations in the St. Johns River Power Park discharge,
25 March 1982, 9p.
Florida Game & Fresh Water Fish Commission. 1982. By letter, Anne E. Shapiro,
Senior Biologist, FGFWFC, to Mr. Ted Bisterfeld, US Environmental
Protection Agency, Region IV, 3 February 1982.
Jacksonville Electric Authority/Florida Power and Light Company (JEA/FP&L).
1981. Site certification application - environmental information
document for proposed St. Johns River Power Park. Prepared by
Envirosphere, Inc., variously paged.
Thompson, Don. 1982. Personal communication, Don Thompson, St. Johns River
Water Management District, to Ron McNeill, WAPORA, Inc., 2 February 1982.
Vergara, E.D. 1981. By letter, E.D. Vergara to Hamilton S. Oven, FDER,
23 July 1981, 9p.
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